Interim Measures: Benefits What are the benefits of utilising interim measures? • Allows for gradual transition (1 -5 years) at time of significant change in market • Allows market to adapt to introduction of Bellanaboy as a new Entry Point • Potentially allows for retention of some tolerances (to be phased out by end of interim period) • Allows further time to establish most appropriate platform option • Allows time to attempt to foster liquidity at IBP • Allows the focus of TSO and Industry efforts towards 2015 to remain on Gas Day, CAM, Nominations, Moffat Agent changes etc..
Way Forward: Why change course now? Industry & CER Feedback • Shipper and CER feedback regarding development of IBP options Benefits of Option 3: Interim Measures Downsides of Option 2: Adjacent Zone • Allows for gradual transition ( 1 – 5 years) at time of significant change in market • Initial investigations into adjacent • Allows market to adapt to introduction of Bellanaboy as a new balancing zone options identified a Entry Point number of significant regulatory • Potential retention of some tolerances hurdles • • Allows further time to establish most appropriate platform Risk of missing 2016 deadline option leading to non-compliance issues • • Allows time to foster liquidity at IBP Committing to Option 2 comes with • a proviso that interim measures Allows the focus of TSO and Industry efforts towards 2015 to may not be considered thereafter remain on Gas Day, CAM, Nominations, Moffat Agent changes etc..
Next Steps: • Split existing A063 Business Rules • Info Provision, Noms, Allocations to go forward for CER approval • Imbalance Charge section to be addressed separately • Partially or entirely as part of ‘interim measures report’ • Balancing platform feasibility to be progressed in tandem with preparation of interim measures report • Transporter to prepare report - Jan / Feb 2015 • Consultation on report - March 2015 • CER to send report to ACER EC - Early April 2015
A064 – ‘ Virtual Reverse Flow: Enhanced flexibility and compliance with EU Network Codes ’
Status Version 2.0 of the VRF Business Rules was published for consultation on the 16 th January ‘ 15; Comments should be returned on or before the 30 th January ’ 15 to: robert.flanagan@gasnetworks.ie & marketarrangements@gaslink.ie
Major Changes in the VRF Business Rules since last presented Clarity Terminology has been amended and improved upon to provide more clarity in Version 2.0 Business Rules;
Major Changes in the VRF Business Rules since last presented Interruption hierarchy Amendment Valid VRF Nomination/Re-Nominations will supersede previous VRF Shipper’s Nomination/Re-Nominations without affecting a position in the interruption hierarchy - clause 1.3.12; The purpose of this change is so as not to discourage Shippers from Re- Nominating resulting in a loss of position in the interruption hierarchy;
Major Changes in the VRF Business Rules since last presented Facilitation of Over Nominations VRF Capacity booked on PRISMA that has not been Nominated on will be made available for Over-nomination by other Shippers. This un-nominated VRF Capacity will be referred to as Unutilised Booked VRF Capacity; If the original Shipper then decides to Nominate on their Unutilised Booked VRF Capacity, subsequent Nominators of the unutilised will be Reduced by the Transporter ; A Reduction of Unutilised Booked VRF Capacity is not proposed to be defined as an Interruption ; Deemed levels of VRF will be recognised up to the effective time of the Reduction
Major Changes in the VRF Business Rules since last presented Bookable VRF Capacity Formula Clarity added to Bookable VRF Capacity formula; “ Bookable VRF Capacity = ROI Forward Flow – Minimum Forward Flow” - clause 3.2.4; The definition for Minimum Flow is now “… a minimum quantity required to ensure physical flow in respect of operational requirements”
Physical Flows at the Moffat IP Work is ongoing by Asset Management on the impact of Corrib on the physical flows at Moffat. An independent check is currently being carried out and the findings will be presented at the next Code Mod Forum of the 3 rd March.
A065 – Financial Security Policy amendments arising from introduction of Capacity Allocation Mechanisms (Regulation 984/2013)
Code Modification Proposal Presentation Financial Security Policy amendments arising from introduction of Capacity Allocation Mechanisms (Regulation 984/2013) Code Modification Number: A065 Proposer: Gaslink 8 th January 2015 Submission Date:
Introduction Code Modification Code Modification A065 Proposal Title and Financial Security Policy amendments arising from introduction Number of Capacity Allocation Mechanisms (Regulation 984/2013) Part C: Capacity; Proposed sections of Part I: Legal and General; the Code to be Financial Security Policy FS01 v3.0; Modified Short Term Product Financial Security Policy v1.0. There may be consequential changes to other areas of the code. A presentation on the changes to the Financial Security Policy will be Procedure made at the Code Modification Forum on the 21 st January 2015 and Version 1.0 of the proposed business rules will be issued to Industry for consultation in the week following the meeting.
Purpose of the Proposal To define the Business Rules required to implement changes to the Financial Security Policies FS01 and ‘Financial Security Policy for Short Term Products ’ as a result of the implementation of the EU Network Codes on Capacity Allocation Mechanisms (CAM) and Balancing. Scope Based on the CAM Network Code, the Balancing Network Code and the draft ‘Interoperability and Data Exchange’ Network Code. The CAM Business Rules have been completed and approved by the CER. Version 2.0 of the Balancing Business Rules have been completed and are being reviewed by the CER.
RECAP: CAM Key Features Standard Capacity • Annual (up to 15 years), Quarterly , Monthly, Daily, Within-Day Products Capacity Auctions • Capacity sold via auction – level of demand (Joint Booking Platform) determines clearing price • Standardised EU-wide auction calendar • Entry and Exit Capacity at both sides of an IP is Bundling of Capacity ‘bundled’ together and sold as a single product • Gas day 05:00 - 04:59 UTC (currently 06:00 – Change to Gas Day 05:59)
RECAP: CAM Auctions Product Bundled Auction Auction Start Product Start Time First PRISMA (Default) Auction* Frequency Monday 7 th March 1 st Monday in March • 1 October Annual Annual 2016 • 1 October • 1 January Monday 6 th June 1 st Monday in June Quarterly Annual 2016 • 1 April • 1 July 16 th November 3 rd Monday in • 1 st of each month Monthly Monthly 2015 for December preceding month 2015 15:30 on 31 st • 05:00 D October 2015 for 1 st Day-Ahead Daily 15:30 D - 1 November 2015 18:00 on 31 st October 2015 for 18:00 D – 1 • 05:00 D Within-Day Hourly 05:00 on 1 st November 2015 * Based on the recommended dates in the Regulation but subject to confirmation by ENTSOG
Financial Security Required to be in place: FS Required FS Required at Existing Level of FS CAM Level of FS Product at time of time of Product Required Product Required booking Auction ? Multi- 72 days N/A N/A Annual * Annual 72 days 0 % Quarterly N/A N/A N/A 0 % Monthly 100% 100% 100% to be Day-Ahead put in place 100% after booking 100% to be Within-Day put in place 100% after booking * Annual Products can be booked for the next 15 years at the PRISMA Auction
PRISMA Financial Security Process PRISMA uses a system of Credit Limits to implement Financial Security. PRISMA maintains a dynamic Credit Limit for Shippers based on an initial Credit Limit notified to PRISMA by the Transporter. The Transporter will upload a Credit Limit to PRISMA for each Shipper based on the Shipper’s existing Financial Security with the Transporter. The Shipper will determine the amount of their Security to be allocated to PRISMA. Before updating PRISMA, the Transporter will ensure that the Financial Security will be in place for a sufficient period of time for the Transporter.
Invoice and Payment Schedule Invoices are issued to Shippers the month after which the Capacity was used. Action Timeline Invoice Issued 12 Business Days into Month after the Month in which Capacity was used Payment Due 12 Calendar Days after Invoice Date OR 2 Business Days prior to Month End; Whichever is later FS Drawdown Can take place 5 Business Days after Due Date
Proposal for Long Term Products Product Auction Date Product Effective Date 1 st Monday in March 1 st October Annual 1 st Monday in June 1 st October Quarterly 1 st January 1 st April 1 st July Financial Security will Not be required at the time of the Auction. The Shipper will be required to put Financial Security in place before the effective date of the product. Financial Security should be in place 10 days before the Auction for a Monthly Product with the same effective date as the Long Term Product. The Shipper will be required to put sufficient Financial Security in place to cover 72 days worth of Capacity bookings (same as current arrangement).
Long Term Product Financial Security Cycle Long Month Term Month M M-1 Auction Long Term Monthly Auction – Auction - 3 rd Monday 1 st Monday in March Financial Product No Financial Effective Day Security Security 1 st of Month Required to Required be in place 10 Days
Proposal for Short Term Products Product Auction Date Product Effective Date 3 rd Monday of Previous 1 st day of Month Monthly Month Day - Ahead Previous Day Effective Day Within - Day Hourly Basis within Day Effective Day It is proposed that full Financial Security should be in place on the PRISMA Platform prior to commencement of the Auction. The Shipper will be required to assign sufficient Financial Security from GTMS to PRISMA. The PRISMA platform will check the Shipper’s available credit against the Capacity being purchased prior to commencement of an auction. In the event that sufficient credit is not in place, the Shipper’s bid will be rejected. The Financial Security will need to remain active for a defined number of days based on the period of exposure for the Transporter or until payment of the Invoice.
Daily Auction Cycle – Maximum Period of Exposure Month Month Month Month M-1 M M+1 M+2 Product Invoice Auction Active Last Day 1 st M 12 Business Later of: 5 Business Month M-1 Days into Days after 2 Business new Month Due Date Days prior to Month End OR 12 Days after Invoice Maximum Number 71 Days of Calendar Days 1 Day 31 Days 17 Days 14 Days 8 Days
Monthly Auction Cycle – Maximum Period of Exposure Month Month Month Month M-1 M M+1 M+2 Product Active Invoice Auction 3rd Monday 12 Business Later of: 5 Business Days into Days after 2 Business new Month Due Date Days prior to Month End OR 12 Days after Invoice Maximum Number 86 Days of Calendar Days 16 Days 31 Days 17 Days 14 Days 8 Days
Non – Interconnection Points Proposal The products offered at Non- Interconnection Points(Exit Points and indigenous Entry Points) will not change as a result of the implementation of the CAM NC. The Financial Security requirements at these points for Annual and Monthly products will remain unchanged. For Daily products, full Financial Security will need to be in place prior to the confirmation of the booking. Product Type Financial Security Required When? Requirement Annual & Multi-Annual 72 days worth of Capacity M-8 Days Monthly 1 Month of Capacity M-8 Days Daily 1 Days worth of Capacity FS Required at time of confirmation of Booking
A066 – ‘ EU Network Code Implementation: Transitional Arrangements ’
Code Modification Proposal Presentation EU Network Code Implementation: Transitional Arrangements Code Modification Number: A066 Proposer: Gaslink 9 th January 2015 Submission Date:
Introduction Code Modification Code Modification : A066 Proposal Title and EU Network Code Implementation: Transitional Number Arrangements Proposed 01 st July 2015 Implementation Date Rationale for Regulation EU 312/2014 (Balancing) and Regulation EU Implementation Date 984/2013 (CAM) have implementation dates of 1 October 2015 and 1 November 2015 respectively, however a number of transitional arrangements need to be implemented in advance of this date to ensure a stable transition process. Part C: Capacity Proposed sections of Part F: Administration the Code to be Modified In addition there may be consequential effects on other areas of the Code as a result of this modification.
Intended Outcome for this Modification Transitional Capacity Arrangements at Interconnection Points • Annual Capacity - Allow capacity for the period up to 30th September 2016 • Daily Capacity - Last 7 days prior to first booking on PRISMA Voluntary Bundling • Process will be clarified - joint process with adjacent TSO • The time period will be confirmed Registration Process • At Interconnection Points • General (Enduring) process • Transitional stage registration process • At points which are not Interconnection Points • Changes to registration process Moffat Agent • Phasing out transitional process
Background • Regulation EU 984/2013 (Capacity Allocation Mechanisms) • Also Regulation EU 312/2014 (Balancing) • CAM Business Rules A062 – CER approved, issued 16th October 2014 • Main CAM modifications covered in A062 • Additional detail firmed up in this modification (A066): • Transitional Capacity Booking arrangements (annual & daily) • Voluntary Bundling • Registration Process: • Registration Process at IPs (PRISMA) - Transitional and Enduring • Registration Process at non-IPs • Moffat Agent Phasing (further to A063 ‘Nominations, Imbalance Charges & Allocations)
Transition Period – Capacity Booking Reference Table Agreed in Code Modification A062 – Business Rules issued Oct 2014 Subject to ENTSOG auction calendar GTMS PRISMA Product Last Capacity booking Last Capacity Effective First CAM Auction First Capacity Effective request on GTMS Date Date Date 05:00 31 st Oct 2015 31 st Oct 2015 1 st Nov 2015 Within-Day 03:00 31 st October 2015 05:00 31 st Oct 2015 31 st Oct 2015 1 st Nov 2015 Day-Ahead 04:59 hours on the Day which is eight days prior to 1 05:00 1 st Nov 2015 1 st Dec 2015 Monthly November 2015 November 2015 Variable 1 st Oct 2016 Annual Sep 2015 March 2016 (as per transitional arrangements) 1 st Oct 2016, 1 st Jan 2017, Quarterly N/A N/A June 2016 1 st Apr 2017, 1 st July 2017
Annual Capacity – Transition Phase Gas yr Gas yr Gas yr 2015 2016 2017 Booked On Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr PRISMA A A n/a n/a n/a n/a n/a n/a GTMS B Capacity ending within this period
Annual Capacity – Transitional Booking Arrangement Agreed in previous Modification A062 • “In August / September 2015 , the Transporter will request each Shipper with existing Annual Capacity Bookings at Interconnection Points, which has an end date between [1 st October 01 2015 and 1 st October 2016] to advise whether it wishes to” request: an extension of the end date to 30 th Sept 2016 (for same Capacity amount) a. b. request a new Annual Capacity booking to be created with an end date of 30 th Sep 2016 (may be for a different capacity amount than the existing booking) c. no action be taken Proposed added detail in this Modification (A066) • Define date that Transporter will request shipper’s preference • Define window within which Shipper must respond to Transporter with preference • Define the communication route
Entry Point Transfers • Section 5.1.1 of the Code of Operations allows for the Transfer of Capacity between two Entry Points. • The CAM Network Code will require all Capacity at the Moffat Entry Point to be bundled with Capacity from National Grid in the UK. • Based on the CAM Business Rules Version 3.0, Approved by the CER on the 16 th October 2014, Entry Point Transfers involving the Moffat Entry Point will no longer be available from the 1 st November 2015, once the CAM Network Code has been implemented. • This is of particular importance as Corrib is coming online this year.
Daily Capacity – Seven Day cut over period Current Situation • Code Part C 1.1.40: Daily Capacity Booking Window on GTMS is from 06:00 on D-7 . To 03:00 on D Agreed in previous Modification A062 GTMS PRISMA Last Capacity Last Capacity First CAM Auction First Capacity Product booking request on Effective Date Date Effective Date GTMS 03:00 31 st Oct 2015 05:00 31 st Oct 2015 31 st Oct 2015 1 st Nov 2015 Day-Ahead Proposed added detail in this Modification (A066) Capacity Booking Window for Daily Capacity will be changed from [ 24 th October 2015 ] for • last 7 days on GTMS • To ensure Shippers may book Daily Capacity on GTMS [ only up to ] first capacity effective booked on PRISMA [05:00 on 1 st November 2015].
Voluntary Bundling Requirement for Voluntary Bundling • Regulation EU 984/2013 - CAM (Art 20) Agreed in previous Modification A062 • Shipper with Entry or Exit Capacity booking at an IP with an end date which extends beyond [ 30 th September 2015 ] • May submit a ‘Bundling Request’. No later than [ 60 days ] prior to the start of the bundling period • Single EIC is required Proposed added detail in this Modification (A066) • Define the bundling request window for the Voluntary Bundling to Shippers • Which Transporter to approach with booking request is clarified • Process for Transporter and Adjacent Transporter to communicate is clarified • Window for Transporter to notify adjacent Transporter of bundling request is clarified • Response time from Transporter’s receipt of bundling request from adjacent Transporter is clarified • Define phasing out of unbundled capacity
Registration Process Agreed in previous Modification A062 • Enduring PRISMA Registration process (outline) Proposed added detail in this Modification (A066) • Enduring Registration process at Interconnection Points (detailed): • Transitional Registration Process at Interconnection Points: • Enduring process adapted to reflect transition to PRISMA in Oct / Nov 2015 • Timelines re registration with adjacent TSO, EIC Codes, PRISMA training etc. • Registration Process at non-Interconnection Points: • Current Code requirement for Shipper to have min 1kWh long term booking in order to make short term bookings • Not feasible with new auctions, therefore new registration process required for all points on network
Moffat Agent Phasing Out & Additional Modifications • Referred to in previous Modification A063 ‘Nominations, Imbalance Charges & Allocations’ • Transporter / Moffat Agent will schedule a dedicated workshop to present details of transition period • Outline of initial proposals on following slides
Moffat Agent Transition Nominations: • Moffat Agent will match nominations up until (and including ) Gas Day 30 September • Last matching run by MA will be at 01:00 on 1 October (i.e. latest renominations for the Gas Day 30th Sept) • TSOs will commence processing nominations at 13:00 on 30th September • i.e. D-1 Nominations for Gas Day 1st October 60
Moffat Agent Transition Allocations: • Moffat Agent will perform Allocations up until (and including) Gas Day 30th September • Allocations ‘Close - out’ under the MAA rules runs to D+5 • Shippers can submit change requests and MAA can perform reallocation up to close- out • Close-out (for Gas Day September 30th) will be at 16:00 on 5th October • TSOs will perform allocations for Gas Day October 1st and thereafter • Allocating whole, in line with the OBA • OBA to commence allocating steering difference to OBA account for Gas Day commencing 05:00 on 1st October • ‘Overlap’ between 1st October and 5th October • MAA still finishing Gas Days to end September whilst TSOs are allocating for Gas Days post 1st October 61
Shipper Readiness
Market Assurance Process Ensures market participants have project plan in place and assesses progress against the plan Monitors and controls necessary changes implemented by market participants to their own systems Gives confidence to the market that the risk of disruption has been mitigated
Market Assurance Process Initiate phase Scoping: Questionnaire to determine scope of assurance needed Induction: Induction meeting and indicative timeline for completion of assurance related activities Execute phase Project planning assessment: Ensuring formally planned project is in place Internal test programme review: Ensuring market participant’s actions have no adverse effect on market Cross participant test review: Ensuring market participants can successfully interact with central market systems Report phase Final market assessment report : Assurance recommendation to CER
Market Assurance Process Some key dates for shippers Now: Apply for EIC code (Eirgrid: http://www.eirgrid.com/customers/energyidentificationcodeseic/ Feb 2015: Initiate the UK license application process April 2015: Register on PRISMA Q2 2015: PRISMA training
Market Assurance Process 1 st March 1 st Aug 1 st Oct 1 February Go Live 31st 2015 2015 2015 2015 Oct 2015 Execute Initiate Scoping Induction Internal testing Internal test review Cross participant testing Final Market Assessment
PRISMA Registration Process 1 st April 1 st June 1 st Oct 1 February Go Live 31st 2015 2015 2015 2015 Oct 2015 Execute Register EIC code PRISMA registration PRISMA training PRISMA testing
UK Licence Application Process (indicative) 1 July 1 February 2015 2015 5 months Apply for shipper license Sign confidentiality agreement Install IXN equipment Accede to Uniform Network Code Legal opinion Credit limits and security Exit meter registration E-training
4. European Network Code Implementation
5. European Network Code Development
Incremental Capacity Verbal Update
Capacity Auctions Timing Verbal Update
6. Other EU Updates
REMIT
REMIT Update REMIT implementing acts entered into force on 7 th January (Reg. no.1348/2014) Market Participants required to report: Wholesale energy products executed at organised market places by 7 th October 2015 Contracts and derivatives concluded outside and organised market by 7 th April 2016 TSO required to report: Nominations, re-nominations and final allocations and on transportation contracts by 7 th April 16 An Organised Market Place (OMP) must provide a Registered Reporting Mechanism (RRM) to Market Participants that request it GTMS is not an OMP as it doesn’t “ bring together multiple third party buying and selling interests ” Gaslink has no plans to provide an RRM facility to the market place Reporting transactions is the responsibility of the Market Participants
REMIT Registration Process Barry Hussey – Gas Commercial CMF – 21/1/2015
REMIT Implementing Acts published!! • Published on December 17 th 2014, entered into force January 7 th , 2015 • Transaction reporting (standard contracts) to start in 9 months (not six) = October, 7 th 2015 • Reporting of non-standard contracts to start in 15 months (not nine) = 7 th April, 2016
Registration of market participants • By March 17 th , the CER will need to submit to ACER a registry of market participants – Market participants will be required to register via Central Registry of European Market Participants (CEREMP) – A portal to this will be published on the CER website in the coming days, along with a guide to using the platform • CER will return with presentations on next steps (Phase 2 of registration; data reporting)
Who should register? Where to register? • According to Art.2.7 of • According to Art.9.1 of REMIT - REMIT – “Market Participant” means any Market participants entering into person, including transmission transactions which are required to system operators, who enters into be reported to the Agency in transactions, including the placing of accordance with Article 8(1) shall orders to trade, in one or more register with the national regulatory wholesale energy markets authority in the Member State in • Except those under the which they are established or de minimus threshold … resident, or, if they are not established or resident in the Union, Production units below in a Member State in which they are 10MW total output electricity; active. 20MW total output gas.
PHASE 1 Registration process – Step 1 • MPs will first set up their account on CEREMP, accessed via link on CER website
PHASE 1
PHASE 1 Step 3 – Result! The CER will receive email at this point; review details and then confirm MP registration on CEREMP
PHASE 1 Step 4 – Activation email
PHASE 1 Step 5 – Set password
PHASE 1 Step 6 – Log-in token • After successfully changing password, MP will receive a Token (code) via email
PHASE 1 Step 7 – Log-in
PHASE 1
PHASE 1 Step 9 – Natural person information
PHASE 1 Step 10 – Ultimate Controller Information
PHASE 1 Step 11 - Corporate Relationship Just hit ‘Next’ here, this is covered in Phase 2, after March 17 th
Step 11 (Optional) – PHASE 1 Delegated Party Information (for reporting on behalf of the Market Participant)
PHASE 1 Step 12 - Confirmation
Phase 2 – Information relation to corporate structure • Once the initial register is published by ACER (after March 17 th , 2015)… – MPs shall provide information relating to the corporate structure of the market participant. – This information has to be completed within 3 months from the first publication of the European register. • CER will provide further updates on next stages of the process
7. National Grid – UK Shipper Registration Process
Brief History of Xoserve
Background to Xoserve Founded 1 st May 2005 • • Jointly owned by the five major gas distribution network companies and National Grid’s gas Transmission business. • Manages the complex interfaces and transactional services between the major gas transporters operating in Britain and their customers, the gas shippers. • Provides key services that support the contractual and licence obligations of the major gas transporters.
Distribution Networks
The role of Xoserve within the industry Obligation Source Recipients Gas Act Shippers Uniform Suppliers Network Code Meter Asset Non Regulated Managers Others Utility Act Agency Services Network Operators Agreement Service Delivery
Customer Lifecycle Activities 1 User Admission 3 2 Terminations & CUSTOMER LIFE CYCLE User Changes & Voluntary ACTIVITIES Amendments Discontinuance
Role of the Customer Lifecycle Team • To co-ordinate the end to end process to facilitate Shipper/Trader User entry & exit as a User under Uniform Network Code including any business changes they may undergo through the company’s lifetime. • Ensure all interested parties are informed of; & undertake any actions required to support the end-to-end process.
User Admission Steps * A Shipper User must be granted a Shipper licence before going live. A Trader User does not require a licence Go Live * * A copy of the Uniform Network Code can be obtained from http://www.gasgovernance.co.uk/UNC System Accounts, XP1 & Gemini E-Training * * A Legal Opinion is required for all Legal Opinion companies registered outside of England and Wales and allows a Obtain copy of Uniform Network Code disagreement/breach to be rectified through that country’s legal system Accession Agreement IXN Equipment (£13,359 or £762 + VAT if configuration) Credit Limit (Energy and Transportation) Confidentiality Agreement & IXN Agreement Customer Application Form and User Admission Fee (£3,010+VAT) Apply for a Shipper Licence if involved in the conveyance of gas*
Changes and Amendments • Change of Contact Details • Company Name Changes • Takeovers & Mergers • Equipment moves & changes
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