letter

Simo Nurmi Energy Authority of Finland Lintulahdenkuja 2A Our Ref: 21.11.2022 No 17-4/22- 0066/7133-1 FI-00530 Helsinki Finland Feedback on the terms and conditions of the LNG terminal Dear Mr. Nurmi, On the 21st of October 2022, the Finnish Energy Authority published the terms and conditions that were forwarded for coordination from the LNG terminal operator Floating LNG Terminal Finland OY. Coordinating the terms and conditions of the Floating LNG Terminal Finland OY is a crucial step towards having an additional source of natural gas in the region. As the interest for using the terminal is extremely high throughout the region and the overall security of supply depends on the access to the terminal, the terms and conditions for using the terminal must be as clear and balanced as possible. The market participants have been actively involved in the process of the public consultation. Considering the main concerns of the market participants, the Ministry of Economic Affairs and Communications would like to echo and stress the following. The terms and conditions of using the terminal must provide balanced responsibilities both to the terminal user and to the operator of the terminal. Unevenly distributed liabilities among the parties might lead to excessive administrative burden for the terminal user. Considering the impact of the energy crisis to the suppliers and the liquidity issues concerning most of the suppliers, an unbalanced liability will affect the possibility to get access to the terminal. Therefore, we urge the national regulatory authority of Finland to stand for a balanced result when comes to the responsibilities of the terminal user and the terminal operator. In addition, the terms and conditions should facilitate flexible conditions for the user of the terminal considering the current energy crisis and price volatility. For example, from our side the requirement to present a new guarantee in two business days might prove to be inflexible towards some suppliers in the region. Furthermore, conditions set to the users (such as the requirement to correspond to ISO 27001) during difficult times tend to burden the users to an unnecessary extent, at least in the beginning of the season. We urge the authority to consider having sufficient level of flexibility on the abovementioned terms and to guarantee the smooth usage of the terminal at least in the forthcoming heating season by Suur-Ameerika 1 / 10122 Tallinn / ESTONIA Phone: +372 625 6342 / Fax: +372 631 3660 / E-mail: [email protected] / http://www.mkm.ee avoiding administrative hurdles to the user as much as possible. With best regards, (signed digitally) Riina Sikkut Minister of Economic Affairs and Infrastructure Copy to Ministry of Economic Affairs and Employment of Finland Rein Vaks +372 625 6347 [email protected] 2 (3) 3 (3)