EFET promotes
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pan-European energy
trading in open,
transparent and liquid
Traders’ Hopes and Fears at Ten Years
The evolution of wholesale electricity and gas markets
(1999 – 2009)
The EFET Vision
for further market development
(2010 – 2020)
www.efet.org
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A Single European Energy Market?
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wholesale markets.
EFET Statement of Purpose
EFET promotes and facilitates European energy trading in open,
transparent and liquid wholesale markets,
unhindered by national borders or other undue obstacles.
______________________
EFET Statement of Activities
EFET Vision
We foresee energy markets throughout Europe,
in which traders efficiently intermediate in the value chain on the basis of clear wholesale price signals,
thereby optimising supply and demand and enhancing security of supply,
to the overall long-term benefit of the economy and of society.
We improve the operation of European wholesale energy markets and enhance the performance of
traders and their support functions in those markets. We reinforce the markets’ functionality and
facilitate their liquidity and transparency.
We do this in particular by:
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Providing standard solutions to the repetitive aspects of wholesale energy transactions, such
as contracting and data exchange;
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Advocating policies and regulatory measures, which allow electricity and gas trading to
develop freely in parallel, and which minimise obstacles to trading in related instruments and
products, including futures and forwards, other derivatives, emission allowances and “green”
certificates;
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Encouraging probity, good risk management practices, responsible corporate governance and
proper accounting among energy traders.
Colofon
art-direction, design and printing:
DesigN & PublisH
editors:
Peter Styles, Jan van Aken,
Ilaria Conti and Maria Popova
All text, images, and content contained
herein are copyright © 2009 EFET,
all rights reserved, and may not be
modified, reproduced, appropriated,
translated, distributed, published
or circulated in any form or medium
without written permission of EFET.
In EFET we ourselves can work on and produce standards for traders to use in the OTC portion of the wholesale energy markets of
Europe (the portion in which continent-wide the majority of transactions are carried out). Certainly, to achieve the implementation
of contracted transactions in the commodities power and gas we rely on the cooperation of TSOs, gas hub companies and gas
storage owners. Equally, we have collaborated with the brokers’ community to achieve a broader take-up of the IT standards
promulgated by EFETnet. When it comes to transactions occurring over customised, multilateral trading platforms, however, we can really
achieve little without active cooperation, creativity and execution on the part of the operators of those platforms. These are brokers, clearing
houses and, most significantly, exchanges. We are encouraged that the association representing energy (so far, mostly power) exchanges,
Europex, is developing a permanent secretariat and becoming more engaged in both the regulators’ Electricity Regional Initiatives and
EU-wide market design programmes under the Florence Forum. Particularly in the case of cross-border market coupling projects focused on
the day-ahead electricity timeframe, there is much work to be done collectively by exchanges, TSOs and market participants.
Foreword by the Chairman and the Secretary General: Achieving the EFET Purpose
The past…
It has been a great pleasure for both of us to see EFET growing as an organisation in the last 10
years.
In 1999 we founded EFET, together with a handful of like-minded colleagues.
The EFET Vision and the way forward
At that time, energy trading in Europe was restricted to a few regional markets, such as the UK and
Scandinavia. In continental Europe there was virtually no framework for wholesale energy markets
subject to competition. Vested industry players did not appear too eager to strive for market
opening. On the contrary, there was in many cases an atmosphere of hostility towards the prospect
of liberalisation.
Here in outline are some of the major challenges, which EFET will need to address in the coming years, with particular focus on those
pertaining to the pan-European energy market design and the related EU policy and regulatory framework:
Undue national intervention continues in some cases to delay or distort the process of establishing price signals in wholesale energy
markets. As the fully liberalised energy market becomes better established, market signals should more reliably inform the right decisions
about investments in terms of fuel choice, location and capacity.
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Despite the efforts of national regulators, there remain serious unresolved cross-border access difficulties. Authority at the EU level needs
to be strengthened to deal with the interfaces between transmission systems. TSOs and exchanges still need to recognise the importance
of developing healthy markets in transmission capacity rights, as well as in the underlying commodities of power and gas, across the
continent.
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The effective unbundling of monopoly transmission infrastructure, to ensure that there are independent system operators providing
market participants with fair and non-discriminatory access, remains in many countries, more notably in the gas sector, an unfulfilled
prerequisite for successful EU energy market opening.
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Improved information transparency remains essential across the energy markets, particularly the provision of information from infrastructure
operators and the accountability and clarity of regulatory decision-making. The immediate goal with respect to transparency should be
for all generators, operators and regulators to match the highest standards already achieved by their peers in other EU countries.
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The successful establishment of the EU Emissions Trading Scheme shows that the market is a powerful and practical tool to deliver public
policy objectives. However, in order for the market to function efficiently, market participants need to be confident that the principles
underpinning the scheme will be consistently applied. The most efficient way to introduce sustainable levels of renewable energy
production across Europe is by promoting and harmonising market mechanisms, but the new RES Directive falls short of the standard
required for this purpose.
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To maintain secure energy supplies consistently across the EU, priority must be given to the development of robust gas and electricity
markets, in which vibrant competition, non-discriminatory grid access, objective regulation and good transparency give confidence to all
market participants, from producers through wholesale intermediaries to consumers. It is illusory to imagine that individual nations within
the EU could separately, as if in some kind of race, beat each other in the security game by signing bilateral inter-governmental deals
with third countries or by favouring so-called national champions.
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To achieve our Vision and fulfil our Purpose, EFET still needs to push for progress in market integration and regulatory harmonisation.
Growth in the liquidity of energy trading, and corresponding improvements in the objectivity of terms of access and in the transparency
of information available to traders are essential. In order to reach these goals, traders must continue to seek enhanced cooperation with
policymakers, competition authorities, sector regulators, exchanges, transmission operators, producers and consumers.
12
In the spirit of an emerging EU free market for energy, we developed the idea to establish EFET as an
association of market-oriented companies, represented by open-minded managers. We shared a vision
and a will to make market liberalisation work throughout Europe. The first initiatives of our traders’
federation focused on transactions standardisation and advocacy of design and regulatory elements
to help the establishment of the EU internal energy market.
Paul van Son
… the present…
Today, the phenomenon of energy trading is a necessary component of the business model of all
committed electricity and gas suppliers across Europe. It is increasingly acknowledged that energy
trading is adding high value to the European economy. Liquid and efficient wholesale markets in
power, gas and emissions are pivotal to the optimisation of the energy chain and to the establishment
of effective risk management mechanisms. In this context, the role and scope of work of EFET have
grown considerably.
In order to ensure that the energy markets across Europe develop adequately and integrate
effectively, we carry on working in four main areas:
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Jan van Aken
Power, gas and emissions market design;
Energy policy and regulation;
Standard energy contracts; and
Electronic transaction data standards.
The EFET master contracts for wholesale OTC transactions in gas, power and related products have
been a tremendous success right from the beginning. They are well-accepted by the market and used
as a general reference point by traders conducting business with (new) counterparties throughout
Europe.
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EFETnet, a subsidiary organisation established in 2005, develops and maintains standards for electronic data exchange between the trading
units of participating companies or brokers. Currently, these standards have over forty users.
Meanwhile, we continue to conduct numerous studies on the requirements for the optimal functioning of wholesale power and gas markets.
Our practical advice and proposals for market design and rules, and for transmission and hub access regimes effectively help the European
Commission, regulators, TSOs and the rest of the industry to move faster in the direction of truly open and transparent markets.
…and the future!
Despite the considerable progress achieved over the past ten years, many challenges still have to be tackled. Urgently needed improvements
in the development of the internal market include:
Coordinating and optimising the load flow in the interconnected European grids;
Strengthening market transparency, in particular, improving the access to adequate information on capacity allocation, generation, and
demand;
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Promoting a more commercial approach of infrastructure operators and advocating cooperation among TSOs within and across borders;
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Eliminating political interference wherever it aims to protect national interests, influence free market price-setting mechanisms or limit
the independence and powers of an energy regulatory authority;
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Integrating successfully renewable energy in the pan-European market.
The EFET contribution to market opening
Advocating appropriate energy policy and regulation has been recognised from the outset as a core activity for an association
representing the interests of European power and gas traders. EFET is known for working quickly and professionally to analyse
issues that affect the operation of Europe’s wholesale energy markets. The relevance of the association’s analyses of these issues is made
possible by the experience of our geographically diverse membership and by our emphasis on maintaining a flexible organisation, in which
decisions are reached by consensus. Conflicting national or sector positions are discussed internally, with the end result being the publication
of EFET position papers that have been objectively and carefully argued.
The EFET opinion is more and more appreciated (and sought) by the main actors on the European energy trading scene. In fact, in the past
few years, representatives of institutional bodies and members of various associations have started inviting EFET on a regular basis for an
exchange of views on specific energy matters.
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Standards and platforms for the future energy marketplace
When seeking standard solutions to the repetitive aspects of wholesale energy transactions, EFET has found a fruitful territory in tackling
the standardisation of gas and electricity spot physical contracts. More recently, we have looked at possibilities in IT-based data exchange
between wholesale counterparties and related business processes. Current priorities in contract standardisation include:
Updating the existing standard power and gas master contracts for OTC transactions in continental Europe;
Helping the uptake of the EFET standards in Eastern European markets by training market participants and providing local language
translations of the General Agreement and its various appendices;
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Completing the coverage of legal opinions beyond the 24 jurisdictions currently included in the legal opinions on gas, electricity, emissions
and credit netting standard contractual terms;
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Developing harmonised appendices to the gas master contract for additional European gas hubs;
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Issuing new appendices for transactions in gas and power transmission capacity rights; and
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Actively advocating the creation of EU-wide netting legislation in order to improve netting for physically settled energy transactions.
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The near future is, of course, influenced by the current economic crisis and the ensuing fall in energy demand and regulatory disruptions. In these
complex conditions, wholesale traders have to navigate through the perilous waters of price volatility and policy and regulatory uncertainties.
Nevertheless, they remain focused on achieving the goal of value chain optimisation for their own benefit and for the benefit of European society.
We are confident that in the future the traders’ community will maintain its high degree of professionalism, impeccable market behaviour and
integrity. Over the past ten years, EFET has become the voice of energy traders across Europe. In the next decade, with the same dedication
and optimism, we will continue our cooperation with all other interested parties and authorities on the way to establishing a truly modern,
open, transparent, sustainable and liquid wholesale energy market in Europe.
The standardisation of data exchange and processing by electronic means will be one of the main areas of EFET work for the future, mostly
channelled through our subsidiary organisation EFETnet (www.efetnet.org). A common IT architecture, coupled with standardised data
formats, codings and automated processing related to lifecycle events of cleared and OTC transactions will deliver significant cost savings and
increase the efficiency of traders’ front, middle and back office operations. Unbundling, the internationalisation of the power and gas sectors,
shorter reaction times for supply optimisation and convergence between commodities are bringing about an acute need to exchange data
in a standardised way between counterparty organisations and other service providers, including transmission system operators, exchanges,
clearing houses, clearing banks and the broker community. That, in turn, allows computers to substitute digital means for costly manual work.
Substitution frees up employees to focus on the management of exceptions and other commercially beneficial tasks. It also translates to fewer
mistakes and helps mitigate operational risk.
So we say: Happy 10th Anniversary to EFET and all the best for the future!
Paul van Son, Chairman and Jan van Aken, Secretary General
Peter Styles
Chairman of the Electricity Committee
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Colin Lyle
Chairman of the Gas Committee
Jan Haizmann
Co-Chairman Legal Committee and
Director of the EU Liaison Office
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Hugh Brunswick
BOP Standardisation and
Managing Director of EFETnet
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In the context of the second type of transparency, it is important that regulators and legislators do not exacerbate the problem of
market entry by zealously imposing bureaucratic disclosure obligations on wholesale tier participants in newly liberalised European
energy markets. They should rather focus on putting in place clearer, harmonised and legally binding rules obliging owners and
operators of infrastructure in the power and gas sectors to publish detailed information about the availability and utilisation of
that infrastructure. In this way, competitive wholesale power and gas markets have a chance to develop efficiently, to the benefit of the
European economy and the European society as a whole.
Expanding market horizons: energy and environment
In the past few years, as part of a concerted EU climate change policy, Member States have made binding commitments to reduce carbon
dioxide emissions. Under two new Directives, they are now prolonging and expanding those commitments, as well as taking on collective
obligations to increase the share of energy consumed from renewable sources. These pledges will entail important repercussions on the
structure and functioning of wholesale energy markets across Europe. Whether they act as help or hindrance to the establishment of a single
European market in electricity and gas largely depends on the degree of determination of policymakers to adopt a harmonised, market-based
approach to the achievement of the targets.
Table of Contents
EFET Statement of Purpose [inside front cover]
Foreword by the Chairman and the Secretary General: Achieving the EFET Purpose....................................................1
Principles of good conduct for energy traders..................................................................................................4
EFET organisation development...................................................................................................................5
EFET member companies...........................................................................................................................6
Highlights : The evolving European wholesale energy market – a look back and a look forward.....................................8
In the case of the EU Emissions Trading Scheme, we have witnessed in the last five years a determined push by the European Commission to
create a truly single European market in carbon emission allowances, with transparency and liquidity in secondary trading constituting an
integral goal of the scheme. The most economically efficient and least disruptive way to reach significantly higher levels of renewable energy
supply across Europe would similarly be through the introduction of market-based mechanisms. These are already being implemented in
some countries today in the form of quotas backed up by the issuance of certificates to producers. Provided that such schemes are properly
implemented, they will support investors’ interests, encourage technological innovation and permit flexibility across the continent in locating
renewable production where wind, solar or geothermal sources are the richest.
EFET Vision [inside back cover]
Currently, there are several obstacles, which work against EU-wide harmonisation around a market-based model:
Low market volume: For promoting renewable energies, most countries have chosen feed-in tariffs at fixed prices rather than certificate
systems;
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Incompatible certificate systems: Some countries do have certificate systems to promote renewable energy, but these vary from country
to country;
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No mutual recognition: With the exception of the schemes in the Netherlands and Italy, certificates may be used only to fulfil obligations
and attract incentives in the issuing country;
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Certificate redemption still linked to the physical electricity supply: Only a trade in certificates that is separate from physical trading
in electricity will develop the requisite flexibility and volume.
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These barriers could only be eliminated by brave political decision-making on a harmonised European basis. As a first step, it is important
that Member States should be encouraged to abandon or amend feed-in tariff systems in favour of more market-based approaches. Tradable
Guarantee of Origin (GoO) certificates would help to promote the use of renewable energy in electricity production and facilitate the
realisation of targets in the most cost-efficient way.
In summary, the economic efficiency of the EU Emissions Trading Scheme has been enhanced through the recent emphasis of the European
Commission on market liquidity and transparency. An economically efficient transfer of a carbon emission allowance leads to a cost-effective
reduction of greenhouse gases, because a contributory technical abatement measure may then be taken by the company that can achieve
the greatest mitigation effect at least additional cost. The same outcome could be expected from transfers throughout the EU of mutually
compatible renewable energy certificates in relation to the lowest cost means of renewable power production.
10
EFET General Meeting 2008
3
Principles of Good Conduct for Energy Trading
Traders entered the year 2009 knowing that the continuing global financial and economic crisis has put the spotlight on the organisation of
markets, the probity of companies participating in markets and the conduct of individual trading managers. Although power and gas trading
is still a rather young business in Europe, and although limited liquidity means that transaction volumes remain small compared with those in
traditional financial instruments and commodities, it behoves us to pay renewed attention to our professionalism and our ethics.
Thus, we think it is important to re-state on our tenth anniversary the principles of good conduct, which EFET worked on and promulgated,
in common with Eurelectric, in 2005. Since then, all new members have to sign up to these principles before their membership application
can be accepted by the EFET Board.
EFET aspires to the adoption within its member companies of values, in which we, as an industry association, believe:
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Integrity of action, for example in dealing with counter-parties and business stakeholders;
Respect for others, such as fellow employees, competitors, and professional advisors;
Open communication, subject to observing legitimate business confidentiality;
Professionalism, ensuring that only qualified parties and staff are involved in trading activities; and
Observing the spirit of a truly open and sustainable wholesale marketplace.
The “10 Pillars” of Good Conduct
Companies engaged in trading in energy markets will:
1. Respect free and fair competition as the basis for trading
energy.
2.Not engage in any activities which would amount to market
abuse, market manipulation or fraud, nor relay information
known or strongly suspected to be false or misleading.
3. Deal with each other in accordance with established market
practices and the standards expected of professional market
counterparties.
4. Deal with customers fairly and with integrity and manage any
conflicts of interest that may arise appropriately.
5. Organise their energy trading business effectively, respecting
appropriate segregation of staff duties, and exercise diligent
control over trading functions.
6. Establish effective risk management policies and control
procedures governing the key risks managed by their energy
trading functions.
4
7. Establish compliance policies setting out the company’s
procedures for fulfilling all legal and regulatory obligations
and any related corporate governance rules relating to their
energy trading functions.
8. Ensure that their traders are suitably qualified and properly
supervised to carry out their duties, including where
appropriate to have taken relevant industry examinations.
9. Prohibit their employees from giving or receiving bribes and
from indulging in other corrupt behaviour in all circumstances;
and establish policies governing gifts and hospitality,
highlighting acceptable and unacceptable practices.
10. Maintain accounts related to trading transactions and risk
books in accordance with relevant accounting standards, and
respecting normal audit practices.
The gas market
At present, only in the UK, Belgium and the Netherlands have the volumes of gas traded in the high-pressure pipeline systems
matched or exceeded the national consumption. Countries like Germany and France have recently made significant improvements
in their internal network access arrangements. Trading has begun at “virtual points” in several pipeline systems and there are
plans to merge some market areas. In Spain, where almost 70% of the supply is LNG, traded volumes are significant, but the development
of a liquid market is constrained by limited interconnection capacity with the rest of the EU. Important gas trading developments are also
underway in other countries, notably at the Italian “virtual point” and in Austria at the border with the Slovak Republic, but access to capacity
in the international pipeline routes remains a serious constraint.
On the whole, the prevailing situation in the gas markets of continental Europe is characterised by a lack of liquidity. The absence of a reliable,
transparent spot gas price creates difficulties in hedging and in devising reliable financial instruments to manage risk. Incompatible pipeline
access causes geographical fragmentation within regions. Traded gas volumes are increasing, but much more needs to be done to establish
robust wholesale markets that can support consumers’ needs throughout Europe. In particular, the following issues need to be addressed:
Guaranteeing fair access to gas infrastructure. Priority access is a problem observable at almost every high-pressure pipeline interface
in Europe. There is a continuing failure to ensure that sufficient capacity is built and that existing capacity is fully used. Coherent
mechanisms for capacity trading are still missing.
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Reducing the number of market areas. In order to create supra-national gas grids and trading zones that transcend national borders,
market rules need to be simplified and harmonised, and independent operators, responsible for several combined pipeline networks, need
to be established.
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Improving information provision. Information on the physical use and availability of gas infrastructure is often not available or not
provided in a consistent or coherent form. To build confidence and encourage trading, market transparency needs to be enhanced. TSOs
need to provide adequate information on the available capacity and the actual gas flows to all market participants and regulators.
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Establishing trust in information availability and transaction patterns
One of the major preconditions for a well-functioning internal market for electricity and gas is market transparency. However, it is important
to note that transparency has two different dimensions: disclosure of information about the use of infrastructure by the owners or operators
and disclosure of information about the state of the market and wholesale transactions (which, if disclosed specifically to regulators, may
aid market monitoring).
The first type of transparency - the publication of consistent information about ex ante availability and ex post use of electricity and gas
infrastructure - has the potential to facilitate market liberalisation and encourage greater competition. The release by TSOs and incumbent
producers of demand, transmission and generation data is crucial to market players’ ability to analyse likely market developments and
participate in forward markets. Access to such information helps new entrants to turn third party access from legal theory into a real business
tool. Overall, transparency about the use of energy infrastructure reduces risk, provides confidence and allows efficiency, liquidity and
security of supply to improve.
The second type of market transparency - access to information about wholesale transactions - may, in particular, constitute a tool for
effective market monitoring. Currently traders have no claim to financial or any commercial data about other traders’ transactions, except
for the very limited and aggregate purpose of checking whether TSOs are properly allowing market access. Aggregated post-trade transparency
requirements for (power and gas) exchanges, brokers and multilateral trading facilities (MTFs) could ensure that clearer and more accurate
pricing information is delivered to the market. However, it should be noted that requirements for regular reporting of individual wholesale
energy transactions would constitute an unnecessary burden. Such reporting is a priori disproportionate to any possible abuses that may need
to be addressed in the power and gas sectors during the current liberalisation phase.
9
The evolving European wholesale energy market – a look back and a look forward
In the following pages we present some highlights of the full version of the EFET 10th Anniversary booklet, due to be published
in the summer of 2009.
EFET organisation development
EFETMembers
EFET Organigram 2000
The evolution of the European wholesale energy market (1999 – 2009)
Secretariat
Well-functioning wholesale markets in electricity and gas are essential, not only because they enhance competition and expand the spectrum
of consumer choices, but also because they help to maintain supply security, achieve environmental objectives and sustain EU competitiveness
in a global context.
In the past ten years, the European energy sector has undergone fundamental transformations. Market participants and regulatory authorities
have made important commitments to improve market transparency and liquidity, with the ultimate goal of creating a single European market
in electricity and gas. As a result of these efforts, wholesale trading, particularly in electricity, has been successfully established in a number
of European regions.
WorkingGroup
Standardisation
GasMaster
However, the development of efficient and competitive markets in electricity and gas is a complex task, as these are network-bound energy
commodities (with the exception of LNG). They cannot be freely traded unless there is equitable third party access to the transmission grid
and gas pipelines respectively. Therefore, despite the considerable progress, a number of important structural and policy challenges still
remain.
The electricity market
Currently, the more mature liberalised European electricity markets are to be found in the regions of Scandinavia and Great Britain. Strong
regulation and partial ownership unbundling have helped to develop competition in the Netherlands. Germany, which is a key region in terms
of volume, price setting and patterns of cross-border transmission access, made considerable progress towards electricity sector liberalisation
around the turn of the millennium.
Meanwhile, other European countries, some of which are among the original EU15, have been relatively hesitant to open or restructure their
electricity markets. Competition in generation and supply in Belgium, France, Greece, Ireland, Italy, and Portugal is still limited in practice.
In Switzerland debates about liberalisation have continued over several years without discernible progress, although the voluntary formation
of a separate joint venture to run the high voltage grid is an encouraging sign. Central and South-Eastern Europe have remained islands of
difficulty, with some governments particularly resilient to change. Limited market liquidity and restricted competition have made the process
of market opening slow and inefficient. It is still difficult for new entrants to break into many of these countries.
Overall, interactions between national or regional markets naturally occur at all the key stages of production, transmission and supply.
However, the persisting operational and structural differences in market design among countries and regions have the potential to produce
inefficient patterns of both trade and trading. In this context, wholesale power market distortions, which remain to be dealt with, include:
The availability of transmission access rights. The (financial) predictability of network access across the EU has to be enhanced and the
incentives for TSOs to grant such access have to be strengthened. In essence, a new market in transmission capacity rights needs to be
facilitated.
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The continuing continental “regulatory gap.” The current framework for sector regulation of unbundled monopoly transmission operators
and/or suppliers is designed to apply primarily within national boundaries. National regulators need to make more consistent and coherent
joint efforts to ameliorate market interactions across borders.
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WorkingGroup
PR/PA
Board
WorkingGroup
Gas
ElectricityMaster
EFET Organigram 2009
Secretariat
Diagram 1:
WorkingGroup
Electricity
In 2000, EFET decided to focus on
electricity liberalisation in France,
on gas liberalisation in Germany and
standardisation of trading contracts.
France
Germany
EFETMembers
EFETDeutschland
Members
Board
EFETDeutschland
Board
MediaRelations
LegalCommittee
Back
Office
Group
IT
Architecture
PwG
LegalOpinion
Review
LCTFCollateral
BPOC
LCTFEmission
eCMPwG
ePMPwG
eSMPwG
eXRPTF
eCreditMatrixTF
PaymentNettingPG
TFGasAppendix
LCTFLNG
LCTFCapacity
LCTFCEE/SEE
GasCommittee
Electricity
Committee
GermanTFGas
(GTFG)
Market
SupervisionWG
TFVAT/Tax
CreditRiskTF
GasHub
Development
LNGPG
TFFrance
Renewable
EnergyWG
TFIberia
TF
Switzerland
CapacityPG
Marketintegration
InformationPG
GermanTF
Electricity(GTFE)
TFItaly
TFCEE
TFEmissions
Trading
CBAuctionsPG
IntradayPG
FlowbasedPG
Diagram 2:
StoragePG
Overview of the current organizational
structure of EFET, including the various
groups and subgroups.
5
Regular Members
6
Associate Members
7