kom (2015) 0340 - Bilag 2: Orienterende notat samt høringssvar Kommissionens høringsmeddelelse om En ny udformning af energimarkedet og høring om Beredskab om el-forsyningssikkerhed

Europaudvalget 2015-16
KOM (2015) 0340 Bilag 2
Offentligt

Denmark’s response to the Commission’s consultation on risk

preparedness in the area of security of electricity supply.

Ministeren

No.

Question 1-9

”Risk identification and

management”

Whilst Directive 89/2005

imposes a general

obligation on Member

States to ensure a high

level of security of supply,

the Directive does not

specify what measures

Member States should

take to prevent risks.

Would there be an added

value in requiring

Member States to draw up

a plan identifying

relevant risks and

preventive measures to

respond to such risks

(risk preparedness

plans)?

If yes, what should be the

minimum requirements

such risk preparedness

plans should comply

with? For instance,

should they:

a. explain the various

types of risks?

In Denmark, it is required that all companies active

in the energy sector draw up specific emergency

plans including risk and vulnerability analysis, risk

preventing measures and risk mitigating steps.

These plans all fit under the overall energy sector

preparedness plan (in Danish the

“sektorberedskabsplan”) in which tasks and

responsibilities are laid out (“who does what”).

For Denmark the benefit of having the issue

regulated at the European level would be in an

enhanced cross border coordination of the risk

plans preparedness plans.

In general the Risk Preparedness Plans should

allow the market to play a central role, and only in

the exceptional event that the market cannot

respond adequately non-market measures should be

activated.

a. A focus should be placed on the assessment of

scenarios which influence more countries where

there could be a spill over effect on other countries,

kom (2015) 0340 - Bilag 2: Orienterende notat samt høringssvar Kommissionens høringsmeddelelse om En ny udformning af energimarkedet og høring om Beredskab om el-forsyningssikkerhed

b. identify the demand

side measures Member

States plan to take (e.g.,

use of interruptible

contracts, voluntary load

shedding, increased

efficiency, energy

savings)?

c. identify the supply side

measures Member States

plan to take (e.g.,

increased production

flexibility, increased

import flexibility)?

d. assess the expected

impact of existing and

future interconnections?

e. identify roles and

responsibilities?

f. identify how Member

States co-operate or

intend to co-operate

amongst each other to

identify, assess and

mitigate risks?

g. other elements?

for example the drought and heat wave in Germany,

France and Italy in the summer of 2003 and in

Poland now in 2015, where it becomes an issue for

the surrounding countries.

b. In case of load shedding the commission is

encouraged to consider a market based solution,

based on which consumers are most willing to pay

for supply or who has the least to lose by being cut

off from supply for a short period of time.

Experience from the natural gas sector shows that it

is not necessarily the protected customers who have

the largest losses when not supplied. This implies

that a harmonised approach across Europe would

not necessarily bring the best results, as it is

important that local and national specificities can

be taken into account. Only after all market based

tools are exhausted should non-market based load

shedding be applied as a measure of last resort.

c. The application of reserves and the sharing of

these across borders are relevant issues to be

addressed. It is important to include electrical

bottlenecks rather than only country borders.

d. Existing yes. On future interconnectors, it would

be prudent to include an assessment in the

development phase of interconnector projects.

e. It is imperative that it is clear to whom the roles

and responsibilities are given and that this is

included in the Risk Preparedness Plans.

f. Focus should be on a clear division of roles and

responsibility.

g. The issue of transparency versus confidentiality

should be addressed in regards to the sharing of

information. Frequent emergency exercises should

be an integrated part of the risk preparedness plans.

Do you think that it would

be useful to establish a

common template for risk

preparedness plans?

The focus should rather be on content rather than

templates.

If a decision is made that requires all member states

to prepare Risk Preparedness Plans, it would

probably be beneficial to ensure they contain

roughly the same information and that they are

coordinated between neighbours as some

kom (2015) 0340 - Bilag 2: Orienterende notat samt høringssvar Kommissionens høringsmeddelelse om En ny udformning af energimarkedet og høring om Beredskab om el-forsyningssikkerhed

countermeasures might influence other member

states. However, a common template might make it

difficult to take national specificities into account.

Given that electricity

markets are increasingly

interlinked, should risk

preparedness plans be

prepared at the national,

regional or EU level?

In general the Risk Preparedness Plans should be

prepared by those who will use the plans. Be it the

Member States, the regional level or EU level.

Given that, it would seem that all TSOs/countries

have some considerations on how to handle risk.

However, as the markets and power systems are

getting more and more interconnected it is sensible

to look at Risk Preparedness Plans on a larger scale

than a purely national one. Given also the

introduction of RSCIs across Europe, it would seem

like a good place to place such considerations and

development of plans.

In terms of language the Risk Preparedness Plans

should be written in the language best understood

by those who will have to work with the plans.

Do you see a role for the

Commission in assessing

these plans? Would you

see an added value of

having the plans peer

reviewed, at a regional or

EU level?

What role do you see in

this context for the

Electricity Coordination

Group?

What level of

transparency should be

given to the plans?

Who should be informed

of what?

How often should risk

preparedness plans be

made / be updated? What

are the relevant time

frames to be covered?

If the content is coordinated, meaning that the Risk

Preparedness Plans cover roughly the same topics

and are coordinated at the regional level, there will

not be much added value of a Commission

assessment and/or a peer review. Regional

coordination of the plans will ensure good quality

level of the plans.

The level of transparency should be as high as

possible taking into account the fact that the plans

could be misused as “blueprints” for those wishing

to damage the electricity supply.

The risks and limits of sharing confidential

information will have to be addressed.

Risks can change quickly due to changes in the

production and consumption patterns, changes in

the grid as well as experiences gained from

incidents.

Consequently a fixed review period (for instance 3

years) needs to combined with a “if needed”

criterion to be able to respond to such changes.

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Given the challenges that

DSOs are facing (e.g.

integration of renewables,

more decentralised

systems), should DSOs

take an active

participation in the

assessment of the risks

and preparation of the

risk preparedness plans?

If yes, do you see the need

for separate assessments

and separate risk plans at

the DSO levels?

Or do you believe it is

more appropriate to

ensure an active

participation of DSOs in

risk assessments and risk

preparedness plans

covering the entire

electricity system?

Ensuring cybersecurity is

an increasingly important

aspect of security of

supply. What measures

should Member States

take to protect themselves

against possible cyber-

attacks or

other cyber-related

threats?

Do you see the need for

specific EU rules on

cyber security, targeted to

the energy field? Given

the cross-border nature of

cyber security risks, what

scope is there for

enhancing co-operation

(for instance through the

exchange of best

practices)?

DSOs are not necessarily central in assessing the

risk and consequences for system adequacy and

security when looking at the issues from a Top-

down EU perspective. In Denmark the national

TSO is capable of assessing the risks faced by the

DSOs,

DSOs could however be central in carrying out any

mitigating measures needed to balance the system.

The member states must ensure that they provide

the right framework for the energy sector to operate

the supply chain and transmission grid in a secure

way:

This framework could include the following:

a. Provide that necessary resources (financial

and manpower) are available to secure the

transmission-critical processes.

b. Support the process of implementing an

Information security policy for the critical

systems.

c. Facilitate that proper standards are

established, an example could be a

standard for secure communication

between operators.

d. Demand that there is adequate redundancy

in the critical systems to minimize loss of

energy.

e. Demand that adequate cyber emergency

plans are in place and that they are tested

on a regular basis.

f. Process for continues mapping of data-

flows.

g. Process for identifying learning lessons

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and shearing lessons learned.

h. A procedure for sharing confidential

information regarding imminent threats.

i. Demand adequate confidentiality

regarding data exchange, such as cyber

emergency plans, data-flows and threats.

Member states’ need for confidentiality and

national security should be recognised. The EU

legislation regarding cyber security should

recognise the security arrangements made by the

individual member states, as well as the anatomy of

the national and regional markets (many vs. few

market participants, central production vs.

decentralized and intermittent production etc).

Question 10 -11

”Addressing crisis

situations”

Currently, it appears that

in some Member States,

detailed emergency plans

exist, whereas in others,

there are only very

summary emergency

plans.

Should there be an

obligation for all Member

States to plan for crisis

situations, e.g., by

including relevant rules

and measures in the

overall risk preparedness

plans?

If yes, what should be the

minimum requirements to

be included? For

instance, should Member

States be required to:

a. Identify actions and

measures to be taken in

emergency situations

(market- and

nonmarketbased)?

b. Set out the conditions

In Denmark, imminent decisions during crisis

situations are handled by the national control

centres.

It is difficult to foresee which rules and measures

to follow in a crisis situation. Control centres need

to have the flexibility to respond, so that both

expertise and experience can be brought in to the

decision process.

Following the answer to question number 10 above

any such rules and measures should allow for the

needed flexibility at the level of control centres.

However, as seen in the natural gas sector,

institutional measures such as the Gas Coordination

Group, where member states and the EU

Commission can coordinate actions and analysis in

an efficient manner can be considered.

a. To the extent possible market based actions and

measures should be prioritised. To build a list of

kom (2015) 0340 - Bilag 2: Orienterende notat samt høringssvar Kommissionens høringsmeddelelse om En ny udformning af energimarkedet og høring om Beredskab om el-forsyningssikkerhed

for suspension of market

activities?

c. Identify categories of

'protected customers'

which, in case of a crisis,

should not be subject to a

disconnection measure

(or only be disconnected

by way of a last resort)?

d. Establish rules for cost

compensation?

e. Indicate how they

intend to co-operate with

other Member States?

f. Reflect any other issues

in their plans?

Question 12-14

“Roles and

responsibilities”

In relation to risk

preparedness, how do you

see the roles and

responsibilities of:



national

governments



national regulators



TSO's



DSO's



European bodies

such as ENTSO-E,

ACER, and the

Electricity

Coordination

Group?



European

Commission



other stakeholders,

such as

consumers?

Given the fact that many

actors are concerned by

security of supply issues,

would you see an added

possible actions and measures could be beneficial

but should not be exhaustive.

b. Often it is only possible to assess the need for

market suspension after an incident.

c. Denmark has only identified such protected

customers within supply of natural gas.

d. Should be included into the market based

solution.

e. By focusing on roles and responsibilities any

legislation and cooperation might be more

functional.

Risk Preparedness Plans will have to be a

combined effort of several participants. The key

participants are the member states (the national

governments or bodies appointed by them), the

TSOs (and the regional RSCIs) and for

coordination

purposes

the

Electricity

Coordination Group together with ENTSO-E.

In Denmark the DSOs have a market based

incentive to cost reduce within risk preparedness.

The TSO does not have the same incentive. The

single TSO is therefore a relevant supervisor for

the DSOs crisis preparedness plans in the Danish

model.

It is important that – for the purpose of regional

cooperation and regional coordination - that there is

a SPOC (single point of contact). However this

does not necessarily imply that a single Competent

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value in the designation

by each Member State of

a ‘Competent Authority’,

responsible for

coordinating security of

electricity supply issues

at national level?

If it is decided to

strengthen regional co-

operation on a more

structural basis between

various players (e.g.,

when drawing up risk

preparedness plans), how

should regions best be

defined?

Authority needs to be appointed.

Considering that the Danish TSO is a government

owned company the Regional Security

Coordination Initiatives (RSCI) could be a

sufficient regional structure. The RSCIs enhance

the operational cooperation of the TSOs.

The RSCIs such as for instance the TSO Security

Cooperation (TSC) in which Energinet.dk

cooperates with 12 other TSOs will deliver

increasingly important data and coordination to the

participating TSO and thereby enabling that system

security is maintained.