AUG Query Responses 21st November 2013 Overview • AUGE Guidelines require AUGE to report outcome of Query Process to UNCC • UNCC to consider AUGE recommendations • UNCC to endorse AUGE’s recommended course of action or vote unanimously to reject (see section 8 of the AUGE Guidelines for details) • Presentation covers two sets of queries • ICoSS response on 23rd October 2013 • British Gas response on 13th November 2013 • Update on iGT CSEP volume error ICoSS – Query 1 • Modification 410A • Introduces improvements to handling of unregistered sites and better control of the MPRN creation process • Response • • • • • Changes the way unregistered sites handled – specifically <12 months category Expect to see declining levels of permanent UG for unregistered sites during 2014/15 AUG Methodology requires update to reflect this Impact is material and will reduce permanent UG for these categories Volume and rate tables will need to be updated • Query classed under 8.5 as “Material and can be implemented for final AUG table” • Subject to previous agenda item regarding mismatch between UNC and AUGE Guidelines ICoSS – Query 2 • Mod 431S and SPA MAM 13/002 • Mod 431S introduces a portfolio reconciliation between Shippers and Transporters which will help identify potential unregistered sites • SPA MAM 13/002 introduces restrictions to stop meters being fitted without a supply contract • Neither have been implemented and therefore cannot be incorporated into the methodology or figures for 2014/15 • Impact of 431S cannot be assessed until the portfolio reconciliation occurs in any case • Query classed under 8.4(a) as “Requiring no action” ICoSS – Query 3 • Mod 424 – re-establishment of Supply Points • This modification reduces occurrence of shipperless sites • The effects of this modification have already been documented in the 2013 AUGS for 2014/15 and included in the calculation of interim rates and volumes • Query classified under 8.4(a) as “Requiring no action” ICoSS – Query 4 • Impact of data quality • ICoSS raised various concerns about data quality and suitability for AUG calculations • No specific issue was raised or estimation of impact it would have • Response highlighted improvements in 2013 to address data quality issues • Data quality issues have been highlighted previously and this is therefore not a new Unidentified Gas issue per se • If specific issues are highlighted then we could investigate them • Query classed under 8.4(a) as “Requiring no action” British Gas - Query 1 • Allocation issue • Discrepancy identified in Allocation totals used in calculation spreadsheets • Identified issue with EWCF used when calculating seasonal normal allocations • Updated data not included in all calculations • This needs to be corrected and volumes/rates table updated accordingly • Nearest classification is under 8.5 “Material change that can be implemented for final gas volumes and rates” – it does not require a change to the AUGS British Gas - Query 2 • Concerns the calculation of the forward estimate of UG • Query relates to the use of the balancing factor from the historical period rather than calculating it by difference for the forecast year • We believe this is a misunderstanding of the process • The AUGS could be clearer on how the forward calculation works • If calculating by difference for forward years, any UG improvement initiatives only get converted to balancing factor (mainly theft) which would be incorrect • Recommend additional clarifications added to AUGS to show how each UG segment is extrapolated from historic to forecast years • Query classified as “8.4(b) requires a change to the AUGS but does not have material impact on volumes/rates” • Subject to previous agenda item regarding mismatch between UNC and AUGE Guidelines British Gas - Query 3 • Concerns the suspected erroneous inclusion of large sites in Unregistered / Shipperless UG calculations • Also queried the 5x multiplier for derivation of temporary UG • Misunderstanding of the use of flags in spreadsheets • Data not removed, but flagged for investigation. • “Remove” flag is used when calculating average LSP AQ to avoid skewing the average • The derivation of the 5x factor is also noted in query response and it is a coincidence that it is a whole number • More details provided in response • Query classed under 8.4(b) as “Requiring no action” British Gas - Query 4 • Concerns exclusion of large sites >58GWh pa when producing AQ scaling factors for shipperless/unregistered sites • Response clarifies process and why sites left out as appropriate • Noted insufficient evidence to assume that all large sites will always be revised downwards • Summarised key process steps for clarification • Query classified under 8.4(b) as “Requiring no action”. British Gas - Query 5 • Concerns CSEP consumption not being adjusted for sites with AQ>1 not consuming, resulting in under-estimate of UG • We note that there is also the opposite issue of not adjusting consumption for sites where AQ=1 that are consuming resulting in a potential over-estimate of UG • CSEPS were adjusted for both situations in an early draft of the AUGS • During the year we identified that CSEP EUC bands were based on max AQ • CSEP EUC banding therefore unreliable • Latest AUGS estimates CSEPs consumption based on average aggregate AQ • This is therefore not a new issue and has already been through consultation during the year • Query classified under 8.4(b) “Requiring no action” iGT CSEP Volume Issue update • • • • • A large iGT CSEP has calculated volumes incorrectly This may or may not have a material impact on UG – no data provided to assess We understand the issue has been corrected going forward The effects are inherent in the interim AUG table Likely to be small • CSEPS account for a small % of demand • This is just one part of that market • Issue concerns a subset of the portfolio • We understand that we are unlikely to get corrections until after the final AUG table has been prepared Next Steps • Deal with any further queries or rejected queries from this meeting • Prepare final AUG table for Gas Transporters on or before 1st January 2014 Thank you for your attention