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.3.3.2

There is uncertainty regarding the report of fundamental data under provisions of Article 9(7)(b) of Commission Implementing Regulation (EU) No 1348/2014.
– quote: „(b) amount of gas in stock at the end of the gas day, inflows (injections) and outflows (withdrawals) for each gas day,“

Our question is what does the amount of gas in stock mean:

a)      Does it refer to the physical withdrawal/injection amount of gas which is measured in the storage facility entry/exit point?

or

b)      Does the withdrawal/injection amount of gas refer to the sum of allocated quantities (for all users) under the accepted nominations?

There is a possibility that there could be a difference between the measured and allocated quantities which are daily recorded on the open balancing account between OSS and TSO.

Regarding the possible difference in amounts in case a) and case b) we need to know which data we send as fundamental data.

Regarding the mentioned above a connected issue is raised in Article 9(9) of Commission Implementing Regulation (EU) No 1348/2014.

– quote : „9. Market participants or Storage System Operators on their behalf shall report to the Agency and, at their request, to national regulatory authorities the amount of gas the market participant has stored at the end of the gas day. This information shall be made available no later than the following working day.“

If the SSO reports on behalf of his storage users the only possible data to report is allocated withdrawal/injection quantities (equal accepted nominations), because this is the amount used to reived the stored gas (users balance account) for each user on a daily basis.

We are concerned that there could be a slight difference in amounts regarding the fundamental data of the whole storage and the amounts per user level.


Answer:

In order to harmonize the reporting, both SSOs and MPs or SSOs reporting on behalf of MPs shall use allocated data/nominations for reporting according to Articles 9(7) and 9(9) of Commission Implementing Regulation (EU) No 1348/2014.

RSS_Icon Last update: 15/11/2016  

FAQs on fundamental data and inside information – Question II.3.3.3

In relation to the Storage Participation Activity Report (Article  (9) of Commission Implementing Regulation (EU) No 1348/2014), where a primary capacity holder at a storage site sells capacity to a third party allowing them to hold gas stock at a storage site, who is the market participant for the stock placed at site by the third party (the secondary capacity holder) for the purposes of this report?

Is it the primary capacity holder or the secondary capacity holder?

The TSO places gas (held for Operating Margins purposes) at a storage facility – sometimes this is through the purchase of capacity rights from an existing storage capacity holder.  The TSO buys the gas (either for injection / as an in store transfer) to hold in store.  Who is the market participant in this case?

We have had different interpretations from different parties ranging from:

a)  it is the responsibility of the party who has legal title while the gas is in store (strictly speaking the storage operator);

b)  it is the responsibility of the party who has contracted / secured primary capacity rights directly with the storage operator;

c)  it is the responsibility of the secondary capacity holder (in this case the TSO) to report.


Answer:

In the Agency’s view the Market Participant responsible for reporting data according to Article 9 (9) of Commission Implementing Regulation (EU) No 1348/2014 in the above example is the secondary capacity holder – the TSO, since according to the Agency’s understanding it is also the secondary capacity holder that makes nominations at the storage facility. The Storage System Operator (SSO) may report on behalf of the Market Participant. The SSO shall identify the Market Participant in the report.

RSS_Icon Last update: 15/11/2016  

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.

RSS_Icon Last update: 31/08/2016  

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.

RSS_Icon Last update: 31/08/2016  

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.

RSS_Icon Last update: 31/08/2016  

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.

RSS_Icon Last update: 31/08/2016  

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.

RSS_Icon Last update: 31/08/2016  

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  

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