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ENTSOG TYNDP 2017 Public consultation questionnaire

Q20:

ENTSOG developed four demand scenarios:

three were designed as differentiated paths towards

achieving the EU 2030 energy and climate targets (Blue

Transition, Green Evolution, EU Green Revolution),

and one as failing to achieve these targets (Slow

Progression). These differentiated paths are intended

to provide the future frame under which to assess the

gas infrastructure. Would you consider this provides a

comprehensive view on the future role of gas?

No,

Explanation :

The scenarios fail to capture the downside risks

associated with a low gas demand scenario. In

particular, none of the scenarios fully meet the newly

proposed 30% EU binding energy efficiency target

for 2030, and are thus not in line with the current

European policy context. No scenario helps

assessing the impact of going beyond the 2030

objectives agreed in 2014, and thus fails to assess

the implications of complying with the EU

commitment to the Paris agreement.

Q21:

TYNDP indicates how scenarios comply with the

EU 2030 energy and climate targets. Do you see that as

an important element of TYNDP?

Yes,

Explanation :

ENTSO-G – thanks to its membership and access to

information - is in a unique position to highlight the

potential impact of climate and clean energy policies

on the business models of its members and to key

investors in the gas sector. Yet, the choice of the

scenarios fails to capture the full range of upside and

downside risks for investors in terms of future gas

demand, and does not send the right signals to

ensure a competitive EU energy sector. For

example, there is not one single scenario adequately

reflecting the EU's long term climate targets

equivalent to reaching a zero carbon energy sector

by 2050. None of the ENTSO-G scenarios for 2030

is in line with a 2 degree compatible pathway

(ranging from being 4%-28% above IEA projections

under the 450ppm scenario). For some of them,

meeting the target over a longer time frame is

implausible. In order to be in line with a pathway to

maintain the “well below 2 degree” goal as per the

EU’s international commitment, the Blue Transition

pathway would require the EU to reduce its gas use

by 39% in just 10 years (Comparing Blue Transition

2030 to the IEA450pmm scenario for 2040). This

risks leading to stranded assets and to EU funds or

governments wasting taxpayers’ money through

regulated tariffs, tax breaks or public grants. In its

recent update on the State of the Energy Union, the

Commission has highlighted this as an area of

concern, by saying: "In view of scarce resources in

the Member States [...] Support should only be given

if in line with the long-term energy policy of the

European Union, avoiding stranded assets and

carbon lock-in."