PAB sub-group on CVA risk highlighted as part of Issue 103
The Performance Assurance Board (PAB) has established a Central Volume Allocation (CVA) Risk sub group in response to BSC Issue 103 that has been raised in response to a number of serious errors within the CVA market. The sub group is currently expected to be a temporary group that focuses on this specific subject area.
Concerns raised within Issue 103
The high level scope of Issue 103: Meter Registrants and Settlement Risk – A New Way and the Performance Assurance Board CVA Risk sub-group can be compared as follows:
- Existing controls to detect and mitigate Settlement errors
- Is the calculation methodology for LLFs fit for purpose in light of increased embedded generation etc.
- Who has operational influence and responsibility of works on Metering Systems at GSP sites
- Who is best placed to ensure overall Metering System accuracy
- Is the current allocation of responsibilities for Metering are relevant and fit for purpose
- Are the current contractual obligations clear, aligned, and transparent?
- Regarding consumption monitoring, including embedded CVA sites and SVA portfolios, who is/are best placed to monitor and manage their impact on GSP volumes?
- SVAA Tolerance Checks – Are there other monitoring and diagnostic tools which can complement or enhance?
- Should load flow models be used to identify locational changes? How can the models across GSP Groups identify DSCP issues?
- Which controls are checked through the work of the BSC Auditor and Technical Assurance Agent
- Are the roles and responsibilities are sufficiently clear for an auditor to be able to properly define and allocate non-compliance?
Issue 103 with Change process
The Proposer believes that there would be value in reviewing existing controls for Settlement error prevention. It is critical to the Proposer that we address these problems prior to the Settlement timetable being shortened by Market-wide Half Hourly Settlement (MHHS) as the opportunities to readdress will be reduced thereafter.
Questions for the sub-group
The focus of the CVA Risk sub group will be on process changes, communication between market participants and any other solutions which could be implemented without the need for a BSC Change.
- The calculation of the ADR – is this still valid with new influences such as embedded generation? – are there other monitoring and diagnostic tools which can complement or enhance?
- Aggregation rules –validation of data before and after change(s)
- Transmission Losses – Are there other monitoring and diagnostic tools which can complement or enhance?
- Meter Alarm Flags – Are the alarm flags actioned by registrants? Are there any business intelligence opportunities?
- Estimation of CVA data – Are the estimation rules appropriate? Is estimation to zero a suitable option? Are registrants approving estimates?
- Issue Log/Known Error – Investigation approach, information sharing approach?
- BSC Service Desk and Operational Support BSC Service Desk and Operational Support Managers – are these the best routes for parties to flag potential inconsistencies or would other routes be needed to quickly resolve potential inconsistencies e.g. regular lessons learnt forums?
- Communication between CVA stakeholders