1 Brussels, 27 th February 2012 8 th GRI Coordination Group South Gas Regional Initiative

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Brussels, 27th February 2012

8th GRI Coordination Group

South Gas Regional Initiative

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GRI Coordination Group Meeting

1. UPDATED South GRI Work Plan 2011-2014

» The Work Plan 2011-2014 is being updated .

» The modified points and additional issues are shown in red.

2. Preliminary Findings of the supervision of compliance with Transparency provisions in Regulation 715/2009/CE

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Work Plan for 2011-20141. CAMs and CMPs affecting interconnection capacities (I)

.Annual short term Open Subscription for the 20% of present existing capacities between Spain and France.

.CAM harmonisation (pilot testing FG-NC on CAM) beginning with the Spanish and Portuguese interconnections. Auction procedure is being developed by TSOs and NRAs to be launched in June 2012. First draft was presented to Stakeholders on the 7th February 2012. (Jun 2012).

. TSOs Common Allocation Platform (Dec 2014).

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Work Plan for 2011-20141. CAMs and CMPs affecting interconnection capacities (II)

.CMPs at interconnections: Regulators and TSOs have analysed CMPs in force. The region’s Work Plan envisages the application of coordinated and harmonized CMPs at borders following “comitology” CMP draft . Could serve as a pilot testing of the CMP to provide feed-back to the European Commission from the South Region.

. The region has already defined a first draft of a common CMP that could be implemented at the Spanish-French border (Dec 2012).

.Extension of the coordinated CMP mechanism to the Spanish-Portuguese cross-border capacity (Jan 2013).

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Work Plan for 2011-2014

2. Ten Year Network Development Plan and Projects of Common Interest

.Keep evaluating the need of infrastructure, following market demand, using market mechanisms to decide if future investments are needed.

.SGRI to provide feed-back to ENTSOG on the contents and methodology to design the regional investment plan.

.Creation of a working group in the region in order to test the process for PCI identification, proposed in the draft Regulation through a pilot exercise (Nov 2013).

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3. Security of supply

.Providing competent and relevant authorities on SoS with a forum to update progress on the Regulation 994/2010 implementation.

.Contributing to the elaboration of the preventive and action plans by promoting stakeholders participation in public consultations.

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Work Plan for 2011-20144. Balancing

.Contributing to the FG and NC, by raising the regional experience and lessons learned.

. Investigation of the use of the gas markets in the region for balancing purposes (Jun 2013).

.Analyse the current configuration of balancing zones to help developing virtual hubs (Dec 2013).

.Possible launching of a pilot project for a common balancing platform integrating the provision of balancing systems in the three countries in the region (Dec 2014).

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5. Tariffs

.Public consultation of Analysis of cross border transmission gas tariffs between Portugal and Spain has recently finished.

. Further studies to evaluate the current tariff structures and propose improvements (Dec 2012).

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6. Interoperatibility

. To contribute with regional experience to the development of the FG and NC.

. To develop specific proposals for the harmonisation of aspects (gas day, communication protocols between TSOs, quality standards, programming and nomination schedules...). (Dec 2014)

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7. Transparency

.Supervision of compliance with the implementation of the new provisions on transparency in the Regulation 715/2009/CE (Jun 2012).

. Transparency Project Plan has been developed in the South region following NGRI example. Preliminary findings were presented to stakeholders in the 15th SG Meeting, last 7th February.

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8. Developing hub-to-hub

.Hub development (Dec 2013).

.Hub-to-hub gas trading in the region (Dec 2014).

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9. Cross regional projects

. Early implementation of CAM following FG and Draft NC.. Monitoring the implementation of Regulation transparency requirements. Collaboration with other regions in the development of a work program to promote transparency compliance.. Implementation of a capacity platform considering other regions’ projects, analysing possible direct adherence to neighbouring capacity platforms in operation.. Promotion of cross regional cooperation in SoS.. Monitoring of other regions’ work to promote hub developments.

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AGENDA OF THE SGRI WORK PLAN FOR 2011-2014 (I)

Areas of work Responsible Starting Deadline

Capacity allocation mechanisms ()

I.1. OSP France-Spain: annual allocation of short-term capacities TSOs Nov. (yearly) Dec. (yearly)

I.2. CAM harmonisation proposal between and NRAs-TSOs Jan. 2011 Jun. 2012

I.3. CAM harmonisation proposal in the whole region NRAs-TSOs Jan. 2012 Dec. 2013

I.4. Set up a common TSO Allocation Platform TSOs Jan. 2014 Dec. 2014

Congestion management procedures (CMP)

II.1. CMP harmonisation proposal between and NRAs-TSOs Jan. 2011 Dec. 2012

II.2. CMP harmonisation proposal between and NRAs-TSOs Jan. 2012 Jan. 2013

Investment in new infrastructure. Ten-Year Network Development Plans and projects of common (European) interest

III.1. Regular update and publication in CEER website of project status of OS 2013 and 2015 TSOs-NRAs Dec. (yearly) Jun. (yearly)

III.2. Drafting of the South Regional Investment Plan 2012 TSOs Jul. 2011 Jan. 2012

III.3. Feedback to ENTSO-G on contents and methodology of the regional investment plan NRAs Jan. 2012 Jul. 2012

III.4. Input to ENTSO-G for the Community-wide TYNDP 2013 TSOs Jan. 2012 Jan. 2013

III.5. Creation of a working group in the region in order to test the process of PCI identificationNRAs -

TSOs

April.

2013Nov. 2013

III.6. Drafting of the South Regional Investment Plan 2014 TSOs Jan. 2013 Jan. 2014

Security of Supply (SoS)

IV.1 Periodically update on progress on Regulation 994/2010 implementationCompetent

Authorities Permanent

IV.2 Promotion of market’s participation through public consultations in the development of

preventive action plansNRAs Permanent

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AGENDA OF THE SGRI WORK PLAN FOR 2011-2014 (II)

Areas of work Responsible Starting Deadline

Balancing

V.1. Contributing to the FG and NC, by raising the regional experience and lessons learned NRAs-TSOs Permanent

V.2. Investigation of the use of the gas markets in the region for balancing purposes NRAs-TSOs Jun. 2012 Jun. 2013

V.3. Analyse the current configuration of balancing zones and possible merging of certain

areasNRAs-TSOs Jan. 2013 Dec. 2013

V.4. Pilot project for a common balancing platform in the three countries TSOs Jan. 2014 Dec. 2014

Tariffs

VI.1. CNE-ERSE joint study on tariff regimes in Spain and Portugal NRAs 2010 Dec. 2011

VI.2. CNE-ERSE proposal for tariff harmonization in Spain and Portugal NRAs 2010 Dec. 2012

VI.3. Further studies to evaluate the current tariff structures and propose improvements NRAs Jan. 2012 Dec. 2012

Interoperability

VII.1. Contribute with the regional experience to the development of the FG and the NC NRAs-TSOs Permanent

VII.2. Analysis of interoperability aspects and procedures that need to be harmonised among

the three countries (in line with the FG-NC)TSOs Jan. 2013 Jan. 2014

VII.3. In particular, harmonisation of gas day, communication protocols between TSOs, quality

standards, programming and nomination schedules, etc.TSOs Jan. 2014 Dec. 2014

Implementation of the 3rd Package

VIII.1. Supervision of compliance with the implementation of the new provisions on

transparency in the Regulation 715/2009/CE, for transmission, LNG and storage infrastructureoperators

NRAs Sep. 2011Jun..

2012

Developing hub-to-hub trading in the South region

IX.1. Hub developmentNRAs-TSOs-

stakeholdersJan.2013 Dec. 2013

IX.2. Hub-to-hub gas trading in the regionNRAs-TSOs-

stakeholdersJan.2014 Dec. 2014

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Key steps Responsible Deadline

Agree information template NRAs November 2011

Template to be filled in by TSOs, LSOs, SSOs

TSOs, LSOs, SSOs 15 January 2012

SGRI to assess/ clarify and consolidate responses

NRAs 31 January 2012

Publish preliminary report and invite stakeholders to comment on the responses

NRAs/ stakeholders February 2012

Publish conclusions NRAs March 2012

SGRI TRANSPARENCY PROJECT PLAN

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1) Survey Procedure

• Following steps taken by the North region, but extending the approach to LSOs and SSOs.

• Questionnaires were sent on December 2nd 2011 to the following agents:

• Deadline to answer: January 15th, 2012.

• Mail reminder was sent on January16th.

• Regulators contact TSOs, LSOs and SSOs to clarify misunderstanding according to preliminary assessment made by NRAs.

• Final Questionnaires are planning to be published in February.

TSOs LSOs SSOs

Portugal REN REN REN / GALP

France TIGF / GRTgazELENGY / STFMC (Fos Cavaou)

STORENGY / TIGF

Spain NATURGAS / ENAGASENAGAS / BBG / REGANOSA / SAGGAS

ENAGAS

Transparency Project Plan

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2) TSOs transparency: preliminary assessment

• According to questionnaires filled out by the TSOs, the preliminary

assessment shows, in general, a high level of compliance with Regulation

715/2009:

Good level of compliance with provisions that require the publication of

information on:

Gas system description

Service description and contracting process

Applicable CAM and CMP

Nomination and matching procedures

Balancing rules and imbalance charges

Secondary markets


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2) TSOs transparency: preliminary assessment (cont.)

Some room for improvement on:

More clarity on services’ prices

Flexibility and tolerances levels

Participation in secondary markets

Historical data

Form of publication (English, units, etc.)


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3) TSOs transparency: preliminary conclusions

• Some areas of non-compliance are in the process of being implemented.

• There are some misunderstandings among TSOs about some transparency requirements (i.e., requirements that are considered “not applicable”, information not directly published by the TSOs, but by third parties, etc.). These misunderstandings are easy to solve, this will improve the level of compliance.

• There’s information not published directly by the TSOs but by other market agents. Again, this difficulty is easy to overcome with links.

• Compliance with some obligations require the modification of national legislation. This specifically refers to the need to publish data in units that use a combustion temperature of reference of 298,15 K. The change of reference temperature would have a considerable impact on other national processes (i.e., measurement processes, invoicing, etc.), so it must be analysed very carefully. The requirement has been complied with a conversion factor provided.


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Yes / Data publishedData published by other market agent (link is available)

Not applicable, forthcoming, or exemption request pending

No / Data not published

No information

• Summary tables in colours have been developed by NRAs

according to the questionnaires received from operators in

the South Region.

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TSOs ’ Transparency QuestionnairesArticle Point of a sub- article

PORTUGAL

REN GRT TIGF ENAGAS NATURGAS

Do you publish a detailed and comprehensive description of the different services offered and

their charges?

3.1.2 b) Do you publish the different types of transportation contracts available for these services?Do you publish the network code and/or the standard conditions outlining the rights and responsibilities of all network users including: 1. Harmonised transportation contracts and other relevant documents;2. if relevant for access to the system, for all relevant points as defined in paragraph 3.2 of this Annex, a specification of relevant gas quality parameters, including at least the gross calorific 3. if relevant for access to the system, for all relevant points information on pressure requirements;4. the procedure in the event of an interruption of interruptible capacity, including, where applicable, the timing, extent, and ranking of individual interruptions (for example pro-rata or first-

3.1.2 d) Do you publish the harmonised procedures applied when using the transmission system, including the definition of key terms?Do you publish provisions on

1. capacity allocation,

2. congestion management,

3. anti-hoarding, and

4. reutilisation procedures?

3.1.2.f) Do you publish the rules applicable for capacity trade on the secondary market vis-à-vis the transmission system operator?3.1.2.g) Do you publish rules on balancing and methodology for the calculation of imbalance charges?

I f applicable, do you publish the flexibility and tolerance levels included in transportation and other services without separate charge, as well asany flexibility offered in addition to this and the corresponding charges

Do you publisha detailed description of the gas system of the transmission system operator and its relevant points of interconnection as defined in paragraph 3.2 of this Annex, as well asthe names of the operators of the interconnected systems or facilities?

3.1.2.j) Do you publish the rules applicable for connection to the system operated by the transmission system operator?

3.1.2.k)Do you publish information on emergency mechanisms, as far as it is the responsibility of the transmission system operator, such as measures that can lead to the disconnection of customers Do you publishprocedures agreed upon by transmission system operators at interconnection points, of relevance for access of network users to the transmission systems concerned, relating to interoperability of agreed procedures on nomination and matching procedures andother agreed procedures that set out provisions in relation to gas flow allocations and balancing, including the methods used?

3.1.2.m)Do you publish a detailed and comprehensive description of the methodology and process, including information on the parameters employed and the key assumptions, used to calculate the technical capacity?

3.1.2.c)

3.1.2.e)

3.1.2.h)

3.1.2.i)

3.1.2.l)

3.1.2 a)

Article of Annex 1

chapter 3 of Regulation 715/2009

Transparency requirementFRANCE SPAIN

3.1.2 Content of publication

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TSOs ’ Transparency Questionnaires

Do you publish the information referred to under paragraph 3.1.2. in the following manner:

(a) on a website accessible to the public, free of charge and without any need to register or otherwise sign on with the transmission system operator;(b) on a regular/rolling basis; the frequency shall be according to the changes that take place and the duration of the service;(c) in a user-friendly manner;

(d) in a clear, quantifiable, easily accessible way and on a non-discriminatory basis;

(e) in downloadable format that allows for quantitative analyses;

(f) in consistent units, in particular kWh (with a combustion reference temperature of 298,15 K) shall be the unit for energy content and m 3 (at 273,15 K and 1,01325 bar) shall be the unit for (g) in the official languages of the member State and

(g) in English

3.1.1.2. Do you provide details on actual changes to all information referred to under paragraph 3.1.2 in a timely manner as soon as available to you?

3.1.1. Form of publication:

3.1.1.1.

Article Point of a sub- article

PORTUGAL


Article of Annex 1



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TSOs ’ Transparency QuestionnairesArticle Point of a sub- article

PORTUGAL


Article of Annex 1



Do you publish at all relevant points the following information for all services and ancillary services provided:(a) the technical capacity for flows in both directions;

I s this information published on a numerical basis?

I s this information in hourly or daily periods, equal to the smallest reference period?

I s this information and updates published as soon as available to you (“near real time”)?

I s this information published for a period of at least 18 months ahead?

Do you publish historical information on the technical capacity for flows in both directions for the past five years on a rolling basis?I s information for single final customers and for production facilities, that is excluded from the definition of relevant points as described under 3.2 (1)(a) published in aggregate format at least per balancing zone. The aggregation of single final customers and of production facilities, excluded from the definition of relevant points as described under 3.2 (1)(a), shall for the application of this annex be considered one relevant point.(b) the total contracted firm and interruptible capacity in both directions





Do you publish historical information on the total contracted firm and interruptible capacity for flows in both directions for the past five years on a rolling basis?(c) the nominations and re-nominations in both directions;




Do you publish historical information on the nominations and re-nominations in both directions for the past five years on a rolling basis?(d) the available firm and interruptible capacity in both directions;





Do you publish historical information on the available firm and interruptible capacity in both directions for the past five years on a rolling basis?(e) actual physical flows;




Do you publish historical information on actual physical flows for the past five years on a rolling basis?(f) planned and actual interruption of interruptible capacity;




Do you publish historical information on planned and actual interruptions of interruptible capacity for the past five years on a rolling basis?(g) planned and unplanned interruptions to firm services as well as the information on restoration of the firm services (in particular, maintenance of the system and the likely duration of any interruption due to maintenance). Do you publish planned interruptions at least 42 days in advance?


Do you publish historical information on planned and unplanned interruptions for the past five years on a rolling basis?

3.3 I nformation to be published at all relevant points and the time schedule according to which this information should be published

3.3.1., 3.3.2. and

3.3.3.

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Do you publish measured values of the gross calorific value or the Wobbe index at all relevant points, on a daily basis? Do you publish preliminary figures at the latest 3 days following the respective gas day?

Do you publish final figures within 3 months after the end of the respective month?

Do you publish for all relevant points, available capacities, booked and technical capacities, on an annual basis over all years where capacity is contracted plus 1 year, and

at least for the next 10 years.

I s this information updated at least every month or more frequently, if new information becomes available?Does the publication reflect the period for which capacity is offered to the market?

Do you publish the information referred to under paragraph 3.3(1) to 3.3(5) in the following manner:(a) on a website accessible to the public, free of charge and without any need to register or otherwise sign on with the transmission system operator;(b) on a regular/rolling basis; the frequency shall be according to the changes that take place and the duration of the service;(c) in a user-friendly manner;

(d) in a clear, quantifiable, easily accessible way and on a non-discriminatory basis;

(e) in downloadable format that allows for quantitative analyses;

(f) in consistent units, in particular kWh (with a combustion reference temperature of 298,15 K) shall be the unit for energy content and m 3 (at 273,15 K and 1,01325 bar) shall be the unit for (g) in the official languages of the member State and

(g) in English

3.1.1.2. Do you provide details on actual changes to all information referred to under paragraph 3.3(1) to 3.3(5) in a timely manner as soon as available to you?

3.1.1.1.

3.3.4.

3.3.5.


PORTUGAL


Article of Annex 1



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Do you publish on a daily basis and updated every day the following specifications re. the aggregated amounts of capacities offered, and contracted on the secondary market (i.e. sold from one network user to another network user), where the information is available to you:(a) interconnection point where the capacity is sold;

(b) type of capacity, i.e. entry, exit, firm, interruptible;

(c) quantity and duration of the capacity usage rights;

(d) type of sale, e.g. transfer or assignment;

(e) the total number of trades/transfers;

(f) any other conditions known to the transmission system operator as mentioned in 3.3.

I s this information provided by a third party?

Do you publish the following specifications re. harmonised conditions under which capacity transactions (e.g. transfers and assignments) will be accepted:(a) a description of standardised products which can be sold on the secondary market;

(b) lead time for the implementation/acceptation/registration of secondary trades. I n case of delays the reasons have to be published;(c) the notification to the transmission system operator by the seller or the third party as referred to under 3.4(1) about name of seller and buyer and capacity specifications as outlined in 3.4(1).

I s this information provided by a third party?

Regarding the balancing service of your system, do you provide to each network user, for each balancing period, its specific preliminary imbalance volumes and cost data per individual network user, at the latest 1 month after the end of the balancing period? Do you provide final data of customers supplied according to standardised load profiles within 14 months later? Do you respect confidentiality of commercially sensitive information while providing this information?I s this information provided by a third party?

Do you offer flexibility services, other than tolerances, for third party access?

I f you do, do you publish daily forecasts on a day-ahead basis of the maximum amount of flexibility, the booked level of flexibility and the availability of flexibility for the market for the next gas day? Do you also publish ex-post information on the aggregate utilisation of every flexibility service at the end of each gas day?(5) Do you publish, per balancing zone:

the amount of gas in the transmission system at the start of each gas day and

the forecast of the amount of gas in the transmission system at the end of each gas day?

Do you publish the amount of gas in the transmission system on an hourly basis?

Do you update the forecast amount of gas for the end of the gas day on an hourly basis throughout the gas day?Alternatively, do you publish, per balancing zone

the aggregate imbalance position of all users at the start of each balancing period and

the forecast of the aggregated imbalance position of all users at the end of each gas day?

3.4.6. Do you provide user-friendly instruments for calculating tariffs?

3.4 I nformation to be published regarding the transmission system and the time schedule according to which this information should be published

3.4.1.

3.4.2.

3.4.3.

3.4.4.

3.4.5.


PORTUGAL


Article of Annex 1



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4) LSOs and SSOs transparency: preliminary assessment

• According to questionnaires sent by the LSOs and SSOs, the preliminary

assessment shows, in general, a high level of compliance with Regulation

715/2009:

Good level of compliance with provisions that require the publication of

information on:

Service description

Contracted and available storage facility capacity

Use and availability of third-party access services

Form of publication


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4) LSOs transparency: preliminary conclusions

• Two French LSOs haven´t sent the filled Questionnaires.

• There’s some misunderstandings among LSOs about some transparency requirements (i.e., requirements that are considered “not applicable”, information not directly published by the LSOs but by third parties, etc.). These misunderstandings are easily to be solved, this will improve the level of compliance.

• There’s information not published directly by the LSOs but by TSO. This difficult is easy to overcome with links to TSO website.

• In general, they publish more information than required.


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LSOs ’ Transparency QuestionnairesArticle Point of a sub- article

PORTUGAL

REN ELENGY FOS CAVAOU ENAGAS BBG SAGGAS REGANOSA

Do you publish a detailed information regarding the services you offer?

Do you publish a detailed information regarding the relevant conditions applied for these services?Do you publish the technical information necessary for LNG facility users to gain effective access to the LNG facility?

19.2For the services provided, do you publish information on contracted and available LNG facility capacity on a numerical basis on a regular rolling basis and in user-friendly

19.3Do you disclose the information required by this Regulation in a meaningful, quantifiably clear and easily accesible way and on a non-discriminatory basis?Do you publish the amount of gas in each storage facility, or group of storage facilities if that corresponds to the way in which the access is offered to system users?Do you publish the inflows and outflows, and the available LNG facility capacity, including for those facilities exempted from third-party access?I s this information communicated to the TSO?

I s this information updated at least daily?

19.5Do you publish sufficiently detailed information on tariff derivation, the metodologies and the structure of tariffs for infraestructure under regulated third-party access?

15.1c) Do you publish data on the use and availability of services you offer, in a time-frame compatible with the LNG facility users´reasonable commercial needs?

Do you keep at the disposal of the national authority, including the national regulatory authority, the national competition authority and the Comission, all information referred in Article 19 for a period of 5 years?

20. Record keeping by system operators

Transparency requirement

FRANCE SPAIN

19. Transparency requirements concerning storage facilities and LNG facilities

19.1

19.4

15. Third-party access services concerning storage and LNG facilities

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5) SSOs transparency: preliminary conclusions

• One Portuguese Questionnaire needs to be completed with links on every transparency requirement.

• There’s some misunderstandings among SSOs about some transparency requirements (i.e., requirements that are considered “not applicable”, information not directly published by the SSOs but by third parties, etc.). These misunderstandings are easily to be solved, this will improve the level of compliance.

• There’s information not published directly by the SSOs but by TSO. This difficult is easy to overcome with links to TSO website.


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SSOs ’ Transparency QuestionnairesArticle Point of a sub- article

SPAIN

REN GALP STORENGY TIGF ENAGAS

Do you publish a detailed information regarding the services you offer?

Do you publish a detailed information regarding the relevant conditions applied for these services?Do you publish the technical information necessary for storage facility users to gain effective access to the storage facility?

19.2For the services provided, do you publish information on contracted and available storage facility capacity on a numerical basis on a regular rolling basis and in user-

19.3Do you disclose the information required by this Regulation in a meaningful, quantifiably clear and easily accesible way and on a non-discriminatory basis?Do you publish the amount of gas in each storage facility, or group of storage facilities if that corresponds to the way in which the access is offered to system users?Do you publish the inflows and outflows, and the available storage capacity, including for those facilities exempted from third-party access?I s this information communicated to the TSO?

I s this information updated at least daily?

19.5Do you publish sufficiently detailed information on tariff derivation, the metodologies and the structure of tariffs for infraestructure under regulated third-party access?

15.1c) Do you publish data on the use and availability of services you offer, in a time-frame compatible with the storage facility users´ reasonable commercial needs?

Do you keep at the disposal of the national authority, including the national regulatory authority, the national competition authority and the Comission, all information referred in Article 19 for a period of 5 years?

20. Record keeping by system operators

Transparency requirement

PORTUGAL FRANCE

19. Transparency requirements concerning storage facilities and LNG facilities

19.1

19.4

15. Third-party access services concerning storage and LNG facilities

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6) Next steps

• Regulators to keep in contact with operators to clarify misunderstandings and possible improvements affecting transparency obligations.

• Public Consultation to be launched in the following days

Operators’ responses to questionnaires will be published on ACER web site. Stakeholders will have full access to these questionnaires and will be able to provide their views. Opinions will provide a valuable assessment of operators’ compliance with the transparency requirements in Regulation 715/2009, helping authorities to ensure that the legislative requirements are appropriately implemented, in particular with:

•Quality, consistency, update frequency and availability of the information

•Information accessibility

•Information accuracy


Documents

1 Brussels, 27 th February 2012 8 th GRI Coordination Group South Gas Regional Initiative