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TAR NC Implementation Document – Second Edition September 2017
How to use the Chapter for non-transmission services
Chapter IV applies to transmission services by default, and therefore to transmission
services revenue and transmission tariffs. All the rules of the Chapter ‘work’ only for
one part of the TSO services.
However, Article 17(3) provides the option of extending such rules also to non-trans-
mission services,
‘mutatis mutandis’
. The TAR NC is silent on how exactly to custom-
ise the rules for extension to non-transmission services revenue. Instead, there is an
obligation – as part of the periodic consultation set out in Article 26 – to consult on
the way to reconcile non-transmission services revenue. In any case, the principles
established by Article 13 of the Gas Regulation apply.
As explained below, TSOs can have only one regulatory account. Following Article
17(3), these are possible approaches for non-transmission services reconciliation
that need further investigation:
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If the non-transmission services revenue is reconciled under the Chapter’s
rules, then the TSO must log the under-/over-recovery from such services onto
the one regulatory account. There are two suggestions:
–
–
One regulatory account should be split into sub-accounts for recording and
reconciling the under-/over-recovery from transmission services and, sepa-
rately, from non-transmission services. ‘Sub-accounts’ are an option under
Article 30(1)(b)(vi) where and to the extent that the TSO functions under a
non-price cap regime.
–
–
One regulatory account is used for recording and reconciling together the
under-/over-recovery from transmission services and from non-transmission
services. This is the current approach in Germany and in France.
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In case the non-transmission services revenue is reconciled pursuant to other
rules than under the Chapter, the under-/over-recovery from such services may
be logged on to some other account than ‘one regulatory account’. Great Britain
currently follows this approach.
The approaches described above are ENTSOG’s examples of what could be done.
The NRA must decide how to reconcile non-transmission services revenue in a
given system. Article 19(2) permits the NRA to enact
‘other rules’
in accordance with
the Gas Directive.
UNDER-/OVER-RECOVERY
Responsibility: no implications for TSO/NRA responsibility
Article 18 addresses under-/over-recovery of the value of the allowed revenue for a
given tariff period. The under-/over-recovery is calculated not for all the TSO’s
allowed revenue but only for the portion corresponding to the provision of transmis-
sion services.
The under-/over-recovery is the difference between: (1) the amount R which repre-
sents the allowed transmission services revenue; and (2) the amount R
A
which is
actually collected revenue by the TSO. Both R and R
A
must relate to the same tariff
period. If the difference R
A
–R is positive, there is an over-recovery. If the difference
is negative, there is an under-recovery.
When calculating the under-/over-recovery of a given TSO, the ITC payments have
to be taken into account in multi-TSO entry-exit systems within a MS.
ARTICLE 18