Clarification and simplification around different areas within Schedule 9 - Qualification and Maintenance.

1. Proposed change: Renaming of Entry documentation for simplification:
a. From “Systems or Process Change Disclosure” to “Change or Incident Notification”
b. From “Service User Categorisation and Assessment” to “REC Service User Assessment Guidance”
2. Proposed change: Obligation 2.3 currently describes as a pre-condition to Qualification that Energy Suppliers have to demonstrate that they are a “Smart Energy Code User” (if required by the Energy Supplier’s Energy Supply License). This should be reworded to “Smart Energy Code Party” for consistency with the SEC.
3. Proposed addition: Obligation 2.4 and obligation 2.6 currently does not specify what is meant by ‘interface with other Market Participants’. An update should specify that this refers to:
i. A change to the method of interfaces (e.g the use of an alternative mechanism to DTN)
ii. A change to the system used in the sending and receipt of flows over DTN
iii. A different situation such as a change of ownership
4. Proposed change: Obligation 3.5 currently refers to says to ‘Energy Suppliers or Distribution Network Operators’ this should be reworded to ‘All REC Parties’ in order to clarify that all REC Parties including MEMs, requesting Qualification for a sector of the market that is has not previously been Qualified, must complete the full Entry Assessment process detailed in the REC Schedule.
5. Proposed change: Obligation 3.7 (b) currently refers to ‘Energy Suppliers and Distribution Network Operators’ this should be reworded to ‘All REC Parties’ in order to clarify that all REC Parties including MEMs, may be subject to Controlled Market Entry Conditions where they have become Qualified. This should also be reflected in obligation 9.7 and 9.9.
6. Proposed addition: Introduction of a new obligation between current obligation 9.9 and 9.10 which states “As a pre-condition to Controlled Market Entry Conditions (CMEC) Exit, all REC Parties should become a DCC Users (if required by its Energy Licence).
7. Proposed change: Obligation 10.2 describes that ‘All REC Service Users are obliged to promptly report any relevant and significant security incidents that affect or have affected their Systems to the Code Manager.’ The method of this communication should be reflected in the obligation as follows ‘All REC Service Users are obliged to promptly report any relevant and significant security incidents that affect or have affected their Systems to the Code Manager via the REC Service Desk’
8. Proposed change: Obligation 11.5 and 11.6 currently refer to ‘Energy Suppliers and Distribution Network Operators’ this should be reworded to ‘All REC Parties’ in order to clarify that all REC Parties including MEMs, need to complete the current systems and process change disclosures.
9. Proposed change: Obligation 13.1 describes that ‘The REC Service User External Assessment will include the submission of the following information in respect of the REC Service User (known as the REC Service User Assurance Evidence)’. This should be reworded to ‘The REC Service User External Assessment must include the submission of the following information in respect of the REC Service User (known as the REC Service User Assurance Evidence)’. This is in order to increase the enforcement of this obligation as the current words don’t stress the requirement enough.
10. Proposed addition: Obligation 13.1 details the required evidence to be submitted as part of the REC Service User External Assessment. Inclusion of requirement 13.1 (f) to describe ‘Some REC Service Users may be required to submit a letter of sponsorship (which should be resubmitted annually) to confirm that a commercial relationship exists or will exist in the next 12 months between a REC Party and the REC Service User’.