Moldovagaz has never paid for transportation of additional volumes of gas to Transnistrian region consumers at the expense of right-bank Dniester consumers.
This is stated in a commentary disseminated by the company on the expenses for transportation of natural gas to Moldovan consumers. These amounts were paid by Tiraspoltransgas. It is underlined that starting from December 2021, Tiraspoltransgas pays to Moldovagaz a part of expenses related to reserving additional capacities for transportation of natural gas to Ukrainian territory, which fall on the consumers on the left bank of Dniester River, monthly by the 14th day of the month following the month of consumption. For its part, Moldovagaz sends to Gazprom the funds received from Tiraspoltransgas by the 20th day of the month following the month of consumption. These explanations were made by Moldovagaz following an open letter from the Unity and Welfare Committee, addressed to the Prime Minister of Moldova, requesting public information on certain issues related to natural gas transportation costs for Moldovan consumers. Moldovagaz stated that, under the contract N1GM-07-11 of 29.12.2006, concluded between Moldovagaz and Gazprom, the natural gas is transported to Moldova on DAP (INCOTERMS 2010) conditions, the point of transmission being the Ukrainian-Moldovan border. Accordingly, costs associated with transportation of natural gas through the territory of Ukraine are included in the purchase price. At the time of signing or extension of the term, the N1GM contract set the approximate volumes of natural gas to be delivered to Moldova during the contract period. Based on the specific nature of natural gas supply contracts, it is practically impossible to determine exactly the volumes required in the future at the time of signing them, as this aspect is conditioned by a number of variable factors (economic, technical, climatic, etc.). According to the company, although the volumes requested by Moldovagaz and fixed in the contract at the time of signing/renewal were each time based on certain statistics accumulated over the years, based on the consumption structure, consumer profile, etc., in reality these volumes had to be specified and adjusted most of the time, usually monthly (in some cases even more often), taking into account the specific conditions of activity in a certain period. In this sense, the N1GM contract provides for certain adjustment procedures to avoid penalties for not taking or exceeding the contracted volumes. The methodology for determining the costs of natural gas transportation through Ukraine in the structure of the purchase price that existed prior to January 1, 2020 was relatively stable and was not affected by the timing of the application for volume adjustment. That is, regardless of whether the request for volume adjustment was submitted 3 months, 1 month or 10 days in advance, the transportation costs of sold volumes were the same and did not affect the purchase price. Since January 1, 2020 access to the points of connection of the Ukrainian gas transportation system is carried out in accordance with the requirements of the Grid Codes of Ukraine, carried over from the Grid Codes of the European Union. According to the Grid Codes, in order to access transmission services, system users are obliged to reserve the capacity of connection points to the transmission system on the basis of annual, quarterly, monthly, daily and intraday capacity auctions. At the time of signing Addendum No.19 dated October 29, 2021 to 1GM contract, based on the negotiations held on October 27-29, 2021 between representatives of the Moldovan side and Gazprom, it was impossible to precisely determine the costs of natural gas transportation through Ukraine for the next 5 years, which were to be incurred by Gazprom and included in the purchase price. Thus, Addendum No.19 dated October 29, 2021 to the 1GM contract sets methodology of determining expenses for transportation of additional volumes to the annual reserve capacity of 5.7 million m3/day (guaranteed), based on monthly auctions for reservation of daily capacities. Moldovagaz stresses that this mechanism is not contrary to international trade rules (DAP, INCOTERMS 2010) and complies with European directives in the field of natural gas, because according to Ukrainian legislation and decisions of Ukrainian regulator in the field of natural gas, Gazprom pays expenses for transportation of natural gas through Ukraine at the moment of reservation of daily capacity, requested by Moldovagaz. Since for objective reasons these costs could not be included in the purchase price at the time of contract conclusion, Addendum No. 19 dated October 29, 2021 to the 1GM contract provided the way of their reimbursement. Between November 2021 and September 2022, $12.373 million was paid to Gazprom, including: $7.26 million - from Moldovagaz for transportation of additional volumes of gas supplied to consumers on the right bank of the Dniester, and $5.113 million - from Tiraspoltransgas for transportation of additional volumes of gas supplied to consumers on the left bank of the Dniester. At the same time it is stressed that Moldovagaz has never paid for transportation of additional volumes of gas to consumers on the left bank of Dniester River at the expense of payments of consumers on the right bank of Dniester River. Starting from December 2021, Tiraspoltransgas pays to Moldovagaz a part of expenses related to reservation of additional gas transportation capacities on the territory of Ukraine, which fall on consumers on the left bank of Dniester River, monthly, by the 14th day of the month following the month of consumption. //04.11.2022 – InfoMarket
