SUBMISSION COVER SHEET

IMPORTANT: Check box if Confidential Treatment is requested 

Registered Entity Identifier Code (optional): 22-105 (1 of 3)

Organization: New York Mercantile Exchange, Inc. ("NYMEX")

Filing as a: DCM SEF DCO SDR 

Please note - only ONE choice allowed.

Filing Date (mm/dd/yy): 07/14/22 Filing Description: Initial Listing of Three (3) Dutch 

TTF Natural Gas Futures and Option Contracts

SPECIFY FILING TYPE 

Please note only ONE choice allowed per Submission.

Organization Rules and Rule Amendments

Certification § 40.6(a)

Approval § 40.5(a)

Notification § 40.6(d)

Advance Notice of SIDCO Rule Change § 40.10(a)

SIDCO Emergency Rule Change § 40.10(h)

Rule Numbers: 

New Product Please note only ONE product per Submission.

Certification § 40.2(a) 

Certification Security Futures § 41.23(a)

Certification Swap Class § 40.2(d)

Approval § 40.3(a)

Approval Security Futures § 41.23(b)

Novel Derivative Product Notification § 40.12(a)

Swap Submission § 39.5

Product Terms and Conditions (product related Rules and Rule Amendments)

Certification § 40.6(a) 

Certification Made Available to Trade Determination § 40.6(a)

Certification Security Futures § 41.24(a)

Delisting (No Open Interest) § 40.6(a) 

Approval § 40.5(a)

Approval Made Available to Trade Determination § 40.5(a)

Approval Security Futures § 41.24(c)

Approval Amendments to enumerated agricultural products § 40.4(a), § 40.5(a)

“Non-Material Agricultural Rule Change” § 40.4(b)(5)

Notification § 40.6(d)

Official Name(s) of Product(s) Affected: See filing.

Rule Numbers: See filing.
300 Vesey Street New York, NY 10282 T 212 299 2200 F 212 301 4645 christopher.bowen@cmegroup.com cmegroup.com

1

Christopher Bowen 

Managing Director and Chief Regulatory Counsel

Legal Department

July 14, 2022

VIA ELECTRONIC PORTAL

Mr. Christopher J. Kirkpatrick

Office of the Secretariat

Commodity Future Trading Commission

Three Lafayette Centre

1155 21st Street, N.W.

Washington, DC 20581

Re: CFTC Regulation 40.2(a) Certification. Initial Listing of Three (3) Dutch TTF Natural 

Gas Futures and Option Contracts.

NYMEX Submission No. 22-190 (1 of 3)

Dear Mr. Kirkpatrick:

New York Mercantile Exchange, Inc. (“NYMEX” or “Exchange”) is certifying to the Commodity Futures 

Trading Commission (“CFTC” or “Commission”) the initial listing of the Dutch TTF Natural Gas 

(USD/MMBTU) Futures, Dutch TTF Natural Gas (USD/MMBTU) Average Price Option, and Dutch TTF 

Natural Gas (USD/MMBTU) Futures-Style Margined Average Price Option contracts (the “Contracts”) for 

trading on the CME Globex electronic trading platform (“CME Globex”) and for submission for clearing via 

CME ClearPort effective Sunday, August 7, 2022 for trade date Monday, August 8, 2022.

Contract Title Dutch TTF Natural Gas (USD/MMBTU) Futures

CME Globex/CME ClearPort Code TFU

Rulebook Chapter 1017

Settlement Type Financial

Contract Size 10,000 MMBTu

Listing Schedule

Monthly contracts listed for the current year and the next 5 calendar years. 

List monthly contracts for a new calendar year following the termination of 

trading in the December contract of the current year.

Pricing Quotation U.S. dollars and cents per MMBTu

First Listed Month September 2022

Minimum Price Fluctuation $0.001 per MMBTu

Value per tick $10

Block Trade Minimum Threshold 5 contracts – subject to a minimum 15-minute reporting window

Termination of Trading

Trading terminates at 17:00 London time on the second last London business 

day of the month prior to the contract month. If this is not a U.S. business day, 

trading terminates on the prior U.S. and London business day.

CME Globex Matching Algorithm First in First Out (FIFO)

Contract Title Dutch TTF Natural Gas (USD/MMBTU) Average Price Option

CME Globex/CME ClearPort Code TFP

Rulebook Chapter 1018

Settlement Type Financial

Contract Size 10,000 MMBTu

Listing Schedule

Monthly contracts listed for the current year and the next 5 calendar years. 

List monthly contracts for a new calendar year following the termination of 

trading in the December contract of the current year.

Pricing Quotation U.S. dollars and cents per MMBTu
300 Vesey Street New York, NY 10282 T 212 299 2200 F 212 301 4645 christopher.bowen@cmegroup.com cmegroup.com

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First Listed Month September 2022

Minimum Price Fluctuation $0.001 per MMBTu

Value per tick $10

Block Trade Minimum Threshold 5 contracts – subject to a minimum 15-minute reporting window

Termination of Trading

Trading terminates at 17:00 London time on the second last London business 

day of the month prior to the contract month. If this is not a U.S. business day, 

trading terminates on the prior U.S. and London business day.

CME Globex Matching Algorithm First in First Out (FIFO)

Underlying Futures Contract Title / 

Commodity Code

Dutch TTF Natural Gas (USD/MMBTU) Futures / TFU

Strike Price Increment $0.500 per MMBTu

Strike Price Listing Rule At-the-money strikes for the nearest 12 months then dynamic thereafter

Option Type European Style

Margining Style Equity Style

Contract Title Dutch TTF Natural Gas (USD/MMBTU) Futures-Style Margined Average 

Price Option

CME Globex/CME ClearPort Code TFF

Rulebook Chapter 1019

Settlement Type Financial

Contract Size 10,000 MMBTu

Listing Schedule

Monthly contracts listed for the current year and the next 5 calendar years. 

List monthly contracts for a new calendar year following the termination of 

trading in the December contract of the current year.

Pricing Quotation U.S. dollars and cents per MMBTu

First Listed Month September 2022

Minimum Price Fluctuation $0.001 per MMBTu

Value per tick $10

Block Trade Minimum Threshold 5 contracts – subject to a minimum 15-minute reporting window

Termination of Trading

Trading terminates at 17:00 London time on the second last London business 

day of the month prior to the contract month. If this is not a U.S. business day, 

trading terminates on the prior U.S. and London business day.

CME Globex Matching Algorithm First in First Out (FIFO)

Underlying Futures Contract Title / 

Commodity Code

Dutch TTF Natural Gas (USD/MMBTU) Futures / TFU

Strike Price Increment $0.500 per MMBTu

Strike Price Listing Rule At-the-money strikes for the nearest 12 months then dynamic thereafter

Option Type European Style

Margining Style Futures-Style

Trading and Clearing Hours

CME Globex Pre-Open Sunday 4:00 p.m. - 5:00 p.m. Central Time/CT Monday - Thursday 4:45 p.m. - 5:00 p.m. CT 

CME Globex Sunday - Friday 5:00 p.m. CT with a daily maintenance period from 4:00 p.m. - 5:00 p.m. CT 

CME ClearPort Sunday - Friday 5:00 p.m. - 4:00 p.m. CT with no reporting Monday - Thursday from 4:00 

p.m. - 5:00 p.m. CT

NYMEX is certifying block trading on the Contracts with a minimum block threshold of five (5) contracts

which is commensurate with the Exchange’s other similar products.

The Exchange reviewed the designated contract market core principles (“Core Principles”) as set forth in 

the Commodity Exchange Act (“CEA” or the “Act”)) and identified that the Contracts may have some bearing 

on the following Core Principles:
300 Vesey Street New York, NY 10282 T 212 299 2200 F 212 301 4645 christopher.bowen@cmegroup.com cmegroup.com

3

• Compliance with Rules: Trading in the Contracts will be subject to the rules in Rulebook Chapter 

4 which includes prohibitions against fraudulent, noncompetitive, unfair and abusive practices. 

Additionally, trading in these Contracts will also be subject to the full range of trade practice rules, 

the majority of which are contained in Chapter 5 and Chapter 8 of the Rulebook. As with all products 

listed for trading on one of CME Group’s designated contract markets, activity in these products

will be subject to extensive monitoring and surveillance by CME Group’s Market Regulation 

Department. The Market Regulation Department has the authority to exercise its investigatory and 

enforcement power where potential rule violations are identified.

• Contracts Not Readily Subject to Manipulation: The Contracts are not readily subject to

manipulation due to the deep liquidity and robustness in the underlying cash market.

• Prevention of Market Disruption: Trading in the Contracts will be subject to Rules of NYMEX, 

which include prohibitions on manipulation, price distortion and disruption to the delivery process. 

As with any new products listed for trading on a CME Group designated contract market, trading 

activity in the Contracts proposed herein will be subject to monitoring and surveillance by CME 

Group’s Market Regulation Department.

• Position Limitations or Accountability: The speculative position limits for the Contracts as 

demonstrated in this submission are consistent with the Commission’s guidance.

• Availability of General Information: The Exchange will publish on its website information 

regarding the Contract’s specifications, terms, and conditions, as well as daily trading volume, open 

interest, and price information.

• Daily Publication of Trading Information: The Exchange will publish the Contracts’ trading 

volumes, open interest levels, and price information daily on its website and through quote vendors 

for the Contracts.

• Execution of Transactions: The Contracts will be listed for trading on the CME Globex electronic 

trading and for clearing through the CME ClearPort. The CME Globex trading venue provides for 

competitive and open execution of transactions. CME Globex affords the benefits of reliability and 

global connectivity.

• Trade Information: All requisite trade information for the Contracts will be included in the audit trail 

and is sufficient for the Market Regulation Department to monitor for market abuse.

• Financial Integrity of Contract: The Contracts will be cleared by the CME Clearing House, a 

derivatives clearing organization registered with the CFTC and subject to all CFTC regulations 

related thereto.

• Protection of Market Participants: NYMEX Rulebook Chapters 4 and 5 set forth multiple 

prohibitions that preclude intermediaries from disadvantaging their customers. These rules apply 

to trading in all of the Exchange’s competitive trading venues and will be applicable to transaction 

in the Contracts.

• Disciplinary Procedures: Chapter 4 of the Rulebook contains provisions that allow the Exchange 

to discipline, suspend or expel members or market participants that violate the Rulebook. Trading 

in the contracts will be subject to Chapter 4, and the Market Regulation Department has the 

authority to exercise its enforcement power in the event rule violations in the product are identified.

• Dispute Resolution: Disputes with respect to trading in the Contracts will be subject to the 

arbitration provisions set forth in Chapter 6 of the Rulebook. Chapter 6 allows all non-members to 

submit a claim for financial losses resulting from transactions on the Exchange to arbitration. A 
300 Vesey Street New York, NY 10282 T 212 299 2200 F 212 301 4645 christopher.bowen@cmegroup.com cmegroup.com

4

member named as a respondent in a claim submitted by a nonmember is required to participate in 

the arbitration pursuant to Chapter 6. Additionally, the Exchange requires that members resolve 

all disputes concerning transactions on the Exchange via arbitration.

Pursuant to Section 5c(c) of the Act and CFTC Regulation 40.2(a), the Exchange hereby certifies that listing 

the Contracts complies with the Act, including regulations under the Act. There were no substantive 

opposing views to listing of the Contracts. 

The Exchange certifies that this submission has been concurrently posted on the Exchange’s website at 

http://www.cmegroup.com/market-regulation/rule-filings.html. 

Should you have any questions concerning the above, please contact the undersigned at (212) 299-2200 

or e-mail CMEGSubmissionInquiry@cmegroup.com.

Sincerely,

/s/Christopher Bowen

Managing Director and Chief Regulatory Counsel

Attachments: Exhibit A: NYMEX Rulebook Chapters 1017, 1018, 1019

Exhibit B: Position Limit, Position Accountability, and Reportable Level Table in 

 Chapter 5 of the NYMEX Rulebook (attached under separate cover)

Exhibit C: NYMEX Rule 588.H. – (“Globex Non-Reviewable Trading Ranges”) Table

Exhibit D: Exchange Fees

Exhibit E: Cash Market Overview and Analysis of Deliverable Supply
5

EXHIBIT A

NYMEX Rulebook

Chapter 1017

Dutch TTF Natural Gas (USD/MMBTU) Futures

1017100. SCOPE OF CHAPTER

The provisions of these rules shall apply to all futures contracts bought or sold on the Exchange for 

cash settlement based on the Floating Price. The procedures for trading, clearing and cash 

settlement of this contract, and any other matters not specifically covered herein shall be governed 

by the general rules of the Exchange.

1017101. CONTRACT SPECIFICATIONS

The Floating Price for each contract month is equal to ICE Dutch TTF Gas 1st Line Financial Futures 

(USD/MMBTU) final settlement price for the corresponding contract month on the last trading day for 

that contract month.

1017102. TRADING SPECIFICATIONS

Contracts shall be listed for a range of calendar months. The number of months open for trading at 

a given time shall be determined by the Exchange. 

1017102.A. Trading Schedule 

The hours of trading for this contract shall be determined by the Exchange. 

1017102.B. Trading Unit 

The contract quantity shall be 10,000 MMBtu. Each contract shall be valued as the contract quantity 

(10,000) multiplied by the settlement price.

1017102.C. Price Increments 

Prices shall be quoted in U.S. dollars and cents per MMBtu. The minimum price fluctuation shall be 

$0.001 per MMBtu. 

1017102.D. Position Limits, Exemptions, Position Accountability and Reportable Levels 

The applicable position limits and/or accountability levels, in addition to the reportable levels, are set 

forth in the Position Limit, Position Accountability and Reportable Level Table in the Interpretations 

& Special Notices Section of Chapter 5. A Person seeking an exemption from position limits for 

bona fide commercial purposes shall apply to the Market Regulation Department on forms provided 

by the Exchange, and the Market Regulation Department may grant qualified exemptions in its sole 

discretion. Refer to Rule 559 for requirements concerning the aggregation of positions and allowable 

exemptions from the specified position limits. 

1017102.E. Termination of Trading

The contract shall terminate at 17:00 London time on the second last London business day of the 

month prior to the contract month. If this is not a U.S. business day, trading terminates on the prior 

U.S. and London business day.

1017103. FINAL SETTLEMENT

Final settlement under the contract shall be by cash settlement. Final settlement, following 

termination of trading for a contract month, will be based on the Floating Price. The final settlement 

price will be the Floating Price calculated for each contract month.
6

Chapter 1018

Dutch TTF Natural Gas (USD/MMBTU) Average Price Option

1018100. SCOPE OF CHAPTER

This chapter is limited in application to put and call Dutch TTF Natural Gas (USD/MMBTU) Average 

Price Options on the Dutch TTF Natural Gas (USD/MMBTU) Futures contract. In addition to the rules 

of this chapter, transactions in Dutch TTF Natural Gas (USD/MMBTU) Average Price Option shall be 

subject to the general rules of the Exchange.

1018101. OPTION CHARACTERISTICS

The number of months open for trading at a given time shall be determined by the Exchange. 

1018101.A. Trading Schedule

The hours of trading shall be determined by the Exchange.

1018101.B. Trading Unit

Dutch TTF Natural Gas (USD/MMBTU) Average Price Call Option traded on the Exchange 

represents differential between the Floating Price and the strike price, multiplied by the contract 

quantity, or zero, whichever is greater. A Dutch TTF Natural Gas (USD/MMBTU) Average Price Put 

Option traded on the Exchange represents the differential between the strike price and the Floating 

Price, multiplied by the contract quality, or zero, whichever is greater. 

1018102.C. Price Increments 

Prices shall be quoted in U.S. dollars and cents per MMBtu. The minimum price fluctuation shall be 

$0.001 per MMBtu.

1018101.D. Position Limits, Exemptions, Position Accountability and Reportable Levels

Position Limits, Exemptions, Position Accountability and Reportable Levels The applicable position 

limits and/or accountability levels, in addition to the reportable level s, are set forth in the Position 

Limit, Position Accountability and Reportable Level Table in the Interpretations & Special Notices 

Section of Chapter 5. A Person seeking an exemption from position limits for bona fide commercial 

purposes shall apply to the Market Regulation Department on forms provided by the Exchange, and 

the Market Regulation Department may grant qualified exemptions in its sole discretion. Refer to 

Rule 559 for requirements concerning the aggregation of positions and allowable exemptions from 

the specified position limits.

1018102.E. Termination of Trading

Trading terminates at 17:00 London time on the second last London business day of the month prior 

to the contract month. If this is not a U.S. business day, trading terminates on the prior U.S. and 

London business day.

1018102.F. Type of Option 

The option is a European-style option cash settled on expiration day.

1018102. EXERCISE PRICES

Transactions shall be conducted for option contracts as set forth in Rule 300.20.
7

Chapter 1019

Dutch TTF Natural Gas (USD/MMBTU) Futures-Style Margined Average Price 

Option

1019100. SCOPE OF CHAPTER

This chapter is limited in in application to put and call Dutch TTF Natural Gas (USD/MMBTU) FuturesStyle Margined Average Price Options on the Dutch TTF Natural Gas (USD/MMBTU) Futures 

contract. In addition to the rules of this chapter, transactions in Dutch TTF Natural Gas 

(USD/MMBTU) Futures-Style Margined Average Price Options shall be subject to the general rules 

of the Exchange.

1019101. OPTION CHARACTERISTICS

The number of months open for trading at a given time shall be determined by the Exchange. 

1019101.A. Trading Schedule

The hours of trading shall be determined by the Exchange.

1019101.B. Trading Unit

Dutch TTF Natural Gas (USD/MMBTU) Futures-Style Margined Average Price Call Option traded on 

the Exchange represents differential between the Floating Price and the strike price, multiplied by 

the contract quantity, or zero, whichever is greater. Dutch TTF Natural Gas (USD/MMBTU) FuturesStyle Margined Average Price Put Option traded on the Exchange represents the differential between 

the strike price and the Floating Price, multiplied by the contract quality, or zero, whichever is greater. 

1019102.C. Price Increments 

Prices shall be quoted in U.S. dollars and cents per MMBtu. The minimum price fluctuation shall be 

$0.001 per MMBtu.

1019101.D. Position Limits, Exemptions, Position Accountability and Reportable Levels

Position Limits, Exemptions, Position Accountability and Reportable Levels The applicable position 

limits and/or accountability levels, in addition to the reportable level s, are set forth in the Position 

Limit, Position Accountability and Reportable Level Table in the Interpretations & Special Notices 

Section of Chapter 5. A Person seeking an exemption from position limits for bona fide commercial 

purposes shall apply to the Market Regulation Department on forms provided by the Exchange, and 

the Market Regulation Department may grant qualified exemptions in its sole discretion. Refer to 

Rule 559 for requirements concerning the aggregation of positions and allowable exemptions from 

the specified position limits.

1019102.E. Termination of Trading

Trading terminates at 17:00 London time on the second last London business day of the month prior 

to the contract month. If this is not a U.S. business day, trading terminates on the prior U.S. and 

London business day.

1019102.F. Type of Option 

The option is a European-style option cash settled on expiration day.

1019102.G. Settlement Variation and Option Value

This contract is a future-style margin option. Settlement variation rules for futures-style margin 

options conform to those set forth for non-options stipulated in NYMEX Rule 814. As such, when a 

clearing member or its customers is long or short any amount of any commodity for a settlement 

cycle, as indicated by Clearing House records, settlement for any outstanding exposure shall be 

made with the Clearing House based on the settlement price for that settlement cycle. For futuresstyle margin options, each clearing member and its customers shall pay to, or collect from, the 

Clearing House any loss or profit, as the case may be, represented by the difference between (x) the 

settlement price of the futures-style margin option for such settlement cycle and (y) the settlement 

price of the futures-style margin option for the prior settlement cycle (or, for the first settlement cycle 

after the purchase/sale of such option, the price at which the option was purchased or sold).

1019102. EXERCISE PRICES

Transactions shall be conducted for option contracts as set forth in Rule 300.20.
8

EXHIBIT B

NYMEX Rulebook

Chapter 5

(“Trading Qualifications and Practices”)

Position Limit, Position Accountability, and Reportable Level Table 

(under separate cover)
9

EXHIBIT C

NYMEX Rulebook

Chapter 5

(“Trading Qualifications and Practices”)

NYMEX Rule 588.H. – (“Globex Non-Reviewable Trading Ranges”) Table

(additions underscored)

Outrights Spreads

Instrument Globex 

Symbol

Globex Non-Reviewable Ranges 

(NRR)

NRR: 

Globex 

Format

NRR:Minimum 

Ticks

NRR: 

Globex 

Format

NRR: 

Outright 

Minimum 

Ticks

Dutch TTF Natural Gas 

(USD/MMBTU) Average month 

Futures

TFU $.10 per MMBtu 100 100 25 25

Globex 

Symbol Globex Non-Reviewable Ranges (NRR)

Dutch TTF Natural Gas 

(USD/MMBTU) Average month 

Futures-Style Margined Options

TFF The greater of the following:

•Delta multiplied by the underlying futures non-reviewable range

•20% of premium up to 1⁄4 of the underlying futures nonreviewable range

•5 ticks

Dutch TTF Natural Gas 

(USD/MMBTU) Average month 

Options

TFP
10

EXHIBIT D

Exchange Fees

Member Non-Member

CME Globex $4.00 $5.00

EFP $4.00 $5.00

Block $4.00 $5.00

EFR/EOO $4.00 $5.00

Processing Fees Member Non-Member

Cash Settlement $1.00 $1.00

Facilitation Fee $0.60

Give-Up Surcharge $0.05

Position Adjustment/Position 

Transfer $0.10
11

EXHIBIT E

Cash Market Overview and Analysis of Deliverable Supply

Cash Market Overview

The Exchange relied on a number of publicly available source to determine Deliverable Supply (“DS”) in 

Dutch TTF Natural Gas. 

NYMEX used data from the European Union’s statistical office, Eurostat, the European Network of 

Transmission System Operators for Gas, ENTSOG, and the European Association of Renewable and Lowcarbon Gases Infrastructure Operators, GIE. In addition, we are using data from Gasunie Transport 

Services (GTS), the gas transmission system operator operating in the Netherlands.

Physical market participants can deliver natural gas into the TTF virtual trading hub via various routes. TTF 

is not a single-location hub, in which one specific entry point (and the capacity of that point) may determine 

deliverable supply. Instead, TTF is a virtual trading point that includes all of all of the Netherlands’ natural 

gas entry and exit points. Market participants can produce gas within the Netherlands, import gas from 

neighboring countries, import gas from undersea pipelines, or take delivery from gas molecules from LNG 

cargoes via LNG import terminals. Finally, they can also make use of local gas storage sites to take delivery 

of natural gas that was previously injected into storage -- all these components add potential to deliver gas 

molecules into the TTF trading system. Following this approach, TTF DS will be defined as the sum of:

• Netherlands internal production of natural gas 

• Netherlands pipeline import capacity – pipelines that connect into the TTF hub

• Netherlands LNG import capacity – capacity of LNG terminals to feed into the TTF

• Gas storage capacity – gas storage sites which can release natural gas into the TTF 

Because capacity figures are not subject to seasonal fluctuations, we do not include a seasonality 

adjustment on pipeline and storage capacity. However, domestic production of natural gas in the 

Netherlands is seasonal: typically, domestic gas fields produce more during the winter months to match 

increased heating demand. Because of this seasonality, we propose to adjust domestic production figures 

to account for that seasonality effect.

TTF DS is not adjusted for long-term contracts. We believe that this is not required, as the TTF market is 

highly developed and spot market liquidity across exchanges and OTC provides ample access to natural 

gas to meet short term supply requirements. Public data sources provide a good overview of prevalent 

market liquidity to assess the suitability of this methodology. Gasunie tracks monthly churn rates which 

documents the significant increase in TTF liquidity across the past few years. The market churn is defined 

as the volume of gas traded (OTC and on exchange) as a ratio to nominated volume. Over the past years, 

market churn rates in TTF have increased from an average of 54x (in 2018) to 91x (in 2020) and 98x (in 

2021) as depicted in Table 1 below.

Table 1 – Monthly Churn Rates at the TTF Virtual Trading Hub

Monthly Churn rates TTF

Minimum Average Maximum

2011 10x 18x 26x

2012 10x 20x 31x

2013 13x 20x 30x

2014 20x 34x 54x

2015 25x 40x 53x
12

2016 23x 46x 78x

2017 25x 42x 59x

2018 30x 54x 85x

2019 36x 72x 107x

2020 70x 91x 128x

2021 65X 98X 144X

Source: Gasunie Transport Services

Table 2 provides natural gas primary production in the Netherlands. Table 3 provides a monthly primary 

production breakdown in the Netherlands (the latest available data is December 2019) Compared to the 

annual average production, production during the lowest active months (in Q2 and Q3) amount to between 

80-90% of the annual average. 

Table 2 – Annual Natural Gas Primary Production in the Netherlands

2017 2018 2019 Average

Terajoules 1,544,415 1,297,096 1,122,222 1,321,244 

GWh 429,008 360,307 311,731 367,015 

TWh 429 360 312 367 

Source: Eurostat

Table 3 – Monthly Natural Gas Primary Production in the Netherlands 

Terajoules 2017 2017% 2018 2018% 2019 2019%

Jan 150,840 117% 129,613 120% 147,157 157%

Feb 143,942 112% 109,499 101% 100,345 107%

Mar 137,045 106% 133,728 124% 106,564 114%

Apr 136,979 106% 101,178 94% 87,082 93%

May 119,885 93% 103,877 96% 94,662 101%

Jun 107,490 84% 99,894 92% 87,415 93%

Jul 116,820 91% 102,643 95% 84,380 90%

Aug 124,284 97% 98,219 91% 87,468 94%

Sep 112,288 87% 97,519 90% 77,663 83%

Oct 122,118 95% 93,324 86% 69,198 74%

Nov 136,845 106% 108,589 100% 87,757 94%

Dec 135,879 106% 119,013 110% 92,531 99%

Average 128,701 108,091 93,519 

Total 1,544,415 1,297,096 1,122,222 

Source: Eurostat

Table 4 provides the Netherlands’ pipeline import capacity – from neighboring countries as well as 

underwater pipelines and LNG import terminals.

Table 4 – Netherlands Pipeline Import Capacity – Border Countries

Netherlands Import capacity 

(GWh/day)

Gas year 18/19 19/20 20/21 3-year average
13

Belgium 394 393 331 378

Germany( Gaspool+NCG) 503 593 594 563

Norway (underwater) 963 963 963 963

LNG import terminals 385 418 385 396

Sum 2300

Source: ENTSOG system development maps

Finally, GIE provides domestic gas storage volume data for the Netherlands. Table 5 shows the average 

of the technical withdrawal capacity of each operator from January 1, 2019 to December 31, 2021. The 

aggregated capacity across all storage sites in the Netherlands was 2,687 GWh/day.

Table 5 – Netherlands Storage Capacity

Operator Facility/Location Status Investment

Start-up Withdrawal

year technical

GWh/day

EnergyStock BV EnergyStock operational existing 2011 424

EnergyStock BV EnergyStock planned planned - 

NAM Grijpskerk operational existing 1997 719

NAM Norg (Langelo) operational existing 1997 763

TAQA Gas Storage Bergermeer operational existing 2015 497

TAQA Piek Gas Alkmaar operational existing 1997 282

Sum 2,687

Source: GIE

The below chart shows that withdrawals from Dutch storage sites occur mainly during winter months to 

respond to seasonal heating demand. It also shows that storage capacity is stable across the years.
14

Analysis of Deliverable Supply

Table 6 summarizes the capacity and volume information for physical gas deliveries within the Netherlands. 

To account for lower production during summer months, domestic production figures are adjusted 

downwards by 20%. 

Table 6 – TTF Deliverable Supply and Spot-Month Position Limit

Natural gas domestic production 367 TWh

Natural gas domestic production 

seasonally adjusted 294 TWh (A)

Netherlands import capacity 2300 GWh/day

840 TWh (B)

Netherlands storage withdrawal capacity 2,687 GWh/day

981 TWh (C)

Deliverable Supply (annual) 2,114 TWh 

(A+B+C)

Deliverable Supply (monthly)

176 TWh

 

176,187,917 MWh

 

601,256,100 MMBTU

 

60,126 Contracts*

Spot month Position limit 12,000 Contracts 

% of DS 19.96%

* Note = 10,000 MMBTU contract equivalent

0

500

1000

1500

2000

2500

3000

3500

1/1/2019 7/20/2019 2/5/2020 8/23/2020 3/11/2021 9/27/2021 4/15/2022

GWh/day

Natural Gas Storage - Capacity & Withdrawals

WITHDRAWAL(GWh/d) WITHDRAWAL CAPACITY(GWh/d)
15

For the Dutch TTF Natural Gas (USD/MMBTU) Futures, Dutch TTF Natural Gas (USD/MMBTU)

Futures-Style Margined Average Price Option, and the Dutch TTF Natural Gas (USD/MMBTU) 

Average Price Option are 10,000 MMBTu units, the Exchange proposes a spot month position limit of 

12,000 contracts, equivalent to 19.96% of Deliverable Supply.