INTRA-DAY TRADING
Development of Modification(s)
1st February 2011
Introduction
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During 2010, the RAs instigated the development of proposals in respect of IntraDay Trading in the SEM.
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Through the Modifications Committee Working Groups, the High Level Design
for Intra-Day Trading was developed.
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The High Level Design was recommended for approval by the Modifications
Committee in Meeting 32.
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In November 2010, the SEM Committee agreed that SEMO and the TSOs
should continue to develop the design in conjunction with the CMS and
Operational Scheduler vendor.
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There is currently no legal drafting to reflect the High Level Design.
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This document discusses options for the development of the required
Modification or Modifications during 2011.
How will the Modifications be developed?
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SEMO will be developing the Modifications to align with the High Level Design
(developed by SEMO on behalf of the Working Group) and the requirements as
provided to the CMS vendor.
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This is in line with the RA decision paper (SEMO-10-011):
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SEMO intends to develop a “Plain English” document which will accompany
each Modification Proposal.
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The “Plain English” document associated with each Modification Proposal will:
• Detail the proposed changes in a more descriptive manner
• Align with legal drafting
• Promote understanding of the changes (noting that the legal drafting is what
will ultimately be considered by the Modifications Committee)
Market changes required for Intra-Day Trading
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The introduction of intra-day trading in the SEM represents a major change in the
market design. As a result, there will be a number of changes that will impact on
the Trading and Settlement Code (“Code”), including:
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Bidding to multiple Gate Windows (EA1, EA2 and WD1) for the relevant Trading Day.
Restriction of Interconnector Unit bidding in the EA1 Gate Window to Capacity Holders.
Reallocation of unused Interconnector Capacity to any Interconnector Unit (with no requirement to
be a Capacity Holder) in EA2 and WD1 MSP Software Runs.
Different lengths of Trading Window for each Ex-Ante MSP Software Run:
• EA1: entire Trading Day
• EA2: entire Trading Day
• WD1: second portion of the Trading Day
Fixing of Interconnector Unit capacity allocations from EA1 MSP Software Run (MIUNs) in the EA2
and WD1 MSP Software Runs.
Fixing of Interconnector Unit capacity allocations from EA1 MSP Software Run (MIUNs) in the EA2
and WD1 MSP Software Runs.
Changes to Credit Cover arrangements to ensure that the SEM remains as collateralised as
possible.
Key T&SC Changes
(initial SEMO assessment which needs to be further refined)
Code
Section
Description
2
Changes to Registration Processes, particularly in relation to the registration of Interconnector Units.
3
Clarification of treatment of Default Data, MSP Software run contingencies and Data Contingencies.
4
Explanation of input data (COD, TOD, EDP data) for each Gate Window, description of Trading Windows/Optimisation Time Horizons.
5
Clarification of the data required and utilised within each Gate Window and MSP Software Run.
6
Clarification of treatment of Trading Day Exchange Rate, Data and Settlement Queries and values for Administered Settlement.
App E
Clarification of publications following each MSP Software Run or Gate Window Closure.
App H
Changes to Registration Processes, particularly in relation to the registration of Interconnector Units.
App I
Changes to clarify the Offer Data requirements for each Ex-Ante Gate Window.
App J
Revision of SMO and TSO Data Transactions (particularly in the context of Technical Offer Data).
App K
Changes to clarify SMO and TSO Data Transactions (new and existing).
App N
Optimisation constraints for each MSP Software Run (e.g. Active Capacity Holdings in EA1, Superposition for EA2 and WD1).
Glossary
New and amended Glossary definitions.
AP1
Changes to Registration processes.
AP2
Clarification of treatment of Interconnector Units in multiple Gate Windows and Trading Windows.
AP3
Clarification of testing in the Certification Environment of bid/offer data for each relevant Gate Window.
AP4
Changes to reflect additional Gate Windows and Trading Windows, along with COD and TOD treatment.
AP6
Detail of reports published following each Ex-Ante MSP Software Run or Gate Window.
AP7
Explanation of agreed run contingencies (run cancellation etc).
AP9
Significant changes to reflect proposed Credit Cover arrangements for Interconnector Units.
AP13
Possible changes to criteria for Data and Settlement Queries.
Option 1: Single Modification
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The changes to the Code to account for Intra-Day Trading are wideranging.
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Development, presentation and approval of a single Modification would
increase the risks of delay to the approval of the legal drafting:
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It would delay when the Modifications Committee can consider the proposed text.
It would be difficult to consider as a whole in a Modifications Committee meeting.
Option 2: Functional Grouping
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Functional grouping would allow a consistent set of changes to be
considered separately (example grouping below – to be refined following further analysis) .
Easier for SEMO to develop and the Modifications Committee/RAs to
consider.
Group Name
Sections Included
Registration and Submission
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Section 2
Section 5 registration-related
Appendix H
Appendix K registration-related transaction
Appendix E registration-related publications
AP1
AP6 registration-related
Key Glossary definitions
Bids, Data Transactions and MSP
Software
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Section 4 (submission and transactions)
Section 5 (Interconnectors & bids/Data Transactions/MSP Software)
AP4 bids
Appendix K Data Transactions
Appendix I
Appendix E scheduling and pricing-related publications
Settlement and Credit
Management
 Section 4 (settlement)
 Section 6
 Appendix E, CRM or settlement-related publications
Note: a full analysis has not been completed, hence further changes may be required.
Option 3: Sectional Grouping
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Sectional grouping would allow each section/AP/Appendix to be
addressed separately.
Would require each section to be revisited once associated changes are
made in other sections.
More difficult for the Modifications Committee/RAs to consider and
approve, as associated changes would not be available to consider at the
same time.
Group Name
Sections Included
Main Sections
Sections 2, 3, 4, 5 and 6
Appendices
Appendices H, I, J, K, N
Agreed Procedures
Agreed Procedure 1, 2, 3, 4, 5, 6, 7, 9, 10, 13 and 14
Note: a full analysis has not been completed, hence further changes may be required.
SEMO Recommendation: Option 2
(Functional Grouping)
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SEMO recommends that a functional grouping approach is adopted.
Current Committee Timelines
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Meeting 33: 01 February (Dublin)
Meeting 34: 05 April (Belfast)
Meeting 35: 09 June (Dublin)
Meeting 36: 09 August (Belfast)
Meeting 37: 11 October (Dublin)
Meeting 38: 06 December (Belfast)
SEMO intends to submit
Modifications from May 2011
More meetings are needed
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It is assumed that the Intra-Day Trading Modification(s) need(s) to be
approved by the end of 2011/very early 2012.
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SEMO is concerned that the Modifications Committee meeting schedule will
be insufficient to allow Modifications Proposals to be considered and
approved to meet the intended timetable.
Proposal
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SEMO proposes that four additional meetings are scheduled, in accordance
with AP12:
• Commence planning, analysis and drafting could begin from mid
February 2011
Current Committee Timelines
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Additional Meeting 1: 10 May (Belfast)
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Meeting 35: 09 June (Dublin)
Additional Meeting 2: 05 July (Dublin)
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Meeting 36: 09 August (Belfast)
Additional Meeting 3: 20 September (Belfast)
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Meeting 37: 11 October (Dublin)
Additional Meeting 4: 10 November (Dublin)
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Meeting 38: 06 December (Belfast)
Note: exact grouping and number of Modification Proposal(s) will be developed by SEMO