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FAQs on fundamental data and inside information – Question II.2.1.1

According to the MOP Version 3 of 30 September, you require the market participants in the data fields 11 “schedule_Time_Period.timeInterval start” and 12 “schedule_time_Period.timeInternal end” to report the beginning and end of their nomination schedule period in UTC time standard.

But regarding the daylight savings time issue: Can electricity TSOs report their nomination schedule period during the summer as <date1-1>t:22:00Z to <date2-1>T22:00Z and during the winter <date1-2>T23:00Z to <date2-1>T23:00Z?


Answer:

On the basis of the IEC ENTSO-E standards, which deal natively with daylight savings, 23 time periods should be reported during the daylight savings time and 25 time periods in winter time. Same applies for nomination schedules: 23 time periods during the daylight savings time and 25 time periods in winter time.

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FAQs on fundamental data and inside information – Question II.3.1.1

As from 1 October 2015, with the entry into force of the CAM NC, shippers now submit Double Sided and Single Sided nominations to initiating and matching TSOs. When the initiating and matching TSOs report the fundamental information at the Interconnection Points which TSO should report the Single Side Nomination and allocation information – the initiating TSO, the matching TSO or both TSOs?

We have an understanding that the spirit of REMIT is to avoid double reporting which would be the case with regards Single Side Nominations and related allocations.

In the Edigas REMIT Reporting Process v5.1 chapter 4 ‘Nominations Monitoring Process’, in section 4.1.6 ‘Rules Governing the Shipper_Account Class’ it contains the following data fields:

a- Internal_marketparticipant.identification

b- Internalaccount

c- Internalaccounttso

d- Externalacccount

e- Externalaccounttso

The Internal_marketparticipant.identification, internalAccount and ExternalAccount will all be identical in case of a Single Side Nomination.

If the matching TSO reporting their data populates the InternalAccountTSO with the EIC of the initiating TSO this would mean duplication of reporting as the Initiating TSO would provide identical details when reporting the same Single Side Nomination.


Answer:

In the Agency’s view a single side nomination report should be submitted. It is up to the TSOs to agree on who does the reporting and one TSO can report a single side nomination. If the TSOs cannot agree, both TSOs should report nominations separately.

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FAQs on fundamental data and inside information – Question II.3.1.2

According to Article 9 (2) (a) of Implementing Regulation (EU) No. 1348/2014, nominations and re-nominations have to be reported with regards to:

(a) all interconnection points,

(b) entry points of production facilities including of upstream pipelines,

(c) for exit points connected to a single customer,

(d) entry and exit points to and from storage,

(e) for LNG facilities,

(f) for physical and virtual hubs.

Which points shall be considered as interconnection points for the purpose of TSO REMIT reporting of fundamental data?


Answer:

The Agency’s current understanding is that only cross-border interconnection points and connection points between adjacent balancing zones shall be considered as interconnection point and as such to fall into the scope of TSO REMIT reporting of fundamental data according to Art. 9 (9) (a) of Implementing Regulation (EU) No 1348/2014.

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FAQs on fundamental data and inside information – Question II.3.1.3

What is the applicable deadline for reporting gas nominations?


Answer:

In the Agency view’s, gas fundamental data usually refers to a gas day running from 6:00 am of one day to 6:00 am of the following day. The information provision deadline of Article 9(2) of Implementing Regulation (EU) No 1348/2014 refers to the working day following the end of the gas day. Therefore, for example, for the gas day 01.10.2015- 06:00 to 02.10.2015-06:00 the fundamental data is reportable no later than the end of the following working day i.e. by the end of 03.10.2015.

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FAQs on fundamental data and inside information – Question II.3.1.4

Final re-nominations for Interconnection Points, required by Article 9.2 (a) from Regulation (EU) No 1348/2014. There are different ways to interpret “Final re-nominations”. TSOs can use the last processed quantity of a nomination or the original nominations, without any processing in the TSO-system. Which value should be sent to ACER?


Answer:

In the Agency’s view the last re-nomination sent by the shipper to the TSO shall be submitted to the Agency as “Final Re-nomination for Interconnection Points” required by Article 9 (2) (a) of Implementing Regulation (EU) No 1348/2014.

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FAQs on fundamental data and inside information – Question II.3.1.5

According to Edig@s MIG for the Nomination and Contract Market Monitoring schema in the field RECIPIENT_MARKETPARTICIPANT.IDENTIFICATION the RRMs shall point the EIC code of the Report recipient, i.e. ACER EIC code.

Would you please point the ACER EIC that shall be included in the field RECIPIENT_MARKETPARTICIPANT.IDENTIFICATION of Nomination Monitoring schema and Contract Market Monitoring schema?


Answer:

ACER’s EIC code is “10X1001B1001B61Q” and it is available in the latest version of the Manual of Procedure (MoP) on data reporting. Please see page 44 and 54 of the MoP.

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FAQs on fundamental data and inside information – Question II.3.1.6

There are different ways to interpret “Day-ahead nominations”. Because a Network User can amend the nomination until the initial nomination deadline there might be many nominations submitted by the Network User. The last received nomination before the nomination deadline is taken into account by the TSO for the scheduling of the gas flow.

Which nomination should be reported?


Answer:

In the Agency’s view the last nomination before the initial nomination deadline sent by the shipper shall be submitted to the Agency as “Day-ahead nomination” required by Article 9 (2) of Implementing Regulation (EU) No 1348/2014.

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FAQs on fundamental data and inside information – Question II.3.1.7

According to Article 9 (2) of Implementing Regulation (EU) No 1348/2014, allocation and re-nomination data need to be reported to ACER on the working day following the allocation. This means that these data will be preliminary and not final. However, corrections of allocations are possible within different time periods according to national law. TSOs believe that updates of fundamental data do not have to be reported to ACER.

Does ACER consider it necessary that the TSOs shall send the respective updates of the fundamental data to ARIS?


Answer:

The fundamental data will be reported on a working day following the end of the gas day. The Agency has been informed that the only updates of fundamental data (nominations) that can occur after reporting on a working day following the end of the gas day are those resulting from a technical failure/error in the TSO system.

Therefore, no updates of fundamental data (nominations) beyond a working day following the end of the gas day (D) are required to be sent to the Agency by the TSOs unless there was a technical failure/error in the TSO system and the data was reported incorrectly to the Agency.

 

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FAQs on fundamental data and inside information – Question II.3.1.8

In the answer to Question III.3.16 ACER Q&A on REMIT 7th Edition, updated 30 June 2015, ACER states the following, regarding “DSOs”: “The Agency also understands electricity and gas distribution networks to be consumption units with regard to electricity and gas that is consumed in order to cover grid losses. Therefore the Agency understands a DSO as final customer and market participant if the aforementioned grid losses are above the threshold of 600 GWh per year. The Agency will aim at providing further guidance on the above definition as required”.

Would you confirm our understanding that the case described in the answer to Question III.3.16 ACER Q&A on REMIT 7th Edition refers to the reporting of supply contracts?

Would you confirm that the TSOs shall not report fundamental data to ACER that refer to connection points between DSOs and TSOs?


Answer:

According to the Agency’s Manual of Procedure (MoP) the information should be provided at daily resolution at least for all bookable points for the reporting day and relating to the network of the relevant gas TSO such as:

  • all interconnection points,
  • entry points of production facilities including of upstream pipelines,
  • exit points connected to a single customer [as defined in Article 2(5) of REMIT],
  • entry and exit points to and from storage,
  • LNG facilities, and • physical and virtual hubs.

Fundamental data as per Article 9 (2) (c) shall be reported for exit points connected to a single customer if the threshold of 600 GWh/year is exceeded. TSOs shall not report fundamental data to the Agency that refers to connection points between DSOs and TSOs.

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FAQs on fundamental data and inside information – Question II.3.1.9

Reporting of fundamental data for end customers with consumption > 600 GWh/year pursuant to Article (9)(2)(c) of Implementing Regulation (EU) No 1348/2014: “For these customers no nominations or re-nominations are available”.

Would you agree that in this case, regarding fundamental data reporting for the end consumers in Germany, the TSOs must report only allocation data, and shall not report any information about the nominations and the re-nominations, since the end consumers do not nominate/re-nominate capacity to the TSOs and such data is not available to the TSOs?

If it is TSOs position that reporting of “zero” values for nominations and re-nominations are not appropriate because this could lead to the assumption that a nomination with a value of 0 was given which is not true. In addition, this would fill up the databases of ACER with irrelevant data and lead to an unnecessary increase of the data volume of the messages. Therefore the TSOs believe that only allocation data should be reported.


Answer:

If the nominations or re-nominations are not available to the TSOs, then there is no need to report nominations or re-nominations with “zero” value. Only allocation data should be reported.

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