Transition to the Retail Energy Code
As part of its Retail Code Consolidation and Switching Programme Significant Code Reviews, Ofgem is intending to merge a number of existing Industry codes into the Retail Energy Code, which includes some aspects of the BSC. These changes will also require existing BSC documents to be updated where references to obsolete codes will need to be updated.
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The Retail Energy Code (REC) 2.0 and Retail Code Consolidation is due to take effect on 1 September 2021. In April 2021, following a consultation with the industry on the proposed REC schedules, Ofgem published its decision on the approach that should be taken to implement REC 2.0.
Meter Operator Agents
One of the changes introduced by REC 2.0 will result in the Meter Operator Agent (MOA) obligations set out in BSCP514 – SVA Metering Operations for Metering Systems Registered in SMRS moving from governance under the Balancing and Settlement Code (BSC) to the REC.
Under the REC arrangements, these agents will be referred to as Meter Equipment Managers (MEMs). Other than the Commissioning flows required in BSCP514, the Code of Practices (CoPs) will remain under the governance of the BSC at this time whilst they are reviewed by Issue Group 93. Once a review of the CoPs is complete, a decision on which Code their governance should sit under will be taken.
Ofgem noted in its decision letter that it would take time to set up new reporting and assurance techniques for the RECCo and it was unlikely that these arrangements would be fully operational by 1 September 2021.
Consequently, it consulted on the option of a transition period, where Elexon continued to assure the obligations moving to the REC for a period, and, given the overwhelming support for this approach in the consultation, concluded this should be put in place.
Recent Modifications, Change Proposals and Issues
- P416: Introducing a route of appeal for the Annual Budget in line with the proposals for the Retail Energy Code
Authority Led SCR Modification process
In order to give effect to its SCR decisions, Ofgem will raise Authority Led SCR Modification Proposals. These Modifications will not follow the standard Modification Procedures. Instead they will follow the timetable set by the Authority and the Authority Led SCR Modification Proposal procedure detailed in BSC Section F5.3A.
This requires the BSC Panel to submit to Ofgem an Authority Led SCR Modification Report, which needs to include an assessment of the proposal and the Panel’s views against the Applicable BSC Objectives.
Latest timeline of events
Elexon have undertaken a significant amount of redlining to facilitate the REC changes, and Authority Led SCR Modifications will be raised at various stages of the REC transition to complete the transfer and update of obligations, as highlighted below.
- 9 October 2019 – Issue 86 raised
- 15 Dec 2020 to 23 Feb 2021 – RCC SCR Ofgem consultation
- 10 May 2021 – P420 raised
- 17 May to 17 June 2021 – P420 consultation period
- 23 July 2021 – P420 decision (target)
- 1 September 2021 – REC v2.0 Go-Live (target)
- 31 March to 31 July 2021 – Switching Programme SCR Ofgem consultation (target)
- December 2021 – Switching Programme BSC Mod raised (target)
- February 2022 – Switching Programme BSC Mod submitted to Ofgem for decision
- Mid-2022 – REC v3.0 Go-Live
REC Version 2.0 makes the necessary changes required as part of Retail Code Consolidation and REC Version 3.0 makes the necessary changes required as part of the Switching Programme.
Significant Code Review
Ofgem raised P420: Retail Code Consolidation Significant Code Review (REC V2.0) on 10 May 2021. It was raised to ensure the BSC aligns with Ofgem’s Retail Code Consolidation Significant Code Review, which consolidates a number of existing codes into the REC.
P420 makes the necessary changes to reflect the code governance changes implemented through the Retail Code Consolidation SCR. Specifically, it will:
- Ensure the BSC reflects the close down of the MRA
- Transfer operational procedures relating to Metering Point Lifecycle from the MRA to the BSC
- Make the necessary changes to transfer SVA Metering arrangements to the REC, and facilitate a transition period for metering assurance
- Insert the required drafting to give effect to the CCSG, which will be established under the REC to better facilitate cross-code change
More information, including the proposed changes to the BSC for REC V2.0 can be found on the Modification web page.
Switching Programme (REC V3.0)
Elexon updated existing BSC documents in April 2020 to reflect the proposed changes that will be required as part of the Switching Programme SCR. These changes were made against the baseline documents at the time and can be found for interim review in the attachments below.
Following the designation of P420 and REC v2.0, Elexon will update all documents affected by the Switching Programme SCR to reflect the September 2021 baseline.
The Issue 86 ‘Review of processes potentially impacted by Ofgem’s Faster Switching Programme’ workgroup was setup in October 2019.
This Issue was to understand how Ofgem’s prospective changes may impact the BSC and “quick win” Change Proposals were raised to help ensure Parties were ready for any new obligations prior to Ofgem raising BSC Modifications.
Change Proposals raised from Issue 86
- CP1529: Earlier initiation of Supplier Agreed Meter Readings process – implemented on 5 November 2020
- CP1532: Reduce Half Hourly Change of Supplier timelines to meet the Initial Settlement Run – will be implemented on 24 February 2022
- CP1533: Mandatory Sending of D0052 for DCC serviced SVA NHH Metering Systems – implemented on 25 February 2021
- CP1534: Introduce Change of Supplier (CoS) – No Meter Process – implemented on 25 February 2021