ACER Opinion 04-2023 on electricity projects in the draft ENTSO-E TYNDP 2022 and in the National Development Plans (NDPs)
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OPINION No 04/2023 OF THE EUROPEAN UNION AGENCY FOR THE COOPERATION OF ENERGY REGULATORS of 4 April 2023 on electricity projects in the draft ENTSO-E Ten-Year Network Development Plan 2022 and in the National Development Plans
THE EUROPEAN UNION AGENCY FOR THE COOPERATION OF ENERGY REGULATORS, Having regard to Regulation (EU) 2019/942 of the European Parliament and of the Council of 5 June 2019 establishing a European Union Agency for the Cooperation of Energy Regulators , and, in particular, Articles 4(3)(b) and Article 4(5) thereof, Having regard to Regulation (EU) 2019/943 of the European Parliament and of the Council of 5 June 2019 on the internal market for electricity, and, in particular, Article 32(1), Article 32(2) and Article 48(2) thereof, Having regard to the outcome of the consultation with the Agency’s Electricity Working Group, Having regard to the favourable opinion of the Board of Regulators of 29 March 2023, delivered pursuant to Article 22(5) of Regulation (EU) 2019/942, Whereas: 1. INTRODUCTION (1) Article 32(2) of Regulation (EU) 2019/943 requires the European Network of Transmission System Operators for Electricity (‘ENTSO-E’) to submit the draft Unionwide network development plan (‘the EU TYNDP’) to the European Agency for the Cooperation of Energy Regulators (‘the Agency’) for its opinion. (2) Pursuant to Article 4(3)(b) of Regulation (EU) 2019/942, the Agency may provide an opinion to ENTSO-E, in accordance with the first subparagraph of Article 32(2) of Regulation (EC) 2019/943, on the EU TYNDP, taking into account the objectives of non-
OJ L158, 14.6.2019, p. 22.
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Opinion No 04/2023
discrimination, effective competition and the efficient and secure functioning of the internal markets in electricity and natural gas. (3) Pursuant to Article 4(5) of Regulation (EU) No 2019/942, the Agency shall, based on matters of fact, provide a duly reasoned opinion as well as recommendations to ENTSO- E, the European Parliament, the Council and the Commission, where it considers that the draft TYNDP does not contribute to non-discrimination, effective competition and the efficient functioning of the market or a sufficient level of cross-border interconnection open to third-party access, or do not comply with the relevant provisions of Regulation (EU) 2019/943 and Directive (EU) 2019/944. (4) The second subparagraph of Article 32(2) of Regulation (EU) 2019/943 requires that the Agency provides, within two months from the day of receipt, a duly reasoned opinion as well as recommendations to ENTSO-E and to the Commission where it considers that the draft TYNDP submitted by ENTSO-E does not contribute to non-discrimination, effective competition, the efficient functioning of the market or a sufficient level of crossborder interconnection open to third-party access. (5) Article 48(2) of Regulation (EU) 2019/943 tasks the Agency to assess the consistency of the national ten-year network development plans (‘the NDPs’) with the EU TYNDP. If the Agency identifies inconsistencies between a NDP and the EU TYNDP, it shall recommend amending the NDP or the EU TYNDP as appropriate. If such NDP is elaborated in accordance with Article 51 of Directive (EU) 2019/944 of the European Parliament and of the Council, the Agency shall recommend that the competent national regulatory authority (‘NRA’) amend the NDP in accordance with Articles 51(7) and 51(8) of that Directive and inform the Commission thereof. (6) Article (11) points a) and b) of Regulation (EU) No 2019/943 tasks the Agency with monitoring the progress regarding the implementation of investments to create new interconnection capacity and the implementation of the EU TYNDP. (7) In addition, recital (12) of Regulation (EU) No 2019/943 emphasises the Agency’s essential role in monitoring regional cooperation between transmission system operators (‘TSOs’) as well as the execution of the tasks of ENTSO-E, to ensure that the cooperation between TSOs proceeds in an efficient and transparent way for the benefit of the internal market in electricity. (8) The Agency considers as ‘national ten-year network development plans’ pursuant to Article 48 of Regulation (EU) 2019/943 all relevant network planning instruments, even if they are referred to with a different title (e.g. investment plan) or a different time span. (9) This Opinion provides the Agency’s assessment on the projects included in the draft EU TYNDP 2022, including an assessment of consistency of the projects in the NDPs of the EU Member States and an European Economic Area (‘EEA’) Member State (Norway) with the projects in the draft EU TYNDP 2022.
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Opinion No 04/2023
2. PROCEDURE (10) On 25 November 2022, the Agency invited the NRAs of EU Member States and other NRAs participating in the relevant Agency’s working structures to review projects and corresponding investments in the already published version of the draft EU TYNDP 2022 which are located on the territory of their country and assess them, including their consistency with projects in NDPs. (11) On 31 January 2022, ENTSO-E submitted the draft EU TYNDP 2022 to the Agency. Following the formal submission of the draft TYNDP 2022 by ENTSO-E to the Agency, the Agency consolidated its findings based on the data corresponding to the formal submission. (12) In this regard, the Agency notes that the publicly consulted version of the draft EU TYNDP 2022 does not include transmission investments 1832, 1833, 1834, 1835 and 1836 (all belonging to project 259 ‘HU-RO’ interconnection), which appear in the version submitted to the Agency. Based on the information provided by the Romanian NRA, all these investments were reported under investment number 1205 in the publicly consulted version, but following the TSO’s request at the end of 2022, the investments were separated. In addition, investment 1826 (at least under this code) has been removed compared to the publicly consulted version. (13) NRAs have provided the Agency with specific information on the national parts of transmission investments and storage projects that are/were: included in the draft EU TYNDP 2022, included in the EU TYNDP 2020, but not in the draft EU TYNDP 2022 and cross-border relevant and appear in their NDPs, but not in the draft EU TYNDP 2022. (14) The data collection from NRAs was completed on 14 March 2023. By this date, NRAs from 27 EU Member States and one EEA Member State (Norway) provided input to the Agency. The list of the participating countries along with the number and share of the reviewed transmission investments and storage projects is presented in Table 8 in Annex I.
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Opinion No 04/2023
(15) Out of the 314 transmission investment items and storage projects included in the draft EU TYNDP 2022, the Agency reviewed NRA responses for 262 investments regarding their consistency with the latest national development plans. 58 investment items belong to more than one country and are, therefore, reviewed by more than one NRA, leading to a total assessment of 348 national parts of transmission investments and storage projects (325 investment items and 23 storage projects). 3. GENERAL INFORMATION ABOUT THE PROJECTS IN THE DRAFT EU TYNDP 2022 (16) The draft EU TYNDP 2022 contains an assessment and a description of 141 transmission projects, with 291 corresponding investment items and 23 storage projects. The Agency notes that additional four transmission and three storage projects applied for inclusion in the draft EU TYNDP 2022, but were rejected due to non-compliance with the draft EU TYNDP 2022 project Inclusion Guidelines (‘Inclusion Guidelines’). Table 1 illustrates the number of transmission projects and investments as well as storage projects of the draft EU TYNDP 2022 compared to the previous four EU TYNDPs.
Table 1: Number of transmission and storage projects in the draft EU TYNDP 2022 and in the four previous EU TYNDPs
EU EU EU EU Draft EU TYNDP TYNDP TYNDP TYNDP TYNDP
2014 2016 2018 2020 2022
Number of projects 127 168 165 154 141
Transmission
Number of investments 371 420 359 321 291 Storage Number of projects 11 23 20 26 23
(17) The classification of the transmission projects according to the number of investment items included in each project in the draft EU TYNDP 2022 is presented in Table 2.
Table 2: Classification of transmission projects in the draft EU TYNDP 2022
Number of transmission projects in the draft EU TYNDP 2022
Projects consisting of 1 investment 89 Projects consisting of 2 investments 23 Projects consisting of 3 investments 9 Projects consisting of 4 investments 7 Projects consisting of 5 investments 6 Projects consisting of 6 investments 2 Projects consisting of 7 investments 2 Projects consisting of 9 investments 1 Projects consisting of 12 investments 1
The remaining investments were not reviewed, as they do not belong to a territory of an EU/EEA Member State. https://eepublicdownloads.blob.core.windows.net/public-cdn-container/tyndpdocuments/TYNDP2022/portfolio/220121_TYNDP2022_draft_project_portfolio.xlsx
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Number of transmission projects in the draft EU TYNDP 2022
Projects consisting of 24 investments 1
(18) The Agency acknowledges the reduction of the average number of investment items per project over time which is considered a positive sign of increased efforts to avoid over clustering of investments. (19) Table 3 represents the total number as well as the total costs of transmission investment items and storage projects according to their status, as provided in the draft EU TYNDP 2022 project sheets.
Table 3: Cost of transmission investments and storage projects according to their status
Transmission investments Storage projects Investment status Cost Cost Number Number (billion EUR) (billion EUR)
Under consideration 83 62.56 10 3.52 Planned, but not yet in permitting 89 23.94 1 0.47 In permitting 71 42.33 12 4.85 Under construction 39 5.06 0 0
Total 282 133.89 23 8.84
(20) The Agency notes that in 2022, the declining trend of the number of transmission investments and the related costs in the EU TYNDP since 2016 further continues . While the share of investments in advancement status ‘under consideration’ remains at 30% and ‘in permitting’ around 25%, the shares of the ‘planned, but not yet in permitting’ and ‘under construction’ slightly changed, i.e. increased by 6 % and decreased by 5 % respectively. Moreover, the number of storage projects in the draft EU TYNDP 2022 slightly decreased after its increase two years ago and the corresponding costs almost halved.
The average number of investments per project has gradually decreased from 2.92 for the TYNDP 2014 to 2.06 for the draft TYNDP 2022. For TYNDP 2020, the average number was 2.08. 9 investments are not included in the table, because according to the information provided in the draft EU TYNDP, they have already been completed or commissioned. 8 The total transmission investment cost does not include the total cost of investments 474 ‘Substation Ribeira de Pena’ and 1214 ‘Ejea de los Caballeros substation’ and operational expenditure (OPEX) of investments 1785 ‘Inkoo-Hikiä’, 1810 ‘HVDC converter stations and cables’, 1811 ‘Offshore Wind Connection Centre Manche 2’, 1812 ‘Offshore Wind Connection South Britanny’, 1808 ‘AO6 Occitanie’, 1809 ‘AO6 Occitanie’ and 1813 ‘Offshore wind connection South Atlantic’ which are not reported or reported to be 0 EUR in the draft EU TYNDP 2022. For an assessment of whether the investments of the draft EU TYNDP 2022 are sufficient to reach the decarbonisation objectives, please refer to the Agency’s Opinion 03/2023 and the TYNDP 2022 System Needs Study carried out by ENTSO-E.
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(21) The Agency notes that the draft EU TYNDP 2022 reports 27% of these investments are new, 45% are on time, 3 % are ahead of time, 14% are delayed and 11 % are rescheduled compared to the TYNDP 2020. (22) The Agency finds that at least one interconnection investment, i.e. investment 1772 ‘Roost-Flebour-Bauler’ has a different status across the borders. In Luxembourg, the national part of the investment is completed, while in Germany it is ‘planned, but not yet in permitting’. A difference in investment status across borders does not necessarily constitute an inconsistency, but could point to limited cross-border coordination, which may be improved. (23) The Agency also identified some interconnections (which have been fully monitored in this Opinion and already achieved at least ‘planned, but not yet in permitting’ status) for which NRAs indicated different commissioning dates for the implementation of their national parts . However, in none of these instances the difference exceeds one year. Also here, the Agency notes that the smaller difference across commissioning dates is not necessarily an inconsistency, though the Agency would expect commissioning dates of interconnectors to be reasonably aligned. (24) A total number of 92 transmission investments and 10 storage projects were present in the TYNDP 2020 but not in the draft EU TYNDP 2022. Out of these, 78 transmission investments and 7 storage projects are at least partly located on the territory of an EU or EEA Member State. Out of these 78 transmission investments and 7 storage projects, approximately 30% are commissioned and another 30% cancelled. Around 10% were not compliant to the Inclusion Guidelines, while the remaining are still under development or their status is not available to the NRA. (25) In addition to the cross-border relevant investments identified by NRAs during former investment review activity (which are neither included in the TYNDP 2020 nor in the draft EU TYNDP 2022), the participating NRAs reported on six cross-border relevant investments not included in the draft TYNDP 2022, but in the relevant NDPs. (26) For about 51% out of the 291 transmission investment items in the draft EU TYNDP 2022, the NRAs indicated no difference between the features of the investment as included or present in the latest NDP and the draft EU TYNDP 2022 (or the difference resulted from the fact that their NDP is outdated). For about 20%, at least some difference was identified. Approximately 29% were not able to be assessed on any aspect by the NRAs mainly due to their absence in the NDP. These investments are listed in Table 9 in Annex I. Most of them are in a very early stage of development.
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Opinion No 04/2023
(27) Figure 1 represents the shares of various inconsistencies between the information provided in the draft EU TYNDP 2022 and the latest NDPs, as indicated by the NRAs. The main inconsistency between transmission investment items included in the latest NDP and draft EU TYNDP 2022 is a different expected commissioning (23 instances), followed by different costs (20 instances), different clustering (13 instances), different status (13 instances), different progress (6 instances) and technical features (4 instances). Detailed information is provided in Table 10 in Annex I.
Figure 1: Differences between the information provided in the draft EU TYNDP 2022 and the latest NDP
Other difference Technical features 5% 5%
Clustering Costs 15% 24%
Commissioning date Progress (and 28% the reason) 7% Status 16%
(28) The Agency acknowledges that the NDPs and the EU TYNDP may temporarily be misaligned due to different schedules for the elaboration of the plans and other reasons (e.g. changes in market fundamentals), which, to some extent, can explain the identified differences and does not necessarily constitute an inconsistency between the plans. (29) For vast majority of investments with a clearly identified difference in the commissioning dates , the commissioning date reported in the draft EU TYNDP 2022 was an earlier date compared to the NRA’s information. Furthermore, for half of the (non-yet commissioned) investments with different advancement status, NRAs identified a more advanced status in the draft EU TYNDP 2022 compared to their information.
Not accounting for those instances where the NRA provided a range for the commissioning date matching also the date provided in the draft TYNDP 2022 or where the NRA flagged a difference without providing a commissioning date.
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Opinion No 04/2023
(30) Regarding storage projects, the Agency notes that no difference has been identified by the NRAs for 4 projects and the remaining projects the NRA was not able to assess. (31) In order to increase the accuracy of the project and investment data of the draft EU TYNDP 2022, the Agency considers it important that the NRA scrutiny of the projects provided in Annex I to this Opinion, is taken into account for the final EU TYNDP 2022, as appropriate. 4. ASSESSMENT OF THE PROJECTS IN THE NDPS AND THE EU TYNDP Investments in the draft EU TYNDP 2022 which are not included in the respective NDP(s) (33) The Agency welcomes the improved transparency regarding the information on the inclusion of a specific project in the respective NDPs (e.g. inclusion of this information in the excel project sheets, provision of the reasons for non-inclusions for some projects), however, it regrets that information on the non-inclusion along with the corresponding reason is not provided for all projects. (34) According to the information provided by NRAs, 80% of the 325 national parts of transmission investments are included in the relevant NDPs , while 20% are not. The summary of reasons for these absences is provided in Figure 2. The most common reason for the absence is an earlier elaboration of the NDP than of the draft EU TYNDP (19 instances), followed by the commissioning date of the investment being beyond the time span of the NDP (15 instances), an insufficient advancement of the investment (12 instances), the investment having been commissioned (10 instances), the investment appertaining to a non-TSO project while such projects are normally not included or present in NDP (9 instances). Additional information is provided in Table 11 in Annex I.
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Opinion No 04/2023
Figure 2: Reasons for the absence of transmission investments in the draft EU TYNDP in the relevant NDPs
commissioning date beyond the an earlier elaboration of the time span NDP 23% 29% non-TSO project or a storage insufficient project advancement 14% 19% commissioning 15%
(35) Regarding the storage projects, 17 projects out of the 23 are not included in the relevant NDPs , mainly because they appertain to a non-TSO storage project (14 instances). The remaining absences are due to an earlier elaboration of the NDP than of the draft EU TYNDP 2022 (2 instances) and an insufficient advancement of the project (e.g. study not having turned into a project yet). More detailed information is provided in Table 12 in Annex I. (36) The Agency reiterates its view that actual implementation of the EU TYNDP transmission projects strongly relies on the NDPs. Non-inclusion of a transmission project (or part of it) in the NDP due to other reasons than the commissioning of a project, cancellation of a project, time difference in the elaboration of the plans or the limited scope of the NDP (e.g. when it does not include third-party projects) raises doubts about the credibility and feasibility of the implementation of the concerned projects. Therefore, the reason for non-inclusion in the NDP is an important information regarding the TYNDP transmission projects. Project’s non-inclusion in the NDP should clearly be flagged and the reason for such absence should be provided in the EU TYNDP. Further, the Agency recalls its view that the NDPs’ scope should include third-party projects .
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Opinion No 04/2023
Investments with cross-border relevance not included in the draft EU TYNDP 2022 (37) Table 4 provides information on the current status or presence in the respective NDPs of one French-Italian, three Italian and two Romanian cross-border relevant transmission investments which were not included in the TYNDP 2020 nor are in the draft EU TYNDP 2022.
Table 4: Investments with cross-border relevance identified by NRAs during former investment review activity, but neither included in the TYNDP 2020 nor in the draft EU TYNDP 2022
Investment name Reporting countries Additional information by the NRA
HVDC Italy-France France and Italy commissioning expected in 2023 project no longer present in the Italian Italy - Switzerland S. Giacomo project Italy draft NDP 2023 Italian-Austrian interconnection project is planned but not yet in Italy ‘Dobbiaco (IT) – Austria (AT)’ permitting project rescheduled due to permitting Italian substation in Volpago Italy difficulties, currently ‘planned, but not yet in permitting’ OHL 400kV Oradea – Nadab Romania commissioned in 2021 OHL Nadab-Bekescsaba circ. 2 and works Romania no longer in the NDP in Nadab 400kV substation
(38) NRAs reported on the following four additional cross-border relevant investments that are included in the relevant NDP as a planned or more advance investment, but do not appear in the draft EU TYNDP 2022: Italian-Swiss AC line ‘Regoledo (IT) – Switzerland’, project ‘planned, but not yet in permitting’, Polish-Ukranian AC line ‘Interconnection 750 kV Rzeszów (PL) – Khmelnitska (UA) (reactivation on 400 kV)’, project completed on the Polish side , Romanian internal AC line ‘400kV OHL Gadalin (RO) – Suceava (RO)’, project ‘in permitting’, Romanian-Moldavian AC line ‘400kV OHL Suceava (RO) – Balti (MD)’, project ‘in permitting’; (39) Additionally, NRAs flagged the following cross-border relevant investment with status ‘under consideration’ which do not appear in the draft EU TYNDP 2022:
The Polish NRA explains that the interconnection 750 kV Rzeszow – Khmelnitska exists, but has not been in operation since 1993. Currently, the interconnection is planned to be reactivated on 400 kV and NDP includes investments relevant to operation of this interconnection at 400 kV, however, its commissioning depends on the situation in Ukraine.
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Hungarian-Romanian AC line ‘Installation of the second circuit of Békéscsaba (HU) – Nadab (RO) 400 kV cross-border line’, Italian-French AC line ‘Voltage upgrade Nava (IT) – S. Dalmas (FR)’. Table 13 in Annex I provides additional information on these investments. (40) The Agency notes that under the current EU TYNDP process, the inclusion of cross border relevant projects in the EU TYNDP solely depends on project promoters’ (‘PP’) voluntary applications, with a risk to bypass the EU-level scrutiny of a project, if the PP does not apply for inclusion in the EU TYNDP. (41) In line with its previous recommendation , the Agency stresses that all the planned projects with cross-border relevance from the NDPs should be included in the EU TYNDP, and that cross-border relevant projects in the NDPs should be flagged explicitly. Investments of TYNDP 2020 which are not present in the draft EU TYNDP 2022 and other cross-border relevant investments not included in the draft EU TYNDP 2022 (42) A list of transmission investments and storage projects that were included in the EU TYNDP 2020, but are neither included in the draft EU TYNDP 2022 (nor is their absence explained by ENTSO-E) is provided in Tables 14 and 15 in Annex I. The Agency identifies a total of 78 such transmission investments and seven storage projects on the territory of EU and/or EEA Member States . (43) Based on the information provided by the NRAs, the Agency identified that about one third of these investments (located in EU Member States and/or Norway) is already commissioned and another third cancelled. Approximately 10% failed to meet the criteria from the Inclusion Guidelines and the remaining share is still under development, postponed indefinitely by the PP or their status is not available to the NRA. (44) The Agency notes that two storage projects that were included in the EU TYNDP 2020 were not included in the draft EU TYNDP 2022 due to their non-compliance to the Inclusion Guidelines. Furthermore, the Irish NRA explained that project 1030 “Mares Organic Power Energy Storage” was not included in the draft EU TYNDP 2022, because it had been cancelled. For the remaining four storage projects located in EU Member States that are not present in the draft EU TYNDP 2022, NRAs were not able to provide information, mostly due to that fact that the project is a non-TSO project and the promoters have no reporting obligation to the NRA.
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Opinion No 04/2023
(45) The Agency is of the view that all commissioned and cancelled investments should enter the subsequent EU TYNDP for monitoring purposes (i.e. without a CBA assessment). For the remaining investment which are no longer included in the draft EU TYNDP 2022 in comparison to the previous edition, a valid explanation for their non-inclusion should be provided in order to ensure appropriate transparency. Projects which were rejected to be included in the draft EU TYNDP 2022 due to non-compliance with the ENTSO-E TYNDP Inclusion Guidelines (46) The Agency notes that four transmission and three storage projects applied for inclusion in the TYNDP 2022, but were rejected due to non-compliance with the Inclusion Guidelines. These projects and the reasons for non-compliance are listed in table 5.
Table 5: Projects that have applied for inclusion in the draft TYNDP 2022, but were not compliant with the Inclusion Guidelines
Project Project name Reason for non-compliance number
PP ceased to exist, so the project does not comply with 284 LEG1 mandatory criteria of company existence. PP did not prove compliance with any of the additional 296 Britib administrative criteria e) to k) from the Inclusion Guidelines.
on
Crete-North Greece-North ssi PP ceased to exist, so the project does not comply with 1077 Macedonia-Bulgaria mi mandatory criteria of company existence. Interconnector rans LAG Interconnector PP ceased to exist, so the project does not comply with T 1081 (LAG) mandatory criteria of company existence. Project is located in Great Britain and therefore does not meet eligibility criteria from section 2.1 of the Inclusion 1015 Cruachan 2 Guidelines, according to which storage projects must be planned to be developed in a country represented within ENTSO-E.
ge
Hydro-pumped electricity Project did not prove compliance with any of the additional 1019 tora storage Gironés & Raïmats administrative criteria e) to j) from the Inclusion Guidelines.
S
Distributed network of Hydrogen storage and Project did not prove compliance with any of the additional 1042 production by electrolysis administrative criteria e) to j) from the Inclusion Guidelines. with re-electrification through a fleet of FCEVs
As of January 2022, the TSOs located in Great-Britain are no longer member of ENTSO-E.
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5. SHORTCOMINGS OR PRACTICAL MISTAKES REGARDING PROJECTS IN THE DRAFT EU TYNDP 2022 Investment numbers (47) Based on the information provided by NRAs, the Agency notes that at least four transmission investments from the EU TYNDP 2020 appear under new investment numbers in the draft EU TYNDP 2022. These investments are clustered differently in the draft EU TYNDP 2022 and they are listed in Table 6.
Table 6: Investment numbers changed in the draft EU TYNDP 2022
Project Investmen number t number Investment name in the in the EU in the EU TYNDP Comment by the NRA EU TYNDP 2020 TYNDP 2020 2020
The Swedish NRA explains that in draft EU TYNDP 2022, Ekhyddan-Nybro- 124 733 this investment corresponds to investments 1783 (‘Nybro- Hemsjo Hemsjo’) and 1784 (‘Ekhyddan-Nybro’).
The Estonian NRA explains investment was moved under project 1094 (‘Estlink 3’) in the draft EU TYNDP 2022. As
new substation 330 kV Sopi is constructed on the line, new 330kV OHL Paide- 170 1004 investments in the draft EU TYNDP 2022 are investments Sindi (L346) 1769 (‘Estonian grid reinforcements: L346 Paide-Sopi 330 kV OHL reconstruction’) and 1770 (‘L347 Sopi-Sindi 330 kV OHL reconstruction’).
The Lithuanian NRA explains the investment code in the New 330 kV OHL 1694 draft EU TYNDP 2022 is 1788 (‘New 330 kV OHL Darbenai-Musa Darbenai-Musa’). 1042 The Lithuanian NRA explains the investment code in the New 330 kV OHL 1695 draft EU TYNDP 2022 is 1789 (‘New 330 kV OHL Panevezys-Musa Panevezys-Musa’).
(48) Furthermore, the Agency identified five instances where the same project number was assigned to two different projects. These projects are listed in Table 7.
Table 7: Projects in the draft EU TYNDP 2022 with the same project numbers
Number Projects with the same number
Purifying-Pumped Hydroelectric Energy Storage (‘P- 1012 330 kV OHL Tartu-Balti (L300) PHES Navaleo’) 1013 Viru-Tsirguliina 330kV OHL CAES Zuidwending, NL 1035 Baczyna Ptolemaida Battery Energy Storage System 1050 Van Eyck - Gramme: HTLS upgrade SE Integrator Purifying-Pumped Hydroelectric Energy Storage ‘Velilla 1041 Rem. lim. in Central Italy del Río Carrión’ (‘P-PHES Velilla’)
(49) The Agency is of the view that applying non-unique project identification numbers (even if one of them is a transmission and the other one is a storage project) or not consistently applying the investment codes across the EU TYNDPs, negatively impacts the EU TYNDP transparency and adds substantial complexities to the EU TYNDP-related
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processes (e.g. monitoring, project consistency assessment, project data comparison for specific purposes). Investment costs for mature investments, the costs should be reported together with a clearly explained uncertainty range, while for non-mature investments, this principle should be applied in case detailed project cost information is available, in the absence of the availability of the detailed project cost information, for investments ‘planned but not yet in permitting’ or ‘under consideration’, a set of standard investment costs with a project-specific complexity factor needs to be used, regarding the reported CAPEX , it should be comprised of two parts: ‘inception CAPEX’, indicator C1a, which is ‘the capital costs incurred at the inception of the project’, and ‘sustaining CAPEX’, indicator C1b, which is the ‘capital expenditure incurred during the assessment period that is necessary to ensure that the functionality of the original assets realised by the inception CAPEX is maintained’. Currently, overall numbers are provided for the CAPEX, but given that the two categories of costs are incurred at different points in time, affecting the overall cost estimate of the project, they should be reported as distinct figures. (51) The Agency notes contrary to the requirements of the Inclusion Guidelines, for nine transmission investments in the draft EU TYNDP 2022, information on the capital expenditures (CAPEX) and/or the operating expenses (OPEX) is missing (e.g. provided as zero). Moreover, the Agency notes that 7 more mature (i.e. of status ‘in permitting’ or ‘under construction’) transmission investments and three storage projects lack information on the cost uncertainty range. The list of these investments and storage projects is provided in Table 16 in Annex I. (52) The Agency notes that the draft EU TYNDP 2022 provides no information indicating for which projects or investments the standard costs were actually used.
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Clustering of investments (53) The Agency welcomes an increased completeness of information regarding the necessity for clustering of projects in comparison to its completeness in the EU TYNDP 2020 . However, six projects with more than one investment in the draft EU TYNDP 2022 remain without an explanation for the necessity of clustering. These projects are listed in Table 17 in Annex I. (54) According to the CBA 3.0 Guideline and Implementation Guidelines for TYNDP 2022 rd based on 3 ENTSO-E guideline for CBA of grid development projects (‘Implementation Guidelines’) , investments clustered within the same project can at most be one project status level apart from each other. (55) The Agency notes that project 170 ‘Baltic States Synchronization with Continental Europe’ in the draft EU TYNDP 2022 contains (not-yet commissioned) investments that are more than one project status level apart from each other, i.e. its least mature investment is ‘under consideration’ and its most mature (not-yet commissioned) investment is ‘under construction’. (56) The Agency recalls that the clustering of investments should be carried out in line with the CBA 3.0 Guideline and the Implementation Guidelines. (57) The Agency notes that for six project in the draft EU TYNDP 2022, project’s status does not correspond to the status of their least mature investment. These projects are listed in Table 18 in Annex I. In the Agency’s view, status of the project should be consistent to the status of its least mature investment. Information on the progress of investments (58) The Agency welcomes that the expected commissioning date for each investment also includes the month, not only the year, which makes these data more informative and increases consistency with several related activities of the Agency. (59) The Agency identified inconsistencies in the information regarding the progress of the investments since 2020. There are 66 new investment numbers in the draft EU TYNDP 2022 and out of them, 17 investments are not labelled as ‘new’, thus either the investment number has changed for a previously included investment (e.g. as it is the case for
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Opinion No 04/2023
investment 1783 and 1784) or the progress data is incorrect and should be ‘new investment’. These investments are listed in Table 19 in Annex I. (60) Furthermore, 30 transmission investments are labelled both in the TYNDP 2020 and in the draft TYNDP 2022 as ‘new investment’. (61) In at least 30 instances, the commissioning year of the investment does not match the progress of the investment when comparing information provided in the TYNDP 2020 and draft TYNDP 2022. 24 investments are labelled as ‘on time’, but appear to be delayed, while six investments appear to be ‘ahead of time’ when comparing the commissioning years from the TYNDP 2020 with the information in the draft TYNDP 2022. These investments are listed in Table 20 in Annex I. Additional shortcomings or practical mistakes regarding projects of the draft EU TYNDP 2022 (62) The Agency’s review of the projects in the draft EU TYNDP 2022 identified some investments for which the draft TYNDP 2022 did not provide the correct list of hosting countries: Projects 123 (‘LitPol Link Stage 2’) and 138 (“Black Sea Corridor”) are reported as internal projects, although they appear to be located on the territory of more than one country. Project 346 (‘ZuidWest380 NL Oost’) is an internal project in the Netherlands, however, Belgium is also reported under this project in the draft EU TYNDP 2022. (63) Finally, for some investments (listed in Table 21 in Annex I) the draft TYNDP 2022 fails to provide sufficiently concrete investment description. The Agency is of the view that for the sake of transparency and robustness of the EU TYNDP, a sufficient description of each investment in the EU TYNDP should be provided. HAS ADOPTED THIS OPINION: 1. The Agency finds that the draft EU TYNDP 2022 assessments and the projects included in it generally contribute to the objectives of non-discrimination and effective competition, referred to in Article 32(2) of Regulation No 2019/943.
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Opinion No 04/2023
2. However, as pointed out in its Opinion 03/2023, the Agency considers that the draft TYNDP 2022 does not sufficiently contribute to the efficient functioning of the market and secure functioning of the internal electricity market due to a number of shortcomings and addresses a number of recommendations to ENTSO-E, as regards the finalisation and adoption of the TYNDP 2022. 3. Further, in line with Article 48(2) of Regulation (EU) 2019/943 the Agency identified a number of inconsistencies between an NDP and the draft EU TYNDP 2022 as provided in the recitals of this Opinion. It is recommended that ENTSO-E further enhances the consistency between the NDPs and the EU TYNDP by implementing the following measures: a. ENTSO-E should further increase its efforts to include all planned projects with cross-zonal relevance from the NDPs in the EU TYNDP. b. ENTSO-E should ensure that each investment included in the EU TYNDP and not included in the NDP of a hosting Member State is clearly flagged in the EU TYNDP and the reason for such absence should also be provided. c. All the commissioned and cancelled investments included in a previous EU TYNDP should enter the subsequent EU TYNDP for monitoring purposes (i.e. without a CBA) and each EU TYNDP should provide a list of investments which are no longer included in the EU TYNDP compared to the previous edition, together with an explanation for their non-inclusion. d. ENTSO-E should ensure that the information on investments’ status and commissioning date are sufficiently credible. Overly optimistic projections of the expected commissioning dates should be avoided. ENTSO-E should define certain reference project timelines (e.g. number of years for permitting and construction periods). For projects whose status is ‘under consideration’ or ‘planned but not yet in permitting’, future EU TYNDPs should provide the project promoter’s estimate together with the estimation of ENTSO-E based on the reference timeline. In case of differences, the project promoters should provide an explanation. e. ENTSO-E should ensure that all investments and projects in the EU TYNDP 2022 respect the criteria for clustering laid down in the CBA 3.0 Guideline and in the Implementation Guidelines. ENTSO-E should revise the clustering and demonstrate the necessity for clustering with regard to the draft EU TYNDP 2022 projects identified in section 5.3 of this Opinion. f. The Agency invites ENTSO-E to improve the costs-related information in the EU TYNDP by: i. including information on CAPEX and OPEX for all transmission investments and storage projects, ii. including the cost uncertainty ranges at least for all projects whose status is ‘in permitting’ or ‘under construction’,
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Opinion No 04/2023
iii. reporting inception CAPEX (i.e. the capital costs incurred at the inception of the project) and sustaining CAPEX (i.e. capital expenditure incurred during the assessment period that is necessary to ensure that the functionality of the original assets realised by the inception CAPEX is maintained) separately, iv. including information on how the costs were determined for each transmission investment or storage project (i.e. by using standard costs or detailed cost information and how the cost data was derived). g. ENTSO-E should consider the differences between the NDPs and the draft EU TYNDP 2022 identified by NRAs and update the draft EU TYNDP 2022 by taking into account the information and comments provided by NRAs in Table 10 in Annex I, as appropriate. ENTSO-E should also review and eliminate the project-specific inconsistencies in the draft EU TYNDP 2022 reported in section 5 of this Opinion. h. ENTSO-E should improve transparency and robustness of the EU TYNDP by ensuring that a sufficient level of technical information is provided for each investment, including those investments in the draft EU TYNDP 2022 which are listed in Table 21 of this Opinion. i. ENTSO-E should apply a unique coding for investments and projects in the EU TYNDP. j. ENTSO-E should, for the purpose of consistency with the previous EU TYNDP, review the information in the draft EU TYNDP 2022 regarding the investment progress since the EU TYNDP 2020 and adjust it where necessary. 4. In order to increase the robustness, credibility and transparency of the NDPs, the Agency recommends that the parties responsible for their development, review and adoption take into account the following measures and pursue their implementation to the extent it is in their powers: a. The NDPs’ scope should be expanded to allow the inclusion of third-party projects, where this is not yet the case. b. Cross-zonal relevant projects in the NDPs should be flagged explicitly. c. The differences between the NDPs and the draft EU TYNDP 2022 identified by NRAs should be considered and the NDPs should be updated by taking into account the information and comments provided by NRAs in Table 10, as appropriate. d. In case of interconnection investments, where the national parts are in different advancement status across the borders, the relevant parties should jointly review the concerned interconnection investments and, in case of inconsistencies, amend the respective planning and implementation plans.
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Opinion No 04/2023 This Opinion is addressed to ENTSO-E, NRAs, TSOs and other project promoters with crosszonal relevant projects. Done at Ljubljana, on 4 April 2023.
- SIGNED -Fоr the Agency The Director C. ZINGLERSEN Annexes: Annex I
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Opinion No 04/2023
ANNEX I
Table 8: Participating countries and the numbers of the reviewed investments and storage projects
Number of relevant national parts of Share of reviewed national parts of Country transmission investments and storage transmission investments and storage projects projects [%]
Austria 16 100 Belgium 19 100 Bulgaria 9 100 Croatia 5 100 Cyprus 3 100 Czech Republic 5 100 Denmark 12 100 Estonia 21 100 Finland 11 100 France 20 100 Germany 43 100 Greece 17 100 Hungary 2 100 Ireland 8 100 Italy 27 100 Latvia 12 100 Lithuania 17 100 Luxembourg 4 100 Malta 1 100 the Netherlands 17 100 Norway 1 100 Poland 11 100 Portugal 8 100 Romania 17 100 Slovakia 4 100 Slovenia 4 100 Spain 21 100 Sweden 13 100
Total 348 100
Table 9: Investment numbers of national parts of investments which were not able to be assessed on any aspect
Investment numbers of national parts of investments which were not able to be assessed by the NRA
403 (SE), 462 (IE), 604 (BE), 616 (SI), 635 (IT), 645 (IT), 650 (BE, DE, LU), 810 (IE), 1014 (IT), 1107 (BE), 1241 (FI), 1255 (NL), 1262 (SE), 1269 (HR), 1378 (IT), 1380 (AT, IT), 1382 (NO), 1384 (IT), 1385 (IE), 1430 (IT), 1431 (GR), 1432 (GR), 1433 (GR), 1434 (GR), 1458 (IT), 1478 (IT), 1482 (IT), 1483 (AT), 1483 (SI), 1493 (DE), 1504 (DE, NL), Investment 1506 (NL), 1507 (NL), 1508 (DE), 1509 (DE), 1511 (DE), 1521 (IT), 1555 (IT), 1557 (IT), numbers 1559 (GR), 1628 (NL), 1638 (IE), 1642 (IE), 1653 (IE), 1675 (SE), 1682 (GR), 1691 (NL), 1704 (GR), 1706 (BE), 1707 (DE), 1708 (DK), 1709 (GR), 1726 (DE), 1727 (IT), 1740 (LV, SE), 1741 (SE), 1750 (IE), 1751 (IT), 1755 (LV), 1756 (LV), 1757 (LV), 1758 (LV), 1759 (DK), 1760 (FI), 1761 (LV), 1762 (FI, SE), 1764 (SE), 1766 (DE), 1785 (FI), 1791 (BE), 1794 (DE), 1795 (IT), 1796 (IT), 1797 (IT), 1798 (IT), 1799 (GR, IT), 1804 (AT), 1805 (AT), 1806 (AT), 1815 (NL), 1816 (DE), 1817 (NL), 1818 (DE), 1819 (DE, NL)
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Table 10: List of identified inconsistencies between the data in the draft EU TYND 2022 and the respective
NDPs or the information available to the NRA
Country Inv. Investment name Information provided by the NRA of NRA number
AC-part of Belgian
Belgium 1625 Modular Offshore Grid II Capacity 2.1 GW
(MOG II)
New 66km double circuit
400kV OHL between
existing Foggia and The Villanova - Gissi part is commissioned, ures Villanova 400kV at 86 therefore the investment item should be Gissisubstations, also Larino-Foggia. connected in and out to
the Larino and Gissi Italy chnical fe substations
Te A reference (but not an investment item) to PST
and other upgrades in included in the draft EU 616 Salgareda - Bericevo TYNDP 2022 project sheets, however, such item was not placed ‘under consultation’ by the NRA.
New 400 kV submarine The investment has a different location, i.e. Bolano 1798 cable Bolano-Paradiso – Annunziata.
Investment is separated in three different projects Belgium 1519 Avelgem-Courcelles in the NDP (2 substations and 1 line).
New 66km double circuit
400kV OHL between
existing Foggia and
Villanova 400kV The investment should not be clustered together 86 substations, also with Deliceto-Bisaccia which is commissioned.
connected in and out to
the Larino and Gissi
substations Project 150 ‘Italy-Slovenia’ should be composed of
two items, short-term upgrades and a potential
future HVDC link. The transfer capacity for the
616 Salgareda-Bericevo short-term investment item is indicated in the
project sheet at around 400 MW. This NTC g increase should be more transparently presented in
n
Italy eri the final TYNDP 2022.
OHL between the Laino In the NDP, the investment is not clustered Clust 645 and Altomonte in together with investment 1727. Calabria
Tyrrhenian HVDC link - The investment should not be clustered together 1557 West with investment 1795.
Tyrrhenian HVDC link - The investment should not be clustered together 1795 East with investment 1557.
New 400 kV overhead The investment should not be clustered together 1796 line between Aliano and with investment 1797. Montecorvino
New 400 kV overhead The investment should not be clustered together 1797 line in the northern area with investment 1796. of Benevento
Investment is separated in two different projects in
the NDP: Poland 1232 Baczyna-Plewiska “Construction of 400 kV Baczyna-Plewiska line”
(CAPEX app. million EUR) and “Expansion of
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Opinion No 04/2023
Country Inv. Investment name Information provided by the NRA of NRA number
400/220/110 kV Plewiska substation” (CAPEX app. 20 million EUR), however the later includes also other, additional works not related to the construction of Baczyna–Plewiska. Investments 1661 and 1662 are separated in three different projects in the NDP: “Construction of 400 kV Dunowo-Żydowo Kierzkowo-Piła Krzewina line” (CAPEX app. 200 Construction of new million EUR), “Expansion of 400 kV and 110 kV 1661 400kV line Dunowo-
switchgear at 400/220/110 kV Dunowo substation
Zydowo Kierzkowo
together with installation of 400/110 kV
transformers” (CAPEX ca. 35 million EUR) and “Expansion and upgrade of the Piła Krzewina substation” (CAPEX app. 28 million EUR) Investments 1661 and 1662 are separated in three different projects in the NDP: “Construction of 400 kV Dunowo-Żydowo Construction of new Kierzkowo-Piła Krzewina line” (CAPEX app. 200 400kV line Pila million EUR), “Expansion of 400 kV and 110 kV 1662 Krzewina-Zydowo switchgear at 400/220/110 kV Dunowo substation Kierzkowo together with installation of 400/110 kV transformers” (CAPEX ca. 35 million EUR) and “Expansion and upgrade of the Piła Krzewina substation” (CAPEX app. 28 million EUR) Investments 1663 and 1664 are separated in three different projects in the NDP: “Upgrade of 400 kV Krajnik-Morzyczyn,
Morzyczyn-Dunowo and Krajnik-Baczyna lines on the section using the existing 400 kV Krajnik-
Modernization of 400kV Plewiska line” (this investment includes also 1663 OHL Krajnikmodernization of other line which is out of the Morzyczyn scope of TYNDP 2022 investments), “Upgrade of
400 kV Słupsk-Żarnowiec line together with construction of a section of the 400 kV line from
Choczewo to Słupsk-Żarnowiec line tap” and “Upgrade of 400 kV Dunowo-Słupsk line”. Investments 1663 and 1664 are separated in three different projects in the NDP: “Upgrade of 400 kV Krajnik-Morzyczyn,
Morzyczyn-Dunowo and Krajnik-Baczyna lines on
Modernization of 400kV the section using the existing 400 kV Krajnik- OHL Morzyczyn- Plewiska line” (this investment includes also 1664 Dunowo-Slupsk- modernization of other line which is out of the Zarnowiec scope of TYNDP 2022 investments), “Upgrade of
400 kV Słupsk-Żarnowiec line together with construction of a section of the 400 kV line from
Choczewo to Słupsk-Żarnowiec line tap” and “Upgrade of 400 kV Dunowo-Słupsk line”. g g Expected commissioning year for the 2 substations mi mi is 2027 while the expected year for the project
te
m 1519 Avelgem-Courcelles m Belgium te da lines is 2029-2030. The draft EU TYNDP reports
Co ssionin da Co ssionin
December 2028.
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Country Inv. Investment name Information provided by the NRA of NRA number
Connection between The investment is expected to be commissioned 1759 Belgium and the Danish between 2031 and 2032, while the draft EU Energy Island TYNDP reports December 2030. The TSO envisioned the investment to be Germany 1772 Roost - Flebour - Bauler commissioned in 2030, while the draft EU TYNDP reports December 2027. In the NDP (2023-2032), the commissioning date 256 256 is June 2023 while the draft EU TYNDP reports June 2022. Greece New AC 400 kV In the NDP (2023-2032), the commissioning date 1738 interconnection line is December 2029, while the draft EU TYNDP Greece - Turkey reports June 2035. New 66km double circuit 400kV OHL between existing Foggia and Villanova 400kV The commissioning date is 2028, while the draft 86 substations, also EU TYNDP reports December 2027. connected in and out to the Larino and Gissi substations This investment is expected by 2025, while the 90 90 draft EU TYNDP 2022 reports December 2023. The investment is ‘under consideration’ (as provided in the draft EU TYNDP 2022) and for this reason, it does currently not have the 616 Salgareda - Bericevo commissioning date defined. The draft EU TYNDP 2022 reports the commissioning date December 2040. The investment is expected to be commissioned in 635 Elmed Project 2028, while the draft EU TYNDP 2022 reports December 2027. OHL between the Laino The investment is expected to be commissioned in Italy 645 and Altomonte in 2029, while the draft EU TYNDP 2022 reports Calabria December 2027. This investment is expected to be commissioned Rem. lim. in Central 1041 by 2023, while the draft EU TYNDP 2022 reports Italy December 2026. This investment is ‘under consideration’ according to the NRA’s opinion 335/2022 on the draft NDP Second HVDC Module 1053 2021 and for this reason, it does currently not have IT-ME a commissioning date. The draft EU TYNDP 2022 reports December 2026. This investment is expected to be commissioned in 1458 SACOI3 2027, while the draft EU TYNDP 2022 reports December 2026. Lienz (AT) - Veneto The expected commissioning date is 2035, while 1555 region (IT) the draft EU TYNDP reports December 2030. New 400 kV overhead The expected commissioning date is 2032, while 1796 line between Aliano and the draft EU TYNDP reports December 2030. Montecorvino New 400 kV overhead The expected commissioning date is 2035, while 1797 line in the northern area the draft EU TYNDP reports December 2030. of Benevento
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Opinion No 04/2023
Country Inv. Investment name Information provided by the NRA of NRA number
The expected commissioning date is 2031, while 1799 GRITA 2 the draft EU TYNDP reports December 2030.
In the NDP 2021, the commissioning date is 2027, Luxembo AC Overhead Line 1630 while the draft EU TYNDP 2022 reports urg Aach-Bofferdange December 2026.
In the NDP, the expected commissioning date is
1035 Baczyna 2025, while the draft EU TYNDP 2022 reports
December 2024.
Modernization of 400kV In the NDP, the expected commissioning date is 1663 OHL Krajnik- 2026 and the draft EU TYNDP reports July 2023. Morzyczyn
Poland Modernization of 400kV In the NDP, the expected commissioning date is OHL Morzyczyn- 1664 2026 and the draft EU TYNDP reports December Dunowo-Slupsk- 2023. Zarnowiec
Modernization of 400kV In the NDP, the expected commissioning date is OHL Zarnowiec- 1665 2025 and the draft EU TYNDP 2022 reports Gdansk/Gdansk December 2023. Przyjazn-Gdansk Blonia
The investment was commissioned in Q3 od 2022,
Austria 886 886 – east of Austria but the reported status in the draft EU TYNDP
2022 is ‘under construction’.
This investment is commissioned. Status in the BRABO II: Zandvliet - 445 draft EU TYNDP 2022 is “under construction” and Lillo - Liefkenshoek commissioning date 2021. Belgium This investment is commissioned. Status in the
605 BRABO II: Lillo 380 draft EU TYNDP 2022 is ‘under construction’ and
commissioning date 2020.
The investment is ‘under construction’ and the Finland 1710 Viitajärvi-Pyhänselkä draft EU TYNDP 2022 reports ‘in permitting’.
The investment is still ‘under consideration’ and
the draft EU TYNDP 2022 reports ‘planned, but Mares Cable: Irish Sea 1638 not yet in permitting’. The investment is not at an Interconnector Cable enough advanced stage and has not yet been
approved.
The investment is still ‘under consideration’ and
atus the draft EU TYNDP 2022 reports ‘planned, but MaresConnect Converter St Ireland 1642 not yet in permitting’. The investment is not at an Station Ireland enough advanced stage and has not yet been
approved.
Enabling Works 2: The investment is still ‘under consideration’ and
EIRGRID 1 x 245kV the draft EU TYNDP 2022 reports ‘planned, but
1653 Connection bay at not yet in permitting’. The investment is not at an
Maynooth and associated enough advanced stage and has not yet been
works approved.
This investment was deemed ‘under consideration’
in the NRA’s opinion 355/2022 on the draft NDP
Second HVDC Module 2021. It is not expected before 2030, unless a Italy 1503 IT-ME future decision will be taken to proceed with the
project. Investment’s status in the draft EU
TYNDP 2022 is ‘under construction’.
This investment is commissioned. Status in the Reconstructions in North Lithuania 1566 draft EU TYNDP 2022 is ‘under construction’ and Eastern Lithuania commissioning date 2021.
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Country Inv. Investment name Information provided by the NRA of NRA number
This investment is commissioned. Status in the Upgrades in Alytus 1568 draft EU TYNDP 2022 is ‘under construction’ and substation (LT) commissioning date 2021.
The investment is already ‘planned but not yet in
1778 Offshore Wind LT 2 permitting’ and the draft EU TYNDP 2022 reports ‘under consideration’.
The investment is already ‘planned but not yet in New 330 kV OHL 1788 permitting’ and the draft EU TYNDP 2022 reports Darbenai-Musa ‘under consideration’.
The investment is already ‘planned but not yet in New 330 kV OHL 1789 permitting’ and the draft EU TYNDP 2022 reports Panevezys-Musa ‘under consideration’.
New 66km double circuit
400kV OHL between
existing Foggia and
Villanova 400kV The investment is delayed and not ‘on time’ as 86 substations, also reported in the draft EU TYNDP 2022.
connected in and out to
the Larino and Gissi on) substations
The investment is delayed due to post-permitting
reas
90 90 implementation measures, while the draft EU
he
t TYNDP 2022 reports the investment is ‘on time’. Italy nd OHL between the Laino The investment is delayed due to permitting
645 and Altomonte in reasons. The draft EU TYNDP 2022 reports the
Calabria investment to be rescheduled.
gress (a
Rem. lim. in Central Progress is ‘ahead of schedule’ and not ‘on time’ 1041 Pro Italy as reported in the draft EU TYNDP 2022.
The project is delayed due to permitting reasons in
1458 SACOI3 the Corse island, while the draft EU TYNDP 2022 reports the investment is ‘on time’.
This investment is rescheduled due to an unclear Second HVDC Module 1503 need of the project. The draft EU TYNDP 2022 IT-ME reports the investment is ‘on time’.
CAPEX for this investment seems unrealistic and
highly inflated. Possible grid enforcement in this Austria 1583 Vorarlberg area is mentioned as System-need-study in the
Austrian NDP only.
In the NDP, the reported costs are 31 million EUR. New Substation 400/110 Croatia 1535 The draft EU TYNDP 2022 reports CAPEX 11.9 sts kV Lika million EUR.
Co
According to the decision by the NRA of 3
November 2022, 1623 million EUR are the costs
France Ireland including 141 million EUR for contingencies. The France 810 Interconnector significant increase is mainly by tensions in the
supply market. The draft EU TYNDP 2022
provides CAPEX 1000 million EUR +- 10%.
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Country Inv. Investment name Information provided by the NRA of NRA number
New 66km double circuit
400kV OHL between
existing Foggia and CAPEX for the missing part is above 200 million Villanova 400kV 86 EUR and not 415 million EUR, as reported in the substations, also draft EU TYNDP 2022. connected in and out to
the Larino and Gissi
substations
New 30km single circuit The actual CAPEX of this investment is around 400kV OHL between the 37 million EUR. The CAPEX of 201 million EUR 96 future substations of reported in the draft EU TYNDP 2022 refers to a Deliceto and Bisaccia, in bundle of interdependent projects. the Candela area
Italy The CAPEX provided in the draft EU TYNDP Rem. lim. in Central 1041 2022 appears to include some interdependent Italy works on the 132 kV grid.
The CAPEX is around 1100 million EUR, while
1458 SACOI3 the draft EU TYNDP 2022 reports 930 million
EUR.
New HVDC line The CAPEX is around 1300 million EUR, while between Villanova and 1521 the draft EU TYNDP 2022 reports Fano existing 400 kV 105 million EUR. substations
The CAPEX is around 175 million EUR, while the
New 400 kV submarine draft EU TYNDP 2022 reports 1124 million EUR. 1798 cable Bolano-Paradiso The expected OPEX is around 3.5 million
EUR/year.
In the NDP, the reported costs are 50.48 million New 330 kV OHL 382 EUR. The draft EU TYNDP 2022 reports CAPEX Vilnius-Neris 24.76 million EUR.
New HVDC In the NDP, the reported costs are 499.87 million
1034 interconnector "Harmony EUR. The draft EU TYNDP 2022 reports CAPEX
Link" 682.6 million EUR.
In the NDP, the reported costs are 11.56 million Reconstruction of 330 1565 EUR. The draft EU TYNDP 2022 reports CAPEX kV OHL LE-Vilnius 18.281 million EUR.
In the NDP, the reported costs are 9.76 million Upgrades in Alytus 1568 EUR. The draft EU TYNDP 2022 reports CAPEX substation (LT) 22.438 million EUR.
In the NDP, the reported costs are 15.6 million New 330 kV Musa Lithuania 1632 EUR. The draft EU TYNDP 2022 reports CAPEX substation 6.14 million EUR.
In the NDP, the reported costs are 43.04 million New 330 kV OHL 1634 EUR. The draft EU TYNDP 2022 reports CAPEX Bitenai - KHAE 42.06 million EUR.
In the NDP, the reported costs are 60 million EUR. New 330 kV OHL 1659 The draft EU TYNDP 2022 reports CAPEX 62.77 Darbenai-Bitenai million EUR.
In the NDP, the reported costs are 110 million New 330 kV OHL 1788 EUR. The draft EU TYNDP 2022 reports CAPEX Darbenai-Musa 66 million EUR.
In the NDP, the reported costs are 50 million EUR. New 330 kV OHL 1789 The draft EU TYNDP 2022 reports CAPEX 21.6 Panevezys-Musa million EUR.
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Country Inv. Investment name Information provided by the NRA of NRA number
In the NDP, the reported costs are 33 million EUR. Luxembo 1629 Substation Bofferdange The draft EU TYNDP 2022 reports CAPEX 44 urg million EUR. In the NDP, the reported costs are 55 million EUR. Poland 373 Ostroleka-Stanislawow The draft EU TYNDP 2022 reports CAPEX 67.74 million EUR. Transfer capacity increase of investments 997, 1472 and 1473 is dependent from each other and not cumulative. This is important for market 997 997 Pleinting - St. Peter simulation. The preparation of the TYNDP data does not provide the possibility to check the correct usage in the simulation.
ty
ci Transfer capacity increase of investments 997, 1472 and 1473 is dependent from each other and
apa
St. Peter (AT) - Tauern not cumulative. This is important for market Austria 1472 er c (AT) simulation. The preparation of the TYNDP data
sf
does not provide the possibility to check the
an
correct usage in the simulation.
Tr
Transfer capacity increase of investments 997, 1472 and 1473 is dependent from each other and Isar/Altheim/Ottenhofen not cumulative. This is important for market 1473 - St. Peter simulation. The preparation of the TYNDP data does not provide the possibility to check the correct usage in the simulation. The Italian NRA disagrees with the benefit’s
All Italy-related clusters in the draft calculation for all Italy-related clusters in the draft nefits Italy EU TYNDP 2022 EU TYNDP 2022 due to unrealistic scenario
Be
assumptions. 1431 Lavrio - Levitha The Greek NRA objects to the inclusion of project 1432 Levitha - Crete 293 (‘Southern Aegean Interconnector (SAI)’) in
1433 Levitha - Syrna the EU TYNDP 2022. In its decision 287/2022, the 1434 Kinaros - Levitha NRA approved the NDP and the interconnection of mainland Greece to Dodecanese which has a er similar route as SAI. This decision was based on Greece extensive studies carried out by a dedicated
Oth
committee established by law in order to 1704 Levitha - Kos recommend the most efficient and economic way for the interconnection of Greek islands in the Aegean Sea. Consequently, the NRA considers project SAI as redundant.
The Polish NRA explains one of the factors affecting the difference is the different PLN-EUR exchange rate used at different points in time.
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Country Inv. Investment name Information provided by the NRA of NRA number
The Greek NRA objects to the inclusion of project 1048 (‘Africa Power Interconnector (GAP)’) in the EU TYNDP 2022, because this project is complementary to SAI project for which the NRA also raised objections. Furthermore, there are Greece Africa Power serious doubts that the weak electrical system of 1709 Interconnector Crete (Greek island) is able to accommodate a second converter station (Euroasia project is the first). Moreover, the NRA fully supports project 1041 (‘GREGY Green Energy Interconnector’) as the only interconnection project between Greece and Egypt recommended by the NRA.
Table 11: List of transmission investment in the draft EU TYNDP 2022 that are not present in the respective NDPs
Reason for the Project Investment Country Investment name absence number number
New 400 kV overhead line Sombor (RS) - Croatia 243 1269 Ernestinovo (HR) Czech 330 1498 New CZ-SK 400 kV interconnector Republic 239 1241 Fenno-Skan 1 renewal 29 1760 Estlink 3 Finland 1094 1785 Inkoo-Hikiä The 1095 1762 4th AC Finland-Sweden north commissioning 325 1483 Upgrade Obersielach (AT) - Podlog (SI) date of the Slovenia 150 616 Salgareda – Bericevo investment is 1504 Danish Hub beyond the time Interconnection NL Maasvlakte to Dutch span of the NDP. 1506 hub (#1) Interconnection NL Maasvlakte to Dutch the 335 1507 30 hub (#2) Netherlands 1815 Dutch Hub 1817 Interconnection Danish hub to Dutch hub 1819 Interconnection Dutch hub to German hub 1047 1691 Emden-Eemshaven The investment Belgium 1049 1706 Converter Stations & Subsea Cabling appertains to a Denmark 1051 1708 Converter stations and Subsea cables non-TSO project Norway 190 1382 NorthConnect or a storage France 299 1458 SACOI3 project and non- Slovenia 323 1478 Dekani (SI) - Zaule (IT) interconnection
The Finnish NRA explains the TSO will do an updated NDP in 2023 and the NRA will monitor that these projects will be introduced in the NDP accordingly. The Dutch NRA assumes it will be part of the NDP 2024 The Belgian NRA explains The TSO received a request for a scoping study from the project promoters. This study is still ongoing.
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Opinion No 04/2023
Reason for the Project Investment Country Investment name absence number number
TSO or storage Redipuglia (IT) - Vrtojba (SI) 324 1482 projects are Interconnection normally not 32 1740 LaSGo Link - Gotland to Latvia Sweden 1068 included or 1741 LaSGo Link - Sweden to Gotland present NDP. the 309 1628 NeuConnect Interconnector Netherlands BRABO II: Zandvliet - Lillo – 445 Belgium 297 Liefkenshoek 605 BRABO II: Lillo 380 256 256 257 257 142 The investment Bulgaria 258 258 has been 262 262 commissioned. 138 800 400 kV OHL Varna-Burgas Reconstruction of 330 kV OHL LE- 1565 Vilnius Lithuania 170 Reconstructions in North Eastern 1566 Lithuania 1568 Upgrades in Alytus substation (LT) 1082 1750 Sea-Socket Mares Cable : Irish Sea Interconnector 1638 Cable Ireland 1642 MaresConnect Converter Station Ireland 349 Enabling Works 2: EIRGRID 1 x 245kV 1653 Connection bay at Maynooth and associated works The investment is 1068 1740 LaSGo Link - Gotland to Latvia not advanced The interconnector between Latvia and enough to be 1755 Estonia with Off-shore wind connection included in the hub in between NDP (e.g. study Cross-border network reinforcement 1756 has not turned 34 Grobina (LV) - Derbenai (LT) Latvia into a project yet). 1088 Cross-border network reinforcement 1757 Broceni (LV) - Telsiai (LT) Internal network reinforcement Ventspils 1758 (LV) - Broceni (LV) Off-shore substation for off-shore wind 1761 park connection 1095 1762 4th AC Finland-Sweden north Sweden 267 1262 Hansa PowerBridge II The investment is Bisamberg (AT) - Wien SO (AT) - 1119 1804 not included, Parndorf (AT) because the latest 1121 1805 Hessenberg (AT) - Weißenbach (AT)
The Swedish NRA explains the TSO has previously denied connection, pending project promoter's next step. The Bulgarian NRA explains the investment has fully been constructed on the Bulgarian side. The Latvian NRA explains preliminary studies going on and the amount and location of the investments will be determined by studies.
PUBLIC
Opinion No 04/2023
Reason for the Project Investment Country Investment name absence number number
NDP was 35 Wien SO (AT) – Ternitz (AT) – Austria 1120 1806 elaborated earlier Hessenberg (AT) than the draft 1122 1810 HVDC converter stations and cables TYNDP. Offshore Wind Connection Centre 1123 1811 Manche 2 Offshore Wind Connection South 1124 1812 Britanny France 1127 1813 Offshore wind connection South Atlantic 1206 HVDC Pamplona area - Cantegrit 276 1207 Upgrade Cantegrit-Saucats 1208 Upgrade Cantegrit-Marsillon 1125 1808 AO6 Occitanie 1126 1809 AO6 Occitanie 40 650 BE-LUX-DE Long-Term perspective 94 1493 PST Vierraden 1050 1707 Converter stations and Subsea Cabling Germany 1058 1726 HVDC Line DE-CH Modernization of existing interconnector 1100 1766 Hradec – Röhrsdorf 1106 1794 Bornholm Energy Island: BEI-DE the 38 260 1255 Interconnector GB-NL Netherlands
Table 12: List of storage projects in the draft EU TYNDP 2022 that are not present in the respective NDPs
Project Reason for absence in Country numbe Project name Comment by the NRA the NDP r
Hydro pumped storage 1026 Riedl The investment Online Grid Controller 1046 appertains to a non- “PSKW-Rio” TSO project or a Germany 1048 WSK PULS (PHES) storage project and 1055 CAES Leer, Germany non-TSO or storage 1056 CAES Etzel, Germany projects are normally CAES Harsefeld-Stade, 1057 not included or present Germany NDP. 1013 CAES Zuidwending, NL the CAES Zuidwending Netherlands 1038 Extension
The Austrian NRA explains the projects are already discussed between NRA and TSO and part of the next years NDP process. The French NRA explains France's NDP was last updated in 2019 and a new one is to be transmitted to the TSO to the NRA soon. The German NRA explains the absent investments are expected to be assessed in the coming NDP (draft by TSOs expected for next spring, final document by BNetzA in early 2024) The Dutch NRA explains the investment will be part of the NDP 2024.
PUBLIC
Opinion No 04/2023
The current NDP 2021- Purifying -Pumped 2026 includes the 1012 Hydroelectric Energy necessary electrical Storage (P-PHES Navaleo) infrastructure (Substation Montearenas 400 kV). The permission for access has been denied and the current NDP does not 1027 P-PHES CUA include the necessary electrical infrastructure for its connection. The current NDP 2021- Reversible Hydraulic 2026 includes the 1039 Power Plant "Los necessary electrical Guajares" infrastructure (Substation Spain Saleres 220 kV). Purifying-Pumped The current NDP 2021- Hydroelectric Energy 2026 includes the 1041 Storage "Velilla del Río necessary electrical Carrión" (P-PHES infrastructure (Substation VELILLA) Velilla 400 kV). The current NDP (2021- Purifying -Pumped 2026) does not include the Hydroelectric Energy 1052 necessary electrical Storage (P-PHES infrastructure (Substation BUSEIRO) Narcea 400 kV). The current NDP 2021- 2026 includes the Reversible hydroelectric 1054 necessary electrical power pump Aguayo II " infrastructure (Substation Aguayo 400 kV). The investment is not ELSEA - European Large included, because the 1037 Scale Energy latest NDP was Slovakia Accumulation elaborated earlier than 1050 SE Integrator the draft EU TYNDP. The investment is not Silvermines Hydroelectric advanced enough to be Ireland 1025 Power Station included in the NDP.
PUBLIC
Opinion No 04/2023
Table 13: List of cross-border relevant transmission investments that are not included in the draft EU TYNDP 2022
Reason for non-inclusion in the TYNDP (if known NDP Investment Expected Status CAPEX to the NRA) and action code name com. date recommended by the NRA
Investment was included in NDP after submission period for the TYNDP Installation of 2022. the second 4.75 ry circuit of After the approval of the ga MAVIR- under million Békéscsaba (HU) 2026 NDP, MAVIR should TV2-006 consideration EUR on – Nadab (RO) contact Transelectrica Hun HU side 400 kV about the project. If both crossborder line TSOs agree, investment will be submitted for inclusion in the TYNDP 2024. Voltage upgrade on an AC line I-NDP under between Nava undefined 160 consideration (IT) and S. ly Dalmas (FR) Ita AC line between The Italian NRA Regoledo (IT) planned, but about 15 I-NDP recommends to include the and a (non- not yet in years 176 investment in the TYNDP defined) node in permitting from now 2022. Switzerland Interconnection depending 750 kV Rzeszów completed on the 2.7 million (PL) - on the Polish situation EUR Poland Khmelnitska side in (UA) Ukraine included in NDP after 400kV OHL 104.7 submission period for F.9 Gadalin (RO) – In permitting million 2030 TYNDP 2022 ia Suceava (RO) EUR an include in the EU TYNDP m included in NDP after Ro 400kV OHL 109.85 submission period for F.10 Suceava(RO)- In permitting million 2030 TYNDP 2022 Balti(MD) EUR include in the EU TYNDP
PUBLIC
Opinion No 04/2023
Table 14: List of transmission investments which were present in the EU TYNDP 2020, but are not included in the draft EU TYNDP 2022
Relevant information Invest. Reporti available to the Project number in ng Investment name NRA regarding number TYNDP country the non- 2020 code inclusion
463 Srananagh - South Donegal IE 82 896 Omagh South to South Donegal IE 229 1674 Zielona Góra - Eisenhuettenstadt PL 233 1235 Conceptual project ES 234 1236 DKE-PL-1 PL Upgrading of existing 220 kV line between SS 1276 HR Dakovo (HR) and TPP Tuzla (BA) to 400 kV line Upgrading of existing 220 kV line between SS 1277 HR 241 Dakovo (HR) and Gradacac (BA) to 400 kV line 1278 Upgrading existing 220 kV SS Dakovo to 400 kV HR New double 400 kV line between SS Dakovo and 1279 HR location Razbojiste 1435 Southern Aegean Interconnector GR 293 1436 Southern Aegean Interconnector GR Cancelled Enabling Works 1: Bellacorick-Oldstreet 2 x 245kV project 1639 IE OHL 1640 Mares Cable 2: Cross Ireland Interconnector Cable IE 1641 Mares Converter Station 3 IE 1647 MAREX Wind infeed cable 1 IE 1648 MAREX Wind Infeed cable 2 IE 1649 MAREX Wind Infeed cable 3 IE 349 1650 MAREX Wind Infeed Cable 4 IE Enabling Works 2: Glinsk Bellacorick Replacement 1651 IE 10 x 245kV bay substation Enabling Works 5: EIRGRID 2 x 245kV 1654 IE Connection bays at Oldstreet and associated works Enabling Works 6: 2 x 245/400 transformer at 1655 IE EIRGRID 220/400kV Substation Oldstreet 1056 1718 SS 400 kV ZONE 5 HR 1057 1722 HVDC Line C3 DE 23 60 FR-BE I: Avelin/Mastaing-Avelgem-Horta HTLS BG, FR 36 141 Kriegers Flak CGS DE, DK 37 142 Norway - Germany HVDC DE, NO 39 144 Audorf – Kassoe DE, DK 696 Hunew 1 HU 697 Hunew 2 HU 48 1500 1. SK-HU interconnection HU, SK Commissioned 1501 2. SK-HU interconnection SK project 386 3rd EE-LV interconnection EE, LV 62 1062 Riga CHP2 - Riga HPP LV 92 146 ALEGrO BE, DE 110 424 Norway - Great Britain NO 172 1487 ElecLink FR 173 1281 Aubange-Moulaine: PSTs BE 197 742 Pyhanselka-Petajavesi FI 200 309 Vitkov-Prestice CZ
PUBLIC
Opinion No 04/2023
Relevant information Invest. Reporti available to the Project number in ng Investment name NRA regarding number TYNDP country the non- 2020 code inclusion
1712 R Vitkov CZ 939 Conneforde – Emden DE 207 1684 Conneforde-Wilhelmshaven DE 245 1246 Upgrade Meeden – Diele DE, NL 262 1257 Belgium-Netherlands: Zandvliet-Rilland BE, NL Double 400 kV OHL Cirkovce(SI)- HR, HU, 320 1558 Heviz(HU)/Zerjavinec(HR) SI 336 1556 Prati (IT) – Steinach (AT) AT, IT 344 1541 Zwolle-Hengelo-Doetinchem-Dodewaard NL 1043 1685 Dollern – Stade DE 284 1619 LEG1 GR 296 1437 Britib ES, FR Non-compliance 1746 Crete-Northern Greece GR to 1077 1747 Northern Greece-North Macedonia GR Implementation 1748 North Macedonia-Bulgaria BG Guidelines 1745 Libya Greece GR 1081 1749 Greece Albania GR Postponement 43 179 1016 DKE-DE (Kontek 2) DE, DK by the PP 62 735 Harku-Sindi 330kV OHL EE Reason 82 897 Omagh South to Turleenan IE unknown/ not 167 998 Viking Link DKW-GB, TYNDP ID 167.998 DK available to the 200 1711 R Kocin CZ NRA or the 151 Ganderkesee - Wehrendorf DE 208 provided 156 Niederrhein-Dörpen DE information was 1270 Baczyna-Zielona Góra PL not-sufficiently 1271 Zielona Góra – Plewiska PL 229 clear 1272 Zielona Góra PL 1673 Zielona Góra - Polkowice PL
The German NRA reports the project is completed, while the Dutch NRA reports that according to the latest NDP, the NL part of the project is rescheduled to 2023. The Dutch NRA explains the investment has partially already been commissioned and the remaining part is under construction The Austrian NRA explains the investment has been completed, but is not yet in operation. The Italian NRA further explains there are some pending upgrades planned to be completed in 2023 and that delays occurred due to construction-related complexities. The Dutch NRA explains investment has partially been commissioned and for the remaining part (i.e. Zwolle- Hengelo), a new needs assessment will be carried out. The German NRA explains the project was not included in the last three NDPs. The Czech NRA explains majority of investments of Project of Common Interest ‘National line Přeštice - Kočín’ has already been commissioned and this investment is scheduled to be completed in 2023. The Polish NRA explains the investment is present in the NDP and its implementation is crucial for the evacuation of power from offshore wind energy and for the improvement of the reliability of power supply to consumers in the Lubuskie Voivodeship.
PUBLIC
Opinion No 04/2023
Relevant information Invest. Reporti available to the Project number in ng Investment name NRA regarding number TYNDP country the non- 2020 code inclusion
252 1456 Massenhoven - Van Eyck: HTLS upgrade BE 253 1224 Uprate of Creys-St Vulbas FR 258 667 Heide/West – Klixbüll DE 348 1546 NoordWest380 NL 1043 1686 Wahle – Mecklar DE 1719 SS 400/220 kV ZONE 6 HR 1723 OHL 2x400 kV ZONE 5 - ZONE 6 HR 1056 1724 OHL 2x220 kV ZONE 6 – Plat HR 1725 SS 220/110 kV Plat HR 1061 1729 Reactive compensation FI 1062 1730 Reactive compensation FI 1063 1731 ZuidWest380 West NL 78 458 HINP-SEAB New Double Circuit Upgrading of existing 220 kV line between SS 241 1530 Gradacac (BA) and TPP Tuzla (BA) to 400 kV line Upgrading existing 220 kV SS Gradacac (BA) to 241 1531 400 kV 264 1259 Beznau – Mettlen 264 1287 Bassecourt - Mühleberg Reason 264 1288 Mettlen – Ulrichen unknown (non- 265 1290 Magadino – Ulrichen EU country) 265 1721 Magadino 264 1284 Pradella-La Punt 266 1286 Chippis – Lavorgo 266 1733 Bickigen – Chippis 266 1734 Chamoson – Chippis 1041 1687 AC Overhead Line 1 (Ras Ghareb-Nile West) AC Overhead Line 2 (Nile West-Wadi El Natroon 1041 1690 EHV)
Table 15: List of storage projects which were present in the EU TYNDP 2020, but are not included in the draft EU TYNDP 2022
Reason for Project Country Project non-inclusion number
cancellation Ireland 1030 MARES Organic Power Energy Storage Belgium 1002 iLand info not Lithuania 1009 Kruonis pumped storage power plant extension project available to the Reversible pumped-storage hydroelectric exploitation “Mont- 1011 NRA Spain Negre” power 3,300 MW Zaragoza, Spain 1036 SR Mar de Aragón
The Dutch NRA explains the expected year of commissioning is 2023 and it has been rescheduled during the completion of the draft EU TYNDP 2022. The Dutch NRA explains the project has been delayed and the date of commissioning rescheduled. The delay occurred during the completion of the draft EU TYNDP 2022.
PUBLIC
Opinion No 04/2023
Non- Spain 1019 Hydro-pumped electricity storage GIRONÉS & RAÏMATS compliance to Distributed network of Hydrogen storage and production by Implementation France 1042 electrolysis with re-electrification through a fleet of FCEVs Guidelines Non- 1014 Coire Glas compliance to 1015 Cruachan 2 Implementation United Guidelines Kingdom 1022 CARES (Compressed Air Renewable Energy Storage) (non-EU country)
Table 16: Transmission investments and storage projects without information on CAPEX and/or OPEX or on the cost uncertainty range
Investment Investment name number No
474 Substation Ribeira de Pena
information on CAPEX
1214 Ejea de los Caballeros substation
and OPEX
1785 Inkoo-Hikiä 1810 HVDC converter stations and cables 1811 Offshore Wind Connection Centre Manche 2
No
information 1812 Offshore Wind Connection South Britanny on OPEX 1808 AO6 Occitanie
1809 AO6 Occitanie 1813 Offshore wind connection South Atlantic 38 HVDC Gatica-Cubnezais 635 Elmed Project 90 90 1041 Rem. lim. in Central Italy
No
New 66km double circuit 400kV OHL between existing Foggia and
information
86 Villanova 400kV substations, also connected in and out to the Larino and
on the cost
Gissi substations
uncertainty
645 OHL between the Laino and Altomonte in Calabria
range
1727 Montecorvino-Avellino and Nord-Ben. in Campania 1055 (storage) CAES Leer, Germany 1056 (storage) CAES Etzel, Germany 1057 (storage) CAES Harsefeld-Stade, Germany
Table 17: Projects without an explanation for the necessity of clustering
Project number Country code Project name Number of investments
259 HU, RO HU-RO 6 270 ES, FR FR-ES project -Aragón-Atlantic Pyrenees 4 276 ES, FR FR-ES project -Navarra-Landes 4 HVDC corridor from Northern Germany 1034 DE 2 to Western Germany 1046 FI Finnish North-South reinforcement 5 1059 IT Southern Italy 2
PUBLIC
Opinion No 04/2023
Table 18: Projects for which the status in the draft EU TYNDP 2022 does not correspond to the status of its least mature investment
Project number Investment status of in the EU Project name Project status the least mature TYNDP 2020 investment
Planned but not yet in 85 Integration of RES in Alentejo In permitting permitting Baltic States Synchronization 170 In permitting Under consideration with Continental Europe 230 GerPol Power Bridge I Under construction In permitting Stevin-Izegem/Avelgem Planned but not yet in 329 In permitting (Ventilus): new corridor permitting Avelgem-Courcelles (Boucle du Planned but not yet in 340 In permitting Hainaut): new corridor permitting Planned but not yet in 349 MaresConnect Under consideration permitting
Table 19: Transmission investments not labelled as new in the draft EU TYNDP 2022
Investment Country Investment name Progress of investment number code
1763 CH Beznau - Mettlen Investment on time 1764 SE SE North-south Long-term reinforcements Investment on time 1767 CH Mettlen - Ulrichen Investment on time 1768 CH Bickigen - Chippis Investment on time 1783 LT, LV ,SE Nybro-Hemsjo Delayed 1784 LT, LV, SE Ekhyddan-Nybro Delayed 1815 DE, DK, NL Dutch Hub Investment on time 1816 DE, DK, NL German Hub Investment on time 1817 DE, DK,NL Interconnection Danish hub to Dutch hub Investment on time 1818 DE, DK, NL Interconnection Danish hub to German hub Investment on time 1819 DE, DK, NL Interconnection Dutch hub to German hub Investment on time Upgrade of the existing 220kV double circuit 1827 RO, RS Rescheduled OHL Arad -Timisoara - Sacalaz to 400kV 1832 HU, RO RO1 Investment on time 1833 HU, RO RO2 Investment on time 1834 HU, RO RO3 Investment on time 1835 HU, RO RO4 Investment on time 1836 HU, RO RO5 Investment on time
Table 20: Transmission investment with inconsistent information about the progress and commissioning date
Progress of Expected Expected investment Investment Country commissioning commissioning Investment name in the draft number code year in year in draft EU TYNDP TYNDP 2020 TYNDP 2022 2022
New 66km double circuit 400kV OHL between existing Foggia and 86 IT Villanova 400kV 2024 12-2027 On time substations, also connected in and out to the Larino and Gissi substations
PUBLIC
Opinion No 04/2023
Progress of Expected Expected investment Investment Country commissioning commissioning Investment name in the draft number code year in year in draft EU TYNDP TYNDP 2020 TYNDP 2022 2022
New 30km single circuit
400kV OHL between the
96 IT future substations of Deliceto 2021 05-2022 On time
and Bisaccia, in the Candela
area
400kV OHL Cernavoda- 273 BG, RO 2023 12-2022 On time Stalpu
308 CZ Vernerov-Vitkov 2023 06-2024 On time
Reinforcements SE2-SE3 in 403 SE 2030 01-2035 On time Sweden
BRABO II: Zandvliet - Lillo 445 BE 2020 01-2021 On time - Liefkenshoek
605 BE BRABO II: Lillo 380 2019 01-2020 On time
France Ireland 810 FR, IE 2026 03-2027 On time Interconnector
Nautilus multi purpose 934 BE, GB 2028 12-2030 On time interconnection UK - BE
997 AT, DE 997 Pleinting - St. Peter 2028 12-2030 On time
Van Eyck - Gramme: HTLS 1050 BE 2029 12-2032 On time upgrade
2nd interconnecter between 1107 BE, DE 2035 12-2038 On time Belgium and Germany
1431 GR Lavrio - Levitha 2024 01-2025 On time
1458 FR, IT SACOI3 2024 12-2026 On time
Isar/Altheim/Ottenhofen - St. 1473 AT, DE 2024 12-2026 On time Peter
DE, DK, 1504 Danish Hub 2035 01-2032 On time NL
DE, DK, Interconnection DKw to 1505 2035 01-2032 On time NL Danish hub
Gramme - Courcelles: HTLS 1515 BE 2033 12-2038 On time upgrade
Mercator - Bruegel: HTLS 1517 BE 2025 12-2026 On time upgrade
New Substation 400/110 kV 1535 BA, HR 2029 12-2030 On time Lika
Tyrrhenian HVDC link - 1557 IT 2025 12-2027 On time West
Refurbishment of the 400kV
1559 GR, MK Meliti (GR)-Bitola (MK) 2036 06-2035 On time
interconnector
1593 Uprate Gatica-Guenes 2025 12-2026 On time
48 Uprate Gatica-Amorebieta- 1595 ES 2025 12-2026 On time Ichaso
1597 Uprate Gatica-Azpeitia 2025 12-2026 On time
The Spanish NRA explains the dates have been amended according to the Spanish NDP 2021-2026.
PUBLIC
Opinion No 04/2023
Progress of Expected Expected investment Investment Country commissioning commissioning Investment name in the draft number code year in year in draft EU TYNDP TYNDP 2020 TYNDP 2022 2022
1620 DE, LU Substation Aach 2025 12-2026 On time 1629 DE, LU Substation Bofferdange 2025 12-2026 On time EE, LT, New 330 kV Darbenai 1660 2025 12-2024 On time LV, PL substation HVDC from Heide/West to 1693 DE 2030 12-2031 On time Polsum New AC 400 kV 1738 GR, TR interconnection line Greece - 2036 06-2035 On time Turkey
Table 21: Investments with insufficiently concrete description
Investment Country Investment name Description of investment number code
The technical solution is subject 650 BE, DE, LU BE-LUX-DE Long-Term perspective to further studies New HVDC line between Villanova and 1521 IT HVDC lines Fano existing 400 kV substations Voltage increase of all existing lines to 380 kV (without an 1583 AT Vorarlberg increase of the line crosssection) and 2 new 380/220 kV transformers in Bürs 1557 IT Tyrrhenian HVDC link - West Italian HVDC tri-terminal link 1763 CH Beznau - Mettlen line 1767 CH Mettlen - Ulrichen AC Line 1768 CH Bickigen - Chippis line 1795 IT Tyrrhenian HVDC link - East Tyrrhenian HVDC link - East
Fotnoter
- 2 The Romanian NRA explains all the listed investments are included in the Romanian NDP and the NRA has not identified any inconsistency with the draft EU TYNDP 2022. In this Opinion, a project may be composed by one or more investments. The part of the draft EU TYNDP 2022 investment which belongs to a country is called ‘national part of an investment’. E.g. if an investment is an interconnector between countries A and B, it is considered that there are two national parts: one consisting of the part of the investment located in country A, and the other consisting of the part of the investment located in country B.
- 10 Investments 256 ‘New interconnection line BG-GR by a 153km single circuit 400kV OHL’, 1211 ‘HVDC Aragon region-Marsillon’, 1630 ‘AC Overhead Line Aach-Bofferdange’ and 1772 ‘Roost-Flebour-Bauler’ 11 The remaining 14 transmission projects are located in Bosnia, Egypt, Switzerland and United Kingdom and the remaining 3 storage projects in United Kingdom.
- 13 1003 (‘Hydro-pumped storage in Bulgaria – Yadenitsa’), 1004 (‘Estonian PHES’), 1006 (‘HPS Amfilochia’) and 1044 (‘Green Hydrogen Hub CAES’) 14 Including 14 transmission investments that are reported to only be described or mentioned in the NDP, without yet being approved.
- 15 Among the six storage projects that are included in the relevant NDP, two (1001 ‘Kaunertal Extension Project’ and 1035 ‘Ptolemaida Battery Energy Storage System’) are reported to only be mentioned in the NDP. 16 The Agency’s Opinion No 05/2021, p. 38-40
- 18 The Agency’s Opinion No 05/2021, p. 7 19 In total, including the territory of non-EU and non-EEA Member States, 92 transmission investments and 10 storage projects from the TYNDP 2020 are not present in the draft TYNDP 2022.
- rd (50) According to the 3 ENTSO-E Guideline for Cost Benefit Analysis of Grid Development Projects (‘CBA 3.0 Guideline’) :
- 21 CBA 3.0 Guideline, p. 93-96 22 CBA 3.0 Guideline, p. 110-112
- 23 The Agency’s Opinion No 04/2021, p.12 24 CBA 3.0 Guideline, p. 20 25 https://eepublicdownloads.blob.core.windows.net/public-cdn-container/tyndpdocuments/TYNDP2022/ACER-opinion/CBA-IG.pdf
- 26 For more information, see section 5.1. 27 Investment numbers 1661, 1662, 1663, 1664, 1665, 1702, 1703, 1704, 1498, 1499, 1521, 1642, 1646, 1652, 1653, 1622, 1623, 1555, 1677, 1688, 1689, 1697, 1706, 1707, 1708, 1727, 1736, 1740, 1741, 1750