Following the opening of the public debate on ANRE’s Regulations Schedule for the period 2020-2022, the Intelligent Energy Association has submitted to ANRE for analysis the following proposals:
- Drawing up and constantly updating (at least before the publication of the list of the regulations schedule) of a “Master Document Register” including all the regulations, technical codes, technical rules, methodologies etc. issued by ANRE and broken down by the three areas – electricity, natural gas, energy efficiency. Without such an updated “inventory” of the documents issued by ANRE it is impossible to manage and monitor the regulatory process and the frequency of amendments.
- The technical code of the gas sector must be brought back in discussion and update the terms and definitions used in the gas sector/harmonize them with the new legislation (for example: the definition of the technological consumption should not refer only to m³ of natural gas consumed by an operator, but to each quantity of energy consumed kWh – cm gas combustion, electricity used in the regulating and metering stations, cathodic protection stations, cathodic protection, fuel consumption…; another example: the NTS Network Code refers to “relevant NTS points” – a term that is not defined in the technical code or in the gas law).
- Regulation 62/2008 on the measurement of gas quantities – the deadlines for preparing the discussion document Q1.2020 and presentation in the Regulatory Committee Q2.2020 – justification: 1. the need to harmonize as soon as possible the requirements on the quality of gas transported in the NTS with the European standards (see EN 16726; differentiation of the quality of gas produced in various regional systems in order to optimize costs with investments in the treatment plants of producers; c. flexibility in defining the limit of the dew point by winter/summer season in order to reduce the operating expenses of gas producers).
We also propose an analysis of the construction of the legal framework ensuring a free and functional market, by:
1.1. Eliminating the regulated gas market.
1.2. Forcing gas producers/suppliers in Romania to publish Best practice guides on gas sales.
1.3. Supplementing the competition legislation and procedures for urgent investigation of anticompetitive practices
1.4. Best practice guide for the allocation of metered gas
1.5. Introducing the notion of daily booked capacity in the existing points on the entire chain production-transmission-distribution
1.6. Rewriting the Transmission Network Code
1.7. The Distribution Network Code
1.8. The Storage Facilities Code
1.9. The Natural Gas Market Code
1.10. Introducing mechanisms to ensure flexibility and functionality of the market.
1.11. Developing cheap guarantee schemes
1.12. Computerization of gas market activity
1.13. Best practice code for licensed suppliers in supporting vulnerable customers
1.14. Legislative changes in order to reduce the number of vulnerable customers (prepayment of gas, flattening the monthly curve of gas payment).
1.15. Redesigning the system for the authorization of persons who are active in the field of design and construction
1.16. Conditioning multiple specializations at the level of the same person
1.17. Setting the incompatibility between the activity of design, verification and examination at the level of the same person
1.18. Obligation of examination by independent experts of works in the gas sector in conditions of opportunity, usefulness, feasibility, reliability, security, safety.
1.19. Rethinking the philosophy of design regulations
1.20. Rethinking the philosophy of performance standards
1.21. Rethinking the philosophy of distribution systems
1.22. Rules and regulations stimulating a re-engineering of the transmission system
1.23. Rules and regulations stimulating a re-engineering of the storage activity
1.24. Redesigning the philosophy of pricing methodologies
1.25. Supporting the establishment of the Gas Engineers Union, a professional entity responsible for the professional preparation, training, development and sanctioning
Translation from Romanian by Romaniascout.