code modification forum - gas networks ireland · 2018/9/26 · 1 day corrib scada signal...

Code Modification ForumClayton Hotel,

Cork

Wednesday, 13 June 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

4. Biogas/CNG Update

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

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

channels for PPM customers

7. Code Modification Proposal A090- Proposed new Invoice Dispute Procedure

2

Agenda (2 of 3)

8. Code Modification Proposal A092- Adjustment of Daily Shipper Imbalance Charges

9. Code Modification Proposal A094 – Changes to Shipper Portfolio Tolerances

10. Update on GNI participation on EBI Trading Platform

11. Modification Rules for IBP 15 Terms

12. Gas /Electricity Interaction interaction

13. Brexit and ROI Gas Market

14. Transparency Data Update

15. AOB

Next Code Modification Forum Meeting

3

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

C559 Transporter to circulate to the CMF Mailing List a work document in relation to Website Transporter Open High

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

charging

Transporter Propose to close

High

C561 Transporter to issue a Code Modification Proposal to obtain approval of amendments to

Cade of Operations enabling GNI trade on a Gas Trading Platform. Subsequently, the

Transporter will arrange a telco with Industry and CRU, 7 days after issuing Code

Modification Proposal

Transporter Propose to close

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

NOTHING TO REPORT

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 Inch Odorant tank refill at Inch.

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. Biogas/CNG Update

12


The Causeway Project

Reducing emissions and increasing renewables.

15

Learn more at www.causewaystudy.eu

http://www.causewaystudy.eu/

Cush RNG Injection Project

Code Modification Forum Update

13 June 2018

Agenda

17

Biomethane Potential in Ireland

The Cush RNG Injection Project

Production site

Injection site

Legal, Safety, Regulatory & Market Development

Next Steps

Biomethane Potential in Ireland

Policy Background

• Ireland’s renewable energy sources (RES) target is

16% RES by 2020.

• Ireland’s Greenhouse Gas (GHG) emissions target is

20% less CO2 by 2020 relative to 2005.

• Road and rail transport contributes ~ 29% of non-ETS

GHG emissions.

• Agriculture contributes ~ 46% non-ETS GHG

emissions.

• Ireland is set to miss both RES and GHG 2020 targets.

Fig.1 EPA non-ETS GHG emissions forecast for 2020

19

Renewable Gas Potential in Ireland

20

• “The Member States with the largest

potential growth of biogas

production between 2014 and 2030

are Ireland and Romania”,

(European Commission Report1).

1Kampman et al. 2016. “Optimal use of biogas from waste streams; An assessment of the potential of biogas from digestion in the EU beyond

2020”. Available at: https://ec.europa.eu/energy/sites/ener/files/documents/ce_delft_3g84_biogas_beyond_2020_final_report.pdf

Biogas Potential in Ireland

• Assessment of Costs and Benefits of Biogas and

Biomethane;

28% of 2015 natural gas demand can be supplied from

biogas.

Additional grass is the largest bio-resource in Ireland

(35 PJ).

Levelised Cost Of Energy (LCOE) biomethane range

(€24 - €124/MWh) depending on feedstock, scale and

discount rate.

SEAI, 2017. “Assessment of Costs and Benefits of Biogas and Biomethane”. Available at:

https://www.seai.ie/resources/publications/Assessment-of-Cost-and-Benefits-of-Biogas-and-Biomethane-in-Ireland.pdf

21

Reduce carbon footprint of network through

development of Renewable Gas.

20% renewable gas on network by 2030.

20% renewable gas will deliver;

2 million tonnes less CO2 p.a.

7.4% of Ireland’s Final Energy

Consumption.

€200 million euro p.a. avoided energy

imports.

Gas Networks Ireland’s Vision for Renewable Gas

GNI, 2017. Network Development Plan 2017. Available at https://www.gasnetworks.ie/corporate/gas-regulation/system-operator/publications/GNI-Network-

Development-Plan-2017.pdf22

Cush RNG Injection Project

Gas to Grid Project Process Overview

24

Biogas Production

Biogas Pre-treatment

Meets Biogas Quality Requirements?

Biogas Upgrading Process

Biomethane Network Entry

Facility

Meets Natural Gas Quality Specification?

Natural Gas Distribution

Network

Biomethane FlareYes

No

Yes

No

Biogas Quality Monitoring

Biomethane Compressor &

Dispenser

Location: Existing AD facility at

Gorteen Lower, Nurney, Co.

Kildare

Location: Cush Biomethane Network Entry Facility

Pressure Reduction Station

Meets Biogas Quality Requirements?

Yes

No

Production Site

Biomethane Production

• AD Site; Green Generation, Nurney, Co. Kildare

‒ EPA licence to take in 25,000 t/annum of biodegradable

waste plus 25,000 t/annum of pig slurry from farm

• Biogas Pre-treatment Process

‒ O2 dosing control system

‒ Additional activated carbon to control VOCs

• Biogas Upgrading Process

‒ Oxygen < 1%

‒ Moisture – 60 0 C at 4 bar

‒ Methane concentration > 98%

• Compressor Station & Disperser

• Transportation Trailers - ADR compliant26

Injection Site

Cush Injection Site

28

• The Network Entry Facility will contain;

Propane Injection System

Non-Fiscal & Fiscal Flow Meters

Pressure & Temperature Sensors

Gas Analysers (C6 GC + sensors)

Diverter Valves

Pressure Regulators

Odorant Injection System

Biomethane Network Entry Facility

29

GNI will own the following assets;

Remote Operated Valve.

Remote Telemetry Unit.

Connecting pipe to the network

Delivery Facility Operator will own and

operate other assets within the Biomethane

Network Entry Facility

Image curtesy of Thyson Technology UK

Legal, Safety, Regulatory and Market Development

Key GNI Deliverables

Contracts

Connected Systems Agreement

Connection Agreement

Property Arrangements

Code of Operations Modifications

General

Oxygen Content

Tariffs

Interim

Enduring

Staff Training

31

Safety

Measurement Risk Assessment

Safety Integrity Level Assessment

Layer of Protection Analysis

Impact Evaluation & Risk Assessment

Material Change Notice

Technical Specification Document

Local Operating Procedures

Communications Plan

Deployment & Commissioning Plan

Systemisation

Key GNI Deliverables cont’d

Code Modification Proposal A091: Modification of oxygen content limit for biomethane

Proposal:

Increase the current oxygen limit of ≤ 0.2mol% to ≤ 1mol%

Applicable to biomethane entry points and to exit points only

All other gas specification parameters will apply at these points

Relevant entry points will be subject to continuous monitoring of both dew point and oxygen content

Rationale:

Some biomethane sources will not be able to meet the current oxygen limit

Benefits

Modification will enable biomethane producers to meet GNI’s quality specifications

Biomethane production is to be encouraged as it supports, inter alia, the reduction of carbon footprint of

the gas network and the reduction of carbon emissions, thereby helping to future proof the gas network in

Ireland

32

Key GNI Deliverables cont’d

Code Modification Proposal A093: RNG Outline Code Modification

Proposal:

To amend the Code of Operations to provide for biomethane entry points on GNI’s network

Examples:

Part A Definitions: e.g. “Delivery Facility Operator”, “Renewable Gas”

Part E Balancing & Shrinkage: e.g. update formula to include biomethane

Part H Operations: e.g. introduction of RG Entry Points, allowing for their connection to Transmission and

Distribution Systems

Benefits

Enable compliant introduction of biomethane into GNI’s system

Support the promotion of renewable gas industry in ROI

33

Gas Networks Ireland’s Safety Approach

• Design review of Biomethane Network Entry.

• GNI Impact Evaluation and Risk Assessment review.

• Measurement Risk Assessment examined gas quality risks following UK GQ8 methodology.

• Safety Integrity Level (SIL) assessment carried out on 5 key instrumentation loops.

• Layer of Protection Analysis (LOPA) on odourisation equipment.

• Hazop study conducted by DFO examined all process risks both upstream and within the injection

point.

• Material Change Notice to be issued to Regulator.

34

Next Steps

Shipper Activities

• Biomethane Producer / Shipper Agreement

• Shipper Safety Case

‒ Shippers must be licenced to ship RNG

‒ CRU currently reviewing Safety Case guidelines

Will be circulated for consultation

• Shipper Registration at Entry Point

• Shipper Engagement with Green Gas Certification Scheme

• Other Shipper relevant support schemes / initiatives TBD

36

Green Gas Certification Scheme for Ireland

37

Centralised Grid Injection – Supporting Agricultural AD

38

Sustainable

Agricultural

Resources1

On-farm and off-farm

Anaerobic Digestion (AD)2

Gas Entry Hub

Renewable Gas Injection

4Renewable Gas available for Industry,

Residential, and Transport Markets5

Renewable

Gas

Gas processing

and transport 3

Biogas

Produced

• Centralised Grid Injection

Increase access to the gas network

Farmer & community owned ADs

High capacity Gas Entry Hub

Large catchment area

Summary

Ireland has:

Abundant resources for biomethane

production.

Large demand from industry.

Proactive gas network operator.

39

Ireland needs:

Government policy support for

biomethane.

Appropriate regulatory processes.

Affordable interest rates for developers.

5. Intra-day Nomination Patterns and Profiles /Code

Mod Proposal A086 –Incentives for intra-day

Balancing


40

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 [5%] 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.

41

Impact if Code Mod was applied in November 2017 –April 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 February, March and April late day nominations have resulted in almost hourly batches late in the

gas day, causing operational difficulties once again for both GNI and National Grid.

• Grid control, have recently, had to undertake aggressive selling actions to compensate for imbalances on the

system.

• The financial Impact to Shippers in April, if the Code Mod was applied, has increased by 293% compared with

January 2018.

42


43


44

NOVEMBER, €334,187.70

DECEMBER, €161,895.41

JANUARY, €67,255.77

FEBRUARY, €115,850.34

MARCH, €252,503.70

APRIL, €264,125.36

0

50000

100000

150000

200000

250000

300000

350000

400000

NOVEMBER DECEMBER JANUARY FEBRUARY MARCH APRIL

Intraday Imbalance Nov 2017 - April 2018

Total

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

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

• November 2017

‒ 8 shippers would have received charges ranging from €365 to €148k

‒ Total charges: €334k

‒ 92% of charges attributable to 3 shippers

• December 2017



‒ 96% of charges attributable to the same 3 shippers

• January 2018




45

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

• February 2018

‒ 7 shippers would have received charges ranging from €15.20 to €72k



• March 2018

‒ 6 Shippers would have received charges ranging from €86 to €149k



• April 2018

‒ 5 Shippers would have received charges ranging from €23k to €114k



46

6. Code Modification Proposal A087-Implementing a

new framework for Suppliers to contract their own

payment channels for PPM customers


47

Code Mod 87 – Front Office PAYG Contracts

• Recap of Code Modification:

‒ Raised by GNI, this modification seeks to revise the provisions in the Code of Operations related to Prepayment Metering so that Suppliers contract their own payment channels for gas prepayment meter customers rather than be required to be a party to a Front Office Services agreement agreed by the Transporter with third party service providers.

• Status of Code Modification:

‒ This code modification is fundamentally a retail issue and it has been agreed that it should be further discussed at the retail (GMARG) forum

48

7. Code Modification Proposal A090 Proposal from BGE for New Invoice Dispute Resolution

Procedure

49


8.Code Modification Proposal A092- Adjustment of

Daily Imbalance Charges


50

8. Code Modification Proposal A092- Adjustment of Daily Imbalance Charges

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

operated by EBI. As trading at the Irish Balancing Point (“IBP”) develops GNI intends to begin using the IBP traded

prices as the basis for cashing out Shipper imbalances under the Code of Operations. The relevant Articles of the

BAL NC are Art. 22 and Art. 23.

• GNI will publish First Tier and Second Tier Cash-out Prices on 21st of each month until October 1st.

• From October 1st , First Tier and Second Tier Cash-out Prices will be published Daily.

• Following the most recent Code Mod Forum (2nd May) GNI circulated:

‒ Worked examples of Daily Imbalance charges, for Shipper review

51

52

Proposed First Tier Imbalance Cash-out Prices to apply in different scenarios

ScenarioFirst Tier Imbalance Cash-out Buy Price

to Apply to Shippers’ Short Positions

First Tier Imbalance Cash-out Sell

Price to apply to Shippers’ Long

Positions

A. GNI has no balancing (buy or sell) requirements, but there are trades

on an IBP Trading PlatformSAP (IBP) plus 2% differential SAP (IBP) minus 2%

B. GNI has no balancing requirements, and there are no trades on an IBP

Trading Platform

SAP (NBP) plus] 2% differential

(Default Rule)

SAP (NBP) minus 2% differential

(Default Rule)

C1. GNI has balancing buy requirements, and it has to utilise the

balancing services contract, and other parties trades with each other on

an IBP Trading Platform

SAP (IBP) plus 2% differential SAP (IBP) minus 2% differential

C2. GNI has balancing buy requirements, and has to utilise the balancing

services contract, and there are no trades on an IBP Trading Platform

SAP (NBP) plus 2% differential

(Default Rule)


(as per Default Rule - see Section

3.2.8)

D1. GNI has balancing sell requirements, and it has to utilise the

balancing services contract, and other parties trades with each other on

an IBP Trading Platform

SAP (IBP) plus 2%differentialSAP (IBP) minus 2%differential

D2. GNI has balancing sell requirements, and has to utilise the balancing

services contract, and there are no trades on an IBP Trading Platform

SAP (NBP) plus 2%differential

(Default Rule)


(Default Rule)

E. GNI has balancing buy requirements, and trades these out on an IBP

Trading Platform

SAP (IBP) plus 2% differentialSAP (IBP) minus 2% differential

F. GNI has balancing sell requirements, and trades these out on an IBP

Trading Platform

SAP (IBP) plus 2% differentialSAP (IBP) minus 2% differential

53

Proposed Second Tier Imbalance Cash-out Prices to apply in different scenarios

ScenarioSecond Tier Imbalance Cash-out Buy

Price to Apply to Shippers’ Short

Positions

Second Tier Imbalance Cash-out Sell Price to

apply to Shippers’ Long Positions

A. GNI has no balancing (buy or sell) requirements, but there are trades on an IBP Trading Platform

SMPbuy (IBP), which is the equivalent of

SAP (IBP) + 5% Differential

SMPsell (IBP) which is the equivalent of SAP

(IBP) - 5% Differential

B. GNI has no balancing requirements, and there are no trades on an IBP Trading Platform

SMP (NBP) plus 5% differential plus

Transportation Costs

(Default Rule)

SMP (NBP) minus 5% differential minus


(Default Rule)

C1. GNI has balancing buy requirements, and it has to utilise the balancing services contract, and other parties trades with each other on an IBP Trading Platform

SMPbuy (IBP) which is the equivalent of

SAP (IBP) + 5% Differential

SMPsell (IBP) which is the equivalent of SAP

(IBP) - 5% Differential

C2. GNI has balancing buy requirements, and has to utilise the balancing services contract, and there are no trades on an IBP Trading Platform



(Default Rule)



(Default Rule)

D1. GNI has balancing sell requirements, and it has to utilise the balancing services contract, and other parties trades with each other on an IBP Trading Platform

SMP (IBP) which is the equivalent of SAP

(IBP) + 5% Differential SMP (IBP) which is the equivalent of SAP (IBP)

- 5% Differential

D2. GNI has balancing sell requirements, and has to utilise the balancing services contract, and there are no trades on an IBP Trading Platform



(Default Rule)



(Default Rule)

E. GNI has balancing buy requirements, and trades these out on an IBP Trading Platform

IBP Marginal Buy Price

Greater of SMPbuy (IBP) and SAP (IBP)

plus 5% differential

IBP Marginal Sell Price

Lesser of SMPsell (IBP) and SAP (IBP) minus

5% differential

F. GNI has balancing sell requirements, and trades these out on an IBP Trading Platform

IBP Marginal Buy Price

Greater of SMPbuy (IBP) and SAP (IBP) plus 5% differential

IBP Marginal Sell Price

Lesser of SMPsell (IBP) and SAP (IBP) minus

5% differential

Worked Examples of Daily Imbalance Charges : Cash-out Buy Price

54

Scenario 1:

• For a day there have been a number of trades on the platform.

• SAP (IBP) has been published as 50 pence/therm

• GNI has not undertaken any balancing actions on this day

• Price used on day = SMPbuy (IBP) means SAP(IBP) + 5%: 52.5 pence/therm (converted accordingly into euro for settlement purposes)

Max GNI Purchase

(pence/therm)

SMPbuy (IBP) means SAP

(IBP) +5% (pence/therm)

SMPbuy NBP

(pence/therm)

SMPbuy (NBP) +5%

(pence/therm)

Price used on day

(pence/therm)

0 52.5 54 56.7 52.5

Scenario 2:

• For a day there have been no trades on the IBP platform.

• SAP (IBP) has therefore not been published.

• GNI has not undertaken any balancing actions on this day.

• Price used on day = SMPbuy (NBP) + 5%: 56.7 + Transportation costs. (converted accordingly into euro for settlement purposes)

Max GNI Purchase

(pence/therm)



SMPbuy NBP

(pence/therm)

SMPbuy (NBP) +5%

(pence/therm)

Price used on day

(pence/therm)

0 0 54 56.7 56.7 + Transportation Costs

Worked Examples of Daily Imbalance Charges: Cash-out Buy Price

55

Scenario 3:

• For a day, GNI has utilised the Trading Platform to undertake Balancing Buys


• Price used on day = IBP Marginal Buy Price: 53 pence/therm (converted accordingly into euro for settlement purposes)

Max GNI Purchase

(pence/therm)



SMPbuy NBP

(pence/therm)

SMPbuy (NBP) +5%

(pence/therm)

Price used on day

(pence/therm)

53 52.5 54 56.7 53

Scenario 4:

• For a day, GNI has utilised the Trading Platform to undertake Balancing Buys


• Price used on day = IBP Marginal Buy Price: 52.5 pence/therm (converted accordingly into euro for settlement purposes)

Max GNI Purchase

(pence/therm)



SMPbuy NBP

(pence/therm)

SMPbuy (NBP) +5%

(pence/therm)

Price used on day

(pence/therm)

52 52.5 54 56.7 52.5

Worked Examples of Daily Imbalance Charges: Cash-out Sell Price

56

Scenario 1:

• For a day there have been 5 trades on the platform.


• GNI has not undertaken any balancing actions on this day

• Price used on day = SMPsell (IBP) means SAP(IBP) - 5%: 47.5 pence/therm (converted accordingly into euro for settlement purposes)

Min GNI Sale (pence/therm)

SMPsell (IBP) means SAP

(IBP) - 5% (pence/therm)

SMPsell (NBP)

(pence/therm)

SMPsell (NBP) - 5%

(pence/therm)

Price used on day

(pence/therm)

0 47.5 51.3 48.7 47.5

Scenario 2:

• For a day there have been no trades on the platform.

• SAP (IBP) has not been published.

• GNI has not undertaken any balancing actions on this day.

• Price used on day = SMP Sell (NBP) - 5%: 51.3 pence/term (converted accordingly into euro for settlement purposes)




SMPsell (NBP)

(pence/therm)

SMPsell (NBP) - 5%

(pence/therm)

Price used on day

(pence/therm)

0 0 51.3 48.7 48.7

Worked Examples of Daily Imbalance Charges: Cash-out Sell Price

57

Scenario 3:

• For a day, GNI has utilised the Trading Platform to undertake Balancing Sells

• SAP (IBP) has been published as 50 (pence/therm)

• Price used on day = IBP Marginal Sell Price: 47.5 (pence/therm) (converted accordingly into euro for settlement purposes)




SMPsell (NBP)

(pence/therm)

SMPsell (NBP) - 5%

(pence/therm)

Price used on day

(pence/therm)

48 47.5 51.3 48.7 47.5

Scenario 4:

• For a day, GNI has utilised the Trading Platform to undertake Balancing Sells

• SAP (IBP) has been published as 50 (pence/therm)

• Price used on day = Lowest GNI Sell Price: 46 (pence/therm) (converted accordingly into euro for settlement purposes)




SMPsell (NBP)

(pence/therm)

SMPsell (NBP) - 5%

(pence/therm)

Price used on day

(pence/therm)

46 47.5 51.3 48.7 46

Responses from Industry

• Concern at liquidity of EBI platform‒ The fact that conditional terms for using the NBP have to be included as scenarios, suggests that

there are doubts over the platform’s maturity and readiness for imbalance price setting.‒ Consider using average of 7 previous days SAP if no trades occur as in GB (caveated by sufficient IBP

liquidity)

• Concern that “any trade” by the TSO, i.e. any one single trading action, could skew the imbalance price.

‒ Inexperience of GNI in conducting balancing trades‒ Evidence in general of

low volume of trades, some of which appear to be test trades Trades at prices which could be seen as experimental

• REMIT Article 2(2) concerns transactions which give false or misleading signals, or price at an artificial level

No suggestion of wilful market manipulation – but in setting a reference price this should be considered

58


• Use of NBP SMP is incorrect

‒ Pancaking of the +/- 5% small adjustment onto the highest/lowest NGG balancing action price or NBP SAP +/- adjustment

• Points out an error in examples 3 and 4 of the SMPsell(NBP) table

‒ Values are higher rather than lower than the SMPsell NBP (corrected in earlier slide)

• Concerns over the speed of introduction, lack of consultation and transparency, and short timeline to implementation. The five years of interim measures ends in April 2019, so there is more time that can be used to introduce change in a more measured way, including monitoring and review, affording counterparties time to set up contractual trading arrangements, and allowing GNI to gain learning from use of the trading platform.

59

9. Code Modification A094- Changes to Shipper Portfolio Tolerances

• Reasons for Code Modification ;

1. Compliance with Art.50.1 of Commission Regulation(EU)No.312/2014 where appliance of tolerances is prohibited where Shippers do not have access to ;

A short-term wholesale gas market that has sufficient liquidity

Gas required to meet short term fluctuations in gas supply

Sufficient information regarding their inputs and off-takes

2. Removal of tolerances will incentivise Shippers to reduce portfolio imbalances and will as a result increase trading platform liquidity

60

Next Steps - Tolerances

Sector/Size(Annual

Quantity) Exit Tolerance % -

CURRENT

Proposed % – 01 August Proposed % – 01 October

LDM >1,500,000,000

kWh (LDM 1) 3.5 1.75 0

LDM > 260,000,000 to

1,500,000,000 kWh

(LDM 2)

9 4.5 0

LDM >57,500,000 to

260,000,000 kWh (LDM

3)

19 9.5 0

DM 30 of DM Exit Allocations 15 0

NDM 2.5 of NDM Exit Allocations 2.5 2.5

Inch Storage Exit

Point 1.5 1.5 0

IP CSEP Non OBA Day 1.5 1.5 0

IP CSEP OBA Day 0 0 0

Sub-Sea I/C >

1,500,000,000 kWh 3.5 1.75 0

Sub-Sea I/C >

260,000,000 to

1,500,000,000 kWh

9 4.5 0

Sub-Sea I/C <

260,000,000 kWh 19 9.5 0

61

• The BAL NC envisages the removal of tolerance

‒ Interim measures allows the retention until 2019

‒ GNI believes, following recent consultation, that it is now time to move towards removal

‒ The table below outlines a 2 step approach to removal of tolerances at LDM, DM.

‒ Corrib and Inch Entry point Tolerances proposed to move to 0.75% on the 1st of August 2018 and 0% on the 1st of October

2018

Code Modifications - Live

Number

A

Title of Proposal Proposer Status

A085 Profiling of Gas Flows at Entry Points IOOA Live

A086 Intra-day Nomination Incentive Proposal GNI Not yet issued

A087 New Framework for Suppliers in PPM Market GNI Live

A090 Proposed new Invoice Dispute Resolution Procedure BGES Live

A091 Modification of oxygen content limits for Renewable

Natural Gas (RNG) injected from RNG Entry Points

GNI Live

A092 Trading Platform participation and adjustment of Daily

Imbalance Charges

GNI Live

A093 RNG Outline Code Modification GNI Live

A094 Changes to Shipper Portfolio Tolerances GNI Live

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• The 3 conditions of Art. 50.1 have not been met

(a) Access to a market that has sufficient liquidity

‒ Spot IBP needs more time to develop

‒ Few trades, partly attributable to low number of commercial agreements in place between counterparties.

(b) Access to gas when required to meet short-term fluctuations

‒ Problematic at the end of the Gas Day

NBP can be accessed until 00:30 and IBP until 02:00

Dead band from 02:00 to 05:00 when sourcing gas becomes an issue

Under I-SEM materiality could grow

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(c) Access to sufficient information regarding inputs and off-takes

‒ Power stations are not in control of their gas offtakes, as they are dispatched by Eirgrid in real time, given indicatives as to the gas take.

‒ NDM allocations are only finalised after the trading day ends.

‒ Impact of I-SEM and DS3 unknown and unquantifiable

Support greater co-operation between gas and electricity sectors

Very disappointed to hear views expressed at the code modification forum that the problem lay solely in the power sector

‒ NDM and DM figures are published Trading D+1, final allocations at D+4

We do not think our concerns about balancing NDM positions were given due consideration at the meeting or in the process

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‒ The removal of First Tier imbalance volumes is in fact a shift from two levels of imbalance charging to one level for all but NDM volumes.

‒ A transition is appropriate and also an assessment, with evidence, of what the correct level of “small adjustment” is to incentivise participants adequately. 3.5% as an initial level for the small adjustment (i.e. between 2% and 5%) would be appropriate to be tried and monitored.

‒ We are concerned that 2%, 5%, 10% and 25% have been in play for imbalance charging recently without evidence basis, and that consultation questions previously issued about the level of small adjustment were selective in their individual scope.

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10. Update on GNI participation on EBI Trading Platform


11.Modification rules for IBP 15 Terms

Two subsequent versions since original 2015 version – April 2018 and May 2018.

Modification Rules for future amendments

Through the CMF process?

Draft Rules?

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12. Gas / Electricity Interaction

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13. BrExit and ROI Gas Market

14. Transparency Data Update


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15. AOB

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1. Upcoming Code Modification Forum Meetings

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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

code modification forum - gas networks ireland · 2018/9/26 · 1 day corrib scada signal...

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