P348 – Provision of gross BM Unit data for TNUoS charging

Formal title: Provision of gross BM Unit data for TNUoS charging

Current Status

Initial Written Assessment
Assessment Procedure
Report Phase
With Authority
Awaiting Implementation


CMP264 ‘Embedded Generation Triad Avoidance Standstill’ and CMP265 ‘Gross charging of TNUoS for HH demand where embedded generation is in Capacity Market’ sought to make changes to the calculation of Transmission Network Use of System (TNUoS) Charges in light of concerns over the value of embedded benefits being paid to embedded generators. In particular, the solution approved by the Authority, Workgroup Alternative CUSC Modification (WACM) 4, reduces the level of Transmission Demand Residual payments to the avoided Grid Supply Point costs. P348 and P349 were raised to facilitate the reporting of Metered Data to support the implementation of proposed changes to the CUSC.

The approved CUSC Modifications require that the Transmission Company is sent gross Half Hourly (HH) embedded export and gross HH demand associated to individual Supplier Balancing Mechanism (BM) Units. In accordance with P348 and P349 Proposed Modifications, BSC Option 2, these values will be simply calculated using existing Settlement data and processes, and reported to the Transmission Company using an updated interface.


P348 was raised by EDF Energy on 1 July 2016. The Proposer has requested that this Modification be treated as an Urgent Modification Proposal.

An Urgent meeting of the BSC Panel will be held on 4 July 2016. The Panel will consider the Proposer’s request for Urgency and will agree a recommendation to the Authority on whether or not P348 should be treated as an Urgent Modification Proposal. The Authority then considered the Panel’s recommendation and determined on 11 July that P348 should not be treated as an Urgent Modification Proposal.

The P348 Assessment Procedure Consultation was issued on Monday 8 August 2016, with responses due back by 26 August 2016. The Workgroup considered the responses to the Assessment Consultation and the extension to the related CUSC Modification timetable. The Workgroup agreed that an extension would be required to ensure that P348 can take into account the solution(s) agreed under CMP265. Elexon requested a two month extension to the P348 Assessment Procedure Timetable. The Panel approved this at its meeting on 8 September 2016.

The second Assessment Procedure Consultation was issued on Monday 20 February 2017 with responses due by Monday 13 March 2017.

The Assessment Report was presented to the Panel at its meeting on 13 of April. The Report Phase Consultation was issued on 19 April 2017 with responses due by 8 May 2017. The Draft Modification Report was presented to the Panel at its meetingo n 11 May 2017. The Panel recommended conditional approval of Options 1, 2 and 3 depending on Ofgem’s decision on the CUSC modifications. The Final Modification Report was issued to the Authority on Monday 22 May. The Authority approved Option 2 on 22 June 2017 for implementation on 22 February 2018.

Ofgem has been served with a claim for judicial review concerning its decision to approve WACM4 of CUSC modifications CMP264 and CMP265.   The judicial review has not been raised against BSC Modifications P348 or P349.

The case number is: CO/4397/2017.

National Grid Electricity Transmission plc has been named by the claimants as an interested party to the proceedings.

We have been advised by Ofgem it is still progressing P348 and P349 as per the Ofgem agreed implementation timeline of 22 February 2018.

Next Events

The Authority approved Option 2 on 22 June 2017 for implementation on 22 February 2018.


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