Mod Proposal Prevention of "Timing Out" of Authority decisions on Modification Proposals Nick Reeves

Background  A mod is said to have “Timed Out” if Authority decision has not been made in time to allow implementation by the proposed date  “Timing Out” identified as an industry issue in 2007 following Balancing & Settlement Code (BSC) mods P198, P200, P203 & P204  Following “Timed Out” BSC mods, Judicial Review deemed that Authority lost ability to decide on “Timed Out” Mods  Ofgem sought views on potential solutions to eliminate risk of “Timing Out” re-occuring & recommended either changes to licenses or industry codes (May 09)  Mod represents National Grid NTS’ view on most efficient solution

Proposed Changes (1)  Change Mod Rules to include a more structured approach to including suggested implementation dates within mod templates;  A minimum of two suggested fixed implementation dates with the associated decide by dates, e.g.  Decide by 18 th February for implementation on 18 th March  Decide by 18 th April for implementation on 18 th May, and  One suggested flexible implementation date, e.g.  Two Calendar Months after an Authority Decision  Important to remember that both type of dates above are required if User chooses to include a suggested date within the proposal  Users will still be able to leave suggested date blank if not critical or practical to include

Proposed Changes (2)  Users wishing to include suggested implementation dates must include accompanying justification for chosen dates  Applies to all type of proposals  All implementation dates provided within proposals will continue to be “Suggested”  Suggested implementation dates will continue to be non-binding  Transporters will continue to confirm the implementation date at the time of the Authority decision has been made

Purpose & Expected Benefits  Ensure greater clarity of mod implementation dates to industry  Promote development of possible implementation options within Mod proposals  Provide consistent structure for presentation of suggested implementation dates  Promote development of justification to support suggested implementation dates  Stimulate industry debate of optimal implementation timings & costs (particularly relevant to User Pays proposals)  Apply industry best practise & promote consistency across industry codes  Remove risk to industry of “Timing Out”  Improved consideration of possible options to aid industry understanding  More detailed analysis of the most cost efficient implementation date  More informed representations and Authority decisions  Allows realisation of mod benefits at earliest opportunity  No wasted / duplicated effort in re- raising Mod proposal  Better facilitation of relevant objectives associated with mod process (A11.2 9) & UNC (A11.1 (f)) PurposeBenefits

Any questions / suggestions to aid clarity?  ??