EURELECTRIC General Comments

1
EURELECTRIC General Comments

• Some differences exist between gas and
  electricity
• But No reason not to open markets in parallel
• Ability to store gas should make market opening
  easier
• Papers list different country situations but do
  not make firm recommendations on way forward
• EURELECTRIC supports Gas Lake concept - one stop
  shop needed, with transparent and
  non-discriminatory access arrangements

2
Comments on GTE Position Papers

• Some harmonisation is needed to make the market
  work compatible (but not necessarily identical)
  national arrangements are required
• Not always clear that GTE and Eurogas interests
  separate
• Gas Quality Need for proactive approach to
  harmonisation
• No justification for contract path solutions
• If shippers to balance demand/supply tools
  needed!
• Strategic storage If not GTE, who is
  responsible?
• Traffic light system insufficient
  Confidentiality - but for whom?

3
Balancing and Storage

• Market players should have access to storage
• GTE report does not reflect shippers viewpoint
• Based on insufficient country information
• Little information on methodology, vague on
  storage
• No firm recommendations made
• Clear need for harmonisation, but GTE insistence
  on differences
• Imbalance penalties should be cost-reflective,
  not punitive

4
Available Capacity Congestion Management

• Advantages of gas-storage forgotten
• - Storage reduces temporary consequences of
  interruption in many long distance transmission
  pipelines
• - Storage gives better use of market
  opportunities
• - Storage and line-pack make flow in transmission
  lines less dependent on actual consumer demand.
• Need for cross-border regulation
• Unconditional availability of contractual path is
  an inefficient use of transmission capacity

5
Available Capacity Congestion Management

• Lake model representative of mature markets with
  traded volume in excess of physical exchange
• Publication of detailed capacity information (as
  a function of time) is essential for
  non-discriminatory use of market opportunities
  and transparent allocation of scarce capacity
• Use-it-or-lose-it principle and secondary market
  mechanisms are necessary
• Auctions could be an efficient alternative for
  congestion management

6
Transmission tarification

• Tariffs should be published and cost-reflective,
  with separate identification of services
• EURELECTRIC does not support contract path type
  charging systems - these are inflexible and
  inhibit trade
• If distance-related system introduced, minimum
  requirement must be introduction of a cap
• Short-term contracts must be possible
• Newcomers must have right to use Swaps
• Transit tariffs should not be cheaper than
  transport tariffs - distortion of market

7
Interoperability

• Gas Quality Harmonisation important, EURELECTRIC
  welcomes Commission study
• Edig_at_s work valuable, but further work needed to
  make information internet-compatible
• Capacity issues not dealt with sufficiently
• Existing rules may hinder implementation of
  interconnection measures
• EURELECTRIC Welcomes Gas Industry Standard Board
• Financing (?) - more details needed