Review of the Harmonised Allocation Rules for long-term transmission rights and regional annexes

Overview

This consultation is based on Article 6 of Commission Regulation (EU) 2016/1719 (FCA Regulation) and concerns the review of Harmonised Allocation Rules for long-term transmission rights (HAR) in accordance with Article 68(5) of these rules.

Together with the HAR main body, all annexes proposing amendments will be consulted. See table below.

The consultation of the Core and GRIT specific HAR Annexes (respectively Annex 1 and 3) is based on Article 4(12) of the FCA Regulation and concerns the amendments of the CCR Core and CCR GRIT TSOs’ specific Annexes to the HAR in the meaning of Article 52(3) of the FCA Regulation. 

Core CCR specific Annex 1

This third amendment proposal covers changes of the caps on compensation that shall be applicable to the HU/SI border in accordance with Article 59(2) of the HAR.

GRIT CCR specific Annex 3

This amendment proposal deletes Article 2 on Temporary arrangement for curtailment deadline on Italy SOUTH-Greece Bidding Zone Border, given that SDAC went live on Italy SOUTH-Greece bidding zone border on 15th December 2020

Extension of HAR Article 59 ("Compensation for curtailments to ensure operation remains within Operational Security Limits before the Day Ahead Firmness Deadline") to decoupling events

To ensure fairness and a level playing field both for market participants and for tariff payers, TSOs believe that a structural solution is to be found in an update of the FCA regulation. As there is no consensus (yet) on this amongst European stakeholders / legislators, TSOs pragmatically propose a change to the HAR enabling a first step in the right direction.

HAR Article 59 provides TSOs with possibilities to mitigate the absence of Congestion Income in case of curtailment to ensure operation remains within Operational Security Limits. The current proposal seeks to extend this possibility to full or partial decoupling events of the Day Ahead market triggering a fallback allocation, which would provide a fairer framework, by including a new fifth paragraph in Article 59, which would read as follows:

5.- Irrespective of whether it is a Direct Current interconnector or not, the cap described in paragraphs 3 and 4 of this Article shall also apply to the remuneration of Long Term Transmission Rights holders for non-nominated Physical Transmission Rights and Financial Transmission Rights in case of fallback Allocation for Implicit Allocation.

TSOs welcome stakeholder views on the application of a cap for decoupling events, and any eventual ideas stakeholders may have to further increase its effectiveness.

Why your views matter

We are seeking input from stakeholders and market participants on the impact of the proposed changes to the current HAR and regional Annexes.

In addition to the changes foreseen at the operational level, all TSOs are considering the possibility of enlarging Article 59 of the HAR to include decoupling events, as such situations impose a large financial risk for the tariff payers.

What happens next

After consultation, TSOs will carefully analyse the received responses, amend the documents if needed and assemble all views in a Consultation Report. The final HAR will be submitted afterwards to all NRAs/ACER for approval. The regional and border specific annexes will be submitted to the respective NRAs for approval.