Anna Stacey,

Consumers & Markets,

Ofgem,

10 South Colonnade,

London,

E14 4PU

half-hourlysettlement@ofgem.gov.uk

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28th January 2019

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Dear Anna,

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RE: CONSULTATION ON SUPPLIER AGENT FUNCTIONS PROPOSED APPROACH

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I write to you further to the meeting between AIMDA and Ofgem of 19th November in which we discussed our concerns over the centralisation of the data aggregation function.

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Subsequently, individual AIMDA members have written to you individually highlighting specific concerns around the details of the thinking that is going on within the TOM design project at ELEXON.

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Whilst we await a response from yourselves on these matters, we wish to be proactive and update you on AIMDA’s thinking as we learn more from the various fora and information sources that we have in the industry.

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It is understood that a consultation documentation is imminent that articulates the thinking from the TOM design work. We hope this consultation can provide clear statements that reinforce the competitive landscape for our services going forwards. There are issues that are of concern, and whilst we have heard some positive statements in their regards at meetings, this is an opportunity for Ofgem to be very clear and unambiguous in the content of the consultation. This would in turn progress the debate forwards at a faster rate, which can only be beneficial for all parties.

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Firstly, AIMDA hope to see that it is made clear in the forthcoming documentation that a DCC user role will be created to facilitate independent data processing/retrieval agents. This is critical to maintaining a fair and level playing field to facilitate competition. Without it, those suppliers who run these agents services today will have an unassailable advantage and the solution will have failed in preserving a competitive market in agent competition.

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Additionally we would like to make it clear that the function of the “data lake” or “HH data hub” (or whatever it is labelled when the document is finally issued) is to facilitate industry settlement only and to ensure this, place clear and firm constraints on the activities of ELEXON or any other central party who has access to this market wide data store to prevent its use for the purposes of added value services to the market. Without this in place, any central provider will have a primary advantage over any other players by virtue of their privileged and central position, which will stifle and thwart innovation and competition.

This is in addition to our objections around the centralisation of the data aggregation role in the first place, which we believe can formulated in a different way, as outlined in our submission of 30thNovember 2018.

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We thought it would be helpful to share these thoughts as you prepare your consultation materials, and as ever, we welcome any discussion that you would like to have on the matter.

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If you require any further information or wish to discuss this response, please contact AIMDA Chairman – Steve Brown on 07753 581443 or steve.brown@imserv.com.

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Yours faithfully

 

Steve Brown

Chair - AIMDA