Richard Fairholme Transmission Workstream 4th September 2008 Modification Proposal 0219 – “Publication of UK Wholesale Gas Market Liquidity Data” – UPDATE Richard Fairholme Transmission Workstream 4th September 2008

Update At the last Transmission Workstream, the proposal received initial support from many industry participants (including Ofgem). Subject to discussions here today, it is still our intention to present this Modification Proposal to the September Mod Panel. Therefore, looking to iron out any issues to ensure it is developed as fully as possible before it is submitted formally. All views welcome. Please overwrite text

Specific Issues for Discussion & Development Publication Timing Historical Data Defining “Total Daily Physical” Interaction with the ‘MIPI project’ Additional Data Items NCORM or UNC Modification Proposal? Please overwrite text

1. Publication Timing 2. Historical Data Currently D+1. Suggested move to D+2, however… Entry closes out at D+5. Any other timing issues to be considered? 2. Historical Data Mod currently specifies publication of 10 years of data. 2 years of data more realistic?

3. Definition of “Total Daily Physical” Current definition is based on National Grid’s Ops Forum report where term is used and is taken to mean: “Amount Physically Delivered to the NTS from the NBP trades. i.e. from the Total Gas Traded on the NBP, the amount that actually ended up as a Physical Supply flow to the NTS.” Is this a reasonable definition for the Mod? Any alternative suggestions?

4. Interaction with the ‘MIPI Project’ National Grid Workshop on 17th September 2008. However… If integrated into the ‘MIPI Project’, seems unlikely to deliver this information until end of 2009. This would be too late. A key reason for raising this Mod is to address current misinformation about the level of liquidity in the wholesale gas market. Not a suitable route if it involves new Code obligations?

5. Additional Data Items Further to suggestions from other Users, we propose to also include: The number of parties trading on the day The number of trades on the day Views sought on the value of this information. Any other information that would be of use?

6. NCORM Change or UNC Modification Proposal? UNC Modification Governance Only seems appropriate if presenting existing data in a different way. Necessary if changes to timing of publication of data and/or new data items. Little opportunity for industry participation. Formal industry consultation & variation / alternative Mod options. Requires UNC Committee approval. Mod Panel recommendation & Ofgem decision. No implementation obligation? Implementation obligations in Code (if approved).

Theme Date Department