EDCM transparency efforts

This page was last updated in October 2014. It might not reflect the current position.

This page is a log of my activities trying to enhance transparency of the EDCM. It is in reverse chronological order.

10 October 2014 update

EDCM opacity ratings

31 July 2014 requests to DNOs

On 31 July 2014 I sent formal requests for information to WPD, ENWL, SSEPD, NPG, UKPN and SPEN, copying Ofgem.

Requests to all the other companies were in similar terms. One of my requests is reproduced below.

Dear [names],

I would like the following information related to the application of the EDCM to each of your DNO areas in respect of the charging year 2014/2015:

1. All the input data entered in tables 1100 to 1182 of the EDCM model. These are DNO-wide figures not specific to any customer. I am not including table 1183 in this request as it might, in some circumstances, contain detailed information that could be traced back to a specific site.

2. All the information that appears in the sheet OneLiners or Aggregates of a populated EDCM model. These are all DNO-wide/aggregated figures not specific to any customer.

3. The denominator (a £/kW figure) in the calculation of EDCM network use factors for each of the EDCM network levels (up to five). The relevant calculation is the one specified at paragraph 30.11 in DCUSA v6.2 schedule 17 or 18. Each of these denominators is a DNO-wide figure not specific to any customer.

Please send information in several instalments if some items take longer than others to retrieve.

None of the data listed above are, contain or allow the inference of individual customers’ confidential data. I do not believe that any of this information could legitimately be classified as confidential.

I plan to use your response in order to help current and potential electricity customers, their cost consultants, other clients, and possibly readers of the Daily Mail understand better how the EDCM works. Examples of my recent work in this area are validating a customer's distribution charges, estimating the potential impact on distribution charges of a confidential business development idea that a customer did not wish to disclose to the DNO, and producing the CDCM and EDCM illustrations – flat load February 2013 data (Microsoft Excel). The purpose of the present data request is to update and expand my generic calculations and illustrative case studies, to allow me to invest in non-confidential preparatory work ahead of specific customer requests, and to inform any opinions that I might express about proposals to change the EDCM or about the transparency and responsiveness of individual DNOs and Ofgem.

Many thanks.

This email is not confidential.

Franck.

31 March 2014: email to Ofgem

I sent the following email to Ofgem on 25 March 2014, summarising problems with an unnamed DNO. There was no reply, and I did not make a big enough fuss at the following DCMF.

Iain,

Here is an update. After 35 days I have had a reply from the DNO, which does contain useful information.

But the DNO refused to disclose the following information that I had requested: "Copies as values of the sheets 11, [911 or 913] and OneLiners (the non confidential information) from your December 2013 and February 2014 models."

The DNO said this about its refusal: “In addition to this, the sheet [911 or 913] data is made available in the published schedules and tables, and the sheet 11 data we can provide to you is available within the published CDCM model.”

This means that I am unable to access the following information:

The kW and kVAr columns in table 911 or 913. This means that, taking the example of FCP, I am unable to understand or predict how reactive power flows drive the application of charge 1.

Average adjusted GP (£/year), GL term from the DG incentive revenue calculation (£/year), and post-2005 CDCM generation capacity aggregates. This means that I am unable to verify, understand or forecast any aspect of EDCM generation capacity charges. I ave not looked at this charges for some time, but when I looked at the February 2013 models I discovered that they varied dramatically across the country (from to in SPEN SPM) for reasons that I could not fathom.

Override notional asset rate for 132kV/HV (£/kW). So I estimate the value of notional assets if the DNO has used this feature of the model.

Maximum network use factor and Minimum network use factor. This means that I do not have up-to-date data on these caps and collars (which are supposed to be the same for all DNOs). See e.g. paragraphs 18.6-18.8 of DCUSA Schedule 17.

Any information about the pot, aggregate notional assets, aggregate income from charge 1, aggregate revenue from demand scaling, etc. This means that, if I had not gone through the MIG issue 70 process, I would have had no means to figure out how EDCM charges are constructed, or to verify that the DNO’s calculations were plausible.

The information that I had requested is all broad aggregates across the whole EDCM customer base. The only thing that might plausibly can be argued to be confidential to one customer is the capacity/demand attributable to EDCM LDNO sites (because there are so few such sites; it would not matter if these numbers were suppressed or modified in order to protect any alleged confidentiality).

As it happens, thanks to the MIG issue 70 process, these information gaps do not currently have a significant impact on my ability to do my work for my client. That won’t always be the case.

If you thought that the EDCM might be delivering some useful signals to customers, then perhaps you would be interested in knowing what information a persistent and well-informed customer can or cannot get in order to understand these signals.

On a separate transparency matter, I attach Ofgem’s refusal to disclose some DNO expenditure information (4 pages, PDF) on spurious “commercial interests”/“trade secrets” grounds (as well as on possibly more valid section 105 grounds).

If I have spare time in the next few days I’ll prepare to make a fuss about transparency — both yours and DNOs’ — at this week's DCMF.

Franck.

25 March 2014: email to Ofgem

I sent the following email to Ofgem on 25 March 2014, summarising problems with an unnamed DNO. There was no reply.

Dear Iain,

Some time ago, an EDCM customer that I work for sent to the relevant DNO a notice of delegated authority saying that I had been appointed as an adviser, and authorising information confidential to the customer to be disclosed to me. Shortly afterwards I wrote to the DNO requesting specific data items used by the DNO in setting EDCM tariffs for my customer.

Assuming that the DNO has been using the DCUSA's EDCM model to calculate its charges, the only work involved in answering my question is to extract a few data items from the populated models and put them in an email to me. I have clearly and precisely identified the data items that I want; they are all taken either from sheets in the model that contain no customer-specific information, or from clearly identified lines in table 935 (which is the input data table for customer-specific information). To further reduce the burden on the DNO, I have been careful to only ask for the minimum that what I need, going so far as to omit from my request information about some of the tariffs applicable to my customer’s sites when I thought them unlikely to be of concern. I also remembered to omit from my request some DNO-level (non-tariff-specific) EDCM information that I had already obtained from the DNO as part of the MIG issue 70 process.

I have received a one-line acknowledgement from the DNO, but no substantive response, no data and no explanation of the delay so far.

What would you consider a reasonable period of time for a DNO to deal with such a customer request? In other words, how many days should I have been waiting until it becomes appropriate to come to you with a complaint? Do you want me to go through some DNO complaints escalation procedure before you can help? Can you promise to keep the name of the customer out of the public domain if I do complain? (if not I need to get the customer to allow me to raise a complaint before giving you specific information)

Franck.

December 2013: closure of MIG issue 70

I demonstrated at the December 2013 meeting of the DCMF MIG some tools that made it easy for DNOs to produce working spreadsheets that only contain non-confidential information and one customer's confidential information, and allow that customer to conduct EDCM scenario modelling. These tools were never used as far I am aware.

Here are the tools I gave to DCMF MIG:

Better versions may now be available through my EDCM model generator.

Franck Latrémolière