Security of Energy Supply

FETSA contribution with regard to the questions raised in the first meeting of the Security of Supply Working Party organized by the European Commission,for the 2007 Berlin Forum, 16 March 2007.

With regard to questions raised by the European Commission during this meeting, Fetsa has formulated the following responses:

Generally speaking we agree with the Commission's opinion, that "The EU's strategic oil stocks mechanism, effectively co-ordinated with stocks of other OECD countries through the IEA, has worked well and should be maintained."
Referring to the discussion during the first meeting, we fully agree with the statement, that "Security Stocks constitute the first defence line in case of a supply disruption."

Nevertheless we also agree that the legislation should be reviewed to meet the changed challenges of the energy world and to give a more stringent framework to the Member States.

In Particular, 

-          we do not think, that an increase in stock obligation from 90 to 120 days is necessary (whereas we would not argue against…), but we do think that an improvement in transparency and availability of stocks is of greater importance. This should be controlled by regular tests / audits !

-          we think, that the past has shown the necessity of having at least a minimum part of the stocks to be held as products; we think that this should be at least 50% of the stocks .This would be in line with the current situation within the Member States ( average 56% ), but should be made mandatory!

-          we also support the idea of reviewing the product categories. As an example, the growing importance of and the specific technical requirements for the storage of this product should be looked at ( proposal of Denmark).

-          we agree that Biofuels are a topic of special concern and will have a great impact, but we think that solutions/regulations should be left to member states.

-          we agree that also for Naphtha (as well as gas!) we should have a – probably separate – strategic stocks system.

-          we always have supported a strict separation of commercial and emergency stocks; where this is not possible, we support the idea of having a deduction in order to comply with the limited actual availability!

-          we agree, that the use of tickets might be a suitable instrument for specific situations (e.g. during the replacement of products due to spec changes); nevertheless we think that stocks held in form of tickets are of limited availability and therefore should be limited to e.g. 10%.

We do not have a distinct opinion on topics like reporting system, date of compliance, and the question of 90 days based on consumption or imports.

Questions and remarks please contact via  info@FETSA.org