GABE
A.S.B.L.
GABE
V.Z.W.
GROUPEMENT DES AUTOPRODUCTEURS GROEPERING VAN AUTOPRODUCENTEN
BELGES D'ELECTRICITE VAN ELEKTRICITEIT IN BELGIE
Ref.: C06-CUB-12-04
Object: ERGEG Consultation.
Brussels, June, the 20 th
, 2007.
U
G
The GABE fully supports ERGEG guidelines but thinks they require the hereafter additional rules.
(G14): The ISO principle is a minimum: either the management, the operation, the studies of the grid must be done by an independent company with a fully independent book-keeping.
(G11-G02-G07): All here-up activities of ISO must be done by its own human resources which must be sufficient (number and competence) and have new employment contract with ISO company.
(G06-G08-G15): Any investment has to be proposed by the ISO and approved by the Regulatory
Authority which imposes the return on investment percentage.
If another company conserves the property of the existing grid (either in the same group as the ISO or not), it may accept the return on investment or sell its grid.
For any new investment, this “historical owner” has no right to supervise, authorize, … the project. It only may accept to invest or refuse, implying the ISO becomes owner of the new investment. If the historical integrate company is not happy, it may sell its ISO subsidiary stakes.
(G08): The ISO management transfer to energy business company should not be authorized within a delay of some years, in order to avoid the risk of actions influenced by the promise of a future super job. But, recruitment of highly qualified people with career restrictions implies salaries higher as the market.
(G24): Additionally, ISO computers and data networks must be separate and ISO computer access must be restricted to ISO people.
But, rules must also impose that any data base, mathematical model, specific software… of either the grid or the electrical system of the zone must be given to the ISO, with legal prohibition any other company of the “historical integrated company” to conserve a copy.
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GABE / President : J-P Bécret. c/o Solvay. Rue de Ransbeek, 310. 1120 Bruxelles. Belgium.
Mail: jean-pierre.becret@solvay.com
Tel.: +32.22.64.26.76.
GABE / General Secretary: J. Mares. c/o Total Rafinaderij. Haven 447 - Scheldelaan, 16. 2030 Antwerpen. Belgium.
Mail: jan.mares@total.com
Tel.: +32.35.45.51.50.