aq appeals and the btu form chris warner. 2 aq appeals and the btu form presentation reflects...

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AQ Appeals and the BTU form Chris Warner

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Page 1: 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

AQ Appeals and the BTU form

Chris Warner

Page 2: 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

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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.

Page 3: 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

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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.

Page 4: 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

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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.

Page 5: 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

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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).

Page 6: 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

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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”.

Page 7: 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

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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.

Page 8: 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

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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

Page 9: 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

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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).