Gas Bill: Input by Afrikaans Handelsinstituut and Petronet

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Mineral Resources and Energy

23 May 2001
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Meeting Summary

A summary of this committee meeting is not yet available.

Meeting report


23 MAY 2001

Chairperson: Mr D Nkosi

Documents handed out:
Afrikaanse Handelsinstituut (AHI) comments on the Gas Bill (Appendix 1)
Petronet Comments on the Gas Bill (See Appendix 2)
Council on Geoscience Report

The Afrikaanse Handelsinstituut and Petronet presented their views on the Gas Bill. They were closely questioned by the Committee. There was a complaint by some that the Committee was entering into deliberations on the Bill when it should only raise questions of clarity regarding these submissions. The AHI was told to draft specific amendments to clauses that it found problematic.

Afrikaner Handelinstituut
Dr Naude said that the AHI supports the objectives of the Bill, though they have difficulty with two issues. The first problem is that some of the powers given to the Gas Regulator are excessive which will have unfortunate consequences. If such powers are granted to the Gas Regulator and certain officials, it would create an atmosphere conducive for irregularities and corruption. The second concern is that the interface between Clause 22 of the Gas Bill and the Competition Act has not been addressed properly and will cause problems. [Refer to the submission for details].

Mr I Davidson (DP) commented that the regulating mechanism for tariffs "is the guts" of this legislation. If the country has an industry that has monopolies or potential monopolies built into it, it has to look at it from the side of the consumer because they are the ones who will suffer. AHI looked at the matter from the side of industry but it should also look at it from the consumer’s viewpoint as well. The problem with (potential) monopolies is that they create captive markets, and that is not good for building an industry. AHI had opposed the tariff part of the Bill but it had not presented constructive suggestions. A regulatory regime that would create that middle part between the consumer and the industry is always needed.

Mr Davidson agreed with what Dr Naude was saying about the Competition Act. He suggested that the relevant department forward some comments based on the Competition Act’s interface with this Bill. He disagreed with Dr Naude’s suggestion that all consumers should have a similar tariff as that would create serious problems for individual consumers. He cited the electricity industry where there is a tariff system for industrial consumers, commercial consumers and individual consumers.

Dr Naude replied that he understands this problem but the committee must note what he said about monopoly. In the energy industry there is a unique substitutability of energy sources. So if one talks about monopoly, for example electricity is not a monopoly because there are a lot of substitutes so that a person can change to gas and other forms of energy. If one defines monopoly, then one must define the relevant market involved. One has to start with the product market and deal with substitutability on the supply side and on the demand side. Dr Naude argued that if prices and conditions of supply are regulated by government officials and substitution takes place, both consumers and the industry would not be able to respond to that.

He said the Competition Act already exists to deal with monopolies and concentration of economic power. With the Gas Bill, there starts to be a duplication of laws as the Competition Act deals precisely with situations of monopoly and lack of competition. This law should not circumvent the Competition Act.

Mr Ramodike (UDM) asked if long-term investment and planning necessarily mean ‘indefinite period’? If it is like that, then the granting of a licence for an indefinite period would mean monopoly?

Dr Naude replied that entering into business for an indefinite period does not mean monopoly. If there is a need "to work on" the licencing system, it must be done in such a way that will attract investors. It is wrong to tell people to invest only for a certain limited period. Many investors would not like to invest under such conditions.

Ms Motobatse (ANC) commented that when the Bill had been drafted, the state law advisers had checked up on similar legislation. She believed that Dr Naude was unduly negative about the Bill. Also his verbal input did not match the written submission.

Dr Naude said the Committee would find reference to every clause he has referred to in his presentation in his written document.

The Chairperson said the Committee had invited those who think there should be further improvements on this Bill to make submissions. There are various stakeholders and all the different interest groups would be heard. During the deliberations that follow, the Committee would try to ensure that the final product balances these different interests.

Mr Nel said it would be helpful to the Committee if the AHI were to give specific clause-by-clause proposals on what areas they would like to be improved in the Bill.

Dr Naude replied that the AHI has not only criticized in its submission. They have specified certain clauses and have been very precise about the areas where they thought there should be improvement.

Mr Davidson pointed out that the Committee has the duty to refine the legislation though none of the committee members are experienced in drafting legislation. The AHI has huge legal resources at its disposal. He repeated Mr Nel’s suggestion that the Committee would like to hear AHI’s specific amendments with regard to the wording of problematic clauses.

On AHI’s point regarding concurrent jurisdiction and tariffs, he suggested that the Department should clarify the issues of jurisdiction and tariffs.

The Chairperson pointed out that people making submissions should be listened to and only questions of clarity should be asked. The issue of deliberations belonged to the Committee. Nevertheless Mr Davidson had identified certain issues which is good.

Mr Davidson commented that it is not wise to hold debates in isolation as the Committee hears one side of the debate but does not hear the opposing side’s response to that argument. He suggested that both sides should be heard together.

The Chairperson asked the Department to comment on the issues raised by the AHI.

Dr Rod Crompton of the Department said they had tried to contact AHI on many occasions but to no avail. Some of the confusions and questions could have been dealt with earlier. Section 21 of the Competition Act applies to any regulation in this country - be it water, electricity or telecommunications. Section 21(h) of the Competition Act sets out clearly what is to be done with concurrent jurisdictions. It says that the concurrent regulators have to negotiate agreements. This applies to any country where there is competition legislation. No one has said it is easy but such legislation is a fact of life and that is how things have to be done.

Dr Crompton said they had looked at international best practices in preparing for this Bill. In many economies, regulation in this sector is much tougher than what has been proposed in the Bill and those countries have survived. In terms of international comparison, the Department feels that this legislation is fairly lightweight with regard to tariffs and regulation. The question of abuse of a dominant position is clearly set out in Section 7 of the Competition Act. He promised that the Department would provide a detailed response to all of AHI’s comments.

The Chairperson summarised Dr Naude’s presentation: AHI would like Clause 22 of the Bill deleted as AHI believes it is contradictory and inconsistent with the Competition Act. On the other issues, the Chairperson suggested that AHI should return with specific suggestions on how to improve this piece of legislation.

Mr Moller said that their submission tackled all the issues that they thought are in need of improvement and there are fifteen of them. He asked the committee not to hesitate to contact them should they require clarity or information on any of the comments made. [For more details, please refer to attached document.]

Mr Davidson said his understanding of the problem is that the whole Bill is based on the inclusion of transmission lines and the exclusion of distribution lines. With electricity, the main transmission lines from ESKOM are included and those small distribution lines set up by individual companies are excluded. Hence the Bill needs to be tightened up in terms of those definitions.

Mr Moller said that they initially thought every pipeline above three bars would be subject to this Bill and that would mean transmission and distribution. In their submission they said there is a need to distinguish between distribution and transmission: anything between two to fifteen bars would be seen as distribution, anything above fifteen bars is transmission, and anything below two bars is reticulation.

Mr Lucas (IFP) wanted to know how Petronet would use the existing pipelines for some of its activities because it is essential to ensure that it develops an integrated pipeline but it needs to be coded.

Mr Moller replied that on the question of the code and Petronet’s involvement, it is true that Petronet would aspire to be involved and in fact they are already involved. They have an existing pipeline that runs gas down to KwaZulu-Natal. The way the system was coded was based on international accepted standards.

Ms Ngaleka asked Mr Moller to motivate Petronet’s suggestions on Clause 21.(1). Why does he recommend that the clause be amended?

Mr Moller agreed that for them the transition is important. The Bill requires that within six months, the present operator should apply for a licence. One could be faced with a situation where the Act is promulgated but people battle for a year or more to put the regulator in place and in the meantime one cannot register one’s present facilities. If the transitional period can be linked to the period when the regulator is being put in place - that would be understandable

Dr Crompton said he agreed with Petronet that the timing of the promulgation of the Act be concurrent with the set-up of the regulator to avoid precisely the problem that has been raised by Mr Moller. If done differently, there would be a danger of legal challenge as to when the regulator be set up.

Regarding the pressure of transmission pipelines, he said that the reason is to avoid the loophole that they feel the Petronet proposal creates. The proposal creates a loophole that one could run a transmission pipeline at less that fifteen bars, so they are merely closing that loophole.

Mr Davidson said he is not sure about the whole issue of transmission versus reticulation. He understands the main purpose of the Act is regulating transmission lines (that is any line above two bar) by way of tariffs. But in the case of less than two bar, it is not intended to regulate unless there is inadequate competition.

Mr Crompton replied that below two bar is reticulation, which is outside the scope of this Bill as it would be unlikely to be a competition. The tariff and the charge of the gas would be one and the same. On distribution and transmission it is possible to have competition, there can be alternative distributors and there can be transmitters using the same infrastructure. The point raised by Petronet has something to do with trying to segment transmission to above two and below fifteen. It may not be a bad idea but it does create a loophole which the Department is trying to close. There could be a transmission outline running at 14, 999 bar thereby escaping the transmission capitalization.

On a point of order Ms Xingwana (ANC) said the purpose of the meeting was to obtain input from the different stakeholders. Deliberations should take place at a later stage and their interrogation of the Department should be part of that meeting. The only discussion at this meeting should be questions of clarity by the Committee which would be addressed by the presenters. Otherwise the Committee could have a special meeting where the department could provide further clarity.

The Chairperson said they had allowed the discussion with Petronet as a stakeholder because the committee wanted to understand Petronet’s input and suggestions. He acknowledged the point that Ms Xingwana was raising and said that it is his responsibility to ensure that such debates are not opened up earlier.

Council of Geoscience
Dr Mzimba presented an annual report on the work of the Council. She emphasised the need for more geoscientists especially from the previously disadvantaged communities. [See document for details].

Due to time constraints, the meeting was adjourned.
Appendix 1




a Control of "tariff"
b Term of license
c Consequences of excessive

a The principle : Competition Act and industry
specific legislation
b Concurrent jurisdiction
c Policy approach
d Scrapping of non-discrimination clause

1 South Africa’s small gas industry is expected to expand and provide a significant component of national primary energy.

"A Gas Regulatory Authority will be established to implement a minimal regulatory regime consistent with orderly development of a competitive gas industry through granting licenses for the transmission, storage, distribution and trading of piped gas."
(White Paper on Energy Policy, December 1998)

2 The AHI supports the objects (clause 2) and general thrust of the Bill.

3 In two respects, however it is essential to reconsider and delete or change the relevant clauses in the Bill :

3.1 Some of the powers given to the Gas Regulator are excessive. They have no place in a "minimal" regulatory regime, will frustrate the important objective in clause 2(b) to "facilitate investment in the gas industry" and create an unhealthy climate encouraging irregularities.

3.2 The interface between this Bill and the Competition Act, 1998 has not been thought through properly and will cause problems.

4 These two areas affect matters of principle important to the business sector.


a Control of "tariff"

5.1 "Tariff" is defined as a "written statement of rates and terms and conditions under which gas or gas services are sold to any customer." (clause 1)

5.2 The Gas Regulator must regulate tariffs in terms of clause 21(1)(n) in the prescribed manner (clause 4(g)).That means that the Regulator must impose license conditions setting "tariffs" for consumers and distributors "where there is inadequate competition as contemplated in Chapters Two and Three of the Competition Act, 1998."

This massive intervention in the business of a licensee by the Regulator prescribing not merely his prices but also his terms and conditions of supply, is unacceptable, particularly if this is done after the issuance of his license. The reasons are the following:

5.2.1 As in the case of any other businessman, flexibility of his price and conditions of supply are critically important to a licensee, who is also an investor. This is particularly significant in view of the interchangeability of the various energy sources. The steam boiler providing steam for say a bread baking plant or the burner on the bread baking oven itself, can easily be converted to use either pipeline gas, LP gas, fuel oil, diesel or illuminating paraffin as heating fuel / energy. Importantly, both the steam boiler and bread baking oven can also use the ever-present choice of electricity as heating energy. The fact is that the energy industry, as far as heating applications are concerned, is unique in its ability to interchange between various energy sources. Numerous examples of such changes exist. To tie a licensee’s hands in such circumstances by allowing bureaucracy to dictate his price and conditions of supply, is wrong. Bureaucrats do not suffer the consequences of their own wrong decisions. The investor does.

5.2.2 The trigger for this severe intervention is "inadequate competition as contemplated in Chapters Two and Three of the Competition Act, 1998" (clause 21(1)(n).

This reference to the Competition Act is ill-conceived. In none of these chapters is the question of "adequate" or "inadequate" competition defined or even contemplated at all. Chapter Two prohibits certain restrictive practices (which lessen competition) and a number of abuses by dominant firms, quite irrespective of the question of "adequacy" of competition. It is no defense against a complaint of a prohibited practice, that there is "adequate competition" in the market.

Chapter Three of the Competition Act deals with the control of mergers. Mergers can of course substantially lessen competition, and this effect may or may not be justified by efficiency or public interest considerations. But nothing in this chapter contemplates the question whether competition in an industry is "adequate" or "inadequate". It fundamentally deals with the impact of a merger.

Moreover, the Competition Tribunal and Competition Appeal Court share exclusive jurisdiction in respect of the interpretation of chapters 2 and 3 in terms of section 62(1) of the Competition Act. This excludes the Competition Commission, civil courts and certainly also the Gas Regulator. The reason for this exclusive jurisdiction is clearly the complexities that arise in the highly specialised area of competition law.

There is no doubt that the very trigger for the Gas Regulator’s usurpation of a businessman’s right to determine his prices and conditions of supply, is on a slippery slope.

5.2.3 The Competition authorities are adequately equipped in terms of their Act and infrastructure to deal with competition problems. If a licensee engages in any anti-competitive conduct, he can be punished in terms of the Competition Act and also incur civil liability to a person who has suffered a loss (section 65(6)). If his price is "excessive", he falls foul of section 8(a). "Predatory" pricing will be a contravention of section 8(c) or 8(d)(iv), and "price discrimination" is prohibited in section 9. The disadvantages of bureaucratic intervention by controlling prices and conditions in an attempt to supplement competition policy and law, far exceed any benefits to be derived.

5.2.4 It will be shown later on (par 9) that the Gas Bill in its present form will not attract investors – quite the opposite – and creates an environment conducive to corruption. The power to intervene on highly uncertain grounds and prescribe prices and conditions, is prominent in these dangers.

5.2.5 It is no answer to the problem that a decision of the Regulator may be brought under review by the High Court (clause 10(3)). The Court is in no position to regulate prices and conditions.

5.3 The Regulator’s power to "set tariffs" (i.e. rates, terms and conditions) must be removed from the Bill. See clause 4(g) and (h), 21(1)(n) and 34(1)(5).

b Term of license

6 Any license "is valid for a period determined by the Gas Regulator who must take cognisance of the need for investors to recover their investments". A licensee may apply to have his license renewed (clause 23).

7 This approach, despite the undoubtedly good intentions, sends a strongly negative message to potential investors in what is supposed to be a rapidly expanding industry in a country where local as well as foreign direct investment is a real problem.

The message is this: "By definition you are going into this business for a limited period of time. You have no certainty of renewal. The license conditions (which presumably include the term) may be varied by the Regulator upon application by any "affected party" (clause 24(1)(e)). At any time, if the same Regulator thinks that competition is inadequate, he may impose control of prices and conditions on you. So, if you are wise, you will invest frugally (if at all). Don’t waste money on expensive quality infrastructure, because eventually someone else, not you, is likely to get the benefit. And as far as the law is concerned, you are not in the gas industry for profit. Recovery if investment is the criterion. Therefore invest as little as possible and take out what you can in the short run – because you are not allowed to plan and do business for the long run. Above all, you are at the mercy of officials in this business."

8 Even if one accepts the need for licensing, it can be dealt with far more constructively. As a matter of principle a license should be granted for an indefinite period so that investment and planning are based on the long term. There is nothing wrong with penalties, including withdrawal of the license, for good cause. But don’t stunt the industry at its birth by over-zealous regulation which instills an atmosphere of temporariness and uncertainty.

c Consequences of excessive powers

9 The "excessive powers" discussed so far are powers of the Gas Regulator. It is important though that the Regulator will consist of five part-time members (clause 5(1)). There will also be a Chief Executive Officer (CEO) who will be responsible for the day-to-day management of the affairs of the Regulator and for administrative control over the employees which he himself appoints (clause 11(1)). Any experienced manager will understand that, almost inevitably, real power will gravitate into the hands of the CEO and, perhaps, one or two of his senior officials. He has the detailed knowledge. He will largely determine the agendas for Regulator meetings, control the submissions to and information before the Regulator and propose and steer the outcome. For firms in the industry the CEO will be the focus of power, the person who can effectively decide the life or death of the firm.

What is the likely effect of the powers in these circumstances?

9.1 An important object of the Bill (clause 2(b)) is to "facilitate investment in the gas industry". Can there be any doubt in anyone’s mind that the excessive powers described earlier are likely to frustrate this object? How many entrepreneurs or large firms will risk significant amounts of capital in such an environment of discretionary intervention in business decisions, temporariness and uncertainty? And if some do, how will that atmosphere influence the way they invest and do business? Will this "promote the efficient, effective sustainable and orderly development and operation" of the gas industry (the first object in clause 2(a))? In fact the extent of reliance on discretionary bureaucratic power in the Bill places the achievement of all the objects under threat.

9.2 A consideration that must carry weight with Parliament is the unhealthiness and danger of statutory systems that create an ideal situation, a temptation, for irregularities and corruption. This Bill illustrates such a situation. This is no reflection on particular persons, but on systems that wisdom and experience dictate should be avoided, despite noble intentions.

9.3 Adoption by Parliament of such a system will set a sad precedent for the future. Next time it is easy to argue that the principle has already been accepted in the Gas Act.

a The Principle : Competition and Industry Specific

10 The Competition Act, 1998 applies to all economic activity (except labour matters) within, or having an effect within, the Republic (section 3(1)). This clearly includes all activities in the gas industry.

11 Since the Competition Act as a whole will apply to all licensees under the Gas Act, Parliament has to consider very carefully whether it is wise to include provisions regulating competition in an industry specific Act like the Gas Act.

If such provisions identical to provisions in the Competition Act are included, nothing is added to what exists – but it is problematical that there then are two sets of identical provisions that appear in different Acts implemented by separate authorities.

Serious problems start when competition provisions in an industry specific Act differ from provisions in the Competition Act. In law both apply to the firms concerned.

b Concurrent jurisdiction

12 After the Nedcor / Stanbic merger episode, involving the Banks Act and the Minister of Finance, the Competition Act was amended with effect from 1 February 2001 to provide for concurrent jurisdiction in a case where an act falls under chapters 2 or 3 of the Competition Act and is also subject to the jurisdiction of another regulatory authority such as the Gas Regulator (section 3(1A)).

The manner in which the concurrent jurisdiction is exercised must be managed, to the extent possible, in accordance with an agreement between the Competition Commission and the regulatory authority concerned.

Numerous problems and legal uncertainties arise from this "concurrent jurisdiction", eg the two authorities have not entered into an agreement, or interpret it differently, or disagree about the outcome, or one of them acts on its own or deviates from the agreement.

With two masters protecting turf, this "concurrent jurisdiction" is at best a troublesome, arrangement – as the Registrar of Banks has recently explained in his Annual Report.

C Policy approach
13 What is absolutely clear as a matter of policy is this : Parliament must respect and preserve the integrity of the Competition Act and its specialised organs, vigorously. It is most undesirable for industry specific legislation to regulate little competition law systems next to the national system. If this occurs, companies in that industry are saddled with the uncertainties, delays and costs flowing from different authorities sitting in judgement of his conduct. To exacerbate the problem, competition law is highly specialised and an authority like the Gas Regulator will most likely be quite out of its depth, as will the CEO, in competition law matters.

14 The principle is clear : in the absence of compelling reason, competition matters should be left to the Competition Act and its specialised organs and not be regulated piecemeal in industry specific legislation. To do so creates bad law and practical problems.

d Scrapping of non-discrimination clause

15 For the reasons given the attempt to prohibit discrimination
by licensees in clause 22 is a weak shadow of principles in the Competition Act, particularly section 9. If licensees, like any other firms, discriminate, it is a matter for the competition authorities and not the Gas Regulator. The clause should be scrapped.

16 General provisions to the effect that the Regulator must exercise his power in such a way that competitive markets are promoted (clause 2(f)) or competition in the industry is promoted (clause 4(j)) are meaningful and do not create jurisdictional problems.
Appendix 2
C A Möller
Chief Executive
Thank you for affording Petronet the opportunity to offer further comment on the Gas Bill
[B18 – 2001]. Your invitation to address the committee on this matter is also much appreciated and we will inform your office of our intentions in this regard.
Petronet applauds the Department of Minerals and Energy for the consultative and participative way in which it has gone about drafting what in our opinion is a very sound Gas Bill. In keeping with this methodology we offer the following comments / queries / suggestions for your consideration.
1. Definitions
i) For the purpose of further clarity the following expansion is suggested for the definition of "transmission" "…………gas by pipeline at a pressure greater than 15 bar gauge supplied………….".
Given the important role that "uncommitted capacity" could play in the future it is recommended that this definition be expanded. Contractual obligations should be defined in terms of signed contracts or existing contracts with definite performance criteria in terms of commencement, period, duration, etc.
2. Objective of the Act
To give affect to particularly 2.a. we find the Act lacking in terms of the Regulators functions accountability and reporting.
In order to achieve an integrated National Gas system within the context of a National Integrated energy plan, we would see the compilation of a "Gas Master Plan" as a specific function of the Regulator.
Having compiled this plan to be approved by the Minister we would then see the Regulator held accountable for orderly development in accordance with the approved plan and reporting accordingly.
3. Functions of the Gas Regulator
Clause 4.(a)(iii) - The need to licence the operation of transmission pipelines is not understood. In the case where the operator is also the owner then licensing conditions will be achieved vide the owner. Where the operator is not the owner a commercial contract between owner and operator will govern the activities. The introduction of any licence conditions outside of this contract will in our opinion lead to confusion and conflict. The onus to ensure that the operations contract terms and conditions are consistent and compliant with all codes, regulations and licence conditions must remain with the owner.
4. Disqualification’s and requirements regarding appointment to Gas Regulator
The requirements of Clauses 6.(1)(d) & (e) and 6.(2)(a) will in our opinion make it very difficult if not impossible to appoint members who will qualify in terms of Clause 6.(1)(a).
5. Meetings of Gas Regulator
The authority vested in the Regulator vide clause 8 (7) b. is of concern. We would propose that mechanisms such as "circulation" be put in place to allow for approval of decisions taken by the Regulator outside of a formal meeting. The mechanism should then be allowed under certain prescribed conditions affecting National interest or Health and Safety.
6. Funds of Gas Regulator
Clause 12.(b) needs to be clarified. Any consideration of levies based on the Regulators cost structures as mooted in the draft Bill would be unacceptable.
7. Activities requiring a licence
Clause 15.(1)(b) - Comment as per .3. above.
8. Application for Licence
Clause 16.(2)(e) makes provision for the applicant to propose the tariff and gas price policies.
In order to allow for orderly development and assessment of business feasibility it is recommended that Regulatory requirements be stipulated, e.g. Required Revenue on Assets Managed, Price capping, etc.
9. Finalisation of application
Clause 19.(3)(b) - Comment as per .3. above.
10. Conditions of Licence
Clause 21.(1)(n) - The reason for not including Transmission pipeline tariffs in this clause is not clear.
11. Expropriation of land by Gas Regulator
Clause 32.(1) - Experience has shown that the expropriation conditions must make provision for immediate occupation.
12. Rights of licensee in respect of premises or land belonging to others
Clause 33.(3)(a) - Transmission pipelines need to be included in this clause.
Clause 33.(5)(b) - Supervision by the authority concerned is not recommended. This can and will lead to confusion over work site responsibility in terms of the Occupational Health and Safety Act. It is suggested that the authority require the presence of a representative to monitor adherence to conditions and protection of the authorities assets.
The rights of the licensee are not adequately protected by the provisions of Clause 33. Conditions restricting the owners use of the land within the servitude area need to be included for the safety and protection of both parties interests.
13. Transitional Provisions
Clause 35.(1) - It is recommended that this clause be amended to stipulate that the prescribed period become effective from the date of the appointment of the Gas Regulator and not from the date of promulgation of the Act.
14. Mozambique Gas Pipeline Agreement
Clause 36. - The need to include this specific agreement in the Gas Act is not understood. If the purpose is to provide protection to the parties in terms of Clause 35.(2)(a)(1.) would then be fair to include all other existing gas pipelines together with their relevant contracts or transmission/transport agreements, tariffs, etc.
15. The Bill is silent on Technical and Operating codes or standards. It is our recommendation that the American code ASME B31.8 "Gas Transmission and Distribution Piping Systems" with relevant amendments for local conditions be adopted and stipulated. This is essential to ensure the feasibility of an integrated pipeline network.


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