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8th version of REMIT Q+A document published

ACER have published the 8th version of their Questions and Answers document on REMIT here. Eight new answers have been added as follows:


Owners of storage (II.4.31) – It is clarified that owners of gas storage facilities are considered market participants and that the results of any auctions in purchase of cushion needs are to be reported. It is also reiterated that all gas contracts are reportable, whether they arise from auction or are continuously traded.

Clarification of the definition of a “production unit” re the 10Mw threshold (II.4.32) – Some clarity is given on the issue of what constitutes a single production unit of more than 10Mw, in particular with the example of a wind farm. The answer states that in order to determine scope, it is necessary to examine both the capacity of each cluster of turbines (i.e. that are not “spatially separated”)  and also the contract used to sell the power. In order to be over the threshold, either the cluster needs to have a capacity of over 10Mw, OR the contract used to sell the power needs to be over 10Mw, even if it covers more than one cluster. There is no concise definition of the word “spatial”.

Final customers reporting of OMP trades (II.4.34) – The answer makes clear that any trade executed on an Organised Market Place must be reported, no matter who traded it. Answer II.4.32 (above) states that this is also the case for units under 10Mw.

Scope of orders to be reported (III.3.19) – This answer clarifies that only orders arising from either an OMP or from a primary capacity auction need to be reported.

Definition of a “Single consumption unit with the capability to consume more than 600 GWh pa (III.3.20) – Various clarifications are given on this topic – firstly the assessment for gas and power should be made separately. Secondly, the answer looks into when to use actual consumption vs capacity.


Who is the “ultimate controller” that needs to be specified as part of registration? (II.4.32) – The question gives the example of a company that has owners who do not have a controlling stake in the entity and asks whether these need to be registered. The answer is that if an entity has owners who are not ultimate controllers, it is likely that the entity will be its own ultimate controller.


What is the difference between becoming a third party RRM and a Market Participant RRM? (III..2.2) – This answer specifies the difference in procedure between becoming a third party RRM vs a market participant that wishes to report their own data. It is stated that each type will get proportionate attention from ACER. it is worth noting that answer III.2.25 given previously, prohibits market participant RRMs from reporting OMP data.

About avivhandler

Aviv is the Managing Director of ETR Advisory, a niche consultancy focused on the regulation of the commodity, energy and financial markets. He has more than 23 years of experience in the financial, energy and commodity markets, covering regulatory compliance, credit, risk and financial technology. Prior to founding ETR, he was Partner at SunGard Global Services, where he built a Centre of Excellence in European Energy and Commodity Regulation. Before that, he founded Coherence, a consulting firm specializing in credit risk in commodity and energy trading as well as software product management. The credit practice ultimately became part of Sirius Solutions, where he was the Managing Director of Europe. He has also held management roles at KWI and Iris Financial, among other organizations. Mr. Handler holds a degree in computer science from Imperial College, University of London.


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