Amprion GmbH
Amprion
Amprion is one of Europe’s leading transmission system operators for electricity.
ID: 426344123116-68
Lobbying Activity
Meeting with Christian Ehler (Member of the European Parliament) and EnBW Energie Baden-Württemberg AG and
12 Dec 2025 · Energiepolitik
Meeting with Christian Ehler (Member of the European Parliament) and EPIA SolarPower Europe and
26 Sept 2025 · Energy policy
Meeting with Christian Ehler (Member of the European Parliament) and RWE AG and
13 Sept 2024 · Energiepolitik - allgemein
Meeting with Christian Ehler (Member of the European Parliament) and ENGIE and
11 Jul 2024 · Energiepolitik allgemein
Meeting with Christian Ehler (Member of the European Parliament) and BDEW Bundesverband der Energie- und Wasserwirtschaft e. V. and
31 May 2024 · Energiepolitik allgemein
Meeting with Michael Bloss (Member of the European Parliament) and Transport and Environment (European Federation for Transport and Environment) and
2 May 2024 · Green Industrial Deal
Meeting with Jens Geier (Member of the European Parliament)
24 Jan 2024 · Exchange on bidding zone review
Meeting with Jens Geier (Member of the European Parliament) and BDEW Bundesverband der Energie- und Wasserwirtschaft e. V. and
12 Jan 2024 · Exchange on industrial and energy policy
Meeting with Kadri Simson (Commissioner) and
6 Sept 2023 · High level dinner before the ENSTO-E grids event – discussion on the challenges for European networks and electrification.
Meeting with Claudia Gamon (Member of the European Parliament, Shadow rapporteur) and VERBUND AG and Austrian Power Grid AG
25 Apr 2023 · Electricity Market Design
Meeting with Jens Geier (Member of the European Parliament) and EnBW Energie Baden-Württemberg AG
18 Apr 2023 · Exchange on the electricity market design (staff level)
Meeting with Michael Bloss (Member of the European Parliament)
31 Mar 2023 · Strommarktdesign
Response to Review of EU rules on fluorinated greenhouse gases
29 Jun 2022
The aim of limiting the global temperature rise is at the heart of climate change mitigation and can only be achieved by reducing greenhouse gas emissions and ultimately becoming carbon neutral. This requires a fundamental transformation of our energy system.
The key to a reliable, affordable and sustainable integrated energy system is energy infrastructure. Amprion, together with all European electricity transmission system operators (TSOs), ensures that an increasing share of renewable energy is integrated into the electricity system, while maintaining system security 24/7. We also support the EU's pledge to make global greenhouse gas emissions climate neutral by 2050 and are ready to continuously reduce our SF6 emissions.
SF6-Gas is currently used by TSOs' in high voltage (52-170 kV) and extra-high voltage (above 220 kV) applications such as gas-insulated lines, gas-insulated substations, air-insulated switchgear including circuit breakers and instrument transformers.
TSOs, together with high voltage product manufacturers, have worked hard over the past decades to reduce their SF6 emissions through various innovative technologies and the introduction of a circular economy for SF6, and made significant progress in recent years.
Amprion is also willing to apply alternative technologies once they have passed necessary type tests and have proven their operational performance. Therefore, SF6 is already applied today only if there is no alternative solution that meets the requirements. However, the legislative proposal contains provisions that, in their current form, will significantly delay grid development projects and severely impact the reliability of electricity supply.
For this reason, Amprion proposes the following four amendments:
1) Enabling reasonable GWP-solutions for all technical applications: An additional GWP<10 limit for alternative gases would impede the further development of technical solutions with a GWP>10 and thus reduce the supply of already available technical alternative solutions on the market. To preserve the pace of grid development and raise the chance that suitable alternative solutions are available for all applications in the electrical transmission grid, applications with GWP>10 should also be allowed.
2) Appropriate definition of ‘placing on the market’ (POM) for electrical switchgear: The definition of POM according to Art. 3(6) in conjunction with Art. 11(1) and Annex IV point (23) takes into account activities and material aspects and is therefore difficult to translate to TSO practice (question regarding the maturity of alternative technologies, no consideration of TSO project durations of more than 4 years and uncertainty regarding project delays). We therefore propose to adjust the definition.
3) Allow spare parts for already installed SF6-equipment: As currently drafted, Art. 11(1) provides for a ban on spare parts, as does Annex IV point (23). To ensure the reliability of the network by allowing maintenance of the existing fleet until the end of its lifespan and to minimise repair time, we propose to exempt spare parts from the ban.
4) Take into account the maturity of alternative solutions: To ensure system security, TSOs place very high demands on the reliability and availability of their high-voltage installations. From experience, new technologies require a break-in period during which some unanticipated problems may occur and reduce availability. Hence, it is critical for any new technology not only to pass the required certification tests, but also to demonstrate good performance in real operation. This should be considered accordingly.
The previously mentioned elements are further explained in the attached document.
Read full responseResponse to Revision of EU rules on Gas
12 Apr 2022
The Hydrogen and Gas Market Decarbonisation Package launched by the EU Commission in December 2021 has been timely, as it is essential to foster the decarbonisation of the European economy while ensuring Europe's security of supply and competitiveness. Especially as the new geopolitical and energy market realities call for an acceleration in the transition to clean energy and towards a greater energy independence for Europe.
Extensive electrification and sector coupling are needed to achieve a largely CO2-neutral system in a cost-efficient manner. Energy infrastructure is the key to a reliable, affordable and sustainable integrated energy system. Together with all European transmission system operators (TSOs) for electricity, Amprion ensures that not only an increasing share of (offshore) renewables is integrated into the power system, but also that renewable energies are connected to customers, demand centres and green hydrogen production, while ensuring system security 24/7.
As direct electrification is the most cost-effective and energy-efficient way to decarbonise final energy demand for most applications, the European regulatory framework must support the efficient use of Europe's renewable energy potential by directly using renewables in electrification, reducing energy (re)conversion, and promoting the use of renewable gases in applications where electrification is unlikely to be technically or economically feasible. In addition, an appropriate regulatory framework for hydrogen and gases is needed that creates a level playing field for the different gaseous energy carriers and supports coordinated decarbonisation across sectors to enable a smarter, more integrated and optimized “one energy system view”. This is key to creating an energy infrastructure across sectors (electricity, gas, hydrogen, etc.) that will enable Europe to achieve its 2050 climate neutrality target.
With regard to the revised Gas Directive, a coordinated integrated network planning approach between the electricity and gas/hydrogen sectors is crucial to fully exploit the contribution of the electricity sector to decarbonisation through sector integration. In addition, it is important that the other sectors provide the flexibility needed for the future electric power system which will be mainly based on weather dependant energy sources. Therefore, promoting an efficient, coordinated approach between the different national network development plans based on increased cooperation between electricity and gas TSOs and limiting the risk of unnecessary complexity and additional delays in the planning process is crucial. Article 51 of the revised Gas Directive proposes how natural gas TSOs should develop their national network development plans. Since some provisions directly relate (or should relate) to the electricity system or its operators, we would like to propose the following amendments:
- Enhanced coordination of planning processes for different energy carriers while keeping different national sectorial plans;
- Ensure mutual exchange of information across sectors;
- Consideration of jointly developed Union-wide TYNDP scenarios in national development plans;
- Assessment of electricity and gas networks should focus on specific needs with significant cross-sectoral impact and involvement of
electricity and natural gas TSOs;
- Purely indicative information on the location and size of market-based facilities (such as power-to-gas).
The previously mentioned elements are further explained in the attached document.
Read full responseResponse to Revision of the Renewable Energy Directive (EU) 2018/2001
18 Nov 2021
Reaching climate neutrality will not be possible without reshaping the energy system in which the majority of energy will come from renewable energy sources by 2050. Energy infrastructure is key to a reliable, affordable and sustainable, integrated energy system. Together with all European Transmission System Operators for electricity, Amprion ensures that not only an increasing share of renewable energy is integrated into the electricity system, but also that (offshore) renewable energy sources are connected to customers, demand centres and green hydrogen production, while at the same time maintaining system security 24/7.
Amprion therefore appreciates the review of the revision of the RED II as it is a key instrument for the further integration of renewables and for achieving the decarbonisation objective by 2030.
The RED III should set the framework that enables and incentivises the increase of the share of renewables in all sectors, be it through electrification or use of renewable gases. The inter-sectoral objective should be to achieve CO2 reductions as efficiently as possible. The direct use of electricity with consequent reduction of primary energy needs, together with the renewable energy deployment, must be promoted wherever this is technically and economically efficient and sustainable. At the same time, indirect electrification will be necessary in certain sectors where decarbonisation is not technically possible. Therefore, sector integration must be adequately promoted through legislation.
With a view to the climate neutrality objective, it is also important to create planning certainty beyond 2030 by providing a timely outlook on the further renewable energy deployment and the necessary grid development between 2030 and 2050.
With our response (see enclosed), we would like to share our view on the issues we consider to be priorities in the EC proposal and which need to be further clarified:
• Joint projects between Member States – Offshore (Art. 9),
• Administrative procedures, regulations and codes – Permitting (Art. 15),
• Guarantees of Origin/Calculation in the transport sector – Renewable fuels of non-biological origin and additionality (Arts. 19, 27(3)),
• Facilitating system integration of renewable electricity – Information obligation for TSOs (Art. 20a (1)).
Read full responseResponse to Revision of the guidelines for trans-European Energy infrastructure
8 Mar 2021
The European Green Deal require a fundamental transformation to enable a fully integrated climate-neutral energy system by 2025. As energy infrastructure is a key enabler of the European energy transition, transmission system operators (TSOs) play an important role in meeting the Green Deal objectives as well as in implementing a functioning internal energy market. Amprion together with all European TSOs for electricity must ensure that an increasing share of renewable energy sources is integrated into the electricity system while maintaining system security.
Amprion appreciates the TEN-E revision as it is a key instrument in the development of an internal energy market and necessary to achieve the Green Deal objectives by ensuring consistency and alignment with the decarbonisation targets. Nevertheless, there are a number of provisions that require further clarification.
With our response (see enclosed), we would like to share our view on the issues we consider to be priorities in the EC proposal and which need to be further clarified:
• Criteria for Projects of Common Interest and Projects of Mutual Interest,
• Organisation of the permit granting process,
• Transparency and public participation,
• Energy system wide cost-benefit analysis,
• Scenarios for the Ten-Year Network Development Plans,
• Infrastructure Gaps Identification,
• Offshore grid planning,
• Offshore grids for renewable energy cross-border cost sharing and
• Enabling investments with cross-border impacts.
We would also like to point out that Amprion fully supports ENTSO-E’s contribution to the EC open consultation on the adopted TEN-E proposal.
Read full responseResponse to Climate change mitigation and adaptation taxonomy
18 Dec 2020
Amprion supports the overall objective of the EU Taxonomy framework to channel investments into sustainable activities and to realise the Green Deal.
Acting in the interest of society, Amprion and European TSOs are committed to deliver the infrastructure needed to reach the EU’s environmental objectives on climate change mitigation and adaptation in a timely manner, while maintaining system security and keeping environmental impacts to a minimum. In this regard, we appreciate that the Delegated Act (DA) on climate change mitigation and adaptation provides evidence for identifying environmentally sustainable activities as well as positive signals and incentives for investors to invest in long-term sustainable projects, such as transmission grids.
However, we recommend some clarifications to ensure consistency and alignment between the Taxonomy regulation (Regulation (EU) 2020/852) and the DA and its Annexes, and to avoid potential legal and interpretive difficulties in the implementation and to ensure that the DA provisions incentivise investments in sustainable activities that contribute to the achievement of the Green Deal and climate neutrality objectives by 2050, and that predictability for investments goes together with environmental protection principles.
In this regard, we see a need for further clarification or modifications in the following chapters:
− 4.9 Transmission and distribution of electricity (classification of the transmission/distribution of electricity as “enabling activities”; eligibility criteria for systems and DNSH criteria 4 and 6),
− 4.12 Storage of hydrogen,
− 7.1, Construction of new buildings, and
− 9.1 Research, development and innovation.
Amendment proposals and comments can be found in the attached document.
Read full responseResponse to A EU hydrogen strategy
8 Jun 2020
The EU objective of becoming climate neutral by 2050 and the related Green Deal require a fundamental transformation of the European energy system. Amprion and all other European TSOs for electricity must ensure that an increasing share of renewable energy sources (RES) is integrated into the electricity system while maintaining system security.
During this transformation process, the current electricity system will meet its limits. More flexibility is necessary to make the energy system sustainable. Amprion therefore appreciates the EC's announced initiative for its Energy System Integration Strategy, in which the EC intends to set out its vision for a smarter, more integrated and optimised energy system. Amprion also appreciates the new dedicated Hydrogen Strategy that aims to avoid a fragmented approach by addressing the energy transition in a coordinated way.
In the consultation on Energy System Integration, hydrogen has been explicitly mentioned as part of a holistic solution. ENTSO-E clarifies in its contribution (18/5/20) that electricity from RES should be used directly when possible due to the higher efficiency of end applications in the electricity system. Nevertheless, hydrogen is the most promising component to fully decarbonise the European economy for applications that cannot be electrified (e.g. furnaces or chemical processes).
Amprion fully supports the consultation contribution of ENTSO-E and additionally submitted a description (3/6/20) of the project hybridge – a 100 MW electrolyser and hydrogen infrastructure to accomplish the technology scale up of electrolysers and to prove the systemic integration of the electrolyser. Therein, we propose how to plan and operate electrolysers to maximise their decarbonisation effects. We also explained how to ensure both unbundling and non-discriminatory principle of the regulated TSO business.
As a response to the roadmap for the EU hydrogen strategy, we have prepared a vision for a hydrogen system as an integrated part of the future European energy system. In the next ten years, the following key elements have to be established as no regret measures to meet the European objectives by 2050:
• The main barriers today are the lack of electricity from RES and the availability of the hydrogen infrastructure on the targeted scale. Thus, the installed capacity of RES should be increased as soon as possible.
• Furthermore, a hydrogen grid is needed to connect hydrogen sources, hydrogen sinks and flexibilities such as storage units. A consolidated planning of the hydrogen, methane and electricity grids is necessary to gradually and efficiently convert parts of the existing methane infrastructure for the only use of hydrogen. A hydrogen grid, to which various producers and customers are connected, then leads to a market and contributes to more competition.
• Although the amount of green electricity from RES available for conversion in electrolysers will be limited in the next decade, the technology of electrolysis needs to be scaled to the gigawatt class and developed for future systemic operation.
• Although the available amount of green hydrogen will be limited in the next decade and the industry’s current hydrogen demand is significant, the conversion of those end use applications from fossil fuels to hydrogen that cannot be electrified should start now nonetheless. This will still need a long time and noteworthy investments in hydrogen technologies, but it will help to avoid stranded investments or lock-in effects in both infrastructural and industrial assets.
With more and more RES, the amount of installed electrolysis capacity and green hydrogen imports can be sharply increased. This allows a gradual reduction of the installed capacity of fossil-based hydrogen production. Furthermore, it requires more flexibility in the hydrogen system provided by underground hydrogen storages.
Further details of our vision and a way forward are described in the attached document.
Read full responseMeeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans), Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans) and
6 Feb 2020 · Green deal, smart sector integration
Meeting with Miguel Arias Cañete (Commissioner) and BDEW Bundesverband der Energie- und Wasserwirtschaft e. V. and
20 Nov 2017 · clean energy package