Madrid, 28 th March 2012

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Madrid, 28th March 2012

19th IG Meeting South Gas Regional Initiative

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19th IG meeting SGRI- AgendaI. Opening

I.1 Welcome

I.2 Approval of the agenda and minutes from the last meeting (for approval)

II. Amendments of the Work Plan of the South GRI (for information by NRAs)

III. Capacity Allocation Mechanism harmonisation: CAM in the interconnection Spain-Portugal

III.1 Progress on agreements (for information by NRAs)

III.2 Draft Information Memorandum (for presentation by TSOs)

III.3 Next steps and calendar (for discussion)

IV. Regional Investment Plant in the South Region : Feedback from Stakeholders (for information by NRAs)

V. MIBGAS: Study on cross border tariffs between Portugal and Spain

V.1 Comments received from Stakeholders in the public consultation (for information by NRAs)

V.2 Next steps (for discussion)

VI. Transparency:

VI.1 Public consultation on compliance with Regulation 715/2009: state of the art (for information by Regulators)

VII. AOB and next meetings

VII.1 Meetings calendar (for information by Regulators)

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II. Amendments of the Work Plan of the South GRI

BackgroundIn the XXth Madrid Forum, held on 26-27 September 2011, the Forum encouraged the GRIs to provide greater focus of the prioritization of their work (in particular to work on infrastructure development and on pilot projects testing early implementation of framework guidelines and network codes), as well as to coordinate the Work Plans between the Regions, inviting the lead regulators for each GRI to regularly update their Work Plans.

The South GRI updated its Work Plan 2011-2014:» According to what requested by the Madrid Forum, and following the guidelines

given by the Forum, this SGRI Work Plan 2011-2014 was updated on 28 Feb 2012, and sent it to ACER

» The updated Work Plan is available on ACER’s website

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II. Amendments of the Work Plan of the South GRI The South GRI updated its Work Plan 2011-2014:» Main updates in the Work Plan are referred to:

CAM: last developments were described in the Work Plan. CAM pilot testing is one of the main priorities of all the Regions. In the South Region an auction for allocating the Spanish-Portuguese interconnection capacity by mid 2012 is being developed.

Implementation of a capacity platform. Roadmap to be defined. (ENTSOG volunteer in the last Madrid Forum to take the lead in this subject. NRAs, TSOs and ACER will collaborate to define it, and to work in the different projects, towards full implementation in 2014 )

Transparency project plan: recent developments on the Public Consultation to check operators’ compliance with Regulation 715/2009 requirements were included in the Work Plan.

MIBGAS: information on the interconnections’ tariff study and its Public Consultation was also updated in the Work Plan

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The South GRI updated its Work Plan 2011-2014:» New issues/projects introduced in the Work Plan are:

10YNDP and PCIs: creation of a working group in the region in order to test the PCI identification process, proposed in the draft Regulation.

SoS: the aim is to provide competent authorities on SoS with a forum to update progress on the Regulation 994/2010 implementation, as well as to contribute to the elaboration of the preventive action plans by promoting stakeholders participation in public consultations.

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AGENDA OF THE SGRI WORK PLAN FOR 2011-2014 (I)


Areas of work Responsible Starting Deadline

Capacity allocation mechanisms ()

I.1. OSP France-Spain: annual allocation of short-term capacities TSOs Nov. (yearly) Dec. (yearly)

I.2. CAM harmonisation proposal between Spain and Portugal NRAs-TSOs Jan. 2011 Jun. 2012

I.2. CAM harmonisation proposal in the whole region NRAs-TSOs Jan. 2012 Dec. 2013

I.3. Set up a common TSO Allocation Platform: Roadmap and Implementation TSOs Jul. 2012 Dec. 2014

Congestion management procedures (CMP)II.1. CMP harmonisation proposal between and NRAs-TSOs Jan. 2011 Dec. 2012

II.2. CMP harmonisation proposal between and NRAs-TSOs Jan. 2012 Jan. 2013

Investment in new infrastructure. Ten-Year Network Development Plans and projects of common (European) interestIII.1. Regular update and publication in CEER website of project status of OS 2013 and 2015 TSOs-NRAs Dec. (yearly) Jun. (yearly)

III.2. Drafting of the South Regional Investment Plan 2012 TSOs Jul. 2011 Jan. 2012III.3. Feedback to ENTSO-G on contents and methodology of the regional investment plan NRAs Jan. 2012 Jul. 2012

III.4. Input to ENTSO-G for the Community-wide TYNDP 2013 TSOs Jan. 2012 Jan. 2013III.5. Creation of a working group in the region in order to test the process of PCI identification NRAs -TSOs Mar. 2012 Dec. 2012

III.6. Drafting of the South Regional Investment Plan 2014 TSOs Jan. 2013 Jan. 2014

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AGENDA OF THE SGRI WORK PLAN FOR 2011-2014 (II)


Security of Supply (SoS)

IV.1 Periodically update on progress on Regulation 994/2010 implementation Competent Authorities

Permanent

IV.2 Promotion of market’s participation through public consultations in the development of preventive action plans

NRAs Permanent

BalancingV.1. Contributing to the FG and NC, by raising the regional experience and lessons learned NRAs-TSOs PermanentV.2. Investigation of the use of the gas markets in the region for balancing purposes NRAs-TSOs Jun. 2012 Jun. 2013V.3. Analyse the current configuration of balancing zones and possible merging of certain areas NRAs-TSOs Jan. 2013 Dec. 2013V.4. Pilot project for a common balancing platform in the three countries TSOs Jan. 2014 Dec. 2014

TariffsVI.1. CNE-ERSE joint study on tariff regimes in Spain and Portugal NRAs 2010 Dec. 2011VI.2. CNE-ERSE proposal for tariff harmonization in Spain and Portugal NRAs 2010 Dec. 2012V.I3. Further studies to evaluate the current tariff structures and propose improvements NRAs Jan. 2012 Dec. 2012

InteroperabilityVII.1. Contribute with the regional experience to the development of the FG and the NC NRAs-TSOs PermanentVII.2. Analysis of interoperability aspects and procedures that need to be harmonised among the three countries (in line with the FG-NC)

TSOs Jan. 2013 Jan. 2014

VII.3. In particular, harmonisation of gas day, communication protocols between TSOs, quality standards, programming and nomination schedules, etc.

TSOs Jan. 2014 Dec. 2014

Implementation of the 3rd PackageVII.1. Supervision of compliance with the implementation of the new provisions on transparency in the Regulation 715/2009/CE, for transmission, LNG and storage infrastructure operators

NRAs Sep. 2011 Jun.. 2012

Developing hub-to-hub trading in the South region

IX.1. Hub developmentNRAs-TSOs-stakeholders

Jan.2013 Dec. 2013

IX.2. Hub-to-hub gas trading in the regionNRAs-TSOs-stakeholders

Jan.2014 Dec. 2014

Areas of work Responsible Starting Deadline

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III. Capacity Allocation Mechanism Harmonization

Area of work Responsible

Starting

Deadline

CAM harmonisation proposal between Spain and Portugal

NRAs-TSOs Jan. 2011 Jun. 2012

III.1 Progress on agreements (information by NRAs)

III.2 Draft Information Memorandum (presentation by TSOs)

III.3 Next steps and calendar

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III.1 CAM at Spanish-Portuguese interconnections. Progress on agreements

With regard to the CAM procedure proposed by TSOs to be applied at the Sp-Pt border, the following principles have been agreed:

Mechanism• At least, yearly coordinated auctions to sell available capacity (monthly products) at

Badajoz and Tuy. • Possibility to develop monthly auctions to sell the remaining available capacity, if any, with

weekly products, including the capacity freed up after CMP application.

Capacity and product definition• Capacity to be sold in a single virtual point aggregating the current physical available

capacity at the two interconnection points.• Firm capacity to be maximised. If there is capacity that is subjected to operational restrictions,

it can be sold as interruptible. Therefore, two products can be offered to the market.• Bundled capacity: the same capacity will be allocated on both sides of the border to the

same company.

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III.1 CAM at Spanish-Portuguese interconnections. Progress on agreements

Allocation procedureCleared price auctions with a single round. During the bidding window, shippers will submit requests for a number of price steps for each capacity product they want during a number of days. During this period shippers will be allowed to submit bids and to withdraw or modify bids previously submitted. At the end of each day, TSOs will publish the aggregated results of the bidding period. No provisional interim allocations will be performed at the end of each bidding day. Capacity will be allocated only after the final bidding window closes.

Price• The reserve price will be the regulated tariff. Interruptible contracts should have a lower

reserve price (calculated taking into account the probability of interruption).•

• The final price will be the one fully covering the capacity offer. • Marginal pricing for each capacity product shall be used.• Premium over the regulated tariff will be 50/50 shared between TSOs.

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III.1 CAM at Spanish-Portuguese interconnections Progress on agreements

Gas year/day• Gas year: From October year n to September year n+1 (according to ENTSOG’s CAM NC)• Gas day (GMT in Portugal and GMT+1 in Spain): from 00:00 to 24:00

Units• kWh/day

Application• First application in June 2012Comments received from stakeholders (1 answer)• In favour of being able to contract flat capacity for the 12 months and also to have the

possibility to contract weekly capacity• Supporting the virtual point and the offer of interruptible capacity (sufficient information

on this product to be provided)• Not in favour of oversubscription• The respond expresses the preference for an auction with multiple rounds• The respond asks for a better definition of the price to be paid by users (a fix price

versus a fix premium over the regulated tariff in force every gas year)

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III.2 CAM at Spanish-Portuguese interconnections Draft Information Memorandum

(Information by TSOs)

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III.3 CAM at Spanish-Portuguese interconnections Next steps and calendar

» TSOs to provide Information Memorandum by 20th April• Allocation Rules• Price steps, reserve price, premium and price definition for firm and

interruptible capacity• Firm and interruptible capacity in the virtual point• Capacity request: Application form• Letter of commitment• Contract information• Non disclosure agreement

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III.3 CAM at Spanish-Portuguese interconnections Next steps and calendar

» Regulators’ comments on the Information Memorandum Draft: before end of April

» Draft amendment by TSOs: mid May

» Presentation of the Information Memorandum to Stakeholders: before end of May (SG programmed for 6th June to be held at the end of May)

» CAM pilot testing project launch: June 2012

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IV. Regional Investment Plan in the South Region (GRIP)


Starting Deadline

Feedback to ENTSO-G on contents and methodology of the regional investment plan

NRAs Jan. 2012 Jul. 2012

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IV Regional Investment Plan in the South Region Feedback from Stakeholders

» Public Consultation of the GRIP was launched in the last SG meeting of the South Region (7 February 2012)

» One response received (from a shipper):General comments

Efforts made by TSOs are very welcome, since the GRIP provides a framework for a coordinated infrastructure development in the Region

The shipper agrees on the great importance of providing appropriate interconnection capacity between countries

However, any investment must be suitably justified, which is not the case of the projects included in the GRIP:

New interconnection pipeline between Spain and Portugal: Both countries have enough interconnection capacity with regard to Portuguese demand

New Iberian Peninsula-France corridor: Open Season procedures developed in the SGRI provide significant interconnection capacity

A deeper analysis of the projects, as well as a solution for the required financing, are recommended

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The need for interconnection capacity Reasons provided on the need for more interconnection capacities are qualitative and

general, there’s no analysis on the necessary economic funds, cost/benefit, synergies, etc.

Physical congestions mentioned in the document are not explainedDemand

Demand forecast (1,8% annually) is overestimated, not based in real data The shipper considers that demand for power generation will not be increased in Spain

and France, due to the fact that power already installed in these countries is sufficientSpain-French new interconnection

Some reinforcements to increase interconnection capacity are not coherent with those included in the Spanish Central Plan 2012-2020 presented in 2011

No cost/benefit analysis; how to recover costs in a way that does not hamper international trade between the countries should be indicated

Spain-Portuguese new interconnection Information on booked and available capacity between these two countries which

justifies the need for a new interconnection is not complete, since no information of utilisation is provided. Congestion may be only contractual and not physical

Demand forecast too optimistic: TSOs estimate raises in spite of the crisis scenario Again, the project is not accompanied by an cost/benefit analysis

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Transmission tariff increaseThe shipper does not agree on the consideration that the new investment cost will add no significant cost to tariffs. The shipper considers important to remind that TPA tariffs have been considerably increased in the last years, and that traders’ margins are low.

Peak demand and average demandThe interconnections shouldn’t be designed to support peak demand, since security of supply is a national issue, which should be considered by the national regulation and planning.However, in the GRIP, decided capacity is undervalued compared with 2020 average demand (interconnection will be sufficient to cover 20% of Spanish gas demand) .

Security of supplyThe scenarios considered to assess the risk of disruption are incomplete, since probability of happening is not described. No other solution, rather than building the mentioned new interconnections, is analysed.

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NRAs will issue their opinion on the GRIP in the next months

IV Regional Investment Plan in the South Region Next steps and calendar

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V. MIBGAS

V.1 Comments received from Stakeholders in the public consultation


Starting

Deadline

CNE-ERSE joint study on tariff regimes in Spain and Portugal

NRAs 2010 Dec. 2011

CNE-ERSE proposal for tariff harmonization in Spain and Portugal NRAs 2010 Dec. 2012

Further studies to evaluate the current tariff structures and propose improvements

NRAs Jan. 2012 Dec. 2012

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V.1 Comments received from Stakeholders in the public consultationonsulta Pública sobre harmonização das tarifas de interligação de gás natural entre Portugal e Espanha

Participants: 16 agents TSOs Shippers / suppliers Industry associations

Denotes the Iberian/wholesale level discussion

Very good participation from stakeholders (have in mind the set of major public consultations at the same time in Europe)

Positive contributions into finding the solutions!

Note: the comments are shown as they were sent, thus they may present inconsistencies and divergences

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Consulta Pública sobre harmonização das tarifas de interligação de gás natural entre Portugal e EspanhaSummary of answers | Q1 (i)

Stakeholders welcomed the regulators’ overview of the Iberian transmission systems and its present regulatory framework• Good first step into a more integrated Iberian gas market

General agreement on the results• Results of the case studies are correct• There is a cost for transporting gas across the border• Cross border payments result from adding transmission tariffs at the IPs• General support for the initiative of removing unjustified cost barriers at the

border• Eliminating tariff pancaking at cross border IPs could help the integration of

markets

Question 1: Would you agree with the analysis made on current market situation and on the major issues affecting cross border trade between Portugal and Spain?

Q1 Q2 Q3 Q4 Q5

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Consulta Pública sobre harmonização das tarifas de interligação de gás natural entre Portugal e EspanhaSummary of answers | Q1 (ii)

More issues should be included in the analysis• Different load profiles and suppliers of smaller size (new entrants)• Balancing costs• Capacity Reservation• CBTs are not the only problem, regulatory framework harmonization should

include other infrastructures and activities• Regulated gas swaps at LNG storage in PT• Conditions of access to the Portuguese Gas System (to transmission and

LNG terminal)

Disagreement on concepts• Cross Border tariffs do not necessarily involve Pancaking• Double tariff is possible without distorting cost reflectiveness

Question 1: Would you agree with the analysis made on current market situation and on the major issues affecting cross border trade between Portugal and Spain?

Q1 Q2 Q3 Q4 Q5

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European regulatory framework• First step of any change in the present Iberian regulatory framework must be

the transposition of the European Directives and Regulations• “Soon” to be approved network codes must also be adopted

CB tariffs should result from general entry-exit transmission tariff methodology• They should signal costs and physical constraints • In SP, transmission and distribution tariffs should be separated to achieve a

better cost allocation• Cost and tariff additivity should be applied in SP• Cross subsidies between activities and between PT and SP must be avoided• Each country’s transmission costs must be recovered• Security of supply costs (over capacity) should be covered by exit tariffs to

consumers

Question 2: How do you think that transmission network costs should be allocated at cross border IP (both in Spain and Portugal), taking into account the defined principles (coherence, transparency, cost recovery and cost reflectiveness, etc) and the starting situation of the regulatory tariff framework in both countries?

Q1 Q2 Q3 Q4 Q5

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Tariff structure harmonization• Tariff methodology and capacity/commodity split• Price definitions (e.g. reserved capacity vs past 12M max)• Treatment of backhaul flows• Elimination of tariff discounts

Other issues to harmonize• Balancing• Capacity Allocation Mechanisms • Congestion Management Procedures• Available information to market agents• Access Conditions


Q1 Q2 Q3 Q4 Q5

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Consulta Pública sobre harmonização das tarifas de interligação de gás natural entre Portugal e EspanhaSummary of answers | Q2 (iii)

Cost transfer away from CBT• CB tariff could be reduced by transferring costs to entry points of MIBGAS

and lowering exits to customers in the exporting country This transference should be established in both countries under the same

objectives and transparent principles. Need to avoid cross-subsidies between systems, detrimental to national users of

one of the countries

• Inter TSO compensation schemes do not signal costs to network users• Other comments suggest a compensation mechanism between TSO and the

creation of a single Iberian entry-exit zone

Long term view of the CBT• Some comments propose the removal of CBT between PT&SP (e.g. electric)• Others propose that CBT should be kept


Q1 Q2 Q3 Q4 Q5

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Priorities of S-GRI WP2011-14 were confirmed• Transposition of EU Directives and Regulations into national law• Harmonization of CAM and CMP at the IP• Harmonization of balancing rules and incentives• Regional investment planning• Implementation of common operating license for market agents

Other topics were mentioned with detail proposals• Reduction of cross border tariff costs• Extend harmonized CAM to other capacity products (longer term) and apply

long term cap. booking at PT side to make possible to implement NC• Single point of nomination for the IPs• Harmonization of capacity payments (annual reserve vs past 12M max)• Improvement of information to market agents on their balancing status, in PT

Question 3: Which do you feel are the most important aspects where harmonization (apart from the cross border tariffs harmonization) can contribute significantly to short term market integration?

Q1 Q2 Q3 Q4 Q5

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Some issues would require a longer time frame• Adoption of harmonized mechanisms for investment decisions (Open

Seasons)• Increase operational reserves for system management by TSO• Creation of a single Virtual IP between PT&SP• Harmonization of security of supply obligations• Single Iberian balancing zone• Common communication protocols and data formats for TSO

Question 3: Which do you feel are the most important aspects where harmonization (apart from the cross border tariffs harmonization) can contribute significantly to short term market integration?

Q1 Q2 Q3 Q4 Q5

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Question 4: How would you implement the proposed step-wise approach, aiming for a more integrated market in the longer term?

Q1 Q2 Q3 Q4 Q5

Agents proposed different steps, final targets and implementation speeds

Strategies can be arranged in several types:• A: the most conservative. Ends w/ harmonization of CAM, CMP and tariff principals.• B: Also conservative. Includes the proposal of reducing CB tariffs.• C: Includes CB tariff elimination in the long term and one Iberian hub.• D: The more forward looking strategies include the merger of the 2 Iberian balancing

areas and entry-exit zones. This strategy, though ambitious, proposes small incremental steps.

• E: Ambitious goals and fast moving.

Until the second step, all comments agree

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Proposed road map A B C D E

EU Gas Dir.& Regs. transposition

New tariff system in SP and improvement in PT tariffsDecoupled E-E tariff system, Additive tariffsNo cross subs, transparent cost allocation; Tariff sufficiency

Harmonize CAM & CMPHarmonize Balancing rules (Network Codes)Transitory market-making measures

Reduce CB Tariffs (ITC, cost transf. to entries, discounts)

CB tariff elimination (no economic border)

VIP between PT&SP

Single HUB w/ 2 balancing zones (1 EE zone)

Single balancing zone, single EE area

Question 4: How would you implement the proposed step-wise approach, aiming for a more integrated market in the longer term?

1 11 11

2 2

2 2

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4 3

3

Different strategies proposed

Q1 Q2 Q3 Q4 Q5

2

2

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Operational level improvements• Common access platform to manage cross border trade• Harmonization of data formats and communication processes• Harmonization of nomination and confirmation process and schedule• Netting of imbalances for shippers in the 2 balancing areas• Operating the IP as a virtual point• Deal with electricity / gas markets interactions• Joint management of underground storage SP-PT and equal tariffs (w/ inter-

SSO compensation mechanism)

Security of supply• Separate “efficient” cost level from extra costs driven by SoS objectives• How to look at SoS in an integrated Iberian market perspective• Possibility to locate strategic gas reserves in the Iberian space

Question 5: Would you identify new issues you think are important to create a favorable cross border trade environment? How would you set the timing and prioritization for the discussion on these issues?

Q1 Q2 Q3 Q4 Q5

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Higher role for TSO activities• Providing more flexibility options to market agents• TSO working together to provide balancing services to shippers• Maximizing cross border capacity availability (e.g. oversubscription &

buyback)• Pushing for operational arrangements and balancing actions to facilitate gas

contracting in a virtual environment

Compatibility of the existing long term contracts (transit)• Conciliate existing contracts with the new harmonized rules, respecting their

legal terms and EU Dirs&Regs• More transparent data on LT booked capacity usage• Anti-hoarding provisions


Q1 Q2 Q3 Q4 Q5

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Consulta Pública sobre harmonização das tarifas de interligação de gás natural entre Portugal e EspanhaSummary of answers | Q5 (iii)

Long term capacity booking framework• Keep long term capacity contract at transmission infrastructures: efficient

cost signal, operative advantages, revenue stability, matches EU codes• Make LT contracts binding for TSO and shippers• Promote secondary capacity trading

HUB development• For wholesale market and balancing market purposes• Organized spot market development• Single balancing point

Extend good practices to higher goals• Tariff harmonization in the border FR-SP


Q1 Q2 Q3 Q4 Q5

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Consulta Pública sobre harmonização das tarifas de interligação de gás natural entre Portugal e EspanhaSummary of answers | Other issues (i)

Good practices on public consultation procedures• Hearing should give at least 8 weeks for comments

Trade off between costs and benefits of market integration• Investments linked to market integration should be compared against

increased competition benefits

CEER Gas Target Model interactions• NRAs shall develop an analysis on “market functioning” and propose

measures to achieve market integration and good market functioning by 2014

• CBT Public Hearing could set the grounds for this analysis

Other issues raised in the public hearing

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Approve and publish the document reviewing and analysing the

comments received [deliverable VI.2 SGRI WP]

CNE-ERSE proposal for tariff harmonization in SP and PT [deliverable VI.2 SGRI WP]

Identify the priorities in MIBGAS market integration process, in particular concerning Cross Border tariff, CAM and CMP harmonization [deliverable VI.3 SGRI WP]

Start implementing small, concrete, steps for an harmonized tariff framework, following closely the European network codes in progress

Opportunities are there in PT (gas codes revision during 2012) and SP (EU Gas Dir. transposition)

Carry on discussions within the SGRI framework and keep stakeholder involvement and updating

V.2 MIBGAS. Next steps (I)

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V.2 MIBGAS. Next steps (II)

Publication of results of the Public Consultation

Amendment of the Study on transit tariffs according to Stakeholders’ document: before end of July

Regulators to analyse possible regulatory changes to facilitate trade between Spain and Portugal: before end of 2012

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VI. Transparency

Public Consultation on compliance with Regulation 715/2009: state of the art

Area of work Responsib

leStartin

gDeadlin

eSupervision of compliance with the implementation of the new provisions on transparency in the Regulation 715/2009/CE, for transmission, LNG and storage infrastructure operators

NRAs Sep. 2011 Jun. 2012

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1) Survey Procedure • Following steps taken by the North region, but extending the approach to LSOs

and SSOs.

• Questionnaires were sent on 2nd December 2011 to all operators in the Region: PT: 1 TSO, 1 LSO, 2 SSO / FR: 2 TSO, 2 LSO, 2 SSO / SP: 2 TSO, 4 LSO, 1 SSO

• Deadline to answer: 15thJanuary 2012.

• Mail reminder was sent on January16th.

• All operators have filled out the questionnaires.

• Regulators contacted TSOs, LSOs and SSOs to clarify misunderstanding according to preliminary assessment made by NRAs.

• Public Consultation has been launched on ACER’s website and it is ongoing until April 20th.

• Preliminary findings were presented at the Madrid Forum on last March 21st by ACER.

VI.1 Public Consultation on compliance with Regulation 715/2009: state of the art

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2) TSOs’ transparency: preliminary assessment• According to questionnaires sent by the TSOs, the preliminary assessment

shows, in general, a high level of compliance with Regulation 715/2009.

Good level of compliance with provisions on:

Gas system descriptionService description and contracting

processUsed CAM and CMPNomination and matching proceduresBalancing rules and imbalance chargesSecondary markets

Some room for improvement on:

Clarity of services’ price Flexibility and tolerances levels Participation in secondary marketsHistorical dataForm of publication (English)


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3) TSOs’ transparency: preliminary conclusions (I)

• Some non-compliances are currently being implemented.

• There are some misunderstandings among TSOs about some transparency requirements (i.e., requirements that are considered “not applicable” because they do not offer the service).

• There’s information not published directly by the TSOs but by other market’s agents. This difficult y is easy to overcome with links.

• Compliance with some obligations requires the modification of national legislation. This specifically refers to the need to publish data in units that use a combustion temperature of reference of 298,15 K. The change of reference temperature would have a considerable impact on others national processes (i.e., measurement processes, invoicing, etc.), so it must be analysed very carefully. This has been solved by providing a conversion factor.


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3) TSOs’ transparency: preliminary conclusions (II)

TSO1 TSO2 TSO3 TSO4 TSO50%

20%

40%

60%

80%

100%

Yes/Data published by TSO or by other market agent Not applicable

No/ Data not published

• On average, 86% of requirements met

• Three of five TSOs above 90%

• The lowest, more than 60%


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4) LSOs and SSOs’ transparency: preliminary assessment

• According to questionnaires sent by the LSOs and SSOs, the preliminary assessment shows, in general, a high level of compliance with Regulation 715/2009.

Good level of compliance with provisions on:

Service descriptionContracted and available storage facility

capacityUse and availability of third-party access

servicesForm of publication

Some room for improvement on:

Data related to amount of gas, inflows, outflows, available storage capacity and tariffs are being published by other market agents


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• There are some misunderstandings

among LSOs about some transparency requirements (i.e., requirements that are considered “not applicable”).

• There’s information not published directly by the LSOs but by TSO. This difficult is easy to overcome with links to TSOs’ website.

• 100% of requirements met (*).

LSO1 LSO2 LSO3 LSO4 LSO5 LSO6 LSO70%

10%20%30%40%50%60%70%80%90%

100%

Yes/Data published by TSO or by other market agent

Not applicable


5) LSOs transparency: preliminary conclusions

(*) taking into account that some requirements are complied providing, in LSO’ web, the relevant link to the market agent’ web where information is published.

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• There are some misunderstandings among SSOs about some transparency requirements (i.e., requirements that are considered “not applicable”).

• There’s information not published directly by the SSOs but by TSO. This difficult is easy to overcome with links to TSOs’ website.

• 100% of requirements met (*).

6) SSOs transparency: preliminary conclusions

SSO1 SSO2 SSO3 SSO4 SSO50%

10%20%30%40%50%60%70%80%90%

100%

Yes/Data published by TSO or by other market agent

Not applicable


(*) taking into account that some requirements are complied providing, in SSO’ web, the relevant link to the market agent’ web where information is published.


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7) Public Consultationhttp://www.acer.europa.eu/portal/page/portal/ACER_HOME/Activities/Regional_Initiatives/

Gas_Regional_Initiatives/South/Public%20Consultation/Public_Consultation_on_Transparency

• Invitation letter to stakeholders – welcome their views on:

Quality , consistency, frequency and availability of the information.

Responses accurately reflect the public information.

User-friendly, available free of charge, without subscription, free of register.

Close to real time, a soon as it is available to the TSO.

In a meaningful, quantifiably clear and easily accessible way, non-discriminatory basis.

In a time-frame compatible with the facility users’ reasonable commercial needs.

• Summary tables of the Preliminary findings prepared by NRAs.

• Fully access to all operators’ questionnaires.

• Comments to be received until 20th April to [email protected] and [email protected]


mailto:[email protected]

mailto:[email protected]

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8) Next steps

• Public Consultation will be closed on 20 April.

• Regulators to study the comments received from stakeholders.

• Regulators to keep contact with operators to communicate Stakeholders’ responses.

• Proposal of work to be done to improve the compliance on transparency.


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VII. AOB and next meetings

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JULYM Tu W Th F Sat Sun

12 3 4 5 6 7 89 10 11 12 13 14 15

16 17 18 19 20 21 2223 24 25 26 27 28 2930 31

NEXT MEETING: 16th SG MEETING is proposed 29th or 30th MAY. To be decided

IG meeting Green Spanish Bank HolidaySG meeting Purple Portuguese Bank HolidayDeadlines Blue French Bank Holiday

JANUARY FEBRUARY MARCHM Tu W Th F Sat Sun M Tu W Th F Sat Sun M Tu W Th F Sat Sun

1 1 2 3 4 5 1 2 3 42 3 4 5 6 7 8 6 7 8 9 10 11 12 5 6 7 8 9 10 119 10 11 12 13 14 15 13 14 15 16 17 18 19 12 13 14 15 16 17 18

16 17 18 19 20 21 22 20 21 22 23 24 25 26 19 20 21 22 23 24 2523 24 25 26 27 28 29 27 28 29 26 27 28 29 30 3130 31

APRIL MAY JUNEM Tu W Th F Sat Sun M Tu W Th F Sat Sun M Tu W Th F Sat Sun

1 1 2 3 4 5 6 1 2 32 3 4 5 6 7 8 7 8 9 10 11 12 13 4 5 6 7 8 9 109 10 11 12 13 14 15 14 15 16 17 18 19 20 11 12 13 14 15 16 17

16 17 18 19 20 21 22 21 22 23 24 25 26 27 18 19 20 21 22 23 2423 24 25 26 27 28 29 28 29 30 31 25 26 27 28 29 3030

J uly deadlines3.2 Feedback to ENTSOG on metodology of GRIP

J anuary deadlines1.2 CAM proposal Pt- Sp2.1 CMP proposal Fr- Sp3.1 SGRIP draft

June deadlines3.4 Regulation 994/2010 SoSimplementation in SGRI

Allocation Cap. Sp-Pt

VII.1 Meetings calendar

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ANNEX: Transparency

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TSOs’ Transparency (I)

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Art. Annex 1

chapter 3 TSO Transparency requirement PORTUGAL FRANCE SPAIN

REN GRT TIGF ENAGAS NATURGAS

3.1.2.k) Do you publish information on emergency mechanisms, as far as it is the responsibility of the transmission system operator, s uch as measures that can lead to the disconnection of customers groups and other general liability rules that apply to the TSO?

3.1.2.l)

Do you publish

procedures agreed upon by transmission system operators at interconnection points, of relevance for access of network users to the transmission systems concerned, relating to interoperability of the network,

agreed procedures on nomination and matching procedures and

other agreed procedures that set out provisions in relation to gas flow allocations and balancing, including the methods used ?

3.1.2.m) Do you publish a detailed and comprehensive description of the methodology and process, including information on the paramete rs employed and the key assumptions, used to calculate the technical capacity?

3.1.1. Form of publication:

3.1.1.1.

Do you publish the information referred to under paragraph 3.1.2. in the following manner:

(a) on a website accessible to the public, free of charge and without any need to register or otherwise sign on with the TSO;

(b) on a regular/rolling basis; the frequency shall be according to the changes that take place and the duration of the servic e;

(c) in a user-friendly manner;

(d) in a clear, quantifiable, easily accessible way and on a non-discriminatory basis;

(e) in downloadable format that allows for quantitative analyses;

(f) in consistent units, in particular kWh (with a combustion reference temperature of 298,15 K) shall be the unit for energy content and m 3 (at 273,15 K and 1,01325 bar) shall be the unit for volume. The constant conversion factor to energy content shall be provided. In addition to the format above, publication in other units is also possible;

(g) in the official languages of the member State and (g) in English

3.1.1.2. Do you provide details on actual changes to all information referred to under paragraph 3.1.2 in a timely manner as soon as a vailable to you?

3.3 Information to be published at all relevant points and the time schedule according to which this information should be published

3.3.1., 3.3.2. and 3.3.3.

Do you publish at all relevant points the following information for all services and ancillary services provided: (a) the technical capacity for flows in both directions; Is this information published on a numerical basis? Is this information in hourly or daily periods, equal to the smallest reference period? Is this information and updates published as soon as available to you (“near real time”)? Is this information published for a period of at least 18 months ahead? Do you publish historical information on the technical capacity for flows in both directions for the past five years on a rolling basis? Is information for single final customers and for production facilities, that is excluded from the definition of relevant poi nts as described under 3.2 (1)(a) published in aggregate format at least per balancing zone. The aggregation of single final customers and of production facilities, excluded from the definition of relevant points as described under 3.2 (1)(a), shall for the applic ation of this annex be considered one relevant point.

TSOs’ Transparency (II)

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Art. Annex 1



TSOs’ Transparency (III)

53

3.3.4.

Do you publish measured values of the gross calorific value or the Wobbe index at all relevant points, on a daily basis?

Do you publish preliminary figures at the latest 3 days following the respective gas day?

Do you publish final figures within 3 months after the end of the respective month?

3.3.5.

Do you publish for all relevant points, available capacities, booked and technical capacities, on an annual basis over all years where capacity is contracted plus 1 year, and at least for the next 10 years. Is this information updated at least every month or more frequently, if new information becomes available? Does the publication reflect the period for which capacity is offered to the market?

3.1.1.1.

Do you publish the information referred to under paragraph 3.3(1) to 3.3(5) in the following manner: (a) on a website accessible to the public, free of charge and without any need to register or otherwise sign on with the transmission system operator;

(b) on a regular/rolling basis; the frequency shall be according to the changes that take place and the duration of the service;

(c) in a user-friendly manner; (d) in a clear, quantifiable, easily accessible way and on a non-discriminatory basis; (e) in downloadable format that allows for quantitative analyses; (f) in consistent units, in particular kWh (with a combustion reference temperature of 298,15 K) shall be the unit for energy content and m 3 (at 273,15 K and 1,01325 bar) shall be the unit for volume. The constant conversion factor to energy content shall be provided. In addition to the format above, publication in other units is also possible;

(g) in the official languages of the member State and (g) in English

3.1.1.2. Do you provide details on actual changes to all information referred to under paragraph 3.3(1) to 3.3(5) in a timely manner as soon as available to you?

3.4 Information to be published regarding the transmission system and the time schedule according to which this information should be published

3.4.1.

Do you publish on a daily basis and updated every day the following specifications re. the aggregated amounts of capacities offered, and contracted on the secondary market (i.e. sold from one network user to another network user), where the information is available to you:

(a) interconnection point where the capacity is sold; (b) type of capacity, i.e. entry, exit, firm, interruptible; (c) quantity and duration of the capacity usage rights; (d) type of sale, e.g. transfer or assignment; (e) the total number of trades/transfers; (f) any other conditions known to the transmission system operator as mentioned in 3.3. Is this information provided by a third party?

Art. Annex 1



TSOs’ Transparency (IV)

54

3.4.2.

Do you publish the following specifications re. harmonised conditions under which capacity transactions (e.g. transfers and assignments) will be accepted:

(a) a description of standardised products which can be sold on the secondary market; (b) lead time for the implementation/acceptation/registration of secondary trades. In case of delays the reasons have to be published;

(c) the notification to the transmission system operator by the seller or the third party as referred to under 3.4(1) about name of seller and buyer and capacity specifications as outlined in 3.4(1).

I s this information provided by a third party?

3.4.3.

Regarding the balancing service of your system, do you provide to each network user, for each balancing period, its specific preliminary imbalance volumes and cost data per individual network user, at the latest 1 month after the end of the balancing period?

Do you provide final data of customers supplied according to standardised load profiles within 14 months later? Do you respect confidentiality of commercially sensitive information while providing this information? I s this information provided by a third party?

3.4.4.

Do you offer flexibility services, other than tolerances, for third party access? I f you do, do you publish daily forecasts on a day-ahead basis of the maximum amount of flexibility, the booked level of flexibility and the availability of flexibility for the market for the next gas day?

Do you also publish ex-post information on the aggregate utilisation of every flexibility service at the end of each gas day?

3.4.5.

(5) Do you publish, per balancing zone: the amount of gas in the transmission system at the start of each gas day and the forecast of the amount of gas in the transmission system at the end of each gas day? Do you publish the amount of gas in the transmission system on an hourly basis? Do you update the forecast amount of gas for the end of the gas day on an hourly basis throughout the gas day? Alternatively, do you publish, per balancing zone the aggregate imbalance position of all users at the start of each balancing period and the forecast of the aggregated imbalance position of all users at the end of each gas day?

3.4.6. Do you provide user-friendly instruments for calculating tariffs?

Art. Annex 1



TSOs’ Transparency (V)

55

Art. LSO’ Transparency requirement

PORTUGAL FRANCE SPAIN

REN ELENGY FOS CAVAOU ENAGAS BBG SAGGAS REGANOSA

19. Transparency requirements concerning storage facilities and LNG facilities

19.1

Do you publish a detailed information regarding the services you offer?

Do you publish a detailed information regarding the relevant conditions applied for these services?

Do you publish the technical information necessary for LNG facili ty users to gain effective access to the LNG facility?

19.2 For the services provided, do you publish information on contracted and available LNG facility capacity on a numerical basis on a regular rolling basis and in user-friendly standarised manner?

19.3 Do you disclose the information required by this Regulation in a meaningful, quantifiably clear and easily accesible way and on a non-discriminatory basis?

19.4

Do you publish the amount of gas in each storage facility, or group of storage facilities if that corresponds to the way in which the access is offered to system users?

Do you publish the inflows and outflows, and the available LNG facility capacity, including for those facilities exempted from third-party access?

Is this information communicated to the TSO?

Is this information updated at least daily?

19.5 Do you publish sufficiently detailed information on tariff derivation, the metodologies and the structure of tariffs for infraestructure under regulated third-party access?

15. Third-party access services concerning storage and LNG facilities

15.1 c) Do you publish data on the use and availability of services you offer, in a time-frame compatible with the LNG facility users´reasonable commercial needs?

20. Record keeping by system operators

Do you keep at the disposal of the national authority, including the national regulatory authority, the national competition authority and the Comission, all information referred in Article 19 for a period of 5 years?

LSOs’ Transparency

56

Art. SSO’ Transparency requirement PORTUGAL FRANCE SPAI N

REN GALP STORENGY TI GF ENAGAS

19. Transparency requirements concerning storage facilities and LNG facilities

19.1

Do you publish a detailed information regarding the services you offer?

Do you publish a detailed information regarding the relevant conditions applied for these services?

Do you publish the technical information necessary for storage facility users to gain effective access to the storage facility?

19.2 For the services provided, do you publish information on contracted and available storage facility capacity on a numerical basis on a regular rolling basis and in user-friendly standarised manner?

19.3 Do you disclose the information required by this Regulation in a meaningful, quantifiably clear and easily accesible way and on a non-discriminatory basis?

19.4

Do you publish the amount of gas in each storage facility, or group of storage facilities if that corresponds to the way in which the access is offered to system users?

Do you publish the inflows and outflows, and the available storage capacity, including for those facilities exempted from third-party access?

I s this information communicated to the TSO? I s this information updated at least daily?

19.5 Do you publish sufficiently detailed information on tariff derivation, the metodologies and the structure of tariffs for infraestructure under regulated third-party access?

15. Third-party access services concerning storage and LNG facilities

15.1 c) Do you publish data on the use and availability of services you offer, in a time-frame compatible with the storage facility users´ reasonable commercial needs?

20. Record keeping by system operators

Do you keep at the disposal of the national authority, including the national regulatory authority, the national competition authority and the Comission, all information referred in Article 19 for a period of 5 years?

SSOs’ Transparency

Madrid, 28 th March 2012

Documents

Transcript of Madrid, 28 th March 2012