P395 ‘Excluding generators from BM Unit Gross Demand and the calculation of EMR Supplier Charges’

Formal title: Excluding generators from BM Unit Gross Demand and the calculation of EMR Supplier Charges

Current Status

Initial Written Assessment
Assessment Procedure
Report Phase
With Authority
Awaiting Implementation


As per ELEXON’s communication concerning the impact of COVID-19 the timeline for P395 has been pushed back. The Assessment Consultation is now due to be issued August 2020.


Currently the BM Unit Gross Demand Report attributes to Suppliers electricity they have provided to generators (including storage facilities) operated by Generation Licensees, which falls outside the definition of ‘supply’ in the Electricity Act 1989.

P395 proposes to amend BSC systems and processes so that the SAA-I042 ‘BM Unit Gross Demand Report’ only includes electricity ‘supplied’ to premises by licensed Suppliers, and therefore excludes electricity imported by Generators operated by a licensee for generation activities (i.e. those activities authorised by their generation licence to carry on).

If you would like to join the P395 Workgroup, attend as a non-voting attendee, or be added to the P395 distribution, please let us know by emailing [email protected]


Centrica raised P395 on 7 November 2019. The Panel considered the IWA on 14 November 2019 and agreed to advance the Modification to the Assessment Procedure. The first meeting of the P395 Workgroup was held on 19 February 2020, with the Workgroup and Proposer agreeing with ELEXON’s interpretation of ToR A) ‘Which imports should be chargeable?’ The Workgroup noted that answering the P395 problem satisfactorily will involve consideration of scalability, practicality and cost to ensure that the solution is truly enduring, consistent with regulations and scalable to domestic level. 

Next Events

The first meeting of the P395 Workgroup took place on Wednesday 19 February 2020 at ELEXON's offices. We are progressing actions taken from this meeting while ascertaining the best time for the next meeting.


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