Europaudvalget 2019-20
EUU Alm.del Bilag 878
Offentligt
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Danish
Government’s
response to the public consultation on regulation No
347/2013 re: guidelines for trans-European energy infrastructure (the "TEN-E
Regulation")
Danish key priorities for the TEN-E Regulation
Fully supports the objectives for the revision of the TEN-E Regulation, which
should ensure that all Projects of Common Interest (PCIs) actively contribute
to the decarbonisation of the EU energy system, consistent with climate
neutrality by 2050.
Priority should be on ways to absorb and convert the increasing amounts of
renewable power sources (RES) through transboundary electricity corridors
connecting low-cost RES-generation with load centres, strengthening
security of supply and enabling cross-border sector integration.
Future gas projects must be evaluated based on the energy and climate
ambitions, supporting only decarbonized gas and sector linkages such as
hydrogen and PtX-infrastructure.
Danish support for TEN-E
The Danish Government fully supports the revision of the TEN-E regulation, which
must address the new policy ambition of the European Green Deal and ensure that
the COVID19 recovery plan contributes to creating an enabling framework for the
decarbonisation of the EU energy system, consistent with climate neutrality by
2050. In this regard, it is essential that the TEN-E Regulation support sustainable
energy infrastructure investments that contribute to achieving our common climate
goals as economically efficiently as possible.
Positive experiences with TEN-E
There is a significant degree of consistency between the new European ambition to
be climate neutral by 2050 and Danish national energy policy, which has delivered
a very high security of energy supply through strong electricity and gas intercon-
nections with neighbouring countries.
Denmark has been a part of several Projects of Common Interest (PCI) since 2013.
In this way, the TEN-E Regulation with the PCI-nomination and Connecting Europe
Facility (CEF) support scheme has contributed to overcome key barriers and accel-
erate the development of European-wide energy infrastructure. In many cases, the
TEN-E Regulation has facilitated cross-border interoperability, communication and
coordination. This has been a catalyst for mobilisation of national and private in-
vestments in the power sector infrastructure.
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 EUU, Alm.del - 2019-20 - Bilag 878: Notat samt høringssvar vedrørende revision af forordningen om trans-europæiske energiinfrastruktur (TEN-E forordningen)
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Several of the completed PCI-projects have linkages to the challenge of integrating
renewables into the electricity system. In general, this is even more relevant today
than in 2013 when the existing TEN-E regulation entered into force. Thus, while the
TEN-E Regulation has been a positive contribution, there is a need to further
strengthen and guide the mechanism in order to ensure timely implementation of
PCIs, which interconnect the energy markets across Europe, thereby improving
RES-integration, energy efficiency, security of supply and competition.
Delivering on the European Green Deal through green power corridors
The Danish Government proposes to increase the benefits from further system in-
tegration by adding emphasis on ways to absorb and convert the increasing
amounts of RES power production.
Priority should be on transboundary power grids enabling further cross-border inte-
gration of low-cost RES-generation with load centres, strengthening security of sup-
ply and enabling cross-border sector integration. For example, by creating a green
power corridor connecting the planned offshore wind farms and next-generation en-
ergy islands in a Baltic Sea region with the Central / South Eastern power corridor.
The revised TEN-E Regulation should also enable sector integration with new tech-
nologies such as Power-to-X and coupling between energy sub-sectors, as well as
other sectors such as industry and agriculture.
Decarbonising the gas infrastructure
The Danish Government recognizes that the TEN-E Regulation has played a role in
securing a well-functioning gas market in the EU with a high level of supply. How-
ever, in order to achieve a climate neutral European Union by 2050 at the latest, fu-
ture infrastructure investments must focus on making renewables the backbone of
the energy system. Investments made under the revised TEN-E regulation will still
be fully functional in 2050 and in most cases for many years after this. It is there-
fore essential to ensure these investments are compatible with our climate goals.
Decarbonisation of the energy system, including the gas system, demands a long
perspective. Investments in fossil technologies, or infrastructure dedicated to these,
risks becoming stranded assets. The revised TEN-E Regulation should ensure that
future gas projects will be based on the energy and climate ambitions set out in the
Green Deal, supporting only decarbonized gas and sector linkages such as hydro-
gen and PtX-infrastructure.
Improving CBA methodology for selecting PCIs
The Cross Border Cost Allocation is today an integrated part of the cost-benefit
analysis (CBA) Methodology. Since ACER in December 2015 issued a recommen-
dation for good practices for CBCA calculation, valuable experiences have been
achieved. Ways to reduce the complexity of the CBA methodology and increase
transparency of the selection of PCIs should be examined.
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