Code Advisory Group (CAG)
Minutes from 11 March 2021 meeting
________________________________________________________________
Code Advisory Group
Minutes from 11 March 2021 meeting
Attendees
CAG Members
Jon Fuller (JF)
Michael Rathbone (MR)
Fiona Matheson (FM) - apologies
Ben Storrie (BS)
David Seymour (DS)
Andrew Smith (AS) - apologies
Jessica Morgan (JM) MOSL
Evan Joanette, (EJ) Chair
Chris Dawson (CD)
Ivy Mandinyenya (IM)
Oliver Robins (OR)
Lisa-Ann Lott (LAL) - Secretariat Agenda
Welcome & Apologies
Minutes and actions
Approve Summary and Sign-off pack
Code Amendment Review o CSD 0704
o Ops Terms o Code Architecture
Next steps
AOB
o Ofwat support o Next meeting
Meeting Notes
1. Welcome and Apologies 1.1. Apologies: FM & AS 2. Minutes and Actions
2.1. 10 February 2021 minutes agreed
2.2. 2 March 2021 meeting minutes were not reviewed in the meeting as members hadn’t had time to review. EJ to circulate via email for sign off.
3. Approve Summary and Sign-off pack
3.1. EJ shared summary and sign-off pack for C1.R/C1.W. Explained purpose was to serve as consultative tool for the industry in lieu of traditional RFI-type consultation. Open to suggestion to improve future versions of the summary pack.
3.2. A member suggested that ‘swim lane’ of what the different project streams are could be useful.
3.3. A member suggested we be crystal clear in the document that this would be the opportunity to comment. Also proposed that an SLA table is explicitly included in the summary pack.
3.4. A member proposed that MOSL explain the code architecture (structure/content) in relation to processes being build one at a time into the bilateral hub (e.g. requirement to use bilats) Outcome: Members generally agreed the pack was clear, concise summary. Members agreed the C1.R/C1.W sign off statements attributed to CAG.
4. Code Amendment Review 4.1. CSD 0704
4.1.1. CD walked through CSD 0704 from step 6
4.1.2. A member proposed that we be clearer that failure to respond to respond to the correction plan. If the timeframe expires, the default should be clear that it’s been agreed. This addresses an Ofwat challenge about whether the end trigger is clear enough.
4.1.3. Ofwat queried whether SLAs apply to every look of a process. MOSL said no. CAG suggests good practice can be tracked through business reporting. New SLAs could be incorporated only if necessary if bad behaviour is observed.
4.1.4. A member proposed that we clarity that revisions to plans are revisions to agreed plans, not an entirely new plan.
4.1.5. A member proposed that we were codifying a plan implementation without a site visit, but CAG was told that the system did not allow that route. Proposed that the rules need to match the system.
4.1.6. Ofwat has challenged us to explore alternative to the word “dispute” when it comes to plan as a “dispute” is a defined term in other areas of the code. CAG members propose that we use lowercase “dispute”. Alternatively, could consider use of the word “disagree”
when it comes to a plan.
4.1.7. CAG members proposed that the introduction to the SLAs should come out of CSD 0704 and into a higher level document like the Ops Terms. There’s already a business days section in the Ops terms where this would fit. Otherwise this would be repeated in every 700-level code doc. All members agreed Ops terms was logical place to look for SLA info.
4.1.8. Ofwat’s proposal that OPS-level SLAs are cross-referenced back to CSD0002. CAG members support this proposal but caution against duplication.
Action: MOSL to move SLA overview to Ops Terms with
appropriate cross-reference to CSD 0002 as the home of OPS-level SLAs.
4.1.9. A member proposed that the SLAs are tracked for each loop in case of future audit purposes.
4.1.10. CD highlighted the simplified SLA table and walked the CAG members through the rational for the streamlined SLAs.
4.1.11. EJ explained that the MPC/MPF subgroup have supported our SLA changes which are in line with MPF principles for improvement.
Outcome: Members generally agreed the format of the SLA table and its usability for operatives. It would be a key element of the code document and support its inclusion.
4.1.12. JF highlighted different terminology like labelling ‘trigger’, ‘event’, ‘act’ differs across table and ops terms
Action: MOSL to review inconsistent use of terms, “trigger”,
“event” in CSD 0704
4.1.13. CD explained that process flow diagrams will be simplified to a similar format to those currently in Annexes. Proposed that other information, like SLAs could be overlaid in non- code version of the flowchart (ie. guidance doc). Propose persisting in use of lowercase lettering for the flowchart boxes which would distinguish the flow chart from the narrative process steps.
Outcome: Members supported that the flow diagrams should be simplified. Focus on one main flowchart per process for the code
4.1.14. OR noted that we were inconsistent in use of “Contracted Retailer” vs “Retailer” and
“Contract wholesaler” and “Wholesaler”. The market terms tend to use “Contract Retailer”. This creates more definitions to define. Propose to consolidate.
Outcome: Members support use of the more specific “Contracted Retailer” clarified in the preamble.
Outcome: Members were unanimously minded to support CSD 0704 however wanted to see the updated draft prior to full support, in particular the flowchart. Also need to remove code that speaks to process steps we didn’t actually build.
Action: MOSL to send new draft of CSD 0704 by email to members by COB 12 March.
4.2. Operational Terms
4.2.1. EJ explained that the introduction had been edited for clarity in line with code review priority.
However, this introduction wasn’t purely related to bilaterals.
4.2.2. CAG confirmed that they supported clarifying code sections where appropriate/ ambiguous/
superfluous. Section 1.4 for instance seems superfluous.
4.2.3. A member suggested that encouraging the continued use of ‘forms’ created ambiguity in the ops terms. Recommended that any disaster recovery is outlined in CSD 0007 rather than Ops terms. The member also proposed that some of the introduction still included wooly language about what the market should achieve, rather than the operational processes themselves.
CAG recommended MOSL make further edits to take any unnecessary scene setting out.
4.2.4. Members were not supportive of retaining forms as a document. Would expect now that key data just gets sent across as spreadsheet, if there was an emergency. These would in fact be more direct as they wouldn’t have the branching paths in the current forms.
Outcome: CAG supports retiring “forms” as these are obsolete. Proposes that any template that replaces is a non-code doc. Propose an obligation on MOSL to produce a template ready to go, probably on website.
4.2.5. Ofwat has proposed that moving some information into CSDs may fall foul of the objectives of the Operational Terms. MOSL has proposed that the Ops terms sets out the CSDs as children of the Ops terms. This is supported by MOSL legal team.
4.2.6. EJ questioned whether the CAG would support a big bang approach to setting up new CSD architecture up for all processes even if the processes hadn’t yet been reviewed. CAG members weren’t supportive of that idea
Outcome: CAG supports that code hierarchy with subsidiary documents is one that’s in the market terms, so will be okay in the operational terms. Support that progressively, the processes are moved into CSDs rather than a big bang.
4.2.7. Reviewed the Ops terms section on C1 where the process has been removed and readers are directed to CSD 0704.
Outcome: CAG supportive of the approach taken to remove the processes from the Ops terms and leave a redirection.
4.2.8. A member asked if the CAG should remove references to forms by MS Word doc and/or sending via snail mail. Impractical that any TPs are still using these methodologies.
4.2.9. MOSL recommended that this would be sorted when all bilaterals processes were built and felt like a change too far at this time.
Outcome: CAG members agreed that they’d be reluctant to remove the option to use other service request methodologies at this time. Should be considered when all processes built into the hub 4.2.10. A member noted that the Ops term tended to use “associated trading party” where we
probably meant “other trading party”. MOSL concurred and would seek to change this. The member also suggested the code is clarified to make it clear that “other” trading party is NOT the one who belongs to any other SPIDs that are discovered mid way through the process.
Action: MOSL to find/replace “associated” trading party with “other”
trading party. Clarify in code that “other” is not the TP associated with related SPIDs discovered through plan preparation.
4.2.11. Members supported MOSL’s proposed to include a GDPR-supporting statement in the code that requires TPs to tell customers that they may share data with the other TP while trying to resolve the matter.
5. Next steps
5.1. Request to go to Panel with request that they support CSD0704 and Ops Terms 5.2. EJ proposed to meet again on Tuesday 16 March. Members agreed.
6. AOB
6.1. No AOB raised.
7. Actions
7.1. MOSL to move SLA overview to Ops Terms with appropriate cross-reference to CSD 0002 as the home of OPS-level SLAs.
7.2. MOSL to review inconsistent use of terms, “trigger”, “event” in CSD 0704 7.3. MOSL to send new draft of CSD 0704 by email to members by COB 12 March.
7.4. MOSL to find/replace “associated” trading party with “other” trading party. Clarify in code that
“other” is not the TP associated with related SPIDs discovered through plan preparation.
