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2 Feedback Section

2.1 From draft to final TYNDP 2022

2.1.1 What has happened since the draft TYNDP publication?

ENTSOG released the draft publication of TYNDP 2022 on 11 April 2023 and launched in parallel a public consultation until 19 May 2023, to allow for stakeholder engagement and continual improvement of the report.

On 25 April, within the public consultation period, ENTSOG hosted a TYNDP Presentation Day webinar open to all stakeholders. This webinar enabled a high-level introduction to the TYNDP 2022 and its role as part of EU regulation, providing a summary of the content and more insights into the results of the assessment.

A wide range of stakeholders had the opportunity to ask questions and participate in discussions on the TYNDP process. A recording of the TYNDP presentation webinar is available on ENTSOG website1.

On 26 May 2023, the draft TYNDP 2022 was submitted to ACER, together with the results of the public consultation, for its Opinion. The Opinion was issued on 14 July 2023 and includes ACER’s noted improvements from the previous edition of TYNDP and recommendations for further improvement, categorised as short and the medium to long-term.

2.1.2 Why a feedback section?

This section aims at presenting the feedback received from both ACER and other stakeholders and describes how the relevant feedback could be addressed in the final TYNDP 2022. The way in which such feedback is addressed is covered in the feedback section itself, rather than in the related sections of the TYNDP, to better facilitate the overview. For other feedback not addressed in TYNDP 2022 but that could be taken into consideration for future editions of the TYNDP – this section indicates into which process it will feed.

The feedback assessment is presented to first respond to the ACER Opinion, covering both the short-term recommendations relating to the TYNDP 2022 and the medium to long-term recommendations for future editions of the TYNDP. This is followed by an analysis of the public stakeholder consultation feedback.

2.1.3 Comparison of past assumptions and projections of gas demand and supply with actually observed (historical) levels

From one TYNDP edition to the next, ENTSOG critically reviews the TYNDP input data, in ­particular the demand scenarios and supply potentials.

For each new TYNDP edition ENTSOG develops ­elements that are discussed as part of the stakeholder engagement process, and this comparison is a way to better formalise its usual formal analysis of assumptions. Supply

Figure 2.1 compares the TYNDP 2022 supply potentials for 2025 with the actual historical EU imports. For Norway, Algeria, LNG, Azerbaijan and Libya, actual 2022 imports are similar to the range of the potentials expected for 2025 in ­TYNDP 20222. Russian range has been disregarded because this supply source was minimised under all circumstances. In addition to Russian supply minimalisation, the minimum supply range of all other sources are no longer considered, focusing on the maximum supply potential.

As part of the TYNDP 2022 process, the supply potentials were amended to better correlate with the historical EU import.


Figure 2.1: Actual Gas supply 2009–2022 and TYNDP 2022 supply potentials (year 2025) Demand

TYNDP 2022 has three scenarios: National Trends, which is developed based on the collection of data from TSOs, and two COP 21 scenarios – Global Ambition and Distributed Energy – which are developed by the scenario building process.

As for previous TYNDP editions, total gas demand was made up of Final Gas Demand (defined as Residential & Commercial, Industrial and Transport sectors) and Gas Demand for Power Generation. Gas demand for Power Generation for all scenarios, jointly developed by ENTSOG and ENTSO-E, is derived from modelling results. During the data collection phase, gas and electricity TSOs worked together to assess gas installed capacity on a country level basis. Yearly Gas Demand for Power Generation averages is calculated from the average of all approved models across all climate years3.

The Best Estimate scenarios for 2022 and 2025 were based on the TSO perspective, reflecting all national and European regulations in place, whilst not conflicting with any of the other scenarios.
National Trends is the central policy scenario, designed to reflect the most recent EU Member States’ National Energy and Climate Plans (NECP), submitted to the EC in line with the requirement to meet current European 2030 energy strategy targets.

In addition, ENTSO-E and ENTSOG have ­created two scenarios in line with the COP 21 targets ­(Distributed Energy and Global Ambition) with the objective to understand the impact on infrastructure needs against different pathways reducing EU-28 emissions to net-zero by 2050.

Global Ambition is a scenario compliant with the 1.5 °C target of the Paris Agreement and ­considering the EU’s climate targets for 2030. It looks at a future that is led by development in centralised generation. Economies of scale lead to significant cost reductions in emerging technologies such as offshore wind, but also imports of energy from competitive sources are considered as a viable option.

Distributed Energy embraces a de-centralised approach to the energy transition. A key feature of the scenario is the role of the energy consumer (prosumer), who actively participates in the energy market and helps to drive the system’s decarbonisation by investing in small-scale solutions and circular approaches.

Figure 2.2 shows the progression of EU level actual demand, versus the result of the TYNDP 2022 under National Trends, Global Ambition and Distributed Energy scenarios.

It is important to note that the demand levels shown reflect the actual weather conditions, whereas data collected for the scenarios represents yearly demand under average climatic conditions.

3 TYNDP 2022 Scenario Report: Building Guidelines (, Chapter 4.1.

Figure 2.2: Actual EU Gas Demand 2000–2022, TYNDP Demand Scenario data (Data Source Eurostat and

Figure 2.2 shows a drop of around 11 % for gas demand between 2013 and 2014, driven by many factors: low coal and CO2 prices with these fuels then replacing gas in the power generation mix; a continuation of slow economic growth; and a significantly warmer than average year, leading to significant reduction for heating.

The graph also shows that EU gas demand in 2015 saw a 4 % recovery from the previous year to 4,595 TWh, which can again be linked to a number of factors, with sectoral differences at a country level.

During 2016, EU gas demand increased again by 6.7 % to 4,903 TWh. The reduction in gas prices starting at the end of 2015 continued into first half of 2016, and although gas prices increased in the final quarter of the year, coal prices increased 68 % compared to same period in 2015. This meant gas competitiveness increased in the power generation market. Power generation analysis has shown a significant coal to gas switch in a number of countries during 2016, linked to the above-mentioned price situation, but also influenced by the ongoing Carbon Price Floor4 policy in the UK.

In 2017, further increase in gas demand was observed, reaching 5,077 TWh (+3,5 %). The apparent coal to gas switch continues moderately. Gas prices were higher when compared to previous the year – strong demand of gas for power and storage injections have supported gas price in EU hubs during the summer and increase in gas demand in the winter.

In 2018, stabilisation in the context of gas demand was observed –5,080 TWh was reached, meaning that value was comparable to 2017. At the beginning of the year, Europe experienced an extreme cold spell. Gas hub tested to limit on the cold snap and prices reached multi-year highs. These circumstances led to declaration of early warnings in a few European countries and significant gas withdraw from storages was observed. During that summer, gas consumption was lower and allowed for gas storages filling. During the last quarter of 2018, there was a decrease of gas demand when compared with that of 2017.

The graph shows that in 2019, there was a preference for gas over coal in the power generation with an increase (when compared to 2018) of 5,171 TWh. The warm weather in the first quarter of the year enabled a transition to summer with considerably high gas volumes in storages. Plentiful supply, falling gas prices and flexibility during the first quarter of the year allowed for very high stock level to be reached at the beginning of the winter and moderate usage of gas inventories in the last quarter. In 2019, LNG strengthened its role in supplying Europe.

In TYNDP 2018, all scenarios have been realistically built, technically sound and based on forward looking policies, whilst also being ambitious in nature and aiming at reducing emissions. For the first time in 2018, the ENTSOs for gas and electricity have worked together, using their unique expertise to provide a broad, common and technically feasible joint set of scenarios. This is key to test the need and performance of possible future infrastructure in challenging but credible situations. Future scenario development processes will seek to enhance and improve gas and electricity interactions, looking for synergies, leading to better sharing of data and cooperation.

Following stakeholders’ request for some continuity in the scenario storylines, TYNDP 2022 scenarios are built based on the TYNDP 2020 scenarios. However, the energy landscape is continuously evolving, and scenarios must keep up with the main drivers and trends influencing the energy system. All scenarios head towards a decarbonised future and have been designed to reduce GHG emissions in line with EU targets for 2030 and / or the United Nations Climate Change Conference 2015 (COP 21) Paris Agreement objective of keeping temperature rise below 1.5 °C.

2.2 ACER Opinion and Recommendations

The full ACER Opinion on the draft TYNDP 2022 can be found on the ACER website5. The following section will provide responses in the same order as the Conclusions of the Opinion.

2.2.1 Recognition of improvements

The ACER Opinion included the following recognition of improvements achieved in the process, methodology and outcome of the draft TYNDP 2022 when compared to TYNDP 2020:

  1. A better presentation of the TYNDP features via dedicated visualisation tools;
  2. The implementation of a common ENTSO-E and ENTSOG process for the development of scenarios for the TYNDP 2022 and the preparation of a stand- alone “scenario report”;
  3. The provision of a window of opportunity for NRAs to check input data for the submitted ­TYNDP candidate projects at an early stage, ­during December 2021;
  4. The increased focus of the TYNDP on Energy Transition aspects and better alignment with the Green Deal decarbonisation goals. This is manifested by a dual gas system modelling approach that considers hydrogen and methane networks simultaneously and through collection of different types of hydrogen projects and network projects aimed at the injection of biomethane;
  1. The consideration of the REPowerEU objectives reflected in the scenarios, even though not representing mandatory targets, and the projects eventually included in the TYNDP;
  2. An open and transparent process for the collection of projects and detailed information and analysis of the projects’ implementation schedule by type of project;
  3. Information related to projects included in the last edition of the TYNDP and triggered by the incremental capacity process;
  4. The collection and publication of methane emission mitigation measures for methane infrastructure projects.

2.2.2 Short-term Recommendations

The ACER Opinion provides for a number of short-term recommendations (Section 4, page 24) listed in the table below, in the order they appear in the ACER Opinion. The TYNDP topic to which these recommendations refer are also indicated in the table below.

ACER short-term recommendationsRelated ­TYNDP topicParagraph in which the recommendation is handled
The comments and remarks of NRAs on the TYNDP 2022 projects, as contained in Annex I to this Opinion.Additional section in the final TYNDP2.2.2.3
Review and re-publish Annex D (methodology) with the aim of enhancing its comprehensiveness. This annex should provide detailed explanations of the assumptions and calculation steps underlying the methodology, particularly with regard to sustainability, and include practical examples illustrating how to interpret the indicators. MethodologyAnnex D
Complement Annex D by publishing all underlying data sets, qualitative assumptions, and formal hypotheses, as granular and disaggregated as possible, in an appropriate and predefined format, in line with Article 11(6) of the recast TEN-E Regulation.MethodologyAnnex D
The publication of a summary document indicating how feedback from the public consultation and from ACER’s Opinion are taken into account for the final TYNDP 2022 and will be considered in future TYNDPs.Additional section in the final TYNDPFeedback chapter
Publish the project-specific CBA assessments results, including the Economic Performance Indicators, in line with Article 11 (6) and Annex V of the recast TEN-E Regulation.Project assessmentProject Fiches
Publish the “enhanced capacities” as well as the related conditions for these capacities to be made available by the respective TSOs. System Assessment2.2.2.1
Update information on how the incremental capacity process initiated in 2021 has evolved since June 2022. Infrastructure Report2.2.2.2

Table 2.1: Short-term ACER recommendations.

Addressing the ACER recommendations is indicated per related TYNDP topic. Methodology and Assessment

Annex D

Annex D was updated by adding further information regarding the storages’ behaviour, the cooperation between the hydrogen and the natural gas networks, the supplies merit order structure, the enhanced capacities application and the CO2 emissions calculation. Simulation results were also published in form of tables in the revised Annex D.2.

Publication Project Fiches

Enhanced Capacities used under condition of “no Russian supply”

Enhanced Capacities are generally considered to be sensitive data and, in some cases, even as confidential information. Infrastructure Report

Update Incremental capacity process initiated in 2021

During the Demand Assessment phase (in 2021), six TSOs/market areas received non-binding capacity requests from network users, but only in two cases incremental capacity has been offered in the binding auctions in July 2023, namely at the Polish-Ukrainian and the Belgian-German borders.

At this time ENTSOG cannot provide more detailed information on the capacity process initiated in 2021 and cannot provide an update. The “monitoring” process is expected to start shortly after the final publication of TYNDP 2022. NRA Comments on the TYNDP 2022 projects

During the TYNDP 2022 Project Collection process, ACER and NRAs were provided with the project data collected for their review and feedback. Promoters were informed on the informal preliminary comments provided by ACER and NRAs and could amend the information provided during the project data collection if deemed necessary. Therefore, the Draft TYNDP 2022 Annex A already includes the NRAs’ feedback whenever considered by promoters.

Other information, such as the maturity of a project, is provided by ENTSOG based on the information submitted by the project promoters and after having applied specific rules as defined in the TYNDP 2022 Practical Implementation Document and in TYNDP 2022 Annex D (Methodology).

As part of its Opinion, ACER offered NRAs an opportunity to provide comments on the projects submitted to TYNDP 2022. These comments are available as an annex to ACER Opinion6 and provide supplemental information on projects, in addition to the promoter information collected as part of TYNDP Annex A.

The comments from the NRAs in particular reflect recent project information and, in many cases, own NRAs views on projects benefits. In some cases, NRAs identified incorrect data.

Some project data have been updated after TYNDP 2022 project collection, and on some occasions reflected in national NDPs. Such updates are not included in the Final TYNDP 2022, to ensure consistency between the project information used to perform the TYNDP assessment, and the project information published. In this context, NRAs input on recent project information represents a valuable additional information for stakeholders even if not included in the Final version of TYNDP 2022.

In cases where NRAs refer to the actual merit of the project, it must be noted that TYNDP is based on transparent and consulted rules for project inclusion and assessment, ensuring a non-discriminatory process and prevention of conflict of interest.

2.2.3 Medium-term and long-term Recommendations

The following table illustrates the medium and long-term ACER Opinion recommendation and the TYNDP (or ENTSOG) processes where are, or can be, addressed.

ACER long-term recommendations (­TYNDP20)Related ­TYNDP / ENTSOG process
Implementing ACER’s recommendations regarding scenarios, as provided in its framework guidelines for the joint TYNDP to be developed by ENTSOsTYNDP Scenario Report
Improving the planning of future TYNDP processesTYNDP process
Plan new TYNDP activities and consultations by the revised TEN-E RegulationTYNDP Scenario Report/TYNDP System Assessment
Increasing stakeholders’ engagement in the processTYNDP process
Single data project collection TYNDP process/TYNDP Project Collection
Improve alignment of project categories with infrastructure categories as defined in recast TEN-E RegulationTYNDP/Practical Implementation Document
Include only “conventional” gas infrastructure projects in the TYNDP needed to address the assessed gapsTYNDP/Practical Implementation Document
Require information from hydrogen infra-structure promoters on the status of market testing and consultations TYNDP Project Collection
Update draft CBA Methodology following future Opinion of ACER, Member States’, and stakeholdersCBA methodology
CBA project assessment for all projectsTYNDP/Project assessment
Encourage promoters to provide more information on costsTYNDP/Practical Implementation Document
For methane projects consider the level of utilisation, and contractual and physical congestion for assessing the need for additional infrastructureTYNDP/System assessment
For methane projects consider the level of utilisation, and contractual and physical congestion for assessing the need for additional infrastructureTYNDP/System assessment
Redesign the approach for the identification of infrastructure gapsTYNDP/System assessment
Adapt the sustainability indicator TYNDP/System assessment
Adapt the assumption under all SoS indicators by prioritising avoided methane demand curtailment over hydrogen demand curtailment. TYNDP/System assessment
Incorporate an indicator for market integration TYNDP/System assessment
Properly reflect differences in gas and hydrogen supply prices and if possible, align them with price assumptionsTYNDP/System assessment
Further development of contribution of methane and hydrogen storagesTYNDP/System assessment
Assessment of necessary adaptations of gas infrastructure to inject RES and decarbonised gases, and related costsTYNDP/Project assessment
Develop ways for analysing and addressing methane and hydrogen emissionsTYNDP/Project assessment
Implement interlinked model jointly with ENTSO-E to analyse electrolysers and their impact on the gridTYNDP/Project assessment
Publish all relevant input and output of TYNDP simulations and make them easily accessible and downloadableTYNDP Publication

Table 2.2: Medium and long-term ACER recommendations. Scenarios, planning and consultation of next TYNDP

TYNDP Scenarios

ENTSOG, together with ENTSO-E, have implemented a number of recommendations of the ACER Opinion 6/2020 in the TYNDP 2022 scenario ­building process and will consider further recommendations in the Scenario report itself.

Improving the planning of the future TYNDP processes and stakeholders’ engagement

ACER recommends to better plan the future TYNDP processes to avoid recurrent delays in the development and the release of TYNDPs. Furthermore, ACER recommends a careful planning of new TYNDP activities and consultations introduced by the revised TEN-E Regulation. In general, ACER encourages ENTSOG to increase the involvement of stakeholders and of gas and hydrogen network operators in the TYNDP development process.

ENTSOG is constantly working on improving the TYNDP process, which includes lessons-learned and feedback received from ACER and other stakeholders. For upcoming stakeholder engagement processes within the TYNDP, ENTSOG makes every effort to effectively promote events and consultation phases open to all stakeholders. At the same time, it is important to underline that the implementation in each new TYNDP and of new updates due to feedback from stakeholders (including ACER’s) there is an inevitable impact on the timeline and creates uncertainty for final publication. Several interactions with stakeholders and delays in responses have an impact on the timeline, but the priority for ENTSOG is to ensure that all stakeholders have an opportunity to contribute and provide their feedback.

For TYNDP 2024, as per ACER recommendation, ENTSOG intends to plan for the process in line with Articles 9 (2) and 10 of Regulation 715/2009, and to publish the draft TYNDP mid-2024. Collection of TYNDP projects

Project Data collection

ACER recommends implementing a common cut-off date for all types of projects within a single data collection process, which should be as close to the publication date of the TYNDP as possible.
In the current timeline for TYNDP 2024, ENTSOG foresees one single data collection for projects. However, it must be noted that after the closure of the Project Data Collection, ENTSOG is undertaking a comprehensive data quality check on received project data to ensure consistency and meaningful simulation later in the process. Data collection for projects is a long and important process for ENTSOG as it is a fundamental prerequisite to the modelling and simulations. The input data are the basis for the network assessment.

Project categories and mandatory data

ACER recommends improving the alignment of new project categories collected for TYNDP with the infrastructure categories as defined in the revised TEN-E regulation, and to include only “conventional” gas infrastructure projects in the TYNDP needed to address the assessed gaps.

ACER suggests that this could be achieved by filtering out “unrealistic” projects.

Following the recommendation of ACER, projects with unrealistic timelines or those not addressing any apparent need should not be included in the TYNDP. ACER’s last recommendation on this topic is to require mandatory information from hydrogen infrastructure promoters on the status of market testing and consultations and to consider such information for the identification of needs of hydrogen infrastructure projects.

ENTSOG is revising its Guidelines for Project Inclusion (GPI) after each TYNDP. Besides updates required by the revised TEN-E regulation, important input for the revision of this document is feedback received from ACER’s Opinion and the stakeholder consultation on TYNDP 2022. In addition, ENTSOG is planning dedicated events for stakeholders to comment on the Draft GPI for TYNDP 2024.

The most current GPI will aim at better alignment with the revised TEN-E Regulation, which was published during the TYNDP 2022 process, and to synchronised collected project categories for a better harmonisation for the second PCI process under the revised TEN-E. For future TYNDP editions, the introduction of additional criteria in the project guidelines can help filter submitted projects. With decreasing methane demand, this also plays an important role. After the finalisation of the GPI, ENTSOG will adapt its project portal, to also include the configuration of new (mandatory) questions. CBA Methodology and infrastructure needs assessments

ENTSOG is constantly working to improve indicators for each TYNDP application of its CBA ­Methodology.

Update draft CBA methodology

ENTSOG published a new draft single-sector Cost-Benefit Analysis (CBA) methodology for the assessment of hydrogen infrastructure, that was created on the basis of Article 11 of the Regulation (EU) 2022/869 on guidelines for trans-European energy infrastructure (TEN-E Regulation). This draft methodology was prepared with consideration of the feedback received during the extensive consultation of the preliminary methodology.

In addition, ENTSOG has submitted its draft CBA methodology to the Member States (MSs), the European Commission (EC), and ACER for opinion as required by regulation. Within three months after receipt of the opinion of ACER and MSs, ENTSOG will amend its methodology to take account of ACER and MS opinions, and finally submit it to the EC for approval.

Requiring CBA projects assessments for all the TYNDP projects instead of PCI applicants only

In line with Regulation (EU) 869/2022 ENTSOG undertakes project-specific cost-benefit analyses (PS-CBA) for all PCI/PMI candidate projects. While Regulation (EU) 860/2022 states that only projects “having reached a sufficient degree of maturity” must receive a PS-CBA, ENTSOG, assessing any project indicating its intention to apply for the following PCI selection process independently of their “maturity” level, already assesses a broader scope of projects and ensures a fair assessment of any of the PCI/PMI candidates.

Providing project cost information irrespective of their intention to apply for PCI status

ENTSOG supports and encourages maximum levels of transparency from promoters. At the same time, ENTSOG must respect the request for confidentiality for projects not applying for PCI/PMI selection process. Additionally, comparability is not an issue since those projects do not receive a project-specific cost-benefit analysis.

Consideration of level of utilisation and contractual and physical congestion of interconnection points for methane projects

In previous TYNDPs ENTSOG considered long-term capacity booking contracts (LTCB) as part of the market layer. This TYNDP 2022 System Assessment does not include LTCB. This does not have any impact of physical bottlenecks. For long-term supply contracts, those are already included at European level in the “minimum” defined for each supply source potential. The different supply sources’ minimum values are based on publicly available literature, exchanges between ENTSOG and the main suppliers as well as on the stakeholder’s feedback received during dedicated workshops. For TYNDP 2022 ENTSOG included an additional assumption for Russian supply minimisations which lead to a higher “minimum” for all other supply source potentials.

For physical congestions, which are often seen as flows, a careful interpretation of utilisation must be conducted as general statements are not constructive or feasible. For instance, a project could show a low level of utilisation, but consideration for an upstream bottleneck may be omitted. Alternatively, a project could show a high level of utilisation, but consideration of an alternative route that could replace it and would therefore guarantee security of supply could be omitted.

Consideration of physical congestion is already embedded in the way the many TYNDP 2022 indicators are calculated: a physical bottleneck will identify an infrastructure need. Flows resulting from ENTSOG simulations are just one of the possible solutions that the simulation tool might provide. The level of utilisation of existing infrastructure and submitted projects might differ from one simulation to another, depending on the underlying assumptions. To assess situations where existing infrastructure is prioritised, ENTSOG runs sensitivities on the value of the tariffs assumed for the projects. In the same way, the sustainability indicator computed for TYNDP 2022 considers, in the allocation of benefits to projects, that existing infrastructure are always prioritised.

Annex D provides more information on the approach taken.

Redesign the approach for the identification of infrastructure gaps

ENTSOG considers different hydrogen infrastructure levels in its draft CBA methodology for the assessment of hydrogen infrastructure. More specifically, for TYNDP 2024, ENTSOG proposes in this document three hydrogen infrastructure levels to be used in the TYNDP System Assessment:

  • Advanced hydrogen infrastructure level that will be based on the existing network together with those projects whose status of implementation is more advanced and, therefore, with a higher likelihood of being successfully implemented.
  • PCI hydrogen infrastructure level will consist of the advanced hydrogen infrastructure level and will additionally contain the latest list of ­hydrogen infrastructure projects of common interest (starting from the sixth PCI list, i. e., the first PCI list under the revised TEN-E Regulation once adopted).
  • TYNDP hydrogen infrastructure level will consist of the PCI hydrogen infrastructure level as well as all remaining projects submitted to the TYNDP.

In a similar way, ENTSOG defines two natural gas infrastructure levels in its draft CBA methodology:

  • FID natural gas infrastructure level should at least consider all the existing infrastructures together with projects having an FID status.
  • Advanced natural gas infrastructure level will consider FID infrastructure level together with the projects meeting the criteria defined for advanced projects.

Definition of the conditions to be fulfilled and considered as advanced hydrogen and natural gas projects will be defined in the TYNDP 2024 Practical Implementation Document.

In addition, as detailed in section CBA ­Methodology and infrastructure needs assessments, ENTSOG is currently in the process of preparing its final CBA Methodology taking into consideration the EC’s, ACER’s and MSs’ opinions. Hydrogen infrastructure levels included in the final CBA methodology might differ if required by these opinions. Modelling assumptions for the system assessment

Adapt the sustainability indicator

This potential demand fuel switch will be measured by societal benefit due to the GHG emissions variation indicator (B1) and societal benefit due to the non-GHG emissions variation indicator (B4) defined in the new CBA methodology.

These indicators consider the change of GHG (and non-GHG) emissions as a result of changing the generation mix of the electricity sector or the supply source used to meet hydrogen demand (including GHG emissions savings from replacement of alternative fuels in non-power sectors).

Adapt the assumption under all SoS indicators

In this edition of the TYNDP the cooperation between methane and hydrogen is assumed, i.e., the available infrastructure is used to equalise to the extent possible the curtailment rates of the different countries or balancing zones (e.g., natural gas customers could (partially) share the burden by curtailment to allow for blue hydrogen production to mitigate hydrogen supply disruptions). In the next TYNDPs ENTSOG will reevaluate this assumption.

Incorporate an indicator for market integration

Market integration is proposed to be measured by the social economic welfare indicator (B2) and cross-border impact of hydrogen transmission projects (B6) as defined in ENTSOG’s revised draft CBA methodology. This draft CBA methodology is currently awaiting feedback from ACER, the EC, and the MSs.

Properly reflect differences in gas and hydrogen supply prices

The model is driven by the carbon content of each fuel and not by the prices, as price relation between methane and hydrogen in the future is unknown, and ultimately there are binding targets regarding the CO2 emission despite the price of the fuels. Market Price assumptions in scenarios are used to establish merit order, not to assume specific price per each fuel.

Further develop the role and contribution of methane and hydrogen storages

In the next TYNDPs ENTSOG will work to further refine the proper representation of the role and contribution of methane and hydrogen storages. Network adaptations for decarbonised gases and emissions and Interlinked Model

Adaptations of the gas infrastructure to enable the injection of higher shares of renewable and decarbonised gases and the costs, implications and challenges associated

The adoption of the project categories for TYNDP 2022, including a dedicated project category for hydrogen and biomethane was welcomed by stakeholders, confirming the relevance of renewable and decarbonised gases in the future. In the next TYNDPs new criteria will be introduced and additional question included to further reflect on the importance and to allow more insights in particular on cost.

Consider ways for analysing and addressing the issue of methane and hydrogen emissions

For TYNDP 2022, ENTSOG included dedicated questions addressing provisions and actions undertook by project promoters to reduce methane emissions. Based on the lack of experience and relevant publications on measuring and analysing hydrogen emissions, ENTSOG currently cannot ­further take them into account but will follow ­further developments and include hydrogen emissions in the analysis when possible.

Implementing improvements leading to the development of a consistent and interlinked electricity and gas networks and market model

ENTSOG, with ENTSO-E, have further improved their joint work on the Interlinked Model. The Interlinked Model was used for the first time for the assessment of PCI candidate projects within the Electrolyser facility category in the 1st PCI call under the revised TEN-E. In parallel, pilot assessments of hydrogen infrastructure project are ongoing to further develop the Interlinked Model for joint system assessment both on the gas and electricity side.

ENTSOG and ENTSO-E must first fulfil the mandate given in the TEN-E revision before further work on the system needs can be considered and applied. Although much of this work has started via the scenario development process, adding this step to the TYNDP requires a full methodological overhaul in the ENTSOG and ENTSO-E system needs processes, given the methodologies used by ENTSOG and ENTSO-E differ vastly. An interlinked system needs process must be built open the Interlinked Model once its development is complete. Display of results

Publish all relevant input and output of TYNDP simulations, easily accessible and downloadable

ENTSOG is constantly working on improving the presentation of TYNDP simulations and has therefore introduced the visualisation platform. The visualisation platform is aiming for a interactive and user friendly accessibility of TYNDP results.

In the past, ENTSOG believes that the full data overview of output data has been seen as exhaustive and overwhelming by stakeholders. On that basis, the visualisation platform was developed. Addressing the request from the Opinion of ACER, simulation results were published also in form of the tables in the new Annex D.2.

2.3 Public Consultation and Stakeholder Feedback

ENTSOG opened the public consultation on draft TYNDP 2022 for six weeks from 11 April to 19 May 2023. In total ENTSOG received 13 replies.

2.3.1 Analysis of the public consultation feedback

For TYNDP 2020 ENTSOG introduced several improvements with the aim of a simple and clear presentation of TYNDP. This was welcomed by the stakeholder in the 2020 edition. ENTSOG continued with similar tools and approaches to keep an increased presentation for TYNDP 2022.

These include, for example, dedicated website and tailor-made visualisation tools allow for interactive access to the main TYNDP features. However, based on received stakeholder feedback, a slight decrease of reader friendliness is reported for TYNDP 2022.

SAR Fig 002-3

Figure 2.3: Is TYNDP 2022 easy to read and navigate through?

SAR Fig 002-4

Figure 2.4: Are the maps, graphs and tables easy to understand?

Most interesting topics

The overview of the topics identified as most interesting by stakeholders indicates that TYNDP is seen by a large share of stakeholders as a valuable source of European-wide information. In general, it can be seen that all parts are considered relevant and interesting.

The most interesting topics are information on projects submitted for TYNDP 2022 and their assessment, the dual gas system assessment, as well as the impact of REPowerEU ambitions for the system assessment.

The collection and analysis undertaken by ENTSOG is a highly valuable source of information, as well as a necessary input to the simulations and the assessment of the infrastructure.

Figure 2.5: Most interesting topics in TYNDP 2022.

Figure 2.6: Most valuable new elements in TYNDP 2022.

New elements introduced for TYNDP 2022

ENTSOG introduced a number of new elements in TYNDP 2022 and stakeholders were consulted on these new elements. All new elements are considered as valuable by the stakeholders. For the first time, ENTSOG modelled a dual gas system for natural gas and hydrogen, and this was identified as most valuable, considered as presenting a possible pathway to decarbonise the networks.

With regards to the development of a hydrogen system, stakeholders found the introduction of new project categories very helpful including a particular category for hydrogen and different maps for methane and hydrogen infrastructure. Feedback suggests that it underlines the importance of the energy transition in the perspective of the EU’s energy and climate objectives towards 2050 (Green Deal, REPowerEU, Hydrogen and Energy System Integration).

Furthermore, for the system assessment in the dual gas model, ENTSOG introduced two contrasted hydrogen infrastructure levels. A complete overview of the assumptions used for the two hydrogen infrastructure level can be found in Annex C.

TYNDP 2022 Annex C27 includes full details of hydrogen cross-border transmission capacities, import capacities (both liquid and pipeline) and injection and withdrawal capacities considered in the two infrastructure levels.

Hydrogen infrastructure level 1 was defined based on project submission data. Hydrogen infrastructure level 2 is a bottom-up infrastructure level that was based on the hydrogen infrastructure level 1 as minimum, and in addition, considers additional infrastructure assumptions – more specifically, higher hydrogen storage, import capacities, as well as higher cross-border capacities for some countries.

For more clarity, in the following tables from Annex C2, additional infrastructure assumptions considered in the hydrogen infrastructure level have been identified highlighted in blue.

TYNDP Annex C2 – intermediateH2 Transmission Yearly Capacity (GWh/d)
From CountryTo CountryLevel203020402050
Austria Germany Level 1150150150
Level 2150150150
ItalyLevel 1126126126
Level 2126219219
SlovakiaLevel 1144144144
Level 2144156156
SloveniaLevel 103333
Level 203333
BelgiumFranceLevel 1108108108
Level 2108200200
GermanyLevel 1919191
Level 29191120
LuxembourgLevel 1000
Level 201420
NetherlandsLevel 14872120
Level 2120192240
United-KingdomLevel 1000
Level 20200200
Bosnia-HerzegovinaCroatiaLevel 1000
Level 243.543.543.5
BulgariaGreeceLevel 179.9779.9779.97
Level 279.9779.9788
RomaniaLevel 117.73110.73110.73
Level 217.73110.73139.44
Croatia Bosnia-HerzegovinaLevel 1000
Level 243.543.5 43.5
HungaryLevel 10128.4128.4
Level 20128.4128.4
Serbia Level 1000
Level 263.8 63.8 63.8
SloveniaLevel 101616
Level 201616
CzechiaGermanyLevel 1144144144
Level 2144144319.2
PolandLevel 1000
Level 203030
SlovakiaLevel 1000
Level 20156156
DenmarkGermanyLevel 1151290290
Level 2151290290
EstoniaFinlandLevel 1100100100
Level 2100200200
LatviaLevel 1200200200
Level 2200200200
FinlandEstoniaLevel 1200200200
Level 2200200200
GermanyLevel 1504504504
Level 2504504504
SwedenLevel 1666666666
Level 2910910910
FranceBelgiumLevel 1108108108
Level 2108200200
GermanyLevel 1204204204
Level 2204243243
SpainLevel 1216216216
Level 2216216216
SwitzerlandLevel 1000
Level 21100100
GermanyAustriaLevel 1150150150
Level 2150150150
BelgiumLevel 1919191
Level 29191120
CzechiaLevel 186144144
Level 286144319.2
DenmarkLevel 1151290290
Level 2151290290
FinlandLevel 1504504504
Level 2504504504
FranceLevel 1192192192
Level 2192243243
NetherlandsLevel 1121212
Level 2244380559.2
PolandLevel 1100100100
Level 2100120227.14
SwitzerlandLevel 1000
Level 20168240
GreeceBulgariaLevel 175.5175.5175.51
Level 275.5175.5188
HungaryCroatiaLevel 10128.4128.4
Level 20128.4128.4
RomaniaLevel 176.8153.6153.6
Level 276.8153.6153.6
SlovakiaLevel 1100200200
Level 2100200200
SloveniaLevel 1019.619.6
Level 2019.619.6
IrelandUnited-KingdomLevel 1000
Level 207.9528.54
ItalyAustriaLevel 1168168168
Level 2168168168
SloveniaLevel 1019.619.6
Level 2019.619.6
SwitzerlandLevel 1888888
Level 2888888
LatviaEstoniaLevel 1100100100
Level 2100100126.76
LithuaniaLevel 1200200200
Level 2200200200
LithuaniaLatviaLevel 1100100100
Level 2100189.59184.31
PolandLevel 1200200200
Level 2200200200
LuxembourgBelgiumLevel 1000
Level 201420
NetherlandsBelgiumLevel 14872120
Level 2120192240
GermanyLevel 1375375375
Level 2375380559
PolandCzechiaLevel 1000
Level 203030
GermanyLevel 1200200200
Level 2200200227.14
LithuaniaLevel 1100100100
Level 2100171.51171.51
PortugalSpainLevel 1818181
Level 2818181
RomaniaBulgariaLevel 117.73110.73110.73
Level 217.73110.73139.44
HungaryLevel 176.8153.6153.6
Level 276.8153.6153.6
SerbiaCroatiaLevel 1000
Level 263.863.863.8
SlovakiaAustriaLevel 1144144144
Level 2144156156
CzechiaLevel 1144144144
Level 2144156156
HungaryLevel 1100200200
Level 2100200200
Slovenia AustriaLevel 101616
Level 201616
CroatiaLevel 103333
Level 203333
HungaryLevel 1019.619.6
Level 2019.619.6
ItalyLevel 1019.619.6
Level 2019.619.6
SpainFranceLevel 1216216216
Level 2216216216
ItalyLevel 10320320
Level 20320320
PortugalLevel 1818181
Level 2818181
SwedenFinlandLevel 1666666666
Level 2910910910
United-KingdomBelgiumLevel 1000
Level 20200200
IrelandLevel 1000
Level 207.9528.54
SwitzerlandFranceLevel 1000
Level 20100100
GermanyLevel 1000
Level 20168240
ItalyLevel 1135135135
Level 2135135135

Table 2.3: TYNDP 2022 Hydrogen cross-border capacities assumed in Hydrogen infrastructure level 1 and 2

TYNDP Annex C2 – intermediateH2 Transmission Yearly Capacity (GWh/d)
From CountryTo CountryLevel203020402050
AlgeriaItalyLevel 1448448448
Level 2448448448
SpainLevel 1000
Level 20245245
NorwayBelgiumLevel 1000
Level 20200200
GermanyLevel 1414414414
Level 2414414414
UkraineHungaryLevel 10150150
Level 20150150
RomaniaLevel 10171.8171.8
Level 20171.8171.8
SlovakiaLevel 1240240240
Level 2240312312

Table 2.4: TYNDP 2022 Hydrogen pipeline import capacities assumed in Hydrogen infrastructure level 1 and 2

TYNDP Annex C2 – intermediateLH2 Transmission Yearly Capacity (GWh/d)
LH2 importing countryLevel203020402050
LH2 Belgium >
Transmission Belgium
LH2 France >
Transmission France
Level 1484848
Level 2484848
LH2 Germany >
Transmission Germany
Level 1228228228
Level 2228228228
LH2 Netherlands >
Transmission Netherlands
Level 1108108108
Level 2144144144
LH2 United-Kingdom >
Transmission UK
Level 1000
Level 2929292

Table 2.5: TYNDP 2022 Hydrogen liquid hydrogen import capacities assumed in Hydrogen infrastructure level 1 and 2

TYNDP Annex C2 – intermediateH2 Storage Capacity (GWh/d)
Level 26.6133.3260.23
Level 26.6133.3260.23
Level 213.6883.5283.52
Level 216.82146.16226.00
Level 22.1912.1012.10
Level 21.9313.8120.74
Level 20.0012.2312.23
Level 20.0012.2312.23
Level 28.6540.8771.55
Level 212.0071.5588.35
Level 228.8028.8028.80
WithdrawLevel 19.509.509.50
Level 228.8028.8028.80
Level 23.394.484.63
Level 23.357.877.87
Level 212.1327.0327.03
Level 25.1347.3947.39
Level 240.0040.00179.62
Level 240.0040.00120.67
GermanyInjectionLevel 125.0834.0834.08
Level 2153.00328.00649.00
WithdrawLevel 129.0738.0738.07
Level 2458.00983.001,943.00
GreeceInjectionLevel 135.0035.0035.00
Level 235.0035.0035.00
WithdrawLevel 135.0035.0035.00
Level 235.0035.0042.48
Level 210.3930.2652.97
Level 215.3241.5283.75
Level 22.777.5012.77
Level 23.048.2714.27
ItalyInjectionLevel 10.0048.12146.82
Level 20.0048.12146.82
WithdrawLevel 10.0076.90146.09
Level 20.0076.90146.09
Level 20.0013.6813.68
Level 22.589.009.00
WithdrawLevel 10.0015.0015.00
Level 215.0015.0015.00
Level 236.00360.00480.00
Level 236.00360.00480.00
Level 21.0013.0017.00
Level 22.402.5513.10
Level 22.552.8319.19
Level 210.3920.4535.90
Level 215.1337.2346.35
Level 28.1125.0625.06
WithdrawLevel 115.1015.1015.10
Level 215.1027.7527.75
Level 20.556.817.19
Level 20.686.657.19
SpainInjectionLevel 171.0071.0071.00
Level 271.0071.0078.39
WithdrawLevel 1142.00142.00142.00
Level 2142.00142.00142.00
Level 217.1719.2323.93
Level 224.7128.3529.48
United KingdomInjectionLevel
Level 219.8792.45127.71
Level 226.75130.50155.93

Table 2.6: TYNDP 2022 Hydrogen storage capacities in Hydrogen infrastructure level 1 and 2

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