Gas interconnection

In December, I blogged about the peculiar pricing rules for the gas interconnector with Scotland. (The current rules would grant substantial market power to importers of LNG.

The CER has been aware of this for a while, and has now published a draft decision. The proposal boils down to the following elements:

  1. The interconnector will be moved, legally, from offshore to onshore. It remains to be seen that this would satisfy the European Commission, which is not happy either about the current regime.
  2. Interconnector capacity will be auctioned.
  3. There is a reserve price for the auction.
  4. The reserve price is the long-run marginal cost.
  5. If the auction do not cover the costs of the pipe-formerly-known-as-the-interconnector, the difference will be split over ALL gas suppliers.

Shannon LNG is understandably cross. They publicly fume about point 5, which will impose a cost on them that rises as they are more successful, but privately they must have hoped that the rules would not change. While I have argued that the rules should change, the current proposal can easily be spun as the regulator protecting a state-owned company from a private competitor.

Point 4 is worrying too. In the decision document, the CER goes back and forth between OPEX for the reserve price and OPEX+CAPEX. In the end, they opt for OPEX+CAPEX. Essentially, they propose to perpetually reward Bord Gais for what increasingly looks like a bad investment decision in the past.

Nothing has been set in stone yet. Let us hope that the CER will reconsider.

22 replies on “Gas interconnection”


Many thanks for posting on this. Just one minor point of clarification. It isn’t just that “[t]he current rules would grant substantial market power to importers of LNG”; they would also grant subtstantial market power to the Corrib Consortium. Indeed, both parties would be competing to secure this market power and its exercise would be constrained.

But we need to be clear about what is really at issue here. In 1996/97 the then government, the relevant department and BGE went though an exercise ‘Gas 2025’ to decide on future gas infrastructure. LNG imports were in the mix at the time, but they was quickly dismissed without adequate consideration because the exercise rapidly descended into an arm-wrestle between the then owners of the system in Northern Ireland and BGE as to who would build the next pipe from Scotland. BGE won and so we are where we are.

Around 10 years ago LNG imports emerged as a viable concept and it has been developed systematically as a project which is now approaching the atge of a Final Investment Decision. Ever since the concept surfaced, governments and the Quadrumvirate (the Department, the CER, the ESB and BGE) have welcomed the project through gritted teeth, but have examined and explored every option to kill the project because it reveals the second interconnector to be the bad investment decision it was all along.

The objective of this exercise by the CER is to kill the LNG import project for once and for all. Some collateral damage will be visited on the Corrib Consortium, but the Government and the Quadrumvirate reckon that they have sunk so much cost they will accept the limited additional pain.

The CER is sounding extremely smug that its latest bit of ‘magic’ will do the trick. It is a very cleverly constructed and innovative decision. It gives the impression that all the angles have been covered. But it has a fatal flaw – and, potentially, a second – that will scupper its cunning and well-laid plans.

A consultation period has been opened until a final decision will be made in the middle of next month and a public meeting is scheduled in the Dublin on 1st March. This consultation exercise will be the same as the usual farcical process in which the CER – and all other economic regulators – indulges. Irrespective of what facts, evidence or analysis are advanced that call into question the case the CER is presenting, the CER will simply dismiss or ignore it all and charge ahead.

It is highly likely that the affected parties will have no option but to initiate legal action in Ireland (and, possibly, at the EU level). It is then that the fatal flaws will be revealed – because these are the only forums in which they can be It should be fun. It may be the case that the Government actually believes the fiction that the only policy and regulatory dysfunction was in the areas of banking supervision and financial regulation – and that everything is hunky-dory in all other sectors. This could be a big eye-opener for it.

It looks to me as if what seems to be a standard prescription that the public should take responsibility for volume risks in major infrastructural investments is crucifying us so often that we badly need a rethink.

It’s doing for us on toll roads. It’s threatening to do for us on incineration in Dublin. It’s shortly going to be doing for us on renewable energy. The energy regulator now wants it to do for us on gas transport.

A variant on the same idea – the public taking responsibility for the contingent liabilities of structurally important businesses – has shafted the whole country through the banks.

Perhaps the theory is sound, but we now have compelling evidence that those parts of the public service responsible for protecting us against the risks that it poses systematically make choices that are against the public interest.

We need a deep rethink on this. While the rethink is underway, the energy regulator should stay off the back of private enterprise seeking to bring us the cheaper energy that is needed badly by homes and businesses.

Bord Gais Networks states in its submission that the new tariff structure will bring savings of between €25m and €45m /p.a. to the gas consumers. Irrespective of whether or not the intial investment was bad, this has to be good news for consumers. Why should consumers pay twice for an investement be it good or bad? isn’t once enough?

Then, Paddy Power, Managing Director of Shannon LNG (owned by Hess LNG which is registered in the offshore tax haven of the Cayman Islands) informed Kerry County Council in Tralee yesterday that the tariffs would cost his company €75m p.a. (or, in other words, €1billion over 13 years). Does this not prove that the Hess business model was based on a price monopoly as it will now not be guaranteed market share? To gain market share it will have to lower its prices to compete with UK suppliers. This proves without a shadow of a doubt that, whatever the weaknesses of the current pricing regime, the new tariff structure will bring increased competition and a downward pressure on prices. I mention offshore tax haven Cayman Islands to highlight the question I have in my mind about why on earth should I feel sorry for a company that might never pay tax here anyway. At least Bord Gais pays dividends to the State (€30 million in 2010 I believe), not to mention tax. If there was no interconnector then Shannon LNG and Shell’s prices would hit the roof and bring no long term investement in strategic infrastructure as happened in the Telecoms sector when Eircom was sold off. Also, let’s not forget, while I am at it, that gas is after all a fossil fuel. Why all this concern for a fossil-fuel multinational from a tax haven while the renewable energy sector (with our obligations approaching 2020) has come to a complete standstill due to what I believe is huge meddling by the fossil fuel sector?

@John A.,

You should take the sound-bites containing big numbers that people broadcast with a pinch of salt. The basis for the numbers advanced by BGN is unclear, but the only interpretation I can put on them is that the higher number is the extra cost that would be imposed on consumers if the current IC tariff structure were retained and both Corrib and Shannon LNG were supplying gas. The lower number presumably relates to the extra cost with Corrib on its own. It’s all a bit of nonsense really, because the IC tariff structure could not be left as it is and these costs would never be imposed. So these are purely theoretical savings. The costs would never be imposed, so they’d never be saved.

It’s a bit like BGN or the ESB Networks going in to the CER and asking for revenues well in excess of what they require. The CER cuts them back to the levels they would settle for – and which would still be in excess of what they get – and it allows the CER to blow its trumpet about how much money it has saved for consumers. But there has been no real saving.

It’s all part of this wonderful optical illusion that is spun to conceal the fact that final consumers are being gouged right, left and centre.

And as for this €75 million a year you claim Paddy Power is asserting this latest bit of ‘magic’ by the CER will cost him, I’m not too sure where this comes from. But I have an idea.

The total annual revenues for the transmission network (inc. the ICs) awarded by the CER is around €170 million. The CER is proposing that 50% of this, say €85 million, will be recovered in entry charges. So , down the road, when Corrib has come and gone, I could see Shannon LNG supplying most of the market upto the NBP price plus the unit recoverable cost of the ICs (a very small number) and paying the lion’s share of this €85 million (which will increase annually broadly in line with inflation).

In any event, the wheels will come off the CER’s cunning plan eventually, so I wouldn’t let the blood pressure increase too much.


I expect you’re right. The Corrib Consortium has sunk so much cost and waited so long to recover it that they will operate at the technical maximum field depletion profile and pump out as much gas as quickly as possible. All they will want is gas sales revenue, as much as possible, as quickly as possible. They will have a headstart on Shannon LNG – if it goes ahead. And, if or when Shannon LNG, comes on, they will, as you say, take the price available.

But it would be good to have them both competing to supply gas below the NBP plus price without being forced to bear the costs of a stupid investment decision made by someone else.

Mulling this over through the day, it struck me that we should now be planning for substantial deregulation of the import of gas into Ireland.

As long as it was a capital intensive business that required planning of pipeline for decades ahead, it was a natural monopoly. The advent of LNG has steeply dropped the barriers to entry for a maritime nation such as Ireland, meaning that there is no market forces reason why we should not have multiple competing points of entry with multiple competing importers within a decade or two.

If allowed to develop, with some minimal interventions to limit market concentration, it should turn into the sort of market that no reasonable person would think should be regulated. It seems to me that it will be much like oil.

Whatever conclusion the CER comes to should explicitly allow for, and facilitate this transition, for the long run benefit of consumers and other end users.

Whatever other changes are made to the draft decision, the nonsense it contains at the moment about high capital infrastructure costs for the future should be deleted. As should the conclusions drawn from the nonsense. Garbage in, garbage out.

@ John A.

Why all this concern for a fossil-fuel multinational from a tax haven while the renewable energy sector (with our obligations approaching 2020) has come to a complete standstill due to what I believe is huge meddling by the fossil fuel sector?

That’s a very good question indeed.

Gas complements wind. It’s needed for when the wind doesn’t blow, because gas turbines are easily turned on and off unlike most other forms of generation. We are going to have vast wind capacity by the end of the decade, which means we will still need lots of gas too.

Also, the carbon emissions are lower for gas than for other fossil fuels, so it’s even semi-green by itself.

@ BeeCeeTee

Also, the carbon emissions are lower for gas than for other fossil fuels, so it’s even semi-green by itself.

This pre-supposes that this new sources of gas (by fracking or whatever) are used in place of oil, coal etc. – which I don’t believe anyone would think will happen. So additional burning of gas is just adding to the hydrocarbon problem, not helping it.


I noted in the earlier post by Richard in Dec that gas prices would simply have to fall if the rate at which shale based gas production has increased over the past 4/5 years continued.

Whist I understand the additional demands placed on the supply chain by the Japanese and German (daft) nuclear decisions, my reading is that shale gas finds will more than offset this unexpected upturn in future demand requirements, with considerable ease.

Your comments in relation to LNG and competition to me make perfect sense and we should gear up for this this eventuality.

The world gas market is very odd with Asian consumers paying nearly 5 times more for exactly the same product as their US equivalents despite the fact the US still being a net importer of gas (albeit now a very marginal one) as is the case for most Asian countries. As the stunning increase in gas production coming from the US eventually seeps its way onto world markets by way of LNG because of a seemingly enormous previously untapped supply, prices in a world sense will likely converge to a level somewhere between current US and Asian prices, over time. In a long term trading call – short Gazprom.

@BCT & YoB,

You both make very valid observations about gas market arrangements in Ireland and internationally. Ireland is effectively part of a single gas market on these islands, which, in turn, is part of a single North West Europe (NWE) gas market with physical and virtual hubs at the UK NBP, the French PEG Nord, Belgium’s Zeebruge, the Dutch TTF plus 2 virtual hubs in Germany. The European Commission with the group of national energy regulators, ERGEG, and the Agency for Co-operation of Energy Regulators (ACER, established by the Third Legislative Package) are working to develop this market and, using its EU Gas Target Model, are seeking to extend it throughout the EU and beyond. But they are doing this in the most cack-handed, silly and costly way imaginable. Still, I expect they will get there eventually in the usual EU fix, fiddle, fudge and fumble manner.

Rather than seeking to kill this LNG import project, the Government should be encouraging it. And the proposed imposition of additional unjustified costs on the Corrib Consortium will have a chilling effect on exploration and production (E&P) activity in, and offshore, Ireland. Not to mention the detrimental impact on Ireland’s reputation in the international energy context. And all to keep BGE in the style to which it has become accustomed.

I’m pretty sure the CER would love to get off the hook on which it finds itself impaled, but it doesn’t seem to be making a very determined effort. Noting that “it is an option for the shareholder of the network asset owner to voluntarily forfeit some of the revenues owed for the cost of the interconnectors” (p38) falls far short of what it should be saying to Government. Since economic regulation of the energy sector was established, successive governments, the CER, the Department and the ESB and BGE have sought to project and sustain this optical illusion that these semi-states are the same, and should be treated the same, as any private sector business performing these activities and that the Government is the same, and should be treated the same, as any private sector investor in a utility or infrastructure business.

This is absolute nonsense. The management of a private sector business in the infrastructure or utility sectors has a fiduciary responsibility to the shareholders to ensure revenues are generated to recover the costs incurred (including a risk-related rate of return with which the shareholders are content). A government, with a majority shareholding, has a continuing duty to ensure that the stream of economic benefits generated exceeds the economic costs incurred over the life-time of investments and imposed on final consumers.

It is patently clear in this instance that circumstances have arisen where the future stream of economic benefits will fall considerably below the economic stream of costs. A responsible government would have no option but to grant the discretion to the economic regulator to make the neccessary adjustments to ensure that the future stream of costs is aligned with the stream of benefits in the public interest. And the regulator should request government to provide it with this discretion.

Instead the CER in a wishy-washy manner suggests that the Government, if it were so inclined, might consider forfeiting some future cost recovery and proceeds to propose imposing the excess costs on prospective new suppliers without any rational justification and in a manner that is detrimental to the public interest.

The CER should simply demand that Government grants it the discretion to make its decision in this matter in the public interest.

However, I can’t see the CER demanding this or the Government granting it. So this is likely to end up in the courts – either in Ireland or the EU, or both.

This won’t lead to a happy outcome for the Government, the CER, the Department or BGE. But they seem determined to push on regardless.

I understand that the country needs gas but how much gas does it actually need?

Shannon LNG plan a 450MW CHP plant adjacent to their proposed LNG plant ( ). Endesa, who bought the ESB power plant at Tarbert 3 miles from the proposed LNG plant, have permission to change the fuel mix from oil to gas with a new gas-fired CCGT power plant ( ). That adds up to 900MW of electricity in the area alone. How does that fit in with renewable energy targets?

What makes Shannon LNG so sure that they can just so dramatically change the Irish energy fuel mix towards the fossil fuel called gas to the point that it kills the renewable energy sector in this country? Has something already been decided or will they continue to use the amazing bullying technique of full-on lobbying with politicians that has been deployed with the proposed CER decision of Friday? Why is the Minister for the Gaeltacht, Jimmy Deenihan, who can’t even speak Irish, so incensed about Energy when it is not even part of his portfolio? Why is the Sinn Fein deputy, Martin Ferris, so concerned about gas in North Kerry for the benefit of an offshore multinational, while at the same time so outraged about the selloff of parts of Bord Gais? Why does the Labour deputy Arthur Spring want to drag the regulator before a committee just because the regulator might make a decision against the interests of Shannon LNG when it is illegal to politically interfere with the independent regulator? Why does the Fianna Fail Senator Ned O’Sullivan abdicate all objectivity in his time on the Joint Committee for Climate Change and Energy Security in the almost fanatical support of the Shannon LNG project which he seems to seems to forget that LNG is a fossil fuel? Answer: they are local Kerry politicians who are like a lynching mob ready to jump on anyone, even from their own political parties, that speaks out against Shannon LNG or asks any intelligent questions? Read this week’s “Kerryman” if you don’t believe me (e.g. Many, many people in the local area are against the LNG project, for the danger, the damage to the environment and for the sterlisation of the Shannon Estuary from further developement such as for the transshipment port, it would entail. But they have to stay very, very quiet because all rationality is gone out of the debate.

Let the regulator do his job because the alternative of letting the politicians do it is far worse.

Why has offshore wind died a death here when it is being promoted so heavily in the UK?

Why has there been a decision to grandfather curtailment levels for onshore wind projects that will kill investment in the renewable energy sector despite our 2020 obligations (see )?

Why promote so heavily one billion euros of sterilising gas development in the remote and beautiful north kerry area for the benefit of a Cayman-Island offshore company that has spent over €60 million on “consultants” and “advisors” to date without even one sod having been turned to date on site?

He who pays the piper calls the tune.

@John A.,

If you want to return to the insular, inward-looking, isolated Ireland – uncontaminated by ‘evil’ outside influences – prior to the 1960s, that’s your choice. But I don’t think you’ll get too many takers. It makes far more sense to look forward and see the Irish energy sector as part of an increasingly integrated single European energy market. And over time, with increased integration, we will see more focus on EU-wide climate change targets, rather than these national targets that are being exploited by subsidy-farmers.

In this context, the CER’s proposed decision is simply stupid in relation to any objective economic or forward-looking criterion.

And if every MNC either contemplating operations – or operating in Ireland – that indulged in offshore taxation arrangements were excluded we wouldn’t have too many left. It is a matter for global governance to ensure appropriate imposition of taxation that has been democratically sanctioned.

@John A.,
A few points:

1) I don’t have specific information on the Shannon LNG CHP plant, but many CHP plants are fueled from renewable sources – waste or biomass. Do you have information that this one will not?

2) Gas and wind are complementary. More wind capacity requires more gas turbine capacity to pick up the slack when winds are low.

3) Why has offshore wind died a death here, but not in the UK? Because the economics are terrible, because we are not as short of renewable resources as they are in the UK, and because the large amount of onshore wind we are connecting is already causing problems for the grid. Even ignoring externalities, the large amount of concrete required to install wind turbines at sea, and the far greater expense of undertaking construction and maintenance operations at sea are make offshore wind much less economically attractive than onshore.

Just in relation to the 800 or so jobs that this project is suppossed to create. No Irish contractors, with the exception of Kentz (who barely operate here), have any experience of building LNG facilities. The majority of these construction jobs will be highly specialised and likely to be foreign contractors.

With regard to long-term jobs, i have visited 2 LNG regas facilties in Spain and these have about 50-60 in each. The benefits to North Kerry wll be minimal. The local Spar might have to take on a few more at the deli counter.

@Paul Hunt

All I was highlighting was that there are many stakeholders affected by these projects who are ignored when there is an extremely narrow focus put on getting the Shannon LNG project across the line at all costs. There is the huge economic cost of the most sizeable hazard in Ireland at the mouth of the estuary sterilising the estuary for further development. This is because no ships will be able to use the estuary when LNG tankers are nearby and by their own standards no ships should be withing 500 metres of them (and the estuary is only 315 metres wide at the entrance). This impact has never been assessed. There is also a huge safety and environmental cost through pollution which equally has an economic cost and which has also not been factored into the cost equation.

Shannon LNG warned the CER on August 10th, 2011 not “to interfere with Shannon LNG’s property rights and related legitimate expectations”. For me, it is therefore strange that a private company from the Cayman Islands can get a compulsory purchase order for roads and a 26km pipeline route from private landowners who equally had their own property rights and legitimate expectations walked all over by Shannon LNG. So what is good for the goose is good for the gander. What will Shannon LNG give in return? nothing only higher gas prices and a ruined Shannon Estuary region.

Shannon LNG then had the cheek to suggest in the same submission that Wind generaters should contribute to the interconnector surcharges as they displaced gas generators…well.. hello….? Where is the concern by this company for our 2020 renewable energy targets? (that might be an answer to BeeCeeTee’s first question).

Colm McCarthy, speaking on RTE on Monday, stated again that parts of the gas transmission network are a natural monopoly. The difference between Ireland and other EU countries is that Ireland is at the edge and is an end destination. No gas passes through to anywhere else. Gas purchasers in the UK will always go for the LNG from Milford Haven as LNG in Ireland will have the interconnector costs going the other way factored in. Everyone agrees that Ireland and the UK is the one gas market so Ireland benefits from the competiton that exists in the UK already. Why should an off-the-shelf offshore company with €1,500 in equity benefit from the costly infrastructure put in place by the Irish and walk away with all the profits as the gas consumer pays twice for the intereconnectors which must be maintained whether they are used or not?

I have absolutely no problem at all about Shannon LNG coming in from the outside but equally they can never, given the way they are setup, expect us to think that they are acting in the interest of Irish consumers.

The Regulator, on the other hand, for all their faults that you highlight, are the most neutral participants in this process and are the most independent of all the players in this process. As Minister Rabbitte pointed out in the Dail yesterday ( ) – “Deputy Griffin is asking me to break the law. I cannot do that” and then our very rational Minister for Energy, went on to explain to the slow learners in the debate:

“At our meeting on 21 December, the Taoiseach, the Minister for Arts, Heritage and the Gaeltacht and Deputy Spring met with the promoters and the American representative. They asked for a forum and they are getting a forum. It is normal practice for the regulator to publish this kind of paper in advance. Let the stakeholders go along to that forum for however long it lasts and let them effect the changes that are deemed sensible.”

So my questions in fact are not in the slightest bit insular. The main one again, which nobody has yet answered is:
How much gas do we need in this country?

@John A.,

I’ll start at the end. The clue is in the title of Richard’s initial post. An interconnector connects two markets with a price being formed, transparently and continuously, in each through the interaction of demand and supply. The interconnector doesn’t have to be bi-directional, but, even if the prevailing flow of gas is in one direction, the volumes flowing in the interconnector will be determined by the difference between the prices in the two markets. Suppliers and traders in both markets will reserve capacity on the interconnector to capture the arbitrage, the fixed costs of the interconnector will be incorporated in the market prices in both markets and, in the absence of congestion, the difference between the prices in both markets will equal the short run costs of increasing or decreasing flows on the interconnector.

This is sometimes described as the Law of One Price where the difereences between prices at different locations in a single market are equal to the short run costs of transport. This is the medium to long-term objective of the EU. It has been achieved already in the North American gas market.

The question is: how does Ireland fit in to this? It is extremely unlikely that a traded gas market with the depth and liquidity of the UK NBP will emerge in Ireland. So the arbitrage between the two markets that would encourage suppliers and traders in Britain to reserve interconnector capacity is unlikely to arise.

The best solution would involve crafting ownership, operational, contractual and regulatory arrangements that would seek to replicate the outcome if the interconnectors were connecting two deep-and liquid traded markets.

The British TSO, NGG, is unlikely to have any interest in acquiring the interconnectors, but it should be possible to determine a value for the interconnectors, if they were to converted to be bi-directional, and NGG might be prepared to come to a deal with BGN to share the ownership and operation. At the moment the vagaries of NGG’s entry-exit pricing mechanism mean that there is only a nominal (close to zero) exit charge at Moffat. Bi-directional interconnectors would impact on the configuration of LRMCs on NGG’s system (in addition to providing another potential source of supply) and this could benefit NGG in revenue terms while having an almost negligible impact on the average cost of transmission in Britain.

This would also increase the potential future use of the interconnectors and the revenues that would be recovered. It might even encourage the prospective new suppliers, the Corrib Consortium and Shannon LNG, to reserve capacity on the interconnectors. And the access to the larger market on both islands should encourage E&P activity in Ireland. But BGE would have to be prepared to accept some write-down of the value of the assets. And this it and the Government resolutely refuse to contemplate.

All of this would require detailed analysis and negotiation, but the effort would be worth it as the outcome would replicate the optimal economic solution.

However, the Government, the CER and BGE seem determined to plough ahead with their fatally flawed approach which involves protecting BGE at all costs from the folly of the investment decision it forced on the then government, killing Shannon LNG and forcing the Corrib Consortium to swallow an unjustifiable share of the costs.

And finally, the Minister is being disingenuous as so many levels that it would be hilarious if this weren’t quite serious. I won’t go in to these farcical public consultations as I’d end up on rolling on the floor laughing, but this idea of the ‘independence’ of the regulator is even more farcical. The CER implements settled government policy. Period. That means (1) ignoring the implications of the continued financial integration of the ESB and BGE by concealing them under a blanket of operational and technical unbundling, (2) setting network revenues to include an implicit financing tax on all consumers to part-finance investment so that government doesn’t have to forgo any dividends or part-finance investment directly and (3), in this case, protecting BGE’s revenue stream by imposing, without any objective justification, the cost recovery for stranded assets on suppliers that will compete with BGE’s supply arm – with the hope of making one exit.

This ‘problem’ hasn’t surfaced today or yesterday. It’s been around long before Shannon LNG appeared on the scene. The CER has spent the best part of the last 15 months pfaffing around. This is the 3rd consultation document. And it’s proposed decision will not provide any ‘regulatory certainty’; it will add to it.

A sensible solution could have been secured years ago. It’s still not too late.

It might be interesting to look at the times with peak electricity demand and the wind energy generated at those times, the week before xmas2007 for one example. There has to be conventional energy generation capacity to match peak demand, as wind power is Whitley unreliable

In Carawaystick’s vein, a fun diversion is to look at look at the stats on wind generation and demand, which Eirgrid publishes at 15 minute increments, easily found at its web site. Just since the start of the year, the share of power provided by wind has ranged from 3.0% to 53.6%. The amount of power demanded from non-wind sources has varied between 1079 and 4278 MW.

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