Interim Code Panel
ICP12-01
Minutes of the meeting of the Interim Code Panel
Held at Ofwat, Bloomsbury
On Wednesday 10 February 2016 at 10.30am
MEMBERS PRESENT
Tim Davis (TD) Chairman John Vinson (JV)
Mike Brindle (MB) (by Telephone) Mark Holloway (MH)
Trevor Nelson (TN) Darren Rice (DR) Alternate – Howard Smith
Elsa Wye (EW) Independent David Siddall (DS) Alternate – Nicola Smith
Nigel Sisman (NSi) Independent
Ben Jeffs (BJ) MOSL, Affiliated
Martin Silcock (MS) ICP Secretary
IN ATTENDANCE
Kulwinder Johal (KJ) MOSL Mihai Ciurba (MC) MOSL
APOLOGIES
Nicola Smith (NSm)
Amanda Rooney (AR) Ofwat, Affiliated
Howard Smith (HS)
1/7 / MINUTES OF PREVIOUS MEETINGS AND ACTIONS ARISING / Action: ICP_A0xxxThe Minutes from 13 January 2016 were accepted.
The Action Log (attached) was reviewed and all actions closed except ICP_A0057, ICP_A0059, ICP_A0062 and ICP_A0063.
Regarding Action ICP_A0062, it was confirmed by MOSL that the Test Strategy development is currently underway. As such, MOSL is not in a position to provide detailed information on when System Testing will take place and when resulting Change Proposals, if any, will be put forward to the Interim Code Panel. However, it was acknowledged that potential changes to the Codes as a consequence of system testing will appear at the end of April, and that Code changes might be proposed by Market Participants as they go through testing.
Regarding ICP_A0063, it was confirmed that Ofwat’s Letters of Approval to the recommended Code changes were published on 1st February 2016 on Ofwat’s website. It was agreed that these Letters of Approval will be published on the Interim Code Panel web page. The Codes will also be updated to incorporate the approved changes. / ICP_A0064 (MS)
2/7 / ICP/WRC012 Password Policy and Account Management (KJ)
Decision: Implementation Recommended
It was acknowledged that the WRC012 documents were released to the ICP after the agreed deadline for paper submission. The Proposer nonetheless requested that ICP recommend implementation to Ofwat. This was due to the fact that this particular Code Change Proposal had been considered several times by the Panel, with it being proposed in October, revisited in November and sent out for consultation in December.
A short overview of WRC012 was provided by the Proposer with the following points mentioned:
· The maximum character restriction on the length for the username has been removed;
· Clarity was included regarding how the initial password is provided;
· CSD0400 and CSD0006 would be aligned with existing inconsistencies removed.
· The number of days for the refresh period has been removed from CSD0006 but kept in CSD0400. This is because one CSD is referring to new administrator account expiry dates, while the other is referring to user accounts.
Members expressed concern that there had been insufficient time to carefully consider the revised Code Change Proposal, as a consequence of the documents being submitted after the agenda was published. Members emphasised that for this specific Code Change Proposal, WRC012, it was appropriate to make a recommendation, but this should not be viewed as creating a general precedent for subsequent short notice items that may be raised.
A discussion on the process of submitting a Change Proposal included the following points:
· Legal drafting should be clearer, showing only changes which are raised by the specific Change Proposal which is being considered.
· The time required to analyse a Change Proposal can be flexible, with more time required for a complex change and less time required for a less complex change.
· The current process for submitting Change Proposals needs to be improved in terms of timing, and relevant documents should be released at least five business days prior to the ICP meeting.
A proposal was made to recommend WRC012 to Ofwat. Members considered that implementation would introduce a more cost effective approach to password management than is currently envisaged in the Codes. In addition, removing inconsistencies between CSDs would aid clarity and transparency for all parties. Implementation would therefore be consistent with the Principles and Objectives, notably by enhancing efficiency in systems design and operation, and Members voted unanimously to Recommend the Change Proposal be implemented.
3/7 / WRC018 – Settlement updates (KJ)
Decision: Implementation Recommended
The Code Change Proposal had been updated following CMOS Design phase 2. This Change Proposal was raised in January and the latest version showed tracked changes against the previous version.
Members noted that the changes proposed are to align the CSDs with the system design and ensure the settlement engine works as intended. It was a concern, however, that the review process carried out by Oxera appeared to have missed the issues which were now being addressed. MOSL explained how settlement testing is carried out. This includes the use of three separate settlement testing models with any variances being investigated in order to establish whether changes to models or the Codes (or both) are necessary or desirable.
Additionally, further confidence in the settlement testing will be provided by the system design, which aims to build a product that is correct, and the testing carried out on the settlement engine. Members suggested that, given its importance, it may be valuable for an independent review of the settlement engine to be carried out once the system is built.
It was highlighted on multiple occasions that this Change Proposal is fundamental as it affects settlements. However, the feedback which had been received from Market Participants regarding WRC018 has not raised any major concerns, with the feedback to be published on the ICP web page.
A question was raised on whether a formal consultation should be undertaken, giving all parties a clear opportunity to assess the proposed changes to this fundamental element. However, it was also argued that further delaying this Code Change Proposal would not add value - the system needs to be built so that settlement works, and aligning the Codes to what is being built should be done at the earliest opportunity.
There was consensus among Members that Market Participants should be encouraged to contribute more to verifying the settlement engine and algorithms. There was agreement that the Code Change Proposal Recommendation should contain a note which urges Trading Parties to utilise their expertise and take a careful look at the settlement engine, highlighting any issues.
Members highlighted the fact that this Change Proposal is almost inevitably a stepping stone towards the final Code provisions, believing that as settlement testing is carried out, the need for further change will be identified.
It was agreed that the User Acceptance Testing (UAT) Strategy will be included on the agenda for the March meeting to provide further clarity to Members about how testing is to be carried out.
It was agreed that this Code Change Proposal is fundamental, as it affect settlements. In terms of the Code Principles and Objectives, it was agreed that implementing this change would contribute to an efficient market, by making the settlement engine work as intended, thereby reducing risk and errors in settlement.
Members voted unanimously to Recommend the Change Proposal be implemented.
Since this Code Change Proposal impacts such a fundamental aspect of system functionality, Members suggested that Ofwat be invited to Approve this Code Change Proposal as soon as possible. / ICP_A0065 (MS)
ICP_A0066 (MS)
ICP_A0067 (MS)
4/7
5/7
6/7
7/7 / WRC019 – Housekeeping changes (KJ)
Decision: Implementation Recommended
A few typographical changes to the Code Change Proposal were identified:
· Remove ‘any’ from the summary field of the Code Change Proposal;
· Introduce a space after ‘T109.M’ (Change 12 on the Excel file);
· Correct the spelling of ‘Chargeble’ (Change 37 on the Excel file);
It was also agreed that a further check, including a spelling check, will be carried out to make sure no additional errors are present.
Members noted that the changes were of a housekeeping nature rather than changing the effect or intent of the Codes. As such, it would be consistent with the Code Principles and Objectives to recommend implementation as this would further transparency and clarity, which is in the interests of an efficient market. Members then voted unanimously to Recommend the Change Proposal be implemented.
Forward planning – revised plan (KJ)
A revised version of the Forward Plan was circulated to Members and discussed in the meeting.
Clarification was provided regarding the timing of future Code Change Proposals. This included clarification on WRC020 (Charging Change Proposal), which will be brought forward to the ICP in March, WRC018 and WRC019 (Recommended to Ofwat as part of this meeting), changes to CSD0400, CSD0405, CSD0406 and CSD0301, which will be submitted in March. Additional minor changes will be brought forward in April, with any other minor updates in May.
There was also discussion around forward planning in respect of Policy changes, which included the timing of Code Changes in respect to Policy work.
In terms of Licensing and Charging Rules, no final date is available of when these will be brought forward to the ICP.
In terms of Exit Regulations, it was suggested that, although this is in July, the associated Code Change Proposal will potentially be submitted in March, based on the discussions held with ICP Members in the Exit Regulations workshop on 1st February.
Regarding GSS, Ofwat is currently working on the proposal. Members questioned whether the GSS changes could have any system impacts, and suggested that it would be beneficial to understand how the requirements would be implemented in practice.
A Developer Services change proposal needs to be added to the Forward Plan for March.
Voting Process (MS)
Previous discussions had concluded that the qualifying majority should be seven Members out of 9 Members being in favour, in order to align with the enduring Panel arrangements in the Market Arrangements Code (MAC).
In order to provide clarity regarding a qualifying majority when all Members are not present, the ICP Secretariat proposed and Members accepted that a qualifying majority would be:
· Four Members (including the chair) when four, five or six voting Members (including the chair) are present at the meeting;
· Five Members (including the chair) when seven, eight or nine voting Members (including the chair) are present at the meeting.
There was also clarification that a Member would count as more than one Member, and can vote more than once, if appointed as an Alternate by another Member.
It was suggested that ICP might usefully review, in light of experience of the ICP process, the MAC arrangements for the enduring Panel. Members could consider aiming to have any changes implemented ahead of the elections of the Enduring Panel. They might, for example, propose lowering the number of Panel Members, which would clearly have implications for the election process.
Any Other Business
A question was raised regarding the baseline Market Participants should use in terms of the Codes. How does a Market Participant know when a particular change is to be implemented in the system - the implementation timing?
Clarification on the process was provided. The first stage is Ofwat approving the Code changes that were considered by the Interim Code Panel. Once the Code changes have been approved, MOSL will, as soon as possible, include the changes in the Codes and publish revised versions.
Members expressed concern that there is not enough visibility of when the changes are implemented in the system. As such, Members suggested that if changes to the Codes are not captured in the system, clear communication regarding this needs to take place. The suggestion that was brought up was that each change should have an associated implementation date, and that this can be communicated in the Codes by introducing a note, such as “Live from ‘date’” which states the implementation date.
MOSL suggested they would develop a release management plan, providing clarity on what the process is, including when approved changes would be implemented in the system and how testing will cover these changes.
The next ICP meeting is scheduled for 9th March 2016 at 10:30am at Ofwat, Bloomsbury. / ICP_A0068 (MS)
ICP_A0069 (KJ)
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