Mouvement écologique statement on CREOS’s Network Development Plan 

MECO  reacted with a statement regarding the ten-year network expansion plan (Ten Year Network Development Plan 20242034) presented by CREOS and published by the Luxembourg Institute of Regulation (ILR) as part of the public consultation. 

Luxembourg needs a modern and robust electric grid to ensure power supply security and support the energy transition. CREOS’s planning is therefore understandable. However, the Mouvement écologique identifies the following areas for optimization and shares numerous proposed improvements, aligned with recommendations from the ILR in the document “Orientations et recommandations relatives aux processus d’établissement et de mise à jour des plans décennaux de développement des réseaux d’électricité.” 

The Government must define clear planning criteria 

• Article 8 of the Electricity Market Act provides that the state can issue, by grand-ducal regulation, precise directives on which the grid operators must base their network development plan. Such a regulation does not yet exist; Mouvement écologique deems its creation highly relevant. 

• It also appears problematic — albeit legally permissible — that CREOS both develops consumption scenarios, is responsible for the network expansion plan, and directly benefits as an investor. Clear state guidelines via grand-ducal regulation on the general orientation of energy policy to be used as assumptions in the network development plan would be all the more important to ensure a separation of responsibilities. 

Ensure parallelism and coherence between the “transmission network” and the “distribution network” 

• The current plan focuses primarily on the high-voltage grid. However, power networks function only as an integrated system: the distribution grid — particularly regarding flexibility and the integration of decentralized production — plays a central role. 

• Mouvement écologique expects that, within the framework of the biennial review of the distribution network, a distribution plan will also be presented and discussed publicly to ensure the necessary overall coherence. 

Strengthen transparency of justifications through analyses and calculations 

• Many assumptions in the plan are insufficiently substantiated. The exact calculation methods, detailed expected developments, cost-benefit analysis, the extent to which the guiding principle “Nova” (optimize the grid before reinforcement or expansion) was taken into account… all those modelings are not sufficiently transparent. 

• This shortcoming must urgently be addressed in future plans. 

Security of supply today is ensured not only by maximum grid expansion but also by increasing flexibility 

• The current plan strongly relies on maximum supply security through the expansion of extra-high-voltage lines, far beyond the N1 standard. No public discussion on this has taken place. Must every load be secured even during the few peak hours under N2 conditions (and even beyond if considering the line to Aubange), or could interruptible loads and flexibility reduce the need for expansion? Flexibility mechanisms serving the public interest have been scarcely considered. Mouvement écologique therefore calls for these aspects to be given significantly more weight in future plans. 

• Given new strategic government initiatives (e.g., hydrogen network, battery storage), future versions of the network expansion plans must better integrate these technologies for network stabilization. 

• Simultaneously, CREOS should present a transparent evaluation of the trade-off between maximum grid expansion and a targeted reduced expansion combined with increased flexibility — including costbenefit considerations. 

The legally prescribed framework for network expansion provides a crucial basis for discussion about this fundamentally important development for both supply security and the energy transition. Mouvement écologique hopes that this position statement will enrich the ongoing discussions and their further evolution.