Industry Governance Group 18.09.2008 Meeting Minutes

Date: 18.09.2008

Chair: David Egan – CERAttendees: ESB Customer Supply - Bridget

Finnegan, Martin Carty.

Energia – Edward Barr, Mandy Reid, Tony Thornton.

ESBIE – Bernadette Jennings.

ESB Networks – Kieran Finucane, Stephen Conway.

MRSO – Frank Leetch.

Design Administrator – Cormac Madden, Oonagh Delaney Susan Morrissey, Colm Gaffney.

CER – David Egan.

Geserv – Peter Varley, Babatunde Sodeke.

Vayu - Bryan Hennessey.

Eirgrid - Michael Callan.Apologies:Version Number 2.0Change Made RMDS update page 10. Text was amended from DUoS Group to Site

Address. “S. Conway confirmed that the Bureau is responsible for changing the Site Address”.

Slides of the meeting are issued separately

Agenda:

1. Minutes from Previous IGG Meeting C. Madden, RMDS

2. Review of Action Items C. Madden, RMDS

3. CER Update D.Egan CER

4. Gemserv Update P. Varley, Gemserv

5. Market Operations Update F. Leetch, MRSO

6. Retail Market Design Service Update C. Madden, C. Gaffney, RMDS

7. Market Design Update C. Madden, C. Gaffney, RMDS

8. Next Steps C. Madden, RMDS

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1. Minutes from Previous IGG Meeting:1. C. Madden asked participants if they had any comments to make about the minutes from the

last IGG meeting.

Participants had no comments to make and the minutes were approved.

2. Review of Action Items:1. IGG Actions

C. Madden presented the slide of IGG actions Closed and Carried Forward (Slide 3). Since the last IGG, 30 IGG actions have been closed and 23 actions are to be carried forward. He presented a breakdown of the actions indicating the responsible parties and the number of actions outstanding for each group.

C. Madden updated the meeting on the release of MCR165 ‘Recalculation of Estimates’.

E. Barr queried the fact that recalculation will not automatically update a change of supplier (or change of legal entity) reading that was estimated.

C. Madden replied that, while the update is not automatic, change of supplier readings are referred to MRSO who can manually update the estimated reading, as it is too serious an issue to automate.

F. Leetch confirmed that MRSO can handle situations manually where there is a significant difference.

E. Barr asked what triggered the event.

C. Madden thought the query comes in to an Outbox and is handled manually. Guidelines on how it should be triggered and how big a mismatch it has to be before it changes are required.

E. Barr asked is this an issue for the next IGG.

C. Madden replied that it is open to the IGG to propose under what circumstances change of supplier estimated readings should be updated. Two market changes had been proposed by suppliers around this issue. One that seeks to impose a 20 day limit on such a change and another that seeks not to have estimates at all for a Change of Supplier (which is in line with Northern Ireland).

E. Barr added that he thought the whole area needs to be looked at and suggested discussing it at the next meeting.

C. Madden agreed, adding that a fuller discussion might follow at the subsequent meeting, once the issues had emerged.

New Action Item – RMDS to propose to CER that the policy around the replacement of estimated Change of Supplier readings be placed on the agenda of the next IGG.

3. CER Update:1. Winter Peak Demand Reduction Scheme

D. Egan mentioned that a consultation paper on the Proposed Changes to the Winter Peak Demand Reduction Scheme and Powersave 2008/09 has just been published. The closing date for responses is the 25th September and it is hoped that decision paper will be published by October 1st. There are a few minor changes to the WPDRS document. The definition of a rebate1 has been changed. The ‘Rebate Rate’ is now to be referred to as a ‘Charge Rate’.

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3. CER Update:Also the WPDRS season which was from November to March has been changed to November to February. The size of the rebate is to be reduced from ten times to three and half times the size of the Reliability Payment. The Proposal also guarantees a minimum of two Powersave days between November 2008 and November 2009. Customers who are signed up to the Powersave scheme, are required to participate in at least one ‘Powersave Event’. This will provide revenue to customers who are registered and participate in a Powersave Event.

2. ESB PES STOD tariffs (ESB PES Seasonal Time of Day (STOD) tariff for Large Energy Users (LEU) from 1st October 2008 to 30th September 2009)

The closing date for responses to this document is September 19 th. The Commission proposes to approve PES’s revised proposal for a 12 month STOD for LEU customers with PES from the 1st October 2008 to 30th September 2009. The Commission proposes that PES customers who wish to avail of the STOD tariff will have to do so on or before the 31 st October 2008. Once a customer has opted for this tariff, that customer cannot switch to any other pricing arrangement before 30th September 2009.

3. Decision paper on PES allowable costs to be published.

D. Egan commented that PES plan to issue a decision paper on PES allowable costs. This proposed decision paper had been deferred because of the interim increase in electricity prices. This decision paper is due to be published on September 19th.

4. Smart Metering

A ministerial announcement was made last Monday which initiated the start of the Smart Metering plan. A customer recruitment phase for the pilot has commenced. Two thousand recruitment letters have been circulated to date. A further three thousand will be distributed by September 19th. A total of 55,000 letters are to be circulated in the next 4 to 5 months. ESB Networks have announced the vendors selected to provide smart meters for the trial. A notice to this effect has been posted on the Official Journal of the European Union (OJEU) website (http://www.ojec.com/). Meetings are taking place which are examining the functionality requirements for the implementation of a prepayment market model. The next Steering Group meeting is the 23rd October.

5. SIG

NIAUR published the Transmission Charging Statement for 2008/09, for use of the Electricity Transmission System in Northern Ireland. The includes:

The System Support Services Tariff Demand Transmission Use of System Charges Generator Transmission Use of System Charges

NIAUR also plan to publish a Joint Energy Retail Competition and Five Year Corporate Strategy document. This document will also incorporate NIAUR’s position on sustainability.

T. Thornton asked when this paper is due to be published.

D. Egan mentioned that he thought the Decision is due to be published in March 2009.

6. CER to schedule a workshop to discuss the Social Welfare FreeElectricity Allowance (Action Item 366)

This meeting has been arranged for next week. A subsequent workshop will be held with suppliers to further discuss the Free Electricity Allowance

1 A rebate is applied to customers who fail to reach their committed level of reduction.

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4. Gemserv Update

1. C. Madden announced that Gemserv had been successful in winning the contract for the next 1½ to 2 years for the provision of assurance services. A provisional meeting has been held with Gemserv and some new ideas have been discussed on how to better serve the assurance requirements of participants.

2. P. Varley commented that Gemserv were delighted to have won the contract and then introduced his colleague Babatunde Sodeke.

P. Varley updated market participants about the recent qualification of a small supplier. He mentioned that this small supplier soon realised that the threshold limits were likely to restrain their commercial aspirations, subsequently, the small supplier proposed carrying out the large supplier assurance process. P. Varley suggested that the thresholds were only just constraining the supplier and as such he didn’t consider it necessary to carry out additional assurance steps. It was determined (in conjunction with CER and RMDS) that the best approach was to increase the thresholds slightly on the condition that supplier provides them with a registration plan when they have their commercial deals in place.

P. Varley suggested that following on from this scenario that it was now an opportune time to redefine the definition of a Small Supplier and make it less rigid.

T. Thornton asked how a Small Supplier is currently defined.

P. Varley responded that a Small Supplier is defined by having less then 200 meter points and a maximum power supply of 10 Megawatts. These numbers came about at the time of market opening and were put in place to cover a short term situation. He considered that it was now timely to review the definition of a Small Supplier.

E. Barr asked what the proposed new conditions for the qualification of a Small Supplier were.

P. Varley suggested that any supplier that is using nothing other then web forms (i.e. no automation) could now be classified as a Small Supplier. He added that this is an initial proposal but it would have to be approved by the AAG (Assurance Advisory Group).

E. Barr asked when these proposals were likely to issue to the AAG.

P. Varley commented that they would be working on these proposals over the next couple of weeks. He requested that participants should confirm who their AAG representatives were. These representatives should be capable of making decisions on behalf of their respective organisations. Gemserv will issue any proposals to the AAG directly.

C. Madden added that during the SEM assurance, participants were surprised at some of the tests they were being asked to carry out and felt that the testing wasn’t representative of their situation. This happened even though the tests had been circulated in advance. This indicates that an active AAG is desirable.

New Action Item – Suppliers to nominate representatives for the Assurance Advisory Group and provide them to Gemserv, copy RMDS.

5. Market Operations Update

1. MRSO UpdateF. Leetch presented the MRSO update.

Meter Registration Agreement Code (AP347)F. Leetch apologised for the delay in releasing the new Meter Registration Agreement Code. This document still requires some outstanding legal work before it can be released. There are

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5. Market Operations Update

however no significant implications for market operations.2. 13th Month Re-Aggregation

F. Leetch mentioned that the re-aggregation for the period June 07 - November 07 was run at the weekend. MRSO will issue the details via CD this week.

New Action Item – MRSO to distribute the re-aggregation CD for June 07 - November 07.3. Distribution Loss Adjustment Factors (DLAFs) and Price Effecting Generation

F. Leetch gave an update on the Distribution Loss Adjustment Factors (DLAFs) which is normally more pertinent to the Wholesale market. The DLAFs are applied to Generation data rather than demand side data. Some of the Generation data affects the market price (7 sites). Currently EirGrid collects and processes this export data for MRSO as it is needed on a 7 day basis by the Market Operator SEMO. Since go-live in Nov ’07 EirGrid systems have not allowed proper application of the DLAF for these sites and they had a derogation of one year to put this right. A corrective action is being put in place for generation data for these 7 sites. A change is being discussed in the Wholesale Market to allow them to properly apply DLAFs (Mod_43_08). Some amendments to the Retail Market Design may be required to accommodate the changes. MRSO/RMDS will keep participants advised as this issue develops.

B. Jennings asked will this impact retail settlement.

F. Leetch responded that there was no direct affect on the retail market other than it will correct the data being fed into the error supplier unit. As a result the generators for these 7 sites haven’t been getting the full payment they were due. He mentioned that vast majority of distribution connected generation are not price affecting and are run autonomously.

F. Leetch announced his departure from MRSO in the near future. He thanked the IGG for their support and co-operation over his term as the MRSO representative.

New Action Item – MRSO to keep the market updated regarding the Modification concerning generator loss adjustment factors and Price Effecting Generation.

4. Meter Operator Update

There was no Meter Operator update. At the last IGG meeting P. Mallon mentioned that Meter Operators were looking at an interim solution until the new market message 131 is implemented.

6. Retail Market Design Service Update:1. Recalculation of Estimates

C. Madden mentioned that the Recalculation of Estimates went live at 2:00pm on September 16th. Some elements of this implementation were added which weren’t part of the initial MCR. This MCR therefore will have to be amended and agreed by the market. There is one element which wasn’t implemented as it relates to a separate workflow. This aspect of the change request is to do with meter changes. At present a meter reading from a removed meter will not trigger a recalculation and a further modification is being worked on to change this. The vast majority of recalculations are going ahead and appear to be working well. The volumes of withdrawal messages have gone up from to two to three thousand a day to between five and six thousand. The volumes weren’t considered to be alarmingly high.

S. Conway confirmed these volumes.

B. Finnegan commented that these volumes were much higher then the estimated volumes previously indicated.

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6. Retail Market Design Service Update:B. Jennings asked is the recalculation based on a tariff change.

C. Madden clarified that the price change condition has been removed from form the MCR. The main limitation is that the difference has to account for a ¼ of the Estimated Usage Factor for the year and there has to be a series of three or more estimate readings. The balance of the will be delivered at a later stage.

New Action Item – RMDS to monitor the volumes of messages arising from the recalculation of estimates.

2. Updating of Site Addresses (Action Item 370)

C. Gaffney gave an update on the issues of the Backlog of Meter Point Address Updates. He commented that he had a meeting with the Connection Bureau in Athlone. The Bureau is now the only group capable of amending the Site address. They have recently introduced more stringent controls for the approval of the Site address and as a result a higher number of proposed site address amendments are being rejected. Historically if the central market system accepted the Site address amendment then the address was changed. This has resulted in:

1. A number of duplicate addresses and2. Sites that the Meter Readers can no longer find.

The decision was therefore made to introduce more rigorous controls for site address amendments. The controls now include several additional steps for validating a site address. The Bureau have found that since these controls have been introduced that the number of valid address amendments have dropped, resulting in a significant increase in 014R rejection messages (Customer Details Change Rejection).

The following are the types of procedures used by the Bureau for verifying the site address:

1. Find out if the Site address already exists2. Is the site a one off, or part of a development3. Research the address (check New Connections)4. Determine if outside verification is required (Planning Authority)5. Carry out a site visit6. Does the address suggest a change in usage (Commercial or Domestic)

Most of the address amendment requests are for multi metering sites and housing/industrial estates. There is a considerable cost associated with amending a site, and this cost is borne by ESB Networks. If the site address is changing from say a domestic name to an industrial name then there is reluctance on the part of the Bureau to amend such addresses as a DUoS Group change may be required.

The Bureau is currently compiling a list of procedural steps to be carried out when verifying a site address. They propose that participants be made aware of the steps they carry out in order for them to understand why a message may be rejected. C. Gaffney proposed creating a Discussion Request to increase the number of Reject Reason Codes so participants have more precise reasons for the rejection of an address.

C. Gaffney mentioned that the Bureau have a backlog of address amendments going back as far as June 2008 (as of September 4 th). He asked suppliers not to send in duplicate site address amendment requests if the 013 message has been submitted after June 2008. He added that in one case 4 requests came in on the same day to amend the same site address. C. Gaffney presented the following examples (slides 13 to 16 of the IGG presentation).

Example 1 Request for no address change, but still accepted and entered by the supplier.

Example 2 Request to change the unit number. This message was rejected as there was an existing unit of the same number for the same address.

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6. Retail Market Design Service Update:

C. Gaffney added that the current reject reason codes do not currently indicate a duplicate unit number. He commented that adding a few extra Reject Reason codes shouldn’t be too difficult.

E. Barr asked would this require a Schema change.

C. Madden indicated that it would.

T. Thornton pointed out that in Example 2 the unit number sent in by the supplier may in fact be correct and the one in the CMS may actually be incorrect.

C. Gaffney responded that a considerable amount of time and effort is spent by ESB Networks in initially setting up the site address. The assumption therefore is that ESB Networks have the correct Site address data. He added that he would double check on this scenario.

New Action Item – RMDS to clarify the procedure used by the Connection Bureau for validating requests for changes to site address when there is a duplicate House / Unit Number.

E. Barr commented that their address amendments are checked with the customer.

M. Reid explained that when they get returned mail, they contact the customer to make sure that all communications are received by the customer. As part of their procedures the customers have to verify their address. Only when this verification step happens is the change request processed. They are therefore fairly sure that they have the correct address.

C. Gaffney gave an example of a site being physically located in one County but a change request to amend it to another County. He pointed out that the Meter Point address was 100% correct but for postal delivery it was better to use the adjacent County in the address. In these cases there may be a case for using / amending the Notification address rather than the Site address. He made the point that the Notification address may be under utilised.

T. Thornton asked how confident the Bureau was in rejecting the likes of a duplicate Unit / House Number.

C. Gaffney again made the point that Bureau carries out a considerable amount of investigation into any proposed site address amendments and that they would be confident in rejecting / accepting any address amendments. A site visit may be required which will further delay any address amendments and the cost of this site visit is absorbed by ESB Networks.

T. Thornton commented that it was good that procedures are being put in place but he was concerned about the ability of suppliers to be able to amend addresses.

C. Gaffney assured the IGG that the Bureau were keen to work on address issues suppliers might have, in order to try and resolve the suggested address amendments in an agreed and timely fashion.

C. Madden commended the fact that the Bureau is putting more rigid controls in place and that a dialog has now opened between the Bureau and participants was a worthwhile development. He commented that all the points being made are perfectly valid. Suppliers may only have one customer in an apartment complex in say Unit 6 and another supplier may already have a Unit 6 registered with them. The difficulty in this scenario is to accept the proposed suppliers change as this would require a complete survey of the apartment block. A commercial balance needs to be struck between rejecting the message and identifying the costs and resources required to carry out a more complete survey.

B. Finnegan made the point that suppliers are more concerned with the Billing address rather then the Site address. Getting the correct address is crucial for suppliers. She accepted that

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6. Retail Market Design Service Update:the examples were valid but she thought they were more the exceptions rather then the norm. B. Finnegan would welcome further dialog with the Bureau discuss additional issues.

C. Madden asked what other issues there were.

B. Finnegan mentioned that they get returned mail and requests from customers to amend their addresses. PES carry out a certain amount of investigation on the address and request an amendment. Some of these address amendment requests were being sent via email and they were being worked on. But since the Bureau has taken over the email account, these requests aren’t being addressed.

C. Gaffney replied that the email address was mistakenly issued to suppliers as this email address was created for communications between Database and the Bureau. He pointed out that suppliers shouldn’t be using this email address and that there is a backlog of approximately 200 emails.

B. Finnegan mentioned that prior to this they had another email address which was working well. She pointed out that they may make a request for multiple address amendments on an email whereas a market message can only be submitted for one address at a time. Communication needs to be more bidirectional on these address issues.

C. Madden mentioned that documenting the address controls will set a framework which should allow for further more structured discussion.

M. Reid asked was there a timescale in place for clearing the address backlog.

C. Gaffney didn’t know the timescale for clearing the backlog but he added that the Bureau is concentrating on clearing this backlog along with developing controls for making better address decisions. He added that the Bureau have concerns over the legal impacts of changing addresses. There is therefore a certain reluctance to change an address if there isn’t sufficient evidence to do so.

Example 3 This example illustrates the varying spelling differences between supplier requests and what is in the Regional Structure.

C. Gaffney added that the address request would change the Regional structure of the address. A Rejection Reason Code would again be useful for this scenario.

T. Thornton asked what proportion of these examples were as blindingly obvious as this one and why was this address request sent in at all.

C. Gaffney added that these examples weren’t the exception but the norm. The Bureau want participants to be made aware of the controls so participants can give guidelines to their staff on address amendments.

T. Thornton thought this example defied logic.

M. Reid thought that the creation of additional Reject Reason codes would help them learn more about the rejections and eventually help them prevent further rejections.

C. Gaffney thought that better use of the Notification address and additional Reject Reason codes could go a considerable way to resolving some of the address issues.

Example 4 This example shows a second request to alter addresses as the original change was made on the 7/7/08.

C. Gaffney gave the example of changing Leinster Street to IDA Industrial Estate. This address was IDA Industrial Estate 3 months previously. He asked how often do you amend the same address. This lead to the issue of whether this is a Commercial or Domestic unit.

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6. Retail Market Design Service Update:

E. Barr asked how you distinguish between a Domestic and a Commercial premise. He asked if it is just purely on DUoS group. This would be a false assumption as many sites that are classed as domestic aren’t really domestic.

C. Gaffney commented that he would need further clarification from the Bureau on this issue.

E. Barr mentioned that all water treatment schemes are deemed domestic in certain locations. These sites could be classed as DG1s.

C. Gaffney suggested that the Bureau know from experience whether or not an address is acceptable.

E. Barr mentioned that if a road forms part of a county boundary, then there is no definitive line between counties and the address you are trying to create may be placed in the wrong county.

C. Gaffney replied that the Bureau would have the X, Y co-ordinates of a site from the Planning Application and they would use these co-ordinates to determine the location and address of the site.

E. Barr mentioned that suppliers do not have the benefit of X, Y co-ordinates.

C. Gaffney confirmed that they don’t receive of X, Y co-ordinates but Post Codes would give better geographic information for all.

E. Barr asked what the latest information on Post Codes was.

C. Madden said that he would try and get information on this topic. He was aware that a request for re-evaluation of the business case was being re-evaluated arising from the previous proposal.

E. Barr asked what consideration they are giving to undelivered mail as part of this cost benefit.

C. Madden mentioned that a broad survey of stakeholders was carried out in 2004/05 as an input into the business case.

S. Conway added that there is a considerable amount of information on Post codes on the ComReg website.

New Action Item – RMDS to seek an update on the proposals regarding the introduction of postal codes.

C. Madden commented that there are a couple of things that can help suppliers. While there is a need for Post codes, an interim alternative would be to use the Postal Towns. These are used for new addresses on the CMS and would help the sorting and delivery of mail.

E. Barr asked if the list of Postal towns could be distributed.

C .Madden agreed to circulate the list of Postal Towns. He confirmed that E. Barr was correct about DG1 And DG2. While there are legacy issues with these DUoS Groups, the plan is to reassign these DUoS Groups based on consumption at a later date. Farm enterprises tend to be on domestic rates but some may actually have now increased their consumption considerably. This doesn’t change the fact that when a request comes into Database to change the DUoS group, they have to look at the request on its own merits.

New Action Item – RMDS to distribute to suppliers the list of Postal Towns to be used.

S. Conway confirmed that the Bureau is responsible for changing the Site Address.

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6. Retail Market Design Service Update:C. Madden mentioned that, in his experience, it is often fairly obvious from the address and the customer/organisation name whether or not a site is a business or domestic site. A certain amount of common sense will apply when accepting or rejecting an address.

C. Gaffney confirmed that the Bureau were a knowledgeable and experienced group and they are taking more time and effort to confirm the address amendments as they have the responsibility for capturing the correct address.

C. Gaffney then presented slide 17 indicating the various roles and responsibilities for site address creation and the various legal documentation used between different parties to the site address. The address creation may involve a Developer, Engineering Office, ESB Networks and the Planning Authority. The Bureau wish to indicate the extent of the work carried out in creating addresses. They are however concerned about Developers changing the addresses especially for half occupied apartment blocks. There are many legal documents between the various parties which depend on accurate site address information (e.g. Developers Agreement, Wiring Cert, Connection Agreement, Customer Supply Agreement etc.). In particular the Wiring Cert and the Connection Agreement have to match exactly. If a Developer amends an address then all these documents are impacted. The Bureau would therefore like some clarification from CER on whether or not developers should be allowed to amend an address after an address has been agreed with the planning authority. This slide highlights some of the concerns the Bureau has to consider. He pointed out that the Electricity bill is considered to be the most significant utility bill for securing bank accounts etc, and therefore developers shouldn’t be allowed to change addresses on a whim.

M. Reid pointed out that, in the North, if a Developer wants to change an address after building a property then the Local Council will produce a Renumbering Cert and this is used to amend all the addresses. The utilities then get a copy of this Renumbering Cert, and then you know exactly what you are changing and why you are changing it. This enforces compliance and standardisation of addresses. The utility doesn’t amend the address based on an instruction from a Developer; instead the Local Council makes this decision.

E. Barr added that this is how it works throughout Europe. The responsibility is placed on the Local Authority.

C. Gaffney agreed that the problem is with the Developer going directly to the utility rather than the Planning Authority for address amendments. This cost to amend the address is also being borne by ESB Networks.

S. Conway gave an example in Dublin where a Developer requested the amendment of 700 addresses. This request was made long after customers were connected.

C. Gaffney mentioned that this is where some direction from CER would be useful. These changes are having a direct impact on customers who are already connected. The Bureau will communicate the controls they are putting in place. He then asked participants if they were in favour of progressing DR to add additional address Reject Reason Codes.

Participants were in favour of creating this new DR.

New Action Item – RMDS to draft a DR proposing more Reject Reason Codes covering responses to requested changes in site address

New Action Item – CER to advise if they can give guidance on whether confirmation from the Planning Authority should be required in order to progress a request to change site address records on the CMS for MPRNs already connected and energised.

B. Finnegan asked if the Bureaus email address was still available for use.

C. Gaffney mentioned that their preference is to get request through messages.

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6. Retail Market Design Service Update:B. Finnegan asked how you communicate complicated address amendments.

C. Gaffney mentioned that he would get further guidance from the Bureau on the use of the email address. He also committed to issuing the address part of the RMDS IGG presentation to the Address distribution list.

New Action Item - RMDS to find out from the Connection Bureau if the email address previously used for requests to change site addresses is still available for this purpose.

New Action Item - RMDS to distribute the address slides to the Address Workshop contact list.

M. Reid asked C. Madden when the next schema release date might be.

C. Madden responded that his understanding is that there will be a schema release towards the end of 2009. The upgrade will take until the end of April 09 and development work should start from that date. This doesn’t stop interim releases which aren’t schema related.

E. Barr asked what is going to be in the next schema. He pointed out that the reject reason codes for addresses aren’t even at DR stage yet.

C. Gaffney replied that the schema release process does allow other change requests to be added to the prioritisation list closer to the schema release date. The impact analysis needs to be carried out.

E. Barr asked for the impact analysis to be carried out on all approved MCRs.

C. Madden thought it was best to progress the MCRs as far as possible so that when the market window opens the market will be ready.

New Action Item – RMDS to request an impact analysis on all the approved MCRs from ESBN.

7. Market Design Update1. C. Madden presented the Market Design Service Update.

DR 0157 - Addition of Vulnerable Customer data deletion flag on 102 V.2

The DR arose out of the concern that the vulnerable customer data for life support and non life support is not transferred to the new supplier during the change of supplier process. The proposal is to alert the new supplier during the CoS process to the fact that this data (life support, non life support or medical institution) did exist on the customer record in Networks system. The alert will be in the format of a flag on the 102 message which indicates that some vulnerable data has been removed from the record. This DR may be overtaken by events as the Data Protection Commissioner has agreed to a mechanism for possibly publishing the medical flag. Customer services are currently compiling a list of medical customers, and a letter will shortly issue to these customers. The customers will then reply if they do not want this information disclosed. This may then free up the data for publication.

E. Barr asked will this data be published on the web.

C. Madden advised that this was the intention and mentioned that following on from this it is proposed that the medical flag could also be added to the 105 market message.

E. Barr asked will the medical flag identify the medical problem.

C. Gaffney replied that the flag is a Yes/No flag which will indicates whether or not vulnerable

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7. Market Design Updatedata has been removed from the record.

C. Madden requested approval to progress this DR to MCR.

APPROVEDParticipants agreed to progress DR 0157 Addition of Vulnerable Customer data deletion flag on the 102 to MCR.

New Action Item – RMDS to progress DR 0157 ‘Addition of Vulnerable Customer data deletion flag on the 102 market message’ to MCR

2. MCR 0165 – Recalculation of Estimates Ver 2.0

C. Gaffney commented that this MCR will have to be re released to reflect what was actually delivered.

New Action Item – RMDS to release version 3 of MCR 0165 – ‘Recalculation of Estimates’ to clarify what has been released and what is planned for release in future under a new MCR.

New Action Item – RMDS to create a new MCR to track the planned changes related to the Recalculation of Estimates that were not released so far and will be referenced as such by version 3 of MCR 0165 – Recalculation of Estimates.

3. MCR 0167 - Delivery of 106D message to EirGrid

C. Madden commented that the Notification of de-energisation of QH meter sites is not currently being sent to EirGrid which results in the site being incorrectly assigned as terminated.

E. Barr commented that he had no problem with this MCR as it doesn’t affect suppliers.

C. Madden requested approval to send this MCR to CER for approval.

APPROVEDParticipants agreed to approve MCR 0167 - Delivery of 106D message to EirGrid.

New Action Item – RMDS to send MCR 0167 ‘Delivery of 106D message to EirGrid’, to CER for approval.

4. MCR 0168 – Addition of 331MM to notify of QH meter removal during QH de-energisation with meter removal process

The proposal is to mirror the process currently used for NQH de-energisation with meter removal for QH sites undergoing de-energisation with meter removal generating a 331 message. Since the current design provides that all 331 messages are issued to TSO as well as the registered supplier, this change will ensure that TSO are updated. C. Madden asked participants if this MCR could be approved.

APPROVEDParticipants agreed to approve MCR 0168 – Addition of 331MM to notify of QH meter removal during QH de-energisation with meter removal process.

New Action Item – RMDS to send MCR 0168 ‘Addition of 331MM to notify of QH meter removal during QH de-energisation with meter removal process’ to CER for approval.

5. SoLR Working Practice 17

C. Gaffney presented working Practice 17 for the Supplier of Last Resort (SoLR). A considerable amount of workshops were held with the ISC, MRSO, and the Supplier of Last Resort (PES). The working practice addresses three different issues:

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7. Market Design Update1. Preparing the data for handover to the SoLR at the end of Day 19.2. How Present < Previous readings are to be handled3. How Large Debits are to be handled.

C. Gaffney commented that the main concern for the Supplier of Last Resort was not the handling of the SoLR event but getting the data in a clean enough state for handover on Day 20. C. Gaffney then walked through the Day 1 to Day 19 of the SoLR Working Practice. The process has five distinct data groupings that need to be distributed / cleaned up by day 19. These data groupings are:

1. Energised and De-energised sites are sent to suppliers and the SoLR2. List of De-energised sites to be de-registered.3. Pending registrations with associated Re-energisations / New Connections4. Pending CoS to the defaulting supplier5. Outstanding Service Orders

At the last IGG concerns about acquiring the MPCC were raised. After discussing this issue with the MPCC Hub Team, they indicated that they can build a dummy MPCC to mimic the Defaulting Suppliers MPCC. This is a better fall back position as it allows for the automatic flow through of messages to the Central Market System as against MRSO manually handling the messages. All the de-energised sites are to be de-registered using the 021 market message (excluding sites with an outstanding re-energisation service order). For new connections MRSO will contact the customer to determine if the new connection is to go ahead and all New Connections are to be completed by Day 19. CoS registrations to the Defaulting Supplier are to be cancelled using the 011 market message. MRSO will inform all customers of the CoS cancellation. CoS (010) service orders to an Alternate Supplier prior to the Direction date are to be completed as normal. QH Registration Messages (010) have to be sent 6 clear working days before the required date (the CER Direction Date).

C. Gaffney mentioned that this process doesn’t really impact suppliers as it is more of a data clean up exercise for the SoLR. For Meter Works the following rules are to be applied:

1. Meter Operator will update the records of any completed meter works (FINI).2. Meter Operator will complete any scheduled meter works by 19 where possible. Any

scheduled meter works that are outstanding after Day 19 are to be cancelled.3. Where a new meter type is replacing the existing meter the SoLR is responsible for the

energy usage from the completion date of the meter works and not the Direction date. The energy cost for the intervening period will be recovered through the available SoLR recovery mechanisms.

4. Meter Operator will cancel any Meter Works that have just been created.

Re-energisations are completed within the defined SLAs. De-energisations for Non Payment of Account (NPA) are cancelled as soon as possible. De-energisations which are not Non Payment of Account (NPA) are to be de-energised before Day 19 if possible. Any outstanding de-energisations after Day 19 are to be cancelled.

C. Gaffney mentioned that the process presents a considerable amount of complexity which participants should take their time to review. He then presented the Present < Previous Reading process for which there may be a role for the Alternative Supplier. This process may be triggered by the Alternative Supplier / SoLR or on receipt of an actual read. A 208 Replacement Reading market message or a work item (triggered by an actual read) is sent to MRSO. MRSO will somehow identify this reading as a SoLR reading. The SoLR reading is readjusted and sent back to the SoLR / Alternate Supplier. The Present < Previous process covers the following 3 scenarios:

1. Where the Customer moves to an Alternative Supplier during the 14 day CoS period.2. Where the Customer moves to an Alternative Supplier after the 3 month lock-in.3. Where the Customer remains with the SoLR.

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Industry Governance Group 18.09.2008 Meeting Minutes

7. Market Design UpdateIt was proposed that customers be allowed a 10 month time limit (from the Direction date) for customers to dispute a SoLR reading. Ten months has been assumed to be sufficient time for a customer to dispute a SoLR reading. The decision issued by CER instructs the SoLR to move the Defaulting Suppliers customers to a regular tariff after 6 months (CER/06/006 section 2.2 f). Therefore it may be more logical to align the SoLR reading objection period with the SoLR 6 month tariff change. He asked what participants thought of the proposed ten month period for disputing a SoLR reading.

B. Finnegan pointed out that the change over read could be an estimate and that an actual read is received at a later date.

E. Barr asked will customers receive an actual read within the 10 month window.

B. Jennings commented that in the event of a SoLR event the onus is on customers to ensure that their details are correct as part of the move. Her opinion was that 10 months is a long time and she was in favour of reducing this objection period to six or even three months. The customers have a certain responsibility to check that their data is correct on or shortly after the SoLR Direction date. She thought ten months was too long a time period.

C. Gaffney mentioned that 10 months was an arbitrary figure proposed in order to facilitate the debate on a suitable timeframe. He suggested that 6 months might be a cleaner solution as there is a tariff change. A decision on this timeframe is required form participants and CER.

B. Finnegan was in favour of the 6 month window as it would be less work for all participants. A decision however will be required on how to handle SoLR exceptions after this date.

E. Barr suggested that a lot of these issues will depend on the availability of a meter reading. If you leave it for 10 months you have a choice of potentially 4 readings two of which are likely to be estimates. If you reduce the timeframe to 6 months then you considerably cut the possibility of having an actual read. He suggested that ESB Networks should take special reads for each of these sites and bear the cost.

B. Jennings asked about the possibility of requiring an actual or customer reading for a Change of Supplier.

C. Madden confirmed that this was the subject of a discussion request.

B. Jennings asked can an unscheduled reading be created for all the MPRNs affected by the SoLR event.

E. Barr replied that this is similar to a special read. The only problem he saw was that the MPRNs could be distributed nationwide.

T. Thornton didn’t see an issue with leaving the objection period at the proposed 10 months.

C. Gaffney mentioned that there was a SoLR tariff change after 6 months.

T. Thornton still didn’t think the tariff change was an issue.

C. Gaffney made the point that the SoLR cost recovery would therefore be over 10 months rather than 6 months.

B. Jennings thought that it made sense to bring the timeframe back to six months.

C. Gaffney mentioned that this is one question that needs to be answered and that some guidance from the Commission would be useful. No participant thought that this time period should be greater the 10 months.

New Action Item – Participants and CER to discuss and propose the length of time

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Industry Governance Group 18.09.2008 Meeting Minutes

7. Market Design Updatefollowing the SoLR event that a customer should be permitted to query the SoLR changeover reading.

C. Gaffney continued the presentation and raised the issue of cost recovery. Customers must provide evidence to the Alternate Supplier / SoLR that they have paid for the overcharged energy consumption and a refund is due. Both the Alternate Supplier / SoLR then compile the SoLR costs and submit these costs to CER for approval. How the Alternate Supplier / SoLR are reimbursed for costs needs further investigation and guidance from CER. The following assumptions also apply:

Defaulting Suppliers will not be refunding Customers. The Defaulting Supplier will receive credit for DUoS overcharges. Readings > 10 months will follow the normal market rules (for debate). MRSO and suppliers can identify a reading from the SoLR event. (Some further work

is required on this issue.) The Customer is obliged to provide proof of any overpayment. If the Customer moves to an Alternative Supplier between month 3 and month 10 then

the Alternate Supplier is obliged to refund the customer and recover the SoLR costs. The Present < Previous costs are recovered through the mechanisms proposed by the

Commission.

C. Gaffney pointed out that further detail on the cost recovery mechanisms is required. The SoLR decision was made in order to reduce the exposure of the SEM market and at the time it was proposed that some of the costs could be recovered through wholesale market charges. Since the decision, the cost responsibility has shifted slightly and the cost recovery needs to be addressed in more detail.

B. Finnegan added that the mechanisms for cost recovery become clearer as the detail of the working practice evolves.

New Action Item – Participants to review Working Practice 17 ‘the Supplier of Last Resort’ and give feedback.

New Action Item – CER to clarify the mechanisms and scope for SoLR cost recovery.

C. Gaffney then presented the Large Debits slide (28). The proposed length of time to query a SoLR Large Debit is 10 months. The process is a manual process with emails being sent to MRSO. MRSO will determine the new replacement start read and inform the SoLR by email. The Customer provides evidence of the tariffs to be applied. The customer is refunded and the costs are sent to CER for recovery. The following assumptions apply:

1. Standard disputes / withdrawals process cannot be used.2. The Defaulting Suppliers will not be rebilling customers.3. MRSO will advise the SoLR of any revised reading.4. The Defaulting Supplier will not receive a debit for DUoS charges.5. If the Defaulting Suppliers customers moves to an Alternate Supplier during the 14

day CoS window, then the SoLR costs are to be recovered by the Alternate Supplier.

E. Barr asked is the document open for amendments.

C. Gaffney replied that the document is in draft format and essentially all content is available for debate. He pointed out to participants that the SoLR event cannot be triggered by a Supplier Unit.

T. Thornton added that in GB each supplier has to make a case to the Commission for their SoLR costs.

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Industry Governance Group 18.09.2008 Meeting Minutes

7. Market Design UpdateB. Finnegan agreed that each supplier should be responsible for the SoLR cost recovery.

C. Gaffney mentioned that there wasn’t a much detail in the Decision paper for cost recovery.

C. Madden was of the opinion that suppliers would need to be given guidelines on cost recovery.

T. Thornton commented that acquiring customers through a SoLR event should be viewed positively.

C. Gaffney mentioned that a considerable amount of progress had been made on the SoLR working practice. However using the SSAC code to identify usage and demand data may not be feasible (as outlined in Decision CER/06/006). The Decision needs to be revisited to make the working practice more effective.

C. Madden thanked all participants for their input to the Working Practice.6. Action 367: MPRN/Name & Address Web Service

C. Madden mentioned that this action is to investigate the possibility of providing a Web Service where a supplier could send out a procedural call to the Networks website using an MPRN and pull back the Name and Address details. This would facilitate the suppliers amending their systems to permit the supplier’s representative to view and verify the address details prior to sending a request for a change of supplier. This service has already been developed for the contracting regulatory bodies and is used as part of the process of advising receipt of a completion cert to ESB Networks. C. Madden mentioned that the initial investigation was to determine if the same web service could be used by suppliers. The initial response was that the Web Service was not designed for high volumes and domestic customer names may also be displayed2. (The Data Protection Commissioner ruled at the time that if someone applies for a new connection to Networks, that there is an implicit request for supply and a Completion Cert. New connections are however treated a bit differently to existing connections.) It therefore looks like that a new Web Service is required but providing this service appears to be feasible. The next step is to create a Discussion Request based somewhat on the existing Web Service. A certain amount of this work can be done without directly affecting the market systems. The gas market is adopting a similar approach and it might be preferable if suppliers validated the address on screen themselves using this Web Service. Suppliers already indicate on the 010 market message that the there is a Supply Agreement in place which MRSO takes on trust. The address validation could also be taken on trust. This may reduce the requirement for the address matching software which is incorporated in the CoS process.

New Action Item – RMDS to develop a DR for a new web service to make MPRN details now on the extranet, available for use by suppliers.

7. Release Planning - Outstanding MCRs

C. Madden pointed out that this list needs to amended slightly and reissued. One prioritisation list has been received from a supplier. He urged other suppliers to prioritise the list of MCRs and submit them to RMDS. One other DR may be added to this list.

New Action Item – RMDS to reissue the list of approved MCRs.

New Action Item – Suppliers to prioritise the list of approved MCRs.8. Action Item 338 - ESB Networks to send a proposal to CER regarding transfer of

customers with annual consumption above 300,000 kWh from DG5 to DG6.

B. O’Connor presented a proposal for moving customers from DG5 to DG6. A proposal is to be sent to CER before the next IGG on how QH DG5 customers are to be transitioned to DG6.

2 Current market rules do not allow for the display of a domestic customers name.

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Industry Governance Group 18.09.2008 Meeting Minutes

7. Market Design UpdateThe longer term plan is to start with QH customers and eventually tackle domestic customers on inappropriate DUoS Groups for their size of load.

8. Next Steps:1. C. Madden mentioned the next IGG meeting was scheduled for October 30th.

Next Meetings of IGG: The following dates have been proposed for the IGG meetings for 2008.

30.10.2008 11.12.2008 22.01.2009

The following dates have been proposed for the IGG conference calls:

02.10.2008 16.10.2008

D. Egan thanked participants for their attendance.

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Industry Governance Group 18.09.2008 Meeting Minutes

Action Items:AI No. Description Assigned to Due Date

24 DR 112 New MPD 37 Market Process for New Transmission Connected site RMDS109 New Commercial Policy required to cover erroneous deregistrations ESBN

166 Raise a Discussion Request to prevent the use of estimate reads for a Change of Supplier. RMDS

196 RMDS to demonstrate the new features of the ARIS Retail Market Design at a future IGG. RMDS 10/01/2008

199 RMDS to reissue DR 0117 - Proposal to add Acceptance, Completion and Cancellation messages to Meter Works design before January 10th IGG. RMDS 10/01/2008

203 CER to finalise the approval of any outstanding MCRS CER 10/01/2008208 RMDS to publish a Glossary of Terms on the RMDS website. RMDS

224RMDS to report back on the two cases of failure by ESBN to adhere to the Change Control Process and the measures put in place buy the Support Centre to prevent a reoccurrence of this problem. RMDS

260 RMDS to log variances of the Usage Factor rule on the Market Issues log RMDS331 RMDS to develop the SoLR Working Practice to handle SoLR exceptions. RMDS

338 ESB Networks to send a proposal to CER regarding transfer of customers with annual consumption above 300,000 kWh from DG5 to DG6. ESBN 30/05/2008

347 MRSO to circulate the New Meter Registration Agreement discussion document by July 18th. MRSO 18/07/2008

349 P. Mallon to organise a presentation outlining the functional benefits of upgrading to SAP ERP 6.1. ESBN

366 CER to schedule workshop to discuss the Social Welfare Allowance before the next IGG (25th September 2008). CER 25/09/2008

367 RMDS to investigate providing a web service to provide correct address data to meet the data standards RMDS

369 RMDS to schedule workshop to discuss issues relating to the Technical Contact Address. RMDS

370 RMDS to investigate the backlog of Meter Point Address updates. RMDS

383 RMDS Update the Meter Category Code document with the New Meter category descriptions. RMDS

385 RMDS to find out the type of data to be issued from the Smart Meters. RMDS

387 Suppliers to provide feedback on MCR 0080 - Remove Meter Point Status Field from 017 message by August 28th. SUPPLIER 28/08/2008

388 RMDS to distribute and present the SOLR Working Practice by the September 25th IGG. RMDS 25/09/2008

389 Suppliers to prioritise the outstanding MCRs by the September 25th IGG. SUPPLIER 25/09/2008

402 RMDS to propose to CER that the policy around the replacement of estimated Change of Supplier readings be placed on the agenda of the next IGG. RMDS

403 Suppliers to nominate representatives for the Assurance Advisory Group and provide them to Gemserv, copy RMDS. SUPPLIER

404 MRSO to distribute re-aggregation CD for June 07 - November 07 MRSO

405 MRSO to keep the market updated regarding the Modification concerning generator loss adjustment factors and Price Effecting Generation. MRSO

406 RMDS to monitor the volumes of messages arising from the recalculation of estimates. RMDS

407RMDS to clarify the procedure used by the Connection Bureau for validating requests for changes to site address when there is a duplicate House / Unit Number. RMDS

408 RMDS to seek an update on the proposals regarding the introduction of postal codes. RMDS

409 RMDS to distribute to suppliers the list of Postal Towns to be used. RMDS

410 RMDS to draft a DR proposing more Reject Reason Codes covering responses to requested changes in site address RMDS

411

CER to advise if they can give guidance on whether confirmation from the Planning Authority should be required in order to progress a request to change site address records on the CMS for MPRNs already connected and energised. CER

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Industry Governance Group 18.09.2008 Meeting Minutes

AI No. Description Assigned to Due Date

412 RMDS to find out from the Connection Bureau if the email address previously used for requests to change site addresses is still available for this purpose. RMDS

413 RMDS to distribute the address slides to the Address Workshop contact list. RMDS414 RMDS to request an impact analysis on all the approved MCRs from ESBN. RMDS

415 RMDS to progress DR 0157 ‘Addition of Vulnerable Customer data deletion flag on the 102 market message’ to MCR RMDS

416RMDS to release version 3 of MCR 0165 – ‘Recalculation of Estimates’ to clarify what has been released and what is planned for release in future under a new MCR. RMDS

417RMDS to create a new MCR to track the planned changes related to the Recalculation of Estimates that were not released so far and will be referenced as such by version 3 of MCR 0165 – Recalculation of Estimates. RMDS

418 RMDS to send MCR 0167 ‘Delivery of 106D message to EirGrid’, to CER for approval. RMDS

419 RMDS to send MCR 0168 ‘Addition of 331MM to notify of QH meter removal during QH de-energisation with meter removal process’ to CER for approval. RMDS

420Participants and CER to discuss and propose the length of time following the SoLR event that a customer should be permitted to query the SoLR changeover reading. SUPPLIER

421 Participants to review Working Practice 17 ‘the Supplier of Last Resort’ and give feedback. SUPPLIER

422 CER to clarify the mechanisms and scope for SoLR cost recovery. CER

423 RMDS to develop a DR for a new web service to make MPRN details now on the extranet, available for use by suppliers. RMDS

424 RMDS to reissue the list of approved MCRs. RMDS425 Suppliers to prioritise the list of approved MCRs. SUPPLIER

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