Transcript Presented Materials

Network Code Interoperability and
Data Exchange Rules
Consultation Workshop
Brussels – 20 Mar 2013
Network Code Interoperability and
Data Exchange Rules
Consultation Workshop
WELCOME….
Brussels – 20 Mar 2013
Network Code Interoperability and
Data Exchange Rules
Consultation Workshop
Panagiotis Panousos
Business Area Manager, System Operation
Brussels – 20 Mar 2013
Introduction
>
Welcome!!!
>
Participants through webcasting to identify themselves
>
Objective: support stakeholders to develop their consultation response
>
How will this be achieved:
 by understanding explanatory presentations
 by listening to other involved parties’ views
 by participating in discussion
4
Half way to network code delivery
>
It’s been quite intensive…
 project plan,
 kick-off,
 launch documentation,
 stakeholder joint working
sessions,
 prime mover meetings,
 bilateral / trilateral
meetings,
 internal consultation,
 business rules
>
Draft NC + Supporting Document
5
The challenge
>
Consultations / discussions
>
>
Internal processes
…but we have to prove we are a “fair
partner to all”
6
Our hope?
Manage to reach a common agreement within the one year!
7
Structure of event
>
Our view:
 What is in the NC
 How legal text can be
interpreted
>
Regulator’s view:
 Is the NC in line with
the FG?
>
Stakeholders’ view:
 Does NC meet
expectations?
>
Commission comments
8
Thank You for Your Attention
Panagiotis Panousos
Business Area Manager, System Operation
ENTSOG -- European Network of Transmission System Operators for Gas
Avenue de Cortenbergh 100, B-1000 Brussels
EML: [email protected]
WWW: www.entsog.eu
Network Code Interoperability and
Data Exchange Rules
Consultation Workshop
Interoperability Team
Brussels – 20 March 2013
NC development process: actual state
Stakeholder involvement
Prime Mover: 5 (OGP, EFET, GIE, CEDEC)
Active SJWS participant: 19
Consultation Respondent: 8 + Observers: 5)
Invitation
Publication Launch
letter EC Kick-off WS Documentation
11/9
13/9
Publication
project plan
09/10
26/9
2/10
11/10
Prime Mover
meetings
07/11
20/11
05/12
24/01
12/03
MF presentation
NC INT End consultation project
plan:
37 responses with general
support
14/11
28/11
11/12
SJWS
Trilateral
meetings
EC/ACER
30/10
29/11
14/12
24/01
11/02
Development of
draft NC
Dec‘12-Feb‘13
28/02/13
Public
Consultation
11
NC Development Process: actual state
DRAFT NETWORK CODE
> Developed by INT team in close cooperation with INT KG/WG and legal
advisers taking into account:
 External Stakeholders: SJWS/Prime Movers/Bilateral meetings
 EC + ACER
 ENTSOG Members: internal consultation
 Input WG CAP + WG BAL: compatibility with other NCs
SUPPORTING DOCUMENT
> Policy options + clarification chosen options
> Questions for Public Consultation (32); DEADLINE: 26 April
> On-line response form with 3 possibilities:
YES
YES with minor comments
NO
12
NC Development Process: next steps
Stakeholder engagement
ENTSOG Member work
Sep 2012
Oct
Project planning and launch
Kick-Off
Nov
Dec
Jan
Interactive draft network code
development
SJWS
SJWS
SJWS
Workshop
Workshop
Workshop
Conclusion WS: 28 May
Workshop
Apr
May
Network Code refinement
Jun
Stakeholder support process
Jul
Aug
Sep 2013
SJWS 1: 14 Nov
SJWS 2: 28 Nov
SJWS 3: 11 Dec
Consultation (2 Months)
Consultation WS: 20 Mar
Third Countries WS 16 Apr
Data Exchange WS: 23 Apr
Feb
Mar
Consultation (1 Month)
Kick-Off WS: 26 Sep
Network Code finalisation
13
NC Interoperability and Data Exchange: Content
General Provisions/Final Provisions
Interconnection Agreements
Units
Gas Quality
Odourisation
Data Exchange
Dispute Resolution
14
NC Interoperability and Data Exchange: Content
I/VIII General and Final Provisions
Subject Matter
Interconnection Agreements
II
III Units
IV Gas Quality
V
Odourisation
Scope
Definitions
Implementation
VI Data Exchange
VII Dispute Resolution
Entry into force
15
NC Interoperability and Data Exchange
I/VIII General and Final Provisions
II
III Units
IV Gas Quality
Mandatory for each
IP: 12 month period
Communication to
NRAs
Mandatory terms +
Default rules
:
V
Odourisation
Amendment Process
Flow Control
VI Data Exchange
Measurement principles quality and quantity
Matching
Allocation of gas quantities
VII Dispute Resolution
Exceptional events
Settlement of disputes IA
Other issues to be
bilaterally agreed in IA
16
Article 4: General Provisions
 NC focuses on 7 mandatory terms in line with the FG
Amendments to the interconnection agreement
Flow control
Measurement principles for gas quantities and quality
Matching
Allocation of gas quantities
Exceptional events
Settlement of disputes
 Changes to 3 of the 7 mandatory terms can have a direct impact on
Network Users
NUs have to be informed about and before any change
NUs will be invited to comment on the possible consequences the change may have on
their activities
Timeframe of 1 to 3 months unless otherwise specified in national rules
 New IAs or any amendments changing any of the 7 mandatory terms
shall be communicated to NRAs
17
Article 5: Development of new and alignment of
existing interconnection agreements
12 month period from entering into force of this NC
 Within 12 months after the Network Code enters force, TSOs shall have:
 In force IAs in compliance with the provisions of the NC at each IP
 This is also valid for IPs starting commercial operation for the first time
 Reviewed their existing IAs and shall amend where necessary to be NC compliant
 When TSOs can’t reach an agreement about the mandatory terms TSOs
shall
 Apply the default rules as described in this NC
 Inform its NRA
 When TSOs can’t reach an agreement about items other than the
mandatory terms TSOs shall have settled the dispute as soon as
reasonably practicable
 With the support of NRAs
 Or any other dispute resolution mechanisms under this NC
18
Article 6: Amendment to interconnection
agreements
 IAs shall specify a transparent and detailed amendment process
 Obligation to amend an IA can have different reasons
Applicable legislative or regulatory framework
If either party to the IA requests by means of a written notice
 Timing for the amendment
Deadlines imposed by applicable legislative or regulatory framework or
Deadlines agreed upon among the involved TSOs
 If TSOs don’t agree on the amendment of the relevant provisions or
the timeline of the amendment process
 The dispute shall be settled in accordance with the provisions of the dispute
resolution part of the IA
19
Article 7: Rules for flow control
 IA shall address the following matters:
Rules to facilitate a controllable, accurate, predictable and efficient flow across the IP
Provisions for TSOs how to steer the flow and obligations to use their reasonable
endeavours to minimize the deviations from the agreed flow
Determination of the TSO who is responsible for the installation, operation and
maintenance of the flow control equipment
 To agree on the direction and quantity of gas flow for the IP for each
hour of the gas day taking into account
The results of the matching process
OBA corrections
Flow control arrangements
 In addition TSOs may alter the flow when it is required under certain
circumstances like
To comply with requirements laid down in safety legislation
To comply with requirements laid down in Emergency Plans or Action Plans in
accordance with EU regulation No. 994/2010
An exceptional event
Risk for NUs
Any other reason specified under national rule
20
Article 7: Rules for flow control
 TSO in charge of the flow control equipment shall in cooperation with
the other TSOs be responsible for steering the gas flow across the IP at
a level of
Accuracy sufficient to minimize the steering difference
Stability in line with the efficient use of the gas transmission network
Pressure that complies with contractual obligations
Best practice
Flow control actions taken at an IP are done only on an operational basis
meaning that network users’ confirmed quantities are not affected as long
as an operational balancing account is in place and any flow alteration
action as described under paragraph 2, (c) of this Article doesn’t have to be
applied.
Where no operational balancing account is in place network users’
confirmed quantities will be affected only to the minimum extent possible.
21
Article 8: Measurement principles for gas quantity
and quality
 The IA shall as a minimum specify the following matters
Details of all measurement responsibilities
Details of the applicable standards
Determination of the TSO who is in charge of the installation, operation and
maintenance of the measurement equipment
Obligation for the aforementioned TSO to provide all necessary information and data of
the measured gas quantity and quality to the other party
Within the timeframe as specified in the IA
 At a frequency as specified in the IA
 The installation, operation and maintenance of the measurement
equipment at an IP shall take into account both relevant national
requirements of the involved TSOs
TSOs shall use their reasonable endeavours to reach an agreement about this
If no agreement can be reached then the provisions of the overarching dispute
resolution of the NC shall apply
22
Article 8: Measurement principles for gas quantity
and quality
Default rule
Where the contracting parties do not agree on a standard for the measurement
of volume and energy, the latest version of European standard EN1776
Functional Requirements for Gas Measuring Systems shall apply.
23
Article 9: Matching
 General Provisions
All TSOs whose systems are connected at an IP shall implement a Matching Process
 The Matching Process shall describe
Communication and processing of the relevant data among the TSOs
Roles (Initiating/Matching TSO)
Timing
Data formats
Calculation of the Processed Quantities and Confirmed Quantities of Network Users
Matching Rules
Default rule is the Lesser Rule
Examples: Results of Lesser Rule
Processed
Quantity
A
Processed
Quantity B
Confirmed
100
100
100
-100
-120
-100
100
80
80
Quantity
24
Article 9: Matching
Nomination / Renomination Cycle (2 hours)
Step 1
Step 2
Step 3
Calculation and
sending of
processed
quantities
Calculation and
sending of
confirmed
quantities
Sending
confirmation to
NUs and schedule
network
Initiating TSO
Initiating TSO
Confirmation
Monitoring
Steering
Calculation
Matching TSO
Confirmed
Quantity
Matching TSO
Confirmation
25
Article 10: Rules for the allocation of gas quantities
 The allocation rules have to be
consistent at both sides of the IP
 IA shall define the OBA as the
applicable allocation rule, however
For existing IAs TSOs may agree to maintain
the existing allocation rules and inform their
NUs thereof
For new IAs TSOs may agree on another
allocation rule. In that case and if a network
user of either of the TSOs requests the
allocation rule should be the OBA then the
TSOs have to conduct a public consultation
Shipper 1
nominated
+ allocated
50
Shipper 2
nominated
+ allocated
Total allocated
100
OBA = 10
= 1000
Shipper 5
nominated
+ allocated
500
Measured
= 1010
Shipper 4
nominated
+ allocated
Shipper 3
nominated
+ allocated
150
200
Default rule
IA shall define the OBA as the
applicable allocation rule
26
Article 11: Exceptional events
 A general obligation for any TSO affected by an exceptional event shall
be to
To comply with the provisions set forth by EC No 1227/2011
Inform the other TSO about the occurrence of the event and
Provide all necessary information to the other TSO
 TSOs shall agree on the
Communications means to be used to inform all relevant parties fast and simultaneous
Telephone for information or otherwise agreed
Written confirmation
 Content of communication between TSOs and TSOs
Nature of the event
Expected duration
Possible consequences on quantities that can be transported over the IP
 Content of communication between TSOs and their respective NUs
Nature of the event
Expected duration
Consequences for the confirmed quantities
27
Article 11: Exceptional events
 When the exceptional event ends the relevant affected TSO shall as
soon as reasonable practical inform the relevant other TSOs and the
affected NUs
Best practice
The relevant TSO shall inform without delay and keep informed the other
TSO and shall inform as soon as reasonable practical its affected NUs
28
FG: Dispute resolution (Articles 12 and 28)
In line with the FG require a twofold approach to the issue of dispute resolution
in the NC is needed:
 an overarching procedure for disputes arising between TSOs
page 7 of the FG
in case an IA is not yet in force;
In relation to the implementation of any provisions set forth in any NC’s sections (units,
gas quality, odourisation etc.) other than in the IAs.
 a procedure regarding the disputes arising out of or in connection to IAs
between TSOs
page 8 of the FG
including, but not limited to, the existence, validity, content, amendment or termination
of the IA
The overarching principle is ipso iure (automatically) applicable.
The IAs’ dispute resolution procedure must be foreseen by each IA as one of
its mandatory terms.
29
Article 12: Settlement of disputes arising from
Interconnection Agreements
As a minimum, the IA shall specify how to settle any dispute that can’t
be amicably settled by the TSOs
Either define the court of jurisdiction
And / Or describe terms and conditions for the appointment of experts
The applicable conflict-of-Iaw rules shall apply in case
The jurisdiction deemed to be not competent
Any of the involved TSOs doesn’t comply with the obligation in connection with the
appointment of experts
Default rule
Should the TSOs not agree on a jurisdiction clause to finally settle the dispute
the applicable conflict-of-law rules shall apply
30
Article 28: Overarching dispute resolution
procedure
In this respect, in line with the FG:
 TSOs shall endeavour to settle the dispute;
 TSOs shall resort to any available dispute settlement mechanism(s) in
place in their respective Member State pursuant to Article 41(11) of the
Directive (EC) 2009/73;
 in case a common final decision cannot be reached, ACER shall take
appropriate measures pursuant to Article 8 of the Regulation (EC)
713/2009.
31
NC Interoperability and Data Exchange
I/VIII General and Final Provisions
Interconnection Agreements
II
III Units
Common set of Units for
external communication
IV Gas Quality
Pressure/Temp/Volume/GCV/
V
Odourisation
Energy/Wobbe index
VI Data Exchange
VII Dispute Resolution
32
Article 13: General provisions
Each TSO shall use the common set of units as defined in the NC for
the communication related to the information exchange described in
the network codes developed so far with other TSOs or with other
counterparties or in respect of the publication of data on a common
platform
The above mentioned provisions are without prejudice to existing
EU regulations covering harmonisation of units for other parameters
33
Article 14: Common set of units
Parameter
Unit
Pressure
bar
Temperature
°C (degree Celsius)
Volume
m3(n)
Gross Calorific Value
kWh/m3(n)
Energy
kWh (based on GCV)
Wobbe-index
kWh/m3(n) (based on GCV)
For pressure, it should be indicated whether it refers to absolute (bar(a)) or gauge
(bar(g)).
The reference conditions for volume shall be 0°C and 1.01325 bar(a).
For GCV, Energy and Wobbe-index the combustion reference temperature shall be
25°C.
34
Article 15: Additional units
 In addition to the units as described in article 13 and 14 other units or
reference conditions for the exchange of data between TSOs and TSOs
and between TSOs and NUs are allowed when the involved parties
agree on it
 Conversion factors consistent with the procedures described in the
latest version of ISO 13443 shall be provided where required
35
NC Interoperability and Data Exchange
I/VIII General and Final Provisions
Interconnection Agreements
II
III Units
TSO-TSO cooperation
Managing GQ differences
GQ Data Publication
IV Gas Quality
V
Odourisation
VI Data Exchange
GQ variations information
exchange -> Eligible Users
Long Term Monitoring
VII Dispute Resolution
36
Gas Quality – Managing Gas Quality Differences
Art. 17
Application area:
> Cross border IPs
> Where the physical flow occurs
> Where the barrier has been identified (based on the real and/or historical
flows and/or expected future flows (outlook))
Article 17 requires to manage the real identified problems that create a barrier
to the cross border flow
37
Gas Quality – Managing Gas Quality Differences
Art. 17
12 month period from entering into force of this regulation
Adjacent TSOs shall within 12 months…
> … agree whether or not there is a barrier persisting on IPs
> … inform relevant NRAs that barrier has been identified
> … develop technically feasible and financially reasonable options
> … jointly carry out CBA
> … conduct a public consultation
> … submit recommended solution to NRAs for approval.
> TSOs shall review the situation with the frequency not less than once per year
The dispute resolution procedure in Art 28 applies if TSOs fail to reach an
agreement on whether the barrier exists and/or how it should be overcome.
38
Gas Quality – Managing Gas Quality Differences
Art. 17
Issues beyond the scope:
> Responsibilities (who is responsible for gas quality) – national responsibility
> Defining gas quality parameters and their acceptable ranges – defined in
national rules/further recommendations for harmonised gas quality standards
are elaborated by CEN (Mandates by EC)
39
Short term monitoring – data publication
Art. 18
> Provide real time gas quality data
> Wobbe-index & gross calorific value publication
> Frequency – at least once per hour
> Data measured at physical IPs
> No warranty given by TSO for any consequential loss or damage related to the
use of the information by any third party
40
Short term monitoring on gas quality variation
information exchange – Art. 19
Criteria for parties being eligible to potentially receive gas quality
information:
> Any end consumer directly connected to the TSOs network, whose operation
may be affected
> OR any network user that has a contract in force with a relevant end
consumer (in regimes that prevent direct contracting TSOs to end consumer)
> Any DSO directly connected to the TSOs network
> Any SSO directly connected to the TSOs network, whose operation may be
affected
Eligible parties to potentially receive gas quality variation information shall be
specified at national level
41
Short term monitoring on gas quality variation
information exchange – Art. 19
12 month period from entering into force of this regulation
TSOs obligations:
> Define and maintain a list of eligible parties
> For identified end consumers TSOs shall assess:
 The nature of indicative information
 Frequency of an update
 Lead-time
 How the information may be exchanged
TSOs shall use their reasonable endeavours using existing equipment to
provide such information
> No warranty given by TSO for any consequential loss or damage related to the
use of the information by any third party
42
Long term monitoring – Art. 20
Scope of the outlook:
> To be produced every 2 years
> At least Wobbe-index – detailed parameters can be defined after
stakeholders’ consultation (TYNDP)
> New supply sources including indigenous and non-conventional gases
production
> For each relevant parameter and every region  result in a range within
which the parameter is likely to evolve
> The outlook shall be consistent and in line with TYNDP regarding:
 Preparation and timing
 Selection of the most relevant cases focusing on the year plus 5 and 10
 Consultation process with stakeholders
43
NC Interoperability and Data Exchange
I/VIII General and Final Provisions
Interconnection Agreements
II
III Units
IV Gas Quality
Process description
Bilateral agreement: 6 m
Detailed plan: 12 m
Member States’
involvement
Safety issue
V
Odourisation
VI Data Exchange
VII Dispute Resolution
If no bilateral agreement:
shift towards nonodourised gas
44
Odourisation – Art. 21
1st phase  6 months period:
> TSOs shall:
 Identify differences in practices that might create a barrier
 Inform their NRAs if the barrier has been identified
 Actively cooperate to identify and assess the consequences related to:
o Potential flow of odourised gas into non-odourised network
o Possible acceptable level of odourant
o Conversion towards non-odourised gas
 Submit the agreement, including cost recovery mechanism, for approval to
relevant NRAs, with the involvement of the relevant authorities where
required.
45
Odourisation – Art. 21
2nd phase  If no agreement can be reached between the TSOs
or if the agreement is not acceptable to the relevant NRAs, then
during 12 months period:
> TSOs shall in cooperation with relevant authorities:
 Develop options to remove barrier
 Define most cost effective option to deliver physical flows of non-odourised
gas after producing cost estimates
 Implementation time
 Define final solution including cost recovery mechanism
46
Network Code Interoperability and
Data Exchange Rules
Consultation Workshop
COFFEE BREAK ….
Brussels – 20 Mar 2013
NC Interoperability and Data Exchange
I/VIII General and Final Provisions
Interconnection Agreements
II
III Units
Common Data Exchange
Solution HOW: initial solution
In parallel with existing solutions
IV Gas Quality
V
Odourisation
VI Data Exchange
VII Dispute Resolution
Cost-Benefit Assessment
final solution
Development process WHAT ->
Common Network Operation
Tool (Reg. 715)
48
Introduction
Components for Data Exchange (HOW):
 Data Network
 Data Exchange Protocol
 Data Format
Types of Data Exchanges - toolbox:
 Document based (3 technical alternatives)
 Integrated (web services – one technology)
 Interactive (web browser – one technology)
49
Introduction
INTRODUCTION: WHAT & HOW
50
Data Exchange - Art 22
>Art 22: General provisions
 What: Regulation 715/2009
 Who: TSOs , TSOs – CP
 Network: Internet
51
Data Exchange- proposed solutions – Art 23
Toolbox
Network
Document based
Data Exchange Internet
Data Exchange Protocol
Data Content Format
Structure Content
Communication
Format
Format
B2B Standard Protocol
XML
Edig@s
AS4
HTTP(S)
XML
Edig@s
SOAP
HTTP(S)
Integrated DE
Internet
Interactive DE
Internet none
tbd
HTTP(S)
1. Data Content Format Edig@s-XML: Use of Edig@s-XML is subject to legal
assessment
2. Initial proposed solutions based on a technical evaluation. Final solutions will
be based on a detailed Cost-Benefit analysis
52
Data Exchange
Initial assessment:
Synergies: Protocol
 EFET: protocol ebMS.v2 for trading activities
 ENTSO-E: MADES/ECP web service based solution for
communications with e-TSOs. Not supported by all TSOs
No technical compatibility between the existing
solutions
Synergies: Data format
 XML generally used
Common data content formats for electricity and gas
will:
- increase maintenance cost for unnecessary updates
- increased risk for failures due to changes
53
Data Exchange
Initial assessment- actual spread
 Actual protocols
 FTP
 AS2
 SMTP sFTP
 Web service (http(s))
 SOAP
 E-mail
 Actual data formats
 Edigas XML
 Edigas – edifact
 Excel (KISS-A)
 Pdf
 Proprietary formats
 Csv files
 Many protocols and formats in use
 No compatibility between these solutions
54
Data Exchange
Initial assessment
Volume of data traffic
 Evaluate existing data exchanges (not subjected to any
regulation)
 Estimate number of messages (/hour,/day) 180.. 26100/d
Scalability
 Estimate size of messages (define limitations of the evaluated
solutions)
 Performance criteria and transmission delay
 Technical requirements
 Security requirements (encryption, signing)
 Commercial requirement (acknowledgement, non
repudiation, potential new functionalities …)
55
Data Exchange
Initial assessment
Avoid discrimination of small shippers and new market
entrants:
 Keep existing solutions in place as long as compliant
with the business requirements
 Services offered by service providers avoid big IT
developments
 Interactive data exchange solutions (depending on
the application) will allow easy access from a PC via
a browser
56
Data Exchange
Initial assessment- actual spread
 Actual protocols
 FTP
 AS2
 SMTP sFTP
 Web service (http(s))
 SOAP
 E-mail
 Actual data formats
 Edigas XML
 Edigas – edifact
 Excel (KISS-A)
 Pdf
 Proprietary formats
 Csv files
Existing Protocols and Data Formats taken into consideration for
the evaluation for a Data Exchange solution
57
Data Exchange
Initial assessment
Evaluated protocols (together with external expert)
 AS2
 ebMS
 AS4
Technical evaluation
AS4 best score; offers more options for the future:
 Rich Meta Data in msg header (e.g. service, action)
 Reception awareness
 Duplication detection
 Pull functionality
58
Data Exchange
Initial assessment
Cost evaluation (to be confirmed by a detailed CBA)
 Implementation cost expected to be equal
 Maintenance cost expected to be similar
 Expected life cycle – AS4 expected to last longer (most recent
technology)
Risk evaluation:
 AS2: lower implementation risk, proven technology
 ebMS: technology well known but many option possible
 AS4 (based on ebMS)
ohigher risk since no experience by TSOs;
59
Data Exchange
Options
1
keep existing
formats
2
implement all
existing formats
Data
format
Harmonisation :
develop Business
3 Requirements
Specifications and
common data
formats
keep existing
situation: different
1
(incompatible)
protocols in use
2
Comm.
Protocol
3
implement all
existing protocols
one protocol
common protocol:
4
co-existence with
existing (local)
protocols
Cost
Compliant with FG
no harmonization;
incompatible solutions in
no cost
EU
--> not compliant
Barriers removed for
high cost for all parties
interoperability
to maintain all data
No common set of data
formats
formats
--> Not compliant
Minimal cost: All
parties implement the
same business model
and data formats
full compliant
Conclusion
not compliant with FG
not cost efficient
best solution for a
minimum cost
Limited communication
possible between TSOs
and CP
not compliant with FG
high cost for all parties Partial interoperability:
to maintain all
no common agreement
protocols
-->No harmonization
not compliant with FG
no cost
cost for all parties to
implement the protocol
Full interoperability
All TSOs and, only CP
that do not support the
existing (local)
protocols, need to
implement the
"common" protocol.
Full interoperability
remark
Not realistic seen the high
number of local
communications in some
member states.Only a
limited number of them
need to communicate with
other TSOs.
Most cost efficient seen
the limited number of
implementations
--> best solution for a
minimum overal
limplementation cost
Central governance
of data formats
required:
ENTSOG-EASEEgas cooperation on
the EDIGAS-XML
data format
It is expected that
the common solution
will replace over
time all existing
solutions
60
Data Exchange
 Detailed Cost-Benefit Assessment study
Detailed study by ENTSOG with support of an external
consultant
 Focus on cost / benefit for the different technical options
 Take the technical evaluation as a starting point
Schedule:
 20-30/3/2013: Send questionnaire and collect information
 23/4/2013: Workshop to exchange views and collect
opinions (present first results of the survey)
 28/5/2013: Presentation CBA results (during conclusion
workshop NC)
61
Data Exchange
62
Data Exchange
63
Data Exchange
64
Data Exchange – Art 24
Art 24: Security and Availability
> Security:
 Each party is responsible for its own infrastructure
 Each party is responsible for the confidentiality of the
information
 Each party shall inform other parties that might be
compromised in case of any IT problem
> Availability: TSOs shall take appropriate measures to
 avoid single points of failure in their data exchange systems
 obtain appropriate services from the internet service
provider(s)
 minimize downtime (planned and unplanned) and inform
their counterparties in case of planned unavailability
65
Data Exchange – Art 25
Art 25: Implementation
 Common solution parallel to the existing solutions
 TSOs implement the common DE solution within 12 month
when NC comes into force.
 Parties who cannot communicate with TSOs with their
existing DE protocol shall also use the common DE solution
 Existing solutions can stay in place as long as they are
compliant with the data exchange requirements for the
corresponding business processes
66
Data Exchange – Art 26
> Art 26: Technology evolution
> Changes to the common solution may be necessary in the
future due to:
 New business requirements
 New technology requirements
 Obsolescence of existing technology
…
ENTSOG will be responsible to take appropriate initiatives to
meet the requirements for data exchange as defined in the
regulations
If required an amendment will be submitted to ACER
67
Data Exchange – Art 27
>Art 27: Development process
> Data exchange requirements under regulation 715/2009 shall :
 be controlled and developed by ENTSOG
 be based on Business Requirements Specification (BRS)
 be published by ENTSOG
> CNOT :
 ENTSOG shall adopt Common Network Operation Tools
 For Data Exchange: all information for the implementation of
the network code
68
Thank You for Your Attention
Interoperability Team
ENTSOG -- European Network of Transmission System Operators for Gas
Avenue de Cortenbergh 100, B-1000 Brussels
EML: [email protected]
WWW: www.entsog.eu
Network Code Interoperability and
Data Exchange Rules
Consultation Workshop
Questions and Answers ….
Brussels – 20 Mar 2013
Network Code on Interoperability
& Data Exchange – ACER’s
preliminary comments
Geert Van Hauwermeiren, ACER Task Force Chair
ENTSOG Interoperability & Data Exchange Workshop
TITRE
Brussels, 20
March 2013
71
FG/NC Interoperability & Data Exchange
Process within the Agency
Ultimately, after 11 September 2013, ACER must provide:
• A reasoned opinion to ENTSOG, within 3 months (Art 6(7) of
the Gas Regulation);
• A recommendation for adoption to EC, once the Agency is
satisfied that the network code is in line with the Framework
Guideline (Art 6(9) of the Gas Regulation).
At this early stage, ACER provides preliminary views to
facilitate the process.
72
ENTSOG Workshop - Brussels, 20 March 2013
FG/NC Interoperability & Data Exchange
Preliminary views on the Network Code (1/6)
Preliminary views on the Network Code
•
•
•
Constructive dialog with ACER;
The text show high quality despite the variety of technical
topics covered;
Ambitious solutions concerning:
•
Interconnection Agreement Transparency provisions
(Art. 4)
•
Operational Balancing Accounts (Art. 10);
•
Units (Art. 15);
•
Data Exchange (Art. 27);
73
ENTSOG Workshop - Brussels, 20 March 2013
FG/NC Interoperability & Data Exchange
Preliminary views on the Network Code (2/6)
Interconnection Agreements
•
•
•
FG states that “The Network Code shall provide for default rules
on each of the above topics, to be directly applicable in the
event the TSOs fail to reach a mutually acceptable agreement on
any of these, within a period of 12 months”;
The default rules are not clearly defined in NC. It is not easy to
see what a default Interconnection Agreement would look like;
In particular, the issues of flow control (Art. 7), gas quality and
quantity measurement (Art. 8) include no or incomplete default
rules, and …;
… where defined, in spite of Art. 1(2), default rules are to be
assessed against existing regulation (CMP, CAM, balancing, …);
74
ENTSOG Workshop - Brussels, 20 March 2013
FG/NC Interoperability & Data Exchange
Preliminary views on the Network Code (3/6)
Gas Quality (1/2)
•
•
Where the FG states obligations, the NC refers to “reasonable
endeavours”;
ENTSOG should clarify that this wording does not prevent the level of
harmonisation aimed at within the FG to be achieved by the Network
code.
Question to stakeholders :
•
•
•
the FG states in its Art. 4 that the NC shall apply "where necessary",
and on short-term monitoring, benefit to "relevant network users".
NC defines "where necessary" in Art. 17 and "relevant Network Users"
in Art. 19.1.
In addition, in Art. 18(1) Wobbe index and GCV, and in Art. 20(3)
Wobbe index, are set as the minimum to be covered respectively by
the short-term and the long term monitoring outlook.
75
ENTSOG Workshop - Brussels, 20 March 2013
FG/NC Interoperability & Data Exchange
Preliminary views on the Network Code (4/6)
Gas Quality (2/2)
•
Possible misalignment on Short Term monitoring (Art.19):
•
While based on the FG, the NC should define situations
when ST monitoring is relevant, as well as the nature and
frequency of the information, the current NC states that
this definition shall take place at Member State level;
•
The justification for the proportionality of the approach is
based on a single example, that does not provide sufficient
explanation.
The Agency believes that an active cooperation of stakeholders
during the on-going public consultation is needed.
ENTSOG should encourage stakeholders to provide feedback on
this particular issue.
76
ENTSOG Workshop - Brussels, 20 March 2013
FG/NC Interoperability & Data Exchange
Preliminary views on the Network Code (5/6)
Data Exchange
•
•
•
the FG states in Art. 6 that "The NC shall foresee a common set of
data formats, data network and data protocol" and "The selection of
such a data exchange solution […] shall be based on a cost-benefit
analysis subject to public consultation“;
At this stage, footnotes 3,4,5 on page 28 of the NC leave the issue
open. They highlight that the data exchange solution is set within the
NC, while the cost-benefit analysis and legal assessment have not
been conducted at this stage. The final NC should be developed in line
with the FG;
Feedback is expected from stakeholders on the scope of application
of the data exchange provisions.
The Public Consultation should provide further feedback on these
issues.
77
ENTSOG Workshop - Brussels, 20 March 2013
FG/NC Interoperability & Data Exchange
Preliminary views on the Network Code (6/6)
Review of the misalignments
•
•
•
•
Interconnection Agreement’s default rules not clear;
Data Exchange – the cost-benefit analysis has to be concluded before
the final preferred data exchange protocol is defined in the NC;
Data Exchange – the legal analysis has to be concluded before the
final preferred data format is defined;
Gas Quality Short-term monitoring – the NC should include an
obligation rather than a “best endeavour” approach.
The Agency has concerns over the current approach on these topics
and will be considering stakeholders’ feedback to assess the extent
to which the NC should be amended in order to reflect better the
requirements of the FG.
78
ENTSOG Workshop - Brussels, 20 March 2013
FG/NC Interoperability & Data Exchange
Preliminary conclusions:
•
There is a good level of compliance overall;
•
There are few remaining concerns:
•
Gas Quality Short-term monitoring (Art.29);
•
Interconnection Agreements (Art.7);
•
Data Exchange (Art. 23).
Beyond these preliminary views, the Agency will continue the
scrutiny of the NC in the light of stakeholders comments in the
public consultation.
79
ENTSOG Workshop - Brussels, 20 March 2013
Network Code Interoperability and
Data Exchange Rules
Consultation Workshop
LUNCH TIME ….
Brussels – 20 Mar 2013
Network Code Interoperability and
Data Exchange Rules
Consultation Workshop
Stakeholders’ views
Brussels – 20 Mar 2013
Interoperability
GIE presentation for ENTSOG WS 20 March 2013
GIE remarks on draft NC (I)
ENTSOG has achieved a lot…
•
GIE supports the overarching targets of this Network Code
•
ENTSOG once again runs a fair and transparent process and has so far
achieved reasonable and pragmatic solutions
•
The crucial aspect of the NC are the impacts on market participants
which may exceed those of the TSOs by far:
•
•
•
Gas Quality/Odourisation solutions may have impacts on downstream
systems or end consumers
The potential investments of „counterparties“ in IT exceed the
investments of TSOs by far
The approach of a common data exchange solution together with the
possibility of keeping current national data exchange solutions in parallel
is fair and pragmatic
83
GIE remarks on draft NC (II)
… but more efforts are needed
•
The processes described by ENTSOG are sufficient in terms of
stakeholder involvement and public consultations...
•
...but
•
•
•
The Network Code should describe in more details how to proceed on
member states level when it comes to a potentially different time
schedule
This could inter alia include stakeholder envolvement, mediation or a set
of criteria
The FG has widen the scope, as a consequence the vital interests of
„counterparties“ need attention on member states level too
84
Prime Mover initial views
on Draft Network Code
Interoperability and Data exchange
ENTSOG Workshop
Brussels, 20 March 2013
Kees Bouwens, ExxonMobil
More about OGP: Our membership spans the globe and accounts for more than
half of the world’s oil output and about one third of global gas production. From
our London office, we foster cooperation in the area of health, safety and the
environment, operations and engineering, and represent the industry before
international organisations, such as the UN, IMO and the World Bank, as well as
regional seas conventions, such as OSPAR, where we have observer status.
OGP Europe in Brussels represents before the EU OGP members who are active
in Europe.
Prime Mover initial views
• Disclaimer
 These are initial views and do not represent the endorsed
position of OGP or any of its members
 These views have been discussed among the prime movers
but do not represent a common view
87
Benefits of this Network Code
• Interoperability and Data exchange facilitate efficient
operation of interconnected networks:
 Harmonisation of operational matters at IPs
 Promote OBA as default allocation rule
 Use of common set of units
 Managing gas quality differences at IPs
 Short-term monitoring of gas quality
 Provide common data exchange solutions
• CAM and Balancing define new business processes.
Interoperability and Data exchange build the seamless
interfaces between TSOs to make this a success.
88
Interconnection Agreements
• This Network Code only deals with TSO to TSO IAs
 Agreements between adjacent TSOs related to IPs
 Network users may be affected by IAs (matching, flow
control and allocation) and this will be made transparent
 Aim is to reduce barriers for network users
• The Network Code does not establish a template for
connection agreements between TSOs and non-TSOs
 Connections to producers, LNG operators, SSOs, DSOs
and end-consumers are not in scope
 Such agreements are governed by relevant national rules
89
Flow control (Art. 7 NC)
• Aim is to minimize impact on users’ confirmed quantities
 Impact can be further reduced by using OBAs
• Provision 7.2(c) allows TSOs to adjust flow for reasons of
Force Majeure
 Reflects that transport of gas is a physical service
 Different from buying and selling gas at adjacent hubs
• Network Code assigns this risk to network users
 Users trading between hubs should take into account that
TSOs may adjust gas flow in the event of Force Majeure
90
Allocation rules (Art. 10 NC)
• Network Code defines OBA as default allocation rule
 TSOs may agree to implement a different allocation rule, in
which case network users may request consultation
• Art. 10.3 allows TSOs to maintain the existing allocation rule
 This is not consistent with the objective to harmonise rules
 Deviations from the general rule should be justified
• Suggestions to amend Art. 10.3:
 Where existing IAs have allocation rules other than OBA,
TSOs shall:
 consult with relevant stakeholders, and publish the results;
 submit the allocation rule to their NRA for approval
91
Gas quality
• Scope of this Network Code is limited
• National rules (should) specify:
 Network users’ responsibility to meet gas quality specs at
system entry points
 TSOs’ responsibility to manage gas quality in the system,
and in particular gas quality at exit points to consumers
• Network Code provides rules on short term monitoring
 Art. 18 and 19 specify that TSOs provide information on
indicative basis only, without warranty for loss or damage
 This does not release TSOs of responsibility towards
consumers based on national rules
92
Data exchange
• This Network Code provides ‘common solutions’
 For TSO to TSO data exchange
 To be implemented by TSOs within 12 months
 Available for network users that wish to use it
• The Network Code does not mandate a single system for
data exchange between TSOs and non-TSOs
 Existing data exchange systems are maintained
 Decisions to replace existing systems are governed by
relevant national rules
 Avoid major costs when existing solutions can handle
93
Implementation (Art. 25 NC)
• Suggestions to amend Art. 25:
 TSOs shall make the common data exchange solutions
available to TSOs and counter parties within 12 months
 TSOs shall implement the necessary data formats according
to the schedules of the different network codes
 Existing data exchange solutions between TSOs and counter
parties shall only be replaced by the common solutions after:
 the TSO has produced a cost benefit analysis of the
potential change and consulted all counter parties;
 the NRA has approved the change under relevant
national rules
94
Network Code
Interoperability &
Data Exchange Rules
Consultation Workshop ENTSOG
Bart Cornelis
Brussels, 20 March 2013
Overview
Scope
Purpose
NC Interoperability & Data Exchange Rules
Conclusion
96
Scope
Established in 2002
Aim is to develop and promote the simplification and streamlining of both the physical transfer
and the trading of gas across Europe.
Creation of EASEE-gas fully supported by the European Commission and Madrid Forum.
Establishment achieved through the work of a dedicated Task Force supported by EFET, Eurogas,
Eurelectric, GEODE, GTE, OGP and the Edigas group.
6 Market segments are represented:
The association is fundamentally based on company
membership and voluntary contribution towards the
development of common business practices.
97
Purpose
To develop and promote common business practices (CBPs) to simplify and streamline
business processes between the stakeholders that will lead to an efficient and effective
European gas market.
Continue a good working relationship with ENTSOG (e.g. contribution to discussions on
different network codes)
Investigate new Network Codes and discuss them among our members
active in the different market segments, and provide a structured feedback
to ENTSOG.
98
NC Interoperability & Data Exchange Rules
P.13-14, Article 9, point 3 (b). It’s not clear how this matching process should work in case of both
bundled and unbundled capacity product nominations at the same time.
Bundled and Unbundled quantities should be nominated separately or together?
Shippers don’t ask for extra complexity with respect to nomination & matching
processes. For each extra complexity added, the added value should be sufficiently clear.
A shipper bringing gas into a TSO in the north of Europe might only be interested to bring it to the
south, and is probably not interested in too many complexities along the way.
Clear requirements / guidelines about nominations are missing. EASEE-gas thinks
that this should be included in this NC (even though it’s described in the Balancing
NC, we advise to include it in this NC)
P.16, Article 10, point 5 (f): What is the alternative for the OBA in case of exceeding of the OBA
limits? Pro rata rule? Same question for borders on which there’s not yet an OBA in place.
P.16, Article 11, point 1: What is an “exceptional event”? Definition, examples?
P.28: EDIG@S: EASEE-gas prefers to keep Edig@s as data format in the NC, and is ready to
cooperate with ENTSOG with the aim to clarify the legal issue.
99
Conclusion
In general, EASEE-gas members are positive about this NC, even if some points still
deserve extra attention.
A transparent and straight forward nomination & matching process is key to promote and
stimulate market access for the shippers.
EASEE-gas is pleased to see that different CBPs are used by ENTSOG for the
development of the Network Codes in general.
100
Business Rules for
Odourisation
Chapter V
GrDF - Direction Technique et Industrielle
1er avril 2016
Position of GrDF – DSO, major player in Europe
– to the questions of the consultation
1. Do you agree with ENTSOGs’ proposal that if cross-border flows are
hampered by differences in odourisation practices between adjacent systems
and transmission system operators cannot reach a bilateral agreement they
should shift towards flow of non-odourised gas?
○ Yes.
○ Yes, but with minor refinements (as described in section B of the Supporting Document).
○ No (as described in section B of the Supporting Document).
The flow of non-odorised gas shall be one of the possible options,
but it shall not be the ultimate option especially because :

odorised gas meets general specifications of gas quality
and especially on sulfur

the choice between the different options fall under the
responsibility of national state authorities

the option of non odorised gas on transmission systems
will decrease the performance level of the odorisation of gas
delivered to distribution networks, which will cause high costs for
the transmission and distribution operators concerned.
GrDF - Direction Technique et Industrielle
1er avril 2016
1
0102
2
Position of GrDF – DSO, major player in Europe
– to the questions of the consultation
2. Do you think that ENTSOGs’ proposal encourage transmission system operators at each
interconnection point to reach an agreement to address effectively barriers resulting from
differences in odourisation practices?
○ Yes.
○ Yes, but with minor refinements (as described in section B of the Supporting Document).
○ No (as described in section B of the Supporting Document).
The proposed text suggests that whatever the situation, the final solution
should be the transit of non-odorised gas…. This position does not
encourage to find an effective solution to remove the barrier and it does
not even encourage to actually assess the existence of a barrier.
The operator identifying a barrier must give objective evidence of the
barrier, and then, from this point, the best cost-effective solution should be
found, amongst all the possible options. We believe that operators shall :
- actively identify and give an assessment of the impacts related to the
eventual flow of odorised gas,
- and evaluate local solutions to mitigate those impacts,
- and at last define a level of odorant in the gas below which those impacts
are acceptable especially to evaluate possible solutions of de-odorisation
or evolution of odorisation practices.
These points need to be specified in the text of the network code as they
are already mentioned in the supporting document.
GrDF - Direction Technique et Industrielle
1er avril 2016
1
0103
3
Arguments for our position
(1/4)
Odorised gas is fully complying with existing gas quality specifications, in
particular sulfur content (Easee gas CBP etc…)
The Network Code will be binding. We need to keep opened all opportunities
offering cost effective, safe solutions, which do not hamper cross border flows.
All the proposals made during the SJWS that were not fully in agreement with the
FG of ACER were rejected in the proposed redaction of the draft NC.
If ENTSOG publishes in the NC as the only rule the exchange of non odorised
gas at IP,
it would become a mandatory rule,
and it could create a barrier for countries for which transporting non
odorised gas would be a problem.
1
0
4
GrDF - Direction Technique et Industrielle
1er avril 2016
104
Arguments for our position
(2/4)
Odorisation practices are linked to local context, and modyfying only the
odorisation practices without changing the whole context would reduce
the safety.
 Indeed, odorisation is linked to the policy of leak research along the
network : in the case of a non-odorised transport network, the leak
research should be more frequent, even along the distribution network.
 and this might also have an impact on the regulation concerning the
installation of gas equipments (for ex : a stop-flow system is mandatory in
some countries)
Therefore, changing odorisation practices would have an impact on operating
costs for operators all along the networks (not only at transmission level)
1
0
5
GrDF - Direction Technique et Industrielle
1er avril 2016
105
Arguments for our position
(3/4)
The concept of non odorised gas is very theoretical.
Indeed, natural gas
might have an odor intrinsically because of the presence of mercaptans for example,
or it might have an odor because of the addition of an adoriferous material like THT for
example
or it might have an odor both by naturally contained mercaptans and by added THT.
How could we define a non odorised gas : would it be a gas in which no addition
of any odoriferous product has been done ? In this case, how would we consider
a gas arriving at an IP with no added odorant but naturally containing a high level
of mercaptans, and therefore, having a strong odor ?
Transmission of only non odorised gas at IP is not possible in the case of a
network connected to underground storages that have once contained odorised
gas.
Indeed, in France for example, where odorisation is done with THT, there would
be several mg/Nm3 of THT in the gas coming out from aquiferous storages during
at least 15 years after stopping the current odorisation practices.
1
0
6
GrDF - Direction Technique et Industrielle
1er avril 2016
106
Arguments for our position
(4/4)
The fact that an agreement should be found within 6 months and only
bilaterally between the 2 concerned TSOs appears to be something difficult.
We suggest that there should be a longer time allowed to look for an agreement
before reaching the solution of non odorisation as possible option (12 months),
and during this period, discussion with other stakeholders could be usefull in
order to define the most cost-effective solution (regulatory authorities, national
member states …)
1
0
7
GrDF - Direction Technique et Industrielle
1er avril 2016
107
GEODE’s position
on
Network Code Interoperability
and Data Exchange
Brussels, March 20th 2013
Johannes Nohl
NC INT – Network‘s situation
 Data Exchange of DSOs doesn‘t affect border crossings
National
Regulation
DSO
TSO
Network Codes
DSO
Page 109
50608-00
109
NC INT – Legal framework
 FGs and NCs are based on Regulation (EC) No 715/2009
 Art. 8 (6): The NCs …, taking into account, if appropriate,
regional special characteristics…
 Art. 8 (7): The NC shall be developed for cross-bordernetwork issues… without prejudice to the Member States’
right to establish national network codes which do not affect
cross-border trade.
 Subject to European harmonization are only TSOs!
 Position of DSOs (situated downstream of TSOs)
 All DSOs are regional different, no cross-border-issues
 Part of NCs anyway! E.g. NC Balancing unthinkable
without DSO’s cooperation (Art. 43).
Page 110
50608-00
110
 Demand of TSOs and network users for single DE solution?
NC INT – Required measures
 NCs need to reflect legal framework: wording has to exclude
DSOs explicitly
- Draft NC INT: “counterparties of TSO”
- Data arising from Regulation (EC) No 715/2009 “and
regulations to supplement it”  Network Codes?
- DSO’s role in other NCs (Art. 43 NC Balancing)
 Let national network codes live for now: clarify scope of NC
INT and requirements of its application
 Cross-border network issues, cross-border trade
 Who are the “counterparties” – name it!
 Consider future development today!
 In case all subjects to a NC are in scope
Page 111
50608-00
 Lead times: Will the market be ready?
111
NC INT – Design future-proof
 ENTSOG has to consider interests of non-members
 41 TSOs (+7)  2200+ DSOs, many of them independent
 Harmonization of DSO’s is economically not reasonable
 Availability of 2200+ IT service providers at one time
 Convergence electricity / gas (synergy) is over
 New IT will be part of network user tariffs
 Existing IT and business rules at distribution level
 Working solutions are already implemented
 Supporting two systems
- Costs of ownership (maintenance etc.)
- Inefficient
Page 112
50608-00
 Will Cost-Benefit-Analysis respect that?
112
NC INT – Minimum conditions
 NC INT can be a statuary framework: Regional differences
can be addressed best by national regulatory bodies
 Necessary NC INT amendments
 IT services take time: Prolong implementation schedule
 AS4 is nearly unknown to the market by now
 Implement Change-Management with fixed terms / dates
 Existing compatible solutions can co-exist until canceled by
national regulatory bodies (not by TSO, Art. 25 (2) NC INT)
 Consider Data Exchange not (only) as a topic for TSOs
 Interests of all market partners need to be balanced
 Include representatives of DSOs in all panels
 Efficient functioning of whole gas market as target
Page 113
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113
THANK YOU!
Thank you for your
attention!
GEODE
Avenue Marnix 28
1000 Brussels
Tel. +32 2 204 44 60
Fax +32 2 204 44 69
www.geode-eu.org
[email protected]
Consultation Workshop for
NC on Interoperability
IFIEC-CEFIC position on gas quality
Dirk Jan Meuzelaar
20 March 2013 Brussels
securing competitive energy for industry
Art. 16-17; adjacent TSO’s have to manage gas differences….
but clarity about responsibility for gas quality is not included in the FG nor NC !
IFIEC-CEFIC support that adjacent TSOs should take appropriate measures in
case gas quality differences could lead to a trade barrier. TSO should manage
quality differences that may persist in the future due to diversification of gas
sources. However according to ENTSOG..
• The manager (TSO) is not responsible
• Responsibility is not an interoperability issue
• The regulation can only place obligations on TSOs
End-users require clarification on this issue.
According to CEFIC/IFIEC responsibility should be
part of the NC.
We cannot refuse the gas
We cannot choose our gas
We cannot send the gas back
Gas quality is still the orphan of the gas industry
securing competitive energy for industry
Gas
Quality
116
DG ENER non-paper on gas quality “roadmap” (Madrid Forum, 22-23/03/12)
One of the three main parallel processes is on information provision
“Development of binding European rules (in the context of a Network Code) on, in
particular, real-time information provision by TSOs to industrial customers concerning
expected gas quality fluctuations, allowing them to optimize equipment performance at
the new gas parameters”.
Binding rules on information provisions for gas quality fluctuations (ENTSOG)
• Fluctuations of gas qualities within the allowed bandwidth are likely to occur more
frequently and more suddenly. The appliances of industrial users, such as turbine
operators or the chemical industry, are often sensitive to such fluctuations in gas
quality. However, this effect can be mitigated when information is available
reasonably ahead of the occurrence of the change. The Framework Guideline on
Interoperability and Data Exchange that is currently under development by the
Agency for the Cooperation of Energy Regulators (ACER) should also consider to
mandate European TSOs to inform industrial customers and power plant
operators in real time about changes in gas quality in the system in order for
them to take necessary steps to calibrate their equipment.
Having adequate near real time info available is an important safety issue!
securing competitive energy for industry
117
Art. 18-19; Short term monitoring is on the right track, however
information is provided on an indicative basis without any warranty
• At physical IPs TSO shall publish data at least once per hour the
near real time WI and GCV
• TSOs shall at National level cooperate with eligible parties to assess
–
–
–
–
The nature of the indicative information
Frequency of an update
Lead-time
How the information may be exchanged
CEFIC/IFIEC support that the best (and cheapest) solution is on a case by case,
customised basis. Moreover, variations of gas quality should be monitored on a
regional level depending on the gas flows, however…
• obligation for TSO’s that information should be user led is missing.
• information provision is indicative without any warranty.
• Information provision should be an obligation of (and be paid by) TSO’s as an
ancillary services
Information provision is part of the solution and not part of the problem !
securing competitive energy for industry
118
Art 20 Long term monitoring to be included in the TYNDP
• We welcome the obligation to include the long term gas quality
monitoring in the TYNDPs.
• According to CEFIC/IFIEC outlook should be provided
–
–
–
–
on a regional level
applicable to the operational quality ranges
the expected volatility
changes of the composition of the gas
• Providing information for this outlook by upstream parties may not
be voluntary or without obligation.
The outlook include ‘only’ scenario’s of the gas quality. Customers in most
countries only rely on (expected) operational ranges. Risk and liability when gas
quality exceed the operational (and not the legal) ranges are unclear
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There are different ranges regarding the range of the Wobbe Index.
This may lead to confusion and legal uncertainty.
(Dutch) Example
Wobbe index MJ/m3 25º/0º
54
49
55,7
Max band Gas Turbine
- 5%
51.5
+ 5%
Current
Operational
Range
-2.5%
57?
+ 2.5%
Contractual range)
Legal range (Network Codes NRAs)
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Operational ranges in most countries much smaller than legal ranges
EASEEGAS range
(> 16% range)
WI MJ/m3 (15º/15º)
46,45 – 54 MJ/m3
WI MJ/m3 (25º/0º)
49 – 57 MJ/m3
13.6 – 15.81 kWh/m3
• TSO’s claim end-users can accept all gasses between the legal ranges, which
seems to be true as long the TSO’s keep the regional gas quality fluctuations in
the current – regional - limited ranges.
• Apart from The Netherlands, we have not found examples of TSO’s announcing
higher volatility of the gas quality in a range exceeding ± 5%
• End-consumers are not complaining, but for the wrong reason: due to very
limited knowledge about gas quality issues, and info about future quality changes
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Fluxys claims it is already using the whole range of the Wobbe Index
Gas supply all different sources in Belgium
But operational ranges are much smaller and there is
no exit point exposed to the whole legal range
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Even in Spain with one of the widest legal ranges the operational
ranges are very limited
LNG downloaded in ENAGAS LNG terminals
WI variation typical exit point Spain
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Source Enagas
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Conclusions
• Responsibility and liability of gas quality should be clear:
– End-users require more clarification.
– At least where the issue will we addressed and handled!
• Providing short term information (art.18):
– Transparency is key
– Information provision is part of the solution and not part of the problem
– having adequate near real time info available is a safety issue primarily !
• Providing long term information (art. 20):
– Information for the outlook from upstream parties may not be voluntary or without
obligation.
– We notice lot of misunderstanding about legal versus operational ranges.
• Customers in most countries only rely on (expected) operational ranges.
• Risk and liability when gas quality exceed the operational (and not the legal) ranges are
unclear
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Impact Assessment
Development process led by EC:
> Questionnaire to collect data:
 NRAs (coordinated by ACER)
 TSOs (coordinated by ENTSOG)
 System users
Question to system users
Odourisation: In the case of those IPs where a system is connected to another
system where odourisation takes place at different levels, do you (would you)
experience barriers to trade in both directions? Are you aware of cross-border
trade related problems? Please list examples.
>
Please send your reply to [email protected]
125
Network Code Interoperability and
Data Exchange Rules
Consultation Workshop
COFFEE BREAK….
Brussels – 20 Mar 2013
Network Code Interoperability and
Data Exchange Rules
Consultation Workshop
CLOSING REMARKS….
Brussels – 20 Mar 2013
Thank You for Your Attention
ENTSOG -- European Network of Transmission System Operators for Gas
Avenue de Cortenbergh 100, B-1000 Brussels
EML:
WWW: www.entsog.eu