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Gas crisis Preparedness

Gas Crisis Preparedness Guideline

Energy Industry Act are described in the “Leitfaden Krisenvorsorge Gas” (Gas Crisis Preparedness Guideline). This guideline details the requirements under Section 21 System responsibility of the Cooperation Agreement Gas IX.

Where bottlenecks occur, established communication channels can help to prevent such situations from occurring in the future and also facilitate the management of bottlenecks. The “Portal Krisenvorsorge Gas” (Gas Crisis Preparedness Portal”) was set up to ensure secure and fast communication between all market participants in an emergency situation. The online portal enables rapid crisis communication between all market participants as well as the administration of contact details and commercial gas parameters. It also supports the simulation of crisis scenarios and periodic communication and function tests.

Your contact at ONTRAS

Denis Gerhardt
Denis Gerhardt
Head of Dispatching Tel: +49 341 27111-2246 denis.gerhardt@ontras.com
Markus Vollhardt
Markus Vollhardt
Group Manager Network Dispatching Tel: +49 341 27111-2558 markus.vollhardt@ontras.com
Thomas Dittrich
Thomas Dittrich
Dispatching Tel: +49 341 27111-2562 thomas.dittrich@ontras.com

All links on the topic

Special edition of the virtual network forum by ONTRAS – gas crisis preparedness

A special edition of the virtual event "ONTRAS.Netzforum" on the topic of “gas crisis preparedness” was held on 17 March 2022. The digital event presented the process flow in the special case of a “stop on Russian gas deliveries” and discussed specific issues with the participating guests. The following provides an overview of the topics covered. Please be aware that we are not able to delve into topics that are outside our scope of responsibility (for example, analysis of the systemic importance of gas-fired power stations, portfolio management if such an incident should occur or legal advice).

Presentation of the event held on 17 March 2022 (link)

Issues of the event

Legal regulations and crisis levels

The legal regulations for the gas crisis preparedness process are described in the German Energy Industry Act (EnWG), the German Energy Security Act (EnSiG), the German Gas Security Ordinance (GasSV), in the European Regulation concerning measures to safeguard the security of gas supply (EU) 2017/1938 (GasSOS Regulation), the Emergency Plan for Gas and the Gas Crisis Preparedness Guideline.

The Emergency Plan for Gas (Item 6, page 17 et seq.) defines the following levels:

A) Early warning level 
The early warning level is communicated by the Federal Ministry for Economic Affairs and Climate Action (BMWK) via a press release.

B) Alert level: 
The alert level is communicated by the BMWK via a press release.

C) Emergency level (EnSiG case)
An emergency level is defined by order of the federal government.
This is communicated by the BMWK via a press release.
The Federal Network Agency is the federal load distributor.
 

Important information at a glance:

  • Emergency Plan for Gas for the Federal Republic of Germany: Federal Ministry for Economic Affairs and Climate Action (BMWK)  (Link)
  • FAQ on the Emergency Plan for Gas of the BMWK (Link)
  • Organisation of the Crisis Team for Gas of the BMWK in German (Link)
  • Information on crisis management and preparedness (gas) on the Federal Network Agency website in German (Link)
  • The role of the Federal Network Agency during gas shortages in German (Link)
  • Legal framework for the secure supply of natural gas on the FNB Gas e.V. website of (Link)

Definition of protected customers

The term protected customer is defined in Section 53a EnWG. Further details on the definition of protected customers are provided on the BDEW website (Link).

The latest (approximate) values for our network on 31.03.2022 are as follows: 

  

  

NKP (network connection point)

NKP (network connection point)

NAP (final Customer)

NAP (final Customer)

  

Percentage non-protected customers

NKP (network connection point)

27 %

NAP (final Customer)

69 %

  

Percentage systemically important gas-fired power stations

NKP (network connection point)

0 %

NAP (final Customer)

7 %

  

Percentage protected customers

NKP (network connection point)

73 %

NAP (final Customer)

24 %

Scenario consideration

ONTRAS is working together with all market participants and in close collaboration with the federal authorities as well as the competent authorities in the eastern German states to ensure that we are well-prepared for possible outage scenarios. We have consulted with our distribution system operators, final consumers, storage facility and biogas plant operators as well as government representatives on the procedure in the event of an imminent gas shortage as defined in the BDEW/VKU/Geode “Leitfaden Krisenvorsorge Gas” (Gas Crisis Preparedness Guideline) to ensure a rapid and coordinated response in an emergency. We considered a range of scenarios and are preparing the appropriate measures.

Daily numbers and data

  • Gas storage facilities: Daily fill level of the gas storage facilities in Germany and Europe: To overview of the gas infrastructure Europe (Link)
  • Gas transport: Interactive map of the gas transport in Germany and Europe supplied by ENTSOG: To ENTSOG map (Link)
  • Capacity utilisation of the LNG terminals: Capacity of the GIE LNG terminals (Link)

Communication via the “Portal Krisenvosorge Gas” (Gas Crisis Preparedness Portal)

At least once a year, ONTRAS initiates a communication and function test to check the availability of our contract partners, rehearse the process and ensure that we can take swift and decisive action.

  • Gas Crisis Preparedness Portal (Link)
  • Information Website (Link)

We communicate with our contract partners through the Portal Krisenvorsorge Gas. Our contract partners in turn then need to communicate with their contract partners.

 

Communication and flow of information between gas network operators

Kommunikationsfluss
Bildquelle: GEOMAGIC

Gas crisis preparedness process

Automated, event-based emails are sent to the 24/7 contacts entered in the Portal Krisenvorsorge Gas. The values entered in the Portal Krisenvorsorge Gas by downstream network operators, storage facility operators and operators of production facilities are immediately integrated into our response measures.

Guide to the portal for: 

  • downstream network operators in German (Link)
  • storage facility operators and operators of production facilities in German (Link)

Depending on the actual situation, our contract partners may implement instructions within a very short space of time (in case of doubt: immediately). ONTRAS itself does not intend to physically restrict access in the standard process. Our contract partners are responsible for the accuracy of the data and for following instructions. 

 

Communication as defined in the guideline

Complete document (in German) as download (Link)

Schema Krisenvorsorge Gas
Bildquelle: GEOMAGIC

Procedure in case of an incident

If a lack of natural gas supply from Russia leads to a gas shortage, it is likely that the entire ONTRAS network area would be affected. 

In the event of a gas shortage, based on the information currently available, ONTRAS will proceed as follows after first exhausting all network- and market-based measures:

  1. Instruct storage facility operators and operators of production facilities to increase their feed-in on a pro rata basis
  2. Reduction on a pro rata basis (non-protected area): downstream network operators, final consumers
  3. Reduction on a pro rata basis (protected area): downstream network operators, final consumers

The aim is to comply with the contractual pressures. As a last resort, the federal load distributor will reach a ruling on shut-offs. The Federal Network Agency is committed to acting in accordance with the principle of proportionality. To enable a structured approach, an IT platform is currently being developed, which will be used to issue standardised instructions to industrial customers (planned go-live Q4/2022).

Compensation regulations

The actions taken by ONTRAS to exercise its obligations under Section 16 of the German Energy Industry Act (EnWG) and in accordance with the Gas Crisis Preparedness Guideline intend to prevent losses for network access customers, customers of downstream network operators, etc. The liability regulations under the entry and exit contract (Section 35(1)) or network connection point contract are based on a culpable act, which is precisely what ONTRAS is making every effort to avoid. In addition, Section 16(3) EnWG stipulates that in case of measures under Section 16(2) or (2a) EnWG and if the conditions regulated therein are present, liability for financial losses is excluded.

If a measure based on the German Gas Security Ordinance can be considered expropriation, Section 11(1) of the German Energy Security Act (EnSiG) provides for the payment of financial compensation. For example, this may be the case if the federal load distributor issues an order on the distribution of gas in accordance with Section 1 of the German Gas Security Ordinance (GasSV). The compensation is payable by the beneficiary of the measure. If no such beneficiary exists, this falls to federal government or the respective federal state. In addition, in certain conditions, Section 12 EnSiG grants an entitlement to hardship allowance provided that the conditions for compensation do not exist.