4. NATURAL GAS

to leave the European Union poses challenges to Ireland’s energy security. It is crucial for the Irish government to ensure stable energy trades between the two countries, particularly cross-border gas and electricity flows. The British government announced in October 2018 that mechanisms governing the cross-border trades would not change fundamentally, but adjustments may be required.

In addition to twinning of the SWSOS between Cluden and Brighouse, work is ongoing to build independent compressor systems for IC1 and IC2. The project is due for completion in 2020.

Emergency response

Policy and organisation

Ireland has set up a legal framework for gas security based on the following act and regulations:

 Gas (Interim) (Regulation) Act 2002 and amendments made by Statutory Instrument 697/2007 specify that the Natural Gas Emergency Plan (NGEP) should set out procedures for the declaration and handling of an emergency. The NGEP also defines roles of the various bodies involved in an emergency event and provides measures to ensure that supplies to vulnerable customers, as determined by the CRU, are protected.

Statutory Instrument 336/2013 gave legal effect to EU Regulation 994/2010. EU Gas Security of Supply (SoS) Regulation 2017/1938, repealing Regulation 994/2010, came into force in November 2017 to ensure all necessary measures are taken to safeguard an uninterrupted supply of gas throughout the European Union. Solidarity and enhanced regional co-operation among EU member states are the guiding principles of this new regulation.

The EU gas SoS Regulation has three levels of emergency crisis:

Early warning: if an event is likely to result in significant deterioration of the gas supply situation.

Alert: if a supply disruption results in a significant deterioration of supply, but the market is still able to manage that disruption without the need to apply non-market-based measures.

Emergency: if a major gas supply disruption results in significant deterioration of supply and market measures and non-market-based measures are introduced to safeguard gas supply to protected customers.

Overall responsibility for security of gas and electricity supply lies with the CRU, which is statutorily obliged to monitor the SoS in Ireland and to take any measures necessary to ensure continuity of supply. The regulator role includes the appointment of a National Gas Emergency Manager, whose role is pivotal in the management of an emergency event. The GNI was appointed to this role of manager, and its duties include development of the NGEP.

Network resilience

The Common Arrangements for Gas Project commenced in 2008 between Northern Ireland and Ireland. It aimed to harmonise technical operations of the gas transmission networks in both jurisdictions. The project was suspended and replaced with new EU internal gas market network codes, now being implemented by the GNI.

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4. NATURAL GAS

The new EU gas infrastructure standard N-1 evaluates a member state’s ability to satisfy total gas demand in case of a disruption of its single largest gas infrastructure on the day of exceptionally high gas demand, which has a statistical probability of once in 20 years. The EU infrastructure standard is met when the N-1 value is greater than or equal to 100%. Ireland and the United Kingdom apply a more severe criterion to ensure that their markets are able to meet at least a once-in-50-years peak demand. In Ireland, the CRU places an obligation on shippers and suppliers to book capacity for a 1-in-50 peak day at the network exit point, as set out in Ireland’s network code of operations. The GNI (Irish TSO) has oversight of the gas activity and ensures the capacity is booked.

The 2016 National Risk Assessment identified the Moffat entry point (with the two subsea interconnectors IC1 and IC2) as the single largest piece of infrastructure. The risk assessment reconfirmed that if a failure happens at Moffat, Ireland is unable to meet the N-1 infrastructure standard as set out in Regulation 2017/1938. The result of the N-1 calculation was 35% (28% without market-based measures). This calculation was done with the median supply and demand scenario set out in the GNI 2016 Network Development Plan. The analysis is based on production figures for the year 2018/19. The CRU agreed a regional approach with the competent authorities in the United Kingdom and Northern Ireland and a joint risk assessment and preventive plan. With a joint risk assessment between the United Kingdom and Ireland, the combined N-1 calculation equals 134%.

In case of a gas supply emergency, Ireland is likely to call for solidarity from its EU neighbouring countries (under the EU gas SoS Regulation 2017/1938). Although it is uncertain how the solidarity mechanism will function when the United Kingdom leaves the European Union, it is important for Ireland to maintain close co-operation on this regional risk-based approach.

Completion of the project to have independent compressor systems for IC1 and IC2 at Brighouse Bay in 2020 will result in a revision of the largest piece of gas infrastructure for Ireland as defined in the EU gas SoS Regulation 2017/1938. N-1 failure will constitute a partial disruption of IC1 or IC2, instead of a complete disruption with failure of IC1 and IC2, as considered at the moment in the 2016 joint risk assessment.

Emergency response measures

There are no public stocks of natural gas in Ireland, and since 2017 there has not been a storage site in operation. If there is a gas supply emergency, Ireland relies on supplyside measures (import flexibility via pipeline and increased domestic production) and demand-side measures (interruptible contracts, fuel switching and load shedding).

Ireland’s gas interconnectors (IC1 and IC2) provide a level of line pack security. If there is a loss of supply at the Moffat gas entry point, the line pack in IC1 and IC2 could potentially supply Irish gas demand on a 1-in-50 winter for 5 days. However, this provision of 5 days is based on the assumption that all gas-fired power stations could switch fuel, from gas to diesel, within 5 hours, and no line pack is diverted to Northern Ireland through the SNP via IC2.

Indigenous gas supplies are mostly at maximum production, which implies that no additional indigenous supply is available in an emergency. Biomethane production and injection into the natural gas network in Ireland is at an early stage of deployment and will not contribute to the SoS in the near term.

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