aq appeals and the btu form chris warner. 2 aq appeals and the btu form presentation reflects...
TRANSCRIPT
AQ Appeals and the BTU form
Chris Warner
2
AQ Appeals and the BTU form
Presentation reflects NGD’s view of UNC regime as
drafted and is intended to explain why it was
constructed in that way.
Procedures and approach largely unchanged since
start of Network Code other than enhancement of
Isolation and Withdrawal regime at RGMA.
3
AQ Appeals and the BTU form
Issue driver – Shipper aspiration? to limit
transportation charge exposure for ‘vacant’ sites not
consuming gas albeit with the User retaining ownership
(Supply Point registration).
UNC addresses this scenario in clear methodical
steps – regime developed over several years.
DNO view - Reduction of AQ to a low value (e.g. 0 or 1) as a
means to avoid relevant (all) transportation and energy
charges via the BTU form for vacant sites while SMP is live and
Shipper retains registration is not permissable.
4
AQ Appeals and the BTU form
Annual Quantities (AQs) derived from Meter
Readings which prima facie evidence of actual energy
Consumption.
AQ appeals based on: Alternative Meter Readings reflecting previous 12 months
consumption, or
Where there is a change in the basis on which gas is consumed
then the BTU form may be used:
– User needs to provide evidence (in the form of detailing plant
and consumption rates) as to the genuine AQ value had the
equipment been in place for the duration of the retrospective
review period.
5
AQ Appeals and the BTU form
Vacant properties not within scope of above
provisions (albeit if no gas consumed, after 12 month
period, AQ review process may result in substantial
reduction in AQ).
Remedies in place to provide solution.
Isolation (ceases energy allocation and energy/commodity
charges).
Withdrawal (ceases Registration and Capacity & Customer
charges).
6
AQ Appeals and the BTU form
RGMA. Purpose: to enable I&W while
leaving meter connected (disabled). MaMCoP
identifies acceptable methods.
Mod 0675. Where meter connected: User must disconnect within
12 months otherwise DNO will disable supply and charge.
Where meter disconnected: GSIU 1994 effective.
NC Modification 0675 Ofgem Decision July 2004. “Whilst it appears entirely pragmatic for meters to remain in place, where
gas is no longer required for a short time, Ofgem is keen to ensure that
meters do not remain connected and left in premises inappropriately, or for
a long period of time, simply to avoid the costs of disconnection and
removal. This could have implications for the transportation of gas and
safety more generally”.
7
AQ Appeals and the BTU form
UNC Modification 0172 Ofgem Decision April 2008. “In accepting Modification 0675 we noted that whilst it appeared pragmatic
for meters to remain in place where gas is no longer required for a short
time, we were keen to ensure that meters do not remain connected and
left in premises inappropriately or for a long period of time, simply to avoid
the costs of disconnection and removal”.
Where Supply Meter Point is Live – notional
reservation of capacity for which appropriate liability
should be borne (cost reflectivity). User obligations to procure meter readings/emergency contacts, etc,
remain.
8
AQ Appeals and the BTU form
Summary:
Scope of G1.6.13 does not contemplate (and was
never intended to) a scenario where a premise is
unoccupied
Where a premise is vacant, the BTU form should not
be used to: Reduce an AQ more quickly than would be achieved by submitting
reads in accordance with the UNC ‘AQ review’ provisions
Change the AQ in circumstances where there has been no
change in plant which results in a change in the basis on which
gas has been consumed
9
AQ Appeals and the BTU form
Concerns if reduction in AQ to 1 were permitted for
vacant sites: Commercial and physical regimes not matched.
Capacity charges incurred over a 12 month period. New regime
would result in immediate cessation of charge while physical
capacity remains available.
Potentially not as safe as current situation.
Safeguards not clear– potential for misallocation could increase?
Arguably not pro-competitive (Previous Workstream discussion
that Shippers retaining ownership benefit from e.g.‘right to object’
– so if they require relief from charge liability they should
Withdraw).