1. Legal Text Production Options for Discussion

2. Legal Text Production 2 Issues with current approach Issues with the current approach to legal text production Quality of Legal Text Consistency of output Impartial approach Transparency Sufficient detail in Modifications Timeliness of output Plain English

3. Possible solutions Raise Modification(s) Move Responsibility for Legal Text production Replace “Transporters shall prepare” with “Code Administrator shall prepare in line with the Guidelines on legal text production” Develop Guideline document Retain existing arrangements Develop “Guidelines on Legal Text Production document” Guideline document becomes a UNC ancillary document Other(?)

4. Proposed solutions Centralisation & Guidelines Places control with the Joint Office Addresses process concerns Delivers efficiencies of centralisation Guidelines deliver transparency Annual review drives improvement More complex change Guidelines only Retains existing Transporter control Addresses process concerns Retains existing “shared” approach Guidelines deliver transparency Annual review drives improvement Simpler approach

5. Proposed solutions Both proposals hang on the development of appropriate robust Guidelines that address issues The Guidelines document would be a Uniform Network Code (UNC) Ancillary Document The Guidelines would be subject to same change management as other UNC Ancillary Documents (V12) The Guidelines would be subject to an annual review with input from all parties. Review to be overseen by UNCC?

6. Legal Text Production (Guidelines only) 6 Business Rules – Guidelines Named points of contact with direct phone and email. Once appointed this should be added to modification Modification proposer has direct contact with appointed legal representative (proposer, not Transporter, is the client) Workgroup members or anyone with a legal question should be able to contact legal representative [?]

7. Legal Text Production (centralisation and guidelines) 7 Business Rules – Guidelines Named legal representative appointed in rotation from published list [may vary dependant on solution] Continuity is important and the relevant Legal representative should not be a temporary appointment. Would normally expect [12] month minimum commitment Legal representative communicates directly with party “client” who raises the Modification

8. Legal Text Production 8 Business Rules – Guidelines The named legal representative should not normally be replaced during the life of the modification Where an alternative (or closely interrelated) modification is proposed the appointed legal representative for the original modification should be appointed for any alternatives

9. Legal Text Production 9 Business Rules – Guidelines Legal representative to be free to attend key meetings to gain context, understanding and provide advice and guidance The work group can request the legal representative attends meetings to provide guidance / advice Guidelines to include SLA’s

10. Legal Text Production 10 Business Rules – Guidelines Legal representative to advise on development of modification to remove any ambiguity and assist with legal text production Legal representative to produce “linking” narrative document between the Modification and Legal text setting out the approach in plain English to converting the modification into the legal text

11. Legal Text Production 11 Business Rules – Guidelines Legal representative to present legal text to Workgroup (if relevant) Legal representative to present legal text to the Mod Panel Annual review of legal text production and report to Panel to identify any improvements

12. Legal Text Production 12 Business Rules – Guidelines Annual Legal budget published [?] Should guidelines document allow for replacement of legal representative if problems occur regarding competence [?]

13. Legal Text Production 13 Way Forward Agree preferred approach Get buy in from relevant parties Agree timeline for delivery GET ON WITH IT & DELIVER ASAP!