Preventive Action Plan. The Netherlands. Prognosis and Market Modelling Report. Preventive Action Plan The Netherlands. 09 January 2015 Document

Transcription

1 Preventive Action Plan The Netherlands Department Prognosis and Market Modelling Report Preventive Action Plan The Netherlands Due by 09 January 2015 Document Preventive Action Plan Date, version 09 January 2015 Our reference LA Status Final 2015 Gasunie Transport Services B.V., Groningen Page 1 of 42

2 Contents 1 GENERAL Introduction Contents and Outline RESULTS OF THE RISK ASSESSMENT AND MEASURES TO BE TAKEN Measures to be taken Infrastructure standard outcome Calculation of the N-1 formula and summary scenarios Scenarios detailed Scenarios related to the N-1 formula Other Dutch scenarios ENTSOG scenarios Supply standard outcome Additional assessment short term resilience of the system DUTCH INFRASTRUCTURE AND SUPPLY STANDARD Specifics of the Dutch gas system Definition of protected customers Supply to protected customers based on three pillars (public service obligations) Pillar I: Peak supply a responsibility of GTS Pillar II: a licensing system for suppliers of protected customers Pillar III: GTS to take action in case of bankruptcy of a supplier The Netherlands applies a 1-50 infrastructure standard Security of supply report Directive 2009/73/EC OBLIGATIONS IMPOSED ON NATURAL GAS UNDERTAKINGS AND OTHER RELEVANT BODIES General legal framework Safe operations of the system Quality conversion Within the Netherlands L-gas in neighbouring countries Control system Day-to-day operations Balancing Other obligations REGIONAL COOPERATION Regional cooperation Operational cooperation Gas Regional Initiative Regional cooperation security of supply Regional cooperation within ENTSOG INFORMATION ON EXISTING AND FUTURE INTERCONNECTIONS PUBLIC SERVICE OBLIGATIONS Peak supply a responsibility of GTS A licensing system for suppliers of protected customers GTS to take action in case of bankruptcy of a supplier Gasunie Transport Services B.V., Groningen Page 2 of 42

3 1 GENERAL 1.1Introduction In order to reinforce security of natural gas supply in the European Union, Regulation (EU) no. 994/2010 of the European Parliament and the Council (hereinafter referred to as the Regulation) entered into force on 20 October 2010, replacing Council Directive 2004/67/EC of 26 April 2004 concerning measures to safeguard security of gas supply. The Regulation introduces measures that require member states to ensure that action is undertaken to prevent potential disruptions to the gas supply and, if a disruption should occur, to mitigate the impact, especially for protected customers. The Ministry of Economic Affairs of The Netherlands has been appointed as the national Competent Authority in accordance with Article 3 of the Regulation. The Dutch Gas Act provides that the Minister can (partly) delegate certain tasks of the Competent Authority to the national gas transmission system operator Gasunie Transport Services (GTS). This particularly relates to the preparation of the Risk Assessment and the Preventive Action Plan. Before adopting the Preventive Action Plan at national level, this Preventive Action Plan was shared with the Pentalateral Gas Platform for consultation, with a view to ensuring that this draft Plan and measures are not inconsistent with the Preventive Action Plan and the Emergency Plan of another Member State and that it complies with Regulation 994/2010. These consultations did not result in amendments of this Preventive Action Plan. The National Regulatory Authority ACM commented on a draft of this Preventive Action Plan and its views are included. 1.2Contents and Outline The primary focus of this Plan is on the risk for the entire gas system. For a correct understanding of the scope and level of detail contained in this Preventive Action Plan it is necessary to recall the overall conclusions of the 2011 and 2014 Risk Assessment that there is a negligible risk for a disruption of the gas supply in the Netherlands, being a net-exporter of natural gas. It is therefore that this preventive Action Plan contains no other security of supply measures than those that are already in place based on Dutch regulation. In line with article 5 of the Regulation the content of this Preventive Action Plan was determined. As such the Plan contains: the results of the risk assessment as laid down in Article 9; = chapter Gasunie Transport Services B.V., Groningen Page 3 of 42

4 (b) the measures, volumes, capacities and the timing needed to fulfil the infrastructure and supply standards, as laid down in Articles 6 and 8, including where applicable, the extent to which demand-side measures can sufficiently compensate, in a timely manner, for a supply disruption as referred to in Article 6(2), the identification of the single largest gas infrastructure of common interest in the case of application of Article 6(3) and any increased supply standard under Article 8(2); = chapter 3 (c) obligations imposed on natural gas undertakings and other relevant bodies, including for the safe operation of the gas system; = chapter 4 (d) the other preventive measures, such as those relating to the need to enhance interconnections between neighbouring Member States and the possibility to diversify gas routes and sources of supply, if appropriate, to address the risks identified in order to maintain gas supply to all customers as far as possible; as no risks were identified this is not included in the Dutch Preventive Action Plan (e) the mechanisms to be used for cooperation with other Member States for preparing and implementing joint Preventive Action Plans and joint Emergency Plans, as referred to in Article 4(3), where applicable; = chapter 5 (f) information on existing and future interconnections, including those providing access to the gas network of the Union, cross-border flows, cross-border access to storage facilities and the physical capacity to transport gas in both directions (bidirectional capacity), in particular in the event of an emergency; = chapter 6 (g) information on all public service obligations that relate to security of gas supply; = chapter 7 Annex 1 provides an overview of European and national regulations related to security of supply aspects Gasunie Transport Services B.V., Groningen Page 4 of 42

5 2 RESULTS OF THE RISK ASSESSMENT AND MEASURES TO BE TAKEN 2.1Measures to be taken The overall conclusion of the Risk Assessment 2014 was that there is a negligible risk for a disruption of the gas supply in the Netherlands, being a net-exporter of natural gas. Assessment of the infrastructure and supply standard does not lead to any need for measures, volumes nor capacities. The paragraphs 2.2 and 2.3 detail the Dutch assessment of the infrastructure and supply standards. These paragraphs are a copy of the Dutch Risk Assessment 2014, as is required by the Regulation. 2.2Infrastructure standard outcome 2.2.1Calculation of the N-1 formula and summary scenarios The calculation of the N-1 formula led to the conclusion that the Netherlands, with a result of 162% for the N-1 formula, lies far above the 100% standard which is required in the Regulation. This result corresponds to the outcome of the 2012 Preventive Action Plan. The values of parameters used for the calculation are detailed in the 2014 Risk Assessment. 1 Gas storage Grijpskerk is the largest single infrastructure in the Netherlands (the -1 ). The various scenarios, developed for the Dutch situation, led to the conclusion that taken de results of the N-1 formula into account, in general no mitigating measures will have to be taken. In the paragraphs below, several scenarios are examined. Also scenarios which are (far) more strict than the N-1 formula. These are included for illustration purposes. As they go (far) beyond the N-1 formula requirements, a less than 100% outcome of these scenarios does not lead to the inclusion of mitigating measure. In addition, and again for illustration purposes only, the findings of the ENTSOG Ten 1 All values in mcm (n 35;17)/d 2015 Gasunie Transport Services B.V., Groningen Page 5 of 42

6 Year Network Development Plan, the Gas Regional Investment Plan of North West Europe and the 2014 Stress Test were included. In these documents also no investment gaps for the Dutch gas transport system were identified which could have had a negative impact on the results of the N-1 formula. The gas demand of protected customers is included in the total number for peak gas demand in the N-1 formula. Protected customer demand is further detailed paragraph 2.3 Supply standard outcome. Protected customers in The Netherlands are defined as: customers who have a connection to a network with a total maximum capacity not exceeding 40 m3 (n) per hour. The protected customers comprise the households and small enterprises Scenarios detailed The Dutch high-pressure network is designed to be able to operate at an average daily effective temperature of -17 C. Since all subgrids are interconnected, they all depend on each other and are therefore all required to meet this high availability standard. All main subsystems (i.e. compressors etc, not pipelines) in the network are equipped with a back-up system (redundancy, also known as N+1 requirement). If very high availability is required (for critical functions) then also another system located elsewhere in the gas transport network is available that can take over the function (as a back-up system). For instance, if an event should prevent the main dispatching centre in Groningen to function, control of the network is also possible from another (classified) location in the Netherlands. Due to the (increasing) use of electrically-powered compressors, large-scale power failures can have consequences for the production and transport of (and the demand for) gas. The way in which electricity and gas are interwoven for the Groningen production field is included in the scenario dealing with the disruption of the Groningen field (see below). Up to today, the (non-)availability of electricity has limited influence on the transport of gas due to the availability of no-break systems to ensure the supply of electricity to the control systems of critical infrastructure and due to gas-fired compression. Exceptionally high gas demand (on the occasion of a day with an average daily effective temperature of -17 C in accordance with the Dutch Gas Act) is the basis for the scenarios set out below. The Risk Assessments details the underlying data Gasunie Transport Services B.V., Groningen Page 6 of 42

7 The scenarios detailed below are clustered into three different groups. Scenarios related to the N-1 formula Other Dutch scenarios ENTSOG scenarios Figure 1 shows all scenarios, divided into these three groups. Scenarios related to the N-1 formula N-1 formula X X 162% 1 Disruption full Norwegian entry (no Norwegian supply) X X X 143% 2 Disruption full German entry ("no Russian supply") X X X 151% 3 Non-availability of LNG X X X 145% 4 Groningen field disruption X X 153% 5 Gas exports fully honoured X X 94% 6 Bergermeer storage becomse operational X X X 173% 7 Gas exports fully honoured &Bergermeer storage X X X 100% Other Dutch Scenarios A Bankruptcy of a supplier B Gas infrastructure problems due to earthquakes C Decrease in domestic production on the longer term D Nord Stream disruption ENTSOG Scenarios disruption largest infrastructure I Resilience Assessment: potential investment gaps in the European gas system exceptional demand under normal Situations (Reference Case): potential investment gaps in the European gas system Under Supply Stress: through the calculation of Remaining Flexibility of each Zone of the system II Supply Dependency Assessment: the dependence of some Zones on a single supply source III Network Adaptability Assessment: the ability of the system to adapt to various supply patterns Figure 1 overview of scenarios and scaling new storage facility disruption outside country N-1result 2.2.3Scenarios related to the N-1 formula Scenario 1 Also a complete disruption of Norwegian supply: total disruption = 64 (Grijpskerk) + 94 (Norway) = 158 mcm/d When complete Norwegian supply via Emden (in reality 2 separate pipelines) is no longer available, 94 mcm/d less is available. Under these conditions the outcome of the N-1 formula is 143% Gasunie Transport Services B.V., Groningen Page 7 of 42

8 Scenario 2 Also a complete disruption of German entry ( no Russian supply ): total disruption = 64 (Grijpskerk) + 56 (entry Germany) = 120 mcm/d To illustrate the possible impact on the N-1 formula of the non-availability of Russian gas, full entry from Germany was interrupted. However, gas flowing to the Netherlands at this border point is not just Russian gas, it also includes gas from German storages and Norwegian gas imported to Germany. As the exact combination of these sources will differ on an hourly base (based on shipper contracts and actual flows) it is impossible to determine only the amount of Russian gas. Therefore the impact of no Russia supply is illustrated by a complete interruption of German entry. As such this scenario is far more strict than Russian gas only. When complete German entry is interrupted, 56 mcm/d is less available. Under these conditions the outcome of the N-1 formula is 151%, which is still high above the required 100%. Scenario 3 Also non-availability of LNG: total disruption = 64 (Grijpskerk) + 42 mcm/d (LNG) = 108 mcm/d Suppose the only LNG terminal in the Netherlands fails or LNG is not available at the market (LNG m = 42 mcm/d) at the same time as the largest infrastructure storage Grijpskerk, then the result of the N-1 formula comes out at 153%. Scenario 4 Also Groningen field disruption: total disruption = 64 (Grijpskerk) + 45 mcm/d (largest group Groningen) = 109 mcm/d The Groningen field does not comprise one physical entry point, but consists of 29 production clusters connected on a ring system. These clusters are divided into 11 independent groups to make the electricity supply to the clusters less vulnerable. If supply to one group fails, the others are able to continue. Disruption of the group of clusters with the greatest capacity means the loss of a volume of production capacity of 45 mcm/d maximum. The result of the N-1 formula in the event of disruption of one of the Groningen production points results in 153% Gasunie Transport Services B.V., Groningen Page 8 of 42

9 Scenario 5 Gas export capacity included in full despite disruption of largest infrastructure: total demand = 881 mcm/d The N-1 formula only takes account of domestic demand (Dmax). The exit capacities at border points are not included in the N-1 formula. If these capacities are used in full within Dmax, then N-1 comes out at 94% which is below the N-1 norm. As this scenario is for illustration purposes only, as it is far more strict than the N-1 formule (worst case), detailing of mitigating measures is also out of scope. Scenario 6 Potential effect of Bergermeer storage facility: storage = + 57 mcm/d During the 1990s, storage facilities at Grijpskerk and Norg were developed near the Groningen field in order to keep capacity (swing) at the required level. Over the last few years, the storage facility capacity in the Netherlands has been greatly expanded and new projects are in the pipeline (f.e. expansion of the Norg storage). The Bergermeer storage facility is scheduled to become fully operational in If the Bergermeer withdrawal capacity is included in the N-1 formula, then the N-1 result will increase to 173%. Scenario 7 Gas exports included in full despite disruption of largest infrastructure scenario but with Bergermeer storage operational: total demand = 881 mcm/d & storage = + 57 mcm/d The effect of the additional Bergermeer storage capacity is that the N-1 formula would result in exactly 100%, when gas export capacities are included in full Other Dutch scenarios Not all realistic risks can be quantified. Whether there is actually sufficient gas volume available, depends besides sufficiently available infrastructure (capacity) on sufficient volume supply and most importantly whether these volumes are made available at the right time, at the right place in the right volume by shippers and traders. These aspects cannot be determined by the N-1 formula, and are therefore included in a separate group of realistic scenarios for the Netherlands. These scenarios do not lead to N-1 related mitigating measures Gasunie Transport Services B.V., Groningen Page 9 of 42

10 Besides the above type of situations, several other realistic risks in the Netherlands were identified for the purpose of this Risk Assessment. It should however be noted that the risks and scenarios listed here are only a small illustration of the huge amount of risks assessed on a day-to-day basis when dealing with pipeline security. The processes related to these detailed risk assessments are laid down in this Dutch Preventive Action Plan. Scenario A bankruptcy of a supplier The Dutch transmission system operator GTS is statutorily responsible for the uninterrupted supply of gas to protected customers in case of a bankruptcy of a supplier, by guaranteeing the payment to producers and by the co-ordination of the re-distribution of protected customers of the bankrupt supplier among the remaining suppliers. In such a case GTS has a coordinating task to make sure that the customers of the non-compliant supplier continue to receive gas. Noncompliance of a supplier does not imply shortage of gas, and will therefore be solved by the market. In this way these customers can choose a new supplier within a reasonable time without an interruption in their gas supply. Bankruptcy of a supplier does therefore not imply shortage of gas towards the protected customers. Scenario B Gas infrastructure problems due to earthquakes Currently GTS studies all possible consequences of earthquakes for the GTS network and supporting facilities. This study covers pipelines as well as GTS offices and public infrastructure relevant for GTS facilities, like telephone connections. If required, these elements will be replaced by GTS with items that can withstand the expected level of earthquakes. This also applies to pipelines (-segments) and other relevant gas infrastructure in the region. Scenario C Decrease in domestic production on the longer term The decrease in the production of domestic natural gas over the long term is a fact. The Dutch and European infrastructure is already being adapted to cope with these changing circumstances. Entry at border points is being extended to allow volume flows to increase and storage facility capacity is being extended in order to allow sufficient swing to be generated. Whether sufficient volumes will be transported depends on the choices then made by the shippers/traders. This loss in volume can be partly compensated for by an increase in the domestic supply of green gas and possibly, in the long term, by the production of shale gas Gasunie Transport Services B.V., Groningen Page 10 of 42

11 Scenario D Nord Stream disruption If the Nord Stream pipeline fails, then there is sufficient infrastructure in northwest Europe to supply gas to customers via another route. This is the result of the substantially increased capacity on the northwest European market in order to be able to facilitate market operations. Whether sufficient volumes will be transported depends on the choices then made by the shippers/traders ENTSOG scenarios ENTSOG scenarios Ukraine and Russia disruption scenarios winter ENTSOG modelled the consequences of Ukraine disruption and Russian disruption ( no Russian supply ) for the whole of the EU under 4 different demand patterns (see figures 2-5). Its specific findings for the Netherlands are listed and detailed here. It should be noted, as stated by ENTSOG as a disclaimer that the results provide an estimation of the impact of a possible disruption crisis and should not be understood as an actual forecast neither in term of demand disruption nor supply mix. Disruption of flows through Ukraine, does not impact the Netherlands under any of the set conditions. This can be concluded from the fact that the Netherlands is coloured blue under all different scenarios in figures 2-5. Disruption of all Russian flows does impact the Netherlands, but only on a January peak day (figure 3, maximum daily demand in all EU countries design demand) and during a cold spell in March (figure 4, with low storage stock due to end of season timeframe). The pink colour indicates that a maximum of 20% of total demand needs to be interrupted in order to solve the problem. The 20% is the average demand share not covered under the maximum spread of the event. This means that the goal of the modelling was minimization of impact on each country. The fact that the Netherlands, despite it relatively low yearly imported Russian volumes (see scenario 2, paragraph 2.2.3), is also impacted in some situations (according to the ENTSOG modelling) can be explained by the good connectivity between the Netherlands and adjacent zones which allows sharing of misery, as was the aim of the ENTSOG modelling. Due to this good cross-border connectivity less regions are bright red and more regions are light pink. As these scenarios are far more strict than the N-1 formula requires, its outcomes do not result in mitigating measures Gasunie Transport Services B.V., Groningen Page 11 of 42

12 Gasunie Transport Services B.V. Figure 2 Winter 2014/2015 Ukraine and Russia disruption, impacted countries, source: ENTSOG, Risk assessment for winter 2014/2015, preliminary results, as presented at the Madrid Forum 6/7 May 2014 Figure 3 January with peak Ukraine and Russia disruption, impacted countries, source: ENTSOG, Risk assessment for winter 2014/2015, preliminary results, as presented at the Madrid Forum 6/7 May Gasunie Transport Services B.V., Groningen Page 12 of 42

13 Figure 4 March disruption with cold spell Ukraine and Russia disruption, impacted countries, source: ENTSOG, Risk assessment for winter 2014/2015, preliminary results, as presented at the Madrid Forum 6/7 May 2014 Figure 5 Across season disruption Ukraine and Russia disruption, impacted countries, source: ENTSOG, Risk assessment for winter 2014/2015, preliminary results, as presented at the Madrid Forum 6/7 May Gasunie Transport Services B.V., Groningen Page 13 of 42

14 ENTSOG TYNDP scenarios Every two years ENTSOG publishes its Ten Year Network Development Plan. Ten Year Network Development Plan analyses whether, when daily demand is very high, sufficient flexibility is available at European border points to be able to counterbalance various disruptions of infrastructure under different demand scenarios. In the Gas Regional Investment Plan (GRIP) the findings of the TYNDP are elaborated for North West Europe. This document can be found on the websites of the TSO in North West Europe and the ENTSOG website. As can be concluded from the graphical presentations below (figures 6-8), none of the scenarios included in the TYNDP 2012 and as such in the GRIP 2013 resulted in a finding of insufficient resilience for the Netherlands (which would be indicated by a red colour in figure 6 and 7 and by a red or blue colour in figure 8) Gasunie Transport Services B.V., Groningen Page 14 of 42

15 I Resilience Assessment: potential investment gaps in the European gas system under normal Situations (Reference Case): potential investment gaps in the European gas system. Figure 6 Infrastructure under Reference Cases, source: NW_131105_MainReport_FINAL-lowres.pdf 2015 Gasunie Transport Services B.V., Groningen Page 15 of 42

16 II Resilience Assessment: potential investment gaps in the European gas system under Supply Stress: through the calculation of Remaining Flexibility of each Zone of the system Figure 7 Infrastructure under Supply stress cases, source: NW_131105_MainReport_FINAL-lowres.pdf 2015 Gasunie Transport Services B.V., Groningen Page 16 of 42

17 III Supply Dependency Assessment: the dependence of some Zones on a single supply source Figure 8 dependence of some Zones on a single supply source, source: NW_131105_MainReport_FINAL-lowres.pdf 2015 Gasunie Transport Services B.V., Groningen Page 17 of 42

18 2.3Supply standard outcome The requirements, as set in Article 8 of the Regulation, determine that gas undertakings ensure gas supply to protected customers under several demand scenarios. Chapter 3 details the Dutch infrastructure and supply standard. In the following paragraph, the assessment of the supply standard as included in the Risk Assessment is shown. Gas supply to protected customers shall, according to the Regulation be ensures under the following the demand scenarios: Extreme temperatures during a 7-day peak period occurring with a statistical probability of once in 20 years. Any period of at least 30 days of exceptionally high gas demand, occurring with a statistical probability of once in 20 years. For a period of at least 30 days in case of the disruption of the single largest gas infrastructure under average winter conditions. The black columns in figure 9 show the mcm/d required by the Dutch protected customers (dd 1st January 2014). In the three REG 994/2010 scenarios and under the 4 th scenario which the actual the Dutch legal national standard for peak supply, compared to the available Dutch indigenous production and available storage & LNG in mcm/d in the yellow columns. The total amount of gas needed to supply protected customers under Dutch peak day standard and under EU legislation is included in this graph. It should be noted that Dutch protected customers are in majority supplied with locally producedgas. Figure 9 demand protected customers under 4 different scenarios compared to national production and storage/lng in mcm/d, source: GTS 2015 Gasunie Transport Services B.V., Groningen Page 18 of 42

19 From the figure it can be concluded that due to the large indigenous production, the Netherlands can easily supply its protected customers under all scenarios, from an infrastructural point of view. It can also be concluded that the existing Dutch standard is stricter (leads to a higher demand) than the obligations of the Regulation. Even when the single largest gas infrastructure is disrupted (as indicated by the top shading of the storage & LNG column). A distinction was made between national production and storage & LNG. Notwithstanding what was written about the production cap on the Groningen field, national production is available under peak situations. 2, The capacity of the LNG terminal may not be fully available due to the unavailability of LNG on the market (can be related to price, general availability etc). It is also possible that storage capacity is not available at the end of the winter due to zero volume. 2.4Additional assessment short term resilience of the system On 28 May 2014 the Commission adopted its European Energy Security Strategy providing a comprehensive plan to strengthen our security of energy supply. Against the background of the situation in Ukraine and the possible related risk of a disruption in gas supplies to the EU, the Strategy encompassed measures to be taken immediately in order to increase the EU's resilience to a major gas disruption in the upcoming winter. As part of those immediate measures, the European Council endorsed the Commission's proposal to launch a so-called stress test exercise with the purpose of assessing the resilience of the European gas system to cope with a severe disruption of gas supply to the EU this winter. The scenarios proposed by the Commission to all participants in this exercise covered the disruption of the Ukrainian gas transit route as well as all Russian gas flows to Europe for periods of one month and six months (September to February), supposing average winter conditions in each case. In addition, a 2-week February "cold spell" sub-scenario was also developed by ENTSOG to cover the effect of peak demand on an already strained supply system. These proposals were based on past experience and the need to put to the test our energy systems under very demanding conditions, i.e. the disruption of all the flows from Europe's main external supplier of natural gas. Each country presented its national report and ENTSOG equally modelled the impact of supply disruptions on the EU-wide gas system. All findings combined were published by the EC. The Dutch stress test concluded that disruption of flows through Ukraine do not necessarily lead to missing volumes in the Netherlands. Under full disruption of Russian supply, the Netherlands is likely to be affected as entry flows on the Dutch 2 This text is based on the information provided by the Minister of Economic Affairs to the Dutch Parliament, in its letter of 17 th January 2014 with the subject Gas extraction in Groningen 2015 Gasunie Transport Services B.V., Groningen Page 19 of 42

20 German border point Oude Statenzijl, are assumed to be interrupted. From an infrastructural point of view (capacity GATE terminal and grid capacity) the Netherlands is, however, able to substitute these missing volumes with additional LNG supplies. Average national H-gas demand and exports could therefore be supplied in the February and September-February timeframe. The results of the EU-wide ENTSOG modelling showed that in the different six month disruption scenarios the EU and the Energy Community Contracting Parties without Ukraine would, after reshuffling the supply mix, altogether still be missing between five and nine billion cubic meters (bcm) of gas. It also showed assuming maximized use of infrastructure and normal market conditions that when such six-month disruptions occur Russian volumes are replaced particularly through the import of additional volumes of LNG. The ENTSOG modelling exercise also showed which countries would be most affected by the gas disruptions. In line with the national stress test, according to the ENTSOG assessment the Netherlands is also not likely to be affected by supply interruptions in any of the scenario. As is illustrated by the next maps (source: Communication from the commission to the European Parliament and the Council on the short term resilience of the European gas system Preparedness for a possible disruption of supplies from the East during the fall and winter of 2014/2015, Brussels, COM(2014) 654 final). Maps of likely supply interruptions before further national measures in February at the end of the 6-month Russian gas supply disruption scenario in cooperative (optimal) and non-cooperative (sub-optimal) scenarios under average winter conditions. Figure 10 maps likely impact supply interruptions under average winter conditions (source Brussels, COM(2014) 654 final, based on ENTSOG) 2015 Gasunie Transport Services B.V., Groningen Page 20 of 42

21 Maps of likely supply interruptions before further national measures in February at the end of the 6-month Russian gas supply disruption scenario in cooperative and non-cooperative scenarios during a cold spell. Figure 11 maps likely impact supply interruptions during a cold spell (source Brussels, COM(2014) 654 final, based on ENTSOG) 2015 Gasunie Transport Services B.V., Groningen Page 21 of 42

22 3 DUTCH INFRASTRUCTURE AND SUPPLY STANDARD 3.1Specifics of the Dutch gas system The Dutch internal gas market is due to the large indigenous production only little influenced when flows in (North West) Europe are interrupted. Moreover, the Netherlands does not depend on a single production facility. The Groningen field alone is divided into 29 production clusters. Additional production is delivered through more than 235 so-called small fields. In this Assessment no distinction is made between Groningen gas (G-gas) and high-calorific gas (H-gas) because this distinction is of no relevance for the supply and infrastructure standard due to the provisions in the Netherlands for quality conversion (see paragraph 4.3). The Dutch network is nevertheless divided into systems for G-gas and for H-gas, as is illustrated on map. In the Netherlands there is one LNG-terminal; GATE. The Dutch gas network is developed in such a way that LNG can be transported to both the Dutch market and to all its neighbouring countries. Storage facilities exist for both G-gas and H-gas. Their details are listen in the public table below. In addition to the data in the figure below, it is worth noting that the Underground Gas Storage Norg has recently been significantly expanded. The withdrawal capacity increased to 76 mcm/d and the working gas volume to about 7 bcm Gasunie Transport Services B.V., Groningen Page 22 of 42

23 Besides storage on Dutch territory, the Netherlands is directly connected to several German storages (see overview in chapter 6) Facility/Location Company Type Working Gas Withdrawal Capacity Injection Capacity Access TPA ntpa Project TPA ntpa Project TPA ntpa Project The Netherlands ,40 66,25 Grijpskerk (*) NAM Gas Field (not depleted) ,00 12,00 not applicable Norg (Langelo) (*) NAM Gas Field (not depleted) ,00 24,00 not applicable Maasvlakte Gasunie LNG Peak Shaving 78 31,20 0,25 not applicable Alkmaar (*) TAQA Energy BV Depleted Field ,00 3,60 not applicable Bergermeer (**) TAQA Energy BV Depleted Field ,00 42,00 negotiated Zuidwending I Gasunie Zuidwending Salt Cavity ,20 26,40 negotiated (*) Grijpskerk and Norg (NAM) + Alkmaar (TAQA) = Groningen System > No longer offering capacity, to be considered as a production facility, no access regime applies (**) Bergermeer : Capacity available before fully operational : negotiated regime Figure 12 Storage facilities in the Netherlands 2014, source: Security of supply in the Netherlands is delivered through an effective gas market. Commercial incentives on shippers/suppliers are vital to provide sufficient gas to customers. The Dutch virtual gas hub TTF is for example the most liquid gas hub on the European continent. This highly effective gas market is supported by an additional legal framework which safeguards security of supply. It should nevertheless not be forgotten that although infrastructure might be available, it is in the end up to shippers and traders to supply gas to where and when it is needed in the right amount. As described in the Dutch Preventive Action Plan in detail, the security of gas supply in the Netherlands is stipulated in Public Service Obligations. Most relevant with regard to the protected customers are the Dutch Gas Act and the Decision in Relation to Security of Supply Pursuant to the Gas Act. 3.2Definition of protected customers Protected customers in the Netherlands are explicitly defined in the Dutch Gas Act as: customers who have a connection to a network with a total maximum capacity not exceeding 40m3 (n;35,17) per hour. The protected customers comprise the households and small enterprises. Demand of protected customers is detailed in paragraph Supply to protected customers based on three pillars (public service obligations) The Netherlands has a clear methodology (legal obligations) for controlling and enforcing the implementation of the supply standard. The Dutch government has set clear standards for the security of supply of protected customers. It should be noted that Dutch protected customers are in majority supplied with locally produced gas. In effect ensuring the Dutch gas supply to protected customers (security of supply) is based on three pillars: 2015 Gasunie Transport Services B.V., Groningen Page 23 of 42

24 3.3.1Pillar I: Peak supply a responsibility of GTS The obligation for security of supply (peak supply) is allocated to the Dutch transmission system operator GTS. Peak supply was provided by GTS in the recent winters 2009/2010, 2010/2011 and 2011/2012. On the basis of the Decision Security of Supply Gas Act, the Dutch national transport operator GTS is legally responsible to annually contract (transparent, non-discriminatory and marked based) both the capacity and the volumes that are necessary in order to be able to supply the additional amount to the small consumers market in the Netherlands when average daily effective temperatures are between -9 o C and -17ºC (so called peak supply). The contracts related to peak supply may only be claimed by GTS on the day when official weather forecasts predict an effective daily temperature for the next day in the city of De Bilt with a maximum of -9C. When there is no effective -9C or lower situation, the capacity and volume can be used by the market. It should be noted that Dutch protected customers are supplied in majority with locally produced gas. Under the -9ºC/ 17ºC conditions end-suppliers buy the required capacity and volume from GTS and together with the capacity and volume the suppliers already contracted upto -9ºC the protected customers can be supplied. The Dutch Regulator ACM monitors this process. In the Dutch balancing regime it is not possible to wait for the end of the gas day to allocate the peak supply amounts. As shippers are responsible for balancing their portfolio, it is necessary to allocate the amount of gas delivered by GTS near real time and to adjust the portfolios accordingly. Therefore, the allocation rule is: if during an hour in a portfolio, the sum of all allocations for household customers exceeds the capacity for that portfolio associated with a -9ºC day, the excess volume will be allocated to the shippers as a peak supply delivery by GTS. The capacity associated with a -9ºC day is equal to the exit capacity that is invoiced in winter (December/January/February). As peak supply is related to the weather pattern during a day and its resulting demand. This means that actual peak supply is only delivered during a few hours a day (morning/evening peak). This means that peak supply can be delivered during several days. The volume reserved by GTS for peak supply is about 95 mcm. This is only 0.1% of the annually by GTS transported amount of gas. Lowering the standard to a 1:20 would reduce this volume demand with 2% of 95 mcm. This is 1.9 mcm (g-gas) 2015 Gasunie Transport Services B.V., Groningen Page 24 of 42

25 which is % of the by GTS annually transported amount of gas (this amount is so low because it is the peak of the peak demand) Pillar II: a licensing system for suppliers of protected customers There is a licensing system for suppliers of protected customers in the Netherlands. Suppliers of small consumers are set standard requirements, amongst others through chapter 5 of the Dutch Gas Act and the Decision license for delivering gas supply to small consumers. A supplier can get his license from the Authority for Consumers & Markets (ACM), the Dutch regulator, only when he can prove his ability to provide his customers in the circumstances stipulated in the license. ACM publishes the companies with such a license on its website. The requirements to gain a permit can be summarised along the four following main requirements (which are supervised by the Dutch Regulator): The obligation to supply to any small customers (protected customer) who requires so. The obligation of a constant reliable supply. The obligation to apply fair tariffs and fair conditions. The obligation to be organisationally, financially and technically sound. Suppliers that have a permit need to live up to 4 requirements: The obligation to supply to any small customers (protected customer), to collect the transport fares and to transfer this money to the regional network operators. The obligation to timely inform the ACM about organisational, financial and technical changes. The obligation to provide information to the ACM about the result of the business undertaking. And the obligation to provide clear, understandable information to its customers about billing and contract wise. The obligation to inform ACM about new tariffs, tariff changes, supply conditions and the gas quality Pillar III: GTS to take action in case of bankruptcy of a supplier The Dutch transmission system operator GTS is statutorily responsible for the uninterrupted supply of gas to protected customers in case of a bankruptcy of a supplier, by guaranteeing the payment to producers and by the co-ordination of the re-distribution of protected customers of the bankrupt supplier among the remaining suppliers. In such a case GTS has a coordinating task to make sure that the customers of the non-compliant supplier continue to receive gas. Noncompliance of a supplier does not imply shortage of gas, and will therefore be solved by the market. In this way these customers can choose a new supplier within a reasonable time without an interruption in their gas supply. Bankruptcy of a supplier does therefore not imply shortage of gas towards the protected customers Gasunie Transport Services B.V., Groningen Page 25 of 42

26 3.4The Netherlands applies a 1-50 infrastructure standard Article 8 of the Regulation sets minimum requirements in respect of the supply standard. In the Netherlands, standards for the infrastructure and security of supply have been laid down via the Gas Act and since 2004 in the Decision Security of Supply Gas Act. 4 The Dutch standard is stricter than the minimum standard laid down in Regulation 994/2010/EU.5 Other member states also apply stricter standards. The existing Dutch standard for infrastructure is related to a situation corresponding to a probability of once in every 50 years, occurring in the central Dutch city of De Bilt. The data sheet, figure 13 overview lowest temperatures in De Bilt since 1961 taken from the Royal Netherlands Meteorological Institute, shows that on the 14th January 1987 it was effectively -17 C in De Bilt. Figure 13 Overview lowest temperatures in De Bilt since Temp1=effective temperature, source: KNMI. 3.5Security of supply report Directive 2009/73/EC Supplying the Dutch gas market even under severe conditions does not require additional market measures. The Dutch balancing system plays an important role in this, as is detailed in paragraph 4.6. Only in case of a catastrophe customers might be interrupted. This is further detailed in the Dutch Emergency Plan. 4 the order in Council of 13 April 2004, laying down regulations regarding provisions in connection with security of supply (Decision Security of Supply the Gas Act) 5 Regulation 994/2010/EU article 8(2) 2015 Gasunie Transport Services B.V., Groningen Page 26 of 42

27 The availability of infrastructural capacity does, however, not guarantee that there will be sufficient gas volumes available; availability of gas depends on the contracted volumes by shippers/traders and, finally, on the physical volumes they deliver. Directive (EG) 2009/73 and REG 994/2010 require all EU member states to report annually to the Commission about the Security of Supply situation. The Dutch Security of Gas Supply report 6 pursuant to Directive (EG) 2009/73 article 5gives an outline of the short-term and medium-term security of gas supply in the Netherlands. This report looks 20-years ahead. The report deals with a number of themes which, as a whole, give an outline of the security of gas supply situation in the Netherlands. Peak and emergency supply are also examined. The report is based on information sent by market parties to the Dutch transmission system operator. Shippers are asked to state the volumes they are currently expecting to ship during the next twenty years and whether that volume has already been contracted or if that is not yet the case. Together with an estimate of the trend in Dutch gas demand, this information can be used to give insight into the degree to which Dutch demand can be met by contracted supply volumes already known at present. This investigation does not result in a forecast of the balance between demand and supply but gives an insight into the extent to which the Dutch gas demand can be fulfilled with contracted supply volumes known at present. From this data, two scenarios are compiled. The first scenario, the Base scenario investigates to what extent sufficient gas has already been contracted in order to meet Dutch demand (the base scenario). The Second scenario is the expectation scenario, which incorporates the total of the reported volumes, including the proportion of the volume indicated by shippers as not yet having been contracted (the expectation scenario) but that probably will be contracted. The base scenario of the 2014 report shows that for the coming years, up to and including 2019, sufficient gas volumes are contracted to meet Dutch demand. After this, starting 2020, a situation develops where contacted volumes are lower than Dutch gas demand. This means that volumes known at present for that period must be supplemented with additional contracts, in order to cover Dutch demand fully. The expectation scenario, based on already contracted and not yet contracted volumes, paints a similar picture. In this scenario sufficient volumes will be available until and including 2022, where after the estimated supplies approximately equals Dutch demand. 6 Rapport Voorzieningszekerheid Gas Gasunie Transport Services B.V., Groningen Page 27 of 42

28 4 OBLIGATIONS IMPOSED ON NATURAL GAS UNDERTAKINGS AND OTHER RELEVANT BODIES 4.1General legal framework Dutch gas undertakings are bound by the Dutch Gas Act, which stipulates amongst others the following tasks related to security: To take measure for the safe operations of the system, To take measures relating to security of supply (including peak-period delivery and supplier of last resort deliveries), To provide quality conversion, To monitor the reliability, quality and safety of the system, To provide other network operators with information in order to allow for safe and efficient day-to-day transport. The legal obligations related to the infrastructure and supply standard (measures relating to security of supply) were described in chapter 3. This chapter details other obligations related to security. 4.2Safe operations of the system Quality and safety of the gas system are of utmost importance in and for The Netherlands. Article 10 of the Dutch Gas Act stipulates that system operators, gas storage companies and LNG companies are legally responsible for providing and maintaining a safe, efficient and reliable gas transmission network, storages and LNG facilities, in a way that respects the environment as much as possible. All parties are required to provide each other with sufficient information to ensure that transport, storage and LNG-operation can be executed secure and efficient. 4.3Quality conversion 4.3.1Within the Netherlands Physically the national Dutch G/L-gas and H-gas networks are separated. The ministerial decree on gas quality ( Regeling Gaskwaliteit ), which is in effect since 1 October 2014, specifies gas quality requirements of entry and exit points. The two networks which together form the national grid are connected through blending stations. These can blend the different gasses and/or use nitrogen to produce the required Wobbe-index. To balance the capacity decrease of the Groningen field, the construction of a new nitrogen facility is foreseen to be realised by the end of Gasunie Transport Services B.V., Groningen Page 28 of 42

29 Shippers can nevertheless book capacity on any entry/exit point without indicating quality. To deliver gas with the correct quality is a legal responsibility (Dutch Gas Act, Articles 10(3d) and 10a (1n) of the physically delivering network operator: for gas which is physically delivered to the national grid, this is the operator of the gas production grid or the upstream network or storage operator.. And for the physical delivery to the power plants, industries, District System Operators and Neighbouring Network Operators this is GTS 4.3.2L-gas in neighbouring countries Low calorific gas (L-gas) is a combination of Dutch Groningen gas (G-gas), originating from the Groningen field, blended with High calorific gas (H-gas) or nitrogen, or H-gas blended with nitrogen. L-gas is exported to Germany, Belgium and France. The current market demand for all L-gas countries is shown in the overview below. It indicates the different sizes of the markets, the countries producing L-gas, G/Lgas storage and the quality conversion facilities. Figure 14 Overview of G-gas and L-gas market (source: North West Gas Regional Investment plan) It has become clear that, due to decreasing G-gas production, the current L-gas market demand cannot be sustained. Other sources of gas will, in due course, 2015 Gasunie Transport Services B.V., Groningen Page 29 of 42

30 replace the L-gas sources. This topic is being discussed in the Pentalateral Gas Platform with representatives of the involved Member States. Due to a gradual decrease of L-gas coming from the Netherlands, a gradual conversion of the markets in Germany is foreseen to start around 2020 to be followed later on in Belgium and France (circa 2024). The conversion of the domestic market in the Netherlands is not likely to start before 2030, because the current appliances are not suited to switch between different gas qualities. Conversion of the markets will take several years since all appliances have to be checked and adapted to a different gas quality range and adaptation of infrastructure is also required. Part of the requirement for future market conversion the German NEP takes into account a reduction of L-gas import capacities from the Netherlands. To prepare Germany for the L-gas decline and the reduction of indigenous production the conversion of some L-gas areas will start around The ENTSOG TYNDP does not model the conversion of L-gas markets because the future need for L-gas substitution is neither a matter of resilience of the system nor can L-gas be imported from somewhere else, which is the core focus of the TYNDP. The conversion of this market into H-gas markets will be the result of on-going intensive interaction between governments, TSOs and suppliers. Currently, evaluations are carried out regarding the possibilities for the substitution of L-gas; the exact impact this may have on infrastructures has not yet been fully determined. 4.4Control system In accordance with the provisions in article 8 of the Dutch Gas Act all Dutch system operators (gas transmission and distribution) need to have an effective control system to monitor the reliability, quality and safety of the system. These provisions are detailed in the Ministerial Decree on Quality Aspects of Transmission System Operation. The control system to manage the quality of the provided transport services also includes a section on safety indicators. This obligation requires (since 2005, in the odd years) the publication by each Dutch transmission and distribution System Operator of a so-called Quality and Capacity Document. In this document each system operator has to: demonstrate it has an effective quality control system for its transport services and other services; describe the quality levels to which it aspires; describe which safety indicators are applied; demonstrate it has sufficient capacity to be able to meet total gas transport requirements; 2015 Gasunie Transport Services B.V., Groningen Page 30 of 42

31 describe which investments, including replacement investments, are needed in order to maintain the quality and continue with the expansion of the gas transmission grid in order to meet total requirements for gas transport. To testify they have an effective quality control system for their assets, all Dutch transmission and distribution system operators are certified to the Dutch technical standard NTA 8120 on asset management, related to the NEN-ISO series, or are aiming at being that soon. An important part of the quality control systems is the assessment of risk related to all activities of the system operators. By connecting the strategic objectives of the system operators to the identified risks, an optimal mode of operation for the system operators can be achieved. In accordance with the provisions contained in Article 35a of the Gas Act and in the Ministerial Decree on Quality Aspects of Transmission System Operation, system operators yearly have to publish a Report on Quality Indicators. The report contains an analysis of the actual quality levels in the previous year, and the quality levels that the system operator aspires to, as described in the 'Quality and Capacity Document'. The Dutch NRA (ACM) with the assistance of the State Supervision on Mines (SodM) audits the Quality and Capacity and the Report Quality Indicators documents. All publications are publicly available on the websites of the system operators. 4.5Day-to-day operations The Dutch transmission system operator monitors the integrity of the transmission network through a system of measures designed to control risk. Constantly sharing of information with other network operators is an integral part of this. Transport security does not just depend on the design criteria for the infrastructure and the proper implementation of management and maintenance, but also on the way in which the transport system is controlled. The balance between these elements ensures efficiency and transport security. In the event of any interruption in the supply, a round-the-clock on-call service ensures that problems are solved effectively, if necessary in close cooperation with other parties, like the Dutch government. The form that the interruption in transmission (under an emergency situation) takes in specific cases is mainly determined by: 2015 Gasunie Transport Services B.V., Groningen Page 31 of 42

32 the magnitude of the emergency, geographic location, the speed with which transmission can be restarted, the consequences of the interruption. 4.6Balancing The Dutch balancing system plays an important role in maintaining general system integrity. The transmission network must be in balance in order to let gas be transported safely and efficiently. 'In balance' means that the network remains within the allowable pressure limits because the volume of gas extracted from the network is in equilibrium with the volume injected into the network. The last change to the balancing regime was on 3rd June 2014 where the system was adapted to be compliant with the European Network Code on Balancing. Under the Dutch balancing regime, every market party is responsible for the volume of gas that it extracts from or injects into the system. Market parties are jointly responsible for maintaining the balance of the network. All parties have continuous insight into their own position. The overall balance position of the entire national network, or the total of the positions of all parties, can also be followed by everyone 24/7. This results in the transparency desired by all parties. As long as the position of the overall network remains within the allowable limits, the network will be in balance and none of the parties will be required to take action. The same will apply even if an individual party is not in balance. Parties can either use own (contracted) means, or buy or sell gas themselves on the TTF (Title Transfer Facility), the Dutch virtual gas trading platform. If they fail to do so adequately and the imbalance rises to unacceptable levels, GTS will buy or sell the necessary amount of gas to mitigate the imbalance at the best price available on the exchange of ICE-ENDEX. The costs will be charged on a pro-rata basis to the causers of the imbalance. They pay the volume weighted average price of the products that GTS received or delivered on the exchange. 4.7Other obligations The Dutch gas system has furthermore to comply with all Dutch and European legislation with respect to many different safety aspect. The main requirements are included in: the Dutch Environmental Protection Act, (in particular) the Decision External Safety Pipelines 2011, the Pressure Equipment Directive (97/23/EC) Gasunie Transport Services B.V., Groningen Page 32 of 42

33 In annex 2, an overview is given of the most relevant European and national regulations and standards for the safe operation of the gas system that are applicable in The Netherlands. A general overview of all applicable regulation is available (in Dutch) through the website of the Netherlands Authority for Consumers and Markets at The following is a summary of some of the preventive actions executed by the Dutch transmission system operator (listing of relevant regulation can be found in the annex of this report): (1) In order to be able to monitor the safety and reliability of the Dutch high pressure grid and, where necessary, to make adjustments, a number of quality performance indicators have been developed. Realistic standards or target values (signal values) are associated with these performance indicators in order to be able to test the results achieved against the objectives. The performance indicators, with their associated signal values, thus form a cohesive system of quality indicators. The published indicators include among others: number of interruptions, average time to safeguard the failure, number of accidents reported to the Dutch Safety Board, number of leaks in the transmission system, number of leaks in connections. (2) A number of preventive measures are taken to keep pipelines in good condition. Pipelines are, for example, coated and cathodically protected against corrosion and have to undergo regular sight inspections (for example a helicopter flight inspection of the grid every two weeks). The integrity of the transport system is monitored with the help of a continual inspection programme. Pigging operations have been performed for many years now. (3) On 1 January 2011, the new Decree on the External Safety of Pipelines (Besluit Externe Veiligheid Buisleidingen (BEVB)) and associated regulations came into force in the Netherlands. This decree stipulates that pipelines carrying hazardous substances, including natural gas pipelines, must be marked on zoning plans, including the corresponding strip of land affected and there must be a system for obtaining construction permits in that strip of land in order to protect the pipeline and energy supply Gasunie Transport Services B.V., Groningen Page 33 of 42

34 (4) Excavation work is still the main cause of damage to the underground pipeline network. Since 1 July 2008, the Act on Information Exchange for Underground Networks (Wet Informatie uitwisseling Ondergrondse Netten (WION)) has come into force in the Netherlands. Excavators are obliged to report planned excavation work. This Act also comprises precautionary measures for the relevant networks, such as marking the pipeline at the place where proposed work is planned and supervision during the work. (5) Dutch pipeline transport companies register their pipeline incidents via VELIN. Information is available on European gas transport companies register their pipeline incidents in a similar way. Information is available via (6) The high pressure transport installations and other installations fulfil specific requirements laid down by legislation and regulations with regard to external safety. Large locations are also subject to reporting obligations within the scope of the Decree on the Risks of Serious Accidents (Besluit Risico s Zware Ongevallen (BRZO)) and/or Supplementary Risk Inventory and Evaluation (Aanvullende Risico Inventarisatie en Evaluatie (ARIE)). Since 1999, the so-called Seveso II Directive has been in force within the European Union, and it has been implemented in the Netherlands by the 1999 Major Accident Decree (BRZO 99). One of the obligations that has been imposed on organisations falling within the scope of the Decree is to draft a Serious Accident Prevention Policy (PBZO). This PBZO document specifies how to prevent different types of serious accidents Gasunie Transport Services B.V., Groningen Page 34 of 42

35 5 REGIONAL COOPERATION 5.1Regional cooperation Since the discovery of the Groningen field in 1959 The Netherlands has played an important role in the supply of gas to the North West European region. Currently the North West region has one of the worlds highest levels of gas penetration in households, industries and power plants. The North West European market represents approximately 50-60% of the total EU-28 peak gas demand. 7 The North West European gas transportation grid was built to transport indigenous production from Dutch and UK gas fields to regional demand centres. Yet due to dwindling indigenous production, the requirement to source gas from further afield became a necessity resulting in infrastructure projects undertaken to bring gas to the North West region from Norway and Russia, as well as in the form of LNG. Besides an exporting country The Netherlands also became a transit country. As a result the already intensive regional cooperation only further increased. With more and more gas supplies originating from distant sources additional local swing is required, mainly through an increase in Storage capacity. The link between storage located on German territory and the Dutch gas network is another example of the close regional cooperation. All these years of cooperation and experience have result in intensive contact with neighbouring TSO s. 5.2Operational cooperation TSOs are challenged to run their networks as efficiently as possible either through incentives or other mechanisms, and as such solving constraints on cross-border points is part of the day-to-day operational business of TSOs. Neighbouring dispatching centres work closely together, where required, optimising gas flows and operation of the network in the region. The dispatching centres of the region have various means to deal with such crossborder issues. For example: To swap gas (re-routing), not only bilaterally but also tri-laterally, Operational Balancing Agreements (OBAs), Mutual assistance, for instance to reduce fuel gas, Exchange of personnel, knowledge and knowhow. 7 Gas Regional Investment Plan Northwest Europe Gasunie Transport Services B.V., Groningen Page 35 of 42

36 All these years of cooperation and experience have resulted in intensive contacts between the neighbouring TSO s in North West Europe. Working with Neighbouring Network Operators (NNOs) is for GTS as common practise as working nationally with Distribution System Operators (DSOs). In case of a constraint at an interconnection point (whether this is due to maintenance, climatic conditions or interruption of supply) NNOs inform each other and relevant shippers immediately through bilateral contacts and through publication on the respective websites. Various actions can be taken to overcome or minimize the constraint. Either through the balancing regimes, or by re-routing gas via other entry/exit points in case the preferred route is constrained. The case study of the German cold spell (included in the North West Gas Regional Investment Plan 2013) illustrates the effective operational cooperation in North West Europe Gasunie Transport Services B.V., Groningen Page 36 of 42

37 5.3Gas Regional Initiative The Gas Regional Initiative was initially founded by ERGEG (the predecessor of ACER) to speed up the integration of Europe's national gas markets. The development of regional gas markets is seen as an important and practical step towards the eventual goal of a competitive, single-european gas market. The overall aim of the Gas Regional Initiative is to push forward, at a practical level, the development of regional gas markets in collaboration with industry, Member States, the European Commission and other stakeholders. Currently, the GRI Northwest is non-active. 5.4Regional cooperation security of supply Regional issues related to security of supply are addressed and discussed in the Pentalateral Gas Platform. In this platform the following representatives of the Ministries responsible for energy policy of Member States participate: Belgium, France, Germany, Luxembourg and the Netherlands, while the Commission is sometimes invited as an observer. The Benelux Secretariat provides logistic support. National Regulatory Authorities or Transmission System Operators are also sometimes invited. 5.5Regional cooperation within ENTSOG With the 3rd Energy Package the European Network Transmission System Operators (ENTSOG) was founded. The Netherlands has been an active member from the start. The bi-annual publication of the Ten Year Network Development Plan and the Gas Regional Investment Plan are examples of these new ways of cooperation in the North West region Gasunie Transport Services B.V., Groningen Page 37 of 42