Αποτελέσματα Δημόσιας Διαβούλευσης της ΡΑΑΕΥ επί της εισήγησης του Ελληνικού Χρηματιστηρίου Ενέργειας για την τροποποίηση του Κανονισμού Βάθρου Εμπορί

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(0)20 7061 5000 EDF Trading Limited Regulatory Department Contact : Anne-Elisabeth Granier Mail: anne.granier@edftrading.com To: The Regulatory Authority for Waste, Energy and Water gasconsultation@raaey.gr London, September 17th 2024 EDF Trading Ltd welcomes the proposal of HEnEX for the amendment of the Natural Gas Trading Platform Regulation. The proposed amendment leads to the introduction of a new category of trading platform participants, namely ‘trading participants only’. EDF Trading would like to express its support for this proposal, which it considers to be beneficial for the market, by allowing more entities to access the platform provided that they have a contract with a network user. In this sense, the proposed development will facilitate access to the platform for different types and categories of gas market participants, leading to an increase of volumes traded on the platform, and improving liquidity. We remain available for any further clarification. ooOoo www.edftrading.com EDF Trading Limited A company registered in England - Registration Number 3750288 Registered office, Piazzale Enrico Mattei, 1 00144 Roma Tel. +39 06 59821 eni.com Eni S.p.A. agrees with the suggested changes to HEnEx rulebook taking into account that the new framework enabled by such changes, based on our understanding, will envisage that the trading-only participant, as counterparty to HEnEx, will operate using the platform to carry out its trading activity while the transmission user, with whom the trading-only participant will conclude a contractual relationship, will be counterparty to DESFA (and only potentially counterparty to HEnEx) and will be solely responsible for the physical balancing of the transactions carried out by the tradingonly participant. Furthermore, considering that the transmission user accepts by virtue of the contract he signed with the trading-only participant to fulfil the obligations arising from the Trade Notifications and that said obligations are defined through a generic reference to another document, it will be advisable to ensure that there will be no duplication of any fees for the transmission user in view of its role related to the trading-only participant’s transactions nor any overlapping of obligations for the transmission user in case of its own hypothetical trading activity on HEnEx. Company share capital Euro 4,005,358,876.00 full paid up Rome Company Register, Tax Identification Number 00484960588 VAT number 00905811006, R.E.A. Rome n. 756453 Branches: Via Emilia, 1 and Piazza Ezio Vanoni, 1 20097 San Donato Milanese (Milan) - Italy CONSULTATION RESPONSE Energy Traders Europe response to the proposal of the Hellenic Energy Exchange to amend the Natural Gas Trading Platform Rulebook Brussels, 20 September 2024 - Energy Traders Europe applauds the intention of HEnEx to implement our proposal for a “light” TSO contract for companies wishing to access the Greek VTP with no transport capacity in their portfolio, as submitted to the Greek NRA, TSO and Energy Exchange in January 20231. We fully support that the introduction of a new type of participant in the Natural Gas Trading Hub of HEnEx – referred to as a Trading-only Participant, who will not be a Transmission User but will have a contract with a Transmission User – has ultimately been submitted for consultation to the Greek Regulator, RAEWW. We are pleased to see that the new framework provides that the trading-only participant, as counterparty to HEnEx, will operate using the platform to carry out its trading activity, while the transmission user, with whom the trading-only participant will conclude a contract, will be counterparty to DESFA (and only potentially counterparty to HEnEx) and will be solely responsible for the physical balancing of the transactions carried out by the trading-only participant. We nonetheless recommend making sure that there will be no duplication of any fees or overlap of obligations for the transmission user on account of the latter’s hypothetical trading activity, as well as on account of their role in transactions performed by the tradingonly participant. Contact Mariana Liakopoulou Markets and Policy Associate m.liakopoulou@energytraderseurope.org 1 EFET proposal on a “light” registration to the Greek gas trading Platform 1 of 1