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Energy Law

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Abstract

European energy law is relatively young as a subject. Looking back to just 20 years ago, the EU had adopted almost no (secondary) legislation regulating the energy sector. ECJ case-law was equally thin on the ground. Since its early days in the mid 1990s, European energy law has caught up at an impressive pace in comparison with other jurisdictions as well as with other sectors covered by the internal market. Today the gas and electricity markets are regulated in great detail by European legislation, and increasingly also by case-law. The EEA Agreement made the EEA/EFTA States partners of the European energy internal market and with its dynamic procedures of incorporating secondary legislation in this sector into the Agreement, Europe was intended to have one energy regulated market. This chapter describes the well-functioning of the EEA Agreement in the energy sector but also points to the challenges the EEA Agreement poses for the creation of a single energy market.

Dr iur HSG, Deputy Director and Head of Legal at the Energy Community Secretariat. The views expressed in this contribution are strictly personal and cannot in any way be attributed to the Secretariat.

LLM, LLM (College of Europe and University of Leuven), currently working for the EFTA Surveillance Authority in charge of energy. The views expressed in this contribution are strictly personal and cannot in any way be attributed to the EFTA Surveillance Authority.

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Notes

  1. 1.

    Case 6/64 Costa v. ENEL [1964] ECR 585.

  2. 2.

    Directive 96/92/EC of the European Parliament and of the Council of 19 December 1996 concerning common rules for the internal market in electricity, and Directive 98/30/EC of the European Parliament and of the Council of 22 June 1998 concerning common rules for the internal market in natural gas.

  3. 3.

    Cases C-157/94 Commission v. Netherlands [1997] ECR I-5699, C-158/94 Commission v. Italy [1997] ECR I-5789, C-C-159/94 Commission v. France [1997] ECR I-5815, see Buschle (2001), pp. 301–342 and 320.

  4. 4.

    See Bye and Hope (2005).

  5. 5.

    Conclusions of the European Council of 4 February 2011, EUCO 2/1/11 REV 1.

  6. 6.

    Directive 2003/54/EC of the European Parliament and of the Council of 26 June 2003 concerning common rules for the internal market in electricity; OJ L 176/37, 15.7.2003 and Directive 2003/55/EC of the European Parliament and of the Council of 26 June 2003 concerning common rules for the internal market in natural gas and repealing Directive 98/30/EC, OJ L 176, 15.7.2003, pp. 57–78 .

  7. 7.

    Article 10 of Directive 2003/54/EC and Article 9 of Directive 2003/55/EC for transmission, Article 15 of Directive 2003/54/EC and Article 13 of Directive 2003/55/EC for distribution, and Article 19 of Directive 2003/54/EC and Article 17 of Directive 2003/55/EC for unbundling of accounts.

  8. 8.

    Article 20 of Directive 2003/54/EC and Article 18 of Directive 2003/55/EC .

  9. 9.

    Article 23 of Directive 2003/54/EC and Article 25 of Directive 2003/55/EC .

  10. 10.

    Inquiry pursuant to Article 17 of Regulation (EC) No 1/2003 into the European gas and electricity sectors (Final Report), COM/2006/0851 final.

  11. 11.

    Directive 2009/72/EC of the European Parliament and of the Council of 13 July 2009 concerning common rules for the internal market in electricity, OJ L 211/55, 14.8.2009; Directive 2009/73 of the European Parliament and of the Council of 13 July 2009 concerning common rules for the internal market in natural gas, OJ L 211/94, 14.8.2009.

  12. 12.

    Regulation (EC) No 713/2009 establishing an Agency for the Cooperation of Energy Regulators, OJ L 211/1, 14.8.2009.

  13. 13.

    See in more detail Hofmann (2014), pp. 131–140.

  14. 14.

    Press Release at http://europa.eu/rapid/press-release_IP-15-4828_en.htm. See also Riley (2012).

  15. 15.

    http://ec.europa.eu/competition/sectors/energy/legislation_en.html.

  16. 16.

    Regulation (EC) No. 1228/2003 of the European Parliament and of the Council of 26 June 2003 on conditions for access to the network for cross-border exchanges of electricity, OJ L 176/1, 15.7.2003.

  17. 17.

    Regulation (EC) No 1775/2005/EC on conditions for access to the gas transmission networks, OJ L 289/1, 3.11.2005.

  18. 18.

    Under the Second Package : Article 3(2) of the Annex to Regulation (EC) No 122812003 according to Commission Decision of 9 November 2006 amending the Annex to Regulation (EC) No 122812003 on conditions for access to the network for cross-border exchanges in electricity.

  19. 19.

    Ìn February 2014, market coupling took place between Norway and 14 Member States in North Western Europe, http://europa.eu/rapid/press-release_MEX-14-0204_en.htm. In May 2014, Spain and Portugal joined. In February 2015, Italy coupled with France, Austria and Slovenia.

  20. 20.

    Regulation (EC) No 714/2009 on conditions for access to the network for cross-border exchanges in electricity and repealing Regulation (EC) No 1228/2003, OJ L 211/15, 14.8.2009, and Regulation (EC) No 715/2009 on conditions for access to the natural gas transmission networks and repealing Regulation (EC) No 1775/2005, OJ L 211/36, 14.8.2009.

  21. 21.

    Articles 170–172 TFEU, see Buschle (2015).

  22. 22.

    Regulation (EC) No 347/2013 on guidelines for trans-European energy infrastructure, OJ L 115/39, 25.4.2013.

  23. 23.

    Regulation 1316/2013 of the European Parliament and of the Council of 11 December 2013 establishing the Connecting Europe Facility Regulation OJ L 348/129, 20.12.2013.

  24. 24.

    Directive 2001/80/EC on the limitation of emissions of certain pollutants into the air from large combustion plants, OJ L 309/1, 27.11.2001.

  25. 25.

    Directive on industrial emissions (integrated pollution prevention and control), OJ L 334/17, 17.12.2010.

  26. 26.

    Directive 2003/87/EC of the European Parliament and of the Council 13 October 2003 establishing a scheme for greenhouse gas emission allowance trading within the Community, OJ L 275/23, 25.10.2003.

  27. 27.

    Commission Communication (2014).

  28. 28.

    Annex I of Directive 2009/28/EC. The Directive also sets forth a mandatory target for the transport sector of 10 % by 2020.

  29. 29.

    Communication ‘A policy framework for climate and energy in the period from 2020 to 2030’ mentions an expected 21 % proportion ofrenewable energy in the total final energy consumed.

  30. 30.

    Article 16 of Directive 2009/28/EC.

  31. 31.

    Commission Communication (2013), p. 15. In the Communication ‘A policy framework for climate and energy in the period from 2020 to 2030’, the Commission proposes to replace binding targets forrenewable energy per Member State by an overall target of 27 % for the EU, as well as a greenhouse gas emissions reduction target of 40 % by 2030.

  32. 32.

    Commission Communication (2014), p. 7.

  33. 33.

    Directive 2012/27/EU on energy efficiency , OJ L 315/1, 14.11.2012. This Directive repealed Directive 2006/32/EC on energy end-use efficiency services, OJ L 114/64, 27.4.2006, as well as Directive 2004/8/EC on the promotion of cogeneration based on a useful heat demand in the internal energy market, OJ L 52/50, 21.2.2004.

  34. 34.

    Most importantly Directive 2010/31 on the energy performance of buildings, OJ L 153/13, 18.6.2010; Directive 2010/30/EU on the indication by labelling and standard product information of the consumption of energy and other resources by energy-related products, OJ L 153/1, 18.6.2010; Directive 2009/125/EC establishing a framework for the setting of ecodesign requirements for energy-related products, OJ L 285/10, 31.10.2009. Under the latter two Directives, a broad range of tertiary legislation for individual product categories has been adopted.

  35. 35.

    Regulation (EU) No 994/2010 concerning measures to safeguard security of gas supply, OJ L 295/1, 12.11.2010. The Regulation repealed Directive 2004/67/EC concerning measures to safeguard security of natural gas supply, OJ L 127/92, 29.4.2004. ASecurity of Supply Directive, Directive 2005/89/EC concerning measures to safeguard security of electricity supply and infrastructure investment, OJ L 33/22, 4.2.2006, has never gained the same practical relevance.

  36. 36.

    Directive 2009/119/EC imposing an obligation on Member States to maintain minimum stocks of crude oil and/or petroleum products, OJ L 265/9, 9.10.2009.

  37. 37.

    Case 72/83 Campus Oil [1984] ECR 2727.

  38. 38.

    E.g. Case C-483/99 Commission v. France [2002] ECR I-4781.

  39. 39.

    Case E-2/06 ESA v. Norway [2007] EFTA Ct. Rep. 163.

  40. 40.

    See Buschle (2001), p. 327 ff.

  41. 41.

    European Commission, A Framework Strategy for a Resilient Energy Union with a Forward-Looking Climate Change Policy, COM (2015) 80 final of 25 February 2015.

  42. 42.

    ESA Energy Sector Inquiry, page 42.

  43. 43.

    Energy Strategy 2020 of the Government of Liechtenstein, page 26 ff.

  44. 44.

    ESA Energy Sector Inquiry, page 51.

  45. 45.

    ESA Energy Sector Inquiry, page 52.

  46. 46.

    Claes, The process of Europeanization—the case of Norway and the Internal Energy Market, ARENA Working Papers WP 02/12.

  47. 47.

    Statistics Office, figures for 2012, http://www.ssb.no/en/elektrisitetaar. The remainder of domestic generation comes from gas and wind.

  48. 48.

    Bye and Hope (2005), pp. 5 ff.

  49. 49.

    ESA Sector Inquiry, p. 20.

  50. 50.

    ESA Sector Inquiry, p. 38.

  51. 51.

    EFTA’s Key Exports, http://www.efta.int/statistics/efta-in-figures.

  52. 52.

    COM(2014) 330 final, 28.5.2014.

  53. 53.

    COM(2015) 80 final, 25.02.2015, p. 7.

  54. 54.

    Directive 96/92/EC was incorporated into the EEA Agreement by Joint Committee Decision 168/1999 on 26 November 1999, and entered into force on 1 July 2000.

  55. 55.

    Directive 98/30/EC was incorporated into the EEA Agreement by Joint Committee Decision 123/2001 on 28 September 2001 and entered into force on 1 August 2002.

  56. 56.

    Lit (h) of Joint Committee Decision 146/2005.

  57. 57.

    Defined as ‘any system with consumption of less than 3000 GWh in the year 1996, where less than 5 % of annual consumption is obtained through interconnection with other systems’.

  58. 58.

    Article 26(1) of Directive 2003/54/EC .

  59. 59.

    As possible under Article 15(2) of Directive 2003/54/EC .

  60. 60.

    JCD No 146/2005 of 2 December 2005.

  61. 61.

    Directive 94/22/EC on the conditions for granting and using authorizations for the prospection, exploration and production of hydrocarbons, OJ L 164/3, 30.6.1994.

  62. 62.

    Claes, pp. 10 ff.

  63. 63.

    JCD No 101/2008.

  64. 64.

    A Member State/Contracting Party ‘in which the first commercial supply of its first long-term natural gas supply contract was made not more than 10 years earlier’.

  65. 65.

    Joint Committee Decision 146/2005 Litra (g).

  66. 66.

    The Energy Community Contracting Parties adopted theThird Package in 2011 By Ministerial Council Decision 2011/02/MC-EnC, http://www.energy-community.org/portal/page/portal/ENC_HOME/INST_AND_MEETINGS?event_reg.category=E12497.

  67. 67.

    Conclusions adopted by the EEA Council its 42nd meeting of 19 November 2014, No 16.

  68. 68.

    Directive 2008/1/EC concerning integrated pollution prevention and control, OJ L 24/8, 29.1.2008.

  69. 69.

    Directive 1999/32/EC relating to a reduction in the sulphur content of certain liquid fuels, OJ L 121/13, 11.5.1999.

  70. 70.

    This Decision also incorporated also the amendments introduced by Directive 2004/101/EC. Directive 2009/29/EC amending Directive 2003/87/EC so as to improve and extend the greenhouse gas emission allowance trading scheme of the Community has been incorporated into the EEA Agreement at point 21(a)(l) of Annex XX.

  71. 71.

    Directive 2001/77/EC of the European Parliament and of the Council of 27 September 2001 on the promotion of electricity produced fromrenewable energy sources in the internal electricity market

  72. 72.

    EEA Joint Committee Decision 102/2005 of 8 July 2005. The Directive entered into force for the EEA EFTA Member States in September 2006.

  73. 73.

    JCD 162/2011. The Directive entered into force on the following day.

  74. 74.

    JCD 37/2004 of 23 April 2004. The Directive entered into force on 4 January 2006.

  75. 75.

    JCD 151/2006 of 8 December 2006. The Directive entered into force on 1 October 2007. In the EU, Directive 2004/8/EC was repealed by Directive 2012/27/EU.

  76. 76.

    Incorporated by JCD 69/2010. The Directive entered into force on 1 November 2012. For information purposes, this Directive is also referred to under Annex IV.

  77. 77.

    Incorporated by JCD 217/2012 of 7 December 2012. The Directive entered into force on 1 June 2013.

  78. 78.

    Incorporated by JCD 69/2010 of 11 June 2010. The Regulation entered into force on 12 June 2010.

  79. 79.

    JCD 49/2007 of 8 June 2007. The Directive entered into force on 1 November 2008.

  80. 80.

    Council Directive 2006/67/EC of 24 July 2006 imposing an obligation on Member States to maintain minimum stocks of crude oil and/or petroleum products, OJ L 217, 8.8.2006.

  81. 81.

    St.prp. nr 100 (1991–1992) Om samtykke til ratifikasjon av Avtale om Det eruopeiske økonomiske samarbeidsområde (EØS), undertegnet i Oporto 2 mai 1992

  82. 82.

    Council Directive 68/414/EEC of 20 December 1968 imposing an obligation on Member States of the EEC to maintain minimum stocks of crude oil and/or petroleum products.

  83. 83.

    Proposition 5 (2012–2013) to the Storting on the EEA Agreement and Norway’s other agreements with the EU, Melding to Stortinget (2012–2013) EØS-avtalen og Norges øvrige avtaler med EU, English version: Proposition 5 (2012–2013) to the Storting on the EEA Agreement and Norway’s other agreements with the EU, textbook 2.3, http://www.regjeringen.no/en/dep/ud/documents/propositions-and-reports/reports-to-the-storting/2012-2013/meld-st-5-20122013/2/3.html?id=732546

  84. 84.

    E.g. the Norwegian Government’s Proposition 5 (2012–2013) to the Storting.

  85. 85.

    Commission Staff Working Document—A review of the functioning of the European Economic Area, SWD (2012) 425 final, 7.12.2012, page 4.

  86. 86.

    See above regarding Article 12(2) of Regulation 1228/2003/EC.

  87. 87.

    As regards the Energy Community, where the socio-economic situation is significantly different from most EU Member States, see Buschle (2014).

  88. 88.

    Commission Staff Working Document—A review of the functioning of the European Economic Area SWD (2012) 425 final, 7.12.2012, p. 8.

  89. 89.

    Commission Staff Working Document—A review of the functioning of the European Economic Area (2012), p. 7.

  90. 90.

    Articles 99 and 100 EEA.

  91. 91.

    Case E-17/11 Aresbank [2012] EFTA Ct Rep, 916.

  92. 92.

    Energy Sector Inquiry Concluding Report of 10 January 2007, page 56.

  93. 93.

    COMP/36.072.

  94. 94.

    Claes, p. 15; Baudenbacher (2010), p. 116.

  95. 95.

    Such as the CDC project for the purchase of gas from Turkmenistan which is currently not pursued further by the Commission. It may be noted that Donald Tusk’s proposal for the creation of an Energy Union of 2014 also calls for the creation of a single buyer entity.

  96. 96.

    Evidently, energy undertakings also benefit from State aid as in any other sector, such as the (incompatible) State guarantees given to the publicly owned electricity companies Landsvirkjun and Orkuveita Reykjavíkur in Iceland, see Decision No 302/09/COL of 8 July 2009.

  97. 97.

    ESA so far has not declared long-term PPAs unlawful or incompatible with the State aid rules In the European Union, the Commission issued Decisions against Hungary’s—IP/08/850—and Poland’s—IP/07/1408—long-term PPA.

  98. 98.

    Decision No 142/00/COL of 26 July 2000.

  99. 99.

    Decision No 305/09/COL of 8 July 2009. Another electricity supply contract between a municipal company and a pulp mill was subsequently approved on similar grounds, Decision No 44/10/COL of 10 February 2010. For a PPA based on concession power with the highly unusual contractual duration of 50, 5 years at fixed prices and without tender, ESA expressed doubts as to whether this stands the private investor test and opened the formal procedure, Decision No 393/11/COL of 14 December 2011.

  100. 100.

    Decision No 56/11/COL of 2 March 2011.

  101. 101.

    Decision No 174/98/COL of 8 July 1998 and Decisions No 391/11/COL and No 392/11/COL of 14 December 2011.

  102. 102.

    Decision No 261/12/COL of 4 July 2012.

  103. 103.

    In Decision No 174/98/COL, however, the yardstick for the test was the rate of return on investments.

  104. 104.

    Decisions No 40/03/COL of 14 March 2003, No. 187/05/COL of 20 July 2005 and No 344/09/COL of 23 July 2009.

  105. 105.

    Decision No 67/15/COL of 25 March 2015, Decisions No 206 and 207/15/COL of 20 May 2015.

  106. 106.

    Decision No 90/02/COL of 31 May 2002. The continuation of the scheme was subject to Decision No 411/06/COL of 19 December 2006.

  107. 107.

    In Norway, energy-intensive industries consume around one-third of the total capacity. The prices paid under long-term PPA are far below the long-run marginal costs, see. Bye and Hope (2005), p. 16. This in itself had already caused the Authority’s concerns with regard to competition and State aid law, see ESA Energy Sector Inquiry, at points 133 ff.

  108. 108.

    With the exception for electricity used in administration buildings.

  109. 109.

    Decision No 148/04/COL of 30 June 2004. Subsequent amendments made by Norway to the tax exemption scheme were accepted by the Authority in Decisions No 149/04/COL of 30 June 2004 and 447/07/COL of 10 October 2007.

  110. 110.

    The same scheme later formed the subject-matter of Decision No 370/04/COL of 15 December 2004.

  111. 111.

    Decision No 342/09/COL of 23 July 2009.

  112. 112.

    Decision No 151/05/COL of 22 June 2005.

  113. 113.

    http://www.eftasurv.int/media/state-aid-guidelines/Part-III---Aid-in-the-context-of-the-greenhouse-gas-emission-allowance-trading-scheme-post-2012.pdf.

  114. 114.

    Decision No 355/13/COL of 25 September 2013.

  115. 115.

    Decision No 125/06/COL of 3 May 2006. Budget increases for the Fund were subject to Decisions 536/09 of 16 December 2009 and 75/10/COL of 10 March 2010, its prolongation covered by Decision 486/10 of 15 December 2010.

  116. 116.

    Decision 248/11/COL of 18 July 2011.

  117. 117.

    E.g. Decisions No 487/10/COL, 488/10/COL, 490/10/COL and 491/10/COL of 15 December 2010, Decision 68/11/COL of 11 March 2011.

  118. 118.

    Decision No 158/12/COL of 9 May 2012, Decision No 518/12/COL of 9 December 2012 and Decision No 91/14/COL of 12 March 2014. Recently, aid granted to a district heating plant fuelled by biomass (wood-chips) in Balzers, Liechtenstein, was also approved by ESA, Decision No 171/14/COL of 24 April 2014.

  119. 119.

    Decision No 257/03/COL of 11 December 2003. As Norway subsequently decided not to implement the scheme, the case was closed, Decision No 167/04/COL of 7 July 2004.

  120. 120.

    Not considered State aid by Decision No 125/11/COL of 13 April 2011.

  121. 121.

    Decision No 69/09/COL of 18 February 2009. The prolongation of the scheme was cleared by Decision No 56/14/COL of 12 February 2014.

  122. 122.

    Decision No 329/09/COL of 15 July 2009. The fact that the direct beneficiaries of the aid were households, not undertakings, did not prevent the finding of State aid, as the scheme would grant producers and importers of the alternative heating technologies covered by the scheme an indirect economic advantage. The scheme was subsequently integrated into the Energy Fund, see Decision No 299/11/COL of 5 October 2011.

  123. 123.

    Decisions No 39/11/COL of 9 February 2011 and 304/13/COL of 10 July 2013.

  124. 124.

    Decision No 150/15/COL of 21 April 2015.

  125. 125.

    Directive 2009/31/EC on the geological storage of carbon dioxide, OJ L 140/114, 5.6.2009.

  126. 126.

    Incorporated into the EEA Agreement at point 21(1)(a) of Annex XX.

  127. 127.

    The body of case-law is at a similar level as the Commission’s which includes Commission Decision N74/2009 of 8.4.2009 on United Kingdom—CCS Demonstration Competition—Feed; Commission Decision N381/2010 of 27.10.2010 on The Netherlands—Aid for a CCS Project in the Rotterdam Harbour Area; Commission Decision N190/2009 on The Netherlands—CO2 Catch-up Pilot Project at Nuon Buggenum Plant.

  128. 128.

    Decision No 302/05/COL of 30 November 2005. Subsequently, ESA also cleared certain amendments to the Gassnova scheme, Decisions No 768/08/COL of 17 December 2008 and 348/10/COL of 15 September 2010.

  129. 129.

    Decision No 503/08/COL of 16 July 2008.

  130. 130.

    Decision No 91/12/COL of 15 March 2012.

  131. 131.

    Decision No 27/09/COL of 29 January 2008.

  132. 132.

    Decision No 74/13/COL of 20 February 2013.

  133. 133.

    Case E-6/08 ESA v. Norway [2009–2010] EFTA Ct. Rep. 4.

  134. 134.

    Case E-12/14 ESA v. Iceland, judgment of 28 January 2015, not yet reported.

  135. 135.

    Case E-21/14 ESA v. Iceland, judgment of 31 March 2015, not yet reported.

  136. 136.

    Case C-234/89 Delimitis [1991] ECR 935.

  137. 137.

    Case E-7/01 Hegelstad [2002] EFTA Ct. Rep. 310.

  138. 138.

    Opinion of Advocate General Jääskinen of 16 April 2013, Joined Cases C‑105/12, C‑106/12 and C‑107/12 Essent, not yet reported, at paragraph 44.

  139. 139.

    Case E-2/06 ESA v. Norway [2007] EFTA Ct Rep. 163; see Buschle (2001), p. 329.

  140. 140.

    Norwegian Act No. 16 of 14 December 1917, the ‘Waterfall Acquisition Act’.

  141. 141.

    Case E-2/06 ESA v. Norway [2007] EFTA Ct Rep. 163, paragraph 86.

  142. 142.

    Arnesen, pp. 287–294; Norberg (2007), pp. 294–300.

  143. 143.

    Joined Cases E-5/04, E-6/04 and E-7/04 Fesil and Finnfjord [2005] EFTA Ct. Rep. 117.

  144. 144.

    Decision No 148/04/COL of 30 June 2004, see above.

  145. 145.

    Case C-143/99 Adria Wien [2001] ECR I-8365.

  146. 146.

    See in more details Buschle (2006), pp. 757–788.

  147. 147.

    Commission Staff Working Document—A review of the functioning of the European Economic Area (2012), p. 9.

  148. 148.

    Annual Report of EFTA 2014, p. 51.

  149. 149.

    In ERGEG, the national regulators’ organisation in place before the entry into force of the Third Package , the EEA/EFTA States participated as observers.

  150. 150.

    The Treaty establishing the Energy Community sets up a Regulatory Board which in some respects serves as a model for ACER .It is interesting to note that The Treaty establishing the Energy Community Ministerial Council’s High Level Reflection Group, in its report published on 12 June 2014, proposes to phase out the Regulatory Board and replace it by Contracting Parties’ membership in ACER , http://www.energy-community.org/portal/page/portal/ENC_HOME/NEWS/News_Details?p_new_id=9161.

  151. 151.

    In accordance with Regulation (EC) No 713/2009,ACER has been vested with powers to take direct binding decisions in certain areas such as exemption for new interconnectors.

  152. 152.

    For instance, the British Prime Minister David Cameron, in his famous speech on the European Union in January 2014 made explicit reference to improvements needed in the internal market for energy, see http://www.theguardian.com/politics/2013/jan/23/david-cameron-eu-speech-referendum.

  153. 153.

    See for instance Hirsbrunner (2001), pp. 301–342 and 285–298.

  154. 154.

    See recently the European Commission (2015).

  155. 155.

    See Kopač and Buschle (2014), p. 26 (in English: Crisis and structure: From Ukraine to a European Energy Union, europolitics magazine Autumn 2014).

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Correspondence to Birgitte Jourdan-Andersen .

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Buschle, D., Jourdan-Andersen, B. (2016). Energy Law. In: Baudenbacher, C. (eds) The Handbook of EEA Law. Springer, Cham. https://doi.org/10.1007/978-3-319-24343-6_36

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