Ref. Ares(2014)2592941 - 05/08/2014
Ref. Ares(2018)5389783 - 19/10/2018
GIE initial reaction to the Commission Communication on
European Energy Security Strategy
1 Who is GIE ?
Gas Infrastructure Europe (GIE) is an association representing the sole interest of the infrastructure
industry in the natural gas business such as Transmission System Operators, Storage System
Operators and LNG Terminal Operators. GIE has currently 69 members in 25 European countries.
One of the objectives of GIE is to voice the views of its members vis-à-vis the European Commission,
the regulators and other stakeholders. Its mission is to actively contribute to the construction of a
single, sustainable and competitive gas market in Europe underpinned by a stable and predictable
regulatory framework as well as by a sound investment climate.
2 GIE general comments
Affordable, reliable and sustainable energy are of crucial importance for a competitive Europe. As a
result of the tensions between Russia and Ukraine the European Council requested the European
Commission to present a European Energy Security Strategy. GIE welcomes the effort by the
Commission to depoliticise the energy debate and providing a framework of short and medium term
actions to increase energy security in the EU.
A well-functioning internal energy market is the best guarantee for energy security. The EU should
therefore concentrate its efforts to enhance the integration of Europe’s energy networks. Over the
past decades gas infrastructure operators have invested to create an efficient and reliable energy
system. Since the gas supply crisis of 2009, additional investments have been carried to enhance the
interconnection of the EU’s gas market. Further ‘missing links’ have been put forward by
infrastructure operators as priority projects under the new TEN-E Guidelines.
GIE would like to highlight some specific comments on various elements of the Communication of
2.1 Immediate actions to increase the EU's capacity to overcome a major
disruption during the winter 2014/2015
GIE and its member companies support measures taken at the EU, regional and national level to
enhance gas market integration and advance the security of gas supply. In this regard GIE
contributes to activities of the Gas Coordination Group (GCG) by sharing its experience and up-to-
date information on the functioning of gas infrastructure in the EU, including transmission systems,
LNG terminals and storage facilities. The transparency platforms and related databases1 which allow
actual monitoring of natural gas flows, storage inventories and utilisation of LNG terminals
throughout the EU in an effective and user-friendly manner are examples of this.
1 The platforms and databases on transmission, UGS and LNG infrastructure is available at: http://www.gie.eu/index.php/maps-data
GIE is ready to continue with supporting the European Commission and the EU member states,
including at the upcoming GCG meetings and with the proposed energy security stress tests.
GIE and its members offer to the EC their assistance in running stress tests and risk assessments and
will continue providing information on transmission network, natural gas storage inventories and
LNG regasification capacities in the EU.
2.2 Review of the SoS Regulation 994/2010
GIE supports the Commission initiatives to evaluate the existing regulatory framework regarding
supply security taking into account the strategic importance of gas storages. However GIE would like
to underline the importance of ensuring the effective implementation of key elements of the
existing Regulation 994/2010 before considering additional rules and regulations. Such a review
The necessity of a review of the supply standard and its potential extension;
Guidance on acceptable means of fulfilling the supply standard (for example are only hub-
based supply contracts sufficient in case of an import disruption) and recognizing the
importance of storages and sufficient storage levels.
GIE is ready to contribute to the review of the existing provisions of the Security of Gas Supply
Regulation which the Commission is scheduled to finalise before the end of 2014.
2.3 Building a well-functioning and fully integrated internal market
In recent years GIE members have invested substantially in cross-border interconnections, reverse
flow projects, storage projects and LNG-regasification projects. The network codes which are
currently being implemented will further enhance the integration of the gas markets. All these
measures contribute towards significant progress in terms of gas market integration and security of
supply in many parts of the EU. For example, gas can now also be transported from West to East,
and from South to North. Nevertheless, there are still pending reverse flow projects which can
further enhance Europe’s supply security and therefore deserve further support to ensure timely
and efficient implementation.
And further actions are needed to ensure all EU member states can benefit from the internal gas
market. Whereas convergence among different areas has increased, certain regions - in particular
those which are completely dependent on the single gas supplier (Baltic states and Finland) or lack
supply diversification are exposed to supply disruptions via their main import routes (e.g. countries
in the CEE and SEE region).
GIE believes that investments in gas infrastructure should primarily be market-based. However we
acknowledge that some investments which are not fully supported by the market might still be
needed due to externalities (e.g. security of supply, solidarity, etc.). They would require targeted
support, such support should however not be to the detriment of existing infrastructure and market
based projects. Therefore, GIE welcomes actions currently taken by the European Commission and
relevant authorities in the member states with regards to TEN-E and CEF Regulations. Timely
implementation of both legal acts is of primary importance, as they can greatly contribute towards
streamlining administrative and regulatory procedures at the pre-investment stage and incentivising
gas infrastructure projects. This, as a result, can lead towards accelerated construction of key gas
investments with the highest potential for the gas market in the EU. Finally, the need for highly
capital intensive new gas infrastructure as mentioned by the European Commission while
simultaneously considering displacing gas by other sources increases the risks for infrastructure
operators and could be to the detriment of new investments.
GIE believes that gas infrastructure in the EU is now more resilient than in 2009 and better capable
to address security of supply concerns. There are however still important infrastructure projects to
be implemented to strengthen SoS, enhance diversification and integrate gas markets in the EU. An
appropriate investment climate and incentives are needed as well as the full implementation of the
TEN-E and SoS regulation.
GIE is available for discussions within GCG and strongly supports a dialogue between the related
GIE supports the Commission’s proposal to review the existing regulatory framework for security of
GIE welcomes actions by the European Commission which recognize the strategic importance of gas
storages and would like to highlight the important role of LNG terminals in enhancing supply
diversification and security of supply.
Fully integrated European natural gas networks will provide aligned price signals, necessary flexibility
and proper solutions to the market needs from any supply direction and/or source in any market
In the short term GIE and its members offer to the EC their assistance in running stress tests and risk
assessments and will continue providing information on natural gas storage inventories and LNG
regasification capacities in the EU.
The policies of energy security and the transition towards a low carbon economy should provide a
level playing field to all energy sources to compete in the internal market.