ELEXON responses to Industry consultations
ELEXON monitors and responds to industry-wide consultations that may have an impact on the provisions in the BSC, on ELEXON, or – through ELEXON – on our customers. Some consultations also require a response from the BSC Panel.
Please let us know if there are any industry based consultations which you feel warrant a response from us.
ELEXON’s response to the Energy Networks Association’s consultation on Flexibility
ELEXON’s response welcomes the new flexibility commitments from network companies and suggests they attempt to mark progress against these commitments, as well as map them to other initiatives to support flexibility announced over the past year.
ELEXON’s response to National Grid ESO’s consultation on Maintaining Non Half- Hourly (NHH) charging arrangements for Measurement Classes F and G
ELEXON’s response agrees that the NHH charging arrangements do need to be extended for HH Elective customers who move into Measurement Class F, in order to avoid double charging. It also notes that it is now possible to separate out demand data for Measurement Classes E, F and G from each other due to P348/349. Measurement Class F and G could be charged under separate methodologies if there is the need or desire to do so from Industry Parties.
ELEXON’s response to National Grid’s consultation on the Network Code on Emergency and Restoration: System Defence and Restoration Plans and terms and conditions amendments
ELEXON’s response suggests: a few changes to National Grid ESO’s terms and conditions for Defence Service Providers and Restoration Service Providers; and some amendments to the Plans where they relate to the BSC.
ELEXON’s response to Ofgem’s consultation on Switching Programme and Retail Code Consolidation: Proposed changes to licences and industry codes
ELEXON’s response requests further detail on cross-code cooperation and alignment, additional attention to processes, and asks for REC schedules to align with other industry-wide initiatives. We also highlight the benefits of procuring an end-to-end REC manager service, avoiding handoffs and maintaining consistency with the principle of a ‘Code Manager’.
ELEXON’s response to Scottish Power Energy Network’s consultation on USEF
ELEXON’s response highlights a number of crucial interactions between new flexibility and existing market structures and describes a number of initiatives currently underway to improve and facilitate smart and flexible energy systems, including P375, P376 and market-wide Half-Hourly Settlement.
ELEXON’s response to National Grid ESO’s consultation on amendements to EBGL Article 18 Terms and Conditions
ELEXON’s response agrees with the updated mapping proposed by National Grid ESO.
ELEXON’s response to DCUSA’s consultation on Removal of Residual Charging for Storage Facilities in the CDCM and EDCM
ELEXON’s response supports the overall intent of the modifications, which is to address concerns raised by Ofgem and BEIS by excluding imports to storage facilities from the calculation of residual DUOS charges. However, we raised concerns with the detail of the proposals:
- Inconsistencies between the DCUSA proposals and related CUSC modification proposals (i.e. CMP280/281) may result in unintended or perverse outcomes
- Aspects of the DCUSA proposals could have been explained in more detail
ELEXON will continue to support the DCP341/342 workgroup and argue the case for alignment between the DCUSA and CUSC proposals.
ELEXON’s response to National Grid’s consultation on EBGL Article 26: Proposal for Defining and Using Specific Products for balancing energy and balancing capacity
ELEXON’s response suggests National Grid ESO emphasises the unique challenges that they face which require continued use of specific products for balancing services and states that the continued use of specific products should not distort the markets for any other products.
ELEXON’s response to BEIS consultation on a Smart Export Guarantee (SEG): Part B
ELEXON’s response highlights the lack of a clear requirement to register SEG eligible installations for settlement under the BSC.
We believe that settlement of export under the BSC is key to unlocking the full system benefits of Market-Wide Half-Hourly Settlement, which will result in more accurate settlement and apportionment of costs across the system and enable more innovative supply propositions.
Therefore, we propose that the SEG requirements should explicitly require exports to be metered and settled to receive a SEG tariff. We do not believe the current proposals adequately address this.
ELEXON’s response to the Energy Networks Association’s consultation on the Future Worlds Impact Assessment
ELEXON’s response highlights the importance of distinguishing trials from enduring market frameworks and highlights a number of implicit assumptions in the analysis that may need to be surfaced and considered.