Technical Assurance of Metering How to rectify common non-compliances

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Technical Assurance of Metering How to Rectify Common Non-Compliances

Guidance Note

Summary

You will find this guidance useful if you are;

    • A Registrant,

    • A Supplier

    • A Party Agent, or

    • A Licensed Distribution System Operator

This guidance will help you learn more about rectifying non-compliances raised under the Technical Assurance of Metering (TAM) process by the Technical Assurance Agent (TAA).

You can find the obligations that you need to adhere to for the Technical Assurance of Metering in Section L, of the BSC: Metering and BSCP27: Technical Assurance of Metering.

Further information on the types of Non-compliances can be found in the Categories of Common Non-compliance guidance.

What is the Technical Assurance of Metering?

The TAM is a detective assurance technique. It’s described in Section L of the BSC and in BSCP27. The process involves inspecting a sample of Half Hourly (HH) Metering Systems by the TAA.

The TAA checks the HH Metering Systems for compliance to the appropriate obligations in the BSC and Code Subsidiary Documents (CSDs). There are different sample types:

    • 1% of the HH Supplier Volume Allocation (SVA) Metering System population,

    • 5% of the HH Central Volume Allocation (CVA) Metering System population,

    • A ‘specific sample’ designed to look at particular areas of risk to the HH Metering System population, and is directed by the Performance Assurance Board (PAB). This can be up to 20% of the HH SVA sample.

If Non-compliances are raised, the responsible party (clarified further in Appendix A) is expected to rectify them at the inspection, or by providing a rectification plan to the TAA and carrying it out within the required timescales. The details of the Non-compliances and rectification plans are held in the TAAMT and the Common Categories of Non-compliances guidance.

What needs to be rectified?

Non-compliances fall under one of four categories, all of which need to be addressed:

    • NC (or NP): A Consumption Data Comparison Check (CDCC) is performed. The TAA takes data directly from the Metering System, and directly compares this data with that taken by the DC. A non-compliance is applied where the two sets of data do not match.

    • Where it can’t be performed NP is recorded, this does not need to be rectified.

    • Category 1: affects the quality of data for Settlement purposes.

    • Category 2: potentially affects the quality of data for Settlement purposes (but doesn’t currently affect it).

    • Observation: inconsistencies with Code of Practice (CoP) requirements, but doesn’t affect, or potentially affect the quality of data for Settlement purposes.

If you need to prioritise any rectifying action, priority should be given to the CDCC and category 1 non-compliances first because these pose a higher risk to the data entering Settlement.

What else do I need to know?

Before a TAA Inspection visit

Pre-Audit Meter Exchanges

The TAA comes across Metering Systems where replacement (on or off site) or alteration work has taken place between notification of the audit and the day of the inspection visit. As a result, the Meter Operator Agent (MOA) updates and resends the Meter Technical Details (MTDs) to the required parties.

When the TAA performs the Inspection Visit, the Data Collector (DC) has not always received the MTDs from the MOA or uploaded the new MTDs correctly and in time for the TAA to see the updated MTDs. This can lead to a non-compliance being recorded against the DC because it has incorrect MTDs, though this is not the fault of the DC.

We recognise that there are some occasions where such work is necessary (e.g. because of a fault or emergency work etc.). Where this is the case, to rectify the non-compliance, you should advise the TAA through the normal process, providing evidence of the correct MTDs and the reason that the work took place.

In all other circumstances, please refrain from doing such work between notification of and the performing of an Inspection Visit. This approach has been endorsed by the PAB.

The TAM technique checks a sample of the HH Metering System population. We use the data from this technique to extrapolate trends and findings for the entire population. We need to ensure that all pre-audit visits and alterations are genuine, to avoid skewing the results, and in some cases causing further, more serious, non-compliances.

MTDs from Supplier Agents - provision to the TAA

MTDs can be input into the TAAMT using the online form (for a CoP 5 Metering System) or adding the MTDs to the inspection visits as a file, or by emailing the TA Helpdesk. For help in completing this, please contact taa_servicedesk@candc-uk.com or have a look at the help files in the HELP tab of the TAAMT.

If you are providing MTDs for a CVA site, CoP1, 2, or 3 Metering System, or for a SVA site with a Complex Supplementary Site Information Form, these files still need to be uploaded to the TAAMT. The TAA will process can process them manually.

If you’re not sure how this process works and / or need access to the TAAMT please contact the TAA (taa_servicedesk@candc-uk.com) or email tametering@elexon.co.uk and we will provide access and education on using the system.

We are working with the TAA and industry to look at efficiencies for this process e.g. how we can decrease manual intervention and continually work on improving all aspects of the service.

Providing Measurement Transformer Certificates – using the National Measurement Transformer Error Statement (NMTES)

If you have exhausted all routes (as described in BSCP27 Section 4) to obtain Measurement Transformer Certificates for the Metering System to be Inspected, you can look at the NMTES to see if the particular Type, Ratio, Manufacturer, Class and Rating (VA) of the measurement transformer is listed.

To do this:

1. First identify whether the particular CT is on a LV circuit (i.e. below 1000v) or a HV circuit (above 1000v);

In other words determine whether it is an ‘LV CT’ or an ‘HV CT’. If you are missing a certificate for a VT then by definition this will be on a HV circuit so just look up ‘VT’.

2. Then you need to compare the Ratio of the installed measurement transformer and see if one with a similar ratio is listed.

    • With multi-ratio CTs and VTs you need to make sure the ratio selected on site matches the ratio underlined in the NMTES Ratio column. This is because the underlined number indicates the primary to secondary ratio for which the generic Error listed relates (e.g. 100/50/5 means that the generic Error quoted relates to a 100/5 setting on the CT and not the 50/5 setting).

3. Next confirm the Manufacturer’s name matches one of those listed.

4. Then check that the measurement transformer is of the appropriate accuracy Class.

5. If the Rating of the measurement transformer matches what’s listed in that particular row of the NMTES then you can clear that certificate related non-compliance as you will have identified a generic certificate for the measurement transformer.

6. You can then communicate to the TAA that you have followed these steps and that a generic certificate exists for this Metering Equipment in the NMTES, you must tell the TAA which record on the NMTES you have used.

Elexon directed the TAA to permit Measurement Transformer certificates of a similar age, make and model for CoP three and five Metering Systems, this process aligns with that used for CoP 1 and 2 Metering Systems.

After the TAA Inspection Visit

Timescales for rectifying Non-compliances

When you are notified that a NC has been applied, you must either rectify it immediately, or provide a rectification plan to the TAA (preferably via the TAAMT) within ten working days, as per BSCP27. The plan should indicate the actions you are going to take to rectify the non-compliance with associated timescales. We expect that non-compliances should be rectified within reasonable timescales, in particular Category 1 non-compliances.

The TAA monitors and manages the process for obtaining ‘missing’ rectification plans. Where the TAA feels that rectification plans and actions have not been completed in a timely manner, they will escalate this to Elexon.

The TAA also monitor and chase all outstanding Category 1 non-compliances. The TAA report on progress to Elexon on a monthly basis, in turn Elexon report progress to the PAB.

The PAB reviews TAM performance metrics of both Registrants and MOAs on a monthly basis. Where a party is consistently underperforming, the Error and Failure Resolution process is likely to be applied.

It is important that issues are rectified as soon as operationally possible, in particular for Category 1 Non-compliances. If a non-compliance has resulted in Settlement Error, a Trading Dispute can be raised through the procedures set out in BSCP11: Trading Disputes.

Using the NMTES to rectify non-compliances (non-provision of measurement transformer certificates and overall accuracy not maintained)

If you have received a non-compliance for non-provision of a measurement transformer certificate (2.16) then you may be able to clear this by looking up the NMTES:

To do this:

1. Follow steps 1-5 under ‘Providing Measurement Transformer Certificates – using the National Measurement Transformer Error Statement (NMTES)’

2. After completing steps 1-5, you can then provide a rectification plan for the TAA to review with your evidence.

3. If you have a non-compliance related to overall accuracy not being maintained because certain certificates are missing (category 2.06), you might be able to use steps 1-5 to see if the measurement transformer in question is listed on the NMTES.

    • Where this is the case you can use the Error figure associated with it to help clear the ‘overall accuracy not maintained’ non-compliance.

4. Provide a rectification plan for the TAA to review with your evidence.

NB. You may not be able to clear the non-compliance in all cases as other certificates may still be missing, e.g. the meter certificate.

Providing evidence of rectification to the TAA

When all actions have been taken to rectify the non-compliance, evidence must be provided to the TAA. If the TAA requires more evidence from you, they will request it. The TAA considers and records the non-compliance as resolved and closes it as appropriate.

Because of the nature of different types of non-compliances, different types of evidence are required. Appendix A details the appropriate evidence.

Collaborative responsibilities

Many of the actions to rectify non-compliances require a collaborative approach by those involved. For example:

    • Where a CT / VT needs replacing, the MOA is assigned responsibility in the TAAMT. However, to replace the CT / VT the MOA and LDSO need to work closely to complete the actions.

    • Where certificates for Metering Equipment are required, the MOA and LDSO need to work collaboratively to provide to the TAA.

When a category 1.01 is assigned to the DC, the DC needs to work closely with the MOA to get accurate MTDs into its system by requesting the MOA investigate why it has the incorrect MTDs. The MOA must respond by sending accurate MTDs (post investigation and update if necessary). The Supplier may need to co-ordinate this approach.

Commissioning after changes to Metering Equipment

If a MOA alters, replaces or updates the Metering System, it must be commissioned. This is a requirement set out in the BSC and the Metering Code of Practice (CoP) 4.

Commissioning provides assurance that the system will record data for Settlement purposes accurately. If commissioning is not, or is partially / incorrectly performed, this can result in errors entering Settlement.

There can be a financial and reputational impact to Industry where errors occur.

Do I need to seek Metering Dispensation Approval?

For financial or practical reasons, it may not be possible for Metering Equipment to comply with a Code of Practice. To avoid a non-compliance for such instances, the Registrant should apply for a Metering Dispensation. Section L of the BSC and BSCP32 contain obligations and requirements for Metering Dispensations.

Section L allows for generic Metering Dispensations to be applied to any item of Metering Equipment. For further information about current generic Metering Dispensations, refer to the Statement of Generic Metering Dispensations document.

BSCP32: Metering Dispensations defines the interfaces and timescales for Metering Dispensation applications, as well as providing the application forms.

We hold a register of specific dispensations, both confidential and not.

What other information is available?

Appendix A

How do I rectify Non-compliances and whose responsibility is it?

The following table shows:

    • The common non compliances raised by the TAA

    • Who is responsible for fixing them

    • Which standard rectification plan should be used in the TAAMT

    • What actions we recommend to rectify these non-compliances

NC

NC Category Description – What the problem is

Who is assigned as the responsible party to the NC?

Which Standard Rectification Plan could I use in the TAAMT?

What else do I need to know to help me rectify this NC?

Registrant

MOA

DC

NC

Comparison Identified inconsistent data. Consumption data held by Data Collector outside tolerance when compared with metered energy data.

Other

This will affect the quality of data entering into the Settlement process. To rectify this NC the DC will need to work with the MOA to confirm / resolve site arrangements. The MTDs must be updated as necessary and be re-issued to the required participants as set out in the relevant BSC documentation. The relevant fault investigation process is adequate for supporting this process. Re-commissioning must occur and updated MTDs and applicable evidence should be provided to the TAA.

Inaccuracy of Standing Data (Key MTD fields) held by Data Collector

1.01

Meter Id (Serial Number)

Provide correct D0268 Data (SVA) Other (CVA – provide corrected MTDs as per BSCP20)

If these data items are incorrect in the DC system, it will affect the way the data is translated from the Metering System and entered into the Settlement process. To rectify this, NC the DC will need to work with the MOA to confirm site arrangements and ensure that they are adequately reflected in the MTDs before being loaded into the DC system. The MTDs must be updated as necessary and be re-issued to the required participants as set out in the relevant BSC documentation, as necessary. The relevant fault investigation process is adequate for supporting this process. Re-commissioning must occur, as necessary, and any updated MTDs and applicable evidence should be provided to the TAA.

Outstation number of channels

Measurement Quantity Id

Pulse Multiplier

Channel configuration

Outstation multiplier / Outstation channel multiplier

Complex Site Supplementary Information Form (SVA only)

Metering Equipment Incorrect or Unsatisfactory

1.02

Metering Equipment not functioning correctly

Change / Replace the metering System Equipment

Errors of this nature affect the quality of data that enters Settlement and as such must be rectified. Rectification of this NC requires a change/exchange to the Metering Equipment. Attendance and rectification by the relevant SO may be required. The MTDs must be updated, as necessary, and be re-issued to all parties in line with the BSC. Re-commissioning must occur, as necessary, and evidence should be provided to the TAA.

Alternative actions may be to seek Metering System Dispensation approval through the relevant process.

Metering Equipment not programmed correctly

Overall accuracy of Metering System not maintained

Summation CTs used

Correct Energy Measurement Check (Primary/Secondary conductor prevailing load test) indicates an error in the metered volume

Timing Error (Major)

1.03

Outstation clock outside of agreed tolerance

Correct the Metering System Clock

MOA must work with the DC to investigate and correct any clock drift exceeding the parameters set out: CoP 1 >± 30 seconds, CoP 2 >± 30 seconds, CoP 3 >± 1 minute, Cop 5 >± 2 minutes.

If the Meter or Outstation clock is continually falling outside these tolerances, then it may be appropriate to replace the equipment entirely. Re-commissioning must occur, as necessary, and evidence should be provided to the TAA.

Measurement transformer Ratios Physically Incorrect

1.04

Measurement transformer ratios different from those set up in Meter (save for any difference being consistent with a measurement error compensation applied within the metering Equipment)

Change / replace Metering System Equipment

Provide correct D0268 Data (SVA)

Other (CVA – provide corrected MTDs as per BSCP20)

To rectify this NC the MOA is required to re-programme the Meter and update MTDs as necessary, reissuing to required participants as set out in the relevant BSC documentation. Re-commissioning must occur, as necessary, and evidence should be provided to the TAA.

Compensation Calculations Incorrect

1.05

Meter compensation for Measurement Transformers incorrectly applied or not applied

Change / replace Metering System Equipment

Provide correct D0268 Data (SVA)

Other (CVA – provide corrected MTDs as per BSCP20)

The MOA must apply the Meter compensations correctly. This NC indicates that no commissioning had taken place (if it had, it would have shown the error). The MTDs must be updated as necessary and be re-issued to the required participants as set out in the relevant BSC documentation. Re-commissioning must occur, as necessary, and evidence should be provided to the TAA. The MTDs must be updated as necessary and be re-issued to all parties in line with the BSC.

Meter compensation for Power Transformers incorrectly applied or not applied

Inaccuracy of Standing Data held by Meter Operator Agent

2.01

Outstation serial number

Provide correct D0268 Data (SVA)

Other (CVA – provide corrected MTDs as per BSCP20)

It is the MOAs obligation to ensure the MTDs are accurate and correct. Where the MOA MTDs do not match the equipment on site the MOA must update the MTDs, as necessary, and re-issue to the required parties in line with the BSC. Evidence of rectification should be provided to the TAA.

Meter Id (serial number)

Outstation number of channels

Measurement Quantity Id

Meter Register Multiplier

Pulse multiplier

Channel configuration

Outstation multiplier / Outstation channel multiplier

Measurement Transformer Ratios

Complex Site Supplementary Information Form (SVA only)

Inaccuracy of Standing Data (non-Key MTD fields) held by Data Collector

2.02

Data Collector’s Meter Technical Details do not match on site equipment due to recent Meter Exchange

Provide correct D0268 Data (SVA)

Other (CVA – provide corrected MTDs as per BSCP20)

Ensure the Meter exchange is genuine, as a result of the fault investigation or tamper investigate process. The MTDs must be updated as necessary and be re-issued to the required participants as set out in the relevant BSC documentation. Re-commissioning must occur, as necessary, and evidence should be provided to the TAA.

Other non-Key fields (e.g. Measurement Transformer Ratios & Meter Register Multiplier)

MOA may need to work with the LDSO to ensure that this NC is rectified. The MTDs must be updated as necessary and be re-issued to the required participants as set out in the relevant BSC documentation. Re-commissioning must occur, as necessary, and evidence should be provided to the TAA.

Non-provision of Standing Data

2.03

Meter Technical Details not provided – Meter Operator Agent and Data Collector

Provide correct D0268 Data (SVA)

Other (CVA – provide corrected MTDs as per BSCP20)

The MTDs must be provided to the TAA for inspection. BSCP27 states that all MTDs must be provided prior to the inspection visit, except for the MOA who may take these details to the inspection visit.

2.06

Incorrect CoP applied

Change / replace Metering System Equipment

Provide Correct D0268 Data (SVA)

Other (CVA – provide corrected MTDs as per BSCP20)

MOA must apply the correct CoP. Re-commissioning must occur where changes to the physical set up of the Metering Equipment have taken place and evidence should be provided to the TAA. Any updated MTDs must be provided to all parties in line with the BSC.

Check Meter missing

MOA must ensure that where the CoP requires, a check meter is both fitted and detailed in the MTDs. Any updated MTDs must be provided to all parties in line with the BSC. After all necessary work re-commissioning must occur and evidence should be provided to the TAA.

Main Meter missing. Check Meter present and accurate

This may be an administrative or a physical NC or both. Where it is administrative, rectification requires the MTDs to be updated and these must be provided to all parties in line with the BSC. If the NC is physical, the MOA must ensure that the Metering System complies with the appropriate CoP and update the MTDs. Any updated MTDs must be provided to all parties in line with the BSC. Re-commissioning must occur, as necessary, and evidence must be provided to the TAA.

Meter accuracy class incorrect

MOA must apply the correct meter accuracy class to the Meter. Any updated MTDs must be provided to all parties in line with the BSC. Re-commissioning must occur, as necessary, and evidence should be provided to the TAA.

2.06 Cont’d

CT accuracy class incorrect

Change / replace Metering System Equipment

Provide Correct D0268 Data (SVA)

Other (CVA – provide corrected MTDs as per BSCP20)

MOA must apply the correct CT accuracy class to the Meter. Any updated MTDs must be provided to all parties in line with the BSC. Re-commissioning must occur, as necessary, and evidence should be provided to the TAA.

VT accuracy class incorrect

MOA must apply the correct VT accuracy class to the Meter. Any updated MTDs must be provided to all parties in line with the BSC. Re-commissioning must occur, as necessary, and evidence should be provided to the TAA.

Voltage selection relay not installed/working when summation CT’s used

MOA must repair or replace the voltage selection relay or install one if necessary. Any updated MTDs must be provided to all parties in line with the BSC. Re-commissioning must occur, as necessary, and evidence should be provided to the TAA.

Possibility that overall accuracy of Metering System not maintained

Supplier and MOA (with assistant of the relevant SO) must provide all documentation to enable Overall Accuracy to be calculated. Failing that the NMTES should be used where applicable in the SVA Market.

If the NC is the result of a physical metering problem, the MOA and the relevant SO will need to replace the Metering Equipment or adjust the Meter to compensate if possible. The MTDs must be updated as necessary and be re-issued to the required participants as set out in the relevant BSC documentation. Re-commissioning must occur and evidence should be provided to the TAA.

2.06 Cont’d

Unapproved data format and protocol in use

Change / replace Metering System Equipment

Provide Correct D0268 Data (SVA)

Other (CVA – provide corrected MTDs as per BSCP20)

This NC requires that the Meter or Outstation is replaced. The MTDs must be updated and re-issued to the required participants as set out in the relevant BSC documentation. Re-commissioning must occur and evidence should be provided to the TAA.

Unsuitable Environment

2.08

Environmental conditions likely to cause Metering Equipment failure

Other

(Please provide a description when submitting your rectification plan)

MOA and Supplier must arrange to either move or protect the Metering Equipment. Re-commissioning must occur, as necessary, and evidence should be provided to the TAA.

Inadequate Over-current Protection

2.09

Insufficient discrimination between source and local fusing

Change / replace Metering System Equipment

Provide corrected D0268 data (SVA)

Other (CVA – provide corrected MTDs as per BSCP20)

MOA must ensure that the fusing set up is correct. Any updated MTDs must be provided to all parties in line with the BSC. Re-commissioning must occur, as necessary, and evidence should be provided to the TAA.

No local isolation

MOA must ensure that isolation is provided at the Meter in line with CoP requirements. Any updated MTDs must be provided to all parties in line with the BSC. Re-commissioning must occur, as necessary, and evidence should be provided to the TAA.

Main and check Meters not separately fused

MOA must ensure that main and check meters are separately fused. Any updated MTDs must be provided to all parties in line with the BSC. Re-commissioning must occur, as necessary, and evidence should be provided to the TAA.

Other Metering Equipment not separately fused

MOA must ensure that all aspects of the Metering Equipment are separately fused. Any updated MTDs must be provided to all parties in line with the BSC. Re-commissioning must occur, as necessary, and evidence should be provided to the TAA.

Non-Settlement Meters not separately fused

MOA must ensure that all aspects of the Metering Equipment are separately fused. Any updated MTDs must be provided to all parties in line with the BSC. Re-commissioning must occur, as necessary, and evidence should be provided to the TAA.

Separate Phase Failure Alarms Not Installed or Inadequate / Failed – Local and Remote

2.10

Alarm not fitted where required

Change / replace Metering System Equipment

Provide corrected D0268 data (SVA)

Other (CVA – provide corrected MTDs as per BSCP20)

MOA must exchange the Meter for one that has a phase alarm fitted. Any updated MTDs must be provided to all parties in line with the BSC. Re-commissioning must occur and evidence should be provided to the TAA.

Alarm not functioning

Inadequate Metering Equipment Integrity

2.11

Settlement Metering Equipment not sealed

Change / replace Metering System Equipment

Provide corrected D0268 data (SVA)

Other (CVA – provide corrected MTDs as per BSCP20)

MOA must ensure that Metering Equipment is sealed in line with the CoP and MOCOPA (SVA) / BSC (CVA) provisions. Re-commissioning must occur, as necessary, and evidence should be provided to the TAA.

Password functionality not included in Outstation

MOA must ensure that the outstation has password capability if required. Any updated MTDs must be provided to all parties in line with the BSC. Re-commissioning must occur, as necessary, and evidence should be provided to the TAA.

Timing Error (Minor)

2.14

Outstation clock outside agreed tolerance

Correct the Metering System Clock

Provide Corrected D0268 data (SVA)

Other (CVA – provide corrected MTDs as per BSCP20)

The DC must trim the clock to correct. Where meters do not allow this to be done in one instance, then it must be done progressively.

CoP 1 ± 20 seconds to 30 seconds

CoP 2 ± 20 seconds to 30 seconds

CoP 3 ± 20 seconds to 1 minute

CoP 5 ± 20 seconds to 2 minutes

If the Meter or Outstation clock is continually falling outside these tolerances, then it may be appropriate to investigate further following the relevant fault investigation process set out in the BSC and may lead to a replacement of Metering Equipment. If replacement is required the MTDs must be updated and provided to all parties in line with the BSC. Re-commissioning must occur and evidence should be provided to the TAA.

Commissioning Records

2.15

Commissioning records not provided

Provide Certificates

Records must be provided or re-commissioning must take place and evidence provided to the TAA.

Commissioning records incorrect

Commissioning records incomplete

Measurement Transformer Certificates not provided or incorrect

2.16

Measurement Transformer Certificates not provided

Provide Certificates

Records must be provided or MOA can use the NMTES, if the Measurement Transformers are on it.

Measurement Transformer Certificates do not match site equipment

Meter Certificates not provided or incorrect

2.17

Meter Certificates not provided

Provide Certificates

Records must be provided and evidence provided to the TAA.

Meter Certificates do not match site equipment

Labelling Inconsistency

0.16

Main/Check/Import/Export

n/a

Metering Equipment must be labelled correctly and if necessary changes to the physical set up.

Circuits (feeders)

Measurement Transformer ratios and / or polarity

Test Terminal Block connections

Test Terminal Block

0.19

Test Terminal Block not fitted / inappropriate

n/a

The MOA must ensure that the Metering System has a test terminal Block fitted and working effectively.

Unauthorised Access

0.20

Possible unauthorised access to Meter location which could lead to interference with Metering Equipment

n/a

Access to the Meter location must be secured by the MOA or SO as applicable. Access must only be provided to the Meter location by the required parties in line with the BSC.

Need more information?

If you’re not sure how this process works and / or need access to the TAAMT please contact the TAA (taa_servicedesk@candc-uk.com) or email tametering@elexon.co.uk and we will provide access and education on using the system.

Also see:

For further information please contact the BSC Service Desk or call 0370 010 6950.

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