Current State of Intraday Markets in Europe May 2007

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1 Current State of Intraday Markets in Europe May 2007 ETSO Report: Current State of Intraday Markets in Europe Page 1 of 18

2 Contents 1. Introduction Objective and scope of this report Intraday markets Purpose of IntraDay Markets (IDM) Definition and scope of intraday markets Characteristics of internal intraday markets OTC Power Exchange-continuous trade Power Exchange-sessions Cross-border intraday capacity allocation First come, first served Pro-rata Auctions Combinations of intraday trading & allocation mechanisms Potential issues with intraday markets Open positions management Intraday cross-border capacity determination Cross-border capacity allocation Cross-border congestion management Internal congestion management Internal balancing reserve management Appendix 1 Examples of current intraday markets A1.1 Power Exchange Intraday markets A1.2 OTC intraday markets Appendix 2 Improved pro-rata allocation mechanism ETSO Report: Current State of Intraday Markets in Europe Page 2 of 18

3 1. Introduction 1.1 Objective and scope of this report The objective of ETSO report is to present an overview of current implementations of intraday markets in Europe. It highlights potential issues without providing solutions and provides the necessary basis for the next report that will cover harmonisation and integration issues regarding internal and cross-border intraday markets. ETSO Report: Current State of Intraday Markets in Europe Page 3 of 18

4 2. Intraday markets In this chapter the purpose of internal and cross border intraday markets is described and currently implemented methods for trading and allocation of cross border capacity in the intraday time frame are presented. Appendix 1 contains detailed information on examples of existing intraday arrangements in Europe. 2.1 Purpose of IntraDay Markets (IDM) For TSOs, the goal with intraday markets is to: facilitate new market segments under secure network conditions enable and encourage self-balancing of market parties in relation to an incentive compatible imbalance pricing scheme For market parties, the need for intraday markets arises from the following Internal IDM unforeseen events after Day Ahead Market (DAM) gate closure (for energy programs) induce the need for additional trade and a change of position after DAM gate closure (for energy programs) market parties that can have open positions or accidentally have them and want to cover for this rather than risk imbalance arbitrage Cross-border IDM all of the above plus cross-border optimisation of portfolio scheduling for multinational market players development of liquidity and competition on IDM (mitigation of market power) Relevance of IDM Even if volumes are rather small the importance of IDM in the light of these goals remains significant. 2.2 Definition and scope of intraday markets Intraday market is defined here as the possibility for transactions between market parties after gate closure of DAM and before final notification. The intraday market product is typically MWh/per period of time (this period can be one hour, one settlement period or a multiple of those). Final notification is the last moment in time where a market party is allowed to change the energy program which will form the basis of the imbalance calculation. The transaction period for the intraday market runs from day D-1 to day D. Typical relevant market milestones during this period are (in consecutive order): Preceding milestones for intraday market 1. Nomination of year and month (general non-day ahead) cross-border capacity 2. Allocation of day ahead cross-border capacity 3. Closure of organised DAM 4. Fixing of organised DAM results ETSO Report: Current State of Intraday Markets in Europe Page 4 of 18

5 5. Gate closure to send energy programs 1 to the TSO 6. Gate closure to send physical notifications 2 (on a nodal basis, also called transmission programs or generation schedules) to the TSO (typically for network security management purposes but sometimes also for identifying balancing needs) 7. Approval of energy programs and confirmation of expected day ahead network security by TSO (typically this marks the end of the DAM) Intraday market milestones 8. Determination of remaining cross-border capacity 9. Opening of intraday market: allow changes in energy programs 10. continuous trading or multiple trading sessions with update of remaining crossborder capacity 11. Closing of intraday market (typically 1 hour before time of operation, energy program changes no longer accepted) 12. Approval of energy programs and confirmation of expected network security by TSO However, not all countries within Europe will have all of these typical market milestones. For example within Great Britain's internal market all market participants can trade until gate closure when they are required to send final physical notification to the TSO. The GB TSO has no involvement in the market (other than as a participant) until this gate closure (1 ½ hours before real time). Note: for settlement purposes some TSOs allow after the fact program changes, but only if this involves exchange of imbalances between market parties in order to level out their mutual imbalances within one control zone Characteristics of internal intraday markets During the intraday market period, trade can take place through several different mechanisms as Over The Counter (OTC), Power exchange (PX) continuous trade, PX sessions, etc. Typically these are as described below OTC The phrase over-the-counter (OTC) refers to transactions that are either concluded directly between two traders or run via a dealer network as opposed to on a centralised exchange. OTC trade leads to bilateral transactions between two known parties with the possibility of non-standard products. Typically these transactions require energy program changes from both parties involved before they can take effect. OTC intraday trade is for example implemented in Switzerland, Great Britain, the Netherlands, Germany, France, Austria and Sweden. For example not implemented at this time in : Denmark, Italy, Norway, Poland, Spain Power Exchange-continuous trade Typically this refers to anonymous trade via a bulletin board like system executed by a central exchange where standard products are traded on a first come first serve basis: 1 2 Energy programs are used by the TSO to check the net balance position of the market in order to manage the balance Physical notifications are used by the TSO to check expected network flows and network security ETSO Report: Current State of Intraday Markets in Europe Page 5 of 18

6 the first matching offer to a bid (or vice versa) is rewarded and fixed into two bilateral transactions offerer (seller) - PX and PX - bidder (buyer). One difference with a bulletin board system is that the trade is anonymous and that typically only standard products can be traded. For example this is implemented in Great Britain, the Netherlands, Sweden, Finland, Eastern Denmark and Germany Power Exchange-sessions This refers to a repeating of the power exchange DAM session on one or more moments during the intraday time period, although the product traded may be different (it can be MWh per settlement period rather than MWh per hour). Each session has a gate opening and gate closing time as well as a fixing time and a different time of delivery scope. For example this is implemented in Spain. 2.4 Cross-border intraday capacity allocation If intraday change of position (energy program change) is allowed in markets on both sides of a border and transmission capacity between those markets is available then intraday cross-border trade is possible. Further prerequisites for cross-border intraday trade are the possibility to procure the transmission capacity and nominate the underlying energy program. Current practice, with the exception of PX IDM sessions, is that transmission capacity available after nomination of day-ahead capacity, is most frequently made available to the market free of charge. Several cross border intra-day allocation mechanisms exist in Europe as described below. Each of these can be implemented as a one or two stages process: two stages process: the TSO allocates an option on capacity to the requesting market participants, who later on nominate the capacity within the allocated capacity ( allocation of options ) one stage process: the allocation and nomination of capacity is made in one step ( allocation of obligations ) In both cases the nomination is normally binding, which allows for netting at the time of nomination. From the point of view of the market participants in case of a cross border OTC trade the cross border allocation and nomination is handled by the market players themselves. For PX based trade it is instead handled by the PX s behind the back of the market participants. In the following chapters the presently implemented allocation principles used by the TSO s are described. For generality there is no distinction between OTC and PX trade and the term market participant can either mean a trader or PX First come, first served Following this principle, market participants have to announce to the TSOs their interest in using intra-day capacity which is still available on a continuous basis. TSOs then verify whether the capacity requests can be fulfilled. If this is the case, the requesting market participants obtain the capacity, in the sequential order of requests, until there is no available capacity left. ETSO Report: Current State of Intraday Markets in Europe Page 6 of 18

7 2.4.2 Pro-rata The usual pro-rata method allocates capacity to each market participant pro rata to the requested volume at a number of defined gate closures. The number of gates is limited by the operational process and by the time needed by market participants who have acquired capacity to negotiate trades. A modification of this method is pro-rata to the requested volume and to the number of participants in order to favour the smaller demands (see the example in Appendix 2) Auctions This allocation mechanism is based on the normal principles of explicit auctions. According to the timing of the allocation process (auctions preparation, auction running time (not less than 30 minutes), publication and communication of results ), and the time requested for negotiation of trade once the capacity has been allocated, the possible number of auctions is limited. 2.5 Combinations of intraday trading & allocation mechanisms Table 1 shows combinations of the trading mechanisms and the main allocations principles described above which are actually in use. In principle all combinations are feasible although not equally obvious. E.g. the most reasonable allocation for PX continuous trade is first-come-first-served while for PX sessions it is auctions. Table 1: Existing combinations of trading and allocation mechanisms First come, first serve (A) Pro-rata (B) Auctions (C) (1) OTC Yes (1A) Yes (1B) Yes (1C) (2) PX continuous trade Yes (2A)? (2B)? (2C) (3) PX sessions? (3A)? (3B) Yes (3C) Examples of actually combinations are described below. They are indicated in the table with a "Yes" plus a reference in brackets. Question marks in the table indicate possibilities not currently implemented. Case 1A: OTC and FCFS This combination is used - on the border between Switzerland/Austria using allocation of options - on the borders between Germany/France (Germany side) and Germany/Switzerland using allocation of obligations. Case 1B: OTC and Pro-rata This combination is used on the French side of borders between France/Germany, France/Switzerland and in the near future France/Belgium, with gate closure every 2 hours. ETSO Report: Current State of Intraday Markets in Europe Page 7 of 18

8 Case 1C: OTC and Auctions This combination is used on the French side of the border France/Spain using allocation of options. Case 2A: PX continuous/otc and FCFS This allocation of obligations is used within Nordel and on the border between Eastern Denmark Germany In this case the system works in the following way trading is anonymous and continuous, and after 2 pm trading is possible during all hours of the actual and the next day until 1 hour before real time. Market participants put their bids/offers for energy on the continuous trading platform. Players in area A can only see bids from area B if there is sufficient capacity between the areas and vice versa when an offer and a bid match, bilateral trades occurs between seller/px and between buyer/px and results in an intra-day cross border exchange. The equivalent capacity is implicitly allocated and nominated by the PX to the two concerned TSOs, which update the remaining available capacity in order that the process goes on So far in Nordel no competing OTC trade and no competing PX s exist. A combination with 1A is however also possible. Case 3C: PX sessions and auctions This combination is used on the Spanish side of the border France/Spain using allocation of options. ETSO Report: Current State of Intraday Markets in Europe Page 8 of 18

9 3. Potential issues with intraday markets Significant changes in physical positions induced by IDM may complicate the process of balance management and network security management and require a major change in TSO operational processes.the following sections highlight some issues that may become important. The importance of these issues and the conclusions will be elaborated in the next report. 3.1 Open positions management An open position of a market party is a situation where the net of selling and buying commitments towards other market parties is not equal to the net of generation of his suppliers and demand of his customers. If open positions after DAM fixing are allowed, then market parties may use this possibility to wait and see if business opportunities improve in the intraday market (arbitrage). Especially if cross-border trade is possible in both DAM and IDM domain and intraday transmission capacity is free of charge this might happen. This could highly complicate the calculation of available capacities since the network usage is only partially known and additional usage will occur and raises the question if network security can still be guaranteed under these circumstances. With closed positions at DAM gate closure for energy programs, this additional usage will only be marginal and available capacities can be calculated with less reliability margin while if open position are allowed additional usage will include arbitrage as well which will necessitate a higher reliability margin. Open positions may also require an increase of balancing reserves by the TSO to ensure the physical offer/demand equilibrium. 3.2 Intraday cross-border capacity determination TSOs determine how much energy can be exchanged before a network security constraint is violated under any of the expected origin/destination scenarios. Neighbouring TSOs agree on a common determination process. The issue is to continuously improve the cooperation in order to maximize the available capacity. Due to the dynamic of the market and the operating conditions the available capacity is dynamic and becomes firm as a result of the nomination process. Firmness is managed by the congestion management process. Firmness implies an economic risk for the TSOs. Managing this risk level can affect the available capacity. Last but not least there is the question about reservation of capacity for the intraday market and under which conditions such reservation can be considered. 3.3 Cross-border capacity allocation The choice for allocation of options or obligations can make a difference in terms of efficient use of available capacity. The pricing principle for intraday capacity is important: free of charge intraday capacity can have effect on the day ahead capacity price and also could change the incentives to have a day ahead closed position. This could have an impact on the management of network security. 3.4 Cross-border congestion management In general this is the process of determining cross-border capacity available to the market, allocation of this capacity to the market and any measures to maintain network ETSO Report: Current State of Intraday Markets in Europe Page 9 of 18

10 security within the restriction that the market can not use (nominate) more than what is allocated. The measures to control network security after nomination include crossborder countertrade, cross-border redispatch, and curtailment of nominated capacity (with or without commercial compensation). It is beyond the scope of this report to further describe these. Essentially the cross-border congestion management process for the intraday market is a copy of this: remaining capacity determination, remaining capacity allocation and network security control. Most important difference is the starting point (more information is known intra and the time before the operational hour (less time available in intra. 3.5 Internal congestion management Compared to cross-border congestion management internal congestion management is the process of managing congestions inside a network rather than between networks. After DAM fixing respectively DAM gate closure for energy programs TSOs need some time to check and fix the network security situation in accordance to the market results (it is beyond the scope of this taskforce to describe how this is done). After this is done the intraday market is opened and as a result of intraday trade the expected network situation may change. To control network security also for this process countertrade, redispatch as well as curtailment of physical nominations may apply. 3.6 Internal balancing reserve management This is the process of managing reserves in order to secure sufficient balancing resources for the operational hour. There are several ways to achieve this. a) through previous availability contracting (year to day ahead): the market has taken the commercial obligation to provide reserves with adequate incentives to keep this obligation b) through a continuous intraday reserve bidding process; The market makes bids for operational reserves to the TSO which can continuously be changed in size and price until shortly before the operational settlement period c) a combination of a) and b) where the availability contract implies the obligation to bid a certain volume in the intraday reserve bidding process d) through intraday generation rescheduling. This requires some kind of central dispatch. Part or whole of these processes take place in the intraday time frame and therefore interfere with the intraday market processes. Verification processes are sometimes in place to check physical availability. These verification processes are especially required in case of availability contracting with capacity payments. Due to changes in physical positions the reserve requirements may change (example: largest running unit changes in size). Finally, when cross-border trade becomes possible, remaining reserve capacity may get sold across the border. This will have consequences for the reserve management. ETSO Report: Current State of Intraday Markets in Europe Page 10 of 18

11 Appendix 1 Examples of current intraday markets A1.1 Power Exchange Intraday markets Country AT CH DK-E, SE, FI, DE Which entity(ies)/company(ies) is(are) responsible for IDM trading platform (matching service of bids and offers)? And for IDM trade settlement? Does exist a fee for the matching service (not the clearing price)? Specify what kind of fee. Is IDM integrated crossborder? - - Power Exchange Nord Pool Spot - IDM Market called Elbas - - Power Exchange (NPS) DK- W - Power Exchange (EEX) (since ) - Power Exchange (EEX) - - YES - see below - EEX: participation fee EUR p.a.; 0,09 EUR/MWh ( ) plus yearly technical fee. - - YES - Finland, Sweden, Germany DE ES FR GB NL Power Exchange (OMEL) Power Exchange (Powernext) has announced opening in June 2007 APX provides the GB market with intraday services APX provides NL only intraday services, not responsible for IDM trading as a whole Power Exchange (OMEL) - see OTC Power Exchange (APX) NO - see OTC yes, transaction fee of 0.14 /MWh of volume matched, 0.07 /MWh for strips, access and membership fee included with APX membership - NO NO NO see OTC NO Is divided in sessions or it - - continous - continous DIVIDED IN SESSIONS - see OTC continuous trading is a continuous trading? Number of sesions see OTC NA Types of Intraday Market Participants - - BRP s - BRPs Generators, Interconnector users, Distribution companies, Qualified Consumers, Suppliers - see OTC All ETSO Report: Current State of Intraday Markets in Europe Page 11 of 18

12 Country AT CH DK-E, SE, FI, DE Is cross-border IDM trading possible? What is the product traded? MWh/hour, MWh/half hour, MWh /quarter hour, other. If other, specify which one What is the imbalance settlement period in your system? Hour, Half hour, Quarter hour. If other, specify which one. Do you have to specify location of bids/offers within bidding area? Pricing mechanism (marginal /pay as bid/else specify) Does any kind of cap price exist in IDM Market? What kind? (upper and lower caps) DK- W DE ES FR GB NL - - YES - NO YES - see OTC NO (not yet) - - MWh/hour (hourly bids + block bids for several hours) - MWh/hour MWh / hour - see OTC MWh/imbalance settlement period and "strips" hour - 1 /4 hour 1 hour - see OTC 15 minutes - - NO (bidding areas equal to Elspot intraday market) - NO PROGRAMMING UNIT - see OTC NA - - Pay as bid - pay as bid MARGINAL - see OTC MARGINAL - - NO - NO YES Bids offers must not be higher than 180 Euros / MWh - see OTC YES, lower bound cap only (all prices must be 0.01 /MWh) Main IDM gates s1 s2 s3 s4 s5 s6 - see OTC continuous trading Gate Closure to submit bids from IDM Markets to PX Market Communication results of matching process - - Continuos trade for D+1 opens at 2 pm (8 am in VET-area) and closes 1 hour before delivery hour - - PX to TSO after end of each hour (two times pr. - continous trading 17:45 (d-1 - NO 18:30 (d-1 21:45 (d-1 22:30 (d-1 1:45 (d 2:30 (d 4:45 (d 5:30 (d 8:45 (d 9:30 (d 12:45 (d 13:30 (d - see OTC continuous trade: 7h30-18h00 same day delivery trade, 12h00-18h00, next day delivery trade - see OTC continuous trade ETSO Report: Current State of Intraday Markets in Europe Page 12 of 18

13 Country AT CH DK-E, SE, FI, DE DK- W hour for E-DK and VET area) Energy Delivered period hour - as required H21(d- 1) - H24 (d) Time between Gate Closure and Start of Energy Delivered Period How is information related to physical position after IDM processes given to the TSO? Is there any kind of nomination process? Which is the Congestion Management procedure currently in use for IDM? (internal and cross-border) Amount of MWh/day traded in PX IDM hour - 1 hour 2h 15 min - - PX submit information and players submit changed programs to TSO. Nomination on interconnectors between bidding areas - - Dynamic market splitting; trades & capacities updated every 30 seconds. Already agreed trade guaranteed by TSO s, if necessary using countertrade. - - Only app. 1 TWh in 2005 compared to NPS DE ES FR GB NL H1- H24 2h 15 min H5- H24 2h 15 min H8- H24 2h 15 min H12- H24 2h 15 min - nomination Power Exhange (OMEL) and Intraday Market Participants must communicate this information to the TSO after matching process H16- H24 2h 15 min - NONE France-Spain interconnection: explicit auctions for the acquisition of intraday crossborder capacity and countertrading to guarantee the programs in case of capacity reductions in real time. Other Spanish interconnections: implicit auction without payment for the allocation of intraday capacities and modifications of programs in case of capacity reductions in real time - 2 GWh/day (<1 % of DAM trade) 57 GWh/day traded in IDM (9% of energy traded in Daily Market) - see OTC Q33 (d) - Q96 (d+1), Q=quarter hour period - see OTC > 90 min - see OTC all parties involved submit changed programs to TSO. For each transaction this involves 3 parties. No nomination process - see OTC Countertrade by TSO or DSO, followed by market restrictions, or bilateral contracts - small ETSO Report: Current State of Intraday Markets in Europe Page 13 of 18

14 Country AT CH DK-E, SE, FI, DE Do you foresee any major change/improvement in the way the intraday market is managed for example in the light of the new CM guideline requirement (2008)? DK- W day-ahead of 175 TWh. Turnover increased after introduction in Germany in september NO ELBAS per early april 2007 DE ES FR GB NL Comment: Elbas is introduced in VET area and will be expanded to all 4 TSOs in april see OTC NO A1.2 OTC intraday markets Country AT CH DK DE ES FR (internal) Which entity(ies)/company(ies) is(are) responsible for IDM trading? Does exist a fee for the matching service (not the clearing price)? Specify what kind of fee. market parties Imp/Exp: APG not specifically for IDM FR (crossborder) each BRP - each BRP - Bilateral Transactio ns I/E declared to RTE NO - NO - Yes (monthly per couple of Parties) Yes for capacity allocation, but set to 0 GB 1),2) Brokers, bilateral contracts/trad es Trading fees will apply. The type of product and mechanism with NL market parties NA ETSO Report: Current State of Intraday Markets in Europe Page 14 of 18

15 Country AT CH DK DE ES FR (internal) Is IDM process coordinated with another(s) country? NO internal: NO; CB: YES FR (crossborder) - NO - - ID access to Intercos with : GB, D, Sp, CH GB 1),2) determine the fee There is no co-ordinated / centralised market. However parties can participate across Interconnector s subject to the reservation of capacity secured day ahead. NL NO (internal only) Is divided in sessions or it continous continuous - continous - sessions sessions Continuous is a continuous trading? Number of sesions N/A NA Types of Intraday Market Participants Is cross-border IDM trading possible? What is the product traded? MWh/hour, MWh/half hour, BRP BRPs - BRPs - BRP and Sites BRP Yes YES - YES 1) - No Yes Yes market participate to market participate subject to the reservation of interconnector capacity MWh/quarter hour MWh/quarterhour - MWh/quaterhou r All - MWh/half-hour MWh/hour MWH/hours but on the Continuous trading All NO all of these ETSO Report: Current State of Intraday Markets in Europe Page 15 of 18

16 Country AT CH DK DE ES FR (internal) MWh /quarter hour, other. If other, specify which one What is the settlement period in your system? Hour, Half hour, Quarter hour. If other, specify which one. Are generation offers / physical positions made portfolio or per programming unit? Programming unit = Each generator, consumer. Pricing mechanism (marginal /pay as bid) Does any kind of cap price exist in IM Market? What kind? Main IDM gates FR (crossborder) 1/4 hour 1/4 hour - 1/4 hour - half hour - portfolio / BRP per BRP - portfolio (per BRP) not required for OTC NO internal: until end of month external: 3/4 of an hour as OTC, not required as OTC, not required - not required for OTC - not required for OTC - NA - - NA - - No evening D-1; every 1 hour D 1 evening D-1; every 2 hours D Energy Delivered period 1/4 hour as required - as required - After GC From 2 hours after GC Time between Gate Closure and Start of Energy Delivered Period external: 3/4 of an hour Standard: 45 min before delivery; Powerplant and reserve: 15 min before delivery - standard situation:45 min. before delivery outage situation: 15 min. before - 0 (but 2h for Generation changes) 2h GB 1),2) product basis 1/2 hour, 2 hours, 4 hours etc 1/2 hour Portfolio - Counter party basis Pay as bid NO NONE 1 1/2 hours before real time - at gate closure NL 15 minutes NA NA NA NA - ETSO Report: Current State of Intraday Markets in Europe Page 16 of 18

17 Country AT CH DK DE ES FR (internal) How is information related to physical position after IDM processes given to the TSO? Is there any kind of nomination process? Which is the Congestion Management procedure currently in use for IDM? Do you foreseen any major change/improvement in the way the intraday market is managed? delivery Nomination Nomination - nomination - Nomination by both Parties external: within NTC + first come - first serve internal: bilateral redispatch NO FR: gates&prorata; DE, AT: FCFS different projects are on the way FR (crossborder) nomination - FCFS Internal : hub Boundarie s : reductions; warranty on Fr/Spain OTC for DK-E and DK-W from november 2007 increasing number of borders with harmonised processes. 1) depending on the rules of the abroad area - Movement towards a regional organised IDM Movement towards a regional organised IDM GB 1),2) FPN - Final Physical Notification 1 hour NA National Grid is not responsible for the IDM YES, crossborder IDM 1 Does not include Northern Ireland 2 Please note National Grid as TSO has no role with the IDM - it is a true market which can be traded in various ways NL by changed programs (both parties have to submit a program change) or single sided transaction program (one party sends in for both) Countertrade by TSO or DSO, followed by market restrictions, or bilateral contracts YES cross-border IDM, movement towards a regional organised IDM ETSO Report: Current State of Intraday Markets in Europe Page 17 of 18

18 Appendix 2 Improved pro-rata allocation mechanism Example of the improved pro rata Input data: - Available capacity = 950 MW - Request participant 1 = 25 MW - Request participant 2 = 75 MW - Request participants 3, 4 and 5 = 500 MW The available capacity is divided by the number of participants (for the first iteration: 950 MW/5 = 190 MW) to determine the maximum capacity attributed to each participant after the first iteration. Each participant receives the minimum value between this limit and its request: the requests that are under this limit (participants 1 and 2) are immediately satisfied, whereas the others (participants 3 to 5) are satisfied only within the limit of 190 MW. Then, as the sum of the allocated capacities after the first iteration (670 MW) is less than the total available capacity, a second iteration takes place to allocate the rest of the capacity to the participants whose requests have not been completely satisfied yet, and so on until the whole capacity is allocated. Available Capacity Number of participants Maximum Capacity attributed Request 1st iteration 2nd iteration 3rd iteration 950 ( ) = ( ) 280 = Allocated Capacity Allocated Capacity Allocated Capacity Total of the Allocated Capacity Participant Participant Participant Participant Participant Total ETSO Report: Current State of Intraday Markets in Europe Page 18 of 18

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