Gas Storage Netherlands has recently shared a position paper 

with European Commission on the security of supply and the role of gas storages. Gas Storage Netherlands of the opinion that government intervention is justified in case a country relies on one single supplier as a result of a lack of interconnections with other markets. For other regions, such as North-western Europe, Gas Storage Netherlands is of the opinion that the European Commission should build further on the completion of the internal energy market by defining and enforcing market rules and providing the right investment conditions for infrastructure including gas storages.

The use of commercial gas storage is an important market-based tool for ensuring security of supply. To address recent concerns of decreasing gas storage booking and even mothballing gas storages, Gas Storage Netherlands advocates lowering transmission tariffs that are in line with the requirements of Regulation 715/2009. Transmission tariffs should be cost reflective and should lead to efficient investment. Therefore, the network code on tariff structures currently developed by the Agency for the Cooperation of Energy Regulators (ACER), the European Network of Transmission System Operators for Gas (ENTSOG) and the European Commission should ensure that transmission tariffs for gas storages reflect the fact that entry- and exit tariffs for gas in storages are already paid at import/production and at end consumer/export facility and take into account benefits that gas storages provide for the transmission network and the gas market in general.

Other security of supply measures concerning gas storage should be used in a careful way to avoid market distortion and should be used only in exceptional circumstances. Most of the measures are already covered by Regulation 994/2010.

The position paper gives background information on gas storage in general and on the pros and cons of various security of supply measures proposed.

Het position paper geeft meer achtergrondinformatie over gasopslag en over de voor- en nadelen van de voorgestelde maatregelen.

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