FAQs on fundamental data and inside information – Question II.3.1.12

Do TSOs need to report gas trade notifications at virtual trading hubs?

Article 9 of the REMIT Implementing Regulation: Rules for the reporting of fundamental data on gas

Paragraph 2: Gas TSOs or third parties on their behalf shall report to the Agency and, at their request, to national regulatory authorities in accordance with Article 8(5) of Regulation (EU) No 1227/2011 day-ahead nominations and final re-nominations of booked capacities specifying the identity of the market participants involved and the allocated quantities. The information shall be made available no later than the following working day.

….(f) for physical and virtual hubs.

Commission Regulation (EU) No 312/2014 establishing a Network Code on Gas Balancing of Transmission Networks

Article 4: BALANCING SYSTEM

Section 3. Network users shall have the possibility to enter into a legally binding agreement with a transmission system operator which enables them to submit trade notifications irrespective of whether they have contracted transport capacity or not.

Article 9(2) of the REMIT Implementation Regulation requires to report nominations and re-nominations at virtual hubs. At the same time Commission Regulation (EU) No 312/2014 defines that for virtual trading hubs there is only trade notification used and no nomination/re-nomination needed (as no capacity allocated).


Answer:

In the Agency’s view trade notifications from TSOs at virtual trading hubs do not have to be reported as nominations if no nominations/re-nominations are required according to Commission Regulation (EU) No 312/2014. All the details should be reported by market participants as a supply contract.

RSS_Icon Last update: 08/01/2019  

FAQs on fundamental data and inside information – Question II.3.3.4

Can you please confirm how the gasDayStart and gasDayEnd data fields should be reported for an entity reporting on UK activities in the Storage Participation Activity Report? The Agency’s guidance for the fields says: The start of the gas day in UTC ISO8601 standard with an example YYYY-MM-DD 06:00 and The end of the gas day in UTC ISO8601 standard with an example YYYY-MM-DD 06:00 The TSO places gas for Operating Margins at UK storage facilities. For the avoidance of doubt can you please provide clear instructions/examples on how as an entity reporting on UK activities should reference the start of the gas day and end of the gas day (including clock change). Following this standard we believe the referencing for gas day starting 21/04/16 for example should be: gasDayStart 2016-04-21 04:00:00Z gasDayEnd 2016-04-22 3:59:59Z


Answer:

If the time zone for the reported facility is in the UK and the gas day starts at 5:00 am local time then the correct start and end time is the following:

During Summer Time Or
gasDayStart 2016-04-21 04:00:00Z 2016-04-21 05:00:00+01:00
gasDayEnd 2016-04-22 04:00:00Z 2016-04-22 05:00:00+01:00
During winter time Or
gasDayStart 2016-11-21 05:00:00Z 2016-11-21 05:00:00+00:00
gasDayEnd 2016-11-22 05:00:00Z 2016-11-22 05:00:00+00:00

RSS_Icon Last update: 08/01/2019  

FAQs on fundamental data and inside information – Question II.3.3.6

Reporting negative values for available capacity due to overbooking.

(available capacity = (technical capacity) – (contracted capacity).

Should available capacity, in case of overbookings, be reported with a negative value, or should overbooked capacities not be taken into account?

The contracted capacity, which is reported within fundamental data reporting, is the sum of the sold firm and interruptible capacities. But to calculate the available capacity, we expect that the contracted capacity (used in the calculation) is purely the firm capacity, since the available capacity shows “only” the firm available capacities that will definitely be available to the market. It makes no sense from our perspective to publish available interruptible capacity because this may change very often with regard to the usage of the storage facility and because it depends on the decisions taken by SSOs and their willingness to risk interruption.

In that case, a negative value of the available capacities could only appear if the firm capacities are oversold. Please confirm.


Answer:

In the Agency’s view the stakeholder is describing two possible options:
Option 1 – Available interruptible capacity is NOT offered by the SSO to the market in which case the following calculation applies:
Contracted capacity = sold firm + sold interruptible capacity
Available capacity = technical capacity – contracted (only sold firm) capacity
In this case the available capacity cannot be negative. It can be ≥ 0.

Option 2 – Available interruptible capacity is offered by the SSO to the market in which case the following calculation applies::
Contracted capacity = sold firm + sold interruptible capacity
Available capacity = technical capacity – contracted (sold firm + sold interruptible) capacity.
In this case the available capacity can be negative. It can be ≤ 0.

RSS_Icon Last update: 08/01/2019  

FAQs on fundamental data and inside information – Question II.3.2.11

From the MoP on data reporting: “The LNG Unavailability Report should be provided by the LNG System Operator in accordance with Article 9(3) c. The data element “lngUnavailabilityReport” is used by the Reporting Party to identify any periods where the facility is unavailable for the reloading and unloading of LNG to participants, whether this is a planned or unplanned activity. To be sent as soon as information becomes available. The unavailability report is used to report any planned or unplanned unavailability of a facility for a gas day or period within a gas day. Each LNG System Operator shall identify the dates and time on which the planned or unplanned outages of the LNG facility occur and the capacity which is affected.”

 

The bold part would refer to the jetty only. Does ACER really want to know the unavailability of the jetty?


Answer:

According to Article 9 (3) (c) of Commission Implementing Regulation (EU) No 1348/2014 LNG, system operators shall report planned and unplanned unavailability announcements of the LNG facility including the time of the announcement and the capacities concerned.

The notion of LNG facility is defined in Article 2(11) of Directive 2009/73/EC as a terminal which is used for the liquefaction of natural gas or the importation, offloading, and re-gasification of LNG, and includes ancillary services and temporary storage necessary for the re-gasification process and subsequent delivery to the transmission system, but does not include any part of the LNG terminals used for storage. Therefore, any unavailability of the facility that falls within the definition of the LNG facility shall be reported with lngUnavailabilityReport.

RSS_Icon Last update: 18/05/2017  

FAQs on fundamental data and inside information – Question II.3.3.5

Should fundamental data be reported during the decommissioning and the blowdown phase, and if so, how?

During the decommissioning phase, there are no commercial contracts applicable, which is why the facility report values are zero. However, in some types of storage facilities, as part of the blowdown / decommissioning phase, cushion gas should be withdrawn from the storage and sold to the market.

Should fundamental data be reported until cushion gas is taken out? Or is transaction reporting for the sale of the cushion gas sufficient?

If fundamental data reporting is still necessary, our understanding is that the total volumes DTMTI, DTMTW, DTMTS, storages volume, injected daily volume und withdrawn daily volume should be zero. Should the daily withdrawal volume show the volumes of cushion gas and the other requested data be reported as zero only in case of a cushion gas takeout?


Answer:

The cushion or base gas (permanent inventory in a storage reservoir) should not be counted as a normal working gas volume. The Agency’s understanding is that the removal of cushion gas is the last step of the decommissioning phase.

If there are no commercial activities during the decommissioning phase and cushion gas is still in a storage reservoir, the SSO should report zero values “0” in the fields: storage, injection, withdrawal, technicalCapacity, contractedCapacity, availableCapacity of Storage Facility Report until cushion gas is sold/taken out.

When cushion gas is sold/taken out, the Agency’s understanding is that the SSO has to make nominations and report movements of gas via the “withdrawal” field in the Storage Facility Report. Fields storage, injection, technical, available and contracted capacity of the storageFacilityReport should be reported with zero values “0”.

If the SSO needs to, for example, inject gas for operational purposes during the decommissioning phase, the Agency’s understanding is that the SSO has to make nominations and report movements of gas via the “injection” field in the Storage Facility Report. Fields storage, withdrawal, technical, available and contracted capacity of the storageFacilityReport should be reported with zero values “0”.

RSS_Icon Last update: 18/05/2017  

FAQs on fundamental data and inside information – Question II.3.2.5

In case an LNG Storage Operator (LSO) does not offer the reporting service, there is uncertainty as to who the responsible Market Participant responsible for reporting the unloading/reloading information to ACER should be, given the LNG could change ownership several times between the ship and the flange of LNG plant.

Title to LNG can change several times before it is discharged. Therefore, for the purposes of reporting LNG unloading/re-loading data it is questionable who the market participant responsible for reporting the unloading/reloading information to ACER is.

MP1 sells its LNG cargo to MP2 before the ship starts unloading. MP2 also owns the terminal capacity. Who is responsible for reporting?


Answer:

In the Agency’s view it is the last person in the chain who will report unloading and reloading data. Where exchange of title has occurred before unloading/reloading commences at the flange, MP2 in the above example is responsible for reporting the loading/unloading data.

Where title is retained by MP1 but MP1 does not own the terminal capacity, the Agency understands that the LSO may not be able to report on their behalf. Therefore it is the Agency’s understanding that the capacity holder (MP2) is responsible for the reporting and this can identify the MP1 in its report when MP2 reports the information. MP2’s ID will be reported in the terminalCustomerIdentifier field, and MP1’s ID in the marketParticipantIdentifier field.

However, the LSO might report on behalf of the capacity holder (MP2) and should identify (if possible) MP1 in the marketParticipantIdentifier field. The Agency understands that, where the LSO reports on behalf of the capacity holder MP2 and has no information on MP1, the LSO may report MP2 in both marketParticipantIdentifier and terminalCustomerIdentifier fields if the LSO has no information on MP1.

RSS_Icon Last update: 15/11/2016  

FAQs on fundamental data and inside information – Question II.3.2.6

Duplication of data fields between LNG transaction and Fundamental data reports.

A comparison of the data to be provided for LNG transaction and fundamental data reporting has identified areas for potential duplication of reporting. Recital 19 of REMIT notes that any kind of double reporting should be avoided.

Our view is to reduce duplicate reporting it would be helpful if ACER could enable, via a “No-action letter” Market Participants to use the execution files to also fulfil the obligation to report LNG Participant Activity Fundamental Data.

Rationale: we are aware that the REMIT implementing regulation requires reporting of both executions and fundamental data for a delivery of an LNG cargo. However, there is a need to avoid double reporting arising from Recital 19 of REMIT.


Answer:

The data fields collected for LNG transaction data and LNG fundamental data are defined in Commission Implementing Regulation (EU) No 1348/2014. Although some data fields for LNG fundamental data are also present in executions of LNG transactions, the scope of fundamental data is broader.

According to Article 10(3) of Commission Implementing Regulation (EU) No 1348/2014, the Agency shall establish procedures, standards and electronic formats based on established industry standards for reporting of information referred to in Articles 6, 8 and 9 of the said regulation. Its Article 9 determines rules for the reporting of fundamental data on gas.

From Article 10(3) of Commission Implementing Regulation (EU) No 1348/2014 it is clear that separate procedures and formats have to be established for fundamental data reporting under REMIT.

Please note that the Agency already aims at minimising the reporting obligation on market participants as much as possible by collecting the required information from existing sources where possible.

RSS_Icon Last update: 15/11/2016  

FAQs on fundamental data and inside information – Question II.3.2.7

Timing/ Frequency of reporting an LNG Participant Activity Report

LNG fundamental data relating to dates of unloading and reloading and volumes unloaded and reloaded per ship must be reported to the Agency by market participants ‘…no later than the working day following unloading or reloading.’
However, the final volume unloaded/reloaded may not be known until after T+1 for various reasons, e.g. the report providing final discharge/load figures may be issued late and we and/or our counterparty may disagree with the report (see practical examples below).

Example 1): Delay in receiving Inspector’s report containing load or discharge figures

Ø Vessel completes discharge 23:00 1st January.

Ø Inspector report issued 23:00 2nd January.

Ø Final figures cannot be actualised in system and reported to REMIT until a.m. 3rd January.

Ø Should an estimate be submitted within T+1? In which case, can an updated figure be submitted on T+2?

Example 2): Quantity discharged or loaded is disputed between parties and cannot be deemed as final on T+1

Ø Vessel completes discharge 09:00 1st January.

Ø Inspector report issued 19:00 1st January.

Ø Counterparties disagree with figures on morning of 2nd January. Parties agree to a retest, which requires 24 hours.

Ø Retest results made available 12:00 3rd January.

Ø Parties agree on new test results 4th January. Final Figures cannot be actualised in system and reported to REMIT until this day.

Ø Should an estimate be submitted within T+1? In which case, can an updated figure be submitted on T+3?


Answer:

According to Article 9(6) of Commission Implementing Regulation (EU) No 1348/2014 the information referred to in Article 9(5)(a) of the said regulation shall be made available no later than the working day following unloading or reloading.

In the examples described above, the inspector reports issues within a t+1 day time frame. This is why the Agency would consider the unloading or reloading only completed once the issue reported by the inspector is sorted out and the t+1 day timeline only starts to run as of then. In general, such inspections and potential dispute settling between the parties on test results of cargo figures should be considered an integral part of the LNG unloading and reloading.

RSS_Icon Last update: 15/11/2016  

FAQs on fundamental data and inside information – Question II.3.2.8

What is the frequency of reporting of the planned loading/reloading of LNG (lngPlannedUsageReport)?

There is a lack of clarity of the frequency of the reporting in case of varieties during the current month.

In our view the report should be submitted once for each calendar month and submitted before the start of the relevant calendar month. The concept could be endorsed by the Agency via a “no action letter” or via additional guidance.

Rationale: There are no provisions in the level 2 text for providing updates to the Agency regarding planned unloading/reloading once the file has been submitted prior to the start of the month. Additionally the Manual of Procedures specifically states: “The data element ”lngPlannedUsageReport” is to be used by the Reporting Party to document expected usage of the facility over the next reporting period. The Reporting Party shall provide a monthly update of the planned usage of the facility, which details expected deliveries and planned reloading and unloading dates over the coming month”.


Answer:

In the Agency’s view the report should be submitted once a month before the start of the relevant calendar month. As Commission Implementing Regulation (EU) No 1348/2014 does not foresee to report updates regarding planned unloading/reloading once the file has been submitted to the Agency, market participants or LSOs shall submit their report that was sent to the LSO on the last day of the month preceding the calendar month to which the report relates to.

Example: If the report on the planned unloading and reloading for the month of April is agreed with the LSO on 15 March and then amended on 29 March, market participants (or the LSO on their behalf) should send their planned loading/reloading report (submitted on 29 March to LSO) to the Agency not later than on 31 March.

RSS_Icon Last update: 15/11/2016  

FAQs on fundamental data and inside information – Question II.3.2.9

Which day/event shall be populated for gasDayStart and gasDayEnd fields in the LNG Participant Activity Report?


Answer:

In order to populate the gasDayStart and gasDayEnd fields in the LNG Participant Activity Report, the Market Participant shall use the relevant records from the Cargo Discharge Log as a reference. The values shall reflect the gas day(s) during which the reloading or unloading occurred.

Example:

Cargo Discharge Log

2 December 2016 – 06:52 – Commenced Discharge

2 December 2016 – 19:38 – Completed Disconnecting Arms

gasDayStart: 2016-12-02T05:00:00Z (time depends on time zone)

gasDayEnd:2016-12-03T05:00:00Z (time depends on time zone)

RSS_Icon Last update: 15/11/2016  

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