Search Subscribe ABOUT ELEXON WHAT WE MANAGE VISION NEWS & INSIGHTS WORKING AT ELEXON CONTACT Home > About Elexon > Consultations: Elexon’s responses to industry consultations Consultations: Elexon’s responses to industry consultations We monitor and respond to consultations that may have an impact on the provisions in the BSC, on Elexon, or on our customers. We respond to consultations if we think that an area of the electricity markets may be affected or where clarification of the BSC provisions is of benefit to the consultation. 2021 28 September 2021 - Elexon’s response to BEIS consultation on Proposals for a Future System Operator role In our response, we welcome the proposals made by BEIS/Ofgem and extend our expertise and knowledge to help deliver the proposal. We note that the proposed framework set out within the consultation provides a good foundation on the path to achieving Net Zero. We note that we do not have a preferred option in relation to ownership of the Future System Operator, but we will support and work well with any of the proposed models. In order for the Future System Operator to be effective and credible, we recommend that the FSO maintain independence not only from industry but also from Government. We welcome further communication and clarity on the overall FSO reform timeline. Status Closed Issue Date 20 July 2021 Response Date 28 September 2021 Elexon’s response to BEIS consultation on Proposals for a Future System Operator role 22 August 2021 - Elexon’s response to House of Lords Call for Evidence on Ofgem and net zero In our response, we note that Ofgem has a key role to play in the energy transition to net zero alongside BEIS. We also note that as new energy markets come into play, Ofgem will need to have an equal oversight and ability to extend its existing regulatory framework to these new markets to ensure there is a similar regulatory regime and oversight. In our response, we suggest that certain areas of the Energy Codes Reform be prioritised. Status Closed Issue Date 23 June 2021 Response Date 22 August 2021 Elexon’s response to House of Lords Call for Evidence on Ofgem and net zero 20 August 2021 - Elexon’s response to MHHS Programme’s consultation on MHHS Programme Governance Framework In our response, we agreed with the proposed framework objectives and hierarchy set out within the consultation. We noted that both proposals should enable the effective delivery of MHHS. We also make suggestions on Workgroup attendee requirements and note that constituency representatives should only include the Code Bodies. Status Closed Issue Date 30 July 2021 Response Date 20 August 2021 Elexon’s response to MHHS Programme’s consultation on MHHS Programme Governance Framework 31 July 2021 - Elexon’s response to Ofgem’s consultation on Switching Programme Significant Code Review: Retail Energy Code v3.0 In our response, we provided some comments around the redlining of REC v3.0 and noted that some other parameters need to be confirmed before Elexon proceeds with the required redlining. More specifically, Elexon asked for clarification around CR-D059 ‘Changes to support Energy Company Data’ and made some comments with regards to the Energy Market Data Specification (EMDS) and around the governance arrangements for the Supplier Meter Registration Service (SMRS). Status Closed Issue Date 04 June 2021 Response Date 31 July 2021 Elexon’s response to Ofgem’s consultation on Switching Programme Significant Code Review: Retail Energy Code v3.0 25 June 2021 - Elexon’s response to Ofgem’s consultation on MHHS Implementation and Governance Arrangements In our response, we generally agreed with the arrangements Ofgem had set out, and also highlighted the importance of robust resolution mechanisms that we need to be able to use if we are in disagreement with the Implementation Manager. We also stated that we could not commit to implementation deadlines until we receive detailed requirements from the Implementation Manager in April 2022. Status Closed Issue Date 23 April 2021 Response Date 25 June 2021 Elexon’s response to Ofgem’s consultation on MHHS Implementation and Governance Arrangements 24 June 2021 - Elexon’s response to Ofgem’s consultation on Data Best Practice guidance and Digitalisation Strategy and Action Plan guidance In our response, we suggest that the intended scope of the Data Best Practice (DBP) be clarified to explicitly include all data collected as a result of any activities arising from an obligation in any of the relevant Licenses. We agreed that requirements for speculative capture of data for future persons does not need to be included in this guidance. We also note that the review should consider whether a data monopoly could be the most efficient way of delivering the principle of making data assets discoverable for potential data users, as it would provide a single location where data can be discovered by all users. Status Closed Issue Date 25 May 2021 Response Date 24 June 2021 Elexon’s response to Ofgem’s consultation on Data Best Practice guidance and Digitalisation Strategy and Action Plan guidance 21 June 2021 - Elexon’s response to National Grid ESO’s consultation on EBGL Article 52 ISH Amendment In our response, we agree with NGESO’s proposal to amend the Imbalance Settlement Harmonisation (ISH) article to include the use of Market Index Price (MIP) in Settlement Calculations. We note that the inclusion of Market Index Price (MIP) is a valid component of system price calculations and is beneficial to both BSC Parties and consumers of electricity. Status Closed Issue Date 20 May 2021 Response Date 21 June 2021 Elexon’s response to National Grid ESO’s consultation on EBGL Article 52 ISH Amendment 21 May 2021 - Elexon’s response to National Grid ESO’s consultation on their Strategy to Enable DSO In our response, we express support for NGESO’s work to enable Distribution System Operators, and note our agreement that the ESO, DSOs and wider market processes need to be coordinated to achieve maximum value from the DSO transition. We also note a number of existing industry services that need to change in order to best accommodate new DSO capabilities. Status Closed Issue Date 30 April 2021 Response Date 21 May 2021 Elexon’s response to National Grid ESO’s consultation on their Strategy to Enable DSO 14 May 2021 - Elexon’s response to Ofgem’s consultation on the Introduction of an Electricity System Restoration Standard In our response we noted that the BSC relies on the definition of Black Start given in the Grid Code, and that if there was a material amendment to this definition there would be a consequential change to the BSC via the Modification process. Status Closed Issue Date 01 April 2021 Response Date 14 May 2021 Elexon’s response to Ofgem’s consultation on the Introduction of an Electricity System Restoration Standard 16 April 2021 - Elexon’s response to BEIS’ consultation on proposed improvements to the Capacity Market We responded to BEIS’ consultation on proposed improvements to the Capacity Market. In our response, we focus on the proposal to require Capacity Market Units to register as Balancing Mechanism Units, to help inform decision making relating to this aspect of the proposals. In particular, we wish to highlight the resources required to ensure registration of new BSC Parties and our inability to commit to processing the registration of all CM participants prior to the 2022 pre-qualification window. Status Closed Issue Date 05 March 2021 Response Date 16 April 2021 Elexon’s response to BEIS’ consultation on proposed improvements to the Capacity Market 26 March 2021 - ELEXON’s response to Ofgem’s call for evidence on the regulatory arrangements for the DCC We responded to Ofgem’s Call for Evidence on the DCC licence arrangements. In our response, we express our view that it would beneficial to see the DCC/SEC arrangements encompassed within an independent Market Operator, as laid out in our recent Policy View on Reforming the System Operator roles and Code Arrangements. In addition, we suggest that Ofgem undertake a review of the way that the DCC arrangements are funded, noting that the returns allowed for the DCC are greatly in excess of what is allowed for other Priced Controlled entities. Status Closed Issue Date 01 February 2021 Response Date 26 March 2021 ELEXON’s response to Ofgem’s call for evidence on the regulatory arrangements for the DCC 23 February 2021 - Elexon’s response to Ofgem’s consultation on Version 2.0 of the Retail Energy Code In our response we suggest that some BSC metering arrangements should not move over to the REC, particularly assurance provisions that impact actual data from metering systems for settlement purposes. Status Closed Issue Date 15 December 2020 Response Date 23 February 2021 Elexon’s response to Ofgem’s consultation on Version 2.0 of the Retail Energy Code 2020 25 November 2020 - Elexon’s response to BEIS’ consultation on International Regulatory Cooperation In our response we detailed our involvement with European and International regulatory bodies and gave our views on how government can best support international regulatory cooperation in future. Status Closed Issue Date 02 September 2020 Response Date 25 November 2020 Elexon’s response to BEIS’ consultation on International Regulatory Cooperation 16 November 2020 - Elexon’s response to Ofgem’s proposal for Version 1.1 of the Retail Energy Code In our response we mainly focused on the assurance of agents and metering systems, and shared our views on the RECCo strategy. Status Closed Issue Date 19 October 2020 Response Date 16 November 2020 Elexon’s response to Ofgem’s proposal for Version 1.1 of the Retail Energy Code 25 September 2020 - Elexon’s Response to the ENA’s consultation on the Open Networks Flexibility Services Workstream In our response we suggested that it would be sensible if Distribution System Operator (DSO) baselining methodologies were consistent with those introduced through BSC Modification P376, in order to avoid asset operators having to meet two different standards at the same time. We also noted that we would be happy to work with the Open Networks team to ensure consistency of these arrangements, and that we’d welcome DSO involvement in P376. Status Closed Issue Date 03 August 2020 Response Date 25 September 2020 Elexon’s Response to the ENA’s consultation on the Open Networks Flexibility Services Workstream 14 September 2020 - Elexon’s response to Ofgem’s MHHS Draft Impact Assessment Status Closed Issue Date 30 April 2020 Response Date 14 September 2020 Elexon’s response to Ofgem’s MHHS Draft Impact Assessment 26 August 2020 - Elexon’s response to National Grid’s Consultation on the Second Balancing Services Charges Task Force Interim Report In our response we note our concerns that fixed charges may not incentivise end user behaviour that would benefit the system. We also voice concerns that it would be difficult for end users to challenge the level of a fixed BSUoS charge. Status Closed Issue Date 22 July 2020 Response Date 26 August 2020 Elexon’s response to National Grid’s Consultation on the Second Balancing Services Charges Task Force Interim Report 31 July 2020 - Elexon's response to OLEV’s consultation on ending the sale of new petrol, diesel and hybrid cars and vans In our response we note our belief that appropriate smart charging infrastructure, metering and data access arrangements are essential in delivering the proposals. Status Closed Issue Date 07 February 2020 Response Date 31 July 2020 Response to OLEV’s consultation on ending the sale of new petrol, diesel and hybrid cars and vans 01 June 2020 - Elexon’s response to consultation on Heat Networks: Building a Market Framework In our response we supported the consultation premises that heat networks are an integral part in the government and industry efforts towards a modernised and low-carbon energy sector of the future. We also explained how a number of market arrangements from the electricity industry and more specifically from the BSC systems could be applied for the development of a prospective UK heat market. Status Closed Issue Date 01 February 2020 Response Date 01 June 2020 Response to consultation on Heat Networks: Building a Market Framework 29 May 2020 - Elexon’s Response to Electralink’s consultation on Flexr We've responded to Electralink’s consultation on their new DNO data provision and standardisation service, Flexr. Our response highlighted the importance of Open Data principles and access to the data held on the platform. We questioned the use of funding over and above the use of existing, paid for, systems architecture and how this affects platform governance. Status Closed Issue Date 21 April 2020 Response Date 29 May 2020 Response to Electralink’s consultation on Flexr 05 May 2020 - Elexon’s response to National Grid ESO consultation on Grid Code Modification GC0143: ‘Last resort disconnection of Embedded Generation’ We have commented on National Grid ESO’s proposed Grid Code Modification which will clarify the existing arrangements for disconnection of embedded generation where there is more electricity generation than expected demand. Status Closed Issue Date 01 May 2020 Response Date 05 May 2020 Response to NGESO consultation on Modification GC0143: ‘Last resort disconnection of Embedded Generation’ 13 April 2020 - Elexon’s response to the Distribution Code consultation on Engineering Recommendation (EREC) P24 Issue 2 – AC supplies to railway systems In our response, we commented on one clause of EREC P24 Issue 2, namely clause 12.9 and its references to the BSC and requirements for metering. We suggested a number of changes to the text. Status Closed Issue Date 16 March 2020 Response Date 13 April 2020 Response to Code consultation on Engineering Recommendation (EREC) P24 Issue 2 – AC supplies to railway systems: 29 March 2020 - Elexon’s response to ACER’s consultation on harmonising imbalance settlement In our response, we noted that it is not clear to us that further harmonisation of imbalance price calculations would provide benefits to consumers. Status Closed Issue Date 09 March 2020 Response Date 29 March 2020 Response to ACER’s consultation on harmonising imbalance settlement 17 March 2020 - Elexon’s response to the ENA’s consultation on the Open Networks Project 2020 Workplan In our response, we note that consistency of processes across distribution regions will be key to unlocking the potential of flexibility. We believe that provision for spending is essential to establishing the flexibility value stack, and that the findings from the Open Networks project should be presented as a case for funding in the RIIO-ED2 price control. Status Closed Issue Date 21 January 2020 Response Date 17 March 2020 Response to the ENA’s consultation on the Open Networks Project 2020 Workplan 27 February 2020 - Elexon’s response to Electralink’s consultation on DCP350 In our response, we are supportive of the provision of increased information on embedded generation >1MW as it can lead to charges being more cost reflective, aid the operation of the system and aid parties in deciding where best to locate their assets. Status Closed Issue Date 06 February 2020 Response Date 27 February 2020 Response to Electralink’s consultation on DCP350 24 January 2020 - Elexon’s response to Ofgem’s consultation on the Retail Energy Code Technical Specification In our response, we agree with the preferred option for transforming and migrating metadata held in existing catalogues, and suggest precaution when reassigning data items, in order to protect the integrity of settlement. Status Closed Issue Date 29 November 2019 Response Date 24 January 2020 Elexon’s response to Ofgem’s consultation on the Retail Energy Code Technical Specification 24 January 2020 - Elexon’s response to BEIS consultation on Heat Network (Metering and Billing) Regulations 2014 Proposed Amendments – January 2020 Elexon’s response supports the proposed amendments to the Heat Network Regulations 2014 (Metering and Billing). More specifically, we agreed with adopting a system using building classes to assess the need for installing individual heat meters both for domestic and non-domestic heat network users. We also made some recommendations on how certain BSC processes could be exemplified for the metering operations for heat networks. Status Closed Issue Date 30 October 2019 Response Date 24 January 2020 Elexon’s response to BEIS consultation on Heat Network (Metering and Billing) Regulations 2014 Proposed Amendments 16 January 2020 - Elexon’s response: ESO’s consultation on NCER amended proposals for market suspension Elexon’s response to ESO’s consultation on Network Code on Emergency and Restoration consultation asks for further detail on the market suspension trigger events. Status Closed Issue Date 16 December 2019 Response Date 16 January 2020 16 January 2020 - Elexon’s response: ESO’s consultation on NCER amended proposals for market suspension 2019 Elexon’s response to ESO’s consultation on NCER amended proposals Our response regarding ESO’s consultation on Network Code on Emergency and Restoration agrees with the one proposed mapping to the BSC, and makes some observations on the change processes. Response to ESO’s consultation on NCER amended proposals Elexon’s response to BEIS consultation on Heat Network (Metering and Billing) Regulations 2014 Proposed Amendments – January 2020 Our response supports the proposed amendments to the Heat Network Regulations 2014 (Metering and Billing). More specifically, we agreed with adopting a system using building classes to assess the need for installing individual heat meters both for domestic and non-domestic heat network users. We also made some recommendations on how certain BSC processes could be exemplified for the metering operations for heat networks. Response to BEIS consultation on Heat Network (Metering and Billing) Regulations 2014 Proposed Amendments – January 2020 Elexon’s response to ACER’s consultation on the implementation framework for the mFRR European platform Our response welcomed the proposed changes to promote consistent terminology. However, we disagreed that balancing bids for system constraints should be used to update the Cross-Zonal Capacity, and therefore distort the cross-border marginal balancing energy price. Response to ACER’s consultation on the implementation framework for the mFRR European platform Policy View: Setting up Electricity Flexibility Platforms Elexon is proposing that nationwide electricity ‘flexibility platforms’ are set up so that offers to provide ‘demand-side response’, or output from electricity storage facilities can be traded easily. The buyers of storage output or demand-side response (DSR) services could include local electricity distribution network operators (DNOs) suppliers and businesses. Policy View: Setting up Electricity Flexibility Platforms Elexon’s response to ACER’s consultation on all TSO’s proposal on the pricing methodology for balancing energy and cross-zonal capacity Our response agreed to allow scheduled counter-activations, but noted that direct counter-activations could happen for reasons other than balancing, and that this could distort imbalance prices so that they no longer represent the time value of energy Response to ACER’s consultation on all TSO’s proposal on the pricing methodology for balancing energy and cross-zonal capacity Elexon’s response to Ofgem’s consultation on Energy Company Obligation (ECO3) methodologies for calculating electricity and gas supply volumes Our response sets out how the required volumes for determining Energy Company Obligation targets can be obtained from existing data flows, and where the consultation has incorrectly identified Consumption Component Classes relating to domestic consumption. Elexon’s response to Ofgem’s consultation on Energy Company Obligation (ECO3) methodologies for calculating electricity and gas supply volumes Elexon’s Response to Ofgem’s Consultation on Refined Residual Charging Banding in the Targeted Charging Review Our response sets out how a BSC-based solution would work to enable fixed residual charges. We also note a number of areas which we believe require further consideration before Ofgem makes its final decision on its Targeted Charging Review proposals. These are Timing, Interaction with other projects – Ofgem should take opportunities, where possible, to develop common ‘whole system’ solutions and to minimise the risks of competing projects and Definitions Response to Ofgem’s Consultation on Refined Residual Charging Banding in the Targeted Charging Review Elexon's response to Ofgem’s consultation on ESO RIIO-2 financial methodology and incentives In our response to Ofgem’s consultation, we concentrated on the design of the ESO incentives with two key messages: first, that the incentives should encourage ESO to work jointly and collaboratively with Elexon for maximum customer benefit. Secondly, that the incentive reporting should allow us to compare our own code management performance with that of others, including ESO. Response to Ofgem’s consultation on ESO RIIO-2 financial methodology and incentives Elexon’s response to the Energy Networks Association’s consultation on Flexibility Our response welcomes the new flexibility commitments from network companies and suggests they attempt to mark progress against these commitments, as well as map them to other initiatives to support flexibility announced over the past year. Response to the Energy Networks Association’s consultation on Flexibility Elexon’s Response to BEIS’ Call for Evidence on Facilitating Energy Efficiency in the Electricity System Our response highlights the need for further clarity around the definition of Energy Efficiency measures. We note that non-controllable demand reduction measures should be encouraged by market signals such as Time of Use Tariffs, whilst active technologies can respond to active signals, such as those used in the Capacity Market. Elexon’s Response to BEIS’ Call for Evidence on Facilitating Energy Efficiency in the Electricity System Elexon’s response to Ofgem/BEIS consultation on reforming energy industry codes Ofgem and BEIS published their consultation on reforming the energy industry codes in July 2019, and we have published our response. We continue to strongly support reform of the code arrangements, in particular the objective of consolidation and simplification. Ofgem and BEIS want to deliver improvements to the codes and code governance arrangements by the mid-2020s and Elexon will support them in doing so. Elexon’s response to Ofgem/BEIS consultation on reforming energy industry codes Elexon’s response to Ofgem/BEIS consultation on Flexible Retail Markets Our response highlights our support for innovation and provides examples of innovation we have spoken to customers about. We requested that government and Ofgem are mindful of other industry change programmes, including the review of codes, when considering further changes to retail markets. Elexon’s response to Ofgem/BEIS consultation on Flexible Retail Markets Elexon’s response to the DFT’s consultation on Electric Vehicle Smart Charging Our response challenges OLEV’s rationale for producing a Phase 2 decision in 2023, noting that there are EV demonstration projects that will run into 2021 and the Smart Meter rollout and MHHS which are not likely to conclude until 2023-24 . Secondly, we found OLEV’s separation of public and private use cases overly simplistic, noting that there are public and private use cases that share characteristics, and could benefit from common solutions. Finally, we encourage OLEV to consolidate its and industry’s work on EVs, e.g. through the adoption of a single repository of EV issues and proposals, to facilitate holistic policy design and the identification of overlap. Elexon’s response to the DFT’s consultation on Electric Vehicle Smart Charging Elexon’s response to the ENTSO-E Consultation ‘Risk Preparedness Regulation’ In our response to ENTSO-E’s consultation, we concentrated on a single aspect: Whether the proposed wording for the templates would be sufficient to encourage TSOs and ENTSO-e to consider the impact that the operation of national rules for market suspension and of European rules for market de-coupling could have at both national and regional levels in each crisis scenario? Elexon’s response to the ENTSO-E Consultation ‘Risk Preparedness Regulation’ Selected consultation archive The archived responses below are organised based by the organisation who published the initial consultation or review. If there is an archived Elexon consultation you cannot find, please email communications@elexon.co.uk. National Grid Elexon’s response to National Grid ESO’s consultation on amendments to EBGL Article 18 Terms and Conditions Elexon’s response to National Grid’s consultation on EBGL Article 26: Proposal for Defining and Using Specific Products for balancing energy and balancing capacity Elexon’s response to National Grid’s consultation on EBGL Article 18 terms and conditions Elexon’s response to National Grid ESO’s C16 Annual Review Elexon’s response to National Grid ESO’s consultation on the ESO draft Forward Plan 2019-21 Elexon’s response to National Grid’s 2018 consultation on changes to its ABSVD Methodology Elexon’s response to National Grid’s consultation on whole electricity system thinking Elexon’s response to Grid Code Modification Proposal H/11 and associated Informal Consultation BEIS Elexon’ response to BEIS consultation on a Smart Export Guarantee (SEG): Part B Elexon’s response to BEIS’s consultation on the enrolment of Secure SMETS1 meters in the Data Communications Company Elexon’s response to BEIS’s consultation on a Smart Export Guarantee (SEG) Elexon’s response to BEIS’s policy paper on heat networks Elexon response BEIS HMT consultation supporting innovation regulated utilities Elexon response BEIS Upgrading our Energy System Ofgem Elexon’s response to Ofgem consultation ESO regulatory and incentives framework Elexon’s response to Ofgem’s consultation on the RIIO-2 Sector Methodology Elexon’s response to Ofgem’s consultation on whole system licence conditions Elexon’s response to Ofgem’s Forward Work Programme 2019-21 Elexon’s response to Ofgem’s Supplier Licensing Review consultation Other Elexon’s response to Scottish Power Energy Network’s consultation on USEF Elexon’s response to DCUSA’s consultation on Removal of Residual Charging for Storage Facilities in the CDCM and EDCM Elexon’s response to the Energy Networks Association’s consultation on the Future Worlds Impact Assessment Elexon’s response to NIC consultation on the Future of Regulation 12 April 2019 Elexon’s response to the Energy Network Association’s consultation on Phase 3 of the Open Networks Work Programme Elexon’s response to ENTSO-E’s Stakeholder Satisfaction Survey 2018 Elexon’s Response to DCUSA Change Proposal DCP268 – DUoS Charging Using HH settlement data Elexon’s open letter: BELLA participation in balancing markets Elexon’s response to the Electricity Market Reform Consultation Copyright © 2021 Elexon Design by Studio Parallel Build by Xanda Ltd Modern Slavery Privacy Policy Cookie policy Copyright Using the website A-Z Index Glassdoor Linkedin twitter Cookie use The default cookie policy on this website is set to "allow all cookies". However, you can change your settings at any time by clicking on Change Settings in your browser. Our cookies do not contain any personal or sensitive information and we only use them to improve the customer experience of the website. If you are happy to continue using the website without changing these settings you consent to our default cookie policy. Cookie Policy Accept