Declaration of SVA Storage Facility for Exclusion from Transmission Network Changes

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Declaration of SVA Storage Facility for Exclusion from Transmission Network Changes

Guidance Note

Background

This guidance document supports the processes introduced on 1 April 2021 by P383 ‘Enhanced reporting of demand data to the NETSO to facilitate CUSC Modifications CMP2801 and CMP2812 and in particular gives information on how to complete the forms required to declare an SVA3 Storage Facility.

Imports to generator and storage facilities are both liable to TNUoS4 demand residual charges and BSUoS5 demand charges. In accordance with CUSC Modification Proposals CMP280 and CMP281, it is argued that Storage Facilities are disadvantaged compared to other generators because their Imports are so much higher. This means that Storage Facilities are likely to attract much higher TNUoS demand residual charges compared to other generators who typically avoid this charge and contribute twice as much toward BSUoS because they are charged both for their Imports and Exports. These concerns were set out in Ofgem and BEIS’ Smart Systems and Flexibility Plan and more recently as part of Ofgem’s Targeted Charging Review.

In order to support the implementation of approved CUSC Modification Proposal CMP281 Elexon implemented P383 on 1 April 2021. P383 introduced processes to collect and report the Imports to certain storage facilities (SVA Storage Facilities) in the P0210 ‘TUoS6 Report’ that BSCCo sends to NETSO7. NETSO uses the P0210 TUoS Report in its calculation of TNUoS and BSUoS. This way NETSO can exclude SVA Storage Facility Imports from its calculation of BSUoS demand charges.

This guidance supports the processes introduced by P383 and in particular gives information on how to complete the forms required to declare an SVA Storage Facility. The Declaration form should be completed by Suppliers and SVA Storage Facility Operators and sent to the SVAA8. Once a Storage Facility is successfully declared, the SVAA collects metered data from the facility’s MSIDs9 and aggregates the Imports with other facility’s Imports and reports these in the P0210 to the NETSO , alongside Supplier BM Units’ overall ‘corrected’10 and actual gross HH metered volumes. This allows the NETSO to calculate network charges excluding SVA Storage Facilities Imports. In order for the SVAA to report the Imports to SVA Storage Facilities in the P0210, SVA Storage Facility Operators, via their Supplier(s), must register SVA Storage Facilities with SVAA including all associated SVA MSIDs.

The forms that SVA Storage Facility Operators and Suppliers need to complete to notify the SVAA of an SVA registered Storage Facility or de-register a storage facility are in BSCP602SVA Metering System Register. The SVAA will check the details of the SVA registered Storage Facility at first registration and the SVAA and BSCCo will then check monthly that the Storage Facility is continuing to operate as such to provide assurance that only SVA Storage Facilities are excluded from Transmission network charges. Any Storage Facility that fails these checks will no longer have its Imports reported in the P0210 and will become the subject Transmission network charges again.

CVA Storage Facilities - The processes introduced by P383 do not include Storage Facilities with MSIDs registered for CVA11, These CVA Storage Facilities are registered directly with the NETSO as these facilities have dedicated BMUs which NETSO maintains dedicated registration details for and receives BMU specific metered data for, Therefore NETSO is able to correct the calculation of network charges for CVA Storage Facilities within its own systems.

BUSoS Settlement by NGESO – We understand that NGESO Settles BUSoS at SF12 and RF13. Therefore, although BSCCo sends the P0210 TUoS Report (containing the MSIDs that should be excluded for the purposes of calculating BSUoS) to NGESO for every Settlement Run, under the CUSC, we understand that NGESO only reconcile (and pay) twice (once at SF, then only again at RF).

What Assets can I register as an SVA Storage Facility?

The Assets that you can register are ones that meet the definition of an SVA Storage Facility under the Connection and Use of System Code (CUSC).

The CUSC defines an SVA Storage Facility as follows:

‘SVA Storage Facility is an Electricity Storage Facility that:

    1. performs Electricity Storage as its sole function;

    2. is operated by a Storage Facility Operator who also holds a generation licence;

    3. has its imports and exports, measured only by Half Hourly Metering Systems which are registered in the Supplier Meter Registration Service (SMRS) as part of a Supplier BM Unit, and where those Half Hourly Metering Systems only measure activities necessary for performing Electricity Storage; and

    4. is the subject of a valid Declaration.’

The Declaration referred to in ‘iv’ is the one that you are applying for in accordance with the BSC and the processes and forms in BSCP602

Electricity Storage Facilities that are co-located with other forms of generations, e.g. Photo Voltaic (PV) cells or hydro power, or final demand, e.g. a home of office, and where those other activities share the same MSIDs as the storage facility do not qualify as SVA Storage Facilities. This is because the Imports and Exports measured by the MSIDs are measuring activities that are not Electricity Storage and therefore do not comply with (iii) in the CUSC definition of an SVA Storage Facility.

SVA Storage Facility Declaration Document form – completed by Supplier and SVA Storage Facility Operator

In order to declare an SVA Storage Facility, the SVA Storage Facility, through its Supplier(s), for the storage facility needs to register it with the SVAA using form BSCP602/01. The Storage Facility Operator (SFO) needs to complete sections B, C and D of form 602/01 (with assistance from the Supplier as appropriate) and send this to the Supplier who will add their authorisation details14 in part A and send it onto the SVAA by sending it to bscservicedesk@cgi.com

The following sections provide guidance on how to complete sections C and D of form F602/01.

If the same Supplier and Storage Facility Operator wants to declare more than one Storage Facility in section B of form 602/01, then a separate Part C and D of the form needs to be completed for each Storage Facility.

Declaration Type:

Choose only one from15:

New –SVA Storage Facility declared for the first time or redeclared after being withdrawn.

CoS – Change of Supplier - identifies that at least one MSID related to the SVA Storage Facility has been the subject of a change of Supplier.

CoA – Change of Agent – identifies that at least one MSID related to the SVA Storage Facility is now managed by a different HHDA

CoM – Change of Metering System - identifies that the SVA Storage Facility has had at least one MSID added or removed from a Declaration(s)

Withdraw – identifies that the SVA Storage Facility’s Declaration(s) should be end-dated

Declaration Set Id:

A unique value (up to 80 characters) assigned by the SVA Storage Facility Operator and used to identify a single Declaration or unite multiple Declarations in respect of different Suppliers, submitted in Declaration Document(s) at a particular point in time for an SVA Storage Facility.

The SVA Storage Facility Operator should assign a new Declaration Set ID when it updates a single Declaration or multiple Declarations for an SVA Storage Facility.

Declaration Id (where known):

This is a value generated and assigned by SVAA. For new declarations, leave blank.

For CoS, COA, CoM or withdraw, the Declaration Id assigned by the SVAA on successful processing of the previous Declaration.

Declaration Set Effective Date:

The date a Storage Facility’s declaration first takes effect or the date on which a change to an existing declaration takes effect, e.g. the date on which a new Supplier is the registrant for one of the Facility’s Metering Systems.

SVA Storage Facility Operator (SFO) Participant ID

A unique, up to eight character ID chosen by the SVA Storage Facility Operator. This cannot be the same as any other SVA Storage Facility Operator Participant IDs. Nor can it be the same as any existing BSC Party Id unless the SVA Storage Facility Operator and the BSC Party are the same entity.

Please check the BSC Signatories and Qualified Persons webpage to ensure that your Participant Id is not currently in use by a BSC Party. The SVA Storage Facility Operator Participant IDs are not published but the SVAA will ask you to change your ID if it is already in use.

SVA Storage Facility Operator (SFO) Company Number

Storage Facility Operator Company Number as registered with Companies House

SVA Storage Facility Operator (SFO) Company Name

Storage Facility Operator Company Name as registered with Companies House and with Ofgem as a Generation Licence holder.

SVA Storage Facility Operator (SFO) Company Address

Storage Facility Operator Company Address as registered with Companies House

SVA Storage Facility Operator (SFO) Company Director

Storage Facility Operator Company Director as registered with Companies House and the director who signed the Declaration Document.

SVA Storage Facility Operator (SFO) Contact Name

The name of the person dealing with the Declaration on a day to day basis who may be the director or another person

SVA Storage Facility Operator (SFO) Contact Phone

The phone number of the SFO Contact

SVA Storage Facility Operator (SFO) Contact Email

The email address of the SFO Contact

Storage Facility (SF) Id

A unique up to 30 Character code assigned by the SVA Storage Facility Operator. Where possible it should be a simple reference (ideally numerical) to reduce the risk of error when reading/processing declarations.

Storage Facility (SF) Name

The legal or operational name of the Storage Facility.

Storage Facility (SF) Address/Location:

The address and/or location (e.g. grid reference) at which the Storage Facility is located.

Storage Facility (SF) Description

A short description of the facility including the type of storage technology and the rated capacity (MW).

Storage Facility (SF) Effective From Date:

For new, CoS, CoA and CoM declarations: The date from which the storage facility should be treated as an SVA Storage Facility or the date that the CoS, CoA and CoM took place. This date cannot be earlier than the submission date of the form without prior agreement from Elexon. For withdrawals include the date of the last action (initial registration, Cos, CoA or CoM).

Storage Facility (SF) Effective To Date:

For withdrawals: The date from which the Storage Facility should no longer be treated as an SVA Storage Facility. Leave blank for new, CoS, CoA and CoM declarations.

Storage Facility (SF) Total MSIDs Count:

The total number of Metering Systems measuring Imports to and Exports from the SVA Storage Facility which may be registered by one or more Suppliers.

e.g. if a SVA Storage Facility has a total of four MSIDs, two registered by one Supplier and two registered by another, the total MSID count on each Supplier’s declaration would be four but each Supplier would only provide the details relating to two MSIDs.

MSID

The unique market wide reference for a Metering System. Also known as Metering Point Administration Number (MPAN)

Import/Export Indicator

Identifies whether a Metering System is an Import Metering System or Export Metering System

GSP Group

The GSP Group within which the SVA Storage Facility is connected (_A, _B, _C, _D, _E, _F, _G, _H, _J _K, _L, _M, _N or _P).

MSID EFD (Storage Facility)

The date from which an MSID is associated with an SVA Storage Facility for the purpose of this declaration process.

MSID ETD (Storage Facility)

The date from which an MSID’s association with an SVA Storage Facility ends for the purpose of this declaration process.

Supplier MPID

The Market Participant ID for the Supplier. The SVA Storage Facility Operator may need to liaise with its Supplier(s) to identify the Supplier MPIDs to include in its Declaration Document.

MSID Supplier EFD

The date from which an MSID is registered by a Supplier in SMRS.

HHDA MPID

The Market Participant ID for the Half Hourly Data Aggregator appointed by a Supplier to a Metering System. The SVA Storage Facility Operator may need to liaise with its Supplier(s) to identify the HHDA MPIDs to include in its Declaration Document.

HHDA EFD

The date from which a Supplier appoints/appointed a Half Hourly Data Aggregator to a Metering System. This date should correspond with the HHDA’s EFD for the Metering System in SMRS. Note that the HHDA EFD may predate the Declaration Set EFD.

Please submit completed Declaration Documents to bscservicedesk@cgi.com .

Note that where MSIDs for an SVA Storage Facility are registered by different Suppliers, each Supplier must submit the Declaration Document for its MSIDs for a new declaration, CoS or CoM. All Declaration Documents related to that Storage Facility must be submitted within 5 Working Days of the first declaration being submitted otherwise they will be rejected. If there is a CoA, only the Supplier who is changing HHDA needs to resubmit the declaration. If the Storage Facility is being withdrawn from the process, only one Supplier needs to submit the declaration document which will cause the withdrawal of that Storage Facility and all MSIDs whether registered to that Supplier or other Suppliers.

An SVA Storage Facility can be declared as such by a Supplier for the purpose of exclusion of the Storage Facility from Transmission network changes. It can concurrently be registered by a Virtual Lead Party for the purpose of providing Balancing Services and / or be used to provide non BM Applicable Balancing Services to the NETSO.

Effective To Dates

Note that the Effective From Date of a Declaration Document or MSID is midnight at the start of that day. The Effective To Date of a Declaration Document or MSID is 23.59pm at the end of that day. When withdrawing an SVA Storage Facility the form asks the Storage Facility Operator to declare the date that the Storage Facility will cease to be an SVA Storage Facility. As at the date quoted the Asset will no longer be a Storage Facility, the Effective To Date will be recorded as the day before the date on the form. For example, if an Operator declares that an SVA Storage Facility will cease to be as of the 1 April then the SVA Storage Facility’s ETD will be set as 31 March.

In Summary:

    • New declaration

      • The storage facility EFD and MSIDs EFDs in declaration = declaration effective date16

    • Change of MSID declarations

      • Any storage facility MSID being added must have MSID EFD in declaration = declaration effective date

      • Any storage facility MSID being removed must have MSID ETD in declaration = declaration effective date – 1 day

    • Change of Supplier declaration

      • Any storage facility MSID changing to new supplier must have MSID Supplier Registration EFD = declaration effective date

        • The MSID’s previous Supplier Registration ETD = declaration effective date – 1 day

    • Change of Agent declaration

      • Any storage facility MSID changing to new HHDA must have MSID HHDA Appointment EFD = declaration effective date

        • The MSID’s previous HHDA Appointment ETD = declaration effective date – 1 day

    • Withdraw Storage Facility declaration

      • The effective date is the first day of withdrawn facility

      • Storage Facility Effective To Date needs to be set to declaration effective date – 1 day (i.e. last day facility is active)

    • Withdraw Operator letter

      • Letter contains an “as of” date which is the effective date of the withdrawal (i.e. first day operator no longer operating)

      • Storage Facilities Effective To Dates need to be set to declaration effective date – 1 day (i.e. last day each facility is active)

Need more information?

For other information please contact the BSC Service Desk at bscservicedesk@cgi.com or call 0370 010 6950.

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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.

3 SVA ‘Supplier Volume Allocation

4 TNUoS ‘Transmission Network Use of System

5 BSUoSBalancing Services Use of System

6 TUoS ‘Transmission Use of System

7 NETSO ‘National Electricity Transmission System Operator

8 SVAASupplier Volume Allocation Agent

9 MSIDs ‘Metering System Identifiers’

10 Supplier BM Unit gross HH demand is reported as Period BMU Gross HH Demand in the P0210. This represents all gross HH Imports attributed to the Supplier BMU, irrespective of whether Imports are to an SVA Storage Facility. A ‘corrected’ value of Period BMU Gross HH Demand is also reported which is Period BMU Gross HH Demand less any Imports to SVA Storage Facilities (separately reported as Period BMU Gross Storage Demand). The ‘corrected’ value is reported as Corrected Period BMU Gross HH Demand.

11 CVA ‘Central Volume Allocation

12 SF ‘Initial Settlement Run

13 RF ‘Final Reconciliation Settlement Run

14 Part A must be completed by a Supplier’s Category A or F authorised person.

15 Where the operator wishes to inform SVAA of more than one Declaration (and therefore identify different Declaration Types) it may fill in and include multiple versions of Part C in a single Declaration Document.

16 Note that the Supplier and HHDA EFD may predate the Facility and MSID EFDs.