Response from MARCOGAZ - Agency for the Cooperation of Energy

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Draft Framework Guidelines on Interope rability
Rules and Data Exchange for the European Gas
Transmission Networks Public Consultation Questionnaire
16 March 2012
PC-07- PUBLIC CONSULTATION ON DRAFT FRAMEWORK GUIDELINES
ON INTEROPERABILITY RULES AND DATA EXCHANGE FOR THE EUROPEAN GAS
TRANSMISSION NETWORKS
QUESTIONNAIRE
Please provide the Agency with your full contact details, allowing us to revert to you with
specific questions concerning your answers.
Name: Daniel HEC
Position held: Secretary General
Phone number and e-mail: +32 2 237 11 35; [email protected]
Name and address of the company you represent: MARCOGAZ, Avenue Palmerston 4, B-1000
Brussels
1.
Scope and application, implementation (Chapter 1 of the Framework Guidelines
(the ‘FG’)
1.1.
Do you consider that the FG on interoperability and data exchange rules should
harmonise these rules at EU level, as follows:
a) At interconnection points only?
b) Including interconnection points and where appropriate points connecting TSOs’
systems to the ones of DSOs, SSOs and LSOs (to the extent cross-border trade is
involved or market integration is at stake)?
c) Other option? Please explain in detail and reason.
d) I don’t know.
In general, Framework Guidelines should aim at harmonising interoperability and data exchange
rules at interconnection points.
1.2.
Do you consider that for any of the above options the level of harmonisation 1 shall be
(Section 1.b of the FG):
a. Full harmonisation: the same measure applies across the EU borders, defined in the
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Draft Framework Guidelines on Interope rability
Rules and Data Exchange for the European Gas
Transmission Networks Public Consultation Questionnaire
network code?
1 Harmonisation is used in the meaning of replacing two or more legal systems with one single system.
Harmonisation with built-in contingency: same principles/criteria are set with a possibility to deviate
under justified circumstances?
b. No additional harmonisation, meaning rules are set at national level, if they deemed
necessary by the national authorities, which may include either NRAs or the
government?
Full harmonisation should be the target although some interim steps to take into account
specific technical issues will need to be set.
1.3.
Shall any of the issues raised in the FG (Interconnection Agreement, Harmonisation of
units, Gas Quality, Odorisation, Data exchange, Capacity calculation) get a different
scope from the general scope as proposed in section 1.b. of the FG (and as addressed
in the previous question)? Please answer by filling in the following table, ticking the box
corresponding to the relevant foreseen scope.
IAs
Full harmonization
Units
X
Partial
harmonization
Gas Quality
Odorisation
Data Exchange
Capacity
Calculation
X (goal)
X
Business as usual
X
1.4. What additional measures could you envisage to improve the implementation of the
network code? Please reason your answer.
2.
Interconnection Agreements
2.1.
Do you think that a common template and a standard Interconnection Agreement will
efficiently solve the interoperability problems regarding Interconnection Agreements and/or
improve their development and implementation?
a.
b.
c.
d.
e.
Yes.
No.
I don’t know.
Would you propose additional measures as to those proposed? Please reason your
answer.
Would you propose different measures as to those proposed? Please reason your
answer.
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Draft Framework Guidelines on Interope rability
Rules and Data Exchange for the European Gas
Transmission Networks Public Consultation Questionnaire
2.2.
2.3.
Do you think that a dispute settlement procedure as laid down in the text will efficiently
contribute to solving the interoperability problems of network users regarding
Interconnection Agreements and their content?
a. Yes.
b. No.
c. I don’t know.
d. Would you propose additional measures as to those proposed? Please reason your
answer.
e. Would you propose different measures as to those proposed? Please reason your
answer.
Do you think that a stronger NRA involvement in the approval of the Interconnection
Agreements could be beneficial? Please explain in detail and reason.
a.
b.
c.
Yes.
No.
I don’t know.
3.
Harmonisation of Units
3.1.
Do you think that there is a need for harmonisation of units?
a.
b.
c.
d.
Yes.
No, conversion is sufficient in all cases.
I don’t know.
Would you propose additional measures as to those proposed? Please reason your
answer.
e. Would you propose different measures as to those proposed? Please reason your
answer.
YES, there is a clear need for using the units already commonly used along the gas chain by
most of the actors at international level (ISO standards to be preferred). This is also in line with
WTO agreements.
3.2.
What is the value added of harmonising units for energy, pressure, volume and gross
calorific value?
a.
b.
c.
d.
e.
f.
Easier technical communication among TSOs.
Easier commercial communication between TSOs and network users.
Both.
No value added.
I don’t know.
Other views. Please reason your answer.
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Draft Framework Guidelines on Interope rability
Rules and Data Exchange for the European Gas
Transmission Networks Public Consultation Questionnaire
Easier communication between all actors: TSOs, TSOs and network users, DSOs…Avoid
calculation mistakes and misunderstanding between stakeholders.
3.3.
Shall harmonisation be extended to other units? Please reason your answer.
No, the current set of units adequately covers the different needs.
4.
Gas Quality
4.1.
Please provide your assessment on the present proposal; in particular assess the
provisions on ENTSOG gas quality monitoring, dispute settlement and TSO cooperation. Would
these measures address sufficiently the issues that are at stake? Please reason your answer.
Harmonisation of gas quality, in line with the DG ENER "Gas quality roadmap" as
welcomed during the last Madrid Forum, should be sought.
In the meantime, it shall be of the responsibility of the TSOs and NRAs to find adequate
solutions when discrepancies are identified at an IP. Tools for handling different gas quality
and cost allocation and recovery mechanisms shall be established.
4.2.
Do you consider that a technically viable solution to gas quality issues that is financially
reasonable will most likely result from:
a. Bilateral solution between concerned stakeholders.
b. Solutions to be developed cross-border by TSOs, to be approved by NRAs and
cost-sharing mechanism to be established.
c. The establishment of a general measure in the Framework Guidelines, setting a
comprehensive list of technical solutions to select from.
d. I don’t know.
e. Other option. Please reason your answer.
Solution a. (bilateral solution) should be preferred, then b (developed by cross border
TSOs, approved by NRA including cost sharing mechanism) and c (general measure). A
case by case approach is most likely to provide the best answers and sharing the solutions
developed at EU scale is very important.
The harmonization of gas quality between TSO and DSO should follow directly the cross
border harmonization. It is essential for the TSO not to be obliged to accept gas that cannot
be delivered to the local distribution and then to the consumers.
Additionally it is important that the formulation in the network codes does not open up for
the possibility to move gas quality challenges from one system to another. An example
could be off-specification gas in offshore systems. The implementation of FG should
preferably define who has the responsibility for gas quality
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Draft Framework Guidelines on Interope rability
Rules and Data Exchange for the European Gas
Transmission Networks Public Consultation Questionnaire
5.
Odorisation
5.1.
Please provide your assessment on the present proposal. Would the measure proposed
address sufficiently the issues that are at stake? Please reason your answer.
Odorisation, defined by national rules, is a major issue for the safety of the gas system
and the consumers. For cross border trade, it should be considered as a sub-issue of gas quality.
In general odorisation should be considered as not needing other harmonisation rules other than
those covering gas quality.
For the time being, non-odorised gas by default at European level is not feasible because
there are still Member States that centrally odorise natural gas in the transmission grids.
Developing other odorisation solutions is a lengthy process as systems operated with odorised gas
may continue to present significant amount of odorant several years after injection of odorant in
transmission systems or gas storages.
NRAs would need to judge which IPs require a solution and should then explore options
together with the TSOs and the relevant Member State Authorities. The final decision shall be
accompanied by an adequate cost allocation and recovery mechanism.
Deodorisation at IP to avoid the transmission of odorised gas raises several issues:
- There is huge uncertainty related to both CAPEX and OPEX of the deodorisation
facilities and the cost of changing the odorisation practices. If de-odorisation was
required, it would be necessary to carry out a cost benefit analysis, in particular to
determine which end users would be affected and where it would be more effective
to deodorise the gas.
- If a default rule at European level is established, cross-border trade between
countries which currently exchange odorised gas shall not be hampered.
- Currently, there is no proven, cost-effective technology to deodorise completely the
gas at cross-border interconnection points. Therefore, the default rule shall not be
approved while there is not any evidence of it.
6.
Data exchange
6.1.
Please provide your assessment on the present proposal. Would the measures
proposed address sufficiently the issues that are at stake? Please reason your answer.
6.2.
Regarding the content of this chapter,
a. Data exchange shall be limited to the communication format.
b. Data exchange shall define both format and content, at least regarding the following
points: __________________ . Please reason your answer.
c. I don’t know.
d. Other option. Please reason your answer.
Draft Framework Guidelines on Interope rability
Rules and Data Exchange for the European Gas
Transmission Networks Public Consultation Questionnaire
6.3.
ENTSOG may support the exchange of data with a handbook of voluntary rules. Please
share your views about such a solution.
7.
Capacity calculation – The Agency view is that discrepancy between the maximum
capacities on either side of an interconnection point, as well as any unused
potential to maximise capacity offered may cause barriers to trade.
7.1.
Please provide your assessment on the present proposal. Would the measures
proposed address the issues that are at stake?
7.2.
Would you propose additional measures as to those proposed? Please reason your
answer.
7.3.
Would you propose different measures as to those proposed? Please reason your
answer.
8.
Cross-border cooperation
8.1.
Please provide your assessment on the present proposal.
8.2.
Do you have any other suggestions concerning cross-border cooperation? Please
reason your answer.
9.
Please share below any further comments concerning the Framework Guideline
on Interoperability and Data Exchange Rules.
Thank you very much for your contribution.
Agency for the Cooperation of Energy Regulators
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