Virtual Lead Party (VLP) – Entering the Market |
Guidance Note |
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Wider Access is the term used for changes to the Balancing & Settlement Code (BSC) and to the National Electricity Transmission System Operator (NETSO) processes (implemented in 2019) to enable customers and independent aggregators – known in the BSC as Virtual Lead Parties (VLPs) to participate in the Balancing Mechanism (BM). BSC arrangements have always allowed customers to participate in the BM through their electricity supplier, but Wider Access allows them to do so through an independent aggregator, or directly themselves (if they accede to the BSC). The Wider Access changes also remove all BSC barriers to customers and independent aggregators participating directly in the Replacement Reserve (RR) market when it is introduced later in 2020. Opening up the BM to Wider Access is important for helping the development of a smarter, more flexible electricity system in which independent aggregators can play a role.
Independent aggregators are parties who bundle changes in consumer’s loads or distributed generation output for sale in organised markets and who do not simultaneously supply the customer with energy.
Wider Access changes to the BSC were implemented under Modification P344 (in the February 2019 and November 2019 BSC Releases), and provide a means for the registration and qualification of VLPs.
A VLP is a distinct new type of Party to the BSC that only participates in Settlement by offering balancing energy. The BSC does not currently provide a mechanism for VLPs to trade in wholesale markets. In recognition of this, a BSC Party who qualifies only in the role of VLP (and not in any of the Trading Party roles that permit access to wholesale markets, such as Generator or Non-Physical Trader) is not subject to the same level of charges and obligations as existing Parties. A BSC Party who qualifies both as a VLP and as a Trading Party will be subject to the same charges and obligations as other Trading Parties.
Market & Registration Process
0.1 Virtual Lead Party (VLP) – Entering the Market
Under the BSC framework, independent aggregators are known as VLPs. This is an overview of the end to end process for entering the market as a Virtual Lead Party (VLP).
This note includes information on the CVA and SVA entry processes; the two entry processes can run in parallel. If you are considering entering the market as a VLP, Elexon recommends that you contact its Market Entry team (market.entry@elexon.co.uk) to arrange a meeting with them to discuss your intentions and they can provide further support and guidance. Market Entry meetings are free of charge to potential Parties, and can be held either at Elexon office or via teleconference.
The full business process for becoming a VLP can also be found in the guidance flow chart on the
Market Entry page of the Elexon website.
This diagram also contains all the necessary forms for Parties to complete as part of the Market Entry process. To access the forms, please click on the relevant step, for a pop up to appear.
It is a requirement for all BSC Parties to complete CVA Market Entry. This section provides an overview of the steps involved and offers on advice on how to complete each step.
The Market Entry process is initiated by acceding to the BSC. At this point you will be considered a BSC Party, and will be subject to Elexon’s Base Monthly Charge of £250 (+VAT) per calendar month or part thereof.
When you are ready to accede, please submit:
Two signed and undated physical copies of the Accession Agreement. These will be countersigned and dated by Elexon on your chosen accession date. Elexon require paper copies, but you can send a scanned copy for the Participant Management team to check before posting if you wish. Please send the Accession Agreements to:
Participant Management team
Once Elexon has received the forms and Accession Fee, they will arrange an Accession Date of your preference. Please contact the Participant Management team for templates of these documents.
Appoint Authorised Signatories
Authorised Signatories are the people appointed to carry out activities under the BSC. Your Authorised Signatory will also need to sign off documentation and forms relating to the market entry process. To appoint your first set of Authorised Signatories Elexon requires:
Order Communications Line
BSC Parties are required to acquire a communications method for Elexon’s systems to communicate with their own. There are two options for this:
CVA Qualification testing
BSC Parties are required to complete CVA
Qualification to certify that the
Party’s CVA system can correctly interact with Elexon’s systems and validate the format of any data that they receive. Parties are required to build or procure their own system. If you did want to go down the route of building your own CVA software please refer to the
NETA Interface Definition Documents (IDDs) and further
related documents.
To complete CVA Qualification, there are three routes:
Waiver testing against an already Qualified Parties system. If you have agreed with a Party that has already Qualified in the role to make use of their system, then you can waiver the testing. To do so complete the BSCP70/02 waiver application listing the flows which you wish to waiver. This should be accompanied by supporting evidence in the form of a letter from the supporting Party;
All BSC Parties are required to register with the Funds Accession Agent (FAA). This is done using the
BSCP301/04(a) form. Please note that the FAA requires you to have a UK bank account, that is an account with a bank that has a branch based in the UK and used GBP is its principal currency.
Nominate operational contracts
Elexon requires Parties to nominate contacts for who should be contacted in relation to different activities under the BSC. The nominated persons should be authorised to undertake activities relating to the area for which they have been nominated. Operational contacts are declared using the contacts spreadsheet, the template for which can be provided by the Market Entry team.
When you have completed CVA
Qualification we will register you as a VLP in our Central
Systems. The registration requires form
BSCP65/01 or this can be completed online using the Self-Service Gateway (Elexon Kinnect
Customer Solution). If completing the
BSCP65/01 form please put the
Party Name in line one of the address followed by the address beginning in line two.
SVA Qualification is a risk based Performance Assurance Technique (PAT) designed to offer confidence to the PAB and the market as a whole, that you are capable of operating in your chosen role without posing a risk to Settlement.
The SVA
Qualification process is based around the
Self-Assessment Document (SAD): BSCP537 Appendix 1, which asks about the organisation’s systems, staff and processes and takes a risk based approach. The risk assigned to an application will be reviewed by Elexon and the
Qualification Service Provider (QSP) at various stages throughout the
Qualification process (for example, as subsequent drafts of the SAD are received) and if an applicant’s circumstances change. It is advisable to take a look at the SAD before initiating the
Qualification process to get a feeling for the types of questions and identify any areas you may have insufficient evidence for.
The Qualification process is initiated by your accession to the BSC. Once you accede, you can contact the Qualification Team to arrange a meeting with Elexon and the QSP to understand your business plans, explain the BSC Qualification processes and agree indicative timescales.
0.2 Completion/submission of the SAD
The SAD is broken down into numerous sections, some generic and some role specific. As a VLP you will need to complete sections 1-6 (generic) and 19 (VLP). Each section has an introduction to provide guidance and each question provides more detailed advice of what the QSP is looking for. There is space to answer each question and attach any supporting evidence you wish to provide.
The SAD can be submitted all at once or section by section. It will be reviewed by the QSP who will provide feedback and request additional detail or evidence where an answer is insufficient. This forms an iterative process that can be repeated many times until the QSP is happy with the submission. A risk-based approach is used when reviewing the SAD, supporting evidence and determining the amount of witness testing carried out on an applicant. Elexon assess the risk of an applicant based on the responses provided in the SAD and the supporting evidence. There is more information in the
QSPS’s Approach to Qualification.
Following completion of the SAD, the QSP will write a report detailing its findings and provide a recommendation for your Qualification application. Elexon and QSP Reports detailing the completion of the procedure are presented to the PAB. Elexon provide a recommendation and all the information needed for the PAB to make a decision on an applicant’s Qualification. The PAB decides on an applicant’s approval for Qualification.
Please note that since the PAB meet once a month (their meeting dates are listed on the
Elexon website) and Elexon and the QSP will need to write their reports, it can be six to eight weeks between finalising the SAD and the PAB presentation.
Registration of Secondary BMUs
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What is a Secondary BM Unit? | Secondary BM Units record the amount of Balancing Energy provided by Virtual Lead Parties to the NETSO. |
Do I need to do anything before registering one? | Before submitting the Secondary BM Unit registration form, you must contact the NETSO[ ], to discuss your obligations and sign the necessary contractual agreements. The NETSO will give you NGC BM Unit Id(s). |
What forms do I need to fill in? | BSCP15/4.14 gives general details of the Secondary BM Unit(s) you are registering. This must be sent to the CRA at least 15 Working Days before the Effective From Date. Alternatively this information can be completed online via the Self-Service Gateway (Elexon Kinnect Customer Solution) |
What information do I provide on the BSCP15/4.14 form? | The Secondary BM Unit ID is V__XPPPP00N. The Secondary BM Unit ID has a prefix of ‘V_’, followed by _X, where X is the relevant GSP Group letter, e.g. _A, PPPP is your four-letter Identifier (this may be the same as your Market Participant Identifier (MPID)), and 00N where N are numbered sequentially, i.e. 001, 002 etc, within each GSP Group for each VLP’s BM Units The NETSO will provide you with the NGC BM Unit ID. Enter a Production/Consumption (P/C) Flag of either P or C. If not sure, then enter a C. You need to state the date on which the Secondary BM Unit will be effective from. |
When do I need to submit these forms by? | You must submit the BSCP15/4.14 form at least 15 Working Days before your proposed Effective From Date. Alternatively, this information can be completed online via the Self-Service Gateway (Elexon Kinnect Customer Solution). |
Is there anything else I need to do? | You also need to allocate your SVA MSID pairs to the Secondary BM Unit using the process contained in BSCP602 |
MSID Pair Allocation – P0278
The process for allocating your
MSID pairs to the
Secondary BM Unit is contained in
BSCP602:
SVA Metering System Register section 2.1.
You must submit your MSID Pair Allocation (s) at least 5 working days in advance of their effective from date. If it is your initial registration, then your MSID Pair should go live on the same date as your Secondary BM Unit.
Once you have access to the Self-Service Gateway (Elexon Kinnect
Customer Solution) you will be able to allocate your
MSID Pairs. Until then, VLPs will need to submit their
MSID Pair Allocation (s) (using
Elexon’s standard template) to the
Supplier Volume Allocation Agent (
SVAA) at neta@imserv.com. The
SVAA will then validate those
MSID Pairs Allocation (s) and provide a response, in the form of either a Confirmation or a Rejection.
0.1 Completing the MSID Pair Allocation template
Column title | Input |
MSID Pair ID | This Id should be left blank. On acceptance, the SVAA will provide the unique MSID Pair Id |
BM Unit ID | You should input the Secondary BM Unit ID stated on the BSCP15/4.14 Form. Alternatively, this information can be completed online via the Self-Service Gateway (Elexon Kinnect Customer Solution). |
GSP Group ID | The GSP group that the BM Unit is located, e.g. _A |
Effective from Settlement Date {MSIDP} | Applicable date (For the initial set of MSID Pairs, this should be the same as the Effective From Date of the SBMU) |
Effective To Settlement Date {MSIDP} | End date of the contract (use high date value if the contract is open-ended e.g. 31/12/2049) |
Import MSID | MSID Pair represents the SVA Metering System (s) at a single customer site and must include an Import |
MSID Import Customer Consent Flag | This is to indicate whether the customer has consented for BSC central systems to share the settlement derived individual MSID ‘Delivered Volumes’ with their Supplier for the Import MSID |
Effective From Settlement Date {ICCF} | Applicable date (The initial date should be the same as the Effective From Settlement Date of the MSID Pair, but could have a later date in the event that the customer gives or withdraws consent) |
Effective To Settlement Date {ICCF} | End date of the contract (use high date value if the contract is open-ended e.g. 31/12/2049) |
Export MSID | MSID Pair represents the SVA Metering System (s) at a single customer site and may include an Export |
MSID Export Customer Consent Flag | This is to indicate whether the customer has consented for BSC central systems to share the settlement derived individual MSID ‘Delivered Volumes’ with their Supplier for the Export MSID |
Effective From Settlement Date {ECCF} | Applicable date (The initial date should be the same as the Effective From Settlement Date of the MSID Pair, but could have a later date in the event that the customer gives or withdraws consent) |
Effective To Settlement Date {ECCF} | End date of the contract (use high date value if the contract is open-ended e.g. 31/12/2049) |
Rejection Reason | This should be left blank |
Delete? | This should be set to False |
Lifecycle of the trading day & how we calculate Settlement for VLPs
0.1 Imbalance Settlements for VLPs
Independent aggregators – known as Virtual Lead Parties – participating directly in the RR market and in the existing BM will pay or be paid Trading Charges according to their participation.
After the end of a Settlement Day D, VLPs must send Delivered Volumes in the form of P0282 MSID Pair Delivered Volume Notification to SVAA by D+1.
They can receive either a confirmation (P0284 Confirmation of MSID Pair Delivered Volume) or a rejection (P0283 Rejection of MSID Pair Delivered Volume) of their P0282.
On D+1, VLPs will receive ECVAA-I014 Notification Report that provides period and cumulative indebtedness data and identifies Parties in Credit Default.
By D+4 they can potentially receive a P0285 MSID Pair Delivered Volume Exception Report in case the Delivered Volume cannot be allocated in full in either the Import or the Export MSID of one MSID pair. In addition, a P0288 Secondary Half Hourly Consumption Volumes will also be issued to them.
By D+5, after Information Interim Run takes place, they will receive the SAA-I014 Settlement Report sub-flow 4 from the SAA that contains full results for Settlement Day D.
Charges are summed to a daily total and payment is required/made ~29 calendar days after the Settlement Date for which the RR or BM action took place. The Trading Charge Advice Notes are released on this timescale where the total exceeds +/-£500, if not released they roll over until the total over a number of days reaches this amount or the end of a year quarter is reached.
There are five Trading Charges that relate to VLPs. The payments and charges are as follows:
The Imbalance Cashflow: payments by Imbalance Parties at System Buy Price (SBPj for negative energy imbalance volumes, i.e. top-up, and payments to Imbalance Parties at System Sell Price (SSPj) for positive energy imbalance volumes, i.e. spill;
The Non Delivery Charge, payments by Trading Parties either: for non-delivered Offers, in the event that a payment at an Offer Price to a Trading Party exceeds the imbalance price paid on the shortfall resulting from any non-delivery; or for non-delivered Bids in the event that the imbalance price paid to a Trading Party for the spill caused by any non-delivery exceeds the price paid by the Trading Party for the Bid. Payments by Imbalance Parties in relation to nondelivered TERRE bids
The
Daily Party RR Cashflow, calculated for each half hour
Settlement Period and is the sum of all payments and charges in respect of RR activations for all
BM Units that the
Party is the
Lead Party for on that day. A detailed explanation of RR activations can be found in the
RR Activations Methodology; and The
Daily Party RR Instruction Deviation Cashflow, calculated for each half hour
Settlement Period and is the sum or all payments and charges in respect of RR deviations for all
BM Units that the
Party is the
Lead Party for on that day. It is calculated as the difference between the TSO dispatched
Replacement Reserve Accepted Offer Volume and the centrally defined EU Standard Product Shape Volume. These volumes are priced at the
Balancing Energy Deviation Price. However, as per the BSC Modification P344 solution, the
Balancing Energy Deviation Price has been set to zero. It is important to note that appropriate
Credit Cover must be in place before starting to trade. Please refer to
Credit Cover guidance note for more information.
0.1 How can you participate in TERRE?
You can participate in TERRE through the BSC framework in a number of ways, as outlined below:
1. A Virtual Lead Party (VLP) may register Secondary BM Units for the purposes of bidding into the TERRE product. One function of Secondary BM Units is to allow Virtual Lead Parties to aggregate a number of sites across multiple Suppliers in order to provide balancing services. Therefore, Secondary BM Units may be a single site, or a collection of sites within the same GSP Group whereby the minimum generation level exceeds 1MW. Secondary BM Units will also be able to be bid into the Balancing Mechanism by the VLP.
2. A Supplier may register Additional BM Units for the purposes of bidding into the TERRE product, alongside bidding into the BM as per the current arrangements. Further, current arrangements within the BSC allow a Supplier to aggregate a number of sites, within an Additional BM Unit, so long as these sites are all within that Supplier’s portfolio. This is commonly known as a Supplier aggregator function.
3. A Trading Party that is not a Supplier may use its existing BM Units for the purposes of bidding into the TERRE product, alongside bidding into the Balancing Mechanism as per the current arrangements. However, a Trading Party that is not a Supplier cannot aggregate sites. Should a Trading Party that is not a Supplier wish to aggregate sites, they would have to register as a VLP.
NaN.1 Can other BSC parties have aggregated Secondary BMUs?
Only a VLP is able to register Secondary BM Units (i.e. aggregate Half Hourly Metering Systems (HH MS) in order to provide balancing services to RR & BM whilst not being responsible for settling the volumes from those meters in regards to contracted v metered volumes).
A Supplier can register an additional BM where they can aggregate HH MS in order to provide balancing services to TERRE and BM, but remains responsible for settling the volumes from those meters in regards to contracted and metered volumes).
0.1 Can you register in multiple roles?
A BSC Party can have multiple roles under the BSC. For example, a Supplier can qualify as a VLP (and vice versa) and under, the VLP role, register Secondary BM Units
0.2 Where can you find a list of all the charges VLP face?
The Schedule of Main and SVA Specified Charges guidance note detail the costs and charges for 2019/2020. You can find the guidance on the following webpage: BSC Costs & Charges
0.3 Can VLPs register assets on behalf of a third party (i.e. a client’s assets)?
A VLP can allocate a client’s asset metering systems (MPAN or MSID) to a Secondary BM Unit where they can aggregate the changes in those client’s sites loads or distributed generation output for sale in the Balancing Mechanism or Replacement Reserves markets. A VLP does not need to be the asset owner.
0.4 Can VLPs use a trading agent to participate in BM and TERRE?
The obligations under the BSC (and CUSC) remain with the registered Party. How Parties choose to ensure compliance is a business decision. To clarify as a VLP you will not be able to ‘trade’ on the wholesale market. Through the BSC, a VLP can offer balancing services to TSO for the BM and RR markets.
0.5 What are the penalties for over and under delivery in TERRE, and how does this compare to those in the BM?
For over delivery (in the BM or TERRE), there is no financial penalty in the trading charges (though you will have expended resources at site that you are not being paid for).
For non-delivered volume (BM or TERRE), a party will be exposed to the imbalance price. An additional non-delivery charge may be levied if the party is benefitting from non-delivery (e.g. the party paid £50, but the imbalance price is £40, which results in a £10 gain. In this case, the party will be levied an additional charge of £10).
0.6 Is there a limit to the size in MW of secondary BMUs?
0.7 In the case the BMU is larger than 50MW or 100MW, are there any additional requirements on the BMU (metering etc.)?
0.8 What data does a VLP need to send to Elexon for a Secondary BMU on a daily basis?
For their Secondary BM Units, VLPs do not need to send FPN nor live generation data to Elexon. BSC does require however that a VLP is compliant with the Grid Code (administered by the NGESO) which has a number of data requirements that a VLP needs to send to NGESO.
Please refer to Section Q for BSC requirements.
For NGESO requirements please refer to Grid Code.
BSC does require that a VLP inform us of the MSID (via MSID Pairs) that they wish to allocate to a Secondary BM Unit prior to offering Balancing Services. After delivery of balancing Service the BSC requires a VLP send ‘Delivered Volumes’ (i.e. the physically delivered balancing volumes) per site.
Please see Section S and
BSCP602 for process details
0.9 When will relevant data be published?
The P344 solution includes provisions for TERRE data (relating to balancing service providers in GB) to be published on the BMRS:
1. Following Gate Closure for each auction period, National Grid will send details of Replacement Reserve Bids to BMRA, who will publish them on the BMRS. The legal text allows up to fifteen minutes for National Grid to provide this data.
2. By thirty minutes after Gate Closure for each auction period, National Grid will send the results of the auction (as received from the LIBRA platform) to BMRA, who will publish them on the BMRS. These results include price and MW level data for all the Replacement Reserve Activations issued to GB balancing service providers; the Level of GB Need Met; and flows scheduled by LIBRA on Interconnectors.
3. BMRA will also include the results of the auction in the indicative imbalance prices, published (as currently) within 45 minutes of the end of the Settlement Period
NaN.1 Can a VLP setup MVRN Authorisations for a Secondary BMU?
MVRN Authorisations are setup from Primary BM Units to Energy Accounts. VLPs can only register Secondary BM Units and they hold Virtual Balancing Accounts instead of Energy Accounts and therefore MVRNs cannot be authorised.
0.1 What if an overlap occurs when submitting MSID Pairs?
An overlap occurs when a Pair of MSID’s are assigned to a SBMU and a different VLP submit the same Pair of MSID’s against a different SBMU for the same or overlapping date range as is already in the spreadsheet.
If the new EFD for the MSID Pair is after the ETD for the previous SBMU, there is no overlap and no further action need be taken.
If the EFD for the MSID Pair overlaps with previous entries, the new submitting VLP’s SBMU will acquire ownership of the MSIDs.
In addition to the BSC, there are a number of other industry codes which you may need to become a
Party to. The list of codes can be found on the
Ofgem Website with contact details of the relevant
Code Administrator. Your licence conditions will specify what codes you are required to sign up to. If you require further assistance on your obligations please contact Ofgem.
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