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Storage discount conditional for storages connected to more than one market area

ACM has published a final decision implementing NC TAR on 24 April 2024. This has led to changes to the Dutch Tariff code, which will enter into force at 1 January 2025. As a consequence, for storage facilities that are connected to more than one market area both the discounted and the non-discounted tariff can be applicable. 

Change of TSC
According to article 6.D.7 of our general terms and conditions (TSC), we are entitled to amend our TSC to accommodate these changed legislation imposing obligations on GTS. We will add a new paragraph 5.1.4 to our TSC: Calculation of the amounts chargeable for storages connected to more than one market area.

Most important change: potential ex-post correction invoice
The new article 3.5, paragraph 4 of the Dutch Tariff Code states that the applicable tariff for storage facilities that are connected to more than one market area should be the non-discounted tariff.

The new article 3.5, paragraph 5 of the Tariff Code Gas states that by way of derogation, the storage discount can be applied if we and the storage system operator (SSO) for such a storage facility have concluded an agreement  which guarantees that the discount is only granted to the extent that the storage facility is used as gas storage (closed loop), and there is no transport of gas via the storage facility between directly connected systems as referred to in recital 4 in the preamble and Article 9 of NC-TAR.

We will apply the applicable storage discount on an ex-ante basis, as a default situation, only if we and the SSO have signed the agreement and the SSO meets the obligations as described in the agreement and the agreement has not been suspended and has not been terminated. In such a case the storage discount is applicable in case the send-in to the storage facility and the send-out of gas from the storage facility takes place within the same market area (closed loop).

Nevertheless, cross-border flows can occur, and these will be identified and administrated by the SSO. Cross border flow from the TTF side to the THE side will occur if, for a specific shipper, an entry allocation at THE side requires more gas from the THE Inventory than available in the THE Inventory. In such a case the remaining entry allocation(s) are deemed to be cross border flows and shall be sourced from the TTF Inventory and the SSO shall subtract the rest of the entry allocation(s) at the THE side from the TTF Inventory on an hourly basis. Mutatis mutandis for cross-border flow from the THE side to the TTF side.

The maximum hourly cross-border flow on a gas day will be defined as cross-border capacity. We will determine the cross-border capacity on a daily basis for each shipper by using the standardized flow report which will be sent by the SSO on a monthly basis.

In case we have identified cross border capacity or the SSO did not meet the obligations as described in the agreement, or the agreement has been suspended or has been terminated, the ex-ante applied discount should not have been granted. In such cases we will send a correction invoice to the shipper. Corrections will be applied for all gas days where cross-border capacity has been identified and for all days that the SSO did not meet the obligations as described in the agreement and for all days during a suspension of the agreement and for all days without the agreement.

 If the cross-border capacity was used to flow gas from the THE side to the TTF side, then we will use the firm entry day product as input for determining the amount chargeable. If the cross-border capacity was used to flow gas from the TTF side to the THE side, then we will use the firm exit day product as input for determining the amount chargeable.

Please find below a draft list of storages which are currently connected to more than one market area: TTF and THE.

Below you can read the draft article that we suggest to add to the TSC  with regards to this subject.

Draft article TSC 2025 File extension pdf File size 152 kB Date last updated 28 Jun 2024