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

text: Agency for the Cooperation of Energy Regulators TrgRepublike 3 1000 Ljubljana, Slovenia

text: Directive

text: . European Commission, Proposal for a Regulation of the European Parliament and of the Council on guidelines for trans-European energy infrastructure and repealing Decision No

text: , Brussels, 19.10.2011, COM(2011) 658 final. http://eurlex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2011:0658:FIN:EN:PDF 4/18

text: ENTSO-E, “ENTSO-E consultation process - 2011 Edition”, 28 June 2011. https://www.entsoe.eu/fileadmin/user_upload/_library/consultations/110628_Consultation_Process_De scription.pdf ENTSO-E, “ENTSO-E public consultation on background scenarios for the next TYNDP - Summary and assessment of stakeholders’ comments” www.entsoe.eu/fileadmin/user_upload/_library/consultations/SOAF_2011_Scenarios_Consultation_An swers.pdf ENTSO-E, “TYNDP public consultation report on received comments”, 10 July 2011. www.entsoe.eu/fileadmin/user_upload/_library/SDC/TYNDP/2012/120705_TYNDP_- _Report_on_consultation_FINAL.pdf ENTSO-E, “TYNDP and Regional Investment Plans workshop results summary”, 2012. www.entsoe.eu/fileadmin/user_upload/_library/events/Workshops/TYNDP_2012_Regional/120309_w orkshops_summnay_v6.pdf 5/18

text: ENTSO-E, “TYNDP public consultation report on received comments”, 10 July 2011. www.entsoe.eu/fileadmin/user_upload/_library/SDC/TYNDP/2012/120705_TYNDP_- _Report_on_consultation_FINAL.pdf 6/18

text: ENTSO-E, “Inclusion of third party projects in the 2012 release of the TYNDP - A guidance document”, 1 February 2011. www.entsoe.eu/fileadmin/user_upload/_library/SDC/TYNDP/2012/3rd_parties_projects_guidance.pdf 9 Third party projects are projects carried by non-ENTSO-E promoters. The network of ENTSO-E is currently interconnected with the electricity systems of seven non ENTSO-E countries: Albania, Belarus, Moldova, Morocco, Russian Federation, Turkey, Ukraine. In addition, Annex I of the TYNDP includes future interconnections with Algeria and Tunisia. Continental South East regional workshop with stakeholders on “TYNDP & RgIP 2012 methodologies and results”, Zagreb, 12 December 2011. https://www.entsoe.eu/events/tyndp-2012regip/ Continental South East regional workshop with stakeholders on “TYNDP & RgIP 2012 methodologies and results”, Zagreb, 12 December 2011. https://www.entsoe.eu/events/tyndp-2012regip/ 8/18

text: Section 10.4 of the TYNDP. European Commission, Directorate General for Energy. Link: http://ec.europa.eu/energy/infrastructure/tent_e/coordinators_en.htm ENTSO-E, “Study roadmap towards modular development plan on pan-European electricity highways system 2050”, Final version, July 2011. www.entsoe.eu/fileadmin/user_upload/_library/publications/entsoe/MoDPEHS/2011-07- 18_MoDPEHS_StudyRoadmap_final_version_publication.pdf ENTSO-E, “Scenario Outlook and System Adequacy Forecast 2011 – 2025”. Section 4.3 of the ENTSO-E’s SO&AF 2012. 9/18

text: Sections 10.1 and 12.2.3 of the TYNDP. 10/18

text: Annex I of the TYNDP. 16/18

identifier: ACER Opinion No 06/2012

title: ACER Opinion 06-2012 on the ENTSO-E Ten-Year Network Development Plan 2012 including Annex

text: Publishing date: 07/09/2012 Document title: ACER Opinion 06-2012 We appreciate your feedback

text: ACER opinion on the ENTSO-E Ten-Year Network Development Plan 2012

text: Ref: 06/2012 5-September-2012

text: This Document contains the opinion of the Agency for the Cooperation of Energy

text: Regulators (the Agency) on the European Ten-Year Network Development Plan (TYNDP) 2012 published by the European Network of Transmission System

text: Related Documents

text: • ERGEG Opinion on the ENTSO-E Pilot Community-wide Ten-year Electricity Network Development Plan, 7 December 2010, Ref: E10-ENM-22-04. http://www.energyregulators.eu/portal/page/portal/EER_HOME/EER_PUBLICATIONS/CEER_PAPERS/Electricity/2 010/E10-ENM-22-04_TYNDP%20opinion_7-Dec-2010.pdf • Final Advice on the Community-wide-Ten-year Electricity Network Development Plan, 10 June 2010, Ref: E10-ENM-22-03. http://www.energyregulators.eu/portal/page/portal/EER_HOME/EER_PUBLICATIONS/CEER_PAPERS/Electricity/2 010/E10-ENM-22-03_TYNDP%20advice_10-Jun-2010.pdf • Ten Year Network Development Plan, 2012-2022, 5 July 2012, ENTSO-E. https://www.entsoe.eu/fileadmin/user_upload/_library/SDC/TYNDP/2012/120705_TYNDP_2012_ report_FINAL.pdf • Directive

text: of the European Parliament and of the Council of 13 July 2009 concerning common rules for the internal market in electricity and repealing Directive

text: . http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:211:0055:0093:EN:PDF •

text: Regulation (EC) No 713/2009

text: of the European Parliament and of the Council of 13 July2009 establishing an Agency for the Cooperation of Energy Regulators. http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:211:0001:0014:EN:PDF •

text: Regulation (EC) No 714/2009

text: of the European Parliament and of the Council of 13 July2009 on conditions for access to the network for cross-border exchanges in electricity and repealing

text: Regulation (EC) No 1228/2003

text: . http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:211:0015:0035:EN:PDF

text: 1 Scope

text: The main purpose of the Ten-Year Network Development Plan (TYNDP) is to identify investment necessary for facilitating the development of cross-border trade, the integration of renewable energies into the electricity system and for guaranteeing security of supply. The TYNDP must provide a shared vision on the European power system for the foreseeable future and ensure greater transparency with regard to the development of the entire electricity transmission network. It shall include modelling of the integrated network, the development of an EU-wide demand-supply scenario and of a European generation adequacy outlook and an assessment of the resilience of the system. It shall build on national investment plans. When preparing the TYNDP, the European Network of Transmission System Operators for Electricity (ENTSO-E) shall conduct an extensive consultation process, involving all relevant market participants.

text: When forming its opinion, the Agency evaluates each aspect of the TYNDP process and the applied methodology, addressing the following questions in particular: • Has ENTSO-E developed scenarios at EU-wide, regional and national level? • Has modelling of the integrated network been included in the plan? • Has consultation of all relevant stakeholders been conducted by ENTSO-E and has the outcome of these consultations been documented? • Has an assessment of the system resilience been conducted? • Have European, regional and national generation outlooks been prepared and are they consistent with each other? • Is there coherence between national, regional and European TYNDPs?

text: The Agency’s initial analysis of the national TYNDPs according to the provisions of the ‘Third Package’ reveals that in most Member States these are still being developed. Therefore, a consistency assessment of national and Community-wide TYNDPs cannot at this stage be carried out by the Agency.

text: Furthermore, detailed comments on the criteria underlying the cost-benefit analysis are not included in the present opinion as there is ongoing cooperation between the Agency, ENTSO-E and the European Commission on this issue in the context of the preparatory work for the Energy Infrastructure Package (EIP) .

text: The present opinion covers the process adopted by ENTSO-E to support the development of the 2012 TYNDP (Section 2 on stakeholder involvement and Section 3 on other general issues) and the methodology used in the plan (from Section 4 to Section 12, focusing on specific sections and subsections of the 2012 TYNDP). Due to the on-going efforts to

text: develop a sound cost-benefit analysis methodology and due to the fact that national TYNDPs are still being drafted, the Agency cannot yet evaluate the investment needs identified by ENTSO-E in the 2012 TYNDP.

text: 2 Consultation processes and stakeholder involvement

text: ENTSO-E organised the following workshops at EU and regional levels: • a public workshop on scenarios on 10 January 2011; • a stakeholder workshop on assessment of projects of European interest on 15 June 2011; • six regional workshops on regional investment plans (RIPs) at the end of 2011; and • a workshop on the TYNDP package on 28 March 2012.

text: In June 2011 ENTSO-E published a document entailing the principles of ENTSO-E consultation practices .

text: In February/March 2011 ENTSO-E conducted a one-month public consultation on the scenarios. Five responses were received. ENTSO-E provided a summary and an assessment of stakeholders’ comments .

text: From 1 March to 26 April 2012 ENTSO-E held an open public consultation on the “TYNDP 2012 package” i.e. on the community-wide TYNDP report, the six RIPs and the System Outlook and Adequacy Forecast (SO&AF). ENTSO-E kept the Agency informed about bilateral meetings with stakeholders. Despite ENTSO-E’s efforts, stakeholder involvement was low.

text: With regard to provision of stakeholder information and earlier stakeholder involvement in the TYNDP consultation process, the Agency recognises the progress made in the past two years i.e. from the 2010 TYNDP. Nevertheless, early stakeholder consultations did not bear the results to match the importance of the TYNDP process despite ENTSO-E’s increased efforts towards higher stakeholder involvement.

text: As stated in the “TYNDP public consultation report on received comments” , ENTSO-E and the Agency are currently working on identifying the optimal way to further integrate and increase stakeholder participation. Ideas proposed so far include, among others, the setting up of a stakeholder group, as proposed at the workshop of 28 March.

text: Pursuant to

text: Article 10(2) of Regulation (EC) No 714/2009

text: , ENTSO-E should provide minutes from all the individual workshops and not only summaries of multiple workshops . The

text: Agency has no evidence that the minutes from most of the individual workshops have been made public.

text: Furthermore, the Agency deems it necessary that the minutes include comments from stakeholders raised during the workshops in order, firstly, to provide more transparency and, secondly, to report on discussions at regional level. In addition to this, a subsequent clarification should be provided by ENTSO-E on how stakeholder feedback has been taken into account in the TYNDP process.

text: The public consultation on the draft TYNDP was well followed by stakeholders. ENTSO-E received approximately 250 comments from more than 20 stakeholders. On the basis of this public consultation, ENTSO-E updated the final edition of the 2012 TYNDP and published a document detailing all the comments from the public consultation that were taken into account and the main changes introduced in the final edition as follows: • inclusion of illustrative transmission adequacy maps; and • inclusion of approximately 20 additional projects mainly coming from German TSOs.

text: The ENTSO-E’s report on received comments does not clearly illustrate the rationale behind the inclusion of these additional projects, whereas the TYNDP indicates that “the TYNDP package has also been updated with the most recent information related to the German national development plan under consultation. Provisional data was introduced in the draft submitted to consultation and the final TYNDP needed only to be marginally adapted”. The Agency assumes that the purpose of this inclusion is to ensure consistency between the EUwide TYNDP and the German national plan; however the Agency cannot definitely assess the necessity of the inclusion of the additional projects, as this would require further explanations on how the additional projects have been assessed.

text: The Agency recommends that ENTSO-E develops an enhanced approach to stakeholder involvement for the 2014 TYNDP and future plans. The Agency considers it necessary for the envisaged stakeholders’ group to be involved in particular in the following areas: scenario development, definition of the expected level of information provided in the TYNDP and revision of the procedures for the inclusion of third party projects.

text: The Agency expects reports on public consultation, related documents and minutes from the meetings to be made public, and expects visibility on the way in which stakeholders’ feedback in the TYNDP preparation process is taken into account by ENTSO-E.

text: 3 Other general issues on the TYNDP process

text: 3.1 Ensuring transparent information

text: In the TYNDP and in the RIPs a sufficient level of transparency of scenarios, inputs and results is required. Transparency of the selection process of the most economically and technically efficient projects is crucial for stakeholders.

text: The Agency believes that a higher degree of transparency will in turn improve the efficiency in the planning process. Therefore, the TYNDP should merge information from individual market players into appropriate statistics and analyses, providing sufficient level of stakeholder information, while preserving the confidentiality of commercially sensitive information.

text: The TYNDP, and particularly its market studies, provides plenty of information. Stakeholders must have a good understanding of where and when congestions will occur in the next ten years and a clear view of increased capacity needs. This information is given in different forms and levels of detail from one regional plan to another. The Agency appreciates that the form is region-specific to provide clearer and the most relevant information for each region. Nevertheless, a harmonised level of information with regard to market study results should be achieved.

text: Furthermore, since it is difficult to define a fair level of information to be provided to the stakeholders, a compromise has to be found between being exhaustive and understandable, and stakeholders could give their opinion about what they consider as a fair level within the consultation process and the envisaged stakeholders’ group (see section 2.1).

text: The Agency sees room for improvement in explaining and expanding the information supplied in specific sections of the TYNDP. Specific comments are therefore provided in the corresponding sections of this Opinion.

text: 3.2 Data consistency throughout the EU, regional and national levels

text: The current structure of the ENTSO-E regional approach comes under a pan-EU framework and methodology. The Agency acknowledges that when providing information and forecasts to ENTSO-E, this structure relies on the efforts of national TSOs and requires a high level of cooperation.

text: With regard to the TYNDP, TSOs are expected to deliver a minimum level of information to ENTSO-E. Such a minimum level of information is however required to feed in a bottom-up approach, as well as to enable the development of the pan-EU database in support of regional and pan-EU studies. Both, the minimum level and quality of information delivered to ENTSO-E by the TSOs needs to be further unified, which represents an essential step to ensure consistency between national and regional or European plans. The latter can only be achieved through providing sufficient amount of national information and TSOs’ strong cooperation within the ENTSO-E structure.

text: 3.3 Treatment of third party projects

text: The Agency acknowledges ENTSO-E’s efforts from early 2011 in developing a procedure for inclusion of third party projects , in line with which ENTSO-E invited stakeholders to make preliminary contacts. ENTSO-E did not receive any comments from stakeholders on this procedure. Due to this and because none of the five third-party projects having applied for the current TYNDP met the criteria set out by ENTSO-E, none of the projects has been taken into account during the development of the TYNDP and has been included in the table of projects.

text: The Agency emphasises the importance of ensuring equal treatment of TSOs’ and the thirdparty’s projects. For this reason ENTSO-E should allow all third party projects to be included in the future TYNDPs, requiring third party projects to provide the same kind of market and grid studies as TSO projects and to provide sufficient level of detail with regard to capacity levels open to non-discriminatory third-party access. The Agency also encourages dissemination of the procedure to a wider audience to ensure that there is full transparency and stakeholder involvement throughout this process.

text: The Agency recommends ENTSO-E to add in an appendix of future TYNDPs all the third party projects which have applied and to explain how they are treated within the TYNDP.

text: 3.4 Investments involving non-ENTSO-E countries

text: Market and grid modelling of non-ENTSO-E countries has been run on a case-by-case basis depending on cooperation frameworks with these countries. For instance, the Agency observes that such an analysis, elaborated in more detail during a workshop , has been used in the context of the interconnection with Turkey . Hardly any information has however been provided for other non-ENTSO-E countries.

text: It is the Agency’s opinion therefore that the current TYNDP does not sufficiently reflect the level of coordination and cooperation regarding investments in non-ENTSO-E countries which can be of great importance for the grid studies in the ENTSO-E countries.

text: Grid development in non-ENTSO-E countries is an important issue, affecting the prospect of development of interconnections at the border of the ENTSO-E’s system and thus of the integration of areas with high potential of renewable energies.

text: The Agency recommends greater transparency around the cooperation frameworks and enhanced cooperation with non-ENTSO-E countries, in particular to understand the implications beyond 2020 and to provide a complete picture of grid development.

text: 3.5 Cooperation with long-term development initiatives

text: The Agency acknowledges ENTSO-E’s consideration of other prospective development initiatives . The long-term development approaches adopted in the North Seas Countries’ 14 15 Offshore Grid Initiative (NSCOGI) and the Electricity Highways 2050 are complementary with the TYNDP.

text: The links between these long-term development approaches and the TYNDP should be enhanced to ensure consistency in the future TYNDPs and to take advantage of the results and conclusions of these different initiatives.

text: 4 Scenarios

text: Already in the SO&AF 2011 , ENTSO-E provided its plan to deliver the SO&AF reports on annual basis.

text: The Agency observes that the minimum frequency for the adequacy report defined by

text: Article 8(4) of Regulation (EC) No 714/2009

text: is every two years and that ENTSO-E occasionally presents in the SO&AF 2012 comparisons between assumptions and results from the SO&AF 2012 and from the SO&AF 2011.

text: It is important that ENTSO-E explains the background and the main reasons for updating assumptions as well as systematically compares the future SO&AF reports with the previous editions. Such review would also help understand whether an annual or biannual release (in odd years, before the TYNDP) of the SO&AF is more appropriate.

text: The Agency welcomes ENTSO-E’s intention to prepare longer-term scenarios until 2030. With such a timescale, the SO&AF will fully comply with the 15-year provision of

text: ENTSO-E expects significant increases in net generating capacity of wind and solar power plants (245 GW and 100 GW in 2020, respectively) . It indicates that many TSOs included renewable energy sources (wind and solar above all) in the category of non-usable capacity. In fact, non-usable capacity is estimated to reach 385 GW in 2020.

text: The Agency notes that hydro power plants are similarly characterised by restrictions on their output, due to various reasons, as indicated by ENTSO-E in the methodology for the SO&AF report. However, over the years, the TSOs have adopted various models and tools to describe the peculiar features of hydro power plants (e.g. the reservoir capacity, the natural inflows, etc.) in order to derive the hydroelectric potential for reliable generation.

text: Taking into account the expected growth of power injections and electricity generation from wind and solar power plants, it is important that ENTSO-E promotes new methodological approaches to estimate an expected reliable capacity of wind and solar power plants. Such new approaches could be fostered by ENTSO-E activities under the cluster 4 of its Research and Development Plan, particularly when developing tools for market integration of renewables.

text: ENTSO-E defines Load Management in the SO&AF as "the potential load reduction under control of each TSO to be deducted from load in the adequacy assessment". However, aggregate statistics are not provided for load management, whereas this is done for the other components of the supply-demand balance (e.g. system services reserve).

text: Out of 34 ENTSO-E countries, 15 (Belgium, Cyprus, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Luxembourg, The Netherlands, Serbia, Spain, Sweden and the United Kingdom) reported values for load management in the scenario EU2020. The overall load management is expected to slightly increase from about 11 GW in 2012 to about 13 GW in 2020. The increase is largely due to the increase in load management in three countries: Spain (+0.8 GW), Greece (+0.5 GW), Sweden (+0.4 GW).

text: The Agency invites ENTSO-E to assess the expectations for all components of the generation adequacy outlook, including load management.

text: The Agency acknowledges the introduction of a top-down scenario (the EU2020 scenario) in addition to the two A and B scenarios in the 2012TYNDP, responding to a previous appeal from stakeholders for an additional top-down approach.

text: The Agency acknowledges the use of cases (within each scenario) in the 2012 TYNDP and in the 2012 RIPs as the main instrument adopted to deal with uncertainties about future scenarios .

text: ENTSO-E introduces extended scenarios for a 2030 vision in the new SO&AF 2012, with a view of extending the timescale of the scenario outlook, since it can take more than ten years to build new grid connections. ENTSO-E states that the objective of constructing contrasting visions that differ enough from each other is to capture a realistic range of possible future pathways and different future challenges for the grid. The Agency believes that uncertainties might also be substantial on a ten-year timescale and that a wider difference in scenarios will be required.

text: The Agency regards as essential the use of a wider span across scenarios and the use of sensitivity analyses on the development of some generation technologies, particularly of nuclear, offshore wind and hydro storage. Furthermore, a more systematic approach to stakeholder engagement should be introduced, ensuring that relevant parties are involved on

text: the relevant issues and that a wide range of quantitative inputs are derived from such involvement.

text: Datasheets for all scenarios in the SO&AF and all sensitivity analyses in the TYNDP should be publicly available.

text: 5 Modelling approach

text: ENTSO-E’s TYNDP projects are proposed in two steps: a) market and b) grid studies. Both groups of studies are subject to an iterative process, bearing results in the form of the most economically and technically efficient projects. Whereas grid studies are traditionally in TSOs’ domain, the current TYNDP positively introduces and applies market studies at European level in order to highlight the needs for increased exchange capacities and to assess the economics of projects. The market studies constitute a major new feature of this TYNDP.

text: Pan-European co-operation and consistency are key issues for both market and grid modelling.

text: 5.1 Market Modelling

text: Market models are intended for defining the grid development needs, in order to predict the way in which new investments will be used by the market and thus to assign an economic value to these projects.

text: The market studies are run according to a European methodology and based on a pan- European database including the current Net Transfer Capacities (NTC), the costs of the different generation technologies and assumptions on the generation mix of the different countries.

text: The Agency expects ENTSO-E to indicate the assumptions adopted on fuel prices, including fuel price differentials across regions, and on CO2 emission prices. A merit order diagram (e.g. figure 11 of the Regional Investment Plan Continental South East), including MW figures for each aggregate of generation technologies at European and at regional level, would increase transparency.

text: As stated above, market modelling is part of the iterative TYNDP preparation process. It simulates the expected commercial power flows across boundaries on the basis of a large number of possible market situations in several forms (power flows or use rate of the capacity with a monotone curve) and provides the most representative market situations to run the grid studies. Step by step, the methodology aims at bringing out an efficiently designed project for each investment need. Moreover, market studies produce several indicators, in particular the socio-economic welfare (SEW) for every set of projects, comparing the situations with and without their implementation.

text: The introduction of market studies has been successfully addressed. This is a newly introduced feature, representing coordinated efforts at the EU level. The results of these efforts are essential for ensuring transparency of the project selection methodology.

text: It is important that the data used for running the market studies is provided in the SO&AF. The Agency considers this to be essential for ensuring a good level of transparency for all stakeholders. In particular, the Agency recommends clarifying and enhancing the approach for modelling generation profile from renewable sources.

text: Market studies and grid studies are part of an iterative process designed to optimise the increase of grid transfer capacity. The Agency considers it important that this methodology is well understood by stakeholders, and therefore recommends that clearer information about the inputs and outputs of the successive steps and on the depth of the iterative process (e.g. through an illustrative example based on one of the projects of the TYNDP) is provided.

text: The Agency acknowledges the ENTSO-E’s efforts with regard to pan-European modelling. It recognises that the currently applied regional approach makes it easier to consider national specificities. The coherence issue stemming from this approach has been addressed by ENTSO-E. Regional studies have been run in line with a coherent European methodology, thanks to overlapping study perimeters and harmonisation at different levels of regional studies, including cross checks for results and border conditions.

text: The Agency regards it essential for ENTSO-E to provide clear information on the sensitivity of the market study results to the considered scenarios.

text: 5.2 Network modelling

text: Network studies answer the following question: “Will the dispatch of generation and load given in every case generated by the market study results in power flows that endanger the safe operation of the system (accounting especially for the well-known N-1 rule)?”

text: Network studies build on the data from a pan-European database, that is fed from internal data from each TSO, on TSOs' assumptions about localisation of generation, on regional market studies and, especially, on the most representative situations among the market modelling studies: either very frequent situations, or more "extreme" situations that are chosen by the TSOs for their ability to encompass representative grid constraints.

text: The outputs of the network studies are physical power flows induced by the commercial ones, grid constraints remaining after implementation of projects and technical indicators of each project. These indicators, combined with the ones derived from market studies (e.g. the socio-economic welfare) enable the multi-criteria analysis.

text: Network studies are based on TSOs’ expertise to run robust models. ENTSO-E provides an insight into the criteria and practices that the TSOs use to run these studies. The Agency considers it important that ENTSO-E continues elaborating further on these practices in line with the System Operation Network Codes under development.

text: Network modelling covers voltage collapse and stability studies. The criteria for these studies are explained in Appendix 3 of the TYNDP. The Agency appreciates that the contingency issue is highlighted, which is an improvement compared to the 2010 TYNDP. Nevertheless, this section should be further elaborated following the pace at which homogeneous practices are being implemented.

text: Regional studies allow for consideration of local aspects and particularities and for ensuring consistency with the national investment plans. European consistency is nevertheless ensured due to the use of a pan-European database and of overlapping study perimeters. 12/18

text: 6 Multi-criteria analysis

text: As an outcome of the market and network studies, a set of criteria is introduced to illustrate the benefits of projects from a European perspective as part of a cost-benefit analysis.

text: The Agency recognises ENTSO-E’s efforts towards developing a multi-criteria assessment approach of projects of a pan-European significance.

text: In the context of the European Commission’s proposal for the EIP, ENTSO-E is expected to propose a cost-benefit methodology for the assessment of projects to become the basis for the selection of Projects of Common Interest (PCIs). The Agency acknowledges the proposed multi-criteria approach as the first step in the development of the expected methodology for a cost-benefit analysis. Nevertheless, the multi-criteria project assessment, which the current TYNDP is based on, needs to be further elaborated in light of the forthcoming EIP. Furthermore, since the TYNDP is to be used as the basis for the PCI selection process, it is essential that the 2014 TYNDP takes advantage of the ongoing developments in the field of a cost-benefit analysis methodology. The criteria is therefore to be robust and well established to avoid any shadows of a doubt expressed by the European Commission or other relevant stakeholders.

text: Considering the currently proposed set of indicators in the analysis, some economic effects linked to the indicators might be double-counted (e.g. for the CO2 indicator). Special attention should therefore be paid to avoid possible double counting of economic effects when developing a cost-benefit analysis.

text: With regard to the assessment of projects of a pan-European significance, the Agency expects that the assessment methodology is explained clearly, particularly when this is performed within the whole iterative process of market and grid studies.

text: The Agency supports the development of a social and economic welfare indicator that leverages the market study approach and highlights the benefits of projects from the perspective of a European electricity market.

text: The Agency welcomes the introduction of a risk indicator of social acceptance depicting the probability of completing the projects by the planned commissioning date on the basis of expert assessment or preliminary environmental studies. In addition to this indicator, the Agency suggests specifying the number of new overhead / underground lines attributed to each investment item. Furthermore, an explanation of how ENTSO-E addresses the refurbishment of existing lines in the process of project assessment is considered to be essential.

text: The Agency expects ENTSO-E to integrate the on-going efforts in improving the methodology for the cost-benefit analysis in the next TYNDP, especially in the light of the development of the PCI selection methodology within the EIP.

text: 7 Clustering of investments

text: ENTSO-E addresses the call for the clustering of projects by defining a project of pan- European significance as a set of single investments that addresses the same transmission need. In total, 503 investment items are clustered into just over 100 projects. In this way, clusters encompass investment items that jointly contribute to the same grid transfer capability.

text: The Agency appreciates the clustering of single investments into projects of pan-European significance to highlight the interdependence of investment items and to provide a more global view of proposed investments necessary to meet the requirements. Showing how certain bottlenecks can be overcome and displaying them via maps is very helpful. However, the graphical presentation should be more consistent and more detailed so as to be more closely aligned with the RIPs, in particular at the cluster level for the largest ones.

text: At the same time, the Agency cannot definitely confirm the necessity of every single investment in the corresponding cluster, as the importance of each item on the whole cluster has not yet been provided in any detail.

text: The Agency regards the further development of the clustering methodology as essential for the provision of a consistent clustering approach throughout Europe. This is of great importance for overall transparency.

text: The Agency expects ENTSO-E to provide further details on the importance of an investment item and its possible impacts on the whole cluster. The Agency recommends that costs be presented for each individual investment item inside each project cluster.

text: 8 Investment requirements

text: As a result of the network and market study process, ENTSO-E has identified almost 100 possible bottlenecks in Europe in the coming decade. The likely bottlenecks have been classified according to three types of concerns: the security of supply; generation direct connection; and market integration. With regard to the latter, 40% of the 100 bottlenecks are of a cross-border nature.

text: In Figure 6.5, ENTSO-E presents the bulk power flows associated with market integration concerns by adopting the following ranges: i) less than 2000 MW; ii) 2000 - 4500 MW; iii) 4500 – 10000 MW; iv) greater than 10000 MW.

text: Since the main purpose of the TYNDP is to identify the investment gaps, notably with respect to cross border capacities, the Agency expects ENTSO-E to develop a specific assessment of cross-border capacities. The aim should be to identify a target value (MW) for the additional transfer capacities at cross-border boundaries.

text: The Agency acknowledges the complexity of quantifying such a target and the possible need to provide capacity ranges depending on the assumptions for each scenario and for each sensitivity case.

text: 9 Additional information provided on projects

text: In addition to the indicators resulting from the multi-criteria analysis, the table of projects included in the TYNDP provides additional information on the status of projects and expected commissioning dates.

text: The Agency acknowledges the progress made since the pilot 2010 TYNDP in displaying structured information on projects and investment items.

text: An explanation should be given as to how certain commissioning dates have been set. Moreover, the Agency draws ENTSO-E’s attention to the risk of a delay in long-term projects and to the importance of providing realistic commissioning dates for projects.

text: Additionally, a more thorough explanation of the terms used in the status column of the table of projects would be welcome. Therefore, the Agency suggests an additional column indicating the type of investment items (overhead line, underground line, substation…).

text: Furthermore, the Agency suggests that ENTSO-E publishes a unified labelling of projects in European and national plans.

text: ENTSO-E calculates the grid transfer capacity increase given by each project and, in Figure 7.5 of the TYNDP, provides an outcome of capacity increases across all boundaries in Europe. The following ranges are used: i) 0 - 999 MW; ii) 1000 - 1999 MW; iii) 2000 - 4000 MW; iv) 4001 - 16000 MW.

text: The Agency expects ENTSO-E to focus further on cross-border capacities. For each border, the aim should be to provide the total amount of additional transfer capacity (MW) provided by the TYNDP projects (including the capacity increase given by third party projects) and to compare it with the investment gap, identified according to Section 8. Reasons for any differences should be analysed.

text: 10 Analysis of resilience

text: In the TYNDP and in the RIPs, ENTSO-E has detailed an approach designed to ensure the resilience of the system.

text: With regard to the background scenarios and the sensitivity analyses, the most restrictive cases based on the possible future situations have been considered in regional studies in order to check the secure functioning of the grid once the projects are commissioned.

text: The Agency acknowledges that the resilience of the system forms part of a consistent approach in the TYNDP and in the RIPs. The Agency considers it important that ENTSO-E pursues its efforts in maintaining consistency between European and regional levels in its analysis of resilience.

text: 11 Transmission adequacy

text: Transmission adequacy forms an essential part of the TYNDP, ensuring that the proposed set of projects matches the requirements. The project selection methodology, and especially the multi-criteria analyses, enables the selection of projects to address a specific need, and thus achieving a net positive impact. The purpose of this part of the TYNDP is to check whether all the requirements identified from a European perspective have been addressed; its aim is to highlight residual congestions or potential additional investment needs. In the final edition of the TYNDP, following the TYNDP public consultation, ENTSO-E has introduced illustrative maps of potential remaining investment requirements which sketched out a first transmission adequacy approach.

text: The Agency acknowledges ENTSO-E’s efforts to assess transmission adequacy. The information presented by ENTSO-E in the transmission adequacy sections of the TYNDP and of the RIPs is a first step which should be further developed to highlight the possible gaps and residual congestions as this part was not addressed in the pilot 2010 TYNDP. The Agency considers it to be a key issue for stakeholders, that the projects which would be able to meet the investment requirements are presented. The Agency particularly welcomes the illustrative maps that ENTSO-E introduced in the final edition of the TYNDP to highlight potential remaining investment requirements.

text: On the basis of the first approach outlined in the current TYNDP, the Agency expects ENTSO-E to pursue its efforts in structuring the transmission adequacy approach that aims to provide information on residual congestion and possible additional investment requirements when relevant from a social and economic point of view.

text: 12 Monitoring of previous plans

text: Chapter 3 of the TYNDP provides information on the comparison of the 2012 TYNDP with the previous edition in 2010.

text: The first part of the chapter shows how projects from the 2010 edition are considered in the current TYNDP. The second part reports on the current status of the projects. Further information on the evolution of the status of the projects is provided in the table of projects .

text: In the Agency’s view, the project assessment methodology already included in the 2010 TYNDP should be further explained, enhanced and benefit from best-practices implemented in some RIPs.

text: The Agency considers that full transparency of the evolution of projects should be provided in the corresponding chapter in the RIPs, especially on delayed and cancelled investments. All cancelled investments should be listed and the reason for cancelation should be displayed in the TYNDP. The same should also apply to delayed investments, since at present the reason for their delay cannot always be easily established, neither in the chapter on assessment of the previous TYNDP, nor in the list of projects.

text: Additionally, the Agency and ENTSO-E should further discuss and coordinate the monitoring of investments in line with the Agency’s monitoring duties. To this end, more detailed information on the project status will probably have to be provided to the Agency.

text: The input data is illustrated quite differently in the TYNDP and in the RIPs. The data seems more detailed in the RIPs and is not easily comparable with the information provided in the TYNDP.

text: In future TYNDPs, the Agency expects a greater level of detail regarding project cancelations and delays.

text: Appendix 1: Abbreviations

text: ACER Agency for the Cooperation of Energy Regulators EIP Energy Infrastructure Package EU European Union ENTSO-E European Network of Transmission System Operator for Electricity ERGEG European Regulators’ Group for Electricity and Gas NSCOGI North Seas Countries’ Offshore Grid Initiative NTC Net Transfer Capacity PCI Project of Common Interest RIP Regional Investment Plan SEW Socio-Economic Welfare SO&AF System Outlook and Adequacy Forecast TSO Transmission System Operator TYNDP Ten-Year Network Development Plan


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identifier: ACER Opinion No 06/2013

publisher: Europeiska unionens byrå för samarbete mellan energitillsynsmyndigheter

sprak: en

title: ACER Opinion 06-2013 on the Network Code on Demand Connection

serie: yttranden

text: Publishing date: 27/03/2013

type: stycke

text: Document title:

text: We appreciate your feedback

text: Publishing date: 27/03/2013

text: Document title:

text: We appreciate your feedback

type: vagledning

utgivare: acer


identifier: ACER Opinion No 06/2014

title: ACER Opinion 06-2014 on the ENTSOG Amendments to the Statutes of the Association

text: Publishing date: 17/03/2014

text: Document title:

text: We appreciate your feedback

text: Publishing date: 17/03/2014

text: Document title:

text: We appreciate your feedback


identifier: ACER Opinion No 06/2015

title: ACER Opinion 06-2015 on the ENTSO-E Research & Development Roadmap 2013-2022

text: Publishing date: 22/07/2015

text: Document title:

text: We appreciate your feedback

text: Publishing date: 22/07/2015

text: Document title:

text: We appreciate your feedback


identifier: ACER Opinion No 06/2016

title: ACER Opinion 06-2016 on the ENTSO-E Annual Report 2015

text: Publishing date: 27/06/2016

text: Document title:

text: We appreciate your feedback

text: Publishing date: 27/06/2016

text: Document title:

text: We appreciate your feedback


identifier: ACER Opinion No 06/2017

title: ACER Opinion 06-2017 on the ENTSOG Draft TYNDP 2017


identifier: ACER Opinion No 06/2018

title: ACER Opinion 06-2018 on Template for Main Terms & Conditions for Bundled Capacity Products - Gas


identifier: ACER Opinion No 06/2019

title: ACER Opinion 06-2019 on the Implementation of the EU Electricity TYNDP


text: Opinion No 06/2020

text: OJ L158, 14.6.2019, p. 22. 2 ENTSO-E news: https://www.entsoe.eu/news/2020/06/29/entso-e-and-entsog-publish-their-final-jointscenarios-for-tyndp-2020-and-open-registration-for-public-webinar/ and ENTSOG Press Release: https://www.entsog.eu/sites/default/files/2020- 06/PR0211_200629_Press%20Release_ENTSOE%20and%20ENTSOG%20publish%20their%20final%20Joint %20Scenarios%20for%20TYNDP%202020%20and%20open%20registration%20for%20public%20webinar.pdf

text: Opinion No 06/2020

text: 29 May 2018: ENTSOs joint Scenario Storyline workshop: https://www.entsog.eu/entsos-gas-and-electricitytyndp-2020-scenario-development-workshop#welcome (Presentations available on ENTSOG website). 4 2 July 2018: Publication of TYNDP 2020 draft storylines: https://www.entsog.eu/sites/default/files/entsogmigration/publications/TYNDP/2018/180702_WGSB_Scenario%20Building%202020_Consultation_Document .pdf 5 From 2 July to 14 September 2018, ENTSOs opened a web-based public consultation: https://consultations.entsoe.eu/tyndp/2020-scenario-storylines/

text: Opinion No 06/2020

text: 18 April 2019: ENTSOs Scenario Building Stakeholder Webinar: https://www.entsoe.eu/events/2019/04/18/entsos-scenario-builidng-stakeholder-webinar/. 7 https://www.entsog.eu/sites/default/files/2019- 06/190408_WGSB_Scenario%20Building%202020_Final%20Storyline%20Report.pdf 8 10 July 2019: ENTSOG workshop on the Gas Supply Potentials and Market Related Assumptions for TYNDP 2020: https://www.entsog.eu/entsog-workshop-supply-potentials-and-market-related-assumptions-tyndp-2020 (Presentations available on ENTSOG website). 9 The publication consists of Scenario Highlights, the main report, the scenario methodology report and the scenarios website https://www.entsos-tyndp2020-scenarios.eu/ 10 https://consultations.entsoe.eu/tyndp/entsos-2020-tyndp-scenarios/ 11 5 December 2019: ENTSOs joint Public Workshop on the draft TYNDP 2020 Scenarios: https://entsog.eu/gas-and-electricity-entsos-workshop-joint-tyndp-2020-scenarios-brussels-5-december (Presentations available on ENTSOG website). 12 https://www.entsoe.eu/events/2020/07/03/webinar-on-final-tyndp2020-scenarios/

text: Opinion No 06/2020

text: The overlapping of these storylines is acknowledged in the draft Scenario Report p.52: “the ENTSOs Working Group Scenario Building (…) had noticed the similarity between National Trends and European Focus”. 14 ACER Opinion No 21/2014, 12/2016 and 10/2018.

text: Opinion No 06/2020

text: https://eepublicdownloads.azureedge.net/clean-documents/Publications/ENTSO- E%20general%20publications/AWP_2019.pdf 16 https://www.entsog.eu/sites/default/files/2018- 12/Annual%20Work%20Programme%20%28AWP%29%202019_%20Final.pdf 17 https://www.acer.europa.eu/Official_documents/Acts_of_the_Agency/Opinions/Opinions/ACER%20Opinion% 2021-2014.pdf

text: Opinion No 06/2020

text: Draft Scenario Report, p.14 19 In year 2030, the EU-28 gas demand is 4254 TWh/year in the NT scenario; 4612 TWh/year in the DE scenario e 4859 TWh/year in the GA scenario.

text: Opinion No 06/2020

text: Draft scenario report, page 57. 21 The Scenario Building Guidelines indicate that the increase of cross-border capacities in the investment model is not used in the following TYNDP processes and intends to ensure rational generation placement and not network needs identification. 22 Except for the trajectories of maximum capacities of solar PV, wind onshore and wind offshore at years 2030 and 2040, which are presented in Annex 3 to the Scenario Building Guidelines.

text: Opinion No 06/2020

text: Annex 2 to the draft scenario report, regarding “Cost Assumptions for the investment modelling”. The final storyline description states that: “Natural gas supplies via pipeline and LNG are still dominant sources of supply. Power-to-Gas sees limited development and is used more for energy storage than a key supply of gas. Biomethane growth is reliant on national policy support. <…> The storyline takes into account imports of green gases using the existing gas infrastructure leading to a decarbonisation of the gas mix in the long run.” The central matrix of factors relevant for the construct of scenarios indicates the level of relevance of various factors by using symbols (+, +, etc.). Cf. Scenario Report, pp. 6 and 11-12, and pt. 25(f) of this Opinion.

text: Opinion No 06/2020

text: Opinion No 06/2020

text: Opinion No 06/2020

text: ACER notes that during the webinar of 3 July 2020, the ENTSOs presented a timeline in which a full dataset seems to be available by February 2021, a draft scenario report is to be released by June 2021, a public consultation on scenarios is to be carried out in July and August 2021 and an updated scenario report is planned by December 2021.

text: Opinion No 06/2020

text: Opinion No 06/2020 This Opinion is addressed to ENTSO-E and ENTSOG. Done at Ljubljana, on 5 November 2020.

identifier: ACER Opinion No 06/2020

title: ACER Opinion 06-2020 on the ENTSO-E and ENTSOG Draft TYNDP 2020 Scenario Report

text: OPINION No 06/2020 OF THE EUROPEAN UNION AGENCY FOR THE COOPERATION OF ENERGY REGULATORS of 5 November 2020 on ENTSO-E and ENTSOG draft TYNDP 2020 Scenario Report

type: rubrik

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 (“ACER”) and, in particular,

text: Articles 4(3)

text: (b) and 4(5) thereof, Having regard to the outcome of the consultation with ACER’s Electricity and Gas Working Groups, Having regard to the favourable opinion of the Board of Regulators of 13 October 2020, delivered pursuant to

text: Article 24(2) of Regulation (EU) 2019/942

text: Whereas:

text: 1. INTRODUCTION

text: (1) On 29 June 2020, the European Network of Transmission System Operators for Electricity (“ENTSO-E”) and the European Network of Transmission System Operators for gas (“ENTSOG”) published their joint TYNDP 2020 Scenario Report (“draft Scenario Report”). The draft Scenario Report documentation encompasses a main report, building guidelines, and main highlights. It is possible to download and visualise the main data sets used for scenarios and the elaboration of the draft Scenario Report.

text: Article 30(1)

text: (b) of

text: Regulation (EU) 2019/943

text: and

text: Article 8(3)

text: (b) of

text: Regulation (EC) No 715/2009

text: require ENTSO-E and ENTSOG, respectively, to adopt and publish a nonbinding Union-wide ten-year network development plan (“TYNDP”) biennially.

text: Pursuant to

text: Article 48(1) of Regulation (EU) 2019/943

text: and

text: Article 8(10) of Regulation (EC) No 715/2009

text: , the electricity and gas TYNDPs shall include, among other features, scenario development.

text: (3) As scenario development is carried out and published as a separate activity during the preparation of the TYNDPs 2020, ACER has assessed the draft Scenario Report separately from the forthcoming draft TYNDPs.

text: (4) The Agency’s assessment takes primarily into account the TYNDP requirements defined by

text: Regulation (EU) 2019/942

text: Regulation (EU) 2019/943

text: and

text: Regulation (EC) 715/2009

text: , i.e. the contribution of the TYNDPs (and specifically of their scenario development) to non-discrimination, effective competition, the efficient and secure functioning of the electricity and gas markets and a sufficient level of cross-border interconnection open to third-party access.

text: 2. ASSESSMENT OF THE DRAFT SCENARIO REPORT

text: The process of preparing the draft Scenario Report

text: (5) During the first half of 2018, the ENTSOs developed the 2020 scenario storylines. The proposed storylines were the following: 1) National Trends; 2) Global Ambition; 3) European Focus; 4) Distributed Energy; and 5) Delayed Transition. These storylines retained some consistency from the TYNDP 2018 scenario storylines, while having similar names.

text: (6) In May 2018, the ENTSOs held a public workshop on the storylines . The participants were asked to share their first impressions on the storylines presented, while the ENTSOs shared the main assumptions and the rationale for their development.

text: (7) From 2 July until 14 September 2018, the five published draft storylines were publicly consulted . Stakeholders had the chance to comment on the proposed storylines, and vote on their relevance. Thirty-five stakeholders participated in the consultation of the storylines.

text: (8) From November 2018 to May 2019, the storylines were finalised. First, a Public Webinar on “Scenario Development Process Update” took place and in April 2019, the ENTSOs

text: held a Scenario Building webinar for stakeholders . The ENTSOs reduced the initial five storylines to the following three: 1) National Trends (NT); 2) Distributed Energy (DE); 3) Global Ambition (GA). The webinar presented the three retained final storylines and provided an overview of the stakeholder input and how it was considered.

text: (9) On 29 May 2019, ENTSOs published the final storylines for the Scenario Report , including a summary of the feedback received on the draft storylines and ENTSOs’ considerations.

text: (10) From May until November 2019, the data collection and scenario building process took place. During this period, ENTSOG held a workshop on Gas Supply Potentials and Market Related Assumptions for the TYNDP 2020 .

text: (11) In November 2019, a draft version of the Scenario Report was published and, two weeks later, open for public consultation from 25 November 2019 until 22 January 2020. The ENTSOs published some data in a zip file called “TYNDP 2020 Scenario Data”, containing worksheets on electricity data, gas data, electricity demand and power-to-gas.

text: (12) In December 2019, the ENTSOs held a joint scenario workshop to present the Scenario Report development process and its main results.

text: (13) On 29 June 2020, the (updated) draft Scenario Report was published. On 3 July 2020, ENTSOs organised a closing webinar to present the Scenarios for the TYNDP 2020 and to kick-off the scenario development process for the TYNDPs 2022 .

text: (14) ACER welcomes the second iteration of the joint ENTSOs’ process for building scenarios for the TYNDP 2020 as initiated within the TYNDP 2018 process. ACER acknowledges the sustained efforts of the ENTSOs to interact with stakeholders throughout the development of the scenarios via public webinars, workshops and consultations. ACER appreciates the transparency on stakeholder responses to the first consultation in the final storylines report, notably the number of received responses, the summarised feedback, and ENTSOs’ response to the feedback.

text: (15) However, ACER regrets that the processes of storylines definition and of scenario development showed some deficiencies leading to a suboptimal trustworthiness of the final scenarios, namely:

text: a. The consultation process, even though involving stakeholders of different interest groups, did not substantially involve stakeholders in the actual storyline development process, beyond an opportunity to provide comments and feedback on a preselected set of storylines. The choice of the final storylines used for the scenarios from the five proposed was actually to a significant extent left to the ENTSOs’ discretion, especially after taking into account the fact that similarities between European Focus and National Trends in essence conclude that only four storylines were proposed and amongst those four, Delayed Transition was eliminated rather quickly due to strong opposition of some stakeholders. b. Storylines and subsequent scenarios used to assess the future requirements of the energy system(s) regarding new infrastructure, market configuration and electricity adequacy aspects are impacted by a wide range of variables. The draft Scenario Report 2020 does not provide sufficient information on the way in which expert knowledge about the range of such variables was used, and if used, then from which sources and in which manner. Consequently, despite the repeated ACER recommendation to invite contributions or reviews from selected experts , it remains somewhat obscure how such knowledge was involved in the storyline/scenario development, and to what extent. c. The availability of data was limited at the time of the consultation on scenarios (November 2019), e.g. making available only the electricity annual and peak demand, while not sharing information on RES profiles. It was also poorly presented, with different information (e.g. electricity generating capacity, generation, emissions, balance) for different scenarios and for different study years in a single spreadsheet, making important pieces of information poorly accessible to readers. d. The transparency of scenario development is further compromised by the apparent lack of published full responses to the December 2019 consultation by the ENTSOs on the web. Furthermore, links provided by the ENTSOs on their websites to stakeholder engagement documents lead to a press release announcing the consultation, but not to the list of respondents, to their full responses, and to the evaluation of the responses by the ENTSOs, apart from very limited information provided in Section 10.2 of the draft Scenario Report. e. Consequently, it is not possible to understand how, in the absence of meaningful data, the respondents could truly evaluate the scenarios proposed for consultation and how the 42 responses to the public consultation on scenarios actually affected the scenario development;

text: f. Last, the ENTSOs qualify their scenario report as “Final Report, June 2020” instead of identifying it as a version for ACER’s Opinion. This approach may confuse the readers regarding ACER’s role as defined by

text: Regulation (EU) 2019/942

text: (16) ACER observes the existence of significant delays in the scenario process. In January 2019, ENTSO-E envisaged in its final work programme for 2019 the finalisation of the Scenario Report by September 2019. ENTSOG indicated in its final work programme for 2019 “the release of the draft information in Q3 before the Final TYNDP 2020 Scenario Report is released in Q4 2019” . In April 2019, the ENTSOs indicated during a webinar that the “Public Release of Scenario Outcomes” would be in Q3 2019 and the “Final Workshop for Release of Scenario Report” (post-consultation) in Q4 2019. The reality is that the Scenario Report was delayed by 9 months compared to the initial planning (July 2020 vs. September 2019).

text: (17) ACER is of the view that a timely scenario development process is crucial to facilitate a consistent development of scenarios at European level and at national level (for national network development plans and other analyses). ACER recalls the recommendation provided in its Opinion No 21/2014, namely that the scenario development should be completed, including an ACER Opinion on scenarios, in the year before the preparation of the TYNDPs .

text: (18) These significant delays endanger the potential participation of stakeholders, time-press subsequent TYNDP processes, possibly endangering the quality of the identification of system needs and of cost-benefit analyses, which have to be performed after the scenario development.

text: (19) The consistency between national network development plans (NDPs) and the European TYNDPs, and more generally the consistency of the framework for assessing investments, is also potentially significantly endangered because of the delays in scenario development, especially in countries where the NDP was prepared in the second half of 2019 or in the first half of 2020. More robust scenarios at national level might be necessary in the upcoming NDPs.

text: (20) For the reasons above, ACER considers that the scenario development of TYNDPs 2020, in terms of its timing and data release, did not sufficiently contribute to efficient and secure functioning of the internal markets for electricity and natural gas.

text: Consistency and robustness of scenario development

text: (21) Based on the “best-estimate” scenario for 2025, three additional scenarios have been jointly developed by the ENTSOs for the 2030 and 2040 timeframes at country level, and two (Distributed Energy and Global Ambition) at an EU level for 2050. In addition, a current-trend scenario is stated to be developed by ENTSO-E (see Section 2.4 below).

text: (22) ACER notes positively the integration of the Paris Agreement and of EU and national energy and climate policy targets in the scenarios, along with the development of carbon budgets, used for distributed energy and global ambition scenarios .

text: (23) ACER acknowledges the improvement in the consistency and timespan of the scenarios compared to the previous edition of the TYNDP, as in the TYNDP 2018 only two scenarios were consistently developed for the 2030 and 2040 timeframes (Sustainable Transition and Distributed Generation), with two additional scenarios developed only for one of the timeframes, respectively 2030 for EUCO and 2040 for Global Ambition.

text: (24) ACER observes progress in the draft Scenario Report, as significant efforts have been made to provide more details on the elaboration process of the scenarios at the different timeframes.

text: (25) However, ACER is of the view that certain elements are subject to improvement, namely:

text: a. In contrast to the previous editions of the Scenario Reports, the underlying assumptions regarding the economic conditions per scenario are not described in the draft scenario report; b. The use of more contrasted scenarios is lacking. This could have been avoided through the joint development of a “current trends” scenario, thus integrating a slower economic and technological development among the range of potential future events. ACER also finds that several variables, such as gas demand and demand-side response, are considered within too narrow value ranges across the various scenarios; c. The consistency of gas demand with the carbon budgets (for scenarios DE and GA) and the carbon-related assumptions in the NECPs (for the NT scenario) remains unclear; d. While scenario development took into account carbon budgets in 2 out of 3 scenarios (top-down), it is not elucidated in the context of scenario development how the carbon-related dimension is considered in the national trends scenario, taking into account the National Energy and Climate Plans (NECPs); as this scenario is constructed with a “bottom-up” approach, at least transparency on key assumptions used for its developing is needed;

text: e. The draft Scenario Report (p. 13 and p. 48) indicates that a “sensitivity analysis regarding the merit order of coal and gas in the power sector is included for 2025”. This “Gas Before Coal” at year 2025 was developed by setting its CO2 price at 56 euro/t. The proposed value is more than twice the “Best Estimate 2025” CO2 price (23 euro/t) and higher or significantly higher than the ENTSOs CO2 price assumptions at year 2030, rendering the sensitivity analysis unrealistic and internally inconsistent. f. The features of the different storylines are not sufficiently precise. The storyline central matrix uses a “grade” notation based on loosely described ranges (‘+’ ‘++’), which is too imprecise to allow analysis by stakeholders. This is acknowledged in the draft Scenario Report, which states (p. 16) that “growth and reduction rates across the different categories are not directly comparable”. In particular, the scenarios do not elaborate on how key variables, such as the electrification rate or the level of gas demand, have been set up in each storyline, whether the electricity and gas interlinkage has been considered, and, in case it has been considered, how that has been done; g. Technologies that are either immature or associated with important uncertainties, such as Carbon Capture, Utilisation and Storage (CCUS) and Land use, land-use change, and forestry (LULUCF), are assumed to be widely applied in all scenarios, without due justification; a more differentiated spectrum of assumptions regarding uncertain technology developments should be considered; h. For two scenarios (GA and DE) a co-optimisation of generation capacity and grid was executed, including a “trajectory data collection for various core supply and demand elements based on up to three national scenarios (with low, medium and high development trajectories)” . According to the Scenario Building Guidelines (p.30), the installed capacities and the generation of the electricity sector are quantified in more detail with the help of a power market investment model (step 2 in top-down scenario building) . The constraints taken into account in the power market investment modelling, as well as in the following step 3 in which security of supply is assessed, are not specified in the scenario development documents , although their impacts on generation capacities represent a key feature for top-down scenario development.

text: (26) ACER notes that the COVID-19 crisis and its impact have not been taken into account in the draft Scenario Report, despite its significant impact on energy demand and on the need of relevant infrastructure investments. ACER acknowledges that the unexpected COVID event materialised only during the finalisation phase of scenario development, and that a complete reassessment of the modelling and the scenarios would have been difficult to manage by the ENTSOs.

text: (27) However, ACER is of the view that the ENTSOs should explore in the TYNDPs 2020 the implications of the COVID-19 pandemic on the future energy demand, including prospects for investment in energy in general and in infrastructure in particular.

text: Transparency of scenarios

text: (28) ACER notes positively that some scenario data are available on the 2020 TYNDP scenario website for downloading without restrictions, and that a visualisation platform was implemented to present the data.

text: (29) ACER also acknowledges significant advances in the elucidation of the sector-related hypotheses in the scenario methodology report, in comparison to the previous TYNDP edition.

text: (30) Still, there are several areas where scenario transparency could be further improved:

text: a. The visualisation platform is not easily usable and does not always provide measurement units and meaningful data, e.g. the energy flows between countries are hardly visible (for electricity) in the “electricity flows” map, and apparently missing for gas; b. The definitions for the different generation capacities and demand-side response leverages are not provided. In particular, only one category is displayed for gas, lignite and coal, while in the previous TYNDP for each of these fuels there were different categories accounting for the efficiency of the power plant; c. The level of information on the forecasted cost of the different technologies considered in the scenarios is limited to few technologies (open cycle gas turbine, combined cycle gas turbine, solar, wind and batteries) and does not allow for an analysis as the data sources are lacking; d. There is a lack of transparency of the hypotheses assumed for several parameters, in particular for efficiencies of electricity generation technologies, for (forced/scheduled) unavailability of electricity generation technologies and of interconnection capacities, for RES injection profiles, for gas price and gas flows by source . Key parameters such as the expected cost of gas, location and availabilities of resources, as well as the impact of future demand for gas transportation services, are not explained and modelled. The conditions for the development of biomethane, power-to-gas, or gas coupled with carbon capture or pyrolysis are not specified;

text: e. The hypotheses for heating, such as electrification rate and heat pumps, are not clearly stated; f. Despite the possibility to access certain data, stakeholders have no access to information on the features of the investment and security supply models as well as to other critical results, such as the expected electric and gas flow. These limitations significantly restrain the ability of stakeholders to assess the scenarios.

text: ACER’s remarks on ENTSO-E’s Current Trends scenario

text: (31) In its Opinion No 10/2018, ACER requested the ENTSOs to introduce a “low economic growth / slow-progress” scenario in all study years which are treated under a multiscenario approach, in order to have a proper understanding of the risks associated with each scenario for each infrastructure project under analysis, as well as to have a balanced set of scenarios, and not only optimistic ones.

text: (32) The draft Scenario Report (page 59) states that “electricity transmission and storage projects (…) will also be assessed in a ‘Current Trends’ scenario, an ENTSO-E scenario not included in this report which describes a future where the energy transition is slower than planned”. In other words, ENTSO-E chose to create an additional, fourth scenario, called Current Trends (CT).

text: (33) ACER understands that the Current Trends scenario was constructed bottom-up, by collecting information about the most conservative national development trajectories from all TSOs.

text: (34) ACER recalls that information on the use of “slow progress” scenarios is available in ACER’s Opinion No 13/2019 on national network development plans, according to which “more than one third of the NDPs appear to also use a scenario which considers lower economic growth or demand” (11 EU Member States). Therefore, a “slow progress” trajectory could have been available in less than half of the countries. However, it remains unclear whether these trajectories were actually used and which assumptions were used for the other countries.

text: (35) For the reasons above, ACER cannot evaluate whether the Current Trends scenario constructed by ENTSO-E is consistent with the request set out in ACER Opinion No 10/2018 recalled here above.

text: (36) ACER regrets to note that the Current Trends scenario is not available in the draft Scenario Report, was not made available in any format for public consultation, and that its dataset was not published or made available for public consultation. In addition to publishing this information, ENTSO-E should clarify which national scenarios were used (where applicable) and which assumptions were adopted in other countries where a “slow progress” or conservative scenario was not readily available.

text: (37) ACER also notes that, according to the draft Scenario Report, no indications exist that a slow economic progress scenario will be used by ENTSOG, rendering the base of the gas TYNDP 2020 to an unbalanced set of scenarios.

text: 3. ACER’S RECOMMENDATIONS

text: Short-term, for the TYNDP 2020

text: (38) Considering the deficiencies of the draft Scenario Report as indicated above, as well as the process of its development, stakeholder interaction and transparency, ACER recommends ENTSO-E and ENTSOG to take the following actions at their earliest convenience:

text: a) Improve documentation pertinent to stakeholder involvement. Even if the draft Scenario Report mentions the involvement of a wide variety of stakeholders, there is little information about organisations/companies actually involved and to what extent they have been involved. Details could be briefly presented with pie graphs, so as to provide a quick insight into how the consultation process has actually worked. Besides, it must be indicated which were the most widely discussed and debated issues among the different stakeholders. The ENTSOs should provide a sufficiently detailed evaluation of stakeholder responses to the public consultation of the draft Scenario Report and how they were taken into account.

text: b) Provide information in the TYNDPs 2020 on the way in which network “needs” depend on important aspects of scenarios, i.e. on the extent and on the way in which key scenario parameters affect the needs in electricity and in gas transmission, in each sectoral TYNDP (TYNDP system needs report).

text: c) Introduce a scenario featuring low economic growth / slow progress in the electricity and gas TYNDPs 2020 for all years where a multi-scenario approach is adopted (i.e. calculate the CBA results also for this scenario).

text: d) Provide all data regarding the “Current Trends” scenario and run a public consultation on it, within the frame of the TYNDP public consultations.

text: e) Explain the interactions, if any, between carbon budgets used in two scenarios and CO2 ETS prices assumed for them. Provide more transparently the definitions for carbon budget. For the National Trends scenario, indicate which carbon-related assumptions were considered in the NECPs, underpinning the data submitted by TSOs under a bottom-up approach.

text: f) Clarify that the “Coal before Gas” and “Gas before Coal” 2025 scenarios are two scenarios rather than a sensitivity analysis of a single scenario, as currently claimed. This clarification should be made in the forthcoming gas TYNDP 2020, unless the

text: Gas before Coal scenario is simply removed as envisaged for the electricity TYNDP, in particular in view of its unrealistic assumptions about CO2 prices.

text: g) Explain better what the notations of the technologies growth (+, ++, +++) actually mean and which assumptions were made to arrive at designating the technologies with these notations.

text: h) Explain why new energy demand drivers, such as the Paris Agreement requirements and NECPs, appear to have limited impact on gas demand in all scenarios.

text: i) Provide transparent information on the constraints taken into account in the power market investment modelling for the top-down GA and DE scenarios, as well as the impacts of these constraints, in particular regarding the definition of the assumed capacities for each electricity generation technology.

text: j) Explain the interaction with the national energy and climate plans of Member States, especially when the final targets of NECP diverge from the values retained in the National Trend scenario.

text: k) Adopt, as much as possible, academic standards for the presentation of the scenarios assumptions and results, such as including clear definitions of the metrics and their basics, formally describing the models and the calculation (simulation) processes; provide references for each input value used in the Scenario Report.

text: l) Publish all parameters and assumptions which are currently not available to interested parties, as indicated in point (30) of this Opinion.

text: m) Enhance transparency on the adjustments done during the modelling.

text: n) Explore the impact of the COVID-19 pandemic and of the subsequent recovery measures in the current (and upcoming) scenarios of energy demand and related investments.

text: Mid and long-term, for TYNDP 2022 scenarios

text: (39) ACER recommends that ENTSO-E and ENTSOG take the following actions for the preparation of TYNDP 2022 scenarios:

text: a) Deliver the TYNDP 2022 scenarios for ACER’s opinion by September 2021, in order to allow sufficient time for the finalisation of the scenarios after ACER’s Opinion by the end of 2021 . In this way, it will help to avoid risks of delays negatively affecting the scenarios’ analyses at national level and the national

text: network development plans, as well reduce the risks of compressing the needs identification process and the cost-benefit analyses of the TYNDPs, which have to be carried out mostly after the completion of the scenario development.

text: b) Define and publicly share a realistic plan of the scenario-related activities, in line with the timing above.

text: c) Carry out a single public consultation on scenarios for the TYNDPs 2022, i.e. on the draft scenario report and its full dataset, in line with the requirement in Annex V.2 of

text: Regulation (EU) No 347/2013

text: d) Reinforce the participation of stakeholders during the scenario development process. Stakeholders (in particular project promoters, NRAs, researchers, Non- Governmental Organisations) may face difficulties in actively engaging in the scenario building process, because they do not have access to the same data as TSOs, and because the time to respond to the public consultation is insufficient. More informed stakeholder involvement could also be facilitated through introductory TYNDP webinars.

text: e) Label the updated version of the Scenario Report after public consultation in 2021 as “version for ACER Opinion”.

text: f) Improve long-term consistency and continuity of storylines over the different editions of the TYNDP, explaining what the new drivers are and why the ENTSOs abandon (if that is the case) or replace old storylines, while accounting to an appropriate extent the long-term implications of the COVID-19 crisis and the EU Recovery Fund on energy sector development.

text: g) Jointly develop contrasted scenarios. This contrast should encompass slow versus fast economic progress and different assumptions on intake of currently immature or highly uncertain technologies,

text: HAS ADOPTED THIS OPINION:

text: The TYNDP 2020 draft Scenario Report provides improvements in comparison to the previous versions of scenario reports, as noted in Chapter 2 of this Opinion.

text: In consideration of the deficiencies of quality, process, and transparency aspects of the draft Scenario Report as explained above, ACER provides recommendations in Chapter 3 of this Opinion on how the ENTSOs could mitigate the drawbacks of the draft Scenario Report for its use in the TYNDPs 2020. ACER invites ENTSO-E and ENTSOG to implement them in a most diligent manner. ACER provides recommendations for the TYNDP 2022 scenario development, and in particular its timeline, involvement of stakeholders, robustness and consistency.

text: - SIGNED -

text: Fоr the Agency The Director

text: C. ZINGLERSEN


document_url: https://acer.europa.eu/Official_documents/Acts_of_the_Agency/Opinions/Opinions/ACER Opinion 06-2021 on ENTSOG%E2%80%99s Summer Supply Outlook 2021.pdf

text: Opinion No 06/2021

text: Cf. ENTSOG’s SSO 2021, p. 3. Ibid., Annex B, p 20. 3 Ibid., p. 6. 4 Cf. ACER’s Opinion No. 16/2019, pt. 12.

text: Opinion No 06/2021

text: Regulation (EU) 2017/1938

text: of the European Parliament and of the Council of 25 October 2017 concerning measures to safeguard the security of gas supply and repealing

text: Regulation (EU) No 994/2010

text: , OJ L280/1, 28.10.2017. Also considered should be the risk assessments as foreseen in

text: Article 7 of Regulation (EU) 2017/1938

text: . 6 Cf. ACER’s Opinion No 16/2019, pt. 14.

identifier: ACER Opinion No 06/2021

title: ACER Opinion 06-2021 on ENTSOG’s Summer Supply Outlook 2021

text: PUBLIC

text: OPINION No 06/2021 OF THE EUROPEAN UNION AGENCY FOR THE COOPERATION OF ENERGY REGULATORS of 27 July 2021 on ENTSOG’s Summer Supply Outlook 2021

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 (hereinafter referred to as “ACER”), and, in particular,

text: Article 4(3)

text: (b) thereof, Having regard to

text: Regulation (EC) No 715/2009

text: of the European Parliament and of the Council of 13 July 2009 on conditions for access to the natural gas transmission networks and repealing

text: Regulation (EC) No 1775/2005

text: , and, in particular, Articles

text: and

text: thereof, Having regard to the outcome of the consultation with the ACER’s Gas Working Group, Having regard to the favourable opinion of the Board of Regulators of 13 July 2021, delivered pursuant to

text: Article 22(5) of Regulation (EU) 2019/942

text: , Whereas:

text: 1. INTRODUCTION (1) On 12 April 2021, the European Network of Transmission System Operators for Gas (“ENTSOG”) published the Summer Supply Outlook 2021 pursuant to

text: Article 8(3)

text: (f) of

text: Regulation (EC) No 715/2009

text: . (2) Pursuant to

text: Article 4(3)

text: (b) of

text: Regulation (EU) 2019/942

text: , ACER may provide an Opinion to ENTSOG on, inter alia, relevant documents referred to in

text: Article 8(3) of Regulation (EC) No 715/2009

text: , as submitted to ACER pursuant to

text: Article 9(2)

text: , first subparagraph, of

text: Regulation (EC) No 715/2009

text: 2. SUMMARY OF THE DOCUMENT (3) In the Summer Supply Outlook 2021, ENTSOG undertakes an assessment of the European gas network for the upcoming summer. The analysis investigates the possible evolution of the supplies and the injection in the storages as well as the ability of the gas Page 1 of 3 infrastructures to handle gas flows to serve the demand, the exports and the storage injection needs during the summer 2021. ENTSOG has used a reference objective of reaching a 90% level of storage capacity by 30 September 2021, and performed a sensitivity analysis considering different scenarios of injection targets and flexibility of injection between 80% and 100% of storage levels. (4) ENTSOG finds that the European gas network is sufficiently robust in most parts of Europe to enable at least 90% gas storage level in preparation of the upcoming winter, also considering maintenance to ensure infrastructure reliability in the long term and flexibility for the network users’ supply strategy . These main findings are based on supply assumptions used for the modelling, namely that the minimum and maximum daily average gas supply potentials from various sources (Algeria, Libya, Norway, Russia and LNG) during the 2021 injection season would be identical to the daily average minimum and maximum supply observed over a six-year period (historical availability, April-September 2015-2020) , with maximum supply from LNG basins identical to the maximum supply potential defined in the TYNDP 2020 . ENTSOG provides the relevant data and the assumptions in the annexes to the Summer Supply Outlook 2021.

text: 3. ASSESSMENT OF THE DOCUMENT (5) ACER welcomes the publication of the Summer Supply Outlook 2021 by ENTSOG in due time, ahead of the summer season. (6) ACER appreciates and underlines the importance of the main conclusions contained in the Summer Supply Outlook 2021 as indicated above. However, ACER notes that conclusions are only valid to the extent to which gas supply from the various sources would actually be available in the volumes used for the purpose of the modelling, which are based on historically observed volumes over a 6-year period of time when no significant disruptions of supply flows occurred. (7) ACER reiterates its view that the modelling approach thus assumes that import gas supplies will always be available to serve demand, i.e. there will always be “additional flexibility” per supply source, and the modelling checks whether the gas transmission network and storages are able to handle the supplied volumes, including by injecting gas in storage. ACER notes that ENTSOG may consider acting on ACER’s outstanding invitation to consider including in future supply outlooks an analysis of the potential changes in supply as an independent variable . (8) ACER is of the view that it would be pertinent for the Summer Supply Outlook 2021 and for future supply outlooks to provide a more detailed assessment of the potential risk to which Member States would be exposed in case of significant disruption of supply from the various sources. ACER notes that such a risk assessment could be provided by analogy to the risk-based approach foreseen under

text: Article 6(1)

text: (c) of

text: Regulation (EU) 2017/1938

text: , whereby for summer supply outlooks the 30-day period would be the period of most intensive injection of gas into storage and for winter outlooks the period foreseen in

text: Regulation (EU) 2017/1938

text: . (9) ACER reiterates its invitation to ENTSOG to consider the various roles which gas supply from UGS may play, such as the role of providing gas for covering baseload and the role of providing gas for peak demand shaving, and highlighting its findings in upcoming Winter and Summer Outlooks , HAS ADOPTED THIS OPINION:

text: 1. ACER is of the view that ENTSOG’ Summer Supply Outlook 2021 meets the objectives of

text: Regulation (EU) 2019/942

text: and

text: Regulation (EC) No 715/2009

text: in terms of contributing to non-discrimination, effective competition and the efficient and secure functioning of the internal natural gas market.

text: 2. ACER invites ENTSOG to carry out supplemental modelling analyses aimed at identifying, by analogy to

text: Regulation (EU) 2017/1938

text: , Member States which could be exposed to the risk of not achieving at least 80% level of gas in storage in case of a gas supply disruption over a 30-day period of most intensive injection of gas into storage. ACER would appreciate if ENTSOG could inform ACER in due time about the results of the supplemental analysis, in view of notifying the relevant Competent Authorities in the potentially concerned Member States, if any. This Opinion is addressed to ENTSOG. Done at Ljubljana, on 27 July 2021. - SIGNED - Fоr the Agency The Director C. ZINGLERSEN


text: Opinion No 06/2022

text: OJ L158, 14.6.2019, p. 22. 2 https://2022.entsos-tyndp-scenarios.eu/wp-content/uploads/2022/04/TYNDP2022_Joint_Scenario_Full- Report-April-2022.pdf

text: Opinion No 06/2022

text: https://www.entsoe.eu/events/2020/07/03/webinar-on-final-tyndp2020-scenarios/ 4 https://www.entsoe.eu/events/2020/12/02/entso-e-entsog-tyndp-2022-scenarios-draft-storyline-reportstakeholder-consultation-workshop/ 5 https://www.entsoe.eu/events/2021/10/20/entso-e-entsog-tyndp-2022-draft-scenarios-report-stakeholderconsultation-workshop/ 6 https://2022.entsos-tyndp-scenarios.eu/wp-content/uploads/2022/04/WGSB-2022_Stakeholder-Meeting-Log- FINAL.xlsx 7 https://2022.entsos-tyndp-scenarios.eu/wp-content/uploads/2021/11/20Oct21_TYNDP2022-Draft-Scenario- Report-Consultation-Workshop-QA-Form.pdf

text: Opinion No 06/2022

text: https://documents.acer.europa.eu/Official_documents/Acts_of_the_Agency/Opinions/Opinions/ACER%20Opin ion%2010-2018%20on%20the%20ENTSO- E%20and%20ENTSOG%20draft%20TYNDP%202018%20Scenario%20Report.pdf 9 https://documents.acer.europa.eu/Official_documents/Acts_of_the_Agency/Opinions/Opinions/ACER%20Opin ion%2006-2020%20on%20ENTSO- E%20and%20ENTSOG%20draft%20TYNDP%202020%20Scenario%20Report.pdf 10 https://eepublicdownloads.azureedge.net/clean-documents/Publications/ENTSO- E%20general%20publications/201022_ENTSO-E_AWP_2021.pdf

text: Opinion No 06/2022

text: Opinion No 06/2022

identifier: ACER Opinion No 06/2022

title: ACER Opinion 06-2022 on the Key Elements of ENTSO-E and ENTSOG Draft TYNDP 2022 Scenario Report

text: OPINION No 06/2022 OF THE EUROPEAN UNION AGENCY FOR THE COOPERATION OF ENERGY REGULATORS of 15 July 2022 on key elements of ENTSO-E and ENTSOG draft TYNDP 2022 Scenario Report

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 (“ACER”) and, in particular,

text: Articles 4(3)

text: (b) and 4(5) thereof, Having regard to the outcome of the consultation with ACER’s Electricity and Gas Working Groups, Having regard to the favourable opinion of the Board of Regulators of 13 July 2022, delivered pursuant to

text: Whereas:

text: 1. INTRODUCTION

text: (1) On 11 April 2022, the European Network of Transmission System Operators for Electricity (“ENTSO-E”) and the European Network of Transmission System Operators for gas (“ENTSOG”) published their joint TYNDP 2022 Scenario Report (“draft Scenario Report”).

text: Article 30(1)

text: (b) of

text: Regulation (EU) 2019/943

text: and

text: Article 8(3)

text: (b) of

text: Regulation (EC) No 715/2009

text: require ENTSO-E and ENTSOG, respectively, to adopt and publish a nonbinding Union-wide ten-year network development plan (“TYNDP”) biennially. Pursuant to

text: Article 48(1) of Regulation (EU) 2019/943

text: and

text: Article 8(10) of Regulation (EC) No 715/2009

text: , the electricity and gas TYNDPs shall include, among other features, scenario development.

text: (3) As scenario development is carried out and published as a separate activity before the preparation of the electricity and gas TYNDPs, ACER has assessed the draft Scenario Report separately from the forthcoming draft TYNDPs.

text: (4) The Agency’s assessment takes primarily into account the TYNDP requirements defined by

text: Regulation (EU) 2019/942

text: Regulation (EU) 2019/943

text: and

text: Regulation (EC) 715/2009

text: , i.e. the contribution of the TYNDPs (and specifically of their scenario development) to non-discrimination, effective competition, the efficient and secure functioning of the electricity and gas markets and a sufficient level of cross-border interconnection open to third-party access.

text: (5) Due to the reasons explained in the rest of the Opinion, the Agency’s assessment focused on a few key aspects: scenario development process, stakeholder involvement, inappropriate assumptions on some key drivers and considerations following the Russian invasion of Ukraine.

text: 2. ASSESSMENT OF THE DRAFT SCENARIO REPORT

text: Scenario development process and stakeholder involvement

text: (6) The ENTSOs organised a public consultation on scenario storylines (3 November – 15 December 2020) and a public consultation on a draft version of the scenario report (7 October - 18 November 2021). The stakeholder involvement activities included a public webinar on the TYNDP 2020 scenarios and kick-off of TYNDP 2022 scenarios on 3 July 2020, one on the draft storyline report on 2 December 2020 and a third one on the 5 6 draft scenarios on 20 October 2021. According to the information published , the ENTSOs also organised meetings with stakeholders and associations.

text: (7) ACER recognises the ENTSOs’ continued efforts to improve stakeholder interactions and appreciates the transparency on stakeholder feedback, e.g. via the publication of a question and answers document from the last webinar of 20 October 2021 .

text: (8) However, ACER continues to observe shortages, both in terms of process setting, storyline selection and stakeholder interactions, namely:

text: a. The scenario building process continues to take too long (nearly two years), increasing the risk of using obsolete data and compressing the timelines for the other TYNDP activities, as already flagged in the ACER Opinions on draft TYNDP 2018 8 9 scenario report and on the draft TYNDP 2020 scenario report ; b. Compared to the previous practice of offering five scenario storylines for stakeholders to choose from, which ACER found overly restrictive and kept under full discretion of the ENTSOs, the latter decided to completely discontinue this approach for TYNDP 2022. This means that stakeholders could not influence the identification of scenarios, but were limited to reflect on the pre-set storylines. c. Although the ENTSOs mention in the Scenario Report that NGO CAN Europe was consulted on the carbon budget for the Distributed Energy and Global Ambition scenarios, there is insufficient information on whether and how expert knowledge from other stakeholders was requested and utilised. Lack of substantial stakeholder involvement in the storyline development process (beyond providing comments and feedback on a preselected set of storylines) results in the key scenario variables potentially not reflecting the most up-to-date expertise. d. Last, the ENTSOs, similarly as for 2020 Scenario Report, again qualify their scenario report as “Final” instead of “Draft” for ACER’s Opinion. ACER reiterates that this may confuse the readers regarding ACER’s role as defined by

text: Regulation (EU) 2019/942

text: (9) As in the 2018 and 2020 scenario building, ACER again observes delays in the scenario process. The ENTSO-E Work Programme 2021 stated that the draft Scenario Report was to be developed by the end of 2021, while the actual publishing of the draft Scenario Report occurred in April 2022.

text: (10) ACER reiterates the need to have a timely scenario development, which is to be completed in the year before the preparation of the TYNDPs, after a simplified and faster process, reducing the risks linked to too early data collection.

text: Key elements of scenario development

text: (11) ACER welcomes the many improvements the ENTSOs have included in the scenario development process of the TYNDP 2022 scenarios, such as enhancements of the sector

text: coupling methodology, improvements of hydrogen considerations, prosumer modelling, etc.

text: (12) ACER notes ENTSOs’ efforts to produce a contrasting set of scenarios, but on the other hand, observes that some variables are still confined within too narrow value ranges. Especially, the determination of gas prices was in the low end of the spectrum of possible assumptions. Namely, at the study year 2030 the gas price was assumed as follows:

text: a. 4.02 eur/GJ (i.e. 14.5 eur/MWh) in the Distributed Energy (DE) scenario; b. 4.02 eur/GJ (i.e. 14.5 eur/MWh) in the Global Ambition (GA) scenario; c. 6.23 eur/GJ (i.e. 22.4 eur/MWh) in the National Trends (NT) scenario;

text: (13) Appendix VIII to the draft Scenario Building Guidelines refers to the World Energy Outlook (WEO) as a source of information, indicating that fuel prices were published in USD 2019/tonne for hard coal and USD2019/Mmbtu for natural gas, but without clearly specifying which WEO edition was used. More generally, the availability of these important assumptions only in the draft Scenario Building Guidelines and its absence in the Draft Scenario Report raises serious doubts on the transparency on ENTSOs activities and key decisions.

text: (14) As already indicated in previous ACER Opinions regarding e.g. the economic development pace, differentiated and sufficiently contrasted assumptions are essential to evaluate the uncertainties in the energy sector developments.

text: (15) The inclusion of a “higher” gas price, e.g. the 8.8 eur/GJ assumption used in the ENTSOs TYNDP scenario report 2018 for the “Distributed Generation” and “Sustainable Transition” scenarios, in at least one scenario of the TYNDP 2022, would have significantly increased the level of differentiation on this important assumption.

text: (16) In addition, the set of contrasting scenarios would greatly benefit from a slower economy scenario, as was the Current Trends scenario, used by ENTSO-E in the TYNDP 2020.

text: (17) In addition, since the differentiation between the different scenarios is not based on clear drivers, the results of project assessments are hard to correlate. This can make the decision to endorse projects often more difficult, especially in those cases where benefits and/or costs are greatly diverging between different scenarios.

text: (18) To alleviate the issue described here, ACER proposes to clearly define the contrast between key scenario drivers for future Scenario Reports, which would enable the stakeholder to understand how the scenario contrast affects the results of the project assessments.

text: Reflections on the impacts of Russian invasion of Ukraine and the following developments on the European energy scenarios

text: (19) On 24 February 2022, Russia invaded Ukraine. Despite the fact that the full aftermath of this remains unclear, it is evident that the energy prices are affected to a large extent and it is increasingly likely that (at least) the gas price will remain substantially higher than initially expected for a considerable amount of time, making especially the DE and GA scenarios implausible when it comes to gas pricing. In addition, other important aspects, such as the rate of RES integration (in line with the Fit for 55 and REPowerEU objectives), have been revised or are under revision in national policies.

text: (20) ACER acknowledges that this act of aggression materialised only during the finalisation phase of scenario development. A complete reassessment of the modelling and the scenarios may not be manageable by the ENTSOs within the “end of 2022” timeline indicated in the disclaimer of the draft Scenario Report.

text: (21) However, due to the crucial impact this will have on Europe’s energy system and infrastructure development, and considering an already existing need for improvement of the draft Scenario Report, appropriate adjustments should be swiftly undertaken.

text: (22) ACER appreciates the commendable efforts the ENTSOs are making by expanding the scope of their assessments in their security of supply analysis (e.g. both ENTSOs’ summer supply outlook). This has enhanced their operational value for decision-makers in a time of enhanced complexity and change. Along the same lines, ACER highlights that in order to enhance the operational value of TYNDPs for decision-makers, similar approaches could be highly beneficial, notwithstanding the considerable timing constraints,

text: HAS ADOPTED THIS OPINION:

text: ACER acknowledges ENTSOs continuous efforts to improve the scenario development and welcomes the opportunity to tackle the remaining issue jointly via the forthcoming TEN-E Scenario Guidelines.

text: As for the 2022 TYNDP, while recognising the extraordinarily tight timeline, ENTSOs are strongly encouraged to swiftly update at least one scenario by considering the following:

text: a. ENTSO-E should amend the gas prices considered, and, as far as they are relevant and already available at national level, updated RES integration levels. b. ENTSOG should also look into the changes of gas sources.

text: Done at Ljubljana, on 15 July 2022.

text: - SIGNED -

text: Fоr the Agency The Director

text: C. ZINGLERSEN