Transcript 3.1. FG Interoperability Rules

FG Interoperability &
Data Exchange Rules
Meeting guide
3rd Ad Hoc Expert Group meeting
TITRE
Vienna, 11
June 2012
INTEROPERABILITY & DATA EXCHANGE
Agenda
Agenda Topics
10:30 – 10:40 1. Welcome & agenda of the day
10:40 – 12:00 2. Presentation of Pöyry :
“Interoperability Framework Guideline
Impact Assessment Analysis"
12:00 – 13:00
Lunch
13:00 – 16:00 3. Draft Framework Guideline discussion
Based on the outcome of the
consultation
16:00 – 16:15 4. Other issues to be addressed
15:15 – 16:30 5. Conclusions of the day
11 June 2012 – 3rd Ad Hoc Expert Group, Vienna
INTEROPERABILITY & DATA EXCHANGE
Update on consultancy study
•
Launch of the study on 2 April 2012;
•
Kick off meeting on 10 April 2012;
•
Skeleton report on 27 April 2012 – to discuss the
structure;
•
Draft Final report delivered just before midnight
on 8 June;
•
Deadline for Final report 15 June 2012.
11 June 2012 – 3rd Ad Hoc Expert Group, Vienna
INTEROPERABILITY & DATA EXCHANGE
Objectives of the study
The purpose of this study is to assist ACER in
preparing an impact assessment for the Framework
Guideline on Interoperability Rules:
•
Collect and present quantified evidence and data,
for the problem identification exercise;
•
•
•
Evaluate the policy options;
•
Propose a roadmap for implementation;
Create a coherent view;
Recommend key design
interoperability rules on;
elements
11 June 2012 – 3rd Ad Hoc Expert Group, Vienna
to
base
INTEROPERABILITY & DATA EXCHANGE
Agenda
Agenda Topics
10:30 – 10:40 1. Welcome & agenda of the day
10:40 – 12:00 2. Presentation of Pöyry :
“Interoperability Framework Guideline
Impact Assessment Analysis"
12:00 – 13:00
Lunch
13:00 – 16:00 3. Draft Framework Guideline discussion
Based on the outcome of the
consultation
16:00 – 16:15 4. Other issues to be addressed
15:15 – 16:30 5. Conclusions of the day
11 June 2012 – 3rd Ad Hoc Expert Group, Vienna
INTEROPERABILITY & DATA EXCHANGE
Agenda
Agenda Topics
10:30 – 10:40 1. Welcome & agenda of the day
10:40 – 12:00 2. Presentation of Pöyry :
“Interoperability Framework Guideline
Impact Assessment Analysis"
12:00 – 13:00
Lunch
13:00 – 16:00 3. Draft Framework Guideline discussion
Based on the outcome of the
consultation
16:00 – 16:15 4. Other issues to be addressed
15:15 – 16:30 5. Conclusions of the day
11 June 2012 – 3rd Ad Hoc Expert Group, Vienna
INTEROPERABILITY & DATA EXCHANGE
Consultation - General outcome
•
From 16 March 2012 to 16 May 2012, the Agency ran a
public consultation on the draft FG on Interoperability and
Data Exchange Rules.
•
The consultation resulted in a total of 34 responses:
6%
4% 4%
Network user
33%
10%
12%
Trader
Transmission
Industry
16%
15%
Producer
Distrbution
LNG
Storage
11 June 2012 – 3rd Ad Hoc Expert Group, Vienna
INTEROPERABILITY & DATA EXCHANGE
34 Respondents :
BDEW
CEDEC
DEPA
EASEE gas
EDISON
EDF
EDP
EFET
Enagas
ENBW
ENEL
ENI
ENI adriaplin
ENTSOG
EURELECTRIC
EUROGAS
EUROGAS
distribution
EUROMOT
EXXONMOBIL
GasLink
GasNatural Fenosa
GEODE
GDF SUEZ
GIE
GMT
GTG Nord
IFIEC/CEFIC
JP Morgan
MARCOGAZ
National Grid
Statoil
OGP
VEN
VNG
11 June 2012 – 3rd Ad Hoc Expert Group, Vienna
INTEROPERABILITY & DATA EXCHANGE
FOUNDING’S
Questions on Scope and application:
Question 1.1 : Do you consider that the FG on
interoperability and data exchange rules should
harmonise these rules at EU level, as follows:
Answers
•At interconnection points only?
• 11
•Including interconnection points and where
appropriate points connecting TSOs’ systems to the
ones of DSOs, SSOs and LSOs (to the extent crossborder trade is involved or market integration is at
stake)?
• 19
•Other option. Please explain in detail and reason?
•2
• I don’t know
•0
11 June 2012 – 3rd Ad Hoc Expert Group, Vienna
INTEROPERABILITY & DATA EXCHANGE
FOUNDING’S
Questions on Scope and application:
Question 1.2 : Do you consider that for any of the
above options the level of harmonisation shall be
(Section 1.b of the FG):
Answers
•Full harmonisation: the same measure applies across
the EU borders, defined in the network code?
• 10
•Harmonisation with built-in contingency: same
principles/criteria are set with a possibility to deviate
under justified circumstances?
• 14
•No additional harmonisation, meaning rules are set at
national level, if they deemed necessary by the
national authorities, which may include either NRAs or
the government?
11 June 2012 – 3rd Ad Hoc Expert Group, Vienna
•1
INTEROPERABILITY & DATA EXCHANGE
FOUNDING’S
Questions on Scope and application:
Question 1.3 :Shall any of the issues raised in the FG
(Interconnection Agreement, Harmonisation of units, Gas
Quality, Odorisation, Data exchange, Capacity calculation) get a
different scope from the general scope as proposed in section
1.b. of the FG (and as addressed in the previous question)?
Please answer by filling in the following table, ticking the box
corresponding to the relevant foreseen scope.
IAs
Units
Gas Quality
Odorisation
Data
Exchange
Capacity
Calculation
Full
harmonization
9
24
7
10
20
9
Partial
harmonization
16
3
19
10
6
12
8
0
3
8
2
5
Business
usual
as
11 June 2012 – 3rd Ad Hoc Expert Group, Vienna
INTEROPERABILITY & DATA EXCHANGE
FOUNDING’S
Questions on Scope and application:
Question 1.4: What additional measures could you envisage to
improve the implementation of the network code? Please
reason your answer.
•look for a trade off between an adequate timeline for the
implementation of the Network Code for operators and
network users;
•ensure for a high level of transparency in each step of the
Network Code development, both with consultation procedures
and with a clear description of reasons for the options chosen;
•harmonise the communication on works on transmission
networks.
11 June 2012 – 3rd Ad Hoc Expert Group, Vienna
INTEROPERABILITY & DATA EXCHANGE
FOUNDING’S
Interconnection Agreements (IAs):
Question 2.1: Will a common template and a
standard Interconnection Agreement do the trick?
•Yes;
•No;
•I don’t know.
•Would you propose additional measures?
•Would you propose different measures?
Answers
•8
•0
•1
• 10
•8
•support from 8 without remarks, 8/10 with additional
measures;
•different measures are expressed :
• drop the standard IA;
• limit the intervention of NRAs;
• limit the scope of the standard IA on certain topics only;
• limit an IA to TSO-TSO operational rules.
11 June 2012 – 3rd Ad Hoc Expert Group, Vienna
INTEROPERABILITY & DATA EXCHANGE
FOUNDING’S
Interconnection Agreements (IAs):
Do experts see a problem in defining a model template for IA
and a standard IA on the following topics:
• Development and Modification of interconnection agreements
• Rules for flow control;
• Measurement principles of gas quantities and quality;
• Matching;
• Rules for the allocation of gas quantities;
• Exceptional events;
• Dispute resolution between TSOs?
Did we overlook effect on connections with non-EU Member
States and/or DSOs (excluding matching and allocation?
11 June 2012 – 3rd Ad Hoc Expert Group, Vienna
INTEROPERABILITY & DATA EXCHANGE
FOUNDING’S
Interconnection Agreements (IAs):
What do experts think about the following additions:
• responsibilities for the management of metering and meter
reading activities
• the selection, for any IP, of a single point of metering;
• include a non-exhaustive list of gas quality parameters;
• coordinate on maintenance plans (as stated in NC CAM);
• make allocation rules transparent to the market;
• include a definition of “exeptional event”;
• require TSOs to act as reasonable and prudent operators at
all times
• account for “fuel gas”.
11 June 2012 – 3rd Ad Hoc Expert Group, Vienna
INTEROPERABILITY & DATA EXCHANGE
FOUNDING’S
Interconnection Agreements (IAs):
Question 2.2: Is the dispute settlement procedure OK? Answers
• 13
•Yes;
•1
•No;
•2
•I don’t know.
•2
•Would you propose additional measures?
•7
•Would you propose different measures?
•support from 13 respondents to the measure;
•main objection: the procedure is related to the national legal
system agreed and shippers can always call on the national
regulatory authority in charge of energy issues;
11 June 2012 – 3rd Ad Hoc Expert Group, Vienna
INTEROPERABILITY & DATA EXCHANGE
FOUNDING’S
Interconnection Agreements (IAs):
What do experts think about the following additional measures
asked in relation to the dispute settlement procedure:
• the installation of a timely and efficient dispute procedure;
• a consultation on its design;
• delays to be set clear;
• detailed rules in Framework Guideline and Network Code and
the consequence for the agreements with non-EU member
states is to be reflected on?
11 June 2012 – 3rd Ad Hoc Expert Group, Vienna
INTEROPERABILITY & DATA EXCHANGE
FOUNDING’S
Interconnection Agreements (IAs):
Question 2.3: Do you want stronger NRA involvement
in the approval of the IA?
•Yes;
•No;
•I don’t know.
Answers
• 16
•8
•2
•support from 16 respondents measures;
•To include another 4 if the stronger involvement of NRAs, and
in last resort ACER, is limited to specific situations, e.g. if the
TSOs have difficulty in reaching an agreement;
11 June 2012 – 3rd Ad Hoc Expert Group, Vienna
INTEROPERABILITY & DATA EXCHANGE
FOUNDING’S
Units:
Question 3.1: Do you think that there is a need for
harmonisation of units?
•Yes;
•No;
•I don’t know.
•Would you propose additional measures?
•Would you propose different measures?
Answers
• 27
•1
•0
•0
•1
•Can standardised conversion rules or conversion factors (to
be specified including the decimal factors to be used) stand in
as an alternative? (TSO-TSO);
• How to decide on the timing of the introduction of
harmonised units in conjunction to other interoperability
harmonisation, such as IT systems?
11 June 2012 – 3rd Ad Hoc Expert Group, Vienna
INTEROPERABILITY & DATA EXCHANGE
FOUNDING’S
Units:
Question 3.3: Shall harmonisation be extended to
other units?
•Yes;
•No.
Answers
• 12
• 11
• gas quality and quantity parameters are suggested;
• the use of the euro for information is proposed;
• the publication of an official conversion table is asked.
Several respondents ask for a supplementary rule to use units
in a consistent way throughout the logistic chain of TSO
services, from capacity booking till allocation of gas.
11 June 2012 – 3rd Ad Hoc Expert Group, Vienna
INTEROPERABILITY & DATA EXCHANGE
FOUNDING’S
Gas Quality:
Question 4.1 - Please provide your assessment on the present
proposal; in particular assess the provisions on ENTSOG gas
quality monitoring, dispute settlement and TSO cooperation?
19 out of 33 responses assess positively one or more parts of
the current proposal.
Detailed modifications to the text are proposed :
• to protect shippers from extra charges and contract change;
• to mention gas quality also in the IA;
• to set the rules on interconnection points;
• to reconsider the implementation time.
11 June 2012 – 3rd Ad Hoc Expert Group, Vienna
INTEROPERABILITY & DATA EXCHANGE
FOUNDING’S
Gas Quality:
What do experts think about the following positions:
• The information provision should be tackled at national level,
because:
• not all TSOs have direct obligations with end users;
• the need for such a service is likely to vary based on the
types of industrial consumers that are connected to a
TSO’s network;
• depends on relatively wide or relatively narrow national
quality specifications;
• possible confidentiality issues;
• Questioning the feasibility of the gas monitoring, because
data is held upstream and sometimes confidential;
11 June 2012 – 3rd Ad Hoc Expert Group, Vienna
INTEROPERABILITY & DATA EXCHANGE
FOUNDING’S
Odourisation:
Question 5.1 Please provide your assessment on the present
proposal. Would the measure proposed address sufficiently the
issues that are at stake? Please reason your answer?
21 out of 30 responses agree that there is an issue with
odourisation.
How is the role of Member States to be defined?
Is the measure useful if reassurance is given that the default
rule (non-odourised gas at IPs) shall not be approved while
there is not any evidence for the need of it? How to define
“evidence” and who to be set responsable?
11 June 2012 – 3rd Ad Hoc Expert Group, Vienna
INTEROPERABILITY & DATA EXCHANGE
FOUNDING’S
Data Exchange:
Question 6.1.: Please provide your assessment on the present
proposal. Would the measures proposed address sufficiently the
issues that are at stake? Please reason your answer?
16 out of 24 associations or companies assess the present
proposal positively.
How do we look towards:
• one unique communication platform for the whole of Europe;
• to harmonise on content;
• to be specific on the timescales for implementation (in
conformity with the other Framework Guidelines)
11 June 2012 – 3rd Ad Hoc Expert Group, Vienna
INTEROPERABILITY & DATA EXCHANGE
FOUNDING’S
Data Exchange:
Question 6.2.: Regarding the content of this chapter,
... b. Data exchange shall define both format and content, at
least regarding the following points: ______________(21/26).
• Specific points are given;
• Or reference is made to other FG/NC;.
How to decide on including content >< flexibility?
How to position voluntery rules >< binding rules?
11 June 2012 – 3rd Ad Hoc Expert Group, Vienna
INTEROPERABILITY & DATA EXCHANGE
FOUNDING’S
Capacity Calculation:
Question 7.1 Please provide your assessment on the present
proposal. Would the measures proposed address the issues that
are at stake?
Is there support including in the Framework Guideline a
common approach to the capacity definitions (baseline,
technical, additional and interruptible) in accordance with
paragraph 3.3 of Annex 1 to the Gas Regulation?
• Expending the rules also to additional and interruptible;
Is it helpful to focus more for a joint calculation of capacity,
using a single model, aiming to reproduce what an ISO would
do if they had responsibility for both systems and an obligation
to maximize the capacity that could be offered?
11 June 2012 – 3rd Ad Hoc Expert Group, Vienna
INTEROPERABILITY & DATA EXCHANGE
Next Steps
11/06: Ad Hoc Experts group meeting & Meeting with Pöyry
12/06: Task Force meeting – Finalisation of Framework Guideline
text according to consultation comments
21/06: Task Force deadline for :
Evaluation of Comments paper;
Impact Assessment paper
Final Framework Guideline text
31/07: ACER deadline
process
to
finalise
the
Framework
11 June 2012 – 3rd Ad Hoc Expert Group, Vienna
Guideline