MOD 0365 - National Grid NTS Initiated Flow Swaps March 7th 2011 Transmission Work stream 2 December 2010

MOD 0365 – High level process overview National Grid NTS formally contact relevant DNO requesting the revision of OPNs at two or more NTS/LDZ offtake(s) within the same LDZ (current UNC). Aggregate OPN position remains as-is (Current UNC). Request also provides the Firm NTS Exit (Flat) Capacity entitlement that would be transferred upon acceptance of the request. DNO then has 15 minutes to decline the request. UNC rationale for declining the request remain as-is. Post 15 minutes the request is deemed to have been accepted and the Firm NTS Exit Capacity is transferred. DNO then has a further 15 minutes to submit the revised OPNs reflecting the request. from the initial formal request, the DNO User has 30 minutes to submit the revised OPN(s).

MOD 195av MOD 195av stated the following: National Grid NTS’ ability under OAD Section I2.4 to request that a DNO revises its Offtake Profile Notices while maintaining the aggregate rate of offtake into an LDZ will remain. This facility will also be extended, based on the same principles, to allow DNO Users to request that National Grid NTS accept Offtake Profile Notices which will transfer, but not increase in aggregate, its NTS Exit (Flat) Capacity holdings between two or more of its NTS/LDZ offtakes. This is to provide DNO Users sufficient certainty that National Grid NTS will transfer its NTS Exit (Flat) Capacity between such NTS/LDZ offtakes, where it would not jeopardise the safe and efficient operation of the NTS, to prevent potential inefficient over-booking of capacity.

UNC B3.13.10... The calculation of a Chargeable NTS Exit (Flat) Overrun shall take into account any additional quantity of gas offtaken at an NTS/LDZ Offtake consistent with any revision to the rate of offtake of gas for the Day at the NTS/LDZ Offtake following the application of OAD Section I2.4 and 2.5 Introduced through 195av We believe B3.13.10 is intended to take into account any additional quantity of gas offtaken and the corresponding decreased quantity of gas offtaken However open to interpretation as no clear reference to the decreasing offtake

Next Steps ..views sought... Amend MOD 365 to include the same capacity transfer provisions for DNO initiated flow swaps: In line with the intent of 195av (i.e. within day transfer of NTS Exit (Flat) Capacity) OAD I2.4 and 2.5 principles remain Provides clarity of within day position covers all flow swap scenarios (e.g. multiple flow swaps at the same locations & clarity regarding the decreasing offtake(s)) MOD to amend B2.13.10 to clarify decreasing quantity aspect OAD I2.4 and 2.5 principles remain. Withdraw MOD UNC remains open to interpretation Unclear how all potential flow swap scenarios would be treated Lack of clarity of within day capacity position