Code Modification Forum Telco/Webex, Wednesday, 19 August 2020
Agenda 1. Review of minutes from last meeting 2. Review of open actions 3. Post Brexit customs declarations 4. GNI Update re Impact of Covid 19 5. Update on Maintenance 6. Gas Quality – Proposed Change Update 7. Code Modification Proposal A087 – New Framework for Suppliers in PPM Market 8. Code Modification Proposal A096/A096A- Data Sharing 9. Code Modification Proposal A101- Extension of Daily Exit Capacity Booking Window 10. Code Modification Proposal A103 – Changes to Shipper Portfolio Tolerances 11. Status of Code Modification Proposals 12. GNI – Notice of intended Code Modification to increase oxygen limit at RNG entry points to tx system 13. Gas and Electricity Interaction 14. GNI Briefing on proposed change to allocation arrangements at Moffat 15. AOB/ Date of next Meeting 2
1. Review of minutes from last meeting • Minutes of CMF meeting of 17 June 2020 were issued on 22 July 2020. • No comments were received 3
2. Review of open actions ID Action Responsibility Status Priority Open C572 Transporter to monitor on ongoing basis the adequacy of the initial 25% Transporter Medium tolerance for RNG Entry Points C575 Transporter to furnish required data to CRU in connection with tariff review Transporter Open High in connection with tariff review in relation to SPC Settings for CNG Offtakes 4
3. BREXIT - Customs Returns Update to the Code Mod Forum 19 th August 2020
Exports from GB to ROI (HRMC) • HRMC recognise that energy moves in a unique way, as a continuous flow, therefore if energy movements are being imported or exported via a pipeline, cable or interconnector (collectively known as fixed transport installations), the FTI operator (GNI (UK) in the instance of exports from GB to ROI) will be responsible for completing the declarations . • From January 2021, HRMC will introduce a bespoke monthly process that allows FTI operators to declare their goods by making an entry into their own records. • Entries into declarant's records will be made over a calendar month and be followed by information submitted to HMRC systems via a supplementary declaration at the end of a monthly period. • From January 2021 until the end of June 2021, these monthly supplementary declarations can be submitted within six months of the movement, though this will require an authorisation to submit supplementary declarations. • From July 2021 all supplementary declarations must be submitted to HMRC by the fourth working day of the following month. 6
Imports from GB to ROI (Irish Revenue) In relation to imports from 3 rd countries, which the UK will become after the end of the transition period, there are • two requirements: • Safety & Security - which is referred to as ENS in the Irish Revenue import procedures manual. The ENS must be lodged in advance of the arrival of the goods, different time limits apply depending on the mode of transport involved . In the case of the ENS the party responsible for lodging the declaration is the carrier (i.e. GNI). In the case of gas by pipeline, the requirement for the ENS is waived and will not be required for gas imports from the UK after the end of the transition period. • Customs Declaration - The Customs declaration must be lodged, at the latest, by the time the goods are presented to customs. The party responsible for lodging the customs declaration is the importer. In relation to the customs declaration Irish revenue expect this requirement to be fulfilled using Entry in the Declarants Records. This means that the importer (i.e. the gas shippers in this instance) will need to record the information relevant to a customs declaration in their own IT systems. • As indicated previously, GNI will not file declarations on behalf of Shippers and this remains the case. • Irish Revenue has recently advised us that engagement thus far between Irish Revenue and the individual gas shippers has been minimal and therefore GNI would encourage all shippers to engage with Irish Revenue to ensure that obligations in this regard are met following the end of the Transition Period. 7
4. GNI Update in relation to Covid 19 impacts • GNI Maintenance and Construction activities are generally returning to normal in line with Government guidelines ‒ Essential activities potentially involving indoor work continue in Laois, Kildare and Offaly (e.g. emergency response) Other indoor or customer contact actives are restricted or suspended ‒ All outdoor activities (maintenance, construction, meter reading …) continue as normal • Demand on the system is strong with areas affected by Covid-19 returned or returning to normal levels 8
Hotel and related sectors are recovering Hotel Laundry 600,000 500,000 450,000 500,000 400,000 350,000 400,000 300,000 kWh 250,000 kWh 300,000 200,000 150,000 200,000 100,000 50,000 100,000 0 0 01/01 01/02 01/03 01/04 01/05 01/06 01/07 01/08 01/09 2020 Allocations 2019 7 day average 2020 Allocations 2019 7 day average 2020 7 day average 2018 7 day average 2020 7 day average 2018 7 day average 9
Demand in key sectors is robust Food and Beverage Pharma 18,000,000 5,800,000 16,000,000 5,300,000 14,000,000 4,800,000 kWh kWh 12,000,000 4,300,000 10,000,000 3,800,000 8,000,000 3,300,000 6,000,000 2,800,000 01/01 01/02 01/03 01/04 01/05 01/06 01/07 01/08 01/09 01/01 01/02 01/03 01/04 01/05 01/06 01/07 01/08 01/09 2020 Allocations 2019 7 day average 2020 Allocations 2019 7 day average 2020 7 day average 2018 7 day average 2020 7 day average 2018 7 day average 10
Gas fired power generation is strong Power 160,000,000 140,000,000 120,000,000 kWh 100,000,000 80,000,000 60,000,000 40,000,000 01/01 01/02 01/03 01/04 01/05 01/06 01/07 01/08 01/09 2019 7 day average 2020 7 day average 2018 7 day average 11
5. Update on Maintenance Activities-2019/2020 Maintenance Days Maintenance Programme Gas Year 2018/2019 Date Duration Entry Points Commentary Station testing, valve check and validations at Cappagh South. 20 th May 2020 1 Bellanaboy Proposed to cancel this as the work will be carried out during the planned entry point outage in August. Odourant injection system planned maintenance. 17 th June 2020 1 Inch Cancelled - unit will be decommissioned as flows at the entry point have ceased. ESD testing at the Corrib Terminal (will be coordinated with the annual Corrib planned maintenance) as 1 Bellanaboy Proposed to cancel this as the work will be carried out during the planned entry point outage in August. 12
6. Qas Quality Update • NSAI Gas Technical Standards Committee (GTSC) • A new committee (TC 11) will support the development of national and international standards in the areas of gas quality including the analysis of natural gas, renewable gas and hydrogen. • Industry were invited to become member of the committee ‒ Good interest shown • GNI will report back to the CMF in relation to the work of the NSAI committee 13
7. Code Mod A087- New Framework for Suppliers in PPM Market • On 21st November, 2018 the CRU issued instruction approving A087 and implementation of a new framework. • The key change is that rather than GNI procuring and negotiating front office service agreements, suppliers will procure their own front office services as of 1 st July 2021. • Working Group, set up under GMARG Terms of Reference, is reviewing the operational and contractual arrangements in advance of the implementation date • GNI have, at Workgroup Meeting on 23 January, presented their proposed contractual pathway • The contractual documentation is under review by Workgroup and existing Front Office Service Providers 14
8. AO96 Data Sharing Agreement/A096A Model Clauses to address a Hard Brexit • A096 -Transporter Proposal – To provide for an updated data sharing regime between Transporter and Shippers to comply with provisions of Data Protection Act 2018 (implementing the General Data Protection Regulation (GDPR) (EU) 2016/679) and to reflect the reality of personal data transfers between the Transporter and the Shippers – REMAINS UNDER REVIEW • A096A – Transporter Proposal – To provide for the transfer of personal data between the Transporter and Shippers based outside the European Economic Area(EEA) through the introduction and application of Model Clauses under a Model Clause Procedure. It is proposed to come into effect on or before the Brexit deadline of 31 October 2019 – THIS HAS BEEN COMPLETED 15
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