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

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”.

3. Countries involved and replies received by May 2015
GRI SSE – pilot project XII
Countries involved and replies received by May 2015
MS SSE
Questionnaire sent
Gas infrastructure
Respondents
Poland x
Czech Republic
Slovakia
Austria
Italy
Hungary
Slovenia
Croatia
Romania
Bulgaria
Greece
Contracting Parties
Bosnia Herzegovina
Serbia
Montenegro
UNMI Kosovo
Albania
FYR of Macedonia
Ukraine
Moldavia
18 questions

4. GRI SSE – pilot project XII
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,

5. 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.  

6. 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.

7. 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

8. 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

9. 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

10. 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.  

11. 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

12. No standard cross-border capacity products have been defined yet
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?
Austria
Croatia
Czech Rep
Greece
Hungary
Italy
FYR of Macedonia
Poland
Romania
Serbia
Slovenia
Ukraine
yearly x
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
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 2015.
Monthly standard capacity products will be offered from 01. October 2016 latest and daily standard capacity products will be offered from 01. July 2017 latest.
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
monthly
D-ahead
within day  x

13. GRI SSE – pilot project XII
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.

14. GRI SSE – pilot project XII
Q11: Explain under which conditions a firm capacity product is considered as such under your regulatory framework.
Austria
Croatia
Czech Rep
Greece
Hungary
Italy
FYR of
Macedonia
Poland
Romania
Serbia
Slovenia
Ukraine
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
cases or during
the
maintanance
period defined
in advance
between TSO,
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 the
TSO
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.
product is
considered as
defined in Reg
(EC) 715/09,
while
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
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)
situation
but 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

15. GRI SSE – pilot project XII
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 (1st and 2nd 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, 2015. 

16. 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?

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

18. 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

19. 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 

20. 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).

21. 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

22. THANK YOU ! GRI SSE – pilot project XII
GRI SSE – Bucharest, 20 November 2015

23. Definitions 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.