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P375 ‘Metering behind the Boundary Point’ July 2019 Workgroup 4 Public

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  • P375 ‘Metering behind the

    Boundary Point’

    July 2019

    Workgroup 4

    Public

  • Health & Safety

    P375/6 Workgroup 32

  • Agenda

    3

    ■ Welcome & objectives

    ■ Review of meeting 3 and actions

    ■ P375 Proposal recap

    ■ P375 Customer journey

    ■ Use case illustration

    ■ Assurance for P375

    ■ Statistical analysis of asset load independence

    ■ Outstanding Issues / Review Terms of Reference

    ■ AOB & Close

  • Objectives

    4

    ■ Review end to end process

    ■ Agree solution addresses Terms of Reference

    ■ Agree outstanding issues

  • P375 Meeting 3 Summary and Actions

  • Meeting 3 Summary (1 of 2)

    P375 Workgroup 46

    ■ An example site was presented by the Proposer

    ■ The critical principle for an Asset Meter is that the equipment or sets of equipment

    can be independently controlled and dispatched

    ■ The Workgroup agreed that a ‘metering by difference’ approach (which is distinct

    from ‘difference metering’ and ‘net metering’) should be incorporated into the P375

    solution

    ■ The Workgroup agreed that more than one Asset Meter can be installed per site.

    Other site flows could be determined using a residual methodology which utilises

    Asset Metering installed

    ■ The Workgroup stepped through the draft Code of Practice 11 for Asset Metering,

    and agreed a number of updates and amendments to testing and commissioning,

    definitions and Single Line Diagrams

    ■ The Workgroup stepped through a draft high-level end to end process diagram and

    considered some of the questions ELEXON posed

  • Meeting 3 Summary (2 of 2)

    P375 Workgroup 47

    ■ The Workgroup agreed that SVAA will apply the Boundary Meter DNO LLFs according

    the voltages used by referencing the Asset and Boundary Meter

    ■ The Workgroup agreed that further consideration was needed on:

    –The assurance regime required for the registration of Asset Meters and the on-

    going monitoring. What data should be sent to which participants and what, if any,

    data should be made public, for example on BMRS

    –The extent to which the new Metering Standards for Asset Meters should cater for

    the type of measuring devices discussed in P379

    –The role of customer consent for moving an asset between VLPs

    –Whether P375 can consider adding Asset Meters to a Supplier’s Additional BMUs

  • P375 Workgroup 48

    Actions from Workgroup 3 (1 of 2)

    No Action Action on Update

    1. ELEXON to update Business Requirements based on Workgroup

    discussions for distribution to the Workgroup before the next

    meeting

    ELEXON Next draft has been prepared

    2. ELEXON to update CoP 11 Requirements based on Workgroup

    discussions for distribution to the Workgroup before the next

    meeting

    ELEXONIn progress based on going discussions. Final draft aiming for WG5

    3. Proposer and ELEXON to develop use case for presentation at the

    next meetingProposer/ELEXON Scenarios presented in WG4

    4.

    NETSO to consider if P375 will allow provision and proof of delivery

    for ancillary servicesNETSO

    ‘If the BSP wishes to use a P375 meter (or P375 difference metering) to aid in proving delivery of the service then we would be receptive to that’ Grahame Neale email

    5.

    ELEXON to document a viable assurance framework for P375 ELEXONPresented by SME in WG4

    ../G Neale email use of P375 to prove delivery of ancillary services.msg

  • P375 Workgroup 49

    Actions from Workgroup 3 (2 of 2)

    No Action Action on Update

    6. ELEXON to clarify appointment of MOPs, DCs, and delivered

    balancing volumes BMRS reporting and AMSID de-registration

    process to the Business Requirements, as well as change of VLP

    process

    ELEXONCustomer journey and scenarios covered in WG4

    7. ELEXON to engage with the Association of Decentralised Energy

    and P379 Design Authority on the use of non-Code of Practice

    Compliant Asset Metering (to inform consultation, scope and

    timescale of P375)

    ELEXONAwaiting response, but held calls and actions from Stark and Verv

    8.

    ELEXON to engage with Data Collectors on the interoperability and

    open protocols to interrogate Asset Meters and an approved list of

    Asset Meters in BSCP601

    ELEXON

    Conference call with Stark 19 July -Stark to talk with developers re meter standards and data protocols when using tenant sub-metering

  • P375 Issue and Scope

    Proposer and ELEXON

  • Problem statement

    11

    ■ The BSC currently only allows metering installed at the defined Boundary Point to be

    used for Settlement purposes

    ■ The solution developed by the P344 Workgroup relies on all Balancing Services

    provided by VLPs (consumers participating directly or through an independent

    aggregator) being settled on metering at the site Boundary Point

    ■ This means that other independent actions on site could lead to the metering at the

    site Boundary Point not reflecting the Balancing Services volumes the VLP actually

    delivered

  • Solution

    12

    ■ A successful solution would allow Asset Metering to replace the Boundary Point

    meter within the Secondary Balancing Mechanism Unit when nominated by the VLP

    ■ The solution will allow Settlement of the Balancing Service to use metering installed

    at the asset with volumes adjusted by line loss factors up to the GSP (equivalent of

    Boundary Point volumes)

    ■ The metering installed will meet Code of Practice standards in terms of requirements

    and accuracy. Performance Assurance will work to ensure Settlement Risk mitigated

    when using Asset Metering

  • Scope of the solution

    13

    All solution options would also need to consider the following:

    ■ a) obtain registration information (VLP SMBUs and AMSIDs)

    ■ b) obtain appointment information (MOPs and DCs)

    ■ b) obtain/provide meter data (DCs balancing volumes at the Asset Meter)

    ■ c) calculate and aggregate the right volumes (who did what where)

    ■ d) adjust settlement, cashflow and payments

    ■ e) be subject to assurance processes

    P375

    VLP Parties

    Registration

    Metering

    Data Collection

    Settlement

    Performance assurance

  • P375 Customer Journey and Scenarios

    Paulina Stelmach and Damian Clough

  • Insert: Document title15

    Registration

    1. Become registered as a VLP

    2. Create a SBMU (per GSP Zone)

    3. Allocate Boundary Point MSID Pairs to SBMU

    Bidding & Despatch

    4. Submit a PN for the SBMU (take into account losses up to GSP)

    5. NGESO Dispatch SBMU using FPN

    6. VLP sends SVAA allocation matrix showing how delivered volumes should be allocated

    to each MSID Pair within SBMU

    Supplier Volume Allocation

    7. SVAA calculates total metered volume for Secondary BM Unit (adjusting for LLF +

    GSPGCF)

    8. SVAA calculates Delivered Volumes per Secondary BM Unit and Supplier BM Unit

    (adjusting for LLF and GSPGCF)

    Current P344 Solution (High Level)

  • Insert: Document title16

    Settlement

    9. SAA calculate accepted volumes using NGESO BOAs and RRAs

    10. Accepted Volumes + FPN equals expected volumes

    11. Comparison between actual metered volumes and expected volumes equals delivered

    volumes

    12. Dependant on the above figure VLP may be charged Imbalance and Non delivery

    charge

    13. Delivered volumes declared by VLP (step 8) are compared to total delivered volume

    (step 11) and adjusted if necessary

    14. Suppliers volumes are then adjusted using these delivered volumes to ensure Supplier

    do not profit/loss from the Balancing Service

    Change of VLP

    15. VLP can register an existing MSID pair which is within another VLP’s SBMU

    16. The MSID pair automatically swaps but the incumbent VLP is informed of the swap

    and can challenge the swap

    Current P344 Solution (High Level)

  • Insert: Document title17

    Registration

    1. Become registered as a VLP

    2. Create a SBMU (per GSP Zone)

    3. Register Asset Metering NEW

    4. Allocate Boundary Point MSID Pairs to SBMU (including new AMMSIDs and difference metering)

    AMEND

    Bidding & Despatch

    5. Submit a PN for the SBMU (take into account losses up to GSP)

    6. NGESO Dispatch SBMU using FPN

    7. VLP sends SVAA allocation matrix showing how delivered volumes should be allocated to each MSID Pair within

    SBMU

    Supplier Volume Allocation

    8. SVAA calculates total metered volume for Secondary BM Unit (adjusting for LLF + GSPGCF). Now

    needs to accept and calculate volumes from HHDC AMMSIDS plus Difference Metering, plus LLFs for

    Asset Meters AMEND

    9. SVAA calculates Delivered Volumes (including on site losses) per Secondary BM Unit and Supplier BM Unit

    (adjusting for LLF and GSPGCF). Needs to deal with multiple VLPs AMEND

    Current P344 Solution (High Level) & P375

  • Insert: Document title18

    Settlement

    10. SAA calculate accepted volumes using NGESO BOAs and RRAs

    11. Accepted Volumes + FPN equals expected volumes

    12. Comparison between actual metered volumes and expected volumes equals delivered

    volumes

    13. Dependant on the above figure VLP may be charged Imbalance and Non delivery

    charge

    14. Delivered volumes declared by VLP (step 8) are compared to total delivered volume

    (step 11) and adjusted if necessary

    15. Suppliers volumes are then adjusted using these delivered volumes to ensure Supplier

    do not profit/loss from the Balancing Service

    Change of VLP

    16. VLP can register an existing MSID pair which is within another VLP’s SBMU

    17. The MSID pair automatically swaps but the incumbent VLP is informed of the swap

    and can challenge the swap

    Current P344 Solution (High Level) & P375

  • Insert: Document title19

    ■ P375 builds on existing P344 baseline solution to allow Asset Metering to be used for

    Settlement

    ■ Volumes from the Asset Meter will need to be provided to SVAA and fed into

    settlement

    –However many existing processes remain the same.

    – Inputs into the settlement process are changing not the actual calculations

    themselves

    Key new processes / changes

    ■ How to register Asset Meter

    ■ Metering compliance

    ■ Difference Metering for Asset Meters

    ■ How volumes from Asset Meters is sent to SVAA, and then adjusted for losses

    ■ Assurance over Independence of Asset

    Summary

  • Insert: Document title20

    ■ What registration data is required

    ■ Does the Asset Meter require a MOP?

    –Does an AMMSID need to be registered before a MOP is appointed?

    – If VLP changes and appoints new DC, new DC may have difficulty locating

    information about the meter necessary to collect and send metered flows

    –MOP could hold this data or be provided at registration/or later (if so what info)

    –Advantage of MOP is maintenance of meter to required standards and schedules

    maintaining accuracy, and could provide continuity even when VLPs change

    (assurance)

    –Who pays for the MOP?

    –Can new VLP appoint new MOP

    ■ What happens if there is a new asset/customer on site and the new VLP

    wishes to use existing AMMSID/MSID within another VLP’s SBMU. Existing

    process will automatically swap pair, but in this case no change of customer

    –New question at registration?

    Outstanding/Scenarios

  • Insert: Document title21

    ■ If Assurance process or another Party (i.e. BRP for Boundary Meter) has

    concerns over independence of an asset or gaming what happens next and

    who is responsible?

    – Inform VLP of sites where there are concerns with any supporting data (i.e. demand

    data), giving them chance to respond with supporting data which is then reviewed by

    ISG/SVG?

    – Inform NGESO?

    – Is it the BSC responsibility? or the purchaser of the Balancing Service?

    – If BSC is allowing data from Asset Meters into the settlement process arguably its

    then becomes a BSC matter

    – If still concerns, Asset Meter could be black flagged for a period preventing it being

    used in Settlement until VLP addresses how independence will be ensured

    –Appeals process created?

    –Ultimately the VLP can still use the Boundary Meter (P344 solution)

    ■ Do we require confirmation from the end customer? (not done for P344)

    Outstanding/Scenarios

  • Insert: Document title22

    ■ Will the DC automatically send us data or should SVAA instruct the DC to

    send the data?

    –We only want to build a new system change if there is the need to do so

    –Send a D354 continuous information needed for baselining

    ■ DC will naturally send us the data as and when they read the meter?

    –How regular will this be. DA’s follow SVAA calendar

    ■ Will VLPs want to use the DTN?

    – Its not part of the existing VLP qualification process

    – If there is a requirement for VLPs to use the DTN we will need to raise some DTC

    change proposals

    ■ There is a current requirement on the VLP to allocate delivered volumes. Do

    they need to tell us

    Outstanding/Scenarios

  • D e m a n d R e s p o n s e . D e l i v e r e d .

    11kV

    private wire

    ring main

    Battery

    connected

    at 11kV

    Local small

    loads

    Large I&C

    customers

    Active

    assets

    Capacity

    Market meters

    Boundary

    meters

    400V ring main

  • Insert: Document title24

    ■ VLP submits a PN (lets just assume there is one site in the SBMU for simplicity) of -20

    as that what it expects demand to be onsite (and in total for SBMU) and submits an

    offer of 4 units of DSR

    ■ SVAA calculates accepted volumes of 4 units.

    ■ FPN of -20 plus 4 units = Expected Metered Volumes at the Boundary Meter of -16

    ■ If the two CHP Units actually deliver 4 units and demand is as expected and forecasted

    in the PN, then the VLP will not be charged imbalance/non delivery charges as Actual

    Metered Volumes will equal -16

    ■ However if demand is higher than expected then this will lead to imbalance/non

    delivery charges as expected volumes will not equal actual volumes at the Boundary

    ■ What happens when more than one Boundary Point?

    Current P344 Calc

  • D e m a n d R e s p o n s e . D e l i v e r e d .

    11kV

    private wire

    ring main

    Battery

    connected

    at 11kV

    Local small

    loads

    Large I&C

    customers

    Active

    assets

    Capacity

    Market meters

    Boundary

    meters

    400V ring main

    -12

    -8

    P375

  • Insert: Document title26

    ■ VLP registers the two Capacity Market meters as Asset Meters

    ■ VLP puts these two AMMSIDs in its SBMU, and removes the Boundary MSID

    ■ VLP submits a PN of 0 (conveniently ignoring losses by using 0) and offers 4 units of

    DSR. The VLP now does not need to worry about what the rest of the site is doing

    when submitting the PN

    ■ SVAA calculates accepted volumes of 4 units.

    ■ FPN of 0 plus 4 units = Expected Metered Volumes +4

    ■ Appointed DC for the Asset Meters sends in metered volumes which SVAA adjusts

    ■ If the two CHP Units actually deliver 4 units then the VLP will not be charged

    imbalance/non delivery charges as Actual Metered Volumes will equal +4.

    ■ Fluctuating site demand does not prevent the VLP being paid for delivery

    ■ However, if the large I&C customer increases its demand by -4 we will see no change

    at the Boundary Meter. When there is no concurrent change in flows at the Boundary

    this may create further investigation

    P375

  • D e m a n d R e s p o n s e . D e l i v e r e d .

    11kV

    private wire

    ring main

    Battery

    connected

    at 11kV

    Local small

    loads

    Large I&C

    customers

    Active

    assets

    Capacity

    Market meters

    Boundary

    meters

    400V ring main

    -12

    -8

    P375

  • Insert: Document title28

    ■ If another VLP wishes to provide a Balancing Service on site it has two options;

    –Use the Boundary Meter (if not currently used by a VLP)

    –Use the new difference metering process

    – Install another Asset Meter

    ■ If an Asset Meter is installed (for the Battery) its FPN will equal -13, or 0 if it can just

    meter the Battery and not the demand.

    ■ If difference metering is used, the FPN will equal -20 i.e. Boundary Meter less Asset

    –Difference metering still includes the noise

    –However if there is large fluctuating demand an asset meter could be installed for

    this to ‘chop’ this out, and then difference meter the rest of the site

    P375

  • D e m a n d R e s p o n s e . D e l i v e r e d .

    Waste water pumping: large site

    Storm pumps:

    duty/standby

    FTFT pumps: duty/assist/standby

    Run

    occasionally;

    not flexible

    Run

    continuously;

    can be flexible

    X X X X X

    X

    XX

    Boundary meter

    Configuration depends on security requirements

    • VLP offers to reduce demand on site by

    shutting off FTFT pump(s)

    • If storm pump switches on, then this may

    lead to imbalance/non delivery charges

    • Options. VLP could install/register three

    Asset Meters relating to FTFT or,

    • VLP could register the Asset Meter which

    calculates demand from the Storm pumps,

    and then register a ‘Asset Meter’ whose

    flows are calculated using the storm flow

    meter and the Boundary Meter

  • D e m a n d R e s p o n s e . D e l i v e r e d .

    Waste water pumping: large site

    Storm pumps:

    duty/standby

    FTFT pumps: duty/assist/standby

    Run

    occasionally;

    not flexible

    Run

    continuously;

    can be flexible

    X X X X X

    X

    XX

    Boundary meter

    Configuration depends on security requirements

    • However when FTFT pumps are turned off

    this should not automatically turn on the

    Standby pumps

    • By using the Boundary Meter this prevents

    these actions being paid.

    • Using Asset Metering opens up the risk of

    this happening so this risk needs to be

    managed

  • P375 Assurance

    George Player

  • Performance Assurance Techniques

    3232

    Re - QualificaitonEducation

    Material Error Monitoring

    Tech Assurance of Metering Systems

    Tech Assurance of Performance

    Assurance Parties

    BSC Audit

    Performance Monitoring and

    Reporting

    Peer ComparisonBreach and Default

    Removal of 'Qualification

    Supplier Charges

    Error and Failure Resolution

    Trading Disputes

    Change Mechanisms

    Bulk Change of Agent

    Qualificaiton

    Incentive

    Remedial

    Preventive

    Detective

    Performance Assurance Framework

    Delivered by PARMS

  • P375 – Assurance

    33

    ■ Qualification

    –Preventative Technique

    –All VLPs to undergo Qualification

    process

    ■ BSC Audit

    –Detective Technique

    –Examines many settlement

    processes

    –Audit Threshold no longer in place

    ■ TAPAP

    –Detective Technique

    –Examines specific processes

    –Targeted at a subset of Parties

    ■ Peer Comparison

    – Incentive Technique

    –Ranks parties on their performance

    –Subject to consultation approval

    ■ Error Failure Resolution

    –Remedial Technique

    –Resolve non-compliance

    –Applied following BSC Audit

    Risk Evaluation Register

    file://PITFS01/ChangeManagement/Public/Modifications/In Progress/P375 - Settlement of Secondary BM Units using metering at the asset/Workgroup Materials/WG4/Risk-Evaluation-Register-2019_20-v1.0-1.xlsx

  • Statistical Analysis of Asset Load Independence

    John Lucas

  • Assets in a BM Unit must be independent of other assets

    ■ The assets placed in a Secondary BM Unit must be independent of any other

    demand or generation on site (otherwise the volume provided won’t be ‘real’)

    Example 1

    – The VLP is controlling 1MW of cold storage

    (which can provide flexibility for short period)

    – There is also a packaging plant on-site

    (whose behaviour is unaffected by the cold

    storage)

    – In a particular year, National Grid happens to

    issue Offers to the VLP at the start of the

    business day (when the packaging plant is

    starting up)

    – There is therefore a statistical tendency for

    the packaging plant act in the opposite

    direction to the BMU – but only because both

    are driven by time of day

    Example 2

    – The VLP is controlling a widget machine

    – There is also a backup widget machine on-

    site

    – When the VLP receives a BOA, they instruct

    the site to pause the widget machine

    – The production manager does as instructed,

    but also starts up the back-up widget

    machine to ensure their production quota is

    still met

    – There is therefore a statistical tendency for

    the backup machine to act in the opposite

    direction to the BMU

  • Statistical monitoring of asset independence

    P375/6 Workgroup 236

    ■ We therefore propose an ongoing monitoring process that analyses data from SVAA

    to look for sites where the assets not in the BMU have an unexplained tendency to

    respond to the instructions issued to the site:

    Ongoing monitoring process

    (e.g. running once a month

    to analyse the last year’s

    data)

    Metered volume MVnon-VLP for

    assets not in BM Unit

    (calculated from Asset Meters

    and Boundary Point Meters)

    Delivered Volume MPDVj as

    notified to SVAA by VLP

    Relevant Performance Assurance Techniques

    (e.g. Technical Assurance)

    Report identifying

    sites with

    unexplained

    correlation between

    VLP’s delivered

    volumes and other

    assets

  • How would the monitoring process work?

    P375/6 Workgroup 237

    ■ To be any use, a monitoring process must:

    –Be reasonably good at sniffing out foul play (such as Example 2)

    –Not generate vast numbers of ‘false positivies’

    ■ One possibility is to measure the correlation between:

    –The VLP’s delivered volume MPDVj

    –The ‘unexplained’ element of MVnon-VLP (after using a linear regression model to

    control for confounding variables such as Time of Day, Day of Week and National

    Demand)

    ■ We don’t have any real data for sites providing balancing services, but we’ve done

    some simple tests using data for BM Units

  • Running the model with BM Unit data

    P375/6 Workgroup 238

    ■ We’ve run the model with metered data and BOA volumes for real BM Units. We

    hoped to find that it:

    1. Does detect BM Units reacting to their own BOAs

    2. Doesn’t detect BM Units reacting to other units’ BOAs

    MeteredVolume

    Response to T_WBURB-2 BOAs

    Response to T_WHILW-1 BOAs

    T_WBURB-2 0.113 0.026

    2__CBGAS000 -0.033 0.053

    T_CARR-1 -0.046 0.061

    T_CRUA-1 -0.046 0.117

    T_DRAXX-2 -0.054 0.063

    T_WHILW-1 0.089 0.127

    ■ Tentative conclusion: generators behaviour is driven by complex factors, and

    spotting the influence of BOAs is not that easy

  • Running the model with modified BM Unit data

    P375/6 Workgroup 239

    ■ We also constructed some synthetic metered volumes by:

    –Starting with the metered volumes for 2__CBGAS000

    – In 50% of Settlement Periods, adding in the BOA volumes for T_WBURB-2 or

    T_WHILW-1

    ■ These metered volumes should definitely raise a red flag, which they did:

    Metered Volume Response to T_WBURB-2 BOAs

    Response to T_WHILW-1 BOAs

    2__CBGAS0001 with artificial response to T_WBURB-2 BOAs

    0.636 -0.156

    2__CBGAS0001 with artificial response to T_WBURB-2 BOAs

    -0.162 0.601

  • Conclusions

    P375/6 Workgroup 240

    ■ Modelling to date has been limited (and not using real data)

    ■ We believe it tentatively supports the idea that this technique would be useful in

    focusing Performance Assurance on potentially problematic sites

    ■ We suggest not hardcoding a particular statistical model in the legal text – ELEXON

    and/or the Panel should be allowed to improve this over time (c.f. CALF

    Methodology)

    ■ If any Workgroup members have real (anonymised) data we could do further testing

  • P375 Workgroup Terms of Reference

  • P375 workgroup Terms of Reference (1 of 2)

    42

    P375 Terms of Reference How it has been met

    1.1.5 The Workgroup will consider the following areas and include

    these in its Assessment Report:

    a) What standard of metering will be required? Note any differences

    between the standards of metering used for other Balancing

    Services such as STOR (the use of Secondary BM Unit’s may be

    extended further than the use of Replacement Reserve under

    TERRE).

    Produced a new Asset Metering Code of

    Practice 11

    b) Consider appropriate ways to demonstrate independence of the

    asset if required? How can we appropriately provide assurance of

    the impacts of the balancing service on the Total System?

    Assurance discussed in Workgroup 2,

    looking for agreement in Workgroup 4

    c) How will pseudo MPANs be registered and linked to the asset and

    how will these MPANs be subsequently be linked to the Settlement

    Meter?

    New registration process detailed in

    Business Requirements

    d) Is the solution, or can it be future proofed against potential

    future Industry developments, for example domestic assets

    providing Balancing Services or operating in the Balancing

    Mechanism.

    Still in discussion Workgroup 4

  • P375 workgroup Terms of Reference (2 of 2)

    43

    P375 Terms of Reference How it has been met

    1.1.5 The Workgroup will consider the following areas and include

    these in its Assessment Report:

    e) What changes are needed to BSC documents, systems and

    processes to support P375 and what are the related costs and lead

    times?

    VLP AMSID Registration, MOP and DC

    Appointment, Settlement, Assurance are

    detailed in the Business Requirements

    f) Are there any interactions (complements and conflictions)

    between P375 and P376?

    Combining P375 and P376 Workgroups

    g) Will any new data flows or amendments to data flows be

    required?

    Identified in the Business Requirements

    h) Are there any Alternative Modifications?

    i) Should P375 be progressed as a Self-Governance Modification? Agreement that it affects competition

    j) Does P375 better facilitate the Applicable BSC Objectives than the

    current baseline?

  • P375 Updated Timetable

    P375/6 Workgroup 344

    Event Date

    Finalised P375 solution by Workgroup 5 (BR page turn)

    W/C 5 August 2019

    Legal Text consideration by Workgroup 6 W/C 2 September 2019

    Assessment consultation 9 September – 27 September 2019

    Consultation responses consideration by Workgroup 7

    W/C 7 October 2019

    Assessment Report presented to Panel 14 November 2019

    Report Phase Consultation 18 November 2019 – 02 December 2019

    Draft Modification Report presented to Panel

    12 December 2019

    Final Modification Report submitted to Authority

    13 December 2019

  • AOB