Question 2.1.45 Data Fields (49) and (50)
Could the Agency clarify further “contract start date and delivery start date may be different: e.g. the contract starts on 1 January 2017, but for peak contracts the delivery starts on Monday morning, which is 2 January 2017.“ statement available on its Open letter on REMIT transaction reporting data quality?
As indicated in the letter, market participants should refer to the Agency’s guidance on transaction reporting, namely the TRUM, Annex II to the TRUM and the FAQs on transaction reporting and they should also liaise with the RRMs reporting on their behalf as they may provide with additional instructions.
Based on the Agency’s schemas, and the ISO 8601 standard which says “Midnight is a special case and may be referred to as either "00:00" or "24:00", our understanding is that midnight may be represented as either 00:00:00, 24:00:00 or 23:59:59.
For example, 2016-08-01 00:00:00 represents the same date and time of 2016-07-31 23:59:59 or 2016-07-31 24:00:00.
However, according to the guidance, 23:59:59 and 24:00:00 should not be reported for delivery start time. Time 23:59:59 or 24:00:00 on Day X should be reported as 00:00:00 in day X+1. The same applies to 06:00:00 and 05:59:59 to represent the end of a gas day.
Delivery Start Time for gas day should be reported as 06:00:00 or 05:59:59 on Day X and Delivery End Date should be reported as 06:00:00 or 05:59:59 on Day X+1.
When trading electricity, delivery start time should be reported as 00:00:00 on Day X if the delivery starts at the beginning of Day X. For delivery end time for an electricity contract, if the delivery ends at midnight of Day X or any other day, the preferable option to report is 23:59:59 (otherwise 24:00:00) on Day X or any other day.
Example: if the delivery starts on 2017.01.01 at the start of that day (Day X), a typical yearly electricity baseload contract is wrongly reported if the delivery start date and time is 2016-12-31 00:00, 2016-12-31 23:59:59 or 24:00:00. The delivery start date and time should be reported as 2017-01-01 00:00:00.
With regard to “contract start date and delivery start date may be different: e.g. the contract starts on 1 January 2017, but for peak contracts the delivery starts on Monday morning, which is 2 January 2017” reporting parties should pay attention to the guidance.
REMIT transaction reporting fields include Field N. (53) “Days of the week" which plays a pivotal role in the simplification of the reporting of delivery profiles. Please see also FAQs on transaction reporting – Question II.2.1.40.
When “Days of the week” is reported correctly, the reported delivery profile will always be the same of the “actual delivery profile” of the contract.
Case 1 – delivery period falls within the calendar period
For electricity contracts, e.g. see example 2.11 in Annex II to the TRUM, a report for the monthly electricity peak load delivery for August 2014. The hourly delivery profile is defined by the fields:
Field N. (49) “Delivery Start Date”: 01/08/2014 identifies the date at which the delivery of the commodity starts as specified in the contract.
Field N. (50) “Delivery End Date”: 31/08/2014 identifies the date at which the delivery of the commodity ends as specified in the contract.
Field N. (53) “Days of the week”: WD identifies on which days of the week the delivery takes place, i.e. week days, as specified in the contract.
Field N. (54) “Load Delivery Intervals”: 08:00/20:00, as specified in the contract
In this specific case 1 August 2014 is Friday, therefore the physical delivery starts on that date. 31 August 2014 is Sunday, thus the physical delivery ends on Friday 29 August.
Case 2 – delivery period falls outside the calendar period
Furthermore, reporting parties should also pay attention to some special circumstances.
For gas contracts, e.g. see example 2.8 in Annex II to the TRUM, given a gas day 06:00 on day D to 06:00 to D+1 may affect the reporting of their monthly contracts. A monthly gas delivery for August 2014, with physical delivery starting on 1 August 2014 delivers gas from 06:00 to 06:00 and the actual physical delivery ends on 1 September 2014 at 06:00. Therefore, the correct way of reporting this contract is:
Field N. (49) “Delivery Start Date”: 01/08/2014
Field N. (50) “Delivery End Date”: 01/09/2014
Field N. (53) “Days of the week”: empty to indicate every day
Field N. (54) “Load delivery intervals”: 06:00/06:00 Another special circumstance is when a monthly electricity off-peak load delivery for August 2014 start at 19:00:00 on 31/07/2014. These are typical monthly contracts but the delivery period falls outside the calendar days, rather than within them.
We are aware that these are industry standards and are used by Organised Market Places (OMPs) and the Agency would expect the reporting of delivery Start and End Date as shown above and in Annex II to the TRUM. The Agency is also aware that in most cases the same standards are used in bilateral trades (non-OMPs trades).