ERGEG comment to KEMA study on Art. 3 and 7 Walter Boltz, Chairman ERGEG Gas Working Group 17th Madrid Forum 14 January 2010

General remarks ERGEG welcomes the KEMA study on methodologies for gas transmission network tariffs and gas balancing fees in Europe We share most of the analysis of the existing systems and the barriers identified We would like to point out that a high level of aggregation might have lead to a certain level of inaccuracy ERGEG has already developed recommendations for some of the barriers identified

Barriers resulting from differences in network access Barriers resulting from differences in network access and incompatible products have been addressed in ERGEG’s work on CAM & CMP Auctions as standard allocation mechanism Cross-border capacity products Provisions on short-term and long-term UIOLI Network access model according to Regulation (EC) 715/2009: decoupled entry-exit systems

Barriers resulting from differences in tariff structures Barriers to short-term trading resulting from high premium on short term capacity products has been addressed in ERGEG’s recommendations on CMP guidelines: Charges for firm capacities with contract periods of more than one day shall not be higher than the added daily charges during the contract period Issues to be addressed in the framework guideline on harmonized transmission tariff structures Pancaking of tariffs Premium on backhaul capacities Lack / Determination of locational charges (efficient signals for investment)

Barriers resulting from differences in regulation Barriers resulting from the lack of coordination in network planning to be mitigated by 10-year network development plans with a top-down view on the EU and regional gas grid Barriers resulting from regulatory treatment of new cross-border infrastructure In its Principles on Calculating Tariffs for Access to Gas Transmission Networks (E07-CBT-01-03) ERGEG has identified the following measures available to NRAs to foster investments in new cross-border infrastructure: A higher rate of return for a specified period of time A shorter depreciation schedule Long-term commitments to a certain tariff methodology ACER will facilitate the coordination between NRAs on a case by case basis for each new cross-border infrastructure project (considering the specific national regulatory framework)

ERGEG Work Programme 2010 The barriers identified by KEMA will serve as input for ERGEG’s further work In 2010, ERGEG will work on Framework guidelines on balancing Framework guidelines on harmonized transmission tariffs

Thank You!