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TAR NC Implementation Document – Second Edition September 2017 |

173

As explained above, certain obligations from Table 20 ‘Who is doing what’ are not

represented on the calendar year timelines above due to their specificity. These

obligations are limited to multi-TSO entry-exit systems within a MS and appear in

Figure 51.

Figure 51 shows only the process associated with the final consultation under Arti-

cle 26, but with additional requirements for multi-TSO entry-exit systems within a

MS. Therefore, most of the white and orange boxes are exactly the same as for the

timeline above, except for those linked to Article 10 of the TAR NC. Other boxes on

the timelines also apply to multi-TSO entry-exit systems within a MS, such as differ-

ent ADs of the TAR NC, publication requirements before the tariff period and before

the annual yearly capacity auctions, deadlines for ACER’s reports, deadlines for in-

formation provision from TSOs to ENTSOG and for ENTSOG’s implementation and

effect monitoring reports.

The timeline in Figure 51 starts with December 2017 as the estimated deadline for

the start of the development of the final consultation document, which is the same

as for the timelines. August 2018 is the estimated date for launching the final

consultation. The timeline then continues until 31 May 2019, which is the deadline

for NRA decision-making after final consultation. May 2024 is the estimated dead-

line for the duration of separate application of RPM(s) in multi-TSO entry-exit

systems within a MS.

In the absence of specific guidance from the TAR NC, Figure 48 allocates the NRA

decision to the time period between December 2017 and August 2018 concerning

who must carry out an impact assessment and a CBA on intermediate steps allow-

ing for separate application of different RPM in case of entry-exit systems merger.

The TAR NC foresees that the consultation on effective ITC and its consequences

for the tariff level (both for the case of joint and separate application of RPM(s) in

multi-TSO entry-exit systems within a MS) is conducted simultaneously with the final

consultation under Article 26 and consultation under Article 28. Thus, the three

consultations will be launched and finished simultaneously. Also, the TAR NC envis-

ages the publication of the responses to the Article 26 consultation within one month

following the end of the consultation, and that by 31 May 2019 the NRA must take

a decision on the applied RPM, and must calculate and publish ‘new’ tariffs. How-

ever, the TAR NC is silent as to the time for the NRA to publish the responses for

consultation per Article 10(5) and the associated NRA decision-making, except for

them to take place at the same time. Per ENTSOG’s assumption, these will take

place at the same time as NRA decisions for consultations under Article 26 and 28.

As explained in ‘Calendar Year 2019’, these decisions should be taken in a timely

manner before 31 May 2019 to allow for tariff calculations on the basis of such de-

cisions. For multi-TSO entry-exit systems, more time may be needed for the calcu-

lation of tariffs, for example due to the necessity of an ITC mechanism.