Code Modification Forum Ashling Hotel, Dublin Wednesday, 16 January 2019
Agenda (1 of 2) 1. Review of minutes from last meeting 2. Review of Action Items from last meeting 3. GNI Scheduled Maintenance Update – Transporter review of operational procedures when system repair result in issue of Restricted Capacity Day Notices 4. Intra-day Nomination Patterns and Profiles / Cod Mod Proposal A086-Incentives for Intra-day Balancing 5. Biomethane update including update of 1) Cush Project, 2) Code Modification Proposal A091- Modification of oxygen content levels for Renewable Natural Gas (RNG) injected from RNG Entry Points and, 3) Code Modification Proposal A093-RNG Outline Code Modification 6. Code Modification A095 – Adjustment of Daily Imbalance Charges / Code Modification Proposal A094- Changes to Shipper Portfolio Tolerances – Update 2
Agenda (2 of 3) 7. Code Modification Proposal A097- Amendment of Final Allocation Date for LDM Offtake(s), DM Offtake(s), NDM Supply Point(s) and Sub-Sea Offtake from D+5 to M+5 8. Brexit and ROI Gas Market 9. Data Sharing Agreement 10. Shrinkage Gas Update 11. Gas and Electricity Interaction 12. AOB Meeting Schedule for 2019 3
1. Review of minutes from last meeting 4
2. Review of Action Items from last meeting 5
Code Modification Forum – Open Actions ID Action Responsibility Status Priority Transporter Open High C538 Transporter to continue consultation process surrounding intra-day nomination patterns and profiles C567 Transporter to carry out development work on its Website to make it more user friendly Transporter Open Medium for Shipper C568 Transporter to carry out a review of its operational procedures in the event of system Transporter Open High repair resulting in the issue of Restricted Capacity Day Notices to minimise Shipper supply restriction consequences C569 Transporter to carry out analysis of extent of Eirgrid Dispatches during Trading Platform Transporter Open High dead band and formulate scheme to process imbalance charge exemptions C571 Transporter to issue letters to Shippers indicating each respective credit position, issue Transporter Open High Report to CRU, and settle each credit position through the Disbursement Account 6
Code Modification Forum 3. GNI Scheduled Maintenance Update 7
Network Maintenance Update 1. Upstream Operator Maintenance GNI have been advised of the following scheduled Maintenance Upstream of Entry Points: Impact on flows at Planned Timings (Subject Duration Entry/Exit Points Location Nature of Works entry/exit points to change) (days) Affected affected NOTHING TO REPORT 8
2018/ 2019 Maintenance Days Maintenance Programme Gas Year 2018/2019 Date Duration Entry Points Commentary 7th March 2019 1 Bellanaboy Station testing, valve check and validations at Cappagh South. 9th May 2019 1 Inch Odourant injection system planned maintenance 4th Jul 2019 1 Moffat Station testing, valve checks and validations at Beattock and Brighouse Bay compressor station 12th Sep 2019 1 Bellanaboy ESD testing at the Corrib Terminal 9
IT Maintenance Update Nature of Works Planned Timings (Subject to change) Duration (days) Systems Affected Nothing to report Please note the above works/timings/duration are subject to change 10
Code Modification Forum 4. Intra-day Nomination Patterns and Profiles /Code Mod Proposal A086 – Incentives for intra-day Balancing 11
Outline of proposed GNI Modification A086 • Modification Raised by GNI to address concerns that the aggregate system imbalance intra-day is creating operational difficulties. • At times, there are large deviations between the prevailing exit nominations on the system and the prevailing entry nominations. GNI wish to introduce an incentive to encourage more alignment of entry and exit • PROPOSAL: At check points during the gas day (11:00, 17:00, 23:00) a shippers portfolio Nomination Imbalance position will be recorded. • A tolerance will be applied at each point • Worked Example: A shipper has 24 units of Aggregate Exit Nomination at 11:00. ‒ Deemed flow at Exit = (24 units * 6hrs/24hrs) = 6 units ‒ Total Entry Nomination = 4 units ‒ Apply a [10%] tolerance: Adjusted Nomination Imbalance Position Nomination Imbalance Position = (6 * 90 %) – 4 = 1.4 units ‒ The Adjusted Nomination Imbalance Position at the 3 time checks will be added ‒ The total for the day will be multiplied by [SAP] * [x%] 12 ‒ The amounts for each day in a month will be invoiced at month end.
Impact if Code Mod was applied in November 2017 – December 2018 • There was a marked improvement in Shipper Nominations following discussions of the proposed modification at recent code mod forums • However, during Mid February to June late day nominations (attributable to 3 Shippers) has resulted in almost hourly batches late in the gas day, causing operational difficulties once again for both GNI and National Grid • Since July 2018 there has been continued improvement in intraday behaviour 13
Impact if Code Mod was applied in November 2017 – December 2018 600,000,000 500,000 Intraday Imbalance Nov 2017 - December 2018 450,000 500,000,000 400,000 350,000 400,000,000 300,000 kWh Euro 300,000,000 250,000 200,000 200,000,000 150,000 100,000 100,000,000 50,000 - - 14 Sum of MONTHLY TOTAL (kWh) Sum of TOTAL MONTHLY PRICE
Code Modification Forum 5.Biomethane Code Modifications/ Biomethane Project • Code Modification Proposal A091-Modification of oxygen content limits for Renewable Natural Gas (RNG) – Legal Drafting Approved • Code Modification Proposal A093 – RNG Outline Code Modification – Legal Drafting Approved 15
Code Modification Forum CUSH PROJECT Commissioning of the Cush Biomethane Network Entry Facility will be completed once GNI receives confirmation of acceptance of Safety Case from CRU 16
Code Modification Forum 6.Code Modification Proposal A095- Adjustment of Daily Imbalance Charges/Code Modification Proposal A094- Changes to Shipper Portfolio Tolerances UPDATE 17
Code Modification Forum Code Modification Proposal A097 – Amendment of Final Allocation Date for LDM Offtake(s), DM Offtake(s), NDM Supply Point(s) and Sub-Sea Offtake from D+5 to M+5 18
Code Modification Proposal A097 • AMENDMENT OF FINAL EXIT ALLOCATION DATE • MODIFICATION PROPOSER : GAS NETWORKS IRELAND • PURPOSE : TO AMEND THE FINAL ALLOCATION DATE IN RESPECT OF LDM OFFTAKE(S), DM OFFTAKES, NDM SUPPLY POINT(S) AND SUB-SEA OFFTAKES FROM D+5 TO M+5 (i.e. 5 CALENDAR DAYS AFTER MONTH END) 19
Code Modification Proposal A097 • Present Position • Sect.2.9.2 of Part D of Code provides that “ The Transporter shall make available to Shippers the Final Allocation in respect of a Shipper’s LDM Offtake(s), DM Offtake(s), NDM Supply Point(s), and/or the Sub- Sea Offtake by 16:00 hours on D+5” • Meter cleansing takes place at the start of a calendar month for a preceding month which is after D+5 • Transporter cannot correct billing issues uncovered after D+5 other than as a cumulative month end adjustment which is not date specific and hinders Shippers in detailing their customer invoices 20 |
Code Modification Proposal A097 • Effect of Proposal Implementation • GNI will be able correct metering issues as they arise, adjust the metered quantity for the day, reallocate and issue more accurate monthly allocation statements/invoices to Shippers • Shippers will be able to issue accurate statement/invoices to customers and will not have to obtain subsequent account adjustments. 21
Code Modification Proposal A097 • Three Industry queries received and two have been responded to by GNI. • Third query will by discussed by GNI with Industry querist before end January • Note of queries and responses will be furnished by GNI to CRU before next CMF Meeting 22
Code Modifications - Live Number Title of Proposal Proposer Status A085 Profiling of Gas Flows at Entry Points IOOA Live/Parked A086 Intra-day Nomination Incentive Proposal GNI Not yet issued A087 New Framework for Suppliers in PPM Market GNI Live/Legal Drafting A090 Proposed new Invoice Dispute Resolution Procedure BGES Live/ Parked A091 Modification of oxygen content limits for Renewable GNI Live Natural Gas (RNG) injected from RNG Entry Points A092 GNI Trading Platform participation GNI Live/Legal Drafting A093 RNG Outline Code Modification GNI Live/ Legal Drafting A094 Changes to Shipper Portfolio Tolerances GNI Live/Consultation A095 Adjustment of Daily Imbalance Charges GNI Live/ Consultation A096 Data Sharing Procedures GNI Not yet issued A097 Amendment of Final Allocation Date from D+5 to M+5 GNI Live 23
Code Modification Forum 8. Brexit and ROI Gas Market 24
Code Modification Forum 9 . Data Sharing Agreement Update 25
Data Sharing Agreement • GNI has consulted its external legal advisors. • GNI intends to mitigate the “Double Jeopardy” issue by proposing modifications to Part B – General Principles which addresses priority between licences, Code etc. • GNI is working to develop drafting, within the Code, to implement the agreed provisions from Draft DPA. • GNI will prepare potential drafting and circulate. 26
Code Modification Forum 10. Shrinkage Gas Update 27
Code Modification Forum 11. Gas / Electricity Interaction 28
Code Modification Forum 12. AOB 29
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