IGT103: Inclusion of reference within IGT UNC to UNC TPD Section G paragraph inclusive - Meter Point Portfolio Reconciliation

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1 Final Modification Report At what stage is this document in the process? IGT103: Inclusion of reference within IGT UNC to UNC TPD Section G paragraph inclusive - Meter Point Portfolio Reconciliation Purpose of Modification: This modification seeks to ensure parity between both the IGT UNC and UNC, for the treatment of IGT Supply Meter Points, to improve the completeness of the data held within the Supply Point Register on behalf of industry parties by carrying out a MPRN portfolio reconciliation between Shipper records and CDSP systems. Panel consideration is due on 18 th April 2018 The Panel determined that this self-governance modification be implemented. High Impact: Medium Impact: Shippers Low Impact: IGT103 Page 1 of 12 Version 1.0

2 Contents 1 Summary 3 2 Governance 3 3 Why Change? 4 4 Code Specific Matters 4 5 Solution 4 6 Impacts & Other Considerations 5 7 Relevant Objectives 8 8 Implementation 9 9 Legal Text 9 10 Consultation Panel Discussions Recommendations 12 Contact: Any questions? Code Administrator igtunc@gemse rv.com Proposer: Rob Johnson Rob.Johnson@espu g.com Other: Paul Orsler Timeline The Proposer recommends the following timetable: Initial consideration by Panel 06 March 2018 paul.orsler@xoserve. com Amended Modification considered by Workgroup N/A Workgroup Report presented to Panel 21 March 2018 Draft Modification Report issued for consultation 21 March 2018 Consultation Close-out for representations 13 April 2018 Variation Request presented to Panel N/A Final Modification Report available for Panel 16 April 2018 Modification Panel decision 18 April 2018 IGT103 Page 2 of 12 Version 1.0

3 1 Summary What UNC 0431 introduced provisions for the CDSP to carry out a meter point reconciliation process on behalf of industry parties under Section G of the UNC. It is the proposer s belief that this reconciliation process should be incorporated by reference in the IGT UNC to support cross-code parity of business rules. Why Following implementation of igt039 and associated Project Nexus UNC Modifications, the IGT UNC now references UNC where parity of business rules are in place for IGT Supply Meter Points. This enables consistent processes to manage and maintain data, regardless of the Distribution Network or IGT network each Supply Meter Point resides within. On assessment of the Post Nexus UNC legal text, it has been identified that a particular section within UNC is not referenced within the IGT UNC. This has the potential to create a lack of consistent treatment of IGT Supply Meter Points held on CDSP systems. Where any IGT Supply Meter Points are being billed by Suppliers but not registered to a Shipper on the CDSP systems, there is at present no requirement for Shippers or the CDSP to conduct an exercise to monitor such sites, despite their being a specific responsibility to perform such an activity for sites held on the Distribution Networks. This disparity has the potential to create unidentified gas and not delivering the correct allocation of costs despite supply arrangements being in place. Implementation of the change should be completed by Mid-2018 so that all parties are prepared ahead of the 2018 exercise scheduled for November How Align IGT UNC and UNC, creating a reference to the meter point reconciliation exercise defined in UNC TPD Section G paragraph This will enable Shippers to obtain from Supply businesses a dataset comprising of all sites that are actively being supplied. The CDSP will match the dataset against the MPRN data they hold, and identify MPRNs: for which a supply arrangement is in place but the MPRN is not registered to a Shipper; that do not appear on the Supply Point Register; are dead or extinct; or appear on one or more Supply Point Portfolios. If Shippers fail to register these MPRNs through the standard process, they will be automatically registered as set out in the agreed Business Rules. 2 Governance Justification for Self-Governance Procedures It is the Proposer s view that the modification meets Self-Governance criteria. The principal of an annual Supply Portfolio exercise has already been agreed by the Authority in its decision letter dated 20 February 2014 on UNC Modification IGT Supply Meter Points were excluded by the original modification as Xoserve did not directly administer these at that time. However, with the introduction of Single Service Provision via Nexus this is no longer the case. Overall, it is believed that the Modification will reduce the potential for discrimination between different classes of parties to the IGT uniform network IGT103 Page 3 of 12 Version 1.0

4 code / relevant gas transporters or gas shippers which currently exists via the exclusion of IGT Supply Meter Points from the Portfolio exercise. No change is required to the UNC as the legal text in Section G2.12 through G2.14 uses the term Supply Meter Point Reference Numbers which include meter points on both Large Transporter and IGT networks. Requested Next Steps This modification should: be subject to self-governance Refer this proposal to a Workgroup for assessment Workgroup Comments The Workgroup agreed that this modification qualified for Self-Governance status. 3 Why Change? Following implementation of igt039 and associated Project Nexus UNC Modifications, the IGT UNC now references UNC where parity of business rules are in place for IGT Supply Meter Points. This enables consistent processes to manage and maintain data, regardless of the Distribution Network or IGT network each Supply Meter Point resides within. On assessment of the Post Nexus UNC legal text, it has been identified that a particular section within UNC is not referenced within the IGT UNC. This has the potential to create a lack of consistent treatment of IGT Supply Meter Points held on CDSP systems. Where any IGT Supply Meter Points are being billed by Suppliers but not registered to a Shipper on the CDSP systems, there is at present no requirement for Shippers or the CDSP to conduct an exercise to monitor such sites, despite their being a specific responsibility to perform such an activity for sites held on the Distribution Networks. The accuracy of centrally held data impacts the reliability of settlement and cost allocations. A number of initiatives have been launched to improve data accuracy, and there has been particular focus on the number of live meter points that have not been registered by a Shipper shipperless and unregistered sites. It is possible that some shipperless and unregistered sites are being billed by Suppliers. Due to the current disparity of Industry Codes, the CDSP has no access to this Supplier information on an IGT network. Reconciling CDSP held data and Supplier held data could validate and improve industry data. 4 Code Specific Matters Technical Skillsets An understanding of the Code and alignment to the UNC will be required in the assessment of this Modification. Reference Documents. IGT103 Page 4 of 12 Version 1.0

5 5 Solution This modification seeks to amend the IGT UNC, to reference UNC TPD Section G, paragraphs , a section which provisions the solution implemented as part of UNC 0431 to perform a meter point reconciliation exercise. The amendment to IGT UNC will ensure IGT Supply Meter Points are included within the meter point reconciliation exercise, preventing any disparity between those sites directly or indirectly connected to the Distribution Networks. For the benefit of all parties, the detail of the meter point reconciliation exercise which has been implemented by UNC signatories is described below; It is proposed to introduce an obligation on Shippers to endeavour to provide MPRN information from supply business systems to allow the CDSP to carry out reconciliation (on behalf of all large and independent Gas Transporters) against the information that it holds. For clarity, it is proposed that the CDSP will only identify actively supplied sites provided by Shippers that are not present or registered to a Shipper on CDSP systems i.e. unregistered or shipperless or are dead/extinct or appearing on one or more supply portfolios. They will not be required to also identify sites registered to a Shipper but not present in the data provided (this is an exercise which Suppliers/Shippers can carry out themselves without access to central systems). It is proposed that Shippers be obliged to provide, for each Supply business that they ship for, each MPRN and the associated Meter Serial Number, Full Postcode and the Shipper and Supplier short codes. The CDSP will complete a reconciliation exercise and reports will be provided to Shippers detailing the MPRNs that they have provided under the terms of this modification but which are not registered against that Shipper. The Shipper concerned shall be expected to register each MPRN on the provided report within 40 business days from the report issue date or, if the Shipper does not consider this action to be appropriate, provide a reason for non-registration to the CDSP within 40 business days from the report issue date. If Shippers request additional time, it is proposed that the CDSP be able to grant up to an additional 50 business days. If the Shipper does not either register the MPRN or provide a reason for non-registration within the allowed timescale, the CDSP will register the MPRN on behalf of the Shipper. Detailed business rules: 1. Shippers will be obligated to take a data extract from a Non Business Day, for the avoidance of doubt this report will only be taken once in any gas year and take place in November. The request for a report will be given a minimum 60 business days notice as and when the IGTs deem a reconciliation exercise is necessary. Reports will be scheduled from all Shippers at the same time and will require the extract date to be the date given by the CDSP. 2. The data extract will be sourced from Suppliers customer database supply portfolio of the associated Supplier for each Shipper. The data extract will include all MPRNs which are actively being supplied in the database where an end user supply contract is in place. Shippers will use all reasonable endeavours to provide the data extract to the CDSP within 15 business days of the agreed extract date and will specify a reason should this not be possible. The data extract which is provided to the CDSP will detail the following: MPRN Meter serial number Post Code Shipper & Supplier Short Codes IGT103 Page 5 of 12 Version 1.0

6 The data extract which is provided will be extracted from the Suppliers customer database of sites that are actively being supplied. If sites have been aggregated then the data will show the relevant MPRNs with the relevant meter serial numbers. 3. Shippers shall use reasonable endeavours to secure the supply portfolio of a Supplier with which it has a shipping arrangement. Where a Shipper is not the same legal entity as the supplier or within the same group of companies and is unable to secure the supply portfolio the Shipper shall report the fact, together with the reason why the Supplier is unable to fulfil the request. This response to the CDSP shall be given within 15 business days of the agreed extract date. 4. In the event that the Shipper has been unsuccessful in securing the supply portfolio of a Supplier to whom it is contractually associated with then the Shipper will provide the Supplier s contact details to enable the CDSP to make a direct request to the Supplier for this information. 5. The CDSP will complete a portfolio comparison exercise using the business rule 2 data provided by the Shipper and the MPRN data held on the Supply Point Register. 6. Where the CDSP identifies an MPRN detailed on the Shipper s report which is unregistered, Shipperless, has a status of dead or extinct on the Supply Point Register database or is not present at all on the Supply Point Register database or where present on more than one Supply Portfolio the identity of each supplier, then they will provide a report to each relevant Shipper specifying these MPRN s. If an MPRN is identified on the Shippers report which does not appear on the supply point register or is dead / extinct then they will be expected to follow the current procedures for creating & registering a new MPRN. 6.1 Where the IGT Supply Point is not present within the Supply Point Register, the Shipper must follow the existing process of requesting the creation of a Found MPRN with the relevant IGT - using the IGT MPRN range to identify the relevant IGT if necessary. 6.2 The IGT in turn will validate this request and will, where accepted, request the creation of the MPRN within the Supply Point Register. 6.3 Once recorded within the Supply Point Register, the Shipper will be expected to follow the current process for registering a new MPRN. 7. The CDSP will provide the Business Rule 6 report to each Shipper as soon as is reasonably practicable. 8. The relevant Shipper will commence the creation / registration of any MPRNs on the Business Rule 6 report within 40 business days from receipt of the business rule 6 report, creation / registration will be prospective. Alternatively where the Shipper considers it would not be appropriate to create / register an MPRN, it will provide a reason to the CDSP for not completing this exercise. 9. If the Shipper is unable to commence the creation / registration of the MPRN within the provision of Business Rule 8 due to further investigations being required then they will provide a reason for requiring additional time to the CDSP who will then grant up to an extra 50 business days (40+50 = 90 business days in total) to commence the creation / registration of the MPRN. If within the original 40 day period or within the additional 50 day period, the Shipper fails to provide a reason for not having commenced the creation / registration of the MPRN and the Supply Point remains absent / un-registered on the Supply Point Register, the CDSP in conjunction with the relevant IGT, shall arrange for the creation / registration of the MPRN on a Shipper s behalf. IGT103 Page 6 of 12 Version 1.0

7 10. This rule will apply if there is a need to create and / or register the MPRN. Where a new MPRN needs to be created, the CDSP will cooperate with the relevant IGT to enable this activity to take place (i.e. creation of new IGT MPRN within the Supply Point Register). Should any additional information be required to register the MPRN by the CDSP then an additional request for data items will be submitted to the relevant Shipper. The Shipper will provide any additional information within 15 business days from the CDSP. 11. If the information requested under BR10 is not provided within the set timescales then the CDSP will have the right to assume default values in order to complete the registration. 12. Once the portfolio reconciliation exercise has been completed by the CDSP an anonymised report will be generated indicating the following by Shipper organisation: The number of MPRNs provided by the Shipper to the CDSP which on the extract date were: (i). unregistered. (ii). shipperless. (iii). Not present at all on Site and Meters. (iv). An MPRN appearing on two or more Supplier portfolios. (v). At a Status of either dead or extinct. The Shipper organisation names will be anonymised on this report. A non-anonymised report will be provided to Ofgem. Time Line of Events Business 60 Extract Days Date Process Notification Extract Report Provision / Non Delivery User Data Reconciliation and Provision of Report Shipper Registration / Reason for non- Registration CDSP Grants Additional Time Provision of Additional Data Items User Pays Classification of the modification as User Pays or not and justification for classification This is not a User Pays Modification as it neither introduces nor amends a User Pays Service. Identification of Users, proposed split of the recovery between igts and Users for User Pays costs and justification n/a Proposed charge(s) for application of Users Pays charges to Shippers n/a Proposed charge for inclusion in ACS to be completed upon receipt of cost estimate from Xoserve n/a IGT103 Page 7 of 12 Version 1.0

8 Workgroup Comments The Workgroup discussed changes to the solution of UNC0641S which has changed the number of business days advanced warning of the exercise. This has been changed from 90 days to 60 days and this has been reflected in the IGT Modification proposal and Workgroup report. The Workgroup agreed with the Proposers decision to change this detail via an amended Modification. 6 Impacts & Other Considerations Does this modification impact a Significant Code Review (SCR) or other significant industry change projects, if so, how? No this modification improves consistency between industry Codes. Consumer Impacts identified. Environmental Impacts identified. Workgroup Impact Assessment The Workgroup discussed possible system impacts which may be resultant of this modification. The Workgroup generally agreed that there would be little impact for IGTs. For Shippers the parties present confirmed that they would have to make minor system changes but could not confirm that this would be the case for all Shippers, dependant on their portfolio size and whether or not they previously automated this process being of a adhoc nature. The Workgroup resolved that the latest date to implement any required system changes would be prior to having to deliver the report in late November 2018 rather than the date at which the modification is formally implemented into the Code. 7 Relevant Objectives Impact of the modification on the Relevant Objectives: Relevant Objective (A) Efficient and economic operation of the pipe-line system (B) Co-ordinated, efficient and economic operation of Identified impact (i) the combined pipe-line system; and/or (ii) the pipe-line system of one or more other relevant gas transporters (C) Efficient discharge of the licensee s obligations (D) Securing of effective competition: Positive (i) between relevant shippers; (ii) between relevant suppliers; and/or IGT103 Page 8 of 12 Version 1.0

9 (iii) between DN operators (who have entered into transportation agreements with other relevant gas transporters) and relevant shippers (E) Provision of reasonable economic incentives for relevant suppliers to secure that the domestic customer supply security standards are satisfied as respects the availability of gas to their domestic customers (F) Promotion of efficiency in the implementation and administration of the Code (G) Compliance with the Regulation and any relevant legally binding decisions of the European Commission and/or the Agency for the Cooperation of Energy Regulators Positive Implementation would be expected to increase the accuracy of data held by the CDSP and reduce the number of unregistered sites. Consequently, there may be less unidentified gas and costs would be more appropriately allocated, thereby supporting objective D by helping to secure effective competition. Implementation will create further alignment between the IGT Uniform Network Code and the larger Transporters Uniform Network Code, promoting efficiency in the implementation and administration of codes. This Modification will also better facilitate relevant objective F) as this modification solution promotes efficiency in the implementation and administration of the Code through better cross-code alignment. Workgroup Comments The Workgroup discussed the positive impact suggested by the proposers on Relevant Objective D. The Proposer identified that the impact on competition is due to the individual unregistered supply points which are not in the market. The Workgroup also agreed with the proposer that this improved the quality of data and Objective F in cross-code alignment. 8 Implementation Implementation of the change should be completed by Mid-2018 so that all parties are prepared ahead of the 2018 exercise scheduled for November Workgroup Comments The Workgroup discussed suggested implementation dates for this modification and discussed the notice period needed for industry to take a snapshot of their portfolio, which Xoserve indicated has to be as close to the exercise as possible. The Workgroup acknowledged that there would be some system changes, however, noted that these would likely not be significant changes. The Chair highlighted that as per the Code, system changes are required to give six months notice for industry after implementation, and the Workgroup recognised that the current timeline would not fit in with this. The Workgroup resolved that the latest implementation date for this Modification is May 2018 and recommend to the Panel that they consider an extraordinary release which would allow parties five months notice period. The Workgroup supported the need for the Modification and for an exercise to be carried out this year. IGT103 Page 9 of 12 Version 1.0

10 The Workgroup suggested that the Panel should accept a shortened Consultation period so this can be brought back to the April Panel for decision, with the 15-day appeal window expiring in early May Legal Text Suggested Text Part CI 20.6 For the purposes of Clause 20.3, the Last Resort User shall execute all such documents, deeds and assignments and perform such acts as the Pipeline Operator may reasonably require, including without limitation, executing any relevant documents, deeds and assignments or perform such acts necessary to ensure compliance with the provisions of the Data Protection Act Supply Portfolios 21.1 For the purposes of this Clause 21 the provisions of Section G2.12 through G2.14 of the UNC shall apply with the following changes: Any reference to a Supply Meter Point Reference Number will be interpreted as a Supply Meter Point Reference Number in respect of an IGTS Supply Meter Point as defined in the IGTAD A2.1.1(g). Paragraph G of the UNC shall be replaced by the following paragraph: Unless otherwise agreed by the CDSP and User under paragraphs or where the User fails to create a Supply Meter Point Reference Number within the Registration Period the CDSP shall issue a request to the relevant Pipeline Operator to create a Supply Meter Point Reference Number to allow Supply Point Confirmation under Workgroup Comments The Workgroup reviewed the proposed legal text and agree that this supports the intended solution. The Workgroup discussed the additional title of Supply Portfolio and resolved that this was a defined term in the UNC, therefore, to align this it was brought over to the IGT suggested text. 10 Consultation Panel invited representations from interested parties until 13 th April The summaries in the following table are provided for reference on a reasonable endeavours basis only. We recommend that all representations are read in full when considering this Report. Representations are published alongside this Final Modification Report. Representations were received from the following parties: Organisation Response Relevant Objectives Key Points BU-UK Support D - Positive F - Positive BUUK supports the implementation of IGT103 for the following reasons: IGT103 Page 10 of 12 Version 1.0

11 - Ensures cross-code parity of business rules between the IGT UNC and UNC by introducing a reference to the reconciliation process. - Allows Shippers an extended notice period of 60 business days to provide MPRN information to the CDSP to carry out a Supply Portfolio reconciliation exercise on behalf of IGTs/GTs. - Ensures IGT Supply Meter Points held on the CDSP system receive the same treatment as the GT Supply Meter Points during the exercise. - Enables Shippers to obtain a dataset of all sites, inclusive of IGT networks, that are actively being supplied. Therefore, identifying any IGT Supply Meter Points that are being billed by Suppliers but are not registered with Shippers. We agree IGT103 meets the criteria of a Self- Governance modification. BUUK believe objective d) and f) have been sufficiently met and that this modification not only promotes the efficiency and administration of the IGT UNC but has a positive impact on competition as brings any identified unregistered supply points into the market. We anticipate potential system impacts to Shippers dependant on portfolio size. There are little impacts identified for IGTs. We do not anticipate any development costs but note costs could be incurred during the reconciliation exercise should the report produced by the CDSP differ from that of the GTs. We believe there is a potential for an increase of operational queries. We would support the implementation of the modification within either the June release or a special release should this not be feasible, this will ensure it is in place before November. IGT103 Page 11 of 12 Version 1.0

12 Code Administrator Observation The Code Administrator has observed that if the Modification (IGT103) is implemented it will fully align the IGT UNC with the UNC with respect to the Annual Meter Point Reconciliation exercise carried out by the CDSP. Currently this exercise has a notice period of 20 days for Shippers to produce their data extract. Only if UNC 0641S is implemented will this notice period change to 60 days which is the period referenced in the IGT 103 Solution. However, it is the CA's view that the principal purpose of this modification is alignment with the UNC re Meter Point Portfolio Reconciliation not the change to the notice period for the exercise. 11 Panel Discussions Discussion The Panel did not voice any opposing views to this Modification and were happy with the solution presented in this Modification, and fully supported the changes to the legal text. The Panel discussed the Code Administrators observation that UNC421S has not yet been sent to Consultation, and the changes to the notice period as set out in UNC421S (20 to 60 days) has not yet been decided upon by the UNC Panel. Only if UNC 0641S is implemented will this notice period change to 60 days which is the period referenced in the IGT 103 Solution. The Panel agreed that if UNC421S is not passed for implementation the notice period will remain at 20 days, regardless of the text within this modification. Consideration of the Relevant Objectives All Panel members agreed that this Modification meets the criteria set out in Objective D and F and the published criteria for Self-Governance modifications. Determinations The vote was carried out with two Pipeline Users and three Pipeline Operators. The Panel agreed that the Modification should be implemented by a unanimous vote. The Panel agreed that, as a Self-Governance Modification, it should be implemented on the date scheduled for the June release, which will give as much notice as possible to industry for the start of the process which will be announced by Xoserve in November This will be subject to a 15-day appeal window as per the Self-Governance process. 12 Recommendations Panel Determination Self-Governance Members agreed: that Modification 103 should be implemented IGT103 Page 12 of 12 Version 1.0