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28 de maig 2019

Ajuda'ns a tombar el projecte Midcat d'una vegada per totes!

Participa a la consulta pública dels Projectes d'Interès Comunitari de la Comissió Europea per dir NO als projectes STEP i Midcat que amenacen el territori gironí.

Ajuda'ns a tombar el projecte Midcat d'una vegada per totes!

Benvolguts amics I amigues,

pDesrés de la negativa de la CNMC als projectes STEP I Midcat, el promotor ENAGAS torna a l’atac I intenta tornar a incorporar el projecte a la nova llista de projectes d’interès comunitari del 2019!

El 29 de maig acaba el termini de la consulta pública a aquesta nova llista de projectes d’interès comunitari.

Necessitem un últim esforç per tombar d’una vegada per totes aquest projecte! És per això que et demanem que participis a la consulta pública. Només et portarà 2 minuts!

Hem de demostrar que des del territori rebutgem els gasoductes STEP I Midcat per innecessaris, costosos I per suposar un risc climàtic que no ens podem permetre!


Per participar a la cunsulta s’ha d’enviar un correu electrònic a ENER-B1-PROJECTS@ec.europa.eu amb l’assumpte:

Submission to 2019 Gas PCI List Consultation

Al cos del text hi pots indicar les raons que consideris oportunes. Si tens temps d'escriure un text personalitzar millor que millor! Tot i això, per fer-t'ho fàcil hem preparat un text ben complert que et pot servir de plantilla, I que si desitges pots adaptar al teu gust.

Recorda signar el correu amb el teu nom!

Moltes gràcies per ajudar-nos a frenar aquest despropòsit!

Esperem que, ara sí, sigui l’últim cop que sentim a parlar del Midcat!


Salut i canya!





Dear DG Energy B1 – European Commission,

I hereby submit my contribution to the “Consultation on the list of candidate Projects of Common Interest in gas infrastructure”. In my opposition to all proposed fossil gas infrastructure projects, I, as an individual stakeholder, ask that you please count this answer individually and do not summarize it together with other answers as one general contribution.

Specifically, in response to the question: “In your opinion, is a proposed project significantly contributing to market integration/sustainability/security of supply/competition and therefore needed from an EU energy policy perspective?” I want it to be noted that gas is a fossil fuel that exacerbates climate change and is incompatible with both the EU climate targets, and the goals of the Paris Agreement. Gas undermines any sustainability criteria and the gas projects of common interest will lock us into a fossil fuel future, resulting in stranded assets and dangerous temperature increases. Moreover, gas infrastructure projects have devastating direct and indirect impacts on affected communities both in Europe but also in gas supply countries around the world.

In relation to the projects South Transit East Pyrenees (STEP) and Iberian‐French corridor: Eastern Axis ‐ Midcat Project I would like to emphasize that I am writing from the affected territory, Catalonia, where I could see the destruction of the land that caused the construction of this gas pipeline in its first phase, between Martorell and Hostalric.

This project was carried out with many administrative irregularities, and without any type of public participation.

ENAGAS received in 2013 more than 13 million euros for the construction of this gaseous, which has never been put into operation. 13 million public euros that we have paid for among all the citizens, whom we have never asked. This money must be added more than 7.5 million for studies prior to the STEP project.

In Spain we have many examples of costly gas projects that have never been in operation or are functioning at a very low percentage of their capacity. To give just one example, the Castor project has never been operational and cost us 3.2 million euros.

Catalonia and Spain has enormous potential for generating renewable energy, and I would like that money we pay among all citizens to invest in renewable energies and in a fair energy transition, not in gas projects that destroy the territory with exaggeratedly expensive projects.

Here are some objective data that show how STEP and Midcat projects are not necessary, or economically profitable. But first of all, I want to show my rejection that we continue to invest public money in any gas project, because we know that gas is a fossil fuel that we can not allow ourselves to continue promoting if we want to slow down climate change.

The project South Transit East Pyrenees (STEP) – ENAGAS (project n° TRA-N-161) is the Spanish part of the STEP pipeline, the first stage of the bidirectional MidCat gas pipeline between France and Spain in the Eastern Pyrenees. It is planned to enable interruptible capacity of 230 GWh/d (over 8,5 bcm/y) ES > FR and firm bidirectional capacity of ~110 GWh. This project is clearly not responding to important eligibility criteria to acquire the PCI status and we do not see how any demand or energy security argument could justify that this project is included again in the Union List.

First of all, since the conclusion of the 3rd PCI list, some crucial analyses and conclusions were made at the occasion of the publication in April 2018 of an independent cost-benefit analysis study commissioned in 2016 by DG ENER to the Finnish consultancy Pöyry (https://www.lamarea.com/wp-content/uploads/2018/04/Informe-gasoducto-La-Marea.pdf).

These conclusions which strongly criticize the relevance of the project cast some really doubts over the previous decisions to give a PCI status to such a project while the gas market context has not changed in the meantime.

This project (“considered as the first stage of a greater project, MidCat”, according to Pöyry) has indeed been strongly supported by the European Commission since the start of the PCI list process in 2013, and received significant financial support through the Connecting Europe Facility programme (around 7.5 million EUROS of public subsidies granted to Enagas and Térega, the promoters of the project, for conceptual and engineering studies).

Yet, according to this study, the project seems very far from meeting the conditions justifying its presence in the PCI List. Energy security reasons and needs to diversify gas supplies are very often used to explain why a PCI project like this one is necessary for Europe and for the countries where the project is built. However, the Pöyry study debunks such justifications:

  • Pöyry confirms, despite denials from the promoters, that STEP is a foot-in-the-door for the much more expensive and bigger MidCat project: “STEP has not been conceived to provide a specific level of capacity, rather it is considered as the first stage of a greater project, MidCat, which aims at providing a substantial increase in cross-border capacity between France and Spain.” Salami-slicing the initial project to make them look like two different projects fools noone: it does not make one more relevant than the other and the remarks done for one project is therefore true for the otherPöyry develops five different scenarios to assess in which case/s STEP could have a positive impact: Only in the case of an extremely unlikely combination of 20-year long hypotheses (low gas demand + steep drop of Algerian gas exports + much higher LNG prices) could STEP have a benefit to Spain, though not to France. The ‘normal’ Green Revolution Scenario is the scenario officially used by the European Commission for the third PCI list (https://cloud.foeeurope.org/index.php/s/5AbMbntT5yD5bKc). It is therefore the most legitimate one among the 5 scenarios used by Pöyry to assess the project. According to the Green Revolution scenario, Pöyry observes that no gas will flow from Spain to France, despite opposite claims and statements by Enagas (notably in their PCI application).
  • According to the Green Revolution scenario, STEP is not cost-effective with a ‘Benefits to Costs Ratio’ (BCR) at only 0.33. Pöyry concludes that “for the Green Revolution, the impact of STEP on disruption costs is not sufficient to reach the required level of monetized benefits, regardless of the probability of disruption assumed.”
  • On the impact of STEP on gas tariffs, Pöyry observes a “lack of correlation between price spreads and flows” between Spain and France, and concludes that “it is not clear that additional capacity (i.e. STEP) would reduce price spreads today.” It is even worse for France as “gas prices generally increase in France, as a consequence of STEP.”
  • The study makes it very clear that STEP doesn’t have any impact on the security of supply of both countries. Many stress tests have been carried out, including disruption of supply from different countries (for quite unlikely long periods of winter months), peak demands and historical weathers: Yet, Pöyry concludes that “the inclusion of STEP in the stress tested situations did not materially change the impact of the situations – i.e. STEP did not provide any additional benefits in these situations. The results of this analysis show that whilst the stress tests impact the European market, STEP does not change either the level of unserved energy or the resulting system costs.” The same applied for the N-1 indicator where Pöyry concludes that “the N-1 indicator for Spain is already high and STEP does not provide a significant improvement because its capacity is limited. (...) STEP does not affect the N-1 for France, as there is no South to North firm capacity.”
  • Pöyry adds that in terms of “pertaining to price convergence; supply source price diversification; remaining flexibility & demand disruption; security of supply (N-1); import route diversification and bi-directionality, (…) none of these indicators are significantly impacted by STEP”. Pöyry concludes that “both France and Spain already enjoy healthy levels of security of supply according to the N-1 measure.”
  • According to the Green Revolution scenario, STEP even becomes completely stranded and loses money from the middle of the 2030’s, only around 10 years after its potential commissioning date (see p.75, 86 and 117-118).

The analyses and conclusions were taken very seriously by the French and Spanish energy regulators during the six month period they had to review the investment request that Terega and Enagas sent them. Yet, in January 2019, and for a large part based on similar grounds as those developed by Poyry, CRE and CNMC jointly rejected the investment request (https://www.cre.fr/Actualites/La-CRE-et-la-CNMC-rejettent-le-projet-d-interconnexion-gaziere-STEP and https://www.cre.fr/content/download/20284/258733), providing even more credibility to our opposition to the project not only for its environmental consequences, but also for its lack of necessity and its inability to show compatibility with PCI eligibility criteria. As another consequence, during the first PCI meetings to prepare this new PCI list, the Spanish government clearly said that they did not “appreciate [ENTSOG's identified] need for new gas infrastructure because we're well placed in terms of market competition and diversification of supplies” (https://twitter.com/FoEE_Antoine/status/1075046517700988929?s=20). The French government confirmed on this same day that they had “no need for new gas infrastructure (https://twitter.com/FoEE_Antoine/status/1075054118895607808?s=20). If neither the Spanish and French energy regulators, not the Spanish and French governments see an interest in building STEP, the project should therefore not be in the next PCI list.

The risk for the project to very quickly become a stranded asset, together with the likely high cost of the pipelines, and the over-dimensioned transport capacities threaten to impact customers energy bills and threaten to divert money needed for energy efficiency and renewables in the region. We therefore do not expect a positive impact on competition and certainly no benefit concerning prices. STEP would not add any value to both countries‘ security of supply and would not significantly contribute to either countries diversification of supply. Both France and Spain have a dense and well-developed gas infrastructure system meeting the N-1 minimum standards, therefore resilient in case any disruption from any major gas provider, and both are very well diversified considering that LNG terminals are a multiple-provider source. The two countries have heavily under-used LNG infrastructures, with both Spain and France reloading part of its imported LNG excess to other destinations in- and outside Europe (http://www.igu.org/sites/default/files/103419-World_IGU_Report_no%20crops.pdf). From January 2012-March 2017, Spain’s LNG terminals have been used at less than one third of their capacity, or lower (Cartagena LNG at only around 10%, El Musel never started operating after its completion). Meanwhile, in France, the four LNG terminals have high spare capacities to import gas (around 70%) according to the International Gas Union (http://www.igu.org/publications/2016-world-lng-report) and the number may drop with the fourth terminal in Dunkerque now operational. Overall, the maximum gas supply capacity of France’s gas infrastructure (pipeline imports, LNG regasification and peak storage output) is 528mcm/d, while peak daily gas demand is some 340mcm/d. This leaves over 180mcm/d (or 35%) “spare” capacity in the gas network (https://www.iea.org/media/freepublications/security/EnergySupplySecurity2014_France.pdf). Both countries are well diversified (France imports from Norway, The Netherlands, Russia and Algeria as well as LNG from different suppliers; Spain imports gas from 11 countries, including Norway, Algeria and, via LNG terminals, Qatar, Nigeria etc.) and saw a stark decline in gas demand during the last years: Spain’s gas demand fell by almost 30% between 2008 and 2015, France’s gas demand fell by over 17% between 2010 and 2015! Not only do these numbers hint to the futility of the Midcat project, and show that there is no demand justifying the project; there are also already two existing interconnections between France and Spain (Biriatou, Larrau – both bidirectional) able to transmit 5.4 bcm/y in both direction. Moreover, the two countries’ markets are sufficiently integrated for current (and future) gas demand of the two states, making obvious that there is no need of further integrating the already sufficiently well-connected markets, as MidCat would do. Spain could reach the same purpose (supplying France with the LNG it received) by re-loading its excesses of LNG, which shows that MidCat clearly does not answer to a problem or a need other than helping the business case of Spain’s under-used LNG terminals.

Thank you in advance for taking the time to review my submission.

Yours sincerely,


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