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Open Letter on the implementation of CMP for BBL

The CMP guidelines  were published in the Official Journal of the European Union on 28 August 2012 and entered into force 20 days later. These guidelines set out certain provisions to be applied to counter and prevent contractual congestion. Contractual congestion is a situation where network users cannot gain access to gas transmission systems in spite of the physical availability of the capacity.

The majority of their provisions were required to be implemented by 1 October 2013. Gasunie Transport Services (GTS), the Dutch gas transmission system operator (TSO) and National Grid Gas (NGG), the Great British (GB) TSO, have both taken steps to implement the requirements of the CMP Guidelines. However, further work is needed in respect of both of the two European gas interconnectors – Interconnector UK (IUK) and BBL Company (BBL) – to make them compliant. This letter focuses specifically on implementation of the CMP regulation on BBL, the gas interconnector between GB and the Netherlands. It focuses solely on whether oversubscription and buy back (OSBB) or firm day-ahead use it or lose it (FDA UIOLI) should be the primary CMP mechanism implemented.

The document briefly sets out the mechanics of each of these congestion management mechanisms and explores the advantages and disadvantages of both options. We invite views from stakeholders on these proposals.