Allcation rule at the interconnection point Mallnow

The Commission Regulation (EU) 2015/703 of 30 April 2015 establishing a network code on interoperability and data exchange (“INT NC”) shall apply from 1st May 2016.

INT NC was developed in the years 2012 - 2015 under the Regulation (EC) No 715/2009 of the European Parliament and of the Council of 13 July 2009 on conditions for access to the natural gas transmission networks and repealing Regulation (EC) No 1775/2005 and in particular under Article 6(11) thereof.

In accordance with Article 9 of INT NC, the adjacent transmission system operators shall establish rules ensuring consistency between the allocated quantities at both sides of the interconnection point.

The basic allocation rule foreseen by Article 9 point 2 of INT NC shall be the operational balancing account (“OBA-rule”). The application of the OBA-rule means that the quantities allocated to the network users at the connection point with the adjacent TSO shall be equal to the confirmed quantities.

However, based on the Article 9 point 4 of INT NC, the adjacent transmission system operators may agree to maintain or implement an allocation rule other than the operational balancing account, provided that this rule is published and network users are invited to comment on the proposed allocation rule within at least two months after publication of the allocation rule.

Therefore, based on the provisions of Article 9 point 4 of INT NC, transmission system operators: Gas Transmission Operator GAZ-SYSTEM S.A. (GAZ-SYSTEM S.A.) and GASCADE Gastransport GmbH (GASCADE) consult with the market participant maintaining of the following currently applicable allocation rule at the interconnection point Mallnow the direction Poland towards Germany:

The current allocation rule applicable between the transmission system operators at the interconnection point Mallnow is based on the mechanism of a so-called balancing Shipper (“balancing Shipper”). This allocation rule means that the existing balancing Shipper-pair balances the deviation between the total nominated quantities and measured quantities on each given gas day. The quantities allocated to other shippers are equal to the confirmed nominations. The role of the balancing Shipper is currently being fulfilled by one of the shippers being active at the interconnection point Mallnow direction Poland towards Germany.

Furthermore the allocation rule balancing Shipper has been successfully applied since commissioning of the station and represents from the point of view of GAZ-SYSTEM S.A. and GASCADE a workable alternative to the OBA-rule. If the current balancing Shipper is not able to perform this function in the future any more or if any other Shipper is not able to execute the balancing shipper on a voluntary and convenient basis, the OBA-rule will be used at the interconnection point Mallnow.

In order to avoid misunderstanding it has to be clarified that the balancing shipper mechanism does not have any influence regarding the operational gas transport procedures of shippers not executing the role of the balancing shipper.
Moreover for the avoidance of doubt it is noted, that these balancing shipper rules shall be valid only at the interconnection point Mallnow direction Poland towards Germany. For the direction Germany towards Poland an OBA-rule shall be applied.


According to Article 9 point 4 of INT NC, GAZ-SYSTEM S.A. and GASCADE invite the interested market participants to comment on the proposed allocation rule.

Please send your comments until  29 April 2016 to the following email addresses: instrukcja@gaz-system.pl and operations@gascade.de


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