P272 - A Programme Facing a Crisis by James Murphy


James Murphy

James Murphy

Migrating 175,000 Profile Class 05-08s to HH Settlement within 18 months was always going to be a challenge. Seven months in and the strain upon the industry is clear. A recent Elexon paper suggests that by April 2016 the industry had completed; just 10% of the mandated migrations, half the planned amount.

If this trend continues it could spell disaster. The evidence suggests that many Suppliers and their Agents are struggling to cope with bulk CoMCs, and it is known that others are missing crucial protocols to communicate with popular meter types. With planned migrations now highly concentrated around supply contract rounds in October and April, crisis looms. This will affect everyone involved. Suppliers risk massive fines for not meeting the P272 deadline and consumers will see disruption to their data, billing and metering estate.


Best Laid Plans

To aid the smooth transition of so many meters, Suppliers were required to submit detailed Migration Plans to Elexon for approval, as well as provide monthly updates to capture progress (or deviation) against those plans[1]. The graph below shows the number of planned CoMCs by month against those actually completed:



This reveals several problems. First, February is the only month in which more CoMCs were completed than planned. This relatively small surplus in one month doesn’t cover the shortfall in the others. When monthly targets are routinely missed it’s no wonder the programme as a whole is off track.

Furthermore, when the number of planned CoMCs approaches significant volume, this rate of failure is multiplied. This is evidenced by March and April where ~8,000 and ~10,000 CoMCs were planned, but less than 50% and 60% were completed. This implies a limit to the industry’s capacity for CoMC work, which can in part be explained by a widespread lack of development to legacy systems. This issue was identified by several industry parties in a 2011 consultation and now five years later, in the thick of it, some are only just addressing the problem.

This also exposes a flaw in the approach to planning CoMC activity. Bi-annual contract rounds in April and October see thousands of consumers changing Supplier. This upheaval makes it difficult for a Supplier to accurately forecast CoMCs as their portfolio is in flux, losing and gaining supplies in equal measure. This causes planned migrations to slide, creating additional work in a diminishing timeframe.

We can expect a similar story in October, which will produce an immense amount of pressure in the last six months of the programme. If the first six months are anything to go by, an unprecedented collaborative effort is required for the industry to get back on track.

Ahead of the Industry

Stark’s P272 team has been meeting for 18 months, before the change was officially approved. The prevailing feeling within the team is that P272 is incredibly complex, but it doesn’t need to be. Through careful consideration, communication and planning we’ve been able to anticipate and mitigate many of the issues that other industry Agents are encountering. Our experience of the April peak tells a brighter story.

On 1 April 2016, we completed 1,200 successful CoMCs in a single day, over a third of the industry total. As well as delivering at scale, we continued to provide industry leading data quality:

>99% Actual Reads @ SF across our entire HH portfolio
>97% Actual Reads @ SF for Measurement Classes E, F & G


SF” is the ‘Initial Settlement Run’; 18 days post consumption, when the imbalance between supply and demand is first calculated. Actual Reads are an essential part of this process as they provide an accurate view of consumption, in the absence of Actual Reads estimated data is used. In Measurement Class C (>100kW) the requirement is for 99% of energy settled on Actual Reads by SF. However, in Measurement Class E, F & G (those introduced for P272) the requirement is 99% of energy settled on Actual Reads by R1; the ‘First Reconciliation Run’, 40 days post consumption.

We believe this distinction restricts the benefits of HH Settlement for consumers and industry alike; accurate data should be available as close to consumption as possible, not 40 days later. That’s why we strive to achieve 96% Actual Reads @ D+1 and 99% Actual Reads @ SF for all Measurement Classes.

The rest of the industry’s Measurement Class E, F & G performance is 89% Actual Reads @ SF. However, these stats include ~4000 meters from the old Measurement Class E, which flatters the figures and obscures the ‘true’ settlement performance for P272- it is probably closer to 86% Actual Reads @ SF, meaning ~14% of data will be estimated. Either way, many consumers will be missing the benefits of P272 due to poor data quality from underperforming Data Collectors.

Stark can communicate with any HH compliant meter in use, whether it be Elster, EDMI, Secure or Iskraemeco. Our diverse communications methods include Paknet, IP and Satellite, which maximises coverage and data completeness. These unique capabilities allow us to deliver a seamless CoMC experience for our customers, with unrivalled data quality and analytical tools empowering them to unlock the benefits of P272.