P399 BSAD Identity Visibility

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

Formal title: Making the identity of Balancing Service providers visible in the Balancing Services Adjustment Data

Current Status

Initial Written Assessment
Assessment Procedure
Report Phase
With Authority
Awaiting Implementation


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.


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This Modification was raised on Tuesday 24 December 2019 and the Initial Written Assessment was presented to the Panel on 16 January 2020. The first Workgroup was held on 27 January 2020 where two potential solutions were sent for impact assessment. These were assessed at the second Workgroup meeting, held on 27 March 2020. At this meeting National Grid ESO (NGESO) identified a potential solution that could significantly reduce lead times and costs of implementation. Following the return of NGESO’s revised Impact Assessment, the Workgroup agreed to consult on a Proposed Solution at its third meeting.

The Assessment Procedure Consultation was issued on 17 August for 15WD with responses considered at its fourth Workgroup meeting on 18 September. Based on these responses and further analysis, the Workgroup agreed on a solution for P399.

The Panel progressed P399 to Report Phase at its meeting in October 2020 (307/08). The Report Phase Consultation was issued on 15 October for a period of one calendar month due to EBGL impacts. The NGESO response to this consultation could require a material change to the solution and so the Workgroup was reconvened on 30 November 2020, per EBGL requirements. The Workgroup determined not to amend the P399 solution and the second Report Phase Consultation was issued on 8 December 2020 with responses invited by 22 December 2020. Responses were collated and presented to the Panel at its meeting on 14 January 2021 and the Modification Report was subsequently sent to Ofgem on 19 January with a recommendation for approval.

Ofgem approved P399 on 18 May 2021 and the Modification was implemented on 4 November 2021 as part of the November 2021 BSC Release.

Next Events

P399 was implemented on 4 November 2021.


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