Question 1

Which regulations describe the way GTS will act in extreme situations?

Accepted Answer

In the event of extreme market conditions, GTS will keep the system balanced as long as possible by the means described in the Transportcode Gas LNB (TCG). EU Regulation 2017/1938 concerning measures to safeguard the security of supply of gas details the circumstances in which the government can declare an emergency situation. According to this Regulation, everything possible has to be done to keep gas available for the ‘solidarity-protected customers’. The emergency plan which is part of the Regulation is implemented in the Netherlands in the so-called Bescherm- en Herstelplan Gas (Gas Protection and Recovery Plan). See the Regulation for more details.

Transportcode Gas LNB

European Regulation

Bescherm en Herstelplan Gas

Transportcode Gas LNB

European Regulation

Bescherm en Herstelplan Gas

Question 2

Are the TTF and certain exit points (e.g. border points) excluded from the measures according to the security of supply Regulation?

Accepted Answer

No. According to the Regulation, which is described in detail in the Bescherm- en Herstelplan Gas (BHG), the competent authority can take all measures that are deemed appropriate to secure the supply of gas to ‘solidarity-protected’ customers. The BHG gives a merit order for certain specific measures. However, if circumstances change quickly, several measures can be introduced at the same time, or measures can be skipped. Please note that ‘solidarity’ means solidarity with other EU member states. This implies that all (neighbouring) EU member states will also have to take measures when gas delivery to ‘solidarity-protected customers’ is threatened in a member state.

Question 3

In an emergency situation GTS can instruct shippers to change their storage nominations. How will GTS act in the event of an emergency situation?

Accepted Answer

GTS will act in accordance with government regulations and stipulations. In the event of an emergency situation in accordance with the TCG, GTS can give instructions on entry and exit points. GTS will communicate these instructions via adapted confirmations (or by phone if necessary). However, if there is a shortage of gas, which cannot be resolved by the means described in the TSC, an emergency security of supply situation will be declared and the measures described in the (BHG) will be called upon. The competent authority will be the Minister of Economic Affairs and Climate Policy. GTS will act according to the Minister’s orders. The Minister of Economic Affairs and Climate Policy will act according to the Regulation, described in the Bescherm en Herstelplan Gas (BHG).

Question 4

Will shippers’ nominations be interrupted by GTS and will GTS instruct shippers via NOMRES as to what they have to nominate? Would shippers be allowed to trade the residual volume in the market or would shippers have to hold on to it to support the SBS?

Accepted Answer

If and when shortages are expected or arise, the market-based system described in the TCG will be kept functioning for as long as possible. GTS will communicate these instructions via adapted confirmations (NOMRES or by phone if necessary). If an emergency security of supply of gas situation is declared, the competent authority will be the Minister of Economic Affairs and Climate Policy. GTS will act according to the Minister’s orders. The Minister of Economic Affairs and Climate Policy will act according to the Regulation, described in the Bescherm- en Herstelplan Gas.

Question 5

In an emergency situation, GTS might reduce withdrawal at exit points. When supplying customers in the GTS/DSO grid, the following groups can de distinguished: GGV, GXX, G1As, G2As, non-metered GGV, non-metered GXX. Which customers can be considered as ’s

Accepted Answer

GTS will act according to the Regulation with the aim being to keep delivery to ‘solidarity-protected customers’ secure as long as possible. In the Netherlands, these consist of the G1As, G2As and essential social services (such as hospitals).

Question 6

What would the consequences be for a shipper's portfolio in relation to the shipper’s customers, assets and storages? How can shippers prepare themselves?

Accepted Answer

The best way to prepare is to have your administrative systems in good shape, so you are able to deliver correct data to the competent authorities when requested. You should also be prepared to act promptly and without discussion according to the orders of the competent authorities (whether directly or via GTS), for instance at your storages or other network points.

In order to reduce the impact of a potential disruption of gas supplies from Russia, GTS also advices policy makers, users of gas and shippers to use the possibilities at their disposal to reduce gas consumption, develop and utilise alternative supply sources and fill storages.

Question 7

How does natural gas curtailment apply to my company? Does it apply to specific exit points designated by GTS (e.g.: natural gas delivery at exit point X will be 0 MW on dd/mm/yyyy) or does it apply to the total natural gas consumption of my company (e.g.

Accepted Answer

If there is an emergency situation according to the Regulation, the competent authority will be the Ministry of Economic Affairs and Climate Policy and GTS will act according to its orders. The Minister has announced that, if the Bescherm en Herstelplan Gas implemented, the 60 largest industrial consumers will be instructed to reduce their consumption of gas to a certain minimum. This will be monitored by the energy sector regulator ACM. The 60 consumers have been informed by the Ministry. If certain consumers do not act according to the instructions, the ultimate measure could be that their connections are cut off from the grid.

Question 8

When will GTS organise the natural gas tender in accordance with the Bescherm en Herstelplan Gas (BHG) plan?

Accepted Answer

The tender described in the Bescherm en Herstelplan Gas (BHG) has not been implemented in the Gas Code/national law.

Question 9

Bescherm en Herstelplan Gas (BHG): how will measure #7 of the Bescherm en Herstelplan Gas (“afschakelen niet beschermde gebruikers” (“disconnection of users who are not protected”) take effect? In which order will customers be switched off?

Accepted Answer

See Q 'How does natural gas curtailment apply to my company'. The order in which customers will be instructed to reduce their gas consumption at particular exits will be determined by the Minister.

Question 10

By how much would each Bescherm en Herstelplan Gas (BHG) measure lead to a reduction in gas consumption?

Accepted Answer

An indication of the gas reduction provided by each measure in the Bescherm en Herstelplan is given in table 4 of the Plan.

Question 11

The Bescherm en Herstelplan Gas (BHG) makes a distinction between essential (“essentieel”) electricity production and non-essential (“niet-essentieel”) electricity production. What does that mean? What does it mean specifically for combined heat and power

Accepted Answer

This is to be decided by the Minister.

Question 12

When a “dwingende aanwijzing” (“binding instruction”) is given to no longer consume natural gas, who will issue it? What legal instruments will be used?

Accepted Answer

See Q 'How does natural gas curtailment apply to my company'. The Minister of Economic Affairs and Climate Policy is the competent authority.

Question 13

When the industrial consumer for whom a shipper has booked exit capacity is switch off, what will happen to the booking, will the shipper get a refund?

Accepted Answer

The focus of the European TSOs and the competent authorities is on security of supply, especially for solidarity-protected consumers. For any questions relating to the working of the Bescherm en Herstelplan Gas (BHG) and compensation for any measure taken in the course of the emergency situation, please contact the Ministry of Economic Affairs and Climate Policy.