Network Code Interoperability and Data Exchange Rules

Network Code Interoperability and Data Exchange Rules

Consultation Workshop

Brussels – 20 Mar 2013


WELCOME….




Panagiotis PanousosBusiness Area Manager, System Operation



Introduction

> Welcome!!!

> Participants through webcasting to identify themselves

> Objective: support stakeholders to develop their consultation response

> How will this be achieved:

by understanding explanatory presentations

by listening to other involved parties’ views

by participating in discussion

4

Half way to network code delivery

> It’s been quite intensive…project plan, kick-off, launch documentation, stakeholder joint working

sessions, prime mover meetings, bilateral / trilateral

meetings, internal consultation, business rules

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> Draft NC + Supporting Document

The challenge

> Consultations / discussions

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> Internal processes

> …but we have to prove we are a “fair partner to all”

Our hope?Manage to reach a common agreement within the one year!

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Structure of event

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> Our view:What is in the NCHow legal text can be

interpreted

> Regulator’s view: Is the NC in line with

the FG?

> Stakeholders’ view:Does NC meet

expectations?

> Commission comments

Thank You for Your Attention

ENTSOG -- European Network of Transmission System Operators for GasAvenue de Cortenbergh 100, B-1000 Brussels

EML:WWW: www.entsog.eu

Panagiotis PanousosBusiness Area Manager, System Operation

[email protected]


Interoperability Team


Brussels – 20 March 2013

11

NC development process: actual state

Invitation letter EC

11/9

Publication project plan

13/9 2/10

MF presentation NC INT

26/9

Kick-off WS

11/10

End consultation project plan:

37 responses with general support

09/10

Publication Launch Documentation

07/1120/1105/1224/0112/03

Prime Mover meetings

14/1128/1111/12

SJWS

Trilateral meetings EC/ACER

30/1029/1114/1224/0111/02

Stakeholder involvementPrime Mover: 5 (OGP, EFET, GIE, CEDEC)

Active SJWS participant: 19Consultation Respondent: 8 + Observers: 5)

Dec‘12-Feb‘13

Development of draft NC

28/02/13

Public Consultation

DRAFT NETWORK CODE>Developed by INT team in close cooperation with INT KG/WG and legal advisers taking into account:

External Stakeholders: SJWS/Prime Movers/Bilateral meetings EC + ACER ENTSOG Members: internal consultation Input WG CAP + WG BAL: compatibility with other NCs

SUPPORTING DOCUMENT>Policy options + clarification chosen options>Questions for Public Consultation (32); DEADLINE: 26 April>On-line response form with 3 possibilities:

YES

YES with minor comments

NO

NC Development Process: actual state

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Sep 2012

Jan

Jul

Jun

May

Apr

Mar

Feb

Nov

Oct

Aug

Sep 2013

Dec

Stakeholder engagementENTSOG Member workConsultation (1 Month)

Kick-Off WS: 26 SepProject planning and launchKick-Off

NC Development Process: next steps

WorkshopConsultation (2 Months)

Consultation WS: 20 MarThird Countries WS 16 AprData Exchange WS: 23 Apr

SJWS 1: 14 NovSJWS 2: 28 NovSJWS 3: 11 Dec

Conclusion WS: 28 May

Network Code finalisation

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Workshop

NC Interoperability and Data Exchange: Content

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NC Interoperability and Data Exchange: Content

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I/VIII

II

III

IV

VII

VI

V

NC Interoperability and Data Exchange

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I/VIII

II

III

IV

VII

VI

V

Other issues to be bilaterally agreed in IA

NC focuses on 7 mandatory terms in line with the FGAmendments to the interconnection agreement

Flow control

Measurement principles for gas quantities and quality

Matching

Allocation of gas quantities

Exceptional events

Settlement of disputes

Changes to 3 of the 7 mandatory terms can have a direct impact on Network Users

NUs have to be informed about and before any changeNUs will be invited to comment on the possible consequences the change may have on

their activitiesTimeframe of 1 to 3 months unless otherwise specified in national rules

New IAs or any amendments changing any of the 7 mandatory terms shall be communicated to NRAs

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Article 4: General Provisions

12 month period from entering into force of this NC

Within 12 months after the Network Code enters force, TSOs shall have: In force IAs in compliance with the provisions of the NC at each IP This is also valid for IPs starting commercial operation for the first time Reviewed their existing IAs and shall amend where necessary to be NC compliant

When TSOs can’t reach an agreement about the mandatory terms TSOs shall

Apply the default rules as described in this NC Inform its NRA

When TSOs can’t reach an agreement about items other than the mandatory terms TSOs shall have settled the dispute as soon as reasonably practicable

With the support of NRAs Or any other dispute resolution mechanisms under this NC

Article 5: Development of new and alignment of existing interconnection agreements

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IAs shall specify a transparent and detailed amendment process Obligation to amend an IA can have different reasons

Applicable legislative or regulatory frameworkIf either party to the IA requests by means of a written notice

Timing for the amendmentDeadlines imposed by applicable legislative or regulatory framework orDeadlines agreed upon among the involved TSOs

If TSOs don’t agree on the amendment of the relevant provisions or the timeline of the amendment process

The dispute shall be settled in accordance with the provisions of the dispute resolution part of the IA

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Article 6: Amendment to interconnection agreements

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IA shall address the following matters:Rules to facilitate a controllable, accurate, predictable and efficient flow across the IPProvisions for TSOs how to steer the flow and obligations to use their reasonable

endeavours to minimize the deviations from the agreed flow Determination of the TSO who is responsible for the installation, operation and

maintenance of the flow control equipment

To agree on the direction and quantity of gas flow for the IP for each hour of the gas day taking into account

The results of the matching processOBA correctionsFlow control arrangements

In addition TSOs may alter the flow when it is required under certain circumstances like

To comply with requirements laid down in safety legislationTo comply with requirements laid down in Emergency Plans or Action Plans in

accordance with EU regulation No. 994/2010An exceptional eventAny other reason specified under national rule

Article 7: Rules for flow control

Risk for NUs

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TSO in charge of the flow control equipment shall in cooperation with the other TSOs be responsible for steering the gas flow across the IP at a level of

Accuracy sufficient to minimize the steering differenceStability in line with the efficient use of the gas transmission networkPressure that complies with contractual obligations

Best practice Flow control actions taken at an IP are done only on an operational basis

meaning that network users’ confirmed quantities are not affected as long as an operational balancing account is in place and any flow alteration action as described under paragraph 2, (c) of this Article doesn’t have to be applied.

Where no operational balancing account is in place network users’ confirmed quantities will be affected only to the minimum extent possible.

Article 7: Rules for flow control

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The IA shall as a minimum specify the following matters Details of all measurement responsibilitiesDetails of the applicable standards Determination of the TSO who is in charge of the installation, operation and

maintenance of the measurement equipmentObligation for the aforementioned TSO to provide all necessary information and data of

the measured gas quantity and quality to the other partyWithin the timeframe as specified in the IA At a frequency as specified in the IA

The installation, operation and maintenance of the measurement equipment at an IP shall take into account both relevant national requirements of the involved TSOs

TSOs shall use their reasonable endeavours to reach an agreement about thisIf no agreement can be reached then the provisions of the overarching dispute

resolution of the NC shall apply

Article 8: Measurement principles for gas quantity and quality

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Default ruleWhere the contracting parties do not agree on a standard for the measurement of volume and energy, the latest version of European standard EN1776 Functional Requirements for Gas Measuring Systems shall apply.

Article 8: Measurement principles for gas quantity and quality

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General ProvisionsAll TSOs whose systems are connected at an IP shall implement a Matching Process

The Matching Process shall describe Communication and processing of the relevant data among the TSOs Roles (Initiating/Matching TSO)TimingData formatsCalculation of the Processed Quantities and Confirmed Quantities of Network Users Matching Rules

Default rule is the Lesser Rule

Article 9: Matching

Examples: Results of Lesser Rule Processe

d Quantity

A

Processed Quantity B

Confirmed Quantity

100 100 100

-100 -120 -100

100 80 80

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Article 9: Matching

Initiating TSO

Matching TSO

Initiating TSO

Matching TSO

Monitoring

Steering

Confirmation

Confirmation

Calculation

ConfirmedQuantity

Nomination / Renomination Cycle (2 hours)

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The allocation rules have to be consistent at both sides of the IP

IA shall define the OBA as the applicable allocation rule, however

For existing IAs TSOs may agree to maintain the existing allocation rules and inform their NUs thereof

For new IAs TSOs may agree on another allocation rule. In that case and if a network user of either of the TSOs requests the allocation rule should be the OBA then the TSOs have to conduct a public consultation

Default ruleIA shall define the OBA as the

applicable allocation rule

Article 10: Rules for the allocation of gas quantities

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Article 11: Exceptional events

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Article 11: Exceptional events

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In line with the FG require a twofold approach to the issue of dispute resolution in the NC is needed:

an overarching procedure for disputes arising between TSOs page 7 of the FG

in case an IA is not yet in force; In relation to the implementation of any provisions set forth in any NC’s sections (units, gas quality, odourisation etc.) other than in the IAs.

a procedure regarding the disputes arising out of or in connection to IAs between TSOs page 8 of the FG

including, but not limited to, the existence, validity, content, amendment or termination of the IA

The overarching principle is ipso iure (automatically) applicable.The IAs’ dispute resolution procedure must be foreseen by each IA as one of its mandatory terms.

FG: Dispute resolution (Articles 12 and 28)

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As a minimum, the IA shall specify how to settle any dispute that can’t be amicably settled by the TSOsEither define the court of jurisdictionAnd / Or describe terms and conditions for the appointment of experts

The applicable conflict-of-Iaw rules shall apply in caseThe jurisdiction deemed to be not competentAny of the involved TSOs doesn’t comply with the obligation in connection with the

appointment of experts

Default ruleShould the TSOs not agree on a jurisdiction clause to finally settle the dispute

the applicable conflict-of-law rules shall apply

Article 12: Settlement of disputes arising from Interconnection Agreements

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In this respect, in line with the FG:

TSOs shall endeavour to settle the dispute; TSOs shall resort to any available dispute settlement mechanism(s) in place

in their respective Member State pursuant to Article 41(11) of the Directive (EC) 2009/73;

in case a common final decision cannot be reached, ACER shall take appropriate measures pursuant to Article 8 of the Regulation (EC) 713/2009.

Article 28: Overarching dispute resolution procedure


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I/VIII

II

III

IV

VII

VI

V

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Article 13: General provisions

Each TSO shall use the common set of units as defined in the NC for the communication related to the information exchange described in the network codes developed so far with other TSOs or with other counterparties or in respect of the publication of data on a common platform

The above mentioned provisions are without prejudice to existing EU regulations covering harmonisation of units for other parameters

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Article 14: Common set of units

Parameter Unit

For pressure, it should be indicated whether it refers to absolute (bar(a)) or gauge (bar(g)).

The reference conditions for volume shall be 0°C and 1.01325 bar(a).For GCV, Energy and Wobbe-index the combustion reference temperature shall be 25°C.

35

In addition to the units as described in article 13 and 14 other units or reference conditions for the exchange of data between TSOs and TSOs and between TSOs and NUs are allowed when the involved parties agree on it

Conversion factors consistent with the procedures described in the latest version of ISO 13443 shall be provided where required

Article 15: Additional units


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I/VIII

II

III

IV

VII

VI

V

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Application area:

> Cross border IPs> Where the physical flow occurs> Where the barrier has been identified (based on the real and/or historical

flows and/or expected future flows (outlook))

Gas Quality – Managing Gas Quality DifferencesArt. 17

Article 17 requires to manage the real identified problems that create a barrier to the cross border flow

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Adjacent TSOs shall within 12 months…> … agree whether or not there is a barrier persisting on IPs> … inform relevant NRAs that barrier has been identified> … develop technically feasible and financially reasonable options> … jointly carry out CBA> … conduct a public consultation> … submit recommended solution to NRAs for approval.

> TSOs shall review the situation with the frequency not less than once per year

The dispute resolution procedure in Art 28 applies if TSOs fail to reach an agreement on whether the barrier exists and/or how it should be overcome.


12 month period from entering into force of this regulation

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Issues beyond the scope:

> Responsibilities (who is responsible for gas quality) – national responsibility

> Defining gas quality parameters and their acceptable ranges – defined in national rules/further recommendations for harmonised gas quality standards are elaborated by CEN (Mandates by EC)


40

> Provide real time gas quality data > Wobbe-index & gross calorific value publication> Frequency – at least once per hour> Data measured at physical IPs> No warranty given by TSO for any consequential loss or damage related to the

use of the information by any third party

Short term monitoring – data publicationArt. 18

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Criteria for parties being eligible to potentially receive gas quality information:>Any end consumer directly connected to the TSOs network, whose operation may be affected>OR any network user that has a contract in force with a relevant end consumer (in regimes that prevent direct contracting TSOs to end consumer) >Any DSO directly connected to the TSOs network>Any SSO directly connected to the TSOs network, whose operation may be affected

Short term monitoring on gas quality variation information exchange – Art. 19

Eligible parties to potentially receive gas quality variation information shall be specified at national level

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TSOs obligations:>Define and maintain a list of eligible parties>For identified end consumers TSOs shall assess:

The nature of indicative information Frequency of an update Lead-time How the information may be exchanged

TSOs shall use their reasonable endeavours using existing equipment to provide such information

>No warranty given by TSO for any consequential loss or damage related to the use of the information by any third party

Short term monitoring on gas quality variation information exchange – Art. 19

12 month period from entering into force of this regulation

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Scope of the outlook:>To be produced every 2 years>At least Wobbe-index – detailed parameters can be defined after stakeholders’ consultation (TYNDP)>New supply sources including indigenous and non-conventional gases production>For each relevant parameter and every region result in a range within which the parameter is likely to evolve>The outlook shall be consistent and in line with TYNDP regarding:

Preparation and timing Selection of the most relevant cases focusing on the year plus 5 and 10 Consultation process with stakeholders

Long term monitoring – Art. 20


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I/VIII

II

III

IV

VII

VI

V

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1st phase 6 months period:>TSOs shall:

Identify differences in practices that might create a barrier Inform their NRAs if the barrier has been identified Actively cooperate to identify and assess the consequences related to:

o Potential flow of odourised gas into non-odourised network

o Possible acceptable level of odourant

o Conversion towards non-odourised gas

Submit the agreement, including cost recovery mechanism, for approval to relevant NRAs, with the involvement of the relevant authorities where required.

Odourisation – Art. 21

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2nd phase If no agreement can be reached between the TSOs or if the agreement is not acceptable to the relevant NRAs, then during 12 months period:

>TSOs shall in cooperation with relevant authorities:

Develop options to remove barrier Define most cost effective option to deliver physical flows of non-odourised

gas after producing cost estimates Implementation time Define final solution including cost recovery mechanism

Odourisation – Art. 21


COFFEE BREAK ….




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I/VIII

II

III

IV

VII

VI

V

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Introduction

Components for Data Exchange (HOW): Data Network Data Exchange Protocol Data Format

Types of Data Exchanges - toolbox: Document based (3 technical alternatives) Integrated (web services – one technology) Interactive (web browser – one technology)

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INTRODUCTION: WHAT & HOWIntroduction

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Data Exchange - Art 22>Art 22: General provisions

What: Regulation 715/2009

Who: TSOs , TSOs – CP

Network: Internet

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1.Data Content Format Edig@s-XML: Use of Edig@s-XML is subject to legal assessment2.Initial proposed solutions based on a technical evaluation. Final solutions will be based on a detailed Cost-Benefit analysis

Data Exchange- proposed solutions – Art 23

Toolbox Network Structure Format

Content Format B2B Standard

Communication Protocol

Document based Data Exchange Internet XML Edig@s AS4 HTTP(S)

Integrated DE Internet XML Edig@s SOAP HTTP(S)

Interactive DE Internet none tbd HTTP(S)

Data Content Format Data Exchange Protocol

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Data ExchangeInitial assessment:Synergies: Protocol

EFET: protocol ebMS.v2 for trading activities ENTSO-E: MADES/ECP web service based solution for

communications with e-TSOs. Not supported by all TSOsNo technical compatibility between the existing

solutionsSynergies: Data format

XML generally usedCommon data content formats for electricity and gas

will: - increase maintenance cost for unnecessary updates- increased risk for failures due to changes

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Data Exchange

Actual protocols FTP AS2 SMTP sFTP Web service (http(s)) SOAP E-mail

Actual data formats

Edigas XML Edigas – edifact Excel (KISS-A) Pdf Proprietary formats Csv files

Initial assessment- actual spread

Many protocols and formats in use No compatibility between these solutions

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Data ExchangeInitial assessment

Volume of data traffic Evaluate existing data exchanges (not subjected to any

regulation) Estimate number of messages (/hour,/day) 180.. 26100/dScalability

Estimate size of messages (define limitations of the evaluated solutions)

Performance criteria and transmission delay Technical requirements

Security requirements (encryption, signing) Commercial requirement (acknowledgement, non

repudiation, potential new functionalities …)

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Avoid discrimination of small shippers and new market entrants:

Keep existing solutions in place as long as compliant with the business requirements

Services offered by service providers avoid big IT developments

Interactive data exchange solutions (depending on the application) will allow easy access from a PC via a browser

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Data Exchange

Actual protocols FTP AS2 SMTP sFTP Web service (http(s)) SOAP E-mail

Actual data formats

Edigas XML Edigas – edifact Excel (KISS-A) Pdf Proprietary formats Csv files

Initial assessment- actual spread

Existing Protocols and Data Formats taken into consideration for the evaluation for a Data Exchange solution

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Evaluated protocols (together with external expert) AS2 ebMS AS4

Technical evaluation AS4 best score; offers more options for the future:

Rich Meta Data in msg header (e.g. service, action) Reception awareness Duplication detection Pull functionality

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Data ExchangeInitial assessmentCost evaluation (to be confirmed by a detailed CBA)

Implementation cost expected to be equal Maintenance cost expected to be similar Expected life cycle – AS4 expected to last longer (most recent

technology)

Risk evaluation: AS2: lower implementation risk, proven technology ebMS: technology well known but many option possible AS4 (based on ebMS)ohigher risk since no experience by TSOs;

Data Exchange

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Cost Compliant with FG Conclusion remark

1keep existing

formats no cost

no harmonization; incompatible solutions in

EU--> not compliant

not compliant with FG

2implement all

existing formats

high cost for all parties to maintain all data

formats

Barriers removed for interoperability

No common set of data formats

--> Not compliant

not cost efficient

3

Harmonisation : develop Business Requirements Specifications and common data formats

Minimal cost: All parties implement the same business model and data formats full compliant

best solution for a minimum cost

Central governance of data formats required:ENTSOG-EASEE-gas cooperation on the EDIGAS-XML data format

1

keep existing situation: different

(incompatible) protocols in use

no costLimited communication possible between TSOs

and CPnot compliant with FG

2implement all

existing protocols

high cost for all parties to maintain all

protocols

Partial interoperability:no common agreement -->No harmonization

not compliant with FG

3 one protocolcost for all parties to

implement the protocolFull interoperability

Not realistic seen the high number of local

communications in some member states.Only a limited number of them

need to communicate with other TSOs.

4common protocol: co-existence with existing (local) protocols

All TSOs and, only CP that do not support the existing (local) protocols, need to implement the "common" protocol. Full interoperability

Most cost efficient seen the limited number of implementations--> best solution for a minimum overal limplementation cost

It is expected that the common solution will replace over time all existing solutions

Options

Data format

Comm. Protocol

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Data Exchange

Detailed Cost-Benefit Assessment studyDetailed study by ENTSOG with support of an external consultant

Focus on cost / benefit for the different technical options Take the technical evaluation as a starting point

Schedule: 20-30/3/2013: Send questionnaire and collect information 23/4/2013: Workshop to exchange views and collect

opinions (present first results of the survey) 28/5/2013: Presentation CBA results (during conclusion

workshop NC)

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Data Exchange

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Data Exchange

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Data Exchange

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Data Exchange – Art 24Art 24: Security and Availability

> Security: Each party is responsible for its own infrastructure Each party is responsible for the confidentiality of the

information Each party shall inform other parties that might be

compromised in case of any IT problem

> Availability: TSOs shall take appropriate measures to avoid single points of failure in their data exchange systems obtain appropriate services from the internet service

provider(s) minimize downtime (planned and unplanned) and inform

their counterparties in case of planned unavailability

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Data Exchange – Art 25Art 25: Implementation

Common solution parallel to the existing solutions

TSOs implement the common DE solution within 12 month when NC comes into force.

Parties who cannot communicate with TSOs with their existing DE protocol shall also use the common DE solution

Existing solutions can stay in place as long as they are compliant with the data exchange requirements for the corresponding business processes

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Data Exchange – Art 26

> Art 26: Technology evolution

>Changes to the common solution may be necessary in the future due to:

New business requirements New technology requirements Obsolescence of existing technology …

ENTSOG will be responsible to take appropriate initiatives to meet the requirements for data exchange as defined in the regulationsIf required an amendment will be submitted to ACER

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Data Exchange – Art 27

>Art 27: Development process

>Data exchange requirements under regulation 715/2009 shall : be controlled and developed by ENTSOG be based on Business Requirements Specification (BRS) be published by ENTSOG

>CNOT : ENTSOG shall adopt Common Network Operation Tools For Data Exchange: all information for the implementation of

the network code




Interoperability Team

[email protected]


Questions and Answers ….



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TITRE

Network Code on Interoperability & Data Exchange – ACER’s preliminary comments

Geert Van Hauwermeiren, ACER Task Force Chair

ENTSOG Interoperability & Data Exchange WorkshopBrussels, 20 March 2013

ENTSOG Workshop - Brussels, 20 March 2013

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FG/NC Interoperability & Data Exchange

Process within the AgencyUltimately, after 11 September 2013, ACER must provide:•A reasoned opinion to ENTSOG, within 3 months (Art 6(7) of the Gas Regulation);•A recommendation for adoption to EC, once the Agency is satisfied that the network code is in line with the Framework Guideline (Art 6(9) of the Gas Regulation).

At this early stage, ACER provides preliminary views to facilitate the process.


Preliminary views on the Network Code•Constructive dialog with ACER;•The text show high quality despite the variety of technical topics covered;•Ambitious solutions concerning:

• Interconnection Agreement Transparency provisions (Art. 4)

• Operational Balancing Accounts (Art. 10);• Units (Art. 15);• Data Exchange (Art. 27);

FG/NC Interoperability & Data ExchangePreliminary views on the Network Code (1/6)

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Interconnection Agreements•FG states that “The Network Code shall provide for default rules on each of the above topics, to be directly applicable in the event the TSOs fail to reach a mutually acceptable agreement on any of these, within a period of 12 months”;•The default rules are not clearly defined in NC. It is not easy to see what a default Interconnection Agreement would look like;•In particular, the issues of flow control (Art. 7), gas quality and quantity measurement (Art. 8) include no or incomplete default rules, and …;… where defined, in spite of Art. 1(2), default rules are to be assessed against existing regulation (CMP, CAM, balancing, …);

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Gas Quality (1/2)•Where the FG states obligations, the NC refers to “reasonable endeavours”; •ENTSOG should clarify that this wording does not prevent the level of harmonisation aimed at within the FG to be achieved by the Network code.

Question to stakeholders : •the FG states in its Art. 4 that the NC shall apply "where necessary", and on short-term monitoring, benefit to "relevant network users".•NC defines "where necessary" in Art. 17 and "relevant Network Users" in Art. 19.1. •In addition, in Art. 18(1) Wobbe index and GCV, and in Art. 20(3) Wobbe index, are set as the minimum to be covered respectively by the short-term and the long term monitoring outlook.

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Gas Quality (2/2)•Possible misalignment on Short Term monitoring (Art.19):

• While based on the FG, the NC should define situations when ST monitoring is relevant, as well as the nature and frequency of the information, the current NC states that this definition shall take place at Member State level;

• The justification for the proportionality of the approach is based on a single example, that does not provide sufficient explanation.

The Agency believes that an active cooperation of stakeholders during the on-going public consultation is needed. ENTSOG should encourage stakeholders to provide feedback on this particular issue.


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Data Exchange•the FG states in Art. 6 that "The NC shall foresee a common set of data formats, data network and data protocol" and "The selection of such a data exchange solution […] shall be based on a cost-benefit analysis subject to public consultation“;•At this stage, footnotes 3,4,5 on page 28 of the NC leave the issue open. They highlight that the data exchange solution is set within the NC, while the cost-benefit analysis and legal assessment have not been conducted at this stage. The final NC should be developed in line with the FG;•Feedback is expected from stakeholders on the scope of application of the data exchange provisions.

The Public Consultation should provide further feedback on these issues.

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Review of the misalignments•Interconnection Agreement’s default rules not clear;•Data Exchange – the cost-benefit analysis has to be concluded before the final preferred data exchange protocol is defined in the NC;•Data Exchange – the legal analysis has to be concluded before the final preferred data format is defined;•Gas Quality Short-term monitoring – the NC should include an obligation rather than a “best endeavour” approach.

The Agency has concerns over the current approach on these topics and will be considering stakeholders’ feedback to assess the extent to which the NC should be amended in order to reflect better the

requirements of the FG.

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FG/NC Interoperability & Data Exchange

Preliminary conclusions:•There is a good level of compliance overall;

•There are few remaining concerns:• Gas Quality Short-term monitoring (Art.29);• Interconnection Agreements (Art.7);• Data Exchange (Art. 23).

Beyond these preliminary views, the Agency will continue the scrutiny of the NC in the light of stakeholders comments in the public consultation.

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LUNCH TIME ….




Stakeholders’ views



InteroperabilityInteroperability

GIE presentation for ENTSOG WS 20 March 2013

GIE remarks on draft NC (I)

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GIE remarks on draft NC (II)

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… but more efforts are needed•The processes described by ENTSOG are sufficient in terms of stakeholder involvement and public consultations...

•...but

• The Network Code should describe in more details how to proceed on member states level when it comes to a potentially different time schedule

• This could inter alia include stakeholder envolvement, mediation or a set of criteria

• The FG has widen the scope, as a consequence the vital interests of „counterparties“ need attention on member states level too

Prime Mover initial viewson Draft Network Code

Interoperability and Data exchange

ENTSOG WorkshopBrussels, 20 March 2013

Kees Bouwens, ExxonMobil

More about OGP: Our membership spans the globe and accounts for more than half of the world’s oil output and about one third of global gas production. From our London office, we foster cooperation in the area of health, safety and the environment, operations and engineering, and represent the industry before international organisations, such as the UN, IMO and the World Bank, as well as regional seas conventions, such as OSPAR, where we have observer status. OGP Europe in Brussels represents before the EU OGP members who are active in Europe.

Prime Mover initial views

• Disclaimer These are initial views and do not represent the endorsed

position of OGP or any of its members These views have been discussed among the prime movers

but do not represent a common view

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Benefits of this Network Code

• Interoperability and Data exchange facilitate efficient operation of interconnected networks: Harmonisation of operational matters at IPs Promote OBA as default allocation rule Use of common set of units Managing gas quality differences at IPs Short-term monitoring of gas quality Provide common data exchange solutions

• CAM and Balancing define new business processes. Interoperability and Data exchange build the seamless interfaces between TSOs to make this a success.

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Interconnection Agreements

• This Network Code only deals with TSO to TSO IAs Agreements between adjacent TSOs related to IPs Network users may be affected by IAs (matching, flow

control and allocation) and this will be made transparent Aim is to reduce barriers for network users

• The Network Code does not establish a template for connection agreements between TSOs and non-TSOs Connections to producers, LNG operators, SSOs, DSOs and

end-consumers are not in scope Such agreements are governed by relevant national rules

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Flow control (Art. 7 NC)

• Aim is to minimize impact on users’ confirmed quantities Impact can be further reduced by using OBAs

• Provision 7.2(c) allows TSOs to adjust flow for reasons of Force Majeure Reflects that transport of gas is a physical service Different from buying and selling gas at adjacent hubs

• Network Code assigns this risk to network users Users trading between hubs should take into account that

TSOs may adjust gas flow in the event of Force Majeure

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Allocation rules (Art. 10 NC)

• Network Code defines OBA as default allocation rule TSOs may agree to implement a different allocation rule, in

which case network users may request consultation

• Art. 10.3 allows TSOs to maintain the existing allocation rule This is not consistent with the objective to harmonise rules Deviations from the general rule should be justified

• Suggestions to amend Art. 10.3: Where existing IAs have allocation rules other than OBA,

TSOs shall: consult with relevant stakeholders, and publish the results; submit the allocation rule to their NRA for approval

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Gas quality

• Scope of this Network Code is limited

• National rules (should) specify: Network users’ responsibility to meet gas quality specs at

system entry points TSOs’ responsibility to manage gas quality in the system,

and in particular gas quality at exit points to consumers

• Network Code provides rules on short term monitoring Art. 18 and 19 specify that TSOs provide information on

indicative basis only, without warranty for loss or damage This does not release TSOs of responsibility towards

consumers based on national rules

92

Data exchange

• This Network Code provides ‘common solutions’ For TSO to TSO data exchange To be implemented by TSOs within 12 months Available for network users that wish to use it

• The Network Code does not mandate a single system for data exchange between TSOs and non-TSOs Existing data exchange systems are maintained Decisions to replace existing systems are governed by

relevant national rules Avoid major costs when existing solutions can handle

93

Implementation (Art. 25 NC)

• Suggestions to amend Art. 25: TSOs shall make the common data exchange solutions

available to TSOs and counter parties within 12 months TSOs shall implement the necessary data formats according

to the schedules of the different network codes Existing data exchange solutions between TSOs and counter

parties shall only be replaced by the common solutions after: the TSO has produced a cost benefit analysis of the

potential change and consulted all counter parties; the NRA has approved the change under relevant

national rules

94

Network Code Interoperability &

Data Exchange Rules

Consultation Workshop ENTSOG

Brussels, 20 March 2013Bart Cornelis

Overview

Scope

Purpose

NC Interoperability & Data Exchange Rules

Conclusion

96

Scope

Established in 2002

Aim is to develop and promote the simplification and streamlining of both the physical transfer and the trading of gas across Europe.

Creation of EASEE-gas fully supported by the European Commission and Madrid Forum.

Establishment achieved through the work of a dedicated Task Force supported by EFET, Eurogas, Eurelectric, GEODE, GTE, OGP and the Edigas group.

6 Market segments are represented:

The association is fundamentally based on companymembership and voluntary contribution towards thedevelopment of common business practices.

97

Purpose

To develop and promote common business practices (CBPs) to simplify and streamline business processes between the stakeholders that will lead to an efficient and effective European gas market.

Continue a good working relationship with ENTSOG (e.g. contribution to discussions on different network codes)

Investigate new Network Codes and discuss them among our members active in the different market segments, and provide a structured feedback to ENTSOG.

98

NC Interoperability & Data Exchange Rules

P.13-14, Article 9, point 3 (b). It’s not clear how this matching process should work in case of both bundled and unbundled capacity product nominations at the same time.Bundled and Unbundled quantities should be nominated separately or together?

Shippers don’t ask for extra complexity with respect to nomination & matching processes. For each extra complexity added, the added value should be sufficiently

clear. A shipper bringing gas into a TSO in the north of Europe might only be interested to bring it to

the south, and is probably not interested in too many complexities along the way.

Clear requirements / guidelines about nominations are missing. EASEE-gas thinks that this should be included in this NC (even though it’s described in the Balancing NC, we advise to include it in this NC)

P.16, Article 10, point 5 (f): What is the alternative for the OBA in case of exceeding of the OBA limits? Pro rata rule? Same question for borders on which there’s not yet an OBA in place.

P.16, Article 11, point 1: What is an “exceptional event”? Definition, examples?

P.28: EDIG@S: EASEE-gas prefers to keep Edig@s as data format in the NC, and is ready to cooperate with ENTSOG with the aim to clarify the legal issue.

99

Conclusion

In general, EASEE-gas members are positive about this NC, even if some points still deserve extra attention.

A transparent and straight forward nomination & matching process is key to promote and stimulate market access for the shippers.

EASEE-gas is pleased to see that different CBPs are used by ENTSOG for the development of the Network Codes in general.

100

Business Rules for Odourisation Chapter V

21 avril 2023GrDF - Direction Technique et Industrielle

102

Position of GrDF – DSO, major player in

Europe – to the questions of the

consultation

21 avril 2023GrDF - Direction Technique et Industrielle 102

103

Position of GrDF – DSO, major player in

Europe – to the questions of the

consultation

21 avril 2023GrDF - Direction Technique et Industrielle 103

104


Odorised gas is fully complying with existing gas quality specifications, in particular sulfur content (Easee gas CBP etc…)

The Network Code will be binding. We need to keep opened all opportunities offering cost effective, safe solutions, which do not hamper cross border flows.

All the proposals made during the SJWS that were not fully in agreement with the FG of ACER were rejected in the proposed redaction of the draft NC.

If ENTSOG publishes in the NC as the only rule the exchange of non odorised gas at IP,

it would become a mandatory rule,

and it could create a barrier for countries for which transporting non odorised gas would be a problem.

Arguments for our position (1/4)

104

105


Odorisation practices are linked to local context, and modyfying only the odorisation practices without changing the whole context would reduce the safety. Indeed, odorisation is linked to the policy of leak research along the network : in the case of a non-odorised transport network, the leak research should be more frequent, even along the distribution network.

and this might also have an impact on the regulation concerning the installation of gas equipments (for ex : a stop-flow system is mandatory in some countries)

Therefore, changing odorisation practices would have an impact on operating costs for operators all along the networks (not only at transmission level)


105

106


The concept of non odorised gas is very theoretical. Indeed, natural gas

might have an odor intrinsically because of the presence of mercaptans for example,

or it might have an odor because of the addition of an adoriferous material like THT for example

or it might have an odor both by naturally contained mercaptans and by added THT.

How could we define a non odorised gas : would it be a gas in which no addition of any odoriferous product has been done ? In this case, how would we consider a gas arriving at an IP with no added odorant but naturally containing a high level of mercaptans, and therefore, having a strong odor ?

Transmission of only non odorised gas at IP is not possible in the case of a network connected to underground storages that have once contained odorised gas. Indeed, in France for example, where odorisation is done with THT, there would be several mg/Nm3 of THT in the gas coming out from aquiferous storages during at least 15 years after stopping the current odorisation practices.


106

107


The fact that an agreement should be found within 6 months and only bilaterally between the 2 concerned TSOs appears to be something difficult.

We suggest that there should be a longer time allowed to look for an agreement before reaching the solution of non odorisation as possible option (12 months),

and during this period, discussion with other stakeholders could be usefull in order to define the most cost-effective solution (regulatory authorities, national member states …)


107

GEODE’s positionon

Network Code Interoperability and Data Exchange

Brussels, March 20th 2013

Johannes Nohl

Page 10950608-00

NC INT – Network‘s situation

Data Exchange of DSOs doesn‘t affect border crossings

DSO

DSOTSO

national b

order

Network Codes

National Regulation

109

FGs and NCs are based on Regulation (EC) No 715/2009

Art. 8 (6): The NCs …, taking into account, if appropriate, regional special characteristics…

Art. 8 (7): The NC shall be developed for cross-border-network issues… without prejudice to the Member States’ right to establish national network codes which do not affect cross-border trade.

Subject to European harmonization are only TSOs!

Position of DSOs (situated downstream of TSOs)

All DSOs are regional different, no cross-border-issues

Part of NCs anyway! E.g. NC Balancing unthinkable without DSO’s cooperation (Art. 43).

Demand of TSOs and network users for single DE solution?Page 11050608-00

NC INT – Legal framework

110

NCs need to reflect legal framework: wording has to exclude DSOs explicitly

- Draft NC INT: “counterparties of TSO”

- Data arising from Regulation (EC) No 715/2009 “and regulations to supplement it” Network Codes?

- DSO’s role in other NCs (Art. 43 NC Balancing)

Let national network codes live for now: clarify scope of NC INT and requirements of its application

Cross-border network issues, cross-border trade

Who are the “counterparties” – name it!

Consider future development today!

In case all subjects to a NC are in scope

Lead times: Will the market be ready?Page 11150608-00

NC INT – Required measures

111

ENTSOG has to consider interests of non-members

41 TSOs (+7) 2200+ DSOs, many of them independent

Harmonization of DSO’s is economically not reasonable

Availability of 2200+ IT service providers at one time

Convergence electricity / gas (synergy) is over

New IT will be part of network user tariffs

Existing IT and business rules at distribution level

Working solutions are already implemented

Supporting two systems

- Costs of ownership (maintenance etc.)

- Inefficient

Will Cost-Benefit-Analysis respect that?Page 11250608-00

NC INT – Design future-proof

112

NC INT can be a statuary framework: Regional differences can be addressed best by national regulatory bodies

Necessary NC INT amendments

IT services take time: Prolong implementation schedule

AS4 is nearly unknown to the market by now

Implement Change-Management with fixed terms / dates

Existing compatible solutions can co-exist until canceled by national regulatory bodies (not by TSO, Art. 25 (2) NC INT)

Consider Data Exchange not (only) as a topic for TSOs

Interests of all market partners need to be balanced

Include representatives of DSOs in all panels

Efficient functioning of whole gas market as targetPage 11350608-00

NC INT – Minimum conditions

113

Thank you for your attention!

GEODE

Avenue Marnix 28 1000 Brussels

Tel. +32 2 204 44 60Fax +32 2 204 44 69 www.geode-eu.org [email protected]

THANK YOU!

securing competitive energy for industry

Consultation Workshop forNC on Interoperability

IFIEC-CEFIC position on gas quality

20 March 2013 Brussels

Dirk Jan Meuzelaar


Art. 16-17; adjacent TSO’s have to manage gas differences…. but clarity about responsibility for gas quality is not included in the FG nor NC !

116

According to CEFIC/IFIEC responsibility should be part of the NC.

We cannot refuse the gasWe cannot choose our gas

We cannot send the gas back

Gas quality is still the orphan of the gas industry

IFIEC-CEFIC support that adjacent TSOs should take appropriate measures in case gas quality differences could lead to a trade barrier. TSO should manage quality differences that may persist in the future due to diversification of gas sources. However according to ENTSOG..•The manager (TSO) is not responsible •Responsibility is not an interoperability issue •The regulation can only place obligations on TSOs

End-users require clarification on this issue.

Gas Quality


DG ENER non-paper on gas quality “roadmap” (Madrid Forum, 22-23/03/12)One of the three main parallel processes is on information provision

“Development of binding European rules (in the context of a Network Code) on, in particular, real-time information provision by TSOs to industrial customers concerning expected gas quality fluctuations, allowing them to optimize equipment performance at the new gas parameters”.

Binding rules on information provisions for gas quality fluctuations (ENTSOG) •Fluctuations of gas qualities within the allowed bandwidth are likely to occur more frequently and more suddenly. The appliances of industrial users, such as turbine operators or the chemical industry, are often sensitive to such fluctuations in gas quality. However, this effect can be mitigated when information is available reasonably ahead of the occurrence of the change. The Framework Guideline on Interoperability and Data Exchange that is currently under development by the Agency for the Cooperation of Energy Regulators (ACER) should also consider to mandate European TSOs to inform industrial customers and power plant operators in real time about changes in gas quality in the system in order for them to take necessary steps to calibrate their equipment.

117

Having adequate near real time info available is an important safety issue!


• At physical IPs TSO shall publish data at least once per hour the near real time WI and GCV

• TSOs shall at National level cooperate with eligible parties to assess – The nature of the indicative information– Frequency of an update– Lead-time– How the information may be exchanged

118

Art. 18-19; Short term monitoring is on the right track, however information is provided on an indicative basis without any warranty

CEFIC/IFIEC support that the best (and cheapest) solution is on a case by case, customised basis. Moreover, variations of gas quality should be monitored on a regional level depending on the gas flows, however… •obligation for TSO’s that information should be user led is missing. •information provision is indicative without any warranty. •Information provision should be an obligation of (and be paid by) TSO’s as an ancillary services

Information provision is part of the solution and not part of the problem !


Art 20 Long term monitoring to be included in the TYNDP

• We welcome the obligation to include the long term gas quality monitoring in the TYNDPs.

• According to CEFIC/IFIEC outlook should be provided – on a regional level – applicable to the operational quality ranges – the expected volatility– changes of the composition of the gas

• Providing information for this outlook by upstream parties may not be voluntary or without obligation.

119

The outlook include ‘only’ scenario’s of the gas quality. Customers in most countries only rely on (expected) operational ranges. Risk and liability when gas quality exceed the operational (and not the legal) ranges are unclear


There are different ranges regarding the range of the Wobbe Index. This may lead to confusion and legal uncertainty.

Legal range (Network Codes NRAs)

(Dutch) Example Wobbe index MJ/m3 25º/0º

54 55,7

57?

Max band Gas Turbine51.5

49- 5% + 5%

Current

Operational

Range -2.5% + 2.5%

Contractual range)

120


Operational ranges in most countries much smaller than legal ranges

121

EASEEGAS range(> 16% range)

WI MJ/m3 (15º/15º)46,45 – 54 MJ/m3

WI MJ/m3 (25º/0º)49 – 57 MJ/m313.6 – 15.81 kWh/m3

• TSO’s claim end-users can accept all gasses between the legal ranges, which seems to be true as long the TSO’s keep the regional gas quality fluctuations in the current – regional - limited ranges.

• Apart from The Netherlands, we have not found examples of TSO’s announcing higher volatility of the gas quality in a range exceeding ± 5%

• End-consumers are not complaining, but for the wrong reason: due to very limited knowledge about gas quality issues, and info about future quality changes


Fluxys claims it is already using the whole range of the Wobbe Index

122

Gas supply all different sources in Belgium

But operational ranges are much smaller and there is no exit point exposed to the whole legal range


Even in Spain with one of the widest legal ranges the operational ranges are very limited

123

WI variation typical exit point Spain

LNG downloaded in ENAGAS LNG terminals

Source Enagas

securing competitive energy for industry 124

Conclusions

• Responsibility and liability of gas quality should be clear:– End-users require more clarification.– At least where the issue will we addressed and handled!

• Providing short term information (art.18): – Transparency is key – Information provision is part of the solution and not part of the problem – having adequate near real time info available is a safety issue primarily !

• Providing long term information (art. 20):– Information for the outlook from upstream parties may not be voluntary or without

obligation. – We notice lot of misunderstanding about legal versus operational ranges.

• Customers in most countries only rely on (expected) operational ranges. • Risk and liability when gas quality exceed the operational (and not the legal) ranges

are unclear

Development process led by EC:>Questionnaire to collect data:

NRAs (coordinated by ACER) TSOs (coordinated by ENTSOG) System users

Question to system usersOdourisation: In the case of those IPs where a system is connected to another system where odourisation takes place at different levels, do you (would you) experience barriers to trade in both directions? Are you aware of cross-border trade related problems? Please list examples.

>Please send your reply to [email protected]

Impact Assessment

125


COFFEE BREAK….




CLOSING REMARKS….






Documents

Network Code Interoperability and Data Exchange Rules