Transparency

GRI SSE -- 7th Stakeholder Group MeetingVienna, 16 October 2009

Andrea ĆirlićováGTE+ Senior Adviser

• Transparency Platform

• Transparency requirements under Regulation (EC) 715/2009

• Transparency Guidelines to be annexed to Regulation (EC) 1775/2005

• Transparency Platform

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History

Phase 1

Phase 2

Development

17 November 2008

TSO-related informationCapacity & tariff informationSearch functionality

Further development & fine-tuning; TP ‘enlargement‘ *

CAM InformationBalancing Model information

17 March 2009

2 April 2009

Capacity display in kWh/d

Actual flows (allocations)Nominations/renominationsInterruptionsDownload facility

27 May 2009

* 17+10 TSOs represented on TP on 16 October 2009

November 2008

June 2008

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Participating TSOs (1)

Participating TSOs (2)

TP Demonstration (1)

TP Demonstration (2)

TP Demonstration (3)

Phase 3

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Way Forward

TP development in 2009-2010 (1)

• Improving the data quality (‘added value of the information‘) & quantity

• Coordination of and support to TSOs in implementing voluntary transparency at the national level

• Attracting non-participating TSOs to join the project

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TP development in 2009-2010 (2)

• Enhancing user-friendliness

• Extending the scope of information provided• Using the TP as a way to comply with Regulation (EC) 715/2009‘s

transparency obligations?

• Introducing more interactive elements, e.g. database-search for aggregated information relating to the transmission systems, incl. possibly data collected for the development of TYNDP

• Supporting the participation of other infrastructure operators

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Based on feedback; issues raised at Transparency Workshop on 30 Sep 2009

Long-term Objective

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• Creation of extensive database

• Creation of interactive tool

• For network users

• For TSOs

• For ACER / MSs

• Commission

Considering that the data may be used by consultancies to sell transparency-related

services, should the use of certain TP services be charged?

• Transparency requirements under Regulation (EC) 715/2009

Regulation (EC) 715/2009

• Published in the Official Journal on 14 August 2009

• Applicable as of 3 March 2011 (repeals Regulation (EC) 1775/2005)

• Additional transparency obligations vis-à-vis TSOs

• New transparency obligations vis-à-vis SSOs and LNG SOs

• To ensure consistent implementation of the transparency obligations by TSOs, GTE+ has undertaken to define a common European approach by specifying the deliverables and recommends all its members as well as other TSOs to implement them

Transparency Obligations• 3-minus rule not applicable any more

• “The transmission system operator shall make public ex-ante and ex-post supply and demand information, based on nominations, forecasts and realised flows in and out of the system. The national regulatory authority shall ensure that all such information is made public. The level of detail of the information that is made public shall reflect the information available to the transmission system operator.The transmission system operator shall make public measures taken as well as costs incurred and revenue generated to balance the system.The market participants concerned shall provide the transmission system operator with the data referred to in this Article.”

• “Each LNG and storage system operator shall make public the amount of gas in each storage or LNG facility, or group of storage facilities if that corresponds to the way in which the access is offered to system users, inflows and outflows, and the available storage and LNG facility capacities, including for those facilities exempted from third-party access. That information shall also be communicated to the transmission system operator, which shall make it public on an aggregated level per system or subsystem defined by the relevant points. The information shall be updated at least daily.” ** Publication may be restricted for a certain time period if the aggregate information refers to only one user, and an exemption has been granted by the NRA on the basis of a request by the storage user.

Ex-ante Supply

* To be published at 6 p.m. CET

If the TSO is obliged, under national regulatory rules, to provide its own supply forecast, such forecast will be published along with the ex-ante supply information as specified above.

Ex-ante supply information* In kWh/d

Aggregated nominations at entries (as specified in the rows below)

Aggregated nominations at IPs with other transmission systems (incl.

balancing zones within the same transmission system) or between

market areas

Aggregated nominations at IPs with storage systems

Aggregated nominations at IPs with production facilities

Aggregated nominations at IPs with LNG terminals

Supply forecast by TSO In kWh/d

Supply forecast

Ex-ante Demand

If the TSO is obliged, under national regulatory rules, to provide its own demand forecast, such forecast will be published along with the ex-ante demand information as specified above.

Ex-ante demand information* In kWh/d

Aggregated nominations at exits (as specified in the rows below)

Aggregated nominations at IPs with other transmission systems (incl. balancing

zones within the same transmission system) or between market areas

Aggregated nominations at IPs with storage systems

Aggregated nominations at IPs with LNG terminals (if applicable)

Demand forecast by TSO In kWh/d

Demand forecast

* To be published at 6 p.m. CET

The information on ex-ante demand will be extended by Aggregate Nominations at IPs with distribution systems if such nominations are available to the TSO, or by any comparable figure if supplied by suppliers to the TSO.

Ex-ante Supply and Demand

• The information on ex-ante supply and demand will be accompanied by the following note if applicable:

The ex-ante supply and demand information needs to considered in the light of the following system specificities: (1)network users are allowed to nominate imbalances;

(2) network users are allowed to nominate virtual counter flows at the IPs between TS-DS (the Aggregate Nomination will be published under ex-ante supply information);

(3) one or more storage facilities are connected to the relevant distribution networks;

(4) one or more production facilities are connected to the relevant distribution networks.

Ex-post Supply

*To be published within 48 hours after the end of the relevant Gas-Day on preliminary basis and by M+30 (working days) as validated figures..

Ex-post supply information* In kWh/d

Aggregated allocations at entries (as specified in the rows below)

Aggregated allocations at IPs with other transmission systems (incl.

balancing zones within the same transmission system) or between market

areas

Aggregated allocations at IPs with storage systems

Aggregated allocations at IPs with production facilities

Aggregated allocations at IPs with LNG terminals

Ex-post Demand

Ex-post demand information* In kWh/d

Aggregated allocations at exits (as specified in the rows below)

Aggregated allocations at IPs with other transmission systems (incl. balancing

zones within the same transmission system) or between market areas

Aggregated allocations at IPs with storage systems

Aggregated allocations at IPs with LNG terminals (if applicable)

Aggregated allocations at IPs with distribution systems and directly connected

customers

*To be published within 48 hours after the end of the relevant Gas-Day on preliminary basis and by M+30 (working days) as validated figures..

Balancing Info

Dynamic type of information should be defined at the national level to reflect the specificities of the respective balancing regime.

Storage & LNG InfoStorage data* Units*

Daily aggregated amount of gas in storage facilities per (sub)system in kWh or m3

Daily aggregated inflows and aggregated outflows in and from storage facilities per (sub)system

in kWh or m3

Daily available capacities at storage facilities aggregated per (sub)system

LNG data* Units

Daily aggregated amount of gas in LNG facilities per (sub)system in kWh or m3

Daily aggregated inflows and aggregated outflows in and from LNG facilities per (sub)system

in kWh or m3

Daily available capacities at LNG facilities aggregated per (sub)system

A joint meeting will be yet held with GSE and GLE to discuss the exact form of publishing aggregated available capacities and the communication format.

Conclusions

• 3rd energy package has brought some more explicit transparency provisions but considerable room for interpretation still remains– Transparency provisions primarily define what information should

be published NOT always who the originator of the information is (e.g. forecasts), which is subject to a subsidiarity principle and needs to be decided at the national level

• GTE+ has attempted to define a common European approach to implementation to ensure consistency and comparability of information

• GTE+ is ready to further work on this issue with all stakeholdersNote: The implementation of the transparency obligations should be considered

along with the implementation of other obligations under both Regulation (EC) 715/2009 and Directive 2009/73/EC.

• Transparency Guidelines to be annexed to Regulation (EC) 1775/2005

State of Play

• Final draft Transparency Guidelines in Commission‘s inter-service consultation

• Comitology procedure to be started in November

• Due to the legal construct for transition between 2nd and 3rd energy package provisions, timeline for the whole process, incl. implementation, is far from clear

• The final draft guidelines‘ transparency requirements are more extensive than originally envisaged in the text presented at MF in May 2009– The implementation of such requirements is likely to call for a

substantial amount of time and money