Subsidieregeling gasopslag Bergermeer 2023

Reactie

Vraag1

We welcome the government’s proposal for this tender to subsidy the filling of Bergermeer storage facility and assure that the Netherlands meet their storage filling obligations for Storage Year 2023 as decided by the European Commission.

Please find below our comment on the tender’s terms.

Excluding the days where Q1-24/DA spread is lower than – 16 €/MWh from the price period

We believe that this condition should be deleted from the tender terms for the following reasons :

This condition is redundant with the cap of the Q1-24/DA price difference set at – 15 €/MWh
Capping the Q1-24/DA price difference at – 15 €/MWh already guaranties that the paid subsidy will always stay within the budgeted amount of the subsidy of 240 M€. Therefore, there is no need to further exclude the days where Q1-24/DA spread is lower than – 16 €/MWh from the price period
This condition brings unnecessary complexity to the terms
Excluding the days where Q1-24/DA spread is lower than – 16 €/MWh means that on those days storage users will get no compensation for their -important- losses, and can discourage storage users from participating in the tender.

With regard to usage of the term production: we assume that the term “production” is used to mean “withdrawal”, we would appreciate if this could be clarified.