ACER’s Second Open Letter of 19 July 2018 on REMIT data quality (ACER-VZ-MS-tl-2018-389) lists the following examples of non-compliance with the rules on REMIT gas storage reporting:
1. Timeliness of providing Storage Facility reports and Storage Participant Activity Report not compliant with REMIT Implementing Regulation No 1348/2014
The Agency observed Storage Facility Reports and Storage Participant Activity Reports that did not comply with requirements on timely reporting.
The Agency also observed some cases of early reports (reported before the respective gas day has started).
2. Correctness of providing Storage Participant Activity Report not compliant with Implementing Regulation provisions
The Agency observed incorrect reports with regards to reported amount of gas stored at the end of the gas day.
The amount of gas stored at the end of the gas day should never be a negative value.
3. Frequency of providing Storage Facility reports not compliant with Implementing Regulation provisions
The Agency observed that the frequency i.e. number of records expected and submitted is not in line with the REMIT Implementing Regulation No 1348/2014.
For some storage facilities the foreseen reports are not provided in the stipulated frequency.
The Agency expects reports from all storage facilities for each gas day.
ACER's Questions and Answers on REMIT
Question III.3.30.
Should gas storage nominations be reported as trades?
No, storage contracts are not considered wholesale energy products under REMIT (please see the definition of wholesale energy products under Article 2(4) of REMIT). Storage system operators are required to report nomination data as defined in Article 9(7) of Commission Implementing Regulation (EU) No 1348/2014 as fundamental data. In addition, the market participants or storage system operators (on their behalf) are required to report gas storage data as specified in Article 9(9) of Commission Implementing Regulation (EU) No 1348/2014.
ACER's Questions and Answers on REMIT
Question III.4.1
How can I report fundamental data?
The legal basis for the fundamental data reporting is laid down in Article 8 and 9 of the Commission Implementing Regulation (EU) No 1348/2014. While Article 8 defines the rules for reporting of fundamental data on electricity, Article 9 specifies the rules for reporting of fundamental data on gas including also data on LNG and gas storage.
In order to explain the details of reporting, the Agency has prepared the Manual of Procedures on transaction and fundamental data reporting (MoP). The MoP is available here: https://www.acer-remit.eu/portal/custom-category/acer_remit_reporting_user_package.
The Agency's intention with the MoP is to provide advice for reporting entities concerning the reporting of fundamental and transaction data. The MoP explains the details of procedures, standards and electronic formats for reporting of fundamental data. In particular, the document includes information on the data submission channels, the data validation rules and the XML-schemas to be used for the reporting.
The focus of the first edition of the MoP is to explain the details of the data fields and reportable schemas related to the electricity and gas fundamental data. Examples of data fields and schemas for the LNG and gas storage data will be included in the MoP in the coming months.
ACER's Questions and Answers on REMIT
Question III.4.6
Article 9(9) of Commission Implementing Regulation (EU) No 1348/2014 mentions that: "Market participants or Storage System Operators on their behalf shall report to the Agency and, at their request, to national regulatory authorities the amount of gas the market participant has stored at the end of the gas day. This information shall be made available no later than the following working day." How shall the market participants (e.g. a TSO) using gas storage facilities report the information about the gas quantities stored in the facility/ies?
The amount of gas that the market participant has stored at the end of the gas day, as defined in Article 9(9) of Commission Implementing Regulation (EU) No 1348/2014, could be reported to ACER by the following means:
(i) through the SSO (if mutually agreed between the parties: SSO and market participant being a storage user);
(ii) by the market participant itself, if registered as RRM; or
(iii) by a third party RRM, authorised by the market participant being a storage user.
Manual of Procedures on transaction data, fundamental data and inside information reporting (MoP on data reporting)
6.2.6 Gas storage data
System storage operators (‘SSOs’) shall report to the Agency for each storage facility or, where facilities operated in groups, for each group of storage facilities the following information through a joint platform:
a) The technical, contracted and available capacity of storage facility,
b) Amount of gas in stock at the end of the gas day, inflows (injections) and outflows (withdrawals) for each gas day,
c) Planned and unplanned unavailability announcements of the storage facility including the time of the announcement and the capacities concerned.
Market participants or SSOs on their behalf shall report to the Agency the amount of gas the market participant has stored at the end of the gas day.
For more details on gas storage data reporting please see ANNEX IV and ANNEX VI.
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Commission Implementing Regulation (EU) No 1348/2014
ACER's Questions and Answers on REMIT, Question III.4.6, III, 3.30, III.4.1
Manual of Procedures on transaction data, fundamental data and inside information reporting (MoP on data reporting), point 6.2.6
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