Data Release Consultation: Data Relating to Default Funding Share (DR343096)

Seeking views from industry on data requests received, prior to the Balancing Mechanism Reporting Service Change Board (BCB) making a determination on whether to release requested data.

Summary

Elexon have assessed seven data items which aim to provide better visibility of the financial impact of the Default Funding Share. When a Party defaults, Elexon consider that share of the BSC Costs as a ‘bad debt’. For every month within a BSC year all identified ‘bad debt’ from within that BSC year (including the invoice month) is aggregated to give a running total of the ‘Annual Default Costs’. These costs are mutualised among non-Defaulting BSC Parties.

From 1 April 2021 to 31 March 2022, £70m of DFS Cost entered Settlement and was mutualised among BSC Parties as DFS payments. It is highly important Elexon provide as much information on the costs affecting industry. The clear publication of these data items at Party level with clear dates will enable efficient risk management and forward financial planning surrounding Supplier failures.

Due to conflict with the Commercial triaging category, Elexon recommend openly publishing these data items only on BSC Parties that have ceased trading under the BSC. Providing this information on Parties that are still trading could negatively impact their ability to trade.

As a result Elexon is seeking responses from industry where they disagree with the recommendations to publish the seven data items detailed in the Reference Table below under the BSC Open Data LIcence on BSC Parties that have ceased trading under the BSC and have outstanding DFS amounts.

Reference Table

Data Item

Description

Elexon Recommendation

Rationale

Defaulter

Company Name

Open

Company names of failed Suppliers are made publicly available by Ofgem when a Supplier fails (see link below table). Elexon see no sensitivity related to this item and a benefit to industry to publish.

BSC Party ID

Unique character string for identifying BSC Parties

Open

BSC Party ID in relation to a Company Name is published by Elexon in various areas. The most complete and public area being the BSC Signatories list. Elexon see no sensitivity related to this item and a benefit to industry to publish.

BSC Default Effective From Date

Date the Supplier is considered a ‘Defaulting Party’

Open

Date of failed Suppliers are made publicly available by Ofgem when a Supplier fails (see link below table) Elexon see no sensitivity related to this item and a benefit to industry to publish to support accuracy in financial planning and visibility of market events.

SoLR Appointed Date

If applicable, the date a replacement Supplier was assigned through the Supplier of Last Resort (SoLR) process

Open

Dates of SoLR appointments are made publicly available by Ofgem when a Supplier fails (see link below table). Elexon see no sensitivity related to this item and a benefit to industry to publish to publish for visibility of market events.

Current DFS (£)

Monetary total of Monthly and Annual Default Costs

Open

Elexon publishes monthly totals of DFS Costs and the number of Failed Suppliers at a System level in the Cash Flows section of the Trading Operations Report. The data shows a monthly breakdown of DFS amounts. Elexon through this Open Data Request is seeking to provide the DFS Cost attributable to each Defaulting BSC Party who has ceased trading under the BSC. This does clash with the ‘Commercial’ triaging category, however, as these Parties have ceased trading under the BSC, Elexon see no reason for not publishing this information under an Open Data Licence. Open publication will support financial planning in the industry and provide transparency of market impacts to industry helping manage risk.

Customer Numbers

Customer numbers represented by the total half hourly and non-half hourly meter counts

Open

Customer numbers are made publicly available by Ofgem when a Supplier fails (see link below table). These are split by ‘Domestic’ and ‘Non-Domestic’ meters. Elexon see no sensitivity related to this item using half hourly and non-half hourly splits, and, a benefit to industry to publish as an indication of the impact of the Supplier failure. Elexon do not see sensitivity associated with this data if the Supplier has ceased trading under the BSC.

Company names of failed Suppliers are made publicly available on the Ofgem web page ‘Check who’s taken over your energy supply’.

There was a data item regarding the ‘Status’ of DFS payments in the original request. This relates to whether the payment is:

  • Outstanding: The DFS Cost is yet to be paid
  • Cleared: The DFS Cost has already been cleared through the repayment process.

As the Cleared payments do not contribute to the DFS Costs that are to be mutualised and paid off by the remaining Trading Parties, these payments will not be included in the data to be published. As all the data items will have the same status (Outstanding), this data item was removed from the request.

Outlook for publication of DFS data

Subject to approval by the BCB, Elexon will publish a historic view of DFS Costs looking at the past 14 months of debt within the Cash Flows section of the Trading Operations Report.

All the requested data items are available through existing data delivery channels. All data items would be displayed in the Cash Flows section of the Trading Operations Report through visualisations and csv download on a monthly basis.

Once these data items are deemed Open, Elexon will also scope publishing these data items on the date of a BSC Party ceasing to trade providing an outlook of DFS Costs to be mutualised by the remaining Trading Parties. This enables organisations to better manage finances in the event of failing Trading Parties.

This is a 15 working-day consultation. Each individual data item has been assessed on the criteria defined within the Process for Requesting BSC Data Code Subsidiary Document.

Initial triage and classification

Elexon’s initial assessment of the requested data set

Elexon have assessed each data item on the four triage categories:

  • Consumer Privacy – A person who can be identified from the information requested – either directly or indirectly in combination with other information
  • Negative Consumer Impact – Likely to drive actions that will negatively impact consumers
  • Security – Creates incremental, or exacerbates existing, security issues which cannot be mitigated via sensible security protocols such as physical site security, robust cyber security or buffer databases
  • Commercial – Relates to the private administration of a business or, data not collected as part of an obligation by a regulated monopoly and would not have been originated or captured without the activity of the organisation

Elexon have identified no areas of concern within the Consumer Privacy, Negative Consumer Impact and Security categories.

Attributing data items to an individual ‘Company Name’ and ‘BSC Party ID’ can be considered to clash with the Commercial category. Elexon see an issue with commercial sensitivity if the BSC Party is still trading. As the publishing of financial difficulties for a Trading Party will have a negative impact on the organisation’s ability to trade, Elexon plans to mitigate any commercial sensitivities by only publishing DFS data on BSC Parties that have ceased trading under the BSC. Total DFS amounts will still be published containing entire DFS Costs containing BSC Parties still trading as the BSC Party ID, Default Date and Company Name will be anonymous at this level of aggregation.

Elexon also accounted for the publishing of these data by Ofgem, the Market Authority. The Market Authority does not publish DFS Costs imposed on the Market by an identifiable Party’s ‘Bad Debt’, or, the number of customers split by half-hourly and non-half hourly meter counts.

DFS Costs by Party are not seen as a concern as these costs are paid by all BSC Trading Parties. All stakeholders should be able to identify financial costs affecting their business and/or the industry for accurate financial planning, risk management and to inform improvements that can be made to the operation of the GB Electricity System. It is important this information is easy to obtain, Openly available to use without restriction and published on a monthly basis (the same periodicity as DFS payments are made).

Ofgem publishes customer numbers of Defaulting Parties who have gone through a SoLR process split by ‘Domestic’ and ‘Non-Domestic’ customers. Elexon half-hourly and non-half hourly customer numbers available and does not see an impact with publishing these figures when the Party has ceased trading under the BSC.

The different Classifications that can be applied to a dataset being processed through the Open Data Request service can be found in the Open Data Request are of the Open Data Request webpage. This also contains templates for licences of each classification. Please note, other than the BSC Open Data Licence, the other templates will be modified and be bespoke to the Data Request to which they apply.

Proposed mitigation

How Elexon proposes to mitigate the data to make it more open (if applicable) and what the subsequent triage and classification shall be

Omission and Aggregation

In order to protect the trading abilities of Defaulting Parties who are still trading, Elexon plans to only publish these data items for Parties that have ceased trading under the BSC. Total DFS Costs will contain all Defaulting Party DFS Costs, but aggregating to a system level, these Parties will not be identifiable.

Benefits

What will be the benefits to BSC Parties, wider industry, and/or requester should the requested data be released

Elexon has considered the findings of the Electricity Data Taskforce: A Strategy for a Modern Digitalised Energy System when assessing the benefits of publishing data contained within an Open Data Request. When assessing the data items contained within Request DR343096:

  1. Maximising the value of data
    Supplying these data items via csv under a BSC Open Data Licence with adequate descriptions of the data within the Trading Operations Report, Elexon will ensure the data items are ‘Discoverable, Searchable, Understandable’.
  2. Visibility and transparency of the data
    Although several of the data items are published by Ofgem (please refer to the reference table), they are not published with attributions to DFS. Making this attribution brings new data into the visibility of the industry, which will provide transparency and provide information for stakeholders to accurately plan financials, manage risks and identify areas for improvement in the market.

The provision of this data also increases transparency for Settlement payments, improving the service provided by Elexon

With the outlook to provide enhanced historical reporting as well as an outlook of financial impact from the date where a Party has ceased trading under the BSC with costs entering the DFS, there will be benefit to BSC Parties who are still trading to account for the additional DFS charges impacting them.

Impacts

What will be the impacts to BSC Parties, wider industry, and/or requester should the requested data be released

These data items relate to DFS Costs originating from Defaulting Parties who have ceased trading under the BSC. The stakeholders in these organisations may oppose the financial impacts being openly available. Elexon, considered the views of the failed Suppliers but felt providing clarity on financial impacts to participants to enable the most efficient operation of the Trading Parties to supersede the reasons for not publishing the data items contained within DR343096.

Duplication

Whether Elexon is aware of similar data sets produced by themselves or other organisations

Elexon has assessed the data already available through its own and other industry publications. Elexon are aware of several of the data items being published on Ofgem’s ‘Check who’s taken over your energy supply webpage. Elexon plans to publish these data items with attribution to DFS Costs, which are not currently available.

Coupling

Whether the data set could be coupled with other data sets (published by Elexon or others) for commercial, nefarious or other purposes

Elexon has not identified any datasets with which the data items within DR343096 could be coupled for commercial, nefarious or other purposes.

Risk

What (if any) will be the risk to Settlement, Elexon and Industry members as applicable

Elexon has not identified any risks with the Open publication of data items within DR343096.

Costs

What will be the cost for Elexon in terms of time and money to create the data set. This will include BSC agent costs as well as any ongoing costs if applicable.

Elexon receives the requested data items through existing data pipelines. By using the Trading Operations Report for delivery, Elexon do not foresee any extra or ongoing costs to providing the data items within DR343096.

Periodicity

Whether the data set is proposed to be re-published at given intervals, or as a one-off

Elexon plan to publish a historic view of the data items within DR343096 on a monthly basis in line with the publication of the Trading Operations Report. This aligns with the periodicity of Default payments which occur on a monthly basis.

Elexon will also look to enhance forward-looking reporting from the date of a Default of a Party who has ceased trading under the BSC when these data items are Classified as Open. These reports will be published ad-hoc from these events.

Review period

How often the BCB should review whether the data set remains extant or whether it will be published in perpetuity to be reviewed by exception

The data sets contained within this Open Data Request will be published in perpetuity and Elexon proposes this dataset not be reviewed by the BCB unless requested via an Open Data Request.

Recommendation

Elexon’s initial recommendation to BCB:

  1. all the data items within DR343096 are published under the BSC Open Data Licence; and
  2. the data items be published in the Cash Flows section of the Trading Operations Report on a monthly basis.

How to respond

The consultation runs as a ‘negative response’ consultation; responses should only be received should the responder disagree with Elexon’s recommendations.

Use the online form to respond to this consultation. All responses must be submitted by 17:00 on 28 June 2022 and will be sent to [email protected] on submission.

If you wish to save and return to your response, or share your response with a colleague before submitting then use the save and return button at the bottom of the form. You will then be given a link with your draft response that you can return to or share before submission.

If you would like a follow up from Elexon about your consultation response, please provide your contact details in the form.

Other forms of response, such as free text email, will be accepted and should be sent to [email protected], clearly indicating which data request consultation you are responding to.

The responses to this consultation will be presented to the BMRS Change Board (BCB) who will be responsible for approving the recommendations.

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