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ACER publishes its Opinion on the European Network of Transmission System Operators for Gas (ENTSOG) draft Ten-Year Network Development Plan (TYNDP) 2022 for gas and hydrogen sectors.
What is this ACER Opinion about?
- ACER welcomes the increased focus of the TYNDP on the energy transition, the dual gas system modelling approach that considers both hydrogen and traditional natural gas networks simultaneously, and that for the first time the TYNDP covers hydrogen projects.
- ACER considers the estimated investment costs of all projects included in the TYNDP 2022 unprecedentedly high (at €110 billion). Hydrogen projects (at €77.5 billion), primarily in early stages, account for almost 70% of these costs.
- ACER finds it difficult to understand why this TYNDP includes such a large portfolio of 'conventional' gas infrastructure projects in the context of the EU Green Deal, the expected reduction of natural gas demand from 2030 and the revised TEN-E Regulation, which excludes 'conventional' gas infrastructure projects from becoming Projects of Common Interest (PCIs).
Recommendations:
ACER still finds room for improving the TYNDP in the following areas:
- Planning and consultation of stakeholders;
- Submission of projects;
- Costs transparency;
- Implementing Cost-Benefit Analysis (CBA);
- Identifying infrastructure needs for hydrogen projects;
- Reconsidering the inclusion of gas projects that may exceed reasonable infrastructure needs.
ACER expects ENTSOG to implement these recommendations to improve the current and future TYNDPs, benefiting European consumers and supporting decarbonisation goals.
