Code Modification Forum Telco/Webex, Wednesday, 19 August 2020 - - PowerPoint PPT Presentation

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

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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

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2. Review of open actions

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ID Action Responsibility Status Priority C572 Transporter to monitor on ongoing basis the adequacy of the initial 25% tolerance for RNG Entry Points Transporter Open Medium C575 Transporter to furnish required data to CRU in connection with tariff review in connection with tariff review in relation to SPC Settings for CNG Offtakes Transporter Open High

• 3. BREXIT - Customs Returns

Update to the Code Mod Forum

19th 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.

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Imports from GB to ROI (Irish Revenue)

• In relation to imports from 3rd 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.

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• 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

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Hotel and related sectors are recovering

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50,000 100,000 150,000 200,000 250,000 300,000 350,000 400,000 450,000 500,000 kWh

Laundry

2020 Allocations 2019 7 day average 2020 7 day average 2018 7 day average 100,000 200,000 300,000 400,000 500,000 600,000 01/01 01/02 01/03 01/04 01/05 01/06 01/07 01/08 01/09 kWh

Hotel

2020 Allocations 2019 7 day average 2020 7 day average 2018 7 day average

Demand in key sectors is robust

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6,000,000 8,000,000 10,000,000 12,000,000 14,000,000 16,000,000 18,000,000 01/01 01/02 01/03 01/04 01/05 01/06 01/07 01/08 01/09 kWh

Food and Beverage

2020 Allocations 2019 7 day average 2020 7 day average 2018 7 day average 2,800,000 3,300,000 3,800,000 4,300,000 4,800,000 5,300,000 5,800,000 01/01 01/02 01/03 01/04 01/05 01/06 01/07 01/08 01/09 kWh

Pharma

2020 Allocations 2019 7 day average 2020 7 day average 2018 7 day average

Gas fired power generation is strong

40,000,000 60,000,000 80,000,000 100,000,000 120,000,000 140,000,000 160,000,000 01/01 01/02 01/03 01/04 01/05 01/06 01/07 01/08 01/09 kWh

Power

2019 7 day average 2020 7 day average 2018 7 day average

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• 5. Update on Maintenance Activities-2019/2020 Maintenance Days

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Maintenance Programme Gas Year 2018/2019

Date Duration Entry Points Commentary 20th May 2020 1 Bellanaboy Station testing, valve check and validations at Cappagh South. Proposed to cancel this as the work will be carried out during the planned entry point outage in August. 17th June 2020 1 Inch Odourant injection system planned maintenance. Cancelled - unit will be decommissioned as flows at the entry point have ceased. as 1 Bellanaboy ESD testing at the Corrib Terminal (will be coordinated with the annual Corrib planned maintenance) Proposed to cancel this as the work will be carried out during the planned entry point outage in August.

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

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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 1st 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

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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
• utside 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

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• 9. A101 Amendment to Code of Operations to facilitate the extension of

the Daily Capacity Booking Window

Proposed by ESB Reasons for Proposal;

• Currently the Daily Capacity Booking Window is defined as:
• The period commencing at start of the Day which is seven Days prior to the requested Capacity Booking Effective Date specified in a

request for Short Term Capacity for a duration of a Day, and ending at 03:00 hours on the requested Capacity Booking Effective Date

• Effective Date for Daily Capacity meaning the Day for which the capacity is requested and active

‒ Shippers have incomplete information of capacity requirements at the Exit Point when the window closes ‒ The overrun cost of under-booking can be extremely high

• Even if prudently booking stacks of Annual / Quarterly / Monthly capacity, daily multipliers combined with overrun charges at 4

times Daily Capacity are highly punitive

‒ Therefore there is a tendency to overbook, which leads to inefficiency

• Cost inefficiency from wastage – pass-through to end-users
• Poor quality signals to Transporter

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A101: Possible Options for Consideration

• A. Extend the Daily Exit Capacity Booking Window to coincide with the publishing of the final meter read of the

day by GNI on GTMS

• B. Extend the Exit Capacity Booking Window to end on D+X
• C. Reduce the Exit Capacity Overrun multiplier from 4 to 1
• D. Allocate Exit capacity to Shippers to match their final allocation (“implicit allocation”)

A101 – update

• It is intended to have a specific telco during September to discuss this proposal
• GNI will circulate analysis in relation to the level, amount and type of overruns before and after the reduction of

the multipliers from 8 to 4

• Shippers are encourage to provide information in relation to the application of overruns particularly in

jurisdictions where the electricity sector operates a centrally dispatched model similar to SEM

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11. Status of Code Modification Proposals

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Number Title of Proposal Proposer Status

A087 New Framework for Suppliers in PPM Market GNI Live/ Implementation process review A096 Data Sharing Agreement GNI Live/Under review A099 CNG Supply Point Capacity Setting GNI In abeyance A101 Extension of Daily Exit Capacity Booking Window ESB Live/Under review A103 Changes to Shipper Portfolio Tolerances CRU Live/ Under review

• 12. Oxygen – Upper Limit at Biomethane Entry Point on

Transmission Network

• Code Modification Proposal A091 effective since February 2019
• Appendix 1 of Part G(Technical) of GNI Code of Operations modified i.e.

O2 content for gas derived from Renewable Natural Gas at an RNG Entry Point connected to the Distribution System shall be up to 1 mol%

• GNI plan a Code Modification Proposal to extend to RNG Entry Points on Transmission Network
• Today we are asking Industry if “Biomethane – Oxygen Content Assessment” (carried out prior to A091) requires

further work for the Tx Code Modification Proposal (and, if so, in what areas)

• Feedback before 16 September to Yvette.jones@gasnetworks.ie

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• 13. Gas and Electricity Interaction

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• 14. Consultation on proposed change to allocation

arrangements at Moffat

• Joint consultation by Gas Networks Ireland and GNI(UK) launched on 5 August 2020 in relation to revised

allocation methodology agreed with National Gas Grid . The consultation period is two months.

• The change requires an amendment to the Interconnection Agreement for the Moffat Interconnection Point

between GNI(UK) and National Gas Grid with a consequent amendment to the associated Tripartite Agreement relating to arrangements at Moffat between GNI, GNI(UK) and National Grid Gas.

• National Grid Gas are required to amend their Uniform Network Code to affect this change and are presently

progressing UNC 0720 (Amendments to the Agreed Target Quantity at the Moffat IP)

• The details of the proposal/consultation with the text of the amendments to the Interconnection Agreement

and Tripartite Agreement are on the GNI Transparency Portal at the following link;

https://www.gasnetworks.ie/corporate/gas-regulation/regulatory-publications/moffat-ia-consultation-20/index.xml

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• 15. AOB

Update on Brexit required Customs Returns by Áine Spillane, Brexit Manager at GNI

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Code Modification Forum Meetings in 2020

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CMF Dates 2020 Location 29th January (Wednesday) Dublin 25th March 2020 (Wednesday) Telco/Webex 17th June 2020 (Wednesday) Telco/Webex 19th August 2020 (Wednesday) Telco/Webex 21st October 2020 (Wednesday) Dublin 16th December 2020 (Wednesday) Dublin

Thank you for your participation