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 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.
ELEXON’s response to BEIS’s consultation on the enrolment of Secure SMETS1 meters in the Data Communications Company
ELEXON’s response states that it is essential that all SMETS variants can have data collected via DCC to realise the full benefit of Market-wide Half-Hourly Settlement, and that meters which are unable to be adopted by DCC should be replaced with those that can.
ELEXON’s response to National Grid’s consultation on EBGL Article 18 terms and conditions
ELEXON’s response proposes that many of the currently proposed mappings are too broad, and should be made specifically to relevant paragraphs only.
ELEXON’s response to NIC consultation on the Future of Regulation 12 April 2019
The Government has asked the National Infrastructure Commission to assess what changes might be necessary to the existing regulatory framework to facilitate future investment needs in infrastructure focusing on energy, telecoms and water.
ELEXON response includes that:
- data and easy access to data is key to unlocking the next wave of innovation
- new regulatory design should seek to avoid further costs from any proliferation of central services and that we believe the recently launched joint BEIS/Ofgem Energy Codes Review is an ideal opportunity to look at these issues
- consolidating the code governance landscape would be beneficial to innovators
ELEXON’s response to Ofgem consultation ESO regulatory and incentives framework
Ofgem proposes that the evaluation moves from a ‘per Principle’ evaluation in 2018/19 to a ‘per Role’ evaluation for the 2019/2020 evaluation.
ELEXON believe that this move will give more flexibility to the ESO to allocate its resources and expenditure to areas where improvements will be most valuable to consumers.
However, it will also give more flexibility to the ESO to allocate its resources where it is most cost-beneficial to ESO itself, i.e. to the easier or least costly to meet targets within each role.
For that reason we continue to support both ensuring that the overall incentive is addressed to maximise end consumer benefits and that there is transparency in the detail of ESO expenditure as was proposed by Ofgem in its earlier call for input on the 2019-20 ESO regulatory and incentives framework.
ELEXON’s response to the Energy Network Association’s consultation on Phase 3 of the Open Networks Work Programme
ELEXON’s response highlights the areas of the Open Network Project likely to impact on settlement and sets out the areas of work ELEXON should be involved in to maintain consistency between national and local arrangements.
ELEXON’s response to National Grid ESO’s C16 Annual Review
ELEXON’s response suggests a number of corrections and clarifications, in particular on the treatment of replacement reserve products and the requirements of generators to provide System Ancillary Services.