EECS Electricity Domain Protocol. for Finland

Transcription

1 EECS Electricity for Finland Prepared by Grexel Based on EECS Rules Release 7 Release 1

2 Contents A Introduction... 3 B Background... 3 B.1 Purpose... 3 B.2 Scope... 3 B.3 Roles and Responsibilities within the Domain... 3 B.4 General... 5 C Overview of national legal and regulatory framework... 5 C.1 EECS Certificate systems... 5 C.2 National Electricity Source Disclosure... 7 C.3 National Public Support Schemes... 7 C.4 Major Deviations from the EECS Rules... 8 D Registration... 8 D.1 Registration of participants... 8 D.2 Registration of Production Devices E Certificate Systems Administration E.1 Issuing EECS Certificates E.2 Form E.3 Transferring EECS Certificates E.4 End of life of EECS Certificates E.5 Administration of corrections and errors F Audit of Production Devices F.1 On-site audits F.2 Production Device registration re-check F.3 Production audits G Change Control (see EECS Rules, section L) G.1 Complaints and Disputes G.2 Change requests Annex 1: Contacts List Annex 2: Standard Terms And Conditions Annex 3: Know-Your-Customer Questionnaire Annex 4: Production Device Registration Form Annex 5: Power of Attorney Template Annex 6: Issuing Request Annex 7: Model Cancellation Statement Grexel Systems Oy 2012 Page 2 of 29

3 A Introduction The framework specified in the EECS Rules and the detailed procedures and conditions specified in this have the main objective of ensuring robustness and transparency in the facilitation of the EECS Electricity Scheme for all Scheme Participants. Important contact information is provided in Annex 1. B Background B.1 Purpose B.2 Scope This sets out the procedures, rights and obligations for the administration of EECS within a specific Domain and relating to certain EECS Products. This is made binding between the Scheme Participant and Grexel Systems Ltd. by agreement in the form of the Standard Terms and Conditions. The objective is to ensure an acceptable level of robustness and transparency in the facilitation of the EECS Electricity Scheme for all Scheme Participants. A promotes quality and clarity, as it: makes local rules transparent; provides clear information to all stakeholders (consumers, market parties, other members, government, the EU Commission etc.); facilitates assessment of compliance and permissible variance from EECS Rules; facilitates audit; and translates local rules into a single format and language, supporting each of the above. This sets out the procedures, rights and obligations: which apply to the Domain of Finland and relate to the EECS Electricity Scheme (as defined in section N of the EECS Rules) and the following EECS Products for the purpose of electricity disclosure: o o o o EECS-GO, ICS:RECS, ICS:EKOENERGY, ICS:EECS-DISCLOSURE B.3 Roles and Responsibilities within the Domain The following roles are defined in the Finnish domain Competent Authority By the Act on Verification and Notification of Origin of Electricity (1129/2003), Fingrid Oyj (government controlled transmission system operator in Finland) is the appointed Competent Authority of the Guarantee of Origin system in Finland. Grexel Systems Oy 2012 Page 3 of 29

4 Measurement Body Fingrid also acts as the measurement body in the Finnish EECS scheme. A Measurement Body is an organisation responsible for the collection of metering data relating to the output of the Production Device. Issuing Body and Registry Operator Grexel is responsible for issuing EECS Certificates and operating the EECS scheme in Finland. Grexel acts also as the Registry Operator for the domain Finland. The central registry can be found at: Production Registrar Production Registrars verify Production Device data as part of the registration process when deemed necessary by the Issuing Body. Production Auditor Production Auditors verify production declarations and (where appropriate) consumption declarations made by registrants of Production Devices when deemed necessary by the Issuing Body. The operation of the Production Auditor is under the control of Grexel and the Association of Issuing Bodies. Scheme Participant Scheme participant is an Account Holder or a Registrant of a Production Device on the EECS registration database. Grexel Systems Oy 2012 Page 4 of 29

5 B.4 General The EECS Rules and its subsidiary documents take precedence over this document except as stated in section C.4 of this document. The definitions used in s shall have the meanings ascribed to them in the EECS Rules except as stated in section C.4 of this document. Grexel preserves the operational and standing data as follows: Data Time Medium Standard terms and conditions and its appendices Production Device Registration forms, audit reports and powers of attorney 5 years Electronic Archive 5 years Electronic Archive Meter reading data 2 years Database backups Transaction data 10 years Database backups C Overview of national legal and regulatory framework C.1 EECS Certificate systems For the Finnish Domain, the relevant local enabling legislation is as follows: Issuing of Guarantees of Origin (RES) and electricity disclosure in Finland is implemented by the law: Laki sähkön alkuperän varmentamisesta ja ilmoitamisesta - Act on Verification and Notification of Origin of Electricity (1129/2003) o o Unofficial translation: and by secondary legislation, the government decrees Valtioneuvoston asetus sähkön alkuperän varmentamisesta Government Decree on Verification of Origin of Electricity (1357/2003) o o Unofficial translation: o Valtioneuvoston asetus sähkön alkuperän ilmoittamisesta - Government Decree on Notification of Origin of Electricity (233/2005). o o Unofficial translation: Cogeneration Guarantee of Origin is implemented by governmental decree: Valtioneuvoston asetus sähkön alkuperän varmentamisesta annetun valtioneuvoston asetuksen muuttamisesta (97/2010) o Grexel Systems Oy 2012 Page 5 of 29

6 o Enables issuing of cogeneration GOs. The most relevant aspects of the decree are translated below. These Act and Degrees transpose Article 5 of 2001/77/EC (RES-E Directive), Article 3 of 2003/54/EC (Internal Electricity Market Directive) and Article 5 of 2004/8/EC (Cogeneration Directive). The main provisions defined in 1129/2003 include: 2 : Sets the energy sources and production technologies eligible for receiving Guarantees of Origin to be later defined in governmental decrees. o Later defined as all renewable energy sources (233/2005) and CHP (97/2010) with the exception of auxiliary consumption. 3 : Mandates the TSO Fingrid to issue Guarantees of Origin for all eligible electricity production. The pricing of the service shall be moderate. 4 : Verification of power plants by accredited auditors. 11 : Electricity suppliers need to, in bills and promotional materials, disclose the origin of the supplied electricity. 12 : The Finnish Energy Market Authority is responsible for the supervision of compliance to this act. The main provisions defined in 97/2010 include: 3 (2): A guarantee of origin can be granted for electricity produced from efficient cogeneration of power and heat. 4 : The information content of a guarantee of origin is complemented as follows: o 1: The capacity of the plant in megavolt ampere o 2: Concerning cogeneration GOs: the lower calorific value of fuels, the use purpose of heat as well as the volume of primary energy savings calculated according to Annex II of 2004/8/EC. 5 : The verification of the technology and energy sources of the plant for issuing guarantees of origin is equal to the verification of the plant in the European Energy Certificate System (EECS). The verification of the plant is valid for a maximum of five years. 9 : When requesting issuance of GOs, the holder of the plant must announce to the issuing body: o The quantity and time of electricity production o For cogeneration GOs of auxiliary electricity consumption: the auxiliary electricity consumption and electricity fed into the grid separately o For a plant using multiple energy sources: fuel consumption separated by energy source. Evidence that the Authorised Issuing Body (Member) has been properly nominated as a Competent Authority or has been properly appointed to issue Certificates for an ICS Fingrid Oy is nominated as the issuing body of RES and cogeneration GOs in Finland according to Act on Verification and Notification of Origin of Electricity (1129/2003) ( Grexel has entered into agreement with Fingrid regarding issuing and database administration of EECS-GO Certificates in Finland. According to the agreement, Grexel Systems Oy 2012 Page 6 of 29

7 Fingrid does issue only one Guarantee of Origin per MWh and if an EECS-GO is issued, it shall not issue any other Guarantee of Origin, in paper or any other form, for the same MWh. Grexel is appointed to issue ICS:RECS Certificates by appointment letter from RECS International. C.2 National Electricity Source Disclosure Legislation and regulation: The legislation regarding electricity disclosure implementing Article 3 of 2003/54/EC (Internal Electricity Market Directive) is included in the legislation for issuing Guarantees of Origin. Summary of the disclosure methodology and process: The Act on Verification and Notification of Origin of Electricity (1129/2003) puts electricity suppliers under obligation to disclose in bills and promotional material the contribution of each energy source to the overall fuel mix as well as the reference to statistical information regarding CO2 and radioactive waste content of the electricity. The different energy sources need to be disclosed at a level of: renewable, nuclear and fossil. The Energy Market Authority of Finland is responsible for the supervision of disclosure information. The current compelling regulation does not provide detailed guidance for electricity disclosure. In practice the electricity suppliers use a disclosure recommendation from the Finnish Energy Industries ( for disclosure of electricity from unknown origin ( (only in Finnish)). This mix is based on the Nordic residual mix, calculated by the RE-DISS project. Today, no obligation exists to use this mix and contract based tracking is allowed to be used for explicit tracking. C.3 National Public Support Schemes In the beginning of 2011, the law, which enables feed-in tariff for wind energy, biogas and small-scale (100kW 8 MW) CHP from wood energy, came into force (1396/2010) ( The FIT guarantees a price of /MWh for electricity for 12 years. The windmills will get an elevated price of /MWh during the first 3 years of operation or until the end of 2015, whichever comes first. The feed-in tariff system functions like a premium system, in which producers sell the electricity on the market and receive a bonus for each MWh, which equals the difference between the target price and average price of electricity during the previous three months at the location of the generator. All Production Devices, which use the abovementioned energy sources/technologies and which were installed after the beginning of 2009, are eligible for the FIT system. For plants using forest residuals the support is determined by the average price of CO2 allowances in the Emission Trading System. If the average price of past three months in the three largest CO2 allowance exchanges has been lower than 10, the support is 18 /MWh. If the average price is above 10, the support decreases linearly towards zero (zero is reached at the average price of 23 ). Small CHP plants (capacity between 100 kw and 8 MW) using 100 % forest residuals as fuel source are eligible for the feed-in tariff instead of the forest residual support scheme. Grexel Systems Oy 2012 Page 7 of 29

8 For new technologies (e.g. wood gasifiers) an investment support scheme exists, in which the support decision is taken individually for each plant. A plant can be eligible for both the forest residual support scheme and investment support scheme, but not both for the feed-in tariff and another support scheme. No relation exists between renewable energy support and electricity disclosure. FIT is the financial support and GO is the proof of ownership of generation attributes. The legislation does not set any restrictions for issuing and cancelling Guarantees of Origin from supported electricity generation. C.4 Major Deviations from the EECS Rules D Registration Due to timelines related to closing of national balance settlement, issuing of EECS Certificates is possible at the earliest 5 th of the month after the month following the month of production. This is not in line with C3.4.1 of the EECS Rules but necessary in order to link correction procedures to the correction procedures of the balance settlement. D.1 Registration of participants Applications 1. Any legal person who is not a member of the Association of Issuing Bodies or such member s affiliate or agent can be a participant of the EECS Scheme. An application to become an Account Holder is done by filling out and signing two copies of the Standard Terms and Conditions form found at (Annex 2) and sending those to Grexel. The required attachments of the Standard Terms and Conditions include: a. Contact Information Sheet b. A certified trade registry extract or similar official document stating: i. That the organization is validly existing and founded under the laws of the mother country ii. Name and address of the organization iii. Business ID of the organization iv. Names of authorized signatories 1. The Standard Terms and Conditions should be signed by this/these Signatory/Signatories c. The copy of the passport or other legitimate ID of each signatory of the STC. d. The copy of the passport of the Authorized Person (root user). e. The applicant must also fill in and attach a Know-Your-Customer questionnaire prepared by the AIB (Annex 3). The purpose of this document is to protect the EECS markets from VAT frauds. i. For licensed electricity producers and/or suppliers located in Finland or Sweden, the Know-Your-Customer questionnaire is not required. 2. After receiving all documentation of the applicant, Grexel evaluates whether the application can be accepted. Handling time of properly submitted applications is 5 business days. Reasons for rejection may be a. Required documents are missing or not properly filled / signed b. Grexel has doubts about the expertise and/or aims of the applicant Grexel Systems Oy 2012 Page 8 of 29

9 c. Rejection recommendation by local tax authorities, Fingrid, or the AIB. 3. If the application is accepted, Grexel creates an Account in the CMO.grexel registry for the applicant organization. When the Account is activated, a log-in authorisation Certificate will be sent via to the applicant, awarding full rights to the created Account (root user). The password to install the Certificate will be sent via sms. The applicant organization is then an Account Holder of CMO.grexel and can start operating the Account. One Account Holder organisation can have multiple users, which can be created by the root user of that Account Holder. 4. Grexel signs both copies of the STCs and archives the other and sends the other to the Account Holder to be archived. Grexel holds an Account in the Finnish domain. Grexel may own a Certificate for the below listed purposes, but it reports such activity to the Association of Issuing Bodies: Testing Undisputed debt Own use Resignation The Account Holder must notify Grexel of intent to close its Account in written form. The effective date of closure must not be less than 10 working days from the date of receipt by Grexel. When closing an Account, the Account Holder is responsible for paying any outstanding payments to Grexel. Grexel is not responsible for refunding any already paid fees of the Account Holder such as the yearly fee for Account Holders and Production Devices. Grexel will amend the EECS Registration database to seal that Account as of the effective date on the request or 10 days from the date of receipt by Grexel, whichever is later. Commercial provisions of closing an Account are set in the contract between Grexel and the Account Holder. Maintenance of standing data An Account Holder must notify Grexel without any delay, in writing of any changes due to come into effect that will result, or unplanned changes that have resulted, in the information recorded in the EECS Registration Database in relation to the Account Holder becoming inaccurate. Grexel will amend the EECS registration database accordingly, without delay. Error handling: If Grexel detects errors in the Account Holder information, it will correct them without any delay. The relevant Account Holder will be informed of such actions. Grexel Systems Oy 2012 Page 9 of 29

10 D.2 Registration of Production Devices Process: Responsible Activity Issuing Body (Grexel) Production Registrar Account Holder (Registrant) Owner of PD 1. Fill in PD information in CMO.grexel 2. Include in the application a line diagram of the PD. 4a No 1 3. In case the Registrant or it s affiliate is not the (sole) owner of the PD, it must include a power of attorney signed by (other) owner(s) of the PD. Yes 4b 2 3 4a. Verify the information in the application for registration. 4b. Is physical inspection of the Production Device necessary? Yes 5a. Accredited Production Registrar conducts a physical inspection of the Production Device. 5b. Does the Production Device comply with the law and EECS rules? 6. Send the Producer (or its agent) formal rejection of the application for registration No 5b 5a No 6 7. Activate PD and set next audit date Yes 8. Send the Producer (or its agent) formal approval of the application for registration. 7 8 Offline Process Online process Document Decision Application Account Holders, which aim to register a Production Device, are referred to as registrants. Only the owner of a Production Device, or a Registrant duly authorised by the owner, may register a Production Device, which is located in Finland, into the EECS registration database. Production Devices can only be registered if they meet the qualification criteria for EECS. To be qualified, Production Devices must: be situated in Finland be capable of producing electricity In addition, different EECS products have additional qualification criteria: EECS Product Additional criteria GO GO When relating to energy source When relating to technology ability to produce electricity using renewable energy source(s) capable of Cogeneration and conforming to the definition of a Cogeneration unit in Article 3(l) of the Cogeneration Directive Grexel Systems Oy 2012 Page 10 of 29

11 ICS:RECS ICS:EKOENERGY ICS:EECS-DISCLOSURE and is in accordance with the guidelines established by Annex II (e) of the Cogeneration Directive ability to produce electricity using renewable energy source(s) registration is approved by the Scheme Operator: The Finnish Association for Nature Conservation (FANC) ability to produce electricity using non-renewable energy source(s) 1. Registrant or Registrar must fill-in the following information when registering a Production Device under its Account in the CMO.grexel system: Production Device: Name, address, registrant, start date, commissioning date, installed capacity, earmark name and type, operator, applied EECS schemes and all owners. Codes of all possible Fuels, which can be converted into energy by that Production Device. According to fuel codes in AIB EECS Fact Sheet 5. Technology code of the Production Device according to technology codes in AIB EECS Fact Sheet 5. The Registrant consents to the publication by Grexel of limited data of the Production Device: Name Domain GSRN number Fuel(s) Technology Installed capacity Date of commissioning Location Name and address of operator Support schemes As the Production Device is registered into CMO.grexel, it is assigned a unique identifier, if one has not already been assigned. The identifier consists of a number with 18 numeric characters that also identifies the Domain of origin. GS1/GSRN (Global Service Relational Number) coding is used. The Registrant must warrant that the information provided to Grexel in connection with its application is complete and accurate and that the Production Device meets the qualification criteria for EECS. This is accomplished by printing out a paper Registration Form (Annex 4) and returning it to Grexel signed by properly authorized person. 2. Along with the Registration Form, the Registrant shall also deliver a line diagram representing the Production Device with at least the following information: Connection to grid(s) Location and codes of all output and import meters Location of transformers Location of generation auxiliaries Grexel Systems Oy 2012 Page 11 of 29

12 where there are generating auxiliaries associated with that Production Device, locations and codes of Import Meter(s), which determine the totality of electricity consumption by the Production Device; 3. In case the Registrant or its affiliate does not own more than 90 % of the Production Device, it must include in the application a power(s) of attorney (Annex 5) signed by other owner(s) of the Production Device. Power of Attorney is required from all owners of the PD who own more than 5 % of the PD. The Power of Attorney (PoA) may give the registrant organization the authority to o register the Production Device, and/or; o deliver production declarations for the Production Device, and/or; o claim ownership of GOs issued for the Production Device (aggregation). Aggregation can also be authorized later as a separate process. 4. Grexel verifies the application and determines if an on-site audit is required. Audit may be deemed unnecessary if relevant registration data can be verified using other reliable sources, such sources being for example: Registration for the purpose of emission trading scheme Registration for Finnish government support scheme Registration for the purpose of license to connect to the grid or distribution network 5. If an on-site audit is required, authorized Production Registrar performs it. Production Registrar confirms the registration data by signing the Registration Form printed our from the central registration database Production Registrar may also correct and comment some of the data in the Registration Form. Grexel will amend the data in the registration database before activating the Production Device accordingly. 6. If the Production Device does not satisfy either the Finnish laws or the EECS Rules, Grexel informs the registrant. The rejection notice shall include reasons of the rejection. These reasons might be for example: in relation to that application, the applicant has failed to comply with any requirement of this or the Standard Terms and Conditions; the qualification criteria are not satisfied in respect to that Production Device; there are one or more generating auxiliaries for that Production Device which do not fit with Import Meters; or the Production Registrar is prevented from satisfactorily verifying the application by the applicant or the owner or operator of the relevant Production Device. 7. If the Production Device satisfies both the Finnish laws and the EECS Rules, Grexel activates the Production Device in the registry database and sets next audit date. Grexel Systems Oy 2012 Page 12 of 29

13 8. When the Production Device is activated, Grexel informs the registrant accordingly. Resignation The Registrant must notify Grexel of intent to deregister their Production Device in writing. Commercial provisions of deregistering a Production Device are set in the contract (Standard Terms and Conditions) between Grexel and the Account Holder. Initial inspection and subsequent audit of Production Devices: If deemed necessary by Grexel, an on-site audit must be performed by an accredited production registrar at the expense of the registrant. Production Devices registration data needs to be checked every five years. Production Devices can also be inspected at a random time, if necessary. Registration data can be checked by an on-site audit by accredited production registrar or Grexel may deem initial or on-site audit unnecessary if relevant Production Device data can be verified using other reliable sources, such as: Registration for the purpose of emission trading scheme Registration for Finnish government support scheme Registration for the purpose of license to connect to the grid or distribution network Maintenance of standing data The Registrant of a Production Device must notify Grexel of any planned changes due to come into effect that will result, or unplanned changes that have resulted, in: the information recorded in the EECS Registration Database in relation to the Production Device becoming inaccurate; or the qualification criteria for the EECS Scheme ceasing to be satisfied with respect to that Production Device. The registrant notifies Grexel of such changes by making the necessary amendments to Production Device information in the central Certificate registry CMO.grexel. On receipt of a change of details notification (following an inspection or otherwise), Grexel will evaluate the impact of the changes on the Qualifying Criteria and respond to the Registrant within 10 working days specifying the decision taken. Grexel may respond to the changes by approving or disapproving them in the central Certificate registry CMO.grexel. Where Grexel becomes aware that a Production Device no longer fulfils, or will no longer fulfil, the qualification criteria, the EECS Registration Database record for that Production Device will be updated to shown that the Production Device no longer qualifies for EECS Scheme Certificates with effect from: (in relation to planned changes notified in advance) the date on which such planned changes are due to come into effect; or (in relation to other changes) as soon as reasonably practicable after becoming so aware. Grexel Systems Oy 2012 Page 13 of 29

14 Error handling If Grexel detects an error in the information of a Production Device in the central registry, it applies the procedures outlined in Chapter D.2.5. Production Devices located on border between domains For the time being, this is not relevant for the Finnish domain. Grexel Systems Oy 2012 Page 14 of 29

15 E Certificate Systems Administration E.1 Issuing EECS Certificates Qualification and EECS Products EECS Certificates can be issued a) in respect of the qualifying energy output of such a Production Device during any period in which it was registered for the purpose of the EECS scheme according to D.2; and b) for a maximum period of 12 months at a time; and c) when issuing request for production that took place previous calendar year was submitted by 5 th of March the following year at the latest; and d) to an Account Holder who does not have any outstanding fees payable to Grexel or its agents in conjunction with EECS Certificates; and e) for EECS products according following additional criteria: EECS Product GO When relating to energy source GO When relating to technology ICS:RECS ICS:EKOENERGY ICS:EECS-DISCLOSURE Additional criteria respective electricity is generated using renewable energy source(s) a) where the Production Device produces High-Efficiency Cogeneration only, the amount of electrical Output produced by that Production b) where the Production Device produces High-Efficiency Cogeneration and electricity which is not High-Efficiency Cogeneration, the amount of eligible generation calculated in accordance with Annexes II and III of the Cogeneration Directive respective electricity is generated using renewable energy sources registration is approved by the Scheme Operator: The Finnish Association for Nature Conservation (FANC) respective electricity is generated using nonrenewable energy source(s) The EECS Scheme Certificates shall be issued in such format as may be determined by AIB from time to time. Grexel Systems Oy 2012 Page 15 of 29

16 Processes: Issue GOs Activity Competent Body (Fingrid Oy) Issuing Body (Grexel) Production Auditor Registrant 1. Issuing request for continuous issuing or relating to a specific time period Collect production data and send to Grexel 2* 3. If the request is for multifuel PD, pumped hydro or cogeneration GOs, has the registrant submitted all required information? 3a. If the request is for cogeneration GOs, fill in cogeneration declaration and send it to Fingrid 3b. If the request is for multifuel PD or pumped hydro, fill in production declaration in CMO.grexel. 3 3a 3b 4. Issue EECS certificates to the account nominated by the registrant. 4 Offline Process Online process Document Decision * Given the current legislation, the registrant has also the possibility to request Finnish national Guarantees of Origin only from Fingrid in paper form. In that case the issuing request is submitted to Fingrid. According to agreement between Grexel and Fingrid, Fingrid only issues one type of Guarantee of Origin for given generated MWh: EECS or Paper. 1. The registrant requests issuance of Certificates. Request may be relating to a specific period consisting of one or several full calendar months or a request for continuous issuing. In case of continuous request, Grexel issues production monthly by one month and 10 business days after the production month. One EECS Scheme Certificate will be issued for each whole one MWh of qualifying energy output of the Production Device. Any identifiable residual kwh will be carried forward to the next issuing period. a. The issuing request can be sent to either Fingrid or Grexel (Annex 6). If the issuing request is sent to Grexel, the registrant authorizes Grexel to request issuance from Fingrid on behalf of the registrant. 2. Fingrid being the measurement body and Competent Authority for Finnish GOs collects production data and sends it to Grexel. 3. If the request is for multi-fuel PD or pumped hydro PD (a), or GOs relating to technology (b) (cogeneration GOs) a. The registrant must fill in production declaration in the CMO.grexel registry b. The registrant must deliver a cogeneration declaration. The format of cogeneration declaration is AIB Cogeneration model Excel workbook found at The model is amended time to time by the AIB. 4. Grexel issues EECS Certificates and deposits them to the Account nominated by the registrant in the CMO.grexel registry. a. One EECS Scheme Certificate will be issued for each whole one MWh of qualifying energy output of the Production Device. Any identifiable residual kwh will be carried forward to the next issuing period. Issuing takes place on 10 th of every month or the next business day. At that time all properly validated and authorized issuing requests are processed. Deadline for delivering issuing request is 5 Finnish business days before issuing date. Issuing can be performed after the closure of the balance settlement of the production Grexel Systems Oy 2012 Page 16 of 29

17 E.2 Form month. Normally balance settlement is closed end of the month following the production moth. Measurement: Only Production Devices that are equipped with metering equipment that complies with the relevant regulations for the trading of generation energy shall be registered. The metering equipment may measure on a scalar basis (meter advance only) or on a period basis (energy measured in units of time) according to the regulations. Fingrid shall issue the Finnish GOs for RES-E and cogeneration for net production according to EU DIRECTIVE 2001/77/EC and Act on Verification and Notification of Origin of Electricity (1129/2003). For the avoidance of doubt, the relevant regulations are the versions of the following agreements and codes presently in force at the time: Agreement between Production Device Owner and Fingrid concerning issuing Finnish GoO for RES-E Electricity Market Act (386/1995) Finnish Energy Industries Recommendation for measuring energy output of Production Device connected to Grid ( ) Energy storage (including pumped storage): Finnish national GOs and other EECS Certificates are always awarded for nett electricity production. The handling of auxiliary consumption as well as energy storage follows the process described in section E.1.2. Combustion fuels (e.g. biomass): Where the Production Device has multiple energy sources, the Production Device Registrant will have to manually report in detail on input factors in the CMO.grexel registry. Request for issuing can be made by sending a formal request to Fingrid or Grexel (Annex 6) If a production declaration is needed, the registrant must fill in production declaration within the CMO.grexel registry If the issuing request is made for cogeneration GOs, the issuing request must be accompanied with a cogeneration declaration in the form of AIB cogeneration model. E.3 Transferring EECS Certificates The Account Holder can get secure electronic access to the Account to make transfers of Certificates to another Account in the same EECS Registration Database or to another EECS Registration Database for EECS Certificates in another Domain through the website CMO.grexel.com. Only persons duly authorized by the Account Holder may request the transfer of EECS Certificates out of that Account Holder s Transferables Account. Authorized persons must be identified on the Account application form (Annexed to STC). Authorized persons can also later be added by the root user(s) of that Account Holder. Only EECS certificates can be transferred to the EECS Registration Database. EECS Products, other than those mentioned in Section B.2, can be transferred into the CMO.grexel registry. Grexel Systems Oy 2012 Page 17 of 29

18 The initiation of transfers is done in the CMO.grexel registry by the selling Account Holder. The transfer of Certificates and the confirmation of that transfer are automated. After the Account Holder has initiated the transfer, the system instantly displays a message of whether or not the initiation has been successful. In transfers between two accounts in registries operated by Grexel, the certificates are automatically transferred to the receiving account if the initiation of the transfer is successful. If the initiation of the transfer is not successful, the certificates do not leave the Account of the original Account Holder. In transfers between Accounts in two different registries, the success of the transfer is subject to the verification process of the AIB HUB and the receiving registry. If the transfer is not successful, the certificates are returned to the Account of the original Account Holder. In transfers between Accounts in two different registries, Grexel will cooperate with other Members of the EECS scheme to amend its own, or the other Members Account Holder information. Administration of malfunctions, corrections and errors. The issuing body Grexel has the right to perform corrective actions such as withdrawal or transfer of Certificates in the registry where Certificates have been erroneously issued or transferred. Where it is impossible to transfer for technical reasons, this can be overcome by cancelling Certificates for use in another domain, with the agreement of the importing issuing body. Any such cancellations are notified to the importing issuing body and the AIB Secretariat. E.4 End of life of EECS Certificates Account Holders possessing Certificates in the CMO.grexel registry, can perform cancellations by executing the transaction in the registry. The Account Holder must specify the Certificates to be cancelled as well as the country of consumption, cancellation purpose, usage category, name, type and location of beneficiary and related consumption period. EECS domains to which a secure electronic transfer of certificates is possible are not included in the list of country of consumption, which prevents ex-domain cancellations from Finland to these domains. The cancellation of Certificates is automated. Certificates can only be cancelled once. Cancelled Certificates are removed from transferrables account by changing their status to cancelled so they do not appear in any Account of the registry after the Cancellation. The Account Holder performing the cancellation has full access to see the details of the cancellation, which are printable in CMO.grexel or they can order an official Cancellation Statement from Grexel. Having performed a cancellation, the Account Holder receives a confirmation of the success or failure of the cancellation instantly in the CMO.grexel registry. Expiry According to Act on Verification and Notification of Origin of Electricity (1129/2003), Guarantees of Origin do not expire in Finland. The same rule applies to all EECS Certificates. Grexel Systems Oy 2012 Page 18 of 29

19 Withdrawal Grexel may withdraw an EECS Certificate held in a Transferables Account on its EECS Registration Database at the request of the Account Holder of that Account, or otherwise in accordance with the provisions of the EECS scheme, thereby cancelling it. Forms: A cancellation statement can be printed out from the registry by the Account Holder organization which has performed the cancellation. An official paper version of the cancellations statement can also be ordered from Grexel (see example in Annex 7). E.5 Administration of corrections and errors In the event that it transpires that the data in any EECS Certificate is inaccurate (whether or not through an act or omission of the Registrant of the originating Production Device): a. Grexel shall (provided that such EECS Certificates are, at the time of such Withdrawal, in the Transferables Account of that Registrant) Withdraw those Certificates; and b. The Registrant shall pay Grexel the cost of securing the agreement of another Account Holder to the Withdrawal of EECS Certificates of the same type from that other Account Holder s Transferables Account, so that, as far as reasonably practicable, EECS Certificates are withdrawn with a volume and a financial value which make good the discrepancy. c. In case the Certificates are no longer in the Finnish domain, Grexel will cooperate with other Issuing Bodies to withdraw the erroneous Certificates. Grexel may also alter a EECS Certificates held in its EECS Registration Database so as to rectify an error which occurred prior to its transfer into the Account in which it is held at such time, provided: a. the Account Holder has agreed to such alteration; b. it is reasonably satisfied that any unjust enrichment of a EECS Scheme Participant as a consequence of such error has, to the extent reasonably practicable, been nullified; c. it is reasonably satisfied that the alteration itself does not give rise to undue enrichment of the Account Holder. F Audit of Production Devices F.1 On-site audits On-site audits of Production Device data can be deemed unnecessary if relevant registration data can be verified using other reliable sources, such as: Registration for the purpose of emission trading scheme Registration for Finnish government support scheme Registration for the purpose of license to connect to the grid or distribution network The Registrant, either as the owner or on behalf of the owner and operator of the Production Device, must permit Grexel, or a Production Registrar as its agent, to Grexel Systems Oy 2012 Page 19 of 29

20 access the Production Device or records associated with it, its energy output and sources of energy. Registrants must report any changes to standing data of a Production Device under D.2.5, but deviations from registered data are also sought in the Production Device audit. This is especially important regarding changes in ownership structures and metering. If a Production Device fails to pass the requirements of the audit or the registration information has changed significantly, Certificates will not be issued before corrective actions have been performed. F.2 Production Device registration re-check Relevant registration data is re-checked every 5 years. All Production Devices can also be audited at a random time. F.3 Production audits Production audits are performed on random basis. The Production Auditor will receive information about the issued EECS Certificates from Grexel and the registered information relating to the Production Device for the period being reviewed. The Production Auditor will compare the issued number of Certificates with data from other sources, such as: Confirmed used fuel Accounting statement for the purpose of Emission Trading System Verified report for the purpose of Feed-in Tariff In case of windmills, installed capacity and estimated full load hours The Production Auditor will report any discrepancies from the registered information to Grexel as soon as possible. Production Registrars are accredited by the Energy Market Authority. Production audits can be performed by Production Registrars, or other auditors accredited by Grexel. G Change Control (see EECS Rules, section L) G.1 Complaints and Disputes Grexel will endeavour to deal with complaints received as soon as possible and within a period of 20 business days. Treatment of the complaint and disputes will be made in accordance with the general rules of commercial law. G.2 Change requests An Account Holder may propose a modification to this ; Such a proposal will include a detailed description, including an exact specification of any proposed modification of this and be passed in writing to Grexel. On receipt of such a request, Grexel will: Respond to the request within 5 working days, describing the procedures to be followed, and estimating when a reply can be expected; Grexel Systems Oy 2012 Page 20 of 29

21 Consult with the other EECS Account Holders within Finland; Decide whether the request and its consequences are in its opinion reasonable; If the proposal leads to the modification of the or if it is otherwise seen important to disseminate, inform the EECS Account Holders within Finland the outcome of this decision. Grexel may make such modifications to this as are in its opinion necessary to the effective and efficient operation of the market. Any modifications to this are subject to approval by the AIB that such changes do not conflict with the Rules of the Association of Issuing Bodies (AIB) for The European Energy Certification System. Implementation of modifications will be notified by to the Account Holder and will take effect on publication of the documentation on the website Grexel Systems Oy 2012 Page 21 of 29

22 Annex 1: Contacts List Competent Authority & Measurement Body Fingrid Oyj, Pentti Säynätjoki, P.O. Box 530, FI Helsinkin Finland, , Authorised Issuing Body Grexel, Marko Lehtovaara, Hermannin Rantatie 8 FI Helsinki Finland, , marko.lehtovaara@grexel.com, Central Monitoring Office (CMO) Grexel, Marika Timlin, Hermannin Rantatie 8 FI Helsinki Finland, , marika.timlin@grexel.com, Registry support Grexel, Marika Timlin, Hermannin Rantatie 8 FI Helsinki Finland, , marika.timlin@grexel.com, Production Registrars See list at ICS:EKOENERGY Scheme Operator The Finnish Association for Nature Conservation (FANC). Contact: Steven Vanholme, , steven.vanholme@sll.fi Measurement Body Fingrid Oyj, Pentti Säynätjoki, P.O. Box 530, FI Helsinkin Finland, , pentti.sayntajoki@fingrid.fi, Grexel Systems Oy 2012 Page 22 of 29

23 Annex 2: Standard Terms And Conditions See separate document: Standard Terms and Conditions. Annex 3: Know-Your-Customer Questionnaire See separate document: KnowYourCustomerGrexel Annex 4: Production Device Registration Form Registrant of the Production Device Production Device Registration form Name: Street: Postal Code: City: Country: Contact Person: Phone: Fax: Ownership share: Operator of Production Device Name: Street: Postal Code: City: Contact Person: Phone: Fax: Country: Registrar of the Production Device Name: Street: Postal Code: Contact Person: Phone: Fax: City: Country: Owner of the Production Device (if not registrant) Name: Street: Postal Code: Contact Person: Phone: Fax: Grexel Systems Oy 2012 Page 23 of 29

24 City: Country: Ownership share: Owner of the Production Device Name: Street: Postal Code: City: Country: Contact Person: Phone: Fax: Ownership share: Production Device information Name: Street: Postal Code: GSRN: Installed Capacity, MW Date of Commissioning: City: Country: Finland Issuing Body: Grexel Finland Latitude Coordinate Code Longitude Radioactive waste produced Meter Information Production Device is connected directly to the grid: Grid Area Gross/Net measurement Meter Code: [filled by Fingrid] Grid Reference: [filled by Fingrid] Calculation Formula Metering Description Fuels (codes according to AIB EECS Fact Sheet 5) Burning value, GJ/ton Technology Public Support Schemes Grexel Systems Oy 2012 Page 24 of 29

25 EECS schemes GO ICS:RECS Trading Scheme Trading Scheme Further information provided with this registration form: Auditor notes: By undersigning this registration form the Registrant also reaffirms the relevant requirements of the including: The Registrant is either the owner of the Production Device or is authorised by the owner of the Production Device, which is the object of this registration form to so register the Production Device for one or several EECS Schemes in Finland. The electrical energy produced by the Production Device is produced according to the Qualifying Criteria set out in the respective Section of the for any of the relevant EECS Schemes in Finland and will in addition be supported by such other criteria as may be from time to time prescribed by the scheme authority responsible for the Domain within which the Production Device lies. The Registrant will claim Certificates only for electricity from qualifying fuel sources which has not been sold or otherwise consumed as electricity associated with one or several attributes of electricity generation covered by any of the EECS Schemes without the use of the corresponding EECS Certificates (including such consumption by autoproducers and electricity for which other evidence of the production of electricity from qualifying energy sources has been issued). The information given in this registration form is truthful and exhaustive. Any planned changes concerning the information given in this registration form will be announced in advance to the Issuing Body. Any unplanned changes will be announced to the Issuing Body at the first possible occasion. The owner of the Production Device and the Registrant as his agent accept the possibility of unannounced visits to their own control and auditing premises and/or the premises of the Production Device, as prescribed in the for EECS Certificates in Finland Registrant Production Registrar Place: Date: Place: Date: Signature Signature Name in print: Name in print: Title: Title: Grexel Systems Oy 2012 Page 25 of 29

26 Annex 5: Power of Attorney Template Power of Attorney To whom it may concern, In relation to the EECS Certificates in Domain Finland. We [Name of the owner of the Production Device], [Address and business ID of the owner] hereby give [Name of the empowered organization] [Address and business ID of the empowered organization] the Power of Attorney to Act on our behalf as the registrant of perform any subsequent work and activity needed for registration of request the issuance of EECS Certificates for deliver production declarations for receive issued EECS Certificates on our behalf for be the sole point of contact for Grexel regarding Mark X if true The Production Device [Name, Address, and GSRN (when available) of the Production Device] This Power of Attorney is valid from day Month year Until further notice by [Name of the owner] [Name of the owner] Place : Date : (Signature) Name : Position : Grexel Systems Oy 2012 Page 26 of 29

27 Annex 6: Issuing Request Request to Issue EECS Certificates Name of Account Holder Name of Production GSRN of Production Monthly Device Device issuing X Start month Model PD X Member code (30X ) Issuing for specific period Stop monthly issuing X Model PD By signing this form I confirm and accept that: I have right to request issuing specified above On our behalf, Grexel has the right to request the issuance of Finnish national Guarantees of Origin and to deliver meter readings specified above from Fingrid Standard issuing fees of Fingrid and Grexel will be charged The information in appended declaration is correct may be subject to audit before or after issuing Date Signature Name Position Appendices Cogeneration Declaration (print-out from AIB cogeneration model) Fuel declaration License to issue ICS:EKOENERGY from FANC Grexel Systems Oy 2012 Page 27 of 29

28 Annex 7: Model Cancellation Statement Cancellation Statement With this Cancellation Statement the indicated Certificates are no longer tradable. Onward sale of this Cancellation Statement is prohibited. Transaction Type: Cancel Transaction Date: :38:54 Transaction Number: Transaction status: Completed From To Name of Account Holder: Power Company Limited Name of Beneficiary: Beneficiary Limited Account: FI-Power Company Limited Cancellation Purpose: Electricity disclosure Domain: Finland Consumption Period: to Street: Kukkakatu 8 Country of Consumption: Finland Postal Code and City: Helsinki Location of Beneficiary: Example Road 4, Helsinki Country: Finland Usage Category: Disclosure Type of Beneficiar y: Energy supplier Total GO: Total MWh: Certificate Number (From - To) Volume Domain Fuel, Technology Issuing Date Productio n Period Production Device (GSRN, installed capacity, name) Trading scheme s Support Schemes To Finland F , T To MW Production Device 1 GO Investment and production support Grexel Systems Oy 2012 Page 28 of 29