Annex VI: Neutrality
(Chapter VII of the BAL NC)
Table 6.1: General overview of Neutrality provisions implementation
GENERAL OVERVIEW OF NEUTRALITY PROVISIONS IMPLEMENTATION
Implementation of Neutrality provisions
acc. to art. 29–31
Implemented
BE/LU, DE, ES, FR, HU, IE, IT, NL
1)
, PL, PT, SK, SI, UK-GB, UK-NI
Partially implemented*
BG, CZ, EE
2)
, EL, LT,
Other mechanism in place AT, DK, SE
Under discussion
HR
3)
, RO
4)
Table 6.2: Overview of countries with partially missing implementation of neutrality provisions*
OVERVIEW OF COUNTRIES WITH PARTIALLY MISSING IMPLEMENTATION OF NEUTRALITY PROVISIONS (ART 30–31 BAL NC)*
Missing provision
Countries
Publication of the methodology
CZ, EE
Publication of monthly aggregated neutrality charges
BG, CZ, EE, EL, LT
Methodology for the calculation of the neutrality charge foresees the apportionment amongst network users and credit
risk management rules (art. 30.2).
CZ, EE, LT
Neutrality charge for balancing is proportionated to the extent the network user makes use of the relevant entry or exit
points concerned or the transmission network (art. 30.3).
CZ, EE, LT
Balancing neutrality charge is shown separately on invoices (art. 30.4).
BG, CZ, EE, LT
Invoices are accompanied by sufficient supporting information (art. 30.4).
BG, CZ, EE, LT
Measures taken on network users in order to mitigate their default in payment (art.31.1).
BG, CZ
5)
, EL
In case of a default attributable to a network user, TSO has the possibility to recover the loss (art. 31.3).
CZ, EL
Rules for a separate neutrality charge for balancing in respect of non-daily metered off-takes for Variant 2.
PT
* In Croatia, Greece and Romania the neutrality mechanism is still under discussion or revision by NRA.
Bulgaria reported the planned implementation by 1 January 2017.
1) NL: As the daily imbalance charge is always zero for all network users, the outcome of the neutrality charge
is also always zero. Therefore we also do not publish every month the neutrality charges as requested by
Art 29.4. We do generate revenues for the end-of-day imbalance incentive through the Linepack Flexibility
Service, and we have implemented a neutrality principle for that. These revenues are deducted from the
Allowed revenues, so the transport tariffs decrease because of that.
2) EE: TSO does nor gain or lose by providing balancing actions, but no separate neutrality charge.
3) HR: The Rules on the Organisation of the Gas Market are not harmonised with BAL NC 312/2014.
4) RO: The document was in a public consultation in the beginning of 2016, and was subsequently withdrawn
by NRA. Subsequently, based on the proposals and comments from the market NRA requested Transgaz to
update the project, therefore it was submitted again to public consultation, with the purpose to be
approved by 31 December 2016. The answers to the questions below refer to the project in question.
5) CZ: Neutrality charge is not applied. Principle of neutrality of balancing is ensured by price regulation
(correction factor in the regulatory formula).
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