Code Modification Forum...2018/09/26 · 2018/ 2019 Maintenance Days Maintenance Programme Gas Year...

Code Modification ForumAshling Hotel,

Dublin

Wednesday, 8 August 2018

Agenda (1 of 2)

1. Review of minutes from last meeting

2. Review of Action Items from last meeting

3. GNI Scheduled Maintenance Update –Operational /IT

4. Intra-day Nomination Patterns and Profiles / Cod Mod Proposal A086-Incentives for Intra-day Balancing

5. Code Modification Proposal A087- Implementing a new framework for Suppliers to contract their payment

channels for PPM customers

6. Biogas update including review of 1) Code Modification Proposal A091- Modification of oxygen content levels for

Renewable Natural Gas (RNG) injected from RNG Entry Points and, 2) Code Modification Proposal A093-RNG Outline

Code Modification

2

Agenda (2 of 3)

7. Code Modification Proposal A095- Adjustment of Daily Shipper Imbalance Charges/ Code Modification Proposal

A094 – Changes to Shipper Portfolio Tolerances –Industry Response to Questionnaire

8 . Gas /Electricity Interaction interaction

9. Security of Supply Regulation 2017/1938 . Art.14 – Information Exchange

10. Data Sharing Agreement

11. Brexit and ROI Gas Market

12. Transparency Data Update

13. Website Feature Update

14. Trading Platform Update- GNI Participation

15. AOB

Next Code Modification Forum Meeting3

1. Review of minutes from last meeting

4

2. Review of Action Items from last meeting

5

ID Action Responsibility Status Priority

C538 Transporter to continue consultation process surrounding intra-day nomination patterns

and profiles

Transporter Open High

C560 Transporter to draft and circulate and circulate to Industry worked examples on capacity

charging

Transporter Propose to close

High

C562 Transporter to furnish Questionnaire to CMF Mailing List with the Minutes of the CMF

Meeting on 13 June in relation to proposed changes to the calculation of the cashout

price regime/ retention of Tolerances


High

C563 Transporter to furnish DM and LDM accuracy data in aggregate to the CMF Mailing List

and to subsequently answer specific Shipper queries


High

C564 Transporter to inform KEL, under their OBA, of the proposal to gradually remove the Inch

Entry Point Tolerance


High

C565 Transporter to organise a telco with the CRU and Industry to consider a Modification for

the IBP 15 Terms


Medium

C566 Transporter to circulate to the CMF Mailing List and upload unto its Website the Allowed

Revenues and Tariffs for Distribution and Transmission for 2018/19


High

Code Modification Forum – Open Actions (Slide 1 of 2)

6

3. GNI Scheduled Maintenance Update

Code Modification Forum

7

Network Maintenance Update

8

Location Nature of WorksPlanned Timings (Subject to change)

Duration (days)

Entry/Exit Points Affected

Impact on flows at entry/exit points affected

Bellanaboy

Bridge Gas

Terminal

Maintenance 10/9/2018-14/9/2018 5BellanaboyEntry Point

No Flows

1. Upstream Operator Maintenance

GNI have been advised of the following scheduled Maintenance Upstream of Entry Points:

2017/ 2018 GNI Proposed Maintenance Days

Maintenance Programme Gas Year 2017/2018

Date DurationEntry Points

Commentary

7th Feb 20181 day Corrib Not required

1 day Inch Not required

31 May-1June 9 May

1 day Corrib SCADA signal validation testing . Now postponed due to deferment of SEPIL transition date

1 day InchIn-Line Inspection (ILI) run between Inch, Lochcarrig Lodge and Caherlag. Date to be finalised with pigging contractor/Odorant tank refill at Inch. Zero flow whilst this takes place.

4th Jul 20181 day Corrib

Fuel gas skid connection at Cappagh South. May not affect flow. Now postponed, was scheduled to tie-in withmaintenance which is now deferred

1 day Inch Not scoped yet

12th Sep 20181 day Corrib Not scoped yet

1 day Inch Not scoped yet

9 Note: Dates and maintenance programme may be subject to change

2018/ 2019 Maintenance Days

Maintenance Programme Gas Year 2018/2019

Date Duration Entry Points Commentary

8th November 2018 1 Inch Deferred in line inspection. Risk to flow during intelligent pigging run

7th March 2019 1 Bellanaboy Station testing, valve check and validations at Cappagh South.

9th May 2019 1 Inch Odourant injection system planned maintenance

4th Jul 2019 1 Moffat Station testing, valve checks and validations at Beattock and Brighouse Bay compressor station

12th Sep 2019 1 Bellanaboy ESD testing at the Corrib Terminal

10

IT Maintenance Update

11

Nature of Works Planned Timings (Subject to change) Duration (days) Systems Affected

Nothing to report

Please note the above works/timings/duration are subject to change

4. Intra-day Nomination Patterns and Profiles /Code

Mod Proposal A086 –Incentives for intra-day

Balancing


12

Outline of proposed GNI Modification A086

• Modification Raised by GNI to address concerns that the aggregate system imbalance intra-day is creating operational difficulties.

• At times, there are large deviations between the prevailing exit nominations on the system and the prevailing entry nominations. GNI wish to introduce an incentive to encourage more alignment of entry and exit

• PROPOSAL: At check points during the gas day (11:00, 17:00, 23:00) a shippers portfolio Nomination Imbalance position will be recorded.

• A tolerance will be applied at each point

• Worked Example: A shipper has 24 units of Aggregate Exit Nomination at 11:00.

‒ Deemed flow at Exit = (24 units * 6hrs/24hrs) = 6 units

‒ Total Entry Nomination = 4 units

‒ Apply a [10%] tolerance: Adjusted Nomination Imbalance Position

Nomination Imbalance Position = (6 * 90 %) – 4 = 1.4 units

‒ The Adjusted Nomination Imbalance Position at the 3 time checks will be added

‒ The total for the day will be multiplied by [SAP] * [x%]

‒ The amounts for each day in a month will be invoiced at month end.

13

Impact if Code Mod was applied in November 2017 –July 2018

• There was a marked improvement in Shipper Nominations following discussions of the proposed modification at

recent code mod forums. The estimated monthly financial impact dropped from €334k (November) to €67k

(January).

• However, during Mid February to June late day nominations (attributable to 3 Shippers) has resulted in almost

hourly batches late in the gas day, causing operational difficulties once again for both GNI and National Grid.

• July has seen an improvement in the behaviour of these 3 Shippers

14


15

NOVEMBER, €334,187.70

DECEMBER, €161,895.41

JANUARY, €67,255.77

FEBRUARY, €115,850.34

MARCH, €252,503.70

APRIL, €264,125.36

MAY, €185,562.38

JUNE, €451,826.77

JULY, €155,892.22

0

50000

100000

150000

200000

250000

300000

350000

400000

450000

500000

NOVEMBER DECEMBER JANUARY FEBRUARY MARCH APRIL MAY JUNE JULY

Intraday Imbalance Nov 2017 - July 2018

NOVEMBER

DECEMBER

JANUARY

FEBRUARY

MARCH

APRIL

MAY

JUNE

JULY


• Assume 10% Exit Tolerance and charging of 5% of SAP

16

November 2017 December 2017

• 8 shippers would have received charges ranging from €365 to

€148k

• Total charges: €334k

• 92% of charges attributable to 3 shippers


€124k


• 96% of charges attributable to the same 3 shippers

January 2018 • February 2018


€30k



• 7 shippers would have received charges ranging from

€15.20 to €72k



March 2018 • April 2018

• 6 Shippers would have received charges ranging from €86 to

€149k



• 5 Shippers would have received charges ranging from €23k

to €114k




17

May 2018

• 3 Shippers would have received charges ranging from €30k to

€101k



June 2018


€295k


• 99% of charges attributable to same 3 shippers

July 2018


€73k


• 98% of charges attributable to same 3 shippers

Shipper May to June

Increase/ Decrease

June to July

Increase/ Decrease

1 191% Increase 92% Decrease



5. Code Modification Proposal A087-,Implementing a

new framework for Suppliers to contract their own

payment channels for PPM customers


18

A087: Proposal for new contractual arrangements for PPM front office services

• The front office service providers (Payzone, An Post) provide a service to gas suppliers and gas customers i.e. they facilitate customers topping-up (vending) and collect money from customers to be subsequently re-distributed to the relevant gas supplier.

• Suppliers pay the front office providers for the service.

• GNI proposes to change current arrangements so that Suppliers, rather than GNI, procure and contract for these services.

19

Figure: Proposed contractual arrangements

A087: Discussed at GMARG with mixed views from suppliers

Comment

Supplier 1 In favour of proposals

Supplier 2 Concern that smaller suppliers and/or new entrants would be disadvantaged

Supplier 3 Concern that larger suppliers would be able to negotiate better terms than smaller and

concern related to resolution of industry wide issues

Supplier 4 Opposed to the proposal

20

Table: GNI received 4 written submissions from suppliers

Other issues raised in discussions included

• Contingency

• Timeline for implementation

A087: Discussed at GMARG with mixed views from suppliers

Comment

Supplier 1 In favour of proposals

Supplier 2 Concern that smaller suppliers and/or new entrants would be disadvantaged

Supplier 3 Concern that larger suppliers would be able to negotiate better terms than smaller and

concern related to resolution of industry wide issues

Supplier 4 Opposed to the proposal

21

Table: GNI received 4 written submissions from suppliers

Other issues raised in discussions included

• Contingency

• Timeline for implementation

A087: Transporter view

• GNI maintains its view that it should not be within the remit of the DSO to procure this service on behalf of suppliers.

• The risk associated with a single procurement of front offices services, which was highlighted during the last procurement process, can be lessened by multiple procurements.

• GNI have put in place two front office service providers that suppliers already have existing relationships with.

• Suppliers should be free to contract with whatever front office providers they can reach a commercial agreement with and GNI should not be involved in these negotiations.

• GNI accepts it will maintain a co-ordination role across the market.

22

6.Biomethane Code Modifications/ BiomethaneProject

• Code Modification Proposal A091-Modification of oxygen content limits for Renewable Natural Gas

(RNG) – under review

• Code Modification Proposal A093 –RNG Outline Code Modification at legal drafting

• Biomethane Project update will be presented at September CMF Meeting

23


7.Code Modification Proposal A095- Adjustment of

Daily Imbalance Charges/Code Modification Proposal

A094- Changes to Shipper Portfolio Tolerances-

Industry Response to Questionnaire


24

Industry Responses to Questionnaire

QUESTION RESPONSE

Q1: What do you believe is the

appropriate tolerance level for

each category of customer

(LDM, DM and NDM)?

IOOA response

• LDM 0%,

• DM 0%

• NDM – Tolerance should be the difference between the nomination at the TSO

forecast level and the allocation.

• Argues providing 2.5 % tolerance to NDM Shippers may provide commercial

advantage to NDM Shippers with large NDM portfolios.

Manx Utilities response

• fully supports the removal of tolerances.

25

These are summary responses only. A copy of the complete responses will be circulated.


QUESTION RESPONSE

Q1: What do you believe is the

appropriate tolerance level for

each category of customer

(LDM, DM and NDM)?

SSE Airtricity Response

• Broadly supports the removal of tolerances when network users have access to

sufficient information regarding their inputs and offtakes.

• Argues that although there is sufficient information for most of the gas day for

LDM sites, during the dead-band period from 00:45, gas traders must use their

own judgement to nominate what is expected for the remaining hours of the gas

day.

• Supports the application of a small tolerance of 2.5% to compensate for the

dead-band period.

• Suggests that a tolerance should be applied to the DM sector given the lack of

metered information available.

26



QUESTION RESPONSE

Q1: What do you believe

is the appropriate

tolerance level for each

category of customer

(LDM, DM and NDM)?

BGE Response

• NDM 2.5 %

• DM 10% - Argues that there is no visibility on volumes during the and it is not possible

to accurately predict their final run .

• Suggests a special dispensation for Powergens: they should not be penalised for

changing volumes, as a result of Eirgid, between the period from 00:00 to 05:00, as

this is beyond the control of Shippers.

Equinor Response

• Believes zero tolerances be applicable for LDM and DM Shippers, and that removal of

these tolerances will boost liquidity at the IBP.

• Suggests that NDM Shippers should receive a tolerance for the difference between

allocations and nominations.

27



QUESTION RESPONSE


is the appropriate



(LDM, DM and NDM)?

Tynagh Energy Response

• Suggests LDM should have a similar methodology to that of NDM : the absence of

tolerances and associated costs if the participant follows TSO nomination advice. If a

generator does not nominate in line with their Eirgrid indicative schedules, tolerances

should be applied.

ESB Response

• Are not satisfied that conditions Article 50.1 (a),(b) and (c) have been adequately met

and until such time that they are tolerances should be maintained

• Recommends that Power Generators receive similar treatment to that of NDMs, in

relation to instruction from the electricity TSO.

• Recommends keeping tolerances for DMs and that any reduction on the current 30%

needs to be monitored.

28



QUESTION RESPONSE


is the appropriate



(LDM, DM and NDM)?

Electric Ireland Response

• Believe tolerances should be maintained, that their removal poses a particular difficulty

to the DM Sector, due to lack of access to up to date information.

Naturgy Response

• Argues that until there is real time access to all DM sites hourly consumption tolerance

levels should not be amended.

• Argues that as LDM sites have hourly telemetry (and the latest time for submitting

renominations is 02:00) tolerances should be reduced, but not reduced to zero.

• Recommends 10% tolerance for LDM3 and 5% tolerance for LDM2

• Agrees that NDM tolerance could stay at 2.5%

29



QUESTION RESPONSE

Q2: What are your views

as to the appropriate dates

for the two-step reduction

proposed?

IOOA Response

• Questions whether there is time available for a meaningful period of reduced tolerances

and whether a two-step approach is required.

Manx Utilities Response

• Suggests removal of tolerances in one-step by August 1st.

• Argues the proposed two step reduction would require additional resources to manage the

difference in tolerances between August 1st and October 1st.

30



QUESTION RESPONSE

Q2: What are your views as to

the appropriate dates for the

two-step reduction proposed?


• Propose a one-step reduction rather than two-step.

• Argues a two-step process would add a layer of complexity, requiring shippers to

amend internal processes following the first step

• Suggest that the following 3 factors must be taken into consideration by GNI,

prior to the removal of tolerances:

1. I-SEM go live

2. Boosting liquidity at the IBP

3. Internal process for Shippers, i.e. 2 months for updating and training.

• Propose an implementation period between December 2018 and February 2019

to allow sufficient time for Shippers to update their internal processes.

BGE Response

• Believe that the two steps are too close together.

• Agrees that the first step should be to 50% levels, but the second step to zero

(not including NDM and DM, as per Q1) should be approximately 6 months after

the first step.

• Proposed dates:

• Step 1 – October 1st 2018

• Step 2 – April 1st 2019.

31



QUESTION RESPONSE

Q2: What are your views as to the

appropriate dates for the two-step

reduction proposed?

Equinor Response

• Does not support GNI’s proposal of a two-step reduction in tolerances.

• Believes a two-step reduction introduces an unnecessary layer of complexity.

• Suggests the new tolerances levels should be implemented on 1st October

2018


• Disagrees with the proposed methodology, however if it were to be

implemented a phased approach with a long lead in time would be preferable.

ESB Response

• Recommends that any reduction in tolerances should be implemented once I-

SEM is live and stable and after the winter period. Suggests requesting from

ACER a continuation of tolerances after April 2019.


• Welcome a two-step reduction approach, however suggest a more gradual

removal over a longer period to give users the opportunity to adjust to a non-

tolerance regime.

32



QUESTION RESPONSE

Q2: What are your views as to the

appropriate dates for the two-step

reduction proposed?

Naturgy Response

• Considers a two-step reduction appropriate for the sectors impacted by the

decision.

• Recommends a 12 month period between steps, as it will take some time for

shippers to improve their processes.

• Proposes final implementation date of 1st October 2019.

• Recommends that new entry points should have a “soft-landing” period of 12

months where a tolerance of 5% would be allowed for the difference between

nominations and allocations.

33



QUESTION RESPONSE

Q3: What is your view as to the

magnitude of the small adjustment

to be used in the calculation of the

marginal sell price and the

marginal buy price?

IOOA Response

• Support the proposed application of IBP SAP or NBP SAP, for First Tier

imbalances.

• Support the proposed 3.5% adjustment, for Second Tier imbalances.

• Suggests that the small adjustment applied should be reviewed on a regular

basis. The review should determine the following:

1. The net cost of implementing balancing actions on the GNI system

2. Whether the adjustment is cost reflective and appropriate, taking into

consideration that the adjustment should be an incentive to balance, not

to penalise.

• Recommends that the first review be completed after six months.

34



QUESTION RESPONSE

Q3: What is your view as to the

magnitude of the small

adjustment to be used in the

calculation of the marginal sell

price and the marginal buy

price?


• Argues that the GNI proposed small adjustment is too high.

• Suggests a maximum small adjustment of plus or minus 2%


• Argues that applying an adjustment which is based on a percentage of SAP could

result in excessive punitive adjustments.

• Suggests that given then link between Irish and GB markets that the application of

a monetary cap would give certainty to Shippers, lowering risk, given the removal

or reduction of tolerances.

• Also suggests a variation on the above whereby, the small adjustment (in c/therm)

is applied at a level that corresponds to the average of 2.5% of NBP spot prices

over a period of 1 year,

• Suggests the above approach would remove fluctuations which would arise where

the small adjustment is linked to the wholesale market.

35



QUESTION RESPONSE

Q3: What is your view as to

the magnitude of the small




price?

BGE Response

• Believe the adjustment can be set at 3.5%, but should be reviewed after an

appropriate period of time i.e. 3-6 months.

Equinor Response

• Supports GNI’s proposal of a 3.5% adjustment, as it is keeping with other European

markets.

• Recommends that the adjustment be reviewed after 6 months of implementation.


• Contends the 3.5% stating they are unclear as to how it was calculated.

• Recommends an adjustment of 2%.

36



QUESTION RESPONSE

Q3: What is your view as to

the magnitude of the small




price?

ESB Response

• Argues that that the proposed adjustment has not been justified with any analysis.

• Suggests an adjustment of 0.5%


• Considers the adjustment of 3.5% is reasonable as a first step, but suggests that it

should be monitored and changed if necessary.

Naturgy Response

• Believes a +/- 2% adjustment is enough of an incentive for shippers to minimise

imbalances.

• Argues that an adjustment above +/-2% could give rise to excessive financial

exposure at current gas prices.

37



QUESTION RESPONSE

Q4: Do you believe the liquidity

threshold criteria provided

above are appropriate?

IOOA Response

• Is satisfied with the four metrics proposed by GNI.

• Queries what happens if the metrics are not met.

• Queries whether metrics 1 – 3 will be used as a guidance, as the minimum

requirements, before IBP SAP can be published on a day.


• No objections to the metrics proposed by GNI

38



QUESTION RESPONSE

Q4: Do you believe the

liquidity threshold criteria

provided above are

appropriate?


• Deem the four metrics proposed by GNI to be appropriate and that metrics 1 – 3

have broadly been met.

• Argues that when the four metrics are not met then the default to the NBP should

apply

• Seeks clarification on the review period specified for metric 4.

• Queries whether the Second Tier sell price should be SAP NBP – 5% minus

Transportation costs, where a valid SAP IBP is not published.

BGE Response

• Regard the metrics proposed by GNI to be low and therefore room for

manipulation.

• Recommends that the metrics be constantly reviewed and immediately acted upon

if manipulation is suspected.

39



QUESTION RESPONSE



provided above are

appropriate?

Equinor Response

• Supports GNI’s proposed liquidity threshold criteria.

• Recommends that the threshold should be reviewed in conjunction with the small

adjustment.


• Questions what the methodology for the criteria has been based off. Questions if

they are recognised threshold methodologies.

ESB Response

• Considers the liquidity measure wholly inadequate.

• Recommends that an independent liquidity assessment be carried out by a

recognised body in European energy trading, such as EFET.


• Considers the liquidity threshold criteria appropriate.

• Recommends that It be reviewed after either a period of time i.e. 1 year, or after a

specific number of trades.

40



QUESTION RESPONSE



provided above are

appropriate?

Naturgy Response

• Believes the liquidity threshold criteria is appropriate.

41



QUESTION RESPONSE

Q5: What is the appropriate

date for the implementation of

the new methodology for

calculation of the cashout

prices?

IOOA Response

• 1st October 2018 and it should coincide with the removal of tolerances.


• 1st October 2018


• Suggests that the new methodology should be applied as soon as possible, in light of

the fact that liquidity at the IBP has been demonstrated.

BGE Response

• 1st October 2018, in line with new tolerances.

42



QUESTION RESPONSE

Q5: What is the appropriate

date for the implementation of

the new methodology for

calculation of the cashout

prices?

Equinor Response

• 1st October 2018


• 1st April 2019

ESB Response

• Recommends implementation after I-SEM is live and stable.


• Suggests waiting for a larger number of trades to ensure prices are more stabilised

Naturgy Response

• Recommends no earlier than the 1st April 2019, as GNI have only become active at the

IBP since 1st June.

43


Code Modifications - Live

Number Title of Proposal Proposer Status

A085 Profiling of Gas Flows at Entry Points IOOA Live/Parked

A086 Intra-day Nomination Incentive Proposal GNI Not yet issued

A087 New Framework for Suppliers in PPM Market GNI Live/Consultation

A090 Proposed new Invoice Dispute Resolution Procedure BGES Live/ Parked

A091 Modification of oxygen content limits for Renewable

Natural Gas (RNG) injected from RNG Entry Points

GNI Live

A092 GNI Trading Platform participation GNI Live/Legal Drafting

A093 RNG Outline Code Modification GNI Live/ Legal Drafting

A094 Changes to Shipper Portfolio Tolerances GNI Live/Consultation

A095 Adjustment of Daily Imbalance Charges GNI Live/ Consultation

44


8. Gas / Electricity Interaction

45


46

9. Security of Supply Regulation 2017/1938

Article 14 – Information Exchange

www.cru.ie

Security of Supply Regulation 2017/1938Article 14 – Information Exchange

47

CRU will write to Natural Gas Undertakings (NGUs’)in early September. NGUs’ must

notify CRU of the details of gas supply contracts with a cross border dimension and

a duration of more than one year which it has concluded to procure gas:

• Contract duration

• Yearly contracted volumes

• Contracted maximum daily volumes in the event of an alert or emergency

• Contracted delivery points

• Minimum daily and monthly gas volumes

• Conditions for the suspension of gas deliveries

All information received will remain confidential within the CRU and the Commission.


10. Data Sharing Agreement Update

48

• Conference call held on 5th July

• In advance of the call Energia had circulated a note with detailed comments

• After the call Shippers were asked for input on 3 questions

1. Should DSA be by Ancillary Agreement or incorporated into Code

2. Shippers were asked to provide comments on the content of the Draft Agreement (v181613 GNI Data Sharing Ancillary Document ISSUED)

3. Shippers were asked to provide comments on the points raised by Energia

• Shipper comments to be returned by 26/07/18

49


• 5 Shippers returned detailed comments

• Wide divergence of opinions

• GNI has submitted details of the comments to CRU

• GNI supports inclusion of individual clauses into Code of Operations

‒ Data Controller to Data Controller is a key concept, generally accepted by industry

‒ Current Code needs to be amended to reflect this and other GDPR points

50


51


ShipperBest Structure of Agreement:

Ancillary/Code Mod/Bilateral

Comments on Energia

Comments

Comments on previous Draft

DSAOther Comments

Energia Code Provisions N/AAs circulated to GMARG/

Code lists

Shipper 2 Code ProvisionsBroadly agreed, minor edits

proposed re warranties, indemnitiesMinor edits proposed |Indemnity to be reciprocal

Shipper 3 Note 1

Shipper 4 Code Modifications Support Comments

Shipper 5 Negotiated Bilateral Agreements Generally Supports comments Minor edits proposedConcern on potential CRU function

regulating Data Protection

GNI Position Code ProvisionsReconsidering warranties,

IndemnitiesN/A

Code needs to address GDPR,

recognise Controller to Controller

relationship

1. Shipper indicated it would not be able to submit comments within the timeframe due to leave periods, comments to follow

52


11. BrExit and ROI Gas Market

53

It was expected that progress would be made at the June EU Council Summit, however this did not materialise

UK Government subsequently published a ‘White Paper’ on 12th July. Relevant highlights include:

‘continued cooperation on energy and transport – preserving the Single Electricity Market in Northern Ireland and Ireland,

seeking broad cooperation on energy’

‘exploring options for our future energy relationship – maintaining the Single Electricity Market (SEM) across the island of

Ireland in any eventuality’

The UK is seeking broad energy cooperation with the EU, including arrangements for trade in electricity and gas, cooperation

with EU agencies and bodies, and data sharing to facilitate market operations

The UK wants to explore with the EU the options for the future energy relationship. One option would be for the UK to leave the

Internal Energy Market (IEM). In this case, the UK would explore what would be needed to ensure trade over interconnectors

would continue without automatic capacity allocation via the IEM system.

Brexit – In The News

54

UK Government subsequently published a ‘White Paper’ on 12th July

An alternative option would be for the UK to participate in the IEM to preserve the existing efficient trading practices over

interconnectors

The UK wants to explore with the EU the options for continued Transmission System Operator participation in the Inter-

Transmission System Operator Compensation Mechanism, and continued membership of the European Networks of

Transmission System Operators for Electricity (ENTSO-E) and Gas (ENTSO-G).

142. The UK is also putting in place arrangements so that, when trading after exit, businesses will have certainty that they will

not face substantially different requirements compared to their current obligations under the Regulation on Wholesale Energy

Market Integrity and Transparency (REMIT).


55

White Paper has been broadly rejected by EU officials primarily due to no satisfactory solution to the customs

issue in Northern Ireland

BEIS are continuing to work towards transposing legislation in order to ensure that nothing changes with regards

to day to day processes post Brexit

GNI continue to engage regularly with DCCAE, CRU, BEIS, Ofgem with regard to Brexit impacts and continue to

highlight security of gas supplies as our number 1 priority


56

Brexit – next steps

• White Paper publishedJuly 12th 2018

• Ongoing negotiations between EU and UK

July – September

• EU Summit – most likely opportunity for a final agreement on the UK divorce from the bloc and a statement on future relationsOctober 18/19th 2018

• Emergency summit?

• A further EU summit could be needed to finalise the divorced deal if the deadlock on Ireland continues in October.

November 2018

• The last European Council of 2018

• Widely seen as the last practical date for an Article 50 divorce deal to be signed off by Britain and the EU

December 13/14th 2018

12. Transparency Data Update


57

Transparency Platform: Overview

• 11th May 2018 GNI launched a new Data Transparency Portal.

• The platform’s functionality allows for:

• Data visualisation

• Hourly, daily and Monthly updates and graphical representation of gas-related data:

• Functionality available for users to download historical data

• Hourly inlet and outlet pressures, with mapping to strategic locations on the network58

• Entry/ Exit Flows • Balancing (Actions & Prices)

• Nominations/Renominations • Capacities

• System Imbalance Position • Gas Quality

• VRF • Shrinkage and Stock Gas

• Activity at the IBP • Macroenvironment

Transparency Platform: Statistics, May 11th to June 28th

• Sessions/ Visits to the platform: 1,358

• Number of Users: 506

• Unique Page Views: 5,910

• Average time on visit to Data Transparency Platform: 08:14

59

Most viewed pages include:1. Entry flows2. Exit flows/gas consumption3. Activity @ IBP

Transparency Platform: Statistics, July 1st to July 31st

• Sessions/ Visits to the platform: 744

• Number of Users: 181

• Unique Page Views: 3,079

• Average time on visit to Data Transparency Platform: 06:56

60

Most viewed pages include:1. Entry flows2. Activity @ IBP3. Exit flows/gas consumption


13. Website Feature Update

“For Shippers” Tab on Homepage with relevant links is being scoped . Web developer asked to provide estimate of scale/cost of development work

61


14. Trading Platform Update – GNI Participation

62

Trading Platform: Overview of activity on EBI platform

63

• 1st June 2018 marked the commencement of GNI’s participation in the Irish balancing point (IBP) trading

platform operated by EBI

• The EBI platform is trending towards increased levels of activity with up to 800,000 therms/day being traded

• Activity does decline on days where there are production problems at the Corrib gas field.

• GNI is now contracted with 4 shippers on the platform

• There are 11 shippers trading on the EBI platform

Trading Platform: Overview of activity on EBI platform, June & July 2018

64

0

2

4

6

8

10

12

14

16

0

100

200

300

400

500

600

700

800

900

K T

herm

s/d

ay

Date

Volume Traded and #Trades – June to July 2018

Volume Traded (Left Axis)

# of Trades (Right Axis)

Trading Platform Activity – June 2018

Number of trades Total Volume Traded

202 (average of 7 per day) 12,673 ktherms (Average of 420 ktherms per day)

65

Number of trades involving GNI Total Volume Traded

20 (average of 2 trades in every 3 days). 19 balancing sells and 1 balancing buy.

1600 ktherms

Platform in General

GNI participation


66

46.0

48.0

50.0

52.0

54.0

56.0

58.0

60.0

62.0

pence/therm

UK NBP SAP Versus IBP SAP - 1st June to 30th June

SAB IBP (p/therm) SAP NBP (p/therm)

Trading Platform Activity – July 2018

Number of trades Total Volume Traded

176 (average of 5 per day) 11, 168 ktherms (Average of 360 ktherms/day)

67

Number of trades involving GNI Total Volume Traded

13 (13 Balancing sells) 1,250 ktherms

Platform in General

GNI participation


68

48.0

50.0

52.0

54.0

56.0

58.0

60.0

pence/therm

UK NBP SAP Versus IBP SAP - 1st July to 31st July

SAB IBP (p/therm) SAP NBP (p/therm)


15. AOB

69

1. Upcoming Code Modification Forum Meetings

70

CMF Dates 2018 Location

7th March 2018 (Wednesday) Cork

2nd May 2018 (Wednesday) Dublin

13th June 2018 (Wednesday) Cork

8th August 2018 (Wednesday) Dublin

26th September 2018

(Wednesday)Cork

28th November 2018

(Wednesday)Dublin

Next Meeting

Thank you for your participation

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