Shippers in the Danish gas transmission system and other stakeholders For Public Consultation: Tariff principles and market design in a Baltic Pipe1 Open Season 1. 1.1 2nd November 2016 FSK/JFS Disclaimers Disclaimer from Energinet.dk While the public consultation refers to time schedules and cost indicators adopted from the joint Energinet.dk and GAZ-SYSTEM PCI Baltic Pipe Feasibility Study (2016), the proposals and views express exclusively the position of Energinet.dk. Market design and tariff principles conform to common European process towards harmonised tariff structures and their aim among others is to support the feasibility of the proposed project. However, it is proposals exclusively directed at the future regulation of Energinet.dk’s transmission system presented to the Danish Energy Regulatory Authority. The principles do not reflect a common or otherwise shared Danish-Polish market design or tariff methodology. 1.2 Disclaimer from GAZ-SYSTEM S.A Please note that the present paper does not foresee any of the conclusions of the joint feasibility study prepared by GAZ-SYSTEM S.A. and Energinet.dk with respect to the socio-economic or technical feasibility of the project. This means that the assumptions and results of the analyses may change significantly. Moreover GAZ-SYSTEM S.A. has not been an author of this document as it only presents the Danish market perspective of the NO-DK-PL project. The discussion between TSOs and NRAs in Denmark and in Poland has not been finalized prior to the presentation of this document. 1.3 General disclaimer The cost allocation of the Zealand CS between the Danish and Polish tariff cost bases is not finally settled. The cost allocation is being discussed between the two TSOs and NRAs in Denmark and Poland. 1 Please remark that in this paper the total Baltic Pipe project refers to the project also knows as NO-DK-PL project Dok. 15/11929-11 1/19 2. 2.1 Background, purpose and résumé Background and purpose Energinet.dk and GAZ-SYSTEM S.A, state-owned transmission system operators in Denmark and in Poland respectively, jointly analyse the feasibility of a proposed new transit infrastructure connecting Norwegian gas fields with Polish consumers via a tie-in to Norwegian offshore system as well as establishing a pipeline interconnection between Danish and Polish transmission systems with the aim of being in operation from October 2022 onwards. The joint PCI Baltic Pipe Feasibility Study is co-funded by the EU and is expected to be concluded by the end of year 2016. The Baltic Pipe interconnection is classified as a European Project of Common Interest (PCI) aiming at providing supply diversification and enhanced market interconnection between gas markets around the Baltic Sea and the adjacent countries, including Finland, Ukraine. In terms of new infrastructure, the project comprises four separate pipeline sections in a transit supply chain: 1. An upstream Norwegian-Danish tie-in connecting existing Norwegian export infrastructure with the Danish transmission system at Nybro 2. Expansion of onshore Danish transmission capacity through the existing transmission system to a new interconnection point towards the Baltic Pipe (Baltic Pipe IP), including a new compressor station aimed at increasing the transit capacity towards Poland 3. Construction of an offshore Baltic Pipe interconnector between Poland and Denmark through the Baltic Sea 4. Expansion of onshore Polish transmission capacity through a new and existing Northern-Central system to enable receiving volumes from Baltic Pipe. Infrastructure on Danish territory including the offshore tie-in is expected to be built and operated by Energinet.dk. Energinet.dk and GAZ-SYSTEM S.A. plan to conduct an Open Season process for the four sections in the transit chain during the first half of 2017. In the Open Season, future users of the pipeline are offered at least 15-years firm capacity contracts at selected points within a proposed joint Danish tariff zone, which includes new and existing infrastructure between an exit point from the Norwegian Gassled system to an interconnection point with Baltic Pipe. Capacity from Poland through Baltic Pipe to Denmark/Sweden is also made available under the Open Season, which will offer shippers the option to book import capacity to the Danish transmission system from either Norway or Poland. Participants in an Open Season will not be offered fixed price terms (tariffs). Tariffs realised during the contract period will be determined and regulated by the tariff methodologies in force at that time. These are conditions similar to Energinet.dk’s Open Season 2009 conditions, according to which shippers have existing long-term contracts for Ellund Entry capacity. See material from 2009 Dok. 15/11929-11 2/19 process here: http://energinet.dk/EN/GAS/Det-danske-gasmarked/Sider/OpenSeason.aspx In this paper, Energinet.dk presents the main principles for tariff structure and market zones in the Danish gas system, which will be proposed for approval by the Danish Energy Regulatory Authority (DERA) and implementation before October 2022. Any future tariff methodology is conditional on approval by DERA. The purpose is (1) to provide market participants with basic assumptions on tariff forecasting and capacity booking patterns for the valuation of Open Season bids, and (2) form the basis for dialogue with shippers and stakeholders on the Danish gas market as regard to market design, given a realisation of the project. The council of DERA is expected to discuss the principles for future market zones and a tariff structure on the Danish gas market before the Open Season is conducted. However, it should be noted that any tariff or market zone methodology revision will be subject to regulatory approval by the Danish Energy Regulatory Authority (DERA). Parallel to the current Open Season process, Energinet.dk will conduct a proposal for future tariff methodology in Denmark with the aim of ensuring compliance with the European tariff network code. The proposal will be made in a dialogue with market participants and stakeholders and is expected to be handled over to DERA in the third quarter of 2017 for approval in 2018 and implementation by October 2018. Energinet.dk will include in this process the tariff principles as described in this paper. Please note that the present paper does not foresee any of the conclusions of the joint feasibility study prepared by GAZ-SYSTEM S.A. and Energinet.dk with respect to the socio-economic or technical feasibility of the project. 2.2 Resumé The main proposals for future principles in the present paper are as follows: • A common entry point for the Norwegian-Danish tie-in in the North Sea and the Danish transmission system. Given the differences in regulation of offshore systems and transmission system operators, a common entry point will allow for a harmonisation of capacity products, balancing terms and tariff structures between the offshore and onshore part of the gas system in Denmark, and will further allow for cost-minimizing synergies for Energinet.dk (hence lower tariffs for customers), ie gas quality blending, reduced IT investments and joint operation of balancing • Uniform cost allocation of CAPEX and OPEX at points in the Danish transmission system. In Energinet.dk’s view, this is a fair, objective and transparent cost-allocation principle since the transit volumes from the Norwegian-Danish-Polish route will change the current flow prognosis significantly and imply a long-term contribution margin for the Danish gas system as a whole. Furthermore, Energinet.dk assess Dok. 15/11929-11 3/19 • • that uniform cost allocation is a requirement for a positive transit business case compare to other routes. Extension of uniform cost allocation of CAPEX and OPEX to the joint entry point in the North Sea. Based on the same reasoning as described above, Energinet.dk will propose socialisation of costs to include entry point(s) in the North Sea. However, such uniform allocation will apply on condition of compliance with regulation for upstream tariff setting Other tariff structure elements remain. The principal foundations in the current Danish tariff structure remain, ie allocation of yearly CAPEX/OPEX to capacity/volume tariffs respectively and exit points and separate security of supply tariff setting. Section 2 of this paper considers the proposed principles for harmonisation of market zones and the tariff structure. Section 3 describes the scenarios for CAPEX and OPEX of the Norwegian-Danish-Polish transit connection and the impact on the future Danish average tariff level. Section 4 includes scenarios for the tariff setting distributed on entry/exit points based on different cost allocation principles. 3. 3.1 Proposed principles Creating a common Danish market zone Creating a seamless interface between upstream offshore and downstream onshore infrastructure is a long-term objective with Energinet.dk. The objective is to ensure equal access for imported and domestically produced gas as well as to attract volumes to the Danish gas market - thereby increasing liquidity and competition. Energinet.dk aims at increasing market zones nationally and towards adjacent systems. Market zones appear to be favoured by the market players and are a logical extension of a common European reform process towards an internal gas market consisting of national markets operating under closely harmonised principles. Today, the upstream infrastructure on the Danish shelf contains several entry and exit points, with Tyra and Syd Arne being the main delivery points. This paper solely describes principles to be applied for a merger of the NorwegianDanish tie-in with the onshore Danish transmission system. However, the principles may be applied to a market zone with one common entry point for the Danish North Sea. Creating a common Danish market zone stands to improve the commercial attractiveness and viability of the total Baltic Pipe project: • Reduces risk of capacity mismatch • Removes the need for multiple capacity contracts entered with independent system operators in a coherent transportation chain • Minimising costs (and hence the tariff level) through synergies in IT systems for capacity booking and billing, joint operation of the balancing system and administrative tasks. Dok. 15/11929-11 4/19 A common market zone could be achieved by moving the entry point into the transmission system offshore to the Norwegian-Danish tie-in. This will effectively substitute the need for shippers to make an entry/exit capacity booking upstream and an entry/exit booking in the transmission system with one entrycapacity booking and one exit-capacity booking (or a transfer of gas at the GTF or EFT point). Such a common market zone is illustrated below: Overall, in a common market zone there will be a list of subjects that are common, and a list of subjects that are separate. This is illustrated below: In this model, gas flows will still be metered at the tie-in and at the current Nybro entry point, allowing for separation of accounts between upstream offshore activities and onshore transmission activities. With a uniform cost-allocation principle as described in the section below, a common market model can imply that costs (both CAPEX and OPEX) are distributed equally to all entry points including the Norwegian-Danish tie-in in the North Sea. Dok. 15/11929-11 5/19 Given the difference in regulation of upstream infrastructure and the transmission system, Energinet.dk proposes to seek the fullest possible system integration between offshore and onshore systems including socialising costs and removing Nybro Entry as a separate interconnection point. The justification for this proposal is provided in the following analyses, which include the impact on resulting tariffs, contribution margins (and risk) from the proposed project and the enterprise models that can achieve the set objectives. The proposal is conditional on the regulatory feasibility, given the difference between upstream infrastructure and transmission systems. The illustration below shows the main characteristics of the upstream and downstream regulation. The definition of upstream infrastructure is given in the Danish Natural Gas Act (Naturgasforsyningsloven), subsection 1 of section 6. The rules for access is given in the Danish Upstream Regulation (Opstrømsbekendtgørelsen) issued in accordance with section 21 of the Danish Natural Gas Act (Naturgasforsyningsloven). There is negotiated access to the upstream infrastructure, which means that prices and conditions are set according to negotiation in a non-discriminatory way. DERA supervises that prices and conditions for access are fair (Danish: Rimelige). According to Danish law governing Energinet.dk’s activities (Lov om Energinet.dk), Energinet.dk may operate upstream infrastructure assets under the condition that the activities are kept on a separate account from the transmission system operator activities in order to avoid cross-subsidisation and distortion of competition. The market zone and tariff structure methodology must at all times be compliant with the above regulation concerning the upstream part of the market zone. Dok. 15/11929-11 6/19 In Energinet.dk’s opinion, it is compliant with both upstream and TSO regulations to allow for one capacity booking giving access to both the upstream offshore and the transmission onshore system. Uniform cost allocation with full socialisation between onshore and offshore points will imply that the resulting tariffs be compliant with the Danish upstream regulation on tariffs (Opstrømsbekendtgørelsen) and the rules governing Energinet.dk (Lov om Energinet.dk). In case of non-compliance, the tariffs at the North Sea entry point must differ from the other points in the transmission system. 3.2 Socialised and uniform cost allocation If the total Baltic Pipe project is realised, the operation of the Danish transmission system could change drastically from servicing a domestic market to costeffectively utilising all excess capacity to service a significant transit flow. The impact on the unit cost of transportation from higher volumes, if the project is realized, will significantly lower the cost for all users through the system. There are potential transit revenues that may benefit all users. The project would also add significant costs to the transmission system cost base. Whereas long-term contracts with Open Season participants mitigate the major part of the economic risk, the remaining risk will be carried by future users of the transmission system together with the owner of the assets. The Tariff Principles deal with how the marginal costs of the project are allocated on new and existing points in the entry-exit system. Currently, under the principles applicable to differentiated capacity tariffs, capital costs (CAPEX) stemming from the infrastructure expansion at Ellund operational from year 2012 have been allocated to individual points in the system, whereas the major remaining CAPEX from other assets are uniformly allocated to all points. The total Baltic Pipe project differs from the historic case behind the Ellund import expansion (which was a case of substituting supplies), in that it brings significant additional volumes in transit to the system. Changing the costallocation between points is not a zero-sum game if the revision results in a significant increase in the use of the system. The analyses presented in chapters three and four of the present memo shows that transit volumes made possible by the project would more than recover the marginal cost of the infrastructure expansion. There is a potential contribution margin from transit revenues. Under the current cost allocation principles (differentiated tariffs), participants in the Open Season risk having to contribute to the majority of the costs of the existing system (proportional to a share of the transport volumes) in addition to all marginal costs. In the opinion of Energinet.dk, this is a disproportional burden placed on new transit customers that lacks justification since the tariffs are not increased, but rather decreased, as a result of the project. Additionally, differentiated tariffs Dok. 15/11929-11 7/19 may risk to jeopardising the entire project feasibility – as shown in the following chapters. Principle of socialising all CAPEX: Energinet.dk proposes to apply a principle of uniform tariffs as the basis for allocating costs. Uniform tariffs would mean that all project-related costs are fully socialised on all points/users, just as the contribution margin is socialised in terms of lower tariffs. Uniform tariffs are the same in all entry and exit points independent on route and end-destination. This was the principle in the Danish transmission system up until year 2012. Uniform tariffs in terms of a future Tariffs Network Code (TAR NC) are understood as a set of uniform entry tariffs and a set of uniform exit tariffs. That is due to an ex ante 50:50 entry-exit split of the cost base (half of the cost base is allocated to entry and exit tariffs respectively). Since more exit capacity is typically booked, the resulting set of exit tariffs is lower than the resulting entry tariffs. Uniform tariffs are not a default cost allocation principle in the current draft TAR NC. Capacity-weighted distance tariffs are the default principle against which other allocation principles are measured. However, capacity-weighted distance tariffs are not a mandatory principle. Instead, Member States are allowed to implement other allocation principles if these receive regulatory approval and if the difference to capacity-weighted tariffs is accounted for. Energinet.dk will publish a comparison to capacity-weighted distance tariffs as part of preparing a tariff methodology proposal to DERA. 4. Impact of Baltic Pipe on Danish transmission tariffs 4.1 Base-case and project-related volumes Energinet.dk publishes base case assumptions on, among other items, the projected flows in the gas transmission.2 These assumptions are utilised in socioeconomic project assessments as basis for investment decisions and long-term planning. The assumptions contain the projected demand for transmission together with expected supply sources (North Sea, imports via Germany and, increasingly, gas from renewable energy sources (RES)), which constitutes the reference case (0-reference) for evaluating the proposed total Baltic Pipe project. Flows in the 0-reference are decreasing over time as a result of increasing energy efficiency and gradual transition from fossil natural gas to RES parallel in Denmark and Sweden. Transit to Germany is conditional on production levels in the North Sea and is expected to be phased out in the period up until year 2025. 2 http://energinet.dk/EN/El/Udvikling-afelsystemet/Analyseforudsaetninger/Sider/default.aspx Dok. 15/11929-11 8/19 Transit from Norway to Poland could reach a very significant share of volumes in the Danish transmission system. If the project is realised, significant transit revenues would accompany cost of new infrastructure. It would also imply that Norwegian and Polish shippers could become key stakeholders in influencing the future tariff methodology. In the figure below, incremental transit capacity from the total Baltic Pipe project is 10 bcm/year with an assumed load factor of 0.9 (9 bcm additional flow) during the 15-year long-term Open Season period. Figure 1 Volumes forecast in the 0-reference and incremental transit from the total Baltic Pipe project until year 2040, million Nm3 Long-term capacity contracts provide Energinet.dk with certain revenues independently of actual utilisation during a 15-year period from year 2022 to 2037. The very long-term demand after year 2037 will depend on the competitiveness of the route and could impose a risk on other users of the transmission system or Energinet.dk’s owner if demand patterns change drastically. Therefore, the following analyses compare transit revenues during the first 15year period with the economic risk after that period in order to evaluate the resulting transportation costs. 4.2 CAPEX/OPEX Budget estimates shown in the following analyses are preliminary and may be subject to changes/improvements until an investment decision is eventually made by Energinet.dk’s board some time at the end of year 2017. Investments and associated operational expenditure are shown in 2016-prices, and forecasts are shown in real prices excluding inflation. 4.2.1 Norwegian-Danish offshore tie-in Four independent solutions for connecting the two systems have been developed. Solution 1 (EPII – Pipeline to Nybro) is based on a direct pipeline connection to the existing Nybro Entry point with no interconnection to existing off- Dok. 15/11929-11 9/19 shore pipeline infrastructure currently owned and operated by DONG Energy or with production platforms operated by different producers. This is the cheapest solution with the highest reliability, availability and maintainability and with the lowest risk during construction and operation. In addition the number of stakeholders is low compared to other solutions. Further the operation of an offshore pipeline is relatively uncomplicated. Other solutions are between 1,6 to 2,6 times more expensive than the cheapest solution, when comparing investments and operational costs. Consequently, in the following analyses, only the EPII – Pipeline to Nybro solution is further investigated. It is an estimated investment of approximately 2.8 billion DKK with an associated annual OPEX of around 40 MDKK. Cost estimates are adopted from the joint Energinet.dk and GAZ-SYSTEM S.A. PCI Baltic Pipe Feasibility Study (2016). The estimates are used only for illustrative purposes to give an impression of the scale of incremental costs relative to the present cost base. The figures are still subject to revision as part of technical optimisation in the design phase. 4.2.2 Incremental expansions in the onshore transmission system Expansion of the existing onshore transmission system effectively utilises spare capacity in the system. In critical sections, the system is expanded by new pipelines in looping with existing pipelines and on the final section on Zealand towards Baltic Pipe on a new 42-inch pipeline is established. Table 1 Construction budget for onshore expansions, MDKK Note: Cost estimates are adopted from the joint Energinet.dk and GAZ-SYSTEM S.A. PCI Baltic Pipe Feasibility Study (2016). The estimates are used only for illustrative purposes to give an impression of the scale of incremental costs relative to the present cost base. The figures are still subject to revision as part of technical optimisation in the design phase. CAPEX and OPEX are again shown in steps matching capacity in the Baltic Pipe and in the Polish transmission system. Since the expansion is based on ‘borrowing’ spare capacity in the existing system, CAPEX is linearly related to incremental capacity. Otherwise, the figures would show economies of scale, ie that 10 bcm/y, if fully utilized, would result in the lowest unit cost of capacity. Dok. 15/11929-11 10/19 Figure 2 Resulting annual CAPEX and OPEX shown for year 2025, MDKK Note: The tariff cost base of the existing system is set to 430 MDKK corresponding to the cost base for the tariff year 2016/17. Changes to the cost base (from economic regulation or productivity gains) have not been analysed in the present paper. The future cost of the existing system in the analyses is therefore a constant 430 MDKK/year. Cost base, existing, is equal to the cost base used in the 0-reference. The annual cost base of new infrastructure assets is marginal compared to the higher cost base of existing assets. The new infrastructure is dominated by CAPEX compared to the more balanced composition of CAPEX/OPEX in the 0reference. The economic lifetime of new and existing assets is both set to year 2052. 4.2.3 New compressor station on Zealand A new compressor station (CS) is planned on Zealand near the expected Interconnection Point with Baltic Pipe. The cost allocation of the Zealand CS between the Danish and Polish tariff cost bases is not finally settled. The cost allocation is being discussed between the two TSOs and NRAs in Denmark and Poland. Since the planned CS constitutes a separate asset with a noticeable impact on future tariffs, the CS is treated as a separate asset in the following analysis. Resulting tariffs are shown with and without the Zealand CS. Cost estimates are adopted from the joint Energinet.dk and GAZ-SYSTEM S.A. PCI Baltic Pipe Feasibility Study (2016). The need for pressure services is related to the dimensioning in adjacent systems, ie Baltic Pipe diameter and required receiving pressure in Poland. In the following analyses, the Baltic Pipe is assumed to be a 36’’ pipeline. The electricity price is based on realised cost in the Egtved CS. Project electricity prices are adopted from Energinet.dk Analysis Assumptions. The investment cost estimate is around 1 billion DKK with an associated OPEX exceeding 200 MDKK annually. Dok. 15/11929-11 11/19 OPEX (compressor fuel consumption) is more closely related to the actual utilisation (how much gas is transported within a given period through the system towards Baltic Pipe) than to technical capacity. The assessment of OPEX is highly dependent on flow scenarios and other factors that at the time of writing can only be estimated with great uncertainty. Hence, OPEX shown are cautiously estimated in the higher end of the expected actual cost range. Additional analyses will aim to estimate the compressor costs with more accuracy within flow scenarios. The annual cost base derived is shown below. Dependent upon flow assumptions, the Zealand CS could constitute a significant addition to the annual cost base. Figure 3 Annual cost-base in 2025, new infrastructure and CS Zealand, MDKK Volume tariffs in Danish transmission have always been uniform (same for all) and are metered on the basis of the offtake from the system. The draft Tariffs Network Code, ie Article 4, Transmission and non-transmission services and tariffs, stipulates that future volume tariffs should remain uniform. 4.3 Resulting average cost of transportation (scenario-based unit cost) As shown in the previous sections, the total Baltic Pipe project with related new infrastructure could add significant marginal cost to the annual tariff cost base. An investment decision contains the risk that costs are transferred to existing users or that the infrastructure owner will be forced to write down assets if the economic lifetime is longer than the commercial value. It is incumbent on Energinet.dk to seek to clarify the framework conditions and mitigate risk associated to the project. It also makes sense to expect a sort of compensation, socio-economically as well as financially, for risk borne by other users of the Danish transmission system of a project that is expected to be primarily driven by demand for transit services. Dok. 15/11929-11 12/19 The potential full cost base resulting from the project is shown as a time series below. Figure 4 Size of new and existing assets as a time series, 2016-2050, MDKK (2016-prices) The figure below shows average transportation costs (unit costs) per unit delivered through the transmission system in the 0-reference case (dotted line) and after the total Baltic Pipe project dependent on utilisation after the expiry of Open Season long-term contracts. The figure illustrates that the average cost of transportation could be significantly lower due to the project. Even if the use of the transit system decreases after year 2035, transportation costs could be well below the reference case. Figure 5 Average transportation costs incl. tie-in and excluding Zealand CS Note: 1 EUR/MWh corresponds to 0.09 DKK/Nm3 at 7.5 DKK/EUR exchange rate. Dok. 15/11929-11 13/19 The difference between transportation cost in the reference case and if Baltic Pipe is realised can be used to calculate the transit net contribution margin in addition to the cost of new infrastructure. The net present value (NPV) of the contribution margin expresses the value of the project for all future users of the system. NPV values here and in the following analysis are calculated at a net discount rate of 4 per cent per annum. Figure 6 NPV net contributions from transit revenues, EUR/MWh NPV (2017-2050) of the contribution margin is estimated at 340 MEUR if volumes after the expiry of Open Season contracts are reduced from 9 bcm/y to 2 bcm/year. Even if transit volumes are reduced to zero, the cash flow still has a positive NPV of 149 MEUR, which is slightly below remaining book value of assets in year 2037, which are estimated at 137 MEUR. Dok. 15/11929-11 14/19 5. A Danish tariff zone and various cost-allocation principles Average transportation costs ignore the fact that different points or users could bear different shares of the tariff cost base. This is the current principle behind differentiated capacity tariffs. With the present Tariff Principles, Energinet.dk proposes to depart from differentiated tariffs. Because: 1. differentiated tariffs impose disproportional costs on new shippers, which are expected to provide a net contribution margin; 2. uniform tariffs provide a more transparent pricing principle that reduces regulatory risk associated with changing cost-allocation principles during the period of operation, and finally 3. differentiated tariffs may risk jeopardising the entire planned project by decreasing the competitiveness of the route compared with alternative sources of supply-side diversification in Poland and regionally. The present chapter analyses the impact of the total Baltic Pipe project on transmission tariffs dependent upon cost-allocation principles. Different costallocation principles lead to changes in the net contribution margin, transit revenues, as marginal costs are either shared proportionally by all users or borne exclusively by shippers participating in the Open Season. In parallel, it is considered how different cost-allocation principles support or contradict the objective of creating a common tariff zone encompassing the entire area of Denmark by including the onshore and offshore systems in one and the same tariff zone. The figure below shows a sketch of the involved infrastructure. Pipelines owned by third parties are indicated as dotted lines. New infrastructure is shown in light blue (Zealand CS is a trapezium) and the existing system as a darker blue cross. Figure 7 Dok. 15/11929-11 Tariffs calculated according to current principles of differentiated capacity tariffs 15/19 Note: The labels North Sea Entry and Exit as well as Zealand CS, Baltic Pipe Entry and Exit are temporary designations for new system points that have no official names. These will be determined in the period up until the launch of the Open Season. The calculation does not include Zealand CS. Inclusion of Zealand CS under the current principles would increase the transport cost of the route, but not tariffs in the existing system. The entryexit split is defined ex ante as 50:50. The table above calculates the resulting tariffs for each segment individually according to the principle of differentiated capacity tariffs in force today. A participant in the Open Season would pay a separate entry-exit (and volume) tariff in the tie-in. The marginal cost of new infrastructure is allocated only to the Open Season participants whereas all users, new and existing, pay the tariffs for the existing system. According to this cost allocation principle, the resulting route cost is 0.86 EUR/MWh from tie-in entry to an exit point towards Baltic Pipe. The net contribution margin ‘savings current users’ in the year 2025 is 29 MEUR. These savings will change along with changes in the cost allocation principles as a measure of how costs are moved between users of the new infrastructure and all other users. 0.86 EUR/MWh is above the cost of an alternative transport route taking Norwegian gas through Germany, when factoring in the additional transportation costs through a new Baltic Pipe offshore interconnector traversing the Baltic Sea. 5.1 Socialising onshore pipelines The principle of differentiated capacity tariffs was introduced to safeguard users of competing entry points from cross-subsidising their direct competitors through socialised tariffs. In its implementation, it removes CAPEX related to expanding import infrastructure (Ellund Entry) from the Nybro Entry (from the North Sea) and the Ellund Exit (towards Germany) tariffs. The total Baltic Pipe project case differs from the Ellund expansions that were put in operation from year 2012: 1. Investments in new infrastructure are expected to reduce transportation costs through substantial transit revenues from additional volumes. The Ellund expansions, in contrast, lead to increasing transportation costs through substituting volumes from domestic production by imported gas. The substitutional effect is reduced if domestic production continues to decline to a level below demand in the Danish-Swedish gas market. 2. Whereas Open Season capacity bookings are expected to be a key criteria for Energinet.dk’s investment decision, just as it was the case with Ellund expansions, there is expected a much closer match between reservations and incremental capacity than was the case with the Ellund expansions, where more than half of the new capacity was allocated to short-term products. The capacity allocation criteria for the Baltic Pipe Open Season are expected stricter: 90 per cent of incremental capacity in the tie-in is allocated to long-term contracts that have duration of minimum 15 years. Contracts in Open Season 2009 were 10-year contracts. Dok. 15/11929-11 16/19 3. The project will establish a new entry point (Baltic Pipe). However, it is designed to preserve existing technical capacity at other system points. This was also the case for the Ellund expansions, but it should be noted that the project does not compete or crowd out other users. Uniform tariffs result in full socialisation of all cost. Thus, the capacity tariffs will be the same at all entry and all exit points. Uniform tariffs result in a simplified tariff structure as shown in the table below. Figure 8 Resulting tariffs according to a principle of socialisation of incremental onshore pipelines According to the principle, all CAPEX from new and from existing infrastructure is pooled into a single tariff cost base. The tariff is calculated as the sum of all CAPEX divided by the sum of expected capacity reservations in all entry and exit points. This is arguably a more cost-reflective principle; it is certainly a more transparent and predictable principle than the current differentiated tariffs. Additionally, socialised tariffs support the notion of a national tariff zone. The principle of cost socialisation reduces the route cost for Open Season Participants transporting gas from tie-in to Poland from 0.86 to 0.80 EUR/MWh (- 7 per cent). The net contribution is similarly reduced from 30 MEUR in the year 2025 to 25 MEUR. Proportional to the share of volumes in the transmission system, Open Season Participants will cover more than 75 per cent of the cost base in that year alone. The transportation chain through Denmark still contains six separate pay points (two entry, two exit and two volume tariffs) with individually varying regulatory risk compared to a model in which offshore and onshore systems are more closely integrated. 5.2 Establishing a tariff zone A Danish tariff zone would incorporate offshore and onshore tariffs into a combined product, either as bundled capacity or through full socialisation of offshore and onshore systems. Dok. 15/11929-11 17/19 A Danish tariff zone brings closer integration between the systems to increase economies of scope, reduce transportation costs and to achieve cost-effective, non-discriminatory third-party-access to the Danish transmission system for all players, be it at interconnection points, Danish gas producers in the North Sea or domestic biogas producers. A tariff zone would also allow Open Season Participants to reserve capacity for entry capacity to the Danish system in either the Norwegian tie-in or in Baltic Pipe Entry towards Baltic Pipe (import capacity from Poland) and for transit flows also a matching exit reservation in Baltic Pipe Entry. The revenues of bundled capacity products are divided between the tie-in subsidiary and the onshore system. One model could be to allocate all costs in the tie-in together with the Nybro Entry to a North Sea Entry tariff. The resulting tariffs are shown in the figure below. Figure 9 Tariffs in a tariff zone with bundled capacity products The table above lists the various tariff elements. The resulting tariffs for Open Season participants are shown in the column ‘Total Baltic Pipe’. The model maintains the tariff structure in the onshore system for all users. The cost of transportation for Baltic Pipe users remains 0.80 EUR/MWh and the resulting tariff is dominated by an entry tariff in the tie-in of 0.41 EUR/MWh. In order to achieve even lower costs on the route and have a more uniform tariff structure, additional socialisation of cost offshore and onshore is required. 5.3 Socialising offshore pipelines As described in section 2, Energinet.dk proposes a common market zone with one entry point and a uniform cost allocation for all points in the system. In the proposed model, all costs offshore and onshore are fully socialised. This reduces transportation costs on the new transit route further. The resulting tariffs are 7.8 per cent below the principle for bundled capacity tariffs and 13.4 per cent below the principle for differentiated tariffs. The net contribution to the onshore tariffs in year 2025 is reduced from 25 MEUR to 22 MEUR. Dok. 15/11929-11 18/19 Figure 10 Resulting tariffs following full tariff socialisation of all incremental and existing infrastructures within a combined offshore and onshore tariff zone Please note that uniform allocation of all costs offshore and onshore is conditional upon the provisions in the Danish upstream regulation and the Law governing Energinet.dk – described in section 2.1. 5.4 Comparison of tariffs resulting from the analysed costallocation principles The resulting tariff according to the various cost-allocation principles is shown in the figure below. The figure also shows the marginal cost of transportation from incremental infrastructure alone. The marginal cost also expresses a capacity tariff in which no other users are put in a worse situation tariff-wise than in the 0-reference, where the total Baltic Pipe project is not realised. Figure 11 Resulting tariffs, EUR/MWh Note: The resulting tariffs are shown from different viewpoints. 0-reference shows the tariffs without the project being realised in year 2025. Differentiated tariffs show the resulting tariffs on the transit route through Denmark from Norway to Baltic Pipe. Dok. 15/11929-11 19/19
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