List of BSC Issues

At the May 2023 Performance Assurance Board (PAB) meeting, Elexon presented the findings report for an Assurance Information Request (AIR) on SVA Risk 005 (Fault Resolution). The PAB responded with questions around some of these findings, specifically around: The reporting of alarm flags through Hand Held Reads (HHR); Differing approaches to dealing with several types of alarm flags and which alarm flags the Half-Hourly Data Collectors (HHDCs) choose to report on; and General concerns around HHDC non-compliance with the BSC.

Elexon reviewed the findings report for an Assurance Information Request on SVA Risk 005. The Performance Assurance Board (PAB) responded with questions around HHDC obligations and general concerns around HHDC non-compliance. Elexon further reviewed party responses and concluded that three of the five concluded findings were compliant with the BSCP502 but are not adequate for purpose and required an additional review. 

Elexon considers that leaving this issue unresolved could lead to impacts on Settlement, this could lead to a further occurrence of this issue happening and a high materiality impact if left unresolved.

The Supplier Meter Registration Agent (SMRA) is a vital service under the Market Wide Half Hourly Settlement (MHHS) Target Operation Model (TOM) and the need to process messages and issue notifications within defined timescales is integral to enable downstream activities to take effect.

Service Level Agreements (SLAs) for SMRAs arrangements were added to the BSC as part of version 3.0 of the Retail Energy Code implementation, having originally been a part of the Master Registration Agreement. These SLAs are self-policed with the SMRAs distributing Service Credits to participants if not met and are not part of the BSC Performance Assurance Framework.

Whilst the concept of SLAs is still required, the current mechanism set out in Annex K-1 and
BSCP501 is no longer appropriate due to the implementation of the MHHS Target Operating
Model (TOM), with faster response times required. The MHHSP TOM does not address the concept of SLAs in relation to liquidated damages, therefore, BSCCo has raised Issue 111 to consider the best future approach.

The method of Energy Contract Volume Notification (ECVN) submission has remained the same since New Electricity Trading Arrangements (NETA) go-live in March 2001 with Section P of the BSC allowing for 20 minutes from submission to acknowledgement (after which an ECVAA System Failure is declared). The current practice of notification can put Trading Parties and their counterparties at financial risk, particularly when notifying close to the Submission Deadline. This is because the rejection feedback can be close to or after the Submission Deadline leaving insufficient time to make a correction.

The current solution is underpinned by ageing technology from submission, authentication, acknowledgment and reporting. Elexon operates to a 15 minutes service level rather than the 20 minutes ECVAA System Failure point for acknowledgement, this service level has been met in eight of the past 12 months. Customer feedback has indicated a preference for a reduced service level that is relevant to trading in real time and therefore requiring immediate acknowledgement of their trades. This may increase competition by increasing liquidity in trades closer to the Submission Deadline.

Many domestic customers are installing solar photovoltaics (PV) in their homes, allowing them to both consume the energy generated and export excess energy to the grid. However, the current Boundary Point Settlement metering system measures electricity Import and Export on an instantaneous basis. This means that even if a household generates and consumes equal amounts of energy over a period, they can still incur charges due to momentary imbalances between generation and consumption. As a result, customers may face higher bills and complexities in energy management. The current system also poses challenges in accurately reflecting the true energy surplus or deficit over a given settlement period.

The contract between Elexon and the Energy Networks Association (ENA) to pass the operational costs for the Radio Teleswitch Service (RTS) through the BSC as ‘BSC Costs’ is due to expire on 31 March 2024. The BSC pass-through operational costs are currently circa £5 million and there are circa 1 million RTS devices (Radio Teleswitches and Radio Telemeters) in use.

This Issue sought to review BSC Section N to identify which areas and associated processes are currently pain points experienced by the Industry. It aimed to identify solutions to address these to improve efficiency and the user experience for these processes.

The Credit Committee has requested that Elexon review the Credit Cover arrangements with industry experts through an Issue Group. This is in response to key concerns about credit being sufficient to protect the market from Supplier Failure while also not being an onerous burden on market participants. 

Issue 105 was raised to explore the consequential impacts of the P448 Alternative Modification and make a recommendation as to whether further industry change is required.

The contract between Elexon and the Energy Networks Association (ENA) to pass the operational costs for the Radio Teleswitch Service (RTS) through the BSC as ‘BSC Costs’ is due to expire on 31 March 2023. The BSC pass-through operational costs are expected to rise from c.£1.5m to c.£5m. Therefore, Elexon wishes to re-establish industry support for passing RTS costs through the BSC from April 2023 onwards, and confirm how the costs should be apportioned (for example Suppliers/Generators). It’s worth mentioning that since the BSC acts as a pass-through intermediary, Elexon has no control over the RTS cost, which is set through an ENA/BBC contract.

The Proposer believes that there would be value in reviewing existing controls for Settlement error prevention. It is critical to the Proposer that we address these problems prior to the Settlement timetable being shortened by Market-wide Half Hourly Settlement (MHHS) as the opportunities to readdress will be reduced thereafter.

A stakeholder survey conducted by Elexon identified a number of key issues/possible areas for improvement in the BSC Change process. The Issue Group  reviewed the BSC Change process to identify possible ways in which these key issues could be addressed or the BSC Change Process could be improved.

CP1584 ‘Allow non-BSC Parties to raise Change Proposals, add a CP withdrawal process and remove BCA/PACA concept’ was raised by Elexon on 1 August 2023 as a result of Issue 102.

Issue 101 intends to define the requirements and principles for the on-going Data Integration Platform (DIP) arrangements that can be included in a subsequent BSC Modification, including the ongoing governance, funding and operation of the DIP.

National Grid Electricity System Operator’s Distributed ReStart project seeks to enable distribution-connected Plant to participate in an updated version of Electricity System Restoration (currently defined as Black Start in the BSC). 

Issue 99 will review the use of the D0215 ‘Provision of Site Technical Details’ and its associated processes, to identify the areas of improvement.

Strict compliance with the market manipulation rules following Ofgem’s ‘Open letter on
dynamic parameters and other information submitted by generators in the Balancing
Mechanism’ may lead to a less economic/efficient outcome than what some generating
plant was doing prior Ofgem’s open letter being published. There is a concern around the
distinction between technical and economic dispatch of parameters.

Due to a global shortage of materials and the on-going impacts of COVID-19 on global supply chains, there is a shortage of semi-conductors among other crucial components, which impacts the ability of Meter manufacturers to produce Meters. This shortage of Settlement Meters could impact on a number of BSC processes.

 This Issue seeks to explore enduring solutions which allow correct reporting to EMRS of chargeable volumes for Supplier Volume Allocation (SVA) Metering Systems that record both exempt supply and licensed supply. 

This Issue seeks to establish the future of the TIBCO messaging service with the migration of BMRS as part of Elexon’s transformation programme.

Issue 93 will review the BSC metering Codes of Practice (CoPs), which have not been reviewed in totality before.

Reserve Scarcity Pricing Review

Issue 86 will review several processes relating to switching, Change of Supplier and Change of Agent. It will be of interest to Data Aggregators (DAs), Data Collectors (DCs), Meter Operator Agents (MOAs) and Suppliers.

The Review of fault management and resolution timescales was introduced when a report from (TAPAP) found that the timescales for fixing faults were unclear; and insufficient guidance was provided on which party involved in the faults process was responsible for each step.

After 10 years of live operations and some significant industry changes such as smart metering and innovative business models, at its meeting on March 2017 the BSC Panel (264/07) approved the Performance Assurance Framework (PAF) review which Elexon is currently undertaking. The BSC Panel also approved Issue 69 to be formed to support the PAF review.