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EFR Plan Checklist V5.0

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EFR Plan Checklist

Guidance Note

What this document covers

    • A brief introduction to the Error and Failure Resolution (EFR) Performance Assurance Technique (PAT), what it is intended to achieve, and how and when it is applied;

    • Advice making sure your EFR plan meets the minimum standard required by Elexon and the Performance Assurance Board (PAB)

What this document does not cover

    • Detailed information on the EFR PAT, what it is intended to achieve, and how and when it is applied, which is included in a separate Guidance Note that also includes:

      • The actions Parties and Party Agents should take when they are being considered for EFR

      • The timescales for producing and reviewing an EFR plan once the technique has been deployed;

      • How EFR plans are monitored and how and when a plan can be closed;

      • When and how EFR plans can be escalated to the PAB or BSC Panel, and the possible consequences should this happen.

    • Details of how to achieve compliance with the BSC, which can be found in the Code itself as well as the BSC Procedures (BSCPs)

Your Operational Support Manager (OSM) is your first point of contact for EFR and is available to support you through the process.

If you have a more general question about EFR, please raise a ticket through the online Elexon Support portal.

What is EFR?

EFR is a Remedial PAT used to assure Elexon, the PAB and the rest of the industry that Performance Assurance Parties (PAPs) understand performance issues and have robust plans in place to correct them in a timely manner. It is formally documented in BSCP538: Error and Failure Resolution.

In particular, EFR is used:

          1. In cases where Elexon and/or the PAB judge that a Party or Party Agent requires Elexon’s support in order to meet its obligations under the Code; and/or

          2. To provide additional visibility and accountability around a Party or Party Agent’s plans where Elexon and/or the PAB judge that the continuing non-compliance poses a significant risk to the accuracy of Settlement, and therefore to the interests of all participants in the energy market.

PAPs in EFR are required to provide Elexon with a detailed plan showing the actions they will take to address the performance issue. This plan must include milestone dates for completing these actions, and forecasts of any associated improvement in performance metrics.

When is EFR applied?

Elexon identifies when EFR is needed through information from other assurance techniques, particularly Performance Monitoring and Reporting, the BSC Audit and Material Error Monitoring.

Settlement Performance EFR Plans

Elexon and the PAB deploy EFR for Suppliers based on their Settlement Performance against the standards set out in Annex S-1.21 of the BSC.

Each quarter, Elexon and the PAB agree a “Focus Threshold” to ensure that EFR remains focussed on the Suppliers contributing the greatest negative impact to overall Settlement Performance. These reviews are then made public through the Elexon website.

Elexon and the PAB consider all Suppliers whose volume of monthly non-compliant estimation falls below the levels set at these Reviews for EFR in accordance with the timetable set out in the review.

However, any Supplier with performance below the standards set out in the Code will be considered for EFR where Elexon or the PAB judge this appropriate.

BSC Audit Issue EFR Plans

Elexon can deploy EFR for any BSC Party or Party Agent where the BSC Auditor has identified a material non-compliance with the Code.

In general, Parties and Party Agents should expect that Elexon will deploy EFR for all High or Medium BSC Audit Issues, and for any Low BSC Audit Issues that have:

    • Persisted for more than one PAOP; and/or

    • Pertain to one of the current Focus Risks as set out in the Risk Operating Plan (ROP).

Again, any Party or Party Agent with open Material BSC Audit Issues may be considered for EFR where Elexon or the PAB judge this appropriate.

Other EFR Plans

Elexon and the PAB may choose to deploy EFR for any PAP based on the outcome of any other Performance Assurance Technique or on relevant information received from any other source or process.

Preparing Your EFR Plan

Whilst the specific contents of each EFR Plan will be different, plans that successfully deliver improvements to performance tend to have certain features in common.

In general, such plans tend to:

    • Have secured an appropriate level of commitment from across an organisation, including providing additional resource if this is needed to ensure success

      • Your EFR plan must be signed off by someone within your organisation who is able to allocate the necessary resource for the plan to succeed

    • Show an understanding of the obligations in the BSC and relevant BSCPs associated with the non-compliance, and what is required to meet them

      • Your OSM is available to answer any questions you may have about your BSC obligations and will be happy to arrange any additional education or training you may require

    • Clearly set out all of the root causes for the current non-compliance

    • Identify specific actions to address these root causes, and have a clear idea of who will complete these and by when

    • Directly connect these actions to forecast measurable improvements (for an example, a % increase in Settlement Performance, or decrease in a backlog of unprocessed dataflows)

      • For example: ‘3% of our energy is Settled on Estimated Annual Consumption from sites that are scheduled to have a Smart meter installed by the end of January. Our success rate for completing scheduled installations is 50%. We are therefore forecasting a 1.5% increase from this workstream in the percentage of our energy Settled on Annualised Advances by the end of January.

    • Identify dependencies on internal and external stakeholders (for example, software development teams or Supplier Agents) and put in place strategies for mitigating any risk these pose to the overall success of the plan

The following section provides a checklist to help you review your EFR plan before submitting it to your OSM.

You should use the checklist in conjunction with the EFR and EFR Escalation Process Guidance Note, particularly the Section “What should I include in my EFR Plan?”

BSCP538 includes an EFR Plan template that can help you structure your plan, although you are not required to use it.

Checklist for Reviewing Your Plan

Question

Y/N

1

Has your plan been reviewed and signed off by someone who is able to allocate the necessary resource for it to succeed? Does this person have sufficient authority to enact major operational changes in the business?

Does this person understand that they may be required to attend a PAB Escalation meeting if the plan does not succeed?

Is appropriate governance in place to ensure progress against the plan? Is this communicated to the sponsor?

2

Have you reviewed the relevant sections of the BSC and BSCPs before preparing your plan?

Are you confident that you fully understand your obligations concerning the non-compliance the plan will address? Have you checked this understanding with your OSM if not?

3

If your plan is for a BSC Audit Issue, have you reviewed the BSC Auditor’s findings and recommendations?

Are you confident that you fully understand their findings? Have you checked this understanding with your OSM if not?

4

If your plan is replacing a previous plan that has failed and/or is for a BSC Audit Issue that has persisted for more than one year, have you reflected on why your previous efforts to rectify the non-compliance failed?

How does your new plan differ, and are you confident that it will succeed?

5

Does your plan provide a clear analysis of all of the root causes of the non-compliance?

6

Does your plan provide details of the specific actions that you will take to address the root causes you have identified?

Do you have a clear idea of who will be taking these actions?

7

Have you provided milestone dates by which time you will have completed these actions?

Have you tied these dates to specific, measurable improvements so that you can confirm the actions are delivering the intended results?

(For example, have you included monthly milestones showing expected improvements in Settlement performance, or reductions in backlogs of unprocessed data flows?)

8

Have you provided details of how many people will be working to complete these actions, and how much time they will be spending on this each day and/or week?

Do they have enough time to complete them by the milestone dates you have set?

9

If your plan involves process changes, does it detail how you will inform and train your staff about these?

Does your plan detail how you will check they are adhering to the new process?

Will you have reporting in place to demonstrate the changes have addressed the non-compliance?

10

If your plan involves software changes, does it provide regular milestones to confirm the plan for implementing these is on track?

Will you have reporting in place to demonstrate the changes have addressed the non-compliance?

Does your plan also include an interim manual process? Does it identify who is responsible for carrying this out?

Do they have enough time to do so?

11

If your plan depends on work by stakeholders from different teams and/or organisations, have you detailed how you will manage their work and ensure that actions are delivered?

If you are a Supplier, have you obtained appropriate commitments from external organisations (especially Party Agents such as Data Collectors, Data Aggregators, and Meter Operators)?

Do you have sufficient escalation pathways available to you if they do not carry out work to the required standard and/or schedule?

12

Does your plan give clear details of the key risks to the plan’s success, and how will you mitigate these?

Have you considered what impacts your plans for Qualification and Migration under Market Wide Half Hourly Settlement (MHHS) will have on your performance in Legacy arrangements?

13

Bearing in mind all of the above, are you confident that your plan will return you to a compliant standard by the date you have specified?

Do you need more information?

Your OSM is your first point of contact for EFR and is available to support you through the process. If you’re not sure who they are, check the BSC Signatories and Qualified Persons page of our website.

The Elexon website has more information on the Performance Assurance Framework, including EFR, the Settlement Performance Standards and the BSC Audit.

More information about the specific BSC Processes and managing the Risks associated with them can be found in Elexon’s Digital BSC, especially the BSC Procedures (BSCPs) and Guidance Notes.

For any other information please raise a ticket through the online Elexon Support portal.

Intellectual Property Rights, Copyright and Disclaimer

The copyright and other intellectual property rights in this document are vested in Elexon or appear with the consent of the copyright owner. These materials are made available for you for the purposes of your participation in the electricity industry. If you have an interest in the electricity industry, you may view, download, copy, distribute, modify, transmit, publish, sell or create derivative works (in whatever format) from this document or in other cases use for personal academic or other non-commercial purposes. All copyright and other proprietary notices contained in the document must be retained on any copy you make.

All other rights of the copyright owner not expressly dealt with above are reserved.

No representation, warranty or guarantee is made that the information in this document is accurate or complete. While care is taken in the collection and provision of this information, Elexon Limited shall not be liable for any errors, omissions, misstatements or mistakes in any information or damages resulting from the use of this information or action taken in reliance on it.

1 Annex S-1: Performance Levels and Supplier Charges