Gas Storage Netherlands (Vereniging Gasopslag Nederland) has responded to a second consultation prompted by the Draft Framework Guidelines on Harmonised Transmission Tariff Structures (draft FG on Tariffs) issued by the Agency for the Cooperation of Energy Regulators (ACER). Gas in gas storages is  transported from a border point or production facility to the gas storage via a high pressure gas transmission network and will be transported from the gas storage to the end consumer via the same gas transmission network. In its response, Gas Storage Netherlands voiced its appreciation for ACER’s efforts in getting to more transparent and harmonised transmission tariff structures. In particular, Gas Storage Netherlands welcomes that benefits of gas storages will be taken into account in the transmission tariffs throughout the EU. Gas Storage Netherlands also agrees that it should be taken into account that for gas that is transported via gas storages, entry and exit tariffs are paid twice (entry and exit fees are paid when entering and exiting the system and again at the gas storage point). Harmonised transmission tariffs structures for gas storages will prevent distorting cross-border investment incentives. Transmission tariffs make up for a significant part of the costs of gas storages. Therefore, developers might not build storages in a market area which has an artificially high entry-exit tariff for gas storage while this area may be where storage is needed most for gas consumers. Gas Storage Netherlands also reiterated that gas storages provide for a substantial cost saving in gas transmission networks. Gas storages also lead to general benefits such as lower volatility and improved security of supply. Currently, the transmission tariff methods for gas storages vary widely and in for instance in The Netherlands these benefits are not reflected in the transmission tariffs at all. The formal VGN response can be found here.

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