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  1. 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

  2. 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

  3. 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

  4. 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

  5. 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 thatbidding 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

  6. 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

  7. 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

  8. 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

  9. 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

  10. 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

  11. 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  No need to adapt the Report

  12. Transmission and Interconnectors 2/3 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

  13. Transmission and Interconnectors 3/3 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 “naturalmonopolies”, 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 No need to adapt the Report

  14. 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) No need to adapt the Report

  15. 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

  16. 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 No need to adapt the Report

  17. Balancing Responsible 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 No need to adapt the Report

  18. 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 No need to adapt the Report

  19. Data confidentiality 2/2 Data 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

  20. 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

  21. 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: