Ending COVID-19 derogations: three month notice period from 1 July

The three-month notice period required to end the COVID-19 Supplier derogations begins on 1 July. The Performance Assurance Board (PAB) made this decision at its meeting on 24 June 2021, taking into account feedback from industry and the loosening of COVID-19 restrictions.

The PAB believe that there is now a reasonable level of confidence that Government restrictions which significantly impact Settlement operations have concluded. In particular, whilst some restrictions do remain in place, very few business premises are now required to remain closed.

What are BSC Parties required to do during the notice period?

During the three-month notice period beginning 1 July 2021:

• No new adjustments are to be made under the derogations to Half-Hourly (HH) or Non Half-Hourly (NHH) Estimated Annual Consumption (EACs).
• Suppliers should review all HH EACs to ensure that they are reflective of the current level of operations at the site. In the absence of any actual data or register reads Data Collectors (DCs) should continue to use the COVID-19 EAC and follow the derogated estimation process through to the end of September 2021 unless instructed otherwise by the Supplier. Supplier Agents will be encouraged to provide any site level information to the Supplier that would help them update the EAC,for example where access to a site is refused but the site itself is open.
• Suppliers should put in place NHH EACs that replace the adjusted derogation EACs. The default expectation would be that EACs return to those used prior to the lockdown. However, an EAC value between the lockdown EAC and the pre-lockdown EAC can be applied where evidence is obtained by the Supplier that activity has now started at the site but at significantly reduced levels.
• A NHH EAC used for the derogated period can remain in place if the Supplier has evidence that this is the most appropriate EAC at the time the derogation ends and in these circumstances there is no need to deem a read again. However, Suppliers should undertake every effort to obtain reads rather than leave these EACs in place. It is expected that this should only be required for a minimal number of sites.

Process at the end of the notice period

By the end of the derogated period in September 2021, Suppliers should submit to Elexon a list of all Metering System Identifiers (MSIDs) that have not returned to their pre-lockdown EAC. This should include the MSID number, initial and current EACs and their rationale for either continuing the derogated EAC or calculating a new EAC. Suppliers will be required to provide evidence for their decisions where Elexon determine that this is necessary for the purposes of Performance Assurance. Examples of acceptable evidence will be given in revisions to the relevant guidance notes.

Elexon will continue to monitor the status of supplies that have been entered into the process through the existing system of data submissions from DCs. Where necessary, Suppliers will be contacted through their Operational Support Manager (OSM) to ensure that plans are in place to remove supplies from the derogation process in line with the provisions of the guidance notes.

Site Inspection Visits

From 1 October 2021 Site Inspection Visits that are due are expected to resume and non-compliances will be raised against Parties that do not complete these going forwards.

Long Term Vacant (LTV) sites

Days after 1 October 2021 will count towards the 215 days for checking whether a site should remain in Long Term Vacant (LTV) process again. These sites should therefore be targeted for site visits to avoid them dropping out of the process.

Additional information

The above changes have been reflected in updates to the relevant guidance notes:

• HH Estimation During COVID-19
• NHH Estimation During COVID-19
• HH and NHH Site Inspections During COVID-19 
• LTV Process During COVID-19

Elexon and the PAB acknowledge that some commercial properties may, despite the legal restrictions being lifted, be difficult to access or DCs may be refused entry. However, we also note that this has at varying scales always been a hurdle for the industry to overcome and would expect Parties to have in place processes and procedures to allow them to maximise the success rate in obtaining actual reads.