CEEP’s submission – GAS Directive Consultation

CEEP’s submission – GAS Directive Consultation

Central Europe Energy Partners (hereinafter as „CEEP”) supports Commission’s Proposal regarding amendment of Directive 2009/73/EC (hereinafter as Gas Directive) aimed at ensuring application of this Directive to gas import infrastructure. We consider legislative initiative from the Commission to be timely and instrumental for both the better functioning of the common EU gas market and advancement towards the Energy Union. We share the Commission view that Impact Assesment (IA) is not needed in this case and it does not contradict the Better Regulation guidliness. In fact, amendment of the Gas Directive is the rectification of an identified legal loophole. The Proposal introduces substantially the same (and already existing) rules for pipelines to and from third countries as those applicable to pipelines within the territory of the European Union. Moreover, application of core principles of the regulatory framework set out in the Gas Directive in relation to third countries are already established practice (e.g. through the incorporation of said principles in international agreements between Member States and third countries concerning onshore pipelines to and from third countries). Therefore, we conclude that Commission Staff Working Document accompanying the legislative package on the internal market for electricity and gas provides a valid assessment of these key provisions. In this context it is worth reminding the EC position “that effective TSO unbundling may be undermined by third country companies active in both supply and network operation (…) [and] that EU is vulnerable to a strategy of third countries to dominate the EU markets not only in terms of supply but also by acquiring the networks[1]”. CEEP, as an organisation consisting of companies acting on the [...]

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