Download 5. Gas Quality

Framework Guidelines
on Interoperability Rules for European
Gas Transmission Networks
Version for 1st Expert Group Meeting
ACER Gas Working Group
FGC-2011-G-003
28 October 2011
Agency for the Cooperation of Energy Regulators
Trg Republike 3
1000 Ljubljana - Slovenia
This Document contains the draft Framework Guidelines on Interoperability Rules
for European Gas Transmission Networks, which the Agency for the Cooperation
of Energy Regulators (ACER) has developed pursuant to Articles 6 of Regulation
(EC) No 713/2009 and of Regulation (EC) No 715/2009 and on the basis of a
request from the European Commission.
Related Documents
-
Framework Guidelines on Capacity Allocation Mechanisms for the European Gas
Transmission Network; FG-2011-G-001; 3 August 2011, adopted by ACER.
-
Framework Guidelines on Gas Balancing in Transmission Systems; FGB-2011-G-002 ;
18 October 2011, published by ACER.
-
EC draft guidelines on congestion management procedures; Commission proposal
for guidelines to be adopted via a comitology procedure; 18th Madrid Forum of 27 &
28 September 2010.
-
Commission Decision of 10 November 2010 amending Chapter 3 of Annex I to
Regulation (EC) No 715/2009 of the European Parliament and of the Council on
conditions for access to the natural gas transmission networks.
-
European Commission Mandate to CEN for standards for biomethane for the use in
transport and injection in natural gas pipelines. (M/475), 8 November 2010.
-
European Commission Mandate to CEN for standardisation in the field of gas
qualities (M/400), 16 January 2007.
-
ENTSOG Interoperability WA - Harmonisation of Maintenance Publication
(INT047-11_rev0)
-
ENTSOG Technical paper on the injection of biogas into the natural gas networks
(INT010-10_Rev FINAL)
-
EASEE-gas CBP 2005-002/02 Interconnection Agreement
EASEE-gas CBP 2005-001/02 Gas Quality Harmonisation
EASEE-gas CBP 2003-002/02 Harmonisation of Nominating and Matching Process
EASEE-gas CBP 2007-006/01 Harmonisation of the Allocation Information Exchange
EASEE-gas CBP 2003-003/02 EDIG@S Protocol
EASEE-gas CBP 2005-003-01 Constraints
EASEE-gas CBP 2003-001-01: Harmonisation of units.
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Table of Contents
1. General Provisions .............................................................................................................4
1.1. Introduction ...................................................................................................................4
1.2. Definition of Interoperability ...........................................................................................4
1.3. Objective .......................................................................................................................5
1.4. Definitions .....................................................................................................................5
1.5. Scope of application ......................................................................................................6
1.6. Implementation .............................................................................................................7
2. Nomination and re-nomination regime .............................................................................7
3. Interconnection Agreements .............................................................................................8
4. Harmonization of Units ......................................................................................................9
5. Gas Quality .......................................................................................................................10
6. Data Exchange..................................................................................................................10
7. Capacity Calculation ........................................................................................................11
7.1. Technical Capacity Calculations..................................................................................11
7.2. Calculation of Available Capacity ................................................................................11
7.3. Updating of Available Capacity Calculations ...............................................................12
7.4. Consistency of Available Capacity Calculations ..........................................................12
8. General provisions ...........................................................................................................12
9. Cross-border cooperation ...............................................................................................13
10. Compliance .......................................................................................................................13
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1.
1.1.
General Provisions
Introduction
Operational, technical, communications-related as well as business procedures can strongly
influence the development of markets. The existence of technical and operational barriers at
European borders constitutes an obstacle to the creation of an integrated, competitive internal
European market for energy. The European Council of 4 February 2011 calls for the completion
of such a market “by 2014 so as to allow gas and electricity to flow freely” 1.
In the light of the ongoing existence of barriers to the free flow of gas in Europe, the Framework
Guidelines on Interoperability Rules for European Gas Transmission Networks (Framework
Guidelines) identify areas where increased harmonisation of technical, organisational and
communication rules and practices will foster market integration and will facilitate and enhance
cooperation between transmission system operators (TSOs) as well as between TSOs and
system users.
The Framework Guidelines aim at setting clear and objective principles for the development of a
network code on interoperability (network code), pursuant to Article 6(2) of Regulation (EC) No
715/2009 (the “Gas Regulation”)2.
The scoping process which provided the basis for the present draft Framework Guidelines
included bilateral meetings with stakeholders as well as a workshop on scoping and an informal
consultation organised by ACER.
ACER received the invitation to start with the Framework GuidlineGuideline on xx November
2011. An ad hoc Expert Group was set up as a result of an open procedure to assist in the
development of the Framework Gudieline.
1.2.
Definition of Interoperability
For the purpose of these Framework Guidelines, the term “interoperability” refers to the ability of
diverse transmission systems to work together (inter-operate) in a technical system / operational
sense in order to facilitate the functional and economic exchange of gas across networks, taking
into account organisational factors that impact system to system performance as well as the
simple and reliable exchange of information between system operators as well as between
system operators and system users.
1
2
European Council of 4 February 2011, Conclusions
Regulation (EC) No 715/2009 of the European Parliament and of the Council of 13 July 2009 on conditions for
access to the natural gas transmission networks and repealing Regulation (EC) No 1775/2005, OJ L 211/36
14/08/2009.
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The overall aim of interoperability is to ensure that users of transmission systems in Europe do
not face higher technical, commercial or operational or communications-related barriers than
might be expected if the relevant networks were efficiently operated by a single entity.
Interoperability results from the cooperation between system operators as well as between
system operators and system users agreeing on technical parameters, common written
operational procedures and protocols used for information exchange.
1.3.
Objective
The over-arching objective of the network code on interoperability is to promote the
harmonisation of rules for the operation of transmission systems in order to encourage and
facilitate efficient gas trading and transport across systems within the EU and thereby move
towards greater market integration.
The specific objective for the network code on interoperability is to define consistent harmonized
technical, operational and communication-related rules that shall allow reaching the overall
objective of the Framework Guideline and the 3rd energy package, including on nomination
processes, interconnection agreements, unit harmonisation, gas quality, capacity calculation and
data exchange.
The scientific and technological principles underlying the rules to be harmonized with a view of
improving the level of interoperability in transmission networks are subject to constant change,
review and improvement by science and experience. New scientific findings and technological
expertise might change the state of the art in the operation of gas transmission networks. The
Framework Guidelines will thus be limited to setting out broad general requirements, leaving
flexibility and space for the inclusion of new technological findings to the network code and its
possible future revisions.
Once drafted, the network code on interoperability is submitted to the Agency for the Cooperation of
Energy Regulators (ACER) for a reasoned opinion. Taking into account its degree of compliance with
the Framework Guidelines and the fulfilment of the overarching objectives (maintaining security of
supply, supporting the completion and functioning of the internal market in gas and cross-border
trade including delivering benefits to the customers), ACER submits the network code to the
European Commission and may recommend that it be adopted within a reasonable time period via
comitology.
1.4.
Definitions
For the purpose of these Framework Guidelines, the definitions of the Directive 2009/73/EC3 (the
“Gas Directive”) and the Gas Regulation apply in addition to the following definitions:
3
Directive 2009/73 of the European Parliament and the Council of 13 July 2009 concerning common rules for the
internal market in natural gas and prpealing Directive 2003/55/EC, OJ L 211/94, 14/08/2009
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
Interface points – the physical entry and exit points on a transmission system where gas
sale/purchase/trade/transfer may be taking place;

Data exchange – the exchange of all necessary information between TSOs as well as
between TSOs and system users and between TSOs and operators of adjacent
distribution systems according to the provisions of the network code.

Infrastructure operators – transmission system operators, storage system operators, LNG
terminal operators and producers;

Interconnection Agreement – an agreement established between at least two
infrastructure operators whose systems are connected, covering rules and principles on
information exchange, operational and technical procedures concerning the delivery or
withdrawal of gas at the particular connection.

Interconnection Point – means a cross-border interconnection point, whether it is
physical or virtual, between two or more Member States as well as interconnection
between adjacent entry-exit-systems within the same Member State, in so far as these
points are subject to booking procedures by network users.

Operational constraint – an unplanned event occurring, for a limited period of time, as
a consequence of a failure in the transmission system or a problem linked to gas quality
and causing available transport capacity at an interconnection point to be unexpectedly
less than aggregated confirmed quantities during the nomination or re-nomination
regime.

Network user – a party that uses the transmission system to transport gas from one
location to another or to trade gas at the virtual trading point.

Gas Day - 5:00 to 5:00 UTC/GMT, or any other time period harmonised across the EU
as defined in the network code on capacity allocation mechanisms by ENTSOG.

Operational Balancing Agreement – an agreement established between two system
operators whose systems are linked at a particular IP to handle day-to-day variations in
the gas flow that are due to operational factors.
1.5.
Scope of application
If not further specified, the rules in these Framework Guidelines on Interoperability Rules for
European Gas Transmission Networks apply to cross-border interconnection points between two or
more Member States as well as to interconnections between adjacent entry-exit systems, and to all
other entry and exit points of those entry/exit systems, including entry/exit points to storage, LNG,
production facilities and end consumers as well as entry/exit points to the distribution sytem .
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The network code on interoperability rules developed by the European Network of Transmission
System Operators for Gas (ENTSOG) and adopted according to the Framework Guidelines will be
applied by TSOs. The provisions contained in the network code are without prejudice to the
regulatory regime for cross-border issues pursuant to Article 42 of the Gas Directive and of the
responsibilities and powers of regulatory authorities established according to Article 41(6) of the Gas
Directive insofar the network code does not provide for full harmonisation.
1.6.
Implementation
Given the different stages of IT development across Europe and the impact that harmonised
interoperability rules may have, implementation may only be achieved gradually. The network
code on interoperability rules shall therefore define rules that are consistent with the ultimate
goal of a common European market, but that allow for TSOs to implement compatible solutions
where this may be appropriate. TSOs shall only implement such compatible solutions if the
national regulatory authority (NRA) has approved this, based on an assessment of the
development of the market.
Member States may put in place additional gas matching or other interoperability arrangements
that shall apply during an emergency (as defined in Article 10(3)(c) of Regulation (EC) No
994/20108 concerning measures to safeguard security of gas supply). Some guidance on these
additional arrangements is already provided in that Regulation and more guidance will eventually
be provided in the network code on operational procedures in an emergency (according to
Article 8(6)(f) of the Gas Regulation).
The network code on interoperability rules shall require the European Network of Transmission
System Operators for Gas (ENTSOG) to regularly review the progress towards its
implementation.
2.
Nomination and re-nomination regime
The differences that exist in terms of nomination processes4 at or between IPs constitute a potential
barrier to trade and may hamper the emergence of an efficient and integrated internal EU gas
market.
Harmonised nomination and re-nomination processes have to be implemented at all interface points
across Europe.
The network code on interoperability rules shall, if not covered by any other legal obligation, provide
for a harmonisation of all nomination and confirmation deadlines so as to ensure that shippers
operating in several entry-exit zones receive confirmation of all scheduled flows for the next gas day
4
Processes include the definition of deadlines and interactions between parties
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simultaneously. This initial nomination and re-nomination scheme shall not restrict the possibility for
shippers to sent in nominations at all times.
All infrastructure operators shall cooperate together as to allow the transmission system operator to
confirm the (hourly or daily) quantities of gas to his network users that will be scheduled to flow
through its system on the next gas day. As mismatches on both sides of an interface point is being
detected during the process of confirming nominations, the transmission system operator shall apply
the ‘lesser rule’ principle, meaning that in case of different positions between a delivering and a
receiving shipper at the two sides of an interconnection, and in case neither of the shippers adjusts
its position, the higher of the two values will be reduced to the lower value in order to avoid a
discontinuity over the intersection.
As a general principle and as a minimum requirement, re-nominations should be received at the
latest two full hours before becoming effective. The network code on interoperability rules can set
shorter lead times, for example where different systems are operated by the same system operator.
The network code on interoperability rules, when specifying the harmonised nomination and renomination process, shall set common rules on all aspects as mentioned above, including the
content and format of messages and confirmation notices to be exchanged between system
operators and system users.
The network code on interoperability rules, when specifying the harmonised nomination and renomination process, shall define processes of cooperation between infrastructure operators in order
to mitigate problems underlying operational constraints, as well as define the rules and procedures
on how information on the duration, extent and handling of constraints is communicated and should
also specify the content of information to be exchanged between TSOs of adjacent systems as well
as between TSOs and users.
The network code shall also outline the procedures to be applied to re-establish a new set of
confirmed quantities for shippers at interconnection points once the constraint is successfully
handled.
The network code on interoperability shall, were appropriate, build on or complement the common
network operation tools ENTSOG has to develop on the coordination of network operations in
normal and emergency conditions, including a common incidents classification scale, and research
plans, as well as recommendations relating to the coordination of technical cooperation between
Community and third-country TSOs.
3.
Interconnection Agreements
Interconnection Agreements shall contain the information necessary to ensure a smooth exchange of
information between adjacent infrastructure operators.
The network code on interoperability rules shall outline a framework for interconnection agreements
to be understood as a minimum set of requirements for the individual interconnection agreements to
be established on a mandatory basis by all connected infrastructure operators at the connections.
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The network code shall describe a template for interconnection agreements at least including the
following points and providing clear guidelines on the level of detail and the content to be covered by
each individual interconnection agreement in order to ensure consistency and a high level of
harmonization across Europe:
4.
o
Matching: Interconnection agreements are to include detailed guidelines on how
communication on the matching process shall function between TSOs with a view to ensuring
confirmed quantities of gas are equal on both side of the point. The Network Code should
also define rules in case of mismatch
o
Rules for flow control: Rules for interconnection agreements to be outlined by the network
code shall ensure that infrastructure operators at the connections agree on the timing,
direction and procedures for flow control.
o
Measurement principles of gas quantities and quality: The network code shall ensure
interconnection agreements include provisions on methods and procedures including
harmonised conversion factors, for the measurement of gas quantities and gas quality as well
as rules for the handling of differences in measurement and measurement corrections.
o
Rules for the allocation of measured gas quantities: The interconnection agreements for
which the network code establishes a common framework shall foresee consistent rules for
the allocation of gas to each shipper. The interconnection agreements shall include
Operational Balancing Agreements to ensure that minor deviations are handled by the
infrastructure operators.
o
Exceptional events: The network code shall ensure that interconnection agreements contain
provisions on how operators shall establish contact and coordinate necessary actions in case
of an exceptional event. The content and timing of information to be exchanged between
operators and between operators and users in case of exceptional events shall be defined.
o
Modification and Development of interconnection agreements: The network code shall
establish how interconnection agreements are to be elaborated between TSOs and shall
outline a transparent process for the modification of these agreements.
Harmonization of Units
A lack of harmonization with regard to the units used by actors along the gas value chain may
consititute a barrier to trade and can unnecessarily complicate the trading and transporting of gas
throughout Europe.
Where the harmonization of units has already been covered by EU legislation, e.g. transparency
guidelines5 or in a network code, the network code on interoperability rules shall not duplicate these
provisions.
5
Chapter 3 of Annex I of the Gas Regulation.
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The network code on interoperability rules shall thus determine the use of harmonized units for
energy, volume and gross calorific value in those cases where the harmonization of units is not yet
foreseen elsewhere.
5.
Gas Quality
The European Commission has identified differences in gas quality as a potential barrier to the
trading of gas and the development of an integrated internal gas market in Europe. It has therefore
requested CEN by Mandate M/400 to harmonise the gas quality parameters (H-gas) in Europe.
A draft standard for all relevant parameters is expected by January 2013.
The network code on interoperability shall foresee the implementation of harmonized ranges for gas
quality, for all relevant gas parameters at the cross border interconnection points between adjacent
entry/exit systems and EU entry points, including the exit of LNG import terminals, for high calorific
gas without added odorants, and excluding areas of production and isolated systems where
production, transportation and utilisation are combined..
The respective parties on a case-by-case basis should address contractual constraints with respect
to the implementation of the various parameters and related values. For the avoidance of doubt, it is
the common understanding that this recommendation should not limit the parties’ rights to agree on
specifications outside the proposed ranges and continue their agreements on a bilateral basis.
The network code on interoperability shall outline rules for the harmonization of odorization practices
in transmission systems throughout Europe with the objective to facilitate cross-border trade.
Furthermore, the European Commission has requested CEN to elaborate a standard for biomethane
(CEN Mandate M475). The network code on interoperability shall make reference to this standard
and outline additional rules on the injection of biogas in the natural gas grid to complement the
standard and ensure a harmonized European approach toward the injection of biomethane.
6.
Data Exchange
Data exchange and settlement rules shall be treated under a separate FG pursuant to Article 8 Gas
Regulation which shall be covered by (a) network code(s) to be developed by ENTSOG.
As far as capacity bookings and the transfer of capacity rights between network users are concerned,
the Framework Guidelines on Capacity Allocation Mechanisms do already require the respective
network code to define standard communication procedures, based on coordinated information
systems and compatible electronic on-line communications.
Covering all areas where tansmission system operators exchange data between each other or with
network users or operators of adjacent systems, the network code on interoperability rules shall
foresee a common, best available technology, standardised messaging protocol and the respective
technical standards for the reliable, secure and smooth exchange of information between TSOs as
well as between TSOs and relevant counterparties.
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7.
Capacity Calculation
Capacity calculation has become a dynamic process. The introduction of bigger entry-exit zones with
a mixture of long and short term gas trading markets creates less predictability of flow patterns. Daily
forecasts for entry and exit flows have to be taken into account and information on potential
congestion and constraints within the system, but also from adjacent systems are to be taken into
consideration.
Article 16 of the Gas Regulation obliges TSOs to offer maximum capacity. This calls for:
a) the calculation of technical capacity through transparent methodologies, identifying all
capacity that can be physically used as well as
b) the forecast of system use for the purposes of identifying technical constraints, where
TSOs may also consider market trends, historical flow data and data on results of allocation
processes.
The network code on interoperability rules shall consequently define a transparent and consistent
process for the calculation of technical capacity in order to identify all capacity that can be physically
used.
The procedures for capacity calculation to be defined by the network code and to be applied by
TSOs shall fulfil at least the following requirements:
7.1. Technical Capacity Calculations
The network code shall oblige TSOs to include parameters and assumptions in the network
scenarios aiming at optimizing the technical capacity of the network.
Parameters and assumptions in the network scenarios must match the particularities of the
transportation services offered to and information published for the market in order to guarantee
that for each transportation service the right level of technical capacity is calculated. When it
comes down to the offer of interruptable capacity, the risk of interruption should be based on
network scenarios giving equal statistical percentage of interruption. .
Parameters and assumptions for which legislation, regulation or commitments exist are set equal
(or comply) to these values (or requirements) and may not have more or less critical values for
the calculation of firm capacity. For other parameters and assumptions, the values are set by the
TSO in order to (a) comply with the requirements of firm capacity, (b) guarantee consistency
over time and (c) guarantee at least compatibility with the adjacent TSOs.
Adjacent TSOs must aim for convergence of network scenarios for the calculation of technical
and available capacities in order to match capacity levels on both sides of interconnection point.
The TSOs must explain any difference in available capacities.
7.2. Calculation of Available Capacity
The Network Code shall define rules to oblige TSOs to guarantee consistency between technical
capacity calculation and the calculation of available capacity
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The calculation of available capacity shall be derived from technical capacity calculation and
shall depend – according to the time horizon – on the following values:
o
o
o
o
nominated capacity;
booked capacity;
operational margin;
new/planned capacity
The network code shall oblige TSOs to calculate the available capacity for each interconnection
and for different capacity products/services) and for different time horizons (short,medium and
long term).
7.3. Updating of Available Capacity Calculations
The Network Code shall define rules that TSOs update their calculation of available and
technical capacity in order to inform the market correctly.
Recalculation of Technical Capacity means new simulations based on refreshed inputs (usually
based on updated forecasts, market surveys, open seasons, investment plans, etc.) Technical
Capacity calculations must be regularly updated, at least on a quarterly basis or as soon as a
divergence is observed between the forecast market developments and the effective
developments. The offered capacity is binding to the TSO meaning that any request equal or
lower the published availability must be guaranteed.
The Network Code shall set out rules for TSOs to coordinate the timing for updating and reevaluation of the calculation of the Technical Capacity values based on a network simulation of
the network capability according to the new information gathered.
7.4. Consistency of Available Capacity Calculations
The Network Code must guarantee consistency and compatibility of the AC calculations with
adjacent TSOs over time. The compatibility requirement means that any differences may not
hinder market access and the development of competition.
In order to meet transparency requirements, TSOs must coordinate a coherent way to present
capacity calculations and levels in order to make information accessible and comparable across
networks for network users.
8.
General provisions
ENTSOG shall involve where appropriate DSOs and relevant stakeholders eg. shippers end users,
Producers, SSOs, LNG Operators in the drafting of the relevant sections of the network code on
interoperability rules.
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9.
Cross-border cooperation
The network code shall require ENTSOG to regularly review
interoperability within its area of application. The review will
additional measures needed to harmonise rules, which may
integrated internal EU market for gas. This is an additional
monitoring.
the progress of harmonisation of
also consider whether there are
facilitate the development of an
requirement to ACER`s role on
10. Compliance
The network code on interoperability rules shall require ENTSOG to regularly review the
progress towards its implementation and report every 12 months, to begin after the entry into
force of the network code, to ACER if harmonisation is not yet achieved. The report shall identify
for each issue the progress made, the hurdles identified and the likelyhood that full compliance
of the interoperability rules shall be obtained at the latest within three years of the entry into
force of the network code. ENTSOG shall publicly consult on these reports before their
submission to ACER. ACER will monitor these reports according to Article 9(1) of the Gas
Regulation. The competent NRA, taking full account of ACER’s opinion, may require the relevant
TSO to take action to improve implementation. ACER may request the concerned NRA to
amend its decision.
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