Shipperless & Unregistered Workgroup

1. Shipperless & Unregistered Workgroup Friday 15th March 2013

2. Agenda • Introduction • Previous actions • Statistical Information • Overall industry volumes • S&U Population ‘Pot’ Priorities • S&U Sites – DN Update • Desktop Investigation / End User Letter Trial Proposal • MPRN Creation Workgroup • MPRN Creation Process change ~ Update • A.O.B.

3. Previous actions

4. Statistical Information

5. Overall Industry Volumes

6. Overall Industry Volumes Excluding Legitimately Unregistered

7. Overall Industry Volumes Excluding Legitimately Unregistered and MPs Created < 12 Months

8. S&U Population ‘Pot’ Priorities

9. S&U Pot Priorities • Xoserve has assigned priority ratings to each of the S&U pots • Two priorities ratings have been assigned • Primary priority; applied to the fresh datasets that are issued on a bi-monthly basis. • Secondary priority; applied on an ongoing basis, for continuous work to reduce the overall population • The ratings were mainly based on the apparent ability to consume gas

10. Pot Descriptions and Trends

11. Primary Pot Priorities

12. Secondary Pot Priorities

13. Energy Networks Association Shipperless & Unregistered sites Chris Warner 15th March 2013 13

14. Shipperless & unregistered sites • Transporters are currently developing and revising policies, procedures and processes to ensure efficient and effective investigation of theft of gas incidents (which includes reported Shipperless & Unregistered (S&U) sites) • Consistent with GT Licence, UNC and SPAA ToG CoP (note: revision to CoP required to address practical issues) • Expected to be complete and implemented by Oct 2013 • Scope includes reacting to reports of suspected incidents of ToG (including ‘upstream’ tampering incidents and ‘downstream’ where no Supplier is found to be present) • May result in certain sites in the S&U Portfolio being reported 14 14 Energy Networks Association

15. Shipperless & Unregistered sites • In order to better understand the make up of the S&U portfolio we suggest a number of activities as follows: • Initiate Shipper/Supplier portfolio reconciliation exercise (under UNC Modification Proposal 0431) • Undertake analysis to better understand the requirements and extent of a data reconciliation exercise to be conducted in the Transporter businesses and Xoserve • Undertake a limited & targeted ‘one off’ consumer lettering exercise • The output will be used to inform Ofgem’s consultation in Q1 2013 on the regulatory framework surrounding GT Licence Condition 7 Transporters propose to take the following measures in respect of the S&U portfolio 15 15 Energy Networks Association

16. Shipperless & Unregistered Sites • The ‘one off’ extended consumer lettering exercise has issues associated with it which will look to address • Risk in undertaking activities in absence of validated and efficient ‘end to end’ processes • May be reduced by setting scope of consequential action • Risk of consumer dissatisfaction through random targeting • Reduced by content of letter • Consequential actions limited to analysis of returns 16 Energy Networks Association

17. Shipperless & Unregistered Sites • Exercise targeted on 1000 sites across all networks and including a range of AQs • Focus primarily on Orphaned sites with meter • Undertaken by Xoserve over 3 month period • However, we need to identify what we are collectively trying to achieve in terms of output and learning • Registration? • Non-responses? • Need to identify Shipper/Supplier role? • Need to understand what is failing and look at a cost targeting mechanism? 17 17 Energy Networks Association

18. Shipperless & Unregistered Sites • The outcome of this exercise can inform the basis of further industry work and the additional funding required by Transporters and Shippers to address this issue. • Ofgem is due to consult on possible modification of GT Licence Condition 7 Q1 2013 • In the absence of a comprehensive plan, defined roles and adequate funding which is informed by the Ofgem’s consultation in Q1 2013, Transporters are not in a position to pursue beyond this trial. 18 18 Energy Networks Association

19. Desktop Investigation / End User Letter Trial Proposal A joint request from all DNs has recently been made for Xoserve to produce a proposal for an exercise to investigate a sample of 1000 MPRNs from the Orphaned Pot of the Shipperless and Unregistered Sites population.

20. Desktop Investigation / End User Letter Trial Proposal Scope Investigation of 1000 MPRNs (with meters) from the Orphaned population, using Xoserve systems and other available information sources. Objectives To promote the confirmation of MPRNs as necessary To ensure that MPRNs are set to EX or DE as necessary

21. Investigation Methods Xoserve Systems UK-Link Data Enquiry Conquest / CMS Address Databases GB Address Manager / Post Office Website Internet Search Engines Google / Bing etc. Google Maps / Earth / Street View Local Authority Websites Local Authority Council Tax Web Pages Local Authority Planning Application Web Pages External Communications Shippers Networks End Users

22. MPRN creation Workgroup

23. Energy Networks Association Root cause solution for unregistered sites / MPRN creation David Mitchell 15th March 2013

24. MPRN Creation - Background • GDNs proposed the MPRN Creation solution – MPRNs are created by shippers and a supply contract is required before the service is laid. • This went out for industry consultation in December 2012 and closed 4th January 2013 • A total of 7 responses were received from a variety of industry participants including GDNs, IGTs, UIPs, MAMs and Shippers 24 Energy Networks Association

25. MPRN Creation – Consultation Responses • There was general support from Shippers with some minor suggested amendments • The UIPs and MAM businesses that responded were very opposed to the proposal as they feel that it would be anti competitive and would complicate the process for end users. Two UIPs have indicated that they would commence legal proceeding should the proposal be implemented. • The IGT respondent was supportive as long as this process is not applied to IGTs but stated that they did not believe this would resolve all unregistered sites and questioned whether this would work for I&C connections and multi-meter point developments 25 Energy Networks Association

26. MPRN Creation – Consultation Responses Concerns Raised • I&C Connections – as a large majority of these connections are speculative i.e. the connection is needed but may not be used for some time. The UIPs especially felt very strongly that this new process would limit their workload as developers would not wish to get a supply contract • Multi meter point developments – As these sites can span over several years ensuring that supply contracts are in place could severely delay the progress for these sites (including fuel poor connections) • Anti competitive – UIPs and MAMs raised concerns that only allowing shippers to create MPRNs will be anti competitive as customers will have to go through a shipper for their MPRN and so the shipper would have an advantage over other connection providers and meter installers. 26 Energy Networks Association

27. MPRN Creation – Consultation Responses Suggestion Raised • Most of the responses stated that the main issue with unregistered sites is not in fact the service in the ground but the meter being fitted as this allows gas to be offtaken • Respondents (including MAMs) suggested placing obligations on MAMs to not fit meters without supply contracts which would then stop unregistered gas being offtaken • It was also suggested through discussions with UIPs that I&C connections are locked to only allow the connection provider to remove the lock once a contract is in place and a meter is being fitted 27 Energy Networks Association

28. MPRN Creation – Next Steps • GDNs are fully committed to implementing root cause solutions for unregistered sites. We have to take the concerns and suggestions raised in the consultation responses seriously and so have re-thought the root cause solution previously proposed • We note that although the previously suggested approach would go some way to reduce the number of unregistered sites it was not a perfect solution as customers could cancel the supply contract or change supplier and would also potentially mean increased waiting times for customer in getting a new connection. • We have therefore come up with the following package of measures which will have the smallest impact on customers whilst minimising any new unregistered sites being created. 28 Energy Networks Association

29. Unregistered Site – Root Cause Solution Measures Smaller, controlled batches of MPRNs for connection providers – More ownership of MPRN creation, reducing duplicates Looking into the benefits of delaying MPRN creation from Quote Acceptance to Job Scheduling Stage – This will lead to less MPRNs being cancelled due to jobs not going ahead Further controls over Code12 MPRN creation – Avoiding duplicate MPRNs being raised 29 Energy Networks Association

30. Unregistered Site – Root Cause Solution Measures • MAMCoP obligation to only install meters where a supply contract is in place – Stopping gas being taken without a supply contract being in place • Further MAMCoP obligation and change to RGMA to obligate MAMs to copy meter installation flows to the C&D Store and to include details of the initiating supplier on the flow – Allowing Xoserve to more actively monitor for meters being fitted • Joint GDN customer connections communications leaflet – Encourage customers to get a supply contract from planned stage in connection process and informing of need for a supply contract before meter fit • MOD410A (if implemented) used as a backstop alongside further monitoring of connection jobs and meter fits by DNs 30 Energy Networks Association

31. Unregistered Site – Next Steps • The smaller actions e.g. batches will be implemented as soon as possible and we will keep industry up to date on progress • We are progressing with the first MAMCoP change. This was raised at the MAMCoP meeting on the 28th February and the official change should be submitted to SPAA by the end of March. The second MAMCoP change is currently being developed and will be progressed during Q2 2013. • The customer communications leaflet is with the GDN Communication Manager to progress through ENA • GDNs will be drafting an ancillary document to the UNC and raising a code modification to refer to this in the UNC. The document will outline the MPRN creation process with the amendments outlined in previous slides 31 Energy Networks Association

32. AOB • Any other business? • Thanks for your attendance… • … your contribution & support • Have a safe journey home!