1. UNCC 11 November 2013 Request for Clarification on AUG Rules Fiona Cottam

2. Background Concept of AUGE set out in UNC Section E Section E refers to UNC Related Document – AUGS Guidelines Apparent discrepancy between UNC and Guidelines Neither UNC nor Guidelines specifies which document “prevails” in event of conflict Seeking confirmation from UNCC of our understanding and clarification on interpretation

3. UNC Section E (1) 10.4.3 … e)the Committee shall decide upon, adopt and publish the AUG Methodology; f)the AUG Expert shall implement the AUG Methodology and prepare a proposed AUG Table; … (h) the Committee shall adopt the final AUG Table submitted by the AUG Expert under paragraph (g) unless by unanimous resolution the Committee determines: (i) to revise such AUG Table and adopt the revised AUG Table; or (ii) to require any further iteration of any steps as referred to in paragraph (g), in which case paragraph (g) (to that extent) and this paragraph (h) shall further apply; (i) the Committee shall publish the AUG Table as adopted under paragraph (h);

4. UNC Section E (2) 10.4.4 For the purposes of the Code: a)the AUG Methodology and AUG Table established for an AUG Year for the purposes of paragraph 10.4.1 shall be those adopted by the UNCC under paragraph 10.4.3, and shall not be subject to modification in relation to such AUG Year; b)the AUG Methodology and the AUG Table shall be binding for the purposes of the Code.

5. AUGS Guidelines (V3 24/02/11) Current possible outcomes of the Query Process (Guidelines 8.4): (a) Requiring no action; (b) Requiring a change to the Final AUGS, but will have (sic) not have a material impact on the final Unidentified Gas volumes; or (c) Requiring a change to the Final AUGS, which will have a material impact, but cannot be implemented in time for the creation of the final Unidentified Gas volumes. Or 8.5 Requiring a change to the final AUGS … which can be implemented in time for the creation of the final UG volumes

6. AUGS Guidelines (V3 24/02/11) Following receipt of a Query under the Query Process (Section 8) 8.5 In the event that the AUGE classifies the change as requiring a change to the Final AUGS, which will have a material impact, and can be implemented in time for the creation of the final Unidentified Gas volumes, then the AUGE will provide an updated Final AUGS taking into account those changes it believes should be incorporated, as well as reasons as to why those changes are necessary.

7. Request for Clarification Guidelines Para 8.5 suggests that a Query may result in an updated Final AUGS, but UNC E10.4.4 seems to state that once approved, the AUGS cannot be changed –This would mean that any Query raised after adoption of the AUGS could not result in any change to the AUGS Which Document prevails? Can the AUGS ever be updated after adoption? –Queries can only be raised from 1 st September onwards –AUGS must be approved “on or around the 1 st September” –It would always be too late to change the AUGS?

8. Query received, upheld by AUGE No change required (to AUGS or Table) No action required Change required to AUGS No action possible Change required to Table only If Table already adopted – No action possible If Table not yet adopted - Action Possible revised Query outcomes If UNC prevails over Guidelines, no update can be made to AUGS or Table after adoption by UNCC Full range of possible outcomes from Query Process would be as shown