Maria Rita Galli, CEO DESFA

Interview to Thodoris Panagoulis, Energypress.gr

1. Ms. Galli, I sought this interview in light of the public statements that were made last week on the issue of the conditions for the creation of an underground gas storage facility in South Kavala. But before I ask you about this, tell me how the gas system responded to the recent big test due to the bad weather system “Elpis”.

Last week, the extremely unfavorable weather conditions caused a peak in gas demand, putting the gas network in extremely demanding operating conditions, very close to the system’s maximum capacity. From Monday 24^th to Wednesday 26^th, the daily gas demand reached a peak of 317 GWh, with historic record high hourly gas consumption of 17 GWh reached on Wednesday evening (26/1, 19.00-20.00). The gas demand was served by LNG from the Revithoussa Terminal and by pipeline gas from the northern entry points (Sidirokastro and TAP at N. Messimvria), with no flows from the Kipi entry point. In January, the LNG terminal received a record number of 8 cargoes unloading, of which one on last Monday in the middle of the snow storm. In these circumstances, DESFA’s personnel made a continuous and huge effort and, even throughout the snowstorm and abnormal cold spell, the successful uninterrupted operation of the System was ensured in its totality. And this, thanks to the reliability of our systems and the quality and dedication of our people.

2. Let us now come to the controversial issue: The president of RAE stated, very harshly, that DESFA as TSO, presented to the Regulator a study with which he considers as necessary for the operation of UGS of N. Kavala, projects in the gas network of total worth of 1 billion Euros and that this cannot be done because the Greek consumer will be overburdened. Are these investments of accompanying projects of 1 billion euros really necessary to operate, when constructed, the UGS of Kavala?

Last week we read many declarations and comments – some of them quite inaccurate – close to a public debate, on the results of the study requested by the Regulator and performed by DESFA as TSO, on the investments needed in the natural gas network to ensure the operation of the planned South Kavala Underground Gas Storage. Even if this topic is very technical and based on complex analysis and simulations, carried out by DESFA and third-party experts and engineers, Ι will try to explain it as simply as possible and provide some factual information.

In September 2020, DESFA was requested by RAE, to elaborate a study – submitted in November 2020, more than one year ago – identifying the investments that would be necessary to accommodate all the requests for capacity access from the ongoing and planned projects, in accordance with state of the art technical and commercial solutions and applicable legal and regulatory framework. During our subsequent interactions with the Regulator, DESFA did not receive any negative comment or remark either on the constraints identified by the study or on the projects, which would be required for the removal of these constraints.

In March 2021, RAE requested DESFA, to carry out a Cost Benefit Analysis (CBA) for these investments, to assess which of them would be beneficial to be implemented as part of the NNGS development. Later, DESFA was requested to carry out an integrated CBA, which would include the Underground Gas Storage itself, as well as the investments in the NNGS which would be necessary exclusively for the operation of the UGS. Such network investments have been estimated in c.a. €420 million, an amount far below the alleged €1bn reported in the press. The CBA, conducted by a highly reputable independent international expert, was presented to the Ministry of Energy, RAE and HRADF in November 2021 and was submitted to RAE in January 2022, confirming that the benefits generated by the UGS, namely by the reduction of price volatility associated to seasonal demand and the security of supply – as quite evident from what has been happening in the EU market in the last months – largely exceeds the costs of the UGS project and the associated network enhancements.

3. So you say that the required projects, based on the base-case scenario, are 420 million Euros. If these projects are not done, can the warehouse be operational? Does it make sense for an investor to enter the process if these projects are not done? It has also been expressed that no project is required…

To put it simply, the UGS in South Kavala, without these upgrades, cannot have access to the natural gas system, either as a whole or partially. Let me explain this further: currently the total maximum daily flow capacity of the Greek System amounts to c.a. 32 Mcm/day, with individual lower capacity caps on the East to West line from Kipi to Karperi and of the North to South line and vice versa. After the completion of the two compressor stations under construction (Kipoi & Ampelia), the total capacity of the system will reach 40 Mcm/d, with an increase primarily of the North – South capacity and vice versa. However, even after the addition of the new compressor stations, the capacity of the West-to-East branch of the system, which is constrained by the 24” diameter of the pipeline and is fully contracted to existing and ongoing entry and consumption points, will not allow to safely transport more gas in the specific branch. The UGS in South Kavala will be exactly on this branch.

The UGS – according to the information provided by HRADF – requires a system capacity upgrade in order for it to be able to serve all Entry and Exit points of the NGTS at an injection rate of gas into the storage of 7Mcm/d and a withdrawal rate of 9 Mcm/d, that is the amount of gas that in one day can be extracted from the storage to be used to serve the market. To comprehend the dimension, 9 Mcm/d equal approximately to the daily import of Russian natural gas from Bulgaria. It is important to understand that the access to the injection and withdrawal capacity of the storage needs to be guaranteed on a firm basis, otherwise its operation cannot be ensured, and no importer, trader or customer will have an interest to pay for such capacity and to store gas, without having the certainty of extracting such gas whenever needed and delivering it to the consumption points anywhere in the country. Assume you are a gas supplier, have booked and paid for the space in the storage, purchased the gas in summer, transported it and stored it in the storage, and when the winter cold spell comes and the prices are sky-rocketing, we tell you that you cannot take your gas and transport it when it is needed in the market…. In other words, without firm available capacity allocated to it, the UGS in South Kavala will have very limited value for the users and therefore the market as a whole. With no upgrade projects, there is no guaranteed access to the NNGS and vice versa.

4. How are the projects that DESFA considers necessary for UGS related to the state of the rest of the gas transmission system, based on the role that natural gas now plays in the country’s energy balance, the quantities that are circulating and the new infrastructure that is being prepared?

The Greek natural gas market recorded a significant growth over the last seven years, with gas demand almost doubled from 2014 to 2021, reaching the historical high of 6.74 bcm in 2021, while further significant growth is expected, driven by new gas fired generation replacing lignite plants, new distribution areas and the role of Greece as an entry door of the wider Balkan and SEE Gas Market. Consequently, the peak daily gas flow is expected to reach c.a. 45Million cm/day in 2030, which exceeds the 40 Million cm/day of the NGTS, after the ongoing compressor stations enhancements.

To support such growth, many new import and export infrastructures have been planned to connect with the natural gas system, some completed, such as TAP, some under construction, as IGB and the Alexandroupolis FSRU, which took the FID few days ago, and the planned projects of the Dioriga Gas FSRU, the Greece-North Macedonia Interconnector, and the South Kavala Underground Gas Storage. These projects require the capacity of DESFA system to be enhanced to ensure that the associated gas imports can flow to the consumption points in the country and export points to neighboring nations. Enhancement projects are already ongoing as part of DESFA TYDP, which nevertheless are not sufficient to satisfy all the requests received. The existing and expansion capacity of the NGTS, resulting from the NGGS ongoing upgrade projects has already been fully contracted to the new import and export projects, as well as the new gas fired power plants under development. At the same time, two large scale projects that will drive Greece’s energy transition, the pipelines in West Macedonia and West Greece, are under way. The underground gas storage comes after these projects and requires new capacity, in order to operate properly, as described above.

5. I would like you to comment on the fact that DESFA is on the one hand the Administrator of the national system (and also has the responsibility for its proper operation, security of supply, etc.), but also a shareholder of FSRU of Alexandroupolis, and a potential investor in YAFA Kavala. Are his proposals as an Operator influenced by his investment activities?

Not at all! As the Operator of the NNGS, we have very specific obligations for the integrity of the NNGS, but also the security of the supply of the country with natural gas. The performance of these obligations, under the control of RAE, derive from Greek and European legislation, but also directly affect the reputation of DESFA and its shareholders. The operational safety of the NNGS is our absolute goal, which, in all our years of operation, we have accomplished with adequacy and professionalism. In this capacity, we would never commit access to a new infrastructure for which we could not guarantee its safe operation in conjunction with the safe operation of the NNGS.

The assessment of which network enhancements would be needed to accommodate the operations of the storage came from the Regulator and have been delivered more than one year ago back in 2020. It is in the institutional role of the TSO to communicate to the market and the Regulator the necessary network developments, which are subject to public consultation. Eventually, one should be asking why this assessment was not requested before the launch of the South Kavala tender, but only after it was officially launched. We believe that any investors in the USG, and ultimately the Greek consumers, who are going to benefit or not from this investment, would require the assurance that the investments can operate before committing to it.

Therefore, indeed, also as potential bidder to the HRADF competition, we would like UGS in South Kavala to have unhindered access to the NNGS, in order to take the commitment to invest in the project.

I would like to emphasize that the role of DESFA. as the Operator of the National Natural Gas System is fully compatible with being a candidate investor in another natural gas infrastructure, which by the way will be fully regulated. This is a common feature of the European gas market, where the TSOs are also operators of the underground gas storages, as it is the case of our three TSO shareholders, Snam – which is the largest EU Gas storage operator, Enagas and Fluxys. Let us not forget that this is exactly what the Greek State demanded from the potential investors in DESFA privatization, that is to be operators of recognized prestige and experience, which could pass to DESFA their experience and know-how from more mature gas markets. What may be unprecedented in the Greek reality, i.e. an Operator being a potential investor in competitive tenders and private projects, is a regular case in the European energy scene. For example, all DESFA shareholders participate or are associated with companies involved in the management of underground storages and LNG infrastructure, in France, as well as in Germany, while in England and Portugal the respective Gas Transmission System Operators are also Operators of the respective electricity transmission systems.

Finally, our role as minority shareholder of the FSRU of Alexandroupolis, which we have concluded in December 2021, has no implications regarding our role as TSO, as well as potential participations in the USG Kavala. We have passed a very rigorous process of DG COMP, in order to enter the company and RAE has approved our entrance, recommending the unbundling between regulated and not regulated investments, which will be implemented in due time.

6. Finally, I would like to ask you about the following: Do you have any comment on the “aggressive” tone during the recent public statement of the president of RAE. Prior to this placement, were you informed about RAE’s positions? Does the formal and institutional channel between the Regulator and the Administrator work?

It was something that no one from us expected and I cannot deny that we have been negatively surprised and disappointed, as our communication with RAE so far on this issue was absolutely smooth and cooperative, as well as with all the other issues in which we have a dialogue with RAE, which are currently quite a lot and very important for the energy market. It is noteworthy that inaccurate data were also given to the press, despite us having presented and explained the data in detail to RAE and had never received any indication that the Regulatory Authority had these kind of objections.

Let me say that it is not common practice, nor do we consider it correct, that the findings of a complex technical and economic study, are commented – with such negative statements – to the press before  any discussion with the Operator through the institutional channels of communication. In addition, some of the terms utilized wereparticularly offensive to DESFA, its employees and executives and we believe that it is not to anyone’s interest, and certainly not to DESFA’s, nor to the Regulator’s and the consumers’.

I would not wish to make an assessment of specific comments, but I would just like to highlight that a private company, such as DESFA, with its governance and shareholders with an international presence, will never engage in a useless large scale and long-term investment, no matter if regulated or not, as this would be finally detrimental to its economic interest and sustainable business model.

For our part, we remain, as always, open to engaging in a collaborative and constructive dialogue with market participants, institutions and the Regulatory Authority for Energy, and fully committed to continuing to perform successfully – with the highest know-how, skills and our commitment – the role of the gas transmission system operator for the benefit of consumers and the market.