Wales & West Utilities Entry – Standard Special Condition D12 Richard Pomroy – Commercial Manager

Licence SSC D12 1 Purpose Outlines purpose of condition 2 Requirement (subject to paragraph 5) to make an entry offer to an applicant wanting to enter gas into the licensee's network once all information required by the licensee is provided 3  Requirement to set out connection terms including: the date which gas will be permitted to enter (no unreasonable delay) terms that offer the maximum flow available from time to time on the pipe-line at the time of the offer unless the applicant requests a lower flow rate the terms for cost recovery and reasonable profit, so far as they will not be recovered from elsewhere, for reinforcement or any other work necessary to make gas entry point available the means by which disputes may be escalated to Ofgem pursuant to paragraph 8 the terms relating to the gas entry agreement (the NEA)

Licence SSC D12 4 Requirement to offer terms as soon as reasonable practicable and in any event no more that 6 months after application containing all information reasonably required is received 5 No obligation to enter into agreement if licensee likely to: be in breach of Gas Act 1986 Section 9 duties, be in breach of Gas Act 1986 Section 16 related regulations or be in breach of other enactments relating to safety or standards relating to the transportation business, be in breach of the UNC, be in breach of other licence conditions

Licence SSC D12 6 Requirement not to discriminate unduly 7 & 8  Dispute Resolution Ability for Ofgem to step in on a dispute relating to initial set-up or variation 9 Requirement to publish principle terms (having regard for confidentiality) no later than one month from date of entering into a gas entry agreement

Licence SSC D12 Where does this leave us? Other options Is it undue discrimination to require propanation? If it is and networks admit low CV gas does this conflict with SSC A17? Licensee shall act in a reasonable and prudent manner in the operation of the pipe- line system … in so far as such operation may affect the operation of the pipe-line system of any other relevant gas transporter Other options Smaller charging zones but time and cost of implementation to transporters and shippers(?), also may be big impact on customer immediately downstream of entry point Networks install propanation and paid for by generality of customers but does this conflict with implication of Gas Act 1995 section 12 that operator of gas processing facilities should own apparatus? Amend Gas Calculation of Thermal Energy Regulations to remove cap for flows below a certain threshold but still have issue of customer immediately downstream of entry point

Other documents to be considered Gas Act 1986 Sections 9, 12,13,16, 21 Gas Act 1995 Section 12 Gas Transporter licence SSC A17 Uniform Network Code (UNC) Transportation Principle Document (TPD) Section I Offtake Arrangements Document (OAD) Section F