General Remarks. The Proposal is not sufficiently clear and described in such a way that All Regulatory Authorities are able to enforce it after approval on a national level. TSOs should write the Proposal in a legal format which is directly enforceable and legally sound, in that it should be possible to foresee how the methodologies will be applied. The Proposal includes a term already defined in legislation and then gives a different meaning to it. The term cross zonal capacity should be used in the meaning given to it in the Transparency regulation 543/2013 in Article 2(10) as ‘the capability of the interconnected system to accommodate energy transfer between bidding zones’. The Proposal furthermore contains articles describing tasks and responsibilities but using the passive voice. This can result in confusion as to who is responsible of performing a duty. TSOs should use the active voice as much as possible when describing tasks and responsibilities. Furthermore, reference to definitions or concepts used in other proposals, which have not been approved by All Regulatory Authorities at the time of submission, should be avoided. In addition, definitions should be consistent across proposals.
Appears in 3 contracts
Sources: Request for Amendment, Request for Amendment, Request for Amendment