UNC Modification Proposal 0248 Meter Reading Replacement for AQs Chris Warner

Current situation The submission of AQ Appeals and AQ Amendments using two alternative dates and reads that provide a more realistic indication of the site’s consumption. There is an AQ Appeal/Amendment process which will allow the use of Meter Readings not currently registered within the Sites and Meters Database. There is the existing functionality to utilise a Meter Reading prior to Transfer of Ownership when challenging an AQ through the AQ Amendments process. The ability to replace the latest read; this functionality remains available up until a subsequent read has successfully loaded onto Sites and Meters database. Shipper Agreed Read process used to replace any opening transfer read whether estimated or provided by the incoming User.

Points for consideration Supply Points could fluctuate between the Domestic (SSP) and I&C (LSP) sectors failing to calculate a reflective AQ Value. The AQ Amendments process would be discontinued in the event that Modification Proposal 0209 were implemented. The aspiration of Modification Proposal 0209 is to deliver a more timely AQ calculation. This would potentially create more accurate consumption information. However, more recent reads are required to calculate an AQ value rather than historic reads. Only reads submitted after the previous year’s AQ calculation would be considered for future AQ calculations.

Points for consideration Replacement of Meter Readings prior to the UNC backstop date would offer no value as any reads prior to this date are not considered for AQ calculation (UNC TPD H3.2.3). Backstop date is currently 30th September 2002 (Changes to 30th Sept 2007 from 2010). Allowing the replacement of any read may have the effect of appearing to disincentivising diligence in validating Meter Readings prior to submission by the shipper/supplier. Effective User read validation routines may reduce the requirement to replace historic reads.

Points for consideration Modification Proposal 0242, is seeking to increase the current read window. Should this be implemented the aspiration is an increased number of accepted accurate/validated reads loaded to Sites and Meters database. There is an existing process for replacing Opening Meter Readings. Any such read should be managed through the inter-Shipper dispute process. The expectation is that transfer reads are not subject to Modification Proposal 0248. Effective and timely management of asset data would see an improvement on accepted read data.

Other process impacts Query process may need to introduced to facilitate Transporters ability to check replacement reads? (No USRV produced). User Pays considerations? As per current process Transfer reads can only be replaced as a ‘Shipper Agreed Read’.

Potential system changes required Ability to accept a read previous to last read held on Sites & Meters. Requirement to create additional ‘read type’ and/or read source that allows read to be loaded to S&M but does not generate reconciliation/filter failures. However, there would be a requirement to consider for AQ process. Remove Registered System User validations (if requirement to replace reads regardless of RSU). Generation of file to the RSU (at the time of original read) supplying read replacement details.