Industry Governance Group IGG Meeting Minutes · Industry Governance Group IGG Meeting Minutes ... Industry Governance Group IGG Meeting Minutes ... 948/1004 ESBN to analyse the process

Industry Governance Group IGG Meeting Minutes

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Date: 8th March 2017 Time & Location 09:30 – 12:30 – UR Offices, Belfast

Chair: Elaine Gallagher, CER

Attendees: Name Location

David Walshe, Alice Mooney RMDS

Elaine Gallagher, Clare Mulcahy CER

John Bracken, Aileen Greaves, Theresa O’Neill, Theresa

Williamson, Marina Hunt ESBN

Nirav Vyas, David Kemp Gemserv

Gerry Halligan MRSO

Siobhan Melvin SSE Airtricity

Seán Doolin Electric Ireland

Stevie Donnelly, Gillian Kinsella BGE

Kevin Sheridan, Krystle Chapman Energia

Jesica Gregory PrepayPower

Tadhg Gunnell Pinergy

John O’Dea Eirgrid

Apologies:

Version Number

1.0

Status

Agenda:

1. General

2. Actions from Previous IGGs/Conference Calls

3. New IGG Actions

4. CER Update

5. ESBN Update

6. Gemserv Update

7. MRSO Update

8. Retail Market Design Update

9. Notice Board Planned Maintenance, Reminders from IGG, etc.

10. AOB

1 – General

D Walshe enquired if everyone was happy to sign off on the minutes V2.0 of the last IGG meeting. Minutes Approved.


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2. Actions – Previous Conference Call & IGG D Walshe provided the Action Item Update. 8 IGG actions were closed since the last IGG Meeting (not including this current IGG meeting). Suppliers can email RMDS if they require the closure details of these actions. 10 IGG actions have been carried forward. They are outlined below.

Action Items

948/1004 ESBN to analyse the process where Move out with no Move in takes place and make proposals

based on existing Supplier processes for best business practise within this area. Process must enable MPs to notify CMS when a move out without a move in takes place. Proposal to be issued to Market in the form of a DR. (The issue is an amalgamation of 948 and 1004).

Update for IGG

This action is an amalgamation of Actions 948 & 1004.

ESBN has a presentation on this Action.

Discussion at IGG

A Greaves gave a Presentation on this Action. See Section 5 ESBN Update for details.

Action deemed closed.

Forum Logged: IGG Assigned to: ESBN Status: Action deemed Closed Due Date: 08.03.2017

1032 De-energisations: CER to revert to ESBN with regard to their schedule of charges for De-

energisations.

Update for IGG

CER to give an update on this Action.

Discussion at IGG

S mac an Bhaird reported that the CER has previously engaged with the ESBN on the schedule of

charges in 2016. The Networks Team within CER is responsible for approving any de-energisation

charges. The ESBN Commercial Team is to engage with the CER Networks Team on this matter.

The CER will update the IGG Conference Call on the progress.

Action to remain open.

Forum Logged: CC Assigned to: CER Status: Action remains Open Due Date: 05.04.2017

1035 ESBN Meter Project - ESBN & CER to agree on a reporting mechanism for the ESBN Meter

Project

Update for IGG

ESBN to provide an update.

Discussion at IGG

J Bracken reported that he has yet to agree a reporting mechanism with the CER.

A new Action was logged (Action 148) for ESBN to schedule an ESBN Meter Project Workshop to

take place later this month. See section 5, ESBN Update for details.

J Bracken reported that the detail of this Action 1035 shall be discussed at the Workshop.


Forum Logged: IGG Assigned to: ESBN/CER Status: Action remains Open Due Date: 04.05.2017


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1036 Revenue Protection Workplan. ESBN to seek formal IGG Approval for the 2017 Revenue Protection Plan circulated after the Revenue Protection Workplan Workshops held Q4/2016.

Update for IGG

D Walshe reported that at the Conference Call the RP Workplan was approved by MPs.

At the Conference Call E Gallagher added that she will review the RP Workplan in question and will

then formally approve the RP Workplan to S Gray by email.

Discussion at IGG

E Gallagher reported that the CER only received this Workplan recently and has not had time to

review it yet.

S Melvin added that Revenue Protection is a huge issue in NI at present and was discussed at the

Revenue Protection Workshop in 2016. This issue has built up over a number of years as resources

have not been allocated to it earlier. In ROI there isn’t a dedicated set of NTs resources to deal

solely with Revenue Protection matters throughout the country. SSE Airtricity requests that the CER

considers assigning dedicated NTs for RP issues within ESBN. This request was already raised at

the RP Workshop in 2016 and she would like focus on this now. S Gray raised this matter as an

output at the Workshop because currently NTs throughout the country schedule RP calls

themselves.

S mac an Bhaird said that this issue seems to be around the price control areas of resources versus

activity. He will discuss this request with the Team in CER that is charge of the Price Review for

Electricity. The CER plans to approve the Revenue Protection Workplan by the end of March 2017.

J Bracken reported that subject to the Agenda he will try to arrange for S Gray to give an update on

Revenue Protection at the next IGG in May 2017.

G Kinsella suggested that the approval for the 2018 Revenue Protection Workplan should be

brought to the table in late 2017 so that it is in place before the end of the year.


Forum Logged: IGG Assigned to: ESBN Status: Action remains Open Due Date: 04.05.2017

1037 CER 2017 Workplan - CER to present the CER 2017 Workplan at the next IGG.

Update for IGG

At the Conference Call, CER reported that it will provide a presentation of this Workplan at the IGG

in March.

CER to give a Presentation on this Action.

Discussion at IGG

S mac an Bhaird gave a Presentation on this Action. See Section 4 CER Update for details.

S Doolin reported that from a resource planning perspective, it would be useful to have earlier

visibility of CER’s workplans going forward. He added it is a bit frustrating as Suppliers do their work

planning cycles in August/September for the following year. There may be some significant pieces

of work that could come up from the CER in the 2017 plan for Suppliers that will have to be

retrofitted into internal business plans which have been resourced. This is quite frustrating for the

people that are planning these resources.

S mac an Bhaird committed that CER will present its 2018 workplan in advance of next year. It may

only be 90% complete but the CER will give MPs sight of its workplan. He recognises the frustration

and he noted it. He shall certainly ensure that the CER 2018 workplan will be available in 2017.

Action deemed closed.

Forum Logged: IGG Assigned to: CER Status: Action deemed Closed Due Date: 08.03.2017

1038 CER Personnel Changes - CER to circulate via RMDS the recent personnel changes within CER.

Update for IGG

At the Conference Call E Gallagher reported that the CER will present a slide outlining the

personnel changes in detail at the next IGG in March.

CER to give a Presentation on this Action.

Discussion at IGG

CER gave a Presentation on this Action. See Section 4 for details.

Action deemed Closed.

Forum Logged: IGG Assigned to: CER Status: Action deemed Closed Due Date: 08.03.2017


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1039 De-energisations - Suppliers raised a concern relating to their experience of ESBN not being

able to complete de-energisation due to access. ESBN will give a presentation on this matter the IGG in March 2017 (Linked to previous Action 1030).

Update for IGG

Action logged at the Conference Call.

ESBN has a presentation on this Action.

Discussion at IGG

ESBN gave a Presentation on this Action. See Section 5 ESBN Update for details of this Action.

4 New Actions were logged with regard to de-energisations. See New Actions, 1043, 1044, 1045 &

1051 for details.

Action 1039 deemed closed.

Forum Logged: CC Assigned to: ESBN Status: Action deemed Closed Due Date: 08.03.2017

1040 Lock Moratorium Dates - ESBN will give a presentation on the Lock Moratorium Disconnection Dates for 2017 at the next IGG in March. (Linked to previous Action 1031).

Update for IGG


ESBN has a Presentation on this Action.

Discussion at IGG

ESBN gave a Presentation on this Action. See Section 5 ESBN Update for details of this Action.

2 New Actions were logged with regard to the Lock Moratorium. See New Actions, 1046 & 1047 for

details.

Action 1040 deemed closed.

Forum Logged: CC Assigned to: ESBN Status: Action deemed Closed Due Date: 08.03.2017

1041 ESBN Meter Project – ESBN to issue, via RMDS, the Meter Test details to MPs ahead of the next IGG in March 2017.

Update for IGG


ESBN to provide an update on this Action.

Discussion at IGG

J Bracken gave a flavour of the Meter Test results in his ESBN Meter Project Update, see Section 5

ESBN update for details. He will outline in full the Meter Test Details at the ESBN Meter Project

Workshop which shall take place within the next 10 working days.


Forum Logged: CC Assigned to: ESBN Status: Action remains Open Due Date: 04.05.2017

1042 IGG Meeting in Belfast on 08.03.2017 – RMDS to change the start time for the IGG to 09:30 and to notify MPs

Update for IGG


RMDS changed the start times of the IGG. Agenda issued to MPs on 01.03.2017.

Discussion at IGG

Action deemed closed

Forum Logged: CC Assigned to: RMDS Status: Action deemed Closed Due Date: 08.03.2017


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3. Actions – New IGG Actions

The following 11 new actions were logged at the IGG.

New Action Items

1043 De-energisations - ESBN to engage with the Data Protection Commissioner in relation to the

use of personal information held by Meter Readers being used by NT's charged with disconnecting premises. ESBN to determine if the use of this information if made available for de-energisations is classified as personal data. (Follow-on from Actions 948/1004 closed at IGG on 08/03/2017).

Discussion at IGG

See Section 5 ESBN Update for details.

Forum Logged: IGG Assigned to: ESBN Status: NEW Action Due Date: 05.04.2017

1044 De-energisations - Suppliers to provide comments on the De-energisation position as outlined by ESBN as presented in its slides. (Follow-on from Actions 948/1004 closed at IGG on 08/03/2017).

Discussion at IGG


Forum Logged: IGG Assigned to: Suppliers Status: NEW Action Due Date: 05.04.2017

1045 De-energisations - ESBN to consider ways of making the Market Message & Engagement Process between ESBN and Suppliers clearer. ESBN and Suppliers to consider what can be done to benefit Suppliers and to revert with detailed suggestions. (Follow-on from Actions 948/1004 closed at IGG on 08/03/2017).

Discussion at IGG


Forum Logged: IGG Assigned to: ESBN/Suppliers Status: NEW Action Due Date: 05.04.2017

1046 Lock Moratorium - ESBN to circulate the Lock Moratorium Update presented at the IGG to the IGG. (Linked to Action 1040)

Discussion at IGG



1047 Lock Moratorium - Suppliers to send comments/feedback on the Lock Moratorium update as presented by ESBN at the IGG on 08/03/2017. (Linked to Action 1040)

Discussion at IGG


Forum Logged: IGG Assigned to: Suppliers Status: NEW Action Due Date: 05.04.2017

1048 ESBN Meter Project - ESBN to schedule, via RMDS, an ESBN Meter Project Workshop to take place before 23/03/2017 (10 days) following the CER decision.

Discussion at IGG


Forum Logged: IGG Assigned to: ESBN/CER Status: NEW Action Due Date: 23.03.2017

1049 CER Rebrand - CER to circulate an update on the CER Rebrand.

Discussion at IGG

See Section 4 CER Update for details.

Forum Logged: IGG Assigned to: CER Status: NEW Action Due Date: 05.04.2017


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1050 SoLR - CER to clarify the extent of the Supplier of Last Resort Work that is planned and referenced in the CER 2017 Workplan. CER to determine if further consultation and an appointment process is in the scope of the work planned.

Discussion at IGG

See Section 4 CER Update for details.

Forum Logged: IGG Assigned to: CER Status: NEW Action Due Date: 05.04.2017

1051 ESBN SLA Agreement - CER to liaise with its internal Networks Team with regard to the wording of the paragraph pertaining to Access Arrangements in the ESBN SLA Agreement as briefed by ESBN in Action 1039 in relation to de-energisations. CER to revert via RMDS.

Discussion at IGG

See Section 8 Retail Market Design – DR1181 for details of this Action.

Forum Logged: IGG Assigned to: CER/RMDS Status: NEW Action Due Date: 05.04.2017

1052 Issues with erroneous de-energisation of sites for Non-Payment. ESBN to investigate how this is occurring and the scale of this issue as raised by Energia and SSE.

Discussion at IGG

See AOB for details.


1053 De-energisation Process whereby Customers are unable to contact their Suppliers directly. SSE Airtricity to submit examples of this issue. CER to review the previous Pilot findings completed by ESBN in 2015 into this issue & determine if it needs to be reopened.

Discussion at IGG

See AOB for details.

Forum Logged: IGG Assigned to: CER/Suppliers Status: NEW Action Due Date: 05.04.2017


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4. CER Update

S mac an Bhaird gave the CER update. S mac an Bhaird presented a slide on Recent & Forthcoming Publications. Refer to Slide for details. Recent Publications. The Electricity and GAS Retail Markets Report was published in Q3/2016. Forthcoming

Information Note – SMART Metering Call for Evidence/Scope Validation.

Information Note – Supplier Audit will be published within the next two weeks.

Monthly Switching Report – will be published in the coming weeks.

Annual Retail Report – scheduled for April/May 2017. There may be some new indicators included in this Report. CER will engage with Industry and there will be opportunity for MPs to submit comments.

Supplier Handbook – will be published in March/early April 2017.

Supplier Handbook Workshop – scheduled for Friday 10th March 2017.

Green Source Product Verification Information Session – scheduled for Friday 24th March 2017. 2016 was the 1st this Session took place. Due to a couple of practical issues the CER thought it would be useful for SEMO to give a presentation on the process and the lessons learnt at the Session on 24th March 2017. The session invite was circulated earlier this week.

S Doolin asked at what stage currently is the Supplier Handbook at. He added that the current tracked and annotated version of the Handbook contains comments that CER are still considering. There are also four other issues awaiting a decision. He asked if every decision will form part of one final document. S mac an Bhaird replied that all this detail will be discussed at the Supplier Handbook Workshop taking place on 10th March 2017. Outstanding decisions from the last version plus engagements with Suppliers over the last month or so have been included in the current version of the Handbook. D Paraschiv will outline the current version at the Workshop together with the emerging thinking on the decision questions. The CER is looking to submit the final version to the Commission by March 2017 for publication and will also consider anything raised at the workshop on 10th March. S Melvin asked when the Competition Review and associated questions will be published. S mac an Bhaird reported that he doesn’t know but will ask Colm O’Gorman in the CER. CER Retail Work Plan for 2017 S mac an Bhaird presented a slide on the CER Retail Work Plan. Refer to slide for details. J Gregory asked about the 1st Work Flow Item “Review of Debt Flagging Process” and asked what the objective of this work plan is. S mac an Bhaird replied that as it has been a number of years since it has been reviewed the CER believes it is a good time to review this process and recommend any changes. S Donnelly enquired what the decision around SoLR in Q4 2017 will entail. S mac an Bhaird replied the CER is reviewing how the SoLR works along with budget controllers and how


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this ties into the SoLR. The CER is working on any improvements for both Electricity and GAS. S Doolin raised a further question on the SoLR. He stated that the SoLR Paper which was issued a number of years ago included a provision for consultation and an appointment process and enquired if this will form part of the scope of this CER work plan. S mac an Bhaird replied that he will take an action to provide clarity on this matter at the next IGG or through email. The following action was logged. Action 1050: SoLR - CER to clarify the extent of the Supplier of Last Resort Work that is planned and referenced in the CER 2017 Workplan. CER to determine if further consultation and an appointment process is in the scope of the work planned. S Melvin enquired if there is any update on the CER name change and when it might happen. S mac an Bhaird agreed to take an action to get an update on this matter. The following action was logged. Action 149: CER Rebrand - CER to circulate an update on the CER Rebrand. Recent and SMART Metering Personnel changes S mac an Bhaird presented a slide on the Recent and SMART Metering personnel changes Refer to Slides for details. He added that Suppliers can contact the CER directly and/or arrange regular Meetings if they have any issues that they want to raise outside of the IGG.

5. ESB Networks Update

J Bracken, M Hunt, T Williamson, A Greaves & T O’Neill presented the ESBN update. Move Out/No Move in. A Greaves presented a slide on Move Out/No Move in. Refer to slide for details.

• The Current Market processes only allow for CoLE or De-energisations. • Different Suppliers have established different practices within their organisations. • This is ESBN’s proposal for an enduring solution to facilitate Suppliers informing ESBN when they

have a scenario where they have a Customer that has moved out and they need time to establish who the new customer is and effect a CoLE.

The enduring solution shall work as follows: This detail will form part of a DR which ESBN hopes to present at the next IGG.

Create a flag on the 013 market message to indicate that the Customer is no longer the customer at the address.

Remove any correspondence address details for this Customer.

ESBN will flag this Customer as no longer being the customer at this address.

Suppliers should instigate within their own organisation their process to follow-up with new Customer for CoLE.

If CoLE/CoS does not take place within 6 weeks the Supplier must instigate the De-energisation process for the address. ESBN/Suppliers need to agree what


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happens if this doesn’t happen.

This doesn’t address the safety or legal concerns for ESBN in not knowing who the Customer is at an address. Therefore it is imperative that Suppliers address the follow up for the CoLE. Any changes to Market Processes will need to be approved by CER.

S Melvin enquired if this DR will be included the 2018 Schema Release. J Bracken reported this is not in the Retail plan at the moment. S Melvin reported that this DR will potentially not be delivered until after the SMART Metering Schema Freeze 2022/2023 and in the meantime Suppliers will still have the Data Protection concerns where Suppliers are aware that a Customer has moved out but ESBN still have the wrong Customer on the account. J Bracken reported that this is one of the items that ESBN is going to Report back to the ReMCoSG on. ESBN is going to outline a Retail Workplan at ReMCoWG that follows this Meeting. S Melvin added that there is a Data Protection issue for Suppliers where they can’t notify ESBN that a Customer has moved out and this situation is going to remain now until after the SMART Metering Go-Live. The issue is that a Customer tells SSE Airtricity that he/she has moved out. SSE Airtricity closes the account. SSE Airtricity opens a “New Occupier Account”, other Suppliers call it something else. SSE Airtricity can’t advise ESBN of this until a new tenant is in the house, which could be the next week/month/year. ESBN still has the old Customer’s name on that account and are sending correspondence to that old Customer and the Connection Agreement is still in the old Customer’s name. A Greaves reported that the current Market processes only allow for a CoLE or a De-energisation and the DR will allow time for the Supplier to establish who the new Customer is. S mac an Bhaird added that SSE Airtricity’s comments are noted at this Forum. He sits on the ReMCoSG and will relay this matter to L Brien in CER who also sits on the ReMCoSG. He added that S Melvin can also write directly to the CER on this matter. S Melvin replied that she will go back to SSE Airtricty’s Data Protection Team and advise them of the status of this issue. J Bracken asked how Suppliers view the Long Term Solution outlined by A Greaves and asked if it provides a working solution. All Suppliers agreed it does. Access to carry out De-energisations. M Hunt gave a Presentation on Access to carry out De-energisations.

Refer to slides for details.

She outlined a slide on the following on

Gaining Access,

User of Meter Readers Data

Service Level Agreements

Code of Practice

De-energisations Outside,

Analysis of an example raised

Gaining Access


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M Hunt reported that ESBN makes every effort to gain access and that local NTs have a lot of information about how to gain access. ESBN obtains access from Suppliers, from the Management Companies it writes to, previous calls and from access details on SAP. She outlined the text that ESBN writes to the Management Companies particularly for access to switch rooms in Apartments Blocks etc. In the majority of cases ESBN never hears anything back from these Companies who, mostly, do not facilitate ESBN in gaining access. User of Meter Readers Data. M Hunt reported that the Data Protection Act prohibits ESBN from using personal information given to a Meter Reader by a Customer to enable access for Meter Reading, e.g. keys under a mat etc. S Melvin reported that ESBN’s interpretation as outlined wouldn’t be personal information as defined in the Act. Personal Information is something that can identify a person and is not what ESBN is saying e.g. keys under a mat etc. M Hunt replied that ESBN’s interpretation is that it is personal information given to the Meter Reader, it is personal information around the access to that person’s premises in order to gain access for Meter readings. S Donnelly highlighted the text in the “Conditions for connection to the Distribution System” in ESBN’s Presentation. It stated that “ESBN have to “disconnect the connection point” and to “read meters”. He believes that ESBN have the ability to undertake both tasks. M Hunt said that if a person gives the information to the Meter Reader in order to gain access to undertake a Meter reading, he can then withdraw that information for something else. It’s particularly to gaining access to read the Meter and not to disconnect. S Melvin added that Personal Data as referenced on the Data Protection Commissioners Website states that personal data is “data relating to a living individual who is or can be identified from either the data or from the data in conjunction with other information that is in or likely to come into the possession of the Data Controller”. In the example “keys under the mat”, there is no living individual identified there. M Hunt replied that it is personal information given for a particular purpose. It’s not just personal information that out there in the ether, it’s personal information that has been given to a particular individual to do a particular job. To transfer that information to another part of the Business to do another job is prohibited under the Act. E Gallagher stated that it may be the fact here that there are two different versions of legal advice being used. It would be interesting to look at case examples in terms of interpretation. It is all very well looking at what the Data Protection Website says but how this being interpreted by the Data Commissioner is the key question. She doesn’t think that by looking at this particular sentence in question that it clearly says it definitely is or definitely isn’t personal information. She also thinks it fair for Suppliers to get legal advice on this matter and to act accordingly on this advice. S mac an Bhaird reported that you’re asking for “one specific thing to read the Meter” and it’s not “to read the Meter and disconnect”. M Hunt added that there are two different agents involved in Meter Readings and Disconnections. In practical terms the Meter Reader goes along and is given access to read the Meter. The NT goes along and the Management Companies say there is no way to gain access. This is what’s happening on a practical basis. The NT is denied access to disconnect even if they have the access information. The Meter room is usually locked, the Meter Reader is shown where the key is but the NT is not allowed access to the key. E Gallagher states that this relates to “permission to enter for a purpose” and whether you have permission or not for that purpose.


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M Hunt read the information on the DPC website “if you obtain personal information for a particular purpose, you may not use the data for any other purpose and you may not divulge the personal data to a third party, except in ways that are “compatible” with the specified purpose. A key test of compatibility is whether you use and disclose the data in a way in which those who supplied the information would expect it to be used and disclosed”. She then read out a piece from the ESBN Service Level Agreements “DSO will depend on Suppliers to provide customer contact details and access arrangements where relevant to carry out this request” S Donnelly asked “how will Suppliers provide access arrangements” as stated in the SLA? Would Supplier’s tell Customers that ESBN is going out to disconnect them and open the door for them? This sentence doesn’t make sense to him. E Gallagher asked that before a disconnection takes place does there not have to be Supplier engagement with the Customer. K Chapman reported that usually, in the case of disconnections, Customers won’t engage. S mac an Bhaird added that on this matter it is best endeavours on all parties. M Hunt then outlined the “No access” detail as per the Code of Practice. She reported that in terms of outside De-energisations, ESBN carried out over 600 in 2016. To disconnect at the pole requires a two man crew on the ground and ESBN may need to trace cables. ESBN has also required the Gardaí to attend in over 70 Disconnection cases. The Gardaí cannot enforce de-energisations and are only there if there if there is aggressive behaviour and in one case the Gardaí refused to attend. With regard to “Underground de-energisations”, only four were de-energised in 2016. S Melvin said that only four went ahead because of the costs involved as it’s over €8,000 for an underground de-energisation. Customers have been de-energised in the first place because they owed money and you’re adding another €8,000 on their bill. S Donnelly enquired if you can perform an underground disconnect for a Multi-meter site. M Hunt replied that you can’t perform an underground disconnection for a Multi-meter site because you’ll disconnect the whole apartment block. M Hunt reported that ESBN will work with Suppliers who wish to obtain an injunction through the Circuit Courts for Non-Payments. ESBN understands that this matter is frustrating for both sides. S Donnelly reported that ESBN is being refused access to its Meters despite ESBN’s Conditions of Distribution whereby Customers cannot bar access to the Meter. He interprets the Law that ESBN can get the Gardaí to enforce disconnections when it is refused access to the Meter. M Hunt says that there is no law for ESBN to inforce this. ESBN has gone through this matter with its legal team in detail. The Gardaí cannot access premises unless they think there is criminal activity taking place and non-payment of a bill is not criminal activity. The only way to gain access in such cases is to get an injunction in the Circuit Court for non-payment of a bill. E Gallagher reported that there are two arguments here. The first being that any additional information that is being given by a Customer, in terms of access to the Meter, is access for a specific purpose and is personal information under the Data Protection Act. ESBN is also saying that any permission given to access a premise is permission to access for a purpose and that specific purpose is access for Meter reading, not for de-energisation. S mac an Bhaird stated that when ESBN cannot gain access to disconnect, that best endeavours is undertaken to de-energise and that ESBN should be engaging with Suppliers to provide the best service possible within the bounds of its legal advice. This engagement appears to be happening, however, there seems to be some disagreement with the Data involved and if it should it be shared by ESBN. This may be something that the EAI would like to get involved in if Industry believes that this is a big issue. He is


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also conscious that this issue has been around for a while and there doesn’t seem to be any resolution or easy wins associated with it. There seems to be two different legal perspectives in place - ESBN and Suppliers. The option for Suppliers to bring cases to the Circuit Court hasn’t been taken up by Suppliers either. K Sheridan reported that is matter is a huge issue for Energia and that there are huge costs associated with it. S mac an Bhaird added that if Suppliers have legal advice that says that ESBN’s position is wrong, and this can be presented to ESBN, then there may be a path forward. S Melvin asked what that path could be when there is two conflicting legal views. S Doolin asked if ESBN has interacted with the Data Protection Commissioner on the specifics of the issues involved. It is possible that each individual Supplier may have of come up with their own angle on this. M Hunt reported that C O’Connor was involved with this issue and ESBN sought legal advice on several occasions from ESBN’s legal Team in relation to this particular matter. S Donnelly suggested that perhaps a change in the Law could be required here in cases whereby ESBN can’t gain access. S mac an Bhaird replied that in order to effect a change in the Law the Industry would have to demonstrate that they have used all the legal tools currently available to them. Suppliers have not used the Circuit Court Injunctions available to them. If the Industry thinks a legal change is required then Suppliers can raise this but this would have to be something that Industry put forward rather than one or two Suppliers and that the EAI might be a good Body to pursue it. However, this path may be too difficult and he’s not sure what the political appetite is for such a change. S Donnelly added that these costs are being spread across all Consumers. He sees CER’s role in protecting consumers and that consumers aren’t being fully protected with regard to this matter. E Gallagher reported that even if the Government accepted that there is a need to change the legislation it would be a political issue and it would be quite difficult to change existing legalisation. It would also be useful to quantify the issue, i.e. how many instances are there and how much is it costing. K Sheridan said that this would require support from CER rather than just from Industry. There is a lot of money owed to Suppliers in relation to this matter. The framework Suppliers are working within is flawed and there is a fundamental problem with ESBN’s inability to access its Meters. E Gallagher reported that she believes it is really important to protect consumers. However, consumers also have contractual rights, property rights and constitutional rights. She requested that Suppliers request their legal people look at this issue. S mac an Bhaird added that from a practical perspective this matter needs to be raised up a level from the IGG - at the EAI for example. S Melvin requested that ESBN also look at making Market Messages clearer for Suppliers. At the moment they contain codes and abbreviations that are sometimes unclear for Suppliers. At the end of the discussion, 3 new Actions were opened: Action 1043: De-energisations - ESBN to engage with the Data Protection Commissioner in relation to the use of personal information held by Meter Readers being used by NT's charged with disconnecting premises. ESBN to determine if the use of this information if made available for de-energisations is classified as personal data. (Follow-on from Actions 948/1004 closed at IGG on 08/03/2017).


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Action 1044: De-energisations - Suppliers to provide comments on the De-energisation position as outlined by ESBN as presented in its slides. (Follow-on from Actions 948/1004 closed at IGG on 08/03/2017). Action 1045: De-energisations - ESBN to consider ways of making the Market Message & Engagement Process between ESBN and Suppliers clearer. ESBN and Suppliers to consider what can be done to benefit Suppliers and to revert with detailed suggestions. (Follow-on from Actions 948/1004 closed at IGG on 08/03/2017).

De-energisation Issue S Donnelly raised a further issue with regard to “no access” for unsuccessful disconnections in AOB. It was agreed at the Forum that this BGE’ query be included in the ESBN “Access to carry out De-energisations” discussion. S Donnelly reported that in some cases of unsuccessful Disconnection Requests the Market Message comes back to say it was not carried out and just says “No access”. BGE is looking for more information on the Market Message to provide guidance for what the next steps are. BGE is finding a lot of Market Messages with “No access”. S Melvin reported that this matter ties in with the discussion and action logged earlier for NTs to provide Suppliers with more information as to what is exactly happening (Action 145). T Williamson replied that the system only allows for a certain number of characters that NTs can use. If Suppliers need information on particular cases they should contact Meter OPs. S Donnelly replied that BGE is not going to contact ESBN after every instance. BGE have put together a list of these cases and can share this list with ESBN. BGE are also finding Market Messages with “Premises not found” even though Meter Readings have been undertaken yet the NT can’t find the Meter. S mac an Bhaird added that this matter also ties into Action 145. J Bracken agreed to revert on this matter. Lock Moratorium. T Williamson gave an Update on Action 1040 Lock Moratorium Dates.

In 2015 & 2016, ESBN extended the last date for de-energisation for Commercial Customers to a week later than the last date for de-energisation for Domestic Customers.

The last date for de-energisation of Commercial Customers in 2016 was Thursday 15th December. The last date for the logging of commercial de-energisation orders was 8th December 2017.

The last date for de-energisation of Domestic Customers was 8th December 2016 with the last date for logging de-energisation orders being 1st December.

T Williamson reported that ESBN noticed that the number of de-energisation orders did not decrease when Suppliers could only log commercial properties. In the period of 2nd to 9th December 2016 591 de-energisation orders were logged - 321 of which were commercial customers only. ESBN compared this to week 14th to 20th October – where the total for domestic and non-domestic de-energisations was 512 but only 232 of those were for de-energisation including both commercial & domestic customers.


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In the Period of 15th to 23rd December 2016, which is the period that Suppliers are looking to extend, ESBN completed 320 re-energisations. A high number of Electrical Wiring Certs issued in this period for customers getting into premises for Christmas. ESBN feels that these dates are satisfactory and that it’s important that these dates for de-energisations to be kept and not changed. S mac an Bhaird said that’s it fair to say that these dates will be reviewed on a yearly basis. T Williamson agreed with this. S Donnelly reported that Suppliers would really need to see the figures in detail to analyse them in order to be in a position to respond to them. ESBN agreed to take an action to circulate the Lock Moratorium Update. New Action: 1046: Lock Moratorium - ESBN to circulate the Lock Moratorium Update presented at the IGG to the IGG. (Linked to Action 1040) S Donnelly reported that domestic disconnections stop at a certain date and BGE’s view is that ESBN’s resources are potentially freed up to carry out more non-domestic disconnections and that this date should be pushed out. M Hunt reported that ESBN is also undertaking a lot of other work such as re-energisations on these dates. In 2016 ESBN completed 321 re-energisations for all customers in that week in question. S Melvin reported that from a Supplier’s point of view Christmas is the busiest period for the majority of business customers. If customers are not engaging or paying but believed that they could get de-energised over Christmas they might be more willing to engage and agree to a payment plan. She agreed that the 8th of December is too early for business customers de-energisations. Suppliers give 14 days’ notice thus it is the end of November when Suppliers are sending out notifications that they are going to request de-energisation. A new Action was logged for Suppliers to send in comments on the Lock Moratorium Update before the next IGG. 1047: Lock Moratorium - Suppliers to send comments/feedback on the Lock Moratorium update as presented by ESBN at the IGG on 08/03/2017. (Linked to Action 1040) ESBN Meter Project J Bracken gave an ESBN Meter Project Update. Refer to slides for details. A new Action was logged for ESBN to schedule an ESBN Meter Project Workshop to take place within the next 10 working days. The CER agreed to see if a meeting room in the CER offices in Tallaght would be available for this Workshop. Action 1048: ESBN Meter Project - ESBN to schedule, via RMDS, an ESBN Meter Project Workshop to take place before 23/03/2017 (10 days) following the CER decision. Eircodes


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J Bracken gave an Eircode Update. Refer to slide for details. J Bracken reported that the Department is getting very animated about Eircodes and has contacted him with the view of getting Eircodes rolled out sooner rather than later. There are three Eircodes MCRs:

MCR 1140 Introduction of Eircodes into the Retail Market

MCR 0175 New Reject Reason for Address Change Rejection

MCR 1169 Addition of Postal Code to two Downloadable Meter Point Files. These 3 MCRs will be delivered under a Schema Release. A file was made available by ESBN for all Suppliers that wished to implement Eircodes in advance of delivery of the three MCRs. Some Suppliers have taken up the offer of that file. That file is still available should other Suppliers wish to avail of it. A Greaves reported that DR 1187 - Solution to Introduce Eircodes using A2 Correspond Address was circulated on 6th March 2017. This DR was discussed later in the Forum. See Section 8 Retail Market Update for details. J Bracken reported that he has received a request from the Department for them to attend a future IGG to discuss Eircodes. The Department gave a presentation to the GAS Market recently on this matter. The Department also reported that it intends to contact each Supplier separately on this matter. K Sheridan reported that Energia needs sight of when Eircodes are going to come into the Market and that they should, ideally, come in to both the Electricity and GAS markets at the same time. S Donnelly said that BGE are of the same view. As Eircodes require a Schema Change he asked if the Department is aware of this and do they understand the mechanics of what can and can’t happen. J Bracken replied that they are aware of this but are keen to see Electricity Bills with Eircodes on them as soon as possible. K Chapman reported that Energia is getting a bit of pressure from customers to add Eircodes on Bills as soon as possible. Energia has added Eircodes to the Correspondence Address so a tidy-up exercise will be necessary after Eircodes Go-Live in the system. ESBN I-SEM Programme T O’Neill presented an update on the I-SEM Programme. Refer to slides for details.

ESBN I-SEM has updated its documentation to reflect the change in the timelines in that the I-SEM Market Trials will run from December 2017 to May 2018. The Go-Live date for the I-SEM is now 23rd May 2018.

Due to the revised I-SEM timelines the Market Trial Working Group will be established by the I-SEM Project in the summer of 2017 and not March 2017.

S Melvin enquired about the first sentence on the slide “No changes are indicated to the Harmonised Retail Schema of the CoBL”. She added that the NIE Networks slides for CDA Meeting were different in that it states that “Supplier charge and decision has been issued. Solution will required System Market Change”. T O’Neill reported that the Supplier Charging decision was as a result of the Supplier Charging Consultation. The de-Minimis charging is going to stay in place until sometime after the I-SEM Go-Live. Price Effecting Units.


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5 Supplier Units have moved to become Price Effecting, and a decision by SEM-O on the remaining 2 is pending.

6. Gemserv Update

Due to time constraints no Gemserv update was given. MPs were asked to Refer to slides for details and to send any questions they have to RMDS.

7. MRSO Update

Due to time constraints no MRSO update was given. MPs were asked to Refer to slides for details and to send any questions they have to RMDS.

8. Retail Market Design Update

D Walshe gave the Market Design Update. LTCA D Walshe outlined the LTCA Timeline from the Presentation of the Auditors Report to issuing the Report from the Working Group to the CER. He reported that the items highlighted in red are complete. Refer to slides for details.

A Meeting took place on Friday 3rd March 2017.

The Final Audit Report was delivered.

The Audit Reported was approved by the LTCA Working Group.

The Working Group agreed that existing LTCA cases will not be covered by a future OSD and are considered closed from an LTCA perspective.

RMDS to circulate a definition to cover the scope of an OCD that shall be implemented “going forward”.

The Working Group will then reconvene and will then issue a Report to the CER.

DR1184 – New Cooling off for CoS (Placeholder) Refer to slides for details.


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The customers’ right to the cooling off period is detailed in an EU Directive which was transposed into Irish legislations.

This DR was first brought to the Forum in November 2016

The latest version was circulated before the last Conference call.

Suppliers have submitted a number of comments and queries on this DR which were addressed.

This DR is being reviewed by CER and is currently on hold. . S mac an Bhaird reported that the CER is currently reviewing this DR. With regard to the examples in the DR the CER would like to ensure that MPs are not bound by them being all inclusive. The CER would not like to see the DR being the reference point as to what the Cooling Off Objections actually are. The CER is currently reviewing the wording around this. DR 1184 was not approved at this Forum. DR1181 – Technical Contact Details Refer to slides for details.

Accurate Technical Contact address and Technical Contact details are required and would assist ESBN in completing supplier requests and obtaining accurate meter readings.

Customers such as large Banks or Telecom Companies with many distributed sites should provide accurate Technical Contact Details.

A Supplier can send Technical details for a Customer using existing Market Messages. This would be beneficial to all Market Participants especially where there are issues around LTNA.

S Melvin reported that with regard to the discussions already made in this Forum on de-energisations if Supplies start sending through these Technical Contact Details will they be used for any other purpose such as Meter Reading and Disconnections? A Greaves replied that you can provide Technical contact details for all Customers but that they are different to Meter Reading notes. M Hunt reported that this detail is covered in the SLA Agreement whereby the Supplier has to provide contact details to ESBN. S Donnelly reported that the first sentence of the ESBN SLA doesn’t make sense to him in that the Suppliers are somehow responsible for getting access to de-energise meters. He requested that the CER reviews the wording of this sentence in the SLA Agreement as it doesn’t make sense. S mac an Bhaird reported that he will raise this matter with the CER Networks Team who are the Gatekeepers of this document. Philip Newsom is the contact in CER and it would be better if representations were made directly to him. He shall discuss this matter P Newson and revert via RMDS. A New Action was logged. Action 1051: ESBN SLA Agreement - CER to liaise with its internal Networks Team with regard to the wording of the paragraph pertaining to Access Arrangements in the ESBN SLA Agreement as briefed by ESBN in Action 1039 in relation to de-energisations. CER to revert via RMDS. MPs agreed to review this DR in more detail before approving it. DR 1181 was not approved at this Forum. MCR1182 (Re-versioned) – Impact of I-SEM in the Retail Market in ROI Refer to slide for details.


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D Walshe reported that this MCR has been re-versioned and now includes changes the following changes.

The 23rd May 2018 is confirmed as the revised Go-Live date for the I-SEM; the I-SEM Project Change Request JCR170 has been approved.

This revision includes an additional 3 existing MPDs which will need to have the Price-Effecting text removed.

MCR 1182 was approved at this Forum. DR1187 – Solution to Introduce Eircodes using A2 Correspondence Address Refer to slide for details. A Greaves outlined the details of this DR. This DR is to facilitate a Supplier who wishes to use the A2 Correspondence Address for Eircodes. Suppliers can provide the Eircodes in the A2 Correspondence Address for all inbound Market Messages. The A2 Correspondence Address is different from the Meter Point Site Address. No Eircodes should be submitted in the A1 (Meter point Site Address) or A3 (Technical Contact Market Message) in advance of the three other Eircode MCRs being delivered. All the relevant Market Messages should be a string field that would contain 7 uppercase alpha numeric characters. The Eircode when printed for posting should appear at the end of an address and the routing key should be displayed separately. All the letters in Eircodes will be in an uppercase format. There are also the couple of important things to note: The correspondence Address is not validated like the Meter Point Address and won’t be. ESBN cannot take a mass of updates from Suppliers as this would trigger off a whole series of things within the Market Systems that would have the potential of sending the Central Market Systems into a loop and potentially bringing the systems down. There is an existing Market System process defect surrounding the A2 Address where there could be a cancellation of a CoS with an A2 address in it. The proposal is to fix this defect in advance the MCR. S Melvin asked why the PO Address field should never be populated with an Eircode. A Greaves reported that this rule is coming straight from the Eircode Project. S mac an Bhaird asked what type of scale would need to happen for a tipping over of the system to occur, tens/hundreds or thousands. A Greaves replied that she revert on this matter. S Doolin reported that there might be additional validation for some of the Suppliers systems as well which could be disputed when Suppliers start using this, and this could vary between Suppliers. This DR will need detailed assessment by Suppliers internally to interpret what it means when this lands in their systems. A Greaves reported that this DR is purely to allow Eircodes to be used in the system before the other three Eircodes MCRs are delivered. Suppliers agreed to review this DR internally within their respective organisations. DR 1187 was not approved at this Forum. It was agreed that approval will be sought at the next Conference Call in April.


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2016 RMDS Customer Satisfaction Survey Refer to Slide for full details. D Walshe reported that this survey shall be issued on or before 31st March 2017 with a return date of four weeks later.

9. Notice Board: Planned Maintenance, Reminders from IGG etc.

Outage Dates: There is 1 planned Outage for March 2017.

There is a planned Site Switch Click Outage in RoI on Sunday 12th March 2017 between 08:30 to 16:30 when the RMP Extranet will be unavailable. Orders logged with appointments will queue in Workflow and will be dealt with immediately once Click is back online.

As agreed at the IGG Conference Call this outage will take place on the second Sunday of the month rather that the 3rd Sunday as the weekend of the 3rd Sunday of the month is a Bank Holiday weekend (St. Patricks Day Friday 17th March.

Full Outage Details are available, as usual, on the RMDS Website.

10. AOB

3 Items were raised in AOB Issues with erroneous de-energisation of sites for Non-Payment. K Sheridan raised this item. K Sheridan reported that this issue has come to the attention of Energia’s Debt Team around a de-energisation of a site which actually hasn’t happened. There are two different instances where this has occurred. 1st example: Energia requested a de-energisation. The NT goes to the site to disconnect. The Customer then rings Energia and pays. Subsequently, an NT contacts Energia saying that he is going to complete this disconnection even though it’s been paid. A number of months later Energia receives a 306 Market Message saying that the site has been de-energised. It hasn’t been de-energised and there is a significant amount of consumption in the meantime. 2nd example: Energia didn’t request a de-energisation but received a 306 Market Message on the System. The Customer stops getting bills from Energia. Energia instructed the Customer to talk to ESBN to see what the problem is. This issue exposes Energia to significant debt in some circumstances whereby Customers

https://rmdservice.com/2017-outages/


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are very likely already not paying. If the matter goes on for a year or two the chances of Energia recovering that debt is very slim to none. Also, from the Customer’s point of view, even if this lasts for a couple of months it’s a huge amount of money for them to be billed for. Energia is out of pocket on this matter through no fault of its own. K Sheridan stated that he would like to know how extensive an issue this is and what work has been done to identify the cause of the issue. J Bracken reported that ESBN has already engaged with Energia on this matter and received a note from Energia on 24rd February 2017. He has since received an update from S Gray. It appears that human error caused this problem. However, he is unsure as to the scale of this issue. S Melvin added that SSE Airtricity has also raised this issue in the past and it has been always been the sites where SSE Airtricity has requested a de-energisation for non-payment. S mac an Bhaird asked since SSE Airtricity have been living with this matter for a period of time, have they amended their systems? S Melvin replied that there’s not a lot SSE Airtricity can do in such cases The site has been de-energised and the final bill has issued. J Bracken agreed to open a new Action to investigate how this matter is occurring and the scale of the issue. A new Action was logged: Action 1052: Issues with erroneous de-energisation of sites for Non-Payment. ESBN to investigate how this is occurring and the scale of this issue as raised by Energia and SSE. De-energisation Process whereby Customers are unable to contact their Suppliers directly. S Melvin raised this item. S Melvin suggested that a De-energisation workshop should be scheduled as de-energisation is a huge issue. SSE Airtricity has raised this particular issue on previous occasions. When NTs go out to perform de-energisations they give the customer an opportunity to contact their Supplier to make an arrangement to pay their Bills. The NTs in the GAS Market give over their phones to the Customer and the call is completed there and then but the ESBN NTs don’t give over their phones over to Customers. S mac an Bhaird stated that this matter has been covered before. S Melvin reported that SSE Airtricity believes this is still an issue and can’t understand why in the Electricity Market the customer is directed to phone the Supplier themselves, join a queue, talk to credit control etc. This really frustrates the situation even more and the Customer has to explain what’s going on and it takes longer to resolve. M Hunt replied that ESBN has already completed a pilot project on this and has made presentations on a number of occasions. ESBN wrote to CER on the findings of the pilot project in 2015. In the pilot ESBN found that in no instance was anybody de-energised because they could not contact their Supplier or that the call couldn’t be made. R Gilmartin in SSE Airtricity then raised this issue again. ESBN subsequently asked for examples but SSE Airtricity did not furnish any examples. S Melvin reported that she will send examples of this issue to ESBN. S mac an Bhaird reported that he will find any submissions made previously by ESBN to CER on this matter. He will review the pilot findings and will make a decision on whether this matter will be re-opened or not.


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A new Action was logged: New Action: 1053: De-energisation Process whereby Customers are unable to contact their Suppliers directly. SSE Airtricity to submit examples of this issue. CER to review the previous Pilot findings completed by ESBN in 2015 into this issue & determine if it needs to be reopened. Disconnection Issue S Donnelly raised an issue with regard to “No access” for unsuccessful disconnections. As agreed at the Forum this query would be included in the earlier ESBN “Access to carry out De-energisations” discussion that followed the presentation. See Section 5 ESBN Update “Access to carry out De-energisations” for details. Next Conference call:

5th April 2017. Next IGG:

3rd May 2017 in Dublin.

Documents

Industry Governance Group IGG Meeting Minutes · Industry Governance Group IGG Meeting Minutes ... Industry Governance Group IGG Meeting Minutes ... 948/1004 ESBN to analyse the process