Consultation on Metering Dispensation D/565 for non-compliant Metering Equipment
Elexon Ltd (Elexon) has raised a generic Metering Dispensation (D/565) on behalf of SMS PLC (SMS). If the BSC Panel approves a generic Metering Dispensation, it allows non-compliant Metering Equipment (or Metering Equipment that has not been approved under BSCP601 – a requirement of CoPs 1, 2, 3, 5, 10 and 11) to be installed and registered in any Settlement Metering System, subject to any conditions the BSC Panel agrees.
Status
Outcome
The SVG (273/02) and ISG (271/02 – Ex-Committee)) approved Metering Dispensation D/565 subject to specific conditions and now added to the Statement of Generic Metering Dispensations Guidance Note.
Submissions
The following information was submitted by responders to the consultation and who were happy for their comments to be made public.
Respondee- E.ON
Response – No
Rationale – Having checked the Elexon tables we can see that only a limited number of data collectors are approved to work with this Meter Type. As this meter is no longer current COP compliant there would be little interest in further Data Collectors becoming compliant and therefore having these meters installed “on the wall” currently means there is limited choice (competition) for Suppliers and Customers on who to use to provide Data Collection services. This would only be compounded if the remaining (small number) of meters are installed.
Our position is that we do not believe that the dispensation should be granted (in any form) as there are other meters that could be installed which are COP Compliant. We also believe that sufficient time to use Meter Stocks held was given by the original dispensation.
However, if the dispensation is to be granted then we would like to see the following very clear restrictions of use in place:
- Only installed following agreement with the Supplier (not customer) – This is in line with Supplier Hub principles.
- Limited to NEW stock only (not meters which have been previously installed elsewhere or reconditioned). As only new stock has not had any cost recovery already.
- Limited to SMS only (to enable them to manage financial risk associated with previous acquisition)
- Limited to End of 2024 (with no further extension) – SMS indicate in the derogation request that they expect to use up stocks in this period.
Respondee – Npower Commercial Gas Limited
Response – No
Rationale – Having checked the Elexon tables we can see that only a limited number of (2) data collectors are approved to work with this Meter Type. As this meter is no longer current COP compliant there would be little interest in further Data Collectors becoming compliant and therefore having these meters installed “on the wall” currently means there is limited choice (competition) for Suppliers and Customers on who to use to provide Data Collection services. This would only be compounded if the remaining (small number) of meters are installed.
Our position is that we do not believe that the dispensation should be granted (in any form) as there are other meters that could be installed which are COP Compliant. We also believe that sufficient time to use Meter Stocks held was given by the original dispensation.
However, if the dispensation is to be granted then we would like to see the following very clear restrictions of use in place:
- Only installed following agreement with the Supplier (not customer) – This is in line with Supplier Hub principles.
- Limited to NEW stock only (not meters which have been previously installed elsewhere or reconditioned). As only new stock has not had any cost recovery already.
- Limited to SMS only (to enable them to manage financial risk associated with previous acquisition)
- Limited to End of 2024 (with no further extension) – SMS indicate in the derogation request that they expect to use up stocks in this period.
Respondee – Scottish Power (Dataserve Limited)
Response – Yes
Rationale – We agree to the proposal as we believe that the Meter/Outstation types comply with the latest issues of the relevant CoPs.
Similarly, we would also like to propose a dispensation for Honeywell/Elster A1140 and A1700 meter types registered for Settlement between 31 December 2023 and 30 June 2024. As above we believe that they also comply with the relevant CoPs.
In addition, this dispensation has been requested as we were due to procure the required compliant meter types for CP1527, however, the manufacturer subsequently announced that they were leaving the market. We now have agreements and orders in place to deliver compliant meter types but request the dispensation as we transition to new meter suppliers.
Original consultation
Who will this impact?
SMS has inherited approximately 100 CEWE Prometer R/W Meter types through its purchase of SSE Large Power metering in 2021.
SMS would like to install the CEWE Prometer R/W Meter types for Settlement purposes, for a period of 12 months, after an existing generic Metering Dispensation (D/535) expires on 30 December 2023.
SMS contacted the manufacturer, Secure Meters, who advised SMS that it is not planning to submit the CEWE Prometer R/W Meter types for Compliance Testing under BSCP601, against the new Issues of the CoPs 1, 2, 3, 5 or 10, or CoP11 Issue 1, due to the CEWE Prometer 100 being the replacement for the CEWE Prometer R&W.
It would cost SMS in excess of £90,000 to replace the CEWE Prometer R/W Meter types with the current CEWE Prometer 100.
What is proposed?
SMS believes the CEWE Prometer R/W Meter types are technically capable of complying with the new Issues of Code of Practice 1, 2, 3, 5 and 10 and can also be used as Half Hourly Integral Outstation Meters under CoP11 Issue 1 for Asset Metering Types 1, 2, 3 or 4.
Background to this Metering Dispensation
On 30 June 2022, Elexon implemented CP1527 ‘Increase the minimum data storage capacity for Settlement Outstations and mandate specific selectable integration periods for Metering Codes of Practice’. CP1527 made the following changes to, and created new Issues of, these CoPs:
- Increase the minimum data storage capacity for Settlement Outstations to 90 days per Outstation channel, at 30 minutes integration periods, for CoPs 1, 2, 3, 5 and 10.
- Mandate specific, selectable, integration periods for CoPs 3, 5, and 10 (i.e. 30, 20, 15, 10 and 5 minutes) and add a test for this requirement (and for CoPs 1 and 2) into BSCP601 ‘Metering Protocol Approval and Compliance Testing
Elexon invited Meter/Outstation manufacturers to submit ‘evidence based’ Compliance Testing applications against the new Issues of these CoPs, for existing approved Meters and Outstations that could comply with the new Issues.
In January 2022, Elexon also raised a generic Metering Dispensation D/535 which the Imbalance Settlement Group (ISG) and Supplier Volume Allocation Group (SVG) approved, to allow stocks of existing approved Meters and Outstations to be installed and registered for Settlement purpose, for a period of 18 months after we implemented CP1527. D535 can no longer be used from 30 December 2023.
On 30 June 2022, we also implemented P375 ‘Settlement of Secondary BM Units using metering behind the site Boundary Point’, which introduced CoP11 (Issue 1) for Asset Metering.
CoP11 allows Half Hourly Integral Outstation Meters, that are approved under BSCP601 against CoPs 1, 2, 3, 5 or 10, to be used under CoP11 as, equivalent, Asset Metering Types 1, 2, 3 or 4. Asset Meter Type 1 is equivalent to a CoP1 Meter, Asset Meter Type 2 is equivalent to a CoP2 Meter, Asset Meter Type 3 is equivalent to a CoP3 Meter and Asset Meter Type 4 is equivalent to a CoP5 or CoP10 Meter.