We are a utility and fall under the REMIT regulation. We ask you to answer us the following questions concerning transaction reporting
- There is a non-standard contract with a defined price and a fixed (no flexibility) volume for the delivery period. The profile of the volume is shaped (every hour another volume). Is it necessary to report executions for this contract, although it is possible to determine the notional amount (data field 38) and the total notional contract quantity (data field 41) for table 1 of the trum?
- Market participants are required to report (within table 1) the data fields „Load delivery intervals“ (data field 54), „Delivery capacity“(data field 55), „Quantity unit used in field 55“ (data field 56) and „Price/time interval quantity“ (data field 57). The examples in the annex II of the TRUM implicate that these data fields only have to be populated in case of deals/contracts which have been concluded at an OMP (e.g. an auction). In all other examples in the annex II (including examples for non standard deals) these data fields aren´t populated. Given that we ask you to answer us the following questions:
- Have these data fields to be populated in case of OMP contracts/deals only or also in the case of non-OMP deals/contracts?
- Have these data fields to be populated only in case of standard contracts or also in case of non-standard-contracts (executions of non-standard-contracts)?
- The examples of the annex II in the TRUM indicate that the load type for gas deals is in all cases “Gas day (GD)” irrespective if the load is variable or not variable. Is this correct or do we have to define the load type of deals with variable load profile as “shaped” (as in the case of power contracts)?
Example for 1:
Delivery Period: 01.01.16 (06:00) – 01.01.17 (06:00)
Price: 25 EUR/MWh
Total Volume: 20.000 MWh
Hourly Volume: 01.01.16 06:00 2,3 MWh
01.01.16 07:00 1,8 MWh
01.01.17 06:00 1,2 MWh
Our interpretations of the two cases are
The contract has to be reported using Table 1 of the Implementing Acts because it has a defined price and volume. It’s not necessary to report executions.
Based on the information provided above, it is our understanding that, since the contract has defined price and volume, it has to be reported using Table 1 of Commission Implementing Regulation (EU) No 1348/2014. It is not necessary to report executions.
Annex II to the TRUM suggests that examples from one type of contract can be used to report another type of contract.
Regarding question 3, based on the information provided above, it is our understanding that the reporting will depend on the contract. If the contract defines the shape, then the shape should be reported. If the contract defines the amount of gas for a day but nomination can be done at any hour of the day, then the gas day values should be reported.