Is There a Single European Market for Electricity?

Since the late 1980s, Europe has aimed to remove the internal barriers to trade and competition. Network industries, which were historically sheltered from competition, have experienced dramatic changes as a consequence. The factors precipitating this change have, to a large extent, been technologically and market driven, but inefficiency of supply has also prompted reform. It has been estimated that in the chemicals sector, European companies pay up to 45% more for energy than their US competitors. Apart from differences in tax regimes, the lack of competition has been identified as a key factor in explaining the cost differential.

The European Commission's 1997 Electricity Directive prescribes common rules for the progressive liberalization of national electricity markets within the EU. Extending the concept of the 1992 Single European Act, the Directive aims to create a European electricity market in which there will be effective competition within and across Europe for contracts to supply electricity. So can Europe create a single market for electricity? The second report in the Monitoring European Deregulation series explores the obstacles to this objective and the policy choices facing regulators at both the national and EU level. The report combines analyses of key issues in electricity market integration and liberalization with evaluations of the practical experiences in the UK, the Nordic countries, Germany, Spain, France and Hungary.

Electricity is produced and delivered in a four-stage, vertically interdependent process involving generation (the production of electrical energy), transmission (transportation of this energy along high-voltage cables), distribution (transportation at lower voltages to final customers) and retailing (advertising, branding, contract bundling and billing for final customers). Electricity transmission and local electricity distribution involve large sunk capital costs. These stages of electricity production are considered to be natural monopolies and there is little scope for actual competition: typically, each European country has one company operating its national transmission network and a number of regional local monopolies operating its distribution networks.

In the past, most national electricity industries in Europe were vertically integrated. To prevent these companies from discriminating in favour of their own generation and retailing businesses, the Directive requires at least a minimum degree of unbundling of generation and transmission, based on separate management and accounts. Most member states have chosen to go one step further and legally separate transmission and generation. But two of the largest countries, France and Germany, have not.

France has argued that transmission and nuclear generation need to be tightly coordinated to maintain safety and integrity of supply. But the evidence from the UK and Scandinavia is that, even in the presence of significant nuclear power, there are few efficiency losses from vertical unbundling. The report, however, goes further. It advocates separating ownership between the natural monopoly elements of the system and other activities, concluding that accounting or even legal separation is simply insufficient.

The rationale for separating the vertical links of the industry is not equally strong at every stage. Separation of the ownership of the transmission and distribution lines in small countries, such as Northern Ireland, is not necessary since both activities have strong natural monopoly elements. The separation of the distribution and retail activities does, however, seem to be desirable and is something that the Directive fails to tackle. Electricity retailing has traditionally been bundled with distribution, but recent liberalization efforts have demonstrated that it is actually separable from distribution and hence competitive. Retail companies can purchase generated electricity and transportation services and compete on the basis of least cost purchasing, metering and billing costs and quality of customer service. In the Nordic countries, customers pay two bills: one for energy from traders and another for energy transport. Retail competition may encourage vertical integration between generators and retailers as it reduces wholesale price risk. If combined with market power in generation, this could be a cause for concern and would require close monitoring by the competition authorities.

The current market structure for electricity generation is highly concentrated. A concentrated market structure need not be a problem for the delivery of competitive prices in the presence of low entry barriers. But where significant entry barriers exist, as they do in Europe, actual competition not potential competition is what determines prices within a market. The experience of the UK and Spain strongly suggests that competitive outcomes cannot be reached without sufficient dispersion of the ownership of generation assets. It has been estimated that splitting the UK's Central Electricity Generating Board into five rather than two generation companies would have yielded benefits to consumers of around £262 million a year.  

There are two main approaches to the reduction of concentration in generation. The first consists of breaking up existing companies into smaller ones. This is achieved more easily when there is significant public ownership in generation but divestment of privately owned assets can be obtained through the use of competition laws. Alternatively, market power can be diluted by extending the market itself. This was the route chosen in Sweden, where the relevant market share of Vattenfall was significantly decreased by the removal of all institutional barriers to trade across the Norwegian, Swedish and Finnish borders. This effectively doubled the size of the market that Vattenfall operated in and has had a significant downward effect on prices.

The nature of electricity means that its supply and demand must always be physically in equilibrium, otherwise the system will fail. This requires a Transmission System Operator (TSO), which oversees the process of instructing plants on required availability and physically balances the system in situations where actual supply and demand deviate from planned supply and demand. System operation is a natural monopoly and there is strong evidence from the UK that it benefits from incentives to reduce 'uplift' costs (i.e. the difference between the pool purchasing price and the pool selling price). Incentives, including penalties, pose financial risks for the TSO, and variations in income arising from incentives could be large.

This suggests that the TSO will need a capital adequacy requirement, of the kind that is naturally available to a regulated grid company, to avoid the risk of bankruptcy. Hence, where the whole transmission system is under one owner, there are advantages in having the owner of the transmission network as the TSO. Ownership of the transmission assets ensures the solvency of the TSO, which can then be subjected to powerful incentive schemes. In the case of several grids under separate ownership, transmission system operation should be independent.

Third party access to the transmission and distribution network is crucial to a competitive market for electricity. The Directive requires member states to implement third party access and offers a choice between three alternative methods: negotiated third party access (nTPA), regulated third party access (rTPA) and the single buyer model. Under nTPA, consumers and producers can contract directly with one another and then negotiate with the network operators for access to the network. Under rTPA, prices for access are published and not subject to negotiation. The single buyer model, where there is a single wholesale buyer of electricity, is functionally equivalent to rTPA but suffers from greater transaction costs.

The vast majority of countries have opted for rTPA, the notable exception to this being Germany, which has chosen nTPA. Both theory and evidence suggest that nTPA may create some difficulties, and it is therefore not surprising that disputes over German transmission and distribution networks have already arisen – in 1998, Enron was denied access to the network. Given the objective of a single competitive market for electricity in Europe, the choice between nTPA and rTPA seems obvious. The latter is transparent, open and non-discriminatory in a way that is far less likely with nTPA.

If the single market for electricity is to become a reality, it must be as easy to trade electrical power between countries as between different parts of the same country. The pricing of access to the transmission system is the key to an integrated electricity market, but owing to the nature of the industry access pricing is not a simple matter. Electricity transmission does not conform to the simple linear laws that govern a standard vertically integrated stage of a production process. Electricity flows between two points via all potential routes in inverse proportion to the resistance along each of the routes – i.e. it will not travel by the shortest route, the so-called 'loop flow effect'. Hence, the transmission of electricity between a producer and a consumer can affect the flow, and therefore the costs, of all other producers and consumers in the system.

This has important implications for the pricing of transmission services. Prices based purely on energy input or output (postage stamp tariffs) or on distance and energy (contract path tariffs) are not efficient given loop flow effects. Node varying transmission prices where producers and consumers pay positive and negative congestion charges for producing or consuming power at different points on the network may be more economically efficient.

The Report argues that Europe needs a transmission pricing system with the following characteristics. First, access charges need to be simple, transparent and only dependent on the point of connection – i.e. nodal transmission pricing. Second, the allocation of charges between entry and exit points should be uniform across jurisdictions, but should allocate at least a small share to the entry point. Third, there should be some geographic differentiation of access charges to provide incentives to relieve congestion and reduce overall transmission loss. And fourth, a scheme for financial compensation between transmission system operators for transit and loop flows should be introduced.

Competition and free trade have proved to be formidable engines of economic growth and prosperity. The Electricity Directive has made a significant contribution towards opening up the national electricity markets for competition. Yet the Directive is not all that is needed even if fully implemented in all member states. The Report concludes with an agenda for the European Commission in 2000. It argues that the Commission should supplement the Electricity Directive with the following additional measures:

  • A mandatory separation of ownership between generation and transmission/distribution.

  • Strict competition policy oversight of integration between generation and retailing.

  • Harmonizing non-tariff conditions for access to transmission and distribution networks.

  • The promotion of international transmission pricing rules.

  • The creation of a body in charge of identifying the need for new interconnection facilities, allocating the cost of these facilities between participants and drawing up compensation schemes that ensure a fair and efficient recovery of these costs.

  • The organization of a system of trading permits for emissions.

Monitoring European Deregulation 2: 'A European Market for Electricity' by Lars Bergman (Stockholm School of Economics and SNS), Gert Brunekreeft (Albert-Ludwigs Universität Freidburg), Chris Doyle (London Economics), Nils-Henrik von der Fehr (University of Oslo), David Newbery (University of Cambridge and CEPR), Michael Pollitt (University of Cambridge) and Pierre Regibeau (University of Essex and CEPR).

The Report was launched at a Lunchtime Meeting held in London in December 1999.