Reported issues

Issue subject Abstract Member State(s) concerned IP(s) concerned Status
Communication protocol and encryption
Companies very connected to the gas business (market area operators and storage operators) tell they do not need to follow article 23 of the network code of interoperability
Germany (DE) In progress
Harmonised Gas Role Model Specification From the Business Process perspective
EASEE-gas put together a role model for the gas sector with the objective of providing a common terminology for the roles that are used among most European countries. The document identifies and defines the different roles carried out within the gas market from a business process point of view. The main focus of this document is on information exchange between market participants (excluding legal matters). It is based on the existing descriptions of business processes in the gas market (ENTSOG BRS; EASEE-gas CBP and MIG as well as the input provided by the Task Force participants). European regulations and common aspects of national regulations were also considered.
  • Austria (AT)
  • Belgium (BE)
  • Bulgaria (BG)
  • Croatia (HR)
  • Cyprus (CY)
  • Czech Republik (CZ)
  • Denmark (DK)
  • Estonia (EE)
  • Finland (FI)
  • France (FR)
  • Germany (DE)
  • Greece (EL)
  • Hungary (HU)
  • Ireland (IE)
  • Italy (IT)
  • Lithuania (LT)
  • Latvia (LV)
  • Luxemburg (LU)
  • Malta (MT)
  • Netherlands (NL)
  • Northern Ireland (UK)
  • Poland (PL)
  • Portugal (PT)
  • Romania (RO)
  • Slovakia (SK)
  • Slovenia (SI)
  • Spain (ES)
  • Sweden (SE)
  • United Kingdom (UK)
In progress
Communication protocol and encryption
Market area operators are implementing changes to the AS2 protocol and forcing market participants to adapt their IT-systems to these changes. Market participants have implemented AS4 according to the NC Interoperability. AS4 contains the requested functionality and if market area operators implement it in accordance with NC interoperability, the change to AS2 and the related efforts and costs for market participants would be obsolete. However, market area operators put forward an argument that they do not have to comply with the NC Interoperability.
Germany (DE) VTP NCG In progress
Communication protocol and encryption
Market Area Operators (in particular in Germany) are making changes to the AS2 protocol (new encryption) instead of following the corresponding articles (21 – 23) on data exchange of NC Interoperability regulation.
Germany (DE) NCG, GASPOOL In progress
Methodology for domestic/transit transmission
Due to historical developments, some transimission systems are designed to provide sufficient capacities to large transit flows. TAR NC regulation does not deal with this situation. Insisting on one methodology for all points is causing discrepancy with the Directive 2009/73/EC, which obliges not to move the transit capacity risk to customers within E/X systém.
Czech Republik (CZ) Withdrawn
Ambiguity in text of Regulation 459/2017 (NC CAM) regarding the way of implementation of virtual interconnection points (VIPs)
In art. 19.9 of NC CAM it is stated that TSOs shall implement functional virtual interconnection points (VIPs) where two or more Interconnection Points (IPs) connect the same two adjacent entry-exit systems. Because of a recent letter from the European Commission (EC) containing its interpretation of the condition in art. 19.9 (a) NC CAM, TSOs are faced with uncertainty about the implications hereof for the implementation process. The EC interpretation differs from the chosen approach of TSOs and introduces the risk that shippers could challenge the way TSOs implement VIPs or even challenge the introduction itself, with the aim to cancel their capacity contracts. We think this ambiguity should be taken away by adapting the NC CAM.
  • Austria (AT)
  • Belgium (BE)
  • Bulgaria (BG)
  • Croatia (HR)
  • Cyprus (CY)
  • Czech Republik (CZ)
  • Denmark (DK)
  • Estonia (EE)
  • Finland (FI)
  • France (FR)
  • Germany (DE)
  • Greece (EL)
  • Hungary (HU)
  • Ireland (IE)
  • Italy (IT)
  • Lithuania (LT)
  • Latvia (LV)
  • Luxemburg (LU)
  • Malta (MT)
  • Netherlands (NL)
  • Northern Ireland (UK)
  • Poland (PL)
  • Portugal (PT)
  • Romania (RO)
  • Slovakia (SK)
  • Slovenia (SI)
  • Spain (ES)
  • Sweden (SE)
  • United Kingdom (UK)
Solved
Ex-post interruptible capacity discounts
Article 16.4 allows NRAs to apply ex-post discounts under certain circumstances. The Article sets the level of ex-post compensation at three times the reserve price for daily firm products, for each day when an interruption occurs.
ENTSOG proposes that ex-post compensation should apply proportionately to the capacity interrupted on an hourly basis, that NRAs may allow this, and that NRAs may also determine a cap on the reimbursement amount.
This interpretation does not adequately compensate shippers for capacity interruptions, and does not properly incentivise TSOs to avoid interruptions – especially where they may span over the change in a gas day.
  • Austria (AT)
  • Czech Republik (CZ)
  • Hungary (HU)
  • Poland (PL)
  • Romania (RO)
  • Slovakia (SK)
  • Slovenia (SI)
See attached file 01 Solved
Communication protocol and encryption
There is an ambiguity in determining which standards apply in setting up electronic data communication with market participants. AS2 and AS4 are clearly the two protocols most used in electronic data exchange in the European gas market today. We interpreted the NC on interoperability and specifically the chapter on data exchange that AS4 should be seen as the sole common protocol for the future. We see now that the German market is still developing evolutions on the AS2 protocol. We also see that certain stakeholders consider themselves not obliged to follow the NC. Would it be possible to have a more aligned view on electronic data communication for all market participants? This would lower operational cost related to setting up the ICT systems supporting the electronic market transactions and enable quicker time to market for new demands.
  • Austria (AT)
  • Belgium (BE)
  • Bulgaria (BG)
  • Croatia (HR)
  • Cyprus (CY)
  • Czech Republik (CZ)
  • Denmark (DK)
  • Estonia (EE)
  • Finland (FI)
  • France (FR)
  • Germany (DE)
  • Greece (EL)
  • Hungary (HU)
  • Ireland (IE)
  • Italy (IT)
  • Lithuania (LT)
  • Latvia (LV)
  • Luxemburg (LU)
  • Malta (MT)
  • Netherlands (NL)
  • Northern Ireland (UK)
  • Poland (PL)
  • Portugal (PT)
  • Romania (RO)
  • Slovakia (SK)
  • Slovenia (SI)
  • Spain (ES)
  • Sweden (SE)
  • United Kingdom (UK)
VTP NCG In progress
Capacity booking issues regarding timing and comparability of day-ahead auctions
The short 30-minute time window for the day-ahead (DAH) auction does not always allow for issues to be solved by the end of the auction window.

As a result the DAH auction fails which leads to market participants not being able to balance their positions and the next opportunity to buy a full 24 hour product is the next within-day (WID) capacity auction. However, the WID products are not always like-for-like DAH products.

  • Austria (AT)
  • Belgium (BE)
  • Czech Republik (CZ)
  • France (FR)
  • Germany (DE)
  • Italy (IT)
  • Netherlands (NL)
  • United Kingdom (UK)
Acknowledged
TSO data reliability issues regarding technical and available capacity on their website
In some cases GM&T observes incorrect TSOs data on their websites. For example, shippers might find that available capacity published on the TSOs' website is actually not offered in the auction platform. TSO's explanation is that misleading information regarding available capacity between the auction platform and their websites is due to errors in their systems.

  • Germany (DE)
  • United Kingdom (UK)
e.g. Bacton, Olbernhau, Wallbach Solved

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