Energi-, Forsynings- og Klimaudvalget 2015-16
EFK Alm.del Bilag 7
Offentligt
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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.
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2
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,
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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.
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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
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countermeasures might influence other member
states. However, a common template might make it
difficult to take national specificities into account.
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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.
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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?
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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.
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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.
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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
10
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.
11
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
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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”
12
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.
13
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.
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