ENTSO-E consultation on RR TSO’s proposal for 2nd amendment of IF for exchange of balancing energy from replacement reserves

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While Eurelectric welcomes the proposed amendments and their aim, Eureletric generally calls for a deeper harmonisation of articles in the Replacement Reserves Implementation Framework with the other implementation frameworks of the balancing platforms.

Concretely, we would like to see the same transparency requirements for elastic needs expressed in art. 3(4) and art. 13(1) of the mFRR implementation framework introduced in this one. Specifically given the analogy between the mFRR and RR processes firmly expressed in the explanatory framework of this consultation by ENTSO-E, we fail to understand the reason behind such differences in transparency requirements between the two platforms. 

The remainder of the document discusses our preferred way forward regarding the Art 13.5. 

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