Presentation to Ofgem’slicenceexempt networks forum Franck Latrémolière Friday 16 May 2014
Why this presentation • My focus is on third-party access on industrial networks that are Supplier-metered at the boundary • Different problems from non-Supplier metered networks • Some issues: • Is there any role for DNOs in private Supplier-metered networks beyond the boundary meter? • Why did DCP 158 and DCP 158A fail? What are the alternatives? • Using difference metering for supply competition: where can it work? Is it appropriate? Is it enough? • Is DCUSA governance delivering what we need? • How can this forum help?
Ofgem’s reasons for rejecting DCP 158/158A • Ofgem’s criticisms of DCP 158/158A (extracts): • “increase the scope for error and the administrative burden” • “increase in the number of data sets and forms to be exchanged” • “concerned about introducing new obligations” • “the proposal will affect … caravan sites and housing associations” • “We support the intention of DCP158 and DCP158A but … the main parties affected [must be] involved …” • No consultation, no visibility, no facts, no comment on the British Gas proposal or its limitations, no apparent awareness of 2012 ENA report, nothing on the impact of possible delays caused by rejection
British Gas counter-proposal for DUoS billing • Proposal raised in British Gas response to a DCUSA consultation; mentioned in two supplier votes • Each supplier pays separately for use of DNO network • But how would the capacity in the connection agreement for the site be allocated between the different MPANs? • Butfor EDCM sites, how could the sneaky charge levied for super-red consumption two years previously be allocated? • The licensed DNO recovers private network use of system charges on behalf of the private network • But on what authority would the DNO levy these charges? • But on what authority would the private network be denied the opportunity to levy its own charges itself if it wishes to do so?
Possible elements of a way forward for this forum • Does this forum have the right focus? • Risk of conflation of issues for non-Supplier metered (legal liabilities) and for Supplier-metered (third party access) • Are we sure that all the other issues that might impair third-party access are being addressed elsewhere? • It would be nice if Ofgem’s decisions were adequately reasoned and based on disclosed and verifiable facts • Not just a one-off problem (see e.g. DCP 139) • DCUSA is not just an industry contract any more; lack of openness is a roadblock to effective governance • DCP “Enhance transparency of DCUSA change management” • Will Ofgem enable consideration of this DCP?