Draft Framework Guidelines on Interoperability Rules and Data Exchange for the European Gas Transmission Networks Public Consultation - Questionnaire

16 March 2012

PC-07- PUBLIC CONSULTATION ON DRAFT FRAMEWORK GUIDELINES ON INTEROPERABILITY RULES AND DATA EXCHANGE FOR THE EUROPEAN GAS
TRANSMISSION NETWORKS

QUESTIONNAIRE

Please provide the Agency with your full contact details, allowing us to revert to you with specific questions concerning your answers.
Name:				MARIA SCHINA
Position held:			DIRECTOR OF REGULATORY AFFAIRS
Phone number and e-mail:	+302102701250	m.schina@depa.gr
Name and address of the company you represent:	DEPA S.A., M.ANTYPA 92, 141 21, IRAKLIO 								ATHENS, GREECE

1.      Scope and application, implementation (Chapter 1 of the Framework Guidelines (the 'FG')
1.1.	Do you consider that the FG on interoperability and data exchange rules should harmonise these 	rules at EU level, as follows:

a)		At interconnection points only?
	It is obvious that the FG’s provisions should harmonize the subject rules at interconnection 	points between EU member states. However, special concern is needed for rules to be applied 	at interconnection points with non-EU member states, as the upstream TSOs are not obliged to 	comply with them.
b)		Including interconnection points and where appropriate points connecting TSOs' systems to the 	ones of DSOs, SSOs and LSOs (to the extent cross-border trade is involved or market integration is 	at stake)?
	Even though the 3rd Energy Package provisions are addressed to the TSOs, we believe that if 	DSOs, SSOs & LSOs cooperated in applying the same rules, it would enhance the FG’s 	application and finally facilitate the interoperability.
c)		Other option? Please explain in detail and reason.
d)		I don't know.

1.2.	Do you consider that for any of the above options the level of harmonisation1 shall be (Section 1.b of 	the FG):
a.	Full harmonization: the same measure applies across the EU borders, defined in the network code?
	Some issues in the FG (like the units that are used or the data to be exchanged) need to be handled 	through the application of the same rules (as defined in the network code) across the EU borders. 	This is necessary for the facilitation of gas trading at EU level.
b. 	Harmonization with built-in contingency: same principles/criteria are set with a possibility to deviate 	under justified circumstances?
We consider that a harmonization with built-in contingency would be more appropriate for other issues in the FG (like the Intergovernmental Agreements or the capacity calculation) having in mind the different characteristics of the adjacent systems as well as their markets’ liquidity. Under such a scheme, the basic principles would be the same but the framework would allow for justified deviations in order to achieve smoothly the full harmonization.
Testing contingency plans would be implemented on regular basis according to common template and rules. Best practices regarding implementation of contingency plans which have been successfully applied could be an issue of cross border communication. A transition period where deviations are allowed, could be provided, so as the adjacent systems‘requirements to be fulfilled. 
c. 	No additional harmonization, meaning rules are set at national level, if they deemed necessary by 	the national authorities, which may include either NRAs or the government?

1.3. 	Shall any of the issues raised in the FG (Interconnection Agreement, Harmonization 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		x	x		x		
Partial
harmonization	x					x	
Business as usual				x			
1.4.    What additional measures could you envisage to improve the implementation of the network code? 	Please reason your answer.
	We consider that the proposed measures are pretty good for the implementation of the code on the 	ground that reasonable time shall be provided to shippers in order to adapt their practices.

2.      Interconnection Agreements

2.1. 	Do you think that a common template and a standard Interconnection Agreement will efficiently 	solve the interoperability problems regarding Interconnection Agreements and/or improve their 	development and implementation?
a.		Yes.
	Having in mind that the common template will be an obligation establishing a minimum set of 	requirements and the standard Interconnection Agreement will be a default one to be agreed 	between the adjacent TSOs, in case they fail to reach an agreement within a specific period, these 	measures are considered sufficient enough to promote the interoperability. The result should be the 	improvement of the TSOs cooperation as it affects directly the shippers.
b.		No.
c.		I don't know.

d.		Would you propose additional measures as to those proposed? Please reason your answer.
	We also believe that special concern is needed about the interconnection agreements with TSOs of 	non-EU member states, on the ground that they are not subject to the EU regulations.
	To conclude, we see that the set of rules to be covered by the standard interconnection agreement 	(scheduling process, flow control, allocation regime, measurements, data communication, etc) is of 	utmost importance to achieve a harmonized trading framework.
e.		Would you propose different measures as to those proposed? Please reason your answer.

2.2. 	Do you think that a dispute settlement procedure as laid down in the text will efficiently contribute to 	solving the interoperability problems of network users regarding Interconnection Agreements and 	their content?
a.		Yes.
	In general the current proposal seems sufficient but consideration is needed for the agreements with 	non-EU member states and the way that these rules are to be followed by them. However, the 	disputes may be minimized if the IAs are efficient.
	A dispute settlement procedure could smooth any discrepancies and contribute to the achievement 	of operational adjustment between European and non-European countries.
	
b.		No.
c.		I don't know.
d.		Would you propose additional measures as to those proposed? Please reason your answer.
e.  	Would you propose different measures as to those proposed? Please reason your answer.

2.3.     Do you think that a stronger NRA involvement in the approval of the Interconnection Agreements 	could be beneficial? Please explain in detail and reason.
a.		Yes.
To the extent that NRA shall assure the compatibility of the interconnection agreements with the EU rules and regulations deriving from the set of documents (FGs, Network Code etc), it could be beneficial. In any case the NRAs may need to be informed about the terms of the IAs.
b.		No.
c.		I don't know.

3.       Harmonization of Units

3.1.     Do you think that there is a need for harmonization of units?
a.		Yes.
	Various unit references add only complexity and costs to the daily activities of the shippers. As a 	result the harmonization of units is very important as it obviously enhances the communication 	between the participants while contributes positively to the measurement’s management.
b.		No, conversion is sufficient in all cases.
c.		I don't know.
d.		Would you propose additional measures as to those proposed? Please reason your answer.
e.   	Would you propose different measures as to those proposed? Please reason your answer.

3.2.	What is the value added of harmonizing units for energy, pressure, volume and gross calorific 		value?

a.		Easier technical communication among TSOs.
b.		Easier commercial communication between TSOs and network users.
c.		Both.
	As it is referred to 3.1 above, using the same units across EU eases both the technical and the 	commercial communication between TSOs and system users and contributes to the efficient market 	functioning, while removes any barrier to trade. 
d.		No value added.
e.		I don't know.
f.		Other views. Please reason your answer.
3.3.	Shall harmonization be extended to other units? Please reason your answer.
	We don’t see the need for such a harmonization to other units, on the ground that the subject ones 	(energy, volume, pressure and GCV) are the main units used in contractual relations between the 	stakeholders.
4.	Gas Quality
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. Would these measures 	address sufficiently the issues that are at stake? Please reason your answer.
	We consider that the measures proposed in the FG are sufficient to remove possible barriers 	(resulting from gas qualities’ differences) to cross-border trading. As the TSOs are responsible for 	the gas flows in the systems they manage, the resolution of these issues depends on the success of 	their cooperation. As a result, it is very important to establish a procedure of TSO cooperation 	aiming among others at minimizing the gas quality deviations. To this scope, a relevant information 	platform (with valid and timely information on the fluctuation of gas quality) is very useful, too.
	Gas quality platform regarding minimization of quality deviations could also be communicated to and 	accessed by the main non-European suppliers.

4.2	Do you consider that a technically viable solution to gas quality issues that is financially reasonable 	will most likely result from:
a.		Bilateral solution between concerned stakeholders.
b.		Solutions to be developed cross-border by TSOs, to be approved by NRAs and cost-sharing 	mechanism to be established.
	We consider that a solution developed cross-border by the TSOs and approved by the NRAs, 	following a market consultation, would be more appropriate. At this case, a cost-sharing mechanism 	between the adjacent TSOs could be established.
c.		The establishment of a general measure in the Framework Guidelines, setting a comprehensive list 	of technical solutions to select from.
d.		I don't know.
e.		Other option. Please reason your answer.

Draft Framework Guidelines on Interoperability Rules and Data Exchange for the European
Gas Transmission Networks Public Consultation - Questionnaire

5.	Odorisation
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.
	The present proposal seems as an adequate way of avoiding the flow of non-odorized gas. Because 	the odorisation problem is a local one, the major attempts should be made through the bilateral 	agreements so as to take into account the special needs and characteristics of the adjacent 	systems. In case of agreement failure within a specific time frame, the Code’s provisions on the 	issue will be applied, on the ground that this local problem has regional consequences. 

6.	Data exchange
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.
	Data exchange is very crucial for the gas trading. To this point, the more the data to be 	communicated the more the cross-border trading is made efficiently, while the harmonization of the 	data format is necessary for avoiding discrimination between the traders. The compatibility between 	the current provisions and that of the CAM FG is needed, regarding the data itself as well as the 	communication processes. Furthermore, it should be made clear to the TSOs that whatever 	information is at their disposal they should communicate it to the shippers, so as all the market 	participants will have the same information at the same time as the TSOs.
6.2	Regarding the content of this chapter,
a.		Data exchange shall be limited to the communication format.
b.		Data exchange shall define both format and content, at least regarding the following
	points: capacity bookings (real and estimations), gas flows (real and estimations), gas quality, 	maintenance periods (scheduled and not ones). Please reason your answer.
	Information disclosure on real time is essential for the EU market functioning, its liquidity and 	integration.
c.		I don't know.
d.		Other option. Please reason your answer.
6.3	ENTSOG may support the exchange of data with a handbook of voluntary rules. Please share your 	views about such a solution.
	We see everything that could make clear the philosophy of the communication content and process 	(exchange protocol & format, implementation guidelines etc) as a positive measure to the final 	target of enhancing the cross-border trading throughout Europe. 
7. 	Capacity calculation - the Agency view is that discrepancy between the maximum	capacities on either side of an interconnection point, as well as any unused potential to 	maximize capacity offered may cause barriers to trade.
7.1.	Please provide your assessment on the present proposal. Would the measures 	proposed address the issues that are at stake?
	The proposal seems to handle the problem sufficiently. The most important is the adjacent TSO 	cooperation in order to reduce the discrepancies between the maximum capacities on either sides 	of an interconnection point, as well as a transparent procedure of this. Again, special consideration 	is needed on interconnection with third countries.

7.2	Would you propose additional measures as to those proposed? Please reason your answer.

7.3. 	Would you propose different measures as to those proposed? Please reason your answer.

8.	Cross-border cooperation
8.1.	Please provide your assessment on the present proposal.
	As the role of cross-border cooperation is essential for the EU gas market integration, the proposal 	is in line with the general target. However, due to the fact that this scheme is a dynamic one, regular 	reviews shall be made in order to adjust the practices in accordance with the current conditions.
8.2		Do you have any other suggestions concerning cross-border cooperation? Please reason your 
	answer.
	It could be developed regarding the best practices and case studies communication within the 	member states. A common data base could also be developed, accessible to shippers and including 	the European TSOs differences regarding standards (such as basic quality ones), basic regulations, 	nomination and balancing policies, storage and LNG facilities etc. Further issues for cross-border 	communication could be: management of gas losses and own consumption and methodology of 	Unaccountable for Gas (UFG) calculation.

9.	Please share below any further comments concerning the Framework Guideline
	on Interoperability and Data Exchange Rules.
	We’d also like to note that the lack of harmonization related to the nomination procedure as a whole 	(deadlines for nomination & renomination by shippers and confirmation by TSO) is an obstacle to 	the efficient functioning of the market, as it affects the capacity allocation.

Thank you very much for your contribution. 
Agency for the Cooperation of Energy Regulators