currENT commends APG on an ambitious plan based on the assumption that 100% Renewables for electricity by 2030 and climate neutrality in Austria will be met in 2040. currENT agrees that only such a level of ambition can ensure that the objectives of the Paris Agreement are met. We also agree that the uneven regional distribution of RES generation leads to additional challenges for network planning and optimisation. 

We appreciate the opportunity to contribute, and we see such transparency as paramount for best possible NDPs, and for the buy-in of society on behalf of which and for whom the networks are developed. 

currENT proposes six key points for APG’s and E-Control’s consideration: 

1.  NOVA PRINCIPLE.

We welcome that grid development in Austria is based on the NOVA principle and have advocated for adopting similar NOVA approaches across Europe and other regions. We see, however, opportunities to improve the contents and the implementation of the NOVA principle in Austria, as well as in Germany. currENT believes that optimisation applies to existing AND future grids. This means that the first block in principle, ‘optimisation’, has to be seen as horizontal and also applying to the two others (reinforcement and expansion). This would translate into the optimisation of existing assets, optimised reinforcement, and optimised expansion. 

2. COMPLEMENTARITY OF OPTIMISATION, REINFORCEMENT AND NETWORK EXPANSION.

3.  BE TECHNOLOGY AGNOSTIC WHEN MENTIONING TECHNOLOGIES UNDER NOVA AND IN THE CONCRETE LOAD FLOW CONTROL MEASURES CEP-70 THAT ARE PROPOSED IN THE NDP.

currENT would like to see a more systematic approach to technology presentation under NOVA and the general reference to a toolbox of solutions that TSOs can use. We suggest that the NDP applies a transparent and systematic approach when it comes to listing available technology solutions. Hence, it should include an overview of available technologies, quoting relevant publications such as the ENTSO-E Technopedia or the CETTIR report by EC as released in November 2020 together with the State of the Union. 

4. THE DEVELOPMENT PLAN SHOULD ACKNOWLEDGE THE VALUE OF EARLY DELIVERY.

The NDP does not currently allow for the value of early delivery to be reflected in the value a project brings. In a plan where some projects will be late, and the exact sequence that will be built is not known, it is crucial that the value of early delivery is added to the methodology, and that the TSO toolbox includes such flexible and quick to deploy tools. Having additional capability is highly valuable for managing congestion and accelerating early renewable integration. 

5. EUROPEAN SOLUTIONS FOR EUROPEAN CHALLENGES.

Curtailment and price differentials in Europe’s power sector cannot be effectively, economically or efficiently addressed through national solutions alone. Thus, we suggest highlighting the contribution that the Austrian NDP makes to achieving the European objectives as developed with the Clean Energy Package and the Green Deal. 

6. UPDATE THE IMPLEMENTATION OF THE NOVA PRINCIPLE.

currENT recommends, in line with the Ecorys 2019 report to the Infrastructure Forum 2019, to: 

• Move towards an output-based approach – reduce bias towards specific technologies, or larger traditional CAPEX solutions only.
• Incentivise the use of smaller or rapidly deployable solutions, especially for short-term, temporary or smaller scale needs.
• Increase transparency and consultation in national processes.
• Accountability should be foreseen when grid optimisation solutions are delayed, that are explicitly considered in the NDP. The Smart Grid Indicator could be an appropriate reference here. 

See more detailed explanations in our full response here.