Reported issues

Issue subject Abstract Member State(s) concernedsort descending IP(s) concerned Status
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)
Closed
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 Solved
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)
Solved
Inconsistencies in the publication of reserve price information prior to the annual yearly capacity auctions
In order to form capacity booking strategies and facilitate efficient portfolio management traders need to know, with certainty, what reserve prices will apply for at least the forthcoming gas year before the yearly capacity auctions, along with any multipliers and seasonal factors for short term capacity products. To the extent such information is not provided, or provided inconsistently, traders face unmanageable price risk and may flow gas sub-optimally, which creates market inefficiency. A review of the information published prior to the most recent yearly capacity auctions will serve to improve the completeness and consistency of data published in future years.
  • Austria (AT)
  • Belgium (BE)
  • Bulgaria (BG)
  • Croatia (HR)
  • 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)
  • Netherlands (NL)
  • Northern Ireland (UK)
  • Poland (PL)
  • Portugal (PT)
  • Romania (RO)
  • Slovakia (SK)
  • Slovenia (SI)
  • Spain (ES)
  • Sweden (SE)
  • United Kingdom (UK)
All relevant CAM NC IPs Solved
Missing harmonisation of interfaces on capacity platforms
Today there are 4 capacity platforms (Prisma, Gaz System, GBS (Gassco booking site) and a Hungarian platform). There is also more to come. In addition TSO's are also running some capacity processes like overnomination and interruptable capacities via their own sites. In the common data exchange solutions table from ENTSOG it was decided that for capacity interactive data exchange should be used. In our opinion this have created a situation where some of the processes is harmonised but the data exchange and platforms are completely different. This makes it difficult for network users (Balancing responsible parties) to keep track of their capacity and to get an overview of options available for transporting the gas in Europe and also the cost involved to do so.
  • 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
BRS for balancing
The business requirements specification for nomination and matching procedures is referencing the Network code on Gas Balancing of Transmission Networks but is only decribing small parts of the network code. This can create a situation where TSO's think they are compliant with the network code by implementing what is included in the nomination and matching BRS but that is only covering the nomination and matching process and is missing out on many of the other balancing parts.
  • 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
Capacity trading platforms - absence of harmonisation across Europe
An automatization of capacity trading process (Follow-up on overall available capacity at a connection point, Capacity booking and surrender, Follow-up on portfolio capacity availably) currently requires :
- Development of a specific interface for Prisma booking as well as evolving it to follow changes
- Development of a specific interface with GazSystem as well as evolving it to follow changes
- Development of a specific interface with Gassco as well as evolving it to follow changes
- Development of a specific interface with FGSz as well as evolving it to follow changes
- Development of a specific interface with National Grid as well as evolving it to follow changes
- Taking into account of a TSO management for over-nomination or curtailments
Entsog's common exchange solution table defines interactive date exchange for capacity trading. That'll very likely mean that in addition to the listed above a network user will have to implement more specific interfaces with the market developing further (Greece, Ukraine, Baltic countries ...)
  • Austria (AT)
  • Belgium (BE)
  • Czech Republik (CZ)
  • France (FR)
  • Germany (DE)
  • Hungary (HU)
  • Netherlands (NL)
  • Poland (PL)
  • United Kingdom (UK)
In progress
Auction restrictions NCG
Since 2017, restrictive conditions have been announced by the TSO on the PRISMA platform for all annual and quarterly auctions in the German NCG market area. Apparently, the German Federal Network Agency for Electricity, Gas, Telecommunications, Post and Railway (Bundesnetzagentur, BNetzA) requested all TSOs operating in the NCG market area to re-allocate capacities after the annual and quarterly auctions. These restrictions on capacity marketing at interconnection points in the NCG market area are contrary to Article 8 NC CAM.
  • Austria (AT)
  • France (FR)
  • Germany (DE)
  • Italy (IT)
  • Luxemburg (LU)
RC Basel, RC Lindau, Zone Kiefersfelden-Pfronten, Steinitz, Wallbach, Oberkappel, Remich, Medelsheim In progress

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