67 / 272
TAR NC Implementation Document – Second Edition September 2017 |
67
Other than cases defined in Article 9(1) where storage facilities are connected to
more than one system and are used to compete with IPs, and further to feedback
from stakeholders, ENTSOG notes that TAR NC
obliges
to set the minimum tariff
discount for storage points. As per Article 9(2), it
allows
to set tariff discounts for
LNG regasification points and infrastructure aiming at removing gas supply isolation.
Storage facilities
When dealing with the topic of discounts, the TAR NC effectively distinguishes
between ‘regular’ storage facilities and storage facilities which allow for ‘cross-system’ use, which is explained below.
‘
Regular
’
storage facilities
: the TAR NC obliges a TSO/NRA to set a minimum
discount of 50% for points with ‘regular’ storage facilities but also allows for a great-
er discount. Following the feedback from stakeholders and through ACER, ENTSOG
highlights recital (4) of the TAR NC where it is indicated that minimum discounts aim
at ‘avoiding double charging’ and ‘acknowledge the general contribution of storage
facilities to system flexibility and security of supply’.
Storage facilities which allow for ‘cross-system’ use
: the TAR NC envisages an
exception from the rule mentioned above where a storage facility is also connected
to at least one other TSO or DSO ‘network’/‘system’. Such an exception is however
only valid ‘to the extent’ network users ‘use’ capacities at the storage facility to
‘compete’ with an IP. Therefore, ENTSOG notes the following aspects of such an
exception based on the feedback received from stakeholders and through ACER:
\\
The description of such a storage facility can be found both in recital (4) and
Article 9(1) of the TAR NC and is based on the terminology using ‘system’ and
‘network’. Recital (4) describes two cases: (1) a storage facility is connected to
transmission systems of at least two TSOs in ‘directly connected entry-exit sys-
tems’ that implies that TSOs within the same entry-exit system are not con-
cerned; and (2) a storage facility is connected to both a TSO and a DSO ‘system’
that implies that such a TSO and a DSO can be located within the same entry-
exit system or in different but directly connected entry-exit systems. Article 9(1)
uses a simpler wording and only referred to a storage facility being connected
to ‘more than one transmission or distribution network’. Therefore, the idea is
that there is a possibility for a ‘cross-system’ use of such storage facilities, be
that either cross-entry-exit system or cross-transmission-distribution system.
\\
The same storage facility can be used in two ways: as a ‘regular’ storage or to
transport gas between the systems. ‘To the extent’ implies that the default rule
of minimum 50% discount does not apply only to the capacity used to actually
transfer gas volumes ‘cross-system’. Undue administrative burden for involved
operators and customers should be avoided.
\\
The TAR NC wording ‘used’ means that the flows/use of capacities between
systems will have to be monitored by SSOs, and/or TSOs, and/or NRAs.
\\
In case of ‘cross-system’ use of such a storage facility, some TSOs reduce the
minimum discount for cross-system gas flows, and Annex F provides examples
of such an approach.
\\
The ‘competition’ evaluation should consider whether cross-system storage use
effectively competes with transport via an IP. The assessment of actual
competition between an IP and a storage facility that is connected to several
systems is not straightforward. Stakeholders suggested that ENTSOG should
refer to ‘simultaneous’ exit and entry nomination at exit-points-to/entry-points-
from storage facilities, or else to a threshold duration of maximum ‘one day’ in
order to conclude that such a storage facility is used as an IP product. Howev-
er, in ENTSOG’s view such a ‘timing’ indicator is not fully satisfactory as the only
indicator of competition. In ENTSOG’s opinion, what matters is the result, i. e.
the fact that an IP has been bypassed by using a storage facility.
As of September 2017, European TSOs currently apply various storage discounts,
as shown by the table below. Some MSs are not indicated in the table: Estonia,
Finland, Greece, Lithuania, Luxembourg and Slovenia have no gas storage facility,
Cyprus and Malta have no transmission system, and data is not available for Latvia.