Subtitle etc Modification 0403 EU Third Package: 21 day switching with flexible objection period Anne Jackson October 2011

EU Third Energy Package: 21 day switching with flexible objection period Rationale for change Expected licence condition on Suppliers. Project Nexus is expected to be delivered within 3 years. The Industry is considering the process impacts of the introduction of Smart Metering. The Change of Supplier process will be considered during the delivery of these projects. Major investment in changing the Change of Supplier process should be made at that time. Analysis should be more extensive and in conjunction with the Electricity Industry. Looking for lower cost and faster solution to enable compliance.

EU Third Energy Package: 21 day switching with flexible objection period Solution Fixing the Confirmation Window to SRD - 7 Business Days through to SRD i.e. exactly as it is under the existing rules. Make the minimum confirmation lead time 21 Calendar Days (minus non-business days prior to confirmation request). Absorb any limitation of days in a flexible Objection period. Process Objection notifications on any Business Day within the period. Process registration requests on any Business Day following sign up or cooling off (as appropriate)

EU Third Energy Package: 21 day switching with flexible objection period Advantages Lower impact to xoserve systems –Gemini systems should not be impacted. –Confirmation Window remains as now (SRD – 7 Business Days) so no impact to activity or triggers during or after this period. No changes needed to other connected and existing processes, for example obtaining opening meter readings, the use of which also falls under the EU Directive. Current objection processing impacted only where and when bank holidays and non-working days occur. Pressure relates to xoserve interactions. Shippers and suppliers can continue to use non-business days, but xoserve will only process files on business days 100% of confirmations completed within 21 calendar days

Illustration 1- No bank holidays Features No Bank Holidays 7 possible days to raise objection Matches current 16 business day window, (where RQ & SSD included)

Illustration 2- One bank holiday Features One Bank Holiday 6 possible days to raise objection 14 business days in total

Illustration 3- One bank holiday in Objection Period Features One Bank Holiday in the objection period 6 possible days to raise objection with xoserve Suppliers/shippers may still utilise the bank holiday 14 business days in total

Illustration 4- Two bank holidays Features Two Bank Holidays 4 possible days to raise objection with xoserve 13 business days in total

Illustration 5- Four bank holidays Features Four Bank Holidays 2 possible days to raise objection with xoserve Suppliers/shippers may operate over weekends or bank holidays 11 business days in total

Illustration 6- Four bank holidays and Cooling Off period followed by non-business day(s) Features Four Bank Holidays Last day of cooling off period is followed by one or more non-business days Confirmation request raised on first business day possible (D-16 in illustration) 2 possible days to raise objection with xoserve Suppliers/shippers unable to operate over weekends or bank holidays 11 business days in total

EU Third Energy Package: 21 day switching with flexible objection period Possible difficulties Issue LSP’s will require nomination prior to the start of the 21 day window. Xoserve have up to 2 days to process / respond to files. This could eradicate or significantly shortened the business days in the objection period. Mitigation I & C LSP’s may be nominated during the contract negotiation or mitigated through contract terms. Domestic LSP’s can be nominated during cool off. Xoserve rarely use the facility and only around the AQ review period. Use of the facility is highly unlikely around the pressure points created by additional non-business days.

Thank You