Wednesday 19 April 2023

Richard Fairholme

UNC Modification Proposal 0295 -

“Allocation of Daily NTS Entry Capacity

Within-Day”

A bid for daily (firm) entry capacity is submitted on Gemini

National Grid thinks about it…

Shipper is left waiting...

Meanwhile…Time is running out!

Entry capacity allocations made too late to be of commercial use

No prescribed timescales

Scope for:

Security of Supply implications

Disputes as regards when allocations should be made

A Summary of the Current Problem

This Proposal

A bid is submitted (or existing bid amended) on the ‘Gemini’ system

On the next hour bar, National Grid NTS must consider the bid (i.e. initiate a Capacity Allocation Period)

Shipper’s bid must be either accepted or turned down in next Capacity Allocation Period.

or

Max. 1 hour 15 minutes

The Case for Change

• Aim of Proposal is to codify existing operational ‘best practice’ by National Grid NTS - NOT to introduce a completely new way of working.

• ‘Best practice’ works well under favourable conditions, but if the system is pushed (e.g. an entry terminal failure on the day) , where is the guarantee that Shippers’ daily capacity bids will be dealt with in a timely and consistent manner?

19 April 2023, E.ON, Page 4

The Case for Change

• The existing UNC rules are ambiguous and open to interpretation as to when

during the day National Grid NTS must allocate capacity once a bid has been

submitted. If the UNC rules were to be strictly interpreted, National Grid

NTS may only have to initiate one capacity allocation period (per

ASEP) each gas Day – regardless of number / timing of Shipper

bids submitted.

• If UNC Mod 284 is implemented, due to cost pressures, daily entry capacity

bookings are likely to more closely match actual gas flows.

= a much more active within-day market This Mod Proposal provides added flexibility and certainty for

Shippers to bid for within-day firm entry capacity: Important for those

Shippers with a variable supply portfolio.

Any Questions?

, E.ON, Page 6