Supplier Volume Allocation Half Hourly Market Best Practice |
Guidance Note |
Timing of sending the D0170 and data provision upon a Change of HHDC
The method for requesting MS related details by a newly appointed Half Hourly Data Collector (HHDC) from the associated old HHDC is detailed in BSCP502 under sections 3.2.4 and 3.2.7. When a request is made using the D0170 the old HHDC is required to send validated HH advances (D0036), the final Meter reading, where available, and the last physical Meter read obtained (D0010). The process does not define the timing for initiating this request.
To ensure that the final Meter reading is available for use by the new HHDC, the new HHDC should not send the D0170 prior to the appointed Effective From Date on their D0155. This will enable the old HHDC to send the final Meter read within the five Working Day (WD) timescale specified.
Data provision by the old HHDC, on request of the D0170 should always contain a final Meter read on the D0010, and 14 months of data on the D0036. Where the old HHDC has less than 14 months’ data they should send as much as they have. This would be the case if the old HHDC had been appointed for less than 14 months and had not requested any history from the previous agent. The old HHDC should populate the D0036 with all the data available, this should include both active and reactive channels. Typically, the HHDC will include Measure Quantities; Active Import (AI), Active Export (AE), Reactive Import (KI) and Reactive Export (KE).
The final Meter read will ensure that the new HHDC can perform validation techniques on HH data required for Settlement purposes to ensure its accuracy, as defined in BSCP502 Appendix 4.0. The industry typically refers to this inter-collection advance reconciliation as a Mini-MAR.
The new HHDC should validate the data transferred on a D0036. This validation should take into account that the old Agent has already validated the data and passed it for use in Settlement. The new HHDC should apply as much of the validation process as is possible from the data provided.
It is the responsibility of the relevant Supplier to ensure that their HHDC Agents transfer all requested data, where available, within five WD of request. Failure to adhere to these rules is a breach of the BSC.
Processing Energisation Status on New Connections
There is still considerable variation in the HH market on the treatment of Energisation Status (ES) during the New Connection process for HH MSs. The HH Agent appointment process is the same for new and existing connections. This can create a situation where the Agent is unaware of the context in which the appointment is taking place and unnecessary delays in the processing of the appointment data flows and the Agent making incorrect assumptions.
Unless the Supplier has explicitly informed the HHDC that the MS is a new connection or De-energised, it should assume that the MS is Energised, and submit estimated data to Settlement until the Half Hourly Meter Operator Agent (HHMOA) sends a D0139 or D0268. If, on receipt of the D0139 or D0268, it becomes apparent that the Meter was De-energised, the HHDC should reset the previously estimated data to zero and resubmit which will resolve the error at the next Reconciliation Run.
On a new connection, one method for informing the HHDC that a new connection is De-energised would be for the Supplier to send an email (or other agreed communication) to the HHDC. The Supplier would need to agree this with the HHDC to ensure that the HHDC can correctly process the information. Both the Supplier and HHDC will need to ensure that all the relevant information is included in the communication flow and that adequate Audit trails are maintained.
On Energisation of the MS, a D0139 or D0268 from the Meter Operator Agent (MOA) will overwrite any assumed or manual ES record.
HHDC should consider implementing controls to alert Suppliers to MS with D0139 or D0268 outstanding for prolonged periods.
Allocation of the Effective From/To Date upon a change of Energisation Status for Half Hourly Metering Systems
Upon changing the ES of HH MSs, the Agent (MOA or Licensed Distribution System Operator (LDSO)) performing this action uses the D0139 to ensure that the relevant Parties (MOA, Supplier and HHDC) are informed of the date that the action was taken (data item J0014). The different processes used by MOAs lead them to report one of two dates on the D0139, under the J0014 data item:
1. the date that the Energisation change was performed; or
2. the registration/appointment ‘Effective From Date’
If the MOA uses the registration/appointment ‘Effective From Date’, erroneous estimated data will be produced and submitted to Settlement. This is because the HHDC will not be able to collect actual data for the period prior to the actual Energisation date, but will have the MS as Energised from the ‘Effective From Date’ on its system. The associated Supplier will also be liable for any financial penalties incurred, via the Performance Assurance Reporting and Monitoring Service (PARMS) Serials, for estimating data over these Settlement Days.
The data item description for J0014 also indicates that the date that should be used is the one when the Energisation occurred. The description reads ‘Calendar date on which requested action was performed’.
As a result of variations between Supplier new connection registration practices and resultant MOA procedures, MOAs should use the date that the Energisation was performed in the ‘Date of Action’ data item of the J0014. This will allow Suppliers the choice of what date they wish to use for their new connection practice and, hence, prevent erroneous data being submitted to Settlement.
Parties should note that they should treat a MS as Energised if it is Energised for any part of the Settlement Day. Therefore, there is a clear difference in the treatment of dates in the Energisation and De-energisation processes. The date of the work to change the ES will be either the first or the last day of the period that the MS was Energised. The period of De-energised will be to the day before Energisation or from the day after De-energisation.
The Agent performing these ES changes (LDSO or MOA) should state the actual calendar date that they performed the change to ES, as specified in the Master Registration Agreement (MRA) Data Transfer Catalogue (DTC). The Supplier and HHDC should be aware that the date they use to notify the change will depend on whether the ES change is from Energised (E) to De-energised (D) or vice versa.
When a MS is changed from Energised to De-energised, to ensure all data for any part of that day is recorded, the Effective From Date (EFD) for the new ES of “D”, De-energised, will be the calendar day after the date in the ‘Date of Action’ J0014 Data item of the D0139. The Effective To Date (ETD) for period of ES as “E”, Energised, will be the calendar date used in the J0014 field, as can be seen below.
For a change from De-energised to Energised, to ensure all the data for any part of that day is recorded, the EFD of the new ES of ‘E’, Energised, will be the same date as specified in the ‘Date of Action’ field. The ETD for the old period of ED of ‘D’, De-energised, will be the calendar date before the ‘Date of Action’, as seen in the diagram below.
Ensuring that the EFD and ETD for changes to ES are correctly set will improve the accuracy of data in Settlement and avoid inconsistency between registration data and Agents’ systems that can lead to D0235 and other exception reporting.
Use of the D0005 to ensure adequate Audit trail
Maintaining adequate Audit trails is important as it provides proof that the Agent has followed the correct process. The use of the D0005 is mandatory in some sections of BSCP502 as it provides an Audit trail:
3.3.2 Change of Meter Class (HH to NHH);
3.3.4 Change of Energisation Status;
3.3.6 Reconfiguration/Replacement of Metering System;
3.3.10 Change of Feeder Status
3.4.1.5 Instructing action on consumption exceeding maximum permissible level;
3.4.2.1 Finding inconsistency; and
3.5 Performing a Proving Test.
Failure to use the D0005 in performing processes, where specified, is a non-compliance with the BSCP and increases risk to Settlement accuracy.
It is also important the BSC Auditor is able to verify that an appropriate participant (Supplier, HHDC, MOA or LDSO) has initiated the process and the BSC Auditor will report where the D0005 is not used.
Metering System Investigation Process
Issues with the use of the D0001 and D0002 have been cited widely over a number of years. In addition to this, the metering fault investigation process shows discrepancies between BSCP502 and BSCP514. As a result of the reported inconsistency in the use of associated data flows and the procedures laid out in the BSCPs, Elexon is issuing guidance around the process and proper use of the data flows.
Use of Data Flows surrounding the Half Hourly Metering System Fault Investigation Process
Elexon recommends the D0001 should only be used by the HHDC for the situations detailed in the table below.
| Metering Fault Request Reason |
A. | The HHDC suspects invalid Meter Technical Details (MTD) on the D0268. |
B. | The HHDC has reason to suspect data retrieved from MS. |
C. | MS failed validation and/or Meter Advance Reconciliation process. |
D. | Energy Data detected on a De-energised MS. |
E. | Unable to dial/collect data from previously available MS. |
F. | When HH data required for a Proving Test cannot be obtained. |
G. | Where energy data is flagged with an alarm. |
H. | At the request of the Supplier. |
It is important that a problem encountered is clearly defined within the D0001 using the ‘Reason for Request’ data item (J0173). This will ensure the MOA has adequate information to progress the investigation efficiently through the appropriate internal route. Suppliers, HHDCs and MOAs can make arrangements to use a standard set of codes for these situations (e.g. A to H above) in order to help facilitate the smooth operation of the process.
The D0001 should not be used to request information from the MOA. In cases where the HHDC or Supplier needs further information on a MS, such as a data retrieval number for a new connection or further details of the MS location, the D0005 or personal communication should be used for this request to the MOA. The ‘Reason for Request’ (J0173) within the D0005 can be used to inform the MOA of the information required. Equally, the D0002 is not a specified method for acknowledging receipt of the D0001. Use of the D0002 to acknowledge receipt of a D0001 has been reported and is not compliant with the Code Subsidiary Documents. In cases where acknowledgement or information requests need to be sent, the D0005 or a personal communication is recommended.
Workaround timing and process interfaces for Metering System fault investigations
Elexon recommends that the MOA should conduct an investigation and only send the D0002 on completing the resolution of the problem described in the D0001. When the HH Meter Operator (MO) is unable to fully resolve the metering fault within the five WD timetable it should use the D0005 or an agreed method of communication in order to update the HHDC (e.g. email). If the fault is still outstanding fifteen WDs after the receipt of the original D0001, the MOA should use the D0005 or an agreed method of communication in order to update the HHDC.
The process and timings are highlighted in the diagram below.
The D0002 should only be issued once for completion of the process. Ensuring this will mitigate the production of a new D0001 for the same MS fault already under investigation.
As the SVA metering fault investigation process falls under obligations contained in BSCPs 502 and 514, all communication received and sent via an email communications route should be stored and archived for Audit purposes. Additionally a dedicated email account should be established for this purpose (e.g. meterinvestigationreports@companyname.co.uk) for distribution among relevant participants to ensure that messages have a single interface and are not directed to individuals within separate organisations.
Meter Advance Reconciliation
Ensuring that the correct equation is used when calculating MAR tolerance
BSCP502 section 4.7 describes the process for performing Meter Advance Reconciliations. This process compares the energy that the Meter has measured between two accumulative register readings (a Meter advance) and the total energy measured in each of the Settlement Periods over the same time span. The BSCP states that the HHDC should investigate any MAR where the difference between the Meter Advance and the sum of Settlement Period data is more than a 1% tolerance (after taking into account readings not taken on a Settlement Period boundary). However, the BSCP does not state how the HHDC should calculate the tolerance.
The HHDC can calculate the tolerance by reference to the sum of Settlement Period data or the Meter Advance. The BSCP is sufficiently ambiguous to allow either interpretation and there is little difference in the control afforded or accuracy checked by either interpretation.
However, to achieve a standard, Elexon recommends that HHDCs use the Meter Advance as the denominator in the required equation as it was always the intended way of calculating discrepancy when performing a tolerance check, as seen.
Discrepancy = |  |
Where: | |
 | is the sum of HH period energy volumes; and |
MA is the corresponding Meter Advance |
| |
Where: | |
| is the last Meter read taken during a site visit; and |
| Is the Meter read taken during a site visit prior to the last site visit (e.g. three months prior for a 100KW + MS) |
The sum of HH period energy volumes may contain less accurate data, such as estimates, that can distort the result. This can result in this test not working as intended and could allow inaccurate data to pass into Settlement.
MAR performance requirements
The BSC Audit and Elexon’s Technical Assurance (under BSCP535) have identified issues relating to the performance of the MAR validation. The major problems reported were due to difficulties with accessing premises. As a result, the following practice should be used to ensure that the HHDC can obtain a Meter read for use in the MAR. Agents and Suppliers need to agree this approach before implementing the procedures.
In line with the process used by the Technical Assurance Agent (under BSCP27), HHDCs should notify the MOA and the customer of their intention to visit premises ten WDs prior to the visit, using an auditable mechanism, e.g. stored email.
This notice should include:
If the HHDC has not received a response within five WDs, it should send a repeat notice of schedule to visit the site.
If the HHDC is told there will be problems obtaining access on the planned date, the site visit should be re-scheduled to avoid the problem.
In addition, Suppliers should make provisions in their appointment arrangements with HHDCs that specify the requirement to re-visit these premises until the HHDC obtains a successful Meter read. Additionally, the Supplier and Agent should implement an escalation process where the HHDC can notify the Supplier of continuing site access problems. The Supplier should note that they are responsible under the BSC (Section S 2.3.4) for ensuring that the registered HHDC has access to the Meters in order to read them within the timescales required for Settlement. Suppliers should consider including complementary conditions in their contract with the customer.
These measures should ensure that an accurate Meter register measurement can be taken and the MAR performed as required under BSCP502 section 4.7 within the timescales specified.
Workaround solution to ensure that MAR reporting requirements can be performed
BSCP502 section 4.7.1 places an obligation on HHDCs to produce a monthly report on the status of MARs. The status types specified are ‘MAR confirmation’, ‘MAR failure’ and ‘MAR overdue’. The D0008 describes the information that the HHDC should report.
Elexon is aware that HHDCs are unable to report the MAR Status ‘MAR overdue’ using the D0008. Originally, this had a ‘MAR overdue’ status code in the J0041 ‘MAR Status’ data item. However, this code was removed with the approval of MRA Change Request CR1187. Elexon believes that reporting the ‘MAR overdue’ status is an important control process that allows the Supplier to be able to manage HHDC performance with regard to performing MARs. Performing this validation technique ensures data accuracy on MSs that do not provide an electronic cumulative reading of the prime Meter Register. The BSC Audit also highlighted the poor performance of this validation check in the audit period to September 2003. Elexon recommends introducing a workaround process for HHDCs to report this status.
The D0008 still contains valid codes for failed MARs under J0041. We recommend that HHDCs report overdue MARs under this code, as failure to perform the MAR within timescales specified in BSCP502 constitutes a failure in their processes. Additionally, the free text field, J0012 ‘Additional Information’ data item can then be used to specify that the failure was caused by a failure to perform the validation. A suggestion for the population of this data item would be to use a prefix of ‘MO’ for MAR Overdue, which would allow space for additional comments, if required. This would allow Suppliers to develop methodology for the easy translation of the information presented. It is recommended that Suppliers agree with their Agents in advance, how they would like the information presented by the HHDC.
Clarification on flagging HH data before and after performing Proving Tests
BSCP502 section 4.6.7 details the rules surrounding treatment of data collected by a HHDC for a Metering System that requires, and has not completed, a Proving Test.
The rules allow the HHDC to treat data from an unproven MS as ‘A’ Flag (Actual data), while the Proving Test is outstanding, for submissions of data to Settlement. However, it also requires that when a Proving Test is failed, the ‘A’ Flag data be changed to ‘E’ flag (Estimated data), due to the fact the MTD have failed to produce correct data by comparison with that expected by the MOA. After a failed Proving Test, the HHDC should replace the HH data collected since the relevant D0268 effective from Settlement date with ‘E’ flag data.
The Proving Test failure would bring into question the validity of the data collected from the Meter and the Elexon recommend the HHDC should consider estimating Settlement data for the MS rather than using the questionable data obtained from the Meter. However, sometimes a MS will fail a proving test for reasons that do not immediately bring the data retrieved from the Meter into question. Where a HHDC is confident that the data retrieved from the Meter is correct, Elexon recommends this be used for Settlement but must be flagged as estimate until a successful proving test is completed. If the Meter data is not flagged as ‘E’ there will be no reason to re-visit the data in order to replace it with correct ‘A’ flag or more accurate data, and accuracy of validation methods using Meter Advances will be compromised.
Under the maximum timescales required for performing Proving Tests (up to 15 WD for meters under Code of Practice 5), Meter data obtained with an outstanding Proving Test should not be required for submission at Settlement Final (SF). In cases where there has been a delay to the initial performance of a Proving Test, HHDCs should have control processes that will prompt them to re-visit data collected in the period to ensure that the quality of data is as accurate as possible.
Failure to ensure that data is treated as estimated, as required by the BSCP, is considered a serious non-compliance.
Reporting requirements for failure to carry out Proving Tests by HHDCs
The process for proving HH MSs is clearly defined in section 3.5 of BSCP502. Part of this process requires that HHDCs report where a Proving Test is required, but has not been initiated in accordance with the timescales specified (section 3.5.6).
During the audit period ending September 2003, the Auditor noted that a number of HHDCs do not have processes in place to fulfil this obligation. As a result, Elexon reminds HHDCs that it is a requirement to notify the associated Supplier, MOA and Elexon using the P0212.
Note that the HHDC should report each failure to perform a Proving Test immediately after the required timescales are exhausted. However, it would be acceptable for the HHDC to produce a weekly report that covered all failures that occurred during the preceding week. The intention of this report is to notify the Supplier so that it can take appropriate action, therefore weekly reporting should be adequate for this purpose and less frequent reporting would not be consistent with the overall Proving Test timescales.
Proving test process completion and timing
Elexon would like to issue clarification on timing and the completion of Proving Test procedures covered in both BSCP502 and BSCP514, for HH MSs. The trigger for the MOA to initiate a Proving Test is well defined and methodologies for collecting data for comparison are also well prescribed.
Timescales for performing this process, as contained in the Appendices of both BSCPs (see table below), are intended to include the data comparison process and the distribution of results by the MOA.
CoP | WDs to complete Proving Test | WDs to complete re-Test | Total |
One | 5 | 5 | 10 |
Two | 5 | 5 | 10 |
Three | 10 | 10 | 20 |
Five | 15 | 15 | 30 |
Currently, the timing allowed for data comparison and issuing of the result by the MOA is three WD after receipt of HH test data (D0003) or a problem report (D0001) from the HHDC. Results are then communicated by a D0214, when successfully proved, or a D0002, when unsuccessful, as defined in section 5.5.5 of BSCP514. This data comparison timescale for issuing Proving Test results is due to be removed by Change Proposal (CP) 955, although the overall timescale from initiation to completion (i.e. issuing results) for the process will remain as shown in the table above.
The following process diagram highlights an ideal timetable to ensure that the Proving test and, if necessary, the re- test can be performed within the timescales defined above.
Using the above process the HHDC will need to ensure that collected HH data is sent (D0003) or a problem notified (D0001) two WD after receipt of the D0005 for Code of Practice 1 or 2 MSs (seven WD for CoP 3 and twelve WD for CoP 5). Additional time required to perform an investigation of the MS by the MOA, where the proving test has failed, will reduce the re-test timescales accordingly.
By using the timescales defined above for the internal parts of this process, MOAs will be able to adhere to new PARMS timescales and Supplier Agents can be assured that they are compliant with changes due to be introduced under CP955.
Interface to SMRS – HHDA System Refresh
Requirements to Perform a Full Annual Refresh
BSCP503 section 3.2.2 places a mandatory requirement on HHDAs to request and perform an annual full refresh. This change was introduced in February 2003.
The intention of performing the annual full refresh is to ensure that the HHDA holds the correct data for Metering Systems, as data held by the SMRS is considered by Settlement to be the definitive view of any Metering System. Suppliers are obliged to ensure that the SMRS view is correct and up to date. A failure to ensure that HHDAs perform the annual full refresh is a significant risk to Settlement accuracy. However, there are problems that HHDAs may face and the following best practice guidance should assist agents when performing the annual full refresh.
Step 1 HHDA requests full refresh from the associated SMRA;
Step 2 Log and check each request and refresh file received to ensure that all SMRS operators provide full refresh files;
Step 3 The HHDA makes a comparison of the standing data on the D0209 with that held on its system for each MS;
Step 4 If an unacceptable level of discrepancies exist, investigate with the SMRA and Supplier, and correct information appropriately, then go back to step 1;
Step 5 Apply D0209 to update system when level of change is understood;
Step 6 Update log to show that full refresh has been completed.
The HHDA will need to use its expertise and experience to judge if the level of change that a full refresh produces is acceptable. The HHDA should seek advice from the relevant Suppliers if there is any cause for concern about the level of inconsistency. Where the HHDA believes that the level of change is unacceptable this should be reported to all impacted Suppliers so that they can work with the HHDA to resolve the underlying problems. HHDAs should initially investigate their processes around D0209 and D0023 and include any abnormal findings in their reports to Suppliers. Once the Suppliers and Agent are sure that the changes that will be made by the refresh are correct then the HHDA should apply the refresh.
Where a comparison of a refresh and the HHDA system shows that no changes would result, the HHDA does not need to apply the refresh. This should be logged and the information from the comparison kept to support the audit trail.
Following this process will ensure discrepancies are correctly rectified, via the D0205, and that the HHDA system is up to date and in line with the SMRS view.
Meter read requirements and their use in BSCP502
Under changes made to BSCP502, further requirements were specified for obtaining. Meter reads, both initial and final, while performing Registration and Metering Activities, under sections 3.2 and 3.3, respectively. These requirements for the HHDC or MOA to obtain and process Meter reads were designed to improve the accuracy of Settlement.
The BSC Auditor identified the following sections of BSCP502 where Meter reads should be obtained and are not being processed:
What / When | Whom | BSCP section |
Initial read during a CoS | HHDC | 3.2.3.3 |
Initial read during a CoHHDC | New HHDC | 3.2.4.6 |
Initial read during a concurrent CoS and CoHHDC | New HHDC | 3.2.7.6 |
Send the HHDC an initial read during a New Connection | MOA | 3.2.1.2 |
Send the HHDC an initial read during a CoMC from NHH to HH | MOA | 3.3.1.2 |
Send the HHDC a final read during a CoMC from HH to NHH | MOA | 3.3.2.5 |
Send the HHDC a final read during a reconfiguration / replacement | MOA | 3.3.6.4 |
Send the HHDC an initial read during a reconfiguration / replacement | MOA | 3.3.6.5 |
Send the HHDC an initial read during an CoES to Energised | MOA | 3.3.3.1 |
Send the HHDC a final read during CoES to De-energised | MOA | 3.3.4.4 |
Send the HHDC a final read during CoES to De-energised | MOA | 3.3.4.8 |
Send the new HHDC a final read during a CoHHDC, on request | old HHDC | 3.2.4.8 |
Send the new HHDC a final read during a concurrent CoS and CoHHDC, on request | old HHDC | 3.2.7.8 |
HHDCs have an obligation to use physical Meter read values collected via the annual site visit, or from the MOAs, for comparison against remotely collected data, as part of the ‘Process Meter Data’ section 4.3.4, and investigate unacceptable discrepancies.
In cases where an electronic cumulative register read is not available as an initial read (i.e. for De-energised sites, Meters with outstations and manually read sites), the HHDC must ensure that an initial Meter read is obtained upon any CoHHDC. As a workaround solution, the HHDC could create the initial Meter read by using the Final Meter read provided by the old HHDC as part of a Meter History request using the D0170, with the agreement of the associated Supplier.
In addition to the processing of Meter reads, under sections: 3.2.1.2 New Connection; 3.3.1.3 CoMC NHH to HH; and 3.3.6.6 Reconfiguration/Replacement of MS, HHDCs must ensure they have systems in place to forward initial Meter reads obtained to both the associated Supplier and LDSO. In cases where the Meter read value is not available, as detailed under section 3.3.6.6 Reconfiguration/Replacement of MSs, the LDSO and Supplier should be informed by the HHDC using the D0002, as appropriate.
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