Security of gas supply and conditions for access to natural gas transmission networks

The European Federation of Energy Traders is pleased to provide the following response. The European energy industry is facing exceptional challenges. We are in the midst of a global shortfall of gas and there is risk of further disruption to Russian gas supplies. Unusually low storage levels at the start of the heating season have prompted calls for rigid obligations to guarantee higher storage levels in future.

Gas Infrastructure Europe (GIE) shares the EC’s objectives of fostering energy security while transitioning towards a carbon-neutral economy. Since 2017, GIE has carried out several studies and developed the knowledge to allow SSOs to offer market-based services, guarantee system optimization and ensure the security of supply.

On March 23, 2022, the Commission made a legislative proposal to regulate gas storage facilities. The proposal amends the EU Security of Supply Regulation (SoS Regulation) as well as the Gas Market Regulation. The Initiative Energien Speichern e. V.

The turbulence of the energy market regarding volatile natural gas prices and especially the threat of a sudden significant disruption of Russian gas supplies, affects Europe as a whole. Without a doubt, a policy to mitigate its consequences would become more effective if implemented at EU rather than only at national -Member State- level. In this respect, DEPA Commercial S.A.

New and major threats are being experienced by the continental gas sector and a coordinated action at European level is needed. Enel therefore welcomes the intention of the European Commission to revise the Regulation (EU) 2017/1938, which aims to improve the resiliency of the gas sector and ensure that security of gas supply is fit to the current challenges.

Dear Sir/Madam On behalf of our clients JSC "NJSC Naftogaz of Ukraine" ("Naftogaz") and Gas Transmission System Operator of Ukraine LLC ("GTSOU"), both wholly owned by the Ukrainian state, we hereby submit their joint comments to Amending Regulation EU 2017/1938 concerning measures to safeguard the security of gas supply (the "SoS Regulation") and Regulation (EC) 715/2009 on conditions for access to natural gas…

The Austrian Federal Economic Chamber (WKÖ) recognizes a secure and stable energy supply as an essential prerequisite of a thriving economy. National gas storage facilities herby play an essential role. However, affordability and the fair sharing of (financial) burdens have to be equally considered. In this context we would like to comment on the proposed regulation.

IFIEC, representing energy intensive customers, welcomes and in many aspects supports, the European Commission's proposal for securing the EU’s winter gas supply. Gas storages are essential in the gas supply chain for several reasons, namely security of supply, seasonal flexibility, price level (liquidity) and price stability (volatility).

Teréga welcomes the EC’s legislative proposal to address the very significant risks for security of supply within the EU resulting from the particular geopolitical situation. Teréga shares the Commission's objective but considers that imposing the same binding measures on all countries can be counterproductive, putting at risk the well functioning systems of countries like France that already have a regulation in…

Repsol welcomes the opportunity to provide comments to the European Commission on the proposal amending Regulation (EU) 2017/1938 and Regulation (EC) n°715/2009. Repsol is committed to ensure the security of gas supply, and thus we support the initiative of the Parliament and the Council on supply in the European Union due to the energy dependence of third countries and a possible disruption to Russian gas flow.

Plinovodi, the Slovenian gas TSO, has summarized remarks on European Commission’s Proposal for the REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Regulation (EU) 2017/1938 of the European Parliament and of the Council concerning measures to safeguard the security of gas supply and Regulation (EC) 715/2009 of the European Parliament and of the Council on conditions for access to natural gas…

Being a leading Ukrainian energy utility company, DTEK is unequivocally committed to achieve carbon neutrality by 2040 and strongly advocates decreasing the dependence on fossil fuels within the shortest possible period of time. We would also appeal to European and global energy companies to stop any dealings with the russian energy sector that channels money into support the outrageous war against Ukraine.

Energie Beheer Nederland (EBN) is public energy company, owned 100 percent by the Dutch state; our shares are administered by the Dutch Ministry of Economic Affairs and Climate. EBN plays a central role in designing the public-private partnership in relation to energy production in the Netherlands and is a minority shareholder in around 200 joint ventures in gas production, geothermal and CO2 storage.

IOGP believes that an efficiently functioning, interconnected and liquid energy market with free and transparent price formation for competing energies from a diversity of domestic and global suppliers, intelligent demand-side solutions, and with a stable legislative framework will best ensure cost-efficient, secure supplies to consumers.

EDF highlights that the decline of the use of fossil fuels in the EU energy mix is a necessity to reach the European climate objectives following different pathways and pace depending on the initial energy mix of each country.

UPRIGAZ, which brings together the players active in the production gas chain through transport to final customers and wholesale intervention storage, adheres to the general principles of this proposal for a regulation amending Regulation 217/1938. 1 — UPRIGAZ agrees with the target of filling storage around 80 % for winter 2022/23; this rate should be increased to 90 % for the following years.

Filed in French · English published by the European Commission

Welcome the Commission’s legislative proposal. Please find below a summary of commitments (amendments and detailed justifications agreed): 1a Mandatory Filling target of 80 % is fit for purpose to ensure the use of gas storage as a fundamental element of a comprehensive security of supply policy.

Filed in Spanish · English published by the European Commission

Eurogas is the association representing the European gas sector. Our members are active throughout the entire gas value chain, covering production, trading, distribution, and supply of natural gas, biomethane and hydrogen. Eurogas recognises that the current market dynamics emerging from the geopolitical situation requires particular attention.