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The Emergency Plan for Gas sets out the procedure to be followed in the event of an acute shortage of gas in Germany, i.e. in the event of an absolute crisis. The plan is reviewed and revised every four years. At the end of March 2022, Federal Minister Habeck declared the ‘early warning level’ of the Emergency Plan for the very first time. This initiated processes for the gas supply in Germany to be closely monitored as a precautionary measure. Germany’s declaration of this ‘early warning level’ was triggered by Russia’s announcement in late March that payment for its gas deliveries would only be accepted in roubles. The G7 countries responded by rejecting this obligation in a joint declaration issued on 28 March. Due to the further reduction of gas flows from Russia, the gas ‘alert level’ was declared on 23 June 2022.

Security platform provides data for distribution of gas

The Emergency Plan for Gas is supplemented with preparations for the specific action to be taken in the event of a gas shortage, regulations on a fuel switch (a switch to alternative fuels in case of need), regulations on filling the gas storage facilities and the introduction of a Gas Security Platform. This digital platform is operated by the market area manager Trading Hub Europe (THE). In the event of an emergency, this platform supports the Federal Network Agency in its role as federal load distributor in directing the supply of gas that is still available, including gas to industrial consumers, within Germany and to EU Member States whose gas infrastructure is connected to Germany.

In addition to the Emergency Plan, Germany also has a Gas Storage Act which has been in force since 30 April 2022. This act obligates all gas operators in Germany to gradually fill their storage facilities. Germany has by far the largest storage capacities for gas in Central and Western Europe, which are sufficient to supply the country’s gas demand for a relatively long period of time. However, this requires the storage facilities to be at a high fill level at the beginning of the heating season. The new provisions stipulate that the gas storage facilities must be at least 95 per cent full by 1 November of each year. As of now (mid-September), this target fill level has already been reached.

The three levels of the Emergency Plan for Gas

In the ‘early warning level’, gas traders and suppliers, TSOs and distribution grid operators are to ensure security of supply through market-based measures. These may include flexibility options on the procurement side, the use of stored gas, an optimisation of load flows among individual gas supply companies, or the calling up of external balancing energy via the wholesale markets. At this stage, the state does not yet intervene. Flexibility in the electricity system is needed to ensure system stability, for example in light of fluctuations in electricity consumption or generation.

At the ‘alert level’ (Stage 2 of the Emergency Plan), it is still the responsibly of the market players to take mitigating action. The ‘emergency level’ (Stage 3 of the Emergency Plan) only comes into play in the event of a “significant disruption to the gas supply or other significant deterioration of the gas supply situation”. The Federal Government can declare this emergency level by issuing an ordinance.

To view the updated Emergency Plan for Gas, please click here.