Watch webinar about Modification P395: Aligning BSC Reporting with EMR Regulations

Elexon will implement Balancing and Settlement Code (BSC) Modification P395 ‘Aligning BSC Reporting with EMR Regulations – an enduring solution’ on 2 November as part of the November 2023 BSC Release.

We hosted a webinar on 21 September 2023 to explain the changes.

Watch the video for this webinar

Slides from the webinar

BSC Change details

• P395: Aligning BSC Reporting with EMR Regulations – an enduring solution

FAQs about P395

Q. For the migration of simple Supplier Volume Allocation (SVA) sites that are currently covered under the temporary fix solution (Non-Final Demand SVA sites) is it correct that no action will be required by Suppliers because Elexon will migrate these via the P395 process automatically?

A. That is correct.

Q. Changes are being made to amend processes so that the Balancing Mechanism (BM) Unit Demand volumes provided by BSC systems to EMRS in the SAA-I042 ‘BM Unit Gross Demand’ only includes electricity ‘supplied’ to premises by Suppliers, correctly excluding electricity imported by Generators and Storage Facilities operated by a generation licensee. Does this only impact internal BSC systems, or will there be any knock-on impacts expected to Supplier systems, essentially will Suppliers simply need to follow the Kinnect processes?

A. There will be no impact on Supplier systems arising from EMR MSID (Metering System ID¬) Declarations (i.e. the migrated ‘interim solution’).

However, if a Supplier wishes to submit an EMR (Asset Metering System ID) AMSID Declaration in respect of a site where Final Demand is present, they will also need to register their Generation and/or storage plant as assets using the modified P375 solution and this would require changes to Suppliers’ systems and processes.

Please note that participation in the processes introduced for P395 are voluntary and in no way mandatory.

Q. If a company is a Supplier to any of the 3 different categories (Non-Final Demand at an SVA site, Final Demand at an SVA site or Central Volume Allocation site) does the Supplier carry out all the activity in Kinnect or does the Generator also need to submit something?

A. Only the Supplier should carry out the activity in Kinnect

Unlike P419, Generators are not required to do anything for P395 where the Supplier is the submitter of the Declaration (Generators that want to submit a CVA BM Unit Declaration will need to submit the declaration themselves).

Q. Can any of the Kinnect screens that need to be completed by Suppliers be completed other than by a Category A? (For example, for P419 admin level staff can complete a lot of what is required, and the Category A just has to authorise it).

A. Yes

An ‘assistant’ can enter the data which will then require approval from a Cat A Authorised Person.

Q. Regarding the P flows section is it correct that Suppliers will not need to construct these files themselves but will instead access these via Kinnect which effectively ‘constructs and sends the P flows for the Supplier’?

A. The Supplier will be able to register Assets either via manual data entry into the relevant Kinnect forms, or, via upload of a structured P-flow file. The benefit of the latter is that you could register multiple Assets in one P-flow.

Q. Will Suppliers receive an email notification if their Kinnect activity is successful and which email address will this go to?

A. Yes

The message will go to the Cat A Authorised Person that either submitted the declaration, or approved the submission if it was entered by an Assistant

Q. Is there an example for a site having more than 1 import MSID?

A. It’s possible that a site could have more than 1 import MSID.

For the P395 solution to work, the same Supplier would have to be responsible for all import MSIDs at the site.

The export Suppliers could be different, because its only import Suppliers that gain from the P395 solution.

Q. Which Parties are responsible for sending the D0354 to data aggregators?

A. Elexon’s Data and Calculations Platform, which is part of our Supplier Volume Allocation Agent (SVAA) system, will be creating the D0354 request for Half Hourly metered data going to Half Hourly Data Aggregators.

Q. Why do Electricity Market Reform (EMR) AMSID declarations need to be submitted by Supplier and not by a Virtual Lead Party (VLP)?

A. Virtual Lead Parties (VLPs) and Asset Metering VLPs (AMVLPs) aren’t charged Final Consumption Levies (FCLs).

Only Import Supplier(s) benefit from EMR AMSID declarations. This is why Suppliers are responsible for registering assets in order to raise AMSID pairs for inclusion in EMR AMSID declarations

Q. Will Suppliers be receiving D0357 files from Data Aggregators (Das) for Meter Point Administration Number (MPANs) they have submitted a declaration for?

A. No

Suppliers will not receive D0357 files for Settlement Dates from 2 November 2023 onwards, as HHDAs will send D0385 files to the SVAA, instead of sending D0357s to EMRS and Suppliers. HHDAs will continue to send D0357s for all Settlement Runs for Settlement Dates up to and including 1 November 2023.

Q. In the webinar it was mentioned that there were “Certain circumstances where the same AMSID pair can be used for both purposes” – what are those circumstances?

A. Yes

There is scope for overlap. For P395 purposes you only need to register assets if you have a generation licence.

A battery storage facility could be used to provide asset metering services under P375 and it would also be eligible for submission under P395. The P375 solution impacts Settlement and P395 does not.

So there isn’t a conflict between registering assets for both purposes and submitting declarations for the same asset.

Q. If we currently flow D0354 files and send the response file D0355 along with directors’ certificates to the EMR helpdesk to show that a battery asset with non-final demand is exempt from FCLs. Will this remove the need for that current process?

A. Yes.

From 2 November 2023, Suppliers should register any new non-Final Demand MPANs using the new EMR MSID Declaration process, instead of sending it to the EMR helpdesk

Q. If there are already exemptions in place for assets, does that mean that companies don’t need to resubmit when this comes into place, or will the exemptions will continue as is?

A. Yes

Any MSIDs covered by the EMR Settlement (EMRS) interim solution will be migrated to our BSC systems as part of the P395 deployment so there’s no need to submit any declaration after 2 November 2023, as from then they should be submitted through the P395 declarations process.

You also do not need to re-submit any declarations.

Q. Is it possible that the potential registration clash between Supplier (P395) and VLP (P375) could result in a site requiring doubling-up of the physical meters?

A. In circumstances where the same site would be suitable for use in P375 and P395 solutions all efforts should be made to not register the same site twice.

If you did put a second meter on the site, it would become clear that it had used for both purposes (and the latter registration should be withdrawn and the related AMSID Pair should not be used).

If the site had already been registered for P375 proposes and an AMISD pair already existed, then that AMSID pair should be used in the EMR AMSID declaration. This would be in place of raising a new AMSID pair for the same asset, which would require separate metering.

Q. Can a VLP register AMSIDs for P395 purposes?

A. No.

Only suppliers can register AMSIDs for P395 purposes (AMVLPs – but not VLPs – can register AMSIDs for P375 purposes).