1. 1/1
Wintershall/ WINGAS proposal to the EU GREEN PAPER
“A European strategy for sustainable, competitive and secure energy”
Wintershall and WINGAS appreciate the opportunity to join the ongoing discussions on the GREEN
PAPER “A European Strategy for Sustainable, Competitive and Secure Energy”. Our comments relate
mainly to those issues mentioned in the GREEN PAPER which are referring to the European gas
markets and to the inherent interaction with the international oil and gas producers:
Wintershall and WINGAS fully agree with the view of the EU-Commission,
that Europe has entered into a new energy era. We share the Commission’s view, that
Europe is facing an increasing gas demand while indigenous production is declining
there is an urgent need for new investment to ensure long term security of gas supply,
there is a growing global competition on gas resources,
energy efficiency has to be increased in all sectors of energy use,
the completion of a fully competitive single European market has to be ensured.
Wintershall and WINGAS will continue to contribute to the future challenges of the European
gas market based on the following key competences:
our international know-how in exploration and production of oil and gas since decades,
our willingness to take the entrepreneurial risks and to contribute to the huge investments in
gas infrastructure necessary to ensure the long term availability of gas at competitive prices,
our long term partnerships with international oil and gas producers based on a balance of
interests between producing and consuming countries,
our experience in natural gas marketing in competition to incumbent players – already prior to
market opening in Europe.

2. 2/2
Wintershall and WINGAS promote the creation of fully a liberalised European gas market.
Market liberalisation should be based on the following targets:
Creating a level playing field to ensure the main target of liberalisation: Free choice of the
customer to vote for its preferred supplier.
Ensuring an adequate regulatory framework for non discriminatory network access which frees
up market forces along the gas value chain.
Shaping consistent and stable framework which is crucial for investments in gas infrastructure:
The investors need long term stability and confidence that they can shoulder the necessary
risks and recover appropriate revenues according to industrial standards.
Unfortunately most of the EU-member states have not yet fully implemented the 2nd
Gas Directive.
Where existing legislation has not been implemented the EU-Commission should keep track of
creating a level-playing field in whole Europe. However it should be pointed out that regulation itself
will not solve the challenges Europe is facing within the framework of a more and more globalised gas
market. Taking responsibility is crucial. Therefore a coherent strategy for sustainable, competitive and
secure energy should assure that market forces can free up and are not hampered by a
continuously deepened micro-regulation or new processes of re-regulation – especially if this
regulation tends to a “one size fits all” approach.
Wintershall and WINGAS fully support the initiatives to open up long term down stream
contracts.
Customers should exercise their freedom of choice and take advantage of the benefits of
liberalisation. The freedom of choice of end consumers and the motivation for suppliers to provide the
most competitive offers are the core targets of a liberalisation process. Consequently the customers
should not be contractually limited to one incumbent supplier for years and years. Opening up long
term historical contracts in the downstream markets of natural gas between the importers of gas and
end consumers would give a positive impulse for competition. Transferring long term import
contracts into customer-orientated contract terms belongs to the main responsibilities of import
companies. Therefore we support the view of the EU-Commission that long term import contracts are
necessary to keep security of supply whereas the one-to-one transformation of these upstream
conditions downstream to the end consumers is dispensable.
Wintershall and WINGAS refuse any further legislation of unbundling.
The existing EU-legislation regarding the principles of unbundling should be implemented in all
member states as soon as possible to ensure non discriminatory network access. Regulators and
competition authorities have now sufficient instruments to give network users the confidence that
network operators comply with non-discrimination. Simply to assume that network operators do not
comply with the current legislation can not justify new legislative action. As individual and
entrepreneurial property rights define one of the main elements and legal rights of a free and
liberalised market economy we strongly oppose to any proposal regarding an ownership unbundling.
Disregarding one of the core principles of our economy would not only endanger the necessary
private-sector investments into the gas infrastructure but would also contradict with the Lisbon
Strategy which is focussed to emphasize the position of Europe’s economy within the world.

3. 3/3
Wintershall and WINGAS commit to the principle of solidarity.
Solidarity is a core principle in the EU but it is also closely linked to the principle of responsibility:
Neither individual market players nor individual members states should be tempted to neglect their
responsibility to look ahead by relying on the community’s solidarity. The principle of solidarity should
never lead to a situation where the market players who have committed to their responsibilities – e.g.
by constructing storage capacities or concluding long term supply contracts – are faced with “free
rider” requests by those who have failed to cope with their responsibility to look ahead. In our view the
existing Directive on Security of Gas Supply with its graduated security of supply mechanisms forms
an adequate and target-driven basis to balance the principles of solidarity and responsibility
(2004/67/EC, Art. 7 coordination group natural gas and art. 9 community’s mechanism). We oppose to
any proposal for a new re-regulation as it would endanger the current balance.
Wintershall and WINGAS call for a market driven use of storage services.
Due to the multiple services provided by gas storages according to the individual requirements of the
customers any new legislative proposal concerning gas stocks which would only concentrate on one
of the services provided by storages would be inappropriate. A gas storage not only serves to prepare
for interruptions in gas supply, but also for seasonal balancing and stabilizing network flow. Last but
not least, natural gas storage is more and more used as a tool for portfolio optimization within gas
trading and therefore contributes to the emerging market in flexibility products. A compulsory
reservation of storage which dedicates capacity to a specific purpose would intervene real
market demand and would limit the competition to other flexibility products like interruptible gas
supply contracts (see also Directive 2004/67/EC, Annex: List of instruments).
Wintershall and WINGAS support the target of energy diversification.
To ensure long term security of energy supply a diversified and balanced energy mix is necessary.
The GREEN PAPER does not refer to Europe’s indigenous oil and gas production, although its
contribution to Europe’s primary energy consumption is still substantial. Maintaining a favourable
framework is necessary to keep the incentives for further investments in exploration but also in
improving the recovery of existing indigenous oil and gas reserves. Improving a balanced energy mix
should not only concentrate on promoting the most eco-efficient renewable energies but should also
include new applications for natural gas.
Wintershall and WINGAS promote the intensification of Europe’s energy partnerships.
We welcome the objective of the Commission to reinforce the existing energy dialogue between
producers and importers of natural gas. The future challenges of Europe’s energy supply can only be
solved through partnerships between consumers and producers on equal level. Security is not a one
way road in favour of Europe as the main importing area. We have to bear in mind that the right of the
producers to ask for security of demand and the right of consumers to ask for security of supply
are two sides of the same coin. Only in case Europe succeeds to integrate the producers’ interests the
long stability and security of supply to Europe in competition with other consuming areas can be
assured.