Moyle EWIC I-SEM Interconnectors Project Financial Transmission Rights Auction: Initial Trial Report VERSION: 1.0 STATUS: Final for Publication DATE: 29 th SEPTEMBER 2017
Contents Introduction... 3 Objectives and Commentary... 3 Participation... 4 Functional Scope Initial Trial and Formal Trial... 4 Scenarios and Results... 7 Queries, Feedback, and Lessons Learned... 11 Credit Limit calculations... 11 System issues... 12 Login... 12 Usability... 13 Queries outside of the initial trial... 13 Other... 14 Next Steps... 15 Actions from initial trial phase... 15 Document control Version Date Author Description of changes v0.5 21.09.2017 Michael Carrington Draft for external review v1.0 29.09.2017 Michael Carrington Report for publication References JAO FAQ document: JAO Resource Center webpage >> select FAQ from the menu JAO Technical information: JAO Resource Center webpage >> select ecat New Auction Tool Moyle & EWIC interconnectors project page >> Market Trial section All TSO proposed Harmonised Allocation Rules (HAR) and supporting document Ireland-UK TSO proposed HAR Annex Page 2 of 15
Introduction An initial trial of the I-SEM FTR Market was held in August/September 2017. This document is an exit report from the initial trial and covers the following topics: Initial trial objectives and commentary on these Participation in the initial trial Functional scope of the initial trial and the proposed scope of the formal FTR Market Trial Initial trial scenarios and results Queries, feedback, and lessons learned Details on next steps to implement the lessons learned are also provided. Objectives and Commentary The objective of the initial trial was to facilitate an early sight of the JAO IT systems so that participants could assess and validate their requirements to interact with the JAO ecat platform. It was assumed participant users were familiar with the auction process and auction systems, typically a user of the current Auction Management Platform or JAO systems. The initial trial provided an opportunity to gain familiarity with the ecat system and get some of the typical trial teething issues out of the way at this early stage. It has also helped identify areas that require extra focus in terms of training delivery, preparation for the formal FTR Market Trial, and test scenarios to include in the formal trial. Participant feedback was a key element of the initial trial. Based on this an additional scenario was added to ensure that the core trial functionality was available to all. There were also scope changes to demonstrate the information on JAO s public website, including bid curves and anonymised bids, using data generated during the trial. The range of auction knowledge among the initial trial participants was quite diverse. Different users were exercising functionality in different parts of the system and a focus area for many was the calculation of credit limits in the system. Learnings for this are documented later. Some users were new to auction systems. As the scenarios were targeted at experienced users of similar systems it was decided to offer a shared desktop and Q&A session to show the ecat and JAO website functionality and discuss how these compare with what will be on offer in relation to the Moyle and EWIC interconnectors. This has also highlighted areas to focus on in future training. The ecat system for the initial trial was configured to utilise the France-Belgium border (BE-FR and FR- BE). This is an FTR border already active for current JAO customers and offered a solid platform on which to demonstrate the current functionality. It also meant that JAO operational staff provided support as they do to existing participants on the live environment. There were some systems issues encountered that were quickly escalated to the ecat system developer for resolution. Overall we consider this a very successful exercise in informing where we are, helping identifying areas for all parties in the FTR market to focus on, and ultimately progress required to be ready for the formal trial in January/February 2018. Page 3 of 15
Participation There were 44 enrolled users from 17 companies for the Initial trial. This included 100% participation from traditional/utility/hedging participants in Moyle and EWIC auctions. All enrolments after the deadline were also facilitated. 13 users were highly engaged in the scenarios and the daily follow-up calls. This helped to highlight common concerns during the trial. It was noted by the JAO support team that the queries and bidding patterns demonstrated a very detailed level of engagement by a number of participants. These users appeared familiar with the auction rules and checking specific aspects of the ecat implementation. The credit limit checks were the biggest focus of this as shown in the Queries and Feedback section. Functional Scope Initial Trial and Formal Trial The table below outlines the functionality covered in the initial trial and provides details of the additional functionality that is planned as part of the formal FTR Market Trial in January/February 2018. Functionality Initial Trial 1 Formal Trial Comment Interconnector/border: France-Belgium (FR-BE, BE-FR) EWIC (IE-GB, GB-IE) Moyle (NI-GB, GB-NI) Moyle and EWIC borders will be added to the JAO systems. Auction Calendar Web UI (ecat) view Public website Future auctions can be seen in the ecat system, but the calendar view is part of JAO s public website. Auction set-up & Offered Capacity Web UI (ecat) view Public website Web services Capacity returns Maintenance periods Functionality to enter capacity returns noted later. 1 Key: Functionality included Functionality available in the initial trial that was not utilised tbd Functionality under consideration for the Formal FTR Market Trial Page 4 of 15
Functionality Initial Trial 1 Formal Trial Comment Auction Products/Timescale Yearly Calendar year Yearly SEM year (Oct-Sep) Half-yearly/Seasonal Quarterly Monthly Additional products being configured for Moyle and EWIC. The base product type will be offered at go-live, i.e. product covers a full CET/CEST calendar day. Bidding, incl. default bids Web UI (ecat) data entry Web UI cut & paste Bid converter/file upload Web services Web services will be utilised in the formal trial with interface testing in advance. Auction Results Web UI (ecat) view Email of XML file Web services Bid Curve Anonymised bids Web services will be utilised in the formal trial with interface testing in advance Bid curve and anonymised bid data on the public site Scenario: Auction Cancellation Secondary Trading Capacity Transfer Capacity Return Capacity Rights Web UI (ecat) view D-2 Daily PA view D-2 Daily PA email PA: Programme Authorisations. These provide a daily summary of FTR rights holdings. They are available on D-2 by 13:00 CET/CEST. Scenario: Rights Curtailment Outage notification via the JAO public website message board, including RSS/ATOM feeds. Curtailment of rights in the ecat System. Page 5 of 15
Functionality Initial Trial 1 Formal Trial Comment Settlement Auctions and compensations Invoice status Additional settlement scenarios: Invoice payment (for resale) Curtailment compensation Day-ahead fallback 2 Regulatory Reporting Transparency REMIT tbd tbd tbd tbd Sample files available will be included with the final initial trial report Linked with Rights Curtailment 3 Alternate reference price 4 This is not part of the participant trial. An FAQ is provided on this reporting and testing will be completed outside of trials Interactive test scenarios are used to exercise the user/system interface elements of the ecat system. Where possible, our preference is to demonstrate the outputs from the system on the ecat and/or JAO public website. In a limited number of cases scenarios may be simulated or provided as a scenario result. 2 Day-ahead fallback occurs when day-ahead market coupling isn t possible on the SEM-GB border. In this scenario the first SEM-GB intraday auction will be used to set the reference price, albeit this is at a ½ hour resolution. 3 Curtailment compensation varies depending on the curtailment reason. The scenarios will include the process in relation to the monthly compensation cap for network security curtailments. 4 See footnote 2 Page 6 of 15
Scenarios and Results The table below provides details on the test scenarios covered during the initial trial and the results. Date Test # Test Scenario Description 2017.8.29 1 Registration and connectivity Tests of correct registration of company, users, and connectivity to ecat Results this was to check that users had connected successfully Yearly auction test Simulation of 2018 Yearly auctions BE-FR yearly auction 1 results: Offered Capacity: 200 Credit calculation: X/N rule is 1/12 5 Requested Capacity: 772 Number of participants: 11 2017.8.30 2 Allocated Capacity: 200 Participants obtaining capacity: 5 1.30/MWh FR-BE yearly auction 1 results: Offered Capacity: 200 Credit calculation: X/N rule is 1/12 Requested Capacity: 539 Number of participants: 11 Allocated Capacity: 200 Participants obtaining capacity: 6 0.55/MWh 5 This identifies the number of months considered in the credit limit calculation refer to queries and feedback section for more details on this. Page 7 of 15
Date Test # Test Scenario Description Monthly auction test Simulation of January 2018 Monthly auctions BE-FR January auction results: Offered Capacity: 200 Requested Capacity: 600 Number of participants: 10 3 Allocated Capacity: 199 6 Participants obtaining capacity: 9 1.00/MWh FR-BE January auction results: Offered Capacity: 200 Requested Capacity: 464 Number of participants: 9 Allocated Capacity: 200 Participants obtaining capacity: 8 0.45/MWh 2017.8.31 Monthly auction with reduction periods + Return from Yearly auction Simulation of February 2018 Monthly auctions with reduction periods and return of capacity from the 2018 Yearly auctions BE-FR February auction results: Offered Capacity: 247 7 Maintenance period 8 : 5.02.2018 9 Requested Capacity: 573 Number of participants: 8 4 Allocated Capacity: 247 Participants obtaining capacity: 7 0.45/MWh FR-BE February auction results: Offered Capacity: 210 10 Maintenance period: 5.02.2018 11 Requested Capacity: 437 Number of participants: 7 Allocated Capacity: 209 12 Participants obtaining capacity: 6 0.35/MWh 6 The allocated capacity is less than the offered capacity as the smallest increment for allocation is 1MW and pro-rata allocations for the bids at the marginal price are rounded down to the nearest whole number. This is the same approach used in current Moyle and EWIC auctions. 7 200MW of available capacity plus 47MW of capacity returns. 8 A maintenance period is a planned outage on an interconnector so no FTRs are granted for that period. 9 Capacity was returned for resale for the same period as which it was offered. It is an option to include/exclude the maintenance period when submitting capacity returns. 10 200MW of available capacity plus 10MW of capacity returns. 11 Capacity was returned for resale for the same period as which it was offered. 12 The allocated capacity is less than the offered capacity as the smallest increment for allocation is 1MW and pro-rata allocations for the bids at the marginal price are rounded down to the nearest whole number. Page 8 of 15
Date Test # Test Scenario Description Monthly auction with reduction periods + cancellation of Monthly auction Simulation of March 2018 Monthly auctions with reduction periods. The auctions will be cancelled and new Monthly auctions for March 2018 will be created. BE-FR March auction 1 results Cancelled: Offered Capacity: 222 13 Maintenance period: 20-21.03.2018 14 Requested Capacity: n/a Number of participants: 8 Allocated Capacity: n/a Participants obtaining capacity: n/a 2017.9.1 5 n/a FR-BE March auction 1 results Cancelled: Offered Capacity: 201 15 Maintenance period: 20-21.03.2018 16 Requested Capacity: n/a Number of participants: 4 Allocated Capacity: n/a Participants obtaining capacity: n/a n/a BE-FR March auction 2 results: Offered Capacity: 200; Maintenance period: 20-21.03.2018 Requested Capacity: 143, Number of participants: 6 Allocated Capacity: 98 17, Participants obtaining capacity: 5 0/MWh 18 FR-BE March auction 2 results: Offered Capacity: 200 Maintenance period: 20-21.03.2018 Requested Capacity: 291 Number of participants: 7 Allocated Capacity: 200 Participants obtaining capacity: 7 0.30/MWh 13 200MW of available capacity plus 22MW of capacity returns 14 Capacity was returned for resale for the same period as which it was offered. 15 200MW of available capacity plus 1MW of capacity returns 16 Capacity was returned for resale for the same period as which it was offered. 17 Bids for 45MW were excluded as part of credit limit verification. The total of remaining bids (98MW) was less than the Offered Capacity so the auction was not congested and the marginal price was zero 18 As the auction was not congested, the marginal price is zero Page 9 of 15
Date Test # Test Scenario Description n/a 2017.09.11 6 Yearly auction to allocate capacity for resales test Additional Scenario 1 Monthly auction with reduction periods + Return from Yearly auction BE-FR April auction 1 results: Simulation of April 2018 Monthly auctions with reduction periods and return of capacity from the 2018 Yearly auctions Offered Capacity: 226 19 Maintenance period: 7-9.04.2018 20 Requested Capacity: 355 Number of participants: 6 Allocated Capacity: 100 21 Participants obtaining capacity: 5 0/MWh 22 FR-BE April auction 1 results: Offered Capacity: 233 23 Maintenance period: 7-9.04.2018 24 Requested Capacity: 249 Number of participants: 7 Allocated Capacity: 233 Participants obtaining capacity: 6 0.35/MWh 2017.09.11 7 Additional Scenario 2 Monthly auction with reduction periods + Return from Yearly auction Results not applicable April 2018 Monthly BE-FR auction available for desktop session 19 200MW of available capacity plus 26MW of capacity returns. 20 Capacity was returned for resale for the same period as which it was offered. 21 Bids for 255MW were excluded as part of credit limit verification. The total of remaining bids (100MW) was less than the Offered Capacity so the auction was not congested and the marginal price was zero. 22 As the auction was not congested, the marginal price is zero. 23 200MW of available capacity plus 33MW of capacity returns. 24 Capacity was returned for resale for the same period as which it was offered. Page 10 of 15
Queries, Feedback, and Lessons Learned Credit Limit calculations 1. In the yearly auctions, is the credit requirement one month or two months? This is dependent on the timing of the auctions. When the auctions are close to the start of the period (e.g. in December for year starting January) then the credit requirement is two months. During the trial the annual auctions were taking place in July for a yearly product starting in January, so the credit requirement was one month. The JAO website wasn t part of the starting scope for the initial trial but provides the information on the credit rule. When auctions are created the credit requirement is shown in the auction description as X/N rule is 1/12 or X/N rule is 2/12 to indicate whether this is one or two months respectively of the 12 months for the annual product. The denominator would be 3 for quarterly auctions and 6 for seasonal auctions. This information can be seen by going to the JAO website - yearly auctions section and selecting Out area BE, In area FR, and 2017. The Auction descriptions box contains the X/N rule is 2/12 information. The JAO test website has the information from the auctions in the initial trial. By selecting Out area BE, In area FR, and 2018 the Auction Specification indicated that the X/N rule is 1/12. 2. When the credit limit is exceeded for an auction with multiple bids, how are bids excluded? Details on the credit limit verification are set out in the Harmonised Allocation Rules. Article 34 is relevant to this question. When bids are submitted the system will accept bids with a warning. At the closure of the bidding period, the platform checks that the bids do not exceed the credit limit. In a specific auction, the bids are excluded one-by-one starting with the lowest bid price until the remaining bids are within the required credit limit. 3. How are credit limits considered when the auctions for multiple borders close at the same time? When auctions for multiple borders close at the same time and the combined bids exceed the credit limit then both sets are excluded. Note that it s common for auctions in both directions on a border to close at the same time. 4. How are credit limits considered when the auctions for multiple borders close at the same time, and there multiple bids that can be excluded? In this case the system tries to exclude bids with the latest timestamp first. 5. Doesn t the credit calculation exclude maintenance periods? This is the case when there are no capacity returns. There was an example during the trial where there were capacity returns from an allocation without a maintenance period considered in addition to the capacity with the maintenance period. This resulted in a small of allocation of capacity for that period and the credit position being a little higher when taking this into account. These allocations are on a pro-rata basis and at the marginal price (as per HAR art. 35.6(b)). Page 11 of 15
System issues 6. Emails to data exchange email address (some users affected, resolved) Some users did not receive the system generated emails to their nominated data exchange email address. The issue was raised with the system developer and resolved for the additional scenario. It has been added as a preparation item for the Formal FTR Market Trial also. 7. Capacity return after a capacity transfer (all users affected, workaround used) After investigation by the system vendor it was determined that this was linked to the simulated time in the test environment and the relevant gates to facilitate this functionality had not been created. This was not one of the planned scenarios in the Initial Trial and we will consider these requirements in developing scenarios for the Formal FTR Market Trial. 8. Scenario 5 system gates not moving delayed some scenario steps (all users affected, resolved) The JAO operations team hit an issue with the trial environment configuration. The issue was raised with the system developer and quickly resolved. This resulted in a delay to some of the scenario 5 steps rather than a postponement. The required configuration has been added as a preparation item for the Formal FTR Market Trial. Login 9. There were a variety of system login issues including certificates, proxy settings, and password resets The support requirements for this varied on a company and sometimes user basis. The connectivity for the Formal FTR Market Trial will now be planned further in advance to ensure any issues can be resolved and participation in this is not impacted. 10. Digital certificate support and SEM/I-SEM certificates From a JAO perspective it is for participants to decide which certificates they wish to use with the JAO system. JAO publish a list of supported digital certificates and certification authorities. In parallel with the trial we successfully tested access to the system using a SEM digital certificate. As part of the next steps we will be testing I-SEM digital certificates and if successful add both SEM and I- SEM digital certificates to JAO s list of supported certification authorities. Page 12 of 15
Usability 11. Questions were raised regarding the usability of the ecat platform. Some details to consider in configuring and interacting with the system include: Users in the Initial Trial were configured to access multiple borders. This can be narrowed down to a shorter list as a registration configuration; For drop-down menus with multiple options you can typically jump to certain options, e.g. press letter Y to jump to Yearly; and ecat access using the Internet Explorer and Mozilla Firefox browser are supported. Other browsers are at your own risk. Queries outside of the initial trial 12. Engagement on registration is increasing. The JAO FAQ document will be updated with additional details on this. A Moyle & EWIC FAQ is also being considered. 13. The JAO FAQ on regulatory reporting under the Transparency and REMIT regulations will also be updated based on recent requests. The following is an updated position from EWIC, Moyle, and JAO: The Commission Delegated Regulation (EU) 2017/565 published earlier this year provides clarification in relation to Directive 2014/65/EU (MiFID II). The FTR Options allocation on the EWIC and Moyle interconnectors will be by Transmission System Operators as per article 8(c) of this (2017/565). The EWIC and Moyle allocations will be via the JAO platform and will be reported in line with the REMIT and Transparency regulations. JAO have already implemented FTR options on the France-Belgium border. Specific to REMIT, the clarification from JAO on their reporting is as follows: For the primary allocations JAO will report the TSO information to REMIT. This can be considered to fulfil the Market Participant reporting requirement also below are the details from REMIT art. 8: While overall responsibility lies with market participants, once the required information is received from a person or authority listed in points (b) to (f) of paragraph 4, the reporting obligation on the market participant in question shall be considered to be fulfilled. For secondary allocations the JAO reporting is only for the TSO side. Market Participants will need to do the relevant REMIT reporting for returns and transfers if they avail of these. Page 13 of 15
14. How are capacity curtailments notified? For Moyle and EWIC the capacity information is currently managed through the Auction Management Platform. This will continue to be used for NTC publication and data feeds to the Transparency platform. When there is a capacity curtailment (e.g. NTC reduction due to an outage) there will be a notification via the message board section of the JAO website and via email to registered participants. The JAO message board supports RSS and ATOM feeds also. This provides users with options to add alerts in their browser, via a mobile device, or to use other RSS/ATOM readers. Other 15. A number of late enrolments for the trial were received and all were facilitated 16. A few users reported that the interfaces and scenarios were not intuitive. It was assumed participant users were familiar with the auction process and auction systems, typically a user of the current Auction Management Platform or JAO systems. A walkthrough session covering the ecat system, the JAO website, and Moyle & EWIC rules was facilitated for users. 17. Details were requested on the XML files emailed from the system to the data exchange email address. Details on the email interactions and XML formats will be prepared and added to the FAQ documentation. 18. We received a confirmation that participants intend to do some web service interface testing with JAO s ecat system during the Formal FTR Market Trial. Web service connectivity and integration testing will be facilitated in advance of the Formal FTR Market Trial. Details will be provided in the next iteration of the FTR Auction: Trial and Participant Test Plan. Page 14 of 15
Next Steps The figure below gives an overview of the trial, testing, and training timeline. Phase 2017 Jul Aug Sept Oct Nov 2018 Dec Jan Feb Mar 1 Enrolment Initial Trial 2 3 Survey Additional Registration Support Training (dates tbd) Trial Platform go-live Figure 1: Trial, training, and testing timeline Actions from initial trial phase 1. Testing of SEM and I-SEM digital certificates: a. Testing of SEM certificate complete b. Testing of I-SEM certificates non-production certificate testing underway. WE expect to get an I-SEM production certificate by the end of October 2017 c. Addition of SEM and I-SEM certificates to JAO s certified issuing authorities 2. Update of JAO s FAQ documentation, incl. registration and REMIT. a. Provision of a Moyle and EWIC FAQ document if appropriate. 3. Development of Training survey to consider FTR market training, in addition to JAO systems training. 4. Development of FTR Auction trading information update building on lessons learned and feedback during the initial trial. 5. Increased liaison with software vendors and facilitation of web services testing. 6. System connectivity testing to be explicitly added to the plan to occur sufficiently in advance of formal trial start. Page 15 of 15