Key Benefits:
Attended the session: Philippe de LADOUCETTE, Chairman, Olivier CHALLAN BELVAL, Jean-Pierre SOTURA and Michel THIOLLIERE, Commissioners.
Given the energy code, in particular Article L. 134-2;
The European Directive 2003 /55/EC of 26 June 2003 concerning rules Common for the internal market in natural gas permits the injection of biomethane into European networks' To the extent that it is technically possible to inject and transport safely into the natural gas network.
In 2008, the Agence française de sécurité sanitaire de l' environnement et du travail (AFSSET) issued an opinion Favourable for injection into the natural gas networks of biomethane produced from waste from agriculture, forestry, the agri-food industry, households or catering, concluding that there is no risk Health.
In addition, articles L. 446-1 to L. 446-4 of the energy code Clarify the provisions relating to the sale of biogas, from which biomethane is produced after treatment. Article L. 446-2 provides that " Subject to the need to preserve the proper functioning of the transmission and distribution networks of natural gas, any biogas producer may enter into a contract with a natural gas supplier for the sale of biogas produced in the territory Pursuant to terms and conditions specified by decree in the Council of State. The resulting overcosts to the supplier are compensated. The administrative authority shall designate, through a transparent procedure, a buyer as a last resort to enter into a biogas purchase contract with any biogas producer who requests it ".
Pursuant to these provisions, the decrees N ° 2011-1594 and n ° 2011-1597 of 21 November 2011 frame the terms of sale and Contract between a producer of biomethane and a Provider. The decree of 23 November 2011 fixes the conditions for the purchase of biomethane injected into the networks and that of June 4, 2012 designates the buyer of last resort.
In 2013, three facilities for the production of biomethane regularly inject into the Natural gas distribution networks for a total volume of approximately 20 GWh/year. However, the standard time limit for setting up a biomethane injection facility is about three to five years, the growth in the number of facilities is expected to accelerate as of 2015: in December 2013, 493 projects were Identified by the transmission system (GRD) and transport (TSO) managers of natural gas, 271 of which are in the study phase by GRD and GRT. The prospects for biomethane injection in natural gas networks are estimated by GRTgaz and GrDF between 6 and 20 TWh per year by 2020.
The specification " Injection of biomethane in natural gas transmission networks ", prepared by the French Association of Gas (AFG) and which supplements the provisions defined in the technical requirements of the natural gas GRT, taken pursuant to the article L. 453-4 of the Energy Code, states that " no studies to date on the interaction between biomethane and groundwater contained in aquifer storage facilities, the injection of biomethane will be limited to the parts of the network of Transportation not carrying gas to storage ".
Facility So far, biomethane injection can only be connected to regional transmission networks and natural gas distribution networks. In addition, the only outlet for the production of injected biomethane is the consumption of natural gas on these injection zones. The ability to inject biomethane into a natural gas network can therefore be limited, especially in the summer when consumption is the lowest. It is thus necessary to define the priority rules that apply when several projects wish to connect to the same zone and compete for the injection capabilities of the zone.
The Working Group (WG) " Biomethane injection ", a forum co-sponsored by GrDF and the Agence de l' environnement et de la maîtrise de l' énergie (ADEME), brings together the main players in the sector, including project carriers, field offices, equipment suppliers, TSOs and GRDs, the National Federation of Concurrent Communities and Authorities (FNCCR), the Directorate-General for Energy and Climate (DGEC) and the Energy Regulatory Commission (ERC). This consultation body drafted and proposed to the CRE in October 2013 a procedure for the management of the reservation capacity for the injection of biomethane in the gas networks. This procedure is published on the website of the " GT Biomethane Injection " (1) is intended to define the roles of the actors (GRT and GRD, project carriers or producers of biomethane) and the priority rules when connecting a biomethane injection facility to the natural gas networks.
Article L. 134-2 of the Energy Code states that " In accordance with the laws and regulations, the Commission for the Regulation of Energy shall specify, by decision published in the Official Journal, the rules concerning: [...] 3 ° the conditions for connecting to the transmission networks and Natural gas distribution ". In accordance with these provisions, the purpose of this CRE deliberation is to clarify the rules for the management of the reservation capacity for the injection of biomethane on the transmission and distribution networks of natural gas, which are Conditions for connecting to these networks. It looks at:
-the " First come, first served " ;
-the definition of the biomethane injection area;
-the definition of a biomethane injection capabilities registry manager;
-the terms and conditions of exchange of information between actors;
-initialization Queues with projects already under investigation by network managers.
This release occurs after a public consultation of the CRE held from November 22, 2013 to December 20, 2013. The CRE received eighteen contributions to this public consultation: eight from producers or promoters, one from an association representing stakeholders in the biogas sector, two from a supplier and from an association Suppliers, four from infrastructure managers, one from an authority organising the distribution of energy, one from an industrialist and one from the French Gas Association. Non-confidential replies are published on the CRE website (2) at the same time as this deliberation.
Following this public consultation, the ERC organised a round table on 23 January 2014 with the main actors Responding to this public consultation.
The details of the CRE in this deliberation will need to be integrated by the " GT Biomethane Injection " In the update of the procedure for managing the use of biomethane injection capacity in natural gas networks. The amended procedure shall be transmitted to the CRE by the " GT Biomethane Injection " Within two months of the publication in the Official Journal of the French Republic of this deliberation.
In addition, in the light of the contributions of the stakeholders to the public consultation, the CRE asks the GT Biomethane Injection " Further analysis of the procedure, with a view to future updates of the procedure. The various requests from the CRE are appended to this deliberation.
The Higher Energy Council (ESC) was referred by the ERC to the draft decision for opinion. It took note of this draft at its meeting on 15 April 2014 and requested " The relaxation of the deadlines for the second update of the procedure, taking into account the small number of projects that will inject biomethane at the end of September 2014. ".
In order to take into account the ESC's request, the CRE has changed its decision in the same way. The following: updates of the procedure incorporating the results of the additional analyses requested by the ERC to the " GT Biomethane Injection " Must be transmitted to it at the end of December 2014 and end of December 2015 at the latest.
SUMMARY
A. -Procedure for the management of biomethane injection capacity reservations on the transmission and distribution networks of natural gas
1. Rule of " First come, first served "
1.1. Proposal of " GT Biomethane Injection "
1.2.
Public Consultation Summary 1.3.
CRE Analysis 2. Definition of the biomethane injection zone
2.1. Proposal of " GT Biomethane Injection "
2.2. Summary of the Public Consultation
2.3.
CRE Analysis 3. Biomethane injection capacity registry manager
3.1. Proposal of " GT Biomethane Injection "
3.2. Proposal for GRTgaz and TIGF
3.3. Public Consultation Summary
3.4.
CRE Analysis 4. Modalities and deadlines for the exchange of information between actors
4.1. Proposal of " GT Biomethane Injection "
4.2.
Public Consultation Summary 4.3. Analysis of CRE
5. Initializing queues with projects already under instruction by
5.1 network managers.
5.2 Public Consultation Summary.
B CRE analysis -CRE decision
Appendix. Additional analysis requests from CRE
1.1. Rule of " First come, first served "
1.2. Technical solutions for accessing the capabilities available upstream of a
1.3 distribution field. Biomethane injection capacity registry manager
1.4. Terms and Timing of Information Exchange Between Actors
A. -Procedure for the management of storage capacity reservations for biomethane on natural gas transmission and distribution networks
The procedure proposed by the " GT Biomethane Injection " Describes the mechanism by which a project holder or a producer of biomethane is allocated a biomethane injection capacity in a natural gas transmission or distribution system. It is organised around the three successive stages necessary for the connection of a biomethane injection facility, from the request for reservation of the injection capacity by the project holder or producer:
- The first step gives rise to detailed studies (for GRDs) or feasibility studies (for TSOs) for the injection of biomethane by the network manager concerned to know the injection potential of the area and to have a The first estimate of the network connection cost. This information will be used by the project holder to write his file " "ICPE" (classified facility for environmental protection). This step is being finalized with the filing of the project holder's ICPE file with the Regional Environmental, Planning and Housing Directorate (DREAL); and
-the second phase involves the administration of the ICPE file. The competent authority shall verify the completeness of the file and then the appraiser. The duration of this step varies according to the ICPE regime of the biomethane installation (declaration, registration or authorization);
-the third step corresponds to the contractualization of the connection and the injection between the manager Networks concerned and the project holder. It concludes with the commissioning of the installation and allocation of all or part of the reserved capacity requested by the project holder.
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The procedure defines the priority rules for handling requests for reservations and then allocating injection capacity And their implementation modalities, as well as the interactions between the Stakeholders (project carriers, GRT or GRD and the Capacity Management Registry Manager).
1. Rule of " First come, first served "
1.1. Proposal of " GT Bias GT "
The priority rule defined by the procedure is that of" First come, first served ". Compliance with this rule is ensured by the maintenance of a capability management register consisting of a queue per injection area listing all capacity reservation requests in chronological order as well as of a database To record the capabilities already allocated to project carriers.
According to this rule, a project promoter first entered in the Capacity Management Registry has a priority injection right on the entered project carriers Later in the registry. Thus, for a given project holder, a request for the reservation of another project holder subsequent to his own project will have no effect on the capacity available for his project.
In the event of an increase in the available capacity, the allocation of These new capabilities are proposed to project holders or producers with a capacity reliquat on the area, i.e. those whose final injection capacity is less than the capacity initially reserved. This proposal is made in ascending order of order number, up to the saturation of the available capacities. If no producer or project carrier present in the queue wishes to use these new injection capabilities, the latter will be made available to producers or promoters who will subsequently enter the queue
In the event of a decrease in injection capacity, producers who inject on the area must reduce their injection capacity in descending order of order number in the allocation base of allocated capacity up to a flow rate Compatible with network capacity. A capacity balance is reserved for them in the queue, corresponding to the difference between the capacity initially allocated and the new capped allocated capacity. The order number that is assigned to a producer on the queue is the same as the order number that it has in the allocated capacity registration database. In the event of an increase in the absorption capacity of the injection zone, the capacity is allocated as a priority to the producers who are crushed to the height of their reliquat. For promoters in the queue whose installations do not yet inject into the networks, the injection studies are then updated by the network managers concerned.
1.2. Public Consultation Summary
Rule of " First come, first served " :
Almost all contributors support the application of the " First come, first served " To manage the reservation of biomethane injection capacity. Thus, several respondents believe that this rule guarantees the producer that the capacity to which he/she subscribes will not be reduced by the subsequent arrival of another producer in the area and that it gives visibility to the time frame of their Injection project
Only two contributors issue reserves. One of the two believes that projects should be prioritized within the framework of the Territorial Climate and Energy Plans and the " First come, first served " Should be used only as a last resort to share projects that have the same priority in the interests of the territory concerned. The other considers that this rule is not acceptable in the case of an injection zone as defined by the procedure (3), provided that the capacity on the upstream networks is accessible to the producers connected to the networks Downstream.
Taking into account the available capacity reductions:
Almost all responding actors support the CRE's proposal expressed in its public consultation document on how to take account of the Reductions in the available capacity of a given injection zone. The CRE had indicated that, in these situations, the procedure would benefit from clarifying that capacity reductions should first relate to the allocable capacities of projects in the queue in descending order of order number, Then the allocated capacity of the producers already injecting in the networks in descending order of order number.
Only a project carrier considers that, for producers already injecting in the networks, the reduction in capacity should Apply to all producers in proportion to their allocated capacity.
1.3. CRE Analysis
The CRE considers the " First come, first served " Promotes transparency in the management of capacity reservations and improves the visibility of project promoters and producers on future developments in allocated capacity. For a project holder with a reserved capacity, this rule limits the decrease in the capacity available for his project, to the only variation of the absorption capacity on the injection zone. As such, this rule does not call into question the economic equilibrium on which the projects are decided.
Moreover, the Administrative Court of Appeal of Paris stated in its decision of 18 October 2012 on the rules on allocation Telephone number " 39-99 " That " The processing of applications in the order of arrival of the complete files, is such as to ensure respect for the principles of objectivity, transparency and non-discrimination " (CAA of Paris, 3rd Chamber, 18 October 2012, 11PA00967).
As a result, the ERC is in favour of applying the rule of " First come, first served " For the reservation of biomethane injection capabilities in natural gas networks.
In order not to penalize the facilities already injecting in the networks, the CRE considers, however, that the procedure should specify that the reductions of the Capacity refers first to the allocable capacities of projects in the queue in descending order of order number, and then the allocated capacities of producers already injecting in the networks in descending order of number Order.
2. Definition of the biomethane injection zone
2.1. Proposal of " GT Biomethane Injection "
The biomethane injection capabilities management registry, and thus the associated queue and registration base, is implemented by injection zone.
The procedure defines the injection area as a The regional transmission system and the downstream distribution zones connected to it (distribution networks located downstream of a distribution transport interface or PITD).
Currently, the design of regional transport networks and Natural gas distribution does not allow natural gas in a network of Distribution to the upstream distribution system or to the regional transport network upstream of the PITD. In the absence of a technical solution to lift the gas back to the regional transmission or distribution networks, the definition of the area of injection used in the procedure implies that:
-for a producer of biomethane connected to a distribution network, the only outlet for injected biomethane is the consumption of natural gas on this distribution network and on the downstream distribution networks;
-for a A producer of biomethane connected to a regional transport network, the outlet of injected biomethane is the consumption of natural gas on this regional transport network and on the distribution networks downstream of the regional antenna considered.
" GT Biomethane Injection " Proposes that this definition of the area of injection be reviewed after the first return of experience in the implementation of the procedure over the years 2014 and 2015, with a view to an update intended to enter into force No later than January 1, 2016. This feedback should be complemented by a technico-economic study of the technical solutions for accessing the capabilities available upstream of the distribution networks.
2.2. Public Consultation Summary
Definition of the area of injection and the study of technical solutions in the event of saturation of the area of distribution:
The vast majority of contributors consider that a definition of the area An injection of an antenna of the regional transmission system and distribution networks located downstream of this regional antenna is likely to promote the development of the biomethane sector. A contributor considers it important to experiment for two years with an injection zone thus defined to promote the development of the sector and then to realize a return of experience to conclude on its relevance.
Only two Contributors are not in favour of this definition, of which a GRD believes that this definition introduces a distortion in access to available capacity and limits the implementation of territorial projects statistically closer to networks of Distribution of transportation networks. It adds that, in the absence of a technical solution to access the capacity of upstream networks, the definition of a zone by network manager is necessary in order not to introduce distortions in access to capacity
All contributors are in favour, in the event of saturation of the area of distribution, of the study of technical solutions allowing access to the capacities available upstream of the zone, these searches for technical solutions Favourable to the development of the sector. Several contributors consider that the study of technical solutions in the event of saturation is a necessary condition for experimenting with common transport and distribution zones as defined in the procedure.
Updated Of the procedure no later than 1 January 2016 on the basis of a return of experience:
All contributors are in favour of updating the procedure by 1 January 2016 at the latest, based on the feedback from the industry, in particular on the implementation of these technical solutions for the recovery of natural gas. However, project holders believe that this date is too far away. They consider that a return of experience can be achieved earlier, based on that of the European countries where the sector is more mature. A project carrier considers that this update should ensure that the reserved and allocated capabilities are maintained prior to the update, in order not to destabilize projects that are already being injected or are being investigated before this update.
2.3. Analysis of the CRE
The definition of the injection zone proposed in the procedure increases the injection zone of the producers of biomethane connected to the regional transmission networks, which thus have access to the sum of available capacities Transportation and distribution. In the absence of a backward technical solution or network mesh, a producer with a distribution network has access only to the capacity available for distribution.
In some cases, a producer connected to a network Transport and inject large volumes of biomethane can thus saturate the available capacity on a downstream distribution network, thus limiting any subsequent connection of the installation of biomethane injection to the same network of Distribution. In these situations of saturation of a distribution area, the procedure provides that the project holder wishing to connect to this area or the producer wishing to increase his injection capacity may request the GRD concerned to study with the GRT or GRD located upstream a technical solution to find an outlet for this surplus of production. This solution can, for example, take the form of a physical countdown or network mesh. At the same time, the project holder must invest in storage-type solutions or even relocate the project.
The CRE considers that this definition of the injection zone is favourable to the overall development of the injection industry. Biomethane. It allows all projects, whether they connect to the transmission network or the distribution network, to gain access to the absorption capacity that they can have at the time of the connection request.
Given the number The CRE considers that a possible update of the procedure on 1 January 2016 will provide a return of experience on the implementation of the procedure. Sufficient duration. It believes, however, that this potential update should not destabilize projects that are already being injected or are being investigated by changing the allocated and dedicated capacity in the queue.
As a result, the ERC is in favour of the Review of the definition of the area of injection for possible updating of the procedure on 1 January 2016, on the basis of the feedback on the implementation of the procedure in 2014 and 2015 and a technical-economic study (already Launched within the " GT Biomethane Injection ") Technical solutions for accessing the capabilities available upstream of the distribution networks. This update, if it leads to a change in the definition of the injection area, can only be applied to new projects but will not be able to modify the capabilities already allocated and reserved on the queue.
3. Biomethane injection capacity registry manager
3.1. Proposal of " GT Bias GT "
The procedure proposed by the" GT Biomethane Injection " Provides for the creation of a new actor: the Injection Capability Registry Manager. For a given injection area, the registry manager is the guarantor of the proper maintenance of the capacity registry:
-it manages the queue inputs and outputs: it assigns the order numbers to each new request Of capacity reservation and placed in the queue the reserved capacity after verification of the transmission time of the documents provided by the promoters to the network managers. Where appropriate, in the event of non-compliance with the transmission deadlines, it shall inform the network manager concerned of the premature exit of the project queue. It allocates the biomethane injection capabilities to the project holder or to the producer of biomethane;
-it is kept informed by the network manager concerned as soon as the absorption capacity of a zone varies significantly. The registry manager then transmits to the network managers whose projects are impacted by this variation the new capacity allocatable (for project holders in the queue) or allocated (for projects injecting on The field).
3.2. GRTgaz and TIGF proposal
TSOs propose to provide the role of registry operator, each for injection areas located on their respective transportation systems. They explain that the TSOs have the overall vision of consumption over a given injection area. Thus, GRTgaz would be the registry manager for all injection zones on the balance zones North and South and TIGF would be the registry manager for all injection zones on its balancing area.
3.3. Summary of Public Consultation
All contributors are in favour of designating a registry manager to ensure the management of the reservations and allocation of injection capacity for each area Of injection. Natural gas suppliers believe that it will ensure strict management of reservations and capacity allocations, as well as a harmonisation of practices across the French territory.
The vast majority of Contributors consider the TSOs to be in the best position to maintain the role of registry manager due to their network positioning. Only three contributors consider that the registry manager should be independent of network managers and appointed through a call for tenders. Several contributors point out that the rules for the management of the register must be transparent and non-discriminatory between carriers of projects on the different networks and that it is necessary to ensure the confidentiality of information Transmitted to registry operators. These contributors consider that regular monitoring by the ERC or DGEC would ensure compliance with these rules.
3.4. Analysis of the CRE
A biomethane injection zone consisting of a regional transportation network and the downstream distribution areas connected to it, the registry manager must have a comprehensive vision of the Consumption, on the one hand, on the regional transport network and, on the other hand, on the downstream distribution networks, in order to be able to allocate the injection capacity, within the limit of the absorption capacity of the
. Favourably the TSOs' proposal to keep the role of registry manager, each for the Injection zones located on its network. It shares the view expressed by the majority of contributors that the TSOs are the best actors to play this role. Their limited number and presence in the entire French territory served by natural gas will ensure the homogeneity of the implementation of the procedure for the management of injection capacity reservations. Moreover, for a given injection zone, the relevant TSO has the global vision on the absorption capacity of the area: it knows the consumption of industrial customers connected to its regional transport network and the volumes Delivered to the PITD for the natural gas consumption of the customers connected to the distribution networks.
As a result, the CRE considers that the procedure should specify that the role of the registry manager is ensured by the TSO, each for the Injection areas on its transportation network.
4. Modalities and deadlines for the exchange of information between actors
4.1. Proposal of " GT Biomethane GT "
In addition to the priority rules for the processing of reservation requests and the allocation of injection capabilities and their implementation procedures, the procedure defines the set of interactions between The actors involved (project carriers, GRT or GRD and the capacity management registry manager).
For each injection zone, the registry manager only contacts the TSO and the GRDs present on the area. Similarly, a project holder or producer shall have sole contact with the manager of the natural gas network to which he wishes to be connected or to whom he is connected.
In addition, the procedure shall specify the maximum time limits allowed for each Three successive stages (cf. § A) and the intermediate steps necessary for the connection of a biomethane injection facility, from the request for reservation of the injection capacity by the project holder or the producer. These delays are as follows:
-for the first step: 18 months maximum between the command of the Phase 2 study and the depot of the project holder's ICPE file with DREAL;
-for the second step: from 11 months to 21 months Maximum depending on the ICPE regime of the biomethane installation (declaration, registration or authorization), between the filing of the ICPE file and the authorization to operate the facility;
-for the third stage: The maximum 36 months between the operating authority and the commissioning of the installation and the allocation of all or part of the reserved capacity requested by the project holder.
For each of the above steps and their steps Intermediary, the network manager transmits to the registry manager the documents received from the project holder, so that the registry manager ensures that the project holder is timely.
4.2. Summary of public consultation
All contributors are in favour of the network manager, on which an injection facility is or will be connected, either the sole contact person for the project holder or the Producer of biomethane. They consider that this will promote the development of the sector by simplifying the approaches of project promoters and ensuring better responsiveness in the event of variations in the injection capacity available on an injection zone.
4.3. Analysis of the CRE
During a request to connect a biomethane injection facility to a natural gas network, the natural contact person for the project holder is the network manager concerned. The CRE is therefore in favour of the proposal to designate the network manager as the sole interlocutor for the project holder or the producer of biomethane. It considers that this organisation is such as to simplify the management of injection capacity on an injection zone by avoiding the multiplication of contacts for project holders and the producers of biomethane
Exception to the time limits of the various stages, the procedure proposed by the " GT Biomethane Injection " Specifies that, where a project is the subject of a suspensive remedy, a further period of nine months shall be granted to the project holder, from the date of appeal, to transmit the necessary documents. The ERC notes that the " Procedure for processing applications for connection of a production facility in BT with power greater than 36 kVA and in HTA, to the public distribution network managed by ERDF On 11 February 2014, in the event of an appeal against the administrative authorisation relating to the installation of a project holder, the processing of the file by ERDF may be suspended, at the request of the project holder, for a maximum period of one year, With the possibility of an annual renewal if there is no other project queued after that of the project holder.
The CRE considers that a period of stay of one year from the date of appeal, as mentioned in the procedure In electricity, is more suited to the standard times of appeal. It considers, as in the case of the electricity procedure, that the procedure for the management of biomethane injection capacities should make it clear that this suspension may be renewed annually, at the request of the project holder, in the case of absence of any other Project in the queue after that of the project holder concerned by the application.
5. Initializing queues with projects already under investigation by network managers
The procedure provides that a biomethane injection project enters the queue when GRD or TSO receives from the Project holder, by registered mail with acknowledgement of receipt, respectively the order or study agreement signed by the project holder for the study " Phase 2 " : the detailed study for GRDs or the feasibility study for TSOs.
To date, Phase 2 studies are underway for approximately 100 biomethane injection projects. Because these projects are already being investigated by the network managers, it is necessary to define the policy to initialize the queue for the injection areas affected by these projects in the management procedure of the Bookings for biomethane injection capacity on natural gas networks.
In its public consultation paper, the CRE indicated that it was considering an initiation of queues with projects already under investigation. The basis of the " First come, first served " : these projects are integrated into the queue, in chronological order of order date or signature of phase 2 study agreement, the date of receipt by the network manager of the signed order letter or study agreement For the authentic phase 2 study. For example, for a given injection area, the project holder who performed this command first will be assigned an order number equal to 1.
5.1. Summary of public consultation
All contributors, with the exception of one project holder, are in favour of projects already being investigated by network managers first integrating queues As soon as they are created, according to the methodology envisaged by the CRE in its public consultation document. One of these contributors considers that project promoters, whose project is being investigated by the network operators, will have to be informed by the network managers of this procedure for the initialization of the queues.
Only a holder The project is of the opinion that this disfavours currently less advanced projects that have not yet been able to apply for a Phase 2 study due to a regulatory schedule.
5.2. Analysis of the CRE
In order to ensure as much transparency as possible on how to initialize queues, the CRE considers it necessary to specify the rules used in the capacity reservation management procedure Of biomethane injection on natural gas networks.
It considers that the " First come, first served " Is the simplest to implement and is consistent with the one to be used for future projects. Finally, it believes that promoters and producers who are already injecting into the networks should be informed by the network managers of the implementation and the results of this rule for the initialization of the queues. For.
B. -CRE Decision
The CRE specifies the rules for the management of biomethane injection capacity reservations on the transmission and distribution networks of natural gas defined in the procedure proposed by the " GT Biomethane Injection " As follows:
-the reductions in potential available capacity at the injection zone level first relate to the allocable capabilities of projects in the queue in descending order of order number, and then capabilities Allocation of producers already injecting in the networks in descending order of order number;
-the update to 1 January 2016 of this procedure, on the basis of feedback from its implementation in 2014 and 2015 and studies Add-on, will not change the allocated and reserved capabilities in the queue Before this update;
-the registry manager role is provided by the TSO, each for the injection areas on its transport network;
-if a project is the subject of a suspensive remedy, a one-year delay Shall be granted to the project holder, from the date of appeal, to transmit the necessary documents. This suspension may be renewed annually, at the request of the project holder, if there is no other project in the queue after that of the project holder concerned;
-to initialize the queues, the Projects already in progress are integrated in them, in chronological order of order date or signature of phase 2 study agreement, the date of receipt by the network manager of the order or convention mail A signed study for the authentic Phase 2 study. The project holders and producers concerned shall be informed of this initiation procedure by the GRT and GRD concerned and of its outcome.
An update of the procedure for the management of biomethane injection capacity in the Natural gas networks taking into account the above elements shall be transmitted to the CRE by the " GT Biomethane Injection " Within two months of publication in the Official Journal of the French Republic of this deliberation.
GRT and GRD will publish the procedure for the management of the reservation capacity for the injection of biomethane on the networks of Transmission and distribution of natural gas on their website.
Pursuant to Article L. 452-3 of the Energy Code, this release will be published in the Official Journal of the French Republic.
ANNEX
CRE COMPLEMENTARY ANALYSES REQUESTS
On the basis of its analyses and contributions to the public consultation on the injection capacity management procedure Biomethane in the networks, the CRE formulates below requests to " GT Biomethane Injection " Additional procedure analysis.
1.1. Rule of " First come, first served "
Several contributors point to the need to specify in the procedure, in addition to the rule envisaged by the ERC in its public consultation regarding the taking into account of capacity reductions, that the number Is retained, if the reduction in capacity through application of this rule leads to a change in the ICPE regime.
In the case of a reduction in the available capacity of an injection zone impeding the capacity allocation to a Project whose ICPE folder is currently being investigated by the administration, the The project holder may wish to benefit from an ICPE scheme that is less restrictive and more suited to the new capacity available for its installation. The procedure specifying that in the event of a change of the ICPE regime the reserved capabilities are out of the queue so as not to block the available capacity on the injection zone, this project holder would see its capacity outputs from the queue To wait. The project holder would then be encouraged not to change his ICPE regime in order to maintain the project in the queue.
The CRE asks the " GT Biomethane Injection " Consider the appropriateness of developing the rule to exit a project from the queue if its ICPE regime is modified, in the case of a reduction in the available capacity of an injection zone impacting the allocable capacities of the Project being investigated. These elements will be taken into account in the next update of the procedure to be transmitted to the CRE at the end of December 2014 at the latest.
1.2. Technical solutions for accessing the capabilities available upstream of a distribution area
Technical solutions, such as rebounds or mesh networks of distribution networks, may allow, in the event of saturation, To circulate or even trace natural gas from the distribution system to the distribution network of the injection zone, or to the regional transport network. Thus, if these solutions are developed, a producer of biomethane connected to a distribution network will benefit from the absorption capacities present on the entire injection zone.
At this point mesh solutions are already Proposed by some GRDs. On the other hand, no countdown project has been implemented in France. Countdown projects exist in Europe with very different characteristics. In 2012, GDF Suez's Centre for Gas Research and Innovation (CRIGEN) made a comeback on the back solutions developed in the UK and Germany.
This feedback shows that back solutions require an investment of around EUR 2 million. The " GT Biomethane Injection " Plans to conduct a technical-economic study on the technical feasibility and cost of implementing a countdown solution in France. The results of this study are expected by the end of 2014.
The majority of contributors consider that the technical solutions for accessing the capabilities available upstream of a distribution area are essential to the Development of the biomethane injection system in the networks. TSOs and another contributor consider the development of back solutions between distribution networks and transportation systems to be a complementary technical solution to other solutions such as mesh size. A GRD recalls that the liquefaction of biomethane, the storage of biogas or biomethane, or the use of fuel will also have to be studied in the event of saturation. A project carrier believes that the injection of biomethane on the main transport network should be investigated, a solution to which the two TSOs are not favourable.
The CRE is in favour of developing any technical solution to the problem. To maximise the value of biomethane and thus the development of this sector, provided that its cost remains reasonable.
Given the large number of biomethane projects identified by the GRT and GRD to date, the CRE Request to " GT Biomethane Injection " To continue the technical-economic study on the technical feasibility and cost of implementing a countdown in France, so that it can be completed by the end of 2014, at the latest by the end of 2014.
However, it considers that these rebounds should not be the only alternatives considered. It is in favour of the analysis by network operators in relation to project carriers and producers of any other solution to deal with situations of injection zone saturation. It also asks the " GT Biomethane Injection " To conduct an analysis of alternative solutions to maximize the volumes of biomethane produced.
1.3. Biomethane Capacity Registry Manager
The GRT, GrDF, and SPEGNN have agreed to jointly draft the specifications for the future single and shared IT tool for managing capacity registries. This specification will then define the development and operating costs of this tool and, more generally, the costs of managing the registry.
The majority of contributors are unfavourable to the integration of costs related to the Development and management of the Register at the cost of detailed and feasibility studies Phase 2 ", the order of these studies that triggered the entry of the project into the queue and thus the request of the registry manager. These contributors consider that these additional costs will penalise a start-up sector. They specify that the costs of Phase 2 studies are already high and that the costs related to the development and management of the registry were not considered in the definition of the rates for the purchase of injected biomethane. Consequently, these contributors consider that the costs relating to the development and management of the register should be integrated within the scope of the costs of the TSO or via the contribution to the public gas service. Only a project holder considers that these costs should be included in connection costs, that is, after the project holder has been granted permission to operate.
At the round table organized by the CRE, GrDF proposed that Costs related to the development and management of the register are borne by the TSO and GRD, in proportion to the number of projects under investigation or already injected into the networks of each operator.
The ERC considers that the costs Relating to the development and management of the register supported by managers of Networks will have to be covered, provided they correspond to the costs of efficient network managers. Coverage will be defined when these costs have been accurately and fully costed by the network managers.
It requires network managers to forward their cost estimates for the Development and management of the capability registry at the end of June 2014 at the latest.
1.4. Modalities and deadlines for the exchange of information between stakeholders
Delays in the procedure:
Several contributors, including project holders, consider that the time limits specified in the procedure are too short, including the time limit For the transmission of the agreement in principle on the technical and financial conditions following the phase 2 studies, those relating to the processing of ICPE files by the administration and the deadlines for the implementation of the installation of biomethane. In particular, several project promoters consider that once authorisation has been obtained, the eight-month time limit left to the project holder to make a financial table tour and sign his contract of injection is too short. These promoters wish that this period should be extended to ten months. Two project promoters consider that the deadlines for the studies carried out by the TSO are too long.
The procedure specifies the time limits for each major step in the processing of a project in the queue, as well as the maximum delays in the transmission of information or documents between project carriers and network managers. However, it is less precise about the maximum time limits for the exchange of information or documents between network managers and registry operators. The CRE considers that the procedure would benefit from a more precise definition of these deadlines.
These elements will be taken into account in the next update of the procedure to be transmitted to the CRE by the end of December 2014 at the latest.
The procedure specifies that the timeouts that are the responsibility of the manager of The network or registry manager does not cause the project queue to exit. The CRE considers that the procedure would benefit from defining more precisely the treatment of projects that would have been overlooked by the network manager or the registry manager, or who would have been delayed by these actors, when Registration in the capacity management registry. These elements will be taken into account in the next update of the procedure to be transmitted to the CRE by the end of December 2014 at the latest.
More generally, in the light of the comments of the contributors to the public consultation on the deadlines for the Different stages of the biomethane injection capacity management procedure, the CRE considers that the " GT Biomethane Injection " Must consider the appropriateness of adapting some of these deadlines on the basis of the return of experience of projects under investigation. In view of the return of experience necessary to analyse this subject, the results of this analysis will be taken into account in the updating of the procedure which will be transmitted to the CRE at the
. Injection capabilities:
Some contributors consider that the procedure does not adequately protect project holders against overbooking of injection capabilities by another project carrier previously entered into the queue To wait. They propose that the procedure incorporate consistency checks between the various documents and studies carried out in order to mitigate this risk.
The CRE considers that the procedure has safeguards to limit the risk of overbooking Injection capabilities. For example, the network manager has information as part of the Phase 2 study that allows him to quantify the flow of the biomethane installation. On the other hand, it calculates the reserved capacity from the declared maximum production capacity.
However, if, for each step of the procedure, the procedure specifies that the network manager transmits the documents Received from the project holder to the registry manager, so that the latter ensures that the project holder has met the deadlines, no checks on the consistency of the information contained in these documents are mentioned in the procedure. As a result, the ERC considers that the procedure would benefit from introducing such a consistency check which would be carried out by the network manager concerned.
More generally, the CRE considers that the procedure would benefit from clarifying that, for each of the main and intermediate stages of the procedure, the network manager is the guarantor of the traceability and archiving of the documents transmitted By the project holder. It is responsible for the dates entered in the register, so that the registry manager can ensure that the time limits are met.
These elements will be taken into account in the next update of the procedure to be followed. Transmitted to the CRE at the end of December 2014 at the latest.
Additional information made available to promoters and producers for each injection zone:
The procedure proposed by the " GT Injection Biomethane " Does not include, for a given injection zone, the publication of available injection capabilities, or even consulting the registry of the injection zone by project carriers or producers of biomethane.
Most contributors (including all project holders) is in favour of the publication of additional information for each injection zone, witness to a need for more transparency on the part of the network and registry operators. Some contributors, however, add that the information provided must be of real value to project holders and that their dissemination is limited to project promoters under investigation. The majority of network managers are not in favour, highlighting the disruption, questioning or risk of litigation that this publication will generate (some data published on the basis of their estimates To be different from contractual data, for example) as well as the cost of study necessary to dispose of this information to a grid France. They also stress the need to restrict the transmission of this information to promoters under investigation.
CRE is in favour of providing additional information on capacity management Of injection and the implementation of the procedure for reserving these capacities. It considers that promoters and producers should have access to more information on the capabilities available on the injection zone and on the network to which they wish to be or are already connected, provided that these Information is genuinely necessary for project holders and producers and that their availability is feasible at a reasonable cost.
As a result, the ERC considers that the " GT Biomethane Injection " Must work on the definition of the information to be made available, as well as the means of making available, project holders and producers concerning the capacities available on the injection zone and on the network to which they wish Be or are already connected, for the next update of the procedure.
These elements will be taken into account in the next update of the procedure to be transmitted to the CRE at the end of December 2014 at the latest
Done at Paris, 24 April 2014.
For the Regulatory Commission Energy:
The President,
P. Of Ladoucette
