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FAQs on transaction reporting – Question III.4.2.1

Which code should we use to identify an organised market place (Data Field No (2)) of gas transportation contract schema when no market organiser exists, e.g. when allocated transportation capacity is traded on secondary market?


Answer:

Version 2.0 of the TRUM states that in case of absence of the organised market place EIC code the field should be populated with “XXXXXXXXXXXXXXXX” if the capacity was allocated outside an organised market place. After consultation with the relevant stakeholders and the authors of the schema it was concluded that this code does not represent good business standards. As a consequence ENTSOG issued an EIC code to be used instead when no market organiser exists: 21X-XXXXXXXXXXXY.

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FAQs on transaction reporting – Question III.4.2.2

According to Edig@s REMIT MIG the field PROCESS_TRANSACTION.IDENTIFICATION is mandatory, and as such it could not be left blank.

How the transactions for bilateral capacity allocations (Shipper-Shipper) and transactions concluded outside of an Organized Market Place shall be identified?

Could we input a free text in the field PROCESS_TRANSACTION.IDENTIFICATION or a predefined set of values should be used?

Do you intend to change the schema in order to allow the field PROCESS_TRANSACTION.IDENTIFICATION to left blank?


Answer:

The field cannot be left blank. In case of Shipper-Shipper transactions a free text of maximum 35 characters should be used for the Process Identification.

As indicated in the TRUM this field should be a Unique Identification of the process only in case of auction process. For other processes concluded outside an organised market place the code shall be defined by the capacity allocating entity (i.e. the internal coding rule of the allocating entity applies, e.g. one code for single process or multiple processes identification possible).

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FAQs on transaction reporting – Question III.4.2.3

According to Edig@s MIG for the approved by ACER schema for gas transportation transactions reporting: urn-easee-gas-eu-edigas-remit-gascapacityallocationsdocument-5-1.xsd, the field “PROCESS_TRANSACTION.ACTION_STATUS.CODE”  accepts the following values:

62G = Active.

63G = Cancelled.

66G = Changed.

Definition of element:

Status code of the report to be reported in accordance with current applicable industry standards as specified in gas network code on Interoperability and data exchange.

According to TRUM field (14) Action type, the following codes are permitted:

62G = Active

63G = Cancelled

66G = Changed

Which status is provided to define the field – the status of the reported transaction or the status of the XML file?


Answer:

The element “PROCESS_TRANSACTION.ACTION_STATUS.CODE” is dedicated to define the status of the reported transactions.

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FAQs on transaction reporting – Question III.4.2.4

Which value should be send to ARIS in case of primary transactions for TRUM field 41 – Bid quantity, if during an auction a minimum value and a maximum value were given by the bidder?


Answer:

The maximum value should be reported for bid quantity.

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FAQs on transaction reporting – Question III.4.2.5

Price in the secondary Market:

Regarding TRUM v. 2.0 field 35 – Data Field – Price, it is foreseen to include the price concluded in transactions on the secondary market.

TSOs do not have this kind of information as the price is determined in agreements that take place strictly between shippers.

It is important for the TSOs to inform ACER also about these kind of transactions directly to ARIS and not only via booking platforms because these kind of transactions entail changes in contracts which need to be updated?


Answer:

The field 35 is mandatory for secondary market allocations. The reporting obligation for secondary market lies with the market participants. Therefore there should be no problem for the TSOs in case they lack the specific information on the price. In case the TSO acts as the third-party RRM it is the responsibility of the market participant(s) to provide the necessary information to the TSO as the RRM for complete and successful data reporting.

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FAQs on transaction reporting – Question III.4.2.6

Mechanism established for secondary market and underlying price:

TRUM field 29 – Procedure applicable, requires that the TSO is obliged to determine which mechanism is used in the Secondary market.

In this respect TSOs that use FCFS would need to fill in TRUM field 34 – Price paid to TSO (Underlying Price).

Do you mean that through TRUM field 34 information about the price that Shipper 1 pays to the TSO in first instance for capacity booking (before the transaction on secondary market takes place) shall be submitted to ARIS? Please clarify.


Answer:

TRUM field 29 is only applicable in case of secondary market allocations. It is not the responsibility of the TSO to determine the mechanism (field 29), but of the involved market participants. The same applies for field 34.

The underlying price is the price that Shipper 1 pays to the TSO in first instance for capacity booking (before the transaction on secondary market takes place).

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FAQs on transaction reporting – Question III.4.2.7

Reference to Article 7(5) of the Implementing Acts in case of transformations of the contract

Examples for transformations of the contract:

  • The contractual nature of a capacity contract can change. For instance, it is possible to convert interruptible capacity into firm capacity.
  • Transformation of capacity from interruptible to firm.

According to Article 7(5) of the Implementing Acts, details of contracts referred to in Article 3(1)(b)(i) of the Implementing Acts shall be reported as soon as possible but no later than on the working day following the availability of the allocation results. Any modification or the termination of the concluded contracts shall be reported as soon as possible but no later than on the working day following the modification or termination.

How to understand the provisions of Article 7(5) of the Implementing Acts in case of transformation of the contract – as a new or as a modified contract?

Should the case of capacity conversion from interruptible to firm be reported as contract modification?


Answer:

It is the Agency’s current understanding that the TSOs will have to report the transformation of a contract as modification of contracts to the Agency since there is a change of the main contractual aspect (product quality). The transformation of a contract shall be reported with 66G 66G = Changed (please refer to TRUM field (14) Action type for details)

Other fields have to be updated accordingly.

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FAQs on transaction reporting – Question III.4.2.8

Reference to Article 7(5) of the Implementing Acts in case of Floating tariffs: change of tariff (regulated price), in particular in case of long term contracts.

According to Article 7(5) of the Implementing Acts, details of contracts referred to in Article 3(1)(b)(i) of the Implementing Acts shall be reported as soon as possible but no later than on the working day following the availability of the allocation results. Any modification or the termination of the concluded contracts shall be reported as soon as possible but no later than on the working day following the modification or termination.

How to understand the provisions of Article 7(5) of the Implementing Acts in case of Tariff change?

Does the TSO have to report the tariff change as modification of the contract?


Answer:

It is the Agency’s current understanding that there is no need to send tariff changes as a modification of the contract if the usage of the tariff is well-defined in a contract and if the tariff change is made publically available by the TSO or by the respective NRA. The Agency reserves the right to request data on tariffs from TSOs.

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FAQs on transaction reporting – Question III.4.2.9

Secondary Transactions (transfer of rights to use/sell transmission capacity from shipper to shipper) that will be reported via capacity platforms – OMP (XX, YY, etc.)

Does ACER require reporting of transfer of rights to use of capacities or is reporting only required in case that a shipper sells the capacity itself to another shipper?


Answer:

The Agency considers the described transfer of rights as a secondary market transaction which has to be reported. The reporting responsibility lies with the market participants.

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FAQs on transaction reporting – Question III.4.2.10

The following cases result from the application of Congestion Management Procedures (CMP) according to No. 2.2. of Annex I of Regulation (EC) No 715/2009.

  • Surrender of capacity;
  • Re-surrender of capacity;
  • Withdrawal of capacity rights (LT UIOLI);
  • Transactions relating to overbooking and/or buyback of capacities;
  • Day-ahead UIOLI (renomination restrictions).

Which of the following transactions need to be reported as primary transactions and should the following cases be considered as contractual modifications to be reported acc. to Art. 7 Para 5 sentence 2 of the REMIT Implementing Acts:

a) Surrender of capacity (Application of No 2.2.4 Annex I Regulation (EC) No 715/2009)?

b) Re-surrender of capacity (Surrendered capacity handed back to the shipper, because the TSO was not able to reallocate it to a new customer)?

c) Withdrawal of capacity rights (Application of Long Term Use-it-or-loose-it mechanism acc. to No. 2.2.5 Annex I Regulation (EC) No 715/2009)?

d) Transactions relating to overbooking and/or buyback of capacities (According to No. 2.2.3. Annex I Regulation (EC) No 715/2009):

Shall the TSOs report transactions for Buyback of capacity (In case of over-demand the TSO buys back the primary capacity itself)?

Shall the TSOs report transactions for Buyback of rights to nominate (In case of overdemand the TSO buys back the right to nominate (in main or reverse flow direction) but the capacity contract in this case still remains with the shipper)?

e) Day-ahead UIOLI – renomination restrictions – Shall the TSOs report the renomination restrictions?


Answer:

According to the Agency’s current understanding, the following applies:

a) Successful surrender of capacity shall be reported as contract modification, insofar as capacity is reallocated to a new customer and therefore remains with the new customer and the original contract is adjusted accordingly.

The relevant information shall be reported only in case of successful surrender.

b) Transactions in case of re-surrender of capacity shall not be reported, because in this case the capacity could not be reallocated and remains with the original customer.

c) Withdrawal of capacity rights shall be reported as contract modification, insofar as capacity is reallocated to a new customer and therefore remains with the new customer and the original contract is adjusted accordingly.

The relevant information shall be reported only in case of successful application of LT UIOLI procedure.

d) The Agency understands that in case the TSO is buying back primary capacity on the basis of a bilateral contract between the TSO and the market participant this transaction will be reported by the TSO as a new contract for primary transportation capacity. In case the buy-back procedure is handled by the TSO buying back capacity on the secondary market (or the right to nominate via transfer of use) this transaction will be reported by the OMP.

e) The Day-ahead UIOLI transactions shall not be reported because the renomination restrictions are initially included in the contracts, which means that if applied, this cannot be considered as contract modification.

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