​​Every 2 years, ACER provides an opinion on the draft grid plans (called Ten-Year Network Development Plans or TYNDPs) proposed by the network operators.

In its Opinions on the draft 2020 plans, ACER finds that the electricity and gas plans (developed by ENTSO-E and ENTSOG respectively) do not sufficiently contribute to the efficient market due to several shortcomings. With respect to electricity, in ACER's view:​

• The TYNDP core building blocks such as scenarios development, infrastructure needs identification and cost-benefit analysis (CBA) implementation need to be improved. There are also shortcomings in public consultations on key elements of the methodologies used for the assessment of the energy projects being proposed by network operators.

• A number of shortcomings could be remedied by legislators in the current TEN-E reforms by strengthening the independent assessment of projects and the regulatory oversight of network operators. ACER has previously pointed to risks of lack of neutrality of the European Network of Transmission System Operators (ENTSOs) and the need for step changes in TEN-E governance to avoid conflict of interests while ensuring transparency.

See also the ACER Opinion on the ENTSOG gas network plan​.​

Shortcomings could be remedied by improving the TEN-E Regulation

The EU framework for energy infrastructure needs to be robust for cost-efficient cross-border projects which are best for the energy transition.

ACER believes that the shortcomings of the TYNDP process as can be remedied by improving the TEN-E investment framework in line with the European Green Deal. To this end, regulators (through ACER and CEER) issued two position papers, one in March 20​21 and one in June 202​​0 on how to improve the revision of TEN-E Regulation including on infrastructure development governance.

ACER has called on the European co-legislators to consider the regulators' proposals as a solution to promote a neutral technical assessment of infrastructure projects in line with the European Green Deal, avoiding risks of unjustified costs to European consumers.

For example, currently the transmission system operators (TSOs), through the European Network of Transmission System Operators (ENTSOs), develop the scenarios to assess projects in different futures. TSOs can be perceived as biased towards favouring more infrastructure as it is in their interest. The neutrality of scenarios and the credibility of the TYNDP process can thus be compromised. To safeguard neutrality, regulators have proposed the introduction of ACER framework guidelines for TYNDP scenarios for the ENTSOs to follow. This has been taken up in the European Commission's legislative proposals but should be further strengthened and streamlined, as suggested by regulators.

Europe's energy regulators have pointed to the need for strengthened regulatory scrutiny over the ENTSO's to safeguard the public interest, for ACER to be given the powers to approve the methodologies for the Cost-Benefit Analysis (CBAs) and to issue binding guidelines to the ENTSOs for the TYNDP development.

What are ACER's key findings of the 2020 draft electricity TYNDP?

ACER has issued two Opinions on the European Network of Transmission System Operators for Electricity (ENTSO-E) TYNDP 2020, one on methodological aspects of the electricity TYNDP 2020 and one on the TYNDP projects.

The ACER Opinions are addressed to ENTSO-E, the European Commission, the European Parliament and the Council.

What are the key improvements in the 2020 draft electricity TYNDP?

The ACER Opinions acknowledge that the TYNDP process is complex and resource intensive, and needs to be carried out within a two-year timeframe. For the elec​tricity TYNDP, ACER welcomes a number of improvements for instance in the so-called Inclusion Guidelines, the data collection process, the needs identification, and the transparency of the CBA assessment.

What are the key shortcomings of the 2020 draft electricity TYNDP?

ACER's opinion notes limited improvements and evolution of the draft plan in comparison to previous TYNDP and identifies 4 main shortcomings:

1. Delays of scenario development process and lack of data release which compromised the integrity of the TYNDP.

2. Unbalanced CBA due to the missing, non-traceable Current Trends scenario.

3. Lack of CBA analysis after the study year 2030.

4. Poor and insufficient consultations of the scenarios methodology and of the needs methodology.

​​In ACER's opinion the draft electricity TYNDP 2020 does not sufficiently contribute to the objective of efficient functioning of the market.

What does ACER recommend for improving future electricity TYNDPs?

ACER encourages the ENTSOs to address the remaining shortcomings and stands ready to provide guidance or clarifications where needed. ACER proposes several recommendations to ENTSO-E in pursuit of an efficient, further integrated and transparent network planning to serve European consumers and Europe's decarbonisation and sector integration ambitions:

For the Final Electricity TYNDP 2020

1. Provide the storyline and full data for the missing Current Trends scenario.

2. Publish the baseline capacities per border as used in the starting grid for the needs exercise and in the reference grids for the CBA calculations.

3. Include a Benefit / Cost ratio and Net Present Value calculation for all projects for each of the four scenarios.

For the Electricity TYNDP 2022 and beyond

1. Restructure the scenario development process in order to be completed by December of the year before the TYNDP.

2. Involve relevant stakeholders and experts in the development of scenario assumptions.

3. Ensure transparency of scenario development and availability of scenario data. All scenarios should be used in the needs exercise and the CBA analysis in a balanced way, using the premise of economic growth.

4. Early and substantial consultation of the needs methodology (including important parameters like the horizons to be studied, the zones modelling, the climatic years to be used).

5. Define an appropriate starting network for the needs identification.

6. Duly implement the provisions of the TYNDP Inclusion Guidelines - non-compliant projects should be excluded.

7. Consider the impact of the 70% minimum interconnection capacity target in the modelling of the power system, where relevant.

8. Transfer capacities should be calculated for all projects and with more granularity and transparency.

9. Consult the main elements of the TYNDP CBA (e.g. study horizons, criteria for the construction of the reference grid, scope of the CBA) before the inclusion of projects in the future TYNDP.

10. Build the reference grid considered for the CBA analysis, according to the Agency's recommendations.

11. ENTSO-E should extend the study horizons for which a CBA analysis is conducted for the TYNDP 2022 at least to one study year after 2030 (e.g. 2035 or 2040).

What is the TYNDP?

The main objectives of the TYNDP are to:​

• identify investment gaps (including cross border capacities

• contribute to a sufficient and non-discriminatory level of cross-border interconnections, the effective competition and the efficient functioning of the market, and

• ensure a greater transparency of the European electricity transmission network.

​The TYNDP builds on national investment plans prepared by the transmission system operators (TSOs) and takes into account the regional investment plans, published every two years.

Projects of Common Interest (PCIs) are selected from the TYNDP via a separate process led by the European Commission. The TYNDP should provide essential and comprehensive information for the selection of PCIs, in particular through complete, monetised, and reliable cost-benefit analysis (CBA) and assessment of projects.

What is the role of ACER and its overall assessment?

ACER issues an opinion on the draft network plan developed by network operators taking into account the objectives of non-discrimination, effective competition, and the efficient and secure functioning of the internal electricity market.

Every 2 years, ACER provides a non-binding opinion on the draft grid plans (called Ten-Year Network Development Plans or TYNDPs) proposed by the network operators.

In its Opinions on the draft 2020 plans, ACER finds that the electricity and gas plans (developed by ENTSO-E and ENTSOG respectively) do not sufficiently contribute to the efficient market due to several shortcomings. With respect to gas,​ in ACER's view:

• Too many conventional gas projects - close to €75 billion – are proposed by network operators and not all are assessed by ENTSOG. Despite ongoing efforts, the framework also fails to properly assess the contribution of gas projects to sustainability.

• The TYNDP core building blocks need to be improved such as scenarios development and cost-benefit analysis (CBA). There are also shortcomings in public consultations with stakeholders on key elements of the energy projects being proposed by network operators.

• A number of shortcomings could be remedied by legislators in the current TEN-E reforms by strengthening the independent assessment of projects and the regulatory oversight of network operators. ACER has previously pointed to risks of lack of neutrality of the two European Networks of Transmission System Operators (ENTSOs) and the need for step changes in TEN-E governance to avoid conflict of interests while ensuring transparency.

See also the ACER Opinion on the ENTSO-E electricity network plan.​

Shortcomings could be remedied by improving the TEN-E Regulation

The EU framework for energy infrastructure needs to be robust for cost-efficient cross-border projects which are best for the energy transition.

ACER believes that the shortcomings of the TYNDP process as can be remedied by improving the TEN-E investment framework in line with the European Green Deal. To this end, regulators (ACER and CEER) issued two position papers, one in March 2021 and one in June 2020​ on how to improve the revision of TEN-E Regulation including on infrastructure development governance.

ACER has called on the European co-legislators to consider the regulators' proposals as a solution to promote a neutral technical assessment of infrastructure projects in line with the European Green Deal, avoiding risks of unjustified costs to European consumers.

For example, currently the transmission system operators (TSOs), through the European Network of Transmission System Operators (ENTSOs), develop the scenarios to assess projects in different futures. TSOs can be perceived as biased towards favouring more infrastructure as it is in their interest. The neutrality of scenarios and the credibility of the TYNDP process can thus be compromised. To safeguard neutrality, regulators have proposed the introduction of ACER framework guidelines for TYNDP scenarios for the ENTSOs to follow. This has been taken up in the European Commission's legislative proposals but should be further strengthened and streamlined, as suggested by regulators.

Europe's energy regulators have pointed to the need for strengthened regulatory scrutiny over the ENTSO's to safeguard the public interest, for ACER to be given the powers to approve the methodologies for the Cost-Benefit Analysis (CBAs) which are used to assess projects, and to issue binding guidelines to the ENTSOs for the TYNDP development.

What are ACER's key findings of the 2020 draft gas TYNDP?

ACER has issued an Opinion on the European Network of Transmission System Operators for Gas (ENTSOG) TYNDP 2020 for gas. The ACER Opinion is addressed to ENTSOG, the European Commission, the European Parliament and the Council.

ACER finds that the draft gas TYNDP 2020 follows a similar methodology as previous editions.

What are the key improvements in the 2020 draft gas TYNDP?

ACER's opinion notes limited improvements and evolution of the draft plan in comparison to previous TYNDP. Improvements are mainly limited to a better presentation of results and for the first time, the inclusion of a heterogeneous category of projects addressing the energy transition. ACER concurs with ENTSOG that current gas infrastructure in Europe is resilient, near to the completion of the internal gas market and that the limited infrastructure investment gaps will be closed in the next five years by projects already currently under development.

What are the key shortcomings of the 2020 draft gas TYNDP?

ACER regrets that the TYNDP includes a broad investment portfolio of conventional gas projects close to € 75 billion, clearly exceeding reasonable needs, in view of the lack of market appetite for developing additional transmission capacities and the decarbonisation objectives. Less than half of these are assessed by ENTSOG in the TYNDP framework. As regards the sustainability assessment of projects, although progress in observed in this TYNDP, there is room to refine it further in the future.

ENTSOG should consider ways to increase stakeholders' interest and engagement in the TYNDP development process, in view of the low number of responses (9) received during its public consultation.

ACER identifies 4 main shortcomings:

1. Lack of proper analysis of the existing and forecasted use of gas infrastructure as critical criterion to take into account when analysing the need of additional gas infrastructure.

2. Shortcomings in the applied methodologies, such as a lack of a complete quantitative needs assessment and doubtful quality of the cost-benefit analysis (CBA) methodology and its application which still requires improvement to demonstrate benefits exceed costs so that each individual gas project contributes to sustainability.

3. The asymmetric treatment of candidate projects depending on whether the projects are intending to apply for Project of Common Interest (PCI) selection or not. ACER expects ENTSOG to apply project-specific cost-benefit analysis for all projects, the same way it is done for the electricity.

4. Shortcomings in the public consultations of the scenarios methodology and the needs methodology.

In ACER's Opinion the draft gas TYNDP 2020 does not sufficiently contribute to the objectives of non-discrimination and efficient functioning of the market.

What does ACER recommend for improving future gas TYNDPs?

ACER is of the view that improvements in European infrastructure planning are feasible. ACER encourages the ENTSOs to address the remaining shortcomings and stands ready to provide guidance or clarifications where needed. ACER proposes several recommendations to ENTSOG in pursuit of an efficient, further integrated and transparent network planning at the service of consumers, decarbonisation, and sector integration ambitions:

For the Final Gas TYNDP 2020

• Consider the National Regulatory Authority's (NRA's) comments on the TYNDP 2020 projects

• Provide a feedback document on how the Public Consultation and ACER's Opinion have been taken into account

• Classify the energy transition projects into gas supply/ production projects and network related investments

• Complete information related to project CBA assessments

• Update information on projects' status by end of year 2020

For the Gas TYNDP 2022 and beyond

• Implement ACER's recommendations on scenarios

• Improve planning process to avoid recurring delays, by publishing next TYNDP by mid-2022

• Incorporate the market perspective on infrastructure gaps

• Improve the implementation of CBA methodology

• Include a number of “conventional" gas infrastructure projects commensurate to the assessed needs, by flagging and filtering out unrealistic projects during the data collection stage

• Roll out modelling tools allowing for sector-integrated assessments of electricity and gas projects

• Provide the same (maximum) level of cost transparency for all TYNDP regulated projects

• More attention focused on adaptations of gas infrastructure for the injection of higher shares of renewable, low carbon and de-carbonised gases (hydrogen, synthetic methane, and bio-methane)

• Together with ENTSO-E, identify suitable locations for power-to-gas installations in the system needs analysis

• Factor the level of utilisation and congestion of existing infrastructure in the needs assessment

• Consider ways of covering methane emissions associated with gas infrastructure

What is the TYNDP?

Every two years, ENTSOG publishes a non-binding TYNDP which looks forward over a ten-year horizon and includes a European supply adequacy outlook for natural gas. TYNDPs are essential for assessing and identifying the need of new infrastructure projects to ensure an adequate level of security of gas supply, market integration and competition. The TYNDP must be consistent with National Development Plans (NDPs) and should take into account the energy policy objective of decarbonisation under the European Green Deal.

Projects of Common Interest (PCIs) are selected from the TYNDP via a separate process led by the European Commission. The TYNDP should provide essential and comprehensive information for the selection of PCIs, in particular through complete, monetised, and reliable cost-benefit analysis (CBA) and a sustainability assessment of projects.

What is the role of ACER and its overall assessment?

ACER monitors the development and execution of the plan, and issues an opinion on the draft TYNDP taking into account the objectives of non-discrimination, effective competition, and the efficient and secure functioning of the internal gas market. ACER also looks to the alignment of the plan with broader energy transition and decarbonisation goals.

ACER organises this online webinar to present the results of the methodological study aimed at identifying and measuring barriers to the development of competitive electricity prices and the entry and participation of new market players in the EU electricity wholesale markets.

Access the webinar's Agenda.

Registration is closed, as the event reached its full capacity.​

The study – which has been carried out with the support of a consultant over several months – will enable ACER to fulfil effectively its new monitoring responsibilities set in the Clean Energy Package. In particular, the study has defined some indicators to be progressively included in future editions of ACER's Annual Report on the Results of Monitoring the Internal Electricity and Natural Gas Markets (the so called Market Monitoring Report​).

This study has benefited from inputs collected from a wide range of stakeholders through a public consultation and some interviews. In this webinar, stakeholders will get information about the barriers identified, the indicators to measure them and the methodology to combine these indicators. ​

Following a six-month consultation with stakeholders and with the objective to contribute to the improvement of REMIT data reporting, ACER published updated REMIT guidance.

It comprises a new version of Annex II of the Transaction Reporting User Manual (TRUM) and of Annex VII of the Manual of Procedures on data reporting, as well as the updated frequently asked questions (FAQs) on transaction reporting and on fundamental data and inside information.

Annex II of TRUM describes several examples of transaction reporting (including orders to trade) related to contracts reportable to ACER, pursuant to the REMIT Implementing Regulation.

More specifically this new publication aims to:

• ensure consistency with the TRUM (main text) v.4.0 published in June 2020
• reflect the market design evolution by adding new examples on market coupling
• include additional examples based on ACER's analysis and the interaction with NRAs and stakeholders.

​Consulted stakeholders include associations of market participants, organised market places, and registered reporting mechanisms.

Access the new version of Annex II of the Transaction Reporting User Manual.

ACER also published ​the updated Annex VII of the Manual of Procedures (MoP) on Data Reporting, describing data fields for inside information and the new electronic formats for reporting. The changes reflect the results of the ACER's Public Consultation on the revision of electronic formats.​

Finally, ACER published the 12th edition of the FAQs on REMIT transaction reporting and the 7th edition of the FAQs on fundamental data and inside information, which include new frequently asked questions to better reflect the continuous evolution of EU markets and facilitate data reporting.

Find the new versions of the FAQ documents on the REMIT Portal.

Today, the European Union Agency for the Cooperation of Energy Regulators (ACER) has opened a public consultation on its draft Framework Guideline on sector-specific rules for cybersecurity aspects of cross-border electricity flows, inviting stakeholders to share their views on the document ahead of its submission to the European Commission.

The non-binding Framework Guidelines will set out clear and objective principles for the development of a binding Cybersecurity Network Code that will contribute to maintain the security of the electricity system across Europe.  As such, the proposed Framework Guideline covers various security-related topics for the electricity sector, such as cross-border risk management, harmonized minimum cybersecurity, information sharing, incident handling and crisis management.

The public consul​tation will run from 30th April ​until 29th June 2021​.

To learn more and submit your views, visit the P​ublic Consultation webpage​.

Upcoming webinar​: ACER will also organise a workshop to introduce and explain the content of the proposed Framework Guideline in May 2021. More information will be published soon on the  ACER​​ website.

Background information

The Electricity Market Regulation provides the legal basis for the establishment of cybersecurity rules in the context of cross-border electricity flows. On 28 January 2021, the European Commission invited ACER to draft the Framework Guidelines for a Network Code on Cybersecurity.