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Effective implementation? Something of a fail (again)

December 3, 2015

According to Naftogaz Ukraine, with effect from 1st January 2016, some 280,000 Ukrainian homes may be without gas.

This is not due to the Kremlin turning off the gas tap – indeed Ukraine is not buying any Russian gas presently, and it is claimed it has no need to do so for the remainder of the year.

The reason for the gas being cut from these homes relates Ukrainian law and its implementation – or lack of it.

It is not an issue that can be blamed upon Naftogaz Ukraine either – for it is not responsible for the creation and passing of the law, nor is it responsible for the implementation of the law.

It so happens that fairly recent changes in legislation relating to gas supply, specifically for those using gas in the heating of water, required the fitting of individual gas meters in all such Ukrainian homes – a necessary step toward energy efficiency and transparency for customers regarding their gas bills undoubtedly.  The law stated all homes using gas to heat water were to be fitted with gas meters by 31st December 2015.

Thus from 1st January 2016 the inference is that those who are not in compliance with the law will have their gas service terminated – presumably until the relevant meters are fitted and they are in legal compliance.

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According to Naftogaz Ukraine, thus far only 75% of the homes that meet the requirements for mandatory gas meters have had them fitted – meaning approximately 280,000 homes are likely to fall foul of the law with effect from New Years Day.

The relevant gas meters are fitted for free by the relevant local/regional gas suppliers, to whom Naftogaz Ukraine supply gas.  Naftogaz Ukraine has no direct contact, contract, or access with end customers.  Naftogaz Ukraine simply supplies gas to the relevant Oblast suppliers that deal with and bill customers.

It is therefore those local/regional suppliers that have failed to fit the required gas meters within the alloted time, that will be turning off the gas to the dwellings they have yet to fit the relevant meters within.

The questions therefore raised are firstly who is responsible for dwellings failing to comply with the law with effect from 1st January 2016, and secondly will the gas be turned off for these unmetered dwellings in compliance with the law, or will the law be broken and temporarily ignored in recognition of (another) implementation failure?

The finger pointing, whichever decision be made, will naturally begin very shortly.  Yet in apportioning responsibility, the problem may lie with either an unrealistic implementation time frame within the law passed, or ineffective implementation by the regional gas supplying companies – or both.

In the meantime, perhaps a formal and legal deadline extension based upon realistic installation completion dates should be made either by Decree or legislative amendment to insure nobody breaks the law unnecessarily?

Once the finger pointing is over however, one wonders whether any lessons will be learned from what will have been a fairly large undertaking, when it comes to national implementation of policy that manifested itself in a very tangible form.  Those lessons, be they learned, would perhaps benefit future energy efficiency implementation projects be they either regional or national in scale.

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