Bristol Water : MAP2
Response, Queries and
Comments
January 2015
Bristol Water Non-Household Retail Separation Programme
Comments Table
Company Name…Bristol Water
#
1
2
2
Document in the
MAP/High Level
Area
Operational Code
(app3_part3_operatio
nalterms)
Operational Code
(app3_part3_operatio
nalterms)
Section of the
Document / Topic
2.5
A1, A5
Issue
Comment
Urgent Definition of SLAs
and Penalties for Failure
required.
In the Dec 11 2014 release of the
MAP 2, the Operational Code
(section 2.5) specifies Service
Standards and penalties for failing
to comply. However, these will not
be fully defined until Q1 2015 at
the earliest . This is essential in
defining the KPIs and reports
needed by BW.
Operational Code does not
always state whether SLAs
are Business or Calendar
Days.
The Operational Code is not
specific on whether the SLA for
actioning an item is in Calendar
Days or Business Days. Scottish
code was originally Business
Days, then Draft English
Operational code changed this to
Calendar Days, now the released
December version does not state.
For example. the SLA for a
Wholesaler to respond to a Preconnection enquiry in Process A1
is stated as simply being 12 days.
This needs to be clear for ALL
Answer
Bristol Water Non-Household Retail Separation Programme
#
Document in the
MAP/High Level
Area
Section of the
Document / Topic
Issue
Comment
processes and also needs to be
aligned with Water UK
requirements recently issued.
3
4
3
Operational Code
(app3_part3_operatio
nalterms)
Operational Code
(app3_part3_operatio
nalterms)
A1
F4, (and E3?)
Does the clock stop when
requesting more information
from Retailers/NHH
Customers ?
24/7 customer contact to
retailers will require the
Wholesale Service Desk
facility to be 24/7 – can we
use our current Ops Room to
deal with all queries both HH
and NHH
In many processes (e.g. A1 Preconnection enquiry) the
Wholesaler can request that the
Retailer or NHH Customer submit
more information. Does the clock
stop whilst waiting for the
response and restart when it is
received and would the SLA start
from scratch ?
what about water quality issues?
The draft rules say that the wholesaler
function and retailer must collaborate
to provide a 24 hour, 7 day a week
contact centre. However, the general
public will not know whether to call a
Retailer or Wholesaler, so they will
only be able to call a single number,
used for both Household and NonHousehold premises.
Answer
Bristol Water Non-Household Retail Separation Programme
#
5
6
4
Document in the
MAP/High Level
Area
Market Operator
procurement and
setup
Operational Code
(app3_part3_operatio
nalterms)
Section of the
Document / Topic
NA
A1, A2, A3, A5
Issue
Comment
There is still ambiguity
around the procurement and
operation of this entity which
could cause delays to the
programme
When will this be resolved?
Developer services clarity
needed – reference to Ofwat
to clarify
How does the Ofwat work dovetail
into OpenWater from a timing and
responsibility perspective ? When
will clarity be provided on how
developer services will fit into the retail
market? It is now being suggested
that developers will be able to interact
with wholesalers and not retailers after
all – is this correct? If not and nonhousehold retailers are to provide
retail services to developers, will all
non-household retailers have to
provide these services? Who will pay
the non-household retailers for these
services? Will new homes have to be
registered with the MO on the basis of
the developer being non-household
and then de-registered when a
householder moves in, or will new
Answer
Bristol Water Non-Household Retail Separation Programme
#
Document in the
MAP/High Level
Area
Section of the
Document / Topic
Issue
Comment
homes be non-contestable? (PM)
7
Operational Code
(app3_part3_operatio
nalterms)
A5
Two year validity of
connection offer
Where the Retailer has accepted
the offer for connection as set out
in the process, in the case of the
connection to a Mains/Sewer
Requisition connection
accompanied by at least one
Individual connection, the offer will
remain valid for a period of two
calendar years from the date of the
connection offer.
Currently, all BW offers are, at
best, valid for a year and end in
April due to new charges that
apply.
8
Operational Code
(app3_part3_operatio
nalterms)
9
B1
Operational Code
5
B5, B7, B10
Is there a need to inform
Retailer of the new Meter
Installation Details ?
As well as the MO, should the
Wholesaler inform the Retailer of
the Meter Details (opening and
closing reads, serial numbers,
locations etc) ?
How will the Wholesaler
know if the Retailer will use
In December 2014 release of Op
Code, there is no specific
instruction from the Retailer,
Answer
Bristol Water Non-Household Retail Separation Programme
#
Document in the
MAP/High Level
Area
Section of the
Document / Topic
(app3_part3_operatio
nalterms)
10
11
Operational Code
(app3_part3_operatio
nalterms)
Operational Code
(app3_part3_operatio
nalterms)
12
F5
D4, E3
Operational Code
(app3_part3_operatio
6
A1
Issue
Comment
an Accredited Entity ?
following receipt of the
Contribution Offer, that the
Wholesaler should proceed with
the installation. If they don't send
this how will the Wholesaler know
to proceed ?
The December release of the
Operational Code is confusing
over its use of Form E to be the
initial method of making a preconnection enquiry and also as a
need to respond to the
wholesaler's request for a
Development Impact Assessment.
Confusion over initial form
submission
Why should the Wholesaler
Respond to NHH Customer
Complaint ?
Is Form E used in both situations
and if so, how does the second
use differ from the first ?
Why does the Wholesaler respond
directly to the NHH Customer ?
Shouldn't this go through the
Retailer ??
The Wholesaler is tasked with the
Wholesaler has to coordinate
responsibility of coordinating
contact between multiple
contact between Retailer(s) and
external parties – how
Environmental Health. What will be
Answer
Bristol Water Non-Household Retail Separation Programme
#
Document in the
MAP/High Level
Area
Section of the
Document / Topic
nalterms)
13
14
15
16
7
Operational Code
(app3_part3_operatio
nalterms)
Operational Code
(app3_part3_operatio
nalterms)
Operational Code
(app3_part3_operatio
nalterms)
Operational Code
(app3_part3_operatio
nalterms)
Issue
should this happen ?
E2a
How will emergency planning
consultation be done ?
D1, D2, D3, D4
What mechanism will be
used to publish Short/Long
term/Water Resources plans
?
C1
Are Sewerage Retailertriggered processes relevant
for a WOC ?
B3
Why does the Wholesaler
have to inform the NHH
Customer of Meter Accuracy
Test results ?
Comment
the mechanism for this three-way
communication ? Who will chair it ?
How will information be passed
between the parties ?
How will the consultation between
the Wholesaler and the Retailer
regarding Emergency Planning be
done ?
Will it be more formal than a
conversation ?
Do OpenWater have any
requirements on how this is done ?
Operational Terms state/strongly
imply that a Sewerage Retailer can
request a Water Wholesaler
engage in Verification of Meter
Details – is this true for a WOC ?
Shouldn’t the Retailer be
responsible for this communication
?
Answer
Bristol Water Non-Household Retail Separation Programme
#
16.2
17
18
19
Document in the
MAP/High Level
Area
Operational Code
(app3_part3_operatio
nalterms)
All
Operational Code
(app3_part3_operatio
nalterms)
Operational Code
(app3_part3_operatio
nalterms)
20
Operational Code
(app3_part3_operatio
8
Section of the
Document / Topic
Issue
B3
Can the Wholesaler charge
for a meter accuracy test that
proves the meter was
accurate ?
All
Revisions are not change
marked – all future changes
from the Baselined
December version should
be.
C7
There is no reference to a
Wholesaler being able to
charge for a Site Visit for a
VOA BA check
E4
Pollution Incident requiring
All Retailers to be informed
has been removed ?
F1
Do all visits for Water
Sampling have to be notified
retrospectively within 1 day ?
Comment
BW have a charge for this
currently, but the ops code does
not state that the Wholesaler can
do this.
This means that a lot of time is
spent reviewing the whole
document to see what has been
changed.
This was allowed in the November
version, but has gone from the
December 2014 release. Why
can’t the Wholesaler invoice for
this work ?
In the November release of the
Operational Code, there was a
requirement to notify all retailers of
a pollution incident. This has been
removed from the December
release - why is it no longer
required ?
The Operational Rules imply that
all visits that have not been
notified to the Retailer need to
have a post-visit notification sent -
Answer
Bristol Water Non-Household Retail Separation Programme
#
Document in the
MAP/High Level
Area
Section of the
Document / Topic
Issue
Comment
Companies need a full
specification on what the
scope and expectations are
for this.
does this really apply to all Water
Sampling and Regulation checks ?
If so, this is prohibitively onerous.
Needed to plan for, and allocate,
sufficient resources and fully
understand the work involved in
this stage of the programme.
nalterms)
21
22
23
9
High Level
Programme Plan
Operational Code
and Market Code
(app3_part3_operatio
nalterms and
app3_part4_marketterms)
Shadow Operation
All
F3
What are the standard set of
statuses that need to be
reported for each process ?
No mention of operational
issues to be informed to all
To promote consistency of
operation and provision of
information, OpenWater should
define the status life-cycle that is
the minimum that should be
reported for each process in the
Operation and Market terms. This
has a significant impact on the
system and business process
changes required of all companies,
and needs to be designed and
built at an early stage of the
project.
Without this, it is likely that the only
statuses that will be reported are
‘Initiated’, In Progress’ and
‘Complete’, which are of little
value.
In the November issue of the
Operational Terms, if the
Answer
Bristol Water Non-Household Retail Separation Programme
#
Document in the
MAP/High Level
Area
Section of the
Document / Topic
Operational Code
(app3_part3_operatio
nalterms)
24
Operational Code
(app3_part3_operatio
nalterms)
F5 (Step 4)
Issue
Comment
Retailers
Wholesaler visited an Eligible
Premise and found urgent
operational issues, it was required
to contact ALL Retailers that may
be affected. This has been
removed from the December 2015
version. Is this requirement no
longer needed ?
December Operational Terms
state "Where any compensation or
other payment is due from the
Wholesaler to Retailer, the
Wholesaler will pay any such
compensation or other payment to
the Retailer."
Why does the Wholesaler
have to pay compensation to
both Retailer and NHH
Customer ?
It also says “The Wholesaler shall
also pay any compensation or other
payment which is due from
the Wholesaler to the Retailer’s NonHousehold Customer to the Retailer
and the
Retailer will pass that compensation
or payment on in full to the NonHousehold
Customer.
“
Why does the wholesaler have to
10
Answer
Bristol Water Non-Household Retail Separation Programme
#
25
Document in the
MAP/High Level
Area
Operational Code
(app3_part3_operatio
nalterms)
Section of the
Document / Topic
Issue
F6
Will Retailers have the
knowledge to respond to
Water Fittings Enquiries ?
26
Market Code
(CSD0301)
T109.5
Why would the Other
Wholesaler receive a
notification of receipt/error ?
27
Market Code
(CSD0301)
T113.0, T114.0
Does not follow the naming
convention for transactions
from Wholesaler to MO.
28
Market Code
(CSD0301)
T123.3
29
Market Code
(CSD0301)
11
T123.3 and others
Comment
pay compensation to BOTH the
Retailer and the NHH Customer
(via the Retailer) ?
Are there potential problems if a
Retailer is able to respond to a
Water Fitting Enquiry ? (Ask Water
Regs if they are worried about
this).
Does this transaction relate to a
flow sent by the Original
Wholesaler or the Other
Wholesaler if there are two
Wholesalers for a split
Sewerage/Water SPID site ?
Should this be T113.3 ? Same
goes for T114.0
Is this transaction to be sent How will one know the identity of
by the Sewerage Wholesaler the other as they are independent
or Water Wholesaler ?
companies ?
What are the responsibilities for
Will any transaction that
Water Wholesalers related to
relates to a Discharge Point
Discharge Points ? It is assumed
be relevant for/need to be
that any transaction related to
sent by a Water Wholesaler
Dishcharge Points and Trade
Answer
Bristol Water Non-Household Retail Separation Programme
#
Document in the
MAP/High Level
Area
Section of the
Document / Topic
Issue
?
30
Market Code
(CSD0301)
Txxx.5 and Txxx.7
What relevance do ‘Other
Wholesaler’
transactions
(those identified by a .5 or .7
suffix) have to a Water Only
Company Water Wholesaler
?
31
Market Code
(CSD0301)
T149.X
Is this notification from the
MO relevant to Water
Wholesalers ?
32
Market Code
(CSD0301)
T157.0
Should this be sent to the
Retailer
and
not
the
Wholesaler as stated ?
33
Market Code
(CSD0301)
T158.3, T159.3,
T163.3
Market Code
(CSD0301)
T117.0, T117.1,
T117.3
34
12
Comment
Effluent are not relevant for a
Water Only Company Water
Wholesaler – is this correct ?
Will a WOC Wholesaler
received/send these ?
Can more detail be given as to the
situations in which a Water
Wholesaler will receive
transactions as the ‘Other
Wholesaler’ and what they should
do with them ?
Not clear from the CSD. 149.3 is
from the Water Wholesaler so the
assumption is that the WS will not
receive a 149.5 ?
Naming convention (.0 suffix)
implies this transaction should be
sent to the Retailer. (see page 67
of CSD0301)
Is this relevant for a Water Or is it only suitable for a
Sewerage Wholesaler as it is
Wholesaler ?
about Drainage/Surface Water ?
Referring to the SPID but using the
Reference to D3001 should
incorrect data item ID – D3001 is
be D2001
the Meter ID, D2001 is the SPID
Answer
Bristol Water Non-Household Retail Separation Programme
#
Document in the
MAP/High Level
Area
Section of the
Document / Topic
35
Market Code
(CSD0301)
T123.3
Is this transaction only Will the Water Wholesaler know
relevant for the Sewerage the related DPID (Discharge Point
Wholesaler ?
ID) of a SPID ?
Issue
Comment
36
Market Code
(CSD0301)
T133.5
What do Water Wholesalers
do if they do not differentiate
connections
between
Building Water and Potable
Water ?
37
Market Code
(CSD0301)
T134.3
Can we have examples of It is not clear how these are to be
the Cryptographic Hash and generated and used.
Algorithm fields ?
38
Operational Code
(app3_part3_operatio
nalterms)
B3
There is no evidence of the
Wholesaler being able to
charge Retailers for Meter
Accuracy Tests
39
Operational Code
(app3_part3_operatio
nalterms)
I3
What actions can be taken
against a Retailer if there
has been illegal use ?
13
Will this transaction be needed ?
BW do not enable connections for
‘Building Water’ – they are the
same as any other connection.
In the current BW charges
scheme, the Wholesaler may
charge a fee of £70 + vat for any
meter accuracy test where the
meter is found to be accurate. This
is not detailed in the Operational
Code.
The Ops Code say there may be
reasons why the Retailer is
responsible but does not define
the actions that can be taken
against the Retailed by the
Wholesaler.
Answer
Bristol Water Non-Household Retail Separation Programme
#
40
41
42
Document in the
MAP/High Level
Area
Operational Code
(app3_part3_operatio
nalterms)
Operational Code
(app3_part3_operatio
nalterms)
Operational Code
(app3_part3_operatio
nalterms)
43
Market Code
(CSD0301)
44
Market Code
(CSD0301)
14
Section of the
Document / Topic
Issue
Comment
I5
Should it include the ability to
There is no ability for the
cancel the disconnection ?
NHH Customer or Retailer to
cancel the disconnection
(unlike I1).
I11
This reconnection process Can the Wholesaler charge for any
specifies that the Wholesaler reconnection it does (at least I8
can make a charge for and I10) ?
reconnecting a site - why do
the
other
reconnection
processes not state this ?
I11
The
timeframe
for
reconnection is stated as ‘As
soon as practicable or as
requested’ – this is different
to
other
reconnection
processes.
Other process state the
reconnection should be done
either the next business day or the
same business day depending on
whether the request is received
before 3pm.
As it relates to discharge points,
Is this relevant for a WOC what should a Water Wholesaler
D2003_Schedule3
populate this field with, particularly
Wholesaler ?
when it is defined as a mandatory
field ?
from
what If a Water Wholesaler needs to
D2004_ExemptCusto Exempt
components ? Is this only populate this, how should it
merFlag
relevant for population by determine the value (which is only
Answer
Bristol Water Non-Household Retail Separation Programme
#
Document in the
MAP/High Level
Area
Section of the
Document / Topic
Issue
Retailers ?
45
Market Code
(CSD0301)
D2005_CustomerCla
ssification
46
Market Code
(CSD0301)
D2008_SICCode
47
Market Code
(CSD0301)
D2011_RateableValu
e
48
Market Code
(CSD0301)
D2014_FarmCroft
49
Market Code
(CSD0301)
D2018_TroughsDrin
kingBowls
15
Comment
True (1) or False (0)
What criteria should a Water Should it only be populated by
Wholesaler use to determine Retailers ?
this classification ?
BW use the 2004 version of Will the MO be using a different
SIC codes. Is this sufficient version set of the SIC codes ? If
so, how will it resolve
for the MO ?
incompatibilities ?
Do Wholesalers need to If so, what should a Wholesaler
populate this as it is billing use to populate it ?
data (and therefore a
Retailer responsibility) ?
How should Wholesalers
determine this ?
BW
cannot
distinguish
between
Troughs
and
Standpipes – what impact
The SIC code may help, but
should a valid set be specified by
OpenWater so that everyone
populated data in the same way.
For instance, SIC Codes 0111 to
0113 all relate to growing crops, so
should be described as a ‘Farm’
but what about 0502 – which is a
Fish Farm ? Also, there are no
codes to identify Crofts.
What will be the effect on the MO
and other participants if Troughs
and Standpipes cannot be
Answer
Bristol Water Non-Household Retail Separation Programme
#
Document in the
MAP/High Level
Area
Section of the
Document / Topic
Issue
will this have ?
50
Market Code
(CSD0301)
differentiated ?
D2024_Unmeasurabl
e
Could
clarification
be This is most likely to be a Retailer
provided on what this is and data item, so how should a
how it should be populated ? Wholesaler populate it ?
D2025_Notify
Disconnection/Reco
nnection
On Go Live, there may be a
number of SPIDS that are under a
Temporary Disconnection. Can
this be clearly definded and how
What are the expectations
should a Wholesaler notify this on
for the population of this item
initial data take-on ? (Other values
for initial data take-on by the
of REC, PDISC and DREG are
MO ?
assumed not to be relevant for
initial data take-on and only have
meaning transactionally once the
market is live ?)
51
Market Code
(CSD0301)
52
Market Code
(CSD0301)
D2026_EWA
53
Market Code
(CSD0301)
D2027_CustomerNa
me and D5001 to
D5013 (Address
fields)
16
Comment
If so, how should it be derived ?
It
is
assumed
that
(EWA = Estimated Weighted
Wholesalers will not populate
Average – a value used in
this item.
Settlements)
Surely they are only relevant once,
Why are these fields needed
for the SPID, not the meter ? If
at both SPID level and Meter
they are relevant for the meter,
Level ?
how will they differ ?
Answer
Bristol Water Non-Household Retail Separation Programme
#
Document in the
MAP/High Level
Area
Section of the
Document / Topic
54
Market Code
(CSD0301)
D3011_MeterReadFr
equency
Issue
Comment
The assumption is that this is There is only a B (Bi-annual) and
a Retailer data item, but why M (Monthly) option. Should
is there no Quarterly option ? Quarterly be added ?
55
Market Code
(CSD0301)
D3010_MeterReadTy
pe
Is
it
the
Retailer’s
responsibility to provide all
readings at initial data takeon ?
56
MAP2 (John Vinson
q1a)
Debt Tools
Separation of Supplies (Joint
HH and NHH)
It is assumed that the Wholesaler
will not need to provide this data
unless they change a meter
themselves – in all other
situations, the Retailer should
provide this. What value should be
used for initial data take-on if
relevant ? If not relevant, how will
the MO calculate consumption
when the next reading is sent in ?
A single supply to a premises may
be used jointly by HH and NHH
customers at that premises. There
may be difficulties if the NHH
customer is a bad debt to the
Retailer and yet the Retailer is
unable to take action or request
the Wholesaler to disconnect the
NHH element as the HH element
would also be affected.
This results in the Retailer not
being able to recover the cost of
water supplied but still having to
17
Answer
Bristol Water Non-Household Retail Separation Programme
#
Document in the
MAP/High Level
Area
Section of the
Document / Topic
Issue
Comment
pay the Wholesaler for that water
through the Settlement process.
57
MAP2 (JV q1b)
Debt Tools
Will the Wholesaler be expected to
perform disconnections in all
circumstances, regardless of cost
or practicality or will they also be
exposed to the bad debt if the
Settlements process excludes this
NHH customer ?
The Retailer might want to ask the
Wholesaler to perform
disconnections at very specific,
business dependent times. (e.g.
between 8-10pm for a nightclub,
or lunchtime for a pub, to impact
Timing and duration of
the business and encourage them
temporary disconnections
to pay).
What are the bounds of the service
that the Wholesaler can/must offer,
and can this vary between
Retailers ?
58
18
MAP2 (JV q2a)
Financing
Effect of escrows, LoC's etc. Current plans require a Retailer to
on both the company and the place a substantial amount of
money into an escrow account to
market
protect Wholesalers from Retailer
Answer
Bristol Water Non-Household Retail Separation Programme
#
Document in the
MAP/High Level
Area
Section of the
Document / Topic
Issue
Comment
bad debt. Some Retailers are
suggesting the level of escrow isn’t
viable, particularly for smaller
Retailers or new entrants, and may
be looking for a different solution.
What options are being considered
by the programme, if any, and
what effect will these have on
Wholesalers ?
59
MAP2 (JV q2b)
Financing
Settlement Process
Some Retailers are suggesting
that the settlements process
places all the risk on them and
none on the Wholesaler. There is
a view that the process is overly
complicated, expensive and
difficult to administer.
Is the programme considering any
alternatives that may impact the
Wholesaler ?
60
19
MAP2 (JV q2c)
Financing
Margins
Some Retailers have a view that
the Retail Margin is too low to be
viable. Incumbent companies may
struggle to provide the people,
systems and services that NHH
Answer
Bristol Water Non-Household Retail Separation Programme
#
Document in the
MAP/High Level
Area
Section of the
Document / Topic
Issue
Comment
Customers require at the price
they are allowed to charge. This
situation may also be a barrier to
entry for new Retail participants.
Are there any plans to change the
Gross Margin calculations and
limits, and how might these impact
the Wholesaler ?
61
MAP2 (JV q3a)
Products
The requirement to publish all
details of deals negotiated by
Retailers can be seen as stifling
innovation of products and
services that could be offered. This
is because other companies will
Publication of standard and benefit from months of
non-standard products – negotiations that one Retailer may
have had to reach the point of
effect on innovation
providing a non-standard service.
This might also apply to
Wholesalers wishing to do the
same thing as other companies
can steal the ideas.
Therefore, there is no incentive to
be innovative which is detrimental
20
Answer
Bristol Water Non-Household Retail Separation Programme
#
Document in the
MAP/High Level
Area
Section of the
Document / Topic
Issue
Comment
to the success of the market.
62
MAP2 (JV q4a)
Metering
Replacement of old meters
What are the programme’s views
on this ?
Retailers may wish to have
stronger mechanisms for ensuring
that meters are replaced in a
timely fashion. Currently, the
Operational Codes do not
incentivise the Wholesaler to do
this, and even act as a disincentive
to Retailers to request changes or
accuracy tests due to charges that
may be imposed upon them.
The Wholesaler would wish to get
the maximum life from its asset to
ensure cost-effectiveness, so does
the programme have any plans to
force Wholesalers to change
assets more frequently or penalise
Wholesalers for late replacement
or meter reading inaccuracies ?
63
21
MAP2 (JV q4b)
Metering
Retailers may request a greater
Meter Types permitted by
range of meter types and
Wholesalers
capabilities than a Wholesaler is
willing to offer. This is because the
Answer
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Comment
Wholesaler is more interested in
lifespan and ease/frequency of
maintenance, whereas Retailers
would prioritise functionality over
longevity. How can these
conflicting priorities be balanced ?
What are the obligations with
which a Wholesaler must comply
as a minimum and what scope do
they have for limiting the range of
meters they are prepared to fit ?
What control does a Wholesaler
have over a meter fitted by an
Accredited Entity ?
64
MAP2 (JV q4c)
Metering
65
Securities and
Emergency Planning
Martin Harvey
22
What are the obligations on a
Wholesaler to install meters that
are compatible with Retailer’s data
of
loggers and AMR equipment ?
What are the implications on the
Wholesaler if they do not reinstate
Retailer equipment properly ?
Removal/Reinstatement
loggers/smart meters
Regarding
the
Contingencies Act:
Civil
Is
a
The definition of a Cat 2 responder in
the Utilities sector is: A water
undertaker or sewerage undertaker
Answer
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retailer a Cat 2 responder?
Group
Securities and
Emergency Planning
Group
Martin Harvey
66
Securities and
Emergency Planning
Group
Martin Harvey
67
Securities and
Emergency Planning
Group
65
Issue
Comment
appointed under section 6 of the
Water Industry Act 1991 (c. 56). By
way of comparison, in the electricity
sector it is an organisation holding a
transmission licence, a distribution
licence, an interconnector licence. In
the telecoms sector it is a person who
provides
a
public
electronic
communications network which makes
telephone services available (whether
for spoken communication or for the
transmission of data). This would
seem to be just ‘wholesalers’
Will Retailers attend LRFs ? Retailers as Cat 2 responders or not
How
will
multi-agency will or should have a duty to share
information and plans.
incidents work
Will Retailers or Wholesalers take the
lead?
Martin Harvey
Will Retailers have lists of
Vulnerable
people,
Care
Homes, Prisons, Hospitals etc
Will the Retailer have to share details
with the Wholesaler?
Does SEMD and in particular
AN/9 sit with the Wholesaler,
Retailer or both?
It would appear that Wholesalers will
solely retain SEMD – if this is so the
following questions need clarification:
a) Retail providers will be consulted
23
Answer
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Comment
but do they have any powers to
change arrangements?
b) Do Retail providers have a seat at
Gold command and so give the
customer a presence?
c) Do Retail providers need to
produce SEMD plans?
d) When can wholesale access
customer information – at
planning or incident phase?
e) In a non SEMD event how will
Wholesale identify vulnerable
customers?
How does Retail get involved in the
boil water etc notice process?
68
24
Securities and
Emergency Planning
Group
Martin Harvey
Will Retailers always be the first
port of call for the customer
24/7?
In theory the billable customer is the
Retailer and the Wholesaler will have
lost its links with the real customer. In
practice I suspect the real customer
will make the call to the Wholesaler particularly OOH unless all Retailers
operate a robust 24/7 call centre.
Clearly some can and will, others
Answer
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Comment
won't.
The scenario I envisage would be that
a real customer will phone the
Wholesaler; at this point the
Wholesalers have to decide if they will
take instruction etc from an end user
rather than their Retail customer.
69
70
25
Securities and
Emergency Planning
Group
Securities and
Emergency Planning
Group
Martin Harvey
Martin Harvey
Will landlords for social housing
be water retailers?
Will GSS / DG penalty
payments go to the retailer or
the customer?
Presumably if an occupant from a
social housing high rise block of flats
said their water supply was suspect,
tastes funny or has poor pressure one
of the first things the WASCo would
do would be to say report it to your
landlord, a retailer by any other name
?
Lets suppose the Operations issues
being dealt with by the Wholesaler
and warranting SEMD support are
also GSS / DG penalties, then
ironically the penalty payment will go
from the Wholesaler direct to the
Retailer. The Wholesaler won't have
any say in whether the end user ever
Answer
Bristol Water Non-Household Retail Separation Programme
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Document in the
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Comment
sees this payment.
The Scottish Model Operational
code: Process 21 – Emergency
Activities, Step 1, Bullet 3 states:
71
Securities and
Emergency Planning
Group
72
Securities and
Emergency Planning
Group
73
26
Securities and
Emergency Planning
Group
Martin Harvey
Martin Harvey
Martin Harvey
“the Emergency Plans will
specify the agreed role of the
Licensed Provider in the
implementation of the
Emergency Plan”
Will the Retailer and Wholesaler,
require a degree of technical
expertise?
For quality incidents there are
thresholds
(all
be
they
hopelessly broad) but not for
sufficiency, yet its sufficiency
that exercises LRF partners and
customers more.
I would say that this sort of description
should be avoided where possible as
you will have Licensed Providers and
Companies
potentially
agreeing
different responses / responsibilities
both in and out of single company
supply areas, such that it will be
difficult to manage to say the least in
that you will not know what response
you are applying for which Licensed
Provider / non-household customer. It
is currently chaotic enough in Incident
mode
with
a
combined
Wholesaler/Retailer. This requires
legislation to ensure uniformity of
response.
Should we assume that both parties
are professional and responsible
organisations who we can trust? Will
this be legislated for?
Will this remain at AN/9 levels for the
Wholesaler or will there be different
thresholds for the Retailers?
e.g. if the Wholesaler has a 20,000
population threshold and has an
incident already in process this may
leave the retailer with no support –
Answer
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Comment
Answer
unless they have to prepare under
SEMD to cover a percentage of their
customers
74
75
Securities and
Emergency Planning
Group
Review of Scottish
Model Operational
Code
Martin Harvey
Will Retailers have to emulate
the customer service provided by
the Wholesaler?
Will there be a legislated minimum
standard of response, recovery,
sufficiency quality etc
Section 20/21/21A Martin Harvey
There are a questions regarding
the Scottish Model (Sections 18,
20, 21, 21A). (pages 3 – 6 of
Martin’s document)
Are these still relevant given the latest
release of MAP2 that have converted
the Scottish Model into a revised
English Model ? Martin should review
his comments in light of these new
processes.
E1, E2, E3 (MH)
Wholesaler, Retailer and Civil
Contingencies Act partners will
all need to interact, but would
need clarity of interfaces and
triggers and some background
risk assessment
Emergency
planning
requires
extensive interaction between multiple
parties that is not fully described.
E1, E2, E3 (MH)
Issues caused by a lack of a
single standard interface for all
Retailers to use for all areas for
Emergency Planning, Declaring
and Implementation.
For water/ww issues this would be a
‘one to many’ activity from wholesaler
to all retailers they serve (or vice
versa – would a retailer seek common
interfaces with all their wholesalers?)
76.1
Operational Code
(app3_part3_operatio
nalterms)
76.2
27
Operational Code
(app3_part3_operatio
nalterms)
MG to review English
Operational Processes
with MH then decide
what questions are
outstanding.
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Partners would expect complete
joined up water sector and
minimum number of partners to
directly engage with.
76.3
76.4
76.5
28
Operational Code
(app3_part3_operatio
nalterms)
Operational Code
(app3_part3_operatio
nalterms)
Operational Code
(app3_part3_operatio
nalterms)
E1, E2, E3 (MH)
E1, E2, E3 (MH)
E1, E2, E3 (MH)
How would a Wholesaler identify
priority customers as the Retailer
has this data ?
Who do partners like the CCA
interact with for issues relating to
key customers (hospitals, major
manufacturer etc) ?
Comment
Assuming Retailers are not Cat 2
responders.
Could be multiplicity of Wholesalers in
a LRF area . Civil Contingencies Act
principles assume agencies act
outside the sphere of their strict
commercial interest, e.g. sharing data
on
organisational/infrastructural
vulnerabilities. How will this be
ensured given the separation of
Retailer and Wholesaler and the strict
responsibilities of dealing with the
NHH Customer ?
How does Wholesaler develop a
prioritised list of vulnerable customers
for provision of alternative supplies?
Do partner agencies liaise with the
retailer or the wholesaler?
They
would not necessarily have developed
relationships with, or visibility of, who
the retailers are. Typically there is a
need for a rapid response. Intolerance
by non-industry stakeholders (public,
media etc) of market arrangements
causing complexity.
Answer
Bristol Water Non-Household Retail Separation Programme
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76.6
Document in the
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Area
Operational Code
(app3_part3_operatio
nalterms)
Section of the
Document / Topic
E1, E2, E3 (MH)
Issue
Limitations of knowledge by the
Wholesaler of needs of key
customers. Also of Retailers of
technical matters.
Comment
How much knowledge of location and
particular needs of a key customer
would a Wholesaler have ? What
technical capability is a Retailer
required
to
have
to
support
customers/ provide reassurance /
water quality advice ?
Wholesaler has an asset based or
business continuity incident.
76.7
Operational Code
(app3_part3_operatio
nalterms)
E1, E2, E3 (MH)
Issues arise for a Water
Company Incident relating to
responsibilities of and
interactions between Wholesaler,
Retailer and other parties./
For asset based incidents, assuming it
is the Wholesaler who organises ‘the
incident meeting’ does retailer attend
wholesaler incident meetings virtually
or in person? Communications with
customers and other agencies are key
in incidents, do Wholesale and retail
communications team cooperate? If
so how? Need common vocabulary
and triggers for incidents at industry
level.
Retailer
and
Wholesaler
need
integrated
business
continuity
arrangements.
76.8
E1, E2, E3 (MH)
Operational Code
(app3_part3_operatio
29
Co-ordination of multi-agency
incidents could be problematic.
It is assumed the main wholesaler in
the affect area would represent all
water sector players. How does this
coordination happen effectively? Do
Answer
Bristol Water Non-Household Retail Separation Programme
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Document in the
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Document / Topic
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Comment
retailers cooperate to ensure common
information is provided to customers?
nalterms)
The CCA would expect that a
multiagency Strategic Coordination
Group (SCG) would coordinate
multiagency activity. The SCG would
expect a single representative of the
water sector, representing all aspects
of the sector, with authority to make
decisions at executive level.
76.9
Operational Code
(app3_part3_operatio
nalterms)
E1, E2, E3 (MH)
For a National/Regional incident,
Water UK have a national plan
for mutual aid and coordination
during incidents organised on a
super-regional basis. There are
mechanisms for engagement
with Defra. What will multi-area
Retailers expect ?
Do retailers with customers in different
areas effected by common problems
expect a common approach from
Wholesalers? – need for national
protocols. SCGs can have difficulties
in engaging with neighbouring SCGs
in
widespread
incidents
and
recognising that utilities commonly
have footprints larger than LRFs.
Would expect Defra to be involved in
an information, guidance or directional
capacity.
How will Defra interact with retailers in
emergencies (if at all)? How will
common picture of operations across
30
Answer
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assets and customers be developed
for National Government ?
77
78
79
80
31
csd0003_volumetran
sferplanned
Compliance
Governance
app3_part2_busines
sterms
N/A
(Retail exit – is there any further
clarity on what will be required
(PM)
For either full retail exit or retail
transfer
(where
all
contestable
customers transferred are into a new
separate company), especially in
relation to consumer protection?
N/A
Level playing field considerations
(PM)
Has any new thinking come to light on
this? are there any plans to publish
any further documents on this
subject?
Very unclear at this stage, so hard to
plan.
N/A
Is there any further clarity on
what Defra / Ofwat will require
from company boards in relation
to market readiness and ongoing
compliance? (PM)
Need clear definition of this as early
as possible.
Definition of Terms
When will we have confirmed
definitions of household and nonhousehold, contestable and noncontestable
customers/premises? Will
premises be contestable in
relation to Supply Point level (the
‘SPID’) or each meter point?
(PM)
Answer
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32
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csd0301_datatransac
tioncatalogue
app3_part3_operatio
nalterms
Section of the
Document / Topic
All
Transfers
Issue
Comment
Data cleansing issues and
penalties (PM)
The delays in providing definitions and
requirements has increased the risk
that data will not be cleansed on time
(at least not without incurring
substantial costs); how will this be
taken into account when the market
opens and data errors come to light?
Will
penalties
be
applied
to
wholesalers from day one of market
opening or will a ‘bedding-in’ period be
allowed to account for the delays
which have been outside wholesalers’
control?
Change of Use (PM)
When will clarity be provided on how
premises which have a change of use
from household to non-household or
vice versa are to be handled (by the
MO, companies etc)? Also includes
granularity of asset that can be traded
and definition of ‘Eligible Premises’.
Clarity around the processes of
moving from contestable to noncontestable premises is needed to
ensure both practicality and efficiency.
The cost to participants of enabling
the market for housing sites initially
classed as contestable, but as soon
as they are purchased by domestic
customers
they
become
noncontestable,
with
perhaps
little
Answer
Bristol Water Non-Household Retail Separation Programme
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Section of the
Document / Topic
Issue
Comment
Answer
revenue received not being sufficient
to cover market costs
83
84
85
86
33
app3_part3_operatio
nalterms
csd0207_chargecalc
ulationallocationand
aggregation
app3_part3_operatio
nalterms
csd0301_datatransac
Communications not made via
the MO (PM)
As any communication between other
parties will not be standardised, how
will the costs relating to such
interactions be monitored / governed
in order to ensure that the
competitiveness of the market is not
unduly affected by costs which may
be wide-ranging and potentially
prohibitive (for example to new
entrants)?
Settlement process and
timetable (PM)
is the intention that this will follow the
Scottish Model or is a more efficient,
cost-effective process going to be
adopted in England? What is the
timescale for producing the intended
process for these activities?
F5
How will complaints be handled ?
(PM)
what arrangements and resources will
be put in place to handle between
non-household retailers and between
non-household
retailers
and
wholesalers?
All
Data specification delays (BN)
The current timescales will not provide
clarity on data schema and mandatory
Communitcations
between parties
General
CSD0301 now released
(11/12/14) but need to
Bristol Water Non-Household Retail Separation Programme
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elements for transition before Feb
next year which reduces our time to
address any gaps where we do not
hold the right information
tioncatalogue
87
88
csd0201_settlementti
metableandreporting
Performance
Incentives
89
app3_part1_objectiv
esdefinitionsprincipl
es.pdf
90
app3_part3_operatio
nalterms
34
Comment
All
The Settlement Audit and
Objection process is incomplete
(BN)
if it follows the Scottish Model, will be
extremely expensive and unwieldy.
Incentive Payments and
Penalties unclear (BN)
Attention should be paid to incentivise
participants to act within the rules,
rather than penalising them when they
don’t. There should be a degree of
leniency in the early days of the
market, with penalties only imposed
and increased after a substantial
period following market opening
1.5.9
From the Customer’s
perspective, the introduction of
Retail Competition will NOT
result in a seamless customer
experience due to the separation
of knowledge and responsibilities
of the disparate parties.
“The Wholesale-Retail Code or
arrangements established by or under
the Wholesale Contract should be
developed in a manner that delivers
a seamless customer experience in
the Areas of Wholesalers and in
Scotland.”
A3
Bristol Water do not differentiate
a water supply on its use so is
this an issue for the Retailer or
MO ?
Bristol Water do not differentiate a
water supply on its use, so we cannot
distinguish a supply used for Building
Water from one used for any other
purpose. Therefore we would not
All
Answer
know the full market
data take on
requirements
Bristol Water Non-Household Retail Separation Programme
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91
app3_part1_objectiv
esdefinitionsprincipl
es.pdf and all other
MAP documents
92
csd0003_volumetran
sferplanned.pdf
93
94
95
35
csd0003_volumetran
sferplanned.pdf
csd0003_volumetran
sferplanned.pdf
csd0003_volumetran
Section of the
Document / Topic
Issue
Comment
charge a different amount for this
volume.
Is this an issue for the Retailer or MO
?
If so, all documentation should be
changed to reflect this.
All
Do CSD0403 and CSD0404
replace CSD0302 ?
2.1
Why would a Wholesaler be
responsible for transferring
Supply Points between Retailers
?
Even if a wholesaler exits, won’t the
same Retailer(s) remain and be
contracted to the new Wholesaler ?
2.1, step h
The socument mentions the
possibility of using a different
method for the transmission of
data relating to Volume
Transfers. When will the
structure and format of this be
known and what are the trigger
points for it being used.
This is needed to :a) design new load mechanisms for
the new format
b) help understand the volumes that
are expected to be processed using
the normal DTC format and hence
influence system designs.
2.1, step h
Error notification and rectification
processes need to be efficient
and effective, even more so for
volume transfer than normal
transfer.
What are the expectations for this
from the MO and what will
Wholesalers have to do to be able to
meet these expectations ?
Concerns regarding the
responsibility of parties to obtain,
If a Wholesaler is executing the
volume transfer, is it responsible for
2.1, step i
Answer
Bristol Water Non-Household Retail Separation Programme
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Issue
use, settle and invoice against
transfer reads
sferplanned.pdf
96
csd0301_datatransac
tioncatalogue
Transaction
Descriptions
There is no indication of
repeating groups within the
transactions – can it be assumed
that the data is fully flat ? (e.g.
every data attribute exists only
once at the top level, and cannot
repeat more than once for a
given top level (normally SPID)
97
csd0301_datatransac
tioncatalogue
Transaction
Descriptions
What is the definition of the
header and trailer of the DTC
files ?
98
36
csd0003_volumetran
sferplanned.pdf
4
For a change of Name, is the
CSD saying that this has to occur
for EVERY SPID under this party
?
Comment
obtaining all the Transfer Reads ?
Does it have any involvement in
obtaining reads in any other situation
? Will there be issues with Settlement
caused by the extended period
needed for obtaining transfer reads ?
If so, how will multiple instances of the
same transaction be handled ?
Need to understand the contents of
these to determine file level validation
rules.
Surely this is not a Volume Data
Transfer issue, as it is a single
transaction stating that Party A now
needs to be know as Party B,
referenced by the ORG ID ? The
assumption is that the ORG ID of the
party changing its name does not
change, hence there is no change to
each SPID related to that ORG ID
(and hence no need to perform a
volume data update )?
Answer
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99
100
101
37
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Area
csd0102_registration
transfers.pdf
csd0102_registration
transfers.pdf
csd0103_registration
cancellationerroneou
stransfers.pdf
Section of the
Document / Topic
Step h1
Step h1
3 Erroneous
Transfer
Issue
The CSD implies that a transfer
for a meter network need only be
done against the main
SPID/Meter, and all sub-meters
will automatically be transferred
– is this correct ?
How should a Wholesaler
validate a request from an
incoming Retailer when it
believes another Retailer is
assigned to the SPID ?
Why is it only the Incoming
Retailer that can lodge an
erroneous transfer ? Why can’t
any party do it, particularly the
Outgoing Retailer ? Also, the
time deadline of 3 months
doesn’t seem long enough.
Comment
Do all sub-meters of a meter network
have to be transferred en masse ?
Can a sub-meter be transferred
without the main meter being
transferred ? Does a 102 process
need to be initiated for just the main
meter or for each and every sub-meter
? Could the Data Owner for a submeter be a different Retailer or
Wholesaler to the Main Meter/SPID ?
The initial view is that the request
would be rejected because the
Wholesaler believes that a different
Retailer legitimately ‘owns’ the SPID –
how is it to know to action the request
from this new Retailer ? This could
occur because the Incoming Retailer
is not able to get a Transfer Reading,
perhaps due to a faulty meter, so
requests the Wholesaler to resolve the
problem as part of the transfer
process.
There needs to be clear incentives for
the party to register an erroneous
transfer and then to enable them to do
so. The full back-out mechanism
needs to be described, with examples,
particular covering the rectification of
Settlement implications (i.e. rescinding
invoices and payments made
Answer
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102
app3_part3_operatio
nalterms
Task and Finish
Group questions
Definitions of enquiry and
complaint
103
app3_part3_operatio
nalterms
Task and Finish
Group questions
Definition of an Emergency
104
app3_part3_operatio
nalterms
Task and Finish
Group questions
Definition of Public Health Risk
38
Comment
erroneously and sending new
invoices).
Definition of what's an inquiry (dealt
with by retailer) and what's a
complaint / quality contact (passed to
wholesaler). Share Scottish Water
decision trees and DWI IL on
categories of contacts. Possibly have
two processes. [Processes E
introduction, E1 (step 1), E2 (declaring
an emergency step 1) F4 (process),
F6 (Enquiries received by retailer]
The lengthy definition of an
emergency or public health risk needs
to be reviewed and could benefit from
being separated into individual
definitions for emergency and public
health risk (although noting there
could be overlap).
Retailers need to understand the
definition of public health risk. For
example this could include information
they receive from a customer
indicating a premises has a private
supply. What information and
guidance do retailers need to support
them recognising public health risks
such as this? Should this be done by
all water companies or could English
guidance be developed
Answer
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105
app3_part3_operatio
nalterms
Task and Finish
Group questions
Which enquiries should be
reported to DWI ?
106
app3_part3_operatio
nalterms
Task and Finish
Group questions
What data should be collected by
Retailer relating to an Incident ?
107
app3_part3_operatio
nalterms
Task and Finish
Group questions
Process for Retailers to comment
on information relating to quality
incidents
39
Comment
What enquiries will be reported to
DWI, how this is to be done and who's
responsibility /accountability it is and
sharing information between
wholesalers and retailers avoiding
double accounting. This was
particularly important for enquiries
such as about the hardness of the
water supply which may be dealt with
entirely by the retailer. There is likely
to be specific requirements for
retailers to hold minimum information
to provide an audit trail for the DWI.
What data should be collected by
retailer to pass on to wholesalers to
support an investigation / incident?
Critical information is likely to include,
but not limited to: premises address,
contact name and number
Process for where retailers can
comment on drafts of information
being provided to customers during a
quality incident in a timely manner wholesalers need to be able send
information straight out if necessary –
and will therefore need access to upto-date records. There was preference
that feedback from retailers should be
encouraged but not deemed
mandatory to allow a flexible
response.
Answer
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app3_part3_operatio
nalterms
Task and Finish
Group questions
Difference between generic and
emergency information.
109
app3_part3_operatio
nalterms
Task and Finish
Group questions
Any legal issues when sharing
information or questions of
misusing information for
competitive advantage ?
110
app3_part3_operatio
nalterms
Task and Finish
Group questions
Retention of historic data by
Wholesalers.
111
app3_part3_operatio
nalterms
Task and Finish
Group questions
Define exactly what immediate
communication means and
consequences of not doing so
40
Comment
Clarify difference between information
provided in an emergency and the
more generic information provided
that retailers may wish to re-brand or
re-emphasise. How long to give
parties to respond?
Are there any legal issues
(confidentiality, data protection or risk
of customer suing wholesaler) with
sharing water fittings regulations’
enforcement notices with retailers,
which may be seen as confidential
between wholesaler and customer?
This information could precede a
criminal prosecution. Would retailers
get an unfair competitive advantage if
they used the enforcement notice to
offer plumbing services?
What historic information will
wholesalers be permitted to retain,
regarding the service history data of
customers? This information can be
critical to a water quality/water fittings
investigation and improve appropriate
response to mitigate or prevent a
water quality event.
What does "immediate" mean for
retailers expected to pass on public
health risks immediately - what
expectations and what are
consequences of not doing so?
Answer
Bristol Water Non-Household Retail Separation Programme
#
Document in the
MAP/High Level
Area
Section of the
Document / Topic
Issue
112
app3_part3_operatio
nalterms
Task and Finish
Group questions
Information on sensitive
customers available within
Market Data sets
113
app3_part3_operatio
nalterms
Task and Finish
Group questions
Extent of work required by
Wholesaler when ‘passing on
information’
114
app3_part3_operatio
nalterms
Task and Finish
Group questions
Form A does not include sections
for Water Fittings Regulations
115
app3_part3_operatio
nalterms
Task and Finish
Group questions
No requirement for Retailers to
pass on Water Fittings notices
app3_part3_operatio
Task and Finish
Disconnection for Illegal Use
process needs to recognise there
116
41
Comment
Should there be standing information
on sensitive customers within market
data sets - lists of hospitals, dentists,
care homes, prisons, schools - with
contact details to enable timely
communication.
What does it mean to pass information
on - simply putting information on a
portal or proactively seeking out
parties? [This relates to wholesalers
obligation for planned and unplanned
changes - processes D1, D2, D3, E1]
Currently new connection application
forms for water companies aim to
cover notification requirements under
the water fittings regulations. This
makes it easier for customers to
comply. Form A misses three areas
that are needed: the name of the
approved contractor (if one is being
used), a description of the plumbing
work and a schedule of the water
fitting being used
For existing premises, there is
currently no requirement for retailers
to pass on water fittings regulations’
enforcement notices within the
Wholesale-Retail code. This could be
simply added to process F6.
The I3 disconnection for illegal use
process needs to recognise that illegal
Answer
Bristol Water Non-Household Retail Separation Programme
Document in the
MAP/High Level
Area
Section of the
Document / Topic
nalterms
Group questions
may not be a Retailer
117
app3_part3_operatio
nalterms
Task and Finish
Group questions
Retailers have an obligation to
report an illegal supply.
118
app3_part3_operatio
nalterms
Task and Finish
Group questions
Role for Retailers in SEMD ?
118
app3_part3_operatio
nalterms
Task and Finish
Group questions
Obligations on Wholesaler
following a transfer of Retailers
4.3.5 and 4.3.6
How will Retail Exit be
implemented ? Will this be via
Volume Transfer Planned or via
data take-on at initial market
opening ?
#
119
42
Market Code and
CSD0003
Issue
Comment
connection found by a wholesaler may
not have any Retailer and therefore a
retailer could not be notified.
It needs to be clear that retailers have
an obligation to report an illegal
site/gap site even when they do not
wish to become the retailer. [C3]
Perhaps this process should also
cross reference to I3 as the process
may stop where identified as illegal?
Is there a role for retailers under
SEMD? If they were to be category 2
responders this would need to be
reflected in the processes. [Process
E2]
Is there an obligation on wholesaler to
recognise and update a new retailer
on site specific plans after a switch or
would this be picked up when plans
are next reviewed? [Process E2]
It is unclear how the initial registration
of eligible NHH premises will be done.
To be specific, the CSD0003 Volume
Transfer Planned is intended for use
once the market has opened and all
SPIDS have been registered.
Likewise, sections 4.3.5 and 4.3.6 of
the Market Code are not clear on how
initial data take-on should be handled.
The question is :- why go through the
exercise of initial data take-on setting
Answer
Bristol Water Non-Household Retail Separation Programme
#
Document in the
MAP/High Level
Area
Section of the
Document / Topic
Issue
120
csd0105_errorrectific
ationretrospectiveam
ends.pdf
1.1.5
Retrospective Amendment of
data limited to certain Settlement
Runs
121
csd0105_errorrectific
ationretrospectiveam
ends.pdf
2.1
How will modified data items be
identified and associated with an
effective from date ?
Comment
up all BW’s NHH customer in the
market and then immediately have to
undertake a Volume Transfer Planned
exercise on all 40,000 to move them
to Water2Business ? Would it not be
more sensible to set them up against
Water2Business in the first place as
part of data take-on ?
The CSD states that certain
retrospective amendments cannot be
made if the effective from date of the
amendment is prior to the most recent
R2 or R3 settlement run. This seems
a little restrictive for the complex data
corrections that are needed to back
out a series of Retailer Transfer
events, perhaps due to an incorrect
meter serial number and/or reading
needing rectification. Can examples
showing how these complex scenarios
would be resolved be provided to aid
understanding of whether the limits
imposed in the CSD are practical.
If more than one data item requires
modification, and the effective from
date is different for each item, how
should the Data Owner send/structure
the transactions to represent the
accurate picture ?
Further, does the Effective From Date
43
Answer
Bristol Water Non-Household Retail Separation Programme
#
Document in the
MAP/High Level
Area
Section of the
Document / Topic
Issue
Comment
relate to the set of data items in the
transaction, so that all are marked as
being effective from the date given
(regardless as to whether the item has
changed) or just the data item(s) that
the MO identifies as being changed ?
122
csd0105_errorrectific
ationretrospectiveam
ends.pdf
Step c
123
csd0105_errorrectific
ationretrospectiveam
ends.pdf
Error correction
Step f part 4
124
csd0105_errorrectific
ationretrospectiveam
ends.pdf
Vacancy Scheme
step d
125
44
csd0105_errorrectific
ationretrospectiveam
Appendix 1
User Management processes
need to be defined
MO can raise additional costs for
error correction as an Additional
Service Charge
Retailers of related SPIDS and
objections
Manual Retrospective
Amendment Pro Forma
Lastly, if all the data items are correct,
but it is only the Effective From date
that is incorrect and needs
rectification, how should this be
actioned ?
This section mentions a new CSD for
User Management allowing certain
users to authorise transactions. When
will this be available ?
What will these costs be, who pays
them, how and what circumstances
trigger an additional cost ? Will there
be any leniency in the early days of
the market when there is likely to be a
large amount of data corrections
needed ?
How does the Wholesaler know who
these Retailers are and whether or not
they have raised a challenge to the
Wholesaler’s request to change the
Vacancy status ?
Should this form be part of the valid
form set (as per the Operational
Code) or be part of a dedicated
Answer
Bristol Water Non-Household Retail Separation Programme
#
Document in the
MAP/High Level
Area
Section of the
Document / Topic
Issue
ends.pdf
126
csd0201_settlementti
metableandreporting
.pdf
2.4
127
csd0201_settlementti
metableandreporting
.pdf
2.5.2
Can description of charges be
supplemented with a code for
the charge listed ?
128
csd0203_meterreads
ubmissionvalidation.
pdf
2.3 , p.17
What is the value of ‘n’ in the
volume validation equation ?
129
45
csd0203_meterreads
ubmissionvalidation.
pdf
All
Can any Wholesale Charges be
generated from a post-RF
settlement report
Should a meter reading for a
market meter be treated as a set
if there is an associated nonmarket meter so that if validation
on EITHER reading fails, then
the whole set fails and cannot be
used for settlement ?
Comment
Market form set to ensure consistency
and visibility by all participants, rather
than an appendix to a CSD ?
This section states that the
Aggregated Settlement Report is the
only one that should be used for
generating Wholesale Charges,
whereas the disaggregated report is
for information only. If the post-RF
settlement report only contains the
disaggregated figures, because it is
SPID-specific, can any of it be used
for Wholesale Charging ? If not, what
is its purpose ?
Having a code caters for changes to
the charge name over time. This may
require changes to the Wholesaler
Tariff submission process.
It is assumed to be the number of
digits of the meter register, so that a
rollover can be handled.
Settlement of a market meter
consumption may be dependent on
the addition or subtraction of volume
recorded on a non-market meter, so if
the non-market meter reading fails
validation , then the volume
associated with it cannot be used to
adjust the volume recorded on the
Answer
Bristol Water Non-Household Retail Separation Programme
#
Document in the
MAP/High Level
Area
Section of the
Document / Topic
Issue
2
Should the section dealing with
sensitive customers have more
than just a tick box ?
131
formf2_metering_ae.
pdf
1
Will the Retailer’s own reference
number be consistent on updates
to reflect the original meter
activity requested ?
132
formf2_metering_ae.
pdf
10.2.1
133
formk_verificationof
meter_metersupply.p
df
130
formf2_metering_ae.
pdf
7
As well as having a check box for
indicating there will be a charge
for the investigation, should the
chargeable amount be given also
?
Is the intention that if a
Wholesaler wants to re-assess
the site, it sends itself the form
?
134
forml_reassessmentr
equest.pdf
2
135
formo_deregistration
request.pdf
3
46
What is the point of the last
check box in this section ?
As well as a checkbox to
indicate if a meter is part of a
network, should it also indicate
which meter(s) is(are) part of a
Comment
market meter.
Should there be a list of reasons for
the Customer being Sensitive
(standardised if possible) ?
Need a way to link any updated
information to the original
request/notification.
Isn’t it sufficient for the Retailer to
ensure that either the Pass or Fail box
has been checked – what does the
last checkbox add ?
Aids completeness if the amount is
included by the Wholesaler on the
form.
Seems odd that a Wholesaler can
send the form to itself requesting an
assessment. Or is it for a Wholesaler,
once it has done the assessment, to
report back to the Retailer ? It’s not
clear from the wording on the form in
section1 and 2.
May be helpful in identifying the
correct meter and performing the
action properly.
Answer
Bristol Water Non-Household Retail Separation Programme
#
Document in the
MAP/High Level
Area
Section of the
Document / Topic
Issue
Comment
network ?
136
formo_deregistration
request.pdf
4.2
137
CSD0104_MaintainS
PIDdata
2.2..3.1
Do we have SIC 1980 as it is
being used for notification
from Retailors
138
CSD0104_MaintainS
PIDdata
2.3.2.2
Government contribution
count is unknown
139
CSD0104_MaintainS
PIDdata
2.3.4
VOA BA / UPRN
lifecycle
140
CSD0104_MaintainS
PIDdata
2.3.6
Building Water Status is
unknown
141
CSD0104_MaintainS
PIDdata
3.1.3
Address of ‘Decision maker’
at supply point address is
unknown to BW
142
CSD0104_MaintainS
PIDdata
What is this section for ?
Temporary disconnection
47
3.2
What Wholesaler Service Request
information should be here and what
should the Wholesaler do with it ?
Check whether we have this set
and how complete it is for initial
transfer? Does the MO apply on
our behalf?
What is this? We do not hold this
information currently so how do we
fill the gap?
We do not currently hold any VOA
BA number sequence. In addition
UPRN’s remain unique, changes
to UPRN’s do not happen.
Assume this is where a Supply
Point is being used to build a
property? Clarification required
We currently hold Sold to, Ship to
and bill to. We would need
clarification on how decision maker
differs.
The process within BW for this is
uncontrolled. GIS is the master of
Supply Points but the notification
process from Operations is
spurious at best.
Answer
Bristol Water Non-Household Retail Separation Programme
#
Document in the
MAP/High Level
Area
Section of the
Document / Topic
143
CSD0104_MaintainS
PIDdata
3.5.2
144
CSD0104_MaintainS
PIDdata
4.2
145
CSD0104_MaintainS
PIDdata
5.1
146
CSDD0106_nonmarketmeters
1.0
147
CSD0202_meterread
submission process
2.4 regular cyclic
meter reading
48
Issue
Surface area of premises is
unknown by BW
Volumetric allowance
calculation
Meter exchange by
accredited entity
Non-Market meters needs
defining in our terms
CSD says that the
Wholesaler is responsible for
reading non-market meters
Comment
This is Sewerage only? Or are we
duty bound to inform in the event
of us knowing?
This is not currently captured
through our systems. Manual
adjustments currently made by
BWBSL
Is the AE working on behalf of the
retailer? If so, how is this meter
exchange information provided to
us as we have the responsibility to
update the MO.
We hold the concept of check
meters in our systems. These are
used for deducting household
consumption away from the main
NHH meter? Clarification needed.
Why also would we instigate a
change in this meter as there is no
mechanism for checking it is
reading correctly or otherwise
Meter reading is not a current BW
operation. It is a BWBSL activity.
Is it legitimate for a Wholesaler to
Answer
This is defined in the
Operational Terms
(Processes B4, B6, B8,
B9), sent to the
Wholesaler by the
Retailer when they have
received it from the AE
or is working on behalf
of the Retailer..
Bristol Water Non-Household Retail Separation Programme
#
148
Document in the
MAP/High Level
Area
formr_reconnection.
pdf
Section of the
Document / Topic
3
149
Operational Terms
All
2.1
150
Csd201_settlement
timetableand
reporting
49
Issue
Comment
on regular frequency no less
than twice a year. BW do not
currently do this work?
have to read these meters on a
cyclic basis (as well as for transfer
readings ) ?
On the reconnection form,
why have all the details
about the disconnection ?
Appointments with NHH
customers are not discussed
at all. This could be a real
source of issues between
Customer, Retailer and
Wholesaler.
The market operator will
make changes to the
timetable with the agreement
of the panel
What purpose does this serve ?
What is the Wholesaler expected
to do with it ? What if the details
differ from the details provided on
the original disconnection form Q ?
Currently, Wholesalers make all
appointments directly with the
customer. In the future, how will
this happen ? If Retailers do it with
their customers, how will they
know what availability the
Wholesaler has ? How will they
know what appointment bands the
Wholesaler offers and has open ?
Could a general principle be that
appointments for NHH Customers
are not necessary as they will
always be in ?
What panel? How will
disagreements, or split decisions
be resolved
Answer
Bristol Water Non-Household Retail Separation Programme
#
Document in the
MAP/High Level
Area
Csd201_settlement
timetableand
reporting
Section of the
Document / Topic
The Market operator shall
also be entitled to carry out
Ad-hoc Runs in accordance
with Section 14 of the market
terms
(Possibly dealt with in Section 17
of the business terms) – Can Adhoc settlement runs be requested
by either the Wholesaler or the
Retailer?
1.1.2
The process assumes that
the data has been correctly
submitted by the data
owners, and does not
necessarily fully describe
situations where either
incomplete or inconsistent
data has been submitted by
the trading parties
How is this data verified. Will either
trading party be subject to an
audit? How will queries about any
of the three parties information be
resolved and by whom? Is there a
timescale for any of these
processes?
3.3.2
Scale the volumes to an
annual volume (doing this
carefully for meters which
were installed or removed
within the relevant period)
Is this just loose wording? Assume
that there would be a moderated
and automated process in place
for picking up any meters that
were installed or removed within
the relevant period. There should
be no need to be “careful”
Csd207_chargecalcu
lation
152
allocationandaggreg
ation
153
allocationandaggreg
ation
50
Comment
2.3.1
151
Csd207_chargecalcu
lation
Issue
Answer
Bristol Water Non-Household Retail Separation Programme
#
Document in the
MAP/High Level
Area
Csd207_chargecalcu
lation
154
51
Comment
The Market operator shall
calculate the daily refund
due from the Wholesaler to
the Retailer under the
Government Contribution in
accordance with CSD0208.
This may be explained elsewhere,
but what does the Government
Contribution relate to?
A.1.3.
If the retailer has supplied a
YVE (Yearly Volume
Estimate)
When are these supplied? Are
they requested? Are they
mandatory?
A.1.5
Ensuring that there are no
large spikes in this allocation
This seems very subjective. What
determines a “spike”. How are
these spikes in volume resolved?
allocationandaggreg
ation
Csd207_chargecalcu
lation
156
Issue
3.12.1
allocationandaggreg
ation
Csd207_chargecalcu
lation
155
Section of the
Document / Topic
allocationandaggreg
ation
Answer
Bristol Water Non-Household Retail Separation Programme
#
Document in the
MAP/High Level
Area
Csd207_chargecalcu
lation
157
52
Issue
Comment
A.4.7
For now, the flexibility of
using a different volume
estimate for the purpose of
deriving a block tariff price
compared to the volume it is
applied to is maintained.
What are the benefits of using
different volume estimates within a
single calculation? Consistency
should be key, and using different
bases for estimates will only lead
to complications and disputes.
9.3.3
The reconciliation amount
payable by the Contracting
Retailer or the Contracting
Wholesaler in terms of
Section 9.3.2 in respect of
Invoice Period X shall bear
interest at the rate of three
(3) per cent per annum
above the current official
Bank Rate, such interest to
be calculated from the date
of payment of the
Reconciliation Balance for
Invoice Period X in terms of
Section 9.2 above up to and
including the date of
payment of the reconciliation
amount calculated on a daily
basis.
Is there not a danger here that the
Retailer or Wholesaler could be
paying interest at a high rate (3%
above base rate) for reasons
outside of their control? For
example, what if errors were made
by the MO in the settlement
process that resulted in too much
or little being invoiced initially? Or
what if a retailer submitted
erroneous meter readings that
resulted in the wholesaler invoicing
too much, and then the wholesaler
subsequently being forced to pay
interest to the retailer?
allocationandaggreg
ation
App3_part2_busines
sterms
158
Section of the
Document / Topic
Answer
Bristol Water Non-Household Retail Separation Programme
#
Document in the
MAP/High Level
Area
159
app10-notes-on-theplanningassumptionsunderpinning-theprogramme.pdf
Section of the
Document / Topic
Issue
Comment
What are Open Water doing to
reduce the level of change and
therefore risk with these later
versions of the MAP.
2. Codes, processes
and procedures.
Changes due in MAP4 will
not be known until Sept/Oct
2015 which creates risk to
the design and build of our
local solutions.
160
app10-notes-on-theplanningassumptionsunderpinning-theprogramme.pdf
3. Market Operator
(MO)
Timeline to Procure MO IT
solution and build looks very
aggressive.
What are the contingency plans to
ensure the overall build delivery is
not affected by Procurement
issues ?
161
app9_plan_to_april2
017.pdf
Key steps to market
opening April 2017
MAP rules are under Change
Control until mid way through
Q1 2016.
Is this a realistic date or is the
MAP4 timing of Sept/Oct expected
to be the final release ?
Shadow Operation is
planned for a 6 month
window but it’s not clear
what is expected during this
period and what’s difference
between “Go-Active” and
“Go-live”.
Can you confirm what the vision of
this is? Is there are view that
Wholesalers will have a selected
number of non household
customers operating from Oct
2016 via agreed retailers with the
full switch taking place in April
2017 ?
When are the workshops likely to
start ?
162
app9_plan_to_april2
017.pdf
Key steps to market
opening April 2017
163
app12-assurancediscussion-paper.pdf
Next Steps –
Timetable to develop
an assurance
framework
53
No visibility of the various
workshops that are planned
to support programme
assurance which could result
in various parties working in
Answer
Bristol Water Non-Household Retail Separation Programme
#
Document in the
MAP/High Level
Area
Section of the
Document / Topic
Issue
Comment
a non-aligned way.
164
Form A
General
165
Form A
Pg2 tick boxes
166
Form A
Pg3 instructions
167
Form A
Pg3 instructions
168
Form A
1. Retailer details
169
Form A
5. Connection
details – Meter
The form is too long
Require an additional tick
box
Instructions are unclear and
Misleading
Inconsistency with Water UK
Developer Standards
Lack of clarity
54
Unnecessary data requested
The whole form is 24 pages, the
section(s) relating just to a
connection is 11 pages.
Customers already complain that
our current 2-page form is too long
Most connections for non-domestic
purposes will include domestic
use, so a tick box for combined
use is required
Instructions say that for certain
purposes only sections 8, 9 or 10
need to be completed, whereas
some or all of the earlier sections
also need to be completed
otherwise the wholesaler will not
have the necessary information
This document refers to Business
Days, the Water UK standards are
based on calendar days. This or
Water UK needs to change
What sort of entity is meant by the
“third-party (non-Retailer)
contact”? Is this the retailer’s
customer or some other party?
This section is unnecessary as the
meter size is the Wholesaler’s
Answer
Bristol Water Non-Household Retail Separation Programme
#
Document in the
MAP/High Level
Area
Section of the
Document / Topic
Issue
Details
170
Form A
5. Connection
details – Meter
Details
171
Form A
8. Requests
(various)
172
Form A
8.4 Water quality
sampling
55
Misleading question
Misleading instructions given
previously
Section not required
Comment
decision, not the Retailer’s. We do,
however, normally ask what size of
supply pipe the applicant is
proposing to use. Similarly I
believe for the next section
(Standard or Non-standard meter
question).
In the Proposed location section, I
think it should refer to ‘preferred’
location rather than ‘proposed’, as
the final decision rests with the
Wholesaler.
If a Retailer just wants, say, a
Trench Inspection, the instructions
state that they should complete
section 8, which directs them to
Section 8.1. Unless they have
already completed other sections
the Wholesaler will not have
sufficient information to process
the request. If the intention is that
the retailer completes Sections 3-7
for every request, this should be
stated. Similarly for 8.2, 8.3 and
8.4.
The Wholesaler does not carry out
water quality sampling of the
customer’s pipework.
Answer
Bristol Water Non-Household Retail Separation Programme
Document in the
MAP/High Level
Area
Section of the
Document / Topic
173
Form A
9,
Change/resubmissio
n of application
details
Misleading instructions given
previously
174
Form A
10. Confirmation of
completion etc
Misleading instructions given
previously
175
Form A
10. Confirmation of
completion etc –
Confirmation of
address
Additional clarity required
176
Form A
11. Declaration
177
Form A
Appendix A
Sections 1, 2, 3 and
4
Better clarity needed
Form A
Appendix A
Sections 1, 2, 3 and
4
Typo
#
178
56
Issue
Minor amendment
Comment
See comments above for S8 –
Instructions need to make clear
that previous sections of the form
have to be completed, as well as
this section.
See comments above for S8 and
S9 – Instructions need to make
clear that previous sections of the
form have to be completed, as well
as this section.
Add to heading “of premises
connected” to ensure clarity
Under 11.1, third statement, add
“in writing” after “Wholesaler”
Not every connection will have a
meter (note that this section
includes existing supplies as well
as new), so change column subheadings from “Meter 1”, “Meter 2”
etc to “Connection 1”, “Connection
2” etc
In the first row, insert the word
“new” in front of last word “meters”.
It was in a previous draft.
Answer
Bristol Water Non-Household Retail Separation Programme
#
179
Document in the
MAP/High Level
Area
Section of the
Document / Topic
Form A
Appendix A
Sections 1, 2, 3 and
4
Issue
Unclear choices in time
periods
Appendix A
180
Form A
2. Number of Water
Fittings
Additional clarity
Appendix A
181
Form A
2. Number of Water
Fittings
..
Appendix
182
Form A
Comment
Answer
The instruction is to “select one of
the following” time periods,
otherwise 24 hours will be used as
the default, but the required period
probably won’t fit in with just one of
the choices available.
Line 2, after “Maximum fill rate for
storage tank”, add “(litres/second)”
Under “Swimming pool” add either
“Capacity” or “Maximum top-up or
fill rate required”
Clarity
3.1 Make clearer in heading that
this is for existing supplies
..
3.2 Make clearer in heading that
this is proposed flowrate
A 3. Flowrate
Appendix
183
Form A
A 3. Flowrate
184
Form E
Section 2
Clarity
185
Form E
Section 2
..
57
After “ordnance Survey references
(10 fig)” add “at centre of site”
What is “Postcode outcode”?
The first 4 characters of
a postcode. E.g. if the
full postcode is BS13
Bristol Water Non-Household Retail Separation Programme
#
Document in the
MAP/High Level
Area
Section of the
Document / Topic
Issue
Comment
Answer
7AT then the Outcode is
BS13 and the Incode is
7AT.
186
Form E
Section 4
Clarity between WOCs and
WASCs
187
Form E
Section 5
Clarity
188
Form E
Section 6
Clarity
189
Form L
Scope, page 2
190
Form L
Section 2
191
Form L
Section 3.2
192
Form L
Section 4
58
Question
..
Improvement of form
..
If Wholesaler is a WOC, Sections
4.2, 4.3, 4.4 and 4.6 are not
required, but S4.5 is
What is the intention of the first
part of S5? Perhaps provide
example(s)?
After first clause of Declaration,
and “in writing”
If the form is designed to be
completed by the Retailer, how
would this happen if point 2
applies, namely that the
Wholesaler wishes to review the
charges?
If the reason for submission is
“Request by Wholesaler”, how
does the Retailer complete the
form?
After “Staff canteen” add a further
option and tick box: “Other (please
specify)” and a line………..
If item above is implemented, then
the first half of 4 can be deleted,
leaving just the second half, and
the heading changed to “Trade
Bristol Water Non-Household Retail Separation Programme
#
Document in the
MAP/High Level
Area
Section of the
Document / Topic
Issue
193
Form L
Section 5
Clarity
194
Form P
Section 3
Question
195
Form P
Section 4
Question
196
Form Q
Section 3
Tidying form
197
Form Q
Section 4
Clarity
198
Form Q
Section 4
Question
59
Comment
Effluent”
What happens if consent is not
given for the Wholesaler to contact
the NHH customer direct?
Can a Retailer request
disconnection for any reason other
than Non-payment? If not, last
question on page 3 is not required.
Final question. I didn’t think
accredited entities could carry out
disconnections in England. Can
they? If not, this question should
be deleted.
Add column lines to table, then
have just one Label “Location” so
that location for each meter gets
input in the relevant column.
As in Section 6 the NHH Customer
must sign the form, how can there
be a box which can be ticked to
say that the NHH Customer has
not consented to the
disconnection. This question
should be deleted.
As above for Form P, I didn’t think
that an accredited entity could
perform a disconnection.
Answer
Bristol Water Non-Household Retail Separation Programme
#
Document in the
MAP/High Level
Area
Section of the
Document / Topic
199
Form Q
Section 5
200
Form R
General, Section 4
201
Form R
Section 5
Clarity
202
Form T
Section 3
Clarity
203
Form T
Section 3
Clarity
204
csd0005_gapsiteallo
cationprocess.pdf
1(a to c)
60
Issue
Clarity
Purpose of form
How to guarantee that all
retailers are registered with
the Market Operator for Gap
Comment
What happens if the Retailer does
not give consent for the
Wholesaler to contact the
customer?
This form seems to be intended for
both: a/ a request for the
Wholesaler to make a
reconnection, and b/ notification,
after the event, that an SLO has
carried out a reconnection. It does
not cover a request for
authorisation for an SLO to carry
out a reconnection.
As above, what happens if the
Retailer does not give consent for
the Wholesaler to contact the
customer?
What is the difference between
Line 2 (Update of existing….) and
Lines 3 and 4 (UPRN correction,
VOA BA Reference correction)?
If Box 3 or 4 is ticked, why isn’t the
Retailer directed to complete
Section 6?
Need to guarantee that all parties
are included in the process
Answer
Bristol Water Non-Household Retail Separation Programme
#
Document in the
MAP/High Level
Area
Section of the
Document / Topic
Issue
Comment
Answer
Site Allocation
Are there any penalties for
retailers who should but don’t opt
in for registration
csd0005_gapsiteallo
cationprocess.pdf
2
205
The Market Operator shall
complete a provisional
exercise to establish which
Retailers meet any of the
criteria for automatic
inclusions
How will the Market Operator know
which retailers to perform this
exercise if they don’t know all the
retailers? Could small retailers
fall through the “gap”
For point of accuracy instead of
doing this once a year should
process not allow any relevant
retailer to join at any point in the
year?
206
207
61
csd0005_gapsiteallo
cationprocess.pdf
2
csd0005_gapsiteallo
cationprocess.pdf
3.2
Provisional exercise for
inclusion of retailers
The Market Operator shall
allocate each Gap Site
Supply Point on a sequential
basis in accordance with the
relevant sub-list of Opted in
What does this mean?
Would it not be better to allocate
each Gap supply point by
postcode and house number
rather than on a sequential basis
as this is a unique reference and
This isn’t referring to a
sequential number to
allocate to a gap site, it
is simply talking about
allocating the site to the
Bristol Water Non-Household Retail Separation Programme
#
62
Document in the
MAP/High Level
Area
Section of the
Document / Topic
Issue
Comment
Answer
Retailers subject to the
proviso that where a Water
Services Supply Point and
an associated Sewerage
Services Supply Point exist
at an Eligible Premises, they
shall, so far as practical, be
allocated to one Opted in
Retailer.
less danger the sequential number
will be issued twice.
next available Retailer
on the list of opted-in
Retailers. They don’t
have a choice of which
sites they get, they have
to take what they are
given. If there are three
Opted-In Retailers, A, B
and C, then the first gap
site will go to Retailer A,
the second to Retailer B,
the third to Retailer C
and the fourth starts the
sequence again at
Retailer A.