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PETROVIETNAM GAS J. S. CORPORATION (PV GAS)
FINAL REPORT
#1300, 3050 Post Oak Blvd, Houston, TX, USA 77056 www.galwaygroup.com #22-04, Suntec Tower 3, Singapore,
038988
Galway Energy Advisors LLC
TABLE OF CONTENTS
Table of Figures.............................................................................................................................................................4
United Kingdom........................................................................................................................................................9
Belgium...................................................................................................................................................................11
Italy .........................................................................................................................................................................12
France......................................................................................................................................................................14
Spain........................................................................................................................................................................16
Russia ......................................................................................................................................................................18
Canada.....................................................................................................................................................................22
Chile ........................................................................................................................................................................24
Argentina.................................................................................................................................................................26
Japan........................................................................................................................................................................28
South Korea.............................................................................................................................................................30
Taiwan.....................................................................................................................................................................32
China .......................................................................................................................................................................34
India ........................................................................................................................................................................37
Singapore ................................................................................................................................................................39
Thailand ..................................................................................................................................................................41
Indonesia .................................................................................................................................................................46
6. Abbreviations......................................................................................................................................................65
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TABLE OF FIGURES
Figure 33 End User Prices in Selected Cities in China................................................................................................34
Figure 41 Gas Price Pooling Mechanism ....................................................................................................................43
Figure 42 Gas Pooling and Resultant End User Gas Prices.........................................................................................43
Figure 48 Gas Prices in Malaysia - Spot Vs. Subsidized.............................................................................................48
1. EXECUTIVE SUMMARY
The Global and Regional Gas Market Study (Study) has been performed at the request of PV
Gas. The purpose of the Study is to derive useful lessons and examples from the analysis of 19
gas markets, notably in respect of gas market structure and gas pricing mechanisms. The bulk of
the Study comprises the individual analysis of each of the 19 gas markets, using a standard
template in each case. Based on the findings from those analyses, the Study concludes by making
recommendations for the future evolution of the gas market structure and gas pricing
mechanisms in Vietnam.
The Study focuses on the different methods by which other governments maintain control over
their respective gas markets – whether by full government ownership, partial ownership, or
solely through regulatory oversight in the case of fully liberalized markets.
In its recommendations on the gas market structure in Vietnam, the Study supports Vietnam’s
well-functioning present structure. Looking ahead, and based on experience from around the
world, the Study recommends that further liberalization be considered carefully and be measured
in decades rather than years. International examples show that further equitization of PV Gas, if
felt desirable, would certainly be possible without impairing government control of the gas
market. On the other hand, the Study strongly recommends against any move to renationalize PV
Gas (a joint-stock company), as international experience shows that this would be perceived
negatively by international markets and investors. The Study also offers some recommendations
on approaches and methods of regulatory oversight.
In respect of pricing, the analysis of the 19 gas markets shows a wide spectrum of variance, from
full government control of gas prices, to open markets where prices are set by market forces.
Most gas markets (including Vietnam) are positioned somewhere between the two extremes.
However, even in the open markets, regulatory oversight in the gas midstream is commonplace.
To prevent abuse of market power, regulations might include transmission tariffs and open
access requirements for third party infrastructure users.
The Study provides insight into the pricing issues which arise when expensive imports (mainly
LNG, but also pipeline gas) are introduced into markets hitherto supplied only with cheaper
domestic gas – a situation which Vietnam will face within a few years. The Study analyses the
different ways in which this issue is being handled in Thailand, India, Malaysia and China.
In its recommendations on gas pricing mechanisms for Vietnam, the Study endorses the existing
gas pricing structure as effective and workable, and recommends maintaining the status quo for
the time being. In respect of planned imports of more expensive LNG, the Study considers gas
price pooling. The Study concludes by advising against a pooling solution based on international
experiences with price pooling mechanisms. Furthermore, the Study strongly endorses the
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2. STUDY INTRODUCTION
This section provides the background to this Global and Regional Gas Market Study and
describes the approach and methodology applied to perform the Study.
The organization therefore commissioned Galway to perform a study covering 19 specified gas
markets - located in both the Atlantic and Pacific basins - in order to derive “lessons learned,”
which can be relevant for the gas market in Vietnam.
• Introduction
• Historic Gas Market Development
• Current Regulatory Structure and Energy Policy
• The Government’s Methods of Control
• Pros and Cons
• Any proposed changes
• Lessons learned
The Study analyzes how various governments "control" their gas markets through having
majority shareholdings in the companies which purchase, transport, import and/or market gas in
their respective countries. The Study also analyses the Regulatory Structure for each gas market.
The Study analyses gas pricing in the different gas markets, focusing mainly on “lessons
learned” in those gas markets which not only have domestic gas, but which also import gas
(pipeline gas or LNG). From this analysis, the Study found various examples of how
governments control gas pricing, including when LNG imports were introduced. On the specific
question of gas price pooling, the Study identifies markets where pooling has either been
implemented, or has been discussed.
Finally, based on the findings highlighted herein, in Section 5 the Study sets out a set of
recommendations for Vietnam in respect of both gas market structure and pricing mechanisms.
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LESSONS LEARNED
Liberalized market and transparent gas price discovery helps to create an efficient market.
However, seasonal pricing dynamics and market factors can cause very significant fluctuations
in gas prices that might not be acceptable to customers in a growing economy.
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BELGIUM
LESSONS LEARNED
A diversified portfolio approach of using long-term contracts and spot market transactions to
meet domestic gas demand needs has provided system flexibility and has helped mitigate price
volatility.
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ITALY
Over the years, gas pricing in Italy been burdened by rising taxation resulting from a number of
taxes imposed at the federal as well as regional levels. Although gas prices at the pre-tax stage
are comparable to prices in the rest of Europe, the post-tax prices are substantially higher.
For industrial customers, the price is usually based on a volume charge and maximum demand
charge. The customer indicates to the supplier the maximum daily volume and the total expected
volume for the year. The price is thus determined taking maximum volumes into consideration.
The volume charge is indexed to gas-oil, crude oil and heavy fuel-oil prices (mirroring the type
of indexation and elasticity to energy price changes which is incorporated into the long-term
import contracts). There are various volume discounts that can be applied to the price. The
demand element of the tariff also has a base charge that is indexed. The indexation is annual, and
is based on the movement in wages and in PPI.
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Pros Cons
Gas trading has introduced liquidity in the High levels of taxation pose a high burden for
market, and more favorable unregulated gas gas end users in the industrial, commercial
prices available to market participants and residential sectors
Government efforts to decouple gas prices Oil and oil products indexation has resulted in
from oil indexation will result in more regulated prices that are higher than the
competitive gas prices unregulated prices set by the market
Over the last couple of years, import contracts with major pipeline suppliers such as Russia,
Algeria and Norway have been renegotiated to reduce the oil indexation, with varying degrees of
success. Overall, there will be a significant reduction in oil price linkage, which should make it
easier to implement the same in the reference prices.
Finally, a tax reform decree was signed in 2013 that would reduce the tax rates applicable to gas
prices, especially for energy intensive industries.
LESSONS LEARNED
Imposing high levels of taxation on commodities that are critical to sustained economic growth
and that are already exposed to the volatility of international import prices is counter-productive
over the long run, and has negatively impacted the Italian economy.
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FRANCE
The vast majority of transactions on the French wholesale market are bilateral contracts. GDF’s
control over the majority of gas supplies and the state’s moratorium on the exploration of shale
plays prevents the French market from achieving higher levels of liquidity.
Two pricing structures are available on the French market: regulated retail prices and market
prices. Regulated retail prices are the prices charged by the incumbent gas suppliers (GDF et al).
These prices are regulated by the CRE based on a predetermined gas price formula. Alternative
suppliers charge market-based prices. Market-based contract prices reflect the type of indexation
and price elasticity incorporated in long-term contracts.
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ANY PROPOSED CHANGES
There are no proposed changes to natural gas pricing structures at this time.
LESSONS LEARNED
The liberalization of commodity markets in the upstream and downstream will likely benefit the
French gas consumer over the long haul, and afford more competitive wholesale and retail fuel
prices. In the period immediately following market liberalization though, distribution companies
and their shareholders have suffered significant losses due to their take or pay commitments to
international gas suppliers. The first key lesson is that a regulated, government-controlled
midstream enables the development and functioning of a liberalized market. Finally, the core
lesson from the French experience is that, although market liberalization is a positive, the rate at
which the market is deregulated is critical to its success. Introduced too quickly, liberalization of
gas monopolies can significantly hinder the survival and well-functioning of core distribution
companies.
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SPAIN
The six LNG regasification terminals are key balancing points for the MS-ATR trading system.
Most of the trades in the exchange are around swaps of storage capacity in the regasification
terminals.
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LESSONS LEARNED
Although prices were deregulated and a gas trading platform was put into place, the development
of an organized hub with transparent gas prices reflecting supply and demand balances was
essential to the proper functioning of the gas market.
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RUSSIA
In 2000, prices were decoupled from inflation and were completely brought under the control of
the Federal Tariff Service (FTS). The Russian Government defines the variation parameters for
regulated wholesale gas prices. The FTS of Russia approves specific regulated wholesale prices
for various price zones with due regard to consumer remoteness from gas production areas and
to consumer categories. This led to significant declines in domestic prices, but resulted in
challenges with WTO membership. Adding further pressure was the emergence of non-Gazprom
gas producers during the 2000s such as Novatek, who, despite paying higher transmission tariffs,
were allowed to sell at higher, unregulated prices, and thus making the economics of gas
production work. Increasingly higher gas volumes were thus purchased by customers in the
unregulated market, while Gazprom started restricting the volumes sold at regulated prices
(based upon an annual quota system).
In 2007, the Russian government announced upward price adjustments over a five year period
with the aim of achieving ‘export netback parity’ by 2011. However, since lower oil prices were
assumed in determining netbacks from European sales, and since the ruble started depreciating,
prices by the end of 2010 were still significantly lower than export netback parity. In December
2010, the government adopted regulation towards a step-by-step liberalization of the gas market
with a transitional period from 2011 to 2014.
Gazprom production was priced based on equal yield of gas supplies to the domestic and foreign
markets. The FTS established decreasing coefficients during the transitional period to bring the
prices to the export netback parity level. These coefficients were an integral part of the pricing
formula, taking into account specific features of pricing in the domestic market. Additionally, the
government set variance limits for the period of 2013-2014, ranging from -3 to +3 percentage
points. These pricing principles were to be applied to all consumers other than households.
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Starting in 2015, Russian Ministries were instructed to develop a coordinated transport tariffs
regulatory system to replace gas price regulation.
The Russian government introduced netback price parity in the domestic natural gas market with
the aim of achieving equal revenue for gas supplies on the domestic and export markets. To this
end, the strategy was to cap annual export gas price growth until the domestic market was fully
liberalized. By applying a decreasing coefficient to the price of export gas, gas sellers were able
to increase export gas prices, but by a lesser amount each year, and until export prices equal
domestic gas prices.
LESSONS LEARNED
The Russian government’s unrealistic target to set domestic prices based on export netback
parity has continued to have a destabilizing effect on the Russian economy. A more prudent
approach would be to gradually deregulate, provide a level playing field for gas market players,
and let the market find the right price. To that end, further development of the electronic trading
system would be a step in the right direction.
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UNITED STATES
It became apparent that the price ceilings established by FPC provided inadequate incentives for
natural gas producers to explore for or develop new fields. As a result, in 1989 the government
removed all price controls and FERC authority over wholesale natural gas prices. To date,
midstream pipeline tariffs remain regulated by FERC. In the US downstream market, PDCs set
gas distribution tariffs for the LDCs.
Today, the US has two distinct markets for natural gas: a physical market, in which gas is
physically sold, purchased and delivered; and a financial market, where derivatives are traded.
Gas can be sold and purchased on the physical and financial markets on the basis of spot trades
(daily market), monthly indexed, or futures (1-36 months in advance) trades.
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Gas is sold and purchased both on the physical and financial markets. Thousands of transactions
take place daily on the physical gas markets between gas producers and buyers. Financial
markets see an exponentially larger number of daily transactions. Only 20% of transactions are
fixed price deals; the rest of gas contracts are priced based on a daily or monthly index, or based
on other financial instruments.
LESSONS LEARNED
The US natural gas market is made up of thousands of buyers and sellers, and gas prices are set
by the market. It is the most dynamic and arguably the most efficient gas market globally.
However, the process of getting to where the market is today took over a century of trial and
error. Moreover, the US Federal and State governments still exercise considerable regulatory
oversight over this highly liberalized gas market – the largest gas market in the world.
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CANADA
The commodity cost is set by the market, where the New York Mercantile Exchange is used as a
benchmark. Futures contracts trade in units of 10,000 million BTU’s and the price is based on
delivery at Henry Hub (“HH”). The AECO price hub in Alberta is the main Canadian pricing
point. It has become a price-setting benchmark in Canada, similar to HH in the US.
There are two types of retail structures available to end consumers of natural gas in Canada: the
option to purchase gas from a distributor the prices of which are regulated by the provincial
authority (no mark-up is allowed), or the option to buy from a broker/marketer at a fixed price,
which is not regulated.
At 2013 prices of approximately $3.00/ million British Thermal Units (MMBtu) in Western
Canada, Canadian natural gas producers are earning insufficient returns to be able to attract
additional investment and to increase, or even sustain production. Hence, natural gas production
in Canada has followed a downward trend in recent years.
Nevertheless, natural gas priced below $4.00/MMBtu has displaced significant amounts of coal-
fired power generation. It is unclear whether domestic gas demand will be sufficient to push
wholesale gas prices above the $5.00/MMBtu level needed to encourage a significant resumption
in dry natural gas drilling activity. If domestic demand is unable to make up for and exceed lost
US import demand, natural gas prices may remain in the $3.00 - $4.00/MMBtu range in the
foreseeable future, and until LNG export terminals are developed.
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WHAT PRICING POLICIES AND MECHANISMS WHEN IMPORTS
INTRODUCED?
Canada is a net exporter of pipeline gas. Since 2009, it has imported limited amounts of LNG at
its Canaport LNG import terminal. These imports have been stored for resale into the North
American gas market during high-demand winter seasons when a margin on the price of
regasified LNG can be gained. The price of gas and LNG is fully deregulated and entirely set by
the market.
LESSONS LEARNED
Overall, a deregulated upstream market model, with regulated midstream pipeline tariffs, has
worked in Canada. However, despite the abundance of natural gas resource and of gas
production capacity, Canadian gas production is now decreasing, and Canada has been unable to
reach its full production potential and become an exporter of LNG. Geographic limitations and
imminent domain pipeline infrastructure development challenges have posed the greatest
obstacles in the face of development. Nevertheless, the federal and provincial governments’
support of gas production and exports, via the expedient approvals of LNG exports, has
incentivized many international players to invest in the development of gas export infrastructure
in both Western and Eastern Canada. It is clear in the case of Canada that the government, by
streamlining and expediting project approvals, has incentivized the development of resources and
of new energy projects.
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CHILE
The two existing LNG terminals are controlled by Enagas, GDF Suez and end users, all of which
have equity ownership in the projects. The Quintero terminal has a long term sales and purchase
agreement (“SPA”) with BG, and the Mejillones terminal has one with GDF Suez. LNG imports
have helped mitigate the seasonality of hydro power generation, as well as reduce diesel imports
volumes. Additionally, LNG imports have replaced lost Argentinian pipeline import volumes.
For these reasons, the country is planning to expand its LNG infrastructure.
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ARGENTINA
In January 2002, the government changed downstream gas prices from US dollars to Argentinian
pesos on a one-to-one basis, and froze these prices at 2001 levels. The freeze did not extend to
the wellhead, with producers being able to sell natural gas at market rates (although in
Argentinian pesos). However, ENERGAS did not approve any upstream price increases to be
passed through to the end-consumer. This meant that the price for domestic sales of natural gas
was frozen. Because domestic prices were effectively frozen, there was an incentive to export
the majority of gas produced, leaving domestic markets short of adequate gas supplies.
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As of April 2014, the government is formalizing a new tariff scheme for residential and
commercial consumers. Consumers that are able to decrease their demand by 20% will qualify to
retain the government subsidy on gas prices. Consumers who lower their demand by 5-20% will
continue to benefit from 50% subsidy, and those who show no decrease in consumption will lose
between 50% and 80% of the subsidy. As a result of this policy, the wellhead price of natural gas
is expected to rise manifold. Similarly, ENERGAS published new distribution tariffs increasing
distribution service fees by a factor of five (5).
LESSONS LEARNED
The domestic gas price freezes instituted by the Argentinian government in the 2000’s created an
unforeseen incentive to export a disproportionate share of natural gas production. Exports to
Chile, in turn, led to severe natural gas shortages on the domestic market. The continuation of
the domestic freeze in natural gas prices and the nationalization of YPF have made new
exploration and production activities less attractive, and have led to a loss in international
interest for upstream investment in Argentina.
One key lesson is that subsidizing expensive LNG imports can be ruinously expensive for the
government but is politically difficult to stop once it has been started.
Another key lesson derived from the Argentinian case study is that renationalization of a
domestic oil and gas company leads to significant international backlash, higher import prices on
gas and LNG, and a decrease or stagnation in international FDI.
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Pros Cons
No subsidy and hence all costs are passed Gas market reform has no impact on the rates
through to the end user charged for residential use. The current price
for residential user is around 30$/MMbtu
LESSONS LEARNED
Liberalization has no direct correlation to price reform and efficient market. Hence, market
evolution through controlled regulatory environment to increase competition is the key to any
developed market.
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SOUTH KOREA
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PROS AND CONS
Pros Cons
Government control through differential Subsidy could only be a short term solution
pricing to end user sectors
Cost plus system helps to control the price Cost plus system may also permit inefficiency
LESSONS LEARNED
The cost-plus pricing can be attractive for some markets where the demand sectors’ affordability
varies, and where the government seeks to incentivize the development of specific targeted
sectors.
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TAIWAN
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PROS AND CONS
Pros Cons
Government controls the price set to Lack of competition has resulted in high
industrial users and distribution companies prices for domestic gas
LESSONS LEARNED
The affordability of gas by end users is ensured by the government through price regulation.
Even though the prices are set based upon cost plus formulae, the full variability of the imported
cost is not allowed to be passed through to the end customer.
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CHINA
Different prices are set for different users, with higher natural gas prices set for non-residential
customers. Additionally, different prices are set for different sectors, with lower prices applicable
to the manufacturing and fertilizer sectors.
End-user gas prices are comprised of wellhead price, pipeline transportation tariff and of the end-
user price. The ex-plant (wellhead) price is typically proposed by the project developer and
adjusted by the central government. This price is based principally on the production cost of
natural gas (wellhead cost plus purification fee, financing cost and tax) plus the appropriate
margin for the producer. The wellhead price is a baseline, and producers and buyers can
negotiate up to 10% above it.
There has been a recent effort by NDRC to reform gas prices in China. The timeline and the
process are listed in the diagram below:
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LNG prices to be passed on to the end consumers. However, the process of price liberalization is
likely to take several years to unfold and to be fully reflected in the domestic market.
Pros Cons
Government controlled end user prices based The government/National Oil Company have
on cost plus formulae to subsidize the price of gas if the full price
cannot be passed through
LESSONS LEARNED
In China, the prices of domestic gas, more expensive imported pipeline gas and of LNG are at
different levels presently. Hence, with the introduction of LNG and pipeline gas imports price
reforms are needed to be introduced to accommodate the discrepancy between LNG imports and
gas received from alternative sources. The transition to a market price for gas is best achieved
through multiple stages of price increases to ease the impact on the domestic economy.
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INDIA
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PROS AND CONS
Pros Cons
Gas prices are not directly subsidized, but Gas demand from LNG is unlikely to rise due
quantities and prices are controlled and to price affordability issues
regulated by the government
LESSONS LEARNED
Gas pooling has been studied by the Indian government, but determined to be too complex and
unlikely to achieve the development of priority industrial sectors. Hence, in India’s case,
differential pricing through gas allocation has been implemented as the pricing mechanism of
choice for the government.
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SINGAPORE
Singapore has two sets of piped gas import contracts with Malaysia and Indonesia, described in
more detail in the next section.
The following table summarizes the various gas pricing contracts Singapore has:
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WHAT PRICING POLICIES AND MECHANISMS WHEN IMPORTS
INTRODUCED?
The Singapore gas market is accustomed to paying oil-linked prices for gas supply. The
mechanism for passing on the delivered energy price is well established, and hence the
introduction of LNG did not result in any significant modifications to the price mechanisms on
the domestic gas market.
Pros Cons
LESSONS LEARNED
Singapore is a developed economy that is accustomed to cost pass through for fuel indexed to
alternative products such as fuel oil. The introduction of LNG imports has not significantly
altered the domestic pricing of energy.
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THAILAND
The weighting of the above element varies between contracts (some prices are adjusted annually,
while others more frequently). Included below is the detailed price formula based on the above
structure:
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Included below is the list of gas customers and the sales price structures available to various
industries:
Thailand has aimed to keep prices affordable by implementing an average gas pooling
mechanism. The Gas Pool determines the price of gas by averaging the well-head cost of
domestic gas supplies with more expensive imported supplies including LNG. Pool 1 is sourced
from the Gulf of Thailand (including MT JDA) and is allocated to GSPs, whereas Pool 2 consists
of all remaining gas including gas from the Gulf of Thailand, MTJDA, Myanmar and LNG.
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Gas prices in Thailand, based on the pool pricing system, have risen steadily since 2000. The
raise has been moderated by the structure of oil price linkages in legacy supply contracts. This
same mechanism ensures that high-priced LNG is more gradually integrated into the market.
One of the significant consequences of this reform package has been rapid growth in the capacity
of the gas system.
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Pros Cons
The pool pricing mechanism helped to The pool price may limit the growth in
average out the difference between domestic domestic gas exploration as the market price
and imported gas prices is not set on margin cost
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LESSONS LEARNED
Thailand’s gas price pooling is one method for averaging out the difference between cheap
domestic gas prices and more expensive gas imports (pipeline or LNG). However, the potential
negative implications of implementing the pricing pool may outweigh its benefits, due to the
following issues Vietnam might face:
• All existing domestic gas contracts need to be restructured so that only one entity buys
from various upstream producers
• There are various and complex tax implications for contracts signed in various regions
• Existing gas buyers need to agree to the rise in their gas price
• New gas supply development may be impacted as the prices are not based on marginal
cost
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INDONESIA
The subsidized industry will still negotiate the gas price with the upstream supplier based on
alternative fuel availability. The government will then pay the subsidy to the end user based on
affordability.
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Pros Cons
The new mechanism of cost plus with a Priority sectors that cannot afford expensive
margin has incentivized new suppliers to gas face a major problem without subsidy
engage in the market
LESSONS LEARNED
Indonesia has seen an evolution in domestic gas prices from historic lows to current levels of
approximately US$ 8-9/MMBtu. The evolution was achieved through sellers and buyers being
able to negotiate directly, without the involvement of an aggregator or national oil company. The
high price of LNG is also being passed through to end users directly, and subsidies are only
given to specific sectors.
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MALAYSIA
Source: CIMB
Non-power Sectors: Prior to the 2008 price increases, gas price for the non-power sector was
fixed at RM9.40/MMBtu (US$2.5/MMBtu) despite being indexed against the price of fuel
oil. The price cap is active only for the power sector. The retail gas sector is regulated by the
government and adjusted according to customers’ ability to pay, as well as according to Petronas
Gas and Gas Malaysia’s rates of return. In March 2009, the government announced a new round
of gas price adjustments. Apart from the price reduction, 100 mmcfd of natural gas from the
power sector was reallocated to the manufacturing sector. This reallocation is only a temporary
reprieve to industrial end users whose gas demand has been increasing by an average of 8% per
annum since 2000, compared to the power sector’s annual gas demand growth of only 2%. The
current average gas price for smaller industrial customers supplied by Gas Malaysia is around
RM16.07/MMBtu.
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Because of the power sector’s reliance on gas, the government considers gas to be of strategic
importance to the Malaysian economy. Hence, gas prices are regulated and set by EPU.
Currently, there is no formal policy in terms of end user price adjustment as the cost of supply
(linked to fuel oil) fluctuates. Gas pricing policy remains controversial, and will continue to be
politically driven until an independent price-setting mechanism is introduced.
LESSONS LEARNED
Malaysia does not provide a good model for gas pricing mechanisms to be emulated by Vietnam.
In Malaysia, gas price subsidies are only made possible by Petronas’ very strong balance sheet.
Given the changing upstream gas market dynamics and the precipitously decreasing reserve
availability, price hikes are inevitable in Malaysia, possibly as early as 2014. The key lesson
derived from Malaysia is that, once introduced, price subsidies are very difficult to remove, both
from a political and from an end-customer perspective.
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The study of 19 different gas markets unsurprisingly revealed a wide variety of gas price levels
and gas price mechanisms.
Gas Price Levels: Whereas the market price of a barrel of crude oil is roughly the same
worldwide (assuming a similar quality of oil), the wholesale market prices of natural gas can
vary greatly by country and region. To take three examples, the current wholesale market prices
of natural gas in three different large gas markets – namely the US, UK and Japan – are
approximately:
Gas Price
Market Comment
($/MMBtu)
US 5 World’s largest gas producer (680 bcm in 2012) and also largest gas
market (720 bcm in 2012). Because of surplus shale gas, the US will
become a major LNG exporter)
Japan 14 Largest LNG market (116 bcm/year), fully dependent on LNG imports.
The reason for the much higher wholesale gas price in Japan – as also in Korea, Taiwan – is full
dependence on LNG imports. It is nevertheless remarkable to have a single commodity (natural
gas) with such major price variations between the US, Europe and Asia.
Gas price mechanisms: The analysis of the 19 different gas markets revealed a wide range of gas
price mechanisms.
At one end of the spectrum, gas prices are set by the free market, for example in the US and UK.
However, even in such open markets, the government establishes regulatory authorities with
oversight powers, for example to prevent natural monopolies (such as trunklines) from abusing
market power. This role is fulfilled by the FERC in the US and by Ofgem in the UK – each
regulating both gas and electricity.
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At the other end of the spectrum are countries where the government fully controls gas prices.
Some Middle East oil & gas producing countries have gas markets of this character (though
these were not specifically analyzed in the Study).
Most gas markets have gas pricing mechanisms within these two extremes. In Vietnam, PVN/PV
Gas negotiate individual gas prices with domestic gas producers, and the government (through
MOIT) approves transport tariffs, distribution tariffs, sales prices, and volume allocations by
market sector.
“Import Only” Countries: Japan, Korea, and Taiwan are three regional examples of large gas
markets supplied fully by LNG imports. Based on 2012 figures, the percentage of LNG imports
consumed by the power sector is high in each case - in Taiwan 80%, in Japan 59%, and in South
Korea 47%. In Singapore, the power sector consumes an even higher 87% of gas imports
(mainly pipeline gas). In all of these four gas markets the high costs of LNG imports - or in
Singapore of both pipeline gas and LNG imports - are fully passed on to end-customers through
the power or gas companies’ tariffs. In Japan, the power companies that directly import LNG
(also the major gas companies) are “private monopolies” in their respective areas. In South
Korea, the dominant power company (93% market share) is KEPCO, which is 51% state-owned.
KEPCO is itself 24.5% equity owner in KOGAS, the near-monopoly government-controlled
LNG importer and trunkline system owner, and also the largest single LNG buyer in the world
(~40 mtpa). It should be of interest to Vietnam that the full cost of LNG imports (including
regasification costs) is passed on to customers through power and gas tariffs in all of the above
countries. There are no government subsidies.
Gas Markets Supplied by both Domestic Gas and LNG Imports: For Vietnam, where the gas
market is currently supplied 100% by domestic pipeline gas, but which will commence importing
LNG within a few years, some useful lessons can be learned from countries whose gas markets
are supplied by both domestic gas and LNG. Countries in this category include:
Malaysia Major LNG exporter from East Malaysia (24 mtpa), but recently
started LNG imports to Peninsula Malaysia which has a pipeline gas
supply deficit
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China While gas currently supplies only 5% of its primary energy, China is
already the 3rd largest gas market in the world, and growing rapidly.
Domestic gas is being increasingly supplemented by LNG and
pipeline gas imports.
Addressing these four countries in turn provides some relevant lessons for Vietnam:
Thailand: Perhaps the most interesting feature for Vietnam to note is that Thailand is arguably
the only gas market in the world to have mathematically implemented “price pooling.” The
decision to “pool” gas prices can be attributed to the commencement of pipeline gas imports
from Myanmar in 2000. Pooling now also includes LNG imports, which commenced in 2011 and
which will grow steadily. Under price pooling, the different prices paid for various offshore
domestic supply streams, for imports from Myanmar, and for LNG are averaged by PTT. The
company then decides on the wholesale and retail prices to be paid by the various market sectors
(power, industry, NG vehicles etc). The “price pooling” of different gas supply costs can only be
achieved because PTT controls all natural gas purchases and all natural gas sales in Thailand.
While price pooling has enabled PTT to mitigate/blend in the higher cost of gas imports, as the
percentage of LNG imports increases and that of domestic gas declines, the pool price is likely to
increase towards the LNG price. Arguably, the cross-subsidization of the full cost of LNG can
distort economic assessments of new gas-consuming investments, because such investments may
be based on today’s pool price which will steadily increase in the future. For any other country
(e.g. Vietnam), introducing a price pool would necessitate changing current selling prices to
customers under existing long-term gas sales contracts. Changes in existing contracts may cause
significant confusion and perhaps resistance. Thus, the benefits of price pooling would be
outweighed by the disadvantages that change in the current system would entail.
A second lesson from Thailand is that the level of control PTT still exercises over all aspects of
the gas market in Thailand is very high, despite the fact that the company is only 51% state-
owned.
India: India is a good example for Vietnam, as both countries share similar economic growth and
development. India’s gas pricing is controlled through regulation, where the government’s
approval is required for the negotiated wellhead price and the transportation tariff. With
declining gas production and increasing gas demand, India started to import LNG in 2004.
Historically, domestic gas prices in India were approximately US$2.5-4/MMBtu, and hence the
introduction of LNG imports has been met with constraints on the domestic market due to a lack
of price elasticity at the US$14-15/MMBtu import price levels.
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The Indian government studied various solutions for managing the price differential between the
domestic gas and imported LNG. One of the initial steps was to increase the domestic gas price
to US$4.2/MMBtu. However, this price increase has not helped significantly to bridge the price
gap. Hence, the Indian gas customers sought to avoid signing long-term LNG contracts linked to
oil index. This phenomenon resulted in acute gas shortages in the country, and the power sector
was severely hit. To address the problem, the Indian government introduced a gas allocation
policy where the priority sectors (i.e. Power and Fertilizer) are to benefit from the cheap
domestic gas, and the rest of the gas customers are to pay the market price for LNG. This
approach has resulted in a decrease in gas usage in the industrial sector. Furthermore, the gas
allocation policy sparked dialogue around gas price pooling in India.
The concept of gas price pooling in India was primarily considered to cross subsidize the
expensive LNG imports through cheap domestic gas. However, following a long consultation
and review process, the government ultimately rejected the implementation of gas price
pooling for the following reasons:
• Variations in taxation among different states – Through gas price pooling, supplies are
provided to all customers at the same price. However, with different taxation levels in
different states, the pooled price may be higher than the contracted price for some states
and lower for others. It will be difficult to account for the variations in taxes through the
pooling mechanism.
• No physical pooling – Given that the supply and demand locations are not ideally
matched, there is no physical pooling of gas, and hence the actual delivery of gas might
be different from the pooled gas. This results in complexity around gas swapping, and
hence taxation again can be a major issue.
• No direct seller-to-buyer interactions – Currently, the sellers and buyers negotiate and
enter into GSPAs, whereas in gas pooling there may be no direct relationship between the
seller and the buyer. The disconnect may result in issues around the structuring and
implementation of GSPA/GTAs.
• Price Discovery – Upstream companies oppose gas price pooling, as the price discovery
and the marginal cost of price setting for new upstream development will be at risk. Also,
the pool does not have control over the international LNG price, and hence, to keep the
average gas price affordable, the domestic gas price might not be reflective of the actual
cost of production, but instead be artificially maintained at lower price levels.
• Pooling of transportation tariffs and legal challenges from existing gas contracts are
going be more complex.
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Malaysia: The gas market in Malaysia is controlled by the national oil & gas company, Petronas,
which earns very large profits from both oil and LNG exports. Petronas is a particularly rich
NOC, because it is permitted to retain a percentage of rent from the hydrocarbon resources that is
higher than is received by most other NOCs. In contrast with its market priced LNG exports,
Petronas’ domestic sales of gas in Peninsula Malaysia have been kept artificially low-priced (i.e.
“subsidized”), with the power sector (mainly state-owned TNB) being by far the largest gas
purchaser. As a result, gas sales have increased steadily, while domestic gas reserves offshore
Peninsula Malaysia have been depleted. This growing gas market imbalance has led to the recent
building of an LNG import terminal offshore Malacca (Melaka), and the commencement of
expensive LNG imports.
While the Malaysian government has well-defined plans to increase the price of domestic gas
progressively each quarter towards international (LNG) prices, so far it has postponed
implementing those plans. Meanwhile, Petronas is having to absorb large losses on its LNG
imports through Malacca, because it is the company with the greatest financial strength to do so.
The core lesson for PVN and PV Gas is that it is important that the full cost of LNG imports be
passed through to customers - mainly the power sector – and that those higher costs can be
“pooled,” if necessary, in EVN’s electricity tariffs.
China: Traditionally, China’s domestic pipeline gas has been sold at relatively low prices.
Today, rapidly growing imports of both pipeline gas from Central Asia and LNG imports are
proving much more expensive than domestic gas. China’s three large National Oil Companies –
CNPC (PetroChina), SINOPEC and CNOOC - are wrestling with the problem of importing
expensive gas and selling at a loss. For example, in 2013 CNPC’s losses on LNG imports alone
were reported at $7 billion. In China, gas prices are largely controlled by the central
government’s National Development & Reform Commission (NDRC). NDRC is gradually
moving city-gate gas prices upwards, towards full market prices. Price floating will allow the
NOCs gradually to reduce losses on gas imports, and to make higher profits on “new” domestic
gas production. The permitted city-gate gas price increases are also aimed at encouraging
increased production by the NOCs of conventional domestic gas (both offshore and onshore) and
of unconventional gas (shale gas, tight gas and coal bed methane).
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Should Vietnam apply Gas Pooling?: Galway is not in favor of Vietnam applying the gas
pooling mechanism for reasons exemplified in both Thailand’s and India’s situations. This is
further detailed below:
THAILAND
As seen from the table above, gas price pooling is unique to the Thai gas market. It is not a
commonly used pricing mechanism.
The rationale behind Thailand having an average pool mechanism was to keep prices affordable.
The gas pool would determine the price of gas by averaging the well-head cost of domestic gas
supplies with more expensive imported supplies including LNG.
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Gas that goes into Pool 1 would be sourced from the Gulf of Thailand (including MT JDA) and
is allocated to GSPs. Gas that goes into Pool 2 would consist of all remaining gas including gas
from the Gulf of Thailand, MT JDA, Myanmar and LNG. A price pooling mechanisms has its
short-term and long-term effects on the price of gas. In the short term, gas pooling did help
average out the upstream gas price variations in Thailand, as shown in the diagrams below.
However, in the long term, pool pricing causes the price of gas to increase. This can be
exemplified by Thailand’s situation where the pool pricing has risen steadily since 2000.
As a result, the price pooling mechanism has been losing its attractiveness in Thailand. Calls
have been made by the Thailand Development Research Institute to the National Council for
Peace and Order (NCPO) and concerned agencies to raise the price of natural gas to reflect
market conditions.
In addition, pooling can distort investment decisions by gas consumers because they do not
reflect the full marginal cost of extra gas (LNG cost). In the long run, the average price of the gas
pool will increase in Thailand due to declining domestic gas reserves.
INDIA
India also faced a challenge pricing LNG. India and Vietnam have similar growth and
development characteristics. LNG imports commenced in 2004 and it was a big challenge to
reconcile high LNG import costs with low domestic prices. There was much serious discussion
of implementing an “economic/marginal cost of gas price mechanism”, however, this was
eventually rejected in favor of an allocation policy. The gas allocation policy meant cheaper
domestic gas was reserved for priority sectors while other customers had to pay full market price
for LNG.
There were various reasons why price pooling was rejected in India:
Taxation issues between different states in India resulting in complex tax related pricing
concerns
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No physical pooling of gas – It is a contract pooling rather than physical pooling of gas
The price of gas is not set by the marginal cost of gas, rather based on a arbitrary
average number
Furthermore, India is an existing example of a country which can manage power prices with
different gas contracts without a gas price pooling mechanism.
In 2004, due to the increase in electricity demand in India, the Government renewed its focus on
a partial power sector privatisation. This involved putting out a large number of electricity power
purchase agreements (PPA) to private market tender, most priced in the range of Rs2-3/kWh.
Competitive fixed charge for about 30 years, including the construction period,
with an option to extend for a further period of 10 years.
The difference in power price based on various fuel is managed by the power distribution
companies through pooling (pooling of power from various fuel source) and cross subsidy
(capacity based charge).
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SUMMARY
Gas pooling is complex and not desirable for Vietnam due to reasons below:
Market distortion (price below market value creates artificial demand; price above
market value destroys demand)
Pooling is a short term solution for new end user to pay lower prices, however in the long
run Pooling disrupts market forces as its not reflective of actual marginal cost of supply
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The larger part of domestic gas sales are of Nam Con Son gas to the power sector. These are
priced at ~$5/MMBtu (or ~$30/bbl oil equivalent), while the smaller volumes of gas from other
offshore areas are sold at somewhat higher prices. Prices to industry (excluding fertilizer) are
sold at the price of alternative fuels.
In international terms, Vietnam’s domestic gas prices today are all commercially competitive.
Future imports of LNG are forecast to be significantly more expensive.
Pros Cons
Government price subsidies have been Gas price pooling is not the answer, as it
successfully avoided would have disadvantages which outweigh
any benefits
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STATUS QUO
Galway advises that Vietnam keeps the status quo. The existing gas pricing structure in Vietnam
is stable and well-functioning. The Government is still in a strong position through both
regulation and ownership compared to other countries. Prices have been agreed between gas
producers and PV Gas (for a specific buyer). All costs are recovered and government subsidies
are not required. By international standards, Vietnam’s domestic gas prices are reasonable.
Hence, there is no need to modify the existing project-by-project (and market sector-by-sector)
pricing mechanisms. The gas contracts - with their respective pricing formulae - can continue to
work well. If changes such as gas pooling are implemented, the negative effects from the
disruption caused would outweigh any benefits.
A gas allocation policy could serve as a measure of last resort should the government seek to
promote certain strategic industries. For example, the Indian government, in an effort to promote
certain industrial sectors, has implemented a policy to allocate more affordable gas supplies to
those key industries. Priority sectors (i.e. Power and Fertilizer) benefit from the cheap domestic
gas. The rest of the gas customers pay the market price for LNG. This approach has resulted in a
decrease in gas usage in the industrial sector. A similar policy in Vietnam would ensure that the
government has sufficient flexibility to allocate the most affordable gas supplies to the industries
it seeks to promote.
Looking ahead, the challenge of introducing more expensive LNG into the Vietnamese gas
market must be considered. The higher costs of LNG imports must be fully passed through to
customers and governments subsidies be avoided (even through gas pooling). The largest
customer sector for LNG will likely be power. Therefore, one option to address the pass-through
of higher LNG costs to end-customers would be to allow price pooling in EVN’s electricity
tariffs. For any potential industrial customers, who are currently using costly LPGs and fuel oils,
the cost of LNG would be affordable. The learning's from other markets such as India and China
is clear that any interference on pricing LNG will only result in either high subsidy related
losses, or negative impact on the LNG demand.
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(ii) Impact on gas pricing of the commencement of LNG imports. LNG imports are planned
to commence within a few years. Such LNG will almost certainly be significantly more
expensive than current domestic gas resources. It is therefore necessary to consider the
best method of passing those higher costs through to the market.
(iii) Government gas price subsidies should be avoided. International experience shows that
fuel subsidies by governments usually become ruinously expensive – and that once such
subsidies are introduced they then become very difficult politically to remove. In respect
of oil product price subsidies, this important lesson can be seen in countries such as Iran,
Venezuela, Indonesia, Nigeria – and several others. Specifically on LNG, both China and
Malaysia provide examples of where the “rich” NOCs who are importing LNG are
currently absorbing losses on expensive LNG imports - though both countries have plans
to phase out such hidden subsidies. Argentina provides another example of subsidizing
LNG imports and this is contributing to the increasing economic meltdown in that
country. It is therefore strongly recommended that the Vietnamese government
should be firm in passing the full costs of LNG (including regasification costs)
through to the market.
(iv) Price pooling. One possible mechanism for passing through the costs of an expensive gas
stream is by “price pooling” (or averaging) with other gas streams. While some degree of
informal price pooling probably exists in several countries – for example Japanese power
and gas companies will average the costs of their various LNG purchase contracts when
calculating their tariffs – the only country revealed by the study of 19 gas markets which
has systematically and mathematically implemented price pooling of domestic gas and
imported gas streams is Thailand. It is the considered recommendation of this Study
that Vietnam should reject price pooling as a method of passing through higher
LNG import costs to the market. The reasons for this recommendation against price
pooling are explained more fully in section 4.2 above, in the discussion on both Thailand
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and more particularly on India. In summary, the complexities involved (including
disruption of existing contracts, tax issues, loss of seller/buyer relationship, distortion of
investment analysis for new projects) outweigh any advantages.
LNG costs pass through recommendations. This Study concludes that the higher costs of
LNG should be passed through to the customers physically receiving the regasified LNG
stream. The major customer will be EVN. EVN will then have “expensive” power from
its LNG-fuelled power station(s). However, such power will be mixed with the power
from its other power stations in the grid and become indistinguishable. This Study
therefore recommends that EVN “pool” its power costs from the various power plants
supplying its grid, when calculating and seeking approval for power tariffs. The pooling
process would thus be similar to a Tokyo Electric or Kansai Electric or Chubu Electric in
Japan “pooling” their generation costs from the whole mix of respective power plants
(coal, oil, gas –and nuclear) to calculate power tariffs. As for other industrial or
commercial gas customers currently using oil or LPG, supply of regasified LNG should
be affordable with full cost pass through.
(v) Gas allocation policy. Finally, a gas allocation policy could serve as a measure of last
resort should the government seek to promote certain strategic industries. For example,
the Indian government, in an effort to promote certain industrial sectors, has implemented
a policy to allocate more affordable gas supplies to those key industries. A similar policy
in Vietnam would ensure that the government has sufficient flexibility to allocate the
most affordable gas supplies to the industries it seeks to promote.
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6. ABBREVIATIONS
APM Administered Price Mechanism (India)
BBL One stock tank barrel, of 42 US gallons liquid volume
BCF One billion cubic feet of natural gas
BP British Petroleum
BPCL Bharat Petroleum Corporation Limited
BPH Regulatory Agency for Upstream Oil and Gas (Indonesia)
MIGAS
BTU British thermal unit
CBM Coalbed Methane
CNOOC China National Offshore Oil Corporation
CNPC China National Petroleum Corporation
CPC Chinese Petroleum Corporation (Taiwan)
CRE Energy Regulatory Commission (France)
CREG Commission de Régulation de l’Électricité et du Gaz (Belgium)
DGO Distribution Grid Operator
DMF Department of Mineral Fuels (Thailand)
DMO Domestic Market Obligation
DOE Department of Energy (US)
E&P Exploration & Production
EC European Community
EDF Électricité de France
EMA Energy Market Authority (Singapore)
ENAGAS Ente Nacional Regulador del Gas (Spain)
ENAP Empresa Nacional del Petróleo (Chile)
ENI Ente Nazionale Idrocarburi (Italy)
EPC Engineering, Procurement and Construction
EPPO Energy Policy & Planning Office (Thailand)
EPU Economic Planning Unit (Malaysia)
ERC Energy Regulatory Commission (Thailand)
EU European Union
FDI Foreign Direct Investment
FERC US Federal Energy Regulatory Commission
FPC Federal Power Commission (US)
GDF Gaz de France
GDF SUEZ Gaz de France and Suez (merged)
GDP Gross Domestic Product
GEMA Gas and Electricity Markets Authority (UK)
GSP Government Selling Price