Although the consistency of the NDPs with the TYNDP has improved, ACER outlines a number of recommendations, which, if adopted, are expected to increase the robustness, credibility and transparency of the national and European plans.
On 22 May, the Agency for the Cooperation of Energy Regulators (ACER) published an Opinion on the consistency of the National Electricity Network Development Plans (NDPs) with ENTSO-E’s European Ten-Year Network Development Plan (TYNDP).
ACER analysed the consistency of the NDPs based on: (i) consistency of inputs (including scenario building); (ii) consistency of analytical methodology (including identification of needs, CBA); and (iii) consistency of outputs (including list of projects). ACER “positively notes that the vast majority of National Regulatory Authorities (NRAs) already (individually) assess the consistency of the NPDs in their jurisdictions with the EU TYNDP with respect to one or more of the three fundamental aspects” and only five NRAs (Cyprus, Denmark, Estonia, Norway and Romania) do not carry out individual consistency checks on any of the three aspects.
In its Opinion, ACER finds that the consistency of the NDPs with the TYNDP has improved. ACER explains the improvements relying on the following factors: (i) a more widespread practice to move the frequency of the NDP from 1 year to 2 years; (ii) a more systematic use of a multi-scenario approach (previously, about half of the NDPs were developed against a single scenario); (iii) a more widespread practice to introduce a cost benefit analysis (CBA) for projects and more benefit categories in the NDPs; and (iv) a more widespread practice to include third-party projects in the NDPs.
However, ACER also states “that some of the practices used for the overall development, review and adoption of the NDPs might negatively impact the robustness, credibility and transparency of the NDPs or could result in inconsistencies with the TYNDP”. To this end, ACER proposes a set of non-binding recommendations to ENTSO-E and to the parties responsible for the development, review and adoption of the NDPs.
Some of the proposals directed at ENTSO-E for improving the TYNDP include: (i) creating two separate Appendices for the TYNDP – one listing the mid-term and long-term projects (in the ten years to come) and the other listing the ‘future’ projects or studies (beyond ten years); (ii) the need to enrich the TYNDP with an appropriate sensitivity analysis for the near-term best-estimate scenario, while a ‘slow progress’ scenario should also be considered in the CBA; (iii) the recommendation that at least one robust scenario with a top-down approach should be developed, taking into account country specificities; and (iv) the suggestion that ENTSO-E should define reference project timelines.
As for the parties responsible for the NDPs, some of the recommendations include: (i) NDPs being prepared with a biannually; (ii) similarly to the TYNDP, the recommendation that NDPs should have two separate Appendices, one for mid- and long-term projects and one for those beyond ten years; (iii) the expansion of NDPs’ scope to allow the inclusion of third-party projects, where it is not yet the case; (iv) a strengthening of the regulatory approval role of the NRAs with regards to the NDPs and a performing a public consultation on the draft plans; (v) cross-referencing the different NDPs coding systems with the TYNDP and explicitly flagging relevant cross-border projects.
According to ACER, these measures, if adopted, will increase the robustness, credibility and transparency of the NDPs as well as their consistency with the TYNDP.