Timing/ Frequency of reporting an LNG Participant Activity Report
LNG fundamental data relating to dates of unloading and reloading and volumes unloaded and reloaded per ship must be reported to the Agency by market participants ‘…no later than the working day following unloading or reloading.’ However, the final volume unloaded/reloaded may not be known until after T+1 for various reasons, e.g. the report providing final discharge/load figures may be issued late and we and/or our counterparty may disagree with the report (see practical examples below).
Example 1): Delay in receiving Inspector’s report containing load or discharge figures
Ø Vessel completes discharge 23:00 1st January.
Ø Inspector report issued 23:00 2nd January.
Ø Final figures cannot be actualised in system and reported to REMIT until a.m. 3rd January.
Ø Should an estimate be submitted within T+1? In which case, can an updated figure be submitted on T+2?
Example 2): Quantity discharged or loaded is disputed between parties and cannot be deemed as final on T+1
Ø Vessel completes discharge 09:00 1st January.
Ø Inspector report issued 19:00 1st January.
Ø Counterparties disagree with figures on morning of 2nd January. Parties agree to a retest, which requires 24 hours.
Ø Retest results made available 12:00 3rd January.
Ø Parties agree on new test results 4th January. Final Figures cannot be actualised in system and reported to REMIT until this day.
Ø Should an estimate be submitted within T+1? In which case, can an updated figure be submitted on T+3?
Answer: According to Article 9(6) of Commission Implementing Regulation (EU) No 1348/2014 the information referred to in Article 9(5)(a) of the said regulation shall be made available no later than the working day following unloading or reloading.
In the examples described above, the inspector reports issues within a t+1 day time frame. This is why the Agency would consider the unloading or reloading only completed once the issue reported by the inspector is sorted out and the t+1 day timeline only starts to run as of then. In general, such inspections and potential dispute settling between the parties on test results of cargo figures should be considered an integral part of the LNG unloading and reloading.