Energy Networks Association

1. Energy Networks Association Root cause solution for unregistered sites / MPRN creation Erika Melén 28th February 2013

2. MPRN Creation - Background • GDNs proposed the MPRN Creation solution – MPRNs are created by shippers and a supply contract is required before the service is laid. • This went out for industry consultation in December 2012 and closed 4th January 2013 • A total of 7 responses were received from a variety of industry participants including GDNs, IGTs, UIPs, MAMs and Shippers Energy Networks Association

3. MPRN Creation – Consultation Responses • There was general support from Shippers with some minor suggested amendments • The UIPs and MAM businesses that responded were very opposed to the proposal as they feel that it would be anti competitive and would complicate the process for end users. Two UIPs have indicated that they would commence legal proceeding should the proposal be implemented. • The IGT respondent was supportive as long as this process is not applied to IGTs but stated that they did not believe this would resolve all unregistered sites and questioned whether this would work for I&C connections and multi-meter point developments Energy Networks Association

4. MPRN Creation – Consultation Responses Concerns Raised • I&C Connections – as a large majority of these connections are speculative i.e. the connection is needed but may not be used for some time. The UIPs especially felt very strongly that this new process would limit their workload as developers would not wish to get a supply contract • Multi meter point developments – As these sites can span over several years ensuring that supply contracts are in place could severely delay the progress for these sites (including fuel poor connections) • Anti competitive – UIPs and MAMs raised concerns that only allowing shippers to create MPRNs will be anti competitive as customers will have to go through a shipper for their MPRN and so the shipper would have an advantage over other connection providers and meter installers. This was discussed at the Shipperless and Unregistered meeting in January and it was noted that this issue could be overcome by keeping MPRN creation with the Transporters. Energy Networks Association

5. MPRN Creation – Consultation Responses Suggestion Raised • Most of the responses stated that the main issue with unregistered sites is not in fact the service in the ground but the meter being fitted as this allows gas to be offtaken • Respondents (including MAMs) suggested placing obligations on MAMs to not fit meters without supply contracts which would then stop unregistered gas being offtaken • It was also suggested through discussions with UIPs that I&C connections are locked to only allow the connection provider to remove the lock once a contract is in place and a meter is being fitted Energy Networks Association

6. MPRN Creation – Next Steps • GDNs are fully committed to implementing root cause solutions for unregistered sites. We have to take the concerns and suggestions raised in the consultation responses seriously and so have re-thought the root cause solution previously proposed • We note that although the previously suggested approach would go some way to reduce the number of unregistered sites it was not a perfect solution as customers could cancel the supply contract or change supplier and would also potentially mean increased waiting times for customer in getting a new connection. • We have therefore come up with the following package of measures which will have the smallest impact on customers whilst minimising any new unregistered sites being created. Energy Networks Association

7. Unregistered Site – Root Cause Solution Measures Smaller, controlled batches of MPRNs for connection providers – More ownership of MPRN creation, reducing duplicates Investigating the possibility of re-introducing the “Planned” status into Xoserve’s system – Ensuring cleaner data and reducing number of legitimate unregistered sites Further controls over Code12 MPRN creation – Avoiding duplicate MPRNs being raised Energy Networks Association

8. Unregistered Site – Root Cause Solution Measures • MAMCoP obligation to only install meters where a supply contract is in place – Stopping gas being taken without a supply contract being in place • Joint GDN customer connections communications leaflet – Encourage customers to get a supply contract from planned stage in connection process and informing of need for a supply contract before meter fit • MOD410A (if implemented) used as a backstop alongside further monitoring of connection jobs and meter fits by DNs Energy Networks Association

9. Unregistered Site – Next Steps • The smaller actions e.g. batches will be implemented as soon as possible and we will keep industry up to date on progress • We are progressing with the MAMCoP change. This is being raised at the MAMCoP meeting on the 28th February and the official change should be raised for the meeting in May 2013 • A ROM has been raised with Xoserve to investigate the “Planned” status • The customer communications leaflet is with the GDN Communication Manager to progress through ENA • GDNs will be drafting an ancillary document to the UNC and raising a code modification to refer to this in the UNC. The document will outline the MPRN creation process with the amendments outlined in previous slides Energy Networks Association