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We monitor and respond to consultations that may have an impact on the provisions in the BSC, on Elexon, or on our customers.
We respond to consultations if we think that an area of the electricity markets may be affected or where clarification of the BSC provisions is of benefit to the consultation.
We have commented on National Grid ESO’s proposed Grid Code Modification which will clarify the existing arrangements for disconnection of embedded generation where there is more electricity generation than expected demand.
Response to NGESO consultation on Modification GC0143: ‘Last resort disconnection of Embedded Generation’We've responded to Electralink’s consultation on their new DNO data provision and standardisation service, Flexr. Our response highlighted the importance of Open Data principles and access to the data held on the platform. We questioned the use of funding over and above the use of existing, paid for, systems architecture and how this affects platform governance.
Response to Electralink’s consultation on FlexrIn our response, we commented on one clause of EREC P24 Issue 2, namely clause 12.9 and its references to the BSC and requirements for metering. We suggested a number of changes to the text.
Response to Code consultation on Engineering Recommendation (EREC) P24 Issue 2 – AC supplies to railway systems:In our response, we noted that it is not clear to us that further harmonisation of imbalance price calculations would provide benefits to consumers.
Response to ACER’s consultation on harmonising imbalance settlementIn our response we note our belief that appropriate smart charging infrastructure, metering and data access arrangements are essential in delivering the proposals.
Response to OLEV’s consultation on ending the sale of new petrol, diesel and hybrid cars and vansIn our response, we are supportive of the provision of increased information on embedded generation >1MW as it can lead to charges being more cost reflective, aid the operation of the system and aid parties in deciding where best to locate their assets.
Response to Electralink’s consultation on DCP350In our response we supported the consultation premises that heat networks are an integral part in the government and industry efforts towards a modernised and low-carbon energy sector of the future.
We also explained how a number of market arrangements from the electricity industry and more specifically from the BSC systems could be applied for the development of a prospective UK heat market.
Response to consultation on Heat Networks: Building a Market FrameworkIn our response, we note that consistency of processes across distribution regions will be key to unlocking the potential of flexibility. We believe that provision for spending is essential to establishing the flexibility value stack, and that the findings from the Open Networks project should be presented as a case for funding in the RIIO-ED2 price control.
Response to the ENA’s consultation on the Open Networks Project 2020 WorkplanOur response regarding ESO’s consultation on Network Code on Emergency and Restoration agrees with the one proposed mapping to the BSC, and makes some observations on the change processes.
Response to ESO’s consultation on NCER amended proposalsOur response supports the proposed amendments to the Heat Network Regulations 2014 (Metering and Billing). More specifically, we agreed with adopting a system using building classes to assess the need for installing individual heat meters both for domestic and non-domestic heat network users. We also made some recommendations on how certain BSC processes could be exemplified for the metering operations for heat networks.
Response to BEIS consultation on Heat Network (Metering and Billing) Regulations 2014 Proposed Amendments – January 2020Our response welcomed the proposed changes to promote consistent terminology. However, we disagreed that balancing bids for system constraints should be used to update the Cross-Zonal Capacity, and therefore distort the cross-border marginal balancing energy price.
Response to ACER’s consultation on the implementation framework for the mFRR European platformElexon is proposing that nationwide electricity ‘flexibility platforms’ are set up so that offers to provide ‘demand-side response’, or output from electricity storage facilities can be traded easily.
The buyers of storage output or demand-side response (DSR) services could include local electricity distribution network operators (DNOs) suppliers and businesses.
Policy View: Setting up Electricity Flexibility PlatformsOur response agreed to allow scheduled counter-activations, but noted that direct counter-activations could happen for reasons other than balancing, and that this could distort imbalance prices so that they no longer represent the time value of energy
Response to ACER’s consultation on all TSO’s proposal on the pricing methodology for balancing energy and cross-zonal capacityOur response sets out how the required volumes for determining Energy Company Obligation targets can be obtained from existing data flows, and where the consultation has incorrectly identified Consumption Component Classes relating to domestic consumption.
Elexon’s response to Ofgem’s consultation on Energy Company Obligation (ECO3) methodologies for calculating electricity and gas supply volumesOur response sets out how a BSC-based solution would work to enable fixed residual charges. We also note a number of areas which we believe require further consideration before Ofgem makes its final decision on its Targeted Charging Review proposals. These are Timing, Interaction with other projects – Ofgem should take opportunities, where possible, to develop common ‘whole system’ solutions and to minimise the risks of competing projects and
Definitions
In our response to Ofgem’s consultation, we concentrated on the design of the ESO incentives with two key messages: first, that the incentives should encourage ESO to work jointly and collaboratively with Elexon for maximum customer benefit. Secondly,
that the incentive reporting should allow us to compare our own code management performance with that of others, including ESO.
Our response welcomes the new flexibility commitments from network companies and suggests they attempt to mark progress against these commitments, as well as map them to other initiatives to support flexibility announced over the past year.
Response to the Energy Networks Association’s consultation on FlexibilityOur response highlights the need for further clarity around the definition of Energy Efficiency measures. We note that non-controllable demand reduction measures should be encouraged by market signals such as Time of Use Tariffs, whilst active technologies can respond to active signals, such as those used in the Capacity Market.
Elexon’s Response to BEIS’ Call for Evidence on Facilitating Energy Efficiency in the Electricity SystemOfgem and BEIS published their consultation on reforming the energy industry codes in July 2019, and we have published our response.
We continue to strongly support reform of the code arrangements, in particular the objective of consolidation and simplification.
Ofgem and BEIS want to deliver improvements to the codes and code governance arrangements by the mid-2020s and ELEXON will support them in doing so.
Elexon’s response to Ofgem/BEIS consultation on reforming energy industry codesOur response highlights our support for innovation and provides examples of innovation we have spoken to customers about. We requested that government and Ofgem are mindful of other industry change programmes, including the review of codes, when considering further changes to retail markets.
Elexon’s response to Ofgem/BEIS consultation on Flexible Retail MarketsOur response challenges OLEV’s rationale for producing a Phase 2 decision in 2023, noting that there are EV demonstration projects that will run into 2021 and the Smart Meter rollout and MHHS which are not likely to conclude until 2023-24 . Secondly, we found OLEV’s separation of public and private use cases overly simplistic, noting that there are public and private use cases that share characteristics, and could benefit from common solutions. Finally, we encourage OLEV to consolidate its and industry’s work on EVs, e.g. through the adoption of a single repository of EV issues and proposals, to facilitate holistic policy design and the identification of overlap.
Elexon’s response to the DFT’s consultation on Electric Vehicle Smart ChargingIn our response to ENTSO-E’s consultation, we concentrated on a single aspect:
Whether the proposed wording for the templates would be sufficient to encourage TSOs and ENTSO-e to consider the impact that the operation of national rules for market suspension and of European rules for market de-coupling could have at both national and regional levels in each crisis scenario?
Elexon’s response to the ENTSO-E Consultation ‘Risk Preparedness Regulation’The archived responses below are organised based by the organisation who published the initial consultation or review. If there is an archived Elexon consultation you cannot find, please email [email protected].