Code Governance Review UNC Modification Proposals

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Code Governance Review UNC
Modification Proposals
Chris Shanley - National Grid NTS
Significant Code Review (‘SCR’)
 UNC Modification Rules change
 3 main elements of proposal:
 Prevent an SCR related non-urgent Modification Proposal
being raised during an associated SCR period
 The treatment of Modification Proposals determined as
relating to a SCR
 Withdrawal or variation of SCR driven Modification Proposals’
Self-Governance (‘SG’)
 UNC Modification Rules change
 3 main elements of proposal:
 Clarification of when a Modification Proposal shall follow the
Self Governance route
 A Self Governance Determination by the UNC Panel
 Appeals Process
Environment / Objectives
 where the impact is likely to be material, the evaluation of
the proposed modification in respect of the relevant
objectives shall include an assessment of the quantifiable
impact of the proposed modification on greenhouse gas
emissions, to be conducted in accordance with any such
guidance (on the treatment of carbon costs and evaluation
of greenhouse gas emissions) as may be issued by the
Authority from time to time; and
 Key Elements –
 Evaluation of proposed modifications shall include
assessment of the quantifiable impact on greenhouse gas
emissions
 Details to be included in reports produced during progression
of the proposal
Charging Methodologies
 Two proposals
 NTS Charging Methodology and Connection Charging Methodology
 Distribution Network Charging Methodology
 Key elements:
 Existing methodology (to be detailed in Appendix A) is incorporated
within the Uniform Network Code
 UNC Modification Rules are amended to reflect that:
 a change to the Charging Methodology is not able to be made unless
the requirements of the UNC Modification Rules are complied with
 the Transporters must convene regular meetings of the charging
methodology forum/s
 a Modification Proposal in respect of a UNC Charging Methodology
may only be made by a UNC signatory or a Materially Affected Party
(being a person or class of persons designated by the Authority for this
purpose)
Role of Code Administrators & Code of Practice
 The CGR Final Proposals require that code administrators:
 Act as a ‘critical friend’, in particular to small participants; and
 Act consistently with the Code Administrator Code of Practice.
 Other key elements:
 Ofgem send back powers
 Published reasons for Panel recommendations (based on relevant
objectives)
 Legal text provision
 Cost information
 Super Mod (in terms of volume of changes to the mod rules)
Alternatives
 Aspect of the CoP workstrand - the approach to be taken
when raising alternatives to Amendment Proposals:
 alternative solutions being developed to the same degree as
an original solution; and
 alternative proposals are raised prior to or during the working
group stage.
 Proposed that the UNC adopt a similar approach to the
CUSC
Alternatives flow chart (part 1) – pre panel
User 1 raises
new
Modification
Proposal
User 2 notifies JO no
later than D-1 of Panel
meeting they believe
an alternative is viable
(with outline of the
alternative or a draft
Modification Proposal)
No later than noon
on D-1
Modification Proposal,
alternative
modification
proposals, and outline
of Alternative(s)
Proposals to Panel
Consultation
Panel decide
route to be taken
Development
Alternatives flow chart (part 2) – development route
Further development
i.e. Review Group or
Workstream
Assessment including
developing any
Alternatives ( in line
with normal
workgroups )
Alternative outline provided to Panel
originally - Modification should be
supplied no later than D-5 of the first
meeting
If
workgroup
members believe a
pre consultation required
made to Panel (normal
UNC rules
apply)
No
The workgroup will make a
recommendation on which mods
better the relevant objectives
and vote, as to which option is
the BEST. View to be include in
the report
Yes
Working Group
Report submitted to
the Panel for
approval
No
Panel Accept
Report
Yes
With Panel
approval proceed
to consultation of
original and
alternatives
Yes
Panel
approve
preconsultation
Alternatives flow chart ( part 3) – consultation route
Consultation
Consultation
UNC parties
respond
Draft Report
Panel vote
Final Report
submitted to
the Authority
Authority
decision
Note no further
Alternatives
can be raised
Appointment and Voting Rights for a Consumer
Representative and Independent Panel Chair
 Modification Proposals 0286 and 0286A: “Extending Modification Panel
Voting Rights to Consumer Representative(s)”
 Ofgem minded to approve 0286A (early July?)
 Main elements of proposal:
 Option for the Authority to appoint a further Consumer
Representative member
 Independent chair’s casting vote
 Other industry participants may wish to consider any other beneficial
changes to the composition of the UNC Panel. It is our view that this
should be addressed outside of this proposal.
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