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Δημόσια Διαβούλευση επί της εισήγησης της ΔΕΣΦΑ Α.Ε. αναφορικά με την επέκταση των ειδικών προϊόντων δυναμικότητας για την μεταφορά φυσικού αερίου από

Η Ρυθμιστική Αρχή Αποβλήτων, Ενέργειας και Υδάτων, στο πλαίσιο των αρμοδιοτήτων της σύμφωνα με τα άρθρο 68, 69 και 88 του ν. 4001/2011, θέτει σήμερα σε δημόσια διαβούλευση την υπ’ αριθμ. πρωτ. 378175/31.03.2026 (ΡΑΑΕΥ I-413939/01.04.2026) εισήγηση της ΔΕΣΦΑ Α.Ε. αναφορικά με τη συνέχιση διάθεσης των ειδικών προϊόντων δυναμικότητας για την μεταφορά φυσικού αερίου από την Ελλάδα στην Ουκρανία Route 1, 2 και 3, όπως εγκρίθηκαν από τις Ρυθμιστικές Αρχές Ελλάδας, Βουλγαρίας, Ρουμανίας, Μολδαβίας και Ουκρανίας, με μικρή τροποποίηση ως προς την ημέρα δημοπράτησής του, έως και τον Σεπτέμβριο 2026, ήτοι έως το τέλος του Έτους Αερίου 2025/2026, ενόψει ανασχεδιασμού του προϊόντος από το επόμενο Έτος Αερίου που θα τεθεί επίσης σύντομα σε δημόσια διαβούλευση. Η παρούσα διαβούλευση θεωρείται συμπληρωματική των από 14/10/2025 και 21/10/2025 διαβουλεύσεων που είχε διεξαγάγει η Αρχή για το ίδιο θέμα. Η δημόσια διαβούλευση θα διαρκέσει έως την Τρίτη, 7 Απριλίου

  1. Οι ενδιαφερόμενοι καλούνται να υποβάλουν τις απόψεις τους στη ΡΑΑΕΥ με ηλεκτρονική επιστολή στη διεύθυνση gasconsultation@raaey.gr ή εγγράφως, με κοινοποίηση στην ΔΕΣΦΑ Α.Ε., εφόσον το επιθυμούν. Η ΡAΑΕY θα δημοσιοποιήσει κατάλογο των συμμετεχόντων στη διαβούλευση, με εξαίρεση την περίπτωση κατά την οποία ο αποστολέας αιτείται τη μη δημοσιοποίηση των στοιχείων ή/και των απόψεων του. Συνημμένα Αρχεία: Πρόταση Διαχειριστών Annex 1- Description of Route 1 Annex 2- Description of Route 2 Annex 3- Description of Route 3 Public Consultation on the proposal of DESFA S.A. regarding the extension of the offer of the special capacity product for the transport of natural gas from Greece to Ukraine until the end of the Gas Year 2025/2026 The Regulatory Authority for Energy, Waste and Water (RAAEY), within the framework of its competencies according to Articles 68, 69, and 88 of Law 4001/2011, is launching today a public consultation on the proposal by DESFA S.A. (ref. 378175/31.03.2026, RAAEY I-413939/01.04.2026) regarding the extension of the offer of the special capacity product for the transport of natural gas from Greece to Ukraine Route 1, 2 και 3, as approved by the Regulatory Authorities of Greece, Bulgaria, Romania, Moldova kai Ukraine, with a minor modification regarding the timing of the execution of the auctions, until September 2026 (included), i.e. until the end of the Gas Year 2025/2026, in view of a redesign of the product starting from the next Gas Year, which will also be set under public consultation soon. This consultation is considered to be supplementary to the ones held by RAAEY on 14/10/2025 and 21/10/2025 on the same issue. The public consultation will last until Tuesday, April 7,
  2. Interested parties are invited to submit their views to RAAEY via email at gasconsultation@raaey.gr or in writing, with a notification to DESFA S.A. if they wish. RAAEY will publish a list of the participants to the consultation and views submitted, except in cases where the participant requests that their details and/or views not be disclosed. Συνημμένα Αρχεία: Common Proposal of the TSOs Annex 1- Description of Route 1 Annex 2- Description of Route 2 Annex 3- Description of Route 3 Annex 1 - Description of Route 1 capacity product Arrangements that need to be adopted by the regulatory authorities of Greece (RAAEY), Bulgaria (EWRC), Romania (ANRE), the Republic of Moldova (ANRE) and Ukraine (NEURC) In addition to the provisions of Regulation (EU) 2017/459, a special capacity product is made available jointly by the Operators of Greece (DESFA), Bulgaria (BULGARTRANSGAZ), Romania (TRANSGAZ), the Republic of Moldova (VESTMOLDTRANSGAZ) and Ukraine (Gas TSO of Ukraine LLC) as follows: Specific capacity product characteristics Product name: Route 1 Product duration: Monthly product Product availability period: May 2026 to September 2026 (monthly products) Entry/Interconnection Points concerned: Kulata / Sidirokastron, Negru Voda 1 / Kardam, Isaccea 1 / Orlivka, Causeni, and Grebenyky Transport Capacity Direction: from Greece to Ukraine. Restrictions: holders of the special Route 1 product will not be able to use it to transport natural gas to and from Virtual Trading Points or to domestic delivery points in Bulgaria, Romania, and the Republic of Moldova. In order to acquire the special product Route 1, interested network users must participate in single auction on Regional Booking Platform (RBP). Method of providing special capacity product Capacity allocation procedure: Auction. Through a single monthly product auction, equal capacity is allocated to the relevant interconnection points for the specific Month M in competition with Route 2 and Route 3 monthly capacity products of respective TSOs Auction execution platform: RBP (Regional Booking Platform) Auction algorithm: Uniform Price Algorithm as provided for in Article 18 of Regulation (EU) 2017/459 Auction execution time: 07:00 UTC (summer time) on the Wednesday following the third Monday of Month M-1 (Route Auction Day), for the allocation of Capacity for the immediately following Month M. A capacity purchase bid at the above Interconnection Points of the special monthly capacity product Route 1, within the framework of the aforementioned auction, is treated as follows: submission, withdrawal or modification from 07:00 UTC to 07:30 UTC (summer time). In the event that, at one or more of the above-mentioned Interconnection Points of the special product Route 1, the rolling auction of monthly capacity, as provided for in Article 13 of Regulation (EU) 2017/459, for Month M, has not been completed by the Route Auction Day, then the auction for the allocation of capacity at the above Interconnection Points of the special product Route 1 during Month M shall be cancelled. Conditions precedent for participation in the auction: the conditions precedent applicable to participation in capacity allocation auctions, as provided for in Regulation (EU) 2017/459, for each of Kulata / Sidirokastron, Negru Voda 1 / Kardam, Isaccea 1 / Orlivka, Causeni and Grebenyky IPs, and in accordance with the regulatory framework applicable at each point for network user access to the natural gas transmission systems of Greece, Bulgaria, Romania, the Republic of Moldova and Ukraine. Auction Reserve Price: the sum of the Starting Reserve Prices applied by each of the above operators for the allocation of monthly capacity at Kulata / Sidirokastron, Negru Voda 1 / Kardam, Isaccea 1 / Orlivka, Causeni and Grebenyky IPs for the special product Route 1, expressed in EURO/kWh/D/ Month (in the case of national currency, the exchange rate with the EURO published by the central bank of each country on the working day preceding the day on which the auction takes place is considered), reduced by 25% for BULGARTRANSGAZ and DESFA, 50% for TRANSGAZ and VESTMOLDTRANSGAZ and 46% for GTSOU on the relevant side of their IPs. Capacity to be auctioned: The minimum available firm capacity at any of the Interconnection Points to which the Route 1 special product relates, after the completion of the rolling monthly auction, in accordance with Article 13 of Regulation (EU) 2017/459 for the same Month considering competition constraints at respective IPs related to Route 2 and Route
  3. If according to the above the monthly capacity to be auctioned is 0, the auction for the allocation of capacity for the special product Route 1 during Month M shall be cancelled. Use of special capacity product Route 1 Submission of Daily Nominations/Re-nominations: Holders of the Route 1 special capacity product submit Daily Nominations and re-nominations at the Kulata / Sidirokastron, Negru Voda 1 / Kardam, Isaceca 1 / Orlivka, Causeni and Grebenyky , concerning the special product Route 1, in accordance with the provisions of Regulation (EU) 312/2014 and the regulatory framework applicable at each point. In addition, before the deadline for submitting Daily Nominations and before the deadline for submitting a re-nomination with which the holder of a Route 1 special capacity product wishes to change the quantity of natural gas transported on its behalf from Greece to Ukraine, within the framework of reservation of capacity of special capacity product Route 1, he shall send an email to the natural gas system operators DESFA, BULGARTRANSGAZ, TRANSGAZ, VESTMOLDTRANSGAZ, and Gas TSO of Ukraine LLC, specifying the quantity of natural gas that it wishes to be transported on its behalf from Greece to Ukraine, within the framework of the Route 1 special product capacity reservation. Calculation of Confirmed Quantity at Entry/Interconnection Points relating to the special Route 1 product: To calculate the Confirmed Quantity at the individual Entry/Interconnection Points on behalf of a Network User who is the holder of the special capacity product Route 1, in addition to the provisions of any Interconnection Agreements between the operators, the rule of the lesser quantity shall apply among the processed quantities calculated by each of the natural gas system operators, i.e. DESFA, BULGARTRANSGAZ, TRANSGAZ, VESTMOLDTRANSGAZ, and Gas TSO of Ukraine LLC, for the quantities nominated for transmission from Greece to Ukraine by the said Network User within the framework of reservation of the special product capacity Route
  4. Annex 2 - Description of Route 2 capacity product Arrangements that need to be adopted by the regulatory authorities of Greece (RAAEY), Bulgaria (EWRC), Romania (ANRE), the Republic of Moldova (ANRE) and Ukraine (NEURC) In addition to the provisions of Regulation (EU) 2017/459, a special capacity product is made available jointly by the Operators of Greece (DESFA), Bulgaria (BULGARTRANSGAZ), Romania (TRANSGAZ), the Republic of Moldova (VESTMOLDTRANSGAZ) and Ukraine (Gas TSO of Ukraine LLC), and the Operator of the Greece-Bulgaria interconnector (IGB) as follows: Specific capacity product characteristics Product name: Route 2 Product duration: Monthly product Product availability period: May 2026 to September 2026 (monthly products) Entry/Interconnection Points concerned: Amfitriti, Komotini DESFA/IGB, Stara Zagora, Negru Voda 1 / Kardam, Isaccea 1 / Orlivka, Causeni, and Grebenyky Transport Capacity Direction: from Greece to Ukraine. Restrictions: holders of the special Route 2 product will not be able to use it to transport natural gas to and from Virtual Trading Points or to domestic delivery points in Greece, Bulgaria, Romania, and the Republic of Moldova. In order to acquire the special product Route 2, interested network users must participate in single auction on Regional Booking Platform (RBP). Method of providing special capacity product Capacity allocation procedure: Auction. Through a single monthly product auction, equal capacity is allocated to the relevant interconnection points for the specific Month M, in competition with Route 1 and Route 3 monthly capacity products of respective TSOs Auction execution platform: RBP (Regional Booking Platform) Auction algorithm: Uniform Price Algorithm as provided for in Article 18 of Regulation (EU) 2017/459 Auction execution time: 07:00 UTC (summer time) on the Wednesday following the third Monday of Month M-1 (Route Auction Day), for the allocation of Capacity for the immediately following Month M. A capacity purchase bid at the above Interconnection Points of the special monthly capacity product Route 2, within the framework of the aforementioned auction, is treated as follows: submission, withdrawal or modification from 07:00 UTC to 07:30 UTC (summer time). In the event that, at one or more of the above-mentioned Interconnection Points of the special product Route 2, the rolling auction of monthly capacity, as provided for in Article 13 of Regulation (EU) 2017/459, for Month M, has not been completed by the Route Auction Day, then the auction for the allocation of capacity at the above Interconnection Points of the special product Route 2 during Month M shall be cancelled. Conditions precedent for participation in the auction: the conditions precedent applicable to participation in capacity allocation auctions, as provided in Regulation (EU) 2017/459, for each of Amfitriti, Komotini DESFA/IGB, Stara Zagora, Negru Voda 1 / Kardam, Isaccea 1 / Orlivka, Causeni and Grebenyky IPs, and in accordance with the regulatory framework applicable at each point for network user access to the natural gas transmission systems of Greece, Bulgaria, Romania, the Republic of Moldova and Ukraine, as well as to the IGB. Auction Reserve Price: the sum of the Starting Reserve Prices applied by each of the above operators for the allocation of monthly capacity at Amfitriti, Komotini DESFA/IGB, Stara Zagora, Negru Voda 1 / Kardam, Isaccea 1 / Orlivka, Causeni and Grebenyky IPs for the special product Route 2, expressed in EURO/kWh/D/ Month (in the case of national currency, the exchange rate with the EURO published by the central bank of each country on the working day preceding the day on which the auction takes place is considered), reduced by 25% for BULGARTRANSGAZ and DESFA, 50% for TRANSGAZ and VESTMOLDTRANSGAZ and 46% for IGB and GTSOU on the relevant side of their IPs. Capacity to be auctioned: The minimum available firm capacity at any of the Interconnection Points to which the Route 2 special product relates, after the completion of the rolling monthly auction, in accordance with Article 13 of Regulation (EU) 2017/459 for the same Month considering competition constraints at respective IPs related to Route 1 and Route
  5. If according to the above the monthly capacity to be auctioned is 0, the auction for the allocation of capacity for the special product Route 2 during Month M shall be cancelled. Use of special capacity product Route 2 Submission of Daily Nominations/Re-nominations: Holders of the Route 2 special capacity product submit Daily Nominations and re-nominations at the Amfitriti Entry Point and at the Interconnection Points Komotini DESFA / IGB, Stara Zagora, Negru Voda 1 / Kardam, Isaceca 1 / Orlivka, Causeni and Grebenyky , concerning the special product Route 2 , in accordance with the provisions of Regulation (EU) 312/2014 and the regulatory framework applicable at each point. In addition, before the deadline for submitting Daily Nominations and before the deadline for submitting a renomination with which the holder of a Route 2 special capacity product wishes to change the quantity of natural gas transported on its behalf from Greece to Ukraine, within the framework of reservation of capacity of special capacity product Route 2, he shall send an email to the natural gas system operators DESFA, IGB, BULGARTRANSGAZ, TRANSGAZ, VESTMOLDTRANSGAZ, and Gas TSO of Ukraine LLC, specifying the quantity of natural gas that it wishes to be transported on its behalf from Greece to Ukraine, within the framework of the Route 2 special product capacity reservation. Calculation of Confirmed Quantity at Entry/Interconnection Points relating to the special Route 2 product: To calculate the Confirmed Quantity at the individual Entry/Interconnection Points on behalf of a Network User who is the holder of the special capacity product Route 2, in addition to the provisions of any Interconnection Agreements between the operators, the rule of the lesser quantity shall apply among the processed quantities calculated by each of the natural gas system operators, i.e. DESFA, IGB, BULGARTRANSGAZ, TRANSGAZ, VESTMOLDTRANSGAZ, and Gas TSO of Ukraine LLC, for the quantities nominated for transmission from Greece to Ukraine by the said Network User within the framework of reservation of the special product capacity Route
  6. Annex 3 - Description of Route 3 capacity product Arrangements that need to be adopted by the regulatory authorities of Greece (RAAEY), Bulgaria (EWRC), Romania (ANRE), the Republic of Moldova (ANRE) and Ukraine (NEURC) In addition to the provisions of Regulation (EU) 2017/459, a special capacity product is made available jointly by Bulgaria (BULGARTRANSGAZ), Romania (TRANSGAZ), the Republic of Moldova (VESTMOLDTRANSGAZ) and Ukraine (Gas TSO of Ukraine LLC), and the Operator of the Greece-Bulgaria interconnector (IGB) as follows: Specific capacity product characteristics Product name: Route 3 Product duration: Monthly product Product availability period: May 2026 to September 2026 (monthly products) Entry/Interconnection Points concerned: IGB entry KOMOTINI-TAP-IGB, Stara Zagora, Negru Voda 1 / Kardam, Isaccea 1 / Orlivka, Causeni, and Grebenyky Transport Capacity Direction: from Greece to Ukraine. Restrictions: holders of the special Route 3 product will not be able to use it to transport natural gas to and from Virtual Trading Points or to domestic delivery points in Greece, Bulgaria, Romania, and the Republic of Moldova. In order to acquire the special product Route 3, interested Network Users must participate in single monthly auction on Regional Booking Platform (RBP). Method of providing special capacity product Capacity allocation procedure: Auction. Through a single monthly product auction, equal capacity is allocated to the relevant interconnection points for the specific Month M in competition with Route 1 and Route 2 monthly capacity products of respective TSOs Auction execution platform: RBP (Regional Booking Platform) Auction algorithm: Uniform Price Algorithm as provided for in Article 18 of Regulation (EU) 2017/459 Auction execution time: 07:00 UTC (summer time) on the Wednesday following the third Monday of Month M-1 (Route Auction Day), for the allocation of Capacity for the immediately following Month M. A capacity purchase bid at the above Interconnection Points of the special monthly capacity product Route 3, within the framework of the aforementioned auction, is treated as follows: submission, withdrawal or modification from 07:00 UTC to 07:30 UTC (summer time). In the event that, at one or more of the above-mentioned Interconnection Points of the special product Route 3, the rolling auction of monthly capacity, as provided for in Article 13 of Regulation (EU) 2017/459, for Month M, has not been completed by the Route Auction Day, then the auction for the allocation of capacity at the above Interconnection Points of the special product Route 3 during Month M shall be cancelled. Conditions precedent for participation in the auction: the conditions precedent applicable to participation in capacity allocation auctions, as provided in Regulation (EU) 2017/459, for each of the IGB entry KOMOTINI-TAP-IGB , Stara Zagora, Negru Voda 1 / Kardam, Isaccеa 1 / Orlivka, Causeni and Grebenyky IPs, and in accordance with the regulatory framework applicable at each point for Network User access to the natural gas transmission systems of Bulgaria, Romania, the Republic of Moldova and Ukraine, as well as to the IGB. Auction Reserve Price: the sum of the Starting Reserve Prices applied by each of the above operators for the allocation of monthly capacity at the IGB entry KOMOTINITAP-IGB, Stara Zagora, Negru Voda 1 / Kardam, Isaccеa 1 / Orlovka, Kaushany and Grebenyky for the special product Route 3, expressed in EURO/kWh/D/ Month (in the case of national currency, the exchange rate with the EURO published by the central bank of each country on the working day preceding the day on which the auction takes place is considered), reduced by 25% for BULGARTRANSGAZ, 50% for TRANSGAZ and VESTMOLDTRANSGAZ and 46% for IGB and GTSOU on the relevant side of their IPs. Capacity to be auctioned: The minimum available firm capacity at any of the Interconnection Points to which the Route 3 special product relates, after the completion of the rolling monthly auction, in accordance with Article 13 of Regulation (EU) 2017/459 for the same Month considering competition constraints at respective IPs related to Route 1 and Route
  7. If according to the above the monthly capacity to be auctioned is 0, the auction for the allocation of capacity for the special product Route 3 during Month M shall be cancelled. Use of special capacity product Route 3 Submission of Daily Nominations/Re-nominations: Holders of the Route 3 special capacity product submit Daily Nominations and re-nominations at IGB entry KOMOTINI-TAP-IGB Interconnection Point , Stara Zagora, Negru Voda 1 / Kardam, Isaccea 1 / Orlivka, Causeni and Grebenyky , concerning the special product Route 3 , in accordance with the provisions of Regulation (EU) 312/2014 and the regulatory framework applicable at each point. In addition, before the deadline for submitting Daily Nominations and before the deadline for submitting a re-nomination with which the holder of a Route 3 special capacity product wishes to change the quantity of natural gas transported on its behalf from Greece to Ukraine, within the framework of reservation of capacity of special capacity product Route 3, he shall send an email to the natural gas system operators IGB, BULGARTRANSGAZ, TRANSGAZ, VESTMOLDTRANSGAZ, and Gas TSO of Ukraine LLC, specifying the quantity of natural gas that it wishes to be transported on its behalf from Greece to Ukraine, within the framework of the Route 3 special product capacity reservation. Calculation of Confirmed Quantity at Entry/Interconnection Points relating to the special Route 3 product: To calculate the Confirmed Quantity at the individual Entry/Interconnection Points on behalf of a Network User who is the holder of the special capacity product Route 3, in addition to the provisions of any Interconnection Agreements between the operators, the rule of the lesser quantity shall apply among the processed quantities calculated by each of the natural gas system operators, i.e. IGB, BULGARTRANSGAZ, TRANSGAZ, VESTMOLDTRANSGAZ, and Gas TSO of Ukraine LLC, for the quantities nominated for transmission from Greece to Ukraine by the said Network User within the framework of reservation of the special product capacity Route 3.

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