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Ofgem Market-Wide Half Hourly Settlement

IMServ Europe Ltd

Scorpio Rockingham Drive,

Linford Wood

Milton Keynes

MK14 6LY

19th October 2017

Sarah Whenham
Department for Business, Energy and Industrial Strategy

1 Victoria Street,
Westminster
London
SW1H 0ET

Copies to: Dermot Nolan, George Huang

 

Dear Cathryn,

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

Thank you for your letter dated 16 January in which you endeavoured to address the concerns outlined in our previous correspondence.

We are grateful for the rationale you provided in selecting particular members of both groups.

Unfortunately, we feel that our specific concerns have not been addressed. Our concerns are fourfold:

  • Both groups (the DWG and DAB) suffer from a lack of expertise which may already have compromised any output or assessment. The collection of companies sending this letter manages the half-hourly settlement of around 70% of the current half-hourly settled sites in the UK. Our members have deep domain expertise and also sit on a number of complementary boards, for example the Balancing and Settlement Code’s PerformanceAssurance Board (PAB). Many of the individuals named in your response often have no or limited UK market expertise, or work with organisations with no or extremely limited UK operations, or solely with extremely limited international operations. It is not clear to us how such individuals should be preferred to our previously nominated candidates. Further we do not feel your response satisfies our concerns about the disproportionate representation at both groups of energy suppliers, whose operations are limited in the half- hourly settled market.

  • The constituents of the DWG include an individual with both market-wide responsibilities and deep expertise of energy metering, which we believe to be beneficial. However, unfortunately the DWG does not include representation with comparable energy data understanding and perspective. This seems imbalanced, particularly given the data retrieval, processing and aggregation focus of the DWG.

IMServ Scorpio Rockingham Drive Linford Wood Milton Keynes MK14 6LY

2 February 2018

  • There has been no stakeholder engagement on the development of the skeleton TOMs and as a result there have been missed opportunities to gather views from consumers and the wider industry.

  • The focus on promoting competition in supply only and not adjacent markets, for example metering and data services, means that due consideration is not being given to deleterious consequences in these areas.

    We believe that in combination these four issues jeopardise the overall objectives of the SCR. In light of the above we would request that you share the process and criteria which you informed your decision making around:

  -  The number of individuals on both the DWG and DAB,
  -  The sector or functional representation on the DWG and DAB,o The acceptance of individuals to the DWG,
  -  The acceptance of individuals to the DAB,
  -  The appointment of chairs to the DWG and DAB.

We believe the addition of further representation to both the DWG and DAB would be beneficial toOfgem’s objectives. Hence we would request again that you reconsider the following applications for attendance at the DWG:

  -  Paul Akrill (IMServ Europe Ltd)
  -  James Murphy (Stark Software International)

Additionally, we would request again that you reconsider the following applications for attendance at the DAB:

  -  Clare Hannah (IMServ Europe Ltd)
  -  Joel Stark (Stark Software International)

  -  Peter Olsen (Energy Assets)
  -  Nick Jones (Siemens Managed Services)

We note your comments that consideration of centralisation of agent services is being considered separately. Nevertheless, we are not satisfied that the analysis carried out by the DWG and DAB will not unduly influence that decision. We intend to write separately on this issue.

We look forward to hearing from you soon

 

Yours sincerely,

Steve Brown Managing Director IMServ Europe Ltd

On behalf of:

Andy Bray, Head of Plan, Siemens Managed Services
Dave Sing, Group Managing Director (Assets), Energy Assets

Joel Stark, Managing Director, Stark Software International