電力自由化EU編概略

 日本では電力事業に対しての自由化の動きは「電力自由化」といわれるが、欧米では、DEREGULATION(規制緩和)という表現がなされ、ニュアンス的には、相当、積極的なイメージがある。その中にあって、EUの電力自由化路線は、1999年2月以降、急速に実行に移されている。ここでの引用はドイツの電力自由化に対する考え方がまとめてある。

By Sabine Froning, Deputy Director of the Brussels Office of the VDEW (Association of German Electricity Supply Companies), Frankfurt am Main, for the journal BWK issue 7/8 1998

Information material in english


top of side  Electricity Market Europe: Limitless Competition(制限無き競争原理の導入)

Since the end of the eighties, it was clear to the European Commission that a domestic European market leading to more growth, competitiveness and jobs would out of necessity also include deregulation of the energy markets. Due to the sheer magnitude of the undertaking and the widely different structures and mentalities in European electricity supply systems, however, the Single Market Directive Electricity could first be ratified by the Energy Council of Ministers of the EU on December 20, 1996 following years of controversial discussions and tough negotiations. One could be forgiven for thinking: the end of a never-ending story. Or was it just the beginning of the most thrilling chapter?

Member nations have until February 19, 1999 to incorporate the Directive into national legislation. Exceptions: Greece, Ireland and Belgium, who have two years, respectively one year longer due to special infrastructural/political circumstances. Being merely a framework with few key stipulations, the Directive is in fact a system of joint basic rules allowing the individual member nations considerable scope for their interpretation.


top of side  Gradual Opening of the Market (EU内では2003年までに3分の1国が自由化に突入、1999年末までにマーケットの60%は自由化移行)

This applies particularly to the degree of market opening. Minimum quotas only are foreseen: around 25% in the first year, 28% in the year 2000 and 33% in the year 2003, i.e. one third of the EU-wide market. Further deregulation is planned for 2006, insofar as the Council of Ministers reaches agreement in time. These guidelines do not preclude further-reaching deregulation at national level. Most member nations will undoubtedly go beyond the minimum measures. In a paper on the status of deregulation of the energy markets published at the beginning of 1998, the European Commission assumed that, even with conservative estimates, at least 60% of the EU energy market will be deregulated by the end of 1999.


top of side  North-South Incline in Competition (自由化が進む北、緩やかな移行の南)

With the ratification of the Energy Law Amendment at the end of April 1998, Germany opened its market completely for all end users and supply companies. But what is a change of era for the German electricity industry, is already everyday for Scandinavia. In Sweden, for example, all consumers have been entitled to participate since January 01, 1996, in Finland since January 1, 1997. Outside the EU, but intimately linked with power supply in Europe, Norway radically deregulated its energy supply in 1991 and since January 1, 1997 all customers can change their supplier at will and free of charge.

Although Great Britain, where deregulation began in 1989 with the division of the vertically integrated Central Electricity Generating Board (CEGB) and has now opened up around 42% of the market, has shelved but not cancelled full deregulation originally planned by early this year, customers will still enjoy freedom of choice by the end of the year. In The Netherlands initially 32% of consumers belong the the "chosen few" as of 1998, by 2008 competition will be extended to all levels down to the smallest consumer. By admitting industrial customers with annual consumption of 100 GWh upwards and all distribution companies, Denmark will achieve deregulation of almost 90%.

Therefore the - traditionally more liberal - northern countries have a head start, whereas with the southern Europeans the concept of centralization and existential public supply remain entrenched and allow only a gradual liberation of the electricity market along the lines of the Directive.


top of side  Cultural Upheaval in Spain

Although exceptions do exist here too: in Spain a new law became effective at the start of 1998 which almost takes on the appearance of a cultural change. Although also opting for a step-by-step opening of their market, the Spaniards are substantially exceeding European requirements in terms of both time and volumes. In future a pool trading system, similar to Great Britain, will operate where the market price for electricity on the following day is determined on the basis of hourly bids by generators and customers. The tradition of the "Service Public", once strongly dictated by central planning, has been thrown overboard and Spain is now backing competition and free enterprise. All that remains is a supply guarantee for each inhabitant, as contained in the majority of national drafts - Germany not excepted.


top of side  Priority of Service Public in France

Germany's neighbour France is currently at odds with its destiny. Over the years, subsequent French governments did all in their power to keep the effects of the European Directive to a minimum for Electricit de France (EDF). Together with Italy and Belgium the country is now among the late comers on the deregulation front. The Government first plans to put forward a draft for implementation of the Single Market Directive in fall. Market opening will certainly be oriented to the minimum stipulations of the Directive and the state will under no circumstances let go of the entrepreneurial reins. Upon taking office in July 1998, the new EDF President France Roussely was given clear directions, whereby public service and social solidarity - especially in pricing policy - still take a front seat. Scope for action in competition is limited: long-term state energy planning continues, the way to other business sectors such as the telecommunications market, seems to be blocked. EDF is to concentrate on its core business.


top of side  EDF Pursues Expansion Overseas(国外供給拡大を続けるフランス国営電力会社)

In contrast, the Government light heartedly allows the concern to further expand its already extensive foreign activities in the run-up to deregulation. The monolith EDF, already in the past the largest European electricity exporter by far with an export surplus of 69.1 TWh in 1996, can only lose customers due to the former area-wide coverage in its own country. Whereas foreign investment totalled FF 800 mill. in 1996, almost FF 5 bill. (000 mill.) is spent today on international activities and this level is to be maintained. Close connections exist to Spain's Endesa, to Austria due to the recent acquisition of Energie Steiermark Holding, to Switzerland, Sweden, Italy and Portugal. Cooperation with other European utilities are possible, perhaps in the course of a still to be defined capital opening. Privatization, in the words of the responsible secretary of state in the Ministry of Industry, Christian Pierret, is out of the question.


top of side  Privatization in The Netherlands(民営化展開推進のオランダ)

Quite a different picture in The Netherlands where the electricity branch is entering its first round of privatization. The big five distribution companies are in the starting blocks of a program to sell traditional shares of communities and provinces to private investors. Here, like elsewhere, the reasons are the strengthening of the financial basis, the bundling of forces by the formation of (cross-border) alliances and the utilization of market experience of new partners. In the face of competition from RWE Energie and Preussen Elektra from Germany, the EDF from France and the American concern Enron, which this year has opened not only offices in Frankfurt but in Amsterdam too, the Dutch utilities feel small and thus obliged to "rearm". As yet virtually inactive abroad, links with international players like Enron or Shell are just what the doctor ordered - under the motto "If you can't beat 'em, join 'em".

The Dutch seem to have found favor with the prospect of competition relatively quickly. From the start of 1999, a spot market at an electricity exchange in Amsterdam with cross-border trading is foreseen. Several German companies and Belgium's Electrabel have already announced interest. In the course of the year futures trading is also planned. Trade with natural gas will also be a component in the long term. The exchange will be structured similar to the Scandinavian model NordPool, were more than 18% of the entire electricity consumption is traded and the spot market price is also indicator for the pricing configuration in bilateral contracts.


top of side  International Electricity Trade:Market Opening with Hurdles (国際間電力取引融通も軌道の緒に)

As important as is the participation of foreign companies on the Amsterdam Power Exchange for its liquidity, as open are still the many questions. They include dealing with the reciprocity clause of individual governments effective until 2006. In principle, imports from abroad could be prevented when domestic providers are not offered identical chances of market participation in the exporting country. Because the German market has a central position in Europe and will be more open in the foreseeable future than the markets of our neighbours France, Belgium, The Netherlands and Austria, the reciprocity clause is a key element here to guarantee a smooth transition in international competition. The reverse side of the reciprocity coin: distributors enjoying full market access in Germany, will possibly be only able to buy abroad there where distributors are also licensed. Some interesting variations exist here. In Switzerland, for example, the access authorization of distributors increases in percentage with the individual deregulation stages.


top of side  Acid Test Electricity Transition

A further stumbling block for international trade on spot markets could be the calculation of transition charges, handled differently from country to country. To date, there are no standard rules for cross-border transitions, only the pertinent national remuneration systems apply according to the proviso of the selected network access system.

In member nations where competition has prevailed for some time, i.e. Scandinavia and Great Britain, the system of "regulated network access" has asserted itself: Transition tariffs are standardized and published. Transactions are streamlined by so-called "postage stamp tariffs", which are calculated independent of transition distance. Nonetheless, the division into "connection zones" can well result in a geographical differentiation, to stimulate a more even balance between generation and distribution. Network tariffs are also state-controlled in The Netherlands and Spain.

In view of the federal structure of Germany's electricity supply, the system of negotiated network access has been chosen as basis model. Under this system, power utilities and consumers negotiate transition tariffs and other conditions for network access directly with the corresponding network operator(s). As of the year 2000, the latter are obliged to publish price ranges for the use of their distribution and transport networks. Companies which opt for the single buyer model, planned in the Energy Law Amendment by the year 2005, are, however, required to obtain official approval and to publish their tariffs for the use of their supply network.

The German Associations Agreement between associations of power utilities and commercial-industrial electricity consumers of May 22, 1998, sets down calculation of transition charges according to transparent joint criteria, whereby network use at all voltage levels is paid for only once at a flat rate like a "postage stamp". A distance surcharge is only levied for the use of the power voltage network for distances exceeding 100 km.

An electricity exchange is also conceivable in Germany. Interest has been expressed, for instance, by the Hanover Commodities Exchange. A number of brokers and dealers have also become established - starting with American and Scandinavian concerns, who have a track record in trade with electricity, through to the first independent companies who, with coordination and pooling, plan to achieve improved conditions not only for major consumers but also for medium-sized companies.


top of side  Switzerland as Power Hub (国外への電力供給を検討中のスイス)

Outside the European Union Switzerland especially is contemplating the opportunities in electricity trading. With sights focused on eastern and southern Europe, its geographical location, own generating capacities and an extensive network offer ideal conditions for acting as a hub. Italy, for example, since abandoning nuclear energy in 1988, is suffering from a chronic electricity shortage and has relatively high imports (17.8 TWh from France in 1996).


top of side  European Commission: Motor of Competition

Because a really functioning single market is only feasible when discrimination freedom of transition charges prevails in international procedures for inter-country power transfer, the harmonization of cross-border tariffs is one of the most important subjects for the European Commission in conjunction with the extrapolation of the Electricity Directive. Any preference for a specific model, however, is not apparent. Experiences from Scandinavia, where cross-border cooperation is already practised under the scope of NordPool, will undoubtedly be reflected in the discussions. The General Direction Energy (GD XVII) of the European Commission will table these questions once again at the next conference on "Electricity Regulation" in Florence in October 1998 and will press for a solution.

In this scenario the Directive foresees the possibility of transition rulings, which, however, must be notified and approved by the member nations of the Commission. By expiry of the deadline on February 20, 1998 only three member nations had not submitted application: Italy, Sweden and Finland. The methods for compensating, respectively avoiding stranded costs range from surcharges on the power price to be shown separately in the electricity bill (similar to the "Competition Transition Charge" common in the USA), over surcharges on the network charge through to temporary purchase commitment and competition exceptions. The test procedure from the Commission should be concluded by the date when the Directive must be ratified in national legislation, in most cases therefore by February 19, 1999.


top of side  Renewable Energies: No Chance in the Electricity Market?(再生可能エネルギーの出番がないわけじゃない?)

On of the most controversial subjects from Brussels' viewpoint was and is the future positioning of renewable energies. European parliamentarians fear on the one side, that renewable energies will have a hard time finding buyers for their relatively expensive power in an open market characterized by price reductions. On the other side, promotional instruments like subsidies, feed-in compensation etc. are seen as special treatment which is not competitively neutral, particularly in cross-border competition. The Directive contains no binding rule on this subject, foresees merely that member nations can make by them named network operators obliged to give preference to renewable energies in load management.

Whereas some member nations abide by the simple form of the preference declaration, some countries have introduced a purchase obligation like in Germany, e.g. Denmark and France. In Great Britain this is linked to a tendering system and financed by a fee payable by the customer. In The Netherlands it is arranged via so-called "Green Certificates". Furthermore, there are a number of widely different benefit regulations. The Scandinavians work predominantly with investment subsidies and tax concessions.

In June 1998, European Parliament urged the Commission in a resolution to urgently introduce Europe-wide regulation. In a paper published at the end of March 1998, the Commission itself pointed out the need for a community-wide, competition-conform system for promotion of these energies.


top of side  Politics Do Not End With Deregulation(自由化だというわけで環境問題等への取り組みという政治課題が無くなったわけではない)

The energy-political activities of the European Commission are by no means at an end. Experiences gained on the already deregulated markets show not least to what extent competition is an on-going process. The inter-effects between developments in the individual member and (as yet) non-member nations will always require new processes of adjustment at both domestic as well as European level. In Brussels an eagle eye will be kept and consultations take place on how the Directive is being implemented nationally and whether further supporting, harmonization or follow-up measures from the EU side are needed. Over and above the increase in efficiency and thus competitiveness expected from the single market, the European institutions will not neglect the two further cornerstones of their energy policy: supply reliability and sustained activities - not least in connection with the obligation to reduce greenhouse gas emissions reached in Kyoto - are still top of the agenda.

By Sabine Froning, Deputy Director of the Brussels Office of the VDEW (Association of German Electricity Supply Companies), Frankfurt am Main, for the journal BWK issue 7/8 1998