Development of gas interconnection capacity between France and Spain
Eni Spa observations
Questions regarding possible transmission access scheme
Transmission scheme:
1. For the Eastern axis on the French side, what transportation scheme would you prefer? − Three-step entryexit system Spain < > TIGF < > GRTgaz − Entry-exit system with direct interconnection Enagas < > GRTgaz
Since the access to the TIGF zone through the Western axis is guaranteed, an entry-exit system with direct
interconnection Enagas < > GRTgaz on the East side is in our opinion preferable. Actually the lack of
competition on the GRTgaz South area is due, first of all, to the congestion on the entry points supplying this
area. A direct interconnection between Spain and GRTgaz could improve this situation with reference both to
possible diversification of the supply points and to prices.
2. If a mix of these two schemes was possible, implying a breakdown of capacity between the two options
(Spain < > TIGF and Enagas < > GRTgaz South), would you support it? (This option is not included in TSOs
studies so capacity could change slightly).
For the reason exposed above we would support this option.
3. If you consider that the breakdown of capacity between the two first solutions is appropriate to satisfy your
shipping needs, what would be the better “mix” (proportion)?
Spain < > TIGF and Enagas < > GRTgaz South 30%
Enagas < > GRTgaz 70 %
4. Would you prefer a different transportation scheme not specified in the consultation document? Which one?
Please explain in detail your proposal.
We do not have any other transportation scheme to propose.
Tariff structure:
5. In case of a direct interconnection between Enagas and GRTgaz South, what kind of tariff structure would
you prefer? Do you think that the tariff applicable to the Enagas < > GRTgaz direct interconnection should be
equal to the sum of the tariffs Spain < > TIGF + TIGF < > GRTgaz (i.e. Spain < > TIGF < > GRTgaz =
Enagas < > GRTgaz)?
As specified in answers to issue 10 and 13 below, tariffs on the two corridors will result from the relevant 0pen
Seasons.
6. Taking into account both TPA tariffs in Spain and in France, do you think that the overall price for the
Western and the Eastern axes should be equal?
The price, as shown in the following sections, should be in our opinion the results of the Open Season
Procedure described below.
Questions regarding the coordination of Open Seasons
7. In case the Western axis was not developed due to a lack of subscriptions during the open season 2013,
would you support to keep carrying out the 2015 open season and, possibly, develop the Eastern axis?
Yes, we would support it coherently with the results of another OS procedure.
8. Would you prefer to have the open seasons for the Western and Eastern axes carried out simultaneously?
What would be your favourite time schedule?
No, we think it is more appropriate to carry out the open seasons in two different phases: the OS for the
Eastern axis should be carried out just after the publication of the results of the Western axis OS.
Questions regarding tariff visibility
9. Tariff visibility: Considering limitations on tariff predictability, what level of tariff visibility would be
appropriate for you to take part in the open seasons? Do you consider that the current tariff visibility is
sufficient? How could it be improved? Please, explain your needs for price clarity
In our opinion it is appraisable that the TSOs the expected tariff level so that the shippers are able to estimate
their commitments in order to present their binding bids to the procedure described in point 10.
10. Binding request: What would be the right duration of the commitments by shippers (e.g. 10, 15, 20 years)
to ensure a balanced trade-off between economic feasibility of the project and shippers’ obligations? What
kind of financial guarantee should the shippers give to back their commitments?
In our opinion it is necessary that an OS procedure determines not only the market capacity needs but also the
availability by each interested stakeholder (sale operators, TSO, other sponsors) to support economically and
financially the necessary investments.
Thus, we think that shippers participating in the OS should be asked to clearly state the limits of their disposal
to support the investment by indicating in a binding offer:
1. the amount of capacity, the period and the duration of the relevant commitment for which they
undertake to enter into ship-or-pay contracts;
2. the price they offer for the requested capacity, as variation (>=) in respect to the expected tariff
indicated by the TSOs; these binding offers will be utilized just in case of congestion (see answer at
point 13).
The possible range of duration of the shippers’ commitments could be reasonably set, in our opinion, between
a minimum of a month and a maximum of 20 years.
11. Security of supply criteria: Should security of supply be taken into account when designing gas
interconnection infrastructures between France and Spain?
In our opinion, there is no doubt that, generally speaking, security of supply is a key issue for every
infrastructure investment.
Questions regarding capacity products and Open Seasons’ design
12. Capacity split: In your opinion, what share of the available capacity should be reserved for short term
contracts and for long term contracts? Should it be the same capacity, or the same percentage of capacity, at
each interconnection?
We think that the share between long term and short term contracts should not be determined in advance; the
most appropriate share is the one resulting from market needs deriving from the commitments stated by the
shippers participating in the OS as said in answer to issue 10..
13. Allocation rules: What methodology (pro-rata, auctions, lottery, etc.) would you prefer in order to
guarantee equal treatment and non discrimination? Dou you think it should be necessary to give priority to
some requests? If so, on which basis? (i.e. gas corridors, longest requested period, earliest starting date, etc.?
Should caps (percentage of the available capacity) on capacity assigned to the same company be established?
What cap? Should the same allocation rules be applied (a) in both corridors (b) in all interconnection points (c)
in both senses at each corridor?
The allocation rules must provide different methodology in case or absence of congestions.

In absence of congestion for every months to every shipper will be allocated the capacity equivalent in
terms of amount, duration and period with the request; the tariff paid will be equivalent to the
transportation tariff determined by the TSO (see point 9);

In case of congestion: we believe the most suitable and not discriminatory methodology is ad auction
methodology.
The capacities allocated each month of the 20 years reference period to each shipper result from the most
profitable combination of the shippers commitments as stated in the OS (see answer to issue 10 above) and
the corresponding monthly price is the so called System Marginal Price, i.e. the lowest price among those
offered by the shippers to whom capacity is allocated in that month.
Moreover we would welcome the same allocation rules in both senses at each corridor.
14. Allocation phases: In your opinion, how many phases of allocation is the optimum? Do you think it would
be preferable to have the possibility to renounce a) a part of the capacity allocated, b) the totality of the
capacity allocated, c) both?
Eni believes that the harmonisation of procedures at interconnection points both within and across each
country is an important step to favour an efficient and liquid gas market. Therefore we think it is necessary
that both the amount of the capacity allocated to each shipper on both sides and the starting date of their
availability would be the same. According to us it is also important that applicants are given the possibility to
renounce the allocated capacity just in case it is different from the requested one.
Additional comments
Please add any additional comment you would have on the development of interconnection capacity
between France and Spain.
San Donato Milanese, 15.12.2008