Summary of proposed changes to the Access Rules
We have set out below a summary of the main changes we propose to make in the BritNed Access
Rules. We welcome your responses to those changes listed in this summary. Please send your
responses to [email protected].
1. BritNed proposes to hold at least one Participants Forum a year instead of two. Please be
assured we will continue to circulate information on a regular basis and will consider holding
additional forums if necessary. The change can be found under Article A6.1.
2. A renewed Letter of Credit has always been Irrevocable but this has never been clarified in
the Access Rules therefore we propose to give clarity under Article B7.15.
3. For the sake of clarity, we wish to make clear in the Financial Section of the Access Rules that
all letters of credit must be from a bank with no less than an ‘A’ Credit rating from Standard
and Poor’s Corporation or ‘A2’ from Moody’s Investors Service Inc. This requirement is
already covered in Schedule 1 Definitions but added to B7.19 for clarification purposes.
4. The current Access Rules mentions the initial Auction Specifications will be published at least
5 days before the start date. BritNed intends to change this to two days. The change is
proposed in Article C2.4.1.
5. We wish to give clarification but not change the intent that if a Participant requests that it
wishes to place its medium term capacity into an auction as a resale BritNed has the right to
set the reserve price for the auction. If the Resale capacity does not clear in the Auction, the
Unit holder will lose the right to such Interconnector Capacity. This change can be found
under Article D4.11.
6. Implicit Transaction Clearing Fee
BritNed proposes to recover from our participants any Implicit transaction and/or clearing
fees imposed upon us.
BritNed is intending to recover such fees generating a minimum spread which will cover the
operational costs related to the implicit allocations ensuring that we do not flow energy
across the interconnector at a financial loss.
We make this proposal within Article D6.3 (e), Schedule 7 and the new definition of “Implicit
Auction Reserve Price”.
7. Ramping cost recovery
BritNed proposes to recover ramping imbalance costs resulting from the implicit
Nominations into the implicit allocation process as a minimum allocation price.
BritNed is of the opinion that this is the best way for a DC link to reflect these costs given the
proposed NWE ramping restriction functionality.
The proposed wording is set out under Article D6.3(e), B2.1(g), Schedule 7 and the new
definition “Ramping Reserve Price”.
8. DC Loss Factor
We can confirm we have no intention to change the DC Loss Factor application for implicit
auctions.
9. Curtailment
In the event of there being a Capacity Shortage (following the curtailment of the BritNed
Interconnector) BritNed curtails the Medium Term, Explicit Daily and Intraday Nominations
on a pro-rota basis. BritNed will not curtail Implicit Nominations in such an event. This
process shall continue but after reviewing the Access Rules we have proposed changes to
provide further clarity. We propose an amendment under Article D8.1 and D9.4.
10. Caps on Compensation
BritNed can confirm that it does not propose to change the current caps on compensation
set out under Article D9.5.
As we are holding the review through this Consultation process Article E4.13 becomes
redundant and can therefore be removed.