1. UNC Review Group 0178 National Grid Distribution “Reclassification of SSP to Domestic only” Review Group Meeting – 22 February 2008 Chris Warner

2. Verification of Usage  As now, the User is expected to confirm the gas usage.  The Transporter will not be able to fully validate this assertion economically as this would require verification of the usage which would necessitate contact with each relevant end consumer.  Alternatively Transporter may be able to provide a higher level of validation in the application of a “maximum AQ value” of domestic usage,  For example a consumer with an AQ of =>500,000kWh would be unlikely to be using gas for domestic purposes.  Inclusion of validation to reject such a configuration within the Supply Confirmation Processes?

3. Scope of Use  The existing flag is not used in any settlement or other UNC process – merely recorded in the SPR.  As we understand it, the suggestion is to  apply RbD to domestic use SPs  Including those with AQ >73,200kWh?  Apply individual meter point reconciliation to all non- domestic use SPs  Including those with AQ <73,200kWh  Is this the sole application?  Is the intention to maintain existing processes for Supply Point Registration?  In 2004 BP raised Network Code Review Proposal 0700 which proposed the division of the Code into domestic and I&C sections. The Review concluded that there were insufficient drivers for change.

4. Aggregations  Which flag is utilised where Supply Point usage is mixed?  assume ‘defaults’ to I&C?  In the SPR the flag is marked against confirmations (i.e. per Supply Point) within the S38 file  Potential for the SP to move in and out of reconciliation via RbD dependent on a different Registered User’s view as to the gas usage.  Current processes mean this is only likely once per year due to threshold crossers.

5. Practical Code Implications  ‘domestic’ SPs with LSP AQs dealt with as if they are SSPs  Should they be re-designated in UNC as SSP and vice versa? (assume not)  Likely to require new defined terms e.g. SSP(i) and/or LSP(d)?  If the change is purely in respect of treatment for settlement purposes (ie: RbD or no RbD) then this can perhaps be ring fenced from all other transactions under the UNC which are subject to the consumption based LSP/SSP split.

6. Current Domestic Flag  Data quality issues with current flag  If implemented as part of 2012 it may be preferable and more accountable/auditable to develop new status’ which could be used as part of the Nomination/Confirmation process (although this would need file format changes in SPA).  A consistent approach across all transactions would appear preferable.

7. Consequential Implications  If the SMP becomes individually reconcilable by reason of usage (non-domestic) then logically the LSP ‘rules’ on  meter reading and  AQ calculation should apply (and vice versa)?  Would SSPs with I&C usage be eligible for elective DM service?  Confirmation cancellation rules may need revisiting.

8. CSEPs  Current processes do not provide the DNs with Supply Point level data at CSEPs  Aggregate level data provided  One Logical Meter Number (LMN) for all of a Users SSPs at a CSEP  One LMN per LSP  To facilitate within current systems, the iGT will have to request separate and distinct LMNs for each non-domestic SSP.  Given that iGTs see no benefit to the current requirements, they are unlikely to favour the additional complexity.

9. Benefits  Benefits for Transporter?  The Transporter is able to validate current consumption based market sectorisation  the level able to be applied under new proposal is lower  Introduces a greater level of SPs requiring Individual Meter Point Reconciliation (up to 40% increase in current population)  Under performance here may be additional uncertainty to RbD.  Benefits for Users?  domestic only  non-domestic only  SSP only  LSP only  mixed portfolio.