Väljaminev kiri

Dear Gaia,

Here are the answers we have coordinated with our TSO. Hopefully, they provide you with the information you need. Do let me know if there is anything else you require!

1. General:

• * Is the “Luhamaa route” considered as a back-up route to the “Belarus to Kaliningrad” route?

Yes, it can be used as a back-up route.

• * ENTSOG capacity platform shows that at Luhamaa entry point capacity (and corresponding flows) was booked only in 13 days in 2023 and 10 days in 2024. Are these numbers correct?

The accurate number of days is 14 days in 2023 and 11 days in 2024. The transit was made through Luhamaa entry point and exit point as Kiemenai. The data forwarded to the ENTSO-G platform for Luhamaa entry point is done so by Conexus only, in the same exit point it is marked as N/A with the comment “According to agreement between parties, Conexus is providing data on behalf of Elering”. Precondition for transit is having a common zone network user who has network agreement and balancing agreement with either Elering or Conexus. All network users active in Common balancing zone can facilitate the transit. There are no agreements signed with Russian TSO. The transit entry point nominated can only be Luhamaa entry point.

From the Common Regulations for the Use of Natural Gas Transmission System (https://elering.ee/sites/default/files/2025-06/Common%20Regulations%20for%20the%20Use%20of%20Natural%20Gas%20Transmission%20System_01062025.pdf):

• * “5.10. Capacity allocation for the transit at entry/exit point Luhamaa

• * 5.10.1. The TSO shall allocate entry capacity for the transit as a daily capacity product in accordance with the transit notification submitted by the third country TSO, provided that the corresponding exit capacity of the common balancing zone is booked by the network user requesting transit.

• * 5.10.2. The third country TSO shall submit a transit notification to the TSO in writing, confirmed by the network user requesting transit, at least two weeks before the actual commencement of the transit. The transit notification shall include the following information:

• * 5.10.2.1. the transit entry point;

• * 5.10.2.2. the transit exit point;

• * 5.10.2.3. the time period during which the transit must be provided;

• * 5.10.2.4. the required transit capacity per day within the time period when transit must be provided (kWh/day);

• * 5.10.2.5. the EIC code of the network user requesting transit.

• * 5.10.3. The TSO shall, not later than three working days after the submission of the transit notification, inform the network user of the allocated firm capacity and make the capacity available for the network user in accordance with sub-paragraph 4.2 of this Regulation.

• * 5.10.4. Transit exit allocations can be modified by the TSO in the case of a mismatch between transit entry allocations and exit nominations.

• * 5.10.5. The capacity allocation request for transit can be rejected in order to minimize the impact on other network users and ensure the security of supply.”

• * Is Luhamaa entry and exit kept operational only to allow the transit of gas from Russia to Kaliningrad?

Yes

• * Luhamaa has two sides, i.e. entry and exit. We interpret ECA’s derogation request solely referring to the ENTRY side of Luhamaa given that the exit side is not operational. Can you confirm?

Yes, the exit is in practice currently not operational. However, we would still require the derogation to apply to the exit side as well, since the possibility to request a derogation is limited. Given that Estonian TSO Elering currently has no contracts with the Russian TSO and there is no clear understanding of what will happen after the war in Ukraine ends, Estonia would not like to be in a situation where we have no derogation in place, yet we are forced to start implementing EU rules at the Russian interconnection point under significant time pressure.

How integrated is the Luhamaa entry point into the Estonian grid, and the relating infrastructure used for the Russian transportation?

Luhamaa entry point and the Estonian part of the transit line is completely separated from the rest of the Estonian grid.

2. Capacity allocation

• * Is only a daily product offered at Luhamaa entry?

Yes

• * If yes, is this choice driven by the need to minimise the access to infrastructure of Russian gas, and to frame it only in the context of a back up route to of Russian gas to Kaliningrad? Or by other drivers?

Yes, it is driven the need to minimise the access to infrastructure of Russian gas, and to frame it only in the context of a back up route to of Russian gas to Kaliningrad

• * Have you formally categorised such daily products as a “conditional” product, as per recast Gas Regulation EU 2024/1789 Article 2(35)?

No, this daily product at Luhamaa entry point is not formally defined as conditional capacity.

• * Can Gazprom own/book such capacity? Or is the daily capacity only allocated to EU shippers?

Precondition for transit is having a common zone network user who has network agreement and balancing agreement with either Elering or Conexus. All network users active in Common balancing zone can facilitate the transit. There are no agreements signed with Russian TSO.

• * Exit point: does it only have to be Kiemenai? Or could it be any point of the Estonian-Latvian common zone (e.g. including storage)?

The exit point can only be Kiemenai exit point between Latvia and Lithuania.

• * How many shippers hold capacity at Luhamaa entry?

There is daily allocation only. Currently no shippers hold any capacity. In 2023 and 2024 trades where by one shipper (Latvijan Gaze).

3. Balancing

• * Do all balancing provisions apply at Luhamaa entry? We found the following special rules for Luhamaa:

• * The entry nominations and physical flows at Luhamaa entry point must equal the exit nominations and physical flows at the exit point from the common zone.

Yes, as only transit is allowed, gas entering Luhamaa cannot be nominated in domestic consumption point of Estonia or Latvia. Transit exit allocations can be modified by the TSO in the case of a mismatch between transit entry allocations and exit nominations.

• * The imbalance volume in the event of discrepancies between the gas nominated and the gas physically injected or withdrawn at Luhamaa is allocated on a monthly basis and pro-rata on the basis of the share of capacity bookings at the Luhamaa entry point (while at other interconnection points of the common zone, the imbalance volumes are allocated on a daily basis and pro-rata on the basis of the share of network users’ nominations). Why was it decided to apply this framework?

This monthly rule comes from pre-war period due to data exchange we had with Russian TSO

4. Congestion management rules: no rules apply at Luhamaa entry. Can you please confirm?

Yes, there is daily allocation only.

5. Interoperability Network Code

• * Art. 16 e. short term monitoring on gas quality and Article 17, i.e. information provision on short-term gas quality variation: do they apply at Luhamaa entry?

As far as we know, yes. The quality measuring and data publishing for Luhamaa point is done by Latvian TSO Conexus.

Tariffs:

• * Is Luhamaa entry included in the TAR NC RPM?

Yes

• * Which tariff/price applies at those bookings at Luhamaa entry?

“Day” Inter-system network use input price: https://elering.ee/en/gas-network-service