Energy Traders Europe welcomes the opportunity to comment on E-Controls consultation on gas network utilisation tariffs (Gas-Systemnutzungsentgelte-Verordnung). While we recognise that the proposed tariff adjustments are based on the established reference price methodology under NC TAR, the resulting tariff levels raise concerns from a network user perspective; particularly since some of the previously considered flexibilities to manage stranded capacity have not been implemented.
Please find our comments detailed out below.