Public consultation on ACER's Transaction Reporting User Manual
Contents
1. i Finnish Energy Industries Answer to public 1 2 consultation Petteri Haveri 2 9 2014 Agency for the cooperation of energy regulators Remit PublicConsultations acer europa eu Public consultation on ACER s Transaction Reporting User Manual TRUM and RRM Requirements for transaction reporting under REMIT The Finnish Energy Industries is a trade organisation for producers suppliers transmission distributors and sales of electricity for district heating and district cooling and for design implementation operation maintenance and construction of networks and power plants Energiateollisuus ry Finnish Energy Industries EC Register ID number 68861821910 84 Address PL 100 00101 Helsinki Finland Contact person Petteri Haveri email petteri haveri energia fi phone 358 9 5305 2404 General points and issues not covered under questions We welcome ACER s work to provide guidance on REMIT reporting in as early phase as possible and to have an open discussion on this guidance Specific issues 3 1 4 Contracts reportable on request We d like to draw ACER s attention to the fact that Contracts for balancing services in electricity are typically made on market places Hence whereas the statement The contracts listed above shall however be reported even in the absence of a request of the Agency if they are concluded at an organised market place can be applied to points 1 3 it is not applicable for poin2. R s work to provide examples on how the reporting is to be done We d welcome would ACER add an example how to report non standard contracts where balancing responsible buys energy from its open supplier in order to be in balanced position
3. t 4 and would create a big burden for balancing markets Secondly we d like to see ACER s opinion how they understand reportable on request We understand the underlying idea being that on ad hoc basis ACER may request this information from an individual market participant in very specific cases It is of great importance to have certainty that market participants don t need to be prepared to ACER s request since this would require investments on IT systems and hence cause unnecessary costs that eventually end up being paid by the customers of wholesale market companies 3 2 1 Wholesale energy products concluded at an organised market place The natural party to do the reporting is the market place It is very hard to understand why the requirement to report is not set directly to the market place The market place is typically the counterparty in every trade executed at the market place We would thus urge ACER NRAs to somehow step into the process of this reporting relationship to ensure proper clear and transparent process in due time and at reasonable costs Register I D number Finnish Energy I ndustries 68861821910 84 Fredrikinkatu 51 53 B Fl 00100 Helsinki P O Box 100 Fl 00101 Helsinki Telephone 358 9 530 520 Fax 358 9 5305 2900 www energia fi 2 2 3 2 3 Wholesale energy products reported in accordance with EMIR or other EU financial markets legislation We understand that the purpose is to minimise reporting cos
4. ts by collecting needed information from available sources We very much welcome that reports provided by EMIR are taken into account We however regret that ACER isn t providing the needed certainty that EMIR reporting is fully sufficient and opens the question whether orders to trade would still be reportable This would pretty much water down the benefits of usage of EMIR reports and lead to expensive double reporting 4 1 d Order report ACER could clarify does it expect only orders that have led to transaction to be reported 4 2 Data fields related to the parties The field beneficiary has caused a lot of discussion We d understand that the purpose of this field is to gain information when a company executes a trade on behalf of another company based on a specific request Then again we have lots of examples where an open supplier has a responsibility to sell energy to its customers and based on their balances the open supplier executes trades We d like to have a confirmation in TRUM that in these kinds of arrangements the beneficiary field doesn t apply 5 Reporting of non standard supply contracts We d welcome would ACER confirm that in case of a non standard agreement it is generally sufficient that the information of master agreement is provided It would be very laborious to report hourly flows of energy and money which are based on this master agreement ANNEX III Examples of transaction reporting We welcome ACE
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