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TAR NC Implementation Document – Second Edition September 2017

BINDING RESERVE PRICES

Responsibility: update of the reserve prices within the tariff period is subject to

NRA decision

Default date for annual yearly capacity auctions

As of 2018, the Amended CAM NC sets the default date of the annual yearly capacity

auction as the first Monday of July, and not the first Monday of March

 1)

. Rescheduling

from March to July should provide more time to gather the accurate information

needed for calculations required for publication.

ENTSOG believes that the timing of 30 days before the annual yearly auctions strikes

an appropriate balance between:

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Allowing network users enough time to plan their booking strategies;

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Providing enough time to enable tariff calculations that are as accurate as

possible, and that can consider forecast contracted capacity in conjunction

with estimates of under-/over-recovery from previous years.

Detrimental effect on revenue and cash flow

The TAR NC requires tariff calculations to set binding tariffs for IPs, and for non-IPs

where the CAM NC applies, prior to the annual yearly capacity auctions. Compared

to the current scenarios, transmission tariffs for IPs will be calculated a few months

in advance. Accelerating the calculation of tariffs will reduce their accuracy, exposing

the TSO to greater uncertainty regarding revenue recovery. In the recitals, the

TAR NC expresses the desire to minimise TSO exposure:

‘In order to promote stabil-

ity of transmission tariffs for network users, to foster financial stability and to avoid

detrimental effects on the revenue and cash flow positions of transmission system

operators, principles for revenue reconciliation should be set out.’

The sentence

covers TSOs functioning under all types of regulatory regimes, including price cap

and non-price cap regimes.

Binding reserve prices ‘for the subsequent gas year’ for

floating payable price approach

Under the floating payable price approach, the TAR NC foresees that the reserve

prices published in June for the annual yearly capacity auctions in July must be

binding for ‘the subsequent gas year’, meaning the gas year beginning in October of

the same calendar year as when the auction takes place. Further to stakeholder

feedback, ENTSOG notes that for the cases where the tariff period does not coincide

with the gas year, this TAR NC rule may result in binding reserve prices further than

the end of this gas year, i. e. until the end of the second tariff period starting within

such a gas year.

 1) See Article 11(4) of the Amended CAM NC.

ARTICLE 12(3)