## Eu Tariffs Code Eu Tariffs Code Code Now In Comitology Process Member States Will Next Meet In April

Inter-services consultation not due to start until late April 
Not expected to have final TAR NC for April April now a pre-comitology meeting Impact assessment still not approved 

## Formal Comitology Meeting In June

Member States could vote on English text (requires 
unanimous MS approval) or could vote to have additional meeting 

## Eu Tariffs Code

Additional meeting (if required) likely to be in 
September/October 
EC's aim is to finish Comitology prior to Madrid Forum 
in October 
Once text passed by Member States then governance 
process between EU Council, EU Parliament and EC (this takes several months) 
Possible "entry into force" in January 2017 (if code 
approved by MS in June) 
Could be delayed until April 2017 if 2nd  comitology 
meeting required 
 

## Feedback At Informal Ms Meeting Held 10 March

MSs went Article by Article through the TAR NC 
Text difficult to read 
Not clear what problem is being solved and would welcome the 
respective explanation in the Impact Assessment 
Five main issues for April meeting: 
1. ACER opinion (main point of contention) 2. Implementation period 3. Asset cost split 4. Storage 5. Interruptible pricing 

## Eu Tariffs Code - Acer Review And Guidance

Concerns by TSOs over ACER's role post consultation on 
proposed charging regime 
ACER to review consultation document plus summary and evaluation 
of consultation responses 
ACER can make recommendations to which NRA must take "utmost 
account" 
Concerns that this does not align with competence of ACER as 
outlined in Regulation (EC) 713/2009 
In addition, ACER's ability to request information from NRA and 
requirement for NRA to respond within 30 days not foreseen by Third Energy Package. 
ACER review will slow down implementation process 
ENTSOG believes ACER's should have monitoring and reporting role 
instead 

## Eu Tariffs Code - Acer Review And Guidance

TAR NC has obligation on ACER to analyse regulatory approaches 
applied in EU and produce "Guidance Document" 
Aims at producing transparency on allowed revenues 
Concerns by TSOs that this goes beyond scope of TAR NC 
Code is about harmonising allocation of costs to users and not 
about harmonising the setting of allowed revenues. 
ENTSOG view is that ACER does not have the competence for 
this task 
Since setting allowed revenue is outside of scope of TAR NC, 
ENTSOG supports the deletion of this article. 
 

## Eu Tariffs Code - Implementation At March Informal Ms Meeting

Different application dates dependent of type of obligation 
Default applicable date is 1 January 2018 
Publication requirements as of entry into force 
Change to reference price methodology linked to regulatory 
period 
Likely GB deadline is between June - October 2019 to **start** 
process 

## Text Considered To Be Too Complicated

Different application dates for different Member States Linkage between RPM and other parameters (e.g. multipliers).. 

## Eu Tariffs Code - Implementation

EC has subsequently proposed change for applicable 
date for **all of obligations in code** to be 17 months 
after entry into force  
Transitional arrangements and mitigating measures 
remain deleted. 
The proposed revised implementation timescale will be 
too short for a proper and consistent implementation in GB regime.  
National Grid and ENTSOG pushing back against 
this revised implementation period 
ENTSOG proposing **24 months** implementation 

## Eu Tariffs Code - Entsog Main Concerns Entsog To Develop Position Paper

Implementation timescales 
Cost allocation test 
 
ACER consultation review 
Code focus on short term shipper 
behaviour 
ACER revenue calculation 
 
CWD as the counterfactual 
guidance (associated transparency) 
Specific nature of interconnectors 
 
Financial stability of TSOs 
Report on specific capacity 
Asset cost split 
products 
Within-day pricing: removal of flat 
Implementation monitoring article 
rate 
Smaller issues 
Storage 
List of non-transmission services Simplified model 

## Eu Tariff Code And The Gb Charging Review Opportunity To Improve Gb Framework As A Key Driver

Consider EU compliance in any development and how options 
fit with GTCR policy 
Chance to drive improvements with industry not just deliver EU 
Compliance (details discussed in NTSCMF) 
Industry workshop held 22 March 

## Incremental Capacity Amendment To Cam Incremental Capacity Amendments To Cam Nc

Process for the incremental capacity/CAM NC amendment 
comitology is same as for TAR NC 
MS meeting of 10 - 11 March: EC to come back at April meeting re 
Order of offer of conditional firm and interruptible capacity after nonconditional firm capacity 
Extending period for offering incremental (and existing) capacity 
beyond 15 years 
Frequency of incremental process Amount of capacity to be set aside in alternative CAM 
Solutions for booking platform cooperation 
Incremental reality check study (EU-Russia Gas Advisory Council) 
Groups involved: ENTSOG, Gazprom, IFIEC, IOGP and GIE