Request for Urgency: P348 and P349 4 July 2016 Talia Addy
P348: Background and Issue CMP264 seeks to limit the impact of the a continuing lack of a level playing field between ■ New Embedded Generators and other generation plant – suspend access to Triad avoidance for New Embedded Generators until Ofgem considers issues associated with Triad Avoidance Currently, in order to calculate TNUoS charges, the SVAA sends the TC net, aggregated ■ metered data for SVA metering systems In order to implement and discharge the requirements of CMP264, the TC will need gross ■ metered data for specific SVA New Embedded Generation
P348: Solution P348 seeks to enable the SVAA to provide gross export and gross import data to the TC to ■ support proposed revisions to TNUoS charging under CMP265 Currently , the TUoS report provides the “Period HH Allocated Volume” data in the “HHA ■ Record Types” (for Supplier BMUs) on the basis of demand net generation within GSP Groups P348 proposes that the SVAA report details of gross import and export volumes by inserting ■ two new columns into the TUoS report: – “ Period BMU HH Allocated Gross Import Volume ” – “ Period BMU HH Allocated Gross Export Volume”
P348: Areas to Consider & Workgroup Membership What changes are needed to BSC documents, systems and processes to support P348 and ■ what are the related costs and lead times? Are there any Alternative Modifications? ■ Does P348 better facilitate the Applicable BSC Objectives compared with the current ■ baseline? We recommend that the P348 Workgroup includes: ■ – members of the CMP265 Workgroup – other relevant participants and interested parties
P348: Request for Urgency The P348 Proposer has requested that this Modification be treated as an Urgent Modification ■ Proposal because: – it is linked to an imminent issue or a current issue that if not urgently addressed may cause a significant commercial impact on parties, consumers or other stakeholder(s) – it is vital that a decision is made ahead of the December 2016 CM Auction – P348 needs to be progressed in line with CMP265 as much as possible so that Ofgem will receive both Modifications in beginning of October 2016 The Proposer believes that progressing this as an Urgent Modification Proposal is the most ■ appropriate and robust way to progress P348
P348: Proposed Progression ELEXON recommend P348 is sent into the Assessment Procedure ■ Timetable 1 (two month assessment, no Report Phase) Two Workgroup meetings Relevant Impact Assessments Assessment Consultation (15 WDs) Final Panel recommendation by end of September Timetable 2 (1.5 month assessment, including Report Phase) Two Workgroup meetings Relevant Impact Assessments Assessment Consultation (10 WDs) Initial Panel recommendation by beginning of September Final Panel recommendation by end of September
P349: Background and Issue CMP265 looks to amend the residual element of the TNUoS demand tariff to mitigate ■ arbitrary and discriminatory “embedded benefits” – these are currently available to exemptible generation connected within distribution systems where those embedded generators operate in the CM The TC receives the TUoS Report (P0210) from the SVAA, which it uses to calculate indicative ■ and actual TNUoS charges – Currently provides “Period HH Allocated Volume” data in the “HHA Record Types” (for Supplier BMUs) on the basis of demand net generation within GSP Groups To facilitate CMP265 it is proposed that the SVAA reports details of gross import and export ■ volumes by inserting two new columns – “Period BMU HH Allocated Gross Import Volume” – “Period BMU HH Allocated Gross Export Volume” into the TUoS report
P349: Solution P349 will introduce a requirement under the BSC for: ■ – Suppliers (that are the registrants of New Embedded Generators) to tell their HHDAs which MSIDs relate to New Embedded Generation – HHDAs to provide Period Metered Data from these MSIDs to the TC in the most efficient and cost-effective process New Embedded Generators will be defined as any HH metered embedded generation unit ■ commissioned after 30 June 2017, where commissioned is defined as the point at which an MSID is first registered in SMRS and first commences generation The implementation of CMP264 requires both SVA and CVA meter data flows for new ■ embedded generation. – The TC should already receive the necessary CVA however, if not this Modification will require including CVA as well as SVA registered generators
P349: Areas to Consider & Workgroup Membership What is the most efficient and effective way for HHDAs to send the required data to the TC? ■ What changes are needed to BSC documents, systems and processes to support P349 and ■ what are the related costs and lead times? Are there any Alternative Modifications? ■ Does P349 better facilitate the Applicable BSC Objectives compared with the current ■ baseline? We recommend that the P349 Workgroup includes: ■ – members of the CMP264 Workgroup – other relevant participants and interested parties
P349: Request for Urgency The P349 Proposer has requested that this Modification be treated as an Urgent Modification ■ Proposal because: – a decision needs to be made on this Modification time to allow necessary system changes to be made before the cut-off date for New Embedded Generators defined in CMP264 (i.e. before 30 June 2017) failure to meet this timetable will be likely have significant commercial impact on relevant industry parties and delay the benefits of CMP264 being realised – P349 is best progressed in line with CMP264 to allow Ofgem to have all the necessary information to enable it to make a holistic decision based on the combined costs and benefits of both changes The Proposer therefore feels that Urgent progression of P349 is appropriate ■
P349: Proposed Progression ELEXON recommend P349 is sent into a the Assessment Procedure with the same timetable ■ and Workgroup as P348 Timetable 1 (two month assessment, no Report Phase) Two Workgroup meetings Relevant Impact Assessments Assessment Consultation (15 WDs) Final Panel recommendation by end of September Timetable 2 (1.5 month assessment, including Report Phase) Two Workgroup meetings Relevant Impact Assessments Assessment Consultation (10 WDs) Initial Panel recommendation by beginning of September Final Panel recommendation by end of September
P348: Recommendations We invite the Panel to: AGREE that P348 progresses to the Assessment Procedure; ■ AGREE to recommend to the Authority that P348 should be treated as an Urgent ■ Modification Proposal; AGREE the Urgent progression timetable, subject to Authority approval; ■ AGREE the proposed membership for the P348 Workgroup; and ■ AGREE the Workgroup’s Terms of Reference. ■
P349: Recommendations We invite the Panel to AGREE that P349 progresses to the Assessment Procedure; ■ AGREE to recommend to the Authority that P349 should be treated as an Urgent ■ Modification Proposal; AGREE the Urgent progression timetable, subject to Authority approval; ■ AGREE the proposed membership for the P349 Workgroup; and ■ AGREE the Workgroup’s Terms of Reference. ■
Recommend
More recommend