Intraday Implicit CrossBorder allocation on BE-NL. and borders (Interim Implicit Cross Border Intraday BE-NL. Description of the allocation mechanism

Transcription

1 Intraday Implicit CrossBorder allocation on BE-NL and borders (Interim Implicit Cross Border Intraday BE-NL Description of the allocation mechanism version 2.0) Description of the allocation mechanism Version 2.0 Date 11 July 2016

2 Contents 1 Introduction General Context and rationale of the project Description of the solution General... 6 Detailed description of the solution... 7 Intraday capacity calculation... 8 Submission of capacity values to M7/ICS General procedure Principle of netting Capacity reduction Firmness Description of M7 trading platform M7 User Interface M7 in this project Description of the different products Gate system and nominations at the TSOs Specificities on the BE-NL border Firmness of nominations Settlement Publication of transaction data Back-up arrangement Contractual architecture for the Market Participant...18 Page 2 of 18

3 1 Introduction This document outlines an improved intraday capacity allocation mechanism for the Belgian-Dutch border, i.e. an implicit allocation mechanism based on continuous trading proposed to replace the existing arrangements. This document brings together a certain number of important analytical elements and provides a detailed description of all the processes, between the transmission system operators (hereafter TSO ) ELIA and TenneT, and the power exchanges (hereafter PX ) APX, Belpex and EPEXSpot, related to the proposed new allocation mechanism. 2 General Context and rationale of the project Currently APX and Belpex operate intraday markets in respectively The Netherlands and in Belgium; EPEXSpot operates the intraday markets in France, Germany, Austria and Switzerland. The APX Power NL Intraday Market was established in 2006, the Belpex Continuous Intraday Market (CIM) in Both allow trading in standardized products (hourly and multi-hourly instruments) to sell and purchase electricity on a continuous basis, and this up to 5 minutes before delivery. EPEXSpot operates a continuous Intraday Market since its creation in 2008 which also provides standardized products (hourly and multi-hourly instruments) to sell and purchase electricity on a continuous basis, and this up to 30 minutes before delivery depending on the delivery area, in France, Germany, Austria and Switzerland. The intraday capacity on the interconnector between Belgium and France is currently allocated to the market participants by means of an explicit allocation method. Since May 2007 this has been done by means of an improved pro rata mechanism with 12 gates. This mechanism might temporarily be replaced by a First-Come-First-Served explicit allocation (with 24 gates) from beginning of 2016, after formal guidance by the regulators. On the contrary, the intraday capacity on the interconnector between Belgium and The Netherlands has already been allocated to the market participants by means of an implicit allocation method since beginning of The Eurolight platform is used to trade capacity and energy simultaneously in an implicit way on this border, through 12 gates. EPEXSpot has been using the M7 (ex- ComXerv ) trading platform, connected to the Intraday capacity service (ICS) platform from Deutsche Börse AG (DBAG) used by TSOs for the intraday capacity allocation, for the same purpose on the German-French border for several years. The explicit First-Come-First-Served allocation is also in place in parallel with the implicit allocation. Both methods are also used on German-Swiss and France-Swiss borders. Within the framework of the North West Europe (NWE) region (also including Austria and Switzerland), a project was launched to design, implement and operate an enduring intraday allocation mechanism: the XBID Market Project. The aim of the NWE+ project is to build out and implement within this region the target intraday allocation mechanism. Page 3 of 18

4 The agreed high level principles are: implicit continuous capacity allocation; centralization of liquidity by means of a shared order book function; if requested by the regulators, explicit allocation to allow OTC trading to be replaced in the future by non-standardised products. It is currently foreseen that this enduring solution could be implemented in the end of The TSOs, TenneT and Elia, together with the PXs, APX, Belpex and EPEXSpot have identified the opportunity to improve the capacity allocation mechanisms for the Belgium-The Netherlands border by replacing the existing allocation mechanism by an implicit allocation mechanism, in line with the enduring requirements. It was decided by the project parties to migrate the Eurolight platform on the Belgian and Dutch hubs to the M7 trading platform from DBAG. If the M7 trading platform is connected with the ICS platform the capacity on both Belgian borders will be allocated implicitly. This will be done through 24 gates and 1 hour neutralization time. This means that the same trading platform is used in Belgian and The Netherlands as the one used in France, Germany, Austria and Switzerland; and that capacity will be allocated through the same capacity management module. This is shown graphically in figure 2. Figure 1: intraday allocation mechanisms on internal CWE borders (* FCFS 24 was implemented in March 2016 and FCFS 24 will be kept in operation as fallback after implementation of the second step) The proposed solution offers substantial advantages compared to the actual allocation mechanism, without negative interference to the XBID Market Project. The cross-border shipping will be organized by the PXs and their CCPs like in the dayahead market coupling. Clearing and settlement are organized through existing PX/CCP arrangements, contracts and market rules. The proposed allocation mechanism have been presented and discussed with the market parties that have been requesting the implementation of quick wins for quite some time. Page 4 of 18

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6 3 Description of the solution 3.1. General The platform that was chosen for intraday implicit allocation consists of two modules: the trading platform "M7" (ex ComXerv ), already used by EpexSpot, and the capacity allocation platform "ICS" at which "M7" will be connected. The external service provider that has been chosen to develop the "Capacity Management Module" (CMM) in ICS platform and the "Shared Order Book" (SOB) in M7 trading solution, is DBAG. M7 the trading system used by EPEXSpot connected to the ICS platform is able to handle cross-border trading via an implicit capacity allocation mechanism. The cross-border coordination mechanism implemented is based on separate market areas which may be connected to each other subject to capacities being available. The possible amount of transactions concluded between these areas is constrained by the capacity limits on the interconnector. Concluded cross-border transactions decrease the available capacity in one direction and increase the available capacity in the opposite direction since the principle of netting is implemented. Figure 2 : Belgian borders Intraday implicit allocation with M7/ICS platforms In the M7 trading system, the Belgian and Dutch markets will be added as separate market areas to the already existing areas of France, Germany, Austria and Switzerland in a similar setup. The trading system shall allow for the data regarding the Belgian and Dutch market areas to be interconnected and to take into account the intraday capacity values for the Dutch-Belgian and French-Belgian borders as calculated by the TSOs. Main features of the solution include: - No interference with other interim solutions; Continuous trading with implicit allocation of available capacity, coupling of existing ID markets; Page 6 of 18

7 Cross-border shipping will be organized by the clearing house appointed by the PX, TSOs will perform the cross-border nominations on behalf of the shipping agent Clearing and settlement of transactions is organized via existing PX/CCP arrangements, so there are no new membership agreements required; and Fully transparent process including daily trade reporting to the regulators where applicable. Detailed description of the solution The solution can schematically be represented as in Figure 4 here below. Please note that the below scheme has still to be formally agreed by all project parties, and thus is subject to minor adjustments /clarifications : Figure 3 : High Level Architecture Intraday trading on M7 will start on the basis of the confirmed intraday capacities calculated by the TSOs according to the current processes with their current systems and security of supply principles in place. Capacities are sent by one TSO (on behalf of both TSOs) to the ICS platform for the BENL border, following which the TSOs will have a real time view on the intraday capacity values for the remaining hours of the day via read-only access to ICS. Additionally, the TSOs will have full control over the intraday capacities, as a specific TSO-interface offered by ICS allows TSOs to modify (remainder) intraday capacities throughout the day in real-time. Cross-border trading will continuously be possible on M7. ICS will reduce/net the intraday capacities with the transactions that have been concluded, and M7 will only show the orders that can be executed within the remaining capacities at any given point in time. The applications of ECC (clearing house of PXs) will keep data on all transactions until the gate closure time for cross-border trades, one hour before delivery. Page 7 of 18

8 The concluded transactions by the market participants will be sent from M7 to the TSOs via ECC systems while ICS will sent allocation results directly to the TSOs for physical fulfilment of cross-border flows. The TSOs will receive the results from ICS and will create the cross-border nominations on behalf of the shipping agent. However in The Netherlands, the shipping agent still needs to submit temporarily the cross-border nominations to Tennet. Matching of the cross-border nominations will be executed by the TSOs. Settlement processes include local hub nominations and daily cash settlement Intraday capacity calculation The current intraday capacity calculation process will be used and is not affected by this implementation project which only aims at improving the capacity allocation process Submission of capacity values to M7/ICS General procedure In order to enhance the competition between the different orders of the hubs, the intraday capacities must be made available for cross-border trading. It has been agreed upon that Elia will provide the available capacities for the Dutch-Belgian border to the ICS platform. This paragraph describes the reception, the integration and the activation of the intraday capacity values into the database of ICS. The reception, acknowledgement, upload and activation of the intraday capacity values file in the ICS database, allows M7 to match the buy and sell orders under the constraints of the network model. Once the intraday capacity values have been agreed upon by the TSOs, the process for submitting the values to the ICS platform can start. As soon as possible, the TSO s system sends the intraday capacity values via internet mail to the ICS platform to a specific address. It is the goal to have uploaded and published the intraday capacity values to the platform by 21h00 for the NL-BE border. The file contains the intraday capacity values for a border in both directions. All intraday capacity values for each border in both directions are automatically stored in the database of ICS and values can be viewed in the TSO GUI. When these checks are successful, ICS sends a positive acknowledgement to the TSO s system. After the successful upload of the capacity values, the TSO operator will have to confirm and activate the intraday capacities for cross-border trading by opening the TSO GUI on ICS. The confirmation is done by comparing the values on screen with the values sent. Once the intraday capacities are confirmed by the TSOs in the ICS platform, M7 receives the intraday capacity values. If the normal procedure fails for transferring and confirming capacity values, there are back-up procedures. These include alternative ways of data transfer or confirmation/activation of intraday capacity values from the TSO s system to ICS. Page 8 of 18

9 Principle of netting All cross-border trades done on M7 are implicitly utilizing cross-border capacity. Available cross-border capacity for intraday trading is automatically updated in M7/ICS after each executed trade. Every time a trade is made, the transmission capacity decreases in the direction of the trade and increases in the opposite direction. Example: Initially there is 100 MW of available transmission capacity for both BE NL and NL BE. A participant in The Netherlands buys 20 MW from a Belgian participant. This will result in an export of 20 MW from Belgium to The Netherlands, which causes the capacity from BE NL to decrease to 80 MW. However, at the same time the capacity from NL BE increases to 120 MW Capacity reduction The TSOs may at any point in time change capacities input to the platform, if so required due to grid circumstances. TSOs have direct access to the platform for this purpose in real time. The capacity can be reduced, or if required put to zero, for security reasons. If no problems are encountered on the grid, all market participants view all orders of the different hubs (depending on the available capacity) and there is one market. If congestions occur and the capacity is reduced, the number of orders visible to the market participants will be decreased and if this capacity is zero, only national/local orders will be visible to the market participants and the market is split. If the capacity has been reduced by the TSOs the ICS screen will be automatically updated Firmness The intraday capacities provided by the TSOs to the PX for the sake of implicit allocation is firm except: a. in the situation described in 3.4.3, i.e. the TSOs may at any point in time reduce the non-used (remaining) intraday capacities values as show on M7/ICS b. in cases of force majeure as explained in more detail in Notwithstanding the situation as referred to under b) above, this implies that all crossborder trades are firm with respect to the cross-border capacity (it being understood of course that the net sum of cross-border trades may never exceed the intraday capacity values; this is being dealt with/safeguarded by M7/ICS algorithm). Once a trade between two market participants has been concluded on the platform, the trade is firm. The change of capacity does not affect the cross-border transactions that have already been concluded Description of M7 trading platform The M7 trading system is the core of this solution connected to the ICS platform. It will enable the actual cross-border intraday trading, netting of capacity and generation of concluded trades and net positions for further processing. M7 is the trading platform which is used by EPEXSpot for its intraday markets in France, Germany, Austria and Switzerland and has proven to be robust and flexible. Page 9 of 18

10 M7 User Interface The main window of the system is shown in Figure 5 below. All functionalities in the trading system can be accessed from the menu at the left hand side of this window. In the Market View screen, price information is shown about the best Bid and Ask Orders available in the market at that moment in time, inclusive bids and offers from other markets up to the intraday capacity. However, the origin of a bid or offer is not shown, i.e. next to the fact that a market participant does not know who is behind a bid or offer (anonymity) he does also not know whether an offer is local or not. If several orders have the same price, the sum volume is seen in the Bid Quantity (BQty) Vol or Ask Quantity (AQty) columns. The orders shown in the Market View are always the best orders on both Bid and Ask sides. Orders are prioritized in the following order: Price and time, i.e. when the order was entered into the Order Book. Figure 5: Main window in M M7 in this project In the M7 trading system, the Belgian and Dutch markets will be added as separate market areas. The trading system shall allow for the data regarding the Belgian and Dutch market areas to be interconnected with the French, German, Swiss and Austrian markets and to take into account the intraday capacity values on the interconnector on the Dutch-Belgian border calculated by the TSOs. M7 and ICS should provide the following means for monitoring and steering the trading process: Market surveillance to be performed by the PX Market Operators in M7; Automated capacity maintenance monitoring facilities for the PX Market Operators in ICS. Page 10 of 18

11 Within the context of this solution M7 will be used to provide the following information: Local and cross-border trade information. Allocation results will also be available for the TSOs via the ICS s systems for further processing; Order details report(s). The CREG requires such report to be made available by Belpex on a daily basis. Additionally similar information might be required by APX and/or Belpex for (internal) reporting Description of the different products M7 allows market participants to submit hourly orders and block orders for off-taking or delivering power (bids or offers respectively). According to the Belpex Market Rules hourly orders and block orders have minimum tick size of possibly 1 or 2 decimals for bid price and 1 decimal bid volume. Hourly orders are always concerning one single hour. The orders are matched based on following prioritization criteria: 1.Price of the order 2.Time when the order was left on the market M7 allows for matching of orders with countering order(s), provided that limit price conditions are fulfilled, in accordance with the following high level specifications: - In case there are two orders with identical prices, the order that was submitted first on the trading platform, will be prioritized. The volumes of the orders have no impact on the prioritization. In case the limit prices are overlapping each other, the matching price will be the limit price of the offer, which was left on the market first; - Considering a situation where e.g. a seller has left an order on the market with a lower asking price than that of the best purchase order, the price is settled according to the order, which was left first on the market. An example would be: Buyer offers 50 for a purchase of 1 MWh. A seller submits its offer after the purchase order was already submitted on the trading platform with an asking price of 30 /MWh. The matching price of the contract will be 50 since the purchase order was submitted on the trading platform first. Same logic applies also vice versa, if a seller has submitted an order with a 30 limit price on the trading platform and a buyer enters a purchase offer with 50 /MWh limit price, the contract will be matched with the 30 limit price since the offer was submitted on the trading platform first; - In case extra capacity is given to the market (by the TSOs, or if a block order matches), M7 will identify all possible matching orders. These orders will all be matched at the same contract price (and not at the initiator price for each transaction), which will be a price between the limit prices of the orders with the lowest spread that were included in this matching. This creates more stable/logical contract prices. - The hourly offers may be matched partially and for example, one sales offer can have several countering purchase offers; - The capacity management module of ICS offers the available transmission capacity to M7 which constraints the executable cross-border trades. If there Page 11 of 18

12 exists any route via available interconnections from any market area to another, cross-border trades may happen. A block bid is an aggregated bid for several consecutive hours with a fixed bidding price and volume. A block bid must be accepted in its entirety; if accepted the contract covers all hours and the volume specified in the bid. A block bid can consist of all hours of a day that are open for trading. The minimum length of a block bid is one hour. A block bid made for one hour differs from the ordinary hourly bid in the sense that the block is all or none, whereas ordinary hourly bids also can be accepted partly. Block orders can only have one countering block order in the matching process and the fill or kill requirement means that each of the following criteria must be fulfilled before a trade can happen: o o o The prices of the two block offers must match with each other; The quantities of the two block offers must be exactly equal; and The hours within the two block offers must be exactly the same Gate system and nominations at the TSOs Specificities on the BE-NL border General The current implicit mechanism on the Belgian-Dutch border through the Eurolight platform has only 12 nomination gates in operation. The number of gates for the implicit intraday allocation via M7/ICS will be changed to 24 gates. This means a gate every hour. The aim of this section is to provide a detailed description of all the processes between ELIA and Tennet and to describe the gate system in place at the TSOs. Each gate contains different phases and deals with all the remaining hours of the day (i.e. the delivery period). The different phases are: 1. (Cross-border) trading The implicit intraday trading system allows cross-border and local trading. The point in time the trading ends depends on the kind of energy trade (local or cross-border trade) and the local hub. Trading on M7 will start on the day before delivery after closure of the day-ahead market. Cross-border trading on M7 by the market participants will start based on the confirmed intraday capacities in ICS (at 21h00 on BE-NL border) and will be continuously possible. M7/ICS reduces/nets the intraday capacities with the volumes traded and will only show on the platform deals remaining within the available capacities. After the cross-border trading is ended, only local orders are visible for the market participants until local trading ends. Trading and cross-border trading end as described hereunder: a. Cross-border trading is possible until 1h before the beginning of the delivery period; b. Trading on the Belgian hub is possible until 5 minutes before the beginning of the delivery period or otherwise as specified by Belpex; c. Trading on the Dutch hub is possible until 5 minutes before the beginning of the delivery period or otherwise as specified by APX; Page 12 of 18

13 d. 2. Trading on the French hub is possible until 30 minutes before the beginning of the delivery period or otherwise as specified by EPEXSpot. Nominations to the TSOs. After the (cross-border) trading on M7/ICS, the nominations need to be submitted to the TSOs.. a. Cross-border nominations must be received before the delivery (exante). The process will be performed by the TSOs on behalf of the shipping agent; b. Hub nominations in Belgium by Belgian market participants: ELIA must receive nominations before 14h00 D+1 (ex-post); c. Hub nominations in The Netherlands by Dutch market participants: Tennet must receive nominations before 10h00 D+1 (ex-post); The period after the nomination deadline and the start of the delivery is defined as the neutralization time, which is a kind of waiting time The gates on the Belgian - Dutch border The implicit allocation of intraday cross-border capacity on the Belgian - Dutch border has a 24-gate scheme. The different gates are shown in Table 1 below. The end of the cross border trading is one hour before the start of the delivery period. Each gate deals with all the remaining hours of the day (i.e. the delivery period). This means that cross-border trades for the delivery period from 23h00 till 24h00, may be concluded during the whole day, but at the latest before 22h00. However crossborder trades for the delivery period 00h00-01h00 must be concluded at the latest before 23h00 on D-1. XB trading is closed in M7 Scope of the gate (delivery period) 23h00 next day (00h -> 24h) 00h00 next day (01h -> 24h) 01h00 current day (02h -> 24h) 02h00 current day (03h -> 24h) 03h00 current day (04h -> 24h) 04h00 current day (05h -> 24h) 18h00 current day (19h -> 24h) 19h00 current day (20h -> 24h) 20h00 current day (21h -> 24h) 21h00 current day (22h -> 24h) 22h00 current day (23h -> 24h) Table 1 : Gate system at TSOs for the Belgian - Dutch border Page 13 of 18

14 Nominations to the TSOs As cross-border trades done on M7 are implicitly utilizing cross-border capacity, it has been decided that, as for the day ahead market coupling, the cross-border shipping will be organized by the clearing house of the power exchanges (hereafter XBshipper). The market participants are only obligated to report the trades done on M7 to their local Transmission System Operator as an internal hub nomination against its local power exchange (or CCP). Following example shows the hub and cross-border nominations to be performed in case of an export from The Netherlands to France: Figure 5 : Scenario where there is a flow from NL to FR. The situation for figure 8 is described below. In France and in The Netherlands, market participants buy and sell energy from and to respectively EPEXSpot and APX. The XBshipper will receive 25 MW from (the clearing house of) APX by means of an internal HUB nomination in The Netherlands and transfers it over the border from The Netherlands to Belgium, and then from Belgium to France. In France, the XB-shipper transfers 25 MW to (the clearing house appointed by) EPEXSpot, who will transfer it to the market participant. Hub nominations The market participants nominate hub nominations against their local power exchange (or CCP) on the Belgian and Dutch hubs at 14h00 D+1 and 10h00 D+1 respectively (ex-post). On the French hub, ECC sends nominations on behalf of market participants at 8h in D+1. Market participants can choose to wait until the delivery day has finished, for sending in the final values to the TSOs as nominations ex-post are allowed at Elia and Tennet. This is not the case on RTE side. These Hub nominations of the market participants should be balanced with the Hub nomination of the PX or the clearing house appointed by the PX. Page 14 of 18

15 Cross-border nominations : Nomination on behalf principle The ICS platform will keep data on all transactions until one hour before delivery, at which point the cross-border information will be sent to the TSOs, who will integrate the data in their nominations systems. The TSOs will create a cross-border nomination on behalf on the shipping agent. Matching of the netted nominations will be executed by the TSOs. The confirmation for the cross-border nomination will only be received after the nomination matching between the TSOs according their internal procedures in this respect. Summary of a gate on the Belgian - Dutch border The schema below visualises graphically how a gate on the Belgian - Dutch border will look like. Cross-border trading is possible until one hour before delivery. Just after the gate closure time, the TSOs will receive the allocation results from the ICS platform. Based upon these allocation results the TSOs will create the cross-border nominations on behalf of the shipping agent. Afterwards the TSOs will perform their matching. Figure 6 : graphical representation of a gate on the Belgian - Dutch border Firmness of nominations As briefly explained in 3.4.4, Elia and TenneT will accept cross-border nominations as a result of cross-border trades from the XB shipper, provided that the value of these does not exceed the value of the intraday capacities put at the disposal of the PXs for the sake of implicit continuous allocation. As for nominations in respect to long term of day-ahead capacities, nominations are firm, except in case of Force Majeure. In accordance with Art. 16 (2) of Regulation (EC) N 714/2009 the TSOs will deploy, within the requirements/imperatives of grid operational security, operational measures such as countertrading and/or redispatch measures to assure the firmness of nominations. The TSOs herewith assume that the costs which may arise to assure the firmness of these nominations (i.e. to guarantee the actual availability of the allocated capacity) can be recovered by the congestion revenue following section (6a) of the same Art. 16 of Regulation (EC) N 714/2009. Page 15 of 18

16 In situations of Force Majeure and emergency situations where the firmness of nominations is affected, the TSOs will: 1 o Either curtail intraday, day ahead, and long term capacity pro rata o And/or curtail injections and/or loads in the respective control areas, as needed in the framework of emergency or defense plan measures and in accordance with the contracts governing the relations between balancing parties and TSOs. The XB-shipper will buy/sell energy across the border, and will perform the crossborder nominations (or TSOs will create cross-border nominations on its behalf). In this respect the clearing house performs a task in the general interest of implicit capacity allocation and hence may not be financially impacted as a consequence of curtailment of nominations. In case the balance perimeter of the XB-shipper is affected as a consequence of curtailment of nominations, TSOs will not send an imbalance invoice/credit note, hence assuring financial firmness Settlement Settlement of transactions concluded in the Dutch and Belgian market areas within M7, will be settled by the clearing house appointed by the PX under existing clearing and settlement arrangements. Upon conclusion of transactions by market participants, the clearing house appointed by the PX becomes the central counterparty. As transactions give rise to almost instant delivery obligations, transactions are fully collateralized, where all Members are required to deposit collateral in the form of Cash or Bank Guarantee, in excess of outstanding exposures at all times. Transaction will be financially settled daily, as part of the standard payment processes in place between the clearing house appointed by the PX and its clearing members. Transactions giving rise to delivery or off-take in The Netherlands are notified to TenneT by the clearing house appointed by APX (and market participants). Transactions giving rise to delivery or off-take in Belgium are notified to Elia by Belpex (and market participants) Publication of transaction data M7 provides market participants with real-time information regarding amongst others transacted prices and volumes, market depth (non-executed bids and offers) and available cross-border capacities. All this data are anonymous, except where e.g. transaction data concerns a market participant s own transactions. The data disseminated by M7 is as well available by means of a number of customer reports that can be exported in support of a market participant s internal processing of transactions. General trading statistics are furthermore published on the websites of the different PXs. Furthermore, the M7 system operated by the PX stores all transaction data, where it will be accessible to clearing participants via existing facilities and protocols. 1 In line with chapter 9 of the EU HAR Page 16 of 18

17 The TSOs publish the intraday capacities values for the first gate on their websites. After the delivery day the total volumes per hour of the cross-border nominations on intraday capacity are published Back-up arrangement The project partners have put in place several back up procedures covering the different stages/processes of the allocation process as described in this note to swiftly deal with technical issues. Page 17 of 18

18 4 Contractual architecture for the Market Participant To be able to participate to this intraday allocation mechanism on the M7 platform and to be able to nominate the transactions to the TSOs, a market participant needs - - on the Belgian hub: o to have an ARP-contract concluded with Elia o to be a Participant at Belpex on the Dutch hub: o to have an PV-contract concluded with TenneT o to be a Participant at APX Page 18 of 18