About unexplainable discontinuities and contradictions between the governmental and administrative levels in the European Union and Federal Republic of Germany

Script of a speech about unexplainable discontinuities and contradictions between the governmental and administrative levels in the European Union and Federal Republic of Germany concerning energy policies and the development of energy union esp. further transmission interconnections.

There are clear discrepancies to observe between the levels EU-FRG (probably any national ones) concerning methodologies, objects of evaluation, suggested technologies, data selection, argumentation and future prognosis about the European policy for electric energy supply. To point this out is objective of this exercise. My comments, thoughts and trolling is held in italic / cursive.

  • Energy transition, grid development, who’s got still any understanding or fundamental knowledge?
  • Are there real needs for that?
  • What’s the benefit – and what sense does it make?
  • Where is the request coming from?
  • Where the trip goes to?
  • Where should it go to?
What to point out?
  • Orga-Foo – Who’s in charge, for which topic, on EU-level, on national level? – critical diction or wording
  • Power in English addresses both, the electric energy (= physical work in kWh,) as well as the electric performance (in W, KW, MW, GW…), while differently used in German without real understanding the difference.
  • Capacity addresses both in German and English: The energetic yield of a storage or tank, and the delivered power in KW as well.
  • Transmission is understood as transport of performance, while only the physical energy really can be transported. Performance can not be transported, just shifted by a prolongation cable. Everybody on the energy stage should be aware of that.
  • Goals – What are different stakeholder’s objectives? What’s in common / What is different? TYNDP and German Scenario Frame Draft comparison.
  • NN tells when there is no statement to the topic.
Who’s in charge?
  • 1. ENTSO-E vs. BNetzA und ACER VS NRA oder Regulierungsbehörde
  • 2. TSOs / DSOs VS ÜNB / VNB
  • 3. EC / EP VS Regierungen / regionale Parlamente
  • 4. RSC – Regional Security Coordinators / Regionale Sicherheitskoordinatoren VS NN
  • 5. BEUC – Bureau Européen des Unions de Consommateur / Europäischer Verbraucherverband VS NN

2. Goals

Findings in TYNDP 2016

  • 1. … achieve Europe’s climate objectives (TYNDP exec. 2016 p. 3) … VS NN
  • 2. Shift of large quantities RES (TYNDP exec. 2016 p. 3, 6) … VS NN
  • 3. 80% Emission cut off in 2030 (TYNDP exec. p. 3) VS … will be given the accompanying constraint, that the German generation park will release a maximum of 165 Million tons of CO2 by 2030 (2035 137 Mi. to / SRE p. 4,5, 74, 75,) and a reduction of Green-House-Gas (GHG)-Emissions compared to 1990 to 2020 of 40% and till 2030 of 55%. (SRE p. 70) / § 1 EEG-E 2016: 40% to 45% till 2025 / 55% to 60% till 2035 / a minimum of 80% till 2050. This growth might be realized steadily, cost-efficient and grid-suitable.  (SRE p. 80)
  • 4. Minimum 27% RES penetration (TYNDP exec. p. 5) VS RES-increasing level in article § 1 Abs. 2 EEG-E 2016 (SRE p. 70)
  • 5. Minimum 27% energy savings ((TYNDP exec. p. 3) VS Primary energy consumption cut down between 2008 and 2020 by 20% (SRE p. 5)
  • 6. Congestion reduction of 40% (TYNDP exec. p. 15) VS Existing and forecasted prognosis for congestion cases are to be avoided, mainly to enable the system to integrate the whole energy “produced“ by generators and to transfer it. (SRE p. 77)
  • 7. 2030 Future market design and operation are still to be invented (TYNDP exec. p. 32) VS The actual legal and regulatory framework sets the basic rules and conditions for the, scenario development, because the development of the legal fundament till 2030 or 2035 is as unforeseeable as market prices or the spread of new technologies (SRE p. 73).
  • 8. Security of Supply (= SoS / (TYNDP exec. p. 36, 41) VS the task of NEP basically is basically to plan a grid that can work without expensive re-dispatch efforts (SRE p. 86).
  • 9. Grid development is the core instrument to achieve the energy union objectives VS the BnetzA furthermore conceives that the national economic optimum is based in a German-wide or probably pan-European energy market. The grid serves to realize this market (SRE p. 97).
  • 10. TYNDP 2016 operates with a wider scope: It delivers a transparent picture of the European transmission grid for electricity. VS NN denial of transparency and public access by §12 f ENWG.
  • 11. A push on infrastructure investment with a plus in local generation, storage and demand side response (TYNDP exec. p. 43) VS NN

Findings in Annual Work Programme 2018  SRE

  • 12. Cope of global challenges the world is confronted with: global warming, economic competitiveness and security of supply ((AWP p. 4) VS objectives to be ensured: SoS and environmental issues threatened by to small dimensioned grids (SRE p. 78)
  • 13. fulfill ECs message: Clean energy for all Europeans, November 2016, (AWP p. 7) VS NN
  • 14. Sustainability, SoS, competitiveness and societal welfare (AWP p. 8) VS NN
  • 15. 23 countries in a common day-ahead-market (AWP p. 8) VS the BnetzA furthermore conceives that the national economic optimum is based in a Germany-wide or probably pan-European energy market. The grid serves to realize this market (SRE p. 97).
  • 16. Integration of 260 GW PV & Wind (AWP p. 8) VS EEG objectives
  • 17. 11 GW Demand side response (AWP p. 8) VS NN
  • 18. Maintain SoS – means that it exists (AWP p. 8) VS SoS in single regions even with increasing local RES generation without grid enforcement cannot be guaranteed (SRE p. 97)
  • 19. 1 billion € improvement of societal welfare (AWP p. 8) VS NN
  • 20. ± 120 TWh energy exchange / year (AWP p. 8) VS NN
  • 21. Implementation of a single common European Energy Market (AWP p. 10) VS the BnetzA furthermore conceives that the national economic optimum is based in a German-wide or probably pan-European energy market. The grid serves to realize this market (SRE p. 97)
  • 22. Will lead to a clearly more efficient European market provide benefits for the customers (AWP p. 10) VS NN
  • 23. Customers integration as active market participants (AWP p. 17) VS NN
  • 24. Interconnectivity target for 2030 15% (AWP p. 17) VS NN
  • 25. sustainable energy transition (AWP p. 17) VS NN
  • 26. distributed generation (AWP p. 17) VS NN
  • 27. Global action for Climate (AWP p. 17) VS NN
  • 28. Clear objective is to transform the European energy system in integrated one (AWP p. 20) VS NN
  • 29. Highlighting flexibility, storage and end-to-end-digitalization to integrate the very different technologies and services in the market (AWP p. 20) VS NN
  • 30. ENTSO-E will define a European electricity market model relying on Regulations and Guidelines for the complete grid (AWP p. 26) VS NN
  • 31. BEUC takes care to ensure from the very beginning an exchange with end-customers, to enable their Input on issues concerning them and to prevent them being driven to the end of the whole design process of regulations and guidelines (AWP p. 40) VS NN
  • 32. Cross-border trade increase in day-ahead and intraday-timeframes. (AWP p. 10) VS the BnetzA furthermore conceives that the national economic optimum is based in a German-wide or probably pan-European energy market. The grid serves to realize this market (SRE p. 97)
  • 3. Means: which means are implemented?
  • 1. Transmission (TYNDP exec. p. 3, 43, 45, ff) VS Transmission (2) ÜNB are obliged to determine the needed transmission capacity based on the approved amount of installed generation performance (No. 1) by market simulations for scenarios B 2030 and C 2030 … (SRE p. 5) – (conflict EU-D programmed)
  • 2. Storage (TYNDP exec. p. 3, 43, 45, ff.) VS in the scenarios for first time additional different values for drivers regarding sector coupling, flexibility options and local storage are implemented p. 70; … flexibility option and storage: (SRE p. 88); … But missing storage technologies who are able to… (SRE p. 97)… (storage in German policy still is NO option)
  • 3. Demand side Management (TYNDP exec. S. 3, 6) VS two „understandings“ of „Demand Side Management“: Cut off power, shut down consumer production or power shift: Shut down generation: temporarily „cut off“ of suitable demand, which is no transfer in time to use it in other moments. This will reduce the electricity consumption.

Shift: Suitable performance request will be displaced in location or time. (SRE p. 89), electricity consumption does not change. … (remark the different understanding of the technical and economic importance)

  • 4. Efficiency increase (TYNDP exec. p. 3) VS „Innovation in this context addresses the interdependence of implementation of new technologies in the power sector to increase flexibility and energy- as well as emission efficiency (p. 70); in scenario A 2030 and B 2030 / 2035 and C 2030, additionally efficiency increase of 27,5 TWh and 32,5/42,3 TWh and 55 TWh assumed, which lead to a significant reduction … (SRE p. 74)
  • Findings in Annual Working Programme vs. SRE
  • 5. Detailed assessment sheets for shift and storage projects (AWP p. 3) VS NN
  • 6. EU interconnectivity targets VS (3) To reduce the grid development need TSOs in all scenarios are obliged – based on the approved installed generation performance un cipher 1 – to use for the determination of the needed transportation volume a reduced Fed-in of all Onshore wind-energy-und photovoltaic-generators (existing and new projected) as binding. (SRE p. 5) … Concerning this, the scenarios B 2035 and C 2030 should reach higher increase levels as in § 4 EEG-E 2016, to reach the EEG-Improvement targets of § 1 Abs. 2 EEG-E 2016 (SRE p. 74)
  • 7. market flow studies (AWP p. 15) VS NN
  • 8. The optimum interconnectivity target for 2030 capacities should “take into account the cost aspect as well as trade potential between the related regions“. (AWP S. 17) VS. NN
  • 9. the target is 15%, respect to the installed capacity in 2030 (AWP S. 17) VS NN
  • 10. Better qualitative and quantitative Benchmarks are to be found, like trade flows, peak loads, and bottlenecks highlighting the needed interconnectivity.“ (EP, ITRE, Dec /15 // AWP S. 17/18) VS already existing and following the request prognosis expected bottlenecks are to be avoided, particularly to enable the system to integrate and transfer the complete energy of all generators (SRE S. 77)
  • 11. Monitoring, forecast and control of distributed RES-Generation and performance management (AWP S. 24) VS NN (better don’t expect management of generation or load of degenerative power plants)
  • 12. Assured implementation of Dynamic Line Rating therefore proves its pan-European relevance VS NN


  • 13. PCI-selection-process, PCI-priority projects can apply to national transmission projects VS NN
  • 14. Second key consists in a better explanation of why’s and how’s of projects VS NN
  • 15. Operative and market design for 2030 still are to invented VS „within the frame of this electricity grid development plan – 2017 version (NEP 2030) for first time a modelling based analysis of national and regional electricity request and load with a high granularity degree is executed“.

(p. 7. Fraunhofer_ISI_2017_Netzentwicklungsplan_Strom).

  • 16. steady state analysis of the TYNDP with a one-hour timeframe resolution (AWP p. 32) VS contrary to approaches at classical electricity applications the demand side management in new applications will not be modelled in a market simulation. Instead a separate load model will be used. (e. g. Emobility / SRE S. 90)
  • 17. Technical devices for frequency and voltage control (AWP S. 32) VS Implementation of „intelligent“ grid technology (by remote control adjustable substation transformers only /SRE S. 77)
  • 18. IT-base technical devices at PV and Wind-generation for inertia simulation and frequency control despite a clearly lower degree of conventional generation VS NN
  • 19. pan-European network-rules for connection (AWP S. 32) VS NN
  • 20. operative guidelines (AWP S. 32) VS NN
  • 21. Enforcement of TSO/DSO interfaces (AWP S. 32) VS NN
  • 22. Accountancy of technological progress, in any case a virulent factor for the consistency of all assumptions about generation (AWP S. 32) VS NN
  • 23. Detailed development descriptions of all scenarios will deliver necessary answers on questions concerning systems and profitability (AWP S. 36) VS NN
  • 24. Market modelling (S. 36 / AWP S. 5) VS (see Fraunhofer ISI & SRE) TSOS are obliged to determine the transport request on basis of installed generation performance capacity for all scenarios (SRE S. 77)
  • 25. Demand side response (DSR / AWP S. 36) VS NN (performance and load management by shut down generation – dispatch and re-dispatch)
  • 26. Identification of system needs relies in any case on pan-European market-studies to derive target capacities VS NN
  • Insertion:
  • 26.1. Remarkable in this context: SRE does provide the following information about that: Maximum load is in addition the maximum sum of all  performance requested by all consumers connected to DSO and TSO grids, within one year in one defined timeframe (hour peak) including the sum of all transport and transformer losses in both, distribution and transportation grids. (SRE S. 106)
  • Fraunhofer_ISI_2017_Netzentwicklungsplan_Strom does it different:

Therefore, has been developed a methodology based on sequential model analyses built one on the others result. For the analysis of the yearly demand the energy request model FORECAST is used, which is based on a technological Bottom-Up-Approach. To determine the load profiles the eLOAD-model will be used, which is based on a broad spread of different technological specific demand-profiles. Furthermore a estimative methodology regarding the market penetration of distributed PV-storage-systems was determined (ISI p. 7). A substantial part of NEP 2030 is a detailed analysis of national (German) electricity demand and load (ISI p. 10). Until now no deeper analysis of the dynamics of energy and climate policies in a timeline regarding technological and structural development has been done (ISI p. 10). To determine the load profiles the model eLOAD (energy load curve adjustment tool) will be used, which is built on the annual request of power quantities derived from the FORECAST-model (ISI p. 11).

  • 27. Nine indicators ranging from socio-economic welfare to environmental impacts (AWP p. 40) VS NN
  • 28. Together with actual technologies, innovative ones will be incorporated in the infrastructures (AWP p. 43) VS Implementation of „intelligent“ grid technology (remote adjustable = “intelligent” substation transformers / SRE p. 77).
  • 29. Promotors, Regulators und policy makers should understand anything of each technology and its availability (AWP p. 43) VS. NN
  • 30. legal basis is to be found in the 3. EU legislative package for the common energy market, 2009 VS EnWG and EEG
  • 31. digital revolution – 4. industrial revolution (AWP p. 4) VS NN
  • 32. EC Energy Balancing Guideline, March 2017 (AWP p. 5) VS NN https://electricity.network-codes.eu/network_codes/eb/
  • 33. Transparency platform (AWP p. 5) VS NN (EnWG §12f)
  • 34. bidirectional dataflow between national operators and regional service centers VS NN (data privacy and protection policy, §12f EnWG)
  • 35. Transformation of our transparency platform into a market serving tool: a common intuitive and customer-friendly platform to centralize data from the entire common energy market. (AWP p. 5) VS NN
  • 36. legislative market rules move forward market integration to provide more competition and optimization of resources. They fix the rules for the calculation of capacities, day-ahead- and intraday- as well as forward-markets VS. NN
CACM-Regulation (Capacity Calculation /AWP S. 6) vs. NN res. VO EK 2015-1222
  • 37. THE CACM REGULATION (AWP S. 10) VS NN – (VO EK 2015-1222 network code guideline for capacity and congestion management pdf S. 1): … b) Analyze the question whether the products offered on the markets for long-term capacities or product-combinations are efficient. In this context at least, the following indicators will be assessed: i) trade horizons; ii) difference between Buy- and Sell-price offers; iii) traded volumes in relation to the real physical consumption; iv) Open position in relation to physical consumption;)
  • and –
  • For this issue they should build a common grid model including estimates for generation, load and grid status for every hour. Available capacity usually should be calculated by a calculation mode based on real power flows., precisely a method respecting the fact, that power can flow over different paths and within which available capacities will be optimized in thoroughly interdependent grids.
  • Insertion: At this point it is critical to point out on some EU-Regulations, binding law even in German countries, in which without any doubt certain preliminaries are created, whose impacts BNetzA contrary to her bigger organizational aunt ENTSO-E (not mother, that would be ACER) does not mention or explain in her report:
  • 37.1 VO EK 2016-1719 Network code guideline for long term capacity allocation.pdf
  • 37.2. Calculation of long term capacity for the Year-Ahead- and Month-Ahead-market timeframe.
  • 37.3. The power-flow-based approach could be used, if cross-zonal capacities between bidding zones are interdependent to each other in a high degree and this approach might be justifiable under the scope of economic efficiency.
  • 37.4. In this regulation detailed determinations for the allocation of cross-zonal capacities on long-term markets for capacity are fixed.
  • 37.5. This regulation is binding law for all transmission grids and connection lines within the Union.
  • 37.6. In member states with more than one TSO this regulation is valid for all TSO in this member states.
  • 37.7. Time frames for capacity calculation: All TSOs in each capacity calculation region provide the calculation for long-term cross-zonal capacity for each allocation of long-term capacity and at least for annual and monthly time frames.
  • 37.8. For the common capacity calculation methodology either a power-flow or coordinated net-transfer-capacity approach will be used.
  • 37.9. For first time TSO propose to determine the all-year peak load using the Bottom-Up-Simulation-model eLOAD (FORECAST / Fraunhofer ISI / p. 108).
  • 37.10. Partial decomposition: Using the „partial decomposition“ means to dissect (decompose) historic load-curves in their elements, i.e. in separate load-flows of all single applications in use.
  • 37.11. To carry out der Partial decomposition the TSOs can rely on a voluminous data base with more than 600 load-profiles derived from field-studies, building-simulations and internal data from industrial projects. (ISI S. 108)
  • 38. ‘Mid-term adequacy forecast’ (MAF) … The methodology used by AMF is nothing but the first pan-European assessment of system adequacy, using market-based techniques for modelling probability VS. NN
  • 39. To map the whole complexity of adequacy in power-systems, TSOs have to provide further data VS. NN (§12f, which TSO here in Germany deny doing, based on old law originated in 1934)
  • 40. 1. Advisory Council Meeting 2015.pdf, (p. 4) released five key topics:
  • Execution on legal basis
  • enforced stakeholders’ engagement
  • greater transparency
  • proactive contribution on policies / legislative initiatives
  • cooperation of traders and TSOs-DSOs and regional cross-border cooperation.
  • Discussion centers warranted in all aspects of TSO-DSO-cooperation (which should not exclude other actors und any circumstances or predetermine solutions without sufficient inclusion of stakeholders)
  • The Advisory Council addressed the question whether TSOs should be allowed to own and run technical devices like storages. The basic assumption is, that assets, used in the power market need to be owned and run by market participants only … but real usability … highlights, that regulations should not hinder TSOs to own and run such assets (for non-market participation purposes)
3rd Advisory Council Storage Assets Role of TSOs.pdf, S. 1; How are these scenarios developed?
  • 41. In general scenarios are based on storylines, assumptions, data collected in data bases, quality checks, pan-European methodologies and final market simulations to quantify energy input.
  • 42. Balancing installed generation and demand might be valuable.
  • 43. On one hand pure energy models (like PRIMES model in the trend setting descriptions of EC) allow a prognosis, based on optimization of all energetic components, therefore not only electricity, as well gas and oil, because they are all interdependently connected and interact.
  • 44. On the other hand, power-based models (like used by ENTSO-E in this report) rely on power-market-simulations, hooked for calculation on all-year load profiles in hourly time frame resolution and climate data as well as on technical grid constraints.
  • 45. power-based models allow to assess price differences between zones, RES spillage, state wide balances, etc. … and they are key to methodologies, building the bridge from bottom-up scenarios to top-down scenarios.
  • 46. Substations will contain battery systems. These batteries will, equipped with control devices be used in the stations, to ensure SoS. Such batteries will be assumed as part of the substations, which build core elements of the grids. For this reason, such batteries are considered grid assets. category 2.
  • 47. Advisory Council members welcome the customer oriented approach in ENTSO-E’s 2017.

    5.0 Tools

  • 1. EU-guideline No. 347/2013 determines, that PCIs will be selected from the TYNDP list for transmission- and storage projects. (EC guideline 347/2013. p. 40) VS flexibility and storage options: SRE 2017-2030 for first time contains additional various flexibility options. Beneath we basically find distributed and centralized storages, load management of classic and new power applications as well as scheduled decoupling of power -and heat-generation in co-generation units (SRE p. 88).
  • 1.1 Referential values for 2015

To determine the referential value of peak load in 2015 TSO data can be used, who have displayed the annual peak load in their report of German TSOs concerning performance balance 2015 following § 12 Abs. 4 and Abs. 5 EnWG stated on 30.09.2015 (furthermore performance balance report 2015). The performance balance report 2015 contains a statistic as well of all 2014 data evaluated by TSOs as a prognosis for 2015. While conclusive TSO statistic for 2015 still is to be expected in the upcoming Performance balance report 2016, BNetzA for determination for the reference value 2015 refers on TSOs prognosis value within the actual performance balance report 2015. (welcome to the filter bubble of nepotism and self-fertilization). In the performance balance report 2015 TSOs aims to explain why a detailed measuring (and transparent data providing) on all grid levels (voltage levels) and of cross-level effects regarding annual peak load is not possible: Due to a multitude of consumers who’s meters do not provide performance (KW) measuring, necessary to determine all year high of performance in single grid sections, but “power” (precisely energy) measuring only (KWh) / (what a pretext!). Many end-consumers as well as small generation providers / prosumers (e. g. photovoltaic installation owners) only have possibility to measure the “electrical work” i. e. electric energy drafted from or provided to the grid. Furthermore, internal data of electricity input of closed industrial or distributive girds, e. g. the German railway grid, are not available (so what, if they are separate it does not matter, if connected we should have data from the connecting stations), what means a significant part of the consumers cannot be considered. Therefore, all-year high cannot be detected by measuring on the customer side.But, because apparently consumption and generation of power in a grind needs to be equal at any time, the all-year high annual peak load will be derived indirectly by power input on suppliers’ side in the performance balance report 2015.  Objection: Obviously a plausible method on first sight, but it – mainly in grid supplied by huge central generation units – disregards the peak shifting potential on lower voltage levels: Forecast 40 million households in Germany with an average performance of 1,2 KW and single peaks of 4 KW in the afternoon between 5 and 7 p. m. (or as well 2 KW in the morning hours 7 a. m. to 9 a. m.) means a real peak load of 160.000.000 KWh in one hour which is 160 GW performance peak on the grid. Just the private households. By-bye plausibility if German TSO identify an annual high peak-load of 84 GW for the whole grid.Assume now those private households install a 5 KWh Li-Ion storage battery delivering a maximum performance of 10 KW to cover this morning and evening peaks while charging the battery slowly with a small fuel cell or private PV or even from their BEV when they back home from work, where they loaded the cat by public PV on the parking lot and the bi-directional working car is connected to the house. There is the key to flexibility. Not in thicker or more wiring. Despite this, TSO do know very well the power inputs of industrial grid, within closed distributive grids and of the German railway grid (which by the way should be qualified as common possession, not of a private company). On this behalf TSOs recorded the „performance flow“ at all connection points between TSO and DSO grid levels as well as all end-customers directly connected to the transmission grid (e. g. Lechstahlwerk Meitingen, up to 180 MW / close to 1 TWh annual consumption which equals 1,5% of German total). Contrary to earlier years TSO dispose as well of data about power input from generative and degenerative suppliers into the distributive grid in high quality. Those data were provided to them within the process „executive market regulation for balancing electricity trade in balancing groups” (MaBiS). Thus, energy balancing processes currently not recognizable by TSOs could be considered and feed-in could be balanced adequately. TSO suppose that 97% of the power input total (on all TSO and DSO grid levels) might be covered by the surveys for the performance balance report 2015. (pure fiction, it is all about preventing transparency to maintain real monopoles = cash-cows)

Due to the improved recording of 97% of all power input compared with earlier years BNetzA considers adequate – for first time – to extrapolate on the whole population. TSOs demonstrate for the statistically determined annual peak performance 81,8 GW for 2014, which will be assumed, within the performance balance report 2015, as prognosis for 2015. Corrected by the 3% missing power input data results an annual performance peak of 84,4 GW for 2015.

  • 2. Grid networks containing both, TSOs and DSOs, keep a key position AWP p. 4) VS. NN (existing structures on state-level are not mentioned in the SER, no transparency)
  • 3. Common Grid Model (AWP. p. 2, 4, 5, 7, 9, 12, 22, 23, 24, 27) VS NN
  • 4. Enactment of network regulations, (AWP p. 4, 5, 12 ff / new regulations) VS. NN
  • 5. Review of bidding zones (AWP p. 7, 8, ) VS. NN
  • 6. The enactment of these codes signifies they are binding EU law. (AWP p. 4, 5, 12) VS. NN (occasionally reference to federal German law) „Developing the scenarios is to be based only on the actual legislative and regulatory frame, because the development of all legal conditions until 2030 resp. 2035 is as unforeseeable as changes of market prices or new technologies spread “ (SRE p. 73).
  • 7. Market stakeholder committee 2015 (AWP p. 8) VS NN
  • 8. Grid stakeholder committee 2016 (AWP p. 9) VS NN
  • 9. System Operations Stakeholders Committee in 2017 (AWP. S. 9) vs. NN
  • 10. Balancing Stakeholder Group (AWP. p. 9) VS NN
  • 11. workshops involving stakeholders … planning of public workshops and consultations 2018 (AWP p. 9) VS NN res. „somewhat of public consultation“, better characterized as instruction or lecture.
  • 12. connection codes implementation library which will gather all available European and national documents and timelines in all European countries and regions as they become available (AWP p. 9) VS NN
  • 13. 2017 updated proposals for the methodologies for calculating scheduled exchanges (AWP p. 10) VS NN
  • 14. FCA … establishing and promoting forward markets (AWP p. 11) VS NN (widely static market model with additional add-on factors for Emobility and heat-pumps. Not on BNetzA/German TSO screen: power to gas / P2G)
  • 15. ENTSO-E has drafted an initial set of 18 non-binding IGDs (implementation guidance documents), highlighting the effect on specific technologies (AWP p. 14) VS NN (just gross assumptions less of facts, nothing concrete)
  • 16. asking stakeholders to ‘Build your own 2030 and 2040 scenarios’ vs. NN (BNetzA legal issue by government 86 parliament, driven by political nepotism. The civil society and end customers have nothing left by to try normative power through fact= build partial autonomy by PV & Storage).
  • 17. pan-European System Needs Report (AWP p. 17) VS NN
  • 18. innovative solutions needed (AWP p. 20) VS NN (no experiments, the German conservative political parole)
  • 19. substation automation (AWP p. 20) VS NN (RONT – remote control substation transformer is only available technical mean)
  • 20. standard fault analysis, location, (AWP p. 20) VS NN (no steady state measurement possible – which is cheating the public, it is just about „data protection“ by §12 f EnWG, which declares all data as „business security issue“, not even anonymized data are available)
  • 21. dynamic line rating (AWP p. 20) VS NN http://lindsey-usa.com/dynamic-line-rating/
  • 22. electricity grids must create synergies with other energy networks (AWP p. 20) VS simple “Sector Coupling”, (while ENTSO-E-approach (integrating telecommunications, gas, heat, water, P2G, data management) clearly leads farer than just simplified sector coupling meant by BNetzA/German TSOs. Legal “Unbundling” to get rid of monopoles led to more rigid technical monopoles on separate sectors: measuring and net operations, which are real monopoles.)
  • 23. transition towards sustainable transport (AWP p. 20) VS NN
  • 24. ENTSO-E will develop … a report on extreme scenarios for the energy system for 2030 (AWP p. 15) VS „Developing the scenarios is to be based only on the actual legislative and regulatory frame, because the development of all legal conditions until 2030 resp. 2035 is as unforeseeable as changes of market prices or new technologies spread “ (SRE p. 73).
  • 25. … will also prepare an assessment of various flexibility solutions to fulfil the electricity power system needs (AWP p. 21) VS „TSOs. obligatory had to take into account the cut of RES peak performances in grid development planning for 2025 in all scenarios. This happened for the moment of its approval on the background of German government clearly and undoubtable intentions (coalition treaty, „green book“ of Ministry of Economics and Energy), to fix the peak performance cut off legally for the future“, (SRE p. 76) and VS „Transmission grid operators are obliged to implement and use the rules for “peak performance cut off” within any frame for grid development planning § 11 Abs 2.“ (SRE p.77 /a real legal-looking attempt to prevent further increase of RES contrary to EU-objectives ).
  • 26. CUSTOMERS AS ACTIVE MARKET PARTICIPANTS (see BEUC): THE TSO-DSO PLATFORM (AWP p. 21) VS NN (Stakeholder = TSO, DSO, any industrial, commercial or economic associations but not one for the customers)
  • 27. TSOs and DSOs cooperate closely … build a common understanding of the challenges and needs from the perspectives of a system operator and neutral market facilitator (AWP p. 21) VS NN
  • 28. ENTSO-E is also mandated to issue short-term ‘seasonal outlook’ reports twice a year, covering the coming summer and winter periods, before 1 June and 1 December (AWP p. 23) vs. NN
  • 29. switch from the current mostly deterministic approach to an hourly probabilistic approach (AWP p. 23) VS law „Developing the scenarios is to be based only on the actual legislative and regulatory frame, because the development of all legal conditions until 2030 resp. 2035 is as unforeseeable as changes of market prices or new technologies spread “(p. 73), which came meanwhile in contradiction to: TSOs for first time propose to derive the annual peak load with the bottom-up-simulation-model eLOAD (SRE p. 108).
  • 30. week-ahead adequacy, … one of the tasks of the RSCs (AWP p. 21) vs. NN
  • 31. facilitated by blockchain technology (AWP p. 24) VS NN (assumable unknown at BnetzA and German TSO/DSO for “secret information” and data protection in §12f EnWG).
  • 32. TSOs plan the operation of the grid from one year ahead to one hour before real time; this is the last timeframe in which market parties can adjust their positioning in intraday markets. Decisions relevant for ensuring the dispatching feasibility are taken by TSOs hours before, considering the best forecast of the situation after that last intraday trading. To make this operational planning, TSOs use computer models of the power system to simulate its behavior depending on the different flows and the different elements of infrastructure. In addition, grid models are also instrumental for security analysis, capacity calculation, and adequacy assessment VS NN (SRE does not offer or even indicate such considerations or if it does, they are thoroughly disguised).
  • 33. The CGM finds its legal basis in three of the network codes: the system operation guideline, the CACM Regulation and the FCA Regulation VS NN (Derived from EnWG issued by government 86 parliament)
  • 34. two methodologies: the CGM methodology, and the generation and load data provision methodology (AWP p. 25) NN (no alternative methodologies)
  • 36. The core interlinks four TSOs: RTE (France), Swissgrid (Switzerland), Amprion (Germany) and APG (Austria). Other TSOs will then be linked to one of these four TSOs, with a maximum of two degrees of separation from the core VS NN
  • 37. By making information available freely to all, it allows for a level-laying field where market participants can make better analyses and decisions. (AWP p. 26) VS NN
  • 38. we will enhance the Transparency Platform from its present form to a ‘market-serving tool’ (AWP p. 26) VS NN
  • 41. PUBLIC CONSULTATIONS (AWP p. 27) VS “public consultations”, precisely: “public instructions”
  • 42. 3rd_Advisory Council Protokollentwurf.pdf (3rd ACP S. 4): Members note that the decentralized system and the close link with the end-customer are key to acknowledge when talking about future governance and the development of Network Codes vs.
  • 43.1 Decentralized system and Link to end-costumer (3rd ACP S. 4,) VS The BnetzA in its youngest approval of a SRE already has refuted the allegedly by several studies propagated testimony that an exclusively decentralized power generation might be preferable (see SRE 2025 decision 19.12.2014, p. 74 f.). The enquiry „Impacts of restricted transmission grid expansion in a 2030 perspective in Germany” by ECOFYS analyzed only a case in which a regionalized growth of RES takes place while grid extension is slowed down or completely stopped. (They should have read the “Leaked DOE study draft_U.S.” as well  https://pv-magazine-usa.com/2017/07/17/leaked-doe-study-draft-u-s-grids-are-getting-more-reliable-not-less/) . Main objective of the study „cost optimized extension of RES in Germany“ by consentec „experts“ as well as Fraunhofer IWES concerned the question, on which locations future RES expansion shall take place to reduce the total cost of power supply.
  • Insertion: Astonishing that this question never is asked if the discussion is about Xmas order list of big energy trusts. No one argues about the real Total Life Circle Cost of new power lines including the permanent fees landlords will charge.
  • Following this Fraunhofer IWES study any generation close to local consumption would have a remarkable effect on grid extensions only if degenerative power plants as well would be built close to consumption centers or if stability ensuring measures within the grid would be suspended.
  • Strange how one Fraunhofer institute does derive other conclusions than another. Even more strange, if looking at the reserve generation, which is nearly completely based on small distributed units with some MW).
  • Furthermore, a consumption-close local generation would require a determined political governance to take decisions for the locations, where to build power plants. This would be contradictive in a diametral way to the current approach based on market signals. (SRE p. 97)
  • The argument is not concise. Every single power plant localization – for huge, degenerative units – in Germany was decided by politicians – maybe, but not really on behalf of the operators’ preferences who don’t care as long as subsidies cash-cow is giving €-milk -, and regarding not only the last plants, not a single one was built without massive subventions, mostly indirect, but nevertheless effected. See R&D-means for gas & steam turbine in Irsching.
  • 6. Benchmarks
  • 1. In a well-integrated Internal Electricity Market, it is economically sound that the grid is sized so that the load factor of every grid element is lower than 50% (TYNDP 2016 exec. p. 19) VS NN
  • 2. key issue is to make the most complete information possible about transmission projects (TYNDP 2016 exec. p. 29) VS NN (BNetzA Newsletter)
  • 3. What we assume today sets the frame under which the future is analyzed (TYNDP 2016 exec. p. 36) vs. NN (this clearly exhorting view for attentiveness is not mentioned in the SRE
  • 4. improving social welfare (TYNDP 2016 exec. p. 41) VS. NN
  • 5. Project promoters, regulators and policy makers need to understand something of each technology and their availability (TYNDP 2016 exec. p. 43) VS NN (requested Know How of policy makers, governmental clerks and “experts” close to Zero. E. g. nearly all BnetzA representatives do have a degree in law, not in MINT…)
  • 6. Welfare and Capacity, relation (TYNDP 2016 exec. p. 49 ff.) VS NN (black hole)
  • 7. the customer should move center stage (AWP p. 4) vs. NN
  • 8. generation grows increasingly decentralized and variable (AWP p. 4) VS. …distributed generation: It is, if anything, sometimes generation close to consumption. But this generation type is subject of a natural and thus even economic conflict towards the profitability of the power plants location. On second hand it is more than doubtable if a constraint in favor of close-to-consumption generation or even a stronger enforcement for RES-generation closer to consumption can match and fulfill the goals (triangle of energy turn) of a secure, reliable, and inexpensive supply … currently missing storage technologies suitable … (SRE p. 97).
  • Indeed, there is no shame to turn clear needs for energy transition – no matter if judged by climate disaster or real sustainability to provide resources for future generations – into a conservative and status quo maintaining scheme, just to keep donations and support for political parties
  • 9. while observing strict neutrality and being out of the market (AWP p. 4) VS NN clear preference for single, completely and exactly identifiable „market“ participants or participating groups by clandestine recoupling of government / parliament / associations / BNetzA / TSO and market leading huge power suppliers. Silence spawns Gold!
  • 7. Methodology
  • 1. FORECAST / ELOAD: Fraunhofer ISI vs. NN
  • Assumptions (are pure assumptions and not reality)
  • 1. Decentralized generation = distributed generation = close to consumption generation (VDE-approach) VS BNetzA. …distributed generation: It is, if anything, sometimes generation close to consumption. But this generation type is subject of a natural and thus even economic conflict towards the profitability of the power plants location. On second hand it is more than doubtable if a constraint in favor of close-to-consumption generation or even a stronger enforcement for RES-generation closer to consumption can match and fulfill the goals (So-called triangle of energy turn) of a secure, reliable, and inexpensive supply (SRE p. 96)
  • 2. ENTSO-E forecasts larger, more volatile power flows over a larger distance across Europe, mostly North-South (AWP p. 12) VS NN
  • 3. Most transmission investment needs are linked to RES-integration developments (AWP p. 12) VS … currently missing storage technologies suitable … (SRE p. 97).
  • 8. Benefits
  • 1. significant positive impact on European social welfare (TYNDP 2016 exec. p. 12) VS NN
  • 2. Europe could benefit from additional, cheap, generation surpluses (TYNDP 2016 exec. p. 16) VS NN
  • 3. Regarding internal German boundaries, the analysis of TYNDP 2016 shows that reinforcement of these does have large European benefits (TYNDP 2016 exec. p. 16) VS NN: For a more detailed explanation see figure on p. 63 in chapter 1.12.6 and 1.12.8 TYNDP 2016, and text:

The planned or already realized powerlines (purple and red colored) crossing Germany North-South in BnetzA Scenario Reports are expressively justified as necessary for Bavarian supply, assuming and pretending an energy poverty in Bavaria after shut down of nuclear power plants. They are not mentioned for European trade or supply. The point is, that BnetzA can not prove necessity in a correct way for internal German supply. They just pretend it. Sorry, but we urgently need people, who know what they are doing. See following lines.

  • “The main drivers behind the development of the transmission capacity at the North-Italian boundary concern the exploitation of new generation, mainly located in the North of Germany and France (wind) and in the South of Italy (wind and photovoltaic). The interconnection projects planned on this boundary will enable wider power exchanges, thus making possible the integration of new generation and pump storage capacity located in the Alps region. Making the balance between societal welfare gain and infrastructure investment costs for increasing levels of interconnection, the optimal level of interconnection, regarding the Italian Norther boundary, is around 13,5 GW, which is what the TYNDP portfolio of mid-term and long-term projects aims to deliver.”
  • 4. A positive environmental impact (TYNDP 2016 exec. S. 27) VS UN-climate-conference in Paris 2015 (COP 21) The “Paris agreement“ with negotiated limitation of global warming is not at all reflected in this SRE (SRE p. 75)
  • 8. Disadvantages
  • 1. financial means 1.5-2 €/MWh of power consumption (TYNDP 2016 exec. p. 12) VS NN
  • 9. Motives // Tasks
  • 1 If implemented … 2006 network codes would have contributed to avoid 15 million cut off and M€ 300 – 500 of economic losses…( TYNDP 2016 exec. p. 8) VS NN
  • 2. The infrastructure projects depicted in the TYNDP are a key enabler of the EU’s climate and energy policy objectives of decarbonization, competitiveness and security of supply (TYNDP 2016 exec. p. 17) VS NN
  • 3. customer-driven energy revolution (3rd ACP p. 4) VS NN (national territorial task)
  • 4. ex. solutions on how to align physical flows and market flows in ID, how to solve congestions in ID and real-time (3rd ACP, p. 4) VS NN (ENTSO-E – contrary to BnetzA SRE does not mention grid overload by congestion, it is detected nowhere)
  • 10. Definitions // Roles
  • 1 Stakeholders = End-customers center stage, MARKET PARTICIPANTS, DSOS, TSOS AND REGULATORS (TYNDP 2016 exec. p. 6) VS BnetzA and German TSO only
  • 2. ENTSO-E coordinates TSOs’ innovation activities to ensure the future transmission grid is up to the challenge (TYNDP 2016 exec. S. 20) VS NN (BNetzA acts as mediator. The precise role and real function is: An outsourced decision predefining entity outside the democratic political process)
  • 11.Sources
  • 1. Approval of SRE 2016 = SRE 2017 – 2030 (Genehmigung)
  • 2. TYNDP 2016 Scenario Development Report
  • 3. TYNDP draft 2018
  • 4. First Advisory Council minutes (protocol)
  • 5. Third Advisory Council minutes (protocol)
  • 6. EC-Regulations/guidelines 2015/1222; 2016/1388; 2016/1477; 2016/1719; 2017/1485;
  • 12 Remarks
  • TYNDP poses one question never mentioned before: AC members note that basic principles that should govern the distribution of roles to find the best solution from a society point of view: storage is not counted as a grid asset and should be freely provided by any market party; TSOs should not participate in this market; they should aim to minimize system costs and to use optimally services without interfering with the market. On governmental or administrative levels in Germany this question naturally never will be posed for actual mode of taking decisions based on beliefs and opinions instead of knowledge, know-how and ratio: Storage still are considered as never-profitable gadgets and treated with a “mother-in-law-“attitude.
  • Liberalization has brought up a strict separation of operation and generation of electricity, transport, trade and measuring of power von Strom.  How now technical devices should be characterized? By physical function (a storage is a device sometimes consuming power and sometimes producing power and therefore a generator and not a grid asset) or just by tis existence within the economic balances of a specific market service provider? Is a storage an asset of grid or of generation? The question on first hand seems to be trivial, but as trivial as it appears, it is enormously critical, because for the grid operations there are legally guaranteed rentabilities on private investments missing for generation units.

Initial questions:

  • Energy turn, grid expansion, who still understands that in its complexity?
  • Is that necessary?
  • What’s the benefit – and therefore does it make any sense – vast parts of the population doubt it?
  • Where does the demand come from?
  • Where the journey leads to?
  • Where should it lead to?

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