UK Power Networks HSS 41 009 v3.0 Authorisation of Independent Connection Providers (ICPs), Authorised Persons (APs) and Senior Authorised Persons (SAPs) by UK Power Networks

Owner Name Jason Carmichael Title Head of Technical Training

Signature

Date 18th October 2017

Authoriser Name Simon Tapp Title Lead Operational Assessor

Signature

Date 18th October 2017

This document forms part of the UK Power Networks Integrated Management System and compliance with its requirements is mandatory. Departure from these requirements may only be taken with the written approval of the above authoriser.

Revision Record Version number 3.0 What has changed? No change to content. Change of Owner and Authoriser. Updated Date published 26/10/2017 references.

Next review date 31/10/2019 Why has it changed? Prepared by Simon Tapp Document Reviewed

Version number 2.0 What has changed? ICP Authorisation options Date published 10/10/2016 Why has it changed? Next review date 01/08/2017 UKPN would prefer to use Option 1 for connections activity and Option 2 for operational activity, but will make all authorisation option available to all ICP’s Prepared by Terry Siemers to suit the ICP’s preferences.

Version number 1.0 What has changed? The issue of a Competition in Connections Code of Practice Date published 25/08/2015 Why has it changed? Next review date 17/08/2016 New Code of Practice

Prepared by Terry Siemers

This printed document is valid at 03/06/18, check after this date for validity. Page 1 of 10 UK Power Networks HSS 41 009 v3.0

Who needs to know?

☒ All UK Power Networks ☒ Network Operations Staff ☒ EPN ☒ Asset Management ☒ LPN ☒ Capital Programme ☒ SPN ☒ Connections ☒ Distribution Capital Delivery ☒ Contractors ☐ Logistics ☐ Customer Services ☒ Network Control ☒ Finance ☒ Network Operations Connections ☐ Legal ☐ Transport Services ☒ G81 External website ☒ Strategy and Regulation ☐ HR & Communications ☐ UK Power Networks Services ☒ SHE&TT ☐ Airports ☒ In Business HSS ☐ Rail ☒ Safety Reps ☐ Strategic projects ☒ ICPs (Independent ☐ HS1, DLR & Commercial buildings Connection Providers) ☐ MUJV / Allenby ☒ IDNOs (Independent Distribution ☒ Business Development Network ☐ Others (specify) Operators) ☐ Information Systems ☐ Meter Operators

Contents

Introduction and Purpose On 21st January 2015 The Office of Gas and Electricity Markets (OFGEM) published a document (‘The Findings of our review of the electricity connections market’) following a review of the market for new connections to the electricity distribution network which described what they found and intended to do to improve competition. One of the review findings was to introduce a new condition into the electricity distribution licence which will require all Distribution Network Operators (DNO’s) to comply with a Code of Practice (CoP). OFGEM approved the Competition in Connections (CiC) CoP in July 2015. With the issue of the CoP which sets out the processes and practices that DNO’s will follow to facilitate competition it has been necessary for UK Power Networks (UKPN) to undertake a review of the CoP content and put into place any necessary process changes required.

This printed document is valid at 03/06/18, check after this date for validity. Page 2 of 10 UK Power Networks HSS 41 009 v3.0

This document looks at two elements where changes are prompted by the CoP, the Accreditation and Authorisation of Authorised Persons (AP’s) and Senior Authorised Persons (SAP’s) working on behalf of an ICP on the UKPN networks and it reflects the significantly increased scope of operational activity an ICP may carry out under the new arrangements. The goal of this document is to codify the established and developing arrangements between DNOs and ICPs for facilitating the effective operation of competition in the market for the provision of Connections. In doing so it addresses the issues OFGEM has identified in its review of the Connections market in relation to Accreditation and Authorisation of APs and SAP’s working on the behalf of an ICP on the UKPN Networks. It also seeks to foster the same high standards of performance by all relevant parties in the harmonisation of processes across DNOs to help foster competition.

Scope Included in the scope are specific areas of the CiC process that have previously been identified by OFGEM as requiring inclusion in the CoP, the areas covered in this document are Accreditation and Authorisation of AP’s and SAP’s working on the behalf of an ICP on the UKPN Networks.

Objective To ensure that our current policies, procedures and practices align with the CiC CoP and do not distort, prevent or restrict competition in the market for new electrical distribution connections.

References

Energy Network Association Competition in Connections Code of Practice draft document

Lloyds Register Energy Scope Guidance v3.0 July 2014 Lloyds Register Energy UK utility schemes Audit, Inspection and Monitoring of Networks Connection HSS 02 004 Providers HSS 41 003 Training, Assessment and Certification of Persons CON 08 115 ICP Self-Connection & Operational Activity Procedure DSR’s Distribution Safety Rules

Definitions

ICP Independent Connections Provider UK Power Networks, including the three licensed areas Eastern UKPN Power Networks (EPN) South Eastern Power Networks (SPN), and London Power Networks (LPN). CoP Code of Practice

This printed document is valid at 03/06/18, check after this date for validity. Page 3 of 10 UK Power Networks HSS 41 009 v3.0

IDNO Independent Distribution Network Operator ENA Energy Networks Association CiC Competition in Connections OFGEM The Office of Gas and Electricity Markets NERS National Electricity Registration Scheme AP Authorised Person SAP Senior Authorised Person SMS Safety Management System LoA Letter of Acceptance

Responsibilities

CiC Operational Liaison Engineer To manage the process by which an ICP, AP or SAP are enabled to work on the UKPN distribution network. To ensure that;  Processes are in place to ensure the safety of UKPN staff, ICP staff and the general public.  Provide the Accreditation Development Manager with the details of AP’s and SAP’s the ICP is intending to utilise.  The quality of work that UKPN adopts is of a suitable standard.  There is a clear communication of responsibilities  By management of the System Operations Reference Numbers (SORN) the staff scheduled to carry out work on the UKPN distribution network have been appropriately assessed and appointed.

Accreditation Development Manager To manage the process by which ICP AP and SAP staff are empowered to work on the UKPN apparatus that forms part of the distribution network. Define the standard of performance to be demonstrated by a person to enable them to be issued with an authorisation certificate. To ensure that assessments of staff working for an ICP are the same standard as for UKPN staff and contractors.

Assessors By using the performance criteria ensuring that assessments are sufficient to examine all aspects of the skills being assessed. Providing an accurate record of each practical assessment and/or underpinning knowledge assessment.

This printed document is valid at 03/06/18, check after this date for validity. Page 4 of 10 UK Power Networks HSS 41 009 v3.0

Records Both the ICP and UKPN will record and store for future reference all the policies, operational processes, certification, local information, procedures and briefing notes exchanged to facilitate safe working on the UKPN distribution system. UKPN will store its exchanged information, both issued and received within the Learning Management System (LMS) All auditing, inspection and monitoring information will be held and recorded as stated in HSS 02 004 Audit, Inspection and Monitoring of Networks Connections Providers.

Process Detail

Review Of Our Process Before The Introduction Of The CiC CoP Authorisation of AP’s and SAP’s takes place in accordance with UKPN policy procedure HSS 41 003. This policy states the required training, experience, knowledge, familiarisation and assessment required to obtain a satisfactory standard before candidates are licenced to operate on the UKPN distribution network. ICPs carry out work on our distribution networks that are not for or on behalf of UKPN, but are adopted by UKPN. Each ICP employee is issued a letter of acceptance which essentially allows him or her to work on the UKPN distribution network. ICPs are National Electricity Registration Scheme (NERS) accredited and monitored by Lloyds Register so, in practice we should be able to allow the nominated AP’s and SAP’s to work on our distribution network. Any candidate nominated by the ICP for a high voltage job within the UKPN area who holds a current appropriate UKPN certificate will be issued a Letter of Acceptance to carry out the HV work. This is as part of the “trial” currently in place in accordance with CON 08 107. When given the Letter of Acceptance the recipients are reminded that there is a distinction between working for UKPN and the ICP. AP’s or SAP’s not holding a UKPN Competence Certificate who are nominated by an ICP to work on our distribution networks are treated in exactly the same way as UKPN employees or contractors. They are required to provide relevant information relating to their past training, experience and knowledge. Depending on the knowledge of an experienced operative, elements of the process may be confirmed for example by the production of a resume or portfolio at an interview. This would be followed up with a practical assessment. Following an interview, a temporary Letter of Acceptance (LoA) would be issued to enable the candidate temporary access to the high voltage network under personal supervision. At an appropriate time, they will be assessed and, if satisfactory, issued with a LoA, not an Operational Competence Certificate, as our current certificate licences persons to operate for and on behalf of UKPN which they won’t be doing as an ICP employee.

This printed document is valid at 03/06/18, check after this date for validity. Page 5 of 10 UK Power Networks HSS 41 009 v3.0

If ICP staff members or contractors leave and then return within twelve months they will be reinstated to their previous authorisation levels unless following a discussion about the work they had undertaken in the intervening period highlighted any concerns. If ICP staff members or contractors are away for a period greater than twelve months a period of familiarisation followed by an assessment will be required. It must be noted that all operational staff for assessment and accreditation purposes are, treated in exactly the same way.

Shortfalls within the process before the introduction of the CiC CoP An inconsistent approach compared against other DNO’s. Inconvenience incurred by the ICP’s waiting for their staff to become authorised. Resentment by ICPs because they might consider our processes as unnecessary.

Risks OFGEM sought to promote competition in the provision of connections as part of the Distribution Price Control Review for the period 2010-15 (DPCR5) and undertook a review of these measures in January 2015 concluding that there were inconsistencies between DNOs in how they manage the connections process. In setting out its proposed remedy OFGEM summarised…we think there is sufficient evidence to show that there are behavioural changes that can be made by the DNOs that could resolve the issues identified without the need for structural reform. We have made the necessary changes set out in this document to ensure that we fully meet the requirements of the CoP for CiC; however, the possible alternatives do not come without their own risks. For example, there is the risk of injury or worse to members of the public, those that work for UKPN and the ICP staffs themselves if there is not a sufficient degree of control to ensure the competence of that AP’s and SAP’s accepted to work on the network. The as-is process that UKPN currently uses to accept the competence of ICP AP’s and SAP’s to work on the distribution network is very similar to how it determines the competence of its own staff and contractors. The to-be process requires the ICP to ensure that those they are nominating to work on the network have the necessary competence and experience. The to-be process will also use the National Electricity Registration Scheme (NERS) to check competence and to mitigate against any risks UKPN will implement a to-be process that balances a sufficient degree of control to ensure competence that at the same time is harmonised with the CoP.

Benefits Potential for harmonisation with other DNO’s. Compliance with the CiC CoP. Improved co-operation between ICP’s and UKPN.

This printed document is valid at 03/06/18, check after this date for validity. Page 6 of 10 UK Power Networks HSS 41 009 v3.0

Our Process Following The Introduction Of The CiC CoP UK Power Networks prefers to authorise an ICP’s AP or SAP using option 2 of the CiC CoP practice under part C 5.2 Authorisation of ICP Employees and Contractors ICPs shall operate under the DNO’s Safety Management System (SMS), including the DNO’s version of the Model Distribution Safety Rules (DSRs). The DNO will determine the relevant competence requirements and issue authorisations to the ICP’s employees or contractors. The DNO will be entitled to undertake appropriate checks to demonstrate, so far as is reasonably practicable, that the ICP’s employee or contractor has an appreciation of network hazards and local procedures. The DNO shall take account of authorisations issued by other DNOs in order to minimise circumstances where repeat authorisation assessments are required for work on different DNOs’ Distribution Systems. The charges to get authorised must be cost-reflective and opportunities to be authorised must be available on a sufficiently frequent basis. Each party shall make available to the other the relevant policies, operational processes, local information and procedures as required to facilitate safe working on a DNO’s Distribution System. This may be in writing or by personal briefing as may be appropriate, but in all cases the information exchanged shall be recorded and such records must be held for future reference by each party. (See flow chart Appendix A page 10) Whilst UK Power Networks would prefer to use Option 2 for “operational activity’ we will work together with any ICP to develop and agree effective arrangements for any alternative option in the CiC CoP that the ICP would prefer to use.

This confirms that UK Power Networks makes available all options to all ICPs to suit the ICP’s preferences.

Lloyds Accreditation The Lloyd’s Register Group operates schemes on behalf of the utility industry and their regulators to assess independently service providers seeking to work within the contestable markets in the electricity, gas, and water sectors. There are currently three schemes covering these sectors:  National Electricity Registration Scheme (NERS)  Gas Industry Registration Scheme (GIRS)  Water Industry Registration Scheme (WIRS). The schemes represent part of an ongoing process to introduce competition into the utility market. Each scheme specifies the minimum criteria against which a service provider must be assessed in order to determine their technical competence and achieve accreditation under the relevant scheme. The assessment criteria for the schemes are intended to enable service providers to be recognised as technically competent, aware of design and safety principles, and capable of installing new connections to high levels of quality and safety. The schemes are intended to help those wishing to procure the services of

This printed document is valid at 03/06/18, check after this date for validity. Page 7 of 10 UK Power Networks HSS 41 009 v3.0

accredited service providers. Each scheme has differing safety implications and competencies for the installation of infrastructure in the electricity, gas and water sectors with various scopes of accreditation.

National Electricity Registration Scheme (NERS) NERS has been developed to allow ICPs to carry out contestable connection work. Any ICP wishing to carry out this work within the contestable market, as defined by OFGEM, must be accredited under this scheme. All DNOs on mainland UK recognise this scheme and, provided that the ICPs hold the appropriate accreditations, the ICP can compete for work within the contestable connections market. When awarding contracts to registered ICPs, the developer, who is usually the client organisation, can be confident that once the work has been completed, the host DNO will adopt the connection for the remainder of its lifetime. All contractors who wish to undertake any part of the contestable connection process including project management design, cable installation etc. require the relevant accreditation. UKPN will undertake a review of the NERS accreditation process to establish if any process improvements could be recommended, any findings or recommendations will be shared and harmonised with all interested parties.

Request for Familiarisation Assessment UKPN will offer all ICP’s the opportunity to send their staff to an appropriate familiarisation session as required by the ICP or individual. UKPN will charge an appropriate market rate for these familiarisation sessions. (See flow chart Appendix A page 10)

Inspection and Monitoring UKPN reserve the right to inspect and monitor the works conducted by any connections provider engaged in activity on any or all of the licensed areas within the distribution network. These inspections can be pre-arranged or ad-hoc based upon an accurate and up to date known whereabouts schedule provided by the connections provider, submitted in advance and agreed between all parties. Alternatively for larger projects, dates will be decided in advance when key activities will be identified and inspection dates arranged. The agreed dates should not impact upon the ability of the provider to deliver the project under inspection in terms of time constraints, unless major issues are encountered. These inspections will be based on adherence to published engineering standards, accepted designs, and will also have a wider focus upon the appreciation of network hazards and DNO local procedures. The process for inspection and monitoring of the work carried out by connections providers on the UKPN distribution networks is documented in HSS 02 004 Audit, Inspection and Monitoring of Networks Connection Providers procedure.

This printed document is valid at 03/06/18, check after this date for validity. Page 8 of 10 UK Power Networks HSS 41 009 v3.0

Non Conformity Management Where non-conformities relating to the work being carried out are noted, these shall be brought to the attention of the person in charge of the works on site verbally, and be followed up by a formal report highlighting the areas of non-conformity and the required remedial action. Depending on the level of non-conformity noted, a repeat visit will usually be required to ensure satisfactory close out of the actions raised. However, for minor non-conformities the remedial action may be closed out upon receipt of evidence in the form of unambiguous photographs, or assurance received from a UKPN resource also involved in the works such as a connecting SAP that all remedial works are complete. Note that for any safety related major non-conformities, an immediate cessation of the works will be ordered and the affected network made safe pending further investigation. This, or in the event of multiple major non-conformities noted across subsequent projects offered by the same connection provider will result in the connection provider being asked to submit an action plan to address these perceived endemic issues. Further, more frequent samples inspections will ensue to test the effectiveness of the submitted action plan, in an attempt to return the connections provider to the level of inspection the provider was at previously. If no noted improvement in performance can be demonstrated, further action may be considered necessary such as providing the supporting evidence to Lloyds Register for consideration of continued compliance against the NERS scheme of work for which the provider is being measured against.

This printed document is valid at 03/06/18, check after this date for validity. Page 9 of 10 UK Power Networks HSS 41 009 v3.0

Appendix A

Title: Proposed Process Changes

ICP UK Power Networks HSS &TT

Start

ICP shall operate using the DNOs SMS and DSRs.

ICP shall notify DNO of the training, experience and knowledge of the nominated AP/ SAPs.

Nominated AP/SAP currently holds Option to attend appropriate Competency Certificate to Yes Familiarisation Course if Yes Deliver Familiarisation Course work on behalf of UK Power Networks required

No

DNO to make appropriate checks to demonstrate No so far as is reasonably practicable that the ICPs employee or contractor has an appreciation of network hazards and local procedures

ICP employee or contractor to successfully attend Issue Competency Certificate to allow a Familiarisation Course, build an Operational them to work for ICP. Portfolio, undertake an Assessment and Interview

ICP shall make available to the DNO relevant DNO shall make available to the ICP relevant policies, operational processes, local policies, operational processes, local information information and procedures as required to and procedures as required to facilitate safe facilitate safe working on the distribution working on the distribution system. This may be system. This may be in writing or personal in writing or personal briefing as may be briefing as may be appropriate. Any appropriate. Any information exchange shall be information exchange shall be recorded and recorded and records kept for future reference. records kept for future reference.

Begin Work e s a h P

This printed document is valid at 03/06/18, check after this date for validity. Page 10 of 10