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 Ofgem’s consultation on Energy Company Obligation (ECO3) methodologies for calculating electricity and gas supply volumes
ELEXON’s response sets out how the required volumes for determining Energy Company Obligation targets can be obtained from existing data flows, and where the consultation has incorrectly identified Consumption Component Classes relating to domestic consumption.
ELEXON’s Response to Ofgem’s Consultation on Refined Residual Charging Banding in the Targeted Charging Review
ELEXON’s response sets out how a BSC-based solution would work to enable fixed residual charges. We also note a number of areas which we believe require further consideration before Ofgem makes its final decision on its Targeted Charging Review proposals. These are:
- Timing – We believe that industry may not have the capacity to implement the necessary changes by April 2021, given the current change pipeline.
- Interaction with other projects – Ofgem should take opportunities, where possible, to develop common ‘whole system’ solutions and to minimise the risks of competing projects.
- Definitions – The proposals would benefit from greater clarity, e.g. in the definitions of ‘final demand’ and ‘site’.
ELEXON’s response to Ofgem’s consultation on ESO RIIO-2 financial methodology and incentives
In our response to Ofgem’s consultation, we concentrated on the design of the ESO incentives with two key messages:
- that the incentives should encourage ESO to work jointly and collaboratively with ELEXON for maximum customer benefit.
- that the incentive reporting should allow us to compare our own code management performance with that of others, including ESO.
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 BEIS’ Call for Evidence on Facilitating Energy Efficiency in the Electricity System
ELEXON’s response highlights the need for further clarity around the definition of Energy Efficiency measures. We note that non-controllable demand reduction measures should be encouraged by market signals such as Time of Use Tariffs, whilst active technologies can respond to active signals, such as those used in the Capacity Market.
ELEXON’s response to Ofgem/BEIS consultation on reforming energy industry codes
Ofgem and BEIS published their consultation on reforming the energy industry codes in July 2019, and we have published our response.
We continue to strongly support reform of the code arrangements, in particular the objective of consolidation and simplification.
Ofgem and BEIS want to deliver improvements to the codes and code governance arrangements by the mid-2020s and ELEXON will support them in doing so.
ELEXON’s response to Ofgem/BEIS consultation on Flexible Retail Markets
ELEXON’s response highlights our support for innovation and provides examples of innovation we have spoken to customers about. We requested that government and Ofgem are mindful of other industry change programmes, including the review of codes, when considering further changes to retail markets.
ELEXON’s response to the DFT’s consultation on Electric Vehicle Smart Charging
ELEXON’s response challenges OLEV’s rationale for producing a Phase 2 decision in 2023, noting that there are EV demonstration projects that will run into 2021 and the Smart Meter rollout and MHHS which are not likely to conclude until 2023-24 . Secondly, we found OLEV’s separation of public and private use cases overly simplistic, noting that there are public and private use cases that share characteristics, and could benefit from common solutions. Finally, we encourage OLEV to consolidate its and industry’s work on EVs, e.g. through the adoption of a single repository of EV issues and proposals, to facilitate holistic policy design and the identification of overlap.
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.