Data Communications Company 2 nd Floor, Ludgate House 245 Blackfriars Road London, SE1 9UF

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1 Data Communications Company 2 nd Floor, Ludgate House 245 Blackfriars Road London, SE1 9UF 6th Floor Dean Bradley House 52 Horseferry Road London SW1P 2AF T +44 (0) F +44 (0) info@energynetworks.org 16 December 2014 Dear Sir/Madam, Energy Networks Association Response to Consultation on Changes to the DCC Plan and Implementation Milestones We welcome the opportunity to comment on the DCC s proposed change options for the Plan and Implementation milestones of the GB smart meter roll-out. As you are aware Energy Networks Association (ENA) is the industry body representing the UK s electricity and gas transmission and distribution Network Operators. The following comments are provided by ENA on behalf of its member companies in response to the DCC consultation which was published on 17 November The comments in the appendix accompanying this letter are submitted in support of any individual submissions provided by our member companies. Please contact me if you require further information or you wish to discuss any of the content of this reply. Yours faithfully Paul Abreu Head of Operations Policy Energy Networks Association 6th Floor, Dean Bradley House 52 Horseferry Road London SW1P 2AF PA: Mavis Neagle Tel: + 44 (0) Fax:+ 44 (0) paul.abreu@energynetworks.org

2 APPENDIX Energy Networks Association Response to Consultation on Changes to the DCC Plan and Implementation Milestones General Comments: As Network Operators all our members prefer to have certainty regarding the proposed live operation date. The date chosen should give all SEC parties confidence that there will be no further slippage to the programme. As such, the majority of our members would be happy to support either variant to the plan providing that the option chosen gives certainty that further re-plan activity is avoided in the future. Our members agree with the DCC view that there is now sufficient information available to provide a delivery plan that DCC are confident will be implemented. Our members are therefore looking for much greater levels of certainty on the timing for the delivery of DCC solutions and expect that any new DCC plan is developed so as to minimise the risk of further re-plan activity being required. All our members are keen to understand the resulting impact on the programme end date brought about by the DCC re-plan and the associated change in the DCC live operation date. They are particularly concerned about any potential compression of the programme timescale and the impact this may have on their field team resources deployed to resolve service termination defects. Any decision regarding the outcome of the consultation must be made promptly in order to provide the certainty that is required to enable the timely adaptation of network operator staff recruitment and training plans. Network Operators hold the view that any contingency in a revised DCC plan must be held by an appropriate DECC transitional governance group. However, Network Operators are concerned that they have few seats allotted to them in any of the existing transitional governance groups. Our members therefore expect that, for issues relating to the use of contingence, DECC will ensure that appropriate weighting is afforded to Network Operators. Our members are mindful that both the proposed implementation milestone changes delay the network related benefits realisation resulting from the smart meter roll-out. They are also mindful that the proposed delays to the programme will increase the number of SMETS1 meters that suppliers will install, also resulting in a reduction in benefits to customers that can be delivered by Network Operators. Our members expect DECC to undertake a full review of the SMIP Impact Assessment once the outcome of this consultation is finalised. Network Operators collectively expect to engage with DECC so that all impacts associated with the re-plan activity are appropriately assessed. Our members expect any review to consider how Smart Meter derived benefits that are delivered to customers by DNO s, or accrue directly to DNO s, are affected by the re-plan outcome. We expect that these impacts will be reflected in a revised DECC Impact Assessment. Our gas members understand and support the requirement for revision to the DCC Plan. However, they are concerned about the consequences of the proposed rescheduling of the start of System Integration Testing Solution Test activities from March 2015 to either October 2015 (as set out in Variant 1) or November 2015 (as set out in Variant 2). In addition to their deliverables in support of the DCC Delivery Programme, the GDN service provider Xoserve has a currently running Change Programme which includes two major deliverables that are planned for implementation at the start of Q4 2015, namely Project Nexus, including replacement of the UK Link system, and the GB implementation of European Network Codes for Capacity and Balancing ( EU Reform ). The clash of all this critical activity poses some issues for Xoserve and they will be writing to you separately to discuss this.

3 We respond to the specific consultation questions as follows: Q1. Do you agree with the proposals to provide facilities for informal testing with Parties? Our members hold the view that if Informal Testing is incremental to existing testing and hence de-risks UEPT then it is welcomed. The informal testing facilities would enable our members to test their back end systems and processes at the earliest opportunity and will provide additional time to address any issues that may emerge as a result of testing. Some of our members request this to be provided as a flexible service e.g. allowing support of multiple environments so that they can make best use of the facility to de-risk testing in later phases and where possible support collaboration across industry domains. Network Operators expect DCC to support testing for all DCC users and give equal opportunities for Parties of all User types to avail themselves of these facilities. Our members also look for further clarity on which subset of service requests will be available to DNOs. Our members also look for further clarity on the entry criteria requirements for participating in the informal test stages. In Section 6 Annex states that Smart Meter Key Infrastructure (SMKI) test service will not be available until October 2015 (Variant 1 plan) so our members are assuming that early phases of informal testing will be available to all users without requiring any SMKI security mechanisms or restrictive user entry processes being in place. Q2. Do you agree with the proposal to bring forward the start of the End-to-End Test stage to commence as soon as possible after the start of Interface Testing? Please describe the risks and benefits you believe to be associated with this change. The proposal to bring forward the End to End Test stage is welcomed by the majority of our members as it provides an early opportunity to validate the use of the service. Early End-to- End Testing should increase the likelihood of the amended DCC go-live date being met on time. However, our members share the concern that parallel activity such as Interface Testing and DCC plans for early live operation will create significant challenges for all users. Our members are mindful that the biggest risk in the overall DCC test approach is the ability to achieve the DCC go-live criteria without any pre-requisite level of End-to-End testing having taken place. Our members suggest that DCC will need to keep Users fully informed as to what elements of End-to-End testing are available for them to use, and when, if anything other than a full Endto-End testing service is provided from the outset of this phase. Whilst early roll out of meter installation may bring benefits to the Supplier roll-out plans, this will require additional processes and work for Network Operators, as they may need to consider significant data take-on activities. It is important to consider their key role and ensure that they are supported in the functionality that is delivered and in the verification and validation of their requirements as service users. Our members also seek assurance from the DCC that overheads and the associated costs created for Service Users will be managed efficiently. Our members suggest that the controls and communication are clear and that these are provided through effective tools which aid the management of the process and the provision of information.

4 Q3. Do you agree that DCC should develop plans to allow functional releases into live operations? Although some of our members agree that this would be a prudent measure, the majority have some reservations on providing unconditional support to the proposed approach. Functional releases into live operation raise complications and scheduling issues that will arise during the implementation and regression testing. Our members would want assurance that this release approach will not be undertaken to the detriment of the Network Operators functionality and that the DCC are able to support the implementation, change, and fault fix processes. DNO have committed to ED1 price control period benefits from smart meters and delays in appropriate functionality could impact their ability to deliver on this. Our members will expect some assurances that functional releases are considered from a use case perspective i.e. DNO would have enough functionality to perform useful tasks with smart meter information. Some of our members suggest that it must be a pre-requisite that DCC has first developed and consulted upon the release strategy supporting the future development and release of change and is also able to clearly identify the functionality that will not be available at initial release (GBCS 0.8.1). All existing Issue Resolution Proposals (IRPs) must first be assessed by the relevant governance bodies so as to ensure there are no critical requirements omitted from the go-live release baseline. This should be concluded as soon as possible so as to allow parties to rely upon a stable design baseline. Q4. Do you agree with the proposal to lock down the baseline requirements for the first live release to those described in Section 2.2? Our members all recognise that a baseline has to be created at some point and, currently, the document versions mentioned in section 2.2 seem to be a sensible choice. However, DCC must be mindful of the fact that they need to deliver a solution that works for the Service Users. The baseline cannot be set in stone as issues may emerge that require changes to the go-live baseline. Our members also raise the following points: There needs to be processes to ensure consistency and checking of the baseline documentation (this point has been raised through other document consultations). Where inconsistencies and errors are identified in the requirements or design then these must be given due consideration and ensure that Network Operators core functionality and ability to meet their operation is not detrimentally affected. Our members seek further assurance of the governance process to fully support this approach. Q5. Do you agree that programme stakeholders should work together to develop appropriate governance to determine whether functionality is deferred if necessary? The majority of our members agree with this proposal and suggest that in order to work efficiently and manage costs an existing transitional workgroup should have responsibility for this rather than creating a new group. Our members will also expect to see that the requirements of all Users are taken in to account when any proposal to defer functionality is made. Any deferral of functionality must only be taken following appropriate consultation with the group of users most impacted by such a deferment. Network Operators are concerned that they have few seats allotted to them in the existing transitional governance groups. Therefore, for issues relating to the deferment of Networks related functionality our members will expect DECC to ensure that appropriate representation is afforded to them.

5 Q6. Do you believe that introducing the ability to apply constraints if necessary during the early period of live operations is an appropriate delivery strategy? Our members consider this to be prudent and agree that the introduction of constraints would be a useful approach, as long as it does not affect their license requirements and duties in their roles as either Registration Data Providers or Network Operators. It is vital that all stakeholders have early visibility of any constraints and that, in particular, Suppliers inform Network Operators of any impacts this will have on any previously notified detailed roll-out plans. This will allow Network Operators to allocate resources needed to address service point defects appropriately. Our members are also mindful that ED1 incentivises them to deliver smart meter benefits. Constraints may impact on their ability to realise these benefits and hence constraints would need to be accounted for across the wider regulatory framework. Q7. Do you agree that programme stakeholders should work together to develop appropriate governance to develop detailed requirements for potential constraints during the early period of live operations? Our members agree with this proposal and recommend that an existing SMIP transitional governance workgroup should have responsibility for this rather than creating a new group. The requirements should cover constraints needed due to anticipated initial roll-out volumes ahead of DCC go-live and also constraints that need to be applied at short notice should an issue emerge in the period following DCC go-live. The focus should rightly be on those transactions that deliver immediate benefit to customers and less used transactions can follow on. Some of our members have a concern regarding the likely increased costs associated with several release cycles and suggest that these should be weighed against the expected risk reduction. Q8. Do you agree with the proposal to commence DCC live operations as soon as possible after the completion of Interface Testing? Although the majority of our members support this proposal they hold the view that "DCC live operations" should not equate to "smart meter live operations". Our members consider it is an extremely high risk strategy to proceed to mass enrolment of meters without completing end to end testing. However, they do agree that it is sensible to issue the new plan on the basis and that live operations should not be delayed if it is not necessary to do so. Our members expect some assurance that controls will be put in place by the DCC to ensure that parallel activities such as testing and live operations for all user groups are managed equitably and effectively. Network Operators would also require advanced notice regarding planned changes in order to manage their resources in line with any revised DCC live operation date. Q9. How much contingency would you propose to include in order to provide the appropriate balance between timeline and risk: three months, six months, or another amount? Our members are not best placed to advise DCC on contingency. Network Operators had planned to be ready for the original go-live date and their main concern has been to ensure that they can plan with confidence to a new go live date, being mindful that any further replanning will be difficult to manage within their ED1 planning cycle. Our members are of the view that that variant 1 seems high risk and variant 2 is still at a relatively high risk level of amber/green level and would welcome further information as to whether this status has been verified independently. Some of our members also raise the

6 challenge of why the variant 2 plan is not more robust, with the requirements freeze and 6 months of contingency in a 21 month timescale. Our members expectation of the re-plan was that DCC would provide an option that was as risk-free as possible so minimise the chances of a further re-plan to an absolute minimum. We would expect that, given the knowledge DCC now has regarding the design baseline, any proposed new plan should have an absolute minimum of uncertainty. Our members therefore would expect to see a DCC option that had a green rating. It is not clear to us that a rating of Amber-Green aligns with this level of confidence and would welcome further clarification in this area. Q10. Do you agree that contingency should be held at Smart Metering Programme level? Our members agree that contingency should be held at SMIP level and be subject to the relevant governance processes, control and suitable DCC user representation. Whilst our members see benefits in affording the DCC flexibility in the timelines for developing its own systems, they are seeking, so far as is reasonably practicable, certainty as to when they will need to interact with the DCC for provision of data, testing and go-live. Given that they are expected to operate efficiently their work needs to be planned well in advance and therefore a key issue for them is having certainty as to when staff will need to be deployed on smart meter related activities rather than the re-planning that has been experienced to date. Our understanding of the DCC proposals for contingency review points is that they provide an opportunity for target dates to be brought forwards. This may create additional uncertainty and therefore it should only be undertaken with the approval of all user groups. Q11. Do you have any comments on the proposed milestones dates included in Annex 6? Some of our members have concerns about the delays in completion of the Solution Design as this increases the risk of change and contingency costs with their suppliers. Our members would like to see this completed earlier, i.e. within the first quarter of Our members note that the representations of both plan variant 1 and plan variant 2 and the milestone dates quoted in section 6.3 have the planned start dates for IM8 and IM9 represented as starting after the end of the PIT contingency period. In order to properly consider the PIT contingency period as true contingency then SIT testing should be planned to commence immediately after PIT (September for both variant 1 and variant 2) with a contingency start date in the event that PIT contingency is required (October for variant 1 and November for variant 2). The same comment applies to the planned start date of the SIT UAT phase. Some of our members also suggest that a "Requirements Baseline freeze" milestone would provide clarity. Q12. Do you agree with the principle of aligning the Implementation Due Dates for IM7, IM8 and IM9 with the Joint Industry Plan, as illustrated in the table in Section 6.3 of Part B? Please provide the rationale for your views. Our members agree that it is sensible to align these milestones with the Joint Industry Plan. This provides clear visibility of the dates to all Parties and removes any ambiguities as to when they fall due.

7 Q13. Do you agree with the proposed changes to the Implementation Milestone Criteria for IM7, IM8 and IM9? Please provide the rationale for your views. Our members agree with the criteria for IM7. However, some of our members see no need to have both milestones IM8 and IM9. They suggest that these should be combined to a single milestone requiring that the Licensee, DSP and both CSPs be ready for Systems Integration Testing. The reason for this is that this is a national program requiring a solution to be available throughout Great Britain and the milestone should reflect that. Other ENA members have a similar concern on milestones IM8 and IM9. Even when milestones IM8 and IM9 have been completed it still leaves one CSP region where the Licensee (and DSP) is still required to get ready for Systems Integration Testing with the CSP. Overall these members suggest that it would be better for the programme if the milestones specified a requirement to be ready in all CSP areas, therefore preparing for the national coverage that is required. If this is not possible milestones IM8 and IM9 should recognise that there are two service providers appointed to cover three CSP areas and it is vital that both service providers solutions are made ready for testing at the earliest opportunity. Our members therefore suggest that IM9 needs to be more clearly defined in order to ensure that following the readiness for SIT of service provider 1 the next CSP area to be made ready for SIT must come from service provider 2. This is explained in the table below. CSP Area First (IM8) CSP Area Second (IM9) CSP North CSP Central or CSP South CSP Central CSP North CSP South CSP North