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INCREASED INTEGRATION of UKRAINIAN and POLISH TRANSMISSION SYSTEMS and GAS MARKETS FINAL REPORT Energy Security Project (ESP) March 10, 2021

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PHOTO CREDIT: UTG INCREASED INTEGRATION OF UKRAINIAN AND POLISH TRANSMISSION SYSTEMS AND GAS MARKETS FINAL REPORT Energy Security Project (ESP) March 10, 2021 This document is made possible by the support of the American people through the United States Agency for International Development (USAID). The contents of this document are the sole responsibility of Tetra Tech ES, Inc., and do not necessarily reflect the views of USAID or the United States Government. This document was prepared by Tetra Tech ES, Inc., prime contractor for the Energy Security Project (ESP), USAID contract 72012118C00003. RECORD OF DOCUMENT REVISION REVISION DATE SUMMARY OF CHANGES A 11.10.2020 B 11.16.2020 C 01.25.2021 D 02.19.2021 E 01.03.2021 F 10.03.2021 USAID/Ukraine USAID Energy Security Project 4 Igor Sikorsky Street 14A Yaroslaviv Val St. Kyiv, Ukraine 04112 Kyiv, Ukraine 01030 Phone: +38-044-521-5000 5-6th Floor https://www.usaid.gov/ukraine www.tetratech.com This document is made possible by the support of the American people through the United States Agency for International Development (USAID). The contents of this document are the sole responsibility of Tetra Tech ES, Inc., and do not necessarily reflect the views of USAID or the United States Government. This document was prepared by Tetra Tech ES, Inc., prime contractor for the Energy Security Project (ESP), USAID contract 72012118C00003. CONTENTS ACRONYMS 6 EXECUTIVE SUMMARY 9 1 TECHNICAL ASSESSMENT 21 1.1 POLISH GAS TRANSMISSION SYSTEM 21 OVERVIEW OF POLISH GTS 21 PROJECTS OF COMMON INTEREST (PCI) 25 CROSS-BORDER INTERCONNECTION POINT WITH UKRAINE 28 1.2 POLISH ŚWINOUJŚCIE LNG TERMINAL 29 EXISTING INFRASTRUCTURE 29 EXPANSION PROGRAM 30 1.3 UKRAINIAN GAS TRANSPORTATION INFRASTRUCTURE 32 1.4 UNDERGROUND GAS STORAGE (UGS) 34 POLAND UGS 34 UKRAINE UGS 35 1.5 TECHNICAL SUMMARY 38 2 MARKET SCREENING 40 2.1 HISTORICAL GAS SUPPLY AND DEMAND 40 UKRAINE 40 POLAND 43 SUMMARY OF HISTORICAL GAS SUPPLY AND DEMAND 49 2.2 DEVELOPMENTS IN POLAND 49 POLAND’S DIVERSIFICATION OF GAS SUPPLY 49 POLAND’S AMBITION AS AN EASTERN AND CENTRAL EUROPEAN GAS HUB 57 SUMMARY OF KEY PROJECTS AND DEVELOPMENTS IN POLAND 60 2.3 UNDERGROUND GAS STORAGE 60 UKRAINIAN STORAGE 62 UKRAINIAN INCENTIVES FOR STORAGE USE 62 FLOWS FROM EUROPE TO UKRAINE 63 POLISH GAS STORAGE 65 FOCUS ON FLOWS BETWEEN POLAND AND UKRAINE 66 GAS STORAGE SUMMARY 69 2.4 FORECASTED CHANGE TO SUPPLY AND DEMAND 70 FORECASTED CHANGES TO THE UKRAINIAN MARKET 70 FORECASTED CHANGES TO THE POLISH MARKET 74 SUMMARY OF FORECASTED SUPPLY AND DEMAND 77 2.5 IMPACT ON UKRAINIAN STORAGE AND IMPORTS 78 UKRAINIAN STORAGE 78 PRICING ANALYSIS 82 UKRAINIAN IMPORTS 86 OVERALL FLOW DEMANDS FROM ANALYSIS 94 2.6 CONCLUSIONS FROM THE MARKET SURVEYS AND INTERVIEWS 94 2.7 MARKET SCREENING CONCLUSIONS AND ENABLERS 95 3 LEGAL AND REGULATORY ASSESSMENT 97 INCREASED INTEGRATION OF UKRAINIAN AND POLISH TRANSMISSION SYSTEMS AND GAS MARKETS | 3 3.1 EU REGULATIONS THAT PROVIDE FOR FREE ACCESS TO THE CAPACITIES OF CROSS-BORDER INTERCONNECTION POINTS BETWEEN THE EU AND ENERGY COMMUNITY CONTRACTING PARTIES 97 APPLICABILITY OF THE EU DIRECTIVES AND REGULATIONS IN POLAND 97 APPLICABILITY OF THE EU DIRECTIVES AND REGULATIONS IN UKRAINE 97 MAIN EU RULES AND PRINCIPLES SECURING FREE ACCESS TO CROSS-BORDER TRANSMISSION SERVICES 98 3.2 CONCLUSIONS FROM REVIEW AND ASSESSMENT OF EXISTING LEGAL DOCUMENTS 98 3.3 POSSIBILITY OF USING UKRAINIAN STORAGE FOR STORING COMPULSORY GAS STOCK AS REQUIRED BY POLISH LEGISLATION 101 MAIN FEATURES OF POLISH COMPULSORY GAS STOCKS REGULATION 101 ASSESSMENT OF THE POSSIBILITY OF MAINTAINING COMPULSORY GAS STOCKS UNDER POLISH REGULATION WITHIN UKRAINIAN UGS 104 CONTEMPLATED AMENDMENTS TO THE STOCK ACTS AS ANNOUNCED BY THE POLISH COUNCIL OF MINISTERS IN AUGUST 2020 106 3.4 STEP-BY-STEP GUIDELINES FOR A SHIPPER WHO IS WILLING TO TRANSPORT GAS FROM POLAND TO UKRAINE, STORE GAS IN UKRAINIAN STORAGE AND THEN TRANSPORT GAS BACK TO EU COUNTRIES INCLUDING A DETAILED DESCRIPTION OF ALL ACTIONS THAT MUST BE UNDERTAKEN BY THE SHIPPER 107 GIVEN THE REGULATORY, COMMERCIAL AND TECHNICAL CONDITIONS, IT IS ASSUMED THAT: 107 POLISH REGULATIONS AND PROCESS FOR PURCHASE OF GAS AND TRANSPORT TO THE UKRAINIAN BORDER AND RE-EXPORT TO POLAND 109 UKRAINIAN REGULATIONS FOR PLACEMENT OF THE GAS IN GAS STORAGE AND RE-EXPORT 111 3.5 GAP ANALYSIS OF THE BARRIERS TO MARKET INTEGRATION AND COMPATIBILITY OF LEGAL RECOMMENDATIONS FOLLOWING THE ANALYSIS OF THE CURRENT FRAMEWORK IN PLACE 112 POLISH REGULATORY GAP ANALYSIS 112 UKRAINIAN REGULATORY GAP ANALYSIS 117 CONCLUSIONS 120 4 ASSESSMENT OF TARIFFS AND BUNDLED PRODUCT SERVICES 121 4.1 APPLICABLE CONCEPTS AND DEFINITION OF PRODUCT BUNDLING 121 NC CAM AND CAPACITY PRODUCTS STANDARDIZATION 121 INCREMENTAL CAPACITY PROCEDURE FOR CROSS-BORDER BUNDLED TRANSMISSION PRODUCT 124 4.2 NC TAR AND GUIDANCE FOR PRICES FOR BUNDLED CAPACITY PRODUCTS 125 DEFINITIONS AND CONCEPTS FOR TARIFFS 125 GUIDANCE FOR PRICES FOR BUNDLED CAPACITY PRODUCTS 128 GUIDANCE FOR PRICES FOR CAPACITY PRODUCTS OFFERED AT VIRTUAL POINTS 130 IMPLICATIONS OF THE NETWORK CODE FOR GAS STORAGE FACILITY 131 BUNDLED PRODUCTS DESIGN: CONCEPTS AND DEFINITION 131 CROSS-BORDER BUNDLED TRANSMISSION PRODUCT 132 4.3 CASE STUDY AND LESSONS FOR THE UA/PL GAS MARKET 134 SPECIFICITY OF DAY-AHEAD AND WITHIN-DAY PRODUCTS (NETHERLANDS)134 INCREASED INTEGRATION OF UKRAINIAN AND POLISH TRANSMISSION SYSTEMS AND GAS MARKETS | 4 CROSS-BORDER GAS TRANSMISSION PRODUCTS/SERVICES (NETHERLANDS/GERMANY) 135 BUNDLED PRODUCT OPPORTUNITIES FOR STORAGE ASSETS (NETHERLANDS/GERMANY/BELGIUM) 136 INTERNATIONAL TRANSIT ENTRY CAPACITY AND TARIFF PANCAKING (ITALY) 141 CHANGE IN FLOW PATTERN IN THE INTERCONNECTOR (UK) 144 PRODUCT DESIGN CONSIDERATIONS FOR UKRAINE AND POLAND 146 4.4 CONCLUSIONS ON THE DESIGN OF BUNDLED PRODUCTS 151 5 CONCLUSIONS & RECOMMENDATIONS 153 6 ANNEX 155 INCREASED INTEGRATION OF UKRAINIAN AND POLISH TRANSMISSION SYSTEMS AND GAS MARKETS | 5 ACRONYMS ACER Agency for the Cooperation of Energy Regulators bcm Billion cubic meters bcma Billion cubic meters per annum BAL Balancing Mechanism BBL Balgzand Bacton Line BEMIP Baltic Energy Market Interconnection Plan CAAGR Compound Average Annual Growth Rate CAM Capacity Allocation Mechanism CAPEX Capital Expenditure CEE Central and Eastern Europe CEER Council of European Energy Regulators CEF Connecting Europe Facility CS Compressor Station DA Day-Ahead DES Delivered Ex-Ships DN Diameter Nominal DSO Distribution System Operator DUD Dolina-Uzhhorod-Derjkordon EC European Commission EEA European Economic Area EFTA European Free Trade Agreement EIC Energy Identification Code EL Energy Law Act EN European Standards ENTSOG European Network of Transmission System Operators for Gas ERO Energy Regulatory Office ESP Energy Security Project EU European Union EuRoPol Polish Transit Pipeline System FOB Free-On-Board FSRU Floating Storage and Regasification Unit GCP Grid Connection Point GCP Gaz- Virtual Interconnection Point established by Gaz-System and UA GTSO based System/UA on Interconnection Point Drozdovichi and Interconnection Point Hermanowice GTSO GDP Gross Domestic Product GDS Gas Distribution Station GIPL Gas Interconnectors between Poland and Lithuania GMS Gas Metering Station GOST Interstate Standard GSA Gaz-System Auction GTS Gas Transmission System GTSO Gas Transmission System Operator INCREASED INTEGRATION OF UKRAINIAN AND POLISH TRANSMISSION SYSTEMS AND GAS MARKETS | 6 IEA International Energy Agency IP Interconnection Point ISO International Organization for Standardization IUK Interconnector UK kgf/cm2 Kilogram of Force per Square Centimeter kPa Kilopascal KRS National Court Register of Poland LLC Limited Liability Company LNG Liquefied Natural Gas LNGT Liquefied Natural Gas Terminal LTC Long-Term Contract mcm Million Cubic Meters mcm/d Million Cubic Meters per Day ESP Mott MacDonald Ltd mmbtu Millions of British Thermal Units MPa Megapascal MWh Megawatt Hour NC Network Code(s) NC BAL Network Code on Gas Balancing of Transmission Networks NC CAM Network Code on Capacity Allocation Mechanisms NC INT Network Code on Interoperability and Data Exchange NC TAR Network Code on Harmonized Transmission Tariff Structures for Gas NEURC National Energy and Utilities Regulatory Commission NIP Tax Identification Number (Poland) Nm3/h Normal Meter Cubed Per Hour NRA National Regulatory Authority nTPA Negotiated Third-Party Access OGP Gaz Operator Gazociągów Przesyłowych Gaz-System S.A. System OPEX Operating Expenditure ORV Open Rack Vaporizer OTC Over-The-Counter PCI Project of Common Interest (European Commission) PE Permanent Establishment Petroleum Includes Oil & Gas from Conventional and Unconventional Sources PL Poland PLN Polish Zloty New (Polish currency since 1994) PWP Point of Interconnection REMIT Regulation on Wholesale Energy Market Integrity and Transparency RPM Reference Price Methodology RRM Registered Reporting Mechanism rTPA Regulated Third-Party Access SBU Standard Bundle Unit SCV Submerged Combustion Vaporizers SPA Sales and Purchase Agreement INCREASED INTEGRATION OF UKRAINIAN AND POLISH TRANSMISSION SYSTEMS AND GAS MARKETS | 7 SSO Storage System Operator TAR Tariff Harmonization TEN-E Trans-European Energy Networks TPA Third-Party Access TSO Transmission System Operator TTF Title Transfer Facility TYNDP Ten-Year Network Development Plan UA Ukraine UA GTSO Ukrainian Gas Transmission System Operator LLC UAH Ukrainian Hryvnia UEEX Ukrainian Energy Exchange UGS Underground Gas Storage UPU Urengoy-Pomary-Uzhhorod USAID United States Agency for International
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