EU Transparency generation data partly missing, how to finally get 543/2013 16.1 enforced?

Dear all

This is my first post on this forum. I use to read the mailing list since ~2017 with a very few contributions.
I speak as an OpenStreetMap contributor, collecting and producing data about power infrastructure, mainly generation and transmission. OpenData, transparency and most initiatives are very useful to me and my involvement is dedicated to reinforce them.
I take the opportunity to write something about what I experienced with 543/2013 policy and ENTSO-E Transparency Platform for years.
Particularly about 16.1 for actual generation.

Transparency regulation focuses on significant production/generation units from market perspective, among other points.
That should ease the enforcement process on their operators as there are few generators to match in regard of the whole installed capacity.
I’d be in favour of lowering down the threshold about unit publication. 16th article could deal with 10 MW units instead of 100 MW. But as we don’t manage to get things done regarding 100 MW units, how can we achieve to get data for smaller ones?

Anyone would expect to find a complete list of functioning generation units.
Data are sent by TSO to the platform, based upon measurements or producers.
Who checks the consistency of those reports?
Then, how reliable any aggregation or global view can be currently?

As a result, most of generation units are shown in the actual generation per generation unit view but a few are missing.

Sending warnings to regulators, ACER of even TSO is such a difficult process, to get in touch with the people in charge.
16th article states that TSO are responsible of reporting production data but can’t they delegate to producers sometimes?
It begins with pointless answers “it’s normal, mind your own business”, whatever, prior to dig a little more in details - years after - to finally realize actual errors.

Three particular situations regarding production should be kept in mind:

  • Compagnie Nationale du Rhône, French operator in charge of Rhone river operations, including electricity generation with ~3.2 GW of run of river hydro installed capacity.
    Teams didn’t comply with REMIT until very late 2021 (10 years to be told about REMIT).
    Currently, generation data per >200 MW production units aren’t reported nor to IIP neither to ENTSO-E.
    See ENTSO-E platform.

  • TotalEnergies Landivisiau gas power plant started operations at the begining of 2022, but still no production data on the IIP neither on ENTSO-E platform (see FR_LANDIVISIAUGU production unit in the link above).

Local regulation alerts has been sent, several times and very recent display of generation units on ENTSO-E views (only for REMIT messages for now), with no generation data is the only proof I got that things are slowly changing.

  • Alpiq, Swiss operator with several GW of hydro installed capacity, mainly storage and pumped storage with highly significant units (Bieudron 1270 MW, more recently Nant de Drance 900 MW).
    However, Swissgrid (TSO) only reports production aggregated per production unit and not per generation unit (despite some of them > 100 MW).

In the same time, Axpo, another Swiss operator got its generation units well integrated and production data reported on ENTSOE platform (Limmern - Muttsee for instance).
Thus, I can’t currently conclude there may be specific regulation rules that would apply to Swissgrid TSO that prevent them to report generation units operated by Alpiq.
See ENTSO-E platform.

I currently got no answer from Swissgrid neither from Alpiq about that.

Finally, such inconsistencies are very disappointing, regarding well known generation units that shouldn’t be missing from the very beginning.
Consistency between generation unit knowledge and measurements should always be ensured. Especially regarding wellknown industrial facilities.
Waiting ~10 years for compliance with regulation is data losses at first.

Am I wrong or alone to experience such issues, which still require too much of energy to be solved?

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