Transcript PP XII - GRI SSE AEEGSI E-Control 2015_11_16 _ver 3

Pilot project XII:
Questionnaire for the assessment of
the main features of
gas system implementation in SSE
countries
Regulatory perspectives
GRI SSE TITRE
–Bucharest, 20 November 2015
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GRI SSE – pilot project XII
Questionnaire for the assessment of the main features of
gas system implementation in SSE countries
The hereby questionnaire is part of the activities described and included in
GRI SSE Work Plan 2015-2018. The purpose of this survey is to examine the
harmonization level of gas systems in the framework of the Third Energy
Package implementation within the South South-East Gas Region. On the
basis of the collected data, project promoters will prepare a report which will
present the current situation in the Region.
According to recital n. 19 of Regulation 715/2009/EC “To enhance competition
through liquid wholesale markets for gas, it is vital that gas can be traded
independently of its location in the system. The only way to do this is to give
network users the freedom to book entry and exit capacity independently,
thereby creating gas transport through zones instead of along contractual
paths. The preference for entry-exit systems to facilitate the development of
competition was already expressed by most stakeholders at the 6th Madrid
Forum on 30 and 31 October 2002. Tariffs should not be dependent on the
transport route. The tariff set for one or more entry points should therefore
not be related to the tariff set for one or more exit points, and vice versa”.
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GRI SSE – pilot project XII
Countries involved and replies received
by May 2015
MS SSE
Poland
Czech Republic
Slovakia
Austria
Italy
Hungary
Slovenia
Croatia
Romania
Bulgaria
Greece
Questionnaire sent
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Gas infrastructure Respondents
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18 questions
Contracting Parties
Bosnia Herzegovina
Serbia
Montenegro
UNMI Kosovo
Albania
FYR of Macedonia
Ukraine
Moldavia
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GRI SSE – pilot project XII
Q1: Has an entry-exit system been implemented in your country that gives network users the freedom
to book entry and exit capacity independently?
If not, please specify:
 when it is going to be introduced.
 which are the conditions that hamper the introduction of a full entry exit system.
All the countries declared to have in place the entry-exit system,
except FYR of Macedonia and Ukraine,
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GRI SSE – pilot project XII
Q2: Does your regulatory framework foresee capacity products with limitation of free allocability
(limited access to the VTP, locational and/or temporal restrictions, etc.)?
 If yes please describe these products.
In all countries there are no capacity products with limitation of free allocation
except Austria and Ukraine.
Austria has in place DZK capacities and short-haul
capacities
Hungary, Romania, Serbia, still
have historical P2P contracts
which limit the access to VTP for some routes.
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GRI SSE – pilot project XII
Q3: Are there still point-to-point (P2P) routes in place? No,
If you still have P2P routes in place, please:
 List the P2P routes;
 describe the reasons;
 Specify whether you plan to dismiss P2P tariffs or if they are permanent tariffs;
In all countries there are no point-to-point routes in place except for special routes in Hungary, Romania and
Serbia.
Hungary
currently there is a possibility to
book P2P route on a monthly and
daily basis at certain cross border
network points, in case of special
circumstances:
- just for cross–border deliveries
- if the shipper hasn’t got HU
trading licence
- and if at one of the related IPs
FGSZ is able to offer only
interruptible capacity,
Romania
No, with the exception of
three pipelines (IsacceaNegru Vodă) which are
not interconnected with
the National Transmission
System. Due to the
agreements and
conventions with Russian
Federation. The P2P
tariffs will be dismiss as
The same entry + exit tariff is
contracts and agreements
applicable in this case. This P2P
ending. Under discussion
service will most probably phased
is one of the third
out by 1 November 2015, due to
pipelines, which contract
the fact that CAM NC compliant
will end on December 31,
interruptible capacity booking
2015.
procedures have been introduced
recently.
Serbia
P2P tariffs do not exist,
only one network user
pays network UoS charge
in line with transit longterm contract which
expires in 2018. P2P
Horgos – Zvornik due to
long term contract. P2P
tariffs are not envisaged
according to our entryexit tariff system, so they
are expected to be
dismisses once the long
term contract is
terminated.
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GRI SSE – pilot project XII
Q4: Is there a virtual trading point in your country?

the VTP?
Can you please briefly describe which requirements are to be fulfilled to operate actively at
Virtual trading points are in place in Austria, Croatia, Czech Republic,
Greece, Hungary, Italy, Poland, Romania, Serbia and Slovenia.
No VTP in Ukraine and in FYR of Macedonia
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GRI SSE – pilot project XII
Q5: Does the virtual trading point cover also functionalities and services of a gas exchange?
Virtual trading points cover functionalities and service of a gas exchange in
Austria, Czech Repuplic, Hungary, Poland.
It is not in place in Croatia, Greece, FYR of Macedonia, Romania, Serbia,
Slovenia, and Ukraine
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GRI SSE – pilot project XII
Q6: Is there a gas exchange in your country?
 Can you please briefly describe which requirements are to be fulfilled to operate actively at
the gas exchange?
Gas exchange in place in Austria, Czech Republic, Hungary, Italy,
Poland, Romania*.
It is not in place in Croatia, Greece**, FYR of Macedonia, Serbia,
Slovenia and Ukraine
**In Greece there is a gas release program from the incumbent operator
* the trading platforms operators are no counterparties
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GRI SSE – pilot project XII
Q7: Have TSOs in your country already started pilot projects for the early implementation of network
codes?
 If yes please briefly specify in which field
Pilot projects for the early implementation of network codes already started in
Austria, Greece, Hungary, Italy, Poland, Romania and Slovenia.
Croatia, Macedonia and Serbia have never carried
out PP and
Ukraine is going to introduce one PP in
cooperation with Poland.
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GRI SSE – pilot project XII
Q8: If TSOs from your country have already started a pilot project for the offer of bundled capacity,
please specify which of the following bundling concepts have already been tested by each of these TSOs?
 Process bundling, i.e. the bundled allocation of capacity with separate contracts with two
TSOs; At the present moment just process bundling has been implemented.
 Product bundling, i.e. on top of process bundling, ensuring the same conditions regarding
the quality and usage of the capacity in the bundle.
Process bundling in Austria, Czech Republic, Italy, Poland, Slovenia.
Product bundling in Hungary.
Romania asserts that both bundling concepts
are implemented in the operational rules of the
RBP.
No PP on bundled capacity in Croatia,
Greece, FYR of Macedonia, Serbia and
Ukraine
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GRI SSE – pilot project XII
Q9: What kind of standard cross-border capacity products (as defined by art. 9 of Commission
Regulation No. 984/2013) does each TSO from your country currently offer?
yearly
quarterly
Austria
Croatia
Czech Rep
x
x
x
x
monthly
x
x
x
D-ahead
x
x
x
within day
Greece
Hungary
Italy
x
Under the EU and the
national legislation
CAM NC complaint
products have been
No standard introduced in Hungary
cross-border as of 1 October 2015.
capacity Accordingly, the yearly
products
and annual quarterly
have been capacity allocation has
defined yet already been completed
for firm cross-border
capacity products on 11
May and on 1 June,
respectively
x
FYR of
Macedonia
Poland
Romania
Serbia
x
x
x
x
x
x
Slovenia
Ukraine
x
Gaz-System offers yearly (4
years in ahead), quarterly,
monthly and day-ahead
cross-border capacity
products. Both firm and
interruptible. Day-ahead and
within-day products are
available without auction
procedure which will be
implemented in Polish
Transmission Network Code
before 1st Nov 2015.
Monthly standard
x
capacity products will
be offered from 01.
October 2016 latest
and daily standard
capacity products will
be offered from 01.
July 2017 latest.
x
x
x
There are no standard
cross-border capacity
products foreseen in the
regulatory framework
now. They can be
introduced after the 1st
of October, 2015 (when
Transmission Network
Code will be approved in
compliance with the
requirements of the 3rd
Energy Package).
x
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GRI SSE – pilot project XII
Q10: Do any of TSOs from your country offer capacity products at CAM IPs which are not compliant
with CAM Regulation? Please specify the characteristics of these products.
Austria
Greece
Hungary
Poland
There is an Open Season
Procedure run by
Magyar Gáz Tranzit Zrt.
In compliance,
and eustream at the
also short-haul
Hungarian-Slovak IP,
We are in the process
capacity at the IP
which aim to allocate
of implementation of
Überckern
Implementation non-standard products auction mechanisms
ABG/SÜDAL
of NC CAM is from the point of view of dedicated to short
between Germany
ongoing.
CAM NC. The product is term products (dayand Austria is
called “joint capacity,” a ahead and withinoffered and
product between
day).(see Q9)
auctioned at
unbundled and bundled
Prisma platform
capacity. The duration of
this capacity product is
15 months.
Romania
Serbia
TSO offers yearly
capacity products
only monthly
products
(starting on the 1 st of
July). Capacity
products are defined
in Netwok code has
been adopted
before CAM. Goal
was to be in line
with adjacent TSO
(FGSZ in Hungary)
where gas year
starts on the 1 st of
July.
Ukraine
There are no capacity
products foreseen in
the regulatory
framework now. They
can be introduced after
the 1st of October,
2015 (when
Transmission Network
Code will be approved
in compliance with the
requirements of the
3rd Energy Package).
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GRI SSE – pilot project XII
Q11: Explain under which conditions a firm capacity product is considered as such under your
regulatory framework.
Austria
Croatia
Czech Rep
Greece
Hungary
Italy
Under the NNGS Network
TSO can restrict the
firm capacity
usage of firm product
product is
due to unplanned or
considered as
planned maintenance
defined in Reg
acivities. In the last case
(EC) 715/09,
Poland
Romania
Serbia
Slovenia
Ukraine
Code (2nd amendment) we
have the following
According to the
definitions:
Committed Delivery
Transmission Capacity:
The maximum Quantity of
it is possible for the TSO
while
to keep the
interruptible
It is a product
transportation fees if
capacity is
which can not
the maintenance
defined by
be interrupted,
activities are
Network code
i.e. the shipper
communicated at least
for gas
is guaranteed
42 days in advance . If
transmission as
to be able to
this is not the case, the
“capacity of the
use booked
TSO have to give back on
transmission
capacity.
pro rata basis and for
system which
the time the
Transmission
interruption take place
System
the tariff fee paid by
Operator has a
shippers.
right to restrict
or totally deny
FYR of
Macedonia
Natural Gas per Entry
Point to which the
Operator commits to
being able to receive from
the Transmission User, per
Day at the specific Entry
Point,
Committed Reception
Transmission Capacity:
The maximum Quantity of
Natural Gas per Exit Point,
to which the Operator
commits as being able to
deliver to the Transmission
Law 123/2012
A firm capacity
When making
the firm capacity
can effectively
available firm
is the capacity
can be
capacity, the TSO
contractually
interrupted
shall provide the
guaranteed as
only in
capacity
network user
uninterruptible
emergency
products
be interrupted
in an
extraordinary
(emergency)
situation but for
no other reason
(such as
temperature,
routing, change
of predominant
Firm transportation
servises can be
interrupted for
maintance and
emergecy situations.
The yearly planned
maintenance
interruption time is
give for each IP by the
TSO in advance
Firm capacity
with guaranteed
by the TSO. An
cases or during
access to such
interruptible
the
capacity except
capacity is the
maintanance
for the periods of capacity that can
period defined
There are no
firm capacity
offered
according to
Regulation
715.
foreseen in the
regulatory
framework
now. They can
agreed
be interrupted by
in advance
scheduled
the TSO, in
between TSO,
after the 1
maintenance or
accordance with
network user
October, 2015
flow direction
emergency
the conditions
and final
etc.).
situations
specified in the
customer.
be introduced
contract with the
network user.
User, per Day at the
specific Exit Point,
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GRI SSE – pilot project XII
Q12: Are there more classes of interruptible products? Explain under which conditions interruptible
capacity products are defined.
One class: Slovenia, Austria, Croatia, Czech Republic, Hungary, Poland,
Serbia, Greece
More classes: Italy (1st and 2nd level)
Romania and FYR of Macedonia: not defined yet
Ukraine, no capacity products foreseen in the
regulatory framework now, they can be
introduced after the 1 October, 2015.
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GRI SSE – pilot project XII
Q13: With reference to CMP provisions, do you have the same set of rules as applied by your
neighbouring countries?
If not, please describe which problems do you face at each IP in relation to the CMP implementation and
which solutions have you already discussed?
Austria
Croatia
Czech Rep
there is still
need to fine
tuning the
CMP rules at
both ides of
IPs.
CMP provision
were consulted
with
neighbouring
NRAs before
putting into
use. So far no
problems were
noticed
(currently
there is no
contractual
congestion at
IPs).
We are awere
that the set of
rules are not
fully the same.
On the Czech
side of the
border, there
are sufficient
amounts of
capacities,
thefore no
CMP
procedure has
been applied.
Greece
Hungary
Italy
Poland
Romania
Serbia
Slovenia
Different CMP
All CMP
rules apply at
provisions are
need of fine
the border
At the
applied to the
tuning with
CMP rules are
The CMP
between
moment we
Greek side of
Austria due to
No. From our not the same.
measures are
Poland and
are aware
the GR-BG and
differnet FDA
information We do not face
not
Germany.
that we treat
GR-TU
mechanism. At
Transgaz did any problem on
harmonised
Oversubscripti
differently the
interconnectio
the moment,
not have
IPs because
with any of
on and buyprocess of
s. RAE has no
we are not
discussions
there was not
the adjacent
back
surrender
information
facing any
with
“physical and
TSOs yet but
mechanism vs.
capacity
on the level of
problem
neighbouring
contractual
this has not
firm daymechanism
implementatio
because the
TSOs on this
congestion”in
created any
ahead use-itcomparing to
n of the CMP
Italian EU IPs
issue.
the last few
issues so far.
or-loose-it
our Austrian
provisions in
are not
years.
mechanism.
neighbours.
the Bulgarian
congested.
side.
Ukraine
CMP
provisions are
not obligatory
for the
Contracting
Parties of the
Energy
Community.
Currently CMP
provisions are
not
implemented.
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GRI SSE – pilot project XII
Q14: How is the gas year defined in your country?
Starting on October 1st –October 1st : Austria, Croatia, Czech Rep,
Hungary, Italy, Poland, Slovenia, and Romania.
Starting on January 1st –January 1st : Greece and FYR of Macedonia.
Starting on July 1st – July 1st : Serbia.
Ukraine: not define currently, but starting from
1 October 2015 according to CAM NC
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GRI SSE – pilot project XII
Q15: How is the gas day defined in your country?
06:00 - 06:00 CET: Austria, Croatia, Czech Republic, Hungary, Italy*,
Poland, Romania** and Slovenia
08:00 - 08:00 CET: Greece, FYR of Macedonia
and Serbia
Ukraine: not define currently, but starting from
1 October 2015, will be set according to
CAM NC
* 06:00 - 06:00 in winter and 05:00 - 05:00
daylight saving time
** CET+1
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GRI SSE – pilot project XII
Q16: According to art. 27 of Commission Regulation No. 984/2013, TSO shall offer “capacity by means
of one or a limited number of joint web-based booking platforms”.
 Which platform for primary capacity booking is used by TSOs in your country or
planned to be used?
 If a different platform is used by the adjacent TSO from one of your neighbouring countries,
have you already discussed measures to overcome matching problems at the IPs involved?
If yes, please describe the discussed model(s).
Prisma:
RBP:
Gaz System Auctions:
Austria, Czech Republic, Italy, Slovenia
Hungary, Romania
Poland, Czech Republic 1 IP
Croatia, Greece, FYR of Macedonia, Serbia and Ukraine
have no platform complaint to the Regulation
No. 984/2013
Serbia: platform is currently under development.
but only for unbundled products.
In between Baringa study promoted by
ACER fix the point on the current situation
but no effective steps have been taken for IPs
with different platforms
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GRI SSE – pilot project XII
.
Q17: Is there a secondary capacity trading platform?
Is the platform for trading secondary capacity the same as through which primary capacity is
allocated?
Platform for trading secondary capacity not in place:
Greece, FYR of Macedonia, Romania, Serbia, Ukraine,
Platform for trading secondary capacity in place:
Austria (Prisma),
Croatia (TSO),
Czech Republic (TSO),
Hungary (TSO, RPB),
Italy (Prisma, other platforms)
Poland (GSA),
Slovenia (TSO).
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GRI SSE – pilot project XII
Q18: Having in mind the accomplishment of the European Energy market and notwithstanding the above
list of questions, have you already recognized specific points of your regulation which hamper the crossborder trade of gas?
Self-criticism:
No open and recognized points which hamper the cross-border trade of gas: Slovenia,
Austria, Czech Rep, Greece*, Italy*, Romania, Serbia
Croatia
Currently, cross-border trade of
gas could be further fostered by
full harmonisation of
interoperability rules by
neighbouring countries’ TSOs. As
for national regulations,
introduction of quarterly capacity
products and intraday capacity
products would be beneficial –
development in progress.
Hungary
the licensing of trading
activities
Poland
specific obligations dedicated to
storages and diversifying the
sources of supply. Storage
obligations in Poland are defined as
the requirement to book and keep
gas in store for any import above
100 mcm. According to shippers,
such an obligation discourages new
market players from entry into our
market.
We were also reported about
difficulties connected with
diversification obligation. According
to our national legal framework, the
maximum volume of gas imported
from one country of origin cannot
exceed 59% at the given year.
*amendment of the current gas legislation are ongoing
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GRI SSE – pilot project XII
THANK YOU !
GRI SSE – Bucharest, 20 November 2015
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Definitions
Gas market
The sum of gas (wholesale) trading activities (spot to forward (inclusive)) with delivery
agreed on a (single) specific delivery hub.
Hub
The virtual trading point of an entry/exit system where the TSO (or a separate
independent entity dedicated at national level) handles all nominations for the transfer of
title to gas between network users (or balancing accounts)
Transparent
market
The sum of gas trading activities (spot, prompt and forward) with delivery agreed on a
(one) specific delivery point and concluded using a transparent trading venue (i.e.
exchange, broker platform).
Note: the main delivery points are the virtual trading points of entry/exit systems. Distinct
delivery points are considered as separate markets.
Virtual trading
point
A notional point in an entry/exit system at which natural gas can be traded within the
entry/exit system after injection and before offtake.
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