SLC 19 & Best Practice in Connections
Content • Substantive proposed changes for the SLC 19 reporting template • SLC 19 audit • Best practice standards 2
SLC 19.4 REPORTING TEMPLATE 3
SLC 19 Context Approach • SLC 19 requires the • The template was initially submission of annual reviewed with input from reporting to confirm no B.Hoy and S.Bolland discrimination and unfair • Legal have also provided treatment input and will do so further • Ofgem is receiving a to finalise the questions number of complaints • General review of the concerning discrimination layout and structure of questions in the template • The need for evidence of non-discrimination was also considered during review 4
Specific Additions to the Template Changes Reasoning Declaration of services provided Context for activities completed by/obtained from DNOs’ affiliates with affiliates and how obtained Details of DNOs’ affiliates in and Context for activities completed by out of area affiliates in and out of area Provision of the actual policy Provides evidence and point of statement in place in a DNOs’ reference of the policy in place for business and details of which non-discrimination areas of the Group that this policy applies to Details of arrangements in place To ensure non-discrimination and for unmetered provides evidence specifically on e.g. Charges for UoS, access to unmetered services non-contestable services, access to bespoke services (rent a jointer) 5
Additions to the Template contd. Changes Reasoning Details of DNO policy for asset Evidence of policy and details of adoption (e.g. Type of terms of security agreement) and terms of security required for all parties may adopt from Extension of measures taken to The current question asks for ensure non-discrimination to details of how ICPS are not include ‘other customers’ discriminated against, but 19.3(c) talks about the business of ‘any other person’ 6
Additional themes added to Template Accountability and audit Communication of SLC 19 requirements The questionnaire The questionnaire currently requests details of the requests details of the following: following: • Staff member responsible for • Details of how SLC 19 requirements compliance are communicated in the • Terms of reference of an audit organisation to operational staff • Process for completion of the • This has been extended to request audit function details of how these licence • Frequency of internal audit requirements are communicated to • Accreditation of internal auditors managerial and executive staff and • Company registration numbers of the methods used to communicate those separate parts of the Group these effectively to different sectors that are audited of the organisation • Any parts of the Group audited • What parts of the Group are separately (with details as above) targeted by this communication policy? 7
SLC 19 AUDIT 8
Update • Terms of Reference have been received from S.Bolland which we are reviewing for circulation to DNOs • It is proposed for there to be an independent spot audit on one DNO a year, every year • ECSG members will be kept informed on this • Comments are requested 9
BEST PRACTICE IN CONNECTIONS 10
Introduction • SLC 19: refers to non-discrimination and evidence to prove this has not occurred • Ofgem has received lots of complaints about DNOs concerning practices that customers and industry consider anti-competitive behaviours and potential barriers to competition • Under DPCR5, Ofgem has given DNOs the chance to earn an unregulated margin if they can prove they have encouraged competition in their area • DNOs to devise their own approach for demonstrating how there is competition or no barriers to competition in their area • DNOs have an opportunity to lead and develop standards of best practice for consideration 11
Themes 1. Stakeholder Engagement - Treatment of customers - Resolution of complaints (e.g. Retail issues) - Provision of advice and consultation (e.g. Breakdown of costs, charging statement, contestable v non-contestable, apportionment.) 12
2. Access to information – Substation general arrangement drawings – Code of practice relating to substation design up to 33kV – Cable installation practice up to 33kV – Code of practice relating to HV network protection (up to 33kV) – Code of practice re: LV network protection – Design policy for industrial supplies – Design policy for HV networks up to 33kV – Current network load information/feeder load analysis – Problems in accessing updates to information in general 13
3. Notification of Mergers and Acquisitions – Potential merger of competitive arm of a DNO into the main business – Provision of multi-utility quotes in area – No level playing field as the competitive arm no longer needs to compete with IDNOs – Ring-fencing arrangements 4. Adoption agreements – Potential discrimination and stringent application of S16 versus SLC 15 – Need for engagement and compromise – Potential charging for budget estimates 14
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