1. Madrid Forum 15 October 2014 Massimo Ricci Chairman

2. 2 General Remarks „Bridge to 2025“ Europex welcomes the effort made by ACER to develop further the regulatory landscape, which may help to further advance the EU energy market and define the role of ACER and the ENTSOs in the coming years. It is also acknowledged that input from the consultation phase is reflected in the “Bridge to 2025 “ conclusions paper.  It is welcomed that the implementation of existing instruments such as Network Codes and Guidelines is now identified as a core priority.  Security of Supply (SoS), Functioning Retail Market and Consumer Participation have also been correctly identified as important parts of a future EU energy market evolution.  Regarding SoS a further diversification of sources / routes will be essential to foster the role of gas in the future energy supply portfolio.  “Bridge to 2025” is a high level paper that is touching upon a number of relevant issues, but is in some parts also lacking detail regarding concrete proposals and solutions before the background of the long process and stakeholder involvement / studies undertaken. In the further process, consensus with stakeholders on market functioning and interpretation of statistical data should be ensured.

3. 3 Future role of ACER: ACER should in the future act as “watchdog” focusing on monitoring implementation and to effectively address, if member states / stakeholders fail to implement or execute Network Codes etc. The granting of new competencies (such as binding subsidiary instruments) requires an assessment: if additional arrangements are needed, to ensure checks and balance mechanisms to safeguard legality of regulatory acts and appropriate remedies. The development of a Governance Guideline by the Commission could facilitate future regulatory processes and legal certainty. Within such guideline, roles and responsibilities could be clearly allocated. Governance Matters

4. 4 ACER: Focus Areas Focus Areas for EU-wide coordination: Implementation of the Network Codes and Guidelines Security of Supply Gas to Power: development of proposals for a tailor-made framework for gas, that will be used for power generation, to keep G2P a viable and practical option for flexibility. Identify and address the issue of ancillary restraints / impediments to market access in different member states.

5. 5 Gas Target Model Review EUROPEX appreciates the balanced way forward indicated in the “Bridge to 2025” document. We have recommended not to come forward with a “one-size-fits-all” approach, and welcome the open process and regional market assessment. We are positive about a flexible approach for a new Gas Target Model. However, during the consultation phase, no concise „new“ or „amended“ target model criteria have been presented to stakeholders. The principal question whether or not to redesign market zones (to merge or to combine) by regulatory intervention has to be based on appropriate legal instruments, both on EU and national level. Given that market zones tend to develop where these are needed, the gas market currently needs specific answers to a declining demand, security of supply questions, etc. and not an academic discussion about market zone creation.

6. 6 Gas Target Model Review New (EU backed) instruments for Regulators at national or European level that empower to change market designs on large scale (market merger etc.) are currently not a priority. Reasons are inter alia:  Wholesale customers already have access to a number of (liquid) European market places and can ship gas to most locations in Europe through entry- / exit systems (thus meeting GTM criteria of access to wholesale markets).  The criteria (new GTM) used by NRA to assess market functioning shall be subject to consultation. Before any measure on market design is taken, an economic test should apply. Any measures should be based on EU instruments (guidelines), which ensure that regional particularities (e.g. emerging natural gas markets) can be taken into account by the NRAs.  In case that NRAs find shortcomings in market functioning, the full application of existing Network Codes etc. should be a clear priority; a situation where “NEW” measures are applied to markets where not even the 3rd Energy Package is implemented, is to be avoided.  Any measure aimed at re-shaping / altering market zones / design should only be taken after REMIT data is available, and analyses by ACER / NRA of such data supports the need for regulatory intervention.

7. Thank you!