Reported issue ID: 02/2020
Dutch TSO requirement of message PRODOC is unnecessary and contrary to Network Code on Gas Balancing of Transmission
by EASEE-gas
Abstract
The Dutch TSO Gasunie Transport Services (GTS) is today forcing its market players to send a message called PRODOC (LoadForecast_Document) in its first version before 13.00 day ahead. This message must be balanced at a point where no Balance Responsible Party (BRP) is balanced (since trading is an ongoing activity). As a result of this many BRP’s create non planned volumes to be able to get their message balanced and approved by GTS and they have to implement these additional messages if they want to take part in the Dutch wholesale market. GTS then responds with a PROCON (LoadForecast_Confirmation) that tells if the program is approved. We do not see which value this message gives to GTS since the same information can be extracted from existing nomination and balancing process. We also notice this process breaches part of the network code on Gas Balancing of Transmission Networks.
Category: National
Reported issue
The Dutch TSO Gasunie Transport Services (GTS) is today forcing its market players to send a message called PRODOC (LoadForecast_Document) in its first version before 13.00 day ahead. This message must be balanced at a point where no Balance Responsible Party (BRP) is balanced (since trading is an ongoing activity). As a result of this many BRP’s create non planned volumes to be able to get their message balanced and approved by GTS and they have to implement these additional messages if they want to take part in the Dutch wholesale market. GTS then responds with a PROCON (LoadForecast_Confirmation) that tells if the program is approved.
We do not see which value this message gives GTS since the same information can be extracted from existing nomination and balancing process where BRP’s send their current planned activity for day ahead but on a detailed level with real values.
We also notice this process breaches the following part of the network code on Gas Balancing of Transmission Networks:
Page 1 (Against harmonisation and specific process only valid in the Netherlands):
(2) In order to move towards greater market integration, it is important that rules on gas balancing of transmission networks facilitate gas trading across balancing zones thus contributing towards the development of market liquidity. This Regulation therefore sets out harmonized Union-wide rules on balancing which have the objective to give network users the certainty that they can manage their balance positions in different balancing zones throughout the Union in an economically efficient and non-discriminative manner.
Page 3 Article 4 (since they will have more accurate information in the nomination)
2. Balancing rules established in accordance with this Regulation shall reflect genuine system needs, taking into account the resources available to transmission system operators and shall provide incentives for network users to balance their balancing portfolios efficiently.
Page 12 Article 12 (Since this must be balanced and is in addition to the real nomination it is not accurate).
2. The transmission system operator may require network users to provide further information on nominations and renominations in addition to the requirements set out in this Regulation, including, inter alia, an accurate, updated and sufficiently detailed forecast of the expected inputs and off-takes, this in accordance with the specific need(s) of the transmission system operator.
Concerned entities
Network Code on Gas Balancing of Transmission Networks, Commission Regulation (EU) 2014/312
- Netherlands
None selected
Notified parties
None selected
- Gasunie Transport Services B.V. (NL)
Suggested actions
- ACER
- ENTSOG
- Involved NRA(s)
- Involved TSO(s)
- Adjustement of implementation
comments (0)
IP's concerned
IP |
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Informed TSO's
TSO |
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Gasunie Transport Services B.V. (NL) |
Informed NRA's
NRA | Country |
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Solution
In the process of validating, categorising, and prioritising the issue, ACER and ENTSOG have determined that the issue is of a national nature.
The issue will therefore be closed on the FUNC Platform without being further processed.
For further details, reference is made to the Issue Solution Note below.