UCTE welcomes the European Commission's Green Paper initiative on sustainable energy. The document discusses several key issues: 1) The importance of a highly reliable power system to prevent blackouts through cooperation between transmission system operators across Europe in one synchronous grid. 2) UCTE has developed robust reliability standards and information sharing to securely operate this large interconnected system. A balance is needed between regional cooperation and rules. 3) Any EU-wide grid code must be based on experience and not compromise security, while respecting regional differences. Infrastructure investment needs support to develop markets and trade while ensuring supply.

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UCTE reaction to the EC's “Green Paper for a European Strategy for
Sustainable, competitive and Secure Energy”
Brussels, 22 September 2006
1. Introduction
UCTE welcomes the European Commission’s initiative of the Green Paper that initiated a broad and
constructive dialogue with all concerned stakeholders towards a European Strategy for Sustainable,
Competitive and Secure Energy Supply. UCTE supports such a pragmatic approach by EC.
UCTE is the association of Transmission System Operators of the largest synchronous interconnected
area out of five electrical systems in Europe (UCTE, NORDEL, UK, Ireland, and Baltic States), gathering
23 both EU and non-EU countries within one single continental power system.
The UCTE remarks focus mainly on concerns regarding the security of operation and EU grid code, the
obstacles to the development of European grids, the currently performed feasibility assessment of
extensions of the power system (incl. risk analysis) and the integration of wind power calling for
reinforcements and improvements of the transmission system. Other Green Paper issues are addressed
by the EU TSO members of UCTE through their sister association ETSO and in some cases by other
relevant European associations or individual companies.
One of the key factors for a successful development of a single EU market ( and as such an absolute
priority) is a highly reliable and secure power system operation preventing interruption of electricity
supply or even blackouts – this is also the main UCTE mission. The high professional expertise and
long term practical experience of UCTE members in such fields are a precious support in order to
precise and implement the ambitious objectives highlighted by the EC for a future well functioning
sustainable, competitive and secure energy supply in Europe.

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2. Synchronous interconnected power system
The synchronous interconnected power system always decisively contributed to a secure and reliable
energy supply thanks to the possibility of permanent mutual assistance in terms of (i) power flows
wheeling across neighbouring and non-neighbouring networks and of (ii) foreign generation reserves
accessibility.
Since 1951 UCTE has been defining and publishing common security rules to operate a continuously
extending synchronous power system with high performance and continues to provide permanent efforts
towards secure operation with the only intention of continuity of energy delivery to all consumers and
welfare of the European community.
UCTE has achieved very substantial progress over the last years in up-dating and extending its
reliability standards (Operation Handbook) making these binding via an inter-TSO Multi-Lateral
Agreement (MLA). It presently also develops an ambitious self-regulating mechanism called
Compliance Monitoring and Enforcement Program (CMEP) the first pilot project of which started in early
2006. Moreover UCTE has defined and implemented different types and levels for data and information
exchange between TSOs to improve the predictability of power system behaviour and transmission
capacity far and near real time of delivery. For the daily TSO business high speed data links between
control centres are the crucial backbone for safe operation of the transmission infrastructure and the
decision-making process for contingency planning and countermeasures whenever an event threatens
the continuity of transmission and balancing.
The development of a more region-based co-ordination and information exchange between involved
TSOs should be pursued along the development of regional markets; this development should also be
followed by additional interregional rules and procedures - where this is appropriate and conditional for
secure long distance exchange of electricity between regional markets.
However, well functioning regional electricity markets are not only a matter of intensive cooperation
between TSOs and power exchanges. They clearly imply especially in the preparation phase of these
markets a consistent and harmonised support of the involved regulators.

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3. EU grid code
UCTE has set-up over many years robust, experience-based common regional technical rules adapted
to the specificities of its synchronous interconnected and highly meshed transmission infrastructure.
UCTE has transformed its earlier guidelines and recommendations into clear and enforceable standards
and requirements for security of operation. All UCTE members are committed to implement these
standards recognized as best applicable practices in the present context of market and regulation.
Nevertheless, it should be emphasized that the different synchronous areas and power systems have
different security rules due to their major technical, geographical, generation mix potential and other
specific differences of size, concept and performance: it would be counterproductive respectively even
useless when different regional rules would be mixed or harmonized without accepting the fact that
regional grid and specific generation characteristics may require a different rule and standard setting.
Since the Operation Handbook as security standards framework is almost completed (Policies 1-7) and
became binding by MLA that came into force on 1 July 2005, a next step towards a pan-European
harmonized set of reliability and security requirements also binding for transmission system users is at
stake.
Concerning the potential setup of a “EU grid code” in terms of grid access, cross border trade,
congestion management and other harmonized market rules, UCTE fully supports the work to be
undertaken and reminds again that any new common rules must be experience-based, instead of any
“trial and error method”: Power System security is and should remain top priority. UCTE will
continue to work in this context in the direction of relevant European stakeholders, Regulatory
associations and EU Commission in close co-operation with ETSO and other sister TSO associations.
4. Priority EU Interconnection Plan
This point recalls unambiguously the 10% minimum interconnection level between Member States, set
by the Barcelona Summit as a called-for prerequisite for a “truly competitive and single European
electricity market”. UCTE notes that in spite of this value being much more than 10% for some
countries, this target has not relieved existing bottlenecks: congestions continue to occur not only on
interconnectors, but also within national networks. Consequently the UCTE high voltage domestic and
cross border transmission system faces a need for re-enforcements.

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UCTE completely agrees on the general need to stimulate transmission infrastructure investments and to
accelerate authorization and licence procedures for new high voltage lines and upgrading existing
ones, to be able to continue facilitating the developments of sustainable energy and international trade
within the framework of reliability and security of supply.
The success of the Trans-European Energy (TEN) program developed so far as well as of the recently
adopted new guidelines on cross border energy transmission could be further increased via achieving a
better public acceptance at all necessary levels (national, regional, local) for the need of high
voltage electricity lines, the construction of which is also today hindered by extremely long
authorization procedures (5-10 years). At the same time, also a better information and awareness of the
public at all levels should be achieved with EU-support.
Therefore, UCTE is calling together with ETSO and other sister associations for an adapted and
coherent framework for the public decision making process at European, national regional, and local
levels, in order to convince European civil society of the general interest and to speed up project
implementation, still respectful of both the environmental conditions and the security of supply objective.
UCTE fully supports and substantially contributes for continental Europe to the EU-wide System
Adequacy Forecast (published by ETSO on behalf of all TSO associations) analysing the impact at
medium and long term of national power systems developments including generation and transmission
capacity. This exercise is at present a fundamental contribution by the TSO community to achieve for
stakeholders and markets a 10-year ahead visibility for the needed development of the electricity
systems from the perspective of transmission system operators.
With regard to the Energy technology plan, UCTE would support innovative solutions in order to ease
the construction of new transmission lines via research initiatives concerning the undergrounding lines at
lower costs, and the increase the transmission capacity of conductors. Such - partly technology-driven -
infrastructure improvements would no doubt also increase the benefits of customers and society taken
from electricity systems.

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5. UCTE Policy about requested extensions of the power system towards East
UCTE faces important challenges concerning the requested development of the EU power system
towards East. UCTE has already proved its competence to interconnect the CENTREL countries,
Romania and Bulgaria in 1995 respectively 1998 Western Ukraine and to re-connect the South-East
Europe in 2004.
Three other systems are presently requesting to synchronously interconnect their systems with the
UCTE grid (IPS/UPS, Turkey, Ukraine/Moldova), the Maghreb being already interconnected since 1999.
Such extensions might be achieved via adoption and where necessary adaptation of technical standards
as required by the UCTE Operation Handbook as well as under legal conditions according to the a.m.
MLA. UCTE is also very concerned about “limits” (technical, legal, efficiency and manageability of
coordination tasks, etc.) to the enlargement of the EU power system which could for example
double in size alone in case of an interconnection with IPS/UPS systems. Presently running projects and
studies will detect security risks for a non-interrupted electricity supply and define and safeguard
additional reliability measures and procedures. .
UCTE underlines that new entrants who are opting for a full integration will have to fully respect its
binding security rules. Of course UCTE as technical association of TSOs does perform on request and
with the support of EC feasibility studies and other investigations about possible (inter)connections and
measures to be taken by the requesting parties.
But UCTE cannot take on its own final decisions for extension of the synchronous area. Besides the
UCTE assessment of the technical feasibility of such extensions, other European and national authorities
as well other conditional stakeholders (regulators, market parties, etc.) have to contribute –- with own
investigations and assessments to such a complex decision process as well (e.g. concerning the
reciprocity of market conditions and the environmental standards)
6. RES Wind issues
UCTE and its members are firmly supporting the development of renewables like wind energy but still
underline that the rapid development of wind power capacity is not in step at all with the needed
development or re-enforcement of the high voltage transmission infrastructure as indicated
before. The complex predictability of wind farms power output capacities and the common regime of
wind in some regions, may lead in the day-to-day business to wide deviations of generation in relation to
foreseen programs and of actual flows in relation of foreseen loads of transmission lines. This results for

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example in the fact that presently more and more regulating and reserve power is being used for
balancing unforeseen deviations caused by the variations of wind generation output.
Therefore UCTE has launched in co-operation with ETSO and with the involvement of relevant European
stakeholders an initiative to perform a European wide wind integration study. Main objectives are to
address the specific network issues and to formulate proposals for a generic and harmonized European
wide approach.
7. Conclusion
UCTE welcomes the debate on several aspects of a coherent EU energy policy and intends to be an
active partner in the discussion about UCTE relevant issues as indicated in the above text.
Key words of UCTE's priorities are clear and binding security standards and rules combined with a
self-regulating mechanism for compliance monitoring and enforcement, reinforcement of
transmission infrastructure capacity by harmonized and accelerated authorisation and license
procedures, extension of the synchronous area in accordance with compliance of security rules
within the legal framework of the inter-TSO agreement and a harmonized integration of renewable
energy within the conditions of a secure and reliable operation of transmission infrastructure and power
system.
As stated above, TSO associations and individual TSOs as energy infrastructure operators have been
working for decades on safety aspects and solutions to realize a security of supply of a high quality as it
is to-day in the energy sector. Concerning the Critical Infrastructure Protection (CIP) issues, it will also
be a great challenge for these operators already also dealing with additional security aspects, to
achieve the same performance even under possible specific external threats aiming at disrupting parts
of the European or the national power supply systems. Working together with gas infrastructure
operators in the Energy Security Platform, the associations will be among the partners of the European
Commission towards defining balanced solutions without distortion of energy markets nor decrease of
the actual service quality level.