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;

5. The consideration of the REPowerEU objectives reflected in the scenarios, even though not representing mandatory targets, and the projects eventually included in the TYNDP;
6. An open and transparent process for the collection of projects and detailed information and analysis of the projects’ implementation schedule by type of project;
7. Information related to projects included in the last edition of the TYNDP and triggered by the incremental capacity process;
8. The collection and publication of methane emission mitigation measures for methane infrastructure projects.

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.

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.

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.

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.

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.

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:

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

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 2.2.3.3 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.

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.

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.

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.