GDEG met on 10th January 2019 and discussed the following MRA Issue Forms (MIFs) and GDAA Issues (GIFs).
GIF38 – Providers no longer part of Green Deal
GDEG discussed the problem Suppliers are having where they are continuing to collect monies from their customers but are unable to pass that funds on to the Remittance Processor or Provider because the companies have been struck off, dissolved and no replacement to take on the obligation has taken place. GDEG noted that this is a standing agenda item for the GDAA Panel as BEIS need to investigate what the legal position is for each plan and whether any SoS instruction could be given.
GIF 0039 – GDAA Monthly Reporting on Cat E obligations
GDEG noted that the recent reporting for a party highlighted areas which the calculations set up were in error. The group were advised that the initial investigation showed that the report looked at the first payment frequency received and not accounts if that changes or that they may be different. Initial amendments which have been made to the report has cleared some erroneous reporting numbers down but there still some scenario’s such as when a D0325 Data Flow was not received by the Supplier because of a Change of Supplier occurring. GDEG agreed further investigating was required to clarify the measures being reported.
Pending CoS and Cancellation of Plans
GDEG considered a potential issue which had been identified in respect of early closure of a Green Deal Plan because the plan has been paid in full and there is a pending Change of Supplier and, as a result, the Pending New Supplier did not get advised to not start collecting the Green Deal Funds. GDEG noted that there are potentially a few options to resolve the matter, for example a change could be made to GDOP08 (GD Provider updates to the Green Del Charge Details) to add in an extra step before the plan is completed and carry out a lookup to ECOES to see if a Change of Supplier is occurring and send updates to both the Current and Pending Supplier. Another alternative could be amending the GDAA obligation to send the D0325 Data Flow to Suppliers on the Supplier Start Date rather than in advanced. GDEG agreed that a new GIF should be raised in order to discuss and agree the solution options via the formal governance process.
GDAA Incident Management Procedure
GDEG highlighted their concerns and requested an update on the current position for it. The group were advised that the work is continuing to be carried out around the policies. GDEG noted that this area is still of concern and a potential risk and what would happen if the industry were to be questioned about this. The group noted that due to the way the GDAA is written that there was a real need to understand what the scope and responsibilities are for parties. GDEG were advised that the GDAA Panel are still working to move these areas along. GDEG noted that the MRA and GDAA are still separate codes and therefore may need to comply with each until the codes are subsumed into the REC.
GDCC Access Agreements
GDEG were advised that the updated Access Agreement was now available to be used and that all parties will be receiving new agreements for their companies to sign and return in due course.