Update on Transparency Obligations
ENTSOG’s Transparency Workshop
Martin Reisner
Junior Adviser, Transparency
Brussels – 11 September 2012
Content
> CMP
 Background
 Decision
 Transparency
> REMIT
 Background
 Obligations
 Latest activities
> Challenges
2
Congestion Management Procedures I
Background
> Initial proposal from the European Commission in late 2010
> EC Stakeholder Workshops and public consultation during 2011
> Formal comitology process completed during early 2012
 2 Gas Committee meetings held in January and April
> Publication in the Official Journal of the European Union on 24 August 2012 following
decision by both Parliament and Council not to oppose adaption:
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Congestion Management Procedures II
Content of the Commission’s Decision
> ENTSOG has identified 2 parts:
 Procedures intended to mitigate contractual congestion
o Oversubscription / buy-back scheme
o Firm day-ahead use-it-or-lose-it mechanism
o Surrender of contracted capacity
o Long-term use-it-or-lose-it mechanism
 Amending Chapter 3 of Annex I to Regulation (EC) No 715/2009
o Additional information to be published
4
Congestion Management Procedures III
Transparency
> Additional information to be published
 occurrence of unsuccessful, legally valid requests for firm capacity products with a
duration of one month or longer including the number and volume of the
unsuccessful requests
 in the case of auctions, where and when firm capacity products with a duration of
one month or longer have cleared at prices higher than the reserve price
 where and when no firm capacity product with a duration of one month or longer
has been offered in the regular allocation process
 total capacity made available through the application of the congestionmanagement procedures laid down in points 2.2.2, 2.2.3, 2.2.4 and 2.2.5 per
applied congestion-management procedure
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Congestion Management Procedures VI
Transparency
> Information has to by published starting from 1 October 2013…
> …in a downloadable format that has been agreed between transmission system
operators and the national regulatory authorities — on the basis of an opinion on a
harmonized format that shall be provided by the Agency — and that allows for
quantitative analyses…
> …on one Union-wide central platform…
> …established by ENTSOG…
> …on a cost-efficient basis.
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REMIT I
Background
> Regulation of the European Parliament and of the Council on wholesale energy
market integrity and transparency
> REMIT covers trading of commodity and financial instruments for financial and nonfinancial counterparties
> “Market participants” – including transmission operators – are subject to new
reporting obligations regarding commodity trading, e.g. for balancing purposes.
Many reporting obligations also refer to storage and LNG regasification data.
> Due to different interpretation  ACER’s 1st Guidance
 Focusing mainly on electricity
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REMIT II
Obligations for Market Participants
> Reporting of inside information
 What is an inside information?
 How should it be reported and to whom?
> Publication of transparency information
 TSOs: Annex 1 of Reg. 715 (Transparency Guidelines)
 Outages / unplanned maintenance has to be published immediately
 Is balancing energy or fuel gas subject of inside information?
> Public Consultation on ‘Registration Format’
 Registration before participating the market
 Just once at any NRA
 ACER will/can publish a list of market participants
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REMIT III
Latest activities
> Public Consultation on ‘Records of Transactions’
> ENTSOG’s key messages
 Data security
 Avoidance of Double Reporting
 TSOs obligation covered by Reg. 715
> ACER Workshop on 19 July
> Publication of Discussion Paper
 2 Options:
o Disclosure of information through (existing) transparency platform (Reg. 715/714)
o Nomination of platforms for disclosure by NRAs on a regional/national level
> ENTSOG’s response
 TSOs fulfill obligation by publishing information on ENTSOGs Transparency
Platform
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Future Challenges
> All TSO fully publish information according to requirements
> Uncertainties for future development…
 …REMIT
 …other regulations
> Reporting to different entities
 the same set of data
 a different / individual set of data
> Coordination for higher efficiency is needed
 …on a national level
 …of obligations due to different regulations
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Thank You for Your Attention
Do you have further questions?
Martin Reisner
Junior Adviser, Interoperability/Transparency
ENTSOG -- European Network of Transmission System Operators for Gas
Avenue de Cortenbergh 100, B-1000 Brussels
EML: martin.reisner@entsog.eu
WWW: www.entsog.eu