Position paper following the consultation on amendments proposed by ACER to the Capacity Allocation and Congestion Management guidelines.
The enforcement of the 70% minimum cross-zonal capacity available for trade up to the intraday, requires offering “virtual capacity” to market participants with little to no time to perform remedial actions. Since TSOs are responsible to maintain operational security, the minimum capacity requirement will in reality be offset to maintain operational security. TSOs call upon NRAs / ACER / EC to investigate alternative solutions, which better balance market needs and system security.
The CCR redefinition introduced with amendments, stems from ACER’s anticipation that a future CCR determination assessment will induce a change in CCR set-up. It is fundamental that TSOs and their NRAs are able to assess and choose the most efficient CCR configuration on the basis of economic and governance-related criteria. Moreover, the concept of BZBs in multiple CCRs must take into account the impact on the implementation of other Guidelines, in particular FCA and SO GL
The distinction between 3rd countries flows and EU flows in the implementation of the 70% target would lead to even more virtual capacity being offered. Hence TSOs strongly call for a reasonable approach to keep the status quo for the consideration of 3rd countries in the EU processes, at least where local arrangements are already in place and/or initiatives exist to develop them.
Applying flow reliability margin instead of total reliability margin in CCRs applying the cNTC approach will be burdensome, might not bring additional benefits and would be unnecessary for those CCRs switching to flow-based. Therefore, TSOs support option 2, where cNTC CCRs assess this through a CBA.