Brussels, 1 December 2017 | Europex has submitted its response to ENTSO-E’s public consultation on the All TSOs’ proposal for the Key Organisational Requirements, Roles and Responsibilities (KORRR) relating to Data Exchange in accordance with Article 40(6) of the Commission Regulation (EU) 2017/1485 of 02 August 2017 establishing a Guideline on Transmission System Operation (SO GL).
Europex suggests deleting Article 19 of the present proposal. We understand the approach to mention all involved parties in the data exchange process. However, the obligation for NEMOs to share market results and cooperate with TSOs is already stipulated in other EU legislation, including Commission Regulation 2015/1222 (CACM, mainly Article 62) and Commission Regulation 543/2013 on the submission and publication of data in electricity markets. Furthermore, the SO GL itself does not mention any NEMO roles or responsibilities, and KORRR is only an implementing and not a legislative document. The enforceability of Article 19 would not be given as it is not in line with the SO GL.
Please read the full consultation response below.