SVG181/03 – APPROVED METERING DISPENSATION D/460 –
REQUEST TO REMOVE A CONDITION
MEETING NAME
SVG 181
Date of meeting
1 March 2016
Paper number
181/03
Owner/author
Mike Smith
Purpose of paper
Decision
Classification
Public
Summary
Macquarie Bank Ltd (MBL) has asked us to remove a condition of its approved
Metering Dispensation D/460 for Teesport. The condition is that it notifies the
ISG and SVG of the identity of the Licenced Supplier for the demand BM Unit
associated with the Imports. MBL has confirmed it is not proposing to use a
Licenced Supplier and so cannot comply with the condition. We invite the SVG
to remove this condition. We will present a similar paper to the ISG on 23
February 2016.
1.
Background to Metering Dispensation D/460
1.1
In October 2015 Macquarie Bank Ltd (MBL) applied for a lifetime Metering Dispensation (D/460) from Code
of Practice (CoP) 3 for the location of the proposed Metering Equipment associated with local demand
(Imports) to the nearby port (Teesport) fed from the Tees Renewable Energy Plant (Attachment A). MBL
provided a single line diagram showing the proposed metering solution (Attachment B).
1.2
MBL also requested to use a difference metering arrangement so that the Imports to the Tees Renewable
Energy Plant could be separately determined from the Imports to Teesport.
1.3
We presented the Metering Dispensation application to the ISG at its meeting in October 2015 (ISG174/02)
and invited the ISG to approve D/460 subject to the following condition:
●
1.4
1
MBL provides a compensation method that:
o
Accounts for the losses from the Actual Metering Point [at Teesport] 1 to the Defined Metering Point
[at the Transmission System Boundary];
o
Is received by ELEXON no later than 31 October 2016;
o
Maintains the overall accuracy of the [Teesport] Metering System within CoP3 limits [at the Defined
Metering Point]; and
o
Is approved by the ISG and SVG.
An ISG Member noted that when the Tees Renewable Energy Plant is producing electricity, the Tees
Renewable Energy Plant will supply the Teesport site via a Supply Licence exemption. However, if for some
reason the Tees Renewable Energy Plant is not running, the Teesport site would be consuming directly from
the Transmission System (via the Tees Renewable Energy Plant). The ISG Member noted that the BSC does
not allow a site to flip between multiple Registrants. Therefore the Member considered that if MBL remains as
the Registrant, it would need to register as a Supplier, or register the site with an existing Supplier for when
the Tees Renewable Energy Plant is not producing. ELEXON commented that a situation whereby the
We have added the text within the square brackets to the verbatim conditions of D/460 for clarification purposes only.
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SVG181/03 – APPROVED METERING DISPENSATION D/460 –
REQUEST TO REMOVE A CONDITION
Teesport site would be consuming directly from the Transmission System is unlikely. ELEXON agreed to
investigate who the Registrant will be for Teesport once it is operational. The ISG agreed to add a condition
to the Metering Dispensation whereby MBL confirms who the Licenced Supplier will be for the Teesport site
when the Tees Renewable Energy Plant is not generating, in order for the Metering Dispensation to become
active.
1.5
The ISG therefore approved D/460 subject to the condition described above and an additional condition that:
●
MBL notifies the ISG and SVG by 31 October 2016 (via ELEXON) who the Licenced Supplier will be for
the [Teesport] demand BM Unit.
1.6
We also presented the Metering Dispensation application to the SVG at its meeting in November 2015
(SVG177/02). The SVG approved D/460 subject to the same conditions the ISG agreed.
2.
Request to remove a condition of D/460
2.1
In December 2015 we received a request from MBL to remove the condition that it inform the ISG and SVG
who the Licensed Supplier will be for the demand BM Unit associated with the Imports to Teesport. This is
because MBL does not intend to use a Licensed Supplier.
2.2
When we asked MBL to clarify who would be supplying the Teesport site with electricity MGT Power Limited
responded and confirmed that MGT Teesside Limited 2, which has a Generation Licence, is the proposed
Registrant of the Metering Equipment associated with the demand BM Unit for Teesport and that it intends to
supply the Teesport site with electricity.
3.
ELEXON’s view
3.1
We sought legal guidance (Appendix 1) on the question of whether the BSC requires a Licensed Supplier to
be responsible for the Imports to Teesport (and therefore register the demand BM Unit associated with
Teesport).
3.2
In summary our conclusion is that the BSC, for the Central Volume Allocation (CVA) Metering System
associated with these Imports:
●
requires the Registrant of the CVA Metering System, and therefore the Lead Party for the demand BM
Unit, to be the person responsible for the Imports (the person supplying electricity to the premises
connected to the Total System); and
●
does not require that person to have a Supply Licence or an exemption from a Supply Licence.
3.3
We therefore agree with MBL that the condition that a Licensed Supplier be identified for this transaction be
removed from D/460. We recommend that the ISG and SVG remove this condition.
4.
ISG’s decision on the request to remove a condition of D/460
4.1
We will present a similar paper (ISG178/05) to the ISG at its meeting on 23 February 2016 and will update
you verbally on the ISG’s decision.
2
MGT Teesside Limited is not currently a BSC Party so will need to accede to the BSC before it commissions the Tees Renewable Energy Plant in
2018. MGT Teesside Limited will also need to register the BM Units and the Metering Equipment for the Tees Renewable Energy Plant and the
Teesport site.
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REQUEST TO REMOVE A CONDITION
5.
Recommendations
5.1
We invite you to:
a)
NOTE the request from the applicant of Metering Dispensation D/460 to remove the condition to inform
the ISG and SVG who the Licensed Supplier for Teesport will be;
b)
NOTE ELEXON’s view that the supplies to Teesport do not have to be provided by a Licensed Supplier;
c)
REMOVE this condition from D/460; and
d)
NOTE that we will present a similar paper to the ISG on 23 February 2016 and will update you verbally
on the ISG’s decision.
Appendices
Appendix 1 – Legal guidance
Attachments
Attachment A – Metering Dispensation D/460
Attachment B – Single line diagram of proposed metering solution
For more information, please contact:
Mike Smith, Metering Analyst
[email protected]
020 7380 4033
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APPENDIX 1 – LEGAL GUIDANCE
Following the request to remove the condition we sought legal guidance on the question of whether the BSC
requires a Licensed Supplier to be responsible for the Imports to Teesport (and therefore register the demand BM
Unit associated with Teesport). The Teesport site is embedded within the Tees Renewable Energy Plant which is
directly connected to the Transmission System.
Section X, Annex X-1, of the BSC defines a Supplier as ‘a Party which holds a Supply Licence and is responsible for
Exports and/or Imports for which such Party is required, by virtue of Section K, to register one or more SVA
Metering Systems’.
Section K defines what an Import is and who is responsible for Imports in various scenarios. For an Import which
constitutes the supply of electricity to premises connected to the Total System (the Transmission System, each
Offshore Transmission System User Asset and each Distribution System), whether or not for consumption at those
premises, the person responsible for the Import is the person who supplies electricity to those premises (K1.2.2 (b)
(i)).
The Party responsible for supplying electricity needs to register the Metering System measuring those Imports
(K1.2.1 (a)). Section K2 defines where Metering Systems should be registered. Metering Equipment which measures
quantities of Imports to (or Exports from) Plant or Apparatus which is directly connected to the Transmission System
must be registered in the Central Meter Registration Service (i.e. be a CVA Metering System) (K2.1.1 (a)).
Therefore as these Imports must be measured by a CVA Metering System the term Supplier, which as per the BSC
applies only to SVA Metering Systems, is not relevant.
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