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

Open data
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Dear all

This is my first post on this forum. I read the mailing list since about 2017 with only a very few contributions.

Overview

I write as an OpenStreetMap contributor, collecting and producing data about power infrastructure, mainly covering generation and transmission. Open data, 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 have experienced for some years with EU regulation 543/2013 policy and the ENTSO‑E Transparency Platform that 543/2013 established. And particularly about article 16.1 for actual generation. That statute in full:

ENTSO‑E is the European Network of Transmission System Operators for Electricity. Also under discussion is REMIT or the Regulation on Wholesale Energy Market Integrity and Transparency, as enacted through EU regulation 1227/2011, thus:

ACER is the European Union Agency for the Cooperation of Energy Regulators. And a TSO is a transmission system operator.

The 543/2013 transparency regulation focuses on significant production/generation units from a market perspective, among other things. That should ease the enforcement process on the plant operators as there are relatively few generation units to match in relation to the installed capacity in total.

I would be in favor of lowering the threshold for unit publication. Article 16 could deal with 10 MW units instead of 100 MW units. But as we don’t manage to get things done well regarding 100 MW units, how would we then manage to get accurate data for these smaller units?

I ask therefore in relation to the Transparency Platform:

  • would anyone expect to find a complete list of functioning generation units?
  • is data sent by TSOs to the platform based upon independent measurements or is it self‑reported by producers?
  • who checks the consistency of those reports?
  • how reliable therefore can any aggregation or global view be currently?

Currently, most of the generation units are shown in the actual generation per generation unit view but several are missing.

Sending corrections and requests to regulators, ACER, and even TSOs is such a difficult process, particularly to get in touch with the people in charge. Article 16 states that the TSOs are responsible for reporting production data but can they not delegate to producers sometimes? It begins with pointless answers like “it’s normal, mind your own business”, whatever, prior to digging a little more in to the details, and — only years after — to finally realize actual errors.

Specific issues

Three particular situations regarding production can be highlighted:

  • Compagnie Nationale du Rhône (CNR), the French operator in charge of Rhone river operations, including electricity generation with ~3.2 GW of run of river hydro installed capacity. The team did not comply with REMIT until very late 2021 (10 years after the REMIT legislation). Currently ENTSOE displays every CNR production unit (even those with no > 100 MW generation units) with no figures reported to to IIP nor themselves. Does anyone know which recent regulation forces them to do so please, instead of ignoring any production unit with no > 100 MW generator?
    Refer ENTSO‑E platform.

  • TotalEnergies Landivisiau gas power plant started operations at the beginning 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 have been sent, several times, and now only the very recent display of generation units on the ENTSO‑E platform (and only for REMIT messages for now), with no generation data. This is the only evidence I have seen that things are slowly improving.

  • 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 exceeding 100 MW.

At the same time, Axpo, another Swiss operator, got its generation units well integrated and production data reported on the ENTSO‑E platform (Limmern–Muttsee for instance). Thus, I cannot currently conclude that there may be specific regulatory rules that would apply to Swissgrid TSO that prevents them from reporting generation units operated by Alpiq. Refer ENTSO‑E platform. I have currently received no answer from Swissgrid, nor from Alpiq about that.

Closure

Such inconsistencies are very disappointing, regarding well‑known generation units that should not be missing from the outset. Consistency between generation unit knowledge and measurements should always be ensured. Especially regarding well characterized technical facilities. Waiting approximately 10 years for compliance with regulation represents an explicit data loss for material that is supposed to form our statutory reporting record.

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


Note Subsequently copy‑edited by @robbie.morrison for style and clarity and then confirmed by @flacombe.

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Am noting this somewhat old formal review:

An underlying survey asks:

  • Has data licensing prevented you from using the data for any purpose?

But there is no follow up on the responses or even the issue itself in the final report.

1 Like
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Deal all, good evening Robbie,

As of today, all involved actors have been upped at least once about raised concerns.

ENTSO-E, three times
ACER, once (one work week after the 15 working days delay promised in their automatic mailing responder)
Local TSO, countless up, pings, hits, screams, booo

What a pity…

Nothing to undermine my motivation to get a robust answer from them.

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Legal status of information served

I attended a by‑invitation workshop in Brussels recently and was able to ask the head of the Mediterranean Energy Regulators (MEDREG) association (website) about the legal status of the data they assemble and make public as a service — and they simply did not know.

Open energy systems modelers in Europe are clambering for legal clarity for this kind of information. And the response I got exactly sums up the situation we face: uncertainty as to whether this material — much of it published under statutory reporting requirements — is protected by the natural (automatic) intellectual property rights of copyright and database protection. Or not?

The exact same situation applies to the ENTSO‑E Transparency Platform. Indeed, I have private communications with their legal department that ENTSO‑E will not enforce 96/9/EC database protection but ENTSO‑E will not write that sentiment into the formal terms‑of‑use for the platform.