text: https://www.entsog.eu/sites/default/files/2022-04/SO0035- 22_Summer_Supply_Outlook_2022_BOA_Rev8.1_220427%20for%20publication.pdf

text: Opinion No 05/2022

text: E.g. to Ukraine 3 REPowerEU Action plan, p.1. “In March 2022, EU leaders agreed in the European Council to phase out Europe’s dependency on Russian energy imports as soon as possible.” https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=COM%3A2022%3A230%3AFIN&qid=1653033742483

text: Opinion No 05/2022

text: In ENTSOG’s model, meeting gas demand (consumption) take priority, and next injections into storages may start to meet the filling targets. 5 And also Bulgaria, Latvia and Serbia. See ENTSOG’s Summer Outlook 2022, p.20. 6 See ENTSOG’s Summer Outlook 2022, pp. 4, 20-25. 30% to 60% of storage filling level in 3 European countries (NL, DE, IT) representing 50% of the total European storage capacities, and 5% to 35% filling level in Eastern Europe (LV, PL, CZ, SK, HU, AT, HR, RS, RO and BG).

text: Opinion No 05/2022

text: EU and some Energy Community Countries like Serbia and Republic of North Macedonia, according to ENTSOG’s modelling. 8 From April to October in the Outlook, but the end of the injection season may vary per Member State. 9 The difference between prices paid for gas in Summer and prices at which gas can be sold in Winter. 10 REPowerEU Communication: Joint European action for more affordable, secure and sustainable energy, p.1 https://eur-lex.europa.eu/resource.html?uri=cellar:71767319-9f0a-11ec-83e1- 01aa75ed71a1.0001.02/DOC_1&format=PDF

text: Opinion No 05/2022

text: ENTSOG Summer Outlook 2022, p. 9. Storages utilization during the winter 2021-2022 is on the lower range. compared to the previous seven years. 12 Idem, p.10. 13 Storage capacity of Sweden is very limited, amounting to only 0.01 TWh of WGV. 14 In order to ensure continuity of supply and minimize the effects of threat to the state's fuel security, the occurrence of an emergency in the gas network or an unforeseen increase in natural gas consumption 15 Representing 39% of all gas in storage EU-27+UK on 1 April 2022. 16 Source: GIIGNL Annual Report, year 2022, p.3. https://giignl.org/wp-content/uploads/2022/05/GIIGNL2022_Annual_Report_May24.pdf 17 On 25 May 2022, the Commission announced the set-up of EU Energy Platform Task Force to secure alternative supplies. https://ec.europa.eu/commission/presscorner/detail/en/IP_22_3299 18 LNG projects such as: additional FSRU in Eemshaven (NL), FSRU Wilhelmshaven (DE), an additional LNG terminal in Germany (Brunsbüttel) and a second LNG terminal in Poland (Gdansk). Source: REPowerEU Plan, Annex III.

text: Opinion No 05/2022

text: At EU level, the Council and Parliament reached on 19 May 2022 a provisional agreement on the Commission’s proposal of legislation on gas storage. https://www.consilium.europa.eu/en/press/press-releases/2022/05/19/gas-storage-council-and-parliament-reacha-provisional-agreement/?utm_source=linkedin&utm_medium=social&utm_campaign=202205119gas+storage&utm_content=visual On 29 April 2022, ACER and CEER published a note on the Commission proposal to revise the gas SoS and gas storage Regulation. https://extranet.acer.europa.eu/Official_documents/Position_Papers/Position%20papers/Regulators%20feedback %20EC%20storage%20regulation%20proposal_final_formatted.pdf 20 Source: ICIS-HEREN, retrieved on 24.5.2022. Forward gas TTF prices for September 2022 are 88.95 €/MWh, and 89.45 €/MWh and 88.20 €/MWh respectively for Q3 2022 and Q1 2023. 21 Source: ICIS-HEREN, retrieved on 24.5.2022. Storage on track to meet 90% fullness. 22 Suspension of Russia's Gazprom gas supplies to Bulgaria, Poland, Finland, the Netherlands and Denmark, information, info collected as of 7 June 2022. 23 According to

text: Article 11(7) of Regulation (EU) 2017/1938

text: . 24 P.19-21 of ENTSO-E’s Summer Outlook 2022, and details in the Country Comments.

text: Opinion No 05/2022

text: https://eepublicdownloads.blob.core.windows.net/public-cdn-container/clean-documents/sdcdocuments/seasonal/2022/1_Summer-Outlook-Report_2022.pdf https://eepublicdownloads.blob.core.windows.net/public-cdn-container/clean-documents/sdcdocuments/seasonal/2022/2_Country-Comments_SOR_2022_Winter_Review_2021-2022.pdf 25 In other words, the market should be able to attract these gas volumes in order to meet the scenarios used in the Outlook. Obviously, the prices and conditions to attract these volumes do not correspond to the observations of the last five summers. 26 Source: ICIS-Heren, 11 March 2022. Algeria may prioritise gas volumes to Italy vs. the Iberian Peninsula https://www.icis.com/explore/resources/news/2022/03/11/10742974/can-the-eu-reach-its-ambitious-newtargets-to-cut-reliance-on-russian-gas-while-maintaining-energy-security/ 27 REPowerEU Communication, p.6, foresees additional LNG diversification potential of 50 bcm, 10 bcm of pipeline import diversification and 3.5 bcm of biomethane by the end of 2022. 28 The IEA 10-Point Plan to Reduce the European Union’s Reliance on Russian Natural Gas of March 2022 estimates around 30 bcm in additional gas supply from non-Russian sources. https://www.iea.org/reports/a-10-point-plan-to-reduce-the-european-unions-reliance-on-russian-natural-gas

text: Opinion No 05/2022

text: Based on clarifications provided by ENTSOG. 30 ENTSOG Summer Outlook, p.7. 31 IEA Gas Market Report, Q2-2022, p.39 “High gas prices are also set to weigh on industrial gas demand, which is expected to fall close [for 2022] to its 2020 levels”. https://iea.blob.core.windows.net/assets/cfd2441e-cd24-413f-bc9f-eb5ab7d82076/GasMarketReport%2CQ2- 2022.pdf Source: Reuters, 22 September 2021. Soaring gas prices ripple through heavy industry, https://www.reuters.com/business/energy/soaring-gas-prices-ripple-through-heavy-industry-supply-chains- 2021-09-22/ McWilliams, B. and G. Zachmann (2022) ‘The European Union demand response to high natural gas prices’, Bruegel Blog, 8 April https://www.bruegel.org/2022/04/the-european-union-demand-response-to-high-natural-gas-prices/

text: Opinion No 05/2022

text: IEA Gas Market Report, Q2-2022, p.39. 33 10 bcm by turning down thermostat 1 degree, 4 bcm by rapid instalment of solar rooftops and heat pumps roll out, and 20 bcm by wind and solar front loading deployment. 34 High gas prices are set to weigh on European gas demand in 2022 and European natural gas demand is forecast to decline by close to 6% in 2022. 35 ENTSOG Summer Outlook, pp. 21, 22, 24, 26.

text: Opinion No 05/2022

text: ACER notes that the map in Figure 15 shows Finland, Estonia and Latvia in red or orange. ENTSOG has acknowledged that there is a typo in this map, and that there is no risk of demand disruption.

text: Opinion No 05/2022

text: Figure 1 - MS dependence on Russian Gas - Share of Russian gas to meet 90% storage level on 1st October. Source: ENTSOG,

text: Figure 22

text: ENTSOG Summer Supply Outlook 2022, p.26, Figure 22. 38 The Danish NRA (DUR) has expressed concerns about the correctness of ENTSOG’s analysis as regards Denmark and Sweden, which are supplied during the summer from Germany and domestic production. Danish annual biomethane production covers approximately 25-30 % of annual Danish consumption. Hence, in DUR’s view that storage filling dependence of Denmark and Sweden on Russian gas should be less than for Germany.

text: Opinion No 05/2022

text: In principle, highest level of preparedness on the EU level can be achieved by MSs cooperating in a coordinated manner, yet constraints to cross-border flows could manifest in a crisis scenario. The Agency notes the importance of solidarity, cooperation, exchange of information and coordinated MS actions for a better preparedness and management of a gas crisis at EU level. 40 There is no a strict end of the filling season but there are storage obligations with deadlines before the start of st winter. E.g. in Germany, the law requires a filling level of 90% by 1 November; in Hungary, injection season ends by 30 September; in Belgium, a filling level of 90% on 1 November is required; in Spain, the adapted regulation (Royal Decree – Law 6/2022) requires a filling level of 80% by 1st November but historically the storage injection cycle finishes in October; in Italy, by 31st October; in Poland, the end of the injection season depends of the type of reservoir, beginning not earlier on 1st September and no later than on 16 November; in salt cavern storages physical injection may be performed during the whole year; in Croatia, the gas storage system has to be filled up to 90% by 1st Nov. 41 However, as of 27 June 2022, Russian gas supply has been significantly reduced or halted to Poland, Bulgaria, Finland, Netherlands and Germany.

text: Opinion No 05/2022

text: E.g. by considering LNG as one gas source independently of the various LNG suppliers. The Russian supply disruption scenario considered the disruption of Russian pipeline gas and not Russian LNG.

text: Opinion No 05/2022

text: https://app.powerbi.com/view?r=eyJrIjoiYTk3YjJhZmQtYTRjZS00NmNkLWIxZDUtYmU2MGE5NWE3ZG U1IiwidCI6IjgxMDU4NGZkLTY5ZjktNDEzNy1hNmExLWMwZTMzMjgwYjE1YyIsImMiOjh9&pageName =ReportSection

text: Opinion No 05/2022

text: ACER Opinion No 11/2021 on ENTSOG Winter Supply Outlook 2021/2022, p.8.

text: Opinion No 05/2022

text: Opinion No 05/2022

identifier: ACER Opinion No 05/2022

publisher: Europeiska unionens byrå för samarbete mellan energitillsynsmyndigheter

sprak: en

title: ACER Opinion 05-2022 on ENTSOG's Summer Supply Outlook 2022

serie: yttranden

text: PUBLIC

type: stycke

text: OPINION No 05/2022 OF THE EUROPEAN UNION AGENCY FOR THE COOPERATION OF ENERGY REGULATORS of 14 July 2022 on ENTSOG’s Summer Supply Outlook 2022

type: rubrik

text: THE EUROPEAN UNION AGENCY FOR THE COOPERATION OF ENERGY REGULATORS, Having regard to

text: Regulation (EU) 2019/942

text: of the European Parliament and of the Council of 5 June 2019 establishing a European Union Agency for the Cooperation of Energy Regulators Regulation (‘ACER’), and, in particular,

text: Article 4(3)

text: (b) thereof, Having regard to

text: Regulation (EC) No 715/2009

text: of the European Parliament and of the Council of 13 July 2009 on conditions for access to the natural gas transmission networks and repealing

text: Regulation (EC) No 1775/2005

text: , and, in particular, Articles

text: and

text: thereof, Having regard to the outcome of the consultation with the ACER’s Gas Working Group, Having regard to the favourable opinion of the Board of Regulators of 13 July 2022, delivered pursuant to

text: Article 22(5) of Regulation (EU) 2019/942

text: , Whereas:

text: 1. INTRODUCTION

text: (1) On 28 April 2022, the European Network of Transmission System Operators for Gas (‘ENTSOG’) published the Summer Supply Outlook 2022 pursuant to

text: Article 8(3)

text: (f) of

text: Regulation (EC) No 715/2009

text: . (2) Pursuant to

text: Article 4(3)

text: (b) of

text: Regulation (EU) 2019/942

text: , ACER may provide an Opinion to ENTSOG on, inter alia, relevant documents referred to in

text: Article 8(3)

text: 2. SUMMARY OF THE DOCUMENT

text: (3) In the Summer Supply Outlook 2022, ENTSOG undertakes an assessment of the European gas network resilience for the upcoming summer (period from 1 April 2022 to 30 September 2022). The analysis investigates the possible evolution of gas supply and the ability of the gas infrastructure in the European Union to handle gas flows to serve demand, the exports outside the Union and the storage injection needs during summer in preparation for the next winter. ENTSOG, as in previous Outlooks, uses a reference case of reaching a 90% filling level of storage by 30 September 2022, and a sensitivity analysis to reach storage filling levels between 80% and 100%.

text: (4) In view of the Russian invasion of Ukraine, which brings new risks for gas supply and a clear political drive to reduce the Union’s dependency on Russian gas , ENTSOG has additionally assessed the Union’s dependence on Russian supply to satisfy gas demand and storage injection needs during the summer, as well as the impacts of a possible long-term supply disruption of all Russian gas pipeline supply routes.

text: 3. ASSESSMENT

text: (5) ACER welcomes ENTSOG’s timely publication of the Summer Supply Outlook 2022 ahead of the summer season. ACER appreciates that the scope and methodology of the Outlook has been expanded to consider the Russian invasion of Ukraine and the possible repercussions for risk preparedness.

text: ENTSOG main findings and framework of analysis

text: (6) ACER takes notes and underlines the importance of the following conclusions contained in the Summer Supply Outlook 2022.

text: Baseline Scenario

text: a. Under the baseline scenario, which does not consider gas supply disruption and minimises the share of Russian gas in the supply mix, the European gas infrastructure offers sufficient flexibility to enable market participants to reach at least a 90% filling level in all underground gas storages by the end of the

text: summer, ensuring planned maintenance and exports to Ukraine with volumes comparable to the previous summer.

text: b. The EU gas system is dependent on Russian gas for a minimum of 20% of its supply to meet gas demand during the summer and refill storages . In order to minimise the share of Russian gas to 20% in the EU gas supply mix, LNG imports would have to increase up to 80 bcm over the summer season significantly higher than the average 50 bcm observed in the past summers and also than the 70 bcm of the last winter season.

text: c. There are infrastructure limitations in the global LNG supply market (liquefaction capacities) to providing all the additional LNG imports Europe needs to significantly reduce Russian gas supplies. Should significant additional volumes of LNG supply be available on the global market to the EU, some infrastructure limitations prevent some Eastern European countries to receive additional LNG imports.

text: Belarus and Ukraine supply route disruption scenario, during the whole summer

text: d. Under the assumption of a disruption of pipeline supply routes through Belarus st and Ukraine starting from 1 April and lasting the summer season, Europe on average can reach 84% filling level of its total storage capacity. Western European countries (United Kingdom, Belgium, France, Spain and Portugal) can reach 100% storage filling level. However, Western countries cannot provide sufficient additional gas to the Eastern-European countries because of limited network transmission capacities. Storages in Germany and Poland would withdraw gas to satisfy the demand at the beginning of the injection period (April and May).

text: Russian supply disruption scenario from 1st April, during the whole summer

text: e. Under the assumption of full Russian pipeline supply disruption starting from st 1 April and lasting the summer season, storages could only reach a 45% filling level of their total capacity. Most European countries cannot reach the target of an 80% filling level, with a significant difference between European countries. Western European countries may reach 90%, but Eastern European countries would not be able to replenish storages to adequate levels.

text: f. There are capacity limitations in Central Eastern Europe, in the North-West and in Southern Europe, limiting gas flows from the West to Central-Eastern Europe.

text: g. Latvia, Estonia and Finland are exposed to a risk of demand curtailment in case of a full Russian supply disruption; gas from storage should be withdrawn to satisfy the summer demand in Northern and Central Eastern Europe.

text: Russian supply dependence assessment

text: h. Most European countries do not rely on Russian gas during summer to satisfy their demand – not considering the refilling of storages - except Latvia, Estonia and Finland. However, most countries would rely on 20% or 30% of Russian gas to reach respectively an 80% or 90% storage level target on 1 October. The assessment identifies interconnection transmission capacity limitations in Central Eastern Europe as well as infrastructure limitations in the North-West and in the South of Europe preventing gas from alternative sources to flow from Western to Central-Eastern Europe, which would mitigate the dependence on Russian supply.

text: i. Imports of alternative supply sources from Turkey to Bulgaria can additionally reduce the dependence of the Balkan countries on Russian gas.

text: Inventories of gas storage and needed gas volumes to reach at least 80% storage target

text: (7) ACER concurs with ENTSOG that gas storages play a crucial role to balance the European gas system and to cover peak demand during winter. The summer months provide shippers the opportunity to refill storages before the start of the next winter, usually based on a positive Summer-Winter spread . The role of storages becomes more relevant in a context where the EU indigenous gas production consistently declines year-on-year, increasing the Union gas import dependency from external gas producers. In addition, the Russian aggression of Ukraine brings new gas supply risks, as Russia has provided approximately 40% of the EU gas demand and 45.3% of its gas import needs during the year 2021 .

text: (8) ACER notes that on 1 April 2022, the starting point of the outlook simulations, the storage filling level was at 287 TWh (26% of the total EU-27 + UK storage capacity), which was in the lower range of the past 5 injection seasons. ACER

text: agrees with ENTSOG that mild temperatures during the winter 2021/22 combined with higher than normal LNG imports to the Union have allowed for a moderate use of gas storage facilities during last winter , to finish the winter season with overall sufficient gas in storages in the Union.

text: (9) However, this average Union storage filling level of 26% on 1st April shows significant differences across Member States . Several countries (Austria, Belgium, Bulgaria, Croatia, Hungary, the Netherlands, Romania and Slovakia), mostly located in Central and South-Eastern Europe and which are generally more dependent on Russian gas, have a storage filling level equal to or less than 20%. On the other hand, Poland, Spain, Portugal and Sweden have filling levels close to 60% or more. In the case of Spain and Portugal, this can be explained by a lesser dependence on Russian gas and significant LNG capacities, and for Poland by national regulations that require the country to maintain gas in storage . In terms of absolute volumes of gas in storages on 1st April, the largest volumes were stored in Italy and Germany .

text: (10) The Outlook notes that the EU can increase LNG imports up to 80 bcm over the summer season to reduce purchases of Russian gas. ACER notes that to reach this objective, Europe would have to import additional 30 bcm of LNG in comparison to the LNG imports observed in the past years. Attracting this incremental LNG volumes to Europe may be challenging for energy companies in the current context: the global LNG supply is tight and is expected to remain so in the upcoming years in view of limited additional liquefaction projects to become online . In the case of countries already receiving significant LNG supplies, most LNG is supplied based on existing long-term contracts which would not be much affected by higher LNG demand and tight LNG market. Political outreach to the main LNG producers should be instrumental to facilitate attracting additional LNG supplies , which may take place in form of longer-term contractual arrangements. In addition, additional LNG volumes from existing and future

text: LNG regasification terminals combined with reduced Russian flows will drastically reconfigure gas flows in the European network.

text: (11) ACER notes that the necessity to inject gas in storage during the summer period is somehow higher than usual in those countries that are more dependent on St Russian gas, which showed on 1 April a lower than usual storage filling level.

text: (12) ACER finds that strengthened and soon to be implemented national and pan-EU storage rules will contribute to assuring that gas storages are filled to adequate levels before the next winter starts, even in spite of non-favourable and highly- 20 21 volatile market signals in the wholesale gas markets . Preliminary data until mid-May shows that, should the current trajectory for filling storages continue during the summer, it would be feasible to reach the storage filling targets. The current situation calls for continued vigilance of all actors responsible for security of gas supply. Gas supply needs, flows and storage filling trajectories should be monitored. Events such as operational incidents, halting of gas from major gas suppliers , accidents in major supply routes or in upstream production sites could limit gas supply to the EU market, creating scarcity, gas prices spikes and, in last instance, forced gas demand curtailments to non-protected customers.

text: (13) In addition, Member States may decide to prioritise the gas supply to certain critical gas-fired power plants over the gas supply to certain categories of protected customers, if the lack of gas supply to such critical gas-fired power plants either could result in severe damage in the functioning of the electricity system or would hamper the production and/or transportation of gas. Collecting information on such national measures could help to increase the robustness of the modelling results in a crisis scenario. In this sense, ENTSO-E Summer Supply Outlook for 2022 assesses the critical gas volume for electricity generation in Europe, finding that significant gas volumes are needed for electricity adequacy reasons .

text: Supply assumptions

text: (14) ENTSOG’s summer outlook maximum gas import supply potentials to the EU (namely Algeria, Libya, Norway, Caspian - Azeri, Russia and LNG) are based on a five-year historical availability. The supply availability by different LNG basins is based on the maximum supply potential as defined in ENTSOG’s TYNDP 2020. The estimates of EU gas domestic production are provided by the gas TSOs, and represent around 6% of the gas supply to the Union.

text: (15) ACER notes that the Outlook conclusions are only valid to the extent to which gas supply from the various sources are available in the volumes used in the simulations, which are based on historically observed volumes over a period of time when no significant supply disruptions occurred . Then, the modelling approach checks whether the gas transmission network and storages can handle the necessary supply volumes to meet demand and refilling of gas storages. The modelling does not consider whether other supply constraints (e.g. related to gas supply contracts or legal constraints) can be expected, nor what the price effects of limited gas supply might be on the wholesale gas markets.

text: (16) ACER notes that supply assumptions for the Outlook are based on historic values and do not seem to have been updated in view of the Russian invasion of Ukraine and other recent developments affecting gas supply .

text: (17) Finally, ACER notes that Table 2 in Annex B (p. 34 in the Outlook) does not show any additional flexibility of gas supply sources. This may not be fully consistent with other analysis undertaken by the Commission and International Energy Agency which foresee some limited additional pipeline gas supply potential to the Union from sources other than Russia.

text: (18) ACER recommends ENTSOG to base gas supply assumptions not only on historical levels but to adapt them, if need be, to significant events occurred in the

text: past or likely to happen in the future, which possibly have an impact on the gas supply import capabilities and/or strategies of the main gas suppliers to the Union.

text: Network topology

text: (19) ACER welcomes that ENTSOG periodically upgrades the topology of its network model based on capacities provided by TSOs to reflect the firm technical capacities that are offered for the upcoming summer. ACER notes that the capacities added by the Gas Interconnection Poland-Lithuania - GIPL, and the Interconnection Greece-Bulgaria were indicated by the TSOs and included in ENTSOG’s simulations during summer. ACER encourages ENTSOG to provide more clarity in the Outlook on the timestamp of the network topology, and to list significant capacities added by commissioned projects during the season.

text: (20) The war in Ukraine is leading to a significant rerouting of gas across Europe, basically increasing supplies from West to East at the expense of traditional East- West flows. Part of such flow changes could be accommodated by TSOs reallocating existing transmission capacities to new expected flow patterns. ACER encourages ENTSOG to provide an update of such re-allocated capacities.

text: Demand assumptions

text: (21) ENTSOG forecasts that summer gas demand will increase by 2.2% from the summer of 2022 to reach a level of 10,190 GWh/d, very close to the maximum gas demand levels of the last 10-years summers.

text: (22) ACER understands that ENTSOG’s gas demand projections for this Outlook are based on a business-as-usual (BaU) scenario. While part of a high summer gas demand can be explained by the need to refill storages, it is not clear if ENTSOG’s gas demand projections consider that sustained high levels of wholesale gas prices are likely to erode gas demand, in particular for energy intensive industries which use gas as feedstock . It is also not clear whether ENTSOG has studied the effect of high gas prices on the demand from gas-fired power plants, as they may be pushed down the merit order by power generators using cheaper fuel (e.g. coal).

text: The International Energy Agency (IEA) estimates that European gas demand will fall by 6% year-on-year, with industrial demand expected to fall by 9% . Moreover, it is not clear if ENTSOG has considered the effect of reducing gas demand and end-user measures as a tool to lower the dependency on Russian gas in the demand projections. The European Commission’s REPowerEU communication and the IEA 10-points actions plan estimate a potential gas demand reduction of more than 30 bcm by quickly implementing gas demand savings end-user measures and increased energy efficiency. The European Commission, following a mandate from the European Council, is working on a coordinated EU gas demand reduction plan. ACER is of the view that demand side measures could also play a role in reducing the Union’s dependency on Russian gas.

text: (23) For future outlooks, ACER recommends ENTSOG to consider to what extent the gas demand figures provided by the gas TSOs are consistent with gas demand estimates from other entities and institutions as well as evolving political priorities. In particular, ACER calls on ENTSOG to incorporate measures leading to gas demand reduction in its gas demand projections, linked to the objective to reduce and eventually phase-out the dependency on Russian gas. In case of significant differences between the TSOs’ estimates and other estimates of public authorities or reputable entities, ACER recommends ENTSOG to study the reasons and re-adjust the gas demand projections if needed.

text: (24) Finally, ACER notes that Annex D (with storage curves, national production and gas demand figures – Data SSO 2022) has not been published with the Outlook.

text: Treatment of odorised gas in the simulations

text: (25) The Outlook scenario of a full disruption of Russian gas investigates the potential impact of short-term and coordinated TSOs’ measures to reduce the dependence on Russian supply by introducing a few quick system modifications, maximising the possibility and potentially increasing gas flows from West to East . This ENTSOG’s assessment is based on the “ad-hoc” analysis conducted by European TSOs in very short-term, to provide a first estimation of the actions that can be taken and their possible impact. Short-term and coordinated TSOs’ measures would enable interconnection capacities from France to Germany, allowing to flow some odorised gas to Germany in a context of gas shortage. The French and

text: German TSOs investigated technical opportunities for setting a reverse flow limited to 100 GWh/d in summer.

text: (26) ACER notes that there are constraints on the acceptance of odorised gas from France to Germany and Belgium due to purity requirements of the latter industrial consumers, and that doubts arise with regards to the feasibility of handling the injection of odourised gas in the German network system, even in a crisis situation. ACER acknowledges that reverse flows could potentially improve the preparedness for a full disruption of Russian gas and help diversify away from Russian gas. ACER calls on ENTSOG and TSOs to give priority, in coordination with national authorities and end-users, to conduct a detailed analysis of the feasibility of implementing reverse flows and needed investments and adaptations, considering ways to overcome legal and technical provisions on the acceptability of odorised gas in Germany and other countries, especially in storages and in sensitive industrial processes. Alternatively, dedicated interconnection capacities for non-odourised gas and/or adaptations to odorization practices in France may increase the interoperability of gas flows between concerned countries.

text: Disruptions and dependence on Russian gas

text: (27) ACER appreciates ENTSOG’s investigation of the potential impact of the Belarus and Ukraine supply route disruptions during 6-months starting from 1 April. It notes that the simulations show no risk of gas demand curtailment and that Europe can reach 84% of its total storage capacity. Alternative gas import routes, LNG terminals and internal cross-border interconnections would be used at their maximum, including those from Belgium to Germany, Belgium to the Netherlands and France to Switzerland.

text: (28) ACER finds relevant ENTSOG’s assessment of a potential supply disruption of all the gas import pipeline routes from Russia during 6-months starting from 1 April, even if this disruption scenario is not defined in the security of gas supply Regulation. ACER notes that in such a scenario, gas import pipeline routes of Norwegian and Azeri gas (from Turkey to Greece) as well as several internal cross-border interconnection and LNG terminals in Croatia, Italy, Lithuania, the Netherlands and Poland would be used at their maximum capacity. Finland, Estonia and Latvia would be exposed to demand curtailment. European storages show notable differences depending on the historic share of Russian gas, with Western countries being able to reach a 90% storage level by the end of summer, and Eastern countries not being able to reach a 30% storage filling level.

text: (29) ACER welcomes ENTSOG’s analysis of the dependence and impacts on Russian gas for better preparedness for the winter, which shows the minimum dependence of the different Member States’ networks on Russian gas supply to satisfy summer demand and filling storages to the 90% target. This analysis shows that the EU gas system, without any Russian pipeline gas, can rely on alternative gas supply sources to fill the storages up to 50%- 55%, showing a marked short-term dependence on Russian gas of at least 20% to meet the 80% storage level for the next winter, increasing to 30% for a 90% storage filling level target. At Member State level, the simulations show significant geographical differences, being the share of Russian gas necessary to meet a 90% storage level on 1 October over 37 38 80% in Sweden, Denmark and several Central Eastern countries (e.g. Poland, Czech Republic, Slovakia, Hungary, Croatia, Romania and Serbia).

text: (30) In the context of the Russian invasion of Ukraine and the Union plans to reduce its dependency on Russian gas, ACER finds that ENTSOG’s analysis and simulations valuable to improve the preparedness for the next winter season and beyond. However, ACER stresses that the simulations are based on a set of assumptions. Therefore, they cannot be considered as a forecast, as also pointed out by ENTSOG. ACER points outs to the following assumptions as providing uncertainty with respect to the interpretation of the simulation results:

text: a. The modelling assumes a cooperative behaviour among Member States .

text: b. The modelling does not consider gas supply contractual or legal constraints for pipeline and LNG supplies, as ENTSOG supply potentials are aggregated for Europe based on historical supply volumes by main gas sources.

text: c. The modelling does not consider the role of gas prices, infrastructure tariffs and a possible gas demand responsiveness, in particular of industrial consumers and gas-fired power plants to a sustained high price environment. A consequence of not considering this possible gas demand responsiveness to prices is a faster move to demand curtailments in the Outlook than would occur.

text: d. The modelling objective function of the simulation targets to fill storage by 1st October, while the storage filling season ends in November or latter in several Member States.

text: e. The disruption scenarios have been performed on 1 April, assuming a full supply disruption starting on 1 April. However, as of 14 July no EU-wide gas supply disruption has been observed . This means that, as time passes during the injection season, the overall storage filling targets become more achievable.

text: f. The modelling of LNG import mix simplifies the dynamics of the global LNG market .

text: (31) Therefore, the results of the simulations, risks and impacts in ENTSOG’s summer outlook should be considered with caution and dynamically in view of more recent events. The analysis of ENTSOG’s Outlook simulations should be complemented with other analyses performed at EU, regional and national level (e.g. updated risks assessments) to have the best possible up-to-date information on the gas supply risks.

text: (32) In particular, ACER finds it important that the ENTSOs coordinate the set of input assumptions and output results used for the seasonal outlooks in order to provide consistent results. The interrelatedness applies especially to ENTSO-E`s seasonal adequacy outlook, which assesses if expected availabilities of power supply (and transmission) infrastructure are sufficient to ensure electricity adequacy. Thus, the ENTSOs respective seasonal assessments should be consistent regarding, for example, the assumptions towards the gas demand from the electricity sector and, on the other hand, the gas supply made available to electricity power plants. It is more important than ever that the ENTSOs continue working together closely in the determination of the gas volumes needed for operating critical gas-fired power plants as well as critical electricity facilities for the gas system (e.g. electricity driven compressors).

text: Infrastructure to reduce dependence

text: (33) ENTSOG has identified transmission capacity limitations to move gas from West to East in case of disruption scenarios of Russian pipeline gas, which hamper most Central Eastern European countries to reach the storage filling targets in preparation for the next winter. ENTSOG has identified possible short-term preparedness actions of the gas TSOs to enhance cooperation for better preparedness between Member States.

text: (34) ACER takes notes of ENTSOG short-term preparedness and coordinated TSOs’ measures, but it considers that additional studies should be developed to identify and quantify the concrete investments needs, with a focus on enabling West to East gas flows and the creation of routes from littoral Member States with LNG terminals (permanently moored or FSRUs) to landlocked ones depending highly on Russian gas. Such investment plans should be made available to decisionmakers, including a cost-benefit assessment of the project proposals. ACER finds not surprising the existence of internal EU bottlenecks to reduce and phase out dependency on Russian gas and expects a more detailed assessment of ENTSOG of the detected internal bottlenecks in terms of importance of the individual

text: congestion points. Furthermore, the assessment should start by considering which bottlenecks could be alleviated by re-allocating existing capacities, since in some instances part of the available capacities which are no longer needed to accommodate traditional gas flows could be re-allocated to accommodate new gas flows. This should be much faster to implement since it does not require new investments.

text: Summer Supply Review for 2021

text: (35) ACER welcomes ENTSOG’s Summer Supply Review 2021, which is prepared by ENTSOG on a voluntary basis. The report is published along with the Summer Supply Outlook 2022 and provides valuable insights (wholesale gas prices, demand and supply) into relevant facts, figures and trends during the last summer. ACER considers insightful the main findings of the review, namely that seasonal gas demand in Europe in the summer of 2021 increased due to a recovery of the European economy, that gas prices were at their highest levels in the last 10 years, while gas in storage reached the lowest levels of the last 6 summers by the end of September with a 75% filling rate.

text: (36) ACER would welcome if ENTSOG could indicate which particular insights from the review will be taken on board in the next outlook. For instance, the more market-oriented discussion of gas flows and wholesale prices in the review is appreciated, and prices could play a more prominent role in the Outlook assessments.

text: Monitoring tools of gas supply situation

text: (37) ACER praises ENTSOG for developing monitoring tools and initiatives beyond its legal tasks, which provide real value for monitoring the gas security of supply situation, such as the European gas flow dashboard , Seasonal Supply Outlook Monitoring , and the support to Gas Coordination Group assessments. ACER encourages ENTSOG to continue making these monitoring tools operational, which are really valuable for having accessible updated information on storage filling levels and the operation of the gas system.

text: Implementation of previous ACER recommendations

text: (38) ACER finds no reference in the Outlook as regards possible implementation of its previous recommendations on seasonal outlooks, namely: consider using a

text: scenario based on expected gas supply and booked capacities; studying first in view of the current environment of extremely high prices the gas demand responsiveness to prices, and in view of the outcomes of such study, consider embedding gas price demand responsiveness in the Outlook .ACER acknowledges ENTSOG’s efforts and additional analysis in the current summer outlook, but it firmly believes that further improvements would be instrumental to better identify potential risks to which Member States would be exposed in case of a tight gas supply situation, including exposure to very high wholesale gas prices.

text: (39) ACER finds that, in view of the current context, ENTSOG should devote the necessary resources to improve, even further, the methodology for the security of gas supply and preparedness assessments. ENTSOG has a mandate under EU regulations to perform these tasks and should count with sufficient resources and the best available modelling capabilities given the high relevance of its assessments and information,

text: HAS ADOPTED THIS OPINION:

text: 1. ACER finds that ENTSOG’ Summer Supply Outlook 2022 meets the objectives of

text: Regulation (EU) 2019/942

text: and

text: Regulation (EC) No 715/2009

text: in terms of contributing to non-discrimination, effective competition and the efficient and secure functioning of the internal natural gas market. ACER’s main conclusions are the following:

text: Scope of analysis and timely publication

text: 2. ACER welcomes ENTSOG’s timely publication of the Summer Supply Outlook 2022. ACER appreciates that the scope and methodology of the Outlook has been expanded to consider the Russian invasion of Ukraine and the possible repercussions for risk preparedness in the Union.

text: 3. ACER appreciates the investigation of the potential impact of supply pipeline route disruptions during 6 months, which includes the analysis of a full disruption of pipeline gas import routes from Russia as well as a partial disruption of some routes. ACER commends ENTSOG for assessing the dependence of the EU on Russian supply to satisfy gas demand, as well as the impacts of a possible long-term supply disruption of Russian gas during the summer. However, ACER notes that the assessment is based on a set of assumptions which may differ from real conditions, and recommends that the summer outlook findings are considered with caution and dynamically in view of more recent events impacting the summer season.

text: 4. ACER notes that the necessity to inject gas in storage during the summer period is generally higher than usual in those countries that are more dependent on Russian gas, which showed a lower than usual filling level on 1st April. The Outlook notes that the EU

text: gas infrastructure can increase LNG imports up to 80 bcm over the summer season, a level of imports significantly higher than the average of 50 bcm observed in the past years. ACER takes note that according to the Outlook simulations the dependence of the EU gas infrastructure system on Russian gas is at least 20% to meet the 80% storage level by the start of next winter 2022/23. Therefore, selected reinforcements of the EU infrastructure may be needed to offer sufficient infrastructure capacities to enable less than 20% of Russian pipeline gas supplies in pursuit of the phase-out of Russian gas imports.

text: Vigilance for storage fillings during summer

text: 5. Strengthened national regulations and pan-EU storage rules for storages should contribute to secure that gas storages are filled to adequate levels before the beginning of the upcoming winter, even despite unfavourable market signals in wholesale gas markets. The current situation calls for continued vigilance of all actors responsible for security of gas supply, and regular monitoring of storage filling trajectories beyond the assumed availability of maximum import flows and injections during past injection seasons. ACER praises ENTSOG for developing tools and initiatives beyond its legal tasks which provide real value for monitoring the gas security of supply situation.

text: Supply potentials and demand estimates

text: 6. The Outlook supply assumptions are based on historical volumes and, with the exception of gas supply disruption from Russia, do not consider whether other supply constraints (e.g. related to gas contracts or regulatory constraints) can be expected, nor what the price effects of limited gas supply might be in the wholesale gas markets and consequently on demand patterns. ACER recommends ENTSOG to base gas supply assumptions not only on historical levels but to adapt them, if need be, to significant events occurred in the past or likely to happen in the future, which may have an impact on the gas supply capabilities and/or strategies of the main gas suppliers to the Union.

text: 7. ACER finds that ENTSOG uses high gas demand projections in this outlook. It is not clear if ENTSOG’ gas demand projections have considered that sustained high level of wholesale gas prices are likely to erode gas demand in particular for industries. ACER calls on ENTSOG to incorporate the effects of gas demand and end-user measures to reduce dependency on Russian gas in its demand projections, in line with the objective to reduce and eventually phase-out the dependency on Russian gas.

text: Treatment of odourised gas

text: 8. ACER notes that there are constraints on the acceptance of odourised gas from France to Germany and Belgium due to purity requirements of industrial consumers and that doubts arise as the feasibility of handling the injection of odourised gas in the German network system, even in a crisis situation. ACER calls on ENTSOG and TSOs to give priority, in coordination with national authorities and end-users, to conduct a detailed analysis of the feasibility of implementing reverse flows and needed investments and adaptations, considering ways to overcome legal and technical provisions on the acceptability of odourised gas and/or dedicated interconnections for non-odourised gas, and/or adaptations tot the odorization practices in France.

text: Infrastructure to reduce dependence on Russian gas

text: 9. ENTSOG has identified transmission capacity limitations to move gas from West to East in case of disruption scenarios of Russian pipeline gas, which may hamper most Central Eastern European countries to reach the storage filling targets in preparation for the next winter. ENTSOG has identified possible short-term preparedness actions of the gas TSOs which can allow for a more even distribution of gas filling levels in the Union. ACER considers that additional studies should be carried out to identify and quantify concrete investments and costs associated with a focus on enabling West to East gas flows and access to LNG supplies for landlocked Member States highly depending on Russian gas. This assessment should start from the possibilities to re-allocate existing capacities in view of new expected gas flow patterns, as such solutions are both faster and cheaper than new investments.

text: Improvements to the simulations methodology

text: 10. ACER reiterates its previous recommendations on the seasonal outlooks aimed at improving the simulations: consider using a scenario based on expected gas supply and booked capacities; and study in view of the current environment of extremely high prices the gas demand responsiveness to prices, and in view of the outcomes of such study consider embedding gas price demand elasticity or responsiveness in the Outlook. ENTSOG has a mandate under EU regulations to perform several gas security of supply tasks, and should count with sufficient resources and the best available modelling capabilities given the importance of its analysis.

text: Interpretation of the simulation results

text: ACER stresses that ENTSOG’s simulations are based on a set of assumptions and cannot be considered as a forecast, as also pointed out by ENTSOG, and that the primary aim of the outlook is an assessment of the readiness of the gas infrastructure. ACER has identified underlying assumptions and factors providing uncertainty with respect to the applicability of the simulation results. Therefore, the results of the simulations, risks and impacts in ENTSOG’s summer outlook should be considered with caution and dynamically in view of more recent events impacting the summer season. ENTSOG’s simulations should be complemented by other analyses performed at EU, regional and national level (e.g. updated risk assessments) to have the best possible information on the supply risks. In this respect, ACER also highlights the importance of close cooperation between ENTSOG and ENTSO-E to ensure, where relevant, consistent assumptions and results in their respective seasonal assessments.

text: This Opinion is addressed to ENTSOG.

text: Done at Ljubljana, on 14 July 2022.

text: - SIGNED -

text: Fоr the Agency The Director

text: C. ZINGLERSEN


text: Opinion No 05/2023

text: E.g. to Ukraine 3 REPowerEU Action plan, p.1. “In March 2022, EU leaders agreed in the European Council to phase out Europe’s dependency on Russian energy imports as soon as possible.” https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=COM%3A2022%3A230%3AFIN&qid=1653033742483 4 It does not consider gas in form of LNG supplied by Russia.

text: Opinion No 05/2023

text: From April to October in the Outlook, but the end of the injection season may vary per Member State. 6 The difference between prices paid for gas in Summer and prices at which gas can be sold in Winter.

text: Opinion No 05/2023

text: The storages of Member States with high filling levels are relatively small compared to Member States with large volumes storages like Germany, Italy, France and the Netherlands. 8 Commission Implementing

text: Regulation (EU) 2022/2301 of 23 November 2022

text: setting the filling trajectory with intermediary targets for 202.3 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32022R2301&qid=1669911511115 9 On 5 August 2022, the Council adopted a Union Regulation aiming to ensure that gas storage capacities in the EU are filled to adequate levels in a spirit of solidarity. The Regulation provides that gas storages must be filled to at least 90% for the following winter periods.

text: Opinion No 05/2023

text: However, the supply assumptions for Russian gas in Annex B, Table 9 of ENTSOG’s Summer Outlook are ~5900 GWh/d and do not seem to consider the reduced gas flows. 11 E.g. OIES, Quarterly Gas Review: Gas Markets in 2023, p.19. as regards the supply outlook for Europe states that “there is little to suggest that European gas production or non-Russian pipeline supply will be higher yearon-year. Indeed, a slight decline is to be expected”, based on forecasts of relevant authorities for upstream production. 12 Norwegian Petroleum Directorate, 2023. Gas Production 2023. https://www.npd.no/en/ 13 Annex B, Table 9 of the ENTSOG’s Summer Outlook 2023 the max summer and winter LNG supply imports are 4201 and 4745 GWh/d, while ENTSOG’s Summer Outlook 2022 (Annex B, p.34) used 4745 GWh/d. 14 Source: GIIGNL Annual Report, year 2022, p.3. https://giignl.org/wp-content/uploads/2022/05/GIIGNL2022_Annual_Report_May24.pdf 15 OIES, Quarterly Gas Review: Gas Markets in 2023, p.24-25. 16 Idem.

text: Opinion No 05/2023

text: ENTSOG Summer Outlook, Annex C, p.37. 18 ENTSOG Summer Outlook, p.8.

text: Opinion No 05/2023

text: ACER will issue a special report about congestion in North-West Europe and how it has been handled by TSOs and NRAs. 20 ENTSOG Summer Outlook, p.9. 21 IEA Gas Market Report, Q1-2023, p. 34. 22

text: Council Regulation (EU) 2023/706 of 30 March 2023

text: amending

text: Regulation (EU) 2022/1369

text: as regards prolonging the demand-reduction period for demand-reduction measures for gas and reinforcing the reporting and monitoring of their implementation. https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32023R0706&from=EN 23 Countries must reduce their consumption compared with the average demand between 1 April 2017 and 31 March 2022. This reference period does not include cut demand reductions since the start of the war.

text: Opinion No 05/2023

text: ACER Opinion No 05/2022 on ENTSOG Summer Supply Outlook 2022/23, para 26. https://www.acer.europa.eu/sites/default/files/documents/Official_documents/Acts_of_the_Agency/Opinions/O pinions/ACER%20Opinion%2005- 2022%20on%20ENTSOG's%20Summer%20Supply%20Outlook%202022.pdf

text: From 30/11/2022 until 24/12/2022 the FR>DE capacity was not available. Capacity was available back on 25/12 until 18/1 after which there was another period of unavailability.

text: Opinion No 05/2023

text: st (33) Despite a higher level of gas storage filling on 1 April in comparison to last year and the expansion of LNG import capacities in Europe, ACER notes the continuation of the following risk factors present since the start of the Russian aggression against Ukraine for the upcoming summer and winter season:

text: ENTSOG Summer Supply Outlook 2023, Executive summary and Sections 3 and 4. 27 ENTSOG Summer Outlook 2022, Annex G – Storage levels on 1 October, p.41 https://www.entsog.eu/sites/default/files/2022-04/SO0035- 22_Summer_Supply_Outlook_2022_BOA_Rev8.1_220427%20for%20publication.pdf

text: Opinion No 05/2023

text: Opinion No 05/2023

text: See for example page 19 of Summer Supply Outlook 2022 (SO0035- 22_Summer_Supply_Outlook_2022_BOA_Rev8.1_220427 for publication.pdf (entsog.eu)) 30 https://gasdashboard.entsog.eu/

text: https://app.powerbi.com/view?r=eyJrIjoiYTk3YjJhZmQtYTRjZS00NmNkLWIxZDUtYmU2MGE5NWE3ZG U1IiwidCI6IjgxMDU4NGZkLTY5ZjktNDEzNy1hNmExLWMwZTMzMjgwYjE1YyIsImMiOjh9&pageName =ReportSection

text: Article 13

text: . For storages, AGSI platform https://agsi.gie.eu/ ; For LNG terminals, ALSI platform https://alsi.gie.eu/

text: Opinion No 05/2023

text: ACER Opinion No 11/2021 on ENTSOG Winter Supply Outlook 2021/2022, p.8.

text: Opinion No 05/2023

text: See footnote 19 on future ACER special report about congestion in North-West Europe.

text: Opinion No 05/2023

text: Opinion No 05/2023

text: st 35

text: (*) The filling data for Czechia again do not take into consideration that the Dolní Bojanovice UGS is connected only to Slovak gas grid. Pursuant to

text: Article 6

text: (a) of

text: Regulation (EU) 2017/1938

text: , the filling targets and filling trajectories only apply to storages directly interconnected to a market area in their territory.

text: Source: AGSI+ platform, 1.5.2023 data, platform accessed on 3.5.2023. https://agsi.gie.eu/

text: Opinion No 05/2023

text: l ve 80% le ling fil 60% age 40% % stor 20%

text: 0% AT BE BG CZ DE DK ES FR HR HU IT LV NL PL PT RO SE SK filling on 1.5.2023 69% 49% 78% 56% 67% 74% 90% 38% 73% 46% 65% 40% 62% 51% 96% 47% 95% 63% Targets 1.5.2023 37% 5% 29% 25% 10% 40% 62% 7% 29% 37% 36% 41% 34% 30% 70% 41% 5% 25%

text: Storage filling data on 1 May 2023 based on REMIT data; storage targets based on intermediate targets for 1.5.2023, as per Annex to the Commission Implementing

text: Type Name Capacity Commissioned (LNG,pipe) (in bcmy) LNG EemsEnergyTerminal NL 8 12.2022 LNG Brunsbüttel FSRU DE 3.5 01. 2023 LNG Wilhelmshaven FSRU DE 7.5 12.2022 LNG Paldiski FSRU EE,FI 2.5 1.11.2022 Pipeline Gas interconnection between PL, LT 2 PL->LT , 1.9 LT-PL 1.5.2022 Poland and Lithuania (GIPL) (during the ramp-up) Pipeline Poland-Slovakia Gas Pipeline PL, SK 4.7 PL->SK, 5.7 SK- 9.2022 >PL Pipeline Interconnector between Greece GR, BG 3 GR->BG 1.10.2022 and Bulgaria (IGB)

text: Opinion No 05/2023

text: Pipeline Baltic Pipe Project PL, DK, 10 NO-> DK, PL, 3 PL- 1.10.2022 NO DK Pipeline Romania-Hungary RO, additional 0.7 RO- 1.10.2022 HU >HU

text: Type Name MS Capacity Expected date (LNG,pipe) (in commissioning bcmy) LNG Lubmin DE 4.5 end 2023 LNG Cyprus LNG Terminal CY 2 10.2023 LNG El Musel ES 0.94 07.2023 LNG Alexandroupolis LNG Terminal GR 5.5 12.2023

identifier: ACER Opinion No 05/2023

title: ACER Opinion 05-2023 on ENTSOG’s Summer Supply Outlook 2023

text: PUBLIC

text: OPINION No 05/2023 OF THE EUROPEAN UNION AGENCY FOR THE COOPERATION OF ENERGY REGULATORS of 13 July 2023 on ENTSOG’s Summer Supply Outlook 2023

text: THE EUROPEAN UNION AGENCY FOR THE COOPERATION OF ENERGY REGULATORS, Having regard to

text: Regulation (EU) 2019/942

text: of the European Parliament and of the Council of 5 June 2019 establishing a European Union Agency for the Cooperation of Energy Regulators (‘ACER’), and, in particular,

text: Article 4(3)

text: (b) thereof, Having regard to

text: Regulation (EC) No 715/2009

text: of the European Parliament and of the Council of 13 July 2009 on conditions for access to the natural gas transmission networks and repealing

text: Regulation (EC) No 1775/2005

text: , and, in particular, Articles

text: and

text: thereof, Having regard to the outcome of the consultation with the ACER’s Gas Working Group, Having regard to the favourable opinion of the Board of Regulators of 12 July 2023, delivered pursuant to

text: Article 22(5) of Regulation (EU) 2019/942

text: , Whereas:

text: 1. INTRODUCTION

text: (1) On 6 April 2023, the European Network of Transmission System Operators for Gas (‘ENTSOG’) published the Summer Supply Outlook 2023 pursuant to

text: Article 8(3)

text: (f) of

text: Regulation (EC) No 715/2009

text: . (2) Pursuant to

text: Article 4(3)

text: (b) of

text: Regulation (EU) 2019/942

text: , ACER may provide an Opinion to ENTSOG on, inter alia, relevant documents referred to in

text: Article 8(3)

text: of

text: 2. SUMMARY OF THE DOCUMENT

text: (3) In the Summer Supply Outlook 2023, ENTSOG undertakes an assessment of the European gas network resilience for the upcoming summer (the period from 1 April 2023 to 30 September 2023). The analysis investigates the possible evolution of gas supply and the ability of the gas infrastructure in the European Union to handle gas flows i) to serve demand, ii) to accommodate the exports from outside the Union and iii) to achieve the storage injection needs during summer in preparation for the next winter. ENTSOG, as in previous Outlooks, uses a reference case of reaching a 90% filling level of storage by 30 September 2023.

text: (4) In view of the risks for gas supply connected to the Russian invasion of Ukraine and in view of the REPowerEU plan to phase out the dependency on Russian gas , ENTSOG has additionally assessed the Union’s dependence on Russian gas supply to satisfy demand and storage injection needs during the summer, as well as the impacts of a possible long-term supply disruption of all Russian gas pipeline supply routes .

text: (5) Following the interest expressed by ACER and stakeholders, ENTSOG has for the first time run an extended analysis of the possible evolution of gas supply covering the winter 2023/24 season, starting from the simulation results obtained for the 2023 injection period. This extended scenario uses a reference case reaching a 30% filling level of storage by 31 March 2024 in a “reference” and in a “cold” winter scenario.

text: 3. ASSESSMENT

text: (6) ACER welcomes ENTSOG’s timely publication of the Summer Supply Outlook 2023 well ahead of the summer season. In particular, ACER appreciates that the Outlook considers as main risk the Russian invasion of Ukraine and the possible repercussions for risk preparedness, and that its scope has been extended to provide an overview of the preparedness for the winter 2023/2024.

text: ENTSOG main findings and analytical framework

text: (7) ACER takes notes and underlines the importance of the following conclusions contained in the Summer Supply Outlook 2023 in the cases of minimised Russian gas imports and of a full Russian pipeline supply disruption.

text: a. Reaching a 90% storage filling level by the end of summer is possible in both cases, enabled by efficient cooperation between countries.

text: b. A Russian pipeline supply disruption would require additional measures to safeguard a 30% target storage level at the end of March 2024.

text: c. Under a “cold winter” (once in 20 years) scenario with a full Russian pipeline supply disruption, which represents the most stressful simulated scenario, additional gas supplies and demand reduction would be required. European countries would be exposed to a risk of demand curtailment between 6 and 13% during the whole winter.

text: d. The existing gas infrastructure, including new projects commissioned last year, can efficiently reduce the dependency on Russian supply.

text: e. Additional measures to improve the security of gas supply situation include:

text: i. Additional LNG imports, above historically observed import levels, could allow higher targets to be reached for all storage facilities before the end of September 2023.

text: ii. Enhanced capacities provided by TSOs would contribute to the increase of import route capacities from the Caspian Area and from Norway, as well as boost the possibility for better cooperation between Germany and Austria, Belgium, France, Czech Republic, and the Netherlands, resulting in an increase of gas supply flow from West to East.

text: iii. Implementation of a 15% gas demand reduction target.

text: Inventories of gas storage to meet storage targets

text: (8) ACER concurs with ENTSOG that gas storages play a crucial role to balance the European gas system and to cover peak demand during winter. The summer months provide shippers the opportunity to refill storages before the start of the next winter, usually based on a positive summer-winter spread . The continuation of the Russian aggression against Ukraine leads to the continuation of gas supply risks, although the EU dependence on Russian gas is currently much lower (approximately 8 %) compared to the start of the invasion of Ukraine (approximately 40% of the EU’s gas demand).

text: (9) ACER notes that on 1 April 2023, the starting point of the outlook simulations, the storage filling level was at 625 TWh (55% of the total EU-27 + UK storage capacity),

text: in the high range of the past 5 injection seasons and doubles the filling level of 26% observed last year. However, this average level hides differences across Member States: filling levels above 70% are observed in Bulgaria, Croatia, Denmark, Portugal, Sweden and Spain, while recorded filling levels are below 35% in Belgium, France and Latvia. No evident regional differences or apparent correlations to the level of dependency on Russian gas are observed as regards storage filling levels across European Member States. On 1 May 2023, the storage filling levels in all Member States with underground gas storage facilities are above the intermediate minimum target for May defined in the Commission’s Regulation setting the storage filling targets for the year 2023. Annexes I and II to this Opinion provide detailed information st on the filling levels on 1 May.

text: (10) Mild temperatures during the last winter 2022/23, higher-than-normal LNG imports into the Union, and high prices and behavioural changes reducing gas demand have permitted a moderate use of gas storage facilities during last winter and allowed for the winter season to end with adequate filling level of gas storages.

text: (11) Strengthened national and EU gas storage regulations and other regulatory interventions played a role in the successful replenishment of gas storages, acting as an instrument to secure adequate filling levels, despite non-favourable and highly volatile market signals in the wholesale gas markets. The EU storage filling level increased to 95% on 1 November 2022, well beyond the 80% filling target and compliant with the EU storage filling targets in all Member States. Evaluating and revising the incentives of the entities responsible for reaching the filling targets is advisable.

text: Supply assumptions

text: (12) ACER notes that the Outlook conclusions are only valid to the extent to which gas supply from the various sources is available in the volumes used in the simulations, which are based on historically observed volumes over a period without significant supply disruptions. The modelling does not consider whether other supply constraints (e.g. related to gas supply contracts or legal or regulatory constraints related to the use of storages) exist, nor what the price effects of limited gas supply might be on the wholesale gas market.

text: (13) ACER notes that supply assumptions for the Outlook are based on historic values of different sources providing gas to the Union (LNG, Norway, Caspian, Algeria and Libya). Supply assumptions of Russian pipe gas reflect the currently reduced Russian imports via Ukraine and TurkStream . ACER understands that the remaining Russian pipeline flows relate to existing long-term contracts between EU buyers and Gazprom.

text: (14) ACER finds ENTSOG’s approach to base gas supply assumptions on historical levels reasonable. However, ACER expects ENTSOG to adapt gas supply assumptions, where relevant, to likely events in the future, which possibly have an impact on the gas supply import capabilities and/or strategies of the main gas suppliers to the Union, beyond assumed historical gas supplies . For example, ACER notes that for Norwegian gas supplies relevant authorities provide prospective information on the gas supply situation .

text: LNG imports

text: (15) The Outlook notes that the Union has to rely on continued high LNG imports over the summer season and beyond to compensate for reduced supplies of Russian gas and to replenish storages. ACER finds no quantification in the Outlook of the additional LNG imports that would be needed, and notes that apparently ENTSOG’s supply assumptions for LNG for 2023 are the same as for 2022, despite the increase of LNG regasification capacities in the Union during last year due the commissioning of new LNG regasification projects.

text: (16) This summer Europe would have to import incremental LNG volumes, which may be challenging and costly in view of limited additional liquefaction projects to become operational and a possible rebound of LNG demand in Asia. China’s LNG rebound in 2023 is uncertain and will depend on its economy recovery, government policies 15 16 and coal consumption . Some studies suggest that China’s potential gas demand growth will be mostly filled by domestic and already contracted LNG supplies, suggesting benign levels of LNG spot prices during 2023.

text: (17) For European countries already receiving significant LNG supplies, most LNG is supplied based on existing long-term contracts which would not be strongly affected by higher LNG demand and a tight LNG market. Only a few new LNG long-term contracts (LTC) have been signed in Europe, despite new LNG terminals coming online in record time, adding additional LNG regasification capacity. Political outreach to the main LNG producers should continue to facilitate attracting additional LNG supplies, which may take place in the form of longer-term contractual arrangements in order to reduce price exposure to LNG spot, which price may remain highly volatile. In doing so, the long-term goal of decarbonising the EU’s energy system needs to be taken into account.

text: (18) ACER highlights that ENTSOG’s Summer Supply Outlook 2023 does not consider the role of Russian LNG to the Union. ACER believes that ENTSOG should consider constraints on the availability of Russian LNG as a risk factor, also in view of the objective to reduce Russian gas imports.

text: Infrastructure to reduce dependence and reallocation of capacities

text: (19) ACER welcomes that ENTSOG periodically upgrades the topology of its network model based on capacities provided by TSOs, in order to reflect the firm technical capacities that are offered for the upcoming summer, including planned maintenance . ENTSOG may consider as a complementary scenario including a situation with enhanced conditional capacities on top of the firm technical capacities in order to test the resilience of the gas system with enhanced capacities. ACER notes that significant amounts of recently commissioned infrastructure namely the Gas Interconnection Poland-Lithuania - GIPL, Poland-Slovakia Gas Interconnection, the Greece-Bulgaria Gas Interconnector – IGB, as well as the Baltic Pipe connecting Norway-Denmark and -Poland have added significant new import and cross-border capacities. Actions have also been taken to improve available capacities between Lithuania and Latvia, France to Germany and Spain to France (under certain conditions), and Romania to Hungary, thus increasing the EU’s energy system’s resilience and security of supply.

text: (20) New LNG and FSRU terminals in Germany (Brunsbüttel, Lubmin and Wilhelmshaven FSRUs), Estonia-Finland (Paldiski FSRU) and the Netherlands (EemsEnergyTerminal) were also recently commissioned adding close to 30 bcm of LNG import capacity to the EU.

text: (21) ACER welcomes that the Outlook lists the projects commissioned during the last year. However, it encourages ENTSOG to provide more clarity on the timestamp of the network topology, and to mention the significant capacities added by commissioned

text: projects during the season or by the “enhanced capacities” provided by the TSOs and considered in certain Outlook simulations.

text: (22) The war in Ukraine is leading to a significant rerouting of gas across Europe, basically increasing supplies from West to East at the expense of traditional East-West flows. However, there are certain transmission capacity limitations on moving gas from West to East, especially in North-West Europe . ACER encourages TSOs to provide ENTSOG updates of such re-allocated capacities.

text: (23) ENTSOG’s simulations are under the assumption of efficient cooperation between the countries. ACER asks ENTSOG to better explain the impact of this assumption, for example by explaining how the simulations would work out without this assumption. This could be a useful way of making the value of such cooperation more explicit.

text: Demand assumptions

text: (24) ENTSOG forecasts that daily demand for summer 2023 is expected to be in the same range as the last three years, close to 10,000 GWh/d and in line with the average of the summer period in the last 5-years summers. The International Energy Agency (IEA) estimates that OECD European gas demand will fall by 3% in 2023 from 2022 values, noting that European gas demand dropped by close to 20% in 2022. According to the IEA, further reduction of gas consumption will be largely driven by lower gas for power generation and a modest recovery of 10% of industrial demand from very depressed gas values in 2022 .

text: (25) On 30 March 2023, the European Council prolonged the emergency legislation on measures to reduce gas demand by 15% for another 12 months, starting from April 2023 . The Commission has estimated that the gas demand reduction regulation has generated savings of gas demand close to 20%, equivalent to more than 40 bcm, between August 2022 and January 2023.

text: (26) ACER finds that the continuation of voluntary demand reduction is crucial to improve the preparedness for next winter 2023/2024, to fully compensate for the decrease in Russian gas supply and achieve the 90% gas storage filling target at least possible cost.

text: (27) ACER notes that the ENTSOG Outlook gas demand projections have been provided by TSOs based on a “business-as-usual” projection, and that demand reduction is considered only as an additional measure to cover stressful gas supply scenarios. ACER reiterates its recommendation to ENTSOG to assess whether the consistency of gas demand figures provided by the gas TSOs are consistent with gas demand estimates from other entities and with the targets on gas demand reduction. TSOs should incorporate in their demand projections measures and policy objectives of gas demand reduction. In case of significant differences between the TSOs’ estimates and other estimates of public authorities or reputable entities, ACER recommends ENTSOG to study the reasons and re-adjust the provided gas demand projections if needed.

text: Treatment of odorised gas

text: (28) ACER has repeatedly called on ENTSOG and TSOs to prioritise conducting a detailed analysis of the feasibility of implementing reverse flows and needed investments (e.g. such as additional compression power) and adaptations in coordination with national authorities and end-users. The analysis should consider ways to overcome legal and technical provisions such as different odorisation practices.

text: (29) ACER welcomes the adjacent French and German TSO, GRTgaz and OGE and GRTgaz Deutschland, having developed physical flows and offered commercial capacities from France to Germany at the Obergailbach interconnection point, despite different odourisation practices in France and Germany. This daily capacity 100 GWh/d, conditional on certain network and demand parameters, has enabled physical gas flows from France to Germany since 13 October 2022 and has been available for most days during the winter 2022/23. ACER recommends ENTSOG and TSOs to continue working into expanding reverse flow capabilities, especially at interconnection points that are in high demand, and to report on such developments in future outlooks.

text: Disruptions scenarios and risk factors

text: (30) ACER finds adequate that the Outlook’s “reference case” reflects the currently reduced Russian pipeline gas supplies limited to the Ukraine and Turkstream routes. ACER welcomes that ENTSOG includes in its risk assessment a disruption of the pipeline gas supply from Russia during the next summer period (Section 3.1.1) and

text: the next winter period, under a “reference winter” (Section 4.1.1) and a “cold winter” (Section 4.2.1) scenario.

text: (31) ENTSOG’s analysis of the dependence and impacts on Russian gas for better winter preparedness has been detailed in the Outlook and is summarised in paragraph (7) of this Opinion. Notwithstanding this, ACER remarks that the simulation results (storage filling levels, rate of demand curtailment) are only provided at aggregated EU level. ACER calls on ENTSOG to provide details of the simulation results and dependency on Russian gas at country level, as the risk patterns may differ across Member States. ACER notes that this information at country level was available and displayed in maps in the last ENTSOG supply outlook and calls on ENTSOG to include this relevant information in future Outlooks.

text: (32) ACER agrees with ENTSOG that the simulated prolonged disruption of Russian gas is undoubtedly the main risk for the upcoming summer and winter. However, this scenario could be heightened by pipeline disruption scenarios for sources other than Russia, which are less likely to occur (e.g. gas supplies from Algeria, prolonged disruption of Norwegian gas supplies via offshore pipeline such as Europipe, Norpipe, Zeepipe, Franpipe). Such additional extreme combined scenarios would provide useful insights regarding the readiness of the European gas infrastructure to deal with less likely but high impact disruption scenarios.

text: Main risk factors for upcoming summer and winter seasons

text: a. High uncertainty about the availability of already drastically reduced Russian pipeline gas supply;

text: b. Limited additional gas volumes from other major sources of gas pipeline imports to go much beyond the contracted/booked volumes;

text: c. Existence of some internal infrastructure bottlenecks in the EU to accommodate new gas flows from the West, despite new infrastructure commissioned this year;

text: d. Possible recovery of the Chinese economy driving upwards global LNG demand and prices, and impacting the price of LNG imports to the EU;

text: e. Operational incidents or accidents in major supply routes, upstream production sites or major LNG liquefaction terminals limiting availability of gas supply to the EU market;

text: f. Draughts and heat waves during summer driving up gas demand for power generation;

text: g. A colder than usual winter, driving up gas demand; and

text: h. Lack of implementation of gas demand reduction targets

text: (34) The materialisation of these risk factors may lead to supply scarcity which would firstly impact gas wholesale prices. Industrial consumers would have to reduce gas demand.

text: (35) In addition, Member States may decide to prioritise the gas supply to certain critical gas-fired power plants over the gas supply to certain categories of protected customers, if the lack of gas supply to such critical gas-fired power plants either could result in severe damage to the functioning of the electricity system or would hamper the production and/or transportation of gas.

text: (36) This situation calls for continued vigilance with respect to gas supply situation beyond the assumed availability of maximum import flows in the past and for monitoring the implementation of the EU gas demand reduction regulation.

text: (37) The analysis of ENTSOG’s Outlook simulations should be complemented with other analyses performed at EU, regional and national level (e.g. updated risks assessments) to have the best possible up-to-date information on the gas supply risks.

text: (38) In particular, ACER finds it important that the ENTSOs coordinate the set of input assumptions and output results used for the seasonal outlooks in order to provide consistent results (e.g. assumptions towards the gas demand from the electricity sector and, on the other hand, the gas supply made available to electricity power plants). It is important that the ENTSOs continue working together closely in the determination of the gas volumes needed for operating critical gas-fired power plants as well as critical electricity facilities for the gas system (e.g. electricity driven compressors).

text: Visualisation of results

text: (39) ACER notices that, compared to the previous Summer Supply Outlook, no maps highlighting bottlenecks were included in the report and no Annex in excel file was published on ENTSOG’s website, although this data is included as an annex to the summer outlook.

text: (40) ACER calls on ENTSOG to publish all relevant input and output of the Summer Supply Outlook simulations. In this respect, ACER also recommends the creation of a visualisation tool/platform where to make available to stakeholders the results of each Summer Supply Outlook and Winter Supply Outlook edition.

text: Monitoring tools of gas supply situation

text: (41) ACER praises ENTSOG for providing monitoring tools and initiatives beyond its legal tasks, which provide real value for monitoring the gas security of supply situation, such as the European gas flow dashboard , the Seasonal Supply Outlook Monitoring , and the support to Gas Coordination Group assessments. ACER notes that associations of storage and LNG facilities have implemented updated transparency platforms for LNG facilities and gas storage facilities as required by

text: Regulation (EU) 2022/2576

text: which include links to tariffs information for LNG facilities. ACER encourages ENTSOG and Gas Infrastructure Europe (GIE) to continue making these useful monitoring tools operational and developing new functionalities at its own initiative or when requested by stakeholders or authorities.

text: Implementation of previous ACER recommendations

text: (42) ACER welcomes that ENTSOG implemented its recommendation to extend the time horizon of this summer outlook from 6 months to one year, in order to have a better understanding of gas preparedness beyond the end of the injection season (summer outlook). ACER calls on ENTSOG to continue this practice for future seasonal supply outlooks.

text: (43) ACER finds no reference in the Outlook as regards the possible implementation of other previous recommendations on seasonal outlooks, namely: consider using a scenario based on expected gas supply and booked capacities; studying the gas

text: demand responsiveness to prices in view of recent event of high prices and price spikes in 2022 .

text: (44) ACER calls on ENTSOG to devote the necessary resources to further improve the methodology for the security of gas supply and preparedness assessments, in view of the high relevance of its assessments and information,

text: HAS ADOPTED THIS OPINION:

text: 1. ACER finds that ENTSOG’ Summer Supply Outlook 2023 meets the objectives of

text: Regulation (EU) 2019/942

text: and

text: Regulation (EC) No 715/2009

text: in terms of contributing to non-discrimination, effective competition and the efficient and secure functioning of the internal natural gas market. ACER’s main conclusions are the following:

text: 2. ACER welcomes ENTSOG’s timely publication of the Summer Supply Outlook 2023 well ahead of the summer season. In particular, ACER appreciates that the Outlook scope has been extended to provide an overview of the preparedness for the winter 2023/2024 and that it considers as the main gas supply risk the effect of the Russian invasion of Ukraine.

text: 3. ACER agrees with ENTSOG that additional LNG imports, enhanced transmission capacities and implementation of a 15% voluntary gas demand reduction target are needed to reach adequate levels of gas in storages at the beginning and end of the 2023/24 winter season in case of a total disruption of Russian piped gas supply.

text: 4. Gas in storage on 1 April is in the high range of the past 5 injection seasons and double the filling level of 26% observed last year. Strengthened national and EU gas storage regulations and other regulatory interventions have played and will continue to play a role in the successful replenishment of gas storages, despite potential non-favourable and st highly volatile market signals in the wholesale gas markets. On 1 May, the filling level reached 60% allowing a cautious optimism as regards the filling of gas storages during the summer. However, the supply risk linked to a drastic reduction of remaining Russian pipe supply persists and Europe should be prepared also for a potential full disruption of Russian supplies. In this context, continued vigilance of gas supplies and monitoring of storage filling trajectories by all actors responsible for security of gas supply remains particularly important. ENTSOG and GIE have provided and improved their tools for monitoring the gas security of supply situation.

text: Supply and demand assumptions

text: 5. The Outlook’s supply assumptions are based on historical volumes and, with the exception of Russian pipeline gas, do not consider other supply constraints (e.g. related to gas

text: contracts or regulatory constraints on the use of storages). ACER expects ENTSOG to base the gas supply assumptions not only on historical levels but to adapt them, where relevant, to potential events likely to happen in the future and having an impact on the gas supply import capabilities and/or strategies of the main gas suppliers to the Union. ACER note that for Norwegian gas supplies relevant authorities provide prospective information on the gas supply situation.

text: 6. ACER finds that ENTSOG uses high gas demand projections for this outlook. ACER reiterates its recommendation to ENTSOG to assess if the TSOs’ gas demand projections are consistent with the gas demand estimates from other entities and with the European targets on gas demand reduction and on the phase-out of the dependency on Russian gas.

text: Disruption scenarios

text: 7. ACER agrees with ENTSOG that the simulated prolonged disruption of Russian gas is undoubtedly the main risk for the upcoming summer and winter. However, this scenario could be heightened by combined disruption scenarios for gas sources other than Russia, which are however less likely to occur (e.g. a disruption of a major offshore pipeline bringing Norwegian gas).

text: Infrastructure to reduce dependence on Russian gas and reallocation of capacities

text: 8. Since the Russian’s invasion of Ukraine, recently commissioned infrastructure has added significant cross-border capacities and more than 30 bcm of the LNG import capacities to the EU’s gas system. ACER welcomes that the Outlook lists the major projects commissioned during the period. It encourages ENTSOG to provide more clarity on the timestamp of the network topology, and to mention the significant capacities added by commissioned projects during the season or by the “enhanced capacities” provided by the TSOs.

text: 9. The war in Ukraine is leading to a significant rerouting of gas across Europe, basically increasing supplies from West to East at the expense of traditional East-West flows. However, there are certain transmission capacity limitations on moving gas from West to East, especially in North-West Europe . Part of such flow changes could be accommodated by TSOs re-allocating existing transmission capacities, which are no longer needed, to new expected flow patterns.

text: Improvements to the simulations’ methodology

text: 10. ACER reiterates its previous recommendations on the seasonal outlooks aimed at improving the simulations: consider using a scenario based on expected gas supply and booked capacities; and study the gas demand responsiveness to prices in view of recent event of high prices and price spikes in 2022. ENTSOG has a mandate under EU regulations to perform several gas security of supply tasks, and should count with

text: sufficient resources and the best available modelling capabilities given the high relevance of its analysis.

text: Level of granularity of the simulation results and visualisation

text: 11. ACER finds that for this outlook the simulation results (storage filling levels, rate of demand curtailment) are only provided at aggregated EU level. ACER calls on ENTSOG to provide details of the simulation results and dependency on Russian at country level, as the risk patterns may differ across EU Member States. ACER also recommends the creation of a visualisation tool/platform to make available to stakeholders the results of each summer and winter supply outlook.

text: 12. ACER notes the continuation of several risk factors, as detailed in paragraph (33), present since the start of the Russian aggression against Ukraine for the upcoming summer and winter season. ACER stresses that ENTSOG’s simulations are based on a set of assumptions and cannot be considered as a forecast, as also pointed out by ENTSOG, and that the primary aim of the outlook is an assessment of the readiness of the gas infrastructure. Therefore, the results of ENTSOG’s summer outlook simulations should be considered with caution and dynamically in view of more recent events impacting the summer season, and complemented by other analyses performed at EU, regional and national level. In this respect, ACER also highlights the importance of close cooperation between ENTSOG and ENTSO-E to ensure, where relevant, consistent assumptions and results in their respective seasonal assessments.

text: This Opinion is addressed to ENTSOG.

text: Done at Ljubljana, on 13 July 2023.

text: - SIGNED -

text: Fоr the Agency The Director

text: C. ZINGLERSEN

text: Annexes:

text: I: Storage filling levels per Member States on 1 May 2023

text: II: EU storage filling levels on 1 May 2023 vs EU Regulation filling targets III: Major LNG regasification and cross-border projects (recently commissioned or to be

text: commissioned soon)

text: Annex I: Storage filling levels per Member States on 1 May 2023

text: WGV: Working Gas Volume of Storages GIS: Gas in Storage

text: Working (gas) Gas in volume storage Country (TWh) (TWh) Filling level of storage (%)

text: Austria 96.9 66.9 69 Belgium 7.6 3.7 49 Bulgaria 5.8 4.5 78 Croatia 4.8 3.5 73 Czech Republic (*) 44.2 24.9 56 Denmark 9.8 7.3 74 France 133.6 50.2 38 Germany 250.2 168.0 67 Hungary 69.7 32.3 46 Italy 193.4 127.3 66 Latvia 22.6 9.1 40 Netherlands 142.4 87.3 61 Poland 37.5 19.1 51 Portugal 4.0 3.8 96 Romania 33.9 15.9 47 Slovakia 37.1 23.3 63 Spain 34.1 30.7 90 Sweden 0.1 0.1 95

text: EU 1127.9 677.8 60

text: Annex II: EU Storage filling levels on 1 May 2023 vs EU Regulation filling targets for

text: 1 May 2023

text: Storage filling level (REMIT) vs storage targets (Annex I), 1.5.2023

text: Annex III: Major LNG regasification and cross-border projects (commissioned since March 2022 or to be commissioned by the end of 2023)

text: -projects recently commissioned from March 2022 to April 2023

text: -projects to be commissioned the latest by end 2023