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Introduction. Discussion of the draft Transparency Report for the CEE Region Developments in other Regions Northern Europe: Report published in September Central Western Europe: Report will be published in the next days Central Southern Europe: Report being discussed between NRAs

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Presentation Transcript
  • Discussion of the draft Transparency Report for the CEE Region
  • Developments in other Regions
    • Northern Europe: Report published in September
    • Central Western Europe: Report will be published in the next days
    • Central Southern Europe: Report being discussed between NRAs
  • Goal: Harmonized implementation of Congestion Management Guidelines (CM-GL), cf. chapter 5
framework 1 2
Framework 1/2
  • Transparency Report is not a legal act by itself
  • BUT:
    • Demonstrates common interpretation of CEE NRAs concerning transparency rules of binding Congestion Management Guidelines (cf. chapter 5)
    • Compliance with these guidelines will be monitored on basis of this common interpretation
framework 2 2
Framework 2/2
  • Implementation of transparency rules of CM-GL in a harmonized way
  • Reduction of information asymmetries
  • Enhancing comparability of market data of different countries/ regions
public consultation
Public consultation
  • Public consultation of CEE Transparency Report
    • Started beginning of October
    • Ended October 31st, 2007
  • Comments received: 15
    • 4 TSOs
    • 4 generators
    • 5 associations
    • 1 cartel office
    • 1 Market Operator
general 1 5
General 1/5

Bidding area or control area

  • Content of the Report:
    • From 2009 information shall generally be aggregated per bidding area
    • In the meantime current practice can continue (either control area or bidding area)
  • Comments
    • Confirm thatbidding area (price area) is relevant
  • Arguments:
    • NRAs share that view of market participants
    • But for some information aggregation per country or per control area/ bidding area is more appropriate
    • Timely enhancement of transparency important, therefore stepwise approach envisaged in the Transparency Report
  • No need to adapt the Report
general 2 5
General 2/5

Surveillance/ sanctions

  • Content of the Report:
    • Issue of surveillance/ sanctions not explicitly tackled in the Report
  • Comment:
    • Surveillance and sanctions are important
  • Arguments:
    • NRAs agree on importance of mechanisms for enforcing transparency requirements
    • NRAs will monitor implementation of the Report
    • Sanctions/ surveillance are tackled by national law
    • Nevertheless commitment of all market participants (e.g. TSOs, DSOs, generators, big consumption units) is important

 Remark will be considered while implementing the Report

general 3 5
General 3/5

Market transparency vs. market surveillance

  • Comments:
    • It seems as if Regulators have requested data needed for reasons of market surveillance
  • Statement of NRAs
    • Important differentiation
    • NRAs have – in earlier consultations – discussed this question very intensely
    • NRAs think that all proposed data is necessary to enhance market transparency

 Report only serves the goal of market transparency

general 4 5
General 4/5

Market time unit

  • Content of the Report:
    • As market time unit the hour has been chosen
  • Comment:
    • Quarter of an hour should be taken as basis timeframe of Transparency Report
  • Arguments:
    • Traded electricity products mostly refer to the hour
    • Choosing quarter of an hour would quadruplicate complexity as well for information providers (TSOs) as for information users (market participants)
  • Within the current framework there is no need to adapt the Report
general 5 5
General 5/5

High demands on TSOs

  • Comments:
    • Ambitious implementation timeframe
    • Double work (TSO platform/ central platform)
    • Short timeframe for information on actual outages (H+2)
  • Arguments:
    • Transparency is important
      • Decreases information asymmetries
      • Facilitates market development
    • NRAs are aware that the deadlines are ambitious

Aggregation of load data

  • Content of the Report:
    • Load data shall be published per control area/ bidding area
  • Comment:
    • Data on load should also be available per voltage level
  • Arguments
    • To estimate prices in a market it is only necessary to have data on total supply and demand of the relevant market
    • That is also valid for the electricity market

 No need to adapt Report as participants of the electricity wholesale markets need only load data (demand) aggregated per bidding area

transmission and interconnectors 1 3
Transmission and Interconnectors 1/3

Publication of usage of congestion revenues

  • Content of the Report:
    • TSOs shall publish the amount of congestion revenues for each auction
  • Comment:
    • Usage of congestion revenues should also be available
  • Arguments:
    • Was not a subject of the Transparency Report
    • Has been/ will be addressed in the report of NRAs according to point 6.5 CM-GL

 No need to adapt the Report

transmission and interconnectors 2 3
Transmission and Interconnectors 2/3

TTC, NTC, ATC data

  • Content of the Report:
    • Total available transmission capacity [NTC-value]
    • Available capacity for the auction [ATC-value]
  • Comment:
    • This data is outdated, NRAs should start directly with flow based capacity indices
  • Arguments:
    • Load flow based allocation still is to be implemented
    • Not clear which data will have to be available for flow based allocation
    • After implementation of load flow based allocation changes of this Report may be necessary

 Today no need to adapt the Report

transmission and interconnectors 3 3
Transmission and Interconnectors 3/3

Outages in the Transmission Grid

  • Content of the Report
    • TSOs have to publish data on outages in the transmission grid
    • If impact of the outage on the available transmission capacity is greater than 100 MW
  • Comment
    • Such outages do not have to be published because they are business secrets of the TSOs
  • Arguments:
    • Transmission grids are “naturalmonopolies”, therefore no competition between system operators
    • Outages in the grid may have an impact on the available transmission capacity
    • Information on such outages is relevant to the market

No need to adapt the Report

generation 1 3
Generation 1/3


  • Comment:
    • TSO has no licence for publication of data of generation/ consumption unit
  • Arguments:
    • Licence is not necessary: CM-GL – binding European law – obliges
      • TSOs to publish (point 5.5, S. 1 CM-GL)
      • Market participants to submit data (point 5.5, S. 2 CM-GL)

No need to adapt the Report

generation 2 3
Generation 2/3
  • Actual generation per unit
    • Content of the Report:
      • Information on actual generation shall be published unit by unit
    • Comments propose:
      • Aggregation per production type or
      • Aggregation as in Northern Report (per control area/ bidding area)
    • Arguments:
      • NRAs recall again the opinion that ex-post data should be published unit by unit, also supported by trading parties
      • To facilitate a harmonized approach compared to other regions aggregated publication is accepted for the time being
      • But generation companies are encouraged to publish data unit by unit on a voluntary basis (like e.g. E.ON Energie, RWE)

 Report will be adapted

generation 3 3
Generation 3/3

Forecasts on wind/ solar power

  • Comment:
    • More reliable forecast on wind/ solar power necessary/ feasible
  • Arguments:
    • Forecasts used by TSOs should be made available to the market
    • Forecasts are also sold by special forecast providers
    • Improvements of methods of forecasting are important, but cannot be influenced by Regulators

No need to adapt the Report


Responsible party for publishing data

  • Comment:
    • Market operator (MO) should be responsible for publishing data on balancing
  • Arguments:
    • CM-GL requires TSOs
    • In many countries TSO also has function of MO
    • If there is a separate MO data should be delivered to TSO

No need to adapt the Report

data confidentiality 1 2
Data confidentiality 1/2

Aggregation of data

  • Comment:
    • Aggregation per bidding area/ control area does not prevent disclosing of business secrets in some small CEE markets
  • Arguments:
    • NRAs acknowledge that this might be a problem.
    • Therefore the Report contains a remark that the competent national authority might accept diverging publication

No need to adapt the Report

data confidentiality 2 2
Data confidentiality 2/2

Data on consumption units

Contents of the Report:

  • Data on outages of consumption units shall be published unit by unit


  • No publication of disaggregated values concerning consumption units


  • Data only necessary for significant consumption units (> 100 MW)
  • Aggregation of information on outages is difficult if the same quality of information shall be maintained
  • Information per unit necessary for the market

 Report should not be adapted

further steps in the cee region
Further steps in the CEE - Region
  • Finalisation of the Report
    • will take place in the RCC this afternoon
  • Publication of the Report early 2008
  • Publication of comments
  • Monitoring of implementation

Thank you for your attention!

Jan Müller

Transmission Network Access and Cross-border Trade in Electricity

Federal Network Agency for Electricity, Gas, Telecommunications, Post and Railways

Tulpenfeld 4, 53113 Bonn

Tel: +49-228-14-5721

E-mail: [email protected]