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scription alo
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majority (10)
e responsible
opposed.
amples of su
mplexity a
finitions on v
mpatible con
pondents; h
yers (6) argu
Considering
EU level is f
tweighs the
mber of answ
ere was an e
ponents ((7
swered to th
me respond
ndard contr
main. In add
how to bund
ancing have
hieve a single
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rmonisation
feedback
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en if bundle
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monised con
please provid
rmness or f
ong certain p
wers ‐ 13.
) agreed tha
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The resp
uch barriers
nd costs
various aspec
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however th
ued for stand
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feasible? If y
costs of its i
wers – 14.
equal numb
yes/ 7 no).
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dents menti
ract is need
dition, harm
dle. Both the
e to be am
e contract.
xperienced in
/ or contract
ed across
and why?
the need to
ed) and on
short term c
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de examples
freedom of
parameters)
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order barrie
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s, like increa
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cts.
were suppo
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yes, do you
mplementat
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estion (2 yes
ioned that
ed if incons
onisation is
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nefficiencies
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Europe)? If
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sign two
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s. Do you th
allocation) c
or can this o
efinitions
rs, others
mentioned
ased risk,
different
orted by 6
mount of
ts.
A
c
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aw regimes
believe tha
tion?
rters and
keholders
s, 1 no).
a single
sistencies
required
nd the NC
order to
A
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s
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s and risks w
nd condition
f so, what
ACER views
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hink that equ
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ACER takes
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of required
should result
across EU, d
t the benefi
ACER takes
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support the
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which make i
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note that n
to limit cross
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note that du
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nefficiencies
Rules fo
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the issue.
to harmonis
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exit zones li
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tandard con
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contract – w
difficult to ac
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oR Report
8
mit cross bo
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s alone (pro
established a
ct definition
ontext, the e
actual defin
onducted in 2
ntract establ
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w regimes i
which would
chieve. How
auses in cap
ety of private
ed that re
order
ristics
oduct
at EU
s are
extent
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2015.
ished
level
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likely
wever,
pacity
e law
quire
Res
Nu
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9.
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cap
par
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differences
majeure;
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pecifications
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rriers. Only 1
trade, as th
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pacity produ
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feedback
wers – 11.
espondents
compared to
ndents men
nd risks:
in events c
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CMPs (e.g
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everything
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wers ‐ 15.
ority in the
spondents c
b). The o
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dents menti
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Balancing N
ndard capac
wers – 12.
f responden
1 responden
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ad no obser
nts suggeste
DOs as well
g the gas day
any differenc
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(6) have exp
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ntioned the
considered
ance progra
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y;
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else being
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responses h
chose option
others (6) r
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ption a).
ioned the n
ucts, while
mized.
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perienced
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addition,
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ay capacity p
ACER agrees
plans no fur
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note that a
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escribe the d
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a number of
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of capacity
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firmness lev
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majority of
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urther analys
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views of s
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vels).
igations as a
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area. ACER a
NC Balancing
ine the conc
as well as th
oR Report
9
ies and risk
such as gas
codes and sh
ntation of t
e standardiz
ses and wor
rms is need
cies.
cts with lim
roducts (wit
stakeholders
firm product
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lved with fu
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12.
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ferent term
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plementatio
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feedback
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ny other obs
nswers – 1
ere are oth
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dents requ
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Some res
culties in ap
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hink that a
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dentified. 4
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mentation (N
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of firmness,
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liquidity, in
arallel exist
ty. 2 respon
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spondents
plication of
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ding guidanc
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endorsed by
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multiple
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onal/non
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hamper the u
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s such as
sufficient
tence of
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stressed
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a
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g
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EU rules, b
dress the a
ts would
(5) would
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n,
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practices
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contracts
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m
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ACER takes
repeating iss
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analysis.
use of capac
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and investm
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gas target
elimination.
b) non‐bindi
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matter. A co
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approach (e.
guidance, 3.
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which is hap
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definitions m
comprehens
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model and
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go for bindi
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ation.
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may be con
sively taking
quirements.
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identified di
tion to firmn
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nal efforts (
order to
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holders’ vie
of measures
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as amendm
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stock of the
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ifferences an
ness, multip
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ders in the EU
additional b
(improving m
be elimin
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s as wel
des, the prog
sures shoul
rules at a
u can differe
ews are not
to be taken
on the issue
mentation, 2.
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mplementat
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ments to NC
the approp
e capacity co
oR Report
10
nd also note
ple contracts
the forthco
U?
barriers. Som
market cond
nated. Euro
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l as the
gress toward
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all (awaiting
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may be suit
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s etc.,
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with
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g the
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table,
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scape
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14.
fac
NC
Nu
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and
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15.
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16.
refe
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17.
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Do you thin
ilitation of t
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pondents a
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Do you see
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mber of answ
majority id
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essed that f
cause the
turity.
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e need for
oducts. Oth
rkets shall
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Are there a
ease provide
feedback
nk that rules
trading alrea
wers – 12.
(8) replied
ong those,
ance may be
s, and prop
condary m
agreed that
on transpa
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ncl. ‘click‐an
trated on reg
e a need for
ity transfer (
wers – 13.
dentified am
t bilateral t
nymized ma
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further analy
choice de
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g. contract d
wers – 12.
rity opposed
ents (4) agr
d (2). Some
a limited n
hers advise
allow for
also suggest
roved (i.e.
ility is increa
any rules ham
e specific cas
s are needed
ady in place
that no r
some stres
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markets.
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arency (incl
harmonised
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(with consist
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transfers. O
arket. 6 res
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epends on
to harmonise
durations, ha
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SECOND
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whether the
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takeholders
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products? If
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oR Report
11
into accoun
as demande
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as to be che
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ndled capa
‐binding rul
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mentioned
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all be bet
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umber of liqu
venues, etc.
wers – 13.
would be in
current reg
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of informatio
need for a
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imposed by
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to be acces
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ts on the
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spondent
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PRISMA
erations),
ted with
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anymore an
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the market a
report ).
could be gra
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he problems
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at additiona
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the current
and on data
nted, when
aggregation
be applied.
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or Trading – E
s identified i
apacity quali
apacity, soph
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the current
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current regi
at more
t should, in
al transpare
of offers,
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availability f
anonymity i
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oR Report
12
in the tradin
ity difference
histicated tr
ve bundling
sues may re
est priority a
been menti
andatory tra
regime as is
avour secon
me, which a
venues wit
your view, t
ncy in secon
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on inform
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ioned
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allows
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20.
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hink that a
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of respond
re sufficient.
nding EU
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chose non‐b
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s:
tible/consist
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any design el
rom traders
wers – 11.
ondents (3)
as barriers.
me responde
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onsidered),
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respondent
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n to overcom
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oviders/inte
discriminato
blematic and
wers – 10.
entified, but
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at fees coul
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ents stated
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rules (r
to REMIT),
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tent contract
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issue, 1 res
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ndents (4)
regarding
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ments are
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and the in
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exception co
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provide a ba
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predictable
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oversight for
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structures, w
ensure this.
nformation
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ACCESS AND H
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tation will
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te barriers.
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conditions
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simple and
periodic rev
oR Report
13
e public fo
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entiate betw
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entry fees
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stressed th
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In general it
ansparent an
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andardised d
otential bala
volumes and
wers – 11.
dentified. 4
dardised dat
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ded to comm
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rules are ne
g to the ‘
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the establis
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wers– 13.
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ressed that
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should be
map on creat
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hat after
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nd predictab
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data exchan
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ta exchange
ation of form
modity. 5 res
rules; 1 res
ments to exist
ming) and ano
eeded at a la
‘hub‐to‐hub’
against a
hubs as be
our of stan
rket practice
designed.
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lementation
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tion of hub
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ns. Some
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present a ba
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trading venu
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rules are
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propose
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arrier for cr
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implementat
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be able to bu
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national rule
countries) co
BAL’s comple
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tandardisati
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ll be put in
M. Best pract
n. At this st
to be awaite
entation mo
oR Report
14
u see a nee
used as inte
time, locatio
mats for tr
olders. Once
rability and
high degre
hen be monit
on) initiative
be facilitated
uld be avo
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(7) believes
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wers – 11.
dentified. So
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n of (existing
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make contr
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identified.
promoted be
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products is a
with the fu
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s that no r
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and assur
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ditions of cap
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sparency.
of better
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a
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developmen
prefer awai
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ANSPARENCY R
pacity servic
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s where this
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and in part
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always in
consultation
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barrier to tr
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nt and NC i
ting the fu
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RULES
ces (incl. usa
establishme
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access).
notes the d
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English, so
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if NRAs co
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products wit
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and commu
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rules at a
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valuate it alo
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ent and early
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published in
to at least
ments with
nd consultat
th limited
ugh? If non
ders’ views
t of existi
ty of produ
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unication o
oR Report
15
all (awaiting
entiate betw
ge of VTP,
ses, stakeho
existing net
any new bin
sparent and
latforms suc
ong any of t
respondents
y implement
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sparency. W
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documents
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EU gas m
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allocability
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wers – 10.
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on interr
ublication
and ex post d
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respondent
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and inte
hould be pub
hink that a
on of existin
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wers – 11.
entified. 3 re
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uired.
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have no ex
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se specify w
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access to
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specify, whe
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er complaine
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s and its pa
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blished a yea
a) binding E
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espondents r
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nformation o
where this is n
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have sufficie
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rules, which
NRAs, some
requirement
recently pu
transparency
further addit
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develop fu
cooperation
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efficiency),
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twork code
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if found to
the transpa
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nforcement
ansparency r
with the re
he transparen
oR Report
16
rruption to
balance betw
ons and a
a few ‘stand
f this shoul
R and poten
ty service an
uestion still
r interruptio
ntation of ex
enforceme
of transpa
sistent with
may review
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ption and/o
uestion still
of the cond
ntation of ex
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may review
o be neces
arency rule
all (awaiting
entiate betw
rules, which
by NRAs,
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ecently publ
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hub‐
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Annex
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enforce
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s stated tha
rkets that
dition, it wa
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derstanding
thout further
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ssues were r
implementa
perceive
ation,
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should give
ement rules
ent with the
achieved.
L
e a problem
, explain the
wers – 13.
ntified issue
ices (7). 5
; others (1)
egardless of
lem or not)
ptable licen
gistration wi
need for lice
ents.
hink that a
on of existing
wers – 14.
ere spread
on‐binding (4
tressed the
ction of adm
lation to rep
at interventi
do not fu
s proposed
an opportun
and reso
r rules.
aised are:
ation needed
unequal ac
s to align w
3.3.5 of Tran
e an outloo
to be cons
e Transparen
LICENSING REQ
m with regar
e main issue
es around
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f whether co
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enses in the
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4), no rules
e simplicity
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porting oblig
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unction pro
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QUIREMENTS F
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(3). The
and the
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gations. It
focus on
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mentation
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problems
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ARTICIPANTS O
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Rules fo
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elop further
ith ENTSOG.
SO
EU? If yes, p
quirements f
s that mutu
forward. How
gally) possibl
rules at a
mplementat
otify accura
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ough the GR
sing rules (e
ost of the res
oR Report
17
additions to
please name
for licenses a
al acceptan
wever, analy
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all (awaiting
tion shall be
tely the rele
roblems. Thi
RI. It then rem
ither non‐bin
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In this c
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Conclusion
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ementation
ch a new FG
heless, ACER
ed once th
ear and spe
nsible to firs
e effects o
olders – wil
on the asse
nisation is n
endment p
intention
al remedies
Analysis of
up by the m
Analysis of
could be lev
Further ana
Balancing is
Further wo
capacity tra
context, ACE
The Agency
TSOs and T
product sta
ACER will co
ACER will su
ACER flags
transparenc
be conside
with.
With regar
ACER is wi
licenses, if m
number of
n, ACER dec
G, in line wit
R is current
e existing N
ecific rules o
st implemen
of the code
l at this sta
essment du
needed in s
proposals of
is to perio
s according
f the capaci
market, and
f the differ
velled by ha
alysis on th
s implemen
ork on sec
ading.
ER also note
y is ready to
TSO platform
andardizatio
ollect, reco
upport the
the neces
cy requirem
red in the
d to licensi
lling to fos
mutual accep
Network C
cided to rec
th the reque
tly not fully
Network Co
on all the m
nt the exist
e applicatio
age not wo
uring and a
pecific deta
f the then ex
odically rev
to the follow
ity products
the potent
ences of c
armonisatio
e design an
ted.
condary ca
es that:
o foster ear
ms have to
on on the ba
mmend and
improveme
sity for spe
ments. Stric
future, if t
ing issues,
ster the imp
tance is prov
Codes are st
commend to
est of the s
convinced
odes are fu
entioned is
ting Networ
on. Hence
rk on comp
after the fu
ailed areas,
xisting netw
view and a
wing prioriti
s currently
tial scope fo
ontract ter
on.
nd procedu
pacity mar
rly impleme
o be encour
asis of self‐c
d advocate
ent of gover
eedy imple
cter enforce
the transpa
ACER is wi
plementation
ved insufficie
till being de
o the Comm
takeholders
that all issu
ully implem
ssues. At the
rk Codes an
e, ACER ‐ a
prehensive
ull NC imp
which mig
work codes.
assess the
es:
on offer, th
or improvem
rms and de
res of virtu
rkets and
entation;
raged to sh
commitmen
best practic
rnance issue
ementation
ement rule
rency oblig
lling to inc
n of harmon
ent.
Rules fo
eveloped or
mission tha
s (26 out of
ues raised b
ented, as t
e same time
nd closely m
as also sug
new bindin
plementatio
ght then tra
outstandin
heir charact
ment and ha
efinitions, a
al trading p
ways to fa
are best pr
nts;
ces;
es.
and enforc
s on transp
gations are
lude that in
nised requir
or Trading – E
r are in the
t it is not a
f 28).
by stakehol
those codes
e, ACER agr
monitor the
ggested by
ng rules, bu
on whether
anslate for e
ng issues a
teristics, th
armonisatio
and whethe
points, once
acilitate se
ractices of
cement of
parency issu
not fully c
n its analys
rements for
oR Report
18
process
a priority
ders will
s do not
rees that
process
several
ut rather
r further
example
and find
eir take‐
on.
er these
e the NC
econdary
capacity
existing
ues may
complied
sis work.
national
Annex INo
Na
1 AIG
2 BD
3 CE
4 CE
5 DE
6 EA
7 ED
8 ED
9 EF
10 En
11 EnTraGm
12 EnNe
13 En
14 En
15 EN
16 Eu
17 Eu
18 Eu
19 GaNa
20 GaDis
21 Ga
22 GaM&
23 Gd
24 GDInfrs
- List of Re
ame
GET
DEW
EGH AG
EZ a.s.
EPA S.A
ASEE-gas
DF
DP S.A.
FET
agas
BW ading mbH
ergie-ederland
ergy UK
i
NTSOG
urelectric
rogas
ropex
alp Gasatural
as Naturastribucion
asTerra BV
azprom &T
dF Suez
DF SUEZrastructure
espondents
Organis
Nationalassociat
Nationalassociat
Hub ope
Compan
Compan
Associat
Compan
Compan
Associat
Compan
Compan
Nationalassociat
Nationalassociat
Compan
Associat
Associat
Associat
Associat
s Compan
al Compan
V Compan
Compan
Compan
Z Compan
sation
tion
tion
erator
ny
ny
tion
ny
ny
tion
ny
ny
tion
tion
ny
tion
tion
tion
tion
ny
ny
ny
ny
ny
ny
Segment
Supplier,
Network
Hub oper
Supplier,
Supplier
Wholesaldistributio
Network
Supplier
Shipper
TSO
Supplier
Industrial
Electricity
TSO
TSO
Industry
Wholesaldistributio
EuropeanExchange
Shipper a
DSO
Shipper
Shipper
TSO
TSO
t
shipper
user
rator
network us
le, retail on
user
l energy us
y Producers
le, retail on
n Ees
and Supplie
Rules fo
CoOr
Ita
Ge
Au
ser CzRe
Gr
and Eu
Fra
Po
Eu
Sp
Ge
sers ThNe
s UK
Be
Eu
Eu
and Eu
Energy Eu
er Po
Sp
ThNe
UK
Fra
Fra
or Trading – E
ountry origin
aly
ermany
ustria
zech epublic
reece
urope
ance
ortugal
urope
pain
ermany
he etherlands
K
elgium
urope
urope
urope
urope
ortugal
pain
he etherlands
K
ance
ance
oR Report
19
of Confidential
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
d