It remains unclear which companies are guaranteed gas supply during the deficit

Amendments to the Natural Gas Act are being discussed in the Economic Affairs Committee of Parliament of Estonia, which, among other things establish rules for which gas consumers must be guaranteed the supply of natural gas in the event of deficit. In the opinion of the Chamber, the new rules are not clear enough and therefore we made a proposal to the Parliament of Estonia to specify the new rules.  

The draft stipulates that if in an emergency it is not possible to ensure the supply of gas to all consumers, the balance provider and the distribution network operator shall ensure the preservation of gas supplies to consumer groups in the following order:  

1. household consumers; 
2. district heating plant, which cannot use any other fuel than gas and is producing heat for domestic use; 
3. power plants which use gas to generate electricity and which are essential for the operation of the electricity system; 
4. gas consumers of services of general interest;  
5. other vulnerable gas consumers for whom the expected period of interruption of gas supply is up to six hours; 
6. other vulnerable gas consumers for whom the period of interruption of gas supply is more than six hours. 
    

In the opinion of the Chamber, it remains unclear in the draft which companies belong to the fourth, fifth and sixth consumer groups. This information is very important for companies, as it may depend on whether or not the company is guaranteed the supply of natural gas in the event of a natural gas deficit.  

For example, it is not clear from the draft who is considered to be a gas consumer of services of general interest. The explanatory memorandum merely states that this group of consumers includes nursing homes, food industry and agriculture. However, it is not clear whether this group includes the whole food industry and the agricultural sector or only a part of it. In addition, it is unclear which companies in other sectors qualify for the fourth consumer group.  

The draft also does not provide a clear answer to the question which companies will belong to the fifth and sixth consumer groups. It is confusing, for example, which gas consumers are expected to have an outage of up to six hours and which are expected to have an outage of more than six hours. The concept of a vulnerable consumer also raises questions, because according to the current Natural Gas Act, only a household consumer can be a vulnerable consumer. 

The draft states that the principles of assigning consumers to groups shall be established by a regulation of the minister responsible for the field. In the opinion of the Chamber, the draft and explanatory memorandum must also be clearer and provide more precise instructions on how companies are divided by different consumer groups. Therefore, the Chamber proposed to the Economic Affairs Committee of the Parliament of Estonia to clearly indicate in the draft and explanatory memorandum which companies may belong to the fourth, fifth and sixth consumer groups. 

The planned amendments to the Natural Gas Act can be found in more detail HERE.