A RAP Power System Blueprint Deep Dive
Revitalising regulation to guide anticipatory investment
Dominic Scott & Zsuzsanna Pató
Summary
Long connection queues and growing curtailmentcurtailment The reduction of power output of specific generators by the system operator on grounds of maintaining grid stability and system safety, often in exchange for compensation. of renewable energy sources, already standard features of many European electricity markets, point to the need to rethink the regulation of power grids. And a look to the future suggests these problems will only become more significant without action now. Future power systems will require more grids to integrate new loads created by electrification and new renewables, many at new locations, at a speed and scale envisaged to be greater in magnitude than seen before, especially at the distribution level.
Other challenges contribute further to the need for a rethink. Investments in the grid — especially high voltage investmentsespecially high voltage investments ACER estimate average project implementation time of approximately 14 years from moment of being considered to the project’s commissioning. RAP discusses ways to do so in our “RIP first come, first served” grid toolkit. — usually take much longer than new load, especially electrifying households, or new renewable energy sources (RES). We have as yet to untap the full potential of smart solutions — like grid-enhancing technologies and enhancements to the flexibility of demand and supply — that allow us to use the existing grid more efficiently and thereby limit the identified need for build. See our toolkit on how to tackle grid scarcity — “RIP first come, first served.”
Anticipatory investments are not a new form of grid investment, and as such do not require a brand-new regulatory framework. Optimal investment — whether anticipatory or not — still entails investing so that the additional cost of build matches the expected societal benefit of this extra capacityexpected societal benefit of this extra capacity At some point, the cost of more grid exceeds the benefit of alleviated congestion. This means the optimal level of congestion is non-zero..
The term anticipatory investment has been coined on a recognition that we need to build electricity grids at a quicker pace, in greater volume, and with view of a longer time-horizon than before in order that grids do not present a bottleneck to the clean energy transition. This Power System Blueprint deep dive sets out the core elements of a regulatory framework to guide this investment.
Figure 1 presents our recommendation for a regulatory framework to deliver the grid investment required to meet the needs of the energy transition. The process is overseen by a national regulatory authority, or NRA, that is independent and with a net zero mandate. Holistic energy plans are formed with policies that fully deliver on decarbonisation ambitions, keeping in view sufficiently long-time horizons. These are translated into grid plans, subject to enhanced institutional coordination — across energy vectors, voltage levels and jurisdictions — that inform the investments undertaken. Tools to allocate risk to those who can manage it best are deployed. Plans are evaluated and revisited by the regulator regularly. We go through each element in turn in the rest of the paper.
Figure 1: Regulatory elements to optimise power grid investments in the energy transition
Source: RAP figure
Note: NRA stands for national regulatory authority.
NRA – ensure independence and net-zero mandate
Governing the transition requires an independent regulator with a net-zero mandate. Regulatory independence, including sufficient resource, is particularly important in underpinning investor confidence. The net-zero mandate underpins other governance features, such as the cross-energy vector independent system operator (ISO), and facilitates the translation of National Energy & Climate Plans (NECP) trajectories into the development of a ‘net zero target grid.’ The net-zero mandate brings the regulator in line with government’s legal climate obligations and directly links consumers’ interests to specific net zero targets.
Energy plans — address inadequacies in NECPs
As the key national energy planning documents that inform Network Development Plans (NDPs), NECPs must flesh out policies that underpin the transition to a net zero power system consistent with decarbonisation goals. Many are not adequate in setting out policies to decarbonise in time with commitments and/or policies and measures are listed without assessing how much they contribute to goals. These must build in transparently the full delivery of policies that reduce the need for new grids, such as implementing obligations on making cross zonal capacities available to the market, addressing barriers to employing grid enhancing technologies, or putting in place the building blocks for tariffs that reflect scarcity on the network (including scarcity-based network tariffs or nodal or zonal pricing).
And they must employ sufficiently long time-horizons to inform network development plans (NDPs) — this means that the next NECPs due by 2028 should have time-horizons, not only 10 years (as stated in the Governance Regulation) but covering the remaining period until net zero power system.
Grid plans — coordinate NDPs, transparently
Enhanced institutional coordination across multiple dimensions and more transparency in developing network development plans is a “must,” no longer a “nice to have.”
A cross-energy-vector independent system operator is likely best placed to coordinate and develop the target network. Giving them a net zero mandate with time-horizons aligned with NECPs ensures their focus in development of a net-zero target grid. Cross-energy vector responsibilities will help ensure the system operator has sight of important interactions, such as with hydrogen production or electrification of end uses. An ISO which does not own the network will be free of conflicts of interest in assessing relative merits of operational solutions. The newly formed National Energy System Operator in Britain is an example of a fully independent nonprofit public agency that has a mandate encompassing all energy vectors.
Improved coordination of network development and operation across jurisdictions is needed. The historic distinction between cross-border versus domestic network from the governance point of view creates barriers to developing an optimal network for an integrated European market. New cross-border capacities modify welfare distribution among consumers and producers on both sides of the border. Current cost sharing practice detached from benefits is a barrier for these welfare generating projects.
This points to the value of strengthening the mandates at the regional level (Regional Coordination Centres) towards an EU level (EU ISO) to complement the current bottom-up project identification with a top-down mechanism where transmission project proposals are driven by regional needs.
The “net zero target grid” needs to be coordinated across voltage levels of the domestic network and with adequately utilised across zonal capacities. Coordination is particularly important for higher voltage grid investments, which take longer to build and may present more of a challenge in securing buy-in than local distribution network upgrades. Enhanced cooperation between DSOs and TSOs will allow for interactions to be accounted for and ensure coherence (for instance aligning time horizons for analysis) in development of NDPs. Estimating the impact of electrification at lower voltages is key for planning upstream.
Engagement of stakeholders in planning is important to support robustness of the outcome. The European Ten Year Network Development Plan (TYNDP) scenarios, which are informed by advice from the European Scientific Advisory Board on Climate Change and the Stakeholder Reference Group, may offer an example to build on at the Member State level. Similarly, bodies leading electrification across different end uses need to feed-in to the planning of power grids. For example, public EV charging infrastructure and local heat planning (now mandatory across the EU) need to feed into power network capacity need assessments. As consumers are the main stakeholders, engagement methods must be designed to cater for the meaningful involvement of different consumers groups.
A cost benefit analysis (CBA) methodology suitable for comparing not just new grid investment options but also alternatives to new grids as required by the efficiency first principle is key to translate multiple scenarios into an actionable plan. The NDPs may use analytical tools to convey an order of priority for grid investments, such as CBA with a lead scenariosuch as CBA with a lead scenario Identification of a “lead approach,” which can guide grid investment by network owners, is important as multiple plans cannot all be acted upon simultaneously. ACER emphasises the importance of developing a best estimate scenario that is stress-tested in a balanced way. ACER’s TYNDP Scenarios Guidelines may provide a framework for development of robust scenarios and a lead scenario., a Least Worst Regrets analysisLeast Worst Regrets analysis Worst Regrets analysis is a decision-making tool that makes recommendations based on which options/strategy produce the least “regret” across all of the analysed. Thus, all investments that feature in the Least Worst Regret approach would be identified as prudent investments and the regulator may have some confidence in the merits a priori of committing the consumer to recover their cost., or other approaches. For projects of medium voltage and above, this can probably be done on a case-by-case basis, while for low voltage inter-related batches of investments may be considered. The approach need not necessarily identify anticipatory investments as distinct from non-anticipatory investments. Rather, it should ensure that risks and uncertainties are accounted for in investment planning processes, and that a robust approach for managing them is pursued. Such a CBA should be able to identify projects where the incremental cost of over-sizing assets is relatively small to the potential benefit in anticipation of future users.
Providing up-to-date information on the existing and planned grids in a granular manner is fundamental for optimal planning and transparency. Tools like hosting capacity maps — becoming mandatory for all DSOs and TSOs — can provide information on remaining capacities, planned investment, anonymised connection requests (dates, capacities and type of resource) and can serve as match-making hub for projects to optimise available capacities (co-location behind the same connection point and coordinating new load and generation siting) and to collect commitments for planned grids (see later).
Getting the price signals right will help system operators develop a ‘net zero grid.’ Of particular importance are prices that provide greater locational granularity, such as nodal pricing (or at least zonal). This transparently shows where constraints lie, facilitates scrutiny and builds public support for the network vision. It also sends signals to use the existing grid efficiently, motivating connection requests where energy and grid are abundant.
Investment decisions — manage risk
Anticipatory investment comes with greater risk that new assets will not be fully used, or used much later than planned. Long lead times for grid build — particularly transmission — contribute to this risk, and merit interventions to address barriers underpinning supply chain bottlenecks, permitting complexities and workforce shortages. Even after addressing these, difficulties in deciphering demand for grid (the “what, where and when”) means a substantial risk of forecasting error. Larger volumes of investment further augment the cost of getting it wrong.
How to allocate the remaining risk? Regulators — acting on behalf and representing the interest of consumers — never have as much information on grid operations and needs as grid companies, and should therefore not take all the risk. On the other hand, risk placed fully on network companies can act as a barrier to investment and result in higher cost in the form of higher financing cost and the cost of inaction. As regulators seek to identify the optimal balance, they may usefully draw on tools that can help allocate risk to those best placed to manage it. While there are no silver bullets, the following may usefully be considered.
Incentives linked to future utilisation. The network company is well placed to identify where scarcity will materialise on the grid, even if subject to uncertainty. The regulator may therefore provide incentives for network companies to find and prioritise projects with better utilisation prospects. Incentives could be in the form of a penalty and reward, or even reward only, and could link to absolute utilisation rates or comparative performance (yardstick). Other avenues that link depreciation with utilisation may be worth exploring.
Financial commitment of future grid users. Connection requests of larger commercial grid users that are locationally mobile — such as RES, data centres, electrolysers, industry, and MW chargers — present particularly substantial risks for grid build. Thus they could be required to “buy-in” in order to gain access to planned new grids. Network companies can use tools such as grid connection capacity auctions, reservation fees or deposits to identify connection requestsdeposits to identify connection requests Auctions, in addition, can demonstrate value of a planned network element and assist in prioritization aid scarce equipment and labour supply for grid building.. Incentives linked to future utilisation (above) could motivate network companies to make full use of tools to weed out grid requests subject to greater uncertainty.
An alternative way to secure consumers from bearing the cost of stranded grid investment is to build in fall-back mechanisms for investments that do not meet a predefined utilisation threshold or that surpass cost thresholds. The regulator can build in re-openers that allow for revisiting anticipatory investment decisions, subject to well-defined triggers. These can clarify up-front the triggers upon which an adjustment of cost allocation of under-utilised investments may be considered.
Revisit plans
As time horizons need to be expanded in planning, especially for DSOs, built-in monitoring and adjustment of plans becomes crucial. Both DSOs and TSOs must already update their plans biannually — according to the Electricity Directive — but whereas the planning horizon is 10 years for TSO, it can be shorter for DSOs. The time horizon for distribution networks should align with that of transmission. NDPs should be evaluated and revisited by the regulator regularly based on how investments are proceeding, and demand projections change. As new information comes to light, scenarios will need to be refreshed both in the NDPs and the NECP as well.
RAP recommendations

References
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The authors extend thanks to reviewers — Luis de Cunha, Vilislava Ivanova, Marion Santini, Bram Claeys and Tim Simard. All errors are the authors’ own.
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- Last modified: March 4, 2025