Submission to Consultation on the Ten Year Network Development Plan (TYNDP) 2022 – Draft Scenario Report

Energy transition

CAN Europe responds to the consultation on the draft scenario report for the Ten Year Network Development Plan (TYNDP) 2022. This masterplan of European energy infrastructure planning is prepared every two years by the European transmission system operators for electricity and for gas, ENTSO-E and ENTSOG.

Although CAN Europe generally welcomes the openness as well as the high level of transparency of the stakeholder engagement process, we have to highlight specific hurdles of non-profit civil society organisations such as CAN Europe in view of contributing to the process. The limited capacities within our membership make it difficult to provide detailed expertise at every step of the scenario building process. In contrast with stakeholders from the industry, CAN Europe is not dealing with the technicalities of planning electricity transmission networks and gas transmission networks on a daily base.

In order to allow for civil society organisations to engage more proactively in this debate, ENTSOs have already made important progress. We would like to reiterate our suggestions to offer introductory webinars for stakeholders that are entering the scene. It also would help to provide more regular updates about the progress of the TYNDP scenario building, for instance through the ENTSOs’ newsletters. In addition, we suggest to publish clear timelines of the TYNDP process to allow for timely preparation and engagement of our member organisations. The Scenario Building Guidelines document goes into the direction of the manual that we have requested at the occasion of previous consultations.

While we understand that ENTSOs increased their direct exchange with industry groups to improve the scenario building on district heat, hydrogen and other areas, we would have seen this exercise as an opportunity to run a peer-reviewed process with independent researchers. Although the technical knowledge of industry federations is valuable, such input could have further increased the impartial character of the TYNDP scenario building process.