Monitoring Reports

Monitoring Reports

ENTSOG aims to continuously improve and update methodologies, tools and data scenarios for its stakeholders, to enhance its deliverables and activities. These are listed in this section.

Balancing Network Code

Third Implementation Monitoring 2017

The third ENTSOG Monitoring Report on the implementation of the Balancing Network Code aims at monitoring the status of NC BAL implementation in the EU by 1 October 2017.

Both ACER and ENTSOG are required to publish monitoring reports – on implementation as well as on effects of the network codes, based for ENTSOG on the provisions of Article 8 (8) of Regulation (EC) no. 715/2009 which empower ENTSOG to monitor and analyse the implementation of the network codes.

Out of 28 EU Member States, the Report evaluates 25 countries (AT, BE / LU, BG, CZ, DE, DK, EE, EL, ES, FR, HU, HR, IE, IT, LT, LV, NL, PL, PT, SE, SI, SK, RO, UK-GB and ­UK-NI).

Three countries (Cyprus, Finland and Malta) held a derogation meaning that the application of the NC BAL (Code) is not mandatory. Estonia also held a derogation but has responded on a voluntary base. UK is mentioned as UK-GB and UK-NI due to two different balancing regimes in place.

The Code foresees three implementation deadlines: 1 October 2015, 1 October 2016 and up to April 2019. For 10 countries (AT, BE / LU, DE, DK, FR, HU, NL, SI, UK-GB) the Code has been applicable already by 1 October 2015. For another five countries (CZ, ES, IT, HR, PT) which have ­applied for the provision of Article 52 (1) of the NC BAL, the deadline for full implementation of the Code was by 1 October 2016.

Instead of full implementation, 11 countries (BG, DE, EL, IE, LT, LV, PL, RO, SE, SK and UK-NI) applied for interim measures for up to five years from the entry into force of the Code (i. e. until April 2019).

STSP and balancing services in own balancing zone by 1 October 2017

The main findings of this Report are the following:

  • 19 countries indicated having implemented the merit order in accordance with Art. 9 with title products at the first place or using only title products whereas 7 countries rely only on balancing services.
  • The information provisions according Art. 32 BAL  NC (3 types of information) are provided by 23 countries and partially by two countries.
  • 20 countries have put in place an information model for daily and non-daily metered off-takes. twelve use the Base Case model, six the Variant 1 and two countries Variant 2. Two countries are still discussing implementation whereas two other countries said that is not necessary since they do not have NDM off-takes connected to their network. Estonia has not chosen yet since they are still holding a derogation
  • The cost benefit analysis (CBA) deadline regarding the information provisions passed in April 2016. Seven countries reported that this CBA has been complete.
  • Daily imbalance charge provisions are in place in 17 countries while the 8 others are using interim imbalance charge.
  • Of the five countries that have already implemented WDOs, two countries stated a change which reduces WDO obligation.
  • Five countries reported to have offered Linepack flexibility service by 1 October 2017.
  • 11 countries have applied interim measures (­balancing platform, balancing services, interim daily imbalance charge and / or tolerances). Some countries have or will reduce progressively the level of their ­tolerances.
  • Four merges of balancing zones (whose two cross-borders) are announced for the next years
    • In France in November 2018,
    • Between Denmark and Sweden, subject to NRAs’ agreement, in April 2019,
    • Among the three Baltic States
      (joint maybe by Finland) by 2020 and
    • In Germany by 2022 at the latest.

Second Effect Monitoring 2017

Following Article 8 (8) of Regulation (EC) No 715 / 2009, ­ENTSOG shall monitor the effects of the Balancing Network Code (BAL  NC) in the European market. The second ENTSOG report on effect monitoring covers the implementation of the BAL  NC on 31 balancing zones across 25 EU countries for the gas year (GY) 2016 / 2017.

ENTSOG introduces 5 indicators (BAL.1 to BAL.5) in order to show certain effects of the implementation of the BAL  NC.

The 25 countries (AT, BG, BE / LU, CZ, DE, DK, EE, EL, ES, FR, HR, HU, IE, IT, LT, LV, NL, PL, PT, SE, SI, SK, RO, UK-GB and UK-NI) where the BAL  NC applies are clustered into three groups related to their chosen implementation deadline as follow:

  • Cluster 2015: AT, BE / LU, DE, DK, FR, HU, NL, SI and UK-GB (10 countries)
  • Cluster 2016: CZ, ES, HR, IT and PT (5 countries)
  • Cluster 2019 + Estonia: BG, EE, EL, IE, LT, LV, PL, SE, SK, RO and UK-NI (11 countries). Estonia holds a ­derogation but has responded on a voluntary base. For the presentation of the indicators, Estonia will be ­added to this cluster.

In 16 countries (AT, BE / LU, CZ, DE, DK, ES, FR, HR, HU, IT, LT, NL, PL, SI and UK-GB), TSOs rely mainly or exclusively on WD title products for their balancing actions.

Portugal, Estonia and seven countries of cluster 2019 (BG, EL, IE, LV, SE, RO and UK-NI) use only balancing services whereas Slovakia use only balancing platform. This analysis should be taken with caution for Portugal, Latvia, Romania and Slovakia, since in these balancing zones, TSOs have taken only a few balancing actions during the year (for 7 days or less).

In order to reduce its residual balancing role, a TSO should reduce the daily volume traded and /  or the number of days it is taking balancing actions during the year. Of interest is the yearly evolution for a given balancing zone, since some intrinsic features of each network will make comparison among balancing zones complicated to interpret.

Average shipper’s cost of being balanced by a TSO (in % of the WAP)
TSO Costs

For this edition, it is only possible to compare to last year the data of cluster 2015 and some countries of cluster 2019. Countries with WDOs (AT, BE / LU, NL) still have the lowest residual balancing role even if the balancing volumes have increased for BE / LU-H and NL. HU and UK-GB are in the same range. The other balancing zones of cluster 2015 ­except PEG Nord (DK, TRS, Gaspool, NCG and SI) shows decreases in volume and /  or number of days. Germany still has the highest residual balancing role, due to their model: TSOs have to take into account gas quality conversion and the handling of NDM off-take volumes in addition to shipper imbalance volumes.

For the cluster 2019 where it was possible to calculate an evolution, we have seen than LT, SE, IE, UK-NI and PL-H have reduced their daily traded volume and /  or the number of trading / balancing days. Only the Greek figures are increasing.

Cluster 2016 countries show a similar behavior as cluster 2015 countries which do not have WDOs in place.

A correlation between daily shipper imbalances and the ­behavior of the TSO is visible. TSO actions are smaller in ­volume and in occurrence since they are able to handle some imbalances in their system before having to take a ­balancing action.

The report also presents a synthetic indicator: the yearly ­volume for balancing actions.

A new indicator BAL5 present the real cost of being ­balanced by the TSO for some balancing zones. This real cost is slightly greater than the small adjustment. It is deliberate to incentive the shippers to balance themselves. ­Indeed, it will be risky for them to take the small adjustment as a proxy of the cost of being balanced by the TSOs in their arbitrage / risk analysis.

* Austria figures are only for 8 months
(from 1 October 2016 to 31 May October 2017)

Tariff Network Code

First Implementation Monitoring 2017

The TAR  NC has been applicable since 6 April 2017 and it is evident from the first TAR  NC monitoring report that the overwhelming majority of TSOs have implemented all the mandatory 2017 requirements from the TAR  NC. In addition, 38 out of the 46¹  TSOs have also implemented the ‘early compliance’ publication requirements, and TSOs have also started preparations for TAR  NC implementation 2018.

For the publication requirements, 40 of the 46²  TSOs taking part in implementation monitoring have published the required information as required, and a valid reason was provided by nearly all TSOs that have not published as set out in the TAR  NC. Only two TSOs indicated that for some of the publication requirements it is a ‘work in progress’ or ‘will not be done until 2018’. In addition, where the NRA has responsibility for publication, some TSOs have still published information on their websites.

Publication of reserve prices for the current gas year on the TSOs website
TSO Implementation

Even so, there are a small number of issues that are worth noting. In several cases the information to be published was not in English, or the text on websites leading to the required information was not in English, this issue should be addressed going forward. For three TSOs, even though there is a link on ENTSOG’s Transparency Platform (TP) leading to the information on the TSOs or NRAs website, and the information to be published, it was at times difficult to find, as the link did not bring the user directly to the required information. In this case user-friendliness and ease of access can be improved. It would benefit all by the link on ­ENTSOG’s TP leading directly to the standardised section template developed by ENTSOG and its members. The template allows the TSO to place links leading to the ­information required to be published for Article 29 and 30, including a link to the NRA website if they are the entity ­responsible for publication.

The 2017 monitoring obligations under the TAR  NC Article 36 ‘Implementation monitoring’ only covers Chapter VIII ‘Publication requirements’. Despite this, it was decided to include all provisions TSOs must implement and comply with in 2017. This also covers the TAR  NC rules from AD  1, coinciding with the entry into force. The outcome gives a more accurate and complete representation of the work TSOs are undertaking in 2017 to implement the TAR NC, and their preparation for implementation in 2018.

Although not mandatory, two TSOs undertook ‘intermediate’ consultations and published it in English. For the majority of TSOs it is their NRA who is responsible for the consultation process, however, most have already started contributing to the process through meetings and by providing any requested documentation.

Eight TSOs are implementing the ‘limited scope’ rules at points with third countries, and two TSOs at points other than IPs and points other than with third countries. Thirty-six TSOs have commenced using the definitions from the TAR  NC that should be introduced in 2017, and this will contribute to clearer communication and help avoid any potential misunderstandings³.

For the attribution of the auction premium from the sale of bundled capacity, it was noted in one case only that TSOs will change their current arrangements. One TSO indicated they are planning to change their arrangements regarding the use of fixed or floating payable price, in 2018. All TSOs with fixed price contracts concluded before 6 April 2017 issued the contracts or information to their NRA before 6 May 2017. Both TSOs operating interconnectors have, or will, apply for derogations from some Articles in the TAR  NC.

Several TSOs highlighted some key challenges they are ­facing with the implementation of the TAR  NC. Some have already identified solutions to these challenges and for ­others it is a work in progress. 2017 was a busy year for the implementation of the TAR  NC, especially with the ­publication requirements in December. TSOs indicated that they were already planning for 2018 with the publication ­requirements before the TSOs new tariff period and before the annual capacity auctions and the consultation process being prominent features of upcoming implementation in 2018.

1) For the publication of the reserve prices, in seven out of the remaining eight cases, it is the responsibility of the NRA and for one TSO it is non-applicable as they don’t have an IP. For the publication of Article 30 (1)(b), 11 out of 19 TSOs have published this information, it being the responsibility of the NRA for six TSOs, two TSOs have not published this ­information as one is applying for a derogation and the decision on this will determine the scope of what is to be published, and for the other TSO it is a work in progress after their derogation expired in 2017.

2) Of the remaining six TSOs, a decision on publication responsibility is still to be made for two TSOs from the same MS, for four TSOs certain requirements were not fulfilled due to, for example, being non-application for one TSO as they don’t have an IP, due to pending derogation applications or it being a work in progress for one TSO.

3) The remaining TSOs are waiting on: NRA decisions, derogation applications or reviews currently taking place.

Baseline for Effect Monitoring 2017

Monitoring the effect of the TAR  NC as early as 2017 is ­necessary to provide a baseline for effect monitoring ­comparison in future years. The effect of the TAR  NC should be compared to the baseline situation assessed in 2017, since the implementation of TAR  NC Articles is staged ­during several years.

The 5 EM indicators used by ENTSOG that will be used for the effect monitoring of TAR  NC are as follows:
  • Indicator TAR.1 on the ‘Level and variability of the under- / over-recovery’ for TSOs.

The objective of TAR.1 is to provide an assessment of the evolution of the regulatory account balance compared to the allowed revenue during the years following the implementation of the TAR  NC.

  • Indicator TAR.2 on ‘Tariff changes at CAM and non-CAM points’4 .

The objective of TAR.2 is to consider the evolution of capacity-based and commodity-based tariffs between the tariff period before the prevailing tariff period and the prevailing tariff period for each TSO.

  • Indicator TAR.3 on ‘Evolution of short-term and long-term bookings’ of TSO capacity at CAM points.

This indicator aims to check the possible changes in the way network users book capacities after the TAR  NC ­implementation. The objective is to consider if the TAR  NC contributes to the increase in the share of short-term bookings in total bookings.

  • Indicator TAR.4 on ‘Publication of information in English’.

Indicator TAR.4 aims to check if information to be published per the TAR  NC will be available in English, which is ­supposed to facilitate access to markets for all network ­users. It contributes to transparency and tariff ­comparability across Europe.

  • Indicator TAR.5 on ‘Multipliers for short-term ­capacity products’ at IPs.

The objective of TAR.5 is to give transparency on multipliers applied to short-term products at IPs only.

4) CAM points in a MS correspond to IPs and – where relevant – non-IPs (including entry-points-from and exit-points-to third countries) where the NRA decided to apply the CAM  NC. Non-CAM points are all other points in the specific MS.

The following conclusions can be drawn in terms of the 5 EM indicators used in this EM report 2017:

TAR.1 (under- / over-recovery): the evolution is mixed in terms of revenue recovery, with most TSOs reporting mixed results as regards the level and the variability of the regulatory account balance since 2013. However, these results correspond to early years and stem from a limited number of TSOs participating in this indicator. Data to be collected in following years will be useful to verify the impact of the TAR  NC on revenue recovery.

TAR.2 (tariff changes): the pattern followed in Europe shows a moderate increase in tariffs across all TSOs between the last 2 tariff periods, with some special cases due to radical changes in capacity-based and commodity-based tariffs. Longer time series will be necessary to check which effect the TAR  NC will have on tariff changes.

TAR.3 (bookings): for most TSOs taking part in this EM report, the share of yearly capacity products remains dominant in recent years. Nonetheless, between gas years 2014 – 15 and 2015 – 16 a slight shift towards short-term products was observed in many TSOs and it is especially beneficial to daily products. This trend will have to be checked in future Effect Monitoring reports.

TAR.4 (publication in English): across the 5 sub-indicators used for TAR.4, it appears that the availability of English translations will mainly depend on the decision of NRAs with regards to the periodic consultation and the consultation on some discounts, multipliers and seasonal factors. More than one third of TSOs highlighted that an English version would be available for the yearly auctions, and more than a half of TSOs stated that an English version would be available for the tariff periods.

TAR.5 (multipliers): considering all types of short-term products, most TSOs already comply with the ranges of multipliers which are defined in the TAR  NC. A few TSOs currently use multipliers which are sometimes significantly out of the ranges. For the tariff period following AD3 of the TAR  NC, they will have to adjust to these ranges (for quarterly and monthly multipliers), or they will have to provide a due justification for this level (for daily and within-day ­multipliers).

These baseline results paint a picture of the situation of ­European TSOs at the start of the implementation of the TAR  NC.

TAR.5 sub-indicator on daily multipliers for TSOs in Europe

CAM Network Code

Implementation Monitoring 2017

The implementation of the CAM  NC is an important step in the harmonisation and development of an integrated energy market within the European Union. Network Users can join and operate within the integrated market more easily than in a multitude of separate national markets with different rules and regulations for network access and capacity trading. In the European Union, standard procedures for capacity booking are provided within the integrated market, for example unified capacity auction dates for capacity products offered on no more than one common booking platform, with one exception – at any single interconnection point instead of individual TSO websites for the booking procedures. Moreover, capacity products are harmonised and operational steps are facilitated by booking the entry and exit capacity at an IP in one single step by bundling the ­respective products.

The integrated energy market goal of the CAM  NC has been almost achieved. The clear majority of TSOs have implemented all of the mandatory requirements from CAM  NC on time, thus providing strong support for the integrated EU gas market.

To fully achieve the desired results, certain measures that have not yet been implemented by some TSOs should be done as soon as possible. The implementation monitoring report shows further developments regarding the implementation of provisions in comparison with the monitoring report for 2015.

Both ACER and ENTSOG are required to publish monitoring reports. ENTSOG’s and ACER’s implementation monitoring reports are complementary. ENTSOG’s report was developed based on data provided by TSOs.

The survey conducted by ENTSOG regarding TSO implementation of the CAM  NC shows that of the 43 TSOs required to apply CAM  NC, 37 have already developed and applied all or at least all mandatory CAM  NC measures. This means that they fully comply with the obligations defined in the CAM  NC.6 TSOs indicate that they have partially implemented the CAM  NC requirements, while 3 TSOs are under derogation, therefore they were excluded from this monitoring report. Furthermore, 3 TSOs have applied implicit allocation ­method (Baltic states), where NRA decided not to apply Art. 8 to 37 of the CAM  NC (Art. 2 (5)).

Based on the last years analysis, ENTSOG decided not to collect data on the CAM  NC requirements at each side of an Interconnection Point. ENTSOG believes that the requirements are widely implemented, and IP analysis would not provide added value to the report.

Current use of capacity booking platforms within EU
Current Use

The implementation of the NC  CAM provisions involves the auctioning of bundled capacity products at all IPs within the European Union, expect where implicit allocation applies. Three different booking platforms are established in the European Union: PRISMA, GAZ-SYSTEM Auction Platform (GSA) in Poland and the Reginal Booking Platform (RBP) in Hungary.

As from end of year 2017, all relevant TSOs are connected to a booking platform. There are only two IPs for which no agreement on a booking platform has been reached so far. These IPs are at the German-Polish border.

Some TSOs have applied interim measures from the ­Commission Regulation (EU) No 312 / 2014, also known as Network Code on Gas Balancing of Transmission Networks. In these cases, certain provisions laid out in the CAM  NC are not applicable, e.g., the introduction of an over-nomination procedure or the offer of within-day interruptible ­capacity.

Moreover, at some IPs it is not possible to implement all CAM  NC articles in daily use since all technical capacity has already been booked on a long-term basis. Hence, no auctions can take place and neighboring TSOs cannot bundle the available capacity.

However, such restrictions in applying of the CAM  NC provisions, especially in the last case, do not necessarily mean a delayed implementation. Despite the non-application of certain rules, TSOs may still have implemented the required measures.

Effect Monitoring 2017

ENTSOG launched the first annual effect monitoring ­process in December 2017 to ensure the timely publication of ­results in this Report.

To measure the effects of the CAM  NC on the European market, ENTSOG used three indicators that show the ­impact of the mechanisms.

To monitor the effects of CAM  NC, the data was requested from all TSOs using any of the booking platforms for capacity allocation during the gas year 2016 / 2017. ENTSOG has aimed to produce its report to be supplementary to ACER’s report. Regarding the effect monitoring, ENTSOG’s focus has been to identify to which extent the main aims of the Network Code have been achieved.

Share of bundled capacity to sold capacity over the entire capacity increases, except of the daily products. One of the reasons for an increase in the bundled capacity share was caused by the exceptional long-term bookings in the ­annual yearly auction in March 2017.

ENTSOG has further developed the methodology and in this report, the indicator uses only data from IPs that are CAM relevant on both sides. ENTSOG believes this will give a ­better picture on the volumes of sold bundled capacity. In the previous year’s report, all CAM relevant IP sides were considered; even those with third countries and DSOs, where no bundled capacity can be auctioned and allocated.

Effect Monitoring Indicators and their results
  • CAM.1: Share of bundled capacity to sold capacity

The ratio of bundled capacity to firm capacity booked for quarterly products was the highest at 77 % of overall sold quarterly capacity and the second highest was 76 % for yearly capacity. There is an increase in the case of the quarterly products in comparison to previous year monitoring. It can be assumed that four different auction times, as set in Regulation (EC) 2017 / 459 for the quarterly auctions ­increased the booking of this capacity product. The next significant increase of the bundled share is in case of monthly products, where half of the capacity has been sold as bundled. The share of bundled capacity in case of daily products has decreased from one third to twenty percent.

  • CAM.2: Share of secondary market-traded bundled capacity to secondary market traded unbundled ­capacity

Share of bundled capacity reallocated due to secondary market trades is marginal at less than 1 %. This is caused by the historical dominance of unbundled capacity.

  • CAM.3: Increase of market participants in a system

The indicator shows an important increase of both, “all participants” and “active participants” in the European market. Number of all participants has increased from gas year 2015 / 2016 to gas year 2016 / 2017 with almost 313 new network users being approved in European systems to participate in the gas market. This means an increase of 14% in one year.

Increase of active participants is even clearer, since the number of active participants in European markets has increased by 25% compared to the previous year. In other words, 180 new network users became active on the European market in 2017.

CMP Guidelines

Implementation Monitoring 2017

ENTSOG independently launched its annual implementation monitoring exercise for CMP Guidelines in November 2017.

Most of ENTSOG members have already fully implemented the CMP Guidelines. 42 of 49 TSOs are fully compliant with the CMP Annex, and only two members were still in the process of implementing some of the CMP measures. After the approval by the NRAs of most of the proposals of implementation of the remaining mechanisms by the end of 2017, most of the TSOs that were not fully compliant with CMP rules have finalised the implementation of the remaining mechanisms at the end of the first quarter of 2017. Two TSOs expect to implement all CMP rules before the end of year 2018.

This means that, with the information received by ENTSOG during December 2017 and January 2018, a total compliance with the CMP Annex all around Europe is expected at the end of 2018. This compliance is subject to the ­expected approval by the NRAs of the CMP implementation ­proposals provided by the TSOs, and to the fact that the expected times for the implementation of the remaining CMPs are ­accomplished and experience no delays.

Effect Monitoring 2017

ENTSOG launched the annual effect monitoring process in December 2017 to ensure the timely publication of results in the 2017 Annual Report. ENTSOG has aimed to produce reports that can be considered supplementary to ACER’s report. Regarding effect monitoring, ENTSOG’s focus has in particular been to identify to which extent the main aims of the guidelines has been achieved.

To measure the effects of the CMP Guidelines on the European market, ENTSOG used two indicators that show the impact of the mechanisms.

To monitor the effects of CMP Guidelines, the data was requested from all TSOs that owned IPs considered congested by ACER in his Congestion Report 2016 / 2017. In addition, ACER undertakes its own monitoring and ENTSOG considers its report as supplementary to ACER’s.

Effect Monitoring Indicators and their results
  • CMP.1: Additional capacity volumes made available through each CMP

As shown, FDA UIOLI is the only CMP mechanism that releases capacity – on a cumulative basis for the period under consideration – at congested IPs while the LT UIOLI mechanism, OS + BB and Capacity Surrender does not provide any additional capacity at congested IP sides to the market for the observed period.

  • Indicator 2 (CMP.2): Share of capacity reallocated through CMP relative to total capacity reallocated

The chosen indicator compares the allocation of additional capacity through CMP mechanisms with the allocation of the total additional capacity (additional capacity allocated from that offered through CMP mechanism + additional ­capacity allocated from offered capacity in the secondary market).

In the figure here, it is seen that both means of re-offering unused capacity via CMP mechanisms and the secondary market have been established in Europe. 10 % of the capacity is allocated via CMPs. Bilateral agreements between network users (secondary market) are still the preferred solution for trading unused capacity.

Additionally, it is worth noticing the importance of the secondary market in offering additional capacity. Almost 50 % of the total amount of reoffered capacity is traded on the secondary market. However, it is important to note that from the total amount of allocated capacity that is re-offered, 85 % of it is allocated to other network users on the secondary market.

Results of CMP indicator 2

To conclude, the current ways of offering additional capacity from unused allocated capacity effectively allows network users to access markets in situations where IPs are contractually congested and technical capacity is not available.

The current situation in the European gas market shows that, of the total amount of additional capacity offered through CMP mechanisms, around 10 % is reallocated.

This means that contractual congestion situations are not limiting market access to other network users who do not hold capacity at the relevant IPs. Otherwise, the demand for additional capacity and reallocated amounts would be much higher. The ­secondary market is an important tool for trading unused capacity between network users and thus significantly helps to ease market access at congested IPs. It can therefore be considered to be a widely accepted alternative to CMP mechanisms by network users.

Network Code on Interoperability and Data ­Exchange Rules

As per Article 8 (8) of Regulation (EC) No 715 / 2009, as well as to Article 25 of the INT NC, ENTSOG monitors the implementation of the Network Code. The first implementation monitoring report of ENTSOG was published in September 2016. By 15 January 2018, TSOs provided ENTSOG with the necessary information (by questionnaire) allowing the fulfilment of its monitoring and reporting obligations for 2017.

The data provided by 45 TSOs have been used as the basis for this report.

Based on the replies from participating TSOs, the report shows that 69 of 72 interconnection points (IPs) are ­covered with interconnection agreements (IAs) between adjacent TSOs. Results indicate that, in the signed IAs, the adjacent TSOs agreed on the main terms and conditions foreseen in the INT  NC. In the most of agreements, the lesser rule is ­implemented as the matching rule and the operational ­balancing account (OBA) as allocation rule.

In the majority of IAs measurement principles and rules for flow control which are foreseen in the INT NC are taken into consideration.

Chapter IV of the INT NC covers gas quality and odourisation issues and prescribes instruments for managing cross-border trade restrictions due to differences in terms of gas quality or odourisation practices. According to the results, no cross-border trade restrictions due to differences in gas quality or odourisation practices. On 2 IPs, a potential restriction has been reported by only one of the adjacent TSOs. Nevertheless, the issues are solved by cooperation between the relevant TSOs and therefore, not subject to the procedure of Article 15  (2).

More than 84 % of the TSOs comply with the obligations ­regarding short-term monitoring on gas quality (Wobbe ­Index [WI] and Gross Calorific Value [GCV] hourly data for each entry IP).

The data exchange security requirements stated in article 22 of the INT  NC are met by 84 %, (this requirement – and the whole chapter 5 – is not applicable 11 % of TSOs).

The majority of TSOs (68.9 %) have already implemented the common data exchange solutions.

Regarding the 20 % TSOs who have not implemented these solutions yet, 2 TSOs have only implemented the optional solution (interactive) but not the mandatory one (document-based) with NRA approval. One TSO has another interpretation of the provisions in the network code and has implemented interactive as well as the integrated solution, but not the mandatory one.

The implementation of CNOTs should have been completed by November 2017, which is 12 months after the publication.

In accordance with Article 23.2, other solutions from those listed in Article 21 are in place for 31 TSOs.

Support the TSOs of Member States, Energy Community and third countries in the implementation of the NC

The Interoperability team and WG keep building a close ­cooperation with the Energy Community through the ReCo teams and joint workshop on Interoperability and Transparency and advise on the roadmap for implementation of the NC within the Contracting Parties and adjacent Member States.