FAQs on fundamental data and inside information – Question III.4.1.10

Does the Agency need to be aware about the point direction for which the affected capacity is announced? If yes, how this information shall be provided through XML based on UMM Schema No 2 “Unavailabilities for gas facilities”?

The format for the XMLs for “Unavailabilities for gas facilities” (Schema No2) does not contain attribute for the point direction.

In the context of publication of unavailabilities for gas facilities, an “Affected asset or units” could be the connection point (cross-border, interconnection point, delivery point, measurement point etc.). In case that the affected point is bidirectional, the point capacity is direction dependent, respectively the values of the UMM Schema No2 attributes: Technical capacity, Available capacity and Unavailable capacity depend on the point direction.

In summary, the technical, available and booked capacities in normal circumstances are different for the different point direction. This means that during an event of unavailability both sites of a point could be affected and respectively – the affected capacities are different per point direction.


Answer:

The point direction shall be identified via field (15/b) Balancing zone in case that the affected point is bidirectional. The field allows for multiple EIC codes identifying balancing zones and the point direction will be determined by the order of EIC codes in the XML schema. The first EIC code should refer to the ENTRY point (IN= Balancing Zone where the flow starts), and the second EIC code should refer to the EXIT point (OUT= Balancing Zone where the flow ends).

When a connection point between a transmission system and LNG terminal or transmission system and Storage facility, or transmission system and TSO from a non-EU country is affected, the submission of IN and OUT balancing zones should reflect the direction of the flow with the above IN/OUT logic applied to the facilities.

For example: if the outage is related to the flow from an LNG facility towards the Gas Transmission Network, the first EIC should represent the LNG facility and the second the Balancing zone. Example:

W EIC LNG facility= Entry point

Y EIC Balancing zone= Exit point

The same applies to storage facilities and bidirectional interconnection points.

For complex cases when one point connects more than two balancing zones, the following logic shall apply:

If the direction is from Entry Point (EIC 1) to several exit points, the first EIC code represents the entry point, the second (EIC 2) and third (EIC 3) /fourth (EIC 4) EICs represent the exit points. If the outage occurs at EIC 1 then the first code will be EIC 1 and then all the possible EICs affected zones should be reported after that. Example:

Reporting party: TSO 1

EIC 1 = Entry point

EIC 2= Exit point

EIC 3 = Exit point

EIC 4 = Exit point

If the outage is at the exit point (e.g. EIC 4) the report should indicate two points as the TSO/operator of EIC 4 will not be able to publish any information about EIC 2 and EIC 3. Example

Reporting party: TSO 4

EIC 1 = Entry point

EIC 4 = Exit point

Or in case or reverse flow:

If the outage is at the entry point (e.g. EIC 4) the report should indicate two points as the TSO/operator of EIC 4 will not be able to publish any information about EIC 2 and EIC 3. Example

Reporting party: TSO 4

EIC 4 = Entry point

EIC 1 = Exit point

If the outage is at the exit point (e.g. EIC 2) the report should indicate two points as the TSO/operator of EIC 2 will not be able to publish any information about EIC 4 and EIC 3. Example:

Reporting party: TSO 2

EIC 1 = Entry point

EIC 2 = Exit point

 

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FAQs on fundamental data and inside information – Question III.4.1.14

Unavailability of unit EIC for gas consumption units (inside information).

Field 16 requires an EIC for the identification of a physical asset. We received the information from market participants that the EIC issuing body for gas consumption units in Germany is not able to provide those codes before the end of 2016 or beginning of 2017. Therefore, it is rather likely that those codes are not available.

The issue does not refer to power production, storage or consumption units where code availability is no problem.

The respective field 16 would remain empty. We suggest to allow us to provide the inside information without EIC on a temporary basis.


Answer:

The above proposal is reasonable. Once the EIC codes are available they should be provided in the UMMs collected by the Agency.

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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.

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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.

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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.

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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.

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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)

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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.

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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.

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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.

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