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Consultations on the Draft Amendment No. 2 of November 20, 2024 to the Storage Code version 001

Gas Storage Poland sp. z o. o. announces the beginning of consultations on the draft of Amendment No. 2 to the Storage Code version 001 with Amendment No. 1, and invites all interested parties to participate in the consultation process.

The contents of the Draft Amendment No. 2 of November 20, 2024 to the Storage Code version 001 and the Comment Submission Form can be found below:

the Draft Amendment 2 of November 20, 2024 to the Storage Code version 001
Comment Submission Form
the Storage Code version 001 draft Amendment No. 2 with tracked changes – includes changes shown in the Draft Amendment No. 2 to the Storage Code version 001

Any comments concerning the content of the Draft Amendment No.2 to the Storage Code version 001 should be sent using the Comment Submission Form, to the following email address: gsp@gas-storage.pl by 20 December 2024.

Amendment No. 2 to the Storage Code provides for the following:

in Part II of the Storage Code, Chapter 6, the introduction of new provisions setting out the rules for the reduction of Storage Capacity under existing Long-Term SSAs in favour of the Transmission System Operator (TSO) in case when demand for Storage Capacity notified by the TSO for the following year is higher than the available Storage Capacity. The proposal provides for a two-stage reduction, i.e. voluntary and mandatory one. In case when the volume of voluntarily declared reduction of Storage Services does not cover the demand of the TSO, a mandatory reduction takes place. As part of the mandatory reduction, the Storage Capacity covered under SSAs will be reduced proportionally for each Storage Customer starting from the following Storage Year, in a way that ensures that the TSO’s declared demand is satisfied. Mandatory reductions will not apply to Storage Capacity allocated or used for the purpose of holding mandatory stocks of natural gas.

Rationale: in the consultation of Amendment No. 1 to the Storage Code, one of the market participants submitted a proposal to delete 6.4.2 of the Storage Code, which provides that the TSO’s demand notified pursuant to § 37a of the System Regulation and Article 4c(2) and (3) of the Energy Law, does not constitute a basis for reducing the Storage Capacity under previously concluded SSAs. The comment submitted did not relate to the scope of Amendment No. 1 to the Storage Code, which was subject to consultation, and was not taken into account given that, according to the SSO’s position on comments 1 and 2 to the draft of Amendment No. 1 to the Storage Code, its acceptance requires a prior consultation with market participants. In view of the above, the SSO has drawn up a proposal to amend the provisions of the SSO and hereby submits it for consultation.

in Part III of the Storage Code, Chapter 9, the introduction of new final provisions concerning the procedure for the allocation of Storage Capacity for the Storage Year 2025/2026. The parameters of Firm Long-Term Storage Capacity to be offered by the SSO to Market Participants for the Storage Year 2025/2026 will allow the respective volume of Gaseous Fuel to be withdrawn into the transmission system within 50 days. Under the above procedure, a portion (pool) of the Storage Capacity comprising Firm Long-Term Capacity in the form of Bundled Units will be set apart, and such pool will be offered as Interruptible Long-Term Capacity in the form of Bundled Units in the absence of the legal requirement for the withdrawal period, starting from 6:00 a.m. on 1 October 2025; the above dedicated pool of Storage will be subject to a separate Storage Capacity allocation procedure. In addition, in the aforementioned case when the continuity of regulation with regard to the time of withdrawal is not maintained starting from 6:00 a.m. on 1 October 2025, the parameters of the Storage Capacity made available in the Application Procedure for the Storage Year 2025/2026 will change.

Rationale: The proposed changes aim to ensure stable parameters of the Storage Capacity and transparent rules for the Storage Capacity allocation procedure for the Storage Year 2025/2026 under the dynamically changing regulatory environment the SSO operates in (as at the end of 2024), in particular taking into account the following:

the effectiveness of the legal requirement to ensure that the parameters of mandatory stocks of natural gas maintained in storage facilities allow for the delivery of their total volume to the gas system within 50 days, which, pursuant to Article 70d of the Stockpiling Act, expires on 30 September 2025; and
a government bill being underway, which provides for the above requirement for withdrawal times to apply as a permanent solution for an indefinite period starting from 1 October 2025.

ARCHIVAL CONSULTATIONS

Consultations on the Draft Amendment No. 1 of July 19, 2024 to the Storage Code version 001

Gas Storage Poland sp. z o. o. announces the beginning of consultations on a draft amendment to the Storage Code version 001 (the Storage Code) and invites all interested parties to participate in the consultation process.

The contents of the Draft Amendment No. 1 of July 19, 2024 to the Storage Code version 001 and the Comment Submission Form can be found below:

the Draft Amendment No. 1 of July 19, 2024 to the Storage Code version 001
Comment Submission Form
the Storage Code version 002 draft no. 1 with tracked changes – includes changes shown in the Draft Amendment No. 1 to the Storage Code version 001

Any comments concerning the content of the Draft Amendment No.1 to the Storage Code version 001 should be sent using the Comment Submission Form, to the following email address: gsp@gas-storage.pl by 19 August 2024.

Rationale for the proposed amendments:

The document being presented for consultation provides for the incorporation of new final provisions to Part III of the Storage Code, enabling the conversion of Interruptible Bundled Units contracted by Storage Customers to Firm Bundled Units, which results in particular from the extension, as of 13 June 2024, of the maximum period for the delivery of the total quantity of mandatory stocks of natural gas to the gas system of 50 days to the period starting from 6.00 a.m. on 1 October 2024 and ending at 6.00 a.m. on 1 October 2025, in accordance with Article 13(2) of the Act of 23 May 2024 on the energy voucher and amending certain acts to cap the prices of electricity, natural gas and system heat (Journal of Laws, item 859), amending Article 70d of the Stockpiling Act.

The period to which the conversion will apply will start at 6.00 a.m. on 1 October 2024 and will end by 6.00 a.m. on 1 October 2025, or on the date of termination of the Storage Services Agreement, whichever occurs first.

Consultations of the Storage Code version 001

Gas Storage Poland sp. z o. o. (“GSP” or “OSM”) announces the start of consultations concerning the draft Storage Code Version 001 (“Storage Code”) dated 21 January 2022 .

The contents of the draft Storage Code and the Consultation Sheet can be found below:

Any comments should be submitted using the Consultation Sheet to the following email address: gsp@gas-storage.pl by 21 February 2022.

The draft Storage Code has been prepared by the SSO in performance of the obligations introduced under the Energy Law Act of 20 May 2021 amending the Energy Law and certain other acts (Dz.U.2021.1093, “Energy Law Amendment”), which entered into force on 3 July 2021.

The Energy Law Amendment introduced, among other things, the obligation for the SSO to prepare a storage code, to carry out public consultations on the draft storage code or the amendments thereto, and to submit the document to the President of the Energy Regulatory Office (“President of the ERO”) for approval.

The Storage Code, once approved by the President of the ERO and published in the ERO Industry Bulletin will come into force on the date indicated in the approving decision of the President of the ERO. As soon as the Storage Code comes into force, the Storage Service Rules will be repealed, and therefore, by virtue of law, the Storage Code will become a part of the existing storage service agreements (“SSA”).

The draft Storage Code presented for consultations has been prepared by the SSO with the requirements set out in Article 9g (3a) of the Energy Law Act. In the draft Storage Code, the rules concerning the allocation of storage capacity have not changed.

The provisions supplementing the Storage Code, which are concerned with creditworthiness assessment as well as the conclusion and termination of SSAs, insofar as they have not been regulated in the Storage Code, are included in the published draft General Terms and Conditions for Storage Services Agreement version 001, which are not subject to consultations.

In parallel to the above-mentioned documents, the Company has published, for information purposes, the draft of the consolidated text of the Terms and Conditions of the Storage Services Platform version 005 (“draft SSP Terms and Conditions version 005”), which incorporates the changes resulting from the draft Storage Code version 001, shown in markup mode. The changes are made for clarification only. The current rules for the use of the Storage Services Platform remain unchanged.

Draft SSP Terms and Conditions version 005 – not subject to consultations.

Documents: