BSC Panel 214 11 July 2013
Report on Progress of Modification Proposals Adam Lattimore 11 July 2013
214/04 P295 ‘Submission and publication of Transparency regulation data via the BMRS’ Talia Addy/Tariq Hakeem 11 July 2013
P295 – Transparency Regulation Tariq Hakeem - National Grid
P295 - Issue • Regulation No 543/2013 (Transparency Regulation) has come into force with an implementation date of 4th January 2015 • The regulation sets out a number of data items that Transmission System Operators (TSOs) have to submit for publication on Electricity Market Fundamental Information Platform (EMFIP) • National Grid as TSO will be required to submit data on behalf of primary data owners • P295 proposes that National Grid submits data to Elexon who then submit the data to EMFIP on behalf of GB • Consideration needs to be given to the interaction between outage data published under P295 and that published under P291
P295 - Solution • National Grid submits a large amount of data to Elexon to support settlement arrangements - some of this data is published on the BMRS • P295 proposes that the information for publication on EMFIP is submitted to Elexon via the existing National Grid / Elexon data channels for onward submission to EMFIP • BSC parties may well derive value from the publication of some / all of this EMFIP data on BMRS
P295 - Benefits • Submission of EMFIP data via Elexon would allow BSC parties to decide how much of the data should also be published on the BMRS, and in what formats etc • Changes to publication and formatting of this data will be under the governance of Elexon and could be amended more easily should BSC parties require it • Submission via Elexon also utilises existing data channel infrastructure
P295 – Applicable Objectives • Better meets Applicable BSC Objective (c) – publication of data on BMRS would allow information to be more accessible to BSC Parties; and • Better meets Applicable BSC Objective (e) – P295 would deliver the legally binding regulation more efficiently as the data would use existing National Grid / Elexon data channels
P295: Modification Proposal • Amend the BSC to allow ELEXON to be the GB data provider for all data that the Transmission Company is required to submit to the EMFIP under the Transparency regulation • Some or all of this data published on the BMRS
P295: Things to Consider (1 of 2) • What information is required under the Transparency regulation? • What information should be published on the BMRS? • What are the obligations on submitting the information?
P295: Things to Consider (2 of 2) • What changes are required to support the proposed solution? • Are there any alternative solutions? • What are the benefits against the Applicable BSC Objectives?
P295: Proposed Progression • Recommend that P295 progresses to an Assessment Procedure • Recommend a four month Assessment Procedure • Three Workgroup meetings • 15WD Impact Assessment & 15WD Assessment Consultation • Assessment Report presented to Panel in November • Workgroup membership should include: • P291 & Issue 47 Workgroup members • SSMG members • Other relevant experts & interested parties
P295: Recommendations The Panel is invited to: • DETERMINE that Modification Proposal P295 progresses to the Assessment Procedure; • AGREE the proposed Assessment Procedure timetable such that an Assessment Report should be completed and submitted to the Panel at its meeting on 14 November 2013; • DETERMINEthat the P295 Workgroup should be formed from members of the P291 and Issue 47 Workgroups and the Settlement Standing Modification Group, along with any other interested parties; and • AGREE the Workgroup’s Terms of Reference.
214/05 Request to raise a Modification; ‘Introduction of a ‘Fast Track’ Modification Process following the outcomes of the Code Governance Review (Phase 2) Claire Anthony 11 July 2013
Code Governance Review Phase 2 • Aimed to enable other industry codes to benefit from the CGR Phase 1 outcomes • Final outcomes published 27 March 2013, along with a Statutory Licence changes consultation • Impact of CGR Phase 2 on BSC • Introduction of the new ‘Fast Track’ Self-Governance process • The Fast Track process would be used to correct any manifest errors and minor housekeeping changes
Modification Proposal • The Issue: • In light of the final publication of the licence conditions, the new Fast Track Self-Governance process needs to be incorporated into the BSC by 31 December 2013 • Proposed Solution: • The BSC will be amended to introduce the Fast Track Self-Governance Modification Process
Fast Track Process Proposer raises Fast Track Self Governance Modification Proposal presented to BSC Panel (Panel unanimously agree) (Panel disagree) Final Fast Track Self-Governance Report Treat either as: published on BSC Website a) Standard ‘Self-Governance’ Modification (15 WDS to object) b) Modification Proposal
Proposed Progression • Recommend: Report Phase – APPROVE • Merits of Proposal are self-evident • The Modification Proposal will enable the quick progression and implementation of minor housekeeping changes to the BSC without the need to go through the full Modification process • Recommend: Implementation Date • 31 December 2013 in line with the changes to Standard Condition C3 of the Electricity Transmission Licence
Applicable BSC Objectives • Modification Proposal better facilitates Applicable BSC Objectives • (a) The proposed changes will mean that the BSC is consistent with SLC C3 of the Licence; and • (d) The Modification Proposal will enable the progression and implementation of minor housekeeping changes • What are the Panel’s views on the Applicable BSC Objectives? • Are there any further questions that the Panel would like to ask as part of the Consultation?
Recommendations We invite the Panel to • RAISEthe Modification Proposal in Attachment A • SUBMIT the Modification Proposal directly to the Report Phase • AGREE a provisional recommendation that the Modification should be made • AGREE a provisional Implementation Date of 31 December 2013 in line with the requirement in Standard Condition C3 of the Electricity Transmission Licence • AGREE the draft legal text in Attachment B • AGREE the draft redlined changes to BSCP40 in Attachment C and • AGREE that the Draft Modification Report should be issued for consultation and submitted to the Panel at its meeting on 12 September 2013
214/06 P283 ‘Reinforcing the Commissioning of Metering Equipment Processes’ Claire Anthony 11 July 2013
P283: Issue • Panel raised P283 on recommendation of PAB • Technical Assurance of Metering Expert Group (TAMEG) and ELEXON concerns • Certain Metering Equipment usually not within Registrant/MOA control when commissioning required • Issues cause incomplete commissioning and records; and incorrect Meter readings (which can lead to significant error)
P283: Proposed Solution (1 of 2) • Make Equipment Owner responsible for • Commissioning current transformers and voltage transformers • Providing relevant records to the Registrant • Two tier approach to obligations • If BSC Party – obligations would lie with the Equipment Owner (LDSO or Transmission Company) • If not a BSC Party – obligations would rest with the Registrant
P283: Proposed Solution (2 of 2) • Require MOA to confirm status of HH Commissioning to Registrant • Metering Equipment commissioned in accordance with CoP4 or • Identified defects/omissions in commissioning of Metering Equipment • Require Registrant to assess and address identified issues • Act to resolve issues that constitute a risk to Settlement • Consult relevant participants and agree steps to address issues • Could include further commissioning of Metering System
P283: Panel’s Initial Views (1 of 2) • Unanimous view that P283 would better facilitate: • Objective (b), because it would improve the accuracy of metered volumes which would promote effective operation of distribution systems • Objective (d), because data entering Settlement would be improved under the P283 arrangements; and • Objective (c), because competition would be improved by increased confidence in the Settlement and commissioning processes as a result of the P283 arrangements • Panel considered that the main benefits of P283 would be against Objectives (b) and (d), with marginal benefit against (c)
P283: Panel’s Initial Views (2 of 2) • Unanimous support for • Implementation Date • 6 November 2014 (November 2014 BSC Release) if an Authority decision is received on or before 6 November 2013; or • The next BSC Release at least 12 months from the date the decision is received, if an Authority decision is received after 6 November 2013 • Legal text • CoP4 drafting
P283: Report Phase Responses(1 of 2) • 12 responses to Report Phase Consultation • Unanimous support of • Modification • Applicable BSC Objectives • Panel’s initial recommendation to approve P283 • Implementation Approach
P283: Report Phase Responses (2 of 2) • No comments were received on the BSC legal text • Several comments received on CoP4 redlining • Minor amendments consisting of further clarification and typographical errors, which have been incorporated into the CoP4 redlining • No new arguments put forward
P283: Panel’s Final Recommendations • Panel invited to confirm its views that P283 would better facilitate Applicable BSC Objectives (b), (d) and (c)?
P283: Recommendations (1 of 2) We invite the Panel to • NOTE the P283 Draft Modification Report and the Report Phase consultation responses • CONFIRM the recommendation to the Authority contained in the P283 Draft Modification Report that P283 should be made as it would better facilitate Applicable BSC Objectives (b), (d) and (c) • APPROVEan Implementation Date for P283 (if approved) of • 6 November 2014 if an Authority decision is received on or before 6 November 2013; or • If an Authority decision is received after 6 November 2013, the next BSC Release at least 12 months from the date the decision is received
P283: Recommendations (2 of 2) • APPROVEthe BSC legal text and CoP4 redlining for P283; and • APPROVE the P283 Modification Report or INSTRUCT the Modification Secretary to make such changes to the report as the Panel may specify
214/07 P291 ‘REMIT Inside Information Reporting Platform for GB Electricity’ David Kemp 11 July 2013
P291: Background & Issue (1 of 2) • REMIT requires market participants to publish inside information • Regulation does not explicitly set out what should be reported • Non-binding ACER guidance provides more detail • ACER expressed preference for using central reporting platforms • Participants can also use their own websites • But this can make it harder for participants to locate all information quickly
P291: Background & Issue (2 of 2) • BMRS publishes and reports data relating to the BM, Settlement and the market in general • Info on BMRS not used in Settlement • BMRS website freely available to view by anyone • P291 proposed BMRS website as best place for a central REMIT platform for GB electricity market • Changes to BMRS reporting require changes to BSC
P291: Proposed Solution • Central reporting platform will be placed on BMRS website • Considered ACER’s best practice example • Participants can submit messages via either the ELEXON Portal and/or existing Grid Code submissions • Grid Code route could only be used by Grid Code participants and only for outage-related information • Participants will be able to choose to use only one route if they wish • BSCCo and TC will forward messages received to BMRA for publication • Use of the platform would be voluntary
P291: Panel’s Initial Views (1 of 2) • Unanimous: P291 would better facilitate Objectives (c) and (e) • Info on public platform means freely accessible to all (c) • Ancillary benefits from non-BSC Parties using platform (c) • Better facilitate compliance with REMIT (e) • Align with spirit of Objective (e) • Unanimous recommendation to approve P291
P291: Panel’s Initial Views (2 of 2) • Unanimous Panel support for Workgroup’s proposed Implementation Date: • 31 December 2014 if approved on or before 31 March 2014 • Panel unanimously agreed draft legal text for Report consultation
P291: Report Phase Responses (1 of 4) • Majority view that P291 should be approved • Would better facilitate Objectives (c) and (e) – agree with Panel’s views • May better facilitate Objective (b) (minority view) • Would be detrimental to Objective (d) (minority view) • But believes benefits against other Objectives outweighs this impact 1 of 2
P291: Report Phase Responses (2 of 4) • One respondent has neutral view on P291 • Support principle of platform • Believe more holistic consideration needed with Transparency reg. (P295) • P291 raised to fix specific defect (REMIT platform) • Transparency reg. out of scope 2 of 2
P291: Report Phase Responses (3 of 4) • Several comments received on legal text • Some amendments made to improve clarity
P291: Report Phase Responses (4 of 4) • General agreement with Implementation Date • Welcome decision to align with Transparency regulation
P291: Panel’s Final Recommendation • Panel invited to confirm its views that P291 would better facilitate Objectives (c) and (e) for the reasons previously given • Panel invited to consider the views put forward against Objectives (b) and (d)
P291: Recommendations (1 of 2) ELEXON invites the Panel to: • NOTE the P291 Draft Modification Report and the Report Phase Consultation responses; • CONFIRM the recommendation to the Authority contained in the P291 draft Modification Report that P291 should be made as it would better facilitate Applicable BSC Objectives (c) and (e); [Continues]
P291: Recommendations (2 of 2) • APPROVE an Implementation Date for P291 (if approved) of: • 31 December 2014 if an Authority decision is received on or before 31 March 2014; • APPROVE the BSC legal text for P291; and • APPROVE the P291 Modification Report or INSTRUCT the Modification Secretary to make such changes to the report as the Panel may specify.
Minutes of Meetings 213 & Actions Arising Adam Richardson 11 July 2013
Chairman’s Report BSC Panel Andrew Pinder 11 July 2013
214/01 ELEXON Report Peter Haigh 11 July 2013
Distribution Report David Lane 11 July 2013
National Grid Update Ian Pashley 11 July 2013