I am responding on behalf of Centrica to the draft decision document on this subject.
Centrica fully supports the initiative by NMa/ DTe on the provision of flexibility services in the Netherlands, which are essential to a properly functioning wholesale market. We believe the current proposals represent a sensible approach to developing additional sources of flexibility and thus facilitating competition.
However, while the proposals are welcome, they focus on the types and prices of flexibility services to be provided in a market where Gasunie is currently dominant. In the absence of competition in the market for flexibility services, new entrants such as Oxxio have had to enter into full-service agreements with Gasunie, on an exclusive basis.
Other parties wishing to sell gas to Oxxio and others therefore have to be able to offer flexibility services together with quality conversion services. Companies like Oxxio need to have a realistic alternative to a bundled L gas supply from Gasunie, and gas flexibility services alone will not address Gasunie's dominance in the L gas market, as identified by Frontier Economics.
Regards
David Johnson
David Johnson
Regulatory Manager, Europe Centrica plc
3 The Square Stockley Park Uxbridge UB11 1BN
