Change Consultations

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Ofgem and BEIS published their consultation on reforming the energy industry codes in July 2019, and the BSC Panel has published its response. While the Panel agrees with the general issues identified in the code review, its members believe there is an overarching need to ensure that the codes are robust and workable.

Views expressed in this response are those of the vast majority of the Panel and do not seek to represent those of ELEXON or Parties to the BSC.

ELEXON’s response sets out how the required volumes for determining Energy Company Obligation targets can be obtained from existing data flows, and where the consultation has incorrectly identified Consumption Component Classes relating to domestic consumption.

ELEXON’s response sets out how a BSC-based solution would work to enable fixed residual charges. We also note a number of areas which we believe require further consideration before Ofgem makes its final decision on its Targeted Charging Review proposals. These are:

• Timing – We believe that industry may not have the capacity to implement the necessary changes by April 2021, given the current change pipeline.
• Interaction with other projects – Ofgem should take opportunities, where possible, to develop common ‘whole system’ solutions and to minimise the risks of competing projects.
• Definitions – The proposals would benefit from greater clarity, e.g. in the definitions of ‘final demand’ and ‘site’. 

ELEXON’s response challenges OLEV’s rationale for producing a Phase 2 decision in 2023, noting that there are EV demonstration projects that will run into 2021 and the Smart Meter rollout and MHHS which are not likely to conclude until 2023-24 . Secondly, we found OLEV’s separation of public and private use cases overly simplistic, noting that there are public and private use cases that share characteristics, and could benefit from common solutions.  Finally, we encourage OLEV to consolidate its and industry’s work on EVs, e.g. through the adoption of a single repository of EV issues and proposals, to facilitate holistic policy design and the identification of overlap. 

ELEXON’s response highlights the need for further clarity around the definition of Energy Efficiency measures. We note that non-controllable demand reduction measures should be encouraged by market signals such as Time of Use Tariffs, whilst active technologies can respond to active signals, such as those used in the Capacity Market. 

ELEXON is proposing that nationwide electricity ‘flexibility platforms’ are set up so that offers to provide ‘demand-side response’, or output from electricity storage facilities can be traded easily.

The buyers of storage output or demand-side response (DSR) services could include local electricity distribution network operators (DNOs) suppliers and businesses.

In our response to ENTSO-E’s consultation, we concentrated on a single aspect: 

Whether the proposed wording for the templates would be sufficient to encourage TSOs and ENTSO-e to consider the impact that the operation of national rules for market suspension and of European rules for market de-coupling could have at both national and regional levels in each crisis scenario?

ELEXON’s response highlights our support for innovation and provides examples of innovation we have spoken to customers about. We requested that government and Ofgem are mindful of other industry change programmes, including the review of codes, when considering further changes to retail markets.

In our response to Ofgem’s consultation, we concentrated on the design of the ESO incentives with two key messages:

• that the incentives should encourage ESO to work jointly and collaboratively with ELEXON for maximum customer benefit.
• that the incentive reporting should allow us to compare our own code management performance with that of others, including ESO.

Ofgem and BEIS published their consultation on reforming the energy industry codes in July 2019, and we have published our response.

We continue to strongly support reform of the code arrangements, in particular the objective of consolidation and simplification.

Ofgem and BEIS want to deliver improvements to the codes and code governance arrangements by the mid-2020s and ELEXON will support them in doing so.

ELEXON’s response requests further detail on cross-code cooperation and alignment, additional attention to processes, and asks for REC schedules to align with other industry-wide initiatives.  We also highlight the benefits of procuring an end-to-end REC manager service, avoiding handoffs and maintaining consistency with the principle of a ‘Code Manager’.

ELEXON’s response welcomes the new flexibility commitments from network companies and suggests they attempt to mark progress against these commitments, as well as map them to other initiatives to support flexibility announced over the past year.

ELEXON’s response highlights a number of crucial interactions between new flexibility and existing market structures and describes a number of initiatives currently underway to improve and facilitate smart and flexible energy systems, including P375, P376 and market-wide Half-Hourly Settlement.

ELEXON supports the methodology outlined in the consultation for setting up the REC Manager functions and services. ELEXON note that the approach is akin to the BSC set up for the delivery of services by BSC agents.

ELEXON’s response agrees that the NHH charging arrangements do need to be extended for HH Elective customers who move into Measurement Class F, in order to avoid double charging. It also notes that it is now possible to separate out demand data for Measurement Classes E, F and G from each other due to P348/349. Measurement Class F and G could be charged under separate methodologies if there is the need or desire to do so from Industry Parties.

ELEXON’s response agrees with the updated mapping proposed by National Grid ESO.

ELEXON’s response suggests: a few changes to National Grid ESO’s terms and conditions for Defence Service Providers and Restoration Service Providers; and some amendments to the Plans where they relate to the BSC.

ELEXON welcomes and supports the proposed distinction made between balancing energy bids activated for balancing and those for system constraints.

ELEXON agrees with the scope of the Pricing Proposal Implementation Framework (PPIF) and welcomes the opportunity for stakeholders to provide feedback. However,  we seek clarity on a number of points within the PPIF. 

ELEXON’s response suggests National Grid ESO emphasises the unique challenges that they face which require continued use of specific products for balancing services and states that the continued use of specific products should not distort the markets for any other products.

ELEXON’s response supports the overall intent of the modifications, which is to address concerns raised by Ofgem and BEIS by excluding imports to storage facilities from the calculation of residual DUOS charges. However, we raised concerns with the detail of the proposals:

• Inconsistencies between the DCUSA proposals and related CUSC modification proposals (i.e. CMP280/281) may result in unintended or perverse outcomes
• Aspects of the DCUSA proposals could have been explained in more detail

ELEXON will continue to support the DCP341/342 workgroup and argue the case for alignment between the DCUSA and CUSC proposals.

ELEXON’s response highlights the lack of a clear requirement to register SEG eligible installations for settlement under the BSC.

We believe that settlement of export under the BSC is key to unlocking the full system benefits of Market-Wide Half-Hourly Settlement, which will result in more accurate settlement and apportionment of costs across the system and enable more innovative supply propositions.

Therefore, we propose that the SEG requirements should explicitly require exports to be metered and settled to receive a SEG tariff. We do not believe the current proposals adequately address this.

ELEXON’s response highlights the importance of distinguishing trials from enduring market frameworks and highlights a number of implicit assumptions in the analysis that may need to be surfaced and considered.

The Government has asked the National Infrastructure Commission to assess what changes might be necessary to the existing regulatory framework to facilitate future investment needs in infrastructure focusing on energy, telecoms and water.

ELEXON response includes that:

• data and easy access to data is key to unlocking the next wave of innovation
• new regulatory design should seek to avoid further costs from any proliferation of central services and that we believe the recently launched joint BEIS/Ofgem Energy Codes Review is an ideal opportunity to look at these issues
• consolidating the code governance landscape would be beneficial to innovators

ELEXON’s response states that it is essential that all SMETS variants can have data collected via DCC to realise the full benefit of Market-wide Half-Hourly Settlement, and that meters which are unable to be adopted by DCC should be replaced with those that can.

ELEXON’s response proposes that many of the currently proposed mappings are too broad, and should be made specifically to relevant paragraphs only.

ELEXON’s response questions whether the ESO Code Administration function should be merged with ELEXON to achieve ‘best in class’ standard and suggests ESO incentives should be aligned with collaboration rather than competition. Our response also suggests incentives should fund small scale innovation, and that information sharing is key to achieving whole system outcomes.

ELEXON’s response suggests a number of corrections and clarifications, in particular on the treatment of replacement reserve products and the requirements of generators to provide System Ancillary Services.

Ofgem proposes that the evaluation moves from a ‘per Principle’ evaluation in 2018/19 to a ‘per Role’ evaluation for the 2019/2020 evaluation.

ELEXON believe that this move will give more flexibility to the ESO to allocate its resources and expenditure to areas where improvements will be most valuable to consumers.

However, it will also give more flexibility to the ESO to allocate its resources where it is most cost-beneficial to ESO itself, i.e. to the easier or least costly to meet targets within each role.

For that reason we continue to support both ensuring that the overall incentive is addressed to maximise end consumer benefits and that there is transparency in the detail of ESO expenditure as was proposed by Ofgem in its earlier call for input on the 2019-20 ESO regulatory and incentives framework.

ELEXON’s response agrees with Ofgem’s position on Agent functions and highlights our view on the centralisation of disaggregated data.

ELEXON’s response highlights the areas of the Open Network Project likely to impact on settlement and sets out the areas of work ELEXON should be involved in to maintain consistency between national and local arrangements.

ELEXON’s response proposes that all export should be metered and settled in order to effectively allocate energy on the system, and highlights potential issues with implementing the SEG, especially in short timescales.

ELEXON’s response welcomes Ofgem’s Forward Work Programme and indicates the workstreams we are supportive of.

ELEXON’s response requests a great focus on collaborative working between ESO and ELEXON, and development of a consistent, industry-wide approach to data publication.

ELEXON’s response highlights the importance of a wide definition of whole system, and agrees that licences should contain obligations to consider the whole system.

ELEXON’s response supports the use of heat networks to decarbonise heat in GB and overviews a number of governance and assurance activities that can de-risk the delivery of heat via networks.

ELEXON’s response highlights the importance of accessible data and information and demonstrates the Balancing Mechanism Reporting Service as a useful source of data.

ELEXON’s response highlights the need for greater transparency and timeliness in ENTSO-E’s communications.

ELEXON’S response welcomes the opportunity to comment on the proposed changes within the Supplier Licensing Review consultation.

ELEXON’S response welcomes the intent of the Smart Systems and Flexibility Plan in setting a clear direction for changes in the energy markets and combining a number of the ongoing actions and initiatives that will pave the way for innovation and new services for consumers.

ELEXON’S response welcomes innovation within regulated utilities and outlines potential barriers to this.

ELEXON’s response suggests additional reporting on expenditure would be useful for assessing the suitability of incentives and highlights the high volume of information produced by the ESO on their performance.

ELEXON’s response welcomes the innovations in REC of digitalisation,  consolidation and new code governance models and makes a number of proposals and recommendations on the corporate and operational governance of the REC Manager based on our experience of managing codes.

ELEXON’s response agrees that revenue stacking should be possible where service characteristics do not prevent it and highlights the advantages to competition of removing exclusivity clauses.

ELEXON’s response requests additional clarity on some aspects of mapping European Network Code requirements to GB Codes and proposes a number of additions to the proposed mapping.

ELEXON’s response highlights the benefits to consumers and small-scale generators of settling exports, and how simplifying settlement will encourage new entrants and innovators into the electricity market.

ELEXON’s response suggests that industry should have greater participation in rules development and that coordination of rules changes with industry Codes could be achieved by expanding Code Administrator roles or by introducing industry workgroups to Capacity Market Rules changes.

ELEXON’s response advocates a holistic review of arrangements to ensure coordination across industry initiatives and highlights the importance of the BSC and central systems in delivering the data required by network charging.

ELEXON’s response highlights the importance of consistency and transparency of market arrangements for flexibility and suggests that leveraging existing market structures could deliver the soonest benefits to end customers. We also outline our view of requirements for neutral market facilitation.

ELEXON’s response highlights impacts of the proposals on the current imbalance settlement arrangements in GB and requests further clarity on the inclusion of locally activated volumes in imbalance price calculations and by what mechanism non-main components could be used in imbalance price calculation.

ELEXON’s response views ENTSO-E’s highest priority as the implementation of European Network Codes. We also highlight the importance of wider stakeholder engagement, and harmonisation between internal ENTSO-E workstreams to ensure coordinated decision making.

ELEXON’s response provides an overview of the regulatory uncertainty faced by charge point administrators and calls for a holistic and transparent regulatory approach to electric vehicles.

ELEXON’s response outlines our view that Half-Hourly data for settlement purposes should be mandatory, in order to ensure more accurate and simpler settlement, as well as to enable innovation. We believe this would deliver the greatest benefits to the UK economy and to end consumers.

ELEXON’s response highlights differences between BSC Panel governance, current CUSC Panel governance and proposed CUSC Panel governance, and provides views on alternates, engagement with Panels and on National Grid Panel members.

ELEXON’s response highlighted the problem of visibility of assets for system balancing, and the potential cross-subsidy caused by Group Correction. We proposed that settlement of import and export should be on a half-hourly metered basis and that this will facilitate innovation in time of use tariffs as well as properly value embedded generation.

ELEXON’s response highlighted the potential interest of suppliers and independent aggregators in providing representatives to the Panel. We also highlighted the reliance of ELEXON on ESO for the provision of data and information and the importance of ESO support when working together on Modifications to the BSC.

ELEXON’s response agrees with Ofgem’s intent for the Retail Energy Code (REC) to be a best-in-class code and highlighted the importance of early appointment of the REC manager, establishing an effective RECCo board and panel, and clarifying the accountability between REC manager and REC panel.

ELEXON’s response reiterated our role as a trusted partner of ENTSO-E, highlighted the importance of engagement and coordination with ELEXON on MARI developments, and stressed the importance of developing in cooperation with Project TERRE

ELEXON’s response highlights the importance of the Half-Hourly Settlement programme to unlock the benefits of smart meters and highlights that smart grids should be included in the cost-benefit analysis.

ELEXON’s response highlights our work on Market-wide Half-hourly Settlement and the benefits that smart meters can bring to consumer markets. It also highlights the work we do to support and enable innovation.

ELEXON’s response highlights the efficiencies of a single central data collection and settlement function to ensure smart appliances interoperability, and the importance of the smart meter rollout and the market-wide Half-Hourly Settlement programme for unlocking the benefits of smart appliances.

ELEXON’s response agrees with National Grid’s approach to determining terms and conditions for balancing, and makes a number of comments on the mapping of Electricity Balancing Guideline Article 18 requirements to the BSC.

ELEXON’s response highlights the importance of a consistent approach to signposting system needs across different distribution regions and highlights the success of the Balancing Mechanism Reporting Service as a single source of market information.

ELEXON’s response to the Ofgem consultation on the RIIO2 framework highlights the potential for ELEXON to perform customer engagement group administration functions and questions the applicability of price controls to all ESO functions

ELEXON’s response to SSE Networks and EA Technology’s consultation on distribution network management of smart electric vehicle charging highlights the importance of market-based solutions for flexibility services and outlines considerations drawn from our experience of helping innovative electric vehicle charging solutions understand the market.

ELEXON’s response to Energy UK’s consultation on Acceptable Smart Charging Standards. Our response highlights the work we have been doing to support innovative charging solutions and outlines uncertainties around existing interoperability and regulatory requirements.

ELEXON’s response to ENTSO-E’s consultation on the Replacement Reserves Implementation Framework for Project TERRE. Our response seeks clarification on a number of points, highlights concerns on the timeline for finalising the definition of gate closure time and requests provisions allowing for ELEXON representation on expert groups.

ELEXON’s response to Ofgem’s analysis of code and licence changes that may be needed for EU exit broadly agrees with Ofgem’s analysis and makes some points of clarification.

ELEXON’s response to draft guidance on reporting and incentive arrangements for the Electricity System Operator. We question whether it is appropriate to pay the ESO to reach best-in-class standards of code administration and provide a number of suggestions for the Performance Panel.

ELEXON’s response seeks clarification of a number of proposed licence conditions and highlights some additional reporting requirements on rejected consultation responses.

This is ELEXON’s response to National Grid’s consultation ‘Proposed revisions to the Applicable Balancing Services Volume Data Methodology’. This formed part of National Grid’s annual consultation on its C16 licence statements.

This is ELEXON’s response to National Grid’s consultation on the first Forward Plan for its new separate Electricity System Operator role.

This is ELEXON’s response to the Energy Networks Association consultation on the 2018 forward work plan for their Open Networks project

ELEXON’s response to Ofgem’s consultation notes observations on several of the workstreams under two of four Key Priorities: Priority 1 – Enabling a better functioning retail market; and Priority 2 – Facilitating change in the energy system

This is ELEXON’s response to ENTSO-E’s (EU Transmission System Operators) 2017 stakeholder satisfaction survey.

This is ELEXON’s response to Ofgem’s informal consultation on the Electricity System Operator (ESO) licence drafting as part of the ESO future arrangements and regulatory framework.

This is ELEXON’s response to Ofgem’s ‘minded to’ assignments, in particular to clarify our respective obligations where there are dual assignments to both ELEXON and National Grid.

This is ELEXON’s response to Ofgem’s consultation: ‘Electricity System Operator Regulatory and Incentive Framework from April 2018’.

This is ELEXON’s response to the ENA on a Joint Electricity Network Innovation Strategy for the six electricity Distribution Network Operators, three electricity Transmission Operators and the electricity System Operator.

This is ELEXON’s response to BEIS’s call for evidence on the Cost of Energy Review (Helm Report).

This is ELEXON’s response to the NIC’s consultation: ‘Congestion, Capacity and Carbon: Priorities for National Infrastructure’.

This is ELEXON’s response to National Grid’s survey on establishing a System Operator IS User Group.

This is ELEXON’s response to Scottish & Southern Electricity Networks’ consultation: ‘Supporting a Smarter Electricity System: Our Transition to DSO’.

This is ELEXON’s response to Ofgem’s ‘Future supply market arrangements – call for evidence’.

This is ELEXON’s response to the European Network of Transmission System Operators for Electricity (ENTSO-E) on its first public consultation for European Project MARI (Manually Activated Reserves Initiative).

This is ELEXON’s response to the European Commission’s consultation on its annual priority list for network codes.

This is ELEXON’s response to the Department for Business, Energy & Industrial Strategy (BEIS) consultation on assigning certain tasks, set out in the European Electricity Balancing Guideline, to ELEXON.

This is ELEXON’s response to the Agency for Cooperation of Energy Regulators (ACER) on its consultation: ‘The revision of electronic formats for reporting under the Regulation on Wholesale Energy Markets Integrity and Transparency (REMIT)’.

This is ELEXON’s response to Ofgem’s consultation ‘Clarifying the regulatory framework for electricity storage: licensing’.

This is ELEXON’s response to Ofgem’s consultation ‘Delivering Faster and More Reliable Switching: proposed new switching arrangements’.

This is ELEXON’s response to National Grid’s viewpoint on the regulatory and incentives framework for the Electricity System Operator (ESO).

This is ELEXON’s response to National Grid’s consultation ‘The future of the Electricity System Operator: Viewpoint on the regulatory and incentives framework’.

This is ELEXON’s response to the Energy Networks Association’s consultation ‘Commercial Principles for Contracted Flexibility: Promoting Access to Markets for Distributed Energy Resources’.

This is ELEXON’s response to Ofgem’s consultation on UK Link and the proposed Central Switching Service.

This is ELEXON’s response to Ofgem’s ‘Future Arrangements for the Electricity System Operator: Working Paper on the Future Regulatory Framework’.

ELEXON’s response gives some specific examples of where ENTSO-E could help us and industry through increased engagement with stakeholders.

Responses to the consultation had to be in a set format loaded into a web interface on the ENTSO-E website.
This document was used to develop the ELEXON response in the format required and represents the submission made. We did not answer all the consultation questions. Only the questions to which ELEXON made a response are listed within the response document.

This is ELEXON’s response to National Grid’s consultation on how best to evolve/simplify the balancing services markets.

This is ELEXON’s response to the survey from the European Network of Transmission System Operators for Electricity (ENTSO-E) on standard (harmonised) balancing products under the European Energy Balancing Guideline.

This is ELEXON’s response to Ofgem’s consultation on undertaking a Targeted Charging Review, potentially through a Significant Code Review.

This is ELEXON’s response to BEIS’s Green Paper on building its industrial strategy.

This is ELEXON’s response to Ofgem’s consultation on its CMP264 and CMP265 ‘minded to’ decision and draft Impact Assessment.

This is ELEXON’s response to the second consultation on DCP268. This CP seeks to facilitate a transition to Half Hourly (HH) Settlement for Non Half Hourly customers by moving to a time band charging basis, based on the HH (profiled) data used in Settlement.

This is ELEXON’s response to Ofgem’s consultation on future arrangements for the electricity system operator: its role and structure and the regulatory and incentives framework.

This is ELEXON’s response to the following two consultations:

Ofgem’s consultation on its draft Forward Work Programme for 2017/18

Ofgem’s consultation on its Simplification Plan for 2017/18

Both consultations closed on 15 February 2017.

This is ELEXON’s response to the National Infrastructure Commission’s Report on the Impact of Technological Change on Future Infrastructure Supply and Demand.

These are ELEXON and the BSC Panel‘s responses to Ofgem’s first consultation on implementing the Competition and Markets Authority’s (CMA) recommendations for industry code governance. This consultation seeks views on what the scope of the new regulatory framework should be and how we should transition to it. It also sets out initial proposals for our strategic direction for codes, the consultative board and the licensing of code managers.

This is ELEXON’s response to DCP282. The CP intends to facilitate management/trading of Unmetered Supplies (UMS) apparatus connected to EDNO networks via the ‘host’ Distributor’s UMS Operator (UMSO) service on one combined inventory, where requested by the customer.

This is ELEXON’s response to the joint BEIS/Ofgem call for evidence on a smart, flexible energy system. BEIS/Ofgem have considered a range of options including:

• removing barriers to energy storage and Demand Side Response
• improving price signals to allow more flexibility
• catalysing innovation, so that new solutions can emerge and compete in the market
• assessing changes to roles and responsibilities in the energy system

This is ELEXON’s response to Ofgem’s consultation on its plan for moving to mandatory Half Hourly Settlement. The consultation seeks views on the aim of the reforms, timing considerations, the regulatory interventions to consider before implementing Half Hourly Settlement, and who should design and approve such interventions.

This is ELEXON’s response to Ofgem’s consultation on the code administrators’ performance survey questionnaire. The survey will be undertaken by an independent third party. The consultation seeks views on the scope and content of the survey.

This is ELEXON’s response to the Competition and Markets Authority (CMA) on its draft Order to deliver its ECOES/DES remedy. The remedy forms part of the CMA’s Energy Market Investigation conclusions.

This is ELEXON’s response to the Competition and Markets Authority (CMA) on its draft Order to deliver its locational transmission losses remedy. The remedy forms part of the CMA’s Energy Market Investigation conclusions.

This is ELEXON’s response to the Department for Transport’s consultation, which includes questions on facilitating widespread smart charging capability for electric vehicles.

You can find a copy of ELEXON’s response to this inquiry on the Select Committee’s website (http://www.parliament.uk/business/committees/committees-a-z/commons-select/energy-and-climate-change-committee/inquiries/parliament-2015/eu-energy-16-17/publications/).

This is ELEXON’s response to CMP264 ‘Embedded Generation Triad Avoidance Standstill’ and CMP265 ‘Gross charging of TNUoS for HH demand where Embedded Generation is in the Capacity Market’. These proposals interact with BSC Modifications P348 ‘Provision of gross BM Unit data for TNUoS charging’ and P349 ‘Facilitating Embedded Generation Triad Avoidance Standstill’.

ELEXON’s response to the Energy Networks Association (ENA) consultation on the possible extension of the Radio Teleswitch Broadcast system from 1 January 2018.

This is ELEXON’s response to DCUSA Change Proposal DCP268. The intent of this proposal is to facilitate a transition to Half Hourly (HH) Settlement for Non Half Hourly (NHH) customers by moving to a time band charging basis, based on the HH (profiled) data used in Settlement.

This is ELEXON’s response to the Grid Code’s consultation on GC0048. This proposal seeks to modify the Grid Code and Distribution Code by setting generator ‘banding thresholds’ as required in the European Network Code ‘Requirements for Generators’.

This is ELEXON’s response to Ofgem’s statutory consultation on the proposed licence amendments required to implement an extended Significant Code Review (SCR) process. These proposals have arisen from Ofgem’s third review of industry code governance.

ELEXON’s observations on the proposed European Intraday Cross Zonal Gate Closure Time of one hour.  This Gate Closure Time sets the end of Intraday trading, and,  as a consequence of the current drafting of the Guideline on Electricity Balancing, also the earliest start time for balancing markets .

On 26 April 2016, ELEXON met with the CMA to discuss our response to the CMA’s proposed remedy on zonal transmission losses. During the meeting, we clarified the respective roles of ELEXON and National Grid under the BSC. The CMA asked us to follow this up by providing further information on ELEXON’s governance.

This is ELEXON’s response to Ofgem’s consultation on code administration reporting metrics and performance surveys in which Ofgem proposes revised metrics and a centrally commissioned survey to monitor code administrator performance. These proposals have arisen from Ofgem’s third review of industry code governance.

This is ELEXON’s response to Ofgem’s consultation on the proposed licence amendments required to implement an extended Significant Code Review (SCR) process. These proposals have arisen from Ofgem’s third review of industry code governance.

On 10 March 2016, the Competition and Markets Authority (CMA) published a summary of its Provisional Decision on Remedies arising from the energy market investigation. The full report was published on 17 March 2016, inviting comments. We have considered the CMA’s proposals and set out our views in relation to those areas that particularly impact ELEXON and the BSC.

Project TERRE (Trans European Replacement Reserves Exchange) is an advance implementation project that forms part of the implementation of the European Network Code on Electricity Balancing.  These are ELEXON’s comments on the TERRE high level design.

ELEXON’s observations on the use of Energy Contract Volume Notifications (ECVN) as proof of GB consumption of overseas electricity, which had been suggested as possible evidence by Ofgem.

Ofgem has proposed a move to principle-based regulation. While this consultation is focused on supply licences, Ofgem intends to consider the applicability of the proposed approach to other parts of the market at a later time and has welcomed early views from stakeholders on this potentially wider scope.

We have only responded to questions that have a direct bearing on the BSC arrangements, mainly, the BSAD Methodology Statement and SMAF Methodology Statement. This response reflects the views of ELEXON Ltd only, it does not represent the views of the BSC Panel, any of its sub-committees or BSC Parties.

Our response highlights the need for ever closer and more frequent engagement by ENTSO-E and the Transmisson System Operators (TSOs) with stakeholders as the European Network Codes enter the implementation phase.

This response includes ELEXON’s comments on strengthening enforcement in gas and electricity markets from the perspective of an experienced industry code administrator.

ELEXON believes Half Hourly Settlement is needed to unlock the potential benefits of smart meters, demand side flexibility and new technology. Our response below explains these benefits in detail.

ELEXON response to ENTSO-E’s Cost Benefit Analysis (CBA) for a shorter Imbalance Settlement Period (ISP) duration.

In November 2015 the National Infrastructure Commission issued a consultation on how changes to existing market frameworks, increased interconnection and new technologies in demand-side management (DSM) and energy storage can better balance supply and demand.

This is ELEXON’s view on new market arrangements needed to unlock the benefits of new technology and innovation.

On 7 July 2015, the Competition and Markets Authority (CMA) published its provisional findings and notice of possible remedies for the energy market investigation. The CMA held a round table session on 15 December 2015 to discuss the assessment of remedy 1, specifically a new cost-benefit analysis for the introduction of pricing for losses.

At this meeting, the CMA invited ELEXON to provide insight into the cost and timescale implications of differing solutions based on previous BSC Modifications which have contemplated losses.

On 7 July 2015, the Competition and Markets Authority (CMA) published its Provisional Findings and Notice of possible remedies for the energy market investigation. The CMA subsequently invited feedback on the methodology and scenarios that would be used in assessing remedy 1, specifically a new cost-benefit analysis for the introduction of pricing for losses.

Ofgem issued an open letter concerning a further review of code governance in May 2015. Ofgem subsequently set out its initial proposals in October 2015. Ofgem’s proposals are aimed at ensuring the code governance arrangements are fit-for-purpose for a changing industry in light of the increasing pace, volume and complexity of change planned in the coming years.

ELEXON’s response to Ofgem’s consultation on its proposals to extend competition in transmission by introducing onshore tenders.

On 7 July 2015, the Competition and Markets Authority (CMA) published its Provisional Findings and Notice of possible remedies for the energy market investigation. The CMA subsequently requested that ELEXON provide additional information in relation to Time of Use Tariffs and Non Half Hourly Profiling.

On 7 July 2015, the Competition and Markets Authority (CMA) published its Provisional Findings and Notice of possible remedies for the energy market investigation. The CMA subsequently requested that ELEXON provide additional information in relation to industry code governance.

On 7 July 2015, the Competition and Markets Authority (CMA) published its Provisional Findings and Notice of possible remedies for the energy market investigation. The CMA subsequently requested that ELEXON provide additional information in relation to the costs associated with Half Hourly settlement for Metering Systems in Profile Classes 1-4.

ELEXON’s response to ACER’s invitation to comment on its 2017 Work Programme.

The response focuses on metering, including our views on registration for balancing and settlement purposes.

On 7 July 2015, the Competition and Markets Authority (CMA) published its Provisional Findings and Notice of possible remedies for the energy market investigation. To assess the merits of remedy one, the CMA intends to carry out a new cost-benefit analysis for the introduction of losses-pricing and invited views on its proposed approach.

ELEXON’s response to ENTSO-E’s consultation highlighting the importance of stakeholder engagement.

Ofgem is looking to repeal the licence condition whereby Suppliers are required to arrange for two-yearly inspections of Non Half Hourly Meters.

Launched in July 2015, Cutting Red Tape is a cross-Whitehall programme led by a small central team across Cabinet Office and the Department for Business, Innovation and Skills. This programme includes several sector-based reviews such as Energy where it looks at barriers to growth and productivity . The review will scrutinise existing regulations (and the way they are enforced and implemented) and seek to remove unnecessary burdens on business while maintaining necessary protections.

The Competition and Markets Authority (CMA) started its investigation into the energy market in Great Britain in summer 2014. This is ELEXON’s response to the CMA’s provisional findings report and notice of possible remedies which were published on 7 July 2015.

Ofgem reviewed industry code governance in 2010 and  2013. However, with the anticipated scale of change required in the coming years, Ofgem has concerns that the arrangements may not be operating in the best interests of consumers. Ofgem believes it is timely to review the reforms it previously implemented and potentially introduce further reforms.

Letter from Michael Gibbons, ELEXON Chairman regarding effective stakeholder engagement in implementation of the Network Code on Electricity Balancing.

ELEXON’s response to the ACER consultation on a REMIT Common Schema.

ELEXON’s response to the above Ofgem consultation.

ELEXON’s response relating to the Network Code on Emergency and Restoration.

ELEXON’s response to Ofgem’s ‘Target Operating Model and Delivery Approach’ document, an output from its ‘Moving to reliable next-day switching’ programme.

ENTSO-E consultation on the methodology for Cost Benefit Analysis including a scoping paper on Imbalance Settlement Period harmonisation.

ELEXON’s response to the Competition and Markets Authority (CMA) paper on gas and electricity settlement and metering, as part of the CMA’s energy market investigation.

ELEXON’s response to the Competition and Markets Authority (CMA) Updated Issues Statement as part of the CMA’s energy market investigation.

BSC Panel Chairman’s response to the DECC/Ofgem proposal.

ELEXON’s response to Ofgem’s statutory consultation.

ELEXON’s response to the ACER/ENTSO-E consultation.

ELEXON’s response to the Electralink DTSA Consultation 2014.

ELEXON’s response to the ACER call for comments.

ELEXON’s response to the ENTSO-E consultation.

ELEXON’s response to the above ENTSO-E consultation. The response is submitted in an excel format as required by ENTSO-E.  If you have any questions, please email Steve Wilkin.

This is ELEXON’s response to Ofgem’s consultation on a potential licence modification to enable the future expansion of the role of ELEXON Limited.

Although not formally being consulted upon, the latest draft of the European Electricity Balancing Network Code was published by ENTSO-E on 16 September 2014.  ELEXON has sent a letter to Ofgem regarding this latest draft which is published here.

ELEXON’s response to the ACER  REMIT RRM consultation.

ELEXON’s comments on CMA Statement of Issues

ELEXON’s response to the Ofgem consultation “Moving to reliable next-day switching”

ELEXON’s response to the above DCUSA consultation.

ELEXON’s response to the related DCUSA changes for BSC Modification Proposal P300.

ELEXON’s response to consultation on a proposal to make a Market Investigation Reference in respect of the supply and acquisition of energy in Great Britain

ELEXON’s response to DECC’s consultation on CFD counterparty and electricity settlements company operational costs 2014/15

ELEXON’s response to the above ACER consultation

ELEXON’s response to Labour’s Energy Green Paper.

ELEXON’s response to DECC’s EMR-related consultation on the offtaker of last resort.

ELEXON’s response to Ofgem’s consultation on extending the existing smart meter framework for data access and privacy to Smart-Type Meters and Advanced Meters.

ELEXON’s response to National Grid’s annual consultation on its licence condition C16 statements.

ELEXON’s response to the DECC NEED consultation.

ELEXON’s response to the Government’s ‘Electricity Market Reform: Consultation on Proposals for Implementation’

ELEXON’s response to the related CUSC changes for Approved BSC Modification P276.

ELEXON’s response to the Ofgem Electricity Balancing Significant Code Review on the draft policy decisions.

ELEXON’s response to the Ofgem consultation on tackling electricity theft.

ELEXON’s response to the ENTSO-E consultation.

ELEXON’s response to the National Grid consultation.

ELEXON’s responses to the Ofgem consultation.

ELEXON’s response to the consequential Grid Code changes for Approved BSC Modification P276.

ELEXON’s responses to the two ACER consultations.

ELEXON’s response to the Ofgem consultation letter.

ELEXON’s response to the Ofgem open letter.

ELEXON’s Response to the Electricity Market Reform Call for Evidence.

Consultation on expanding the electricity-related activities that Electralink is able to complete.

This consultation sets out the Government’s conclusions following responses to the consultation in April 2012 on the proposed rights and obligations to be contained in the Smart Energy Code (SEC). It also sets out and seeks views on the draft legal text that will constitute the first stage of the SEC. There are additional specific questions to which readers are invited to respond relating to the initial establishment of the SEC and its governance in the transitional period.

This consultation letter seeks views on two issues relating to obligation setting under ECO:

1. the methodology to be used by a supplier to determine the number of domestic customers it supplies electricity and/or gas to; and
2. the methodologies to be used by a supplier to calculate the amount of electricity and gas supplied to domestic customers.

ELEXON’s response to the above European Commission consultation.  The consultation covers transaction reporting under the European Regulation REMIT, which will, in due course, include the reporting of Balancing Mechanism Bid-Offer Acceptances.

ELEXON’s response to the Ofgem consultation.  We made observations on where changes to the BSC would be required if certain parameter values were changed; and on potential interactions between the SCR and the developments foreseen for European Network Codes, particularly the Electricity Balancing Network Code.

ELEXON has provided a response to the DECC consultation on SMETS2. Our answers centre on the management of metering requirements and delivering a centralised industry assurance regime, and the lessons we have learned in doing so.

ELEXON’s response to National Grid’s open letter consultation on Bilateral Embedded Licence Exemptible Large Power Station Agreement (BELLA) participation in the Balancing Mechanism.

ELEXON’s response to the Ofgem consultation on whether the losses incentive mechanism for 2010-15 (DPCR5) should be activated.

ELEXON’s response to the ACER consultation.

ELEXON’s response to the DECC consultation.

ELEXON’s response to the ACER consultation.

ELEXON’s response to the DECC consultation.

ELEXON responses to four DECC Smart Implementation Programme consultations.

ELEXON’s response to the Ofgem letter.

ELEXON’s response to the Ofgem consultation.

ELEXON’s response to the Ofgem open letter.

We submitted a comment on the usage and publication of the proposed European REMIT market participant register.

We submitted some observations in response to the above Ofgem consultation.

The ELEXON response to the Office of Renewable Energy Deployment’s consultation on Tariffs for no-PV technologies and scheme administration issues.

Our response to the Smart Metering Implementation Programme Prospectus

The BSC Panel’s response to DECC’s call for evidence in relation to the review of Ofgem which DECC proposes to carry out in parallel with a complementary programme of work on electricity market reform.

Our response to DECC’s consultation on the Implementation of the EU Third Internal Energy Package.

Our response to Ofgem’s Smart Metering Implementation Programme consultation highlights the valuable expertise we believe we can share with the programme, particularly on the discussions around the DataCommsCo (DCC).

ELEXON’s response to Ofgem’s open letter consultation: Potential Significant Code Reviews (SCRs).

The BSC Panel’s response to Ofgem’s open letter consultation: Potential Significant Code Reviews (SCRs).

Our response to Ofgem’s consultation on changing the implementation date of the EHV distribution charging methodology and hence the EHV/HV charging boundary to 1 October 2011.

Our response to the European Regulator’s Group for Electricity and Gas (ERGEG) consultation on the draft Guideline on Fundamental Electricity Transparency. In due course the Guidelines (of which this is one) will set a binding framework for the development of European network codes.   This particular Guideline sets out the requirements to send specified data (BSC and operational in the GB context) to a central European information platform where it will be published.

Our response to the web-based consultation on the Council of European Energy Regulators’ proposed work programme for 2011.

Our response to National Grid’s consultation on potential enhancements to the Balancing Mechanism enabled by their procurement of a new Electricity Balancing System.

Our response to the Department of Energy and Climate Change’s consultation on opening private distribution networks to third party suppliers.

Our response to the National Grid consultation on potential changes to the publication of constraint information. The consultation focuses on improving the transparency of constraint-related information and includes suggestions such as aligning BMRS Zones and Grid Code OC2 Zones.

Our response to the joint Ofgem E-Serve and Department of Energy and Climate Change consultation on code changes required to support the offshore transmission ‘generator build’ option.

Our response to the Ofgem request for information relating to a potential derogation from the two yearly meter inspections licence condition.

Our response to DECC’s consultation on the Warm Home Discount scheme and in particular, providing further evidence to support DECC’s proposal to appoint ELEXON as the operator of the reconciliation mechanism.

Our response to DECC’s consultation on the Warm Front eligibility criteria to which ELEXON was invited by DECC to respond. The Government is proposing to change the definition of those households eligible for assistance under the Warm Front scheme.

Our response to the Government’s proposals for Electricity Market Reform, which include Feed In Tariffs, a Capacity Mechanism and an Emissions Performance Standard.

Our response to the Government’s consultation on introducing a carbon price floor.

Our response to the Ofgem consultation on how private distribution network operators/owners should charge third party suppliers for using their networks. We highlighted a linkage with the options for implementing third party access in imbalance settlements.

Our response to the Energy Networks Association consultation on the EHV Distribution Charging Methodology (EDCM). Our response concentrates on one aspect: the number of Line Loss Factor Classes (LLFCs) needed to support distributor billing processes and potential solutions to the current restriction on the number of LLFCs.

ELEXON’s response to the Ofgem and Ofgem E-Serve proposed corporate strategy and plan.

Our response to the Single Electricity Market (SEM) Committee in the island of Ireland on the possibility of treating all the interconnectors between the island of Ireland and Great Britain as a single interconnector in the SEM. In our response we said that we have no view on whether the East West and Moyle Interconnectors should be treated jointly or separately under the SEM. However, we said that in either case, the two Interconnectors should be treated separately for the purposes of the BSC.

Our response to the 2011 Ofgem Spring Package, which seeks to protect consumer interests as Suppliers start rolling out smart meters across Great Britain.

Our response to the European Commission’s plans for the establishment of Framework Guidelines and Europe-wide Network Codes covering the electricity and gas markets.

Our response to the Ofgem consultation.

Our response to the Ofgem consultation.

Our response to the Council of European Energy Regulators’ above consultation on demand response in a market with smart meters.

Our response to the European Regulators Group on the above consultation. We responded to just one consultation question – on the publication of data.

Our response to the changes proposed by National Grid to the Grid Code. These proposed changes relate to the provision of data from intermittent generation for participation in the Balancing Mechanism.

Our response to the National Grid consultation.

Our response to the Council of European Energy Regulators’ above consultation on retail market design.

Our response to the European Commission consultation, commenting on the need for the detailed data definitions, without which it will be difficult to assess the magnitude of the changes required and the implementation time.

On 29 July 2011 Ofgem published an open letter stating their intention to extend the vires of ELEXON. Ofgem’s letter included publication of a Report (the Morse Report) commissioned to consider the implications of widening the scope of ELEXON’s role beyond the current BSC arrangements. This document is ELEXON’s response to the Morse Report.

Our response to DECC’s Smart Metering Implementation Programme: consultation on draft licence conditions and technical specifications for the roll-out of gas and electricity smart metering equipment (August 2011).

Our response to Ofgem’s Commercial interoperability: proposals in respect of managing domestic customer switching where meters with advanced functionality are installed.

Our response to DECC’s Smart Metering Implementation Programme: consultation on draft licence conditions for a Code of Practice for the installation of gas and electricity smart meters.

Our response to DECC’s Smart Metering Implementation Programme: A call for evidence on privacy and data access (August 2011).

Our response to DECC’s consultation on the detailed policy design for the regulatory and commercial framework that should apply to the Data and Communications Company (DCC).

Our response to the Department of Energy and Climate Change consultation on capacity mechanisms (part of its Electricity Market Reform proposals).

Our response to the Ofgem consultation on regulatory measures to address the effects of Gross Volume Correction (GVC) and other Settlement data adjustments on the Distribution Losses Incentive Mechanism (DLIM).

Our response to a European study on integrating renewable generation into the various European Member State electricity markets. We made a comment on the Great Britain report.

Our response to Ofgem’s consultation on electricity cash-out issues.

Our response to the European Parliament Economic and Monetary Affairs Committee’s questionnaire on Markets in Financial Instruments Directive (MiFID).

Our response to Ofgem’s consultation on its non-domestic proposals as part of its Retail Market Review.

Our response to Ofgem’s consultation about changing our current Governance and Vires to allow us to do more beyond the BSC.

Our response to the changes proposed by National Grid to the rules used to validate BM Unit data submitted by Parties under the Balancing Codes of the Grid Code.

Our response to Ofgem’s Code Administration Code of Practice review.