UKRAINIAN GAS HUB · 6 Ukrainian gas hub a chance for Europe What is a Gas Hub? 1. Gas hub defined...

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Policy Paper UKRAINIAN GAS HUB – A CHANCE FOR EUROPE FINLAN D NORWAY SWEDEN DENMARK North sea Baltic sea ESTONIA LATVIA LITHUANIA GERMANY POLAND CZECH REPUBLIC M O L D O V A S L O VA K IA A U S T R I A B E L G I UM H U N G A R Y U N I T E D K I N G D O M IRELAND ROMANIA SERBIA BULGARIA FRANCE C R O A T IA ITALY GREECE PORTUGAL SPAIN

Transcript of UKRAINIAN GAS HUB · 6 Ukrainian gas hub a chance for Europe What is a Gas Hub? 1. Gas hub defined...

Page 1: UKRAINIAN GAS HUB · 6 Ukrainian gas hub a chance for Europe What is a Gas Hub? 1. Gas hub defined Simply speaking, a gas hub is a location where sev- eral gas pipelines interconnect.

Policy Paper

UKRAINIAN GAS HUB – A CHANCE FOR EUROPE

FINLA

ND

NORWAY

SWEDEN

DENMARK

North sea Baltic sea

ESTONIA

LATVIA

LITHUANIA

GERMANY POLAND

CZECH REPUBLIC

MOLDOVA

SLOVAKIA

A USTRI A

BELGIUM

HUNG ARY

UN

ITED

KIN

GDOM

IRELAND

ROMANIA

SERBIA

BULGARIA

FRANCE

CROA

TIA

ITALY

GREECE

PORTU

GAL

SPAIN

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This report has been created under the Ukrainian Think Tank Development Initiative, implemented by the International Renaissance Foundation (IRF) in partnership with the Think Tank Fund (TTF) and funded by the Embassy of Sweden in Ukraine (SIDA).

The views and interpretations expressed in this report are the authors’ and do not necessarily reflect those of the Government of Sweden.

DiXi Group is Ukrainian think tank involved in research and consultations related to information policy, energy, security, and investments.

Our mission is to be a driving force of high-quality changes in the energy sector, in order to achieve good governance and responsible consumption on the way towards sustainable energy. These changes envisage establishment of free and competitive markets with a high level of transparency, efficient regulation and respect for the rule of law principles, effective production and consumption of energy resources, overcoming corruption and other negative phenomena.

DiXi Group does not take any political positions; therefore, the views expressed in this publication are those of the authors.

This publication is available for downloading from the information-analytical resource Ukrainian Energy (www.ua-energy.org).

For additional copies of this document and further information, please contact:

02095, Kyiv, 24 Sribnokilska Street, P.O. Box 68

[email protected]

© NGO DiXi Group, 2016© SIDA, 2016Layout – Taras MosienkoPrinted by SiLa LLC

Prepared by Lukas Kulich, Science Po, DiXi Group Fellow

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IntroductionThe current decade is far from being finished but it has already became an important part of modern Ukrainian history. Ukrainian governments were for far too long undecided in what direction to choose for the development of their country: either to align with the European Union or with the Russian Fed-eration. When the former Ukrainian President Viktor Yanukovych refused to sign the Ukraine-European Union Association Agreement in November 2013 and thus decided to comply with the Russian Fed-eration, pro-EU Ukrainians assembled in the Maidan square where violent clashes between police and protesters took place in the early 2014. Yanukovy-ch then fled to Russia in March of the same year. Ukraine consequently started new period in its his-tory with the desire to achieve economic prosperity and to join the European Union.

There is nevertheless a long road ahead for Ukraine in its quest to achieve these objectives. The coun-try’s economy had been for too long dominated by personal interests of oligarchs. Ineffective adminis-tration and corruption continue to reign in Ukraine.

Effective implementation of legislation is hard to achieve and economic growth together with busi-ness creation have fallen considerably since the War in Donbas. Until the Revolution of Dignity, Ukraine’s energy sector had been heavily dependent on Rus-sia due to both Gazprom’s monopolistic position as supplier in the Ukrainian gas market and Kremlin’s influence on Ukrainian officials.

The 2013 rupture with Yanukovych’s ancient régime gave Ukraine a unique opportunity to create a liber-alized and healthy economy. In order to achieve this objective, a stable gas supply is needed. Gas is one of the most important elements in Ukrainian economy: it is not only used for energy-intensive industrial re-gions in the East of Ukraine but it is also an essential fuel for residential heating. This said, gas supply was also Ukraine’s weak spot since the country had been reliant only on the Russian Behemoth - Gazprom. Af-ter the unlawful annexation of Crimea by Russia in March 2014, the need to drift away from Russian gas and to diversify gas supply became more important than ever before in Ukraine.

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4Ukrainian gas hub – a chance for Europe

52,6

26,8

36,5

44,8

32,9

25

14,5

6,1

66,3

51,957,6 59,3

54,850,4

42,6

33,3

79,34%

51,64%

63,37%

75,55%

60,04%

49,60%

34,04%

18,32%

0,00%

10,00%

20,00%

30,00%

40,00%

50,00%

60,00%

70,00%

80,00%

90,00%

0

10

20

30

40

50

60

70

2008 2009 2010 2011 2012 2013 2014 2015

Gas v

olum

e (in

bcm

)

Russian Gas import (bcm) Ukraine’s gas consumption (bcm) Dependence Ratio

4

Creation of a gas hub in Ukraine plays an impor-tant role in achieving gas supply diversification and liberalization of Ukrainian gas market. Gas hubs concentrate large quantity of gas supply that as-sures long-term energy security for the country, as well as gas-on-gas competition, which pushes the prices of blue fuel down. Gas hub will furthermore contribute to the improvement of overall business environment in Ukraine and to further Ukrainian in-tegration into the European Union. In the first part

of this report (‘What is a Gas Hub?’), the report will present the theory behind functioning of a gas hub and associated energy exchanges. In its second part, (‘Creating Gas Hub’), the report will list all the necessary elements for its design and hub creation in Ukraine. In the third part (‘Threats and Opportu-nities to Gas Hub Project’), the report will present potential opportunities and obstacles to the gas hub launch. The report will then finish with a series of recommendations.

UKRAINIAN DEPENDENCE ON RUSSIAN GAS PIPELINE IMPORTS 2008-2015*

* Dependence ratio is calculated as the division of Russian gas imports by Ukraine’s overall gas consumption for a specific year. Data retrieved from http://naftogaz-europe.com/article/en/NaturalGasSuppliestoUkraine and http://www.naftogaz.com/files/Zvity/Naftogaz_Annual_Report_2015_engl.pdf, p. 86

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5Policy Brief

3330,3

27,5 29,7 31,534,3 33,1 34,1 34,2

29,7 29,6 28,9 29,2 27,9 28 2724,2

18,9

75,6 75,7 73,470,5 69,8

76,3 75,8 76,4 73,969,8

66,3

51,957,6 59,3

54,850,4

42,6

33,8

44%

40%

37%

42%

45% 45%44% 45%

46%

43%45%

56%

51%

47%

51%

54%

57% 56%

0%

10%

20%

30%

40%

50%

60%

0

10

20

30

40

50

60

70

80

90

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015

Gas v

olum

e (in

bcm

)

Ukraine's Non-Industrial Gas Consumption 1998-2015

Gas Consumption in Household, DNCs, Government Financed Institutions Total Gas Consumption Gas Consumption Ratio

UKRAINIAN DEPENDENCE ON RUSSIAN GAS PIPELINE IMPORTS 2008-2015*

* Gas Consumption Ratio is calculated as the division of non-industrial consumption (households, district heating companies and governmental institutions) by Ukraine’s total gas consumption for a specific year. Data retrieved from http://naftogaz-europe.com/article/en/GasConsumptioninUkraineeng.

FINLA

ND

NORWAY

SWEDEN

DENMARK

North sea Baltic sea

ESTONIA

LATVIA

LITHUANIA

GERMANY POLAND

CZECH REPUBLIC

MOLDOVA

SLOVAKIA

A USTRI A

BELGIUM

HUNG ARY

UN

ITED

KIN

GDOM

IRELAND

ROMANIA

SERBIA

BULGARIA

FRANCE

CROATIA

ITALY

GREECE

PORTU

GAL

SPAIN

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6Ukrainian gas hub – a chance for Europe

What is a Gas Hub?

1. Gas hub defined

Simply speaking, a gas hub is a location where sev-

eral gas pipelines interconnect. The interconnection

of several supply pipelines represents an opportu-

nity to trade and physically exchange gas between

a large number of buyers and suppliers. Whilst the

first gas hubs were established in the United States

as early as in the 1950s (e.g. the Henry Hub in Loui-

siana), the concept of gas hubs came to Europe sig-

nificantly later except the United Kingdom which

established its National Balancing Point (NBP) in

1990s. The majority of gas hubs in continental Eu-

rope have been created only in the last 10 years and

their development was catalyzed with the arrival of

Liquid Natural Gas (LNG) into European gas market.

Among the most important gas hubs in Europe are

the Title Transfer Facility (TTF) in the Netherlands,

GASPOOL in Germany, PEG Nord in France and Cen-

tral European Gas Hub (CEGH) in Baumgarten, Aus-

tria, which was created just in 2013.

A gas hub can be either physical or virtual. Physical

hubs are placed in a specific geographical location

where pipelines physically interconnect and where

the entire gas transmission system is located; they

therefore operate as a single system. Physical gas

hubs are used more in the United States (e.g. the

Henry Hub) than in Europe where virtual gas hubs

are used more extensively.

Virtual (also known as balancing) hubs cover wider

geographical area, represented by a national or a

transnational gas network. In a virtual gas hub, the

authority operating the gas transmission network

hub may accept gas at any point of the geographical

zone covered by the hub; a virtual hub is thus a bal-

ancing point inside a pipeline system. Whilst physi-

cal hubs permit larger volume trading, more partici-

pants may entry gas trading in virtual hubs. Contrary

to physical hubs, participants in virtual gas hubs can

choose among various exit/entry points within the

gas grid and have no obligation to arrange transpor-

tation of gas; the transportation of gas within the

grid is the obligation of an independent Transmis-

sion System Operator (TSO).

The presence of multiple supply gas pipelines in

gas hubs will create gas-on-gas competition, which

will push gas prices down. Moreover, the interplay

of supply and demand in gas hub trading will allow

for the discovery of gas market price. Gas hubs thus

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7Policy Brief

What is a Gas Hub?

BOX 1: WHAT IS HENRY HUB?

Henry Hub is a physical gas hub located in Erath, Louisiana. It was indirectly named by William Henry, a

German national who immigrated to the United States in 1840s. Henry Hub is owned by Sabine Pipe Line

LLC (a subsidiary of Chevron) and interconnects four intrastate and nine interstate gas pipelines owned

by private and public operators. Its futures contracts have been traded at the New York Mercantile

Exchange (NYMEX) since 1990s.

The hub as such does not transport big quantities of gas (only 1.8 billion cubic feet, i.e. 50.97 mcm, per

day) despite large number of associated exchange trading: most of futures contracts are actually not

physically delivered but cleared at the NYMEX exchange. With 400 000 contracts being traded every

day, Henry Hub is very liquid and became the benchmark for other gas prices.

Henry Hub is nevertheless not a 100% physical hub. There are significant distances between entry

and exit points and compressor stations; Henry Hub should be thus imagined as a ‘bowl of spaghetti’.*

Nevertheless, due to the tight concentration of pipelines at one space, Henry Hub may be imagined as

a gas exchange point and therefore to be classified as a physical hub.

* Rusty Braziel, “Henry The Hub, I Am I Am – Understanding Henry Hub: How Changing Natural Gas Flows Will Impact The Benchmark“, RBN Energy LLC, published on 23 September 2012, https://rbnenergy.com/henry-the-hub-i-am-i-am-understanding-henry-hub

** Rusty Braziel, “Henry The Hub, I Am I Am – Understanding Henry Hub: How Changing Natural Gas Flows Will Impact The Benchmark“

Trunkline

Texas Gas Columbia Gulf

Sonat

Gulf South

Bridgeline

Acadian

Trunkline

Sabine

NGPL

Sea RobinJefferson island

Henry Hub

Location of Henry Hub and Respective Pipelines in Erath, Louisiana**

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8Ukrainian gas hub – a chance for Europe

TYPES OF SERVICES OFFERED AT GAS HUBS

Below is the list of the most common services at gas hubs (the services offered may vary from one gas

hub to another):*

• Transportation: gas transportation within the hub, gas transportation from one pipeline to

another, hub-to-hub transportation

• Storage: short-term (so called ‘parking’) or long-term

• Peaking: selling additional gas in the case of unexpected increases in demand

• Title transfer: changes in ownership of a specific volume of gas present in a hub

• Gas loaning: an advance of natural gas repaid later by the shipper within a short-term period

• Gas management: compression, balancing, pooling/volume aggregation

* Adapted from “Conceptual design for a virtual gas hub(s) for the east coast of Australia”, FTI Consulting, December 2015, http://www.aemc.gov.au/getattachment/98035b44-a513-4d34-a5a0-9048b7166db3/FTI-Consulting-%E2%80%93-Conceptual-design-for-a-virtual-g.aspx, p. 37, 38

help significantly improving overall efficiency of

gas markets.1 The gas-on-gas competition in gas

hubs offers significantly lower market prices than

those in long-term contracts (LTCs) signed with ma-

jor gas suppliers2 and eliminates to a large extent

political motivations behind gas supply. While the

oil-indexed LTCs are still present in Europe, they are

progressively fading off: major gas suppliers such as

Gazprom are unwillingly moving to a price area iden-

tic or at least comparable to spot gas prices by offer-

ing significant discounts in order to secure demand

for their products. Gas hubs promote also futures

exchange trading, hedging against eventual price

risks and financial speculation.

Gas hubs are important in assuring short-term en-

ergy security: gas can be purchased from hubs to

cover short-term hikes in demand (especially dur-

ing heating seasons) or unexpected supply disrup-

tions. They play nevertheless a key role in gaining

long-term energy security too: thanks to the stored

volumes of gas from a large number of suppliers, a

1 Several gas hubs (e.g. the Henry Hub in the United States or National Balancing Point in the United Kingdom and Title Transfer Facility in the Netherlands) have already reached a significant level of maturity defined by a high churn rate and thus offer a benchmark gas price. This is not the case of gas hubs in Central and Eastern Europe which, contrary to the North-Western Europe are yet to reach maturity. For more information, see Heather (2015)

2 After the creation of NBP in the United Kingdom, the gas-on-gas prices were as low as 30% compared to LCSs in late 1990s. Heather (2010), p. 12

country dispose of a sufficiently high gas storage

and is no longer dependent of one major provider. In

addition to energy security, gas hubs highly increase

political and economic importance of the country in

which they are located. They favour integration of

regional gas markets into a transnational or even

the world gas market. In order to succeed with this

integration, it is beneficial that several already func-

tioning hubs exist within the geographical space of

a planned transnational gas market and that these

hubs can trade between themselves without any

economic or technical barriers (for this purpose, a

sufficiently developed gas interconnection is need-

ed to assure that gas molecules may flow in any

direction).3 Gas hubs thus represent the key ingre-

dient for development of further energy integration

into a transnational gas market.4

2. Pre-requisites for gas hub creation and functioning

In order to establish a gas hub, several require-

ments are to be met. Firstly, a fully liberalized gas

market is crucial in order to create competition be-3 The Energy Community, created in 2006, is an example of such effort: it

comprises EU states, Albania, Bosnia and Herzegovina, Kosovo, Republic of Macedonia, Moldova, Montenegro, Serbia, Georgia and Ukraine. The non-EU states of the Energy Community are committed to implement EU’s acquis communautaire in the fields of energy what promotes their integration to the Energy Community and finally to the European Union.

4 Heather (2015), p. 12

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9Policy Brief

FIVE MAIN REQUIREMENTS THAT LEAD TO SUCCESSFUL TRADING

Heather (2015) mentions in his paper on the evolution of European traded gas hubs 5 main elements

necessary for creation of a successful gas exchange:*

• Liquidity: how quickly it is possible to convert an investment portfolio to cash without

affecting the asset’s price (standardization of traded contracts leads to increased liquidity)

• Volatility: energy markets tend to be very volatile and also very liquid, they are also very

sensitive to external information

• Anonymity: clearing houses allow for trade between both ‘big’ and ‘small participants on

unbiased basis

• Market Transparency: openness of public information increases traders’ confidence in

markets

• Traded volumes: the importance of gas hub increases with the increase of traded volumes of gas

* Adapted from Heather (2015), p. 7-8

tween suppliers needed for market price discovery

and for the consequent pushing of gas prices down.

Secondly, a gas hub must attract a large number

of suppliers and buyers in order to assure efficient

competition and to have a sufficiently high gas in-

flow. High level of transparency in gas trading is

one of the necessary elements how to attract gas

suppliers and buyers. Exchanges in gas hubs must

be carefully controlled and regulated and the data

from hub trading must be made accessible to pub-

lic to ensure transparency and the trust of traders.

Thirdly, the Third Party Access (TPA) is necessary for

a gas hub creation. The gas grid must be unbundled;

that is the transmission network operator becomes

independent of gas producers and suppliers in or-

der to eliminate any commercial or political abuse

done to gas purchase. However, unbundling of the

gas network and establishing an independent TSO

can represent a complicated process, as it requires

substantial changes in energy legislation and regu-

lation.

Furthermore, both virtual and physical hubs need

an authority which will manage and oversee them.

This process is nevertheless more complicated in

virtual hubs where the TSO is responsible for all

the transport, storage and balancing of gas within

the grid’s large pipeline system. Establishing a set

of legal and administrative rules for gas transmis-

sion, trading and associated responsibilities is indis-

pensable for setting both legal and technical basis

of both gas hub functioning and the associated gas

exchange.5 The TSO is also responsible for balancing

the amounts of linepack (gas currently ‘squeezed’ in

pipeline) and in order to prevent any gas shortages

on a daily basis.

Next, the entry to the gas hub must be made on a

non-discriminatory basis. While both entry and exit

to physical hubs are limited to interconnected gas

supply pipelines, virtual hubs dispose of multiple

geographically-dispersed entry points (e.g. storage

or production sites, pipelines from foreign gas sup-

pliers, LNG re-gasification terminals) as well as exit

points (LNG compression terminals, transportation

pipelines, district heating companies, power plants

or industrial sites). Entry and exit tariffs for gas flows

are nevertheless necessary to sustain activities of

TSOs linked to management of gas transportation

and pipeline maintenance (in Continental Europe,

suppliers are obliged to book the capacity which

shall be used for entry and exit of their gas supply

and the capacity booked can be traded on a second-

ary market). A postage stamp tariff model is used 5 An example of such code is the Uniform Network Code for the National

Balancing Point in the United Kingdom, see https://www.ofgem.gov.uk/licences-codes-and-standards/codes/gas-codes/uniform-network-code.

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10Ukrainian gas hub – a chance for Europe

to apply the same tariff for a uniform gas unit when

entering or leaving the market but other models of

tariff pricing are also used e.g. matrix approach, dis-

tance to the virtual point etc.6

Other gas hub requirements are of financial na-

ture: a large number of buyers is needed to secure

a sufficient level of liquidity in the market. Stand-

ardization of contracts helps to achieve simplicity

in gas trading and offers possibility to contract gas

on spot and future basis. This opens space for fu-

tures market, financial hedging and speculation. Fi-

nancial speculation shall not be nevertheless seen

as a threat to gas markets: financial actors are im-

portant as they increase market’s liquidity needed

for sustaining the market. Creation of an online-

trading platform based on a bidding system with a

low transaction cost is thus absolutely crucial for an

efficient functioning of a gas hub. For this purpose,

a clearing house processing matching bits between

suppliers and traders on the basis of anonymity has

to be equally established (the clearing house would

increase the confidence of traders by removing

counter-party risk and thus allow investors to op-

timize their portfolios). At the same time, gas hubs

still allow to exchange gas in gas on a bilateral or

over-the-counter (OTC) basis.

6 For different pricing entry-exit tariffs, see paper by Maurice Vos, Bert Kiewiet and Konstantin Petrov, “Gas Transmission Pricing Models For Entry-Exit Systems and Implementation Options“, http://crninet.com/2013/2b.%20Kiewiet-Paper.pdf

The process of gas hub construction is nevertheless

very lengthy and it takes generally 10-15 years to

achieve a mature gas hub.7 Different actors (state,

suppliers, traders etc.) with different interests and

different degree of commitment to the project have

to participate together. As it has been already seen

above, some actors involved in the allocation of en-

ergy resources will not agree with a fully liberalized

gas market, as their rent from activities associated

with gas will decrease with the rise of market trans-

parency. Moreover, the nature of gas hub is equally

determined by states’ cultural attitude towards

trade: in Central and Eastern Europe, we may wit-

ness more regulated gas hubs trading than e.g. in

the United Kingdom what is a country traditionally

oriented towards free trade. The cultural and politi-

cal attitude towards the establishment of gas hubs is

especially important in the case of post-communist

countries in transition, such as the case of Ukraine.

7 Heather (2015), p 6

TRADE IN ENERGY MARKETS

There are two ways for trading in energy markets:

1. Over-the-counter (OTC) trading: bilateral trading between a buyer and a seller, which may

be dealt directly or mediated via brokers. Forwards are OTC contracts, mandating delivery of

a commodity on a specified date. Forwards are settled only after the delivery of gas, there is

therefore a full counter-party risk throughout all the delivery period.

2. Energy exchanges: matching bids of buyers and sellers on anonymous basis (clearing). Futures

contracts are traded in energy markets which, like in the case of forwards, mandate a delivery

of commodity. However, futures contracts are processed by a Clearing House, which requires

from buyers and sellers a “margin” in order to cover associated counter-party risk.

Contracts traded may be either spot (Intra Day, Day Ahead), prompt (Balance of Week, Weekend,

Balance of Month), or near/mid-far/curves (3 months, 6 months, 1 year…).

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11Policy Brief

DEVELOPMENT OF A GAS HUB TO MATURITY

Heather (2015) describes ‘the path of maturity’ of a gas hub as follows:*

“The process usually starts with a move to Third Party Access (TPA) to the network infrastructure,

often requiring legislative changes to force incumbents to release infrastructure capacity and gas

supply volumes thus incentivizing independents to enter the market. There is a requirement for the

adoption of rules and regulations governing the physical side of the business, whilst the emergence of

standardized contracts will favour the commercial aspects. This will then be followed by bilateral trading,

often aided by the first brokers, helping to create trading opportunities between counterparties. These

trades start to be reported in the trade press, thus creating the beginnings of a transparent market.

With price disclosure comes price discovery which in turn attracts more players to the market, often at

this stage smaller physical traders and the first tentative moves by financial players too. The creation

of exchange products (futures), based on the underlying physical contracts, offers greater access to

the market, especially by non-physical players (who will always close out their trading positions before

maturity).

Gradually, as increasing numbers of varied participants come to trade in a particular market, a forward

curve will develop and this will be used for risk management purposes. The final stage of maturity is

when the hub develops sufficient liquidity for traders to use specific traded products (such as the Day

Ahead or the Month Ahead) as indices on which to price their physical transactions.”

* Heather (2015), p 6-7

Indices derived for LT Contracts

Liquid Forward Curve Develops

Futures Exchange

Non-Physical Players enter

OTC Brokered Trading

Balancing Rules&Standardised Trading Contracts

Price Discovery and Disclosure

Bi-Lateral Trades

Third Party Access to Pipelines/Regas Terminal

10+years?

Source: H.Rogers (OIES)

HUBS‘ PATH TO MATURITY**

** Heather (2015), с. 7

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12Ukrainian gas hub – a chance for Europe

Creating Gas Hub in Ukraine

3. Why to create a gas hub in Ukraine?

The annexation of Crimean Peninsula and the war in

the Donbass Region harmed the Russian-Ukrainian

relations for years to come. Ukraine alone can no

longer rely on Gazprom as a sole supplier for gas

and the country must undertake a very thorny but

important path to achieve energy security on a long

term. Of the several ways of achieving energy secu-

rity, diversification of gas supply is by far the most

efficient way of securing gas inflow. Gas hubs permit

gas trade between a substantial number of gas sup-

pliers and buyers. Since an important concentration

of gas can be stored on long term; gas hubs repre-

sent therefore the key element in Ukraine’s energy

diversification efforts. Establishing a new gas hub

does not mean a complete end of Russia-originated

gas in Ukraine but it is nevertheless an important

limitation to Russia’s influence over Ukraine’s en-

ergy sector.

A large volume of gas traded in the hub will assure

that there will be a sufficient amount of gas supply

for Ukraine’s domestic consumption and that there

shall not be any additional worries whether the

country will have a sufficient amount of gas for win-

ter heating seasons. Moreover, the withdrawal from

LTCs and the implementation of gas-on-gas com-

petition policies will push gas prices further down

and thus alleviate the financial burden bestowed

over the country.1 However, there is a long road to

go. Ukraine did not undergo any major reforms on

gas market liberalization before the Revolution of

Dignity and it has to cope with the liberalization of

gas market only now. Ukraine has therefore to push

itself towards the completion of substantial reforms

on liberalizing its energy sector and must create a

competitive business environment for gas produc-

tion, transport and trading.

Besides the economic advantage, establishing a

new gas hub will have a very important political im-

pact. Ukraine showed after the tumultuous events

of 2013-2014 its determination to end with the till-

then reigning status quo, based on the constant

switching of its favour between the European Un-

ion and the Russian Federation. Ukraine finally reaf-

firmed itself as a country willing to join the EU and

1 In 2015, then-Prime Minister Arseniy Yatsenyuk stated that despite Gazprom had offered a discounted price of $212 per thousand cubic me-ters, supplies from Europe were even cheaper and cost $200 per tcm. Leonid Bershidsky, “How Ukraine Weaned Itself Off Russian Gas”, Bloomb-erg View, published 12 Jan 2016, https://www.bloomberg.com/view/arti-cles/2016-01-12/how-ukraine-weaned-itself-off-russian-gas

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13Policy Brief

to commit itself to adopting reforms in accordance

with the EU acquis communautaire. The creation of

a gas hub would not only create a Ukrainian regional

gas market but would also allow for Ukraine’s fur-

ther integration into the European Energy Commu-

nity. The gas hub will be beneficial for the European

Union too: a successful development of the gas hub

will not only further weaken Gazprom’s still-lasting

commercial power over the European gas market

but will assure energy security for the neighbouring

EU countries (Hungary, Poland, Slovakia, and Roma-

nia) on a long term. Creating a new gas hub will thus

help progressively establish Ukraine as an important

political power in the region and will strengthen its

image as a politically responsible country willing to

achieve stability and prosperity.

Finally, a further liberalization of Ukraine’s gas mar-

ket will help in achieving even more transparency in

the energy sector. Despite the fact that Ukraine has

done already a lot in order to diminish the corruption

and power of pro-Russian Ukrainian oligarchs in the

energy sector, some space for political and economic

manipulation unfortunately still exists. However, the

Ukrainian government must show its willingness to

implement the necessary measures to achieve im-

portant levels of transparency if it wants the gas

hub project succeed, even despite the objections

of pro-Russian officials still present in the Ukrainian

government and ministries. The creation of the gas

hub will therefore greatly help in efforts to increase

transparency in Ukrainian gas market.

4. Where to create a new gas hub?

The most important question to be raised about gas

hub launch in Ukraine is whether the new gas hub

should be physical or virtual and where it shall be

created. This report argues that due to the specific

allocation of Ukrainian gas pipelines and gas stor-

ages, the new gas hub shall work as a physical hub

and shall be located in the west of Ukraine.

Currently, Ukraine disposes of 12 gas storages in its

territory (one additional storage facility is located in

the occupied Crimea) with a total current storage ca-

pacity of 31.3 bcm.2 Five storages are concentrated

in the western Ukraine (Bilche-Volytsko Uherske,

Uherske XIV-XV, Oparske, Dashavske, Bohorod-

chanske) with a total capacity of 25.32 bcm what

represents 84% of the country’s storage capacity.

Gas storages at the east of the country are aimed

primarily to secure Kyiv’s domestic consumption,

to provide gas inflow to regions focused on heavy

industry, or they are located closer to the unstable

conflict zone. In order to decrease any costs linked

to the gas transportation and avoid the unstable

Eastern region of Ukraine, it is desirable to establish

a new gas hub in the western Ukraine at the proxim-

ity of EU member states.

The Bilche-Volytsko-Uherske gas underground

storage facility represents an optimal spot for the

creation of a new gas hub. With 17 bcm of storage

capacity and being the westernmost among all of

Ukrainian facilities, it is the largest underground gas

storage in Europe3 and offers the best possibility for

the concentration of multiple sources of gas. Gas

pipeline infrastructure is well-developed in this re-

gion thanks to the presence of the

interconnection of several pipelines (Soyuz, Prog-

ress, Urengoy-Pomary-Uzhgorod, Kyiv-Zakhidnyi

Kordon I/II, Dolyna-Uzhgorod, Ivatsevychi-Dolyna

I/II/III). The Bilche-Volytsko-Uherske gas under-

ground storage has therefore a big potential to

become an important European crossroad through

which gas will be able to flow into and from the Eu-

ropean Union. It will play an important role in sup-

plying gas to over all the territory of Ukraine thanks

to the gas interconnection points with Poland (with

capacity of up to 1.5 bcm per annum), Hungary (up to

5.5 bcm per annum), and Slovakia (up to 15 bcm per

annum).4

2 “Gas Storage”, utg.ua, http://utg.ua/en/utg/gas-transportation-system/underground-gas-storage.html, accessed 8 October 2016.

3 Pyotr Vorobyov, “Ukraine’s Gas Transmission System: Problems and Pros-pects”, strategic-culture.org, published on 2 July 2015, http://www.stra-tegic-culture.org/news/2015/07/02/ukraine-gas-transmission-system-

problems-and-prospects.html 4 “Ukraine’s Gas Sector Reform: A Future Win-Win for Ukraine and Europe“,

Policy Brief by DiXi Group, published 10 May 2016, http://dixigroup.org/eng/publications/ukraines-gas-sector-reform-a-future-win-win-for-ukraine-and-europe/

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14Ukrainian gas hub – a chance for Europe

Since this gas storage facility is big enough to ac-

commodate substantial amount of gas and other gas

storage facilities in Ukraine are not full even during

the winter season, a physical hub is preferable to a

virtual gas hub since the latter would have to cope

with complex administrative rules over a large terri-

tory. Creating virtual hub is equally not desirable for

the reason that Ukraine does not need any gas entry/

exit points on the north and east of the country (Rus-

sia and Belarus being dominated by Gazprom) as the

gas market will focus to the west of the country.

The other four gas storages located in the Western

Ukraine will be used mainly for supplying domestic

demand in Ukraine, especially for the winter heating

season, but may be used as the storages of last re-

sort in extreme cases if the Ukrainian domestic gas

demand permits so. So far, there has been no im-

pediments to pipelines in the areas currently under

state of hybrid war. It is highly improbable that pro-

Russian separatists would attack these pipelines as

it is in the Russian interest to keep flows of gas to

Europe safe and unharmed; doing otherwise would

constitute a setback for Moscow. However, in this

highly unstable region, this possibility cannot be to-

tally excluded.

The new gas hub could operate on a basis compa-

rable to the Henry Hub in the US: it will function as

a physical hub where several gas supply pipelines

physically interconnect themselves and where buy-

ers are allowed to purchase gas. For this reason, a

completely new pipeline infrastructure shall be con-

structed in order to assure an appropriate intercon-

nectedness between the supply pipelines and the

pipelines used to distribute the gas after the deal.

The Bilche-Volytsko-Uherske storage disposes of

excellent interconnection capability with 291 gath-

ering wells in Bilche-Volytske and 50 wells in Uher-

ske deposit5, which would – in the case of a high

5 N. Prytula, R. Boroviy, M. Prytula, O. Khymko, “Matematichna model Bilche-Volitskoho Pidzemnoho Skhovyshcha Hazu (Mathematic Model of the Bilche-Volytsko-Uherske storage, own translation), 2010, accessed on October 12, http://www.nbuv.gov.ua/old_jrn/natural/Vnulp/Komp-nauky/2010_686/27.pdf

UKRAINE’S GAS STORAGES AND THEIR BALANCE*

* Image taken from http://naftogaz-europe.com/article/en/englstorage, accessed 16 October 2016

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15Policy Brief

diversity of gas supply inflows – offer the capacity

needed to accommodate gas of all the different ori-

gins. The construction of additional infrastructure

for interconnection may prove as costly but it can

nevertheless help in achieving significant decrease

on gas purchase on a long-term basis.

The gas hub must assure to acquire a sufficient

number of compressor stations in order to assure

that any gas purchased by Ukrainian suppliers will

be able to flow anywhere in the country. Since the

target audience of the gas hub is both Ukrainian do-

mestic market and the countries of the European

Union, the gas hub must assure that there will be

enough pipeline capacity to deliver gas to both the

East and West, pipelines with bi-directional flow

would be therefore more than desirable. It is nev-

ertheless important to underline the fact that gas

pipelines and gas storages in Ukraine must be kept

in best condition; Ukrtransgaz together with the au-

thority managing the new gas hub must assure that

both pipelines and gas storages are well maintained

and regularly tested for any potential flaws. Any dis-

ruption in gas inflows or outflows would severely

damage gas trading and would harm the confidence

of traders in Ukrainian gas trade.

5. Creating a Network Code for new gas hub

It is necessary to create a Network Code for the

new gas hub that shall be applied only to the ju-

risdiction of the hub. This code shall contain all the

necessary provisions for the transmission of traded

gas in compliance with the Law “On the Natural Gas

Market”, mainly the non-discriminatory access to the

local grid of interconnected pipelines and provisions

in alignment with the rules presented in the Third

Energy Package on balancing gas volumes in un-

derground storage facilities. This Code should also

establish an overseeing Authority responsible for

a good of management of the grid. It is preferable

that this Authority will be independent from Nafto-

gaz (if possible, it should be independent even from

Ukrtransgaz which should not have more than 49%

stake in order not to interfere in any way with the

functioning of the hub). Should not the new gas hub

authority be independent, any non-transparent gas

flows will create space for manipulations and thus

decrease the hub’s credibility. However, cooperation

with Ukrtransgaz should not be excluded since the

hub will serve also as an important gas supply for

Ukrainian domestic gas and Ukrtransgaz shall be

responsible for managing transport of gas into and

out of the gas hub.

The gas in the Bilche-Volytsko-Uherske storage fa-

cility will have two main objectives: to serve as gas

supply for the consumption in Ukraine and to serve

also as an emergency “package” in the case of high

gas demand. For this reason, the Resolution “On

Approval of the Code of Gas Transmission System”6

should introduce new provisions concerning the co-

operation with the gas hub Authority in which new

inter-storage balancing mechanism will be intro-

duced. In the period of high gas demand (e.g. heat-

ing season), the balancing mechanism will activate

independently of the Gas Hub Authority the pur-

chases of gas for the Ukrainian hinterland to cover

any eventual gas shortages without disrupting gas

trades already made or trades being dealt with (the

main idea is that suppliers will purchase gas without

any disruption of the market but will take use of the

existing gas in the hub for domestic purposes).

Further additions shall equally be made to the

NEPURC resolutions “On Approval of the Code of

Gas Storage Facilities”7 and “On Approval of the Code

of Gas Distribution Systems” 8. These additions shall

introduce provisions on the separation of the hub’s

gas storage facilities from Naftogaz or the future

storage operator, as the new gas hub will represent

a new independent jurisdiction. In order not to hin-

der interests of foreign customers in storing their

gas in Ukraine, a non-discriminatory access of third

parties to the gas storage facilities within the gas

hub should be introduced into the resolution. The

modified resolutions should also contain new provi-

sions linked to the technical aspects of the gas hub,

such as the functioning of long and short term gas

storage, gas pooling, title transfer etc.

6 The resolution can be found in Ukrainian language here: http://zakon5.rada.gov.ua/laws/show/z1378-15

7 The resolution can be found in Ukrainian language here: http://zakon3.rada.gov.ua/laws/show/z1380-15

8 The resolution can be found in Ukrainian language here: http://zakon0.rada.gov.ua/laws/show/z1379-15

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16Ukrainian gas hub – a chance for Europe

6. Trading in Gas Hub

So far, two energy exchanges involved in natural gas

trading exist in Ukraine. The Commodity Exchange

Ukrainian Energy Exchange (CE UEEX) trades in all

energy commodities available in Ukraine (coal, gas,

oil, electricity, biomass). 9 UEEX was created in 2010

and it is an open trading platform pricing the prod-

ucts on the basis of fair price discovery between

supply and demand using “BETS” private electronic

system for trading. Over 360 companies are mem-

bers on the exchange, are the market of oil products

is considered as the liquid one. As for the gas mar-

ket, according to UEEX, it is not liquid in Ukraine.

Another exchange is Ukrainian Gas Exchange (UGX),

created by Ukraine’s investment bank Dragon Capi-

tal which started gas futures trading on 4 August

2016. However, the Ukrainian Gas Exchange website

offers very little information on its trading.10

Among the issues in the gas market for foreign

traders are problems with payments and booked

capacities of gas transmission system. Currently,

it is one of profound obstacles to expanding the

number of gas traders in the Ukrainian market. In

9 CE UEEX’ website: https://www.ueex.com.ua/eng/ueex/ 10 UGX’s wevsite: http://www.ugx.com.ua/

addition, barriers include the flow of documents,

as there is still no transition to EDI (electronic data

interchange) system, which would simplify market

access to international traders who used to work

with this system. Despite these concerns, the ex-

change representatives are interested in the crea-

tion of gas hub and expressed willingness to par-

ticipate in the activity11.

This report argues that trades done at the new gas

hub should be indexed to the existing exchange(s).

Such linkage will bring several benefits: 1) there

will be no additional need to create new exchange

unique only to the gas hub trading; 2) there are

established exchanges with a good credibility, 3)

no additional on-line trading platforms will not be

needed for the trading. However, it is desirable to

create similarly to the Network Code a document

on short term trading in the gas hub. The document

shall contain all the necessary provisions which es-

tablish a proper functioning of the gas hub within

the exchange and all the procedures and informa-

tion necessary for traders, such as the confirmations

on purchase, proceeding on billing and payment,

pricing, termination of contracts, liabilities, warran-

ties and force majeure.

11 Interview with CE UEEX representatives

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17Policy Brief

Moreover, a special clearing house within the ex-

change shall be created and shall cooperate with

the new gas hub transmission authority in gas bal-

ancing. The exchange shall equally create standard-

ized gas trade contracts to be traded on the spot

market with futures with a specified delivery date.

The creation of the gas hub exchange is thus cru-

cial for a fully liberalized Ukrainian gas market: not

only it will greatly enhance the transparency of the

Ukrainian gas sector but it will inject the liquidity

needed to gas trading.

FINLA

ND

NORWAY

SWEDEN

DENMARK

North sea Baltic sea

ESTONIA

LATVIA

LITHUANIA

GERMANY POLAND

CZECH REPUBLIC

MOLDOVA

SLOVAKIA

A USTRI A

BELGIUM

HUNG ARY

UN

ITED

KIN

GDOM

IRELAND

ROMANIA

SERBIA

BULGARIA

FRANCE

CROATIA

ITALY

GREECE

PORTU

GAL

SPAIN

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18Ukrainian gas hub – a chance for Europe

THREATS & OPPORTUNITIES TO GAS HUB PROJECT

1. Legislation on Ukrainian TSO unbundling is still ineffective

Ukraine already did a great leap forward by adopting

the Law No. 2250 “On the Natural Gas Market”, rati-

fied by Verkhovna Rada on 9 April 2015 and signed

by President Petro Poroshenko on 5 May 2015, with

most of the legislation taking effect from 1 October

2015. By early 2016, about 50 bylaws were adopted

in order to make the Law on the Natural Gas effec-

tive1. The primary objective of this law is clear: to lib-

eralize Ukrainian gas market, previously ultimately

dominated by Naftogaz and DSOs, and to harmonize

it with existing European energy legislation in order

to promote further energy integration of Ukraine

into the European Union. It thus follows the Energy

Community’s Third Energy Package and notably the

EU directives on functioning of natural gas inter-

nal market and conditions for access to natural gas

transmission networks. The law calls for TSO un-

bundling, gas market operation and regulation, non-

1 “Ukraine’s Gas Sector Reform: A Future Win-Win for Ukraine and Europe“, Policy Brief by DiXi Group, p. 3

discriminatory third party access to the gas network,

market gas pricing and energy security.2 Among oth-

er things, the law creates a viable legal environment

for introducing a foreign investor to the gas TSO, as

well as sets strict requirements effectively preclud-

ing Russian companies from such partaking.

The law did not impose any concrete measure how

to unbundle Ukrainian gas supply and transmission.

Instead of this, two alternatives for unbundling were

proposed: 1) Ownership Unbundling (OU) where pro-

ducing and supply companies are not allowed to

own majority stake in Ukrainian gas transmission

networks and vice-versa (the law stipulated that OU

would be applied by default) and 2) the Independ-

ent System Operator (ISO) model where Ukrainian

gas transmission network will remain in possession

of Naftogaz but being operated by a third party in-

dependent of Naftogaz.3 Only on 01 July 2016, Cabi-2 The Law on the Natural Gas Market may be found in English version at:

http://www.naftogaz.com/files/Information/Ukraine%60s%20Natu-ral%20Gas%20Market%20Law_engl.pdf

3 The option for Independent Transmission Operator which could be in pos-session of energy groups but would have to exist as a separated legal entity, was not mentioned in the law.

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19Policy Brief

net of Ministers of Ukraine published the Resolution

No. 496, which endorsed the ownership unbundling

model, though with specific reservations necessary

for substantial distinguishing of powers between

two Ministries as much as alienation of the gas pipe-

line system from the state ownership remain legally

prohibited 4. Prior to the publication, the resolution

had been reviewed by the Energy Community Secre-

tariat.5 The ownership unbundling is done in accord-

ance to the Energy Community’s Directive 2009/73/

EC, which states that

“Under ownership unbundling, to ensure full inde-

pendence of network operation from supply and

production interests and to prevent exchanges

of any confidential information, the same person

should not be a member of the managing boards of

both a transmission system operator or a transmis-

sion system and an undertaking performing any of

the functions of production or supply. For the same

reason, the same person should not be entitled

to appoint members of the managing boards of a

transmission system operator or a transmission sys-

tem and to exercise control or any right over a pro-

duction or supply undertaking.“6

The factual implementation of the chosen unbun-

dling model is materially complicated by the ongo-

ing arbitral proceedings between Naftogaz and

Gazprom since terms and implementation of the

current gas transportation contract is in the mid-

dle of the parties’ claims. Nevertheless, both the

Energy Community Secretariat and the Ukrainian

government have provided for appropriate meas-

ures in the unbundling model. However, the Ministry

of Economic Development and Trade of Ukraine did

a controversial move in subordinating Ukrtransgaz

without any discussion what is a direct breach of

4 Unofficial English translation of this resolution can be found at http://www.naftogaz.com/files/official_documents/CMU-unbundling-resolu-tion-No496-ukr-eng.pdf.

5 The text of this review can be found at https://www.energy-community.org/portal/page/portal/ENC_HOME/DOCS/4140379/32675252E16C57A6E053C92FA8C0B902.pdf

6 http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:211:0094:0136:en:PDF

the rules presented in the Third Energy Package

since both Naftogaz and Ukrtransgaz would be un-

der control of a single ministry what consequently

makes unbundling void. It was revealed that this

decision is linked with 4 bn UAH tender for the fa-

vour of scandalous businessman Konstantin Grigo-

rishyn.7 The Energy Community, along with multiple

other stakeholders and donors, expressed its dis-

satisfaction with this order and the current Ukrain-

ian Prime Minister Volodymyr Groysman pledged for

a personal handling of this situation and maintained

that a full vertical unbundling of Ukrainian TSO will

take place. Although this decision has been finally

recalled, Naftogaz was unprecedently subordinated

to the Cabinet of Ministers directly.

Moreover, on September 22, 2016, Verkhovna Rada

adopted the long-waited Law No 1540 “On the Na-

tional Energy and Public Utilities Regulatory Com-

mission”. The key objective of this law is clear: to

establish an independent state Regulatory Author-

ity which will monitor and control energy and public

utilities sector. This Authority will be responsible for

a fair competition in energy markets and the correct

implementation of reforms in the energy sector. The

members of the Authority shall be chosen by an ad

hoc Selection Committee, which shall consist of 5

people (2 appointed by the President, 2 by the Par-

liament and 1 by the Government upon the recom-

mendation of the Ministry of Energy).8

Even if Ukraine’s gas market is currently in the state

of transition towards a liberalized gas market, there

is still a long way to go and as it was shown above,

the road is way too bumpy. The Ukrainian gas mar-

ket legislation is still under heavy influence of po-

litical and economic actors interested in acquiring

personal gains from the efforts for liberalization.

7 ”ANALYSIS OF SITUATION OCCURRED WITH REGARD TO THE MINISTRY OF ECONOMY’S DECISION TO AMEND THE CHARTER OF NJSC “NAFTOGAZ OF UKRAINE” RELATING TO THE CONTROL OVER PJSC “UKRTRANSGAZ”, Dixi Group, published on 16 September 2016, http://www.slideshare.net/uaen-ergy/dixi-groups-comment-regarding-the-situation-with-ukrtrasgaz.

8 ”Ukraine: Law on Energy Regulator Finally Adopted”, cms-lawnow.com, published on 7 October 2016, http://www.cms-lawnow.com/ealerts/2016/10/ukraine-law-on-energy-regulator-finally-adopted

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20Ukrainian gas hub – a chance for Europe

Although the above-mentioned laws are significant

efforts, their successful implementation and avoid-

ance of particular interests is indispensable for a

creation of fully liberalized gas with a high level of

transparency without which the confidence of trad-

ers – and thus the new gas hub project – will fail. It

is thus in the interest of competent ministries and

authorities to speed up this project and make it as

transparent as possible.

2. Nord Stream 2 and Turkish Stream may represent threat to Ukrainian gas system

Russia pushes further for the diversification of its

gas supply routes in order to achieve complete de-

tour of the Ukrainian territory and to secure its gas

supply for European market. Bypassing Ukraine is

based purely on political interest without any eco-

nomic rationale: Russia wants to deprive Ukraine of

its leverage over the Russian gas flowing through

her territory, to eliminate her revenues from the gas

transport and thus to diminish its political power. In

order to mask political motivations behind these ef-

forts for the detour, Russia invokes forecasts for the

growth of gas demand in Europe.9 However, as more

renewable sources are being used, the real growth

for gas in Europe remains questionable.

One of the major Russian efforts for gas supply diver-

sification was the South Stream project. The South

Stream pipeline was projected to flow through an un-

dersea pipeline located in the Black Sea and to enter

the European continent in Bulgaria, offering gas sup-

ply to all the Balkans. However, this project was met

with a disapproval from the European Union, which

argued that the construction of this pipeline would

have resulted into the increase of Russian gas mo-

nopoly position in the region. The project was then

halted in 2014 on the basis of breach of existing Euro-

pean energy regulatory measures. South Stream be-

ing abandoned, Russia pushed for several other pro-

jects aimed on re-routing its gas despite the fact that

the pipelines supplying gas to Central Europe offered

9 Mariia Melnyk, ”Opal rozbratu. Navisho Yevrosoyuz pidihrav antiukrayin-skym planam ”Gazpromu“, Yevropeyska Pravda, published 4 November 2016, http://www.eurointegration.com.ua/articles/2016/11/4/7056945/

* Source: http://www.gazprom.com/about/production/projects/pipelines/built/nord-stream2/

NORD STREAM 2*

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21Policy Brief

the shortest way to do so. Gazprom bet on two cards:

the Nord Stream 2 and the Turkish Stream.

The already existing Nord Stream 1 gas pipeline with

a capacity of 55 bcm of annual transport originates

in the Russian town of Vyborg near the Finish bor-

der, crosses the Baltic Sea and ends in Greifswald,

Northern Germany. The Nord Stream 2 pipeline

would only twin the existing Nord Stream 1 pipeline,

doubling the capacity to 110 bcm. The political moti-

vation between Nord Stream 2 is to end transits of

Russian gas through Ukraine and to use Germany as

the main point for further distribution of Russian gas

in Central Europe. Even if several European coun-

tries called for the implementation of the project

(with the strongest voice for the project from Ger-

many), the EU Vice-Commissioner for Energy, Maroš

Šefčovič, expressed his dissatisfaction with the

project, arguing that construction of Nord Stream 2

would go directly against the principles of European

gas supply diversification mentioned in the Third En-

ergy Package.10

The position of the European Commission became

shadier with the decision of the EU Commissioner for

Regulation, Margrethe Vestager, to allow Gazprom

to use more capacity in the adjacent OPAL pipeline,

which is vital for the distribution of gas in Germany

and Central Europe11 (Nord Stream 1 has been trans-

porting until now only a slightly more than it is the

half of its capacity12). The Nord Stream 2 project did

10 Georgi Gotev, ”Sefcovic embarks on third trilateral gas talks on Ukraine”, euractiv.com, published on 31 August 2016, accessed 30 September 2016, https://www.euractiv.com/section/energy/news/sefcovic-embarks-on-third-trilateral-gas-talks-on-ukraine/

11 Rachelle Toplensky, Jack Farchy, Henry Foy, ”Gazprom and Brussels agree to settle long-running dispute”, ft.com, published 26 October 2016, htt-ps://www.ft.com/content/9467b568-9b85-11e6-8f9b-70e3cabccfae

12 ”Estonia, 7 other countries send letter to Juncker on Nord Stream 2”, news-postimees.ee, published 17 March 2016, accessed on 8 October 2016, http://news.postimees.ee/3622797/estonia-7-other-countries-send-letter-to-juncker-on-nord-stream-2

*Source: http://www.gazprom.ru/about/production/projects/pipelines/built/turk-stream/

TURKISH STREAM

*

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22Ukrainian gas hub – a chance for Europe

not seem to be viable but doubts about the firmness

of the EU Commission’s commitment to Ukraine’s

energy security arise after this decision. However, it

is possible to expect that the countries of Central

Europe will object the OPAL. The countries of Cen-

tral Europe (Slovakia, Hungary, and Poland) will fight

for further transit of Russian gas through their terri-

tory in order to keep their transit fee revenues; they

would also sue the European Commission for any

further decisions favouring Nord Stream 2. Moreo-

ver, Polish regulator has made already a serious

blow to the Nord Stream 2 project by arguing that

the new pipeline would be in breach with the Polish

competition law.13

Gas will nevertheless continue to flow through

Ukraine. Several countries of Central Europe have

still long-term ship-or-pay contracts with Gazprom

(Slovakia until 2028 and Poland until 2022) and

failures with delivery would prove too costly for

Gazprom.14 It is thus possible to argue that despite

the stated Gazprom’s rejection to continue to trans-

port its gas via Ukraine, gas will continue to flow,

albeit possibly in diminished volumes.

Turkish Stream aims to replace the cancelled South

Stream project: the South Stream pipelines will not

flow to Bulgaria but to Turkey which is not a member

of the European Union. Consequently, the Russian

gas in Turkey is planned to be dispatched over the

countries in the Balkans via Greece. The project was

announced by the Russian President Vladimir Putin

on 1 December 2014 but was temporally halted dur-

ing the Turkish shoot-down of a Russian aircraft al-

legedly on Turkish territory in November 2015 but it

was nevertheless resumed on 10 October 2016.15

Turkish Stream as such does not aim to completely

detour Ukraine: its target countries are located in

13 Henry Foy, Jack Farchy, “Nord Stream 2 pipeline risks delays due to Pol-ish hurdle”, ft.com, published 28 July 2016, https://www.ft.com/content/e2cf7602-5411-11e6-befd-2fc0c26b3c60

14 Ladka Bauerova, “Gas-Tranit Deal Shows Cost to Russia of Bypassing Ukraine”, bloomberg.com, published on 5 June 2015, http://www.bloomb-erg.com/news/articles/2015-06-05/slovak-gas-transit-deal-shows-by-passing-ukraine-will-cost-russia

15 Andrew Ward and Laura Pitel, “Russia and Turkey agree gas pipeline deal”, ft.com, published on 10 October, 2016, accessed on 10 October 2016, https://www.ft.com/content/52c05b6e-8f1f-11e6-a72e-b428cb934b78

the Balkans and not in the Central and Western

Europe, which constitutes the key market area for

Gazprom. However, the project leaves back-doors

opened for Gazprom: the fully built Turkish Stream

pipeline would have capacity of 60 bcm what

would give Gazprom in the case of need the pos-

sibility to detour Ukraine completely and still reach

the Central and Western European gas market. Fur-

thermore, Ukraine would lose with the construc-

tion of Turkish Stream gas flows over Ananiev-

Tiraspol-Ismail and Shebelynka-Ismail pipelines

(with total capacity of 26 bcm), supplying Romania,

Bulgaria, Greece, Turkey and Macedonia. The Eu-

ropean Commission has not pronounced itself on

Turkish Stream as it is still in the stage of studying

the case.16 Turkish Stream thus represents rather

an indirect threat to Ukraine’s energy security com-

pared to Nord Stream 2, which represents a direct

threat. However, if combined with Nord Stream 2,

Ukraine’s importance as gas transit country would

be diminished. It is therefore in Ukraine’s interest

to fight against both Nord Stream 2 and Turkish

Stream if it wishes to maintain its long-term energy

security and to keep Russian gas flowing through

its territory, the necessary condition for functioning

of the gas hub.

Establishing a new gas hub does not mean to put

end to flows of Russia-originated gas to Ukraine but

it nevertheless represent an important limitation

to Russia’s influence over Ukraine’s energy sector.

However, in order to assure gas-on-gas competi-

tion in the new gas hub, Ukraine will have to pur-

sue negotiations with the Russian Federation since

absence of Russian gas transit would decrease the

competition and cause serious damage to the gas

hub project. The negotiations between Russia and

Ukraine would be difficult, especially after the an-

nexation of Crimea and the war in Donbas. They are

nevertheless two options available for Ukraine: 1) to

convince the EU to force Gazprom to accept selling

its gas on the Ukraine’s Eastern border and in this

case, no further negotiations with Gazprom over its

16 Kostis Geropoulos, “Šefčovič : EU wants Russia’s Gazprom, Ukraine’s Nafto-gaz to honour winter protocol“, neweuope.eu, published 1 November 2016, https://www.neweurope.eu/article/sefcovic-eu-wants-russias-gazprom-ukraines-naftogaz-honour-winter-protocol/

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23Policy Brief

gas in the new gas hub would be needed; 2) to start

negotiations with German officials and business-

men, since modernization of Ukraine’s gas trans-

mission network is less costly than constructing a

brand-new pipeline.

3. Gas storage is unprofitable under current market conditions

Ukrainian gas storage will play crucial role in the

liberalization of Ukrainian gas market and in the

creation of the new gas hub. Ukraine disposes of 32

bcm of storage facilities which may be upgraded to

50 bcm17 and in addition, Ukrtransgaz has capacity

transportation of 140 bcm annually.18

However, the prospect for a liquid Ukrainian gas

storage markets looks currently grim on both macro

and micro level. On macro level, the demand for gas

is currently falling in Europe. Despite the fact that

gas storage business was once very lucrative in Eu-

rope, many investments in gas storages were made

all over Europe in last years and there is currently a

surplus of gas storage facilities. The over-supply of

gas in Europe significantly narrowed the spread be-

tween summer and winter prices for gas, therefore

making the gas storage business much less compel-

ling.19 The closest EU neighbours of Ukraine - coun-

tries of Central Europe (Hungary, Slovakia, Czech Re-

public and Austria) - already have a sufficient level

of their domestic gas storage facilities. These coun-

tries are located near Germany which has the high-

est level of gas storage capacity just after Ukraine.

Russia poses a problem too: Alexei Miller expressed

himself that Russia will never use Ukrainian gas

storage again due to an incident.20 It is, however,

questionable whether this statement is based on

truth but the lack of Russian gas could potentially 17 Vitalii Rybak, “Alan Riley: «Ukraine could be the main gas storage facilita-

tor for the East-Central Europe», ukrainianweek.com, published 14 March 2016, http://ukrainianweek.com/World/160497

18 http://utg.ua/en/utg/gas-transportation-system/characteristic.html, ac-cessed 14 October 2016

19 “Analysis of the Restructuring Options of NJSC Naftogaz“, World Bank, published 9 February 2016, p. 95. http://documents.worldbank.org/cu-rated/pt/928071468185344153/Analysis-of-the-restructuring-options-of-NJSC-Naftogaz

20 “Gazprom tries to discourage Europe to use Ukrainian underground gas storage facilities”, europeandialogue.eu published 3 July 2013, http://www.eurodialogue.eu/Gazprom-Tries-to-Discourage-Europe-to-Use-Ukrainian-Underground-Gas-Storage-Facilities

represent a threat to the Ukrainian gas hub where

large volumes of gas will be needed.

On micro level, the already-mentioned unbundling

of TSO will be crucial to assure transparent, reliable

and efficient gas transport over the Ukrainian terri-

tory. Ukrainian gas storages are operating on a very

low level of their technical capacity, which makes

them unprofitable, and some of the facilities might

be closed. Ukraine also lacks of quick-cycle storage

facilities, as it is too expensive to inject and with-

draw the gas in storage facilities technically difficult

and also expensive. In order to increase the profit-

ability of its storage facilities, Ukrtransgaz has risen

the entry tariffs for gas from abroad, however this

move did not help to increase their profitability and

might well even deter some investors in booking the

capacity for gas storage facilities.21 Moreover, there

is a general complain to Ukrainian gas that even

if entry tariffs for gas from abroad have been set,

there are no exit tariffs for stored gas what greatly

hinders interests of investors in Ukraine’s under-

ground gas storage.22 The entry tariffs being already

high enough, it is advisable that with the construc-

tion of new gas hub, the entry and exit tariffs will be

lowered in order to increase the competitiveness of

Ukrainian gas transmission system and thus attract

new buyers.

Ukrainian underground storage facilities do not cur-

rently offer any competitive advantage over their

European rivals but with lower gas storage market

prices, transparent rules for transmission and a di-

versified supply of gas, they could become attrac-

tive for players in the energy field. Moreover, the

EU Vice-Commissioner for Energy Maroš Šefčovič

has already stated that Ukraine’s gas storage facili-

ties will play an important role in the integration of

Ukraine into the Energy Community.

Nevertheless, even if the short term prospects for

underground gas storage in Europe look grim, a

21 Analysis of the Restructuring Options of NJSC Naftogaz“, World Bank, published 9 February 2016, p. 98

22 “EU shippers avoid Ukrainian gas storage as no exit tariffs set“, icis.com, published 19 July 2015, http://www.icis.com/resources/news/2016/07/19/10017297/eu-shippers-avoid-ukrainian-gas-storage-as-no-exit-tariffs-set/

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24Ukrainian gas hub – a chance for Europe

study by company Naftogazbudinformatyka shows

that in longer run, the outlook for gas storage is

positive and encouraging (Paul Bieniawski, expert of

the company Zechstein Energy Storage argues that

there will be even a shortage of these facilities in 5

years23). If Ukraine wishes to monetize upon her gas

storage facilities, developing a viable gas hub will be

a positive spill-over for the attraction of buyers.

Ukraine thus still has to search for new opportuni-

ties how to take use of her gas storage facilities and

there are several options, how to do that. Ukraine

can still take advantage of storage-poor countries

(Poland, Romania) or even with far-distance coun-

tries, e.g. Turkey24. Other possible option for Ukraine

is to develop LNG re-gasification terminals in the

Black Sea and to store this gas for LNG producers

from abroad, notably the United States.

4. Opportunities for gas supply diversification remain limited for now

The Nabucco project with an ambitious capacity of

31 bcm, connecting the Caspian region with central

Europe via Turkey and the Balkans in which Ukraine

could have participated, was halted by the Europe-

an Commission. In 2005, the White Stream pipeline

sparked hopes for Ukrainian gas supply diversifica-

tion. White Stream aimed to transport Azerbaijani

gas through Georgia to either Ukraine or Romania

via a sub-sea pipeline with capacity of 32 bcm. De-

spite the fact that the European Commission or-

dered a feasibility study, no major steps to imple-

ment the project were taken since then.

The development of Liquefied Natural Gas (LNG) rep-

resents an important turn in Ukraine’s gas supply di-

versification efforts. Global gas market is becoming

truly ‘global’ with the arrival of affordable LNG which

can be – as it is in the case of crude oil - freighted to

any country with re-gasification terminals. Ukraine 23 Alla Eremenko, Leonid Unigovskiy, Evgenij Andranov “Nuzhny li evrope-

ytsam ukrainskie podzemnye khranilishcha gaza?” (Do Europeans need Ukrainian underground gas storage facilities? Own translation), gazeta.zn.ua, published 20 November 2015, http://gazeta.zn.ua/energy_market/nuzhny-li-evropeycam-ukrainskie-podzemnye-hranilischa-gaza-analiz-potencialnoy-potrebnosti-evrosoyuza-v-phg-ukrainy-_.html

24 “Ukrainian envoy: Natural gas storage at Turkey‘s disposal“, dailysabah.com, published 16 May 2016, http://www.dailysabah.com/energy/2016/05/17/ukrainian-envoy-natural-gas-storage-at-turkeys-disposal

should take advantage of the ever-developing LNG

market in order to diversify its gas supply. This could

be done by importing LNG from major global play-

ers in the field, such as the United States or Qatar.

However, Ukraine lacks any re-gasification terminals

and the prospect for building an LNG re-gasification

terminal in Odessa near the Black Sea is still too far

away, mainly due to the fact that Turkey will not al-

low LNG cargos pass through Bosporus.

For this reason, the most pragmatic solution for tak-

ing benefits of global LNG seems to use re-gasifi-

cation terminals in Poland and to transport the US

LNG into Ukraine; Ukraine is already planning con-

struction of a 99 km interconnector of 5 bcm/year

capacity (may be further updated to 8 bcm/year),

which will give Ukraine the possibility to reach the

LNG terminal in the Polish town of Świnoujście.25

This pipeline will operate in dual mode so, in the

case when Ukraine optimizes its gas balance and

increases production, or receives delivery points for

Russian gas at the eastern borders, Ukrainian gas

may be exported to Poland.

The other option is taking use of the LNG terminal in

Klaipeda, Lithuania, constructed in 2014. 26 However,

in order to get the re-gasified LNG to Ukraine, gas

molecules would have to be transported via either

Belarus or Poland. Since Belarus’ gas transmission

network is owned by Gazprom, this route does not

seem to be feasible unless some concessions (such

as for example attractive transit fees) are proposed

to Gazprom. The route through Poland is more desir-

able politically speaking though the interconnector

between Poland and Lithuania is yet to be build.27

Despite the fact that LNG supply from the Western

part of the Black Sea is quasi-locked, LNG could play

a role of Ukrainian linkage with the Caspian region if

25 “Ukraine plans to start 5 bcm/year natural gas pipeline project to Po-land”, platts.com, published 17 Jun 2016, http://www.platts.com/latest-news/natural-gas/kiev/ukraine-plans-to-start-5-bcmyear-natural-gas-26473057

26 “Ukraine asks Belarus to “Explore” Lithuanian LNG Import Possibilites, “ naturalgasworld.com, published 6 August 2015, http://www.naturalgas-world.com/ukraine-belarus-to-explore-lithuanian-lng-import-possibili-ties-24876

27 “Lithuania Extends Polish Link Bid Period”, naturalgasworld.com, pub-lished 8 July 2015 http://www.naturalgasworld.com/lithuania-extends-polish-link-bid-period-30497

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25Policy Brief

additional infrastructure is constructed. A construc-

tion of an LNG re-gasification terminal near Odessa

would help Ukraine to take advantage of developing

gas production in Caucasus (notably in Georgia and in

Azerbaijan) with natural gas being liquefied in Georgia

and then shipped through the Black Sea what would

recall the spirit of the White Stream project. 28 This

means that a liquefaction terminal would have to be

constructed in Georgia too what would necessitate

additional investment. This said, Georgia constitutes

an important part of the South Caucasus Pipeline

(SCP) that links directly to the Trans Anatolian Pipe-

line (TANAP). With a total capacity of 25 bcm per year,

abundant gas supply from the SCP could increase the

attractivity of the Ukrainian-Georgian LNG Project.

Another option how to get the Caspian gas to

Ukraine would be to negotiate with Turkmenistan

(which has the fourth largest natural gas reserves

28 Andy Tully, “Can LNG Help Ukraine?”, oilprice.com, published 16 July 2015, http://oilprice.com/Latest-Energy-News/World-News/Can-LNG- Help-Ukraine.html

in the world) and Gazprom about the eventual re-

sumption of Turkmen gas supply to Ukraine. The

eventual construction of the sub-sea Trans-Caspian

Gas pipeline with a capacity of 30 bcm linking Turk-

menistan and Azerbaijan would significantly ease

Ukraine’s access to the Turkmen gas on the condi-

tion that an LNG terminal is built in Georgia. Building

LNG terminal in the Georgian town of Kulevi is a part

of the Azerbaijan–Georgia–Romania Interconnector

(AGRI) project to deliver Caspian gas to Europe via

LNG shipping but for now, not more than a feasibility

study has been made.29

The Turkmen gas option combined with the LNG

supply from Northern Europe could thus represent

the most realistic ways to achieve abundant gas

supply and gas-on-gas competition in the planned

hub. Ukraine should not stand idle and start its dip-

lomatic and business initiative as soon as possible.

29 http://www.roconsulboston.com/Pages/InfoPages/Commentary/OilEmp/AzerbaijanGas09.html

Baltic sea

North sea

RUSSIA

NORWAY

KALININGRAD

GERMANY POLAND

BELARUS

UKRAINE

LATVIASWEDEN

DENMARK

LITHUANIA

БЕЛЬГІЯ

ESTONIA

LNG IMPORTTERMINAL:KLAIPEDA,LITHUANIA

LNG IMPORTTERMINAL:

ŚWINOUJŚCIE,POLAND

* Source: https://www.stratfor.com/sample/analysis/poland-and-baltics-find-new-energy-options

LNG IMPORT TERMINALS IN THE BALTIC SEA*

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26Ukrainian gas hub – a chance for Europe

5. Domestic consumption must be curbed to achieve energy sufficiency

Due to the Soviet legacy of abundance of natural gas

combined with the lack of innovation in the energy

sector, Ukraine is one of the most energy-inten-

sive countries in the world with the lowest energy

efficiency of households in Europe. Gas constitutes

31% of Ukraine’s primary energy consumption from

which only 3% are used for the electricity genera-

tion – the remaining 97% is used for heat genera-

tion. Rozwalka and Tongendren argue in their report

(2016) that “gas accounts for almost three-quarters

of fuel consumed by both district heating compa-

nies (DHCs) and households with private heating

systems.”30 The district heating systems remain un-

reformed since the fall of Soviet Union with only

minimal investments in energy efficiency.

However, Ukraine’s gas market diminished consid-

erably in last years. Whilst the Ukrainian gas con-

sumption reached 70-75 bcm in 2005, it plummeted

to 50 bcm in 2013 to 42.6 bcm in 2014, 33.8 bcm in

2015 and it is expected that this fall in consumption

will continue even further.31. The fall in domestic

consumption is due to the fact that Ukrainian gov-

ernment partly diminished gas subsidies32 what re-

sulted in bigger gas prices for households and con-

sequently the fall in consumption, combined with

the military conflict on the East of Ukraine, where

Gazprom supplies the conflict areas by 2-2.5 bcm

annually, and which accounted for 20% of Ukrainian

gas consumption before the war33 and the annexa-

tion of Crimea. The plummeting gas consumption is

also linked to the overall drop in Ukrainian economic

output.

Regarding future trends in domestic consumption

in Ukraine, Pirani and Yafimava argue in their report

that if an economic recovery of Ukraine starts in

2016-2017, the consumption will rise to 40-45 bcm

in the early 2020s.34 For this reason, investing into

30 Rozwalka & Tordengren (2016) p. 431 Rozwalka & Tordengren (2016) p. 1232 Rozwalka & Tordengren (2016), p. 3533 Pirani & Yafimava (2016), p. 4034 Pirani & Yafimava (2016), p. 50

Ukrainian energy efficiency is crucial in order to

curb domestic gas consumption and to reach a state

of gas self-sufficiency and eventually the state of

gas exports.

The diminishment in gas subsidies was equally im-

portant in order to increase transparency of Ukrain-

ian gas sector since these subsidies represented a

large space for political manipulation and shady con-

tracts.35 The removal of this cross-subsidization of

Ukrainian residential gas prices by cutting subsidies

of Naftogaz hoped for adding more incentives to

the development of energy efficiency measures in

Ukraine. Even if diminishing state gas subsidies will

help in economizing gas and alleviating the burden

to which the state treasury is exposed, it remains

however questionable whether they will really in-

centivize further promotion of energy efficiency. The

consumption habits have already changed and fur-

ther cuts in subsidies could result in a state where

households will be unable to pay for their bills.36

This report urges Ukraine to curb its gas consump-

tion as much as it can be promoting energy efficien-

cy measures, full commercial metering, implementa-

tion of renewable sources, and increasing public’s

awareness on wasting energy. If Ukraine’s domestic

gas consumption is decreased to a substantial level,

Ukraine will get free from import dependence and

will even start exporting its own gas. For this pur-

pose, it is equally important to raise domestic gas

production as it is discussed below.

6. Domestic gas production must be increased to a sufficient level

Increasing Ukraine’s gas production to a sufficient

level is important for two reasons: Ukraine would be

less and reliant on foreign gas and eventual Ukrain-

ian gas exports could in turn provide additional sup-

ply for the planned gas hub. Ukraine’s potential for

gas production is huge: proven gas reserves are es-

timated at 924 bcm and potential reserves around

35 Rozwalka & Tordengren (2016),p. 3736 “Gas Production in Ukraine decreased by 3% in 2015”, Naftogaz.com, pub-

lished 2 February 2016, http://www.naftogaz.com/www/3/nakweben.nsf/0/970478E2A71A6B0FC2257F4C00580C55?OpenDocument

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27Policy Brief

5.6 Tcm.37 Yet, for almost a decade, the Ukrainian

annual natural gas production has been oscillating

only around 20 bcm (19.9 bcm in 2015, even after the

annexation of Crimea by the Russian Federation).38

Several factors hindered the growth in gas produc-

tion, such as changing fiscal regime in 2015 by in-

creasing royalties to 55% for wells above 5 km and

28% for wells below 5 km what effectively ham-

pered any investments from abroad (these royalties

were decreased in 2016 again into the previous lev-

els, 29% and 14%)39, corruption, and lack of transpar-

ency in energy deals, restricted generally to compa-

nies linked to oligarchs.

In order to become totally independent of foreign

gas import, Ukrainian Energy and Coal Minister Ihor

Nasalyk at the Energy Spring 2016 Congress in Kiev

to raise gas production to 27 bcm by 2020 (the esti-

mated gas consumption volume for that year) what

became the main strategy of state-owned gas com-

pany Ukrgazvydobuvannya (UGV).40

However, substantial investments are needed in or-

der to effectively raise Ukraine’s gas production to

desired levels. Most of the Ukrainian gas reserves

are either depleted, small-scale or high-depth fields.

Ninety percent of the proven reserves are fields

with no more than 5 bcm of natural gas.41 Further-

more, projects to produce 4 bcm of natural gas

would necessitate investments of around 300 mil-

lion USD.42 Ukrgazvydobuvannya has already started

with modernization and purchase of new equipment

for exploration and development drilling thanks to

Chinese loans.43 Additional foreign investment is

needed though.

37 “Serhiy Golovnyov, “Why Ukraine is not energy independent?“, Business Censor, published on 13 September 2016

38 “Ukraine seeks to stop importing gas by 2020 - energy minister”, In-terfax.com.ua, published 27 May 2016, http://en.interfax.com.ua/news/economic/346178.html

39 Tax Code (02.12.2010 No. 2755-VI), Verkhovna Rada of Ukraine40 “Ukraine seeks to stop importing gas by 2020 - energy minister”, Inter-

fax.com.ua, published 27 May 201641 “How much largest oil and gas companies in Ukraine earn?“, Khvylia, 19

September 201642 “Is it possible to reanimate the capacity of gas production in Ukraine?“,

ICPS, 9 September 201543 “Success in Ukrgazvydobuvannya reforming process“, National Reform

Council, 18 February 2016

Ukraine should push now for strengthening coop-

eration between foreign leading production compa-

nies and favour creating joint ventures with domes-

tic producers. Ukraine has already done some effort

in order to attract foreign investors such as the Cab-

inet of Ministers decision to increase the transpar-

ency of actions for production licenses.44 It is just up

to Ukraine to continue in such efforts in attracting

investors: is estimated that with a proper level of in-

vestment, Ukrainian gas production may increase in

ten years up to 40 bcm per year.45

44 “Cabinet of Ministers adopted a reform resolution at the initiative of the State Service of Geology and Mineral Resources“, The State Service for Geology and Mineral Resources, 18 April 2016

45 Philip Vorobyov, “Making Ukraine Europe’s new gas supplier“, Petroleum Economist, 31 August 2016

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Ukrainian gas hub – a chance for Europe

28

1. A detailed study comprising design of the gas hub from the technical view should be made by the government as well as a report on cost of construction of additional infrastructure and pipelines with bi-directional flow.

2. The Gas Hub Network Code complying with laws mentioned in the report and the Third Energy Package should be developed. An Authority responsible for the gas hub management shall be established with its duties and responsibilities described in the Network Code. TSO should cooperate in the Network Code creation, as it will be important to determine duties and responsibilities of both gas hub and TSO in gas transmission.

3. Ukraine should start negotiations with exchanges on gas trading, establishment of a Clearing House for the gas hub and the possible cooperation between exchange(s) and the hub for gas balancing.

4. Ukraine should start raising awareness of countries of Central and Eastern Europe (especially Slovakia, Hungary, Poland and Czech Republic) about the benefits of gas hub and its associated trading and gas storage services. Ukraine should support all the voices and measures raised from these countries against Gazprom’s actions threatening the implementation of the Third Energy Package. Ukraine should con-tinue in its initiative to get pipeline access to the LNG re-gasification terminals in the Baltic Sea.

RECOMMENDATIONS

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Policy Brief

29

5. Ukraine should start negotiations with German officials and executives in order to achieve mutual understanding of Ukrainian energy issues. Ukraine should make German public aware of the business benefits linked to gas hub trading and to con-vince officials that modernizing Ukrainian gas transmission system is far less costly than investing in a completely new pipeline system.

6. Ukraine should explore with Georgia possibilities for LNG shipments as well as to start negotiations on gas supply from Azerbaijan and Turkmenistan, crucial for assuring gas-on-gas competition in the planned hub. At the same time, Ukraine should also approach Gazprom as such partner, which could benefit from the de-velopment of gas hub. With the increased LNG supply from the United States and Qatar to the European markets, Gazprom may be willing to keep its market demand secure and to make some concessions.

7. Ukraine should promote energy efficiency in order to curb domestic gas consump-tion by raising public awareness on energy waste, introduce new tools and incen-tives to save energy. At the same time, Ukraine should strive for attracting foreign investment needed for increase in domestic production.

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Ukrainian gas hub – a chance for Europe

30

Alla Eremenko, Leonid Unigovskiy, Evgenij Andranov “Nuzhny li evropeytsam ukrainskie podzemnye khranilishcha gaza?” (Do Europe-ans need Ukrainian underground gas storage facilities?), gazeta.zn.ua, published 20 Novem-ber 2015, http://gazeta.zn.ua/energy_market/nuzhny-li-evropeycam-ukrainskie-podzemnye-hranilischa-gaza-analiz-potencialnoy-potreb-nosti-evrosoyuza-v-phg-ukrainy-_.html

”ANALYSIS OF SITUATION OCCURRED WITH RE-GARD TO THE MINISTRY OF ECONOMY’S DECI-SION TO AMEND THE CHARTER OF NJSC “NAF-TOGAZ OF UKRAINE” RELATING TO THE CON-TROL OVER PJSC “UKRTRANSGAZ”, Dixi Group, published on 16 September 2016, http://www.slideshare.net/uaenergy/dixi-groups-comment-regarding-the-situation-with-ukrtrasgaz

“Analysis of the Restructuring Options of NJSC Naftogaz“, World Bank, published on 9 February 2016, p. 95. http://documents.worldbank.org/cu-rated/pt/928071468185344153/Analysis-of-the-restructuring-options-of-NJSC-Naftogaz

Andrew Ward and Laura Pitel, “Russia and Tur-key agree gas pipeline deal”, ft.com, published on 10 October, 2016, accessed on 10 October 2016, https://www.ft.com/content/52c05b6e-8f1f-11e6-a72e-b428cb934b78

“Cabinet of Ministers adopted a reform resolu-tion at the initiative of the State Service of Ge-ology and Mineral Resources“, The State Service for Geology and Mineral Resources, 18 April 2016

“Conceptual design for a virtual gas hub(s) for the east coast of Australia”, FTI Consult-ing, December 2015, http://www.aemc.gov.au/getattachment/98035b44-a513-4d34-a5a0-9048b7166db3/FTI-Consulting-%E2%80%93-Conceptual-design-for-a-virtual-g.aspx, p. 37, 38

”Estonia, 7 other countries send letter to Juncker on Nord Stream 2”, news-postimees.ee, pub-lished 17 March 2016, accessed on 8 October 2016, http://news.postimees.ee/3622797/esto-nia-7-other-countries-send-letter-to-juncker-on-nord-stream-2

“EU shippers avoid Ukrainian gas storage as no exit tariffs set“, icis.com, published 19 July 2015, http://www.icis.com/resources/news/2016/07/19/10017297/eu-shippers-avoid-ukrainian-gas-storage-as-no-exit-tariffs-set/

“Gas Production in Ukraine decreased by 3% in 2015”, Naftogaz.com, published 2 February 2016, http://www.naftogaz.com/www/3/nakweben.nsf/0/970478E2A71A6B0FC2257F4C00580C55?OpenDocument

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