Interim Intraday Market Solution for I SEM Go Live SONI NEMO Interim IDM Final.pdf · As the trading day is from 23:00 to 23:00 it is appropriate to have a D-1 intraday auction covering

Interim Intraday Market Solution

for I-SEM Go-Live

May 2016

Interim Intraday Solution

© EirGrid 2016. Commercial In Confidence. Page i

Contents

1 Introduction ........................................................................................................................................................... 1

2 Decision Criteria..................................................................................................................................................... 1

3 Stakeholder Engagement....................................................................................................................................... 2

4 SEM Committee Decision on Interim Intraday Solution ........................................................................................ 3

5 Current Intraday Market Arrangements for SEM .................................................................................................. 3

6 Preferred Solution ................................................................................................................................................. 4

6.1 Justification for Cross-Border Intraday Auctions ......................................................................................... 5

6.2 Market Participants’ Views .......................................................................................................................... 7

6.3 Justifications for Local Continuous Trading .................................................................................................. 7

6.4 Market Participants’ Views .......................................................................................................................... 8

7 Discussions with GB Stakeholders ......................................................................................................................... 8

8 Article 63: Complementary Regional Auctions ...................................................................................................... 9

9 Other Options Assessed ......................................................................................................................................... 9

9.1 More than three cross-border intraday implicit auctions with local continuous ........................................ 9

9.2 Local auctions with one cross-border implicit intraday auction .................................................................. 9

9.3 Local auctions with local continuous (i.e. no cross-border trading) .......................................................... 10

9.4 Local continuous trading with local auctions and cross-border implicit auctions ..................................... 10

9.5 Continuous cross-border trading and continuous local trading ................................................................ 10

10 Detailed Solution Design Considerations............................................................................................................. 11

10.1 Registration ................................................................................................................................................ 11

10.2 IT Solution .................................................................................................................................................. 11


© EirGrid 2016. Commercial In Confidence. Page ii

10.3 Credit Provision .......................................................................................................................................... 11

10.4 Market Participant Queries ........................................................................................................................ 11

10.5 Order Formats and Products ...................................................................................................................... 11

10.6 Dual Currency ............................................................................................................................................. 12

11 Dual Currency Arrangements .............................................................................................................................. 12

12 Cost Recovery ...................................................................................................................................................... 12

13 Next Steps ............................................................................................................................................................ 12


© EirGrid 2016. Commercial In Confidence. Page 1

1 Introduction

EirGrid and SONI are the NEMOs designated in Ireland and Northern Ireland under Commission Regulation (EU)

2015/1222 establishing a guideline on capacity allocation and congestion management (CACM). EirGrid and SONI

NEMOs (hereafter the I-SEM NEMOs), through the I-SEM Project, are required to design, build and run a Day-

Ahead and Intraday electricity market for Ireland and Northern Ireland. In line with CACM and the European Target

Model for an integrated electricity market, the I-SEM NEMOs will join the European solution for cross-border

intraday continuous trading (XBID). However, as with the other countries that are not members of the XBID Go-

Live in July 2017, XBID will not be available to Ireland and Northern Ireland for I-SEM Go-Live in October 2017.

EirGrid and SONI as designated NEMOs have joined the XBID accession stream and will work towards joining XBID

at the earliest feasible date.

EirGrid Plc and SONI ltd are the certified TSOs in Ireland and Northern Ireland respectively and will allocate

capacity on behalf of the Moyle Interconnector and East West Interconnector based on any cross-border trading

between Ireland, Northern Ireland and Great Britain.

A cross-border and local intraday solution is needed for I-SEM Go-Live1. The purpose of this document is to set out

the solutions that were assessed by the I-SEM NEMOs, and to describe what is considered the most appropriate

and achievable solution for the interim intraday design for I-SEM. In developing this solution, the I-SEM NEMOs

briefed market participants, and other stakeholders, and welcomed feedback to the solution options under

consideration. The feedback received was used in the assessment and development of the interim intraday

solution.

The interim intraday solution will endure until the I-SEM NEMOs join XBID. Becoming a full member of XBID is

dependent on the execution of a Local Implementation Project (LIP) as part of the XBID Accession Stream. The

timing around this has yet to be confirmed by the XBID Accession Committee. In developing the solution for the

interim intraday design the I-SEM NEMOs endeavoured to ensure the enduring solution will be compatible with

the interim intraday solution and that they would complement each other to the extent possible.

The I-SEM NEMOs have procured the services of EPEX SPOT and ECC (European Commodity Clearing) to provide

the services of trading platform solutions and clearing for the I-SEM. The procurement concluded in February 2016

and the I-SEM NEMOs team have been working together with the services providers to establish clarity on the

feasibility of the options for the interim intraday market design under consideration.

2 Decision Criteria

The following criteria were used to develop the interim intraday solution:

Promotion of liquidity – as market participants are required to be balance responsible the intraday market

must be liquid

Facilitation of balance responsibility actions in the intraday timeframe

1 The SEM Committee Energy Trading Arrangement Decision Paper (SEM-15-065)



Facilitation of renewable energy on the system

Accessibility for all market participants – regardless of size, position or generation type, market

participants can access the intraday market to adjust commercial positions and support system security

Market participant acceptability – the solution should be one which market participants can readily

implement and utilise

NEMO and wider I-SEM central systems and services implementation risk and complexity

Implications for capacity management between all stakeholders

Ease of transition to XBID, including use of systems for continuous trading and ability to have cross-border

auctions which would continue to be utilised post accession to the XBID arrangements

3 Stakeholder Engagement

As part of the development of this solution, the I-SEM NEMOs implementation team has endeavoured to engage

with and gather as much stakeholder input as possible. The inputs from market participants and other

stakeholders were comprehensive and very helpful throughout the assessment of the design to-date. Stakeholder

input has directly influenced the design of the solution.

Some of the stakeholder engagements are listed below:

The team briefed 16 market participant organisations at a meeting facilitated by the Electricity

Association Ireland (EAI) on the 23rd

March 2016.

The team presented the draft interim IDM solution to 27 market participant organisations at the first

NEMO Business Liaison Group on the 4th

April 2016.

Bilateral discussions and meetings with a number of market participant organisations were also held.

Regulatory input from CER and the Utility Regulator of Northern Ireland was also sought throughout the

design process.

Subsequent to the briefings, 9 market participant organisations made written submissions to the I-SEM NEMOs.

The discussions and resulting submissions have been captured in this document. Appendix A lists the organisations

that were briefed and those that made written submissions.

The I-SEM NEMOs team held a meeting with the Moyle Interconnector (Moyle) and East West Interconnector

(EWIC) owners to establish clarity on their views regarding the solution and pricing of capacity intraday and to

discuss pre/post coupling requirements from the perspective of capacity allocation.

Responses to SEM Committee Energy Trading Arrangements Detailed Design Consultation Paper (SEM-15-026)

were also taken into account in developing the preferred solution. These responses were summarised in the SEMC

Decision Paper (SEM-15-065).



4 SEM Committee Decision on Interim Intraday Solution

In the SEM Committee ETA Decision Paper (SEM-15-065) the SEM Committee decided that an interim solution

should be implemented to ensure that an intraday market is in place from the beginning of I-SEM. The SEM

Committee noted that it saw merit in the inclusion of regional intraday auctions as part of this solution.

The SEM Committee notes that once Ireland and Northern Ireland become full members of XBID these auctions

may be phased out if the auctions result in negatively influencing the effectiveness of the XBID market. This

depends on the functionality of XBID. The I-SEM NEMOs suggest that this decision is made as part of the design of

the XBID LIP.

5 Current Intraday Market Arrangements for SEM

Figure 1 below shows the current intraday market arrangements for the SEM. There is one day-ahead auction held

at 09:30 and 2 intraday ‘implicit’ auctions from the perspective of SEM market participants use of the Moyle and

EWIC interconnectors, however these auctions are not fully implicit from the perspective of the GB market, and

market participants must separately establish their commercial and physical positions in the GB market.

The first ‘intraday’ auction is called the Ex-Ante 2 auction held at 11:30 D-1 which cover the delivery hours of 06:00

to 06:00 (i.e. the full Trading Day). The second is called the Within-Day auction held at 08:00 which covers the

delivery hours of 18:00 to 06:00 (i.e. the second half of the Trading Day).

Figure 1 Current SEM Intraday Market



At the time of writing this document, APX (now EPEX SPOT) enjoys 100% of the intraday market trading volume

within GB. This comprises one ‘Day-Ahead’ auction which is run in the intraday timeframe at 15:30 (i.e. after the

PCR DAM) covering 48 half hour trading periods between 23:00 and 23:00, and also operates a continuous local

trading service. At present, there is no implicit cross-border capacity arrangement in place in the intraday

timeframe for GB.

The different combinations for the continuous half hourly matching within GB are described in Figure 2.

UK Half Hour Day-Ahead 15:30 Local Auction by APX(EPEX) in IDM D-1

UK Spot (<4hrs)/Prompt (>4hrs) Markets by APX(EPEX) in IDM

Continuous trading locally

½ hour block, 48 periods/day. ½ hr 1 begins 23:00; ½ hr 48 ends 23:00 (Opens for trading 49½ hrs prior)

Continuous half hourly product matching within GB in different combinations including: Weekend products (48 hours) 4 hr blocks/day, block 1 begins at 23:00; block 6 ends 23:00 (market opens 2 days in advance) 12 blocks/day, block 1A begins 23:00; block 6B ends 23:00 (opens 48½ hrs pre-delivery) ½ hour product (where most of the trading is done) which matches the settlement period

Figure 2 Intraday Arrangements within GB

6 Preferred Solution

Figure 3 shows the I-SEM NEMOs preferred interim cross-border implicit auction and local intraday continuous

trading solution. The solution is to establish 3 cross-border intraday implicit auctions and to facilitate continuous

local trading with the possibility of local implicit auctions. Auctions should be implicit and based on half hourly

products.

The first auction (IDM Auction 1) should be held at 19:00 D-1 and will cover 48 ½ hour periods. IDM Auction 1 will

cover the delivery hours 23:00 to 23:00.

The second auction (IDM Auction 2) should be held at 07:00 and cover 28 ½ hour periods. IDM Auction 2 will cover

the delivery hours 09:00 to 23:00.

The third auction (IDM Auction 3) should be held at 14:00 and cover the remaining 14 ½ hour periods. IDM Auction

3 will cover the delivery hours 16:00 to 23:00.



Figure 3 Preferred Interim Intraday Solution

6.1 Justification for Cross-Border Intraday Auctions

Cross-border intraday implicit auctions are supported by market participants and interconnector owners. Prices

are set at the point of trade which allows for financial planning as well as system planning. Capacity and power are

sold in one single transaction and participants are not exposed to interconnector outages, i.e. transactions are held

financially firm.

Implicit intraday price coupled cross-border auctions, as per the Day-Ahead price coupled auction, allows for the

optimal use of the interconnectors where the electricity market price difference between the GB and I-SEM

bidding zones will dictate the direction of power flow across the interconnectors. This leads to improved socio-

economic welfare benefits and more efficient long-term signals for future interconnector developments.

As the trading day is from 23:00 to 23:00 it is appropriate to have a D-1 intraday auction covering the full trading

day, so that market participants that are unable to trade in the continuous market overnight can establish better

commercial positions utilising intraday cross-border implicit auctions. The auction timing of 19:00 was selected

with office hours in mind while also accommodating the update in wind information and bearing in mind the day-

ahead auction timings. The GB intraday auction held at 15:30 was also considered. It could be beneficial to link the



first intraday cross-border auction to this 15:30 auction as it would represent minimal change for stakeholders in

GB. The argument against holding this auction (19:00) later than the GB auction has been made by market

participants currently participating in GB, where they do not see sufficient activity in the continuous market after

normal working hours, which limits the liquidity in the continuous market and their ability to adjust commercial

positions which were not successfully established from the intraday auction.

The use of the second and third auctions allow for market participants to adjust their position closer to delivery

time, which is desirable in the context of Article 63 of CACM2. The auction times of 07:00 and 14:00 were chosen

with office hours in mind while keeping a sufficient spread in time available to market participants to receive up to

date market information.

The number of auctions was chosen after discussions with market participants. The majority of market participants

that responded to the solution under assessmeny stated that a minimum of 2 auctions would be acceptable but

that auctions that were in line with the release of wind forecasts (i.e. 4 or more auctions) would be the optimal

solution. Given that the number of cross-border auctions must be agreed with the NEMO(s) in Great Britain (GB),

the I-SEM NEMOs will be seeking 3 cross-border intraday auctions for the interim intraday design. It should be

noted that any cross-border auction arrangement will require agreement with all GB stakeholders.

The I-SEM NEMOs consider that there is sufficient liquidity in the intraday market to hold 3 implicit cross-border

auctions. IDM Auction 2 and Auction 3 will cover the hours until the end of the day (23:00). This will facilitate TSO

planning by giving a full profile for the remaining hours after each auction.

Based on market participant feedback, the I-SEM NEMOs considered up to 6 cross-border implicit auctions to

reflect the updated wind information. The I-SEM NEMOs consider that the intraday liquidity may not be sufficient

to cater for more than 3 auctions. It is expected that congestion on the interconnectors and the resulting 100%

flows on both interconnectors in the day-ahead market will limit the cross-border capacity available for traders in

what is expected to remain the desired direction of flow for the intraday timeframe. Historical flows on EWIC and

Moyle does however indicate that there is the potential for a level of price fluctuation and therefore changing of

direction of flow on the interconnectors which would make more intraday auctions desirable. The use of 4 or

more auctions may be revisited as European harmonisation improves and further clarity on the levels of intraday

cross-border liquidity between I-SEM and GB is developed post Go-Live.

The interim intraday solution is being designed with 30 minute trading periods to align with the 30 minute

settlement periods in the I-SEM balancing market timeframe. This will facilitate market participants in establishing

balance responsible positions within the intraday market. Facilitation of a shorter settlement granularity, e.g. 15

minute would be a challenge for the balancing and settlement solution.

It should be noted that cross-border auctions do not satisfy the CACM requirement for cross-border continuous

intraday trading. However it does satisfy the requirement for pricing of capacity. It has been advised by the I-SEM

NEMOs service provider that cross-border intraday continuous trading will be difficult to implement for I-SEM Go-

Live. This is due, in part, to the complexity of addressing the issue of establishing a capacity calculation mechanism

and associated contractual arrangements between all of the stakeholders between GB and I-SEM. These

2 Please see Section 8 for more details on compliance with Article 63 of CACM.



arrangements will be established as part of the XBID LIP and will be incorporated into the enduring intraday

solution. Further work needs to be undertaken to explore the technical requirements for continuous cross-border

trading. The timeline for implementing this will be considered in terms of the XBID LIP for I-SEM.

Article 83 of CACM states that Ireland and Northern Ireland must provide for “allocation of interconnector capacity

in...at least two implicit intraday auctions” by 31 December 2017. The design presented in this document therefore

satisfies the requirements under CACM.

6.2 Market Participants’ Views

The use of intraday cross-border implicit auctions was widely supported by market participants through responses.

While they acknowledged that the I-SEM NEMOs must establish formal agreements with their GB counterparts for

any cross-border implicit auction arrangements, market participants noted that more than 2 auctions would be

beneficial.

Market participants acknowledged that the development of a cross-border continuous trading solution is required

to ensure adequate market access under I-SEM arrangements.

One response suggested that the interim intraday solution should allow participants the opportunity to trade at

the settlement period granularity to facilitate shape management and therefore their imbalance position.

One response expressed concern that the cross-border continuous trading is out of scope for I-SEM Go-Live. This

respondent questioned why an “off-the-shelf” solution is not available as the I-SEM NEMOs service provider has

implemented similar local continuous intraday functionality in other EU markets. In response to this query, it is

mainly the issue of the need to establish the required arrangements for the capacity platform for the region that

introduces the complexity (together with dual currency challenges). The capacity platform is managed by the TSOs

and is provided by Deutsche Börse which is the owner of the XBID solution. This capacity platform is fully

implemented on certain borders on the continent (FR-DE, DE-AT, DE-CH, FR-CH and soon on BE-FR, etc.). The TSOs

feed it with remaining available cross-border capacity for intraday cross-border transactions and the market

participants, including the NEMOs, book capacity in real time on this platform. As NEMOs, EirGrid and SONI will

need to connect to this platform with our continuous trading system and in real time, the I-SEM NEMOs will need

to be able to get capacity, if available, to match orders from different delivery areas. For the I-SEM NEMOs’ LIP

solution it will be the equivalent of the capacity module within XBID, but with an OTC access.

6.3 Justifications for Local Continuous Trading

In parallel with the cross-border intraday auctions, the I-SEM NEMOs intend to run a local continuous intraday

market. A continuous market will ensure adequate market access and facilitate market participants in adjusting

their position close to real time. Participants will be able to run and plan power generation closer to delivery.

Unforeseen events such as power outages will be more easily managed in a continuous market. Furthermore, the

use of a continuous market brings the I-SEM a step closer to the XBID solution. In order to finally join XBID, I-SEM

must develop a Local Implementation Project (LIP) which will transition the intraday market form current

arrangements to XBID. Establishing a continuous local intraday market at this point will help to simplify the



transition to XBID. From a systems perspective the use of the M7 product available from our service providers is

closely aligned with the XBID system (which was based on M7).

6.4 Market Participants’ Views

All responses received were in favour of local continuous trading, with many insisting on this at a minimum.

Respondents noted that implementation of continuous trading will help make the market transition to LIP and

XBID more straight forward. However, some did note that it may not provide significant liquidity in the I-SEM on its

own.

The drivers that were identified for the implementation of continuous trading included: evolving forecasts (wind

and demand), the need to manage availability changes, the change in trading period granularity between the day-

ahead market and the balancing market timeframes, adjusting positions established in the intraday auctions, and

the requirement that FPNs must be physically feasible.

Respondents favoured the use of continuous products similar to those used in GB.

7 Discussions with GB Stakeholders

The feasibility of the cross-border intraday auctions is contingent on the acceptance of GB stakeholders. The I-SEM

NEMOs note that the GB market participants, Ofgem and the GB NEMOS, in particular EPEX SPOT as the only

market operator of an intraday auction in GB today, must be satisfied by the value of the 3 intraday auctions. In

addition, National Grid as the GB TSO is a key stakeholder with regard to the technical feasibility and IT

compatibilities of facilitating the 3 implicit intraday auctions on the system.

Sufficient market liquidity is also a requirement for the acceptability of multiple intraday cross-border auctions. It

is the opinion of EPEX that implementing a glidepath to the 3 auctions is a more conservative approach. This would

involve establishing IDM Auction 1 only for the I-SEM Go-Live. As it becomes evident that there is sufficient

liquidity in the market IDM Auction 2 would be introduced and subsequently IDM Auction 3. This would mitigate

against the risk of not having sufficient liquidity for multiple intraday cross-border auctions from the start of I-SEM.

It was also noted that the preferred solution exceeds the transitional requirements set out on Article 83 of CACM

(see section 6.1). It would therefore be important to set out the principles for cost recovery to ensure that the

costs incurred by the GB, Irish and Northern Irish parties involved in the establishment and operation of the 3

intraday cross-border auctions are adequately recovered.

While the I-SEM NEMOs acknowledge the concerns expressed by EPEX, the feedback from Irish and Northern Irish

market participants indicate that there is value in holding at least 3 intraday cross-border auctions. In addition,

Article 83 of CACM states that Ireland and Northern Ireland must have at least two implicit cross-border intraday

auctions by 31 December 2017. Therefore establishing IDM 1 only for I-SEM Go-Live with no commitment to

establishing a second auction before 31 December 2017 would prevent Ireland and Northern Ireland from

complying with CACM.



Lack of acceptance of the preferred solution is a risk to implementation of the full solution for I-SEM Go-Live. The I-

SEM NEMOs will continue engagement with the GB parties in an effort to mitigate against this risk.

8 Article 63: Complementary Regional Auctions

Article 63 of CACM allows for the use of regional auctions in addition to cross-border continuous trading via what

has now been identified as XBID. NEMOs and TSOs on bidding zone borders (i.e. Ireland, Northern Ireland and

Great Britain) may jointly submit a common proposal for the design and implementation of complementary

regional intraday auctions. This proposal must meet the requirements outlined in Article 63 and is subject to

consultation in accordance with Article 12.

It should be noted that at this point the cross-border implicit auctions being proposed are not being proposed

under Article 63. This solution is an interim solution to facilitate the transition to the XBID Accession Stream LIP.

However, in designing the LIP in cooperation with the parties in GB a joint decision may be made to submit a

proposal for complementary regional intraday auctions if it identified as a beneficial addition. If this occurs the

NEMOs and TSOs will jointly make a submission to the relevant NRAs that will comply with the conditions outlined

in Article 63 prior to 18 months after the entry into force of CACM.

9 Other Options Assessed

9.1 More than three cross-border intraday implicit auctions with local

continuous

As discussed above, most market participants that commented on the considered solutions for an interim intraday

solution stated that they would prefer more than two cross-border auctions. In particular, they felt that it would

be beneficial for auctions to line up with wind forecast updates. The number of auctions that occur is dependent

on agreement with the power exchanges in GB. The I-SEM NEMOs consider that 3 auctions may be acceptable to

the GB power exchanges for I-SEM Go-Live but that more would represent a challenge.

Furthermore, the I-SEM NEMOs consider that 3 auctions are suitable as sufficient liquidity may not be available for

further auctions.

9.2 Local auctions with one cross-border implicit intraday auction

Local intraday auctions and only one cross-border implicit intraday auction is considered to be insufficient for the

needs of I-SEM for Go-Live. It was determined that in order to gain greater compliance with CACM and to make

the ease of transition to XBID more simple, it is necessary to operate an intraday continuous market. A cross-

border continuous market is not feasible for I-SEM Go-Live due to the complexities involved. It will be achieved

through the XBID Local Implementation Project. However, it is possible to implement a local continuous intraday

solution in a cost efficient manner given the time constraints. Therefore, a local continuous will facilitate the

initiation of a continuous intraday market for the I-SEM as a step towards transitioning to XBID.



Most market participants that commented on the interim intraday solutions under review acknowledge that it was

sensible to include a continuous intraday market with the view to transitioning to XBID. Some responses did note

that local continuous trading may not provide sufficient liquidity in I-SEM alone and that auctions will also be

required.

9.3 Local auctions with local continuous (i.e. no cross-border trading)

Local auctions with local continuous trading is not an acceptable solution for the interim intraday trading. Market

participants that made a submission to the I-SEM NEMOs and those that responded to the SEMC consultation

(SEM-15-026) were against the use of this solution. It was felt that it would not deliver sufficient liquidity for the

intraday market and access to cross-border capacity is essential. The I-SEM NEMOs determined that this solution is

the least CACM compliant and will not assist in the transition to XBID.

In the SEMC Energy Trading Arrangements Detailed Design Decision Paper (SEM-15-065) the SEMC notes that a

local only intraday solution is not a viable solution as is could be seen as a retrograde step from the current trading

arrangements and developing this as an interim solution could result in redundant costs. In addition, this solution

would not satisfy Article 83 of CACM.

Through their submissions through the I-SEM NEMOs market participants note that while local (and cross-border)

auctions are widely supported as they will help pool liquidity they are insufficient on their own to support

participant trading needs in the intraday timeframe. However, there is a risk that the GB counterparts will not

agree to intraday cross-border trading. This is a low risk and is being managed by the I-SEM NEMOs.

9.4 Local continuous trading with local auctions and cross-border implicit

auctions

The I-SEM NEMOs are open to local continuous trading with local auctions and cross-border implicit auctions for

the interim intraday solution. It is not the preferred solution because of the added complexity of combining local

continuous trading with a larger number of local auctions. Furthermore, there is a concern that the combination

could reduce liquidity in both markets.

However, the I-SEM NEMOs accept that this may be a more attractive arrangement for smaller market participants

and may result in pooling of liquidity and further price certainty.

Most responses were in favour of additional local auctions if required. It was noted by a number of market

participants that 3 or 4 local auctions could be optimal. A number of responses noted that it would be useful for

the local auctions to be timed in conjunction with the wind forecast update and that sufficient time was given

before the auction (e.g. 1 hour) for market participants to consider the information.

9.5 Continuous cross-border trading and continuous local trading

As discussed in section 6.1.1 the use of continuous cross-border intraday trading poses difficulty for reaching the I-

SEM timelines and so will not be used for the intraday interim solution. However further work will be carried out



to understand the technical requirements and timelines for the use of continuous cross-border intraday trading in

the context of the I-SEM’s XBID LIP.

10 Detailed Solution Design Considerations

Through the stakeholder input channels described in section 3, market participants discussed detailed solution

design considerations. This section summarises those considerations that will be taken into account as the I-SEM

NEMOs develop the preferred solution.

10.1 Registration

It would be more efficient for a market participant to deal with one party for registration to the greatest extent

possible. It can be assumed there will also be benefits from the perspective of the balancing market operator if

unit ID’s, party ID’s etc. align. This is especially the case given the algebra requirements for settlement.

10.2 IT Solution

While different systems may inevitably exist, it would be helpful if possible enablers such as digital certificates,

web portals, etc. were aligned. The divergent back end systems should be masked as much as possible from

participants by a singular front end.

10.3 Credit Provision

The provision of collateral is of concern. A design which requires the posting of collateral in multiple places for

different markets may result in over collateralisation, administrative burden, risk and cost. Market participants

would like to see strong lines of communication and harmonisation of implementation across the I-SEM NEMOs

and balancing market function to minimise such issues. This is being assessed within the I-SEM programme. Ideally

market participants would welcome this also being extended to cover more timeframes.

10.4 Market Participant Queries

To the extent that roles, functions and outputs can be brought together the helpdesk support for the NEMO and

other market timeframes managed by EirGrid and SONI will align to the extent possible.

10.5 Order Formats and Products

One market participant asked if order formats for continuous trading and intraday auctions (which need to also

consider clearing and price formation approaches) are being considered in conjunction with current imbalance

arrangements. Market participants felt that the I-SEM NEMOs should be careful not to introduce a systemic

difference in pricing between intraday markets and the balancing market as could distort incentives to trade in

intraday market. In relation to recovery of fixed costs, participants will want to recover start costs in the imbalance

pricing.



In considering products, market participants believe that products will be required at trading period granularity (to

facilitate DAM schedule management). The development of products aligned to GB products is also desirable.

10.6 Dual Currency

Market participants in Northern Ireland would find it useful to see all prices on the continuous intraday market

platform in Great British Pounds.

11 Dual Currency Arrangements

Arrangements for dealing with dual currency within the I-SEM will need to be designed as part of the interim

intraday solution. This design work is currently ongoing and the I-SEM NEMOs are satisfied at this point that a

feasible and satisfactory solution can be produced. A solution for such arrangements will be shared once finalised.

12 Cost Recovery

Article 76 of CACM states that NEMOs shall be entitled to recover costs through national agreements with the

competent regulatory authority. These costs include the common, regional and national costs of establishing,

updating or further developing the single intraday coupling and will be shared between all Member States that

benefit from the solution.

A LIP is required to become a full member of XBID and this interim intraday solution is the first step towards

completion of that LIP. Therefore, the cost of establishing (including design and implementation) the interim

solution should be considered as costs associated with establishing the single intraday coupling. As such, the costs

incurred in designing, implementing and operating the interim intraday solution should be considered as being

covered under Article 76 of CACM.

As discussed in section 6.1 the preferred solution exceeds the CACM requirements for Ireland’s and Northern

Ireland’s transitional provisions. This should be taken into account when determining the principles for cost

recovery including cost sharing with GB.

13 Next Steps

The I-SEM NEMOs intend to implement a continuous local intraday market and 3 cross-border implicit auctions for

the interim intraday solution. The interim intraday solution will be the first step towards an XBID LIP and has been

generally supported by market participants. Further work will be carried out in cooperation with the GB NEMOs to

develop this solution and ensure it is mutually agreeable.

The costs and timeline for implementation and the operating costs of the preferred solution need to be reviewed

in detail. This piece of work has begun and is dependent on a number of the design elements outlined in this

document.



The I-SEM NEMOs will continue to accept input from market participants and any stakeholders in the development

of the detailed design of the interim intraday market.

Once the CER and the Utility Regulator of Northern Ireland have considered the I-SEM NEMOs’ preferred interim

intraday solution, the I-SEM NEMOs will further engage with the relevant parties in GB to complete the detailed

design of the interim solution. The implementation of the interim intraday solution described in this document is

contingent on the acceptance of the solution from the GB parties. There is a risk that the GB parties will favour a

more conservative approach to the intraday solution. Once an agreement has been reached, a programme of work

will be developed and implementation will begin. The implementation timeline will be in line with the I-SEM Go-

Live date and will include adequate time for market participant training. Market participants will receive frequent

updates on progress through the NEMO Business Liaison Group.



Appendix A: Stakeholder Input

The following organisations3 were briefed on the interim intraday solution:

AES UK & Ireland

Aughinish Alumina Ltd.

Bord Na Mona

Bord Na Mona Power Gen

Bord Gais Energy

Brookfield Renewable

Budget Energy

Captured Carbon

Cenergise

EirGrid / SONI

Electric Ireland

Electricity Association of Ireland (EAI)

ElectroRoute

ESB

ESB Trading

EirGrid Interconnector Limited

Gaelectric

Irish Wind Energy Association

Mutual Energy (Moyle)

NI PPB

NIE Networks

Power NI Energy Ltd

PrePay Power

SSE

Tynagh Energy

Utility Regulator Northern Ireland

VAYU

Viridian Group Limited (Energia)

WFO Ltd / WFSO Ltd

The following organisations made written submissions to the I-SEM NEMOs:

1. Energia

2. Power NI

3. IWEA

4. Gaelectric

5. Brookfield

3 Organisations that attended multiple briefings are only listed once.



6. Viridian Power

7. ESB

8. Electricity Association of Ireland

9. AES

Documents

Interim Intraday Market Solution for I SEM Go Live SONI NEMO Interim IDM Final.pdf · As the trading day is from 23:00 to 23:00 it is appropriate to have a D-1 intraday auction covering