Response to ENTSO-E consultation on TYNDP 2022

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For this consultation we have decided to ask as few questions as possible, and instead to allow you to provide any comment you want. Please use the following free text fields to enter your comments.

Open Comments

Free Comments1

The long-term visibility of the TYNDP modelling should be improved. When selecting investment candidates at a given moment, the model has only limited degree of visibility on the evolution still required. TYNDP 2022 saw improvements in this approach by moving from a single time horizon approach to a multi-temporal approach. When selecting investment candidates at a given moment in time (eg: 2030), the plexos tool has a certain degree of visibility on the evolution still required (eg: increasing carbon price and electricity demand up to 2037). However, this is still not sufficient, and this must be improved.

Due to this limitation, the competitiveness of the different technologies and grid arrangements for meeting future requirements are not clear. Following examples could explain this limitation.

  • The role of long-term storage to absorb the renewable surplus could be undermined because the model would prioritize to expand interconnection capacities due to this limitation
  • Similarly, if a certain network requirement (say due to 3 GW capacity addition on a 38 kV system) is known now to be needed for a country by 2030, this could be accommodated with Demand Side Response and some network investments. However, if it is known now about the network requirements for a capacity addition of 10 GW on a 38 kV system by 2040, there is little likelihood of any normal investment or DSM being able to accommodate it and some more radical approach will be required. Probably, an efficient strategy would be to upgrade the 38 kV system to a 110 kV system. Having limited degree of visibility in the model will avoid such rational decisions. With the current network models, improving this visibility is possible.

Free Comments2

In the TYNDP scenario development and results, energy efficiency should be considered not just in energy end-use but also on total primary energy demand/supply. Total primary energy demand shows the use of total use of energy in its primary form before converting to electricity or other fuels or energy carriers. In the net zero scenarios there are significant energy losses resulting from the conversion of electricity into hydrogen and biomass into biomethane. Total primary energy demand includes the energy lost in those conversions and provides a more complete picture of the energy efficiency improvements in the scenarios.

Eurelectric would also like to highlight the need for strong involvement of DSOs in the TYNDP process. As the energy system is getting more decentralized with more renewable resources and flexibility resources connected to the distribution grid, there is an enhanced role for DSOs in shaping the whole energy sector. Following aspects will justify this enhanced role of DSOs

  • More and more distributed energy resource means activities of DSOs will significantly influence the shaping of the energy system.
  • DSOs will develop dedicated solutions for long-term sectoral plans
  • DSO’s grids, local balancing by DSOs, use of flexibility by DSOs will be key for the security of supply in the future.
  • DSOs are rightly placed to anticipate the risks and threats to the system
  • DSOs possess better knowledge, competences and basic data on the effective usage and operation of those resources

All these aspects above highlights the importance of engaging DSOs in the scenario building with a bottom-up approach and calls for an increased DSO-TSO cooperation in the TYNDP process.  At the same time, it is necessary to define the framework for this cooperation on a partnership basis that is not only for the benefit of both parties but for the system.

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