ENA Review of ENA Type Test Register for Compliance with G98 and G99
With the increasing up-take in manufacturers registering their equipment on the Type Test Register, DNOs and ENA have become aware that many of the declarations of compliance in the register are not complete or appear to have inconsistencies in the information that has been declared as meeting the requirements of G98 or G99. As such, it is not possible to say if the generation equipment related to each incomplete declaration is compliant with the law. In response to this observation, ENA has recently initiated a review of the completeness and sensibility of the records in the register. Following the outcome of the review, ENA has flagged up obvious missing information to the relevant manufacturers requesting that they address these issues as a matter of urgency. ENA will be reviewing resubmitted data as part of a wider review of equipment compliance on the register. Please note that the scope of this inital review was not a definitive review of the compliance of generation equipment to G98 and G99.
Following on from the initial review, and in the absence of a 3rd party certification regime, DNOs and ENA remain concerned about the compliance of manufacturers’ equipment to the relevant G98 and G99 requirements. In response to this concern ENA has appointed engineering consultants to undertake a deeper review of the equipment in the database which is set to be initiated in Q4 2019. Currently there are over 900 entries in the ENA register and the process of reviewing these manufacturers’ submissions is a non-trivial task; therefore the review programme is expected to be ongoing until Q3 2020 and is likely to continue until DNOs are satisfied that there are appropriate 3rd party certification bodies offering adequate service to the market.
The scope of the deeper review of compliance is to:undertake a review of the Compliance Verification Reports registered for each device for completeness and accuracy; assess the type test evidence to confirm whether it demonstrates compliance; verify the validity of and whether an equipment certificate has been used to demonstrate compliance; undertake 2 industry workshops to disseminate learnings of how stakeholders can demonstrate compliance; prepare industry guidance on acceptable type testing methodologies.The compliance report is confidential to the manufacturer and ENA members; however, ENA may issue some future guidance on compliance off the back of the consultant’s review.
08 October 2019