7) ex-post information for the previous week on the filling rate of the water reservoir and hydro storage plants in aggregated form (MWh) per bidding area on the third working day of the W+1. A comparison to the value of the year before must also be given. This is to be published for each bidding area only in countries with more than 10% feed-in of this type of generation per year or for bidding areas with more than 30% feed-in of this type of generation per year. The primary owners of this data are generating units;

8) actual unit by unit generation output (MW) detailed per generation unit of each production unit equal to or greater than 100 MW installed generation capacity, updated every hour. The information shall be provided H+1. The primary owners of the data are generating units;

9) actual aggregated generation output per market time unit and per generation type, as defined in Annex 1, to be published H+1. Actual generation of wind and solar power (MWh) in each bidding area per each market time unit in countries with more than 1% feed-in of wind or solar power generation per year or for bidding areas with more than 5% feed-in of this type of generation per year, to be published H+2, updated if necessary on the basis of measured values. Smallscale generation might be estimated. The primary owners of the data are generating units.

10) ex-ante forecast of day-ahead generation (MWh) of wind power and solar power for each bidding area per each market time unit for the following day in countries with more than 1% feed-in of wind or solar power generation per year or for bidding areas with more than 5% feed-in of this type of generation per year. Information shall be published D-1 at the latest at 18h00. Update is required in case of changes. The primary owners of the data are generating units, TSOs or in some Member States central forecast bodies responsible for preparing the forecast.

As was stressed in other articles on this website, from an electricity producer point of view, the need to precisely identify the possible items on the “inside information’ list is absolute. Some clues follow from the Article 15(4) and (5) of the Regulation No 714/2009 which impose on the market participants the obligation to provide the transmission system operators with the relevant data, which the TSOs are obliged to publish. Considering the generation side the ‘relevant data’ listed by the Article 15(4) of the said Regulation are availability and actual use of generation, balancing power, reserve capacity. Also recital 19 in the preamble to the said Regulation enumerates precise information on ‘electricity generation, supply and demand including forecasts, network and interconnection capacity, flows and maintenance, balancing and reserve capacity’ as necessary to enable all market participants to assess the overall demand and supply situation and identify the reasons for movements in the wholesale price. Also Annex I to the Regulation (Guidelines on the Management and Allocation of Available Transfer Capacity of Interconnections Between National Systems) among the information that the TSOs are obliged to publish lists ex-ante information on planned outages and ex-post information for the previous day on planned and unplanned outages of generation units larger than 100 MW.

But besides certain particular transparency initiatives undertaken in a few Member States like Germany and France, at the current stage there is lacking (and urgently needed) the common, precise and, possibly, exhaustive list of data the electricity generators are required to disclose.
It appears that the above list prepared by the ERGEG could function as the preliminary and practical indicative tool for generators situated in Member States where the process for regulatory implementation of transparency requirements is not sufficiently advanced.

The issue of the compatibility with critical infrastructure protection and national security should not however be neglected. The importance of this problem has been noticed by ENTSO-E Response EC Public consultation on ERGEG Advice on Comitology Guidelines on Fundamental Electricity Data of 15 September 2011 in which European Transmission System Operators observed that the draft Transparency Guideline should take into account the need for compatibility with the Council Directive 2008/114/EC on the identification and designation of European critical infrastructures. This Directive requires taking caution when disclosing information related to critical infrastructure, which, if disclosed, could be used to plan and act with a view to causing disruption or destruction of critical infrastructure installations. Unit-based information is in many instances considered as “critical infrastructure information”, subject to particular protection and generally not publicly available in real time. This would support the publication of aggregated values close to real time and unit by unit data ex-post.

It appears that the difficult question of the weighing up the balance between the interests of the wholesale energy market transparency and the need for protection EU critical energy infrastructure has been leaved to the discretion of the each electricity generator taking the relevant decisions on its own responsibility.