Opinion of the European Economic and Social Committee on:the Proposal for a Directive of the European Parliament and of the Council concerning the alignment of measures with regard to security of supply for petroleum products,the Proposal for a Directive of the European Parliament and the Council concerning measures to safeguard security of natural gas supply, andthe Proposal for a Council Directive repealing Council Directives 68/414/EEC and 98/93/EC imposing an obligation on Member States of the EEC to maintain minimum stocks of crude oil and/or petroleum products, and Council Directive 73/238/EEC on measures to mitigate the effects of difficulties in the supply of crude oil and petroleum products(COM(2002) 488 final — 2002/0219 (COD) ﾔ 2002/0220 (COD) — 2002/0221 (CNS))
Date: 2003-03-26
Institutions: European Economic and Social Committee
Subjects: approximation of laws, crude oil, natural gas, petroleum product, security of supply

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3.3.5.
The EESC intends, within a limited timescale, to
encourage structured consultation between the social partners
in the sectors concerned.

3.3.6.
The EESC notes that CEMBUREAU has said it
maintains contacts with ERMCO (European association for
ready-to-use concrete), BIBM (International Bureau for Precast
Concrete), FIEC (European Construction Industry Federation)
and EFBWW (European Federation of Building and Woodwor-

kers in the EEC) to develop a complete approach to the
question of workers’ health.

A convention between the parties designed to
3.3.7.
guarantee health protection for people coming into contact
with cement would be highly desirable, and would be likely to
make an important contribution, on the part of the social
partners concerned, to the draft directive under discussion; as
a result, its adoption and its implementation by the Member
States would be made easier.

Brussels, 26 March 2003.

The President

of the European Economic and Social Committee

Roger BRIESCH

Opinion of the European Economic and Social Committee on:

— the ‘Proposal for a Directive of the European Parliament and of the Council concerning the

alignment of measures with regard to security of supply for petroleum products’,

— the ‘Proposal for a Directive of the European Parliament and the Council concerning

measures to safeguard security of natural gas supply’, and

— the ‘Proposal for a Council Directive repealing Council Directives 68/414/EEC and 98/93/EC
imposing an obligation on Member States of the EEC to maintain minimum stocks of crude
oil and/or petroleum products, and Council Directive 73/238/EEC on measures to mitigate
the effects of difficulties in the supply of crude oil and petroleum products’

(COM(2002) 488 final — 2002/0219 (COD) — 2002/0220 (COD) — 2002/0221 (CNS))

(2003/C 133/04)

On 15 October 2002, the Council decided to consult the European Economic and Social Committee,
under Article 95 of the Treaty establishing the European Community, on the above-mentioned proposals.

The Section for Transport, Energy, Infrastructure and the Information Society, which was responsible for
the Committee’s work on the subject, adopted its opinion on 13 March 2003. The rapporteur was
Mr Cambus.

At its 398th plenary session on 26 and 27 March 2003 (meeting of 26 March), the European Economic
and Social Committee adopted the following opinion with 96 votes in favour and three abstentions.

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1. Summary of the Commission’s proposals

1.1.
The three texts presented to the EESC follow on from
the Green Paper entitled ‘Towards a European strategy for the
security of energy supply (1)’.

1.2.
There is a common background to the texts presented
by the Commission, namely the fact that, over the next
20 years, the EU’s external energy dependency could increase
from 70 % to 90 %, in the case of oil, and from 40 % to 70 %,
in the case of gas. Energy is a vital commodity for the economy
(production and transport), whilst also providing private
comfort for individuals. As most oil and gas production is
based in areas of political uncertainty, security of supply with
regard to both oil and gas is clearly a strategic requirement for
the EU.

In its communication, the Commission identifies two
1.3.
types of risks with regard to energy supply, namely: physical
shortage caused by technical problems (loss of installations) or
political difficulties (deliberate suspension of all or part of
deliveries) and the spiralling of prices to levels which would
place a heavy burden on the EU and would exact a heavy cost
in terms of loss of growth and jobs (an increase of USD 10 per
barrel would cut the EU’s rate of growth of GDP by 0,5 %) and
which would also place an unbearable burden on households
as final users (e.g. for heating or motor vehicle fuel).

As regards oil, two directives (2) have already been
1.4.
introduced with a view to addressing security of supply in the
Member States by imposing on them an obligation to maintain
stocks corresponding to 90 days’ consumption for three
categories of petroleum products, (motor gasolines, middle
distillates and heavy fuel oil), with adjusted conditions for oil-
producing Member States.

1.4.1. Member States are free to implement these obli-
gations in whatever form suits them, ranging from stockhold-
ing by private operators to stockholding by public bodies.

1.4.2.
The completion of the internal energy market makes
it necessary to proceed to a further stage in order to: improve
competition in the refined products sector, guarantee that this
market operates properly, make the EU’s security stock

( 1) COM(2000) 769 final.
( 2) Council Directive 68/414/EEC of 20.12.1968 imposing an obli-
gation on Member States of the EEC to maintain minimum stocks
of crude oil and/or petroleum products and Council Directive 98/
93/EC of 14.12.1998 amending Directive 68/414/EEC imposing
an obligation on Member States of the EEC to maintain minimum
stocks of crude oil and/or petroleum products. The first directive
imposed an obligation on Member States to keep stocks corre-
sponding to 65 days’ consumption, a figure which was sub-
sequently increased to 90 days’ consumption by the second
directive.

capacity more credible and more high profile, and ensure that
the action taken by Member States in the event of oil market
crises is both uniform and coherent.

1.4.3.
The proposals put forward with a view to achieving
these objectives are as follows: the creation of a central body
in each Member State to help new entrants and those
not having their own installations to respect the storage
obligations;
the possibility of holding stocks in another
Member State, so as not to place transnational operators at a
disadvantage; increasing the stockholding requirement from
90 days’ consumption to 120 days’ consumption, with one-
third of the stocks being held by the central body in order to
raise the profile of the strategy for ensuring security of supply;
and finally, the introduction, at EU level, of a joint regulatory
framework covering the release of stocks of petroleum prod-
ucts and involving an appropriate decision-making process
under the comitology procedure.

1.4.4.
The Commission also puts forward a novel idea in
respect of oil: the possibility of using strategic reserves to
intervene on the market with the aim of seeking to reduce the
impact of speculation on the volatility of prices for petroleum
products when supply crises are anticipated.

Turning to the gas sector, the situation here is charac-
1.5.
terised by (a) a delay in opening up the internal market, even
though gas is accounting for an ever larger share of the EU
energy market because of,
inter alia, its role in electricity
generation (between 50 and 60 % of electricity is generated
from gas) and (b) a high level of external dependence since
40 % of gas is supplied from three sources outside the EU.
The International Energy Agency (IEA) has no means of
intervention at its disposal in respect of gas.

1.5.1.
Before the gas sector was opened up to competition,
security of supply was ensured by supply companies which
enjoyed a monopoly. Once the market for gas is opened up,
there will be several market players; the responsibilities of each
of these players will therefore have to be redefined in order to
ensure security of supply for gas users.

1.5.2.
The situation with regard to gas differs from that for
oil from the point of view of the technical scope for holding
stocks, which mainly depends on subterranean geology. The
aim of the Commission’s proposal is to extend to gas the
principles set out
in respect of oil but without simply
transferring the same instruments. The aim is for the Member
States to adopt a minimum joint approach with a view to
completing and protecting the market.

1.5.3. With a view to ensuring security of gas supplies, the
Commission proposes to impose an obligation on Member
States to define the responsibilities of operators for ensuring
the supply of gas for a period of 60 days of average
consumption to customers who are not in a position to replace

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gas with an alternative fuel. It is, however, proposed that new
entrants to the market for gas and companies with small
market shares be exempted from this obligation. The Com-
mission intends to monitor closely long-term contracts and
the contribution which they make towards ensuring security
of supply in the Member States.

In the event of crises and in order to ensure solidarity
1.5.4.
between Member States, the Commission wishes to be able to
take decisions to release stocks of gas held in the Member
States and actually to interrupt supplies to the interruptible
market.

1.6.
From a general standpoint, the proposals put forward
by the Commission are based on the affirmation that, once the
energy market in the EU has been opened to competition, the
strategy for ensuring security of supply can no longer be
pursued most effectively at the level of operators or individual
Member States; this responsibility will therefore have to be
assumed by the EU.

2. General comments

2.1. Relevance of the proposal

2.1.1.
The EESC expresses its appreciation for this proposal,
which follows on from the Green Paper on the security of
energy supplies and carries out a thorough appraisal of the
EU’s security of energy supply in respect of oil and gas. After
devoting ten years mainly to organising the energy market,
opening to competition the monopolies which have tradition-
ally existed in the fields of electricity and gas, and promoting
renewable sources of energy, it is important that the Com-
munity now backs up this action by tackling the fundamental
issues relating to the supply of these products; the EU has a
structural deficit in domestic production of energy products
and is therefore highly dependent on non-EU suppliers. It is
important to note the major roles played by oil and gas in the
EU’s energy balance, particularly in transport and energy-
generation (which has been responsible for a very sharp
increase in the consumption of gas), and their consequent
contribution to growth, employment and private comfort.

2.2.

Subject of the proposal

2.2.1.
Of the energy products imported by the EU (coal,
gas, oil and uranium), oil and gas are undoubtedly those which
play the most significant role in the context of the energy
balance. Furthermore, they are imported from regions in the
world which suffer from a lack of diversification and are
exposed to political risks. In view of the strategic importance
of oil and gas, it is therefore vital to establish specific policies
for these products.

2.2.2.
The EESC considers that these two energy sources —
natural gas and oil — give rise to fundamentally different
problems; in including them in the same package of measures,
we must not underestimate the impact of these differences.
The first of these differences is that gas is generally speaking
both a raw product and a final product at one and the same
time; it has a low technological added value within the EU,

whereas most oil
is imported in the form of crude and
subsequently processed within the EU. This explains why the
price of gas has generally followed the price of oil, with the
aim of enabling the full range of competing uses of these two
forms of energy to be developed. This also explains the
existence of ‘destination clauses’, which are incompatible with
the rules of the single market; this matter is currently being
addressed in the case of new contracts. The supporters in
favour of opening up the gas sector to competition hope that
this will be a way of reducing, if not completely removing, the
link between the prices of
these two forms of energy.
Furthermore, on a global level the companies producing oil
and gas are frequently the same since prospecting for one of
these products frequently leads to the discovery of supplies of
the other.

2.2.3.
The second difference relates to the structure of the
market. There has long been a worldwide market for oil and it
is transported from the areas of production to the areas of
refining and consumption by ship rather than pipeline. This is
not the case with gas. The market for gas is organised on a
regional level (the EU obtains its supplies mainly from Norway,
Algeria and Russia; the USA links up with Canada and Mexico
to provide a market for gas; and Japan, Korea and Indonesia
form a further market). The EU market has been the most
stable — the American market is less stable and the Asian
market is more expensive. Although this is outside the scope
of this opinion, the recent events which have had such an
impact on the coastlines and populations of Spain and France
bolster the case for the increased use of pipelines to transport
oil wherever this is technically feasible, even if it would seem
to be more costly in purely economic terms.

2.2.4.
The third important difference is that within the EU
natural gas is generally transported to end markets by pipeline,
whereas petroleum products, including LPG, are transported
by pipeline from import and storage areas to refineries but are
then generally transported by tankers to the final point of
consumption. Any provisions which serve to shift strategic
and operational stocks of refined petroleum products away
from the centres of consumption will thus increase the number
of transport operations by lorry.

2.2.5.
The EESC therefore wishes to clearly differentiate the
measures to be taken in respect of these two energy sources,
even though it is desirable, as the Commission proposes, to set
out common guidelines.

2.2.6.
The EESC would like the proposal for a Directive to
cover also the candidate states when addressing the question
of security of energy supply, considering the impact on both
the new Member States and the current Member States. It is
important to negotiate the deadlines by which the candidate
states will have to comply with the storage levels and
procedures applicable to the existing Member States and to
discuss the technical and economic issues with which the
candidate states could be confronted in this context.

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3. Specific comments

3.1. Comments on the proposals in respect of oil

The EESC endorses the proposal

to oblige the
3.1.1.
Member States to set up a central security stockholding body,
which is to hold stocks representing one third of the specified
obligations. The EESC believes that these centralised stocks
will fulfil the need to highlight the existence of the EU’s
strategic stocks and will help to discourage those who may be
tempted to engage in price speculation. The EESC also
endorses the possibility for several Member States to meet this
stockholding requirement on a joint basis and for Member
States to hold their mandatory stocks in another Member
State. The best way to provide for this could be, in the EESC’s
view, to have stocks earmarked by the operator concerned or
to have recourse to centralised stockholding bodies, whose
establishment is proposed by the Commission. The aim is to
ensure clear identification of
the parties responsible for
managing stocks held outside a Member State.

The EESC does, however, wonder — for a variety of
3.1.2.
reasons, set out below — whether it is advisable to oblige the
Member States to increase their security stocks from 90 days’
consumption to 120 days’ consumption. Any increase in the
stockholding requirement clearly provides better guarantees
that crises can be overcome but these improved guarantees
come with a price tag; it is essential to fully appreciate what is
at stake and the likely outcome of such an increase before
taking the requisite decision.

3.1.2.1. Member States are currently obliged by the EU
(under Directives 68/414/EEC and 98/93/EC) to hold stocks
of finished products (listed in three categories) corresponding
to 90 days of average consumption. Under provisions estab-
lished by the IAE, of which they are members, EU Member
States have to hold stocks equivalent to 90 days’ imports; this
latter requirement generally imposes a greater obligation,
particularly in view of the fact that the IAE stipulates that an
allowance of 10 % has to be made to cover, inter alia, bottom-
of-tank stocks which cannot be used. As a result of this and in
view of the additional precautions that some states may take,
the actual stocks held by IEA member states are estimated by
the agency to correspond, on average, to 114 days’ imports,
whereas the stocks held by EU Member States are estimated by
the Commission to correspond to 115 days’ consumption.
Nonetheless, the impact of increasing the mandatory obli-
gation to 120 days could not be described as minimal; it would
have a very onerous effect on the southern Member States,
which, for reasons of climate and because of their lower
heating requirements, hold stocks of the order of 90 days,
whereas the reserves of some northern Member States already
exceed 120 days.

3.1.2.2.
Since the Yom Kippur War in 1973, which led to
the imposition of an oil embargo by some Arab states, oil-
consuming states have not had to face new physical disruptions
of supply brought about by political events. The spiralling of
oil prices as a result of the 1973 embargo prompted a number

of reactions, in particular, the substitution of other energy
sources, such as nuclear power and,
to a lesser extent,
renewables. This reduced the marketing outlets for oil-produc-
ing countries for many decades. Producer and consumer states
consequently became aware that they had a joint interest in
avoiding any drop in oil production and consumption levels.
This being the case, the development of political relations
conducive to good commercial cooperation seems to be an
approach which should be pursued, particularly in view of the
fact that the USA is in the process of refocusing its commercial
relations on our side of the Atlantic and, in particular, Africa.

3.1.2.3.
It is, however, not possible to rule out the risk of
incidents being caused by, for example, terrorists, which could
lead producers and consumers to reduce supplies of oil from
one localised geographic area for a certain period. In such a
case, it is unlikely according to experts that, if it has not been
possible to find a suitable solution to the problem within the
period of 90 days covered by the current level of the mandatory
reserves, 30 more days will be long enough to find such a
solution.

3.1.2.4.
The economic impact of a decision to increase the
level of strategic stocks to 120 days differs according to
whether this involves (a) topping up existing unused physical
stocks, in which case the only additional cost to be taken into
account would be that of adding to the products tied up in
this way or (b) increasing the actual volume of the necessary
storage installations. In view of the ever growing distrust and
fear felt towards all classified industrial installations, there are
few areas in the EU which are prepared to accept the building
or expansion of storage facilities for petroleum products,
bearing in mind that ‘Seveso’ type installations are involved
here. Finally, the bill for this increase in strategic stocks is
likely to have to be met by consumers; such a measure would,
of course, not be very popular and nor would it be particularly
conducive to maintaining growth.

3.1.3.
The EESC does not agree with the line taken by the
Commission towards the IEA. Since its establishment in 1973,
the IEA has had the role of coordinating the reactions of
member countries confronted by crises leading to a physical
shortage of oil supplies in the world. The IEA has, since its
establishment, adjusted its rules of operation to bring them
into line with the changing background situation, with,
incidentally, the participation of the EU. It was not the IEA’s
task to intervene when prices shot up since this is not its role.

As the oil market is a worldwide market and since
3.1.3.1.
one third of production capacity is situated in the OPEC
countries, a coordinated response has to be organised at world
level if it is to be effective. The argument which holds good in
the EU, to the effect that a reaction by one Member State
acting alone and in opposition to the other Member States
would be ineffective, is even more valid in the case of reactions
at world level to serious oil supply crises. In the EESC’s view it
is therefore essential for the EU’s strategy on security of oil
supply not to be separate to that adopted by the other major
consumer states; to that end the EU’s strategy should be based
on a close collaboration with the IEA. By speaking with one

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voice, EU Member States will certainly carry more weight
within and in their dealings with the IEA than if they adopted
a Eurocentric approach, which does not make very much sense
since the oil market is a worldwide market.

3.1.4. Whilst the EESC shares the Commission’s concerns
over the damaging effects of sharp increases in oil prices on
the EU economy and household purchasing power,
is,
however, very guarded about the Commission’s proposal for
using strategic stocks to intervene on the market in a counter-
cyclical way when the prices rise sharply. The EESC bases its
standpoint on a number of arguments.

it

3.1.4.1.
Regulating oil prices is a difficult task as the price
of these products has an inbuilt volatility. It is impossible to
achieve a fine balance between supply and demand. Invest-
ments in exploiting oilfields are decided upon, on average, five
years before production starts and on the basis of forecasts
which are never strictly confirmed by the actual situation at
the time in question. Subject to this technical and economic
constraint, the OPEC states keep the variation in oil prices
within the range of USD 22-28 per barrel; this appears to be
the average level of prices which is acceptable to all the players
involved. If the OPEC states did not take this action, price
volatility would no doubt produce prices ranging from USD 3-
60 per barrel. OPEC accounts for almost 40 % of global oil
production, which enables it to regulate prices in this way. The
EU, for its part, accounts for only between 20 % of global oil
consumption; it is therefore an illusion to believe that, on the
strength of a percentage of the market which is less than half
of that controlled by OPEC, the EU would be capable of
achieving more effective results, possibly by acting indepen-
dently of cooperation at world level through the IEA.

Oil prices may spiral out of control when the oil
3.1.4.2.
industry and consumers fear an imminent actual physical
shortage, brought about by serious political or climatological
factors which could come into play (such as wars, terrorist
attacks or earthquakes). The reason why prices go up is
because all buyers rush to increase their reserve stocks. How is
it possible to imagine that, in such a situation, when all the
actors involved fear the worst, the authorities in the EU could
decide to oblige the Member States to release part of their
strategic reserves in order to hold price levels for a brief
moment, only to have to reconstitute these reserves later at a
high price in order to contend with the risk of a real physical
shortage? This is hardly credible.

3.1.4.3.
There is also a practical difficulty since oil pur-
chases are computer managed on the basis of the workload
plans of refining units and price thresholds. The strategic
stocks cannot be included amongst the lists of regular suppliers
to be found in the management programmes; under these
circumstances reserves could only be marketed using ‘manual’
and hence onerous processes. This would fly in the face of the
need for rapid intervention, designed to wrong foot the market.
However, announcements of intention to place stocks on the
market would not be incompatible with this requirement.

Finally,

3.1.4.4.
the decision to release strategic stocks
would be a costly venture and this cost would have to be
justified and endorsed by the European Parliament, as the idea
of an EU body taking such a decision and then presenting the
bill to the Member States would not go down well. The cost
would be very high, even if we assume that only the one-third
of the strategic reserve managed at a central level would be
available for use in this way as this corresponds to almost one
month’s oil consumption in the EU and would be placed on
the market probably at the equivalent to USD 20 per barrel,
only to be renewed at a much higher price later.

3.1.4.5.
The experience gained with the world tin market,
where producer and consumer states organised the market
and concluded six agreements between 1953 and 1981,
demonstrates that action taken to control prices failed to
produce the desired result. The theory that measures to control
demand are the way to bring an influence to bear on prices
has not been borne out in practice.

3.1.4.6.
There is a kind of contradiction between, on the
one hand, the EU doctrine based on the efficiency of the
market in dealing with monopolies, oligopolies and adminis-
trations and, on the other hand, the readiness to give one of
the EU institutions the power to intervene on the oil market in
the event of unfavourable developments.

3.2.

Proposals relating to gas

3.2.1.
The EESC endorses the decision to oblige Member
States to introduce policies for ensuring supplies of gas in
order to guarantee supplies, under difficult conditions, to
customers lacking alternative fuel options (non-interruptible
customers with no alternative fuel switching capacity), be such
customers households or businesses. The EESC shares the
Commission’s view that these policies, setting out the responsi-
bilities of the various market participants, should not stand in
the way of the development of the internal market in gas,
which is in the course of being completed.

The EESC endorses

3.2.2.
the proposed formula for
assessing the obligation to ensure that security of gas supply
can be maintained for a period of 60 days of average
consumption, in the event of supplies being restricted.

The EESC understands that, given the current situ-
3.2.3.
ation as regards the internal market for gas, the Commission
does not wish to penalise unduly companies which are ‘new
entrants’ to the market or ‘companies with small market
shares’. The EESC does not however believe that consideration
should consequently be given to exempting these companies
on principle from the security of supply provisions to be
implemented by the Member States. It should be up to the
Member States to define the best way to reconcile, on the one
hand, the priority which has to be attached to maintaining
security of supply for customers with, on the other hand, the
real opening-up of the market.

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3.2.3.1.
Household customers and very small enterprises
do not have the necessary knowledge to gauge the reliability
of an offer made by a gas supplier, if the state does not
require the supplier in question to assume his share of the
responsibility, irrespective of how big or small he may be.
the proposed exemption would result
Furthermore,
in a
difference of
treatment vis-à-vis oil suppliers which are
required in the Commission’s proposal to contribute to stocks
— and to make payments to the central stockholding agency.

The EESC is pleased to note that the Commission has
3.2.4.
adopted a more realistic approach to long-term contracts,
which it criticised considerably on the occasion of the opening-
up of the market in gas to competition, singling out the ‘take-
or-pay’ clauses for special criticism. These contracts and clauses
are justified on the grounds of the size of the investments
required to market natural gas and the shared desire of
producers, purchasers and investors to recoup and make a
profit on their investments and ensure security of supply. In
the EESC’s view, however the Commission cannot readily
oblige Member States to accept minimum requirements in
long-term contracts since in a market which is open to
competition each company is free to decide how it manages
its supplies.

3.2.5.
The EESC endorses the proposal made by the Com-
mission that it be authorised to put forward recommendations
to Member States on the measures to be taken in the event of
a disruption in supplies from a key supplier to the EU. If no
effective action is taken on these recommendations, the
Commission wishes to be authorised to require Member States
to take action. The EESC highlights the fact that, in such a
case, it would be difficult for the Commission to assess the
exact nature of the constraints in connection with the use of
stocks and operation of networks, particularly as regards
security. Gas stocks form part of the integrated management of
the gas-supply system; they cannot be arbitrarily requisitioned.
Furthermore, it is not possible to hold stocks for excessively
long periods without using them.

3.2.6.
The EESC supports the proposal that Member States
report to the Commission on their respective situations as
regards supply problems and the policies which they are
pursuing in order to promote security of supply.

3.3. Oil and gas

The EESC believes that, from the public standpoint,
3.3.1.
the strategy for ensuring security of energy supply has to be
transparent; this transparency has been explicitly requested by
consumer representatives.

3.3.2.
The EESC recognises that Member States have tra-
ditionally ensured their own security of energy supply by
selecting the most appropriate ways and means which best
meet their political needs. Oil and gas are not the only sources
of energy in the Member States; some Member States chose to
invest heavily in hydroelectric and/or nuclear power. Should

Member States be faced with supply crises affecting any one of
the energy sources making up their overall energy-supply
package, it is normal that they should be able to take into
account their overall energy situation. That being the case,
direct intervention by the EU should be ruled out, in accord-
ance with the principle of subsidiarity.

3.3.2.1.
The role of the EU should be to (a) define common
standards, as it has done in the documents under consideration;
(b) ensure that the Member States apply these standards, which
it is proposing to do by means of the reports to be presented
by the Member States; and (c) propose coordination and
solidarity instruments, particularly in respect of the manage-
ment of strategic oil and gas stocks.

3.3.3.
The EESC draws attention to the fact that another
way of responding to the risk of oil and gas supply difficulties
in the EU is for the Commission to continue its actions and
incentives for promoting: diversification of energy supply
sources; research in the field of non-polluting, renewable
sources of energy; and a reduction in the consumption of
hydrocarbon fuels.

3.3.4.
In the light of the provisions of the Treaty of Nice,
the EESC considers that it should be involved in the assessment
and monitoring of the policies for ensuring security of oil and
gas supplies since the EESC itself comprises representatives of
the various economic and social components of organised civil
society and represents producers, consumers, workers and
movements for the protection of the environment.

4. Conclusions

4.1.
The EESC supports the Commission’s objective of
defining common guidelines for ensuring security of oil and
gas supplies in the EU, following on from the Green Paper on
security of energy supply and backing up the guidelines already
introduced for achieving a European energy market.

On the subject of oil supplies, the EESC endorses the
4.2.
Commission’s proposal to oblige the Member States to set up
a central body responsible for security stocks. The intention is
to give greater prominence to the holding of such stocks,
ensure cost-transparency and not discriminate against com-
panies without their own storage facilities, thereby avoiding
any distortion of competition.

The EESC takes a very guarded line as regards the
4.2.1.
proposal to increase the security stockholding requirement
from 90 days’ consumption to 120 days’ consumption for all
Member States, bearing in mind that, in practice, northern
states need to hold larger stocks than southern states for
obvious climatological reasons, as they do at present. The
EESC believes that there are no compensatory benefits to
justify the additional cost of such a decision.

C 133/22

EN

Official Journal of the European Union

6.6.2003

4.2.2.
The EESC gives a similarly guarded response to the
proposal to use these strategic stocks for the purpose of
bringing an influence to bear on oil prices in cases where fear
of a possible physical shortage leads companies to engage in
precautionary purchases, thereby giving rise to panic and
consequent price increases.

The EESC takes the view that, in order to give it
4.2.3.
sufficient clout and prospects of success, action by the EU to
manage oil supply crises should be carried out within the
framework of the IEA.

4.3.
As regards gas supplies, the EESC shares the Com-
mission’s desire to give the Member States responsibility for
laying down the rules to be followed by companies in order to
ensure security of supply.

4.3.1.
The EESC believes that the proposal to take appropri-
ate steps to ensure supplies of gas equivalent to 60 days’
average consumption represents an effective approach.

Brussels, 26 March 2003.

4.3.2.
The EESC underlines the fact that the storing of gas
is a very different matter from the storing of oil; the constraints
and technical difficulties involved need to be appreciated when
stocks have to be used in the event of supply crises.

The EESC notes that companies which are new
4.3.3.
entrants to the market may be exempted from the obligation
to hold security stocks; it wonders what impact this measure
may have and proposes that responsibility for it should lie
with the Member States.

4.4.
In the light of the EESC’s own nature and role, it
believes that it should be associated and involved in the
monitoring and assessment of the policies for ensuring security
of oil and gas supplies; such involvement would fulfil the need
for transparency expressed by representatives of European
consumers.

The President

of the European Economic and Social Committee

Roger BRIESCH