The term 'countertrading' means a cross zonal exchange initiated by system operators between two bidding zones to relieve physical congestion (Article 2(13) of the Regulation on submission and publication of data in electricity markets and Article 2(27) of the Regulation (EU) 2019/943 of the European Parliament and of the Council of 5 June 2019 on the internal market for electricity (recast).
27 September 2022
ACER Decision No 13/2022 of 27 September 2022 on the Methodology for the Optimisation of Inter-Transmission System Operators Settlements related to Redispatching and Countertrading
ACER Decision 35/2020 on the Methodology for Coordinated Redispatching and Countertrading for the Core Capacity Calculation Region
ACER Decision 35/2020 on Core RDCT 35 - Annex I
ACER Decision 35/2020 on Core RDCT 35 - Annex Ia
ACER Decision 35/2020 on Core RDCT 35 - Annex II
According to the Core CCR TSOs’ proposal for the methodology for coordinated redispatching and countertrading in accordance with Article 35.1 of Commission Regulation (EU) 2015/1222 of 24 July 2015, “Core RD and CT Methodology” of 5 September 2018 countertrading means “a measure performed by one or several Transmission System Operators (TSOs) in one or several bidding zones in order to relieve physical congestions where the location of activated resources are not known within the bidding zone”.
Explanatory document to the above proposal explains, moreover, that in the case that upregulating and downregulating measures are countertrading, they are considered as a measure between at least two bidding zones with the objective to relieve physical congestions, where the precise generation or load pattern alteration is not pre-defined.
This measure is a market based-solution, where the cheapest bid is selected independently of the geographical location within the bidding zone.
By using countertrading resources, the relieving effect on the congestion must be ensured.
The EU Network Code on System Operation (Commission Regulation (EU) 2017/1485 of 2 August 2017 establishing a guideline on electricity transmission system operation (System Operation Guideline - SOGL)) in Article 55(c) lists countertrading among services provided by third parties, through procurement when applicable, that each TSO uses for ensuring the operational security of its control area.
Countertrading in the European Union Internal Electricity Market is part of the broader scope of remedial actions (see Article 22(1)(f) of the SOGL).
Countertrading can be prepared in different processes and in different timeframes, i.e. day-ahead, intraday and real-time (Explanatory document of 5 September 2018 to the proposal for the coordinated redispatching and countertrading methodology for Capacity Calculation Region Core in accordance with Article 35 of the Commission Regulation (EU) 2015/1222 of 24 July 2015 establishing a Guideline on Capacity Allocation and Congestion Management, p. 7).
The most prominent EU country when it comes to the volumes for 2015 for the internal and cross-border countertrading was Germany.
The respective numbers for Germany, according to the ACER/CEER Annual Report on the Results of Monitoring the Internal Electricity Markets in 2015 (September 2016, p. 27), were:
- volume (in GWh): internal 1,914, cross-border 412,
- overall cost (in thousand euros) - 26,316.
According to the Report of the Core TSOs of 13 December 2018 assessing the progressive coordination and harmonisation of mechanisms and agreements for redispatching and countertrading (in accordance with EU Regulation 1222/2015 article 35(3), Version for Public Consultation, p. 3) in the Core region, the impact of countertrading is not the same everywhere.
Some TSOs apply countertrading already for a long-time, whilst others only apply it occasionally or have developed non-costly remedial actions to solve their congestions.
Generally, the agreements and mechanisms used for countertrading are national, and they are often quite different due to historical reasons.
The Core TSOs consider the implementation of the requirements set out in the CACM Regulation (Regulation establishing a Guideline on Capacity Allocation and Congestion Management) as the next step.
Article 35 of the said CACM Regulation provides for some coordinated measures on countertrading.
According to the said provisions, within 16 months after the regulatory approval on Capacity Calculation Regions (CCRs), all TSOs in each CCR are required to develop a proposal for a common methodology for coordinated countertrading.
As the provisions stipulate, the said methodology "shall include actions of cross-border relevance and shall enable all TSOs in each capacity calculation region to effectively relieve physical congestion irrespective of whether the reasons for the physical congestion fall mainly outside their control area or not".
Each TSO must, moreover, abstain from unilateral or uncoordinated countertrading measures of cross-border relevance.
In accordance with Article 21(1)(b)(ii) of the CACM, the proposal for the common capacity calculation methodologies should include rules for avoiding undue discrimination between internal and cross-zonal exchanges to ensure compliance with point 1.7 of Annex I to Regulation (EC) No 714/2009.
According to Article 74(6) of the CACM, the common methodologies for the sharing of countertrading costs between TSOs must:
- ensure a fair distribution of costs and benefits between the TSOs involved,
- facilitate adherence to the general principles of congestion management under Article 16 of Regulation (EC) No 714/2009, and
- comply with the principles of transparency and non-discrimination.
The said issues are the subject of the ACER Recommendation No 2/2016 of 11.11.2016 on the common capacity calculation and redispatching and countertrading cost sharing methodologies.
When it comes to the Core CCR the TSOs submitted the above proposal on 5 September 2018 (Core CCR TSOs’ proposal for the methodology for coordinated redispatching and countertrading in accordance with Article 35.1 of Commission Regulation (EU) 2015/1222 of 24 July 2015, “Core RD and CT Methodology” - see link in the documentation section).
The methodologies at issue must be seen in the context of a minimum binding level of capacity for cross-zonal trade at the level of 70% (as from 1 January 2020) stipulated in Article 16(8) of the Regulation (EU) 2019/943 on the internal market for electricity (Recast Electricity Market Regulation).
ACER’s recommends to “[u]rgently adopt and implement regional methodologies for coordination of redispatching and countertrading (and related cost-sharing) as an absolute prerequisite to meet the 70% minimum target” (ACER Market Monitoring Report 2019 – Electricity Wholesale Markets Volume, 21.10.2020, p. 14).