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reinfoced (sic) separation of network operation from production and supply (unbundling)

That question completely excludes the option of re-bundling network operation from production and supply. This may not be the direction things have evolved in recent years, but the option should certainly be offered in a public consultation that purports to be neutral, and Europeans should be allowed to argue for choices different from those of the Commission.

That question can hardly be separated from that of regulating the existence of spare capacity, its size, who provides it, and how it is paid for.

reinforced powers and independence of national regulatory authorities

Again, this presupposes that Europe's energy policy will be based on indirect regulation rather than on national (or other) monopolies which require a different kind of relationship with the State This may be the facts on the ground, but the point of this consultation should not be necessarily to endorse the current policy choices, but to have a debate on the full range of possible solutions. Secondly, as with the question above, it totally excludes the choice of less independence, which is known to be preferred by some - they should be allowed to participate to this consultation as well.

harmonised grid access conditions (European Grid Code)

This question should probably be developped to include a discussion of the mechanisms to build the interconnection capacities that would be required for any harmonised grid code to make any sense. Should such capacities be built? Who should pay for them? What environmental safeguards should be put in place?

Create a European Energy Regulator

This question makes no sense until the goals, means and powers of such regulator are defined. Creating an institution whose role is not defined is pointless at best, and reckless if this is seen as a carte blanche for policies that have not been approved by,  or explained to Europeans to be implemented by a small committee.

Create a body of transmission system operators at the European level

This already exists (link to be provided). This question seems to be an open ended invitation to give it more formal roles and powers, without the content of these activities being discussed. Again, it appears to be a request for carte blanche action behind the scenes.

In the long run, we're all dead. John Maynard Keynes

by Jerome a Paris (etg@eurotrib.com) on Wed Sep 6th, 2006 at 06:58:13 PM EST
Subject to my comment above (difference between our Consultation contribution and this letter of procedural complaint), I think some of these may be used: the paragraph on the European grid, for example.

But let's note that most of the Green Paper itself excludes other options than those the Commission wants to push through, and it's in commenting the GP that many of these points (and DoDo's) should be made.

However, it is a valid procedural point to say that the Consultation mechanism excludes options other than those of the Commission.

by afew (afew(a in a circle)eurotrib_dot_com) on Thu Sep 7th, 2006 at 02:05:24 AM EST
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