Wholesale Market Integration SEE Wholesale Market Opening: Electricity Industry Views

Transcription

1 15th Athens Forum Wholesale Market Integration SEE Wholesale Market Opening: Electricity Industry Views Tomaz Lajovic Chairman of the Ad-hoc Group South East Europe Athens, 26 November 2009

2 SEE Market Opening Study: EURELECTRIC feedback (1) Wholesale market reform will be a fundamental solution of the main barriers to the market opening and investments climate attractiveness. Energy Community plays a key role in the harmonisation of the market rules in SEE thus creating long term regulatory predictability and visibility; however Governments and Regulators commitment is essential. Market design should provide for incentives to remunerate new entrants and appropriately address the possibility of the existing generation power plants (not committed to EU emission standards) exercising dumping on the market. 2

3 SEE Market Opening Study: EURELECTRIC feedback (2) Harmonisation of market rules and procedures, transparency, definition of NTC (for the latter, coordination among TSOs, including capacity calculation) have to be promoted and enforced. Coexistence of the region-wide implicit capacity allocations with the explicit capacity allocations through the CAO project has to be ensured in order to guarantee the two projects are not undermining but mutually supporting each other. Despite past market parties requests to the Athens Forum, the Report does not addresses the CO 2 perspective for the region, fundamental to create a stable investment climate. 3

4 Pre-requisites for SEE Market Opening: Completing the Liberalisation process Political commitment to market liberalisation both in legislation and in implementation of best practices Credible and stable regulatory framework to attract investors Efficient market infrastructure to enhance liquidity and trade End of price regulation (wholesale and retail) to give correct price signals and stimulate competition Abolishment of import/export and other transaction based fees Non-discriminatory Third Party Access Adequate transparency and customer information 4

5 Price Regulation in SEE Direct ways: Regulation of price for end consumers (to end by 2015) Regulation of producers sale price Indirect ways: Export/import restrictions to influence a national merit order Decrease of ATC offered by TSO lowering the energy price in the local market Various transaction-based grid fees applied to wholesale transactions Administrative measures impairing market access Consequences: no liquidity increase, no price convergence No Market Integration! 5

6 Regulation 1228/2003 forbids improper transaction based charges. Preamble, point 13, states that import/export charges in addition to appropriate use of system charges are to be avoided Article 1 calls for harmonised principles on cross-border charges Article 4, paragraph 1, requires network charges reflecting actual costs incurred Article 4, paragraph 4, forbids differentiation between internal and crossborder transactions Article 4, paragraph 5, forbids charges for transits Article 6, paragraph 1, allows only non-discriminatory market based congestion management solutions Charges for cross-border transactions can only be derived from market based capacity allocation mechanism and scheduling. 6

7 Amended Congestion Management Guidelines provide detailed provisions. Point 1.2 forbids restrictions to access to the network if there is no congestion Point 2.9 forbids any kind of reserve prices in capacity allocation Any kind of monetary pre-condition for execution of cross-border transaction applicable in the cases of no congestion is forbidden. 7

8 Transaction-based grid fees have to be abolished! Country 1 Trader A Trader B 10 MWh 10 MWh Country 2 Grid fees charged for 10 MWh injected + 10 MWh extracted Trader C Trader D Flow = 0 MW Nominations for the same hour Transaction-based grid fees are not justified as they have no direct influence on the flows, while reasonable scheduling fees might be acceptable. Regulation 1228/2003, Article 4/1 8

9 Fees Applied to Wholesale Transactions in SEE: Some examples (1) Bulgaria: Export/import fees 8,97 /MWh Comment: These cross-border fees are transaction-based and applied to internal metered injections/withdrawals as well Greece: Import injection charges 2,5% (Athens Forum has been addressed a letter by the Greek regulator justifying these fees) Comment: These cross-border charges are transaction-based and applied to internal injections scheduled via Greek pool as well; however a specific problem with these charges is that they are applied retroactively in the form of pro-rata decrease of the volumes paid for resulting from the Greek pool s day-ahead matching DISCLAIMER: The figures above may not be entirely accurate and we apologise for any inconsistency; however, based on a thorough scrutiny of the legal texts, we believe this is the best information market participants can gather from existing provisions. 9

10 Fees Applied to Wholesale Transactions in SEE: Some examples (2) Romania: Export/import fees 0,71 /MWh 6,29 /MWh Comment: These cross-border fees are transaction-based and applied to internal metered physical injections/withdrawals as well Bosnia: Export fees 4,65 /MWh Comment: These cross-border fees are transaction-based and applied to internal metered physical withdrawals as well DISCLAIMER: The figures above may not be entirely accurate and we apologise for any inconsistency; however, based on a thorough scrutiny of the legal texts, we believe this is the best information market participants can gather from existing provisions. Any kind of grid fee has to be charged only for actual metered flows, as wholesale transactions have no direct effect on the system. Abovementioned practices limit market integration potential. 10

11 Other relevant issues in SEE: some conclusions Legal reliability and long term regulatory visibility (including CO 2 treatment and ETS Directive phase-in) required to guarantee security of investments Poor transparency of market rules and complexity of procedures (including some licensing processes) Interconnection capacity still low: need to maximise existing and incentivise new grid investments Powers and independence of regulatory authorities still insufficient CAO is positive initiative but limited progress: participation of BG and SR is crucial for success Wholesale liquidity very limited: need to establish harmonised day-ahead capacity allocation and scheduling processes, facilitate power exchanges Progress in implementation of the EU acquis can be improved: more enforcement needed