Warsaw, April 2018€¦ · summary of general and detailed comments received from market participants concerning the proposed changes to the storage service rules of 18 june 2014,

SUMMARY OF GENERAL AND DETAILED COMMENTS RECEIVED FROM MARKET

PARTICIPANTS CONCERNING THE PROPOSED CHANGES TO THE STORAGE SERVICE RULES OF 18

JUNE 2014, AS FURTHER AMENDED ON 25 MAY 2015 AND AS FURTHER AMENDED ON 2 JULY 2015, ON 29 MARCH 2016, ON 8 MAY

2017, AND BY REVISION NO. 1 OF 10 FEBRUARY 2018 AND REVISION NO. 2 OF 24 FEBRUARY 2018

TOGETHER WITH THE POSITION OF THE STORAGE SYSTEM OPERATOR

GAS STORAGE POLAND SP. Z O.O. HAVING ITS REGISTERED OFFICE IN DĘBOGÓRZE

Warsaw, April 2018

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I. Introduction

Summarised below are the general and detailed comments submitted by market participants with regard to the proposed amendments to the Storage Service Rules of 18 June 2014, as amended on 25 May 2015, and as further amended on 2 July 2015, on 29 March 2016, on 8 May 2017, and by Revision No. 1 of 10 February 2018 and Revision No. 2 of 24 February 2018 (the “SSR” or the “Rules”) in the process of consultations held by Gas Storage Poland sp. z o.o. (“GSP”). The consultations were held in the period from 1 December 2017 to 15 March 2018. Next to the comments submitted regarding the draft of the Rules, the table presents the position of GSP. The comments in the table are arranged in the chronological order of their submission.

II. Summary of comments submitted in the course of the consultation process concerning the draft Rules together with the position of GSP

Item Submitting Party

Comment SSO's Position

1. Participant 1

General

The principles of tariff setting for gas storage services concerning mandatory stocks – independently of the storage facility for which the booking is made. Mandatory stocks are not used for commercial purposes so the parameters of the service are irrelevant, provided that they fall within the scope provided for in the Stockpiling Act. Therefore we suggest that a new product dedicated exclusively to mandatory stocks is introduced, which is priced uniformly regardless of the physical place where the stock is held.

If the above is not possible, we suggest that a product for GSF Kawerna is introduced which meets the minimum requires of the Stockpiling Act. The 90/40 Storage Service is a step in this direction but the parameters of gas withdrawal and injection in this service seem to be to high comparing to the minimum requirements set out in the Stockpiling Act. The package enables the injection of gas within approx. 54 days and its withdrawal within 22.5 days. A good solution would be to introduce a product for GSF Kawerna which fulfils the minimum requirements of the Stockpiling Act (i.e. 40 days for withdrawal and injection within 4 months in case when the stock is mobilised). Thereby the cost of such Storage Service for the Storage Customers which were not able to book Storage Services in reservoir storage facilities would have been optimised.

Terms of purchase of Storage Capacity – introduction of the possibility of booking Storage Services also for storage years starting

Clarification

GSP designs the portfolio storage products on the basis of both technical and economic analyses as well as market research, aiming to take into account, on one hand, the needs of market participants, and the technically and economically efficient operation of the Storage Facilities – on the other.

Moreover, in the current legal situation, according to the provisions of the Regulation on detailed principles of tariff design and calculation, and settlements in the trade in gaseous fuels of 28 June 2013, the rates for storage services have to be fixed, which means that the introduction of an auction mechanism is not allowed. The Company does not exclude the implementation of a mechanism for offering Storage Capacity on an auction basis in case when legal regulations are changed accordingly.

In light of the above, the comments cannot be taken into account under the current circumstances.

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at a different date than on the first day following the next Spring Maintenance Downtime Period (e.g. up to 4 years ahead). This will enable the booking of Storage Services in advance, which is necessary for ensuring the stability and predictability of business activity carried out in Poland, especially taking into account the Stockpiling Act. Such solution is applied by the TSO in the capacity allocation procedure on the auction platform (transmission capacity may be booked for each gas year separately). Currently, in case of the SSO, it is only possible to purchase of Storage Services starting from the next storage year, which significantly limits the possibility of long‐term business planning due to the risk of non‐availability of services in the future.

The introduction of an auction mechanism for the sale of Storage Capacity which has not been allocated based on the applications submitted by 31 January – such Storage Capacity could be made available on an auction basis where the offered price of Storage Capacity is decreased at each subsequent step until a predefined minimum price is reached (e.g. the price for the SSO’s cheapest storage facility), or on the basis of the notification of certain demand by the Storage Customer. Thereby, an optimum allocation of Storage Capacity by the SSO will be possible and auction participants will be able to purchase Storage Capacity for the purposes of holding their mandatory stocks at a better price

2. Participant 1

Detailed comment Clause 03/03/2010

We suggest that clause 3.3.10 is changed as follows:

“The order of priority established in clause 3.3.1 a) and in clause 3.3.7 a) shall be applicable to the allocation of Storage Capacity offered under Storage Services in the form of Bundled Units, Flexible Bundled Units Bundled and – in case of the GSF Kawerna – the 90/40 Storage Service.

This will prevent a situation (which is possible with the current wording of the Rules) where a Storage Customer interested in booking Storage Services for the purposes of holding a mandatory

Comment partially accepted

According to the currently applicable Rules (clause 3.3 but also clause 2.7) priority is given to bundled services which enable the creation of mandatory stocks provided that the Applicant requests their allocation for the purposes of creating mandatory stocks.

The provision of clause 3.3.10 has been clarified as follows:

The order of priority established in clause 3.3.1 a) and in clause 3.3.7 a) shall be applicable to the allocation of Storage Capacity offered under Firm Storage Services in the form of Bundled Units, including the Bundled Units making part of the 90/40 Storage Service, as well as in the form of Flexible Bundled Units comprising Injection Capacity and Withdrawal Capacity

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stock in the form of the 90/40 Storage Service or a Flexible Bundled Unit does not receive any Storage Capacity because of all Storage Capacity having been booked by another Storage Customer in the form of a Bundled Unit for commercial purposes. The Storage Capacity booked for mandatory stock purposes should always have priority over the booking of Storage Capacity for commercial purposes since the main objective of storage facilities in Poland is to ensure energy security of the country.

ordered jointly provided that they are equal or greater than the combined Injection Capacity and Withdrawal Capacity specified for the 90/40 Storage Service.”

3. Participant 1

Detailed comment

New clause before clause 3.3.2.1

We suggest adding a new clause with the following wording before clause 3.3.2.1:

“The order for the allocation of Storage Capacity under Firm Long‐Term Storage Services for the purposes of holding mandatory stocks:

1) 4‐year Firm Storage Service Bundled Unit, Flexible Bundled Unit, 3‐year 90/40 Storage Service Bundled Unit, Flexible Bundled Unit, 2‐year 90/40 Storage Service Bundled Unit, Flexible Bundled Unit,

2) Yearly Firm Storage Service Bundled Unit, Flexible Bundled Unit, 90/40 Storage Service.”

Thereby, independently of the form in which the mandatory stocks are held (Bundled Unit, Flexible Bundled Unit, 90/40 Storage Service), the priority of the allocation of the Storage Capacity will be guaranteed to the Storage Customer, which should be the primary goal of gas storage in Poland. Only capacities which are not sold for mandatory stock purposes should be offered commercially on the market.

Comment dismissed

In accordance with clause 3.3.1 of the Rules a situation where an application for a Storage Services Agreement for mandatory stock purposes is considered in the second place, i.e. after an application for a SSA for commercial purposes.

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4. Participant 1

Detailed commentAppendix 8 to the Rules, section 1.1.

We suggest that the wording “The trade shall be limited to Storage Capacity in the same form in which it was acquired by the Storage Customer on the Primary Market” be replace with the following wording:

“A Storage Customer may trade Storage Capacity it is eligible to in any configuration, regardless of the form it was acquired on the Primary Market.”

We also suggest deleting the Example indicated in that section.

The current wording creates an artificial barrier to the trade in Storage Capacity on the Secondary Market. The possibility of flexible sale of the unused Storage Capacity by the Storage Customer will enable better matching of the available products with the needs of Storage Customers (seller and buyer) while being neutral for the SSO from the economic perspective.

Comment dismissed

In order to ensure transparency and safety of secondary trading in Storage Capacity, the principle adopted in the Rules stipulates that secondary trading may only concern products in the same form in which they were acquired on the primary market.

5. Participant 2Participant 5

General comment

Participant 2 and Participant 5 welcomed the invitation to take part in the market screening to assess the demand for storage services of 12 September 2017, and the present consultations of the changes to the Storage Service Rules, which follow up on the earlier market screening exercise.

The 90/40 Storage Service will be implemented upon the entry into force of a new tariff of Gas Storage Poland sp. z o. o. (current tariff remains in effect until 31 March 2018), which means that market participant are not able to carry out a comprehensive assessment of the impact of this service.

Clarification

GSP provides services on the basis of the Storage Service Rules and the Tariff for Gas Storage Services. At this stage, the Company is not able to present the tariff aspects of the implementation of the new Storage Service as such questions will only be subject to the tariff procedure. Once the tariff including the 90/40 Storage Service is approved and the service starts to be provided, the Company will monitor its efficiency.


Detailed comment Clause 2.3.1.2.

Please add information on the period in which the 90/40 Storage Service is to be provided (see: description of the period of service provision for the Reverse Storage Service in clause 2.3.1.19).

Ideally, the period of service provision for the 90/40 Storage Service should be aligned with the period required under Article 25(4) of the

Comment dismissed

The Reverse Storage Service to which the comment refers is a special kind of a Short‐Term Storage Service offered in reservoir storage facilities during specific periods of the Storage Year, which justifies the definition of the period of the provision of this Storage Service.

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Act of 16 February 2007 on the stockpiling of crude oil, petroleum products and natural gas and on the operating procedures applicable in emergencies involving state fuel security or disturbances in the petroleum market (Dz.U. 2007.52.343, for consolidated text see: (Dz.U. 2017.1210.1387).

(http://prawo.sejm.gov.pl/isap.nsf/download.xsp/WDU20070520343/U/D20070343Lj.pdf).

However, in case of the 90/40 Storage Service such definition is not justified. The service is provided in the form of bundled units as a Long‐Term Storage Service or Monthly Short‐Term Storage Service, according to clause 2.6.1 and clause 6.1.4.2, i.e. at time periods stipulated in clause 2.3.2. which regulates the period of provision of the Long‐Term Storage Service and Short‐Term Storage Service.

Moreover, it should be noted that in accordance with 25(4) of the Act of 16 February 2007 on the stockpiling of crude oil, petroleum products and natural gas and on the operating procedures applicable in emergencies involving state fuel security or disturbances in the petroleum market (Dz.U. 2007.52.343, for consolidated text see: (Dz.U. 2017.1210.1387), i.e. the Stockpiling Act, which is referred to in the comment, mandatory stocks of natural gas are to be held from 1 October of a given year until 30 September of the following year.

The storage service offered by GSP consists in the injection of Gaseous Fuel into a Storage Facility or Group of Storage Facilities, use of the Working Volume of a Storage Facility of a Group of Storage Facilities by Storage Customers for the purpose of storing the injected Gaseous Fuel, withdrawal of Gaseous Fuel from the Storage Facility or Group of Storage Facilities. The technical parameters of the storage services provided by GSP are defined on the basis of technical capabilities of the storage facilities and taking into account the technical parameters of such facilities.

Accordingly, the creation of mandatory stocks of natural gas in storage facilities at the time indicated by the law makers, based on the services offered by GSP must cover the period required for the injection of gaseous fuel by the Storage Customer to the storage facility prior to the period stipulated by the Act.

At the same time, GSP does not restrict the possibility for the Storage Customer to purchase gaseous fuel held in the storage facility and injected by another Storage Customer, and the execution by the Buyer of a SSA for a term which will not include the injection of gaseous fuel (GSP does not represent any of the parties to the potential transaction to purchase gas at storage since as a storage system operator the Company is not allowed to engage in gas trading).

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7. Participant 3

General comment

It is not clear why the availability of the Reverse Storage Service is limited to 9 months, i.e. from December until August. Even though this service depends on the operation of the storage facility in the principal direction, it could be also used between September and November. As a short‐term service it could be used e.g. during singular days in October.

Clarification The period for the provision of the Reverse Storage Service as proposed in the Rules was established on the basis of the analysis carried out by GSP in respect of the technical capabilities to provide the service and takes into account the experience from the operation of individual storage facilities where the service is planned to be introduced. GSP believes that this period guarantees the fulfilment of GSP's obligations towards Storage Customers.

8. Participant 3

Detailed commentClause 2.3.1.20.

We suggest aligning the provisions for GSF Sanok and UGS Wierzchowice. Besides, the definition of “Gas Day” implies that it is a period from 6:00 am on a given day until 6:00 am of the following day.

2.3.1.20. The injection of Gaseous Fuel under the Reverse Storage Service may continue, as appropriate:

2.3.1.20.1 for the GSF Sanok, until the end of last Gas Day before the beginning of the Spring Maintenance Downtime Period for the Storage Facility making part of the Group of Storage Facilities, for which it starts the latest;

2.3.1.20.2. for the Storage Facility of UGS Wierzchowice, until the end of the last 6.00 a.m. of the Gas Day prior to the beginning of the Spring Maintenance Downtime Period for in which the Spring Maintenance Downtime Period starts.

Comment accepted

At the same time, clause 3.1.5 has been amended.

“until the end of the current Storage Year”

9. Participant 3


As above. 2.3.1.21.The withdrawal of Gaseous Fuel under the Reverse Storage

Service may begin not earlier than:

2.3.1.21.1. for the GSF Sanok, from the beginning of the first Gas Day after the end of the Spring Maintenance Downtime Period for the Storage Facility making part of the Group of Storage Facilities, for which it starts the soonest;

Comment accepted

At the same time, clause 3.1.5 has been amended.

“until the end of the current Storage Year”

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2.3.1.21.2. for the Storage Facility of UGS Wierzchowice, from the beginning of the first 6.00 a.m. of the Gas Day following the end of the Spring Maintenance Downtime Period in which the Spring Maintenance Downtime Period ends.

10. Participant 3

Detailed commentClause 2.3.1.24. We suggest clarifying that a Storage Customer using the Reverse Storage Service is obliged to submit a re‐nomination: “In case when the Storage Customer submits, under the Reverse Storage Service, a Nomination ...”

Comment accepted

11. Participant 3

Detailed commentclauses 2.7.16; 2.7.17

We request that clauses 2.7.16. and 2.7.17. be removed and the Storage Customers are allowed to freely use the capacity purchased as part of the bundled units for the purposes of holding their mandatory stock. Additional charges, if collected, would mean that Storage Customers are double charged for the same performance, which should not take place!

The approach taken by the SSO acts to the detriment of the Storage Customer and presents a balancing risk for the Storage Customer and their customers. Moreover, the withdrawal of gas from the UGS at a low rate could also adversely affect the operation of the facilities. As long as the mobilisation of the mandatory stock is not required, the technical injection/withdrawal capacity remains largely unused for an extended time period. This could lead to a lower rate of gas withdrawal and an extended period for which a high level of facility filling is maintained.

Additionally, it should be noted that according to the current regulations the Storage Customer does not submit a nomination for the withdrawal of a mandatory stock. The SSO follows the instructions of the TSO as to the delivery of the necessary gas volumes from mandatory stocks. The stock may be delivered for other market participants and not necessarily for the Storage Customer it is held by. The above may mean that the Storage Customer that booked storage capacity for the purposes of holding a mandatory stock does not actually use the withdrawal capacity that was allocated to it and for which it incurs costs.

Comment dismissed The principles of the Allocation of Storage Capacity with priority given to entities obliged to keep a mandatory stock rule out the possibility of the use of the capacity that was acquired by a Storage Customer on a priority basis for any other purposes not related to keeping the mandatory stock.

Any capacity within Bundled Units allocated for this purpose that remains unused should be therefore re‐offered to all facility users as part of Intraday Storage Service.

The capacity is made available to all users on a TPA basis, as set out in point 2.7.17. of the Rules. It should be noted that the provision of the capacity connected with a mandatory stock results in a simultaneous reduction of the injection or withdrawal capacity made available under other services provided on a TPA basis.

Due to the fact that the provision of the capacity connected with a mandatory stock results in a simultaneous reduction of the injection or withdrawal capacity made available under other services provided on a TPA basis, the Storage Customer, when purchasing the interruptible services and services based on a mandatory stock, would use the interruptible services as the firm services restricting by the same other Storage Customers a possibility to use the purchased services.

The mandatory stocks are managed and mobilised by the TSO subject to the competent minister for energy, and according to the provisions of the Stockpiling Act (Articles 51 and 52) and the TNC (clause 21.2) in case of disruptions of natural gas supply both the SSO and the entities obliged to

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maintain mandatory stocks are required to be ready for their mobilisation and to follow the instructions of the TSO in this regard.

Therefore, the Storage Customer’s right to freely dispose of the Storage Capacity is, by definition, excluded with respect to the Storage Capacity acquired for the purposes of holding their mandatory stocks. The injection, maintenance and mobilisation of such stocks are in principle aimed at ensuring energy security in case of an occurrence of an emergency situation rather than at serving the interest of the Storage Customers holding such stocks.

12. Participant 3

Detailed commentClause 3.2.1.4.3

We suggest that the requirements concerning both licences be aligned:

“a copy or photocopy of the Applicant's licence for supply of gaseous fuels, a copy or photocopy of a licence for foreign trade in natural gas....”

Comment accepted

13. Participant 3

Detailed commentclause 3.6.2.3

The principle according to which applications submitted after 20 March will be considered is not clear. If the intention of the provision is that such applications are not to be considered at all, we suggest adding the following sentence:

“Applications submitted after 3:00 p.m. of 20 March shall not be considered”.

Comment accepted

Application for a Long‐Term SSA with a starting date for the provision of Storage Services indicated as the beginning of the Storage Year, submitted after 3:00 p.m. of 20 March of the year in which the Storage Services are to commence, shall not be considered.

At the same time, in clause 3.6.2.15, the period for the consideration of applications for a Short‐Term SSA in the Storage Facility of UGS Wierzchowice or GSF Sanok was extended. The applications for the such Short‐Term SSA will be considered, in the period between 21 March until 15 July according to the order of their submission, i.e. with the application of the principles set out in clause 3.3.8.

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14. Participant 3

Detailed commentclauses 6.1.2; 7.1.2; 8.1.2

We request that the time lag to begin the execution of a renomination is shortened to 2 hours, and that the Storage Customer/Shipper is given the possibility of submitting renominations in accordance with the TNC.

The SSO and the TSO have an operator's account which is used to optimise the operation of UGS facilities and therefore there is no basis for the extension of the time lag to begin the nomination execution.

Independently of the above, current information indicating whether a given storage facility is in operation or not should published on the SSO’s website. Without such information the Shipper cannot freely use the contracted storage services.

Comment dismissed.

The starting time of a nomination/renomination is driven by the technical parameters of the GSF Sanok, GSF Kawerna and Wierzchowice SF and the need to enable effective renomination by other Storage Customers. Moreover, the primary purpose of the Operator's Account is to optimise the operation of storage facilities rather than, in each and every case, provide flexibility of services. If the first condition is fulfilled, i.e. the SSO has technical capabilities to ensure the interoperability of storage facilities with the transmission system using the operator's account, then such situation is directly reflected in the availability of services. Otherwise, the use of the operator's account solely for the provision of services could be seen as broadening the service portfolio.

The SSO publishes on its website all information required by the law, both on the community and national level. Moreover, services are provided in the groups of storage facilities and the Wierzchowice storage facility, and therefore the publication on the operation of individual facilities is not justified.

From the point of view of service provision, each Storage Customer obtains, at least once a day, 3‐day forecasts of the operability of storage facilities, or groups of storage facilities, under the concluded SSAs. Such forecasts fully enable the nomination / renomination of each Storage Customer in accordance with their needs. We do not see any connection of the current operation of storage facilities with the use of contracted services.

15. Participant 3

Detailed commentclauses 6.5; 7.4; 8.4

We request that the operating parameters (withdrawal and injection curves) for specific storage facilities are made available on request of a Storage Customer in an electronic format (MS Excel). The following data arrangement is suggested:

- column 1 – storage filling level,

- column 2 – withdrawal/injection capacity (withdrawal/injection capacities may also be described as a function of the filling level).

Comment dismissed

Currently, there is no practice among Storage System Operators in the EU to use this method of publication of the operating parameters. The parameters provided by GSP in the SSR and on the online information platform (OIP) fully reflect the operating capabilities of storage facilities.

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General comment

The Reverse Storage Service and Intraday Storage Service will take advantage of the capacity resulting from offsetting the submitted nominations. In the Rules, there is no clear provision which of the two services will have priority. Clause 2.12.1.11 stipulates that the capacity will be divided pro rata between the interested Storage Customers. Should it be inferred on the basis of this provision that the Reverse Storage Service and Intraday Storage Service have an equal priority? It is suggested that the provisions of the Rules are supplemented.

Comment dismissed The Reverse service will be provided on the basis of a duly executed SSA. If the Storage Customer submits a nomination under this service, the SSO will execute it first. Moreover, the capacity available in the form of the Intraday Storage Service is determined an ongoing basis and published on the Company's website, and are based on the remaining unused storage capacity. In case when the storage capacity is used up in full for other services, the SSO’s capability to provide the Intraday Service will either be non‐existent or limited, and then it is allowed not to publish the information on the availability of the Service. The pro rata allocation under the Intraday Service applies to those Storage Customers that submit nominations/renominations for this service for the same hours of the Gas Day.


General comment

The order of allocation of Storage Capacity for Short‐Term Storage Services – we suggest to introduce a single allocation priority for all monthly services – both for 11 and 1‐month services


See changes described in in section 32 of the response to comments.


Detailed commentWithdrawal Period / Reverse Storage Service

“The period in a Storage Year between the Autumn and Spring Maintenance Downtime Periods during which Storage Customers may withdraw Gaseous Fuel from a Storage Facility or Group of Storage Facilities” ‐ introduction of the definition of the Reverse Storage Service enables the injection during the withdrawal period (on an offsetting basis, but it still be injection). Proposed change to the definition:

Comment partially accepted The definition of the Withdrawal Period has been revised by adding the phrase "subject to the Reverse Storage Service” at the end. Withdrawal Period – the period in a Storage Year between the Autumn and Spring Maintenance Downtime Periods during which Storage Customers may withdraw Gaseous Fuel from a Storage Facility or Group of Storage Facilities, subject to the Reverse Storage Service.


Detailed commentInjection Period / Reverse Storage Service “The period in a Storage Year between the Spring and Autumn Maintenance Downtime Periods during which Storage Customers may deliver Gaseous Fuel to the SSO for injection into a Storage Facility or Group of Storage Facilities” ‐ introduction of the definition of the Reverse Storage Service enables the withdrawal during the injection period (on an offsetting basis, but it still be withdrawal). Proposed change to the definition:

Comment partially accepted. The definition of the Injection Period has been revised by adding the phrase "subject to the Reverse Storage Service” at the end. Injection Period – the period in a Storage Year between the Spring and Autumn Maintenance Downtime Periods during which Storage Customers may deliver Gaseous Fuel to the SSO for injection into a Storage Facility or Group of Storage Facilities, subject to the Reverse Storage Service

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Detailed commentReference Gross Calorific Value

Definition to be supplemented by a value in kWh/m3.

Clarification

The current provision corresponds to the standards accepted on the gas market – the provision remains unchanged.



“The information referred to in clause 2.12.1.1 shall not apply to Gaseous Fuel which is stored by the Storage Customer for the purposes of creating and maintaining the mandatory stock referred to in clause 2.7” – a typo correction.

Comment accepted


Detailed commentClause 2.3.1.20.2.

Proposed change of the provision wording: “The Storage Facility of UGS Wierzchowice until 6.00 hours of the Gas Day in which the Spring Maintenance Downtime Period starts.” to “The Storage Facility of UGS Wierzchowice until the end of the Gas Day preceding the Gas Day in which the Spring Maintenance Downtime Period starts.”

The change has been accepted in accordance with Comment No. 8.



Proposed change of the provision wording: “The Storage Facility of UGS Wierzchowice from 6.00 hours of the Gas Day in which the Spring Maintenance Downtime Period ends” to “The Storage Facility of UGS Wierzchowice from 6.00 hours of the Gas Day following the Gas Day the last day of the Spring Maintenance Downtime Period.”

The change has been accepted in accordance with Comment No. 9.



“(...) to submit a Renomination on the basis of information received from the SSO.” It is suggested that the provision is supplemented by the form in which the information is to be provided by the SSO, e.g. by the means of the OIEP, EDIG@S message.

Comment accepted

The wording “in the form of an EDIGAS (NOMRES) message” was added.

In case when the Storage Customer submits a Nomination exceeding the sum of Nominations submitted for the flow of Gaseous Fuel in the opposite direction, the Storage Customer shall be required to submit a Renomination on the basis of information received from the SSO in the form of an EDIG@S (NOMRES) message.

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Detailed commentClause 2.7.2.

“The possibility of creating a mandatory stock on the basis of Flexible Bundled Units offered as Firm Storage Service in the Storage Facility of UGS Wierzchowice or in a Group of Storage Facilities must be each time agreed with the SSO prior to the submission of the application for a SSA” – are such consultations required also in case when the maximum withdrawal capacity is ordered? Proposal to define the form of such consultation.

Comment accepted

In the provision of clause 2.7.2, a wording has been added which stipulates that the agreement on the possibility of creating a mandatory stock on the basis of Flexible Bundled Units offered in the form of a Firm Storage Service will be done “either in writing or by electronic mail”.



“in case when the Applicant submits an application for a SSA in order to create a mandatory stock, the Applicant shall be obliged to present the SSO with a copy of the declaration of the planned volume of the imports of Gaseous Fuel as submitted to the President of ERO in accordance with the procedure set out in Article 25.6 of the Stockpiling Act together with a confirmation of its submission or sending; provided that the copy of the decision of the President of ERO concerning the determination of the stock volume shall be presented by the Applicant to the SSO immediately following its delivery to the Applicant; „The Applicant is required, not later than 14 days before the first day of the imports, to inform the President of the Energy Regulatory Office; the application for a SSA should be submitted by 31 January. The outcome of the storage capacity allocation may have an impact on the import plan – the SSO should rely on the declaration and decision of the President of the Energy Regulatory Office rather than commercial plans of the Applicant. Proposed change to the wording of the Rules:

Comment accepted



“(…)upon a written request submitted (…)” Suggestion to restore the previous wording “(…)upon an application submitted (…)”

Comment dismissedThe change resulted from the need to clarify the provision. The word 'application' used in this clause is not equivalent to the application for a Storage Services Agreement being subject to procedures for applying for storage capacity.

In this case, the term means a written request (letter) of the Storage Customer regarding the possibility of allocating the mandatory stocks to the storage capacity held by the Storage Customer.

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Detailed commentClause 2.10.3.

The provision to be supplemented with the gross calorific value expressed in kWh/m3, or the number of digital places the value should be rounded off to be specified

Comment accepted

The SSO reserves the right to suspend the injection of Gaseous Fuel into UGS in case when the quality of Gaseous Fuel is characterised by a Gross Calorific Value lower than 38 MJ/m3 (10.556 kWh/m3) even in case when the TSO accepts such Gaseous Fuel for transportation in the Transmission System.



Proposed change of the provision wording: “a copy or photocopy of a licence for supply of gaseous fuels, photocopy of a licence for foreign trade in natural gas” to “a copy or photocopy of the licence for the supply of gaseous fuels”

Comment accepted

In accordance with comment no. 12


Detailed commentClause 3.2.1.4.4. Proposed change of the provision wording: “a declaration referred to in clause 2.7.6, if the Applicant submits the application for the purposes of creating a mandatory stock” to “the declaration referred to in clauses 2.7.6 and 2.7.7, of the Applicant submits the application for the purposes of creating a mandatory stock”

Comment dismissed

At the point of submitting an application for the execution of a Storage Services Agreement, the declaration referred to in clause 2.7.6 is sufficient.



Proposed change of the provision wording by deleting:

“3) Interruptible Storage Service – one‐year Bundled Unit,”, the Storage Service with these parameters is already included under “1) Interruptible Storage Service – 4‐year Bundled Unit, 3‐year Bundled Unit, 2‐year Bundled Unit, one‐year Bundled Unit,”

Comment accepted

Additionally, point 4) “Interruptible Storage Service – one‐year Flexible Bundled Unit” was deleted and in point 2) the wording “one‐year Flexible Bundled Unit” was added



Proposed change of the wording: “3) 10‐month Interruptible Storage Service – Bundled Unit,”

Similarly as in point 3.3.8.1, to “3) 10‐month Interruptible Storage Service – Bundled Unit, ‐ etc. up to 1‐month Interruptible Storage Service ‐ Flexible Bundled Unit,”

Comment accepted

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33. Participant 4

General comment

The planned availability of new storage capacity should be published by means of the OIP, and the date of such publication should be specified in the provisions of the Rules.

Clarification

The availability of new Storage Capacity depends on the progress of investment project development. The GSP initiates the procedures for making new storage capacity available as soon as the investment process is completed.

34. Participant 5


The proposed Injection Capacity of 0.769 MWh/h (excluding the Extension of Services) in combination with the proposed characteristics set out in clause 6.5.1 will allow for the injection of approximately 985 MWh. It is suggested that the Injection Capacity included in a Bundled Unit is recalculated.

Clarification

The adopted Injection Capacity ensures the injection of 1000 MWh in no more than 90 days. The provided characteristics also take into account interruptible storage capacity which are injected last, including storage capacity the injection of which is dependent on thermodynamic conditions in the caverns.

35. Participant 6


In clause 1.8.2.1 of the Rules, the word “illegally” should be deleted as legal advisors, tax advisors, accountants and consultants should not use confidential information concerning the Storage Services when providing services to other entities. The condition of “illegality” limits the scope of the prohibition in question in an unclear and unjustified manner.

Comment accepted

The comment was incorporated to the Rules on the basis of clause 1.7.7. as regards Revision no. 1 which came into force on 10 February 2018 In clause 1.8.2.1, the word “illegally” has been deleted.

36. Participant 6

Detailed comment Clause 2.3.3.5.2.

In point 2.3.3.5.2 of the Rules it is recommended to specify the prerequisites for the interruption or limitation of the provision of Interruptible Storage Services in an exhaustive manner, by defining a closed list. The current wording of this provision, which contains examples, empowers the storage system operator to interrupt or limit the provision of this service also without good reason.

Comment accepted

The comment was incorporated to the Rules on the basis of clause 1.7.7. as regards Revision no. 1 which came into force on 10 February 2018. Clause 2.3.3.5.2 of the Rules specifies a closed list of prerequisites for the interruption of Interruptible Storage Services.

At the same time, it should be clarified that the Company does not agree with the claim that the current wording of point 2.3.3.5.2 entitled the SSO to interrupt or limit Interruptible Storage Services without a justified reason. This clause does not provide for such authorisation.

Additionally, the provision in question should be construed in the context

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of other provisions of the Rules, including, among others, clause 2.2.1) of the SSR and the applicable legal regulations (including Article 4c of the Energy Law Act) according to which the SSO is obliged to provide Storage Services (including Interruptible Storage Service) on a non‐discriminatory and equal treatment of Storage Customers taking into account optimum and efficient use of Storage Facilities or Groups of Storage Facilities and Storage Capacity.

Consequently, it must be assumed that, under the current wording of Clause 2.3.3.5.2 of the Rules, the SSO is entitled to interrupt the provision of Interruptible Storage Services only for justified reasons, the non‐exhaustive list of which is included in the aforementioned provision.

37. Participant 6

Detailed comment Clause 2.7.

In the light of the wording of Article 24(3) of the Act of 16 February 2007 on stocks of crude oil, petroleum products and natural gas, the principles of proceeding in circumstances of a threat to the fuel security of the State and disruption on the petroleum market (Dz.U.2017.1210, as amended), clause 2.7 of the Rules should be supplemented by adding a decision imposing an obligation on the storage system operator to indicate, to the Storage Customer, the storage facility where the gaseous fuel constituting its mandatory stock is held (applies to GSF Kawerna and GSF Sanok).

Comment accepted

The comment was incorporated to the Rules on the basis of clause 1.7.7. as regards Revision no. 1 which came into force on 10 February 2018.In clause 2.7.7.6 of the Rules a provision was added according to which, in case of a mandatory stock being kept in a Group of Storage Facilities (GSF), the SSO – at the request of the Storage Customer – shall inform the Storage Customer in which Storage Facilities (making part of the GSF) the gaseous fuel constituting the mandatory stock created by such Storage Customer is kept.

38. Participant 6


In view of the general nature of the principles concerning the verification of applicants’ creditworthiness, it is proposed to add the following wording in the first sentence of clause 3.2.2.5 of the Rules: “in a manner that ensures equal treatment of all Applicants” or “in a non‐discriminatory manner”.

Comment accepted

The comment was incorporated to the Rules on the basis of clause 1.7.7. as regards Revision no. 1 which came into force on 10 February 2018. The first sentence of clause 3.2.2.5 of the Rules has been supplemented by the proposed provision.

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39. Participant 6

Detailed comment Clause 3.3.1.a)

Based the conclusions of the monitoring of the procedure for offering new and release of existing storage capacity in the Group of Storage Facilities Kawerna, Group of Storage Facilities Sanok and the Storage Facility of UGS Wierzchowice initiated on 13 January 2017, which was carried out by Participant 6, it is suggested that a reservation is added clause 3.3.1(a) of the Rules stipulating that the priority in obtaining an allocation of storage capacity for the purpose of creating a mandatory stock is not available to those applicants that have contracted sufficient Storage Capacity to create such stock but have not submitted a request or information according to the procedure set out in, respectively, clause 2.7.12 or clause 2.7.13 of the Rules. In the above‐mentioned procedure, the priority given to the applicant who was in possession of the storage capacity but failed to procure that such capacity is reclassified from “commercial” to “mandatory stocks” led to a significant reduction of the availability of Storage Services for to other applicants. According to the preliminary analysis, the lack of such a reservation may be considered as inconsistent with the Programme for ensuring non‐discriminatory treatment of the users of storage facilities (Compliance Programme) approved by the decision of the President of the Energy Regulatory Office of 14 May 2014, ref. No.: DRR‐7125‐7(6)/2014/Mko1, as amended by the decision of the President of ERO of 20 January 2017, ref. No.: DRR.WRD.7125.10.2016.Gmi1. Pursuant to section 3.2.1 of the Compliance Programme, Gas Storage Poland Sp. z o.o. is obliged to ensure non‐discriminatory treatment of the users of storage facilities, and to apply objective and transparent rules in the performance of the operator's statutory tasks. In particular, section 3.3.1.1 of the Compliance Programme states that it is considered discriminatory and contrary to the principle of equality to favour any entity, in particular the PGNiG Group, in access to the services provided by the storage system operator. Offering the possibility of concluding a long‐term SSA with priority resulting from point 3.3.1(a) of the Rules to an entity which has already contracted storage capacity for commercial purposes could constitute a form of preference for this entity in access to Storage Services. Moreover, in the above mentioned capacity offering procedure, the exercise of such right by Participant 3 made some entities unable to fulfil their statutory obligation to create

Clarification

In the Company's opinion, the comment should not be taken into account as the proposed solution would discriminate against those Storage Customers which have been allocated long‐term Storage Capacity for commercial purposes.

The proposed rule forcing Storage Customers to reclassify their Storage Capacity allocated for commercial purposes into mandatory stocks differentiates between Storage Customers in a way that does not seem to be sufficiently justified, however:

1) the principle of priority of allocation to entities obliged to create mandatory stocks, resulting from § 29(2) of the System Regulation, is

applicable only in the case of system congestion, i.e. in the case where

the available Storage Capacity enabling the creation of mandatory stock

is insufficient in relation to the demand for such Capacity. However, the

proposed solution is to be applied also in the case where there is no

congestion situation, i.e. when sufficient Storage Capacity is available

to create mandatory stocks on their basis by all obliged entities

(although not always in the cheapest storage facility);

2) the proposed solution limits access to cheaper storage facilities for the

purpose of creating mandatory stocks to those operators would like to

use, in parallel, more flexible and thus more expensive cavern facilities

for commercial purposes ‐ if the proposed solution is implemented,

such operators may have to create mandatory stocks in expensive

cavern facilities where they hold commercial stocks;

3) the proposed arrangement will discourage gas market participants

from using cavern storage facilities for commercial purposes and

therefore appears to run counter to the obligation of the GSP to ensure

an economically and technically optimal use and allocation of storage

capacity, as required under Article 17(1) and (2)(a) of Regulation (EC)

No 715/2009.

Referring to the arguments put forward by Participant 6, it should also be stressed that the lack of the proposed reservation (limiting the possibility of applying the priority order under clause 3.3.1(a) of the Rules) in the

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mandatory stocks by obtaining the allocation of storage capacity on the primary market. Most of these entities then used the ticket service based on the storage capacity contracted for purposes other than the creation or maintenance of mandatory stocks. In the opinion of Participant 6, in order to ensure the consistency of this provision of the Rules with the Compliance Programme, it should be stipulated that the priority in the conclusion of the Long‐Term SSA is only given to the extent that the applicant does not use Firm Storage Services for purposes other than the creation of mandatory stocks and to the extent that it is not covered by a SSA concluded for purposes other than the creation of a mandatory stock during the period covered by the application. In accordance with Article 9d(4) of the Energy Law Act (for consolidated text see: Dz.U. 2017, item 220, as amended, hereinafter the “Energy Law Act”) Gas Storage Poland Sp. z o.o., as the storage system operator, is responsible for the implementation of the Compliance Programme.

procedure for offering Storage Capacity launched in January 2017 did not prevent the performance of the statutory obligation to create a mandatory stock on the primary market. The applicants had the opportunity to apply for and obtain the allocation of Storage Capacity at the GSF Kawerna, which, however, was not used in most cases. Moreover, entities obliged to maintain mandatory stocks pursuant to the Stockpiling Act may also keep their stocks outside the territory of the Republic of Poland.

It should be noted, however, that obliged entities should have known the required level of mandatory stocks to be crated when planning their deliveries for the period from 1 April 2016 until 31 March 2017. After 1 April 2017, each obliged entity could quite accurately calculate the level of mandatory stocks it would be obliged to establish. It is therefore incomprehensible why the principles of allocation of Storage Capacity being currently adopted are to protect the interests of companies that did not apply for the allocation of Storage Capacity to mandatory stocks in a timely manner. It should be noted that in the period from 1 April 2016 till 30 September 2017 there was a real possibility of obtaining an allocation of Storage Capacity for the mandatory stock.

In the Company's opinion, the fact that a significant part of the applicants ultimately decided to use the ticket service as the form of fulfilling their obligation to create mandatory stocks was not due to the fact that they were in a situation of constraint and were not able to obtain Storage Capacity on the primary market. On the one hand, this was due to the strategy voluntarily chosen by these entities in the allocation procedure (including the submission of applications for the allocation of storage capacities in reservoir storage facilities, applying for SSA for terms shorter than 4 years or indicating a low level of the acceptable reduction of the allocation in case the application could not be accepted in its entirety), and on the other, it was mainly driven by economic and practical reasons supporting the use of the ticket service. There is no doubt that, from the point of view of a Storage Customer, not only it is a convenient service (the period of its provision corresponds exactly to the period in which there is an obligation to maintain mandatory stocks and the volume of stocks is not limited by the minimum size of a Bundled Unit), but also safe given that the execution of the agreement under Art. 24b of the Act on Stocks is subject to supervision by the President of URE.

In addition, it should be noted that the limited availability of the Storage Capacity that can be used for the creation of mandatory stocks, which is

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noted in the Comment, was primarily a consequence of an external circumstance, independent of the SSO, i.e. an amendment to the Stockpiling Act, which once and for all significantly extended the scope of the obliged entities required to create a mandatory stocks in a situation where a part of the Storage Capacity had been contracted in previous years for commercial purposes. This situation should not be expected to recur in the coming years, as new or released Storage Capacity (including Storage Capacity previously used for commercial purposes) will be first allocated to mandatory stocks.

It should also be stressed that all Storage Capacity currently allocated to commercial stocks or to mandatory stocks were allocated by the Company under TPA procedures, in which all market participants could participate on equal terms. Therefore, there is no basis for the allegation of unequal or discriminatory treatment of the applicants. Also, the principle of giving priority in offering storage capacity to entities applying for capacity “for mandatory stocks” has been and is explicitly articulated in the provisions of the Rules and applied by the SSO, in accordance with § 29(2) of the System Regulation.

40. Participant 6

Detailed comment Clause 3.3.3.

In order to facilitate access to the Storage Services for obliged entities required to maintain smaller volumes of mandatory gas stocks and in view of the need to develop competition in the gas market, it is suggested that, in clause 3.3.3 second sentence the words “the largest quantity” is replaced by the words “the smallest quantity”, and that it is further specified that, where the quantity of storage capacity allocated under the arrangements laid down in the second sentence of clause 3.3.3 second sentence exceeds the quantity indicated by the applicant, the remaining part of that capacity is to be allocated to the next applicant that applies for a quantity greater than the said applicant but smaller than that applied for by the other applicants. Under a procedure which was subject to our monitoring, bundled units which could not be allocated pro rata were allocated to that entity applied for the larger quantity. However, it appears that the allocation

Comment accepted

The comment was incorporated to the Rules on the basis of clause 1.7.7. as regards Revision no. 1 which came into force on 10 February 2018. In clause 3.3.3 of the Rules, a principle was introduced, according to which, in case of no possibility to allocate a Bundled Unit in the same priority category on a pro rata basis, due to the indivisibility of the Bundled Unit, such Bundled Unit should be allocated to the Applicant requesting the smallest quantity of Bundled Units.

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of storage capacity to an applicant that requests a smaller quantity would be more conducive to the development of competition in the gas market by facilitating the performance of the obligation to create mandatory stocks for smaller operators.

41. Participant 6

Detailed comment Clause 3.3.8.1. point 2

The 90/40 Storage Service will be provided as part of a bundled unit which is essentially a specific type of a flexible bundled unit. Therefore, in the opinion of Participant 6, there is no justification for granting priority in 3.3.8.1. point 2 of the RŚUM to applicants applying for the allocation of storage capacities under such service over applicants applying for the provision of firm Short‐Term Storage Services provided in the form of a flexible bundled unit.

Clarification

In the opinion of the Company, maintaining the order of allocation where the 90/40 Storage Service is given priority over a Flexible Bundled Unit, as proposed in the amendment of the SSR, is justified, as 90/40 Storage Service guarantees the parameters necessary to create a mandatory stock, while the creation of such a stock based on the Flexible Bundled Unit is not always guaranteed. On the other hand, the 90/40 Storage Service has inferior parameters than the a Bundled Unit, which is optimal the point of view of technical operation of the Storage Facility. Therefore, the order of allocation proposed in clauses 3.3.2.1 and 3.3.8.1 of the SSR (Bundled Unit, 90/40 Storage Service, Flexible Bundled Unit) is justified.

42. Participant 6

General comment

In the opinion of Participant 6, it would also be desirable for the storage system operator to carve out a pool of bundled units with lower parameters, so that entities with mandatory stocks set at a level lower than 1000 MWh could gain direct access to Storage Services commensurate with their demand.

Clarification

Comments on the size of the Bundled Units made in previous years by the gas market participants have been analysed in detail by the Company and have been taken into account to a large extent. In particular, in the first half of 2017, the working volume comprised in a Bundled Unit was reduced by the SSO by over five times, i.e. from the level of 5,486 MWh to the level of 1000 MWh. In 2017, the Company also carried out procedures for offering Storage Capacity, in the course of which participants were allocated Storage Capacity in the form reduced Bundled Units for the purposes of creating mandatory stocks. In the Company's opinion, the reduction of the Bundled Unit to the level of 1000 MWh was a significant step towards appropriate addressing of the needs of the gas market resulting, among others, from the entry into force of the amendment to the Stockpiling Act of 22 July 2016, which extended the scope of entities

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covered by the Act.

In general, the Company agrees with the suggestion but, at the same time, would like to make it clear that its implementation requires the Company to carry out technical, economic analyses as well as market research to determine the appropriateness of creating a pool of “smaller bundled units” and the optimum number and size of such “smaller bundled units”, taking into account the needs of market participants as well as technically and economically efficient operation of the Storage Facilities. The Company will carry out appropriate analyses, but due to the time needed to do so, the potential offering by the SSO of any such pool of “smaller bundled units” will be possible at a later date, after the conclusion of the current procedure for offering Storage Capacity.

43. Participant 6

I would like to bring yet another comment to your attention, as regards the wording of the Rules which was made subject to public consultations on 1 December 2017. With regard to clause 3.3.2.1 of the Rules, I suggest that one‐year, two‐year, three‐year and four‐year bundled units are given equal priority in the order of allocation of storage capacity under firm Long‐Term Storage Services as regards applications for storage capacity to create and hold mandatory stocks. In my opinion, with regard to entities that have applied for the execution of a SSA in order to comply with their statutory obligation, there is no justification for differentiating the order in which these capacities are allocated, depending on the period indicated in the application.

Comment accepted

The comment was incorporated to the Rules on the basis of clause 1.7.7. as regards Revision no. 2 which came into force on 24 February 2018.

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Comments to the Storage Service Rules of 18 June 2014, as amended on 25 May 2015, and as further amended on 2 July 2015 , on 29 March 2016 and on 8 May 2017 (hereinafter the “Rules”), and by Revision No. 1 of 10 February 2018 and Revision No. 2 to the Rules of 24 February 2018.

1. Participant 2

Participant 2 hereby requests Gas Storage Poland sp. z o.o. (hereinafter “GSP”) to change the wording of clause 3.3.10 of the Storage Service Rules of 18 June 2014, as amended on 25 May 2015, and as further amended on 2 July 2015 , on 29 March 2016 and on 8 May 2017 (hereinafter the “Rules”) and including the revisions of 10 February 2018 and of 24 February 2018 being currently subject to consultation (hereinafter the “Rules”).

The proposed amendment aims to effectively introduce a priority for undertakings which implement the provisions of the Act of 16 February 2007 on stocks of crude oil, petroleum products and natural gas, the principles of proceeding in circumstances of a threat to the fuel security of the State and disruption on the petroleum market (Dz.U.2017.1210) and the Act of 7 July 2017 amending the Act on stocks of crude oil, petroleum products and natural gas, the principles of proceeding in circumstances of a threat to the fuel security of the State and disruption on the petroleum market and some other acts (Dz.U.2017.1387), hereinafter jointly referred to as the “Stockpiling Act”).

The current wording of the Rules limits the priority in the allocation of storage capacity by GSP made available as part of storage services exclusively in the form of Bundled Units (the terms “Bundled Unit” and “Flexible Bundled Unit” have the same meaning as in the definitions of the Rules). Introduction Participant 2 is subject to the obligation to create and maintain natural gas stocks under the Stockpiling Act. On 25 July 2017 , Participant 2 concluded an agreement with GSP for the provision of natural gas storage services in the relevant volume of natural gas and in the relevant time period, fulfilling the obligation imposed on the Company by the provisions of the Stockpiling Act. At the same time, it should be stressed that pursuant to the provisions of Art. 24 section 1 a) of the Stockpiling Act, an energy company


See the clarification for comment no 2.

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conducting business activity related to foreign trade in natural gas and an entity importing natural gas are obliged to maintain mandatory stocks of natural gas in order to ensure the supply of natural gas to the Republic of Poland and to minimise the consequences in the event of a threat to the fuel security of the state. Proposed amendment to the Rules Participant 2 requests for the following wording to be given to clause 3.3.10 of the Rules: “The order of priority established in clause 3.3.1 a) and in clause 3.3.7 a) shall be applicable to the allocation of Storage Capacity offered as part of Storage Services in the form of Bundled Units or Flexible Bundled Units”.

Please note the previous wording of clause 3.3.10 of the Rules: “The priority established in clause 3.3.1 a) and in clause 3.3.7 a) shall be applicable to the allocation of Storage Capacity offered as part of Storage Services in the form of Bundled Units.” Justification

Section 3.3.1 a) of the Rules of Gas Storage Poland sp. z o.o. concerns the order of priority in the execution of agreements with applicants while giving preference to those companies submitted an application for a long‐term storage services agreement (hereinafter referred to as “SSA”) declaring, in the application that they are required to maintain mandatory stocks pursuant to the provisions of the Stockpiling Act, and the application for a long‐term SSA is submitted to create such mandatory stock and the ordered services enable the creation of such stock and do not go beyond what is necessary for its creation.

At the same time, clause 3.3.10 of the same Rules limits the priority specified in clause 3.3.1(a) thereof exclusively to the allocation by GSP of storage capacity in the form of Bundled Units.

It should be noted that the legislator's objective in implementing the provisions of the Stockpiling Act was, among other things, to ensure the supply of natural gas to the Republic of Poland and to minimise the effects of threats to the state's fuel security. This means that regardless of the choice of product offered by GSP – be it a Bundled Unit or Flexible Bundled Unit – priority should still be given to making storage capacity available to entities which declare to GSP that they are obliged to maintain stocks in accordance with the provisions of

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the Stockpiling Act, and the application for the conclusion of a long‐term SSA is submitted in order to create a mandatory stock and the ordered storage services allow for the creation of such a stock without exceeding the scope which is necessary for its creation. In other words, priority should be given in each case to the creation and maintenance of mandatory natural gas stocks rather than to the commercial interests of companies contracting natural gas storage services.

It is worth noting that the selection of the Flexible Bundled Unit by companies operating on the natural gas market in Poland is dictated by the justified optimisation of gas storage costs by obliged entities under the Stockpiling Act. In the case of our Company, the volume of mandatory reserves determined by the decision of the President of the Energy Regulatory Office is significantly lower than the volume of the Bundled Unit offered by GSP. In view of the above arguments, GSP is urgently requested to respond to the change to the Rules proposed by Participant 2

Documents

Warsaw, April 2018€¦ · summary of general and detailed comments received from market participants concerning the proposed changes to the storage service rules of 18 june 2014,