This page provides full details of the proposed change, relevant dates and decisions.

What is the issue?

Below is a summary of the issues that the Change Proposal seeks to address:

 

  • Significant variance in the nature of ITE providers – CMAG Members have highlighted that
    the expertise, quality standards and experience of ITE organisations/individuals varies
    enormously.
  •  Significant variance in the nature of ITE reports submitted to EMR DB – CMAG Members
    have highlighted that the content of ITE reports that are submitted to EMR DB varies enormously.
  • EMR DB has limited powers to reject poor quality ITE reports – EMR DB have highlighted
    that they only have powers to assess ITE reports against the requirements set out in the CM Rules.
    As a result, the ITE report rejections reasons are primarily limited to whether relevant ITE
    declarations have been made and whether an ITE that has prepared a given report meets the
    requirements to be an ITE. Importantly, EMR DB have stated their powers to reject on the basis of
    the evidence and content of a submitted report is limited.
  • Suitability of ITE reporting requirements – Questions have been raised as to whether the
    current provisions suitably distinguish between relevant CMU types and Generating Unit
    attributes
  • Level of Assurance – Concerns have been raised as to whether the current CM Rules ITE
    Reporting requirements deliver the appropriate level of assurance intended by policy. Members
    have raised specific concerns in relation to:

    • A lack of consequence for providing poor quality ITE reports;
    • Whether, in some cases, ITE reports may be required when they are not adding any value,
      or not required when they could add a level of assurance; and
    • It is not clear what assurance value some requirements of ITEs or ITE reports add.

What is the proposed solution?

CP382 seeks to:

  • Update the ITE definition to remove the requirement for international experience;
  • Move to a report template based approach. The proposer contends that this is easier for both the ITE to complete and for the
    Delivery Body to assess whilst still confirming a similar level of checks from one ITE to another

Status

Diagram of CMAG Rule Change Proposal stages: Submission, Scheduled, CMAG development, Consultation, With Ofgem, Implemented.

Proposer: EMR DB Type of change: Amendment Date Raised: 09 September 2024 Category: Assurance

Next Steps

Milestone Date
Proposal Form Submission 9 September 2024
CMAG Initial Consideration Meeting 24 (17 September 2024)
CMAG Development TBC
CMAG Recommendation to Ofgem TBC
Ofgem Statutory Consultation TBC
Implementation TBC

Impacts and Related Changes

Impacts

ITEs and Capacity Providers that are required/wish to use CM Rules provisions which require ITEs