eu tariff code update 23 rd june 2014. 2 eu tariff code update – early feedback informal acer...
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EU Tariff Code Update
23rd June 2014
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EU Tariff Code Update – early feedback
Informal ACER feedback:
Draft code not on line with FG and insufficient harmonisation
Not coherent and “trying to please everyone”
Fixed price: don’t like indexation but use of premium could have merit
“open for discussion” on one-off reset of capacity (Commission thinks stakeholders
have good arguments so want to hear counter arguments from TSOs)
Informal Prime Movers feedback
Draft code too open with no harmonisation and little progress
For Cost Allocation Methodologies it would be better to have general
principles rather than writing methodologies into law
Confusion over which revenues subject to code and which are not
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EU Tariff Code Update
Draft Tariff Code open for consultation
Stakeholder workshop 25 June ENTSOG shall focus on:
Scope and interaction with CAM
Mitigating measures (including discussion of one-off capacity reset)
Capacity Allocation Approach (including how capacity/ commodity
split could work for revenue recovery)
Multipliers
Interruptible (including justification for use of ex-post discount and
pricing of non-physical back-haul the same as physical)
Use of fixed prices at IPs
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Mitigating measures
Spread increase or decrease in tariffs over a couple of
years so that there is a glide path for tariff changes
Use the auction premium, if any, to mitigate against
tariff increases
While ENTSOG is not in favour of the one off capacity
reset option, it is open to discussing other mitigating
measures that would not undermine contractual
commitments
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One off capacity reset option
ENTSOG concerns include:
Could lead to severe instability in the market and impact on tariff stability in
the future
Could cause cross-subsidisation between different users and a non-cost
reflective redistribution of costs
Penalises network users needing gas, the remaining gas users will pay for
the choices of other gas users
Discourages new entrants from coming into the market
Impact on investments. Those that triggered investment in the past and
made commitments to underpin that investment may return the capacity and
then that investment would have to be paid for by those that rebook capacity
or keep their existing capacity bookings.
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Transmission services definition
ACER want:
clarity of what is in scope and what is out.
cap on amount of allowed revenue not included in definition of
“transmission services”
detailed list of what is not part of “transmission services”
Prime movers want to know:
how revenue recovery works for services that are not part of
“transmission services”
how does “complementary revenue recovery charge” work
how one regulatory account works with other rules
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Total Allowed Revenue
Transmission Services Revenue
Revenue from other regulated activities
(exclusions from Trans services definition)
CAP Part of Transmission
Services Revenue
COM Part of Transmission
Services Revenue
CRRC
CAP Part of Transmission
Services Revenue
Reference Prices
€90m €80m €60m €40m
€10m
€20m
€20m
€2/u
Cap/Com split = 75%:25%
€1/u
€1/u
Cost Allocation Approach – with Capacity, Commodity and Complementary ReRe Charge
AssumptionsBooked capacity: 20 unitsThroughput: 20 units
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Multipliers
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• Concern from TSOs over multipliers• Definition of congestion (link to CMP)• Safeguard to allow multipliers greater than 1.5 if certain criteria met
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Some suggested fixed price mechanisms could be:
(1)fixed price + indexation
(2)fixed price + a risk premium
(3)fixed price + a variable charge
(4)fixed price + a combination of indexation, and a premium or variable charge.
Fixed Price Mechanisms
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Payable Price = Fixed Price + A Combination