Raad van Bestuur
Postbus 41920, 1009 DC Amsterdam Bezoekadres
Spaklerweg 20 Amsterdam
Postadres
Postbus 41920 1009 DC Amsterdam
Telefoon +31 20 59 74111 Fax +31 20 56 27599
n.v. Nuon is statutair gevestigd in Amsterdam. K.v.K. 34108286. Banknummer: 56.25.32.250.
Directie Toezicht Energie T.a.v Maria de Kleijn Postbus 16326
2500 BH Den Haag
Contactpersoon Karen Lagendijk
020 562 7429
karen.lagendijk@nuon.com
Betreft
Your reference 102647
Datum
23 februari 2007
Dear Mrs. de Kleijn,
With this letter we would like to respond on behalf of N.V. Nuon (Nuon) to your request to comment on the draft recommendations from the DTe to the Ministry of Economic Affairs regarding possible routes to accelerate the development of TTF.
Development Dutch roundabout:
Nuon strongly believes in the development of the Dutch roundabout as the regional hub for the Northwest European gas market. Nuon actively contributes to this development by investing in new cross-border capacities between the Dutch, German and Belgian markets, gas storages in Epe- Germany and Zuidwending. Nuon is also actively trading on the TTF market. We consider the development of TTF into the liquid market place for this hub as a fundamental step in the development of the Dutch roundabout. We share your observations that with 90% of the Dutch gas currently not passing TTF, there are still major changes needed to elevate TTF to the desired end-state described in your draft report.
Need for urgent intervention:
The discussion on how liquidity on the TTF market can be stimulated is not complete without acknowledgement of the unique position of GasTerra on this market. As the DTe is indubitably well aware GasTerra combines the exclusive access to the low-cal NAM fields and flexibility, the legal obligation to aggregate all gas under the small fields policy as well as a historic long-term position in scarce resources like quality conversion and cross border capacities. GasTerra’s continued reluctance to offer significant low-cal volumes and adequate flexibility products on TTF makes it impossible for the marketplace to develop the desired maturity. By insisting on deliveries at the GOS (‘Gas Ontvangst Station ” ) GasTerra maintains market inefficiencies, leading to
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n.v. Nuon is statutair gevestigd in Amsterdam. K.v.K. 34108286. Banknummer: 56.25.32.250.
unnecessary additional costs that are currently passed on to the Dutch end-customers. In our view this continues to be the main obstacle to the development of the Dutch wholesale gas market and can not be resolved by individual market parties. Intervention from the regulatory bodies in this discussion is therefore an absolute pre-requisite.
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n.v. Nuon is statutair gevestigd in Amsterdam. K.v.K. 34108286. Banknummer: 56.25.32.250.
Package to accelerate TTF development:
We deem the most efficient measure to accelerate the development of the TTF market to be a top-down decision which would rule that with effect from e.g. January 1, 2008 all gas and flexibility are to be handed-over at the TTF. This could be achieved by means of a “ Ministeriële Regeling ” , applicable for all existing and future gas domestic contracts and should form a total ban on GOS hand-over. We fully realize that such intervention would have significant practical implications, but we believe these can be resolved by market parties without jeopardizing security of supply. In the Dutch power market a very similar decision was already made in the year 2001 and also the recent court ruling in Germany mentioned in your report illustrates that similar measures are taken in other countries without endangering security of supply.
The abovementioned measure is required on top of the already initiated expansion of cross-border capacities in the GTS Open Season and full socialization of quality conversion capacity.
We share your view that an alternative solution of allowing re-entry of the gas at the GOS approaches the problem the wrong way around.
We remain at your disposal to discuss the above in more detail with you and your colleagues.
Sincerely,
Øystein Loseth
Member of the N.V. Nuon Board
