1 TITRE GRI SSE –Bucharest, 20 November 2015 Pilot project XII: Questionnaire for the assessment of the main features of gas system implementation in SSE countries Regulatory perspectives

2 GRI SSE – pilot project XII Questionnaire for the assessment of the main features of gas system implementation in SSE countries The hereby questionnaire is part of the activities described and included in GRI SSE Work Plan The purpose of this survey is to examine the harmonization level of gas systems in the framework of the Third Energy Package implementation within the South South-East Gas Region. On the basis of the collected data, project promoters will prepare a report which will present the current situation in the Region. According to recital n. 19 of Regulation 715/2009/EC “To enhance competition through liquid wholesale markets for gas, it is vital that gas can be traded independently of its location in the system. The only way to do this is to give network users the freedom to book entry and exit capacity independently, thereby creating gas transport through zones instead of along contractual paths. The preference for entry-exit systems to facilitate the development of competition was already expressed by most stakeholders at the 6th Madrid Forum on 30 and 31 October Tariffs should not be dependent on the transport route. The tariff set for one or more entry points should therefore not be related to the tariff set for one or more exit points, and vice versa”.

Countries involved and replies received by May GRI SSE – pilot project XII 18 questions

Q1: Has an entry-exit system been implemented in your country that gives network users the freedom to book entry and exit capacity independently? If not, please specify:  when it is going to be introduced.  which are the conditions that hamper the introduction of a full entry exit system. All the countries declared to have in place the entry-exit system, except FYR of Macedonia and Ukraine, 4 GRI SSE – pilot project XII

Q2: Does your regulatory framework foresee capacity products with limitation of free allocability (limited access to the VTP, locational and/or temporal restrictions, etc.)?  If yes please describe these products. In all countries there are no capacity products with limitation of free allocation except Austria and Ukraine. Austria has in place DZK capacities and short-haul capacities Hungary, Romania, Serbia, still have historical P2P contracts which limit the access to VTP for some routes. 5 GRI SSE – pilot project XII

Q3: Are there still point-to-point (P2P) routes in place? No, If you still have P2P routes in place, please:  List the P2P routes;  describe the reasons;  Specify whether you plan to dismiss P2P tariffs or if they are permanent tariffs; In all countries there are no point-to-point routes in place except for special routes in Hungary, Romania and Serbia. 6 GRI SSE – pilot project XII

Q4: Is there a virtual trading point in your country?  Can you please briefly describe which requirements are to be fulfilled to operate actively at the VTP? Virtual trading points are in place in Austria, Croatia, Czech Republic, Greece, Hungary, Italy, Poland, Romania, Serbia and Slovenia. No VTP in Ukraine and in FYR of Macedonia 7 GRI SSE – pilot project XII

Q5: Does the virtual trading point cover also functionalities and services of a gas exchange? Virtual trading points cover functionalities and service of a gas exchange in Austria, Czech Repuplic, Hungary, Poland. It is not in place in Croatia, Greece, FYR of Macedonia, Romania, Serbia, Slovenia, and Ukraine 8 GRI SSE – pilot project XII

Q6: Is there a gas exchange in your country?  Can you please briefly describe which requirements are to be fulfilled to operate actively at the gas exchange? Gas exchange in place in Austria, Czech Republic, Hungary, Italy, Poland, Romania*. It is not in place in Croatia, Greece**, FYR of Macedonia, Serbia, Slovenia and Ukraine **In Greece there is a gas release program from the incumbent operator * the trading platforms operators are no counterparties 9 GRI SSE – pilot project XII

Q7: Have TSOs in your country already started pilot projects for the early implementation of network codes?  If yes please briefly specify in which field Pilot projects for the early implementation of network codes already started in Austria, Greece, Hungary, Italy, Poland, Romania and Slovenia. Croatia, Macedonia and Serbia have never carried out PP and Ukraine is going to introduce one PP in cooperation with Poland. 10 GRI SSE – pilot project XII

Q8: If TSOs from your country have already started a pilot project for the offer of bundled capacity, please specify which of the following bundling concepts have already been tested by each of these TSOs?  Process bundling, i.e. the bundled allocation of capacity with separate contracts with two TSOs; At the present moment just process bundling has been implemented.  Product bundling, i.e. on top of process bundling, ensuring the same conditions regarding the quality and usage of the capacity in the bundle. Process bundling in Austria, Czech Republic, Italy, Poland, Slovenia. Product bundling in Hungary. Romania asserts that both bundling concepts are implemented in the operational rules of the RBP. No PP on bundled capacity in Croatia, Greece, FYR of Macedonia, Serbia and Ukraine 11 GRI SSE – pilot project XII

Q9: What kind of standard cross-border capacity products (as defined by art. 9 of Commission Regulation No. 984/2013) does each TSO from your country currently offer? 12 GRI SSE – pilot project XII AustriaCroatiaCzech RepGreeceHungaryItaly FYR of Macedonia PolandRomaniaSerbiaSloveniaUkraine yearly xxx No standard cross-border capacity products have been defined yet Under the EU and the national legislation CAM NC complaint products have been introduced in Hungary as of 1 October Accordingly, the yearly and annual quarterly capacity allocation has already been completed for firm cross-border capacity products on 11 May and on 1 June, respectively x x Gaz-System offers yearly (4 years in ahead), quarterly, monthly and day-ahead cross-border capacity products. Both firm and interruptible. Day-ahead and within-day products are available without auction procedure which will be implemented in Polish Transmission Network Code before 1st Nov M onthly standard capacity products will be offered from 01. October 2016 latest and daily standard capacity products will be offered from 01. July 2017 latest. x There are no standard cross-border capacity products foreseen in the regulatory framework now. They can be introduced after the 1st of October, 2015 (when Transmission Network Code will be approved in compliance with the requirements of the 3rd Energy Package). quarterly x xx x monthly xxxxx x x D-ahead xxxxx x within day x

Q10: Do any of TSOs from your country offer capacity products at CAM IPs which are not compliant with CAM Regulation? Please specify the characteristics of these products. 13 GRI SSE – pilot project XII

Q11: Explain under which conditions a firm capacity product is considered as such under your regulatory framework. 14 GRI SSE – pilot project XII AustriaCroatiaCzech RepGreeceHungaryItalyFYR of Macedonia PolandRomaniaSerbiaSloveniaUkraine According to the Law 123/2012 the firm capacity is the capacity contractually guaranteed as uninterruptible by the TSO. An interruptible capacity is the capacity that can be interrupted by the TSO, in accordance with the conditions specified in the contract with the network user. firm capacity offered according to Regulation 715. When making available firm capacity, the TSO shall provide the network user with guaranteed access to such capacity except for the periods of agreed scheduled maintenance or emergency situations Firm capacity can be interrupted only in emergency cases or during the maintanance period defined in advance between TSO, network user and final customer. There are no capacity products foreseen in the regulatory framework now. They can be introduced after the 1 October, 2015 TSO can restrict the usage of firm product due to unplanned or planned maintenance acivities. In the last case it is possible for theTSO to keep the transportation fees if the maintenance activities are communicated at least 42 days in advance. If this is not the case, the TSO have to give back on pro rata basis and for the time the interruption take place the tariff fee paid by shippers. firm capacity product is considered as defined in Reg (EC) 715/09, while interruptible capacity is defined by Network code for gas transmission as “capacity of the transmission system which Transmission System Operator has a right to restrict or totally deny It is a product which can not be interrupted, i.e. the shipper is guaranteed to be able to use booked capacity. Under the NNGS Network Code (2nd amendment) we have the following definitions: Committed Delivery Transmission Capacity: The maximum Quantity of Natural Gas per Entry Point to which the Operator commits to being able to receive from the Transmission User, per Day at the specific Entry Point, Committed Reception Transmission Capacity: The maximum Quantity of Natural Gas per Exit Point, to which the Operator commits as being able to deliver to the Transmission User, per Day at the specific Exit Point, A firm capacity can effectively be interrupted in an extraordinary (emergency) situationbut for no other reason (such as temperature, routing, change of predominant flow direction etc.). Firm transportation servises can be interrupted for maintance and emergecy situations. The yearly planned maintenance interruption time is give for each IP by the TSO in advance

Q12: Are there more classes of interruptible products? Explain under which conditions interruptible capacity products are defined. One class: Slovenia, Austria, Croatia, Czech Republic, Hungary, Poland, Serbia, Greece More classes: Italy (1 st and 2 nd level) Romania and FYR of Macedonia: not defined yet Ukraine, no capacity products foreseen in the regulatory framework now, they can be introduced after the 1 October, GRI SSE – pilot project XII

Q13: With reference to CMP provisions, do you have the same set of rules as applied by your neighbouring countries? If not, please describe which problems do you face at each IP in relation to the CMP implementation and which solutions have you already discussed? 16 GRI SSE – pilot project XII

Q14: How is the gas year defined in your country? Starting on October 1 st –October 1 st : Austria, Croatia, Czech Rep, Hungary, Italy, Poland, Slovenia, and Romania. Starting on January 1 st –January 1 st : Greece and FYR of Macedonia. Starting on July 1 st – July 1 st : Serbia. Ukraine: not define currently, but starting from 1 October 2015 according to CAM NC 17 GRI SSE – pilot project XII

Q15: How is the gas day defined in your country? 06: :00 CET: Austria, Croatia, Czech Republic, Hungary, Italy*, Poland, Romania** and Slovenia 08: :00 CET: Greece, FYR of Macedonia and Serbia Ukraine: not define currently, but starting from 1 October 2015, will be set according to CAM NC * 06: :00 in winter and 05: :00 daylight saving time ** CET+1 18 GRI SSE – pilot project XII

Q16: According to art. 27 of Commission Regulation No. 984/2013, TSO shall offer “capacity by means of one or a limited number of joint web-based booking platforms”.  Which platform for primary capacity booking is used by TSOs in your country or planned to be used?  If a different platform is used by the adjacent TSO from one of your neighbouring countries, have you already discussed measures to overcome matching problems at the IPs involved? If yes, please describe the discussed model(s). Prisma: Austria, Czech Republic, Italy, Slovenia RBP:Hungary, Romania Gaz System Auctions:Poland, Czech Republic 1 IP Croatia, Greece, FYR of Macedonia, Serbia and Ukraine have no platform complaint to the Regulation No. 984/2013 Serbia: platform is currently under development. but only for unbundled products. In between Baringa study promoted by ACER fix the point on the current situation but no effective steps have been taken for IPs with different platforms 19 GRI SSE – pilot project XII

Q17: Is there a secondary capacity trading platform?. Is the platform for trading secondary capacity the same as through which primary capacity is allocated? Platform for trading secondary capacity not in place: Greece, FYR of Macedonia, Romania, Serbia, Ukraine, Platform for trading secondary capacity in place: Austria (Prisma), Croatia (TSO), Czech Republic (TSO), Hungary (TSO, RPB), Italy (Prisma, other platforms) Poland (GSA), Slovenia (TSO). 20 GRI SSE – pilot project XII

Q18: Having in mind the accomplishment of the European Energy market and notwithstanding the above list of questions, have you already recognized specific points of your regulation which hamper the cross- border trade of gas? Self-criticism: No open and recognized points which hamper the cross-border trade of gas: Slovenia, Austria, Czech Rep, Greece*, Italy*, Romania, Serbia *amendment of the current gas legislation are ongoing 21 GRI SSE – pilot project XII

THANK YOU ! GRI SSE – Bucharest, 20 November GRI SSE – pilot project XII

Gas market The sum of gas (wholesale) trading activities (spot to forward (inclusive)) with delivery agreed on a (single) specific delivery hub. Hub The virtual trading point of an entry/exit system where the TSO (or a separate independent entity dedicated at national level) handles all nominations for the transfer of title to gas between network users (or balancing accounts) Transparent market The sum of gas trading activities (spot, prompt and forward) with delivery agreed on a (one) specific delivery point and concluded using a transparent trading venue (i.e. exchange, broker platform). Note: the main delivery points are the virtual trading points of entry/exit systems. Distinct delivery points are considered as separate markets. Virtual trading point A notional point in an entry/exit system at which natural gas can be traded within the entry/exit system after injection and before offtake. 23 Definitions