Consultation on the draft consent decision of the Dutch Minister of Economic Affairs dated June 24, 2016 in respect of gas extraction at Groningen

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1 Consultation on the draft consent decision of the Dutch Minister of Economic Affairs dated June 24, 2016 in respect of gas extraction at Groningen ENGIE s response paper [ENGIE Energie Nederland NV / Gerda FRANS, ref.nr E-45] Date : 10/08/2016 The draft consent decision of the Dutch Minister of Economic Affairs (the Draft Consent Decision ) dated June 24, 2016 related to the cap of L-gas production from the Groningen field and the associated advice from Gasunie Transport Services (GTS) (the GTS Advice ) dated June 8, 2016 (together the Documents ), are particularly relevant to ENGIE s interests. As a European gas midstreamer, ENGIE ships large quantities of low-calorific gas (L-gas) to Belgium and France, through its long term supply contract with GasTerra, for the supply of 1,8 million of L-gas end-users. ENGIE welcomes the consultation launched by the Dutch Minister of Economic Affairs regarding its Draft Consent Decision. This consultation gives the opportunity to stress the importance of a finetuned steering of L-gas production in the Netherlands, for both seismic and gas security of supply (SoS) risks management. ENGIE would like to highlight that these issues must be addressed from both short and mid-term perspectives, in the context of the forthcoming conversion of L-gas end-users installations into H-gas installations in Belgium, France and Germany. In view of all these elements, ENGIE will hereafter highlight that : I. An accurate assessment of L-gas volumes needs is of utmost importance II. The L-gas volumes needs used in the Documents could be distorted by potential L to H- gas injection flows III. The Documents lack consideration for short-term flexibility and peak gas balance issues IV. ENGIE proposes to provide support to set up and implement solutions concerning the L- gas extraction issues at Groningen now and in the future V. The Groningen production cap should be reviewed before 2021 to ensure a smooth L to H-gas conversion transitory period in the interest of all stakeholders I. An accurate assessment of L-gas volumes needs is of utmost importance Despite the trend in the decline of L-gas demand observed in the recent years, ENGIE would like to emphasize that the decision on the cap to the Groningen production should result from a deep analysis of L-gas end-users needs of each supplied country, based on each local regulatory framework in force. 1

2 As the exclusive supplier of the French L-gas zone, ENGIE estimates the needs of the French L-gas end-users for the next Gas Year (GY 16) as follows 1 : - 4,4 Bcm under normal weather conditions, - 4,7 Bcm in case of cold weather conditions. For Belgium, needs for L-gas users for GY 16 can be approximatively estimated as follows : - 5,0 Bcm under normal weather conditions, - 5,4 Bcm in case of cold weather conditions. In its advice, GTS only refers to a 5 Bcm consumption for a cold year both in Belgium and France. GTS does not provide any figures for an average winter, although GTS indicates, on the third page of its advice, that those figures have been freshly updated. ENGIE recalls that such figures may decrease in the next years and undoubtedly before 2021, depending in particular on the progress of the respective domestic conversion projects of L-gas endusers installations into H-gas installations. II. The L-gas volumes needs used in the Documents could be distorted by potential L to H-gas injection flows ENGIE would like to point out that the GTS Advice does not take into account any potential exit flow from L-gas to the H-gas zones through blending plants. Indeed, several blending plants in the Fluxys and GRTgaz networks enable the injection of several Bcm/y of L-gas into the H-gas transmission networks in France and Belgium. Yet, volumes flowing into those blending installations are a key parameter in the analysis, which is complementary to the physical needs of end-users, and is currently neglected. In case of observed or expected injection of L-gas into the H-gas transmission networks, a common goal must be the adjustment of L-gas supply contracts to the exact needs of L-gas end-users, in order to avoid as much as possible injection of L-gas into the H-gas transmission networks just for the purpose of satisfying annual contractual commitments of oversized L-gas contracts. To prevent such a scenario, L-gas buyers such as ENGIE should be allowed to adjust their contractual commitments downwards. Otherwise, L-gas buyers could be in the same situation as ENGIE for GY16 and beyond, i.e. in order to satisfy its contractual commitments with GasTerra, ENGIE will be forced to inject several Bcm of L-gas into the H-gas transmission networks via the blending plants. Without such downward adjustments of L-gas contracts, several Bcm shall be produced each year (from Groningen and/or nitrogen plants) in addition to what is currently considered in the GTS Advice. 1 These figures are given as L-gas volumes, in Bcm, as bought to Gasterra. In other words, they do not correspond to G-gas as extracted from the Groningen field (G-gas produced in Groningen is then mixed with H-gas to get L-gas as exported to downwards countries). 2

3 III. The Documents lack consideration for short-term flexibility and peak gas balance issues Sensitivity of L-gas consumptions to temperature deviations requires to maintain some flexibility in the L-gas production from the Groningen field to prevent any gas disruption risk. In this context, the rate of upward flexibility of Groningen production proposed by the Dutch Ministry, up to 6 Bcm/y compared to a reference value of 24 Bcm/y under normal conditions (i.e. +25 %), seems high enough to cope with an annual over-consumption in case of a very cold year and to meet SoS requirements in the countries to be supplied (Germany included). However, ENGIE would like to point out some key issues regarding flexibility management for short time-frames. ENGIE notably notices from the State Supervision of Mines (SodM) advice that : - on the one hand, the amount of earthquakes and Groningen production fluctuations (seasonal included) seem correlated, - on the other hand, additional investigations seem needed, as the current seismic calculation model NAM is requiring further clarifications. While the SodM explicitly calls to avoid fast production fluctuation (weekly/monthly) 2, NAM considers that a Uniform rate of extraction could be met via a maximum variation of production of 20 % from a month to another, without any intra-month limitation. Meanwhile, GTS in its advice and the Ministry of Economic Affairs in its Draft Consent Decision are using NAM hypothesis as is. Based on the Documents provided for this consultation, there does not seem to be any stricter fluctuation constraints than a +/- 20% monthly volume deviation range. In particular, extreme dayahead and weekly variation seem to be allowed without any constraint, in absence of any peak flow analysis (in m 3 /h or in m 3 /d) and of any assessment of the minimum rate of flexibility required for. Yet, decisions regarding volume and peak flexibility are necessary linked to each other, as for any gas supply contract. Proceeding with a flow assessment in m 3 /h, complementary to the volume analysis, is indeed of utmost importance and cannot be avoided in view of a goal of uniform rate of production over the gas year. If there are tighter within-month constraints, they should be provided in the Documents to assess their compatibility with market needs. In this context, ENGIE calls for more transparency on these flexibility and peak gas balance issues, as this topic is insufficiently discussed in the Documents. An annual production cap of 24 Bcm, which would still allow a very volatile production on short timeframes, does indeed seem of limited fact to seismic risk management at Groningen, as it seems to require a rate of extraction as uniform as possible. Moreover, ENGIE considers that such transparency is a prerequisite to envisaging any decision regarding the project of new nitrogen plant at Zuidbroeck, for which a decision as regards investment is expected by the end of this summer. Furthermore, ENGIE notices from the GTS Advice that the Groningen field would still be required to ensure a back-up role to cope with various operational outages or hazards, in the order of 0,5 million m 3 /h. In this context, ENGIE would like to point out that a downward adjustment of its contractual commitments, as mentioned in the paragraph II above, could release some flexibility to the disposal of the Dutch market in the same order of magnitude than the one requested by GTS. 2 Seismisch risico Groningenveld, Beoordeling rapportages & advise, Staatstoezicht op de Mijnen, December 2015, page 43. 3

4 IV. ENGIE proposes to provide support to set up and implement solutions concerning L-gas extraction issues at Groningen now and in the future As evoked above, ENGIE considers that an efficient L-gas system is key to ensuring SoS to L-gas customers all over Europe and a smooth L to H-gas conversion transitory period. An efficient L-gas system means, among others, a fined-tuned production of the Groningen field adapted to the needs, which would avoid production of useless L-gas volumes. In particular, a situation where oversized L-gas export contracts would force buyers to flow several Bcm/y of L-gas to the H-gas markets, downstream from the Netherlands, would imply an excess of L- gas production and should be avoided. This would be very detrimental to the limitation of earthquakes in the Netherlands and to the sustainability of the Groningen production field. Holding significant subscribed capacities for storage, quality conversion and transport in the L-gas networks in France, Belgium and in the Netherlands, ENGIE confirms being fully open to envisaging a significant reduction of the flexibility levers currently applicable into its L-gas supply contracts. Such a reduction could contribute to a more efficient management of L-gas supply throughout Europe (in particular a more stable production of the Groningen L-gas) as from GY 16 and for the interest of all stakeholders involved. ENGIE has been willing for a while and is still willing to downsize its L-gas supply contract to avoid such a situation both in a short term and long term time frame. Obviously, ENGIE is not entitled to do so unilaterally and therefore needs the agreement of its L-gas supplier, GasTerra. V. The Groningen production cap should be reviewed before 2021 to ensure a smooth L to H- gas conversion transitory period in the interest of all stakeholders The Dutch Ministry of Economic Affairs intends to set a production cap at Groningen field at 24 Bcm a year combined with a minimization of monthly fluctuations, with a term of the consent decision by 2021, i.e. over a 5-year horizon. While the cap of 24 Bcm could be adequate for the coming GY 16, ENGIE would like to point out that maintaining such a fixed cap over a 5-year period would not make sense in the context of the upcoming L-to-H gas conversion project. As the conversion project will be deployed in each country involved by 2019, maintaining a production cap at a fixed value until 2021, whereas L-Gas needs will significantly lower in the meantime, would be detrimental to both seismic risk management and sustainability of the Groningen field, in a context of depletion of its production. The potential risk of excess of L-gas, compared to the needs of end-users, as mentioned in chapter I above for GY 16, could even be amplified in the following years due to the L-to-H gas conversion project and the associated decrease of L-gas needs. Moreover, there still are some significant uncertainties on the rhythm of the conversion of the endusers, for each of the countries involved, as well as on the conversion from L to H-gas of some key infrastructures (ex : storages). In this context, ENGIE advocates for a review of the 24 Bcm/y cap of the Groningen production prior to 2021 and preferably by GY 18. Such a short-term review could indeed enable a further reduction of the cap in line with the progress of the conversion projects. 4

5 CONCLUSION An adjustment of L-gas supply contracts to the exact needs of L-gas end-users is crucial in order to lower L-gas to H-gas flows and avoid useless L-gas production ; More transparency on flexibility management and peak gas balance issues is needed ; ENGIE holds significant subscribed capacities for storage, quality conversion and transport in the L-gas Networks in France, Belgium and in the Netherlands which could favour the reduction of L-gas supply from Groningen and therefore decrease seismicity risks ; A review of the 24 Bcm/y cap of the Groningen production on a regular basis and before 2021 is highly recommended ; ENGIE confirms that it has been and is still fully open to envisaging a significant reduction of the flexibility rights currently applicable into its L-gas supply contract. Obviously, ENGIE is not entitled to downsize its L-gas supply contract unilaterally and therefore needs the agreement of its L-gas supplier, GasTerra. * * * 5