Comments Table
Company Name…PORTSMOUTH
Document in the
MAP
WATER
Section of the
Document
Issue
Comment
METER READINGS ON BEHALF OF
SEWERAGE COs
This has a significant financial
impact on WoCs and should be
addressed
PORTSMOUTH WATER’S TOP 7 ISSUES
Appendix 3
4.10.1
Part 4
General Duties
Market Terms
There is no acknowledgment of the
arrangement for WoCs to supply and receive
payment for meter readings from WaSCs. Meter
readings will be available to all market
participants
CSD 0202
Pages 7 and 14,
Meter Read Submission
Process
2.4 and Section 3
Main MAP
45
DATA REQUIREMENTS
CSD 0301 Data
Transactions Catalogue
Overall
Unclear whether some data marked in the
Catalogue as Optional is truly Optional, but is
Required for initial load
The catalogue deals with ongoing transactions
once the market is active
1 Portsmouth Water MAP 2 Responses
See section 205 of the Water
Industry Act 1991
Are fields marked as Optional in CSD
0301 also Optional for initial market
load? We need to know whether
these fields are truly Optional, or
whether they are Required for the
initial upload of data to the Market.
This is because significant work is
required to collect some of this data
Examples include:
Unique Property Reference Number
Valuation Office Agency BA reference
Standard Industrial Classification 80
Coordinates, property and meter
Meter Location Code
Customer Classification
Customer Banner Name
Decision Maker Function/Title
Trough, sprinkler, hosepipe, swimming pool
Main Market
Architecture Plan
Overall
2 Portsmouth Water MAP 2 Responses
CODE TIMESCALES
Timescales, in particular those set at 2
business days. Examples include a change of
Banner Name, advising the result of a Planned
Visit by a Wholesaler, and changing the
address of the Decision Maker
and import it into our systems; in
some cases a suitable field does not
yet exist
Will standards required for initial load
be made clear in MAP 3, when CSD
0404 Interface for the Provision of
Standing Data is published?
When will the latest version of the
CSD 0301 Annex be made available?
It is difficult for us to make
appropriate plans without this
knowledge, and it narrows the time
window for collecting this data if it
proves necessary
Is it necessary for the functioning
of the market for some of these
timescales to be so tight, will be
difficult to achieve in practice with
little if any benefit.
A 5 day standard would seem
more appropriate
Wholesale-Retail Code
Part 3 Operational
Terms
Page 57
NOTICE PERIODS FOR WORK
Process D2 Step 1
Notice required for Planned Activities
22 days’ notice may not be
realistically achievable. Please
clarify the definition of Planned
Activities vs. Reactive Activities.
Will making details available on
the web, as per Scottish Water’s
Licensed Provider portal, be an
acceptable form of notice?
If so can this be explicitly stated?
Wholesale-Retail Code
Part 3:
Page 78
COMPLAINTS RESPONSE PERIOD
Process F5, Step 3
Complaints Procedure
Operational Terms
3 Portsmouth Water MAP 2 Responses
The customer may not receive a
substantive response within 10
days as required by Guaranteed
Service Standards, because the
Code gives the wholesaler alone
10 days to respond to the retailer
Wholesale-Retail Code
Part 4:
Page 38
TARIFF TIMING
4.5.3
Set of Tariffs on 1 April, subsequent July
Market Terms
The Company’s charging year
starts 1 July. The charges for the
first quarter for any year will be the
prior year charges.
We will calculate and publish our
wholesale tariffs in February as
required but the switch should not
be applied until 1 July.
CSD 0104
Page 28,
BULK METERS
Maintain SPID Data
2.3.5
Currently we are unaware of the identity of
individual premises supplied by a bulk meter
4 Portsmouth Water MAP 2 Responses
Are we required to collect and
provide this information?
PORTSMOUTH WATER’S REMAINING RESPONSES
Appendix 3 Wholesale
Retail Code Part 1:
Objectives, Definitions
and Principles
There is no definition of Quarterly reads. The Data
Transactions Catalogue allows for Bi-Annually or
Monthly only
We have some quarterly read
meters. Would we submit all of
the readings to the market, or
suppress every other read?
CSD 0301 Data
Transactions Catalogue
Page 59
Appendix 3 Wholesale
Retail Code Part 1:
Objectives, Definitions
and Principles
Page 8
Actual Daily and Annual Volume
We are struggling to understand
the meaning of this even after
reading CSD 0207. Can the
meaning please be clarified, e.g.
with a simple flowchart
Appendix 3 Wholesale
Retail Code Part 1:
Objectives, Definitions
and Principles
Page 8
Assessed Charges
We do not have an Assessed
Option. There are several different
methodologies used by other
companies – is one
recommended?
5 Portsmouth Water MAP 2 Responses
Appendix 3 Wholesale
Retail Code Part 1:
Objectives, Definitions
and Principles
Page 21
Wholesale-Retail Code
Part 2:
Page 6
Monthly Read Meters
Is the standard described a
minimum for these meters?
Most of our monthly read meters
are smaller than this, will they be
accepted as real reads?
Routine accuracy tests for meters
2.4.1
Business Terms
We see no need for this
requirement, we feel that it is
sufficient for retailer to be able to
request
Part 3, page 34 defines that
process
Wholesale-Retail Code
Part 2:
Page 7
2.4.3 (c)
Meters installed and maintained in accordance with
good industry practice
What is the definition used for
good industry practice? If not
specific does the statement need
to be present?
Installation of Retailer Equipment should be
suitably controlled by the wholesaler
We would agree to third party
equipment being installed on our
apparatus subject to a separate
agreement of conditions, including
the fitment of a dual pulse splitter
so that the wholesaler can also
use the AMR for leakage
purposes
Business Terms
Wholesale-Retail Code
Part 2
Retailer Equipment Part B
Page 10,
Section 6
6 Portsmouth Water MAP 2 Responses
Wholesale-Retail Code
Part 3:
Pages 73/74
Advising Retailer of Wholesaler Visit
Why does report of visit have to
be communicated within one day,
this is unduly onerous and five
would be more appropriate
Interim Supplier Allocation Process
Can an incumbent retailer opt in to
this process within their area of
supply?
Decision Maker: this CSD refers only to the
Function and define it as optional but other CSDs
also refer to the name and address
What is the function of this field?
Is it truly optional or mandatory?
The Planning Reference D2069 and Wholesale
Connection Reference D2009 are Required Items
for a new connection in the Data Transaction
Catalogue. Only the Planning Reference is
mentioned in CSD 0101, and the two items seem
to be synonymous.
We do not think there is any
benefit to the market in collecting
and sending the Planning
Reference. This should not be a
Required item.
Process F1, Step 3
Business Terms
Wholesale-Retail Code
Part 4:
Page 27,
4.3.9
Market Terms
CSD 0004
Interim Supplier
Allocation Process
Overall
CSD 0301 Data
Transactions Catalogue
Page 7,
CSD 0101 Registration
New Supply Points
Page 7,
CSD 0301
D2072
2.1
Pages 15 and 29
7 Portsmouth Water MAP 2 Responses
Please clarify what the Wholesale
Connection Reference is, as we
do not understand this item
CSD 0104
Page 19,
Maintain SPID Data
2.2.3.1
CSD 0104
Page 19,
Maintain SPID Data
2.2.3.1
CSD 0301
Page 15,
Data Transactions
Catalogue
D2008
8 Portsmouth Water MAP 2 Responses
Change in Standard Industrial Classification are in
No Impact on Charges section
SIC code changes described as
not impacting on charges - is this
true? There could be an impact on
VAT
SIC 80
Please confirm the format of SIC
80 e.g. 1 digit, 3 digit, etc., and
whether it is really Optional as
indicated in CSD 0301
The field description in the
previous version (6.0) of CSD
0301 Annex A, data item D2008
allows for 16 digits so does not
answer question
CSD 0104
Page 20,
Change of Banner Name
Maintain SPID Data
2.2.4
Function and Address of Decision Maker
CSD 0301
Page 34,
Data Transactions
Catalogue
3.1.2
Page 115,
Two business days seems to us
an unnecessarily stringent
standard for notifying these
changes without any benefit
accruing to the market, 5 would
seem more appropriate.
T155.2 and T155.0 are the only
transactions where this field is
Required
T155.2 & T155.0
We note that 3.1.2.1 is under
review
CSD 0104
Page 18,
Maintain SPID Data
2.2.2
CSD 0301
Page 58
Critical National Infrastructure indicator
What is the definition of this and
from where – e.g. central national
point - is it obtained?
Retailer requests Building Water via Form A, then
Wholesaler notifies market.
Process for cessation of Building
Water is not clear. How does
Retailer notify Wholesaler?
Data Transactions
Catalogue
CSD 0104
2.3.6 Building Water Status
Maintain SPID Data
9 Portsmouth Water MAP 2 Responses
CSD 0104
3.4.1.2 Deregistration
Each wholesaler must notify the Deregistration at
the same time
This is not practical, as different
companies are involved and
information needs to flow between
them
Maintain SPID Data
Step b i) page 54
CSD 0104
5.1, Meter Exchange, page
83
Meter Location Code is a Required Item
The available Codes do not cover
Wall Mounted Meter Boxes. We
request either an additional code
or an alteration to the M3
description.
2.1.2 Vacancy Scheme
Application, 3, page 12
Cryptographic hash required and every file made
into a single archive file
This requirement seems unduly
onerous. It should be possible to
follow an audit trail at both the
Wholesaler and Market Operator
in case of query
Forms
Form A: Application to
Connect to the
Wholesaler's Water Supply
System
Comprehensive form but no details for
infrastructure charges
Application forms should include
details to determine infrastructure
charges. The Demand Related
multiplier (DRM) is the current
standard.
Forms
Form F1 Metering Activity
No provision for commonly required reasons to visit
such as seized stopcock or low pressure
Provision should be added for
common service requests
Maintain SPID Data
CSD 0301
Data Transactions
Catalogue
CSD 0105
Error Correction and
Retrospective
Amendments
Page 59
Form G Complaints
10 Portsmouth Water MAP 2 Responses
Operational Terms
Process H4, page 96
Forms
Process H5, page 98
Forms V and W Gap Site
and Vacancy Scheme
Applications
11 Portsmouth Water MAP 2 Responses
Gap site incentive scheme and vacant premises
incentive payments will be set out in wholesale
tariff documents
Will these schemes be
standardised across the country?
Where two wholesalers are
affected, how will it be
apportioned between them