EMERGENCY PLAN FOR SECURITY OF SUPPLY OF NATURAL GAS
_______________________________________________________________
THE NETHERLANDS
Within the framework of Regulation (EU) No 994/2010 of the European
Parliament and of the Council of 20 October 2010 concerning measures to
safeguard security of gas supply and repealing Council Directive 2004/67/EC
December 2014
Energy Market Directorate
Ministry of Economic Affairs
The Netherlands
Introduction
Regulation (EU) No 994/2010 of the European Parliament and of the Council of 20
October 2010 concerning measures to safeguard security of gas supply and repealing
Council Directive 2004/67/EC (hereinafter ‘the Regulation’) stipulates, among other
things, that Member States must draw up an emergency plan detailing the measures to
be taken to deal with an unexpected disruption of the gas supply, when it is not possible
to deal with the crisis by means of the more usual measures referred to in the preventive
action plan.
This plan is the emergency plan for the Netherlands. Our country occupies a unique
position within the European Union when it comes to natural gas. Within the European
Union, the Netherlands is the largest net exporter of natural gas and is expected to
remain a net exporter of natural gas until at least 2025. This situation also affects (the
contents of) this emergency plan. Given its sizeable domestic production and the option it
has of making use of this should imports be disrupted, the Netherlands is relatively
immune to an unexpected disruption to the gas supply in (north-west) Europe. This is
further reinforced by the fact that Dutch gas production is not dependent on a single
source. The Groningen field, the largest source of Dutch natural gas, has over 20
independently operating production sites, in addition to which gas is also extracted from
235 ‘small’ fields.
Consequently, the emergency plan for the Netherlands can be and is relatively
straightforward. As described below, there is a crisis organisation, which is activated in
the event of a serious disruption to the gas supply. However, given the situation in the
Netherlands with regard to natural gas, there is no need to fall back on non-market
based measures, and domestic production may and can be relied upon to absorb any gas
supply problems.
The emergency plan for the Netherlands is developed below, using as its starting point
the subjects listed in Article 10(1) of the Regulation for inclusion in the emergency plan.
This emergency plan was sent to the Dutch Transmission System Operator, the National
Regulatory Authority and to our neighbouring countries for consultation. Their comments
were taken into account in this final version.
1. Crisis levels (Article 10(1)(a))
In general, crisis management in the Netherlands involves four distinct phases, which
correspond to the timeline of the (impending) crisis:
1. Normal phase: preparing for a crisis by keeping scenarios up to date and through
crisis awareness, education, training and exercises.
2. Alert phase: there are signs that a crisis is imminent or that a serious incident needs
to be addressed. From the alert phase, it is possible to call off the alert phase and
return to the normal phase, or to escalate to the crisis phase.
3. Crisis phase: addressing and managing the crisis.
4. Post-crisis phase: Calling off the crisis organisation, evaluating and adjusting
scenarios.
From the normal phase it is possible to upscale either to the alert phase or the crisis
phase, which is known as escalation. There are two types of escalation, namely
informative escalation and organisational escalation.
Informative escalation
Escalation from ‘normal’ to ‘alert’ is known as informative escalation. This type of
escalation is necessary when a heightened state of alert is needed with regard to the
situation and it is essential to be well-informed and to be able to exchange information
quickly and appropriately. The normal organisational structure continues to be used on
the basis of the usual responsibilities. Such escalation is designed to optimise internal
and external information exchange, also with a view to prepare for possible escalation to
the crisis phase.
Organisational escalation
This type of escalation is necessary when the day to day organisation cannot anticipate
the situation that has occurred or is expected to occur. Organisational escalation makes it
possible to coordinate and expedite internal procedures for information exchange,
decision-making and taking action.
2. Role and responsibilities of natural gas undertakings and of industrial gas
customers (Article 10(1)(b))
In so far as any roles and responsibilities in times of crisis have been defined, they relate
only to distribution and transmission system operators. Under Article 51 of the Dutch Gas
Law, these network system operators are required to draw up an emergency response
plan every 5 years. Article 20a of the Ministerial Order ‘Quality aspects of management of
electricity and gas networks’ (Staatscourant, 2004, 2531) lays down more detailed rules
with regard to these emergency response plans. The requirements with regard to
emergency response plans relate primarily to procedural requirements in the event of a
crisis. A rigorous procedure must be followed to develop the crisis management system,
and it must be subject to adequate organisational guarantees. The precise content is the
responsibility of the network system operator itself.
3. Role and responsibilities of the competent authorities and of the other
bodies (Article 10(1)(c))
The Minister of Economic Affairs (EZ) is the competent authority for implementation of
the Regulation 994/2010. The Minister of Economic Affairs has political responsibility for
energy supply, while the network system operators have operational responsibility. This
division of responsibilities means that the Minister is responsible for determining the
policy framework in all phases of crisis management. Within the framework set, the
network system operators do what is expected of them. An example of this is that the
Minister must indicate in the framework (response phase) whether certain groups of
customers or sectors are to be given priority access to energy supply. Network system
operators then take this into account in their interruption plans. The Minister has only
very limited operational control over the gas and electricity sector. Ultimately, it are the
national transmission system operator (GTS for gas) and the distribution system
operators that have the authority to control gas flows within the networks.
Another aspect of political responsibility is that the Minister is accountable for his policy
measures and has to inform the Dutch Parliament and the general public about the
extent, cause and consequences of a crisis, and about the policy measures he has taken
to mitigate the effects of such a crisis. This implies that there must be an extensive and
up-to-date network of crisis managers in the sector in order to enable efficient
information exchange between the sector and the Minister.
A clear distribution of responsibilities entails resolving a crisis at the lowest level possible
(at municipal level for a municipal crisis, at provincial level for a provincial crisis and at
national level for a nationwide crisis) and means that other ministries are responsible for
1 the Official Journal of the Netherlands, containing new laws and governmental announcements
their own policy areas (i.e. the Ministry of Safety and Justice for law and order and
security, the Ministry of Health, Welfare and Sport for public health, etc.). Cascading
dependencies can lead to a crisis in the energy sector spreading to other sectors.
Combating this therefore requires an escalation to involve other ministers.
The crisis organisation of the Ministry of Economic Affairs is integrated into its day to day
organisation. All of the support and policy directorates concerned are responsible for
making adequate preparations for and combating a crisis when it occurs in their policy
area. With regard to gas supply, this means that the primary responsibility lies with the
Energy Market (EM) Directorate, which is part of the Directorate-General for Energy,
Telecommunication and Competition (further abbreviated DGETM). The management
team of the Energy Market Directorate appoints a crisis coordinator for gas, who has an
important role to play in the field of crisis management, both in the day to day
organisation and in the crisis organisation, and maintains contacts with the gas sector.
The crisis coordinator is also a member of the Energy Crisis Team (ECT) and the
operational EZ crisis team. The Energy Market Director is ultimately responsible for crisis
management in the field of electricity and gas and is the chairman of the ECT. At the
Ministry of Economic Affairs, the Departmental Coordination Centre for Crisis
Management (DCC) is responsible for the general coordination of crisis management,
both within the Ministry and on an inter departmental basis.
4. Opportunity for natural gas undertakings and industrial gas customers to
respond (Article 10(1)(d))
As stated, the Minister for Economic Affairs has political responsibility for energy supply,
while the network system operators have operational responsibility. This division of
responsibilities means that the Minister is responsible for determining the framework in
all phases of crisis management. Within the framework set, the network system
operators do what is expected of them.
The Gas Law and the secondary legislation based upon it include a number of provisions
intended to guarantee security of gas supply. For example, the Minister monitors security
of supply each year. As part of this, he also examines measures to deal with peak
demand or the failure of one or more suppliers.
The network system operator has an important role to play, especially in guaranteeing
security of supply. It is the task of the network system operators to guarantee the safety
and reliability of the networks, and they should make arrangements with regard to
security of supply. Furthermore, they must have a quality control system relating, among
other things, to the safety and reliability of the transmission and distribution service and
have sufficient capacity to ensure transmission and distribution. If necessary, the
Minister can impose investment obligations on network system operators.
The national transmission system operator for gas, GTS, has been given additional tasks
and responsibilities by law to make arrangements regarding security of supply.
Depending on the seriousness of a possible crisis, GTS will primarily use market based
measures, which can be done through the market oriented balancing system. Under this
system, all parties (shippers) operating on the gas network must be in balance within a
certain period of time. If this does not happen, for whatever reason, GTS has the means
to redress the resulting imbalance. It can use the bid-ladder to buy or sell the deficit or
surplus of gas on the market. The costs thus incurred by GTS are passed on to the party
that caused the imbalance. In a very serious crisis, GTS can give shippers a specific
instruction with the aim to restore the balance within the network. In case this does not
lead to results and the system remains in a situation of imbalance (the ‘red’ zone), GTS
may call an emergency and can act as described below.
GTS may call an emergency situation if and when it is confronted with large, unexpected
disturbances in the transmission network, including communication and control systems,
which may endanger the integrity of the network. In such a situation GTS take the
following measures:
(1) use of means which may have been contracted for emergency situations;
(2) instructions regarding installations for the storage of gas and LNG and entry point of
the transmission network;
(3) instructions regarding exit points of the transmission network. This means that exits
can be instructed to reduce their off-take or to which off. The effect is that the
household sector will be affected last.
The legal for these measures to be taken by GTS can be found in the Gas Act, article 17b
(7) ‘The network operator of the transmission network may give instructions on the
execution of a submitted programme, if this is necessary for the efficient execution of the
operator’s legal tasks.’
In addition to these day-to-day tasks and responsibilities, all network system operators
must work together to guarantee the transmission and distribution of gas and electricity
even in exceptional circumstances.
The Department for Energy of the Authority for Consumers and Markets (ACM, Dutch
Competition Authority) monitors compliance with and implementation of the legislation.
5. Measures and actions regarding district heating and electricity production
(Article 10(1)(e))
In the Netherlands, the district-heating and electricity-production sectors also operate on
the gas market. In a crisis, they are protected through the balancing system operated by
GTS.
When it comes to the supply of electricity and the dependency from natural gas, the
Dutch transmission system operator for electricity, TenneT, has updated its emergency
plan in which more attention is given to the interdependency between gas and electricity
production, especially in the Groningen area where gas production locations get a
preferred treatment when there are disturbances in the delivery of electricity.
Furthermore there are generic emergency measures if and when production fails.
There is no specific ranking order for shutting down the supply to gas customers. This is
not deemed necessary, because there is no need for a short-term decision for a
shutdown of certain customers, as is the case with electricity, due to existing buffers of
gas. Furthermore, it is technically impossible to shut down certain customers or objects,
because they are connected to the distribution network, which in turn receives gas from
a gas receiving station. It is not possible to make a selection of clients after the gas
receiving station, so a shutdown of a particular gas receiving station would mean that all
customers who are located behind that station would be shut off.
The TSO has the possibility to make agreements with those parties that are connected
directly to the national gas grid. Also, priority is given to certain vital services, whose
continuous service depends on the continuous availability of gas, such as large gas-fired
power plants.
6. Procedures and measures to be followed (Article 10(1)(f))
Prior to or during (impending) disruptions and crises, the DCC and the various policy and
support directorates have their own tasks, responsibilities and powers within the
Ministry’s crisis organisation. The Energy Market Directorate’s responsibility for
(impending) crises in the gas sector is restricted to the downstream sector. Crises in the
upstream sector are dealt with by the State Supervision of Mines (Staatstoezicht op de
Mijnen, SodM). If a crisis in the upstream sector has repercussions for the downstream
sector, the Energy Market Director is involved.
Responsibilities
The division of responsibilities between the DCC and the Energy Market Directorate is as
follows:
• the DCC is responsible for general coordination of crisis management, both within the
Ministry and on an inter-departmental basis;
• the DCC is responsible for auxiliary matters in relation to crisis management;
• the DCC identifies the framework within which the policy and support directorates
must develop crisis management;
• The policy and support directorates are responsible for developing crisis management
within their own policy or support area, taking into account the framework set by the
DCC.
Powers
Depending on the crisis management phase, decisions are made either by the DCC or by
the Energy Market Directorate.
In the normal and alert phases, decisions are made by the Energy Market Directorate and
action is taken in accordance with the crisis management manual for gas and electricity.
In the crisis phase, decisions are made by the DCC and action is taken in accordance with
the basic EZ crisis management manual.
Distribution of tasks
The following tables show the tasks to be performed by the DCC and the Energy Market
Directorate, respectively, in each crisis management phase.
Normal
DCC
• Acting as the initial and general
contact and information point at the
Ministry, contactable 24/7.
• Looking
out
for/following
developments which may indicate a
serious disruption in any of the
Ministry’s policy areas.
• Coordinating the Ministry’s crisis
management policy.
• Conducting inter-departmental and
international consultations which do
not specifically fall within the remit of
the support and policy directorates.
• Internally guaranteeing and
continuously improving crisis
management, among other things
through a policy on training and
exercises.
• Ensuring that information is gathered
and
distributed
on
an
(inter-)departmental basis in the field
of general crisis management.
• Providing auxiliary support to the
Ministry’s crisis organisation before,
during and after a crisis.
phase
Energy Market Directorate
• Internal and external contact point
with regard to crisis management in
the gas and electricity sector.
• Looking out for/following
developments which may indicate a
serious disruption in its own sector.
• Informing the sector about its
responsibilities, tasks and powers, so
that the sector really does shoulder its
responsibilities.
• Maintaining contacts with the sector
and, where necessary, putting items
on the agenda for the relevant regular
consultations that take place.
• Keeping the sector manual up to date
(which includes updating the contact
and availability details).
• Informing the DCC about relevant
developments with regard to crisis
management in the sector.
• Participating in crisis exercises held on
a departmental or inter-departmental
basis or by organisations within the
sector.
• Responsibility for the necessary basic
information and keeping it up to date.
Alert phase
DCC
Energy Market Directorate
• Information exchange with the Energy • Information exchange with the DCC
Market Directorate (notification,
(notification, situation).
situation).
• Deciding on the (de-)escalation level.
• Advising on the escalation level.
• Continuously monitoring the latest
developments with regard to the
current situation.
• Informing the Communications
Directorate of any escalation.
• Maintaining contacts with partners in
the chain.
Crisis
DCC
• Information exchange with the Energy
Market Directorate.
• Advising the EZ Management Board
(Bestuursraad) on the (de-)
escalation level.
• Setting up the necessary crisis rooms.
• Dealing with the post-crisis phase.
phase
Energy Market Directorate
• Information exchange with the DCC.
• Setting up the ECT.
• Member of the Operational Team and
the Policy Team.
Upon receipt of a notification, there is immediate communication between the DCC and
the Energy Market Directorate. The crisis coordinator for gas verifies and gathers the
relevant information with regard to the notification received. He then classifies the
situation into one of the three crisis management phases (normal, alert, crisis). Once the
situation has been classified, the crisis coordinator informs the Energy Market Director
and the Head of the DCC. After obtaining advice from the Head of the DCC, the Energy
Market Director decides which escalation level to go to.
7. Crisis manager/crisis team (Article 10(1)(g))
If a crisis occurs, the Energy Market Director can activate the ECT. In performing its role,
the ECT mirrors the day to day organisation as much as possible and is chaired by the
Energy Market Director or a member of the Directorate’s management team. The ECT
functions as a ‘back office’ for the staff members of the Energy Market Directorate who
have seats in the Ministry’s crisis organisation teams, i.e. the Policy Team and the
Operational Team.
The ECT consists of the following people:
• chairperson: Energy Market Director or a member of the Directorate’s management
team;
• member: crisis coordinator for gas/electricity;
• member: policy officer at the Energy Market Directorate;
• member: policy officer at the Energy Market Directorate.
The ECT has the following tasks:
• gathering information and verifying its accuracy with companies and other relevant
partners;
• analysing the information received and producing a summary and overview of critical
points;
• drawing up the measures to be taken;
• informing and advising the Policy Team and/or Operational Team on the measures to
be taken;
• maintaining contacts with the sector and reporting on this;
• maintaining contacts with other public authorities and reporting on this;
• taking minutes of meetings;
• keeping abreast of incoming and outgoing information and ensuring follow up to
information processing and compliance with any feedback sought;
• ensuring that the information that has already been gathered is accessible;
• classifying the situation if there are any changes.
If the situation changes and can be classified as crisis management phase ‘normal’ or
‘alert’, the Energy Market Director can decide to dissolve the ECT, making sure that the
tasks resulting from the ECT are duly transferred to the day to day organisation.
8. Contribution of market based measures (Article 10(1)(h))
It is for the network system operators and other parties operating on the gas market to
determine what measures to take to cope with a crisis. The competent authority has no
influence on this. However, where appropriate, the GTS can give shippers instructions
with the aim of balancing the network and maintaining or restoring that balance (see
paragraph 4).
9. Contribution of non-market based measures (Article 10(1)(i))
As stated in the previous paragraph, it is for the network system operators and other
parties operating on the gas market to determine what measures to take to cope with a
crisis. Consequently, in the Netherlands, no use is made of the non-market based
measures listed in Annex III to the Regulation (none of which are therefore included in
the legislation in force).
Only in the case of an emergency and then only as a measure of last resort, GTS can
instruct certain exits to reduce their off-take (see section 4).
10. Cooperation with other countries (Article 10(1)(j))
In times of crisis, it may and will be necessary to cooperate with other (surrounding)
Member States to cushion the effects of disruption to the gas supply. The Netherlands
has no cooperation agreements with other (surrounding) Member States which come into
force only in times of crisis. Through the Pentalateral Gas Platform, the Netherlands is
engaged in more general cooperation with Belgium, Germany, France and Luxembourg
on matters relating to natural gas (operation of the market, security of supply). If
required by the nature and scale of a potential crisis, that platform will be used to
mitigate its consequences. Furthermore, use will be made of existing regular (diplomatic)
relations with Member States and the European Commission where necessary. This will of
course depend on the nature and scale of the crisis. The Netherlands also anticipates that
there will be a role for the Gas Coordination Group set up pursuant to the Regulation.
Cooperation between TSO’s
In times of crisis, it may be necessary to cooperate with other (surrounding) TSO’s to
cushion the effects of disruption to the gas supply. The dispatching centres of the WestEuropean TSO’s have frequent regular contacts on a daily basis in order to safeguard a
smooth operation of the West-European gas transport. The Dutch TSO does not have
cooperation agreements with other (surrounding) TSO’s which come into force only in
times of crisis.
In case of an emergency the TSOs will consult each other to find practical short-term
solutions. This regular consultations of TSOs facilitate an unhampered gas flow on Dutch
border points.
The cooperation between TSO’s has been formalised in the Third Package (Regulation
715/2009). The formalised cooperation has led to the identification of network related
bottlenecks in the Ten Year Network Development Plan of ENTSOG. In addition, the
Dutch TSO did its own analysis of (future) bottlenecks, amongst others using the findings
of the market consultation through its two-yearly open seasons.
In the Gas Regional Investment Plans for Northwest-Europe a more in-depth analysis is
made for the region. This two-yearly plan gives insight in the regional gas supply and
demand balance, infrastructure developments, ongoing and planned projects and in the
way TSO’s cooperate with each other.
11. Reporting obligation (Article 10(1)(k))
Besides the reporting obligation under the Regulation, there are no reporting
requirements in the Netherlands other than those mentioned in this emergency plan.
12. Predefined actions to make gas available in the event of an emergency
(Article 10(1)(l))
The Netherlands have no predefined actions to make gas available in the event of an
emergency. GTS does, however, have the legal responsibility to safeguard the security of
supply for protected customer in periods of extreme cold weather (-9 / -17 degrees
Celsius). GTS uses amongst others the LNG peak shaver installation in Rotterdam for this
purpose
The Netherlands do not have any commercial agreements between the parties involved in
such actions or compensation mechanisms for natural gas undertakings. The only
possible exception to this is the purchase of gas by GTS as a result of the -9/-17 rule,
(under the Dutch Gas Law). This is further described in the Dutch Risk Assessment and
the Preventive Action Plan.
As regards the cross border supply of gas, all associated agreements and contracts are in
the commercial domain. The competent authority has no involvement in, or knowledge
of, these agreements (apart from the contracts that are notified to the competent
authority under Article 13(6)(b) of the Regulation).