P420 ‘Retail Code Consolidation Significant Code Review’

P420 was implemented on 1 September 2021.

Ofgem confirmed approval of P420 on 23 July 2021 for an Implementation date of 1 September 2021.

Final Authority Led SCR Modification Report

The P420 Final Authority Led SCR Modification report was presented to the Panel at its meeting on 8 July 2021.

The Panel unanimously agreed with all recommendations and P420 will be implemented on 1 September 2021 subject to Ofgem confirmation.

Industry Consultation

P420 was issued for Industry Consultation on 17 May 2021 with responses invited by Thursday 17 June 2021.

We received six responses to the Industry Consultation representing Distributors, a
Supplier and a Trade Body. The main objectives of the Consultation period was to provide
market participants an opportunity to comment on the EBGL objectives and whether the
proposed redlining met the intention of P420.

No respondents objected to the Panel’s recommendations that P420 does impact EBGL
Article 18 terms and conditions related to balancing held within the BSC, noting they were
not in a position to comment, or agreed with the initial assessment that the changes were
minor.

BSC Panel Update

The P420 Draft Authority Led SCR Modification report was presented to the Panel at its meeting on 13 May 2021.

The Panel unanimously agreed with Ofgem’s opinion that P420 better facilitates Applicable BSC Objective (d).  All other recommendations were agreed.

Authority Led SCR Modification Procedure

As P420 is an Authority Led SCR Modification, it will not follow the standard Modification Procedures  

There is a significant amount of redlined changes made to 15 BSC Sections and 49 Code Subsidiary Documents, due to the volume of change the following timetable will be adhered to as part of P420, this provides a one month consultation period as per the EBGL Article 18 terms and conditions change process.

Ofgem raised P420 on 10 May 2021. This is an Authority Led SCR Modification and as such will not follow the standard Modification Procedures. Instead it will follow the timetable set by the Authority and the Authority Led SCR Modification Proposal procedure detailed in BSC Section F5.3A.

Why Change?

P420 is being raised to ensure the BSC aligns with Ofgem’s Retail Code Consolidation Significant Code Review, which consolidates a number of existing codes into the REC. The proposed changes have a direct impact on the BSC in terms of the transfer of the SVA Metering arrangements from the BSC to the REC and cross-code change procedures, as well as consequential changes reflecting the close down of the MRA.

Solution

P420 makes the necessary changes to reflect the code governance changes implemented through the Retail Code Consolidation SCR. Specifically, it will:

1. Ensure the BSC reflects the close down of the MRA.
2. Transfer operational procedures relating to Metering Point Lifecycle from the MRA to the BSC.
3. Make the necessary changes to transfer SVA Metering arrangements to the REC, and facilitate a transition period for metering assurance.
4. Insert the required drafting to give effect to the CCSG, which will be established under the REC to better facilitate cross-code change

Next Steps

Elexon will present the Draft Authority Led SCR Modification Report to the BSC Panel on 13 May 2021.