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CSEPs Reconciliation Proposals. Presenter: Steve Nunnington. Background. IGTs responsible in NExA for passing Rec data to xoserve so that CSEP Rec charges can be calculated. Rec should occur on every I&C NDM LMN. Volumes required not meter readings.
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CSEPs Reconciliation Proposals Presenter: Steve Nunnington
Background • IGTs responsible in NExA for passing Rec data to xoserve so that CSEP Rec charges can be calculated. • Rec should occur on every I&C NDM LMN. • Volumes required not meter readings. • LMNs used within Gemini. Commodity billed against LMN • Only 6 LMNs have been reconciled in year. • Total LMN population 4096 (NDM I&C) • Leaves a pool of unreconciled energy.
Issues • IGTs state they don’t get meter reads from shippers. • Shippers claim that IGTs are not processing reads provided. • Volumes submitted by IGTs are failing validation by xoserve. • File format difficulties. Not included within Annexe A of NExA. • Industry agreement that Rec does not occur where there is a previous unreconciled period. • No commercial incentive for IGTs to submit Rec data.
Impacts • Unspecified amount of unreconciled gas within the LDZs. • RBD shippers bear this unspecific risk. • If meter reads are unavailable to IGTs then AQ calculations may not be robust. • Uncertainty, frustration and a lack of trust within the industry.
Historical Issues • Missing Rec Periods • There are a number of sites where Rec was not undertaken in the early days of competition. This may go back as far as 1996. • May be that an opening read was not obtained or the data failed validation and not resubmitted. • This means that there is a period of time in the past when the site in question is not reconciled. • Where more recent consumption is identified the Rec cannot take place as the current rules do not permit unreconciled periods to exist. • Custom and practise. Not a NExA or a UNC rule. • Ofgem sponsored group has discussed this and recommends that reconciliation with prior missing Rec periods is permitted. • However need to look at a solution that solves missing Rec periods.
Historical Issues • Estimated Readings • Unrealistic to expect shipper or IGT to provide a read which could be as much as 11 years old. • Ofgem group recommends a neutral Rec for these periods. • Should be based on an extrapolation of the prevailing AQ value. • IGTs responsibility to provide these estimates. • A methodology is set out in UNC M3.6 (Opening Read Estimate.) • IGTs should be encouraged to submit metered volumes. As such this methodology should only be used prior to 2006. • More recent periods should contain actual volumes.
Maintenance of the CSEP Rec Regime • Once the issue of missing Rec periods is addressed we need to make sure the regime is self sustaining. • Must Reads • Where a shipper fails to obtain a reading at a given site within a set period of time, the transporter picks up the responsibility within its Must Read responsibility. • These periods and frequencies are set out within Section M 3.4 & 3.5 of DNOs UNC. Must Read responsibility is to be found in M 3.6. • For IGTs this Must Read responsibility can be found in their UNC Part E section 5. • IGTs should therefore conform to their contractual obligations under the UNC. • IGTs could levy a cost reflective charge.
Maintenance of the CSEP Rec Regime • Opening Reads • Shippers have a responsibility to obtain an opening read as set out in Section M 3.8 of UNC. • Where a shipper fails to obtain an opening read. It is equally clear that the DNO has responsibility to provide an opening read estimate. • IGTs have exactly the same responsibility in their UNC within Annexe 6 Part E Clause 6.8. • For this function IGTs allowed to levy a cost reflective charge. • It is unclear whether IGTs are currently operating this regime. • File Formats • CRI file published on UK Link web site. • IGTs not users of UK Link. Thus this may be inappropriate. • Xoserve to publish all SPA, AQ Review and CSEPs Rec files in UK Link standard file formats. • DNOs to raise code modifications to include these file formats in Annexe A. of the CSEP NExA.
The Way Forward • Ofgem NExA group has approved these proposals. • Presentations to:- • BOF • Distribution Workstream • Initial phase will look at solving the historical issues. • xoserve to engage with IGTs to put in place neutral Rec proposals for 1 October 2007. • Neutral Rec will be presented to shippers by IGTs before submission to xoserve. • If shipper is unhappy with any Neutral Rec then he can supply a meter reading to IGT as an alternative. • DNOs to raise code modifications to include file formats in Annexe A. of the CSEP NExA.