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Unbundling within the Electricity Market and the
EMRA Resolution on Legal Unbundling
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Att. Revan Sunol
Introduction
“Procedures and Principles concerning the Legal Unbundling of
Distribution Systems and Retail Sales” was published within the
Official Gazette dated September 27, 2012 and numbered 28424 with-
in the scope of The Energy Market Regulatory Authority (“EMRA”)
Resolution dated September 12, 2012 and numbered 4019
(“Resolution”). Within the Resolution, the principles and procedures
concerning the operation by undertakings holding a distribution license
of distribution systems and retail sales under separate legal entities
have been set forth.
The Notion of Unbundling
Unbundling within energy markets refers to the unbundling of ver-
tically integrated structures. The unbundling of generation, transmis-
sion, distribution and retail sales has an important role within the elec-
tricity market with regard to the implementation of competition. The
inclination towards the unbundling of the transmission and distribution
operations, which are referred to as network operations and which
carry natural monopoly characteristics, from generation and retail sales
activities, is based on the concern that the dominant undertaking may
limit in various ways the access of other undertakings that it is
competing with in generation and retail sales areas. The mechanism
referred to as vertical unbundling aims to provide the access of all
players to distribution and transmission systems without discrimina-
tion and the prevention of cross subsidization between undertakings
conducting generation, transmission, distribution and retail sales activ-
ities.
Unbundling within the electricity market may be realized as
unbundling of accounts, legal unbundling and ownership unbundling.
ENERGY LAW
249
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Article of September 2012