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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
ACERAgency for the Cooperationof Energy Regulators
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.
ACERAgency for the Cooperationof Energy Regulators
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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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.
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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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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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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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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.
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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.
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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.
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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.
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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%
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of Energy Regulators
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
ACERAgency for the Cooperationof Energy Regulators
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.
ACERAgency for the Cooperationof Energy Regulators
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.
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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.
ACER
— Agency for the Cooperationof Energy Regulators
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$Os are certified
. Independent TransmissionBulgariaOperator (ITO)
. . The process of TSO certification under the Full OwnershipCroatia Other circumstances . .
Unbundhng (OU) model is ongoing.. At the moment there is no gas or gas infrastructure in CyprusCyprus Other circumstances
and there is no TSO.Czech Independent Transmission
. CertifiedRepublic Operator (ITO). Full Ownership UnbundlingEstoma
(OU)Several models (in case of .. . GRTgaz is certified as an ITO.France several TSOs operating in , .
Terega (formerly TIGf) is certified as an OU.your Member_State)Several models (in case of
. . 15 out of 16 TSOs are certified. 13 operate under the ITOGermany several TSOs operating inmodel and 3 under the OU model.your Member_State)
DESFA S.A. is certified as Independent Transmission
GreecIndependent Transmission Operator (ITO) for gas, by RAE’s decision Nr.e
Operator (ITO) 523/25.9.2014, according to the provisions of Greek Law_________________________
4001/201 1, as amended.
28’ç63
S
Table 16: TSO unbundling model, country-specific replies by NRAs
ACER
Agency for the Cooperationof Energy Regulators
Reporting . . .
NRATSO unbundhng model -gas Information on certification of TSOs, other comments
Several models (in case ofHungary several TSOs operating in One of the two TSOs is OU and the other one is ITO
your Member_State)Full Ownership Unbundling Gas Networks Ireland (GM) has been certified as anIreland
(OU) ownership unbundled (OU) TSO.Several models (in case of
Italy several TSOs operating in All the Italian TSOs have been certified as either OU or ITO.your Member_State)
LatviaFull Ownership Unbundling Certification process is ongoing. Draft decision was sent to
(OU) the European Commission for assessment on 3 1 May 201$.. 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
ACER— Agency for the Cooperation
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
ACER— Agency for the Cooperation
of Energy Regulators
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
— Agency for the Cooperationof Energy Regulators
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
Agency for the Cooperationof Energy Regulators
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
— Agency for the Cooperationof Energy Regulators
Reporting TSO responsibilities in defining the NRA’s role in defining the NDP under nationalNRA NDP under national legislation legislation (Summary)
(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
Agency for the Cooperationof Energy Regulators
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
Reporting TSO responsibilities in defining the NRA’s role in defining the NDP under nationalNRA NDP under national legislation legislation (Summary)
(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
Agency for the Cooperationof Energy Regulators
Reporting TSO responsibilities in defining the NRA’s role in defining the NDP under nationalNRA NDP under national legislation legislation (Summary)
(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
Agency for the Cooperationof Energy Regulators
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$O shall consult the NDP. duty to change the NDP and shall monitor and
assess the implementation of the NDP.
Slovenia The TSO is not obliged to carry out all the The NRA must conduct a public consultation oninvestments listed in the ten-year NUP. the NDP and may require from the TSO to changeProjects that should be built in the next the NDP and/or the Investment Plan if it is not inthree years are listed in the Three-Year line with the public consultation results and/orInvestment Plan, which is attached to the methodology. The NRA’s consent on the NDPNDP and is confidential. The Investment includes also the consent on the Investment Plan.Plan contains detailed data and The realization of the projects must be reported ininformation on the projects and must be in the next Investment Plan.line with the methodology issued by theNRA.
Spain All TSOs participate in the NDP The NDP is approved by the Government. Thedevelopment by proposing investments regulator only provides the Ministry of Energythat they consider necessary to attend the with its opinion via a non-binding report.demand in their zone of influence. TheNDP is designed by the Technical SystemManager (Enagás GTS), taking intoaccount projects proposed by TSOs,
___________
network users and other Stakeholders.
Sweden Not applicable Not applicable
United The TSOs create the plan based on The NRA monitors the development of the NDPKingdom existing and forecast supply and demand. and publishes the results. It is prepared by the ISO(Northern This is done with a view to highlight to and the process is set out in the network codes ofIreland) market participants, any infrastructure the TSOs.
that needs upgraded over the next tenyears. The TSOs consult with shippersand the NRA as part of this process.
37 o63
ACER
— Agency for the Cooperationof Energy Regulators
Reporting T$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
ACERAgency for the Cooperationof Energy Regulators
Figure 7: Most recent NDPs by year of publication
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ER
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the
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pera
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nerg
yR
egul
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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
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cati
onof
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proj
ects
.G
reec
eT
here
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clas
sifi
cati
onac
cord
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atur
ity
and/
orur
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ycr
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ra
new
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ect
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e,x
ther
eis
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eG
asN
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ork
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rtic
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isio
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evel
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ent
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)to
allo
wfo
rth
eim
med
iate
exec
utio
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nur
gent
proj
ect.
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gary
XIr
elan
dX
- Ital
yx
Lat
via
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ithu
ania
XT
heT
SOha
sto
indi
cate
the
com
mis
sion
ing
date
ofth
esp
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men
tpro
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iter
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ecif
ied.
rg Mal
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and
Due
toth
ela
rge
num
ber
ofin
vest
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t pro
ject
s,as
afi
rst
step
the
TSO
clas
sifi
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ojec
tsin
toth
ree
grou
ps:
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(Loa
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elat
edE
xpen
ditu
re),
NL
RE
(Non
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dR
elat
edE
xpen
ditu
re)
and
RN
I(o
ther
/add
itio
nal
inve
stm
ents
not
43
äç
AC
ER
—A
genc
yfo
rth
eC
oope
rati
onof
Ene
rgy
Reg
ulat
ors
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ort
ing
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ther
NR
AM
atu
rity
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ency
crit
eria
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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
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pply
thro
ugh
the
cons
truc
tion
ofne
wel
emen
tsof
the
tran
smis
sion
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ork.
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grou
pN
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ojec
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ntai
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vest
men
tscl
assi
fied
asin
vest
men
tsin
tran
smis
sion
infr
astr
uctu
rew
hich
are
not
asso
ciat
edw
ith
anin
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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
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tth
ene
xtst
ep,
the
TSO
clas
sifi
esth
epr
ojec
tsin
clud
edin
togr
oup
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tosu
b-gr
oups
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ted
wit
hin
fras
truc
ture
item
s,i.e
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stem
pipe
lines
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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.
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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
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illi
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loty
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dot
her
inve
stm
ents
are
liste
din
aggr
egat
edite
ms
wit
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nam
es.
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TSO
rank
sth
ein
vest
men
tsde
pend
ing
onth
eir
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rtan
ce,
impa
cts
and
expe
cted
cont
ribu
tion
s(b
enef
its).
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tuga
lx
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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
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iter
iaac
cord
ing
toR
egul
atio
n99
4/20
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and
toec
onom
iccr
iter
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.g.
tari
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s).
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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
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ain
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wed
enX
Not
appl
icab
le,
noN
DP.
Uni
ted
The
ND
Pre
port
son
the
inve
stm
ent p
roje
cts
unde
rway
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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
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ual
Ene
rgy
to(N
orth
ern
Xun
dert
ake
this
deve
lopm
ent.
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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
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hen
we
fore
cast
dem
and
we
cons
ider
ifan
yne
wga
sor
elec
tric
ity
gene
rati
onis
like
lyin
the
peri
od.
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ted
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pin
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706
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707
/201
710
/201
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
008
05/2
008
Sw
eden
Uni
ted
Kin
gdom
(Nor
ther
nIr
elan
d)04
/201
705
/20
1 708
/201
708
/201
711
/201
711
/201
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
au
ctio
ns,
approaches
need
s(top-dow
nm
arket
candidates
(bottom
-up
mark
et
co
nsu
ltatio
ns,
sh
ip
pers’
dem
and)
used
ap
pro
ach
)m
od
ellin
g
approach)
Austria
XX
X
Belgium
xX
x3
Bulgaria
XX
Croatia
XX
2
Cypm
sX
2
Czech
Republic
X
Estonia
1
xF
ranc
e-
xG
enan
yX
x2
Gre
ece
Xx
2H
unga
ryX
Irel
and
XX
XX
4It
aly
Xx
2L
atvi
aX
Lit
huan
iaI_
_____
x1
Lux
embo
urg
XM
alta
XX
XX
1
Pol
and
4x
Por
tuga
lX
Rom
ania
Ix
Slo
vak
Rep
ubli
cI_
____
xS
love
nia
XX
x3
Spa
inX
Sw
eden
XU
nite
dK
ingd
om(N
oih
em1
Irel
and)
x1
Uni
ted
Kin
gdom
XX
X3
Tot
al13
1111
10
\
47
AC
ER
Age
ncy
for
the
Cooper
atio
nof
Ene
rgy
Reg
ulat
ors
Tab
le24
:N
DP
anal
yti
cal
met
hodolo
gy
ND
Pin
clud
es(u
ses)
esti
mat
eof
the
foll
owin
g_co
stit
ems
SoS
Use
ofU
seof
..
Com
men
tsif
“yes
‘to
.In
form
atio
non
the
netw
ork-
flow
econ
omic
Rep
ort
ing
NR
Am
arket
net
wo
rkm
odel
sof
the
TS
Os
and
sim
ulat
ions
Inve
stm
ent
Op
erat
ioN
DP
does
not
eval
uati
onSo
Sec
onom
icev
alua
tion
stud
ies
stud
ies
cost
sna
lco
sts
incl
ude
cost
36.
i5se
lect
ed(C
AP
EX
)(O
PE
X)
info
rmat
ion
Aus
tria
Yes
No
xx
No
TS
Oha
vea
netw
ork
sim
ulat
ion
mod
el(S
irno
ne)
for
inve
stm
ents
and
capa
city
offe
rs.
Not
rele
vant
..
For
man
yye
ars
now
none
wM
atur
esy
stem
.B
elgi
umY
esY
es.
xN
o.
.
bott
lene
cks
have
been
dete
cted
whi
chD
ecar
boni
sati
onis
the
wou
ldre
quir
ein
vest
men
tsto
incr
ease
grow
ing
conc
ern.
capa
city
atIP
s.M
atur
esy
stem
.
Bul
gari
aY
esY
esx
No
Net
wor
kfl
owm
odel
so
fth
eIS
Oar
edo
neby
hydr
auli
csi
mul
atio
nsba
sed
onC
roat
iaN
oY
esdi
ffer
ent
scen
ario
sta
king
into
acco
unt
xN
oth
ede
velo
pmen
to
fth
esi
gnif
ican
tin
fras
truc
ture
proj
ects
.
Cyp
rus
No
No
xN
on/
a
.E
RU
does
not
have
such
mod
elan
dC
zech
Rep
ubli
cY
esY
es.
..
xN
ous
essc
enan
osat
itsdi
spos
al.
.N
otab
leto
Est
oma
No
No
xas
sess
Fra
nce
Yes
Yes
xN
o
The
TS
Os
use
diff
eren
tne
twor
kfl
owG
erm
any
Yes
Yes
xN
om
odel
s.
34M
arket
stu
die
sca
rrie
do
ut
cover
ing
pro
ject
ions
of
gas
mar
ket
fun
dam
enta
ld
ata
(su
pp
lies
,d
eman
d,
pea
kd
eman
dca
pac
ity).
35N
etw
ork
stu
die
s(h
ydra
uli
csi
mula
tions)
carr
ied
ou
tco
ver
ing
the
abil
ity
of
the
net
work
toco
ver
stre
ssIh
igh
dem
and
situ
atio
ns.
36E
con
om
icval
uat
ion
of
gas
lost
load
(Vo
LL
)du
eto
pote
nti
alsu
pply
dis
rupti
ons.
\ 48à63
AC
ER
Age
ncy
for
the
Coo
pera
tion
ofE
nerg
yR
egul
ator
s
ND
Pin
clud
es(u
ses)
esti
mat
eof
the
foll
owin
gco
stit
ems
Use
ofU
seof
.
SoS
Com
men
tsif
“yes
”to
Info
rmat
ion
onth
ene
twor
k-fl
owec
onom
icR
epo
rtin
gN
RA
mar
ket
net
work
mod
els
ofth
eT
SO
san
dsi
mul
atio
nsIn
ves
tmen
tO
per
atio
ND
Pdo
esno
tev
alua
tion
econ
omic
eval
uati
onst
udie
sst
udie
sco
sts
nal
cost
sin
clud
eco
st36
.se
lect
ed(C
AP
EX
)(O
PE
X)
info
rmat
ion
Gre
ece
Yes
Yes
xN
o
..
Not
able
toH
unga
ryY
esY
esSi
rnon
em
odel
ling
tool
x__
____
____
____
___
asse
ssN
etw
ork
anal
ysis
was
carr
ied
out
usin
ghy
drau
lic
netw
ork
mod
elli
ngso
ftw
are
(Pip
elin
eSt
udio
).A
sing
lehy
drau
lic
mod
elo
f the
Inte
rcon
nect
oran
dR
OT
tran
smis
sion
syst
ems
was
cons
truc
ted
usin
gP
ipel
ine
Stud
io.
Thi
ssi
mul
atio
nso
ftw
are
was
conf
igur
edto
anal
yse
the
Irel
and
Yes
Yes
tran
sien
t24
hour
dem
and
cycl
eov
era
xN
om
inim
umpe
riod
ofth
ree
days
toob
tain
cons
iste
ntst
eady
resu
lts.
Inor
der
toas
sess
the
syst
emon
days
ofdi
ffer
ent
dem
and
patt
ern,
thre
ede
man
dda
yty
pes
wer
ean
alys
edfo
rea
chsu
pply
scen
ario
over
a1 0
year
peri
odto
2025
/26,
(fro
mN
o(u
pto
Ital
yY
esN
ox
2018
)20
17)
Inth
eJo
int
Ris
kA
sses
smen
to
fth
eSo
Sev
alua
tion
isca
rrie
dse
curi
tyof
gas
supp
lyo
fth
eE
urop
ean
out
inth
eJo
int
Ris
kU
nion
Mem
ber
Stat
eso
fE
ston
ia,
Ass
essm
ent
oft
hese
curi
tyF
inla
nd,
Lat
via
and
Lit
huan
iapr
epar
edof
gas
supp
lyoft
heby
Dir
ecto
rate
Gen
eral
Join
tR
esea
rch
Eur
opea
nU
nion
Mem
ber
Lat
via
Yes
Yes
x-
.
Cen
tre
(DG
JRC
)o
fth
eE
urop
ean
Sta
tes
ofE
stor
na,
Fin
land
,C
omm
issi
onin
2016
byus
ing
and
Lat
via
and
Lit
huan
iaim
prov
ing
ahy
drau
lic
mod
elo
fth
epr
epar
edby
DG
JRC
oft
here
gion
that
ispa
rtof
the
EU
Gas
proj
ect
Eur
opea
nC
omm
issi
onin
(Zac
care
lli
etal
.20
14).
2016
.N
CC
appr
oves
the
ND
Pas
Lit
huan
iaN
oN
ox
xN
oa
stra
tegi
cdo
cum
ent.
49
AC
ER
Age
ncy
for
the
Coo
pera
tion
ofE
nerg
yR
egul
ator
s
ND
Pin
clud
es(u
ses)
esti
mat
eof
the
follo
win
g_co
st_i
tem
sSo
S.
Use
ofU
seof
..
Com
men
ts,
if“y
esto
.In
form
atio
non
the
netw
ork-
flow
econ
omic
.R
eport
ing
NR
Am
arket
net
work
mod
els
ofth
eT
$Os
and
sim
ulat
ions
Inve
stm
ent
Op
erat
loN
DP
does
not
eval
uati
onSo
Sec
onom
icev
alua
tion
stud
ies
stud
ies
cost
sna
lco
sts
incl
ude
cost
36.
i5se
lect
ed(C
AP
EX
)(O
PE
X)
info
rmat
ion
How
ever
,N
RA
’sap
prov
alof
the
ND
Pdo
esno
tm
ean
the
appr
oval
oft
heco
ncre
tepr
ojec
ts.
CB
Ais
prov
ided
duri
ngth
ein
divi
dual
appr
oval
proc
ess
of p
roje
cts.
Lux
embo
urg
No
No
xN
o
Mal
taY
esY
es-
--
-
NR
Aev
alua
tion
isba
sed
onth
eT
SO
sN
otab
leto
Pol
and
Yes
Yes
xst
atem
ent
and
sour
cedo
cum
ents
.as
sess
The
netw
ork
stud
ies
used
inth
isP
ortu
gal
No
Yes
situ
atio
nar
eon
lyon
stat
icsy
stem
xN
ore
gim
e.
Rom
ania
Yes
Yes
xN
o
Slo
vak
Rep
ubli
cY
esY
esx
No
onth
ere
ques
to
fth
eN
RA
,th
eT
SO
.m
ust
subm
ithy
drau
lic
sim
ulat
ions
for
Slo
veni
aY
esY
es.
..
..
xN
oth
ein
divi
dual
proj
ect
inor
der
topr
ove
the
elig
ibil
ity
oft
he
proj
ect.
The
Tec
hnic
alS
yste
mM
anag
erus
esan
Spa
inN
oY
esac
know
ledg
edco
mm
erci
alhy
drau
lic
xN
oto
ol.
Sw
eden
Yes
Yes
--
-N
o
Uni
ted
Kin
gdom
Ahy
drau
lic
mod
elo
fth
eN
I(N
orth
ern
Yes
Yes
tran
smis
sion
syst
emw
asco
nstr
ucte
dx
No
Irel
and)
whi
chal
low
sth
eus
erto
conf
igur
ean
d
5O.Q
1f63
AC
ER
Age
ncy
for
the
Cooper
atio
nof
Ene
rgy
Reg
ulat
ors
ND
Pin
clud
es(u
ses)
esti
mat
eof
the
foll
owin
g_co
stit
ems
SoS
Use
ofU
seof
Com
men
ts,
if“y
es”
toIn
form
atio
non
the
netw
ork-
flow
econ
omic
Rep
ort
ing
NR
Am
arket
net
work
Inve
stm
ent
Op
erat
ioN
DP
does
not
eval
uati
onec
onom
icev
alua
tion
mod
els
ofth
eT
SO
san
dsi
mul
atio
nsst
udie
s34
stud
ies3
5co
sts
nal
cost
sin
clud
eco
st36
.15
sele
cted
(CA
PE
X)
(OP
EX
)in
form
atio
n
anal
yse
the
dem
and
onth
ene
twor
kfo
ra
num
ber
ofsc
enar
ios.
Nat
iona
lG
rid
use
netw
ork
mod
elli
ngso
ftw
are
call
edS
imon
ew
hich
isU
nite
dK
ingd
omY
esY
espr
oduc
edby
Liw
acom
.N
atio
nal
Gri
d-
--
No
run
both
stea
dyst
ate
and
tran
sien
tsc
enar
ios.
51Ô
63
ACERAgency for the Cooperationof Energy Regulators
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
ACERAgency for the Cooperationof Energy Regulators
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
.1
AC
ER
—A
genc
yfo
rth
eC
oope
rati
onof
Ene
rgy
Reg
ulat
ors
Table
27
:N
DP
pro
jects
with
cross-border
im
pact
which
are
not
listed
in
the
draft
EU
TY
ND
P2018
.R
eference
Natio
nal
Ty
pe
(h
ig
hp
ressu
re
Rep
ortin
g.
..
..
Co
de
in
.E
xpected
date
of
NR
A(*
)D
evelopm
ent
Plan
tran
sm
issio
np
ip
elin
es,
UG
$,
Project
nam
e
ND
P
Project
pro
mo
ter
co
mm
issio
nin
g(N
DP
),year
LN
Gterm
in
al)
.M
MR
PR
ogat
ec-
.
Slo
vern
a20
1 8R
ever
sefl
owat
SI-
HR
IPC
1 6P
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vodi
2018
upgr
ade
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efl
ow
GR
Tga
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erm
any
2016
VD
$R
othe
nsta
dt26
-6(5
5.04
%)
IO
GE
12/2
018
(44.
96%
)R
ever
sier
ung
Wes
t-O
stG
RT
gazD
Ger
man
y20
16M
EG
AL
VD
S30
4-1
(55.1
4%
)/O
GE
12/2
018
Wai
dhau
s(4
4.86
%)
GR
Tga
zDG
erm
any
2016
VD
SM
EG
AL
Rim
par
309-
1(5
5.0
4%
)/O
GE
12/2
020
(44.
96%
)G
RT
gazD
Ger
man
y20
1 6V
DS
ME
GA
LR
impa
r3
12-1
(55.
04%
)/
OG
E12
/202
3(4
4.96
%)
007-
Ger
man
y20
16V
DS
Qua
mst
edt
(neu
)01
/009
-G
UD
12/2
016
Ger
man
y20
1 6H
ipr
essu
repi
peli
neT
EN
P4
GA
SC
E12
/202
4
NR
Aco
mm
en
ts
on
project
data
cons
iste
ncy
(dra
fiT
YN
DP
201
8pr
ojec
ts)
InA
pril
201
8,22
NR
As
prov
ided
com
men
tsfo
r33
outo
f207
proj
ects
incl
uded
inth
edr
aftE
UT
YN
DP
201
8(c
f.T
able
28).
9N
RA
s(F
ranc
e,S
love
nia,
Spa
in,
Por
tuga
l,U
nite
dK
ingd
om(N
orth
ern
Irel
and)
,C
zech
Rep
ubli
c,C
roat
ia,
Aus
tria
,It
aly)
had
com
men
tson
the
cons
iste
ncy
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