MRA Guideline for the Supplier of Last Resort Procedure GD19 Version : 2.0 Status : Final Date : 27 July 2007 Document Reference : GD19_2.0 2007 MRA Service Company Limited, 10 Fenchurch Street, London, EC3M 3BE. All rights reserved. No part of this publication may be reproduced or transmitted in any material form (including photocopying or storing it in any medium, by electronic means and whether or not transiently or incidentally to some other use or publication) without the permission of MRA Service Company Limited, whose address is set out above. MRA Guideline for the Supplier of Last Resort Procedure GD19 CONTENTS 1. INTRODUCTION 1.1 1.2 1.3 1.4 1.5 1.6 1.7 1.8 2. 3 PURPOSE USE OF THIS GUIDELINE STRUCTURE OF THIS DOCUMENT BACKGROUND ASSUMPTIONS HALF HOURLY REGISTRATIONS ACRONYMS AND DEFINITIONS REFERENCES 3 3 3 3 5 6 6 7 NORMAL REGISTRATION PROCESSING 2.1 2.2 2.3 2.4 8 OVERVIEW DETAILED DESCRIPTION CONSTRAINTS ON THIS PROCESS SUMMARY OF ISSUES 8 8 9 12 3. AGREEMENT BETWEEN SOLR AND DEFAULTING SUPPLIER’S DATA COLLECTOR 3.1 3.2 3.3 3.4 OVERVIEW DETAILED DESCRIPTION CONSTRAINTS ON THE PROCESS SUMMARY OF ISSUES 13 13 13 14 15 ANNEX A – DIAGRAMS SHOWING NORMAL REGISTRATION PROCESSING 16 ANNEX B – DIAGRAMS SHOWING USE OF THE DEFAULTING SUPPLIER’S DATA COLLECTOR TO PROCESS THE APPOINTMENT READING 22 Version: Status: Date: 27th July 2007 Document Reference: GD19_2.0 2.0 Approved 2 of 30 MRA Guideline for the Supplier of Last Resort Procedure GD19 1. Introduction 1.1 Purpose This guideline describes the process(es) that may be adopted by a Supplier of Last Resort (SoLR) in order to complete its registrations for the Metering Points to which it has been appointed. The purpose of this guideline is to identify the existing obligations on Suppliers (and where appropriate, other participant roles) that must be complied with whilst registering for Metering Points that are subject to a Last Resort Supply Direction. In doing so, this document will identify a number of issues that a SoLR must consider during this process and, where appropriate, suggest different courses of action to overcome those issues. This guideline does not place any obligations on parties over and above those obligations placed on them by the Master Registration Agreement (MRA) or other Core Industry Documents. 1.2 Use of this Guideline In fulfilling its purpose, this document summarises a number of the obligations contained within the MRA and other Core Industry Documents. This guideline does not constitute a contractual requirement and in all cases, the obligations as contained within the MRA and other Core Industry Documents take precedence over this document. Whilst the MRA Service Company Limited (MRASCo) shall endeavour to maintain the accuracy and completeness of this guideline, MRASCo accept no responsibility or liability as to or in relation to the accuracy or completeness of the information contained within this guideline. The information provided in this document acts as a guide only; it is the responsibility of MRA parties to adopt suitable processes and procedures to ensure compliance to existing obligations. 1.3 Structure of this Document Section 2 of this guideline describes the transfer of registrations to the SoLR using normal registration processing; this section also considers the timescales that apply to this process and some of the considerations regarding the change of Supplier meter reading. Section 3 then considers how the process would be modified if the SoLR and the agents of the Defaulting Supplier reach an agreement so that any readings taken prior to the SoLR SSD are processed into Settlement. 1.4 Background Ofgem can, in circumstances such as the appointment of a receiver, an administration order being made or a High Court winding up order being made, revoke the licence of an electricity Supplier. Ofgem may revoke the licence in such circumstances with a minimum of 24 hours’ notice. Version: Status: Date: 27th July 2007 Document Reference: GD19_2.0 2.0 Approved 3 of 30 MRA Guideline for the Supplier of Last Resort Procedure GD19 Not every Supplier failure will require regulatory intervention – the business assets of a Defaulting Supplier, including its customer portfolio, may be sold in a trade sale. However Ofgem will take all reasonable steps to secure the continuity of supply for all customers and where a trade sale has not been possible, such action may include revocation of licence and appointment of a SoLR. Where a SoLR is appointed, Ofgem will always seek the consent of the Supplier(s) concerned; however, if no suitable Supplier consents to being appointed as a SoLR, Ofgem will consider directing a Supplier against its wishes to ensure the continuity of supply to the customers concerned. Where Ofgem receives advance warning that a Supplier is likely to enter receivership, Ofgem will seek bids from other Suppliers to take-on the customer portfolio of that Defaulting Supplier. The process for seeking this information and for selection of the SoLR is described in references 1 and 2. Ofgem may choose to appoint one SoLR for the entire Customer portfolio or may choose several Suppliers, each being responsible for all of the Customers of the Defaulting Supplier in one or more GSP Groups. Where more than one SoLR has been appointed to the customer portfolio of the Defaulting Supplier each SoLR will commence registering for the Metering Points to which it has been appointed. This guideline considers the implications and processes to be adopted for the transfer of those registrations – the requirements for this process are described in reference 4. Where only one SoLR has been appointed for the entire portfolio of a Defaulting Supplier that SoLR may decide not to transfer the Metering Points; however, it must transfer the Settlement liabilities. The requirements and procedures defined under the Balancing and Settlement Code (BSC) describe the process to be followed to ensure that all Settlement liabilities are transferred to the SoLR from the relevant Settlement Day including the procedure for transferring BM Units in such circumstances. These procedures are not considered further in this guideline and the processes described in this guideline need not be followed in the event that only one SoLR is appointed. In order to develop the processes for registration of a SoLR to the Metering Points to which it has been appointed, a SoLR Expert Group was established by Ofgem and chaired by MRASCo. This Expert Group proposed a number of alternative processes that could be adopted for these registration transfers ranging from use of existing registration processes to the ‘bulk transfer’ of registrations to the SoLR Supplier ID. Through a number of consultations with industry, it was clear that no single proposal (or any combination of the tabled proposals), if presented as a change to the industry baseline, would gain the required support from all sectors of the industry in order for it to be accepted and implemented. The MRA Development Board (MDB) therefore made the decision that a guideline should be created summarising the options available that do not require any changes to the baseline in order to be implemented. These options are described in this guideline. Version: Status: Date: 27th July 2007 Document Reference: GD19_2.0 2.0 Approved 4 of 30 MRA Guideline for the Supplier of Last Resort Procedure GD19 1.5 Assumptions In order to develop the process descriptions contained within this guideline, the following assumptions have been made: Version: Status: The agents previously appointed by the Defaulting Supplier do not fail. During the SoLR project it was appreciated that if the agents of the Defaulting Supplier were also to fail, then this would significantly increase the risks and impact the processes adopted in a SoLR event described. It was however agreed that in order to develop a solution to Supplier failure, this assumption had to be made. It is for industry to determine if further work is required to consider agent failure. During the period of time between the SoLR being appointed and the SoLR’s Supply Start Date (SSD) for the Metering Points concerned, the agents previously appointed by the Defaulting Supplier will continue to provide services for those Metering Points. This is provided-for by Section K of the BSC. There is no requirement for the SoLR to appoint the agents used by the Defaulting Supplier (the process diagrams associated with this document assume that there a change of agent). However, in cases where the same agents are used, the agent appointment processes would be simplified and would not be dependent on the exchange of information from the old agents to the new agents. If the SoLR appoints alternative agents (on or after its SSD), the agents of the Defaulting Supplier would cease to provide services for those Metering Points from the date of those alternative appointments – in the absence of the Defaulting Supplier, it will be the responsibility of the SoLR to notify the outgoing agents of the termination of appointment. Retrospective registrations by the SoLR will not be permitted – the SoLR will not be allowed to submit registration requests for the Metering Points concerned containing Supply Start Dates prior to the dates of those requests. There are operational risks associated with the processes described in this document. Where a Supplier is appointed as a SoLR it must accept that it must bear such operational risks. In accordance with Clause 26.4 of the MRA (Reference 5) all registrations must be completed within 3 months of the SoLR appointment. On becoming aware of a potential Defaulting Supplier, Ofgem will request information from that Supplier on its customer portfolio – the request for such information is discussed in reference 2. Where such information is provided, relevant parts of this will be forwarded to the SoLR who may be able to determine from this, cases where the mailing address for a Customer is different to the Metering Points address (which is held on MPAS). Such information may also indicate which Date: 27th July 2007 Document Reference: GD19_2.0 2.0 Approved 5 of 30 MRA Guideline for the Supplier of Last Resort Procedure GD19 Metering Points in the portfolio inherited by the SoLR have pre-payment metering. The agents previously appointed by the Defaulting Supplier are unlikely to receive a de-appointment notification (D0151) from that Supplier. Where the systems of those agents require this de-appointment notification in order to pass Metering Point information to the agents appointed by the SoLR this will potentially delay the agent transfer process. It is assumed that the SoLR will enter into dialogue with the agents concerned in order to expedite a solution. Recent experience has shown that in some instances a trade sale is agreed between the failing Supplier and another Supplier before the point at which a Last Resort Supply Direction would be issued. Section K of the BSC contains provisions to allow a Supplier where specified events have occurred to transfer some, or all, of its portfolio to another Supplier voluntarily. The processes described in this guideline could be utilised in such circumstances. 1.6 Half Hourly Registrations The processes described in this paper assume that the Metering Points being transferred are Non Half Hourly Metering Points, in particular with regard the process for obtaining a change of Supplier meter reading. Where a SoLR is appointed to Half Hourly Metering Points, there should be sufficient incentives on that SoLR to register these Metering Points as quickly as possible. This will therefore significantly reduce the period of time between SoLR appointment and SoLR SSD. This will be assisted by the fact that there are likely to be fewer Half Hourly Metering Points than Non Half Hourly Metering Points transferred in a SoLR situation. In such cases, it is expected that the SoLR would use normal change of Supplier processing to effect those transfers and instruct its appointed Data Collector to start retrieving the stored half hourly data from the meters concerned as soon as possible. 1.7 Acronyms and Definitions Any capitalised term that is not defined in this guideline shall have the meaning given to it in the MRA. Version: Status: Date: 27th July 2007 Document Reference: GD19_2.0 2.0 Approved 6 of 30 MRA Guideline for the Supplier of Last Resort Procedure GD19 1.8 Version: Status: Annualised Advance (AA) has the meaning given to that term in the BSC BM Unit has the meaning given to that term in the BSC Core Industry Documents has the meaning given to that term in the BSC Estimated Annual Consumption (EAC) has the meaning given to that term in the BSC Supplier ID has the meaning given to that term in the BSC References 1 Supplier of Last Resort: Guidance on Current Arrangements Published by Ofgem, March 2001 2 Supplier of Last Resort (Electricity): Appointment Process Requirements, Version 2.0. Published by Ofgem, 29 September 2000 3 Supplier of Last Resort: Transfer of Financial Liabilities Requirements, Version 2.0. Published by Ofgem, 29 September 2000 4 Supplier of Last Resort: Transfer of Registrations Requirements, Version 2.0. Published by Ofgem, 29 September 2000 5 Master Registration Agreement: Version 7.0. Published by MRASCo at full commencement of the Utilities Act Date: 27th July 2007 Document Reference: GD19_2.0 2.0 Approved 7 of 30 MRA Guideline for the Supplier of Last Resort Procedure GD19 2. Normal Registration Processing 2.1 Overview This section describes the registration processes to be adopted by the Supplier of Last Resort (SoLR) to transfer the Metering Points currently registered to the Defaulting Supplier to its own Supplier ID. It also describes the sequence of events for processing of the change of Supplier meter reading by the Data Collector appointed by the SoLR. Other parts of the process (for example, the selection of a SoLR) are covered, but in lesser detail as these processes are described more fully elsewhere. The registration processes described are essentially the normal change of Supplier processes albeit that there are tighter timescales on completion of certain stages. The key constraint on the processes described here, is that the registrations must be completed within a relatively short period after the SoLR appointment in order that the SoLR appointment reading is processed by the Data Collector appointed by the SoLR. The end to end diagrams showing this process are presented in Annex A to this document. The activities in these diagrams are labelled SoLR 1, SoLR 2, SoLR 3 and so on and are referenced in the following detailed description of the process (Section 2.2). Following the detailed description of the process, there is a discussion of the constraints placed on a SoLR using this process to transfer the registrations of the Defaulting Supplier (Section 2.3). The key points for consideration by a SoLR are then summarised in Section 2.4. 2.2 Detailed Description This section provides a step-by-step description of the process: i. In accordance with the process described in Reference 2, Ofgem determines that the Failing Supplier’s licence shall be revoked and, from the bids received from potential Suppliers of Last Resort, selects which SoLR shall be appointed to the Failing Supplier’s MPANs in each GSP Group area. This may include appointment of a SoLR against its wishes. (SoLR 1 to 7). ii. Ofgem announces the Licence Revocation and the SoLR appointment(s). This will trigger the MPAS Providers to forward the information they hold on the MPANs concerned to the appointed SoLRs. Service Providers are required to provide these details to the SoLR within 4 working days of the request being made, in accordance with MRA Clause 26.1 (Reference 5). (SoLR 7 and SoLR 8). iii. Version: Status: Once each appointed SoLR has been notified of its appointment and has received the details of the Metering Points to which it has been appointed, the SoLR will then be in a position to commence submitting registration requests (D0055s) for those Metering Points and also to commence writing to the customers concerned to notify them of the appointment (SoLR 9). Date: 27th July 2007 Document Reference: GD19_2.0 2.0 Approved 8 of 30 MRA Guideline for the Supplier of Last Resort Procedure GD19 The normal sequence of events for the transfer of a registration are then followed: iv. In response to each D0055 received from the SoLR, MPAS will provide the appropriate registration confirmations (D00217/D0260) or rejections (D0057). The SoLR must submit Supply Start Dates (SSD) in accordance with existing MRA rules and will not be allowed to make retrospective registrations. The Defaulting Supplier will not be allowed to submit any objections to these registrations. (SoLR 17) v. The SoLR commences the appointment of a Data Collector, Data Aggregator and Meter Operator for each of the Metering Points (this can be commenced at any stage – the appointments must however be effective from the registered SSD for each particular Metering Point) (SoLR 10 to 16) vi. If the SoLR has appointed agents other than those used by the Defaulting Supplier, an exchange of Metering Point information occurs between the old and new agents (SoLR 18 to 21) vii. Once the agent appointments have been confirmed, the SoLR provides its appointed Data Collector with any reading provided by the Customer or instructs that Data Collector to obtain a reading. In accordance with Settlement rules, the Data Collector must determine the most appropriate read for the change of Supplier on SSD + 8 working days and submit this (on a D0086) to the SoLR, the Data Collector appointed by the Defaulting Supplier and the Distributor. Without changes to its Supplier billing systems, the SoLR will start billing the customer from the SSD reading rather than from the SoLR appointment date. As with normal CoS processing, the Data Collector will produce a D0010 for each candidate CoS reading and a D0019 containing the initial EAC based on the CoS reading. (SoLR 22, 23, 25 and 61) viii. If the administrators of the Defaulting Supplier’s assets have made appropriate arrangements, the CoS reading received by the Defaulting Supplier’s Data Collector may be used as a basis for producing a closing account to the Customer. However if it is, the reading must be deemed back to the date of the licence revocation in order that the administrators of the Defaulting Supplier do not bill the Customer for any period after the licence revocation. As with normal CoS processing, the Data Collector of the Defaulting Supplier (the ‘old’ Data Collector) will produce a D0019 containing the final AA based on the CoS reading (SoLR 25 to 26) 2.3 Constraints on this process In order for a SoLR to use this process and still comply with its Licence obligation to obtain and process a SoLR appointment reading within 14 calendar days of its appointment, all the registrations must be transferred to the SoLR within a few days of appointment. This is considered in more detail below: Version: Status: Date: 27th July 2007 Document Reference: GD19_2.0 2.0 Approved 9 of 30 MRA Guideline for the Supplier of Last Resort Procedure GD19 Denoting Day D as the day of the SoLR appointment, between day D and day D+3 working days, the SoLR can expect to receive from MPAS Providers the details of the Metering Points to which it has been appointed. (These details are requested on Day D-1 and must be submitted to the SoLR(s) within 4 working days of that request). Once the SoLR has the required MPAD information, it will be in a position to: - commence writing to the customers concerned, notifying them of the SoLR appointment and, if appropriate, requesting a meter reading. - commence submitting registration requests for the MPANs. In accordance with its Licence obligations, the SoLR must have made reasonable endeavours by D plus 14 calendar days to obtain a SoLR appointment reading. It is anticipated that in most cases the customer will provide this or the reading will be deemed. These key events are shown on the timeline below: D SoLR appointment date D+3 working days MPAD report due by this date D+14 calendar days SoLR Reading to be obtained by this date SoLR commences submitting registration requests SoLR commences notifying customers of the appointment During this period (as at all times), the SoLR and the Data Collector appointed by the SoLR must comply with the existing rules for processing all meter readings and in particular those obtained on change of Supplier. The pertinent parts of those rules are summarised below: Version: Status: Under BSC obligations, any meter reading obtained must be processed and submitted into Settlement. Therefore if a reading is provided by the Customer on or around the time of the SoLR appointment it must be processed and submitted into Settlement. In order for the Data Collector appointed by the SoLR to process a reading as part of its normal processing, that reading must be taken on or after the Data Collector’s appointment date, and therefore on or after the SoLR’s SSD. If this is the case, irrespective of whether it is Date: 27th July 2007 Document Reference: GD19_2.0 2.0 Approved 10 of 30 MRA Guideline for the Supplier of Last Resort Procedure GD19 used as the Meter Reading on Change of Supplier (MRoCoS), the Data Collector will process that reading and submit it into Settlement. Since any reading obtained within 5 working days either side of a Supplier’s SSD is a potential candidate for the MRoCoS, the Data Collector appointed by the SoLR may still process a reading taken before SSD as long as that reading was taken in the period SSD-5 to SSD-1 and that reading is used for the MRoCoS. Summarising all of these constraints, the SoLR can use the process described above to transfer the registrations of the Defaulting Supplier’s MPANs and comply with its obligations regarding meter reading processing if: the SoLR appointment reading is taken (or provided by the Customer) within 14 days of appointment and the date of the reading is on or after the SoLR SSD. The Data Collector would therefore process that reading irrespective of whether it is used for the MRoCoS. the SoLR appointment reading is taken (or provided by the Customer) within 14 days of appointment but prior to the SoLR SSD as long as the reading is no more than 5 days prior to the SSD and that reading is used for the MRoCoS. This will only be the case if there is no better candidate for the MRoCoS taken after the SoLR appointment reading in accordance with the rules stated in BSCP504. As previously stated, the Data Collector appointed by the Defaulting Supplier will receive a copy of the MRoCoS (in accordance with normal processing of CoS readings). Where this reading was taken after the SoLR appointment, this reading must be estimated back to the date of the Licence revocation before being used by the administrators of the Defaulting Supplier to bill the Customer. This is essential to ensure that the closing account to the Customer does not include any consumption after the Licence revocation. As the Defaulting Supplier or its administrators will carry out this estimation, the SoLR will not have sight of this reading and will not therefore be in a position to align the closing and opening readings to the Customer. Further, even if the SoLR were to receive a copy of the MRoCoS estimated back to SoLR appointment date, it still may not be able to use this to commence billing the Customer, as Supplier systems will be designed to commence billing the customer from the SSD - the SoLR appointment date and therefore the date of the estimated reading will be prior to the SoLR SSD. Consequently, using this process there is a significant risk that the closing reading used by the Defaulting Supplier (or its administrator) to close the account with the Customer, will not match the start reading used by the SoLR to open the Customer account. This will inevitably generate queries from Customers who may in turn dispute those readings. It should also be noted that it is possible that in the interval between the SoLR being appointed to the MPAN and the SoLR submitting its registration request, the Customer could choose another Supplier (Supplier Z) and that Supplier could submit its registration request. If the SoLR then submits its own registration request and this registration is accepted (any lock-out period from Supplier Z’s registration having expired) then Supplier Z would lose the Version: Status: Date: 27th July 2007 Document Reference: GD19_2.0 2.0 Approved 11 of 30 MRA Guideline for the Supplier of Last Resort Procedure GD19 Metering Points, contrary to the Customer’s wishes. Such instances would be considered as Erroneous Registration and would be resolved via the Erroneous Registration process in order to return the registration to the Customer’s chosen Supplier. Summary of Issues 2.4 Below is a summary of the key issues a SoLR would have to consider if following the process described above: Version: Status: The appointment date of the SoLR and the SoLR SSD will not be aligned. A Supplier will only fulfil its obligations using this process if either - the SoLR appointment reading is taken on or after the SoLR SSD, or - the SoLR appointment reading is taken before the SoLR SSD but is used as the CoS reading. If a customer own reading for the SoLR appointment is provided prior to SSD and is not used as the MRoCoS, that reading would not be processed into Settlement. The closing reading used by the administrators of the Defaulting Supplier may not correspond to the start reading used by the SoLR. Without significant changes to Supplier systems or a manual over-ride to those systems, the SoLR will only commence billing the Customer from the SSD and not the SoLR appointment date. If the Customer chooses an alternative Supplier to the SoLR who in turn registers before the SoLR submits its registration, the Erroneous Registration process would have to be invoked to resolve the situation. Date: 27th July 2007 Document Reference: GD19_2.0 2.0 Approved 12 of 30 MRA Guideline for the Supplier of Last Resort Procedure GD19 3. Agreement between SoLR and Defaulting Supplier’s Data Collector 3.1 Overview The process so far described in section 2, allow for all registrations to be completed within a relatively short timescale in order to facilitate the timely submission of SoLR appointment readings into Settlement. Where the Customer portfolio acquired by the SoLR is of significant size, these timescales may not be achievable and the SoLR may therefore wish to consider other means in order to meet its Settlement obligations. Amongst the solutions presented by the SoLR Expert Group, a scenario was proposed whereby the SoLR reaches an agreement with the Data Collector appointed by the Defaulting Supplier so that all readings taken prior to the SoLR SSD are processed into Settlement. This process is described here. It should however be noted that the original proposal suggested changes to the baseline to support this process. As no agreement has been reached to make these changes, participants should note that there are no obligations on either Data Collectors or Suppliers to support these arrangements and that there are no agreed flow structures to support any of the non-standard communications included in this description. The end to end diagrams showing this process are presented in Annex B to this document. The activities in these diagrams are labelled SoLR 1, SoLR 2, SoLR 3 and so on and are referenced in the following detailed description of the process (Section 3.2). Following the detailed description of the process (Section 3.2), there is a discussion of the constraints placed on a SoLR wishing to use this process to support the transfer of registrations from the Defaulting Supplier (Section 3.3). The key points for consideration by a SoLR are then summarised in Section 3.4. 3.2 Detailed Description This section provides a step-by-step description of the process Up to the point where a Supplier receives notification that it has been appointed as the SoLR for a portfolio of MPANs, the process follows the same sequence as for normal registration process described in section 2 steps (i) to (iii) in section 2.2. Then: iii a Version: Status: At some time after the SoLR has received notification that it has been appointed as SoLR and received notification from MPAS of the ID of the incumbent Data Collector for the Metering Points that are to be transferred, the SoLR will contact that Data Collector. The SoLR then negotiates with that Data Collector to either: Date: 27th July 2007 Document Reference: GD19_2.0 2.0 Approved 13 of 30 MRA Guideline for the Supplier of Last Resort Procedure GD19 - Accept a copy of a Customer own reading taken at or around the time of the SoLR appointment - Or, obtain a meter reading for the SoLR appointment (it is expected that in most cases this will be a deemed meter reading). The Data Collector would then process that reading and submit it into Settlement using normal processing thereby providing a copy of the processed reading to the Distributor and to the Defaulting Supplier (or its administrators). The SoLR should therefore arrange that it also receives a copy of the results of the processing of that reading. This would be outwith normal meter reading processing for the Data Collector. It is not anticipated that the SoLR will make this request for all the MPANs that are to be transferred from the Defaulting Supplier but only those that it expects not to have registered within the timescales prescribed in section 2 (SoLR 27 and 28). iii b On receipt of the processed reading, the Defaulting Supplier (or its administrators) may then use this reading as a basis for the closing account for the Customer concerned. In cases where this reading is dated after the SoLR appointment date, the reading should be deemed back to the date of the appointment before being used to bill the Customer (SoLR 29). iii c On receiving the copy of the SoLR appointment reading, the SoLR may be in a position to use this as a start reading for the Customer account (SoLR 30). Once these arrangements have been made, the SoLR will then follow normal processing to submit, in due course, the registrations for these Metering Points and appoint its own agents. Therefore to complete this process, steps (iv) to (vii) of normal registration processing described in section 2.2 would be followed. Although the Data Collector appointed by the Defaulting Supplier would receive a copy of the MRoCoS in this process (step viii in section 2.2), it is not anticipated that this reading would be used to generate a final account to the Customer as the reading processed in steps (iii) a and (iii) b would be used as the basis for the closing account. 3.3 Constraints on the Process If the SoLR is able to follow the processes described in section 3.2, it will be able to ensure that a SoLR appointment reading taken prior to SSD is processed and submitted into Settlement. However, in order for this alternative to be used, the SoLR must first establish a relationship with the Data Collector previously appointed by the Defaulting Supplier such that it is prepared to accept and process meter readings on behalf of the SoLR. This will be prior to the SoLR submitting its registration requests for the Metering Points concerned and therefore prior to the SoLR being able to formally appoint a Data Collector to those Metering Points. Version: Status: Date: 27th July 2007 Document Reference: GD19_2.0 2.0 Approved 14 of 30 MRA Guideline for the Supplier of Last Resort Procedure GD19 Such a relationship is unprecedented in current market operation (in no other situation is a Supplier required to establish a relationship with an agent for a particular Metering Point that it has not previously appointed to that Metering Point). Although such an arrangement may require some manual intervention over normal meter reading processing, once the Data Collector has accepted the Customer own reading provided by the SoLR or the instruction to obtain a reading and has agreed to provide a copy of the processed reading to the SoLR, normal processing would be used. As with the process described in section 2.2, if the SoLR registration should replace the registration of another supplier chosen by the Customer, then the Erroneous Registration procedure would have to be invoked to restore the registration to the Customer’s selected supplier (see section 2.3). 3.4 Summary of Issues Below is a summary of the key issues a SoLR would have to consider if following the process described above: The appointment date of the SoLR and the SoLR SSD will not be aligned. In the period between these two dates the information held on registration systems will not correspond to the Settlement liabilities of the Metering Points concerned. Relies on arrangements between the SoLR and the Data Collector appointed by the Defaulting Supplier in order for the appointment reading to be processed. In order for the Data Collector appointed by the Defaulting Supplier to process a reading provided by the SoLR and submit a copy of the processed reading to the SoLR, may require manual intervention to the Data Collector’s systems and procedures for processing (non-CoS) readings. Unless the SoLR appointment reading is actually taken on the SoLR appointment date, there is still a possibility that the reading used by the Defaulting Supplier to close the Customer account does not match that used by the SoLR to commence billing the Customer. If the Customer chooses an alternative Supplier to the SoLR who in turn registers before the SoLR submits its registration, the Erroneous Registrations process would have to be invoked to resolve the situation. Version: Status: Date: 27th July 2007 Document Reference: GD19_2.0 2.0 Approved 15 of 30 MRA Guideline for the Supplier of Last Resort Procedure GD19 Annex A – Diagrams showing Normal Registration Processing The diagrams to support this process should be read in the following order: SHEET 1A SHEET 2A SHEET 1B SHEET 1C SHEET 2B Supplier of Last Resort Process (Non Bulk) SHEET 2D SHEET 2C SoLR NHHMO Notification of MOp appointment Failing Supplier situation resolved (eg Trade Sale) D0155 Potential failing Supplier in difficulty Discuss resolution of problem with Potential Failing Supplier. Restrict registration activity (if appropriate) and request details of portfolio. Check data held on potential Suppliers of Last Resort Potential DS Request for details of Customer Portfolio Provide details of Customer Portfolio Details of Customer Portfolio Make provisional match between SoLR information and Defaulting Supplier portfolio. Update stored information on Potential SoLRs. Resolve Failing Supplier problem (eg via Trade Sale) or make decision to revoke licence. Ofgem Licence Revoked SoLR 4 SoLR 3 Request for count of MPANs registered to the Defaulting Supplier Request for MPAN Details of DS SoLR 5 Potential SoLR Confirm or update information held by Ofgem MPAS Ofgem SoLR 2 SoLR 1 Request to confirm stored details on potential Suppliers of Last Resort Process Request for count of MPANS registered to the Defaulting Supplier SoLR 6 Count of MPANs registered to the Defaulting Supplier Receive information on counts of MPANs and retrieve information on potential SoLR and any supporting information. Evaluate and select SoLR(s). Notify each SoLR of its appointment; pass-on details of MPAN counts and notify participants of appointment NHHMO Provide details of other agents and customer details SoLR 13 NHHDC Create report of MPAD information and pass on to the SoLR(s) SoLR 8 Notification of DC appointment MPAD information D0204 D0155 Confirm acceptance of appointment SoLR 15 Forward meter technical details Request for meter technical details SoLR 18 D0170 Meter technical details SoLR 20 SoLR 14 DS NHHDC Request EAC/AA history from DC appointed by Defaulting Supplier D0148 D0131 SoLR 16 Forward EAC/AA history Request for EAC/AA history EAC/AA History SoLR 19 D0170 Receive consumption history. Confirm that MPAN has been included in the reading schedule D0010 D0152 SoLR 21 D0055 SoLR 17 Notification to Participants of SoLR appointment(s) Formal notice of licence revocation D0153 Confirm acceptance of contractual appointment SoLR 12 Customer Closing bill to customer Customer SoLR 26 Confirmation that registration request has been accepted SoLR NHHDC Receive confirmation of registration and agent appointments. Instruct DC to process or obtain MRoCoS D0217 D0260 Instruct DC to process CoR, obtain read and/or deem reading for SSD Obtain and/or process reading for SSD. On SSD+8, forward readings to SoLR, old DC and Distributor. SSD reading Receive SSD reading. Reading used as start reading for customer SoLR Customer start reading SoLR Records D0086 SoLR 25 SoLR 23 SoLR Confirmation of appointment D0011 SoLR Records Confirmation of registration D0209 Notification to customer of SoLR appointment Ofgem Agents, Suppliers, Distributors, PPMIPs NHHDA Consumption details submitted to Settlements DS NHHDA NHHDA Data Aggregator Records Normal processing - SSD within 14 days of appointment Data Aggregator Records D0019 Customer Receive notification of SoLR appointment. If appropriate, provide meter reading Reading provided by customer SoLR 61 SHEET 3H Version: Status: Receive SSD reading. If appropriate, bill customer using reading (deemed back to date of licence revocation) SoLR 24 D0072 D0071 SoLR Option SHEET 3G Copy of SSD reading D0086 Confirmation MPAN is in the reading schedules SoLR 22 NHHDA Updated information on Potential Suppliers of Last Resort Forward SSD reading to Administrators of Defaulting Supplier SSD reading D0149 D0150 SoLR 9 SoLR 7 Confirmation or updated information Ofgem Records Adminstrators of DS DS NHHDC SoLR Process registration request Submit registration request for MPAN Meter technical details D0149 D0150 Meter technical details D0012 MPAS Receive notification of appointment, MPAN count and MPAD information. Notify customer of appointment. Register for MPAN(s) and appoint agents Distributor Records D0086 Receive meter technical details. Forward to SoLR and DC D0149 D0150 SHEET 2E Distributor SSD reading NHHMO DS NHHMO Request meter technical details from MOp appointed by Defaulting Supplier NHHDC Customer and agent details SoLR Notification of appointment, appropriate MPAN counts and details of Defaulting Supplier's portfolio Customer and agent details D0148 D0131 NHHDC Provide details of other agents and customer details Confirmation of appointment D0011 SoLR 11 Confirmation of DA appointment Process Driver Path Confirmation of appointment D0011 SoLR 10 SoLR MPAS Instruction to pass on MPAD information to appointed SoLR(s) Ofgem Ofgem Confirm acceptance of appointment SHEET 1E SHEET 1D SHEET 2I SHEET 2J Date: 27th July 2007 Document Reference: GD19_2.0 2.0 Approved 16 of 30 MRA Guideline for the Supplier of Last Resort Procedure GD19 Version: Status: Date: 27th July 2007 Document Reference: GD19_2.0 2.0 Approved 17 of 30 MRA Guideline for the Supplier of Last Resort Procedure GD19 Version: Status: Date: 27th July 2007 Document Reference: GD19_2.0 2.0 Approved 18 of 30 MRA Guideline for the Supplier of Last Resort Procedure GD19 Version: Status: Date: 27th July 2007 Document Reference: GD19_2.0 2.0 Approved 19 of 30 MRA Guideline for the Supplier of Last Resort Procedure GD19 Version: Status: Date: 27th July 2007 Document Reference: GD19_2.0 2.0 Approved 20 of 30 MRA Guideline for the Supplier of Last Resort Procedure GD19 Version: Status: Date: 27th July 2007 Document Reference: GD19_2.0 2.0 Approved 21 of 30 MRA Guideline for the Supplier of Last Resort Procedure GD19 Annex B – Diagrams showing use of the Defaulting Supplier’s Data Collector to process the Appointment Reading The following diagrams should be read in the following order: SHEET 2A SHEET 2A SHEET 2B SHEET 2C SHEET 2B Supplier of Last Resort Process (Non Bulk) SHEET 2D SHEET 2C SoLR NHHMO Confirm acceptance of appointment Notification of MOp appointment Failing Supplier situation resolved (eg Trade Sale) Potential DS Request for details of Customer Portfolio Provide details of Customer Portfolio Details of Customer Portfolio Make provisional match between SoLR information and Defaulting Supplier portfolio. Update stored information on Potential SoLRs. Resolve Failing Supplier problem (eg via Trade Sale) or make decision to revoke licence. Instruction to pass on MPAD information to appointed SoLR(s) Ofgem Licence Revoked SoLR 1 SoLR 4 Confirm or update information held by Ofgem Request for count of MPANs registered to the Defaulting Supplier Request for MPAN Details of DS SoLR 5 Potential SoLR Request to confirm stored details on potential Suppliers of Last Resort MPAS Ofgem SoLR 2 Process Request for count of MPANS registered to the Defaulting Supplier Count of MPANs registered to the Defaulting Supplier SoLR 6 Receive information on counts of MPANs and retrieve information on potential SoLR and any supporting information. Evaluate and select SoLR(s). Notify each SoLR of its appointment; pass-on details of MPAN counts and notify participants of appointment SoLR 8 Confirm acceptance of appointment Notification of DC appointment MPAD information D0204 D0170 NHHDC D0148 D0131 EAC/AA History SoLR 19 D0010 D0152 SoLR 21 Forward SSD reading to Administrators of Defaulting Supplier SSD reading D0086 SoLR 24 Confirmation MPAN is in the reading schedules Confirmation that registration request has been accepted Process registration request D0055 Receive confirmation of registration and agent appointments. Instruct DC to process or obtain MRoCoS D0217 D0260 SoLR 17 Instruct DC to process CoR, obtain read and/or deem reading for SSD D0072 D0071 SoLR 9 NHHDC SoLR Obtain and/or process reading for SSD. On SSD+8, forward readings to SoLR, old DC and Distributor. Receive SSD reading. Reading used as start reading for customer SSD reading D0086 SoLR 25 SoLR 23 SoLR 22 Confirmation of registration NHHDA Confirm acceptance of contractual appointment D0153 Notification to Participants of SoLR appointment(s) SoLR 12 SoLR Confirmation of appointment D0209 SoLR Records DS NHHDA NHHDA D0011 SoLR Option Receive notification of SoLR appointment. If appropriate, provide meter reading Notification to customer of SoLR appointment Agents, Suppliers, Distributors, PPMIPs Data Aggregator Records Reading stored. SoLR Records D0019 Customer SoLR reading processed by incumbent agents Ofgem SoLR NHHDA Consumption details submitted to Settlements Data Aggregator Records Ofgem Records Administrator of DS DS NHHDC SoLR SoLR 7 Confirmation or updated information Formal notice of licence revocation Adminstrators of DS Copy of SSD reading D0012 Submit registration request for MPAN SoLR 3 Updated information on Potential Suppliers of Last Resort Distributor Records D0149 D0150 Meter technical details D0149 D0150 Receive consumption history. Confirm that MPAN has been included in the reading schedule Forward EAC/AA history Request for EAC/AA history D0170 SoLR 16 SHEET 2E Distributor Meter technical details SoLR 20 MPAS Receive notification of appointment, MPAN count and MPAD information. Notify customer of appointment. Register for MPAN(s) and appoint agents SHEET 2E D0086 Receive meter technical details. Forward to SoLR and DC Meter technical details D0149 D0150 DS NHHDC Request EAC/AA history from DC appointed by Defaulting Supplier Customer and agent details SoLR 14 SoLR Notification of appointment, appropriate MPAN counts and details of Defaulting Supplier's portfolio SoLR 18 NHHDC Provide details of other agents and customer details Confirmation of appointment D0011 SoLR 11 D0155 Forward meter technical details Request for meter technical details SoLR 15 SSD reading NHHMO DS NHHMO Request meter technical details from MOp appointed by Defaulting Supplier Customer and agent details D0148 D0131 SoLR NHHDC Create report of MPAD information and pass on to the SoLR(s) Confirmation of DA appointment Process Driver Path NHHMO Provide details of other agents and customer details SoLR 13 MPAS Discuss resolution of problem with Potential Failing Supplier. Restrict registration activity (if appropriate) and request details of portfolio. Check data held on potential Suppliers of Last Resort Confirmation of appointment D0011 SoLR 10 D0155 Ofgem Ofgem Potential failing Supplier in difficulty SHEET 2D Reading provided by customer SoLR 61 SHEET 3H SHEET 3G SHEET 2I Distributor SoLR reading required prior to MRoCoS SoLR reading or routine reading SHEET 2J Distributor Records D0010 DS NHHDC SoLR Negotiate with DC appointed by DS to process SoLR or obtain SoLR reading CoR and/or instruction to obtain and process SoLR reading Process CoR or obtain SoLR reading as instructed. Process routine reading (if appropriate) SoLR 27 Adminstrators of DS Receive SoLR or routine reading. If appropriate, bill customer using reading (deemed back to date of licence revocation) SoLR reading or routine reading Customer Closing bill to customer Customer SoLR 28 D0010 SoLR 29 SoLR Receive copy of SoLR or routine reading. Could be used as start reading for customer billing Copy of SoLR reading or routine reading SoLR Customer start reading SoLR Records D0010 SoLR 30 DS NHHDA Consumption data submitted to Settlements Data Aggregator Records D0019 SHEET 2G Version: Status: SHEET 2H SHEET 2I Date: 27th July 2007 Document Reference: GD19_2.0 2.0 Approved 22 of 30 MRA Guideline for the Supplier of Last Resort Procedure GD19 Version: Status: Date: 27th July 2007 Document Reference: GD19_2.0 2.0 Approved 23 of 30 MRA Guideline for the Supplier of Last Resort Procedure GD19 Version: Status: Date: 27th July 2007 Document Reference: GD19_2.0 2.0 Approved 24 of 30 MRA Guideline for the Supplier of Last Resort Procedure GD19 Version: Status: Date: 27th July 2007 Document Reference: GD19_2.0 2.0 Approved 25 of 30 MRA Guideline for the Supplier of Last Resort Procedure GD19 Version: Status: Date: 27th July 2007 Document Reference: GD19_2.0 2.0 Approved 26 of 30 MRA Guideline for the Supplier of Last Resort Procedure GD19 Version: Status: Date: 27th July 2007 Document Reference: GD19_2.0 2.0 Approved 27 of 30 MRA Guideline for the Supplier of Last Resort Procedure GD19 Version: Status: Date: 27th July 2007 Document Reference: GD19_2.0 2.0 Approved 28 of 30 MRA Guideline for the Supplier of Last Resort Procedure GD19 Version: Status: Date: 27th July 2007 Document Reference: GD19_2.0 2.0 Approved 29 of 30 MRA Guideline for the Supplier of Last Resort Procedure GD19 Version: Status: Date: 27th July 2007 Document Reference: GD19_2.0 2.0 Approved 30 of 30
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