Material Change and Triggers for re-Qualification
Material Change and Triggers for re-Qualification |
Guidance Note |
Material Change and Triggers for re-Qualification
Changes that are highly likely to have an impact on a Qualified Person’s ability to meet its BSC Obligations would normally be a Material Change and it is almost certain that re-Qualification would be required;
Changes that are likely to have an impact on a Qualified Person’s ability to meet its BSC Obligations may be the subject of a discussion with Elexon to determine whether they would constitute a Material Change;
Changes that are unlikely to have an impact on a Qualified Person’s ability to meet its BSC Obligations would not normally be the subject of a discussion with Elexon and re-Qualification would probably not be required;
The impact of a change and its potential to trigger a re-Qualification exercise will vary at different agent organisations. Where it is unclear from the results of a Risk and Impact assessment conducted on any change whether or not re-Qualification is required, the organisation should consider the questions and obligations in the SAD which may be impacted, and if necessary contact Elexon for further guidance;
Changes to the core IT systems used to operate the Qualified Persons’ service (and hence deviation away from those system that were Qualified) may be the subject of a discussion with Elexon to determine the scale of the risk to and potential impact on BSC Obligations should those changes not be appropriately implemented;
The Qualification Requirements embodied in the SAD should be considered when assessing the impact of a proposed change that may impact the declarations made previously by a Qualified Person;
All aspects of a change (system, processes, staff etc.) should be considered to determine if the change is a Material Change. Where any one of these is highly likely, the change is likely to be a Material Change but a combination of likely impacts may also be a Material Change;
A change may be a single change implemented in isolation or a group of changes that are batched together for implementation;
The extent of the SAD which would be completed and the level of supporting evidence required will vary per application, based on the scope of the re-Qualification and initial assessment of the risk of the re-Qualification applicant by Elexon.
0.1 Table 1: Example re-Qualification Triggers
Typical Impact on BSC Obligations | |||
| Unlikely | Likely | Highly likely |
System Change | Changes to non-Settlement interfacing systems. | Replacement of IT system core to the operation of the agency service with established, proven system. | Replacement of Settlement systems with a new, unproven system. |
| Minor software application version upgrades. | Major upgrade of IT systems core to the operation of the agency service. | Bulk migration of data with industry content between systems. |
| Software changes that do not affect the structure, format or calculated content of data flows sent to other participants. | Replacement of flow router or gateway. | Upgrade to or replacement of systems which impact inter-operation with other participants. |
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| Upgrade to server or operating system. |
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Process Change | Changes to non-Settlement interfacing processes. | Manual process replaced by automated process (industry facing). Process modifications that affect the calculation of any data items that are subsequently transmitted to another participant. | Multiple manual processes replaced by automated processes (industry facing). Major rewrite of business processes used for the operation of the agency service, requiring new supporting documentation (e.g. Local Working Instructions) and staff re-training. |
Staff Change | Changes to appointed sub-contractors. | Staff changes due to acquisition of new company. | Relocation requiring total staff replacement. |
Change of Ownership | Qualified Party has been sold and all staff, systems and processes remain the same. | Qualified Party has been sold and some staff, systems and processes remain the same. | Qualified Party has been sold and very few staff, systems and processes remain the same. |
Growth | Step changes under an agent’s previous maximum Certified volume (granted under the Accreditation and Certification process before Modification P197 implementation) would not require a re-Qualification exercise as the agent will have demonstrated volume and performance capabilities when the maximum Certified volume was granted, This also applies for step changes arising as a result of the Bulk Change of Agent Process which is covered in BSCP513: Bulk Change of NHH Supplier Agent | Step changes in number of Metering Systems for which the agent intends to be responsible (for example an increase of 25% in the number of Metering Systems in 2 months) over the agent’s previous maximum Certified volume, or volume capabilities demonstrated through testing under the Qualification Process. This also applies for step changes arising as a result of the Bulk Change of Agent Process. It should be noted that there is no set ‘tolerance’ percentage level for step increases in Metering Systems; this may vary at different organisations and by agent type. Factors for consideration when assessing the need for a re-Qualification in this area should include (but not limited to); current operating volumes, previous maximum Certified volume, previously tested volumes, previous demonstration of business expansion and timescales for the step change. |
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Significant Non Compliance |
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| Where suggested by the PAB due to the number of non-compliances identified by other PAF techniques, e.g. the number of BSC Audit issues that a participant has (Party Agents/AMVLP Agents and SMRAs only). |
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1 Material Change is defined in Section X-1 of the BSC as being a proposed change to the Qualified Person’s systems and processes has the potential to impact that person’s ability to meet its obligations under the Code.
2 The Removal of Qualification process is documented in BSCP537: SVA Qualification Process for BSC Parties, Party Agents and CVA Meter Operators.