This page lists all Change Consultations which are opened when we need to obtain feedback from the industry on potential Modifications, Change Proposals and Issues. The page also includes Change consultations which have ceased to be active as they have reached their closed date.
- Change Proposal Circulars highlight change information and Impact Assessment responses
A number of opportunities to simplify and align the P344 ‘Project TERRE’ and P354 ‘Use of ABSVD for non-BM Balancing Services at the metered (MPAN) level’ legal text have been identified. The process for allocating MSID Pair Delivered Volumes to composite MSIDs will be be updated to account for both Virtual Lead Party and NETSO inputs. The P344 and P354 processes surrounding the Supplier Volume Allocation Metering System Balancing Services Register will be aligned and simplified.
This Modification is intended to enable the aggregation of specific Metering Systems’ metered data for network charging purposes, i.e. to support the operation of CUSC Modification Proposals CMP280 and CMP281. This Modification will introduce processes explaining how Suppliers, Half Hourly Data Aggregators (HHDAs) and the Supplier Volume Allocation Agent (SVAA) participate in the aggregation and reporting of storage facilities’ Metering Systems’ metered data and enable the BSC Panel and BSCCo to perform assurance activities in relation to the aggregation of this data.
The Workgroup will review the responses and provide their final views, before submitting the Assessment Report to the Panel on 8 August 2019.
This Modification is concerned with providing clarity in regards to BSC compliance with European Balancing Guideline (EBGL) Article 18 terms and conditions related to balancing, with a specific view of the EBGL Amendment process and Article 62 (Derogations).
The Proposed Modification would make clear that any BSC Modification seeking to amend any BSC provisions that constitute the Article 18 terms and conditions related to balancing, once approved by the Authority (i.e. Ofgem) cannot be progressed as Self-Governance. This is due to the EBGL requirement that any amendment to the Article 18 terms and conditions related to balancing must undergo a separate EBGL Amendment process (detailed in Articles 4, 5, 6 and 10) and be given approval by the Authority.
The Proposed Modification would also specifically preclude any BSC provisions constituting EBGL Article 18 terms and conditions related to balancing from being granted a BSC derogation via the BSC Sandbox process.
The P374 Workgroup agreed to raise an Alternative Modification that is identical to the Proposed, except in that it will not specifically preclude BSC provisions that constitute Article 18 terms and conditions related to balancing from a BSC derogation. Instead the current process would remain, allowing each application to be assessed on a case-by-case basis.
The Proposer contends that there is no reason for a different treatment of Reserve products and Non BM Fast Reserve should have been captured already in the calculation of the Imbalance Price via the BSAD and via the Reserve Scarcity Price (RSP) methodology. This Modification is about Non BM Fast Reserve, however, the implementation of this Modification will remove any potential ambiguity and make it clear to the Electricity System Operator, when developing future Balancing Services and associated systems that all Actions should flow through into the Imbalance Price calculation.
P371 seeks to include the price of Non-Balancing Mechanism (BM) Fast Reserve actions into the calculation of the Imbalance Price. The aim is to correct the calculation of the Imbalance Price; guarantee fair and harmonised treatment of all services which cost should be included; provide greater transparency and, ultimately, ensure National Grid’s compliance with the Balancing Services Adjustment Data Methodology Statement (BSAD).
The P366 Assessment Report was presented to the Panel on 9 May 2019 and the Report Phase consultation, seeking views on the Panel’s initial recommendations to the Authority, was issued on 17 May 2019 to 3 June 2019.
The BSC requires that, in relation to each GSP Group, the percentage of total energy attributable to a Supplier, in respect of Non Half Hourly (NHH) Metering Systems, settled on the basis of Annualised Advances (AA) for each Settlement Day shall be not less than 80% for the Third Reconciliation (R3) Volume Allocation Run (VAR) and 97% for the Final Reconciliation (RF) VAR. Any underperformance against these targets is subject to a Supplier Charge. This is monitored and reported in the Performance Assurance Reporting and Monitoring System (PARMS) using PARMS Serial SP08a.
Due to the nature of the NHH performance requirements, small Suppliers are most susceptible to HTR related SP08a Supplier Charges. The proposer believes they are unfairly disadvantaged and are less able to compete competitively for customers with HTR sites. This is because, in contrast to large Suppliers, the inability for small Suppliers to absorb HTR sites into their Settlement performance means that they must price the SP08a Supplier Charge cost into their Supply contract, which makes their prices less competitive.
The P366 Proposed solution will set the SP08a Supplier Charge for PARMS Serial SP08a for R3 and RF are set to £0.00 for all Suppliers, and does not require the declaration of HTR Metering Systems
The current Balancing and Settlement Code (BSC) Panel Elections process is in need of improvement. In regards to BSC Section H ‘General’ Paragraph 9.2.5, ELEXON is required to issue nomination and voting letters via post or fax which is a very time-consuming process and wastes a large amount of paper. Parties are required to submit nominations and votes via post or fax which is out of date with modern technology.
The proposed solution is to amend BSC Section H ‘General’ Paragraph 9.2.5 to allow BSC Panel Election notices, nomination / voting papers etc. to be sent and received via email by both ELEXON and voting Trading Parties during the BSC Panel Elections period. Other forms of communication may be permissible as determined by the Panel from time to time.
A number of opportunities to add clarity have been identified within the P344 ‘Project TERRE’ legal text, alongside the correction of manifest errors. This Modification will ensure that the legal text accurately reflects the P344 Workgroup’s intended solution, as approved by the BSC Panel and the Authority and as detailed in the P344 Business Requirements documentation.
The Balancing Mechanism Reporting Service (BMRS) is the primary channel for providing operational data relating to Great Britain’s (GB) Electricity Balancing and Settlement arrangements, as well as REMIT and European Transparency Regulation data.
This Modification proposes to move a selection of Balancing Mechanism Reporting Service (BMRS) reporting items, currently set out in BSC Section V ‘Reporting’, to a new Code Subsidiary Document (CSD). This will remove the need to progress a Modification for future amendments while retaining obligations to provide or report required data remain within the BSC.
BMRS changes, which meet newly established criteria designed to speed up the progression of ‘De-Minimis BMRS Changes’ will not be subject to the normal Change Proposal (CP) consultation and will instead be progressed straight for decision. A 15 Working Day objection window will allow market participants to challenge the application of the criteria.
P384 will ensure balancing information required by the European Electricity Balancing Guideline (EB GL) and the European Transparency Regulation (ETR) is available to Market Participants. It will also ensure the Balancing and Settlement Code Company (BSCCo) and National Electricity Transmission System Operator (NETSO) remains compliant with this European legislation.
P366 will amend how Supplier Charge SP08a is applied to Non Half Hourly non-domestic Meters that are hard-to-read (HTR). It is believed that applying Supplier Charge SP08a to HTR Metering Systems is anti-competitive and limits consumer choice.
The Workgroup will review the responses and provide their final views, before submitting the Assessment Report to the Panel on 9 May 2019
The current definition of Standard BM Unit configurations is too restrictive and not reflective of current market practices. Parties have to follow the non-Standard BM Unit registration process even though their Plant and Apparatus would be considered as standard in all respects other than how the BM Units are registered in CVA. This leads to inefficient and delayed registration activities. ELEXON’s ‘Review of Metering Dispensations and non-standard BMUs’ and changes in market participation over the last 24 months indicate that BSC Section K3.1 is not necessarily reflective of current market practice in terms of how Parties wish to register and configure their BM Units.
Furthermore, the BSC is not clear on what should be done when Plant and Apparatus are reconfigured in such a way that the new configuration is different enough that it does not meet the same criteria under which it was originally registered. Failure to notify these changes undermines the ability to accurately Balance and Settle the GB market.
P364 proposes to:
- Amend BSC Section K so that certain configurations of Plant and Apparatus do not have to apply to the ISG where the Plant and Apparatus is otherwise of a standard configuration;
- Amend the BSC and any associated CSDs to require Parties to consider if their BM Unit configuration has changed. If such changes result in a change of BM Unit configuration then the Party responsible should be required to seek approval based on their new configuration.
- Amend BSC Section K3.1 (Configuration of BM Units) so that it reflects current Industry practice as well as any expected future changes to industry.
The P363+4 combined Assessment Report was presented to the Panel on 14 MArch 2019. the Panel agreed to amalgamate P363 into P364 and allow P364 to move into the Report Phase. Following amalgamation of P363 and P364, only the P364 page will be updated. The P363 page will not be updated.
The European Union Withdrawal Act (2018) will allow the BSC to remain operative immediately following exit day. However, there will be technical inaccuracies, which may lead to confusion for anyone not familiar with the relevant Brexit legislations, and will need updating as soon as possible.
Most EU regulations will be retained in UK law in the event of the UK leaving the EU without a deal – a ‘no-deal Brexit’. However, the UK government has laid Statutory Instruments (SIs) that, when in force, will mean that some parts of EU Regulations will not be retained i.e. some Articles within Regulations will effectively be ‘deleted’ from retained UK law (some of the ‘deleted’ articles are, in some cases, replaced by UK replacement legislation but, not all). This means that the BSC will need to be updated to reflect this. Additionally, references to partially retained EU Regulations will need to be updated.
It should be noted that some revoked EU Legislation may not lead to the BSC being amended as it is more efficient for these parts of the BSC to remain ‘dormant’ until further details emerge of the UK’s future relationship with the EU post-Brexit. An example would be parts of the Code dealing with P344 ‘Project TERRE’ which won’t become ‘active’ until December 2019.
The requirement to raise a Modification to make additions or changes to the data reported via the Balancing Mechanism Reporting Service (BMRS), is contributing to extended timescales for implementing these updates.
P372 aims to simplify the governance arrangements and reduce the timescales for the publication of data on the Balancing Mechanism Reporting Service (BMRS).
The BSC is constructed in a way that means the burden of governance can be reduced while maintaining appropriate oversight, by taking BMRS changes out of the Modification process and putting them under formal control of the Change Proposal (CP) process.
P381 proposes to remove Section C3.9.1 of the BSC in respect of ‘quarterly reports’. Currently, the quarterly reports are not viewed by market participants, as the information is made readily available in a more timely and accessible manner elsewhere on the BSC Website. Therefore, the current quarterly reports process utilises ELEXON resource that could be better used adding greater value for our customers.
Recent changes to the Replacement Reserve Implementation Framework (RRIF), specifically the Transmission System Operator (TSO) energy bid submission gate closure time for Replacement Reserves (RR), mean that National Grid as the GB Electricity System Operator (ESO) will not be able to be compliant with the Balancing and Settlement Code (BSC) obligations introduced under Modification P344 ‘Project TERRE implementation into GB market arrangements’.
This Modification proposes to modify the BSC Section Q ‘Balancing Mechanism Activities’ wording introduced by P344 to ensure National Grid ESO’s continued compliance with the BSC and the RRIF.
Following ELEXON’s review of Metering Dispensation the decision was made to raise two separate Modifications, P363 ‘Simplifying the registration of new configurations of BM Units’ and P364 ‘Clarifying requirements for registering and maintaining BM Units’, to address the issues that were found. Separate Modifications were proposed to address the two different defects at hand. It was thought that by keeping the Modifications separate we avoid the possibility of them being dependent on each other when it comes to approval and/or rejection.
The combined P363/4 Workgroup identified a single solution that will remedy both the P363 and P364 defects. The proposed solution for P363/4 has four elements:
- Expand BSC Section K ‘Classification and registration of Metering Systems and BM units’ Section 3 criteria for those BM Unit configurations that are deemed to meet the conditions to be registered as a Standard BM Unit;
- Lay down new criteria for what is considered to be a Standard BM Unit;
- Change the BSC so that an application to register BM Units must either meet the configuration criteria (bullet one above) or align with the new list of registration criteria (bullet two above) to be considered as a Standard BM Unit; and
- Removing the need to apply for a Non-Standard BM Unit where the configuration is Standard but there is more than one Party involved.
We have issued Urgent Modification Proposal P378 ‘ Introduction of a CM Supplier Interim Charge’ for industry consultation, with responses invited by 5pm on Tuersday 29 January 2019.
P378 seeks to use the BSC to introduce a CM Supplier Interim Charge for Suppliers. This will act as a contingency fund to protect the industry, and customers, from a price shock in the event that the CM standstill is lifted and back payments are required to be made. The Modification solution is based on the recommendations of Issue 76.
We have issued P370 ‘Allow the Panel to designate non-BSC Parties to raise Modifications’ for Report Phase Consultation, interested parties were invited to respond by Friday 25 January 2019. P370 seeks to allow the BSC Panel, instead of Ofgem, to designate interested third parties to raise Modification Proposals and for Ofgem to become the appeals body. P370 also opens up the Issues process to non-BSC Parties.
BSC Section T 1.5.3(b)(iii) defines ‘short term’ in relation to Market Index Data as a time period in reference to Gate Closure. Following BSC Modification P342 implemented in November 2017, the deadline for contracts for delivery in a Settlement Period has moved from Gate Closure to the Submission Deadline. P342 did not change the Market Index Definition Statement (MIDS) to reflect this. The 2018 MIDS Review is proposing to amend references of Gate Closure to the Submission Deadline to include trades taken in the hour prior to a Settlement Period in Market Index Data which will impact Market Index Data Providers. This change to the MIDS will need BSC Panel approval in November and approval from the Authority.
We have issued P370 ‘Allow the Panel to designate non-BSC Parties to raise Modifications’ for Assessment Procedure Consultation, which you are invited to respond to by Monday, 12 November 2018. P370 seeks to allow the BSC Panel, instead of Ofgem, to designate interested third parties to raise Modification Proposals and for Ofgem to become the appeals body. P370 also opens up the Issues process to non-BSC Parties.