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Ofgem Market-Wide Half Hourly Settlement

IMServ Europe Ltd

Scorpio Rockingham Drive,

Linford Wood

Milton Keynes

MK14 6LY

27th November 2017

Cathryn Scott

Ofgem,
9 Milbank,

Westminster,

London

SW1P 3GE

Dear Cathryn,

Ofgem Market-Wide Half Hourly Settlement – Membership of the Design Working Group (DWG) and Design Advisory Board (DAB)

The purpose of this letter is to request an explanation of Ofgem’s rationale and decision-making process behind the appointment of members to the DWG and DAB.

We feel that both the DWG and DAB are missing key representation from industry parties that currently deliver half-hourly settlement. Collectively, our organisations manage the majority of the existing half-hourly settled market and are under-represented on these groups. In developing and assessing the Target Operating Model(s) (TOM) for Market-Wide HHS we would have expected Ofgem to call upon this knowledge and expertise, which is ready and willing to help.

As it stands, the supplier agent representatives that have been chosen for the DWG predominantly operate in the Non Half-Hourly market or are focussed on metering as opposed to settlement. This will create a knowledge gap in the workgroup that could jeopardise delivery of its objectives. We would also highlight that membership is heavily weighted towards suppliers rather than independent agents, which could further narrow the range of experience.

Similarly, the DAB is extremely light on industry representation with just one supplier and no independent agents. We don’t understand how the DAB can be expected to assess the various TOMs developed by the DWG, or to provide “strategic advice”, when the majority of its members don’t have practical experience of the UK energy market, let alone the systems, processes and principles that underpin half-hourly settlement.

Ofgem engagement with the smaller non-domestic sector, particularly SMEs, has been poor to date - as evidenced by their lack of representation on these two groups. A significant proportion of our mutual customers fall into this segment and as such we are anxious for their views to be heard. We welcome the appointment of a Citizen’s Advice representative to the DAB but would argue that their focus will be primarily domestic consumers. This makes the absence of a specific, non-domestic consumer representative on these groups all the more concerning.

In light of the issues raised above we would request that Ofgem explain their logic behind appointing the members of the DWG and DAB so that we can better understand their choices.

Yours Sincerely,

Steve Brown

Managing Director IMServ Europe Ltd

On behalf of;

Andy Bray, Head of Plan, Siemens Metering Services
Chris Mawer, Business Development Director, SMS plc
Dave Sing, Chief Operator Officer, Energy Assets
Joel Stark, Managing Director, Stark Software International

Roger Sparks, Smart Metering Manager, WPD Smart Metering