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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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  • 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


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