APPENDIX 10
Memorandum by Ofgem
SUMMARY
— Ofgem welcomes the Trade and Industry
Committee's inquiry into issues arising from the storms in October
2002, which left nearly two million customers without power, some
for as long as nine days.
— Ofgem has dealt with well over 3,000
requests for determinations over disputed claims for compensation.
Over 2,700 of these customers will be receiving compensation.
— Around 18,000 customers who did not
request determinations will also receive compensation.
— The problems were not caused by the
overall level of investment in the networks—an independent
report has found that "there appears to be no fundamental
reason why . . . companies that performed less well . . . should
not meet the standards set by the best".
— Ofgem is working with industry to
improve the ability of network companies to deal with any future
incidents and, in particular, to improve the mechanism for payment
of compensation to customers.
A. INTRODUCTION
1. Ofgem welcomes the Trade and Industry
Committee's decision to conduct an inquiry into the issues arising
from the October storms including electricity distribution companies'
progress in addressing the issues highlighted in the BPI report,
the arrangements for payment of compensation to customers affected
by power failures and the determination of disputes by Ofgem over
claims for compensation that were turned down by these companies.
2. This submission sets out some background
information to set the storms in context, outlines the relevant
features of the regulatory framework, explains the process Ofgem
has taken in determining compensation claims and outlines the
approach Ofgem is taking to improve the regulatory arrangements
in this area.
B. BACKGROUND
3. The storms of 27 October 2002 affected
much of Southern England, the Midlands and Wales. The storms caused
extensive damage to the electricity distribution networks in these
areas[10]
with almost two million customers without electricity for varying
lengths of time. Most customers were reconnected within the first
18 hours by their electricity distribution companies, although
a substantial number were without power for much longer periods.
The worst served customers were without power for up to nine days.
4. The aftermath of the storms brought by
far the largest number of determination requests that Ofgem has
ever faced and has demonstrated practical difficulties with the
existing regulatory framework.
5. The performance of some of the affected
distribution companies in the October 2002 storm fell short of
the standards that should be expected. However, some of the worst
affected companies performed substantially better in reconnecting
customers and had either no or very few claims for compensation
passed to Ofgem for determination.
6. We note the conclusion of the BPI report
that said "there appears to be no fundamental reason why
those companies that performed less well on this occasion should
not meet the standards set by the best in how the event was anticipated
and managed. Even among the best performing companies there is
no room for complacency." The BPI report also notes that
"there are a number of areas that have differentiated companies
on this occasion, in which all companies should be able to match
the performance of best performing companies with minimum cost
and minimum time delay".
7. Many of the distribution companies have
made substantial improvements in quality of supply performance
since the early 1990s, with the average number of power cuts per
customer having fallen by 11% and the average duration having
fallen by at least 30%. These figures understate the true extent
of improvements because numbers of customers interrupted and duration
were historically under-recorded. [11]
8. Current average levels of performance
are better than those in most other European countries. [12]
9. Studies of resilience[13]
and asset risk management[14]
practices conducted prior to the October 2002 storms generally
did not demonstrate major cause for concern. However, there is
not a strong correspondence between the findings of these studies
in respect of individual companies and their actual performance
in response to the storms. This demonstrates that while these
studies provide useful background information it is important
that the regulatory regime continues to focus on outputs. For
example, focussing on targets in relation to the number and length
of power cuts rather than the detailed monitoring of investment
plans which were not the main contributory factor to poor performance.
C. REGULATORY
FRAMEWORK
Overview
10. Ofgem's principal objective, as inserted
into the Gas and Electricity Acts by the Utilities Act 2000, is
to protect the interests of present and future consumers of electricity
and gas, wherever appropriate by promoting effective competition.
Ofgem has other important duties, including in relation to security
of supply, the environment and ensuring that companies can finance
their activities to meet their obligations.
11. In the case of the electricity distribution
companies, Ofgem protects consumers through a combination of regulatory
instruments, including financial incentives provided primarily
through price controls, licence obligations setting out requirements
to (or not to) act in particular ways and other secondary legislation
such as statutory instruments and determinations.
12. One of the main benefits of incentive
regulation is that it leaves detailed operational decisions where
they are usually best taken, with company management, but rewards
or penalises the company for the outcome of those decisions. This
is generally much more effective in protecting customers' interests
than for an economic regulator or Government to tell companies
how to go about their business. In Ofgem's experience (see for
example, paragraph 9 above), it is not practicable for the regulator
or its consultants to predict or judge in advance which management
policies will work best and it may be counter-productive to try
to make such judgements.
13. Inevitably, any form of incentive regulation
will reward only those aspects of desirable behaviour which can
be measured, monitored and to which a value can be attributed.
It is therefore necessary also to rely on broader obligations,
and these are an essential part of the regulatory regime. For
example, distribution companies have a statutory duty to develop
and maintain an efficient, co-ordinated and economical system
of electricity distribution.
Key aspects of current regulatory arrangements
14. The price controls on network monopolies
are typically reviewed every five years. The last price control
review of the distribution companies was concluded in December
1999 (DPCR3). [15]The
next review (DPCR4) is now underway[16]
and is expected to conclude in late 2004.
15. As part of each price review, Ofgem
considers the overall level of capital expenditure which should
be assumed in setting price limits, based on evidence from the
companies and analysis of their requirements. It is important
to allow companies to recover and earn a reasonable return on
their investments in order to ensure they are willing to invest
and to give them incentives to invest efficiently and effectively,
in order to protect the interests of consumers. However, the capital
expenditure assumption does not determine investment levels nor
authorise specific investment projects—the key drivers of
actual capital expenditure are the obligations and incentives
that companies face. If improvements in a particular output are
required, it is therefore appropriate to focus on incentives to
achieve that objective rather than to prescribe an amount of money
to be allowed in the price control. The level of the incentive
would ideally be based on the willingness of customers to pay
for the improved output.
16. During the course of DPCR3, Ofgem recognised
that the regulation of quality of service that distribution companies
deliver was in need of improvement. Over the following years,
Ofgem undertook a major review (the Information and Incentives
Project or IIP), to establish more accurate and comparable information
on the quality of service delivered by the distribution companies
and then to implement an incentive regime. [17]
17. The framework of output measures and
output-based incentives in place on the distribution companies
currently has four main elements:
— output measures that are subject
to direct financial incentives under the price control—the
number and duration of interruptions to customers' supply, the
quality of telephone response and the quantity of electrical losses
(see paragraphs 18 and 19 below);
— output measures to monitor performance
between reviews, including more detailed information on interruptions
and information on the speed of telephone response and a range
of Overall Standards of Performance relating to areas such as
making and keeping appointments and replying to correspondence;
— Guaranteed Standards of Performance
whereby individual customers may be due compensation if the distribution
company fails to meet a specified standard of performance (see
paragraph 22 to 25 below); and
— a survey of asset risk management
policies and procedures (see paragraph 26 below).
18. Following any incident on their network,
distribution companies may face financial implications from the
overall incentive on the aggregate annual number and duration
of interruptions and/or from Guaranteed Standards in respect of
individual customers.
19. Under the general quality of supply
incentives, each distribution company has a target[18]
level of performance for the number of customers interrupted and
the total duration customers are off supply (termed "customer
minutes lost"). If annual performance is worse than the target,
companies face a penalty of up to 1.75% of price controlled revenue
(capped at 0.875% in 2002-03 as this was the first year in which
the penalty applied). Companies that have improved performance
and beaten their targets may also be eligible for rewards in 2004-05.
20. Distribution companies also face rewards
or penalties of up to 0.125% of their revenue, on an annual basis,
depending on their relative quality of telephone response. This
is assessed through a monthly consumer survey.
21. Distribution companies may claim an
adjustment for events which they believe were exceptional and
had a significant impact on their performance. Ofgem has developed
tests to judge whether the event is sufficiently exceptional and
the impact material. In deciding the extent of any adjustment
Ofgem will take into account whether the distribution company
has taken all reasonable steps to restore customers in an efficient
and effective manner.
22. Under the Guaranteed Standard on Supply
Restoration[19]
domestic customers are entitled to £50 compensation (business
customers £100) if their electricity supply is not restored
within 18 hours. [20]Customers
are entitled to an additional payment of £25 for each subsequent
period of 12 hours that supply is not restored. In order to trigger
a payment under this Standard, the electricity distribution company
must receive a claim for compensation from the customer within
one month of their supply being restored.
23. However, distribution companies are
legally entitled to claim an exemption from making such payments
under this Standard if exceptional circumstances prevented them
from restoring supplies in the relevant timescales, provided that
they took reasonable steps both to design and maintain their network
and to reconnect customers. Examples of exceptional circumstances
under this Standard include severe weather or inability to access
premises to restore electricity supplies. [21]
24. The exemptions were introduced as part
of the standards of performance arrangements in 1991 in recognition
of the fact that there may be circumstances outside the control
of companies which prevent them from restoring customers' supplies
within the relevant timescales. Requiring companies to pay out
compensation is such cases would expose them to higher levels
of risk.
25. Customers are entitled to dispute a
company's exemption claim, initially with energywatch, and then
to seek a determination from Ofgem. In such cases it is Ofgem's
job to decide whether the company was acting within its legal
obligations in applying the exemption and therefore whether the
customer should be paid compensation.
26. The current incentive arrangements all
focus on current network performance. Ideally, regulatory arrangements
would also take account of the impact of decisions made by companies
today on their future performance. However, future performance
is, by its nature, impossible to measure today. Ofgem considers
that there are two main ways in which future performance can be
addressed through the regulatory framework:
— by reviewing the decision-making
processes and procedures that companies have in place, which has
been done through the Asset Risk Management Survey. This is intended
to promote good practice and to provide Ofgem with an early warning
of potential problems, but cannot be a perfect indication; and
— by creating an expectation that there
will be adverse consequences from poor performance in future.
The development and evolution of the existing regulatory framework
is in part intended to make this clear to companies.
27. In a paper published in February 2003,
[22]Ofgem
set out the approach it proposed to take to develop the regulatory
framework and has been working on this review in parallel with
determining the compensation claims (see section E below).
D. STANDARDS
OF PERFORMANCE
CLAIMS FOLLOWING
THE OCTOBER
STORMS
Background
28. Over 3,250 customers that were off supply
for longer than 18 hours following the October 2002 storms have
asked Ofgem to determine disputes relating to the application
of exemptions discussed in paragraphs 22 to 24 above. This is
the largest number of disputes that Ofgem or its predecessor OFFER
has had to deal with. [23]The
large majority of determination referrals came to Ofgem via energywatch
although a small number of customers contacted Ofgem directly.
Ofgem began receiving determination requests from energywatch
in January 2003 with the majority received and logged on our database
by the end of March. However, Ofgem has continued to receive a
modest number of determination requests since this date and energywatch
are still processing requests.
29. The work on determining the disputes
has now been completed and Ofgem will be issuing its decisions
in the week commencing 1 September 2003. The approach to determining
the disputes is set out below.
General approach adopted to determine the October
storms disputes
30. For an event of the scale of the October
storms the companies' approach to maintenance and emergency planning
will have a significant effect on their overall performance in
restoring customers. The speed with which each customer can be
reconnected will also be closely inter-related. Even the most
efficiently managed company will only have finite resources to
deploy in restoring supplies. This means that the resources used
to reconnect one group of customers will not be available to reconnect
others. Given these circumstances it was not practicable to settle
customers' determinations on an individual basis.
31. It was necessary to use an approach
which assessed both the effectiveness with which companies restored
supplies generally and their success in prioritising restoration
across customers. Ofgem has therefore adopted a method which involves
grouping customers and assessing companies' effectiveness in restoring
individual customers in each group relative to companies that
performed well during the same event.
32. This approach is consistent with the
conclusions of the DTI storms report that said "there appears
to be no fundamental reason why those companies that performed
less well on this occasion should not meet the standards set by
the best in how the event was anticipated and managed. Even among
the best performing companies there is no room for complacency".
Grouping of customers
33. Customers have been grouped according
to the complexity of faults that their distribution company had
to deal with in order to restore their supplies. This has been
based on the number and voltage of faults affecting each customer.
Where customers' supplies have been affected by a larger number
of faults it will typically take longer to restore their supplies.
It is also generally accepted that efficient prioritisation of
supplies means the repair of those faults that will restore supplies
to the greatest number of customers. This will tend to mean that
higher voltage faults are restored first. The next priority would
normally be given to low voltage faults, followed by circuits
that connect individual customers.
34. Customers have therefore been divided
into four groups whose membership is mutually exclusive. Group
1 contains the customers whose supply was interrupted by one or
more High Voltage ("HV") faults. Group 2 contains customers
whose supply was interrupted by one or more Low Voltage ("LV")
faults, possibly in combination with HV faults. Group 3 contains
customers whose supply was interrupted by a single LV Service
fault. Group 4 contains customers whose supply was interrupted
by other combinations of faults including at least one LV Service
fault.
Benchmarking performance
35. The two companies that have been used
to benchmark restoration performance are Western Power Distribution
(WPD) South-West and South-Wales. They were chosen as the benchmark
companies for several reasons:
— the storms had at least as severe
an impact in their areas as for other companies;
— they had similar levels of tree coverage
as other companies;
— their performance in restoring customers
was good; and
— they had no outstanding determination
cases.
36. For each group of customers, Ofgem analysed
a large sample of WPD data and any key differences in circumstances
between companies to establish benchmark restoration times. In
Ofgem's judgement these are the times at which a company that
had taken all reasonable steps could have been expected to have
restored electricity supplies to all customers in the group and
at which the exemptions should therefore cease to operate. Customers
are then entitled to £25 compensation at the next standards
of performance contravention time[24]
and for each additional 12 hours period thereafter.
37. The benchmark times are set out in Table
1 below:
Table 1
BENCHMARK RESTORATION TIMES
| Group | Faults
| Benchmark times | Time at which
first payment
is due
|
| 1 | HV faults only | 20.1 hours
| 30 hours |
| 2 | LV faults possibly in combination with HV faults
| 33.1 hours | 42 hours |
| 3 | 1 LV service fault |
47.7 hours | 54 hours |
| 4 | Other combinations including at least 1 LV service fault
| 61.8 hours | 66 hours |
| | |
|
38. Table 2 sets out the basic payments that customers
in each group are entitled to which are dependent on the length
of power cut.
Table 2
PAYMENT LEVELS FOR FIRST POWER CUT GREATER THAN 18 HOURS
| Group | 1
| 2 | 3 | 4
|
|
Group Description
|
HV only | LV, in
possible
combination
with HV
|
1 LV service | Others
including at
least 1 LV
service stage
|
| Up to 30 hours | £0
| £0 | £0 | £0
|
| 30 hrs to 41 hrs 59 mins |
£25 | £0 | £0
| £0 |
| 42 hrs to 53 hrs 59 mins |
£50 | £25 | £0
| £0 |
| 54 hrs to 65 hrs 59 mins |
£75 | £50 | £25
| £0 |
| 66 hrs to 77 hrs 59 mins |
£100 | £75 | £50
| £25 |
| 78 hrs to 89 hrs 59 mins |
£125 | £100 | £75
| £50 |
| 90 hrs to 101 hrs 59 mins |
£150 | £125 | £100
| £75 |
| Duration | 102 hrs to 113 hrs 59 mins
| £175 | £150 | £125
| £100 |
| of the | 114 hrs to 125 hrs 59 mins
| £200 | £175 | £150
| £125 |
| interruption | 126 hrs to 137 hrs 59 mins
| £225 | £200 | £175
| £150 |
| 138 hrs to 149 hrs 59 mins
| £250 | £225 | £200
| £175 |
| 150 hrs to 161 hrs 59 mins
| £275 | £250 | £225
| £200 |
| 162 hrs to 173 hrs 59 mins
| £300 | £275 | £250
| £225 |
| 174 hrs to 185 hrs 59 mins
| £325 | £300 | £275
| £250 |
| 186 hrs to 197 hrs 59 mins
| £350 | £325 | £300
| £275 |
| 198 hrs to 209 hrs 59 mins
| £375 | £350 | £325
| £300 |
| 210 hrs to 221 hrs 59 mins
| £400 | £375 | £350
| £325 |
| 222 hrs to 233 hrs 59 mins
| £425 | £400 | £375
| £350 |
| 234 hrs to 245 hrs 59 mins
| £450 | £425 | £400
| £375 |
| | |
| | |
39. Some customers experienced more than one power cut
lasting more than 18 hours as result of the October storms. Such
customers will receive full payment under the Standards of Performance
for any further power cuts lasting longer than 18 hours in addition
to any payments they are due for under Table 1 above.
40. If customers have already received ex-gratia payments
from their distribution company these will be deducted in calculating
the final payment to be made to the customer.
Payments to other customers
41. In addition to the determinations the electricity
distribution companies have also agreed to make payments on the
same basis to other customers whose claims were received within
one month of their supply being restored. These customers have
a right to request a determination from Ofgem but have not done
so. The companies will be making payments to around 18,000 additional
customers. These payments are estimated to exceed £1.6 million.
42. Ofgem welcomes the companies' agreement to pay these
customers and recognises that it goes beyond their legal obligations.
Ofgem considers this to be a good outcome for customers.
Impact on the NEWSAC arrangements for sharing field staff
43. A number of companies have raised concerns that the
use of comparative analysis in determining the disputes may undermine
future emergency co-operation through the NEWSAC arrangements,
whereby companies loan each other field staff. Ofgem considers
that the efficient use of resources across the industry will tend
to compress the range of times taken to restore customers' supplies,
rather than increase them. This would reduce the overall length
of power cuts and would continue to be in the long-term interest
of companies and customers.
E. DEVELOPMENT OF
INTERIM AND
LONGER-TERM
ARRANGEMENTS FOR
EXCEPTIONAL EVENTS
Background
44. During initial work on the distribution price control
review and ongoing work on the determination process Ofgem found
important weaknesses in the current standards of performance arrangements
and in particular the application of exemptions:
— there is a lack of clarity in incentives to electricity
distribution companies;
— there are delays in compensation reaching consumers;
— there is confusion for consumers about whether
compensation is payable; and
— the determination process can be highly resource
intensive for both Ofgem and energywatch.
45. To address these issues, Ofgem has begun to consider
new arrangements to be introduced from April 2005, as part of
the price control review. This work is described below.
46. However, as there is 18 months between now and April
2005, including two winters, Ofgem considers that it is important
to put in place interim arrangements to cover events before the
next price control, and avoid the problems encountered following
last year's storms. Ofgem consulted on this issue in its July
consultation paper on the distribution price control review. [25]Responses
to the consultation were due on 22 August and, following consideration
of the responses, Ofgem intends to discuss the detail of such
a mechanism with the distribution companies, energywatch and other
interested parties with a view to having new interim arrangements
in place by the end of October. The form of the interim arrangements
will depend on the outcome of this consultation process, and an
agreement being reached with the distribution companies, but Ofgem's
current thinking is outlined below.
Possible form of the interim arrangements
47. As noted in paragraph 24 above, the standards of
performance exemptions were introduced in recognition of the fact
that there are some events outside the control of companies that
prevent them from restoring customers' supplies in the relevant
timescales. Ofgem's intention in developing interim arrangements
is to ensure customers receive more rapid payments following exceptional
events whilst maintaining appropriate incentives for supply restoration.
Such interim arrangements can only be introduced with the agreement
of the companies or by changes to the Statutory Instrument. Ofgem's
preferred option for these arrangements would be to proceed by
agreement, which will require that the new arrangements do not
expose the companies to materially increased risk.
48. In order to ensure that customers receive appropriate
compensation for being off supply and that there are appropriate
incentives for companies to restore customers promptly for different
scale events, Ofgem considers that it may be appropriate to divide
severe weather events into two categories:
(a) For smaller events (eg cases where only a few thousand
customers are affected) the existing standards of performance
arrangements would continue to apply.
(b) For larger events (for example cases where more than
5% of a company's customers are affected) companies would waive
their right to claim an exemption for power cuts above a certain
duration and would instead pay out all valid claims for compensation
on a pre-agreed basis.
49. The electricity distribution companies would then
seek recovery of compensation costs for the larger events through
the price control, which would be spread across all consumers.
Ofgem would need to review whether it was appropriate for a company
to recover all or some of the costs associated with meeting the
compensation claims. This could be based on an assessment of the
company's performance both in terms of designing and maintaining
the network and restoring customers' supplies once they had been
interrupted, including the extent to which delays in restoration
were beyond the companies' control.
50. Ofgem is currently working on developing the detail
of the interim arrangements and considering alternative approaches
such as rules relating the proportion of compensation recovered
to the time taken to restore customers' supplies.
Arrangements for 2005-10
51. As part of the price control review process Ofgem
is reviewing quality of supply incentives and Standards of Performance
generally, including the exemptions regime, to seek ways of providing
more clarity and improved incentives to companies.
52. Ofgem has commissioned a customer survey to assess
customers' expectations of performance and willingness to pay
for improvements. Fieldwork has now been completed for the first
phase of this survey and Ofgem intends to publish the findings
in September 2003. The second phase of the survey, which will
include the detailed assessment of willingness to pay for improvements,
will be conducted in early 2004 and the results published in May
2004.
53. Ofgem has appointed consultants to review the technical
characteristics of previous exceptional events. The consultants
have collected extensive data from distribution companies in respect
of previous events, to ensure that revised arrangements are appropriate
for a range of circumstances, and not just for those that occurred
in October 2002. In addition, Ofgem and its consultants have held
initial discussions with distribution companies and the Met Office
about establishing a link between the weather and the impact of
an event with a view to strengthening incentive arrangements.
54. Ofgem has also begun a process for requesting and
analysing cost projections from the distribution companies as
part of the DPCR4 work programme. As recommended in the BPI report,
this will include an assessment of the costs and benefits of additional
undergrounding and accelerated upgrading of overhead lines.
55. Ofgem is also reviewing the regulatory arrangements
for provision of information by companies to customers, in the
light of:
(a) the experience under the IIP arrangements;
(b) the failings of some companies in this regard in the
October 2002 storms; and
(c) the importance placed on information by customers
as demonstrated by the customer survey.
56. In line with the overall price control review timetable,
in the summer and autumn of 2004 Ofgem will expect to discuss
changes to the relevant Statutory Instrument setting out the Guaranteed
Standards of Performance with the DTI and propose licence modifications
to have effect from 1 April 2005. In the event of difficulties
in implementing interim arrangements it may be appropriate to
bring this timing forward.
F. CONCLUSIONS
57. The October storms led to an unprecedented number
of determinations and highlighted weaknesses in the current Standards
of Performance arrangements such as delays in payment of compensation.
58. Ofgem believes that a better mechanism is required
for handling such events in future. This should involve more rapid
payment of compensation to customers who are badly affected and
an agreed mechanism to assess how much of the cost should be passed
through to customers in general.
59. In Ofgem's view the storms did not demonstrate any
major weaknesses in the overall regulatory framework or in the
incentives for distribution companies to invest. The evidence
suggests that differences in performance are explained more by
management and organisation than any lack of investment. As part
of DPCR4, Ofgem is reviewing the incentives on companies regarding
storm resilience generally and the provision of information to
customers and expects to develop proposals to improve the regulatory
framework in these areas.
10
The distribution companies that were affected by the October
storms were: EDF (Eastern), EDF (Seeboard), Aquila, SP Manweb,
WPD (South-West), WPD (South-Wales), East Midlands Electricity,
Southern and United Utilities. Back
11
"2001-02 Electricity Distribution Quality of Supply Report",
Ofgem, June 2003 (Ref 51/03). Back
12
"Quality of Electricity Supply: Initial Benchmarking on
Actual Levels, Standards and Regulatory Strategies", Council
of European Energy Regulators, April 2001. Back
13
"Department of Trade and Industry-Resilience of Electricity
Transmission and Distribution Systems2, British Power International,
May 2002. Back
14
"Asset Risk Management Survey-Composite Industry Report",
December 2002, British Power International, ERA Technology, Mott
MacDonald. Back
15
"Review of Public Electricity Suppliers 1998 to 2000-Distribution
Price Control Review Final Proposals", Ofgem, December 1999. Back
16
"Electricity Distribution Price Control Review-Initial Consultation",
Ofgem, July 2003 (Ref 68/03). Back
17
"Information and incentives project-Incentive Schemes Final
Proposals", Ofgem, December 2001 (Ref 78/01). Back
18
The process for setting targets, monitoring and auditing performance
against the targets is explained in "Information and incentives
project-Incentive Schemes Final Proposals", Ofgem, December
2001 (Ref 78/01). Back
19
See Regulation 5 in Statutory Instrument 2001 No 3265: "The
Electricity (Standards of Performance) Regulations". Back
20
Time is measured from the point at which the company could reasonably
be expected to be aware of the fault either through the operation
of an automatic device on the network or a customer telephoning
the distribution company's call centre to report the fault. Back
21
See Regulation 17 in Statutory Instrument 2001 No 3265. Back
22
"Developing network monopoly price controls-Update document",
Ofgem, February 2003 (Ref 05/03). Back
23
Ofgem and its predecessor OFFER determined six supply restoration
disputes prior to the October storms. Back
24
Under the standard of performance on supply restoration the first
contravention time is set at 18 hours and then there are further
contravention times after each additional period of 12 hours eg
30 hours, 42 hours, 54 hours etc. Back
25
"Electricity Distribution Price Control Review-Initial Consultation",
Ofgem, July 2003 (Ref 68/03). Back
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