Section P: energy contract volumes and metered volume reallocations |
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Section P sets out how Contract Trading Parties (Trading Parties and NETSO), may notify contract volumes to settlements, specifically to the
Energy Contract Volume Aggregation Agent (
ECVAA). Two types of notifications,
Energy Contract Volume Notifications (ECVNs) and
Metered Volume Reallocation Notifications (MVRNs), are allowed and these can only be submitted on behalf of Contract Trading Parties by agents, appointed by the Parties specifically for this purpose, and known as
Energy Contract Volume Notification Agents (
ECVNAs) and
Metered Volume Reallocation Notification Agents (
MVRNAs) respectively.
(a) how pairs of Contract Trading Parties may authorise ECVNAs or MVRNAs to submit notifications on their behalf, details of the information that such authorisations must contain and the validation checks that the ECVAA applies;
(b) how such ECVNA and MVRNA authorisations may be terminated;
(c) the information that ECVNs and MVRNs themselves must contain and the validation checks applied, including Credit Default;
(d) the process for matching notifications;
(e) the process through which ECVN's Volume Data and MVRNs may be nullified;
(f) the aggregation of the Energy Contract Volume Data and Metered Volume Reallocation Data and the submission of the aggregated data to the Settlement Administration Agent (SAA); and
(g) how the provisions are modified in the event of failure of the ECVAA systems.
For clarity it must be noted that a
Party that registers solely as a
Virtual Lead Party (VLP) shall hold a
Virtual Balancing Account and not
Energy Accounts in accordance with
Section A. Parties that registers solely as VLP’s are therefore are not considered Contract Trading Parties and may not notify
Energy Contract Volume Notifications (ECVNs) or
Metered Volume Reallocation Notifications (MVRNs) to settlement.
It is emphasised that ECVNA and MVRNA authorisations may only be made in the form specified, with no scope for Contract Trading Parties to specify any additional kind of qualification or condition on the agents. The authorisation specifies the period in which the agent may submit a notification on behalf of the relevant Contract Trading Parties, but the notifications submitted may then cover a period that extends beyond the period of authorisation.
Notifications submitted by agents are deemed to be correct, and there is no basis for Contract Trading Parties to challenge any notification that has been properly submitted on their behalf. Notifications will have no effect on Settlement Periods for which the Submission Deadline has past when the notification is received.
The sign convention applying to notifications is defined by stating that volumes specified in any notification are deducted from the "Energy (From) Account" and added to the "Energy (To) Account" specified in the authorisation. However volumes can be positive or negative. For the avoidance of doubt, the Energy (From) Account and Energy (To) Account may belong to the same Trading Party, i.e. the Production and Consumption Accounts of a single Trading Party, but an ECVNA or MVRNA authorisation is still required.
Where the same ECVNA (or MVRNA) is appointed by each of the two relevant Contract Trading Parties, the ECVNA (or MVRNA) so appointed shall submit ECVNs (or MVRNs) on behalf of each of those Contract Trading Parties.
During certain
Contingency Provisions detailed in
Section G, e.g. Black Start,
Energy Contract Volume Notifications are disregarded for the purposes of settlement. Furthermore, notifications submitted during such periods which have an effect outside the period may be disregarded (and consequently required to be re-submitted in order to have effect).
Energy Contract Volume Notification Agent Authorisations
Submission of
ECVNA Authorisations must be made in accordance with
BSCP71 and must specify:
(a) the relevant ECVNA(s);
(b) the Relevant Contract Parties;
(c) the Energy (To) Account and Energy (From) Account;
(d) the day on which the authorisation is intended to take effect; and
(e) whether the Energy Contract Volume Notification Agent is authorised to submit:
(i) only Replacement Energy Contract Volume Notifications; or
(ii) only Additional Energy Contract Volume Notifications; or
(iii) either Additional Energy Contract Volume Notifications or Replacement Energy Contract Volume Notifications.
An
ECVNA Authorisation may specify an end date or is, in the absence of any specified end date, 'evergreen'. Certain basic conditions must be fulfilled for the authorisation to be valid, i.e. the
Relevant Contract Parties must be Contract Trading Parties and the
ECVNA(s) must have fulfilled qualification criteria set out in
Section J. In addition the
Energy Accounts specified must be
Energy Accounts of the Relevant Contract Trading Parties although the form in
BSCP71, by specifying the
Energy Accounts as either the Production or
Consumption Accounts of the
Relevant Contract Parties, makes it impossible for this not to be the case.
Items under (e) can be amended at a later date using the form in
BSCP71.
As specified in BSCP71, the ECVAA will undertake the necessary validation checks and notify the Parties and ECVNA(s) that the authorisation has been confirmed or rejected.
Termination of ECVNA Authorisations
An
ECVNA Authorisation remains in force until the specified end date (if any) or if either of the
Relevant Contract Parties ceases to be a
Contract Trading Party. An authorisation also may be terminated in accordance with
BSCP71 by either of the Relevant Contract Trading Parties or by either of the
ECVNAs, the consent of all of whom is required when the authorisation is created. An authorisation will also be terminated if, at any stage, a subsequent valid authorisation is received for the same Contract Trading Parties, Agent and
Energy Accounts. Again, as specified in
BSCP71, the
ECVAA will notify the Contract Trading Parties and Agent of a terminated authorisation.
Nothing in the BSC prevents Contract Trading Parties from authorising more than one agent in respect of a given pair of Energy Accounts. The BSC does, however, provide for a second or "successor" Authorisation to state that it replaces a prior Authorisation in the case where the Contract Trading Parties are the same, thereby terminating the prior Authorisation.
Energy Contract Volume Notifications
An Energy Contract Volume Notification (ECVN) shall be one or more of the following types:
An Additional ECVN is where the ECVN (the "second" such notification) submitted for which the relevant ECVNA, Energy (From) Account and Energy (To) Account are the same as those for an earlier valid ECVN (the "first" such notification), the second notification does not specify that it is to replace the first notification and the period for which the second notification shall be effective includes one or more Settlement Periods that are within the period for which the first notification is effective.
An Initial ECVN is where no earlier valid ECVN with the same Energy Contract Volume Notification Agent, Energy (From) Account and Energy (To) Account has been acknowledged. Or an ECVN (the "second" such notification) submitted for which the relevant ECVNA, Energy (From) Account and Energy (To) Account are the same as those for an earlier valid ECVN (the "first" such notification) and the second notification is not an Additional ECVN or a Replacement ECVN in relation to the first notification.
A Replacement ECVN means an ECVN (the "second" such notification) submitted for which the relevant ECVNA, Energy (From) Account and Energy (To) Account are the same as those for an earlier valid ECVN (the "first" such notification), the second notification specifies that it is to replace the first notification and either:
the Effective from Date of the second notification is the same as or prior to the Effective to Date of the first notification; or
the first notification has no Effective-to Date.
The BSC requires that an ECVN specifies the Energy Accounts (achieved in practice by specifying the relevant authorisation), the first Settlement Day on which the ECVN is intended to be in force (i.e. the 'Effective-from Date') the MWh quantity for each Settlement Period, which may be any number between –99,999.999 and +99,999.99. The ECVNA may also specify the last effective Settlement Day (i.e. the 'Effective-to Date') to be later than the first, which implies that the MWh quantity specified for the Settlement Period is to be repeated for the same Settlement Period on each Settlement Day for which the ECVN is in force. If the last effective Settlement Day is specified to be the same as the first then the ECVN applies for a single day only, and where the last effective Settlement Day is not specified then the notification is evergreen, i.e. applies to every Settlement Day until further notice.
If the ECVAA determines that an ECVN submitted by an ECVNA is not valid, the ECVAA will inform the Relevant Contract Parties and ECVNA, unless it has been requested not to notify a Relevant Contract Party or agent by that Relevant Contract Party or agent.
Refusal and Rejection for Credit Reasons
If either Relevant Contract
Party is in
Level 2 Credit Default, as determined under
Section M, then:
(a) for any valid ECVN which has been previously accepted, Energy Contract Volumes for Settlement Periods for which the Submission Deadline falls within the "Credit Default Rejection Period" which have the effect of increasing the Energy Indebtedness of the Relevant Contract Party in default, will be disregarded; and
(b) further ECVNs submitted during the "
Credit Default Refusal Period" (see
Section M) which have the effect of increasing the
Energy Indebtedness of the Relevant Contract
Party in default will not be accepted.
Note that ECVNs that have been previously accepted will become effective again as soon as the Relevant Contract Party ceases to be in default, but only for Settlement Periods for which the Submission Deadline falls after the Credit Default Rejection Period.
Metered Volume Reallocation Notifications and Authorisations
The provisions that apply to MVRNs are identical to those that apply to ECVNs except that:
(a) ECVNA is replaced by the MVRNA;
(b) in place of the Relevant Contract Parties and Energy Accounts, the MVRNA Authorisation must specify the Primary BM Unit to which it relates, the identity of the Lead Party of the Primary BM Unit and the identity of the Subsidiary Party and the Energy Account to which:
(i) a fixed MWh quantity of the Primary BM Unit Metered Volume is to be reallocated from the Primary BM Unit for energy imbalance settlement purposes; and/or
(ii) a proportion of the Primary BM Unit Metered Volume less the ‘Period BM Unit Bid-Offer Volume’ from the Primary BM Unit is to be reallocated from the Primary BM Unit for energy imbalance settlement purposes;
in each case the quantity of energy transferred for energy imbalance purposes is multiplied by the
Transmission Loss Multiplier for the
BM Unit (see
Section T).
For clarity the BM Unit to which MVRNs relate to cannot be a Secondary BM Unit
(c) for a MVRNA Authorisation to be valid, the Lead Party must be the Lead Party of the BM Unit, the Subsidiary Party must be a Contract Trading Party, the MVRNA(s) must have qualified and the Energy Account of the Subsidiary Party must be the same type, i.e. Production or Consumption, as the BM Unit.
As for the ECVN the fixed MWh quantity may be any number between –99,999.999 and +99,999.99, with the difference being (as defined in
Section T, and noted above) that a MVRN fixed quantity is applied before determining transmission losses whilst the fixed quantity specified in an ECVN is applied after determining transmission losses. The percentage quantity specified in an MVRN, representing the proportion of a
BM Unit Metered Volume allocated to the
Subsidiary Energy Account, must be between 0 and 100%. In both the case of the fixed reallocation and percentage reallocation where no value is specified it will be assumed to be zero.
Further validation checks are carried out to ensure that in any Settlement Period all percentage re-allocations relating to a BM unit do not exceed 100%. If that is the case the MVRNs will be disregarded in inverse chronological order until the total percentage equals or is less than 100%.
As detailed in
Section T, both the percentage reallocation and fixed reallocation are used in the determination of the
Credited Energy Volume for both the Lead and
Subsidiary Party. The same provisions for refusal and rejection for credit reasons apply. In addition, the same matching process is carried out, with the exception that an additional criterion applies – the percentage value of the reallocation must match.
Section M defines the effect an MVRN has on
Energy Indebtedness, recognising that the quantity of energy implied by the percentage reallocation cannot be known until the metered quantities are established, i.e. not until after real time.
Either member in a pair of Contract Trading Parties may submit a request to the ECVAA to nullify all ECVNs and all MVRNs effective between those Parties. The request, known as a Volume Notification Nullification Request (VNNR), must specify the following:
(a) the Energy (From) Account and the Energy (To) Account for the Energy Contract Volume Notifications that are to be nullified;
(b) the Lead Energy Account and the Subsidiary Energy Account for the Metered Volume Reallocation Notifications that are to be nullified; and
(c) the intended Settlement Day and Settlement Period from which the nullification is to apply.
Upon receipt of a VNNR, the ECVAA will assess validity of the request. A VNNR will be validated if:
(a) the required information has been submitted (see above); and
(b) all ECVNA Authorisations and all MVRNA Authorisations between the relevant accounts have been terminated.
Upon validation of a VNNR, the ECVAA shall, within the required timescales, inform both Contract Trading Parties of the Settlement Period from which the nullification shall be effective and commence nullifying all relevant Energy Contract Volumes and Metered Volume Reallocations. Where a VNNR is not validated, the ECVAA shall inform the Contract Trading Party which made the request within the required timescales.
For ECVNs, the net contract position, known as the Account Bilateral Contract Volume, for each Contract Trading Party's Energy Account is established by summing the data for all valid notifications submitted and not rejected (for credit reasons) for which the Energy Account is the Energy (From) Account and subtracting the sum of the equivalent data where the Energy Account is the Energy (To) Account. These aggregated quantities are sent to the SAA.
For MVRNs, the fixed quantities and the percentage quantities are summed for each BM Unit and sent to the SAA. Just as an individual percentage quantity in an MVRN applying to any given Settlement Period cannot exceed 100%, so the total of the percentages for all MVRNs applying to any Settlement Period cannot exceed 100% either. If this is not the case then the most recently received MVRN or MVRNs are disregarded in their entirety until the criteria is met.
Failures of the ECVAA System
A failure of the ECVAA System may impair the ability for the ECVAA to receive notifications before the Submission Deadline of one or more Settlement Periods to which notifications relate. Consequently an ECVAA System Failure is defined as a failure of the ECVAA System which has the effect that the ECVAA is unable to receive notifications and/or the failure of the ECVAA to send confirmation of receipt of notifications within 20 minutes.
Two times are defined: the system failure time, being the time at which the system failure started; and the resubmission deadline, being the end of the next Business Day following the end of the system failure (or more precisely the time the ECVAA notifies Elexon of the same). Elexon can vary these times if it considers this appropriate.
Consequences of ECVAA System Failure
Where a failure occurs, Elexon and the ECVAA are required to notify Contract Trading Parties and agents of the start of the failure and of the end of the failure. After the failure has ended then up to the resubmission deadline, notifications may be resubmitted in relation to Settlement Periods for which the Submission Deadline occurs between the system failure time and the resubmission deadline. This is intended to allow agents up until the end of the next following Business Day to submit the notifications that they were unable to during the failure itself, plus any consequential notifications for the Settlement Periods after the system has been restored but which may be before the agent has been able to make any resubmissions.
Where the notification by some but not all agents is affected, the provisions applying following an ECVAA System Failure may apply to the affected agents only. If a Contract Trading Party or agent considers that there has been an ECVAA System Failure but no such failure has been announced by Elexon or the by the ECVAA, then Elexon must investigate and determine whether an ECVAA System Failure affecting the agent has indeed occurred
Note that in making ex-post notifications, only those notifications which would have been submitted before the relevant the Submission Deadline may be submitted, i.e. the BSC does not facilitate ex-post trading during an ECVAA System Failure, only the ex-post notification of ex-ante trades.
Recognising that an ECVAA System Failure could have prevented the submission of notifications that would have decreased the Energy Indebtedness of a Contract Trading Party, credit checking is suspended until there is no longer material doubt as to the accuracy of the credit calculations.
Where an ECVAA System Failure has affected some but not all agents, it may be impracticable for the ECVAA to maintain a normal service to unaffected agents and Contract Trading Parties, whilst simultaneously endeavouring to process a backlog of notifications from affected agents. Under such circumstances, Elexon or the ECVAA may determine that the ECVAA System should be withdrawn from operation and the procedures for ECVAA System Failure be applied to all agents.
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