BritNed Access Rule changes in conjunction with the Harmonised Allocation Rules
1
This overview contains a summary of the main proposed changes to the BritNed Access Rules as set out in the
consultation draft. This is not a substitute for reading the consultation draft in full which market participants
are urged to refer to as there are various other changes to the Access Rules not referred to in this summary.
Introduction
The Dutch and British electricity transmission systems are connected by a 1000MW HVDC link
between Maasvlakte in the Netherlands and the Isle of Grain in England known as the BritNed
Interconnector (BritNed). BritNed is a joint venture between National Grid Interconnector Holdings
Limited and NLink International BV2 and supports electricity trading in both the GB to Netherlands
and Netherlands to GB directions.
The BritNed Access Rules govern the allocation of rights to use the interconnector by explicit auction
across all timescales, as well as setting out more general terms of use.
The Network Code on Forward Capacity Allocation (FCA) provides for the establishment of a single
platform for the allocation of long term transmission rights on a harmonised basis throughout the
EU. The Agency for the Cooperation of Energy Regulators (ACER) has given the European Network of
Transmission System Operators (ENTSO-E) the task of developing the harmonised Allocation Rules
for Forward Capacity Allocation (HARs) required by the FCA for early adoption. Transmission System
Operators (TSOs) including BritNed have been instrumental in drafting the HARs.
As the HARs document covers the allocation of long term rights only, the allocation of Daily and
Intraday rights and the nominations processes are to remain within the BritNed Access Rules.
BritNed has drafted a new Participation Agreement, based on the pro forma developed by ENTSO-E,
which will give contractual effect to both the HARs and the BritNed Access Rules, it is available as
part of this consultation pack. BritNed proposes this new Participation Agreement will replace the
previous BritNed Participant Agreement.
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2
http://www.britned.com/~/media/BritNed/Regulatory/BritNed%20Access%20Rules%2018122014.pdf?la=en
The ultimate parent undertaking of National Grid Interconnector Holdings Limited is National Grid plc which is incorporated in Great
Britain, and the ultimate parent undertaking of NLink International BV is TenneT Holdings BV which is incorporated in The Netherlands.
The proposed contract structure is shown in the following diagram:
BRITNED PARTICIPATION AGREEMENT
HARMONISED ACCESS RULES (HARs)
(Long Term Capacity Allocation for all
participating borders)
BRITNED ACCESS RULES
Day Ahead and Intraday allocation,
and use of capacity (all timescales).
GB-NL ANNEX
Containing BritNed
variations from HARs
To ensure that the BritNed Access Rules dovetail with the HARs, BritNed has reviewed the current
BritNed Access Rules3 to determine the changes required. A draft revised set of BritNed Access Rules
has consequently been produced. The reason for the changes within this Consultation Draft is to
reflect the new arrangements whereby long term capacity allocation is now to be administered
under the HARs and not as previously under the BritNed Access Rules.
Main amendments to the Access Rules
In the interests of conforming the two sets of rules as far as possible, we are proposing to adopt a
number of key terms defined in the HARs for the BritNed Access Rules e.g. Registered Participant in
place of Participant, Auction Tool in place of Kingdom, Allocation Platform in place of BritNed,
Collateral in place of Credit Cover, Rights Document in place of ICEs. We are also proposing that a
number of the ‘boilerplate’ clauses in the HARs should be imported by cross reference into the
Access Rules. Apart from these conforming changes, the predominant changes in the new version of
the BritNed Access Rules are in relation to the removal of all the provisions which are specific to long
term capacity auctions. Adoption of the HARs, in advance of the FCA coming into force is purely
voluntary and for the purposes of moving the long term allocation processes from the current Access
Rules into the HARs. It is not therefore the intention, during this consultation, to amend the current
BritNed firmness arrangements.
3
http://www.britned.com/~/media/BritNed/Regulatory/BritNed%20Access%20Rules%2018122014.pdf?la=en
Henceforth the following provisions of the BritNed Access Rules are now in the HARs:
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


Rule C2: Medium Term Auctions;
Rule D3: Secondary Market;
Rule D6: ‘Use-it-or-Sell-It’ (UIOSI);
Rule D9.4/5/7: Curtailment Reconciliation: Provisions for Curtailment Reconciliation of
Medium Term Rights and Medium Term Nominations.
Sch. 4.3.1-4.3.10: ‘Medium term business process’.
Other changes to the BritNed Access Rules are in relation to the adoption of the HARs principles.
The provisions of the BritNed Access Rules which have been amended for this reason include:

Rule A2.1/2.2 and A8: ‘BritNed Participant Agreement’ and Schedule 2 and 3
‘BritNed Participation Agreement’: Participation requirements are now within the HARs and
the BritNed Participant Agreement is to be replaced with the Participation Agreement;

Rule B1 and B2: ‘Invoicing and Payment’: In particular Invoicing (B2.1) is to be undertaken on
the same basis as described in the HARs;

Rule B7: Payment Security: The Payment Security is to be undertaken on the same basis as
described in the HARs and using the same collateral. There are some consequential changes
such as, for example, the deletion of ‘Letter of Credit’ from Sch.1 as the term is no longer
used;

Rule C1.2: Types of Auctions: Now reflects HARs provisions regarding the details of results
that are to be published;

Rule C1.1 and C2: ‘Medium term auctions’ interpreted as long term within the HARs
terminology are now within HARs, thus Sch. 6 is not used.

Rule C6.4(d): Allocation: The allocation of capacity where several bids (at the marginal price)
cannot be accepted in full for the total requested capacity has been amended to reflect the
allocation provisions of the HARs.

Rule D4: ‘Resale’: Not used as it relates to Medium Term Auctions. The term has also been
deleted from Sch. 1.
Regulatory Requirements
BritNed’s Interconnector Licence (Standard Licence Condition 11A) requires it to carry out an annual
review of its Access Rules and this consultation constitutes BritNed’s review for 2015. BritNed
considers that the proposed Access Rules amendments will satisfy the ‘relevant access rules
objectives’ (in particular the requirement to be ‘compliant with Regulation 2009/714/EC (on crossborder exchanges) and any relevant legally binding decision of the Commission’), by anticipating the
HARs elements of the FCA.
Consultation Pack and associated Rules change process
This consultation pack contains the following documents; they serve to support stakeholders
through this consultation process:
1. The covering letter;
2. This overview document which contains a summary of the main changes and the
consultation questions;
3. The proposed “BritNed Access Rules” Consultation Draft document;
4. BritNed Participation Agreement
5. (for information) the draft BritNed Border Specific Annex.
The above suite of consultation documents is available from BritNed’s website: www.britned.com
For your reference also is a link to the ENTSO-E site for the Harmonised Access Rules document and
associated consultation material.
https://consultations.entsoe.eu/markets/fca-harmonisation-of-allocation-rules/consult_view
Questions list
Document
Question
Q1
BritNed
Access Rules
What are your views on the new allocation methodology for the case where
several bids cannot be accepted in full for the total requested capacity, as
proposed in the HARs (Article 35) and the BritNed Access Rules (Rule C6.4)?
Q2
BritNed
Access Rules
As the “Return of capacity” functionality for Intraday products has little value
to participants we intend to drop this functionality (which is rarely (if ever)
used and its removal will shorten the document), although, for the avoidance
of doubt, the Secondary market (return and resale) for long term products will
stay as-is.
Could you please give your views on the removal of this functionality,
contained in Rule D5 of the BritNed Access Rules?
Q3
BritNed
Access Rules
HARs
Are you satisfied with the provisions of the HARs and BritNed Access Rules
regarding Credit Limit calculation taking into account the changes in Rule B.7,
in particular the removal of Rule B7.5.
Q4
HARs
Are you satisfied with the current range of BritNed Long-Term products?
Would you like to add any product types? If yes, which products?
Q5
HARs
Are you satisfied with the publication of the BritNed products list on the
BritNed website4 instead of publishing it annexed to the HARs?
Q6
BritNed
Access Rules
and Annex
Considering that this project is for early implementation of Harmonised
Allocation Rules ahead of FCA obligation, BritNed is of the opinion that the
previously approved Rules associated with Curtailment and associated
compensations continue to be appropriate. Do you consider that there are any
other changing external factors that necessarily trigger a need to amend
Curtailment Rules ahead of FCA coming into force?
Q6
HARs
Are you satisfied with the HARs timescales for final results availability (Article
37 (Contestation of Auction Results) of the HARs), whereby at the end of the
fourth working day after publication of the provisional Auction results, the
provisional Auction results shall be considered as final and binding”?
Next steps: indicative process and timelines
18 March – ENTSO-E planning to hold a Stakeholder workshop.
2 April – consultation closes.
April-June – review of market participants responses.
End-June expected submission to NRAs for approval.
By end-Sept NRA approvals.
2016 adoption, timescales for BritNed dependent on systems development programme.
4
http://www.britned.com/Participants%20portal/Explicit%20auctions