EconGas Response - 22022016 PDF
EconGas Response - 22022016 PDF
EconGas GmbH
Donau-City-Straße 11
Christoph Rejlek
+43 (0)66488456909
Christoph.rejlek@econgas.com
1. Introduction
Natural gas transmission system operator companies SNTGN Transgaz SA, FGSZ Zrt. and
Gas Connect Austria GmbH consider to jointly conduct a binding open season for the book-
ing of new or incremental cross-border transmission capacity at the Romanian-Hungarian
border and the Hungarian-Austrian border, in both flow directions. The preparatory process is
supported by the respective national regulatory authorities, i.e. ANRE (Romania), HEA (Hun-
gary) and E-Control (Austria). All involved TSOs published the same survey electronically
either via an electronic form or as a downloadable document.
Any other details of the possible open season procedure (e.g. exact timing, quantity of
offered capacity, tariffs, legal terms applicable to capacity contracts, financial securities etc.)
are out of the scope of the present Public Market Consultation.
Participants of the survey are kindly asked to fill in the questionnaire, where general ques-
tions are asked and to evaluate the proposed Methods according to their perceived merits.
For the new capacity, an amount at least equal to 10 % of the technical capacity will be set
aside and offered no earlier than the annual quarterly capacity auction according to Article 8
(8) CAM NC.
For the sake of the example, a 15-years booking period is assumed when describing the
Methods.
• Offered contractual capacity product: yearly bundled capacity product at each IP in both
directions (1 October-1 October) at Csanápalota (RO>HU) / (HU>RO) and at Mo-
sonmagyaróvár (HU>AT) / (AT>HU).
• Conditional bids: no. Capacity products are offered in independent, single-year products,
where no conditional bids can be made between certain years or across the offered inter-
connection points.
• In total, 60 capacity auctions (1 auction per IP per flow direction per year) are envisaged
to be organised.
• Offered contractual capacity product: yearly bundled capacity product for 2 IPs, in both
flow directions (1 October-1 October) at Csanápalota (RO>HU) / (HU>RO) and at Mo-
sonmagyaróvár (HU>AT) / (AT>HU).
• Conditional bids: yes. Capacity products are offered in three, subsequent capacity alloca-
tion rounds.
• Allocation round I:
o A single batch made of 15 single-year product is allocated simultaneously for the two
interconnection points. It means that within 1 allocation procedure, all 15 yearly bun-
dled capacity products per flow direction on both interconnection points are allocated.
o In total, 1 capacity auction per flow direction is organised.
4. Questionnaire
4.1. Would you support a possible capacity allocation design other than those de-
scribed in Regulation 984/2013/EU, i.e. ascending clock algorithm or uniform
price algorithm?
NO
If yes, which?
For the allocation of long term capacity products, we support the ascending clock
algorithm. A market-based allocation can however only be guaranteed, if shippers
have a guarantee that the auction round steps are set as low as possible and need to
be consulted upon with shippers. Excessively high round premia would undermine
the nature of the ascending clock algorithm.
4.2. Do you have any preference between auction algorithms, e.g. ascending clock,
uniform price or pay-as-you bid?
4.3. In case of Method No. 2, which batch of single-year products would you prefer,
e.g. 5, and/or 10 and/or 15 years?
☐ 15-year batch
4.4. Would you allow conditional bidding during the open season procedure?
YES
4.5. If conditional bidding during the open season procedure is allowed, which type
of conditionality would you deem necessary?
Other
1) We support the conditionality that shippers who are interested ONLY in both bor-
der points (in one or both directions) must have the chance to be allocated both bun-
dles to the same extent (duration and hourly flow rate), if they request so (“superbun-
dled capacity”). But if requested, shippers should also have the possibility to bid for
single bundled capacity products as well (AT/HU and HU/RO in both directions).
2) We also support a step back clause as suggested in method 3 which allows ship-
pers to revoke their bids. The deadline for shippers to step back should be as late as
possible and has to be consulted before.
3) Shippers need a price guarantee which allows them to terminate the bundled con-
tracts if the regulated tariff at any of the TSOs goes up excessively. Such a provision
is seen in Germany and prevents shippers from being exposed to arbitrary tariff
changes in the upwards direction. The maximum annual tariff increase needs to be
agreed upon by shippers. Shippers having bought the entire route (=both IPs) also
need the right to step out of the entire route if TSO capacity on only one IP tariff goes
up excessively.
4) Shippers with already existing contracts along the envisaged project route must be
given the opportunity to include their exisitng contracts in the bidding process (i.e.
“conditional surrendering”). No interested shipper must be forced to pay twice for
capacity because the allocation mechanism does not allow for flexibility to avoid this.
5) The planned project covers three European countries and thus a plethora of differ-
ent regulations per country applies. Shippers, especially those having purchased the
entire route in one direction or both directions, must have the right to cancel single or
even ALL contracts if conditions (GTCs, market rules, legislation) deteriote signifi-
cantly in one of the three countries involved.
4.6. Would you prefer ex ante or ex post conditionality in the open season’s capacity
allocation design? Please state your reasons.
4.8. Would you have a preference for any of the above mentioned Methods?
Method 2
We support method 2, but only under the provisions we already mentioned under 4.5