ERDEM-NEWSLETTER-2018-metin

88 NEWSLETTER 2018 tions in the decisions of the CK and Enerjisa, and has determined that distribution companies, operating in distribution regions, as well as ASCs, are in dominant positions. Within this context, regarding the distribution of electricity which is a natural monopoly, the related market is determined as “electricity distribution service,” and prov- inces where these distribution companies operate is determined as the geographical market. The related market for electricity retail sales is divided into vari- ous sub-markets 6 . With regard to Electricity sold to Consumers who are below the Non-paying Consumer Limit : Consumers do not have the right to choose suppliers and, therefore, they must access electricity from ASCs, and the mentioned supply activity is defined as a separate prod- uct market. The related geographical market has also been identified as the provinces where the ASC operates. As for Consumers who are above the Non-paying Consumer Limit: The relevant market has been divided into sub-categories as clients of the industry, residences and businesses, and demonstrate different characteristics. Electricity sales activities regarding the aforementioned consumer groups have been identified as separate but related product markets by the Competition Authority. In addition, a subdivision has been made on the basis of the customers of the in- dustrial group, and the customers connected to the transmission line system, and the customers connected to the distribution line system, have been determined as different related product markets. Within this framework, related product markets for retail electricity commerce in terms of non-paying consumers are as follows: • The electrical retail market for industrial customers connec- ted to the system at the transmission level; • The electrical retail market for industrial customers connec- ted to the system at the distribution level; • The market of electricity retail sales made to commercial customers; and 6 For detailed information, CK decision, p. 24 ff.