- Gazprom violates the supply contract and the Brussels trilateral protocol. No explanation has been provided so far
- Fully in line with the contract, Naftogaz ordered 114 million cubic meters (mcm) for both 22 and 23 February. Gazprom only supplied 47 and 39 mcm on these dates, respectively
Naftogaz’ prepayment depends on Gazprom’s contract compliance
- As of 23 February 2015, Naftogaz’ remaining prepaid balance with Gazprom stands at 287 mcm
- Naftogaz will not be in a position to make an additional advance payment for supply of Russian gas until it receives assurance that Gazprom strictly complies with the contract
- If Russian gas supply is stopped, Ukraine will have to rely solely on EU imports to cover the gap
Supplies to the occupied territory (ATO zone) are illegal under the contract
- On 22 and 23 February additional 13 and 3 mcm, respectively, were allegedly supplied to the ATO zone through previously unused gas metering stations (GMS) Platove and Prokhorivka
- Because of the fighting, Naftogaz removed its personnel from these GMSs weeks ago. There are no authorized Naftogaz representatives to control and confirm gas delivery
- Technical agreement between the parties stipulates that any change of supply routes must be coordinated and approved by both parties
- Naftogaz has repeatedly informed Gazprom that unilateral change of supply routes has not been approved by Naftogaz
Standard procedure is crucial for ensuring smooth supply to the EU
- By the standard procedure, Gazprom indicates gas volumes to be delivered at specific exit points on the western border of Ukraine, depending on orders from EU clients
- Naftogaz, in turn, indicates gas volumes to be delivered at specific entry points on Ukraine’s eastern border. This procedure is essential to make possible the delivery of requested volumes to the EU border with no time lag (during the same day)
Uncontrolled GMSs were never used to supply transit gas
- Naftogaz warns of risks that Gazprom may claim it supplied transit volumes through uncontrolled GMSs in occupied regions
- This may result in potential gas supply disruptions to the EU, not because Ukraine fails to transit gas but because Gazprom stops supply
- Transit supplies through occupied GMSs would make no logistical sense, be economically inefficient and would endanger the security of flows because of the fighting