Change

CEPA and Elexon have issued a Call for Evidence to gather stakeholder views on the potential benefits, costs and other impacts of implementing P415.

This Modification aims to reduce the requirement from two or more Suppliers, to one or more Suppliers, to be involved in a Shared Supplier Volume Allocation (SVA) Metering Arrangement.

Amending the BM Unit Gross Demand Report to the EMRS to include electricity ‘supplied’ to premises by Suppliers, correctly excluding electricity imported by Generators or Battery Storage facilities operated by a licensee for generation activities, for use in calculating FCL in accordance with BEIS regulations.

Ofgem’s Switching Significant Code Review (SCR) will introduce the new Central Switching Service (CSS) and version 3.0 of the Retail Energy Code (REC 3.0). P436 progresses the consequential BSC changes needed to align with REC 3.0.

This Modification seeks to enable EMRS to undertake the necessary preparatory work for potential future settlement services to LCCC.

This Modification seeks to enable BSC Systems to aggregate the Import data of all non-Final Demand sites for exclusion from Balancing Services and Use of System (BSUoS) charges.

At the Panel meeting on 9 December 2021, Ofgem noted that there was a risk that they will be unable to make a decision on P421 by 3 February 2021, which is required to meet the standard February 2022 Release. Were this to happen, P421 would ‘time-out’ and be closed.

To mitigate this risk the Panel requested a revised Implementation Date for P421 (in accordance with Section F2.11.18).

Under the current approved P376 solution, VLPs with BM Units that have not been registered as a ‘Baselined BM Unit’ would be required to specify the ‘Inactive’ status of a non-baselined BM Unit. It is Elexon’s view that this new requirement was not intended, is expected to increase both system development costs associated with P376 as well as on-going operational costs for VLPs. This current requirement is not necessary, adds no value and does not better facilitate any of the Applicable BSC Objectives. The Proposer of P376 agrees that allowing non-baselined BM Units would cause a problem and suggested disallowing this functionality.

This is the Report Phase Consultation for P429 ‘Switching off Participant-Reported PARMS Serials’.

P429 would permanently cease the operation of, and remove the obligations associated with, participant-reported Performance Assurance Reporting and Monitoring System (PARMS) Serials and associated Supplier Charges.

This is the Assessment Procedure Consultation for P419 ‘Enhanced Reporting of Demand Data to the NETSO to facilitate BSUoS Reform’.

This Modification seeks to expand the systems and processes introduced by P383 ‘Enhanced reporting of demand data to the NETSO to facilitate CUSC Modifications CMP280 and CMP281’ to allow eligible facilities to declare exemption from BSUoS charges and provide NGESO with aggregated Non-Final Demand data.

This Modification aligns the BSC with the provisions introduced into the Grid Code under GC0144 ‘Alignment of Market Suspension Rights to the EU Emergency and Restoration Code Article 35.1(b)’

This is the Assessment Procedure Consultation for P332 ‘Revisions to the Supplier Hub Principle’.

This Modification seeks to address issues associated with customer preferred Supplier Agents. The proposed solution is a side letter between Elexon and Supplier Volume Allocation (SVA) Data Collectors (DCs) which will enable a Supplier who does not have a direct contract with the DC to enforce, as a last resort, the side letter as a proxy contract, to ensure that BSC obligations are met. The proposed solution will now apply to SVA DCs only as SVA Meter Operator governance will move from the BSC to the Retail Energy Code (REC) from 1 September 2021 as part of Retail Code Consolidation (RCC).

This Modification will update the BSC to ensure it accurately reflects the BSC provisions constituting the network code on electricity emergency and restoration (NCER) Rules in the mapping for the European Electricity Balancing Guideline (EBGL) Article 18 Terms and Conditions. Both the EBGL and the NCER were incorporated into UK law by the European Union (Withdrawal) Act 2018 following the UK-EU transition period.

We have issued P416 ‘Introducing a route of appeal for the Annual Budget in line with the proposals for the Retail Energy Code’ for Report Phase Consultation, which you are invited to respond to by 3 June 2021.

P416 seeks to amend the BSC to include an appeals mechanism to Ofgem that could be used to challenge items in the Annual Budget in line with the appeals mechanism detailed in proposals for the Retail Energy Code (REC).

The Proposed Solution contains the following key features:

• Any BSC Party can raise an appeal against an Annual Budget line item within 10 WDs of the BSCCo Board issuing approval of the Annual Budget
• Provisions to allow the Authority to respond to appeals by referring individual items back to the Board for reconsideration, powers to change costings or remove individual items from the Annual Budget, and powers to dismiss appeals that are trivial or vexatious or has no reasonable prospect of success.
• Provisions to stop all of part of spend against appealed Annual Budget line items if specified conditions are met.

We have issued P420 ‘Retail Code Consolidation Significant Code Review’ for Industry  Consultation, which you are invited to respond to by 17 June 2021.

P420 seeks to ensure the BSC aligns with Ofgem’s Retail Code Consolidation Significant Code Review, which consolidates a number of existing codes into the REC. The proposed changes have a direct impact on the BSC in terms of the transfer of the SVA Metering arrangements from the BSC to the REC and cross-code change procedures, as well as consequential changes reflecting the close down of the MRA.

P420 makes the necessary changes to reflect the code governance changes implemented through the Retail Code Consolidation SCR. Specifically, it will:

1. Ensure the BSC reflects the close down of the MRA.
2. Transfer operational procedures relating to Metering Point Lifecycle from the MRA to the BSC.
3. Make the necessary changes to transfer SVA Metering arrangements to the REC, and facilitate a transition period for metering assurance.
4. Insert the required drafting to give effect to the CCSG, which will be established under the REC to better facilitate cross-code change

Utilising a Baselining Methodology to set Physical Notifications for Settlement of Applicable Balancing Services

We have issued P402 ‘Enabling reform of residual network charging as directed by the Targeted Charging Review’ for Report Phase Consultation, which you are invited to respond to by 5pm on Monday 1 March 2021.

The P402 Proposed Solution will introduce new reporting requirements on LDSOs and BSCCo that will ensure the provision of data to enable the NETSO to set TNUoS demand residual tariffs and enable accurate billing of subsequent charges. To ensure that NETSO receives the data it requires, P402 introduces processes that require the provision, consolidation and validation of three types of data to NETSO (Monthly Billing data, Annual Tariff Setting data and Unmetered Supplies (UMS) data), the creation of two new reports to NETSO and an update to the P0210 ‘TNUoS Report’.

Under the Proposed Solution, new requirements will be introduced on Licenced Distribution System Operators (LDSOs) to send reports to Elexon (as the BSCCo) and on BSCCo to aggregate this data and report to National Electricity Transmission System Operator (NETSO). This will impact LDSOs, NETSO and BSC systems and processes.

The P402 Alternative Solution sees LDSOs compiling this data themselves, sending it directly to National Grid and so not to relying on BSCCo or BSC Systems and Agents for these purposes.

The Alternative Solution will introduce new requirements on LDSOs to send reports to NETSO. This will impact LDSOs and NETSO and will not require any changes to BSC Systems – however BSCCo will provide support to Parties as part of Business as Usual.

The BSC Panel initially recommends that the P402 Alternative Modification should be approved and that the P402 Proposed Modification should be rejected

We invite you to respond to this Report Phase Consultation to provide your views on the Panel’s initial recommendations for P402.

Please send your response to [email protected] using the form attached to the consultation by 5pm on Monday 1 March 2021. 

Please note that this is your final opportunity to comment on this Modification.

P376 ‘Utilising a Baselining Methodology to set Physical Notifications’ proposes to allow the Final Physical Notification which feeds into the Settlement of Trading Charges to be created via a Baselining Methodology. The new Physical Notification will be de-coupled from the Physical Notification used by National Electricity Transmission System Operator (NETSO) for dispatch. This change will allow Balancing Service Providers to be fully recompensed for their actual change from normal usage and the impact this change has on the system, thus enabling greater participation.

P418 aims to ensure the Legal Text for approved BSC Modification P383 properly reflects the approved solution, business requirements, and is aligned with the BSC baseline introduced by P344, P354 and P388. In particular, it will clarify that the solution being delivered by P383 is applicable to both Supplier Base Balancing Mechanism (BM) Units and Additional BM Units.

We have issued P413 ‘Enable Elexon to be the Programme Manager for the implementation of Market-wide Half Hourly Settlement’ for Assessment Procedure Consultation, which you are invited to respond to by 15 January 2021 .

P413 will require Elexon to provide Market-wide Half Hourly Settlement (MHHS) Implementation Management services under the BSC, as the BSC Company (BSCCo), where Ofgem determines that Elexon shall provide some or all of these services. These services may include activities and responsibilities relating to MHHS programme management, system integration and programme party co-ordination (or any part of these). Elexon may also appoint a MHHS Implementation Assurance Provider, depending on Ofgem’s preference.

Under the Proposed Modification, Elexon’s costs in providing MHHS Implementation Management services will be recovered from BSC Trading Parties by market share (through the BSC’s existing Main Funding Share mechanism). The Workgroup also seeks views on a potential Alternative Modification that would recover these costs solely from Suppliers by market share (through a new Specified BSC Charge).

P413 will enable Elexon to participate in any competitive tender exercise used to appoint MHHS Implementation Management services. Any Elexon bid costs will be recovered from BSC Trading Parties through the Main Funding Share, but will be subject to a cap.

We are re-issuing P399 for Report Phase Consultation as new material information in relation to the solution was provided in the first Report Phase Consultation. The ESO response identified that the cost for including the ‘tendered status’ filed will now cost an additional £350k-500k. The Workgroup have decided to keep the tendered status in the solution, but in light of this material increase in cost are re-issuing P399 for consultation.

Following the introduction of P392 ‘Amending BSC Change Process for EBGL Article 18’ in June 2020, all BSC Modifications must now consider the impact on the EBGL Article 18 terms and conditions for balancing. This requires that the Workgroup is reconvened, where there have been any representations that may require the Modification Proposal to be amended. The Workgroup must then decide whether to amend, or not, the solution and where it is amended re-consult. 

We have issued P402 ‘Enabling reform of residual network charging as directed by the Targeted Charging Review’ for Assessment Procedure Consultation, which you are invited to respond to by Tuesday 27 October 2020.

The purpose of this second P402 Assessment Procedure Consultation is to invite BSC Parties and other interested parties to provide their views on the merits of the P402 Proposed and Alternative Solutions. In particular, the Workgroup seeks your views on the Alternative Modification Proposal, which was raised by the Workgroup in response to the first Assessment Procedure Consultation. The P402 Workgroup will then discuss the consultation responses, before making a recommendation to the BSC Panel at its meeting on 16 January 2020 on whether or not to approve P402.

P402 will introduce new reporting requirements on LDSOs and BSCCo that will ensure the provision of data to enable the NETSO to set TNUoS demand residual tariffs and enable accurate billing of subsequent charges.

Please send your response to [email protected] using the form attached to the consultation by Tuesday 15 December 2020.

We have issued P379 ‘Multiple Suppliers through Meter Splitting’ for Cost Benefit Analysis Consultation, which you are invited to respond to by Friday 15 January 2021.

P379 will enable consumers to be supplied by multiple Suppliers through Balancing and Settlement Code (BSC) Settlement Meters at the Boundary Point. P379 will allow multiple Suppliers to compete for the supply or export of electricity through a single Meter without needing to establish an agreement between all of the Suppliers involved for every instance.

We invite you to respond to this Assessment Procedure Consultation to provide your views on the expected costs and benefits of P379.

Please send your response to [email protected] using the form attached to the consultation by Friday 22 January 2021.

P414 ‘Allowing a Party to Withdraw from the BSC and transfer outstanding liabilities to another Party’ seeks to improve the BSC exit arrangements. It will allow a BSC Party to withdraw from the Code as soon as practicable after serving a notice of withdrawal provided that all liabilities under the Code are satisfied or transferred to another BSC Party through a transfer of its BSC party ID to that legal entity.

We have issued P402 ‘Enabling reform of residual network charging as directed by the Targeted Charging Review’ for Assessment Procedure Consultation, which you are invited to respond to by Tuesday 27 October 2020.

P402 will introduce new reporting requirements on LDSOs and BSCCo that will ensure the provision of data to enable the NETSO to set TNUoS demand residual tariffs and enable accurate billing of subsequent charges. To ensure that NETSO receives the data it requires, P402 introduces processes that require the provision, consolidation and validation of three types of data to NETSO (Monthly Billing data, Annual Tariff Setting data and Unmetered Supplies (UMS) data), the creation of two new reports to NETSO and an update to the P0210 ‘TNUoS Report’.

We invite you to respond to this Assessment Procedure Consultation to provide your views on the Workgroup’s initial recommendations for P402.

Please send your response to [email protected] using the form attached to the consultation by Tuesday 27 October 2020.

In June 2019 the Energy Data Task Force (EDTF) published its report ‘A Strategy for a Modern Digitalised Energy System’. One of its recommendations was that the energy sector should ‘adopt the principle that Energy System Data should be Presumed Open’. The EDTF report recommends that BEIS and/or Ofgem should use legislative and regulatory powers to achieve this recommendation.

The BSC does not fully adhere to open data principles however, by taking action now, we can remain at the forefront of industry development and will be able to create the precedence for industry to follow/emulate.

P398 proposes amending the BSC so that all data is assumed open unless there is a reason otherwise. The Panel (or delegated Sub-Committee) will determine if there is any reason not to make data available. This will be done based on a transparent process of triage and categorisation. In the longer term, we will look at an IT solution to make accessing BSC data even easier than having to make a formal request for release/publication.

P375 proposes using Metering Equipment ‘behind’ the defined Boundary Point for Balancing Services (‘behind the Meter’), for Settlement purposes rather than the Boundary Point Meter.

This will allow balancing-related services on-site to be separated from imbalance-related activities, more accurately reflecting the balancing-energy volumes provided by the Balancing Service Provider (BSP).

P375 arose from Issue 70 ‘Settlement of Secondary BM Units using metering at the asset’.

P399 seeks to include additional information in the Balancing Services Adjustment Data (BSAD) to identify the assets involved in bilateral trades.

Currently, each Balancing Adjustment Action taken outside the Balancing Mechanism is reported with a unique sequential number. The Proposer contends that this does not identify the counterparty to the bilateral trade and creates an information advantage to those counterparties, reducing transparency in the operation of the system creating a barrier to effective competition.

P397 seeks to introduce a mechanism through which the Balancing and Settlement Code Company (BSCCo) determines whether Licensed Distribution System Operators (LDSOs), the National Electricicty Transmission System Operator (NETSO), certain Party Agents and BSC Agents, and BSCCo should carry out the Settlement Adjustment Processes following a DCE. BSCCo would determine the nature of the DCE and, where necessary, determine and compare the costs and value of the DCE in order to determine whether the value of carrying out the Settlement Adjustment Processes outweigh the costs.

Responses to the P411 Report Phase Consultation are invited by 29 July 2020.

P408 will align with Grid Code Modification GC0130 to publish new and amended Output usable data on BMRS.

The BSC restricts the activities of Elexon and in the absence of a specific Modification any additional activities cannot be pursued by Elexon (even when those activities would be of benefit to BSC Parties, industry generally and/or the consumer). 

In the past specific Modifications have been necessary which have enabled Elexon to provide the Warm Homes Discount Reconciliation service, EMR settlement, and to participate in gas performance assurance framework and REC manager appointment processes.

Such individual Modifications to extend Elexon’s vires are time consuming and can be an unnecessary distraction for industry. They can also result in Elexon being unable to pursue an opportunity within a required timeframe.

P390 seeks to introduce a framework into the BSC that allows the Elexon Board to determine whether Elexon can undertake additional activities provided certain conditions are met and with consent of the Authority

All of the conditions introduced in previous Modifications to Elexon’s vires, P330 ‘Allowing Elexon to tender for the Uniform Network Code Gas Performance Assurance Framework Administrator (PAFA) role’ and P365 ‘Enabling Elexon to tender for the Retail Energy Code (REC)’ are included, plus some additional conditions to safeguard the interests of BSC Parties.

Following closure of the Report Phase Consultation on 29 April, the Draft Modification Report will be presented to the BSC Panel on 14 May 2020.

P405 will allow notices that the BSC currently requires to be sent by post or fax to be sent by email. Due to the COVID-19 pandemic, it is not currently practical to use post or fax. More generally, it is now accepted and more efficient to send notices via email.