I-SEM Business Liaison Group NEMO. 26 January 2018

Transcription

1 I-SEM Business Liaison Group NEMO 26 January

2 Agenda SEMOpx Implementation Update Block Orders for the Intraday Continuous Market Foreign Exchange Rate SEMOpx Statement of Charges SEMOpx Interim Consultative Forum Interim Modifications Process Market Coupling Facilitator Recovery of Costs related to Invalid Contracted Quantities Previously Raised Rule Changes x2 Liability 2

3 Agenda SEMOpx Implementation Update Block Orders for the Intraday Continuous Market Foreign Exchange Rate SEMOpx Statement of Charges SEMOpx Interim Consultative Forum Interim Modifications Process Market Coupling Facilitator Recovery of Costs related to Invalid Contracted Quantities Previously Raised Rule Changes x2 Liability 3

4 Implementation Programme Solution Delivery Vendor Development Testing Market Trial #N18: DA Regional Coupling Framework Agreement (15/4/17) #N99: Regulator approved Framework Agreement for DA Regional Coupling (1/6/17) #N6: MRC Approval (1/4/18) #N52: DA - MRC, Regional & Member Test complete (30/4/18) Regional Coupling DAM - Framework Agreement IDM - Framework Agreement IT & Process IT & Process Regional, MRC/PCR & Member Tests Regional & Member Tests #N50: ID Regional Coupling Framework Agreement (1/5/17) #N51: Regulator approved Framework Agreement for ID Regional Coupling (1/7/17) #N55: ID Regional Test Complete (30/4/18) On-Boarding Clearing On-boarding #N61c: PCR CR Progress Report (31/1/17) #N61b: PCR CR Progress Report (31/3/17) Exchange On-boarding #N61d: PCR CR Final Decision (31/10/17) PCR Process PCR / EUPHEMIA CR Process Prep. Go-live KEY: RA Milestone; TSO Milestone

5 Previous Meeting Minutes & Actions No. Action Resolution Status 298 RAs to Clarify reasonable tolerances between trades and PNs In NEMO BLG 26/01 Closed 299 SEMOpx to request feedback from Exchange Members on the rule change proposals 300 SEMOpx to consider feedback received as part of proposed rule changes and present finalised rule changes at next NEMO BLG DONE sent out 7/12/2017 Done to be presented at Interim SEMOpx Consultative Committee 26/01 Closed Closed 5

6 Agenda SEMOpx Implementation Update Block Orders for the Intraday Continuous Market Foreign Exchange Rate SEMOpx Statement of Charges SEMOpx Interim Consultative Forum Interim Modifications Process Market Coupling Facilitator Recovery of Costs related to Invalid Contracted Quantities Previously Raised Rule Changes x2 Liability 6

7 Pre-Defined Blocks for Intraday Continuous 22 Pre-Defined Blocks to be offered in IDC for Go-Live Pre-Defined Block One baseload block covering periods 1-48 Three 8 hour blocks Six 4 hour blocks Twelve 2 hour blocks Rationale Manage unit commitment and spread fixed costs across full-day where position not established through DAM/IDA Manage unit commitment and spread fixed costs across a longer period intra-day where position not established Widespread support from participants Access shorter blocks to allow participants to trade in and out of positions in advance of the balancing market and manage scheduling risks. 7

8 Pre-Defined Blocks for Intraday Continuous 8 originally proposed pre-defined blocks (baseload, peak, etc) not included concerns re complexity and over-lapping nature of blocks Increased number of blocks will increase complexity of user interface Recommend reviewing effectiveness after 12 months operation based on experience. Manage change through consultative committee. 8

9 Agenda SEMOpx Implementation Update Block Orders for the Intraday Continuous Market Foreign Exchange Rate SEMOpx Statement of Charges SEMOpx Interim Consultative Forum Interim Modifications Process Market Coupling Facilitator Recovery of Costs related to Invalid Contracted Quantities Previously Raised Rule Changes x2 Liability 9

10 FX Rate - Background Current signed-off solution in SEM and SEM-GB: SEMO (EirGrid/SONI) retrieves the FX Rate on D-2 from the ECB website at 16:00 CET Distributed to the SEM-GB NEMOs Same rate applied to DAM, IDA 1 and IDA 2 Agreed with all Regional Partners important to align a single GBP rate across SEM and GB markets Current solution in GB for the DAM: Nord Pool receive FX Rate from Nordea 15 mins before DAM gate closure Nordea continuously update FX rate Nord Pool publish the rate used on their own website Nordea publish rates 4 times a day Issue: NGIL have stated that while they are in favour of a transparent rate they could not accept one published so far in advance of the DAM gate closure

11 FX Rate - Requirements FX rate is used to convert GBP bids/offers into Euro Results provided in GBP using same FX rate ECC use separate FX rate to settle contracts SEMOpx preferred solution: Transparent rate that is static and traceable Published by a reputable source Maintain the same rate between SEMOpx and SEMO ECB Rate published at D-2 satisfies these requirements we acknowledge a rate closure to the DAM gate closure reduces exposure to rate fluctuations 11

12 FX Rate - Options 1. Multiple GBP FX rates SEMOpx uses GB Solution, SEMO uses ECB D-2 rate System and procedural changes SEM Participants dealing with 2 FX Rates between SEMO and SEMOpx Less transparent SEMOpx and SEMO using ECB D-2, GB parties using current GB solution Lower system and procedural changes Participants that operate in both GB and SEM will need to manage 2 FX rates May need additional agreements, likely additional costs 2. SEMOpx and SEMO address the timeliness issue of transparent rate Lowest system and procedural changes Modification to TSC for timing of FX rate publication Changes to the systems to interface with new FX rate

13 FX Rate Next Steps Identify publicly available source that satisfies SEMOpx requirements and NGIL concerns over timeliness Seek agreement from NGIL Apply changes to solution TSC modification procedure will be followed 13

14 Agenda SEMOpx Implementation Update Block Orders for the Intraday Continuous Market Foreign Exchange Rate SEMOpx Statement of Charges SEMOpx Interim Consultative Forum Interim Modifications Process Market Coupling Facilitator Recovery of Costs related to Invalid Contracted Quantities Previously Raised Rule Changes x2 Liability 14

15 Statement of Charges (1 of 3) The published SEMOpx Tariffs are for the period 23 May October 2019 Fee Structure Cost Once off entry fee 5,000 Annual subscription fee ( for first 16 months of SEMOpx) 5,000 Variable trading fee DAM (per MWh) Variable trading fee IDM (per MWh) The Annual Subscription Fee for SEMOpx Members covers up to one M7 user login and two ETS user logins. Additional user logins will incur additional fees, per user login per system. System Cost M7 ( per additional user login for the 1st 16 months of SEMOpx) ETS ( per additional user login for the 1st 16 months of SEMOpx)

16 Statement of Charges (2 of 3) SEMOpx charges will be invoiced on a monthly basis by ECC on SEMOpx s behalf on the [3 rd ] ECC working day after the end of the calendar month Exchange Members will pay these fees through their Clearing Member or as a Direct Clearing Participant as applicable on the 16 th ECC working day after the end of the calendar month SEMOpx charges will not be invoiced until after I-SEM go live. ECC will invoice for the first 9 days of the new market (23rd May to 31st May) on 7 th June 2018 The invoice issued in June in relation to May will include: total once off entry fee; M7 and ETS additional user fee as applicable; and variable DAM and IDM trading fee (per MWh) for the first 9 days of the market The annual subscription fee will be invoiced from June onwards (1/16 th of 5k ie will be invoiced each month) 16

17 Statement of Charges (3 of 3) ECC Product Group Name Trading Curr Fee Curr Inv. Template Fee Amt SEMOPX_ST_POWER_EGRD Irish Power Day-Ahead SEM EUR EUR EGRD.EUR SEMOPX_ST_POWER_SONI Northern Irish Power Day-Ahead SEM GBP GBP SONI.GBP SEMOPX_IT1_POWER_EGRD Irish Power Intraday No.1SEM EUR EUR EGRD.EUR SEMOPX_IT2_POWER_EGRD Irish Power Intraday No.2 SEM EUR EUR EGRD.EUR SEMOPX_IT3_POWER_EGRD Irish Power Intraday No.3 SEM EUR EUR EGRD.EUR SEMOPX_IT1_POWER_SONI Northern Irish Power Intraday No.1 SEM GBP GBP SONI.GBP SEMOPX_IT2_POWER_SONI Northern Irish Power Intraday No.2 SEM GBP GBP SONI.GBP SEMOPX_IT3_POWER_SONI Northern Irish Power Intraday No.3 SEM GBP GBP SONI.GBP SEMOPX_IT_POWER_EGRD Irish Power Intraday SEM (Continuous) EUR EUR EGRD.EUR SEMOPX_IT_POWER_SONI Northern Irish Power Intraday SEM (Cont.) EUR GBP SONI.GBP SEMOPX_FF_ANNUAL_EGRD Annual Membership Fee EirGrid - EUR EGRD.EUR 5,000 SEMOPX_FF_ANNUAL_SONI Annual Membership Fee SONI - GBP SONI.GBP 4,400 SEMOPX_FF_TECHNICAL_EGRD Technical Fee EirGrid - EUR EGRD.EUR 5,000 SEMOPX_FF_TECHNICAL_SONI Technical Fee SONI - GBP SONI.GBP 4,400 SEMOPX_FF_ENTRY_EGRD Entry Fee EirGrid - EUR EGRD.EUR 5,000 SEMOPX_FF_ENTRY _SONI Entry Fee SONI - GBP SONI.GBP 4,400 SEMOPX_FF_ARANNUAL_EGRD AOLR Annual Service Fee EirGrid - EUR EGRD.EUR SEMOPX_FF_ARANNUAL_SONI AOLR Annual Service Fee SONI - GBP SONI.GBP SEMOPX_FF_ARVARIABLE_EGRD AOLR Volume Based Fee EirGrid - EUR EGRD.EUR SEMOPX_FF_ARVARIABLE_SONI AOLR Volume Based Fee SONI - GBP SONI.GBP SEMOPX_FF_ARENTRY_SONI AOLR Entry Fee EirGrid - EUR EGRD.EUR SEMOPX_FF_ARENTRY_EGRD AOLR Entry Fee SONI - GBP SONI.GBP :stg rate of 0.88 used for illustrative purposes Structure of AOLR fees not yet determined 17

18 Agenda SEMOpx Implementation Update Block Orders for the Intraday Continuous Market Foreign Exchange Rate SEMOpx Statement of Charges SEMOpx Interim Consultative Forum Interim Modifications Process Market Coupling Facilitator Recovery of Costs related to Invalid Contracted Quantities Previously Raised Rule Changes x2 Liability 18

19 Agenda SEMOpx Implementation Update Block Orders for the Intraday Continuous Market Foreign Exchange Rate SEMOpx Statement of Charges SEMOpx Interim Consultative Forum Interim Modifications Process Market Coupling Facilitator Recovery of Costs related to Invalid Contracted Quantities Previously Raised Rule Changes x2 Liability 19

20 Interim Modifications Process - Background K.4 sets out the need for an Interim Consultative Forum until the enduring Exchange Committee has been appointed Purpose: to consult on further development and finalisation of proposed Rules and Procedures Changes to the Rules have arisen to facilitate unforeseen concepts and to modify certain paragraphs Finalisation of the Procedures is needed 20

21 Interim Modifications Process 21

22 Interim Modifications Process - Procedures Date 5 th May 2017 Draft SEMOpx Operating Procedure issued. Next Steps 13 th February 2018 Updated version to be issued and communicated to Market Participants at the BLG. The expected changes cover (but not limited to); Product Types, Auction Timings, general tidy up and removal of sections. 14 th March 2018 The final (baselined) version of the Operating Procedure will be issued for consultation. This version will include; The SEMOpx Fallback and Backup Procedure; o Addresses any required deviation from the normal auction processes and timelines. Post March 2018 Additional modifications to the Operating Procedure may be identified. Establish enduring SEMOpx Consultative Committee and relevant procedures 22

23 Interim Modifications Process - Rules Any changes to the Rules are approved by the Regulatory Authorities C No Trading when Not Authorised under TSC 26 Jan C 2.4 Trading Halt 26 Jan Market Coupling Facilitator 13 Feb Please note, during the interim period, SEMOpx will not be in a position to process Modification Proposals. Any proposals received prior to I-SEM Go-Live will be stored and addressed as soon as practicable under the enduring mods process. 23

24 Agenda SEMOpx Implementation Update Block Orders for the Intraday Continuous Market Foreign Exchange Rate SEMOpx Statement of Charges SEMOpx Interim Consultative Forum Interim Modifications Process Market Coupling Facilitator Recovery of Costs related to Invalid Contracted Quantities Previously Raised Rule Changes x2 Liability 24

25 MCF Background Regional Coupling Pre-coupling Coupling Participants bids and offers Cross-zonal Capacities and Constraints For Moyle, EWIC, and ROI-NI CZC for SEM PMBs Bids & Offers Market Participants NP submit CZC for IFA EPEX submit CZC for Britned

26 MCF Background Regional Coupling Validation of Results Financial Settlement Physical Settlement Final PMB Results Netting of financial positions between CCPs Post-coupling Submission of XB Nominations Congestion Rent Collection of congestion rent and submission to JAO (acting on behalf of the ICOs Shipping

27 MCF Market Coupling Contract SEMOpx is responsible for the allocation of the interconnector capacity The congestion rent is the consideration for the allocation of capacity For the congestion rent to be collected ECC must clear the capacity To clear the capacity it must be a product on the Exchange Market Coupling Contract (MCC) The MCC is only available to one member type -> the Market Coupling Facilitator (MCF) Only Interconnector Owner (or their agent) may become the MCF Changes to the Rules necessary Does not impact other member type Draft Rule and Procedure changes will be presented 13 Feb 27

28 Agenda SEMOpx Implementation Update Block Orders for the Intraday Continuous Market Foreign Exchange Rate SEMOpx Statement of Charges SEMOpx Interim Consultative Forum Interim Modifications Process Market Coupling Facilitator Recovery of Costs related to Invalid Contracted Quantities Previously Raised Rule Changes x2 Liability 28

29 3 - Invalid Contracted Quantities - Background A modification has been raised to the TSC to provide a workable solution to how specific low probability risks related to imbalances, due to invalid Ex-Ante Market Contracted Quantities, are mitigated in the I-SEM, given the interrelationship between the Ex-Ante Markets and Imbalance Settlement. Some elements of the solution would potentially require changes to the SEMOpx Rules, ECC Clearing Conditions, and Trading and Settlement Code. Presented last time Consultative Forum on this Queries raised and comments received since then to be addressed today. Revised proposal provided today

30 3 - Invalid Contracted Quantities - Scenarios Scenario Exchange Member trades in the Ex-Ante Markets before a Unit is effective in the Balancing Market Exchange Member trades in the Ex-Ante Markets while a Trading Halt should have been in effect. Exchange Member trades in the Ex-Ante Markets while a Suspension of the relevant Unit from the Balancing Market is in effect. Probability Extremely Low Very Low Extremely Low

31 3 - Comments and Responses 6 sets of comments received (3 agreed, 3 had reservations) Main Themes of Comments Exchange Member responsible firstly (6) Should never occur if automated processes (2) Use of Ex-Ante Collateral (1) Use Balancing Market Collateral (1) Incentives for SEMOpx to be careful (1) SEMOpx should cover risk and imbalances (3) Not all Exchange Members as a cost recovery measure (1) SEMOpx Rules allow all avenues for recovery (1) Reporting on occurrences by SEMOpx (1) Don t include default fund concept (6) (x) Indicates number of responses that raised this point 31

32 Amendments to Proposal Addition of trading out of Invalid Contracted Quantity positions as first step Confirmation that high likelihood of recovering costs (before impacting imbalance settlement payments) Use of Clearing Member or Direct Clearing Member collateral held with ECC Removal Default Fund from mitigations? Removal of socialisation of costs with all Exchange Members 32

33 *Items in purple added, default fund and charge all Exchange Members removed based on feedback 3- Invalid Contracted Quantities Recovery of Costs 1 ECC instruct the Exchange Member to close invalid contracted quantities by countertrades or will trade in Ex-Ante Markets to close position/minimise costs ECC Clearing Conditions 2 ECC withholding payment to the Exchange Member for the value of the invalid Contracted Quantities therefore minimising the costs needing recovery ECC Clearing Conditions 3 ECC to charge the Exchange Member that caused the invalid Contracted Quantities through trading in the Ex-Ante Markets, when not authorised to do so ECC Clearing Conditions 4 ECC to recover costs from the Exchange Members Clearing Member or Direct Clearing Member Ex-Ante Market collateral (as applicable) ECC Clearing Conditions 5 ECC to inform SEMO if payments cannot be recovered in time for Balancing Market payment deadlines. SEMO to withhold any payments for the relevant Units in Imbalance Settlement to minimise the costs needing recovery TSC Mod 6 SEMO to draw down on the Balancing Market posted credited cover for the Participant of the relevant Units prior to payments out due date TSC Mod 7 Where the issue can be attributed to SEMOpx s service provider, recovery of costs through liability provisions Service Provider Agreements 33

34 4 All Avenues for Recovery of Costs Rationale for Change To ensure SEMOpx Rules allow for all available avenues to recover costs of the Invalid Contracted Quantities from the Exchange Member. SEMOpx Rules clause G means an Exchange Member is required to indemnify SEMOpx for losses and expenses arising from its breach of the Rules or the Procedures. Each of the situations that give rise to an invalid Contracted Quantity will now be a breach of the Rules. However, an additional clause in section G.3.3 so that the imbalance amount due to the invalid Contracted Quantity under the TSC is still considered a loss for SEMOpx under clause G would provide further weight to ensuring SEMOpx has available all avenues to recover costs.

35 4 All Avenues for Recover of Costs Rule Amendment G Where a breach of these SEMOpx Rules by an Exchange Member results in a Contracted Quantity submitted under paragraph F of the Trading and Settlement Code being invalid under clause G.2.10 of that Code, for the purposes of the indemnity in paragraph G.3.3.1, the relevant Reassigned Amount (within the meaning of that Code) shall continue to be regarded as a loss incurred by SEMOpx. Note: G.2.10 is to be included as part of the legal drafting for MOD_17_17 35

36 Agenda SEMOpx Implementation Update Block Orders for the Intraday Continuous Market Foreign Exchange Rate SEMOpx Statement of Charges SEMOpx Interim Consultative Forum Interim Modifications Process Market Coupling Facilitator Recovery of Costs related to Invalid Contracted Quantities Previously Raised Rule Changes x2 Liability 36

37 Previously Raised Rule Changes Ref No. 1 No Trading when not authorised under TSC 2 Trading Halt if Clearing House requests Title Description Status Additional criteria to clause C so that Exchange Member has the responsibility to not trade prior to the effective date under the TSC [adding to criteria of having responsibility to not trade when suspended or has a trading halt relevant under the TSC] Where Clearing House requests, SEMOpx can halt trading activity of an Exchange member (e.g. one or more of DAM, IDM1, IDM2, IDM3, IDC). New New 37

38 1 - No Trading when Not Authorised under TSC Text Change C An Exchange Member shall not submit Orders in respect of Units registered in respect of a Participant under the Trading and Settlement Code where: a) the Order is for a Trading Period prior to the effective date and time of the Unit before the Unit s registration under the Trading and Settlement Code takes effect; b) the Participant has been Suspended under the Trading and Settlement Code; or c) the Market Operator is prohibited from accepting notification of Contracted Quantities in respect of that Participant under paragraph G of the Trading and Settlement Code. 38

39 2 - Trading Halt if CCP request Rule Amendment C 2.4 Trading Halt C SEMOpx may declare an Exchange Member to be subject to a Trading Halt if: a) the Exchange Member breaches these SEMOpx Rules, the Procedures or the Exchange Membership Agreement and SEMOpx considers that the breach adversely affects the operation of any of the Trading Systems or another Exchange Member s ability to interface with those systems; b) SEMOpx is aware that paragraph G of the Trading and Settlement Code applies and, in accordance with that paragraph, the Market Operator is prohibited from accepting Contracted Quantities submitted by any Scheduling Agent in respect of a Participant who has a Unit or Units registered under the Trading and Settlement Code for which the Exchange Member is authorised by SEMOpx to submit Orders (with a term in italics in this paragraph having the meaning given in the Trading and Settlement Code); c) SEMOpx considers that it is necessary to do so to ensure the integrity of the Exchange in light of the SEMOpx Objective and SEMOpx Principles; or d) SEMOpx considers that the Exchange Member may have breached one or more of the conduct provisions set out in Chapter D; e) SEMOpx is are requested instructed to exclude an Exchange Member from trading by the Clearing House in accordance with the Clearing Conditions Rules. 39

40 Agenda SEMOpx Implementation Update Block Orders for the Intraday Continuous Market Foreign Exchange Rate SEMOpx Statement of Charges SEMOpx Interim Consultative Forum Interim Modifications Process Market Coupling Facilitator Recovery of Costs related to Invalid Contracted Quantities Previously Raised Rule Changes x2 Liability 40

41 I-SEM Project Contact Details Web: I-SEMproject@sem-o.com THANK YOU! 41