NG Strawman – Ofgem Response Review of Emergency Claims Arrangements, 16 March 2009

Issues to Consider Should there be a deadline for placing offers on the OCM? Is there an incentive to wait until the end of the day to place offers? When would claims be submitted and paid? Might the three month cost recovery process deter shippers from sourcing additional gas? On what basis are claims assessed? No single model (FSC, Black Start, Network Code Modification Proposals) upon which to base changes Should claimants be paid for losses incurred or according to a “market value” of gas? Recommend a working group is established to develop proposal/guidelines

Issues to Consider How will the costs of emergency claims be calculated? Would offers on the OCM be adjusted by the frozen SAP? Should short shippers be targeted with the marginal or average cost of validated claims? What is appropriate level of incentive?