Code Modification Forum Ashling Hotel, Dublin Wednesday, 31 - PowerPoint PPT Presentation

Code Modification Forum Ashling Hotel, Dublin Wednesday, 31 January 2018

Agenda (1 of 2) 1. Review of minutes from last meeting 2. Review of Action Items from last meeting 3. General Items Update 4. GNI Scheduled Maintenance Update 5. Code Modification Proposal ‒ A083 Interruptible Capacity at Non IP Entry Points 6. Intra-day Nomination Patterns and Profiles 7. Code Modification Proposal : A086 – Intra-day Nomination Incentive Framework 8. Balancing 2

Agenda (2 of 2) 9. VRF Tariffing Structure 10. Gas Electricity Interaction 11. BrExit and ROI Gas Market 12. Transparency Data 13. Code Modification Proposal A087- Implementing a new framework for Suppliers to contract their own payment channels for PPM customers 14 Code Modification Proposal A088 – Implementing a Capacity Conversion Service for Shippers 15 AOB Next Code Modification Forum Meeting 3

1. Review of minutes from last meeting 4

2. Review of Action Items from last meeting 5

Code Modification Forum – Open Actions (Slide 1 of 2) ID Action Responsibility Status Priority Open High C530 Release revised Version 5.02 of the Code of Operations which reflects any outstanding Transporter Code Modifications approved by the CER subsequent to the 1 St October 2015 C538 Transporter to continue consultation process surrounding intra-day nomination patterns Transporter Open High and profiles Open Medium C539 Transporter to further provide timelines of next steps to further review and consult on Transporter potential amendments to cashout prices and tolerances, after finalisation of the tender process to secure a Trading Platform Service Provider. Industry to provide its views on potentially amending the 2 Nd tier imbalance multipliers Propose to C548 Industry High close (75% and 125%) previously introduced via Code mod A074 6

Code Modification Forum – Open Actions (Slide 2 of 2) ID Action Responsibility Status Priority C543 Transporter to consider feedback from Shippers concerning the proposal agreed with the Upstream Propose to High close parties to the Bellanaboy Administration Agreement before notifying the parties to send the Operator(s) required instruction letter to GNI Open C552 Transporter to circulate a draft Bilateral Contract for industry consultation Transporter High C553 Industry to provide feedback on draft Bilateral Contract, once circulated Industry Open High C554 Industry to provide response(s) specifying any fundamental changes to the key principles of Industry Propose to High the Proposed Amended VRF Business Rules and specifying how much booked capacity would close be available C555 Transporter to issue individual intraday data to Shippers to help them evaluate impact of Transporter Propose to High Transporter’s Proposal close C557 Transporter to review proposal to appoint a Residual Shipper for intraday nominations Transporter Propose to Medium close 7

Code Modification Forum 3. General Items Update 8

Code of Operations 5.02 • Version 5.02 will be released in due course, to reflect: ‒ Code Mods A071, A079, A080, A081 and A082 (all of which have been approved by the CRU). 9

Code Modification Forum 4. GNI Scheduled Maintenance Update 10

Network Maintenance Update 1. Upstream Operator Maintenance GNI have been advised of the following scheduled Maintenance Upstream of Entry Points: Entry/Exit Impact on flows at Planned Timings (Subject Duration Location Nature of Works Points entry/exit points to change) (days) Affected affected 11

2017/ 2018 GNI Proposed Maintenance Days Maintenance Programme Gas Year 2017/2018 Entry Date Duration Commentary Points 1 day Corrib Not required 7th Feb 2018 1 day Inch Not required 1 day Corrib Not scoped yet. 9th May 2018 ILI run between Inch, Lochcarrig Lodge and Caherlag. Date to be finalised with pigging contractor/Odorant tank 1 day Inch refill at Inch. Zero flow whilst this takes place. 1 day Corrib Fuel gas skid connection at Cappagh South. May not affect flow 4th Jul 2018 1 day Inch Not scoped yet 1 day Corrib Not scoped yet 12th Sep 2018 1 day Inch Not scoped yet Note: Dates and maintenance programme may be subject to change 12

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 13

Code Modification Forum 6. Code Modification Proposal A083: ‘Interruptible Capacity at Non IP Entry Points’ 14

A083: Update from Upstream Operator Action Item C543: Transporter to consider feedback from Shippers concerning the proposal agreed with the parties to the Bellanaboy Administration Agreement before notifying the parties to send the instruction letter to GNI • No Industry feedback received • GNI have notified Bellanaboy Administration Agreement parties that it is awaiting instruction letter 15

Code Modification Forum 6. Intra-day Nomination Patterns and Profiles 16

Outline of proposed GNI Modification • 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 • E.g. 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%] ‒ The amounts for each day in a month will be invoiced at month end. 17

Impact if Code Mod was applied in November / December 2017 • Assume 10% Exit Tolerance and charging of 5% of SAP • November ‒ 8 shippers would have received charges ranging from € 365 to € 148k ‒ Total charges: € 334k ‒ 92% of charges attributable to 3 shippers • December ‒ 5 shippers would have received charges ranging from € 17 to € 124k ‒ Total charges: € 162k ‒ 96% of charges attributable to the same 3 shippers 18

Action Item C556 – Transporter to issue individual intraday data to Shippers to help them evaluate impact of Transporter’s Proposal GNI has furnished relevant Shippers with this data 19

Transporter to review proposal to appoint a Residual Shipper for intraday nominations GNI Response • No legal concept of ‘Residual Shipper’ • Shipper cannot purport to make nominations/renominations to gas to which it has no title • INFR applies so if a ‘ R esidual Shipper’ nominated gas early in a Day this could not be zeroed out later in the day 20

Industry Response to GNI Presentation at CMF Meeting at CMF Meeting on 6 December 2017 including A086 Code Modification Proposal IOOA Response IOOA are broadly in support of GNI’s initiative in this area. They consider the first step is to reduce the second tier imbalance multipliers . They query whether this proposal constitutes zipping on a six hourly basis. They consider and comment on the three scenarios in the GNI presentation. They note that the check point calculations consider metered exit flows and not metered entry flows and that the tolerance should be applied to the overall nomination. They state that the Proposal does not clarify how nomination lead times will apply and how such lead times will influence the Proposal. They look forward to working with GNI in the development of the Proposal to resolve the intra-day nomination profile issue. Aughinish Alumina Response Aughinish Alumina agree with the Proposal. They state that it is not an unreasonable request for Shippers to nominate at entry at least what they have flowed at exit , three times a day cont/ 21

Industry Response to GNI Presentation at CMF Meeting at CMF Meeting on 6 December 2017 including A086 Code Modification Proposal (cont’d) - They believe the 1O% tolerance is sufficient and that the aggregate adjusted nomination imbalance position should be (SAP) *(25%) - They do not agree with the sentiment that the 25% second tier imbalance charge is causing late nominations which is a separate issue Energia Response - It is a general response to a specific issue - It exposes gas – fired electricity generators to an increased risk of financial penalty for events outside their control and as such serves no purpose - No evidence has been presented that the increased multipliers have affected Shipper behaviour - While there is a risk of the imbalance arrangements being gamed by certain Shippers it is unclear that the Proposal addresses the issue or is an appropriate or proportionate response - The issue of Shipper behaviour is a complex matter and should be the subject of a holistic review and not a piecemeal and /or kneejerk modification 22

Code Modification Forum 8. Balancing 23