1. Transparency GRI SSE -- 7th Stakeholder Group Meeting Vienna, 16 October 2009 Andrea Ćirlićová GTE+ Senior Adviser

2. Transparency Platform Transparency requirements under Regulation (EC) 715/2009 Transparency Guidelines to be annexed to Regulation (EC) 1775/2005

3. Transparency Platform gas-roads.eu

4. History Phase 1 Phase 2 Development 17 November 2008 TSO-related information Capacity & tariff information Search functionality Further development & fine-tuning; TP ‘enlargement‘ * CAM Information Balancing Model information 17 March 2009 2 April 2009 Capacity display in kWh/d Actual flows (allocations) Nominations/renominations Interruptions Download facility 27 May 2009 * 17+10 TSOs represented on TP on 16 October 2009 November 2008 June 2008 gas-roads.eu

5. gas-roads.eu Participating TSOs (1)

6. Participating TSOs (2)

7. TP Demonstration (1)

8. TP Demonstration (2)

9. TP Demonstration (3)

10. Phase 3 gas-roads.eu Way Forward

11. TP development in 2009-2010 (1) Improving the data quality (‘added value of the information‘) & quantity Coordination of and support to TSOs in implementing voluntary transparency at the national level Attracting non-participating TSOs to join the project gas-roads.eu

12. TP development in 2009-2010 (2) Enhancing user-friendliness Extending the scope of information provided Using the TP as a way to comply with Regulation (EC) 715/2009‘s transparency obligations? Introducing more interactive elements, e.g. database-search for aggregated information relating to the transmission systems, incl. possibly data collected for the development of TYNDP Supporting the participation of other infrastructure operators gas-roads.eu Based on feedback; issues raised at Transparency Workshop on 30 Sep 2009

13. Long-term Objective gas-roads.eu Creation of extensive database Creation of interactive tool For network users For TSOs For ACER / MSs Commission Considering that the data may be used by consultancies to sell transparency-related services, should the use of certain TP services be charged?

14. Transparency requirements under Regulation (EC) 715/2009

15. Regulation (EC) 715/2009 Published in the Official Journal on 14 August 2009 Applicable as of 3 March 2011 (repeals Regulation (EC) 1775/2005) Additional transparency obligations vis-à-vis TSOs New transparency obligations vis-à-vis SSOs and LNG SOs To ensure consistent implementation of the transparency obligations by TSOs, GTE+ has undertaken to define a common European approach by specifying the deliverables and recommends all its members as well as other TSOs to implement them

16. Transparency Obligations 3-minus rule not applicable any more “The transmission system operator shall make public ex-ante and ex-post supply and demand information, based on nominations, forecasts and realised flows in and out of the system. The national regulatory authority shall ensure that all such information is made public. The level of detail of the information that is made public shall reflect the information available to the transmission system operator. The transmission system operator shall make public measures taken as well as costs incurred and revenue generated to balance the system. The market participants concerned shall provide the transmission system operator with the data referred to in this Article.” “Each LNG and storage system operator shall make public the amount of gas in each storage or LNG facility, or group of storage facilities if that corresponds to the way in which the access is offered to system users, inflows and outflows, and the available storage and LNG facility capacities, including for those facilities exempted from third-party access. That information shall also be communicated to the transmission system operator, which shall make it public on an aggregated level per system or subsystem defined by the relevant points. The information shall be updated at least daily.” * * Publication may be restricted for a certain time period if the aggregate information refers to only one user, and an exemption has been granted by the NRA on the basis of a request by the storage user.

17. Ex-ante Supply * To be published at 6 p.m. CET If the TSO is obliged, under national regulatory rules, to provide its own supply forecast, such forecast will be published along with the ex-ante supply information as specified above. Ex-ante supply information*In kWh/d Aggregated nominations at entries (as specified in the rows below) Aggregated nominations at IPs with other transmission systems (incl. balancing zones within the same transmission system) or between market areas Aggregated nominations at IPs with storage systems Aggregated nominations at IPs with production facilities Aggregated nominations at IPs with LNG terminals Supply forecast by TSOIn kWh/d Supply forecast

18. Ex-ante Demand If the TSO is obliged, under national regulatory rules, to provide its own demand forecast, such forecast will be published along with the ex-ante demand information as specified above. Ex-ante demand information*In kWh/d Aggregated nominations at exits (as specified in the rows below) Aggregated nominations at IPs with other transmission systems (incl. balancing zones within the same transmission system) or between market areas Aggregated nominations at IPs with storage systems Aggregated nominations at IPs with LNG terminals (if applicable) Demand forecast by TSOIn kWh/d Demand forecast * To be published at 6 p.m. CET The information on ex-ante demand will be extended by Aggregate Nominations at IPs with distribution systems if such nominations are available to the TSO, or by any comparable figure if supplied by suppliers to the TSO.

19. Ex-ante Supply and Demand The information on ex-ante supply and demand will be accompanied by the following note if applicable: The ex-ante supply and demand information needs to considered in the light of the following system specificities: (1)network users are allowed to nominate imbalances; (2) network users are allowed to nominate virtual counter flows at the IPs between TS-DS (the Aggregate Nomination will be published under ex-ante supply information); (3) one or more storage facilities are connected to the relevant distribution networks; (4) one or more production facilities are connected to the relevant distribution networks.

20. Ex-post Supply *To be published within 48 hours after the end of the relevant Gas-Day on preliminary basis and by M+30 (working days) as validated figures.. Ex-post supply information*In kWh/d Aggregated allocations at entries (as specified in the rows below) Aggregated allocations at IPs with other transmission systems (incl. balancing zones within the same transmission system) or between market areas Aggregated allocations at IPs with storage systems Aggregated allocations at IPs with production facilities Aggregated allocations at IPs with LNG terminals

21. Ex-post Demand Ex-post demand information*In kWh/d Aggregated allocations at exits (as specified in the rows below) Aggregated allocations at IPs with other transmission systems (incl. balancing zones within the same transmission system) or between market areas Aggregated allocations at IPs with storage systems Aggregated allocations at IPs with LNG terminals (if applicable) Aggregated allocations at IPs with distribution systems and directly connected customers *To be published within 48 hours after the end of the relevant Gas-Day on preliminary basis and by M+30 (working days) as validated figures..

22. Balancing Info Framework measures taken to balance the system Balancing model Hourly / Daily with hourly constraints / Daily / Monthly with daily constraints Balancing tolerances (types & range) Hourly Imbalance Tolerance / Daily Imbalance Tolerance / Additional Daily Imbalance Tolerance / Cumulated Imbalance Tolerance / Additional Cumulated Imbalance Tolerance Information to network users prior to and during the respective Gas-Day Cash-out arrangements Balancing mechanisms (flexibility tools) used by the TSO Costs incurred Revenues generated Remarks Dynamic type of information should be defined at the national level to reflect the specificities of the respective balancing regime.

23. Storage & LNG Info Storage data*Units* Daily aggregated amount of gas in storage facilities per (sub)system in kWh or m3 Daily aggregated inflows and aggregated outflows in and from storage facilities per (sub)system in kWh or m3 Daily available capacities at storage facilities aggregated per (sub)system LNG data*Units Daily aggregated amount of gas in LNG facilities per (sub)system in kWh or m3 Daily aggregated inflows and aggregated outflows in and from LNG facilities per (sub)system in kWh or m3 Daily available capacities at LNG facilities aggregated per (sub)system A joint meeting will be yet held with GSE and GLE to discuss the exact form of publishing aggregated available capacities and the communication format.

24. Conclusions 3rd energy package has brought some more explicit transparency provisions but considerable room for interpretation still remains –Transparency provisions primarily define what information should be published NOT always who the originator of the information is (e.g. forecasts), which is subject to a subsidiarity principle and needs to be decided at the national level GTE+ has attempted to define a common European approach to implementation to ensure consistency and comparability of information GTE+ is ready to further work on this issue with all stakeholders Note: The implementation of the transparency obligations should be considered along with the implementation of other obligations under both Regulation (EC) 715/2009 and Directive 2009/73/EC.

25. Transparency Guidelines to be annexed to Regulation (EC) 1775/2005

26. State of Play Final draft Transparency Guidelines in Commission‘s inter- service consultation Comitology procedure to be started in November Due to the legal construct for transition between 2nd and 3rd energy package provisions, timeline for the whole process, incl. implementation, is far from clear The final draft guidelines‘ transparency requirements are more extensive than originally envisaged in the text presented at MF in May 2009 –The implementation of such requirements is likely to call for a substantial amount of time and money