With this feedback to the proposals of the European Network of Transmission System Operators for Electricity (ENTSO-E) and for Gas (ENTSOG) for the Ten Year Network Development Plan (TYNDP) 2024, CAN Europe would like to raise its concerns about the compatibility of the scenarios for European energy infrastructure with the Paris Agreement. While we acknowledge some progress in transparency and variation of the scenarios, we still see room for improvements to better prepare our networks for an accelerated energy transition.

According to our understanding, the suggested storylines (‘Decentralised Energy’ and ‘Global Ambition’) can only be considered as preliminary because the design of future scenarios under the TYNDP will have to be aligned to the overarching principles of the upcoming Scenario Guideline by the European Union’s Agency for the Cooperation of Energy Regulators (ACER), expected in January 2023.

For CAN Europe, it is self-evident that all TYNDP scenarios need to show pathways towards the Paris Agreement‘s objective of limiting average global temperature increase to 1.5°C. While the storyline matrix presented by the ENTSOs on 20 July 2022 claims to be fully in line with the EU’s 2030 targets and its 2050 climate neutrality objective, we fear that these scenarios again imply overshooting the (very generous) carbon budget allocated.

By allowing too high greenhouse gas emissions before 2050, the TYNDP scenarios would only theoretically respect the Paris Agreement’s 1.5°C threshold if disproportionately strong emissions reductions and carbon removals come into play very quickly after 2050. The scenarios then would bet again on the quick roll-out of carbon removal technologies such as Direct Air Capture, Carbon Capture and Storage (CCS) and bioenergy with CCS whose readiness and availability remains questionable.