text: OJ L158, 14.6.2019, p. 22. 2 OJ L 158, 14.6.2019, p.54

text: Opinion No 02/2024

text: See

text: Article 16

text: and Point 1.7 of Annex I of

text: Regulation (EC) No 714/2009

text: of the European Parliament and of the Council of 13 July 2009 on conditions for access to the network for cross-border exchanges in electricity and repealing

text: Regulation (EC) No 1228/2003

text: , OJ L 211, 14.8.2009, p. 15. 4 See recital (27) of

text: Regulation (EU) 2019/943

text: of the European Parliament and of the Council of 5 June 2019 on the internal market for electricity (recast).

text: Opinion No 02/2024

text: The revised Electricity Regulation is part of this ‘Clean energy for all Europeans’ legislative package. 6 See

text: Commission Regulation (EU) 2017/1485 of 2 August 2017

text: establishing a guideline on electricity transmission system operation.

text: Opinion No 02/2024

text: See section 2.2.1 of the 2023 edition of the market monitoring report on cross-zonal capacities and the 70% margin available for cross-zonal trade (MACZT), which can be accessed using the following link: https://www.acer.europa.eu/sites/default/files/documents/Publications/2023_MMR_MACZT_0.pdf 8 The deadline was extended by one week to allow for all stakeholders to respond.

text: Opinion No 02/2024

text: nd (20) On 7 March 2024, the Opinion was discussed at the 122 ACER Board of Regulators meeting, and it was informally endorsed by the Board of Regulators through electronic procedure on 11 March 2024.

text: The 2023 edition of the market monitoring report on the progress of EU electricity wholesale market integration can be accessed using the following link: https://www.acer.europa.eu/sites/default/files/documents/Publications/2023_MMR_Market_Integration.pdf 10 See recital (27) of the Electricity Regulation, ‘Uncoordinated curtailments of interconnector capacities increasingly limit the exchange of electricity between Member States and have become a serious obstacle to the development of a functioning internal market for electricity.’

text: Opinion No 02/2024

text: See Article 13(5) of the Electricity Regulation. 12 See sections 2.2.2 and Table 4, respectively, of the 2023 edition of the market monitoring report on cross-zonal capacities and the 70% margin available for cross-zonal trade (MACZT): https://www.acer.europa.eu/sites/default/files/documents/Publications/2023_MMR_MACZT_0.pdf

text: Opinion No 02/2024

text: See ACER’s overview and main characteristics of the derogation requested during period 2020-2023: https://acer.europa.eu/sites/default/files/documents/Official_documents/Acts_of_the_Agency/Publications%20A nnexes/ACER%20Report%20on%20the%20result%20of%20monitoring%20the%20MACZT%20Generic/ACE R%20Report%20on%20the%20result%20of%20monitoring%20the%20MACZT%20Derogations.pdf

text: Opinion No 02/2024

text: See e.g. Recital (27) of the Electricity Regulation: “(…) Furthermore, in the case of foreseeable problems for ensuring grid security, derogations should be possible for a limited transition phase.” 15 See, for example, the CREG’s Decision (B)2687 on the request of Elia System Operator SA for derogation from the minimum level of capacity to be made available for cross-zonal trade: https://www.creg.be/sites/default/files/assets/Publications/Decisions/B2687FR.pdf

text: Opinion No 02/2024

text: See, for example, the data reported by Bundesnetzagentur on the volumes of redispatching activated in Germany during the first two quarters of 2023:

text: Opinion No 02/2024

text: https://data.bundesnetzagentur.de/Bundesnetzagentur/SharedDocs/Downloads/DE/Sachgebiete/Energie/Unterne hmen_Institutionen/Versorgungssicherheit/Netzengpassmanagement/Q2-2023_Quartalsbericht- Netzengpassmanagement.pdf 17 See Chapter 3 of the market monitoring report on the progress of EU electricity wholesale market integration: https://www.acer.europa.eu/sites/default/files/documents/Publications/2023_MMR_Market_Integration.pdf

text: Opinion No 02/2024

text: See Tables 4 and 5 of ACER Decision No 11/2022 of 8 August 2022 on the alternative bidding zone configurations to be considered for the bidding zone review process: https://www.acer.europa.eu/sites/default/files/documents/Individual%20Decisions/ACER%20Decision%2011- 2022%20on%20alternative%20BZ%20configurations.pdf

text: Opinion No 02/2024

text: Opinion No 02/2024

text: See the list of projects under the TYNDP 2022 and their status: https://tyndp2022-projectplatform.azurewebsites.net/projectsheets/transmission

text: Opinion No 02/2024

text: Opinion No 02/2024

identifier: ACER Opinion No 02/2024

title: ACER Opinion 02-2024 on the necessary developments for the fulfilment of the minimum cross-zonal capacity requirements

text: PUBLIC

text: OPINION No 02/2024 OF THE EUROPEAN UNION AGENCY FOR THE COOPERATION OF ENERGY REGULATORS of 10 April 2024 on the necessary developments for the fulfilment of the minimum crosszonal capacity requirements

text: THE EUROPEAN UNION AGENCY FOR THE COOPERATION OF ENERGY REGULATORS,

text: Having regard to

text: Regulation (EU) 2019/942

text: of the European Parliament and of the Council of 5 June 2019 establishing a European Union Agency for the Cooperation of Energy Regulators , and, in particular,

text: Article 15(3)

text: thereof,

text: Whereas:

text: 1. INTRODUCTION

text: (1) As the EU strives to meet the ambitious renewable energy targets and address the challenges of climate change, the efficient exchange of electricity across borders plays a pivotal role in fostering an integrated and resilient internal electricity market. Maximising the possibilities to exchange energy between Member States enhances the resilience of the overall power system, ensures the optimal use of generation assets and facilitates the penetration of renewable energy. A fully functioning internal electricity market, where electricity can be freely exchanged across borders, is of key importance to the EU’s decarbonisation efforts.

text: (2) The development and implementation of rules for the calculation and allocation of cross-zonal capacities has been an integral step for the completion of the internal electricity market. The primary objective of these rules is an efficient management of

text: congestions (i.e., situations in which all requests from market participants to trade between network areas cannot be accommodated as they would significantly affect the physical congestions in the grid), so as to maximize the access to cross-zonal trade and thus allow for efficient market functioning.

text: (3) Over the last decade, significant progress has been achieved in the area of capacity allocation, in particular through the development and introduction of market coupling. Market coupling ensures that the available cross-zonal capacities, as calculated by transmission system operators (‘TSOs’), are used in the most efficient manner. In the area of coordinated capacity calculation, however, progress has been much slower.

text: (4) The electricity market in the European Union is structured into bidding zones, where the impact of electricity trade between market participants within each bidding zone on physical congestions is ignored, even though it may not be negligible, and thus trade within zones is unlimited. In contrast, the trade between bidding zones is limited by a predefined set of values of cross-zonal transmission capacity reflecting physical congestions in the grid.

text: (5) Following this model, requests for internal exchanges get unlimited and prioritised access to the scarce network capacity, whereas requests for cross-zonal exchanges can only access the portion of that capacity which is not already used by internal exchanges. Under the historic bidding zone configuration in the EU, where bidding zones reflect national borders and not necessarily the physical reality of the power grid, this approach constitutes a significant barrier for the integration and the efficient functioning of the internal electricity market. Moreover, it discriminates between network users in different parts of the network, with some users accessing the scarce capacity of the network for free and without limitations, while others having to compete for an ex-ante limited amount of capacity. This comes at the expense of endconsumers, who cannot reap the benefits of a fully integrated electricity market.

text: (6) The principles of maximization of cross-zonal capacities and non-discrimination between internal and cross-zonal trade have long been enshrined in the European legal and regulatory framework for electricity , as they stem directly from the fundamental freedoms of the Treaty on the Functioning of the European Union. However, the lack of progress towards upholding these two core principles led to the introduction of a concrete and measurable minimum level of available capacity for cross-zonal trade in the ‘Clean energy for all Europeans’ legislative package.

text: Article 16(8) of Regulation (EU) 2019/943

text: of the European Parliament and of the Council of 5 June 2019 on the internal market for electricity (hereafter referred to as

text: the ‘Electricity Regulation’) requires TSOs, without prejudice to operational security limits, not to limit the volume of interconnection capacity to be made available to market participants as a means of solving congestion inside their own bidding zone or to manage flows resulting from transactions internal to bidding zones. TSOs are considered compliant with this requirement of the Electricity Regulation if they make available for cross-zonal trade at least 70% of the physical capacity of internal and cross-zonal critical network elements considering contingencies (‘CNECs’).

text: (8) This minimum threshold introduced in the Electricity Regulation (hereinafter referred to as the ‘minimum 70% requirement’), which aims at mitigating the discrimination of cross-zonal trades in favour of domestic trades, has become a key tool in the progress of EU electricity market integration, as it incentivises the optimal use of the available network assets. Article 16(8) of the Electricity Regulation further specifies that the remaining maximum amount of 30% can account for reliability margins, loop flows and internal flows on each critical network element with contingency.

text: (9) To allow for Member States to implement this provision without endangering system security, a process was agreed upon during the negotiations of the ‘Clean energy for all Europeans’ package , whereby the relevant stakeholders were to cooperate to identify structural congestions within and between bidding zones and assess potential bidding zone reconfigurations. To support this process, Article 15 of the Electricity Regulation allows Member States to establish action plans to ensure the gradual fulfilment of the minimum 70% requirement, up until the end of 2025, in parallel to the implementation of structural measures to cope with the identified structural congestion.

text: (10) In the meantime, where necessary for maintaining operational security, the relevant regulatory authorities may, at the request of the TSOs in a capacity calculation region (‘CCR’), grant a derogation from the minimum 70% requirement pursuant to the first subparagraph of Article 16(9) of the Electricity Regulation to the extent necessary to ensure operational security, relaxing the requirements under Article 16(8) of the Electricity Regulation for a limited period.

text: (11) Moreover, as a measure of last resort, TSOs have the possibility, in accordance with Article 16(3) of the Electricity Regulation, to deviate from the minimum cross-zonal capacity requirements (which correspond to either the 70% or the interim national targets stemming from the applicable derogations and/or action plan, if any), in cases where such levels of capacity would result in a violation of the operational security limits defined by each TSO in accordance with the system operation guideline adopted on the basis of

text: Article 18(5) of Regulation (EC) No 714/2009

text: (12) In accordance with

text: Article 15 of Regulation (EU) 2019/942

text: of the European Parliament and of the Council of 5 June 2019 establishing a European Union Agency for the Cooperation of Energy Regulators (hereafter referred to as the ‘ACER Regulation’), ACER is tasked with monitoring potential barriers to cross-border trade, and to report on any identified barrier to the completion of the internal markets for electricity and natural gas.

text: (13) The limited levels of cross-zonal capacities made available, which the minimum 70% requirement aimed to address, have long been a barrier to the further integration of EU electricity markets, making them a primary focus of ACER’s monitoring efforts. However, the specific strategy with regards the implementation of the minimum 70% requirement is of national discretion, and the assessment of TSO compliance with the minimum requirements remains, therefore, the responsibility of the national regulatory authorities.

text: (14) ACER’s monitoring activities on the evolution of cross-zonal capacities over the last years have shown that a large share of EU TSOs are still far from fulfilling the minimum 70% requirement , and that significant barriers to the maximization of cross-zonal capacities persist. Therefore, in accordance with Article 15(3) of the ACER Regulation, ACER issues this Opinion to the European Parliament and to the European Commission, aiming to outline the causes, effects and necessary developments required to remove such barriers.

text: 2. PROCEDURE

text: (15) On 21 July 2023, ACER published its yearly edition of the market monitoring report on cross-zonal capacities and the minimum 70% margin available for cross-zonal trade ('MACZT’, which measures the share of the physical capacity of a network element that is made available to the market for cross-zonal trade), which reported on the monitoring analysis for 2022. This report aimed to highlight the importance of maximising the margin available for cross-zonal trade in the context of the 2022 energy crisis, to assess the usage of network elements with regard to the minimum cross-zonal capacity requirements, and to identify potential barriers to cross-zonal trade.

text: (16) On 21 July 2023, ACER published a notice inviting interested stakeholders to submit observations on the insights presented in the market monitoring report on cross-zonal capacities and the minimum 70% MACZT by 22 September 2023 via a public consultation. ACER received 31 observations representing a broad range of stakeholders, including TSOs, energy traders, energy producers, industry associations

text: and regulatory authorities. An overview of the observations received, as well as the response from ACER, were relevant, is presented in Annex I of this Opinion.

text: (17) ACER held a public webinar on 6 September 2023, where it presented the main conclusions of the market monitoring report on cross-zonal capacities and the minimum 70% MACZT, addressed the questions of the audience, and discussed the topic with selected panellists.

text: (18) On 3 November 2023, ACER published its market monitoring report on the progress of EU electricity wholesale market integration. This report evaluated the functioning of the EU’s internal electricity market in 2022 by assessing, among other indicators, the use of remedial actions by EU TSOs in grid congestion management.

text: (19) The draft Opinion was shared with ACER’s Capacity Calculation and Congestion Management task force (‘CACM TF’) and ACER’s Electricity Working Group (‘AEWG’), where national regulatory authorities were invited to provide their views on the draft in two commenting rounds. Three regulatory authorities, the Bundesnetzagentur (‘BNetzA'), the Commission de Régulation de l’Énergie (‘CRE’) and the Autorità di Regolazione per Energia, Reti e Ambiente (‘ARERA’), submitted written views during the commenting phases. Both CRE and ARERA emphasized the need to further highlight the costs of fulfilling the minimum 70% requirement, via the use of remedial actions and grid expansion, while BNetzA argued that sufficient progress is being made in the implementation of the requirement and does not share the need to issue the present Opinion.

text: 3. ACER’S ASSESSMENT

text: (21) Limited levels of transmission capacity made available for cross-zonal trade hamper the process of electricity market integration in the EU. This, in turn, represents a barrier to the transition of the EU power system towards net-zero and a detriment to the European consumer. By way of an example, the expected 300 GW of offshore wind to be installed in the EU by 2050 will require an integrated market with sufficient capacity to reach the demand centres across the whole EU. The fulfilment of the minimum 70% requirement in an efficient and structural way, minimizing the need

text: for curtailment of renewable energy , will contribute to tackling the need for crosszonal capacities in the EU’s path towards decarbonization. Moreover, it contributes to addressing the discrimination of cross-zonal trade in favour of internal trade, inherent to the EU’s market design.

text: (22) ACER’s monitoring on the implementation of the minimum 70% requirement over the last years has shown uneven progress since the introduction of this provision. Concretely, the 2023 market monitoring report on cross-zonal capacities and the 70% margin available for cross-zonal trade showed that the TSOs corresponding to the more meshed areas of the EU power grid, albeit with some exceptions, are still far from being able to guarantee the 70% of MACZT in most hours of the year, and highlighted that significant limitations to the progress towards fulfilling the requirement and, more generally, the maximization of cross-zonal capacities, persist.

text: (23) The implementation of regional coordinated capacity calculation methodologies, stemming from the

text: Regulation (EU) 2015/1222

text: establishing a guideline on capacity allocation and congestion management (hereafter the ‘CACM Regulation’), is a prerequisite for guaranteeing the minimum cross-zonal capacity requirements in a structural and operationally secure manner. The implementation of these methodologies, however, have been delayed across several capacity calculation regions (‘CCRs’), including both the Core and Nordic CCRs. This has led to, in some cases, TSOs falling short from the fulfilment of the minimum cross-zonal capacity requirements, or the impossibility to fully monitor the fulfilment of such requirements in others .

text: (24) Moreover, electricity flows within bidding zones induced by transactions within other bidding zones (i.e., loop flows) remain significant. These ‘free-riding flows’ can use up a high share of the physical capacity of certain network elements, without bearing the costs for their usage, making them partially inaccessible to cross-zonal trade, and thus hindering the possibilities of the most affected TSOs to fulfil the minimum 70% requirement. Additionally, the increasing level of penetration of renewable energy sources into the system could further exacerbate this phenomenon in the coming years, as the volumes of trade necessary to transport the renewable energy output to the demand centres will increase vastly. A solution to the problem is thus urgent. The methodologies for the forecast, activation, and cost-sharing of remedial actions across TSOs' control areas, as well as and targeted grid developments, would allow to partly mitigate the impact of loop flows. However, the above-mentioned methodologies have not been implemented to this date and the large-scale targeted grid developments that would be necessary are not expected in the short term.

text: (25) Based on the information currently available, ACER sees significant difficulties in achieving the structural and efficient fulfilment of the minimum 70% requirement across the whole EU by 2026, which would in turn jeopardise the ambitious targets set for renewable energy integration. In the following subsections of this Opinion, ACER aims to address some of the main elements that lead to such an outlook, and to highlight the necessary developments that would enable the fulfilment of the minimum 70% requirement within the timeline defined in the Electricity Regulation. As such developments may require political acceptance, ACER considers of key importance to raise awareness for the issue and the potential solutions.

text: 3.1.1. No (near) end in sight for derogations from the minimum 70% requirement

text: (26) Pursuant to the first subparagraph of Article 16(9) of the Electricity Regulation, at the request of the TSOs in a CCR, the relevant regulatory authorities may grant a derogation from the minimum 70% requirement on foreseeable grounds where necessary for maintaining operational security, provided that no other regulatory authority of the affected CCR disagrees with the proposed derogation. Article 16(9) of the Electricity Regulation provides that:

text: (a) the extent of a derogation shall be strictly limited to what is necessary to maintain operational security;

text: (c) a derogation shall be granted for no more than one-year at a time, or, provided that the extent of the derogation decreases significantly after the first year, up to a maximum of two years;

text: (d) a derogation shall avoid discrimination between internal and cross-zonal exchanges.

text: (27) Such derogations, intended to facilitate the transition to the fulfilment of the minimum 70% requirement by 2026, allow for a temporary relaxation of the minimum 70% requirement to ensure that operational security is not compromised. Since the entry into force of the Electricity Regulation, a majority of EU TSOs have been granted derogations by their respective regulatory authorities on different grounds . While the number of derogations applicable in the EU has been decreasing in recent years, these have limited the progress towards the maximization of cross-zonal capacities.

text: (28) Through its monitoring efforts, ACER has detected that some of the currently applicable derogations can lead to either very low requirements of MACZT in certain

text: conditions, or to no quantitative requirement at all. While some derogations establish a moving requirement, defined ex-ante based on the forecasted risk to operational security, a share of the granted derogations do not have a clear enforceable threshold defined for all market time units. Either they set no target, or this target only applies to a share of the hours.

text: (29) ACER considers important that all derogations include, where possible, enforceable and concrete targets for all market time units, as this is the only way to guarantee that derogations are in fact strictly limited to what is necessary to maintain operational security. Failing to do so also implies that the condition not to discriminate between internal and cross-zonal exchanges cannot be guaranteed. Moreover, a floor of the margin made available for cross-zonal trade should be considered when defining the target, to guarantee that a minimum level of capacity is always made available.

text: (30) Moreover, the progress in implementing the methodologies and processes that address the reasons behind derogation requests over the last years has been slow. ACER thus sees a risk that derogations will continue to be used well beyond 2025, and thus that they will effectively perpetuate low margins of cross-zonal capacity after that. This contradicts the intention of the legislator in the transitional nature of derogations whereby, as of 1 January 2026, all identified structural congestion inside bidding zones should have been addressed, and thus 70% of margin available for cross-zonal trade should be reached in the entire EU by then.

text: (31) A clear case of this risk are derogations that are granted to address the impact of significant loop flows originating in neighbouring bidding zones. In the Core CCR, several TSOs have requested derogations on a yearly basis since entry into force of the minimum 70% requirement due to the presence of loop flows above an acceptable threshold. These derogations have been granted under the assumption that, as the origin of the loop flows is outside the control area of a given TSOs, the local remedial action potential is insufficient to alleviate the impact of such flows.

text: (32) Although the finalization of the national action plans by the end of 2025 are expected to reduce the level of loop flows across the Core CCR, the general applicability of the 70% requirement after that is no guarantee that the negative effect of loop flows in neighbouring control areas is fully tackled. The implementation of processes to forecast, activate and share the cost of remedial actions across the TSOs of the region are necessary to address this issue, at least in the day-ahead timeframe, by reducing the detrimental effect of loop flows on the capacity levels made available to the market. The most relevant processes in that regard are the coordinated validation assessment within the capacity calculation, the regional operational security

text: coordination (‘ROSC’) and the redispatching and cost-sharing methodologies. The coordinated validation step will allow Core TSOs to assess the operational security of the calculated capacities with the forecast of all the remedial actions that would be available in the region. The redispatching and cost-sharing methodologies will then ensure that TSOs at the source of the loop flows will trigger, and bear the cost of, the necessary remedial actions to mitigate their impact.

text: (33) Despite the legal deadlines for the implementation of these methodologies being set well before the end of 2025, the projected development timeline of the Core TSOs indicates that some of these processes will not be established by then. These delays further underline the concern that derogations to address the impact of loop flows from neighbouring bidding zones will continue to be requested beyond 2025, thereby hampering the progress towards meeting the minimum 70% requirement in the most affected Member States. In light of the aforementioned, implementation delays beyond the timeline provided in the Electricity Regulation for the fulfilment of the minimum 70% requirement should not warrant additional derogations.

text: 3.1.2. Remedial actions may not always be a feasible nor a cost-efficient option to guarantee 70%

text: (34) As clarified by recital 20 of the Electricity Regulation, where the coordinated capacity calculation performed at a regional level does not result in cross-zonal capacity equal to or above the minimum capacities set out in the Electricity Regulation, regional coordination centres (‘RCCs’) are tasked with considering all available costly and non-costly remedial actions to further increase capacity up to the minimum requirement, including redispatching potential within and between the CCRs, while respecting the operational security limits of the TSOs of the CCRs. The triggering of remedial actions by TSOs allows for a reduction in the flows of certain CNECs in such a way that the applicable minimum cross-zonal capacity can be offered to the market for cross-zonal trade.

text: (35) ACER’s market monitoring report on the progress of EU electricity wholesale market integration shows a significant increase in the costs of remedial actions incurred by TSOs in 2022 as compared to previous years. The total cost of remedial actions in 2022 totalled 5.2 billion EUR, which constitutes a 46% increase compared to 2021. This increase can be explained by the energy crisis and related price increases on the one hand, but also due to the constantly increasing volumes of costly remedial actions necessary to guarantee the minimum cross-zonal capacity requirements. Preliminary data on remedial actions for the year 2023 in Germany indicate that, even if the costs incurred may be lower than those of 2022 due to the generally lower electricity prices, the volumes of redispatching activated continue to increase steadily . Furthermore,

text: ACER’s monitoring shows that a large share of the generation technologies involved in redispatching are fossil-based. Concretely, in 2022 a 66% of the reported redispatching volumes in the EU involved fossil-based generation, constituting a total of over 26 TWh.

text: (36) The surge of certain renewable energy sources in the power system, especially offshore wind, driven by the ambitious emission reduction targets set by the EU as well as individual Member States, will only exacerbate the need for activating remedial actions, and its costs, unless more structural measures are implemented swiftly. These are notably the development of grid infrastructure or the adjustment of the current bidding zone configuration. In absence of these structural measures, the surge of renewable energy penetration will bring an increased need for curtailment of renewable energies, at the expense of the use of more expensive and polluting generation technologies, which may risk squandering some of the efforts in the EU’s emission reduction targets and increasing the energy bill for end-consumers.

text: (37) Moreover, ACER has reported a significant number of cases where a lack of sufficient remedial actions prevented TSOs from securing the applicable minimum cross-zonal capacity requirement. ACER expects this effect to increase in the coming years, as the national transitory targets continue advancing towards 70%, and more renewable energy is integrated into the power system.

text: (38) In the intraday timeframe, guaranteeing the minimum cross-zonal capacity requirements by relying solely on remedial actions poses a major challenge to TSOs. Closer to real time, the availability of remedial actions tends to decrease, as some of the assets currently used in congestion management are not flexible enough to be activated close to real time. While such technical complexity does not generally exempt trading in the intraday timeframe from complying with the non-discrimination principle and the obligations under Article 16(8) of the Electricity Regulation, structural solutions such as bidding zone reconfigurations or targeted grid reinforcements may be a pre-condition for the practical and consistent application of the principle in the intraday timeframe. With the increasing penetration of generation from variable renewable energy sources into the system, the importance of intraday markets is expected to be such that the maximisation of cross-zonal capacities offered in that timeframe should become a priority.

text: (39) In case that TSOs are unable to fulfil the minimum 70% requirement by relying extensively on the use of remedial actions, more structural solutions need to be pursued. This can be done either by reinforcing the power grid development where internal congestion often occurs, or is foreseen to occur, or by adjusting the bidding

text: zone configuration so that it better reflects the reality of the power grid, and in that way convert a share of the loop and internal flows into allocated flows.

text: (40) The reconfiguration of the bidding zones in the EU is currently being assessed by means of a pan-European bidding zone review study, mandated by Article 14 of the Electricity Regulation. In that context, ACER Decision No 11/2022 of 8 August 2022 on the alternative bidding zone configurations to be considered in the bidding zone review process analysed the impact of a potential reconfiguration of bidding zones in the progress towards fulfilling the minimum 70% requirement. This assessment showed, inter alia, that some bidding zone configurations alternative to the current one could significantly reduce the levels of loop flows across Continental Europe. Such a reduction would reduce the need to rely on costly remedial actions, and the corresponding costs incurred, to guarantee the minimum cross-zonal capacity requirements in the bidding zones most affected by loop flows.

text: (41) However, both these alternatives are not without challenges, and both come with associated costs. The bidding zone review process has undergone several delays due to the modelling complexities and may not by itself ensure that the minimum crosszonal capacity requirements can be met, while network developments are becoming increasingly complex due to permitting difficulties and public opposition. Therefore, it is important to conclude in a timely manner the on-going processes on a technical level, in order to then be able to engage with the relevant stakeholders and decisionmakers at a political level.

text: 3.1.3. Deviations from the minimum requirements may become more frequent

text: (42) Besides the applicability of derogations, TSOs have the possibility, in accordance with Article 16(3) of the Electricity Regulation, to deviate from the legally binding minimum cross-zonal capacity requirements, as a measure of last resort, in those cases where such levels of capacity would result in a violation of the operational security limits defined by each TSO in accordance with the system operation guideline as currently established by

text: Commission Regulation (EU) 2017/1485

text: (43) These deviations are designed within the regional coordinated capacity calculation processes, by allowing a reduction of the cross-zonal capacities calculated by the RCC, either unilaterally or in a coordinated manner, whenever a risk for operational security that cannot be resolved through remedial actions, is detected. Article 16(3) of the Electricity Regulation states that if ACER concludes that the prerequisites for such a deviation are not fulfilled or are of a structural nature, ACER shall submit an opinion to the relevant regulatory authorities and to the Commission.

text: (44) A summary of all deviations needs to be provided to ACER by the relevant RCC in the form of quarterly reports. Under the current conditions, ACER cannot yet conclude whether the prerequisites for such deviations are met in each individual case, as not all necessary elements to assess the potential threat to operational security, such as the remedial actions considered in the analysis, are made available to ACER. It is therefore crucial that the existing information gaps are closed as soon as possible by ensuring transparency with ACER and NRAs on both the local and coordinated validation processes. However, on the basis of the information available, ACER considers that some of these cases may not be justifiable on grounds of operational security, namely in case of the following situations.

text: (45) Firstly, the consideration of all possible available remedial actions, both costly and non-costly, is a prerequisite when assessing the need for a deviation from the capacity requirements. This stems from Article 16(4) of the Electricity Regulation, which provides that costly remedial actions are to be used to reach the minimum capacity requirements. Unless all possible remedial actions available to a given TSO are considered when assessing the security of the cross-zonal capacity requirements, the application of a validation adjustment will not be a last resort option, and thus should not lead to a deviation.

text: (46) Moreover, when assessing the use of validation adjustments, special care needs to be taken in ensuring that this mechanism does not lead to internal congestion being pushed to the borders. This may happen when TSOs reduce capacities on critical network elements to address forecasted overloads on internal network elements, which are not critical network elements.

text: (47) Network elements that are not critical network elements (‘CNEs’) should in no case lead to reductions of cross-zonal capacities. The same should apply to network elements which are identified as critical but which are not significantly influenced by cross-zonal exchanges (i.e., with a maximum zone-to-zone PTDF below 5%) , as provided by

text: Article 29(3)

text: (b) of the CACM Regulation. These elements will be predominantly loaded with flows resulting from exchanges within bidding zones and, therefore, reducing cross-zonal capacities to avoid congestion on them is both inefficient and disproportionate.

text: (48) ACER’s assessment shows that the need for deviations from the cross-zonal capacity requirements on grounds of operational security reasons can lead to significant reductions of the calculated capacities, and thus to a less efficient market outcome. Moreover, unless structural measures are developed promptly, the growing share of renewable generation in the power system could further exacerbate the lack of remedial actions to deal with grid congestion, leading to a more frequent need for deviations. ACER considers crucial that deviations from the minimum cross-zonal capacity requirements do not become systematic, due to the lack of grid development or a suboptimal bidding zone configuration and calls for closer attention by the relevant regulatory authorities on ensuring that all the prerequisites for such deviations are met.

text: 3.1.4. Grid development will be critical to integrate renewable energy, but may not guarantee the fulfilment of 70%

text: (49) A necessary condition for the integration of renewable energy into the system is the reinforcement of the EU’s power grid. The vast amounts of renewable energy expected to be integrated into the system in the coming years require a significant acceleration on the EU’s grid expansion efforts. With regards to the minimum 70% requirement, the development or reinforcement of power lines where internal congestion often occurs, or is foreseen to occur, allows for more electricity to flow within bidding zones and thus can reduce the ratio of flows induced by internal exchanges that use up capacity of critical network elements, also reducing the amount of redispatching that would be necessary to guarantee the 70%.

text: (50) However, the fulfilment of the minimum 70% requirement cannot be solely reliant on the development of the power grid, as it may not be sufficient nor timely enough to consistently enable the fulfilment of the requirement. Firstly, grid development projects may not always have a positive impact on the margin available for crosszonal trade if they do not tackle specifically the grid bottlenecks internal to bidding zones where the margin is insufficient. By way of example, an increase of capacity of a cross-zonal line may result in an increase of loop flows, which could hamper further the fulfilment of 70%. It is thus important that grid development projects are (also) assessed with regards to their impact on the fulfilment of the minimum 70% requirement.

text: (51) Secondly, grid infrastructure projects can entail significant costs to the system and are subject to long development timelines, with potential delays, which may not allow the grid to keep pace with the rapid growth in renewable generation. As an example, assessing the projects under ENTSO-E’s Ten-Year Network Development Plan (TYNDP) of 2022 with an expected commissioning date before the end of 2025, points to a significant share (36%) of projects which have been delayed or rescheduled since the previous TYNDP of 2020, and over half of such projects (52%) still being in planning or permitting phases.

text: (52) An efficient use of the available grid infrastructure, such as through more coordinated operational processes and a potentially more adequate bidding zone configuration, would limit the number of grid development projects, and their costs, necessary to cope with the expansion of renewable energy.

text: 4. CONCLUSION

text: (53) The full integration of the EU internal electricity market is yet to be realized. Only by achieving truly integrated electricity markets will the EU be able to reap fully the

text: benefits from the penetration of renewable energy sources into the power system and guarantee a cost-effective decarbonisation. Ensuring non-discriminatory access to the EU network is a fundamental step towards that integration.

text: (54) The minimum 70% requirement, introduced in the Electricity Regulation, sets a clear standard for the availability of cross-zonal capacity in the EU, providing certainty to all market participants on their future access to the network. The minimum 70% requirement is also one of the key elements aiming to prevent discrimination of crosszonal trade against internal trade. In order to comply with this provision without endangering the security of the power system, the Electricity Regulation established a transitory period until the end of 2025 for all transmission system operators to deal with any potential structural grid congestion internal to the bidding zones. The minimum 70% requirement should become fully applicable in all EU Member States by 2026.

text: (55) However, ACER’s monitoring on the implementation of the minimum 70% requirement over the last years has shown that significant progress is still needed, while already recording a substantial increase in redispatching costs. The delay in implementing key processes, such as the capacity calculation methodologies and redispatching framework, has led to recurring derogations from the legal requirements, while the effects of more structural solutions such as necessary investments in grid reinforcement and potential bidding zone reconfigurations are yet to materialize. Based on the current developments, and without further pursuing such structural solutions, ACER considers that the fulfilment of the minimum 70% requirement across the whole EU by 2026, without massively relying on redispatching, is unlikely.

text: (56) While the specific strategy with regards to how to fulfil the minimum 70% requirement is of national discretion, the aforementioned delays in grid expansion, along with the limitations of relying heavily on remedial actions to guarantee the cross-zonal capacity requirements under the current bidding zone configuration, could pose a risk to the EU's ability to uphold the principle of non-discrimination between internal and cross-zonal trade in the coming years. This, in turn, could jeopardize the efforts invested in the integration of the electricity markets in the EU and thus the transition towards a carbon-neutral power system.

text: (57) As the fulfilment of the minimum 70% requirement is a key element to enable the energy transition and bring the benefits of an integrated electricity market to the endconsumers, it is essential to foster awareness on the political dimension of the more structural solutions necessary for its fulfilment and to underpin such solutions, in close cooperation with all stakeholders, with objective assessments of their feasibility and the mid- and long-term costs for the system,

text: HAS ADOPTED THIS OPINION:

text: 1. ACER would like to inform the European Commission and European Parliament of the urgency in the implementation of the minimum 70% requirement, and the need to

text: consider the structural solutions that would enable the fulfilment of this requirement in a cost-efficient and timely manner. These solutions include the potential reconfiguration of bidding zones, the optimal and coordinated use of remedial actions, and targeted grid developments aimed at reducing internal congestion. Not doing so would jeopardize the efforts invested in the transition towards a carbon-neutral power system in the EU. With respect to such solutions, ACER notes the following:

text: a) In relation to the coordinated use of remedial actions, ACER notes the delay in implementing the necessary methodologies to forecast, activate and share the cost of remedial actions across the EU, beyond the established regulatory deadlines. It is important that TSOs implement such processes without further delay in order to mitigate reductions of cross-zonal capacity below the minimum 70% requirement due to excessive loop flows and to increase transparency on the need and use of remedial actions. Moreover, TSOs should ensure that implementation delays beyond the legal deadlines do not jeopardise the timeline provided in the Electricity Regulation for the fulfilment of the minimum 70% requirement. b) Member States and, if they fail to agree, the European Commission, will have a key role to play in upholding the principle of non-discrimination of cross-zonal trade once the bidding zone review is finalized. Wherever the availability of remedial actions does not enable the sustained and efficient fulfilment of the minimum 70% requirement as of 2026, and where infrastructure investments cannot cover the remaining gap within the foreseen timeframe, Member States or the European Commission will need to decide on the appropriate configuration of the bidding zones. When taking such decision, it is important that they carefully consider their respective renewable energy targets and the overall system costs.

text: This Opinion is addressed to the European Parliament and the European Commission.

text: Done at Ljubljana, on 10 April 2024.

text: - SIGNED -

text: Fоr the Agency The Director

text: C. ZINGLERSEN

text: Annexes:

text: Annex I – Evaluation of responses


text: OJ L158, 14.6.2019, p. 22. 2 OJ L 259, 27.9.2016, p. 42.

text: Opinion No 02/2025

text: Opinion No 02/2025

text: ACER Decision 18/2023 on Harmonised Allocation Rules Amendment.

text: Opinion No 02/2025

text: https://umm.nordpoolgroup.com/#/messages/79210ee1-3395-4f75-a972-7b03888b107a/5 5 https://www.jao.eu/news/capacity-curtailment-fi-ee-border-delivery-period-2 6 OJ L 220, 25.8.2017, p. 1.

text: Opinion No 02/2025

text: Opinion No 02/2025

text: Opinion No 02/2025

text: Opinion No 02/2025

text: OJ L 197, 25.7.2015, p. 24

text: Opinion No 02/2025

text: Opinion No 02/2025

text: Opinion No 02/2025

identifier: ACER Opinion No 02/2025

publisher: Europeiska unionens byrå för samarbete mellan energitillsynsmyndigheter

sprak: en

title: ACER Opinion 02-2025 on the curtailment of financial transmission rights and interpretation of force majeure

serie: yttranden

text: PUBLIC

type: stycke

text: OPINION No 02/2025 OF THE EUROPEAN UNION AGENCY FOR THE COOPERATION OF ENERGY REGULATORS of 9 April 2025 relating to the curtailment of financial transmission rights and interpretation of force majeure

type: rubrik

text: THE EUROPEAN UNION AGENCY FOR THE COOPERATION OF ENERGY REGULATORS, Having regard to

text: Regulation (EU) 2019/942

text: of the European Parliament and of the Council of 5 June 2019 establishing a European Union Agency for the Cooperation of Energy Regulators , and, in particular,

text: Article 6(7)

text: thereof, Having regard to the outcome of the consultation with the European Commission, pursuant to

text: Article 6(7) of Regulation (EU) 2019/942

text: , Having regard to the outcome of the consultation with ACER’s Electricity Working Group (‘AEWG’), Having regard to the favourable opinion of the Board of Regulators of 2 April 2025, delivered pursuant to

text: Article 22(5)

text: (a) of

text: Regulation (EU) 2019/942

text: , Whereas:

text: 1. INTRODUCTION

text: (1) By email of 28 January 2025, the regulatory authority of Estonia, Konkurentsiamet, requested ACER to provide an opinion, pursuant to

text: , with regard to difficulties in the application of

text: Commission Regulation (EU) 2016/1719 of 26 September 2016

text: establishing a guideline on forward capacity allocation (the ‘FCA Regulation’). (2) The difficulties with the application of the FCA Regulation relate to an incident on the Finnish-Estonian (‘FI-EE’) bidding zone border on 25 December 2024, when the

text: submarine HVDC cable Estlink2 was damaged by a ship’s anchor. This incident prompted the transmission system operators (‘TSOs’) of Estonia, Elering AS, and Finland, Fingrid Oyj, to declare an event of force majeure and curtail the allocated long-term transmission rights (‘LTTRs’) on that bidding zone border. Following this curtailment, Estonian market participants filed complaints against the TSOs’ invoking of force majeure. When processing these complaints and investigating whether a violation in the activities of Elering AS occurred, the Estonian regulatory authority, Konkurentsiamet, encountered difficulties with the application of the requirements under Title II, Chapter 6 of the FCA Regulation and provisions in the harmonised allocation rules (HAR) adopted in accordance with Articles 51 and 52 of the FCA Regulation.

text: 2. LEGAL CONTEXT

text: (3) The FCA Regulation lays down rules on the firmness of allocated cross-zonal capacity in the forward markets.

text: (4) Article 53 of the FCA Regulation states under paragraph (1) that ‘All TSOs shall be entitled to curtail long-term transmission rights to ensure operation remains within operational security limits prior to the day-ahead firmness deadline. …’ Paragraph (2) of the same article further clarifies that ‘The concerned TSOs on the bidding zone border where long-term transmission rights have been curtailed shall compensate the holders of curtailed long-term transmission rights with the market spread.’

text: (5) Article 56 of the FCA Regulation states under paragraph (1) that ‘In the event of force majeure, TSOs may curtail long-term transmission rights. …’ Paragraph (3) of that article specifies that ‘In the event of curtailment due to force majeure the concerned holders of long-term transmission rights shall receive compensation for the period of that force majeure by the TSO which invoked the force majeure. In this case, the compensation shall be equal to the amount initially paid for the concerned long-term transmission right during the forward allocation process.’ Paragraph 4 of the same article states that ‘The TSO which invokes a force majeure shall make every possible effort to limit the consequences and duration of the force majeure.’

text: (6) Article 54 of the FCA Regulation addresses the possible definitions of caps for the compensation of curtailed LTTRs. More specifically, paragraph (1) of that article states that ‘The concerned TSOs on a bidding zone border may propose a cap on the total compensation to be paid to all holders of curtailed long-term transmission rights in the relevant calendar year or the relevant calendar month in case of Direct Current interconnectors.’ Paragraph (2) of the same article states that ‘The cap shall not be lower than the total amount of congestion income collected by the concerned TSOs on the bidding zone border in the relevant calendar year. In case of Direct Current interconnectors, TSOs may propose a cap not lower than the total congestion income collected by the concerned TSOs on the bidding zone border in the relevant calendar month.’

text: (7) Pursuant to

text: Article 52(2)

text: (k) of the FCA Regulation, the HAR ‘shall follow the principles of non-discrimination and transparency and at least contain the provisions

text: on firmness and compensation rules pursuant to

text: Article 53

text: and

text: Article 55

text: .’ ACER Decision no. 18/2023 approved the latest version of the HAR as set out in Annex I of that decision.

text: Article 2(2)

text: (u) of the HAR , defines force majeure in line with Article 2(45) of the CACM Regulation, which is also applicable for the FCA Regulation pursuant to its

text: Article 2

text: , as follows: ‘force majeure’ means any unforeseeable or unusual event or situation beyond the reasonable control of a party and/or the relevant TSOs, and not due to a fault of the party and/or the relevant TSOs, which cannot be avoided or overcome with reasonable foresight and diligence, which cannot be solved by measures which are from a technical, financial or economic point of view reasonably possible for the party and/or the relevant TSOs, which has actually happened and is objectively verifiable, and which makes it impossible for the party and/or the relevant TSOs to fulfil, temporarily or permanently, its obligations’.

text: 3. DIFFICULTIES WITH THE APPLICATION OF THE FCA REGULATION

text: (8) The difficulties described by Konkurentsiamet can be summarised as follows:

text: (9) The FI-EE bidding zone border comprises two HVDC cables: ˗ Estlink1 with 358 MW capacity, and ˗ Estlink2 with 658 MW capacity.

text: (10) As defined in the methodology for the regional design of LTTRs for the Baltic capacity calculation region (‘CCR’) in accordance with Article 31 of the FCA Regulation, LTTRs are issued for the monthly and yearly timeframe in the form of financial transmission rights (‘FTRs’) options on the FI-EE bidding zone border.

text: (11) On 25 December 2024, a ship’s anchor damaged the submarine HVDC cable Estlink2 on the FI-EE bidding zone border.

text: (12) At the time of the incident, the FTRs which were allocated via the single allocation platform for the FI-EE bidding zone border accounted for: ˗ 350 MW from the yearly allocations for 2024 and 2025, and ˗ further 300 MW provided by TSOs for the monthly allocation for December 2024 and January 2025.

text: (13) As specified in the unavailability notice , the Estlink2 cable is expected to be unavailable until end of July 2025. Until then the available interconnector capacity on the FI-EE bidding zone border will be limited to 358 MW.

text: (14) From 26 December 2024 until 30 January 2025, the single allocation platform published daily messages for the curtailment of FTRs on the FI-EE bidding zone border from 650 MW allocated to between 337 and 342 MW due to force majeure for the period from 27 December 2024 until 31 January 2025.

text: (15) Following the curtailment by the TSOs due to force majeure, Estonian market participants filed complaints with Konkurentsiamet against the TSO’s decision to invoke force majeure as ground for the curtailment of FTRs, since in the view of these market participants the required preconditions for a force majeure event had not been met.

text: (16) Konkurentsiamet explained to ACER that they are processing the complaints and, as a result of these proceedings, if the Konkurentsiamet identifies a violation in the activities of the TSO, Konkurentsiamet has the right to issue a precept to the TSO to eliminate the violation. Konkurentsiamet further clarified that, since in this case the complainants also aim to obtain certain financial compensation from the TSO, the respective claims are subject to resolution through negotiations between the parties and, if no agreement is reached, to a ruling in civil court proceedings.

text: (17) When processing the market participants’ complaints, Konkurentsiamet encountered difficulties with the application of Articles

text: , and 56 of the FCA Regulation, as well as Articles

text: , and 60 of the HAR. In this context, it is not clear to Konkurentsiamet whether the TSOs’ obligation towards allocated FTRs is physical or financial, and what TSOs should take into consideration when curtailing already allocated FTRs and invoking force majeure as a reason for this FTRs’ curtailment.

text: 4. THE REQUEST

text: (18) Konkurentsiamet requested ACER’s opinion on the abovementioned difficulties with the application of Articles

text: , and 60 of the HAR and specifically asked the following questions:

text: (19) Question 1: Should the amounts of already allocated FTRs be directly dependent from the value of net transfer capacity between the bidding zones, considering the particular situation and the definition of operational security limits in

text: Commission Regulation (EU) 2017/1485 of 2 August 2017

text: establishing a guideline on electricity transmission system operation ? Also, if the TSOs are not deliberately limiting net transfer capacity (of cross-border connection) to ensure the system operates within security limits from

text: a physical characteristics perspective, but a certain amount of cross-border net transfer capacity is unavailable due to reasons beyond the TSOs’ control, particularly due to the occurrence of “an unforeseeable or unusual event or situation beyond the reasonable control of the relevant TSOs, which cannot be avoided”, then, in such a case, are the TSOs even permitted to invoke the clause "to ensure operation remains within operational security limits" for curtailing FTRs?

text: (20) Question 2: If the value of net transfer capacity between bidding zones were to significantly decrease due to occurrence of “an unforeseeable or unusual event or situation beyond the reasonable control of the relevant TSOs, which cannot be avoided”, would then occurrence of such an event provide sufficient cause for TSOs for curtailing the amounts of already allocated FTRs with reference to a force majeure event?

text: (21) Question 3: Alternatively, if the FTRs are purely financial instruments, can then mere occurrence of “an unforeseeable or unusual event or situation beyond the reasonable control of the relevant TSOs, which cannot be avoided”, which results in significant reduction of net transfer capacity between bidding zones, provide sufficient cause for TSOs to curtail already allocated FTRs with reference to a force majeure event, unless the TSOs have exhausted a cap on compensations which is applicable in accordance with Article 59 (3) of the HAR?

text: 5. PROCEDURE

text: (22) On 28 January 2025, ACER received the request of Konkurentsiamet for an opinion, according to

text: , on the application of the FCA Regulation concerning the curtailment of LTTRs on the FI-EE bidding zone border and the interpretation of force majeure provisions.

text: (23) Between 28 January 2025 and 18 March 2025, ACER engaged in discussions with the European Commission and the regulatory authorities. These interactions focused in particular on:

text: (a) Possibilities for curtailing LTTRs on the FI-EE bidding zone border and requirements for invoking force majeure; and

text: (b) Clarifications concerning the specific case for which Konkurentsiamet requests ACER’s opinion.

text: (24) On 10 March 2025, the draft of an opinion replying to the present request of Konkurentsiamet was submitted to the AEWG for consultation. In its advice of 18 March 2025, the AEWG broadly endorsed the draft ACER opinion and invited ACER to:

text: ˗ to clarify the reasoning regarding ACER’s competency in this case and the necessity to issue an opinion, ˗ to reflect in more detail the relation between FTRs and the compensation cap, and

text: ˗ to clearly differentiate between specific findings related to the respective FI-EE case and general conclusions.

text: (25) The AEWG advice also included individual comments from the regulatory authorities of Finland, Austria, France and Germany concerning: ˗ the mandate for regulatory authorities or ACER to assess whether an event qualifies as force majeure; ˗ the suggestion to clarify whether the event qualifies as force majeure or not and an opinion for a possible conclusion; ˗ views on what could be considered as a TSOs’ impossibility to fulfil the financial obligation to remunerate FTRs with the day-ahead market spread; ˗ application of the cap in the event of force majeure; and ˗ the possibility for TSOs to curtail FTRs on the FI-EE bidding zone border to ensure operation remains within operational security limits based on Article 57(7) of the HAR and the regional HAR annex for the Baltic CCR .

text: (26) ACER consulted with the European Commission based on draft opinion as submitted for AEWG’s advice in accordance with the requirement pursuant to

text: 6. ASSESSMENT

text: ACER’s competence to deliver this opinion

text: (28) According to

text: where, in a specific case, a regulatory authority encounters difficulties with the application of the network codes and guidelines referred to in

text: Regulation (EU) 2019/943

text: , it may request ACER to provide an opinion. ACER shall deliver its opinion, after consulting the Commission, within three months of the date of receipt of such a request.

text: (29) From the information provided by Konkurentsiamet (see Rectial (16)) it is apparent that Konkurentsiamet is not assessing whether the event qualifies as force majeure following a request from the TSO under Article 56(5) of the FCA Regulation . Instead, ACER understands that Konkurentsiamet is processing a specific case, due to complaints raised by market participants, which falls under their duties as a regulatory authority to ensure the compliance of their TSO with the FCA Regulation in accordance with

text: Article 59(1)

text: (b) of

text: Directive (EU) 2019/944

text: (30) ACER therefore understands that Konkurentsiamet is entitled to request ACER to provide an opinion under Article 6(7) of Regulation 2019/942 on the application of the FCA Regulation and the HAR as adopted in accordance with Articles 51 and 52 of the FCA Regulation, and that ACER is therefore required to provide such opinion.

text: (31) For the avoidance of doubt, ACER would like to clarify that with this opinion ACER is only providing answers to the questions raised by the Konkurentsiamet’s on the difficulties with applying the requirements of the FCA Regulation for their specific case, but does not provide an assessment of the actions taken by TSOs or a conclusion on whether the relevant event qualifies as force majeure or not. Considering the feedback received in the AEWG advice and to more clearly limit the opinion to the questions raised by Konkurentsiamet, ACER deleted parts of Recital (49) from the draft opinion shared with AEWG for advice.

text: Curtailment to ensure operational security (Question 1)

text: (32) The amount of cross-zonal capacity to be allocated in the long-term timeframe as LTTRs should be limited by the amount calculated in accordance with the capacity calculation methodology pursuant to Article 10 of the FCA Regulation and further defined by the methodology for splitting of long-term cross-zonal capacity in accordance with Article 16 of the FCA Regulation. After this cross-zonal capacity has been allocated via the single allocation platform, the firmness provisions defined under Title II, Chapter 6 of the FCA Regulation apply. Following an unplanned outage, Article 53(1) of the FCA Regulation allows TSOs to curtail LTTRs in order to ensure operation remains within operational security limits.

text: (33) In case LTTRs are curtailed to ensure operational security according to Article 53(1) of the FCA Regulation specific compensation rules, including any defined cap, under Articles 53 and 54 of the FCA Regulation and as further specified in the HAR would become applicable. A precondition for applying these compensation rules and any defined cap is thus that the LTTRs have been curtailed. ACER therefore understands that the conditions for curtailment must be met in the first place, and any right for TSOs to curtail LTTRs cannot be inferred from the introduction of a cap on the FI-EE bidding zone border. Furthermore, in ACER’s view, curtailment cannot be based on Article 57(7) of the HAR, as this provision merely clarifies that the compensation rules for curtailed LTTRs apply if offered day-ahead cross zonal capacities are lower than allocated LTTRs. Besides curtailment for operational security reasons, the FCA Regulation only allows for curtailment prior to the day-ahead firmness deadline in case of force majeure pursuant to Article 56(1) of the FCA Regulation, but not for any other reasons.

text: (34) For long-term cross-zonal capacity allocation which takes place after an unplanned outage, the outage should be considered in the capacity calculation process and subsequently limits the amount of LTTRs allocated to the available cross-zonal capacity on the relevant bidding zone border (e.g. as done when allocating LTTRs on the FI-EE bidding zone border for February 2025).

text: (35) The LTTRs on the FI-EE bidding zone border are allocated in the form of financial transmission rights options (FTR options). In accordance with Article 33 of the FCA Regulation, such FTR options cannot be physically nominated by the LTTR holders, but the holders are only entitled to obtain financial remuneration from TSOs equal to the day-ahead market spread pursuant to Article 35 of the FCA Regulation. Therefore, ACER understands that the TSOs’ obligations from FTRs are only of financial and

text: not of a physical nature. This means that in principle an allocation of FTRs lead to the financial obligation for the TSOs to remunerate the FTR holders with the day-ahead market spread, but the FTR holder does not have a possibility to use the FTRs in a way which could impact a TSOs’ physical operation of the transmission grid. Considering this lack of physical attributes of the FTR options on the FI-EE bidding zone border, by default those FTR options cannot have a physical impact which could endanger operational security limits.

text: (36) Further, ACER understands that the allocation of FTRs on the FI-EE bidding zone border has no possible physical impact through the day-ahead capacity calculation process since the day-ahead capacity calculation methodology pursuant to

text: Article 20(2) of Commission Regulation (EU) 2015/1222 of 24 July 2015

text: establishing a guideline on capacity allocation and congestion management (‘CACM Regulation’) for the Baltic CCR does not consider previously allocated LTTRs in any way. The day-ahead capacity calculation process, where an outage is taken into consideration, may result in coordinated net transmission capacity values for the relevant bidding zone border lower than allocated in the long-term timeframe. Regardless of the outcome of the capacity calculation, the firmness of LTTRs is subject to the requirements defined under Title II, Chapter 6 of the FCA Regulation. Hence, as stated in Rectial (32), LTTRs may only be curtailed prior to the day-ahead firmness deadline to ensure operational security (Article 53(1) of the FCA Regulation) or in the case of force majeure (Article 56(1) of the FCA Regulation).

text: (37) ACER did not identify a possible physical impact of FTR options on the FI-EE bidding zone border due to the purely financial nature of FTRs or any other possible physical impacts from FTRs for this bidding zone border on the operation of the transmission grid. Therefore, ACER is of the opinion that FTRs on the FI-EE bidding zone border should not be curtailed for the purpose of ensuring that operation remains within operational security limits prior to the day-ahead firmness deadline in accordance with Article 53 of the FCA Regulation.

text: Conditions for invoking force majeure (Question 2)

text: (38) Article 56(1) of the FCA Regulation provides that the TSOs may curtail LTTRs in the event of force majeure. Article 2 of the FCA Regulation provides that the definitions of the CACM Regulation are also applicable for the purpose of the FCA Regulation. Article 2(45) of the CACM Regulation contains a definition of force majeure which corresponds in essence to the definition included in

text: Article 2(2)

text: (u) of the HAR.

text: (39) In its request for an opinion, Konkurentsiamet referred to the definition of force majeure in

text: Article 2(2)

text: (u) of HAR, broken down into five sub-conditions:

text: (a) any unforeseeable or unusual event or situation beyond the reasonable control of a party and/or the relevant TSOs, and not due to a fault of the party and/or the relevant TSOs,

text: (b) which cannot be avoided or overcome with reasonable foresight and diligence,

text: (c) which cannot be solved by measures which are from a technical, financial or economic point of view reasonably possible for the party and/or the relevant TSOs,

text: (d) which has actually happened and is objectively verifiable, and

text: (e) which makes it impossible for the party and/or the relevant TSOs to fulfil, temporarily or permanently, its obligations.

text: (40) Konkurentsiamet’s question 2 (see Recital (18)) asks whether the fulfilment of the first two criteria in the force majeure definition (i.e. Recital (39)(a) and (b)) provides already sufficient cause for a TSO to invoke force majeure.

text: (41) In this regard, ACER understands that the concept of force majeure and its meaning must be determined by reference to the legal context in which it is to operate and that force majeure constitutes an exemption situation and therefore should be applied restrictively. The definition of force majeure provided in

text: Article 2(2)

text: (u) of the HAR sets out the distinct cumulative conditions that each must be satisfied for an event to qualify as force majeure. Thus, each condition needs to be assessed and if any of the five conditions are not met, the event cannot be classified as force majeure.

text: (42) Therefore, based on the force majeure definition, ACER understands that when TSOs invoke force majeure, they must demonstrate that the relevant situation fulfils all conditions. This also includes the requirement, as specifically pointed to by Konkurentsiamet, that the situation is making it impossible for the TSO to fulfil temporarily or permanently, its obligations.

text: (43) Konkurentsiamet described the event as the submarine cable Estlink2 being damaged by a ship’s anchor resulting in its operational failure. In general, such event is impacting the TSOs’ physical operation of the transmission grid, which needs to be done in accordance with the relevant requirements for maintaining operational security. Furthermore, this event limited the available cross-zonal capacity to be allocated in the day-ahead timeframe and therefore reduced the day-ahead congestion income generated at that bidding zone border. The remuneration of LTTRs on that bidding zone border relates to the day-ahead market spread on the relevant bidding zone border, which is also reflected in the day-ahead congestion income on that bidding zone border. Day-ahead congestion income of a bidding zone border can therefore be directly used by TSOs to remunerate LTTRs. If TSOs allocated a higher amount of cross-zonal capacity in the long-term timeframe than what they have available in the day-ahead timeframe, revenue adequacy for remunerating LTTRs with generated day-ahead congestion income can no longer be provided (e.g. TSOs will face a financial loss for the cross-zonal capacity volumes which are not available in day-ahead if the day-ahead market spread is higher than the LTTR price).

text: (44) While the TSOs’ obligations from FTR options on the FI-EE bidding zone border do relate to the event in a financial sense, the conclusions in section 6.16.2 above clarify that the allocated FTR options on the FI-EE bidding zone border do not imply a possible physical impact on the TSOs’ operation. The relevant obligation for TSOs related to FTR options on the FI-EE bidding zone border and the definition of force majeure in

text: Article 2(2)

text: (u) of the HAR is thus the obligation to remunerate the FTR holders with the market spread in accordance with

text: Article 35(3)

text: (a) of the FCA Regulation. In this regard it is to note that, as stated in Article 56 of the HAR, in case of curtailment of the FTRs due to force majeure before the day-ahead firmness deadline the holders of those FTRs lose their right to receive such remuneration. Instead, the FTR holders are entitled to receive reimbursement in accordance with Article 56(3) of the FCA Regulation and Article 60 of the HAR.

text: (45) Therefore, the situation of reduced available cross-zonal capacity on the FI-EE bidding zone border and already allocated FTRs on that bidding zone border impacts only the TSOs’ financial ability to remunerate the holders of FTRs. In such case, for invoking force majeure as a justification to curtail FTRs, TSOs would need to consider whether the event has a financial impact that makes it impossible for the TSOs to temporarily or permanently fulfil their obligations.

text: Consideration of the cap on the compensation of LTTRs in the event of force majeure (Question 3)

text: (46) The cap for the compensation of LTTRs in accordance with Article 54 of the FCA Regulation may be used to limit the total compensation to be paid to all holders of curtailed LTTRs to the total congestion income collected by the TSO on the relevant bidding zone border.

text: (47) Article 59 of the HAR further specifies that such cap should consider the congestion income of the long-term, day-ahead and intraday timeframes and the remuneration of LTTRs under normal circumstances as well as compensation of curtailed LTTRs. As specified in Article 59(3) of the HAR and Article 4(2) of the regional HAR annex for the Baltic CCR pursuant to Article 52 of the FCA Regulation, a monthly cap for the compensation of curtailed LTTRs is established for the FI-EE bidding zone border.

text: (48) The cap under Article 59 of the HAR relates to compensation for curtailments to ensure that operation remains within operational security limits. Further, as specified under Article 60 of the HAR, reimbursement for curtailments due to force majeure before the day ahead firmness deadline does not consider the cap but should be calculated based on the marginal price from the initial LTTR auction or the weighted average of marginal prices of all the auctions. Considering that, as concluded in Section 6.2, the curtailment for maintaining operational security does not seem feasible for FTRs on the FI-EE bidding zone border, the cap would not become effective.

text: (49) However, in ACER’s opinion, the status of a cap as defined pursuant to Article 54 of the FCA Regulation could still serve as one of several factors that could be taken into

text: account for considering the TSOs’ financial means to fulfil its obligation of remunerating FTR options for the FI-EE bidding zone border,

text: HAS ADOPTED THIS OPINION:

text: Regulation (EU) 2016/1719

text: can be interpreted to the following effect:

text: 1. TSOs may curtail long-term transmission rights pursuant to

text: Article 53(1) of Regulation (EU) 2016/1719

text: , only if the allocated long-term transmission rights would endanger that operation of the transmission grid remains within operational security limits prior to the day-ahead firmness deadline. Since financial transmission rights on the FI-EE bidding zone border cannot have an impact on operational security, they should not be curtailed pursuant to

text: 2. TSOs should not invoke force majeure unless all conditions specified in the definition of force majeure pursuant to

text: Article 2(2)

text: (u) of the harmonised allocation rules pursuant to

text: Article 51 of Regulation (EU) 2016/1719

text: are met.

text: 3. The cap on the total compensation to be paid to all holders of curtailed long-term transmission rights applies only to the compensation for curtailments to ensure that operation remains within operational security limits before the day ahead firmness deadline in accordance with Article 59 of the harmonised allocation rules pursuant to

text: Article 51 of Regulation (EU) 2016/1719

text: . This cap does not apply to curtailments due to force majeure before the day ahead firmness deadline in accordance with Article 60 of the harmonised allocation rules pursuant to

text: Article 51 of Regulation (EU) 2016/1719

text: . Since financial transmission rights on the FI-EE bidding zone border should not be curtailed for operational security reasons in accordance with

text: , a cap should not be applicable for that bidding zone border.

text: This Opinion is addressed to the regulatory authority of Estonia, Konkurentsiamet.

text: Done at Ljubljana, on 9 April 2025.

text: - SIGNED -

text: Fоr the Agency The Director

text: C. ZINGLERSEN

type: vagledning

utgivare: acer


text: ENTSOG is mandated to assess European gas supply adequacy, evaluating the overall capability of the natural gas system to meet current and anticipated demand. However, this assessment is part of a different ENTSOG’s deliverable – the Union-wide Ten-Year Network Development Plan (TYNDP) for natural gas – which is published every two years in accordance with

text: Article 26(3)

text: (b) of

text: Regulation (EU) 2024/1789

text: . The two-year interval between consecutive TYNDPs does not allow for sufficiently frequent monitoring of rapid developments in gas supply, particularly due to the stepwise phase-out of Russian gas imports – covering both LNG and pipeline gas – with a full ban taking effect in early 2026 and in autumn 2027 respectively. 2 A gas pipeline from Norway to Germany. 3 EU gas demand is projected to decline, according to ACER 2025 Monitoring Report on Analysis of the European LNG market developments (Fit-for-55 scenario). 4 As per ACER 2025 Monitoring Report on Security of EU electricity supply. As per ACER 2025 Monitoring Report on Capacity use and booking trends in European natural gas markets.

text: The global LNG market gained liquidity in the last decade with the share of destination-free contracts of 45% in 2024 according to IEA Gas 2025 fuel report on Analysis and forecasts to 2030. 7 About half LNG supply contracts to Europe in 2025 have fixed destination according to ACER 2025 Monitoring Report on Analysis of the European LNG market developments. 8 ENTSOG may have established an overall gas supply priority order to some extent, but this is not described in the Outlook.

identifier: ACER Opinion No 02/2026

title: ACER Opinion 02-2026 on ENTSOG's Winter Supply Outlook 2025/26

text: No 02/2026

text: OPINION

text: on the ENTSOG Winter Supply Outlook 2025/26

text: 11 February 2026

text: A C E R O P I N I O N N O 0 2 / 2 0 2 6

text: Executive summary

text: 1 The EU’s provisional agreement on stepwise phasing out Russian gas imports – reached by the Council and the European Parliament – marks a strategic shift towards a European energy system that is more secure and independent from Russia. In this context, ENTSOG’s Winter Supply Outlook 2025/26 provides an updated view of Europe’s infrastructure readiness to manage gas flows for the coming winter season. Despite the storage levels starting this winter at 83% (943 TWh), lower than the previous year (94%, 1082 TWh), ENTSOG’s reference scenario indicates that the EU gas infrastructure can distribute gas effectively while maintaining storage above 30% by the end of winter, even in case of full disruption of the remaining Russian pipeline supply via TurkStream.

text: 2 ACER welcomes ENTSOG’s comprehensive stress-testing of the gas infrastructure and the inclusion of new facilities and updated maintenance patterns. Regarding supply assumptions, ACER appreciates the explicit integration of the Russian gas phase-out. However, ACER recommends refining the liquefied natural gas (LNG) modelling approach. In particular, instead of capping the LNG supply at historical levels, the maximum LNG supply could be based on the available regasification capacity and the global pool of destination-free LNG cargoes that could be redirected to Europe in periods of high-demand. This, in turn, requires more granular supply modelling, including the dispatch order of LNG cargos and their interaction with demand-side response.

text: 3 ACER also suggests that looking ahead the methodology should evolve to complement infrastructure stress-testing with realistic cross-sectoral demand projections and credible supplymolecule adequacy assessments, while providing greater transparency on flows at gas entry points. This reflects the legal requirement for supply outlooks as well as geopolitical developments which have an impact on EU’s supply risks. As Russian imports are phased out entirely – by early 2026 (LNG) and autumn 2027 (pipeline gas) – the EU’s supply risks will increasingly depend on global LNG market dynamics rather than on the internal gas infrastructure bottlenecks, which tend to occur only under extreme conditions, such as a cold winter combined with a major supply disruption.

text: 4 The rapid pace of geopolitical change and market development calls for continuous gas supply adequacy monitoring to ensure that the EU’s gas system remains resilient throughout the transition to full independence from Russian gas. A C E R O P I N I O N N O 0 2 / 2 0 2 6

text: 1. Background

text: 5 On 9 October 2025, the European Network of Transmission System Operators for Gas (ENTSOG) adopted its Winter Supply Outlook 2025/26 pursuant to Article 26(3)(g) of

text: Regulation (EU) 2024/1789

text: . Under

text: Article 4(3)

text: (b) of

text: Regulation (EU) 2019/942

text: , ACER may issue an opinion on ENTSOG’s winter and summer supply outlooks, taking into account the objectives of nondiscrimination, effective competition and the proper and secure functioning of the internal market for natural gas.

text: 6 To date, the outlooks have primarily focussed on testing the ability of the European gas infrastructure to cope with different fixed supply, demand and disruption scenarios. While supply adequacy analysis is less in the focus. In its previous opinion (No 06/2025), ACER advocated a more market-oriented approach to modelling liquefied natural gas (LNG) supply and gas demand response. Considering the new Outlook, this Opinion reiterates ACER’s past recommendations that have not yet been implemented by ENTSOG.

text: 7 This Opinion concerns the Winter Supply Outlook 2025/26 (the Outlook) and is issued pursuant to

text: Article 4(3)

text: (b) of

text: Regulation (EU) 2019/942

text: and

text: Article 26(3)

text: (g) of

text: Regulation (EU) 2024/1789

text: . It is addressed to ENTSOG.

text: 2. Procedure

text: 8 ACER’s Gas Working Group provided its advice on 14 January 2026.

text: 3. Summary of the Outlook

text: 10 The Outlook assesses the ability of European gas infrastructure to cope with the upcoming winter season under different scenarios. Although storage levels on 1 October 2025 were lower than last year – 83% (943 TWh) compared to 94% (1082 TWh) – the reference supply-demand scenario indicates that the infrastructure can distribute gas effectively while maintaining storage levels above 30% at the end of the winter season (31 March 2026), even in the event of a full disruption of TurkStream (Russian) pipeline supply.

text: 11 In terms of the applied methodology, the current Outlook does not introduce major methodological changes or new modelling assumptions to the reference scenario compared with the previous edition.

text: 4. ACER’s assessment

text: 12 Regulation 2024/1789 requires ENTSOG to adopt seasonal outlooks.

text: Article 26(3)

text: (g) explicitly refers to supply outlooks. However, the Outlook does not provide a fully developed assessment of the gas supply side. A C E R O P I N I O N N O 0 2 / 2 0 2 6

text: 13 Implementing ACER’s recommendations presented below would allow for a more comprehensive consideration of both gas supply and demand dynamics in the seasonal outlooks.

text: 14 Infrastructure: ACER welcomes ENTSOG’s comprehensive testing of gas infrastructure under a wide range of cold winter demand scenarios, supply disruptions, and Europipe II fault. Continuous modelling updates, including newly commissioned facilities and infrastructure maintenance plans, are also well appreciated.

text: 15 The assumption of international cooperation further strengthens the optimised use of the existing infrastructure, while cooperation among EU Member States typically becomes relevant only in emergency situations. Greater transparency would be achieved by explaining the impact of this assumption on the results, e.g. by indicating at which stage cooperation among the EU Member States becomes a necessity to ensure that supply can meet demand in Europe at each entry point.

text: 16 ACER recommends ensuring greater transparency in the assumptions underlying the free-flow modelling approach, e.g. by showing regional dependency on gas entry points of the European gas infrastructure.

text: 17 Demand: The reference winter gas demand volume is based on a TSO estimate, which is slightly higher compared to last winter (+4%).

text: 18 ACER recommends using more realistic reference demand assumptions – reflecting the expected decline in demand and considering cross-sectoral energy trends. Recently, the gas demand has shown a declining trend year on year. Looking ahead, the electricity sector currently accounts for roughly one-third of the EU gas demand, and this share is expected to decline moderately by 2030 due to increased renewable deployment . ENTSO-E also publishes seasonal assessments of gas needs for power generation, which could support more coherent reference scenario building.

text: 19 Supply: ACER welcomes the Outlook’s alignment with the phase-out roadmap of Russian gas supply and its modelling of Russian pipeline deliveries through TurkStream either as a last-resort source or as fully disrupted.

text: 20 The sharp reduction in Russian supply since 2022 has been largely offset by increased LNG imports, which now cover roughly 40% of EU gas demand . The United States delivers the highest volumes of LNG to the EU, accounting for 60% of LNG imports in the third quarter of 2025 and resulting in a strong dependency for the EU. ENTSOG highlights access to adequate LNG supply as a key factor for European gas security. The Outlook’s `low-LNG supply` sensitivity analysis shows that insufficient LNG imports could lead to storage depletion by the end of winter, potentially requiring demand response measures to avoid shortfalls. This underscores the need A C E R O P I N I O N N O 0 2 / 2 0 2 6 to secure adequate LNG volumes, particularly under cold winter conditions or in the event of a major supply disruption.

text: 21 ACER recommends capping LNG supply at a level of (i) the European LNG terminal regasification and network capacities (the high-LNG scenario); and (ii) global LNG volumes under 6 7 destination-free contracts , in addition to fixed-destination EU contracts . ACER recommends that this approach is considered as an input to a more refined supply-modelling methodology, as it reflects the global liquidity of LNG and the ability to redirect cargos to the highest-value market.

text: 22 Market: The LNG supply dependency could be examined by only capping the EU LNG imports at the level of available regasification infrastructure capacity (the high-LNG scenario). Modelling results under this setup would indicate the maximum volumes of LNG that can be utilised. These volumes can then be analysed from a supply-adequacy perspective by comparing them with destination-free LNG volumes available on the global LNG market and with overall technical LNG availability, while also accounting for potential operational constraints, e.g. adverse sea conditions, that may delay LNG cargos.

text: 23 Removing the fixed LNG supply scenarios (low, reference, high) and allowing the global LNG supply to respond to the scenario conditions (e.g. higher demand due to cold winter) would render the analysis more realistic. This change would allow the Outlook to focus on potential supply adequacy risks under extreme scenarios (stress test) such as cold winters and/or pipeline disruptions.

text: 24 ACER recommends simulating how the gas market would behave under various modelled scenarios, e.g., by ordering gas supply routes and volumes by their typical dispatch merit order.

text: 25 In practice, LNG is usually more expensive. Thus, it would be added to the supply mix after cheaper pipeline gas. Within each type of supply, additional volumes would cost more, reflecting how prices have behaved in the past . When supply becomes tight, demand response to increasing marginal sourcing prices could also be included as a possible reaction.

text: 26 The current omission of demand response leads to an early demand curtailment to keep demand and supply balanced under extreme circumstances. This effect is further amplified by the application of curtailment prior to the use of strategic reserves in Europe, as about 11% of the gas storage in Europe remains unavailable in the Outlook.

text: 27 ACER recommends reviewing the methodology underpinning the outlooks, considering experience accumulated so far and ACER`s recommendations. As EU gas infrastructure has matured and enabled substantial shifts in gas flows from east to west, more attention should be placed on global LNG supply availability for Europe. Complementing infrastructure stress testing with assessments of gas-molecule adequacy would address an emerging challenge: potential supply shortages due to the current market and geopolitical environment.

text: 5. Conclusions

text: 28 ACER welcomes ENTSOG’s continued monitoring of the EU gas infrastructure readiness for the coming season, under both reference and extreme conditions (cold winter, supply disruption). A C E R O P I N I O N N O 0 2 / 2 0 2 6

text: 29 The Outlook is broadly consistent with the objectives of non-discrimination, effective competition, and the proper and secure functioning of the internal natural gas market. ACER urges ENTSOG to implement the recommendations outlined in Section 4 of this Opinion. This Opinion is addressed to ENTSOG. Done at Ljubljana, on 11 February 2026. — SIGNED — V. ZULEGER, ACER Director ad interim


text: Please click on the icon to take a 5’ online survey and provide your feedback about this document

identifier: ACER Opinion No 03/2011

title: ACER Opinion 03-2011 on ENTSO-E Work Programme 2011-2012

text: Publishing date: 30/05/2012

text: Document title:

text: We appreciate your feedback

text: Publishing date: 30/05/2012

text: Document title:

text: We appreciate your feedback


identifier: ACER Opinion No 03/2012

title: ACER Opinion 03-2012 on the ENTSO-E Annual Report 2011

text: Publishing date: 05/06/2012 Document title: ACER Opinion 03-2012

text: We appreciate your feedback

text: We appreciate your feedback


identifier: ACER Opinion No 03/2013

title: ACER Opinion 03-2013 on ENTSOG's Annual Winter Supply Outlook 2012-13

text: Publishing date: 15/02/2013

text: Document title:

text: We appreciate your feedback

text: Publishing date: 15/02/2013

text: Document title:

text: We appreciate your feedback


identifier: ACER Opinion No 03/2014

title: ACER Opinion 03-2014 on the Proposal for Operation of the ENTSO-E Central Information Transparency Platform

text: Publishing date: 05/02/2014

text: Document title:

text: We appreciate your feedback

text: Publishing date: 05/02/2014

text: Document title:

text: We appreciate your feedback


identifier: ACER Opinion No 03/2015

title: ACER Opinion 03-2015 on the Compliance of the Decision of National Commission for Energy Control and Prices of the Republic of Lithuania

text: Publishing date: 13/07/2015 Document title: ACER Opinion on the Compliance of the Decision of NCC

text: We appreciate your feedback

text: We appreciate your feedback


identifier: ACER Opinion No 03/2016

title: ACER Opinion 03-2016 on ENTSO-E Recommendations on Cooperation EU and Third-Country TSOs

text: Publishing date: 21/03/2016 Document title: on ENTSO-E Recommendations on Cooperation EU and thirdcountry TSOs

text: We appreciate your feedback

text: We appreciate your feedback


identifier: ACER Opinion No 03/2017

title: ACER Opinion 03-2017 on the ENTSO-E Winter Outlook Report 2016/2017 and Summer Review 2016


identifier: ACER Opinion No 03/2018

title: ACER Opinion 03-2018 on the Application of Articles 5 and 141-2 of the Commission Regulation Establishing a Guideline on Electricity Transmission System Operation


identifier: ACER Opinion No 03/2019

title: ACER Opinion 03-2019 on ENTSOG's Winter Supply Outlook 2018-2019


identifier: ACER Opinion No 03/2020

title: ACER Opinion 03-2020 on ENTSO-E Guideline for Cost-Benefit Analysis