ACER Opinion 11-2023 on ENTSOG’s Winter Supply Outlook 2023-2024

PUBLIC

OPINION No 11/2023 OF THE EUROPEAN UNION AGENCY FOR THE COOPERATION OF ENERGY REGULATORS of 14 December 2023 on ENTSOG’s Winter Supply Outlook 2023/2024

THE EUROPEAN UNION AGENCY FOR THE COOPERATION OF ENERGY REGULATORS, Having regard to Regulation (EU) 2019/942 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, Article 4(3)(b) thereof, Having regard to 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, Articles 9(2) and 8(3) thereof, Having regard to the outcome of the consultation with ACER’s Gas Working Group, Having regard to the favourable opinion of the Board of Regulators of 13 December 2023, delivered pursuant to Article 22(5) of Regulation (EU) 2019/942, Whereas:

1. INTRODUCTION

(1) On 17 October 2023, the European Network of Transmission System Operators for Gas (‘ENTSOG’) published the Winter Supply Outlook 2023/2024 (‘WSO 2023/24’) pursuant to Article 8(3)(f) of Regulation (EC) No 715/2009 , which also includes a preliminary outlook for the summer 2024. (2) Pursuant to Article 4(3)(b) of Regulation (EU) 2019/942, ACER may provide an Opinion to ENTSOG on, inter alia, relevant documents referred to in Article 8(3) of Regulation

2. SUMMARY OF THE DOCUMENT

(3) In the WSO 2023/24, ENTSOG undertakes an assessment of the resilience of the European gas network for the upcoming winter (October 2023 to March 2024). ENTSOG’s analysis investigates the ability of the gas infrastructure to dispatch the necessary supply volumes to meet gas demand, and especially to deal with high demand situations, provided that gas supply is available. The Outlook is based on assumptions of gas supply potentials, on historical gas supplies during the last 5 years (or based on TSO information), and it looks into the possible evolution of gas supplies and underground gas storage (‘UGS’) utilisation levels during the upcoming winter withdrawal season. Based on these assumptions the WSO 2023/24 assesses the readiness of the gas infrastructure for the winter season.

(4) ENTSOG simulates the ability of the gas infrastructure system to ensure supply and 2 3 demand adequacy under a “Reference winter” and a “Cold winter” . The “Cold Winter” assessment is complemented by a sensitivity which considers the voluntary target for Member States to reduce their natural gas consumption by 15% . The WSO 2023/24 also simulates “stress tests” of the gas infrastructure under two cases of high demand linked to cold weather, namely under a “Peak day” and a “2-week cold spell”.

(5) On the supply side, in line with its obligation under the EU Security of gas supply Regulation , ENTSOG has undertaken an assessment of a full disruption of a single supply source, specifically, for WSO 2023/24, Russian piped gas. Furthermore, ENTSOG, for the first time has analysed how different levels of LNG availability could impact the risk of demand curtailment and the amount of gas remaining in storage at the end of the winter.

(6) Compared to the previous outlooks, this WSO 2023/24 also includes a sensitivity analysis to check if the gas infrastructure system is sufficiently flexible to achieve storage levels exceeding 30% at the end of the withdrawal period .

(7) In line with its Summer Supply Outlook 2023 and ACER recommendation on WSO 2022/23 , ENTSOG extended the analysis by also including an overview of summer 2024, thus covering the full gas year from October 2023 to September 2024.

(8) On 17 October 2023, ENTSOG also published a report on the European gas supply and demand for the past Winter 2022/23 , which aims to provide an ex-post analysis of the gas demand and supply in the previous seasons. The report was published on a voluntary basis along with the WSO 2023/24.

3. ASSESSMENT OF THE DOCUMENT

(9) ACER welcomes the timely publication of the WSO 2023/24 and accompanying documents ahead of the winter season. ACER appreciates the analysis of the historical gas supply, demand patterns and use of storages, as well as of the possible evolution of storage levels for the upcoming winter and summer resulting from the assumptions and simulations contained in the Outlook.

(10) ACER welcomes the inclusion of additional sensitivity analyses of the level of LNG potential imports reaching Europe, as the availability of sufficient LNG volumes is one of the main risk factors for the upcoming winter and summer seasons.

(11) ACER welcomes the inclusion of a sensitivity analysis on the maximum level of gas in storage that could be reached at the end of the winter period.

(12) ACER finds the inclusion of a section on the Balticonnector pipeline disruption relevant (Chapter 6).

3.1. ENTSOG main findings and analytical framework

(13) ACER takes note and underlines the importance of the following main findings contained in the WSO 2023/24:

all Members States had already reached the 90% filling target objective set out in the EU gas storage regulation .

b. The European gas infrastructure, including projects to be commissioned over the upcoming winter, offers sufficient flexibility to dispatch the necessary supply volumes to meet demand in Europe and reach “safe” storage levels, assuming that there is efficient cooperation among the different Member States and that sufficient gas reaches the EU.

c. However, under specific scenarios of high demand, some possible demand curtailments are identified by ENTSOG, along with the low level of gas in stock at the end of the winter and some infrastructure bottlenecks emerging within Europe. Such stressful situation is further aggravated in case of low LNG availability and/or in case of a full disruption of Russian gas supply.

d. Additional storage flexibility could be achieved by using Ukrainian storage facilities, provided that those volumes can be injected and subsequently withdrawn during the winter season and if market participants are willing to make use of it.

e. According to the WSO 2023/24 results, at least 46% of working gas volume would be needed at the end of the winter to meet the summer demand and to reach the 90% st target in all Members States on 1 November 2024. Such level would not be achieved in case of a “Reference Winter” with low LNG imports or in case of a “Cold Winter” (unless a -15% demand reduction is applied).

f. A sensitivity conducted on the Balticconector disruption shows that its prolonged unavailability (i.e. through the whole winter) limits the possibility for Finland to cooperate with its neighbouring countries but it does not pose a significant risk to the security of gas supply in the region nor to the possibility of adequately filling the storages.

(14) ACER takes note of the following conclusions contained in the WSO 2022/23:

a. High storage levels, the current gas infrastructure system and new projects to be commissioned, enhanced cooperation and additional LNG import capacities can efficiently reduce the dependence on Russian gas supply, and partially mitigate the risk of demand curtailment in case of a full and prolonged Russian pipeline disruption.

b. Without demand reduction, most countries would be exposed to significant risk of demand curtailment in case of a “Cold winter”.

c. However, demand reduction alone might not be enough. Ensuring sufficient LNG imports are essential to prevent demand curtailments and to ensure adequate filling of gas storages.

d. Some infrastructure bottlenecks within EU remain. Between France and Spain, between Poland and Lithuania, and between Southern -East Europe and Central Europe.

e. Early and significant withdrawal of gas from storages will result in low storage levels at the end of the winter season, having a negative impact on the flexibility of the gas system and on the preparedness for the next winter season 2023/24.

3.2. Gas storage filling levels in view of EU Gas Storage Regulation

(16) ACER welcomes that the EU collective 90% storage filling rate objective was already st achieved in mid-August, nearly 2-months ahead of the 1 of November deadline. Where possible, NRAs have checked the accuracy of storage filling levels reported in ENTSOG’s Winter Outlook.

(17) Regulation (EU) 2022/1032 states that “Member States shall take all necessary measures […] to meet the filling targets […]” and introduces a set of measures which each Members States could adopt to reach those targets. The recently published ACER consultancy study “On the impact of EU and national gas storage regulations” shows that the measures implemented in the Members States effectively helped to reach the storage filling levels at national and European level. Measures like financial incentives for storage users, stockholding obligations, institution of last resort storage entities and use-it-or-lose-it mechanisms, allowed to reach an adequate level of preparedness, despite the discouraging market signals. The study also shows that such measures came at a cost, and that gas prices moved upward also due to the strong competition among countries to refill their storages before the regulatory filling target dates .

(18) Also based on the difficulties and risks observed in implementing these measures, the ACER consultancy study emphasizes the need to further improve the transparency and verifiability of the measures as well as the need to strengthen coordination between Member States with and without storages to avoid Member States without gas storages

to face constraints in accessing gas sources. The ACER consultancy study also underlines the need for making the last resort mechanism more efficient, by ensuring carefully planning of the conditions when the last resort entity acts, the volume requirements, and by introducing risk reduction mechanisms which can interact with existing market rules and do not increase wholesale prices (e.g., price hedging by the designated entity).

(19) The study will be followed up by a Council of European Energy Regulators (CEER) study which will review the agreements and the burden -sharing mechanism between Member States that have storage facilities and the ones that do not have them. The followup study will identity best practices and propose recommendations to design storage filling obligations with the aim to enhance their effectiveness and efficiency in the future.

(20) ACER highlights the critical importance of counting on adequate storage levels at the end of the winter season to cover still possible high demand or system stress situations. ACER concurs with ENTSOG that early and significant withdrawal from storages has a negative impact on the flexibility of the gas system and can increase the exposure to supply risks towards the end of the winter. ACER takes note of ENTSOG’s view that a st 46% aspirational target for storage filling level on 1 April 2024 will be needed to ensure preparedness for the upcoming winter 2024/25.

(21) As the actual use of imports and/or storage is eventually determined by market participants, ACER expects storage users to prudently withdraw gas from storage during this winter. Furthermore, ACER calls on national competent authorities to monitor and take measures, starting with market-based incentives and measures, to favour a gas withdrawal pattern that enables safeguarding the continuity of gas deliveries during the next winter.

(22) ACER understands that the WSO 2023/24 considers the strategic reserves set out by national legislation, allowing for “more realistic” simulations. The ACER consultancy study “on the impact of EU and national gas storage regulations” shows that in some countries the introduction of strategic reserves was a measure implemented following the adoption of Regulation (EU) 2022/1032 . In other countries the use of strategic reserves was already existing but was amended after the adoption of Regulation (EU) 2022/1032.

(23) Additionally, to the role of storages, ENTSOG also considers the role of tanks from LNG regasification terminals which would offer additional short-term flexibility to cover the peak-demand and short-term cold spells .

3.3. The role of LNG and other supply sources to replace Russian piped gas

(24) Since the start of the Russian aggression against Ukraine, Europe has succeeded in reducing its dependency from Russian gas. Despite the significant reduction in Russian imports, while some countries are now completely independent, in 2023 some other countries continued to rely on Russian gas imports, both through pipelines and LNG .

(25) In April 2022, the European Commission launched the EU Energy Platform, AggregateEU, to support demand aggregation and joint purchase of gas. The creation of this platform aimed at facilitating the reduction of European dependence from Russian gas.

(26) LNG has been the main gas source to replace significant gas imports from Russia and this is likely to continue in the future. Increased high LNG imports (822 TWh in winter 2022/23 vs 639 TWh in winter 2021/22) were necessary to partially offset the decline in Russian gas pipeline imports from Russia, as other gas pipeline sources have limited flexibility to increase supply. With the majority of LNG cargos not tied to long-term contracts, these incremental LNG volumes remain subject to global price fluctuations. The European Commission quarterly gas market reports show that for most of the first quarter of 2023, as well as for most of 2022, Europe offered price premiums compared to Asia. On one hand the upward pressure on prices might be lower during winter 2023/24 thanks to the availability of more LNG regasification and more liquefaction capacities , as well as, thanks to the alleviation of some cross-border congestions within Europe . On the other hand, both the European gas and LNG markets are still expected to be characterised by volatility across this winter, and likely the next one as well, with

price risk skewed to the upside , especially in case of unforeseen events (see section 3.4 on risks factors for this winter).

(27) The WSO 2023/24 assumes that LNG imports could be increased up to the maximum of current EU LNG import regasification capacities plus additional LNG import capacities expected to come online soon . Although the EU regasification terminals have in general sufficient spare regasification capacity, there are variations in the available spare capacity across Member State and LNG terminals. Additionally, there might be scheduling constraints for LNG cargos deliveries in some LNG terminals this winter. The arrival of LNG cargoes to EU LNG terminals depends on commercial decisions, as LNG market is global and spot LNG cargoes will be destined where demand offers the highest price . Besides available LNG regasification capacity, sufficient transmission capacities are necessary to make fully use of the LNG import potential across Europe.

3.4. Risks factors for this winter

Main risk factors for upcoming winter

(28) ACER notes the continuation of risk factors present since the start of the Russian aggression against Ukraine for the upcoming winter season:

a. High uncertainty about the availability of Russian gas supply, in particular concerning LNG from Russia (today still counting 15%-19% of overall EU LNG imports), and about the flows through Ukraine, also beyond 2024 due to the expiration and possible non-renewal of the transit contract between the two countries ;

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

c. Existence of limited cross-border capacities in the EU to accommodate new gas flows from the West and LNG terminals which previously came from the East;

d. Increase in Asian’s gas demand due to economic recovery or unavailability of other sources such as hydro or nuclear, possibly driving upwards global LNG demand and prices, and impacting the price levels and availability of LNG imports to the EU;

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

f. A colder than usual winter, driving up gas demand;

g. Lack of implementation of gas demand reduction targets; and

h. A low storage filling level at the end of the winter, limiting the deliverability of storages and complicating the replenishment of storages during summer 2024.

(29) The materialisation of these risk factors may lead to supply scarcity which would firstly impact wholesale gas prices, leading to some demand reduction, in particular for industrial consumers. Forced gas demand reductions would come next and involuntary demand curtailment of non-essential gas consumers would be a last resort emergency measure.

(30) 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. In this sense, ENTSO-E’s Winter Outlook 2023/24 assesses 37 38 the critical gas volume for electricity generation in Europe , finding that the critical gas volume decreases approximately by 10% compared with winter 2022 /23, due to more favourable conditions such as higher nuclear availability in Europe and higher hydro availability, as well as due to a stagnant demand.

(31) This situation calls for continued vigilance with respect to gas supply situation and for monitoring the implementation of the EU gas demand reduction regulation.

WSO 2023/24 Supply Disruption Scenarios

(32) ACER finds adequate that the Outlook’s “reference case” reflects the currently reduced Russian imports limited to Ukraine and Turkstream routes to the EU. ACER welcomes that ENTSOG includes in its assessment a full disruption of the piped gas supply from Russia, investigating its potential impact on the storage filling level at the end of the winter and gas demand curtailment for the “Reference Winter” and “Cold Winter” scenarios.

(33) The WSO’s simulations show that storages cannot reach the 30% filling level at the end of the winter season in case of a “Cold Winter”, and that the European countries would face demand curtailment. Under a prolonged disruption of the pipeline supply from Russia, the assessment reveals insufficient LNG capacity as well as infrastructure bottlenecks between Southern Europe and Central Europe, which do not allow for better cooperation. Under high demand situations and disruption of Russian pipeline imports, the situation is aggravated, and the assessment under a “Cold Winter” shows also bottlenecks between Poland and Lithuania and between South -Eastern Europe with the rest of Europe.

(34) ACER agrees with ENTSOG that the full disruption of Russian gas is undoubtedly the main risk for the upcoming winter. However, this scenario could be aggravated by disruption scenarios for sources other than Russia, which are nevertheless 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 situations.

3.5. Demand assumptions in view of EU Gas Demand Reduction

(35) On 5 August 2022, the European Union adopted a Regulation on a coordinated demandreduction measures for gas to increase the Union level of preparedness as regards gas supply disruptions, in view of a significant risk that a complete halt of Russian gas supplies may materialise soon. This regulation recommends a voluntary reduction of natural gas demand by at least 15% which may become mandatory by a declaration of a “Union alert” . Member States have flexibility in choosing the demand reduction measures . On 28 March 2023, Member States agreed to extend the voluntary 15% gas demand reduction target until March 2024 .

(36) ACER notes that the “Reference Winter” demand shows an increase of ca. 16% compared to the demand registered for the winter 2022/23 , while being lower than the average of the previous 5 years (-8% vs the average of winters 2017/18 - 2021/22). ACER

understands that the “Reference Winter” demand data was provided by TSOs on a monthly granularity level but it is not entirely clear if and how ENTSOG checks the TSOs demand projections and if they are consistent with the aggregated demand at EUlevel. In this regard, it is not clear if the TSO demand projections consider, for example, that sustained high levels of wholesale gas prices can and have eroded gas demand, in particular for energy-intensive industries . ACER also notes that the “Reference Winter” demand is calculated in a different way than the “Reference Summer” demand, with only the latter considering the 15% reduction.

(37) ACER finds the Outlook’s seasonal demand projection and the peak demand projections

in particular, too high , especially when compared to the historical demand evolution and the observed continuing decrease in gas demand.

(38) In ACER’s views, ENTSOG should have preferably used a “baseline scenario” of gas demand for the winter outlook built upon the European Union targets of reduction of gas demand, which would be consistent with the Union Regulation on coordinated demandreduction measures for gas .

(39) In addition, demand reduction measures in the power sector can have a relevant impact on the overall gas demand via reduced consumption of gas-fired power plants. In its Winter Outlook 2023/24 , ENTSO-E assesses that the amount of gas needed to ensure adequacy on the electrical power system (critical gas volume (CGV)) could be further decreased by 10% if energy saving measures to reduce total consump tion and peak

demand would be implemented . Such cross-sectoral insights should be reflected in the ENTSOG WSOs.

3.6. Network topology

(40) ENTSOG periodically upgrades the topology of its network model based on capacities provided by TSOs to reflect the technical capacities that are available for the upcoming winter. The WSO 2023/24 topology includes four new LNG infrastructures but does not provide a complete list of all the infrastructures considered in the assessment.

(41) ACER welcomes that the WSO also considers non-EU countries in the WSO perimeter. In some cases, non-EU countries are considered through predefined exogenous input either assumed by ENTSOG (e.g., Serbia) or provided by the relevant TSO of the concerned country (e.g., Ukraine). ACER invites ENTSOG to seek ways to further cooperate with non-EU countries and with the Energy Community to extend, where possible, the geographical perimeter of the simulations to other relevant countries (e.g., Moldova and Ukraine).

(42) ENTSOG considered “enhanced capacities” as provided by some TSO, which would allow to maximise the flows in the case of disruption of full Russian pipeline supply. According to the TSOs, those capacities would increase interconnection capacities between Germany and Austria, Belgium, the Czech Republic, and the Netherlands, as well as between Spain and France, allowing central Europe to access more LNG imports. However, there is lack of transparency in the WSO on the actual capacity, the conditions under which those capacities could be made available and on the actual required investments.

(43) ACER encourages once again ENTSOG to provide more clarity in the Outlook on the timestamp of the network topology as well as to publish, together with all the main relevant data, the full list of capacities considered in the WSO 2023/24, thus also including the considered upcoming projects and the enhanced capacities.

3.7. Maximisation of gas import and cross-border capacities

(44) The war in Ukraine is leading to a significant rerouting of gas across Europe, increasing supplies from West to East substituting traditional East-West flows. ENTSOG has identified transmission capacity limitations to move gas from West to East in case of disruption scenarios of Russian pipeline gas, which hamper some Central Eastern European countries to satisfy their gas demand and reach adequate level of storage filling targets at the end of the winter 2023/24 and in case of a full disruption of Russian gas. Part of such flow changes could be accommodated by TSOs re-allocating existing

transmission capacities to new expected flow patterns. ACER recommends ENTSOG to provide an update of such re-allocated capacities and to TSOs to maximise the availability of capacities to accommodate new flow configurations.

(45) As stated in the ACER report on “Congestion in the EU Gas Markets” and in the ACER special report on “Addressing congestion in North-West European gas markets” , ACER urges the affected TSOs to take appropriate and coordinated cross -border actions to maximise capacities and manage contractual and physical congestions, and it invites ENTSOG to publicly report on the actions undertaken by the affected TSOs and to specify how much additional capacity has been made available in this way.

3.8. Monitoring tools of gas supply situation

(46) ACER praises once again 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 Regulation (EU) 2022/2576 which include links to tariffs information for LNG and storage facilities. ACER encourages ENTSOG and Gas Infrastructure Europe (GIE) to continue making these useful monitoring tools operational and developing new functionalities at their own initiatives or based on the requests of stakeholders or authorities.

3.9. Implementation of previous ACER recommendations

(47) ACER finds no reference in the Outlook as regards possible implementation of its previous recommendations on seasonal outlooks, namely consider using a scenario based on expected gas supply and booked capacities; consider levels of winter demand which better incorporates exogenous factors such as demand reduction targets , demand elasticity triggered by future gas prices or fuel switch behaviours (e.g. under peak demand situations some sectors might switch to other fuels than gas) . However, ACER firmly believes that improvement in the WSO assumptions and methodology would be instrumental to better identify potential risks (and remedies) to which Member States

would be exposed in case of a tight gas supply situation, triggering timely anticipatory measurements.

(48) ACER encourages ENTSOG to consider developing, in consultation with stakeholders, such methodological improvements for future Outlooks in order to improve the robustness of the Outlook’s assessments. ENTSOG should devote, as a matter of priority, more resources to improve, even further, the methodology for the security of gas supply and preparedness assessments,

HAS ADOPTED THIS OPINION:

1. ACER is of the view that ENTSOG’ Winter Supply Outlook 2023/2024 contributes to the objectives of Regulation (EU) 2019/942 and Regulation (EC) No 715/2009 in terms of contributing to non-discrimination, effective competition, and the efficient and secure functioning of the internal natural gas market.

Scope of analysis and timely publication

2. ACER welcomes ENTSOG’s timely publication of the Winter Supply Outlook 2023/2024. ACER appreciates that the scope and methodology of the Outlook has been expanded to consider the outage of major infrastructures, the Russian invasion of Ukraine and caused risks for imports to Europe, different level of LNG availability and the inclusion of a sensitivity on the maximum level of storages that could be reached at the end of the filling period.

Improvements to Winter Supply Outlook methodology

3. ACER acknowledges ENTSOG’s efforts and additional analysis in the current winter supply outlook. However, ACER firmly believes that improvement in the WSO assumptions and methodology would be instrumental to better identify potential risks to which Member States would be exposed in case of a tight gas supply situation. ACER encourages ENTSOG to consider improving the WSO assumptions and methodology, in particular by including in the supply assumptions the expected gas supply and booked capacities rather than using a scenario only based on historical values, and to embed expected gas prices and gas price demand elasticity in the definition of the demand which is an exogenous input to the modelling.

4. In the last years, both Winter Supply Outlook and the Summer Supply Outlook have become important reference documents for stakeholders. ACER recommends ENTSOG to proactively engage with stakeholders well in advance of the Supply Outlooks' preparation and to consult them on the proposed methodology to gain insights into expected improvements.

5. 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. ACER also encourages ENTSOG and ENTSO-E to align the timing of the publication of the respective Winter Supply Outlooks.

Gas demand projections and savings

6. ENTSOG should have included a “baseline scenario” of gas demand for the winter outlook built upon the European Union targets for reduction of gas demand, which would be consistent with the Union Regulation on coordinated demand-reduction measures for gas.

Risks factors for this winter and upcoming injection season

7. ACER agrees with ENTSOG that the simulated disruption of Russian gas is undoubtedly the main risk for the upcoming winter. However, this scenario could be aggravated by other source, which are nevertheless less likely to occur, yet not modelled in the Outlook. The presence of risk factors , given the continuity of the Russian war against Ukraine calls for continued vigilance with respect to the gas supply situation. ACER calls on ENTSOG and all actors to remain vigilant for the upcoming winter and to track closely these risk factors.

Transparency

8. ACER urges ENTSOG to publish all the assumptions and decisions underling the input used in the WSO 2023/24. ENTSOG should collect and publish the assumptions used to define the enhanced capacities and to derive the demand data provided by the TSOs.

New infrastructure projects and maximisation of gas import and cross-border capacities

9. ACER welcomes that new cross-border initiatives and new LNG regasification capacities have contributed to the security of supply of EU. It remains a priority that cross-border capacities ensure the preparedness of the EU gas infrastructure to transport gas supplies that reduce and replace Russian gas supplies. ACER invites TSOs to take appropriate and coordinated cross-border actions to maximise capacities and manage contractual and physical congestions.

Vigilance over EU storage filling levels

10. ACER welcomes that the EU collective 90% storage filling rate objective was already achieved in August, and that storage filling levels have reached the 90% target in all st Member States well ahead 1 of November. Strengthened gas storage regulations and measures have played a role in the successful replenishment of storages.

11. ACER highlights the critical importance of monitoring and keeping adequate storage levels towards the end of the winter season to cover for possible high demand or supply disruption situations. Early and significant withdrawal from storages results in low storage levels at the end of the winter season and increases the risk for the next replenishment season. Therefore, ACER expects storage users to prudently withdraw gas from storage

- SIGNED –

Fоr the Agency The Director

C. ZINGLERSEN

Annexes:

I: Storage filling levels per Member States on 1 October 2023

II: EU Storage filling levels on 1 November 2023 vs EU Regulation filling targets III: Incorrect or unclear information in ENTSOG’s Winter Outlook 202 3/2024

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

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

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

Austria 97.6 92.6 95 Belgium 9.1 8.4 92 Bulgaria 5.9 5.7 96 Croatia 4.8 4.6 97 Czech Republic 44.6 43.2 97 Denmark 9.8 9.0 92 France 134.4 126.2 94 Germany 254.1 244.1 96 Hungary 70.1 66.7 95 Italy 195.4 188.7 97 Latvia 22.6 20.9 92 Netherlands 142.4 137.1 96 Poland 37.5 37.3 100 Portugal 3.6 3.5 97 Romania 33.9 33.1 98 Slovakia 36.9 35.7 97 Spain 34.1 34.2 100 Sweden 0.1 0.1 95

EU 1136.8 1091.3 96

Annex II: EU Storage filling levels on 1 November 2023 vs EU Regulation filling targets.

Annex III: Incorrect or unclear information in ENTSOG’s Winter Outlook 2023 /2024

(1) In page 8, third paragraph of ENTSOG WSO 2023/24, it says: “The topology of the network model considers the existing European gas infrastructure, the firm technical capacities provided by TSOs, which include maintenance plans known as of September 2023 and new upcoming projects as of their respective expected start of commercial operations. For example: • Brunsbuettel Hafen and Stade FSRUs in Germany; • Musel LNG terminal in Spain; • Le Havre FSRU in France.”

CNMC notices that Musel LNG terminal, previously mothballed, entered into operation at the end of July 2023. (2) All “monthly supply mix” graphs in ENTSOG WSO 2023/24 (e.g., Figure 15) refer to GWh/d in the vertical axis while they refer to “sum of the month” in the horizontal axis. ENTSOG should ensure consistency in the way data are displayed and correct the graphs accordingly.