Chris Warner Network Code Manager UNC Modification Proposal 0369 Re-establishment of Supply Meter Points – measures to address shipperless sites Chris Warner Network Code Manager

Overview of Issue The Network Code ‘Supply Point Withdrawal and Isolation’ provisions were comprehensively reviewed as part of Ofgem’s ‘Review of Gas Metering Arrangements’ (RGMA) programme in 2004. Significant amendments were made within the remit of Network Code Modification 0675 (implemented 2004). No changes have been made to the provisions in UNC TPD Section G3 since then. The purpose of Modification Proposal 0369 is to: Render an increased level of rigour in the relevant UNC provisions to: Lessen the likelihood of ‘shipperless sites’ occurring (Unregistered Supply Points which are flowing gas or capable of flowing gas) Provide a mechanism whereby such sites are registered at the earliest opportunity Reduce the User community’s exposure to the consequences of ‘unidentified gas’

The case for change Re-establishment (UNC TPD 3.7) Re-establishment is the setting of a previously Isolated Supply Meter Point back to a status of ‘live’ If Transporters become aware that gas is capable of being offtaken at an Isolated SMP, the Transporter will: Notify the Registered User The Registered User will Re-establish the SMP Provided the Supply Meter was not disconnected from the Transporter’s system at the point of Isolation, the Registered User will be liable for all relevant charges: In this case given that no Effective Withdrawal has occurred retrospective charges levied will be limited to Transportation Commodity.

The case for change (continued) If an Effective Supply Point Withdrawal has occurred i.e. in addition to the Isolation of the SMP, the Registered User has Withdrawn from Supply Point ownership, provided the Supply Meter was not disconnected from the Transporter’s system at the point of Isolation: If gas has subsequently been offtaken, the previous Registered User is liable for all charges as if the Effective Supply Point Withdrawal has not occurred If gas has not been offtaken but is capable of being offtaken the previous Registered User will be responsible for Capacity and Customer charges as if the Effective Supply Point Withdrawal has not occurred

The case for change (continued) Limitations of Re-establishment terms Applies where: The Supply Meter remains connected to Transporters system. Retrospective charges will continue to be applied until the previous Registered User either undertakes physical works or re-establishes the SMP However: Retrospective charging provisions do not apply where the Supply Meter has been disconnected from the Transporters system

The case for change (continued) In the case of a Supply Point where an Effective Withdrawal has occurred and the previous Registered User has advised that it has disconnected the Supply Meter, circumstances may arise where: The Registered User has not correctly undertaken physical works to ensure that the Supply Meter has been disconnected from the Transporters’ system despite notifying the Transporter that such works have occurred The Supply Meter has been reconnected to the Transporters system but the Supply Point remains ‘shipperless’. Where this occurs there is no recourse to: Seek to levy retrospective charges from the previous Registered User Ensure that the Supply Point is re-registered (does not remain ‘shipperless’) (notwithstanding that TPD G3.7.6 identifies that a “Relevant Registered User” is the Registered User for the period commencing on the date of Isolation and ending on the next Supply Point Registration Date)

Solution components Isolated and Withdrawn Supply Points Where the Supply Meter which was installed at the time of an Effective Withdrawal is found to be offtaking gas or capable of offtaking gas, the Transporter will: Notify the previous Registered User Require that the previous Registered User registers the relevant Supply Point into its ownership If a Supply Point Confirmation is not submitted within one calendar month of such notification the Transporter will register the Supply Point on behalf of the previous Registered User (using the data attributes pertinent to the relevant Supply Point as at the point of Effective Supply Point Withdrawal).

Solution components (continued) Isolated and Withdrawn Supply Points Where the Supply Meter has been notified to the Transporter as disconnected from the Transporters system but that gas is identified as being offtaken through the Supply Meter installed at the point of Effective Withdrawal, the Previous Registered User will be liable for all charges associated with the Supply Point as if it had not been subjected to an Effective Withdrawal. Isolated only Supply Meter Points Where the Supply Meter has been disconnected from the Transporters system and gas identified as being offtaken through the Supply Meter installed at the point of Effective Withdrawal, the Registered User will be liable for all charges associated with the SMP as if it had not been Isolated.

Solution components (continued) Where the Transporter has visited a Supply Point premises for the purposes of undertaking a disconnection of the service pipe in accordance with the Gas Safety (Installation and Use) Regulations 1998 (GSIU) but upon visiting the relevant premises finds that the Supply Meter (installed at the point of Isolation and/or Effective Withdrawal) remains connected to the Transporters network and may or may not be capable of flowing gas, the Transporter will: Levy an appropriate charge to the previous Registered User in accordance with its Siteworks Terms and Procedures (UNC TPD G7)

Deemed Supply Contracts The proposed UNC Legal Text would reflect that in cases where the previous Registered User has procured an Effective Supply Point Withdrawal, but the Supply Meter (installed at the point of Effective Withdrawal) is found to be offtaking gas or capable of offtaking gas, the User Registration will be deemed not have ceased (up to and at the point of the next Supply Point Registration date or next Effective Withdrawal). In these circumstances a Deemed Supply Contract will exist in accordance with the Gas Act Schedule 2B Para 8(2)(a). In accordance with Condition 7 Paragraph 4(c) the Supplier (subject to the relevant licence provisions) may have recourse to recover from the consumer the charges to which it is entitled.

Supporting statistical information The current volume for Shipperless - PTS (February 2011) 1,176 (Same meter on site) AQ Profile 1 – 73,200 = 1,080 73,201 > = 96 Age since withdrawal < 1 year = 93 1-2 yrs = 329 3-4yrs = 244 > 4yrs = 510