Elering AS
AS “Augstsprieguma tīkls” Your ref: 01.08.2025
LITGRID AB Our Ref: 18.09.2025 nr 7-12/25-0193-306-
2
Copy:
The Public Utilities Commission
National Energy Regulatory Council
Document is forwarded by e-mail to
[email protected],
[email protected],
[email protected],
[email protected],
[email protected]
Regarding reporting on the Baltic Balancing Capacity Market
Dear representatives of the Baltic Transmission System Operators,
The Baltic National Regulatory Authorities1 (NRAs) have received a letter from the Baltic
Transmission System Operators2 (TSOs) dated 1 August 2025 regarding reporting on the Baltic
Balancing Capacity Market.
Pursuant to Article 12(8) of the methodology for the market-based allocation process of cross-
zonal capacity for the exchange of balancing capacity for the Baltic CCR in accordance with
Article 41(1) of the Commission Regulation (EU) 2017/2195 of 23 November 2017
establishing a guideline on electricity balancing (EBGL) (MBCZCA methodology), the TSOs
are required to submit, by six months after the go-live of the market-based allocation process,
a report, to the relevant regulatory authorities.
Pursuant to Article 14(2) of the Baltic balancing capacity market (BBCM) design principles, in
accordance with Article 33(1) and Article 38(1) of the EBGL, the Baltic TSOs, by six months
after the go-live of the Baltic balancing capacity market and subsequently at least once a year,
shall publish and submit information to the relevant regulatory authorities about the volumes
and usage of demand reduction resources and back-up resources.
In the respective letter, the TSOs emphasize that they have encountered significant hurdles and
have found it impossible to provide the reports referred to above to the Baltic CCR NRAs in a
timely manner. The Baltic TSOs indicate that they deeply regret not being able to provide the
reports referred to above to the Baltic CCR NRAs in a timely manner, and they further indicate
that they will be able to submit these reports by 31 October 2025 at the latest.
The letter from the Baltic TSOs informs the Baltic NRAs that, although the deadline for the
submission of the above-mentioned reports was August 2025, the Baltic TSOs wish to request
an exemption from the Baltic NRAs to extend the deadline for submitting the respective reports
until 31 October 2025 at the latest.
1
Estonian Competition Authority, The Public Utilities Commission, National Energy Regulatory Council
2
Elering AS, AS “Augstsprieguma tīkls”, LITGRID AB
Tatari 39 / 10134 Tallinn / ESTONIA / Registry number 70000303
Phone: +372 667 2400 / E-mail:
[email protected]
Although the Baltic NRAs understand the reasons put forward by the Baltic TSOs for not being
able to submit the reports on time, we would like to draw attention to the fact that the MBCZCA
methodology is a CCR-wide methodology approved by all NRAs of the Baltic CCR.
Furthermore, since the derogation request related to the MBCZCA methodology contained in
the Baltic TSOs’ letter is addressed only to the Baltic NRAs, it follows that the Baltic NRAs
alone cannot grant such a derogation request concerning the MBCZCA methodology.
Therefore, the Baltic NRAs consider that, if the TSOs wish to initiate processes related to CCR-
wide methodologies, such as the MBCZCA methodology, any such requests must be addressed
to all NRAs of the Baltic CCR.
With regard to the report pursuant to Article 14(2) of the BBCM design principles, in
accordance with Articles 33(1) and 38(1) of the EBGL, and the exceptional extension of the
submission deadline to 31 October 2025, the Baltic NRAs acknowledge the significant hurdles
and justifications outlined in the Baltic TSOs’ letter. The Baltic NRAs therefore consider that,
as a one-off exception, it is justified to extend the deadline for submitting the aforementioned
report until 31 October 2025.
However, the Baltic NRAs wish to emphasize that this exceptional extension of the deadline
for this report does not affect the deadlines for future reports. If the first report is exceptionally
submitted by 31 October 2025, the deadline for the second report shall follow the methodology
and must be submitted no later than one year after the original deadline of the first report.
Accordingly, the deadline for the second report shall be August 2026 at the latest.
Sincerely,
On behalf of the Baltic NRAs
Estonian Competition Authority
The Public Utilities Commission
National Energy Regulatory Council
(digitally signed by)
Evelin Pärn-Lee
Director General
2 (2)