According to a document from Transgaz, the proposed entry-exit system creates the premises for increasing the liquidity of the natural gas market in Romania, especially regarding short-term (daily / intra-day) transactions. This document is the first result of a working group formed last Autumn by representatives of DG ENERGY, ACER, ENTSOG, ANRE and TRANSGAZ, in order to check the compliance of the current regulatory framework with the provisions of European legislation and to formulate concepts / specific recommendations for amending national secondary legislation or other applicable rules.

The national system operator also states that it is running “significant investments in the system development thus allowing for a gradual increase of the regional interconnectivity as of 2019, with positive effects on the evolution of the gas market”. Also, the company is carrying out development projects designed to increase transmission capacities in the export direction, which will contribute to the increase of the pressure levels in the Romanian gas system by 2020.

The proposed entry-exit system

Network users shall be able to book entry capacity and exit capacity independently. A VTP will be established to enable gas title transfers, irrespective of their location in the NTS. At least one trading platform will be connected to the VTP. Not only the signatories of the capacity booking contracts, but also other gas market participants, will have access to the VTP.

Access to the VTP is unrestricted and shall be granted based on the conclusion of a balancing contract between market participants (including paper traders) and the transmission system operator (TSO).

Information platform of the TSO

The TSO owns and operates an information platform (available 24/7), set up in accordance with the provisions of the Network Code. The TSO envisages the further development of the IT platform thus allowing for the performance of all processes described in this concept paper. Data exchange between the TSO and market participants are performed in a secure manner, in accordance with the relevant provisions of Reg. (EU) no. 2015/703.

The processes carried out within the platform are:

• Capacity booking platform (primary capacity platform – PCP) to be used for domestic points
• The transfer of the rights and obligations related to the booked capacity (secondary capacity platform–SCP)
• VTP operation
• (re)nomination, matching, allocation
• Imbalances calculation
• Information exchange (nominations, allocations, imbalance positions, trade notifications, etc.)

The transfer of the ownership title in the VTP

It is an abstract, and unique point of the NTS, in between the NTS entry and exit points, where the transfer of the gas title from one gas market participant to another is enabled.

The VTP is used by the gas market participants both for commercial purposes and for the individual balancing of the NU portfolio, during a gas day, in compliance with the rules on the access to and the use of the VTP.

The VTP enables for gas title transfers independently of their location in the NTS.

The transfer of the ownership title in the VTP is made upon the TSO’s confirmation of the transaction notification. Such rule will be stipulated both in the national Network Code and in the balancing contract, enabling access to the VTP. The confirmation by the TSO of the transaction notification will be an electronic message which, according to the Romanian law, may be used as evidence in court (the message will include at least the name of the parties, the quantity, and the date).

According to art. 1678 of the Romanian Civil Code -Selling goods of the same nature – “”Where the sale relates to goods of the same nature, including goods of a limited nature, the property shall be transferred to the buyer on the date of their individualization by surrender, counting, weighing, measuring or otherwise agreed or imposed by the nature of the good.

VTP notification validation process

If the notification of a transaction is sent by the operator of a trading platform/clearing house, the TSOs confirms within thirty minutes the title transfer to the involved parties and registers in their portfolios the sold or purchased quantities.

If the notification of a bilateral transaction is made by the involved parties the TSO proceeds as follows:

• compares the quantities notified by the two participants to the transaction and if they are equal it registers the sold or purchased quantities in their portfolios
• the TSO will confirm to the parties the recording in their portfolios of the sold or purchased quantities
• if the two quantities are different, the TSO rejects both notifications and informs the involved parties

Each VPT will group several physical points

The NTS currently has the following types of physical entry points:

• 137 physical entry points from production fields
• 7 physical entry points from underground storages, for withdrawal of gas from underground storages
• 2 physical entry points from EU member states neighboring gas transmission systems
• 2 physical entry points from non-EU member states neighboring gas transmission systems

The creation of an entry-exit system requires the simplification of the network, which will be obtained by grouping several physical points. Thus, there will be 11 NTS virtual entry points, with the technical capacity of each virtual entry point calculated by summing the technical capacities of the composing physical entry points.

The NTS has the following types of physical exit points: 870 physical exit points to distribution systems; 232 physical exit points to direct clients; 7 physical exit points to underground storages; 2 physical exit points to EU member states neighboring gas transmission systems; 1 physical exit points to non-EU member states neighboring gas transmission systems; There will be 37 virtual exit points to distribution systems, 2 virtual exit points to underground storage systems, 2 virtual exit points to EU member states neighboring gas transmission systems and 1 virtual exit points to non-EU member states neighboring gas transmission systems.

The document brings details on the contractual framework for capacity booking, describes the commercial and operational processes at the entry / exit points, as well as the types of information that the system operator will publish, but also an example of un use case on PVT.