shipperless & unregistered workgroup friday 15 th march 2013

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Shipperless & Unregistered Workgroup Friday 15 th March 2013

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Shipperless & Unregistered Workgroup

Friday 15th March 2013

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.

Previous actionsRef. Description Action Status

136All to investigate the impact of the proposed MPRN Creation Process change on their organisations’ systems and processes and feedback any issues for the next Workgroup meeting.

All C/Fwd

137All Networks to investigate examples of MPRNs set to DE in error.Update 5th December – Networks had nothing to report on this matter.

All Networks C/Fwd

127

All Distribution Network representatives to discuss possible future Xoserve end user letter exercises.Update 19th September – DNs are in agreement that the resurrection of the EU Letter Process would be worth while. However, a firm detailed decision has not yet been made.All DNs to engage with Xoserve to finalise decision.Update 5th December – Networks stated that they would favour further desktop investigations. However, they would engage with Xoserve to discuss the possibilities of reintroducing the End User Letter process.

All DNs C/Fwd

138Xoserve agreed to republish the slides which described when a new MPRN would need to be created.

Xoserve Open

139 Xoserve to investigate if UIPs can have access to Data Enquiry. Xoserve Open

140Xoserve agreed to conduct analysis on a sample of 25 MPRN Creations to determine if any were created as a result of an MPRN being erroneously set to DE.

Xoserve Open

141Xoserve to consider different ways of presenting the Industry Statistics to demonstrate the levels of priority of the various pots.

Xoserve Open

142DNs to consider what actions they could complete to meet the requirements following the Desktop Data Cleansing Exercise conducted by Xoserve.

All DNs Open

Statistical Information

Overall Industry Volumes

Unregistered Sites Jan-12 Mar-12 May-12 Jul-12 Sep-12 Nov-12 Jan-13

Shipper Activity 376 398 360 279 302 292 279

Orphaned

TOTAL 14,845 15,023 15,138 15,263 15,445 15,767 16,077

With Meter 6331 (42.6%) 6443 (42.9%) 6442 (42.6%) 6504 (42.6%) 6591 (42.7%) 6735 (42.7%) 6855 (42.6%)

Shipperless Sites - Shipper (PTS)

GSR 1,317 1,346 1,110 1,062 1,023 975 1,013

GSS 903 1,015 1,003 919 845 113 205

Shipperless Sites - Industry (SSP) 4,657 4,781 4,957 4,985 4,977 4,781 4,898

No Activity 1,408 1,199 1,291 1,290 1,387 1,433 1,587

Legitimately Unregistered

32,653 33,329 33,758 34,307 34,903 35,224 36,924

Meter Point created less than 12 months

27,728 28,555 28,084 28,975 29,659 29,848 28,816

TOTAL 82,984 84,631 84,698 86,161 87,696 88,320 89,564

Overall Industry Volumes Excluding Legitimately Unregistered

Unregistered Sites Jan-12 Mar-12 May-12 Jul-12 Sep-12 Nov-12 Jan-13

Shipper Activity 376 398 360 279 302 292 279

Orphaned

TOTAL 14,845 15,023 15,138 15,263 15,445 15,767 16,077

With Meter 6331 (42.6%) 6443 (42.9%) 6442 (42.6%) 6504 (42.6%) 6591 (42.7%) 6735 (42.7%) 6855 (42.6%)

Shipperless Sites - Shipper (PTS)

GSR 1,317 1,346 1,110 1,062 1,023 975 1,013

GSS 903 1,015 1,003 919 845 113 205

Shipperless Sites - Industry (SSP) 4,657 4,781 4,957 4,985 4,977 4,781 4,898

No Activity 1,408 1,199 1,291 1,290 1,387 1,433 1,587

Legitimately Unregistered

32,653 33,329 33,758 34,307 34,903 35,224 36,924

Meter Points created less than 12 months

27,728 28,555 28,084 28,975 29,659 29,848 28,816

TOTAL 50,331 51,302 50,940 51,854 52,793 53,096 52,640

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

Unregistered Sites Jan-12 Mar-12 May-12 Jul-12 Sep-12 Nov-12 Jan-13

Shipper Activity 376 398 360 279 302 292 279

Orphaned

TOTAL 14,845 15,023 15,138 15,263 15,445 15,767 16,077

With Meter 6331 (42.6%) 6443 (42.9%) 6442 (42.6%) 6504 (42.6%) 6591 (42.7%) 6735 (42.7%) 6855 (42.6%)

Shipperless Sites - Shipper (PTS)

GSR 1,317 1,346 1,110 1,062 1,023 975 1,013

GSS 903 1,015 1,003 919 845 113 205

Shipperless Sites - Industry (SSP) 4,657 4,781 4,957 4,985 4,977 4,781 4,898

No Activity 1,408 1,199 1,291 1,290 1,387 1,433 1,587

Legitimately Unregistered

32,653 33,329 33,758 34,307 34,903 35,224 36,924

Meter Points created less than 12 months

27,728 28,555 28,084 28,975 29,659 29,848 28,816

TOTAL 22,603 22,747 22,856 22,879 23,134 23,248 23,824

S&U Population ‘Pot’ Priorities

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

Pot Descriptions and TrendsUnregistered Sites

Current Volume

12-month Trend

Difference Description

Shipper Activity 279 Down 68.54%

Reports are issued to the specific shippers containing MPRNs for which an activity has been identified. E.g. Confirmation rejection, Meter asset update to the C&D store, Conquest raised to create the M Number, End User. These reports only include MPRNs > 12 months from creation date.

Orphaned

With Meter 16,077 Up 3.13%

This report is sent out to the whole industry. Records include MPRNs either following a shipper's response to the shipper activity report, that they have no further interest in the M Number, or where no response is received before the production of the next Bi monthly report. They include sites where a service has been completed and in some instances a meter already installed. This report only includes MPRNs > 12 months from creation date.

TOTAL6855

(42.6%)Up 5.14%

Shipperless Sites - Shipper (PTS)

GSR

1,013 Down 27.94% These contain sites which have previously been confirmed with meter removed. Information provided by the Networks suggests either the existing meter still on site or a new meter has been fitted.

Shipperless Sites - Industry (SSP) 205 Down 2.93%

No Activity   4,898 Up 2.51%These contain meter points created on UK Link where no shipper activity has been recorded and that remain unconfirmed.

Legitimately Unregistered

  1,587 Up 9.86%These contain sites which can represent one of the following reasons: Vacant sites; No Gas meter but live service; Service still in planning stage

Meter Point created less than 12 months

  36,924 Up 12.37%These figures provide details of meter points that have not reached the first anniversary of their creation date and remain unconfirmed.

TOTAL   28,816 Up 8.64%

  Not included in Total Figures

Primary Pot Priorities

Unregistered Sites Initial Priority Justification

Shipper Activity 1Records within this pot have been associated with a particular shipper. It is important that the shippers thoroughly investigate records issued to them as soon as possible while the inforamtion is "fresh" to ensure that they do not fall into the Orphaned Pot unnecessarily.

Orphaned

With Meter 3This section of the S&U population should be treated with priority as intelligence suggests that the site is capable of using gas, and a meter has been reported to be in situ.

TOTAL 5The remainder of the Orphaned Pot should be addressed as a second priority. However, it is recommended that this pot should be broken down further to form sub-pots defined by the record's original pot.

Shipperless Sites - Shipper (PTS)

GSR

2

Records within this pot remain on the specific shippers' reports until they have confirmed the MPRN. They should be investigated as a high priority as the networks have identified that the site is capable of consuming gas, and that the meter on site is the one that the previous shipper has purported to have removed.

Shipperless Sites - Industry (SSP)

4Records within this pot should be investigated as a high priority as the networks have identified that the site is capable of consuming gas.

No Activity   6MPRNs in this pot have had no activity since their creation. Therfore it is not certain that gas is being consumed on these sites.

Legitimately Unregistered

  8

Recent analysis of the Legitimately Unregistered Population increased confidence that the MPRNs in this pot were correctly categorised.

Meter Point created less than 12 months

  7Previous analysis has shown that <80% of MPRNs are confirmed within 12 months of creation through normal means.

Secondary Pot PrioritiesUnregistered Sites

Overall Priority

Justification

Shipper Activity N/ARecords within this pot are automatically included in the Orphaned pot in the next reporting run if they are not confirmed or set to EX or DE.

Orphaned

With Meter iThis section of the S&U population should be treated with the highest priority as intelligence suggests that the site is capable of using gas, and a meter has been reported to be in situ.

TOTAL iiThe remainder of the Orphaned Pot should be addressed as a second priority. However, it is recommended that this pot should be broken down further to form sub-pots defined by the record's original pot.

Shipperless Sites - Shipper (PTS)

GSR

iii Records within this pot remain on the specific shippers' reports until they have confirmed the MPRN.

Shipperless Sites - Industry (SSP)

iv Records within this pot remain on the reports until they have been confirmed.

No Activity   N/ARecords within this pot are automatically included in the Orphaned pot in the next reporting run if they are not confirmed or set to EX or DE.

Legitimately Unregistered

  v

Recent analysis of the Legitimately Unregistered Population increased confidence that the MPRNs in this pot were correctly categorised.

Meter Point created less than 12 months

  viPrevious analysis has shown that <80% of MPRNs are confirmed within 12 months of creation through normal means.

13

EnergyNetworksAssociationShipperless & Unregistered sites

Chris Warner15th March 2013

14

Shipperless & unregistered sites

14

Energy Networks Association

• 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

15

Shipperless & Unregistered sites

15

Energy Networks Association

• 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

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

Energy Networks Association

17

Shipperless & Unregistered Sites

17

Energy Networks Association

• 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?

18

Shipperless & Unregistered Sites

18

Energy Networks Association

• 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.

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.

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

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

MPRN creation Workgroup

EnergyNetworksAssociationRoot cause solution for unregistered sites / MPRN creationDavid Mitchell15th March 2013

MPRN Creation - Background

24

Energy Networks Association

•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

MPRN Creation – Consultation Responses

25

Energy Networks Association

•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

MPRN Creation – Consultation Responses Concerns Raised

26

Energy Networks Association

•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.

MPRN Creation – Consultation Responses Suggestion Raised

27

Energy Networks Association

•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

MPRN Creation – Next Steps

28

Energy Networks Association

•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.

Unregistered Site – Root Cause Solution Measures

29

Energy Networks Association

1. Smaller, controlled batches of MPRNs for connection providers – More ownership of MPRN creation, reducing duplicates

2. 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

3. Further controls over Code12 MPRN creation – Avoiding duplicate MPRNs being raised

Unregistered Site – Root Cause Solution Measures

30

Energy Networks Association

4. MAMCoP obligation to only install meters where a supply contract is in place – Stopping gas being taken without a supply contract being in place

5. 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

6. 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

7. MOD410A (if implemented) used as a backstop alongside further monitoring of connection jobs and meter fits by DNs

Unregistered Site – Next Steps

31

Energy Networks Association

•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

AOB

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