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RTE Réseau de transport d'électricité

RTE

RTE operates France's high-voltage electricity transmission network and ensures secure power supply across continental France and Europe.

Lobbying Activity

Meeting with Anna Stürgkh (Member of the European Parliament) and DIGITALEUROPE

27 Jan 2026 · Electricity Grids

Meeting with Yvan Verougstraete (Member of the European Parliament)

11 Dec 2025 · Grids Package

RTE Urges Stability and Simplicity in EU Taxonomy Revision

4 Dec 2025
Topic — The initiative reviews technical criteria to update and simplify environmental reporting rules.
Message — RTE requests that the Commission avoids making technical screening criteria more complex. They urge officials to ensure predictability and coordinate simplification efforts.12
Why — Stability would protect previous investments and prevent new administrative compliance costs.34
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French grid operator RTE backs open-source energy AI

5 Nov 2025
Topic — New European Union strategy for leveraging digital technologies and artificial intelligence in the energy sector.
Message — RTE recommends improving the governance of the Common European Energy Data Space to include grid operators. They advocate for using open-source initiatives to develop high-quality datasets and software. The organization also supports creating training programs for a skilled digital energy workforce.123
Why — This strategy would lower software costs and prevent dependency on specific technology providers.45
Impact — Proprietary software vendors lose their market grip as the sector shifts towards open-source standards.6
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Meeting with Pascal Canfin (Member of the European Parliament)

27 Oct 2025 · Paquet réseaux

RTE urges stronger EU cooperation to protect electricity grids

13 Oct 2025
Topic — The EU is updating its energy security rules to handle new geopolitical threats.
Message — RTE calls for joint European mechanisms to detect and respond to infrastructure threats. They want better protection for physical sites and stricter cybersecurity for foreign technology. The operator suggests streamlining existing laws to address hybrid attacks such as drones.123
Why — Enhanced coordination would help the operator better protect its critical infrastructure against attacks.45
Impact — Foreign technology providers face stricter hurdles and mandatory compliance with European security standards.67
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RTE Urges Inclusion of Grid Technologies in Sustainability Rules

10 Oct 2025
Topic — Setting minimum environmental sustainability requirements for net-zero technology public procurement.
Message — RTE requests that grid technologies be explicitly included in the new procurement rules. They propose using transmission system operators' expertise to establish relevant environmental criteria.12
Why — Standardized rules would help the operator identify genuine sustainable suppliers and improve industrial resilience.34
Impact — Less sustainable suppliers may lose market share if they cannot provide transparent information.5
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Response to EU’s next long-term budget (MFF) – EU funding for competitiveness

10 Oct 2025

Please find attached RTE's feedback to the public consultation. We remain at your disposal should you require any further information.
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RTE urges EU funding for domestic grid reinforcement projects

10 Oct 2025
Topic — The European Commission is consulting on the next long-term budget for infrastructure.
Message — RTE requests that domestic grid reinforcements with cross-border impacts become eligible for EU funding. They also want grant amounts confirmed earlier to ensure that strategically important projects are not abandoned. Finally, they seek simplified funding processes for transmission system operators.123
Why — RTE would secure crucial financial support for its planned €100 billion infrastructure upgrade.4
Impact — European citizens lose out on energy security if critical grid projects are abandoned.5
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Meeting with Christophe Grudler (Member of the European Parliament) and FuelsEurope

10 Sept 2025 · Politique énergétique européenne

RTE Urges Mandatory Climate Data Sharing for Energy Grids

29 Aug 2025
Topic — This consultation seeks an integrated framework for managing accelerating European climate risks.
Message — RTE proposes mandatory data sharing for energy producers to improve grid modeling. They also request a coordinated EU deployment plan for technologies and prioritizing energy sufficiency.123
Why — Improved modeling would lower network balancing costs and optimize grid operating conditions.4
Impact — Renewable energy producers would face new regulatory burdens to share proprietary data.5
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Response to Revision of the 'New Legislative Framework'

27 Aug 2025

Please find attached RTE's feedback in response to the call for evidence for the revision of the New Legislative Framework.
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French grid operator RTE demands CBAM exemptions for electricity

1 Aug 2025
Topic — The consultation examines extending the carbon border adjustment mechanism to more industrial products.
Message — RTE requests the exemption of grid safety services between operators from carbon tax obligations. They advocate for emission calculations that reflect real-time energy mixes. They also suggest using fixed yearly prices to maintain interconnector attractiveness.123
Why — This would remove administrative burdens and protect the economic viability of interconnectors.45
Impact — European consumers face higher costs if cheaper low-carbon electricity imports become uncompetitive.6
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RTE urges inclusion of power grid infrastructure in CRM list

25 Jul 2025
Topic — This consultation identifies products and waste streams with high critical raw materials potential.
Message — RTE proposes adding infrastructure like transformers and pylons to the recovery list. They also call for regulatory simplification and technical standards to ensure material purity.123
Why — Including these components would help RTE secure strategic materials and improve supply chain resilience.45
Impact — Non-EU recycling markets lose access to valuable waste as strategic resources are kept within Europe.6
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RTE Urges Regional Coordination for Faster EU Grid Development

21 Jul 2025
Topic — The European Commission is consulting on measures to upgrade, digitalise, and expand energy grids.
Message — RTE seeks regional coordination to support electrification and a "first ready, first served" connection policy. They also propose extending the infrastructure planning and project selection cycles to four years.123
Why — Stable regulations and longer planning cycles would reduce administrative costs and attract long-term investors.4
Impact — Developers with less mature energy projects would lose priority access to the electrical grid.56
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Response to Revision of the Standardisation Regulation

15 Jul 2025

Please, find attached RTE's contribution to the call for evidence on the revision of the Standardisation Regulation.
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Meeting with Bruno Tobback (Member of the European Parliament)

15 Jul 2025 · Financing Europe's infrastructure

Meeting with Joachim Balke (Head of Unit Energy)

2 Jul 2025 · Exchange related to call for evidence and public consultation on the European Grids Package

Meeting with Joachim Balke (Head of Unit Energy)

19 May 2025 · Transpyrenean crossings interconnectors

Meeting with Joachim Balke (Head of Unit Energy)

23 Apr 2025 · Presentation of RTE's 2040 grid development plan to DG ENER

Meeting with Christophe Grudler (Member of the European Parliament)

25 Mar 2025 · Politique énergétique européenne

Meeting with Pascal Canfin (Member of the European Parliament, Shadow rapporteur)

20 Mar 2025 · Omnibus I

Meeting with Marina Mesure (Member of the European Parliament) and SAFRAN and ENEDIS

14 Mar 2025 · Visite du salon Global Industries

Meeting with Valérie Hayer (Member of the European Parliament) and ELECTRICITE DE FRANCE and SGI Europe

12 Mar 2025 · Economie sociale et solidaire et Services d'intérêt général

Response to List of net-zero technology final products and their main specific components

20 Feb 2025

RTE Réseau de Transport dÉlectricité, the French electricity Transmission System Operator, welcomes the draft implementing act on final products and main specific components. RTE believes that the resilience criteria could help support domestic EU manufacturing in the long run. Since most European manufacturers act as equipment assemblers, developing domestic manufacturing capacities will take some time. In some cases, certain subcomponents are sourced from third countries that are not signatories to the World Trade Organization Government Procurement Agreement. It is therefore essential to take this situation into account to avoid creating additional pressures on domestic supply chains in the short term. RTE trusts that the European Commission will take these factors into account when conducting the supply chain resilience assessment, particularly if the scope includes not only final products but also subcomponents.
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Response to Delegated act on primarily used components under the Net-Zero Industry Act

20 Feb 2025

RTE Réseau de Transport dÉlectricité, the French electricity Transmission System Operator, welcomes the draft delegated act on primarily used components. This proposal reflects a shared recognition that electricity grid technologies are the backbone of the energy transition, particularly in the current context of both energy transition and geopolitical tensions. To date, the list provided by the European Commission includes essential grid technologies and components that will encourage manufacturers to develop new manufacturing capacities for grid technologies within the Union, benefiting from the provisions of Regulation (EU) 2024/1735. Over the next 15 years, RTE is expected to invest approximately 100 billion to renovate, adapt the French extra-high voltage transmission grid to climate change, integrate low-carbon electricity, and support the necessary electrification of the economy. These investments will require timely access to grid technologies. They must also benefit Europeans by enhancing sovereignty (securing access to strategic technologies), creating jobs, and improving social welfare across Europe. RTE believes that expanding grid-technology manufacturing capacities in Europe will strengthen resilience, contribute to supply-chain diversification, reduce environmental footprint, and support the timely delivery of grid projects.
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Meeting with Christian Ehler (Member of the European Parliament) and EPIA SolarPower Europe and

13 Dec 2024 · Energy policy

Response to Digital Product Passport (DPP) service providers

10 Dec 2024

Please, find attached RTE's feedback on the call for evidence on the Digital Product Passport (DPP).
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Meeting with Christophe Grudler (Member of the European Parliament)

23 Oct 2024 · Politique énergétique européenne

Response to Ex-post evaluation of the Connecting Europe Facility 2014-2020

24 Sept 2024

During the current MFF period (2021-2027), RTE benefited from the support of the European Union through the CEF-Energy fund, with subsidies granted for studies and/or works for certain interconnection projects, including: - The Bay of Biscay interconnector between France and Spain. - The Celtic Interconnector between France and Ireland. Due to inflation, and scarcity of resources and materials, those two projects suffered increased costs related to works. The rules to benefit from CEF-Energy did not allow for a correlative support from the European Union for these two major PCI projects. For the future, RTE calls for a substantial increase in the funds allocated to the CEF-Energy, which is used to subsidise trans-European electricity projects, mainly interconnections and connections for marine energy production. Such an increase would also control the rise in bills for electricity consumers. In addition, RTE calls for a simplifying of procedures to apply for CEF funds, so as to minimise the use of resources from grid operators.
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Response to Guidance to facilitate the designation of renewables acceleration areas

23 Feb 2024

Please, find attached RTE's feedback on EC call for evidence about guidance on designating renewables acceleration areas.
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Response to Managing EU climate risks

12 Jan 2024

Please, find enclosed RTE's feedback on: Societal resilience - managing EU climate risks.
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Meeting with Christophe Grudler (Member of the European Parliament)

22 Nov 2023 · Politique européenne de l'énergie

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.

RTE Urges Innovation Fund Access for Electricity Grid Projects

7 Aug 2023
Topic — Consultation on updated rules and competitive bidding for the EU Innovation Fund.
Message — RTE advocates for the Innovation Fund to support innovative electricity transmission grid projects. They request funding for high-cost offshore infrastructure and demonstrators to enable decarbonization.12
Why — This change would lower financial risks for RTE's capital-intensive offshore network developments.3
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French Grid Operator RTE Demands Faster Tech Permitting

21 Jun 2023
Topic — The European Commission's proposal to boost manufacturing of green energy technologies.
Message — RTE proposes expanding tech definitions and slashing permitting times to nine months. They also suggest allowing longer-term contracts to encourage industrial investment.123
Why — RTE would secure a stable European supply chain and prevent infrastructure bottlenecks.4
Impact — Asian manufacturers would lose market share to favored European production.5
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Response to Ecodesign for Sustainable Products - Product priorities

12 May 2023

The implementation of ESPR should take into consideration two approaches: one regarding industrial products and another for consumer products. We suggest implementing an industrial approach for intermediary products as Aluminum (Al) and its alloys; Non-ferrous metal products as Copper (Cu), Steel, polymers, given their industrial properties and applications. Standardisation activity regarding these intermediate products is key. Al, Cu and Steel should be treated in priority given possible recycling processes and potential supply chain disruptions that could stall the twin transition. Regarding final products like paints, the most important information requirements are the expected lifetime of the product, its application rules and its disposal. The horizontal measures like durability, recyclability, post-consumer recycled content should be addressed in priority and in this order given the unprecedented increase in demand for the essential intermediate products in net zero technologies and the improvement potential in their environmental footprints. Recyclability and post-consumer recycled content are the most relevant horizontal measures to reduce environmental impacts for Al and its alloys; Non-ferrous metal products as Cu, Steel. For the information requirement recycled content per ton of input material it is essential to take into account simultaneously quality issues, since secondary metal quality is of central importance for final products. Local recycling industry possibilities should to be examined in priority. Recyclability and post-consumer recycled content is a complex process for polymeric materials e.g. cables insulation and sheath that require a high level of purity and physical performance qualities to suit their particular application. For both horizontal measures, technical and quality studies should be taken into consideration jointly in cables designing phase. Regarding the horizontal measure of post-consumer recycled content, one of the most relevant aspects to take into consideration for industrial products is the definition of the minimum recycled content needed without sacrificing quality and performance. To this end, technical studies and quality assessments are needed to verify the acceptable content range of post-consumer recycled material in a new industrial product for a given use, without degrading electrical, mechanical and chemical expected functionalities. Regarding the horizontal measure of durability, notably the aspect of maintainability of an equipment should be tempered with the TCO tool in order to estimate maintenance costs. Concerning the reparability aspect, the potential provision of introducing a reparability scoring index and/or label for industrial equipment is not reasonable for all industrial products, nevertheless standardisation of repair accessories and/or new technologies (in terms of production or materials) could help. Working with industrial ecosystem to implement raw materials recycling and processing capacities in EU to ensure the transformation and recovery of materials and therefore securing a sustainable supply is crucial. This will need specialized skills and industrial know-how to ensure better sorting, identification of waste streams, reorientation to allow better recycling and high recovery rates. Waste regulation shall be adapted to encourage recovery and recycling of raw materials by creating legal certainty and removing unnecessary administrative burden regarding end-of-waste criteria. Given the high decommissioning rates that will follow the next decade, creating and strengthening processing and recycling specialized industrial bases for grid components and products in EU is key for enhancing a sustainable supply of materials and avoid delocalization of EU industry. Defining LCA method standards to compare solutions from different technologies and new products specific rules is key to ensure successful implementation of ESPR.
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Response to Initiative on EU taxonomy - environmental objective

3 May 2023

RTE supports investments in technologies that ensure the earliest and most efficient decarbonisation of SF6 equipment. However, we disagree with the draft criteria for HV switchgears in Annex I (p9) of EC Del. regulation amending (EU) 2021/2139: 4.Switchgears () with a GWP>10 are not compliant. This criteria does not follow the advice of the Platform on Sustainable Finance (p364) recommending : Abve 145kV or more than 50kA shrt crct: eqpt containing gas mixtures with a GWP>675 are not compliant. With this justification (p374): For switchgear >145kV or more than 50kA shrt crct, technical feasibility of switchgear with a GWP <10 is not yet proven, and no technological solution is available on the market. However, the limit of 2000 GWP seems high considering current R&D roadmap, this is why the expert group proposes a lower value of 675 According to Recital 40 of the Taxonomy Regulation : () the EC should ensure that those criteria are based on available scientific evidence (1), are developed by taking into account life-cycle considerations, including existing life-cycle assessments (LCA) (2), and are updated regularly(3) 1/ By not following the advice of the Platform, the EC is departing from a scientific based approach, since the advice is based on the trusted information provided in full transparency by the industry to the EC and reflected in a study on alternatives to F-gases in switchgears published by the EC in 2020 (Report C(2020) 6635 final) which states : (p.7) For HV (>245kV) substantial R&D is still needed. First commercial solutions relying on gas blends with synthetic substances are expected within a 5 year time frame. Covering the variety of technical requirements and applications will need more time (NB:synthetic substances refer to fluoronitrile, GWP 500-600) (conclusion) In space restricted environments, GIS designs based on fluoronitrile may be the only alternative to SF6 because other solutions require more space. 2/ RTE conducted in 2021 a LCA study comparing LCAs of different types of HV GIS & circuit breakers (63 & 225 kV), carried out internally with an external critical review (in compliance with ISO 14071 standard) to question data, hypotheses and to check the modelling and interpretation of results. The study concluded that fluoronitrile (GWP 500-600) & dry air solutions (GWP<10) have an equivalent global carbon footprint (with a slight advantage for fluoronitrile since dry air solutions are more massive and consume more raw materials and energy in the construction phase, which is the most CO2 emitting). NB:a prospective approach was taken for the decarbonisation of steel production and any similar issues by 2040. We propose replacing point 4 with: For switchgears with () gas mixtures with a GWP, considering the total life cycle of the switchgear and the role they play in the decarbonisation of the EU economy: Below and equl to 145 kV and up to 50kA shrt crct: eqpt containing gas mixtures with a GWP>10 are not compliant except if their full Life Cycle CO2 footprint is equivalent to eqpt containing gas mixtures with a GWP<10 Abve 145kV or more than 50kA shrt crct: eqpt containing gas mixtures with a GWP>675 are not compliant. () s. containing SF6 are not compliant. This would help direct investments for techno. below 145kV with the best LCA. Above 145kV, this would avoid excluding the alternatives already developed, currently tested for 420kV, which LCA should be as advantageous as alternatives with GWP<10, if those are available once (no prototype, no pilot, doubt raised whether it can be achieved). They may be also the only possible solution where space is limited. This would not preempt the results of negotiations on the F-Gas and PFAS regulations and would allow for an earlier and fair (not only based on GWP which addresses only CO2 emissions during the exploitation phase of the equipment) decarbonation.
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Meeting with Ditte Juul-Joergensen (Director-General Energy) and Bureau Européen des Unions de Consommateurs and

20 Jan 2023 · U.S.-EU Task Force: Best practices in Energy Savings and Flexibility Other participants: Cleantech-Cluster Energy, ELVIA, EU DSO Entity, California Energy Commission, ASE, AEE, ComEd, Octopus Energy, OPower, Uplight

Meeting with Pascal Canfin (Member of the European Parliament)

13 Dec 2022 · Green Deal

Response to European Critical Raw Materials Act

25 Nov 2022

Please find attached RTE's contribution to the call for evidence on critical raw materials (in French).
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Meeting with Antoine Colombani (Cabinet of Executive Vice-President Frans Timmermans) and TotalEnergies SE and

25 Oct 2022 · Green Deal state of play

Meeting with Ditte Juul-Joergensen (Director-General Energy) and Bureau Européen des Unions de Consommateurs and

17 Oct 2022 · US-EU Task Force Convening: energy efficiency and energy savings. The California Energy Commission, ACEEE, ASE, Advanced Energy Economy, Arcadia, ComEd, Octopus Energy, OhmConnect, OPower, Uplight and the Covenant of Mayors also participated.

Meeting with Pascal Canfin (Member of the European Parliament) and Schneider Electric

14 Oct 2022 · Green Deal

RTE seeks extra funding and faster permits for grid projects

27 Jul 2022
Topic — EU guidance on accelerating permitting for renewable energy and facilitating power purchase agreements.
Message — RTE requests additional support for infrastructure projects facing rising costs from the crisis. They also want to include all assets necessary for connection in the renewables go-to areas.12
Why — This would help the company manage a major surge in infrastructure costs.3
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Response to Revision of EU rules on Gas

12 Apr 2022

RTE takes note of the European Commission’s proposals to revise the Gas Markets Directive and Regulation. The European Commission is sending a clear message in favour of achieving climate objectives for 2030 and 2050 by including specific provisions for renewable and low carbon gases and by creating a legal framework for the hydrogen market. To support decarbonisation of European electricity mixes and electrification of uses, which are the main thrusts of the European energy system transition towards carbon neutrality, the gas sector, and especially hydrogen and other decarbonised gases, will help to provide solutions whether to decarbonise energy uses that will remain difficult to electrify, such as industry or heavy transport, or to have flexible and controllable decarbonised electricity production facilities which will be necessary for the proper functioning of electricity systems with a very high penetration of intermittent renewable energies (cf. RTE’s Energy Pathways to 2050 [1]). As a result, the development of energy networks must be coherent and based on the integration of energy systems. RTE would like to draw the European Commission’s attention on the following elements of the proposal for a directive on common rules for the internal markets in renewable and natural gases and in hydrogen published on 15th December 2021. The crisis related to the Russian invasion of Ukraine brings the European Union to adopt emergency measures (REPowerEU communication and Gas storage proposal). The following remarks do not concern those emergency measures. Tariff discounts for renewable and low carbon gases (article 16 of the Regulation proposal) The European Commission proposal for a Regulation provides for the application of discounts on injection tariffs to the advantage of renewable and low-carbon gases (article 16 of the proposal). In general, RTE considers that network tariffs are not the most appropriate way to support the development of renewable and low-carbon energies. Tariff discounts may generate adverse effects. When tariffs do not reflect the use of the network by users, tariff discounts are a source of cross-subsidies unfavourable to other users, and in particular to consumers if they are to compensate for the infrastructure’s revenue deficit by paying higher tariffs to cover the costs. If tariff discounts are not compensated for by other users, they directly undermine revenues, and financing and investment capacities of energy infrastructures. Therefore, the ability for energy infrastructures to be adaptive, which is essential for the energy transition, can be undermined too. Although the European Commission proposes to set up an inter-TSO compensation mechanism when the income of one of the TSOs decreases by 10% due to the implementation of tariff discounts, RTE recommends giving priority to other support mechanisms for renewable and low-carbon gases that do not lead to cross-subsidies which could be detrimental to consumers (e.g. through direct public support mechanisms or through market mechanisms, contracts for difference or long term contracts). [1] https://assets.rte-france.com/prod/public/2022-01/Energy%20pathways%202050_Key%20results.pdf
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RTE urges reciprocal data sharing between gas and electricity operators

12 Apr 2022
Topic — Revision of EU rules to facilitate renewable and low-carbon gas markets.
Message — RTE requests that information sharing between gas and electricity operators becomes reciprocal. They recommend that storage and electrolyzer placement be decided jointly.12
Why — RTE would obtain data needed to plan the electricity grid more effectively.3
Impact — Gas operators lose the ability to independently plan new hydrogen infrastructure projects.4
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Response to 2022 Strategic Foresight Report

17 Mar 2022

Please find attached RTE's contribution.
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Response to Review of Directive 2012/27/EU on energy efficiency

19 Nov 2021

RTE would like to draw the attention of the European Commission to the issue of network losses addressed in Article 25 of the proposal. Electricity losses in energy systems are inevitable, mainly due to the laws of physics (technical losses). When electricity is transported between generation and consumption sites, losses occure, the volume of which depends on the power transported, the distance between the injections and withdrawals of electricity, weather conditions and characteristics of the network (length, cross-sections, impedance, mesh, etc.). The proposal for the revision of the Energy Efficiency Directive deals with power losses in Article 25 states that: - TSOs shall map network losses and take cost-effective measures to reduce network losses; - National regulatory authorities shall limit the possibility for TSOs to be remunerated for "avoidable" network losses from the tariffs paid by consumers. RTE believes that the reduction of power losses should not be the only criterion for energy efficiency in electricity transmission networks. Indeed, power losses are highly dependent on the distance between generation and consumption sites and not only on the overall level of electricity consumption. Thus, in the context of the COVID-19 pandemic, final electricity consumption has decreased, with a downward effect on losses, but at the same time the volume of electricity losses in France had increased overall and in some months significantly, in particular due to the use of more distant generation sites, due to the unavailability of nuclear capacity located close to major cities. In addition, the unavailability of these nuclear capacities led to a significant reduction in French electricity exports and an increase in imports, particularly from Spain. Long distance flows have therefore transited through the French electricity transmission network, which has significantly increased network losses. More generally, RTE believes that losses are likely to increase in the coming years for two reasons: - The average distance between new generation facilities and consumption centres will increase, particularly due to the expected development of offshore wind power; - Growing public opposition to overhead power lines will lead TSOs to bury existing ones, to create new underground power lines and to use low expansion cables and phase-shifting transformers. All these measures, which aim to meet the environmental expectations of citizens, will have the effect of increasing electricity losses. Finally, it must be taken into account that some technical solutions, such as low expansion cables, increase losses but avoid building infrastructure. The cost-benefit analysis may lead to the selection of this type of solution, particularly with regard to environmental criteria, even if it generates greater losses than in the past. Consequently, RTE suggests to amend Article 25 in order to consider the carbon footprint of the electricity system as a whole and not the reduction of network losses in isolation. In particular, the limitation on the remuneration of TSOs from tariffs paid by consumers, as provided for in paragraph 3 of this article, should not apply when the carbon footprint of the electricity system is decreasing.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Nov 2021

RTE would like to draw attention of the European Commission to two points that directly affects Transmission System Operators (TSOs) for electricity: • Participation of all generation sources of electricity in network balancing services: In the coming years, the share of renewable energies in the European electricity mix will increase significantly. According to RTE’s report on Energy Futures 2050 (FR: Futurs Énergétiques 2050), published on 25 October 2021, the share of renewable energy in the French electricity mix is expected to reach, depending on the scenario presented, between 50% and 100% whereas this share was only around 25% in 2020. To date, the historical and centralised generation sites supply the bulk of the “system and balancing services” allowing to ensure the supply/demand balance at any moment, the security of the electricity system and the security of the networks. In the future, it will be crucial to involve all types of electricity generation, including units producing electricity from renewable energy, in these “system and balancing services”. Hence, RTE recommends to insert in the text (for example in the article 20-a) a provision specifying that all means of electricity generation, including units producing electricity from renewable energy, shall be involved in providing system and balancing services. To this end, appropriate regulatory incentives responding to the characteristics of all types of the means of electricity generation and expected services could be necessary to encourage the development of these services and maintain a sufficient level for the balance and safety of the system, as well as, for the security of the networks. • Consideration of heat and cooling systems in the development of the transmission network: Article 24-8 of the draft revision of RED requires TSOs to take into account in their network development policy the result of the assessment carried out every 4 years by DSOs of the potential for heat and cooling systems to participate in network balancing and the provision of system services. Given the power levels of centralised heat and cooling systems, RTE is of the opinion that the provision of balancing and system services by these systems is not likely to have any impact on the development of the electricity transmission network. Moreover, TSOs are required, pursuant to the texts on the internal electricity market (Directive 2019/944 and Regulation 2019-943), to ensure non-discriminatory access to market mechanisms , in particular for the provision of balancing and ancillary services. From this point of view, Article 24-8 is problematic because it would lead TSOs to treat centralised heat and cold production systems differently from other players. For those two reasons, RTE recommends to delete all reference to TSOs in article 24-8.
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Response to Updating the EU Emissions Trading System

8 Nov 2021

RTE Réseau de Transport d'Électricité, a player in the energy transition in France and Europe, has taken note of the European Commission's proposals in the Fit for 55 package. Concerning the revision of the EU-ETS, RTE Réseau de Transport d'Électricité notes that : - the emission reduction target in 2030 (compared to 2005) is increased from -43% to -61% for the EU as a whole and that allowances must decrease by 4.2% per year (instead of 2.2% today); - Member States will have to spend 100% (instead of 50%) of the revenues from the auctioning of allowances on actions related to the EU's decarbonisation objectives. As a result, revenues from auctioning of allowances are expected to increase in the years following the revision of the EU-ETS Directive. As a reminder, networks contribute strongly to the energy transition and to the decarbonisation of the economy. Thus, it would be legitimate to devote part of the EU-ETS revenues to the financing of network developments aimed at connecting renewable energy production parks. However, in the draft revision of the EU-ETS Directive published on 14 July, RTE notes that network development is not among the actions eligible for financing by funds from the auctioning of emission allowances. Consequently, RTE believes that it would be desirable to complete, during the legislative negotiations, article 10-3 of the text in order to specify that Member States may use the revenue from the auctioning of allowances to contribute to the financing of network developments linked to the commissioning of renewable energies or other technologies participating in the transition to a decarbonised economy and to best meet the objectives of the Climate Law for 2030 and 2050.
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Meeting with Pascal Canfin (Member of the European Parliament)

14 Sept 2021 · Green Deal

Meeting with Benoît Biteau (Member of the European Parliament)

31 Aug 2021 · Eoliennes en mer

Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

2 Jun 2021

RTE welcomes the Commission’s aim to increase transparency in the market and help prevent greenwashing by providing information to investors about the environmental performance of assets and economic activities of financial and non-financial undertakings. However, the evaluation of the KPIs introduced in the delegated act should be implemented incrementally based on already available data in order to prevent any disproportionate administrative burden for corporates. As there are activities that meet the technical screening criteria under two different objectives (e.g transmission of electricity), the identification of taxonomy-aligned activities should remain at an aggregate level that suits the types of activities that are reported and allow a direct calculation of KPI without having to apply a conventional split when assets, turnover or opex cannot be identified for each aligned activity.
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Response to Revision of the guidelines for trans-European Energy infrastructure

8 Mar 2021

RTE welcomes the European Commission (EC) initiative to review the TEN-E Regulation and its necessary alignment with the Green Deal to support the achievement of climate neutrality. In this respect the input of independent TSOs is crucial for the trans-European network development as a key enabler for the energy transition but also pivotal for the safe and secure operation of networks and the European consumers’ security of supply in an increasingly complex system. The newly introduced mandatory sustainability criterion is an essential step. However, in order to embrace all relevant decarbonisation paths this criterion should reflect the connection of renewable and other decarbonised energy sources to the grid. Moreover, in order to achieve a future-proof piece of legislation, expanding the scope of PCI projects to different technologies should go in hands with updating the eligibility criteria through precise conditions ensuring the European benefit in terms of European integration and of the development of a carbon-neutral energy system. These criteria could reflect the holistic increase of cross-border capacity, the increase of various connected offshore renewable generation technologies and basins in line with the European offshore strategy, and in the case of smart-grids the increase of flexibilities made available through market mechanisms to a decarbonized and more complex energy system. The newly integrated provisions that will allow for a consistent development of offshore electricity grids throughout various sea basins are welcomed. In order to ensure relevant offshore planning choices, sufficient time for the elaboration of the offshore network development plans will be key. This process, involving Member States, ENTSO-E, TSOs and the EC, will require close cooperation amongst all stakeholders to ensure consistency between political will and technical possibilities. In case the EC would develop offshore plans instead of ENTSO-E, the conditions of such a transfer should be clearly defined and responsibilities endorsed by the EC on the plans’ robustness and related risks incurred to investments, implementation and future operations. Furthermore, the TYNDP should be updated every 3 years like the offshore plans. More generally, cross-sectorial infrastructure planning requires a strengthened role for the ACER and EC in the governance. However this strengthening must be coherent with national competencies, responsibilities and choices. In particular: - an EC’s competence for the choice of scenarios needs to leave the necessary leeway for defining National Energy and Climate Plans and for the competences of national regulators in terms of approval of regulated investments. - the definitions of CBA or cost allocation methods for offshore networks deserve to be supported by the expertise of ENTSO-E and defined in a concerted framework with the Member States to ensure shared regulatory targets and models. Therefore, it appears important to frame more precisely the respective role and liabilities of ACER and the EC in these processes (joint scenarios, CBA methodologies, infrastructure gaps). RTE welcomes the EC’s will to simplify administrative and permitting procedures. It is, nevertheless, essential to pay attention to the new layer of complexity that may result from these provisions ( e.g. one-stop shops) given the fact that administrative and permitting procedures fall within national competences. Finally, the inclusion of projects of mutual interest (PMI) is more than welcomed to take into account the need to develop infrastructure projects with third countries. RTE agrees with a CEF financing of PMI projects only to the portion sited on the territory of EU Member States. However, particular attention should be paid to the possibilities of a joint financing for the remaining section connecting the third State (eg in the Mediterranean) through development aid or EU’s neighborhood policy.
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Response to Enhancement of European policy on critical infrastructure protection

27 Jul 2020

Under the provisions of the Defence code, the French legislative framework for critical infrastructure protection is one of the most robust at the European level. As a critical infrastructure operator (CIO), RTE bears all the expenses for the protection of electricity transmission network infrastructures on the French national territory. This expenditure is validated by the French Energy Regulatory Commission (Commission de Régulation de l'Energie). Thus, RTE invests several million euros a year to improve the safety and security of its sites (fire safety standards, video surveillance equipment, access control, remote surveillance) and to ensure the physical protection of infrastructures (dispatching sites, substations), and implements a comprehensive set of measures in the domains of human resources (protection of employees, background checks…) and cybersecurity. Yet, the cross-border challenges stemming from the COVID-19 pandemic and rising climate risks (such as heat waves, storms, floods and fires) as featured in the New EU Strategy on adaptation to climate change have underlined the need for a European approach, including in the energy sector, notably in terms of critical infrastructures protection. In this context, RTE welcomes the timely reactivation of the Thematic Network on Critical Energy Infrastructure Protection (TNCEIP) as key expert group of owners and operators of infrastructures in the energy sector, which has much contributed to the development of the European Critical Infrastructure Protection (CIP) policy between 2013 and 2016. RTE welcomes the future EU Security Strategy 2020-2025 and agrees with the European Commission that the existing legislative framework for the protection and resilience of European critical infrastructures is inadequate in view of the evolution of threats and risks patterns. In this perspective, the revision of the European Critical Infrastructure (ECI) Directive 2008/114/EC is deemed necessary. Therefore, RTE supports policy option 4 “New requirements focused on essential services” considered by the European Commission in its initial impact assessment. Under this option, the European Commission would propose a general framework defining the main principles and expected outcomes of a EU critical infrastructure protection policy, leaving it to sectoral or specific cross-sectoral legislation to determine more detailed requirements where necessary. In terms of approach, the focus would shift away from identifying and protecting a narrow set of European critical infrastructures to the protection and resilience of infrastructures providing “essential services” as already provided by the NIS Directive for information system operators. • Such a new approach would thereby ensure that all relevant sectors – beyond only energy and transport ones – providing essential services are included in the European critical infrastructure protection policy – e.g. electricity distribution system operators (DSOs), and would be aligned with the policy reflected in the NIS Directive. • By doing so, the European legislative framework would better take into account interdependency between critical infrastructures operators and/or providers of essential services, and a potential cross-border trickle-down effect, to be further dealt with by sectoral or specific cross-sectoral legislation. • This corpus of European rules, expressed in terms of resilience capacities and not in terms of technical standards for infrastructures protection, would be more likely to make electricity transport system operators (TSOs) and DSOs of the 27 Member States agree on common standards, thereby making it possible to mitigate the risks or consequences of an attack on a weaker element or link of the electricity network. • Finally, such a convergence would ensure a better harmonisation of security costs borne by operators and reflected in network access tariffs.
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Meeting with Kadri Simson (Commissioner) and

10 Jul 2020 · Exchange of views on energy system integration and hydrogen strategies.

Response to Strategy for smart sector integration

5 Jun 2020

Our convictions on the challenges of smart sector integration Transmission System Operators are natural enablers of sector integration • Europe's ability to accommodate the development of renewable energies, electric mobility, hydrogen, etc. depends on the transformation and reinforcement of European electricity networks. This is the first condition to strengthen sector integration. • This transformation will make it possible to develop new sources of flexibility that will reduce the adaptation costs of the electricity system (through grids digitalisation in particular). • The model of electricity transmission system operators enables it to meet these challenges. They have the neutral and independent expertise essential to analyse system needs, to plan investments in the welfare interest under the supervision of national regulators, as well and above all to ensure efficient and secure operation of the power system. • Technological progress can be very swift. They can contribute to shifting the centre of gravity of industrial ecosystems outside Europe. Sector integration raises the question of European autonomy over key technologies for energy transition. • The deployment of new infrastructures is often hampered by issues of societal acceptance. This can only be mitigated by political support at national and local level. • The present regulatory framework is already complete. Network operators need first of all stability, but also that the rules are developed taking into account national/local realities. It is essential that technological solutions or investment choices are not framed too quickly. • Sector integration must therefore be gradual, step by step, depending on the technological options available and the energy policy guidelines at European and Member State level. RTE's recommendations for a flexible and resilient power system in support of smart sector integration Support the ongoing adaptation of the TSOs' industrial model to foster innovation. • Recognise the key role of electricity transmission network infrastructures and their digital "twins" in the European sector integration strategy in order to achieve EU 2050 climate objectives. • Support the investments necessary for the adaptation and reinforcement of grid infrastructures and their digital transformation. Define common and efficient management tools • Define a more open and transparent framework for the development of European multi-energy scenarios to identify technological options and key factors for the evolution of supply and demand in the long term. A European Energy Transition Observatory could complement the expertise of the TSOs and their European associations ENTSO-E and ENTSO-G. • Propose a reasonable periodicity for the development cycle of multi-energy scenarios to ensure a relevant result. Identify complementary sources of financing to meet the resource requirements induced by a multi-energy approach. • Continue to improve cost-benefit analysis methods in the interest of the community (CBA) through the homogeneous integration of European climate objectives for the analysis of investment needs in the different energy sectors (study of "reference value" of carbon emissions in the long term that can be used for welfare assessment). • Identify processes considered as "green", i.e. those that effectively contribute to the reduction of greenhouse gas emissions, for example, by issuing certificates of guarantee of decarbonated or recycled origin. A stable and incentive regulatory framework • Promote stable and incentive "long term regulation" to meet structural investment needs. • The regulatory framework shall ensure that the level of investment needed matches the decarbonation targets for 2030 and beyond.
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Meeting 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 Ditte Juul-Joergensen (Director-General Energy)

15 Oct 2019 · Energy infrastructures and electricity market developments.

Meeting with Ivo Schmidt (Cabinet of Vice-President Maroš Šefčovič)

28 Jun 2018 · E- MOBILITY

Meeting with Miguel Arias Cañete (Commissioner) and Amazon Europe Core SARL and

23 Mar 2018 · Energy sector

Meeting with Phil Hogan (Commissioner)

29 Nov 2017 · Interview

Meeting with Dominique Ristori (Director-General Energy) and Redeia and Redes Energéticas Nacionais, S.G.P.S., S.A.

17 Mar 2016 · Energy Union, interconnection

Meeting with Miguel Arias Cañete (Commissioner) and ENEL SpA and

23 Feb 2016 · 2nd EU Energy Summit - breakfast roundtable

Meeting with Miguel Arias Cañete (Commissioner) and TenneT Holding B.V. and

16 Feb 2016 · Market Design

Meeting with Maria Cristina Lobillo Borrero (Cabinet of Vice-President Miguel Arias Cañete)

5 Feb 2016 · Electricity market design

Meeting with Dominique Ristori (Director-General Energy)

5 Feb 2016 · Energy policy

Meeting with Manuel Szapiro (Cabinet of Vice-President Maroš Šefčovič)

5 Feb 2016 · Energy Union

Meeting with Dominique Ristori (Director-General Energy)

22 May 2015 · Energy Union

Meeting with Dominique Ristori (Director-General Energy)

27 Mar 2015 · Energy Union

Meeting with Markus Schulte (Digital Economy) and VERBUND AG and

3 Dec 2014 · Smart Grids