Reports EU Regulations REMIT Reporting Services & Solution | Page 52

REMIT Reporting Services and Solutions - July 2015 updated March 2016 section 5.5. This is also the stage at which to decide whether to adopt a temporary solution, or a permanent one, as examined in section 5.8. This is also when an RRM should be chosen. It is tempting to leave the selection of a phase 1 solution to the “last minute” on the basis that OMPs, or certain services, will carry out reporting. However, it is recommended that this not be relied upon until all data agreements are signed. Even after this stage, it is useful to have a contingency plan in case an OMP fails to report, or fails to provide data to a third party, on the first reporting date. 7.6 Phase 2 solution The phase 2 solution needs to primarily consider how all of the required data will be captured and sent to the selected RRM. There are several sources of data that need to be discovered and linked to the RRM, which correspond to the types of data outlined in section 6.1. Each is likely to have a different source: - - - - - Look alike, simple and stand-alone complex trades - are likely to come from an ETRM system. These will need to be sourced and somehow transformed for sending to the RRM. This will happen in different ways depending on the solution shape chosen Framework contracts – are unlikely to be stored in any system. A mechanism will need to be found to capture the required data elements, and to send them to an RRM, either ACER XML or via another method. Some dedicated regulatory software will permit users to manually enter the framework and transform it into ACER XML. Some services, and RRMs will also provide a GUI, which permits such entry. Executions – Sometimes these are stored in ETRM systems, in which case the data can be extracted for onwards sending. At other times, the data will need to be manually captured; either using dedicated software or possibly manually entered into a service or RRM. Transportation and capacity – while this data is sometimes to be found in an ETRM, it often is not and will need to be sourced from where it is stored. Many will need to then transform this into the appropriate XML format, although some RRMs may permit it to be entered using a GUI. Expect more activity in this area in the months after the 7th April. Fundamental data – market participants must report the fundamental data as outlined in section 6.6. This data is unlikely to be in any RRM. It will therefore be necessary to find the data and possibly transform it into the correct format before it is sent to the RRM 7.7 Stay in touch and implement While this section is intended as a guideline, the solution must be approached as any project, with a budget, timeline and scope. It is every project manager’s job to keep within these three objectives, and a REMIT project is no different. There are however, some important differences, in particular: - The timeline cannot be moved Neither can the scope, at least not by the market participant. The requirements may change later. This last two points are important: while a market participant may not change scope, the details around the rules change on a daily basis, and these must be kept up with and understood during the implementation and also after it. In some cases, there will be ambiguity over a requirement. In order to address these it is important to stay in touch with others facing the same issues, until definitive rulings are created. Having a moving target and scope, controlled by others, with ambiguity, and a fixed timeline is challenging. It is important to equip oneself with the tools to meet this challenge as best as possible. Copyright 2016 – ETR Advisory Ltd and Commodity Technology Advisory LLC 51