COVID-19: BSC Performance Assurance Board (PAB) approves further derogations

On 3 April 2020, the BSC Performance Assurance Board (PAB) approved temporary derogations from the BSC rules, in accordance with BSCP537, which allowed Suppliers to submit new estimates for non-domestic properties which better reflect their consumption during this period of lockdown.

The Performance Assurance Board’s decisions

On 30 April the PAB approved further derogations to allow:

• Suppliers to submit new consumption estimates, either at the end of the lockdown period, or at a point where the Supplier recognises that the site has resumed operation. This is so the estimated consumption reflects the actual consumption at the property, as businesses start to become operational again
• Data Collectors a grace period from their obligations to undertake site inspections during a lockdown and for three months following a lockdown. This is so field staff can focus on obtaining meter readings and performing meter fault investigations. 

The PAB also agreed that the BSC Auditor will take a pragmatic approach when assessing compliance with the Long Term Vacant (LTV) process in its assessments for the 2020/2021 audit period, as the ability to keep a property within the process is dependent on site visits. It agreed that a grace period should be applied during a lockdown and for three months following a lockdown.

More details on the agreed derogations can be found in the COVID-19 – Additional Temporary Derogations Recommendations paper, which was presented to the PAB at its 30 April meeting.

Guidance Notes

We have updated the Non Half Hourly (NHH) and Half Hourly (HH) Estimation During COVID-19 Guidance Notes to reflect the further derogations and advice. We have also produced two new Guidance Notes, which set out the position for site inspection visits and the LTV process:

• Updated – Non Half Hourly (NHH) Estimation Guidance During COVID 19 (v3.0)
• Updated – Half Hourly (HH) Estimation Guidance During COVID-19 (v3.0)
• New – Non Half Hourly (NHH) Long Term Vacant (LTV) During COVID-19 (v1.0)
• New – Site Inspection Visits During COVID-19 (v1.0)

The PAB agreed that the approach set out in the Guidance Notes could be used again for future lockdowns periods, if required. These will be confirmed by the PAB and communicated to the industry via the usual methods. However, Elexon will monitor the use of the process and any feedback in case further revisions are necessary.

How will we monitor the derogations?

Elexon and the PAB recognise the potential concerns that Suppliers may make inappropriate use of the new process or not take action to reinstate the estimates when businesses resume trading. Therefore the guidance is clear that Suppliers and Data Collectors need to keep auditable records of any use of the COVID-19 estimation derogations.

Elexon and the PAB may request these records at any time for monitoring purposes and the records may be the subject of an audit by Elexon or the BSC Auditor.

We have also put in place central monitoring, which will look at the prevalence of new estimates being submitted. This will help to identify issues or misapplication of the approach. We will share this information regularly with the PAB including on an ex-committee basis, if we identify any urgent issues.

Details of the monitoring being put in place are available in the April 2020 Public Risk Report.