Talanza Energy Consulting

junio, 2020

Regions in risk of default with the new Storage Policy

Starting in July 2020, fuel distributors and traders will have to increase inventories until they reach an  average of 5 days of sales of gasoline and diesel and 1.5 days of sales of jet fuel, to comply with the Public Policy on Minimum Fuel Inventories (the Policy) published by the Ministry of Energy (SENER).

We conducted a regional analysis with public information, considering the Policy’s regionalization. Said analysis reveals the impossibility for some traders and distributors to comply with the requirements of the Policy, particularly those from regions with higher storage infrastructure deficit, like Central and West.


To help the continuity of supply and the logistics associated with the market in case of an emergency, the Policy establishes that at least 50% of the minimum inventories should be stored in terminals that usually supply traders or distributors by auto-tank (strategic reserve). The remaining minimum inventories could  be placed in any other terminal in the country, through the acquisition of tickets. A regional analysis of  existing inventories and demand shows the following findings:


Most Mexican actual physical inventory is  in the Gulf region, followed by the  Northwest and Central regions. Together,  these three areas concentrate more than  60% of the stock.

Gulf and Northwest regions concentrate  most of the gasoline and diesel inventory  while Central and Southeast regions  concentrate most of the jet fuel inventory.


From a demand point, the Central and West regions have the highest gasoline and diesel consumption.  Meanwhile, Central and Northeast regions group 84% of the jet fuel consumption. However, these  regions, with the highest fuel demand, do not show the uppermost level of inventories. CRE’s permits  database reports that the storage infrastructure in the Central and West regions is insufficient to  comply with the strategic reserve.

For Permit Holders in the Central region to  comply, on average, each existing terminal  would have to serve up to 86 service stations and an average of 73 in the West  region, which seems highly unlikely.

Therefore, without more terminals ready  to commence operations close to the  points of consumption, many traders and distributors will not be able to comply with the strategic reserve.


Each company, in compliance with its values, philosophy, and risk management, may consider various  strategies to deal with this situation. Here are a few:

  1. Survival of the fittest. Prices will raise, those who can pay more for a scarce service will get it.
  2. Prepare a legal strategy. Permit Holders may argue how circumstances beyond their control and responsibility prevent them from complying with part of the Policy.
  3. Pay the penalty when CRE imposes the fine. The latter may be challenged given the lack of infrastructure.


Tickets are leasing agreements for  stockholding in which the seller reserves an  amount of fuel on behalf of the buyer for a  fee. The ticket buyer has the option to take  delivery of physical stocks in times of crisis,  according to conditions specified in the  contract. The rationale behind stock tickets  is that a company holding stocks over its  obligation can offer them to cover another  company’s obligation.

Permit Holders can have 50% of their  capacity and inventories in terminals other  than where they usually purchase their  product, by acquiring tickets from a third  party.


PEMEX TRI (Petróleos Mexicanos subsidiary)  has excess capacity on several regions, and  therefore, will have a leading position in the  tickets market.

Considering that 85% of the storage terminals  belong to Pemex TRI, traders and distributors  without enough storage capacity may have to  purchase tickets from this state-owned  company.


  1. The guidelines for ticket emission are pending. The project should be subject to public consultation through the Comisión Nacional de Mejora Regulatoria.
  2. CRE presents delays in the analysis of  several storage projects and permit  requests, which enhance the scarcity of  infrastructure. This will lead to higher ticket prices.
  3. The Policy is subject to review at least every  five years, or at any time if SENER seeks an  adjustment. Still, it seems unlikely that  authorities will consider delaying the  entering into effect of this Policy any  further, given that Pemex TRI complies and  will be able to profit from other Permit  Holders’ needs.
  4. Permit Holders must define a regulatory  strategy to continue operations and avoid  penalties.

In Talanza, we advise Permit Holders and interested  firms in finding mechanisms for new oil storage  projects to commence operations as soon as  possible: obtaining permits, tariffs, and terms &  conditions.

Como firma internacional con presencia en Estados Unidos, México y Colombia, encaminamos empresas del sector energético hacia un correcto cumplimiento normativo y asesoramos gobiernos a diseñar e implementar regulaciones que impulsen la sostenibilidad en el largo plazo para dicha industria.
Resultado de la sinergia entre líderes Canadienses y Mexicanos, en Eminent nos especializamos en la cuantificación, control y reducción de emisiones de metano. Como pioneros en México en aplicar la tecnología OGI, potenciamos la sostenibilidad de la industria petrolera internacional.