1. Mod 270 Potential Options Rob Hill 15/02/2009

2. Six potential options following discussion at last months Development Workgroup OptionNameDescription 1Elective DM for SSPs Use daily elective regime (Mod 224) to move a SSP with automated meter reading capability into a daily read submission regime. 2Aggregate logical meter number (CSEP) Aggregate SSPs with automated meter reading capability behind a single logical meter per LDZ using existing CSEP functionality. Shipper would then submit a single monthly aggregate read by logical meter for daily energy allocation. AQ and read submission process for individual SSPs to be continued as current. 3Aggregate large supply point Aggregate SSPs with automated meter reading capability as a single large supply point. Shipper would then submit a single monthly read for the LSP for energy allocation. 4Smart EUC (Rolling AQ) Build on mod 209 to allow monthly read submission to adjust AQs on a rolling basis. 5AQ Appeals for SSPs Open up the LSP AQ appeal process to SSPs, use regular read submission (mod 202) to allow more frequent appeal. 6LSP ElectiveAllow shippers to elect SSPs with automated meter reading capability as LSPs with a monthly read cycle.

3. Option 1 Elective DM for SSPs Description  Use daily elective regime (Mod 224) to move a SSP with automated meter reading capability into a daily read submission regime. Strengths  Uses existing systems capability Weaknesses  Cost prohibitive for SSPs (c£800/year)  Would require daily nomination of gas  Resource intensive for shippers and Xoserve  Systems constrained to a maximum number of sites 25,000 Issues  This is not a practical solution and has already been discounted in the modification proposal

4. Option 2 Aggregate logical meter number (CSEP) Description  Aggregate SSPs with automated meter reading capability behind a single logical meter per LDZ using existing CSEP functionality. Shipper would then submit a single monthly aggregate read by logical meter for daily energy allocation. AQ and read submission process for individual SSPs to be continued as current. Strengths  Uses existing logical meter capability  Available to all shippers with SSPs with automated meter reading capability Weaknesses  Some systematic changes required to enable aggregation, de- aggregation and continued SSP AQ review process. Issues  Who is best placed to aggregate and how are aggregated reads kept in sync with SSP reads?  How would the COS process work for aggregation and de-aggregation?

5. Option 3 Aggregate large supply point Description  Aggregate SSPs with automated meter reading capability as a single large supply point. Shipper would then submit a single monthly read for the LSP for energy allocation. Strengths  Uses existing aggregation and de-aggregation meter capability  Available to all shippers with SSPs with automated meter reading capability Weaknesses  Complex aggregation and de-aggregation process.  Breaks ‘linked by purpose’ rules for aggregation Issues  How would the COS process work for aggregation and de- aggregation?

6. Option 4 Smart EUC (Rolling AQ) Description  Build on mod 209 to allow monthly read submission to adjust AQs on a rolling basis. Strengths  Changes required are well defined Weaknesses  Long lead time for implementation  Uncertainty over regulatory support Issues

7. Option 5 AQ Appeals for SSPs Description  Open up the LSP AQ appeal process to SSPs, use regular read submission (mod 202) to allow more frequent appeal. Strengths  Uses a well defined and existing process Weaknesses  Semi manual processes therefore resource intensive.  AQ dead band may preclude AQ adjustment for SSPs Issues

8. Option 6 LSP Elective Description  Allow shippers to elect SSPs with automated meter reading capability as LSPs with a monthly read cycle. Strengths  Uses a well defined and existing process  Open to all shippers Weaknesses  Potential maximum volume cap due to system constraints Issues  Shipper loss process would need to de-elect from LSP to SSP