Less than 3 rule the way forward

1. Transparency in transport and storage systems Less than 3 rulethe way forward

2. Transparency in transport and storage systems • Proposed order of thinking • Example transport system • Proposed information at points where less than 3 rule applies • Information is for the benefit of achieving goals • Proposed way forward

3. 3-shipper rule in transport and storage facilitiesproposed order of thinking • For what purposes will the disclosed information be used • Select legitimate purposes (for market parties) • Support non-discriminatory access to transport and storage facilities • Support security of supply • What kind of information should be disclosed, given the selection of legitimate purposes? • Inventory of information that should be disclosed to the market • How can commercial confidential information be protected? • Application of less than 3 rule in case • Less than 3 users • Users have requested non-disclosure with system operator • Approval of national regulator for non-disclosure • Alternative handling of the information at points where the less than 3 rule applies

4. Example Less than 3 rule in transport system • Two situations where the goal of the information is to support non-discriminatory access to transport facilities: • Shipper who considers to buy firm transport capacity and who wants to optimize the timing of the purchase • If firm transport capacity is sold out and a shipper considers to buy interruptable transport capacity, the shipper needs to know the chance of interruption

5. Example Situation 1: shipper who considers to buy firm transport capacity • At a point where the less than 3 rule applies, one can: • Instead of disclosing maximum (technically available) capacity ánd booked transport capacity, only disclose the remaining free transport capacity and not disclose the number of shippers that are active at the point (this can be applied to all points in the network)

6. Example Situation 2: shipper considers to buy interruptable transport capacity • At a point where the less than 3 rule applies, one can: • Instead of showing the total history of flows, • Show only that part of historic flows that is needed to estimate the chance of interruption, such that no commercial confidential information is disclosed or • Let the TSO estimate the chance of interruption and disclose no information about history of flows

7. Information is for the benefit of achieving goals

8. Example: • Inventory of legitimate goals • Related to access to transport and storage facilities Support non-discriminatory access to transport facilities and security of supply Primary goal: support non-discriminatory access to transport facilities Prioritise goals Inventory of situations that require information Buy firm capacity Buy interruptable capacity • Inventory of best practices • (best way to achieve goals) • Quantitative information • Proces information • Information conditions Proposed way forward Take confidentiality issues into account Less than 3 rule Remaining free firm and interruptable capacity etc. NOT: Number of shippers Maximum available capacity Complete flow history Harmonisation / interoperability throughout the region Fixes …

9. Thank you