RGI response to the European Commission 'Collection of Feedback' on the revised TEN-E Regulation

The Renewables Grid Initiative (RGI) welcomes the proposal for the revision of the TEN-E Regulation and underlines some overarching principles which we believe should be taken into consideration in the development of energy infrastructure.

RGI appreciates the overall intention to align the network infrastructure with climate targets and welcomes the proposal for the revision of the TEN-E Regulation.

However, we would like to underline some overarching principles which we believe should be taken into consideration in the development of the energy infrastructure.

These can be found below, and the full consultation response can be downloaded at the end of this page.

Direct electrification is the most efficient way to fuel our economies and meet our needs. Electrification based on renewable energy sources will bring technological innovation, resilience in the system and incredible gains in terms of system and cost efficiency. With the support of the EU industrial strategy towards climate neutrality and digital leadership, new business models and European jobs will be created.

Electricity grids are needed. They are the backbone and enabler of a renewables-based energy system with the highest level of security of supply in the consumers’ interest. Highly distributed and efficient systems still need grids.

Flexibility is the most important element, and it comes in many different shapes and technologies. These are not interchangeable, and we must understand when and for which purpose they are needed. Learning and innovation here are essential as well as supporting market mechanisms.

• No single technology is the answer to decarbonisation. A whole ‘energy system approach’ is the most effective way to reduce emissions and identify optimisation opportunities through a variety of options and technologies among different sectors and for the existing energy infrastructure. The best solutions from a socio-economic welfare and environmental perspective should be selected to address the identified system needs. A clear assessment of carbon content of different energy carriers in different policies and scenarios needs to be conducted.

• If Europe is to reap the full potential of its renewable energy sources while ensuring security of supply and competitiveness, the achievement of the 2030 electricity interconnection target of at least 15% set in the Governance Regulation remains an essential building block to make the best use of variable renewable energy sources such as wind and solar, as long as the corresponding welfare benefits outweigh the costs incurred.

• In consideration of the new governance provisions envisaged by the proposal, the European Commission (EC) should ensure that efficiency in both planning and implementation processes are applied in order to reduce additional burdens, delays and unnecessary costs.

Nature and environment are the basis for human livelihood and economic activities. We are in a strong symbiosis with the environment in which we live. Avoiding and minimising impacts on biodiversity and embedding nature conservation and restoration measures in all infrastructure projects is key.

• The energy transition is first and foremost a deep societal transformation and therefore benefits for communities impacted need to be systematically created when deploying infrastructure projects. Local benefits can and should be designed in close collaboration with impacted communities.

In addition, in our full response, we addressed the new provisions envisaged by the EC proposal for a revised TEN-E Regulation such as PCI scope, sustainability, governance of the Ten-Year Network Development Plan, offshore developments, permit granting and public participation, Projects of Mutual Interest and cross-border cost allocations.

Our responses to the consultation and a detailed explanation on the above mentioned points can be downloaded through the below link. In case of any questions, please get in touch with cristina@renewables-grid.eu.


Cristina Simioli
Programme Manager - Offshore Energy and Nature

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t: +49 30 7677 194533

RGI gratefully acknowledges the EU LIFE funding support:

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Funded by the European Union. Views and opinions expressed are however those of the author(s) only and do not necessarily reflect those of the European Union or the LIFE Programme. Neither the European Union nor the granting authority can be held responsible for them.