18 - europa · 2018-10-30 · ndps. the agency is ofthe view that such misalignments could be...

ACERAgency for the Cooperationof Energy Regulators

OPINION No 11/2018OF THE AGENCY FOR THE COOPERATION OF

ENERGY REGULATORS

of 18 October 2018

ON THE REVIEW OF NATIONAL NETWORK DEVELOPMENT PLANS TOASSESS THEIR CONSISTENCY WITH THE

EU TEN-YEAR NETWORK DEVELOPMENT PLAN

THE AGENCY FOR THE COOPERATION Of ENERGY REGULATORS,

Having regard to Regulation (EC) No 71 5/2009 ofthe European Parliament and ofthe Councilof 1 3 July 2009 on conditions for access to the natural gas transmission networks and repealingRegulation (EC) No 1775/2005’, and, in particular, Article 8(11) thereof,

Having regard to the favourable opinion of the Board of Regulators of 1 5 October 2018,delivered pursuant to Article 1 5( 1 ) of Regulation (EC) No 713/2009,

Whereas:

(1) Article 8(1 1) of Regulation (EC) No 715/2009 tasks the Agency with reviewing thenational network development plans (“NDPs”) to assess their consistency with the EUTen-Year Network Development Plan (“TYNDP”),

HAS ADOPTED THIS OPINION:

1 INTRODUCTION

Objective

This Opinion on the consistency of gas network development plans is adopted in line withArticle 8 of Regulation (EC) No 715/2009. The objective is to review the most recentlypublished NDPs and to analyse their consistency with the draft TYNDP published by theEuropean Network of Transmission System Operators for Gas (“ENTSOG”) in 201 8 (“drafiEU TYNDP 201 8)2, which, at the date of adoption of this Opinion, is under elaboration.

The review leads to recommendations for improving the consistency of future NDPs with theEU TYNDP, as well as to the identification of certain best practices applicable to the

1 OJL211, l4.8.2009,p. 36.2 See ENTSOG TYNDP 201 8 — Annex A — Project Table, 1 June 20 1 8, athttps://www.entsog.eu/publications/tyndp#ENTSOG-TEN-YEAR-NETWORK-DEVELOPMENT-PLAN2018


development of consistent NDPs and EU TYNDPs, which should be followed at Europeanlevel.

Data

The Opinion is based on information3 provided by national regulatory authorities (NRAs) viaresponses to on-line questionnaires. The Annexes to this Opinion contain detailed country-specific responses provided by NRAs on methodological aspects ofNDPs (Annexes I and II),as well as information regarding the consistency of the most recent NDPs with the drafi EUTYNDP 20 1 8 (Annex III).

27 out of29 NRAs4 provided information for the purpose ofreviewing methodological aspectsofNDPs. 23 NRAs provided information about gas infrastructure projects falling within theirregulatory domain. Out ofthese 23 responding NRAs, 10 NRAs had comments or remarks onprojects in the drafi EU TYNDP 2018, and 13 NRAs reviewed the projects, but had nocomments or remarks on them. In this Opinion, NRA comments on the consistency of theprojects are used in combination with information publicly available in the drafi EU TYNDP2018.

2 MAIN ISSUES AND CONSIDERATIONS

2.1 Methodological aspects of national and EU-wide network development plans

Stakeholder consultations

Stakeholder consultations are a vital part of the network development plans process, both atnational and EU-wide level. ENT$OG carries out a public stakeholder consultation during theelaboration of the drafi EU TYNDP. NDPs, while generally prepared with stakeholderinvolvement, differ regarding the degree to which stakeholders are proactively engaged andtheir feedback is considered. In particular, public consultation ofNDPs is usually held duringthe preparation stage and involves existing and potential network users, market participantsand other relevant stakeholders.

1 1 out of the 27 responding NRAs provided information regarding the timeframe of thestakeholder consultation in the context ofthe drafting ofthe NDPs. The Agency notes that thesubject, topic and scope of the stakeholder consultations carried out by ENTSOG for EUTYNDPs and by NRAs and/or transmission system operators (“TSO”) for NDPs may not befully aligned, as the TYNDP consultations involve mainly projects of EU concern, whileNDPs focus on projects from a national perspective. Similar considerations can be put forwardin the context of consulting NDPs and gas regional investment plans (“GRIPs”) as referred toin Article 12(1) ofRegulation (EU) 715/2009.

The Agency recalls that, according to Article 1 0(a) of Regulation (EU) 71 5/2009, the EUTYNDPs are required, in particular, to build on national investment plans, also taking intoaccount regional investment plans as referred to in Article 12(1) of the same Regulation. Forthese reasons, the Agency recommends that the entities responsible for the development and

3 The deadline to submit the information was 12th June 2018. For Italy, national inputs were updated withinformation as of September 2018.4 26 online questionnaires were received from the NRAs of AT, BE, BG, CY, CZ, DE, EE, ES, FR, GR, HR,HU, IE, IT, LT, LU, LV, MT, PL, PT, RO, SE, SI, 5K, UK-Great Britain, and UK-Northern Ireland. The DKNRA reported that currently there is no specific national development plan for gas, and that a pilot plan is beingprepared and is expected to be finished by the end of the year. Some information regarding FT and NL (as of20 1 6) can be found in the Agency’s Opinion No 14/20 1 6.

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the adoption of national and regional plans ensure that stakeholder consultations include,where appropriate, the cross-border aspects of other NDP plans, GRIPs and the projectsincluded in them, since such an approach to stakeholder consultations would help to build theEU TYNDPs on NDPs and GRIPs. Cross-border aspects of projects included in NDPs andGRIPs should also be consulted with stakeholders in order to avoid misalignments ofinformation provided for such projects in the various plans.

Publication ofthe plans

The EU TYNDP is published every other year and more than 80% ofthe NDPs are publishedat least every other year. With the exception of Spain and Sweden, all the reported NDPs havebeen published during the last 3 years.

The Agency recalls the importance of keeping the NDPs up to date. The Agency considersthat a biennial development, updating and publishing of the NDPs would enhance theconsistency ofthe NDPs and the EU TYNDP.

The Agency notes that in the independent transmission operators (“ITO”) and independentsystem operators (“ISO”) 6 models, TSOs are de lege lata obliged to submit their respectiveNDPs to the NRA every year, and changing the NDPs’ development frequency to biennialwould require a change in the European gas legislation (Articles 22(1) and 41(3)(c) ofDirective 2009/73/CE), a change already proposed in the analogous Electricity Directive.

Single and consolidated nationalplans

In 6 out of 7 Member States where multiple TSOs exist, NRAs reported that a consolidatedNDP is elaborated. At the time of the data submission, the status was essentially identical tothe one observed 2 years ago and described in the Agency’s Opinion No l4/20l6, i.e. 5consolidated plans were in place. In September 201 8, the Italian NRA introduced minimumrequirements for the Italian NDPs and the cost-benefit analysis (CBA) of the relatedtransmission investments8, requesting network operators to prepare a consolidated plan. TheAgency reiterates its view9 that the elaboration ofa consolidated NDP in Member States wheremore than one network operator exists would provide added value, subject to an assessmentof the need of devoting resources, coordinating schedules, collecting and exchanging data.

Cooperation on cross-border issues

The Agency notes that misalignments exist between NDPs regarding the foreseen cross-bordercapacities of some projects, as well as the timing oftheir construction, as indicated in differentNDPs. The Agency is of the view that such misalignments could be largely avoided with thehelp of enhanced consultations on draft NDPs with the TSOs of the neighbouring MemberStates, and via regular exchange ofinformation on those projects included in the NDPs whichare expected to have a cross-border impact. Project promoters should inform NRAs of theoutcomes of such consultations.

However, due to different schedules for the elaboration ofplans and other reasons, for examplechanges in market fundamentals, the NDPs and the EU TYNDP may temporarily be out of

5 Cf. Chapter IV ofDirective 2009/73/EC.6 Ibid, see Article 41(3)(c).7https://www.acer.europa.eu/Official documents/Acts of the Agency/Opinions/Opinions/ACER%200pinion%20 14-20 1 6.pdf8 ARERA, Regulatory Order 468/20 1 8/R/gas of 27 September 20 1 8. https://.arera.iit/docs/1 8/468- 1 8.htm9 See Agency’s Opinion No 14/2016, page 3.


alignment, even if excellent coordination and regular exchanges of information take place.The Agency acknowledges that achieving full alignment of all the infrastructure developmentplans in the EU, while desirable in principle, may be associated with high cost and excessiveadministrative burden, and that therefore such alignment should be pursued to the extent thatit is efficient.

Regulatory environment and oversight

The Agency notes that the level ofregulatory oversight is generally higher for NDPs than forthe EU TYNDP. This is mainly due to the existence ofpublic authorities with decision-makingregulatory powers on NDPs, while the current EU legal framework does not provide for asimilar regulatory framework for the EU TYNDP. In about 40% of the instances, NRAs areformally empowered, albeit in differing ways, to approve, reject or validate the NDP proposalsof the T$Os, and in some cases the NRAs also carry out a consultation process on the draftNDP. On the other hand, the regulatory supervision of the EU TYNDP is mainly carried outin the form of a non-binding opinion of the Agency on the draft EU TYNDP . The Agency isof the view that the regulatory oversight over the elaboration of the EU TYNDP should bestrengthened, even if this would imply legislative changes.

In several Member States, NRAs play only a limited consultative role in the process of NDPelaboration and have no effective powers to review or validate the NDPs. The Agencyrecommends that the regulatory oversight by NRAs and their role in the NDP elaboration bestrengthened in the Member States where, so far, this oversight has been limited. The Agencynotes that several unbundling models exist for TSOs across the EU, and the choice of aparticular unbundling model influences the NDP process. The Agency finds that the choice ofthe unbundling models has not changed during the last 2 years. Irrespective ofthe unbundlingmodel chosen in each Member State, the Agency is of the view that NRAs oversight anddecision-making powers over cross-border projects and projects with cross-border impactshould be strengthen, given that NRAs play an important role regarding investment requestsfor projects of common interest (“PCIs”) under Regulation (EU) No 347/2013.

The Agency acknowledges the different legal nature of NDPs across the EU. In almost 40%ofthe instances, the NDP has a legally binding nature, in particular regarding projects expectedto be commissioned in the short term (between 3 and 5 years).

Identification ofinvestment gaps, categorisation and assessment ofprojects

In most NDPs, the identification ofinvestment gaps and the assessment ofthe degree to whichspecific projects address them is typically based on a combination of approaches.

The Agency reaffirms its support to applying a combination of approaches for the purpose ofidentifying infrastructure gaps and assessing projects10. In particular, the Agency recommendscomplementing the generic discussion on infrastructure needs (top-down approach) with acase-specific analysis of individual projects and economic tests revealing the market interestin the projects (bottom-up approach, market test). The Agency notes that the EU TYNDPshould be further improved to allow for the identification of the investment gaps associatedwith clearly ascertained capacity bottlenecks and other system needs, based on an assessmentofthe degree to which each specific project addressed the identified investment gaps.

10 The Agency notes that the so-called “incremental proposal” amending the CAM NC under CommissionRegulation (EU) 2017/459 of 16 March 2017, establishing a network code on capacity allocation mechanismsin gas transmission systems and repealing Regulation (EU) No 984/2013 may affect the NDP processes

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of Energy Regulators

The Agency welcomes the use of project-specific criteria, such as maturity, for categoñsingprojects listed in the drafi EU TYNDP 2018, and invites the TSOs developing and theauthorities monitoring the NDPs to consider the use of such criteria for cross-border projectsand projects with cross-border impact which are included in both the EU TYNDP and NDPs.

Security ofgas supply

The Agency finds that most NDPs do not include an evaluation of the level to which securityof gas supply is achieved. The Agency identifies security of gas supply as a potential area ofimprovement ofthe consistency ofNDPs and the EU TYNDP. The Agency notes that securityof gas supply is a national, regional and European issue. At European level, the Agencyrecommends that ENTSOG and TSOs endeavour to improve the economic evaluation ofsecurity of supply in the EU TYNDP in the context of the CBA methodology and itsapplication, by carrying out studies or taking into account available studies or studies whichmay become available.

Technical aspects: modelling tools, network topology

The modelling tools and the network topology used for the elaboration ofthe EU TYNDP aregenerally less robust than the more accurate and detailed topology and better modelling andsimulation tools typically used for the preparation ofNDPs. Consequently, the assessment andthe identification of physical capacity bottlenecks, as well as the simulation of gasinfrastructure operational conditions, are generally more robust in the NDPs than in the EUTYNDP. The Agency invites ENTSOG to consider improving the modelling performed forthe purpose of the EU TYNDP, by further building on the expertise and the best practices,models and tools used by the TSOs for developing NDPs.

2.2 Consistency of projects in NDPs and the draft EU TYNDP 2018

Consistency ofproject inclusion, criteriafor cross-border significance

There are 7 projects with cross-border impact included in NDPs, but not listed in the draft EUTYNDP 201 8 ‘ 6 of which are located in Germany. However, the Agency notes that theunderstanding of the concept of “cross-border impact” may differ in the context of the variousNDPs, especially regarding the scale or magnitude of the impact that would qualify it as“significant”. Such differences could, to some extent, explain the number of projectsconsidered to have a cross-border impact in Germany’s NDP, but are absent in the TYNDP.The Agency considers that the criteria for considering the cross-border impact of a project as“significant” should be discussed and better aligned across NDPs and between NDPs and theEU TYNDP’2. ENTSOG, project promoters, NRAs and the Agency should participate in sucha discussion.

1 1 Reported by the NRAs of Slovenia (1 project) and Germany (6 projects). Reasons of such nonalignment betweenplans could be of objective character: projects may already be completed and therefore no longer be a part of amore recent plan, but still be a part of a document that was published earlier, or may no longer be deemednecessary and therefore no longer be a part of the more recent document.12 For example, Annex IV (1) of Regulation (EU) No 347/201 3 establishes that, for gas transmission, a projectwith significant cross-border impact is a project on the territory of a Member State which concerns investmentin reverse flow capacities or changes the capability to transmit gas across the borders of the Member Statesconcerned by at least 10 % compared to the situation prior to the commissioning of the project. In the context ofinvestment request and CBCA procedures, the Agency in its Recommendation No 5/20 1 5 issued criteria to definea “significance threshold” for the net positive impact of a project.

ACERm Agency for the Cooperation


The Agency notes that 156 out of the 207 projects in the draft EU TYNDP 201 8 (75%) arelisted in NDPs, a coverage in line with that of the EU TYNDP 201 713• Considering onlyTYNDP projects located in EU Member States, this percentage is slightly higher (78%, 147out of 1 89 projects). In 1 1 countries, there is full (1 00%) consistency: all projects included inthe draft EU TYNDP 201 8 are also present in the NDPs of these countries.

The Agency is ofthe view that more attention is needed in the development ofthe EU TYNDPto the inclusion of all projects listed in NDPs that may have a significant cross-border impact,thus improving the basing ofthe EU TYNDP on NDPs.

Consistency ofproject data

23 NRAs provided comments for 3 1 ‘ out of207 projects listed in the draft EU TYNDP 2018.

Reported non-aligned data between the draft EU TYNDP 201 8 and the NDPs for projectslisted in both plans are of diverse nature, but mostly concern technical and factualdiscrepancies, such as, for example, projects present in NDPs but erroneously cross-listed inthe EU TYNDP, differences in the reported timing of cross-border cost allocation (CBCA)decisions, the assignment of infrastructure items to particular projects, the technicaldescription of projects (or lack thereof), the project promoter’s name, the milestones of theproject schedules, and the maturity status ofthe projects.

The Agency is of the view that the potential consequences of such apparent discrepancies ormisalignment of data at project level varies in importance. For example, some types ofmisalignment, such as differences in the project schedule and technical parameters, may be,to a large extent, explained by the natural evolution of a project between the moments when itwas listed in the EU TYNDP and in the respective NDP, and may not necessarily be ofimmediate concern. The Agency calls on project promoters to ensure that coherent and reliableinformation for different plans is provided to NRAs, ENTSOG and the Agency, and regularlyupdated.

Reasonsfor project data rnisalignments

Several factors may explain the reasons for the differences in the descriptions ofthose projectswhich are present in both the EU TYNDP and in NDPs. First, the timing of the release of themost recent NDPs varies between countries, ranging from 2008 to 201 8. Second, promoterscan apply directly for inclusion in the EU TYNDP, even without having their projects includedin the most recent edition of the NDP, in those instances where a NDP exists.

EU TYNDP to be based on NDP projects

The Agency stresses that Regulation (EC) 71 5/2009, which sets the basic principles andrequirements for the development of EU TYNDPs, requires that the TYNDPs be based, inparticular, on NDPs and, where appropriate, on EU aspects of network planning. From thisperspective, ENTSOG should strive to bring the number ofprojects listed in the EU TYNDP,but not listed in NDPs, to a reasonably low level. The Agency sees the listings in the EU

13 See Acer Opinion No 6/2017 on ENTSOG’s draft TYNDP 2017, Section 3.10, Consistency ofNDP ITYNUP, p. 18, at:https://www.acer.europa.eu/Official_docurnents/Acts_oLthe Agency/Opinions/Opinions/ACER%200pinion%2006-20 1 7.pdf14 One comment related to several LNG terminals.

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TYNDP of projects not belonging to any NDP as possibly originating from the followingreasons:

. the existence of Member States in which there is no obligation to adopt a NDP15, butwhich do have interest in the development of cross-border gas infrastructure;

. the fact that some projects are located outside the EU and consequently cannot becomepart of any NDP within the EU;

. the submission ofa project for the EU TYNDP afier the adoption ofthe relevant NDP;

. the existence of outdated NDPs;

. the submission of a project for the EU TYNDP addressing an investment gap orcapacity bottleneck at EU level, which is not relevant at national level, leading to theproject not being listed in the NDPs.

In the view of the Agency, projects which are not present in a NDP could be included in theEU TYNDP only on the basis of a case-by-case assessment, after having heard the involvedNRAs, and afier providing solid justifications oftheir need — i.e., evidence on how the projectwould help to close an infrastructure gap present at EU level, but not already addressed in aNDP.

The Agency finds that ENT$OG provides transparency in the drafi EU TYNDP 2018regarding the inclusion (or not) ofEU TYNDP projects in NDPs. At the same time, the Agencynotes the importance of further strengthening the consistency of NDPs and the EU TYNDP,in pursuit of not only the fulfilment of a regulatory requirement, but also of increasing thecredibility of the EU-wide gas network planning. In view of this aim, the Agency calls onENTSOG to consider clarifying the reasons for non-NDP projects being proposed in the EUTYNDP. Such clarifications should be included in the EU TYNDP itself.

The Agency advises proj ect promoters to apply for the inclusion of the proj ect in the relevantNDP(s), before applying in the EU TYNDP process, or, should no NDP exist or ifthe projectis located outside the EU, ensure that the relevant authorities in the hosting and thesignificantly impacted countries review the project before an application is filed for inclusionof the project in the EU TYNDP. In all instances, the NRAs of all significantly impacted EUMember States should have an opportunity to review such applications before their submissionfor the EU TYNDP.

The Agency reiterates its recommendation that, in principle, projects not having obtained exante regulatory review in the context of the NDPs or in another way, should not be includedin the EU TYNDP. The Agency considers that in cases when, by way of a due justification,non-NDP projects are included in the EU TYNDP, such projects should be listed separatelyin the EU TYNDP and their listing accompanied by thejustification ofthe need(s) they addressand ofthe projects’ merits.

NRA views on draft EU TYNDF 2012 projects

The Agency notes that, in 201 8, ENTSOG invited for the first time NRAs to provide views onEU TYNDP candidate projects and data items, and that the invitation was sent out early in thedevelopment process for the TYNDP 2018. The Agency welcomes this practice, which is

15 Countries holding a derogation under Article 49 ofthe Directive 73/CE/2009 (Cyprus, Latvia, Luxemburgand Malta) do not have an obligation to develop national development plans.

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ACER— Agency for the Cooperation


likely to improve data quality and the consistency ofprojects included in the EU TYNDP andNDPs. The Agency recommends ENT$OG to continue the practice in the development offuture EU TYNDPs.

3 MAIN CONCLUSIONS

For the purpose of this Opinion, the Agency reviewed the most recent editions of the NDPsand assessed their consistency with the draft EU TYNDP 2018. This comprehensive reviewaddressed the consistency ofthe listings ofthe projects in the plans and various aspects relatedto the methodology used for the elaboration of the NDPs and the EU TYNDP. The Agencynotes that only minor changes have occurred in the NDP development processes since a similarreview was carried out 2 years ago.

The Agency positively notes the improvement of the transparency of the EU TYNDPregarding cross-references to the NDP investment item (project) codes. The Agency welcomesthe progress, although limited, achieved since the last review of NDPs in improving theconsistency ofthe NDPs and the EU TYNDP.

The Agency welcomes the collaborative attitude ofENTSOG in allowing NRAs to share theirviews regarding projects and various project data shortly after the submission of candidateprojects for the draft EU TYNDP 201 8. The Agency commends the NRAs for proactivelyengaging in project data verification. The Agency specifically notes that data verification led,in some instances, to data reconciliation between the NDPs and the draft EU TYNDP 2018,thus providing more realistic and consistent data for the projects in the EU TYNDP. TheAgency acknowledges this pragmatic arrangement leading to improvements in the consistencyof projects in the EU TYNDP and NDPs, and recommends its continuation in future EUTYNDPs.

With the aim of further improving the consistency of future EU TYNDPs and NDPs, theAgency specifically recommends that further work is undertaken to address the followingissues in the context of the NDPs:

Modality andfrequency ofnetworkplans publication

. a NDP should be prepared and published in each Member State every 2 years, inpursuit of enhanced consistency of the NDPs and the EU TYNDP, the latter alreadybeing elaborated biennially; and

. a consolidated NDP for gas transportation should be considered for every MemberState where more than one TSO exists. The benefits ofdeveloping a consolidated NDP,including all types of gas infrastructure projects and providing an holistic integratedview of the need of network developments, should be measured against the additionalcoordination efforts required.

Engaging stakeholders, improving consultations and regulatory supervision

. NDPs should carefully reflect the views of market players who use the gasinfrastructure (shippers), together with the views ofother stakeholders, about the needsfor new infrastructure, during the entire NDP elaboration process;

. adequate consultations of the draft NDPs and due coordination of operators shouldtake place during the preparation of the NDPs regarding the development of cross-

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border capacities and other projects with significant cross-border impact, and theentities responsible for NDPs should apply clear criteria for the identification ofpotentially significant cross-border impacts; and

. regulatory oversight over the NDPs should be strengthened in the Member Stateswhere so far this oversight has been limited.

Improving NDF methodologies and the transparency ofinformation

. Due attention should be given to the consistent identification of the needs for gasinfrastructure capacity in the NDPs, in particular for cross-border projects, and themapping ofthe proposed infrastructure against the identified needs;

. consistent criteria, such as project maturity, should be applied for the purpose ofassessing projects in the NDPs, to help the comparability of projects in EU-wide andnational plans;

. cross-references should be included in the NDPs between the NDP investment item(project) codes and the EU TYNDP codes, in the same way it is currently done in theEU TYNDP; and

. project cost data should be included in the NDPs, at least at an aggregated level.

The Agency notes that most of the above recommendations were already included in theAgency’s review ofNDPs and their consistency with the EU TYNDP carried out in 2016. TheAgency notes that, even though NRAs expressed an overall high level of support for furtherimplementing most of these recommendations, the progress observed in implementing theserecommendations since 2016 has been modest.

The Agency formulates the following recommendations to ENTSOG and project promoters,in pursuit of improving the consistency of future EU TYNDPs and NDPs:

Engaging stakeholders, improving consultations and regulatory supervision

. to continue the good practice ofgetting NRAs’ views on projects and project data itemsearly in the TYNDP process, in order to improve data quality and the credibility of theEU TYNDP. The Agency encourages ENTSOG to take into utmost consideration theviews of NRAs on the gas system development needs and on the extent to which thevarious EU TYNDP candidate projects address these needs.

Improving EU TYNDP methodologies and transparency ofinformation’6

. To improve the process ofidentification ofinfrastructure needs in the EU TYNDP andits consistency with the identification of needs in NDPs, in particular by better takinginto account any current and expected level of capacity congestion and gas flows incross-border infrastructures which are already addressed in NDPs;

. to continue improving ENTSOG’s network model, as well as the network and marketmodelling tools used for developing the EU TYNDPs, by further building on theexpertise and the best practices, models and tools used by TSOs for developing NDPs;and

16 See also the Agency’s Opinion No 6/2017 on the ENTSOG’s draft TYNDP 2017.

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. to include project costs and monetised benefits data in the EU TYNDPs, ensuring thatthe confidentiality claims of promoters are not detrimental to an adequate level of costtransparency.

Securing that the EU TYNDP is based on NDPs

. Project promoters should generally apply first for a project’s inclusion in the NDPbefore applying to the EU TYNDP process. The Agency encourages all projectpromoters to seek first regulatory review in the context of the NDPs;

. in instances where it is impossible to apply for inclusion in a NDP, such as in theabsence of a NDP, project being located outside the EU, or mismatch between themoment when the NDP is adopted and the moment when the window for applying forthe EU TYNDP becomes available, project promoters should first consult the projectwith all concerned NRAs before applying for the EU TYNDP;

. ENTSOG should be cautious and apply strict procedures in order to avoid the inclusionof unrealistic non-NDP projects in the EU TYNDP, for which the criteria set out inENT$OG’s practical implementation document used for the EU TYNDP could beconsidered; and

. non-NDP projects should be listed separately in the EU TYNDP and be accompaniedby a solid justification of the needs which they intend to address, but are not coveredby projects already present in the NDPs.

DoneatLjubljanaon 18 October2018.

fort1zAgencyDirec%r ad interim

Alberto PtTOT$CHNIG

Enclosures (Annexes I-HI):

ANNEXI.• National Development Plans. MethodologicalAspects (Analytical Part)

ANNEXH. NDP Questionnaires: Data Annexes

ANNEXHL Consistency ofNDP / TYNDP Projects

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ANNEXES

LIST OF TABLESTable 1 : Unbundling model of the gas TSO(s) 13Table 2: NDP development process 14Table 3: Frequency ofpublication ofNDPs 15Table 4: Time horizon ofNDPs 15Table 5 : Legal nature of NDPs 16Table 6: Number ofNDPs 16Table 7: Most recent NDP publication 17Table 8: Date ofpublishing ofthe most recent NDPs vs. EU TYNDPs 18Table 9 : Estimated NDP target cross-border capacities 19Table 10: Consistency ofcross-border capacity in the NDPs ofneighbouring Member States

19Table 1 1 : Market studies in NDPs 21Table 12: Network studies in NDPs 21Table 1 3 : Inclusion and use of costs in NDPs 22Table 14: Use of cost-benefit analysis in NDPs 23Table 1 5 : Economic evaluation of security of supply in NDPs 23Table 16: TSO unbundling model, country-specific replies by NRAs 28Table 17: Development ofNDPs (comments ofNRAs selecting “Other Options”) 30Table 1 8 : Legal nature of NDPs (comments of NRAs selecting “Other options”) 31Table 19: TSO and NRA responsibilities in defining NDPs 32Table 20: Most recent NDP: links to web sites where the NDP is published 40Table 2 1 : Project classification in NDPs according to maturity and/or urgency criteria 43Table 22 : NDP development process: main steps timeline 45Table 23 : Determination of investment gaps in NDPs 47Table 24: NDP analytical methodology 48Table 25: Draft EU TYNDP 2018 projects present in NDPs, by type of assets 53Table 26: Draft EU TYNDP 201 8 projects present in NDPs, by EU-28 countries 53Table 27: NDP projects with cross-border impact which are not listed in the draft EUTYNDP2O18 55Table 28: NRA comments on draft TYNDP 201 8 projects 56

LIST OF FIGURESfigure 1 : Unbundling model ofthe gas TSO(s) by Member State 25Figure 2: NDP by year ofpublishing 26Figure 3 : NDP legal nature 26Figure 4: Number ofNDPs by Member State 27Figure 5: Inclusion ofcost and benefits in NDPs 27Figure 6: Use of cost-benefit analysis and monetization 28Figure 7: Most recent NDPs by year ofpublication 39Figure 8: NDP projects listed in the draft EU TYNDP 201 8 (EU-28, percent) 54Figure 9: Projects listed in NDP(s) but not listed in the draft EU TYNDP 2018 54

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COUNTRY CODES

Member State Country code

Austria AT

Belgium BE

Bulgaria BG

Croatia HR

Cyprus CY

Czech Republic CZ

Denmark DK

Estonia EE

Finland FT

France FR

Germany DE

Greece GR

Hungary HU

freland IE

Italy IT

Latvia LV

Lithuania LT

Luxembourg LU

Malta MT

Netherlands NL

Poland PL

Portugal PT

Romania RO

Slovak Republic SK

$lovenia ST

Spain ES

Sweden SE

United Kingdom-Northern Ireland UK-N. Ireland

United Kingdom-Great Britain UK-GB

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— Agency for the Cooperationof Energy Regulators

ANNEX I: National Development Plans: Methodological Aspects

1. Regulatory aspectsThe NRAs provided information on key regulatory aspects governing the NDPs, such as theunbundling model chosen for gas TSOs, the specific provisions regarding NDPs forIndependent Transmission System Operators (“ITOs”), and the alignment of the nationalframework with the provisions of Article 22 of the Directive 2009/73/EC’7. The NRAsdescribed the roles and responsibilities of the TSOs and of the NRAs in defining the NDPsunder the applicable national legislation. The Agency examined the NRA information onunbundling models in more detail, focusing on the different legal requirements in theunbundling models regarding the safeguards for the implementation ofprojects in the case ofan ITO model.

1.1 Unbundling model

Table 1 shows that Full Ownership Unbundling (“OU”) is the predominant unbundling modelfor gas TSOs (38% ofthe Member States), followed by ITO (23% ofthe Member States).

Table 1 : Unbundling model of the gas TSO(s)

NRAUnbundling model % NRAsresponsesBE; EE; IE; LV; LT; PL; PT; SE; UK-N.Full Ownership Unbundling (OU) 10 38%Ireland; UK-GB

Independent Transmission Operator6 23% AT; BG; CZ; GR; 5K; SI(ITO)

Other circumstances 4 15% CY; HR; LU; MTSeveral models (in case of several

5 19% DE; ES; FR; HU; ITTSOs operating in the Member State)Independent System Operator (ISO) 1 4% ROTotal 26 100%

Note: Malta and Cyprus were not included in the review carried out in 2016. In this year ‘s review, the NRAs ofMalta and Cyprus submitted responses to the questionnaires. Their responses are included in Table 1, althoughthese NRAs were not always in a position to provide the required answers, and marked “other options / n. a.”when responding. Cyprus currently has no gas or infrastructure, but there are planned infrastructure projectsaimed to bring gas to the cotintiy or deliver it to other countries. Malta switched its prirnaty source of energyfrom heavyfuel oil to natural gas in 201 7, and gas accounted that yearfor approximately 70% ofthe energyconsumption in the count;y. Natural gas to Malta is delivered as LNG and used for power generation in acombined cycle gas turbine (CCGT) plant.

The Agency notes the existence of different unbundling models across the EU Member Statesand the dominance of the OU and ITO models. The Agency notes that the variety of theapplicable unbundling models affects the specific features of the NDPs. for example, NDPsfor ITOs should be developed in line with Article 22 of Directive 2009/73/CE, a requirementwhich is not present for OU entities. In Germany, France, Hungary, Italy and Spain severalunbundling models for gas TSOs exist simultaneously. Overall, no changes were observedduring last 2 years regarding the chosen unbundling model.

1.2 Specific provisions regarding NDPsfor ITOs

The NRAs provided information on the specific provisions contained in the nationallegislation regarding NDPs for ITOs and on actions taken by NRAs according to Article 22(7)

‘7OJL211, 14.8.2O19,p. 114.

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Agency for the Cooperationof Energy Regulators

of Directive 2009/73/EC. In one case, in Austria, a T$O did not execute an investment during

the 3 years after the investment was foreseen in the NDP, for reasons other than overriding

reasons’8. No other actions have been reported by NRAs according to Article 22(7) of

Directive 2009/73/EC to ensure that an investment is made.

The Agency notes that in cases where the ITO model is applied, no specific regulatory actions

have been taken to ensure that investments are made, given that the TSOs, under normal

conditions, execute the investments foreseen in the NDPs after obtaining the pertinent

regulatory approval. No changes in these practices occurred during the last 2 years.

2. Key features of the NDPs

2.1 NDPprocess,ftequency and modality ofpublication, time horizon

NDP developmentprocess

In about 40% of the cases, the NRAs are formally empowered to approve the NDPs’9, with

23% of the NRAs having the possibility to either approve or reject the proposed plan as

submitted by TSOs, while 19% ofthe NRAs have the power to amend the NDP as well. 46%

of the NRAs reported the existence of “other” specific processes for the elaboration and

adoption ofthe NDPs.

Table 2 provides an overview of the NDP development process per Member State. Table 17

in Annex II contains comments from NRAs reporting on the existence of various NDP

development modalities.

Table 2: NDP development process

NRANEW development process % NRAsresponsesProposal developed by TSOs, approvedby Ministries. NRAs are consulted on 2 8% ES20; PTthe proposal ofthe TSOsProposal developed by TSOs, approvedby NRAs. NRAs can amend the TSOs’ 5 19% DE; FR; GR; IE; LIproposalProposal developed by TSOs, approvedby NRAs. NRAs can only approve I 7 27% AT; BG; HR; HU; PL; RO; SIreject the proposal (but not amend it)

. BE CY CZ; EE; IT LV; LU; MTOther options 12 46%SE; UK-N. Ireland; UK-GB

Total 26 100%

18 In the case of the Bidirectional Austrian-Czech Interconnector (BACI) investment project, notwithstandingthat, according to ECA, there was positive market demand assessment and the willingness to invest ofboth TSOsinvolved, the capacity of the project was not offered in the auction in July 2018. ECA takes the view that thedifferent views of the NRAs in Austria and Czech Republic on supporting the project, in the sense of includingit in the respective NDPs, is related to the non-offering of capacity in July 201 8. ERU has a different view,arguing that according to the Network Code (NC) on Capacity Allocation Mechanism (CAM), there is norelationship between not offered capacity of the project in the July auction and the divergent positions of NRAson the project, because the process falls under the responsibility of TSOs. ERU states that it does not object tothe development of the project, as long as the project promoters implement it at their own risk as a purelycommercial project.19 The EU legislation does not require NRAs competencies to approve NDPs in cases where the OU model isapplied, but some national legislations do assign such competencies to the respective NRAs.20 The Opinion of Spanish NRA on the draft NDP is not binding for the Ministry.

14\f 63


frequency and modality ofpublication

As shown in Table 3, NDPs are published annually in 62% of the cases and every two yearsin 19% ofthe cases. “Other” situations are reported in 19% ofthe cases.

Table 3: Frequency of publication of NDPs

Frequency of ND? NRA. . /0 NRAspublication responses

AT; BE BG CZ EE FR GR HU IF IT; LV ET SIAnnual 1 6 62%5K UK-N. Ireland; UK-GB

Biennial 5 19% DE;LU;PL;PT;ROOther 5 19% CY;ES;HR;MT;SE

As regards the sectoral coverage of the publication, 24 NDPs (92%) are gas-specific, whiletwo (Malta and Spain21) are cross-sectoral, covering electricity, oil, and gas networks.

Time horizon

As shown in Table 4, the time horizon ofthe majority ofNDPs (85%) is 10 years.

Table 4: Time horizon of NDPs

Time horizon of the NRA%NDP responses

AT; BE; BG; CZ; DE; EE; ES; FR; GR; HR; HU; IE;IT;10 years 22 85%LU; LT; PL; PT; RO; SI; 5K; UK-GB; UK- N. Ireland

Other time horizon 4 15% CY; LV; MT; SETotal 26 100%

The information provided by NRAs regarding the schedule of NDP development and timehorizon reveals an overall picture which is very similar to the one observed 2 years ago.

2.2 Legal nature and number ofNDPsper Member State

Table 5 shows that in 1 0 cases (3 8%) the implementation of projects included in the NDPs ismandatory in the short term (i.e., if the projects are expected to be commissioned during theupcoming 3 years, they must be implemented) and indicative in the longer term. In 8 MemberStates (3 1 %) all projects included in NDPs are indicative. In one case (Slovakia), the NRAreported that projects qualify as being indicative or mandatory depending on their urgency,and only in 1 case (Germany) the NRAs reported that all projects in the NDPs are mandatory.

21 In the case of Spain, only electricity and gas networks.

15o3

The Agency notes that most ofthe NRAs reporting the existence of”other” NDP developmentmodality have only a limited consultative role and very limited powers - or no powers at all -

for reviewing and validating the investments foreseen in the NDPs. This is especially the casewhere OU TSOs are involved, since the EU legal framework does not require such T$Os todevelop a NDP.

Information provided by NRAs indicated that changes in the modality of reviewing orapproving NDPs did take place in a few countries. However, these changes were minor andoverall the modalities for the development of the NDPs remained essentially the same asreported in 2016.

Total 26 100%

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Comments provided by NRAs regarding other legal NDP modalities are available in Annex

II, Table 18.

Table 5: Legal nature of NDPs

Legal nature of NDPs % NRAsresponses. . BE EE IT LV LU PL; RUIndicative, for all projects 8 3 1%

GBMandatory in the short term (projects to becommissioned in 3 years must be

38°/AT; BG; CZ; FR; GR; HU; IE;

implemented) and indicative in the long °LT; PT; SI

termMandatory, for all projects 1 4% DEIndicative and mandatory depending on the

4% 5Kurgency of the projectscy. ES HR MT22 SE UK-N.Other 6 23%Ireland

Total 26 100%

The Agency acknowledges that various NDP development and implementation processes arepossible under national legislations.

The Agency notes that the co-existence ofmandatory and indicative projects in the NDPs, aswell as ofNDPs with a different legal nature, are circumstances which do not necessarily leadto inconsistencies in the implementation ofinvestments in EU’s gas infrastructure. However,the Agency strongly recommends NRAs and project promoters and other stakeholdersinvolved in the NDP process to give cross-border projects, whenever possible, the same status(mandatory or not) in the NDPs of all the concerned Member States.

The overall pattern of the legal nature of NDPs has not significantly changed since the lastreview performed by the Agency in 2016, although in a few countries the legal modality didundergo changes.

Table 6 shows that in more than half of the analysed countries (54%) there is a single TSOand a single NDP. In Member States with two or more TSOs, varying numbers of NDPs arepossible (a single consolidated plan at national level or more than one plan at TSO level, oneper TSO). In almost % ofthe Member States (73%), there is one national-level NDP.

Table 6: Number of NDPs

NRA% NRAsNDP adoption modality

responses

BE; BU; CZ; EE; HR: IF; LT; LV;LU; PE;One TSO, one NDP 14 54%PT; 5K; SI; UK-GB

Several TSOs, one consolidated5 19% AT; DE; ES; HU; UK - N. IrelandNDP

Several TSOs, several NDPs (one2 8% FR; IT (up to 2017)per TSO)

Other options 5 19% CY; GR; MT; RO; SETotal

_________________

26 100%Note: In September 2018, the Italian NRA introduced the additional requirement for a consolidated plan.

22 Malta indicated this question is not applicable.

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The Agency continues seeing potential merits in having a consolidated NDP in countries withseveral operators, given that such consolidation may improve the regulatory oversight andprovide a comprehensive, consistent infrastructure development plan in a single document.

2.3 Most recent NDPs: publication, timeline

Table 7 shows the most recent year ofNDP publication. 92% ofthe NDPs have been publishedduring the last 2 years, with the notable exceptions of$pain and Sweden where the NDPs date10 years ago.

Table 7: Most recent NDP publication

Most recent NDP NRA. . % NRAspublication (year) responses

2008 2 8% ES; SE

2016 4 15% DE;GR;HU;LU

2017 AT; CZ; FR; HR; IE; IT; LT; LV; PL; PT; RO; 5K;14 54% UK - N. Ireland; UK - GB

2018 6 23% BE; BG; CY; EE; MT; SI

Total 26 100%

The Agency recalls the importance of keeping the NDPs up-to-date and encourages theelaboration and the publication ofupdated versions ofNDPs which are older than 2 years. Inthis respect, to facilitate a proper reconciliation of data, and procedures between TSOs andNRAs of different Member States, as well as participation in consultations, translating theNDPs in the languages of Member States which may be impacted by projects listed in theNDPs, or into English, may be considered.

2.4 Use ofmaturity and urgency criteria in NDPs

Out of 27 responding NRAs, 7 NRAs indicated that the NDPs use only maturity criteria toclassify investments. In 2 other instances, only urgency is used, while in 4 cases both maturityand urgency criteria are used to categorise infrastructure projects in the NDPs (see Table 21in Annex II for details). More than 50% ofthe NDPs do not use specific investment maturityor urgency criteria.

2.5 Comparison ofthe NDPs and the EU TYNDPs

Time olpublication

The different precise timing (date) of publication is potentially a source of misalignmentsbetween investment items appearing in NDPs and the EU TYNDP. Such misalignments donot necessarily lead to inconsistencies between the plans, as differences between the sameprojects as they appear in NDPs and the EU TYNDP may be due to the natural evolution ofthe projects and their market environment during the period in-between the moments of theplans’ publication.

17


Table 8: Date of publishing of the most recent NDPs vs. EU TYNDPs

Year 200$ 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018

Number ofNUPspublished 2 4 14 6(most recentonly)

x (expectedEU TYNDPs x x x x x x by end of

2018)

Legal nature and integration ofinvestments in networkplans

The Agency notes that, irrespective to the general legal nature ofthe NDPs, pursuant to Article3(6) of Regulation (EU) 347/2013 projects of common interest (PCIs) should be included inNDPs, and that the PCIs should be conferred the highest possible priority within the NDPs23.The Agency notes that the obligation to include competing and potentially competing projectsin NDPs (especially in those NDPs which are not just indicative but legally enforceable) andto confer the highest national priority on these projects is challenging to implement, sincenaturally not all the competing PCIs will be built. For this reason, the Agency stronglyrecommends ENTSOG to make sure that all projects proposed for inclusion in the TYNDPare reviewed in depth by NRAs, and that the views of the NRAs are duly reflected whendesigning the TYNDP. Such a procedural arrangement will reduce the chances ofprojects notreviewed by NRAs getting on the TYNDP and obtaining eligibility for PCI status as well, thusalso alleviating potential inconsistencies between the NDPs, the TYNDP and the projectsproposed for the PCI lists.

The time horizon of infrastructure planning (10 years) is generally aligned in the NDPs andthe EU TYNDP.

Use ofmaturitv / urgency criteria

Since the 2017 edition of the TYNDP, ENTSOG classifies projects according to their“maturity” or “advancement” status into three categories: projects with FID taken (“FIDprojects”), “advanced non-FID projects”24, and “less advanced non-FID projects”.

NDPs use criteria to categorise projects. In some cases, urgency and/or maturity criteria areused, while in other instances, other criteria are applied. In almost half of the NDPs, maturitycriteria are used to classify projects, along with other criteria.

23 Cf. the Agency’s 2016 Consolidated Report on Projects of Common Interest, p. 94. In assigning priority, thefact may be considered that the PCI list contains competing and potentially competing, as well as generic projects,whose implementation remains rather uncertain. Cf.http://www.acer.europa.eu/Official_documents/Acts_of the Agency/Pub11cati0nJCONSOLIDATED°/b2OREPORT%200N%2OTHE%2OPROGRESS%200F%2OELECTRTCITY%2OAND%2OGAS%2OPROJECTS%200f%2OCOMMON%2OINTEREST%2Ofor%2Othe%2Oyear%202015.pdf

24 In the EU TYNDP, “advanced non-FID projects” refers to projects with front-end engineering and design(FEED) started, or grants for FEED awarded, or permitting started in all hosting countries, and with acommissioning date within 7 years.

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The Agency welcomes the use of criteria such as maturity and/or urgency to categoñseprojects listed in the TYNDPs and invites the T$Os developing and the authorities monitoringNDPs to consider the use of such criteria for cross-border projects and projects with cross-border impact included in both the EU TYNDP and NDPs.

3. Outputs ofNDPs and the EU TYNDP

The NRAs provided information about the main features of the NDPs, such as highlightingthe estimated target cross-border capacities, the identification of investment gaps, theavailability ofproject cost information, and the use of cost-benefit analysis and its results.

3.1 Estimated target capacities

The “target cross-border capacity” is the onethat helps to achieve in a cost efficient way oneor more of the following: an adequate level of capacity to cover peak gas demand, marketintegration, competition and security ofsupply. The Agency is ofthe view that the target cross-border capacity is one of the key parameters which should be considered for elaborating gasnetwork development plans, and has repeatedly called on ENTSOG to develop and apply sucha concept in the TYNDP.

As shown in Table 9, 54% of the NRAs indicate that NDPs include target cross-bordercapacity estimates. However, it is not always clear whether NRAs meant the concept of “targetcross-border capacity” as described above, i.e. as an efficient capacity goal supported by CBAor modelling simulations, or simply had in mind the incremental capacities that the projectsincluded in the NDPs would add to the existing cross-border capacities. Thus, the positiveNRAs responses to this question should be considered with caution.

Table 1 0 shows that in more than 50% of the cases the NRAs were not in a position to assessthe alignment of target cross-border capacities with the NDPs of the neighbouring countries,or were not able to respond at all.

Table 9: Estimated NDP target cross-border capacities

Estimated target cross- NRANRAsborder capacities responses

AT BG EE GR HR HUIE; MT PL PT; ROYes 14 54%SK; SI; UK-GBBE CY CZ DE ES FR IT LV LT LU SE1T0 1 2 46°,/o ‘ ‘ ‘

UK - N. IrelandTotal 26 100%

Table 10: Consistency of cross-border capacity in the NDPs of neighbouring Member States

Target cross-borderNRAcapacities alignment with % NRAs

. . responsesneighbouring NDPsYes 6 23% AT;BE;IE;PT; SI; SKNo 3 12% BG;CY;E$Not able to assess CZ; EE; FR; DE; HR; HU; LU; LV; PL; RO;

12 46% SE;UK-GBNo answer 5 19% GR; IT; LT; MT; UK - N. Ireland

19

Total 26 100%



The Agency recommends that, in pursuit ofbetter coordination ofprojects creating new cross-border capacities, the draft NDPs are consulted with the TSOs ofneighbouñng Member Statesand the NRAs in these States, especially with respect to cross-border capacities. The Agencynotes that the NRAs and the TSOs should closely cooperate for cross-border projects byexchanging relevant capacity information on a regular basis.

The Agency notes that in comparison with the practices reported in 2016, fewer NRAs reportin 201 8 that they estimate consistently the target cross-border capacities with the NRAs ofother potentially impacted countries. The Agency notes that the absence of consultations or,as a minimum, coordination between NRAs on NDPs containing projects directly or indirectlyimpacting other countries is a factor that contributes to the lack of consistency between plans,and should therefore be avoided.

3.2 Identification ofinvestment gaps

The NRAs provided information about the way in which investment gaps are determined inthe NDPs. Out of 27 responses, 1 3 NRAs indicated that investment gaps are identified in theNDPs afier an in-depth analysis of the infrastructure needs (top-down approach); in 1 1 cases,the identification of infrastructure gaps is an outcome of gas infrastructure system and/ormarket modelling, in 1 1 cases the analysis is performed on a case-by-case basis after ananalysis ofprojects (bottom-up approach), and in 10 cases the identification ofthe gaps is anoutcome of an economic test (capacity auctions, market consultations, shippers’ request forcapacity).

Table 23 in Annex II illustrates the investment gaps identification modalities.

The Agency is ofthe view that a combination ofseveral criteria and approaches is likely to bebeneficial for arriving at a robust and trustworthy identification of investment gaps andprojects closing these gaps. The Agency recommends NRAs to exchange information aboutthe approaches used for the identification of investment gaps, in particular for cross-borderinvestment gaps, and strive to apply, besides market signals (congestion) and open seasonprocedures (market subscriptions for new capacity), coordinated methodologies.

3.3 Comparison ofthe NDPs and the EU TYNDP

The EU TYNDP generally follows a “bottom-up approach” for the identification of investmentgaps and the analysis of projects closing those gaps, where the potential individualcontribution of a project or the collective contribution of a group of projects, both classifiedby maturity level, to various non-monetary indicators are assessed. The merits ofthe projects(or the groups ofprojects) are assessed against the changes in the values ofthe indicators thatwould be caused by implementing the project(s). On the other hand, most NDPs use acombination of various approaches for the identification of investment gaps.

4. Analytical methodology of the NDPs and comparison with the TYNDP 2017

The NRAs provided information on the analytical methodologies used for elaborating NDPs,covering aspects such as the use of market and network studies, economic tests (e.g., openseason procedures), the availability of cost data, and the evaluation of security of supply.

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4.1 Market and network studies

Market studies covering projections of gas market fundamental data (supply, demand, peakdemand capacity, and prices) are carried out in more than 70% ofthe instances. This representsa 1 0% increase in the use of market studies in the last 2 years.

Table 11 : Market studies in NDPs

Total 26 100%

Network studies, i.e. hydraulic simulations carried out to determine the ability ofthe networkto flow gas and to cover stress I high demand situations, are used in 75% of NDPs, slightlymore often than market studies, increasing by 7% compared to the last review of NDPs. Thenetwork studies are carried out using software solutions and are based on detailed networktopology data. Such network modelling is used, in some cases, for both routine networkoperations and for simulating network developments under different scenarios (physicalvolumes and entry/exit flow configurations).

Table 12: Network studies in NDPs

Total 24

4.2 Use ofcost data

100%

Table 1 3 shows that project cost information is used in 70% of NDPs, although thisinformation is not always publicly available. 62% of the NRAs indicated that NDPs containonly investment costs (CAPEX), while in 2 other instances NDPs contain both investmentcosts and operational expenses (CAPEX and OPEX). The availability of cost data in NDPshas not changed since the previous review ofNDPs in 2016.

21

Use of market NRA. % NRAsstudies responses

AT BE BG CZ DE fR GR HU; IE IT; LV MT PLYes 19 73%RO; SE; SI; 5K; UK-N/Ireland; UK-GB

No 7 27% CY; EE; ES; HR; LT; LU; PT

Use ofNRAs

network % NRAs. responses

studies

0 BE; BG DE; ES; FR; GR; HU; IE; LV; MI; PL PT ROYes 1 8 75 /oSE SI; 5K; UK-N/Ireland; UK-GB

No 6 25% AT; CY; FE; IT; LT; LU


Table 13: Inclusion and use of costs in NDPs25

NRAInclusion of costs in NDPs % NRAs

responses

Investment costs(CAPEX);Operational costs 2 8% AT; LT(OPEX)

Investment costs (CAPEX) 16 62%BG; CY; CZ; DE; EE; ES; FR; GR; HR;IE;IT; LU; LV; PL; PT; SI

NDP does not include costinformation 15% BE; RO; 5K; UK N. Ireland

No answer 4 15% HU ; MT; SE; UK-GB

Total 26 100%

Cost information about planned investments

Only 1 0 NRAs indicated that information on the total cost ofplanned investments is availablein the NDPs. The total value of such investments amounts to approximately €17. 1 billion overthe next 10 years, but in only 2 instances the reported CAPEX covered the entire 1 0-yearhorizon, i.e. approximated life-cycle costs. 3 NRAs26 pointed out that the projected investmentcost is considered to be confidential in the NDPs.

Due to limited data availability, the cost information at aggregated level as provided in thisOpinion is not to be seen as representative of the expected investment expenditure, which islikely to be significantly higher, also because the reported cost data is not full life-cycle cost.For example, the estimated total investment costs for gas PCIs included in the 201 7 list ofPCIs amount to €43.5 billion27. Data provided by NRAs in 2018 are less complete than theones provided 2 years ago.

The Agency notes that the absence of fundamental information such as cost and especiallylife-cycle cost of projects in in some NDPs and the EU TYNDP, makes many projectsquestionable in the eyes of the public, given the fact that these projects are to be undertakenin a heavily regulated industry, and given the fact that many ofthese projects also lack benefitsdata. The Agency recommends to the parties responsible for preparing NDPs and the TYNDPto assure that cost data is transparent and properly assessed on the basis of full life-cycleproject cost.

4.3. Use ofcost-benefit analysis and monetisation

Cost-benefit analysis (CBA) is carried out for preparing 3 1 % of the NDPs. However, thevarious categories of benefits (e.g. enhanced security of supply, market integration,competition, sustainability) are generally not monetised.

“Other circumstance&’ regarding the use of CBA in NDPs are reported by 1 5% ofNRAs. Forexample, in Great Britain, National Grid currently uses a “Whole Life Prioritisation matrix”process to evaluate investments, which takes into account the cost of the options, the benefits

25 Costs are not published in all cases since they could be a confidential part of the NDP.26 Austria, Croatia, Poland.27 ACER Consolidated Report on the progress ofelectricity and gas PCIs for the year 2017.

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and the suitability ofthe option to meet the need. Greece indicates that both costs and benefits

are taken into account for specific asset investments, even though in Greece there is no

established CBA methodology for gas projects yet.

Table 14: Use of cost-benefit analysis in NDPs

Total 26 100%

4.4 Security ofgas supply (economic evaluation)

None of the NDPs includes the economic evaluation of security of gas supply (SoS) in the

form of the cost of disruption of gas supply (CoDG) per individual project, although other

type of SoS assessments are carried out in NDPs. For example, Latvia commented that SoS

evaluation has been carried out in the framework of the Joint Risk Assessment of the security

ofgas supply ofthe European Union Member States ofEstonia, Finland, Latvia and Lithuania

prepared by Directorate General Joint Research Centre (DG JRC) of the European

Commission in 2016.

Table 15: Economic evaluation of security of supply in NDPs

. . . NRA$o$ - economic evaluation in NDPs % NRAs

responsesYes

0 0%No AT; BE; BG; CY; CZ; DE; ES; FR;

GR; IE; IT (up to 2017); HR; LU; LT;PT; RO; SK; SE; UK - N.Ireland;

21 81% UK-GB

Not able to assess 3 12% EE; HU; PLNo answer 2 8% MT; LVTotal 26 100%

Note: in Italy, since NDPs 20 1 8, the monetised benefit category B3 SoS is composed by the impacts under normaland stress conditions.

4.5 Comparison ofthe NDPs and the EU TYNDP

Use olmarket and network studies

The EU TYNDP “market” or “energy” model uses price assumptions from the TEA’s28 WordEnergy Outlook, and TSO gas demand estimates for their respective country.

The EU TYNDP is based on the submitted projects by TSOs and other promoters, and is notan outcome of the EU TYNDP modelling.

233

Use of CBA in NUPsNRA

NRAsresponses

Yes 8 31% AT; IE;IT;MT;PT;RO; SI; SE

BE BG CZ DE EE ES FR GR HU LV LTNo 1 4 54% ‘ ‘ ‘

PL; 5K; UK - N. IrelandOther 4 15% CY; HR; LU; UK - GB

28 International Energy Agency.


In contrast, 75% of the NDPs use network modelling and 73% of the NDPs use gas demandmarket studies. In 23% ofthe instances, simulation is run using hydraulic modelling software,while in the other cases other models are used. The use ofhydraulic simulations makes NDPsassessments generally different from TYNDP assessments when it comes to identifyingphysical bottlenecks in the system and the “real life” operational conditions of the gasinfrastructure network. NDP simulation tools are generally well suited to identify investmentgaps and simulate possible solutions. Under some NDPs, NDP projects are an output fromsystem simulations, while in the EU TYNDP projects are an input for the modelling.

Availability ofcost information

The 201 7 EU TYNDP includes aggregated cost information per project categories, i.e. pertransmission pipelines, LNG and UG$, but not at individual project level.

In contrast, nearly 70% ofNDPs include cost information about the project investment costs,and in some cases the operational expenses associated with the infrastructure projects are alsoconsidered.

Cost-benefit analysis and monetisation ofbenefits

The CBAs of the TYNDP carried out so far by ENTSOG have primarily used multi-criteriaanalysis based on a set of indicators, and the analyses have been performed at system levelrather than for individual projects. The analyses have not used cost data at individual projectlevel.

On the other hand, approximately one-third of the NDPs are elaborated by using CBA, whilein another third ofthe NDPs studies ofthe costs and the benefits ofthe projects are conductednot in the context of NDP itself, but on a case-by-case basis, before deciding on investing inspecific projects. In all of these instances, both costs and benefits are considered.

The Agency reiterates its position that a CBA methodology which does not take into accountcosts is a contradictio in terminis and is consequently unable to produce meaningful results asrequired by the regulations.29 The Agency expects that the updated version of ENTSOG’sCBA methodology will contain ways and means that enable the carrying out of assessmentsand comparisons of project-specific costs and benefits, and that the methodology will allowthe monetisation ofbenefits to the maximum possible extent.

29 Agency’s Opinion on draft ENISOG’s TYNDP 2015, p. 4http://www.acer.etiropaeu/official_documents/acts_oLthe agency/opinions/opinions/acer%2Oopinion%201 1-2015.pdf

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ANNEX II: NDP Questionnaires: Data Annexes

Data availability

The Agency, in cooperation with NRAs, developed a questionnaire in order to collect dataabout the key features and the methodology used for the development of the NDPs (“NDPquestionnaire”).

27 out of 29 NRAs cooperating under the Agency (AT, BE, BG, CZ, CY, DE, DK, EE, ES,FR, GR, HU, HR, IE, IT, LT, LU, LV, MT, PL, PT, RO, SE, SI, SK, UK-GB30, UK-N.Ireland3 1) responded to the Agency’ s request of information via the NDP questionnaire.

Figure 1 : Unbundling model of the gas T$O(s) by Member State

‘:

30 Ofgem.

K

. Full Ownership Unbundling OU)

. Independent TransmissionOperator tITO)

. Independent System Operator(ISO)

S Other Circumstances

Several models (several TSOsoperating in the Memberstate)

31 The Danish NRA reported that currently there is no specific NDP for gas. Due to few investments in the gasnetwork by the ISO, the yearly national report on gas security of supply has been used as a vehicle to describeexpected future net developments, but without any detailed project information regarding cost figures,commissioning dates, etc. Together with a report/list of assets this has made up the overview of gas systeminvestments. However, the NRA informed that a strategic investment plan is foreseen in the future, so that thenet development plan will become part of the strategic investment plan.

25 of 63

m No information


Figure 2: NDP by year of publishing32

L 2008

III 2016

2017

. 2018

‘- : No information

32 Spanish NDP is from 2008, last update in 2010.

S Indicative, for all projects

KMandatory in the short term(projects commissioned in 3 years)and indicative in the long term

R Mandatory, (or all project

. Indicative and mandatory(depending on the urgency of theprojects)

S Others

III No

26f

I

I

Figure 3: NDP legal nature

ACERAgency for the Cooperation

— of Energy Regulators

Figure 4: Number of NDPs by Member State

m SeveraiTSOs oneconsolidated NDP

27 63

. One

. Several TSOs,several NDP

Other options

S No information

\

Figure 5: Inclusion of cost and benefits in NDPs

411

B Investment costs(CAPEX) only

Investment costs(CAPEX) andoperational costs(OPEX)

NDP does notinclude costinformation

r • No information

;;r.

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figure 6: Use of cost-benefit analysis and monetisation

. Yes

RNo

Other

a No Information

Reporting . . .

NRA

TSO unbundling model -gas Information on certification of TSOs, other comments

. Independent TransmissionAustria TSOs are certifiedOperator_(ITO)Full Ownership UnbundlingBelgium

(OU) T$Os are certified

. Independent TransmissionBulgariaOperator (ITO)

. . The process of TSO certification under the Full OwnershipCroatia Other circumstances . .

Unbundhng (OU) model is ongoing.. At the moment there is no gas or gas infrastructure in CyprusCyprus Other circumstances

and there is no TSO.Czech Independent Transmission

. CertifiedRepublic Operator (ITO). Full Ownership UnbundlingEstoma

(OU)Several models (in case of .. . GRTgaz is certified as an ITO.France several TSOs operating in , .

Terega (formerly TIGf) is certified as an OU.your Member_State)Several models (in case of

. . 15 out of 16 TSOs are certified. 13 operate under the ITOGermany several TSOs operating inmodel and 3 under the OU model.your Member_State)

DESFA S.A. is certified as Independent Transmission

GreecIndependent Transmission Operator (ITO) for gas, by RAE’s decision Nr.e

Operator (ITO) 523/25.9.2014, according to the provisions of Greek Law_________________________

4001/201 1, as amended.

28’ç63

S

Table 16: TSO unbundling model, country-specific replies by NRAs

ACER


Reporting . . .

NRATSO unbundhng model -gas Information on certification of TSOs, other comments

Several models (in case ofHungary several TSOs operating in One of the two TSOs is OU and the other one is ITO

your Member_State)Full Ownership Unbundling Gas Networks Ireland (GM) has been certified as anIreland

(OU) ownership unbundled (OU) TSO.Several models (in case of

Italy several TSOs operating in All the Italian TSOs have been certified as either OU or ITO.your Member_State)

LatviaFull Ownership Unbundling Certification process is ongoing. Draft decision was sent to

(OU) the European Commission for assessment on 3 1 May 201$.. TSO is certified (see https://eur-lex.europa.eu/legal

LithuaniaFull Ownership Unbundhng

content/EN/TXT/?uri=CELEX%3A520 1 5XG0707%280 1%2( )Luxembourg holds a derogation towards Article 9 of theDirective 73/2009. Art. 10 ofthis Directive and Art 3 of

Luxembourg Other circumstances Regulation 7 1 5/2009 are not applicable. However, pursuantto national law, ILR designated the ISO and communicated

this designation to the Commission.Article 49 ofDirective 2009/73/EC states that Article 9 on

Malta Other circumstances ‘unbundling of transmission systems and transmission systemoperators’ shall not apply to Malta. There is no TSO in Malta.Gaz-System S.A. is the sole gas ISO on the territory of the

Republic ofPoland. In 2014, the company was certifiedunder the OU model in relation to performing the function of

PolandFull Ownership Unbundling TSO on the networks belonging to the company. In 2015,

(OU) Gaz-System S.A. was certified under the ISO model inrelation to performing the function of TSO on the Polish

section of the Yamal pipeline belonging to EuRoPol GAZS.A.

Full Ownership Unbundling .Portugal(OU) The TSO is certified

RomaniaIndependent System

Certified ANRE Order no.72/20 14Operator_(ISO)Slovak Independent Transmission .. TSO is certified.Republic Operator (ITO)

. Independent Transmission .Slovenia TSO is certifiedOperator_(ITO). There are 4 TSOs in Spain all of them certified. Enagás andSeveral models (in case of .. . . Reganosa (2 TSOs) are certified as OU. Saggas and EnagasSpain several TSOs operating in .Transporte del Norte (2 TSOs) are certified as ISO, beingyour Member State) ,

Enagas_(OU)_their_ISO.Full Ownership Unbundling . . .Sweden

(OU) Swedegas is a certified transmission grid operator

Umted . .

Yes certified. Article 8(b) of the Gas (Northern Ireland)Kingdom Full Ownership Unbundhng .

Order 1996 requires a person who holds a licence to be(Northern (OU) .

certified at all times.Ireland)United .

. Full Ownership UnbundhngKingdomIOU” Certified.

(GB) k I

29 of63


of Energy Regolators

Table 17: Development of NDPs (comments of NRAs selecting “Other Options”)

Reporting NRA Development of NDPs, “Other Options”

Belgium NDP is not subject to formal approval but subject to coherence check by CREG.

Cyprus CERA may require TSOs to comply with minimum standards for the maintenance anddevelopment of the transmission system, including interconnections.Article 22- ‘Network development and powers to make investment decisions’ of thedirective 2009/73/EC has not been fully transposed into national law. The only provisionthat is clearly transposed is the following: “The regulatoiy authority monitors whetherthe network development plan covers all investment needs and whether it is consistentwith the non-binding ornmunity-wide ten-year network developmentplan referred to inarticle 8(3)(b) Regulation (EC) No 715/2009. The regulatoiy authority may require thetransmission system operator to amend its ten-year network development plan.”

Czech Republic Proposal developed and consulted by TSOs. The Ministry issues a binding opinion.The NRA is consulted on the proposal ofthe TSO. The NRA can approve the plan or canamend the NDP.

Estonia Proposal developed by TSO. The NRA can recommend changes to the TSOs’ proposal.

Italy The NDPs are not formally “approved”. Rather, they are “evaluated” by both the NRAand the Ministry, according to the respective duties. The NRA can amend the TSO’sproposal.

Latvia Proposal developed by TSO, NRA can amend it.According Cabinet of Ministers Regulation No.322 “Regulations Regarding the AnnualAssessment Report ofa Transmission System Operator” in the annual assessment reportTSO must provide assessment of the new transmission projects. “Regulations onSubmission oflnformation in the Energy Sector” determine the investment plan for thenext 5 years. The report on the implementation of the investment plan for the referenceyear is to be submitted annually by 3 1st March.

Luxembourg There is no approval of the NUP: according to national law, the TSO has to develop aten-year national plan, notify this plan to the Ministry and copy the NRA.

Slovak Republic Proposal developed by TSO, the NRA consults the NDP and can ask the TSO foramendments. The NRA shall request the TSO to change the NUP in a reasonable periodif the NDP either fails to reflect economically reasonable and technically feasibleimplementation of investments, or is in conflict with the EU TYNDP or is not preparedin accordance with defined conditions.

Sweden Not applicable

United Kingdom The TSOs consult with the NRA in the development of the statement but the NRA does(Northern not amend, reject or approve it.Ireland)

United Kingdom This depends on the proposals being developed by the TSO as different approaches are(GB) required e.g. for an asset proposal versus a commercial proposal.

30 o163



Table 18: Legal nature of NDPs (comments of NRAs selecting “Other options”)

Reporting NRA Legal nature of NDPs, “other options”

Croatia Mandatory in the short term (for the projects commissioned in the current regulatory period- maximum up to 5 years) and indicative in the long term (for the projects planned to becommissioned in the subsequent regulatory period/s).

Spain It is mandatory for LNG terminals, high pressure (>60 bar) and secondary (60-16 bar)pipelines and UGS connected to high pressure network33. It is indicative for the rest of theinfrastructures (compressor stations and other pipelines).

Sweden Not applicable, no NDP.

TSO and NRA responsibilities in defining the NDPs

The NRAs provided information about the role of the T$Os in defining and elaborating theNDPs according to national legislation. The precise process ofNDP elaboration and adoptionvaries somewhat across Members States, but the main features are fairly similar.

Commonly, TSOs propose the NDP afier consulting relevant stakeholders, such as entitiesconnected to the system, gas undertakings, and shippers. TSO network development proposalscover all necessary investments and are based on reasonable assumptions about gas demandand supply, system adequacy and economic impact. The proposals and the results of theconsultation process carried out by the TSOs are then sent to the NRA for examination.

Generally, the role of the NRA is to examine the TSOs’ network development proposalsregarding the coverage of necessary investments, scenarios, assumptions, and the impact ofnew investments on transmission tariffs and on the functioning of gas markets. The NRAmonitors the NDP development process in order to assure that it is conducted in a non-discriminatory and transparent manner and, in some instances, the NRA cross-checks theconsistency ofthe NDPs and the EU TYNDP.

The NRA may conduct a second consultation round on the TSO network developmentproposals with relevant stakeholders.

In some Member States where several gas infrastructure operators exist (e.g. France, Italy),each TSO, LNG and UGS operator may develop its own network development plan, while inother such Member States where multiple operators exist (Austria, Germany, Hungary, Spain,UK — Northern Ireland) there is just one integrated plan containing projects from the variousoperators within the country.

Table 1 9 illustrates the responses received as regards the roles of the TSOs and the NRAs indefining the NDP.

33 Called “basic UGS” under Spanish terminology.

ACER


The Agency notes that in the vast majority ofcases the NDPs are developed by the TSOs afier

a consultation process involving relevant stakeholders. In the Agency’s view, this practice is

generally justified, since the TSOs operate and closely monitor the systems and are thus best

placed to identify bottlenecks and constraints in the operation of the networks and to propose

network developments to the public authorities (to the NRAs in most cases and to the

Ministries in a fewother cases).

Table 19: T$O and NRA responsibilities in defining NDPs

Reporting TSO responsibilities in defining the NRA’s role in defining the NDP under nationalNRA NDP under national legislation legislation (Summary)

(Summary)

Austria The TSOs jointly submit a coordinated The NRA approves the CNDP by an officialNDP (CNDP) to the NRA for approval. decision. The T$Os must prove that theWhen elaborating the CNDP, reasonable investments in the plan are necessary for technicalassumptions about the evolution of reasons, adequate and economically efficient. Priorproduction, supply, consumption and to issuing the related official decision, the NRAexchanges with other countries shall be consults the CNDP with the organisationsmade. The CNDP plan shall contain representative ofsystem users. The NRA publishesefficient measures to guarantee the the results of the consultation, indicating inadequacy of the system and ensure a high particular any needs for investments. In particular,degree ofavailability ofcapacity (security the NRA verifies whether the CNDP covers theof supply of the infrastructure). In investment needs identified in the consultation todrawing up the CNDP, technical and their full extent and whether it is consistent witheconomic expediency, the interests of all the TYNDP.market participants and consistency withthe TYNUP and the long-term plan shallbe taken into consideration.

Belgium Develop a ten-year NDP for the next 10 CREG receives a 10 year NDP from the TSO on anyears on a yearly basis annual basis. CREG has to verify the coherence of

the NIJP with the EU TYNDP. CREG has to verifywhether open season procedures are correctlycovered. The coherence of tariffs and investmentsare checked. CREG is closely involved in the NDPon a voluntary basis. NDP is not subject to a formalapproval procedure.

Bulgaria In accordance with the Bulgarian Energy In accordance with the Bulgarian Energy Act theAct, the TSO develops, consults with all NRA consults with all current or potential users ofthe interested parties and provides to the the network the 10-year plan for development ofNRA annually a 10-year plan. The TSO the transmission network in an open andshall consider the available information transparent way. Potential users of the networkabout forthcoming changes in the gas may be requested tojustify their claims. The resultsproduction, supplies, consumption and from the process of consultations, including thevolume with other Member States, possible needs for investments, shall be publishedincluding via research, while taking in on the NRA’s web site. The NRA shall find out ifconsideration the investment plans for the 10-year plan for the development of theregional networks, for networks on the transmission network covers all the needs forterritory of the EU, and for equipment for investments established in the process ofstorage of natural gas. consultations, and if it is coherent with the EU

TYNDP. The NRA shall monitor and assess theimplementation of the 10-year plan for thedevelopment of the transmission network.

32 of’

ACER


Reporting ISO responsibilities in defining the NRA’s role in defining the ND? under nationalNRA NDP under national legislation legislation (Summary)

(Summary)

Croatia The TSO prepares the NDP in accordance The NRA approves the NDP and within thatwith the Energy Development Strategy process the NRA:and its Implementation Programme, and - verifies the conformity of the NDP with thesubmits it to the NRA for authorization Energy Development Strategy and itstogether with a Request for determining Implementation Plan (may consult the Ministry),or changing the amount of tariff items for - verifies the conformity of the NDP with the EUgas transmission. Planned investments TYNDP (may consult ACER),must be technologically justified and - consults all existing or potential transmissioneconomically efficient, and ensure an system users about the NDP through a publicadequate security level of gas supply. debate lasting 15 days, and in that process the NRA

may request adequate proof from potentialtransmission system users.- verifies whether the NDP covers all investmentneeds recognized in the consultation process,- may demand amendments of the NDP from thetransmission system operator.

Cyprus The TSO has to prepare a NIJP. CERA is indirectly approving such a plan.

Czech The TSO compiles the NDP in The NRA consults the NDP, assesses the NDP andRepublic accordance with the Energy Law, consults its compliance with the requirements for the

the proposed NDP with existing and realization of investments in the transmissionpotential future users of the transmission system and with the EU TYNDP, and evaluates thesystem, submits the proposed NDP to the implementation ofthe NDP. The NRA can approveMinistry for a binding opinion, together the plan or can issue a decision on an order towith a record ofthe consultations with the change or eliminate defects of the NDP.NRA, and publishes the NDP.

Denmark No NDP for gas No NUP for gas

Estonia After consulting with market participants, The NRA monitors and assesses the investmentsthe system operator prepares a NDP made in order to implement a networkproposal and submits it to the development plan as regards their consistency withCompetition Authority. the EU TYNDP and presents its assessmentThe system operator submits to the NRA regarding the investment plans of the systema report on the progress made in operator in its annual report. Such assessment mayimplementing the network development include recommendations to amend thoseplan and on eventual changes in the plan investment plans.each year, amending the developmentplan in particular with respect to theinvestments to be made during thefollowing three years.

France The TSOs’ responsibilities in the NDP CRE’s responsibilities in the NDP process are theprocess are the following: develop long- following: organize a public consultation, checkterm scenarios for demand & supply the coherence of the national plans with the EU-(common to both TSOs) and evaluate the wide TYNDP and the multiannual energy plan, andneed for grid reinforcement at check that all system needs are covered.transmission level.

Germany The TSOs have to jointly develop a 10 The NRA is consulting the draft NOP with allYear NDP. This NDP has to contain all relevant stakeholders and can oblige the TSOs tomeasures that are needed to optimise, change and amend the NDP according to the NRAsenhance and strengthen the network and specifications. The NRA can also appoint thethe security of supply. responsibility of implementing investment

measures to specific TSO.

\33 of%3

ACER



(Summary)

Greece There is currently no NOP provided for in RAE monitors and evaluates the implementation ofthe Greek legislation, to include all the TYNDP. In circumstances where the TSO doesprojects, either the ones included in the not execute an investment, which, under theGreek T$O (DESFA) NDP or projects of TYNDP, was to be executed in the following threeother project sponsors developed as years, other than for overriding reasons beyond itsIndependent Natural Gas Systems control, RAE can take at least one of the following(INGS). Therefore, the only NDP measures to ensure that the investment in questioncurrently approved by RAE in Greece is is made, if such investment is still relevant, on thethe one prepared and submitted to RAE basis of the most recent TYNDP: (a) require theby DESFA. RAE has the competence to ISO to execute the investments in question; (b)enforce the TSO to perform changes at the organise a tender procedure open to any investorsNDP regarding user requests for new for the investment in question; or (c) oblige theinvestments. TSO to accept a capital increase to finance the

necessary investments and allow independent. investors to participate in the capital.

Hungary The TSO prepares the NDP. The NRA approves the NDP.

Ireland Gas Networks Ireland (GM), as Ireland’s CRU, as Ireland’s NRA is required to consult allgas TSO is required to publish on an actual or potential system users regarding the Gasannual basis a NDP. As part of the NIJP TSO’s NDP. Additionally, the CRU, as Ireland’sdevelopment process, GNI is required to NRA, is also required to publish the result of themake reasonable assumptions about the consultation process, and examine whether theevolution of gas production, supply, TSO’s NDP covers all potential needs forconsumption and exchanges with other investments identified during the consultationcountries. process and is consistent with the EU TYNDP.

Italy According to national legislation, the According to national legislation, the NRA has theItalian Gas TSOs are required to submit, following tasks/duties: 1) to run a publicon a yearly basis, NDPs to the NRA and consultation on the NUPs; 2) to evaluate whetherthe Ministry. The NDPs must contain a the investments foreseen in the NDPs are adequatedescription of the network, of its to satisfy system needs, and whether the NDPs arecongestions, and a list of justified consistent with the European TYNDP; 3) toinvestments to be realised in the following monitor the actual implementation of the NDPs1 0 years. TSOs must also estimate the over time.possible evolution of gas demand and Also, the NRA has the power to ask the TSOs forsupply trends, taking into account NDPs amendments to their NDPs.in other countries as well as plannedinvestments in storage and LNGterminals.

Latvia There is no NDP in the gas sector. The content and process of the NDP is notAccordingly to the Energy Law (Article determined by the Energy Law. PUC has defined43.1), the natural gas system operator the content of the NDP in the ‘Regulations onshall prepare a transmission system and Submission of Information in the Energy Sector”.consumption conformity annualassessment report for a period ofup to 10years. Since 2017, the TSO is obliged tosubmit for information an investment planfor the next 5 years and a report on theimplementation ofthe investment plan forthe reference year.

\34 of

ACER


Lithuania implemented the OU model. Ittransposed Article 22 ofthe Gas Directiveinto its legislation. The TSO isresponsible for the development of theNUP.

Lithuania implemented the OU model, Article 22of the Gas Directive was transposed into ourlegislation. The NRA is responsible for theassessment of the NDP - whether it is prepared inline with the Gas Directive and the Law on NaturalGas requirements. Article 3 1 (4)-(7) of the Law onNatural Gas states that: 4. The NRA shall consultall actual or potential system users on the NDP inan open manner; 5. The NRA shall examinewhether the NDP covers all investment needsidentified during the consultation process, andwhether it is consistent with the EU-wide ten-yearnetwork development plan. If any doubt arises asto the consistency with the EU-wide networkdevelopment plan, the NRA shall consult theAgency. The NRA may require the TSO to amendits NDP where it fails to cover all investment needsidentified during the consultation process, or wherethe NDP is not consistent with the EU-wide ten-year network development plan, or where thedevelopment plan does not comply with therequirements for the content of the NDP as definedin this law; 6. The NRA shall monitor and evaluatethe implementation of the NDP and publish theresults. The NRA shall oblige the TSO failing toimplement the NIJP to implement the NDP andmay impose sanctions; 7. In circumstances wherethe TSO, other than for overriding reasons beyondits control, does not execute an investment, which,under the NDP, was to be executed in the followingthree years, the NRA must take at least one of thefollowing measures to ensure that the investment inquestion is made if such investment is still relevanton the basis of the most recent NDP : 1) to requirethe TSO to execute the investments in question; 2)to organise a tender procedure open to anyinvestors for the investment in question; 3) tooblige the TSO to accept a capital increase tofinance the necessary investments and allowindependent investors to participate in the capital.

Lithuania


(Summary)

Luxembou Creos, the national TSO, has to develop a The NRA has no role in defining the NDP. Therg ten-year national plan, notify this plan to NRA has to evaluate the NDP and to analyse it in

the Ministry and copy the NRA. regards to the EU-TYNDP, which can lead toThis plan has to be updated every 2 years. possible recommendations.

35 of’3

ACER



(Summary)

Malta Each transmission system operator shall The Regulator’s role is to cooperate in regard tobuild sufficient cross-border capacity to cross-border issues with the regulatory authority orintegrate European transmission authorities of the Member States concerned andinfrastructure accommodating all with the Agency; it monitors compliance andeconomically reasonable and technically reviews the past performance of network securityfeasible demands for capacity and taking and reliability rules. The Regulator shall beinto account security of gas supply. responsible for fixing or approving sufficiently inThe transmission system operators shall advance of their entry into force at least theadopt rules for balancing, and procure the methodologies used to calculate or establish theenergy they use for the carrying out of terms and conditions for: a) connection and accesstheir functions according to transparent, to national networks, including tariffs, and LNGnon-discriminatory and market based facilities. Those tariffs or methodologies shallprocedures. allow the necessary investments in the networks

and LNG facilities; b) the provision of balancingservices; and c) access to cross-borderinfrastructures, including the procedures for theallocation of capacity and congestion management.

Poland The TSO consults a draft NUP with The draft development plan has to be agreed withinterested parties in an open and the Regulator. The NRA provides consultationstransparent manner. The TSO shall with the owner of the pipeline regarding theextensively cooperate with regional financing of investments in a gas pipelineauthorities in order to assure compliance maintained by the TSO (in case when the TSO iswith assumptions, strategies and plans not the owner ofthe pipeline). Moreover, the NRAelaborated by regional authorities. The assesses the compliance with the legaldraft development plan has to be agreed requirements, considering the balance of interestswith the Regulator. The approved of the energy undertakings and gas customers.development plan needs to be updatedevery 2 years. The execution of theapproved plan is reported on a yearlybasis. The development plans shouldensure long-term maximisation ofefficiency related to the costs of theinvestments and the costs borne by theenergy enterprise, so as to ensure that theexpenses and the costs associated withthem do not cause an extensive increaseofprices and fee rates ofnatural gas in therespective years, while ensuring thecontinuity, reliability and quality of thegas supply.

Portugal As defined by Decree-Law No. 231/2012, ERSE conducts a public consultation of the NDPthe TSO elaborates every odd year a NDP proposal received from the Government, preparedproposal which will be submitted to the by the TSO. With the information gathered andGovernment, which in turn sends it to the with the results of its own analysis, ERSE submitsNRA. The TSO introduces in the NDP a to the Government its opinion about the projectsproposal for the modifications requested contained in the proposed NDP.by the Government.

36 o3

ACER


Reporting T$O responsibilities in defining the NRA’s role in defining the NDP under nationalNRA NDP under national legislation legislation (Summary)

(Summary)

Romania The T$O has the obligation to elaborate Under the Electricity and Gas Law no. 123/2012,an investment and development plan for the development plans provided by the TSO must10 years, based on the current status and be approved by the NRA.the future evolution of the natural gassources and consumption, includingnatural gas imports and exports. The planincludes financing conditions andsolutions on how to carry out theinvestments for the transmissionfacilities, based on the management andurban plans ofthe territory where they arelocated, in accordance with theenvironmental protection standards.

Slovak The TSO develops the NDP. National The NRA shall consult the NDP with existing andRepublic legislation defines the criteria which shall potential network users, review the compliance of

be followed and criteria for the measures the NDP with legal requirements and the EUneeded to ensure system adequacy and TYNDP. The NRA can impose on the TSO thesafety. The T$O shall consult the NDP. duty to change the NDP and shall monitor and

assess the implementation of the NDP.

Slovenia The TSO is not obliged to carry out all the The NRA must conduct a public consultation oninvestments listed in the ten-year NUP. the NDP and may require from the TSO to changeProjects that should be built in the next the NDP and/or the Investment Plan if it is not inthree years are listed in the Three-Year line with the public consultation results and/orInvestment Plan, which is attached to the methodology. The NRA’s consent on the NDPNDP and is confidential. The Investment includes also the consent on the Investment Plan.Plan contains detailed data and The realization of the projects must be reported ininformation on the projects and must be in the next Investment Plan.line with the methodology issued by theNRA.

Spain All TSOs participate in the NDP The NDP is approved by the Government. Thedevelopment by proposing investments regulator only provides the Ministry of Energythat they consider necessary to attend the with its opinion via a non-binding report.demand in their zone of influence. TheNDP is designed by the Technical SystemManager (Enagás GTS), taking intoaccount projects proposed by TSOs,

___________

network users and other Stakeholders.

Sweden Not applicable Not applicable

United The TSOs create the plan based on The NRA monitors the development of the NDPKingdom existing and forecast supply and demand. and publishes the results. It is prepared by the ISO(Northern This is done with a view to highlight to and the process is set out in the network codes ofIreland) market participants, any infrastructure the TSOs.

that needs upgraded over the next tenyears. The TSOs consult with shippersand the NRA as part of this process.

37 o63

ACER


Reporting T$O responsibilities in defining the NRA’s role in defining the NDP under nationalNRA NDP under national legislation legislation (Summary)

(Summary)

United National Grid Gas produces an annual Ofgem does not have a role in defining the NDPKingdom Gas Ten Year Statement (GTYS) in order under legislation. Investments are all driven by the

to comply with Special Condition 7A of market.its Gas Transporters Licence relating tothe National Transmission System (NTS)and section 0 of the TransportationPrincipal Document of the UniformNetwork Code. The GTYS providesNational Grid Gas customers andstakeholders with a better understandingofhow they intend to plan and operate theNTS over the next ten years. It providesupdates on key network projects andchanges to theplanning processes. They also provideinformation to help customers toidentify connection and capacityopportunities on the NTS.

38\63


Figure 7: Most recent NDPs by year of publication

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AC

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Age

ncy

for

the

Coo

pera

tion

ofE

nerg

yR

egul

ator

s

Table

21:

Project

classification

in

ND

Ps

according

to

maturity

and/or

urgency

criteria

Rep

ortin

g.

Other

NR

AM

atu

rity

Urgency

criteria

Su

mm

ary

of

co

mm

en

ts

Aus

tria

The

T$O

sm

ustp

rove

that

the

inve

stm

ents

inth

epl

anar

ene

cess

ary.

How

ever

, pro

ject

sm

aybe

appr

oved

asx

x(c

ondi

tiona

l)pl

anni

ngpr

ojec

tsin

case

they

are

ina

conc

eptu

alst

age

and

plan

ning

cons

ider

atio

nsar

eno

tfi

nalis

ed.

Plan

ning

proj

ects

are

indi

cativ

epr

ojec

ts.

Bel

gium

No

form

alcl

assi

fica

tion,

but

the

‘labe

l’of

the

proj

ect

inte

rms

ofur

genc

yan

dm

atur

ity

isge

nera

lly

clea

rly

xx

xde

scri

bed.

Bul

gari

ax

Cro

atia

Pro

ject

sar

ecl

assi

fied

ingr

oups

byte

chni

cal t

ype:

pipe

line

s,m

easu

ring

and

redu

ctio

nst

atio

ns,

gas

junc

tion

s,x

aban

donm

ent

ofga

sob

ject

sw

hich

are

out

offu

nctio

n,co

mpr

esso

rst

atio

ns,

mon

itor

ing

and

cont

rol

syst

ems,

tech

nica

l pro

tect

ion

syst

ems,

oper

atin

gfa

cilit

ies,

deve

lopm

ent

ofne

wte

chno

logi

es.

Cyp

rus

xC

zech

xT

heN

DP

defi

nes

thre

eca

tego

ries

ofpr

opos

edpr

ojec

ts-

proj

ects

with

FID

take

n,N

ON

-FID

proj

ects

and

whi

chR

epub

lic

shal

lbe

com

plet

edw

ithi

nth

ene

xt3

year

sE

ston

iaX

Fra

nce

xG

erm

any

XT

here

isno

clas

sifi

cati

onof

the

proj

ects

.G

reec

eT

here

isno

clas

sifi

cati

onac

cord

ing

tom

atur

ity

and/

orur

genc

ycr

iteri

a.Sh

ould

anur

genc

yfo

ra

new

proj

ect

aris

e,x

ther

eis

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ure

inth

eG

asN

etw

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xtra

ordi

nary

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isio

nof

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evel

opm

ent

Plan

)to

allo

wfo

rth

eim

med

iate

exec

utio

nof a

nur

gent

proj

ect.

Hun

gary

XIr

elan

dX

- Ital

yx

Lat

via

xL

ithu

ania

XT

heT

SOha

sto

indi

cate

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com

mis

sion

ing

date

ofth

esp

ecif

icin

vest

men

tpro

ject

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uxem

bou

xN

ocr

iter

iaar

esp

ecif

ied.

rg Mal

tax

n/a

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and

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toth

ela

rge

num

ber

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vest

men

t pro

ject

s,as

afi

rst

step

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TSO

clas

sifi

espr

ojec

tsin

toth

ree

grou

ps:

LR

Ex

(Loa

dR

elat

edE

xpen

ditu

re),

NL

RE

(Non

-Loa

dR

elat

edE

xpen

ditu

re)

and

RN

I(o

ther

/add

itio

nal

inve

stm

ents

not

43

äç

AC

ER

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genc

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rati

onof

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rgy

Reg

ulat

ors

Rep

ort

ing

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ther

NR

AM

atu

rity

Urg

ency

crit

eria

Su

mm

ary

of

com

men

ts

incl

uded

into

grou

psL

RE

and

NL

RE

).T

hegr

oup

ofL

RE

proj

ects

cont

ains

inve

stm

ents

clas

sifi

edas

inve

stm

ents

intr

ansm

issi

onin

fras

truc

ture

asso

ciat

edw

ithth

ein

crea

sein

dem

and

for

gas

and

focu

sed

onde

velo

pmen

t,i.e

.th

eco

nstr

ucti

onof

new

elem

ents

ofth

etr

ansm

issi

onne

twor

kin

clud

ing

new

rout

es,

incr

easi

ngits

capa

city

,im

prov

ing

secu

rity

ofsu

pply

thro

ugh

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cons

truc

tion

ofne

wel

emen

tsof

the

tran

smis

sion

netw

ork.

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grou

pN

LR

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ojec

tsco

ntai

nsin

vest

men

tscl

assi

fied

asin

vest

men

tsin

tran

smis

sion

infr

astr

uctu

rew

hich

are

not

asso

ciat

edw

ith

anin

crea

sein

gas

dem

and,

i.e.

mai

nly

inve

stm

ents

focu

sed

onm

odem

isat

ion

and

repl

acem

ent

of

fixe

das

sets

.A

tth

ene

xtst

ep,

the

TSO

clas

sifi

esth

epr

ojec

tsin

clud

edin

togr

oup

LR

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tosu

b-gr

oups

rela

ted

wit

hin

fras

truc

ture

item

s,i.e

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stem

pipe

lines

,co

mpr

esso

rst

atio

ns,

syst

emno

des,

gas

stat

ions

wit

hm

easu

ring

syst

ems

and

conn

ecti

onto

the

tran

smis

sion

netw

ork.

Age

nera

lru

lere

quir

esth

atna

mes

are

only

give

nto

inve

stm

ent p

roje

cts

with

aco

stva

lue

of a

tle

ast

2m

illi

onZ

loty

,an

dot

her

inve

stm

ents

are

liste

din

aggr

egat

edite

ms

wit

hout

nam

es.

The

TSO

rank

sth

ein

vest

men

tsde

pend

ing

onth

eir

impo

rtan

ce,

impa

cts

and

expe

cted

cont

ribu

tion

s(b

enef

its).

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tuga

lx

The

proj

ects

are

clas

sifi

edac

cord

ing

toth

eir

cont

ribu

tion

tosy

stem

inte

grit

y(s

ecur

ity),

e.g.

toth

eN

-icr

iter

iaac

cord

ing

toR

egul

atio

n99

4/20

1 0,

and

toec

onom

iccr

iter

ia(e

.g.

tari

ffim

pact

s).

Rom

ania

XS

lova

kT

heN

UP

defi

nes

thre

eca

tego

ries

ofpr

opos

edpr

ojec

ts-

proj

ects

with

FID

take

n,pr

ojec

tsw

hich

shal

l be

Rep

ubli

cco

mpl

eted

wit

hin

the

next

3ye

ars,

and

proj

ects

unde

rco

nsid

erat

ion.

Slov

enia

The

T$O

mus

tpro

vide

apr

ojec

tspr

iori

tylis

t.It

isup

toth

eT

SOto

deci

dew

hich

proj

ects

shou

ldbe

buil

tdu

ring

xth

ene

xtth

ree

year

s.T

heN

RA

may

requ

ire

tosh

orte

nth

epr

iori

tylis

tif

the

budg

etpl

anne

din

next

regu

lato

ryfr

amew

ork

cann

otco

ver

all

the

proj

ects

.Sp

ain

XS

wed

enX

Not

appl

icab

le,

noN

DP.

Uni

ted

The

ND

Pre

port

son

the

inve

stm

ent p

roje

cts

unde

rway

,sp

ecif

ical

lyth

ew

ork

unde

rway

toex

tend

the

natu

ral

gas

Kin

gdom

tran

smis

sion

netw

ork

toth

ew

est

ofN

orth

ern

Irel

and.

The

Uti

lity

Reg

ulat

orgr

ante

da

licen

ceto

Mut

ual

Ene

rgy

to(N

orth

ern

Xun

dert

ake

this

deve

lopm

ent.

The

ND

Pon

lyco

mm

ents

onin

vest

men

t pro

ject

san

ddo

esno

tpro

vide

deta

ilbe

caus

eIr

elan

d)no

near

ene

eded

.W

hen

we

fore

cast

dem

and

we

cons

ider

ifan

yne

wga

sor

elec

tric

ity

gene

rati

onis

like

lyin

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peri

od.

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ted

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ingd

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44d63

AC

ER

Age

ncy

for

the

Coo

pera

tion

ofE

nerg

yR

egul

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s

Tab

le2

2:

ND

Pd

evelo

pm

ent

pro

cess:

main

ste

ps

tim

eli

ne

..

NR

Ao

pin

ion

or

Min

iste

rial

consult

ati

on

or

Sta

keh

old

er

consult

ati

on:

TS

Odra

ft:

NR

Aco

nsu

ltati

on

date

s:

Report

ing

NR

Aappro

val

ap

pro

val

Fro

mT

oF

rom

To

Fro

mT

oD

ate

Fro

mT

o

Aus

tria

09/2

017

10/2

017

10/2

017

10/2

017

11/2

017

11/2

017

01/2

018

No

form

alth

ere

isa

opin

ion

ordi

scus

sion

wit

hw

orki

nggr

oup

appr

oval

.st

akeh

olde

rson

inve

stm

ents

afte

rwar

dsbu

tB

elgi

umN

/abu

tno

form

alto

geth

erbu

tno

CR

EG

disc

uss

proc

edur

esfo

rmal

alw

ays

the

ND

Pco

nsul

tati

ons

inC

RE

Gs

annu

al_r

epor

t

Bul

gari

a

Cro

atia

03/2

017

04/2

017

08/2

017

11/2

017

11/2

017

12/2

017

12/2

017

Cyp

rus

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

Cze

chR

epub

lic

07/2

017

08/2

017

01/2

017

1020

1711

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711

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712

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712

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712

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7

Est

onia

Fra

nce

Non

e10

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711

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703

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8N

one

Ger

man

y02

/201

603

/201

604

/201

604

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604

/201

605

/201

607

/201

7

Gre

ece

05/2

016

06/2

016

n/a

08/2

016

08/2

016

09/2

016

01/2

017

n/a

Hun

gary

Irel

and

08/2

017

08/2

017

09/2

017

10/2

017

12/2

017

N/a

.to

geth

erto

geth

erw

ith

Ital

yS

ame

asN

RAS

ame

asN

RA

na.

i 1/2

017

02/2

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04/2

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cons

ulta

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cons

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06/2

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(est

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06/2

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AC

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ncy

for

the

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pera

tion

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egul

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s

..

NR

Aopin

ion

or

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iste

ria

lconsult

ati

on

or

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keh

old

er

consult

ati

on:

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ati

on

date

s:

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NR

Aapproval

ap

pro

val

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mT

oF

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From

To

Date

From

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huania

26M

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ne2

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22

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ne

22June2017

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Luxem

bourg

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a

12

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6-P

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DP

(OU

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ND

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land

03/2

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03/2

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01/2

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na.

n.a

10/2

017

na.

BN

DP

(IS

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no

tap

pro

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2018

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05/2

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05/2

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05/2

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06/2

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Slo

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09/2

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11/2

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09/2

017

11/2

017

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30

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ND

Pse

ntto

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istr

yof

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no

my

Slo

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a04

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705

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706

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706

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707

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710

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7S

pain

08/2

007

09/2

007

08/2

006

07/2

007

10/2

007

01/2

008

01/2

008

01/2

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Sw

eden

Uni

ted

Kin

gdom

(Nor

ther

nIr

elan

d)04

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705

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1 708

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708

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711

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711

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7

46of

63

AC

ER

—A

genc

yfo

rth

eC

oope

rati

onof

Ene

rgy

Reg

ulat

ors

Table

23

:D

eterm

in

atio

no

fin

vestm

en

tgaps

in

ND

Ps

Ev

alu

atio

nafter

an

Ou

tco

me

in

-d

ep

th

analysis

of

of

sy

stem

Evaluated

on

acase-b

y-case

No

of

Rep

ortin

gN

RA

the

in

frastru

ctu

re

and/or

basis

after

analysis

of

pro

ject

Ou

tco

me

of

an

econom

ic

test

(cap

acity

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51Ô

63


ANNEX III: Consistency of NDP I TYNDP Projects

1 Project Consistency check, background

Project consistency check. background

The NRAs were invited to crosscheck from 21 March until 1 6 April 201 8 the input data(project attributes) of the draft TYNDP 201 8 project candidates as submitted by the projectpromoters to ENTSOG, including the consistency with National Development Plans (NDPs).

The views and comments of the NRAs on the projects were communicated to ENTSOG “asreceived”, at a moment when the TYNDP 201 8 was at an early phase ofdevelopment with theaim of improving the quality of the input data for TYNDP 201 8 projects, and to help resolvepotential inconsistencies.

NRA Responses

The Agency received 22 completed questionnaires from NRAs:(1) 9 NRAs provided no comments/remarks on draft TYNDP 201 8 projects: Estonia,

Belgium, Bulgaria, Lithuania, Denmark, Malta, Latvia, Finland and Hungary.(2) 13 NRAs provided comments/remarks on TYNDP 201 8 projects: Luxembourg,

France, Slovenia, Spain, Portugal, United Kingdom (Northern Ireland), Germany,Czech Republic, Slovak Republic, Croatia, Austria, Italy. Regarding the type ofcomments37

0 9 NRAs provided project-specific comments and remarks on data items ofTYNDP 201 8 projects: France, Slovenia, Spain, Portugal, United Kingdom(Northern Ireland), Czech Republic, Croatia, Austria, Italy.

0 8 NRAs provided general comments and remarks on TYNDP 201 8 projects:Luxembourg38, Spain, United Kingdom (Northern Ireland), Germany, CzechRepublic, Slovak Republic, Italy, Greece.

The input ofNRAs collected in April 201 8 was communicated to ENTSOG without delay.

ENTSOG organised bilateral discussions among promoters and NRAs, seeking clarificationsand reconciliation of the input data39. The Agency was informed of the outcomes thediscussions only in a few cases.

Projects listed in the draft EU TYNDP 201 8 but not listed in the NDPs

Table 25 illustrates the cross-plan consistency oflisting by type ofassets. The table shows that75% of the projects included in the draft EU TYNDP are included in the NDPs. The rate ofcross-listing is slightly higher for transmission assets (77%) than for storage or LNG facilities(67%).

Table 26 and Figure 8 show the cross-listing of projects in the plans per country only in thegeographic perimeter of the EU-28. In 14 countries the consistency of project listings in the

37 Multiple choice question, both options (General and project-specific comments) were possible.38 Luxemburg replied to the survey but indicated that it does not have any gas projects with cross-borderimpact.39 For the 1 1 NRAs (France, Slovenia, Spain, Portugal, UK, Germany, Czech Republic, Slovak Republic,Austria, Luxemburg and Croatia) which give consent to send NRA staff contact data to project promoters.

52 of3


NDP and the TYNDP is complete (100%). Overall, the rate of per-country cross-listing ofprojects in the TYNDP and the NDPs is about 78% in the EU-28.

Table 25: Draft EU TYNDP 2018 projects present in NDPs, by type of assets

Not included in . % included inType of assetNDPs

Included in NDPs Total

LNG 9 18 27 67%TRA 38 130 168 77%UGS 4 8 12 67%Total 51 156 207 75%

Table 26: Draft EU TYNDP 2018 projects present in NDPs, by EU-28 countries

Not included Included inCountryNDPs NDP

Total Included in NDPs (percent)

Austria 4 4 100%Belgium 3 3 100%Bulgaria 1 9 10 90%Croatia 13 13 100%Cyprus 1 1 0%CzechRepublic 4 4 100%Denmark 2 2 0%Estonia 4 4 100%Finland 1 1 0%France 11 11 100%Germany 9 11 20 55%Greece 9 9 18 50%Hungary 8 8 100%Ireland 3 3 100%Italy 4 16 20 80%Latvia 3 3 0%Lithuania 1 2 3 67%Luxembourg 0 0 0 100%Malta 1 1 100%Netherlands 4 4 100%Poland 1 11 12 92%Portugal 4 4 100%Romania 4 8 12 67%Slovak Republic 6 6 100%Slovenia 6 6 100%Spain 4 7 11 64%Sweden 1 1 0%United Kingdom 1 3 4 75%TOTAL 42 147 189 78%

53 o63

ACER— Agency For the Cooperation— of Energy Regulators

Figure 8: NDP projects listed in the draft EU TYNDP 2018 (EU-28, percent)

0-24%

25 - 49%

. 50 - 74%

m -

. 95 - 100%

_ No

Projects with cross-border impact listed in NDPs but not listed in the draft EU TYNDP 2018

Table 27 and Figure 9 show that 7 projects with cross-border impact are included in NDPs,but are not listed in the draft EU TYNDP 201 8. The majority of these projects (6 out of 7) islocated in Germany and one in Slovenia.

Figure 9: Projects listed in NDP(s) but not listed in the draft EU TYNDP 2018

54 ô63

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