The document outlines the position of the Council of European Energy Regulators (CEER) regarding the European Commission’s proposals forming the European Grids Package. The package includes legislative proposals aimed at accelerating permitting procedures for energy infrastructure and revising the Trans-European Networks for Energy (TEN-E) framework. CEER welcomes the initiative as an important step toward strengthening the integration, resilience and sustainability of Europe’s energy infrastructure while emphasising that new provisions should remain coherent with the existing regulatory framework.
Energy transition and infrastructure challenges
Europe’s energy transition requires significant changes in the structure of the energy system. Achieving greenhouse-gas reduction targets requires increasing the share of renewable energy while replacing part of fossil fuel consumption with electricity. This transformation introduces greater variability in electricity production and therefore requires more flexible and resilient energy networks.
CEER highlights the importance of considering interactions between different energy carriers such as electricity, natural gas and hydrogen. Despite the ongoing decarbonisation process, natural gas continues to play an important role in the European energy system, particularly in providing flexibility and ensuring security of supply. At the same time, the future development of hydrogen remains uncertain and may require very large investments.
Infrastructure planning is therefore a complex task involving technological considerations, supply-chain constraints and the integration of new assets into existing energy networks. Planning must also be dynamic and capable of adapting to evolving demand patterns and technological progress.
Role of National Regulatory Authorities
CEER stresses the crucial role of National Regulatory Authorities (NRAs) in energy infrastructure development. These authorities have extensive experience in analysing investment plans, evaluating cost estimations and overseeing infrastructure development processes.
The organisation welcomes the strengthening of NRA responsibilities proposed in the new legislation, particularly the power to approve or amend national network development plans. This enhanced oversight is expected to improve transparency and ensure that infrastructure investments are economically justified.
However, CEER also emphasises that additional responsibilities must be accompanied by sufficient financial and human resources to allow regulators to effectively perform their tasks.
Role of ACER and European coordination
The document also discusses the role of the Agency for the Cooperation of Energy Regulators (ACER). CEER welcomes the proposal to grant ACER additional responsibilities, including developing methodologies for identifying infrastructure needs and updating rules on congestion revenue usage.
At the same time, CEER stresses the importance of maintaining the involvement of the ACER Board of Regulators in these processes in order to ensure transparency, consistency and accountability.
Network planning and scenario development
One of the central topics in the document concerns the use of scenarios for network planning. The European Commission proposes developing a central scenario reflecting EU energy policy objectives.
CEER acknowledges the value of such a scenario for long-term planning but argues that relying exclusively on a single scenario could be problematic due to uncertainties regarding technological developments, energy demand and the future role of hydrogen.
Therefore, CEER recommends systematically using multiple scenarios and sensitivity analyses. This approach allows infrastructure planners to identify projects that remain beneficial under a wide range of possible future developments.
CEER also suggests that scenario analyses should be updated more frequently, ideally every two years, in order to reflect rapidly evolving market conditions and policy changes.
Identifying infrastructure needs
The European Commission proposes identifying infrastructure needs by comparing scenario-based simulations with proposed infrastructure projects.
CEER emphasises that this process should be complemented by detailed technical and economic analysis. Infrastructure planning should not rely solely on simplified modelling of the European energy system.
Moreover, the organisation recommends conducting infrastructure needs assessments more frequently to keep pace with developments in the energy sector.
Cost-benefit analysis methodologies
Cost-benefit analysis methodologies are essential tools for evaluating the value of infrastructure projects. CEER argues that these methodologies should remain flexible enough to reflect the specific characteristics of individual projects.
The organisation recommends that ACER and national regulators play a leading role in approving and updating these methodologies due to their technical expertise.
Cross-border cost allocation
The document also addresses the issue of allocating costs for cross-border infrastructure projects between Member States.
CEER warns that evaluating projects based only on a single central scenario could lead to inefficient investment decisions. Instead, multiple scenarios should be used to ensure that projects remain economically viable under different possible futures.
Congestion revenues
CEER expresses concerns about proposals to collect and redistribute congestion revenues for infrastructure investment purposes at EU level.
According to the organisation, such a mechanism could lead to inefficient allocation of resources and weaken incentives for efficient congestion management within electricity markets.
Permitting procedures
CEER considers the proposed timeframe for permitting procedures of infrastructure projects to be appropriate. However, the organisation warns that mandatory tacit approval mechanisms could undermine legal certainty and potentially delay projects due to increased appeals.
Conclusion
CEER concludes that the European Grids Package represents a timely opportunity to strengthen Europe’s energy infrastructure in support of decarbonisation and electrification. For the package to succeed, it must be grounded in realistic technical and economic analysis, recognise the role of multiple energy carriers and ensure strong involvement of national regulatory authorities.
The organisation expresses its readiness to cooperate with EU institutions and ACER in shaping legislation that supports efficient investments, cross-border infrastructure development and the creation of an integrated and secure European energy system.
