There is uncertainty regarding the report of fundamental data under provisions of Article 9(7)(b) of Commission Implementing Regulation (EU) No 1348/2014. - quote: „(b) amount of gas in stock at the end of the gas day, inflows (injections) and outflows (withdrawals) for each gas day,“
Our question is what does the amount of gas in stock mean:
a) Does it refer to the physical withdrawal/injection amount of gas which is measured in the storage facility entry/exit point?
b) Does the withdrawal/injection amount of gas refer to the sum of allocated quantities (for all users) under the accepted nominations?
There is a possibility that there could be a difference between the measured and allocated quantities which are daily recorded on the open balancing account between OSS and TSO.
Regarding the possible difference in amounts in case a) and case b) we need to know which data we send as fundamental data.
Regarding the mentioned above a connected issue is raised in Article 9(9) of Commission Implementing Regulation (EU) No 1348/2014.
- quote : „9. Market participants or Storage System Operators on their behalf shall report to the Agency and, at their request, to national regulatory authorities the amount of gas the market participant has stored at the end of the gas day. This information shall be made available no later than the following working day.“
If the SSO reports on behalf of his storage users the only possible data to report is allocated withdrawal/injection quantities (equal accepted nominations), because this is the amount used to reived the stored gas (users balance account) for each user on a daily basis. We are concerned that there could be a slight difference in amounts regarding the fundamental data of the whole storage and the amounts per user level.
Answer: In order to harmonize the reporting, both SSOs and MPs or SSOs reporting on behalf of MPs shall use allocated data/nominations for reporting according to Articles 9(7) and 9(9) of Commission Implementing Regulation (EU) No 1348/2014.