On the Draft Regulation on Gas Supply Security

We fully support the Commission’s goal of ensuring that all Member States devise and implement appropriate gas supply security policies. The draft Regulation contains many valuable provisions and certainly goes in the right direction. Though this note focuses on what we think is wrong with the text we have received, it is meant to be constructive advice to help the Commission achieve its goals. We have three main points and recommendations: There are two conflicting approaches in the draft Regulation: (1) a supply security rule that all member states have to comply with irrespective of their national situation (ensuring gas supplies to ‘protected customers’ for 60 days in N-1 situation); (2) ‘national preventive action plans’ based on an assessment of the risks faced by each member state. We think that the Commission should abandon the ‘N-1 for 60 days’ rule; it should mandate independently carried out and peer-reviewed national risk assessments, on the basis of which the Commission would negotiate legally binding national gas security action plans. The notion of ‘ensuring gas supplies to protected customers’ is flawed. The Commission should abandon it in favour of ‘meeting contracted final energy demand in case of gas supply disruption’. The formula for calculating the ‘N-1’ indicator is flawed. If the Commission wants to retain this tool (which we advise it not to do) the formula should be revised.