German energy regulator Bnetza has launched a consultation on its draft gas transmission tariffs for October-December 2021 following the NCG-Gaspool market area merger.
Bnetza expects a uniform reference price of €0.421/MWh in the fourth quarter of 2021 in the integrated German market area, following the merger of NCG and Gaspool that is scheduled for 1 October 2021. The fees will apply to firm, freely allocable capacity.
This would be above the €0.46/MWh fee in NCG for this calendar year but below the €0.38/MWh charge in Gaspool.
To calculate the reference prices for the quarter, the system operators had to run a "hypothetical booking forecast" that assumes there is a single German market area for the whole of 2021, Bnetza said.
The fees are based on the same methodology that was used for this calendar year following the implementation of the EU's network code on harmonised transmission tariffs (NC TAR).
Bnetza expects to use a postage stamp methodology next year, unchanged from 2020, which results in a single tariff for entry and exit points regardless of distance.
But with the launch of the consultation on the draft tariffs for the merged German market area in 2021, the regulator has also raised the possibility of changing its tariff calculation approach. It has asked market participants to provide their views on an approach proposed in a report commissioned by German system operators Gascade and GRT Gaz Deutschland along with Russia's state-controlled Gazprom Export.
The report argues that the standardisation approach that Bnetza takes does not account for "different transmission tasks and their cost differences", and consequently "distorts" the signals generated from the tariffs.
The report suggests two possible alternatives. Under the first suggestion, a distinction would be made between exit points for domestic customers and exit points at border and cross-market points.
A second approach — which the report says would be best for avoiding cross-subsidisation — would involve the "explicit separation of the transport tasks and function-specific costs". This would allow for a "function-specific cost allocation", with costs distributed according to the respective transmission tasks.
Dusseldorf's higher regional court last May rejected requests by Gascade and GRT Gaz Deutschland to temporarily suspend the introduction of the new tariff structure on the grounds that the changes would involve an "unlawful cross-subsidisation of domestic gas distribution at the expense of cross-border transport".
"Germany risks losing substantial transit flows and consequently also liquidity at its virtual trading points" as a result of the changes, Gascade managing director Christoph von dem Bussche said.
No other changes are suggested to the 2020 fee calculation method. A 75pc discount is still planned for entry and exit tariffs at storage connection points, while multipliers will be kept unchanged.
Market participants can submit comments on the draft regulations and tariffs until 18 May.
