1. Electricity Regional Initiative Central Eastern European Region Draft Report on Transparency for the CEE-Region Jan Müller Bundesnetzagentur ERI Central Eastern Europe CEE Implementation Group Meeting, 4th December 2007

2. 2 ERI Central Eastern Europe CEE Implementation Group Meeting, 4th December 2007 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

3. 3 ERI Central Eastern Europe CEE Implementation Group Meeting, 4th December 2007 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

4. 4 ERI Central Eastern Europe CEE Implementation Group Meeting, 4th December 2007 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

5. 5 ERI Central Eastern Europe CEE Implementation Group Meeting, 4th December 2007 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

6. 6 ERI Central Eastern Europe CEE Implementation Group Meeting, 4th December 2007 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 that bidding 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

7. 7 ERI Central Eastern Europe CEE Implementation Group Meeting, 4th December 2007 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

8. 8 ERI Central Eastern Europe CEE Implementation Group Meeting, 4th December 2007 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

9. 9 ERI Central Eastern Europe CEE Implementation Group Meeting, 4th December 2007 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

10. 10 ERI Central Eastern Europe CEE Implementation Group Meeting, 4th December 2007 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

11. 11 ERI Central Eastern Europe CEE Implementation Group Meeting, 4th December 2007 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

12. 12 ERI Central Eastern Europe CEE Implementation Group Meeting, 4th December 2007 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

13. 13 ERI Central Eastern Europe CEE Implementation Group Meeting, 4th December 2007 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

14. 14 ERI Central Eastern Europe CEE Implementation Group Meeting, 4th December 2007 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 “natural monopolies”, 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

15. 15 ERI Central Eastern Europe CEE Implementation Group Meeting, 4th December 2007 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

16. 16 ERI Central Eastern Europe CEE Implementation Group Meeting, 4th December 2007 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

17. 17 ERI Central Eastern Europe CEE Implementation Group Meeting, 4th December 2007 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

18. 18 ERI Central Eastern Europe CEE Implementation Group Meeting, 4th December 2007 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

19. 19 ERI Central Eastern Europe CEE Implementation Group Meeting, 4th December 2007 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

20. 20 ERI Central Eastern Europe CEE Implementation Group Meeting, 4th December 2007 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

21. 21 ERI Central Eastern Europe CEE Implementation Group Meeting, 4th December 2007 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

22. 22 ERI Central Eastern Europe CEE Implementation Group Meeting, 4th December 2007 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: Jan.Mueller @BNetzA.de