We’re less than a month away from the planned Go-Live date for the new switching arrangements and REC v.3.0 governance.
In preparation for this milestone, we have worked closely with industry, the switching programme, Ofgem and our service providers to ensure all our obligations for go-live would be met.
RECCo, has submitted its final readiness assessment to the Delivery Group within the Switching Programme to support the upcoming Go/No-go decision on whether to proceed with the planned Go-Live on 18 July 2022. We confirmed a readiness status of ‘Green’.
This “Green” status reflects delivery of four significant workstreams including contracting with Xoserve for the delivery of the Gas Enquiry Service, Party Under Integration obligations for the Electricity Enquiry Service, REC Version 3 governance development and baselining and the development and testing of REC Code Manager business processes to support new switching arrangements.
RECCo and the REC Code Manager have also been working hard in other areas to ensure that the REC is ready to support the new switching arrangements. This has included:
There are a small number of remaining activities that we will be completing over the next month, however all remaining activities have mitigations in place and are expected to complete ahead of Go-Live.
We would like to take this opportunity to thank all industry parties, service providers and the switching programme for their support and collaboration in reaching this point. We look forward to continuing to work closely to support a smooth transition to REC governance and enduring operation of the new arrangements.
This month, we asked Neil McKeown, Chief Customer Officer at the C&C Group, our Electricity Enquiry Service (EES) Service Provider, to reflect on their switching programme journey and readiness for Go-Live on 18th July 2022...
Over a period of many months, the past few years in fact, we have worked hard in collaboration with a broad range of other stakeholders, most recently in partnership with RECCo to ensure EES meets the new Switching Programme requirements for Go-Live on 18th July 2022.
At a holistic level our activities have included:
We have also managed the EES participation in an intense, 18-month period of industry testing of the new CSS ecosystem and associated processes, delivered by Landmark and other Parties Under Integration. This has included the phases of Integration Testing (PIT/SIT), End User Testing (UEPT & E2E) and Go Live/Transition Testing (DMT).
As we write this, we are currently executing Transition in the final run up to Go-Live.
The team at C&C Group continues to work extremely hard to ensure that we are not only ready for Go-Live but also that we are able to support EES throughout the Early Life Support (ELS) period and beyond into Business as Usual (BAU).
Whilst BAU itself is quite a simple acronym, in practice over a period of many months we have invested significantly in new people, new training, and new processes so that from 18th July (CSS Go-Live) the EES continues to perform and operate in future years as steadily as it has done for energy market stakeholders at any time under our stewardship going back 17 or so years.
If you have any questions on the EES, please contact: enquiries@recmanager.co.uk.
The obligation for RECCo to operate Ofgem’s Market Stabilisation Charge (MSC) was implemented into the REC on 14 April 2022.
Activities have since been focused on developing the governance and processes to support the administration of the MSC with a target operational date of 30th June 2022. Today (29th June) the Project Steering Group were able to confirm our readiness for go-live on 30th June. This is a huge achievement for the team, delivering the project in a 4-month period, working closely with the REC Code Manager, REC Parties and Ofgem under extremely tight timeframes.
As reported in previous newsletters, the project involved undertaking the following 3 core workstreams:
REC Change Proposal R0034 was developed to introduce the vires for RECCo to operate the scheme. The Change Proposal was subsequently approved on the 8th April 2022 and implemented on the 14th April 2022.
REC Change Proposal R0035 has also been developed which sets out how the scheme will operate. The final Change Report was published on 10th June, with the Change Panel voting to recommend to the Authority to approve the change, for implementation on the 30th June. The Authority subsequently approved R0035 on 27th June 2022.
Further details of both REC Change Proposals are available on the REC Portal.
On 28th June 2022 Ofgem issued a consultation on further changes to the MSC, proposing to:
Neither of these proposals is expected to require further change to the solution implemented within the REC, or to the associated RECCo contracts with service providers which included provision for such an extension.
To support the administration of the MSC scheme, RECCo procured a technical solution. Over the past month, activity has focused on the build & test phase of the solution. This week all testing has been successfully completed on time and all issues resolved.
We have held several stakeholder events over past months to ensure the design of the arrangements is fully understood by REC Parties and to seek valuable stakeholder inputs.
The events held on 22nd April and 23rd May were both well attended with positive feedback received and we thank all that attended for their contributions. Where comments were received from REC Parties, including during the consultation period of R0035, these have been addressed either directly within the drafting or as included as part of the Final Change Report.
The REC Code Manager has recently reached out to all Suppliers to request the contact and bank details that should be used for administration of the scheme as well as any non-domestic only MPID’s that should be excluded from the MSC. If you have not yet provided these please contact Laura.Stone@recmanager.co.uk.
RECCo developed a business readiness assessment to ensure RECCo is fully prepared to move from the project phase into operation of the administration of the MSC. The assessment is focussing on the following areas:
An acceptance criteria for each area was assigned which enabled the project team to regularly assess and score each criteria to determine RECCo’s overall readiness for administering the MSC. The Project Steering Group used the business readiness assessment to inform the decision to progress to Go-Live on 30th June.
The first live invoice run is planned to commence on 12th July and will cover the first three 4-weekly invoice periods from 14th April to 5th July. The first two invoice periods elapsed without the MSC being triggered, and so no invoices will be produced.
The third invoice period ends on 5th July and if the MSC has been triggered during this invoice period, invoices will be produced on 26th July with payments falling due from Suppliers on 9th August. RECCo payments to Suppliers will be made by 23rd August, should the MSC be triggered.
Further information on the MSC, including full details of the MSC invoicing schedule (after July 30th), our Plan On A Page and our log of Question & Answers can be found on the RECCo website.
If you have any comments on our MSC project, please contact our project lead Tracy Hardy.
As part of our role in ensuring the ongoing effective and efficient governance of the retail energy market and management of REC Services, we are responsible for ensuring that the MHHS programme requirements which impact the REC and REC Services are appropriately considered and delivered.
The MHHS Programme has been working on updating its plan to reflect recent programme change requests, potential delays to completing the design and preparing for the wider programme re-plan, due after the achievement of M5.
The programme has recently published an Interim Plan on a Page which sets out the planned activities for the remainder of this year.
As part of this work, we have been working with the programme to develop the plan for completing code drafting activity. An updated plan was presented to the Cross Code Advisory Group on 22 June 2022, and feedback from the CCAG will input into the final version of the plan.
Once this is agreed and baselined, we will also update our internal project plan and publish an updated Plan on a Page on our website.
The MHHS Programme has established a new Level 4 Working Group, the Code Drafting Working Group (CDWG), to support the development of code drafting required for MHHS and provide recommendations to the Cross Code Advisory Group (CCAG). This will include the development of the consequential changes to the REC to implement the MHHS Target Operating Model and detailed design.
RECCo will be attending the CDWG to support the code drafting activity. The first meeting is on Thursday 30th June 2022. You can view the Terms of Reference on the MHHS website and if you’re interested in joining the group you can do so by emailing PMO@mhhsprogramme.co.uk.
We are pleased to report that the MHHS Programme Change Request CR008 which was raised to enable RECCo representation at the Programme Steering Group (PSG), Design Advisory Group (DAG) and Testing and Migration Advisory Group (TMAG), was approved 17th June 2022.
This is an important step to enable transparency and support the early engagement and representation of programme impacts on REC Service Provider systems and processes, and the wider end-to-end design in decision making.
If you have any queries or comments, contact the Project Lead in the RECCo Operations and Transformation team, Jonathan Hawkins.
The review of the existing REC metering codes of practice and development of a consolidated set of drafting has been devised into two stages.
Great progress has been made in the development of the proposed drafting with stages 1 and 2 of the review now being completed and made available for industry input.
The review period for stage 1 was completed on 21st June and a number of valuable comments were received from stakeholders which have been easily addressed. Stage 2 completes its review period on 30th June and to date no technical issues, concerns or comments have been received.
A number of parties have already reviewed both stages 1 and 2 of the proposed drafting but there is still an opportunity to feed in your comments on stage 2! If you wish to do so, please email any comments directly through to our project expert Rob Short, where your feedback and comments will be collated and appropriately considered.
We held a Metering CoP Consolidation Introductory webinar session on 7th June 2022 to make sure stakeholders were well informed on the project and knew how they could get involved as part of the review process.
During this session we provided an overview of the project, the delivery timescales and the proposed new structure of the metering arrangements.
If you were unable to attend a recording of the session is available on the RECCo website and our YouTube channel.
REC Change Proposal R0047 has been raised into the REC change process to bring the proposed consolidated drafting into the REC arrangements. The Change Proposal was approved for initial assessment by the Change Panel on 7th June 2022.
The initial impact assessment window for this change will run from 29th July to 19th August 2022 and the final Consultation Period will run from 16th September to 7th October 2022 with the Final Change Report being published on 4th November 2022, following the REC Change Panel decision.
As the Code Consolidation workstream nears completion, the focus of the project team is moving to the procurement of a scheme auditor to assure the consolidated metering arrangements.
The project plan and approach to the procurement has initially been drafted and is being reviewed internally. As part of developing the procurement requirements, the project team will shortly be reaching out to industry stakeholders to obtain feedback on the current assurance scheme arrangements to help shape the approach to be taken.
RECCo will also be holding a market engagement session with potential audit service providers to provide more information on the scheme requirements before issuing of a Request for Proposal over coming months.
If you’d like any further information of the project, please visit our dedicated area on the RECCo website or email our metering expert Rob Short.
Under the Retail Energy Code, we are required to progress an Energy Theft Reduction Strategy.
Some of the elements of this strategy are already in place having been migrated from legacy code arrangements and are subject to ongoing development:
The deadline for submission of reports of confirmed thefts to qualify for the 2021/22 gas and electricity theft detection incentive schemes year has now passed.
The REC Code Manager is in the process of collating the data and we will shortly communicate the forward timetable for payment of invoices into, and subsequently payment of credits from the schemes.
Operating in much the same way as the Market Stabilisation Charge (MSC), we will seek to promptly redistribute monies received, and seek to escalate any late payments in order to ensure their timely settlement.
Early indications are that the overall targets for the schemes have not been met. We will be engaging with scheme participants to better understand whether this is due to the continuing effects of Covid-19 during 2021/22 or other factors which could suitably form part of the Code Managers assessment for future targets.
More generally, we are considering ways in which the efficacy of the schemes can be improved for the 2023/24 reporting year. As any material changes to the schemes may be dependent upon the timely progress of a REC Change Proposal, we will be aiming to formulate ideas for improvement this summer, with a view to raising a REC Change Proposal in the Autumn, which may be implemented ahead of the scheduled start of the 2023/24 scheme year on 1st April.
We will issue invitations to a workshop on the development of the incentives schemes shortly, but in the meantime if you have any thoughts or suggestion on the current or future operation of the schemes, please contact us via: theft@retailenergycode.co.uk and we would be happy to discuss them.
The decarbonisation of energy poses a potentially existential threat to the current GB gas industry.
Efforts are therefore gathering pace to find means of repurposing the GB gas infrastructure to deliver hydrogen rather than natural gas (methane).
While government and Ofgem focus may be on the ‘hydrogen villages’ set to trial by 2025, smaller scale but no less significant projects which do not require such governmental support are proceeding at a faster pace.
One such project is ‘H100’, which will be operated by SGN and supported by funding from both the Scottish government and an Ofgem innovation allowance to design the world's first 100% hydrogen gas distribution network, which aims to demonstrate the safe, secure and reliable distribution of hydrogen.
The project will conduct research into the characteristics of hydrogen to provide a full understanding of the impact of its distribution in relative terms to natural gas. This will then enable the development of a safety case and compliance framework that will ensure the reliable and safe operation of a demonstration network.
Rather than operate under wholly separate governance, the arrangements for the project are to be codified within the Uniform Network Code through modification UNC799. UNC799 is nearing the conclusion of the UNC process and will shortly be submitted to Ofgem for a decision. Upon its first consideration of the Final Modification Report in June, the UNC Panel considered that there were sufficient new issues that it should be referred back to a workgroup.
In particular, it was considered that the impacts upon suppliers had not been sufficiently considered. The subsequent workgroup held 27 June 2022 was well attended, with over 30 attendees, including a cross code presence with representatives of the Smart Energy Code and IGT UNC as well as the Retail Energy Code.
So far, the operational impacts upon suppliers are expected to be limited, with the aim of the trial being to replicate normal operational arrangements as closely as possible. This will be facilitated by SGN acting as the Metering Equipment Manager (MEM) to all of the supply points participating in the scheme, ensuring that household appliances are swapped out for hydrogen compatible devices, including the provision of hydrogen-ready SMETS2 meters.
All of the hydrogen for the trial will be procured through a single shipper, who will in turn source it exclusively from a single hydrogen producer. However, consumers will be charged the equivalent of their chosen supplier’s default tariff, with the caloric value of the gas being adjusted for billing purposes and ensuring that the consumer will not face any additional costs associated with using hydrogen.
We consider that the impact of the trial upon REC arrangements may be limited, but recognise the importance of this and other such trials if the gas industry is to decarbonise and meet its net-zero ambitions. We will therefore seek to ensure that we proactively identify and progress any changes that may be required to facilitate the trial.
For instance, as discussed at the Metering Expert Panel, the installation of a hydrogen metering does not currently fall within the scope of the Metering Code of Practice. It may therefore be necessary to progress a derogation against the usual metering accreditation requirements for any supplier (and their MEM) participating in the trial.
We also understand that there may be impacts upon suppliers systems resulting from the trial, which the 27th June Workgroup considered needed to be further assessed. The impacts on REC governed systems may be limited to the addition of the additional meter types and a project specific network identification into the Market Domain Data available via the Gas Enquiry Services.
For further details on the H100 project see H100 Fife and UNC799.