Reporting of fundamental data for end customers with consumption > 600 GWh/year pursuant to Article (9)(2)(c) of Implementing Regulation (EU) No 1348/2014: “For these customers no nominations or re-nominations are available”.
Would you agree that in this case, regarding fundamental data reporting for the end consumers in Germany, the TSOs must report only allocation data, and shall not report any information about the nominations and the re-nominations, since the end consumers do not nominate/re-nominate capacity to the TSOs and such data is not available to the TSOs?
If it is TSOs position that reporting of “zero” values for nominations and re-nominations are not appropriate because this could lead to the assumption that a nomination with a value of 0 was given which is not true. In addition, this would fill up the databases of ACER with irrelevant data and lead to an unnecessary increase of the data volume of the messages. Therefore the TSOs believe that only allocation data should be reported.
Answer: If the nominations or re-nominations are not available to the TSOs, then there is no need to report nominations or re-nominations with “zero” value. Only allocation data should be reported.