The CACoP contains 14 principles to facilitate convergence and transparency in code Modification processes and to help protect the interests of small market participants and consumers. The title of each of the 14 principles can be seen below and once expanded, you will find further commentary with respect to how how we achieve each of the principles.
Principle 1 - Code Administrators shall be Critical Friends
As part of our role as a Critical Friend, we provide unbiased and constructive guidance/advice to Parties and other interested industry participants alike. Maybe you have a general question around a specific process or would like to understand more about a certain obligation. Then again, it could be that you would like to raise a Change Proposal and need some help with completing the form. If you have an idea and you think it could be an improvement on a current process/procedure but aren’t quite sure, then contact us to bounce around some ideas. You can find more information on our role as a Critical Friend the please visit our dedicated web page here.
Principle 2 - Documentation Published by Code Administrators shall be in clear English
We draft and publish all documents using plain English, where possible, after all, if we don’t understand it then there is a chance others won’t either. The content of the DCUSA varies from relatively simple processes to very technical mathematical equations and so sometimes there is a need to stray from the use of Plain English but instead you may find a graph or a diagram has been included with a view to assisting readers to better understand what the text means.
All reports are written in a concise manner, clearly setting out the background and context in which changes are being introduced, with industry jargon and acronyms set out in full when used for the first time.
Principle 3 - Information will be promptly and publicly available to users
Agendas and Papers for each meeting are uploaded to the DCUSA website no later than 5 working days before the meeting and the minutes and any associated attachments will be uploaded no later than 5 working days after the meeting.
The majority of information related to the DCUSA is publicly accessible on the website, this includes:
- the live Agreement itself (excluding the Revenue Protection Code of Practice) as well as all previous versions within the Archive;
- a list of the Parties;
- the live Change Register and an Archive Change Register;
- unless deemed to contain confidential information, copies of each Change Proposal made, any consultation issued in respect of a Change Proposal and each Change Report delivered to the Panel and/or the Authority as well as the Authority’s decision.
In simple terms all matters, minutes, reports, consultation responses, data and other information related to the change control process set out in Section 1C produced by or for, or made available to, the Panel, the Secretariat, the Panel Secretary or a Working Group (with the exception of contact details or documents containing confidential information).
Principle 4 - The Code of Practice will be reviewed periodically and subject to amendment by users
ElectraLink as the Code Administrator for the DCUSA sends a representative to attend and contribute to the CACoP group meetings, in order to ensure the document remains fit for purpose and to feed in any party views on the procedures outlined within the text.
Principle 5 - Code Administrators shall support processes which enable users to access a ‘pre-Modification’ process to discuss and develop Modifications
The DCUSA Panel have created a number of sub-groups which can act as a ‘pre-Modification’ process and to which ElectraLink, as the Code Administrator for the DCUSA, provides support. These groups are:
- The Standing Issues Group (SIG): is a general pre-modification group where members discuss any issues relating to the operation of the agreement, in order to identify solutions before any Change Proposals are raised.
- The Theft Issues Group (TIG): is a group that helps develop changes to introduce mechanisms for reporting and detecting the theft of electricity. The group covers all theft related areas including the theft of electricity code of practice, the Electricity Theft Detection Incentive Scheme, the Energy Theft Tip-Off Service and the Theft Risk Assessment Service.
- The Distribution Charging Methodology Development Group (DCMDG): is a group that specialises in the Distribution Use of System Charging Methodologies. A Party or interested industry participant may raise an issue related to the methodologies and the DCMDG will review the issue and where possible identify a solution before a Change Proposal is raised.
Principle 6 - The Proposer of a Modification will retain ownership of the detail of their solution
The DCUSA sets out that the any solution developed by a Working Group is to be compatible with the statement of intent provided by the Proposer upon raising a Change Proposal. Therefore, the Proposer defines the amount of ownership they wish to have by reference to how specific their statement of intent is. The more specific the intent, the greater their ownership of the solution and vice versa where there is a broad intent. ElectraLink as the Code Administrator for the DCUSA assists this process by allowing for members to express their views and to support the group in coming to a consensus.
Principle 7 - Code Administrators will facilitate alternative solutions to issues being developed to the same degree as an original solution
The DCUSA sets out that if a member of any Working Group disagrees with the solution being developed or believes that a better solution exists, then they are able to raise an alternative Change Proposal to the original. However, the alternative must still be compatible with the statement of intent provided by the original Proposer. ElectraLink as the Code Administrator for the DCUSA ensures that the group set up to develop the change gives equal consideration to the original and the alternative solution.
Principle 8 - Estimates of implementation costs to central systems will be produced and consulted upon prior to a Modification being recommended for approval
The DCUSA does not set out the creation or maintenance of any central systems and therefore, there is no is need to consult on the estimated cost to implement a change to a central system. Where needed, ElectraLink as the Code Administrator for the DCUSA does include cost estimates in consultations if costs have been identified relating to the implementation of a Change Proposal.
Principle 9 - Legal text will be produced and consulted upon prior to a Modification being recommended for approval
The standard Terms of Reference for each DCUSA Working Group stipulate that the group must develop and consult on the proposed legal text. ElectraLink, as the Code Administrator for the DCUSA, assists Working Groups to develop their draft text which is consulted on and following this we liaise with the appointed legal advisors to produce the final version prior to it being voted on by Parties.
Principle 10 - Modifications will be consulted upon and easily accessible to users, who will be given reasonable time to respond
DCUSA consultations are issued to DCUSA Parties and other interested parties in order to gather industry opinion on the development of a Change Proposal. The minimum amount of time for responses to be provided is 15 working days. In our role as the Code Administrator for the DCUSA, we ensure that Working Groups consider whether there is a need to allow more time for industry to respond to a consultation due to the nature and complexity of the Change Proposal and solution being developed. All documentation related to consultations is issued as an attachment to an email notification as well as being uploaded to the website.
Principle 11 - There will be flexibility for implementation, to allow proportionate delivery time and realisation of benefits
The DCUSA has three standard releases per year in February, June and November. In addition, there is generally one Special release on the 01 April each year in which changes to the charging methodologies are implemented. Where deemed necessary and/or appropriate, implementation can occur in an extraordinary release, either at a designated point in time or if urgently required, as early as 5 working days following approval.
In order to ensure consistency across the industry the publication dates for the three scheduled releases are kept in line with those published in the other industry codes such as the Balancing and Settlement Code (BSC) and the Master Registration Agreement (MRA).
Further to this, it should be noted that due to the 15-month lead time required for changes to the charging methodologies, the time taken from decision to implementation may appear longer than other Codes.
Principle 12 - The Code Administrators will report annually on agreed metrics
All energy Code Administrators have committed to operating their Code Administration functions in accordance with the Code of Practice. CACoP Principle 12 requires Code Administrators to assess their efficiency in discharging the roles and responsibilities captured within the principles of the CACoP and the effectiveness of the change management process more generally.
As such, each year we compile a report which sets out the results measured against each of the required qualitative and quantitative metrics for our Code Administration services provided to the DCUSA.
Principle 13 - Code Administrators will ensure cross code co-ordination to progress changes efficiently where modifications impact multiple codes
Given the number of interacting concurrent work-streams progressing across the entire industry, it is vitally important that we work jointly with other Code Administrators to facilitate change in a smooth and efficient manner. Code Administrators have agreed to a Joint Working Practice for any Change Proposal that has cross code impacts. Alongside this, the CACoP group meets regularly, during which, there is always time set aside for a discussion on cross code changes.
Principle 14 - Code Administrators shall support prospective energy innovators
As of November 2019, the DCUSA now contains specific provisions for a DCUSA Innovation Sandbox. A Sandbox Application is initiated by a person or company (Sandbox Applicant) that wishes to trial a new product or service and applies to Ofgem under their regulatory sandbox initiative. If approved, it enables an innovation to be trialled over a set time frame covering products or services in the live environment via special derogation against existing obligations.
The DCUSA Innovation Sandbox was introduced as Ofgem are not able to offer relief from the detailed codes (of which DCUSA is one) which underpin the operation of the gas and electricity markets, and which industry maintain. In order to widen the scope of the regulatory sandbox, Ofgem have worked closely with Code Administrators and developed Principle 14.
This provision allows us, as the Code Administrator for the DCUSA, to assist innovators as they apply for a derogation to specific obligations that are then sent to Ofgem for final permission to be granted so that the trial can be undertaken.
