Introduction

• General good practice;

• The options available to a Replacement Supplier;

• Examples of potential pitfalls to watch out for and good practice for each of the options;

• The information that Elexon will request from you to help understand the approach you are taking and the controls you are putting in place;

• How to use Elexon’s performance reporting to ensure the management of the SoLR is not resulting in any Settlement Performance issues; and

• The Performance Assurance Framework (PAF) responsibilities of the Replacement Supplier following a SoLR.

• General advice to Agents affected by SoLR activities.

• Elexon’s Defaulting Party and Failing Supplier Guidance Note; and

• Ofgem’s Supplier of Last Resort Guidance

General good practice

• Contact the appointed agents of the failing Supplier to inform them of your plans timeframes and any impacts this may have on their business , for example with regards to submission of de-appointment and other Change of Supplier (CoS) or Change of Agent (CoA) flows;

• Contact any agents you plan to appoint to the new Metering System Identifiers (MSIDs) to inform them of your plans and any impacts this may have on them, for example with regards to submission of appointment and other CoS or CoA flows;

• Contact the Administrator of the failing Supplier, where one has been appointed, and agree a clear view between both organisations of Settlement volumes associated with the account on the date of the change; whilst this isn’t a Settlement obligation, it can help to avoid misunderstanding between the two organisations and identify any issues early;

• Compare this information to any data you are provided with from Ofgem around the customer base of the failing Supplier;

• Ensure you have controls for identifying any data quality issues associated with the MSIDs you have been appointed to, and that any problems you identify are addressed quickly;

• Contact Electralink and ensure they are aware of the SoLR event. They can advise on any Data Transfer Network (DTN) changes (such as flow re-routing) that will be necessary;

• Ensure you have processes in place to request reads from customers of the failing Supplier, followed up by a robust read strategy that identifies and addresses the root cause of any problems processing these reads; Ofgem advises customers of failing Suppliers to take a Meter read when they announce the appointment of a SoLR, and getting accurate actual reads processed properly will be the best way to make sure that the MSIDs you are appointed to are settled accurately;

• Monitor the Settlement performance data you receive from Elexon and via any relevant DTN (or other) flows, to identify and quickly work to resolve any issues not picked up by other processes; and

• Liaise regularly with your Elexon Operational Support Manager (OSM) to inform them of how you are progressing with the actions, and advise them of any possible help or support you may need (for example, contact details for Agents you may not currently work with, or any additional data that would be helpful to you).

The options available to a Replacement Supplier

• Responsible for the BM Units’ Exports and Imports;

• The Registrant for all Metering Systems associated with those BM Units; and

• Liable for all charges and benefits relating to the Metering Systems.

• Responsible for the failing Supplier’s MPID

• Manage the new MSIDs using the Supplier Id that had belonged to the failing Supplier; or

• Undertake a CoS at a later date to transfer the MSIDs to one of your existing MPIDs

Potential Replacement Supplier pitfalls and mitigations

• You should have a clear migration plan in place, with indicative numbers of migrations against dates; these dates should take into account any external limitations on what you will be able to process – for example, the Gas market has a hard limit of 5000 registrations that some Suppliers have found restricts the number of dual-fuel customers they are able to register in a single tranche and you may need to consider whether your plans exceed the Bulk Change of Agent threshold set out by the BSC Panel and follow the process set out in BSCP513 “Bulk Change of NHH Supplier Agent” ;

• Your plan should consider any additional resources that will be required both at your business and your agents’ in order to complete the migration work and address any issues encountered along the way;

• Your plan should include regular migration reports to check for any issues, and be clear as to who is responsible for addressing these, including clearly defined escalation points;

• Depending on the number of MSIDs to be migrated, you may wish to consider undertaking a small pilot migration to see if any issues are encountered, and make sure these are addressed before continuing with the migration;

• You should share this plan with your Elexon OSM, and keep them updated throughout any migration activities;

• Whether you have undertaken a pilot migration or not, you should keep track of root causes for any issues you encounter during the migration, and analyse any common root causes to determine if changes to your chosen approach are required;

• You should take steps to ensure that all account details are up-to-date and accurate, and that any notes or issues logged on a customer’s account are resolved; where the data provided to you by Ofgem or the failing Supplier is missing or incomplete, you should have a clear strategy in place for obtaining the missing information as quickly as possible;

• You should take steps to ensure that there will be a full set of agents appointed and Meter Technical Details (MTDs) in place for each MSID that is due to be migrated, and check to make sure that this is the case once migration is complete;

• You should take steps to ensure that any exceptions (for example, those indicated by D0095¹ and D0023²), whether open before or created by the migration, are investigated and addressed; for the prior MPID; and

• You should take steps to ensure that any excessive Estimated Annual Consumption (EACs) / Annualised Advances (AA)s whether in place before or created by the migration, are detected, investigated, and addressed. Excessive EAC and AAs are common after SoLRs as the customer read provided may be out of line with the previous consumption. This is particularly important in the event of a SoLR as the failing Supplier will no longer be available to review the CoS read against the previous consumption so a control point is lost.

• Firstly, it is not required for settlement but you should consider how best to establish a boundary marking the point that you took responsibility for the MSIDs for billing purposes or as part of any agreements you have with the administrator of the failing Supplier. If you intend to use customer reads to generate a D0010, you should plan what to do if these are unavailable as BSCP504 does not permit a Supplier creating deemed a read in these circumstances nor does it allow the re-dating of actual reads. If readings are obtained and you wish for them also to be used in Settlement then the reads must be provided to the current DC for validation and inclusion in the Meter Read History.

• Secondly, you should ensure you have communicated your migration plan with the relevant Agents. Note that the Agent appointed at the time of the SoLR remains the Agent until either the CoS or CoA process has been completed. You should take steps to communicate with both the previous and new Agent before starting the migration. Once started you should monitor the transfer of MRH and the subsequent validation/generation of CoS reads to ensure that these properly enter into Settlement and do not generate large EAC/AA instants for both MPIDs involved.

• You should be careful to draw a distinction between these two event and ensure only validated customer readings are allowed to progress into Settlement.

• Additionally, you may need to migrate a small number of complex Meters over separately following a bulk CoS. You should inform Elexon the date you intend to have completed migration of all Meters, including any remaining Complex Meters.

• You should be aware that you are now responsible for the failing Supplier’s MPID and managing the end to end process of migrating MSIDs across to a new MPID. For instance submitting D0151s⁴, Termination of Appointment or Contract by Supplier, is the responsibility of the appointed SoLR rather than the Administrator. The administrator may submit this on behalf of the Supplier if there are issues with access to the systems of gateway that requires this however, the responsibility for the data and controls remain with the Replacement Supplier. Ensure that if you have agreed a process with the Administrator and ensure this has been communicated to both the previous and new Agents.

How Elexon’s Performance reporting can help

• The first comes from the customer reads provided to the current DC shortly after the SoLR being processed into settlement to assist with creating a boundary marker for billing purposes. The customer reads provided for the SoLR date will often be entered retrospectively and therefore won’t necessarily be reflected in the earlier Settlement Runs.

• The second, whether deemed or actual reads, are CoS reads entered into Settlement causing AA to be created for the period back to the previous read.

• As can be seen from this graph, Settlement performance of each run as fallen to the level of the prior run before dropping to zero which suggests the flow of data has stopped. This may be because the old DC has stopped processing CoS Reads, or has become unable to since the SoLR date. Also, performance not reacted reacted at all to the CoS event that followed which indicates that the CoS reads haven’t progressed into Settlement possibly the new DC being unable to generate the D0086. In this scenario, the DC may require assistance.Whilst the Settlement performance prior to the SoLR date is not your responsibility as the Replacement Supplier (see the section below), it is your responsibility to ensure that the appropriate steps for the CoS are completed in line with the BSC. Reviewing the performance data prior to the SoLR to ensure these issues don’t occur will help you monitor whether the customer reads and any deemed or actual CoS reads have been successfully processed or whether there are issues that you need to investigate with your agents (pre and post the CoS date). Please contact your OSM if you would like to discuss this monitoring.

Information that Elexon will request from the Replacement Supplier

• Confirmation on whether you will be undertaking a CoS process or maintaining the failing Supplier’s MPID;

• Confirmation of a timeframe for any CoS/CoA activities;

• Details of the controls you will put in place to manage appointments, data quality, exceptions and obtaining reads;

• An indication of expected Performance across all run types for the next 14 months for the failing Supplier’s MPID and the MPIDs you are migrating MSIDs to if undertaking the CoS route from the SoLR date; and

• That regular which detail when any migrations take place, the Agents involved and confirmation that you have communicated with Agents, during any performance discussions with your OSM.

Performance Assurance responsibilities of the Replacement Supplier

Approaches for PATs that are impacted by a SoLR

Advice for Agents involved in SoLR Activities

• Manage the new MSIDs using the MPIDs that had belonged to the failing Supplier, in which case the Replacement Supplier should communicate if it intends to migrate the MSIDs to a new Agent; or

• Undertake a CoS to transfer the MSIDs to one of its existing MPIDs, in which case the Replacement Supplier should communicate if it intends to use nominate a new Agent during the CoS process.