Code Modification Forum Ashling Hotel, Dublin Wednesday, 8 August - - PowerPoint PPT Presentation

Code Modification Forum

Ashling Hotel, Dublin Wednesday, 8 August 2018

Agenda (1 of 2)

1. Review of minutes from last meeting 2. Review of Action Items from last meeting 3. GNI Scheduled Maintenance Update –Operational /IT

• 4. Intra-day Nomination Patterns and Profiles / Cod Mod Proposal A086-Incentives for Intra-day Balancing
• 5. Code Modification Proposal A087- Implementing a new framework for Suppliers to contract their payment

channels for PPM customers

• 6. Biogas update including review of 1) Code Modification Proposal A091- Modification of oxygen content levels for

Renewable Natural Gas (RNG) injected from RNG Entry Points and, 2) Code Modification Proposal A093-RNG Outline Code Modification

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Agenda (2 of 3)

• 7. Code Modification Proposal A095- Adjustment of Daily Shipper Imbalance Charges/ Code Modification Proposal

A094 – Changes to Shipper Portfolio Tolerances –Industry Response to Questionnaire 8 . Gas /Electricity Interaction interaction

• 9. Security of Supply Regulation 2017/1938 . Art.14 – Information Exchange
• 10. Data Sharing Agreement
• 11. Brexit and ROI Gas Market
• 12. Transparency Data Update
• 13. Website Feature Update
• 14. Trading Platform Update- GNI Participation
• 15. AOB

Next Code Modification Forum Meeting

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1. Review of minutes from last meeting

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2. Review of Action Items from last meeting

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ID Action Responsibility Status Priority C538 Transporter to continue consultation process surrounding intra-day nomination patterns and profiles Transporter Open High C560 Transporter to draft and circulate and circulate to Industry worked examples on capacity charging Transporter Propose to close High C562 Transporter to furnish Questionnaire to CMF Mailing List with the Minutes of the CMF Meeting on 13 June in relation to proposed changes to the calculation of the cashout price regime/ retention of Tolerances Transporter Propose to close High C563 Transporter to furnish DM and LDM accuracy data in aggregate to the CMF Mailing List and to subsequently answer specific Shipper queries Transporter Propose to close High C564 Transporter to inform KEL, under their OBA, of the proposal to gradually remove the Inch Entry Point Tolerance Transporter Propose to close High C565 Transporter to organise a telco with the CRU and Industry to consider a Modification for the IBP 15 Terms Transporter Propose to close Medium C566 Transporter to circulate to the CMF Mailing List and upload unto its Website the Allowed Revenues and Tariffs for Distribution and Transmission for 2018/19 Transporter Propose to close High

Code Modification Forum – Open Actions (Slide 1 of 2)

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3. GNI Scheduled Maintenance Update

Code Modification Forum

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Network Maintenance Update

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Location Nature of Works Planned Timings (Subject to change) Duration (days) Entry/Exit Points Affected Impact on flows at entry/exit points affected

Bellanaboy Bridge Gas Terminal

Maintenance 10/9/2018-14/9/2018 5 Bellanaboy Entry Point No Flows

• 1. Upstream Operator Maintenance

GNI have been advised of the following scheduled Maintenance Upstream of Entry Points:

2017/ 2018 GNI Proposed Maintenance Days

Maintenance Programme Gas Year 2017/2018 Date Duration Entry Points Commentary 7th Feb 2018 1 day Corrib Not required 1 day Inch Not required 31 May-1June 9 May 1 day Corrib SCADA signal validation testing . Now postponed due to deferment of SEPIL transition date 1 day Inch In-Line Inspection (ILI) run between Inch, Lochcarrig Lodge and Caherlag. Date to be finalised with pigging contractor/Odorant tank refill at Inch. Zero flow whilst this takes place. 4th Jul 2018 1 day Corrib Fuel gas skid connection at Cappagh South. May not affect flow. Now postponed, was scheduled to tie-in with maintenance which is now deferred 1 day Inch Not scoped yet 12th Sep 2018 1 day Corrib Not scoped yet 1 day Inch Not scoped yet

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Note: Dates and maintenance programme may be subject to change

2018/ 2019 Maintenance Days

Maintenance Programme Gas Year 2018/2019

Date Duration Entry Points Commentary 8th November 2018 1 Inch Deferred in line inspection. Risk to flow during intelligent pigging run 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

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IT Maintenance Update

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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

• 4. Intra-day Nomination Patterns and Profiles /Code

Mod Proposal A086 –Incentives for intra-day Balancing

Code Modification Forum

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Outline of proposed GNI Modification A086

• Modification Raised by GNI to address concerns that the aggregate system imbalance intra-day is creating
• perational 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%] ‒ The amounts for each day in a month will be invoiced at month end.

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Impact if Code Mod was applied in November 2017 –July 2018

• There was a marked improvement in Shipper Nominations following discussions of the proposed modification at

recent code mod forums. The estimated monthly financial impact dropped from €334k (November) to €67k (January).

• 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.

• July has seen an improvement in the behaviour of these 3 Shippers

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Impact if Code Mod was applied in November 2017 –July 2018

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NOVEMBER, €334,187.70 DECEMBER, €161,895.41 JANUARY, €67,255.77 FEBRUARY, €115,850.34 MARCH, €252,503.70 APRIL, €264,125.36 MAY, €185,562.38 JUNE, €451,826.77 JULY, €155,892.22

50000 100000 150000 200000 250000 300000 350000 400000 450000 500000 NOVEMBER DECEMBER JANUARY FEBRUARY MARCH APRIL MAY JUNE JULY

Intraday Imbalance Nov 2017 - July 2018

NOVEMBER DECEMBER JANUARY FEBRUARY MARCH APRIL MAY JUNE JULY

Impact if Code Mod was applied in November 2017 –July 2018

• Assume 10% Exit Tolerance and charging of 5% of SAP

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November 2017 December 2017

• 8 shippers would have received charges ranging from €365 to

€148k

• Total charges: €334k
• 92% of charges attributable to 3 shippers
• 5 shippers would have received charges ranging from €17 to

€124k

• Total charges: €162k
• 96% of charges attributable to the same 3 shippers

January 2018

• February 2018
• 5 shippers would have received charges ranging from €18 to

€30k

• Total charges: €67k
• 96% of charges attributable to 3 shippers
• 7 shippers would have received charges ranging from

€15.20 to €72k

• Total charges: €116k
• 93% of charges attributable to 3 shippers

March 2018

• April 2018
• 6 Shippers would have received charges ranging from €86 to

€149k

• Total charges: €252k
• 96% of charges attributable to 3 shippers
• 5 Shippers would have received charges ranging from €23k

to €114k

• Total charges: €264k
• 91% of charges attributable to 4 shippers

Impact if Code Mod was applied in November 2017 –July 2018

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May 2018

• 3 Shippers would have received charges ranging from €30k to

€101k

• Total charges: €186k
• 99% of charges attributable to 3 shippers

June 2018

• 3 Shippers would have received charges ranging from €52k to

€295k

• Total charges: €452k
• 99% of charges attributable to same 3 shippers

July 2018

• 3 Shippers would have received charges ranging from €25k to

€73k

• Total charges: €156k
• 98% of charges attributable to same 3 shippers

Shipper May to June Increase/ Decrease June to July Increase/ Decrease 1 191% Increase 92% Decrease 2 0% Increase 3% Decrease 3 229% Increase 26% Decrease

• 5. Code Modification Proposal A087-,Implementing a

new framework for Suppliers to contract their own payment channels for PPM customers

Code Modification Forum

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A087: Proposal for new contractual arrangements for PPM front

• ffice services
• The front office service providers

(Payzone, An Post) provide a service to gas suppliers and gas customers i.e. they facilitate customers topping-up (vending) and collect money from customers to be subsequently re- distributed to the relevant gas supplier.

• Suppliers pay the front office providers

for the service.

• GNI proposes to change current

arrangements so that Suppliers, rather than GNI, procure and contract for these services.

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Figure: Proposed contractual arrangements

A087: Discussed at GMARG with mixed views from suppliers

Comment

Supplier 1 In favour of proposals Supplier 2 Concern that smaller suppliers and/or new entrants would be disadvantaged Supplier 3 Concern that larger suppliers would be able to negotiate better terms than smaller and concern related to resolution of industry wide issues Supplier 4 Opposed to the proposal

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Table: GNI received 4 written submissions from suppliers

Other issues raised in discussions included

• Contingency
• Timeline for implementation

A087: Discussed at GMARG with mixed views from suppliers

Comment

Supplier 1 In favour of proposals Supplier 2 Concern that smaller suppliers and/or new entrants would be disadvantaged Supplier 3 Concern that larger suppliers would be able to negotiate better terms than smaller and concern related to resolution of industry wide issues Supplier 4 Opposed to the proposal

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Table: GNI received 4 written submissions from suppliers

Other issues raised in discussions included

• Contingency
• Timeline for implementation

A087: Transporter view

• GNI maintains its view that it should not be within the remit of the DSO to procure this

service on behalf of suppliers.

• The risk associated with a single procurement of front offices services, which was

highlighted during the last procurement process, can be lessened by multiple procurements.

• GNI have put in place two front office service providers that suppliers already have existing

relationships with.

• Suppliers should be free to contract with whatever front office providers they can reach a

commercial agreement with and GNI should not be involved in these negotiations.

• GNI accepts it will maintain a co-ordination role across the market.

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6.Biomethane Code Modifications/ Biomethane Project

• Code Modification Proposal A091-Modification of
• xygen content limits for Renewable Natural Gas

(RNG) – under review

• Code Modification Proposal A093 –RNG Outline Code

Modification at legal drafting

• Biomethane Project update will be presented at

September CMF Meeting

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Code Modification Forum

7.Code Modification Proposal A095- Adjustment of Daily Imbalance Charges/Code Modification Proposal A094- Changes to Shipper Portfolio Tolerances- Industry Response to Questionnaire

Code Modification Forum

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Industry Responses to Questionnaire

QUESTION RESPONSE

Q1: What do you believe is the appropriate tolerance level for each category of customer (LDM, DM and NDM)? IOOA response

• LDM 0%,
• DM 0%
• NDM – Tolerance should be the difference between the nomination at the TSO

forecast level and the allocation.

• Argues providing 2.5 % tolerance to NDM Shippers may provide commercial

advantage to NDM Shippers with large NDM portfolios. Manx Utilities response

• fully supports the removal of tolerances.

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These are summary responses only. A copy of the complete responses will be circulated.

Industry Responses to Questionnaire

QUESTION RESPONSE

Q1: What do you believe is the appropriate tolerance level for each category of customer (LDM, DM and NDM)? SSE Airtricity Response

• Broadly supports the removal of tolerances when network users have access to

sufficient information regarding their inputs and offtakes.

• Argues that although there is sufficient information for most of the gas day for

LDM sites, during the dead-band period from 00:45, gas traders must use their

• wn judgement to nominate what is expected for the remaining hours of the gas

day.

• Supports the application of a small tolerance of 2.5% to compensate for the

dead-band period.

• Suggests that a tolerance should be applied to the DM sector given the lack of

metered information available.

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These are summary responses only. A copy of the complete responses will be circulated.

Industry Responses to Questionnaire

QUESTION RESPONSE

Q1: What do you believe is the appropriate tolerance level for each category of customer (LDM, DM and NDM)? BGE Response

• NDM 2.5 %
• DM 10% - Argues that there is no visibility on volumes during the and it is not possible

to accurately predict their final run .

• Suggests a special dispensation for Powergens: they should not be penalised for

changing volumes, as a result of Eirgid, between the period from 00:00 to 05:00, as this is beyond the control of Shippers. Equinor Response

• Believes zero tolerances be applicable for LDM and DM Shippers, and that removal of

these tolerances will boost liquidity at the IBP.

• Suggests that NDM Shippers should receive a tolerance for the difference between

allocations and nominations.

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These are summary responses only. A copy of the complete responses will be circulated.

Industry Responses to Questionnaire

QUESTION RESPONSE

Q1: What do you believe is the appropriate tolerance level for each category of customer (LDM, DM and NDM)? Tynagh Energy Response

• Suggests LDM should have a similar methodology to that of NDM : the absence of

tolerances and associated costs if the participant follows TSO nomination advice. If a generator does not nominate in line with their Eirgrid indicative schedules, tolerances should be applied. ESB Response

• Are not satisfied that conditions Article 50.1 (a),(b) and (c) have been adequately met

and until such time that they are tolerances should be maintained

• Recommends that Power Generators receive similar treatment to that of NDMs, in

relation to instruction from the electricity TSO.

• Recommends keeping tolerances for DMs and that any reduction on the current 30%

needs to be monitored.

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These are summary responses only. A copy of the complete responses will be circulated.

Industry Responses to Questionnaire

QUESTION RESPONSE

Q1: What do you believe is the appropriate tolerance level for each category of customer (LDM, DM and NDM)? Electric Ireland Response

• Believe tolerances should be maintained, that their removal poses a particular difficulty

to the DM Sector, due to lack of access to up to date information. Naturgy Response

• Argues that until there is real time access to all DM sites hourly consumption tolerance

levels should not be amended.

• Argues that as LDM sites have hourly telemetry (and the latest time for submitting

renominations is 02:00) tolerances should be reduced, but not reduced to zero.

• Recommends 10% tolerance for LDM3 and 5% tolerance for LDM2
• Agrees that NDM tolerance could stay at 2.5%

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These are summary responses only. A copy of the complete responses will be circulated.

Industry Responses to Questionnaire

QUESTION RESPONSE

Q2: What are your views as to the appropriate dates for the two-step reduction proposed? IOOA Response

• Questions whether there is time available for a meaningful period of reduced tolerances

and whether a two-step approach is required. Manx Utilities Response

• Suggests removal of tolerances in one-step by August 1st.
• Argues the proposed two step reduction would require additional resources to manage the

difference in tolerances between August 1st and October 1st.

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These are summary responses only. A copy of the complete responses will be circulated.

Industry Responses to Questionnaire

QUESTION RESPONSE

Q2: What are your views as to the appropriate dates for the two-step reduction proposed? SSE Airtricity Response

• Propose a one-step reduction rather than two-step.
• Argues a two-step process would add a layer of complexity, requiring shippers to

amend internal processes following the first step

• Suggest that the following 3 factors must be taken into consideration by GNI,

prior to the removal of tolerances: 1. I-SEM go live 2. Boosting liquidity at the IBP 3. Internal process for Shippers, i.e. 2 months for updating and training.

• Propose an implementation period between December 2018 and February 2019

to allow sufficient time for Shippers to update their internal processes. BGE Response

• Believe that the two steps are too close together.
• Agrees that the first step should be to 50% levels, but the second step to zero

(not including NDM and DM, as per Q1) should be approximately 6 months after the first step.

• Proposed dates:
• Step 1 – October 1st 2018
• Step 2 – April 1st 2019.

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These are summary responses only. A copy of the complete responses will be circulated.

Industry Responses to Questionnaire

QUESTION RESPONSE

Q2: What are your views as to the appropriate dates for the two-step reduction proposed? Equinor Response

• Does not support GNI’s proposal of a two-step reduction in tolerances.
• Believes a two-step reduction introduces an unnecessary layer of complexity.
• Suggests the new tolerances levels should be implemented on 1st October

2018 Tynagh Energy Response

• Disagrees with the proposed methodology, however if it were to be

implemented a phased approach with a long lead in time would be preferable. ESB Response

• Recommends that any reduction in tolerances should be implemented once I-

SEM is live and stable and after the winter period. Suggests requesting from ACER a continuation of tolerances after April 2019. Electric Ireland Response

• Welcome a two-step reduction approach, however suggest a more gradual

removal over a longer period to give users the opportunity to adjust to a non- tolerance regime.

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These are summary responses only. A copy of the complete responses will be circulated.

Industry Responses to Questionnaire

QUESTION RESPONSE

Q2: What are your views as to the appropriate dates for the two-step reduction proposed? Naturgy Response

• Considers a two-step reduction appropriate for the sectors impacted by the

decision.

• Recommends a 12 month period between steps, as it will take some time for

shippers to improve their processes.

• Proposes final implementation date of 1st October 2019.
• Recommends that new entry points should have a “soft-landing” period of 12

months where a tolerance of 5% would be allowed for the difference between nominations and allocations.

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These are summary responses only. A copy of the complete responses will be circulated.

Industry Responses to Questionnaire

QUESTION RESPONSE

Q3: What is your view as to the magnitude of the small adjustment to be used in the calculation of the marginal sell price and the marginal buy price? IOOA Response

• Support the proposed application of IBP SAP or NBP SAP, for First Tier

imbalances.

• Support the proposed 3.5% adjustment, for Second Tier imbalances.
• Suggests that the small adjustment applied should be reviewed on a regular
• basis. The review should determine the following:

1. The net cost of implementing balancing actions on the GNI system 2. Whether the adjustment is cost reflective and appropriate, taking into consideration that the adjustment should be an incentive to balance, not to penalise.

• Recommends that the first review be completed after six months.

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These are summary responses only. A copy of the complete responses will be circulated.

Industry Responses to Questionnaire

QUESTION RESPONSE

Q3: What is your view as to the magnitude of the small adjustment to be used in the calculation of the marginal sell price and the marginal buy price? Manx Utilities Response

• Argues that the GNI proposed small adjustment is too high.
• Suggests a maximum small adjustment of plus or minus 2%

SSE Airtricity Response

• Argues that applying an adjustment which is based on a percentage of SAP could

result in excessive punitive adjustments.

• Suggests that given then link between Irish and GB markets that the application of

a monetary cap would give certainty to Shippers, lowering risk, given the removal

• r reduction of tolerances.
• Also suggests a variation on the above whereby, the small adjustment (in c/therm)

is applied at a level that corresponds to the average of 2.5% of NBP spot prices

• ver a period of 1 year,
• Suggests the above approach would remove fluctuations which would arise where

the small adjustment is linked to the wholesale market.

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These are summary responses only. A copy of the complete responses will be circulated.

Industry Responses to Questionnaire

QUESTION RESPONSE

Q3: What is your view as to the magnitude of the small adjustment to be used in the calculation of the marginal sell price and the marginal buy price? BGE Response

• Believe the adjustment can be set at 3.5%, but should be reviewed after an

appropriate period of time i.e. 3-6 months. Equinor Response

• Supports GNI’s proposal of a 3.5% adjustment, as it is keeping with other European

markets.

• Recommends that the adjustment be reviewed after 6 months of implementation.

Tynagh Energy Response

• Contends the 3.5% stating they are unclear as to how it was calculated.
• Recommends an adjustment of 2%.

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These are summary responses only. A copy of the complete responses will be circulated.

Industry Responses to Questionnaire

QUESTION RESPONSE

Q3: What is your view as to the magnitude of the small adjustment to be used in the calculation of the marginal sell price and the marginal buy price? ESB Response

• Argues that that the proposed adjustment has not been justified with any analysis.
• Suggests an adjustment of 0.5%

Electric Ireland Response

• Considers the adjustment of 3.5% is reasonable as a first step, but suggests that it

should be monitored and changed if necessary. Naturgy Response

• Believes a +/- 2% adjustment is enough of an incentive for shippers to minimise

imbalances.

• Argues that an adjustment above +/-2% could give rise to excessive financial

exposure at current gas prices.

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These are summary responses only. A copy of the complete responses will be circulated.

Industry Responses to Questionnaire

QUESTION RESPONSE

Q4: Do you believe the liquidity threshold criteria provided above are appropriate? IOOA Response

• Is satisfied with the four metrics proposed by GNI.
• Queries what happens if the metrics are not met.
• Queries whether metrics 1 – 3 will be used as a guidance, as the minimum

requirements, before IBP SAP can be published on a day. Manx Utilities Response

• No objections to the metrics proposed by GNI

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These are summary responses only. A copy of the complete responses will be circulated.

Industry Responses to Questionnaire

QUESTION RESPONSE

Q4: Do you believe the liquidity threshold criteria provided above are appropriate? SSE Airtricity Response

• Deem the four metrics proposed by GNI to be appropriate and that metrics 1 – 3

have broadly been met.

• Argues that when the four metrics are not met then the default to the NBP should

apply

• Seeks clarification on the review period specified for metric 4.
• Queries whether the Second Tier sell price should be SAP NBP – 5% minus

Transportation costs, where a valid SAP IBP is not published. BGE Response

• Regard the metrics proposed by GNI to be low and therefore room for

manipulation.

• Recommends that the metrics be constantly reviewed and immediately acted upon

if manipulation is suspected.

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These are summary responses only. A copy of the complete responses will be circulated.

Industry Responses to Questionnaire

QUESTION RESPONSE

Q4: Do you believe the liquidity threshold criteria provided above are appropriate? Equinor Response

• Supports GNI’s proposed liquidity threshold criteria.
• Recommends that the threshold should be reviewed in conjunction with the small

adjustment. Tynagh Energy Response

• Questions what the methodology for the criteria has been based off. Questions if

they are recognised threshold methodologies. ESB Response

• Considers the liquidity measure wholly inadequate.
• Recommends that an independent liquidity assessment be carried out by a

recognised body in European energy trading, such as EFET. Electric Ireland Response

• Considers the liquidity threshold criteria appropriate.
• Recommends that It be reviewed after either a period of time i.e. 1 year, or after a

specific number of trades.

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These are summary responses only. A copy of the complete responses will be circulated.

Industry Responses to Questionnaire

QUESTION RESPONSE

Q4: Do you believe the liquidity threshold criteria provided above are appropriate? Naturgy Response

• Believes the liquidity threshold criteria is appropriate.

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These are summary responses only. A copy of the complete responses will be circulated.

Industry Responses to Questionnaire

QUESTION RESPONSE

Q5: What is the appropriate date for the implementation of the new methodology for calculation of the cashout prices? IOOA Response

• 1st October 2018 and it should coincide with the removal of tolerances.

Manx Utilities Response

• 1st October 2018

SSE Airtricity Response

• Suggests that the new methodology should be applied as soon as possible, in light of

the fact that liquidity at the IBP has been demonstrated. BGE Response

• 1st October 2018, in line with new tolerances.

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These are summary responses only. A copy of the complete responses will be circulated.

Industry Responses to Questionnaire

QUESTION RESPONSE

Q5: What is the appropriate date for the implementation of the new methodology for calculation of the cashout prices? Equinor Response

• 1st October 2018

Tynagh Energy Response

• 1st April 2019

ESB Response

• Recommends implementation after I-SEM is live and stable.

Electric Ireland Response

• Suggests waiting for a larger number of trades to ensure prices are more stabilised

Naturgy Response

• Recommends no earlier than the 1st April 2019, as GNI have only become active at the

IBP since 1st June.

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These are summary responses only. A copy of the complete responses will be circulated.

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/Consultation A090 Proposed new Invoice Dispute Resolution Procedure BGES Live/ Parked A091 Modification of oxygen content limits for Renewable Natural Gas (RNG) injected from RNG Entry Points GNI Live 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

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Code Modification Forum

• 8. Gas / Electricity Interaction

45

Code Modification Forum

46

• 9. Security of Supply Regulation 2017/1938

Article 14 – Information Exchange

www.cru.ie

Security of Supply Regulation 2017/1938

Article 14 – Information Exchange

47

• CRU will write to Natural Gas Undertakings (NGUs’)in early September. NGUs’ must

notify CRU of the details of gas supply contracts with a cross border dimension and a duration of more than one year which it has concluded to procure gas:

• Contract duration
• Yearly contracted volumes
• Contracted maximum daily volumes in the event of an alert or emergency
• Contracted delivery points
• Minimum daily and monthly gas volumes
• Conditions for the suspension of gas deliveries
• All information received will remain confidential within the CRU and the Commission.

Code Modification Forum

• 10. Data Sharing Agreement Update

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• Conference call held on 5th July
• In advance of the call Energia had circulated a note with detailed comments
• After the call Shippers were asked for input on 3 questions

1. Should DSA be by Ancillary Agreement or incorporated into Code 2. Shippers were asked to provide comments on the content of the Draft Agreement (v181613 GNI Data Sharing Ancillary Document ISSUED) 3. Shippers were asked to provide comments on the points raised by Energia

• Shipper comments to be returned by 26/07/18

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• 10. Data Sharing Agreement Update

• 5 Shippers returned detailed comments
• Wide divergence of opinions
• GNI has submitted details of the comments to CRU
• GNI supports inclusion of individual clauses into Code of Operations

‒ Data Controller to Data Controller is a key concept, generally accepted by industry ‒ Current Code needs to be amended to reflect this and other GDPR points

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• 10. Data Sharing Agreement Update

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• 10. Data Sharing Agreement Update

Shipper Best Structure of Agreement: Ancillary/Code Mod/Bilateral Comments on Energia Comments Comments on previous Draft DSA Other Comments Energia Code Provisions N/A As circulated to GMARG/ Code lists Shipper 2 Code Provisions Broadly agreed, minor edits proposed re warranties, indemnities Minor edits proposed |Indemnity to be reciprocal Shipper 3 Note 1 Shipper 4 Code Modifications Support Comments Shipper 5 Negotiated Bilateral Agreements Generally Supports comments Minor edits proposed Concern on potential CRU function regulating Data Protection GNI Position Code Provisions Reconsidering warranties, Indemnities N/A Code needs to address GDPR, recognise Controller to Controller relationship

• 1. Shipper indicated it would not be able to submit comments within the timeframe due to leave periods, comments to follow

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Code Modification Forum

• 11. BrExit and ROI Gas Market

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 It was expected that progress would be made at the June EU Council Summit, however this did not materialise  UK Government subsequently published a ‘White Paper’ on 12th July. Relevant highlights include:

 ‘continued cooperation on energy and transport – preserving the Single Electricity Market in Northern Ireland and Ireland, seeking broad cooperation on energy’  ‘exploring options for our future energy relationship – maintaining the Single Electricity Market (SEM) across the island of Ireland in any eventuality’  The UK is seeking broad energy cooperation with the EU, including arrangements for trade in electricity and gas, cooperation with EU agencies and bodies, and data sharing to facilitate market operations  The UK wants to explore with the EU the options for the future energy relationship. One option would be for the UK to leave the Internal Energy Market (IEM). In this case, the UK would explore what would be needed to ensure trade over interconnectors would continue without automatic capacity allocation via the IEM system.

Brexit – In The News

54

 UK Government subsequently published a ‘White Paper’ on 12th July

 An alternative option would be for the UK to participate in the IEM to preserve the existing efficient trading practices over interconnectors  The UK wants to explore with the EU the options for continued Transmission System Operator participation in the Inter- Transmission System Operator Compensation Mechanism, and continued membership of the European Networks of Transmission System Operators for Electricity (ENTSO-E) and Gas (ENTSO-G). 

• 142. The UK is also putting in place arrangements so that, when trading after exit, businesses will have certainty that they will

not face substantially different requirements compared to their current obligations under the Regulation on Wholesale Energy Market Integrity and Transparency (REMIT).

Brexit – In The News

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 White Paper has been broadly rejected by EU officials primarily due to no satisfactory solution to the customs issue in Northern Ireland  BEIS are continuing to work towards transposing legislation in order to ensure that nothing changes with regards to day to day processes post Brexit  GNI continue to engage regularly with DCCAE, CRU, BEIS, Ofgem with regard to Brexit impacts and continue to highlight security of gas supplies as our number 1 priority

Brexit – In The News

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Brexit – next steps

• White Paper published

July 12th 2018

• Ongoing negotiations between EU and UK

July – September

• EU Summit – most likely opportunity for a final agreement on the

UK divorce from the bloc and a statement on future relations

October 18/19th 2018

• Emergency summit?
• A further EU summit could be needed to finalise the divorced deal if

the deadlock on Ireland continues in October.

November 2018

• The last European Council of 2018
• Widely seen as the last practical date for an Article 50 divorce deal

to be signed off by Britain and the EU

December 13/14th 2018

• 12. Transparency Data Update

Code Modification Forum

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Transparency Platform: Overview

• 11th May 2018 GNI launched a new Data Transparency Portal.
• The platform’s functionality allows for:
• Data visualisation
• Hourly, daily and Monthly updates and graphical representation of gas-related data:
• Functionality available for users to download historical data
• Hourly inlet and outlet pressures, with mapping to strategic locations on the network

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• Entry/ Exit Flows
• Balancing (Actions & Prices)
• Nominations/Renominations
• Capacities
• System Imbalance Position
• Gas Quality
• VRF
• Shrinkage and Stock Gas
• Activity at the IBP
• Macroenvironment

Transparency Platform: Statistics, May 11th to June 28th

• Sessions/ Visits to the platform: 1,358
• Number of Users: 506
• Unique Page Views: 5,910
• Average time on visit to Data Transparency Platform: 08:14

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Most viewed pages include:

• 1. Entry flows
• 2. Exit flows/gas consumption
• 3. Activity @ IBP

Transparency Platform: Statistics, July 1st to July 31st

• Sessions/ Visits to the platform: 744
• Number of Users: 181
• Unique Page Views: 3,079
• Average time on visit to Data Transparency Platform: 06:56

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Most viewed pages include:

• 1. Entry flows
• 2. Activity @ IBP
• 3. Exit flows/gas consumption

Code Modification Forum

• 13. Website Feature Update

“For Shippers” Tab on Homepage with relevant links is being scoped . Web developer asked to provide estimate of scale/cost

• f development work

61

Code Modification Forum

• 14. Trading Platform Update – GNI Participation

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Trading Platform: Overview of activity on EBI platform

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• 1st June 2018 marked the commencement of GNI’s participation in the Irish balancing point (IBP) trading

platform operated by EBI

• The EBI platform is trending towards increased levels of activity with up to 800,000 therms/day being traded
• Activity does decline on days where there are production problems at the Corrib gas field.
• GNI is now contracted with 4 shippers on the platform
• There are 11 shippers trading on the EBI platform

Trading Platform: Overview of activity on EBI platform, June & July 2018

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2 4 6 8 10 12 14 16 100 200 300 400 500 600 700 800 900

K Therms/day Date

Volume Traded and #Trades – June to July 2018

Volume Traded (Left Axis) # of Trades (Right Axis)

Trading Platform Activity – June 2018

Number of trades Total Volume Traded 202 (average of 7 per day) 12,673 ktherms (Average of 420 ktherms per day)

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Number of trades involving GNI Total Volume Traded 20 (average of 2 trades in every 3 days). 19 balancing sells and 1 balancing buy. 1600 ktherms Platform in General GNI participation

Trading Platform Activity – June 2018

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46.0 48.0 50.0 52.0 54.0 56.0 58.0 60.0 62.0

pence/therm

UK NBP SAP Versus IBP SAP - 1st June to 30th June

SAB IBP (p/therm) SAP NBP (p/therm)

Trading Platform Activity – July 2018

Number of trades Total Volume Traded 176 (average of 5 per day) 11, 168 ktherms (Average of 360 ktherms/day)

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Number of trades involving GNI Total Volume Traded 13 (13 Balancing sells) 1,250 ktherms Platform in General GNI participation

Trading Platform Activity – June 2018

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48.0 50.0 52.0 54.0 56.0 58.0 60.0

pence/therm

UK NBP SAP Versus IBP SAP - 1st July to 31st July

SAB IBP (p/therm) SAP NBP (p/therm)

Code Modification Forum

• 15. AOB

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1.

Upcoming Code Modification Forum Meetings

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CMF Dates 2018 Location

7th March 2018 (Wednesday) Cork 2nd May 2018 (Wednesday) Dublin 13th June 2018 (Wednesday) Cork 8th August 2018 (Wednesday) Dublin 26th September 2018 (Wednesday) Cork 28th November 2018 (Wednesday) Dublin Next Meeting

Thank you for your participation