0291 – NTS Licence SC27 – Balancing Arrangements Linepack Review Group 291 - June 2010

Action 002 – European Third package: Restrictions on Transporters offering ‘Storage Type’ services Article 15 of the Gas Directive which provides for legal separation, but only where an independent system operator has been appointed. Article 29 makes it clear that if the unbundling rules in Article 9 are complied with a combined transmission, LNG, storage and distribution operator is permitted. Article 33(3) also implies that a contract for linepack can be with someone other than a storage system operator (i.e. a transmission system operator).