Updates and Changes in HAR Review 2023
The HAR Review 2023 outlines updates regarding remuneration, changes in the 15 min MTU, and modifications in LTFBA rules. It addresses issues like decoupling remuneration, liability types, credit limits, auction specifications, and more. These adjustments aim to enhance the efficiency and effectiveness of the systems involved.
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HAR Review 2023 1 December 2022
HAR bi-annual update Explanatory note Changes implemented in the version for ACER Shadow Opinion 15 min MTU Remuneration in case of decoupling LTFBA changes General changes
15 min MTU A later change changes to 15 min MTU in DA was already tackled in this update of HAR in order to not initiate another HAR update before the Go-Live of 15 min MTU. The update to tackle the 15 min MTU in DA required few and small changes of the Harmonised Allocation Rules.
Remuneration in case of decoupling TSOs once again have a large need to stress the importance of the possibility to curtail the remuneration in case of the de-coupling in the DA. This has been reflected in article 49 of the revised Harmonised Allocation Rules.
LTFBA and general changes Topic Liability Type General / LTFBA Change Impact in the event of issues related to a LTFBA auction failing is significant. Liability regime needed to be amended to consider this. Credit Limit and collaterals + Bid submission LTFBA Review how bids are assessed and rejected due to insufficient credit limit and TSOs to assess if amount of credit limit required can be reduced. Note: Included as unsolved and open question for Shadow Opinion and PC Revision of changes in the auction evaluation gate extension. At least for the December auctions, when we have yearly and monthly ones, the previously defined timings planned with the LTCC group didnt match with the requirements in the HAR. Auction specification LTFBA Auction Results determination LTFBA Originally defined in the HLMD: Provisions needed for non-single BZ border auctions. In the SAP methodology/ allocation algorithm requirements the following was defined: Additional criteria, such as how to handle equally priced bids for a given auction affected by a combined constraint are defined in the HAR.
LTFBA and general changes Topic Type Change Return LTFBA Needed a reform of the suspension article in case of different scenarios and how capacity rights are canceled, especially in case of suspension due to sanction. Current wording is not sufficiently clear and leaves room for interpretation, especially for capacity which has already been bought and paid for. Sanctioning, suspension and unused LT capacity General Reason for cancelling auction LTFBA Added possibility of cancelling an auction due to incorrect offered capacity values. Needed to cover the case where a market participant is repeatedly in a payment incident and uses a bank guarantee and in such a case an MP may be asked to switch to use a cash deposit. Payment incidents General
LTFBA and general changes Topic Corporate Account Type General Change The corporate account used by market participants to pay for cash deposits (collateral) or allocated capacity must originate from an EU bank or from a bank in an area where JAO operates. Purpose is to minimize risks of transactions originating from third countries. Amendment article General Possibility to amend certain aspects of the HAR without requiring regulatory approval or a lighter approval process. Especially for cases which put at risk the ongoing operations. Applicability of the HAR General General remark that the HAR is in practice the hierarchical highest level of all the rules and other non-HAR rules must adapt the same changes to ensure non-discrimination and equal treatment of market participants across rules which are part of the same allocation platform. Need to introduce wording to ensure that this practice is also legally defendable. Termination of participation agreement due to inactivity General Possibility of one-sided termination of a participation agreement in the event of long-term inactivity of a market participant. References General Mistakes in current references. Need to be corrected but also propose that before ACER finalizes the HAR after accepting/rejecting changes, then a general review should be done to ensure that there are no mistakes. Process for Border Specific Annexes General HAR publication often delayed due to missing BSAs. BSAs should be available at the same time as HAR is finalized.
