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Treatment of Annual Quantities for Vacant or Mothballed Sites

This proposal aims to clarify the treatment of annual quantities (AQs) for vacant or mothballed sites, introducing mechanisms for accurate bottom stop system off-take quantities (BSSOQs) and avoiding potential increases in unallocated energy costs. The proposal also suggests the ability for shippers to reduce BSSOQs outside the existing window and charges that discourage profiling AQs during the year.

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Treatment of Annual Quantities for Vacant or Mothballed Sites

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  1. THE TREATMENT OF ANNUAL QUANTITIES, SYSTEM OFFTAKE QUANTITIES AND BOTTOM STOP SYSTEM OFFTAKE QUANTITIES FOR VACANT OR MOTHBALLED SITES OR SITES THAT HAVE DECREASED CONSUMPTION BY MORE THAN 20% OR 146,400kWh STEFAN LEEDHAM 26 February 2009

  2. ISSUES • UNC requirement for accurate AQs • TPD G1.6.6: “a reasonable assumption as to the quantity offtaken” • TPD G1.6.13 (d): “the Transporter will consider the details provided by the Registered User … and where it is satisfied that the Annual Quantity or such variable.. fails to satisfy the requirement in paragraph 1.6.6 and that estimate of the Annual Quantity provided by the Registered User satisfies the requirement in paragraph 1.6.6, then the Transporter shall substitute the Annual Quantity with that estimate of the Annual Quantity…” • Differing interpretations for use of BTU Form under G1.6.13 • 96.5% of transportation charges derived from SOQ or BSSOQ • The economic climate is changing: • 2004/05 9% of commercial and industrial properties were vacant • Industry is reducing production or mothballing premises

  3. OBJECTIVES • Clarify section G 1.6.13 • Introduce mechanism for accurate BSSOQs • Avoid incentive to profile an AQ during the year • Ensure customer charges reflect costs incurred • Avoid potential increases in unallocated energy costs • Reduce likelihood of stranded assets from permanent closure • Pragmatic solution to changing economic climate

  4. THE PROPOSAL • Clarify section G 1.6.13 • Ability to re-set AQ and SOQ for LSP NDM sites to 1 or any multiple thereof • Introduce ability for Shippers to reduce the BSSOQ outside of existing window – provided minimum • Shippers confirm validity of proposed AQ through reasonable endeavours and written confirmation to Shippers • Introduce charges so Shippers are indifferent to profiling AQ during the year • Shippers charged back to date when AQ, SOQ, BSSOQ re-set if increase within 12 months

  5. ISSUES • Mod 640 rules • Should a LSP site dropping to an AQ of 1 & increasing within 12 months be exposed to 640 rules as well? • DM requirements • What happens when a DM site drops down to 1? • Should they be allowed to drop to 73,201kWh and be DM Voluntary? • Interruptible sites • Are there any issues with interruptible sites? • Any other issues?

  6. WAY FORWARD • Distribution Workstream - 26 February • Further development - 27 February – 11 March • Mod Panel - 19 March • DMR Issued for consultation - 20 March • Consultation end - 14 April • FMR produced - 15-16 April • Mod Panel - 16 or 21 April • Ofgem decision - May

  7. THANK YOU

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