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Moyle & East West Access Rules Approval

Moyle & East West Access Rules Approval. 22 nd FUI Implementation Group Meeting London , 30 September 2011. NRAs’ LT Capacity Allocation Requirements. Following discussion at FUI IG meeting 9 th May, NRAs issued paper with guidance for FUI ICs on co-ordination of LT capacity allocation

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Moyle & East West Access Rules Approval

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  1. Moyle & East West Access Rules Approval 22nd FUI Implementation Group Meeting London, 30 September 2011

  2. NRAs’ LT Capacity Allocation Requirements • Following discussion at FUI IG meeting 9th May, NRAs issued paper with guidance for FUI ICs on co-ordination of LT capacity allocation • Two drivers: • Infringement letters in 2010 from the European Commission citing non-compliance with Chapter 3 of the CMG • Need for a common regional approach to achieve internal electricity market by 2014 - CASC-CWE cited as a good example of regional co-ordination • Minimum NRA requirements set out: • Implement previously identified quick wins • Develop identical access rules for Moyle and East West • Explain residual differences compared with IFA access rules • Explain why full compliance with Ch. 3 of CMG not possible

  3. NRAs’ LT CACM Requirements (contd.) • CACM Framework Guidelines envisage: • a single auction platform • a single set of rules for allocation and nomination of transmission rights and secondary trading • Two possible paths to get there: • Sequential approach, with individual IC timetables for joining CASC-CWE • Common regional approach, with common set of rules and a common platform, before joining CASC-CWE • IC owners asked for views on the most efficient path

  4. Progress since 20th May 2011 • 15th July paper from IC owners, with line by line comparison of the four sets of access rules • Moyle and East West access rules substantially redrafted, using IFA rules as a template • Remaining differences between Moyle and East West included: • Credit cover provisions • Timing of auctions • Remaining differences between Moyle/East West and IFA/BritNed • Nomination, intraday, trading day definition - market design differences • Curtailment – IFA differs from the rest • Late payments and interest rates - legal differences • Manifest error - IT-related • Force majeure – legal systems

  5. Compliance with Chapter 3 of the CMG • CMG require in the FUI region: “common coordinated congestion management method and procedure for the allocation of capacity to the market at least annually, monthly and day ahead” • All ICs in the region will offer annual, monthly and day ahead products … but does not preclude the allocation of additional capacity products • Allocation methodologies and processes are aligned • Coordinated structures for allocation of capacity in the different timeframes are in place – same auction specifications, same bidding rules, same results publication timetables, same secondary trading • Consistent contractual framework in place • IC owners will consult on auction timings

  6. Response by NRAs - 8th August • Recognised the good work that had been done • Raised questions about Moyle and East West rules: • Credit cover • Timing of daily auctions • Interest and late payments • Requested timetable for implementation of quick wins in the IFA and BritNed rules • Pointed to areas for further co-ordination and more information: • Force majeure • Curtailment • Firmness • Capacity products • Treatment of losses • Consistency of quick wins with CASC-CWE rules

  7. NRAs’ Final Position on Moyle & East West • Meeting with IC owners on 30th August • NRAs’ final position on Moyle and East West: • Need for demonstration of explicit compliance with the transparency requirements of Regulation (EC) 714/2009 • Removal of references to congestion charging in the rules • Once intra-day trading in SEM is in place, rules will need revision to allow for UIOLI/UIOSI • Description of the relationship between long term, day ahead and intraday capacity (incl. nomination, allocation and UIOLI/UIOSI) • Harmonised definition of force majeure • Submission of final set of access rules for approval at SEM Committee and Ofgem Executive Board meetings at end-September • Outcome

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