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Mod Proposal 0281 - Prevention of "Timing Out" of Authority decisions on Modification Proposals

Mod Proposal 0281 - Prevention of "Timing Out" of Authority decisions on Modification Proposals. Nick Reeves. Background. A mod is said to have “Timed Out” if Authority decision has not been made in time to allow implementation by the proposed date

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Mod Proposal 0281 - Prevention of "Timing Out" of Authority decisions on Modification Proposals

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  1. Mod Proposal 0281 - Prevention of "Timing Out" of Authority decisions on Modification Proposals Nick Reeves

  2. Background • A mod is said to have “Timed Out” if Authority decision has not been made in time to allow implementation by the proposed date • “Timing Out” identified as an industry issue in 2007 following Balancing & Settlement Code (BSC) mods P198, P200, P203 & P204 • Following “Timed Out” BSC mods, Judicial Review deemed that Authority lost ability to decide on “Timed Out” Mods • Ofgem sought views on potential solutions to eliminate risk of “Timing Out” re-occuring & recommended either changes to licenses or industry codes (May 09) • Mod represents National Grid NTS’ view on most efficient solution

  3. Proposed Changes (1) • Change Mod Rules to include a more structured approach to including suggested implementation dates within mod templates; • A minimum of two suggested fixed implementation dates with the associated decide by dates, e.g. • Decide by 18th February for implementation on 18th March • Decide by 18th April for implementation on 18th May, and • One suggested flexible implementation date, e.g. • Two Calendar Months after an Authority Decision • Important to remember that both type of dates above are required if User chooses to include a suggested date within the proposal • Users will still be able to leave suggested date blank if not critical or practical to include

  4. Proposed Changes (2) • Users wishing to include suggested implementation dates must include accompanying justification for chosen dates • Applies to all type of proposals • All implementation dates provided within proposals will continue to be “Suggested” • Suggested implementation dates will continue to be non-binding • Transporters will continue to confirm the implementation date at the time of the Authority decision has been made

  5. Ensure greater clarity of mod implementation dates to industry Promote development of possible implementation options within Mod proposals Provide consistent structure for presentation of suggested implementation dates Promote development of justification to support suggested implementation dates Stimulate industry debate of optimal implementation timings & costs (particularly relevant to User Pays proposals) Apply industry best practise & promote consistency across industry codes Remove risk to industry of “Timing Out” Improved consideration of possible options to aid industry understanding More detailed analysis of the most cost efficient implementation date More informed representations and Authority decisions Allows realisation of mod benefits at earliest opportunity No wasted / duplicated effort in re-raising Mod proposal Better facilitation of relevant objectives associated with mod process (A11.2 9) & UNC (A11.1 (f)) Purpose & Expected Benefits Purpose Benefits

  6. Any questions / suggestions to aid clarity? • ??

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