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EDITORIAL Welcome to the ninth edition of The International Comparative Legal Guide to: Oil & Gas Regulation. This guide provides corporate counsel and international practitioners with a comprehensive worldwide legal analysis of the laws and regulations of the oil and gas sectors. It is divided into two main sections: Eight general chapters. These are designed to provide readers with a comprehensive overview of key issues affecting oil and gas regulation, particularly from the perspective of a multi-jurisdictional transaction. Country question and answer chapters. These provide a broad overview of common issues in oil and gas regulation in 36 jurisdictions. All chapters are written by leading energy lawyers and industry specialists and we are extremely grateful for their excellent contributions. Special thanks are reserved for the contributing editor Geoffrey PictonTurbervill, of Ashurst LLP, for his invaluable assistance. Global Legal Group hopes that you find this guide practical and interesting. The International Comparative Legal Guide series is also available online at www.iclg.co.uk.
Alan Falach LL.M. Group Consulting Editor Global Legal Group
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Chapter 18
Denmark
Nicolaj Kleist
Bruun & Hjejle
1 Overview of Natural Gas Sector 1.1
A brief outline of Denmark’s natural gas sector, including a general description of: natural gas reserves; natural gas production including the extent to which production is associated or non-associated natural gas; import and export of natural gas, including liquefied natural gas (LNG) liquefaction and export facilities, and/or receiving and re-gasification facilities (“LNG facilities”); natural gas pipeline transportation and distribution/transmission network; natural gas storage; and commodity sales and trading.
The Danish natural gas network was established on the basis of the Natural Gas Supply Act of 1972, the Act on Establishment of a Natural Gas Network of 1979 and the Heat Supply Act of 1979. On 30 May 1979, the Danish Parliament adopted legislation on the construction of a nationwide natural gas supply. The State-owned company DONG Energy A/S (“DONG”) had already been established some years earlier. It was therefore natural to let DONG build and operate the natural gas transmission network. On the distribution side, the municipalities established, in 1978, five regional natural gas planning companies, all of which were later converted into distribution companies. The distribution and sale of natural gas were regarded as public service tasks. Until 2000 these activities were carried out exclusively by DONG and the regional natural gas undertakings. In accordance with the Heat Supply Act, the regional undertakings were subject to a non-profit principle. From 1 January 2004, the Natural Gas Supply Act established a fully open market for natural gas, where natural gas customers have the right to choose their own natural gas supplier. The major part of the Danish natural gas production comes from fields owned by Danish Underground Consortium (“DUC”), which is a joint venture between A.P. Møller-Mærsk A/S, Shell Olie-og Gasudvinding Danmark B.V. (the Netherlands) and Chevron Denmark Inc. (USA).,while DONG, Hess and others account for a minor part. From the fields in the North Sea most of the natural gas is transported to the processing plant in Nybro, located on the west coast of Jutland. The major part of the natural gas is transported through two upstream pipelines while a minor part is transported to the Netherlands through a pipeline connected to the NOGAT pipeline in the Dutch part of the North Sea. From Nybro, natural gas is transported into the transmission system. The transmission system is connected with the transmission systems in Germany and
Morten Ruben Brage
Sweden. There are two natural gas storage facilities: one at Torup in Jutland; and one at Stenlille in Zealand. Both are connected to the transmission system. The two storage facilities are used for seasonal and load balancing and emergency supply. The natural gas used for domestic consumption is transported directly to the consumers through the distribution network. DONG owns and operates the upstream pipelines that transport the natural gas ashore to the plant in Nybro, while Energinet.dk is responsible for the transmission. Energinet.dk owns, operates and develops the Danish transmission network for electricity and gas and is responsible for effective and safe supply and for a competitive energy market. Energinet.dk is owned by the Danish State and must also ensure open and equal access to the transmission networks for all users. Energinet.dk also issues rules on gas transportation and coordinates the general planning of emergency supply for the natural gas sector. The distribution is divided into regions where distribution is handled by DONG in South Jutland and on South and West Zealand, HMN Naturgas handles Central and North Jutland and the capital region, Naturgas Fyn handles the island of Funen (Fyn). All areas serviced by natural gas are accompanied by a supply company to secure all existing and potential consumers of natural gas. The supply companies are owned by, or otherwise related to, the distribution companies. Natural gas consumers have the option to buy natural gas from other gas suppliers. 1.2
To what extent are Denmark’s energy requirements met using natural gas (including LNG)?
Approximately one-fifth of the Danish gross energy consumption is covered by natural gas produced in the Danish sector of the North Sea. In 2012, Denmark produced 6.1bn Nm3 natural gas and imported approximately 0.2bn Nm3 from Germany. Denmark exported 2.8bn Nm3 to Sweden, Germany and the Netherlands. The Danish natural gas consumption in 2012 amounted to 3.7bn Nm3. 1.3
To what extent are Denmark’s natural gas requirements met through domestic natural gas production?
Denmark has been self-sufficient with natural gas since 1997. In 2012, Denmark produced 6.1bn Nm3 natural gas and the Danish natural gas consumption amounted to 3.7bn Nm3.
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Denmark
1.4
To what extent is Denmark’s natural gas production exported (pipeline or LNG)?
In 2012, Denmark imported approximately 0.2bn Nm3 from Germany and exported 2.9bn Nm3 to Sweden, Germany and the Netherlands.
2 Overview of Oil Sector 2.1
Please provide a brief outline of Denmark’s oil sector.
The first permission for investigation for hydrocarbons (oil and gas) in the Danish subsoil was given in 1935. On 8 July 1962, A.P. Møller was granted a 50-year sole concession for exploration and production of oil and gas in the entire Danish territory. Today the licensees are A.P. Møller-Mærsk A/S and Mærsk Olie og Gas A/S. Since 1981 A.P. Møller-Mærsk has gradually relinquished areas previously under the concession. Today only approximately 2 per cent of the Danish territory is under sole concession. The sole concession is exercised by DUC. Mærsk Olie og Gas AS is the operator. On 1 January 2004, the sole concession was extended by 30 years to expire in 2042. The first production field in Denmark was the Dan field, which was discovered in 1972. The Dan field is located approximately 200km west of the coast of Jutland. Production began in 1972 and since then the production of oil and gas has increased significantly. There are five production centres for hydrocarbons: Dan/Halfdan; Gorm and Tyra (all operated by the A.P. Møller group); Siri (operated by DONG); and South Arne (operated by Hess Denmark ApS). The three centres include 19 fields with more than 50 platforms and three subsea installations. All fields are outside the territorial waters but within the continental shelf area and the exclusive economic zone. Other licence holders are Wintershall Noordzee B.V., PA Resources UK Ltd., New World Resources Operations ApS, New World Operations ApS, Total E&P Denmark B.V. and Nikoil Limited. 2.2
To what extent are Denmark’s energy requirements met using oil?
In 2012, the production was 11.7 million m3 equalling 202,196 barrels daily. The 2012 production represents a decrease of 8.6 per cent compared to 2011. The production from the Danish part of the North Sea continues, as expected, to decrease. Production has halved since 2004. The DEA expects the oil production to decline for the period between 2012 to 2015 and then expects a rise in production as new fields are developed and some of the existing fields are developed further. DEA expects that Denmark will remain a net exporter of oil and gas until 2018-2020. 2.3
To what extent are Denmark’s oil requirements met through domestic oil production?
Denmark has been self-sufficient with oil since 1993. In 2012, the degree of self-sufficiency was 148 per cent (155 per cent in 2011 and 168 per cent in 2010). Denmark’s period of self-sufficiency in oil can potentially be prolonged with additional production from technological developments and new hydrocarbon discoveries.
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Denmark 2.4
To what extent is Denmark’s oil production exported?
In 2011, Denmark exported a total of 5,310 tonnes to the following countries: Canada (284 tonnes); Finland (84 tonnes); France (451 tonnes); Germany (297 tonnes); Ireland (85 tonnes); the Netherlands (1,089 tonnes); Norway (2,566 tonnes); Russia (219 tonnes); the United Kingdom (62 tonnes); and the USA (173 tonnes).
3 Development of Oil and Natural Gas 3.1
Outline broadly the legal/statutory and organisational framework for the exploration and production (“development”) of oil and natural gas reserves including: principal legislation; in whom the State’s mineral rights to oil and natural gas are vested; Government authority or authorities responsible for the regulation of oil and natural gas development; and current major initiatives or policies of the Government (if any) in relation to oil and natural gas development.
The Subsoil Act (Consolidated Act No. 960 of 13 September 2011 on the Use of the Danish Subsoil) lays down the basic framework for oil and gas exploitation and production. The Subsoil Act regulates exploitation and recovery activities in the Danish subsoil and on the Danish Continental Shelf concerning raw materials (and specifically hydrocarbons). The Danish Subsoil Act does not apply to the Faroe Islands or Greenland. Under the Subsoil Act and Continental Shelf Act, all resources in the Danish subsoil belong to the Danish State, and all structures located on the continental shelf are governed by Danish law. This applies to installations located within the exclusive economic zone and the territorial sea. The utilisation of raw materials from the overlying layer (bottom, etc.) is not covered by the Subsoil Act, but regulated by the Mineral Resources Act. The exploitation of raw materials in the subsurface is primarily regulated by the Subsoil Act. The law covers the underground both at sea and on land. The Subsoil Act defines the conditions for the implementation of prospecting, exploration and production. The Subsoil Act also contains rules on supervision, case management, complaints procedure, etc. The Subsoil Act applies to prospecting, exploration and extraction of minerals in the subsoil (if the minerals have not been subject to private economic exploitation in Denmark before 3 February 1932), use of land for storage or purposes other than the extraction of raw materials and scientific studies of the subsurface. Permissions with exclusive rights (concessions) can be given only after approval from the Danish Parliamentary Energy Committee. Most of the powers of the Minister for Climate, Energy and Buildings pursuant to the Subsoil Act have been delegated to the DEA. The DEA is responsible for the entire chain of tasks linked to energy production and supply, transportation and consumption, including energy efficiency and savings, etc. The DEA is expected to launch the seventh licensing round for oil and gas exploration and production licences in the North Sea in late 2013 or early 2014. The licensing round will cover the areas to the west of 6°15’ east longitude. Other significant laws are: the Offshore Safety Act (520/2013); the Act on the Environmental Assessment of Plans and Programmes (939/2013);
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the Hydrocarbon Tax Act (971/2011); and the Act on Assessment and Collection (966/2011). A number of executive orders, regulations and guidelines have been issued under these Acts. 3.2
How are the State’s mineral rights to develop oil and natural gas reserves transferred to investors or companies (“participants”) (e.g. licence, concession, service contract, contractual rights under Production Sharing Agreement?) and what is the legal status of those rights or interests under domestic law?
The Danish State has a general right to all hydrocarbons in the subsoil of the Danish territorial jurisdiction area. The Danish State can grant licences to preliminary investigations, exploration and production of hydrocarbons. Licences are granted as part of open tender procedures or under the “open door” procedure. A licence may be subject to State participation. Concessions and licences are generally considered private property rights protected by law. 3.3
If different authorisations are issued in respect of different stages of development (e.g., exploration appraisal or production arrangements), please specify those authorisations and briefly summarise the most important (standard) terms (such as term/duration, scope of rights, expenditure obligations).
It follows from section 28 of the Subsoil Act that no works to be carried out in connection with activities covered by the Subsoil Act may be initiated until an approval has been obtained from the DEA. Preliminary Investigations The DEA may grant licences for a term of up to three years for performing specific types of preliminary investigations in order to explore for and produce raw materials, or to use the subsoil for storage or purposes other than the production of raw materials. A licence to preliminary investigations does not imply an exclusive right for the licensee. Nor does a licence imply that the licensee will have priority over other applicants for a subsequent licence to explore and produce hydrocarbons that might be found as part of the preliminary investigations. Exploration for and Production of Raw Materials The DEA may grant a licence conferring an exclusive right on the holder to explore for and to produce one or more raw materials within a defined area subject to specific terms and conditions or according to the “open door” procedure. Licences concerning the areas that A.P. Møller-Mærsk A/S has relinquished have been offered in open tender procedures, sometimes referred to as “rounds”, of which presently six rounds have taken place. Separate licences may be granted for exploration and production, respectively. An exploration licence may grant the licensee a preferential right to a production licence. An exploration licence may lay down provisions on a gradual reduction of the area comprised by the licence and may set out any work obligations to be met by the licensee. Licences shall only be granted to applicants who are deemed to have the necessary expertise and financial resources and who can be expected to carry out the activities in a manner so as to ensure that society gains maximum insight into and benefits from
the activities. The DEA may refuse to consider an application for a licence, if the exploration for or production of the relevant raw material is incompatible with other ongoing or planned use of the subsoil or with appropriate exploitation of the subsoil in other respects. A licence may be revoked (i) in case of non-compliance with the provisions of the Subsoil Act or with any terms and conditions or enforcement notices issued in pursuance of the Subsoil Act, (ii) where an application for a licence contains incorrect or misleading information, or (iii) where a licensee files a petition for suspension of payment or is declared bankrupt. 3.4
Denmark
the Act on the Establishment and Use of a Pipeline for Transport of Crude Oil and Condensate (957/2011);
Denmark
To what extent, if any, does the State have an ownership interest, or seek to participate, in the development of oil and natural gas reserves (whether as a matter of law or policy)?
Since 2005, State-owned Nordsøfonden has participated with a 20 per cent interest in all new licences in the Danish sector. In July 2012, Nordsøfonden similarly acquired a 20 per cent ownership interest in DUC. Nordsøfonden is a non-operating partner in DUC and in all new licences, which makes Nordsøfonden an important participant in the Danish Continental Shelf. The aim of Nordsøfonden is to create more value by putting existing knowledge to use across licences and supporting the development of new technologies to enhance recovery of the vast oil and gas resources remaining in the subsurface. 3.5
How does the State derive value from oil and natural gas development (e.g. royalty, share of production, taxes)?
The Hydrocarbon Tax Act includes specific taxation rules for undertakings with income from preliminary investigations, exploration and production of hydrocarbons on Danish soil. Under these rules, a statement of income from the production of hydrocarbon must be made. The hydrocarbon tax is levied on the basis of different statements of income depending on whether the licence was issued before or after 1 January 2004. For licences issued before 1 January 2004 the hydrocarbon tax amounts to 70 per cent of the taxable hydrocarbon income. A deficit in the hydrocarbon income cannot be deducted in any other income, and a deficit from other income cannot be deducted in the hydrocarbon income. The pipeline tax can be deducted. Income from the sole concession to A.P. Møller-Mærsk A/S and from licences issued on or after 1 January 2004 is taxed on the basis of the following rules: The hydrocarbon tax rate has been reduced to 52 per cent. The annual deduction for investments has been reduced to 5 per cent annually for a six-year period and is thus worth 30 per cent in total. A statement of all hydrocarbon income on Danish soil must be prepared. The pipeline tax can be deducted in the hydrocarbon tax, but can no longer be deducted in the income. 3.6
Are there any restrictions on the export of production?
The Minister for Climate, Energy and Buildings can decide that oil undertakings must submit information on terms of import, export, production, sale, storage and transport and on general company matters (Act No. 165 of 7 May 1975 on notification and sale duty concerning hydrocarbons).
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Are there any currency exchange restrictions, or restrictions on the transfer of funds derived from production out of the jurisdiction?
Denmark
No, there are none. 3.8
What restrictions (if any) apply to the transfer or disposal of oil and natural gas development rights or interests?
Licences may not be assigned to any other party, neither directly nor indirectly, unless the DEA allows such assignment and approves the pertinent terms and conditions. 3.9
Are participants obliged to provide any security or guarantees in relation to oil and natural gas development?
Licences are normally issued with conditions that the licence holders must provide security for or guarantee the licence holders’ commitments in connection with the licences. 3.10 Can rights to develop oil and natural gas reserves granted to a participant be pledged for security, or booked for accounting purposes under domestic law?
It follows from the Danish Subsoil Act that licences granted under the Act cannot be made subject to debt enforcement by creditors. Licences granted pursuant to the Natural Gas Supply Act are exempted from legal proceedings and may neither directly nor indirectly be transferred to other parties unless the authorities approve such transfer and the related terms. Rights to develop oil or natural gas may be booked for accounting purposes. 3.11 In addition to those rights/authorisations required to explore for and produce oil and natural gas, what other principal Government authorisations are required to develop oil and natural gas reserves (e.g. environmental, occupational health and safety) and from whom are these authorisations to be obtained?
The exploration and production of hydrocarbons are subject to various environmental regulations. The EIA Directive is implemented by the Subsoil Act. According to the Sea Environment Act, a licence to offshore projects that may have a significant impact on the environment may only be granted after an assessment of the project’s environmental consequences and when the involved authorities and organisations have been invited to give their comments. Projects regarding offshore plants and pipelines that are likely to have a significant impact in a special area of conservation shall be subject to an assessment of the projects’ implications for the area in the light of the conservation objectives regarding that area.
Denmark The Offshore Safety Act, the Convention on the Continental Shelf of 1958, the Sea Law Convention of 1982 and the Subsoil Act apply. 3.13 Is there any legislation or framework relating to gas storage? If so, what are the principle features/requirements of the legislation?
Gas storage is subject to regulation under the Danish Subsoil Act, the Natural Gas Supply Act and Executive Order No. 684 of 23 June 2011 on EIA, consequence assessment concerning international nature conservation areas and protection of certain species in connection with projects about offshore exploration for and production of hydrocarbons, storage in the subsoil, pipelines, etc. Obligations of a storage undertaking include placing the necessary storage capacity at the disposal of the transmission undertakings, measuring the supply of natural gas to and from the storage facility and providing the users with the necessary information. The storage undertaking is obliged to place storage capacity at the disposal of Energinet.dk, but only to the extent necessary to enable Energinet.dk to maintain a physical balance in the network and to ensure security of supply. Storage activities can only be carried out under licence. Licences can be granted to applicants who are considered to have the necessary expertise and financial background. Licences are granted for a minimum of 20 years and may be subject to conditions. A storage undertaking is to maintain, develop and extend the storage facility to the extent necessary. The storage undertaking must prepare plans for future natural gas supply and cooperate with the transmission undertaking and the distribution undertakings in planning the necessary measures to secure the natural gas supply in emergencies and other extraordinary situations. Any interested party has the right to use the storage facilities if technically and economically necessary to obtain access to the transmission or distribution systems. A storage undertaking may refuse access to the system if the storage undertaking lacks the necessary capacity, or if a natural gas undertaking has serious economic and financial difficulties in fulfilling contracts containing take-or-pay commitments or if the Rules for Gas Storage stipulate that access may be denied. Reasons must be given for any denial of access, and such denial can be brought before the DERA. The storage undertaking exchanges data with the transmission undertaking, distribution undertakings, etc., to ensure that transport and storing of natural gas can take place in a safe and efficient way within the entire system.
4 Import / Export of Natural Gas (including LNG) 4.1
Outline any regulatory requirements, or specific terms, limitations or rules applying in respect of cross-border sales or deliveries of natural gas (including LNG).
There are none. 3.12 Is there any legislation or framework relating to the abandonment or decommissioning of physical structures used in oil and natural gas development? If so, what are the principal features/requirements of the legislation?
5 Import / Export of Oil 5.1
Offshore installations must be dismantled in a responsible manner. There is an obligation to plan and carry out decommissioning, so that health and safety risks at work are identified, assessed and reduced as much as is practicable.
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Outline any regulatory requirements, or specific terms, limitations or rules applying in respect of cross-border sales or deliveries of oil and oil products.
There are none.
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6.1
Outline broadly the ownership, organisational and regulatory framework in relation to transportation pipelines and associated infrastructure (such as natural gas processing and storage facilities).
relevant landowner or by compulsory acquisition. Compulsory acquisition of real property must be in the interests of the public good. The compulsory acquisition must take place subject to the Procedure for the Compulsory Acquisition of Real Property. 6.4
How is access to oil and natural gas transportation pipelines and associated infrastructure organised?
Natural gas Natural gas produced in the North Sea is transported to Denmark in upstream pipelines to the gas treatment plant at Nybro. DONG owns and operates the pipelines and the gas treatment plant. The gas treatment plant is an entry point to the Danish natural gas transmission network.
See the answer to question 6.6 below. 6.5
To what degree are oil and natural gas transportation pipelines integrated or interconnected, and how is cooperation between different transportation systems established and regulated?
Upstream natural gas pipelines are regulated by the Danish Natural Gas Supply Act and Executive Order No. 1090 of 6 December 2000.
See the answer to question 1.1 above.
The establishment and operation of upstream pipelines require a licence issued by the DEA.
6.6
Any interested party is, in principle, entitled to access an upstream pipeline network against payment. Prices and terms are negotiated between the applicant and the owner or operator and supervised by the DERA. Oil DONG owns and operates a pipeline from the fields in the North Sea to the mainland. Certain hydrocarbon producing plants in the North Sea must be connected to the pipeline, and part of the oil produced in the North Sea must be transported through the pipeline. Pipeline users pay a fee to DONG. In order to fulfil Denmark’s international obligations, the Danish State can demand that oil undertakings keep stockpiles of oil or sell oil. The Danish emergency oil management system is generally handled by the Danish Central Stockholding Entity (“FDO”), which holds extensive stocks in the form of both ordinary emergency stocks and specific stocks on behalf of oil companies. The FDO has a board of six members elected annually by the member companies from the oil industry. The DEA participates in board meetings as an associated member. 6.2
What Governmental authorisations (including any applicable environmental authorisations) are required to construct and operate oil and natural gas transportation pipelines and associated infrastructure?
The DEA is the primary authority in regard to requiring permission to construct and operate oil and natural gas transportation pipelines and associated infrastructure. Also the municipalities must be involved, as the municipalities have the overall responsibility for the planning of heat supply. Heat supply plans must be taken into account when the city council decides on applications for approval of projects concerning the establishment of a collective heat supply system or the carrying out of a major change in existing systems. For major plants there may be a duty to complete an Environmental Impact Assessment under the rules of the Planning Act. 6.3
In general, how does an entity obtain the necessary land (or other) rights to construct oil and natural gas transportation pipelines or associated infrastructure? Do Government authorities have any powers of compulsory acquisition to facilitate land access?
Denmark
6 Transportation
Denmark
Outline any third-party access regime/rights in respect of oil and natural gas transportation and associated infrastructure. For example, can the regulator or a new customer wishing to transport oil or natural gas compel or require the operator/owner of an oil or natural gas transportation pipeline or associated infrastructure to grant capacity or expand its facilities in order to accommodate the new customer? If so, how are the costs (including costs of interconnection, capacity reservation or facility expansions) allocated?
Natural gas The DEA may issue rules on access to an upstream pipeline network, including to facilities providing technical services in connection with such access. The current rules are laid down in Executive Order No. 1090 of 6 December 2000, which entered into force on 1 January 2001. Any interested party is entitled to use the natural gas upstream pipeline network against payment. After the initial request for access, negotiations between the applicant and the owner or operator of the upstream pipeline network shall be commenced and concluded within reasonable time. The owner or operator shall notify the DEA when a request for access is received. Access may be denied only if (i) the technical specifications are incompatible, (ii) necessary in order to avoid interference with an efficient production, or (iii) necessary in order to respect duly substantiated needs of the owner, operator or a third party regarding transportation or processing of natural gas. It is a condition for denial of access that such obstacles cannot be easily overcome. A denial of access must be given within 14 days after the request is received. The owner or operator must state the grounds for a denial of access. The DEA may order the owner or operator to deny access, or to make it conditional, in the exceptional cases where access would either (i) imperil the regular and safe supply of natural gas to the Danish market, (ii) be contrary to the regulation of exploration and production of hydrocarbons or the general development of upstream facilities, or (iii) imperil the environment. The DERA shall take market practice into account when stipulating prices and terms. Decisions by the DERA can be appealed to the Energy Board of Appeal. Oil Oil is regulated by the Pipeline Act.
Land rights to construct oil and natural gas transportation pipelines or associated infrastructure may be obtained by agreement with the
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Are parties free to agree the terms upon which oil or natural gas is to be transported or are the terms (including costs/tariffs which may be charged) regulated?
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See the answer to question 6.6 above.
7 Gas Transmission / Distribution 7.1
Outline broadly the ownership, organisational and regulatory framework in relation to the natural gas transmission/distribution network.
The Danish transmission network is connected to the natural gas transmission networks in Germany and Sweden. The transmission network is connected to the distribution network, which the customers are connected to and are being supplied from. A few major customers are being supplied directly from the transmission network. The activities of Energinet.dk do not require a licence, as special provisions apply to Energinet.dk. It follows from the Natural Gas Supply Act that transmission, distribution, storage and LNG activities may only be carried out under licences granted to companies considered to have the necessary technical and financial resources. It also follows from the Natural Gas Supply Act that transmission, distribution, storage and LNG companies must maintain, convert and expand the natural gas supply network, storage and LNG facilities in the supply area to the extent necessary. The transmission and distribution companies shall ensure sufficient and effective transport of natural gas and associated services in their own networks, including (i) maintenance of the physical balance in the network, (ii) making necessary transport capacity available, (iii) ensuring metering of delivery and purchase of natural gas in the network, and (iv) providing users of the network with all necessary information on metering of the natural gas transported through the network. Transmission and distribution companies must set up a programme for internal monitoring which describes their initiatives to prevent discriminating behaviour. An annual report describing the programme and its supervision must be published and submitted to the DERA. Transmission company A transmission company shall (i) connect the distribution network and consumers to the extent necessary, (ii) ensure the quality of the natural gas supplied from the transmission network, (iii) ensure supply security in Denmark, (iv) co-operate with other transmission companies in Denmark and in other countries with a view to achieving efficient exchange of natural gas, (v) prepare plans for the future demand for transmission capacity, (vi) ensure that there are sufficient quantities of natural gas in the overall natural gas system so that the physical balance in the network can be maintained, and (vii) use transparent, non-discriminatory, market-based methods in the procurement of the energy use to carry out its activity. Distribution company A distribution company shall (i) connect consumers to the distribution network to the extent necessary, and (ii) advise consumers on energy saving. Storage company A storage company shall (i) meter deliveries of natural gas to and from storage, (ii) provide users of a storage facility with all necessary information on the metering of the natural gas conveyed to and withdrawn from the storage facility, and (iii) make necessary storage capacity available for transmission companies’ performance of the task.
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What Governmental authorisations (including any applicable environmental authorisations) are required to operate a distribution network?
Distribution of natural gas activities can only be carried out under licence. A licence can be granted to undertakings that have the necessary technical expertise and financial resources. The licence is granted for a particular geographic area and for a period of minimum 20 years. After five years, the terms of the licence may be amended with one year’s notice. The licensee must own the facilities used for the activities covered by the licence. A distribution undertaking has a duty to supervise, operate and maintain the distribution network, manage the change of suppliers for customers, invoice customers for the use of the distribution network and continuously record the sale of gas to customers. The distribution undertaking exchanges data with the transmission undertaking, other distribution undertakings, etc., to ensure that transport and storing of natural gas can take place in a safe and effective way within the entire system. 7.3
How is access to the natural gas distribution network organised?
System access to the natural gas transmission and distribution networks and LNG facilities are regulated primarily by the Natural Gas Supply Act. Any person has the right, in return for payment, to use the transmission and distribution networks and LNG facilities if this is technically and financially necessary in order to provide efficient system access, storage, line pack and other ancillary services (the system). Transmission, distribution and LNG companies may be denied access to the system (i) if they do not have the necessary capacity, (ii) if access to the system would prevent them from fulfilling the obligations imposed on them pursuant to the Natural Gas Supply Act, or (iii) due to serious financial and economic difficulties with contracts containing take-or-pay terms. If access is denied due to lack of capacity, the denying company must soon thereafter apply for permission to expand the capacity, if such expansion is profitable or if the applicant is willing to pay for the expansion. Applications for use of the system are made to the transmission, distribution, storage or LNG company operating the network, storage facility or LNG facilities the use of which is being requested. Companies shall provide access to the system on the basis of objective, transparent and non-discriminatory criteria. The Energy Regulatory Authority handles complaints concerning the denial of application for access to the system. 7.4
Can the regulator require a distributor to grant capacity or expand its system in order to accommodate new customers?
See the answer to question 7.3 above. 7.5
What fees are charged for accessing the distribution network, and are these fees regulated?
The transmission, distribution or LNG company sets the prices and terms of use of the transmission and distribution network and LNG facilities. The companies must provide access to the system on the basis of objective, transparent and non-discriminatory criteria. The prices
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Transmission, distribution and LNG companies shall publish tariffs and terms of use of the transmission and distribution networks and LNG facilities. Disputes may be submitted to the DERA for resolution. 7.6
Are there any restrictions or limitations in relation to acquiring an interest in a gas utility, or the transfer of assets forming part of the distribution network (whether directly or indirectly)?
A distribution network owned by a licensee, or shares in companies which own distribution networks, can only be transferred to the Danish State. The Danish State has a duty to buy. The Danish State must exercise its duty to buy within three months after the date on which the Danish State was notified of the owner’s wish to dispose of the distribution network or the shares. If the parties cannot reach an agreement on the conditions of the transfer, the price and terms of the transfer will be fixed by a valuation commission in accordance with the procedure that applies to compulsory sale to the Danish State.
8 Natural Gas Trading 8.1
Outline broadly the ownership, organisational and regulatory framework in relation to natural gas trading. Please include details of current major initiatives or policies of the Government or regulator (if any) relating to natural gas trading.
Any person may freely choose a natural gas supplier. Companies required to hold a licence must make their services available to consumers at objective, transparent and non-discriminatory terms. The wholesale market operates largely on the basis of take-and-pay contracts between the participating companies. The contracts are typically signed for a period of 15-25 years. Denmark is covered by the gas exchange Gaspoint Nordic. As of 17 December 2012, Gaspoint Nordic became 100 per cent owned by Energinet.dk. Up until July 2013 the company’s name was Nord Pool Gas. Gaspoint Nordic provides a market place to producers, retailers, energy companies, trading representatives and major consumers at which they can buy or sell natural gas. Trading at Gaspoint Nordic is based on continuous trading and is performed electronically through an internet-based trading system. This enables the market players to monitor market developments, place their own bids and orders and receive the latest market information in real time – hence contributing to the continuous development and a dynamic gas market. 8.2
What range of natural gas commodities can be traded? For example, can only “bundled” products (i.e., the natural gas commodity and the distribution thereof) be traded?
There are no restrictions.
9 Liquefied Natural Gas 9.1
Outline broadly the ownership, organisational and regulatory framework in relation to LNG facilities.
LNG is regulated by the Natural Gas Supply Act. LNG facilities may only be established after the DEA has issued the relevant permits. A permit may only be issued if the applicant is able to document that there is sufficient need for the facility in question. The permit may be conditional on compliance with terms concerning the specific establishment and operation of LNG facilities, including the safety provisions for removal. 9.2
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shall be set according to reasonable, objective and nondiscriminatory criteria relative to the costs associated with the individual users of the network and the consumers.
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What Governmental authorisations are required to construct and operate LNG facilities?
See the answer to question 9.1 above. 9.3
Is there any regulation of the price or terms of service in the LNG sector?
Executive Order No. 1277/2007 lays down rules for the review of prices and conditions for transport, supply and storage of natural gas as well as terms and conditions for access to transmission and distribution networks and LNG facilities, including tariffs. Transmission, distribution and storage of LNG and supply companies must submit to the DERA, inter alia, methods of calculation or determination of terms or conditions for access to the transmission or distribution networks and LNG facilities, including tariffs for the coming year, rates, tariffs and terms for services covered by licence, and the basis for fixing these, including supply agreements. 9.4
Outline any third-party access regime/rights in respect of LNG Facilities.
See the answer to question 7.3 above.
10
Downstream Oil
10.1 Outline broadly the regulatory framework in relation to the downstream oil sector.
The downstream oil sector covers the refining of crude oil as well as the distribution of products derived from crude oil. The process is regulated by the Environmental Protection Act, the Water Supply Act, the Petrol Distributions Act, the Oil Emergency Act and the Competition Act. 10.2 Outline broadly the ownership, organisation and regulatory framework in relation to oil trading.
Denmark has one crude oil pipeline connecting some of the offshore production to the refinery and export terminal, both located in Fredericia. The pipeline is owned and operated by DONG Pipe A/S. A product pipeline system, NEPS (Northern European Pipeline System) extends from Germany to North Jutland and is owned and operated by the Danish military forces.
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Bruun & Hjejle Consolidation in the Danish oil industry has continued over the past decade, with many smaller companies being purchased by larger companies. Approximately 90 per cent of the downstream oil industry is represented by five companies: Statoil Fuel & Retail A/S; A/S Dansk Shell; Kuwait Petroleum (Q8 Denmark); OK a.m.b.a.; and the Uno-X group.
11
Competition
11.1 Which Governmental authority or authorities are responsible for the regulation of competition aspects, or anti-competitive practices, in the oil and natural gas sector?
The DERA is an independent board that supervises prices and terms of delivery of energy licence-committed undertakings. The aim of the DERA is to ensure an efficient and transparent energy market in Denmark. The Minister for Climate, Energy and Buildings appoints the members of the DERA. The board consists of a chairman, six members and two substitutes who are all appointed for a four-year period. The members must represent expert knowledge within law, technology, environment, business and consumer matters. A secretariat in the Danish Competition Authority assists the DERA. Transmission, storage and distribution undertakings and supplycommitted undertakings are under the supervision of the DERA. The Energy Board of Appeal is the final administrative appeal body for decisions by public authorities, such as the DERA, the DEA or one of Denmark’s 98 municipalities. Decisions by the Energy Board of Appeal cannot be brought before any other administrative body. Decisions by the Energy Board of Appeal can be brought before the courts.
Natural Gas Supply Act, gain access to a company’s premises, where the DERA may review and make copies of any information, including accounts, accounting materials, books, other commercial documents and electronically stored data. The DERA takes any necessary steps in order to ensure transparency relative to prices, tariffs, discounts and terms. The DERA lays down rules on the manner in which companies make such information public, as well as rules on invoicing and on specification of costs to the receivers of transport and energy services. 11.4 Does the regulator (or any other Government authority) have the power to approve/disapprove mergers or other changes in control over businesses in the oil and natural gas sector, or proposed acquisitions of development assets, transportation or associated infrastructure or distribution assets? If so, what criteria and procedures are applied? How long does it typically take to obtain a decision approving or disapproving the transaction?
The Danish Competition and Consumer Authority enforce the Danish Competition Act and are responsible for providing merger control. Mergers, etc., may be subject to approval from the Authority.
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Foreign Investment and International Obligations
12.1 Are there any special requirements or limitations on acquisitions of interests in the natural gas sector (whether development, transportation or associated infrastructure, distribution or other) by foreign companies?
The Danish Competition and Consumer Authority enforce the Danish Competition Act and endorse major business mergers and instruct companies to revoke agreements that restrict competition. The Danish Competition and Consumer Authority acts as secretariat for the Energy Board of Appeal.
There are no special requirements or limitations.
11.2 To what criteria does the regulator have regard in determining whether conduct is anti-competitive?
Danish energy legislation is under strong influence from EU law.
The DERA may regulate prices and terms of delivery of licencecommitted undertakings, including the terms of access to transmission and distribution networks. Further, the Authority supervises revenue framework regulation, including efficiency demands. The Authority supervises access to storage facilities. Under rules laid down by the Minister for Climate, Energy and Buildings, the DERA supervises activities carried out by Energinet.dk. The DERA may open a case of its own initiative or after receiving a complaint. The DERA may hear cases about prices and conditions in the electricity, gas and heat supply sectors. 11.3 What power or authority does the regulator have to preclude or take action in relation to anti-competitive practices?
If the DERA finds that prices and terms contravene the provisions in the Natural Gas Supply Act, the DERA may order prices and terms to be modified. Without a court order and at any time upon appropriate proof of identity, the DERA may, for supervisory purposes pursuant to the
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12.2 To what extent is regulatory policy in respect of the oil and natural gas sector influenced or affected by international treaties or other multinational arrangements?
13
Dispute Resolution
13.1 Provide a brief overview of compulsory dispute resolution procedures (statutory or otherwise) applying to the oil and natural gas sector (if any), including procedures applying in the context of disputes between the applicable Government authority/regulator and: participants in relation to oil and natural gas development; transportation pipeline and associated infrastructure owners or users in relation to the transportation, processing or storage of natural gas; downstream oil infrastructure owners or users; and distribution network owners or users in relation to the distribution/transmission of natural gas.
See the answer to question 11.1 above. There are a number of provisions on complaints and dispute resolution. The DERA may open a case on its own initiative or after receiving a complaint. The DERA may hear cases about prices and conditions in the electricity, gas and heat supply sectors. The DERA may hear complaints from consumers regarding certain information to be included in consumer contracts, etc., or regarding prices, discounts and other general terms being made publicly available from such
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Decisions by the Energy Board of Appeal cannot be brought before any other administrative body. Decisions by the Energy Board of Appeal can be brought before the courts. 13.2 Is Denmark a signatory to, and has it duly ratified into domestic legislation: the New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards; and/or the Convention on the Settlement of Investment Disputes between States and Nationals of Other States (“ICSID”)?
Denmark has ratified the New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards and the Convention on the Settlement of Investment Disputes between States and Nationals of Other States. 13.3 Is there any special difficulty (whether as a matter of law or practice) in litigating, or seeking to enforce judgments or awards, against Government authorities or State organs (including any immunity)?
No, there is not.
13.4 Have there been instances in the oil and natural gas sector when foreign corporations have successfully obtained judgments or awards against Government authorities or State organs pursuant to litigation before domestic courts?
There have been a number of cases, especially relating to taxation, where foreign corporations have successfully obtained judgments against the Danish authorities.
14
Updates
14.1 Please provide, in no more than 300 words, a summary of any new cases, trends and developments in Oil and Gas Regulation Law in Denmark.
On 7 October 2013, the Danish Energy Board of Appeal confirmed a decision from the DERA on transport tariffs for natural gas fields in the Danish upstream system in the North Sea to the natural gas processing plant in Nybro off the West coast of Jutland. The DERA had ordered DONG Naturgas A/S to lower its transport tariffs from 0.1 DKK pr. cubic metre to a range of approximately 0.05 – 0.07 DKK pr. cubic metre in the period between July 2011 to October 2012.
Nicolaj Kleist
Morten Ruben Brage
Bruun & Hjejle Nørregade 21 1165 Copenhagen K Denmark
Bruun & Hjejle Nørregade 21 1165 Copenhagen K Denmark
Tel: Fax: Email: URL:
Tel: Fax: Email: URL:
+45 33 34 52 97 / +45 30 18 87 97 +45 33 34 50 50
[email protected] www.bruunhjejle.com
Nicolaj Kleist is partner at Bruun & Hjejle and has extensive experience in advising on regulatory matters and public law issues, especially within the energy sectors where he advises energy and supply utilities within oil, gas, electricity and heating. He regularly assists in disputes before public authorities and complaints boards and has assisted on a number of high-profile cases regarding capital and price issues. Recent accomplishments include assisting in a dispute regarding pricing of upstream natural gas transportation, advising in an acquisition creating Denmark’s fourth-largest power company, and negotiating major gas purchase agreements.
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undertakings. Decisions of the DERA can be appealed to the Energy Board of Appeal.
+45 33 34 52 42 / +45 30 18 87 42 +45 33 34 50 50
[email protected] www.bruunhjejle.com
Morten Ruben Brage works with regulatory matters, particularly the regulation and use of real estate, including issues related to public and energy law. He is an external lecturer in environmental law at the University of Copenhagen and co-editor of the Danish legal publication on environmental decisions and judgments Miljøretlige Afgørelser og Domme (“MAD”).
Bruun & Hjejle is a leading Danish law firm for complex transactions and disputes partnering with leading clients. Our strategic focus is on M&A, Banking & Finance, Real Estate and Construction, Dispute resolution and Regulatory. We have a leading energy practice with years of experience representing Government, municipal and privately owned energy and utilities companies. Bruun & Hjejle’s multi-specialist approach allow Bruun & Hjejle to identify and advise on regulatory trends and developments across regulated businesses and to combine our public and administrative law knowledge with industry insight and commercial understanding. Bruun & Hjejle are equipped to assist our clients in developing comprehensive strategies and solutions for doing business in any environment of complex regulation. Bruun & Hjejle are often instructed in groundbreaking cases where we leverage our broad knowledge in law and deep understanding of the political processes, rule-making and public authority decision-making.
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