German energy regulator Bnetza has until early January to reach and publish a draft decision on the 55bn m³/yr Nord Stream 2 project developer's application to act as the line's operator, with a final decision not likely until summer 2022.
The developer applied for certification from Bnetza in June, but the regulator has been reviewing submitted documentation to identify whether the application was complete.
Bnetza determined on 8 September that all necessary documents had been submitted for inspection, and said it has four months from that date to produce a draft decision and submit it to the European Commission. The commission then has two months to give Bnetza its opinion, but can request views from other parties, which could extend its assessment by a further two months.
Bnetza is obliged to adopt a final decision within two months of its draft decision, but can extend this period to align with the commission's inquiry.
This suggests that Bnetza may not have to make its final decision until early May at the latest, but could decide earlier.
Operating a gas pipeline without certification is not compliant with German energy rules, Bnetza said, which would keep the line from starting up until a positive decision is finalised. The regulator will only certify the operator if it can prove it is "organised in accordance with respective unbundling requirements", Bnetza said.
This could prevent Russian state-controlled Gazprom from shipping any gas through the line this year, even though the project is likely to be physically ready to start up earlier.
The pipeline's remaining uncompleted string — one of two parallel lines — was finished on 10 September, after its developer connected the underwater German and Danish sections. But pre-commissioning activities on the string — including filling it with operational gas — will still need to be carried out.
The developer will need a third party to "verify the safety and technical integrity" of the project and to issue a "certificate of compliance", before Denmark's energy agency approves the line's start-up in Danish waters.
And the pipeline will have to pass technical tests before commissioning, in accordance with the relevant safety regulations under the construction and operating permit issued by the Stralsund mining authority, Bnetza said.
German federal state Mecklenburg-Vorpommern's energy ministry is responsible for final approval of the line's start-up, Bnetza said.
Gazprom previously said that it could ship 5.6bn m³ along the line this year, but this is unlikely unless Bnetza and the commission each make an early decision. Regardless, Gazprom may have little need to use the pipeline over the rest of this year. It has already outlined its export plans for 2021, suggesting particularly slow sales to European markets in September-December.
Gazprom could meet these needs using its already-active export routes, including Nord Stream 1, the Yamal-Europe pipeline route and transit through Ukraine. But the firm may have to book significantly more capacity along Yamal-Europe or through Ukraine, especially if it seeks to lift sales early next year.
