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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.

RSS_Icon Last update: 31/03/2016  

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.

RSS_Icon Last update: 31/03/2016  

FAQs on fundamental data and inside information – Question II.3.1.10

TSOs have to report nominations and allocations of booked capacities. If the Capacity is booked on a virtualized point (comprising two or more physical points), but the nominations and allocations are still made on the physical points (therefore points with different EIC codes than the virtual point where the capacity was booked), how the nominations and allocations shall be reported? Per physical or virtualized point?

Should the TSO aggregate the nominations and allocations for both physical points and report them as nominations and allocations for the virtual point?

It is TSOs position that in order to have a better understanding of how the capacity is used, it is better to aggregate the nominations and allocations and to report them under the EIC code of the virtualized point. This is the approach for data publication on the Transparency Platform of ENTSOG in case of virtualized points.


Answer:

Nominations and allocation should be reported in a way that fits the specific/national market design. In most cases it is expected that it will be reported per physical point, but if the market design is constructed in a way that virtual points encompass two or more physical points then nominations may be reported per virtual point.

RSS_Icon Last update: 31/03/2016  

FAQs on fundamental data and inside information – Question II.3.1.11

How shall corrections of gas nomination (NominationMonitoring_Document schema) data be reported?


Answer:

In the Agency’s view, each retransmission of a document that introduces changes to the previous reports of gas nomination should be submitted by incrementing the value of the field “Version” by 1.

RSS_Icon Last update: 31/03/2016  

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.3.2.1

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  

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