UNC Modification Reference Number 0221 Entry Capacity and the Appropriate Allocation of Financial Risk Strawman Modification Proposal

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UNC Modification Reference Number 0221 Entry Capacity and the Appropriate Allocation of Financial Risk Strawman Modification Proposal Process Flow diagram 1. Security Provided pre auction (above min level) to enable participation in auction 2. Entry Capacity Auction Bid Value Calculated 3. Security Requirement calculated using Entry Capacity Credit Assessment Process 5. Security not put in place or Shipper termination - Entry Capacity Default rules apply QSEC Auction held Allocation process starts - after last bid window Allocation process finalised 4. Security level updated to reflect revised / overall position Min 30 days Max 18 days Max 60 days Max 30 days Aug Sept Oct v Dec Jan

1. Security Provided pre-auction (above min level) to enable participation in auction All Users must ensure that they have sufficinet security in place prior to the next auction (QSEC and AMSEC). The level of security required pre-auction must be equivelant to at least 80% (TBC) of the level of security required after the auction This estimate should be based on the Auction Bid Value calculation process (2) and the Entry Capcity credit asssement process (3) Security needs to be provided within 30 days of the QSEC auction taking place Security tools allowed are either a LOC or a Deposit Deed/ Deposit Bank Account (as specified in section 4) On reciept of security all relevant systems will be updated to allow the User to particpate in the Auction

2. Entry Capacity Auction Bid Value Calculated Following the auction allocation window closing, each Users Auction Bid Value will be calclulated For each ASEP the Auction Bid Value for the next full Gas Year + the peak year in the 8 year NPV test period (year 4 to year 11 - inclusive) will be captured [To be agreed] A Users Auction Bid Value will be the aggregated amount of all ASEPs

3. Security Requirement calculated using Entry Capacity Risk Assessment Process Once an auction bid value has been derived the following process needs to be used to determine the exact amount to be secured for each specific User A scaling factor will allow the Auction Bid Value to be reduced to an appropriate level (percentage of overall auction bid value) The scaling factor will comprise of 3 risk elements: Users credit rating risk Project risk Community impact risk (see below for details) 3a 3b 3c The amount of secuity required equals the Auction Bid Value * (Users credit rating risk + Project risk + Community impact risk)

3a. Security Requirement calculated using Entry Capacity Risk Assessment Process The first stage of the Entry Capacity Credit assessment process is to derive the Users Credit Rating Risk The Users credit rating, (highest (?) of either Standard and Poor's or Moody's Inverstors Service) shall be obtained from X. If the User does not have an Approved Credit Rating, or a Users Approved Credit rating is less than Ba3 then a User may obtain an Independednt Assessment score (in accordance with section V3.1.7) Table 1 will be used to derive the User's credit Rating Risk [new table based on principles within section V] Users credit rating risk = ( (X) + (Y) * Users Credit rating Score) [The above percentages need to be agreed. Element X sets the minimum percentage of the Auction Bid Value to be captured and a further percentage is added to this (Y - 25% max), which takes into account the Users score] Table 1 Stan dard and Poor s M oody s Investors Service Indep endent A ssessm ent Score AA A /AA Aaa/Aa 0 A A 60 BB B + Baa1 10 80 BB B Baa2 9 81 BB B - Baa3 8 82 BB + Ba1 7 83 BB Ba2 6 84 BB- Ba3 5 85 4 86.5 3 90 2 93.33 1 96.5 N o credit rating N o credit rating 0 100 U sers C red it R ating Sco re (% )

3b. Security Requirement calculated using Entry Capacity Risk Assessment Process If the utilisation of the Users entry capacity is dependent on significant investment to develop an import or storage facility, then a project risk assessment will be undertaken The user must provide the required evidence to support the position of thier project 25% Feasibility study and land in place? 20% Is planning permission (onshore and offshore (if applicable) in place? 15% Has construction started or are related contracts in place? 10% Has construction been completed? 0%

3c. Security Requirement calculated using Entry Capacity Risk Assessment Process The risk to the community can be measured by the proportion of the revised auction bid value (after the auction) against the User holding prior to the auction The Community Impact risk is calculated by the following formula: Community Impact risk = (Z) * (1- revised auction bid value / existing User holding) Element Z sets the maximum percentage of the Auction Bid Value to be captured by the Community Impact risk. [The above percentage needs to be agreed].

4. Security level updated to reflect revised /overall position Once the revised level of secuity is calculated the User will be informed Security needs to be provided within 20 days of the notification For the purposes of long term Entry Capacity, only the following types of security shall apply: a LOC or a Deposit Deed/Deposit Bank Account. [Section V3.4.5 defines the types of security applicable under the Code. te that only the above tools are allowed] Default rules activated (see section 5) Security Provided? End

5. Entry Capacity Default Rules Long Term - new proposal Short Term - Existing Arrangements If an "Event of Default" occurs, National Grid will conduct the following process. (1) Event of Default: - User has insufficient security in place? End On the first business day of each month for each User carry out a financial assessment Users current Code indebtedness & future 12 months capacity charges for QSEC should not exceed 85% of Code Credit Limit In the event of a default National Grid will re-call the users capacity at all entry points National Grid will call on the security provided by the User The user will lose the right to participate in long term auctions (AMSEC or QSEC) until security is provided Where capacity has been Transferred to another User, National Grid will offer the Capacity to them within 5 Business Days, at original price paid by first User (in accordance with section B5.4) Does the User pass the financial assessment? Within 5 business days after the first business day inform User that more surety/ security is required End Where the other User does not take up the capacity or spare capacity remains, National Grid will consider whether to run an adhoc QSEC or AMSEC auction (at that ASEP/s affected) Has the User provided sufficient security within 10 Business days following notification? End The remaining capacity will be offered for sale at the subsequent Annual QSEC or AMSEC auction, including substitution The level of any new Auction Bid Values purchased will be compared to the original value of the recalled capacity. If there is a short fall in expected revenue then the security provided by the Defaulting User will be used to offset it. Any excess from the above assessment will be returned to the affected User Users Registered Quarterly Firm NTS Entry Capacity for the relevant calendar quarters lapse Quarterly Firm NTS Entry Capacity may be reauctioned in the daily auction at NG discretion (B2.4.13) A lapsed capacity means that a User will no longer hold the capacity therefore this is not invoiced.