electricity regional initiative central eastern european region draft report on transparency for the...

Electricity Regional InitiativeCentral Eastern European Region

Draft Report on Transparency for the CEE-Region

Jan MüllerBundesnetzagentur

ERI Central Eastern EuropeCEE Implementation Group Meeting, 4th December 2007

2 ERI Central Eastern EuropeCEE Implementation Group Meeting, 4th December 2007

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

• Goal: Harmonized implementation of Congestion Management Guidelines (CM-GL), cf. chapter 5


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

• 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 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

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 that bidding 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

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

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

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

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


Load

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

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




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



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 “natural monopolies”, 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



Generation 1/3

Licence

• 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)



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

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



BalancingResponsible 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



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



Data confidentiality 2/2Data on consumption units

Contents of the Report:• Data on outages of consumption units shall be published unit

by unit

Comment:• No publication of disaggregated values concerning

consumption units

Arguments: • 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

• 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]

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