P459 ‘Allowing different Supplier Agents to be appointed to Import and Export MSIDs’

The first Workgroup meeting will be held on 23 February 2024.

On 6 September 2023, Elexon received a request from Scottish Power to discuss a potential alternative solution for P459 Allowing different Supplier Agents to be appointed to Import and Export MSIDs’.

Since the Assessment Phase has not yet started Workgroups, Elexon had an informal meeting with Scottish Power to analyse their proposal:

Issue

• No flag on the current D0155 lets a MOP know they are being appointed for an Export supply tied to an Import MPAN the MOP is already appointed to.
• MOPs these days generally don’t accept D0155s from a Supplier they don’t have a contract for or in a GSP Group they aren’t contracted for.
• BSC and REC clearly state that the export Supplier needs to appoint the Import MOP
• Allowing a Supplier to appoint a different MOP does not resolve the issue of the MOP not knowing it is an Export MPAN and runs the risk of the meter being changed/updated impacting the Import supply

Proposed solution

• Amend the D0155 to allow the supplier to tell the MOP it is an Export MPAN supplied via a meter already covered by an Import, DCC enrolled, smart meter they are appointed for by using the J0048 – Contract Reference. It is mandatory for all D0155s

The Scottish Power solution would require having a REC change but not a BSC one. Hence, the last update that someone had put forward a solution that they thought would remove the need for P459 (but not a REC change) and discussing the solution as part of the P459 Assessment Procedure would only complicate the process.

However, after carefully reviewing the Scottish Power REC Change Proposal with Elexon, the Proposer has concluded that the alternative solution does not fundamentally solve the P459 problem statement because:

• The Scottish Power solution only works if the MOP is willing to accept the appointment in the first place. It just provides an association with the Import MPAN but if the MOP doesn’t want to accept the Export appointment it doesn’t resolve the defect.
• Allowing different MOPs to be appointed on Import Export sites could cause the below problems:
  • Not all MOPs have capabilities to remotely connect to all Meter types.
  • All MOPs follow the Change of Agent process which means they are allowed to attend site once appointed and replace the existing meter(s) and Comms on site. This can cause problems for the other appointed MOPs and stop them from dialling the Meters they have on record if a fault is raised, which can result in a site visit being booked and wasting money on pointless site visits.
  • Replacing the Meter(s) & Comms on site can also stop the HHDC in remotely connecting to the Meter, which can have a massive impact on settlement and SF performance.
  • Can cause issues with MOPs not being able to correctly program other MOPs Meters if a programming issue occurs, i.e. incorrect CT’s, multipliers being incorrectly programmed, which can cause CAT1 Non-compliance for TAA Audits also have an impact on Settlement and SF performance.
  • MOPs can also be found non-compliant when doing TAA audits. As the MOPs need to provide the TAA proof of the Metering Technical details that are within the MOPs system and what is on site. If there is a missed meter change all because the other MEM has not forwarded the Newly installed meter details over to the other appointed MOP this is a CAT1 non-compliance.
  • Can also cause issues for the customers needing to arrange two separate site visits for two different MOPs.

Therefore, P459 will continue analysing Good Energy’s proposal through the Workgroup process. Since REC, SEC and potentially DCUSA changes are still needed, P459 will progress as a Cross-code package as planned and require careful MHHS consideration.

The BSC Panel considered the Initial Written Assessment for P459 at their meeting on 10 August 2023

Good Energy raised P459 on 3 August 2023