1 / 5

UNC Modification Proposal 0229

UNC Modification Proposal 0229. Guidelines document. Background. Ofgem RIA states that it is ‘minded to accept’ Mod 0229 NGD presented its concerns with the associated guidelines at January 2010 Distribution Workstream

mona-rollins
Download Presentation

UNC Modification Proposal 0229

An Image/Link below is provided (as is) to download presentation Download Policy: Content on the Website is provided to you AS IS for your information and personal use and may not be sold / licensed / shared on other websites without getting consent from its author. Content is provided to you AS IS for your information and personal use only. Download presentation by click this link. While downloading, if for some reason you are not able to download a presentation, the publisher may have deleted the file from their server. During download, if you can't get a presentation, the file might be deleted by the publisher.

E N D

Presentation Transcript

  1. UNC Modification Proposal 0229 Guidelines document

  2. Background • Ofgem RIA states that it is ‘minded to accept’ Mod 0229 • NGD presented its concerns with the associated guidelines at January 2010 Distribution Workstream • As agreed at Workstream, DNOs have since engaged with Proposer and discussed these • No agreement on issues forthcoming. 0229 guidelines remain unchanged.

  3. DNO concerns • DNOs accept that 0229 principles essentially sound. However our opinion is that: • Proposal as drafted (including guidelines) • Perceived as unduly complex • Could give rise to challenges and process ‘stop points’ • Possibly unlikely to result in timeline to conclusion • Unmitigated risks exist • AUGE tender controlled by UNC Committee • Not acceptable for UNC Committee to select AUGE and then for Transporters to be forced to contract with selected party. • Eventualities - Suitability of candidate/or no candidates?

  4. DNO concerns (continued) • Multiple opportunities for parties to challenge/agree output of AUGE (AUGS) – undermines purpose of independent agent • Risk that challenges driven by commercial interests - undermines ‘neutrality’ of AUGE • Once appointed need to let AUGE conclude • Risk of changes to Guidelines which could impact Transporter contractual arrangements • Guidelines appear to be unclear as to the specific output i.e. the ‘methodology’ or ‘Statement’ or ‘AUGS’? Also timing and deliverability not clear. • Complexity threatens delivery within timescales – likelihood that ‘zero volumes’ could result. • Process for AUGE/AUGS output unduly protracted – no output for up to 2 years from implementation.

  5. DNO opinion: • No issues with Mod 0229 principles (includes appointment of independent AUGE & production of AUGS) • Must be a simplified AUGE tendering and appointment process – wholly a Transporter responsibility (see suggested amendments) • Should addresses the scenario where AUGE is not appointed • Should permit challenge and review but process should conclude in an acceptable timescale • Reliance on AUGE as ‘independent’ authority ensures AUGS not influenced by commercial drivers/interests • Ofgem has requested legal text – NGD has commenced work • Funding arrangements appear not to be addressed • Assuming Ofgem directs to implement – need to identify and consider next steps?

More Related