2 September Agency for the Cooperation of Energy Regulators Trg republike Ljubljana Slovenia. Public Consultation Paper.

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1 2 September 2014 Agency for the Cooperation of Energy Regulators Trg republike Ljubljana Slovenia Re: ICE Trade Vault Europe Limited s Response to the REMIT Transaction Reporting User Manual Public Consultation Paper Dear, ICE Trade Vault Europe Limited ( ICE Trade Vault Europe ) welcomes the opportunity to comment on the Agency for the Cooperation of Energy Regulators ( ACER or the Agency ) public consultation paper related to the Wholesale Energy Market Integrity and Transparency Regulation ( REMIT ) Transaction Reporting User Manual ( TRUM ) (the Consultation Paper ). As background, IntercontinentalExchange, Inc. ( ICE ) was established in 2000 as an over the counter ( OTC ) marketplace with the goal of providing transparency and impartiality for the previously opaque, fragmented energy market. Since that time, ICE has grown significantly through organic growth fostered by product, technology and clearing innovation, and by acquisition of futures and equities exchanges that have broadened its product offerings and risk management services. As a part of this growth, ICE created ICE Trade Vault, LLC., the first provisionally registered Swap Data Repository in the United States, as well as ICE Trade Vault Europe, a registered Trade Repository serving the credit, interest rate, equities and commodities asset classes throughout Europe. ICE would like to commend the Agency for its work on the Consultation Paper and its further refinement and enhancement of the TRUM. ACER has been very proactive in discussing with relevant parties the structure and responsibilities related to wholesale energy market reporting, including ICE Trade Vault Europe and ICE Endex. In order to provide ACER with helpful feedback on the TRUM, below please find answers to the Consultation Paper s questions. The Agency s comments and/or questions are reprinted in italics below, with ICE Trade Vault Europe s response immediately following. 1. Please provide us with your views on the scope of the objectives of this document. In particular, please provide your opinion on whether the kind of information included and the structure of the TRUM are suitable to facilitate reporting. If not, please explain which additional information the TRUM should cover and/or how it should be structured. ICE Trade Vault Europe Response: ICE Trade Vault Europe believes the current version of the TRUM is comprehensive and provides market participants with adequate details on how to report initial orders and ICE Trade Vault Europe Limited ICE Trade Vault Europe Limited VAT Registration No Milton Gate phone +44 (0) Registered in England No Chiswell Street fax +44 (0) Registered Office: Milton Gate 60 Chiswell Street London EC1Y 4SA London EC1Y 4SA online:

2 transactions. However, ICE Trade Vault Europe believes that the TRUM should also include information regarding the following: More detail related to how amendments and/or additions to the TRUM will be effected, including: o the timeframes/lead times by which changes to the TRUM must be implemented by affected market participant; and o that changes should not be affected on a retroactive basis (i.e. changes need not be applied to trades that have been previously reported.) More detail related to how lifecycle events are reported by market participants. 2. Please provide us with your general comments on the purpose and structure of the draft TRUM. In particular, please provide your opinion on whether the information the Agency intends to include in the first edition of the TRUM is sufficient for the first phase of the transaction reporting (contracts executed at organised market places). If not, please explain which additional information should be covered. ICE Trade Vault Europe Response: ICE Trade Vault Europe believes that this version of the TRUM provides sufficient information to allow for the commencement of transaction reporting for contracts executed at organised market places. However, ICE Trade Vault Europe believes that REMIT s draft Implementing Acts (the Implementing Acts ) require further refinement and clarification. In particular, ICE believes that Article 6(1) of the draft Implementing Acts does not affirmatively place the obligation to report on the organised market place as the current language allows a market participant to report through an organised market place or a trade matching or trade reporting system. The use of the word or has allowed some market participants to interpret their obligation to report via an organised market place as an option and not a requirement. ICE believes that this language should be strengthened to specifically state that a market participant is not required to report those transactions executed at organised market place because the organised market place shall report on their behalf. ICE recognises and appreciates ACER s attempt at clarifying this language in Section of the TRUM. However, ICE is cognisant that this document is not legally binding and therefore it is more appropriate for this reporting obligation to be clarified in the Implementing Acts. 3. Please provide us with your views on the Agency s proposed approach as regards the list of standard contracts. In particular, please provide your views on whether: The list of standard contract types enables reporting parties to establish whether to use Table 1 or Table 2 of the Annex I of the draft Implementing Acts when reporting information under REMIT; and The identifying reference data listed in Annex II to be collected by the Agency would be sufficient and suitable to establish the list of standard contracts. 2

3 Do you agree that the list of standard contracts in Annex II should also be considered sufficient to list the organised market places or would you prefer to have a separate list of organised market places? Please justify your views. ICE Trade Vault Europe Response: In general, ICE Trade Vault Europe believes that the list of standard contract types detailed in the TRUM enables reporting parties to establish whether to use Table 1 or Table 2 of Annex I of the draft Implementing Acts. However, ICE Trade Vault Europe seeks clarity on the below issues: Contracts reportable upon request Section details those contracts that are reportable upon request of the Agency. This section appears to follow Article 4 of the draft Implementing Acts. Neither REMIT nor the Implementing Acts include a recordkeeping requirement which requires market participants to maintain records of orders and trades in a required format. While it is assumed that market participants will maintain records of ordinarily reportable orders or trades in order to facilitate required reporting, some market participants may not keep records of orders or trades that are only reportable upon request in the same format as ordinarily reportable contracts because this is not an affirmative requirement and could be burdensome for some market participants. Therefore, a market participant may not be able to provide ACER with the data described in Annex I of the Implementing Acts for those contracts that are reportable upon request. Furthermore, if market participants are implicitly required to maintain records of the orders and trades that are reportable upon request, ICE Trade Vault Europe believes that this requirement is an imposition on market participants that is not grounded in law (e.g. REMIT or the Implementing Acts.) Therefore, ICE Trade Vault Europe seeks clarity on the format that ACER expects market counterparties to use for those contracts that are reportable upon request. Definition of standard contract Section reiterates the definition of standard contract found in the draft Implementing Acts. ICE Trade Vault Europe seeks clarity on whether shaped deals are considered standard or non standard contracts. ICE Trade Vault Europe recommends that ACER clarify in the TRUM that shaped deals are considered non standard contracts because these transaction types are overly complex and the industry will need longer lead times to develop standardized reporting for these transactions. Updates to information from organised market places Section states that [o]rganised market places shall submit updates of the [contract] information as changes occur. As stated in ICE s letter dated 25 April 2014(attached) to the European Commission with regard to the draft Implementing Acts, ICE requests clarity on the process for organised markets to update reference data information. Currently, organised market places undergo a significant amount of operational and legal work prior to listing a contract for trading because of their status as a regulated entity by one or many competent authorities, each with their own set of rules and regulations. While these organised market places understand and appreciate the need to notify ACER of new wholesale energy contracts and their underlying reference data, ICE believes that the process for the submission of updates needs to be clearly articulated in the TRUM so that organised market places are fully aware of the requirements and processes involved and these 3

4 requirements are equally applied by ACER. Furthermore, ICE recommends the use of the language as changes occur be specified. For example, ICE recommends that organised market places notify ACER within 10 business days following any changes to wholesale energy contracts or their underlying reference data. The provision of more exact language will ensure that ACER receives up to date information, while still allowing organised market places to incorporate these new requirements into their operational and legal workflows. Change in RRMs Section states that a market participant must inform ACER in their registration form of whether it chooses to report via a registered reporting mechanism ( RRM ) and the identity of the RRM must be disclosed. ICE Trade Vault Europe recommends that ACER elaborate on the obligations of market participants when they choose to change RRMs. ICE Trade Vault Europe recommends that ACER specify the process for amending their registration form to properly identify the new RRM (e.g. timeframe required for notification.) Further, ICE Trade Vault Europe recommends that ACER specify whether market participants are required to transfer previously reported trades to the new RRM. When a market participant chooses to change RRMs, ACER should require that said market participant s open transactions will need to be terminated and reopened at the new RRM to allow the new RRM the ability to correctly manage and report those transactions. Finally, ICE Trade Vault Europe prefers a separate list of organised market places as this will be easier for ACER to maintain on an ongoing basis and for market participants and RRMs to understand. 4. Please provide us with your views on the explanation of product, contract and transaction provided in this Chapter, in particular on whether the information is needed to facilitate transaction reporting. ICE Trade Vault Europe Response: ICE Trade Vault Europe appreciates the clear definitions of product, contract and transactions provided in this section of the TRUM. However, ICE Trade Vault Europe asks ACER to further clarify the definition of order report to make clear that an order is only reportable when it has been made visible to the marketplace. 5. Please provide us with your views on the field guidelines for the reporting of transactions in standard supply contracts. TRUM: ICE Trade Vault Europe Response: Below please find a field by field analysis of guidelines set forth in the Field #3: Trader ID as identified by the organised market place and/or for the market participant or counterparty the TRUM states that for bilateral contracts traded off organised market places, Trader ID should be identified as the reporting counterparty s internal ID. ICE Trade Vault Europe suggests that ACER clarify that the reporting counterparty may also identify their trader with the trader s internal name, which 4

5 is currently standard practice. In the example provided, ICE Trade Vault Europe believes that Company A should be able to identify trader Xyz Abcdef as Xyz Abcdef or with Company A s internal ID for trader Xyz Abcdef. In addition, ICE Trade Vault Europe suggests the removal of the sentence Company ID as identified by the organised market place should be reported as Comp A to prevent confusion since Company ID is not a reportable field. Field #8: Beneficiary Identification ICE Trade Vault Europe appreciates ACER s clarification on how market participants and organised market places should report field #8: Beneficiary Identification. We believe this is an improvement that will be welcomed by the industry. ICE Trade Vault Europe recommends one final clarification. Specifically, page 26 of the TRUM states, [m]ost of the reported trades will look like: A sells to B with beneficiary C. The Agency will in these cases receive two reported trades: A sells to B, B sells to C. ICE Trade Vault Europe recommends that ACER note that the above sentence is true in the case of cleared transactions. However, bilateral and uncleared transactions will look like: A sells to B with beneficiary C. In these cases, ACER will receive one reported trade: A sells to B with C identified in field #8 as Beneficiary. Field #11: Buy/Sell Indicator ICE Trade Vault Europe recommends that ACER clarify that float versus float index transactions derivatives should be reported as one transaction. Additionally, ICE Trade Vault Europe recommends that float versus float index transactions should be reported with Buyer pay index and Seller pay index fields in order to verify the buyer and seller values reported for every transaction on the same product are in sync. Field #18: Price Limit ICE Trade Vault Europe seeks clarity on the description of accepted values and examples for the price limit field. The TRUM currently provides the example 58,60. Does this mean that the price limit is 58 and/to 60, or does this mean the price limit is 58.60? Additionally, this description should state that trailing zeros should not be reported. Field #23: Energy Commodities For commodity spreads products, ICE Trade Vault Europe recommends the reporting of a buyer pay index and seller pay index within a single record to represent the transaction, rather than breaking down in to two separately reportable legs to align the reporting with the way these transactions are booked in market participants risk management systems. Field #24: Transaction Timestamp ICE Trade Vault Europe recommends using Transaction timestamp to record date and time of the transaction/order. Further, an additional field: Last Update Timestamp should be added to record the timestamp of any updates to align with common practice across other regulatory reporting regimes, including EMIR. This will also allow ACER to identify when the trade record has been updated versus an edit to the execution time field from a previously misreported value. 5

6 Field #26: Contract Trading Hours In order for RRMs to validate the contract trading hours reported on a transaction, ICE Trade Vault Europe suggests that ACER break out this field into the following fields: start date, start time, end date and end time to allow RRMs to validate each field independently as different contracts will allow for different combinations of these fields. From a data management and system efficiency perspective, it is best practice to represent data elements in unique fields versus concatenating multiple data elements. Field #27: Unique Transaction Identifier On page 38 of the TRUM, ACER states that it will provide further information on how market participants will provide the Unique Transaction Identifier ( UTI ) for bilateral trades as soon as the European Securities and Markets Authority ( ESMA ) and its registered trade repositories have agreed on a solution. To date, ESMA has not mandated a taxonomy for UTI generation, nor has it mandated which market participants shall be responsible for generating and consuming UTIs. ICE Trade Vault Europe recommends that for trades which are already reportable under an existing reporting regulation, that UTI/USI is used. For standardized contracts, the execution platform generates the UTI and for bilateral trades ACER should require the counterparties to enter into an agreement as to which UTI generation hierarchy the parties must employ in order to easily generate UTIs and subsequently transmit those UTIs to their opposing counterparties. In the bilateral reporting market today, some parties prefer to always select one counterparty to generate the UTI while others prefer to use a default seller generation model. Field #30: Organised Market Place Identification/OTC ICE Trade Vault Europe recommends that ACER require market participants to populate this field with XXXX for bilateral trades executed away from an organised market place and XOFF for listed derivatives that are traded off exchange instead of XBIL as suggested in the TRUM in order to provide uniformity with the reportable fields defined in the European Market Infrastructure Regulation ( EMIR ). Field #32: Price ICE Trade Vault Europe recommends that ACER create an additional field to report the premium for options. It is best practice to have one purpose per field and if there are multiple purposes per field, RRMs will not be able to validate the data. Therefore, ICE Trade Vault Europe recommendations the addition of a new field for Option Premium. Field #33: ICE recommends that ACER use the ISDA Commodity Reference Price Definitions for these index names as they are current industry standard convention. Please see Appendix A which provides a sample list of values for this field. Field #34: Index Value ICE Trade Vault Europe recommends revising the information provided for field #34: Index Value. When an index value is not known, the market participant should report a null value as 0 could be otherwise valid. 6

7 Field #36: Notional Amount ICE Trade Vault Europe recommends that ACER streamline the information used to calculate notional amount. Specifically, notional amount should be equal price multiplied by total notional contract quantity (field 39). This simplified approach will allow more consistent reporting by market participants. Furthermore, ICE Trade Vault Europe recommends ACER specifically clarify the notional calculation for options and for index trades. If ACER were to leave the option premium reported in the price field, then the notional amount calculation would be incorrect since the notional amount calculation would use the option strike price instead of the option premium. For index trades, where the index fixing value is known, the calculation should refer to the index value and not the price. When it is a fixed for float, and you know the index value and fixed price, these both need to be accounted for in the calculation. To avoid confusion among reporting parties, ICE Trade Vault Europe recommends ACER clarify the notional calculation value for options. Field #40: Quantity unit for field 38 and 39 Please see Appendix A to this letter which provides a list of values for this field. Field #41: Settlement method ICE Trade Vault Europe seeks clarity on how this field should be populated for swaptions as they settle into the underlying swap, which is neither a physical or cash settlement. ICE Trade Vault Europe recommends the addition of the value Contract to describe the settlement method of swaptions. Field #42: Last trading date and time In order for RRMs to validate the last trading hours reported on a transaction, ICE Trade Vault Europe suggests that ACER break out this field into the following fields: last trading date and last trading time. From a data management and system efficiency perspective, it is best practice to represent data elements in unique fields versus concatenating multiple data elements. Field #46: Option exercise date ICE Trade Vault Europe suggests that this field be replaced by Option Frequency. It can be difficult for market participants and RRMs to populate this field with multiple dates, and therefore reporting standard data values such as: monthly or daily is a more suitable and consistent approach. Field #51: Duration Because the duration of a transaction can be derived from the contract trading hours field (field 26), ICE Trade Vault Europe recommends that this field 51 be used for quantity frequency which will display if the quantity is represented in hours, days or months. Field #53: Days of the week Please see Appendix A to this letter which provides a list of values for this field. Using the provided logic for hours and days will allow ACER to more easily break out the hours traded on which days for the product in a single data value versus the much more technically complex 7

8 method of multiple values for a single field with an unknown number of submissions per transaction. Based on ICE s experience operating a global confirmation and trade repository system, the methodology provided in the TRUM is not generally supported by customers trade capture systems. o Example logic: Create a position for each day of the term according to the Days of Week for the individual hours from thru value. if M F then only days that fall on a M, T, W, Th, F if M Su then any day of the week if Sa then only Sa if Sun then only Su if Sa Sun then only Sa & Su Rules: # of hours in the position is given in the Number of Hours in the position per day row Strip whitespace Parentheses mean multiple days/hours combinations Comma means multiple rules within a day/hour combination In HoursFromThru value: Hyphen means FromThru (inclusive of last entry) In HoursFromThru value: to means FromTo (exclusive of last entry) Timezone is provided on the trade Field #54: Load Delivery Intervals Please see Appendix A to this letter which provides a list of values for this field. Please reference logic provided under: Field #53: Days of the Week. Field #60: Action type ICE Trade Vault Europe recommends the addition of another field after field 60 to include details of the action type. This field would be populated to indicate lifecycle events or other details. 6. Please provide us with your views on the examples of transaction reporting listed in Annex III of the draft TRUM. Do you consider the listed examples useful to facilitate transaction reporting? 8

9 ICE Trade Vault Europe Response: ICE Trade Vault Europe appreciates the inclusion of this Annex III in the draft TRUM. ICE Trade Vault Europe believes that the listed examples in Annex III are useful to facilitate transaction reporting. 7. In your view, are there any additional examples to be added in Annex III of the draft TRUM? Please provide a description of example(s) that in your opinion should be covered. ICE Trade Vault Europe Response: ICE Trade Vault Europe recommends the addition of the following items to Annex III of the draft TRUM: Lifecycle events examples for each possible event; o Novation o Option Exercise for a swaption o Modify Terms (full and partial) o Clearinghouse Give Up o Early Termination o Bust/Full Buy Out o Dispute and Correction of a confirmed trade Clarification on expectations around cleared trades and which lifecycle events, if any, ACER expect to be reported for cleared trades. For example, given that we understand that ACER require the matched trade to be reported, rather than the cleared trade, it would be useful for ACER to clarify that clearing, netting and compression for example do not constitute reportable lifecycle events for cleared transactions. Explanation of how market participants and RRMs can request additional examples to be added to the TRUM. 14. Do you agree that, if organised market places, trade matching or reporting systems agree to report trade data in derivatives contracts directly to the Agency they must do so in accordance with Table 1 of Annex I of the draft Implementing Acts as regards contracts referred to in Article 3(1)(a)(9) and Table 3 or 4 as regards contracts referred to in Article 3(1)(b)(3)? ICE Trade Vault Europe Response: ICE Trade Vault Europe believes that market participants, organised market places, trading matching or reporting systems (and therefore, all RRMs) should be required to report all standard contracts in accordance with Table 1 of Annex I of the draft Implementing Acts. This requirement should not include those trades that are already reportable under EMIR in the format prescribed in Table 1 of Annex I of the draft implementing acts as those contracts will be provided to ACER in their EMIR format. 9

10 15. In your view, are Tables 1, 3 and 4 of Annex I of thee draft Implementing Acts suited for the reporting of contracts referred to in Article 3(1)(a)(9) and Article 3(1)(b)(3) respectively? ICE Trade Vault Europe Response: ICE Trade Vault Europe believes that Table 1 of Annex I of the draft Implementing Acts is suitable for the reporting of standardised contracts if the changes denoted in ICE Trade Vault Europe s response to Question 5 above are implemented. In addition to the questions set following: out in the Consultation Paper, ICE Trade Vault Europe recommends the Annex IV ICE Trade Vault Europe recommends that ACER publish and distribute the XML schemas to be used for reporting as soon as possible. Market participants and RRMs need as much time as possible to understand and implement these schemas. In summary, ICE Trade Vault Europe fully supports ACER s efforts in further refining the TRUM and considering the comments set forth above. Should you have any questions about the above recommendations or questions, please feel free to contact the undersigned. Sincerely, ICE Trade Vault Europe Limited ICE Trade Vault Europe Limited CC: 10

11 Annex A NATURAL GAS NBP PLATTS ENGR NATURAL GAS NBP MONTH AHEAD UNWEIGHTED AVERAGE PRICE ARGUS NAT GAS NATURAL GAS NBP DAY AHEAD ARGUS NAT GAS NATURAL GAS NBP DAY AHEAD OFFER HEREN NATURAL GAS NBP DAY AHEAD INDEX HEREN NATURAL GAS NBP DAY AHEAD AND WEEKEND UNWEIGHTED AVERAGE PRICE HEREN NATURAL GAS NBP DAY AHEAD AND WEEKEND UNWEIGHTED AVERAGE PRICE ARGUS NAT GAS NATURAL GAS NBP MONTHLY HEREN NATURAL GAS MONTHLY IPE NATURAL GAS IPE NBP NATURAL GAS INDEX IPE NATURAL GAS GAS UK APX OCM SAP APX ENDEX NATURAL GAS DAILY IPE NATURAL GAS ZIG INDEX DOW JONES NAT GAS NATURAL GAS ZEEBRUGGE WEEKEND BASE INDEX DOW JONES NAT GAS NATURAL GAS ZEEBRUGGE MONTH AHEAD UNWEIGHTED AVERAGE PRICE HEREN NATURAL GAS ZEEBRUGGE DAY AHEAD BASE INDEX DOW JONES NAT GAS NATURAL GAS ZEEBRUGGE DAY AHEAD AND WEEKEND UNWEIGHTED AVERAGE PRICE HEREN NATURAL GAS ZEEBRUGGE DAY AHEAD AND WEEKEND UNWEIGHTED AVERAGE PRICE ARGUS NAT GAS NATURAL GAS ZEEBRUGGE HUB MONTH AHEAD UNWEIGHTED AVERAGE PRICE ARGUS NAT GAS NATURAL GAS TTF MONTH AHEAD UNWEIGHTED AVERAGE PRICE HEREN NATURAL GAS TTF MONTH AHEAD UNWEIGHTED AVERAGE PRICE ARGUS NAT GAS NATURAL GAS TTF ICE NATURAL GAS TTF DAY AHEAD ARGUS EUROPEAN NATURAL GAS NATURAL GAS TTF DAY AHEAD AND WEEKEND UNWEIGHTED AVERAGE PRICE HEREN NATURAL GAS TTF DAILY ICE NATURAL GAS ST FERGUS DAY AHEAD ARGUS EUROPEAN NATURAL GAS NATURAL GAS PEG SUD DAY AHEAD UNWEIGHTED AVERAGE PRICE HEREN NATURAL GAS PEG NORD DAY AHEAD UNWEIGHTED AVERAGE PRICE HEREN 11

12 NATURAL GAS PEG NORTH DAY AHEAD LEBA EUROPEAN GAS NATURAL GAS PEG NORD DAY AHEAD ARGUS EUROPEAN NATURAL GAS NATURAL GAS PEG NORD DAY AHEAD INDEX HEREN NATURAL GAS NCG MONTHLY AVERAGE EEX NATURAL GAS NCG MONTH AHEAD PLATTS EUROPEAN GAS DAILY NATURAL GAS NCG MONTH AHEAD UNWEIGHTED AVERAGE PRICE HEREN NATURAL GAS NCG DAY AHEAD PLATTS EUROPEAN GAS DAILY NATURAL GAS NCG DAY AHEAD LEBA EUROPEAN GAS NATURAL GAS NCG DAY AHEAD AND WEEKEND UNWEIGHTED AVERAGE PRICE HEREN NATURAL GAS NCG DAILY VALUE EEX NATURAL GAS LEBA TTF DAY AHEAD WINDOW AND WEEKEND WINDOW LEBA NATURAL GAS LEBA TTF DAY AHEAD AND WEEKEND INDEX LEBA NATURAL GAS GASPOOL MONTHLY AVERAGE EEX NATURAL GAS GASPOOL DAILY VALUE EEX NATURAL GAS ATVP DAY AHEAD INDEX HEREN NATURAL GAS AVTP DAY AHEAD INDEX HEREN NATURAL GAS GASPOOL DAY AHEAD NATURAL GAS NCG DAY AHEAD INDEX HEREN NATURAL GAS PEGS EOD POWERNEXT NATURAL GAS PSV DAY AHEAD INDEX HEREN NATURAL GAS TIGF DAY AHEAD INDEX HEREN NATURAL GAS TTF CUMULATIVE MONTH INDEX HEREN NATURAL GAS TTF DAY AHEAD INDEX HEREN ELECTRICITY SWEP DOW JONES POWER ELECTRICITY POWER NL DAY AHEAD PEAK APX ELECTRICITY POWER NL DAY AHEAD BASE APX ELECTRICITY POWER INDEX HOURLY OMEL ELECTRICITY POWER INDEX HOURLY APX ELECTRICITY HOURLY ROPEX DAY AHEAD OPCOM ELECTRICITY HOURLY ROPEX DAY AHEAD PEAK OPCOM ELECTRICITY HOURLY ROPEX DAY AHEAD OFF PEAK OPCOM ELECTRICITY HOURLY ROPEX DAY AHEAD BASE OPCOM ELECTRICITY HOURLY PHELIX EEX ELECTRICITY HOURLY BLOCK RUSH HOUR EEX 12

13 ELECTRICITY HOURLY BLOCK OFF PEAK II EEX ELECTRICITY HOURLY BLOCK OFF PEAK I EEX+ELECTRICITY HOURLY BLOCK OFF PEAK II EEX ELECTRICITY HOURLY BLOCK NIGHT EEX ELECTRICITY GERMAN POWER BASELOAD ICE ENDEX ELECTRICITY EUR ELSPOT (SYSTEM PRICE) HOURLY NORDPOOL ELECTRICITY ELSPOT (SE 4 MALMO) HOURLY NORDPOOL ELECTRICITY ELSPOT (SE 3 STOCKHOLM) HOURLY NORDPOOL ELECTRICITY ELSPOT (FI HELSINKI) HOURLY NORDPOOL ELECTRICITY ELSPOT (F1 HELSINKI) HOURLY NORDPOOL ELECTRICITY DUTCH POWER PEAKLOAD ICE ENDEX ELECTRICITY DUTCH POWER BASELOAD ICE ENDEX ELECTRICITY DAY AHEAD PUN (DAILY AVG) GME ELECTRICITY DAY AHEAD HOURLY POWERNEXT ELECTRICITY DAY AHEAD HOURLY HUNGARY HUPX ELECTRICITY DAY AHEAD PEAK EPEX ELECTRICITY DAY AHEAD GERMANY/AUSTRIA EPEX ELECTRICITY DAY AHEAD BASE EPEX ELECTRICITY DAILY PHELIX PEAK SPOT EEX ELECTRICITY DAILY PHELIX BASE SPOT EEX ELECTRICITY BELGIAN POWER BASELOAD ICE ENDEX NATURAL GAS ZEEBRUGGE DAY AHEAD AND WEEKEND UNWEIGHTED AVERAGE PRICE ARGUS NAT GAS NATURAL GAS OCM ELECTRICITY LEBA UK POWER INDEX DAY AHEAD WINDOW TELERATE ELECTRICITY LEBA UK POWER INDEX WORKING DAYS TELERATE ELECTRICITY LEBA UK POWER INDEX MONDAY FRIDAY PEAK TELERATE ELECTRICITY LEBA UK POWER INDEX ALL DAYS TELERATE ELECTRICITY NOK ELSPOT (SYSTEM PRICE) HOURLY NORDPOOL ELECTRICITY SEK ELSPOT (SYSTEM PRICE) HOURLY NORDPOOL ELECTRICITY DKK ELSPOT (SYSTEM PRICE) HOURLY NORDPOOL ELECTRICITY NOK ELSPOT SWEDEN (STO) HOURLY NORDPOOL ELECTRICITY SEK ELSPOT SWEDEN (STO) HOURLY NORDPOOL ELECTRICITY DKK ELSPOT SWEDEN (STO) HOURLY NORDPOOL ELECTRICITY EUR ELSPOT SWEDEN (STO) HOURLY NORDPOOL 13

14 ELECTRICITY NOK ELSPOT FINLAND (HEL) HOURLY NORDPOOL ELECTRICITY SEK ELSPOT FINLAND (HEL) HOURLY NORDPOOL ELECTRICITY DKK ELSPOT FINLAND (HEL) HOURLY NORDPOOL ELECTRICITY EUR ELSPOT FINLAND (HEL) HOURLY NORDPOOL ELECTRICITY NOK ELSPOT DENMARK WEST (ARH) HOURLY NORDPOOL ELECTRICITY SEK ELSPOT DENMARK WEST (ARH) HOURLY NORDPOOL ELECTRICITY DKK ELSPOT DENMARK WEST (ARH) HOURLY NORDPOOL ELECTRICITY EUR ELSPOT DENMARK WEST (ARH) HOURLY NORDPOOL ELECTRICITY NOK ELSPOT DENMARK EAST (CPH) HOURLY NORDPOOL ELECTRICITY SEK ELSPOT DENMARK EAST (CPH) HOURLY NORDPOOL ELECTRICITY DKK ELSPOT DENMARK EAST (CPH) HOURLY NORDPOOL ELECTRICITY EUR ELSPOT DENMARK EAST (CPH) HOURLY NORDPOOL ELECTRICITY NOK NORWAY (OSL) HOURLY NORDPOOL ELECTRICITY SEK NORWAY (OSL) HOURLY NORDPOOL ELECTRICITY DKK NORWAY (OSL) HOURLY NORDPOOL ELECTRICITY EUR NORWAY (OSL) HOURLY NORDPOOL ELECTRICITY NOK ELSPOT NORWAY (BER) HOURLY NORDPOOL ELECTRICITY SEK ELSPOT NORWAY (BER) HOURLY NORDPOOL ELECTRICITY DKK ELSPOT NORWAY (BER) HOURLY NORDPOOL ELECTRICITY EUR ELSPOT NORWAY (BER) HOURLY NORDPOOL ELECTRICITY NOK ELSPOT NORWAY (MOL) HOURLY NORDPOOL ELECTRICITY SEK ELSPOT NORWAY (MOL) HOURLY NORDPOOL ELECTRICITY DKK ELSPOT NORWAY (MOL) HOURLY NORDPOOL ELECTRICITY EUR ELSPOT NORWAY (MOL) HOURLY NORDPOOL ELECTRICITY NOK ELSPOT NORWAY (TRON) HOURLY NORDPOOL ELECTRICITY SEK ELSPOT NORWAY (TRON) HOURLY NORDPOOL ELECTRICITY DKK ELSPOT NORWAY (TRON) HOURLY NORDPOOL ELECTRICITY EUR ELSPOT NORWAY (TRON) HOURLY NORDPOOL ELECTRICITY NOK ELSPOT NORWAY (TROM) HOURLY NORDPOOL ELECTRICITY SEK ELSPOT NORWAY (TROM) HOURLY NORDPOOL ELECTRICITY DKK ELSPOT NORWAY (TROM) HOURLY NORDPOOL ELECTRICITY EUR ELSPOT NORWAY (TROM) HOURLY NORDPOOL ELECTRICITY NOK ELSPOT NORWAY (KRI) HOURLY NORDPOOL ELECTRICITY SEK ELSPOT NORWAY (KRI) HOURLY NORDPOOL 14

15 ELECTRICITY DKK ELSPOT NORWAY (KRI) HOURLY NORDPOOL ELECTRICITY EUR ELSPOT NORWAY (KRI) HOURLY NORDPOOL ELECTRICITY HOURLY BLOCK MORNING EEX ELECTRICITY HOURLY BLOCK HIGH NOON EEX ELECTRICITY HOURLY BLOCK AFTERNOON EEX ELECTRICITY HOURLY BLOCK EVENING EEX ELECTRICITY HOURLY BLOCK OFF PEAK I EEX ELECTRICITY HOURLY BLOCK BUSINESS EEX ELECTRICITY CONTINUOUS TRADING BASE EEX ELECTRICITY CONTINUOUS TRADING PEAK EEX ELECTRICITY CONTINUOUS TRADING WEEKEND BASE EEX ELECTRICITY MONTHLY PHELIX BASE SPOT EEX ELECTRICITY MONTHLY PHELIX PEAK SPOT EEX ELECTRICITY MONTH FUTURES BASE EEX ELECTRICITY MONTH FUTURES PEAK EEX ELECTRICITY QUARTER FUTURES BASE EEX ELECTRICITY QUARTER FUTURES PEAK EEX ELECTRICITY YEAR FUTURES BASE EEX ELECTRICITY YEAR FUTURES PEAK EEX ELECTRICITY POWER INDEX HOURLY EEX Quantity Unit MWh Quantity Unit MW Quantity Unit GJ Quantity Unit Therms Quantity Unit KW Quantity Unit MMBtu Days of the week Sun Sun Days of the week Su Days of the week Sa Su Days of the week M Su Days of the week M F Days of the week F Su Days of the week (M F) (Sa Su) Load delivery 2330 to

16 intrevals HoursFromThru 2300 to 2400 HoursFromThru 2300 to 2330 HoursFromThru 2300 to 2300 HoursFromThru 2300 to 0700, 1900 to 2300 HoursFromThru 2300 to 0700 HoursFromThru 2300 to 0300 HoursFromThru 2300 to 0100 HoursFromThru 2230 to 2300 HoursFromThru 2200 to 2300 HoursFromThru 2200 to 2230 HoursFromThru 2130 to 2200 HoursFromThru 2100 to 2300 HoursFromThru 2100 to 2200 HoursFromThru 2100 to 2130 HoursFromThru 2030 to 2100 HoursFromThru 2000 to 2400 HoursFromThru 2000 to 2100 HoursFromThru 2000 to 2030 HoursFromThru 1930 to 2000 HoursFromThru 1900 to 2400 HoursFromThru 1900 to 2300 HoursFromThru 1900 to 2100 HoursFromThru 1900 to 2000 HoursFromThru 1900 to 1930 HoursFromThru 1830 to 1900 HoursFromThru 1800 to 2400 HoursFromThru 1800 to 1900 HoursFromThru 1800 to 1830 HoursFromThru 1730 to 1800 HoursFromThru 1700 to 1900 HoursFromThru 1700 to 1800 HoursFromThru 1700 to 1730 HoursFromThru 1630 to

17 HoursFromThru 1600 to 2000 HoursFromThru 1600 to 1700 HoursFromThru 1600 to 1630 HoursFromThru 1530 to 1600 HoursFromThru 1500 to 1900 HoursFromThru 1500 to 1700 HoursFromThru 1500 to 1600 HoursFromThru 1500 to 1530 HoursFromThru 1430 to 1500 HoursFromThru 1400 to 1800 HoursFromThru 1400 to 1500 HoursFromThru 1400 to 1430 HoursFromThru 1330 to 1400 HoursFromThru 1300 to 1500 HoursFromThru 1300 to 1400 HoursFromThru 1300 to 1330 HoursFromThru 1230 to 1300 HoursFromThru 1200 to 1300 HoursFromThru 1200 to 1230 HoursFromThru 1130 to 1200 HoursFromThru 1100 to 1500 HoursFromThru 1100 to 1300 HoursFromThru 1100 to 1200 HoursFromThru 1100 to 1130 HoursFromThru 1030 to 1100 HoursFromThru 1000 to 1400 HoursFromThru 1000 to 1100 HoursFromThru 1000 to 1030 HoursFromThru 0930 to 1000 HoursFromThru 0900 to 2000 HoursFromThru 0900 to 1100 HoursFromThru 0900 to 1000 HoursFromThru 0900 to 0930 HoursFromThru 0830 to

18 HoursFromThru 0800 to 2400 HoursFromThru 0800 to 2000 HoursFromThru 0800 to 1900 HoursFromThru 0800 to 1800 HoursFromThru 0800 to 0900 HoursFromThru 0800 to 0830 HoursFromThru 0730 to 1700 HoursFromThru 0730 to 0900 HoursFromThru 0730 to 0800 HoursFromThru 0700 to 2300 HoursFromThru 0700 to 2100 HoursFromThru 0700 to 1900 HoursFromThru 0700 to 1500 HoursFromThru 0700 to 1100 HoursFromThru 0700 to 0900 HoursFromThru 0700 to 0800 HoursFromThru 0700 to 0730 HoursFromThru 0630 to 0700 HoursFromThru 0600 to 2200 HoursFromThru 0600 to 1000 HoursFromThru 0600 to 0700 HoursFromThru 0600 to 0630 HoursFromThru 0530 to 0600 HoursFromThru 0500 to 0700 HoursFromThru 0500 to 0600 HoursFromThru 0500 to 0530 HoursFromThru 0430 to 0500 HoursFromThru 0400 to 0500 HoursFromThru 0400 to 0430 HoursFromThru 0330 to 0400 HoursFromThru 0300 to 0700 HoursFromThru 0300 to 0500 HoursFromThru 0300 to 0400 HoursFromThru 0300 to

19 HoursFromThru 0230 to 0300 HoursFromThru 0200 to 0300 HoursFromThru 0130 to 0200 HoursFromThru 0100 to 2400 HoursFromThru 0100 to 0700 HoursFromThru 0100 to 0300 HoursFromThru 0100 to 0200 HoursFromThru 0100 to 0130 HoursFromThru 0030 to 0100 HoursFromThru 0000 to 2400 HoursFromThru 0000 to 0800 HoursFromThru 0000 to 0600 HoursFromThru 0000 to 0100 HoursFromThru 0000 to 0030 HoursFromThru (0000 to 0900, 2000 to 2400) (0000 to 2400) HoursFromThru (0000 to 0800, 2000 to 2400) (0000 to 2400) HoursFromThru (0000 to 0600, 2200 to 2400) (0000 to 2400) 19