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FAQs on fundamental data and inside information – Question II.3.2.1

How shall corrections of LNG data be reported?


Answer:

Updates or corrections to any previously submitted data according to Article 9 (3) and 9 (5) of Implementing Regulation (EU) No 1348/2014 should be sent in a new file.

The date in the filename should correspond to the date the update and/or correction report is sent. Dates inside the file should refer to the date for which the updates or corrections are referring to.

 

RSS_Icon Last update: 31/03/2016  

FAQs on fundamental data and inside information – Question II.3.2.2

Shall we understand that as far as the “technical capacity”, “contracted capacity” and “send-out” values do not include the truck loaded quantities as the truck loading services are out of scope of REMIT?


Answer:

It is the Agency’s understanding that LNG truck loading services are not in scope of REMIT. Therefore the capacities offered through truck loading services should be excluded from reporting according to Article 9(3) of Implementing Regulation (EU) No 1348/2014.

RSS_Icon Last update: 16/06/2016  

FAQs on fundamental data and inside information – Question II.3.2.3

Technical capacity, Contracted capacity, Available capacity, Send-out, Inventory

Technical capacity – is it a maximum speed of regasification in the LNG terminal guaranteed throughout the entire calendar year or rather a daily maximum available regasification speed less the potential, partial (or complete) installation unavailability?

Contracted capacity – is it a maximum contracted speed of regasification (according to the terms and conditions of the contract) or rather daily nominations reported by the Terminal User (under a contract)?

Available capacity – shall represent a simple subtraction of cell values as follows: “available capacity” = “technical capacity” – “contracted capacity”?

Send-out – shall mean actual values resulting from send-out or reloading volumes measured in the LNG terminal expressed in GWh/d?


Answer:

Further to definitions provided in the Manual of Procedure on data reporting the Agency’s understanding of technical capacity, contracted capacity, available capacity, send-out and inventory is the following:

  • Technical capacity means the daily total firm regasification capacity that the LNG Facility Operator can offer to the terminal users, taking account of system integrity and the operational requirements of the terminal expressed on a daily basis in GWh/day.
  • Contracted capacity is the capacity that the LNG Facility Operator has allocated to users by means of a contract expressed on a daily basis in GWh/day.
  • Available capacity is the part of the technical capacity that has not been allocated to users and is still available expressed on a daily basis in GWh/day:
    “available capacity” = “technical capacity” – “contracted capacity”.
  • Send-out is the aggregated daily gas flow (regasified LNG) from the Terminal into the gas transmission system expressed in GWh.
  • Inventory is the total volume of LNG in the LNG tanks at the end of the previous gas day, expressed in GWh.

RSS_Icon Last update: 16/06/2016  

FAQs on fundamental data and inside information – Question II.3.2.4

What should we report as available capacity in case of planned/unplanned reduction of the daily technical capacity of an LNG facility?

Example: On a given gas day there is a planned/unplanned reduction of the daily technical capacity (example: from 21,9MSm3/d to 18 MSm3/d). The reduction has no impact on the daily nomination (which is, for example, 5 MSm3/d).

Do we need to keep unchanged the value of the available capacity and to send the information only through the planned/unplanned report or do we need to change also the available capacity? If the latter, how should we change the data? Should we report 0 as available capacity or should we leave it as it is because there is no impact on the daily nomination (to avoid providing multiple information which is not useful to the market)?


Answer:

Technical capacity will be reported in GWh/day and the value of 21,9MSm3/d shall be converted accordingly. Contracted capacity remains the same. Unavailable capacity of 3.9 MSm3/d (needs to be converted to GWh/day) will be reported under the field ‘unavailableCapacity’.

Available Capacity = “technical capacity” (21,9) – “contracted capacity” (5) = 16.9 MSm3/d shall be converted into GWh/day.

RSS_Icon Last update: 16/06/2016  

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  

FAQs on fundamental data and inside information – Question II.3.2.10

What should be provided for the unloaded LNG volume (‘unloadedVolume’ field) in the LNG Participant Activity Report?


Answer:

Market Participants should report the unloaded volume as defined in their Terminal Access Contracts.

RSS_Icon Last update: 15/11/2016  

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