Review of Transmission Exit Capacity Transfers in the
Gas Market
DOCUMENT
TYPE:
REFERENCE:
Consultation Paper
DATE
PUBLISHED:
CLOSING
DATE:
24th February 2010
CER/10/037
2nd April 2010
The Commission for Energy Regulation,
The Exchange,
Belgard Square North,
Tallaght,
Dublin 24.
www.cer.ie
CER – Information Page
Related Documents:
•
Gaslink Code of Operations
•
CER/07/115 - Short-Term Capacity Products Decision Paper
•
CER/09/171– Review of the Regulated Tariff Formula (RTF)
Responses to this consultation should be returned by email, post or fax and
marked for the attention of Clive Bowers ([email protected]) at the Commission.
The Commission intends to publish all submissions received. Respondents
who do not wish part of their submission to be published should mark this area
clearly and separately or enclose it in an Appendix, stating the rationale for not
publishing this part of their comments.
2
Table of Contents
Glossary ............................................................................................................ 4
1. Introduction and Background ............................................................................ 5
1.1 Introduction .................................................................................................. 5
1.2 Description of the exit capacity regime ........................................................ 6
1.2.1 Exit capacity tariffs ................................................................................ 6
1.2.2 Booking exit capacity ............................................................................. 6
1.2.3 Exit capacity market in practice ............................................................. 7
1.3 Drivers for this Review ................................................................................. 8
2. EU Regime...................................................................................................... 10
3. Market Impact Analysis ................................................................................... 12
3.1 Exit Capacity Transfer Analysis ................................................................. 12
3.2 Impact of Exit Capacity Transfers on Primary Capacity Tariffs .................. 12
3.3 Market Sector Analysis .............................................................................. 13
3.3.1 Non Daily Metered (NDM) ................................................................... 13
3.3.2 Daily Metered (DM) ............................................................................. 14
3.3.3 Power Generation & Unregulated sector ............................................. 15
3.4 Distribution of Impacts if Secondary Transfers Were Ended. .................... 16
3.5 Wider Retail Market Analysis ..................................................................... 16
4. Some Arguments for and against Exit Capacity Transfers .............................. 18
5. Questions ........................................................................................................ 20
6. Responding to the Consultation ...................................................................... 21
3
Glossary
Within this document the following terms are used:
Exit Capacity Transfer - An Exit Capacity Transfer is where a shipper transfers
Primary exit capacity to another part of their portfolio or to another shipper. With
an exit capacity transfer, capacity can be moved between sites at different
geographical locations. This capacity is commonly known as secondary exit
capacity. In the case of sales to other shippers, this capacity can be called back
by the selling shipper.
Entry Capacity Trading - Entry Capacity Trading is where one shipper sells on
to another shipper, rights in relation to all or part of their Primary Annual Entry
Capacity at the same entry point. This is known as trading of primary entry
capacity. This capacity can be called back by the selling shipper.
Secondary Capacity- Secondary Capacity is a term we use in this paper to
describe all traded entry capacity and transferred exit capacity in the whole
market.
NDM – Non Daily Metered
DM - Daily Metered
MWh – Mega Watt hour
GWh – Giga Watt hour
RTF – Regulated Tariff Formula
I&C – Industrial and Commercial
**Please note that the above is merely a glossary of terms used within this
document and where appropriate, interested parties should refer to the Code of
Operations for specific definitions.
4
1. Introduction and Background
1.1 Introduction
In this Consultation Paper the Commission reviews the current regime for
secondary transfers of exit capacity in the Irish gas transmission system. Among
the key issues on which stakeholders’ views are sought are:
‐
‐
‐
‐
‐
Is the rationale for continuing to allow such secondary transfers valid, given
the development of short term flexible capacity products in recent times?
Is the current regime efficient?
Is the current regime equitable between categories of gas customers?
What would be the likely impact of ending secondary capacity transfers on
different customer categories – e.g. residential customers versus I&Cs,
between different I&C categories, the power generation sector etc?
Do EU rules allow for termination of secondary transfers of exit capacity, as
distinct from entry capacity, where it is clear that trading must be allowed?
In embarking on this review, the Commission is anxious to emphasise that it has
an open mind on the future of the current secondary capacity transfer regime –
whether it should be allowed continue, be amended or terminated. Some of the
policy issues involved in this review are complex. Similarly, quantifying the likely
impact of change on different customer categories is also a complex exercise.
The Commission is particularly anxious to hear stakeholders’ views on these
issues.
A related, but distinct, aspect of the review is the relationship between capacity
transfer rules and the Regulated Tariff Formula (RTF) which applies to BG
Energy in the retail sector. A review of secondary capacity was anticipated in the
Commission’s Review of the RTF (CER/09/171 of 20 November 2009). This was
because of the concern that the current rules may allow BG Energy enjoy a
particular benefit in this end of the retail market. This is still a valid concern. The
primary focus in the present paper, however, is on the whole underlying rationale
of the current rules on capacity transfers in the first place and likely broad
sectoral impact of amending/terminating it. In other words, the review would be
undertaken in any event, regardless of any decision of the RTF regime.
Should the Commission conclude from this consultation exercise that the rules on
secondary transfers should be amended, or indeed that such transfers should be
5
ended, it would issue a direction to Gaslink pursuant Section 14 of the Gas
Interim) Regulation Act 2002. The Gas Code of Operations (Part C/5)
would also have to be amended to reflect such a direction.
1.2 Description of the exit capacity regime
1.2.1 Exit capacity tariffs
Ireland employs a postalised exit tariff regime where the cost of primary exit
capacity is the same at all parts of the Ireland system. The system averages
costs across the system; if tariffs were set on a regional basis (as opposed to
postalised) it is likely that Dublin and Cork would have much lower exit tariffs than
Westport (for example) given the more mature nature of the network and the
greater population density. Primary exit capacity and commodity tariffs are
calculated as follows.
1.2.2 Booking exit capacity
Transmission exit capacity is booked by shippers in accordance with their
requirements and more specifically with Part C of the Code of Operations.
•
•
NDM customers must book NDM exit capacity as advised by the transporter.
Temperature sensitive customers must book capacity for a 1 in 50 year peak
day adverse conditions. This means that at most times during the year the
NDM sector has spare capacity that it isn’t using.
DM customers have discretion on the amount of capacity they book. They are
however issued a transporter recommended exit capacity amount which they
are not obliged to book.
6
•
LDM customers book capacity in line with their own requirements subject to
the transporter respecting overall system integrity.
1.2.3 Exit capacity market in practice
At present shippers have the ability to transfer exit capacity as per the Code of
Operations. Transfers can occur between shippers, between sectors and
between individual LDM sites.
There are significant volumes of exit capacity transfers executed within the gas
market at present and the number has been increasing. A large portion of the
transfers are where unused NDM exit capacity is transferred to other sectors and
other shippers. BG Energy supplies over 98% of the NDM residential market and
so has more spare 1 in 50 capacity than any other shipper. BG Energy sells on
this unused capacity to themselves and other shippers. The Commission sets the
floor price for these capacity transfers and the money recouped (from all NDM
capacity transfers) is recycled back through regulated NDM tariffs.
BG Energy and a number of other independent shippers purchase the discounted
secondary capacity and use it for their DM customers. Because of this there are
a significant number of DM customers and some LDM customers that only book
a nominal capacity amount of 1kWh. In this way shippers can make a margin off
the capacity they supply to customers.
However, not all shippers in the market utilise secondary capacity transfers.
Some potential new shippers have suggested that the current regime actually
acts as a barrier to entry to the market. Specifically they do not believe that it is
appropriate to have to go to their main competitor (BG Energy) to buy capacity to
compete with them and others in the market.
Exit capacity transfers are utilised in the power generation sector also. If one
station is down the shipper can transfer the capacity to another power station that
may be replacing the output of the first.
7
Example of the Impact of Exit Capacity Transfers
•
•
•
•
•
•
A new customer connects in Galway and a new pipeline is built to serve their
site. Another customer connects in Cork and a pipeline is built to serve their
load.
In this example two pipes have been built to serve the two customers.
Given that pipelines are in place to serve these customers it is fair and
reasonable that each customer makes a contribution for them through capacity
payments.
However, the ability to transfer capacity allows shippers to transfer capacity from
the site in Galway to the site in Cork to reduce overall bookings.
In such a case, the transporter builds and maintains two pipelines but the
shipper does not book sufficient capacity for both customers, hence the
pipelines are not being remunerated.
If the sites that caused the building of these pipelines are not remunerating them
some other customer is.
1.3 Drivers for this Review
A key consideration in this review is that the system is remunerated in a fair and
equitable way with any financial burden placed on customers in proportion to the
service they receive. As part of this exit capacity transfers are being considered.
The facility to transfer transmission exit capacity was implemented in 1998
(before CER came into operation) as part of the first transmission code of
operations. At that time there were only ten or so third party access sites in the
market and only annual primary capacity was available. Some of the customers
had loads that peaked outside of the winter such as the sugar processing plant
and the facility to transfer exit capacity was deemed appropriate. Since then a
suite of regulated short term Monthly, Daily and Within Day capacity products
were implemented in 2007 which gives significant flexibility to the market. The
Commission wishes to examine whether it is desirable to retain secondary
transfers of primary exit capacity given the flexibility that is available in the short
term products.
The existence of secondary capacity impacts on areas of the Connections Policy.
Under the Connections Policy appraisals for new connections and new towns
assume that primary annual capacity will be booked by all new customers and
will not be transferred away from the site. However in some cases the new sites
8
are not booking primary annual capacity and in other cases the capacity is being
transferred on. This can have an impact on the viability of new connections and
can create a burden on other system users.
The current Connections Policy ensures that the transporter builds the gas
network with capability to supply all customers on the coldest of days. In other
words the system is maintained without constraints where the system is
reinforced for new connections if reinforcement is needed. Building this capacity
and then allowing exit capacity transfers which reduce bookings on the exit may
be economically inefficient. In light of this the Commission wishes to examine the
impact of capacity transfers on how the system is reimbursed.
The Commission is currently reviewing the Regulated Tariff Formula. As part of
this the Commission committed to examining the secondary capacity market in
detail.
The Commission also wishes to examine the impact of secondary capacity on the
Non Daily Metered (NDM) market. Domestic NDM customers must book
sufficient capacity to meet demand on a 1 in 50 severe winter. Given this, it is
important to ensure that all users, including NDM users, pay a fair amount for the
capacity made available.
9
2. EU Regime
One of the three pillars of European energy policy is competition. As part of this,
third party access is a key principle of gas networks. Within the wider European
gas market, congestion is seen as a key barrier to new market entry and liquidity.
Across mainland Europe contractual congestion has been seen as a major issue.
This is where the entire capacity of pipelines has been booked on long term
contracts, traditionally by legacy participants. This has meant that in many cases
there is no capacity available to new players. For the most part only contractual
congestion has existed with physical congestion seen as less of a problem.
In order to tackle the issue of network congestion at EU level measures were put
forward to promote liquidity and market entry. From a networks point of view
probably the most significant piece of legislation was Regulation (EC) No
1775/2005. Regulation 1775 concerned conditions for access to the natural gas
transmission networks and mandated the introduction of a number of new gas
capacity products in the market. Short Term products from the transporter
(monthly, daily, within-day1) were made available from 1st October 2007 following
CER decision paper CER/07/115. The Regulation also provided for the ability of
shippers to trade their primary capacity on a secondary market.
Regulation 1775 also required the introduction of certain interruptible gas
capacity products. There are interruptible products in place at present at Inch
where gas leaves the onshore into storage and also where a shipper’s
nominations are in excess of their active capacity The business rules for
regulated interruptible products at the Entry were developed in 2008 but the
product was not systemised on GTMS due to CAG being in development and the
absence of congestion on the system. It is expected that an interruptible product
will be in place as part of CAG.
Regulation 1775 has recently been repealed by Regulation 715/2009/EC (under
the EU Third Package) and this repeal takes effect from 3 March 2011. The new
Regulation does not require the introduction of new products over and above
what is currently required.
A key point to bear in mind, however, is that the EU Regulations confine
themselves to congestion management procedures (such as secondary transfers
or trades) “which facilitate cross-border exchanges in natural gas” (see, for
1
Within-day short term product was made available from June 2008
10
example, Article 16.3 of Regulation 715/2009). They do not prescribe such
procedures on domestic exit systems. This is hardly surprising. It is difficult to see
how the presence, or absence, of secondary transfers on Ireland’s gas exit
system could in any way adversely affect trade between Member States.
11
3. Market Impact Analysis
3.1 Exit Capacity Transfer Analysis
In the next sections we explore the overall requirement for secondary transfers of
exit capacity in terms of:
•
•
•
Likely impact on Exit Tariffs
Likely impact on individual market sectors
Likely impact on the wider retail market
At the outset it is important to note that we cannot say with any certainty what the
effect of removing exit capacity transfers on overall primary bookings would be.
Therefore we use a range of assumptions with regard to increased primary
capacity bookings. The range of increased bookings used is based on 60-100%
of the amount of short term daily products booked during the recent peak day in
January 2010 (not including power generation) which we believe to be a
conservative range of estimates. In reality the impact on primary bookings may
be more or less than the range put forward in this paper.
3.2 Impact of Exit Capacity Transfers on Primary Capacity Tariffs
Taking the exit tariff for the current gas year, the required revenue is €116.03m
with projected capacity bookings of 241.39 GWh. Under the current 90/10
capacity/commodity regime this gives a capacity tariff of €432/peak day MWh2.
Let us now assume a range of increased exit bookings in the absence of
secondary transfers.
Current Bookings
Level
Higher estimate of
increased bookings
Lower estimate of
increased bookings
2
Aggregate Exit Capacity Regime
Required Revenue Capacity Bookings
€116.03m
241GWh
Capacity Tariff
€432/peak day MWh
€116.03m
259 GWh
€412/peak day MWh
€116.03m
253 GWh
€418/ peak day MWh
As published in cer/09/149
12
The analysis above takes no account of the revenue from short term products
that shippers might book for some of their customers. This would have an impact
on the figures but the level is difficult to quantify ex-ante.
3.3 Market Sector Analysis
While it may seem to be a statement of the obvious, the removal of the ability to
transfer exit capacity would have a negative impact on those (shippers, individual
sites, sectors) who gain revenue from the sale of such capacity and those
(shippers, individual sites) who buy secondary capacity to lower their capacity
costs by reducing their purchases of firm annual capacity or short term products.
What is less obvious is the scale of this negative impact on sectors as a whole or
on individual shippers / individual sites within these sectors.
At a very basic level, it is likely that high load factor “base load” sites should
benefit from any reduction in the capacity tariff consequent on an ending of
secondary capacity transfers. By contrast, gas customers with a more seasonal
or “lumpy” load pattern are likely to lose out. We attempt to shed some light on
this in the following sections.
3.3.1 Non Daily Metered (NDM)
If we take the NDM market, the current gas year there are circa 100 GWh of
capacity bookings forecast. This means that the NDM market will pay €43.2m for
its transmission exit capacity. In the higher bookings scenarios above, the NDM
market would only pay €40.3m to €41.2m for its transmission exit capacity, i.e.
between €2.02m and €2.96m less than it currently pays. Given that BG Energy
serves a significant proportion of the NDM market (over 98% of the domestic
market) the regulated tariffs they offer set a benchmark in the market. BG Energy
is required to give the proceeds from their secondary capacity sales (from their
NDM book) back to the NDM market and this is reflected in the end tariff. In the
2008/09 gas year BG Energy gave back some €5m to the NDM market resulting
from exit capacity transfers.
13
NDM Exit Capacity Regime
Capacity Tariff Capacity
Bookings
€432.61 /peak 100 GWh
Current
Bookings Level day MWh
€412 /peak day 100 GWh
Higher
estimate
of MWh
increased
bookings
Low estimate €418 / peak 100 GWh
of
increased day MWh
bookings
Savings Range
NDM Booking
cost
€43.26m
€41.2
€41.8m
€1.46 - €2.06m
Note: No change in aggregate NDM 1 in 50 booking
If the ability to transfer secondary capacity were no longer available, the NDM
market would likely be worse off on a year to year basis although this would be
difficult to quantify given that sales of BG Energy secondary capacity vary from
year to year and the many other factors that impact capacity tariffs (demand
being a significant one). Using the lower numbers above (€4.8m – €1.46 =
€3.34m) would have the effect of increasing BG Energy NDM tariffs by circa
0.9%.
The NDM sector is required, for security of supply reasons, to book capacity for 1
in 50 year conditions. Such conditions have just occurred in 2010 and the system
was able to provide gas to all NDM customers. Had the system not been built to
such standards, capacity might not have been available for NDMs. Given the
benefits that NDM customers receive for booking for 1 in 50 year conditions, it
could be argued that it is only equitable that they pay for these.
3.3.2 Daily Metered (DM)
Any removal of exit capacity transfer would likely have the most impact in the
retail DM and LDM sectors given that these are the customers that rely most on
secondary transfers.
In the non power LDM and DM sector at present there are in the region of 10.5
GWh of exit capacity booked. If all DM sites booked the transporter
recommended DM exit capacity3 there could be over 25 GWh of capacity
bookings which would suggest that there could be 15 GWh of secondary capacity
used in the sector. This would suggest that if secondary trading of capacity was
3
See Part C Section 6 of the Gaslink Code of Operations
14
disallowed this sector would pay considerably more in capacity charges than at
present.
However, the impact on end customers in the DM sector may not be as
significant as the above suggests. This is because it is unclear whether the
benefit of using secondary capacity is passed on either in part or in full by
shippers to the final customers. In other words it depends on just how competitive
this sector is and is likely to be in the future.
Bookings
15 GWh
15 GWh
Aggregate DM Exit Capacity Regime
Tariff €/peak day MWh
@ €432.61
@ €432.61 x 71%*
@ €412 (Higher Bookings)
@ €418 (Lower Bookings)
Cost
€6.48m
€4.61m
€6.18m
€6.27m
*One full year of secondary capacity purchased from BG Energy is priced at equivalent to 71% of
the primary capacity cost, this is taken as the best estimate of the price paid for secondary
capacity but the actual figure depends on the time of year covered by the actual purchase, e.g.
summer capacity is sold at 50% of the cost of annual capacity).
If the benefit of utilising secondary is passed on in full to the customers (taken as
71% above) then the DM customers pay €4.61m for this capacity. If suppliers
retain part of this saving as margin then the customers would not see all of this
benefit. It is likely that in the event of removing the facility to transfer exit capacity
there would be individual customers within this sector who would gain and others
who would loose.
3.3.3 Power Generation & Unregulated sector
The impact on the power generation sector is even more difficult to quantify.
In theory many of these plants are base load and will book primary annual
capacity and so will benefit from lower primary charges. The situation may be
somewhat different for lower load profile plants which may not justify booking
primary capacity and short term products may be seen as cost-prohibitive. This
issue has been raised by generators following discussions held at the industry
fora in late 2009.
Having carried out some initial analysis, it may be that the impact on gas plants in
the merit order may not be significant in terms of fuel choice for peaker plants.
Our preliminary analysis would support a view that even with short term daily
capacity costs included in the bid price, a gas fired peaker would still be in merit
15
compared to a distillate fired peaker. We have examined this under a number of
scenarios (recent prices (08/01/10), high gas prices (30/09/08) and high gas/oil
differential (31/10/08)) and it would appear that the gas peaker would in all these
cases be in merit ahead of distillate.
In addition to power generation there are a number of LDM customers in the
unregulated retail sector (consumption >264 GWh/annum). These customers
may experience an increase in exit capacity charges depending on how much of
the benefits of secondary exit capacity they currently receive. The likelihood is
that they do receive discounts on their capacity. However, they will benefit from a
lower overall tariff should it be reduced due to increased primary bookings (see
Section 3.2).
3.4 Distribution of Impacts if Secondary Transfers Were Ended.
In the preceding scenarios the benefit of any extra bookings will be shared prorata between sectors based on capacity bookings. Our analysis would suggest
that the benefits would be shared in the following approximate ratios depending
on the level of bookings i.e. if power generation has 52% of the total exit
bookings then they see 52% of the benefit of any reduced exit capacity tariff).
Power Generation
Rest of LDMs and DMs
NDM
Shrinkage
Lower Bookings
52%
7%
39%
2%
Higher Bookings
51%
8%
39%
2%
3.5 Wider Retail Market Analysis
As stated at the outset, the Commission has been considering the issue of
secondary capacity transfers at the exit and the RTF consultation issued in 2009
has brought forward a review of the regime. In the RTF Consultation the
Commission stated;
“The Commission has been examining the secondary capacity market in more
detail in recent times and does have some concerns on how it is operating,
including its effects both on network tariffs and on the retail sector.” The 2009
consultation pointed towards concerns raised to the Commission about the
information asymmetry that exists regarding secondary capacity between BG
Energy and all other suppliers.
16
Following Commission presentations at the Code Mod Forum and GMARG it was
suggested by some interested parties that there were market intervention
solutions available for alleviating any concerns with secondary capacity and
reducing, or eliminating, the information asymmetry advantages which BG
Energy currently enjoys under the secondary capacity regime. This is probably
true, though it should be remembered that often such rules are vulnerable to
manipulation and gaming.
It may be, on the other hand, that the ending of secondary capacity trading would
aid competition in the market. A number of suppliers in the market have
complained that no competition has developed at the customer level above the
RTF sector. It could be argued that this is due in part to the existence of
secondary capacity and the ending of the product could create competition in the
sector.
17
4. Some Arguments for and against Exit Capacity Transfers
As mentioned earlier, the Commission is satisfied that the current secondary
capacity regime warrants review though it has an open mind on the outcome of
that review. The purpose of this consultation exercise is to elicit views on the
policy issues involved and on the likely impact that termination – should that
course be followed - would have on individual gas customer groups. To aid the
debate, in this section we set out some of the arguments for and against the
current regime that have been have been put to the Commission in recent times
or that we ourselves consider warrant addressing.
The list of arguments below does not claim to be exhaustive.
Secondary capacity allows the NDM market sector mitigate somewhat the
cost of booking 1 in 50 exit capacity throughout the year.
At present the ability to transfer primary capacity as interruptible does allow NDM
customers recoup some of the cost of booking for the 1 in 50 year. However, this
process actually results in a lowering of primary capacity bookings which in turn
raises the overall tariffs.
Secondary capacity provides for an efficient use of the transmission
system in a cost effective manner
While secondary capacity does provide flexibility to shippers it is unclear whether
it actually results in a more efficient system. For example the existence of
secondary capacity does not result in less pipes being built given the current
Connections Policy Framework. Also while secondary capacity may be cost
effective for some market sectors or subsets thereof, it may not be cost effective
for the market as a whole.
Secondary capacity provides flexibility to the power generation sector and
may encourage gas peaker plants and summer peaking loads onto the
system
The existence of secondary capacity provides significant flexibility to the power
generation sector and summer peaking loads. On the other hand, there are now
a suite of regulated short term products that provide at least as much flexibility as
secondary. It may be that a review of the pricing of these products would be
appropriate in the event of any removal of secondary. Regarding the case for
summer peaking loads it should be noted that the summer monthly products are
currently priced lower than the primary annual equivalent.
Secondary capacity provides a facility for primary capacity holders to
transfer-on capacity that they no longer require. It has been suggested that
the comfort this facility provides may even promote primary bookings.
This may be a valid advantage of secondary capacity but such occurrences are
more likely to be the exception than the norm. Also, there is significant flexibility
18
availability when booking short term capacity. Given that primary capacity
contracts are one year in length the exposure is limited somewhat.
Secondary capacity helps to promote sustainable forms of energy like
wood pellets where customers can utilise gas when renewable feedstock’s
are not available.
Again, there is the counter argument that there is sufficient flexibility available to
the market in the form of annual, monthly and daily products.
Secondary capacity is an important element in the continuing development
of competition in the small, medium and large business customer
segments capacity.
It may be that the existence of secondary capacity (in the RTF sector) has helped
to develop competition in the various market sectors. However this may only be
because BG Energy are obliged to quote and charge customers for the full
amount of primary capacity while independent shippers can offer some or all of
the benefit of secondary. If the RTF did not exist, independent shippers would not
have such protection, so the potential benefit for independents would not be as
significant.
Secondary capacity offers scope for discounts and product differentiation
between suppliers.
See preceding counter argument. Also it may be that secondary capacity
currently creates a less than transparent charging regime for customers. If
secondary did not exist all customers would be able to more closely reconcile
their transporter recommended exit capacity with their bills and capacity would be
closer to a pass through only product (although potentially portfolio benefit could
differentiate offers). This would see shippers compete in the main on the price of
gas and the margin.
19
5. Questions
Q1: Should Primary Capacity transfers be allowed on the Exit?
Is there a continuing rationale for the product?
Q2: What is your view on the assessment of secondary capacity and its
impact on the individual market sectors as set out in Section 3 of this
paper?
Q3: What are your views on the interaction between secondary transfers
and the retail gas market, in the light of Section 3.5 of this paper?
Q4: Any other comments or submissions you wish to make?
If there are questions other than those presented above please feel free to
present and discuss in your consultation response.
20
6. Responding to the Consultation
The Commission invites comments on this paper from interested parties to be
submitted no later than 5.00pm on Friday 2nd April 2010. Comments should be
sent, preferably in electronic format to;
Clive Bowers
Commission for Energy Regulation
The Exchange
Belgard Square North
Tallaght
Dublin 24
Tel: +353 1 4000800
Fax: +353 1 4000850
[email protected]
The Commission intends to publish all comments received – those respondents
wishing for certain sections of their submission to remain confidential should
submit the relevant sections in an appendix marked confidential.
21
Appendix A. Relevant EU Legislation.
Regulation (EC) No 715/2009 of the European Parliament and of the Council of
13 July 2009 on conditions for access to the natural gas transmission networks
and repealing Regulation (EC) No 1775/2005
Regulation (EC) No 1775/2005 of the European Parliament and of the Council of
28 September 2005 on conditions for access to the natural gas transmission
networks
Appendix B. Short Term Tariff Information.
Short term capacity is priced at a percentage of primary annual capacity. The
short term multipliers are included in the table below.
Short Term Tariff
Multipliers
October
November
December
January
February
March
April
May
June
July
August
September
Primary Annual Equivalent
Monthly
Daily
15%
15%
20%
35%
40%
30%
15%
8%
8%
8%
8%
8%
8.33%
0.75%
0.75%
1.33%
2.33%
2.67%
2.00%
0.75%
0.40%
0.40%
0.40%
0.40%
0.40%
0.27%
22