Change Consultations

– before transfer

test 2

summary

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.