Hybrid projects : How to reduce costs and space of offshore development : North Seas offshore energy clusters study.
Date: 2019-05-24
Institutions: Directorate-General for Energy
Subjects: North Sea, costing, innovation, new technology, offshore oil structure, photovoltaic cell, renewable energy, solar energy, wind energy

b  

Hybrid projects: How to reduce costs 
and space of offshore developments 
North Seas Offshore Energy Clusters study 

Roland Berger GmbH 
21 December 2018 [revised version 20 May 2019] 

 
 
 
 
 
  
 
 
 
 
 
ii   HYBRID PROJECTS: HOW TO REDUCE COSTS AND SPACE OF OFFSHORE DEVELOPMENTS  

  North Seas Offshore Energy Clusters study 

Contact: 

Uwe Weichenhain (uwe.weichenhain@rolandberger.com) 

Authors: 

Uwe Weichenhain 
Simon Elsen 
Thomas Zorn 
Sebastian Kern  

Contract specifications: 

Contract no. ENER/B1/2016-326 
Project title "Development of the North Seas offshore energy potential – a cluster-based approach"  

This study was prepared in friendly cooperation with: 

The UK Department for Business, Energy and Industrial Strategy (BEIS), the Belgian Federal Public 
Service  (FPS)  Economy,  the  Dutch  Ministry  of  Economic  Affairs  and  Climate  Policy  (MoEA),  the 
German Federal Ministry for Economic Affairs (BMWi), the Danish Ministry of Energy, Utilities and 
Climate (MoEUC), the UK Office of Gas and Electricity Markets (Ofgem), the Belgian Commission for 
Electricity and Gas Regulation (CREG), the Dutch Authority for Consumers and Markets (ACM), the 
German  Federal  Network  Agency  (BNetzA),  the  Danish  Utility  Regulator  (DUR),  National  Grid 
Ventures,  Elia,  TenneT  TSO  B.V.,  TenneT  TSO  GmbH,  Energinet,  EnBW  Energie  Baden-
Württemberg, innogy, Ørsted and Vattenfall. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Abstract 

Europe’s energy system is changing, driven by society’s desire to decarbonise and switch to cleaner, 
renewable energy sources. The European Commission and the EU Member States back these goals; 
they have signed the UN’s Paris Agreement to limit global temperature rises and agreed to increase 
the amount of energy produced from renewables. 

These  aims  are  only  achievable  with  offshore  wind  power.  To  fulfil  them,  existing  offshore  assets 
should be cost-effectively and sustainably expanded to fully utilise the vast wind-energy potential of 
the North Seas. 

Hybrid projects offer a solution. They combine offshore generation and transmission assets, which 
conventionally operate as separate entities. This enables them to link projects and provides a platform 
for  coordination  between  countries.  Such  projects  have  several  advantages  over  conventional 
offshore projects. They are cheaper, use less space and pave the way towards a future integrated 
energy  system  in  the  North  Seas  region.  Ultimately,  they  can  contribute  to  making  the  energy 
transition and decarbonisation happen. 

As such, there is a clear need to assess the use of hybrid projects in real terms. This study identifies 
18  potential  hybrid  projects,  based  on  existing  conventional  projects  in  the  North  Seas  that  are  in 
early-stage  development.  It  assesses  the  five  most  feasible  projects  against  their  conventional 
reference cases in terms of capital expenditures,  lifetime operating expenses  and socio-economic 
welfare. 

The study finds that the five projects show cost saving potentials of up to 10%, or up to EUR 2,500 
million, depending on the size of the comparable conventional project. But it also finds that hybrid 
projects face significant legal, regulatory and other barriers. To address these, the study proposes 
project-specific  Action  Plans  outlining  the  mitigation  measures  stakeholders  can  take.  Finally,  the 
study provides recommendations on implementing future hybrid projects, thereby paving the way to 
a future-proof European energy system. 

 
 
 
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Executive Summary 

The European energy system is rapidly changing. The continent’s energy transition is in full swing, 
with production switching from conventional fuels to renewable sources. This process is being driven 
by society’s desire to decarbonise and mitigate the effects of climate change.  

The European Commission and EU Member States actively support these goals. In December 2015 
they committed to decarbonisation in Europe by signing the Paris Agreement. This plan, a product of 
the 21st Conference of the Parties of the United Nations Framework Convention on Climate Change, 
aims to limit the rise in global temperatures to no more than 2° Celsius above pre-industrial levels, 
while actually working towards a limit of 1.5° Celsius. EU members have also agreed to produce 32% 
of consumed energy from renewables by 2030. A rulebook produced at the 24th Conference of the 
Parties in Katowice in December 2018 supports the implementation of the Paris Agreement. It will 
help governments measure greenhouse gas emissions, report progress towards curbing carbon use 
and mobilise USD 100 billion a year to fund climate policy. 

These aims, and indeed the energy transition itself, are dependent on offshore wind power. But to 
fulfil them, existing offshore assets should be cost-effectively and sustainably expanded. 

Why hybrid projects? 

The  vast  offshore  wind-power  potential  in  the  North  Seas  is  one  of  Europe‘s  greatest  renewable 
assets. The North Seas region has an estimated economically attractive potential of more than 635 
GW by 2030. It is already being tapped, with installed wind capacity expected to reach 90 GW in the 
next ten years. But to fully exploit the potential, wind farms need to be built ever further out to sea. 
This makes development more complicated and more expensive. If viable projects are to be realised, 
it is crucial to reduce the costs of and space needed by offshore assets using innovative solutions 
that efficiently connect wind farms to land. Hybrid projects offer just such a solution. 

Traditionally, offshore wind-power projects have a strong national focus with the power transmission 
line feeding just one national grid. Additionally, offshore generation is usually not coordinated with 
nearby developments in other countries. Hybrid projects are different; they combine generation and 
transmission  elements,  linking  two  or  more  countries  and  providing  a  platform  for  coordination 
between them. In the North Seas, this could, for example, mean a joint development of an offshore 
wind farm and an interconnector, allowing a Dutch wind farm to be connected to the British and Dutch 
grids.  

Benefits of hybrid projects 

Compared to their conventional reference cases, in which generation and transmission assets are 
developed and operated as separate entities, hybrid projects have several benefits. As well as offering 
significant potential for cost savings, they take up less space, thereby leaving more space available 
to  other  users  of  the  sea  and  lowering  environmental  impact.  In  the  North  Seas,  they  also  create 
cross-border links, helping to provide additional interconnection capacity and underpinning the EU’s 
internal energy market. The European offshore industry and job market benefit, too. In short, they can 
make the energy transition and decarbonisation happen.  

The use of hybrid projects to exploit the North Seas’ wind-power potential also has political support. 
In  2016,  countries  in  the  North  Seas  region  (Ireland,  the  United  Kingdom,  France,  Belgium,  the 
Netherlands, Luxembourg, Germany, Denmark, Norway and Sweden) signed the North Seas Energy 
Cooperation declaration. It aims to strengthen cooperation on energy and improve conditions for the 
development of offshore wind energy, ensuring a sustainable, secure and affordable energy supply 

 
 
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in  the  region.  As  part  of  this,  it  encourages  transmission  system  operators  and  offshore  wind 
developers to become early movers in hybrid projects. 

Such  initiatives  are  helping  hybrid  projects  to  gain  momentum.  Although  only  one  has  been 
implemented so far – Kriegers Flak, which is nearing commissioning – more and more stakeholders 
in the North Seas region are now taking an interest and developing a better understanding of project 
economics and benefits. At the same time, progress in harmonising EU energy policies and regulation 
has changed perceptions of the challenges developers face in realising them. 

However,  hybrid  projects  are  more  challenging  to  develop  than  conventional  offshore  wind-power 
projects. For example, they pose significant legal and regulatory barriers. Bearing in mind their key 
role in the energy transition and decarbonisation, this means there is a clear need to assess their use 
in practice. 

What are the key findings across hybrid projects? 

The purpose of this study is to assess hybrid projects in as real terms as possible, or more specifically: 

1.  To  assess  the  costs  and  benefits  of  hybrid  projects  compared  to  conventional,  separately 

developed offshore generation and transmission projects (reference cases); 

2.  To develop concrete Action Plans to overcome barriers to hybrid project development. 

It also presents project-specific findings for feasible hybrid projects and gives recommendations on 
taking them forward.  

1.  Assessment of costs and benefits 

The study identifies 18 potential hybrid projects based on conventional developments in the North 
Seas which are in the early stages of planning or construction. These are located in four North Seas 
regions: the Irish Sea / North Channel; the UK-NL-BE cluster; Dogger Bank; and the German Bight.  

Starting from 18 hybrid project ideas, the ten most promising hybrid projects are assessed against 
their  reference  cases,  with  the  analysis  focusing  on  differences  in  terms  of  capital  expenditures, 
lifetime operating expenses and lifetime socio-economic welfare over a 25-year period. Other factors, 
such  as  the  environment  and  the  European  Union's  energy  policy  targets,  are  also  considered. 
Stakeholders  such  as  transmission  system  operators,  offshore  wind  farm  developers,  national 
ministries and regulatory authorities across Ireland, the United Kingdom, Belgium, the Netherlands, 
Germany and Denmark were involved throughout the study.  

Of  the  ten  hybrid  projects,  five  are  found  to  be  significantly  more  beneficial  than  their  respective 
reference case:  

▪  The "IJmuiden Ver to UK" hybrid project – connects a Dutch offshore wind farm to British and 

Dutch electricity markets. 

▪  The  "Combined  Grid  Solution  IJmuiden  Ver  to  Norfolk"  hybrid  project  –  provides  an  offshore 

connection between a Dutch and British offshore wind farm. 

▪  The "COBRA Cable" hybrid project – connects a German offshore wind farm to the Dutch and 

Danish electricity markets via the COBRA Cable interconnector. 

▪  The  "DE  OWF  to  NL"  hybrid  project  –  connects  a  German  offshore  wind  farm  to  the  Dutch 

electricity market. 

▪  The "North Sea Wind Power Hub" (NSWPH) hybrid project  – connects offshore wind farms to 

several North Seas countries via a hub in proximity to the Dogger Bank area. 

 
 
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The five projects show potential for cost savings of between EUR 300 million and EUR 2,500 million, 
depending on the size of the comparable conventional project. This translates into 5 to 10% of total 
project costs. More detail about the findings for each of the five projects can be found in the “What 
are the project-specific findings?” section. 

The  assessment  findings  provide  only  a  starting  point  for  the  development  of  hybrid  projects.  As 
projects proceed, more action is required, for example on technical planning, preparation of the supply 
chain and analyses of electricity flows and operational feasibility. And most importantly, barriers to 
development need to be overcome.  

2.  Assessment of barriers and development of Action Plans 

Legal, regulatory and other barriers hinder the development of hybrid projects. The study identifies 
16 distinct barriers and assesses mitigation options for them. It then proposes concrete actions that 
transmission  system  operators,  offshore  wind  farm  developers  and  public  authorities  can  take  to 
overcome these barriers. Only 13 of the 16 barriers are considered in detail for each project as three 
will be dealt with by measures in the EU’s Clean Energy Package, which is in the process of being 
formally adopted by Member States. 

The  13  barriers  concern  legal  requirements,  planning  procedures  and  energy  market  rules  in  the 
North Seas countries, or more specifically: 

▪  Uncertainty about responsibility for project development;  

▪  Uncertainty about regulation deriving from jurisdiction over cross-border cable systems; 

▪  Uncertainty about market arrangements;  

▪  Uncertainty about hybrid cable system classification;  

▪  Failure of developers to align planning across assets and countries;  

▪  Uncertainty about responsibility and rules to provide access to maritime space for offshore wind 

farms (location selection, site pre-investigation and tender execution); 

▪  Uncertainty about responsibility and rules to provide access to maritime space for offshore wind 

farms (tender design); 

▪  Lack of regulated revenues for anticipatory investments;  

▪  Uncertainty about applicable subsidy schemes for renewably energy sources;  

▪  Limited engagement of public stakeholders;  

▪  Uncertainty regarding the British market; 

▪  Disproportionate allocation of costs and benefits across involved stakeholders;  

▪  Uncertainty about legislative regime for power-to-gas and related infrastructure. 

The construction of the Kriegers Flak hybrid project in the Baltic Sea, the one hybrid project nearing 
commissioning, shows that these barriers are surmountable if stakeholders make a concerted effort. 
To  ease  the  process,  the  study  proposes  Action  Plans  containing  specific  mitigation  measures  to 
overcome  each  barrier.  In  general,  the  measures  tackle  ad  hoc  or  project-specific  problems.  But 
where they concern all hybrid projects, for example the limited engagement of public stakeholders, 
they could also be effectively addressed at the North Seas Energy Cooperation.  

 
 
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What are the project-specific findings? 

The  study  produces  both  cross-project  and  project-specific  findings.  The  former  result  from  the 
assessments  of  the  18  potential  hybrid  projects  versus  their  respective  reference  cases  and  are 
covered in earlier sections. The latter relate to the five most feasible hybrid projects, with a particular 
focus on the 13 barriers and their mitigation measures. The five are summarised below.  

IJmuiden Ver to UK 

This hybrid project connects a Dutch offshore wind farm to the United Kingdom and the Netherlands. 
Over the 25-year assumed asset lifetime, it yields savings of about EUR 400 million compared to the 
reference  case.  These  are  driven  by  the  elimination  of  65  km  of  cable  and  an  onshore  converter 
station.  

The  project  faces  several  barriers,  although  others  are  bypassed.  For  example,  the  developers 
envisage  a  market  arrangement  (division  of  bidding  zones)  in  which  the  wind  farm  only  sends 
electricity  to  its  Dutch  home  market.  This  removes  the  major  barrier  of  defining  applicable 
transnational subsidy schemes for renewables – essentially agreeing which country will foot the bill. 
Even so, the feasibility of the expected market arrangements and the accompanying national subsidy 
scheme  for  renewables  still  need  to  be  aligned  with  the  relevant  state  authorities.  Other  critical 
barriers remain. These include uncertainty over regulated revenues for anticipatory investments, or 
the  shorter-term  set-up  costs  that  help  to  stave  off  higher  costs  in  the  long  term,  and  the 
disproportionate  allocation  of  costs  and  benefits  among  stakeholders  and  the  two  countries.  It  is 
unclear if the hybrid cable system classification barrier, or the laws limiting how different cables are 
allowed to be used for different functions, also applies in this case. 

While  mitigation  of  all  these  barriers  is  possible,  another  is  making  this  difficult:  uncertainty 
surrounding the British market. The project’s advancement is particularly complex due to the ongoing 
negotiations regarding the withdrawal of the UK from the European Union, the associated uncertainty 
regarding the country’s participation in the European Union's internal energy market and concerns 
about future regulation changes. 

Combined Grid Solution IJmuiden Ver to Norfolk 

The project provides an offshore connection between the offshore substations of a British and a Dutch 
wind farm. Using the same 25-year assumptions, it yields lifetime savings of about EUR 720 million 
compared  to  the  reference  case,  thanks  to  the  elimination  of  130  km  of  cable  and  two  onshore 
converter stations.  

Like the "IJmuiden Ver to UK" hybrid project, the stakeholders envisage a market arrangement where 
the offshore wind farms only send generated electricity to their home markets – in this case the UK 
and  the  Netherlands.  Thus,  the  definition  of  an  applicable,  transnational  subsidy  scheme  for 
renewables  is  rendered  unnecessary.  The  classification  of  parts  of  the  overall  cable  system  as  a 
hybrid cable system is also unlikely to be a problem. But again, the envisaged market arrangement, 
subsidy  schemes  for  renewable  energy  sources  and  cable  system  classification  will  need  to  be 
validated with the relevant authorities. 

Barriers do exist, however. The two barriers of uncertainty regarding regulated revenues for required 
anticipatory  investments,  and  the  disproportionate  allocation  of  costs  and  benefits  across  the 
stakeholders and countries involved, will again have to be overcome. And as with the previous project, 
barrier  mitigation  and  project  development  are  particularly  complex  because  of  the  ongoing 

 
 
 
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negotiations regarding the UK’s withdrawal from the EU. But once the outcome of the negotiations is 
clear, Vattenfall and TenneT TSO B.V. can take this pilot project forward. 

North Sea Wind Power Hub (NSWPH)  

The NSWPH connects offshore wind farms to several North Seas countries via a hub near the Dogger 
Bank area in the North Sea. It promises 25-year lifetime savings of about EUR 2,500 million compared 
to the reference case. These arise from the elimination of interconnector systems, the installation of 
electrical equipment on the hub rather than offshore and the provision of operations and maintenance 
services from the hub rather than from shore.  

The international nature of the project dictates several of its barriers. In terms of market arrangement, 
a  dedicated  bidding  zone  needs  to  be  implemented.  Due  to  the  unique  nature  of  the  project,  the 
introduction of a bidding zone lacking domestic demand is needed. This will require a comprehensive 
bidding zone review process. In addition, three other barriers will have to be overcome: uncertainty 
about  regulated  revenues  for  required  anticipatory  investments,  the  lack  of  an  applicable, 
transnational subsidy scheme for renewable energy sources and the  disproportionate allocation of 
costs and benefits across the stakeholders and countries. One barrier is removed, however: because 
hybrid  cable  systems  will  be  eliminated,  they  will  not  require  new  legal  classification. With  project 
commissioning planned for 2035, there is sufficient time to implement mitigation measures against 
the identified barriers. 

COBRA Cable 

This project connects a German offshore wind farm to the Netherlands and Denmark via the existing 
COBRA Cable interconnector. Over the typical asset lifetime of 25 years, it will yield savings of about 
EUR 390 million compared to the reference case. These occur because the project renders 200 km 
of cable and an onshore converter station redundant compared to the reference case.  

If the project is to be realised, several barriers will need to be addressed. Responsibility for linking the 
offshore wind farm to the interconnector  should be clearly assigned, the  applicability of a German 
subsidy  scheme  validated  and  the  disproportionate  allocation  of  costs  and  benefits  between 
stakeholders and countries overcome. As with the market arrangements for the NSWPH project, the 
implementation  of  a  dedicated  bidding  zone  for  the  offshore  wind  farm  would  require  a  better 
understanding of how a bidding zone with no domestic demand would work. A comprehensive bidding 
zone review process might also be needed. However, establishing a new bidding zone would, at least, 
remove the need for hybrid cable system classification.  

These barriers can be overcome by implementing the mitigation measures identified in this study. But 
the potential savings should be set against the cost of pausing operations and connecting the COBRA 
Cable interconnector to the offshore wind farm.  

DE OWF to NL 

This hybrid project connects a German offshore wind farm to the Netherlands. Assuming the typical 
asset  lifetime  of  25  years,  it  will  yield  lifetime  savings  of  about  EUR  260  million  compared  to  the 
reference  case.  These  are  due  to  the  elimination  of  115  km  of  cable,  as  the  distance  to  a  Dutch 
onshore connection point is shorter than that to the German one.  

While this hybrid project does not involve a hybrid cable system, three major barriers still need to be 
mitigated  when  considering  a  market  arrangement  of  sending  power  from  Germany  to  the 
Netherlands:  the  responsibility  for  onshore  grid  connection,  the  applicability  of  a  German  subsidy 
scheme  for  renewable  energy  sources  and  the  disproportionate  allocation  of  costs  and  benefits 
across the stakeholders and countries involved.  

 
 
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Compounding these more critical barriers, a lack of engagement and support by public stakeholders 
is also currently hindering the project. The main concern is that an disproportionate allocation of costs 
and  benefits  resulting  from  expected  onshore  grid  reinforcements  might  have  to  be  covered  by  a 
country that does not receive commensurate benefits. In addition, depending on the agreed project 
setup, any grid reinforcement costs should be set against the identified lifetime savings. Nevertheless, 
as  soon  as  public  engagement  and  support  can  be  ensured,  stakeholders  can  advance  this  pilot 
project.  

How to make hybrid projects a reality?  

The  study  makes  four  main  recommendations  on  implementing  future  hybrid  projects.  These  are 
based on the project-specific assessments performed on the concrete projects, as well as the detailed 
mitigation measures for their identified barriers.  

1.  Implement  HANSAs,  project-specific  legal  agreements  to  provide  security  for 

developers 

Although the European Union is planning an internal  energy market, most countries still place 
more  emphasis  on  their  own  energy  policies  and  rules.  This  hinders  the  implementation  of 
transnational projects, such as the hybrid projects considered in this study. Such projects require 
transnational  approaches  regarding  legal  and  regulatory  framework  conditions.  Hybrid  Asset 
Network Support Agreements address this problem. HANSAs are project-specific, enforceable 
legal  agreements  between  countries  that  provide  security  for  developers.  They  ensure  that 
specific  mitigation  measures  designed  to  overcome  relevant  legal  and  regulatory  barriers  are 
developed and implemented, offering both shorter-term certainty and the possibility of informing 
future legal frameworks. 

2.  Provide public funds to de-risk pilot projects 

Hybrid projects are riskier than conventional offshore developments. They are largely untested, 
require collaboration between multiple parties and integrate several projects into one. Developers 
therefore need incentives to switch from a conventional offshore project to a hybrid one during its 
early stages; the best time as changes naturally become more difficult and costly in later stages. 
Public  financial  support  is  key  to  this,  helping  developers  and  investors  to  de-risk  pilot  hybrid 
projects  and  allowing  for  early-stage  alignment  across  assets  and  countries.  The  EU’s 
Connecting Europe Facility provides early-stage and investment support for Project of Common 
Interest. Additionally, offering EUR 900 million in early-stage co-investments for renewable cross-
border projects is considered from 2021. 

3.  Agree rules to fairly share costs and benefits among countries and stakeholders 

Stakeholders are unlikely to commit to a hybrid project without first knowing what benefits and 
costs it will bring them. The problem is that each hybrid project generates a unique set of costs 
and benefits, and these are typically disproportionately distributed. For example, while country A 
may carry the burden of grid connection costs, country B may benefit from cheaper electricity. 
Such inequalities call for clear rules governing the fair allocation of costs and benefits, and these 
should act as a starting point for the development of project-specific solutions. 

4.  Widen the hybrid approach towards an integrated regional energy system (sector 

coupling) 

Hybrid  projects  can  be  expanded  and  improved  by  combining  them  with  so-called  power 
conversion technology. This converts electricity into another source of energy, typically gas, to 
ease transmission or store fuels during periods of oversupply. In combination, hybrid projects and 

 
 
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conversion  technology  can  help  to  avoid  onshore  grid  congestion  and  supply  risks.  Proposed 
hybrid projects such as the North Sea Wind Power Hub provide an ideal testing ground for this 
energy system approach, known as sector coupling. It will ultimately be essential in establishing 
an  energy  system  that  can  integrate  significantly  more  capacity  from  renewable  sources.  The 
European Commission and national governments should support such moves, for example, with 
grants to analyse different technological options and conduct feasibility studies. 

In conclusion, hybrid projects can make a significant contribution to  Europe’s energy transition and 
its decarbonisation. In the shorter term they reduce costs and needed space, while in the longer term 
they pave the way towards an integrated and future-proof European energy system in the North Seas 
region. 

 
 
 
 
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Table of Contents 

Table of Figures ............................................................................................................................... xvii 

Table of Tables ................................................................................................................................. xxi 

Glossary   ....................................................................................................................................... xxiii 

List of Abbreviations ....................................................................................................................... xxix 

1.  Hybrid projects and the North Seas region ................................................................................... 1 

2.  Assessing the costs and benefits of hybrid projects ..................................................................... 8 

2.1  Methodology ........................................................................................................................... 8 

2.2  Findings ................................................................................................................................ 11 

2.2.1  Significant savings over the project lifetime .............................................................. 13 

2.2.2  Reduced need for space and environmental impact ................................................. 15 

2.2.3  Other benefits for society .......................................................................................... 17 

3.  Overcoming barriers to hybrid projects ....................................................................................... 19 

3.1  Methodology ......................................................................................................................... 19 

3.2  Findings ................................................................................................................................ 21 

3.2.1  Uncertainty about responsibility for project development ......................................... 22 

3.2.2  Uncertainty about regulation deriving from jurisdiction over cross-border cable 

systems ......................................................................................................................... 25 

3.2.3  Uncertainty about market arrangements ................................................................... 27 

3.2.4  Uncertainty about hybrid cable system classification ................................................ 27 

3.2.5  Failure of developers to align planning across assets and countries ........................ 29 

3.2.6  Uncertainty about responsibility and rules to provide access to maritime space for 

OWFs (location selection, site pre-investigation, tender execution) ............................. 30 

3.2.7  Uncertainty about responsibility and rules to provide access to maritime space for 

OWFs (tender design) ................................................................................................... 31 

3.2.8  Discrepancies in responsibilities and requirements for balancing ............................ 31 

3.2.9  Discrepancies in priority dispatch regulation ............................................................. 32 

3.2.10 Discrepancies in curtailment regulation and compensation ...................................... 33 

3.2.11 Lack of regulated revenues for anticipatory investments .......................................... 33 

3.2.12 Uncertainty about applicable RES subsidy scheme.................................................. 35 

3.2.13 Limited engagement of public stakeholders .............................................................. 38 

3.2.14 Uncertainty regarding the UK market ........................................................................ 39 

3.2.15 Disproportionate allocation of costs and benefits across involved stakeholders ...... 40 

3.2.16 Uncertainty about legislative regime for power-to-gas and related infrastructure ..... 41 

3.3  Barrier interdependencies .................................................................................................... 42 

3.4  Action Plan for the European Commission .......................................................................... 44 

 
 
 
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4.  Case studies of selected hybrid projects ..................................................................................... 46 

4.1  Project Irish Sea ................................................................................................................... 48 

4.1.1  Details of the hybrid project and reference case ....................................................... 48 

4.1.2  Evaluation of hybrid project vs. reference case ........................................................ 49 

4.1.3  Development of an Action Plan to overcome barriers ............................................... 51 

4.2  Nautilus  ................................................................................................................................ 51 

4.2.1  Details of the hybrid project and reference case ....................................................... 51 

4.2.2  Evaluation of hybrid project vs. reference case ........................................................ 52 

4.2.3  Development of an Action Plan to overcome barriers ............................................... 54 

4.3  UK OWF to BE ..................................................................................................................... 54 

4.3.1  Details of the hybrid project and reference case ....................................................... 54 

4.3.2  Evaluation of hybrid project vs. reference case ........................................................ 55 

4.3.3  Development of an Action Plan to overcome barriers ............................................... 56 

4.4  IJmuiden Ver to UK .............................................................................................................. 56 

4.4.1  Details of the hybrid project and reference case ....................................................... 56 

4.4.2  Evaluation of hybrid project vs. reference case ........................................................ 57 

4.4.3  Development of an Action Plan to overcome barriers ............................................... 58 

4.5  CGS IJmuiden Ver to Norfolk ............................................................................................... 82 

4.5.1  Details of the hybrid project and reference case ....................................................... 82 

4.5.2  Evaluation of hybrid project vs. reference case ........................................................ 83 

4.5.3  Development of an Action Plan to overcome barriers ............................................... 85 

4.6  NeuConnect ....................................................................................................................... 111 

4.6.1  Details of the hybrid project and reference case ..................................................... 111 

4.6.2  Evaluation of hybrid project vs. reference case ...................................................... 112 

4.6.3  Development of an Action Plan to overcome barriers ............................................. 114 

4.7  North Sea Wind Power Hub (NSWPH) .............................................................................. 114 

4.7.1  Details of the hybrid project and reference case ..................................................... 114 

4.7.2  Evaluation of hybrid project vs. reference case ...................................................... 116 

4.7.3  Development of an Action Plan to overcome barriers ............................................. 117 

4.8  COBRA Cable .................................................................................................................... 144 

4.8.1  Details of hybrid project and reference case ........................................................... 144 

4.8.2  Evaluation of hybrid project vs. reference case ...................................................... 145 

4.8.3  Development of an Action Plan to overcome barriers ............................................. 147 

4.9  CGS DE OWF to NL OWF ................................................................................................. 170 

4.9.1  Details of the hybrid project and reference case ..................................................... 171 

4.9.2  Evaluation of hybrid project vs. reference case ...................................................... 172 

 
 
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4.9.3  Development of an Action Plan to overcome barriers ............................................. 173 

4.10 DE OWF to NL ................................................................................................................... 173 

4.10.1 Details of the hybrid project and reference case ..................................................... 173 

4.10.2 Evaluation of hybrid project vs. reference case ...................................................... 174 

4.10.3 Development of an Action Plan to overcome barriers ............................................. 175 

5.  Appendix .................................................................................................................................... 196 

5.1  IJmuiden Ver to UK ............................................................................................................ 196 

5.1.1  Uncertainty about responsibility for project development ....................................... 196 

5.1.2  Uncertainty about regulation deriving from jurisdiction over cross-border cable 

systems ....................................................................................................................... 199 

5.1.3  Uncertainty about market arrangements ................................................................. 201 

5.1.4  Uncertainty about hybrid cable system classification .............................................. 201 

5.1.5  Failure of developers to align planning across assets and countries ...................... 203 

5.1.6  Uncertainty about responsibility and rules to provide access to maritime space for 

OWFs (location selection, site pre-investigation and tender execution) ..................... 204 

5.1.7  Uncertainty about responsibility and rules to provide access to maritime space for 

OWFs (tender design) ................................................................................................. 204 

5.1.8  Discrepancies in responsibilities and requirements for balancing .......................... 207 

5.1.9  Discrepancies in priority dispatch regulation ........................................................... 207 

5.1.10 Discrepancies in curtailment regulation and compensation .................................... 208 

5.1.11 Lack of regulated revenues for anticipatory investments ........................................ 208 

5.1.12 Uncertainty about applicable RES subsidy scheme................................................ 209 

5.1.13 Limited engagement of public stakeholders ............................................................ 209 

5.1.14 Uncertainty regarding the UK market ...................................................................... 210 

5.1.15 Disproportionate allocation of costs and benefits across involved stakeholders .... 211 

5.1.16 Uncertainty about legislative regime for power-to-gas and related infrastructure ... 212 

5.2  CGS IJmuiden Ver to Norfolk ............................................................................................. 212 

5.2.1  Uncertainty about responsibility for project development ....................................... 212 

5.2.2  Uncertainty about regulation deriving from jurisdiction over cross-border cable 

systems ....................................................................................................................... 217 

5.2.3  Uncertainty about market arrangements ................................................................. 219 

5.2.4  Uncertainty about hybrid cable system classification .............................................. 220 

5.2.5  Failure of developers to align planning across assets and countries ...................... 222 

5.2.6  Uncertainty about responsibility and rules to provide access to maritime space for 

OWFs (location selection, site pre-investigation and tender execution) ..................... 223 

5.2.7  Uncertainty about responsibility and rules to provide access to maritime space for 

OWFs (tender design) ................................................................................................. 223 

5.2.8  Discrepancies in responsibilities and requirements for balancing .......................... 226 

 
 
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5.2.9  Discrepancies in priority dispatch regulation ........................................................... 227 

5.2.10 Discrepancies in curtailment regulation and compensation .................................... 227 

5.2.11 Lack of regulated revenues for anticipatory investments ........................................ 227 

5.2.12 Uncertainty about applicable RES subsidy scheme................................................ 229 

5.2.13 Limited engagement of public stakeholders ............................................................ 230 

5.2.14 Uncertainty regarding the UK market ...................................................................... 231 

5.2.15 Disproportionate allocation of costs and benefits across involved stakeholders .... 232 

5.2.16 Uncertainty about legislative regime for power-to-gas and related infrastructure ... 232 

5.3  North Sea Wind Power Hub (NSWPH) .............................................................................. 233 

5.3.1  Uncertainty about responsibility for project development ....................................... 233 

5.3.2  Uncertainty about regulation deriving from jurisdiction over cross-border cable 

systems ....................................................................................................................... 236 

5.3.3  Uncertainty about market arrangements ................................................................. 238 

5.3.4  Uncertainty about hybrid cable system classification .............................................. 241 

5.3.5  Failure of developers to align planning across assets and countries ...................... 244 

5.3.6  Uncertainty about responsibility and rules to provide access to maritime space for 

OWFs (location selection, site pre-investigation and tender execution) ..................... 245 

5.3.7  Uncertainty about responsibility and rules to provide access to maritime space for 

OWFs (tender design) ................................................................................................. 245 

5.3.8  Discrepancies in responsibilities and requirements for balancing .......................... 248 

5.3.9  Discrepancies in priority dispatch regulation ........................................................... 249 

5.3.10 Discrepancies in curtailment regulation and compensation .................................... 249 

5.3.11 Lack of regulated revenues for anticipatory investments ........................................ 249 

5.3.12 Uncertainty about RES subsidy scheme ................................................................. 251 

5.3.13 Limited engagement of public stakeholders ............................................................ 253 

5.3.14 Uncertainty regarding the UK market ...................................................................... 255 

5.3.15 Disproportionate allocation of costs and benefits across involved stakeholders .... 255 

5.3.16 Uncertainty about legislative regime for power-to-gas and related infrastructure ... 255 

5.4  COBRA Cable .................................................................................................................... 256 

5.4.1  Uncertainty about responsibility for project development ....................................... 256 

5.4.2  Uncertainty about regulation deriving from jurisdiction over cross-border cable 

systems ....................................................................................................................... 260 

5.4.3  Uncertainty about market arrangements ................................................................. 261 

5.4.4  Uncertainty about hybrid cable system classification .............................................. 267 

5.4.5  Failure of developers to align planning across assets and countries ...................... 270 

5.4.6  Uncertainty about responsibility and rules to provide access to maritime space for 

OWFs (location selection, site pre-investigation and tender execution) ..................... 271 

 
 
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5.4.7  Uncertainty about responsibility and rules to provide access to maritime space for 

OWFs (tender design) ................................................................................................. 274 

5.4.8  Discrepancies in responsibilities and requirements for balancing .......................... 278 

5.4.9  Discrepancies in priority dispatch regulation and compensation ............................ 278 

5.4.10 Discrepancies in curtailment regulation and compensation .................................... 278 

5.4.11 Lack of regulated revenues for anticipatory investments ........................................ 279 

5.4.12 Uncertainty about applicable RES subsidy scheme................................................ 279 

5.4.13 Limited engagement of public stakeholders ............................................................ 282 

5.4.14 Uncertainty regarding the UK market ...................................................................... 283 

5.4.15 Disproportionate allocation of costs and benefits across involved stakeholders .... 284 

5.4.16 Uncertainty about legislative regime for power-to-gas and related infrastructure ... 284 

5.5  DE OWF to NL ................................................................................................................... 284 

5.5.1  Discrepancies in national grid connection responsibility ......................................... 284 

5.5.2  Uncertainty about regulation deriving from jurisdiction over cross-border cable 

systems ....................................................................................................................... 287 

5.5.3  Uncertainty about market arrangements ................................................................. 289 

5.5.4  Uncertainty about hybrid cable system classification .............................................. 291 

5.5.5  Failure of developers to align planning across assets and countries ...................... 291 

5.5.6  Uncertainty about responsibility and rules to provide access to maritime space for 

OWFs (location selection, site pre-investigation and tender execution) ..................... 292 

5.5.7  Uncertainty about responsibility and rules to provide access to maritime space for 

OWFs (tender design) ................................................................................................. 295 

5.5.8  Discrepancies in responsibilities and requirements for balancing .......................... 298 

5.5.9  Discrepancies in priority dispatch regulation ........................................................... 299 

5.5.10 Discrepancies in curtailment regulation and compensation .................................... 299 

5.5.11 Lack of regulated revenues for anticipatory investments ........................................ 299 

5.5.12 Uncertainty about applicable RES subsidy scheme................................................ 299 

5.5.13 Limited engagement of public stakeholders ............................................................ 301 

5.5.14 Uncertainty regarding the UK market ...................................................................... 303 

5.5.15 Disproportionate allocation of costs and benefits across involved stakeholders .... 303 

5.5.16 Uncertainty about legislative regime for power-to-gas and related infrastructure ... 304 

 
 
 
 
 
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Table of Figures 

Figure 1: Hybrid project concepts ....................................................................................................... 2 

Figure 2: Kriegers Flak Combined Grid Solution ................................................................................ 3 

Figure 3: Collaboration with PROMOTioN project.............................................................................. 5 

Figure 4: Hybrid project clusters ......................................................................................................... 6 

Figure 5: Study methodology.............................................................................................................. 7 

Figure 6: Methodology of demonstrating the advantage of hybrid projects ....................................... 9 

Figure 7: Overview of assessment of costs and benefits across hybrid project ideas ..................... 13 

Figure 8: Significant lifetime savings on hybrid projects .................................................................. 14 

Figure 9: Diagram of the use of offshore space in the North Seas region ....................................... 17 

Figure 10: Methodology for overcoming barriers to hybrid projects ................................................. 21 

Figure 11: Overview of identified barriers mapped onto hybrid projects .......................................... 22 

Figure 12: Overview of barrier interdependencies ........................................................................... 43 

Figure 13: Barrier mitigation – Action Plan for the European Commission ...................................... 45 

Figure 14: Project Irish Sea – Reference case and hybrid project profile ........................................ 49 

Figure 15: Project Irish Sea – Assessment results .......................................................................... 50 

Figure 16: Nautilus – Reference case and hybrid project profile ..................................................... 52 

Figure 17: Nautilus – Assessment results ........................................................................................ 53 

Figure 18: UK OWF to BE – Reference case and hybrid project profile .......................................... 54 

Figure 19: UK OWF to BE – Assessment results ............................................................................. 55 

Figure 20: IJmuiden Ver to UK – Reference case and hybrid project profile ................................... 57 

Figure 21: IJmuiden Ver to UK – Assessment results ...................................................................... 58 

Figure 22: IJmuiden Ver to UK – Action Plan ................................................................................... 63 

Figure 23: IJmuiden Ver to UK barrier mitigation – Uncertainty about responsibility for project 

development ........................................................................................................................... 66 

Figure 24: IJmuiden Ver to UK barrier mitigation – Uncertainty about regulation deriving from 

jurisdiction over cross-border cable systems ......................................................................... 68 

Figure 25: IJmuiden Ver to UK barrier mitigation – Uncertainty about market arrangements ......... 69 

Figure 26: IJmuiden Ver to UK barrier mitigation – Uncertainty about hybrid cable system 

classification ........................................................................................................................... 72 

Figure 27: IJmuiden Ver to UK barrier mitigation – Failure of developers to align planning 

across assets and countries ................................................................................................... 73 

Figure 28: IJmuiden Ver to UK barrier mitigation – Uncertainty about responsibility and rules 

to provide access to maritime space for OWFs (tender design) ............................................ 75 

Figure 29: IJmuiden Ver to UK barrier mitigation – Lack of regulated revenues for anticipatory 

investments ............................................................................................................................ 76 

 
 
 
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Figure 30: IJmuiden Ver to UK barrier mitigation – Uncertainty about applicable RES subsidy 

scheme ................................................................................................................................... 77 

Figure 31: IJmuiden Ver to UK barrier mitigation – Limited engagement of public stakeholders .... 79 

Figure 32: IJmuiden Ver to UK barrier mitigation – Uncertainty regarding the UK market .............. 80 

Figure 33: IJmuiden Ver to UK barrier mitigation – Disproportionate allocation of costs and 

benefits across involved stakeholders ................................................................................... 82 

Figure 34: CGS IJmuiden Ver to Norfolk – Reference case and hybrid project profile .................... 83 

Figure 35: CGS IJmuiden Ver to Norfolk – Assessment results ...................................................... 84 

Figure 36: CGS IJmuiden Ver to Norfolk – Action Plan ................................................................... 90 

Figure 37: CGS IJmuiden Ver to Norfolk barrier mitigation – Uncertainty about responsibility 

for project development .......................................................................................................... 93 

Figure 38: CGS IJmuiden Ver to Norfolk barrier mitigation – Uncertainty about regulation 

deriving from jurisdiction over cross-border cable systems ................................................... 95 

Figure 39: CGS IJmuiden Ver to Norfolk barrier mitigation – Uncertainty about market 

arrangements ......................................................................................................................... 96 

Figure 40: CGS IJmuiden Ver to Norfolk barrier mitigation – Uncertainty about hybrid cable 

system classification............................................................................................................. 100 

Figure 41: CGS IJmuiden Ver to Norfolk barrier mitigation – Failure of developers to align 

planning across assets and countries .................................................................................. 102 

Figure 42: CGS IJmuiden Ver to Norfolk barrier mitigation – Uncertainty about responsibility 

and rules to provide access to maritime space for OWFs (tender design) .......................... 103 

Figure 43: CGS IJmuiden Ver to Norfolk barrier mitigation – Lack of regulated revenues for 

anticipatory investments ....................................................................................................... 105 

Figure 44: CGS IJmuiden Ver to Norfolk barrier mitigation – Uncertainty about applicable 

RES subsidy scheme ........................................................................................................... 106 

Figure 45: CGS IJmuiden Ver to Norfolk barrier mitigation – Limited engagement of public 

stakeholders ......................................................................................................................... 108 

Figure 46: CGS IJmuiden Ver to Norfolk barrier mitigation – Uncertainty regarding the UK 

market .................................................................................................................................. 109 

Figure 47: CGS IJmuiden Ver to Norfolk barrier mitigation – Disproportionate allocation of 

costs and benefits across involved stakeholders ................................................................. 111 

Figure 48: NeuConnect – Reference case and hybrid project profile ............................................ 112 

Figure 49: NeuConnect – Assessment results ............................................................................... 113 

Figure 50: North Sea Wind Power Hub (NSWPH) – Assumed commercial electricity flows in 

the reference and hybrid projects ......................................................................................... 115 

Figure 51: North Sea Wind Power Hub (NSWPH) – Reference case and hybrid project profile ... 116 

Figure 52: North Sea Wind Power Hub (NSWPH) – Assessment results ...................................... 117 

Figure 53: North Sea Wind Power Hub (NSWPH) – Action Plan ................................................... 122 

Figure 54: North Sea Wind Power Hub (NSWPH) barrier mitigation – Uncertainty about 

responsibility for project development .................................................................................. 125 

 
 
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Figure 55: North Sea Wind Power Hub (NSWPH) barrier mitigation – Uncertainty about 

regulation deriving from jurisdiction over cross-border cable systems ................................ 127 

Figure 56: North Sea Wind Power Hub (NSWPH) barrier mitigation – Uncertainty about 

market arrangements ........................................................................................................... 129 

Figure 57: North Sea Wind Power Hub (NSWPH) barrier mitigation – Uncertainty about 

hybrid cable system classification ........................................................................................ 131 

Figure 58: North Sea Wind Power Hub (NSWPH) barrier mitigation – Failure of developers to 

align planning across assets and countries ......................................................................... 132 

Figure 59: North Sea Wind Power Hub (NSWPH) barrier mitigation – Uncertainty about 

responsibility and rules to provide access to maritime space for OWFs (tender design) .... 134 

Figure 60: North Sea Wind Power Hub (NSWPH) barrier mitigation – Lack of regulated 

revenues for anticipatory investments.................................................................................. 136 

Figure 61: North Sea Wind Power Hub (NSWPH) barrier mitigation – Uncertainty about 

applicable RES subsidy scheme .......................................................................................... 138 

Figure 62: North Sea Wind Power Hub (NSWPH) barrier mitigation – Limited engagement of 

public stakeholders ............................................................................................................... 140 

Figure 63: North Sea Wind Power Hub (NSWPH) barrier mitigation – Disproportionate 

allocation costs and benefits across involved stakeholders................................................. 142 

Figure 64: North Sea Wind Power Hub (NSWPH) barrier mitigation – Uncertainty about 

legislative regime for power-to-gas and related infrastructure ............................................. 144 

Figure 65: COBRA Cable – Reference case and hybrid project profile ......................................... 145 

Figure 66: COBRA Cable – Assessment results ............................................................................ 146 

Figure 67: COBRA Cable – Action Plan ......................................................................................... 151 

Figure 68: COBRA Cable barrier mitigation – Uncertainty about responsibility for project 

development ......................................................................................................................... 154 

Figure 69: COBRA Cable barrier mitigation – Uncertainty about regulation deriving from 

jurisdiction over cross-border cable systems ....................................................................... 156 

Figure 70: COBRA Cable barrier mitigation – Uncertainty about market arrangements ............... 158 

Figure 71: COBRA Cable barrier mitigation – Uncertainty about hybrid cable system 

classification ......................................................................................................................... 160 

Figure 72: COBRA Cable barrier mitigation – Failure of developers to align planning across 

assets and countries ............................................................................................................ 161 

Figure 73: COBRA Cable barrier mitigation – Uncertainty about responsibility and rules to 

provide access to maritime space for OWFs (location selection, site pre-investigation, 
tender execution) .................................................................................................................. 162 

Figure 74: COBRA Cable barrier mitigation – Uncertainty about responsibility and rules to 

provide access to maritime space for OWFs (tender design) .............................................. 164 

Figure 75: COBRA Cable barrier mitigation – Uncertainty about applicable RES subsidy 

scheme ................................................................................................................................. 167 

Figure 76: COBRA Cable barrier mitigation – Limited engagement of public stakeholders .......... 168 

Figure 77: COBRA Cable barrier mitigation – Disproportionate allocation of costs and benefit 

across involved stakeholders ............................................................................................... 170 

 
 
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Figure 78: CGS DE OWF to NL OWF – Reference case and hybrid project profile ...................... 171 

Figure 79: CGS DE OWF to NL OWF – Assessment results ......................................................... 172 

Figure 80: DE OWF to NL – Reference case and hybrid project profile ........................................ 174 

Figure 81: DE OWF to NL – Assessment results ........................................................................... 175 

Figure 82: DE OWF to NL – Action Plan ........................................................................................ 179 

Figure 83: DE OWF to NL barrier mitigation – Uncertainty about responsibility for project 

development ......................................................................................................................... 182 

Figure 84: DE OWF to NL barrier mitigation – Uncertainty about regulation deriving from 

jurisdiction over cross-border cable systems ....................................................................... 183 

Figure 85: DE OWF to NL barrier mitigation – Uncertainty about market arrangements .............. 185 

Figure 86: DE OWF to NL barrier mitigation – Failure of developers to align planning across 

assets and countries ............................................................................................................ 186 

Figure 87: DE OWF to NL barrier mitigation – Uncertainty about responsibility and rules to 

provide access to maritime space for OWFs (location selection, site pre-investigation, 
tender execution) .................................................................................................................. 188 

Figure 88: DE OWF to NL barrier mitigation – Uncertainty about responsibility and rules to 

provide access to maritime space for OWFs (tender design) .............................................. 189 

Figure 89: DE OWF to NL barrier mitigation – Uncertainty about applicable RES subsidy 

scheme ................................................................................................................................. 191 

Figure 90: DE OWF to NL barrier mitigation – Limited engagement of public stakeholders ......... 193 

Figure 91: DE OWF to NL barrier mitigation – Disproportionate allocation of costs and 

benefits across involved stakeholders ................................................................................. 195 

 
 
 
 
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Table of Tables  

Table 1: IJmuiden Ver to UK – Barriers, barrier mitigation measures and interdependencies ........ 62 

Table 2: CGS IJmuiden Ver to Norfolk – Barriers, barrier mitigation measures and 

interdependencies .................................................................................................................. 89 

Table 3: North Sea Wind Power Hub (NSWPH) – Barriers, barrier mitigation measures and 

interdependencies ................................................................................................................ 121 

Table 4: COBRA Cable – Barriers, barrier mitigation measures and interdependencies .............. 150 

Table 5: DE OWF to NL – Barriers, barrier mitigations and interdependencies ............................ 178 

Table 6: IJmuiden Ver to UK – Assessment of options for responsibility during IC 

development and construction phase .................................................................................. 197 

Table 7: IJmuiden Ver to UK – Assessment of options for responsibility during IC operation 

phase .................................................................................................................................... 198 

Table 8: IJmuiden Ver to UK – Assessment of options for regulation deriving from jurisdiction 

deriving from cross-border cable systems ........................................................................... 200 

Table 9: IJmuiden Ver to UK – Assessment of options for hybrid cable system classification ...... 202 

Table 10: IJmuiden Ver to UK – Assessment of options for tender design .................................... 207 

Table 11: IJmuiden Ver to UK – Assessment of regulatory regimes for anticipatory 

investments .......................................................................................................................... 208 

Table 12: IJmuiden Ver to UK – Assessment of options for formalisation of commitment from 

public stakeholders ............................................................................................................... 210 

Table 13: CGS IJmuiden Ver to Norfolk – Assessment of options for responsibility during IC 

development and construction phase .................................................................................. 214 

Table 14: CGS IJmuiden Ver to Norfolk – Assessment of options for responsibility during IC 

operation phase .................................................................................................................... 217 

Table 15: CGS IJmuiden Ver to Norfolk – Assessment of options for regulation deriving from 

jurisdiction deriving from cross-border cable systems ......................................................... 219 

Table 16: CGS IJmuiden Ver to Norfolk – Assessment of options for hybrid cable system 

classification ......................................................................................................................... 221 

Table 17: CGS IJmuiden Ver to Norfolk – Assessment of options for tender design .................... 226 

Table 18: CGS IJmuiden Ver to Norfolk – Assessment of regulatory regimes for anticipatory 

investments .......................................................................................................................... 229 

Table 19: CGS IJmuiden Ver to Norfolk – Assessment of options for formalisation of 

commitment from public stakeholders .................................................................................. 230 

Table 20: North Sea Wind Power Hub (NSWPH) – Assessment of options for grid connection 

responsibility ......................................................................................................................... 235 

Table 21: North Sea Wind Power Hub (NSWPH) – Assessment of options for regulation 

deriving from jurisdiction deriving from cross-border cable systems ................................... 237 

Table 22: North Sea Wind Power Hub (NSWPH) – Assessment of options for market 

arrangement ......................................................................................................................... 240 

Table 23: North Sea Wind Power Hub (NSWPH) – Assessment of options for hybrid cable 

system classification............................................................................................................. 243 

 
 
 
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Table 24: North Sea Wind Power Hub (NSWPH) – Assessment for options of tender design ...... 248 

Table 25: North Sea Wind Power Hub (NSWPH) – Assessment of regulatory regimes for 

anticipatory investments ....................................................................................................... 251 

Table 26: North Sea Wind Power Hub (NSWPH) – Assessment of options for RES subsidy 

schemes ............................................................................................................................... 252 

Table 27: North Sea Wind Power Hub (NSWPH) – Assessment of options for formalisation of 

commitment from public stakeholders .................................................................................. 254 

Table 28: COBRA Cable – Assessment of options for grid connection responsibility ................... 259 

Table 29: COBRA Cable – Assessment of options for regulation deriving from jurisdiction 

deriving from cross-border cable systems ........................................................................... 261 

Table 30: COBRA Cable – Assessment of options for market arrangement ................................. 266 

Table 31: COBRA Cable – Assessment of options for hybrid cable system classification ............ 270 

Table 32: COBRA Cable – Assessment of options for location selection and site pre-

investigation ......................................................................................................................... 273 

Table 33: COBRA Cable – Assessment of options for tender responsible party ........................... 274 

Table 34: COBRA Cable – Assessment of options for tender design ............................................ 277 

Table 35: COBRA Cable – Assessment of options for RES subsidy schemes ............................. 281 

Table 36: COBRA Cable – Assessment of options for formalisation of commitment from 

public stakeholders ............................................................................................................... 283 

Table 37: DE OWF to NL – Assessment of options for grid connection responsibility .................. 286 

Table 38: DE OWF to NL – Assessment of options for regulation deriving from jurisdiction 

deriving from cross-border cable systems ........................................................................... 289 

Table 39: DE OWF to NL – Assessment of options for market arrangements .............................. 290 

Table 40: DE OWF to NL – Assessment of options for location selection and site pre-

investigation ......................................................................................................................... 294 

Table 41: DE OWF to NL – Assessment of options for tender responsible party .......................... 295 

Table 42: DE OWF to NL – Assessment of options for tender design ........................................... 298 

Table 43: DE OWF to NL – Assessment of options for RES subsidy schemes ............................. 301 

Table 44: DE OWF to NL – Assessment of options for formalisation of commitment from 

public stakeholders ............................................................................................................... 302 

 
 
 
 
 
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Glossary 

Term1 

Description 

Capital 
expenditures 
(CAPEX) 

Capital  expenditures  are  the  funds  needed  for  the  development  and  the 
construction  of  the  hybrid  project.  In  this  study,  capital  expenditures  are 
assumed  to  be  fully  incurred  with  commissioning  of  a  hybrid  project  and  are 
therefore not discounted.  

Clean Energy 
Package (CEP) 

The Clean Energy Package was adopted by the Member States in December 
2018  and  will  be  subject  to  scrutiny  before  entering  into  force  in  2019.  After 
entering into force, the new framework needs to be assessed in detail by the 
relevant project stakeholders.  

Combined grid 
solution (CGS) 

Combined grid solutions connect two offshore wind farms located in different 
exclusive  economic  zones,  which  are  individually  connected  to  shore  of  the 
respective countries. 

Connecting 
Europe Facility 
(CEF) 

The Connecting Europe Facility is an EU funding instrument to promote growth, 
jobs  and  competitiveness  through  targeted  infrastructure  investment  at 
European  level.  It  supports  the  development  of  high  performing,  sustainable 
and  efficiently  interconnected  trans-European  networks  in  the  fields  of 
transport, energy and digital services. 

Contract for 
Difference (CfD) 

A Contract for Difference is a  long-term contract,  where two parties agree to 
trade  a  certain  volume  of  energy  for  a  set  strike  price.  If  the  market  price  is 
higher  or  lower  than  the  agreed  strike  price,  then  the  parties  settle  the 
difference. Thus, a CfD enables a generator to stabilise its revenues at a pre-
agreed level (strike price-level). 

Distribution system 
operator (DSO) 

Distribution  system  operator means  a  natural  or  legal  person  responsible  for 
operating,  ensuring  the  maintenance  of  and,  if  necessary,  developing  the 
distribution system in a given area and, where applicable, its interconnections 
with other systems and for ensuring the long-term ability of the system to meet 
reasonable demands for the distribution of electricity (Directive 2007/72/EC). 

European Fund for 
Strategic 
Investments (EFSI) 

The European Fund for Strategic Investments is an initiative launched jointly by 
the EIB Group – the European Investment Bank and the European Investment 
Fund – and the European Commission to help overcome the current investment 
gap in the EU. It provides funding for economically viable projects, especially 
for projects with a higher risk profile than usually taken on by banks. It focuses 
on sectors of key importance for the European economy. 

1 Definitions provided by Roland Berger to clarify the specific usage of terms in this study. 

 
 
 
                                                      
 
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Term1 

Description 

European Network 
of Transmission 
System Operators 
for Electricity 
(ENTSO-E) 

ENTSO-E,  the  European  Network  of  Transmission  System  Operators  for 
Electricity,  represents 43  electricity  transmission  system  operators  from  36 
countries across Europe. ENTSO-E members share the objective of setting up 
the  internal  energy  market  and  ensuring  its  optimal  functioning,  and  of 
supporting the ambitious European energy and climate agenda. 

Exclusive 
economic zone 
(EEZ) 

An  exclusive  economic  zone  is  a  maritime  zone  prescribed  by  the  United 
Nations Convention on the Law of the Sea. The exclusive economic zone is an 
area  beyond  and  adjacent  to  the  territorial  sea,  where  the  coastal  state  has 
sovereign rights  for exploring and exploiting  the marine resources as  well as 
jurisdiction  with  regard  to  the  establishment  and  use  of  artificial  islands, 
installations and structures. 

High voltage 
alternating current 
(HVAC) 

High voltage alternating current is an electric current, generated by a voltage of 
more than 100 kV, which periodically reverses direction. High voltage is used 
for electric power transmission to reduce the energy lost in the resistance of the 
wires.  Short  distance  HVAC  transmission  generally  has  lower  overall 
investment  cost  than  an  equivalent  DC  transmission  scheme  due  to  the 
absence  of  additionally  needed  and  expensive  DC  converters  for  voltage 
transformations. 

High voltage direct 
current (HVDC) 

High voltage direct current is an electric current, generated by a voltage of more 
than 100 kV, which flows unidirectional. High voltage is used for electric power 
transmission  to  reduce  the  energy  lost  in  the  resistance  of  the  wires.  Long 
distance  point  to  point  HVDC  transmission  generally  has  lower  overall 
investment cost than  an equivalent  AC  transmission  scheme due to cheaper 
cables and very limited losses. 

Hybrid Asset 
Network Support 
Agreement 
(HANSA) 

A  Hybrid  Asset  Network  Support  Agreement  is  a  project-specific  agreement 
between countries. It formalises their commitment to support the development 
and operation of an (electricity) network – based on hybrid cable systems – and 
the implementation of required actions. A HANSA represents a legally binding 
commitment to maintain the terms of legislation and regulation in place at the 
time of the adoption of the HANSA and to clarify ambiguities in European and / 
or  national  legislation  and  regulation,  which  might  obstruct  hybrid  project 
development.  It  thereby  provides  legal  certainty  to  developers.  European 
legislation and regulation can only be addressed via a HANSA in case of the 
signing of the agreement by all Member States of the European Union. 

Hybrid cable 
system 

Hybrid cable systems are cable systems that fulfil multiple functionalities, such 
as the transmission of electricity from an offshore wind farm to shore and the 
transmission of electricity from one country to another to allow for market-to-
market flows. 

Hybrid project 

Hybrid  projects  are  transnational,  coordinated  offshore  energy  generation 
projects. Typically, hybrid projects combine generation and transmission assets 
across maritime boundaries. 

 
 
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Term1 

Description 

Intergovernmental 
Agreement (IGA) 

An  Intergovernmental  agreement  is  an  agreement  between  countries  that 
formalises  their  commitment  to  the  implementation  of  required  actions  for 
barrier  mitigation.  An  IGA  represents  a  legally  binding  commitment  to  adapt 
legislation  and  regulation  in  the  future,  and  thus  provides  legal  certainty  to 
developers.  

Memorandum of 
Understanding 
(MoU) 

A  Memorandum  of  Understanding  is  a  formalisation  of  the  goodwill  of  the 
involved  parties  in  the  form  of  a  non-binding  agreement.  An  MoU  addresses 
barriers by formalising the agreements of the involved parties with regards to 
the implementation of required actions to overcome barriers.  

Natura 2000 

Natura  2000  is  a  network  of  core  breeding  and  resting  sites  for  rare  and 
threatened species, and some rare natural habitat types which are protected in 
their own right. It stretches across all 28 EU countries, both on land and at sea. 
The  aim  of  the  network  is  to  ensure  the  long-term  survival  of  Europe's  most 
valuable  and  threatened  species  and  habitats,  listed  under  both  the  Birds 
Directive and the Habitats Directive. 

Nautical mile (nm)  A nautical mile is a unit of measurement defined as 1.852 kilometres. 

North Seas Energy 
Cooperation 

The North Seas Energy Cooperation was formed in 2016 through the Political 
Declaration  on  energy  cooperation  between  North  Seas  Countries  (Belgium, 
Denmark,  France,  Germany,  Ireland,  Luxembourg,  the  Netherlands,  Norway 
and Sweden, and later also the UK). The involved countries agreed to further 
strengthen their energy cooperation to improve conditions for the development 
of offshore wind energy to ensure a sustainable, secure and affordable energy 
supply in the area. 

North Seas 
Offshore Energy 
Cluster 

Areas  which have the potential  to be “North  Seas Offshore  Energy  Clusters” 
are geographical areas in the exclusive economic zones of any Signatory State 
to the June 2016 Political Declaration on North Seas Energy Cooperation that 
border on areas in one or more other Signatory States, where there is a firm 
intention to invest in offshore infrastructure for the purposes of transporting or 
generating  energy,  and  where,  further  linked  investment  could  either  reduce 
costs or provide access to the bordering national market(s) or both. 

Offshore 
Transmission 
Owner (OFTO) 

for  offshore 
An  Offshore  Transmission  Owner  assumes  responsibility 
transmission  assets  in  the  UK.  An  OFTO  is  competitively  appointed  by  the 
national regulatory authority Ofgem through a tender process and is awarded 
an OFTO license. The OFTO transmission license does not permit market-to-
transmission  and  an 
market 
interconnector license.  

flows  and  OFTOs  cannot  hold  both  a 

Operating 
expenses (OPEX) 

Operating  expenses  are  the  funds  needed  to  operate  and  maintain  a  hybrid 
project. In this study, operating expenses are calculated and discounted over a 
typical asset lifetime. 

 
 
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Term1 

Description 

Power-to-gas 

Power-to-X 

Power-to-gas  refers  to  an  electricity  conversion  pathway  that  utilizes  surplus 
electricity to allow for the decoupling of power from the electricity sector for use 
in other sectors. The idea behind power-to-gas is to convert renewable energy 
to hydrogen using electrolysis or to methane by combining the newly  gained 
hydrogen with carbon dioxide. 

Power-to-X refers to various electricity conversion pathways that utilize surplus 
electricity to allow for the decoupling of power from the electricity sector for use 
in other sectors. The X in the terminology refers to the product, that emerges 
from the electricity conversion (e.g. gas (hydrogen or methane), liquid, syngas, 
etc.). 

PRIMES EUCO30  The  PRIMES  model  is  an  EU  energy  system  model  which  simulates  energy 
consumption and the energy supply system in the European Union and each of 
its Member States. It includes consistent carbon price trajectories. EUCO30 is 
a  scenario,  created  using  the  PRIMES  model,  that  reflects  the  2030  targets 
agreed by the European Council. It achieves the at least 40% greenhouse gas 
emissions  reduction  target,  a  32%  share  of  renewables  and  the  energy 
efficiency target of 32.5%. 

PROgress on 
Meshed HVDC 
Offshore 
Transmission 
Networks 
(PROMOTioN) 

The  PROgress  on  Meshed  HVDC  Offshore  Transmission  Networks  project 
researches the long-term vision of a meshed offshore grid in the North Sea. It 
is funded under the EU Horizon 2020 programme on "Competitive Low-Carbon 
Energy"  and  serves  as  a  link  between  research,  validation  and  testing  of 
technology  and  the  development  of  recommendations  for  meshed  offshore 
grids. 

Projects of 
Common Interest 
(PCI) 

Projects of Common Interest are key cross border infrastructure projects that 
link  the  energy  systems  of  EU  countries.  They  are  intended  to  help  the  EU 
its  energy  policy  and  climate  objectives:  affordable,  secure 
achieve 
and sustainable energy for all citizens, and the long-term decarbonisation of the 
economy in accordance with the Paris Agreement.  

Reference case 

Reference  cases  consist  of  separately  developed,  uncoordinated  offshore 
generation  and  transmission  projects  comparable  to  the  respective  hybrid 
projects (i.e. with the same generation and transmission capacity). 

Regulated asset 
base (RAB) 

The regulated asset base is a system of long-term tariff design aimed primarily 
at  encouraging 
the  expansion  and  modernization  of 
infrastructure. It  is  the  value  of  net  invested  capital  for  regulatory  purposes, 
calculated on the basis of the rules defined by an authority for determining base 
revenues for the regulated businesses. 

investment 

in 

Socio-economic 
welfare (SEW) 

The  socio-economic  welfare  can  be  described  as  a  level  of  economic 
satisfaction experienced by participants in an economic system. In the context 
of offshore wind projects, the socio-economic welfare consists of the producer 
surplus, the consumer surplus and the congestion rent. 

 
 
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Term1 

Description 

Special-purpose 
vehicle (SPV) 

A special-purpose vehicle is a separate legal entity created by an organization. 
The SPV is a subsidiary company with its own assets and liabilities, as well as 
its  own  legal  status.  Usually,  they  are  created  for  a  specific  objective,  often 
which is to isolate financial risk. As it is a separate legal entity, if the SPV goes 
bankrupt, the parent company must not carry its obligations. 

Ten Year Network 
Development Plan 
(TYNDP) 

The  ENTSO-E ten-year  network  development  plan  is  Europe's  network 
development  plan  to  2025,  2030  and  2040.  It  is  published  bi-annually  and 
focuses on what the electricity grid should look like to create maximum value 
for Europeans, ensure continuous access to electricity throughout Europe and 
deliver on the climate agenda. 

Territorial sea 

The sovereignty of a coastal State extends, beyond its land territory and internal 
waters to an adjacent belt of sea, described as the territorial sea. Every State 
has  the  right  to  establish  the  breadth  of  its  territorial  sea  up  to  a  limit  not 
exceeding 12 nautical miles. 

Transmission 
system operator 
(TSO) 

Transmission system operator means a natural or legal person responsible for 
operating,  ensuring  the  maintenance  of  and,  if  necessary,  developing  the 
transmission system in a given area and, where applicable, its interconnections 
with other systems, and for ensuring the long-term ability of the system to meet 
reasonable demands for the transmission of electricity (Directive 2009/72/EC). 

UK Cap and Floor 
regime 

UK Capacity 
Market 

investment 

The UK national regulatory agency Ofgem has created the cap and floor regime 
to  encourage 
interconnectors.  Electricity 
in  electricity 
interconnectors generally earn revenue from the allocation of capacity to users 
who want to flow electricity between the UK and neighbouring countries. Under 
the UK's regime, a cap as well as a floor exist that represent the maximum and 
minimum  amount  of  revenue  that  an  electricity  interconnector  can  earn, 
providing security for the developers. 

The  Capacity  Market  is  a  mechanism  introduced  by  the  UK  government  to 
ensure that electricity supply continues to meet demand as more volatile and 
unpredictable renewable generation plants come on stream. Participants will be 
paid a per MW rate for the capacity they offer to the market. In return, the agreed 
capacity  needs  to  be  available  when  providers  are  called  upon  at  any  time 
during  the  contracted  period.  Both  the  capacity  payments  as  well  as  the 
Capacity Market obligation are defined in agreements that are awarded to the 
capacity providers via auctions. However, the mechanism has been declared 
illegal by the General Court of the EU on November 15, 2018 and it is presently 
put on hold, with the next capacity auction indefinitely postponed.  

United Nations 
Convention on the 
Law of the Sea 
(UNCLOS) 

The United Nations Convention on the Law of the Sea entered into force in 1994 
and lays down a comprehensive regime of law and order in the world's oceans 
and  seas  establishing  rules  governing  all  uses  of  the  oceans  and  their 
resources. It enshrines the notion that all problems of ocean space are closely 
interrelated and need to be addressed as a whole. 

 
 
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Term1 

Description 

Voluntary 
cooperation 

Voluntary  cooperation,  as  opposed  to  a  project-specific  Memorandum  of 
Understanding  (MoU)  or  a  project-specific  Hybrid  Asset  Network  Support 
Agreement (HANSA), does not rely on a formalisation of goodwill of the involved 
parties but rather is the outcome of the common understanding to jointly work 
towards a common goal. There is no legally binding element. 

 
 
 
 
 
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List of Abbreviations 

Abbreviation 

Meaning 

(HV)AC 

(HV)DC 

ACM 

BE 

BEIS 

BMWi 

bn 

BNetzA 

BSH 

CACM 

CAPEX 

CBA 

CBCA 

CEF 

CEP 

CfD 

CGS 

CO2 

DE 

DK 

DSO 

DUR 

e.g. 

EC 

EEZ 

EFSI 

(High voltage) alternating current 

(High voltage) direct current 

Authority for Consumers & Markets, Netherlands 

Belgium 

Department for Business, Energy & Industrial Strategy, UK 

Federal Ministry for Economic Affairs and Energy, Germany 

Billion 

Federal Network Agency, Germany 

Federal Maritime and Hydrographic Agency, Germany 

Capacity Allocation and Congestion Management 

Capital expenditures 

Cost-benefit analysis 

Cross-border cost allocation 

Connecting Europe Facility  

Clean Energy Package 

Contract for Difference 

Combined grid solution 

Carbon dioxide 

Germany 

Denmark 

Distribution system operator 

Danish Utility Regulator 

For example (exempli gratia) 

European Commission 

Exclusive economic zone 

European Fund for Strategic Investments 

ENTSO-E 

European Network of Transmission System Operators for Electricity 

EU 

EUR 

GBP 

European Union 

Euro 

Pound sterling 

G-charges 

Generation charges 

 
 
 
xxx   HYBRID PROJECTS: HOW TO REDUCE COSTS AND SPACE OF OFFSHORE DEVELOPMENTS  

  North Seas Offshore Energy Clusters study 

Abbreviation 

GW 

HANSA 

i.e. 

IC 

IGA 

incl. 

Meaning 

Gigawatt 

Hybrid Asset Network Support Agreement 

That is to say (id est) 

Interconnector 

Intergovernmental Agreement 

Including 

KF CGS 

Kriegers Flak Combined Grid Solution 

km 

kt/a 

kV 

kW 

m 

MoEA 

MoEUC 

MOG 

MoU 

MW 

MWh 

MWh/a 

NGV 

NL 

nm 

NRA 

Kilometre 

Kiloton per year 

Kilovolt 

Kilowatt 

Million 

Ministry of Economic Affairs and Climate Policy, Netherlands 

Ministry of Energy, Utilities and Climate, Denmark 

Modular Offshore Grid 

Memorandum of Understanding 

Megawatt 

Megawatt hours 

Megawatt hours per year 

National Grid Ventures, UK 

The Netherlands 

Nautical mile 

National regulatory authority 

NSWPH 

North Sea Wind Power Hub 

Ofgem 

OFTO 

OPEX 

OWF 

p.a. 

PCI 

Office of Gas and Electricity Markets, UK 

Offshore Transmission Owner, UK 

Operating expenses 

Offshore wind farm 

Per year (per annum) 

Projects of Common Interest 

PROMOTioN 

PROgress on Meshed HVDC Offshore Transmission Networks 

RAB 

reg. 

Regulated asset base 

Regarding 

 
 
xxxi   HYBRID PROJECTS: HOW TO REDUCE COSTS AND SPACE OF OFFSHORE DEVELOPMENTS  

  North Seas Offshore Energy Clusters study 

Abbreviation 

Meaning 

RES 

RVO 

SEW 

SPV 

tbd 

TSO 

TYNDP 

UK 

UK-NL-BE 

UNCLOS 

Renewable energy sources 

Netherlands Enterprise Agency, Netherlands 

Socio-economic welfare 

Special-purpose vehicle 

To be determined 

Transmission system operator 

Ten Year Network Development Plan 

The United Kingdom 

Cluster UK, Netherlands and Belgium 

United Nations Convention on the Law of the Sea 

 
 
1   HYBRID PROJECTS: HOW TO REDUCE COSTS AND SPACE OF OFFSHORE DEVELOPMENTS 

  North Seas Offshore Energy Clusters study 

1.  Hybrid projects and the North Seas region 

The decarbonisation of European societies constitutes a major target of the European Commission 
and  national  governments.  In  December  2015  they  committed  to  decarbonisation  in  Europe  by 
signing the Paris Agreement. This plan, a product of the 21st Conference of the Parties of the United 
Nations Framework Convention on Climate Change, aims to limit the rise in global temperatures to 
no  more  than  2°  Celsius  above  pre-industrial  levels,  while  actually  working  towards  a  limit  of  1.5° 
Celsius. EU members have also agreed to produce 32% of consumed energy from renewables by 
2030.  A  rulebook  produced  at  the  24th  Conference  of  the  Parties  in  Katowice  in  December  2018 
supports the implementation of the Paris Agreement. It will help governments measure greenhouse 
gas emissions, report progress towards curbing carbon use and mobilise USD 100 billion a year to 
fund climate policy. 

These aims, and indeed the energy transition itself, are entirely dependent on offshore wind power. 
To fulfil them, existing offshore assets should be cost-effectively and sustainably expanded. 

The  vast  offshore  wind-power  potential  in  the  North  Seas  is  one  of  Europe‘s  greatest  renewable 
assets. The North Seas region has an estimated economically attractive potential of more than 635 
GW by 20302. It is already being tapped, with installed wind capacity expected to reach 90 GW in the 
next  ten  years3  Based  on  these  numbers,  it  becomes  clear  that  exploiting  the  vast  wind  energy 
potential of the North Seas region will make a major contribution to the fulfilment of the Paris Climate 
Agreement and for tackling climate change. 

But  to  fully  exploit  the  potential,  wind  farms  need  to  be  built  ever  further  out  to  sea.  This  makes 
development more complicated and more expensive. If viable projects are to be realised, it is crucial 
to  reduce  the  costs  of  and  the  space  needed  by  offshore  assets  using  innovative  solutions  that 
efficiently connect wind farms to land. Hybrid projects offer just such a solution. 

Traditionally, offshore wind-power projects have a strong national focus with the power transmission 
line feeding just one national grid. Additionally, offshore generation is usually not coordinated with 
nearby developments in other countries. Hybrid projects are different; they combine the generation 
and transmission elements, linking two or more countries and providing a platform for coordination 
between them. By contrast, the term reference case applies to offshore developments in the North 
Seas  consisting  of  separately  developed  generation  and  transmission  assets.  They  are  used  as 
benchmarks for the evaluation of hybrid projects throughout the study.  

The study groups hybrid projects into five concepts (Figure 1). 

2 WindEurope. 2017. Unleashing Europe's offshore wind potential. https://windeurope.org/wp-
content/uploads/files/about-wind/reports/Unleashing-Europes-offshore-wind-potential.pdf 

3 Estimate based on assessment of existing studies. Refer to Gorenstein Dedecca, Joao and Rudi 
A. Hakvoort. 2017. A review of the North Seas offshore grid modelling: Current and future research. 
https://doi.org/10.1016/j.rser.2016.01.112. 

 
 
 
                                                      
 
2   HYBRID PROJECTS: HOW TO REDUCE COSTS AND SPACE OF OFFSHORE DEVELOPMENTS 

  North Seas Offshore Energy Clusters study 

Figure 1: Hybrid project concepts 

▪  A  "combined  grid  solution"  connects  two  offshore  wind  farms  (OWFs)  in  different  exclusive 
economic  zones  (EEZs),  both  of  which  are  individually  connected  to  the  shore  of  their  home 
country. An example is the Kriegers Flak transmission project between Denmark and Germany 
(see Figure 2). 

▪  A "modular grid" connects multiple OWFs, located in different EEZs, to shore via a single export 
cable system. Although it  lacks a transnational  dimension,  one example of this  concept  is the 
Modular Offshore Grid in Belgium, which connects nine OWFs to shore.  

▪  An "interconnector tie-in" connects an OWF to shore via an interconnector. No examples of this 

concept currently exist.  

▪  An  "offshore  hub"  connects  multiple  OWFs  to  at  least  two  markets  via  an  offshore  hub.  The 

proposed North Sea Wind Power Hub is an example of this concept. 

▪  A "neighbour OWF" connects an OWF located in the EEZ of country 1 to the shore of country 2. 

No examples of this concept currently exist. 

Kriegers Flak Combined Grid Solution 

Via  an  interconnector,  the  Kriegers  Flak  Combined  Grid  Solution  (KF  CGS)  links  the  offshore 
substations of the export cable system of the Danish OWF Kriegers Flak (600 MW) and the offshore 
substation of the export cable system of the German OWFs Baltic 1 (48 MW) and Baltic 2 (288 MW) 
in the Baltic Sea to onshore connection points in Bentwisch, Germany, and Bjæverskov, Denmark. 

Combined grid solutionABModular gridCInterconnector tie-inOffshore wind farmConverter stationEEZborderOffshorecableOffshore hubDENeighbour OWF 
 
 
 
3   HYBRID PROJECTS: HOW TO REDUCE COSTS AND SPACE OF OFFSHORE DEVELOPMENTS 

  North Seas Offshore Energy Clusters study 

The installation should become operational in 2019.4 Its technical design challenges and additional 
success factors are briefly outlined in this box. 

The KF CGS technical design is based on a connection between the  offshore substations of the 
export  cable  systems  of  Kriegers  Flak  and  Baltic  2  via  two  subsea  cables.  As  the  Danish  and 
German OWFs use different voltage levels (150 vs. 220 kV), an offshore transformer module has 
been  fitted  on  the  Danish  offshore  platform.  Additionally,  two  serially  connected  voltage  source 
converters will be installed onshore in Bentwisch because the German and Danish electricity grids 
are not synchronised. An upgraded control system in Berlin controls the entire system. With these 
technological  additions  to  the  design  of  the  OWFs  in  place,  the  transmission  system  operators 
(TSOs), 50Hertz and Energinet, can physically connect the German and Danish grids.  

As well as overcoming several technological challenges, the KF CGS has several advantages. First, 
Germany  and  Denmark  have  closely  collaborated  on  energy  issues  before.  For  example,  they 
implemented a cooperative RES subsidy  scheme for photovoltaics based on statistical transfers 
between Germany and Denmark.5 Second, at an early stage, the stakeholders were able to agree 
on a feasible technical setup which all parties view as operationally efficient and cost-competitive. 
Third,  the  project  clearly 
fulfils  a  pilot  function,  has 
PCI status and receives up 
to  EUR  150  m  in  funding 
from  the  European  Energy 
Programme  for  Recovery.6 
Fourth, the project received 
support  from  the  national 
regulators in Germany and 
Denmark,  giving  the  TSOs 
a 
to 
clear  mandate 
the 
collaborate 
and 
to  make 
opportunity 
anticipatory 
investments. 
Additionally, the market-to-
market  flows  increase  the 
level  of  security  of  supply  in  the  Eastern  Danish  bidding  zone.  Together,  these  factors  facilitate 
efficient project implementation. 

Figure 2: Kriegers Flak Combined Grid Solution  

Hybrid projects have several benefits. As well as offering significant potential for cost savings, they 
take up less space, thereby lowering environmental impact. In the North Seas, they also create cross-

4 Energinet. 2018. KRIEGERS FLAK – COMBINED GRID SOLUTION. 
https://en.energinet.dk/Infrastructure-Projects/Projektliste/KriegersFlakCGS 

5 The Government of the Federal Republic of Germany and the Government of the Kingdom of 
Denmark. 2016. Agreement on the Establishment of a Framework for the Partial Opening of 
National Support Schemes to Support the Generation of Energy from Solar Photovoltaic Projects. 
https://www.bmwi.de/Redaktion/EN/Downloads/agreement-between-germany-and-
denmark.pdf?__blob=publicationFile&v=4 

6 European Commission. 2013. Fact sheet: Baltic-Kriegers Flak: Combined grid solution. 
http://ec.europa.eu/energy/eepr/projects/files/offshore-wind-energy/baltic-kriegers-flak_en.pdf 

DenmarkGermanyIshøjBjæverskovKriegersFlak (DK)Baltic 2 (DE)Baltic 1 (DE)BentwischCGSproject (interconnector)Converter station (AC/DC)400 kV substation (AC)220 kV substation (AC)150 kV substation (AC)220 kV cable150 kV cableSweden 
 
                                                      
 
4   HYBRID PROJECTS: HOW TO REDUCE COSTS AND SPACE OF OFFSHORE DEVELOPMENTS 

  North Seas Offshore Energy Clusters study 

border links, helping to provide additional interconnection capacity and underpinning the EU’s internal 
energy market. The European offshore industry and job market benefit, too. 

The use of hybrid projects to exploit the North Seas’ wind-power potential also has political support. 
In  2016,  countries  in  the  North  Seas  region  (Ireland,  the  United  Kingdom,  France,  Belgium,  the 
Netherlands, Luxembourg, Germany, Denmark, Norway and Sweden) signed the North Seas Energy 
Cooperation declaration. It aims to strengthen cooperation on energy and improve conditions for the 
development of offshore wind energy, ensuring a sustainable, secure and affordable energy supply 
in  the  region.  As  part  of  this,  it  encourages  transmission  system  operators  and  offshore  wind 
developers to become early movers in hybrid projects. 

Such  initiatives  are  helping  hybrid  projects  to  gain  momentum.  Although  only  one  has  been 
implemented so far – Kriegers Flak, which is nearing commissioning – more and more stakeholders 
in the North Seas region are now taking an interest and developing a better understanding of project 
economics and benefits. At the same time, progress in harmonising EU energy policies and regulation 
has  changed  perceptions  of  the  challenges  developers  face  in  realising  them.  Additionally,  the 
European Commission is placing an emphasis on cross-border infrastructure projects.7  

However,  hybrid  projects  are  more  challenging  to  develop  than  conventional  offshore  wind-power 
projects. For example, they pose significant legal and regulatory barriers. Bearing in mind their key 
role in the energy transition and decarbonisation, this means there is a clear need to assess their use 
in practice. 

Against this backdrop, this study analyses potential hybrid projects featuring  offshore transmission 
and generation assets which are currently at an early planning stage. It serves two purposes: 

▪  To  assess  the  costs  and  benefits  of  hybrid  projects  compared  to  conventional,  separately 

developed offshore generation and transmission projects (reference cases); and 

▪  To develop concrete Action Plans to overcome barriers to hybrid project development. 

The  study  has  the  ambition  to  encourage  developers  to  become  early  movers  in  hybrid  project 
development  and  public  authorities  to  commit  to  them.  It  also  aims  to  help  generate  a  pipeline  of 
feasible hybrid  projects that are  beneficial compared  to run than their  respective reference cases. 
This represents a first step towards the long-term vision of an integrated offshore grid in the North 
Seas region (see Figure 3). 

Collaboration with the PROMOTioN project 

The  "PROgress  on  Meshed  HVDC  Offshore  Transmission  Networks"  (PROMOTioN)  project8  is 
exploring the long-term vision of a meshed offshore grid in the North Sea. It is funded by the EU 
Horizon  2020  programme  on  "Competitive  Low-Carbon  Energy".  The  project  builds  a  bridge 
between research, validation and testing of technology, and the development of recommendations 
for meshed offshore grids. Specifically, its objectives regarding meshed offshore grids in the North 
Seas region are:  

7 European Commission. 2018. Factsheet: Connecting Europe Facility. 
https://ec.europa.eu/energy/sites/ener/files/documents/cef_factsheet.pdf; 

European Commission. 2017. Communication on strengthening Europe's energy networks. 
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52017DC0718&from=EN 

8 PROMOTioN. 2018. PROMOTioN. https://www.promotion-offshore.net/ 

 
 
 
                                                      
 
5   HYBRID PROJECTS: HOW TO REDUCE COSTS AND SPACE OF OFFSHORE DEVELOPMENTS 

  North Seas Offshore Energy Clusters study 

▪  To identify the technical, financial and regulatory requirements for energy infrastructure priority 

corridors; 

▪  To facilitate agreement among operators and manufacturers; 

▪  To demonstrate cost-effective HVDC grid technologies; 

▪  To prepare the first phase for the deployment of innovative components; 

▪  To propose market rules and revenue streams; and 

▪  To propose regulations for permitting and environmental compatibility.  

The project was launched in 2016 and will be finalised at the end of 2019. Its consortium includes 
more than 30 partners from 11 countries and is organised in 15 work packages, for which interim 
results are available. 

This  study  has  engaged  closely  with  the  PROMOTioN  project  partners  on  various  occasions. 
Although  there  is  a  thematic  overlap,  especially  regarding  PROMOTioN  Work  Package  7  on 
regulation and financing, the work of this study focuses on a practical path towards the shorter-term 
implementation  of hybrid projects. The PROMOTioN  project, however, focuses  on the  long-term 
implementation  of  a  meshed  offshore  grid  and  the  corresponding  technological  challenges. 
Nonetheless, the work of this study and the work of PROMOTioN are complementary. 

The  inclusion  of  new  technologies,  such  as  those  investigated  by  PROMOTioN,  in  the  hybrid 
projects presented in this study is feasible, especially considering their potential pilot character. The 
hybrid projects identified in this study can therefore serve as potential demonstration projects for 
the  technology  investigated  by  PROMOTioN.  This  comprises  circuit  breakers,  gas-insulated 
switchgear, network protection systems and extended network control strategies. However, given 
the developmental status of the PROMOTioN technology, the risks associated with demonstrating 
the technology in a hybrid project should be shared on an equitable basis. 

Figure 3: Collaboration with PROMOTioN project 

The hybrid project ideas considered in this study are geographically located in four regional clusters 
(Figure  4):  Irish  Sea  /  North  Channel,  UK-Netherlands-Belgium  (UK-NL-BE),  Dogger  Bank  and 
German Bight.  

 
 
 
6   HYBRID PROJECTS: HOW TO REDUCE COSTS AND SPACE OF OFFSHORE DEVELOPMENTS 

  North Seas Offshore Energy Clusters study 

Figure 4: Hybrid project clusters 

To summarise the findings, this study breaks down into five main chapters (Figure 5): 

▪  Chapter 1 gives a general introduction to hybrid projects as well as to the context and the purpose 

of this study. 

▪  Chapter 2 summarises the findings  of the assessment of costs and benefits across the hybrid 
project  ideas  discussed.  In  total,  18  hybrid  project  ideas  are  identified,  all  based  on  an 
assessment of offshore generation and transmission assets which are due to be commissioned 
by  2030.9 These are compared  with their respective reference cases to  deduce  their  potential 
advantages. All work was carried out in close collaboration with stakeholders. The chapter finds 
that  coordinated,  transnational  development  of  generation  and  transmission  projects  creates 
potential for synergies. 

▪  Chapter  3  summarises  the  findings  on  the  barriers  facing  hybrid  projects.  The  study  identifies 
barriers to the commencement of project development in association with commercial and public 
stakeholders. The chapter finds that hybrid projects are subject to additional risks compared to 
their respective reference cases. 

▪  Chapter 4 outlines case studies of ten hybrid project ideas. These compare the costs and socio-
economic welfare (SEW)10 benefits arising from the hybrid projects with their respective reference 
cases. They also outline project-specific Action Plans – developed with commercial and public 
stakeholders – that help to overcome the identified barriers in each hybrid project development. 
The Action Plans define required actions, responsibilities and timelines, and can be used once 
an  individual  hybrid  project  has  been  given  the  go-ahead.  The  chapter  finds  that  concrete 
mitigation measures can address the additional risk involved in hybrid projects. 

9 With the exception of the North Sea Wind Power Hub (NSWPH) with a planned commissioning 
post-2030 (ENTSO-E. 2018. Project 335 – North Sea Wind Power Hub. 
https://tyndp.entsoe.eu/tyndp2018/projects/projects/335).  

10 Socio-economic welfare (SEW) consists of producer surplus, consumer surplus and congestion 
rent. 

UK-NL-BEIrish Sea/ North ChannelDogger BankGerman Bight 
 
 
                                                      
 
7   HYBRID PROJECTS: HOW TO REDUCE COSTS AND SPACE OF OFFSHORE DEVELOPMENTS 

  North Seas Offshore Energy Clusters study 

▪  Chapter  5  is  the  appendix.  It  includes  project-specific  documentation  about  interaction  with 
stakeholders on the assessment of barriers as well as the identification and selection of barrier 
mitigation measures. 

Figure 5: Study methodology 

For the remainder of this document,  

▪  Hybrid projects and hybrid project ideas always mean the combined development of  offshore 

electricity generation and transmission assets across maritime borders.  

▪  On  the  other  hand,  the  respective  reference  case  always  means  the  conventional,  separate 
development of generation and transmission assets connected to the same countries and with 
the same capacities as in the corresponding hybrid project.  

For example, while an OWF may be connected to two markets via an interconnector in the hybrid 
project, the interconnector could be a stand-alone, point-to-point interconnector in the reference case.  

Assess the costs and benefits of hybrid projectsDevelop concrete actions to overcome barriers>Identification of barriers>Identification of mitigation options>Development of Action PlansChapter 2Chapter 3>Long list of hybrid projects–Collection of asset inventory–High-level assessment of hybrid projects>Short list of hybrid projects–Details of hybrid projects–Assessment of hybrid projects-Cost assessment-Market modelling>Identification of barriers to commencement of hybrid project development>Identification, assessment and selection of mitigation options>Development of Action Plans to implement selected mitigation options>Detailed project-specific findings for the ten most promising hybrid projectsCase studies of selected hybrid projectsChapter 4 
 
 
 
 
 
8   HYBRID PROJECTS: HOW TO REDUCE COSTS AND SPACE OF OFFSHORE DEVELOPMENTS 

  North Seas Offshore Energy Clusters study 

2.  Assessing the costs and benefits of hybrid projects 

Key findings 

▪  The  study’s  assessment  of  costs  and  benefits  shows  that  hybrid  projects  can  have  an 
advantage over conventional offshore projects. Of the ten hybrid projects assessed in detail, 
five have an advantage over their respective reference case, while five are at a comparative 
disadvantage. 

▪  Significant savings  can  be  realised over  the project lifetime of advantageous hybrid  projects 
compared to their respective reference case. Depending on project setup and size, these are 
in the range of EUR 300 m to EUR 2,500 m. This translates into savings of between 5% and 
10% of total project costs.  

▪  There are several further benefits. Hybrid projects allow for more efficient use of space in the 
already crowded North Seas region compared to the respective reference cases. This reduces 
environmental  impact  and  ensures  transmission  and  generation  capacity  has  a  significantly 
reduced footprint. 

▪  Compared to the respective reference cases, hybrid projects support the development of the 
internal energy market by providing additional interconnection capacity. They also contribute to 
a more sustainable energy mix by offering additional OWF generation capacity. In addition, the 
projects  stimulate  the  offshore  industry’s  competitiveness  by  providing  a  platform  for  the 
development and implementation of new technologies. 

▪  The  assessment  findings  are  only  a  starting  point  for  the  development  of  hybrid  projects. 
Throughout  the  development  process  further  action  is  required,  for  example,  on  detailed 
technical  planning,  preparation  of  the  supply  chain  and  analyses  of  electricity  flows  and 
operational feasibility. 

2.1  Methodology 

The assessment of the costs and benefits of hybrid projects involved two main activities, as shown in 
Figure 6. First, the study identified a long list of hybrid projects; second, it selected a short list of the 
most promising projects and evaluated these in detail.  

 
 
 
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Figure 6: Methodology of demonstrating the advantage of hybrid projects 

To  draw  up  the  long  list  of  hybrid  projects,  the  study  created  an  inventory  of  OWFs  and 
interconnectors.  This  considered  all  OWFs  in  the  Irish,  UK,  Belgian,  Dutch,  German,  Danish  and 
Norwegian EEZs that are currently operational or due to be commissioned by 2030. It also considered 
all  interconnectors  which  link  any  two  of  the  above-mentioned  countries  and  that  are  currently 
operational  or  due  to  be  commissioned  by  2030.  Additionally,  the  study  considered  the  possible 
generation  and  transmission  infrastructure  of  the  NSWPH,  even  though  this  hybrid  project  has  a 
commissioning horizon beyond 2030. The inventory was aligned with WindEurope's central scenario 
forecast of installed OWF capacity by 2030.11 A long list of 18 hybrid project ideas was identified from 
the inventory.  

To select a short list of hybrid projects for further evaluation, the study conducted an initial feasibility 
check together with the stakeholder group. This was based on four dimensions: 

▪  Technical feasibility ("Can the hybrid project be implemented from a technical perspective?"); 

▪  Cable  development  ("Is  the  cable  system  of  the  hybrid  project  already  implemented  or 

specified?"); 

▪  OWF alignment ("Are there early-stage OWFs near to the cable system development?"); and 

▪  Stakeholder constellation ("Is the stakeholder group complex and are there sufficient incentives 

for stakeholder engagement?"). 

11 The OWF inventory was cross-referenced with WindEurope's forecast of installed OWF capacity 
by 2030 (WindEurope. 2017. Wind energy in Europe: Scenarios for 2030. 
https://windeurope.org/wp-content/uploads/files/about-wind/reports/Wind-energy-in-Europe-
Scenarios-for-2030.pdf). The cross-check found no notable differences in estimated capacities for 
Ireland and Denmark, slight differences for the UK (~Δ400 MW), Belgium (~Δ280 MW) and the 
Netherlands (~Δ60 MW) and different expectations for the completion of an individual OWF before 
2030 in Germany (~Δ865 MW). Overall, the assessments are aligned. 

>Identification of OWFs planned to be commissioned by 2030 (incl. NSWPH with commissioning post-2030)>Identification of ICs planned to be commissioned by 2030 (incl. NSWPH with commissioning post-2030)>Alignment of OWFinventory with WindEurope (OWFcapacity by 2030)>More than 40 structured interviews (e.g. OWF developers, TSOs, national ministries and NRAs) to generate short list>Definition of hybrid project and reference case together with project-specific stakeholders>Alignment on technical and commercial specifications (e.g. cable technology, capacity and cable length)>Cost assessment based on comparison of hybrid project and reference case CAPEX and OPEX>Market modelling to calculate socio-economic welfare, energy not served, RES curtailment and CO2emissionsCollection of asset inventoryHigh-level assessment of hybrid projectsLong list of hybrid projectsShort list of hybrid projectsDetails of hybrid projectsDetailed assessment of hybrid projects 
 
 
                                                      
 
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Hybrid project ideas were only taken forward if all four dimensions were assessed positively. After 
more than 40 interviews, meetings and a survey involving relevant stakeholders, the study selected 
a short list of ten hybrid project ideas for further evaluation. 

Before evaluating the ten projects, the study looked in more detail at the technical and commercial 
specifications  of  the  hybrid  projects  and  their  reference  cases.  This  was  done  to  enable  a  better 
comparison  of  them.  Technical  specifications  included,  for  example,  generation  and  transmission 
capacity, transmission technology, cable system length, required electrical equipment and capacity 
for  example,  capital  expenditures  (CAPEX), 
factors.  Commercial  specifications 
development  period,  construction  period,  operation  /  depreciation  period,  regulated  revenues  and 
operating expenses (OPEX).  

included, 

The  evaluation  process  of  the  short-listed  hybrid  projects  consisted  of  two  components:  cost 
assessment and market modelling. Both were used to assess whether a hybrid project would deliver 
lifetime savings over the respective reference case. For the cost assessment component, the study 
calculated  the  CAPEX  and  OPEX  of  all  assets  included  in  the  hybrid  project  and  in  the  reference 
cases. CAPEX is assumed to be fully incurred with commissioning of the project and is therefore not 
discounted. OPEX is calculated and discounted over a typical asset lifetime of 25 years,12 unless the 
project-specific stakeholders specified a different asset lifetime. 

For the market modelling component, the study relied on the expertise of the Joint Research Centre 
of the European Commission. The modelling was based on the METIS model, which is used by the 
European Commission to inform evidence-based policy-making.13 It allows for an hourly optimisation 
of the European power system, minimising the variable cost of generation while respecting technical 
and economic operating constraints.  

The  modelled  scenarios  feature  a  specific  hybrid  project  and  its  reference  case,  using  the  same 
project details as the cost assessment. For each scenario the following indicators were calculated: 

▪  Socio-economic welfare (EUR m p.a.). The socio-economic welfare for a given delivery point (i.e. 
a given country) is the sum of its consumer surplus, its producer surplus and half of the congestion 
rent  for  power  transmission  lines  connected  to  the  delivery  point.  A  consumer  surplus  occurs 
when the consumer is willing to pay more for a given product than the current market price. The 
consumers'  benefit  equals  the  value  of  loss  of  load  (VoLL),  which  is  15,000  EUR/MWh  in  the 
model. A producer surplus occurs when the producers is paid more for a given product than the 
minimum  amount  the  producer  is  willing  to  accept  in  terms  of  cost  of  its  production.  The 
congestion rent is the benefit made when transferring energy from a zone to another, meaning 
the cost saved from using a production from another zone to meet local demand. 

▪  Energy not served (MWh/a). Energy not served is the expected energy not delivered to market 
demand. The model assumes a value of loss of load of 15,000 EUR/MWh as penalty factor, which 
ensures that the model minimizes energy not served in the simulation. 

▪  RES  curtailment  (MWh/a).  RES  curtailment  is  the  expected  energy  not  produced  due  to 
curtailment measured. RES curtailment is minimised in the model using a penalty factor equal to 
0.5 EUR/MWh. 

12 Ioannou, Anastasia, Andrew Anguas, Feargal Brennan. 2018. A lifecycle techno-economic model 
of offshore wind energy for different entry and exit instances. Applied Energy. 
https://doi.org/10.1016/j.apenergy.2018.03.143 

13 European Commission. 2018. METIS – Modelling the European Energy System. 
https://ec.europa.eu/energy/en/data-analysis/energy-modelling/metis 

 
 
                                                      
 
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  North Seas Offshore Energy Clusters study 

▪  CO2 emissions (kt/a). CO2 emissions measure the variation of the system's emissions of CO2. 
The economic value of the emissions is internalised in the producer surplus of the socio-economic 
welfare.  The  price  of  the  emissions  is  consistent  with  the  EUCO30  scenario  at  27  EUR/t.  To 
calculate the economic value of the emissions, the model places "coal before gas" in the merit 
order curve. 

Variations in these indicators between the hybrid project and the reference case make it possible to 
identify the additional benefits related to the hybrid project. The model is based on the following key 
assumptions. 

▪  The  generation  mix  and  demand  in  2030  are  based  on  the  PRIMES  EUCO30  2030  scenario 
implemented in METIS. It uses adapted capacities for offshore wind according to the inventory of 
OWFs compiled by this study for the identification of potential hybrid projects.  

▪  The transmission system in 2030 is based on the ENTSO-E TYNDP 2018 and TYNDP 2016. It 
uses  adapted  figures  for  offshore  interconnection  capacity  depending  on  the  inventory  of 
interconnectors compiled by this study for the identification of potential hybrid projects.  

▪  The model represents each country as a single node in the electricity grid and therefore does not 

consider networks inside countries. 

▪  The  model  uses  a  direct  current  approximation  and  therefore  does  not  take  into  account 

transmission losses. 

▪  The power exchanges between the defined zones are modelled using the Net Transfer Capacity 

approach.  

▪  The model assumed a price of EUR 27 per ton of CO2 in line with PRIMES EUCO30 2030, which 

is internalised in the operating cost of generators. 

A detailed explanation of the model, the underlying assumptions and the modelling results are given 
in Careri, Francesco. [Forthcoming]. The impact of North Sea electricity projects in a 2030 scenario: 
Preliminary  assessment  of  system  benefits  for  the  pan-European  power  system  through  METIS. 
Petten: European Commission Joint Research Centre. 

2.2  Findings 

The study provides a detailed assessment of ten hybrid projects across four regions (Figure 7). The 
assessment considers the differences between hybrid projects and respective reference cases with 
regards to CAPEX, OPEX and socio-economic welfare (SEW) over a 25-year operational period. It 
finds that four hybrid projects have a significant advantage over their respective reference cases. A 
significant advantage means that lifetime savings are in excess of 5% of the total lifetime costs of the 
respective reference case. Total lifetime costs consist of CAPEX and OPEX over a typical 25-year 
operation period. The four advantageous hybrid projects are geographically located in the UK-NL-BE, 
German Bight and (close to) the Dogger Bank area of the North Seas region. They are: 

▪ 

IJmuiden Ver to UK: A Dutch OWF in the IJmuiden Ver area is linked to the UK electricity market 
via an interconnector and to the Dutch electricity market via an export cable system. 

▪  CGS  IJmuiden  Ver  to  Norfolk:  The  UK  and  Dutch  electricity  markets  are  linked  by  an 
interconnector between a  UK OWF in the Norfolk area and a Dutch OWF in the IJmuiden Ver 
area. Both OWFs have radial connections to their home markets. 

▪  North  Sea  Wind  Power  Hub  (NSWPH):  OWFs  in  the  Dutch,  German  and  Danish  EEZs  are 
connected  to  the  Dutch,  German  and  Western  Danish  electricity  markets  via  a  hub.  The  hub 

 
 
12   HYBRID PROJECTS: HOW TO REDUCE COSTS AND SPACE OF OFFSHORE DEVELOPMENTS 

  North Seas Offshore Energy Clusters study 

features  cable  connections  to  the  Netherlands,  Germany  and  Denmark  which  can  function  as 
export cable systems and as interconnectors. 

▪  COBRA Cable: The so-called leftover OWF areas in the German Cluster 8 are connected to the 

Dutch and Western Danish electricity markets via the COBRA Cable interconnector. 

Two further hybrid projects demonstrate a moderate advantage over their respective reference cases, 
where  a moderate advantage means lifetime savings  of up to  5% of the  total lifetime costs of the 
respective reference case. The two hybrid projects are geographically located in the UK-NL-BE and 
German Bight area of the North Seas region. They are: 

▪  NeuConnect: The OWFs in the German Cluster 1 (OWP West, Borkum Riffgrund West 1 and 
Borkum  Riffgrund  West  2)  are  linked  to  the  UK  and  German  electricity  markets  via  the 
NeuConnect interconnector.14 

▪  DE OWF to NL: A German OWF is radially connected to the Netherlands only. 

The  remaining  four  hybrid  projects  are  at  a  disadvantage  compared  to  their  respective  reference 
cases. This means that implementation of these hybrid projects would lead to additional lifetime costs 
compared to the respective reference cases. These hybrid projects are geographically located in the 
Irish Sea / North Channel, UK-NL-BE and German Bight area of the North Seas region. They are: 

▪  Project Irish Sea: An Irish OWF is combined with an interconnector from Ireland to the UK. Both 
the OWF and the interconnector are linked to the same onshore converter station in Ireland. 

▪  Nautilus: A Belgian OWF is connected to the UK and Belgian electricity markets via the Nautilus 

interconnector. 

▪  UK OWF connected to BE: A UK OWF is connected to the Belgian electricity market only. 

▪  CGS DE OWF to NL OWF: A Dutch OWF in the extreme eastern part of the Dutch EEZ and a 
German OWF in the extreme western part of the German EEZ are linked via an interconnector. 
Both OWFs have radial connections to their home markets. 

14 NeuConnect is not further considered in this study with regard to the assessment of barriers and 
the development of barrier mitigations as project stakeholders are not sufficiently incentivised to 
engage in the hybrid project development due to the advanced planning stages of the conventional, 
separate assets.  

 
 
 
                                                      
 
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Figure 7: Overview of assessment of costs and benefits across hybrid project ideas 

In summary, the assessments of the ten projects considered in detail show that each is unique and 
needs to be considered on a case-by-case basis. Whether a hybrid project has an advantage over 
the  respective  reference  case  depends  on  the  individual  project  setup,  such  as  its  geographical 
location or technical layout. Chapters 2.2.1 to 2.2.3 seek to summarise the findings that can serve as 
instructive starting points for the selection of hybrid project ideas in the future. However, they should 
not be adopted without thorough individual assessment. 

2.2.1 

Significant savings over the project lifetime 

Based on the sample of ten hybrid project ideas considered in this study, lifetime savings of between 
5% and 10% are possible – or EUR 300 m to EUR 2.5 bn in absolute numbers (Figure 8). This is 
based  on  a  comparison  between  the  implementation  and  operation  of  a  hybrid  project  and  the 
implementation and operation of the respective reference case. Cost savings are realised differently 
for each hybrid project depending on its setup, but can be summarised on the basis of four drivers: 

▪  Reducing kilometres of export cable system. This involves shortening the distance from an OWF 
to the connection point,  either by connecting the OWF to a closer shore  than  in the reference 
case, or to an interconnector. Shorter export cable systems reduce the CAPEX and OPEX of an 
installation.  

▪  Reducing kilometres of interconnector cable. This is achieved by linking OWFs or by connecting 
an  OWF  to  an  additional  market  via  an  interconnector  instead  of  having  a  shore-to-shore 
interconnector. Fewer kilometres of cable reduce the CAPEX and OPEX of an installation.  

▪  Reducing  the  number  of  onshore  and  offshore  substations.  This  is  done  by  combining  OWF 
export  cable  systems  and  interconnectors,  which  both  increases  utilisation  and  decreases  the 

1)         if >5%,         if between 5% and 0%,          if 0%,          if between 0% and -5%,          if <-5% benefits relative to reference case∆SEW1)∆CAPEX1)∆OPEX1)∆Lifetime savings1)2Nautilus3UK OWF to BE4IJmuiden Ver to UK5CGS IJmuiden Ver to NorfolkCOBRA Cable8North Sea Wind Power Hub7NeuConnect6DE OWF to NL10Project Irish Sea1CGS DE OWF to NL OWF9 
 
 
14   HYBRID PROJECTS: HOW TO REDUCE COSTS AND SPACE OF OFFSHORE DEVELOPMENTS 

  North Seas Offshore Energy Clusters study 

number of substations. Fewer onshore and offshore substations reduce the CAPEX and OPEX 
of an installation. 

▪  Realising  less  expensive  operations  and  maintenance  services  for  offshore  installations.  This 
involves  creating  an  offshore  hub  in  close  proximity  to  offshore  installations  to,  for  example, 
accommodate  personnel  or  store  spare  parts.  Less  expensive  operations  and  maintenance 
services reduce the OPEX of an installation. 

The SEW is consistently positive for hybrid projects, but also consistently slightly lower than the SEW 
of the respective reference cases. Thus, while the hybrid project ideas have a positive  SEW, their 
contribution is lower than that of the respective reference cases. This is because hybrid projects utilise 
cable  systems  for  more  than  one  purpose.  For  example,  in  an  interconnector  tie-in  concept  (the 
connection of an OWF to shore via an interconnector), the capacity of the cable system between the 
countries is used both for market-to-market flows and to send electricity from the OWF to shore. In 
the  market  model  employed  by  this  study,  this  concept  either  results  in  reduced  interconnection 
capacity  or  reduced  electricity  generated  in  the  hybrid  OWF  due  to  required  curtailment  when 
compared to the reference case, and therefore in lower SEW. However, the market modelling shows 
that the difference between hybrid project SEW and reference case SEW is consistently small. When 
extrapolated for a typical 25-year lifetime, the cost savings exceed the difference in SEW by more 
than a factor of ten.  

Due  to  the  increased  implementation  probability  of  generation  and  transmission  capacities  in  real 
hybrid projects due to increased cost-efficiency, the SEW of hybrid projects can be higher than the 
SEW of the respective reference case if either generation or transmission capacity is not implemented 
at full scale in the reference case. 

Figure 8: Significant lifetime savings on hybrid projects15 

15 SEW assessment based on Careri, Francesco. [Forthcoming]. The impact of North Sea electricity 
projects in a 2030 scenario: Preliminary assessment of system benefits for the pan-European power 
system through METIS. Petten: European Commission Joint Research Centre. 

∆CAPEX∆LifetimeSEW1)∆Lifetime savings∆Lifetime OPEX (cable systems)1)SEW reference project∆SEWx 25 years∆Socio-economic welfare (SEW) (hybrid project -reference case) [EUR m p.a.]∆Lifetime savings (hybrid project -reference case) [EUR m]1) 8% discount factor-30+300+100+300-100+1,500+1,000+2,500Max.Min. 
 
 
 
                                                      
 
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The main factors that determine whether a hybrid project yields savings compared to its respective 
reference case are summarised below: 

▪ 

Interconnector tie-in concepts: Cost savings are realised if an OWF, connected to shore via an 
interconnector,  is  located  more  than  50  kilometres  from  shore  and  the  conventional  setup 
employs HVDC technology to send electricity to shore. OWFs that are less than 50 kilometres 
from shore  are  usually  connected  to  land  using  HVAC  technology,  which  does  not  include  an 
offshore converter station – in contrast to an HVDC system – and is therefore less expensive. If 
cost  savings  are  realised,  the  larger  investment  in  HVDC  technology  is  offset  by  lower  power 
losses in the cable system.16 

▪  Combined grid solution concepts: Cost savings are realised in a similar way to interconnector tie-
in concepts. Significant savings are generated if OWFs connected by an offshore interconnector 
are  located  more  than  50  kilometres  from  shore  and  the  conventional  setup  employs  HVDC 
technology  to  send  electricity  to  shore.  For  OWFs  located  less  than  50  kilometres  offshore 
employing  HVAC  technology,  the  cost  of  upgrading  to  HVDC  technology  makes  no  economic 
sense. So, combined grid solution concepts are likely to generate significant cost savings  only 
where OWFs are located further than 50 kilometres from any shore. 

▪  Neighbour  OWF  concepts:  Cost  savings  can  only  be  realised  via  cable  savings,  meaning  the 
hybrid  project  must  include  a  connection  to  a  closer  onshore  connection  point  than  in  the 
reference case. In addition, the avoidance of onshore grid reinforcement can be advantageous, 
depending on the specific project setup. 

▪  Offshore  hub  concepts:  Cost  savings  are  realised  through  multiple  factors.  First,  savings  are 
realised by reducing the CAPEX of substations. These can be placed on the hub, removing the 
need for their own offshore foundations. Second, the space available on an offshore hub allow 
for  larger  substations  with  cheaper  designs.  Third,  offshore  hubs  allow  for  the  cost-effective 
maintenance  of  equipment,  accommodation  of  staff  and  provision  of  port  and  helicopter 
infrastructure, decreasing OPEX. However, OPEX savings also depend on the distance between 
an offshore hub and the closest market from where maintenance can be provided. The combined 
CAPEX and OPEX savings must outweigh the additional cost of building an offshore hub. Other 
factors  can  also  drive  down  costs  or  provide  additional  revenues.  Examples  include  providing 
power-to-gas services, providing a basis for training and research activities and offering touristic 
activities. 

▪  Modular grid concept: This study did not find any modular grid concept-based hybrid project idea 
which  merited  inclusion  in  the  detailed  assessment.  It  is  therefore  not  possible  to  determine 
whether such a project yields savings or not.  

2.2.2  Reduced need for space and environmental impact 

Improved transnational coordination is  necessary  in the North Seas due to  the  limited space. The 
area is heavily used for oil and gas, maritime transport and fishing, for example (Figure 9). In addition, 
there  are  extensive  environmentally  protected  zones  in  the  region,  known  as  Natura  2000.  For 

16 According to ABB (Why HVDC: Economic and environmental Advantages. 
https://new.abb.com/systems/hvdc/why-hvdc/economic-and-environmental-advantages) the break-
even distance for the offshore deployment of HVDC over HVAC technology typically is about 50 km. 
However, since the break-even distance depends on multiple factors, an analysis must be 
performed for each individual case. 

 
 
                                                      
 
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  North Seas Offshore Energy Clusters study 

example,  about  30%  of  the  German  EEZ  is  defined  as  a  Natura  2000  area.17  However,  the 
development of OWFs in or adjacent to Natura 2000 areas is not a priori excluded, as set out in the 
European  Commission's  guidance  document  "Wind  energy  developments  and  Natura  2000"18.  It 
draws on the EU’S Birds and Habitats Directives19, which established the organised network of Natura 
2000 areas to protect nature and wildlife. That said, the use of such sites for OWF development is 
either very cost-intensive, due to the need for thorough environmental impact assessments, or simply 
not envisaged. Many Member States choose to assert that designated Natura 2000 areas are, by 
definition, "no-go areas" for the development of OWFs.20 

The Wadden Sea accounts for the largest share of the Natura 2000 area in both the Netherlands and 
Germany. With a surface area of about 10,000 km2, the area is directly off the coastline of the two 
countries. As a result, many cable systems must cross the Wadden Sea Natura 2000 area. To deal 
with this situation, Germany's Wadden Sea Plan21 confines such cable systems to a restricted number 
of corridors that have the least impact on the environment. Indeed, the plan states the requirement 
"to concentrate cable crossings through the Wadden Sea within a minimum of cable corridors and a 
minimum  of  cables,  using  the  best  available  techniques,  e.g.  cables  with  the  highest  capacity 
available". 

Against this backdrop, hybrid projects help to reduce the space required for offshore power generation 
and transmission developments. They use fewer substations and fewer or shorter cables to achieve 
the same generation and transmission capacity. In addition, their reduced need for offshore space 
compared to their respective reference cases results in a lower environmental impact. Thus, hybrid 
projects facilitate environmental preservation, while integrating more OWF generation capacity in the 
energy mix.  

17 Federal Agency for Nature Conservation. 2014. Marine Natura 2000 sites in the German North 
Sea and Baltic Sea. https://www.bfn.de/en/service/facts-and-figures/nature-conservation/nature-
conservation-areas/marine-natura-2000-areas-in-the-north-sea-and-baltic-sea.html 

18 European Commission. 2011. Wind energy developments and Natura 2000. 
http://ec.europa.eu/environment/nature/natura2000/management/docs/Wind_farms.pdf 

19 European Commission. 2015. The Birds and Habitats Directives. 
https://publications.europa.eu/en/publication-detail/-/publication/7230759d-f136-44ae-9715-
1eacc26a11af 

20 WindEurope. 2017. Offshore wind energy in the North Sea: Industry recommendations for the 
North Seas Energy Forum. https://windeurope.org/wp-content/uploads/files/policy/position-
papers/WindEurope-Offshore-wind-energy-in-the-north-sea.pdf 

21 Common Wadden Sea Secretariat. 2010. Wadden Sea Plan 2010. http://www.waddensea-
secretariat.org/sites/default/files/downloads/wsp-v2-11-02-03-final-lowres.pdf 

 
 
 
                                                      
 
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Figure 9: Diagram of the use of offshore space in the North Seas region22 

2.2.3  Other benefits for society 

As  well as providing significant savings over the project lifetime, reducing the  need for space and 
easing  environmental  impact,  hybrid  projects  yield  further  benefits  for  society.  For  example,  they 
support  the  development  of  the  EU  internal  energy  market  through  additional  interconnection 
capacity,  contribute  to  a  more  sustainable  energy  mix  by  integrating  additional  OWF  generation 
capacity  and  foster  the  competitiveness  of  the  offshore  industry  by  providing  a  platform  for  the 
development and implementation of new technologies.  

Hybrid projects thus contribute to achieving the EU's energy policy targets. The EU has agreed to 
build an Energy Union and to jointly achieve a set of targets relating to energy and climate policy. 
Among the goals are an interconnection target of 15% by 2030, an energy efficiency target of 27% 
by 2030,23 a CO2 emissions reduction target of 40% by 2030 and an innovation target to maintain EU 

22 4COffshore. 2018. 4COffshore. https://www.4coffshore.com/offshorewind/; 
Submarinecablemap. 2018. Submarinecablemap. https://www.submarinecablemap.com/#/; 
Globalfishingwatch. 2018. Globalfishingwatch. http://globalfishingwatch.org/map/; 
Natura2000. 2018. Natura2000. http://natura2000.eea.europa.eu/ 
Offshore Magazine. 2013. North Sea Offshore Oil & Gas Map. https://www.offshore-
mag.com/content/dam/offshore/print-articles/Volume%2073/08/NorthSeaMap2013-071713Ads.pdf; 
Shipmap. 2018. Shipmap. https://www.shipmap.org/. 

23 A non-binding energy efficiency target of 32.5% by 2030 was agreed in the Clean Energy 
Package negotiations. 

100 kmExisting wind fieldConsented wind fieldSearch area wind fieldSubmarine cableFishing groundsNatura 2000 areaPipelineMajor shipping routeDEDKUKNLBEOil & gas field area 
 
 
                                                      
 
18   HYBRID PROJECTS: HOW TO REDUCE COSTS AND SPACE OF OFFSHORE DEVELOPMENTS 

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leadership in renewable energy technology.24 While the energy efficiency is not affected by hybrid 
project development, the other three targets are affected. The size of a given hybrid project’s effect 
on these targets needs to be assessed individually. 

▪ 

In hybrid projects, interconnectors can be established at marginal cost. In essence, part of the 
development and construction cost for a new interconnector is saved by utilising  existing cable 
infrastructure  to  transmit  electricity  from  OWFs  to  shore.  Hybrid  projects  therefore  have  the 
potential  to  catalyse  the  development  of  interconnection  capacity  and  contribute  to  the 
development of the EU internal energy market via the 2030 interconnection target. 

▪  As hybrid projects reduce the cost and space requirements of OWF developments, they play a 
part in exploiting the full wind potential of the North Seas region, including farther offshore. Hybrid 
projects  can  thus  contribute  to  a  more  sustainable  energy  mix  by  offering  additional  OWF 
generation capacity, helping to reach the 2030 CO2 emissions reduction target. 

▪  Lastly,  hybrid  projects  enable  the  integration  of  innovative  technology.  New  concepts  such  as 
offshore power-to-gas are gaining momentum, and hybrid setups such as offshore hub concepts 
could  provide  the  space  needed  to  integrate  conversion  technology.  However,  power-to-gas 
conversion can also take place onshore. The idea behind power-to-gas is to convert renewable 
energy  to  hydrogen  for  transmission  or  storage  during  periods  of  oversupply.  Such  sector 
coupling initiatives represent a first step towards more integrated energy systems in the European 
Union, with many benefits. For example, the NSWPH could transmit offshore power to shore by 
using  power-to-gas  infrastructure,  optimising  costs  through  the  utilisation  of  existing  pipeline 
systems for transportation. That would limit investments and avoid "not in my back-yard" issues 
of new electricity transmission infrastructure. Furthermore, the conversion of electricity to gas can 
contribute  to  overcoming  onshore  grid  congestion  issues,  as  this  kind  of  coupling  provides 
additional flexibility in storage and transport. In addition, gas would facilitate more integrated uses 
of energy in other sectors. Initial hydrogen applications in the transport sector include fuel cells 
installed  in  cars,  buses,  trains  and  ferries25,  while  research  is  being  undertaken  in  heating 
applications as  well.26 In industry  applications, hydrogen has already  been used  extensively.27 
Linking the power sector (especially electricity from renewables) to other energy sectors – namely 
energy  in  buildings,  transport  and  industry  –  thus  creates  a  more  flexible,  efficient  and 
environmentally friendly energy system.28 Hydrogen could also be used as raw material for other 
i.e.  power-to-X,  where  X  represents  refined  products  such  as  methanol, 
products, 
dimethoxyethane or ammonia for use as a fertilizer. Beyond the combination of offshore power 
generation  and  power-to-gas,  hybrid  projects  can  also  contribute  to  the  advancement  of 
conventional offshore technology, such as larger-scale HVDC converter stations, large-scale DC 
breakers  and  multi-terminal  interconnector  technology.  In  this  way,  hybrid  projects  have  the 
potential  to  provide  a  platform  to  catalyse  the  development  and  implementation  of  innovative 
technology. In summary, hybrid projects contribute to the EU's aim of maintaining its leadership 
in renewable energy technology. 

24 European Commission. 2018. 2030 Energy Strategy. 
https://ec.europa.eu/energy/en/topics/energy-strategy-and-energy-union/2030-energy-strategy 

25 Hydrogen Europe. 2018. Hydrogen Uses. https://hydrogeneurope.eu/hydrogen-uses 

26 Dodds, Paul E. et al. 2015. Hydrogen and fuel cell technologies for heating: A review. London: 
University College London, Imperial College London 

27 Hydrogen Europe. 2018. Hydrogen Uses. https://hydrogeneurope.eu/hydrogen-uses 

28 WindEurope. 2018. Breaking new ground. https://windeurope.org/wp-content/uploads/files/about-
wind/reports/WindEurope-breaking-new-ground.pdf 

 
 
                                                      
 
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3.  Overcoming barriers to hybrid projects 

Key findings 

▪  While barriers to the commencement of hybrid project development exist, all can be overcome. 

They need to be addressed to provide certainty to developers. 

▪  Most  barrier  mitigation  measures  need  to  be  implemented  by  project-specific  stakeholders. 
These  include  OWF  developers,  transmission  system  operators  (TSOs),  national  ministries, 
national regulatory authorities (NRAs) and other authorities. 

▪  Some barriers necessitate the involvement of the European Commission. This may be because 
exemptions  from  European  regulations  are  required,  European  regulations  need  to  be 
amended, or because national laws need to be made compliant with European law. Thus, the 
actions  required  to  implement  mitigation  measures  should  become  part  of  the  North  Seas 
Energy Cooperation plan, which facilitates hybrid project development.  

▪  As the level of coordination required to implement hybrid projects grows, so do the number of 
relevant barriers and mitigation measures. For example, if an OWF in a hybrid project sends 
electricity to markets other than its home market, the barriers relating to market arrangement 
and RES subsidy schemes need to be considered.  

▪  Different levels of formalisation are required to implement measures to mitigate barriers. Some 
mitigation  measures  can  be  implemented  based  on  voluntary  cooperation  between  project 
developers.  Others,  such  as  defining  who  is  responsible  for  grid  connection  and  the 
interconnector,  require  a  project-specific  Memorandum  of  Understanding  (MoU),  or  even  a 
project-specific Hybrid Asset Network Support Agreement (HANSA). Generally, all barriers that 
can be mitigated through voluntary cooperation should be handled accordingly. Project-specific 
MoUs  and  HANSAs  should  only  be  deployed  where  they  are  absolutely  necessary,  as  the 
process is more complex and lengthy.  

▪  Power  conversion  to  gas  and  gas  transmission  are  increasingly  seen  as  complementary  to 
renewable  energy  sources.  However,  the  combination  creates  new  barriers  to  project 
development. For example, there is uncertainty about a legislative regime for power-to-gas and 
related infrastructure for hydrogen. No dedicated legislative framework exists at the national or 
European  level  to  regulate  power  conversion  to  hydrogen  and  /  or  hydrogen  transmission. 
Creating such a framework would pave the way towards more integrated energy systems  by 
coupling energy sectors (power, building, transport, industry). 

Legal, regulatory and other barriers hinder the development of hybrid projects. The study seeks to 
identify  these  barriers  and  develop  mitigation  measures  and  Action  Plans  for  the  five  most 
advantageous  hybrid  projects.  In  each  case,  work  focuses  on  project-specific  barriers,  and  was 
carried out with the help of relevant project stakeholders. The methodology behind and results of this 
work are presented in the subchapters below. 

3.1  Methodology 

The methodology for developing measures to overcome barriers to hybrid projects consists of three 
main  strands  (Figure  10).  First,  the  study  worked  with  stakeholders  to  identify  barriers.  Second,  it 
devised  mitigation  options  for  the  identified  barriers.  Third,  this  study  developed  Action  Plans  to 
implement  the  devised  mitigation  measures  and  thereby  overcome  the  identified  barriers.  These 
plans are intended to be a tool for stakeholders to be used once a given hybrid project has been given 
the go-ahead. 

 
 
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To begin with, a comprehensive list of barriers hindering the  initiation or progress of hybrid project 
development was drawn up. To identify barriers, stakeholder interaction was crucial. Although primary 
and secondary research into publicly available documents29 was conducted, the process of sharing, 
discussing  and  revising  the  list  of  the  most  relevant  barriers  with  different  stakeholders  was  an 
essential  part  of  the  research.  The  stakeholders  included  OWF  developers,  transmission  system 
operators (TSOs), national ministries and national regulatory authorities (NRAs). While emphasis was 
placed  on  legal  and  regulatory  barriers,  this  study  also  included  barriers  linked  to  planning 
procedures, business cases, financing as well as European and national political support. 

The study evaluated the most relevant barriers to the five most advantageous hybrid projects. Since 
each  project  has  a  different  technical  and  geographical  setup,  not  all  of  the  barriers  identified  are 
relevant to every project. A barrier was deemed to be relevant in cases where, if left unaddressed, it 
would prevent project development due to its commercial risk. If the commercial risk of a given project 
becomes too large, project developers have no incentive to drive the project towards implementation. 

The  most  feasible  mitigation  measures  were  devised,  assessed  and  selected  through  continuous 
interaction with project stakeholders. Based on these selections, Action Plans were developed. These 
map  required  implementation  activities  for  all  relevant  stakeholders.  The  identified  mitigation 
measures  and  Action  Plans  can  contribute  to  the  long-term  target  of  harmonising  the  legal  and 
regulatory framework for hybrid projects in the North Seas region, where this is found to be reasonable 
(beyond the scope of this study). 

As  part  of  the  work  on  barrier  mitigation,  in  addition  to  voluntary  cooperation,  a  project-specific 
Memorandum of Understanding (MoU) or a project-specific Hybrid Asset Network Support Agreement 
(HANSA)  were  considered.  These  formal  commitments  to  address  barriers  include  all  actions  for 
project-specific mitigation measures. Only one of the two is required for each hybrid project. 

▪  A project-specific MoU formalises the goodwill of the parties involved in the form of a non-binding 
agreement.  An  MoU  addresses  barriers  by  formalising  the  agreements  of  the  parties  involved 
with regard to the implementation of required actions to overcome barriers.  

▪  A project-specific HANSA represents a possible shorter-term option to overcome the identified 
barriers  on  a  project-specific  basis  and  in  a  legally  binding  form,  thereby  allowing  project 
development to start. Network Support Agreements (without the hybrid dimension) are an existing 
tool used by countries to formalise their commitment to support the development and operation 
of (electricity) networks. In the past, for example, such agreements have been used to overcome 
barriers in the development of cross-border gas infrastructure.30 These agreements represent a 
legally  binding  commitment  to  adapt  national  legislation  and  regulation  in  the  future,  and  thus 
provide legal certainty to developers. European legislation and regulation can only be adapted in 

29 The study relied on two databases for general reference, namely the Legal Guide to offshore 
wind in Northern Europe, provided by CMS, and RES Legal, provided by the European 
Commission. Secondary research considered, in particular, Hannah Katharina Müller's dissertation 
(2015. A legal framework for a transnational offshore grid in the North Sea, Groningen: University of 
Groningen.), the PwC, Tractebel Engineering and ECOFYS study for the European Commission 
(2016. Study on regulatory matters concerning the development of the North Sea offshore energy 
potential. Brussels: European Commission.) and the PROMOTioN project (2018. Progress on 
Meshed HVDC Offshore Transmission Networks. Brussels: European Commission). 
30 For example: Landesbergamt in Clausthal-Zellerfeld, Petroleum Safety Authority Norway. 2004. 
Memorandum of Understanding related to the Europipe and Europipe II natural gas pipelines. 
Landesbergamt in Clausthal-Zellerfeld, Petroleum Safety Authority Norway. 2004. Memorandum of 
Understanding related to the Norpipe pipeline from Ekofisk to Emden. 

 
 
                                                      
 
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consequence of a Network Support Agreement if all Member States of the European Union sign 
it. 

Figure 10: Methodology for overcoming barriers to hybrid projects 

3.2  Findings 

The  study  identifies  a  total  of  sixteen  tangible  barriers  that  are  potentially  relevant  for  the 
implementation  of  hybrid  projects.  An  overview  of  the  sixteen  barriers,  mapped  onto  five  hybrid 
projects, is shown in Figure 11. While mitigation measures to address these barriers are necessary, 
stakeholders agree that none would render hybrid project development entirely unfeasible as all are 
surmountable  in  the  foreseeable  future.  This  study  presents  the  most  recent  efforts  towards 
developing and preparing the implementation of mitigation measures for the identified barriers. 

To address the barriers identified, a concerted effort is needed from OWF developers, transmission 
system operators (TSO) and public stakeholders, such as national governments, national regulators 
and EU institutions. 

▪  To help pave the way for the efforts of EU institutions, a consolidated Action Plan concerning all 
barriers  requiring  the  involvement  of  the  European  Commission  is  included  at  the  end  of  this 
chapter. This is intended to be used as a tool to help the European Commission work towards 
overcoming identified barriers. 

▪  To  prepare  all  other  parties,  including  OWF  developers,  TSOs,  national  ministries  and  NRAs, 
barriers to the five most advantageous hybrid projects are discussed in detail in Chapter 4 of this 
study. 

The detailed findings of interaction with stakeholders regarding the development, assessment and 
selection of project-specific mitigation options is documented in Chapter  5, in the Appendix to this 
study. The documentation is structured around the hybrid project ideas that were examined in detail. 

>Structured interviews with stakeholders and researchers>Evaluation of existing legislation and regulation>Incorporation of materials from existing EU-funded initiatives>Screening of external studies, dissertations and reports>Development of mitigation options based on research>Detailing and refinement of mitigation options>In-depth discussion and evaluation of mitigation options >Selection of mitigation measures to overcome ind.barriersPrimary researchSecondary researchIdentification of barriers to commencement of hybrid project developmentDevelopment, assessment and selection of mitigation optionsConceptualisationStakeholder interactionDevelopment of Action Plans to implement selected mitigation optionsConceptualisationStakeholder interaction>Development of required actions, responsibilities and timelines to implement mitigation measures>Detailed discussion and evaluation of Action Plans, including responsibilities and timelines 
 
 
 
 
22   HYBRID PROJECTS: HOW TO REDUCE COSTS AND SPACE OF OFFSHORE DEVELOPMENTS 

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Figure 11: Overview of identified barriers mapped onto hybrid projects 

Chapters 3.2.1 through 3.2.16 provide a general explanation of the sixteen barriers to hybrid projects. 
The  case  studies  in  Chapters  4.1  through  4.10  present  the  project-specific  evaluation  of  these 
barriers,  the  mitigation  measures  and  the  required  actions  for  the  five  most  advantageous  hybrid 
projects. 

3.2.1  Uncertainty about responsibility for project development 

To develop hybrid projects, the parties responsible for the development and construction as well as 
operation of the relevant cable systems need to form a group to promote the idea. This breaks down 
into two subgroups: responsibility for grid connection and responsibility for the interconnector. Both 
areas are discussed below. 

Responsibility for grid connection refers to the obligation to provide a grid connection for an OWF. 
While an OWF developer  can meet the responsibility, usually  a national TSO31 does. Additionally, 

31 Within the scope of the countries in focus, responsibility for grid connection is organized 
differently in the UK and in Ireland. Under the UK OFTO regime, an OFTO or an OWF developer 
can develop and construct the grid connection (UK Electricity Act 2004. Section 6C (1). 
https://www.legislation.gov.uk/ukpga/2004/20/section/92), but only the OFTO can operate the grid 
connection due to the European unbundling regulation for electricity grids (European Commission. 
2009. DIRECTIVE 2009/72/EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 
concerning common rules for the internal market in electricity. Article 9. https://eur-
lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32009L0072&from=EN). Thus, in the case of 
offshore grid development and construction by the OWF developer (which has so far exclusively 
been the case in the UK), the constructed asset must be transferred to the OFTO at commissioning. 
In Ireland, the OWF developer is responsible for the development of the onshore grid connection. 
While Irish onshore grid connections also underlie the European unbundling regulation for electricity 
grids, there is no process in place for the transfer of the asset at commissioning (SSE Generation 

Relevant barrier for projectNo relevant barrier/relevance uncertain for project1) Part of CEP negotiations, mitigation to be developed based on CEP results (if required)CGS NL to UKIJmuiden Ver to UKDE OWF to NLCOBRA CableNSWPH5. Failure of developers to align planning across assets and countries10. Discrepancies in curtailment regulation and compensation1)16. Uncertainty about legislative regime for power-to-gas and related infrastructure 2. Uncertainty about regulation deriving from jurisdiction over cross-border cable systems14. Uncertainty regarding the UK market6. Uncertainty about responsibility and rules to provide access to maritime space for OWFs (location selection, site pre-investigation, tender execution)4. Uncertainty about hybrid cable system classification9. Discrepancies in priority dispatch regulation1)12. Uncertainty about the applicable RES subsidy scheme8. Discrepancies in responsibilities and requirements for balancing1)11. Lack of regulated revenues for anticipatory investments13. Limited engagement of public stakeholders7. Uncertainty about responsibility and rules to provide access to maritime space for OWFs (tender design)15. Disproportionate allocation of costs and benefits across involved stakeholders1. Uncertainty about responsibility for project development3. Uncertainty about market arrangements 
 
 
                                                      
 
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both the scope  of responsibility for grid connection  and the distribution of connection charges can 
differ: 

▪ 

▪ 

If the OWF developer is responsible for establishing the grid connection of an OWF, the export 
cable  system  needs  to  be  sold  to  a  third  party  before  commissioning.  This  is  due  to  the  EU’s 
unbundling regulation.32 This model is found in the UK (with the OFTO regime) and in Ireland.33 

If a TSO is responsible for developing an OWF's grid connection, the TSO develops, commissions 
and  operates  the  asset.  This  model  is  applied  in  Belgium,  the  Netherlands,  Germany  and 
Denmark.34  

▪  Generators such as OWFs must pay certain charges for a connection to national electricity grids. 

These charges consist of first connection charges and generation charges (G-charges). 

–  First  connection  charges  are  a  one-off  payment,  applied  to  all  generators  and  used  to  fund 
required grid expansions or reinforcements. In the context of OWFs, an export cable system 
can be built in the range between a super shallow and a deep approach. This means there are 
different models for the distribution of first connection charges between power producers and 
power consumers. In the super shallow approach, the costs of all assets required for the grid 
connection  of  the  OWF  (including  the  offshore  transformer  station)  are  socialised  via 
transmission tariffs, so the OWF developer pays no charges. In a shallow approach, the OWF 
developer pays for the entire infrastructure to connect the OWF to the national transmission 
system  (including  offshore  substations,  cables  and  other  necessary  equipment).  In  a  deep 
approach, the OWF developer pays for all costs of the shallow approach plus those for other 
reinforcements and extensions of the existing national transmission system that are necessary 
for  its  grid  connection.  Of  the  countries  in  this  study,  Ireland,  the  UK,  Belgium  and  the 
Netherlands follow a shallow approach, but first connection charges can differ nevertheless. 

Ireland Ltd. 2018. Offshore Wind Energy Revolution 'at Risk'. http://ireland.sse.com/news-and-
views/all-articles/2018/6/offshore-wind-revolution-at-risk/). 

32 European Commission. 2009. DIRECTIVE 2009/72/EC OF THE EUROPEAN PARLIAMENT 
AND OF THE COUNCIL concerning common rules for the internal market in electricity. Article 9. 
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32009L0072&from=EN 

33 UK Electricity Act 2004. Section 6C (1). https://www.legislation.gov.uk/ukpga/2004/20/section/92 
Ofgem. 2013. The Electricity (Competitive Tenders for Offshore Transmission Licenses) 
Regulations 2013. https://www.ofgem.gov.uk/ofgem-publications/51634/letter-electricity-
competitive-tenders-offshore-transmission-licences-regulations-2013-pdf 
Ireland's only operational OWF is Arklow Bank, which is developed as a demonstrator project (SSE 
Generation Ireland Ltd. 2018. Arklow Bank Wind Park. http://ireland.sse.com/what-we-do/our-
projects-and-assets/renewable/arklow-bank-wind-park/). Future Irish OWFs will have to adhere to 
EU unbundling rules. 

34 Dutch Elektriciteitswet 1998. §4 Article 24Aa. https://wetten.overheid.nl/BWBR0009755/2018-07-
28#Hoofdstuk3_Paragraaf4_Artikel24Aa  
German Erneuerbare-Energien-Gesetz 2017 (EEG 2017). § 8. https://www.gesetze-im-
internet.de/eeg_2014/__8.html 
German Energiewirtschaftsgesetz (EnWG). § 17b.  http://www.gesetze-im-
internet.de/enwg_2005/__17b.html 
Danish Bekendtgørelse om nettilslutning af vindmøller og pristillæg for vindmølleproduceret 
elektricitet m.v. Chapter 1 § 2. 
https://www.retsinformation.dk/Forms/R0710.aspx?id=188845#id27a00582-d6fa-44ff-ba6f-
ebb7689685fd 

 
 
                                                      
 
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Germany and Denmark follow a super shallow to (partially) shallow approach. First connection 
charges can still differ, however.35 

–  G-charges are payments for the utilisation of a grid connection by a generator. They finance 
the operation of the cable system. G-charges exist in the form of energy-based charges and 
power-based  charges.  In  the  case  of  energy-based  G-charges,  producers  are  charged  for 
every unit of energy produced (i.e. MWh). This approach exists in Belgium and Denmark. With 
power-based G-charges,  producers pay for each  unit of transmission capacity connected to 
the  generator  (i.e.  MW).  This  approach  exists  in  the  UK  and  Ireland.  The  Netherlands  and 
Germany  do  not  charge  generators  at  all  and  the  costs  are  fully  socialised.  In  addition  to 
different systems across the countries  in focus in this study, the level of G-charges claimed 
from generators differs from country to country36 due to the range of charges and exemptions 
permitted  by  Regulation  (EU)  838/2010.  It  lays  down  guidelines  for  the  inter-transmission 
system  operator  compensation  mechanism  and  a  common  regulatory  approach 
to 
transmission charging.37 

If an OWF is physically connected to at least one foreign market, multiple TSOs (or other export cable 
system developers in Ireland and the UK) may have an interest in assuming responsibility for the grid 
connection. The TSO, or other entity responsible for onshore grid connections in the EEZ in which 
the OWF is located, may be interested for business reasons and / or to ensure  that development, 
construction and operation aligns with the other cable systems in the EEZ. In addition, the TSO or 
other responsible entity in the country where the onshore connection point is located may likewise be 
interested. This would again be for business reasons and / or due to responsibility for the respective 
onshore grid (as in the case of a TSO). On the other hand, OWF developers can prefer responsibility 
in  the  hands  of  one  country  over  responsibility  in  the  hands  of  another  country  based  on  the 
differences in national first connection charge and G-charge regimes. 

How responsibility for grid connection is allocated on legal grounds is unclear in the described setup. 
National law defines who is responsible for grid connection and it can only apply to national territory 
(including the national EEZ). So, it is unclear whether the responsibility can, under national law, be 
assigned to OWFs that are located outside the national territory (including the national EEZ).38 As a 
result,  where an OWF is connected to  another country, the TSO or other responsible  entity in the 
other  country  is  unlikely  to  have  a  clear  mandate  to  provide  the  connection.  Similarly,  no  binding 

35 ENTSO-E. 2018. Overview of transmission tariffs in Europe: Synthesis 2018. 
https://docstore.entsoe.eu/Documents/MC%20documents/TTO_Synthesis_2018.pdf; 
The European Wind Energy Association. 2016. Position paper on network tariffs and grid 
connection regimes. http://www.ewea.org/fileadmin/files/library/publications/position-papers/EWEA-
position-paper-on-harmonised-transmission-tariffs-and-grid-connection-regimes.pdf 

36 ENTSO-E. 2018. Overview of transmission tariffs in Europe: Synthesis 2018. 
https://docstore.entsoe.eu/Documents/MC%20documents/TTO_Synthesis_2018.pdf; 
The European Wind Energy Association. 2016. Position paper on network tariffs and grid 
connection regimes. http://www.ewea.org/fileadmin/files/library/publications/position-papers/EWEA-
position-paper-on-harmonised-transmission-tariffs-and-grid-connection-regimes.pdf 

37 European Commission. 2010. COMMISSION REGULATION (EU) No 838/2010 on laying down 
guidelines relating to the inter-transmission system operator compensation mechanism and a 
common regulatory approach to transmission charging. https://eur-lex.europa.eu/legal-
content/EN/TXT/?qid=1544039239312&uri=CELEX:32010R0838 

38 Müller, Hannah Katharina. 2015. A legal framework for a transnational offshore grid in the North 
Sea (Doctoral dissertation). Groningen: University of Groningen. 

 
 
                                                      
 
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obligations  can  be  placed  on  the  respective  TSO  or  responsible  entity  if  the  connection  does  not 
reach the national onshore grid. 

Responsibility for the interconnector refers to the willingness of TSOs and potential third parties to 
develop and construct, as well as operate, an interconnector. No dedicated entity is responsible for 
the  development  of  interconnectors.  It  is  therefore  of  paramount  importance  to  clarify  who  takes 
responsibility for the interconnector in a hybrid project.  

Different parties can assume responsibility in the development and construction phase, as well as in 
the operation phase. In hybrid projects, it may be feasible to have different players responsible for 
both. 

▪ 

▪ 

In the development and construction phase, there is no limitation on the type of stakeholder who 
could take responsibility for the asset. While interconnectors are typically developed by consortia 
of national TSOs, private developers – as is the case with the NeuConnect interconnector – can 
be responsible as well. 

In the operational phase, the types of stakeholder who can assume responsibility for the asset 
are limited. Due to the European unbundling regulation,39 generation of electricity is separated 
from the operation of transmission networks. Depending on the unbundling model of the Member 
State, generators must either sell off  their transmission network or maintain formal ownership, 
but an independent system operator or a subsidiary must perform operations. 

To allow for hybrid project development that includes an OWF physically connected to at least one 
foreign market, responsibility for both the grid connection and the interconnector needs to be aligned 
between project stakeholders. 

This barrier is relevant for the hybrid projects IJmuiden Ver to UK (Chapter 4.4.3), CGS IJmuiden Ver 
to Norfolk (Chapter 4.5.3), NSWPH (Chapter 4.7.3), COBRA Cable (Chapter 4.8.3) and DE OWF to 
NL (Chapter 4.10.3). Please refer to the indicated chapters for the project-specific evaluation of the 
barrier and barrier mitigation as well as project-specific actions and responsibilities to implement the 
mitigation. 

3.2.2  Uncertainty about regulation deriving from jurisdiction over cross-border 

cable systems 

The United Nations Convention on the Law of the Sea (UNCLOS) specifies the rights and duties of 
states in offshore territory. It aims to strike a balance between assuring the general rights of the high 
seas,  such  as freedom  of navigation40  and  the  freedom  to  lay  cables  and  pipelines,41  and  coastal 
states’ right to exploit their natural resources.42 To achieve this, it defines different maritime zones, 
each with different rights and duties for states. 

39 European Commission. 2009. DIRECTIVE 2009/72/EC OF THE EUROPEAN PARLIAMENT 
AND OF THE COUNCIL concerning common rules for the internal market in electricity. Article 9. 
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32009L0072&from=EN 

40 United Nations. 1982. United Nations Convention on the Law of the Sea. Part III. 
http://www.un.org/Depts/los/convention_agreements/texts/unclos/UNCLOS-TOC.htm 

41 United Nations. 1982. United Nations Convention on the Law of the Sea. Part VI., Article 79. 
http://www.un.org/Depts/los/convention_agreements/texts/unclos/UNCLOS-TOC.htm 

42 Müller, Hannah Katharina. 2015. A legal framework for a transnational offshore grid in the North 
Sea (Doctoral dissertation). Groningen: University of Groningen. 

 
 
                                                      
 
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In the North Sea, the zones "high seas", "territorial sea" and "exclusive economic zone (EEZ)" are 
especially  relevant.  All  states  enjoy  the  freedoms  of  the  high  seas,  which  include  the  freedom  of 
navigation, overflight and laying of submarine cables and pipelines. These freedoms extend across 
all maritime zones. In the territorial sea, which extends up to 12 nautical miles (nm) from shore, the 
coastal  state  enjoys  full  sovereignty  and  full  jurisdiction,  meaning  that  all  national  laws  apply. 43 
However, the coastal state must still observe the rules of international law, which, for example, include 
allowing  for  innocent  passage  (which  does  not  include  the  freedom  to  lay  cables  and  pipelines), 
subject to UNCLOS.44 In the EEZ, which extends up to 200 nm into the sea adjacent to the territorial 
sea,  the  coastal  state  enjoys  exclusive  sovereign  rights,  such  as  the  right  to  explore  and  exploit, 
conserve and manage natural resources, including for the generation of offshore energy.45 Hence, no 
other state may, for example, build an offshore wind farm (OWF) in another state's EEZ without the 
consent of the coastal state. 

Jurisdiction over an OWF is clearly defined based on the location of the OWF in one country's EEZ. 
Since  an  OWF  serves  to  exploit  marine  resources  within  a  country's  EEZ,  the  same  country  has 
jurisdiction over the OWF installation. The same holds true for the conventional export cable system 
(i.e. an export cable system linking the OWF to the market of the country in whose EEZ the OWF is 
located). This is because the cable system is required for the exploitation of the marine resources.46 

However, for cable systems crossing maritime boundaries, such as interconnectors or export cable 
systems  connecting  an  OWF  to  another  country,  several  states  can  demand  regulatory  oversight 
regarding  environmental,  technical  and  operational  standards.  When  jurisdiction  is  concurrent, 
conflicting regulation may be in place due to a "regime of different jurisdictions".47 

▪  Developers of hybrid projects must obtain permits from all countries in whose maritime zones its 
cable system is physically located. Thus, for cable systems crossing multiple EEZs, permits from 
all  coastal  states  are  required  before  construction  begins.  Each  country  can  determine 
environmental  and  technical  standards  by  establishing  the  criteria  for  the  necessary  permits. 
Developers  must  ensure  that  they  remain  compliant  with  all  environmental  and  technical 
standards set out by the coastal states as well as by EU law.  Such procedure is common with 
regular interconnectors as well.48 

▪  During the operational phase, multiple countries may have jurisdiction over cross-border cable 
systems. This means they may claim the right to determine the applicable regulations regarding 
operational standards. This situation is common with regular interconnectors as well.  

43 United Nations. 1982. United Nations Convention on the Law of the Sea. Part II., Article 2, 3. 
http://www.un.org/Depts/los/convention_agreements/texts/unclos/UNCLOS-TOC.htm 

44 United Nations. 1982. United Nations Convention on the Law of the Sea. Part II., Article 17. 
http://www.un.org/Depts/los/convention_agreements/texts/unclos/UNCLOS-TOC.htm 

45 United Nations. 1982. United Nations Convention on the Law of the Sea. Part V., Article 56, 57. 
http://www.un.org/Depts/los/convention_agreements/texts/unclos/UNCLOS-TOC.htm. 

46 Müller, Hannah Katharina. 2015. A legal framework for a transnational offshore grid in the North 
Sea (Doctoral dissertation). Groningen: University of Groningen. 

47 Müller, Hannah Katharina. 2015. A legal framework for a transnational offshore grid in the North 
Sea (Doctoral dissertation). Groningen: University of Groningen, 32. 

48 Interconnector developers usually apply for all relevant permits in all jurisdictions which are 
crossed by the cable. See, for example, the license procedures for the COBRA Cable (TenneT. 
2015. Environmental impact appraisals and planning for interconnectors in the North Sea. 
https://renewables-grid.eu/fileadmin/user_upload/Files_RGI/Event_material/ 
Offshore_expert_workshop/4_RGI_Offshore_Workshop_2015_Spits_TenneT.pdf.  

 
 
                                                      
 
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As such, applicable operational regulations need to be clarified for hybrid projects that cross maritime 
borders if the jurisdiction of multiple countries is concurrent. 

This barrier is relevant for the hybrid projects IJmuiden Ver to UK (Chapter 4.4.3), CGS IJmuiden Ver 
to Norfolk (Chapter 4.5.3), NSWPH (Chapter 4.7.3), COBRA Cable (Chapter 4.8.3) and DE OWF to 
NL (Chapter 4.10.3). Please refer to the indicated chapters for the project-specific evaluation of the 
barrier and barrier mitigation and project-specific actions as well as responsibilities to implement the 
mitigation. 

3.2.3  Uncertainty about market arrangements  

Market arrangements define the conditions for the transmission of electricity from OWFs to shore in 
hybrid setups. In line with EU law and the national law of countries with a coastline on the North Seas, 
the conventional market arrangement is that the OWF commercially and physically feeds into its home 
market,  i.e.  the  grid  of  the  country  in  whose  EEZ  the  OWF  is  located.  In  hybrid  setups,  however, 
OWFs may be physically connected to several markets and / or may not be physically connected to 
their home market. Thus, the direction of commercial electricity flows is unclear.  

In hybrid projects where the OWF is physically connected to several markets, the conventional market 
arrangement  is  either  not  feasible  or  new,  innovative  market  arrangements  can  be  created  to 
capitalise on additional benefits. Commercial OWF flows to multiple markets – for example as backup 
capacity in case of outages in parts of a cable system – are possible if suitable regulatory approaches 
can be found.  Even though such market arrangements are not  in  line  with existing regulation, the 
benefits  may  warrant  consideration.  This  is  especially  true  when  considering  a  potential  future 
meshed-grid approach to support offshore wind development.  

In  this  context,  the  interests  of  the  various  stakeholders  need  to  be  balanced.  For  example, 
interconnector operators and OWFs connected to shore via interconnectors both have an interest in 
avoiding  congestion  on  the  interconnector  to  maximise  capacity  available  for  trade  and  /  or 
transmission to shore. Generally, consumers in connected markets have an interest in low energy 
prices.  

To allow for hybrid project development including an OWF physically connected to at least one foreign 
market, the bidding zone(s) of the OWF needs to be clarified. This defines the market arrangement, 
and thus the market the OWF commercially feeds into. 

This barrier is relevant for the hybrid projects NSWPH (Chapter 4.7.3), COBRA Cable (Chapter 4.8.3) 
and DE OWF to NL (Chapter 4.10.3). Please refer to the indicated chapters for the project-specific 
evaluation  of  the  barrier  and  barrier  mitigation  and  the  project-specific  actions  as  well  as 
responsibilities to implement the mitigation. 

3.2.4 

 Uncertainty about hybrid cable system classification 

Cable systems in hybrid projects can fulfil two functions: the transmission of electricity from an OWF 
to shore; and the transmission of electricity between countries. Such cable systems have a hybrid 
character and therefore do not neatly fit existing legal definitions. As a consequence, either no existing 
legislation  applies  to  them  as  no  legal  definition  exists,  or  multiple  legislation  applies  to  them  as 
multiple definitions apply. This is the case at both the national and European level.  

▪  For example, in the UK, there are no applicable definitions for hybrid cable systems under the UK 
offshore  transmission  owner  (OFTO)  regime.  This  is  based  on  a  licensing  system,  which 
authorises persons to carry out certain activities. A transmission license authorises a person to 
transmit  electricity  but  does  not  permit  market-to-market  flows.  An  interconnector  license 
authorises  a  person  to  participate  in  the  operation  of  market-to-market  electricity  flows.  One 

 
 
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  North Seas Offshore Energy Clusters study 

▪ 

▪ 

▪ 

person  cannot  hold  both  a  transmission  license  and  an  interconnector  license  (or  any  other 
license for that matter).49 Therefore, existing legislation and regulation does not currently cover 
hybrid  projects  that  include  an  asset  that  requires  both  a  transmission  license  and  an 
interconnector license. 

In  the  Netherlands,  it  is  unclear  whether  current  legislation  and  regulation  allows  for  cable 
systems  with  hybrid  functionality.  Under  Dutch  law,  the  Dutch  offshore  grid  comprises  the 
networks intended for the purpose of transporting electricity, and connecting one or more offshore 
wind  farms  to  the  national  high-voltage  grid.50  Interconnectors  are  defined  as  cross-border 
networks that link the networks of two countries.51 It is unclear whether these definitions legally 
prohibit the hybrid functionality of cable systems in hybrid projects. 

It is also unclear if current German legislation and regulation allows for cable systems with hybrid 
functionality. Cables connecting offshore wind farms to the national electricity grid become part 
of  the  grid  on  completion52.  As  such,  they  are  defined  as  connections  between  technical 
installations for the uptake, transmission and distribution of electrical energy for general supply53. 
Interconnectors are defined as cables connecting electricity grids or, alternatively, as connections 
that  cross  the  boundaries  between  two  states  and  are  solely  put  in  place  to  link  the  national 
transmission systems of the two states.54 It is unclear whether these definitions legally prohibit 
the hybrid functionality of cable systems in hybrid projects. 

In Denmark, it is conceivable that the hybrid functionality of cable systems  may be compatible 
with existing legislation and regulation. However, the Danish authorities need to validate such an 
assumption. All power grids at all voltage levels in the territorial sea and in the EEZ of Denmark 
are subject to approval from the Ministry of Energy Supply and Climate Change.55 All transmission 
projects above 100 kV must be approved in accordance with the Executive Order published on 
Energinet.56 Thus, both cable systems connecting OWFs to shore and interconnectors are subject 
to  the  same  regime,  so  the  hybrid  functionality  of  cable  systems  is  unlikely  to  be  legally 
problematic. 

49 UK Electricity Act 1989. Section 6 (1)(b) and (e), (2A). 
https://www.legislation.gov.uk/ukpga/1989/29/contents 

50 Dutch Elektriciteitswet 1998. §1 Article 15a. https://wetten.overheid.nl/BWBR0009755/2018-07-
28#Hoofdstuk3_Paragraaf1_Artikel15a 

51 Dutch Elektriciteitswet 1998. §1 Article 1 (as). https://wetten.overheid.nl/BWBR0009755/2018-07-
28#Hoofdstuk1_Paragraaf1_Artikel1 

52 German Energiewirtschaftsgesetz (EnWG). § 17d (1). http://www.gesetze-im-
internet.de/enwg_2005/__17d.html 

53 German Erneuerbare-Energien-Gesetz 2017 (EEG 2017). § 3 (35). https://www.gesetze-im-
internet.de/eeg_2014/__3.html 

54 German Energiewirtschaftsgesetz (EnWG). § 3 (34). http://www.gesetze-im-
internet.de/enwg_2005/__3.html 

55 Danish Bekendtgørelse af lov om elforsyning. § 22a. 
https://www.retsinformation.dk/Forms/R0710.aspx?id=202155 

56 Danish Bekendtgørelse af lov om Energinet. § 4. 
https://www.retsinformation.dk/Forms/r0710.aspx?id=202154 

 
 
                                                      
 
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▪  EU Directive 2009/72/EC57 does not provide a definition for hybrid cable systems, and narrowly 
defines interconnectors as equipment used to link electricity systems. Similarly, Regulation (EC) 
714/200958 defines interconnectors as a transmission line that crosses or spans a border between 
Member States, and which connects the national transmission systems of the Member States. 
So, any reference to the transport of power generated offshore to shore or generation itself is 
excluded. 

To  allow  for  hybrid  project  development  with  hybrid  cable  systems,  applicable  regulation  on  the 
national and European levels needs to be clarified. 

This barrier is relevant for the hybrid projects IJmuiden Ver to UK (Chapter 4.4.3), CGS IJmuiden Ver 
to Norfolk (Chapter 4.5.3), NSWPH (Chapter 4.7.3) and COBRA Cable (Chapter 4.8.3). Please refer 
to the indicated chapters for the project-specific evaluation of the barrier and barrier mitigation as well 
as project-specific actions and responsibilities to implement the mitigation. 

3.2.5 

Failure of developers to align planning across assets and countries 

Hybrid projects are complex due to the integration of multiple assets in one project across maritime 
boundaries. Planning involves three distinct aspects of complexity: geographical, technical and timing 
alignment.  

▪  Geographical alignment refers to the hybrid-specific alignment of the routing of cable systems 
and the location of the OWFs included in a project. As hybrid projects depend on the productive 
combination of transmission and generation assets, the routing of cable systems and the location 
of generation assets needs to be aligned to maximise cost savings and aide project development. 
However,  the  development  of  OWFs  has  so  far  been  nationally  organised  and  alignment 
procedures retain a strong national focus. The development of interconnectors naturally requires 
cooperation  between  countries  but  has  so  far  been  focused  solely  on  the  development  of 
transmission lines, with no other added functionalities. 

▪  Technical alignment refers to the alignment of the technologies and equipment used to develop 
the individual assets of the hybrid project. As hybrid projects usually consist of several assets, 
control  systems,  communication  equipment  and  other  interfaces  must  function  together. 
Technical  standards  need  to  be  communicated  transparently  and  early  to  enable  suppliers  to 
design  the  necessary  equipment  in  accordance  with  joint  standards  and  thus  ensure 
interoperability. 

▪  Timing alignment refers to the alignment of the development timelines of the individual assets in 
the  hybrid  project. With multiple  assets  involved,  the  development  timelines  for  each  must  be 
aligned  to  prevent  stranded  assets  and  delays  that  could  drive  up  development  costs.  Timing 
alignment is especially relevant in projects with a natural discrepancy in the development start 
date or in the commissioning date of individual assets. For example, if an OWF is connected to 
an interconnector late because of a delay in the tender process, it can cause disruptions to the 
operations of the interconnector and lead to potential revenue losses. This would also probably 
increase the costs of the hybrid project. 

57 European Commission. 2009. DIRECTIVE 2009/72/EC OF THE EUROPEAN PARLIAMENT 
AND OF THE COUNCIL concerning common rules for the internal market in electricity. Article 2 
(13). https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32009L0072&from=EN 

58 European Parliament, European Council. 2009. REGULATION (EC) No. 714/2009 on conditions 
for access to the network for cross-border exchanges in electricity. Article 2 (1). https://eur-
lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32009R0714&from=EN 

 
 
                                                      
 
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In short, the geographical, technical and timing alignment of planning across assets and countries is 
paramount in early development stages to avoid delays, increased costs and / or stranded assets. 
Doing so also encourages the development of hybrid projects. 

This barrier is relevant for the hybrid projects IJmuiden Ver to UK (Chapter 4.4.3), CGS IJmuiden Ver 
to Norfolk (Chapter 4.5.3), NSWPH (Chapter 4.7.3), COBRA Cable (Chapter 4.8.3) and DE OWF to 
NL (Chapter 4.10.3). Please refer to the indicated chapters for the project-specific evaluation of the 
barrier and barrier mitigation as well as project-specific actions and responsibilities to implement the 
mitigation. 

3.2.6  Uncertainty about responsibility and rules to provide access to maritime 

space for OWFs (location selection, site pre-investigation, tender execution) 

Access  to  maritime  space  for  OWFs  is  usually59  granted  through  national  tenders.  These  often60 
involve  central  location  selection  and  site  pre-investigation  as  well  as  the  actual  tender  process 
conducted by national authorities.61 Location selection and site pre-investigation can be conducted 
through a centralised or de-centralised process by national authorities or project developers. These 
processes ultimately lead to the identification of concrete conditions (e.g. water depth, characteristics 
of seabed and currents) at a preferred site, enabling the evaluation of the feasibility and costs of the 
envisioned development. 

The party responsible for the tender executes an OWF tender as defined in the tender design, which 
lists the requirements and processes to ensure close coordination and efficiency (see also Chapter 
3.2.7). OWF developers normally do not have a strong preference for a certain country's authority, 
provided that requirements are transparent and processes efficient. 

▪  Exceptions exist regarding an (additional) open-door approach in Ireland, the UK and Denmark. 
Otherwise,  OWF  location  selection  and  site  pre-investigation  are  conducted  by  the  country  in 
whose EEZ the OWF is physically located.62 However, if an OWF is linked to multiple markets or 
to  a  foreign  market  only,  those  countries  will  also  have  an  interest  in  the  selection  and  pre-

59 Of the countries in focus, Ireland introduced a Renewable Electricity Support Scheme to support 
renewable energy generation through a tender-based process in 2018. The scheme is still to be 
approved by the European Commission but will probably not be sufficient. It is not technology-
specific, and the potential sizes of future individual auctions as outlined today may be too small 
compared to typical OWF capacities. 

60 Within the scope of the countries in focus, in Ireland, the UK and Denmark, an open-door 
approach (additionally) exists, which allows OWF developers to conduct location selection and site 
pre-investigation activities themselves. Developers use the resultant information to apply to the 
respective national authorities for permits relevant for the development of a specific site.  
61 In the UK, the access to maritime space for OWFs is given through auctions instead of tenders. 

62 Regarding the UK, see IEA-RETD. 2017. Comparative Analysis of International Offshore Wind 
Energy Development: REWIND OFFSHORE. http://iea-retd.org/wp-content/uploads/2017/03/IEA-
RETD-REWind-Offshore-report.pdf 

Dutch Wet windenergie op zee. Article 3. https://wetten.overheid.nl/BWBR0036752/2015-07-
01#Hoofdstuk2_Artikel3 

German Energiewirtschaftsgesetz (EnWG). § 12a. http://www.gesetze-im-
internet.de/enwg_2005/__12a.html 

Danish Lov om maritim fysisk planlægning. Chapter 3. 
https://www.retsinformation.dk/Forms/R0710.aspx?id=180281 

 
 
                                                      
 
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investigation of the OWF location. This makes it necessary to define the responsibility for and the 
rules applicable to the OWF location selection and pre-investigation process. 

▪  Except for the cases mentioned above, the party responsible for executing an OWF tender is an 
authority from the country in whose EEZ the OWF is geographically located. However, if an OWF 
is physically connected to at least one foreign market, then these countries have an interest in 
the  tender  process,  too.  This  makes  it  necessary  to  align  responsibility  for  the  OWF  tender 
process to initiate the development.  

To allow for hybrid project development that includes an OWF physically connected to at least one 
foreign market, project stakeholders need to align responsibilities and rules for location selection, site 
pre-investigation and tender execution. 

This  barrier  is  relevant  for  the  hybrid  projects  COBRA  Cable  (Chapter  4.8.3)  and  DE  OWF  to  NL 
(Chapter  4.10.3).  Please  refer  to  the  indicated  chapters  for  the  project-specific  evaluation  of  the 
barrier and barrier mitigation as well as project-specific actions and responsibilities to implement the 
mitigation. 

3.2.7  Uncertainty about responsibility and rules to provide access to maritime 

space for OWFs (tender design) 

Tender design is usually established by the country in whose EEZ the OWF is geographically located. 
The  design  needs  to  balance  the  requirements  set  out  for  prospective  developers  in  light  of  the 
targeted  cost  competition  with  the  probability  of  realisation.63  Where  an  OWF  is  included  in  a 
transnational hybrid project, it also needs to balance the interest of multiple countries. 

▪  While  cost  competition  is  an  important  target,  the  probability  of  realisation  also  needs  to  be  a 

focus for innovative hybrid projects.  

▪ 

If an OWF is physically connected to at least one foreign market, the countries involved will also 
have  an  interest  in  the  design  of  the  tender.  At  present,  there  is  no  commonly  agreed  tender 
design  for  hybrid  project  OWFs  that  would  allow  multiple  countries  to  influence  the  tender 
requirements. These requirements can be broken down into financial and material requirements, 
of  which  the  former  are  easier  to  coordinate  if  needed.  When  it  comes  to  material  tender 
requirements, needs differ. For example, the country in whose EEZ the OWF is located has  a 
strong interest in defining environmental standards, while the country to whose onshore grid the 
OWF is connected has a strong interest in defining technical and operational requirements.  

To allow for hybrid project development that includes an OWF physically connected to at least one 
foreign market, project stakeholders need to align on tender requirements. 

This barrier is relevant for the hybrid projects IJmuiden Ver to UK (Chapter 4.4.3), CGS IJmuiden Ver 
to Norfolk (Chapter 4.5.3), NSWPH (Chapter 4.7.3), COBRA Cable (Chapter 4.8.3) and DE OWF to 
NL (Chapter 4.10.3). Please refer to the indicated chapters for the project-specific evaluation of the 
barrier and barrier mitigation as well as project-specific actions and responsibilities to implement the 
mitigation. 

3.2.8  Discrepancies in responsibilities and requirements for balancing 

Generators  are  assigned  balancing  responsibility  to  ensure  that  the  available  energy  supply  is 
predictable and secure. They must forecast their own production and pay for any imbalances (positive 

63 In the UK, the access to maritime space for OWFs is given through auctions instead of tenders. 

 
 
                                                      
 
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or negative deviations from forecasts). This responsibility can be transferred to a third party or direct 
marketing company. 

The EU’s Clean Energy Package (CEP) suggests that all market participants are responsible for the 
imbalances  they  cause  through  new  installations,  including  renewable  energy  generators  such  as 
offshore  wind  farms.  Exemptions  are  foreseen  only  for  small  generators,  installations  that  already 
receive financial support and demonstration projects. Member States may make derogations until the 
end of 2025 for renewable energy generators of any size. Starting in 2026, however, such derogations 
will only be applicable to generators with an installed capacity of less than 250 kW.64 By 2025, there 
will be  no more relevant discrepancies in  the responsibility and requirements for balancing across 
countries. The exception  is  for imbalance settlement  periods, particularly involving the UK  with  30 
minutes65 compared to the proposed 15 minutes66. 

Once enacted and translated into national law, the new framework needs to be assessed in detail by 
project-specific  stakeholders.  As  the  translation  into  national  law  is  still  outstanding,  no  country-
specific  analysis  is  possible  at  the  time  of  writing.  However,  when  it  comes  to  the  shorter-term 
implementation of the considered hybrid projects, it is likely that no further barrier mitigation of the 
responsibilities and requirements for balancing will be needed. This barrier is therefore not discussed 
for any of the hybrid projects. 

3.2.9  Discrepancies in priority dispatch regulation 

Priority  dispatch  regulation  defines  which  generators  must  be  granted  priority  access  by  the  grid 
operator to dispatch electricity into the grid. It also sets out rules that allow grid operators to impose 
curtailment. 

The CEP67 suggests that priority dispatch will  remain in place for existing installations, small-scale 
renewable installations and demonstration projects. Other installations, irrespective of the technology 
used, will be subject to non-discriminatory third-party access rules. Priority dispatch will no longer be 
in place for new offshore wind farms or other new, large renewable energy generators. Generators 
that have, under previous regulation, enjoyed priority dispatch will continue to do so provided that the 
installation is not subject to significant modifications.68 

Once enacted and translated into national law, the new framework needs to be assessed in detail by 
project-specific  stakeholders.  As  the  translation  into  national  law  is  still  outstanding,  no  country-
specific  analysis  is  possible  at  the  time  of  writing.  However,  when  it  comes  to  the  shorter-term 

64 European Commission. 2018. COM 2016/861 final; REGULATION on the internal market for 
electricity. Article 4. http://ec.europa.eu/transparency/regdoc/rep/1/2016/EN/COM-2016-861-F2-EN-
MAIN-PART-1.PDF 

65 ENTSO-E. 2016. Activation purposes of Balancing Energy Bids – Draft Version 5. 
https://docstore.entsoe.eu/Documents/MC%20documents/balancing_ancillary/160519_Activation_P
urposes.pdf 

66 European Commission. 2018. COM 2016/861 final; REGULATION on the internal market for 
electricity. Article 7. http://ec.europa.eu/transparency/regdoc/rep/1/2016/EN/COM-2016-861-F2-EN-
MAIN-PART-1.PDF 

67 European Commission. 2018. Clean energy for all Europeans. 
https://ec.europa.eu/energy/en/topics/energy-strategy-and-energy-union/clean-energy-all-
europeans 

68 European Commission. 2018. COM 2016/861 final; REGULATION on the internal market for 
electricity. Article 11. http://ec.europa.eu/transparency/regdoc/rep/1/2016/EN/COM-2016-861-F2-
EN-MAIN-PART-1.PDF 

 
 
                                                      
 
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implementation of the considered hybrid projects, it is likely that no further barrier mitigation of priority 
dispatch  regulation  will  be  needed.  This  barrier  is  therefore  not  discussed  for  any  of  the  hybrid 
projects.  

3.2.10  Discrepancies in curtailment regulation and compensation 

Curtailment refers to the involuntary limitation of the maximum possible output of a generator, given 
available  resources.  An  independent  authority  such  as  the  grid  operator  imposes  the  limitation. 
Reasons for curtailment include grid congestion, grid security, necessary controls of the voltage level 
and excess generation during off-peak demand periods. Curtailment can impact the business cases 
of renewable energy generators such as OWFs as the amount of electricity generated falls short of 
the maximum generation  possible  given the same conditions. In addition,  unlike other generators, 
OWFs cannot save any kind of fuel to compensate for the curtailment. 

The CEP69 suggests that curtailment of renewables should be kept to a strict minimum. In other words, 
renewable  energy  sources  will  only  be  curtailed  if  no  alternative  exists,  or  if  the  alternative  would 
result  in  disproportionate  costs  or  affect  the  stability  of  the  grid.  In  addition,  renewable  energy 
generators will be compensated for up to 90% of the net revenues lost (including lost financial support) 
due to curtailment.70  

Once enacted and translated into national law, the new framework needs to be assessed in detail by 
project-specific  stakeholders.  As  the  translation  into  national  law  is  still  outstanding,  no  country-
specific  analysis  is  possible  at  the  time  of  writing.  However,  when  it  comes  to  the  shorter-term 
implementation  of  the  considered  hybrid  projects,  it  is  likely  that  no  further  barrier  mitigation  of 
curtailment regulation and compensation will be needed. This barrier is therefore not discussed for 
any of the hybrid projects. 

3.2.11  Lack of regulated revenues for anticipatory investments 

Anticipatory  investments  are  made  to  future-proof  assets  in  anticipation  of  future  returns. 
Stakeholders  use  them  in  the  present  to  more  simply  and  cost-efficiently  expand  transmission 
infrastructure  or  generation  capacity  in  the  future.  In  contrast  to  regular  investments,  anticipatory 
investments  may  not  generate  an  immediate  return.  For  example,  a  company  might  build  an 
interconnector with a different technical setup or a higher capacity than needed to perform its current 
function to enable the future connection of offshore generation capacity. Another example are export 
cable systems built with a higher capacity than necessary to enable the future connection of additional 
generation  capacity.  Commercial  players  and  TSOs  carry  out  anticipatory  investments  for 
interconnectors. The responsible national TSOs in EU Member States with a North Seas coastline 
undertake such investments in export cable systems as they have responsibility for grid connection. 
The only exceptions are the UK, where the OFTO regime assigns responsibility to OWF developers 
or OFTOs, and Ireland, where OWF developers are responsible. 

Since anticipatory investments inherently carry a greater financial risk than conventional investments, 
both commercial players and TSOs seek to cover such risks with reimbursement guarantees. One 
possibility for reimbursement is to include interconnectors and other cable systems in the regulated 

69 European Commission. 2018. Clean energy for all Europeans. 
https://ec.europa.eu/energy/en/topics/energy-strategy-and-energy-union/clean-energy-all-
europeans 

70 European Commission. 2018. COM 2016/861 final; REGULATION on the internal market for 
electricity. Article 12. http://ec.europa.eu/transparency/regdoc/rep/1/2016/EN/COM-2016-861-F2-
EN-MAIN-PART-1.PDF 

 
 
                                                      
 
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asset  base  (RAB).  Alternatively,  commercial  players  may  seek  compensation  through  subsidy 
schemes for OWFs. Otherwise, the additional costs linked to anticipatory investments remain with the 
commercial  player  or  TSO  –  a  significant  disincentive  to  undertaking  such  investments  in  the  first 
place. At the same time, it is in the interests of society, and thus of regulatory authorities, to prevent 
unnecessary investments. 

▪  For  conventional  cable  systems,  anticipatory  investments  are  usually  included  in  the  national 
regulatory regime. This is due to the fact that in Belgium, the Netherlands, Germany and Denmark 
the  national TSO is responsible for connecting OWFs to shore. National regulation prescribes 
when and how – this is, through which cable corridors – OWFs must be connected to the grid. 
Such planning also includes the construction of cable systems that have a higher capacity than 
immediately needed to connect additional OWFs to them in the future. The only exception is the 
UK, where the OFTO regime assigns responsibility to OWF developers or OFTOs, and Ireland, 
where OWF developers are responsible. 

▪ 

If  developers  incur  a  higher  risk  for  the  development,  construction  and  operation  of  the 
infrastructure, compared to the risks normally incurred by a comparable project, they can apply 
for  the  project  to  become  a  Project  of  Common  Interest  (PCI)  under  the  guidelines  for  trans-
European energy infrastructure (Regulation (EU) 347/2013)71. The regulation allows higher risk 
assets  to  be  included  in  the  RAB  with  appropriate  incentives.  This  includes  anticipatory 
investments  for  export  cables  and  interconnectors.  However,  this  is  not  a  possibility  in  all 
countries and is implemented only and to varying degrees for PCIs. In the UK, the Netherlands 
and Germany, anticipatory investments for PCIs can be included in the RAB of the relevant TSO. 
Indeed, in the Netherlands and in Germany, such investments are treated as regular investments 
and TSOs must apply for cost approval. A benchmarking scheme for assessing the efficiency of 
investments is present in these countries, too72. In Ireland, Belgium and Denmark, it is currently 
unclear whether anticipatory investments for PCIs can be included in the RAB.73  

▪  Generally,  commercial  players  constructing  and  operating  an  interconnector  can  also  obtain 
regulated  revenues  as  reimbursement  for  anticipatory  investments  by  applying  to  national 
regulatory  authorities  for  the  asset’s  inclusion  in  the  regulated  asset  regime.  If  anticipatory 
investments for interconnectors cannot be included in the RAB, commercial players can apply for 
an exemption under Regulation (EC) 714/200974. This allows for an interconnector to become a 
merchant line, thereby covering investments through congestion rents from the transmission of 
electricity between different markets with different electricity prices. The Cap and Floor regime 
offers additional support where links to either the UK or Belgium are envisaged. 

71 European Parliament, European Council. 2013. REGULATION (EU) No. 347/2013 on guidelines 
for trans-European energy infrastructure. https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:32013R0347&from=en 

72 ACER. 2014. Recommendation of the Agency for the cooperation of energy regulators No 
03/2014. 
https://www.acer.europa.eu/Official_documents/Acts_of_the_Agency/Recommendations/ACER%20
Recommendation%2003-2014.pdf 

73 ACER. 2014. Recommendation of the Agency for the cooperation of energy regulators No 
03/2014. 
https://www.acer.europa.eu/Official_documents/Acts_of_the_Agency/Recommendations/ACER%20
Recommendation%2003-2014.pdf 

74 European Parliament, European Council. 2009. REGULATION (EC) No. 714/2009 on conditions 
for access to the network for cross-border exchanges in electricity. Article 17. https://eur-
lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32009R0714&from=EN 

 
 
                                                      
 
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▪  The UK presents a special case for anticipatory investments in export cable systems as these 
are developed under the OFTO regime. Anticipatory investments for offshore infrastructure are 
classified as either "developer-led Wider Network Benefit Investments" (WNBIs) or "Generator-
Focused  Anticipatory  Investments"  (GFAIs).  WNBIs  are  investments  that  provide  a  benefit  to 
multiple  parties,  including  the  demand  and  generation  side  as  well  as  onshore  and  offshore 
parties. GFAIs are investments in offshore infrastructure that allow for the future connection of 
additional offshore assets.75 

It is unclear whether hybrid projects can benefit from anticipatory investments. This is  because EU 
Member States are at different stages in their implementation of the regulation on guidelines for trans-
European energy infrastructure, and because there are different national procedures to assess the 
need for anticipatory investments. 

To allow for hybrid project development, it is necessary to provide certainty about the remuneration 
for anticipatory investments. This helps to clarify the commercial conditions for commercial players 
and TSOs. 

This barrier is relevant for the hybrid projects IJmuiden Ver to UK (Chapter 4.4.3), CGS IJmuiden Ver 
to Norfolk (Chapter 4.5.3) and NSWPH (Chapter 4.7.3). Please refer to the indicated chapters for the 
project-specific evaluation of the barrier and barrier mitigation as well as project-specific actions and 
responsibilities to implement the mitigation. 

3.2.12  Uncertainty about applicable RES subsidy scheme 

RES subsidy schemes guarantee a revenue per unit of produced energy for generators. Their aim is 
to nationally  expand renewable energy production and thereby contribute to the EU target of 32% 
renewables in the energy mix.76 RES subsidy schemes have a strong national focus and the allocation 
of subsidies and the type of subsidy vary between countries. Ireland has no dedicated RES subsidy 
scheme for offshore wind, while the UK operates a Contract for Difference (CfD) subsidy scheme. 
Denmark, the Netherlands and Germany  will (for windfarms built from 2020 onwards; feed-in tariff 
applicable before then) introduce feed-in premiums. Belgium uses a green certificate scheme.77  

▪  Non-existent  RES  subsidy  schemes  for  OWFs:  If  no  subsidy  scheme  for  electricity  generated 
from  offshore  wind  exists,  the  electricity  must  be  sold  at  market  prices.  In  this  situation, 
arrangements such as Power Purchase Agreements (PPAs) may guarantee a bilaterally agreed, 
constant price over the medium-term. 

▪  Feed-in premiums: If a feed-in premium is in place, electricity generated from offshore wind is 
sold at the market price, but the generator receives a premium. The government guarantees the 
premium for a specific period of time. It can be set externally by the government, or in competition 
through a tender procedure. The premium is either constant (for past projects) or sliding, with the 
latter  meaning  that  the  premium  amount  depends  on  market  prices  (i.e.  the  premium  amount 
decreases if market prices exceed a certain strike price and increases if market prices fall below 
a certain strike price). 

75 National Grid. 2015. User Commitment for Generator Focused Anticipatory Investment (GFAI). 
https://www.nationalgrideso.com/sites/eso/files/documents/41074-
Conclusions%20Letter%20on%20GFAI%20User%20Commitment%20April%202015%20v1_0.pdf 

76 European Commission. 2018. Renewable energy: Moving towards a low carbon economy. 
https://ec.europa.eu/energy/en/topics/renewable-energy 

77 pwc. 2018. Unlocking Europe’s offshore wind potential: Moving towards a subsidy free industry. 
https://www.pwc.nl/nl/assets/documents/pwc-unlocking-europes-offshore-wind-potential.pdf 

 
 
                                                      
 
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▪  Feed-in tariffs / Contracts for Difference (CfD): If a feed-in tariff is in place, electricity generated 
from offshore wind is sold at the market price, but the generator receives a fixed price irrespective 
of the market price. The government guarantees this price for a specific period of time. It can be 
fixed at a set level by the government or it can be determined in competition through a tender 
procedure. A CfD works in a similar way. If a CfD is in place, electricity generated from offshore 
wind is sold at the market price and any difference between the market price and an agreed strike 
price is levelled between the generator and the government. If the market price is higher than the 
strike price, the generator pays the difference to the government. If the market price is lower than 
the strike price, the government pays the generator. 

▪  Green certificate schemes: A green certificate scheme involves the issuing of green certificates, 
typically for each 1 MWh of renewable power produced. They are subsequently traded among 
suppliers  and  consumers  separately  from  the  generated  power.  Depending  on  government 
policy,  both  suppliers  and  consumers  may  be  required  to  have  a  minimum  percentage  of 
renewable production in their portfolio. This can be acquired through green certificates, thereby 
generating the needed demand for the certificates. The price of the certificates depends on their 
scarcity on the market. 

From a legal perspective, OWFs are supported through the RES subsidy scheme of the country  in 
whose territorial sea or EEZ the OWF is located. An exception occurs when cooperation mechanisms 
are provided for in national law. For example, in the UK, the CfD scheme only applies to OWFs located 
in the UK territorial sea or the UK EEZ, as laid down  in the  CfD allocation frameworks  of the CfD 
tender rounds so far (2014 and 2017; 2019 in planning).78 In the Netherlands, subsidies can be given 
to OWFs in other Member States. But this is on condition that a cooperation mechanism is agreed, 
the generated electricity is fed into the grid of the other Member State and the electricity prices of the 
other  Member  State  apply.79  In  Germany,  subsidies  can  also  be  given  to  OWFs  in  other  Member 
States. Here, the conditions are that a cooperation mechanism is agreed, the subsidy is allocated by 
means of a joint tender (and tenders of the other Member State are opened  to German renewable 
generators),  the  principle  of  mutuality  is  observed  and  the  generated  energy  is  either  physically 
imported or has a comparable effect on the German market.80 In Denmark, subsidies can only be 
allocated to OWFs located in Danish territorial waters or the Danish EEZ. This is because tenders for 
OWF licenses, which are required to obtain financial support, are only conducted for such areas.81 

78 The allocation frameworks define a CfD Unit as "the whole or part of an Eligible Generating 
Station situated in Great Britain or the territorial waters thereof" with an Offshore CfD Unit being "a 
CfD Unit which generates electricity by the use of wind and which is situated (or is to be situated) 
wholly in offshore waters" (DECC (now BEIS). 2014. CfD: Final Allocation Framework for the 
October 2014 Allocation Round. https://assets.publishing.service.gov.uk/government/ 
uploads/system/uploads/attachment_data/file/404405/Contract_for_Difference_Final_Allocation_Fra
mework_for_the_October_2014_Allocation_Round.pdf) The 2017 framework references the 2014 
framework (BEIS. 2017. CfD: Allocation Framework for the second Allocation Round. 
https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/6
01120/Allocation_Framework_for_the_second_Allocation_Round.pdf. 

79 Dutch Besluit stimulering duurzame energieproductie 2007. §5a Article 55b. 
https://wetten.overheid.nl/BWBR0022735/2017-04-01#Paragraaf5a_Artikel55b  

80 German Erneuerbare-Energien-Gesetz 2017 (EEG 2017). § 5. https://www.gesetze-im-
internet.de/eeg_2014/__5.html 

81 Danish Bekendtgørelse af lov om fremme af vedvarende energi. § 22, § 23 and §37. 
https://www.retsinformation.dk/Forms/R0710.aspx?id=203053  

 
 
                                                      
 
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This conventionally translates into the applicability of the RES subsidy scheme of the country in whose 
EEZ the OWF installation is geographically located.  

But in hybrid projects, OWFs are physically connected to at least one foreign market. This being the 
case,  no  RES  subsidy  scheme  or  the  RES  subsidy  schemes  of  different  countries  could  apply, 
depending  on  the  applicable  national  legislation  and  regulations.  Uncertainty  exists  about  the 
commercial flow conditions for the OWF and public acceptance of support for OWFs, both of which 
hinder project development. 

EU  Directive  2009/28/EC82,  on  the  promotion  of  the  use  of  energy  from  RES,  provides  for 
transnational  cooperation  mechanisms  in  the  form  of  statistical  transfers,  joint  projects  between 
Member States and joint support schemes. These mechanisms may be voluntarily used to implement 
subsidy schemes for transnational (hybrid) projects.  

▪  The subsidy scheme of the OWF’s home market can be accessed by compensating the home 
market country using statistical transfers between the involved countries. The OWF must not be 
physically connected to the bidding zone of the home market because in a statistical transfer the 
required  amount  of  RES  is  deducted  from  one  country's  progress  towards  its  RES  target  and 
added to the other's. This is an accounting procedure and no actual energy changes hands. 

▪  Under the joint project mechanism, each involved party applies its own national subsidy scheme 
to the project, or parts of the project. Thus, two or more countries co-fund a hybrid project and 
share the resulting renewable energy for the purpose of meeting their RES targets. Both statistical 
transfers  and  physical  transmission  of  electricity  between  countries  may  need  to  take  place, 
depending on the distribution of costs and benefits of the project for each country.83  

▪  Lastly, it’s possible to establish a joint support scheme for a hybrid project agreed by all relevant 
parties.  Thus,  two  or  more  countries  fund  a  joint  support  scheme  to  allow  hybrid  project 
development. 

Depending  on  the  hybrid  project  setup,  different  cooperation  mechanisms  and,  hence,  subsidy 
schemes  will  apply.  It’s  therefore  important  to  clarify  the  commercial  flow  conditions  for  OWFs 
included in hybrid projects. 

To  allow  for  hybrid  project  development  of  an  OWF  that  requires  subsidies  and  is  physically 
connected to at least one foreign market, stakeholders need to clarify the applicability of national RES 
subsidy  schemes  relating  to  OWFs  included  in  a  hybrid  project.  The  process  should  include 
consideration of EU Directive 2009/28/EC84. 

This barrier is relevant for the hybrid projects NSWPH (Chapter 4.7.3), COBRA Cable (Chapter 4.8.3) 
and DE OWF to NL (Chapter 4.10.3). Please refer to the indicated chapters for the project-specific 
evaluation of the barrier and barrier mitigation as well as project-specific actions and responsibilities 
to implement the mitigation. 

82 European Parliament, European Council. 2009. DIRECTIVE 2009/28/EC on the promotion of the 
use of energy from renewable sources. Article 6, 7, 9 and 11. https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:32009L0028&from=EN 

83 European Commission. 2013. Guidance on the use of renewable energy cooperation mechanism. 
https://ec.europa.eu/energy/sites/ener/files/documents/com_2013_public_intervention_swd05_en.p
df 
84 Also consider the recast of EU Directive 2009/28/EC, which, at the time of writing, was not yet 
published. 

 
 
                                                      
 
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3.2.13  Limited engagement of public stakeholders  

The  engagement  of  public  stakeholders  is  key  to  the  successful  implementation  of  innovative 
infrastructure projects such as hybrid offshore projects. 

▪  First, public stakeholders can assure project developers of their commitment to a specific hybrid 
project,  including  their  availability  for  dialogue  and  discussion,  in  one  of  two  ways:  a  project-
specific MoU or a project-specific HANSA between all relevant stakeholders. Such agreements 
indicate or formalise commitment from the involved parties– commercial (only in the case of an 
MoU) and public stakeholders.  

▪  Second,  public  stakeholders  can  support  early-stage  hybrid  projects  by  providing  financial 
support  for  feasibility  studies,  pilot  projects  and  research  and  development  for  innovative, 
technological solutions. Such early-stage support is particularly important as these activities are 
usually  financed  via  the  balance  sheet  of  the  project  developers  without  access  to  project 
financing.85  For  example,  the  Connecting  Europe  Facility  (CEF)  and  the  European  Fund  for 
Strategic Investments (EFSI)  both provide financial  support designed to  facilitate cross-border 
energy projects.  

–  CEF provides early-stage and investment support to projects with a PCI status. Additionally, 
for  the  period  2021-2027,  CEF  is  considered  to  specifically  target  cross-border  renewable 
energy projects with a potential budget of at least 10 % of its overall budget of CEF Energy, 
which is expected to be EUR 8.65 billion. This budget would not be subject to projects having 
a PCI status. Funding would cover all renewable energy sources, including offshore wind. To 
implement hybrid projects, the renewed CEF provides financial support for studies and works. 
It also offers technical assistance to set up cooperation agreements between stakeholders for 
pre-feasibility studies, scoping studies, the mapping of potential sites, and the assessment of 
regulatory and financing conditions. CEF supports such activities up to a maximum of 50%86 of 
the costs.87  

–  EFSI is an initiative under the Juncker Plan launched jointly by the European Commission and 
the EIB Group – the European Investment Bank and the European Investment Fund –to help 
bridge the EU’s current investment gap. EFSI consists of a EUR 26 bn guarantee from the EU 
budget, complemented by a EUR 7.5 bn allocation of the EIB's own capital. The total amount 
of EUR 33.5 bn aims to unlock additional investment of at least EUR 500 bn by 2020 by partially 
financing projects (that may also prepare the ground for additional investments). EFSI is aimed 
at projects that have a high risk, including cross-border projects, and that involve sectors of key 
importance  to  the  European  economy.88  Such  projects  include  investments  in  renewable 

85 WindEurope. 2017. Financing and investment trends. https://windeurope.org/wp-
content/uploads/files/about-wind/reports/Financing-and-Investment-Trends-2017.pdf 

86 In exceptional cases, CEF funding could be increased to a maximum of 75 %. 

87 European Commission. 2018. European solidarity on Energy: Better integration of the Iberian 
Peninsula into the EU energy market. http://europa.eu/rapid/press-release_IP-18-4621_en.htm 

European Commission. 2018. Proposal for a Regulation establishing the Connecting Europe 
Facility. https://eur-lex.europa.eu/resource.html?uri=cellar:da5da09e-6a5a-11e8-9483-
01aa75ed71a1.0003.03/DOC_1&format=PDF 

88 European Investment Bank. 2018. What is the European Fund for Strategic Investments (EFSI)? 
http://www.eib.org/en/efsi/what-is-efsi/index.htm 

 
 
                                                      
 
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energy  sources,  energy  efficiency  and  electricity  networks,  including  interconnections.  This 
strengthens energy diversification, security of supply and inter-European cooperation.89 

▪  Third,  public  stakeholders  can  further  incentivise  project  developers  by  providing  financial 
guarantees  to  support  the  de-risking  of  hybrid  projects.  Such  guarantees  reassure  project 
developers about unforeseen situations that may arise as a result of the pilot character of hybrid 
projects. 

To  allow  for  hybrid  project  development,  it  is  highly  beneficial  for  stakeholders  to  formalise  public 
commitment  –  in  a  project-specific  MoU  or  a  project-specific  HANSA,  for  example  –  and  to  make 
public funding support available for early-stage developments or construction.  

This barrier is relevant for the hybrid projects IJmuiden Ver to UK (Chapter 4.4.3), CGS IJmuiden Ver 
to Norfolk (Chapter 4.5.3), NSWPH (Chapter 4.7.3), COBRA Cable (Chapter 4.8.3) and DE OWF to 
NL (Chapter 4.10.3). Please refer to the indicated chapters for the project-specific evaluation of the 
barrier and barrier mitigation as well as project-specific actions and responsibilities to implement the 
mitigation. 

3.2.14  Uncertainty regarding the UK market 

At the time of writing, uncertainty remains with regard to long-term relations between the UK and the 
EU.  The  UK  is  likely  to  leave  the  internal  energy  market,  exposing  it  to  additional  costs  from  de-
coupling its electricity market.  The outcome of the negotiations  regarding the  country’s  withdrawal 
from the EU may have an impact on the following relevant UK policies:  

▪  The Capacity  Market in the UK  was introduced in 2014 to increase the security of  supply and 
incentivise investments in renewable energy sources. The Capacity Market, which is currently on 
hold (see below), pays generators and interconnectors to be available within a time frame of four 
hours in the event of an unexpected shortage in electricity. Annual auctions are held four years 
in advance of the potential time of electricity delivery.90 In the latest auction, for delivery of energy 
in 2021/2022, the interconnectors  that  entered the auction secured contracts  with a combined 
capacity of 2.2 GW. Clearance stood at a record low of 8.40 GBP/kW, edging out new coal and 
gas  generation.91  The  UK  Capacity  Market  provides  an  additional  revenue  stream  for 
interconnector  business  cases,  beyond  revenues  from  congestion  rents.  It  also  incentivises 
interconnector development. The UK was compelled to include interconnectors into the Capacity 
Market due to EU competition rules,92 which are unlikely to apply after the country’s withdrawal 
from the EU. However, on November 15, 2018, the UK Capacity Market was declared illegal by 
the  European  Court  of  Justice  and  has  now  been  put  on  hold,  with  the  next  capacity  auction 
postponed indefinitely.93 While there are currently no changes proposed to the Capacity Market, 

89 European Commission. 2018. Factsheet: Energy sector. 
https://ec.europa.eu/commission/sites/beta-political/files/energy-sector-factsheet-297x210-
july18_en.pdf 

90 Ofgem. 2018. Capacity Market (CM) Rules. https://www.ofgem.gov.uk/electricity/wholesale-
market/market-efficiency-review-and-reform/electricity-market-reform/capacity-market-cm-rules. 

91 Grimwood, Tom. 2018. Interconnectors beat new gas in record-breaking capacity auction. 
https://utilityweek.co.uk/interconnectors-elbow-new-gas-capacity-auction-clears-record-low/. 

92 Flavell, Scott and Alessio Villanacci. 2016. Impact of Brexit on UK energy security: Analysing the 
impact of different Brexit scenarios on the UK energy security of supply. http://energy.sia-
partners.com/sites/default/files/impact_of_brexit_on_uk_energy_security_sia_partners.pdf.pdf. 

93 European Court of Justice. 2018. Judgement of the General Court on State Aid relating to the UK 
Capacity Market. 

 
 
                                                      
 
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notwithstanding  the  ECJ’s  ruling,  it  may  be  necessary  to  re-evaluate  its  status  after  the  UK's 
withdrawal from the EU. 

▪  The UK's Cap and Floor regime incentivises interconnector development to the UK by offering a 
minimum amount of revenue to interconnector developers as a floor (while revenues above the 
cap must be transferred to the grid operator).94 The development of new interconnectors means 
the UK increases its reliance on energy imports. While there are currently no changes proposed 
to  the  Cap  and  Floor  regime,  it  may  be  necessary  to  re-evaluate  its  status  after  the  UK's 
withdrawal from the EU. 

▪  The  EU’s  Connecting  Europe  Facility  supports  cross-border  electricity  projects  of  Common 
Interest (PCIs). It is based on the guidelines for trans-European energy infrastructure (Regulation 
(EU) 347/2013)95 and the Connecting Europe Facility Regulation (Regulation (EU) 1316/2013).96 
PCIs  benefit  from  accelerated  permit  granting  procedures  and  improved  regulatory  treatment, 
and  can  apply  for  financial  support  through  EU  instruments.97  Without  the  UK’s  continued 
participation in the internal energy market, interconnector projects that link to the country may no 
longer qualify for PCI status and the associated advantages. 

To facilitate hybrid project development that includes links to the UK, developers should clarify the 
commercial conditions for interconnector business cases in the  UK market. These are  likely  to be 
affected  by  the  outcome  of  the  negotiations  regarding  the  country’s  withdrawal  from  the  EU. 
Specifically, developers should consider the UK Capacity Market, the Cap and Floor regime and the 
availability of EU support related to the PCI status. 

This barrier is relevant for the hybrid projects IJmuiden Ver to UK (Chapter 4.4.3) and CGS IJmuiden 
Ver to Norfolk (Chapter 4.5.3). Please refer to the indicated chapters for the project-specific evaluation 
of the barrier and barrier mitigation as well as project-specific actions and responsibilities to implement 
the mitigation. 

3.2.15  Disproportionate allocation of costs and benefits across involved 

stakeholders 

Each offshore wind project is associated with a variety of direct and indirect costs and benefits, with 
the costs borne by either the project developer or the respective country.  By way of compensation, 
the project developer and the respective country receive certain benefits from the realisation of the 

http://curia.europa.eu/juris/document/document.jsf?text=&docid=207792&pageIndex=0&doclang=e
n&mode=req&dir=&occ=first&part=1&cid=1430154 

Vaughan, Adam. 2018. UK's backup power subsidies are illegal, European court rules. 
https://www.theguardian.com/environment/2018/nov/15/uk-backup-power-subsidies-illegal-
european-court-capacity-market 

94 Ofgem. 2016. Cap and floor regime: unlocking investment in electricity interconnectors. 
https://www.ofgem.gov.uk/system/files/docs/2016/05/cap_and_floor_brochure.pdf 

95 European Parliament, European Council. 2013. REGULATION (EU) No. 347/2013 on guidelines 
for trans-European energy infrastructure. https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:32013R0347&from=en 
96 European Parliament, European Council. 2013. REGULATION (EU) No. 1316/2013 establishing 
the Connecting Europe Facility. https://eur-lex.europa.eu/legal-
content/EN/TXT/HTML/?uri=CELEX:32013R1316&from=EN 

97 European Commission. 2018. Projects of Common Interest. 
https://ec.europa.eu/energy/en/topics/infrastructure/projects-common-interest 

 
 
                                                      
 
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project. Naturally, the benefits received by one party may represent the costs of another party. The 
types of hybrid project development costs that can be considered include, but are not limited to: 

▪ 

▪ 

▪ 

▪ 

▪ 

▪ 

the grid connection and interconnector costs associated with the hybrid project, including onshore 
grid reinforcement costs; 

the costs associated with pre-investigation and selection of the OWF site; 

the tender process for the OWF included in the hybrid project; 

the RES subsidy scheme in place for the OWF included in the hybrid project; 

the responsibility to pay curtailment compensation to the OWF developer; 

forgone congestion rent, given that an interconnector is part of the hybrid project and is negatively 
impacted by the development of the hybrid project; and 

▪ 

the liability for maintaining the availability of the grid. 

The benefits from the realisation of a hybrid project that can be considered include, but are not limited 
to: 

▪ 

▪ 

▪ 

▪ 

▪ 

the receipt of RES shares from the production of renewable energy / fulfilment of national RES 
targets; 

the phasing out of CO2-emitting generation in the national energy mix; 

the reduction in energy prices from the increased supply of renewable energy; 

the revenues from the additional generation; and 

congestion rents from the exchange of electricity between countries. 

In a hybrid project, at least two different countries are involved. Certain costs are initially allocated to 
one  of  them,  whereas  certain  benefits  might  initially  be  allocated  to  the  other.  In  addition,  hybrid 
project setups can include disincentives for interconnector developers and OWF developers. These 
may  depend  on  the  geographical,  regulatory  and  technical  setup  of  the  project  and  the  mitigation 
measures chosen for the identified barriers. A coordinated reallocation of costs and benefits may be 
necessary after the initial allocation. 

To allow for hybrid project development where stakeholders are disincentivised by the initial allocation 
of costs and benefits, agreement should be sought on the principles for the reallocation of costs and 
benefits. This should be between project developers as well as national regulatory authorities and 
ministries in the respective countries. 

This barrier is relevant for the hybrid projects IJmuiden Ver to UK (Chapter 4.4.3), CGS IJmuiden Ver 
to Norfolk (Chapter 4.5.3), NSWPH (Chapter 4.7.3), COBRA Cable (Chapter 4.8.3) and DE OWF to 
NL (Chapter 4.10.3). Please refer to the indicated chapters for the project-specific evaluation of the 
barrier and barrier mitigation as well as project-specific actions and responsibilities to implement the 
mitigation. 

3.2.16  Uncertainty about legislative regime for power-to-gas and related 

infrastructure  

Power-to-gas  and  related  infrastructure  used  to  integrate  renewable  power  generation  with  other 
sectors  of  the  EU  energy  system  is  a  current  topic  of  research  and  innovation.  The  technology 
converts renewable energy to hydrogen, and in combination with RES, especially in hybrid projects, 
can  provide  additional  flexibility  in  terms  of  transport  and  storage.  However,  power  conversion  to 

 
 
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hydrogen and hydrogen transmission do not yet have a dedicated legislative framework at either the 
national or European level.  

▪  Legislation and regulation for (natural / industrial / chemical) gas infrastructure may be applicable 
to power conversion to hydrogen and hydrogen transmission to some extent. But this does not 
account for the potential importance of hydrogen in the future energy market as shares of RES 
in the energy mix increase.  

▪  Established energy market infrastructure providers, such as electricity and gas TSOs and DSOs, 
depend on an effective legislative framework to incorporate power conversion to hydrogen into 
hybrid projects and their service offerings. 

▪  New  and  /  or  updated  European  legislation  for  power  conversion  to  hydrogen  should  address 
unbundling, non-discriminatory access to infrastructure, market arrangements and the regulation 
of tariffs.  

To  allow  for  hybrid  project  development  that  incorporates  power  conversion  to  hydrogen  and 
hydrogen transmission, new and / or updated legislation targeting the hydrogen sector is necessary. 

This barrier is relevant for the hybrid project NSWPH (Chapter 4.10.3). Please refer to the indicated 
chapters  for  the  project-specific  evaluation  of  the  barrier  and  barrier  mitigation  as  well  as  project-
specific actions and responsibilities to implement the mitigation. 

3.3  Barrier interdependencies 

In alignment with stakeholders, this study identifies existing interdependencies between the sixteen 
barriers discussed above. Although the barriers were analysed individually, interdependencies exist 
between them and must be considered when applying barrier mitigation. This means the selection of 
a given mitigation option for one barrier may preclude the selection of another option for a second 
barrier. Since the mitigation options for the barriers are highly project-specific, the interdependencies 
between the mitigation options are discussed in detail alongside the project-specific Action Plans in 
Chapter  4.  An  evaluation  of  the  project-specific mitigation  options  for  each  project  is  presented  in 
Chapter 5, the Appendix to this study. 

The  following  paragraphs  briefly  outline  the  barrier  interdependencies.  An  overview  of  the 
interdependencies is shown in Figure 12. 

 
 
 
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Figure 12: Overview of barrier interdependencies  

In general, the choice of the most suitable market arrangement is interdependent with the hybrid cable 
system  classification  chosen  for  the  hybrid  project’s  cables,  and  with  the  RES  subsidy  scheme 
applicable  to  the  OWF.  The  hybrid  cable  system  classification  determines  the  functionality  of  the 
cables included in the project. It thereby affects the transmission conditions of the included OWFs – 
and vice versa. The transmission conditions of the OWF in turn affect how and at what level an RES 
subsidy scheme may need to be applied to the OWF – and vice versa. 

As  RES  subsidies  are  usually  awarded  in  national  tender  rounds,  RES  subsidy  schemes  are 
interdependent with access to maritime space. The country granting access to maritime space to the 
OWF is likely to also be the country awarding the subsidy to the OWF. 

Alignment on environmental, technical and operational rules under jurisdiction is interdependent with 
alignment  of  strict  tender  requirements  for  access  to  maritime  space.  Furthermore,  jurisdiction  is 
interdependent with failure to align planning, as obtaining the required permits and aligning regulation 
facilitates continuous dialogue and early-stage alignment among developers.  

In  situations  where  individual  parts  of  a  hybrid  project  are  commissioned  significantly  earlier  than 
others, the hybrid cable system classification can have an impact on the business case of assets that 
are already commissioned. As such, the hybrid cable system classification is interdependent with the 
alignment of planning across assets and countries. 

Responsibility  for  grid  connection  and  /  or  the  development  and  construction  plus  operation  of 
interconnectors  must  be  clearly  assigned  to  allow  for  early-stage  alignment  and  to  facilitate 
continuous dialogue between project developers. Consequently, project development responsibility 
is interdependent with failure to align planning across assets and countries. In addition, the alignment 
of  planning  across  assets  and  countries  is  interdependent  with  access  to  maritime  space.  This  is 
because the geographical, technical  and timing alignment of the OWF included in a hybrid project 
depends  heavily  on  the  permits  and  licenses  granted  to  the  OWF.  Furthermore,  anticipatory 
investments need to be considered early in the planning of a hybrid project, both from a technical and 
timing alignment perspective. Moreover, to assess  a hybrid project’s early-stage feasibility  to align 
geographical,  technical  and  timing  aspects,  close  collaboration  with  national  and  EU  funding 
mechanisms is necessary. It follows that failure to align planning across assets and countries is also 
interdependent with the engagement of public stakeholders. 

Market arrangementRES subsidy schemeHybrid cable system classificationAnticipatory investmentsLimited engagement of public stakeholdersCost / benefit allocationProject development responsibilityInterdependency affecting mitigationInterdependency affecting cost and benefit distributionJurisdictionAccess to maritime spaceFailure to align planning 
 
 
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Lastly,  to  choose  an  appropriate  mitigation  option  for  a  disproportionate  allocation  of  costs  and 
benefits  across  involved  stakeholders,  all  barriers  that  affect  a  hybrid  project’s  costs  and  benefits 
require consideration. Therefore, 

▪ 

▪ 

▪ 

▪ 

the choice of who is responsible for grid connection and interconnectors is interdependent with 
this barrier. This is because it defines which stakeholder carries the costs and reaps the benefits 
of the grid connection and the interconnector in the hybrid setup; 

the choice of market arrangement and the hybrid cable system classification are interdependent 
with this barrier. This is because both significantly impact the costs and benefits derived by OWF 
developers and interconnector developers; 

responsibility and rules to provide access to maritime space for OWFs are interdependent with 
this barrier. This is because location selection, site pre-investigation and tender execution imply 
costs for the country conducting these activities; 

the choice of an RES subsidy scheme is interdependent  with this barrier, as subsidy schemes 
directly impact the costs and benefits derived by the OWF developers; 

▪  anticipatory investments are interdependent with this barrier, as the remuneration for anticipatory 
investments presents developers with benefits, and the countries involved with additional costs; 
and 

▪ 

limited  engagement  of  public  stakeholders  is  interdependent  with  this  barrier.  This  is  because 
both the choice of a formalisation of the commitment to a given hybrid project’s development and 
a given hybrid project’s public financial support present stakeholders with additional costs and 
benefits. 

3.4  Action Plan for the European Commission 

The  project-specific  Action  Plans  cover  all  mitigation  measures  required  to  ensure  the  successful 
implementation  of  a  specific  hybrid  project.  In  addition  to  these,  a  separate  Action  Plan  for  the 
European Commission is provided in Figure 13 below. This outlines actions across the considered 
hybrid projects which necessitate the involvement of the European Commission. It also specifies to 
what extent the European Commission needs to become active to overcome the barriers described 
above. It functions as a tool to work towards overcoming the barriers identified. 

In its capacity as a supranational institution, the European Commission can act as both a supervisor 
and a coordinator to encourage all stakeholders to abide by the proposed timelines. Furthermore, it 
can  provide  guidance  on  the  compliance  of  chosen  mitigation  options  with  European  law,  and,  if 
necessary,  implement  adjustments  to  European  legislation  and  regulation.  Lastly,  through  its 
involvement, the European Commission  can define a  future vision  and  a clear trend for the future 
development of the European energy system. Such an energy system may be characterised by sector 
coupling and the integration of innovative technologies (such as power conversion to gas), all of which 
is likely to pave the way towards a more efficient, integrated European energy system. 

In this regard, he European Commission can engage through the North Seas Energy Cooperation to 
facilitate coordinated collaboration between stakeholders. 

The hybrid project ideas addressed in this study are currently in early development stages, but already 
include tangible assets and have development timelines in place. As such, both the Action Plan for 
the  European  Commission  and  the  project-specific  Action  Plans  foresee  the  formalisation  of 
mitigation measures for the barriers by the end of 2020. This timeline does not directly apply to the 
NSWPH hybrid project.  

 
 
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 Figure 13: Barrier mitigation – Action Plan for the European Commission 

201920202021CGS IJmuiden Ver to NorfolkdevelopmentresponsibilityEU`s third energy package established unbundling of energy suppliers from network operators. Thus, clarify the possibility of an unbundling exemption for VattenfallClarify the need for and extent of bidding zone review processNSWPH, COBRA Cable, DE OWFto NLarrangementAlignmentProjectMarket Validate whether no additional compensation for cable system operators is requiredSupport and supervise involved stakeholdersregarding cable system compensationNSWPHClarify whether a bidding zone review process according to CACM Art. 32 (4) is required and, if so, whether a shortened process might be possibleSupport and supervise involved stakeholdersregarding IC compensationHybrid cableAllocation ofIJmuiden Ver-UK, CGS IJmuiden Ver-Norfolk, NSWPH, COBRA Cable, DE OWF to NLHydrogenIn cooperation with national ministries and the NSWPHconsortium members, identify key focus areas for legislative efforts to prepare for a future legislative frameworkValidate availability of CEF funding to ensure incentivisationEnsure to avoid duplication of work by supporting NSWPH consortium members regarding evaluation of existing findings and researchAlign and agree re-allocation between developers and countriesConsider all costs / benefits deriving from barrier mitigations where EC is involvedto assure an adequate initial allocation of costs and benefitsClarification of role of ECIJmuiden Ver-UK, CGS IJmuiden Ver-Norfolk, NSWPH, COBRA Cable, DE OWF to NLEvaluate existing findings, ongoing legislative efforts and research projects regarding H2and sectorcouplingUnder the premise that hybrid project is a PCI, carry out the evaluation and selection of submitted proposals for CEF funding Support and supervise the reallocation of costs and benefits among developers and countriesEvaluate existing EU regulation on natural / industrial /chemical gas regarding applicability to powerconversion to H2and H2transmissionSupport de-risking ofhybrid project by provi-ding financial guaranteesIJmuiden Ver-UK, CGS IJmuiden Ver-Norfolk, NSWPH, COBRA Cable, DE OWF to NLIJmuiden Ver-UK, CGS IJmuiden Ver-Norfolk, NSWPH, COBRA Cable, DE OWF to NLcosts / benefitsBarrierProvide financial support for feasibility studies, pilot projects as well as R&D to catalyse the development of hybrid projectsIJmuiden Ver-UK, CGS IJmuiden Ver-Norfolk, NSWPH, COBRA Cable, DE OWF to NLEnsure consideration of costs and benefits deriving from other barrier mitigationsRelevant for hybrid projectsIdentify key focus areas for future legislative effortsEvaluate existing regulation on natural gas and industrial / chemical gas regarding applicability to H2NSWPHProvide financial guarantees to reassure stakeholders in situations which can not be foreseen due to the pilot character of the hybrid project NSWPHNSWPHlegislationValidate whether no additional compensation for cable system operators is requiredIJmuiden Ver-UK, CGS IJmuiden Ver-NorfolkAlign and implement the type of formalisation of public commitmentCOBRA CableValidate whether no add. compensation for IC operators is requiredNSWPHIf no exemptions can be granted, provide a EU regulatory framework that allows for successful hybrid project development (e.g. include hybrid definition) in cooperation with the European Parliament and the European Council IJmuiden Ver-UK, CGS IJmuiden Ver-NorfolkTake part in publicly supporting hybrid project through MoU in early project stages. Later, serve as advisor / supervisor for implementing project-specific HANSAengagementPublic Support and supervise involved stakeholdersregarding IC compensationIJmuiden Ver-UK, CGS IJmuiden Ver-Norfolk, NSWPH, COBRA Cable, DE OWF to NLAssess and agree whether additional compensation for IC operators is requiredsystemclassificationApply for project-specific exemptions from European regulationsSupport early-stage alignment among developers through public fundingSupport and supervise involved stakeholdersregarding cable system compensationSupport and supervise involved stakeholdersregarding IC compensationIf required, adjust the regulatory framework on a European level                Assess and agree whether additional compensation for IC operators is requiredCOBRA CableClarify unbundling exemption for VattenfallEvaluate the application of TSOs and decide whether exemptions from EU regulations is grantedIJmuiden Ver-UK, CGS IJmuiden Ver-Norfolk 
 
 
 
 
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4.  Case studies of selected hybrid projects 

Key findings 

▪  The "Project Irish Sea" hybrid project is an adjusted version of an interconnector tie-in concept, 
connecting an Irish OWF to Ireland and the UK via an interconnector.  Implementation of the 
project results in additional lifetime costs of about EUR 33 m compared to implementation of 
the  reference  case.  No  barrier  assessment  was  conducted  for  the  hybrid  project  due  to  the 
absence of lifetime savings. 

▪  The "Nautilus" hybrid project is an interconnector tie-in concept, with a Belgian OWF connected 
to  the  UK  and  Belgium  via  the  Nautilus  interconnector.  Implementation  of  the  hybrid  project 
results in additional lifetime costs of about EUR 1,105 m compared to implementation of the 
reference case. No barrier assessment was conducted for the hybrid project due to the absence 
of lifetime savings.  

▪  The  "UK  OWF  to  BE"  hybrid  project  is  a  neighbour  OWF  concept,  with  a  UK  OWF  radially 
connected to Belgium. Implementation of the hybrid project results in additional lifetime costs 
of about EUR 890 m compared to implementation of the reference case. No barrier assessment 
was conducted for the hybrid project due to the absence of lifetime savings. 

▪  The  "IJmuiden  Ver  to  UK"  hybrid  project  is  an  adjusted  version  of  an  interconnector  tie-in 
concept,  with  a  Dutch  OWF  connected  to  the  Netherlands  via  an  export  cable  system.  An 
interconnector also links the offshore substation of the Dutch export cable system and the UK 
market. If barriers are mitigated, implementation of the hybrid project results in lifetime savings 
of about EUR 400 m compared to implementation of the reference case. Barriers and barrier 
mitigation  measures  were  assessed  in  this  study  and  an  Action  Plan  developed  for  the 
implementation  of  mitigation  measures.  The  hybrid  project  is  worth  considering  and  further 
research by the relevant parties is needed. 

▪  The "CGS IJmuiden Ver to Norfolk" hybrid project is a combined grid solution concept, with an 
interconnector  between  the  offshore  substations  of  the  export  cable  systems  of  a  UK  and  a 
Dutch  OWF.  It  thereby  links  the  UK  and  the  Netherlands.  If  barriers  are  mitigated, 
implementation of the hybrid project results in lifetime savings of about EUR 720 m compared 
to  implementation  of  the  reference  case.  Barriers  and  barrier  mitigation  measures  were 
assessed  in  this  study  and  an  Action  Plan  developed  for  the  implementation  of  mitigation 
measures. The hybrid project is worth considering and further research by the relevant parties 
is needed. 

▪  The  "NeuConnect"  hybrid  project  is  an  interconnector  tie-in  concept,  with  German  OWFs 
connected to the UK and Germany via an interconnector. Implementation of the hybrid project 
results  in  lifetime  savings  of  about  EUR  47  m  compared  to  implementation  of  the  reference 
case.  No  barrier  assessment  was  conducted  for  the  hybrid  project  due  to  the  relatively  low 
lifetime savings. 

▪  The "North Sea Wind Power Hub" (NSWPH) hybrid project is an offshore hub concept, with a 
hub near the Dogger Bank area. It links multiple OWFs in its vicinity to the Dutch, German and 
Western Danish markets. If barriers are mitigated, implementation of the hybrid project results 
in  lifetime  savings  of  about  EUR  2.5  bn  compared  to  implementation  of  the  reference  case. 
Barriers  and  barrier  mitigation  measures  were  assessed  in  this  study  and  an  Action  Plan 
developed  for  the  implementation  of  mitigation  measures.  The  hybrid  project  is  worth 
considering and further research by the relevant parties is needed. 

 
 
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▪  The "COBRA Cable"  hybrid project is an interconnector tie-in concept,  with a German OWF 
connected to the Netherlands and Denmark via the COBRA Cable interconnector.  If barriers 
are mitigated, implementation of the hybrid project results in lifetime savings of about EUR 390 
m compared to implementation of the reference case. Barriers and barrier mitigation measures 
were assessed in this study and an Action Plan developed for the implementation of mitigation 
measures. The hybrid project is worth considering and further research by the relevant parties 
is needed. 

▪  The "CGS DE OWF to NL OWF" hybrid project is a combined grid solution concept, with an 
interconnector between the offshore substations of the export cable systems of a Dutch and a 
German  OWF.  It  thereby  links  the  Netherlands  and  Germany.  Implementation  of  the  hybrid 
project results in additional lifetime costs of about EUR 60 m compared to implementation of 
the  reference  case.  No  barrier  assessment  was  conducted  for  the  hybrid  project  due  to  the 
absence of lifetime savings. 

▪  The "DE OWF to NL" hybrid project is a neighbour OWF concept, with an OWF in a German 
cluster  adjacent  to  the  Dutch  EEZ  connected  to  the  Netherlands.  If  barriers  are  mitigated, 
implementation of the hybrid project results in lifetime savings of about EUR 260 m compared 
to  implementation  of  the  reference  case.  Barriers  and  barrier  mitigation  measures  were 
assessed  in  this  study  and  an  Action  Plan  developed  for  the  implementation  of  mitigation 
measures. The hybrid project is worth considering and further research by the relevant parties 
is needed. 

To  complement  the  study’s  general  findings  about  hybrid  project  development  in  the  North  Seas 
region,  the  following  chapters  use  a  case  study  format  to  summarise  the  detailed,  project-specific 
findings of the ten hybrid project ideas selected for evaluation. In most cases, the project details, the 
cost  assessment,  the  results  of  the  market  modelling  and  the  project-specific  Action  Plan  are 
provided. Market modelling is conducted for seven out of the ten hybrid projects. Action Plans  are 
developed for five out of the ten hybrid projects and are intended to be used as a tool by stakeholders 
once a given hybrid project has been given the go-ahead. 

Before  detailing  the  individual  projects,  it  is  important  to  clarify  a  few  (non-exhaustive)  qualitative 
points about the quantitative findings. These are summarised below: 

▪  To help interpret the quantitative results, it is important to note that electrical equipment which is 
not commercially available was included in the assessment. It is based on a cost multiple, but 
possibly  neglecting  required  research  and  development  costs.  For  example,  disconnector 
modules  for  combining  offshore  infrastructure  were  included.  These  are  currently  being 
researched but no conclusion has yet been reached about them. 

▪  Benefits from the utilisation of available interconnector capacity in times of energy scarcity and / 
or high prices are expected but were not assessed. Such periods often coincide with low RES 
generation (subject to only minor conflicts of interest regarding usage of interconnector capacity 
in hybrid setup between the OWF and interconnector). 

▪  To  make  decisions  regarding  favourable  energy  generation  and  transmission  development 
options, factors other than  direct  project costs are also important for successful hybrid  project 
development.  Such  additional  factors,  for  example  onshore  grid  reinforcement  costs,  must  be 
considered before the beginning of project development but were not considered in this study. 

▪  The impact of offshore developments on municipalities and inhabitants (e.g. through magnetic 
fields, changes in landscapes etc.), must be evaluated but was not considered in this study. This 
is particularly important where significant onshore grid reinforcements are required. 

 
 
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▪ 

In projects where an OWF is connected to several markets, additional advantages would arise in 
the event of a fault or congestion at the onshore end of one part of the cable systems. In such a 
scenario, produced energy could still be transmitted via the other end of the cable system. Thus, 
generation  would  not  have  to  halt  in  the  event  of  a  fault  or  congestion,  depending  on  the 
commercial  and  regulatory  arrangements  allowing  for  such  electricity  flows.  This  additional 
benefit of a hybrid setup was not assessed in this study.  

4.1  Project Irish Sea 

The hybrid project idea "Project Irish Sea" is an adjusted version of an interconnector tie-in concept. 
In the project, an Irish OWF is combined with an interconnector from Ireland to the UK. The onshore 
substations of the OWF are linked to the onshore transformer station of the interconnector in Ireland. 
However, the idea shows no lifetime savings compared to the reference case. It may be that other 
possible benefits from the implementation of the hybrid project compared to the reference case could 
outweigh  the  additional  costs.  But  the  Project  Irish  Sea  hybrid  project  is  given  no  detailed  further 
consideration in the scope of this study as any other potential benefits could not be taken into account 
here. 

4.1.1  Details of the hybrid project and reference case 

The individual assets included in the hybrid project and in the reference case are modelled  on the 
basis  of  real  assets.  But  the  assumed  characteristics  do  not  claim  to  represent  the  actual 
characteristics of the assets included in either ongoing or future developments. 

In the reference case (Figure 14), the conceptualised interconnector is a stand-alone, point-to-point 
interconnector between Ireland and the UK. It is constructed based on HVDC technology with 700 
MW nominal capacity and a length of 155 km. The conceptualised OWF included in the project idea 
is located in the Irish EEZ and has a nominal generation capacity of 800 MW. The conceptualised 
OWF  is  radially  connected  to  two  individual  onshore  connection  points  in  Ireland.  Each  of  the 
connecting cable systems consists of a 35 km 220 kV HVAC cable with a nominal capacity of 400 
MW.  No  intermediate  offshore  transformers  are  required,  as  the  wind  turbines  can  be  connected 
directly to the high-voltage offshore transformer via the 66-kV array cable system. 

In this hybrid project (Figure 14), the conceptualised interconnector is a point-to-point interconnector 
between Ireland and the UK. It is constructed to the same specifications as in the reference case. 
The  conceptualised  OWF  is  located  in  the  Irish  EEZ  and  has  the  same  specifications  as  in  the 
reference case. However, in the hybrid project, the onshore substations of the conceptualised OWF 
are also connected to the onshore transformer station of the interconnector. The two export cable 
systems each have a length of 45 km. This includes the connection between the onshore substations 
of the OWF and onshore transformer station of the interconnector. Booth have a nominal capacity of 
400 MW. 

 
 
 
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Figure 14: Project Irish Sea – Reference case and hybrid project profile 

It is assumed that the development, construction and commissioning of the individual assets (OWF, 
export  cable  system  and  interconnector)  are  not  aligned,  as  interconnector  development  requires 
significantly  more  time.  It  is  also  assumed  that  the  OWF  and  export  cable  system  will  be 
commissioned in 2028. The interconnector is assumed to be commissioned in 2030, both in the hybrid 
project and in the reference case.  

However, if the commissioning of the OWF, export cable system and interconnector can be aligned, 
additional benefits can be realised. In the reference case, the onshore substations of the OWF require 
compensation equipment to feed into the Irish grid. Once onshore connections between the onshore 
substations of the OWF and the onshore transformation station of the interconnector are in place, the 
compensation equipment is no longer required. This is because the interconnector capacity can be 
utilised  for  compensating  the  fluctuation  in  the  electricity  flow  from  the  OWF.  Thus,  compared  to 
asynchronous commissioning, simultaneous commissioning of both the OWF and the interconnector 
would enable savings on the cost of compensation equipment. Asynchronous commissioning requires 
additional  compensation  equipment  until  the  commissioning  and  connection  of  the  OWF  to  the 
interconnector. 

In  general,  this  hybrid  project  idea  and  all  development  areas  and  stakeholders  are  included  as 
examples  only  as  the  assessment  has  been  conducted  without  comprehensive  interaction  with 
specific project stakeholders. 

4.1.2 

Evaluation of hybrid project vs. reference case 

To evaluate the hybrid project against the reference case, this study calculates the lifetime savings 
of the hybrid project. These include the difference in cost and the difference in socio-economic welfare 
(SEW) between the hybrid project and the reference  case. Both the cost assessment – looking at 
CAPEX and OPEX – and the market modelling-based SEW assessment are based on the technical 
setup  of  the  hybrid  project  and  the  reference  case  as  described  in  the  project  details.  Additional 
indicators used in the assessment are energy not served, RES curtailment and CO2 emissions. CO2 
emissions are internalised in the SEW. 

Reference caseHybrid caseDifferenceNominal capacity interconnector [MW]0700700Nominal capacity OWF [MW]0800800Offshore transformer / converter / switching stations01 / 0 / 01 / 0 / 0Length interconnector [km]0155155Length export cable [km]+ 2070 (35 + 35)90 (45 +45)Onshore transformer / converter stations03 / 23 / 2Converter stationTransmission cableTransformerstationReference caseIndicativeIndicativeReference caseGeographical mapping 
 
 
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Assuming  a  typical  asset  lifetime  of  25  years,  the  hybrid  project  yields  additional  lifetime  costs  of 
about EUR 33 m compared to the reference case (Figure 15). The additional lifetime costs are driven 
entirely by an increase in CAPEX and OPEX. OPEX are calculated and discounted over a 25-year 
period.  However,  the  hybrid  project  may  yield  benefits  that  are  not  quantified  in  the  scope  of  this 
study. These benefits include increased RES shares in the Irish market without added fluctuation of 
supply,  improved  transmission  conditions  for  the  OWF  in  the  hybrid  project  and  the  possibility  of 
avoiding onshore congestion. Onshore congestion can be avoided because the hybrid project setup 
provides alternative routing for electricity. This takes place via the offshore connection between the 
two onshore substations of the OWF via the offshore transformer station of the OWF. The SEW is the 
same  for  the  hybrid  project  and  in  the  reference  case.  This  is  because  neither  the  available 
interconnector  capacity  is  reduced,  nor  is  the  OWF  generation  curtailed  in  the  hybrid  project. 
Therefore, the SEW has no effect on the lifetime savings of the hybrid project. 

Figure 15: Project Irish Sea – Assessment results98 

Regarding the cost assessment, the result is driven by the export cable system for which the OWF 
developer  in  Ireland  is  responsible.  The  costs  of  the  export  cable  system  are  higher  in  the  hybrid 
project than in the reference case. Additional kilometres of export cable system are required in the 
hybrid project to connect the onshore substations of the OWF to the onshore transformer station of 
the interconnector. Overall, this results in higher CAPEX and OPEX for the export cable system. 

The results of the market modelling are the same for the hybrid project and the reference case. Energy 
not  served  is  zero  in  both  cases  due  to  the  comprehensive  nature  of,  and  redundancies  in,  the 
European electricity system. Nor is there any difference in curtailment or CO2 emissions, because 
OWF electricity generation and interconnection capacities are not affected by the hybrid project setup. 
As a result, neither setup adversely affects the EU's energy policy target of energy security, nor its 

98 SEW assessment based on Careri, Francesco. [Forthcoming]. The impact of North Sea electricity 
projects in a 2030 scenario: Preliminary assessment of system benefits for the pan-European power 
system through METIS. Petten: European Commission Joint Research Centre. 

1) 8% discount factor      2) Including variation in CO2emissions (0 kt/a), internalised in producer surplus-31-33∆Lifetime savings∆CAPEX0∆Lifetime OPEX (cable systems)1)∆Lifetime SEW1)-20SEW reference project∆SEW2)∆Socio-economic welfare (SEW) (hybrid project -reference case) [EUR m p.a.]x 25 years∆Lifetime savings (hybrid project -reference case) [EUR m] 
 
 
 
                                                      
 
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targets regarding the further establishment of the internal energy market and the decarbonisation of 
the economy. 

4.1.3  Development of an Action Plan to overcome barriers 

Due to the limited advantage of the hybrid project over the reference case, no project-specific barriers, 
barrier mitigation measures or Action Plans were assessed or developed. 

4.2  Nautilus 

The hybrid project idea "Nautilus" is an interconnector tie-in concept. In the project, a Belgian OWF 
is connected to the UK and Belgian market via the Nautilus interconnector. However, the idea shows 
additional lifetime costs compared to the reference case, in which the OWF and interconnector are 
stand-alone assets. Thus, the Nautilus hybrid project is given no detailed further consideration in the 
scope of this study. 

4.2.1  Details of the hybrid project and reference case 

The individual assets included in the hybrid project and in the reference case are modelled  on the 
basis  of  real  assets.  But  the  assumed  characteristics  do  not  claim  to  represent  the  actual 
characteristics of the assets included in either ongoing or future developments. 

In the reference case (Figure 16), Nautilus is a stand-alone, point-to-point interconnector between the 
UK and Belgium. It is constructed based on HVDC technology with 1,400 MW nominal capacity and 
a length of 170 km. The OWF included in the project idea is either Site 1 or Site 2 in the Belgian EEZ 
(still to be tendered), each having a nominal generation capacity of 900 MW. In both cases, the OWF 
is  radially  connected  to  Belgium  with  a  50  km  HVAC  export  cable  system  which  has  a  nominal 
capacity  of  900  MW.  Like  the  Modular  Offshore  Grid  (MOG),  Site  1  and  Site  2  are  likely  to  be 
connected to shore via a Modular Offshore Grid 2 (MOG 2).99 However, as the onshore connection 
concept is still to be defined, a more conservative individual radial connection was assumed in the 
reference  case.  No  intermediate  offshore  transformers  are  required,  as  the  wind  turbines  can  be 
connected directly to the high-voltage offshore transformer via the 66-kV array cable system. 

In  this  hybrid  project  (Figure  16),  Nautilus  is  a  multi-terminal  interconnector  between  the  UK  and 
Belgium. It is constructed mostly to the same specifications as in the reference case. However, the 
length of the interconnector is 210 km due to the rerouting required to allow for the offshore tie-in of 
the  OWF.  The  OWF  (Site  1  or  Site  2  in  the  Belgian  EEZ)  has  the  same  specifications  as  in  the 
reference case. It is connected to the interconnector with a very short HVDC export cable system. 
However, an additional offshore switching station is required to allow for safe connection of the OWF 
and  the  interconnector.  Due  to  the  rerouting  of  the  interconnector,  the  hybrid  project  setup  only 
requires a very short export cable system for the link to the interconnector. The export cable system 
has a nominal capacity of 900 MW. 

For all cable systems, onshore transformer stations are not  in the scope of the  assessment. As a 
result, benefits deriving from the hybrid project compared to the reference case – with fewer onshore 
transformer  stations  in  the  hybrid  project  than  in  the  reference  case  –  have  not  been  considered. 
Furthermore,  onshore  grid  reinforcement  costs  are  not  in  the  scope  of  this  assessment.  But  it  is 
important  that  they  are  considered  before  project  development  would  be  initiated.  The  need  for 

99 The first wave of Belgian OWFs is connected to shore via the MOG in a coordinated manner. 
MOG 2 is under consideration to connect the second wave of Belgian OWFs to shore in a similarly 
coordinated manner. 

 
 
                                                      
 
52   HYBRID PROJECTS: HOW TO REDUCE COSTS AND SPACE OF OFFSHORE DEVELOPMENTS 

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onshore  grid  reinforcements  can  be  expected  to  be  lower  in  the  hybrid  project  compared  to  the 
reference case. This is because the OWF does not translate into the need for an additional onshore 
grid connection point. 

Figure 16: Nautilus – Reference case and hybrid project profile 

It is generally assumed that the development, construction and commissioning of the individual assets 
(OWF,  export  cable  system  and  interconnector)  can  be  aligned  in  the  hybrid  project  to  prevent 
temporarily stranded assets. However, to do so in this case means to delay development of the OWF 
and the export cable system by three years. This assumes commissioning in 2028 together with the 
interconnector, instead of 2025 as announced by the Belgian government.  

4.2.2 

Evaluation of hybrid project vs. reference case 

To evaluate the hybrid project against the reference case, this study calculates the lifetime savings 
of the hybrid project. These include the difference in cost and the difference in socio-economic welfare 
(SEW) between the hybrid project and the  reference  case. Both the cost assessment  – looking at 
CAPEX and OPEX – and the market modelling-based SEW assessment are based on the technical 
setup  of  the  hybrid  project  and  the  reference  case,  as  described  in  the  project  details.  Additional 
indicators used in the assessment are energy not served, RES curtailment and CO2 emissions. CO2 
emissions are internalised in the SEW. 

Assuming a typical asset lifetime of 25 years, the hybrid project yields significant additional lifetime 
costs of about EUR 1,105 m compared to the reference case (Figure 17). The additional lifetime costs 
are driven mostly by an increase of about EUR 1,060 m in CAPEX and OPEX. OPEX are calculated 
and  discounted  over  a  25-year  period.  Additionally,  a  lower  hybrid  project  SEW  of  EUR  4  m  p.a. 
compared to the reference case translates into additional costs of EUR 45 m from lower lifetime SEW, 
discounted over 25 years. The small difference in SEW is spread over the entire European electricity 
system. It is originally driven by the less optimal operational setup of the generation and transmission 
assets  included  in  the  hybrid  project  compared  with  the  reference  case.  This  means  that  either 
available interconnector capacity is reduced or the OWF generation is curtailed, as the two conflict 

Reference caseHybrid caseDifferenceNominal capacity interconnector [MW]1,4001,4000Nominal capacity OWF [MW]9009000Offshore transformer / converter / switching stations1 / 0 / 01 / 1 / 1+ 2Length interconnector [km]170210+ 40Length export cable [km]500-50Onshore transformer / converter stations0 / 20 / 20Geographical mappingReference caseIndicativeIndicativeReference caseConverter stationTransmission cableTransformerstationSwitching station 
 
 
 
53   HYBRID PROJECTS: HOW TO REDUCE COSTS AND SPACE OF OFFSHORE DEVELOPMENTS 

  North Seas Offshore Energy Clusters study 

with  each  other.  The  result  provides  a  robust  basis  for  the  development  of  an  individual  radial 
connection or a MOG 2, as long as both developments are based on HVAC technology. 

Figure 17: Nautilus – Assessment results100 

Regarding the cost assessment, the result is driven by the export cable system of the OWF and the 
interconnector. The cost of the export cable system is higher in the hybrid project than in the reference 
case. Conversely, the elimination of 50 km of export cable, an additionally required offshore switching 
station and offshore converter station in the hybrid project compared to the reference case result in 
higher CAPEX and OPEX for the export cable system. The stations are required to connect the OWF 
to the interconnector. Furthermore, the cost of the interconnector is higher in the hybrid project than 
in the reference case. The interconnector must be rerouted to allow for the offshore tie-in of the OWF 
and retrofitted with multi-terminal technology. These factors result in higher  CAPEX and OPEX for 
the interconnector.  

In both the hybrid project and the reference case, energy not served is zero due to the comprehensive 
nature of and redundancies in the European electricity system. Therefore, neither setup adversely 
affects the EU's energy policy target of energy security. Compared to the reference case, the effect 
of the hybrid project on curtailment and CO2 emissions is very small.101 This suggests that the hybrid 
project is unlikely to have a significant impact on the EU's energy policy targets regarding the further 
establishment of the internal energy market and the decarbonisation of the economy. 

100 SEW assessment based on Careri, Francesco. [Forthcoming]. The impact of North Sea 
electricity projects in a 2030 scenario: Preliminary assessment of system benefits for the pan-
European power system through METIS. Petten: European Commission Joint Research Centre. 

101 The hybrid project generates additional curtailment of 980 MWh/a and additional CO2 emissions 
of 56 kt/a (internalised in socio-economic welfare). For more details, please refer to Careri, 
Francesco. [Forthcoming]. The impact of North Sea electricity projects in a 2030 scenario: 
Preliminary assessment of system benefits for the pan-European power system through METIS. 
Petten: European Commission Joint Research Centre. 

-861-198∆Lifetime savings-45∆Lifetime SEW1)-1,104∆CAPEX∆Lifetime OPEX (cable systems)1)∆SEW2)-4SEW reference project∆Socio-economic welfare (SEW) (hybrid project -reference case) [EUR m p.a.]∆Lifetime savings (hybrid project -reference case) [EUR m]1) 8% discount factor       2) Including variation in CO2emissions (+56 kt/a), internalised in producer surplusx 25 years 
 
 
 
                                                      
 
54   HYBRID PROJECTS: HOW TO REDUCE COSTS AND SPACE OF OFFSHORE DEVELOPMENTS 

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4.2.3  Development of an Action Plan to overcome barriers 

Due  to  the  fact  that  the  hybrid  project  exhibits  no  advantage  over  the  reference  case,  no  project-
specific barriers, barrier mitigation measures or Action Plans were assessed or developed. 

4.3  UK OWF to BE 

The hybrid project idea "UK OWF to BE" is a neighbour OWF concept. In the project, a UK OWF is 
radially  connected  to  the  Belgian  market  only.  However,  the  idea  shows  additional  lifetime  costs 
compared to the reference case, in which the OWF is radially connected to the UK market only. Thus, 
the UK OWF connected to BE hybrid project is given no detailed further consideration in the scope of 
this study. 

4.3.1  Details of the hybrid project and reference case 

The individual assets included in the hybrid project and in the reference case are modelled  on the 
basis  of  real  assets.  But  the  assumed  characteristics  do  not  claim  to  represent  the  actual 
characteristics of the assets included in either ongoing or future developments. 

In the reference case (Figure 18), the OWF conceptually included in the project idea is East Anglia 
One in the UK EEZ. It has a nominal generation capacity of 700 MW. The OWF is radially connected 
to the UK via a 75 km HVAC export cable system, with a nominal capacity of 700 MW. No intermediate 
offshore transformers are required, as the wind turbines can be connected directly to the high-voltage 
offshore transformer via the 66-kV array cable system. 

In this hybrid project (Figure 18), the OWF conceptually included in the project idea is East Anglia 
One in the  UK  EEZ. It  has the same specifications  as in the reference case. The OWF is radially 
connected to Belgium with a 120 km HVDC export cable system, with a nominal capacity of 700 MW. 

For  all  cable  systems,  onshore  transformer  stations  are  not  in  the  scope  of  the  assessment. 
Furthermore,  onshore  grid  reinforcement  costs  are  not  in  the  scope  of  this  assessment.  But  it  is 
important that they are considered before project development would be initiated. 

Figure 18: UK OWF to BE – Reference case and hybrid project profile 

Reference caseHybrid caseDifferenceNominal capacity interconnector [MW]000Length interconnector [km]000Nominal capacity OWF [MW]0700700Offshore transformer / converter / switching stations+ 11 / 0 / 01 / 1 / 0Length export cable [km]+ 4575120Onshore transformer / converter stations+ 10 / 00 / 1Converter stationTransmission cableTransformerstationReference caseIndicativeIndicativeReference caseGeographical mapping 
 
 
 
55   HYBRID PROJECTS: HOW TO REDUCE COSTS AND SPACE OF OFFSHORE DEVELOPMENTS 

  North Seas Offshore Energy Clusters study 

It is generally assumed that the development, construction and commissioning of the individual assets 
(OWF and export cable system) can be aligned in the hybrid project to prevent temporarily stranded 
assets. It is assumed that both assets will be commissioned in 2028, in both the hybrid project and 
the reference case. 

In  general,  this  hybrid  project  idea  and  all  development  areas  and  stakeholders  are  included  as 
examples  only  as  the  assessment  has  been  conducted  without  comprehensive  interaction  with 
specific project stakeholders. 

4.3.2 

Evaluation of hybrid project vs. reference case 

To evaluate the hybrid project against the reference case, this study calculates the lifetime savings 
of the hybrid project. These include the difference in cost between the hybrid project and the reference 
case. The cost assessment – looking at CAPEX and OPEX – is based on the technical setup of the 
hybrid project and the reference case as described in the project details. Market modelling was not 
conducted for this project. 

Assuming  a  typical  asset  lifetime  of  25  years,  the  hybrid  project  yields  additional  lifetime  costs  of 
about EUR 890 m compared to the reference case (Figure 19). The additional lifetime costs are driven 
entirely by an increase in CAPEX and OPEX. OPEX are calculated and discounted over a 25-year 
period. 

Figure 19: UK OWF to BE – Assessment results 

The increase in CAPEX and OPEX is driven by the export cable system of the OWF. The cost of the 
export  cable  system  is  higher  in  the  hybrid  project  than  in  the  reference  case.  The  need  for  an 
additional offshore converter station and onshore converter station, as well as a longer export cable 
system in the hybrid project compared to the reference case, results in higher CAPEX and OPEX for 
the  export  cable  system.  Due  to  the  increased  distance  to  shore,  HVDC  technology  is  required, 
creating the need for converter stations. 

-741-156-897N/A∆Lifetime SEW1)∆CAPEX∆Lifetime OPEX (cable systems)1)∆Lifetime savings∆SEWSEW reference projectN/A∆Socio-economic welfare (SEW) (hybrid project -reference case) [EUR m p.a.]∆Lifetime savings (hybrid project -reference case) [EUR m]1) 8% discount factorx 25 years 
 
 
 
56   HYBRID PROJECTS: HOW TO REDUCE COSTS AND SPACE OF OFFSHORE DEVELOPMENTS 

  North Seas Offshore Energy Clusters study 

4.3.3  Development of an Action Plan to overcome barriers 

Due to the hybrid project showing no advantage over the reference case, no project-specific barriers, 
barrier mitigation measures or Action Plans were assessed or developed. 

4.4 

IJmuiden Ver to UK 

The  hybrid  project  idea  "IJmuiden  Ver  to  UK"  is  an  adjusted  version  of  an  interconnector  tie-in 
concept. In the project, a Dutch OWF in the IJmuiden Ver area is connected to the Netherlands via 
an export cable system. In addition, an interconnector links the offshore substation of the Dutch export 
cable  system  and  the  UK  market.  The  idea  shows  significant  lifetime  savings  compared  to  the 
reference case, in which the OWF and interconnector are stand-alone assets. Thus, the  IJmuiden 
Ver to UK hybrid project is given further consideration in the scope of this study, and an Action Plan 
for the implementation of barrier mitigation measures is developed. The Action Plan is intended to be 
used as a tool by stakeholders once the IJmuiden Ver to UK hybrid project has been given the go-
ahead. 

Both  the  CGS  IJmuiden  Ver  to  Norfolk  hybrid  project  and  the  IJmuiden  Ver  to  UK  hybrid  project 
include  the  IJmuiden  Ver  development  area  and  consequently  have  a  similar  stakeholder  group. 
However, the projects have different technical and commercial setups and are therefore evaluated 
separately. 

4.4.1  Details of the hybrid project and reference case 

The individual assets included in the hybrid project and in the reference case are modelled on the 
basis  of  real  assets.  But  the  assumed  characteristics  do  not  claim  to  represent  the  actual 
characteristics of the assets included in either ongoing or future developments. 

In the reference case (Figure 20), the interconnector is a stand-alone, point-to-point interconnector 
between the UK and the Netherlands. It is constructed based on HVDC technology with 1,300 MW 
nominal  capacity  and  a  length  of  190  km. The  OWF  included  in  the  project  idea  is  located  in  the 
IJmuiden Ver area of the Dutch EEZ and has a nominal generation capacity of 1,300 MW. The OWF 
is radially connected to the Netherlands via an 80 km HVDC export cable system. No intermediate 
offshore transformers are required, as the wind turbines can be connected directly to the high-voltage 
offshore  transformer  via  the  66-kV  array  cable  system.  The  export  cable  system  has  a  nominal 
capacity of 1,300 MW. 

In this hybrid project (Figure 20), the interconnector is a point-to-point interconnector between the UK 
and the offshore substation of the export cable system of the Dutch OWF in the IJmuiden Ver area. 
It is mostly constructed to the same specifications as in the reference case. However, the length of 
the interconnector is reduced to 125 km compared to the reference case. The OWF and its  export 
cable system have the same specifications as in the reference case. 

For all cable systems, onshore transformer stations are not  in the scope of the  assessment. As a 
result, benefits deriving from the hybrid project compared to the reference case – with fewer onshore 
transformer  stations  in  the  hybrid  project  than  in  the  reference  case  –  have  not  been  considered. 
Furthermore,  onshore  grid  reinforcement  costs  are  not  in  the  scope  of  this  assessment.  But  it  is 
important  that  they  are  considered  before  project  development  would  be  initiated.  The  need  for 
onshore  grid  reinforcements  can  be  expected  to  be  lower  in  the  hybrid  project  compared  to  the 
reference case, as the OWF does not translate into the need for an additional onshore grid connection 
point. 

 
 
 
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Figure 20: IJmuiden Ver to UK – Reference case and hybrid project profile 

It is generally assumed that the development, construction and commissioning of the individual assets 
(OWF,  export  cable  system  and  interconnector)  can  be  aligned  in  the  hybrid  project  to  prevent 
temporarily stranded assets. In line with the expected commissioning of the IJmuiden Ver OWF by 
2027, it is assumed that the export cable system and interconnector will be commissioned in 2027. 
However,  the  later  commissioning  of  the  interconnector  would  also  be  possible,  as  the  OWF  and 
export cable system function  independently from the  interconnector. The assumed commissioning 
dates are the same for the hybrid project and reference case. 

4.4.2 

Evaluation of hybrid project vs. reference case 

To evaluate the hybrid project against the reference case, this study calculates the lifetime savings 
of the hybrid project. These include the difference in cost and the difference in socio-economic welfare 
(SEW) between the hybrid project and the reference  case. Both the cost assessment  – looking at 
CAPEX and OPEX – and the market modelling-based SEW assessment are based on the technical 
setup  of  the  hybrid  project  and  the  reference  case  as  described  in  the  project  details.  Additional 
indicators included in the assessment are energy not served, RES curtailment and CO2 emissions. 
CO2 emissions are internalised as cost in the SEW. 

Assuming a typical asset lifetime of 25 years, the hybrid project yields lifetime savings of about EUR 
400  m  compared  to  the  reference  case  (Figure  21).  The  lifetime  savings  are  driven  entirely  by  a 
reduction in CAPEX and OPEX of about EUR 460 m. OPEX are calculated and discounted over a 
25-year period. However, a lower hybrid project SEW of EUR 5 m p.a. compared to the reference 
case translates into additional cost from lower lifetime SEW of EUR 60 m, discounted over 25 years. 
This figure is vastly exceeded by the above-mentioned cost savings, however, so the lifetime savings 
remain positive. The small difference in SEW is spread over the entire European electricity system. 
It is originally driven by the less optimal operational setup of the generation and transmission assets 
included in the hybrid project compared to the reference case. This means that either the available 
interconnector capacity is reduced or the OWF generation is curtailed, as the two conflict with each 
other. 

Reference caseHybrid caseDifferenceNominal capacity interconnector [MW]01,3001,300Nominal capacity OWF [MW]01,3001,300Offshore transformer / converter / switching stations01 / 1 / 0 1 / 1 / 0Length interconnector [km]-65190125Length export cable [km]08080Onshore transformer / converter stations-10 / 30 / 2Converter stationTransmission cableTransformerstationReference caseIndicativeIndicativeReference caseGeographical mapping 
 
 
 
58   HYBRID PROJECTS: HOW TO REDUCE COSTS AND SPACE OF OFFSHORE DEVELOPMENTS 

  North Seas Offshore Energy Clusters study 

Figure 21: IJmuiden Ver to UK – Assessment results102 

Regarding  the  cost  assessment,  the  result  is  driven  by  the  interconnector  only.  The  cost  of  the 
interconnector is lower in the hybrid project than in the reference case. The interconnector requires 
fewer kilometres of cable in the hybrid project and fewer substations. As the interconnector only links 
the UK market to the offshore substation of the Dutch export cable system, and does not extend from 
shore to shore, one onshore converter station and about 65 km of cable are rendered redundant. The 
hybrid  project  requires  the  use  of  disconnector  modules,  but  the  associated  costs  are  negligible 
compared to the cost savings. The cost of the OWF and its export cable system are the same in the 
hybrid and the reference case. 

In both the hybrid project and reference case, energy not served is zero due to the comprehensive 
nature of and redundancies in the European electricity system. Therefore, neither setup adversely 
affects the EU's energy policy target of energy security. Compared to the reference case, the effect 
of the hybrid project on curtailment and CO2 emissions is very small.103 This suggests that the hybrid 
project is unlikely to have a significant impact on the EU's energy policy targets regarding the further 
establishment of the internal energy market and the decarbonisation of the economy. 

4.4.3  Development of an Action Plan to overcome barriers 

This chapter summarises the findings specific to the development of the IJmuiden Ver to UK hybrid 
project. It builds on the general explanation of the barriers in Chapter 3.2, the general explanation of 
the interdependencies between barriers in Chapter 3.3 and the findings of project-specific discussions 
of the barriers and mitigation options in Chapter 5.1. 

102 SEW assessment based on Careri, Francesco. [Forthcoming]. The impact of North Sea 
electricity projects in a 2030 scenario: Preliminary assessment of system benefits for the pan-
European power system through METIS. Petten: European Commission Joint Research Centre. 

103 The hybrid project generates additional curtailment of 1,500 MWh/a and additional CO2 
emissions of 77 kt/a (internalised in socio-economic welfare). For more details, please refer to 
Careri, Francesco. [Forthcoming]. The impact of North Sea electricity projects in a 2030 scenario: 
Preliminary assessment of system benefits for the pan-European power system through METIS. 
Petten: European Commission Joint Research Centre. 

-5740162∆Lifetime savings396∆Lifetime OPEX (cable systems)1)∆CAPEX∆Lifetime SEW1)∆SEW2)SEW reference project-5∆Socio-economic welfare (SEW) (hybrid project -reference case) [EUR m p.a.]∆Lifetime savings (hybrid project -reference case) [EUR m]1) 8% discount factor         2) Including variation in CO2emissions (+77 kt/a), internalisedin producer surplusx 25 years 
 
 
                                                      
 
59   HYBRID PROJECTS: HOW TO REDUCE COSTS AND SPACE OF OFFSHORE DEVELOPMENTS 

  North Seas Offshore Energy Clusters study 

This  study  notes  that  11  of  the  16  identified  barriers  need  to  be  overcome  to  allow  for  the 
commencement of the IJmuiden Ver to UK hybrid project development. The mitigation measures for 
9 of the 11  identified barriers assume that the market arrangement and the RES subsidy scheme 
applicable  to  the  IJmuiden  Ver  to  UK  hybrid  project  will  be  validated  as  follows:  The  market 
arrangement foreseen for the IJmuiden Ver to UK hybrid project is that the Dutch OWF transmits its 
electricity solely to the Dutch market. Therefore, with regard to the hybrid cable system classification, 
only  leftover  capacity  on  the  cable  systems  linking  the  UK  to  the  Dutch  market  is  available  for 
interconnection. In line with the market arrangement, the RES subsidy scheme applicable to the Dutch 
OWF is the Dutch RES subsidy scheme (i.e. the SDE+ subsidy scheme with its regular characteristics 
in  terms  of  type,  level  and  duration  of  support,  as  well  as  the  technology  coverage).  The  market 
arrangement  and  the  RES  subsidy  scheme  as  foreseen  by  the  project  stakeholders  ensure  that 
implementation is highly probable.  

Although  the  barriers  are  addressed  individually,  interdependencies  exist  between  them.  When 
developing ways to mitigate one barrier, it is therefore necessary to also consider the mitigation of 
other  barriers.  Table  1  provides  an  overview  of  the  project-specific  barriers  and  barrier  mitigation 
measures, as well as a brief description of the interdependencies to be considered in the development 
of the individual barrier mitigation measures. 

Barrier 

Mitigation measure 

Interdependencies 

Uncertainty 
about 
responsibility for 
project 
development 

Uncertainty 
about regulation 
deriving from 
jurisdiction over 
cross-border 
cable systems 

Assign responsibility for 
development and construction 
as well as operation of the 
interconnector to a group of 
players which potentially 
includes TenneT TSO B.V. and 
UK interconnector developer 

Obtain all required permits and 
align regulation deriving from 
concurrent jurisdiction over 
cross-border cable systems 

Uncertainty 
about market 
arrangements 

Allow for commercial flows 
from the OWF included in the 
hybrid project to the Dutch 
market only 

▪  Failure of developers to align planning 
across assets and countries: clearly 
assigning responsibility for development, 
construction and operation of interconnector 
facilitates continuous dialogue and early-
stage alignment 

▪  Failure of developers to align planning 

across assets and countries: obtaining all 
required permits and aligning regulation is 
facilitated by continuous dialogue and early-
stage alignment  

▪  Uncertainty about responsibility and rules to 
provide access to maritime space for OWFs 
(tender design): aligned regulation relevant 
for the OWF needs to be reflected in the 
tender design 

▪  Uncertainty about hybrid cable system 

classification: allowing commercial flows only 
from the OWF to the Dutch market implies 
defining the export cable system as export 
cable system with interconnector functionality 

▪  Uncertainty about applicable RES subsidy 
scheme: allowing commercial flows to the 

 
 
 
60   HYBRID PROJECTS: HOW TO REDUCE COSTS AND SPACE OF OFFSHORE DEVELOPMENTS 

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Barrier 

Mitigation measure 

Interdependencies 

Dutch market only fits with the Dutch subsidy 
scheme applying to the OWF 

Uncertainty 
about hybrid 
cable system 
classification 

Define the export cable system 
as an export cable system with 
interconnector functionality, 
which makes it a hybrid cable 
system, if defining the export 
cable system as part of the 
national transmission system is 
not possible 

▪  Uncertainty about market arrangements: 
export cable system with interconnector 
functionality fits the foreseen fixed access of 
OWF to home market 

▪  Uncertainty about applicable RES subsidy 

scheme: export cable system with 
interconnector functionality fits foreseen 
national subsidy scheme applying to the 
OWF 

Failure of 
developers to 
align planning 
across assets 
and countries 

Facilitate continuous dialogue 
and early-stage alignment 
between the project developers 

Uncertainty 
about 
responsibility 
and rules to 
provide access 
to maritime 

Implement a tender design with 
strict requirements, which are 
aligned among the UK and the 
Netherlands and eliminate all 
hybrid-specific uncertainties 

▪  Uncertainty about responsibility for project 

development: continuous dialogue and early-
stage alignment facilitates clear assignment 
of responsibility for development, 
construction and operation of interconnector  

▪  Uncertainty about regulation deriving from 

jurisdiction over cross-border cable systems: 
continuous dialogue and early-stage 
alignment facilitates obtaining all required 
permits and aligning regulation 

▪  Uncertainty about responsibility and rules to 
provide access to maritime space for OWFs 
(tender design): continuous dialogue and 
early-stage alignment are facilitated by an 
aligned tender design 

▪  Lack of regulated revenues for anticipatory 
investments: continuous dialogue and early-
stage alignment among developers is 
facilitated by validating the availability of 
regulated revenues for anticipatory 
investments in the Netherlands 

▪  Limited engagement of public stakeholders: 

continuous dialogue and early-stage 
alignment are facilitated by formalising public 
commitment and public funding for feasibility 
studies, R&D etc. 

▪  Uncertainty about regulation deriving from 

jurisdiction over cross-border cable systems: 
tender design needs to reflect aligned 
regulation relevant for the OWF 

 
 
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Barrier 

Mitigation measure 

Interdependencies 

space for OWFs 
(tender design) 

Lack of 
regulated 
revenues for 
anticipatory 
investments 

Validate the feasibility of 
regulated revenues for 
anticipatory investment under 
the regulatory regimes in the 
Netherlands 

Uncertainty 
about applicable 
RES subsidy 
scheme 

Apply the Dutch RES subsidy 
scheme to the OWF included in 
the hybrid project 

▪  Failure of developers to align planning 

across assets and countries: aligned tender 
design is facilitated by continuous dialogue 
and early-stage alignment 

▪  Uncertainty about applicable RES subsidy 
scheme: tender design in accordance with 
the rules of Dutch authorities fits with 
applying a Dutch RES subsidy scheme  

▪  Failure of developers to align planning 

across assets and countries: certainty about 
regulated revenues for anticipatory 
investments in the Netherlands is facilitated 
by continuous dialogue and early-stage 
alignment 

▪  Uncertainty about market arrangements: the 

business case of the OWF and thereby the 
level of required subsidies are affected by 
allowing for commercial flows to the Dutch 
market only 

▪  Uncertainty about hybrid cable system 

classification: the business case of the OWF 
and thereby the level of required subsidies 
are affected by defining the export cable 
system as export cable system with 
interconnector functionality 

▪  Uncertainty about responsibility and rules to 
provide access to maritime space for OWFs 
(tender design): applying a Dutch RES 
subsidy scheme fits with tender design in 
accordance with the rules of Dutch 
authorities 

Limited 
engagement of 
public 
stakeholders 

Formalise public commitment 
in the form of a project-specific 
MoU or HANSA. Also, facilitate 
feasibility studies and scoping 
studies for early-stage 
alignment through public 
funding, for example 

▪  Failure of developers to align planning 

across assets and countries: formalising 
public commitment and public funding for 
feasibility studies, R&D etc. is facilitated by 
continuous dialogue and early-stage 
alignment  

Uncertainty 
regarding UK 
market 

Await clarification of the future 
of UK policies and intended 
future interaction with the EU's 
internal energy market 

▪  No interdependencies to be considered 

 
 
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Barrier 

Mitigation measure 

Interdependencies 

Disproportionate 
allocation of 
costs and 
benefits across 
involved 
stakeholders 

Reallocate costs and benefits 
deriving from the hybrid project 
where required based on a 
project-specific process 

▪  Uncertainty about responsibility for project 

development (responsibility for 
interconnector): costs and benefits deriving 
from mitigation to be considered 

▪  Uncertainty about market arrangements: 

costs and benefits deriving from mitigation to 
be considered 

▪  Uncertainty about hybrid cable system 

classification: costs and benefits deriving 
from mitigation to be considered 

▪  Lack of regulated revenues for anticipatory 

investments: costs and benefits deriving from 
mitigation to be considered 

▪  Uncertainty about applicable RES subsidy 
scheme: costs and benefits deriving from 
mitigation to be considered 

▪  Limited engagement of public stakeholders: 
costs and benefits deriving from mitigation to 
be considered 

Table 1: IJmuiden Ver to UK – Barriers, barrier mitigation measures and interdependencies 

Combining all the measures needed to mitigate the barriers of relevance to the IJmuiden Ver to UK 
hybrid  project  creates  an  Action  Plan  that  supports  the  commencement  of  the  development.  In 
addition to placing the required actions on a timeline, the Action Plan  also details the stakeholders 
responsible for each of the actions (Figure 22). The Action Plan is intended to be used as a tool by 
stakeholders once the IJmuiden Ver to UK hybrid project has received the go-ahead. 

 
 
 
63   HYBRID PROJECTS: HOW TO REDUCE COSTS AND SPACE OF OFFSHORE DEVELOPMENTS 

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Figure 22: IJmuiden Ver to UK – Action Plan  

The barriers and mitigation measures specific to the IJmuiden Ver to UK hybrid project as well as the 
actions required to implement the identified mitigation measures are explained in more detail in the 
subchapters  below.  As  part  of  the  work  on  barrier  mitigation,  a  project-specific  Memorandum  of 
Understanding (MoU) or a project-specific Hybrid Asset Network Support Agreement (HANSA) were 
considered. Both types of formal commitment to address barriers can include all actions for mitigation 

201920202021National ministriesAssess need for and extent of onshore grid reinforcementsIf required, change national permit proceduresTSOs, national ministriesIf possible, implement a one-stop shop Clarify required permits under UK and Dutch regulationTSOs, national ministries, NRAsJurisdictionEnsure fair allocation of costs andbenefits across stakeholdersNational ministries, NRAsIf NL export cable system not classifiedas transmission system, adjust UK / NL regulations to allow IC definitionBarrierOWF developer, TSOs, national ministries, NRAs, ECDetermine initial allocation of costs / benefitsEnsure consideration of costs and benefits deriving from other barrier mitigationsAllAwait clarification of future of UK capacity market and UK cap and floor regimeUK marketResponsibility1)Validate availability of CEF funding to ensure incentivisationMarketOWF developer, TSOs, national ministries, NRAsIdentify relevant cost / benefit categoriesAlign and agree reallocation between developers and countriesTSOs, national ministries, NRAsAllocation ofbenefitsNational ministries, NRAsEnsure fair allocation of costs andbenefits across stakeholdersTSOs, ECTSOs, NRAs, ECcosts andmaritime spaceTSOs, national ministries, NRAs assets andcountriesNational ministries, ECValidate inclusion of anticipatory investments into Dutch Offshore Grid Development FrameworkEngage in dialogue to achieve early-stage alignment reg. locations, routingand technical specifications of assetsOWF developer, national ministries, NRAsTSOs, national ministries, NRAsPublicRES subsidiesinvestmentsengagementSupport de-risking of hybrid project by providing financial guaranteesSupport early-stage alignment among developers through public fundingTenneT TSO B.V., MoEA, ACM in the NLTSOs, national ministries, NRAs, ECAlign and implement the type of formalisation of public commitmentEnsure fair allocation of costs andbenefits across stakeholdersEnsure fair allocation of costs andbenefits across stakeholdersTenneT TSO B.V., MoEA, ACM in the NLNational ministries, ACM in the NL, other national authoritiesAgree tender design with strict requirementsAccess toAgree tender requirements considering the interests of the UK and the NLValidatefeasibilityofapplyingtheDutchsubsidyschemetotheOWFAnticipatoryNational ministries, ACM in the NL, other national authoritiesTSOs, national ministries, NRAsMoEA, ACM in the NLMoEA, ACM in the NLEnsure fair allocation of costs andbenefits across stakeholdersValidate whether no additional compensation for IC operator is requiredTSOs, NRAsTSOs, national ministries, NRAs, ECEuropean institutionsIf required, adjust the regulatory framework on a European levelIf not possible, define new hybrid asset class and develop new NL regulationDevelop regional capacity calculation and allocation mechanism within framework of CACMTenneT TSO B.V. in the NL, ECPlanning acrossApply for project-specific exemptions from European regulationsValidate compatibility of defining NL export cable system as a national transmission system (in line with EU law) with NL regulationcable systemMoEA, ACM in the NLTSOs, national ministries, NRAsIf required, adjust NL regulation to classify NL export cable system as atransmission system and to allow dual functionalityHybridEnsure fair allocation of costs andbenefits across stakeholdersclassificationIf compatible, validate fit of dual functionality of NL export cable system with NL regulationMoEA, ACM in the NLAlignmentTSOs, national ministriesdevelopmentresponsibilityTSOs, national ministriesProject Define responsibility for operation of ICDefine responsibility for development and construction of ICNational ministriesarrangementAwait clarification of UK's future participation in internal energy marketAlign operational rules across bordersValidatefeasibilityofcommercialflowsfromOWF totheDutchbiddingzoneonlyNational ministries, NRAsTenneT TSO B.V., MoEA, ACM in the NLTSOs1) Responsible stakeholders are OWF developer: tbdin the NL; TSOs: tbdin the UK and TenneT TSO B.V. in the NL; Ministries: BEIS in the UK, MoEA in the NL; NRAs: Ofgem in the UK, ACM in the NL; Other national authorities: Crown Estate in the UK, RVO in the NL; European institutions: European Commission, European Parliament, European Council, European Court of Justice 
 
 
64   HYBRID PROJECTS: HOW TO REDUCE COSTS AND SPACE OF OFFSHORE DEVELOPMENTS 

  North Seas Offshore Energy Clusters study 

measures of relevance to the IJmuiden Ver to UK hybrid project. Thus, it can be sufficient to set up 
only one type. 

Uncertainty about responsibility for project development 

Project-specific barrier evaluation: The definition of responsibility for the interconnector and for the 
grid connections of the OWF will determine who is responsible for the development of the IJmuiden 
Ver to UK hybrid project.  

One party is responsible for the development, construction and operation of the interconnector linking 
the UK market and the offshore substation of the Dutch export cable system. The definition of which 
party is responsible for this is determined neither by European law nor by national law, and therefore 
needs to be aligned between project developers and other stakeholders.  

The  OWF  site  is  in  the  Dutch  EEZ,  where  TenneT  TSO  B.V.  is  generally  responsible  for  the  grid 
connection based on Dutch law.104 This responsibility does not need to be reviewed. Thus, there is 
also no uncertainty regarding the applicability of Dutch first connection charges (shallow approach) 
and Dutch G-charges (no G-charge) for the OWF.105 

Barrier mitigation: The mitigation option identified as most feasible for the interconnector is to define 
a group of players, which potentially includes TenneT TSO B.V. and a UK interconnector developer, 
who would be responsible for development and construction, as well as operation. This is based on 
consideration of the interdependencies shown in Table 1, interaction with project stakeholders (see 
Chapter 5.1.1) and the ease of implementation in terms of the required effort. 

The other mitigation option considered in this study was to designate TenneT TSO B.V. as the party 
responsible for development and construction as well as operation of the interconnector.  

The mitigation option identified as most feasible was selected for the following reason: Both mitigation 
options are covered under existing legislation and regulation. However, the involvement of a potential 
UK interconnector developer has the advantage of providing further expertise about the development, 
construction and operation of a cable system connected to the UK market. This is in addition to the 
expertise  TenneT  TSO  B.V.  has  gained  from  the  development,  construction  and  operation  of  the 
BritNed  interconnector  (operated  together  with  National  Grid  Ventures).  Even  so,  the  selected 
mitigation  option  necessitates  additional  alignment  between  TenneT  TSO  B.V.  and  the  UK 
interconnector developer  to develop and construct the cable system as  well  as  to ensure efficient 
operation of the cable system. 

Irrespective of which mitigation option is selected, this barrier is interdependent with the "failure of 
developers to align planning across assets and countries" barrier. Clearly defining responsibility for 
the  development  and  construction  as  well  as  operation  of  the  interconnector  requires  continuous 
dialogue and early-stage alignment on the hybrid project setup among the defined project promoters. 
Clearly  defined  responsibilities  and  continuous  dialogue  and  alignment,  in  turn,  allow  for  the 
commencement of project development. 

104 Dutch Elektriciteitswet 1998. §4 Article 24Aa. https://wetten.overheid.nl/BWBR0009755/2018-07-
28#Hoofdstuk3_Paragraaf4_Artikel24Aa 

105 ENTSO-E. 2018. Overview of transmission tariffs in Europe: Synthesis 2018. 
https://docstore.entsoe.eu/Documents/MC%20documents/TTO_Synthesis_2018.pdf; 
The European Wind Energy Association. 2016. Position paper on network tariffs and grid 
connection regimes. http://www.ewea.org/fileadmin/files/library/publications/position-papers/EWEA-
position-paper-on-harmonised-transmission-tariffs-and-grid-connection-regimes.pdf 

 
 
                                                      
 
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Actions and responsibilities for mitigation implementation: To implement this mitigation measure for 
the IJmuiden Ver to UK hybrid project, the following actions are required: 

▪  Based on the mitigation option of spreading responsibility for the interconnector over a group of 
players,  define  who  is  responsible  for  development  and  construction  of  the  interconnector. 
Options for the allocation of responsibilities include, for example, making TenneT TSO B.V. and 
a  UK  interconnector  developer  responsible  for  development  and  construction.  With  regard  to 
TenneT TSO  B.V.,  validate  whether  the  offshore  TSO  TenneT TSO  B.V.,  as  a  separate  legal 
entity  from  the  onshore  TSO,  is  responsible.106  This  can  be  achieved  through  voluntary 
cooperation between TenneT TSO B.V. (and a potential UK interconnector developer) as well as 
the national ministries and NRAs (the BEIS and Ofgem in the UK, and the MoEA and ACM in the 
Netherlands). 

▪  Based on the mitigation option of spreading responsibility for the interconnector over a group of 
players, define who is responsible for operation of the interconnector. Options for the allocation 
of  responsibilities  include,  for  example,  making  TenneT  TSO  B.V.  and  a  UK  interconnector 
developer  responsible  for  operation.  This  can  be  achieved  through  voluntary  cooperation 
between TenneT TSO B.V. (and a potential UK interconnector developer), as well as the national 
ministries and NRAs (the BEIS and Ofgem in the UK, and the MoEA and ACM in the Netherlands). 

▪  Assess the need for and extent of onshore grid reinforcements in the UK to allow for the operation 
of  the  interconnector  between  the  UK  market  and  the  offshore  substation  of  the  export  cable 
system of the  IJmuiden Ver OWF. This action can be achieved through voluntary cooperation 
between TenneT TSO B.V. and a National Grid, the UK onshore TSO. 

▪  Ensure compatibility with measures adopted to mitigate the barrier "disproportionate allocation of 
costs and benefits across involved stakeholders". Do this through the fair reallocation among the 
UK  and  the  Netherlands  of  costs  and  benefits  deriving  from  shared  responsibility  for  the 
interconnector.  Certainty  about  the  allocation  of  costs  and  benefits  can  be  achieved  by 
addressing this issue as part of the project-specific HANSA between the UK and the Netherlands. 
TenneT TSO B.V. (and a potential UK interconnector developer) as well as the national ministries 
and NRAs (the BEIS and Ofgem in the UK, and the MoEA and ACM in the Netherlands) assume 
responsibility for this action. 

The  barrier,  its  mitigation  and  the  actions  required  to  implement  the  mitigation  are  summarised  in 
Figure  23.  The  actions  required  to  implement  the  mitigation  measure  and  the  stakeholders 
responsible for the individual actions are summarised across barriers in Figure 22. 

106 In the Netherlands, TenneT TSO B.V. holds the licenses needed to act as both onshore TSO 
and offshore TSO. Clarification is therefore needed whether the interconnector would be developed 
by the offshore or the onshore TSO. Formally, the two are separate grid operators with different 
regulatory frameworks for the different assets. So far, the initiative for interconnection development 
has been with the offshore TSO. 

 
 
 
                                                      
 
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Figure 23: IJmuiden Ver to UK barrier mitigation – Uncertainty about responsibility for project development 

Uncertainty about regulation deriving from jurisdiction over cross-border cable systems 

Project-specific barrier evaluation: The OWF included in the IJmuiden Ver to UK hybrid project idea 
is located in the Dutch EEZ. The OWF serves to exploit marine resources within the Dutch EEZ and 
its onshore connection point is located in the Netherlands (and thereby a cable system between the 
OWF  and  the  onshore  connection  point  does  not  cross  any  maritime  boundary).  As  such,  the 
Netherlands has jurisdiction over the OWF installation and the corresponding export cable system 
belonging to the included OWF. 

The interconnector has its connection points on the UK shore and at the offshore substation of the 
Dutch export cable system. It therefore crosses the UK territorial sea and EEZ as well as the Dutch 
EEZ. Both the UK and the Netherlands have jurisdiction over the cable and can determine applicable 
regulations.  Thus,  jurisdiction  over  the  interconnector  might  be  concurrent  and  the  regulations 
applicable to the interconnector derived from UK and from Dutch jurisdiction might contradict each 
other. 

Barrier mitigation: The mitigation option identified as most feasible is to obtain all required permits 
and to align regulation deriving from concurrent jurisdiction over the  operation  of the cross-border 
cable  system  between 
the 
interdependencies shown in Table 1, interaction with project stakeholders (see Chapter 5.1.2) and 
the ease of implementation in terms of the required effort. 

is  based  on  consideration  of 

involved.  This 

the  countries 

The  other  mitigation  options  besides  aligning  regulation  deriving  from  concurrent  jurisdiction 
considered in this study were (1) to define regulation deriving from UK jurisdiction as applicable to the 
interconnector  during  operation,  and  (2)  to  define  regulation  deriving  from  Dutch  jurisdiction  as 
applicable.  

The mitigation option  identified as most feasible  was selected for the following reasons: While UK 
jurisdiction is applicable to the interconnector across all relevant maritime zones (UK territorial sea, 
UK EEZ and Dutch EEZ), operational rules must also be aligned with Dutch regulation. This is due to 
the connection of a Dutch export cable system to the interconnector. Thus, the selected mitigation 
option of aligning operational rules deriving from concurrent jurisdiction benefits from the redundancy 
of further alignment to allow for the connection of the interconnector to the Dutch export cable system. 
In addition, the selected mitigation option considers the interests of the UK and the Netherlands and 
can  build  on  existing  agreements  established  for  interconnectors  between  the  UK  and  the 
Netherlands,  such  as  BritNed.  Dutch  jurisdiction  is  not  applicable  in  the  relevant  maritime  zones 
crossed by the interconnector. 

Regarding interdependencies, this barrier is interdependent with the "failure of developers to align 
planning  across  assets  and  countries"  and  "uncertainty  about  responsibility  and  rules  to  provide 
access  to  maritime  space  for  OWFs  (tender  design)"  barriers.  Obtaining  all  required  permits  and 
aligning  regulation  is  facilitated  by  continuous  dialogue  and  early-stage  alignment.  Furthermore, 
aligned operational regulation needs to be reflected in the requirements of the OWF tender. 

Uncertainty about responsibility for project development>Assign responsibility for interconnector to group of players>Define responsibility for construction and operation of IC>Assess need for and extent of onshore grid reinforcements>Ensure fair allocation of costs and benefits across stakeholdersBarrierMitigation measureActions 
 
 
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  North Seas Offshore Energy Clusters study 

Actions and responsibilities for mitigation implementation: To implement this mitigation measure for 
the IJmuiden Ver to UK hybrid project, the following actions are required: 

▪  For development and construction, clarify the permits  needed for the interconnector under UK 
and  Dutch  regulations.  Compliance  with  the  environmental  and  technical  rules  under  UK  and 
Dutch  regulations  can  be  ensured  by  obtaining  these  permits.  This  can  be  achieved  through 
voluntary cooperation between TenneT TSO B.V. (and a potential UK interconnector developer) 
and the national ministries (the BEIS, supported by Marine Management Organisation and The 
Crown Estate, in the UK, and the MoEA in the Netherlands).  

▪ 

▪ 

If possible, implement a one-stop shop on national level to allow for a coordinated process with 
only one permit required for the interconnector. As stipulated in Regulation (EU) 347/2013,107 a 
one-stop shop in terms of a competent authority that integrates or coordinates all permit granting 
processes should reduce process complexity, as well as increase efficiency and transparency. 
The  scope  of  a  one-stop  shop  could  be  extended  to  provide  a  consolidated  database  of 
environmental data, facilitating easy data exchange between countries. However, the longer-term 
benefits  are  accompanied  by  significant  shorter-term  setup  costs.  So,  the  feasibility  of 
implementing  this  action  in  the  scope  of  mitigating  barriers  to  the  IJmuiden  Ver  to  UK  hybrid 
project is questionable. Certainty about the implementation can be achieved by addressing this 
issue as part of the project-specific HANSA between the UK and the Netherlands, if feasible. The 
national  ministries  would  assume  responsibility  for  this  action  (the  BEIS,  supported  by  the 
Environment Agency, in the UK, and the MoEA, supported by the Ministry of Infrastructure and 
Water Management, in the Netherlands). 

If required, change the national permit procedures for the specific hybrid project. Guidance from 
project-specific  developers  in  the  form  of  an  inventory  of  environmental  and  technical  rules  is 
required to inform changes to the permit procedures. Certainty about changes can be achieved 
by  addressing  this  issue  as  part  of  the  project-specific  HANSA  between  the  UK  and  the 
Netherlands.  The  national  ministries  would  assume  responsibility  for  this  action  (the  BEIS, 
supported by Marine Management Office and Environment Agency, in the UK, and the MoEA, 
supported by the Ministry of Infrastructure and Water Management, in the Netherlands). 

▪  For  the  operational  phase,  align  the  applicable  national  regulations  arising  from  concurrent 
jurisdiction for the specific hybrid  project. The required  alignment may concern  liability issues, 
control  system  operations  (voltage  levels,  grid  synchronisation  etc.)  and  matters  discussed  in 
relation  to  other  barriers.  Also  consider  existing  national  and  EU  legal  frameworks  such  as 
System  Operations  regulation  (Regulation  (EU)  2017/1485)108  and  the  CACM  regulation 
(Regulation (EU) 2015/1222).109 Guidance from project-specific developers is required to inform 
the alignment. Certainty about the alignment of operational rules can be achieved by addressing 
this  issue  as  part  of  the  project-specific  HANSA  between  the  UK  and  the  Netherlands.  The 

107 European Parliament, European Council. 2013. REGULATION (EU) No. 347/2013 on guidelines 
for trans-European energy infrastructure. (29). https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:32013R0347&from=en 

108 European Commission. 2017. COMMISSION REGULATION (EU) 2017/1485 establishing a 
guideline on electricity transmission system operation. https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:32017R1485&from=DE 

109 European Commission. 2015. COMMISSION REGULATION (EU) 2015/1222 establishing a 
guideline on capacity allocation and congestion management. https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:32015R1222&from=EN 

 
 
                                                      
 
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national ministries and NRAs assume responsibility for this action (the BEIS and Ofgem in the 
UK, and the MoEA and ACM in the Netherlands). 

The  barrier,  its  mitigation  and  the  actions  required  to  implement  the  mitigation  are  summarised  in 
Figure  24.  The  actions  required  to  implement  the  mitigation  measure  and  the  stakeholders 
responsible for the individual actions are summarised across barriers in Figure 22. 

Figure 24: IJmuiden Ver to UK barrier mitigation – Uncertainty about regulation deriving from jurisdiction over 
cross-border cable systems 

Uncertainty about market arrangements 

Project-specific barrier evaluation: Clarification of commercial flows is required as the potential OWF 
site of the IJmuiden Ver to UK hybrid project is located in the Dutch EEZ, whereas the onshore grid 
connection points are in the UK and the Netherlands. Thus, commercial flows to both the UK and the 
Dutch markets are possible, and commercial flows for the OWF included in the hybrid project must 
be clarified. 

Barrier mitigation: The mitigation option identified as most feasible is to allow for commercial flows 
from  the  OWF  included  in  the  hybrid  project  to  the  Dutch  market  only.  Therefore,  only  leftover 
capacities  are  available  for  interconnection  and  the  OWF  can  transmit  its  electricity  to  the  Dutch 
market with priority. This is based on consideration of the interdependencies shown in Table 1 and 
the ease of implementation in terms of the required effort. 

Since this market arrangement was identified as most feasible in interaction with project stakeholders 
from the beginning, no other mitigation options were considered in detail. 

Regarding  interdependencies,  this  barrier  is  interdependent  with  the  barriers  "uncertainty  about 
hybrid cable system classification" and "uncertainty about applicable RES subsidy scheme". Efficient 
commercial flows from the OWF to the Dutch market only imply defining the export cable system as 
an export cable system with interconnector functionality. In addition, such a definition may affect the 
business case of the OWF included in the hybrid project and thereby the level of required subsidies. 

Actions and responsibilities for mitigation implementation: To implement this mitigation measure for 
the IJmuiden Ver to UK hybrid project, the following actions are required: 

▪  Validate the feasibility of defining the market arrangement as commercial flows from the project’s 
OWF  to  the  Dutch  market  only.  This  can  be  achieved  through  voluntary  cooperation  between 
TenneT TSO B.V., the MoEA and ACM in the Netherlands. 

▪  Ensure compatibility with measures adopted to mitigate the barrier "disproportionate allocation of 
costs and benefits across involved stakeholders". Do this through the fair reallocation among the 
UK and the Netherlands of costs and benefits deriving from the market arrangement. Certainty 
about the allocation of costs and benefits can be achieved by addressing this issue as part of the 
project-specific HANSA between the UK and the Netherlands. TSOs, the national ministries and 

Uncertainty about regulation deriving from jurisdiction over cross-border cable systems>Obtain required permits for development and construction of interconnector>Align rules and regulations for operation of interconnector>Clarify required permits>If possible, implement a one-stop shop>If required, change national permit procedures>Align applicable national regulations (operational rules)BarrierMitigation measureActions 
 
 
 
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NRAs  (the  BEIS  and  Ofgem  in  the  UK,  and  TenneT  TSO  B.V.,  the  MoEA  and  ACM  in  the 
Netherlands) assume responsibility for this action. 

The  barrier,  its  mitigation  and  the  actions  required  to  implement  the  mitigation  are  summarised  in 
Figure  25.  The  actions  required  to  implement  the  mitigation  measure  and  the  stakeholders 
responsible for the individual actions are summarised across barriers in Figure 22. 

Figure 25: IJmuiden Ver to UK barrier mitigation – Uncertainty about market arrangements 

Uncertainty about hybrid cable system classification 

Project-specific barrier evaluation: The export cable system included in the IJmuiden Ver to UK hybrid 
project functions as a hybrid cable system, as it serves two distinct and legally differentiated functions. 
According to Regulation (EC) 714/2009,110 an interconnector is defined as "a transmission line which 
crosses or spans a border between Member States and which connects the national transmission 
systems of the Member States." A conventional export cable system provides for the transmission of 
electricity  generated  by  the  OWF  to  an  onshore  connection  point  without  crossing  borders.  In  the 
hybrid setup, the export cable system provides for the transmission of electricity generated by the 
OWF and market-to-market flows. Such dual functionality prevents the straight-forward classification 
of  the  cable  system  under  EU  and  national  legislation  and  regulations  as  either  an  export  cable 
system or an interconnector.  

The interconnector included in the hybrid project, i.e. the cable connection from the UK market to the 
offshore substation of the Dutch export cable system, functions solely as an interconnector. This is 
because  the  Dutch  OWF  transmits  electricity  to  the  Dutch  market  only  (market  arrangement  as 
foreseen by the project developers). However, this definition is based on the following assumption: a 
cable system which does not connect two national transmission systems can still be defined as an 
interconnector  when  one  end  is  connected  to  the  offshore  substation  of  the  Dutch  export  cable 
system. 

Barrier mitigation: The mitigation option identified as most feasible is to define the export cable system 
as an export cable system with interconnector functionality. This effectively makes the setup a hybrid 
cable system. The transmission of power generated by the OWF has priority regarding access to the 
cable system capacity and only leftover capacity is available for interconnection.  This is based on 
consideration of the interdependencies shown in Table 1, interaction with project stakeholders (see 
Chapter 5.1.4) and the ease of implementation in terms of the required effort. 

The other mitigation option considered in this study was to define the Dutch export cable system as 
an interconnector with export cable functionality for leftover capacities.  

110 European Parliament, European Council. 2009. REGULATION (EC) No. 714/2009 on conditions 
for access to the network for cross-border exchanges in electricity. Article 2 (1). https://eur-
lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32009R0714&from=EN 

Uncertainty about market arrangements>Establish commercial flows from OWF to Dutch bidding zone only>Validate feasibility of commercial flows from OWF to the Dutch bidding zone only>Ensure fair allocation of costs and benefits across stakeholdersBarrierMitigation measureActions 
 
 
 
                                                      
 
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The  mitigation  option  identified  as  most  feasible  was  selected  for  the  following  reasons:  For  both 
mitigation  options,  it  is  questionable  whether  they  are  covered  under  Dutch  regulation.  This  is 
because Dutch regulation does not expressly prohibit the dual functionality of a cable system. From 
a European perspective, however, hybrid cable systems are not covered by existing regulations, and 
exemptions or, if necessary, adjustments are required for both options. Thus, the mitigation option 
was selected due to its interdependencies with other barriers, as explained below.  

Regarding interdependencies, defining the Dutch export cable system as an export cable system with 
interconnector functionality for leftover capacities fits the  envisaged market arrangement and RES 
subsidy scheme. This is because it gives the Dutch OWF priority access to the capacity of the Dutch 
export cable system for the transmission of generated electricity to the Dutch market. As a result, the 
chosen classification of the export cable system has no impact on the business case of the OWF in 
the hybrid project. But it does impact the business case of the interconnector when compared to a 
conventional  point-to-point  interconnector.  Therefore,  the  requirement  for  additional  compensation 
for the interconnector operator needs to be assessed. In addition, the European energy policy targets 
of  diversifying  and  integrating  RES  as  well  as  reducing  greenhouse  gas  emissions  are  prioritised 
when defining the Dutch export cable system as an export cable system  whose leftover capacities 
are available for interconnection. 

Actions and responsibilities for mitigation implementation: To implement this mitigation measure for 
the IJmuiden Ver to UK hybrid project, the following actions are required: 

▪  Validate whether defining the Dutch export cable system as a national transmission system – in 
line with the definition in EU legislation and regulations – complies with Dutch regulations.111 This 
is required to allow the cable system between the UK market and the offshore substation of the 
export cable system of the Dutch OWF to be defined as an interconnector within the meaning of 
EU  regulations.  In  addition,  validate  that  an  export  cable  system  defined  as  a  national 
transmission  system  is  legally  allowed,  under  Dutch  regulations,  to  provide  for  both  the 
transmission  of  electricity  from  the  Dutch  OWF  to  shore  and  for  interconnection  flows.  Lastly, 
assess whether TenneT TSO B.V., as an offshore grid operator, should be allowed to develop 
interconnection capacity (due to the leftover capacity on the export cable system being available 
for interconnection) for which it currently needs an explicit mandate from the MoEA. This can be 
achieved through voluntary cooperation between the MoEA and ACM in the Netherlands, initiated 
by TenneT TSO B.V. 

▪ 

If required, preferably adjust Dutch regulations for the specific hybrid project to classify the export 
cable  system  as  a  national  transmission  system.  This  should  allow  both  the  transmission  of 
electricity from the OWF and interconnection flows. If this is not possible, allow the same dual 
functionality by defining a new hybrid asset class and developing new regulation for that asset 
class. Guidance from project-specific developers is required to inform the adjustment of Dutch 
regulation.  Certainty  about  changes  can  be  achieved  by  addressing  this  issue  as  part  of  the 
project-specific  HANSA  between  the  UK  and  the  Netherlands.  The  MoEA  and  ACM  in  the 
Netherlands assume responsibility for this action. 

▪ 

If required, adjust UK and Dutch regulations for the specific hybrid project to change the definition 
of  an  interconnector.  Despite  the  fact  the  cable  system  does  not  connect  two  national 
transmission systems, this would allow the cable system between the UK market and the offshore 

111 Dutch Elektriciteitswet 1998. §1 Article 15a. https://wetten.overheid.nl/BWBR0009755/2018-07-
28#Hoofdstuk3_Paragraaf1_Artikel15a 
Dutch Elektriciteitswet 1998. §1 Article 1 (as). https://wetten.overheid.nl/BWBR0009755/2018-07-
28#Hoofdstuk1_Paragraaf1_Artikel1 

 
 
                                                      
 
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substation of the Dutch export cable system to be defined as an interconnector. Certainty about 
changes can be achieved by addressing this issue as part of the project-specific HANSA between 
the  UK  and  the  Netherlands.  The  national  ministries  and  NRAs  assume  responsibility  for  this 
action (the BEIS and Ofgem in the UK, and the MoEA and ACM in the Netherlands). 

▪  On  a  European  level,  apply  for  project-specific  exemptions  from  existing  European  regulation 
based  on  the  pilot  character  of  the  hybrid  project.  One  exemption  could  possibly  concern  the 
definition  of  a  cable  system  as  an  interconnector  which  does  not  connect  two  national 
transmission  systems.  Another  could  possibly  concern  the  EU's  requirement  to  make  the 
maximum  capacity  of  interconnectors  available  for  access  by  third  parties.112  This  can  be 
achieved  through  voluntary  cooperation  between  TenneT  TSO  B.V.  and  the  European 
Commission, initiated by the project developers (TenneT TSO B.V.). 

▪ 

If  required,  adjust  the  EU's  regulatory  framework  such  that  it  facilitates  hybrid  project 
development.  For  example,  incorporate  a  hybrid  cable  system  definition  in  Regulation  (EC) 
714/2009.113 Also clarify how the hybrid project's requirements fit with the stipulation of free usage 
of  the  "maximum  capacity"  of  interconnectors  by  third  parties.  Guidance  from  project-specific 
developers is required to inform the adjustment of the existing regulatory framework. Initiated by 
EU  Member  States,  this  can  be  achieved  through  the  harmonisation  of  the  EU's  regulatory 
framework by the European Commission, the European Parliament and the European Council. 
The European Court of Justice, which interprets and clarifies existing European law,114 may need 
to clarify "maximum capacity" in this context. 

▪  Develop a regional capacity calculation and allocation mechanism that accounts for the hybrid 
cable  system  classification  (export  cable  system  with  interconnector  functionality)  within  the 
framework of the existing CACM regulation (Regulation (EU) 2015/1222).115 This can be achieved 
through  voluntary  cooperation  between  TenneT  TSO  B.V.  (and  a  potential  UK  interconnector 
developer) and NRAs (Ofgem in the UK and ACM in the Netherlands). 

▪  Validate whether no additional compensation for the interconnector operator is required, as the 
interconnector is developed as part of the hybrid project from the beginning. However, the OWF 
developer is compensated through a RES subsidy scheme by bidding for the required subsidy 
level in a competitive process. For this, the OWF developer needs clarity on the market conditions 
applicable to the OWF in the future. The former can be achieved through voluntary cooperation 
between TenneT TSO B.V. (and a potential UK interconnector developer), national ministries and 
NRAs (the BEIS and Ofgem in the UK, and the MoEA and ACM in the Netherlands) as well as 
the European Commission. 

▪  Ensure compatibility with measures adopted to mitigate the barrier "disproportionate allocation of 
costs and benefits across involved stakeholders". Do this through the fair reallocation among the 

112 European Parliament, European Council. 2009. REGULATION (EC) No. 714/2009 on conditions 
for access to the network for cross-border exchanges in electricity. https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:32009R0714&from=EN 

113 European Parliament, European Council. 2009. REGULATION (EC) No. 714/2009 on conditions 
for access to the network for cross-border exchanges in electricity. https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:32009R0714&from=EN 

114 European Commission. 2018. Court of Justice of the European Union (CJEU). 
https://europa.eu/european-union/about-eu/institutions-bodies/court-justice_en 

115 European Commission. 2015. COMMISSION REGULATION (EU) 2015/1222 establishing a 
guideline on capacity allocation and congestion management. https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:32015R1222&from=EN 

 
 
                                                      
 
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UK and the Netherlands of costs and benefits deriving from the hybrid cable system classification. 
Certainty about the allocation of costs and benefits can be achieved by addressing this issue as 
part of the project-specific HANSA between the UK and the Netherlands. TenneT TSO B.V. (and 
a potential UK interconnector developer) as well as national ministries and NRAs (the BEIS and 
Ofgem  in  the  UK,  and  the  MoEA  and  ACM  in  the  Netherlands)  assume  responsibility  for  this 
action. 

The  barrier,  its  mitigation  and  the  actions  required  to  implement  the  mitigation  are  summarised  in 
Figure  26.  The  actions  required  to  implement  the  mitigation  measure  and  the  stakeholders 
responsible for the individual actions are summarised across barriers and in Figure 22. 

Figure 26: IJmuiden Ver to UK barrier mitigation – Uncertainty about hybrid cable system classification 

Failure of developers to align planning across assets and countries 

Project-specific barrier evaluation: The IJmuiden Ver to UK hybrid project is complex. This is due to 
the inclusion of a Dutch OWF, an  export cable system to the Dutch market and an interconnector 
linking the UK market to the offshore substation of the Dutch export cable system. As all three assets 
have separate permit, development and construction timelines, geographical alignment is crucial. For 
example, the location of the offshore substation of the export cable system in the Netherlands must 
align with the route of the interconnector such that the interconnector can be added later. In addition, 
interoperability between the different components of the three assets must be ensured, based on the 
alignment of technical specifications to enable the hybrid project to function. 

Uncertainty about hybrid cable system classification>Define the export cable system as an export cable system with interconnector functionality, which makes it a hybrid cable system, provided that defining the export cable system as part of the national transmission system is not possible>Validate compatibility of defining NL export cable system as a national transmission system (in line with EU law) with NL regulat.>If compatible, validate fit of dual functionality of NL export cable system with NL regulation>If required, adjust NL regulation to classify NL export cable system as a transmission system and to allow dual functionality>If not possible, define new hybrid asset class and develop new NL regulation>If NL export cable system is not classified as transmission system, adjust UK and NL regulations to allow IC definition>Apply for project-specific exemptions from EU regulations>If required, adjust regulatory framework on European level >Develop regional capacity calculation, allocation mechanism>Validate whether no additional compensation for IC operator is required>Ensure fair allocation of costs and benefits across stakeholdersBarrierMitigation measureActions 
 
 
 
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Barrier mitigation: The mitigation option identified as most feasible is to facilitate continuous dialogue 
and early-stage alignment between the project developers. Given that the location of the Dutch OWF 
is determined by the Dutch authorities, project developers need to align on the following: the routing 
of the cable systems and the location of substations, the technical specifications of the cable systems, 
the substations and the OWF included in the hybrid project. This is based on consideration of the 
interdependencies shown in Table 1, interaction with project stakeholders (see Chapter  5.1.5) and 
the ease of implementation in terms of the required effort. 

Apart from continuous dialogue and early-stage alignment between the project developers, no other 
mitigation options were considered.  

Regarding  interdependencies,  this  barrier  is  interdependent  with  the  following  five  barriers: 
"uncertainty about responsibility for project development"; "uncertainty about regulation deriving from 
jurisdiction over cross-border cable systems"; "uncertainty about responsibility and rules to provide 
access to maritime space for OWFs (tender design)"; the "lack of regulated revenues for anticipatory 
investments" and the "limited engagement of public stakeholders". Continuous dialogue and early-
stage  alignment  are  complemented  by  clearly  defining  who  is  responsible  for  development, 
construction and operation of the interconnector as well as the need to obtain all relevant permits and 
align  regulation.  However,  dialogue  and  alignment  themselves  are  supported  by  the  following 
measures  to  mitigate  other  barriers.  An  aligned  tender  design  allows  for  the  involvement  of  and 
coordination with the developer of the OWF in the hybrid project. Two factors allow for such alignment 
by  decreasing  the  risk  to  hybrid  project  development  arising  from  early-stage  project-specific 
decisions: certainty about the availability of regulated revenues for anticipatory investments; and a 
formalised public commitment and public financial support. 

Action and responsibilities for mitigation implementation: To implement this mitigation measure for 
the IJmuiden Ver to UK hybrid project, the following action is required: 

▪  Engage in a continuous dialogue to achieve early-stage alignment regarding locations, routing 
and  technical  specifications  for  the  individual  assets.  This  can  be  achieved  through  voluntary 
cooperation between TenneT TSO B.V. (and a potential UK interconnector developer) and the 
national ministries and NRAs (the BEIS, supported by The Crown Estate and Ofgem, in the UK, 
and the MoEA, supported by RVO and ACM, in the Netherlands).  

The  barrier,  its  mitigation  and  the  actions  required  to  implement  the  mitigation  are  summarised  in 
Figure  27.  The  actions  required  to  implement  the  mitigation  measure  and  the  stakeholders 
responsible for the individual actions are summarised across barriers in Figure 22. 

Figure 27: IJmuiden Ver to UK barrier mitigation – Failure of developers to align planning across assets and 
countries 

Uncertainty about responsibility and rules to provide access to maritime space for OWFs 
(tender design) 

Project-specific barrier evaluation: A suitable tender design needs to be chosen for the IJmuiden Ver 
to UK hybrid project. The OWF in the project setup is located in the Dutch EEZ and an interconnector 

Failure of developers to align planning across assets and countries>Facilitate continuous dialogue and early-stage alignment between project developers>Engage in dialogue to achieve early-stage alignment regarding locations, routing and technical specifications of assetsBarrierMitigation measureActions 
 
 
 
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links the UK market and the offshore substation of the Dutch export cable system. Thus, both the UK 
and  the  Netherlands  have  an  interest  in  defining  the  requirements  for  the  OWF  development  in 
accordance  with  their  respective  standards.  These  may  be  contradictory.  In  addition,  the  tender 
design needs to ensure that tender candidates can realistically develop the OWF. In consequence, 
the tender design must clarify which hybrid-specific requirements to include. 

Barrier mitigation: The mitigation option identified as most feasible is to implement a tender design 
with strict tender requirements. These should be aligned among the UK and the Netherlands and also 
eliminate all hybrid-specific uncertainties for the OWF developer. This is based on consideration of 
the  interdependencies shown  in  Table  1,  interaction  with project stakeholders (see Chapter  5.1.7) 
and the ease of implementation in terms of the required effort. 

The  other  mitigation  options  considered  in  this  study  were  (1)  to  have  a  strict  tender  design  with 
requirements  aligned  among  the  stakeholders,  (2)  to  have  a  strict  tender  design  without  hybrid-
specific uncertainties for the OWF developer and (3) to have a lenient tender design with requirements 
aligned among the stakeholders and without hybrid-specific uncertainties for the OWF developer.  

The mitigation option identified as most feasible was selected for the following reasons: While aligned 
requirements  potentially  necessitate  amendments  to  national  legislation  and  regulations,  both 
countries  have  valid  interests  in  defining  certain  requirements  for  the  overall  tender.  Aligned 
requirements also aid in ensuring the interoperability of the OWF with the other assets of the hybrid 
project.  These  factors  increase  the  probability  of  successful  hybrid  project  implementation. 
Furthermore,  a  tender  design  with  strict  requirements  also  increases  the  probability  of  successful 
project  implementation,  allowing  for  a  possible  decrease  in  the  cost  efficiency  of  the  OWF 
development due to more limited competition. Lastly, certainty about hybrid-specific characteristics 
of  the  OWF  development  increases  the  probability  of  successful  project  implementation  –  and 
decreases the cost of implementation – by reducing the risk premium otherwise demanded by OWF 
developers in terms of subsidies. 

Regarding  interdependencies,  this  barrier  is  interdependent  with  the  following  three  barriers: 
"uncertainty about regulation deriving from jurisdiction over cross-border cable systems"; the "failure 
of developers to align planning across assets and countries"; and "uncertainty about applicable RES 
subsidy scheme". Aligned regulation deriving from UK and Dutch jurisdiction needs to be reflected in 
the  requirements  of  the  OWF  tender.  In  addition,  the  OWF  tender  can  include  an  RES  subsidy 
scheme established by the Netherlands. Continuous dialogue and early-stage alignment facilitate an 
aligned tender design.  

Action and responsibilities for mitigation implementation: To implement this mitigation measure for 
the IJmuiden Ver to UK hybrid project, the following actions are required: 

▪  Agree a tender design with strict requirements. Certainty about the tender design can be achieved 
by  addressing  this  issue  as  part  of  the  project-specific  HANSA  between  the  UK  and  the 
Netherlands. The national ministries and other national authorities assume responsibility for this 
action  (the  BEIS  and  The  Crown  Estate  in  the  UK,  and  the  MoEA,  ACM  and  RVO  in  the 
Netherlands). 

Agree tender requirements which take account of the valid interest of the UK and the Netherlands. 
This  means  jointly  defining  material  requirements  such  as  technical  and  operational  standards. 
Environmental standards do not need to be aligned between the UK and the Netherlands, as Dutch 
environmental  standards  apply  to  the  OWF.  Similarly,  financial  requirements  do  not  need  to  be 
aligned  across  countries.  Guidance  from  project-specific  developers  is  required  to  inform  the 
development  of  project-specific  tender  requirements.  Certainty  about  tender  requirements  can  be 
achieved by  addressing  this issue as  part  of the  project-specific HANSA between the UK  and the 

 
 
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Netherlands.  The  national  ministries  and  other  national  authorities  assume  responsibility  for  this 
action  (the  BEIS  and  The  Crown  Estate  in  the  UK,  and  the  MoEA,  ACM  and  RVO  in  the 
Netherlands).The  barrier,  its  mitigation  and  the  actions  required  to  implement  the  mitigation  are 
summarised  in  Figure  28.  The  actions  required  to  implement  the  mitigation  measure  and  the 
stakeholders responsible for the individual actions are summarised across barriers in Figure 22. 

Figure 28: IJmuiden Ver to UK barrier mitigation – Uncertainty about responsibility and rules to provide access 
to maritime space for OWFs (tender design) 

Lack of regulated revenues for anticipatory investments 

Project-specific  barrier  evaluation:  Anticipatory  investments  are  necessary  to  allow  for  the 
implementation  of  the  IJmuiden  Ver  to  UK  hybrid  project.  As  the  interconnector  establishes  a  link 
between the offshore substation of the Dutch export cable system and the UK market, it is necessary 
to adapt the technical setup of the substations to support the interconnector link. These adaptations 
represent  additional  investment  costs  for  TenneT  TSO  B.V.  as  the  developer  of  the  substation  in 
anticipation  of  the  future  interconnector  link.  As  any  investments  in  grid  infrastructure  deemed 
inefficient by regulators are not compensated,116 the additional costs faced by TenneT TSO B.V. may 
present an obstacle to hybrid project development. 

Barrier mitigation: The mitigation identified as most feasible is to validate the feasibility of regulated 
revenues  for  the  anticipatory  investments  under  the  regulatory  regime  in  the  Netherlands.  This  is 
based  on  consideration  of  the  interdependencies  shown  in  Table  1,  interaction  with  project 
stakeholders (see Chapter 5.1.11) and the ease of implementation in terms of the required effort. 

Besides  validating  the  feasibility  of  regulated  revenues  for  anticipatory  investments  under  the 
regulatory regime in the Netherlands, no other mitigation option can be considered. The export cable 
system, which requires anticipatory investments, is  geographically  located in the Netherlands. The 
Dutch regime is therefore applicable and must be assessed with regard to the coverage of the specific 
investments.  

Regarding interdependencies, this barrier is interdependent with the "failure of developers to align 
planning across assets and countries" barrier. Continuous dialogue and early-stage alignment with 
the  MoEA  and  ACM  in  the  Netherlands  support  the  validation  of  the  coverage  of  the  anticipatory 
investments with regulated revenues under the Dutch regime.  

Actions and responsibilities for mitigation implementation: To implement this mitigation measure for 
the IJmuiden Ver to UK hybrid project, the following actions are required: 

116 ACER. 2014. Recommendation of the Agency for the cooperation of energy regulators No 
03/2014. 
https://www.acer.europa.eu/Official_documents/Acts_of_the_Agency/Recommendations/ACER%20
Recommendation%2003-2014.pdf 

Uncertainty about responsibility and rules to provide access to maritime space for OWFs (tender design)>Implement tender design with strict tender requirements which are aligned between the UK and the Netherlands and eliminate all hybrid-specific uncertainties>Agree tender design with strict requirements>Agree tender requirements considering the interests of the UK and the NetherlandsBarrierMitigation measureActions 
 
 
 
                                                      
 
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▪  Validate the inclusion  of the anticipatory  investments in the Dutch Offshore Grid Development 
Framework117  to  allow  for  their  inclusion  in  the  investment  planning  of  TenneT TSO  B.V.  This 
ensures that anticipatory investments for the export cable system of the Dutch OWF are covered 
by  regulated  revenues.  This  action  can  be  based  on  an  existing  decision-making  process  for 
investments  for  the  offshore  grid.  It  can  therefore  be  achieved  through  voluntary  cooperation 
between TenneT TSO B.V., the MoEA and ACM in the Netherlands. 

▪  Ensure compatibility with measures adopted to mitigate the barrier "disproportionate allocation of 
costs and benefits across involved stakeholders". Do this through the fair reallocation among the 
UK and the Netherlands of costs and benefits deriving from regulated revenues for anticipatory 
investments. Certainty about the allocation of costs and benefits can be achieved by addressing 
this issue as part of the project-specific HANSA between the UK and the Netherlands. TenneT 
TSO B.V. (and a potential UK interconnector developer) and the national ministries and NRAs 
(the  BEIS  and  Ofgem  in  the  UK,  and  the  MoEA  and  ACM  in  the  Netherlands)  assume 
responsibility for this action. 

The  barrier,  its  mitigation  and  the  actions  required  to  implement  the  mitigation  are  summarised  in 
Figure  29.  The  actions  required  to  implement  the  mitigation  measure  and  the  stakeholders 
responsible for the individual actions are summarised across barriers in Figure 22. 

Figure 29: IJmuiden Ver to UK barrier mitigation – Lack of regulated revenues for anticipatory investments 

Uncertainty about the applicable RES subsidy scheme 

Project-specific  barrier  evaluation:  The  OWF  included  in  the  IJmuiden  Ver  to  UK  hybrid  project  is 
located  in  the  Dutch  EEZ,  which  suggests  a  Dutch  RES  subsidy  scheme.  However,  due  to  the 
connection to the UK market, the following schemes are also possible: a UK subsidy scheme with 
statistical transfers between the UK and the Netherlands, a joint project or a joint subsidy scheme 
between the UK and the Netherlands. All are in line with EU Directive 2009/28/EC118 on the promotion 
of the use of energy from RES. In summary, the applicability of a support scheme from one of the 
countries involved or in some joint form is to be determined. 

Barrier mitigation: The mitigation option identified as most feasible is to apply the Dutch RES subsidy 
scheme to the OWF included in the hybrid project. Under this scheme, the Dutch government awards 
the OWF a premium tariff through the Dutch tender process (i.e. the SDE+ subsidy scheme with its 
regular characteristics in terms of type, level and duration of support as well as technology coverage). 
This  is  based  on  consideration  of  the  interdependencies  shown  in  Table  1  and  the  ease  of 
implementation in terms of the required effort, 

117 Dutch Elektriciteitswet 1998. Article 21. https://wetten.overheid.nl/BWBR0009755/2018-07-
28#Hoofdstuk3_Paragraaf3_Artikel21 

118 European Parliament, European Council. 2009. DIRECTIVE 2009/28/EC on the promotion of the 
use of energy from renewable sources. https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:32009L0028&from=EN 

Lack of regulated revenues for anticipatory investments>Validate feasibility of regulated revenues for anticipatory investments under the regulatory regime in the NL>Validate inclusion of anticipatory investments in Dutch Offshore Grid Development Framework>Ensure fair allocation of costs and benefits across stakeholdersBarrierMitigation measureActions 
 
 
 
                                                      
 
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Since this RES subsidy scheme was identified as applicable in interaction with project stakeholders 
from the beginning, no other mitigation options were considered in detail. 

Regarding  interdependencies,  this  barrier  is  interdependent  with  the  following  three  barriers: 
"uncertainty about market arrangements"; "uncertainty about hybrid cable system classification"; and 
"uncertainty  about  responsibility  and  rules  to  provide  access  to  maritime  space  for  OWFs  (tender 
design)". The business case of the OWF in the hybrid project – and thereby potentially the level of 
required subsidies – is affected by the market arrangement of commercial flows from the OWF only 
to the Dutch market. Similarly, the level of required subsidies  is also impacted by the hybrid cable 
system classification of defining the export cable system as export cable system with interconnector 
functionality. Lastly, applying a Dutch subsidy scheme fits with a tender design in accordance with 
the rules of Dutch authorities. 

Actions and responsibilities for mitigation implementation: To implement this mitigation measure for 
the IJmuiden Ver to UK hybrid project, the following actions are required: 

▪  Validate the feasibility of defining the RES subsidy scheme that is applicable as a Dutch subsidy 
scheme. This can be achieved through  voluntary cooperation between TenneT TSO B.V., the 
MoEA and ACM in the Netherlands. 

▪  Ensure compatibility with measures adopted to mitigate the barrier "disproportionate allocation of 
costs and benefits across involved stakeholders". Do this through the fair reallocation among the 
UK and the Netherlands of costs and benefits deriving from the RES subsidy scheme. Certainty 
about the allocation of costs and benefits can be achieved by addressing this issue as part of the 
project-specific  HANSA  between  the  UK  and  the  Netherlands.  The  OWF  developer,  national 
ministries and NRAs (the BEIS and Ofgem in the UK, and the MoEA and ACM in the Netherlands) 
assume responsibility for this action. 

The  barrier,  its  mitigation  and  the  actions  required  to  implement  the  mitigation  are  summarised  in 
Figure  30.  The  actions  required  to  implement  the  mitigation  measure  and  the  stakeholders 
responsible for the individual actions are summarised across barriers in Figure 22. 

Figure 30: IJmuiden Ver to UK barrier mitigation – Uncertainty about applicable RES subsidy scheme 

Limited engagement of public stakeholders 

Project-specific  barrier  evaluation:  The  support  of  public  stakeholders  is  needed  for  successful 
implementation of the IJmuiden Ver to UK hybrid project, as regulatory and technical barriers must 
be  overcome,  and  financial  support  provided  across  two  countries,  namely,  the  UK  and  the 
Netherlands.  

Barrier mitigation: The mitigation option identified as most feasible is to formalise public commitment 
in  the  form  of  a  project-specific  MoU  or  a  project-specific  HANSA.  Feasibility  studies  and  scoping 
studies  for  early-stage  alignment  through  public  funding,  for  example,  should  also  be  facilitated. 
Furthermore, adequate de-risking of the hybrid project is required. This is based on consideration of 

Uncertainty about the applicable RES subsidy scheme>Apply Dutch subsidy scheme to OWF included in hybrid project>Validate feasibility of applying the Dutch subsidy scheme to the OWF>Ensure fair allocation of costs and benefits across stakeholdersBarrierMitigation measureActions 
 
 
 
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the interdependencies shown in Table 1, interaction with project stakeholders (see Chapter 5.1.13) 
and the ease of implementation in terms of the required effort, 

Besides  formalising  public  commitment  in  the  form  of  a  project-specific  MoU  or  a  project-specific 
HANSA and facilitating feasibility studies and scoping studies or providing financial  guarantees, no 
other mitigation option was considered.  

Regarding interdependencies, this barrier is interdependent with the "failure of developers to align 
planning  across  assets  and  countries"  barrier.  Continuous  dialogue  and  early-stage  alignment 
between the project developers is facilitated by formalising the commitment of relevant stakeholders 
of the hybrid project and / or by providing public funding for early-stage activities. These may include 
feasibility studies, scoping studies and technical research and development. 

Actions and responsibilities for mitigation implementation: To implement this mitigation measure for 
the IJmuiden Ver to UK hybrid project, the following actions are required: 

▪  Align and implement the type of formalisation of public commitment to allow for the development 
of the IJmuiden Ver to UK hybrid project. The formalisation of commitment in the form of a project-
specific MoU or HANSA is an expression of the goodwill of the stakeholders to support hybrid 
project development. It assures project developers of public support, e.g. in the form of a dialogue 
with  relevant  government  bodies.  In  early  project  stages,  a  project-specific  MoU  provides 
sufficient certainty for project developers. The stakeholders assuming responsibility are TenneT 
TSO B.V. (and a potential UK interconnector developer), national ministries and NRAs (the BEIS 
and  Ofgem  in  the  UK,  and  the  MoEA  and  ACM  in  the  Netherlands),  as  well  as  the  European 
Commission.  In  later  project  stages,  a  project-specific  HANSA  is  required  to  provide  project 
developers with sufficient legal certainty. The stakeholders assuming responsibility include the 
national  ministries  (the  BEIS  in  the  UK,  and  the  MoEA  in  the  Netherlands)  and  the  European 
Commission. 

▪  Catalyse  the  development  of  the  IJmuiden  Ver  to  UK  hybrid  project  by  supporting  early-stage 
alignment among developers. Do this through public funding for feasibility studies, pilot projects 
and R&D for innovative, technological solutions, in addition to existing offshore support schemes. 
Such public support allows developers to firmly commit to the development of the project. This 
can be achieved through voluntary cooperation between the national ministries (the BEIS in the 
UK, and the MoEA in the Netherlands) as well as the European Commission. 

▪  Support the de-risking of the hybrid project by providing financial guarantees. Such guarantees 
can reassure project developers in situations which cannot be foreseen due to the pilot character 
of the hybrid project. This can be achieved through voluntary cooperation between the project 
developers  (TenneT  TSO  B.V.  and  a  potential  UK  interconnector  developer)  as  well  as  the 
European Commission. 

▪  Ensure  compatibility  with  the  measures  adopted  to  mitigate  the  barrier  "disproportionate 
allocation of costs and benefits across involved stakeholders". Do this through the fair reallocation 
among the UK and the Netherlands of costs and benefits deriving from the engagement of public 
stakeholders. Certainty about the allocation of costs and benefits can be achieved by addressing 
this  issue  as  part  of  the  project-specific  HANSA  between  the  UK  and  the  Netherlands.  The 
national ministries and NRAs assume responsibility for this action (the BEIS and Ofgem in the 
UK, and the MoEA and ACM in the Netherlands). 

The  barrier,  its  mitigation  and  the  actions  required  to  implement  the  mitigation  are  summarised  in 
Figure  31.  The  actions  required  to  implement  the  mitigation  measure  and  the  stakeholders 
responsible for the individual actions are summarised across barriers in Figure 22. 

 
 
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Figure 31: IJmuiden Ver to UK barrier mitigation – Limited engagement of public stakeholders 

Uncertainty regarding the UK market 

Project-specific barrier evaluation: The IJmuiden Ver to UK hybrid project stands to benefit from the 
UK  Capacity  Market  and  the  UK  Cap  and  Floor  regime  because  it  establishes  interconnection 
capacity between the UK and the Netherlands. While there currently are no changes proposed to the 
UK Capacity Market or the UK Cap and Floor regime, any potential effects of the UK's withdrawal 
from the EU need to be evaluated after the withdrawal is completed. Thus, it is also unclear whether 
the IJmuiden Ver to UK hybrid project will benefit from these policies.119 

Barrier  mitigation:  Considering  interaction  with  project  stakeholders  (see  Chapter  5.1.14),  no 
immediate actions can be taken. It is necessary to await clarification of future UK policies as well as 
the UK's intended future interaction with the EU energy market.  

Besides awaiting clarification of future UK policies and the future participation of the UK in the EU's 
internal energy market, no other mitigation option was considered.  

Regarding interdependencies, this barrier is not interdependent with any other barrier considered in 
this study. 

Actions and responsibilities for mitigation implementation: To implement this mitigation measure for 
the IJmuiden Ver to UK hybrid project, the following actions are required: 

▪  Await clarification of the future of the UK Capacity Market and the UK Cap and Floor regime to 

clarify the future business case for interconnectors linking to the UK.  

▪  Await clarification on whether the UK intends to participate in the EU’s internal energy market in 

the future to provide planning security for hybrid project developers.  

The  barrier,  its  mitigation  and  the  actions  required  to  implement  the  mitigation  are  summarised  in 
Figure  32.  The  actions  required  to  implement  the  mitigation  measure  and  the  stakeholders 
responsible for the individual actions are summarised across barriers in Figure 22. 

119 Vaughan, Adam. 2018. UK's backup power subsidies are illegal, European court rules. 
https://www.theguardian.com/environment/2018/nov/15/uk-backup-power-subsidies-illegal-
european-court-capacity-market 

Limited engagement of public stakeholders>Formalise public commitment >Facilitate early-stage alignment through public funding and support de-risking of hybrid project>Align and implement formalisation of public commitment (in early project stages in form of MoU, later HANSA)>Support early-stage alignment among developers through public funding>Support de-risking of project by providing financial guarantees>Ensure fair allocation of costs and benefits across stakeholdersBarrierMitigation measureActions 
 
 
 
                                                      
 
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Figure 32: IJmuiden Ver to UK barrier mitigation – Uncertainty regarding the UK market 

Disproportionate allocation of costs and benefits across involved stakeholders 

Project-specific barrier evaluation: Agreeing on the allocation of costs and benefits in the IJmuiden 
Ver to UK hybrid project is complex. This is because the OWF is geographically located in the Dutch 
EEZ  and  the  offshore  substation  of  its  export  cable  system  is  linked  to  the  UK  market  by  an 
interconnector.  Certain  costs  and  benefits  are  initially  incurred  by  the  UK  and  certain  costs  and 
benefits  are  initially  incurred  by  the  Netherlands  due  to  the  technical  setup  and  the  details  of  the 
hybrid project. In addition, the measures adopted to mitigate other barriers assign costs or distribute 
benefits  to  the  UK  and  the  Netherlands.  Furthermore,  developers  may  realise  additional  benefits. 
Thus,  costs  and  benefits  are  generally  not  distributed  fairly,  and  no  suitable  approach  exists  to 
reallocate costs and benefits across all stakeholders of the hybrid project.  

Barrier mitigation: The mitigation option identified as most feasible is to reallocate costs and benefits 
deriving  from  the  hybrid  project  where  required,  based  on  a  project-specific  process.  In  some 
respects,  the  process  can  be  based  on  the  existing  methodology  given  by  the  Cross-Border  Cost 
Allocations  (CBCA)  process,120  which  builds  on  the  Cost  Benefit  Analysis  (CBA)  conducted  by 
ENTSO-E121  for  Projects  of  Common  Interest.  For  the  CBCA  process,  benefits  such  as  socio-
economic welfare and CO2 emissions are calculated on a national level to compensate net losers for 
the implementation of a project through a CBCA decision. The CBCA process provides a good starting 
point for the reallocation of costs and benefits across countries but is best suited for evaluating cross-
border electricity interconnectors. This is based on consideration of the interdependencies shown in 
Table 1, interaction with project stakeholders (see Chapter 5.1.15) and the ease of implementation in 
terms of the required effort. 

Besides implementing the process resulting in the reallocation of costs and benefits deriving from the 
implementation of the hybrid project, no other mitigation option was considered.  

Regarding  interdependencies,  this  barrier  is  interdependent  with  the  following  six  barriers: 
"uncertainty  about  responsibility  for  project  development  (responsibility  for  interconnector)"; 
"uncertainty about market arrangements"; "uncertainty about hybrid cable system classification"; the 
"lack of regulated revenues for anticipatory investments"; "uncertainty about applicable RES subsidy 
scheme"; and "limited engagement of public stakeholders". Reallocation also relates to those barriers. 
This is because their mitigation translates into costs and benefits for specific stakeholders that might 

120 ACER. 2015. Recommendation No 5/2015 on good practices for the treatment of the investment 
requests, including CBCA requests, for electricity and gas PCIs. 
https://acer.europa.eu/Official_documents/Acts_of_the_Agency/Recommendations/ACER%20Reco
mmendation%2005-2015.pdf 

121 ENTSO-E. 2018. 2nd ENTSO-E Guideline: For Cost Benefit Analysis of Grid Development 
Projects. 
https://tyndp.entsoe.eu/Documents/TYNDP%20documents/Cost%20Benefit%20Analysis/2018-10-
11-tyndp-cba-20.pdf 

Uncertainty regarding the UK market>Await clarification of future UK policies>Await clarification of intended future interaction with EU’s energy market>Await clarification of future of UK capacity market and UK cap and floor regime>Await clarification of UK's future particip. in internal energy market BarrierMitigation measureActions 
 
 
                                                      
 
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have to be reallocated together with all other costs and benefits of the hybrid project. Therefore, the 
costs and benefits deriving from all six interdependent barriers must be considered. 

Actions and responsibilities for mitigation implementation: To implement this mitigation measure for 
the IJmuiden Ver to UK hybrid project, the following actions are required: 

▪ 

Identify the relevant cost and benefit categories between the involved stakeholders, covering all 
significant  aspects  of  the  hybrid  project.  This  can  be  achieved  through  voluntary  cooperation 
between TenneT TSO B.V. in the Netherlands (and a potential UK interconnector developer) as 
well as national ministries and NRAs (the MoEA and ACM in the Netherlands, and the BEIS and 
Ofgem in the UK).  

▪  Ensure that due consideration is given to all costs and benefits deriving from measures adopted 
to  mitigate  the  following  barriers:  "uncertainty  about  responsibility  for  project  development"; 
"uncertainty about market arrangements"; "uncertainty about hybrid cable system classification"; 
the "lack of regulated revenues for anticipatory investments"; "uncertainty about applicable RES 
subsidy  scheme";  and  the  "limited  engagement  of  public  stakeholders".  This  can  be  achieved 
through  voluntary  cooperation  between  all  stakeholders  involved  in  the  individual  barrier 
mitigation measures. 

▪  Determine  the  initial  allocation  of  costs  and  benefits,  covering  the  cost  and  benefit  categories 
across  all  significant  aspects  of  the  hybrid  project  identified  in  the  first  step.  In  this  process, 
developers  typically  conduct  the  assessment  of  costs  and  benefits,  while  NRAs  oversee  and 
validate  results.  Thus,  this  can  be  achieved  through  voluntary  cooperation  between  the  OWF 
developer, TenneT TSO B.V. in the Netherlands (and a potential UK interconnector developer) 
as well as national ministries and NRAs (the BEIS and Ofgem in the UK, and the MoEA and ACM 
in the Netherlands). 

▪  Align and agree a suitable reallocation of costs and benefits between developers, the UK and the 
Netherlands.  This  should  be  based  on  the  identification  of  cost  and  benefit  categories  among 
stakeholders as well as the assessment of the initial allocation of costs and benefits along the 
identified  categories.  The  allocation  could  closely  reflect  ongoing  practices  for  implemented 
interconnectors. These might already be suitable to incentivise all parties involved in the hybrid 
project. Certainty about the allocation of costs and benefits can be achieved by addressing this 
issue  as  part  of  the  project-specific  HANSA  between  the  UK  and  the  Netherlands.  The  OWF 
developer, TenneT TSO B.V. in the Netherlands (and a potential UK interconnector developer), 
and national ministries and NRAs (the BEIS and Ofgem in the UK, and MoEA and ACM in the 
Netherlands) assume responsibility for this action, as well as the European Commission. 

▪  Validate  the  availability  of  CEF  funding  to  ensure  adequate  incentivisation  for  all  relevant 
stakeholders if the following applies: the IJmuiden Ver to UK hybrid project is a PCI and adds 
socio-economic value, but the initial allocation of costs and benefits is not sufficiently balanced to 
incentivise  all  countries  and  stakeholders  to  implement  the  hybrid  project.  While  CEF  funding 
cannot resolve viability issues of projects, it is a last resort for PCIs that have received a CBCA 
decision  but  are  still  not  commercially  viable  for  each  individual  stakeholder.122  This  can  be 
achieved through voluntary cooperation between TenneT TSO B.V. and NRAs (Ofgem in the UK 
and ACM in the Netherlands) as well as the European Commission. 

122 European Parliament, European Council. 2013. REGULATION (EU) No. 347/2013 on guidelines 
for trans-European energy infrastructure. Article 14. https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:32013R0347&from=en 

 
 
                                                      
 
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The  barrier,  its  mitigation  and  the  actions  required  to  implement  the  mitigation  are  summarised  in 
Figure  33.  The  actions  required  to  implement  the  mitigation  measure  and  the  stakeholders 
responsible for the individual actions are summarised across barriers in Figure 22. 

Figure 33: IJmuiden Ver to UK barrier mitigation – Disproportionate allocation of costs and benefits across 
involved stakeholders 

4.5  CGS IJmuiden Ver to Norfolk  

The  hybrid  project  idea  "CGS  IJmuiden  Ver  to  Norfolk"  is  a  combined  grid  solution  concept.  It 
connects the UK and the Dutch electricity markets via an interconnector. The interconnector links the 
offshore substations of the export cable systems of a UK OWF in the Norfolk area and a Dutch OWF 
in the IJmuiden Ver area. Both OWFs have planned radial connections to their respective markets. 
The idea shows significant lifetime savings compared to the reference case, in which OWFs and the 
interconnector are stand-alone assets. Thus, the CGS IJmuiden Ver to Norfolk hybrid project is given 
further consideration in the scope of this study and an Action Plan for the implementation of measures 
to  mitigate  barriers  has  been  developed.  The  Action  Plan  is  intended  to  be  used  as  a  tool  by 
stakeholders once the CGS IJmuiden Ver to Norfolk hybrid project has been given the go-ahead. 

Both  the  CGS  IJmuiden  Ver  to  Norfolk  hybrid  project  and  the  IJmuiden  Ver  to  UK  hybrid  project 
include  the  IJmuiden  Ver  development  area  and  consequently  have  similar  stakeholder  groups. 
However, the projects have different technical and commercial setups and are therefore evaluated 
separately. 

4.5.1  Details of the hybrid project and reference case 

The individual assets included in the hybrid  project and in the reference case are modelled on the 
basis  of  real  assets.  But  the  assumed  characteristics  do  not  claim  to  represent  the  actual 
characteristics of the assets included in either ongoing or future developments. 

In the reference case (Figure 34), the interconnector is a stand-alone, point-to-point interconnector 
between  the  UK  and  the  Netherlands.  It  is  constructed  based  on  HVDC  technology  with  900  MW 
nominal capacity and a length of 190 km. The OWFs included in the project idea are in the Norfolk 
area of the UK EEZ and in the IJmuiden Ver area of the Dutch EEZ. They have nominal generation 
capacities of 900 MW and 1,300 MW, respectively. The UK OWF is radially connected to the UK via 
a 100 km HVDC export cable system. The Dutch OWF is radially connected to the Netherlands with 
an  80  km  HVDC  export  cable  system.  No  intermediate  offshore  transformers  are  required,  as  the 
wind turbines can be connected directly to the high-voltage offshore transformers via the 66-kV array 
cable systems. The UK export cable system has a capacity of 900 MW and the Dutch export cable 
system a nominal capacity of 1,300 MW. 

Disproportionate allocation of costs and benefits across involved stakeholders>Reallocate costs and benefits among involved stakeholders>Identify cost / benefit categories>Ensure consideration of all costs / benefits deriving from other barrier mitigation measures>Determine initial allocation>Align and agree reallocation >Validate availability of CEF funding to ensure incentivisationBarrierMitigation measureActions 
 
 
 
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In the hybrid project (Figure 34), the interconnector is a point-to-point interconnector between the two 
offshore  substations  of  the  export  cable  systems  of  the  Norfolk  and  IJmuiden  Ver  OWFs.  It  is 
constructed mostly to the same specifications as in the reference case. However, the length of the 
interconnector is reduced to 60 km compared to the reference case. The OWFs and their export cable 
system have the same specifications as in the reference case. 

For all cable systems, onshore transformer stations are not  in the scope of the  assessment. As a 
result, benefits deriving from the hybrid project compared to the reference case – with fewer onshore 
transformer  stations  in  the  hybrid  project  than  in  the  reference  case  –  have  not  been  considered. 
Furthermore,  onshore  grid  reinforcement  costs  are  not  in  the  scope  of  this  assessment.  But  it  is 
important  that  they  are  considered  before  project  development  would  be  initiated.  The  need  for 
onshore  grid  reinforcements  can  be  expected  to  be  lower  in  the  hybrid  project  compared  to  the 
reference case, as the OWFs do not translate into the need for additional onshore grid connection 
points. 

Figure 34: CGS IJmuiden Ver to Norfolk – Reference case and hybrid project profile 

It is generally assumed that the development, construction and commissioning of the individual assets 
(two OWFs, two export cable systems and an interconnector) can be aligned in the hybrid project to 
prevent  temporarily  stranded  assets.  The  IJmuiden  Ver  OWF  is  expected  to  be  commissioned  by 
2027 and the Norfolk OWF by 2030 at the latest. Following this, it is assumed that the OWFs, export 
cable  systems  and  interconnector  will  be  commissioned  in  2027.  However,  the  separate 
commissioning  of  the  OWFs  and  export  cable  systems  or  the  later  commissioning  of  the 
interconnector  would  also  be  possible,  as  both  national  systems  function  independently.  The 
assumed commissioning dates are the same for the hybrid project and reference case. 

4.5.2 

Evaluation of hybrid project vs. reference case 

To evaluate the hybrid project against the reference case, this study calculates the lifetime savings 
of the hybrid project. These include the difference in cost and the difference in socio-economic welfare 
(SEW) between the hybrid project and the reference  case. Both the cost assessment  – looking at 
CAPEX and OPEX – and the market modelling-based SEW assessment are based on the technical 

Reference caseHybrid caseDifferenceNominal Capacity interconnector [MW]0900900Nominal capacity OWF [MW]02,200 (900 + 1,300)2,200 (900 + 1,300)Offshore transformer / converter / switching stations02 / 2 / 02 / 2 / 0Length interconnector [km]-13019060Length export cable [km]0180 (100 + 80)180 (100 + 80)Onshore transformer / converter stations-20 / 40 / 2Reference caseIndicativeIndicativeReference caseGeographical mappingConverter stationTransmission cableTransformerstation 
 
 
 
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setup  of  the  hybrid  project  and  the  reference  case,  as  described  in  the  project  details.  Additional 
indicators used in the assessment are energy not served, RES curtailment and CO2 emissions. CO2 
emissions are internalised as cost in the SEW. 

Assuming a typical asset lifetime of 25 years, the hybrid project yields lifetime savings of about EUR 
720  m  compared  to  the  reference  case  (Figure  35).  The  lifetime  savings  are  driven  entirely  by  a 
reduction of CAPEX and OPEX of about EUR 770 m. OPEX are calculated and discounted over a 
25-year period. However, a lower hybrid project SEW of EUR 4 m p.a. compared to the reference 
case translates into additional costs of EUR 48 m from lower lifetime SEW, discounted over 25 years. 
But  because  the  above-mentioned  cost  savings  significantly  exceed  these  additional  costs,  the 
lifetime  savings  remain  positive.  The  small  difference  in  SEW  is  spread  over  the  entire  European 
electricity  system.  It  is  originally  driven  by  the  suboptimal  operational  setup  of  the  generation  and 
transmission assets included in the hybrid project compared to the reference case. This means that 
either the available interconnector capacity is reduced or the OWF generation is curtailed as the two 
conflict with each other. 

Figure 35: CGS IJmuiden Ver to Norfolk – Assessment results123 

Regarding  the  cost  assessment,  the  result  is  driven  by  the  interconnector  only.  The  cost  of  the 
interconnector is lower in the hybrid project than in the reference case. The interconnector requires 
fewer kilometres of cable in the hybrid project and fewer substations. The interconnector links only 
the offshore substations of the export cable systems of the UK OWF and the Dutch OWF and does 
not extend from shore to shore. This renders redundant two onshore converter stations and about 
130  km  of  cable.  The  hybrid  project  requires  the  use  of  disconnector  modules,  but  these  have 
negligible costs compared to the cost savings. The costs of the OWF and its export cable system are 
the same in the hybrid and the reference case.  

123 SEW assessment based on Careri, Francesco. [Forthcoming]. The impact of North Sea 
electricity projects in a 2030 scenario: Preliminary assessment of system benefits for the pan-
European power system through METIS. Petten: European Commission Joint Research Centre. 

-48724106∆Lifetime OPEX (cable systems)1)∆Lifetime savings∆CAPEX667∆Lifetime SEW1)∆SEW2)-4SEW reference project∆Socio-economic welfare (SEW) (hybrid project -reference case) [EUR m p.a.]∆Lifetime savings (hybrid project -reference case) [EUR m]1) 8% discount factor        2) Including variation in CO2emissions (-14 kt/a), internalisedin producer surplusx 25 years 
 
 
 
                                                      
 
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In both the hybrid project and the reference case, energy not served is zero due to the comprehensive 
nature of and redundancies in the European electricity system. Therefore, neither setup adversely 
affects the EU's energy policy target of energy security. Compared to the reference case, the effect 
of the hybrid project on curtailment and CO2 emissions is very small.124 This suggests that the hybrid 
project  is  unlikely  to  have  a  significant  impact  on  the  EU's  energy  policy  targets  on  the  further 
establishment of the internal energy market and the decarbonisation of the economy. 

4.5.3  Development of an Action Plan to overcome barriers 

This chapter summarises the findings specific to the development of the CGS IJmuiden Ver to Norfolk 
hybrid  project.  It  builds  on  the  general  explanation  of  the  barriers  in  Chapter  3.2,  the  general 
explanation  of  the  interdependencies  between  barriers  in  Chapter  3.3  and  the  findings  of  project-
specific discussions of the barriers and mitigation options in Chapter 5.2. 

This  study  notes  that  11  of  the  16  identified  barriers  need  to  be  overcome  to  allow  for  the 
commencement  of  the  CGS  IJmuiden  Ver  to  Norfolk  hybrid  project  development.  The  mitigation 
measures for 9 of the 11 identified barriers assume that the market arrangement and the RES subsidy 
scheme applicable to the CGS IJmuiden Ver to Norfolk hybrid project will be validated as follows: The 
foreseen market arrangement is that the UK OWF transmits its electricity solely to the UK market and 
the Dutch OWF transmits its electricity solely to the Dutch market. Therefore, with regard to the hybrid 
cable system classification, only leftover capacity on the cable systems linking the UK to the Dutch 
market is available for interconnection. In line with this market arrangement, the RES subsidy scheme 
applicable to the UK OWF is the UK RES subsidy scheme. This is a Contract for Difference scheme 
with its regular characteristics in terms of type, level and duration of support, as well as the technology 
coverage. The RES subsidy scheme applicable to the Dutch OWF is the Dutch RES subsidy scheme 
(i.e. the SDE+ subsidy scheme with its regular characteristics in terms of type, level and duration of 
support, as well as the technology coverage). The market arrangement and the RES subsidy scheme 
as foreseen by the project stakeholders ensure that implementation is highly probable.  

Although  the  barriers  are  addressed  individually,  interdependencies  exist  between  them.  When 
developing ways to mitigate one barrier, it is therefore necessary to also consider the mitigation of 
other  barriers.  Table  2  provides  an  overview  of  the  project-specific  barriers  and  barrier  mitigation 
measures, as well as a brief description of the interdependencies to be considered in the development 
of the individual barrier mitigation measures. 

Barrier 

Mitigation measure 

Interdependencies 

Uncertainty about 
responsibility for 
project 
development 

Assign responsibility for 
development and construction 
as well as the operation of the 
interconnector to a group of 
players, which potentially 
includes TenneT TSO B.V. 

▪  Failure of developers to align planning 
across assets and countries: clearly 
assigning responsibility for development, 
construction and operation of interconnector 
facilitates continuous dialogue and early-
stage alignment 

124 The hybrid project generates additional curtailment of 3,300 MWh/a and additional CO2 
emissions of 14 kt/a (internalised in socio-economic welfare). For more details, please refer to 
Careri, Francesco. [Forthcoming]. The impact of North Sea electricity projects in a 2030 scenario: 
Preliminary assessment of system benefits for the pan-European power system through METIS. 
Petten: European Commission Joint Research Centre. 

 
 
 
                                                      
 
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Barrier 

Mitigation measure 

Interdependencies 

and UK interconnector 
developer 

Uncertainty about 
regulation 
deriving from 
jurisdiction over 
cross-border 
cable systems 

Obtain all required permits and 
align regulation deriving from 
concurrent jurisdiction over 
cross-border cable systems 

▪  Failure of developers to align planning 

across assets and countries: obtaining all 
required permits and aligning regulation is 
facilitated by continuous dialogue and early-
stage alignment  

Uncertainty about 
market 
arrangements 

Allow for commercial flows 
from the Dutch OWF to the 
Dutch market and from the UK 
OWF to the UK market 

▪  Uncertainty about responsibility and rules to 
provide access to maritime space for OWFs 
(tender design): aligned regulation of 
relevance to the OWF to be tendered needs 
to be reflected in the tender design 

▪  Uncertainty about hybrid cable system 

classification: allowing for only commercial 
flows from the Dutch OWF to the Dutch 
market and from the UK to the UK market 
implies defining the export cable systems as 
export cable systems with interconnector 
functionality  

▪  Uncertainty about applicable RES subsidy 

scheme: allowing for only commercial flows 
from the UK OWF to the UK market and 
from the Dutch OWF to the Dutch market fits 
the national subsidy schemes applying to 
the respective OWFs 

Uncertainty about 
hybrid cable 
system 
classification 

Define the export cable 
systems as export cable 
systems with interconnector 
functionality, which makes 
them hybrid cable systems, if it 
is not possible to define the 
Dutch export cable system as 
part of the Dutch national 
transmission system 

▪  Uncertainty about market arrangements: 
export cable systems with interconnector 
functionality fits the foreseen fixed access of 
OWFs to respective home markets 

▪  Uncertainty about applicable RES subsidy 

scheme: export cable systems with 
interconnector functionality fits the foreseen 
national subsidy schemes applying to the 
respective OWFs 

Failure of 
developers to 
align planning 
across assets and 
countries 

Facilitate continuous dialogue 
and early-stage alignment 
between the project 
developers 

▪  Uncertainty about responsibility for project 
development: continuous dialogue and 
early-stage alignment facilitates clear 
assignment of responsibility for 
development, construction and operation of 
interconnector 

▪  Uncertainty about regulation deriving from 

jurisdiction over cross-border cable systems: 

 
 
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Barrier 

Mitigation measure 

Interdependencies 

continuous dialogue and early-stage 
alignment facilitates obtaining all required 
permits and aligning regulation 

▪  Uncertainty about responsibility and rules to 
provide access to maritime space for OWFs 
(tender design): continuous dialogue and 
early-stage alignment are facilitated by an 
aligned tender design 

▪  Lack of regulated revenues for anticipatory 
investments: continuous dialogue and early-
stage alignment among developers is 
facilitated by validating the availability of 
regulated revenues for anticipatory 
investments in the UK and the Netherlands 

▪  Limited engagement of public stakeholders: 

continuous dialogue and early-stage 
alignment are facilitated by formalising 
public commitment and public funding for 
feasibility studies, R&D etc. 

Uncertainty about 
responsibility and 
rules to provide 
access to 
maritime space 
for OWFs (tender 
design) 

Implement a tender design 
with strict requirements which 
are aligned between the UK 
and the Netherlands 

▪  Uncertainty about regulation deriving from 

jurisdiction over cross-border cable systems: 
tender design needs to reflect aligned 
regulation relevant to the OWFs 

▪  Failure of developers to align planning 

across assets and countries: aligned tender 
designs are facilitated by continuous 
dialogue and early-stage alignment 

▪  Uncertainty about applicable RES subsidy 

scheme: implementing a tender design with 
strict requirements which are aligned 
between the UK and the Netherlands fits 
with applying the national RES subsidy 
schemes to the UK and Dutch OWF 
respectively  

Lack of regulated 
revenues for 
anticipatory 
investments 

Validate the feasibility of 
regulated revenues for 
anticipatory investment under 
the regulatory regimes in both 
the UK and the Netherlands 

▪  Failure of developers to align planning 

across assets and countries: certainty about 
regulated revenues for anticipatory 
investments in the UK and the Netherlands 
is facilitated by continuous dialogue and 
early-stage alignment 

 
 
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Barrier 

Mitigation measure 

Interdependencies 

Uncertainty about 
applicable RES 
subsidy scheme 

Apply the subsidy scheme of 
the Netherlands to the Dutch 
OWF and the UK subsidy 
scheme to the UK OWF 

▪  Uncertainty about market arrangements: the 
business case of the OWFs and thereby the 
level of required subsidies are affected by 
allowing for commercial flows from the UK 
OWF to the UK market and from the Dutch 
OWF to the Dutch market only 

▪  Uncertainty about hybrid cable system 
classification: the business case of the 
OWFs and thereby the level of required 
subsidies are affected by defining the export 
cable systems as export cable systems with 
interconnector functionality 

▪  Uncertainty about responsibility and rules to 
provide access to maritime space for OWFs 
(tender design): applying a UK and a Dutch 
RES subsidy scheme to the UK and Dutch 
OWF, respectively, fits with a tender design 
with strict requirements, which are aligned 
between the UK and the Netherlands 

Limited 
engagement of 
public 
stakeholders 

Formalise public commitment 
in the form of a project-specific 
MoU or HANSA. Also, facilitate 
feasibility studies and scoping 
studies for early-stage 
alignment through public 
funding, for example 

▪  Failure of developers to align planning 

across assets and countries: formalising 
public commitment and public funding for 
feasibility studies, R&D, etc. if facilitated by 
continuous dialogue and early-stage 
alignment  

Uncertainty 
regarding the UK 
market 

Await clarification of the future 
of UK policies and intended 
future interaction with the EU's 
internal energy market 

▪  No interdependencies to be considered 

Disproportionate 
allocation of costs 
and benefits 
across involved 
stakeholders 

Reallocate costs and benefits 
deriving from the hybrid project 
where required, based on a 
project-specific process 

▪  Uncertainty about responsibility for project 

development (responsibility for 
interconnector): costs and benefits deriving 
from mitigation to be considered 

▪  Uncertainty about market arrangements: 

costs and benefits deriving from mitigation 
to be considered 

▪  Uncertainty about hybrid cable system 

classification: costs and benefits deriving 
from mitigation to be considered 

 
 
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Barrier 

Mitigation measure 

Interdependencies 

▪  Lack of regulated revenues for anticipatory 
investments: costs and benefits deriving 
from mitigation to be considered 

▪  Uncertainty about applicable RES subsidy 
scheme: costs and benefits deriving from 
mitigation to be considered 

▪  Limited engagement of public stakeholders: 

costs and benefits deriving from mitigation 
to be considered 

Table 2: CGS IJmuiden Ver to Norfolk – Barriers, barrier mitigation measures and interdependencies 

Combining all the measures needed to mitigate the barriers of relevance to the CGS IJmuiden Ver to 
Norfolk hybrid project creates an Action Plan that supports the commencement of the development. 
In  addition  to  placing  the  required  actions  on  a  timeline,  the  Action  Plan  further  details  the 
stakeholders responsible for each of the actions (Figure 36). The Action Plan is intended to be used 
as a tool by stakeholders once the CGS IJmuiden Ver to Norfolk hybrid project has received the go-
ahead. 

 
 
 
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Figure 36: CGS IJmuiden Ver to Norfolk – Action Plan  

The barriers and mitigation measures specific to the CGS IJmuiden Ver to Norfolk hybrid project and 
the actions required to implement the identified mitigation measures are explained in more detail in 

201920202021Determine initial allocation of costs / benefitsAllVattenfall in the UK, TSOs, national ministries, NRAscosts andEnsure consideration of costs and benefits deriving from other barrier mitigationsAwait clarification of future of UK capacity market and UK cap and floor regimeAllocation ofAwait clarification of UK's future participation in internal energy marketIdentify relevant cost / benefit categoriesVattenfall in the UK, TSOs, NRAs, ECOWF developers, TSOs, national ministries, NRAs, ECValidate availability of CEF funding to ensure incentivisationUK marketVattenfall in the UK, TSOs, ECAlign and implement the type of formalisation of public commitmentNational ministries, NRAsSupport early-stage alignment among developers through public fundingVattenfall in the UK, TSOs, national ministries, NRAs, ECPublicengagementEnsure fair allocation of costs andbenefits across stakeholdersNational ministries, ECEnsure fair allocation of costs andbenefits across stakeholdersSupport de-risking of hybrid project by providing financial guaranteesOWF developers, national ministries, NRAsValidate compatibility of defining UK export cable system as a national transmission system (in line with EU law) with UK regulationBEIS, Ofgem in the UKIf required, adjust UK regulation to classify UK export cable system as a transmission systemBEIS, Ofgem in the UKValidate feasibility of commercial flows from OWFs to their respective home markets MoEA, ACM in the NLIf required, adjust the regulatory framework on a European levelApply for project-specific exemptions from European regulationsMoEA, ACM in the NLValidate compatibility of defining NL export cable system as a national transmission system (in line with EU law) with NL regulationEnsure fair allocation of costs andbenefits across stakeholdersVattenfall in the UK, TenneT TSO B.V. in the NL, ECNational ministries, NRAsAdjust OFTO regime in the UK to allow dual functionalityarrangementDevelop regional capacity calculation and allocation mechanism within framework of CACMHybridBEIS, Ofgem in the UKIf export cable systems not classifiedas transmission systems, adjust UK / NL regulations to allow for IC definitionEuropean institutionsIf compatible, validate fit of dual functionality of NL export cable system with NL regulationcable systemMoEA, ACM in the NLMoEA, ACM in the NLVattenfall in the UK, TSOs, national ministries, NRAsTSOs, national ministries, NRAsResponsibility1)If required, adjust NL regulation to classify NL export cable system as a transmission system and to allow dual functionalityclassificationIf not possible, define new hybrid asset class and develop new NL regulationTSOs, national ministries, NRAs, ECValidate whether no additional compensation for IC operator is requiredEngage in dialogue to achieve early-stage alignment reg. locations, routingand technical specifications of assetsTSOs, national ministries, NRAsTSOs, NRAsValidate feasibility of applying the national subsidy schemes to the respective OWFsValidate inclusion of anticipatory investments into Dutch Offshore Grid Development FrameworkAgree tender design with strict requirementsPlanning acrossEnsure fair allocation of costs andbenefits across stakeholdersVattenfall in the UK, TSOs, national ministries, NRAsinvestmentsAnticipatoryTenneTTSO B.V., MoEA, ACM in the NLNational ministries, ACM in the NL, other national authoritiesNational ministries, ACM in the NL, other national authoritiesAgree tender requirements considering the interests of the UK and the NLRES subsidiesassets andcountriesAccess toNational ministries, NRAsValidate efficiency of anticipatory investments under development build option in OFTOregimeVattenfall, Ofgem in the UKMarket Vattenfall in the UK, TSOs, national ministries, NRAsEnsure fair allocation of costs andbenefits across stakeholdersAlign operational rules across bordersDefine responsibility for operation of ICVattenfall in the UK, national ministries, NRAs, ECJurisdictionProjectClarify required permits under UK and Dutch regulationVattenfall in the UK, TenneT TSO B.V. in the NL,national ministriesVattenfall in the UK, TenneT TSO B.V. in the NL,national ministriesValidate whether responsibility for construction of IC lies with Vattenfall and TenneT TSO B.V.Ensure fair allocation of costs andbenefits across stakeholdersTSOs, national ministriesIf required, change national permit proceduresIf possible, implement a one-stop shop developmentresponsibilityVattenfall in the UK, TSOs, national ministries, NRAsNational ministries, NRAsClarify unbundling exemption for VattenfallNational ministriesAlignmentNational ministriesBarrierAlign and agree reallocation between developers and countriesOWF developers, TSOs, national ministries, NRAsbenefitsmaritime space1) Responsible stakeholders are OWF developers: Vattenfall in the UK and tbdin the NL; TSOs: tbdin the UK and TenneT TSO B.V. in the NL; Ministries: BEIS in the UK, MoEAin the NL; NRAs: Ofgem in the UK, ACM in the NL; Other national authorities: Crown Estate in the UK, RVOin the NL; European institutions: European Commission, European Parliament, European Council, European Court of Justice 
 
 
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the subchapters below. As part of the work on barrier mitigation, a project-specific Memorandum of 
Understanding (MoU) or a project-specific Hybrid Asset Network Support Agreement (HANSA) were 
considered. Both types of formal commitment to address barriers can include all actions for mitigation 
measures relevant to the CGS IJmuiden Ver to Norfolk hybrid project. Thus, it can be sufficient to set 
up only one type. 

Uncertainty about responsibility for project development 

Project-specific barrier evaluation: The definition of responsibility for the interconnector and for the 
grid  connections  of  the  OWFs  will  determine  who  is  responsible  for  the  development  of  the  CGS 
IJmuiden Ver to Norfolk hybrid project.  

One party is responsible for the development, construction and operation of the interconnector linking 
the  offshore  substation  of  the  export  cable  systems  of  the  UK  and  Dutch  OWF across  the  border 
between the UK and Dutch EEZ. The definition of which party is responsible for this is determined 
neither  by  European  law  nor  by  national  law  and  therefore  needs  to  be  aligned  between  project 
developers and other stakeholders. 

One OWF site is in the UK EEZ, where the OFTO regime applies for the grid connection based on 
UK law125. The other OWF site is in the Dutch EEZ, where TenneT TSO B.V. is generally responsible 
for the grid connection based on Dutch law.126 These responsibilities do not need to be reviewed. 
Thus, there is also no uncertainty regarding the applicability of UK and Dutch first connection charges 
(shallow approach in the UK and in the Netherlands) and G-charges (power-based G-charge in the 
UK and no G-charge in the Netherlands) for the respective UK and Dutch OWF.127 

Barrier mitigation: The mitigation option identified as  most feasible is to define a group of players, 
including  TenneT  TSO  B.V.  and  Vattenfall,  who  would  be  responsible  for  development  and 
construction of the interconnector. It also involves defining a group of players, potentially including 
TenneT TSO B.V. in collaboration with  Vattenfall or a UK interconnector developer, who would be 
the 
interconnector.  This 
responsible 
interdependencies shown in Table 2, interaction with project stakeholders (see Chapter  5.2.1) and 
the ease of implementation in terms of the required effort.  

is  based  on  consideration  of 

for  operation  of 

the 

For the development and construction of the interconnector, the mitigation options considered in this 
study were (1) to define TenneT TSO B.V., (2) to define TenneT TSO B.V. and Vattenfall, (3) to define 
TenneT TSO B.V. and an OFTO and (4) to define TenneT TSO B.V. and a UK interconnector as the 
parties responsible. For the operation of the interconnector, the mitigation options considered were 
(1) to define TenneT TSO B.V., (2) to define TenneT TSO B.V. and Vattenfall, (3) to define TenneT 
TSO B.V. and an OFTO and (4) to define TenneT TSO B.V. and a UK interconnector developer as 
the parties responsible.  

The mitigation options identified as most feasible for development and construction  – TenneT TSO 
B.V. and Vattenfall being responsible – and for operation – TenneT TSO B.V. being responsible in 

125 UK Electricity Act 2004. Section 6C (1). https://www.legislation.gov.uk/ukpga/2004/20/section/92 

126 Dutch Elektriciteitswet 1998. §4 Article 24Aa. https://wetten.overheid.nl/BWBR0009755/2018-07-
28#Hoofdstuk3_Paragraaf4_Artikel24Aa 

127 ENTSO-E. 2018. Overview of transmission tariffs in Europe: Synthesis 2018. 
https://docstore.entsoe.eu/Documents/MC%20documents/TTO_Synthesis_2018.pdf; 
The European Wind Energy Association. 2016. Position paper on network tariffs and grid 
connection regimes. http://www.ewea.org/fileadmin/files/library/publications/position-papers/EWEA-
position-paper-on-harmonised-transmission-tariffs-and-grid-connection-regimes.pdf 

 
 
                                                      
 
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collaboration  with  Vattenfall  or  a  UK  interconnector  developer  –  were  selected  for  the  following 
reasons: While Options (1) and (4) are covered under existing legislation and regulation, Option (2) 
and Option (3) are not. In Option (2), Vattenfall is not allowed to operate transmission assets due to 
EU  unbundling  regulation,  and  in  Option  (3),  an  OFTO  cannot  hold  both  a  transmission  and 
interconnector  licence. In general, the involvement of a UK entity, in the form of collaboration with 
either Vattenfall, an OFTO or a UK interconnector developer, has the advantage of providing further 
operational expertise. This is in addition to the operational expertise TenneT TSO B.V. has gained 
from  the  operation  of  the  BritNed  interconnector  (operated  together  with  National  Grid  Ventures). 
Except  for  Option  (1),  all  considered  mitigation  options  necessitate  additional  alignment  between 
TenneT TSO  B.V.  and  the  UK  entity  to  develop  and  construct  the  interconnector,  and  ensure  the 
efficient operation of the cable system. The continued collaboration between Vattenfall and TenneT 
TSO B.V. should be considered. This is because Vattenfall is likely to make use of the developer build 
option under the OFTO regime and can apply for an exemption from the unbundling regulation. 

Irrespective of which mitigation option is selected, this barrier is interdependent with the "failure of 
developers to align planning across assets and countries" barrier. Clearly defining responsibility for 
the  development  and  construction  as  well  as  operation  of  the  interconnector  requires  continuous 
dialogue and early-stage alignment on the hybrid project setup among the defined project promoters. 
Clearly  defined  responsibilities  and  continuous  dialogue  and  alignment,  in  turn,  allow  for  the 
commencement of project development. 

Actions and responsibilities for mitigation implementation: To implement this mitigation measure for 
the CGS IJmuiden Ver to Norfolk hybrid project, the following actions are required: 

▪  Based on the mitigation option of spreading responsibility for the interconnector over a group of 
the 
for 
players,  validate  whether  responsibility 
interconnector  lies  with  Vattenfall  and  TenneT  TSO  B.V.  With  regard  to  TenneT  TSO  B.V., 
validate whether the offshore TSO TenneT TSO B.V., as a separate legal entity from the onshore 
TSO,  is  responsible.128  Certainty  about  development  and  construction  responsibility  can  be 
achieved through voluntary cooperation between Vattenfall, TenneT TSO B.V. and the national 
ministries and NRAs (the BEIS and Ofgem in the UK and the MoEA and ACM in the Netherlands). 

the  development  and  construction  of 

▪  Clarify a potential unbundling exemption for Vattenfall,129 given that Vattenfall may participate in 
operation of the interconnector for the purpose of the hybrid project. This can be achieved through 
voluntary cooperation between  Vattenfall  and  the  national ministries and  NRAs (the BEIS and 
Ofgem in the UK as well as the MoEA and ACM in the Netherlands) as well as the European 
Commission. 

▪  Based on the mitigation option of spreading responsibility for the interconnector over a group of 
players, define who is responsible for operation of the interconnector. Options for the allocation 
of responsibilities include, for example, making TenneT TSO B.V. and Vattenfall or TenneT TSO 
B.V. and a UK interconnector developer responsible for operation.  Certainty about operational 
responsibility  can  be  achieved  through  voluntary  cooperation  between  TenneT  TSO  B.V.  and 

128 In the Netherlands, TenneT TSO B.V. holds the licenses needed to act as both onshore TSO 
and offshore TSO. Clarification is therefore needed whether the interconnector would be developed 
by the offshore or the onshore TSO. Formally, the two are separate grid operators with different 
regulatory frameworks for the different assets. So far, the initiative for interconnection development 
has been with the offshore TSO. 

129 Likely to be addressed by still to be adopted European Commission. 2018. COM 2016/861 final; 
REGULATION on the internal market for electricity. 
http://ec.europa.eu/transparency/regdoc/rep/1/2016/EN/COM-2016-861-F2-EN-MAIN-PART-1.PDF 

 
 
                                                      
 
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Vattenfall  or  a  UK  interconnector  developer,  as  well  as  the  national  ministries  and  NRAs  (the 
BEIS and Ofgem in the UK and the MoEA and ACM in the Netherlands). 

▪  Ensure  compatibility  with  the  measures  adopted  to  mitigate  the  barrier  "disproportionate 
allocation of costs and benefits across involved stakeholders". Do this through the fair reallocation 
among the UK and the Netherlands of costs and benefits deriving from shared responsibility for 
the  interconnector.  Certainty  about  the  allocation  of  costs  and  benefits  can  be  achieved  by 
addressing this issue as part of the project-specific HANSA between the UK and the Netherlands. 
TenneT  TSO  B.V.  and  Vattenfall  or  a  UK  interconnector  developer,  as  well  as  the  national 
ministries and NRAs (the BEIS and Ofgem in the UK and the MoEA and ACM in the Netherlands) 
assume responsibility for this action. 

The  barrier,  its  mitigation  and  the  actions  required  to  implement  the  mitigation  are  summarised  in 
Figure  37.  The  actions  required  to  implement  the  mitigation  measure  and  the  stakeholders 
responsible for the individual actions are summarised across barriers in Figure 36.  

Figure 37: CGS IJmuiden Ver to Norfolk barrier mitigation – Uncertainty about responsibility for project 
development 

Uncertainty about regulation deriving from jurisdiction over cross-border cable systems 

Project-specific barrier evaluation: The OWFs included in the  CGS IJmuiden Ver to Norfolk  hybrid 
project idea are located in the UK and the Dutch EEZ. As the OWFs serve to exploit marine resources 
within the UK and the Dutch EEZs, the UK and the Netherlands have jurisdiction over the respective 
OWF  installations.  The  corresponding  export  cable  systems  belonging  to  the  OWFs  have  their 
onshore connection points in the UK and the Netherlands. They therefore do not cross the border 
between the UK and the Dutch EEZ. Thus, the UK and the Netherlands have jurisdiction over the 
respective export cable systems. 

The interconnector has its connection points at the offshore substations of the export cable system 
of the UK OWF and the Dutch OWF and therefore crosses the UK EEZ and the Dutch EEZ. Both the 
UK and the Netherlands have jurisdiction over the cable and can determine applicable regulations. 
Thus, the jurisdiction over the interconnector might be concurrent and the regulations applicable to 
the interconnector derived from UK and from Dutch jurisdiction might contradict each other. 

Barrier mitigation: The mitigation option identified as most feasible is to obtain all required permits 
and to align regulation deriving from concurrent jurisdiction over  the  operation  of  the cross-border 
cable  system  between 
the 
interdependencies shown in Table 2, interaction with project stakeholders (see Chapter 5.2.2) and 
the ease of implementation in terms of the required effort. 

is  based  on  consideration  of 

involved.  This 

the  countries 

Uncertainty about responsibility for project development>Assign responsibility for interconnector to group of players>Validate whether responsibility for construction of IC lies with Vattenfall and TenneT TSO B.V.>Clarify unbundling exemption for Vattenfall>Define responsibility for operation of IC>Ensure fair allocation of costs and benefits across stakeholdersBarrierMitigation measureActions 
 
 
 
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The  other  mitigation  options  besides  aligning  regulation  deriving  from  concurrent  jurisdiction 
considered in this study were (1) to define regulation deriving from UK jurisdiction as applicable to the 
interconnector  during  operations,  and  (2)  to  define  regulation  deriving  from  Dutch  jurisdiction  as 
applicable.  

The mitigation option identified as most feasible was selected for the following reasons: No regulation 
deriving either from UK or Dutch jurisdiction is immediately applicable to all the maritime zones that 
the  interconnector  crosses.  Therefore,  alignment  between  the  countries  is  necessary.  While  the 
chances of the UK and the Netherlands agreeing on a single jurisdiction are limited, the alignment of 
rules  deriving  from  two  jurisdictions  can  be  a  lengthy  process.  On  the  other  hand,  the  selected 
mitigation  option  reflects  the  interests  of  both  countries  in  alignment  and  can  potentially  build  on 
existing agreements established for interconnectors between the UK and the Netherlands, such as 
BritNed. 

Regarding interdependencies, this barrier is interdependent with the barriers "failure of developers to 
align planning across assets and countries" and "uncertainty about responsibility and rules to provide 
access  to  maritime  space  for  OWFs  (tender  design)".  Obtaining  all  required  permits  and  aligning 
regulation is facilitated by continuous dialogue and early-stage alignment. Furthermore, the aligned 
operational regulation needs to be reflected in the requirements of the OWF tender. 

Actions and responsibilities for mitigation implementation: To implement this mitigation measure for 
the CGS IJmuiden Ver to Norfolk hybrid project, the following actions are required: 

▪  For development and construction, clarify the permits  needed for the interconnector under UK 
and  Dutch  regulations.  Compliance  with  the  environmental  and  technical  rules  under  UK  and 
Dutch  regulations  can  be  ensured  by  obtaining  these  permits.  This  can  be  achieved  through 
voluntary cooperation between TenneT TSO B.V. (and a potential UK interconnector developer) 
and the national ministries (the BEIS, supported by the Marine Management Organisation and 
The Crown Estate, in the UK and the MoEA, supported by the Ministry of Infrastructure and Water 
Management, in the Netherlands). 

▪ 

If possible, implement a one-stop shop on the national level to allow for a coordinated process 
with only one permit required for the interconnector. As stipulated in Regulation (EU) 347/2013130, 
a  one-stop  shop  in  terms  of  a  competent  authority  that  integrates  or  coordinates  all  permit 
granting  processes  should  reduce  process  complexity,  as  well  as  increase  efficiency  and 
transparency.  The  scope  of  a  one-stop  shop  could  be  extended  to  provide  a  consolidated 
database  of environmental data, facilitating easy  data exchange between countries.  However, 
the  longer-term  benefits  are  accompanied  by  significant  shorter-term  setup  costs.  So,  the 
feasibility of implementing this action in the scope of mitigating barriers to the IJmuiden Ver to UK 
hybrid project is questionable. Certainty about the implementation can be achieved by addressing 
this issue as part of the project-specific HANSA between the UK and the Netherlands, if feasible. 
The national ministries would assume responsibility for this action (the BEIS, supported by the 
Environment Agency, in the UK and the MoEA, supported by the Ministry of Infrastructure and 
Water Management, in the Netherlands).  

▪ 

If required, change the national permit procedures for the specific hybrid project. Guidance from 
project-specific  developers  in  the  form  of  an  inventory  of  environmental  and  technical  rules  is 
required to inform changes to the permit procedures. Certainty about changes can be achieved 

130 European Parliament, European Council. 2013. REGULATION (EU) No. 347/2013 on guidelines 
for trans-European energy infrastructure. (29). https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:32013R0347&from=en 

 
 
                                                      
 
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by  addressing  this  issue  as  part  of  the  project-specific  HANSA  between  the  UK  and  the 
Netherlands.  The  national  ministries  would  assume  responsibility  for  this  action  (the  BEIS, 
supported by the Marine Management Office and the  Environment Agency, in the UK and the 
MoEA, supported by the Ministry of Infrastructure and Water Management, in the Netherlands).  

▪  For  the  operational  phase,  align  the  applicable  national  regulations  arising  from  concurrent 
jurisdiction for the specific hybrid  project. The required alignment may concern  liability issues, 
control  system  operations  (voltage  levels,  grid  synchronisation  etc.)  and  matters  discussed  in 
relation to other barriers. Also consider existing national and EU legal frameworks such as the 
System  Operations  regulation  (Regulation  (EU)  2017/1485)131  and  the  CACM  regulation 
(Regulation (EU) 2015/1222).132 Guidance from project-specific developers is required to inform 
the alignment. Certainty about the alignment of operational rules can be achieved by addressing 
this  issue  as  part  of  the  project-specific  HANSA  between  the  UK  and  the  Netherlands.  The 
national ministries and NRAs assume responsibility for this action (the BEIS and Ofgem in the 
UK and the MoEA and ACM in the Netherlands). 

The  barrier,  its  mitigation  and  the  actions  required  to  implement  the  mitigation  are  summarised  in 
Figure  38.  The  actions  required  to  implement  the  mitigation  measure  and  the  stakeholders 
responsible for the individual actions are summarised across barriers in Figure 36.  

Figure 38: CGS IJmuiden Ver to Norfolk barrier mitigation – Uncertainty about regulation deriving from 
jurisdiction over cross-border cable systems 

Uncertainty about market arrangements 

Project-specific barrier evaluation: Clarification of commercial flows is required as the potential OWF 
sites of the CGS IJmuiden Ver to Norfolk hybrid project are located in the UK and the Dutch EEZ, 
with onshore grid connection points in both the UK and the Netherlands. Thus, commercial flows of 
both  OWFs  to  both  the  UK  and  the  Dutch  market  are  possible.  Commercial  flows  for  the  OWFs 
included in the hybrid project must therefore be clarified. 

Barrier mitigation: The mitigation option identified as most feasible is to allow commercial flows only 
from the UK OWF to the UK market, and from the Dutch OWF to the Dutch market. Therefore, only 
leftover capacities are available for interconnection and the OWFs can transmit their electricity to the 

131 European Commission. 2017. COMMISSION REGULATION (EU) 2017/1485 establishing a 
guideline on electricity transmission system operation. https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:32017R1485&from=DE 

132 European Commission. 2015. COMMISSION REGULATION (EU) 2015/1222 establishing a 
guideline on capacity allocation and congestion management. https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:32015R1222&from=EN 

Uncertainty about regulation deriving from jurisdiction over cross-border cable systems>Obtain required permits for development and construction of interconnector>Align rules and regulations for operation of interconnector>Clarify required permits>If possible, implement a one-stop shop>If required, change national permit procedures>Align applicable national regulations (operational rules)BarrierMitigation measureActions 
 
 
 
                                                      
 
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respective  national  markets  with  priority.  This  is  based  on  consideration  of  the  interdependencies 
shown in Table 2 and the ease of implementation in terms of the required effort. 

Since this market arrangement was identified as most feasible in interaction with project stakeholders 
from the beginning, no other mitigation options were considered in detail. 

Regarding  interdependencies,  this  barrier  is  interdependent  with  the  barriers  "uncertainty  about 
hybrid cable system classification" and "uncertainty about applicable RES subsidy scheme". Efficient 
commercial flows from only the UK OWF to the UK market and from only the Dutch OWF to the Dutch 
market  imply  defining  the  export  cable  systems  as  export  cable  systems  with  interconnector 
functionality. In addition, such a definition may affect the business case of the OWFs included in the 
hybrid project and thereby potentially the level of required subsidies. 

Action and responsibilities for mitigation implementation: To implement this mitigation measure for 
the CGS IJmuiden Ver to Norfolk hybrid project, the following actions are required: 

▪  Validate the feasibility of defining the market arrangement as commercial flows from the OWFs 
included in the hybrid project to their respective home markets only. This can be achieved through 
voluntary cooperation between the TSOs, national ministries and NRAs (the BEIS and Ofgem in 
the UK, and TenneT TSO B.V., the MoEA and ACM in the Netherlands). 

Ensure  compatibility  with  measures  adopted  to  mitigate  the  barrier  "disproportionate  allocation  of 
costs and benefits across involved stakeholders". Do this through the fair reallocation among the UK 
and the Netherlands of costs and benefits deriving from the market arrangement. Certainty about the 
allocation of costs and benefits can be achieved by addressing this issue as part of the project-specific 
HANSA between the UK and the Netherlands. Project developers, the national ministries and NRAs 
assume responsibility for this action (Vattenfall, the BEIS and Ofgem in the UK, and TenneT TSO 
B.V., the MoEA and ACM in the Netherlands).The barrier, its mitigation and the actions required to 
implement  the  mitigation  are  summarised  in  Figure  39.  The  actions  required  to  implement  the 
mitigation  measure  and  the  stakeholders  responsible  for  the  individual  actions  are  summarised 
across barriers in Figure 36. 

Figure 39: CGS IJmuiden Ver to Norfolk barrier mitigation – Uncertainty about market arrangements 

Uncertainty about hybrid cable system classification 

Project-specific barrier evaluation: The export cable systems included in the CGS IJmuiden Ver to 
Norfolk  hybrid  project  function  as  hybrid  cable  systems,  as  they  serve  two  distinct  and  legally 
differentiated functions. According to Regulation (EC) 714/2009,133 an interconnector is defined as "a 
transmission line which crosses or spans a border between Member States and which connects the 
national transmission systems of the Member States." A conventional export cable system provides 

133 European Parliament, European Council. 2009. REGULATION (EC) No. 714/2009 on conditions 
for access to the network for cross-border exchanges in electricity. Article 2 (1). https://eur-
lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32009R0714&from=EN 

Uncertainty about market arrangements>Establish commercial flows from UK OWF to UK bidding zone and from Dutch OWF to Dutch bidding zone>Validate feasibility of commercial flows from OWFs to their respective home markets >Ensure fair allocation of costs and benefits across stakeholdersBarrierMitigation measureActions 
 
 
 
                                                      
 
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for  the  transmission  of  electricity  generated  by  the  OWF  to  an  onshore  connection  point  without 
crossing  borders.  In  the  hybrid  setup,  the  export  cable  systems  provide  for  the  transmission  of 
electricity  generated  by  the  OWFs  to  shores  and  market-to-market  flows.  Such  dual  functionality 
prevents a straight-forward classification of the cable systems under EU and national legislation and 
regulations as either export cable systems or interconnectors. 

The interconnector included in the hybrid project, meaning the cable connection between the offshore 
substation of the export cable systems of the UK OWF and the Dutch OWF, functions solely as an 
interconnector. This is because the UK OWF transmits electricity only to the UK market and the Dutch 
OWF  only  to  the  Dutch  market  (in  the  market  arrangement  foreseen  by  the  project  developers). 
However, this definition is based on the assumption that a cable system which does not connect two 
national transmission systems can still be defined as an interconnector when one end is connected 
to the offshore substation of the UK export cable system and the other end is connected to the Dutch 
export cable system. 

Barrier  mitigation:  The  mitigation  option  identified  as  most  feasible  is  to  define  the  export  cable 
systems as export cable systems with interconnector functionality. This effectively makes export cable 
systems hybrid cable systems. Thus, the transmission of power generated by the OWFs has priority 
regarding  access  to  the  capacity  of  the  cable  systems  and  only  leftover  capacity  is  available  for 
interconnection. This is based on consideration of the interdependencies shown in Table 2, interaction 
with project stakeholders (see Chapter 5.2.4) and the ease of implementation in terms of the required 
effort. 

The other mitigation option considered in this study was to define the UK and the Dutch export cable 
systems as interconnectors with export cable functionality for leftover capacities.  

The  mitigation  option  identified  as  most  feasible  was  selected  for  the  following  reasons:  Neither 
mitigation option is covered under UK law, since OFTO transmission licenses do not allow for market-
to-market  flows.  Nor  can  OFTO  transmission  licenses  and  interconnector  licenses  be  held  by  the 
same  party.  In  the  Netherlands,  it  is  questionable  whether  the  two  mitigation  options  are  covered 
under Dutch regulation, as it does not expressly prohibit the dual functionality of a cable system. From 
a  European  perspective,  however,  existing  regulations  and  exemptions  do  not  cover  hybrid  cable 
systems. Alternatively, adjustments may be required for both options. Thus, the mitigation option was 
selected due to its interdependencies with other barriers, as explained below.  

Regarding  interdependencies,  this  barrier  is  interdependent  with  the  barriers  "uncertainty  about 
market arrangements" and "uncertainty about applicable RES subsidy scheme". Defining the export 
cable systems as export cable systems with interconnector functionality for leftover capacities fits the 
envisaged market arrangement and RES subsidy schemes. This is because it gives the UK and Dutch 
OWFs priority access to the capacity of the UK and Dutch export cable system for the transmission 
of generated electricity to the UK and Dutch markets. As a consequence, the selected classification 
of the export cable systems has no impact on the business case of the OWFs included in the hybrid 
project.  But  it  does  impact  on  the  business  case  of  the  interconnector  when  compared  to  a 
conventional point-to-point  interconnector. Therefore, the  need for additional compensation for the 
interconnector  operator  must  be  assessed.  Furthermore,  the  European  energy  policy  targets  of 
diversifying and integrating RES, as well as reducing greenhouse gas emissions, are prioritised when 
defining the export cable systems as export cable systems whose leftover capacities are available for 
interconnection. 

Actions and responsibilities for mitigation implementation: To implement this mitigation measure for 
the CGS IJmuiden Ver to Norfolk hybrid project, the following actions are required: 

 
 
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▪  Validate whether defining the Dutch  export cable system as a national transmission system in 
line with the definition in EU legislation and regulations complies with Dutch regulations.134 This 
is  required  to  allow  the  cable  system  between  the  offshore  substations  of  the  export  cable 
systems of the UK and Dutch OWFs to be defined as an interconnector within the meaning of EU 
regulations. In addition, validate that an export cable system defined as a national transmission 
system  is,  under  Dutch  regulations,  legally  allowed  to  provide  for  both  the  transmission  of 
electricity from the Dutch OWF and interconnection flows. Lastly, assess whether TenneT TSO 
B.V., as an offshore grid operator, should be allowed to develop interconnection capacity (due to 
the leftover capacity on the export cable system being available for interconnection) for which it 
currently  needs  an  explicit  mandate  from  the  MoEA.  This  can  be  achieved  through  voluntary 
cooperation between the MoEA and ACM in the Netherlands, initiated by TenneT TSO B.V. 

▪ 

If required, preferably adjust Dutch regulations for the specific hybrid project to classify the export 
cable  system  as  a  national  transmission  system.  This  should  allow  both  the  transmission  of 
electricity from the OWF and interconnection flows. If this is not possible, allow the same dual 
functionality by defining a new hybrid asset class and developing new regulation for that  asset 
class. Guidance from project-specific developers is required to inform the adjustment of Dutch 
regulation.  Certainty  about  changes  can  be  achieved  by  addressing  this  issue  as  part  of  the 
project-specific  HANSA  between  the  UK  and  the  Netherlands.  The  MoEA  and  ACM  in  the 
Netherlands assume responsibility for this action. 

▪  Validate whether defining the UK export cable system as a national transmission system in line 
with the definition in EU legislation and regulations complies with UK regulations. This is required 
to allow the cable system between the offshore substations of the export cable systems of the 
UK and Dutch OWFs to be defined as an interconnector within the meaning of EU regulations. 
This can be achieved through  voluntary cooperation  between the BEIS and Ofgem in the UK, 
initiated by Vattenfall. 

▪ 

▪ 

If required, adjust UK regulation to classify the export cable system as a national transmission 
system. In addition, adjust the UK OFTO regime such that OFTO and / or interconnector licences 
allow the dual functionality of assets.135 Guidance from project-specific developers is required to 
inform  the  adjustment  of  the  UK  OFTO  regime.  Certainty  about  changes  can  be  achieved  by 
addressing this issue as part of the project-specific HANSA between the UK and the Netherlands. 
The BEIS and Ofgem in the UK assume responsibility for this action. 

If required, adjust UK and Dutch regulations for the specific hybrid project to change the definition 
of  an  interconnector.  Despite  the  fact  the  cable  system  does  not  connect  two  national 
transmission  systems,  this  would  this  would  allow  the  cable  system  between  the  offshore 
substation of the UK export cable and the offshore substation of the Dutch export cable system 
to be defined as an interconnector. Certainty about changes can be achieved by addressing this 
issue as part of the project-specific HANSA between the UK and the Netherlands. The national 
ministries and NRAs assume responsibility for this action (the BEIS and Ofgem in the UK and the 
MoEA and ACM in the Netherlands). 

134 Dutch Elektriciteitswet 1998. §1 Article 15a. https://wetten.overheid.nl/BWBR0009755/2018-07-
28#Hoofdstuk3_Paragraaf1_Artikel15a 
Dutch Elektriciteitswet 1998. §1 Article 1 (as). https://wetten.overheid.nl/BWBR0009755/2018-07-
28#Hoofdstuk1_Paragraaf1_Artikel1 

135 UK Electricity Act 1989. Section 6 (1)(b) and (e), (2A). 
https://www.legislation.gov.uk/ukpga/1989/29/contents 

 
 
                                                      
 
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▪  On  a  European  level,  apply  for  project-specific  exemptions  from  existing  European  regulation 
based  on  the  pilot  character  of  the  hybrid  project.  One  exemption  could  possibly  concern  the 
definition  of  a  cable  system  as  an  interconnector  which  does  not  connect  two  national 
transmission  systems.  Another  could  possibly  concern  the  EU's  requirement  to  make  the 
maximum  capacity  of  interconnectors  available  for  access  by  third  parties.136  Vattenfall  and 
TenneT TSO B.V. can initiate this and achieve it through voluntary cooperation between them 
and the European Commission. 

▪ 

If required, adjust the EU's regulatory framework so it facilitates hybrid project development. For 
example, incorporate a hybrid cable system definition in Regulation (EC) 714/2009137. Also, clarify 
how  the  hybrid  project’s  requirements  fit  with  the  stipulation  of  free  usage  of  the  "maximum 
capacity"  of  interconnectors  by  third  parties.  Guidance  from  project-specific  developers  is 
required to inform the adjustment of the existing regulatory framework. Initiated by EU Member 
States, this can be achieved through the harmonisation of the EU's regulatory framework by the 
European  Commission,  the  European  Parliament  and  the  European  Council.  The  European 
Court  of  Justice,  which  interprets  and  clarifies  existing  European  law,138  may  need  to  clarify 
"maximum capacity" in this context. 

▪  Develop a regional capacity calculation and allocation mechanism that accounts for the hybrid 
cable  system  classification  (export  cable  systems  with  interconnector  functionality)  within  the 
framework of the existing CACM regulation (Regulation (EU) 2015/1222).139 This can be achieved 
through voluntary cooperation between TenneT TSO B.V. (and a potential third party in the UK) 
and NRAs (Ofgem in the UK and ACM in the Netherlands). 

▪  Validate whether no additional compensation for the interconnector operator is required, as the 
interconnector  is  developed  as  part  of  the  hybrid  project  with  a  subsidiary  purpose  from  the 
beginning.  However,  the  OWF  developer  is  compensated  through  a  RES  subsidy  scheme  by 
bidding for the required subsidy level in a competitive process. For this, the OWF developer needs 
clarity on the market conditions applicable to the OWF in the future. The former can be achieved 
through voluntary cooperation between TenneT TSO B.V. (and a potential third party in the UK), 
national ministries and NRAs (the BEIS and Ofgem in the UK, and the MoEA and ACM in the 
Netherlands), as well as the European Commission. 

▪  Ensure compatibility with measures adopted to mitigate the barrier "disproportionate allocation of 
costs and benefits across involved stakeholders". Do this through the fair reallocation among the 
UK and the Netherlands of costs and benefits deriving from the hybrid cable system classification. 
Certainty about the allocation of costs and benefits can be achieved by addressing this issue as 
part of the project-specific HANSA between the UK and the Netherlands. TenneT TSO B.V. (and 

136 European Parliament, European Council. 2009. REGULATION (EC) No. 714/2009 on conditions 
for access to the network for cross-border exchanges in electricity. https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:32009R0714&from=EN 

137 European Parliament, European Council. 2009. REGULATION (EC) No. 714/2009 on conditions 
for access to the network for cross-border exchanges in electricity. https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:32009R0714&from=EN 

138 European Commission. 2018. Court of Justice of the European Union (CJEU). 
https://europa.eu/european-union/about-eu/institutions-bodies/court-justice_en 

139 European Commission. 2015. COMMISSION REGULATION (EU) 2015/1222 establishing a 
guideline on capacity allocation and congestion management. https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:32015R1222&from=EN 

 
 
                                                      
 
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a potential third party in the UK) as well as national ministries and NRAs (the BEIS and Ofgem in 
the UK as well as the MoEA and ACM in the Netherlands) assume responsibility for this action. 

The  barrier,  its  mitigation  and  the  actions  required  to  implement  the  mitigation  are  summarised  in 
Figure  40.  The  actions  required  to  implement  the  mitigation  measure  and  the  stakeholders 
responsible for the individual actions are summarised across barriers in Figure 36.  

Figure 40: CGS IJmuiden Ver to Norfolk barrier mitigation – Uncertainty about hybrid cable system 
classification 

Failure of developers to align planning across assets and countries 

Project-specific  barrier  evaluation:  Several  factors  make  the  CGS  IJmuiden  Ver  to  Norfolk  hybrid 
project complex. These are the inclusion of a UK OWF, a Dutch OWF, an export cable system to the 
UK market and one to the Dutch market, and an interconnector linking the offshore substations of the 

Mitigation measureUncertainty about hybrid cable system classification>Define the Dutch export cable system as an export cable system with interconnector functionality, which makes it a hybrid cable system, provided that defining the Dutch export cable system as part of the Dutch national transmission system is not possible>Define the UK export cable system as an export cable system with interconnector functionality>Validate compatibility of defining NL export cable system as a national transmission system (in line with EU law) with NL regulat.>If compatible, validate fit of dual functionality of NL export cable system with NL regulation>If required, adjust NL regulation to classify NL export cable system as a transmission system and to allow dual functionality>If not possible, define new hybrid asset class and develop new NL regulation>Validate compatibility of defining UK export cable system as a national transmission system (in line with EU law) with UK regulat.>If required, adjust UK regulation to classify UK export cable system as a transmission system >Adjust the UK OFTO regime to allow dual functionality >If export cable systems are not classified as transmission systems, adjust UK / NL regulation to allow IC definition >Apply for project-specific exemptions from EU regulations>If required, adjust regulatory framework on European level >Develop regional capacity calculation, allocation mechanism>Validate whether no additional compensation for IC operator is required>Ensure fair allocation of costs and benefits across stakeholdersBarrierActions 
 
 
 
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export cable systems of the UK OWF and the Dutch OWF. As all five assets have separate permit, 
development and construction timelines, geographical alignment is crucial. For example, the locations 
of the offshore substations of the export cable systems in the UK and the Netherlands must align with 
the route for the interconnector so the interconnector can be added later. The UK OWF has been 
tendered  but can still  consider an  interconnector route, as the permits for the assets have not  yet 
been finalised. The Dutch OWF in the IJmuiden Ver area is yet to be tendered, with the possibility of 
considering an interconnector route in the subsequent permit procedures. In addition, interoperability 
between  the  different  components  of  the  five  assets  must  be  ensured  based  on  the  alignment  of 
technical specifications to enable the hybrid project to function. 

Barrier mitigation: The mitigation option identified as most feasible is to facilitate continuous dialogue 
and early-stage alignment between the project developers. Given that the UK and Dutch authorities 
respectively determine the location of the UK OWF and the Dutch OWF, project developers need to 
align on the following: the routing of the cable systems, the location of substations and the technical 
specifications of the cable systems, the substations and the OWFs included in the hybrid project. This 
is  based  on  consideration  of  the  interdependencies  shown  in  Table  2,  interaction  with  project 
stakeholders (see Chapter 5.2.5) and the ease of implementation in terms of the required effort. 

Apart from continuous dialogue and early-stage alignment between the project developers, no other 
mitigation options were considered.  

Regarding  interdependencies,  this  barrier  is  interdependent  with  the  following  four  barriers: 
"uncertainty about responsibility for project development"; "uncertainty about regulation deriving from 
jurisdiction over cross-border cable systems"; "uncertainty about responsibility and rules to provide 
access to maritime space for OWFs (tender design)"; the "lack of regulated revenues for anticipatory 
investments" and the "limited engagement of public stakeholders". Continuous dialogue and early-
stage  alignment  are  complemented  by  clearly  defining  who  is  responsible  for  development, 
construction and operation of the interconnector as well as the need to obtain all relevant permits and 
align  regulation.  However,  dialogue  and  alignment  themselves  are  supported  by  the  following 
measures  to  mitigate  other  barriers.  An  aligned  tender  design  allows  for  the  involvement  of  and 
coordination with the developer of the OWF included in the hybrid project. Two factors allow for such 
alignment  by  decreasing  the  risk  to  hybrid  project  development  arising  from  early-stage  project-
specific decisions: certainty about the availability of regulated revenues for anticipatory investments; 
and a formalised public commitment and public financial support. 

Action and responsibilities for mitigation implementation: To implement this mitigation measure for 
the CGS IJmuiden Ver to Norfolk hybrid project, the following action is required: 

▪  Engage in a continuous dialogue to achieve early-stage alignment regarding the locations, routing 
and  technical  specifications  for  the  individual  assets.  This  can  be  achieved  through  voluntary 
cooperation between Vattenfall and TenneT TSO B.V. (and a potential third party in the UK) and 
the national ministries and NRAs (the BEIS, supported by The Crown Estate and Ofgem, in the 
UK, and the MoEA, supported by RVO and ACM, in the Netherlands). 

The  barrier,  its  mitigation  and  the  actions  required  to  implement  the  mitigation  are  summarised  in 
Figure  41.  The  actions  required  to  implement  the  mitigation  measure  and  the  stakeholders 
responsible for the individual actions are summarised across barriers in Figure 36. 

 
 
 
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Figure 41: CGS IJmuiden Ver to Norfolk barrier mitigation – Failure of developers to align planning across 
assets and countries 

Uncertainty about responsibility and rules to provide access to maritime space for OWFs 
(tender design) 

Project-specific barrier evaluation: A suitable tender design needs to be chosen for the CGS IJmuiden 
Ver to Norfolk hybrid project. The OWFs included in the project setup are located in the UK and the 
Dutch EEZ and the offshore substations of their export cable systems are linked via an interconnector. 
Thus, both the UK and the Netherlands have an interest in defining the requirements  for the OWF 
development in accordance with their respective standards. These may be contradictory. In addition, 
the  tender  designs  need  to  ensure  that  tender  candidates  can  realistically  develop  the  OWF.  In 
consequence, the tender design must clarify which hybrid-specific requirements to include.  

Barrier mitigation: The mitigation option identified as most feasible is to implement a tender design 
with strict tender requirements. These should be aligned between the UK and the Netherlands and 
also eliminate all hybrid-specific uncertainties for the OWF developers. This is based on consideration 
of the interdependencies shown in Table 2, interaction with project stakeholders (see Chapter 5.2.7) 
and the ease of implementation in terms of the required effort 

The  other  mitigation  options  considered  in  this  study  were  (1)  to  have  a  strict  tender  design  with 
requirements  aligned  among  the  stakeholders,  (2)  to  have  a  strict  tender  design  without  hybrid-
specific uncertainties for the OWF developer and (3) to have a lenient tender design with requirements 
aligned among the stakeholders and without hybrid-specific uncertainties for the OWF developer.  

The mitigation option identified as most feasible was selected for the following reasons: While aligned 
requirements  potentially  necessitate  amendments  to  national  legislation  and  regulations,  both 
countries have valid interests in defining certain requirements for the tenders. Aligned requirements 
also aid in ensuring the interoperability of the OWFs with the other assets of the hybrid project. These 
factors increase the probability of successful hybrid project implementation. Furthermore, a tender 
design with strict requirements also increases the probability of successful project implementation, 
allowing for a possible decrease in the cost efficiency of the OWF development due to more limited 
competition. Lastly, certainty about hybrid-specific characteristics of the OWF development increases 
the probability of successful project implementation – and decreases the cost of implementation – by 
reducing the risk premium otherwise demanded by OWF developers in terms of subsidies. 

Regarding  interdependencies,  this  barrier  is  interdependent  with  the  following  three  barriers: 
"uncertainty about regulation deriving from jurisdiction over cross-border cable systems"; the "failure 
of developers to align planning across assets and countries"; and "uncertainty about applicable RES 
subsidy scheme". Aligned regulation deriving from UK and Dutch jurisdiction needs to be reflected in 
the  requirements  of  the  OWF  tenders.  In  addition,  the  OWF  tenders  can  include  a  RES  subsidy 
scheme established  by  the UK and the Netherlands,  respectively. Continuous  dialogue  and  early-
stage alignment facilitate aligned tender designs. 

Actions and responsibilities for mitigation implementation: To implement this mitigation measure for 
the CGS IJmuiden Ver to Norfolk hybrid project, the following actions are required: 

Failure of developers to align planning across assets and countries>Facilitate continuous dialogue and early-stage alignment between project developers>Engage in dialogue to achieve early-stage alignment regarding locations, routing and technical specifications of assetsBarrierMitigation measureActions 
 
 
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▪  Agree a tender design with strict requirements. Certainty about the tender design can be achieved 
by  addressing  this  issue  as  part  of  the  project-specific  HANSA  between  the  UK  and  the 
Netherlands. The national ministries and other national authorities assume responsibility for this 
action  (the  BEIS  and  The  Crown  Estate  in  the  UK,  and  the  MoEA,  ACM  and  RVO  in  the 
Netherlands). 

▪  Agree  tender  requirements  which  take  account  of  the  valid  interests  of  the  UK  and  the 
Netherlands. This means jointly defining material requirements such as technical and operational 
standards.  Environmental  standards  do  not  need  to  be  aligned  between  the  UK  and  the 
Netherlands,  as  national  environmental  standards  apply  to  the  respective  OWFs.  Similarly, 
financial requirements do not need to be aligned across countries. Guidance from project-specific 
developers  is  required  to  inform  the  development  of  project-specific  tender  requirements. 
Certainty  about  tender  requirements  can  be  achieved  by  addressing  this  issue  as  part  of  the 
project-specific HANSA between the UK and the Netherlands. The national ministries and other 
national authorities assume responsibility for this action (the BEIS and The Crown Estate in the 
UK, and the MoEA, ACM and RVO in the Netherlands). 

The  barrier,  its  mitigation  and  the  actions  required  to  implement  the  mitigation  are  summarised  in 
Figure  42.  The  actions  required  to  implement  the  mitigation  measure  and  the  stakeholders 
responsible for the individual actions are summarised across barriers in Figure 36. 

Figure 42: CGS IJmuiden Ver to Norfolk barrier mitigation – Uncertainty about responsibility and rules to 
provide access to maritime space for OWFs (tender design) 

Lack of regulated revenues for anticipatory investments 

Project-specific  barrier  evaluation:  Anticipatory  investments  are  necessary  to  allow  for  the 
implementation of the CGS IJmuiden Ver to Norfolk hybrid project. As the interconnector establishes 
a link between the offshore substations of the export cable systems of the UK OWF and the Dutch 
OWF, it is necessary to adapt the technical setup of the substations to support the interconnector link. 
These  adaptations  represent  additional  costs  for  the  developers  of  the  substations  –  that  is,  for 
Vattenfall  in  the  UK  and  for  TenneT  TSO  B.V.  in  the  Netherlands.  This  necessitates  additional 
investments  in  anticipation  of  the  interconnector  link.  As  any  investments  in  grid  infrastructure 
deemed inefficient by regulators are not compensated,140 the additional costs developers face may 
present an obstacle to hybrid project development. 

Barrier mitigation: The mitigation identified as most feasible is to validate the feasibility of regulated 
revenues  for  the  anticipatory  investments  under  the  regulatory  regimes  in  both  the  UK  and  the 
Netherlands. This is based on consideration of the interdependencies shown in Table 2, interaction 

140 ACER. 2014. Recommendation of the Agency for the cooperation of energy regulators No 
03/2014. 
https://www.acer.europa.eu/Official_documents/Acts_of_the_Agency/Recommendations/ACER%20
Recommendation%2003-2014.pdf 

Uncertainty about responsibility and rules to provide access to maritime space for OWFs (tender design)>Implement tender design with strict tender requirements which are aligned between the UK and the Netherlands and eliminate all hybrid-specific uncertainties>Agree tender design with strict requirements>Agree tender requirements considering the interests of the UK and the NetherlandsBarrierMitigation measureActions 
 
 
 
                                                      
 
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with project stakeholders (see Chapter 5.2.11) and the ease of implementation in terms of the required 
effort. 

Besides  validating  the  feasibility  of  regulated  revenues  for  anticipatory  investments  under  the 
regulatory regime in the UK and in the Netherlands, no other mitigation option can be considered. 
The UK export cable system, which requires anticipatory investments, is geographically located in the 
UK. The UK regime is therefore applicable and must be assessed with regard to the coverage of the 
specific investments. The Dutch export cable system, which also requires anticipatory investments, 
is geographically located in the Netherlands. The Dutch regime is therefore applicable and must be 
assessed with regard to the coverage of the specific investments.  

Regarding interdependencies, this barrier is interdependent with  the "failure of developers to align 
planning across assets and countries" barrier. Continuous dialogue and early-stage alignment with 
the  BEIS  and  Ofgem  in  the  UK,  as  well  as  the  MoEA  and  ACM  in  the  Netherlands,  support  the 
validation of the coverage of the anticipatory investments with regulated revenues under the UK and 
Dutch regimes, respectively.  

Actions and responsibilities for mitigation implementation: To implement this mitigation measure for 
the CGS IJmuiden Ver to Norfolk hybrid project, the following actions are required: 

▪  Validate  the  efficiency  of  the  anticipatory  investment  under  the  developer  build  option  of  the 
OFTO regime. This ensures that anticipatory investments for the export cable system of the UK 
OWF  in  the  hybrid  project  are  covered  by  regulated  revenues.141  If  they  are,  the  anticipatory 
investment  can  be  factored  into  the  calculation  of  the  final  transfer  value  of  the  export  cable 
system  to  the  OFTO.  This  can  be  achieved  by  voluntary  cooperation  between  Vattenfall  and 
Ofgem in the UK. 

▪  Validate the inclusion  of the anticipatory  investments in the Dutch Offshore Grid Development 
Framework142  to  allow  for  their  inclusion  in  the  investment  planning  of  TenneT TSO  B.V.  This 
ensures that anticipatory investments for the export cable system of the Dutch OWF are covered 
by  regulated  revenues.  This  action  can  be  based  on  an  existing  decision-making  process  for 
investments  for  the  offshore  grid.  It  can  therefore  be  achieved  through  voluntary  cooperation 
between TenneT TSO B.V., the MoEA and ACM in the Netherlands. 

▪  Ensure compatibility with measures adopted to mitigate the barrier "disproportionate allocation of 
costs and benefits across involved stakeholders". Do this through the fair reallocation among the 
UK and the Netherlands of costs and benefits deriving from regulated revenues for anticipatory 
investments. Certainty about the allocation of costs and benefits can be achieved by addressing 
this issue as part of the project-specific HANSA between the UK and the Netherlands. Vattenfall, 
TenneT TSO B.V. (and a potential third party in the UK) and the national ministries and NRAs 
(the BEIS and Ofgem in the UK and the MoEA and ACM in the Netherlands) assume responsibility 
for this action. 

The  barrier,  its  mitigation  and  the  actions  required  to  implement  the  mitigation  are  summarised  in 
Figure  43.  The  actions  required  to  implement  the  mitigation  measure  and  the  stakeholders 
responsible for the individual actions are summarised across barriers in Figure 36.  

141 Ofgem. 2017. Offshore Transmission: Updated Guidance for Cost Assessment. 
https://www.ofgem.gov.uk/system/files/docs/2017/07/170629_update_cost_assessment_guidance_
_0.pdf 

142 Dutch Elektriciteitswet 1998. Article 21. https://wetten.overheid.nl/BWBR0009755/2018-07-
28#Hoofdstuk3_Paragraaf3_Artikel21 

 
 
                                                      
 
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Figure 43: CGS IJmuiden Ver to Norfolk barrier mitigation – Lack of regulated revenues for anticipatory 
investments 

Uncertainty about applicable RES subsidy scheme 

Project-specific barrier evaluation: The OWFs included in the CGS IJmuiden Ver to Norfolk  hybrid 
project are located in the UK and Dutch EEZs. Due to the connection to both the UK and the Dutch 
markets,  the  application  of  a  UK  subsidy  scheme  and  a  Dutch  subsidy  scheme  are  generally 
conceivable. In addition to applying the respective national subsidy schemes to the OWFs depending 
on  their  location,  the  following  schemes  involving  both  countries  are  also  possible:  a  UK  and  /  or 
Dutch subsidy scheme with statistical transfers between the UK and the Netherlands applicable to 
both OWFs, a joint project or a joint subsidy scheme between the UK and the Netherlands. All are in 
line with EU Directive 2009/28/EC143 on the promotion of the use of energy from RES. In summary, 
the applicability of a support scheme from one of the countries involved or in some joint form is to be 
determined. 

Barrier mitigation: The mitigation option identified as most feasible is to apply the subsidy scheme of 
the Netherlands to the Dutch OWF and to apply the UK subsidy scheme to the UK OWF. Under this 
option, the UK government awards the UK OWF a CfD (i.e. a subsidy with its regular characteristics 
in  terms  of  type,  level  and  duration  of  support  as  well  as  technology  coverage).  And  the  Dutch 
government awards the Dutch OWF a premium tariff through the Dutch tender process (i.e. the SDE+ 
subsidy scheme with its regular characteristics in terms of type, level and duration of support as well 
as technology coverage). This is based on consideration of the interdependencies shown in Table 2 
and the ease of implementation in terms of the required effort. 

Since the applicability of these RES subsidy schemes was identified as most feasible in interaction 
with project stakeholders from the beginning, no other mitigation options were considered in detail. 

Regarding  interdependencies,  this  barrier  is  interdependent  with  the  following  three  barriers: 
"uncertainty about market arrangements", "uncertainty about hybrid cable system classification" and 
"uncertainty  about  responsibility  and  rules  to  provide  access  to  maritime  space  for  OWFs  (tender 
design)". The business cases of the OWFs in the hybrid project – and thereby potentially the level of 
required  subsidies  –  are  affected  by  the  market  arrangement  of  commercial  flows  from  the  Dutch 
OWF to the Dutch market only, and from the UK OWF to the UK market only. Similarly, the level of 
required subsidies is also impacted by the hybrid cable system classification of defining the export 
cable systems as export cable systems with interconnector functionality. Lastly, applying a UK and a 
Dutch subsidy scheme to the respective OWFs fits with a tender design with strict tender requirements 
aligned between the UK and the Netherlands. 

143 European Parliament, European Council. 2009. DIRECTIVE 2009/28/EC on the promotion of the 
use of energy from renewable sources. https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:32009L0028&from=EN 

Lack of regulated revenues for anticipatory investments>Validate feasibility of regulated revenues for anticipatory investments under the regulatory regimes in the UK and NL>Validate efficiency of anticipatory investments under developer build option in OFTO regime>Validate inclusion of anticipatory investments in Dutch Offshore Grid Development Framework>Ensure fair allocation of costs and benefits across stakeholdersBarrierMitigation measureActions 
 
 
                                                      
 
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Actions and responsibilities for mitigation implementation: To implement this mitigation measure for 
the CGS IJmuiden Ver to Norfolk hybrid project, the following actions are required: 

▪  Validate the feasibility of applying the subsidy scheme of the Netherlands to the Dutch OWF and 
the UK subsidy scheme to the UK  OWF. This can be achieved through voluntary  cooperation 
between national ministries and NRAs (the BEIS and Ofgem in the UK and the MoEA and ACM 
in the Netherlands). 

▪  Ensure compatibility with measures adopted to mitigate the barrier "disproportionate allocation of 
costs and benefits across involved stakeholders". Do this through the fair reallocation among the 
UK and the Netherlands of costs and benefits deriving from the RES subsidy scheme. Certainty 
about the allocation of costs and benefits can be achieved by addressing this issue as part of the 
project-specific  HANSA  between  the  UK  and  the  Netherlands.  OWF  developers,  national 
ministries and NRAs assume responsibility for this action (Vattenfall, the BEIS and Ofgem in the 
UK, and the MoEA and ACM in the Netherlands). 

The  barrier,  its  mitigation  and  the  actions  required  to  implement  the  mitigation  are  summarised  in 
Figure  44.  The  actions  required  to  implement  the  mitigation  measure  and  the  stakeholders 
responsible for the individual actions are summarised across barriers in Figure 22. 

Figure 44: CGS IJmuiden Ver to Norfolk barrier mitigation – Uncertainty about applicable RES subsidy scheme 

Limited engagement of public stakeholders 

Project-specific  barrier  evaluation:  The  support  of  public  stakeholders  is  needed  for  successful 
implementation of the CGS IJmuiden Ver to Norfolk hybrid project as regulatory and technical barriers 
must  be  overcome  and  financial  support  provided  across  two  countries,  namely,  the  UK  and  the 
Netherlands. 

Barrier mitigation: The mitigation option identified as most feasible is to formalise public commitment 
in  the  form  of  a  project-specific  MoU  or  a  project-specific  HANSA.  Feasibility  studies  and  scoping 
studies  for  early-stage  alignment  through  public  funding,  for  example,  should  also  be  facilitated. 
Furthermore, adequate de-risking of the hybrid project is required. This is based on consideration of 
the interdependencies shown in Table 2, interaction with project stakeholders (see Chapter 5.2.13) 
and the ease of implementation in terms of the required effort. 

Besides  formalising  public  commitment  in  the  form  of  a  project-specific  MoU  or  a  project-specific 
HANSA and facilitating feasibility studies and scoping studies or providing financial  guarantees, no 
other mitigation option was considered.  

Regarding interdependencies, this barrier is interdependent with  the "failure of developers to align 
planning  across  assets  and  countries"  barrier.  Continuous  dialogue  and  early-stage  alignment 
between the project developers is facilitated by formalising the commitment of relevant stakeholders 
of the hybrid project and / or by providing public funding for early-stage activities. These may include 
feasibility studies, scoping studies and technical research and development. 

Uncertainty about the applicable RES subsidy scheme>Apply Dutch subsidy scheme to Dutch OWF and UK subsidy scheme to UK OWF>Validate feasibility of applying national subsidy schemes to the respective OWFs>Ensure fair allocation of costs and benefits across stakeholdersBarrierMitigation measureActions 
 
 
 
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Actions and responsibilities for mitigation implementation: To implement this mitigation measure for 
the CGS IJmuiden Ver to Norfolk hybrid project, the following actions are required: 

▪  Align and implement the type of formalisation of public commitment to allow for the development 
of the CGS IJmuiden Ver to Norfolk hybrid project. The formalisation of commitment in the form 
of  a  project-specific  MoU  or  a  project-specific  HANSA  is  an  expression  of  the  goodwill  of  the 
stakeholders  to  support  hybrid  project  development.  It  assures  project  developers  of  public 
support, e.g. in the form of a dialogue with relevant government bodies. In early project stages, a 
project-specific  MoU  provides  sufficient  certainty  for  project  developers.  The  stakeholders 
assuming responsibility are Vattenfall, TenneT TSO B.V. (and a potential third party in the UK), 
and national ministries and NRAs (the BEIS and Ofgem in the UK and the MoEA and ACM in the 
Netherlands),  as  well  as  the  European  Commission.  In  later  project  stages,  a  project-specific 
HANSA is required to provide project developers with sufficient legal certainty. The stakeholders 
assuming responsibility include the national ministries (the BEIS in the UK and the MoEA in the 
Netherlands) and the European Commission. 

▪  Catalyse the development of the CGS IJmuiden Ver to Norfolk hybrid project by supporting early-
stage  alignment  among  developers.  Do  this  through  public  funding  for  feasibility  studies,  pilot 
projects and R&D for innovative, technological solutions, in addition to existing offshore support 
schemes.  Such  public  support  allows  developers  to  firmly  commit  to  the  development  of  the 
project. This can be achieved through voluntary cooperation between the national ministries (the 
BEIS in the UK and the MoEA in the Netherlands) and the European Commission. 

▪  Support the de-risking of the hybrid project by providing financial guarantees. Such guarantees 
can reassure project developers in situations which cannot be foreseen due to the pilot character 
of the hybrid project. This can be achieved through voluntary cooperation between the project 
developers (Vattenfall and TenneT TSO B.V., and a potential third party in the UK) as well as the 
European Commission. 

▪  Ensure  compatibility  with  the  measures  adopted  to  mitigate  the  barrier  "disproportionate 
allocation of costs and benefits across involved stakeholders". Do this through the fair reallocation 
among the UK and the Netherlands of costs and benefits deriving from the engagement of public 
stakeholders. Certainty about the allocation of costs and benefits can be achieved by addressing 
this  issue  as  part  of  the  project-specific  HANSA  between  the  UK  and  the  Netherlands.  The 
national ministries and NRAs assume responsibility for this action (the BEIS and Ofgem in the 
UK and the MoEA and ACM in the Netherlands).  

The  barrier,  its  mitigation  and  the  actions  required  to  implement  the  mitigation  are  summarised  in 
Figure  45.  The  actions  required  to  implement  the  mitigation  measure  and  the  stakeholders 
responsible for the individual actions are summarised across barriers in Figure 36.  

 
 
 
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Figure 45: CGS IJmuiden Ver to Norfolk barrier mitigation – Limited engagement of public stakeholders 

Uncertainty regarding the UK market 

Project-specific barrier evaluation: The CGS IJmuiden Ver to Norfolk hybrid project stands to benefit 
from the UK Capacity Market and the UK Cap and Floor regime because it establishes interconnection 
capacity between the UK and the Netherlands. While there are currently no changes proposed to the 
UK Capacity Market or the UK Cap and Floor regime, any potential effects of the UK's withdrawal 
from the EU need to be evaluated after the withdrawal is completed. Thus, it is unclear whether the 
CGS IJmuiden Ver to Norfolk hybrid project will benefit from these policies.144 

Barrier  mitigation:  Considering  interaction  with  project  stakeholders  (see  Chapter  5.2.14),  no 
immediate actions can be taken. It is necessary to await clarification of future UK policies as well as 
the UK's intended future interaction with the EU energy market.  

Besides awaiting clarification of future UK policies and the future participation of the UK in the EU's 
internal energy market, no other mitigation option was considered.  

Regarding interdependencies, this barrier is not interdependent with any other barrier considered in 
this study. 

Actions and responsibilities for mitigation implementation: To implement this mitigation measure for 
the CGS IJmuiden Ver to Norfolk hybrid project, the following actions are required: 

▪  Await clarification of the future of the UK Capacity Market and the UK Cap and Floor regime to 

clarify the future business case for interconnectors linking to the UK. 

▪  Await clarification on whether the UK intends to participate in the EU’s internal energy market in 

the future to provide planning security for hybrid project developers. 

The  barrier,  its  mitigation  and  the  actions  required  to  implement  the  mitigation  are  summarised  in 
Figure  46.  The  actions  required  to  implement  the  mitigation  measure  and  the  stakeholders 
responsible for the individual actions are summarised across barriers in Figure 36.  

144 Vaughan, Adam. 2018. UK's backup power subsidies are illegal, European court rules. 
https://www.theguardian.com/environment/2018/nov/15/uk-backup-power-subsidies-illegal-
european-court-capacity-market 

Limited engagement of public stakeholders>Formalise public commitment >Facilitate early-stage alignment through public funding and support de-risking of hybrid project>Align and implement formalisation of public commitment (in early project stages in form of MoU, later HANSA)>Support early-stage alignment among developers through public funding>Support de-risking of project by providing financial guarantees>Ensure fair allocation of costs and benefits across stakeholdersBarrierMitigation measureActions 
 
 
 
                                                      
 
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Figure 46: CGS IJmuiden Ver to Norfolk barrier mitigation – Uncertainty regarding the UK market 

Disproportionate allocation of costs and benefits across involved stakeholders 

Project-specific  barrier  evaluation:  Agreeing  on  the  allocation  of  costs  and  benefits  for  the  CGS 
IJmuiden  Ver  to  Norfolk  hybrid  project  is  complex.  This  is  because  he  OWFs  are  geographically 
located in the UK and Dutch EEZs and the offshore substations of their export cable systems  are 
linked by  an interconnector. Certain costs and benefits are  initially  incurred by the UK and certain 
costs and benefits are initially incurred by the Netherlands due to the technical setup and the details 
of  the  hybrid  project.  In  addition,  the  measures  adopted  to  mitigate  other  barriers  assign  costs  or 
distribute benefits to the  UK and the Netherlands. Furthermore, developers may  realise  additional 
benefits. Thus, costs and benefits are generally not distributed fairly, and no suitable approach exists 
to reallocate costs and benefits across all stakeholders of the hybrid project.  

Barrier mitigation: The mitigation option identified as most feasible is to reallocate costs and benefits 
deriving  from  the  hybrid  project  where  required,  based  on  a  project-specific  process.  In  some 
respects,  the  process  can  be  based  on  the  existing  methodology  given  by  the  Cross-Border  Cost 
Allocations (CBCA) process145. It builds on the Cost Benefit Analysis (CBA) conducted by ENTSO-
E146 for Projects of Common Interest. In the CBCA process, benefits such as socio-economic welfare 
and CO2 emissions are calculated on a national level to compensate net losers for the implementation 
of  a  project  through  a  CBCA  decision.  The  CBCA  process  provides  a  good  starting  point  for  the 
reallocation  of  costs  and  benefits  across  countries  but  is  best  suited  for  evaluating  cross-border 
electricity interconnectors. This is based on consideration of the interdependencies shown in Table 
2, interaction with project stakeholders (see Chapter 5.2.15) and the ease of implementation in terms 
of the required effort. 

Besides implementing the process resulting in the reallocation of costs and benefits deriving from the 
implementation of the hybrid project, no other mitigation option was considered.  

Regarding  interdependencies,  this  barrier  is  interdependent  with  the  following  six  barriers: 
"uncertainty  about  responsibility  for  project  development  (responsibility  for  interconnector)"; 
"uncertainty about market arrangements"; "uncertainty about hybrid cable system classification"; the 
"lack of regulated revenues for anticipatory investments"; "uncertainty about applicable RES subsidy 
scheme";  and  the  "limited  engagement  of  public  stakeholders".  Reallocation  also  relates  to  those 
barriers. This is because their mitigation translates into costs and benefits for specific stakeholders 

145 ACER. 2015. Recommendation No 5/2015 on good practices for the treatment of the investment 
requests, including CBCA requests, for electricity and gas PCIs. 
https://acer.europa.eu/Official_documents/Acts_of_the_Agency/Recommendations/ACER%20Reco
mmendation%2005-2015.pdf 

146 ENTSO-E. 2018. 2nd ENTSO-E Guideline: For Cost Benefit Analysis of Grid Development 
Projects. 
https://tyndp.entsoe.eu/Documents/TYNDP%20documents/Cost%20Benefit%20Analysis/2018-10-
11-tyndp-cba-20.pdf 

Uncertainty regarding the UK market>Await clarification of future UK policies>Await clarification of intended future interaction with EU’s energy market>Await clarification of future of UK capacity market and UK cap and floor regime>Await clarification of UK's future particip. in internal energy market BarrierMitigation measureActions 
 
 
                                                      
 
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that  might  have  to  be  reallocated  together  with  all  other  costs  and  benefits  of  the  hybrid  project. 
Therefore, the costs and benefits deriving from all six interdependent barriers must be considered.  

Actions and responsibilities for mitigation implementation: To implement this mitigation measure for 
the CGS IJmuiden Ver to Norfolk hybrid project, the following actions are required: 

▪ 

Identify the relevant cost and benefit categories between the involved stakeholders, covering all 
significant  aspects  of  the  hybrid  project.  This  can  be  achieved  through  voluntary  cooperation 
between Vattenfall and TenneT TSO B.V. in the Netherlands (and a potential third party in the 
UK) as well as national ministries and NRAs (the MoEA and ACM in the Netherlands and the 
BEIS and Ofgem in the UK). 

▪  Ensure that due consideration is given to all costs and benefits deriving from measures adopted 
to  mitigate  the  following  barriers:  "uncertainty  about  responsibility  for  project  development"; 
"uncertainty about market arrangements"; "uncertainty about hybrid cable system classification"; 
the "lack of regulated revenues for anticipatory investments"; "uncertainty about applicable RES 
subsidy  scheme";  and  the  "limited  engagement  of  public  stakeholders".  This  can  be  achieved 
through  voluntary  cooperation  between  all  stakeholders  involved  in  the  individual  barrier 
mitigation measures. 

▪  Determine  the  initial  allocation  of  costs  and  benefits,  covering  the  cost  and  benefit  categories 
across  all  significant  aspects  of  the  hybrid  project  identified  in  the  first  step.  In  this  process, 
developers  typically  conduct  the  assessment  of  costs  and  benefits,  while  NRAs  oversee  and 
validate  results.  Thus,  this  can  be  achieved  through  voluntary  cooperation  between  the  OWF 
developers (including Vattenfall), TenneT TSO B.V. in the Netherlands (and a potential third party 
in the UK) as well as national ministries and NRAs (the BEIS and Ofgem in the UK, and the MoEA 
and ACM in the Netherlands). 

▪  Align and agree a suitable reallocation of costs and benefits between developers, the UK and the 
Netherlands.  This  should  be  based  on  the  identification  of  cost  and  benefit  categories  among 
stakeholders as well as the assessment of the initial allocation of costs and benefits along the 
identified  categories.  The  allocation  could  closely  reflect  ongoing  practices  for  implemented 
interconnectors. These might already be suitable to incentivise all parties involved in the hybrid 
project.  Particularly,  the  reallocation  of  costs  must  ensure  that  Vattenfall  has  an  incentive  to 
implement  the  hybrid  project  due  to  its  increased  responsibility  under  the  UK  OFTO  regime. 
Certainty about the allocation of costs and benefits can be achieved by addressing this issue as 
part  of  the  project-specific  HANSA  between  the  UK  and  the  Netherlands.  OWF  developers 
(including Vattenfall), TenneT TSO B.V. in the Netherlands (and a potential third party in the UK) 
and national ministries and NRAs (the BEIS and Ofgem in the UK and MoEA and ACM in the 
Netherlands) assume responsibility for this action, as well as the European Commission. 

▪  Validate  the  availability  of  CEF  funding  to  ensure  adequate  incentivisation  for  all  relevant 
stakeholders if the following applies: the CGS IJmuiden Ver to Norfolk hybrid project is a PCI and 
adds  socio-economic  value,  but  the  initial  allocation  of  costs  and  benefits  is  not  sufficiently 
balanced to incentivise all countries and stakeholders to implement the hybrid project. While CEF 
funding cannot resolve viability issues of projects, it is a last resort for PCIs that have received a 
CBCA decision but are still not commercially viable for each individual stakeholder.147 This can 
be  achieved  through  voluntary  cooperation  between  Vattenfall,  TenneT  TSO  B.V.  in  the 

147 European Parliament, European Council. 2013. REGULATION (EU) No. 347/2013 on guidelines 
for trans-European energy infrastructure. Article 14. https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:32013R0347&from=en 

 
 
                                                      
 
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Netherlands (and a potential third party in the UK) and NRAs (Ofgem in the UK and ACM in the 
Netherlands) as well as the European Commission. 

The  barrier,  its  mitigation  and  the  actions  required  to  implement  the  mitigation  are  summarised  in 
Figure  47.  The  actions  required  to  implement  the  mitigation  measure  and  the  stakeholders 
responsible for the individual actions are summarised across barriers in Figure 36.  

Figure 47: CGS IJmuiden Ver to Norfolk barrier mitigation – Disproportionate allocation of costs and benefits 
across involved stakeholders 

4.6  NeuConnect 

The hybrid project idea "NeuConnect" is an interconnector tie-in concept. In the project, the OWFs in 
the  German  Cluster  1  (OWP  West,  Borkum  Riffgrund  West  1  and  Borkum  Riffgrund  West  2)  are 
connected to the UK and to Germany via the NeuConnect interconnector. However, the idea shows 
small  lifetime  savings  compared  to  the  reference  case,  in  which  the  OWF  and  interconnector  are 
stand-alone  assets.  In  addition,  both  the  interconnector  and  OWF  assets  have  already  reached 
advanced  stages  of  the  permitting  procedure,  which  do  not  cover  the  hybrid  setup.  Thus,  the 
NeuConnect hybrid project is given no detailed further consideration in the scope of this study. 

4.6.1  Details of the hybrid project and reference case 

The individual assets included in the hybrid project and in the reference case are modelled on the 
basis  of  real  assets.  But  the  assumed  characteristics  do  not  claim  to  represent  the  actual 
characteristics of the assets included in either ongoing or future developments. 

In  the  reference  case  (Figure  48),  NeuConnect  is  a  stand-alone,  point-to-point  interconnector 
between  the  UK  and  Germany,  constructed  based  on  HVDC  technology  with  1,400  MW  nominal 
capacity and a length of 675 km. The three OWFs included in the project idea are OWP West, Borkum 
Riffgrund West 1 and Borkum Riffgrund West 2 in Cluster 1 of the German EEZ. They have a total 
nominal  generation  capacity  of  900  MW.  The  OWFs  are  connected  to  Germany  via  a  locally 
coordinated export cable system featuring a 130 km of HVDC technology. No intermediate offshore 
transformers are required, as the wind turbines can be connected directly to the high-voltage offshore 
transformer via the 66-kV array cable system. The export cable system has a nominal capacity of 900 
MW. 

In the hybrid project (Figure 48), NeuConnect is a multi-terminal interconnector between the UK and 
Germany, otherwise constructed to the same specifications as in the reference case. The OWFs have 
the same specifications as in the reference case. The OWFs are connected to NeuConnect via a 10 
km HVDC export cable system. The export cable system has a nominal capacity of 900 MW. 

Disproportionate allocation of costs and benefits across involved stakeholders>Reallocate costs and benefits among stakeholders>Identify cost / benefit categories>Ensure consideration of all costs / benefits deriving from other barrier mitigation measures>Determine initial allocation>Align and agree reallocation >Validate availability of CEF funding to ensure incentivisationBarrierMitigation measureActions 
 
 
 
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For all cable systems, onshore transformer stations are not  in the scope of the  assessment. As a 
result, benefits deriving from the hybrid project compared to the reference case – with fewer onshore 
transformer  stations  in  the  hybrid  project  than  in  the  reference  case  –  have  not  been  considered. 
Furthermore,  onshore  grid  reinforcement  costs  are  not  in  the  scope  of  this  assessment.  But  it  is 
important  that  they  are  considered  before  project  development  would  be  initiated.  The  need  for 
onshore grid reinforcements can be expected to be lower in the NeuConnect hybrid project compared 
to the reference case, as the OWFs do not need an additional onshore grid connection point. 

Figure 48: NeuConnect – Reference case and hybrid project profile 

It is generally assumed that the development, construction and commissioning of the individual assets 
(OWFs,  export  cable  system  and  interconnector)  can  be  aligned  in  the  hybrid  project  to  prevent 
temporarily stranded assets. However, to do so in this case means to prolong the lifetime of the locally 
coordinated  export  cable  system  by  one  year  (as  the  OWFs  are  expected  to  be  commissioned  in 
2024 and 2025) and the lifetime of the interconnector by two years (as the interconnector is expected 
to be commissioned in 2023) compared to the typical lifetime of 25 years for offshore assets. 

4.6.2 

Evaluation of hybrid project vs. reference case 

To evaluate the hybrid project against the reference case, this study calculates the lifetime savings 
of the hybrid project. These include the difference in cost and the difference in socio-economic welfare 
(SEW) between the hybrid project and the reference  case. Both the cost assessment  – looking at 
CAPEX and OPEX – and the market modelling-based SEW assessment are based on the technical 
setup  of  the  hybrid  project  and  the  reference  case  as  described  in  the  project  details.  Additional 
indicators used in the assessment are energy not served, RES curtailment and CO2 emissions. CO2 
emissions are internalised in the SEW. 

Assuming a typical asset lifetime of 25 years, the hybrid project yields lifetime savings of about EUR 
50  m  compared  to  the  reference  case  (Figure  49).  The  lifetime  savings  are  driven  entirely  by  a 
reduction in CAPEX of about EUR 125 m. However, additional lifetime costs of about EUR 15 m from 
increased  OPEX,  and  additional  lifetime  costs  of  EUR  60  m  from  lower  lifetime  SEW,  reduce  the 
CAPEX effect. Both OPEX and SEW are calculated and discounted over a 25-year period. The small 

Reference caseHybrid caseDifferenceNominal capacity interconnector [MW]01,4001,400Nominal capacity OWF [MW]0900900Offshore transformer / converter / switching stations+ 11 / 1 / 01 / 1 / 1Length interconnector [km]0675675Length export cable [km]-12013010Onshore transformer / converter stations-10 / 30 / 2Reference caseIndicativeIndicativeReference caseConverter stationTransmission cableTransformerstationSwitching stationGeographical mapping 
 
 
 
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difference in SEW is spread over the entire European electricity system. It is originally driven by the 
suboptimal operational setup of the generation and transmission assets included in the hybrid project 
compared  to  the  reference  case.  This  means  that  either  the  available  interconnector  capacity  is 
reduced  or  the  OWF  generation  is  curtailed  as  the  two  conflict  with  each  other.  Overall,  OPEX  is 
higher in the hybrid project compared to the reference case, as CAPEX savings are the result of a 
reduction  of  kilometres  of  cable  system,  which  has  low  relative  OPEX,  and  additional  substation 
infrastructure, which has higher relative OPEX. 

Figure 49: NeuConnect – Assessment results148 

Regarding the cost assessment, the result is driven by the export cable system but is reduced by the 
interconnector. The cost of the export cable system is lower in the hybrid project than in the reference 
case. The export cable system requires fewer kilometres of cable in the hybrid project. As the export 
cable system only links the OWFs to NeuConnect and does not reach the German shore, one onshore 
converter station and  about  120 km of  export cable system are rendered redundant.  However,  an 
additional offshore switching station is required in the hybrid project to allow for safe the connection 
of the OWFs to the interconnector. These factors result in lower CAPEX and OPEX for the export 
cable system. The cost of the interconnector is higher in the hybrid project than in the reference case, 
as the interconnector requires multi-terminal technology.  

In both the hybrid project and the reference case, energy not served is zero due to the comprehensive 
nature of and redundancies in the European electricity system. Therefore, neither setup adversely 
affects the EU's energy policy target of energy security. Compared to the reference case, the effect 
of the hybrid project on curtailment and CO2 emissions is very small.149 This suggests that the hybrid 

148 SEW assessment based on Careri, Francesco. [Forthcoming]. The impact of North Sea 
electricity projects in a 2030 scenario: Preliminary assessment of system benefits for the pan-
European power system through METIS. Petten: European Commission Joint Research Centre. 

149 The hybrid project generates additional curtailment of 1,700 MWh/a and additional CO2 
emissions of 100 kt/a (internalised in socio-economic welfare). For more details, please refer to 
Careri, Francesco. [Forthcoming]. The impact of North Sea electricity projects in a 2030 scenario: 

-6247∆Lifetime savings∆Lifetime OPEX (cable systems)1)-16∆CAPEX124∆Lifetime SEW1)1) 8% discount factor      2) Including variation in CO2emissions (+100 kt/a), internalised in producer surplus∆SEW2)-5SEW reference project∆Socio-economic welfare (SEW) (hybrid project -reference case) [EUR m p.a.]∆Lifetime savings (hybrid project -reference case) [EUR m]x 25 years 
 
  
 
                                                      
 
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project  is  unlikely  to  have  a  significant  impact  on  the  EU's  energy  policy  targets  on  the  further 
establishment of the internal energy market and the decarbonisation of the economy. 

4.6.3  Development of an Action Plan to overcome barriers 

Due to the limited advantage of the hybrid project over the reference case, no project-specific barriers, 
barrier mitigation measures or Action Plans were assessed or developed. 

4.7  North Sea Wind Power Hub (NSWPH) 

The hybrid project idea "North Sea Wind Power Hub" (NSWPH) is an offshore hub concept.  In the 
project,  OWFs  in  the  Dutch,  German  and  Danish  EEZs  are  connected  to  the  Dutch,  German  and 
Western Danish markets via a hub. The hub features cable connections to the Netherlands, Germany 
and Denmark which can function as export cable systems and as interconnectors. The addition of a 
connection to the UK is under consideration. The idea shows significant lifetime savings compared to 
the reference case, in which OWFs and interconnectors are stand-alone assets. Thus, the NSWPH 
hybrid  project  is  given  further  consideration  in  the  scope  of  this  study,  and  an  Action  Plan  for  the 
implementation of barrier mitigation measures is developed. The Action Plan is intended to be used 
as a tool by stakeholders once the NSWPH hybrid project has been given the go-ahead. 

4.7.1  Details of the hybrid project and reference case 

The individual assets included in the hybrid project and in the reference case are  modelled on the 
basis  of  real  assets.  But  the  assumed  characteristics  do  not  claim  to  represent  the  actual 
characteristics of the assets included in either ongoing or future developments. 

In the reference case (Figure 51), the interconnectors are stand-alone, point-to-point interconnectors 
between  the  Netherlands  and  Denmark  (offshore),  and  between  the  Netherlands  and  Germany 
(onshore). They are constructed based on HVDC technology offshore and HVAC technology onshore. 
They have 2,000 MW nominal capacity and a length of 329 km, and 200 MW nominal capacity and a 
length  of  10  km,  respectively.  These  capacities  reflect  the  cable  system  capacities  utilised  for 
interconnection purposes in the hybrid project after the transmission of electricity generated by the 
OWFs (Figure 50). Generated electricity is defined by the nominal generation capacity and average 
capacity factor per OWF of 45%. Thus, in the reference case, no interconnector from Germany to 
Denmark is constructed, as no capacity is utilised for interconnection purposes between these two 
countries in the hybrid project. The OWFs included in the project idea are in proximity to the Dogger 
Bank area of the Dutch, German and Danish EEZs, with a total nominal generation capacity of 12,000 
MW. The OWFs are radially connected to shore, with two export cable systems to the Netherlands, 
three export cable systems to Germany and one export cable system to Denmark. These have a total 
length in the range of 2,100 to 2,400 km. Each export cable system has a nominal capacity of 2,000 
MW and uses HVDC technology.  No  intermediate offshore transformers are required,  as the  wind 
turbines can be connected directly to the high-voltage offshore transformers via the 66-kV array cable 
systems. 

Preliminary assessment of system benefits for the pan-European power system through METIS. 
Petten: European Commission Joint Research Centre. 

 
 
 
                                                      
 
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Figure 50: North Sea Wind Power Hub (NSWPH) – Assumed commercial electricity flows in the reference and 
hybrid projects 

In the hybrid project (Figure 51), the NSWPH is a hub to collect and then transmit offshore power to 
the  Netherlands,  Germany  and  Demark.  No  stand-alone  interconnector  is  included  in  the  hybrid 
project, as interconnection capacity is provided by the linkage of the export cable systems on the hub. 
However, the nominal interconnection capacity between the Netherlands and Denmark is 2,000 MW, 
between the Netherlands and Germany 200 MW and between Germany and Denmark 0 MW (Figure 
50). These are based on an exogenous price forecast150 and the cable system capacities utilised for 
the transmission of electricity generated offshore to the connected shores. The OWFs and the export 
cable  systems  between  the  hub  and  the  national  markets  have  the  same  specifications  as  in  the 
reference case. The NSWPH consortium is considering the inclusion of power-to-gas infrastructure 
on  the  hub  or  onshore  in  combination  with  the  NSWPH  hybrid  project.  For  example,  the  NSWPH 
could transmit offshore power to shore by using power-to-gas infrastructure, optimising costs by using 
existing pipeline systems for transport. This would limit investments and avoid "not in my back-yard" 
issues  for  new  electricity  transmission  infrastructure.  However,  the  inclusion  of  power-to-gas 
infrastructure was not quantitatively assessed as part of this study. 

For all cable systems, onshore (as opposed to on-hub) transformer stations are not in the scope of 
the assessment. As a result, benefits deriving from the hybrid project compared to the reference case 
– with fewer onshore transformer stations in the hybrid project than in the reference case – have not 
been  considered.  Furthermore,  onshore  grid  reinforcement  costs  are  not  in  the  scope  of  this 
assessment.  But  it  is  important  that  they  are  considered  before  project  development  would  be 
initiated. The need for onshore grid reinforcements can be expected to be lower in the hybrid project 
compared to the reference case,  as the elimination of interconnectors translates into the need for 
fewer onshore grid connection points. 

150 The exogenous price forecast is based on average wholesale prices calculated in the PRIMES 
market model used for the EU reference scenario 2016. It was adjusted using historical price data 
available on the ENTSO-E transparency platform. In the Netherlands, the price rises from EUR 50.3 
in 2020 to EUR 59.3 in 2030 before falling back to EUR 56.7 in 2050. In Germany, the price 
continuously falls from EUR 39.4 in 2020 to EUR 30.8 in 2050. In Denmark, the price rises from 
EUR 25.1 in 2020 to EUR 26.6 in 2030 before falling back to EUR 22.7 in 2035 and maintaining this 
price level until 2045. The price eventually falls to EUR 19.2 in 2050. 

2 GW6 GW4 GW0.2 GW IC0 GW IC0.9 GW ES1.8 GW ES2.7 GW ES2.0 GW ICReferencecase~0.9 GW ES2 GW~2.0 GW ICNSWPH~2.0 GW IC~1.8 GW ES~0.2 GW IC4 GW6 GW~2.7 GW ES~0.2 GW ICHybrid case 
 
 
                                                      
 
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Figure 51: North Sea Wind Power Hub (NSWPH) – Reference case and hybrid project profile 

It is generally assumed that the development, construction and commissioning of the individual assets 
(multiple  OWFs, multiple  export  cable  systems  and  a  hub)  can  be  aligned  in  the  hybrid  project  to 
prevent temporarily stranded assets. It is assumed that the hub, the OWFs and the cable systems 
will  be  commissioned  in  2035,  both  in  the  hybrid  project  and  in  the  reference  case.  However,  the 
separate commissioning of the individual OWFs and export cable systems would also be possible. 
This is also the case with the later commissioning of some of the OWFs and export cable systems 
linking the hub to the Dutch, German and Western Danish bidding zone. The assumed commissioning 
dates are the same for the hybrid project and the reference case. 

4.7.2 

Evaluation of hybrid project vs. reference case 

To evaluate the hybrid project against the reference case, this study calculates the lifetime savings 
of the hybrid project. These include the difference in cost between the hybrid project and the reference 
case. The cost assessment – looking at CAPEX and OPEX – is based on the technical setup of the 
hybrid project and the reference case, as described in the project details. Market modelling was not 
conducted for this project. 

Assuming a typical asset lifetime of 25 years, the hybrid project yields lifetime savings of about EUR 
2.5  bn  compared  to  the  reference  case  (Figure  52).  The  lifetime  savings  are  driven  entirely  by  a 
reduction in CAPEX and OPEX. OPEX are calculated and discounted over a 25-year period. 

Reference caseHybrid case1)DifferenceNominal capacity interconnector [MW]0~ 2,000 (DK-NL), ~ 200 (NL-DE)Up to 4,000 (to NL), 6,000 (to DE), 2,000 (to DK)Nominal capacity OWF [MW]012,00012,000Offshore transformer / converter / switching stations+ 66 / 6 / 06 / 6 / 6Length interconnector [km]-339339 (329 + 10)0Length export cable [km]02,100 –2,4002,100 –2,400Onshore transformer / converter stations-40 / 100 / 61) Additional value provided by inclusion of power-to-gas infrastructure in final project setup Converter stationTransmission cableTransformerstationReference caseIndicativeIndicativeReference caseGeographical mapping 
 
 
 
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Figure 52: North Sea Wind Power Hub (NSWPH) – Assessment results 

The  decrease  in  CAPEX  and  OPEX  is  driven  by  the  shared  utilisation  of  the  hub  and  the  cable 
systems  for  the  transmission  of  electricity  between  countries  in  the  hybrid  project.  Thus,  the  hub 
decreases  overall  CAPEX  and  OPEX  compared  to  stand-alone  OWF  projects  and  point-to-point 
interconnectors, due to eliminated and more cost-efficient assets. Regarding the elimination of assets, 
no additional interconnector systems are required in the hybrid project, making more than 300 km of 
interconnector  cable  and  four  onshore  converter  stations  redundant.  Regarding  the  more  cost-
efficient assets, offshore substation infrastructure required in the reference case can be realised as 
on-hub  substation  infrastructure  in  the  hybrid  project.  This  eliminates  the  need  for  underwater 
foundations  and  potentially  allows  for  less  costly  and  larger  technical  designs  which  are  not 
constrained by space limits, as on an offshore platform. In addition, lower OPEX resulting from the 
utilisation of the  hub as a  maintenance hub  in  the hybrid  project  contributes to the overall  lifetime 
savings. 

In  addition  to  the  quantitatively  assessed  lifetime  savings,  the  NSWPH  may  provide  additional 
benefits through the inclusion of power-to-gas infrastructure on the hub, or onshore in combination 
with the NSWPH hybrid project. An extended hub lifetime may also facilitate the re-powering of the 
on-hub electrical infrastructure, thereby further decreasing lifetime costs. 

4.7.3  Development of an Action Plan to overcome barriers 

This chapter summarises the findings specific to the development of the NSWPH hybrid project. It 
builds  on  the  general  explanation  of  the  barriers  in  Chapter  3.2,  the  general  explanation  of  the 
interdependencies between barriers in Chapter 3.3 and the findings of project-specific discussions of 
the barriers and mitigation options in Chapter 5.3. 

This  study  notes  that  11  of  the  16  identified  barriers  need  to  be  overcome  to  allow  for  the 
commencement  of  the  NSWPH  hybrid  project  development.  Although  the  barriers  are  addressed 
individually, interdependencies exist between them. When developing ways to mitigate one barrier, it 
is therefore necessary to also consider the mitigation of other barriers. Table 3 provides an overview 
of the project-specific barriers and barrier mitigation measures, as well as a brief description of the 
interdependencies to be considered in the development of the individual barrier mitigation measures. 

∆CAPEX1,0282,496∆Lifetime OPEX (cable systems)1)∆Lifetime savingsN/A∆Lifetime SEW1)1,468∆SEWN/ASEW reference project∆Socio-economic welfare (SEW) (hybrid project -reference case) [EUR m p.a.]∆Lifetime savings (hybrid project -reference case) [EUR m]1) 8% discount factorx 25 years 
 
 
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Barrier 

Mitigation measure 

Interdependencies 

Uncertainty about 
responsibility for 
project 
development 

Assign responsibility for grid 
connection to the TSO of the 
country in whose EEZ the 
OWF is located, namely, 
TenneT TSO B.V., TenneT 
TSO GmbH and Energinet 

▪  Failure of developers to align planning 
across assets and countries: clearly 
assigning grid connection responsibility 
facilitates continuous dialogue and early-
stage alignment 

Uncertainty about 
regulation 
deriving from 
jurisdiction over 
cross-border 
cable systems 

Obtain all required permits and 
align regulation deriving from 
concurrent jurisdiction over 
cross-border cable systems 

▪  Failure of developers to align planning 

across assets and countries: obtaining all 
required permits and aligning regulation is 
facilitated by continuous dialogue and early-
stage alignment  

Uncertainty about 
market 
arrangements 

Implement a dedicated bidding 
zone for the OWFs included in 
the hybrid project 

Uncertainty about 
hybrid cable 
system 
classification 

Define the cable systems as 
interconnectors 

▪  Uncertainty about responsibility and rules to 
provide access to maritime space for OWFs 
(tender design): aligned regulation relevant 
for the OWFs needs to be reflected in the 
tender designs 

▪  Uncertainty about hybrid cable system 
classification: a dedicated bidding zone 
implies defining the cable systems as 
interconnectors 

▪  Uncertainty about applicable RES subsidy 
scheme: a dedicated bidding zone affects 
the business cases of the OWFs and 
thereby the level of required subsidies  

▪  Uncertainty about market arrangements: 

defining the cable systems as 
interconnectors implies establishing a 
dedicated bidding zone 

▪  Uncertainty about applicable RES subsidy 
scheme: defining the cable systems as 
interconnectors, which is required due to the 
market arrangement of a dedicated bidding 
zone, affects the business cases of the 
OWFs and thereby the level of required 
subsidies  

Failure of 
developers to 
align planning 
across assets and 
countries 

Facilitate continuous dialogue 
and early-stage alignment 
between the project 
developers 

▪  Uncertainty about responsibility for project 
development: continuous dialogue and 
early-stage alignment facilitates clear 
assignment of responsibility for grid 
connection 

▪  Uncertainty about regulation deriving from 

jurisdiction over cross-border cable systems: 

 
 
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Barrier 

Mitigation measure 

Interdependencies 

continuous dialogue and early-stage 
alignment facilitates obtaining all required 
permits and aligning regulation 

▪  Uncertainty about responsibility and rules to 
provide access to maritime space for OWFs 
(tender design): continuous dialogue and 
early-stage alignment facilitates an aligned 
tender design 

▪  Lack of regulated revenues for anticipatory 
investments: continuous dialogue and early-
stage alignment among developers is 
facilitated by validating the availability of 
regulated revenues for anticipatory 
investments in the Netherlands, Germany 
and Denmark 

▪  Limited engagement of public stakeholders: 

continuous dialogue and early-stage 
alignment are facilitated by formalising 
public commitment and public funding for 
feasibility studies, R&D etc. 

Uncertainty about 
responsibility and 
rules to provide 
access to 
maritime space 
for OWFs (tender 
design) 

Implement a tender design 
with strict requirements which 
are aligned between the 
Netherlands, Germany and 
Denmark. It should reflect that 
OWFs are located across 
three EEZs but connected to 
the same hub 

▪  Uncertainty about regulation deriving from 

jurisdiction over cross-border cable systems: 
tender design needs to reflect aligned 
regulation relevant to the OWFs  

▪  Failure of developers to align planning 

across assets and countries: aligned tender 
designs are facilitated by continuous 
dialogue and early-stage alignment 

▪  Uncertainty about applicable RES subsidy 
scheme: a tender with aligned, strict 
requirements includes a joint support 
scheme established by the Netherlands, 
Germany and Denmark 

▪  Failure of developers to align planning 

across assets and countries: certainty about 
regulated revenues for anticipatory 
investments is facilitated by continuous 
dialogue and early-stage alignment 

Lack of regulated 
revenues for 
anticipatory 
investments 

Validate the feasibility of 
regulated revenues for 
anticipatory investments under 
the regulatory regimes in the 
Netherlands, Germany and 
Denmark; adjust the system in 
Denmark if required 

 
 
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Barrier 

Mitigation measure 

Interdependencies 

Uncertainty about 
applicable RES 
subsidy scheme  

Establish a joint support 
scheme between the 
Netherlands, Germany and 
Denmark for the OWFs 
included in the hybrid project 

▪  Uncertainty about market arrangements: the 
business cases of the OWFs and thereby 
the level of required subsidies are affected 
by a dedicated bidding zone 

▪  Uncertainty about hybrid cable system 

classification: the business cases of the 
OWFs and thereby the level of required 
subsidies are affected by the market 
arrangement of a dedicated bidding zone. 
This requires defining the cable systems as 
interconnectors 

▪  Uncertainty about responsibility and rules to 
provide access to maritime space for OWFs 
(tender design): applying a joint support 
scheme established by the Netherlands, 
Germany and Denmark fits a tender design 
aligned between the three countries 

Limited 
engagement of 
public 
stakeholders 

Formalise public commitment 
in the form of a project-specific 
MoU or HANSA. Also, facilitate 
feasibility studies and scoping 
studies for early-stage 
alignment through public 
funding, for example 

▪  Failure of developers to align planning 

across assets and countries: formalising 
public commitment and public funding for 
feasibility studies, R&D, etc. is facilitated by 
continuous dialogue and early-stage 
alignment 

Disproportionate 
allocation of costs 
and benefits 
across involved 
stakeholders 

Reallocate costs and benefits 
deriving from the hybrid project 
where required based on a 
project-specific process 

▪  Uncertainty about responsibility for project 

development (responsibility for grid 
connection): costs and benefits deriving 
from mitigation to be considered 

▪  Uncertainty about market arrangements: 

costs and benefits deriving from mitigation 
to be considered 

▪  Uncertainty about hybrid cable system 

classification: costs and benefits deriving 
from mitigation to be considered 

▪  Lack of regulated revenues for anticipatory 
investments: costs and benefits deriving 
from the mitigation to be considered 

▪  Uncertainty about applicable RES subsidy 
scheme: costs and benefits deriving from 
mitigation to be considered 

 
 
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Barrier 

Mitigation measure 

Interdependencies 

▪  Limited engagement of public stakeholders: 

costs and benefits deriving from mitigation 
to be considered 

▪  No interdependencies to be considered 

Uncertainty about 
legislative regime 
for power-to-gas 
and related 
infrastructure 

Provide guidance on sector 
coupling and assure NSWPH 
stakeholders of future 
legislative support to allow for 
the integration of gas 
conversion in the hybrid 
project idea 

Table 3: North Sea Wind Power Hub (NSWPH) – Barriers, barrier mitigation measures and interdependencies 

Combining all the measures needed to mitigate the barriers of relevance to the NSWPH hybrid project 
creates an Action Plan that supports the commencement of the development. In addition to placing 
the required actions on a timeline, the  Action Plan further details the stakeholders responsible for 
each of the actions (Figure 53). The Action Plan is intended to be used as a tool by stakeholders once 
the NSWPH hybrid project has received the go-ahead. 

While the Action Plan is currently structured such that barrier mitigation measures are planned until 
the end of 2020, it is conceivable that the formalisation of some mitigation measures might also be 
sufficient  post-2020.  This  is  because  the  NSWPH  hybrid  project  idea  is  currently  planned  to  be 
commissioned  by  2035.  The  Action  Plan  for  the  project  can  therefore  possibly  be  given  a  longer 
timeframe than indicated. 

 
 
 
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Figure 53: North Sea Wind Power Hub (NSWPH) – Action Plan 

The barriers and mitigation measures specific to the NSWPH hybrid project and the actions required 
to implement the identified mitigation measures are explained in more detail in the subchapters below. 
As part of the work on barrier mitigation, a project-specific Memorandum of Understanding (MoU) or 
a project-specific Hybrid Asset Network Support Agreement (HANSA) were considered. Both types 

201920202021National ministries, NRAsMoEA, ACM in the NL, BMWi, BNetzA in DEresponsibilityAlign operational rules across bordersJurisdictionclassificationHybridcable systemIf required, change national permit proceduresAlignmentIf required, adjust national regulationsTSOs, national ministries, BSHin DEValidate compatibility of defining cable systems as interconnectors with regulation in the NL, DE and DKClarify required permits under Dutch, German and Danish regulationValidate whether no additional compensation for cable system operators is requiredNational ministriesTSOs, national ministries, NRAs, ECIf possible, implement a one-stop shopMoEA, ACM in the NL, BMWi, BNetzA in DENational ministriesAssess need for and extent of onshore grid reinforcementsTSOsResponsibility1)NSWPH consortium members, national ministries, ECIdentify key focus areas for future legislative effortsNSWPH consortium members, national ministries, ECEvaluate existing regulation on natural gas and industrial /chemical gas regarding applicability to H2BarrierHydrogenTSOs, NRAs, ECDetermine initial allocation of costs / benefitsIdentify relevant cost / benefit categoriesSupport early-stage alignment among developers through public fundingEvaluate existing findings, ongoing legislative efforts and research projectsregarding H2and sector couplingTSOs, national ministries, NRAsEnsure considering costs and benefits deriving from other barrier mitigationsTSOs, national ministries, NRAs, ECPublicIf feasible, define the characteristics ofand implement joint support schemeValidate availability of CEF funding to ensure incentivisationAlign and agree reallocation between developers and countriesSupport de-risking of hybrid project by providing financial guaranteesTSOs, ECOWF developers, TSOs, national ministries, NRAs, ECNSWPH consortium members, ECAllocation ofAlign and implement the type of formalisation of public commitmentcosts andOWF developers, TSOs, national ministries, NRAsNational ministries, NRAsOWF developers, national ministries, NRAsEnsure fair allocation of costs and benefits across stakeholdersbenefitsNational ministries, ECNational ministries, NRAsNational ministries, NRAsEnsure fair allocation of costs and benefits across stakeholdersAllengagementlegislationValidate applicability of first connection charges and G-charges analogous to grid connection responsibilitydevelopmentProjectEnsure fair allocation of costs and benefits across stakeholdersTSOs, NRAsValidate inclusion of anticipatory investments in Dutch Offshore Grid Development FrameworkTSOs, national ministries, NRAsTSOs, national ministries, NRAsEnerginet, MoEUC, DUR in DKTSOs , national ministries, NRAs, ECClarify grid connection responsibility for OWFs under NL, DE and DK lawValidate whether no additional compensation for cable system operators is necessaryValidate feasibility of joint support schemeIf required, adjust Danish regulationConfirm that grid connection responsibility remains with TSO of the country in whose EEZ the OWF is locatedTSOsConduct a joint market simulation to assess the impact on the chosen market arrangementTenneT TSO B.V., MoEA, ACM in the NLAnticipatoryTSOs, national ministries, NRAsRES subsidiesEnsure fair allocation of costs and benefits across stakeholdersTenneT TSO GmbH, BMWi, BNetztA, BSHin DEClarify treatment of anticipatory investments under Danish regulationNational ministries, NRAsMoEUC, DUR in DKTSOs, national ministries, NRAsValidate inclusion of anticipatory investments in German Spatial Grid Development PlanEnsure fair allocation of costs and benefits across stakeholdersinvestmentsIf required, adjust national regulationsTSOs, national ministriesAgree tender requirements considering the interests of the NL, DE and DKMarket maritime spaceClarify the need for and extent of bidding zone review processarrangementsNational ministries, NRAs, other national authoritiesAgree tender design with strict requirementsAccess toTSOs, ECNational ministries, NRAs, other national authoritiesOWF developers, TSOs, national ministries, NRAsassets andcountriesEngage in dialogue to achieve early-stage alignment reg. locations, routingand technical specifications of assetsPlanning acrossTSOs, national ministries, NRAsEnsure fair allocation of costs and benefits across stakeholders1) Responsible stakeholders are OWF developers: tbd; TSOs: TenneT TSO B.V. in the NL, TenneT TSO GmbH in DE, Energinet in DK; Ministries: MoEAin the NL, BMWi in DE, MoEUCin DK; NRAs: ACM in the NL, BNetzA in DE, DUR in DK; Other national authorities: RVOin the NL, BSHin DE; NSWPH consortium members: TenneT TSO B.V., TenneT TSO GmbH, Energinet, Gasunie, Port of Rotterdam 
 
 
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of formal commitment to address barriers can include all actions for mitigation measures of relevance 
to the NSWPH hybrid project. Thus, it can be sufficient to set up only one type. 

Uncertainty about responsibility for project development 

Project-specific barrier evaluation: The definition of responsibility for the cable systems between the 
hub and the markets, as well as for the grid connections of the OWFs to the hub, will determine who 
is responsible for the development of the NSWPH hybrid project.  

The  definition  of  the  party  responsible  for  the  OWFs'  connections  to  the  hub  is  complex.  This  is 
because  the  potential  OWF  sites  are  located  in  the  Dutch,  German  and  Danish  EEZs  but  are 
connected to the hub instead of to an onshore connection point located in the home country of the 
respective  OWF.  The  hub  is  expected  to  be  located  in  one  country's  EEZ.  Thus,  based  on  the 
responsibility  for  grid  connection  as  stipulated  by  Dutch,  German  and  Danish  national  law,  no 
generally  suitable  definition  of  grid  connection  responsibility  exists  for  this  specific  hybrid  project 
setup. 

Responsibility for the cable systems between the hub and the markets of the Netherlands, Germany 
and Western Denmark is assumed jointly by the TSOs involved in the NSWPH consortium. These 
are TenneT TSO B.V., TenneT TSO GmbH and Energinet. This responsibility does not need to be 
reviewed.  

Barrier mitigation: The mitigation option identified as most feasible is to assign responsibility for grid 
connection to the TSO of the country in whose EEZ the OWF is located, namely, TenneT TSO B.V., 
TenneT TSO GmbH or Energinet. This is based on consideration of the interdependencies shown in 
Table 3, interaction with project stakeholders (see Chapter 5.3.1) and the ease of implementation in 
terms of the required effort. 

The other mitigation options considered in this study were to make (1) the NSWPH consortium and 
(2) the developer of the respective OWF responsible for the OWF's grid connection to the hub.  

The  mitigation  option  identified  as  most  feasible  was  selected  for  the  following  reasons:  While 
amendments to national legislation and regulations may be required for the selected mitigation option, 
the  other  two  options  are  not  covered  under  existing  European  and  /  or  national  legislation  and 
regulations  as  well.  While  the  NSWPH  consortium  does  not  exclusively  consist  of  TSOs  who  are 
generally responsible for OWFs in a national context, OWF developers are actually prohibited from 
taking  on  responsibility  for  grid  connection  due  to  the  EU's  unbundling  regulation.151  Furthermore, 
assigning responsibility to the respective national TSO has the advantage of ensuring the required 
grid  connection  expertise.  It  also  eliminates  the  financial  risk  from  delays  or  failures  of  the  grid 
connection for OWF developers, as compensation is guaranteed by national regulations. In addition, 
the  efficient  integration  of  the  individual  grid  connection  developments  is  ensured  due  to  the 
involvement of the respective TSOs, namely, TenneT TSO B.V., TenneT TSO GmbH and Energinet 
in the NSWPH consortium. 

Irrespective of which mitigation option is selected, this barrier is interdependent with the "failure of 
developers to align planning across assets and countries". Clearly defining responsibility for the grid 
connection  requires  continuous  dialogue  and  early-stage  alignment  on  the  hybrid  project  setup 
among the defined project promoters. Clearly defined responsibilities and continuous  dialogue and 
alignment, in turn, allow for the commencement of project development. 

151 European Commission. 2009. DIRECTIVE 2009/72/EC OF THE EUROPEAN PARLIAMENT 
AND OF THE COUNCIL concerning common rules for the internal market in electricity. Article 9. 
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32009L0072&from=EN 

 
 
                                                      
 
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Actions and responsibilities for mitigation implementation: To implement this mitigation measure for 
the NSWPH hybrid project, the following actions are required: 

▪  Confirm that responsibility for the grid connection remains with the TSO for the country in whose 
EEZ  the  OWF  is  located.  Certainty  about  grid  connection  responsibility  can  be  achieved  by 
addressing this issue as part of the project-specific HANSA between the Netherlands, Germany 
and  Denmark.  The  TSOs  (TenneT  TSO  B.V.,  TenneT  TSO  GmbH  and  Energinet)  as  well  as 
national ministries and NRAs (the MoEA and ACM in the Netherlands; the BMWi and BNetzA in 
Germany; and the MoEUC and DUR in Denmark) assume responsibility for this action. 

▪  Validate  the  applicability  of  first  connection  charges  and  G-charges  analogous  to  the  grid 
connection  responsibility  by  the  three  TSOs  involved:  Dutch  (shallow  first  connection  charges 
and  no  G-charges);  German  (shallow  to  super-shallow  first  connection  charges  and  no  G-
charges);  and  Danish  (super-shallow  to  partially  shallow  first  connection  charges  and  energy-
based  G-charges).152  This  action  can  be  achieved  through  voluntary  cooperation  between 
TenneT  TSO  B.V.,  TenneT  TSO  GmbH  and  Energinet,  as  well  as  the  NRAs  (ACM  in  the 
Netherlands, BNetzA in Germany and DUR in Denmark). 

▪  Ensure compatibility  with existing regulations by clarifying  responsibility for  grid  connection for 
the  OWFs  under  Dutch,  German  and  Danish  law.153  This  can  be  achieved  through  voluntary 
cooperation between TenneT TSO B.V., TenneT TSO GmbH and Energinet, as well as the MoEA 
in the Netherlands, the BMWi in Germany and the MoEUC in Denmark. 

▪ 

If required, adjust Dutch, German and Danish regulations to allow the respective TSOs to assume 
responsibility for the connection of the OWFs to the hub which is located in a different country's 
EEZ. Guidance from project-specific developers is required to inform the adjustment of the Dutch, 
German and Danish regulations. Certainty about Dutch, German and Danish regulations can be 
achieved  by  addressing  this  issue  as  part  of  the  project-specific  HANSA  between  the 
Netherlands, Germany and Denmark. The MoEA and ACM in the Netherlands, the BMWi and 
BNetzA in Germany as well as the MoEUC and DUR in Denmark assume responsibility for this 
action. 

▪  Assess the need for and extent of onshore grid reinforcements in the Netherlands, Germany and 
Denmark  to  allow  for  the  operation  of  the  interconnectors  between  the  hub  and  the  Dutch, 
German  and  Danish  markets.  This  action  can  be  achieved  through  voluntary  cooperation 
between TenneT TSO B.V., TenneT TSO GmbH and Energinet. 

152 ENTSO-E. 2018. Overview of transmission tariffs in Europe: Synthesis 2018. 
https://docstore.entsoe.eu/Documents/MC%20documents/TTO_Synthesis_2018.pdf; 
The European Wind Energy Association. 2016. Position paper on network tariffs and grid 
connection regimes. http://www.ewea.org/fileadmin/files/library/publications/position-papers/EWEA-
position-paper-on-harmonised-transmission-tariffs-and-grid-connection-regimes.pdf 

153 Dutch Elektriciteitswet 1998. §4 Article 24Aa. https://wetten.overheid.nl/BWBR0009755/2018-07-
28#Hoofdstuk3_Paragraaf4_Artikel24Aa  
German Erneuerbare-Energien-Gesetz 2017 (EEG 2017). § 8. https://www.gesetze-im-
internet.de/eeg_2014/__8.html 
German Energiewirtschaftsgesetz (EnWG). § 17b.  http://www.gesetze-im-
internet.de/enwg_2005/__17b.html 
Danish Bekendtgørelse om nettilslutning af vindmøller og pristillæg for vindmølleproduceret 
elektricitet m.v. Chapter 1 § 2. 
https://www.retsinformation.dk/Forms/R0710.aspx?id=188845#id27a00582-d6fa-44ff-ba6f-
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▪  Ensure  compatibility  with  the  measures  adopted  to  mitigate  the  barrier  "disproportionate 
allocation of costs and benefits across involved stakeholders". Do this through the fair reallocation 
among the Netherlands, Germany and Denmark of costs and benefits deriving from responsibility 
for  grid  connection.  Certainty  about  the  allocation  of  costs  and  benefits  can  be  achieved  by 
addressing this issue as part of the project-specific HANSA between the Netherlands, Germany 
and Denmark. The TSOs as well as the national ministries and NRAs assume responsibility for 
this action (TenneT TSO B.V., the MoEA and ACM in the Netherlands; TenneT TSO GmbH, the 
BMWi and BNetzA in Germany; and Energinet, the MoEUC and DUR in Denmark). 

The  barrier,  its  mitigation  and  the  actions  required  to  implement  the  mitigation  are  summarised  in 
Figure  54.  The  actions  required  to  implement  the  mitigation  measure  and  the  stakeholders 
responsible for the individual actions are summarised across barriers in Figure 53. 

Figure 54: North Sea Wind Power Hub (NSWPH) barrier mitigation – Uncertainty about responsibility for 
project development 

Uncertainty about regulation deriving from jurisdiction over cross-border cable systems 

Project-specific barrier evaluation: The OWFs included in the NSWPH hybrid project idea are located 
in the Dutch, German and Danish EEZs. They serve to exploit marine resources within the Dutch, 
German  and  Danish  EEZs.  As  such,  the  Netherlands,  Germany  and  Denmark,  respectively,  have 
jurisdiction over the OWF installations and their export cable systems,  which link the OWFs to the 
hub. Thus, there are no contradictory regulations arising from jurisdiction over the OWFs and export 
cable  systems.  Furthermore,  the  country  in  whose  EEZ  the  hub  is  located  –  assuming  that  the 
offshore installation is located in a single country's EEZ – has jurisdiction over it. So again, there are 
no contradictory regulations. 

However,  the  cable  systems  linking  the  NSWPH  to  shore  have  onshore  connection  points  in  the 
Netherlands,  Germany  and  Western  Denmark.  They  therefore  cross  the  Dutch  territorial  sea  and 
EEZ, the German territorial sea and EEZ, and the Danish territorial sea and EEZ. Depending on the 
location of the NSWPH, some of the cables cross maritime boundaries between the countries. Once 
individual cables cross maritime  boundaries, several countries have a claim to determining  whose 
regulations apply to them. Thus, the jurisdiction over the cable systems linking the NSWPH to shore 
might be concurrent and the regulations applicable to the cable systems derived from Dutch, German 
and Danish jurisdiction might contradict each other. 

Barrier mitigation: The mitigation option identified as most feasible is to obtain all required permits 
and to align regulations deriving from concurrent jurisdiction over the operation of cross-border cable 

Uncertainty about responsibility for project development>Assign responsibility for grid connection to TSO of country in whose EEZ the OWF is located>Confirm that grid connection remains with TSO of country in whose EEZ the OWF is located>Validate applicability of first connection and G-charges in line with grid connection resp.>Clarify grid connection for OWFs under NL, DE and DK law>If required, adjust regulations>Assess need for and extent of onshore grid reinforcements>Ensure fair allocation of costs and benefits across stakeholdersBarrierMitigation measureActions 
 
 
 
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systems between the hub and the countries involved. For the development and construction as well 
as for the operational phase, such procedures are also common for regular interconnectors. This is 
based  on  consideration  of  the  interdependencies  shown  in  Table  3,  interaction  with  project 
stakeholders (see Chapter 5.3.2) and the ease of implementation in terms of the required effort. 

The  other  mitigation  option  considered  in  this  study  besides  aligning  regulation  deriving  from 
concurrent jurisdiction was to define regulation deriving from Dutch, German and Danish jurisdiction 
as applicable to the respective cable systems between the hub and the Dutch, German and Western 
Danish bidding zones during operations.  

The  mitigation  option  identified  as  most  feasible  was  selected  for  the  following  reasons:  The 
respective countries' jurisdiction is applicable to the cable systems across all relevant maritime zones 
(own territorial sea and  own or foreign  EEZs). However, operational rules must be aligned across 
countries  anyway  due  to  the  cable  systems  which  link  the  onshore  connection  points  in  the 
Netherlands,  Germany  and  Denmark  to  the  same  hub.  In  addition,  the  selected  mitigation  option 
considers the interests of the three countries and can build on existing agreements established for 
interconnectors between them. 

Regarding interdependencies, this barrier is interdependent with the barriers "failure of developers to 
align planning across assets and countries" and "uncertainty about responsibility and rules to provide 
access  to  maritime  space  for  OWFs  (tender  design)".  Obtaining  all  required  permits  and  aligning 
regulation is facilitated by continuous dialogue and early-stage alignment. Furthermore, the aligned 
operational regulations must be reflected in the requirements of the OWF tenders. 

Actions and responsibilities for mitigation implementation: To implement this mitigation measure for 
the NSWPH hybrid project, the following actions are required: 

▪  For  development  and  construction,  clarify  the  necessary  permits  for  the  cables  linking  the 
NSWPH to shore under Dutch, German and Danish regulations. Compliance with environmental 
and technical rules under Dutch, German and Danish regulations can be ensured by obtaining 
these permits. This can be achieved through voluntary cooperation between the TSOs (TenneT 
TSO B.V. in the Netherlands, TenneT TSO GmbH in Germany and Energinet in Denmark) and 
the  national  ministries  (the  MoEA,  supported  by  the  Ministry  of  Infrastructure  and  Water 
Management, in the Netherlands; the BMWi and the German Federal Maritime and Hydrographic 
Agency  (BSH),  supported  by  the  Federal  Environment  Agency,  in  Germany;  and  the  MoEUC, 
supported by the Danish Environmental Protection Agency, in Denmark). 

▪ 

If possible, implement a one-stop shop on the national (or even European) level to allow for a 
coordinated  process  with  only  one  permit  required  for  the  cable  systems.  As  stipulated  in 
Regulation (EU) 347/2013,154 a one-stop shop in terms of a competent authority that integrates 
or  coordinates  all  permit  granting  processes  should  reduce  process  complexity,  as  well  as 
increase efficiency and transparency. The scope of a one-stop shop could be extended to provide 
a  consolidated  database  of  environmental  data,  facilitating  easy  data  exchange  between 
countries. However, the longer-term benefits are accompanied by significant shorter-term setup 
costs.  So,  the  feasibility  of  implementing  this  action  in  the  scope  of  mitigating  barriers  to  the 
NSWPH hybrid project is questionable. Certainty about the implementation can be achieved by 
addressing this issue as part of the project-specific HANSA between the Netherlands, Germany 
and Denmark, if feasible. The national ministries would assume responsibility for this action (the 

154 European Parliament, European Council. 2013. REGULATION (EU) No. 347/2013 on guidelines 
for trans-European energy infrastructure. (29). https://eur-lex.europa.eu/legal-
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MoEA, supported by the Ministry of Infrastructure and Water Management, in the Netherlands; 
the  BMWi,  supported  by  the  Federal  Environment  Agency,  in  Germany;  and  the  MoEUC, 
supported by Danish Environmental Protection Agency, in Denmark). 

▪ 

If required, change the national permit procedures for the specific hybrid project. Guidance from 
project-specific  developers  in  the  form  of  an  inventory  of  environmental  and  technical  rules  is 
required to inform changes to the permit procedures. Certainty about changes can be achieved 
by  addressing  this  issue  as  part  of  the  project-specific  HANSA  between  the  Netherlands, 
Germany and Denmark. The national ministries would assume responsibility for this action (the 
MoEA, supported by the Ministry of Infrastructure and Water Management, in the Netherlands; 
the  BMWi,  supported  by  regional  governments  and  the  Federal  Environment  Agency,  in 
Germany; and the MoEUC, supported by Danish Environmental Protection Agency, in Denmark). 

▪  For  the  operational  phase,  align  the  applicable  national  regulations  arising  from  concurrent 
jurisdiction for the specific hybrid  project. The required alignment may concern  liability issues, 
control  system  operations  (voltage  levels,  grid  synchronisation  etc.)  and  matters  discussed  in 
relation to other barriers. Also consider existing national and EU legal frameworks such as the 
System  Operations  regulation  (Regulation  (EU)  2017/1485)155  and  the  CACM  regulation 
(Regulation (EU) 2015/1222).156 Guidance from project-specific developers is required to inform 
the alignment. Certainty about the alignment of operational rules can be achieved by addressing 
this  issue  as  part  of  the  project-specific  HANSA  between  the  Netherlands,  Germany  and 
Denmark. The national ministries and NRAs assume responsibility for this action (the MoEA and 
ACM  in  the  Netherlands;  the  BMWi  and  BNetzA  in  Germany;  and  the  MoEUC  and  DUR  in 
Denmark). 

The  barrier,  its  mitigation  and  the  actions  required  to  implement  the  mitigation  are  summarised  in 
Figure  55.  The  actions  required  to  implement  the  mitigation  measure  and  the  stakeholders 
responsible for the individual actions are summarised across barriers in Figure 53. 

Figure 55: North Sea Wind Power Hub (NSWPH) barrier mitigation – Uncertainty about regulation deriving from 
jurisdiction over cross-border cable systems 

155 European Commission. 2017. COMMISSION REGULATION (EU) 2017/1485 establishing a 
guideline on electricity transmission system operation. https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:32017R1485&from=DE 

156 European Commission. 2015. COMMISSION REGULATION (EU) 2015/1222 establishing a 
guideline on capacity allocation and congestion management. https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:32015R1222&from=EN 

Uncertainty about regulation deriving from jurisdiction over cross-border cable systems>Obtain required permits for development and construction of export cable system>Align rules and regulation for operation of interconnector with export cable system>Clarify required permits >If possible implement a one-stop shop>If required, change national permit procedures>Align applicable national regulation (operational rules)BarrierMitigation measureActions 
 
 
 
                                                      
 
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Uncertainty about market arrangements 

Project-specific barrier evaluation: The clarification of commercial flows is required for the NSWPH 
hybrid project. This is because the potential OWF sites are located in the Dutch, German and Danish 
EEZs, with onshore grid connection points in the Netherlands, Germany and Denmark via the hub. 
Thus, commercial flows to the hub and / or to the Dutch, German and Danish markets are possible. 
Commercial flows for the OWFs included in the hybrid project must therefore be clarified. 

Barrier mitigation: The mitigation option identified as most feasible is to implement a dedicated bidding 
zone  for  the  OWFs  included  in  the  hybrid  project.  This  is  based  on  consideration  of  the 
interdependencies shown in Table 3, interaction with project stakeholders (see Chapter  5.3.3) and 
the ease of implementation in terms of the required effort. 

The other mitigation options considered in this study were (1) to implement commercial flows of the 
OWFs  to  their  respective  home  markets  only,  (2)  to  implement  dynamic  commercial  flows  of  the 
OWFs to the high-price market, and (3) to implement dynamic commercial flows of the OWFs to the 
low-price market.  

The mitigation option identified as most feasible was selected for the following reasons: Implementing 
a dedicated bidding zone for the OWFs included in the hybrid project is covered under existing market 
regulation. But it may necessitate a comprehensive bidding zone review process. Also, Option (1), 
which implements commercial flows of the OWFs to the respective home markets only, is covered 
under existing market regulation. However, the other mitigation options are not covered under existing 
market  regulation.  This  is  because  they  violate  the  existing  CACM  regulation  (Regulation  (EU) 
2015/1222)157 regarding the requirement for the stability of bidding zones across market time frames 
for options (2) and (3). The selected mitigation option has no business case implications for the OWFs 
in the hybrid project or for the cable systems between the hub and the Dutch, German and Western 
Danish bidding zones. However, all other considered mitigation options have negative business case 
implications  either  for  the  OWFs  or  for  the  cable  systems  and  might  therefore  require  additional 
compensation. The selected mitigation option also allows for the transmission of electricity generated 
by the OWFs in the hybrid project to other markets in case of outages or maintenance of single cable 
systems. It can therefore reduce the curtailment of the OWFs. This is also the case with the mitigation 
options to commercially connect the OWFs to the high-price or low-price market, 

Regarding  interdependencies,  this  barrier  is  interdependent  with  the  barriers  "uncertainty  about 
hybrid  cable  system  classification"  and  "uncertainty  about  applicable  RES  subsidy  scheme".  The 
implementation of a new bidding zone for the OWFs included in the hybrid project  implies defining 
the cable systems between the respective countries and the hub as interconnectors. In addition, such 
a  definition  may  affect  the  business  case  of  the  OWFs  included  in  the  hybrid  project  and  thereby 
potentially the level of required subsidies. 

Actions and responsibilities for mitigation implementation: To implement this mitigation measure for 
the NSWPH hybrid project, the following actions are required: 

▪  Clarify  whether  a  bidding  zone  review  process  in  accordance  with  the  CACM  regulation 
(Regulation (EU) 2015/1222) Article 32 (4)158 is required to establish an additional bidding zone 

157 European Commission. 2015. COMMISSION REGULATION (EU) 2015/1222 establishing a 
guideline on capacity allocation and congestion management. Article 33. https://eur-
lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32015R1222&from=EN 

158 European Commission. 2015. COMMISSION REGULATION (EU) 2015/1222 establishing a 
guideline on capacity allocation and congestion management. Article 32 (4). https://eur-
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containing the OWFs included in the NSWPH hybrid project. It is especially important to clarify 
whether the regular bidding zone review process should be adhered to, or whether a shortened 
bidding  zone  review  process  is  possible.  Clarification  is  also  required  on  the  feasibility  of 
establishing a bidding zone without consumers and compatible with the CACM regulation. This 
action can be achieved through voluntary cooperation between TenneT TSO B.V., TenneT TSO 
GmbH and Energinet, as well as the European Commission. 

▪  Conduct a joint market simulation between Nordpool and EPEX Spot, for example, to assess the 
impact of the different market arrangements. Insights into the effects of the market arrangements 
are especially important in these three areas: congestion of the cable systems linking the artificial 
hub to the markets; efficient price formation across the different bidding zones; and curtailment 
of the OWFs linked to the artificial hub. This action can be achieved through voluntary cooperation 
between TenneT TSO B.V., TenneT TSO GmbH and Energinet. 

▪  Validate whether no additional compensation is required for the cable system operators, as the 
cable systems are developed as part of the hybrid project from the beginning. Consider also the 
results  of  the  joint  market  simulation.  OWF  developers,  however,  are  compensated  through  a 
RES subsidy scheme by bidding for the required subsidy level in a competitive process. For this, 
OWF developers need clarity on the market conditions applicable to the OWFs in the future. This 
can be achieved through voluntary cooperation between TenneT TSO B.V., TenneT TSO GmbH 
and Energinet, as well as national ministries and NRAs (the MoEA and ACM in the Netherlands; 
the BMWi and BNetzA in Germany; and the MoEUC and DUR in Denmark) and the European 
Commission. 

▪  Ensure  compatibility  with  the  measures  adopted  to  mitigate  the  barrier  "disproportionate 
allocation of costs and benefits across involved stakeholders". Do this through the fair reallocation 
among the Netherlands, Germany and Denmark of costs and benefits deriving from the different 
market arrangements. Certainty about the allocation of costs and benefits can be achieved by 
addressing this issue as part of the project-specific HANSA between the Netherlands, Germany 
and Denmark. TSOs as well as the national ministries and NRAs assume responsibility for this 
action (TenneT TSO B.V., the MoEA and ACM in the Netherlands; TenneT TSO GmbH, the BMWi 
and BNetzA in Germany; and Energinet, the MoEUC and DUR in Denmark). 

The  barrier,  its  mitigation  and  the  actions  required  to  implement  the  mitigation  are  summarised  in 
Figure  56.  The  actions  required  to  implement  the  mitigation  measure  and  the  stakeholders 
responsible for the individual actions are summarised across barriers in Figure 53. 

Figure 56: North Sea Wind Power Hub (NSWPH) barrier mitigation – Uncertainty about market arrangements 

Uncertainty about market arrangements>Implement a dedicated bidding zone for the OWFs included in the hybrid project>Clarify need for and extent of bidding zone review process>Conduct joint market simulation>Validate whether no additional compensation for cable system operators is necessary>Ensure fair allocation of costs and benefits across stakeholdersBarrierMitigation measureActions 
 
 
 
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Uncertainty about hybrid cable system classification 

Project-specific barrier evaluation: The cable systems linking the NSWPH to the Dutch, German and 
Western Danish markets function as hybrid cable systems. This is because they serve two distinct 
and  legally  differentiated  functions.  Regulation  (EC)  714/2009159  defines  an  interconnector  as  "a 
transmission line which crosses or spans a border between Member States and which connects the 
national transmission systems of the Member States." A conventional export cable system provides 
for  the  transmission  of  electricity  generated  by  the  OWF  to  an  onshore  connection  point  without 
crossing borders. In the hybrid setup, the cable systems provide for the  transmission of electricity 
generated by the OWFs to shores via the hub and market-to-market flows. Such dual functionality 
prevents straight-forward classification of the cable systems  under EU and national legislation and 
regulations as either export cable systems or interconnectors. 

Barrier mitigation: The mitigation option identified as most feasible is to define the cable systems as 
interconnectors between the new bidding zone established for the hub, and the Dutch, German and 
Western Danish bidding zones. This is based on consideration of the interdependencies shown in 
Table 3, interaction with project stakeholders (see Chapter 5.3.4) and the ease of implementation in 
terms of the required effort, 

The other mitigation options considered in this study were (1) to define the cable systems between 
the hub and the Dutch, German and Western Danish  bidding  zones as export cable systems with 
leftover capacities available for interconnector functionality, and (2) to define them as interconnectors 
with leftover capacities available for transmission from the OWFs to shore via the hub.  

The mitigation option identified as most feasible was selected for the following reasons: The mitigation 
option to define the cable  systems between the hub  and the Dutch, German and Western Danish 
bidding zones as interconnectors is covered under all relevant national regulations. This is provided 
connections involving a new dedicated bidding  zone  are covered. The other considered mitigation 
options  may  possibly  be  covered  under  Dutch  and  Danish  regulations,  but  not  under  German 
regulations, which expressly prohibit the dual functionality of cable systems. Also, from a European 
perspective,  the  other  considered  mitigation  options  are  not  covered  under  existing  regulations. 
Furthermore, the mitigation option was selected due to its interdependencies with other barriers. 

Regarding interdependencies, defining the cable systems between the hub and the Dutch, German 
and  Western  Danish  bidding  zones  as  interconnectors  is  interdependent  with  the  following  two 
barriers:  "uncertainty  about  market  arrangements"  and  "uncertainty  about  applicable  RES  subsidy 
scheme". Defining the cable systems between the hub and the Dutch, German and Western Danish 
bidding zones as interconnectors fits the implementation of a new bidding zone for the OWFs in the 
hybrid project. In addition, such a definition may affect the business case of the OWFs in the hybrid 
project. This is due to the uncertain market price in the new dedicated bidding zone, which applies to 
the OWFs included in the hybrid project and thereby potentially affects the level of required subsidies. 

Actions and responsibilities for mitigation implementation: To implement this mitigation measure for 
the NSWPH hybrid project, the following actions are required: 

▪  Validate whether defining the cable systems as interconnectors between the new bidding zone 
established for the hub and the Dutch, German and Western Danish bidding zones complies with 
Dutch,  German  and  Danish  regulations.  Validation  is  required,  as  the  cable  systems  connect 
bidding zones but not necessarily countries. This can be achieved through voluntary cooperation 

159 European Parliament, European Council. 2009. REGULATION (EC) No. 714/2009 on conditions 
for access to the network for cross-border exchanges in electricity. Article 2 (1). https://eur-
lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32009R0714&from=EN 

 
 
                                                      
 
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between the national ministries and NRAs (the MoEA and ACM in the Netherlands, the BMWi 
and BNetzA in Germany and the MoEUC and DUR in Denmark), initiated by the TSOs.  

▪ 

If required, adjust Dutch, German and Danish regulations to allow for interconnectors between 
the newly established bidding zone and national bidding zones in the hybrid project. Guidance 
from  project-specific  developers  is  required  to  inform  the  adjustment  of  Dutch,  German  and 
Danish regulations. Certainty about changes can be achieved by addressing this issue as part of 
the  project-specific  HANSA  between  the  Netherlands,  Germany  and  Denmark.  The  national 
ministries and NRAs assume responsibility for this action (the MoEA and ACM in the Netherlands, 
the BMWi and BNetzA in Germany and the MoEUC and DUR in Denmark). 

▪  Validate whether no additional compensation for the cable system operators is required, as the 
cable systems are developed as part of the hybrid project from the beginning. OWF developers, 
however, are compensated through a RES subsidy scheme by bidding for the required subsidy 
level in a competitive process. For this, OWF developers need clarity on the market conditions 
applicable  to  the  OWFs  in  the  future.  This  can  be  achieved  through  voluntary  cooperation 
between TenneT TSO B.V., TenneT TSO GmbH and Energinet as well as national ministries and 
NRAs  (the  MoEA  and  ACM  in  the  Netherlands;  the  BMWi  and  BNetzA  in  Germany;  and  the 
MoEUC and DUR in Denmark) and the European Commission. 

▪  Ensure  compatibility  with  the  measures  adopted  to  mitigate  the  barrier  "disproportionate 
allocation of costs and benefits across involved stakeholders". Do this through the fair reallocation 
among  the  Netherlands,  Germany  and  Denmark  of  costs  and  benefits  deriving  from  the 
classification of the cable systems as interconnectors. Certainty about the allocation of costs and 
benefits can be achieved by addressing this issue as part of the project-specific HANSA between 
the  Netherlands,  Germany  and  Denmark.  TSOs  as  well  as  the  national  ministries  and  NRAs 
assume responsibility for this action (TenneT TSO B.V., the MoEA and ACM in the Netherlands; 
TenneT TSO GmbH, the BMWi and BNetzA in Germany; and Energinet, the MoEUC and DUR 
in Denmark). 

The  barrier,  its  mitigation  and  the  actions  required  to  implement  the  mitigation  are  summarised  in 
Figure  57.  The  actions  required  to  implement  the  mitigation  measure  and  the  stakeholders 
responsible for the individual actions are summarised across barriers in Figure 53. 

Figure 57: North Sea Wind Power Hub (NSWPH) barrier mitigation – Uncertainty about hybrid cable system 
classification 

Failure of developers to align planning across assets and countries 

Project-specific  barrier  evaluation:  Several  alignment  issues  make  the  NSWPH  hybrid  project 
complex: the inclusion of the OWFs in the Dutch, German and Danish EEZs; cable systems linking 
the hub to the Dutch, German and Western Danish markets; and the hub itself. As the various assets 
have separate permit, development and construction timelines, geographical alignment is crucial. In 

Uncertainty about hybrid cable system classification>Define the cable systems as interconnectors>Validate compatibility with regulation in the NL, DE and DK>If required, adjust regulations>Validate whether no additional compensation for cable system operators is required>Ensure fair allocation of costs and benefits across stakeholdersBarrierMitigation measureActions 
 
 
 
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addition, interoperability between the different components of the various assets must be ensured to 
enable the hybrid project to function. 

Barrier  mitigation:  The  mitigation  option  identified  as  most  feasible  is  to  facilitate  a  continuous 
dialogue and early-stage alignment between the project developers. Given that  the location of the 
Dutch,  German  and  Danish  OWFs  is  determined  by  the  Dutch,  German  and  Danish  authorities 
respectively, the project developers need to align on the following: the routing of the cable systems, 
the location of substations and the specifications of the cable systems, substations, OWFs and the 
offshore hub in the hybrid project. This is based on consideration of the interdependencies shown in 
Table 3, interaction with project stakeholders (see Chapter 5.3.5) and the ease of implementation in 
terms of the required effort. 

Apart from continuous dialogue and early-stage alignment between the project developers, no other 
mitigation options were considered.  

Regarding  interdependencies,  this  barrier  is  interdependent  with  the  following  five  barriers: 
"uncertainty about responsibility for project development"; "uncertainty about regulation deriving from 
jurisdiction over cross-border cable systems"; "uncertainty about responsibility and rules to provide 
access to maritime space for OWFs (tender design)"; the "lack of regulated revenues for anticipatory 
investments"; and the "limited engagement of public stakeholders". Continuous dialogue and early-
stage  alignment  are  complemented  by  clearly  defining  who  is  responsible  for  the  development, 
construction and operation of the cable systems as well as the need to obtain all required permits and 
align  regulation.  However,  dialogue  and  alignment  themselves  are  supported  by  the  following 
measures  to  mitigate  other  barriers.  Aligned  OWF  tenders  allow  for  the  involvement  of  and 
coordination with the developer of the OWF in the hybrid project. Two factors allow for such alignment 
by  decreasing  the  risk  to  hybrid  project  development  arising  from  early-stage  project-specific 
decisions: certainty about the availability of regulated revenues for anticipatory investments; and a 
formalised public commitment and public financial support.  

Action and responsibilities for mitigation implementation: To implement this mitigation measure for 
the NSWPH hybrid project, the following action is required: 

▪  Engage in a continuous dialogue to achieve early-stage alignment regarding the locations, routing 
and  technical  specifications  of  the  individual  assets.  This  can  be  achieved  through  voluntary 
cooperation  between  the  OWF  developers  and  TenneT  TSO  B.V.,  TenneT  TSO  GmbH  and 
Energinet, as well as national ministries and NRAs (the MoEA, supported by RVO and ACM, in 
the Netherlands; the BMWi, supported by the BSH and BNetzA, in Germany; and the MoEUC 
and DUR in Denmark). 

The  barrier,  its  mitigation  and  the  actions  required  to  implement  the  mitigation  are  summarised  in 
Figure  58.  The  actions  required  to  implement  the  mitigation  measure  and  the  stakeholders 
responsible for the individual actions are summarised across barriers in Figure 53. 

Figure 58: North Sea Wind Power Hub (NSWPH) barrier mitigation – Failure of developers to align planning 
across assets and countries 

Failure of developers to align planning across assets and countries>Facilitate continuous dialogue and early-stage alignment between project developers>Engage in dialogue to achieve early-stage alignment regarding locations, routing and technical specifications of assetsBarrierMitigation measureActions 
 
 
 
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Uncertainty about responsibility and rules to provide access to maritime space for OWFs 
(tender design) 

Project-specific barrier evaluation: A suitable tender design needs to be chosen for the NSWPH hybrid 
project. The OWFs in the project setup are located in the Dutch, German and Danish EEZs and are 
connected to onshore connection points in the Netherlands, Germany and Denmark via the hub. As 
the hub links multiple OWFs to shore via common infrastructure, the design of the OWFs must adapt 
to  the  technical  setup  of  the  NSWPH  and  its  associated  infrastructure.  Thus,  hybrid-specific 
requirements (e.g. technical changes to control systems on substations) must be fulfilled. 

Barrier mitigation: The mitigation option identified as most feasible is to implement a tender design 
with strict requirements. These should be aligned between the Netherlands, Germany and Denmark 
and reflect that OWFs are located in three EEZs but connected to the same hub. Furthermore, the 
tender requirements should eliminate all hybrid-specific uncertainties for the OWF developers. This 
is  based  on  consideration  of  the  interdependencies  shown  in  Table  3,  interaction  with  project 
stakeholders (see Chapter 5.3.7) and the ease of implementation in terms of the required effort. 

The  other  mitigation  options  considered  in  this  study  were  (1)  to  have  a  strict  tender  design  with 
requirements  aligned  among  the  stakeholders,  (2)  to  have  a  strict  tender  design  without  hybrid-
specific  uncertainties  for  the  OWF  developer,  and  (3)  to  have  a  lenient  tender  design  with 
requirements aligned among the stakeholders and without hybrid-specific uncertainties for the OWF 
developer.  

The mitigation option identified as most feasible was selected for the following reasons: While aligned 
requirements  potentially  necessitate  amendments  to  national  legislation  and  regulations,  the 
Netherlands,  Germany  and  Denmark  have  valid  interests  in  defining  certain  requirements  for  the 
tenders  of  the  OWFs  connected  to  the  hub.  Aligned  requirements  also  aid  in  ensuring  the 
interoperability of the OWFs with the other assets of the hybrid project. All of these factors increase 
the probability of successful hybrid project implementation. Furthermore, a tender design with strict 
requirements  also  increases  the  probability  of  successful  project  implementation,  allowing  for  a 
possible decrease in the cost efficiency of the OWF development due to  more limited competition. 
Lastly,  certainty  about  hybrid-specific  characteristics  of  the  OWF  development  increases  the 
probability  of  successful  project  implementation  –  and  decreases  the  cost  of  implementation  –  by 
reducing the risk premium otherwise demanded by OWF developers in terms of subsidies. 

Regarding  interdependencies,  this  barrier  is  interdependent  with  the  following  three  barriers: 
"uncertainty about regulation deriving from jurisdiction over cross-border cable systems"; the "failure 
of developers to align planning across assets and countries"; and "uncertainty about applicable RES 
subsidy scheme". Aligned regulation deriving from Dutch, German and Danish jurisdiction needs to 
be reflected in the requirements of the OWF tenders. In addition, the OWF tenders can include a joint 
support scheme established by the Netherlands, Germany and Denmark. Continuous dialogue and 
early-stage alignment facilitate aligned tender designs. 

Actions and responsibilities for mitigation implementation: To implement this mitigation measure for 
the NSWPH hybrid project, the following actions are required: 

▪  Agree a tender design with strict requirements. Certainty about the tender design can be achieved 
by  addressing  this  issue  as  part  of  the  project-specific  HANSA  between  the  Netherlands, 
Germany  and  Denmark.  The  national  ministries,  NRAs  and  other  national  authorities  assume 
responsibility for this action (the MoEA, ACM and RVO in the Netherlands; the BMWi, BNetzA 
and BSH in Germany; and the MoEUC and DUR in Denmark). 

▪  Agree tender requirements which take account of the valid interest of the Netherlands, Germany 
and  Denmark.  This  means  jointly  defining  material  requirements  such  as  technical  and 

 
 
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operational standards in alignment with the requirements of the NSWPH hybrid project deriving 
from the connection of all OWFs to shore via the hub. Environmental standards do not need to 
be  aligned  between  the  Netherlands,  Germany  and  Denmark,  as  national  environmental 
standards  apply  to  the  respective  OWFs.  Similarly,  financial  requirements  do  not  need  to  be 
aligned  across  countries.  Guidance  from  project-specific  developers  is  required  to  inform  the 
development of project-specific tender requirements. Certainty about tender requirements can be 
achieved  by  addressing  this  issue  as  part  of  the  project-specific  HANSA  between  the 
Netherlands,  Germany  and  Denmark.  The  national  ministries,  NRAs  and  other  national 
authorities assume responsibility for this action (the MoEA, ACM and RVO in the Netherlands; 
the BMWi, BNetzA and BSH in Germany; and the MoEUC and DUR in Denmark). 

The  barrier,  its  mitigation  and  the  actions  required  to  implement  the  mitigation  are  summarised  in 
Figure  59.  The  actions  required  to  implement  the  mitigation  measure  and  the  stakeholders 
responsible for the individual actions are summarised across barriers in Figure 53. 

Figure 59: North Sea Wind Power Hub (NSWPH) barrier mitigation – Uncertainty about responsibility and rules 
to provide access to maritime space for OWFs (tender design) 

Lack of regulated revenues for anticipatory investments 

Project-specific  barrier  evaluation:  Anticipatory  investments  are  necessary  to  allow  for  the 
implementation of the NSWPH hybrid project. While the offshore hub is important for the realisation 
of the hybrid project, it also represents significant, additional costs for its developers, even though not 
all OWFs will be connected to the hub when it is commissioned. Any investments in grid infrastructure 
deemed inefficient by regulators are not compensated,160 so the additional costs to developers may 
present an obstacle to hybrid project development. 

Barrier  mitigation:  The  mitigation  option  identified  as  most  feasible  is  to  validate  the  feasibility  of 
regulated revenues for the anticipatory investments under the regulatory regime in the Netherlands, 
Germany  and  Denmark,  and  to  adjust  the  regime  in  Denmark  if  required.  This  is  based  on 
consideration of the interdependencies shown in Table 3, interaction with project stakeholders (see 
Chapter 5.3.11) and the ease of implementation in terms of the required effort. 

Besides  validating  the  feasibility  of  regulated  revenues  for  anticipatory  investments  under  the 
regulatory  regime  in  the  Netherlands,  Germany  and  Denmark  (with  adjustments  in  Denmark,  if 
necessary), no other mitigation option can be considered. For cable systems  requiring anticipatory 
investments  that  are  geographically  located  in  the  Netherlands  and  the  hub,  the  Dutch  regime  is 
applicable. It must therefore be assessed with regard to the coverage of the specific investments. For 
cable systems requiring anticipatory investments that are geographically located in Germany and the 

160 ACER. 2014. Recommendation of the Agency for the cooperation of energy regulators No 
03/2014. 
https://www.acer.europa.eu/Official_documents/Acts_of_the_Agency/Recommendations/ACER%20
Recommendation%2003-2014.pdf 

Uncertainty about responsibility and rules to provide access to maritime space for OWFs (tender design)>Implement tender design with strict tender requirements which are aligned between the NL, DE and DK and eliminate all hybrid-specific uncertainties>Agree tender design with strict requirements>Agree tender requirements considering the interests of the NL, DE and DKBarrierMitigation measureActions 
 
 
 
                                                      
 
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hub, the German regime is applicable. It must therefore be assessed with regard to the coverage of 
the  specific  investments.  Lastly,  for  the  cable  system  requiring  anticipatory  investments  that  are 
geographically located in Denmark and the hub, the Danish regime is applicable. It must therefore 
also be assessed with regard to the coverage of the specific investments. 

Regarding interdependencies, this barrier is interdependent with  the "failure of developers to align 
planning across assets and countries". Continuous dialogue and early-stage alignment with the MoEA 
and  ACM  in  the  Netherlands,  the  BMWi  and  BNetzA  in  Germany  and  the  MoEUC  and  DUR  in 
Denmark  support  the  validation  of  the  coverage  of  the  anticipatory  investments  with  regulated 
revenues under the Dutch, German and Danish regimes, respectively. 

Actions and responsibilities for mitigation implementation: To implement this mitigation measure for 
the NSWPH hybrid project, the following actions are required: 

▪  Validate the inclusion  of  the anticipatory  investments in the Dutch Offshore Grid Development 
Framework161  to  allow  for  their  inclusion  in  the  investment  planning  of  TenneT TSO  B.V.  This 
ensures that a share of the anticipatory investments for the hub and the cable systems between 
the hub and the (Dutch) market is covered by regulated revenues. This action can be based on 
an  existing  decision-making  process  for  investments  for  the  offshore  grid.  It  can  therefore  be 
achieved  through  voluntary  cooperation  between  TenneT  TSO  B.V.,  MoEA  and  ACM  in  the 
Netherlands. 

▪  Validate the inclusion of the anticipatory investments in the German Spatial Grid Development 
Plan162  and  Maritime  Spatial  Plan163  to  allow  for  their  inclusion  in  the  investment  planning  of 
TenneT TSO GmbH. This will ensure that a share of the anticipatory investments for the hub and 
the cable systems between the hub and the (German) market is covered by regulated revenues. 
This action can be based on an existing decision-making process for investments for the offshore 
grid. It can therefore be achieved through voluntary cooperation between TenneT TSO GmbH 
(together with 50Hertz, Amprion and TransnetBW), BMWi, BNetzA and BSH in Germany. 

▪  Clarify  the  treatment  of  the  anticipatory  investments  in  Denmark  to  validate  their  coverage  by 
regulated revenues. This will ensure that a share of the anticipatory investments for the hub and 
the cable systems between the hub and the (Western Danish) market is covered by regulated 
revenues. This can be achieved through voluntary cooperation between Energinet, MoEUC and 
DUR in Denmark. 

▪ 

If  required,  adjust  Danish  regulation  to  support  the  anticipatory  investments  needed  for 
implementation  of  the  NSWPH  hybrid  project.  Guidance  from  project-specific  developers  is 
required to inform the adjustment of Danish regulation. Note that Denmark’s regulatory framework 
for  TSO  investments  is  currently  being  reviewed,  with  updated  legislation  expected  in  mid-
2019.164  Against  this  backdrop,  further  adjustments  might  not  be  necessary.  Otherwise, 
adjustments  can  be  achieved  by  addressing  this  issue  as  part  of  the  project-specific  HANSA 

161 Dutch Elektriciteitswet 1998. Article 21. https://wetten.overheid.nl/BWBR0009755/2018-07-
28#Hoofdstuk3_Paragraaf3_Artikel21 

162 BMWi. 2017. Gesetz zur Entwicklung und Förderung der Windenergie auf See. §5. 
https://www.gesetze-im-internet.de/windseeg/__5.html 

163 BMWi. 2005. Gesetz über die Elektrizitäts- und Gasversorgung. §17. http://www.gesetze-im-
internet.de/enwg_2005/__17a.html 

164 Danish Energy Agreement 2018. https://en.efkm.dk/media/12307/energy-agreement-2018.pdf 

 
 
                                                      
 
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between the Netherlands, Germany and Denmark. The MoEUC and DUR in Denmark assume 
responsibility for this action. 

▪  Ensure  compatibility  with  the  measures  adopted  to  mitigate  the  barrier  "disproportionate 
allocation of costs and benefits across involved stakeholders". Do this through the fair reallocation 
among the Netherlands, Germany and Denmark of costs and benefits deriving from coverage of 
anticipatory investments. Certainty about the allocation of costs and benefits can be achieved by 
addressing this issue as part of the project-specific HANSA between the Netherlands, Germany 
and Denmark. The TSOs as well as the national ministries and NRAs assume responsibility for 
this action (TenneT TSO B.V., the MoEA and ACM in the Netherlands; TenneT TSO GmbH, the 
BMWi and BNetzA in Germany; and Energinet, the MoEUC and DUR in Denmark). 

The  barrier,  its  mitigation  and  the  actions  required  to  implement  the  mitigation  are  summarised  in 
Figure  60.  The  actions  required  to  implement  the  mitigation  measure  and  the  stakeholders 
responsible for the individual actions are summarised across barriers in Figure 53. 

Figure 60: North Sea Wind Power Hub (NSWPH) barrier mitigation – Lack of regulated revenues for 
anticipatory investments 

Uncertainty about applicable RES subsidy scheme 

Project-specific barrier evaluation: The OWFs included in the NSWPH hybrid project are located in 
the  Dutch,  German  or  Danish  EEZs.  Thus,  subsidy  schemes  of  the  Netherlands,  Germany  and 
Denmark could apply to the respective OWFs. In addition, a joint project or a joint support scheme 
between  the  Netherlands,  Germany  and  Denmark  are  possible,  in  line  with  EU  Directive 
2009/28/EC165 on the promotion of the use of energy from RES. In summary, the applicability of a 
support scheme from one of the countries involved or in some joint form is to be determined. 

Barrier  mitigation:  The  mitigation  option  identified  as  most  feasible  is  to  establish  a  joint  support 
scheme  between  the  Netherlands,  Germany  and  Denmark for  the  OWFs  included  in  the  NSWPH 
hybrid project. This is based on consideration of the interdependencies shown in Table 3, interaction 
with project stakeholders (see Chapter 5.3.12) and the ease of implementation in terms of the required 
effort. 

The other mitigation options considered in this study were (1) to apply the national subsidy schemes 
to the OWFs, depending on their location, or (2) to apply no subsidy scheme.  

165 European Parliament, European Council. 2009. DIRECTIVE 2009/28/EC on the promotion of the 
use of energy from renewable sources. Article 6, 7, 9 and 11.https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:32009L0028&from=EN 

Lack of regulated revenues for anticipatory investments>Validate feasibility of regulated revenues for anticipatory investments under regulatory regimes in the NL, DE and DK>If required, adjust regime in DK>Validate inclusion of anticipatory investments in Dutch Offshore Grid Development Framework as well as German Spatial Grid Dev. Plan and Maritime Spatial Plan>Clarify treatment of anticipatory investments in Denmark>If required, adjust DK regulation>Ensure fair allocation of costs and benefits across stakeholdersBarrierMitigation measureActions 
 
 
 
                                                      
 
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The mitigation  option  identified as most feasible  was selected for the following reasons:  The legal 
feasibility  of  applying  location-dependent  national  subsidy  schemes  to  the  OWFs  depends  on  the 
clarification of the onshore connection point and is therefore uncertain. The feasibility of tendering the 
OWFs  without  a  subsidy  scheme  depends  on  the  ability  of  OWF  developers  to  ensure  project 
bankability  through  offtake  securities,  such  as  power  purchase  agreements.  Establishing  a  joint 
support  scheme  across  the  Netherlands,  Germany  and  Denmark  is  legally  covered  and  ensures 
project bankability. But it might be problematic due to the extended timeline, which is needed to agree 
the specifications of the scheme and formulate the necessary legally binding agreement between the 
Netherlands, Germany and Denmark. 

Regarding  interdependencies,  this  barrier  is  interdependent  with  the  following  three  barriers: 
"uncertainty about market arrangements"; "uncertainty about hybrid cable system classification"; and 
"uncertainty  about  responsibility  and  rules  to  provide  access  to  maritime  space  for  OWFs  (tender 
design)". A dedicated bidding zone for the NSWPH is accompanied by defining the cable systems 
linking the hub to shore as interconnectors. The market price established in the bidding zone affects 
the business case of the OWFs included in the hybrid project and thereby the level of required RES 
subsidies. Furthermore, applying a joint support scheme established by the Netherlands, Germany 
and Denmark to the NSWPH hybrid project fits with a tender design with aligned, strict requirements. 

Actions and responsibilities for mitigation implementation: To implement this mitigation measure for 
the NSWPH hybrid project, the following actions are required: 

▪  Validate  the  feasibility  of  a  joint  support  scheme  between  the  Netherlands,  Germany  and 
Denmark  for  all  OWFs  included  in  the  NSWPH  hybrid  project.  In  most  cases,  the  voluntary 
cooperation  of  EU  Members  States  in  a  joint  support  scheme  in  line  with  EU  Directive 
2009/28/EC166  requires  the  statistical  transfer  of  a  specified  amount  of  energy  produced  from 
RES  between  countries.  In  addition,  the  European  Commission  needs  to  be  notified  of  the 
following: the allocation of energy across countries at the latest three months after the end of the 
first  year  in  which  it  takes  effect;  the  total  amount  of  energy  from  RES  received  within  three 
months of the end of each year; and the allocation of energy across countries according to the 
notified distribution rule. The Netherlands, Germany and Denmark also have additional, national 
requirements.  The  Netherlands  require  that  the  generated  electricity  must  not  be  fed  into  the 
Dutch  grid  and  that  the  electricity  prices  of  the  relevant  area  apply.167  In  Germany,  the 
requirements are the mutuality of the scheme, the possibility of physical transmission of electricity 
to  Germany  (or  a  similar  effect  on  the  German  electricity  market),  plus  an  Intergovernmental 
Agreement  (IGA)  between  the  countries  involved.168  For  example,  the  existing  joint  support 
scheme for RES between Norway and Sweden is based on an IGA between the two countries.169 
In Denmark, existing legislation only allows subsidies to be allocated to OWFs located in Danish 
territorial waters or the Danish EEZ. This is because tenders for OWF licences, on which financial 

166 European Parliament, European Council. 2009. DIRECTIVE 2009/28/EC on the promotion of the 
use of energy from renewable sources. Article 11. https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:32009L0028&from=EN 

167 Dutch Besluit stimulering duurzame energieproductie 2007. §5a Article 55b. 
https://wetten.overheid.nl/BWBR0022735/2017-04-01#Paragraaf5a_Artikel55b  

168 German Erneuerbare-Energien-Gesetz 2017 (EEG 2017). § 5 (3). https://www.gesetze-im-
internet.de/eeg_2014/__8.html  

169 Statnett. 2011. Agreement between the Government of the Kingdom of Norway and the 
Government of the Kingdom of Sweden on a common market for electricity certificates. http:/ 
/www.statnett.no/Global/Dokumenter/Kraftsystemet/Elsertifikater/swedish_norwegian_treaty.pdf 

 
 
                                                      
 
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support depends, are conducted  only for these  areas.170 This action can be achieved through 
voluntary cooperation between the MoEA and ACM in the Netherlands, the BMWi and BNetzA in 
Germany and the MoEUC and DUR in Denmark. 

▪ 

If feasible, define the characteristics of and implement the joint support scheme for the specific 
hybrid project. In terms of the characteristics of the joint support scheme, establish the type, level 
and duration of support, plus the technology coverage. Clarify the commercial flow conditions for 
OWFs in the NSWPH hybrid project as part of this process. Due to the additional requirements 
in  the  Netherlands,  Germany  and  Denmark,  certainty  about  Dutch,  German  and  Danish 
regulations  can  be  achieved  by  addressing  this  issue  as  part  of  the  project-specific  HANSA 
between the Netherlands, Germany and Denmark. The MoEA and ACM in the Netherlands, the 
BMWi and BNetzA in Germany and the MoEUC and DUR in Denmark assume responsibility for 
this action. 

▪  Ensure  compatibility  with  the  measures  adopted  to  mitigate  the  barrier  "disproportionate 
allocation of costs and benefits across involved stakeholders". Do this through the fair reallocation 
among  the  Netherlands,  Germany  and  Denmark  of  costs  and  benefits  deriving  from  the  joint 
support  scheme.  Certainty  about  the  allocation  of  costs  and  benefits  can  be  achieved  by 
addressing this issue as part of the project-specific HANSA between the Netherlands, Germany 
and Denmark. The OWF developers as well as national ministries and NRAs (the MoEA and ACM 
in the Netherlands; the BMWi and BNetzA in Germany; and the MoEUC and DUR in Denmark) 
assume responsibility for this action. 

The  barrier,  its  mitigation  and  the  actions  required  to  implement  the  mitigation  are  summarised  in 
Figure  61.  The  actions  required  to  implement  the  mitigation  measure  and  the  stakeholders 
responsible for the individual actions are summarised across barriers in Figure 53. 

Figure 61: North Sea Wind Power Hub (NSWPH) barrier mitigation – Uncertainty about applicable RES 
subsidy scheme 

Limited engagement of public stakeholders 

Project-specific  barrier  evaluation:  The  support  of  public  stakeholders  is  needed  for  successful 
implementation of the NSWPH hybrid project, as regulatory and technical barriers must be overcome 
and  financial  support  provided  across  three  countries,  namely,  the  Netherlands,  Germany  and 
Denmark. 

Barrier mitigation: The mitigation option identified as most feasible is to formalise public commitment 
in  the  form  of  a  project-specific  MoU  or  a  project-specific  HANSA.  Feasibility  studies  and  scoping 
studies  for  early-stage  alignment  through  public  funding,  for  example,  should  also  be  facilitated. 
Furthermore, adequate de-risking of the hybrid project is required. This is based on consideration of 

170 Danish Bekendtgørelse af lov om fremme af vedvarende energi. § 22, § 23 and §37. 
https://www.retsinformation.dk/Forms/R0710.aspx?id=203053  

Uncertainty about applicable RES subsidy scheme>Establish joint support scheme between the Netherlands, Germany and Denmark>Validate feasibility of joint support scheme>If feasible, define characteristics of and implement support scheme>Ensure fair allocation of costs and benefits across stakeholdersBarrierMitigation measureActions 
 
 
 
                                                      
 
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the interdependencies shown in Table 3, interaction with project stakeholders (see Chapter 5.3.13) 
and the ease of implementation in terms of the required effort. 

Besides  formalising  public  commitment  in  the  form  of  a  project-specific  MoU  or  a  project-specific 
HANSA and facilitating feasibility studies and scoping studies or providing financial guarantees, no 
other mitigation option was considered.  

Regarding interdependencies, this barrier is interdependent with the "failure of developers to align 
planning  across  assets  and  countries"  barrier.  Continuous  dialogue  and  early-stage  alignment 
between the project developers is facilitated by formalising the commitment of relevant stakeholders 
of the hybrid project and / or by providing public funding for early-stage activities. These may include 
feasibility studies, scoping studies and technical research and development. 

Actions and responsibilities for mitigation implementation: To implement this mitigation measure for 
the NSWPH hybrid project, the following actions are required: 

▪  Align and implement the type of formalisation of public commitment to allow for the development 
of the NSWPH hybrid project. The formalisation of commitment in the form of a project-specific 
MoU or a project-specific HANSA is an expression of the goodwill of the stakeholders to support 
hybrid project development. It assures project developers of public support, e.g. in the form of 
dialogue  with  relevant  government  bodies.  In  early  project  stages,  a  project-specific  MoU 
provides sufficient certainty for project developers. The stakeholders assuming responsibility are 
TenneT TSO  B.V.,  TenneT  TSO  GmbH,  Energinet  and  the  national  ministries  and  NRAs  (the 
MoEA and ACM in the Netherlands; the BMWi and BNetzA in Germany; and the MoEUC and 
DUR in Denmark). They also include the European Commission. In later project stages, a project-
specific  HANSA  is  required  to  provide  project  developers  with  sufficient  legal  certainty.  The 
stakeholders  assuming  responsibility  include  the  national  ministries  (the  MoEA  in  the 
Netherlands, the BMWi in Germany and the MoEUC in Denmark) and the European Commission. 

▪  Catalyse  the  development  of  the  NSWPH  hybrid  project  by  supporting  early-stage  alignment 
among developers. Do this through public funding for feasibility studies, pilot projects and R&D 
for  innovative,  technological  solutions,  in  addition  to  existing  offshore  support  schemes.  Such 
public support allows developers to firmly commit to the development of the project. This can be 
achieved  through  voluntary  cooperation  between  the  national  ministries  (the  MoEA  in  the 
Netherlands, the BMWi in Germany and the MoEUC in Denmark) and the European Commission. 

▪  Support the de-risking of the hybrid project by providing financial guarantees. Such guarantees 
can reassure project developers in situations, which cannot be foreseen due to the pilot character 
of  the  hybrid  project.  This  can  be  achieved  through  voluntary  cooperation  between  the  TSOs 
(TenneT TSO B.V., TenneT TSO GmbH and Energinet) as well as the European Commission. 

▪  Ensure  compatibility  with  the  measures  adopted  to  mitigate  the  barrier  "disproportionate 
allocation of costs and benefits across involved stakeholders". Do this through the fair reallocation 
among  the  Netherlands,  Germany  and  Denmark  of  costs  and  benefits  deriving  from  the 
engagement of public stakeholders. Certainty about the allocation of costs and benefits can be 
achieved  by  addressing  this  issue  as  part  of  the  project-specific  HANSA  between  the 
Netherlands, Germany and Denmark. The national ministries and NRAs assume responsibility 
for this action (the MoEA and ACM in the Netherlands; the BMWi and BNetzA in Germany; and 
the MoEUC and DUR in Denmark). 

The  barrier,  its  mitigation  and  the  actions  required  to  implement  the  mitigation  are  summarised  in 
Figure  62.  The  actions  required  to  implement  the  mitigation  measure  and  the  stakeholders 
responsible for the individual actions are summarised across barriers in Figure 53. 

 
 
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Figure 62: North Sea Wind Power Hub (NSWPH) barrier mitigation – Limited engagement of public 
stakeholders 

Disproportionate allocation of costs and benefits across involved stakeholders 

Project-specific barrier evaluation: Agreeing on the allocation of costs and benefits in the NSWPH 
hybrid project is complex. The OWFs are geographically located in the Dutch, German and Danish 
EEZs and are connected to shore via the hub, which also provides interconnection capacity. Certain 
costs and benefits are initially incurred by the Netherlands, by Germany and by Denmark due to the 
technical setup and the details of the hybrid project. In addition, the measures adopted to mitigate 
other  barriers  assign  costs  or  distribute  benefits  to  the  Netherlands,  Germany  or  Denmark. 
Furthermore, developers may realise additional benefits. Thus, costs and benefits are generally not 
distributed  fairly,  and  no  suitable  approach  exists  to  reallocate  costs  and  benefits  across  all 
stakeholders of the hybrid project.  

Barrier mitigation: The mitigation option identified as most feasible is to reallocate costs and benefits 
deriving  from  the  hybrid  project  where  required,  based  on  a  project-specific  process.  In  some 
respects,  the  process  can  be  based  on  the  existing  methodology  given  by  the  Cross-Border  Cost 
Allocations (CBCA) process.171 It builds on the Cost Benefit Analysis (CBA) conducted by ENTSO-
E172 for Projects of Common Interest. In the CBCA process, benefits such as socio-economic welfare 
and CO2 emissions are calculated on a national level to compensate net losers for the implementation 
of  a  project  through  a  CBCA  decision.  The  CBCA  process  provides  a  good  starting  point  for  the 
reallocation  of  costs  and  benefits  across  countries  but  is  best  suited  for  evaluating  cross-border 
electricity interconnectors. This is based on consideration of the interdependencies shown in Table 
3, interaction with project stakeholders (see Chapter 5.3.15) and the ease of implementation in terms 
of the required effort. 

Besides implementing the process resulting in the reallocation of costs and benefits deriving from the 
implementation of the hybrid project, no other mitigation option was considered.  

171 ACER. 2015. Recommendation No 5/2015 on good practices for the treatment of the investment 
requests, including CBCA requests, for electricity and gas PCIs. 
https://acer.europa.eu/Official_documents/Acts_of_the_Agency/Recommendations/ACER%20Reco
mmendation%2005-2015.pdf 

172 ENTSO-E. 2018. 2nd ENTSO-E Guideline: For Cost Benefit Analysis of Grid Development 
Projects. 
https://tyndp.entsoe.eu/Documents/TYNDP%20documents/Cost%20Benefit%20Analysis/2018-10-
11-tyndp-cba-20.pdf 

Limited engagement of public stakeholders>Formalise public commitment >Facilitate early-stage alignment through public funding and support de-risking of hybrid project>Align and implement formalisation of public commitment (in early project stages in form of MoU, later HANSA)>Support early-stage alignment among developers through public funding>Support de-risking of project by providing financial guarantees>Ensure fair allocation of costs and benefits across stakeholdersBarrierMitigation measureActions 
 
 
                                                      
 
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Regarding  interdependencies,  this  barrier  is  interdependent  with  the  following  six  barriers: 
"uncertainty about responsibility for project development (grid connection responsibility)"; "uncertainty 
about  market  arrangements";  "uncertainty  about  hybrid  cable  system  classification";  the  "lack  of 
regulated  revenues  for  anticipatory  investments";  "uncertainty  about  applicable  RES  subsidy 
scheme";  and  the  "limited  engagement  of  public  stakeholders".  Reallocation  also  relates  to  those 
barriers. This is because their mitigation translates into costs and benefits for specific stakeholders 
that  might  have  to  be  reallocated  together  with  all  other  costs  and  benefits  of  the  hybrid  project. 
Therefore, the costs and benefits deriving from all six interdependent barriers must be considered.  

Actions and responsibilities for mitigation implementation: To implement this mitigation measure for 
the NSWPH hybrid project, the following actions are required: 

▪ 

Identify  relevant  cost  and  benefit  categories  between  the  involved  stakeholders,  covering  all 
significant  aspects  of  the  hybrid  project.  This  can  be  achieved  through  voluntary  cooperation 
between  TSOs  (TenneT  TSO  B.V.  in  the  Netherlands,  TenneT  TSO  GmbH  in  Germany  and 
Energinet  in  Denmark)  as  well  as  national  ministries  and  NRAs  (the  MoEA  and  ACM  in  the 
Netherlands; the BMWi and BNetzA in Germany; and the MoEUC and DUR in Denmark). 

▪  Ensure that due consideration is given to all costs and benefits deriving from measures adopted 
to  mitigate  the  following  barriers:  "uncertainty  about  responsibility  for  project  development"; 
"uncertainty about market arrangements"; "uncertainty about hybrid cable system classification"; 
the "lack of regulated revenues for anticipatory investments"; "uncertainty about applicable RES 
subsidy  scheme";  and  the  "limited  engagement  of  public  stakeholders".  This  can  be  achieved 
through  voluntary  cooperation  between  all  stakeholders  involved  in  the  individual  barrier 
mitigation measures. 

▪  Determine  the  initial  allocation  of  costs  and  benefits,  covering  the  cost  and  benefit  categories 
across  all  significant  aspects  of  the  hybrid  project  identified  in  the  first  step.  In  this  process, 
developers  typically  conduct  the  assessment  of  costs  and  benefits,  while  NRAs  oversee  and 
validate  results.  Thus,  this  can  be  achieved  through  voluntary  cooperation  between  OWF 
developers, TenneT TSO B.V. in the Netherlands, TenneT TSO GmbH in Germany and Energinet 
in Denmark as well as national ministries and NRAs (the MoEA and ACM in the Netherlands; the 
BMWi and BNetzA in Germany; and the MoEUC and DUR in Denmark). 

▪  Align  and  agree  a  suitable  reallocation  of  costs  and  benefits  between  developers,  the 
Netherlands,  Germany  and  Denmark.  This  should  be  based  on  the  identification  of  cost  and 
benefit categories among stakeholders as well as the assessment of the initial allocation of costs 
and benefits across the identified categories. Certainty about the allocation of costs and benefits 
can  be  achieved  by  addressing  this  issue  as  part  of  the  project-specific  HANSA  between  the 
Netherlands, Germany and Denmark. OWF developers, TenneT TSO B.V. in the Netherlands, 
TenneT TSO GmbH in Germany and Energinet in Denmark as well as  national ministries and 
NRAs  (the  MoEA  and  ACM  in  the  Netherlands;  the  BMWi  and  BNetzA  in  Germany;  and  the 
MoEUC  and  DUR  in  Denmark)  assume  responsibility  for  this  action,  as  well  as  the  European 
Commission. 

▪  Validate  the  availability  of  CEF  funding  to  ensure  adequate  incentivisation  for  all  relevant 
stakeholders if the following applies: the NSWPH hybrid project is a PCI and adds socio-economic 
value, but the initial allocation of costs and benefits is not sufficiently balanced to incentivise all 
countries and stakeholders to implement the hybrid project. While CEF funding cannot resolve 
viability issues of projects, it is a last resort for PCIs that have received a CBCA decision but are 

 
 
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still  not  commercially  viable  for  each  individual  stakeholder.173  This  can  be  achieved  through 
voluntary  cooperation  between  TSOs,  namely,  TenneT  TSO  B.V.  in  the  Netherlands,  TenneT 
TSO GmbH in Germany and Energinet in Denmark, and NRAs (ACM in the Netherlands, BNetzA 
in Germany and DUR in Denmark) as well as the European Commission. 

The  barrier,  its  mitigation  and  the  actions  required  to  implement  the  mitigation  are  summarised  in 
Figure  63.  The  actions  required  to  implement  the  mitigation  measure  and  the  stakeholders 
responsible for the individual actions are summarised across barriers in Figure 53. 

Figure 63: North Sea Wind Power Hub (NSWPH) barrier mitigation – Disproportionate allocation costs and 
benefits across involved stakeholders 

Uncertainty about legislative regime for power-to-gas and related infrastructure 

Project-specific barrier evaluation: The inclusion of power-to-gas and gas transmission infrastructure 
is considered in the NSWPH hybrid project, specifically power-to-hydrogen conversion and hydrogen 
transmission.  However,  including  hydrogen  infrastructure  on  the  hub  is  complicated  without  a 
dedicated  framework for  hydrogen  legislation.  Currently,  most  hybrid  project  designs  focus  on  the 
combination of generation and transmission infrastructure and do not incorporate power conversion 
to gas or gas transmission. However, depending on the technical setup of the project, the inclusion 
of power-to-hydrogen and hydrogen transmission infrastructure might be beneficial, as in the case of 
the NSWPH hybrid project. Thus, the clarification of national and European regulations in terms of 
unbundling,  market  arrangements  and  the  regulation  of  tariffs  is  necessary.  In  addition,  the 
progressive integration of energy systems across sectors, which boosts flexibility in the electricity grid 
as extra renewable energy capacity is added, depends on non-discriminatory access to infrastructure 
across sectors. 

Barrier mitigation: The mitigation option identified as most feasible is to provide guidance on sector 
coupling and to reassure NSWPH stakeholders of future legislative support to allow for the integration 
of hydrogen conversion.  A dedicated  legislative framework is needed in the longer term  for power 
conversion to hydrogen and hydrogen transmission. This would enable the European energy system 
to adapt to new technologies and help European Member States achieve their climate policy targets. 
It would also address unbundling, non-discriminatory access to infrastructure, market arrangements 
and the regulation of tariffs. This is based on consideration of the interaction with project stakeholders 
(see Chapter 5.3.16) and the ease of implementation in terms of the required effort. 

173 European Parliament, European Council. 2013. REGULATION (EU) No. 347/2013 on guidelines 
for trans-European energy infrastructure. Article 14. https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:32013R0347&from=en 

Disproportionate allocation of costs and benefits across involved stakeholders>Reallocate costs and benefits among stakeholders>Identify cost / benefit categories>Ensure consideration of all costs and benefits deriving from other barrier mitigation measures>Determine initial allocation>Align and agree reallocation>Validate availability of CEF funding to ensure incentivisationBarrierMitigation measureActions 
 
 
 
                                                      
 
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Besides  providing  guidance  on  sector  coupling  and  assuring  NSWPH  stakeholders  of  the  future 
legislative  support  for  the  inclusion  of  hydrogen  conversion  and  transmission  in  the  hybrid  project 
idea, no other mitigation option was considered. 

Regarding interdependencies, this barrier is not interdependent with any other barrier considered in 
this study for this hybrid project. 

Actions and responsibilities for mitigation implementation: To implement this mitigation measure for 
the NSWPH hybrid project, the following actions are required: 

▪  To avoid duplication of work, evaluate existing findings and ongoing legislative efforts as well as 
research projects regarding  power conversion to  hydrogen, hydrogen transmission  and sector 
coupling on the European level. This can be achieved through voluntary cooperation between the 
NSWPH  consortium  members,  particularly  Gasunie  and  Energinet,  as  well  as  the  European 
Commission. 

▪  Evaluate the existing regulations for (natural / industrial / chemical) gas as possible starting points 
for application to power conversion to hydrogen and hydrogen transmission before implementing 
a dedicated legislative framework. Base this on the assessment of the status quo of the legislative 
efforts  regarding  power  conversion  to  hydrogen  and  hydrogen  transmission.  New  and  /  or 
updated  European  legislation  regarding  power  conversion  to  hydrogen  and  hydrogen 
transmission  should  address  unbundling,  non-discriminatory  access  to  infrastructure,  market 
arrangements and the regulation of tariffs. This can be achieved through voluntary cooperation 
between the NSWPH consortium members, particularly Gasunie and Energinet, as well as the 
national  ministries  (the  MoEA  in  the  Netherlands,  the  BMWi  in  Germany  and  the  MoEUC  in 
Denmark), as well as the European Commission. 

▪  Take advantage of the experience gained from initial larger-scale power conversion to hydrogen 
and  hydrogen  transmission  projects  (e.g.  the  onshore  project  Element  One174).  Use  this  to 
establish the NSWPH hybrid project as a pilot project for the large-scale coupling of renewable 
power generation with other sectors of the energy system. In this context, and building on the 
assessment of possible starting points for dedicated hydrogen legislation, identify focus areas for 
future legislative efforts to prepare for a future legislative framework for hydrogen. This can be 
achieved through voluntary cooperation between the NSWPH consortium members, particularly 
Gasunie and Energinet as well as the national ministries (the MoEA in the Netherlands, the BMWi 
in Germany and the MoEUC in Denmark), as well as the European Commission. 

The  barrier,  its  mitigation  and  the  actions  required  to  implement  the  mitigation  are  summarised  in 
Figure  64.  The  actions  required  to  implement  the  mitigation  measure  and  the  stakeholders 
responsible for the individual actions are summarised across barriers in Figure 53. 

174 TenneT Holding B.V. 2018. Gasunie, TenneT and Thyssengas reveal detailed, green ‘sector 
coupling’ plans using power-to-gas technology. https://www.tennet.eu/news/detail/gasunie-tennet-
and-thyssengas-reveal-detailed-green-sector-coupling-plans-using-power-to-gas-tec/ 

 
 
 
                                                      
 
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Figure 64: North Sea Wind Power Hub (NSWPH) barrier mitigation – Uncertainty about legislative regime for 
power-to-gas and related infrastructure  

4.8  COBRA Cable 

The hybrid project  idea "COBRA  Cable" is an interconnector tie-in concept.  In the project, the so-
called leftover OWF areas in the German Cluster 8 are connected to the Netherlands and to Denmark 
via  the  COBRA  Cable  interconnector.  The  OWF  is  connected  to  multiple  markets,  rendering  a 
conventional  connection  of  the  OWF  to  a  German  onshore  connection  point  redundant.  The  idea 
shows  significant  lifetime  savings  compared  to  the  reference  case,  in  which  the  OWF  and  the 
interconnector  are  stand-alone  assets.  Thus,  the  COBRA  Cable  hybrid  project  is  given  further 
consideration in the scope of this study, and an Action Plan for the implementation of barrier mitigation 
measures is developed. The Action Plan is intended to be used as a tool by stakeholders once the 
COBRA Cable hybrid project has been given the go-ahead. 

4.8.1  Details of hybrid project and reference case 

The individual assets included in the hybrid project and in the reference case are  modelled on the 
basis  of  real  assets.  But  the  assumed  characteristics  do  not  claim  to  represent  the  actual 
characteristics of the assets included in either ongoing or future developments. 

In  the  reference  case  (Figure  65),  COBRA  Cable  is  a  stand-alone,  point-to-point  interconnector 
between the Netherlands and Denmark. It is constructed based on HVDC technology with 700 MW 
nominal capacity and a length of 329 km. The OWF included in the project idea is a so-called leftover 
area in Cluster 8 of the German EEZ. A leftover area is an area that remains undeveloped adjacent 
to  already  tendered  or  developed  OWF  areas.  Usually,  leftover  areas  cannot  be  economically 
connected to shore based on conventional export cable systems. According to the BSH, the leftover 
areas in Cluster 8 have a nominal generation capacity of 425 MW. The OWF is radially connected to 
Germany  via  a  200  km  HVDC  export  cable  system.  No  intermediate  offshore  transformers  are 
required, as the wind turbines can be connected directly to the high-voltage offshore transformer via 
the 66-kV array cable system. The export cable system has a nominal capacity of 425 MW.175 

In  the  hybrid  project  (Figure  65),  COBRA  Cable  is  a  multi-terminal  interconnector  between  the 
Netherlands and Denmark, otherwise constructed to the same specifications as in the reference case. 
The OWF has the same location and specifications as in the reference case. The OWF is connected 
to the interconnector via a very short HVDC export cable system. Due to the location of the OWF 

175 Alternatively, a connection of the leftover area via the locally coordinated export cable system of 
the German OWF Cluster 10 is considered post 2030. However, since the latter is still uncertain, 
e.g. due to the required crossing of major shipping lanes, this study uses the radial connection to 
shore as in the reference case. 

Uncertainty about legislative regime for power-to-gas and related infrastructure>Provide guidance on sector coupling>Assure stakeholders of future legislative support for integration of H2conversion in hybrid project idea>Evaluate existing findings, ongoing legislative efforts and research projects regarding H2and sector coupling>Evaluate existing regulation on gas regarding applicability to H2>Identify key focus areas for future legislative effortsBarrierMitigation measureActions 
 
 
                                                      
 
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close to the interconnector, the hybrid project setup only requires a very short export cable system 
for the link to the interconnector. The export cable system has a nominal capacity of 425 MW. 

For all cable systems, onshore transformer stations are not  in the scope of the  assessment. As a 
result, benefits deriving from the hybrid project compared to the reference case – with fewer onshore 
transformer  stations  in  the  hybrid  project  than  in  the  reference  case  –  have  not  been  considered. 
Furthermore,  onshore  grid  reinforcement  costs  are  not  in  the  scope  of  this  assessment.  But  it  is 
important  that  they  are  considered  before  project  development  would  be  initiated.  The  need  for 
onshore  grid  reinforcements  can  be  expected  to  be  lower  in  the  hybrid  project  compared  to  the 
reference case, as the OWF does not need an additional onshore grid connection point. 

Figure 65: COBRA Cable – Reference case and hybrid project profile 

It is assumed that the development, construction and commissioning of the individual assets (OWF, 
export cable system and interconnector) can be aligned in the hybrid project to prevent temporarily 
stranded assets. However, to do so in this case means bringing forward the development of the OWF 
and the export cable system by twelve years (commissioning in 2023) – if it is developed at all in the 
reference  case.  It  also  requires  prolonging  the  lifetime  of  the  interconnector  by  four  years  (as  the 
interconnector is expected to be commissioned in 2019176) compared to the standard offshore asset 
lifetime of 25 years. 

4.8.2 

Evaluation of hybrid project vs. reference case 

To evaluate the hybrid project against the reference case, this study calculates the lifetime savings 
of the hybrid project. These include the difference in cost and the difference in socio-economic welfare 
(SEW) between the hybrid project and the reference  case. Both the cost assessment  – looking at 
CAPEX and OPEX – and the market modelling-based SEW assessment are based on the technical 
setup  of  the  hybrid  project  and  the  reference  case,  as  described  in  the  project  details.  Additional 

176 TenneT Holding B.V., Energinet. 2018. COBRACable. http://www.cobracable.eu/ 

Reference caseHybrid caseDifferenceNominal capacity interconnector [MW]0700700Nominal capacity OWF [MW]0425425Offshore transformer / converter / switching stations01 / 1 / 01 / 1 / 0Length interconnector [km]0329329Length export cable [km]-2002000Onshore transformer / converter stations-10 / 30 / 2Converter stationTransmission cableTransformerstationReference caseIndicativeIndicativeReference caseGeographical mapping 
 
 
 
                                                      
 
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indicators included in the assessment are energy not served, RES curtailment and CO2 emissions. 
CO2 emissions are internalised as cost in the SEW. 

Assuming a typical asset lifetime of 25 years, the hybrid project yields lifetime savings of about EUR 
390 m compared to the reference case (Figure 66). The lifetime savings are derived entirely from a 
reduction of CAPEX and OPEX of about EUR 420 m. OPEX are calculated and discounted over a 
25-year period. However, a lower hybrid project SEW of EUR 3 m p.a. compared to the reference 
case translates into additional costs from lifetime SEW of about EUR 30 m, discounted over 25 years. 
The above-mentioned cost savings significantly exceed this figure. Lifetime savings therefore remain 
positive.  The  small  difference  in  SEW  is  spread  over  the  entire  European  electricity  system.  It  is 
originally  driven  by  the  suboptimal  operational  setup  of  the  generation  and  transmission  assets 
included in the hybrid project compared to the reference case. This means that either the available 
interconnector capacity is reduced or the OWF generation is curtailed as the two conflict with each 
other. 

Figure 66: COBRA Cable – Assessment results177 

Regarding  the  cost  assessment,  the  result  is  driven  by  the  OWF  and  the  export  cable  system, 
although it is slightly reduced by the interconnector. The cost of the OWF is lower in the hybrid project 
than  in  the  reference  case.  The  OWFs  can  be  commissioned  earlier  compared  to  the  alternate 
possibility of post-2030 connection, and thus benefit from lower (i.e. less inflated) OPEX. In addition, 
the  cost  of  the  export  cable  system  is  lower  in  the  hybrid  project  than  in  the  reference  case.  The 
export cable system links only the OWF to the interconnector and does not reach the German shore, 
rendering redundant one onshore converter station and about 200 km of export cable system. The 
hybrid  project  requires  the  use  of  disconnector  modules,  but  these  incur  only  negligible  costs 
compared to the cost savings. The cost of the interconnector is higher in the  hybrid project than in 
the reference case because the interconnector requires multi-terminal technology.  

177 SEW assessment based on Careri, Francesco. [Forthcoming]. The impact of North Sea 
electricity projects in a 2030 scenario: Preliminary assessment of system benefits for the pan-
European power system through METIS. Petten: European Commission Joint Research Centre. 

34-29386∆Lifetime SEW1)∆Lifetime OPEX (cable systems)1)391∆CAPEX∆Lifetime savings∆SEW2)SEW reference project-3∆Socio-economic welfare (SEW) (hybrid project -reference case) [EUR m p.a.]∆Lifetime savings (hybrid project -reference case) [EUR m]1) 8% discount factor       2) Including variation in CO2emissions (+46 kt/a), internalisedin producer surplusx 25 years 
 
 
 
                                                      
 
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In both the hybrid project and the reference case, energy not served is zero due to the comprehensive 
nature of and the redundancies in the European electricity system. Therefore, neither setup adversely 
affects the EU's energy policy target of energy security. Compared to the reference case, the effect 
of the hybrid project on curtailment and CO2 emissions is very small178. This suggests that the hybrid 
project  is  unlikely  to  have  a  significant  impact  on  the  EU's  energy  policy  targets  on  the  further 
establishment of the internal energy market and the decarbonisation of the economy. 

4.8.3  Development of an Action Plan to overcome barriers 

This chapter summarises the findings specific to the development of the COBRA Cable hybrid project. 
It  builds  on  the  general  explanation  of  the  barriers  in  Chapter  3.2,  the  general  explanation  of  the 
interdependencies between barriers in Chapter 3.3 and the findings of project-specific discussions of 
the barriers and mitigation options in Chapter 5.4. 

This  study  notes  that  10  of  the  16  identified  barriers  need  to  be  overcome  to  allow  for  the 
commencement  of  the  COBRA  Cable  hybrid  project  development.  Although  the  barriers  are 
addressed  individually,  interdependencies  exist  between  them. When  developing  ways  to  mitigate 
one barrier, it is therefore necessary to also consider the mitigation of other barriers. Table 4 provides 
an  overview  of  the  project-specific  barriers  and  barrier  mitigation  measures,  as  well  as  a  brief 
description  of  the  interdependencies  to  be  considered  in  the  development  of  the  individual  barrier 
mitigation measures. 

Barrier 

Mitigation measures 

Interdependencies 

Uncertainty about 
responsibility for 
project 
development 

Assign responsibility for grid 
connection to TenneT TSO 
GmbH, in close collaboration 
with the owners and operators 
of the COBRA Cable 
interconnector, TenneT TSO 
B.V. and Energinet 

▪  Failure of developers to align planning 
across assets and countries: clearly 
assigning grid connection responsibility 
facilitates continuous dialogue and early-
stage alignment 

Uncertainty about 
regulation 
deriving from 
jurisdiction over 
cross-border 
cable systems 

Obtain all required permits and 
align regulation deriving from 
concurrent jurisdiction over 
cross-border cable systems 

▪  Failure of developers to align planning 

across assets and countries: obtaining all 
required permits and aligning regulation is 
facilitated by continuous dialogue and early-
stage alignment  

▪  Uncertainty about responsibility and rules to 
provide access to maritime space for OWFs 
(tender design): aligned regulation relevant 
to the OWF needs to be reflected in the 
tender design 

178 The hybrid project generates additional curtailment of 2,100 MWh/a and additional CO2 
emissions of 46 kt/a (internalised in socio-economic welfare). For more details, please refer to 
Careri, Francesco. [Forthcoming]. The impact of North Sea electricity projects in a 2030 scenario: 
Preliminary assessment of system benefits for the pan-European power system through METIS. 
Petten: European Commission Joint Research Centre. 

 
 
 
                                                      
 
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Barrier 

Mitigation measures 

Interdependencies 

Uncertainty about 
market 
arrangements 

Implement a dedicated bidding 
zone for the OWF included in 
the hybrid project 

Uncertainty about 
hybrid cable 
system 
classification 

Define the cable systems as 
interconnectors 

▪  Uncertainty about hybrid cable system 
classification: a dedicated bidding zone 
implies defining the cable systems as 
interconnectors 

▪  Uncertainty about applicable RES subsidy 
scheme: a dedicated bidding zone affects 
the business case of the OWF and thereby 
the level of required subsidies  

▪  Uncertainty about market arrangements: 

defining the cable systems as 
interconnectors implies establishing a 
dedicated bidding zone 

▪  Failure of developers to align planning 

across assets and countries: defining the 
cable systems as interconnectors most 
closely aligns with the existing COBRA 
Cable business case. It therefore facilitates 
continuous dialogue and early-stage 
alignment 

▪  Uncertainty about applicable RES subsidy 
scheme: defining the cable systems as 
interconnectors, which is required due to the 
market arrangement of a dedicated bidding 
zone, affects the business case of the OWF 
and thereby the level of required subsidies  

Failure of 
developers to 
align planning 
across assets and 
countries 

Facilitate continuous dialogue 
and early-stage alignment 
between the project 
developers 

▪  Uncertainty about responsibility for project 
development: continuous dialogue and 
early-stage alignment facilitates clear 
assignment of responsibility for grid 
connection  

▪  Uncertainty about regulation deriving from 

jurisdiction over cross-border cable systems: 
continuous dialogue and early-stage 
alignment facilitates obtaining all required 
permits and aligning regulation 

▪  Uncertainty about hybrid cable system 
classification: continuous dialogue and 
early-stage alignment are facilitated by 
defining the cable systems as 
interconnectors as this most closely aligns 
with the existing COBRA Cable business 
case 

 
 
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Barrier 

Mitigation measures 

Interdependencies 

▪  Uncertainty about responsibility and rules to 
provide access to maritime space for OWFs 
(location selection, site pre-investigation, 
tender execution): continuous dialogue and 
early-stage alignment are facilitated by an 
aligned OWF location 

▪  Limited engagement of public stakeholders: 

continuous dialogue and early-stage 
alignment are facilitated by formalising 
public commitment and public funding for 
feasibility studies, R&D etc. 

▪  Failure of developers to align planning 

across assets and countries: location 
selection, site pre-investigation and tender 
execution by, and in accordance with, the 
rules of German authorities provides clarity 
on OWF location 

▪  Uncertainty about applicable RES subsidy 

scheme: location selection, site pre-
investigation and tender execution by, and 
according to, the rules of German authorities 
fits provision of a subsidy scheme by 
German authorities 

▪  Uncertainty about regulation deriving from 

jurisdiction over cross-border cable systems: 
tender design needs to reflect aligned 
regulation relevant for the OWF  

▪  Failure of developers to align planning 

across assets and countries: aligned tender 
design is facilitated by continuous dialogue 
and early-stage alignment 

▪  Uncertainty about applicable RES subsidy 
scheme: a tender with aligned, strict 
requirements includes a German subsidy 
scheme aligned with the Netherlands and 
Denmark 

▪  Uncertainty about market arrangement: the 
business case of the OWF and thereby the 
level of required subsidies are affected by a 
dedicated bidding zone 

▪  Uncertainty about hybrid cable system 

classification: the business case of the OWF 

Uncertainty about 
responsibility and 
rules to provide 
access to 
maritime space 
for OWFs 
(location 
selection, site 
pre-investigation, 
tender execution) 

Uncertainty about 
responsibility and 
rules to provide 
access to 
maritime space 
for OWFs (tender 
design) 

Conduct location selection, 
site pre-investigation and 
tender execution by, and in 
accordance with, the rules of 
German authorities 

Implement a tender design 
with strict requirements which 
are aligned between the 
Netherlands, Germany and 
Denmark 

Uncertainty about 
applicable RES 
subsidy scheme  

Apply the German RES 
subsidy scheme to the hybrid 
project OWF, potentially with 
statistical transfers between 
countries 

 
 
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Barrier 

Mitigation measures 

Interdependencies 

and thereby the level of required subsidies 
are affected by the market arrangement of 
an own bidding zone. This requires defining 
the cable systems as interconnectors 

▪  Uncertainty about responsibility and rules to 
provide access to maritime space for OWFs 
(location selection, site pre-investigation, 
tender execution and tender design): 
applying a German RES subsidy scheme 
fits location selection, site pre-investigation, 
tender execution and tender design by, and 
in accordance with, the rules of German 
authorities  

Limited 
engagement of 
public 
stakeholders 

Formalise public commitment 
in the form of a project-specific 
MoU or HANSA. Also, facilitate 
feasibility studies and scoping 
studies for early-stage 
alignment through public 
funding, for example 

▪  Failure of developers to align planning 

across assets and countries: formalising 
public commitment and public funding for 
feasibility studies, R&D, etc. is facilitated by 
continuous dialogue and early-stage 
alignment 

Disproportionate 
allocation of costs 
and benefits 
across involved 
stakeholders 

Reallocate costs and benefits 
deriving from the hybrid project 
where required, based on a 
project-specific process 

▪  Uncertainty about responsibility for project 

development (responsibility for grid 
connection): costs and benefits deriving 
from mitigation to be considered 

▪  Uncertainty about market arrangement: 

costs and benefits deriving from mitigation 
to be considered 

▪  Uncertainty about hybrid cable system 

classification: costs and benefits deriving 
from mitigation to be considered 

▪  Uncertainty about responsibility and rules to 
provide access to maritime space for OWFs 
(location selection, site pre-investigation, 
tender execution): costs deriving from 
mitigation to be considered 

▪  Uncertainty about applicable RES subsidy 
scheme: costs and benefits deriving from 
mitigation to be considered 

▪  Limited engagement of public stakeholders: 

costs and benefits deriving from mitigation 
to be considered 

Table 4: COBRA Cable – Barriers, barrier mitigation measures and interdependencies 

 
 
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Combining all the measures needed to mitigate the barriers of relevance to the COBRA Cable hybrid 
project creates an Action Plan that supports the commencement of the development. In addition to 
placing the required actions on a timeline, the Action Plan also details the stakeholders responsible 
for each of the actions (Figure 67). The Action Plan is intended to be used as a tool by stakeholders 
once the COBRA Cable hybrid project has received the go-ahead. 

Figure 67: COBRA Cable – Action Plan 

The barriers and mitigation measures specific to the COBRA Cable hybrid project  and the actions 
required  to  implement  the  identified  mitigation  measures  are  explained  in  more  detail  in  the 
subchapters  below.  As  part  of  the  work  on  barrier  mitigation,  a  project-specific  Memorandum  of 
Understanding (MoU) or a project-specific Hybrid Asset Network Support Agreement (HANSA) were 

201920202021TSOs, NRAs, ECOWF developer, TSOs, national ministries, NRAs, ECOWF developer, TSOs, national ministries, NRAsValidate availability of CEF funding to ensure incentivisationAllAlign and agree reallocation between developers and countriesBarrierAgree tender design with strict requirementsNational ministries, NRAsEnsure fair allocation of costs and benefits across stakeholdersNational ministries, other national authoritiesmaritime spaceAgree that responsibility for location selection, site pre-investigation and tender execution remains with the German authorities Clarify the need for and the extent of bidding zone review processAccess toMarket arrangementsNational ministries, NRAs, other national authoritiesAgree tender requirements considering interests ofNL, DE and DKNational ministries, NRAs, other national authoritiesRES subsidiesTSOs, national ministries, NRAsBMWi, BNetzA, BSHin DEEnsure fair allocation of costs and benefits across stakeholdersTSOs , national ministries, NRAs, ECConduct joint market  simulation to assess the impact of the chosen market arrangementIf required, assess implications of onshore grid reinforcementsTSOsClarify possibility and dates for special tender round ("Sonderausschreibung") in DEEnsure compatibility of DE subsidy scheme to hybrid project OWF with DE lawBMWi, BNetzAin DEAssess and agree whether additional compensation for IC operators is requiredTSOs, ECMoEA, ACM in the NL, BMWi, BNetzA in DETSOs, national ministries, NRAscable systemEnsure fair allocation of costs and benefits across stakeholdersPlanning acrossMoEA, ACM in the NL, BMWi, BNetzA in DEclassificationTSOs, national ministries, NRAs, ECNational ministries, ECPublicOWF developer, national ministries, NRAsEnsure fair allocation of costs and benefits across stakeholdersAlign and implement the type of formalisation of public commitmentEnsure fair allocation of costs and benefits across stakeholdersNational ministries, NRAsTSOs, national ministries, NRAsEnsure consideration of costs and benefits deriving from other barrier mitigationscosts and Allocation ofbenefitsIdentify relevant cost / benefit categoriesAssess and agree whether additional compensation for IC operators is requiredResponsibility1)Determine initial allocation of costs / benefitsTSOsOtherwise, adjust German regulation (particularly EEG §5.3)BMWi, BNetzAin DEIf required, adjust German regulationNational ministries, NRAsClarify required permits under German regulationJurisdictionNational ministriesTSOs, national ministries, NRAsEnsure fair allocation of costs and benefits across stakeholdersValidate compatibility of defining cable systems as interconnectors with regulation in the NL, DE and DKHybridEngage in dialogue to achieve early-stage alignment reg. locations, routingand technical specifications of assetsAlign operational rules across bordersIf required, change national permit proceduresassets andcountries TSOs, national ministries, NRAsTenneT TSO GmbH, BMWi, BSHin DETSOs, ECSupport early-stage alignment among developers through public fundingTSOs, national ministries, NRAs, ECengagementBMWi, BNetzAin DESupport de-risking of hybrid project by providing financial guaranteesIf required, adjust national regulationsDefine applicable first connection charges and G-charges in alignment with the NL, DE and DKresponsibilityValidate grid connection responsibility of TenneT TSO GmbHAlignmentTenneT TSO GmbH, BMWiin DETSOs, NRAsdevelopmentClarify grid connection responsibility for OWF between TSOs under DE lawProjectTSOsTSOs, national ministries, NRAsAlign mode of collaboration between TenneT TSO B.V., TenneT TSO GmbH and Energinet1) Responsible stakeholders are OWF developer: tbd; TSOs: TenneT TSO B.V. in the NL, TenneT TSO GmbH in DE, Energinet in DK; Ministries: MoEAin the NL, BMWi in DE, MoEUCin DK; NRAs: ACM in the NL, BNetzA in DE, DUR in DK; Other national authorities: RVOin the NL, BSHin DE 
 
 
 
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considered. Both types of formal commitment to address barriers can include all actions for mitigation 
measures of relevance to the COBRA Cable hybrid project. Thus, it can be sufficient to set up only 
one type. 

Uncertainty about responsibility for project development 

Project-specific barrier evaluation: The definition of responsibility for the interconnector and for the 
grid connection  of the OWF will determine  who  is responsible for  the development of the  COBRA 
Cable hybrid project.  

The definition of the party responsible for the OWF's connection to the interconnector is complex. The 
potential OWF site is located in the German EEZ, where TenneT TSO GmbH is generally responsible 
for grid connection based on German law.179 This assumes an onshore connection point in the area 
where TenneT TSO GmbH would be responsible. However, the onshore grid connection points of the 
interconnector  are  in  the  Netherlands  and  Denmark,  where  TenneT  TSO  B.V.  and  Energinet  are 
generally  responsible  for  grid  connection.  Thus,  for  this  specific  hybrid  project  setup,  no  suitable 
definition of grid connection responsibility exists. 

TenneT TSO B.V. and Energinet have been responsible for development and construction and are 
the parties responsible for operating the COBRA Cable interconnector. This responsibility does not 
need to be reviewed.180  

Barrier mitigation: The mitigation option identified as most feasible is to assign responsibility for grid 
connection to TenneT TSO GmbH in close collaboration with the owners and operators of the COBRA 
Cable  interconnector,  TenneT  TSO  B.V.  and  Energinet.  This  is  based  on  consideration  of  the 
interdependencies shown in Table 4, interaction with project stakeholders (see Chapter  5.4.1) and 
the ease of implementation in terms of the required effort.  

The  other  mitigation  options  considered  in  this  study  were  to  make  (1)  TenneT  TSO  B.V.  and 
Energinet,  (2)  the  OWF  developer  and  (3)  TenneT  TSO  B.V.,  TenneT  TSO  GmbH  and  Energinet 
responsible for the OWF's grid connection to the COBRA Cable interconnector.  

The mitigation option identified as most feasible was selected for the following reasons:  Due to the 
EU's unbundling regulation,181 OWF developers are prohibited from taking on responsibility for grid 
connection.  The  allocation  of  grid  connection  responsibility  to  TenneT  TSO  B.V.  and  Energinet  or 
jointly to TenneT TSO B.V., TenneT TSO GmbH and Energinet also requires clarification regarding 
legal and regulatory coverage. The same holds true if responsibility is assigned only to TenneT TSO 
GmbH.  In  the  selected  mitigation  option,  the  risk  towards  project  realisation  can  be  mitigated  by 
efficient  cooperation  between  TenneT  TSO  GmbH  and  the  operators  of  the  COBRA  Cable 
interconnector (TenneT TSO B.V. and Energinet). The selected mitigation option therefore allows all 
relevant stakeholders to maintain appropriate influence and interest in the project in addition to most 
closely aligning with current practice. 

179 If the onshore connection point is located in the area of responsibility of Amprion in the reference 
case, then Amprion would be responsible for the listed actions instead of TenneT TSO GmbH 
(German Erneuerbare-Energien-Gesetz 2017 (EEG 2017). § 8. https://www.gesetze-im-
internet.de/eeg_2014/__8.html). 

180 TenneT Holding B.V. 2018. COBRAcable. https://www.tennet.eu/our-grid/international-
connections/cobracable/ 

181 European Commission. 2009. DIRECTIVE 2009/72/EC OF THE EUROPEAN PARLIAMENT 
AND OF THE COUNCIL concerning common rules for the internal market in electricity. Article 9. 
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32009L0072&from=EN 

 
 
                                                      
 
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Irrespective of which mitigation option is selected, this barrier is interdependent with the "failure of 
developers to align planning across assets and countries" barrier. Clearly defining responsibility for 
the  grid  connection  requires  continuous  dialogue  and  early-stage  alignment  on  the  hybrid  project 
setup among the defined project promoters. Clearly defined responsibilities and continuous dialogue 
and alignment, in turn, allow for the commencement of project development. 

Actions and responsibilities for mitigation implementation: To implement this mitigation measure for 
the COBRA Cable hybrid project, the following actions are required: 

▪  Validate the assignment of responsibility to TenneT TSO GmbH to ensure that the integration of 
the OWF in the interconnector is successful. Certainty about grid connection responsibility can 
be  achieved  by  addressing  this  issue  as  part  of  the  project-specific  HANSA  between  the 
Netherlands, Germany and Denmark. The TSOs (TenneT TSO B.V., TenneT TSO GmbH and 
Energinet) and national ministries and NRAs (the MoEA and ACM in the Netherlands, the BMWi 
and BNetzA in Germany and the MoEUC and DUR in Denmark) assume responsibility for this 
action. 

▪  Agree a mode of collaboration between TenneT TSO GmbH and the owners and operators of the 
COBRA  Cable  interconnector,  TenneT  TSO  B.V.  and  Energinet.  This  action  can  be  achieved 
through voluntary cooperation between TenneT TSO GmbH, TenneT TSO B.V. and Energinet. 

▪  Define the applicable first connection charges and G-charges in alignment with the three involved 
countries:  the  Netherlands  (shallow  first  connection  charges  and  no  G-charges);  Germany 
(shallow  to  super-shallow  first  connection  charges  and  no  G-charges);  and  Denmark  (super-
shallow to partially shallow first connection charges and energy-based G-charges). 182 This action 
can be achieved through voluntary cooperation between TenneT TSO B.V., TenneT TSO GmbH 
and Energinet as well as the NRAs – ACM in the Netherlands, BNetzA in Germany and DUR in 
Denmark. 

▪  Validate the applicability of German law and ensure compatibility  with existing regulations. Do 
this by clarifying which TSO is responsible for OWF grid connection under German law.183 This 
can be achieved through voluntary cooperation between TenneT TSO GmbH and the BMWi in 
Germany. 

▪ 

If required, adjust German regulations to allow responsibility for grid connection to be assigned 
to  TenneT  TSO  GmbH.  This  is  despite  the  onshore  connection  points  being  located  in  the 
Netherlands and Denmark. Guidance from project-specific developers is required to inform the 
adjustment of German regulations. Achieve certainty  about German regulations by addressing 
this  issue  as  part  of  the  project-specific  HANSA  between  the  Netherlands,  Germany  and 
Denmark. The BMWi and BNetzA in Germany assume responsibility for this action. 

Ensure compatibility with the measures adopted to mitigate the barrier "disproportionate allocation of 
costs  and  benefits  across  involved  stakeholders".  Do  this  through  the  fair  reallocation  among  the 
Netherlands,  Germany  and  Denmark  of  costs  and  benefits  deriving  from  responsibility  for  grid 

182 ENTSO-E. 2018. Overview of transmission tariffs in Europe: Synthesis 2018. 
https://docstore.entsoe.eu/Documents/MC%20documents/TTO_Synthesis_2018.pdf; 

The European Wind Energy Association. 2016. Position paper on network tariffs and grid 
connection regimes. http://www.ewea.org/fileadmin/files/library/publications/position-papers/EWEA-
position-paper-on-harmonised-transmission-tariffs-and-grid-connection-regimes.pdf 

183 German Erneuerbare-Energien-Gesetz 2017 (EEG 2017). § 8. https://www.gesetze-im-
internet.de/eeg_2014/__8.html 

 
 
                                                      
 
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connection. Certainty about the allocation of costs and benefits can be achieved by addressing this 
issue  as  part  of  the  project-specific  HANSA  between  the  three  countries.  The  TSOs,  national 
ministries and NRAs assume responsibility for this action (TenneT TSO B.V., the MoEA and ACM in 
the Netherlands; TenneT TSO GmbH, the BMWi and BNetzA in Germany; and Energinet, the MoEUC 
and DUR in Denmark) The barrier, its mitigation and the actions required to implement the mitigation 
are  summarised  in  Figure  68.  The  actions  required  to  implement  the  mitigation  measure  and  the 
stakeholders responsible for the individual actions are summarised across barriers in Figure 67. 

Figure 68: COBRA Cable barrier mitigation – Uncertainty about responsibility for project development 

Uncertainty about regulation deriving from jurisdiction over cross-border cable systems 

Project-specific  barrier  evaluation:  The  interconnector  of  the  COBRA  Cable  hybrid  project  has  its 
onshore connection points in the Netherlands and in Denmark. It thereby crosses the Dutch territorial 
sea and EEZ, the German EEZ and the Danish territorial sea and EEZ. Since Germany must grant 
the freedom of the high seas to lay cables, the Netherlands and Denmark can claim jurisdiction over 
the cable. They have done so through an agreement formulated by the project partners TenneT TSO 
B.V. and Energinet, who jointly construct and operate the interconnector.184 

However, since the OWF serves to exploit marine resources within the German EEZ, Germany has 
jurisdiction over the OWF installation and the export cable system (jurisdiction ends at the offshore 
converter station). Thus, the jurisdiction over the cable system, which includes the interconnector and 
the export cable system, might be concurrent. As a result, the regulation applicable to the export cable 
system  derived  from  German  jurisdiction,  and  to  the  interconnector  derived  from  the  agreement 
formed by TenneT TSO B.V. and Energinet, might contradict each other. 

Barrier mitigation: The mitigation option identified as most feasible is to  obtain all required permits 
and to align regulation deriving from concurrent jurisdiction over  the  operation  of  the cross-border 
cable  system  between 
the 
interdependencies shown in Table 4, interaction with project stakeholders (see Chapter 5.4.2) and 
the ease of implementation in terms of the required effort. 

is  based  on  consideration  of 

involved.  This 

the  countries 

184 TenneT Holding B.V., Energinet. 2018. COBRACable. http://www.cobracable.eu/ 

Uncertainty about responsibility for project development>Assign responsibility for  grid connection to TenneT TSO GmbH in collaboration with TenneT TSO B.V. and Energinet>Validate grid connection responsibility of TenneT TSO GmbH in collaboration with TenneT TSO B.V. and Energinet>Align mode of collaboration >Define applicable first connection and G-charges in alignment with the NL, DE and DK>Clarify grid connection responsi-bilityfor OWF under DE law>If required, adjust DE regulation>Ensure fair allocation of costs and benefits across stakeholdersBarrierMitigation measureActions 
 
 
 
                                                      
 
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The  other  mitigation  option  considered  besides  aligning  regulation  deriving  from  concurrent 
jurisdiction  was  to  define  regulation  deriving  from  German  jurisdiction  as  applicable  to  the  cable 
systems linking the German OWF to the COBRA Cable interconnector.  

The  mitigation  option  identified  as  most  feasible  was  selected  for  the  following  reasons:  The 
application  of  operational  rules  deriving  from  German  regulation  is  legally  feasible.  But  additional 
alignment  would  be  necessary  as  different  operational  regulations  apply  to  the  COBRA  Cable 
interconnector as compared to the cable system connecting the German OWF to the COBRA Cable 
interconnector. At the same time, the alignment of operational rules deriving from Dutch, German and 
Danish regulations can be a lengthy process. However, such alignment reflects the interests of all 
countries involved in the alignment. It can potentially be based on the existing agreements established 
for the COBRA Cable interconnector between the Netherlands, Germany and Denmark. 

Regarding interdependencies, this barrier is interdependent with the following two barriers: "failure of 
developers to align planning across assets and countries" and "uncertainty about responsibility and 
rules to provide access to maritime space for OWFs (tender design)". Obtaining all required permits 
and aligning regulation is facilitated by continuous dialogue and early-stage alignment. Furthermore, 
aligned operational regulation needs to be reflected in the requirements of the OWF tender. 

Actions and responsibilities for mitigation implementation: To implement this mitigation measure for 
the COBRA Cable hybrid project, the following actions are required: 

▪  For  development  and  construction,  clarify  the  permits  for  the  export  cable  system  that  are 
required under German regulations. Compliance with the environmental and technical rules under 
German regulations can be ensured by obtaining these permits. This can be achieved through 
voluntary cooperation between TenneT TSO GmbH, the BMWi and the BSH (supported by the 
Federal Environment Agency).  

▪ 

If required, change the national permit procedures for the specific hybrid project. Guidance from 
project-specific  developers  in  the  form  of  an  inventory  of  environmental  and  technical  rules  is 
required to inform changes to the permit procedures. Certainty about changes can be achieved 
by  addressing  this  issue  as  part  of  the  project-specific  HANSA  between  the  Netherlands, 
Germany and Denmark. The national ministries would assume responsibility for this action (the 
MoEA in the Netherlands, the BMWi in Germany (supported by regional governments) and the 
MoEUC in Denmark). 

▪  For  the  operational  phase,  align  the  applicable  national  regulations  arising  from  concurrent 
jurisdiction for the specific hybrid  project. The required alignment may concern  liability issues, 
control  system  operations  (voltage  levels,  grid  synchronisation  etc.)  and  matters  discussed  in 
relation to other barriers. Also consider existing national and EU legal frameworks such as the 
System  Operations  regulation  (Regulation  (EU)  2017/1485)185  and  the  CACM  regulation 
(Regulation (EU) 2015/1222)186. Guidance from project-specific developers is required to inform 
the alignment. Certainty about the alignment of operational rules can be achieved by addressing 
this  issue  as  part  of  the  project-specific  HANSA  between  the  Netherlands,  Germany  and 
Denmark. The national ministries and NRAs assume responsibility for this action (the MoEA and 

185 European Commission. 2017. Commission Regulation (EU) 2017/1485 establishing a guideline 
on electricity transmission system operation. https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:32017R1485&from=DE 

186 European Commission. 2015. COMMISSION REGULATION (EU) 2015/1222 establishing a 
guideline on capacity allocation and congestion management. https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:32015R1222&from=EN 

 
 
                                                      
 
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ACM in the Netherlands, the BMWi and BNetzA in Germany as well as the MoEUC and DUR in 
Denmark). 

The  barrier,  its  mitigation  and  the  actions  required  to  implement  the  mitigation  are  summarised  in 
Figure  69.  The  actions  required  to  implement  the  mitigation  measure  and  the  stakeholders 
responsible for the individual actions are summarised across barriers in Figure 67. 

Figure 69: COBRA Cable barrier mitigation – Uncertainty about regulation deriving from jurisdiction over cross-
border cable systems 

Uncertainty about market arrangements 

Project-specific barrier evaluation: The clarification of commercial flows is required for the COBRA 
Cable hybrid project. This is because the potential OWF site is located in the German EEZ, whereas 
the onshore grid connection points of the interconnector, connecting the OWF to shore, are in the 
Netherlands and Denmark. So, while the OWF physically feeds electricity into the Dutch or Danish 
markets,  commercial  flows  to  the  Dutch,  (virtually)  to  the  German  or  to  the  Danish  market  are 
possible. Hence commercial flows for the OWF included in the hybrid project must be clarified. 

Barrier mitigation: The mitigation option identified as most feasible is to implement a dedicated bidding 
zone  for  the  OWF  in  the  hybrid  project.  This  is  based  on  consideration  of  the  interdependencies 
shown  in  Table  4,  interaction  with  project  stakeholders  (see  Chapter  5.4.3)  and  the  ease  of 
implementation in terms of the required effort.  

The other mitigation options considered in this study were (1) to implement commercial flows either 
to the Dutch or the Danish bidding zone, (2) to implement commercial (virtual) flows to the German 
market, (3) to implement dynamic commercial flows from the OWF to the high-price market and (4) 
to implement dynamic commercial flows from the OWF to the low-price market.  

The mitigation option identified as most feasible was selected for the following reasons: Implementing 
a  dedicated  bidding  zone  for  the  OWF  in  the  hybrid  project  is  covered  under  existing  market 
regulations, although it may necessitate a comprehensive bidding zone review process. The other 
mitigation  options  are  not  covered  under  existing  market  regulations.  Indeed,  options  (3)  and  (4) 
violate the existing CACM regulation (Regulation (EU) 2015/1222)187 regarding the requirement for 
the stability of bidding zones across market time frames. Furthermore, while the selected mitigation 
option has no business case implications for the OWF in the hybrid project, establishing a dedicated 
bidding  zone does impact  the business case of the COBRA  Cable  interconnector. This potentially 
makes additional compensation necessary. However, the need for  additional compensation is also 
given  for  either  the  OWF  in  options  (1)  and  (4),  or  the  interconnector  in  options  (2)  and  (3).  The 
selected mitigation option also allows for the transmission of electricity generated by the OWF in the 

187 European Commission. 2015. COMMISSION REGULATION (EU) 2015/1222 establishing a 
guideline on capacity allocation and congestion management. Article 33. https://eur-
lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32015R1222&from=EN 

BarrierMitigation measureActionsUncertainty about regulation deriving from jurisdiction over cross-border cable systems>Obtain required permits for development and construction of export cable system>Align rules and regulations for operation of interconnector with export cable system>Clarify required permits >If required, change national permit procedures>Align applicable national regulations (operational rules) 
 
 
 
                                                      
 
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hybrid  project  to  the  other  market  in  case  of  outages  or  maintenance.  It  can  therefore  reduce  the 
curtailment of the OWF. 

Regarding  interdependencies,  this  barrier  is  interdependent  with  the  following  two  barriers: 
"uncertainty about hybrid cable system classification" and "uncertainty about applicable RES subsidy 
scheme". The implementation of a new bidding  zone for the OWF in the hybrid  project  requires a 
change in definition of the cable systems. It  implies defining the cable systems as interconnectors 
between the new bidding zone established for the German OWF and the Dutch and Western Danish 
bidding zones. Such a definition may affect the business case of the OWF in the hybrid project and 
thereby potentially the level of required subsidies. 

Actions and responsibilities for mitigation implementation: To implement this mitigation measure for 
the COBRA Cable hybrid project, the following actions are required: 

▪  Clarify  whether  a  bidding  zone  review  process  in  accordance  with  the  CACM  regulation 
(Regulation (EU) 2015/1222) Article 32 (4)188 is required to establish an additional bidding zone 
containing only the OWF in the COBRA Cable hybrid project. It is especially important to clarify 
whether the regular bidding zone review process should be adhered to, or whether a shortened 
bidding  zone  review  process  is  possible.  Clarification  is  also  required  on  the  feasibility  of 
establishing a bidding zone without consumers, and to compatibility with the CACM regulation. 
This action can be achieved through voluntary cooperation between TenneT TSO B.V., TenneT 
TSO  GmbH  and  Energinet,  as  well  as  the  European  Commission,  initiated  by  the  BMWi  in 
Germany. 

▪  Conduct a joint market simulation between Nordpool and EPEX Spot, for example, to assess the 
impact of the different market arrangements. Insights into the effects of the market arrangements 
are especially important in these three areas: congestion of the COBRA Cable interconnector; 
efficient price formation across the different bidding zones; and curtailment of the OWF linked to 
the COBRA Cable. This action can be achieved through voluntary cooperation between TenneT 
TSO B.V., TenneT TSO GmbH and Energinet, initiated by the BMWi in Germany. 

▪  Assess and agree whether additional compensation for the interconnector operators is required, 
as the interconnector was not developed as part of the hybrid project from the beginning. Due 
consideration should be given to the results of the joint market simulation. The OWF developer, 
however, is compensated through an RES subsidy scheme by bidding for the required subsidy 
level in a competitive process. For this, the OWF developer needs clarity on the market conditions 
applicable to the OWF in the future. This can be achieved through voluntary cooperation between 
TenneT TSO B.V., TenneT TSO GmbH and Energinet as well as national ministries and NRAs 
(the MoEA and ACM in the Netherlands, the BMWi and BNetzA in Germany, and the MoEUC 
and DUR in Denmark). Cooperation should also take place with the European Commission. 

▪  Ensure  compatibility  with  the  measures  adopted  to  mitigate  the  barrier  "disproportionate 
allocation  of  costs  and  benefits  across  involved  stakeholders".  Achieve  this  through  the  fair 
reallocation among the Netherlands, Germany and Denmark of costs and benefits deriving from 
the market arrangement. Certainty about the allocation of costs and benefits can be achieved by 
addressing this issue as part of the project-specific HANSA between the three countries. TSOs 
as well as the national ministries and NRAs assume responsibility for this action (TenneT TSO 

188 European Commission. 2015. COMMISSION REGULATION (EU) 2015/1222 establishing a 
guideline on capacity allocation and congestion management. Article 32 (4). https://eur-
lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32015R1222&from=EN 

 
 
                                                      
 
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B.V.,  the  MoEA  and  ACM  in  the  Netherlands;  TenneT TSO  GmbH,  the  BMWi  and  BNetzA  in 
Germany; and Energinet, the MoEUC and DUR in Denmark). 

The  barrier,  its  mitigation  and  the  actions  required  to  implement  the  mitigation  are  summarised  in 
Figure  70.  The  actions  required  to  implement  the  mitigation  measure  and  the  stakeholders 
responsible for the individual actions are summarised across barriers in Figure 67. 

Figure 70: COBRA Cable barrier mitigation – Uncertainty about market arrangements 

Uncertainty about hybrid cable system classification 

Project-specific barrier evaluation: The interconnector included in the COBRA Cable hybrid project 
functions as a hybrid cable system. This is because it serves two distinct and legally differentiated 
functions.  Regulation  (EC)  714/2009189  defines  an  interconnector  as  "a  transmission  line  which 
crosses or spans a border between Member States and which connects the national transmission 
systems of the Member States." A conventional export cable system provides for the transmission of 
electricity generated by the OWF to an onshore connection point without crossing borders. But in the 
hybrid setup, the COBRA Cable interconnector provides for the transmission of electricity generated 
by  the  OWF  and  market-to-market  flows.  Such  dual  functionality  prevents  straight-forward 
classification of the cable system under both EU and national legislation and regulations as either an 
export cable system or an interconnector. 

Barrier mitigation: The mitigation option identified as most feasible is to define the cable systems as 
interconnectors between the new bidding zone established for the German OWF and the Dutch and 
Western Danish bidding zones. This is based on consideration of the interdependencies shown in 
Table 4, interaction with project stakeholders (see Chapter 5.4.4) and the ease of implementation in 
terms of the required effort.  

The other mitigation options considered in this study were to (1) define the cable systems between 
the German OWF and the Dutch and Western Danish bidding zones as export cable systems, with 
leftover capacities available for interconnector functionality and to (2) define them as interconnectors 
with leftover capacities available for transmission from the OWF to the shores.  

The mitigation option identified as most feasible was selected for the following reasons: The mitigation 
option to define the cable systems between the German OWF and the Dutch and Western Danish 
bidding zones as interconnectors is based on the existing regulatory framework for interconnectors. 
By contrast, the other considered mitigations options require the definition of a new asset class and 

189 European Parliament, European Council. 2009. REGULATION (EC) No. 714/2009 on conditions 
for access to the network for cross-border exchanges in electricity. Article 2 (1). https://eur-
lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32009R0714&from=EN 

Uncertainty about market arrangements>Implement a dedicated bidding zone for the OWF included in the hybrid project>Clarify need for and extent of bidding zone review process>Conduct a joint market simulation>Assess and agree whether additional compensation for IC operators is required>Ensure fair allocation of costs and benefits across stakeholdersBarrierMitigation measureActions 
 
 
 
                                                      
 
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therefore  changes  in  European  and  potentially  in  national  regulatory  frameworks.  The  mitigation 
option was also selected due to its interdependencies with other barriers. 

Regarding interdependencies, defining the cable systems between the German OWF and the Dutch 
and Western Danish  bidding  zones as interconnectors is interdependent  with three  other barriers. 
These  are:  "uncertainty  about  market  arrangements";  the  "failure  of  developers  to  align  planning 
across assets and countries"; and "uncertainty about applicable RES subsidy scheme". Defining the 
cable  systems  between  the  German  OWF  and  the  Dutch  and  Western  Danish  bidding  zones  as 
interconnectors fits the implementation of a new bidding zone for the OWF in the hybrid project. In 
addition, such a definition may affect the business case of the OWF included in the hybrid project. 
This is due to potential curtailment of the OWF and thereby potentially the level of required subsidies. 
Curtailment of the OWF could be a consequence of competition for capacity on the cable systems 
linking the new bidding zone (including the German OWF) to the Dutch and Western Danish bidding 
zones  between  the  transmission  of  electricity  from  the  German  OWF  to  shore  and  interconnector 
flows between the connected markets. Lastly, defining the cable systems as interconnectors most 
closely  aligns  with  the  existing  COBRA  Cable  business  case. This  therefore  facilitates  continuous 
dialogue and early-stage alignment. 

Actions and responsibilities for mitigation implementation: To implement this mitigation measure for 
the COBRA Cable hybrid project, the following actions are required: 

▪  Validate whether defining the cable systems as interconnectors between the new bidding zone 
established for the  German OWF and the Dutch and Western Danish bidding  zones complies 
with Dutch, German and Danish regulations. This is required because the cable systems connect 
bidding zones but not necessarily countries. This can be achieved through voluntary cooperation 
between the national ministries and NRAs (the MoEA and ACM in the Netherlands and the BMWi 
and BNetzA in Germany). It can be initiated by the TSOs. 

▪ 

If required, adjust Dutch, German and Danish regulations to allow for interconnectors between 
the newly established bidding zone and national bidding zones in the hybrid project. Guidance 
from  project-specific  developers  is  required  to  inform  the  adjustment  of  Dutch,  German  and 
Danish regulations. Certainty about changes can be achieved by addressing this issue as part of 
the  project-specific  HANSA  between  the  Netherlands,  Germany  and  Denmark.  The  national 
ministries and NRAs assume responsibility for this action (the MoEA and ACM in the Netherlands 
as well as the BMWi and BNetzA in Germany).  

▪  Assess and agree whether additional compensation for the interconnector operators is required, 
as the interconnector  was not developed as part of the hybrid project from the beginning. The 
OWF developer, however, is compensated through an RES subsidy scheme by bidding for the 
required subsidy level in a competitive process. For this, the OWF developer needs clarity on the 
market conditions applicable to the OWF in the future. This can be achieved through voluntary 
cooperation between TenneT TSO B.V., TenneT TSO GmbH and Energinet as well as national 
ministries and NRAs (the MoEA and ACM in the Netherlands; the BMWi and BNetzA in Germany; 
and the MoEUC and DUR in Denmark). Cooperation should also take place with the European 
Commission.  

▪  Ensure  compatibility  with  the  measures  adopted  to  mitigate  the  barrier  "disproportionate 
allocation of costs and benefits across involved stakeholders". Do this through the fair reallocation 
among  the  Netherlands,  Germany  and  Denmark  of  costs  and  benefits  deriving  from  the 
classification of the cable systems as interconnectors. Certainty about the allocation of costs and 
benefits can be achieved by addressing this issue as part of the project-specific HANSA between 
the three countries. TSOs as well as the national ministries and NRAs assume responsibility for 

 
 
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this action (TenneT TSO B.V., the MoEA and ACM in the Netherlands; TenneT TSO GmbH, the 
BMWi and BNetzA in Germany; and Energinet, the MoEUC and DUR in Denmark). 

The  barrier,  its  mitigation  and  the  actions  required  to  implement  the  mitigation  are  summarised  in 
Figure  71.  The  actions  required  to  implement  the  mitigation  measure  and  the  stakeholders 
responsible for the individual actions are summarised across barriers in Figure 67. 

Figure 71: COBRA Cable barrier mitigation – Uncertainty about hybrid cable system classification 

Failure of developers to align planning across assets and countries 

Project-specific  barrier  evaluation:  The  COBRA  Cable  hybrid  project  is  made  complex  by  the 
integration of the German OWF, the export cable system linking the German OWF to the COBRA 
Cable interconnector and the COBRA Cable interconnector. As all three assets have separate permit, 
development  and  construction  timelines,  geographical  alignment  is  crucial.  IN  ad,  interoperability 
between  the  different  components  of  the  three  assets  –  based  on  the  alignment  of  technical 
specifications – must be ensured to enable the hybrid project to function. 

Barrier  mitigation:  The  mitigation  option  identified  as  most  feasible  is  to  facilitate  a  continuous 
dialogue  and  early-stage  alignment  between  the  project  developers.  Given  that  the  German 
authorities  determine  the  location  of  the  German  OWF  and  the  routing  of  the  COBRA  Cable 
interconnector is set, project developers need to align on the following: the routing of the export cable 
system and the location of substations, the specifications of the export cable system, the substations 
and the OWF in the hybrid project. This is based on consideration of the interdependencies shown in 
Table 4, interaction with project stakeholders (see Chapter 5.4.5) and the ease of implementation in 
terms of the required effort. 

Apart from continuous dialogue and early-stage alignment between the project developers, no other 
mitigation options were considered.  

Regarding  interdependencies,  this  barrier  is  interdependent  with  the  following  five  barriers: 
"uncertainty about responsibility for project development"; "uncertainty about regulation deriving from 
jurisdiction over cross-border cable systems"; "uncertainty about hybrid cable system classification"; 
"uncertainty about responsibility and rules to provide access to maritime space for OWFs (location 
selection, site pre-investigation, tender execution and tender design)"; and the "limited engagement 
of public stakeholders". Continuous dialogue and early-stage alignment are complemented by clearly 
defining responsibility for the development, construction and operation of the grid connection, as well 
as  the  need  to  obtain  all  required  permits  and  align  regulation.  However,  dialogue  and  alignment 
themselves  are  supported  by  the  following  measures  to  mitigate  other  barriers.  Aligned  OWF 
locations allow for the involvement of and coordination with the developer of the OWF in the hybrid 
project. Two factors allow for such alignment by decreasing the risk to hybrid project development 
arising  from  early-stage  project-specific  decisions:  clearly  defining  the  cable  systems  as 

Uncertainty about hybrid cable system classification>Define the cable systems as interconnectors>Validate compatibility with regulation in the NL, DE and DK>If required, adjust regulations>Assess and agree whether additional compensation for IC operators is required>Ensure fair allocation of costs and benefits across stakeholdersBarrierMitigation measureActions 
 
 
 
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interconnectors,  which  most  closely  aligns  with  the  existing  COBRA  Cable  business  case;  and 
formalising public commitment and public financial support. 

Action and responsibilities for mitigation implementation: To implement this mitigation measure for 
the COBRA Cable hybrid project, the following action is required: 

▪  Engage in a continuous dialogue to achieve early-stage alignment regarding locations, routing 
and  technical  specifications  for  the  individual  assets.  This  can  be  achieved  through  voluntary 
cooperation between TenneT TSO B.V., TenneT TSO GmbH and Energinet as well as national 
ministries and NRAs (the  MoEA, supported by  RVO  and  ACM,  in the Netherlands; the BMWi, 
supported by the BSH, and BNetzA, in Germany; and the MoEUC and DUR in Denmark). 

The  barrier,  its  mitigation  and  the  actions  required  to  implement  the  mitigation  are  summarised  in 
Figure  72.  The  actions  required  to  implement  the  mitigation  measure  and  the  stakeholders 
responsible for the individual actions are summarised across barriers in Figure 67. 

Figure 72: COBRA Cable barrier mitigation – Failure of developers to align planning across assets and 
countries 

Uncertainty about responsibility and rules to provide access to maritime space for OWFs 
(location selection, site pre-investigation, tender execution) 

Project-specific barrier evaluation: The location selection, site pre-investigation and tender execution 
of the COBRA Cable OWF is conducted by German authorities as it is located in the German EEZ. 
Due to existing  national  and international law, the construction of installations in  a given country's 
EEZ can only be granted by the coastal state. However, in the COBRA Cable hybrid project, Dutch, 
German and Danish stakeholders have an interest in those activities because both the interoperability 
of the components and the compliance with all national and European regulations must be ensured. 

Barrier mitigation: The mitigation option identified as most feasible is to conduct location selection, 
site  pre-investigation  and  tender  execution  by  and  in  accordance  with  the  rules  of  the  German 
authorities. This  is based  on consideration of the  interdependencies shown  in  Table 4,  interaction 
with project stakeholders (see Chapter 5.4.1) and the ease of implementation in terms of the required 
effort. 

Regarding  the  responsibility  for  location  selection  and  site  pre-investigation,  the  other  mitigation 
options considered in this study were to assign responsibility (1) to Dutch and / or Danish authorities 
and (2) to the OWF developer. The mitigation option identified as most feasible was selected for the 
following  reasons:  Legal  and  regulatory  applicability  of  any  responsibility  other  than  German 
responsibility is not given. Furthermore, additional alignment and coordination would be necessary 
otherwise, which likely extends the timelines of the processes. 

Regarding the responsibility for tender execution, the other mitigation options considered in this study 
were to assign Dutch and / or Danish responsibility. The mitigation option identified as most feasible 
was selected for the following reasons: Tender execution by any party other than German authorities 
entails  considerable  uncertainties  regarding  legal  and  regulatory  applicability  and  is  unlikely  to  be 
publicly supported. Additionally, tender execution by German authorities is most closely aligned with 

Failure of developers to align planning across assets and countries>Facilitate continuous dialogue and early-stage alignment between project developers>Engage in dialogue to achieve early-stage alignment regarding locations, routing and technical specifications of assetsBarrierMitigation measureActions 
 
 
 
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  North Seas Offshore Energy Clusters study 

ongoing procedures. It is therefore likely to be more efficient than aligning procedures for execution 
by other parties. 

Regarding interdependencies, this barrier is interdependent with the following two barriers: "failure of 
developers  to  align  planning  across  assets  and  countries"  and  "uncertainty  about  applicable  RES 
subsidy  scheme".  Clarifying  responsibility  for  location  selection,  site  pre-investigation  and  tender 
execution helps to determine the OWF location,  which thereby facilitates  continuous dialogue and 
early-stage alignment. Furthermore, location selection, site pre-investigation and tender execution by 
and  in  accordance  with  the  rules  of  German  authorities  fits  the  provision  of  a  subsidy  scheme  by 
German authorities. 

Actions and responsibilities for mitigation implementation: To implement this mitigation measure for 
the COBRA Cable hybrid project, the following actions are required: 

▪  Facilitate the development of the COBRA Cable hybrid project by agreeing that the responsibility 
for  location  selection,  site  pre-investigation  and  tender  execution  remains  with  the  German 
authorities.  Certainty  on  these  three  factors  can  be  achieved  by  addressing  this  issue  in  the 
project-specific  HANSA  between  the  Netherlands,  Germany  and  Denmark.  The  national 
ministries  and  other  national  authorities  assume  responsibility  for  this  action  (the  MoEA 
(supported  by  the  Dutch  Ministry  of  Infrastructure  and  Water  Management)  and  RVO  in  the 
Netherlands; the BMWi and BSH in Germany; and the MoEUC in Denmark). 

▪  Ensure  compatibility  with  the  measures  adopted  to  mitigate  the  barrier  "disproportionate 
allocation of costs and benefits across involved stakeholders". Do this through the fair reallocation 
among  the  Netherlands,  Germany  and  Denmark  of  costs  and  benefits  deriving  from  the 
responsibility for location selection, site pre-investigation and tender execution. Certainty about 
the  allocation  of  costs  and  benefits  can  be  achieved  by  addressing  this  issue  in  the  project-
specific  HANSA  between  the  three  countries.  The  national  ministries  and  NRAs  assume 
responsibility  for  this  action  (the  MoEA  and  ACM  in  the  Netherlands;  the  BMWi  and  BNetzA, 
supported  by  the  Federal  Environment  Agency,  in  Germany;  and  the  MoEUC  and  DUR  in 
Denmark). 

The  barrier,  its  mitigation  and  the  actions  required  to  implement  the  mitigation  are  summarised  in 
Figure  73.  The  actions  required  to  implement  the  mitigation  measure  and  the  stakeholders 
responsible for the individual actions are summarised across barriers in Figure 67. 

Figure 73: COBRA Cable barrier mitigation – Uncertainty about responsibility and rules to provide access to 
maritime space for OWFs (location selection, site pre-investigation, tender execution) 

Uncertainty about responsibility and rules to provide access to maritime space for OWFs 
(tender design) 

Project-specific barrier evaluation: A suitable tender design needs to be chosen for the COBRA Cable 
hybrid project. The OWF included in the project setup is located in the German EEZ and is linked to 
onshore connection points in the Netherlands and Denmark via the COBRA Cable interconnector. As 

Uncertainty about responsibility and rules to provide access to maritime space for OWFs (location selection, site pre-investigation, tender execution)>Conduct location selection, site pre-investigation and tender execution by and in accordance with the rules of German authorities>Agree that German responsibility for location selection, site pre-investigation and tender execution remains in place>Ensure fair allocation of costs and benefits across stakeholdersBarrierMitigation measureActions 
 
 
 
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this interconnector is scheduled to be commissioned in 2019.190 the design of the OWF to be linked 
to  the  COBRA  Cable  at  a  later  point  must  adapt  to  the  interconnector’s  operational  and  technical 
setup. Thus, the Netherlands, Germany and Denmark have an interest in defining the requirements 
for the OWF development in accordance with their respective standards. These may be contradictory. 
In addition, the tender design needs to ensure that  tender candidates can realistically develop the 
OWF.  

Barrier mitigation: The mitigation option identified as most feasible is to implement a tender design 
with strict requirements. These should be aligned between the Netherlands, Germany and Denmark 
and eliminate all hybrid-specific uncertainties for the OWF developer. This is based on consideration 
of the interdependencies shown in Table 4, interaction with project stakeholders (see Chapter 5.4.7) 
and the ease of implementation in terms of the required effort. 

The  other  mitigation  options  considered  in  this  study  were  (1)  to  have  a  strict  tender  design  with 
requirements  aligned  among  the  stakeholders,  (2)  to  have  a  strict  tender  design  without  hybrid-
specific  uncertainties  for  the  OWF  developer,  and  (3)  to  have  a  lenient  tender  design  with 
requirements aligned among the stakeholders and without hybrid-specific uncertainties for the OWF 
developer.  

The mitigation option identified as most feasible was selected for the following reasons: While aligned 
requirements  potentially  necessitate  amendments  to  national  legislation  and  regulations,  the 
Netherlands,  Germany  and  Denmark  have  valid  interests  in  defining  certain  requirements  for  the 
tender of the OWF connected to the COBRA Cable interconnector. Aligned requirements also aid in 
ensuring the interoperability of the OWF with the other assets of the hybrid project. All of these factors 
increase the probability of successful hybrid project implementation.  Furthermore, a tender  design 
with strict requirements also increases the probability of successful project implementation, allowing 
for  a  possible  decrease  in  the  cost  efficiency  of  the  OWF  development  due  to  more  limited 
competition. Lastly, certainty about hybrid-specific characteristics of the OWF development increases 
the probability of successful project implementation – and decreases the cost of implementation – by 
reducing the risk premium otherwise demanded by OWF developers in terms of subsidies. 

Regarding  interdependencies,  this  barrier  is  interdependent  with  the  following  three  barriers: 
"uncertainty about regulation deriving from jurisdiction over cross-border cable systems"; the "failure 
of developers to align planning across assets and countries"; and "uncertainty about applicable RES 
subsidy scheme". Aligned regulation deriving from Dutch, German and Danish jurisdiction needs to 
be  reflected  in  the  requirements  of  the  OWF  tender.  In  addition,  the  OWF  tender  can  include  a 
German subsidy scheme aligned with the Netherlands and Denmark, involving statistical transfers 
between  the  three  countries.  Continuous  dialogue  and  early-stage  alignment  facilitate  an  aligned 
tender design.  

Actions and responsibilities for mitigation implementation: To implement this mitigation measure for 
the COBRA Cable hybrid project, the following actions are required: 

▪  Agree a tender design with strict requirements. Certainty about the tender design can be achieved 
by  addressing  this  issue  as  part  of  the  project-specific  HANSA  between  the  Netherlands, 
Germany  and  Denmark.  The  national  ministries,  NRAs  and  other  national  authorities  assume 
responsibility for this action (the MoEA, ACM and RVO in the Netherlands; the BMWi, BNetzA 
and BSH in Germany; and the MoEUC and DUR in Denmark). 

190 TenneT Holding B.V., Energinet. 2018. COBRACable. http://www.cobracable.eu/ 

 
 
                                                      
 
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▪  Agree tender requirements which take account of the valid interest of all three countries. In the 
Netherlands  and  Denmark,  this  means  defining  material  requirements  such  as  technical  and 
operational  standards  in  alignment  with  the  specifics  of  the  COBRA  Cable  interconnector.  In 
Germany  it  means  defining  environmental  standards.  Like  environmental  standards,  financial 
requirements  do  not  need  to  be  aligned  across  countries.  Guidance  from  project-specific 
developers  is  required  to  inform  the  development  of  project-specific  tender  requirements. 
Certainty  about  tender  requirements  can  be  achieved  by  addressing  this  issue  as  part  of  the 
project-specific  HANSA  between  the  Netherlands,  Germany  and  Denmark.  The  national 
ministries, NRAs and other national authorities assume responsibility for this action (the MoEA, 
ACM and RVO in the Netherlands; the BMWi, BNetzA and BSH in Germany; and the MoEUC 
and DUR in Denmark). 

The  barrier,  its  mitigation  and  the  actions  required  to  implement  the  mitigation  are  summarised  in 
Figure  74.  The  actions  required  to  implement  the  mitigation  measure  and  the  stakeholders 
responsible for the individual actions are summarised across barriers in Figure 67. 

Figure 74: COBRA Cable barrier mitigation – Uncertainty about responsibility and rules to provide access to 
maritime space for OWFs (tender design) 

Uncertainty about applicable RES subsidy scheme 

Project-specific barrier evaluation: The OWF included in the COBRA Cable hybrid project is located 
in  the  German  EEZ,  which  suggests  a  German  RES  subsidy  scheme.  However,  the  following 
schemes are also possible: a Dutch or Danish subsidy scheme, and a joint project or a joint support 
scheme  between  the  Netherlands,  Germany  and  Denmark.  All  are  in  line  with  EU  Directive 
2009/28/EC191 on the promotion of the use of energy from RES. In summary, the applicability of a 
support scheme from one of the countries involved or in some joint form is to be determined. 

Barrier  mitigation:  The  mitigation  option  identified  as  most  feasible  is  to  apply  the  German  RES 
subsidy  scheme  to  the  OWF  in  the  hybrid  project,  potentially  with  statistical  transfers  between 
countries. This means the German government awards the OWF a premium tariff through the German 
tender  process,  potentially  through  a  special  additional  tender  round  ("Sonderausschreibung").192 
This is based on consideration of the interdependencies shown in  Table 4, interaction with project 
stakeholders (see Chapter 5.4.12) and the ease of implementation in terms of the required effort. 

The other mitigation options considered in this study were (1) to apply a Dutch subsidy scheme, (2) 
to apply a Danish subsidy scheme, (3)  to apply a joint project between the Netherlands, Germany 
and Denmark or (4) to apply no subsidy scheme.  

191 European Parliament, European Council. 2009. DIRECTIVE 2009/28/EC on the promotion of the 
use of energy from renewable sources. https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:32009L0028&from=EN 

192 CDU, CSU, SPD. 2018. Koalitionsvertrag zwischen CDU, CSU und SPD. 
https://www.cdu.de/system/tdf/media/dokumente/koalitionsvertrag_2018.pdf?file=1 

Uncertainty about responsibility and rules to provide access to maritime space for OWFs (tender design)>Implement tender design with strict tender requirements which are aligned between NL, DE and DK and eliminate all hybrid-specific uncertainties>Agree tender design with strict requirements>Agree tender requirements considering the interests of NL, DE and DKBarrierMitigation measureActions 
 
 
 
                                                      
 
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The mitigation  option  identified as most feasible  was selected for the following reasons:  The legal 
feasibility  of  applying  a  Dutch  or  Danish  subsidy  scheme  to  the  German  OWF  is  not  given.  The 
feasibility of tendering the OWF without a subsidy scheme depends on the ability of OWF developers 
to  obtain  offtake  securities  such  as  power  purchase  agreements.  Such  agreements  ensure  the 
bankability of the OWF investment. Establishing a joint project between the Netherlands, Germany 
and Denmark is legally covered and provides the necessary bankability. But it might be problematic 
due to the extended timeline, which is needed to agree the specifications of the scheme and formulate 
the necessary legal agreements. In addition, the national regulations in the Netherlands, Germany 
and Denmark and the specifications of the COBRA Cable hybrid project render a joint support scheme 
difficult. The Netherlands require that the generated electricity must not be fed into the Dutch grid and 
that the electricity prices of the relevant area apply.193 Additional requirements in Germany are the 
mutuality of the scheme, the possibility of physical transmission of electricity to Germany (or a similar 
effect on the German electricity market), plus an Intergovernmental Agreement (IGA) between the 
countries involved.194 In Denmark, existing legislation only allows subsidies to be allocated to OWFs 
located in Danish territorial waters or the Danish EEZ. This is because tenders for OWF licences, on 
which financial support depends, are conducted only in these areas.195 In addition, the requirements 
laid down in the EU Directive 2009/28/EC196 must be fulfilled. Applying the German subsidy scheme 
to the OWF is potentially viable from a legal and regulatory perspective. Nonetheless, the date and 
duration of a special tender round are unknown and could potentially delay project development. 

Regarding  interdependencies,  this  barrier  is  interdependent  with  the  following  three  barriers: 
"uncertainty about market arrangements"; "uncertainty about hybrid cable system classification"; and 
"uncertainty about responsibility and rules to provide access to maritime space for OWFs (location 
selection, site pre-investigation, tender execution and tender design)". A new dedicated bidding zone 
for the hybrid OWF is accompanied by defining the cable systems as interconnectors linking the new 
bidding  zone to shore. The market price established in  the new  bidding  zone affects the business 
case  of  the  OWF  included  in  the  hybrid  project  and  thereby  the  level  of  required  RES  subsidies. 
Furthermore, applying a German subsidy, potentially involving statistical transfers between the three 
countries to the OWF fits with location selection, site pre-investigation and tender execution by and 
in accordance with the rules of German authorities. It also fits with a tender design with aligned, strict 
requirements. 

Actions and responsibilities for mitigation implementation: To implement this mitigation measure for 
the COBRA Cable hybrid project, the following actions are required: 

▪  Clarify  the  possibility  and  the  dates  for  a  special  tender  round  ("Sonderaussschreibung")  in 
Germany to allow for a timely award of the subsidy scheme to the OWF. This can be achieved 
through voluntary cooperation between the BMWi, the BNetzA and BSH in Germany. 

▪  Ensure that the envisaged mitigation of assigning a German subsidy scheme to the OWF included 
in  the  hybrid  project  complies  with  German  law.  German  subsidy  schemes  have  regular 

193 Dutch Besluit stimulering duurzame energieproductie 2007. §5a Article 55b. 
https://wetten.overheid.nl/BWBR0022735/2017-04-01#Paragraaf5a_Artikel55b  

194 German Erneuerbare-Energien-Gesetz 2017 (EEG 2017). § 5 (3). https://www.gesetze-im-
internet.de/eeg_2014/__8.html  

195 Danish Bekendtgørelse af lov om fremme af vedvarende energi. § 22, § 23 and §37. 
https://www.retsinformation.dk/Forms/R0710.aspx?id=203053  

196 European Parliament, European Council. 2009. DIRECTIVE 2009/28/EC on the promotion of the 
use of energy from renewable sources. Article 11. https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:32009L0028&from=EN 

 
 
                                                      
 
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characteristics in terms of type, level and duration of support as  well as technology coverage. 
Clarify  whether  statistical  transfers  to  the  renewable  energy  target  of  Germany  based  on  the 
electricity generated by the OWF in the hybrid project – which commercially and physically feeds 
electricity into the Dutch or Danish market – are required to access the German subsidy scheme. 
This assumes that the electricity physically flowing into the Dutch or Danish market has a similar 
effect  on  the  German  market  as  if  the  electricity  would  be  physically  flowing  into  the  German 
market. Pay particular attention to the stipulations laid down in the Renewable Energy Sources 
Act (EEG) §5 (3)197, i.e. with regard to the mutuality of the scheme and the possible coverage of 
the scheme in an IGA. This can be achieved through voluntary engagement of the BMWi and the 
BNetzA in Germany. 

▪ 

It may be that statistical transfers to Germany are required but are not sufficient to allow for the 
applicability of the German RES subsidy scheme to the OWF in the hybrid project. If so, assess 
the implications of the required onshore grid reinforcements to allow for the physical transmission 
of electricity from the Netherlands or Denmark to Germany. This action could be achieved through 
voluntary cooperation between TenneT TSO B.V., TenneT TSO GmbH and Energinet. 

▪  Otherwise, adjust German regulations, particularly the Renewable Energy Sources Act (EEG) §5 
(3), to ensure that statistical transfers to Germany are sufficient for applying the German RES 
subsidy scheme to the OWF in the hybrid project. Guidance from project-specific developers is 
required to inform the adjustment of German regulation. Certainty about German regulation can 
be  achieved  by  addressing  this  issue  as  part  of  the  project-specific  HANSA  between  the 
Netherlands,  Germany  and  Denmark.  The  BMWi  and  BNetzA  in  Germany  would  assume 
responsibility for this action. 

▪  Ensure  compatibility  with  the  measures  adopted  to  mitigate  the  barrier  "disproportionate 
allocation of costs and benefits across involved stakeholders". Do this through the fair reallocation 
among  the  Netherlands,  Germany  and  Denmark  of  costs  and  benefits  deriving  from  the  RES 
subsidy  scheme.  Certainty  about  the  allocation  of  costs  and  benefits  can  be  achieved  by 
addressing  this  issue  as  part  of  the  project-specific  HANSA  between  the  three  countries.  The 
OWF developer, national ministries and NRAs assume responsibility for this action (the MoEA 
and ACM in the Netherlands; the BMWi and BNetzA in Germany; and the MoEUC and DUR in 
Denmark). 

The  barrier,  its  mitigation  and  the  actions  required  to  implement  the  mitigation  are  summarised  in 
Figure  75.  The  actions  required  to  implement  the  mitigation  measure  and  the  stakeholders 
responsible for the individual actions are summarised across barriers in Figure 67. 

197 German Erneuerbare-Energien-Gesetz 2017 (EEG 2017). § 5 (3). https://www.gesetze-im-
internet.de/eeg_2014/__8.html  

 
 
 
                                                      
 
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Figure 75: COBRA Cable barrier mitigation – Uncertainty about applicable RES subsidy scheme 

Limited engagement of public stakeholders 

Project-specific barrier evaluation: The support of public stakeholders is needed for the successful 
implementation  of  the  COBRA  Cable  hybrid  project  as  regulatory  and  technical  barriers  must  be 
overcome and financial support provided across three countries, namely, the Netherlands, Germany 
and Denmark. 

Barrier mitigation: The mitigation option identified as most feasible is to formalise public commitment 
in  the  form  of  a  project-specific  MoU  or  a  project-specific  HANSA.  Feasibility  studies  and  scoping 
studies  for  early-stage  alignment  through  public  funding,  for  example,  should  also  be  facilitated. 
Furthermore, adequate de-risking of the hybrid project is required. This is based on consideration of 
the interdependencies shown in Table 4, interaction with project stakeholders (see Chapter 5.4.13) 
and the ease of implementation in terms of the required effort. 

Besides  formalising  public  commitment  in  the  form  of  a  project-specific  MoU  or  a  project-specific 
HANSA and facilitating feasibility studies and scoping studies or providing financial guarantees, no 
other mitigation option was considered.  

Regarding interdependencies, this barrier is interdependent with  the "failure of developers to align 
planning  across  assets  and  countries"  barrier.  Continuous  dialogue  and  early-stage  alignment 
between the project developers is facilitated by formalising the commitment of relevant stakeholders 
of the hybrid project and / or by providing public funding for early-stage activities. These may include 
feasibility studies, scoping studies and technical research and development. 

Actions and responsibilities for mitigation implementation: To implement this mitigation measure for 
the COBRA Cable hybrid project, the following actions are required: 

▪  Align and implement the type of formalisation of public commitment to allow for the development 
of the COBRA Cable hybrid project. The formalisation of commitment  in the form of a project-
specific MoU or a project-specific HANSA is an expression of the goodwill of the stakeholders to 
support hybrid project development. It assures project developers of public support, e.g. in the 
form of dialogue with relevant government bodies. In early project stages, a project-specific MoU 
provides sufficient certainty for project developers. The stakeholders assuming responsibility are 
TenneT TSO  B.V.,  TenneT  TSO  GmbH,  Energinet  and  the  national  ministries  and  NRAs  (the 
MoEA and ACM in the Netherlands; the BMWi and BNetzA in Germany; and the MoEUC and 
DUR in Denmark). They also include the European Commission. In later project stages, a project-
specific  HANSA  is  required  to  provide  project  developers  with  sufficient  legal  certainty.  The 
stakeholders  assuming  responsibility  include  the  national  ministries  (the  MoEA  in  the 
Netherlands, the BMWi in Germany and the MoEUC in Denmark) and the European Commission. 

▪  Catalyse  the  development  of  the  COBRA  Cable  hybrid  project  by  supporting  the  early-stage 
alignment among developers. Do this through public funding for feasibility studies, pilot projects 

Uncertainty about applicable RES subsidy scheme>Apply German subsidy scheme to OWF included in hybrid project>Clarify possibility and dates for special tender round in DE>Ensure compatibility of envisaged mitigation option with DE law>If required, assess implications of onshore grid reinforcement>Otherwise, adjust DE regulation>Ensure fair allocation of costs and benefits across stakeholdersBarrierMitigation measureActions 
 
 
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and R&D for innovative, technological solutions in addition to existing offshore support schemes. 
Such public support allows developers to firmly commit to the development of the project. This 
can be achieved through voluntary cooperation between the national ministries (the MoEA in the 
Netherlands, the BMWi in Germany and the MoEUC in Denmark) and the European Commission. 

▪  Support the de-risking of the hybrid project by providing financial guarantees. Such guarantees 
can reassure project developers in situations which cannot be foreseen due to the pilot character 
of  the  hybrid  project.  This  can  be  achieved  through  voluntary  cooperation  between  the  TSOs 
(TenneT TSO B.V., TenneT TSO GmbH and Energinet) and the European Commission. 

▪  Ensure  compatibility  with  the  measures  adopted  to  mitigate  the  barrier  "disproportionate 
allocation of costs and benefits across involved stakeholders". Do this through the fair reallocation 
among  the  Netherlands,  Germany  and  Denmark  of  costs  and  benefits  deriving  from  the 
engagement of public stakeholders. Certainty about the allocation of costs and benefits can be 
achieved  by  addressing  this  issue  as  part  of  the  project-specific  HANSA  between  the  three 
countries. The national ministries and NRAs assume responsibility for this action. (the MoEA and 
ACM  in  the  Netherlands;  the  BMWi  and  BNetzA  in  Germany;  and  the  MoEUC  and  DUR  in 
Denmark).  

The  barrier,  its  mitigation  and  the  actions  required  to  implement  the  mitigation  are  summarised  in 
Figure  76.  The  actions  required  to  implement  the  mitigation  measure  and  the  stakeholders 
responsible for the individual actions are summarised across barriers in Figure 67.  

Figure 76: COBRA Cable barrier mitigation – Limited engagement of public stakeholders 

Disproportionate allocation of costs and benefits across involved stakeholders 

Project-specific barrier evaluation: Agreeing on the allocation  of costs and benefits  in  the COBRA 
Cable hybrid project is complex. The OWF site is geographically located in the German EEZ, whereas 
the onshore grid connection points are in the Netherlands and Denmark. Certain costs and benefits 
are  initially  incurred  by  Germany  and  certain  costs  and  benefits  are  initially  incurred  by  the 
Netherlands and Denmark due to the technical setup and the details of the hybrid project. In addition, 
the measures adopted to mitigate other barriers assign costs or distribute benefits to the Netherlands, 
Germany and Denmark. Furthermore, developers may  realise  additional benefits. Thus, costs and 
benefits are generally not distributed fairly, and no suitable approach exists to reallocate the costs 
and benefits across all stakeholders of the hybrid project.  

Barrier mitigation: The mitigation option identified as most feasible is to reallocate costs and benefits 
deriving  from  the  hybrid  project  where  required,  based  on  a  project-specific  process.  In  some 
respects,  the  process  can  be  based  on  the  existing  methodology  given  by  the  Cross-Border  Cost 

Limited engagement of public stakeholders>Formalise public commitment >Facilitate early-stage alignment through public funding and support de-risking of hybrid project>Align and implement formalisation of public commitment (in early project stages in form of MoU, later HANSA)>Support early-stage alignment among developers through public funding>Support de-risking of project by providing financial guarantees>Ensure fair allocation of costs and benefits across stakeholdersBarrierMitigation measureActions 
 
 
 
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Allocations (CBCA) process.198 It builds on the Cost Benefit Analysis (CBA) conducted by ENTSO-
E199 for Projects of Common Interest. In the CBCA process, benefits such as socio-economic welfare 
and CO2 emissions are calculated on a national level to compensate net losers for the implementation 
of  a  project  through  a  CBCA  decision.  The  CBCA  process  provides  a  good  starting  point  for  the 
reallocation  of  costs  and  benefits  across  countries  but  is  best  suited  for  evaluating  cross-border 
electricity interconnectors. This is based on consideration of the interdependencies shown in Table 
4, interaction with project stakeholders (see Chapter 5.4.15) and the ease of implementation in terms 
of the required effort. 

Besides implementing the process resulting in the reallocation of costs and benefits deriving from the 
implementation of the hybrid project, no other mitigation option was considered.  

Regarding  interdependencies,  this  barrier  is  interdependent  with  the  following  six  barriers: 
"uncertainty about responsibility for project development (grid connection responsibility)"; "uncertainty 
about  market  arrangements";  "uncertainty  about  hybrid  cable  system  classification";  "uncertainty 
about responsibility and rules to provide access to maritime space for OWFs (location selection, site 
pre-investigation, tender execution)"; "uncertainty about applicable RES subsidy scheme"; and the 
"limited  engagement  of  public  stakeholders".  Reallocation  also  relates  to  those  barriers.  This  is 
because their mitigation translates into costs and benefits for specific stakeholders that might have 
to be reallocated together with all other costs and benefits of the project. Therefore, the costs and 
benefits deriving from all six interdependent barriers must be considered. 

Actions and responsibilities for mitigation implementation: To implement this mitigation measure for 
the COBRA Cable hybrid project, the following actions are required: 

▪ 

Identify  relevant  cost  and  benefit  categories  between  the  involved  stakeholders,  covering  all 
significant  aspects  of  the  hybrid  project.  This  can  be  achieved  through  voluntary  cooperation 
between  TSOs  (TenneT  TSO  B.V.  in  the  Netherlands,  TenneT  TSO  GmbH  in  Germany  and 
Energinet  in  Denmark)  as  well  as  national  ministries  and  NRAs  (the  MoEA  and  ACM  in  the 
Netherlands; the BMWi and BNetzA in Germany; and the MoEUC and DUR in Denmark). 

▪  Ensure that due consideration is given to all costs and benefits deriving from measures adopted 
to  mitigate  the  following  barriers:  "uncertainty  about  responsibility  for  project  development"; 
"uncertainty about market arrangement"; "uncertainty about hybrid cable system classification"; 
"uncertainty about responsibility and rules to provide access to maritime space for OWFs (location 
selection, site pre-investigation, tender execution)"; "uncertainty about applicable RES subsidy 
scheme";  and  the  "limited  engagement  of  public  stakeholders".  This  can  be  achieved  through 
voluntary cooperation between all stakeholders involved in the individual barrier mitigations. 

▪  Determine  the  initial  allocation  of  costs  and  benefits,  covering  the  cost  and  benefit  categories 
across  all  significant  aspects  of  the  hybrid  project  identified  in  the  first  step.  In  this  process, 
developers  typically  conduct  the  assessment  of  costs  and  benefits,  while  NRAs  oversee  and 
validate  results.  Thus,  this  can  be  achieved  through  voluntary  cooperation  between  OWF 

198 ACER. 2015. Recommendation No 5/2015 on good practices for the treatment of the investment 
requests, including CBCA requests, for electricity and gas PCIs. 
https://acer.europa.eu/Official_documents/Acts_of_the_Agency/Recommendations/ACER%20Reco
mmendation%2005-2015.pdf 

199 ENTSO-E. 2018. 2nd ENTSO-E Guideline: For Cost Benefit Analysis of Grid Development 
Projects. 
https://tyndp.entsoe.eu/Documents/TYNDP%20documents/Cost%20Benefit%20Analysis/2018-10-
11-tyndp-cba-20.pdf 

 
 
                                                      
 
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developer, TenneT TSO B.V. in the Netherlands, TenneT TSO GmbH in Germany and Energinet 
in Denmark, as well as national ministries and NRAs (the MoEA and ACM in the Netherlands; the 
BMWi and BNetzA in Germany; and the MoEUC and DUR in Denmark). 

▪  Align  and  agree  a  suitable  reallocation  of  costs  and  benefits  between  developers,  the 
Netherlands,  Germany  and  Denmark.  This  should  be  based  on  the  identification  of  cost  and 
benefit categories among stakeholders as well as the assessment of the initial allocation of costs 
and benefits across the identified categories. Certainty about the allocation of costs and benefits 
can  be  achieved  by  addressing  this  issue  as  part  of  the  project-specific  HANSA  between  the 
Netherlands, Germany and Denmark. The OWF developer, TenneT TSO B.V. in the Netherlands, 
TenneT TSO GmbH in Germany and Energinet in Denmark, and national ministries and NRAs 
(the MoEA and ACM in the Netherlands; the BMWi and BNetzA in Germany; and the MoEUC 
and DUR in Denmark) assume responsibility for this action, as well as the European Commission. 

▪  Validate  the  availability  of  CEF  funding  to  ensure  adequate  incentivisation  for  all  relevant 
stakeholders if the following applies: the COBRA Cable hybrid project is a PCI and adds socio-
economic  value,  but  the  initial  allocation  of  costs  and  benefits  is  not  sufficiently  balanced  to 
incentivise  all  countries  and  stakeholders  to  implement  the  hybrid  project. While  CEF  funding 
cannot resolve viability issues of projects, it is a last resort for PCIs that have received a CBCA 
decision  but  are  still  not  commercially  viable  for  each  individual  stakeholder.200  This  can  be 
achieved through voluntary cooperation between TSOs (TenneT TSO B.V. in the Netherlands, 
TenneT TSO GmbH in Germany and Energinet in Denmark) and NRAs (ACM in the Netherlands, 
BNetzA in Germany and DUR in Denmark) as well as the European Commission. 

The  barrier,  its  mitigation  and  the  actions  required  to  implement  the  mitigation  are  summarised  in 
Figure  77.  The  actions  required  to  implement  the  mitigation  measure  and  the  stakeholders 
responsible for the individual actions are summarised across barriers in Figure 67. 

Figure 77: COBRA Cable barrier mitigation – Disproportionate allocation of costs and benefit across involved 
stakeholders 

4.9  CGS DE OWF to NL OWF 

The hybrid project idea "CGS DE OWF to NL OWF" is a combined grid solution concept. In the project, 
a  Dutch  OWF  in  the  extreme  eastern  part  of  the  Dutch  EEZ  and  a  German  OWF  in  the  extreme 
western part of the German EEZ are connected,  via the offshore substations of their  export cable 
systems, by an interconnector. Both OWFs have radial connections to their respective home markets. 

200 European Parliament, European Council. 2013. REGULATION (EU) No. 347/2013 on guidelines 
for trans-European energy infrastructure. Article 14. https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:32013R0347&from=en 

Disproportionate allocation of costs and benefits across involved stakeholders>Reallocate costs and benefits among involved stakeholders>Identify cost / benefit categories>Ensure consideration of all costs and benefits deriving from other barrier mitigation measures>Determine initial allocation>Align and agree reallocation>Validate availability of CEF funding to ensure incentivisationBarrierMitigation measureActions 
 
 
 
                                                      
 
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However, the idea shows additional lifetime costs compared to the reference case, in which the OWFs 
are radially connected to their respective national markets only. Thus, the CGS DE OWF to NL OWF 
hybrid project is given no detailed further consideration in the scope of this study. 

4.9.1  Details of the hybrid project and reference case 

The individual assets included in the hybrid project and in the reference case are  modelled on the 
basis  of  real  assets.  But  the  assumed  characteristics  do  not  claim  to  represent  the  actual 
characteristics of the assets included in either ongoing or future developments. 

In  the  reference  case  (Figure  78),  the  interconnector  is  a  stand-alone,  point-to-point  onshore 
interconnector between the Netherlands and Germany. It is constructed based on HVAC technology 
with 700 MW nominal capacity and a length of 10 km. The OWFs included in the project idea are an 
OWF  in  the  eastern  area  of  the  Dutch  EEZ  (e.g.  the  recently  announced  Ten  noorden  van  de 
Waddeneilanden Zoekgebieden development area) and an OWF in the western part of the German 
EEZ. Each has a nominal generation capacity of 700 MW. The Dutch OWF is radially connected to 
the Dutch market with a 70 km HVAC export cable system. The German OWF is radially connected 
to  the  German  market  with  an  80  km  HVDC  system.  No  intermediate  offshore  transformers  are 
required, as the wind turbines can be connected directly to the high-voltage offshore transformers via 
the 66-kV array cable systems. Both export cable systems have a nominal capacity of 700 MW. 

In the hybrid project (Figure 78), the interconnector is a point-to-point offshore interconnector between 
the  offshore  transformer  station  of  the  export  cable  system  of  the  Dutch  OWF  and  the  offshore 
transformer  station of the  export cable system of the  German OWF. It is constructed  to the same 
specifications as in the reference case. However, the length of the interconnector is 40 km. The OWFs 
and their export cable system have the same specifications as in the reference case. 

For  all  cable  systems,  onshore  transformer  stations  are  not  in  the  scope  of  the  assessment. 
Furthermore,  onshore  grid  reinforcement  costs  are  not  in  the  scope  of  this  assessment.  But  it  is 
important that they are considered before project development would be initiated. 

Figure 78: CGS DE OWF to NL OWF – Reference case and hybrid project profile 

Reference caseHybrid caseDifferenceNominal capacity interconnector [MW]0700700Nominal capacity OWF [MW]01,400 (2 x 700)1,400 (2 x 700)Offshore transformer / converter / switching stations02 / 1 / 02 / 1 / 0Length interconnector [km]301040Length export cable [km]0150 (70 + 80)150 (70 + 80)Onshore transformer / converter stations00 / 10 / 1Converter stationTransmission cableTransformerstationReference caseIndicativeIndicativeReference caseGeographical mapping 
 
 
 
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It is generally assumed that the development, construction and commissioning of the individual assets 
(two  OWFs,  two  export  cable  systems  and  interconnector)  can  be  aligned  in  the  hybrid  project  to 
prevent  temporarily  stranded  assets.  It  is  assumed  that  the  OWFs,  export  cable  systems  and 
interconnector will be commissioned in 2028, both in the hybrid project and in the reference case. 

In  general,  this  hybrid  project  idea  and  all  development  areas  and  stakeholders  are  included  as 
examples only, as the assessment was conducted without comprehensive interaction with specific 
project stakeholders. 

4.9.2 

Evaluation of hybrid project vs. reference case 

To evaluate the hybrid project against the reference case, this study calculates the lifetime savings 
of the hybrid project. These include the difference in cost between the hybrid project and the reference 
case. The cost assessment – looking at CAPEX and OPEX – is based on the technical setup of the 
hybrid project and the reference case, as described in the project details. Market modelling was not 
conducted for this project. 

Assuming a typical asset lifetime of 25 years, the hybrid project yields additional lifetime cost of about 
EUR 60 m compared to the reference case (Figure 79). The additional lifetime costs are driven entirely 
by an increase in CAPEX and OPEX. OPEX are calculated and discounted over a 25-year period. 

Figure 79: CGS DE OWF to NL OWF – Assessment results 

The increase in CAPEX and OPEX is driven by the interconnector only. The cost of the interconnector 
is higher in the hybrid project than in the reference case. The interconnector requires more kilometres 
of cable in the hybrid project compared to the reference case, as the onshore interconnector can be 
built with a comparatively short cable. In addition, the hybrid setup requires the use of disconnector 
modules. The cost of the OWFs and its export cable systems are the same in the hybrid project and 
in the reference case. 

-63-59∆CAPEX∆Lifetime savings∆Lifetime OPEX (cable systems)1)∆Lifetime SEW1)N/A-4SEW reference project∆SEWN/A∆Socio-economic welfare (SEW) (hybrid project -reference case) [EUR m p.a.]∆Lifetime savings (hybrid project -reference case) [EUR m]1) 8% discount factorx 25 years 
 
  
 
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4.9.3  Development of an Action Plan to overcome barriers 

As the  hybrid project  presents no  advantage  over the reference case,  no project-specific barriers, 
barrier mitigation measures or Action Plans were assessed or developed. 

4.10  DE OWF to NL 

The hybrid project idea "DE OWF to NL" is a neighbour OWF concept. In the project, a German OWF 
is  radially  connected  to  the  Netherlands  only.  The  idea  shows  lifetime  savings  compared  to  the 
reference case, in which the OWF is connected to Germany. Thus, the DE OWF to NL hybrid project 
is given further consideration in the scope of this study and an Action Plan for the implementation of 
barrier  mitigation  measures  is  developed.  The  Action  Plan  is  intended  to  be  used  as  a  tool  by 
stakeholders once the DE OWF to NL hybrid project has been given the go-ahead. 

4.10.1  Details of the hybrid project and reference case 

The individual assets included in the hybrid project and in the reference case are  modelled on the 
basis  of  real  assets.  But  the  assumed  characteristics  do  not  claim  to  represent  the  actual 
characteristics of the assets included in either ongoing or future developments. 

In the reference case (Figure 80), the OWF included in the project idea is located in a German Cluster 
adjacent to the Dutch EEZ. It has a nominal generation capacity of 1,200 MW. The OWF is radially 
connected  to  Germany  with  a  260  km  HVDC  export  cable  system.  No  intermediate  offshore 
transformers are required, as the wind turbines can be connected directly to the high-voltage offshore 
transformer via the 66-kV array cable system. The export cable system has a nominal capacity of 
1,200 MW. 

In the hybrid project (Figure 80), the OWF has the same location and specifications as in the reference 
case. However, the OWF is radially connected to the Netherlands with a 145 km HVDC export cable 
system, which is otherwise constructed to the same specifications as in the reference case.  

For  all  cable  systems,  onshore  transformer  stations  are  not  in  the  scope  of  the  assessment. 
Furthermore,  onshore  grid  reinforcement  costs  are  not  in  the  scope  of  this  assessment.  But  it  is 
important that they are considered before project development would be initiated. In the DE OWF to 
NL  hybrid  project,  onshore  grid  reinforcements  are  required  in  both  the  hybrid  project  and  the 
reference case. This is because the connection of the OWF translates into the need for an onshore 
grid connection point in either the Netherlands or Germany. 

 
 
 
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Figure 80: DE OWF to NL – Reference case and hybrid project profile 

It is generally assumed that the development, construction and commissioning of the individual assets 
(OWF and export cable system) can be aligned in the hybrid project to prevent temporarily stranded 
assets. It is assumed that the OWF and export cable system will be commissioned before 2030, both 
in the hybrid project and in the reference case. 

4.10.2  Evaluation of hybrid project vs. reference case 

To evaluate the hybrid project against the reference case, this study calculates the lifetime savings 
of the hybrid project. These include the difference in cost and the difference in socio-economic welfare 
(SEW) between the hybrid project and the reference  case. Both the cost assessment  – looking at 
CAPEX and OPEX – and the market modelling-based SEW assessment are based on the technical 
setup  of  the  hybrid  project  and  the  reference  case,  as  described  in  the  project  details.  Additional 
indicators used in the assessment are energy not served, RES curtailment and CO2 emissions. CO2 
emissions are internalised as cost in the SEW. 

Assuming a typical asset lifetime of 25 years, the hybrid project yields lifetime savings of about EUR 
260  m  compared  to  the  reference  case  (Figure  81).  The  lifetime  savings  are  driven  entirely  by  a 
reduction in CAPEX and OPEX of about EUR 300 m. OPEX are calculated and discounted over a 
25-year period. However, a lower hybrid project SEW of EUR 3 m p.a. compared to the reference 
case translates into additional cost from lifetime SEW of about EUR 40 m, discounted over 25 years. 
However,  as  the  above-mentioned  cost  savings  significantly  exceed  these  additional  costs,  the 
lifetime  savings  remain  positive.  The  small  difference  in  SEW  is  spread  over  the  entire  European 
electricity system. It is originally driven by the shift in low-margin cost power generation from Germany 
to the Netherlands in consequence of the connection of the OWF to the Netherlands in the hybrid 
project. 

Reference caseHybrid caseDifferenceNominal capacity OWF [MW]01,2001,200Offshore transformer / converter / switching stations01 / 1 / 01 / 1 / 0Length export cable [km]-115260145Onshore transformer / converter stations00 / 10 / 1Nominal capacity interconnector [MW]000Length interconnector [km]000Converter stationTransmission cableTransformerstationReference caseIndicativeIndicativeReference caseGeographical mapping 
 
 
 
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Figure 81: DE OWF to NL – Assessment results201 

Regarding the cost assessment, the result is driven by the export cable system. The cost of the export 
cable system is lower in the hybrid project than in the reference case. This is because 115 kilometres 
of export cable system are rendered redundant in the hybrid project compared to the reference case, 
lowering CAPEX and OPEX for the export cable system. This difference is slightly reduced by more 
expensive power losses in the hybrid project (OWF connected to the Netherlands) compared to the 
reference  case  (OWF  connected  to  Germany).  These  are  due  to  higher  electricity  prices  in  the 
Netherlands than in Germany.  

In both the hybrid project and the reference case, energy not served is zero due to the comprehensive 
nature of and redundancies in the European electricity system. Therefore, neither setup adversely 
affects the EU's energy policy target of energy security. Compared to the reference case, the effect 
of the hybrid project on curtailment and CO2 emissions is very small.202 This suggests that the hybrid 
project  is  unlikely  to  have  a  significant  impact  on  the  EU's  energy  policy  targets  on  the  further 
establishment of the internal energy market and the decarbonisation of the economy. 

4.10.3  Development of an Action Plan to overcome barriers 

This chapter summarises the findings specific to the development of the DE OWF to NL hybrid project. 
It  builds  on  the  general  explanation  of  the  barriers  in  Chapter  3.2,  the  general  explanation  of  the 
interdependencies between barriers in Chapter 3.3 and the findings of project-specific discussions of 
the barriers and mitigation options in Chapter 5.5.  

201 SEW assessment based on Careri, Francesco. [Forthcoming]. The impact of North Sea 
electricity projects in a 2030 scenario: Preliminary assessment of system benefits for the pan-
European power system through METIS. Petten: European Commission Joint Research Centre. 

202 The hybrid project results in less curtailment of 875 MWh/a and additional CO2 emissions of 192 
kt/a (internalised in socio-economic welfare). For more details, please refer to Careri, Francesco. 
[Forthcoming]. The impact of North Sea electricity projects in a 2030 scenario: Preliminary 
assessment of system benefits for the pan-European power system through METIS. Petten: 
European Commission Joint Research Centre. 

1) 8% discount factor      2) Including variation in CO2emissions (+192 kt/a), internalised in producer surplus-3726316284∆Lifetime OPEX (cable systems)1)∆CAPEX∆Lifetime SEW1)∆Lifetime savingsSEW reference project∆SEW2)-3∆Socio-economic welfare (SEW) (hybrid project -ref. case) [EUR m p.a.]∆Lifetime savings (hybrid project -reference case) [EUR m]x 25 years 
 
 
                                                      
 
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This  study  notes  that  9  of  the  16  identified  barriers  need  to  be  overcome  to  allow  for  the 
commencement  of  the  DE  OWF  to  NL  hybrid  project  development.  Although  the  barriers  are 
addressed  individually,  interdependencies  exist  between  them. When  developing  ways  to  mitigate 
one barrier, it is therefore necessary to also consider the mitigation of other barriers. Table 5 provides 
an  overview  of  the  project-specific  barriers  and  barrier  mitigation  measures,  as  well  as  a  brief 
description  of  the  interdependencies  to  be  considered  in  the  development  of  the  individual  barrier 
mitigation measures. 

Barrier 

Mitigation measure 

Interdependencies 

Uncertainty about 
responsibility for 
project 
development 

Assign responsibility for grid 
connection to either TenneT 
TSO B.V. or TenneT TSO 
GmbH, each in close 
collaboration with the other 
entity 

▪  Failure of developers to align planning 
across assets and countries: clearly 
assigning grid connection responsibility 
facilitates continuous dialogue and early-
stage alignment 

Uncertainty about 
regulation 
deriving from 
jurisdiction over 
cross-border 
cable systems 

Obtain all required permits and 
align regulation deriving from 
concurrent jurisdiction over 
cross-border cable systems 

▪  Failure of developers to align planning 

across assets and countries: obtaining all 
required permits and aligning regulation is 
facilitated by continuous dialogue and early-
stage alignment  

Uncertainty about 
market 
arrangements 

Allow for commercial flows 
from the OWF included in the 
hybrid project to the Dutch 
bidding zone only 

▪  Uncertainty about responsibility and rules to 
provide access to maritime space for OWFs 
(tender design): aligned regulation of 
relevance to the OWF needs to be reflected 
in the tender design 

▪  Uncertainty about applicable RES subsidy 

scheme: commercial flows from the OWF to 
the Dutch bidding zone affect the business 
case of the OWF and thereby possibly the 
level of required subsidies  

Failure of 
developers to 
align planning 
across assets and 
countries 

Facilitate continuous dialogue 
and early-stage alignment 
between the project 
developers 

▪  Uncertainty about responsibility for project 
development: continuous dialogue and 
early-stage alignment facilitates clearly 
assigning grid connection responsibility 

▪  Uncertainty about regulation deriving from 

jurisdiction over cross-border cable systems: 
continuous dialogue and early-stage 
alignment facilitates obtaining all required 
permits and aligning regulation 

▪  Uncertainty about responsibility and rules to 
provide access to maritime space for OWFs 
(location selection, site pre-investigation, 
tender execution and tender design): 

 
 
 
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Barrier 

Mitigation measure 

Interdependencies 

Conduct location selection, 
site pre-investigation and 
tender execution by and in 
accordance with the rules of 
German authorities 

continuous dialogue and early-stage 
alignment are facilitated by an aligned OWF 
location 

▪  Limited engagement of public stakeholders: 

continuous dialogue and early-stage 
alignment are facilitated by formalising 
public commitment and public funding for 
feasibility studies, R&D etc. 

▪  Failure of developers to align planning 

across assets and countries: location 
selection, site pre-investigation and tender 
execution by and in accordance with the 
rules of German authorities provides clarity 
on OWF location 

▪  Uncertainty about the applicable RES 

subsidy scheme: location selection, site pre-
investigation and tender execution by and in 
accordance with the rules of German 
authorities fits provision of a subsidy 
scheme by German authorities 

Implement a tender design 
with strict requirements which 
are aligned between the 
Netherlands and Germany 

▪  Uncertainty about regulation deriving from 

jurisdiction over cross-border cable systems: 
tender design needs to reflect aligned 
regulation relevant for the OWF  

▪  Failure of developers to align planning 

across assets and countries: aligned tender 
design is facilitated by continuous dialogue 
and early-stage alignment 

▪  Uncertainty about applicable RES subsidy 
scheme: a tender with aligned, strict 
requirements includes a German subsidy 
scheme aligned with the Netherlands 

Uncertainty about 
responsibility and 
rules to provide 
access to 
maritime space 
for OWFs 
(location 
selection, site 
pre-investigation, 
tender execution) 

Uncertainty about 
responsibility and 
rules to provide 
access to 
maritime space 
for OWFs (tender 
design) 

Uncertainty about 
applicable RES 
subsidy scheme  

Apply the German RES 
subsidy scheme to the OWF 
included in the hybrid project, 
with statistical transfers 
between countries 

▪  Uncertainty about market arrangement: the 
business case of the OWF and thereby 
possibly the level of required subsidies are 
affected by commercial flows from the OWF 
to the Dutch bidding zone only 

▪  Uncertainty about responsibility and rules to 
provide access to maritime space for OWFs 
(location selection, site pre-investigation, 
tender execution and tender design): 
applying a German subsidy scheme aligned 
with the Netherlands fits location selection, 

 
 
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Barrier 

Mitigation measure 

Interdependencies 

site pre-investigation, tender execution and 
tender design by and in accordance with the 
rules of German authorities  

Limited 
engagement of 
public 
stakeholders 

Formalise public commitment 
in the form of a project-specific 
MoU or HANSA. Also, facilitate 
feasibility studies and scoping 
studies for early-stage 
alignment through public 
funding, for example 

▪  Failure of developers to align planning 

across assets and countries: formalising 
public commitment and public funding for 
feasibility studies, R&D etc. is facilitated by 
continuous dialogue and early-stage 
alignment 

Disproportionate 
allocation of costs 
and benefits 
across involved 
stakeholders 

Reallocate costs and benefits 
deriving from the hybrid project 
where required, based on a 
project-specific process 

▪  Uncertainty about responsibility for project 

development (grid connection 
responsibility): costs and benefits deriving 
from mitigation to be considered, including 
onshore grid reinforcement cost 

▪  Uncertainty about market arrangements: 

costs and benefits deriving from mitigation 
to be considered 

▪  Uncertainty about responsibility and rules to 
provide access to maritime space for OWFs 
(location selection, site pre-investigation, 
tender execution): costs deriving from 
mitigation to be considered 

▪  Uncertainty about applicable RES subsidy 
scheme: costs and benefits deriving from 
mitigation to be considered 

▪  Limited engagement of public stakeholders: 

costs and benefits deriving from mitigation 
to be considered 

Table 5: DE OWF to NL – Barriers, barrier mitigations and interdependencies 

Combining all the measures needed to mitigate the barriers of relevance to the DE OWF to NL hybrid 
project creates an Action Plan that supports the commencement of the development. In addition to 
placing the required actions on a timeline, the Action Plan further details the stakeholders responsible 
for each of the actions (Figure 82). The Action Plan is intended to be used as a tool by stakeholders 
once the DE OWF to NL hybrid project has received the go-ahead. 

 
 
 
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Figure 82: DE OWF to NL – Action Plan 

The barriers and mitigation measures specific to the  DE OWF to NL hybrid project and the actions 
required for the implementation of the identified mitigation measures are explained in more detail in 
the subchapters below. As part of the work on barrier mitigation, a project-specific Memorandum of 
Understanding (MoU) or a project-specific Hybrid Asset Network Support Agreement (HANSA) were 
considered. Both types of formal commitment to address barriers can include all actions for mitigation 
measures of relevance to the DE OWF to NL hybrid project. Thus, it can be sufficient to set up only 
one type. 

Uncertainty about responsibility for project development 

Project-specific barrier evaluation: The definition of responsibility for the grid connection of the OWF 
will determines who is responsible for the development of the DE OWF to NL hybrid project. 

Defining the party responsible for grid connection is complex. This is because the potential OWF site 
is in the German EEZ, where TenneT TSO GmbH is generally responsible for the grid connection 

201920202021Identify relevant cost / benefit categoriesSupport de-risking of hybrid project by providing financial guaranteesNational ministries, ECSupport early-stage alignment among developers through public fundingValidate availability of CEF funding to ensure incentivisationDetermine initial allocation of costs / benefitsAllbenefitsOWF developer, TSOs, national ministries, NRAs, ECOWF developer, TSOs, national ministries, NRAsEnsure consideration of costs and benefits deriving from other barrier mitigationsTSOs, national ministries, NRAsBarrierAlign and agree reallocation between developers and countriescosts andAllocation ofEnsure fair allocation of costs and benefits across stakeholdersNational ministries, NRAsTSOs, national ministries, NRAs, ECEnsure fair allocation of costs and benefits across stakeholdersNational ministries, NRAsEnsure fair allocation of costs and benefits across stakeholdersClarify existing regulation regarding commercial connection of German OWF to Dutch shoreBMWi, BNetzAin DEOtherwise, adjust German regulation (particularly EEG §5.3)Clarify the need for and extent of bidding zone review processTSOs, ECClarify possibility and dates for special tender round ("Sonderausschreibung") in DEengagementIf required, assess implications of onshore grid reinforcementsMarket Agree tender requirements considering interests of the NL and DEBMWi, BNetzA, BSHin DEAlign and implement the type of formalisation of public commitmentPublicRES subsidiesBMWi, BNetzAin DENational ministries, NRAsNational ministries, NRAs, other national authoritiesarrangementsTSOsTSOs, national ministries, NRAsNational ministries, NRAs, other national authoritiesEnsure compatibility of DE subsidy scheme to hybrid project OWF with DE lawAgree tender design with strict requirementsNational ministries, NRAsEnsure fair allocation of costs and benefits across stakeholdersNational ministries, other national authoritiesIf required, adjust national regulationsresponsibilityassets andcountriesAccess toNational ministries, NRAsTSOs, national ministries, BSHin DETSOs, national ministriesTSOs, NRAsDefine applicable first connection charges and G-charges in alignment with the NL and DE TSOsEngage in dialogue to achieve early-stage alignment reg. locations, routing, specifications, timelines of assetsIf required, change national permit proceduresClarify required permits under Dutch and German regulationPlanning acrossOWF developer, national ministries, NRAsIf required, adjust national regulationsmaritime spaceClarify grid connection responsibility for OWF in hybrid context under NL and DE lawAlign mode of collaboration between TenneT TSO B.V. and TenneT TSO GmbHdevelopmentProjectNational ministries, NRAsTSOs, national ministries, NRAsAlign operational rules across bordersAgree that responsibility for location selection, site pre-investigation and tender execution remains with the German authorities TSOs, national ministries, NRAsNational ministriesTSOs, national ministries, NRAsEnsure fair allocation of costs and benefits across stakeholdersAlignmentDefine grid connection responsibility among TenneT TSO B.V. and TenneT TSO GmbH TSOs, ECResponsibility1)TSOs, NRAs, ECAssess need for and extent of onshore grid reinforcementsTSOsJurisdiction1) Responsible stakeholders are OWF developer: tbd; TSOs: TenneT TSO B.V. in the NL and TenneT TSO GmbH in DE; Ministries: MoEAin the NL and BMWi in DE; NRAs: ACM in the NL and BNetzA in DE; Other national authorities: RVOin the NL, BSHin DE 
 
 
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based  on  German  law203  (assuming  an  onshore  connection  point  in  the  area  where  TenneT  TSO 
GmbH  would  be  responsible).  But  the  onshore  grid  connection  point  is  in  the  Netherlands,  where 
TenneT TSO B.V. is generally responsible for the grid connection based on Dutch law.204 Thus, for 
this specific hybrid project setup, no suitable definition of grid connection responsibility exists. 

Barrier mitigation: The mitigation option identified as most feasible is to assign responsibility for grid 
connection to either TenneT TSO B.V. or TenneT TSO GmbH, each in close collaboration with the 
other entity. This is based on consideration of the interdependencies shown in Table 5, interaction 
with project stakeholders (see Chapter 5.5.1) and the ease of implementation in terms of the required 
effort. 

The other mitigation option considered in this study was to make TenneT TSO B.V. and TenneT TSO 
GmbH jointly responsible for the grid connection of the OWF to the Dutch market.  

The mitigation option identified as most feasible was selected for the following reasons: The allocation 
of responsibility for grid connection to either TenneT TSO B.V. or to TenneT TSO GmbH, or jointly to 
TenneT TSO B.V. and TenneT TSO GmbH, still requires clarification regarding legal and regulatory 
coverage.  However,  in  the  case  of  joint  responsibility,  operational  feasibility  depends  heavily  on 
efficient cooperation between TenneT TSO B.V. and TenneT TSO GmbH. In addition, TenneT TSO 
B.V. benefits from general and project-specific knowledge regarding grid connection requirements. 

Irrespective of which mitigation option is selected, this barrier is interdependent with the "failure of 
developers to align planning across assets and countries" barrier. Clearly defining responsibility for 
the  grid  connection  requires  continuous  dialogue  and  early-stage  alignment  on  the  hybrid  project 
setup among the defined project promoters. Clearly defined responsibilities and continuous dialogue 
and alignment, in turn, allow for the commencement of project development. 

Actions and responsibilities for mitigation implementation: To implement this mitigation measure for 
the DE OWF to NL hybrid project, the following actions are required: 

▪  Define  responsibility  for  grid  connection  among  TenneT  TSO  B.V.  and  TenneT  TSO  GmbH. 
Certainty about grid connection responsibility can be achieved by  addressing this issue as part 
of the project-specific HANSA between the Netherlands and Germany. The TSOs (TenneT TSO 
B.V. and TenneT TSO GmbH), as well as national ministries and NRAs (the MoEA and ACM in 
the Netherlands, and the BMWi and BNetzA in Germany) assume responsibility for this action. 

▪  Agree a mode of collaboration between TenneT TSO B.V. and TenneT TSO GmbH. This action 
can be achieved through voluntary cooperation between TenneT TSO GmbH and TenneT TSO 
B.V. 

▪  Define  the  applicable  first  connection  charges  and  G-charges  in  alignment  between  the 
Netherlands  (shallow  first  connection  charges  and  no  G-charges)  and  Germany  (shallow  to 
super-shallow  first  connection  charges  and  no  G-charges).205  This  action  can  be  achieved 

203 If the onshore connection point is located in the area of responsibility of Amprion in the reference 
case, then Amprion would be responsible for the listed actions instead of TenneT TSO GmbH 
(German Erneuerbare-Energien-Gesetz 2017 (EEG 2017). § 8. https://www.gesetze-im-
internet.de/eeg_2014/__8.html). 

204 Dutch Elektriciteitswet 1998. §4 Article 24Aa. https://wetten.overheid.nl/BWBR0009755/2018-07-
28#Hoofdstuk3_Paragraaf4_Artikel24Aa 

205 ENTSO-E. 2018. Overview of transmission tariffs in Europe: Synthesis 2018. 
https://docstore.entsoe.eu/Documents/MC%20documents/TTO_Synthesis_2018.pdf; 
The European Wind Energy Association. 2016. Position paper on network tariffs and grid 

 
 
                                                      
 
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through voluntary cooperation between TenneT TSO B.V. and TenneT TSO GmbH, as well as 
the NRAs (ACM in the Netherlands and BNetzA in Germany). 

▪  Ensure compatibility with existing regulations by clarifying who is responsible for grid connection 
for the OWF between the TSOs under Dutch and German law.206 This can be achieved through 
voluntary cooperation between TenneT TSO B.V., TenneT TSO GmbH and the national ministries 
(the MoEA in the Netherlands, and the BMWi in Germany). 

▪ 

If  required,  adjust  Dutch  and  German  regulations  to  allow  grid  connection  responsibility  to  be 
assigned to either TenneT TSO B.V. or TenneT TSO GmbH. This is despite the fact that the OWF 
site and the onshore connection point are not located in the same country. Guidance from project-
specific  developers  is  required  to  inform  the  adjustment  of  Dutch  and  German  regulation. 
Certainty about Dutch and German regulations can be achieved by addressing this issue as part 
of the project-specific HANSA between the Netherlands and Germany. The national ministries 
and NRAs assume responsibility for this action (the MoEA and ACM in the Netherlands, and the 
BMWi and BNetzA in Germany).  

▪  Assess the need for and extent of onshore grid reinforcements in the Netherlands to allow for the 
operation of the grid connection of the German OWF to the Dutch onshore connection point. This 
action can be achieved through voluntary cooperation between TenneT TSO B.V. and TenneT 
TSO GmbH. 

▪  Ensure  compatibility  with  the  measures  adopted  to  mitigate  the  barrier  "disproportionate 
allocation of costs and benefits across involved stakeholders". Do this through the fair reallocation 
among  the  Netherlands  and  Germany  of  costs  and  benefits  deriving  from  the  grid  connection 
responsibility (including possible onshore grid reinforcement costs). Certainty about the allocation 
of  costs  and  benefits  can  be  achieved  by  addressing  this  issue  as  part  of  the  project-specific 
HANSA  between  the  two  countries.  The  TSOs,  national  ministries  and  NRAs  assume 
responsibility  for  this  action  (TenneT  TSO  B.V.,  the  MoEA  and  ACM  in  the  Netherlands,  and 
TenneT TSO GmbH, the BMWi and BNetzA in Germany). 

The  barrier,  its  mitigation  and  the  actions  required  to  implement  the  mitigation  are  summarised  in 
Figure  83.  The  actions  required  to  implement  the  mitigation  measure  and  the  stakeholders 
responsible for the individual actions are summarised across barriers in Figure 82. 

connection regimes. http://www.ewea.org/fileadmin/files/library/publications/position-papers/EWEA-
position-paper-on-harmonised-transmission-tariffs-and-grid-connection-regimes.pdf 

206 Dutch Elektriciteitswet 1998. §4 Article 24Aa. https://wetten.overheid.nl/BWBR0009755/2018-07-
28#Hoofdstuk3_Paragraaf4_Artikel24Aa 
German Erneuerbare-Energien-Gesetz 2017 (EEG 2017). § 8. https://www.gesetze-im-
internet.de/eeg_2014/__8.html 

 
 
 
                                                      
 
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Figure 83: DE OWF to NL barrier mitigation – Uncertainty about responsibility for project development 

Uncertainty about regulation deriving from jurisdiction over cross-border cable systems 

Project-specific barrier evaluation: The OWF included  in the  DE OWF to NL  hybrid project  idea is 
located in the German EEZ. As the OWF serves to exploit marine resources within the German EEZ, 
Germany has jurisdiction over the OWF installation.  

The situation with the export cable system is more complex. As it is required to exploit the natural 
resources in the German EEZ via the OWF and part of it is located in the German EEZ, Germany can 
claim  jurisdiction  over  the  cable  (the  Netherlands  must  grant  the  freedom  of  the  high  seas  to  lay 
cables as part is also located in the Dutch EEZ). However, the export cable system has its onshore 
connection  point  in  the  Netherlands  and  therefore  crosses  the  Dutch  territorial  sea.  Thus,  the 
Netherlands can also claim jurisdiction over the cable. In consequence, the jurisdiction over the export 
cable system might be concurrent and the regulations applicable to the export cable system derived 
from Dutch and from German jurisdiction might contradict each other. 

Barrier mitigation: The mitigation option identified as most feasible is to obtain all required permits, 
and to align regulation deriving from concurrent jurisdiction over  the  operation  of  the cross-border 
cable  system  between 
the 
interdependencies shown in Table 5, interaction with project stakeholders (see Chapter 5.5.2) and 
the ease of implementation in terms of the required effort. 

is  based  on  consideration  of 

involved.  This 

the  countries 

The  other  mitigation  options  considered  in  this  study  besides  aligning  regulation  deriving  from 
concurrent jurisdiction were to define regulation deriving from (1) Dutch jurisdiction and (2) German 
jurisdiction as applicable to the export cable system linking the German OWF to the Dutch market.  

The mitigation option identified as most feasible was selected for the following reasons:  Additional 
alignment is necessary because the application of operational rules deriving from Dutch or German 
jurisdiction is legally uncertain. The alignment of operational rules deriving from Dutch and German 
jurisdiction can be a lengthy process, but it is in the interests of both the Netherlands and Germany. 

Regarding interdependencies, this barrier is interdependent with the barriers "failure of developers to 
align planning across assets and countries" and "uncertainty about responsibility and rules to provide 
access  to  maritime  space  for  OWFs  (tender  design)".  Obtaining  all  required  permits  and  aligning 
regulation  is  facilitated  by  a  continuous  dialogue  and  early-stage  alignment.  Furthermore,  aligned 
operational regulation needs to be reflected in the requirements of the OWF tender. 

Uncertainty about responsibility for project development>Assign responsibility for grid connection to either TenneT TSO B.V. or TenneT TSO GmbH>Define grid connection responsibility among TenneT TSO B.V. and TenneT TSO GmbH>Align mode of collaboration between stakeholders>Define applicable first connection and G-charges in alignment with the NL and DE >Clarify grid connection responsibility for OWF under Dutch and German law>If required, adjust regulations>Assess need for and extent of onshore grid reinforcements>Ensure fair allocation of costs and benefits across stakeholdersBarrierMitigation measureActions 
 
 
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Actions and responsibilities for mitigation implementation: To implement this mitigation measure for 
the DE OWF to NL hybrid project, the following actions are required: 

▪  For development and construction, clarify the necessary permits of the export cable system under 
Dutch  and  German  regulations.  Compliance  with  the  environmental  and  technical  rules  under 
Dutch and German regulations can be ensured by obtaining the permits. This can be achieved 
through voluntary cooperation between TenneT TSO B.V., TenneT TSO GmbH and the national 
ministries (the MoEA in the Netherlands, and the BMWi and the BSH in Germany, supported by 
the Federal Environment Agency). 

▪ 

If required, change the national permit procedures for the specific hybrid project. Guidance from 
project-specific  developers  in  the  form  of  an  inventory  of  environmental  and  technical  rules  is 
required to inform changes to the permit procedures. Certainty about changes can be achieved 
by  addressing  this  issue  as  part  of  the  project-specific  HANSA  between  the  Netherlands  and 
Germany. The national ministries would assume responsibility for this action (the MoEA in the 
Netherlands, and the BMWi, supported by regional governments, in Germany). 

▪  For  the  operational  phase,  align  the  applicable  national  regulations  arising  from  concurrent 
jurisdiction for the specific hybrid  project. The required alignment may concern  liability issues, 
control  system  operations  (voltage  levels,  grid  synchronisation  etc.)  and  matters  discussed  in 
relation to other barriers. Also consider existing national and EU legal frameworks such as the 
System  Operations  regulation  (Regulation  (EU)  2017/1485)207  and  the  CACM  regulation 
(Regulation (EU) 2015/1222).208 Guidance from project-specific developers is required to inform 
the alignment. Certainty about the alignment of operational rules can be achieved by addressing 
this  issue  as  part  of  the  project-specific  HANSA  between  the  Netherlands  and  Germany.  The 
national ministries  and  NRAs assume responsibility for this  action (the MoEA and ACM  in  the 
Netherlands, and the BMWi and BNetzA in Germany). 

The  barrier,  its  mitigation  and  the  actions  required  to  implement  the  mitigation  are  summarised  in 
Figure  84.  The  actions  required  to  implement  the  mitigation  measure  and  the  stakeholders 
responsible for the individual actions are summarised across barriers in Figure 82. 

Figure 84: DE OWF to NL barrier mitigation – Uncertainty about regulation deriving from jurisdiction over cross-
border cable systems 

207 European Commission. 2017. COMMISSION REGULATION (EU) 2017/1485 establishing a 
guideline on electricity transmission system operation. https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:32017R1485&from=DE 

208 European Commission. 2015. COMMISSION REGULATION (EU) 2015/1222 establishing a 
guideline on capacity allocation and congestion management. https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:32015R1222&from=EN 

Uncertainty about regulation deriving from jurisdiction over cross-border cable systems>Obtain required permits for development and construction of export cable system>Align rules and regulations for operation of interconnector with export cable system>Clarify required permits >If required, change national permit procedures>Align applicable national regulation (operational rules)BarrierMitigation measureActions 
 
 
 
                                                      
 
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Uncertainty about market arrangements 

Project-specific barrier evaluation: Clarification of commercial flows is required as the potential OWF 
site of the DE OWF to NL hybrid project  is located in the German EEZ, whereas the onshore grid 
connection point is in the Netherlands. So, while the OWF physically transmits electricity to the Dutch 
market, commercial flows to the Dutch or (virtually) to the German market are possible. Commercial 
flows for the OWF in the hybrid project must therefore be clarified. 

Barrier mitigation: The mitigation option identified as most feasible is to allow commercial flows from 
the OWF included in the hybrid project to the Dutch bidding zone only. This is based on consideration 
of the interdependencies shown in Table 5, interaction with project stakeholders (see Chapter 5.5.3) 
and the ease of implementation in terms of the required effort, 

The other mitigation options considered in this study were (1) to implement commercial (virtual) flows 
to the German bidding zone and (2) to implement dynamic commercial flows of the OWF to the high-
price market.209  

The mitigation option identified as most feasible was selected for the following reasons: While the 
legal feasibility is not given for any of the mitigation options, Option (2) violates the existing CACM 
regulation (Regulation (EU) 2015/1222)210 regarding the requirement for stable bidding zones across 
market  time  frames.  Options  (1)  and  (2)  do  not  require  additional  compensation  for  price 
discrimination of the OWF included in the hybrid project. But the selected mitigation option does not 
require onshore grid reinforcements regarding interconnector capacity between the Netherlands and 
Germany. 

Regarding  interdependencies,  this  barrier  is  interdependent  with  the  "uncertainty  about  applicable 
RES subsidy scheme" barrier. The implementation of fixed access to the Dutch bidding zone may 
affect the business case of the OWF in the hybrid project and thereby potentially the level of required 
subsidies. 

Actions and responsibilities for mitigation implementation: To implement this mitigation measure for 
the DE OWF to NL hybrid project, the following actions are required: 

▪  Clarify  whether  a  bidding  zone  review  process  in  accordance  with  the  CACM  regulation 
(Regulation  (EU)  2015/1222)  Article  32  (4)211  is  required  for  the  physical  and  commercial 
connection of a German OWF to a Dutch onshore connection point. It is especially important to 
clarify  whether  the  regular  bidding  zone  review  process  should  be  adhered  to,  or  whether  a 
shortened  bidding  zone  review  process  is  possible.  Furthermore,  clarification  is  required  with 
respect to the necessity of assigning the German OWF to the Dutch bidding zone to realise the 
envisaged  market  arrangement.  This  action  can  be  achieved  through  voluntary  cooperation 
between TenneT TSO B.V. and TenneT TSO GmbH, as well as the European Commission. It 
can be initiated by the BMWi in Germany, 

209 Dynamic flows to the low-price market disproportionately disadvantage the OWF (always 
receives the lowest market price) and do not carry a benefit, since no interconnector is involved in 
the setup. Therefore, dynamic flows to the low-price market were not considered. 

210 European Commission. 2015. COMMISSION REGULATION (EU) 2015/1222 establishing a 
guideline on capacity allocation and congestion management. Article 33. https://eur-
lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32015R1222&from=EN 

211 European Commission. 2015. COMMISSION REGULATION (EU) 2015/1222 establishing a 
guideline on capacity allocation and congestion management. Article 32 (4). https://eur-
lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32015R1222&from=EN 

 
 
                                                      
 
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▪  Clarify  whether  existing  Dutch  and  German  regulations  cover  the  commercial  connection  of  a 
German OWF solely to a Dutch onshore connection point. Thus, the existing Dutch and German 
market regulations need to be assessed with respect to inadequate national regulations and any 
amendments  which  may  be  necessary.  This  can  be  achieved  through  voluntary  cooperation 
between the national ministries and NRAs (the MoEA and ACM in the Netherlands, and the BMWi 
and BNetzA in Germany), initiated by the BMWi in Germany. 

▪ 

If required, adjust national regulations to allow the implementation of the hybrid project with the 
given market arrangement. Guidance from project-specific developers is required to inform the 
adjustment  of  Dutch  and  German  regulations.  Certainty  regarding  legislative  changes  can  be 
achieved by addressing this issue as part of the project-specific HANSA between the Netherlands 
and Germany. The national ministries and NRAs assume responsibility for this action (the MoEA 
and ACM in the Netherlands, and the BMWi and BNetzA in Germany). 

▪  Ensure  compatibility  with  the  measures  adopted  to  mitigate  the  barrier  "disproportionate 
allocation of costs and benefits across involved stakeholders". Do this through the fair reallocation 
among  the  Netherlands  and  Germany  of  costs  and  benefits  deriving  from  the  market 
arrangement. Certainty about the allocation of costs and benefits can be achieved by addressing 
this issue as part of the project-specific HANSA between the two countries. TSOs, the national 
ministries and NRAs assume responsibility for this action (TenneT TSO B.V., the MoEA and ACM 
in the Netherlands, and TenneT TSO GmbH, the BMWi and BNetzA in Germany). 

The  barrier,  its  mitigation  and  the  actions  required  to  implement  the  mitigation  are  summarised  in 
Figure  85.  The  actions  required  to  implement  the  mitigation  measure  and  the  stakeholders 
responsible for the individual actions are summarised across barriers in Figure 82. 

Figure 85: DE OWF to NL barrier mitigation – Uncertainty about market arrangements 

Failure of developers to align planning across assets and countries 

Project-specific barrier  evaluation: The  integration  of a German OWF and an  export cable system 
from the German OWF to a Dutch onshore connection point makes the DE OWF to NL hybrid project 
complex.  As  the  two  assets  have  separate  permit,  development  and  construction  timelines, 
geographical  and  timing  alignment  is  crucial.  In  addition,  interoperability  between  the  different 
components of the two assets must be ensured to enable the hybrid project to function. 

Barrier  mitigation:  The  mitigation  option  identified  as  most  feasible  is  to  facilitate  a  continuous 
dialogue and early-stage alignment between the project developers. Given that  the location of the 
German  OWF  is  determined  by  the  German  authorities,  project  developers  need  to  align  on  the 
following: the routing of the export cable system and the location of substations, the specifications of 
the export cable system, substations and the OWF as well as the timelines for the hybrid project's 
individual  assets.  This  is  based  on  consideration  of  the  interdependencies  shown  in  Table  5, 
interaction with project stakeholders (see Chapter 5.5.5) and the ease of implementation in terms of 
the required effort. 

Uncertainty about market arrangements>Establish commercial flows from OWF to Dutch bidding zone only>Clarify need for and extent of bidding zone review process>Clarify existing regulations >If required, adjust regulations>Ensure fair allocation of costs and benefits across stakeholdersBarrierMitigation measureActions 
 
 
 
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Apart from continuous dialogue and early-stage alignment between the project developers, no other 
mitigation options were considered.  

Regarding  interdependencies,  this  barrier  is  interdependent  with  the  following  four  barriers: 
"uncertainty  about  responsibility  for  project  development  (responsibility  for  grid  connection)"; 
"uncertainty about regulation deriving from jurisdiction over cross-border cable systems"; "uncertainty 
about responsibility and rules to provide access to maritime space for OWFs (location selection, site 
pre-investigation,  tender  execution)";  and  the  "limited  engagement  of  public  stakeholders". 
Continuous  dialogue  and  early-stage  alignment  are  complemented  by  clearly  defining  the 
responsibility for the development, construction and operation of the grid connection of the German 
OWF as well as the need to obtain all required permits and align regulation. However, dialogue and 
alignment themselves are supported by the following mitigations to other barriers. An aligned OWF 
location allows for the involvement of and coordination with the developer of the OWF in the hybrid 
project. Formalised public commitment and public financial support decrease the risk to development 
arising from early-stage project-specific decisions and therefore allow for such alignment. 

Action and responsibilities for mitigation implementation: To implement this mitigation measure for 
the DE OWF to NL hybrid project, the following action is required: 

▪  Engage  in  a  continuous  dialogue  to  achieve  early-stage  alignment  regarding  the  locations, 
routing,  technical  specifications  and  timelines  of  the  individual  assets.  This  can  be  achieved 
through voluntary cooperation between TenneT TSO B.V. and TenneT TSO GmbH, as well as 
national ministries and NRAs (the MoEA, supported by RVO and ACM, in the Netherlands, and 
the BMWi, supported by the BSH and BNetzA, in Germany). 

The barrier, its mitigation and the actions required to implement mitigation are summarised in Figure 
86. The actions required to implement the mitigation measure and the stakeholders responsible for 
the individual actions are summarised across barriers in Figure 82. 

Figure 86: DE OWF to NL barrier mitigation – Failure of developers to align planning across assets and 
countries 

Uncertainty about responsibility and rules to provide access to maritime space for OWFs 
(location selection, site pre-investigation, tender execution) 

Project-specific barrier evaluation: The location selection, site pre-investigation and tender execution 
of the DE OWF to NL OWF is conducted by German authorities as it is located in the German EEZ. 
Due to existing  national  and international law, the construction of installations in  a given country's 
EEZ can only be granted by the coastal state. However, in the DE OWF to NL hybrid project, Dutch 
and German stakeholders have an interest because both the interoperability of the components and 
the compliance with all national and European regulations must be ensured. 

Barrier mitigation: The mitigation option identified as most feasible is to conduct location selection, 
site  pre-investigation  and  tender  execution  by  and  in  accordance  with  the  rules  of  the  German 
authorities. This  is based  on consideration of the  interdependencies shown  in  Table 5,  interaction 

Failure of developers to align planning across assets and countries>Facilitate continuous dialogue and early-stage alignment between project developers>Engage in dialogue to achieve early-stage alignment regarding locations, routing, technical specifications and timelines of assetsBarrierMitigation measureActions 
 
 
 
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  North Seas Offshore Energy Clusters study 

with project stakeholders (see Chapter 5.5.6) and the ease of implementation in terms of the required 
effort. 

Regarding  the  responsibility  for  location  selection  and  site  pre-investigation,  the  other  mitigation 
options considered in this study were to assign responsibility (1) to Dutch authorities and (2) to the 
OWF  developer.  The  mitigation  option  identified  as  most  feasible  was  selected  for  the  following 
reasons: Legal and regulatory applicability of any responsibility other than German responsibility is 
not given. Furthermore, additional alignment and coordination would otherwise be necessary, which 
would likely extend the timelines for the procedures. 

Regarding the responsibility for tender execution, the other mitigation option considered in this study 
was to assign Dutch responsibility. The mitigation option identified as most feasible was selected for 
the  following  reasons:  Tender  execution  by  any  party  other  than  German  authorities  entails 
considerable  uncertainties  regarding  legal  and  regulatory  applicability.  It  is  unlikely  to  be  publicly 
supported. In addition, tender execution by German authorities is most closely aligned with ongoing 
procedures and is therefore likely to be more efficient. 

Regarding interdependencies, this barrier is interdependent with the barriers "failure of developers to 
align planning across assets and countries" and "uncertainty about applicable RES subsidy scheme". 
Clarifying  responsibility  for  location  selection,  site  pre-investigation  and  tender  execution  helps  to 
determine the OWF location, which thereby facilitates continuous dialogue and early-stage alignment. 
Furthermore, location selection, site pre-investigation and tender execution by and in accordance with 
the rules of German authorities fits the provision of a subsidy scheme by German authorities. 

Actions and responsibilities for mitigation implementation: To implement this mitigation measure for 
the DE OWF to NL hybrid project, the following actions are required: 

▪  Facilitate the development of the DE OWF to NL hybrid project by agreeing that the responsibility 
for  location  selection,  site  pre-investigation  and  tender  execution  remains  with  the  German 
authorities. Certainty on these three factors can be achieved by addressing this issue as part of 
the project-specific HANSA between the Netherlands and Germany. The national ministries and 
other  national  authorities  assume  responsibility  for  this  action  (the  MoEA  and  RVO  in  the 
Netherlands, and the BMWi and BSH in Germany). 

▪  Ensure  compatibility  with  the  measures  adopted  to  mitigate  the  barrier  "disproportionate 
allocation of costs and benefits across involved stakeholders". Do this through the fair reallocation 
among the Netherlands and Germany  of costs and benefits deriving from the responsibility for 
location selection, site pre-investigation and tender execution. Certainty about the allocation of 
costs and benefits can be achieved by addressing this issue as part of the project-specific HANSA 
between the two countries. The national ministries and NRAs assume responsibility for this action 
(the MoEA and ACM in the Netherlands, supported by the Dutch Ministry of Infrastructure and 
Water Management; and the BMWi and BNetzA, supported by the Federal Environment Agency, 
in Germany). 

The  barrier,  its  mitigation  and  the  actions  required  to  implement  the  mitigation  are  summarised  in 
Figure  87.  The  actions  required  to  implement  the  mitigation  measure  and  the  stakeholders 
responsible for the individual actions are summarised across barriers in Figure 82. 

 
 
 
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Figure 87: DE OWF to NL barrier mitigation – Uncertainty about responsibility and rules to provide access to 
maritime space for OWFs (location selection, site pre-investigation, tender execution) 

Uncertainty about responsibility and rules to provide access to maritime space for OWFs 
(tender design) 

Project-specific barrier evaluation: A suitable tender design needs to be chosen for the DE OWF to 
NL hybrid project. The OWF included in the project setup is located in the German EEZ and is linked 
to an onshore connection point in the Netherlands. Thus, both the Netherlands and Germany have 
an  interest  in  defining  the  requirements  for  the  OWF  development  according  to  their  respective 
standards. These may be contradictory. In addition, the tender design needs to ensure that the tender 
candidates can realistically develop the OWF. In consequence, the tender design must clarify which 
hybrid-specific requirements to include. 

Barrier mitigation: The mitigation option identified as most feasible is to implement a tender design 
with  strict  requirements.  These  should  be  aligned  between  the  Netherlands  and  Germany  and 
eliminate all hybrid-specific uncertainties for the OWF developer. This is based on consideration of 
the  interdependencies shown  in  Table  5,  interaction  with project stakeholders (see Chapter  5.5.7) 
and the ease of implementation in terms of the required effort. 

The  other  mitigation  options  considered  in  this  study  were  (1)  to  have  a  strict  tender  design  with 
requirements  aligned  among  the  stakeholders,  (2)  to  have  a  strict  tender  design  without  hybrid-
specific uncertainties for the OWF developer and (3) to have a lenient tender design with requirements 
aligned among the stakeholders and without hybrid-specific uncertainties for the OWF developer.  

The mitigation option identified as most feasible was selected for the following reasons: While aligned 
requirements  potentially  necessitate  amendments  to  national  legislation  and  regulations,  the 
Netherlands and Germany have valid interests in defining certain requirements for the tender of the 
OWF connected to the Dutch market. Aligned requirements also aid in ensuring the interoperability 
of the OWF with the other assets of the hybrid project. All of these factors increase the probability of 
successful hybrid project implementation. Furthermore, a tender design with strict requirements also 
increases the probability of successful project implementation, allowing for a possible decrease in the 
cost  efficiency  of  the  OWF  development  due  to  more  limited  competition.  Lastly,  certainty  about 
hybrid-specific characteristics of the OWF development increases the probability of successful project 
implementation – and decreases the cost of implementation – by reducing the risk premium otherwise 
demanded by OWF developers in terms of subsidies. 

Regarding  interdependencies,  this  barrier  is  interdependent  with  the  following  three  barriers: 
"uncertainty about regulation deriving from jurisdiction over cross-border cable systems"; the "failure 
of developers to align planning across assets and countries"; and "uncertainty about applicable RES 
subsidy scheme". Aligned regulation deriving from Dutch and Danish jurisdiction needs to be reflected 
in the requirements of the OWF tender. In addition, the OWF tender can include a German subsidy 
scheme  aligned  with  the  Netherlands,  involving  statistical  transfers  between  the  two  countries. 
Continuous dialogue and early-stage alignment facilitate an aligned tender design. 

Uncertainty about responsibility and rules to provide access to maritime space for OWFs (location selection, site pre-investigation, tender execution)>Conduct location selection, site pre-investigation and tender execution by and in accordance with the rules of German authorities>Agree that German responsibility for location selection, site pre-investigation and tender execution remains in place>Ensure fair allocation of costs and benefits across stakeholdersBarrierMitigation measureActions 
 
 
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Actions and responsibilities for mitigation implementation: To implement this mitigation measure for 
the DE OWF to NL hybrid project, the following actions are required: 

▪  Agree a tender design with strict requirements. Certainty about the tender design can be achieved 
by  addressing  this  issue  as  part  of  the  project-specific  HANSA  between  the  Netherlands  and 
Germany. The national ministries, NRAs and other national authorities assume responsibility for 
this action (the MoEA, ACM and RVO in the Netherlands, and the BMWi, BNetzA and BSH in 
Germany). 

▪  Agree tender requirements which take account of the valid interest of the Netherlands in defining 
material requirements such as technical and operational standards, and of Germany in defining 
environmental  standards.  Furthermore,  align  financial  requirements  considering  the  valid 
interests  of  both  the  Netherlands  and  Germany.  Guidance  from  project-specific  developers  is 
required  to  inform  the  development  of  project-specific  tender  requirements.  Certainty  about 
tender  requirements  can  be  achieved  by  addressing  this  issue  as  part  of  the  project-specific 
HANSA between the Netherlands and Germany. The national ministries, NRAs and other national 
authorities assume responsibility for this action (the MoEA, ACM and RVO in the Netherlands, 
and the BMWi, BNetzA and BSH in Germany). 

The  barrier,  its  mitigation  and  the  actions  required  to  implement  the  mitigation  are  summarised  in 
Figure  88.  The  actions  required  to  implement  the  mitigation  measure  and  the  stakeholders 
responsible for the individual actions are summarised across barriers in Figure 82. 

Figure 88: DE OWF to NL barrier mitigation – Uncertainty about responsibility and rules to provide access to 
maritime space for OWFs (tender design) 

Uncertainty about applicable RES subsidy scheme 

Project-specific  barrier  evaluation:  In  the  context  of  the  DE  OWF  to  NL  hybrid  project,  the  OWF 
included in the hybrid project is located in the German EEZ. Thus, a German subsidy scheme could 
apply. A Dutch subsidy scheme is also possible. In addition, a joint project or a joint subsidy scheme 
between the Netherlands and Germany could apply, in line with EU Directive 2009/28/EC212 on the 
promotion of the use of energy from RES. In summary, the applicability of a support scheme from 
one of the countries involved or in some joint form is to be determined. 

Barrier  mitigation:  The  mitigation  option  identified  as  most  feasible  is  to  apply  the  German  RES 
subsidy  scheme  to  the  OWF  included  in  the  hybrid  project,  potentially  with  statistical  transfers 
between countries. Such a move would mean the German government awards the OWF a premium 
tariff  through  the  German  tender  process,  potentially  through  a  special  additional  tender  round 

212 European Parliament, European Council. 2009. DIRECTIVE 2009/28/EC on the promotion of the 
use of energy from renewable sources. https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:32009L0028&from=EN 

Uncertainty about responsibility and rules to provide access to maritime space for OWFs (tender design)>Implement tender design with strict tender requirements which are aligned between the NL and DE  and eliminate all hybrid-specific uncertainties>Agree tender design with strict requirements>Agree tender requirements considering the interests of NL and DEBarrierMitigation measureActions 
 
 
 
                                                      
 
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("Sonderausschreibung")213. This is based on consideration of the interdependencies shown in Table 
5, interaction with project stakeholders (see Chapter 5.5.12) and the ease of implementation in terms 
of the required effort. 

The other mitigation options considered in this study were (1) to apply a Dutch subsidy scheme, (2) 
to apply a joint project between the Netherlands and Germany and (3) to apply no subsidy scheme.  

The mitigation  option  identified as most feasible  was selected for the following reasons:  The legal 
feasibility of applying  a Dutch subsidy scheme to the German OWF is  not given. The feasibility of 
tendering the OWF without a subsidy scheme depends on the ability of the OWF developer to obtain 
offtake securities such as power purchase agreements. Such agreements ensure the bankability of 
the OWF investment. Establishing a joint  project between  the Netherlands and Germany is legally 
covered  and  provides  the  necessary  bankability.  But  it  might  be  problematic  due  to  the  extended 
timeline, which is needed to agree the specifications of the scheme and to formulate the necessary 
legal agreement. Applying the German subsidy scheme to the OWF is potentially viable from a legal 
and regulatory perspective. Nonetheless, the date and duration of a special tender round is unknown 
and could potentially delay project development. 

Regarding  interdependencies,  this  barrier  is  interdependent  with  the  following  two  barriers: 
"uncertainty about market arrangements" and "uncertainty about responsibility and rules to provide 
access to maritime space for OWFs (location selection, site pre-investigation, tender execution and 
tender  design)".  Implementing  commercial  flows  of  the  OWF  to  only  the  Dutch  market  affects  the 
business  case  and  thereby  the  level  of  required  RES  subsidies.  Furthermore,  applying  a  German 
subsidy scheme aligned with the Netherlands to the German OWF fits with location selection, site 
pre-investigation and tender execution by and in accordance with German rules. Such a scheme may 
potentially  involve  statistical  transfers  between  the  two  countries.  It  also  fits  a  tender  design  with 
aligned, strict requirements. 

Actions and responsibilities for mitigation implementation: To implement this mitigation measure for 
the DE OWF to NL hybrid project, the following actions are required: 

▪  Clarify  the  possibility  and  the  dates  for  a  special  tender  round  ("Sonderaussschreibung")  in 
Germany to allow for a timely award of the subsidy scheme to the OWF. This can be achieved 
through voluntary cooperation between the BMWi, the BNetzA and BSH in Germany. 

▪  Ensure that the envisaged mitigation of assigning a German subsidy scheme to the OWF in the 
hybrid project complies with German law. German subsidy schemes have regular characteristics 
in terms of type, level and duration of support as well as technology coverage. Clarify whether 
statistical transfers to the renewable energy target of Germany based on the electricity generated 
by the OWF in the hybrid project – which commercially and physically feeds electricity into the 
Dutch  market  –  are  required  to  access  the  German  subsidy  scheme.  This  assumes  that  the 
electricity physically flowing into the Dutch market has a similar effect on the German market as 
if the electricity would be physically flowing into the German market. Pay particular attention to 
the stipulations laid down in the Renewable Energy Sources Act (EEG) §5 (3)214, i.e. with regard 
to the mutuality of the scheme and the possible coverage of the scheme in an IGA. This action 
can be achieved through voluntary cooperation between the MoEA and ACM in the Netherlands 
as well as the BMWi and BNetzA in Germany. 

213 CDU, CSU, SPD. 2018. Koalitionsvertrag zwischen CDU, CSU und SPD. 
https://www.cdu.de/system/tdf/media/dokumente/koalitionsvertrag_2018.pdf?file=1 

214 German Erneuerbare-Energien-Gesetz 2017 (EEG 2017). § 5 (3). https://www.gesetze-im-
internet.de/eeg_2014/__8.html  

 
 
                                                      
 
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▪ 

It may be that statistical transfers to Germany are required but are not sufficient to allow for the 
applicability of the German RES subsidy scheme to the OWF in the hybrid project. If so, assess 
the implications of the required onshore grid reinforcements to allow for the physical transmission 
of electricity from the Netherlands to Germany. This action could be achieved through voluntary 
cooperation between TenneT TSO B.V. and TenneT TSO GmbH. 

▪  Otherwise, adjust German regulations, particularly the Renewable Energy Sources Act (EEG) §5 
(3), to ensure that statistical transfers to Germany are sufficient to allow for the applicability of the 
German RES subsidy scheme to the OWF in the hybrid project. Guidance from project-specific 
developers is required to inform the adjustment of German regulation. Certainty about German 
regulation  can  be  achieved  by  addressing  this  issue  as  part  of  the  project-specific  HANSA 
between  the  Netherlands  and  Germany.  The  BMWi  and  BNetzA  in  Germany  would  assume 
responsibility for this action. 

▪  Ensure  compatibility  with  the  measures  adopted  to  mitigate  the  barrier  "disproportionate 
allocation of costs and benefits across involved stakeholders". Do this through the fair reallocation 
among  the  Netherlands  and  Germany  of  costs  and  benefits  deriving  from  the  RES  subsidy 
scheme. Certainty about the allocation of costs and benefits can be achieved by addressing this 
issue as part of the project-specific HANSA between the two countries. The OWF developer as 
well as national ministries and NRAs (the MoEA and ACM in the Netherlands, and the BMWi and 
BNetzA in Germany) assume responsibility for this action. 

The  barrier,  its  mitigation  and  the  actions  required  to  implement  the  mitigation  are  summarised  in 
Figure  89.  The  actions  required  to  implement  the  mitigation  measure  and  the  stakeholders 
responsible for the individual actions are summarised across barriers in Figure 82. 

Figure 89: DE OWF to NL barrier mitigation – Uncertainty about applicable RES subsidy scheme 

Limited engagement of public stakeholders 

Project-specific barrier evaluation: The support of public stakeholders is needed for the successful 
implementation  of the  DE  OWF to NL  hybrid project,  as regulatory and technical barriers must be 
overcome,  and  financial  support  provided  across  two  countries,  namely,  the  Netherlands  and 
Germany. 

Barrier mitigation: The mitigation option identified as most feasible is to formalise public commitment 
in  the  form  of  a  project-specific  MoU  or  a  project-specific  HANSA.  Feasibility  studies  and  scoping 
studies  for  early-stage  alignment  through  public  funding,  for  example,  should  also  be  facilitated. 
Furthermore, adequate de-risking of the hybrid project is required. This is based on consideration of 
the interdependencies shown in Table 5, interaction with project stakeholders (see Chapter 5.5.13) 
and the ease of implementation in terms of the required effort.  

Uncertainty about the applicable RES subsidy scheme>Apply German subsidy scheme to OWF included in hybrid project>Clarify possibility and dates for special tender round in DE>Ensure compatibility of envisaged mitigation option with DE law>If required, assess implications of onshore grid reinforcement>Otherwise, adjust DE regulation>Ensure fair allocation of costs and benefits across stakeholdersBarrierMitigation measureActions 
 
 
 
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Besides  formalising  public  commitment  in  the  form  of  a  project-specific  MoU  or  a  project-specific 
HANSA and facilitating feasibility studies and scoping studies or providing financial guarantees, no 
other mitigation option was considered.  

Regarding interdependencies, this barrier is interdependent with the "failure of developers to align 
planning  across  assets  and  countries"  barrier.  Continuous  dialogue  and  early-stage  alignment 
between the project developers is facilitated by formalising the commitment of relevant stakeholders 
of the hybrid project and / or by providing public funding for early-stage activities. These may include 
feasibility studies, scoping studies as well as technical research and development. 

Actions and responsibilities for mitigation implementation: To implement this mitigation measure for 
the DE OWF to NL hybrid project, the following actions are required: 

▪  Align and implement the type of formalisation of public commitment to allow for the development 
of the DE OWF to NL hybrid project. The formalisation of commitment in the form of a project-
specific MoU or a project-specific HANSA is an expression of the goodwill of the stakeholders to 
support hybrid project development. It assures project developers of public support, e.g. in the 
form of dialogue with relevant government bodies. In early project stages, a project-specific MoU 
provides sufficient certainty for project developers. The stakeholders assuming responsibility are 
TenneT TSO B.V., TenneT TSO GmbH and the national ministries and  NRAs (the MoEA and 
ACM  in  the  Netherlands,  and  the  BMWi  and  BNetzA  in  Germany),  as  well  as  the  European 
Commission.  In  later  project  stages,  a  project-specific  HANSA  is  required  to  provide  project 
developers with sufficient legal certainty. The stakeholders assuming responsibility include the 
national  ministries  (the  MoEA  in  the  Netherlands  and  the  BMWi  in  Germany),  as  well  as  the 
European Commission. 

▪  Catalyse  the  development  of  the  DE  OWF  to  NL  hybrid  project  by  supporting  the  early-stage 
alignment among developers. Do this through public funding for feasibility studies, pilot projects 
as  well  as  R&D  for  innovative,  technological  solutions,  in  addition  to  existing  offshore  support 
schemes.  Such  public  support  allows  developers  to  firmly  commit  to  the  development  of  the 
project. This can be achieved through voluntary cooperation between the national ministries (the 
MoEA in the Netherlands and the BMWi in Germany), as well as the European Commission. 

▪  Support the de-risking of the hybrid project by providing financial guarantees. Such guarantees 
can reassure project developers in situations which cannot be foreseen due to the pilot character 
of  the  hybrid  project.  This  can  be  achieved  through  voluntary  cooperation  between  the  TSOs 
(TenneT TSO B.V. and TenneT TSO GmbH) and the European Commission. 

▪  Ensure  compatibility  with  the  measures  adopted  to  mitigate  the  barrier  "disproportionate 
allocation of costs and benefits across involved stakeholders". Do this through the fair reallocation 
among  the  Netherlands  and  Germany  of  costs  and  benefits  deriving  from  the  engagement  of 
public  stakeholders.  Certainty  about  the  allocation  of  costs  and  benefits  can  be  achieved  by 
addressing  this  issue  as  part  of  the  project-specific  HANSA  between  the  two  countries.  The 
national ministries  and  NRAs assume responsibility for this  action (the MoEA and ACM  in  the 
Netherlands, and the BMWi and BNetzA in Germany). 

The  barrier,  its  mitigation  and  the  actions  required  to  implement  the  mitigation  are  summarised  in 
Figure  90.  The  actions  required  to  implement  the  mitigation  measure  and  the  stakeholders 
responsible for the individual actions are summarised across barriers in Figure 82. 

 
 
 
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Figure 90: DE OWF to NL barrier mitigation – Limited engagement of public stakeholders 

Disproportionate allocation of costs and benefits across involved stakeholders 

Project-specific barrier evaluation: Agreeing on the allocation of costs and benefits in the DE OWF to 
NL hybrid project is complex. The potential OWF site is geographically located in the German EEZ, 
whereas the onshore grid connection point is in the Netherlands. Due to the technical setup and the 
details of the hybrid project, certain costs and benefits are initially incurred by Germany and certain 
costs  and  benefits  are  initially  incurred  by  the  Netherlands.  In  addition,  the  measures  adopted  to 
mitigate  other  barriers  assign  costs  or  distribute  benefits  to  the  Netherlands  and  Germany. 
Furthermore, developers may realise additional benefits. Thus, costs and benefits are generally not 
distributed  fairly,  and  no  suitable  approach  exists  to  reallocate  the  costs  and  benefits  across  all 
stakeholders of the hybrid project.  

Barrier mitigation: The mitigation option identified as most feasible is to reallocate costs and benefits 
deriving  from  the  hybrid  project  where  required,  based  on  a  project-specific  process.  In  some 
respects,  the  process  can  be  based  on  the  existing  methodology  given  by  the  Cross-Border  Cost 
Allocations (CBCA) process.215 It builds on the Cost Benefit Analysis (CBA) conducted by ENTSO-
E216 for Projects of Common Interest. In the CBCA process, benefits such as socio-economic welfare 
and CO2 emissions are calculated on a national level to compensate net losers for the implementation 
of  a  project  through  a  CBCA  decision.  The  CBCA  process  provides  a  good  starting  point  for  the 
reallocation  of  costs  and  benefits  across  countries  but  is  best  suited  for  evaluating  cross-border 
electricity interconnectors. This is based on consideration of the interdependencies shown in Table 
5, interaction with project stakeholders (see Chapter 5.5.15) and the ease of implementation in terms 
of the required effort. 

Besides implementing the process resulting in the reallocation of costs and benefits deriving from the 
implementation of the hybrid project, no other mitigation option was considered.  

Regarding  interdependencies,  this  barrier  is  interdependent  with  the  following  five  barriers: 
"uncertainty about responsibility for project development (grid connection responsibility)"; "uncertainty 

215 ACER. 2015. Recommendation No 5/2015 on good practices for the treatment of the investment 
requests, including CBCA requests, for electricity and gas PCIs. 
https://acer.europa.eu/Official_documents/Acts_of_the_Agency/Recommendations/ACER%20Reco
mmendation%2005-2015.pdf 

216 ENTSO-E. 2018. 2nd ENTSO-E Guideline: For Cost Benefit Analysis of Grid Development 
Projects. 
https://tyndp.entsoe.eu/Documents/TYNDP%20documents/Cost%20Benefit%20Analysis/2018-10-
11-tyndp-cba-20.pdf 

Limited engagement of public stakeholders>Formalise public commitment >Facilitate early-stage alignment through public funding and support de-risking of hybrid project>Align and implement formalisation of public commitment (in early project stages in form of MoU, later HANSA)>Support early-stage alignment among developers through public funding>Support de-risking of project by providing financial guarantees>Ensure fair allocation of costs and benefits across stakeholdersBarrierMitigation measureActions 
 
 
                                                      
 
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about market arrangements"; "uncertainty about responsibility and rules to provide access to maritime 
space  for  OWFs  (location  selection,  site  pre-investigation,  tender  execution)";  "uncertainty  about 
applicable RES subsidy scheme"; and the "limited engagement of public stakeholders". Reallocation 
also relates to those barriers. This is because their mitigation translates into costs and benefits for 
specific stakeholders that might have to be reallocated together with all other costs and benefits of 
the hybrid project. Therefore, the costs and benefits deriving from all five interdependent barriers must 
be considered.  

Actions and responsibilities for mitigation implementation: To implement this mitigation measure for 
the DE OWF to NL hybrid project, the following actions are required: 

▪ 

Identify  relevant  cost  and  benefit  categories  between  the  involved  stakeholders,  covering  all 
significant  aspects  of  the  hybrid  project.  This  can  be  achieved  through  voluntary  cooperation 
between TSOs (TenneT TSO B.V. in the Netherlands and TenneT TSO GmbH in Germany) as 
well as national ministries and NRAs (the MoEA and ACM in the Netherlands, and the BMWi and 
BNetzA in Germany). 

▪  Ensure that due consideration is given to all costs and benefits deriving from measures adopted 
to  mitigate  the  following  barriers:  "uncertainty  about  responsibility  for  project  development"; 
"uncertainty about market arrangements"; "uncertainty about responsibility and rules to provide 
access to maritime space for OWFs (location selection, site pre-investigation, tender execution)"; 
"uncertainty  about  applicable  RES  subsidy  scheme";  and  the  "limited  engagement  of  public 
stakeholders".  This  can  be  achieved  through  voluntary  cooperation  between  all  stakeholders 
involved in the individual barrier mitigations. 

▪  Determine  the  initial  allocation  of  costs  and  benefits,  covering  the  cost  and  benefit  categories 
across  all  significant  aspects  of  the  hybrid  project  identified  in  the  first  step.  In  this  process, 
developers  typically  conduct  the  assessment  of  costs  and  benefits,  while  NRAs  oversee  and 
validate  results.  Thus,  this  can  be  achieved  through  voluntary  cooperation  between  OWF 
developers (TenneT TSO B.V. in the Netherlands and TenneT TSO GmbH in Germany) as well 
as  national  ministries  and  NRAs  (the  MoEA  and  ACM  in  the  Netherlands,  and  the  BMWi  and 
BNetzA in Germany). 

▪  Align and agree a suitable reallocation of costs and benefits between developers, the Netherlands 
and Germany. Base this on the identification of cost and benefit categories among stakeholders 
as  well  as  the  assessment  of  the  initial  allocation  of  costs  and  benefits  across  the  identified 
categories. Certainty about the allocation of costs and benefits can be achieved by  addressing 
this issue as part of the project-specific HANSA between the Netherlands and Germany. OWF 
developers (TenneT TSO B.V. in the Netherlands and TenneT TSO GmbH in Germany) as well 
as national ministries and NRAs (the MoEA and ACM in the Netherlands; the BMWi and BNetzA 
in Germany; and the MoEUC and DUR in Denmark) assume responsibility for this action, as well 
as the European Commission. 

▪  Validate  the  availability  of  CEF  funding  to  ensure  adequate  incentivisation  for  all  relevant 
stakeholders if the following applies: the DE OWF to NL hybrid project is a PCI and adds socio-
economic  value,  but  the  initial  allocation  of  costs  and  benefits  is  not  sufficiently  balanced  to 
incentivise  all  countries  and  stakeholders  to  implement  the  hybrid  project.  While  CEF  funding 
cannot resolve viability issues of projects, it is a last resort for PCIs that have received a CBCA 

 
 
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decision  but  are  still  not  commercially  viable  for  each  individual  stakeholder217.  This  can  be 
achieved through voluntary cooperation between TSOs (TenneT TSO B.V.  in the Netherlands 
and TenneT TSO GmbH in Germany) as well as NRAs (ACM in the Netherlands and BNetzA in 
Germany), and the European Commission. 

The  barrier,  its  mitigation  and  the  actions  required  to  implement  the  mitigation  are  summarised  in 
Figure  91.  The  actions  required  to  implement  the  mitigation  measure  and  the  stakeholders 
responsible for the individual actions are summarised across barriers in Figure 82. 

Figure 91: DE OWF to NL barrier mitigation – Disproportionate allocation of costs and benefits across involved 
stakeholders 

217 European Parliament, European Council. 2013. REGULATION (EU) No. 347/2013 on guidelines 
for trans-European energy infrastructure. Article 14. https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:32013R0347&from=en 

Disproportionate allocation of costs and benefits across involved stakeholders>Reallocate costs and benefits among stakeholders>Identify cost / benefit categories>Ensure consideration of all costs and benefits deriving from other barrier mitigation measures>Determine initial allocation>Align and agree reallocation>Validate availability of CEF funding to ensure incentivisationBarrierMitigation measureActions 
 
 
 
 
 
                                                      
 
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5.  Appendix 

Throughout the course of this study, the relevant barriers were identified in interaction with the project-
specific  stakeholders  and  based  on  desk  research.  In  the  same  way,  mitigation  options  were 
developed and assessed for each of the barriers relevant for a specific hybrid project. Generally, the 
project-specific stakeholders include OWF developers, TSOs, national ministries and NRAs.  

The following five Subchapters 5.1 to 5.5 summarise the barriers and barrier mitigations for each of 
the  selected  five  hybrid  project  ideas  IJmuiden  Ver  to  UK,  CGS  IJmuiden  Ver  to  Norfolk,  COBRA 
Cable, North Sea Wind Power Hub (NSWPH) and DE OWF to NL. The dimensions considered in the 
assessment represent a list of important factors, which, however, are not necessarily comprehensive. 
Where necessary, the summary of the interactions includes interpretations of the topics discussed to 
efficiently present a complete picture. 

5.1 

IJmuiden Ver to UK 

Throughout  stakeholder  interaction,  11  out  of  16  barriers  are  identified  as  relevant  for  the 
implementation  of  the  IJmuiden  Ver  to  UK  hybrid  project  idea.  The  results  of  the  interaction  with 
stakeholders with regard to all barriers – relevant and not relevant – are summarised in the ensuing 
subchapters. 

5.1.1  Uncertainty about responsibility for project development 

The barrier "uncertainty about responsibility for project development" is divided into three subtopics, 
grid  connection  responsibility,  responsibility  for  the  development  and  construction  of  the 
interconnector  and  responsibility  for  the  operation  of  the  interconnector.  The  three  subtopics  are 
addressed individually in the following.  

Grid connection responsibility 

This subtopic of the barrier is not relevant for the IJmuiden Ver to UK hybrid project. 

Under Dutch law, the operator of the offshore grid, which is TenneT TSO B.V., has an obligation to 
connect  any  OWF  to  the  onshore  grid,  which  fulfils  the  technical  requirements  set  out  in  the  law. 
Therefore,  responsibility  for  the  development  and  construction  as  well  as  operation  of  the  Dutch 
export cable system is clearly assigned to TenneT TSO B.V. and not further discussed in this study.  

Responsibility for development and construction of interconnector  

This subtopic of the barrier is relevant for the IJmuiden Ver to UK hybrid project. 

To address this barrier, two mitigation options are assessed with regard to their applicability (Table 
6) – excluding the implications of interdependencies with other barriers. 

▪  Option 1 "TenneT TSO B.V. is responsible": The Dutch TSO, TenneT TSO B.V., is responsible 
for  the  development  and  construction  of  the  interconnector  between  the  UK  market  and  the 
offshore substation of the export cable system of the Dutch OWF. 

▪  Option 2 "TenneT TSO B.V. and UK interconnector developer are responsible": The Dutch TSO, 
TenneT TSO B.V., and a UK interconnector developer are responsible for the development and 
construction  of  the  interconnector  between  the  UK  market  and  the  offshore  substation  of  the 
export cable system of the Dutch OWF. 

 
 
 
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Option 1: TenneT TSO B.V. is 
responsible 

Option 2: TenneT TSO B.V. and UK 
interconnector developer are 
responsible 

Legal / 
regulatory 
coverage 

Covered in UK and NL legislation and 
regulation – EU network codes such as 
"HVDC Connections" support technical 
standardisation 

Covered in UK and NL legislation and 
regulation – EU network codes such as 
"HVDC Connections" support technical 
standardisation  

Costs 

Costs are with NL 

Costs are with NL and UK IC developer 

Financial risk 

Financial risk is with TenneT TSO B.V. 
(offshore grid operator), and thus with NL, 
therefore low risk towards project 
realisation 

Financial risk is with TenneT TSO B.V. 
(offshore grid operator) and UK IC 
developer, and thus with NL and UK IC 
developer, therefore uncertain risk 
towards project realisation 

Development 
risk 

Alignment of development not needed for 
a single developer and also not across 
parts of entire cable system due to 
congruent responsibilities, therefore low 
risk towards project realisation 

Alignment of development needed for 
multiple developers and additionally 
across parts of entire cable system due to 
differing responsibilities, therefore 
uncertain risk towards project realisation 

Market-specific 
expertise 

Knowledge on general and project-
specific grid connection requirements 
given for TenneT TSO B.V. in the NL and 
to some extent in the UK (from BritNed) 

Knowledge on general and project-
specific grid connection requirements 
given for UK IC developer in the UK and 
for TenneT TSO B.V. in the NL 

Summary 

Covered under UK and NL legal and 
regulatory regime and with low risk 
towards project realisation but only with 
market-specific expertise in the NL 

Covered under UK and NL legal and 
regulatory regime and market-specific 
expertise in the UK and the NL, but with 
uncertain risk towards project realisation 

Table 6: IJmuiden Ver to UK – Assessment of options for responsibility during IC development and 
construction phase 

In  summary,  the  interaction  with  stakeholders  shows  both  options  –  TenneT  TSO  B.V.  being 
responsible for the development and construction of the interconnector (Option 1) as well as TenneT 
TSO  B.V.  together  with  a  UK  interconnector  developer  being  responsible  (Option  2)  –  have 
advantages and disadvantages. While TenneT TSO B.V. is legally allowed and able to develop and 
construct  the  interconnector  on  its  own  (Option  1),  the  collaboration  with  a  UK  interconnector 
developer is also possible and would make sense as a UK interconnector developer can contribute 
additional market-specific expertise regarding the connection to the UK market (Option 2). On the 
other hand, the risk towards project realisation can be reduced if TenneT TSO B.V. is responsible for 
the development and construction of the entire cable system of the hybrid project (Option 1). 

Considering the results of the interaction with the stakeholders, the selection and / or implementation 
of  the  appropriate  mitigation  option  for  the  IJmuiden  Ver  to  UK  hybrid  project  must  also  take  into 
account the interdependencies between the individual barriers. 

Responsibility for operation of interconnector 

This subtopic of the barrier is relevant for the IJmuiden Ver to UK hybrid project. 

 
 
 
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To  address  this  subtopic  of  the  barrier,  two  mitigation  options  are  assessed  with  regard  to  their 
applicability (Table 7) – excluding the implications of interdependencies with other barriers. 

▪  Option 1 "TenneT TSO B.V. is responsible": The Dutch TSO, TenneT TSO B.V., is responsible 
for the operation of the interconnector (only interconnector cable) between the UK market and 
the offshore substation of the export cable system of the Dutch OWF. 

▪  Option 2 "TenneT TSO B.V. and UK interconnector developer are responsible": The Dutch TSO, 
TenneT TSO B.V., and a UK interconnector developer are responsible for the operation of the 
interconnector (only interconnector cable) between the UK market and the offshore substation of 
the export cable system of the Dutch OWF.  

Option 1: TenneT TSO B.V. is 
responsible 

Option 2: TenneT TSO B.V. and UK 
interconnector developer are 
responsible 

Legal / 
regulatory 
coverage 

Covered in UK and NL legislation and 
regulation – EU network codes, such as 
"System Operations", and EU 
Regulations, such as "Electricity cross-
border exchanges", support technical 
standardisation 

Covered in UK and NL legislation and 
regulation – EU network codes, such as 
"System Operations", and EU 
Regulations, such as "Electricity cross-
border exchanges", support technical 
standardisation 

Costs 

Costs are with NL 

Costs are with NL and UK IC developer 

Operational 
risk 

Alignment of operations not needed for a 
single developer and also not across 
parts of entire cable system due to 
congruent responsibilities, therefore low 
risk towards project realisation  

Alignment of operations needed for 
multiple developers and additionally 
across parts of the entire cable system 
due to differing responsibilities, therefore 
uncertain risk towards project realisation 

Market-
specific 
expertise 

Summary 

Knowledge on general and project-
specific operational requirements given 
for TenneT TSO B.V. in the NL and to 
some extent in the UK (from BritNed) 

Knowledge on general and project-
specific operational requirements given 
for UK IC developer in the UK and for 
TenneT TSO B.V. in the NL 

Covered under UK and NL legal and 
regulatory regime and with low risk 
towards project realisation but only with 
market-specific expertise in the NL 

Covered under UK and NL legal and 
regulatory regime and with market-
specific expertise in the UK and the NL, 
but with uncertain risk towards project 
realisation 

Table 7: IJmuiden Ver to UK – Assessment of options for responsibility during IC operation phase 

In summary, this interaction  with stakeholders shows that  both options  – TenneT TSO B.V. being 
responsible for the operation of the interconnector (Option 1) as well as TenneT TSO B.V. together 
with  a  UK  interconnector  developer  being  responsible  (Option  2)  –  have  advantages  and 
disadvantages. While TenneT TSO B.V. is legally allowed and able to operate the interconnector on 
its own (Option 1), the collaboration with a UK interconnector developer is also possible (Option 2). 
The collaboration with a UK interconnector developer (Option 2) provides additional market-specific 
expertise  on  operational  requirements  in  the  UK.  On  the  other  hand,  the  risk  towards  project 

 
 
 
 
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realisation can be minimised if TenneT TSO B.V. is responsible for the operation of the entire cable 
system of the hybrid project (Option 1). 

Considering the results of the interaction with the stakeholders, the selection and / or implementation 
of  the  appropriate  mitigation  option  for  the  IJmuiden  Ver  to  UK  hybrid  project  must  also  take  into 
account the interdependencies between the individual barriers. 

5.1.2  Uncertainty about regulation deriving from jurisdiction over cross-border 

cable systems 

This barrier is relevant for the IJmuiden Ver to UK hybrid project. 

To address this barrier, three mitigation options are assessed with regard to their applicability (Table 
8)  –  excluding  the  implications  of  interdependencies  with  other  barriers.  The  assessment 
concentrates  on  the  jurisdiction  applicable  to  the  operation  of  the  interconnector  since  the 
development  and  construction  of  the  interconnector  constitute  no  barrier.  Furthermore,  Dutch 
regulation is applicable to the OWF and the export cable system. 

▪  Option 1 "UK jurisdiction's regulations": In addition to European law, UK regulation applies to the 
operation of the interconnector between the UK market and the offshore substation of the export 
cable of the Dutch OWF across the UK territorial sea, the UK EEZ and the Dutch EEZ. 

▪  Option 2 "Dutch jurisdiction's regulations": In addition to European law, Dutch regulation applies 
to the operation of the interconnector between the UK market and the offshore substation of the 
export cable of the Dutch OWF across the UK territorial sea, the UK EEZ and the Dutch EEZ. 

▪  Option 3 "Alignment of jurisdictions' regulations": Based on negotiations between the UK and the 
Netherlands,  a  new  combination  of  regulations  applies  to  the  operation  of  the  interconnector 
between the UK market and the offshore substation of the export cable system of the Dutch OWF 
across the UK territorial sea, the UK EEZ and the Dutch EEZ – in addition to European law. The 
new combination of regulations over the operation of the interconnector can potentially be based 
on existing agreements established for the interconnectors between the UK and the Netherlands, 
such as BritNed. 

Option 1: UK 
jurisdiction's 
regulations 

Option 2: Dutch 
jurisdiction's 
regulations 

Rights and 
duties in UK 
territorial sea 
during 
operation 

No uncertainty since the 
UK has jurisdiction and 
UK operational rules 
apply since cable crosses 
UK territorial sea 

Uncertainty and thus 
alignment required since 
the UK has jurisdiction 
and UK operational rules 
apply since cable crosses 
UK territorial sea 

Option 3: Alignment of 
jurisdictions' 
regulations, e.g. based 
on BritNed 

Alignment required to 
combine operational rules 
deriving from jurisdictions 
of the UK and the NL for 
UK territorial sea through 
involvement of the UK 
and the NL 

 
 
 
 
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Rights and 
duties in UK 
EEZ during 
operation 

Rights and 
duties in NL 
EEZ during 
operation 

Option 1: UK 
jurisdiction's 
regulations 

Option 2: Dutch 
jurisdiction's 
regulations 

No uncertainty since the 
UK has jurisdiction and 
UK operational rules 
apply since cable crosses 
UK territorial sea and not 
the NL territorial sea as 
well as does not serve 
exploitation of the NL EEZ 

No uncertainty since the 
NL has jurisdiction, but NL 
operational rules do not 
apply since the cable 
neither crosses NL 
territorial sea nor serves 
the economic exploitation 
of the NL EEZ  

Uncertainty and thus 
alignment required since 
the UK has jurisdiction 
and UK operational rules 
apply since cable crosses 
UK territorial sea and not 
NL territorial sea as well 
as does not serve 
exploitation of the NL EEZ 

Uncertainty and thus 
alignment required since 
the NL has jurisdiction, 
but NL operational rules 
do not apply since the 
cable neither crosses NL 
territorial sea nor serves 
the economic exploitation 
of the NL EEZ 

Option 3: Alignment of 
jurisdictions' 
regulations, e.g. based 
on BritNed 

Alignment required to 
combine operational rules 
deriving from jurisdictions 
of the UK and the NL for 
UK EEZ through 
involvement of the UK 
and the NL 

Alignment required to 
combine operational rules 
deriving from jurisdictions 
of the UK and the NL for 
NL EEZ through 
involvement of the UK 
and the NL 

No additional alignment of 
operational rules required 

No additional alignment of 
operational rules required  

Hybrid project 
requirements 

Alignment of operational 
rules between the UK and 
the NL required because 
of connection of NL OWF 
to the interconnector via 
offshore substation of 
export cable system  

Timeline 

Others 

Summary 

Alignment may extend 
timeline of project 

Alignment may extend 
timeline of project 

Alignment may extend 
timeline of project 

Alignment of operational 
rules required to allow for 
a combination of assets in 
hybrid project  

Uncertainty and thus 
alignment required to 
ensure applicability of 
Option 2 since UK rules 
apply in all relevant 
maritime zones 

Provisions for assigning 
liability in case of grid 
connection failure need to 
be implemented 

Alignment required to 
ensure applicability of 
Option 3 since UK rules 
apply in all relevant 
maritime zones 

Table 8: IJmuiden Ver to UK – Assessment of options for regulation deriving from jurisdiction deriving from 
cross-border cable systems 

In  summary,  the  interaction  with  stakeholders  shows  that  all  options  –  the  agreement  on  the 
applicability of operational rules to the interconnector based on UK (Option 1) or Dutch jurisdiction 

 
 
 
 
 
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(Option 2) as well as the alignment of rules deriving from the UK and Dutch jurisdiction (Option 3) – 
have  advantages  and  disadvantages.  While  chances  of  an  agreement  among  the  UK  and  the 
Netherlands on a single jurisdiction are limited, the alignment of rules deriving from two jurisdictions 
can be a lengthy process. Yet, Option 3 reflects the interests of both countries in the alignment and 
can potentially build on existing agreements established for the interconnectors between the UK and 
the Netherlands, such as BritNed.  

Considering the results of the interaction with the stakeholders, the selection and / or implementation 
of  the  appropriate  mitigation  option  for  the  IJmuiden  Ver  to  UK  hybrid  project  must  also  take  into 
account the interdependencies between the individual barriers. 

5.1.3  Uncertainty about market arrangements 

This barrier is relevant for the IJmuiden Ver to UK hybrid project. 

In the context of the IJmuiden Ver to UK hybrid project, the market arrangement is foreseen to be 
commercial flows to the home market, this is, of the Dutch OWF only to the Netherlands. Since this 
market arrangement was identified in the interaction with project stakeholders as most feasible from 
the beginning, no other mitigation options were considered in detail. Leftover capacities on its export 
cable system are foreseen to be available for interconnector trade.  

Considering the identification of the market arrangement by the stakeholders, the validation of this 
mitigation option as appropriate for the IJmuiden Ver to UK hybrid project must also take into account 
the interdependencies between the individual barriers. 

5.1.4  Uncertainty about hybrid cable system classification 

This barrier is relevant for the IJmuiden Ver to UK hybrid project. 

To address this barrier, two mitigation options are assessed with regard to their applicability (Table 
9)  –  excluding  the  implications  of  interdependencies  with  other  barriers.  The  assessment 
concentrates  on  the  export  cable  system  between  Dutch  OWF  and  the  Dutch  market.  The 
interconnector  included  in  the  hybrid  project,  meaning  the  cable  connection  from  the  offshore 
substation of the export cable system of the Dutch OWF to the UK market, functions solely as an 
interconnector as the Dutch OWF only transmits electricity to the Dutch market (market arrangement 
as foreseen by the project developers). 

▪  Option  1  "Export  system  with  interconnector  functionality":  The  Dutch  export  cable  is  a  hybrid 
cable system which allows for the transmission of electricity from the Dutch OWF to the Dutch 
market. Hence, the Dutch export cable system (together with the interconnector) only provides 
leftover  capacities  for  the  interconnector  functionality  between  the  UK  and  the  Dutch  bidding 
zone. 

▪  Option  2  "Interconnector  with  export  cable  functionality":  The  Dutch  export  cable  system  is  a 
hybrid cable system which allows for the transmission of electricity from the Dutch OWF to the 
Dutch market only with leftover capacities. Hence, the Dutch export cable system (together with 
the interconnector) primarily provides interconnector functionality between the UK and the Dutch 
bidding zone. 

 
 
 
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NL national 
legal / 
regulatory 
coverage 

EU legal / 
regulatory 
coverage 

Option 1: Export cable with IC 
functionality 

Option 2: IC with export cable 
functionality  

Potentially covered as NL regulation 
does not expressly prohibit dual 
functionality of cables but legal / 
regulatory feasibility to be validated 

Potentially covered as NL regulation 
does not expressly prohibit dual 
functionality of cables but legal / 
regulatory feasibility to be validated 

Not covered under Electricity Directive 
because it does not include an add. 
definition for hybrid cable systems; EU 
Regulation 714/2009 prescribes that 
"maximum capacity of the 
interconnections […] shall be made 
available to market participants" with 
clarity needed whether "maximum" 
refers to nominal or leftover capacities of 
cable systems in hybrid projects 

Not covered under Electricity Directive 
because it does not include an add. 
definition for hybrid cable systems; EU 
Regulation 714/2009 prescribes that 
"maximum capacity of the 
interconnections […] shall be made 
available to market participants" with 
clarity needed whether "maximum" 
refers to nominal or leftover capacities of 
cable systems in hybrid projects 

Potential for 
curtailment of 
OWF 

OWF can transmit electricity to shore at 
full generation capacity, and thus no 
business case implications and 
minimised curtailment 

OWF can transmit electricity to shore 
depending on leftover capacity of cable 
system, and thus negative business 
case implications due to additional 
curtailment 

Potential for 
congestion of 
IC 

Capacity available for trade is 
significantly reduced, and thus negative 
business case implications for IC 
functionality of the entire cable system 

Full capacity is available for trade, and 
thus no business case implications for 
IC functionality of the entire cable 
system 

Compensation  Due to joint development of 

transmission assets in hybrid project, 
optimisation of business case of cable 
system as a whole given; potentially no 
additional compensation necessary  

Due to foregone revenues from 
additional curtailment, additional 
compensation for OWF required 

Third party 
access 

Third party access only given for leftover 
capacities after transmission of 
electricity from OWF to shore 

Third party access given 

Impact on 
EU's energy 
policy targets 

Priority on primary targets of 
diversification and integration of RES as 
well as on GHG emission reductions 
over secondary target of maximised IC 
capacity 

Priority on secondary target of 
maximised IC capacity over primary 
targets of diversification and integration 
of RES as well as on GHG emission 
reductions  

Summary 

Not covered under existing EU 
regulation, but potentially covered under 
NL regulation; potential for negative 
business case implications for IC may 
necessitate additional compensation 

Not covered under existing EU 
regulation, but potentially covered under 
NL regulation; negative business case 
implications for OWF necessitate 
additional compensation 

Table 9: IJmuiden Ver to UK – Assessment of options for hybrid cable system classification 

 
 
 
 
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In  summary,  the  interaction  with  stakeholders  shows  that  both  options  –  an  export  cable  with 
interconnector functionality (Option 1) and an interconnector with export cable functionality (Option 2) 
– have advantages and disadvantages. Both, Option 1 and 2 require changes in the European and 
potentially in the Dutch legal and regulatory frameworks. Option 2 has unfavourable implications for 
the business case of the OWF developer since the developer has no priority access to transmission 
capacity. Contrary, in Option 1, the interconnector developer has no priority access to the capacity of 
the cable system resulting in unfavourable implications for the business case for the interconnector. 
However, in Option 1 the interconnector developer might be able to optimise the entire cable system 
to counterbalance the implications in consequence of the connection of the OWF to it. Furthermore, 
Option 2 prioritises the secondary EU energy policy target  of maximised electricity interconnection 
capacity over the primary targets of diversification and integration of RES as well as greenhouse gas 
emission reduction.  

Considering the results of the interaction with the stakeholders, the selection and / or implementation 
of  the  appropriate  mitigation  option  for  the  IJmuiden  Ver  to  UK  hybrid  project  must  also  take  into 
account the interdependencies between the individual barriers. 

5.1.5 

Failure of developers to align planning across assets and countries 

The barrier "failure of developers to align planning across assets and countries" is divided into three 
subtopics, geographical alignment, technical alignment and timing alignment. The three subtopics are 
addressed individually in the following. 

Geographical alignment 

This subtopic of the barrier is relevant for the IJmuiden Ver to UK hybrid project. 

In  summary,  the  interaction  with  stakeholders  shows  that  there  is  no  specific,  tangible  mitigation 
option to address the barrier of failed geographical alignment across assets and countries, but rather 
that a process towards the mitigation of the barrier must be followed. The process consists of the 
continuous  exchange  between  project  developers  and  other  stakeholders  to  allow  for  the 
achievement of early-stage, geographical alignment. 

Considering the results of the interaction with the stakeholders, the mitigation process to be followed 
for the IJmuiden Ver to UK hybrid project must also take into account the interdependencies between 
the individual barriers. 

Technical alignment 

This subtopic of the barrier is relevant for the IJmuiden Ver to UK hybrid project. 

In  summary,  the  interaction  with  stakeholders  shows  that  there  is  no  specific,  tangible  mitigation 
option to address the barrier of failed technical alignment across assets and countries, but rather that 
a  process  towards  the  mitigation  of  the  barrier  must  be  followed.  The  process  consists  of  the 
continuous  exchange  between  project  developers  and  other  stakeholders  to  allow  for  the 
achievement of early-stage, technical alignment. 

Considering the results of the interaction with the stakeholders, the selection and / or implementation 
of  the  appropriate  mitigation  option  for  the  IJmuiden  Ver  to  UK  hybrid  project  must  also  take  into 
account the interdependencies between the individual barriers. 

Timing alignment 

This subtopic of the barrier is not relevant for the IJmuiden Ver to UK hybrid project. 

 
 
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In the context of the IJmuiden  Ver to UK hybrid project, timing alignment is not relevant since the 
OWF can function as a stand-alone asset with the interconnector between the offshore substation of 
the export cable system of the Dutch OWF and the UK onshore connection point as an additional 
asset that can be added later in time. Thus, the timelines do not need to be aligned provided that 
geographical and technical alignment have taken place. 

5.1.6  Uncertainty about responsibility and rules to provide access to maritime 

space for OWFs (location selection, site pre-investigation and tender 
execution) 

The barrier "uncertainty about responsibility and rules to provide access to maritime space for OWFs 
(location selection, site pre-investigation and tender execution)" is divided into two subtopics, location 
selection and site  pre-investigation as  well as tender  execution. The two subtopics are addressed 
individually in the following. 

Location selection and site pre-investigation 

This subtopic of the barrier is not relevant for the IJmuiden Ver to UK hybrid project. 

In the context of the IJmuiden Ver to UK hybrid project, there is no uncertainty concerning location 
selection  and  site  pre-investigation  responsibility  and  procedures  since  the  Dutch  authorities  are 
responsible and Dutch procedures are applicable to the Dutch OWF included in the hybrid project. 

Tender responsible party 

This subtopic of the barrier is not relevant for the IJmuiden Ver to UK hybrid project. 

In  the  context  of  the  IJmuiden  Ver  to  UK  hybrid  project,  there  is  no  uncertainty  concerning 
determination of the tender responsible party since responsibility lies with Dutch authorities for the 
tender of the Dutch OWF included in the hybrid project. 

5.1.7  Uncertainty about responsibility and rules to provide access to maritime 

space for OWFs (tender design) 

This barrier is relevant for the IJmuiden Ver to UK hybrid project. 

To address this barrier, four mitigation options are assessed with regard to their applicability (Table 
10) – excluding the implications of interdependencies with other barriers. 

▪  Option  1  "Strict  design  with  aligned  requirements  and  without  hybrid-specific  uncertainties":  A 
tender  design  with  strict  pre-qualification  requirements  implies  that  extensive  pre-qualification 
requirements  are  defined  to  ensure  hybrid-specific  and  general  capabilities  to  develop  the 
IJmuiden  Ver  to  UK  hybrid  project.  The  requirements  are  aligned  among  the  UK  and  the 
Netherlands, including a jointly agreed set of financial requirements and a certain set of both UK 
and Dutch rules related to the OWF site (e.g. environmental details) and a certain set of both UK 
and Dutch rules related to the grid connection of the OWF (e.g. technical and operational details 
such as system integration or frequency control). Furthermore, all uncertainties arising from the 
hybrid character of the OWF development are clarified prior to the tender. 

▪  Option 2  "Strict design  with aligned requirements": A tender design  with strict  pre-qualification 
requirements implies that extensive pre-qualification requirements are defined to ensure hybrid-
specific  and  general  capabilities  to  develop  the  IJmuiden  Ver  to  UK  hybrid  project.  The 
requirements are aligned among the UK and the Netherlands, including a jointly agreed set of 
financial requirements and a certain set of both UK and Dutch rules related to the OWF site (e.g. 
environmental details) and a certain set of both UK and Dutch rules related to the grid connection 

 
 
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of  the  OWF  (e.g.  technical  and  operational  details  such  as  system  integration  or  frequency 
control).  Furthermore,  the  uncertainties  arising  from  the  hybrid  character  of  the  OWF 
development are not clarified prior to the tender.  

▪  Option  3:  "Strict  design  without  hybrid-specific  uncertainties":  A  tender  design  with  strict  pre-
qualification  requirements  implies  that  extensive  pre-qualification  requirements  are  defined  to 
ensure hybrid-specific and general capabilities to develop the IJmuiden Ver to UK hybrid project. 
The  requirements  are  either  defined  by  the  UK  or  by  the  Netherlands  and  not  aligned. 
Furthermore,  all  uncertainties  arising  from  the  hybrid  character  of  the  OWF  development  are 
clarified prior to the tender. 

▪  Option 4 "Lenient design with aligned requirements and without hybrid-specific uncertainties": A 
tender design with lenient pre-qualification requirements is chosen, implying that only limited pre-
qualification requirements are defined to ensure competition and low prices. The requirements 
are  aligned  among  the  UK  and  the  Netherlands,  including  a  jointly  agreed  set  of  financial 
requirements  and  a  certain  set  of  both  UK  and  Dutch  rules  related  to  the  OWF  site  (e.g. 
environmental details) and a certain set of both UK and Dutch rules related to the grid connection 
of  the  OWF  (e.g.  technical  and  operational  details  such  as  system  integration  or  frequency 
control). Furthermore, all uncertainties arising from the hybrid character of the OWF development 
are clarified prior to the tender. 

Legal / 
regulatory 
coverage 

Alignment of 
requirements 

Option 1: Strict 
design, aligned 
requirements and 
no uncertainties 

Option 2: Strict 
design and 
aligned 
requirements  

Not covered and 
potential 
amendments to 
national legislation 
and regulation 
necessary since 
multiple countries 
are involved in 
defining tender 
design 

Not covered and 
potential 
amendments to 
national legislation 
and regulation 
necessary since 
multiple countries 
are involved in 
defining tender 
design 

Financial, technical 
and operational 
requirements 
aligned; 
environmental 
requirements 
defined by the NL 

Financial, technical 
and operational 
requirements 
aligned; 
environmental 
requirements 
defined by the NL 

Option 3: Strict 
design and no 
uncertainties 

Covered and no 
amendments to 
national legislation 
and regulation 
necessary since 
only one country is 
involved in defining 
tender design 

No alignment of 
requirements 

Option 4: Lenient 
design, aligned 
requirements and 
no uncertainties 

Not covered and 
potential 
amendments to 
national legislation 
and regulation 
necessary since 
multiple countries 
are involved in 
defining tender 
design 

Financial, technical 
and operational 
requirements 
aligned; 
environmental 
requirements 
defined by the NL 

 
 
 
 
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Hybrid-
specific un-
certainties 

Realisation 
probability 

Option 1: Strict 
design, aligned 
requirements and 
no uncertainties 

Option 2: Strict 
design and 
aligned 
requirements  

Uncertainties 
arising from hybrid 
character of 
development not 
entirely clarified 
such that 
uncertainty remains 
for OWF developer 

All uncertainties 
arising from hybrid-
specific setup are 
clarified, e.g. 
liability, applicable 
jurisdiction, grid 
connection 
responsibility, 
hybrid cable 
system 
classification 

Applying OWF 
developers are 
aware of all 
specifications and 
requirements and 
can align planning 
and financing right 
from the beginning 

Applying OWF 
developers are 
aware of all 
specifications and 
requirements and 
can align planning 
and financing right 
from the beginning  

Option 4: Lenient 
design, aligned 
requirements and 
no uncertainties 

All uncertainties 
arising from hybrid-
specific setup are 
clarified, e.g. 
liability, applicable 
jurisdiction, grid 
connection 
responsibility, 
hybrid cable 
system 
classification 

Applying OWF 
developers are not 
aware of most 
specifications and 
requirements, 
which might result 
in significant cost 
overruns / delays 
after the tender 
process 

Option 3: Strict 
design and no 
uncertainties 

All uncertainties 
arising from hybrid-
specific setup are 
clarified, e.g. 
liability, applicable 
jurisdiction, grid 
connection 
responsibility, 
hybrid cable 
system 
classification 

Applying OWF 
developers are 
aware of all 
specifications and 
requirements and 
can align planning 
and financing right 
from the beginning; 
however, it is 
questionable 
whether an OWF 
connected to two 
countries can be 
tendered without 
alignment of tender 
requirements 

Cost efficiency  Due to strict 

requirements and 
specifications, less 
developers 
expected to apply – 
cost efficiency of 
offers expected to 
decrease with 
fewer applicants 

Due to strict 
requirements and 
specifications, less 
developers 
expected to apply – 
cost efficiency of 
offers expected to 
decrease with 
fewer applicants 

Due to strict 
requirements and 
specifications, less 
developers 
expected to apply – 
cost efficiency of 
offers expected to 
decrease with 
fewer applicants 

Due to lenient 
requirements and 
specifications, 
many developers 
expected to apply – 
cost efficiency of 
offers expected to 
increase with more 
applicants 

 
 
 
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Summary 

Option 1: Strict 
design, aligned 
requirements and 
no uncertainties 

Option 2: Strict 
design and 
aligned 
requirements  

Legal and 
regulatory 
coverage to be 
assessed and 
potentially 
decreases cost 
efficiency 

Legal and 
regulatory 
coverage to be 
assessed and 
decreases cost 
efficiency, 
particularly due to 
remaining hybrid 
uncertainties 

Option 4: Lenient 
design, aligned 
requirements and 
no uncertainties 

Legal and 
regulatory 
coverage to be 
assessed and 
strongly decreases 
probability of 
project realisation  

Option 3: Strict 
design and no 
uncertainties 

Legal and 
regulatory 
coverage given, but 
with limited chance 
of realisation due to 
non-consideration 
of one country's 
interest in defining 
tender 
requirements 

Table 10: IJmuiden Ver to UK – Assessment of options for tender design 

In summary, the interaction with stakeholders shows that all four options – a strict or lenient tender 
design  with  aligned  requirements  and  certainty  about  hybrid-specific  characteristics  of  the  OWF 
development (Option 1 and 4), a strict tender design with aligned requirements (Option 3) as well as 
a  strict  tender  design  with  certainty  about  hybrid-specific  characteristics  of  the  OWF  development 
(Option  2)  –  have  advantages  and  disadvantages.  While  a  tender  design  with  strict  requirements 
(Options 1, 2 and 3) increases the probability of successful project implementation, a tender design 
with  lenient  requirements  (Option  4)  decreases  the  cost  of  implementation  through  competition. 
Furthermore, certainty about hybrid-specific characteristics of the OWF development (Options 1, 3 
and  4)  increases  the  probability  of  successful  project  implementation  and  decreases  the  cost  of 
implementation by reducing the risk premium otherwise demanded by OWF developers in terms of 
subsidies. Lastly, aligned requirements (Options 1, 2 and 4) aid in ensuring the interoperability of the 
OWF with the other assets of the hybrid project and thereby increase the probability of successful 
hybrid project implementation. 

Considering the results of the interaction with the stakeholders, the selection and / or implementation 
of  the  appropriate  mitigation  option  for  the  IJmuiden  Ver  to  UK  hybrid  project  must  also  take  into 
account the interdependencies between the individual barriers. 

5.1.8  Discrepancies in responsibilities and requirements for balancing 

In  the  context  of  the  IJmuiden  Ver  to  UK  hybrid  project,  there  is  no  discrepancy  concerning  the 
balancing responsibility and requirements in the shorter term since the balancing regulation of the 
Netherlands  applies  to  the  Dutch  OWF  included  in  the  hybrid  project.  Furthermore,  the  topic  is 
addressed in the Clean Energy Package such that in the longer term the translation into Dutch law 
needs to be assessed in detail by the project-specific stakeholders. 

5.1.9  Discrepancies in priority dispatch regulation 

In the context of the IJmuiden Ver to UK hybrid project, there is no discrepancy concerning the priority 
dispatch regulation in the shorter term since the Dutch priority dispatch regulation applies to the Dutch 
OWF included in the hybrid project. Furthermore, the topic is addressed in the Clean Energy Package 
such  that  in  the  longer  term  the  translation  into  Dutch  law  needs  to  be  assessed  in  detail  by  the 
project-specific stakeholders. 

 
 
 
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5.1.10  Discrepancies in curtailment regulation and compensation 

In the context of IJmuiden Ver to UK hybrid project, there is no discrepancy concerning the curtailment 
and curtailment compensation regulation in the shorter term since the Dutch curtailment regulation 
applies to the Dutch OWF included in the hybrid project. Furthermore, the topic is addressed in the 
Clean  Energy  Package,  such  that  in  the  longer  term  the  translation  into  Dutch  law  needs  to  be 
assessed in detail by the project-specific stakeholders. 

5.1.11  Lack of regulated revenues for anticipatory investments 

This barrier is relevant for the IJmuiden Ver to UK hybrid project. 

To address this barrier, only the Dutch regulatory regime is assessed with regard to its applicability 
to cover anticipatory investments (Table 11) – excluding the implications of interdependencies with 
other barriers. The assessment concentrates on the Dutch regime since the anticipatory investments 
have to be undertaken during the development of the export cable system, for which TenneT TSO 
B.V. is responsible. 

Dutch regulation 

Legal / 
regulatory 
coverage 

Anticipatory investments for export cable systems and interconnectors are 
considered under Dutch regulation 

Treatment of 
anticipatory 
investments 

Anticipatory investments are treated exactly the same as non-anticipatory 
investments, but must be included in Offshore Grid Development Framework by 
the Dutch government 

Efficiency 
benchmark 

Efficiency benchmark exists and regulatory regime provides for standard 
procedures to assess appropriate investments 

Public opinion  Public support required for inclusion of investment in Offshore Grid Development 

Framework 

Risk to project 
realisation 

Risk of 
stranded 
asset 

Summary 

No risk since TSO can cover investments through their inclusion in the RAB 

Risk of stranded transmission investment exists with coverage under Dutch 
regulation uncertain 

Anticipatory investments are treated as regular investments but are taken at 
discretion of government through inclusion in Offshore Grid Development 
Framework 

Table 11: IJmuiden Ver to UK – Assessment of regulatory regimes for anticipatory investments 

In summary, the  interaction  with stakeholders shows that the  inclusion of the hybrid project in the 
Offshore Grid Development Framework in the Netherlands needs to be agreed, since the risk of non-
recovery  of  anticipatory  investments  is  likely  to  be  prohibitive  otherwise.  Still,  the  efficiency  of 
anticipatory investments must be assessed to ensure the sensible expansion of infrastructure. 

 
 
 
 
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Considering the results of the interaction with the stakeholders, the selection and / or implementation 
of  the  appropriate  mitigation  option  for  the  IJmuiden  Ver  to  UK  hybrid  project  must  also  take  into 
account the interdependencies between the individual barriers. 

5.1.12  Uncertainty about applicable RES subsidy scheme 

This barrier is not relevant for the IJmuiden Ver to UK hybrid project. 

In  the  context  of  the  IJmuiden  Ver  to  UK  hybrid  project,  there  is  no  uncertainty  concerning  the 
applicability  of  national  subsidy  schemes  since  the  national  subsidy  scheme  of  the  Netherlands 
applies to the OWF included in the hybrid project. 

5.1.13  Limited engagement of public stakeholders 

The  barrier  "limited  engagement  of  public  stakeholders"  is  divided  into  two  subtopics,  formalised 
public support and financial support. The two subtopics are addressed individually in the following. 

Formalisation of commitment from public stakeholders  

This subtopic of the barrier is relevant for the IJmuiden Ver to UK hybrid project. 

To address this barrier, two mitigation options are assessed with regard to their applicability (Table 
12) – excluding the implications of interdependencies with other barriers. 

▪  Option  1  "Memorandum  of  Understanding  (MoU)":  A  Memorandum  of  Understanding  is  a 
formalisation of the goodwill of the involved parties in form of a non-binding agreement. An MoU 
addresses  barriers  by  formalising  the  agreements  of  the  involved  parties  with  regard  to  the 
implementation  of  required  actions  to  overcome  the  barriers.  It  can  involve  all  project 
stakeholders,  such  as  OWF  developers,  TSOs,  national  ministries  and  NRAs  as  well  as  the 
European Commission. 

▪  Option 2 "Hybrid Asset Network Support Agreement (HANSA)": A project-specific Hybrid Asset 
Network  Support  Agreement  is  a  legally-binding  commitment  to  adapt  national  legislation  and 
regulation in the future, and thus provides legal certainty to developers. European legislation and 
regulation can only be adapted via a project-specific HANSA if all Member States of the European 
Union  sign  the  agreement.  It  only  directly  involves  public  stakeholders,  such  as  national 
ministries. 

Option 1: Memorandum of 
Understanding (MoU) 

Option 2: Hybrid Asset Network 
Support Agreement (HANSA) 

Required effort  Some interaction and alignment 

required among project developers and 
stakeholders to facilitate signing of 
agreement 

Provided 
certainty 

Intentional character of signed 
agreement sufficient for hybrid projects 
in early development stage  

Significant interaction and alignment 
among political project stakeholders 
required to facilitate signing of 
agreement 

Legally binding commitment to topics 
covered by signed agreement directly 
facilitates project development, but is 
only required at a later development 
stage of hybrid projects 

 
 
 
 
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Option 1: Memorandum of 
Understanding (MoU) 

Option 2: Hybrid Asset Network 
Support Agreement (HANSA) 

Summary 

Reasonable effort to align agreement 
required prior to signing and non-legally 
binding commitment sufficient in early 
project development stages 

Significant effort for alignment of 
agreement required prior to signing but 
provides legal certainty and therefore 
suitable in later development stages 

Table 12: IJmuiden Ver to UK – Assessment of options for formalisation of commitment from public 
stakeholders 

In  summary,  the  interaction  with  stakeholders  shows  that  both  options  –  a  project-specific 
Memorandum  of  Understanding  (Option  1)  and  a  project-specific  Hybrid  Asset  Network  Support 
Agreement (Option 2) – have advantages and disadvantages. While less effort is usually required to 
align  and  sign  a  project-specific  MoU,  an  MoU  is  not  legally  binding,  and  thus  the  commitment  of 
public stakeholders provides limited certainty, for example, about legal and regulatory changes for 
project developers (Option 1). However, while a project-specific HANSA provides legal certainty about 
the commitment of stakeholders to implement legal and regulatory changes, the alignment process 
requires more effort (Option 2).  

Considering the results of the interaction with the stakeholders, the selection and / or implementation 
of  the  appropriate  mitigation  option  for  the  IJmuiden  Ver  to  UK  hybrid  project  must  also  take  into 
account the interdependencies between the individual barriers as well as the development stage of 
the hybrid project. 

Financial support 

This subtopic of the barrier is relevant for the IJmuiden Ver to UK hybrid project. 

In  summary,  the  interaction  with  stakeholders  shows  that  there  is  no  specific,  tangible  mitigation 
option  to  address  the  barrier  of  limited  financial  support,  but  rather  that  a  portfolio  of  support 
programmes is available, and their usage needs to be increased to facilitate the implementation of 
hybrid projects. In the past, hybrid project development and / or considerations, such as the Combined 
Grid Solution Kriegers Flak in the Baltic Sea and the Interconnector tie-in COBRA Cable in the North 
Sea,  indicate  that  such  support  is  required  to  de-risk  and  thereby  allow  for  the  realisation  of  pilot 
projects. In this context, financial support can come in various forms, such as co-financing for early-
stage feasibility studies, scoping studies or R&D, co-financing of development and construction or 
guarantees  for  the  operational  phase.  Generally,  financial  support  programmes  are  available  on 
national and European level and should be as specifically targeted at hybrid projects as possible. The 
target is to increase the awareness for and the usage of existing financial support programmes and 
thereby foster the development of hybrid projects. 

Considering the results of the interaction with the stakeholders, the mitigation of this barrier for the 
IJmuiden Ver to UK hybrid project must also take into account the interdependencies between the 
individual barriers. 

5.1.14  Uncertainty regarding the UK market 

The barrier "uncertainty regarding the UK market" is divided into two subtopics, UK Capacity Market 
and UK Cap and Floor regime as well as EU internal energy market. The two subtopics are addressed 
individually in the following. 

 
 
 
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UK Capacity Market and Cap and Floor regime 

This subtopic of the barrier is relevant for the IJmuiden Ver to UK hybrid project. 

In  summary,  the  interaction  with  stakeholders  shows  that  there  is  no  specific,  tangible  mitigation 
option to address the barrier of uncertainty about the continuance of the UK Capacity Market – which 
has been declared illegal by the General Court of the EU on November 15, 2018 and it is presently 
put  on  hold,  with  next  the  capacity  auction  indefinitely  postponed  –  as  well  as  the  Cap  and  Floor 
regime, particularly in the context of the negotiations regarding the withdrawal of the UK from the EU, 
but rather that a process towards the mitigation of the barrier must be followed. The process consists 
of awaiting the finalisation of the negotiations between the UK and the European Union to allow for 
the clarification of the future of the UK Capacity Market and Cap and Floor regime. 

Considering the results of the interaction with the stakeholders, the mitigation process to be followed 
for the IJmuiden Ver to UK hybrid project must also take into account the interdependencies between 
the individual barriers. 

EU internal energy market 

This subtopic of the barrier is relevant for the IJmuiden Ver to UK hybrid project. 

In  summary,  the  interaction  with  stakeholders  shows  that  there  is  no  specific,  tangible  mitigation 
option to address the barrier of uncertainty about the continuance of the participation of the UK in the 
EU internal energy market, particularly in the context of the negotiations regarding the withdrawal of 
the UK from the EU, but rather that a process towards the mitigation of the barrier must be followed. 
The process consists of awaiting the finalisation of the negotiations between the UK and the European 
Union  to  allow  for  the  clarification  of  the  future  of  the  UK's  participation  in  the  EU  internal  energy 
market. 

Considering the results of the interaction with the stakeholders, the mitigation process to be followed 
for the IJmuiden Ver to UK hybrid project must also take into account the interdependencies between 
the individual barriers. 

5.1.15  Disproportionate allocation of costs and benefits across involved 

stakeholders 

This barrier is relevant for the IJmuiden Ver to UK hybrid project. 

In  summary,  the  interaction  with  stakeholders  shows  that  there  is  no  specific,  tangible  mitigation 
option  to  address  the  barrier  of  disproportionate  allocation  of  costs  and  benefits  across  involved 
stakeholders,  but  rather  that  a  process  towards  the  mitigation  of  the  barrier  must  be  followed. 
Generally, the process consists of the identification and alignment of cost and benefit categories, the 
determination of the initial allocation of costs and benefits, the agreement on a re-allocation of costs 
and benefits as well as – if required and available – the usage of CEF funding to ensure the individual 
incentivisation of all stakeholders. This can build on the existing process for Cost Benefit Analyses 
(CBA) and Cross-Border Cost Allocations (CBCA) as defined by ENTSO-E for cross-border electricity 
interconnectors, which needs to be adjusted according to the specifications of each individual hybrid 
project. The process should allow for the incentivisation of all relevant stakeholders to implement the 
hybrid project. 

Considering the results of the interaction with the stakeholders, the mitigation process to be followed 
for the IJmuiden Ver to UK hybrid project must also take into account the interdependencies between 
the individual barriers. 

 
 
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5.1.16  Uncertainty about legislative regime for power-to-gas and related 

infrastructure  

This barrier is not relevant for the IJmuiden Ver to UK hybrid project. 

In the context of the IJmuiden Ver to UK hybrid project, it is currently not planned to include power 
conversion to gas and / or gas transmission solutions. Thus, there is no need for and consequently 
no uncertainty regarding the legislative regime for power conversion to gas and gas transmission for 
the specific hybrid project idea. 

5.2  CGS IJmuiden Ver to Norfolk  

Throughout  stakeholder  interaction,  9  out  of  16  barriers  are  identified  to  be  relevant  for  the 
implementation of the CGS IJmuiden Ver to Norfolk hybrid project idea. The results of the interaction 
with  stakeholders  with  regard  to  all  barriers  –  relevant  and  not  relevant  –  are  summarised  in  the 
ensuing subchapters.  

5.2.1  Uncertainty about responsibility for project development 

The barrier "uncertainty about responsibility for project development" is divided into three subtopics, 
grid  connection  responsibility,  responsibility  for  the  development  and  construction  of  the 
interconnector  and  responsibility  for  the  operation  of  the  interconnector.  The  three  subtopics  are 
addressed individually in the following. 

Grid connection responsibility 

This subtopic of the barrier is not relevant for the CGS IJmuiden Ver to Norfolk hybrid project. 

The OWF sites are in the UK EEZ, where the OFTO regime applies for the grid connection, and in 
the  Dutch EEZ,  where the  responsibility for  development, construction as  well  as operation  of the 
Dutch  export cable system is  assigned to the  offshore grid operator TenneT TSO B.V. Therefore, 
responsibility for the development and construction as well as operation of the UK and Dutch export 
cable system lies with Vattenfall and an OFTO under the developer build option in the UK and TenneT 
TSO B.V. in the Netherlands. The responsibility is not further discussed in this study. 

Responsibility for development and construction of interconnector  

This subtopic of the barrier is relevant for the CGS IJmuiden Ver to Norfolk hybrid project. 

To address this barrier, four mitigation options are assessed with regard to their applicability (Table 
13) – excluding the implications of interdependencies with other barriers. 

▪  Option 1 "TenneT TSO B.V. is responsible": The Dutch TSO, TenneT TSO B.V., is responsible 
for the development and construction of the interconnector (only interconnector cable) between 
the offshore substations of the export cable systems of the UK OWF and the Dutch OWF. 

▪  Option 2 "TenneT TSO B.V. and Vattenfall are responsible": The Dutch TSO, TenneT TSO B.V., 
and the OWF developer, Vattenfall, are responsible for the development and construction of the 
interconnector (only interconnector cable) between the offshore substations of the export cable 
systems of the UK OWF and the Dutch OWF.  

▪  Option 3 "TenneT TSO B.V. and OFTO are responsible": The Dutch TSO, TenneT TSO B.V., and 
a  to  be  determined  UK  OFTO  are  responsible  for  the  development  and  construction  of  the 
interconnector (only interconnector cable) between the offshore substations of the export cable 
systems of the UK OWF and the Dutch OWF. 

 
 
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▪  Option 4 "TenneT TSO B.V. and UK interconnector developer are responsible": The Dutch TSO, 
TenneT TSO B.V., and a UK interconnector developer are responsible for the development and 
construction of the interconnector (only interconnector cable) between the offshore substations 
of the export cable systems of the UK OWF and the Dutch OWF. 

Legal / 
regulatory 
coverage 

Option 1: TenneT 
TSO B.V. is 
responsible 

Covered in UK and 
NL legislation and 
regulation – EU 
network codes 
such as "HVDC 
Connections" 
support technical 
standardisation  

Option 2: TenneT 
TSO B.V. and 
Vattenfall are 
responsible 

Option 3: TenneT 
TSO B.V. and 
OFTO are 
responsible 

Covered in UK and 
NL legislation and 
regulation 
(unbundling 
applies only after 
commissioning) – 
EU network codes 
such as "HVDC 
Connections" 
support technical 
standardisation  

Not covered in UK 
legislation and 
regulation since 
one OFTO cannot 
hold both 
transmission and 
IC license but 
covered in NL 
legislation and 
regulation – EU 
network codes 
such as "HVDC 
Connections" 
support technical 
standardisation  

Costs are with UK 
and NL 

Costs 

Costs are with NL  Costs are with NL 

and OWF 
developer 

Financial risk 

Financial risk is 
with TenneT TSO 
B.V. (offshore grid 
operator), and thus 
with NL, therefore 
no risk towards 
project realisation 

Financial risk is 
with TenneT TSO 
B.V. (offshore grid 
operator) and OWF 
developer, and 
thus with NL and 
OWF developer, 
therefore risk 
towards project 
realisation in case 
of cost overrun for 
OWF developer 

Financial risk is 
with TenneT TSO 
B.V. (offshore grid 
operator) and 
OFTO, and thus 
with NL and OFTO, 
therefore risk 
towards project 
realisation in case 
of cost overrun for 
OFTO 

Option 4: TenneT 
TSO B.V. and UK 
interconnector 
developer are 
responsible 

Covered in UK and 
NL legislation and 
regulation – EU 
network codes 
such as "HVDC 
Connections" 
support technical 
standardisation  

Costs are with NL 
and UK IC 
developer 

Financial risk is 
with TenneT TSO 
B.V. (offshore grid 
operator) and UK 
IC developer, and 
thus with NL and 
UK IC developer, 
therefore risk 
towards project 
realisation 

 
 
 
 
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Development 
risk 

Market-specific 
expertise 

Summary 

Option 1: TenneT 
TSO B.V. is 
responsible 

Alignment of 
development not 
needed for single 
developer but 
across parts of 
entire cable system 
due to differing 
responsibilities, 
therefore low risk 
towards project 
realisation 

Knowledge on 
general and 
project-specific grid 
connection 
requirements given 
for TenneT TSO 
B.V. in the NL and 
to some extent in 
the UK (from 
BritNed) 

Covered under UK 
and NL legal and 
regulatory regime 
and with low risk 
towards project 
realisation but only 
with market-
specific expertise 
in the NL 

Option 2: TenneT 
TSO B.V. and 
Vattenfall are 
responsible 

Option 3: TenneT 
TSO B.V. and 
OFTO are 
responsible 

Option 4: TenneT 
TSO B.V. and UK 
interconnector 
developer are 
responsible 

Alignment of 
development 
needed for multiple 
developers and 
additionally across 
parts of entire 
cable system due 
to differing 
responsibilities, 
therefore uncertain 
risk towards project 
realisation  

Alignment of 
development 
needed for multiple 
developers and 
additionally across 
parts of entire 
cable system due 
to differing 
responsibilities, 
therefore uncertain 
risk towards project 
realisation  

Alignment of 
development 
needed for multiple 
developers and 
additionally across 
parts of entire 
cable system due 
to differing 
responsibilities, 
therefore uncertain 
risk towards project 
realisation  

Knowledge on 
general and 
project-specific grid 
connection 
requirements given 
for Vattenfall in the 
UK and for TenneT 
TSO B.V. in the NL 

Knowledge on 
general and 
project-specific grid 
connection 
requirements given 
for OFTO in the UK 
and for TenneT 
TSO B.V. in the NL  

Knowledge on 
general and 
project-specific grid 
connection 
requirements given 
for UK 
interconnector 
developer in the 
UK and for TenneT 
TSO B.V. in the NL  

Covered under UK 
and NL legal and 
regulatory regime 
and market-
specific expertise 
in the UK and the 
NL, but with 
uncertain risk 
towards project 
realisation 

Not covered under 
UK legal and 
regulatory regime 
and with uncertain 
risk towards project 
realisation but 
market-specific 
expertise in the UK 
and the NL 

Covered under UK 
and NL legal and 
regulatory regime 
and market-
specific expertise 
in the UK and the 
NL, but with 
uncertain risk 
towards project 
realisation 

Table 13: CGS IJmuiden Ver to Norfolk – Assessment of options for responsibility during IC development and 
construction phase 

In summary, the interaction with stakeholders shows that all four options – TenneT TSO B.V. being 
responsible for the development and construction of the interconnector (Option 1) as well as TenneT 
TSO  B.V.  together  with  Vattenfall  (Option  2),  a  to  be  determined  UK  OFTO  (Option  3)  or  a  UK 
interconnector developer being responsible (Option 4) – have advantages and disadvantages. While 
TenneT TSO B.V. is legally allowed and able to develop and construct the interconnector on its own 
(Option 1), the collaboration with Vattenfall or with a UK interconnector developer is also possible and 
would  make  sense  as  a  UK  entity  can  contribute  additional  market-specific  expertise  about  the 

 
 
 
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connection to the UK market (Options 2 and 4). A collaboration between TenneT TSO B.V. and an 
OFTO  (Option  3)  is  not  covered  under  the  UK  legal  and  regulatory  regime.  Compared  to  shared 
responsibility between TenneT TSO B.V. and Vattenfall, an OFTO or a UK interconnector developer 
(Options 2, 3 and 4), the risk towards project realisation can be reduced if TenneT TSO B.V. is solely 
responsible for the development and construction of the interconnector (Option 1). 

Considering the results of the interaction with the stakeholders, the selection and / or implementation 
of the appropriate mitigation option for the CGS IJmuiden Ver to Norfolk hybrid project must also take 
into account the interdependencies between the individual barriers. 

Responsibility for operation of interconnector 

This subtopic of the barrier is relevant for the CGS IJmuiden Ver to Norfolk hybrid project. 

To  address  this  subtopic  of  the  barrier,  four  mitigation  options  are  assessed  with  regard  to  their 
applicability (Table 14) – excluding the implications of interdependencies with other barriers. 

▪  Option 1 "TenneT TSO B.V. is responsible": The Dutch TSO, TenneT TSO B.V., is responsible 
for  the  operation  of  the  interconnector  (only  interconnector  cable)  between  the  offshore 
substations of the export cable systems of the UK OWF and the Dutch OWF. 

▪  Option 2 "TenneT TSO B.V. and Vattenfall are responsible": The Dutch TSO, TenneT TSO B.V., 
and the OWF developer, Vattenfall, are responsible for the operation of the interconnector (only 
interconnector cable)  between the offshore substations of the export cable systems of the UK 
OWF and the Dutch OWF. 

▪  Option 3 "TenneT TSO B.V. and OFTO are responsible": The Dutch TSO, TenneT TSO B.V., and 
a  to  be  determined  UK  OFTO  are  responsible  for  the  operation  of  the  interconnector  (only 
interconnector cable)  between the offshore substations of the export cable systems of the UK 
OWF and the Dutch OWF. 

▪  Option 4 "TenneT TSO B.V. and UK interconnector developer are responsible": The Dutch TSO, 
TenneT  TSO  B.V.,  and  UK  interconnector  developer  are  responsible  for  the  operation  of  the 
interconnector (only interconnector cable) between the offshore substations of the export cable 
systems of the UK OWF and the Dutch OWF.  

 
 
 
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Legal / 
regulatory 
coverage 

Option 1: TenneT 
TSO B.V. is 
responsible 

Covered in UK and 
NL legislation and 
regulation – EU 
network codes, 
such as "System 
Operations", and 
EU Regulations, 
such as "Electricity 
cross-border 
exchanges", 
support technical 
standardisation 

Option 2: TenneT 
TSO B.V. and 
Vattenfall are 
responsible 

Option 3: TenneT 
TSO B.V. and 
OFTO are 
responsible 

Not covered in UK, 
NL and EU 
legislation and 
regulation 
(unbundling 
applies for OWF 
developer) – EU 
network codes, 
such as "System 
Operations", and 
EU Regulations, 
such as "Electricity 
cross-border 
exchanges", 
support technical 
standardisation 

Not covered in UK 
legislation and 
regulation since 
one OFTO cannot 
hold both 
transmission and 
IC license but 
covered in NL 
legislation and 
regulation – EU 
network codes, 
such as "System 
Operations", and 
EU Regulations, 
such as "Electricity 
cross-border 
exchanges", 
support technical 
standardisation 

Costs are with UK 
and NL 

Option 4: TenneT 
TSO B.V. and UK 
interconnector 
developer are 
responsible 

Covered in UK and 
NL legislation and 
regulation – EU 
network codes, 
such as "System 
Operations", and 
EU Regulations, 
such as "Electricity 
cross-border 
exchanges", 
support technical 
standardisation 

Costs are with NL 
and UK IC 
developer 

Costs 

Costs are with NL  Costs are with NL 

and OWF 
developer 

Operational 
risk 

Alignment of 
operations not 
needed for single 
developer but 
across parts of 
entire cable system 
due to differing 
responsibilities, 
therefore low risk 
towards project 
realisation  

Alignment of 
operations needed 
for multiple 
developers and 
additionally across 
parts of entire 
cable system due 
to differing 
responsibilities, 
therefore uncertain 
risk towards project 
realisation 

Alignment of 
operations needed 
for multiple 
developers and 
additionally across 
parts of entire 
cable system due 
to differing 
responsibilities, 
therefore uncertain 
risk towards project 
realisation 

Alignment of 
operations needed 
for multiple 
developers and 
additionally across 
parts of entire 
cable system due 
to differing 
responsibilities, 
therefore uncertain 
risk towards project 
realisation 

 
 
 
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Market-specific 
expertise 

Summary 

Option 1: TenneT 
TSO B.V. is 
responsible 

Knowledge on 
general and 
project-specific 
operational 
requirements given 
for TenneT TSO 
B.V. in the NL and 
to some extent in 
the UK (from 
BritNed) 

Covered under UK 
and NL legal and 
regulatory regime 
and with low risk 
towards project 
realisation but only 
with market-
specific expertise 
in the NL 

Option 2: TenneT 
TSO B.V. and 
Vattenfall are 
responsible 

Option 3: TenneT 
TSO B.V. and 
OFTO are 
responsible 

Knowledge on 
general and 
project-specific 
operational 
requirements given 
for Vattenfall in the 
UK and for TenneT 
TSO B.V. in the NL 

Knowledge on 
general and 
project-specific 
operational 
requirements given 
for OFTO in the UK 
and for TenneT 
TSO B.V. in the NL  

Option 4: TenneT 
TSO B.V. and UK 
interconnector 
developer are 
responsible 

Knowledge on 
general and 
project-specific 
operational 
requirements given 
for UK IC 
developer in the 
UK and for TenneT 
TSO B.V. in the NL 

Not covered under 
EU and national 
legal and 
regulatory regime 
and with uncertain 
risk towards project 
realisation, but with 
market-specific 
expertise in the UK 
and the NL  

Not covered under 
UK legal and 
regulatory regime 
and with uncertain 
risk towards project 
realisation, but with 
market-specific 
expertise in the UK 
and the NL  

Covered under UK 
and NL legal and 
regulatory regime 
and with market-
specific expertise 
in the UK and the 
NL, but with 
uncertain risk 
towards project 
realisation  

Table 14: CGS IJmuiden Ver to Norfolk – Assessment of options for responsibility during IC operation phase 

In summary, this interaction with stakeholders shows that all four options – TenneT TSO B.V. being 
responsible for the operation of the interconnector (Option 1) as well as TenneT TSO B.V. together 
with Vattenfall (Option 2), a to be determined UK OFTO (Option 3) or a UK interconnector developer 
being  responsible  (Option  4)  –  have  advantages  and  disadvantages.  While  TenneT  TSO  B.V.  is 
legally allowed and able to operate the interconnector on its own (Option 1), the collaboration with a 
UK interconnector developer is also possible and would make sense as a UK entity can contribute 
additional  market-specific  expertise  about  the  operation  of  a  cable  system  connected  to  the  UK 
market (Option 4). A collaboration between TenneT TSO B.V. and Vattenfall (Option 2) or an OFTO 
(Option 3) is not covered under EU and / or UK legal and regulatory regime. Compared to shared 
responsibility between TenneT TSO B.V. and Vattenfall, an OFTO or a UK interconnector developer 
(Options 2, 3 and 4), the risk towards project realisation can be reduced if TenneT TSO B.V. is solely 
responsible for the operation of the interconnector (Option 1).  

Considering the results of the interaction with the stakeholders, the selection and / or implementation 
of the appropriate mitigation option for the CGS IJmuiden Ver to Norfolk hybrid project must also take 
into account the interdependencies between the individual barriers. 

5.2.2  Uncertainty about regulation deriving from jurisdiction over cross-border 

cable systems 

This barrier is relevant for the CGS IJmuiden Ver to Norfolk hybrid project. 

 
 
 
218   HYBRID PROJECTS: HOW TO REDUCE COSTS AND SPACE OF OFFSHORE DEVELOPMENTS 

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To address this barrier, three mitigation options are assessed with regard to their applicability (Table 
15)  –  excluding  the  implications  of  interdependencies  with  other  barriers.  The  assessment 
concentrates  on  the  regulation  applicable  to  the  operation  of  the  interconnector  since  the 
development and construction of the interconnector constitute no barrier. Furthermore, the UK as well 
as  the  Dutch  regulation  is  applicable  to  the  UK  and  Dutch  OWFs  and  export  cable  systems, 
respectively. 

▪  Option 1 "UK jurisdiction's regulations": In addition to European law, UK regulation applies to the 
operation of the interconnector linking the offshore substations of the two export cable systems 
of the UK and Dutch OWFs across both the UK and the Dutch EEZ. 

▪  Option 2 "Dutch jurisdiction's regulations": In addition to European law, Dutch regulation applies 
to  the  operation  of  the  interconnector  linking  the  offshore  substations  of  the  two  export  cable 
systems of the UK and Dutch OWFs across both the UK and the Dutch EEZ. 

▪  Option 3 "Alignment of jurisdictions' regulations": Based on negotiations between the UK and the 
Netherlands,  a  new  combination  of  regulations  applies  to  the  operation  of  the  interconnector 
linking  the  offshore  substations  of  the  two  export  cable  systems  of  the  UK  and  Dutch  OWFs 
across both the UK and the Dutch EEZ – in addition to European law. The new combination of 
regulations  over  the  operation  of  the  interconnector  can  potentially  be  based  on  existing 
agreements established for the interconnectors between the UK and the Netherlands, such as 
BritNed. 

Rights and 
duties in UK 
EEZ during 
operation 

Rights and 
duties in NL 
EEZ during 
operation 

Option 1: UK 
jurisdiction's 
regulations 

Option 2: Dutch 
jurisdiction's 
regulations 

Uncertainty and thus 
alignment required since 
neither country has clear 
jurisdiction since cable 
neither crosses the UK 
nor the NL territorial seas 
as well as does not serve 
exploitation of the UK nor 
the NL EEZ  

Uncertainty and thus 
alignment required since 
neither country has clear 
jurisdiction since cable 
neither crosses the UK 
nor the NL territorial seas 
as well as does not serve 
exploitation of the UK nor 
the NL EEZ  

Uncertainty and thus 
alignment required since 
neither country has clear 
jurisdiction since cable 
neither crosses the UK 
nor the NL territorial seas 
as well as does not serve 
exploitation of the UK nor 
the NL EEZ 

Uncertainty and thus 
alignment required since 
neither country has clear 
jurisdiction since cable 
neither crosses the UK 
nor the NL territorial seas 
as well as does not serve 
exploitation of the UK nor 
the NL EEZ 

Option 3: Alignment of 
jurisdictions' 
regulations, e.g. based 
on BritNed 

Alignment required to 
combine operational rules 
deriving from jurisdictions 
of the UK and the NL for 
UK EEZ through 
involvement of the UK and 
the NL 

Alignment required to 
combine operational rules 
deriving from jurisdictions 
of the UK and the NL for 
NL EEZ through 
involvement of the UK and 
the NL 

 
 
 
 
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Hybrid project 
requirements 

Timeline 

Others 

Summary 

Option 3: Alignment of 
jurisdictions' 
regulations, e.g. based 
on BritNed 

No additional alignment of 
operational rules required 

Option 1: UK 
jurisdiction's 
regulations 

Option 2: Dutch 
jurisdiction's 
regulations 

Alignment of operational 
rules between the UK and 
the NL required because 
of a connection of the NL 
OWF to the interconnector 
via the offshore substation 
of the Dutch export cable 
system 

Alignment of operational 
rules between the UK and 
the NL required because 
of a connection of the UK 
OWF to the interconnector 
via the offshore substation 
of the UK export cable 
system 

Alignment may extend the 
timeline of the project 

Alignment may extend the 
timeline of the project 

Alignment may extend the 
timeline of the project 

Uncertainty and thus 
alignment required to 
ensure applicability of 
Option 1 since no clear 
rules apply in all relevant 
maritime zones 

Uncertainty and thus 
alignment required to 
ensure applicability of 
Option 2 since no clear 
rules apply in all relevant 
maritime zones 

Provisions for assigning 
liability in case of grid 
connection failure need to 
be implemented 

Alignment required to 
ensure applicability of 
Option 3 since no clear 
rules apply in all relevant 
maritime zones 

Table 15: CGS IJmuiden Ver to Norfolk – Assessment of options for regulation deriving from jurisdiction 
deriving from cross-border cable systems 

In summary, the interaction with stakeholders shows that all three options  – the agreement on the 
applicability of operational rules to the interconnector based on UK (Option 1) or Dutch jurisdiction 
(Option 2) as well as the alignment of rules deriving from the UK and Dutch jurisdiction (Option 3) – 
have  advantages  and  disadvantages.  While  chances  of  an  agreement  among  the  UK  and  the 
Netherlands on a single jurisdiction are limited, the alignment of rules deriving from two jurisdictions 
can be a lengthy process. Yet, Option 3 reflects the interest of both countries in the alignment and 
can potentially build on existing agreements established for the interconnectors between the UK and 
the Netherlands, such as BritNed. 

Considering the results of the interaction with the stakeholders, the selection and / or implementation 
of the appropriate mitigation option for the CGS IJmuiden Ver to Norfolk hybrid project must also take 
into account the interdependencies between the individual barriers. 

5.2.3  Uncertainty about market arrangements 

This barrier is relevant for the CGS IJmuiden Ver to Norfolk hybrid project. 

In the context of the CGS IJmuiden Ver to Norfolk hybrid project, the market arrangement is foreseen 
to be commercial flows to the home market, this is, of the UK OWF only to the UK and of the Dutch 
OWF only to the Netherlands. Since this market arrangement was identified in the interaction with 
project stakeholders as most feasible from the beginning, no other mitigation options were considered 

 
 
 
 
 
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in detail. Leftover capacities on the export cable systems of the OWFs are foreseen to be available 
for interconnector trade.  

Considering the identification of the market arrangement by the stakeholders, the validation of this 
mitigation option as appropriate for the CGS IJmuiden Ver to Norfolk hybrid project must also take 
into account the interdependencies between the individual barriers. 

5.2.4  Uncertainty about hybrid cable system classification 

This barrier is relevant for the CGS IJmuiden Ver to Norfolk hybrid project. 

To address this barrier, two mitigation options are assessed with regard to their applicability (Table 
16)  –  excluding  the  implications  of  interdependencies  with  other  barriers.  The  assessment 
concentrates on the export cable systems between the UK OWF and the UK market as well as the 
Dutch OWF and the Dutch market. The interconnector included in the hybrid project, meaning the 
cable connection from the offshore substation of the export cable systems of the UK OWF and the 
Dutch  OWF  functions  solely  as  an  interconnector  since  each  OWF  only  transmits  electricity  to  its 
respective home market (market arrangement as foreseen by the project developers). 

▪  Option 1 "Export system with interconnector functionality": The UK and the Dutch export cable 
system are hybrid cable systems which allow for the transmission of electricity from the UK and 
the Dutch OWF to the UK and the Dutch  markets, respectively. Hence, the UK and the Dutch 
export cable system (together with the interconnector and the other export cable system) only 
provide  leftover  capacities  for  the  interconnector  functionality  between  the  UK  and  the  Dutch 
bidding zone. 

▪  Option 2 "Interconnector with export system functionality": The UK and the Dutch export cable 
system are hybrid cable systems which allow for the transmission of electricity from the UK and 
the Dutch OWF to the UK and the Dutch market, respectively, only with leftover capacities. Hence, 
the UK and the Dutch export cable system (together with the interconnector and the other export 
cable  system)  primarily  provide  interconnector  functionality  between  the  UK  and  the  Dutch 
bidding zone. 

Option 1: Export cable with IC 
functionality 

Option 2: IC with export cable 
functionality  

UK national 
legal / 
regulatory 
coverage 

Not covered as OFTO transmission 
license does not permit market-to-
market flows and one OFTO cannot hold 
both a transmission and an 
interconnector license 

Not covered as OFTO transmission 
license does not permit market-to-
market flows and one OFTO cannot hold 
both a transmission and an 
interconnector license 

NL national 
legal / 
regulatory 
coverage 

Potentially covered as NL regulation 
does not expressly prohibit dual 
functionality of cables but legal / 
regulatory feasibility to be validated 

Potentially covered as NL regulation 
does not expressly prohibit dual 
functionality of cables but legal / 
regulatory feasibility to be validated 

 
 
 
 
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EU legal / 
regulatory 
coverage 

Option 1: Export cable with IC 
functionality 

Option 2: IC with export cable 
functionality  

Not covered under Electricity Directive 
because it does not include an add. 
definition for hybrid cable systems; EU 
Regulation 714/2009 prescribes that 
"maximum capacity of the 
interconnections […] shall be made 
available to market participants" with 
clarity needed whether "maximum" 
refers to nominal or leftover capacities of 
cable systems in hybrid projects 

Not covered under Electricity Directive 
because it does not include an add. 
definition for hybrid cable systems; EU 
Regulation 714/2009 prescribes that 
"maximum capacity of the 
interconnections […] shall be made 
available to market participants" with 
clarity needed whether "maximum" 
refers to nominal or leftover capacities of 
cable systems in hybrid projects 

Potential for 
curtailment of 
OWF 

OWFs can transmit electricity to shore at 
full generation capacity, and thus no 
business case implications and 
minimised curtailment 

OWFs can transmit electricity to shore 
depending on leftover capacity of cable 
systems, and thus negative business 
case implications due to additional 
curtailment 

Potential for 
congestion of 
IC 

Capacity available for trade is 
significantly reduced, and thus negative 
business case implications for IC 
functionality of the entire cable system 

Full capacity is available for trade, and 
thus no business case implications for 
IC functionality of the entire cable 
system 

Compensation  Due to joint development of 

transmission assets in hybrid project, 
optimisation of business case of cable 
system as a whole given; potentially no 
additional compensation necessary  

Due to foregone revenues from 
additional curtailment, additional 
compensation for OWFs required 

Third party 
access 

Third party access only given for leftover 
capacities after transmission of 
electricity from OWFs to shores 

Third party access given 

Impact on 
EU's energy 
policy targets 

Priority on primary targets of 
diversification and integration of RES as 
well as on GHG emission reductions 
over secondary target of maximised IC 
capacity 

Priority on secondary target of 
maximised IC capacity over primary 
targets of diversification and integration 
of RES as well as on GHG emission 
reductions  

Summary 

Not covered under existing EU 
regulation, but potentially covered under 
NL regulation; potential for negative 
business case implications for IC may 
necessitate additional compensation 

Not covered under existing EU 
regulation, but potentially covered under 
NL regulation; negative business case 
implications for OWFs necessitate 
additional compensation 

Table 16: CGS IJmuiden Ver to Norfolk – Assessment of options for hybrid cable system classification 

In  summary,  the  interaction  with  stakeholders  shows  that  both  options  –  an  export  cable  with 
interconnector functionality (Option 1) and an interconnector with export cable functionality (Option 2) 
– have advantages and disadvantages. Both, Option 1 and 2 require changes in the European and 
UK regulatory framework as well as potentially in the Dutch legal and regulatory framework. Option 2 

 
 
 
 
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has unfavourable  implications for the  business case  of the OWF developers since the developers 
have no priority access to transmission capacity. Contrary, in Option 1, the interconnector developers 
have no priority access to the capacity of the cable system resulting in unfavourable implications for 
the business case for the interconnector. However, the interconnector developers might be able to 
optimise the entire cable system to counterbalance implications in consequence of the connection of 
the OWFs to it. Furthermore, Option 2 prioritises the secondary EU energy policy target of maximised 
electricity interconnection capacity over the primary targets of diversification and integration of RES 
as well as greenhouse gas emission reduction. 

Considering the results of the interaction with the stakeholders, the selection and / or implementation 
of the appropriate mitigation option for the CGS IJmuiden Ver to Norfolk hybrid project must also take 
into account the interdependencies between the individual barriers. 

5.2.5 

Failure of developers to align planning across assets and countries 

The barrier "failure of developers to align planning across assets and countries" is divided into three 
subtopics, geographical alignment, technical alignment and timing alignment. The three subtopics are 
addressed individually in the following. 

Geographical alignment 

This subtopic of the barrier is relevant for the CGS IJmuiden Ver to Norfolk hybrid project. 

In  summary,  the  interaction  with  stakeholders  shows  that  there  is  no  specific,  tangible  mitigation 
option to address the barrier of failed geographical alignment across assets and countries, but rather 
that a process towards the mitigation of the barrier must be followed. The process consists of the 
continuous  exchange  between  project  developers  and  other  stakeholders  to  allow  for  the 
achievement of early-stage, geographical alignment. 

Considering the results of the interaction with the stakeholders, the mitigation process to be followed 
for the CGS IJmuiden Ver to Norfolk hybrid project must also take into account the interdependencies 
between the individual barriers. 

Technical alignment 

This subtopic of the barrier is relevant for the CGS IJmuiden Ver to Norfolk hybrid project. 

In  summary,  the  interaction  with  stakeholders  shows  that  there  is  no  specific,  tangible  mitigation 
option to address the barrier of failed technical alignment across assets and countries, but rather that 
a  process  towards  the  mitigation  of  the  barrier  must  be  followed.  The  process  consists  of  the 
continuous  exchange  between  project  developers  and  other  stakeholders  to  allow  for  the 
achievement of early-stage, technical alignment. 

Considering the results of the interaction with the stakeholders, the selection and / or implementation 
of  the  appropriate  mitigation  option  for  the  IJmuiden  Ver  to  UK  hybrid  project  must  also  take  into 
account the interdependencies between the individual barriers. 

Timing alignment 

This subtopic of the barrier is not relevant for the CGS IJmuiden Ver to Norfolk hybrid project. 

In  the  context  of  the  CGS  IJmuiden  Ver  to  Norfolk  hybrid  project,  timing  alignment  is  not  relevant 
since the two OWFs can function as stand-alone assets with the interconnector between the offshore 
substations of the export cable systems of the OWFs as an additional asset that can be added later 
in  time.  Thus,  the  timelines  do  not  need  to  be  aligned  provided  that  geographical  and  technical 
alignment have taken place. 

 
 
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5.2.6  Uncertainty about responsibility and rules to provide access to maritime 

space for OWFs (location selection, site pre-investigation and tender 
execution) 

The barrier "uncertainty about responsibility and rules to provide access to maritime space for OWFs 
(location selection, site pre-investigation and tender execution)" is divided into two subtopics, location 
selection and site  pre-investigation as  well as tender  execution. The two subtopics are addressed 
individually in the following. 

Location selection and site pre-investigation 

This subtopic of the barrier is not relevant for the CGS IJmuiden Ver to Norfolk hybrid project. 

In the context of the CGS IJmuiden Ver to Norfolk hybrid project, there is no uncertainty concerning 
location selection and site  pre-investigation responsibility and procedures since the UK and Dutch 
authorities  are  responsible  and  UK  and  Dutch  procedures  are  applicable,  respectively,  for  the  UK 
OWF and the Dutch OWF included in the hybrid project. 

Tender responsible party 

This subtopic of the barrier is not relevant for the CGS IJmuiden Ver to Norfolk hybrid project. 

In the context of the CGS IJmuiden Ver to Norfolk hybrid project, there is no uncertainty concerning 
determination  of  the  tender  responsible  party  since  the  respective  party  of  the  national  tender 
procedure is responsible for the tenders of the UK OWF and the Dutch OWF included in the hybrid 
project. 

5.2.7  Uncertainty about responsibility and rules to provide access to maritime 

space for OWFs (tender design) 

This barrier is relevant for the CGS IJmuiden Ver to Norfolk hybrid project. 

To address this barrier, four mitigation options are assessed with regard to their applicability (Table 
17) – excluding the implications of interdependencies with other barriers. 

▪  Option  1  "Strict  design  with  aligned  requirements  and  without  hybrid-specific  uncertainties":  A 
tender  design  with  strict  pre-qualification  requirements  implies  that  extensive  pre-qualification 
requirements are defined to ensure hybrid-specific and general capabilities to develop the CGS 
IJmuiden  Ver  to  Norfolk  hybrid  project.  The  requirements  are  aligned  among  the  UK  and  the 
Netherlands, including a jointly agreed set of financial requirements and a certain set of both UK 
and Dutch rules related to the OWF sites (e.g. environmental details) and a certain set of both 
UK and Dutch rules related to the grid connection of the OWFs (e.g. technical and operational 
details  such  as  system  integration  or  frequency  control).  Furthermore,  all  uncertainties  arising 
from the hybrid character of the OWF developments are clarified prior to the tender. 

▪  Option 2  "Strict design  with aligned requirements": A tender design  with strict  pre-qualification 
requirements implies that extensive pre-qualification requirements are defined to ensure hybrid-
specific and general capabilities to develop the CGS IJmuiden Ver to Norfolk hybrid project. The 
requirements are aligned among the UK and the Netherlands, including a jointly agreed set of 
financial requirements and a certain set of both UK and Dutch rules related to the OWF sites (e.g. 
environmental details) and a certain set of both UK and Dutch rules related to the grid connection 
of  the  OWFs  (e.g.  technical  and  operational  details  such  as  system  integration  or  frequency 
control).  Furthermore,  the  uncertainties  arising  from  the  hybrid  character  of  the  OWF 
developments are not clarified prior to the tender. 

 
 
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▪  Option  3:  "Strict  design  without  hybrid-specific  uncertainties":  A  tender  design  with  strict  pre-
qualification  requirements  implies  that  extensive  pre-qualification  requirements  are  defined  to 
ensure hybrid-specific and general capabilities to develop the CGS IJmuiden Ver to Norfolk hybrid 
project. The requirements are either defined by the UK or by the Netherlands and not aligned. 
Furthermore, all uncertainties arising from the hybrid  character of the OWF developments are 
clarified prior to the tender. 

▪  Option 4 "Lenient design with aligned requirements and without hybrid-specific uncertainties": A 
tender design with lenient pre-qualification requirements is chosen, implying that only limited pre-
qualification requirements are defined to ensure competition and low prices. The requirements 
are  aligned  among  the  UK  and  the  Netherlands,  including  a  jointly  agreed  set  of  financial 
requirements  and  a  certain  set  of  both  UK  and  Dutch  rules  related  to  the  OWF  sites  (e.g. 
environmental details) and a certain set of both UK and Dutch rules related to the grid connection 
of  the  OWFs  (e.g.  technical  and  operational  details  such  as  system  integration  or  frequency 
control).  Furthermore,  all  uncertainties  arising  from  the  hybrid  character  of  the  OWF 
developments are clarified prior to the tender. 

Legal / 
regulatory 
coverage 

Alignment of 
requirements 

Option 3: Strict 
design and no 
uncertainties 

Covered and no 
amendments to 
national legislation 
and regulation 
necessary since 
only one country is 
involved in defining 
tender design 

No alignment of 
requirements 

Option 1: Strict 
design, aligned 
requirements and 
no uncertainties 

Option 2: Strict 
design and 
aligned 
requirements  

Not covered and 
potential 
amendments to 
national legislation 
and regulation 
necessary since 
multiple countries 
are involved in 
defining tender 
design 

Not covered and 
potential 
amendments to 
national legislation 
and regulation 
necessary since 
multiple countries 
are involved in 
defining tender 
design 

Financial, technical 
and operational 
requirements 
aligned; 
environmental 
requirements 
defined by the UK 
and the NL for 
corresponding 
OWFs 

Financial, technical 
and operational 
requirements 
aligned; 
environmental 
requirements 
defined by the UK 
and the NL for 
corresponding 
OWFs 

Option 4: Lenient 
design, aligned 
requirements and 
no uncertainties 

Not covered and 
potential 
amendments to 
national legislation 
and regulation 
necessary since 
multiple countries 
are involved in 
defining tender 
design 

Financial, technical 
and operational 
requirements 
aligned; 
environmental 
requirements 
defined by the UK 
and the NL for 
corresponding 
OWFs 

 
 
 
 
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Hybrid-
specific un-
certainties 

Realisation 
probability 

Option 1: Strict 
design, aligned 
requirements and 
no uncertainties 

Option 2: Strict 
design and 
aligned 
requirements  

All uncertainties 
arising from hybrid-
specific setup are 
clarified, e.g. 
liability, applicable 
jurisdiction, grid 
connection 
responsibility, 
hybrid cable 
system 
classification 

Uncertainties 
arising from hybrid 
character of 
development not 
entirely clarified 
such that 
uncertainty 
remains for OWF 
developer 

Applying OWF 
developers are 
aware of all 
specifications and 
requirements and 
can align planning 
and financing right 
from the beginning 

Applying OWF 
developers are 
aware of all 
specifications and 
requirements and 
can align planning 
and financing right 
from the beginning  

Option 4: Lenient 
design, aligned 
requirements and 
no uncertainties 

All uncertainties 
arising from hybrid-
specific setup are 
clarified, e.g. 
liability, applicable 
jurisdiction, grid 
connection 
responsibility, 
hybrid cable 
system 
classification 

Applying OWF 
developers are not 
aware of most 
specifications and 
requirements, 
which might result 
in significant cost 
overruns / delays 
after the tender 
process 

Option 3: Strict 
design and no 
uncertainties 

All uncertainties 
arising from hybrid-
specific setup are 
clarified, e.g. 
liability, applicable 
jurisdiction, grid 
connection 
responsibility, 
hybrid cable 
system 
classification 

Applying OWF 
developers are 
aware of all 
specifications and 
requirements and 
can align planning 
and financing right 
from the beginning; 
however, it is 
questionable 
whether OWFs 
connected to two 
countries can be 
tendered without 
alignment of tender 
requirements 

Cost efficiency  Due to strict 

requirements and 
specifications, less 
developers 
expected to apply 
– cost efficiency of 
offers expected to 
decrease with 
fewer applicants 

Due to strict 
requirements and 
specifications, less 
developers 
expected to apply 
– cost efficiency of 
offers expected to 
decrease with 
fewer applicants 

Due to strict 
requirements and 
specifications, less 
developers 
expected to apply 
– cost efficiency of 
offers expected to 
decrease with 
fewer applicants 

Due to lenient 
requirements and 
specifications, 
many developers 
expected to apply 
– cost efficiency of 
offers expected to 
increase with more 
applicants 

 
 
 
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Summary 

Option 1: Strict 
design, aligned 
requirements and 
no uncertainties 

Option 2: Strict 
design and 
aligned 
requirements  

Legal and 
regulatory 
coverage to be 
assessed and 
potentially 
decreases cost 
efficiency 

Legal and 
regulatory 
coverage to be 
assessed and 
decreases cost 
efficiency, 
particularly due to 
remaining hybrid 
uncertainties 

Option 4: Lenient 
design, aligned 
requirements and 
no uncertainties 

Legal and 
regulatory 
coverage to be 
assessed and 
strongly decreases 
probability of 
project realisation  

Option 3: Strict 
design and no 
uncertainties 

Legal and 
regulatory 
coverage given, 
but with limited 
chance of 
realisation due to 
non-consideration 
of one country's 
interest in defining 
tender 
requirements 

Table 17: CGS IJmuiden Ver to Norfolk – Assessment of options for tender design 

In summary, the interaction with stakeholders shows that all four options – a strict or lenient tender 
design  with  aligned  requirements  and  certainty  about  hybrid-specific  characteristics  of  the  OWF 
development (Option 1 and 4), a strict tender design with aligned requirements (Option 3) as well as 
a  strict  tender  design  with  certainty  about  hybrid-specific  characteristics  of  the  OWF  development 
(Option  2)  –  have  advantages  and  disadvantages.  While  a  tender  design  with  strict  requirements 
(Options 1, 2 and 3) increases the probability of successful project implementation, a tender design 
with  lenient  requirements  (Option  4)  decreases  the  cost  of  implementation  through  competition. 
Furthermore, certainty about hybrid-specific characteristics of the OWF development (Option 1, 3 and 
4)  increases  the  probability  of  successful  project  implementation  and  decreases  the  cost  of 
implementation by reducing the risk premium otherwise demanded by OWF developers in terms of 
subsidies. Lastly, aligned requirements (Options 1, 2 and 4) aid in ensuring the interoperability of the 
OWF with the other assets of the hybrid project and thereby increase the probability of successful 
hybrid project implementation. 

Considering the results of the interaction with the stakeholders, the selection and / or implementation 
of the appropriate mitigation option for the CGS IJmuiden Ver to Norfolk hybrid project must also take 
into account the interdependencies between the individual barriers. 

5.2.8  Discrepancies in responsibilities and requirements for balancing 

In the context of the CGS IJmuiden Ver to Norfolk hybrid project, there is no discrepancy concerning 
the balancing responsibility and requirements in the shorter term since UK and Dutch responsibilities 
and  requirements  apply  to  the  UK  OWF  and  the  Dutch  OWF  included  in  the  hybrid  project, 
respectively.  Furthermore,  the  topic  is  addressed  in  the  Clean  Energy  Package  such  that,  for  the 
Dutch  OWF,  the  translation  into  Dutch  law  needs  to  be  assessed  in  detail  by  the  project-specific 
stakeholders in the longer term. 

 
 
 
 
  
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5.2.9  Discrepancies in priority dispatch regulation 

In the context of the CGS IJmuiden Ver to Norfolk hybrid project, there is no discrepancy concerning 
priority dispatch regulation in the shorter term since UK and Dutch priority dispatch regulation applies 
to the OWFs included in the hybrid project, respectively. Furthermore, the topic is addressed in the 
Clean  Energy  Package, such that, for the Dutch OWF, the translation into Dutch law  needs to be 
assessed in detail by the project-specific stakeholders in the longer term. 

5.2.10  Discrepancies in curtailment regulation and compensation 

In  the  context  of  CGS  IJmuiden  Ver  to  Norfolk  hybrid  project,  there  is  no  discrepancy  concerning 
curtailment  and  curtailment  compensation  regulation  in  the  shorter  term  since  UK  and  Dutch 
curtailment  regulation  applies  to  the  UK  OWF  and  the  Dutch  OWF  included  in  the  hybrid  project, 
respectively. Furthermore, the topic is  addressed  in the Clean  Energy  Package, such that, for the 
Dutch  OWF,  the  translation  into  Dutch  law  needs  to  be  assessed  in  detail  by  the  project-specific 
stakeholders in the longer term. 

5.2.11  Lack of regulated revenues for anticipatory investments 

This barrier is relevant for the CGS IJmuiden Ver to Norfolk hybrid project. 

To address this barrier, four mitigation options are assessed with regard to their applicability (Table 
18) – excluding the implications of interdependencies with other barriers. 

▪  Case  1:  Anticipatory  investments  under  Dutch  regulation.  Anticipatory  investments  for  export 
cable  systems  are  necessary  due  to  the  timeline  of  the  specific  hybrid  project.  In  the  case  of 
unaligned development, the OWF and export cable system are expected to be developed first 
but  must  take  into  account  the  addition  of  the  interconnector  at  a  later  point  in  time  in  their 
technical design. Dutch export cable systems are developed by TenneT TSO B.V. 

▪  Case 2: Anticipatory investments for export cable systems under the developer build option of 
the UK OFTO regime. Anticipatory investments for export cable systems are necessary due to 
the timeline of the specific hybrid project. In the case of unaligned development, the OWF and 
export cable system are expected to be developed first but must take into account the addition of 
the interconnector at a later point in time in their technical design. UK export cable systems are 
developed by OWF developers and transferred to an OFTO before commissioning. 

▪  Case 3: Anticipatory investments for export cable systems under the OFTO build option of the 
UK OFTO regime. Anticipatory investments for export cable systems are necessary due to the 
timeline of the specific hybrid project. In the case of unaligned development, the OWFs and export 
cable systems are expected to be developed first but must take into account the addition of the 
interconnector  at  a  later  point  in  time  in  their  technical  design.  UK  export  cable  systems  are 
developed by OFTOs. 

▪  Case  4:  Anticipatory  investments for  interconnectors  under  the  UK  Cap  and  Floor  regime.  No 
anticipatory investments for the interconnector are expected due to the timeline of the specific 
hybrid  project.  In  the  case  of  unaligned  development,  the  interconnector  is  expected  to  be 
developed last. Interconnectors are developed by third parties. 

 
 
 
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Case 1: Dutch 
regulation 

Case 2: UK 
regulation – 
Developer build 

Case 3: UK 
regulation – OFTO 
build 

Case 4: UK 
regulation – Cap 
and Floor 

Concerned asset: 
Export cable 
system  

Concerned asset: 
Export cable 
system 

Concerned asset: 
Export cable 
system 

Concerned asset: 
Interconnector 

Legal / 
regulatory 
coverage 

Treatment of 
anticipatory 
investments 

Efficiency 
benchmark 

Anticipatory 
investments for 
export cable 
systems and 
interconnectors are 
considered under 
Dutch regulation 

Anticipatory 
investments are 
treated exactly the 
same way as non-
anticipatory 
investments, but 
must be included in 
Offshore Grid 
Development 
Framework by the 
Dutch government 

Efficiency 
benchmark exists 
and regulatory 
regime provides for 
standard 
procedures to 
assess appropriate 
investments 

Public opinion  Public support 

required for 
inclusion of 
investment in 
Offshore Grid 
Development 
Framework 

Anticipatory 
investments for 
export cable 
systems are 
considered under 
OFTO regime  

Anticipatory 
investments for 
export cable 
systems are 
considered under 
OFTO regime  

Anticipatory 
investments for 
interconnectors are 
considered under 
Cap and Floor 
regime 

Risk remains with 
developer since 
anticipatory 
investment are 
subject to 
determination of 
final transfer value 

Risk remains with 
OFTO since 
anticipatory 
investment are 
subject to valuation 

Efficiency 
benchmark is 
carried out on a 
project-by-project 
basis for both 
WNBI218 and 
GFAI219, such that 
criteria remain 
unclear 

Efficiency 
benchmark is 
carried out on a 
project-by-project 
basis for both 
WNBI220 and 
GFAI221, such that 
criteria remain 
unclear 

Risk remains with 
developer since 
anticipatory 
investments must 
be deemed to be in 
consumer's best 
interest to be 
included in 
determination of 
cap and floor levels  

Efficiency 
benchmark is 
carried out on a 
project-by-project 
basis such that 
criteria remain 
unclear 

Public support 
given if benchmark 
ensures that 
investment is 
efficient 

Public support 
given if benchmark 
ensures that 
investment is 
efficient 

Public support 
given if benchmark 
ensures that 
investment is 
efficient 

218 Developer-led Wider Network Benefit Investment 

219 Generator Focused Anticipatory Investment 

220 Developer-led Wider Network Benefit Investment 

221 Generator Focused Anticipatory Investment 

 
 
 
 
                                                      
 
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Case 1: Dutch 
regulation 

Case 2: UK 
regulation – 
Developer build 

Case 3: UK 
regulation – OFTO 
build 

Case 4: UK 
regulation – Cap 
and Floor 

Concerned asset: 
Export cable 
system  

Concerned asset: 
Export cable 
system 

Concerned asset: 
Export cable 
system 

Concerned asset: 
Interconnector 

No assurance 
given to developer 
that expended 
costs will be 
recovered 

No assurance 
given to developer 
that expended 
costs will be 
recovered 

No assurance 
given to developer 
that expended 
costs will be 
recovered 

Risk of stranded 
transmission 
investment exists 
but may be covered 
under existing user 
commitment 
arrangement 

Risk of stranded 
transmission 
investment not 
applicable for 
compensation 
under Cap and 
Floor regime 

Risk of stranded 
transmission 
investment exists 
and may be 
internalised / only 
covered under user 
commitment 
arrangement given 
special 
circumstances 

Risk of non-
recovery of 
anticipatory 
investment is 
prohibitive  

Risk of non-
recovery of 
anticipatory 
investment is 
prohibitive 

Risk of non-
recovery of 
anticipatory 
investment is 
prohibitive 

Risk to project 
realisation 

Risk of 
stranded 
asset 

Summary 

No risk since TSO 
can cover 
investments 
through their 
inclusion in the 
RAB 

Risk of stranded 
transmission 
investment exists 
with coverage 
under Dutch 
regulation uncertain 

Anticipatory 
investments are 
treated as regular 
investments but are 
taken at discretion 
of government 
through inclusion in 
Offshore Grid 
Development 
Framework 

Table 18: CGS IJmuiden Ver to Norfolk – Assessment of regulatory regimes for anticipatory investments 

In summary, the interaction with stakeholders shows that reimbursement needs to be assured under 
UK  legislation  and  that  the  inclusion  of  the  hybrid  project  in  the  Offshore  Grid  Development 
Framework in the Netherlands needs to be agreed, since the risk of non-recovery of costs is likely to 
be prohibitive otherwise. Still, the efficiency of anticipatory investments must be assessed to ensure 
the sensible expansion of infrastructure. 

Considering the results of the interaction with the stakeholders, the selection and / or implementation 
of the appropriate mitigation option for the CGS IJmuiden Ver to Norfolk hybrid project must also take 
into account the interdependencies between the individual barriers. 

5.2.12  Uncertainty about applicable RES subsidy scheme 

This barrier is not relevant for the CGS IJmuiden Ver to Norfolk hybrid project. 

 
 
 
 
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In the context of the CGS IJmuiden Ver to Norfolk hybrid project, there is no uncertainty concerning 
the applicability of national subsidy schemes since the respective national subsidy schemes of the 
Netherlands and the UK apply to the OWFs included in the hybrid project. 

5.2.13  Limited engagement of public stakeholders 

The  barrier  "limited  engagement  of  public  stakeholders"  is  divided  into  two  subtopics,  formalised 
public support and financial support. The two subtopics are addressed individually in the following. 

Formalisation of commitment from public stakeholders  

This subtopic of the barrier is relevant for the CGS IJmuiden Ver to Norfolk hybrid project. 

To address this barrier, two mitigation options are assessed with regard to their applicability (Table 
19) – excluding the implications of interdependencies with other barriers. 

▪  Option  1  "Memorandum  of  Understanding  (MoU)":  A  Memorandum  of  Understanding  is  a 
formalisation of the goodwill of the involved parties in form of a non-binding agreement. An MoU 
addresses  barriers  by  formalising  the  agreements  of  the  involved  parties  with  regard  to  the 
implementation  of  required  actions  to  overcome  the  barriers.  It  can  involve  all  project 
stakeholders,  such  as  OWF  developers,  TSOs,  national  ministries  and  NRAs  as  well  as  the 
European Commission. 

▪  Option 2 "Hybrid Asset Network Support Agreement (HANSA)": A project-specific Hybrid Asset 
Network  Support  Agreement  is  a  legally-binding  commitment  to  adapt  national  legislation  and 
regulation in the future, and thus provides legal certainty to developers. European legislation and 
regulation can only be adapted via a project-specific HANSA if all Member States of the European 
Union  sign  the  agreement.  It  only  directly  involves  public  stakeholders,  such  as  national 
ministries. 

Option 1: Memorandum of 
Understanding (MoU) 

Option 2: Hybrid Asset Network 
Support Agreement (HANSA) 

Required effort  Some interaction and alignment 

required among project developers and 
stakeholders to facilitate signing of 
agreement 

Provided 
certainty 

Intentional character of signed 
agreement sufficient for hybrid projects 
in early development stage  

Significant interaction and alignment 
among political project stakeholders 
required to facilitate signing of 
agreement 

Legally binding commitment to topics 
covered by signed agreement directly 
facilitates project development, but is 
only required at a later development 
stage of hybrid projects 

Summary 

Reasonable effort to align agreement 
required prior to signing and non-legally 
binding commitment sufficient in early 
project development stages 

Significant effort for alignment of 
agreement required prior to signing but 
provides legal certainty and therefore 
suitable in later development stages 

Table 19: CGS IJmuiden Ver to Norfolk – Assessment of options for formalisation of commitment from public 
stakeholders 

In  summary,  the  interaction  with  stakeholders  shows  that  both  options  –  a  project-specific 
Memorandum  of  Understanding  (Option  1)  and  a  project-specific  Hybrid  Asset  Network  Support 

 
 
 
 
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Agreement (Option 2) – have advantages and disadvantages. While less effort is usually required to 
align  and  sign  a  project-specific  MoU,  an  MoU  is  not  legally  binding,  and  thus  the  commitment  of 
public stakeholders provides limited certainty, for example, about legal and regulatory changes for 
project developers (Option 1). However, while a project-specific HANSA provides legal certainty about 
the commitment of stakeholders to implement legal and regulatory changes, the alignment process 
requires more effort (Option 2).  

Considering the results of the interaction with the stakeholders, the selection and / or implementation 
of the appropriate mitigation option for the CGS IJmuiden Ver to Norfolk hybrid project must also take 
into account the interdependencies between the individual barriers as well as the development stage 
of the hybrid project. 

Financial support 

This subtopic of the barrier is relevant for the CGS IJmuiden Ver to Norfolk hybrid project. 

In  summary,  the  interaction  with  stakeholders  shows  that  there  is  no  specific,  tangible  mitigation 
option  to  address  the  barrier  of  limited  financial  support,  but  rather  that  a  portfolio  of  support 
programmes is available, and their usage needs to be increased to facilitate the implementation of 
hybrid projects. In the past, hybrid project development and / or considerations, such as the Combined 
Grid Solution Kriegers Flak in the Baltic Sea and the Interconnector tie-in COBRA Cable in the North 
Sea,  indicate  that  such  support  is  required  to  de-risk  and  thereby  allow  for  the  realisation  of  pilot 
projects. In this context, financial support can come in various forms, such as co-financing for early-
stage feasibility studies, scoping studies or R&D, co-financing of development and construction or 
guarantees  for  the  operational  phase.  Generally,  financial  support  programmes  are  available  on 
national and European level and should be as specifically targeted at hybrid projects as possible. The 
target is to increase the awareness for and the usage of existing financial support programmes and 
thereby foster the development of hybrid projects. 

Considering the results of the interaction with the stakeholders, the mitigation of this barrier for the 
CGS  IJmuiden  Ver  to  Norfolk  hybrid  project  must  also  take  into  account  the  interdependencies 
between the individual barriers. 

5.2.14  Uncertainty regarding the UK market 

The barrier "uncertainty regarding the UK market" is divided into two subtopics, UK Capacity Market 
and UK Cap and Floor regime as well as EU internal energy market. The two subtopics are addressed 
individually in the following. 

UK Capacity Market and Cap and Floor regime 

This subtopic of the barrier is relevant for the CGS IJmuiden Ver to Norfolk hybrid project. 

In  summary,  the  interaction  with  stakeholders  shows  that  there  is  no  specific,  tangible  mitigation 
option to address the barrier of uncertainty about the continuance of the UK Capacity Market – which 
has been declared illegal by the General Court of the EU on November 15, 2018 and it is presently 
put  on  hold,  with  next  the  capacity  auction  indefinitely  postponed  –  as  well  as  the  Cap  and  Floor 
regime, particularly in the context of the negotiations regarding the withdrawal of the UK from the EU, 
but rather that a process towards the mitigation of the barrier must be followed. The process consists 
of awaiting the finalisation of the negotiations between the UK and the European Union to allow for 
the clarification of the future of the UK Capacity Market and Cap and Floor regime. 

 
 
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Considering the results of the interaction with the stakeholders, the mitigation process to be followed 
for the CGS IJmuiden Ver to Norfolk hybrid project must also take into account the interdependencies 
between the individual barriers. 

EU internal energy market 

This subtopic of the barrier is relevant for the CGS IJmuiden Ver to Norfolk hybrid project. 

In  summary,  the  interaction  with  stakeholders  shows  that  there  is  no  specific,  tangible  mitigation 
option to address the barrier of uncertainty about the continuance of the participation of the UK in the 
EU internal energy market, particularly in the context of the negotiations regarding the withdrawal of 
the UK from the EU, but rather that a process towards the mitigation of the barrier must be followed. 
The process consists of awaiting the finalisation of the negotiations between the UK and the European 
Union  to  allow  for  the  clarification  of  the  future  of  the  UK's  participation  in  the  EU  internal  energy 
market. 

Considering the results of the interaction with the stakeholders, the mitigation process to be followed 
for the CGS IJmuiden Ver to Norfolk hybrid project must also take into account the interdependencies 
between the individual barriers. 

5.2.15  Disproportionate allocation of costs and benefits across involved 

stakeholders 

This barrier is relevant for the CGS IJmuiden Ver to Norfolk hybrid project. 

In  summary,  the  interaction  with  stakeholders  shows  that  there  is  no  specific,  tangible  mitigation 
option  to  address  the  barrier  of  disproportionate  allocation  of  costs  and  benefits  across  involved 
stakeholders,  but  rather  that  a  process  towards  the  mitigation  of  the  barrier  must  be  followed. 
Generally, the process consists of the identification and alignment of cost and benefit categories, the 
determination of the initial allocation of costs and benefits, the agreement on a re-allocation of costs 
and benefits as well as – if required and available – the usage of CEF funding to ensure the individual 
incentivisation of all stakeholders. This can build on the existing process for Cost Benefit Analyses 
(CBA) and Cross-Border Cost Allocations (CBCA) as defined by ENTSO-E for cross-border electricity 
interconnectors, which needs to be adjusted according to the specifications of each individual hybrid 
project. The process should allow for the incentivisation of all relevant stakeholders to implement the 
hybrid project. 

Considering the results of the interaction with the stakeholders, the mitigation process to be followed 
for the CGS IJmuiden Ver to Norfolk hybrid project must also take into account the interdependencies 
between the individual barriers. 

5.2.16  Uncertainty about legislative regime for power-to-gas and related 

infrastructure  

This barrier is not relevant for the CGS IJmuiden Ver to Norfolk hybrid project. 

In the context of the CGS IJmuiden Ver to Norfolk hybrid project, it is currently not planned to include 
power  conversion  to  gas  and  /  or  gas  transmission  solutions.  Thus,  there  is  no  need  for  and 
consequently no uncertainty regarding the  legislative  regime for power conversion to  gas  and gas 
transmission for the specific hybrid project idea. 

 
 
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5.3  North Sea Wind Power Hub (NSWPH) 

Throughout  stakeholder  interaction,  11  out  of  16  barriers  are  identified  to  be  relevant  for  the 
implementation of the NSWPH hybrid project idea. The results of the interaction with stakeholders 
with regard to all barriers – relevant and not relevant – are summarised in the ensuing subchapters.  

5.3.1  Uncertainty about responsibility for project development 

The barrier "uncertainty about responsibility for project development" is divided into three subtopics, 
grid  connection  responsibility,  responsibility  for  the  development  and  construction  of  the 
interconnector  and  responsibility  for  the  operation  of  the  interconnector.  The  three  subtopics  are 
addressed individually in the following. 

Grid connection responsibility 

This subtopic of the barrier is relevant for the NSWPH hybrid project. 

To address this barrier, three mitigation options are assessed with regard to their applicability (Table 
20) – excluding the implications of interdependencies with other barriers.  

▪  Option 1 "Entity of country in whose EEZ OWF is located is responsible": The respective national 
TSO is responsible for the connection of the OWFs to the hub, depending on the location of the 
OWFs (e.g. the Dutch TSO, TenneT TSO B.V., is responsible for the grid connection of the OWFs 
located in the Dutch EEZ).  

▪  Option 2 "Consortium is responsible": The consortium, consisting of the Dutch TSO, TenneT TSO 
B.V., the German TSO, TenneT TSO GmbH, the Danish TSO, Energinet, Gasunie and the Port 
of Rotterdam, is responsible for the connection of a given OWF to the hub.  

▪  Option 3 "OWF developer is responsible": The OWF developer is responsible for the connection 

of a given OWF to the hub.  

Legal / 
regulatory 
coverage 

Option 1: Entity of 
country in whose EEZ 
OWF is located is 
responsible 

Not fully covered in NL, 
DE and DK legislation and 
regulation (connection to 
offshore structure 
potentially in other EEZ), 
but only amendments 
necessary – EU network 
codes such as 
"Requirements for 
generators" support 
technical standardisation  

Option 2: Consortium is 
responsible 

Option 3: OWF 
developer is responsible 

Not covered in NL, DE 
and DK legislation and 
regulation – EU network 
codes such as 
"Requirements for 
generators" support 
technical standardisation  

Not covered in NL, DE, 
DK and EU legislation and 
regulation (unbundling 
applies for OWF 
developer) – EU network 
codes such as 
"Requirements for 
generators" support 
technical standardisation 

 
 
 
 
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Option 1: Entity of 
country in whose EEZ 
OWF is located is 
responsible 

Option 2: Consortium is 
responsible 

Option 3: OWF 
developer is responsible 

Costs 

Costs are with NL, DE and 
DK, including liability for 
grid connection delay or 
unavailability of grid 

Costs are with consortium, 
including liability for grid 
connection delay or 
unavailability of grid 

Costs are with OWF 
developer, including 
liability for grid connection 
delay or unavailability of 
grid 

Financial risk is with OWF 
developer, therefore risk 
towards project realisation  

Financial risk is with 
TenneT TSO B.V., 
TenneT TSO GmbH and 
Energinet, and thus with 
NL, DE and DK, therefore 
no risk towards project 
realisation 

Financial risk is with 
consortium and thus with 
NL, DE and DK, therefore 
no major risk towards 
project realisation 

Alignment of development 
not needed for single 
developer but across parts 
of the entire cable system 
due to differing 
responsibilities, therefore 
low risk towards project 
realisation 

Alignment of development 
not needed for single 
developer but across parts 
of the entire cable system 
due to differing 
responsibilities, therefore 
low risk towards project 
realisation 

Alignment of development 
not needed for single 
developer but across parts 
of the entire cable system 
due to differing 
responsibilities, therefore 
low risk towards project 
realisation 

Alignment of operations 
not needed for single 
developer but across parts 
of the entire cable system 
due to differing 
responsibilities, therefore 
low risk towards project 
realisation 

Alignment of operations 
not needed for single 
developer but across parts 
of the entire cable system 
due to differing 
responsibilities, therefore 
low risk towards project 
realisation 

Alignment of operations 
not needed for single 
developer but across parts 
of the entire cable system 
due to differing 
responsibilities, therefore 
low risk towards project 
realisation 

Knowledge on general 
and project-specific grid 
connection and 
operational requirements 
given for TenneT TSO 
B.V., TenneT TSO GmbH 
and Energinet in NL, DE 
and DK, respectively 

Knowledge on general 
and project-specific grid 
connection and 
operational requirements 
given for TenneT TSO 
B.V., TenneT TSO GmbH 
and Energinet in NL, DE 
and DK, respectively 

Knowledge on general 
and project-specific grid 
connection and 
operational requirements 
not given for OWF 
developers 

Risk for OWF 
developer 

No financial risk for OWFs 
in case of delays or failure 
in grid connection, as 
compensation is 
guaranteed by regulation 
in NL, DE and DK 

No financial risk for OWFs 
in case of delays or failure 
in grid connection, as 
compensation is 
guaranteed by regulation 
in NL, DE and DK 

Financial risk for OWFs in 
case of delays and failure 
in grid connection, as 
OWF developers are fully 
liable 

Financial risk 

Development 
risk 

Operational 
risk 

Market-specific 
expertise 

 
 
 
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Option 1: Entity of 
country in whose EEZ 
OWF is located is 
responsible 

Option 2: Consortium is 
responsible 

Option 3: OWF 
developer is responsible 

First 
connection 
charges and 
G-charges 

Shallow first connection 
charges and no G-
charges in the NL, shallow 
to super-shallow first 
connection charges and 
no G-charges in DE, 
super-shallow to partially 
shallow first connection 
charges and energy-
based G-charges in DK 

Shallow first connection 
charges and no G-
charges in the NL, shallow 
to super-shallow first 
connection charges and 
no G-charges in DE, 
super-shallow to partially 
shallow first connection 
charges and energy-
based G-charges in DK 

Uncertainty about first 
connection charges and 
G-charges faced by OWF 
developers 

Summary 

Not fully covered under 
NL, DE and DK legal and 
regulatory regime, but with 
low risk towards project 
realisation 

Not covered under NL, DE 
and DK legal and 
regulatory regime, but with 
low risk towards project 
realisation 

Not covered under NL, 
DE, DK and EU legal and 
regulatory regime, but with 
some risk (for OWF 
developers) towards 
project realisation 

Table 20: North Sea Wind Power Hub (NSWPH) – Assessment of options for grid connection responsibility 

In  summary,  the  interaction  with  stakeholders  shows  that  only  two  options  –  to  allocate  the 
responsibility  to  the  entity  of  the  country  in  whose  EEZ  the  OWF  is  located  (Option  1),  to  the 
consortium of the NSWPH hybrid project (Option 2) and to the OWF developers (Option 3)  – have 
advantages  and  disadvantages.  Under  the  current  legal  and  regulatory  framework Option  1  might 
require amendments to the legal and regulatory regime, while Options 2 and 3 are not covered. The 
risk towards project realisation is similar across all mitigation options. Furthermore, the inclusion of 
the relevant TSOs in Options 1 and 2 ensures required market-specific expertise and insures OWF 
developers in case of a delay or a failure of their grid connection.  

Considering the results of the interaction with the stakeholders, the selection and / or implementation 
of the appropriate mitigation option for the NSWPH hybrid project must also take into  account the 
interdependencies between the individual barriers. 

Responsibility for development and construction of interconnector  

This subtopic of the barrier is not relevant for the NSWPH hybrid project. 

Due to the scale and ambition of the NSWPH hybrid project, it is jointly undertaken by a consortium 
consisting of TenneT TSO B.V., TenneT TSO GmbH, Energinet, Gasunie and the Port of Rotterdam. 
Thus, the responsibility to develop and construct the hub as well as the cable systems connecting the 
hub to its onshore connection points in the Netherlands, Germany and Denmark is assumed by the 
consortium members. The responsibility is not further discussed in this study. 

Responsibility for operation of interconnector 

This subtopic of the barrier is not relevant for the NSWPH hybrid project. 

Due to the scale and ambition of the NSWPH hybrid project, it is jointly undertaken by a consortium 
consisting of TenneT TSO B.V., TenneT TSO GmbH, Energinet, Gasunie and the Port of Rotterdam. 

 
 
 
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Thus, the responsibility to operate the hub as well as the cable systems connecting the hub to its 
onshore connection points in the Netherlands, Germany and Denmark is assumed by the consortium 
members. The responsibility is not further discussed in this study. 

5.3.2  Uncertainty about regulation deriving from jurisdiction over cross-border 

cable systems 

This barrier is relevant for the NSWPH hybrid project. 

To address this barrier, two mitigation options are assessed with regard to their applicability (Table 
21)  –  excluding  the  implications  of  interdependencies  with  other  barriers.  The  assessment 
concentrates  on  the  jurisdiction  applicable  to  the  cable  systems  linking  the  NSWPH  to  the  Dutch, 
German and Western Danish market. The jurisdiction over the OWFs and the cable systems linking 
them to the hub as well as the hub itself is determined through the location of these assets. 

▪  Option  1  "Individual  national  jurisdiction's  regulations":  In  addition  to  European  law,  Dutch 
regulation applies to cables linking the NSWPH to the Dutch market, German regulation applies 
to  cables  linking  the  NSWPH  to  the  German  market  and  Danish  regulation  applies  to  cables 
linking  the  NSWPH  to  the  Western  Danish  market.  Each  coastal  state  defines  and  enforces 
applicable regulation regarding the corresponding cables in its maritime zones. 

▪  Option  2  "Alignment  of  jurisdictions'  regulations":  Based  on  negotiations  between  the 
Netherlands,  Germany  and  Denmark,  a  new  combination  of  regulations  applies  to  all  cable 
systems linking the NSWPH to shores – in addition to European law. Coastal states jointly define 
and enforce applicable regulation regarding all cable systems across the Dutch, the German and 
the  Danish  maritime  zones.  The  new  combination  of  regulations  over  the  cable  systems  can 
potentially be based on existing interconnector agreements. 

Option 1: Individual national 
jurisdiction's regulations 

No uncertainty for cables to the NL 
since the NL has jurisdiction and NL 
operational rules apply since cables 
cross NL territorial sea  

No uncertainty for cables to the NL 
since the NL has jurisdiction and NL 
operational rules apply since cables 
cross NL territorial sea and not DE and 
DK territorial sea as well as do not serve 
exploitation of DE and DK EEZ 

No uncertainty for cables to DE since 
DE has jurisdiction and DE operational 
rules apply since cables cross DE 
territorial sea 

Option 2: Alignment of jurisdictions' 
regulations, e.g. based on existing 
interconnector agreements 

Alignment required to combine 
operational rules deriving from 
jurisdictions of the NL, DE and DK for 
the NL territorial sea through 
involvement of the NL, DE and DK 

Alignment required to combine 
operational rules deriving from 
jurisdictions of the NL, DE and DK for 
the NL EEZ through involvement of the 
NL, DE and DK 

Alignment required to combine 
operational rules deriving from 
jurisdictions of the NL, DE and DK for 
DE territorial sea through involvement of 
the NL, DE and DK 

Rights and 
duties in NL 
territorial sea 
during 
operation 

Rights and 
duties in NL 
EEZ during 
operation 

Rights and 
duties in DE 
territorial sea 
during 
operation 

 
 
 
 
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Rights and 
duties in DE 
EEZ during 
operation 

Rights and 
duties in DK 
territorial sea 
during 
operation 

Rights and 
duties in DK 
EEZ during 
operation 

Option 1: Individual national 
jurisdiction's regulations 

No uncertainty for cables to the DE 
since DE has jurisdiction and DE 
operational rules apply since cables 
cross DE territorial sea and not the NL 
and DK territorial sea as well as do not 
serve exploitation of the NL and DK 
EEZ 

No uncertainty for cables to DK since 
DK has jurisdiction and DK operational 
rules apply since cables cross DK 
territorial sea 

No uncertainty for cables to DK since 
the DK has jurisdiction and DK 
operational rules apply since cables 
cross DK territorial sea and not the NL 
and DE territorial sea as well as do not 
serve exploitation of the NL and DE 
EEZ 

Option 2: Alignment of jurisdictions' 
regulations, e.g. based on existing 
interconnector agreements 

Alignment required to combine 
operational rules deriving from 
jurisdictions of the NL, DE and DK for 
DE EEZ through involvement of the NL, 
DE and DK 

Alignment required to combine 
operational rules deriving from 
jurisdictions of the NL, DE and DK for 
DK territorial sea through involvement of 
the NL, DE and DK 

Alignment required to combine 
operational rules deriving from 
jurisdictions of the NL, DE and DK for 
DK EEZ through involvement of the NL, 
DE and DK 

Hybrid project 
requirements 

Alignment of operational rules between 
the NL, DE and DK required because of 
connection of the respective countries' 
cable systems to the hub 

No additional alignment of operational 
rules required 

Timeline 

Others 

Summary 

Alignment may extend timeline of 
project 

Alignment may extend timeline of 
project 

Alignment of operational rules required 
to allow for a combination of assets in 
hybrid project  

Provisions for assigning liability in case 
of grid connection failure need to be 
implemented 

Alignment required to ensure 
applicability of Option 2 since no clear 
rules apply in all relevant maritime 
zones 

Table 21: North Sea Wind Power Hub (NSWPH) – Assessment of options for regulation deriving from 
jurisdiction deriving from cross-border cable systems 

In summary, the interaction with stakeholders shows that both options – the agreement on applying 
operational  rules  to  the  cable  systems  linking  the  NSWPH  to  shore  based  on  individual  national 
jurisdiction (national regulation applies to the cables linking the NSWPH to the respective national 
markets) (Option 1) as well as the alignment of rules deriving from the Dutch, German and Danish 
jurisdiction  (Option  2)  –  have  advantages  and  disadvantages.  While  the  feasibility  of  applying 
individual  national  regulations  to  the  cable  systems  is  potentially  impeded  by  the  necessity  of 
connecting all cable systems to the same hub, the alignment of rules deriving from three jurisdictions 

 
 
 
 
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can be a lengthy process. Yet, Option 2 reflects the interests of all involved countries in the alignment 
and can potentially be based on existing agreements established for interconnectors. 

Considering the results of the interaction with the stakeholders, the selection and / or implementation 
of the appropriate mitigation option for the NSWPH hybrid project must also take into  account the 
interdependencies between the individual barriers. 

5.3.3  Uncertainty about market arrangements 

This barrier is relevant for the NSWPH hybrid project. 

To address this barrier, four mitigation options are assessed with regard to their applicability (Table 
22) – excluding the implications of interdependencies with other barriers. 

▪  Option 1 "Commercial flows to home market": With commercial flows of the OWFs to their home 
markets, the OWFs commercially transmit only to the market of the country in whose EEZ they 
are physically located.  

▪  Option 2 "Dynamic flows to high-price market": With commercial flows to the dynamic high-price 
market, the OWFs always commercially transmit their electricity to the market of the Netherlands, 
Germany and Denmark that has the highest price.  

▪  Option 3 "Dynamic flows to low-price market": With commercial flows to the dynamic low-price 
market, the OWFs always commercially transmit their electricity to the market of the Netherlands, 
Germany and Denmark that has the lowest price.  

▪  Option  4  "Dedicated  bidding  zone":  With  a  dedicated  bidding  zone,  the  OWFs  always 
commercially feed their electricity into a dedicated bidding zone, newly established for the OWFs 
included in the NSWPH hybrid project.  

Option 1: 
Commercial flows 
to home market 

Option 2: 
Dynamic flows to 
high-price market 

Option 3: 
Dynamic flows to 
low-price market 

Option 4: 
Dedicated bidding 
zone 

Legal / 
regulatory 
coverage 

Covered under 
existing market 
regulation  

Not covered under 
existing market 
regulation, 
particularly in 
violation of CACM 
requirement of 
stability of bidding 
zones across 
market time frames 

Not covered under 
existing market 
regulation, 
particularly in 
violation of CACM 
requirement of 
stability of bidding 
zones across 
market time frames 

Covered under 
existing market 
regulation as new 
bidding zone can 
be treated as home 
market after 
bidding zone 
review process 

 
 
 
 
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Option 1: 
Commercial flows 
to home market 

Option 2: 
Dynamic flows to 
high-price market 

Option 3: 
Dynamic flows to 
low-price market 

Option 4: 
Dedicated bidding 
zone 

Price 
determination 

Home market price 
applies  

Dedicated bidding 
zone price applies  

Price determination 
problematic when 
transmission of 
generated 
electricity to high-
price market not 
possible (limited 
capacity) – 
alternative price 
determination 
needed 

Price determination 
problematic when 
transmission of 
generated 
electricity to low-
price market not 
possible (limited 
capacity) – 
alternative price 
determination 
needed 

Price effects 

Effect of 
decreasing prices 
in home market, as 
OWFs produce at 
close to zero 
marginal costs – 
indirect price 
effects through 
available IC 
capacity 

Effect of 
decreasing prices 
in the high-price 
market, as OWFs 
produce at close to 
zero marginal costs 
– indirect price 
effects through 
available IC 
capacity 

Effect of 
decreasing prices 
in the low-price 
market, as OWFs 
produce at close to 
zero marginal costs 
– indirect price 
effects through 
available IC 
capacity 

Price 
discrimination 
of OWFs 

Not discriminatory 
against any OWF 
as hybrid OWFs 
and other OWFs in 
the NL, DE or DK 
bidding zones 
receive same 
prices 

Discriminatory 
against any other 
OWF in the NL, DE 
or DK bidding 
zones, as hybrid 
OWFs always 
receive high price 
of NL, DE or DK 
market 

Discriminatory 
against hybrid 
OWFs as they 
always receive low 
price of NL, DE or 
DK market  

Conflict 
between 
transmission 
from OWFs to 
shores and IC 
functionality 

Conflict since 
commercial IC 
flows and 
commercial OWF 
flows are in same 
direction at times 

Conflict since 
commercial IC 
flows and 
commercial OWF 
flows are always in 
same direction 

No conflict, since 
commercial IC 
flows and 
commercial OWF 
flows are always in 
opposite direction 

Effect of 
decreasing prices 
in the dedicated 
bidding zone, as 
OWFs produce at 
close to zero 
marginal costs – 
indirect price 
effects through 
available IC 
capacity 

Not discriminatory 
against any OWF 
as hybrid OWFs 
and OWFs in the 
NL, DE or DK 
bidding zones 
receive price of 
their bidding zone 

No conflict, since 
commercial IC 
flows are between 
bidding zones only 
and commercial 
OWF flows are to 
dedicated bidding 
zone only 

 
 
 
 
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Option 1: 
Commercial flows 
to home market 

Option 2: 
Dynamic flows to 
high-price market 

Option 3: 
Dynamic flows to 
low-price market 

Option 4: 
Dedicated bidding 
zone 

Compensation  Negative business 

Outages 

Summary 

case implications 
for hybrid OWFs or 
ICs from conflict for 
cable system 
capacity, and thus 
additional 
compensation 
necessary 

In case of outages 
of single cable 
systems, 
transmission of 
electricity only 
possible via other 
cable systems to 
home market 

Negative business 
case implications 
for hybrid OWFs or 
ICs from conflict for 
cable system 
capacity, and thus 
additional 
compensation 
necessary 

Negative business 
case implications 
for hybrid OWFs 
from price 
discrimination, and 
thus additional 
compensation 
necessary 

No business case 
implications for 
hybrid OWFs or 
ICs, and thus no 
additional 
compensation 
necessary 

In case of outages 
of single cable 
systems, 
transmission of 
electricity via all 
unaffected cable 
systems possible 
(also to other 
markets)  

In case of outages 
of single cable 
systems, 
transmission of 
electricity via all 
unaffected cable 
systems possible 
(also to other 
markets)  

In case of outages 
of single cable 
systems, 
transmission of 
electricity via all 
unaffected cable 
systems possible 
(also to other 
markets)  

Legal and 
regulatory 
coverage given, not 
discriminatory 
against any OWF 
but negative 
business case 
implications for 
OWFs or ICs from 
conflict for cable 
system capacity  

Legal and 
regulatory 
coverage not given, 
discriminatory 
against other 
OWFs and 
negative business 
case implications 
for OWFs or ICs 
from conflict for 
cable system 
capacity 

Legal and 
regulatory 
coverage not 
given, 
discriminatory 
against hybrid 
OWFs and 
negative business 
case implications 
for OWFs from 
price discrimination 

Legal and 
regulatory 
coverage given, 
not discriminatory 
against any OWF 
and no negative 
business case 
implications for 
OWFs or ICs 

Table 22: North Sea Wind Power Hub (NSWPH) – Assessment of options for market arrangement 

In  summary,  the  interaction  with  stakeholders  shows  that  all  four  options  –  OWFs  always 
commercially evacuating electricity to the bidding zone of their respective home market (Option 1), 
OWFs  commercially  evacuating  electricity  to  the  higher-price  or  lower-price  market  of  the 
Netherlands, Germany and Denmark (Option 2 and 3) as well as establishing a dedicated bidding 
zone  for  the  OWFs  included  in  the  NSWPH  hybrid  project  (Option  4)  –  have  advantages  and 
disadvantages.  While  Option  2  and  3  violate  the  European  CACM  regulation,  commercially 
evacuating electricity to the OWFs' home markets is covered under existing market regulation (Option 
1).  Legal  and  regulatory  coverage  for  a  dedicated  bidding  zone  is  given  (Option  4),  however,  the 
necessity and extent of a bidding zone review process needs to be clarified. Furthermore, depending 
on the chosen mitigation option, negative business case implications for hybrid OWFs or ICs require 
additional compensation from the conflict for cable system capacity (Options 1 and 2) or from price 
discrimination for hybrid OWFs (Option 3). 

 
 
 
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Considering the results of the interaction with the stakeholders, the selection and / or implementation 
of the appropriate mitigation option for the NSWPH hybrid project must also take into  account the 
interdependencies between the individual barriers. 

5.3.4  Uncertainty about hybrid cable system classification 

This barrier is relevant for the NSWPH hybrid project. 

To address this barrier, three mitigation options are assessed with regard to their applicability (Table 
23)  –  excluding  the  implications  of  interdependencies  with  other  barriers.  The  assessment 
concentrates on the cable systems linking the NSWPH to the Dutch, German and Western Danish 
market. The cables linking the OWFs to the hub have no dual functionality. 

▪  Option 1 "Export system with interconnector functionality": Cable systems linking the NSWPH to 
shore are hybrid cable systems which allow for the transmission of electricity from the hub to the 
Dutch, German and Western Danish markets with priority. Hence, the Dutch, German and Danish 
export cable systems only provide interconnector functionality between the Dutch, German and 
Western Danish bidding zone for leftover capacities. 

▪  Option 2 "Interconnector with export system functionality": Cable systems linking the NSWPH to 
shore are hybrid cable systems which allow for the transmission of electricity from the hub to the 
Dutch,  German  and  Western  Danish  markets  only  with  leftover  capacities.  Hence,  the  Dutch, 
German and Danish export cable systems primarily provide interconnector functionality between 
the Dutch, German and Western Danish bidding zone. 

▪  Option 3 "Interconnector (with dedicated bidding zone)": Cable systems linking the NSWPH to 
shore are interconnectors and do not allow for the transmission of OWF-generated electricity to 
shores.  This  option  is  included  for  compatibility  with  the  market  arrangement  of  a  dedicated 
bidding zone, where OWFs only feed electricity to the dedicated bidding zone and interconnectors 
link the dedicated bidding zone to other markets. 

Option 1: Export system 
with IC functionality 

Option 2: IC with export 
system functionality  

Option 3: Interconnector 
(with dedicated bidding 
zone) 

NL national 
legal / 
regulatory 
coverage 

Potentially covered as NL 
regulation does not 
expressly prohibit dual 
functionality of cables but 
legal / regulatory feasibility 
to be validated 

Potentially covered as NL 
regulation does not 
expressly prohibit dual 
functionality of cables but 
legal / regulatory feasibility 
to be validated 

Covered under NL 
regulation as regular 
interconnector, but legal 
coverage of connection 
involving new bidding 
zone to be validated  

 
 
 
 
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DE national 
legal / 
regulatory 
coverage 

DK national 
legal / 
regulatory 
coverage 

EU legal / 
regulatory 
coverage 

Potential for 
curtailment of 
OWF 

Option 3: Interconnector 
(with dedicated bidding 
zone) 

Covered under DE 
regulation as regular 
interconnector, but legal 
coverage of connection 
involving new bidding 
zone to be validated 

Option 1: Export system 
with IC functionality 

Option 2: IC with export 
system functionality  

Not covered as DE 
regulation does not allow 
for dual functionality since 
cable systems linking two 
bidding zones are defined 
as ICs and must solely 
have that purpose and 
export cables are defined 
as connections between 
technical installations 
solely for the uptake, 
transmission and 
distribution of electrical 
energy for general supply 

Not covered as DE 
regulation does not allow 
for dual functionality since 
cable systems linking two 
bidding zones are defined 
as ICs and must solely 
have that purpose and 
export cables are defined 
as connections between 
technical installations 
solely for the uptake, 
transmission and 
distribution of electrical 
energy for general supply 

Potentially covered but 
needs to be validated 
since both export cables 
and ICs a part of the same 
regulatory regime and 
subject to approval by the 
ministry 

Potentially covered but 
needs to be validated 
since both export cables 
and ICs a part of the same 
regulatory regime and 
subject to approval by the 
ministry 

Covered under DK 
regulation as regular 
interconnector, but legal 
coverage of connection 
involving new bidding 
zone to be validated 

Not covered under 
Electricity Directive 
because it does not 
include an add. definition 
for hybrid cable systems; 
EU Regulation 714/2009 
prescribes that "maximum 
capacity of the 
interconnections […] shall 
be made available to 
market participants" with 
clarity needed whether 
"maximum" refers to 
nominal or leftover 
capacities of cable 
systems in hybrid projects 

Not covered under 
Electricity Directive 
because it does not 
include an add. definition 
for hybrid cable systems; 
EU Regulation 714/2009 
prescribes that "maximum 
capacity of the 
interconnections […] shall 
be made available to 
market participants" with 
clarity needed whether 
"maximum" refers to 
nominal or leftover 
capacities of cable 
systems in hybrid projects 

OWFs can transmit 
electricity at full 
generation capacity, and 
thus no business case 
implications and 
minimised curtailment 

OWFs can transmit 
electricity depending on 
leftover capacity of cable 
systems, and thus 
negative business case 
implications due to 
additional curtailment 

Covered under Electricity 
Directive because cable 
functions as regular 
interconnector such that 
maximum capacity is 
made available to market 
participants 

No business case 
implications 

 
 
 
 
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Option 1: Export system 
with IC functionality 

Option 2: IC with export 
system functionality  

Option 3: Interconnector 
(with dedicated bidding 
zone) 

Potential for 
congestion  

of IC 

Capacity available for 
trade is significantly 
reduced, and thus 
negative business case 
implications for IC 
functionality of the entire 
cable system 

Compensation  Due to joint development 
of transmission assets in 
hybrid project, 
optimisation of business 
case of cable system as a 
whole given; potentially no 
additional compensation 
necessary 

Third party 
access 

Third party access only 
given for leftover 
capacities after 
transmission of electricity 
from OWFs to shores 

Full capacity is available 
for trade, and thus no 
business case 
implications for IC 
functionality of the entire 
cable system 

Full capacity is available 
for trade, and thus no 
business case 
implications for IC 
functionality of the entire 
cable system 

Due to foregone revenues 
from additional 
curtailment, additional 
compensation for OWFs 
required 

No additional 
compensation required 

Third party access given 

Third party access given 

Impact on 
EU's energy 
policy targets 

Priority on primary targets 
of diversification and 
integration of RES as well 
as on GHG emission 
reductions over secondary 
target of maximised IC 
capacity 

Priority on secondary 
target of maximised IC 
capacity over primary 
targets of diversification 
and integration of RES as 
well as on GHG emission 
reductions  

Primary targets of 
diversification and 
integration of RES as well 
as on GHG emission 
reductions and secondary 
target of maximised IC 
capacity are prioritised 

Summary 

Not covered under 
existing EU and DE 
regulation, but potentially 
covered under NL and DK 
regulation; potential for 
negative business case 
implications for ICs may 
necessitate additional 
compensation 

Not covered under 
existing EU and DE 
regulation, but potentially 
covered under NL and DK 
regulation; negative 
business case 
implications for OWFs 
necessitate additional 
compensation 

Covered under existing 
EU as well NL, DE and 
DK regulations with 
validation for connection 
to dedicated bidding zone 
needed and no business 
case implications 

Table 23: North Sea Wind Power Hub (NSWPH) – Assessment of options for hybrid cable system classification  

In  summary,  the  interaction  with  stakeholders  shows  that  all  three  options  –  an  export  cable  with 
interconnector functionality (Option 1), an interconnector with export cable functionality (Option 2) as 
well  as  an  interconnector  (with  dedicated  bidding  zone)  (Option  3)  –  have  advantages  and 
disadvantages. Both, Option 1 and 2 require changes in the European and potentially in the national 
legal and regulatory frameworks. By contrast, Option 3 is based on the existing legal and regulatory 

 
 
 
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framework  for  interconnectors  and  therefore  does  not  require  changes  to  European  and  national 
regulation if the connection of an interconnector to a new bidding zone is covered. However, Option 
2 has unfavourable implications for the business case of the OWF developers since the developers 
have no priority access to transmission capacity. Contrary, in Option 1, the interconnectors have no 
priority  access  to  the  capacity  of  the  cable  system  resulting  in  unfavourable  implications  for  the 
business case of the interconnector. In Option 3, the OWFs feed electricity to the new bidding zone 
and the interconnectors link the new bidding zone to other markets, and thus there are no business 
case implications for the OWFs and interconnectors. Furthermore, in contrast to Option 1, Option 2 
prioritises the secondary  EU energy  policy  target  of  maximised electricity  interconnection capacity 
over the primary targets of diversification and integration of RES as well as greenhouse gas emission 
reduction, while Option 3 prioritises both targets.  

Considering the results of the interaction with the stakeholders, the selection and / or implementation 
of the appropriate mitigation option for the NSWPH hybrid project must also take into  account the 
interdependencies between the individual barriers. 

5.3.5 

Failure of developers to align planning across assets and countries 

The barrier "failure of developers to align planning across assets and countries" is divided into three 
subtopics, geographical alignment, technical alignment and timing alignment. The three subtopics are 
addressed individually in the following. 

Geographical alignment 

This subtopic of the barrier is relevant for the NSWPH hybrid project. 

In  summary,  the  interaction  with  stakeholders  shows  that  there  is  no  specific,  tangible  mitigation 
option to address the barrier of failed geographical alignment across assets and countries, but rather 
that a process towards the mitigation of the barrier must be followed. The process consists of the 
continuous  exchange  between  project  developers  and  other  stakeholders  to  allow  for  the 
achievement of early-stage, geographical alignment. 

Considering the results of the interaction with the stakeholders, the mitigation process to be followed 
for  the  NSWPH  hybrid  project  must  also  take  into  account  the  interdependencies  between  the 
individual barriers. 

Technical alignment 

This subtopic of the barrier is relevant for the NSWPH hybrid project. 

In  summary,  the  interaction  with  stakeholders  shows  that  there  is  no  specific,  tangible  mitigation 
option to address the barrier of failed technical alignment across assets and countries, but rather that 
a  process  towards  the  mitigation  of  the  barrier  must  be  followed.  The  process  consists  of  the 
continuous  exchange  between  project  developers  and  other  stakeholders  to  allow  for  the 
achievement of early-stage, technical alignment. 

Considering the results of the interaction with the stakeholders, the selection and / or implementation 
of the appropriate mitigation option for the NSWPH hybrid project must also take into  account the 
interdependencies between the individual barriers. 

Timing alignment  

This subtopic of the barrier is not relevant for the NSWPH hybrid project. 

In the context of the NSWPH hybrid project, a separate commissioning of the individual OWFs located 
in the Dutch, German or Danish EEZ and their export cable systems or a later commissioning of some 

 
 
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of the OWFs and export cable systems compared to the hub and the cable systems linking the hub 
to  the  Dutch,  German  and  Western  Danish  bidding  zone  is  possible.  The  hub  can  independently 
provide interconnector capacity between the Netherlands, Germany and Denmark. 

5.3.6  Uncertainty about responsibility and rules to provide access to maritime 

space for OWFs (location selection, site pre-investigation and tender 
execution) 

The barrier "uncertainty about responsibility and rules to provide access to maritime space for OWFs 
(location selection, site pre-investigation and tender execution)" is divided into two subtopics, location 
selection and site  pre-investigation as  well as tender  execution. The two subtopics are addressed 
individually in the following. 

Location selection and site pre-investigation 

This subtopic of the barrier is not relevant for the NSWPH hybrid project. 

In the context of the NSWPH hybrid project, there is no uncertainty concerning location selection and 
site  pre-investigation  responsibility  and  procedures  since  the  respective  national  authorities  are 
responsible and the respective national procedures are applicable for the OWFs in the Dutch EEZ, 
German  EEZ  and  Danish  EEZ.  However,  the  national  location  selection  and  site  pre-investigation 
responsibility and procedures must be in alignment with the location of the NSWPH  to allow for an 
efficient inclusion of OWFs in the hybrid project. 

Tender responsible party 

This subtopic of the barrier is not relevant for the NSWPH hybrid project. 

In the context of the NSWPH hybrid project, there is no uncertainty concerning determination of the 
tender responsible party since the respective party of the national tender procedure is responsible for 
the tenders of the OWFs in the Dutch EEZ, German EEZ and Danish EEZ.  

5.3.7  Uncertainty about responsibility and rules to provide access to maritime 

space for OWFs (tender design) 

This barrier is relevant for the NSWPH hybrid project. 

To address this barrier, four mitigation options are assessed with regard to their applicability (Table 
24) – excluding the implications of interdependencies with other barriers. 

▪  Option  1  "Strict  design  with  aligned  requirements  and  without  hybrid-specific  uncertainties":  A 
tender  design  with  strict  pre-qualification  requirements  implies  that  extensive  pre-qualification 
requirements  are  defined  to  ensure  hybrid-specific  and  general  capabilities  to  develop  the 
NSWPH  hybrid  project.  The  requirements  are  aligned  among  the  Netherlands,  Germany  and 
Denmark, including a jointly agreed set of financial requirements and a certain set of both Dutch, 
German and Danish rules related to the OWF sites (e.g. environmental details) and a certain set 
of both Dutch, German and Danish rules related to the grid connection of the OWFs (e.g. technical 
and  operational  details  such  as  system  integration  or  frequency  control).  Furthermore,  all 
uncertainties arising from the hybrid character of the OWF development are clarified prior to the 
tender. 

▪  Option 2  "Strict design  with aligned requirements":  A tender design  with strict  pre-qualification 
requirements implies that extensive pre-qualification requirements are defined to ensure hybrid-
specific  and  general  capabilities  to  develop  the  NSWPH  hybrid  project.  The  requirements  are 
aligned among the Netherlands, Germany and Denmark, including a jointly agreed set of financial 

 
 
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requirements and a certain set of both Dutch, German and Danish rules related to the OWF sites 
(e.g. environmental details) and a certain set of both Dutch, German and Danish rules related to 
the grid connection of the OWFs (e.g. technical and operational details such as system integration 
or frequency control).  

▪  Option  3:  "Strict  design  without  hybrid-specific  uncertainties":  A  tender  design  with  strict  pre-
qualification  requirements  implies  that  extensive  pre-qualification  requirements  are  defined  to 
ensure  hybrid-specific  and  general  capabilities  to  develop  the  NSWPH  hybrid  project. 
Furthermore,  all  uncertainties  arising  from  the  hybrid  character  of  the  OWF  development  are 
clarified prior to the tender. 

▪  Option 4 "Lenient design with aligned requirements and without hybrid-specific uncertainties": A 
tender design with lenient pre-qualification requirements is chosen, implying that only limited pre-
qualification requirements are defined to ensure competition and low prices. The requirements 
are  aligned  among  the  Netherlands,  Germany  and  Denmark,  including  a  jointly  agreed  set  of 
financial requirements and a certain set of both Dutch, German and Danish rules related to the 
OWF sites (e.g. environmental details) and a certain set of both Dutch, German and Danish rules 
related to the grid connection of the OWFs (e.g. technical and operational details such as system 
integration or frequency control). Furthermore, all uncertainties arising from the hybrid character 
of the OWF development are clarified prior to the tender. 

Legal / 
regulatory 
coverage 

Alignment of 
requirements 

Option 1: Strict 
design, aligned 
requirements and 
no uncertainties 

Option 2: Strict 
design and 
aligned 
requirements  

Not covered and 
potential 
amendments to 
national legislation 
and regulation 
necessary since 
multiple countries 
are involved in 
defining tender 
design 

Not covered and 
potential 
amendments to 
national legislation 
and regulation 
necessary since 
multiple countries 
are involved in 
defining tender 
design 

Financial, technical 
and operational 
requirements 
aligned; 
environmental 
requirements 
defined by the 
country in whose 
EEZ the OWF is 
located 

Financial, technical 
and operational 
requirements 
aligned; 
environmental 
requirements 
defined by the 
country in whose 
EEZ the OWF is 
located 

Option 3: Strict 
design and no 
uncertainties 

Covered and no 
amendments to 
national legislation 
and regulation 
necessary since 
only one country is 
involved in defining 
tender design 

No alignment of 
requirements 

Option 4: Lenient 
design, aligned 
requirements and 
no uncertainties 

Not covered and 
potential 
amendments to 
national legislation 
and regulation 
necessary since 
multiple countries 
are involved in 
defining tender 
design 

Financial, technical 
and operational 
requirements 
aligned; 
environmental 
requirements 
defined by the 
country in whose 
EEZ the OWF is 
located 

 
 
 
 
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Hybrid-
specific un-
certainties 

Realisation 
probability 

Option 1: Strict 
design, aligned 
requirements and 
no uncertainties 

Option 2: Strict 
design and 
aligned 
requirements  

Option 3: Strict 
design and no 
uncertainties 

Option 4: Lenient 
design, aligned 
requirements and 
no uncertainties 

All uncertainties 
arising from hybrid-
specific setup are 
clarified, e.g. 
liability, applicable 
jurisdiction, grid 
connection 
responsibility, RES 
subsidy scheme 

Uncertainties 
arising from hybrid 
character of 
development not 
entirely clarified 
such that 
uncertainty remains 
for OWF developer 

All uncertainties 
arising from hybrid-
specific setup are 
clarified, e.g. 
liability, applicable 
jurisdiction, grid 
connection 
responsibility, RES 
subsidy scheme 

All uncertainties 
arising from hybrid-
specific setup are 
clarified, e.g. 
liability, applicable 
jurisdiction, grid 
connection 
responsibility, RES 
subsidy scheme 

Applying OWF 
developers are 
aware of all 
specifications and 
requirements and 
can align planning 
and financing right 
from the beginning 

Applying OWF 
developers are 
aware of all 
specifications and 
requirements and 
can align planning 
and financing right 
from the beginning  

Applying OWF 
developers are not 
aware of most 
specifications and 
requirements, 
which might result 
in significant cost 
overruns / delays 
after the tender 
process 

Applying OWF 
developers are 
aware of all 
specifications and 
requirements and 
can align planning 
and financing right 
from the beginning; 
however, it is 
questionable 
whether OWFs 
connected to 
multiple countries 
can be tendered 
without alignment 
of tender 
requirements 

Cost efficiency  Due to strict 

requirements and 
specifications, less 
developers 
expected to apply – 
cost efficiency of 
offers expected to 
decrease with 
fewer applicants 

Due to strict 
requirements and 
specifications, less 
developers 
expected to apply – 
cost efficiency of 
offers expected to 
decrease with 
fewer applicants 

Due to strict 
requirements and 
specifications, less 
developers 
expected to apply – 
cost efficiency of 
offers expected to 
decrease with 
fewer applicants 

Due to lenient 
requirements and 
specifications, 
many developers 
expected to apply – 
cost efficiency of 
offers expected to 
increase with more 
applicants 

 
 
 
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Summary 

Option 1: Strict 
design, aligned 
requirements and 
no uncertainties 

Option 2: Strict 
design and 
aligned 
requirements  

Legal and 
regulatory 
coverage to be 
assessed and 
potentially 
decreases cost 
efficiency 

Legal and 
regulatory 
coverage to be 
assessed and 
decreases cost 
efficiency, 
particularly due to 
remaining hybrid 
uncertainties 

Option 4: Lenient 
design, aligned 
requirements and 
no uncertainties 

Legal and 
regulatory 
coverage to be 
assessed and 
strongly decreases 
probability of 
project realisation  

Option 3: Strict 
design and no 
uncertainties 

Legal and 
regulatory 
coverage given, but 
with limited chance 
of realisation due to 
non-consideration 
of two countries' 
interest in defining 
tender 
requirements 

Table 24: North Sea Wind Power Hub (NSWPH) – Assessment for options of tender design 

In summary, the interaction with stakeholders shows that all four options – a strict or lenient tender 
design  with  aligned  requirements  and  certainty  about  hybrid-specific  characteristics  of  the  OWF 
development (Option 1 and 4), a strict tender design with aligned requirements (Option 3) as well as 
a  strict  tender  design  with  certainty  about  hybrid-specific  characteristics  of  the  OWF  development 
(Option  2)  –  have  advantages  and  disadvantages.  While  a  tender  design  with  strict  requirements 
(Options 1, 2 and 3) increases the probability of successful project implementation, a tender design 
with  lenient  requirements  (Option  4)  decreases  the  cost  of  implementation  through  competition. 
Furthermore, certainty about hybrid-specific characteristics of the OWF development (Options 1, 3 
and  4)  increases  the  probability  of  successful  project  implementation  and  decreases  the  cost  of 
implementation by reducing the risk premium otherwise demanded by OWF developers in terms of 
subsidies. Lastly, aligned requirements (Options 1, 2 and 4) aid in ensuring the interoperability of the 
OWFs with the other assets of the hybrid project and thereby increase the probability of successful 
hybrid project implementation. 

Considering the results of the interaction with the stakeholders, the selection and / or implementation 
of the appropriate mitigation option for the NSWPH hybrid project must also take into  account the 
interdependencies between the individual barriers. 

5.3.8  Discrepancies in responsibilities and requirements for balancing 

In the context of the NSWPH hybrid project, there is no discrepancy in the applicability of national 
balancing responsibility and requirements in the shorter term. Since each generator must always be 
part of only one bidding zone according to the existing CACM regulation and since the participation 
of  one  generator  in  different  bidding  zones  at  different  times  would  be  highly  challenging  for  the 
operation of the entire energy system, an OWF physically connected to multiple bidding zones can 
only commercially feed its electricity into one bidding zone. Furthermore, the topic is addressed in the 
Clean Energy Package. It is likely that no further barrier mitigation regarding balancing responsibilities 
and requirements is needed for the implementation of the NSWPH hybrid project.  However, in the 
longer term the translation into Dutch, German and Danish law needs to be assessed in detail by the 
project-specific stakeholders. 

 
 
 
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5.3.9  Discrepancies in priority dispatch regulation  

In the context of the NSWPH hybrid project, there is no discrepancy in the applicability of national 
priority dispatch regulation in the shorter term. Since each generator must always be part of only one 
bidding zone according to the existing CACM regulation and since the participation of one generator 
in different bidding zones at different times would be highly challenging for the operation of the entire 
energy system, an OWF physically connected to multiple bidding zones can only commercially feed 
its electricity into one bidding zone. Furthermore, the topic is addressed in the Clean Energy Package. 
It  is  likely  that  no  further  barrier  mitigation  regarding  priority  dispatch  regulation  is  needed  for  the 
implementation of the NSWPH hybrid project. However, in the longer term the translation into Dutch, 
German and Danish law needs to be assessed in detail by the project-specific stakeholders. 

5.3.10  Discrepancies in curtailment regulation and compensation 

In  the  context  of  NSWPH  hybrid  project,  there  is  no  discrepancy  in  the  applicability  of  national 
curtailment regulation and compensation in the shorter term. Since each generator must always be 
part of only one bidding zone according to the existing CACM regulation and since the participation 
of  one  generator  in  different  bidding  zones  at  different  times  would  be  highly  challenging  for  the 
operation of the entire energy system, an OWF physically connected to multiple bidding zones can 
only commercially feed its electricity into one bidding zone. Furthermore, the topic is addressed in the 
Clean Energy Package. It is likely that no further barrier mitigation regarding curtailment regulation 
and compensation is needed for the implementation of the NSWPH hybrid project. However, in the 
longer term the translation into Dutch, German and Danish law needs to be assessed in detail by the 
project-specific stakeholders. 

5.3.11  Lack of regulated revenues for anticipatory investments 

This barrier is relevant for the NSWPH hybrid project. 

To address this barrier, three mitigation options are assessed with regard to their applicability (Table 
25) – excluding the implications of interdependencies with other barriers. 

▪  Case 1: Anticipatory investments under Dutch regulation are possible. Anticipatory investments 
for export cable systems, interconnectors and the hub are necessary due to the timeline of the 
specific hybrid project. In the case of unaligned development, the hub is expected to be developed 
first  with  the  connections  of  the  OWFs  to  the  NSWPH  following  after  the  commissioning. 
Therefore, the additions in the technical design of the hub must be taken into account. Export 
cable systems, interconnectors and the hub are developed by, among others, the national TSO, 
TenneT TSO B.V. 

▪  Case 2: Anticipatory investments under German regulation are possible. Anticipatory investments 
for export cable systems, interconnectors and the hub are necessary due to the timeline of the 
specific hybrid project. In the case of unaligned development, the hub is expected to be developed 
first  with  the  connections  of  the  OWFs  to  the  NSWPH  following  after  the  commissioning. 
Therefore, the additions in the technical design of the hub  must be taken into account. Export 
cable systems, interconnectors and the hub are developed by, among others, the national TSO, 
i.e. TenneT TSO GmbH. 

▪  Case  3:  Anticipatory  investments  under  Danish  regulation  are  not  foreseen.  Anticipatory 
investments  for  export  cable  systems,  interconnectors  and  the  hub  are  necessary  due  to  the 
timeline of the specific hybrid project. In the case of unaligned development, the hub is expected 
to  be  developed  first  with  the  connections  of  the  OWFs  to  the  NSWPH  following  after  the 
commissioning. Therefore,  the additions in the technical design of the  hub must be taken into 

 
 
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  North Seas Offshore Energy Clusters study 

account. Export cable systems, interconnectors and the hub are developed by, among others, 
the national TSO, Energinet. 

Dutch regulation 

German regulation 

Danish regulation 

Concerned asset: 
Export cable systems, 
interconnectors and hub 

Concerned asset: 
Export cable systems, 
interconnectors and hub 

Concerned asset: 
Export cable systems, 
interconnectors and hub 

Legal / 
regulatory 
coverage 

Anticipatory investments 
for cables and installations 
are considered under 
Dutch regulation 

Anticipatory investments 
for cables and installations 
are considered under 
German regulation 

Anticipatory investments 
for cables and installations 
are not considered under 
Danish regulation 

Treatment of 
anticipatory 
investments 

Efficiency 
benchmark 

Anticipatory investments 
are treated exactly the 
same as non-anticipatory 
investments, but must be 
included in Offshore Grid 
Development Framework 
by the Dutch government 

Anticipatory investments 
are subject to approval by 
the regulatory authority 
(BNetzA) and thus must 
be included in the Spatial 
Grid Development Plan 
and Maritime Spatial Plan 

Efficiency benchmark 
exists but regulatory 
regime provides for 
standard procedures to 
assess appropriate 
investments  

Efficiency benchmark 
exists but regulatory 
regime provides for 
standard procedures to 
assess appropriate 
investments 

No provisions for 
anticipatory investments 

No provisions for 
anticipatory investments 

Public opinion  Public support given if 

investment is in line with 
Offshore Grid 
Development Framework 

Public support given if 
investment is in line with 
Spatial Grid Development 
Plan and Maritime Spatial 
Plan 

Public support depends 
on the introduction of 
adequate legal / 
regulatory provisions 

Risk to project 
realisation 

No risk since TSO can 
cover investments in its 
RAB and Offshore Grid 
Development Framework 
determines investments 

No risk since TSO can 
cover investments in its 
RAB and Spatial Grid 
Development Plan and 
Maritime Spatial Plan 
determine investments 

No provisions for 
anticipatory investments, 
and thus currently large 
risk to project realisation 

Risk of 
stranded asset 

Risk of stranded 
transmission investment 
exists with coverage 
under Dutch regulation 
uncertain 

No risk of stranded 
transmission investments 
as investments are fully 
covered under German 
regulation 

No provisions for 
anticipatory investments, 
and thus currently large 
risk of stranded assets 

 
 
 
 
 
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Dutch regulation 

German regulation 

Danish regulation 

Concerned asset: 
Export cable systems, 
interconnectors and hub 

Concerned asset: 
Export cable systems, 
interconnectors and hub 

Concerned asset: 
Export cable systems, 
interconnectors and hub 

Summary 

Anticipatory investments 
are treated as regular 
investments at discretion 
of government through 
inclusion in Offshore Grid 
Development Framework 

Anticipatory investments 
are subject to regulator's 
approval  

No provisions for 
anticipatory investments 

Table 25: North Sea Wind Power Hub (NSWPH) – Assessment of regulatory regimes for anticipatory 
investments 

In summary, the interaction with stakeholders shows that it is necessary to clarify the assurance of 
reimbursements in the Netherlands and Germany and establish reimbursement in Denmark to enable 
TSOs  or  other  commercial  players  to  engage  in  anticipatory  investments.  At  the  same  time,  the 
efficiency  of  anticipatory  investments  must  be  assessed  to  ensure  the  sensible  expansion  of 
infrastructure. 

Considering the results of the interaction with the stakeholders, the selection and / or implementation 
of the appropriate mitigation option for the NSWPH hybrid project must also take into  account the 
interdependencies between the individual barriers. 

5.3.12  Uncertainty about RES subsidy scheme 

This barrier is relevant for the NSWPH hybrid project. 

To address this barrier, three mitigation options are assessed with regard to their applicability (Table 
26) – excluding the implications of interdependencies with other barriers. 

▪  Option 1 "National subsidy scheme": The respective national country, with payments organised 
through the respective TSOs, is responsible for the subsidy scheme of a given OWF, depending 
on the location of the OWF. Consequently, the Netherlands are responsible for the OWFs located 
in the Dutch EEZ,  Germany is responsible for the OWFs in the German EEZ and Denmark is 
responsible for the OWFs in the Danish EEZ. 

▪  Option  2  "Joint  support  scheme":  According  to  EU  Directive  2009/28/EC  Member  States  may 
establish and co-fund a joint support scheme to spur renewable energy production. In this context, 
the OWFs included in the NSWPH hybrid project are supported through a joint support scheme 
of  the  stakeholder  countries,  the  Netherlands,  Germany  and  Denmark.  Regardless  of  their 
location, the same joint support scheme applies to all OWFs as long as they are included in the 
NSWPH hybrid project. 

▪  Option 3 "No subsidy scheme": The OWFs included in the NSWPH hybrid project are tendered 
without a subsidy scheme (i.e. comparable to zero-subsidy bids) and neither a subsidy scheme 
of the Netherlands, Germany nor Denmark nor a joint support scheme is needed. 

 
 
 
 
 
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Option 1: National 
subsidy scheme  

Option 2: Joint support 
scheme  

Option 3: No subsidy 
scheme 

Legal / 
regulatory 
provisions 

Covered in national legal 
and regulatory regime in 
NL, DE and DK but 
applicability to project to 
be clarified due to 
connection of OWFs to 
shore via hub (uncertainty 
about onshore connection 
point) 

Covered by EU Directive 
2009/28/EC on a 
European level but legally 
binding document 
between NL, DE and DK 
needs to be formulated to 
establish joint support 
scheme 

Covered in national legal 
and regulatory regime 

Costs 

Costs borne by the NL, 
DE and DK 

Costs borne jointly by the 
NL, DE and DK 

No costs must be borne 
by the NL, DE and DK 

Mechanism 

Sliding feed-in premium in 
NL and DE (for tenders 
from 2020 onwards), feed-
in tariff in DK 

Support scheme type, 
level of support, duration 
and technological 
coverage to be agreed 
upon 

Project 
bankability 

Bankability in NL, DE and 
DK ensured through 
subsidy schemes 

Bankability ensured 
through joint support 
scheme 

Public opinion  Public opinion in NL, DE 
and DK can be opposed 
to funding RES generation 
potentially transmitted to 
other countries with public 
funds 

Public opinion in NL, DE 
and DK can be opposed 
to funding RES generation 
potentially transmitted to 
other countries with public 
funds 

No mechanism necessary 

Bankability of project 
depends on other offtake 
securities, such as long-
term power purchase 
agreements 

Public opinion neutral 
since no public funds used  

Timeline 

Summary 

Uncertain timeline in NL, 
DE and DK as OWF sites 
are not foreseen in 
existing (central) plans but 
tender processes in place 

Uncertain timeline in NL, 
DE and DK as OWF sites 
are not foreseen in 
existing (central) plans 
and joint support scheme 
must be established 

Uncertain timeline in NL, 
DE and DK as OWF sites 
are not foreseen in 
existing (central) plans but 
tender processes in place 

Covered in national legal 
and regulatory regime with 
clarity on onshore 
connection point needed, 
bankability ensured but 
public opinion potentially 
opposed and uncertain 
timeline  

Covered in EU and 
national legal and 
regulatory regime with 
legal agreement required, 
bankability ensured but 
public opinion potentially 
opposed and uncertain 
timeline 

Covered in national legal 
and regulatory regime but 
bankability only ensured 
with offtake securities and 
uncertain timeline 

Table 26: North Sea Wind Power Hub (NSWPH) – Assessment of options for RES subsidy schemes 

 
 
 
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In  summary,  the  interaction  with  stakeholders  shows  that  all  three  options  –  applying  the  national 
subsidy scheme of the country in whose EEZ the OWF is located to the respective OWF (Option 1), 
establishing  a  joint  support  scheme  (Option  2)  as  well  as  tendering  OWF  sites  without  a  subsidy 
scheme  (i.e.  comparable  to  zero-subsidy  bids)  (Option  3)  –  have  advantages  and  disadvantages. 
While the feasibility of Option 1 depends on the applicability of the national subsidy schemes to the 
hybrid project OWFs due to needed clarity on the onshore connection point, the feasibility of tendering 
without  a  subsidy  scheme  (Option  3)  largely  depends  on  the  ability  of  OWF  developers  to  secure 
offtake  securities  like  power  purchase  agreements  to  ensure  the  bankability  of  the  project. 
Establishing a joint support scheme of the Netherlands, Germany and Denmark is legally covered 
and provides the necessary bankability but might be problematic due to the extended timeline which 
is  needed  to  agree  the  specifications  of  the  scheme  and  to  formulate  a  legally  binding  document 
between the Netherlands, Germany and Denmark.  

Considering the results of the interaction with the stakeholders, the selection and / or implementation 
of the appropriate mitigation option for the NSWPH hybrid project must also take into  account the 
interdependencies between the individual barriers. 

5.3.13  Limited engagement of public stakeholders 

The  barrier  "limited  engagement  of  public  stakeholders"  is  divided  into  two  subtopics,  formalised 
public support and financial support. The two subtopics are addressed individually in the following. 

Formalisation of commitment from public stakeholders  

This subtopic of the barrier is relevant for the NSWPH hybrid project. 

To address this barrier, two mitigation options are assessed with regard to their applicability (Table 
27) – excluding the implications of interdependencies with other barriers. 

▪  Option  1  "Memorandum  of  Understanding  (MoU)":  A  Memorandum  of  Understanding  is  a 
formalisation of the goodwill of the involved parties in form of a non-binding agreement. An MoU 
addresses  barriers  by  formalising  the  agreements  of  the  involved  parties  with  regard  to  the 
implementation  of  required  actions  to  overcome  the  barriers.  It  can  involve  all  project 
stakeholders,  such  as  OWF  developers,  TSOs,  national  ministries  and  NRAs  as  well  as  the 
European Commission. 

▪  Option 2 "Hybrid Asset Network Support Agreement (HANSA)": A project-specific Hybrid Asset 
Network  Support  Agreement  is  a  legally-binding  commitment  to  adapt  national  legislation  and 
regulation in the future, and thus provides legal certainty to developers. European legislation and 
regulation can only be adapted via a project-specific HANSA if all Member States of the European 
Union  sign  the  agreement.  It  only  directly  involves  public  stakeholders,  such  as  national 
ministries. 

Option 1: Memorandum of 
Understanding (MoU) 

Option 2: Hybrid Asset Network 
Support Agreement (HANSA) 

Required effort  Some interaction and alignment 

required among project developers and 
stakeholders to facilitate signing of 
agreement 

Significant interaction and alignment 
among political project stakeholders 
required to facilitate signing of 
agreement 

 
 
 
 
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Option 1: Memorandum of 
Understanding (MoU) 

Option 2: Hybrid Asset Network 
Support Agreement (HANSA) 

Provided 
certainty 

Intentional character of signed 
agreement sufficient for hybrid projects 
in early development stage  

Legally binding commitment to topics 
covered by signed agreement directly 
facilitates project development, but is 
only required at a later development 
stage of hybrid projects 

Summary 

Reasonable effort to align agreement 
required prior to signing and non-legally 
binding commitment sufficient in early 
project development stages 

Significant effort for alignment of 
agreement required prior to signing but 
provides legal certainty and therefore 
suitable in later development stages 

Table 27: North Sea Wind Power Hub (NSWPH) – Assessment of options for formalisation of commitment from 
public stakeholders 

In  summary,  the  interaction  with  stakeholders  shows  that  both  options  –  a  project-specific 
Memorandum  of  Understanding  (Option  1)  and  a  project-specific  Hybrid  Asset  Network  Support 
Agreement (Option 2) – have advantages and disadvantages. While less effort is usually required to 
align  and  sign  a  project-specific  MoU,  an  MoU  is  not  legally  binding,  and  thus  the  commitment  of 
public stakeholders provides limited certainty, for example, about legal and regulatory changes for 
project developers (Option 1). However, while a project-specific HANSA provides legal certainty about 
the commitment of stakeholders to implement legal and regulatory changes, the alignment process 
requires more effort (Option 2).  

Considering the results of the interaction with the stakeholders, the selection and / or implementation 
of the appropriate mitigation option for the NSWPH hybrid project must also take into  account the 
interdependencies  between  the  individual  barriers  as  well  as  the  development  stage  of  the  hybrid 
project. 

Financial support 

This subtopic of the barrier is relevant for the NSWPH hybrid project. 

In  summary,  the  interaction  with  stakeholders  shows  that  there  is  no  specific,  tangible  mitigation 
option  to  address  the  barrier  of  limited  financial  support,  but  rather  that  a  portfolio  of  support 
programmes is available and their usage needs to be increased to facilitate the implementation of 
hybrid projects. In the past, hybrid project development and / or considerations, such as the Combined 
Grid Solution Kriegers Flak in the Baltic Sea and the Interconnector tie-in COBRA Cable in the North 
Sea,  indicate  that  such  support  is  required  to  de-risk  and  thereby  allow  for  the  realisation  of  pilot 
projects. In this context, financial support can come in various forms, such as co-financing for early-
stage feasibility studies, scoping studies or R&D, co-financing of development and construction or 
guarantees  for  the  operational  phase.  Generally,  financial  support  programmes  are  available  on 
national and European level and should be as specifically targeted at hybrid projects as possible. The 
target is to increase the awareness for and the usage of existing financial support programmes and 
thereby foster the development of hybrid projects. 

Considering the results of the interaction with the stakeholders, the mitigation of this barrier for the 
NSWPH  hybrid  project  must  also  take  into  account  the  interdependencies  between  the  individual 
barriers. 

 
 
 
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5.3.14  Uncertainty regarding the UK market 

The barrier "uncertainty regarding the UK market" is divided into two subtopics, UK Capacity Market 
and UK Cap and Floor regime as well as EU internal energy market. The two subtopics are addressed 
individually in the following. 

UK Capacity Market and Cap and Floor regime 

This subtopic of the barrier is not relevant for the NSWPH hybrid project. 

In the context of the NSWPH hybrid project, no commercial nor public UK stakeholders are involved. 
Thus, there is no uncertainty regarding the UK  Capacity Market and Cap and Floor regime for the 
specific hybrid project idea. 

EU internal energy market 

This subtopic of the barrier is not relevant for the NSWPH hybrid project. 

In the context of the NSWPH hybrid project, no commercial nor public UK stakeholders are involved. 
Thus,  there  is  no  uncertainty  regarding  the  participation  in  the  EU  internal  energy  market  for  the 
specific hybrid project idea. 

5.3.15  Disproportionate allocation of costs and benefits across involved 

stakeholders 

This barrier is relevant for the NSWPH hybrid project. 

In  summary,  the  interaction  with  stakeholders  shows  that  there  is  no  specific,  tangible  mitigation 
option  to  address  the  barrier  of  disproportionate  allocation  of  costs  and  benefits  across  involved 
stakeholders,  but  rather  that  a  process  towards  the  mitigation  of  the  barrier  must  be  followed. 
Generally, the process consists of the identification and alignment of cost and benefit categories, the 
determination of the initial allocation of costs and benefits, the agreement on a re-allocation of costs 
and benefits as well as – if required and available – the usage of CEF funding to ensure the individual 
incentivisation of all stakeholders. This can build on the existing process for Cost Benefit Analyses 
(CBA) and Cross-Border Cost Allocations (CBCA) as defined by ENTSO-E for cross-border electricity 
interconnectors, which needs to be adjusted according to the specifications of each individual hybrid 
project. The process should allow for the incentivisation of all relevant stakeholders to implement the 
hybrid project. 

Considering the results of the interaction with the stakeholders, the mitigation process to be followed 
for  the  NSWPH  hybrid  project  must  also  take  into  account  the  interdependencies  between  the 
individual barriers. 

5.3.16  Uncertainty about legislative regime for power-to-gas and related 

infrastructure  

This barrier is relevant for the NSWPH hybrid project.  

In  summary,  the  interaction  with  stakeholders  shows  that  the  integration  of  power  conversion  to 
hydrogen and hydrogen transmission in the NSWPH hybrid project has multiple advantages. Coupling 
power generation with the production of hydrogen represents a first step towards a more integrated 
energy system in the European  Union. The utilisation of existing  gas pipelines for the transport of 
converted  hydrogen  to  shore  might  optimise  costs.  The  conversion  of  electricity  to  hydrogen  can 
further contribute to overcome onshore grid congestion issues since the coupling provides additional 
flexibility  in  storage  and  transport  such  that  energy  can  be  traded  more  flexibly  in  the  market. 
However,  power  conversion  to  hydrogen  and  hydrogen  transmission  so  far  remain  without  a 

 
 
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dedicated  legislative  framework  both  on  the  national  and  the  European  level.  Legislation  and 
regulation of natural / industrial / chemical gas infrastructure may be starting points for an application 
to  power  conversion  to  hydrogen  and  hydrogen  transmission,  but  do  not  account  for  the  potential 
importance of hydrogen in the future energy market with increasing shares of RES in the energy mix. 
New and / or updated European legislation in the hydrogen sector needs to consider unbundling, non-
discriminatory  access  to  infrastructure,  market  arrangements  and  regulation  of  tariffs.  Established 
energy market infrastructure providers such as electricity and gas TSOs and DSOs depend on an 
effective  legislative  framework  to  incorporate  power  conversion  to  hydrogen  and  hydrogen 
transmission into their existing asset base and service offering. 

5.4  COBRA Cable 

Throughout  stakeholder  interaction,  10  out  of  16  barriers  are  identified  to  be  relevant  for  the 
implementation  of  the  COBRA  Cable  hybrid  project  idea.  The  results  of  the  interaction  with 
stakeholders with regard to all barriers – relevant and not relevant – are summarised in the ensuing 
subchapters.  

5.4.1  Uncertainty about responsibility for project development 

The barrier "uncertainty about responsibility for project development" is divided into three subtopics, 
grid  connection  responsibility,  responsibility  for  the  development  and  construction  of  the 
interconnector  and  responsibility  for  the  operation  of  the  interconnector.  The  three  subtopics  are 
addressed individually in the following. 

Grid connection responsibility 

This subtopic of the barrier is relevant for the COBRA Cable hybrid project. 

To address this barrier, three mitigation options are assessed with regard to their applicability (Table 
28) – excluding the implications of interdependencies with other barriers.  

▪  Option 1 "TenneT TSO B.V. and Energinet are responsible": The Dutch TSO, TenneT TSO B.V., 
and the Danish TSO, Energinet, are responsible for the connection of the German OWF to the 
interconnector operated by the two TSOs.  

▪  Option  2  "TenneT  TSO  GmbH  is  responsible":  The  German  TSO,  TenneT  TSO  GmbH,  is 

responsible for the connection of the German OWF to the interconnector. 

▪  Option 3 "OWF developer is responsible": The OWF developer is responsible for the connection 

of the German OWF to the interconnector. 

▪  Option  4  "TenneT  TSO  B.V.,  TenneT  TSO  GmbH  and  Energinet  are  responsible":  The  Dutch 
TSO, TenneT TSO B.V., the German TSO, TenneT TSO GmbH and the Danish TSO, Energinet 
are responsible for the connection of the German OWF to the interconnector. 

 
 
 
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Legal / 
regulatory 
coverage 

Option 2: TenneT 
TSO GmbH is 
responsible 

Option 3: OWF 
developer is 
responsible 

Not covered in DE 
legislation and 
regulation (OWF 
location and 
onshore connection 
point define 
responsibility) – EU 
network codes, 
such as "HVDC 
Connections" and 
"Requirements for 
generators", 
support technical 
standardisation 

Not covered in NL, 
DE, DK and EU 
legislation and 
regulation 
(unbundling applies 
for OWF 
developer) – EU 
network codes, 
such as "HVDC 
Connections" and 
"Requirements for 
generators", 
support technical 
standardisation 

Option 1: TenneT 
TSO B.V. and 
Energinet are 
responsible 

Not covered in NL 
and DK (OWF 
location defines 
responsibility) as 
well as DE 
legislation and 
regulation (OWF 
location and 
onshore connection 
point define 
responsibility) – EU 
network codes, 
such as "HVDC 
Connections" and 
"Requirements for 
generators", 
support technical 
standardisation 

Option 4: TenneT 
TSO B.V., TenneT 
TSO GmbH and 
Energinet are 
responsible 

Not covered in NL 
and DK (OWF 
location defines 
responsibility) as 
well as DE 
legislation and 
regulation (OWF 
location and 
onshore connection 
point define 
responsibility) – EU 
network codes, 
such as "HVDC 
Connections" and 
"Requirements for 
generators", 
support technical 
standardisation 

Costs 

Financial risk 

Costs are with NL 
and DK, including 
liability for grid 
connection delay or 
unavailability of 
grid 

Costs are with DE, 
including liability for 
grid connection 
delay or 
unavailability of 
grid 

Costs are with 
OWF developer, 
including liability for 
grid connection 
delay or 
unavailability of 
grid 

Costs are with NL, 
DE and DK, 
including liability for 
grid connection 
delay or 
unavailability of 
grid 

Financial risk is 
with TenneT TSO 
GmbH, and thus 
with DE, therefore 
no risk towards 
project realisation  

Financial risk is 
with OWF 
developer, 
therefore risk 
towards project 
realisation  

Financial risk is 
with TenneT TSO 
B.V. (offshore grid 
operator) and 
Energinet, and thus 
with NL and DK, 
therefore no risk 
towards project 
realisation  

Financial risk is 
with TenneT TSO 
B.V. (offshore grid 
operator), TenneT 
TSO GmbH and 
Energinet, and thus 
with NL, DE and 
DK, therefore no 
risk towards project 
realisation  

 
 
 
 
 
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Development 
risk 

Operational 
risk 

Market-specific 
expertise 

Option 1: TenneT 
TSO B.V. and 
Energinet are 
responsible 

Alignment of 
development 
needed for multiple 
developers but not 
additionally across 
parts of entire 
cable system due 
to congruent 
responsibilities, 
therefore low risk 
towards project 
realisation 

Alignment of 
operations needed 
for multiple 
developers but not 
additionally across 
parts of entire 
cable system due 
to congruent 
responsibilities, 
therefore low risk 
towards project 
realisation 

Knowledge on 
general and 
project-specific grid 
connection and 
operational 
requirements 
partially given for 
TenneT TSO B.V. 
and Energinet in 
NL and DK, 
respectively 

Option 2: TenneT 
TSO GmbH is 
responsible 

Option 3: OWF 
developer is 
responsible 

Alignment of 
development not 
needed for a single 
developer but 
across parts of 
entire cable system 
due to differing 
responsibilities, 
therefore uncertain 
risk towards project 
realisation 

Alignment of 
development not 
needed for a single 
developer but 
across parts of 
entire cable system 
due to differing 
responsibilities, 
therefore uncertain 
risk towards project 
realisation 

Alignment of 
operations not 
needed for a single 
developer but 
across parts of 
entire cable system 
due to differing 
responsibilities, 
therefore uncertain 
risk towards project 
realisation 

Alignment of 
operations not 
needed for a single 
developer but 
across parts of 
entire cable system 
due to differing 
responsibilities, 
therefore uncertain 
risk towards project 
realisation 

Knowledge on 
general and 
project-specific grid 
connection and 
operational 
requirements 
partially given for 
TenneT TSO 
GmbH in DE 

Knowledge on 
general and 
project-specific grid 
connection and 
operational 
requirements not 
given for OWF 
developers 

Option 4: TenneT 
TSO B.V., TenneT 
TSO GmbH and 
Energinet are 
responsible 

Alignment of 
development 
needed for multiple 
developers and 
additionally across 
parts of entire 
cable system due 
to differing 
responsibilities, 
therefore low risk 
towards project 
realisation 

Alignment of 
operations needed 
for multiple 
developers and 
additionally across 
parts of entire 
cable system due 
to differing 
responsibilities, 
therefore low risk 
towards project 
realisation 

Knowledge on 
general and 
project-specific grid 
connection and 
operational 
requirements given 
for TenneT TSO 
B.V., TenneT TSO 
GmbH and 
Energinet in NL, 
DE and DK, 
respectively 

 
 
 
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Risk for OWF 
developer 

First 
connection 
charges and 
G-charges 

Option 1: TenneT 
TSO B.V. and 
Energinet are 
responsible 

No financial risk for 
OWF in case of 
delays or failure in 
grid connection, as 
compensation is 
guaranteed by 
regulation in NL 
and DK 

Option 2: TenneT 
TSO GmbH is 
responsible 

Option 3: OWF 
developer is 
responsible 

No financial risk for 
OWF in case of 
delays or failure in 
grid connection, as 
compensation is 
guaranteed by 
regulation in DE 

Financial risk for 
OWF in case of 
delays and failure 
in grid connection, 
as OWF developer 
is fully liable 

Uncertainty about 
first connection 
charges and G-
charges faced by 
OWF developers 

Shallow first 
connection charges 
and no G-charges 
in the NL, shallow 
to super-shallow 
first connection 
charges and no G-
charges in DE, 
super-shallow to 
partially shallow 
first connection 
charges and 
energy-based G-
charges in DK 

Shallow first 
connection charges 
and no G-charges 
in the NL, shallow 
to super-shallow 
first connection 
charges and no G-
charges in DE, 
super-shallow to 
partially shallow 
first connection 
charges and 
energy-based G-
charges in DK 

Option 4: TenneT 
TSO B.V., TenneT 
TSO GmbH and 
Energinet are 
responsible 

No financial risk for 
OWF in case of 
delays or failure in 
grid connection, as 
compensation is 
guaranteed by 
regulation in NL, 
DE and DK 

Shallow first 
connection charges 
and no G-charges 
in the NL, shallow 
to super-shallow 
first connection 
charges and no G-
charges in DE, 
super-shallow to 
partially shallow 
first connection 
charges and 
energy-based G-
charges in DK 

Summary 

Not covered under 
NL, DE and DK 
legal and 
regulatory regime, 
but with low risk 
towards project 
realisation 

Not covered under 
NL, DE and DK 
legal and 
regulatory regime 
and with uncertain 
risk towards project 
realisation 

Not covered under 
NL, DE, DK and 
EU legal and 
regulatory regime 
and with uncertain 
risk towards project 
realisation 

Not covered under 
NL, DE and DK 
legal and 
regulatory regime 
and with uncertain 
risk towards project 
realisation 

Table 28: COBRA Cable – Assessment of options for grid connection responsibility 

In  summary,  the  interaction  with  stakeholders  shows  that  only  three  options  –  to  allocate  the 
responsibility to TenneT TSO B.V. and Energinet (Option 1), to TenneT TSO GmbH (Option 2), to the 
OWF developer (Option 3) as well as to the consortium of TenneT TSO B.V., TenneT TSO GmbH 
and Energinet (Option 4) – have advantages and disadvantages. All options are not covered under 
current  legal  and  regulatory  frameworks.  The  allocation  of  responsibility  to  the  Dutch  and  Danish 
entity (Option 1) features a low risk towards project realisation whereas the other options feature an 
uncertain risk towards project realisation due to required alignment across developers and across all 
parts of the entire cable system (interconnector and export cable system). With regard to required 
market-specific expertise, only developers in Option 4 can provide such expertise across all markets. 
The inclusion of TSOs in Options 1, 2 and 4 insures OWF developers in case of a delay or a failure 
of their grid connection. 

 
 
 
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Considering the results of the interaction with the stakeholders, the selection and / or implementation 
of the appropriate mitigation option for the COBRA Cable hybrid project must also take into account 
the interdependencies between the individual barriers. 

Responsibility for development and construction of interconnector 

This subtopic of the barrier is not relevant for the COBRA Cable hybrid project. 

The  COBRA  Cable  interconnector  itself  is  developed  and  constructed  by  TenneT  TSO  B.V.  and 
Energinet and is planned to be commissioned in 2019. The responsibility for the interconnector is not 
further discussed in this study. 

Responsibility for operation of interconnector 

This subtopic of the barrier is not relevant for the COBRA Cable hybrid project. 

The COBRA Cable interconnector itself is planned to be commissioned in 2019 and subsequently 
operated by TenneT TSO B.V. and Energinet. The responsibility for the interconnector is not further 
discussed in this study. 

5.4.2  Uncertainty about regulation deriving from jurisdiction over cross-border 

cable systems 

This barrier is relevant for the COBRA Cable hybrid project. 

To address this barrier, two mitigation options are assessed with regard to their applicability (Table 
29)  –  excluding  the  implications  of  interdependencies  with  other  barriers.  The  assessment 
concentrates on the jurisdiction applicable to the cable system connecting the German OWF to the 
COBRA  Cable  interconnector.  The  OWF  underlies  German  jurisdiction  in  line  with  the  installation 
exploiting wind as a natural resource within the German EEZ. 

▪  Option  1  "German  jurisdiction's  regulations":  In  addition  to  European  law,  German  regulation 

applies to the cable system connecting the OWF to the COBRA Cable interconnector. 

▪  Option  2  "Alignment  of  jurisdictions'  regulations":  Based  on  negotiations  between  the 
Netherlands,  Germany  and  Denmark,  a  new  combination  of  regulations  applies  to  the  cable 
system connecting the OWF to the COBRA Cable interconnector – in addition to European law. 
This new combination of regulations can potentially be based on the existing agreement between 
the Netherlands and Denmark concerning the COBRA Cable interconnector. 

Option 1: German jurisdiction's 
regulations 

Option 2: Alignment of jurisdictions' 
regulations, based on COBRA Cable 
IC agreement 

Rights and 
duties in DE 
EEZ during 
operation 

No uncertainty since DE has jurisdiction 
and DE operational rules apply since 
cable does not cross NL and DK 
territorial sea and serves exploitation of 
DE EEZ 

Alignment required to combine 
operational rules deriving from 
jurisdictions of the NL, DE and DK for 
DE EEZ through involvement of the NL, 
DE and DK 

 
 
 
 
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Hybrid project 
requirements 

Timeline 

Others 

Summary 

Option 1: German jurisdiction's 
regulations 

Alignment of operational rules between 
DE and the NL as well as DK required 
because of connection of DE OWF to 
the COBRA Cable interconnector via the 
export cable system 

Option 2: Alignment of jurisdictions' 
regulations, based on COBRA Cable 
IC agreement 

No additional alignment of operational 
rules required 

Alignment may extend timeline of 
project 

Alignment may extend timeline of 
project 

Provisions for assigning liability in case 
of grid connection failure need to be 
implemented 

Alignment of operational rules required 
to allow for a combination of assets in 
hybrid project  

Alignment required to ensure 
applicability of Option 2 since DE rules 
apply in DE EEZ 

Table 29: COBRA Cable – Assessment of options for regulation deriving from jurisdiction deriving from cross-
border cable systems 

In summary, the interaction with stakeholders shows that both options – the agreement of applicability 
of operational rules to the  cable system connecting the OWF to the COBRA Cable interconnector 
based on German jurisdiction (Option 1) as well as the alignment of rules deriving from the Dutch, 
German  and  Danish  jurisdiction  (Option  2)  –  have  advantages  and  disadvantages.  While  the 
alignment of jurisdictions' regulations and the corresponding involvement of all three countries (Option 
2)  ensures  feasibility,  the  alignment  of  operational  rules  deriving  from  three  jurisdictions  can  be  a 
lengthy process. Yet, Option 2 reflects the interests of all involved countries in the alignment and can 
potentially  be based  on the existing agreement between the Netherlands, Germany  and Denmark 
established for the COBRA Cable interconnector. Furthermore, the application of German regulation 
(Option 1) requires cross-border alignment as well, due to differing regulation applying to the COBRA 
Cable interconnector and the connection of the OWF to the interconnector.  

Considering the results of the interaction with the stakeholders, the selection and / or implementation 
of the appropriate mitigation option for the COBRA Cable hybrid project must also take into account 
the interdependencies between the individual barriers. 

5.4.3  Uncertainty about market arrangements 

This barrier is relevant for the COBRA Cable hybrid project. 

To address this barrier, five mitigation options are assessed with regard to their applicability (Table 
30) – excluding the implications of interdependencies with other barriers. 

▪  Option 1 "Commercial flows either to the Dutch or to Danish market": With commercial flows to 
either  the  Netherlands  or  Denmark,  the  German  OWF  is  always  feeding  its  electricity 
commercially into the Dutch or Danish market, thus into the bidding zones to which the OWF is 
connected. 

 
 
 
 
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▪  Option 2 "Commercial (virtual) flows to home market": With commercial (virtual) flows to the home 
market, this is, Germany, the German OWF always transmits its electricity commercially to the 
German market, and thus into the bidding zone in which the OWF is physically located. 

▪  Option 3 "Dynamic flows to high-price market": With commercial flows to the dynamic high-price 
market, the German OWF always commercially transmits its electricity to the higher-price market. 
This might either be the Dutch or the Danish market.  

▪  Option 4 "Dynamic flows to low-price market": With commercial flows to the dynamic low-price 
market,  the  German  OWF  always  commercially  transmits  its  electricity  into  the  lower-price 
market. This might either be the Dutch or the Danish market.  

▪  Option  5  "Dedicated  bidding  zone": With  a  dedicated  bidding  zone,  the  German  OWF  always 
commercially feeds its electricity to its dedicated bidding zone, newly established for the OWF 
included in the hybrid project. 

 
 
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Option 1: 
Commercial flows 
either to the Dutch or 
to Danish market 

Option 2: 
Commercial (virtual) 
flows to home market 

Option 3: Dynamic 
flows to high-price 
market 

Option 4: Dynamic 
flows to low-price 
market 

Legal / 
regulatory 
coverage 

Not covered under 
existing market 
regulation 

Not covered under 
existing market 
regulation  

Price 
determination 

Either Dutch or 
Western Danish 
market prices apply 

Home market price 
applies  

Not covered under 
existing market 
regulation, particularly 
in violation of CACM 
requirement of stability 
of bidding zones 
across market time 
frames 

Not covered under 
existing market 
regulation, particularly 
in violation of CACM 
requirement of stability 
of bidding zones 
across market time 
frames 

Price determination 
problematic when 
transmission of 
generated electricity to 
high-price market not 
possible (limited 
capacity) – alternative 
price determination 
needed 

Price determination 
problematic when 
transmission of 
generated electricity to 
low-price market not 
possible (limited 
capacity) – alternative 
price determination 
needed 

Option 5: Dedicated 
bidding zone 

Covered under existing 
market regulation as 
new bidding zone can 
be treated as home 
market after bidding 
zone review process 

Dedicated bidding 
zone price applies  

 
 
 
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Price effects 

Option 1: 
Commercial flows 
either to the Dutch or 
to Danish market 

Option 2: 
Commercial (virtual) 
flows to home market 

Option 3: Dynamic 
flows to high-price 
market 

Option 4: Dynamic 
flows to low-price 
market 

Option 5: Dedicated 
bidding zone 

Effect of decreasing 
prices in NL or DK, as 
OWF produces at 
close to zero marginal 
costs – indirect price 
effects through 
available IC capacity 

Effect of decreasing 
prices in home market, 
as OWF produces at 
close to zero marginal 
costs – indirect price 
effects through 
available IC capacity 

Effect of decreasing 
prices in the high-price 
market, as OWF 
produces at close to 
zero marginal costs – 
indirect price effects 
through available IC 
capacity 

Effect of decreasing 
prices in the low-price 
market, as OWF 
produces at close to 
zero marginal costs – 
indirect price effects 
through available IC 
capacity 

Effect of decreasing 
prices in the dedicated 
bidding zone, as OWF 
produces at close to 
zero marginal costs – 
indirect price effects 
through available IC 
capacity 

Price 
discrimination 
of OWFs 

Discriminatory against 
hybrid OWF if DE 
market price is higher 
than NL or DK market 
price, which it receives 

Not discriminatory 
against any OWF as 
hybrid OWF and other 
OWFs in DE bidding 
zone receive same 
prices 

Discriminatory against 
any other OWF in the 
DE bidding zones, as 
hybrid OWF always 
receives high price of 
NL or DK market 

Discriminatory against 
hybrid OWF as it 
always receives low 
price of NL or DK 
market 

Conflict 
between 
transmission 
from OWF to 
shore and IC 
functionality 

Conflict since 
commercial IC flows 
and commercial OWF 
flows are in same 
direction at times 

No conflict, since 
commercial IC flows 
either to NL or DK 
market and 
commercial OWF flows 
(virtually) to DE market  

Conflict since 
commercial IC flows 
and commercial OWF 
flows are always in 
same direction 

No conflict, since 
commercial IC flows 
and commercial OWF 
flows are always in 
opposite direction 

Not discriminatory 
against any OWF as 
hybrid OWF and 
OWFs in DE bidding 
zone receive price of 
their bidding zone 

No conflict, since 
commercial IC flows 
are between bidding 
zones only and 
commercial OWF flows 
are to dedicated 
bidding zone only 

 
 
 
 
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Option 1: 
Commercial flows 
either to the Dutch or 
to Danish market 

Compensation  Negative business 

case implications for 
hybrid OWF from price 
discrimination and for 
hybrid OWF or IC from 
conflict for cable 
system capacity, and 
thus additional 
compensation 
necessary 

Option 2: 
Commercial (virtual) 
flows to home market 

Option 3: Dynamic 
flows to high-price 
market 

Option 4: Dynamic 
flows to low-price 
market 

No business case 
implications for hybrid 
OWF or IC, and thus 
no additional 
compensation 
necessary 

Negative business 
case implications for 
hybrid OWF or IC from 
conflict for cable 
system capacity, and 
thus additional 
compensation 
necessary 

Negative business 
case implications for 
hybrid OWF from price 
discrimination, and 
thus additional 
compensation 
necessary 

Option 5: Dedicated 
bidding zone 

No business case 
implications for hybrid 
OWF or ICs, and thus 
no additional 
compensation 
necessary 

Outages 

No backup cable 
system available 

No backup cable 
system available 

No backup cable 
system available 

No backup cable 
system available 

In case of outages of 
one cable system (NL 
to dedicated bidding 
zone or DK to 
dedicated bidding 
zone), transmission of 
electricity from OWF to 
shore via unaffected 
cable system possible 

 
 
 
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Option 1: 
Commercial flows 
either to the Dutch or 
to Danish market 

Option 2: 
Commercial (virtual) 
flows to home market 

Option 3: Dynamic 
flows to high-price 
market 

Option 4: Dynamic 
flows to low-price 
market 

Option 5: Dedicated 
bidding zone 

Though no conflict for 
cable system capacity, 
congruence of 
business cases of new 
ICs and COBRA Cable 
unclear 

Others 

Summary 

Legal and regulatory 
coverage not given, 
discriminatory against 
hybrid OWF and 
negative business 
case implications for 
OWF from price 
discrimination as well 
as for OWF or IC from 
conflict for cable 
system capacity 

Legal and regulatory 
coverage not given, 
not discriminatory 
against any OWF and 
no negative business 
case implications for 
OWF or IC 

Legal and regulatory 
coverage not given, 
discriminatory against 
other OWFs and 
negative business 
case implications for 
OWF or IC from 
conflict for cable 
system capacity 

Legal and regulatory 
coverage not given, 
discriminatory against 
hybrid OWF and 
negative business 
case implications for 
OWF from price 
discrimination 

Legal and regulatory 
coverage given, not 
discriminatory against 
any OWF and no 
negative business 
case implications for 
OWF but unclear for 
ICs 

Table 30: COBRA Cable – Assessment of options for market arrangement 

 
 
 
 
 
 
 
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In summary, the interaction with stakeholders shows that all five options – OWF always commercially 
evacuating  electricity  to  either  the  Dutch  or  Danish  market  (Option  1)  or  (virtually)  to  the  German 
market (Option 2), OWF commercially evacuating electricity to the higher-price or lower-price market 
of the Netherlands and Denmark (Option 3 and 4) as well as establishing a dedicated bidding zone 
for the OWF included in the hybrid project (Option 5) – have advantages and disadvantages. While 
legal and regulatory coverage is not given for Options 1, 2, 3 and 4, with Options 3 and 4 violating 
the European CACM requirement of stability of bidding zones across market time frames. Yet, legal 
and regulatory coverage for a dedicated bidding zone is given (Option 5). However, the necessity and 
extent of a bidding zone review process needs to be clarified. In case of commercial (virtual) flows to 
Germany (Option 2), there may be a need for onshore grid reinforcements. Furthermore, depending 
on  the  chosen  mitigation  option,  negative  business  case  implications  for  the  hybrid  OWF  or  IC(s) 
require additional compensation from the conflict for cable system capacity (Options 1 and 3) or from 
price discrimination for the hybrid OWF (Options 1 and 4). 

Considering the results of the interaction with the stakeholders, the selection and / or implementation 
of the appropriate mitigation option for the COBRA Cable hybrid project must also take into account 
the interdependencies between the individual barriers. 

5.4.4  Uncertainty about hybrid cable system classification 

This barrier is relevant for the COBRA Cable hybrid project. 

To address this barrier, three mitigation options are assessed with regard to their applicability (Table 
31)  –  excluding  the  implications  of  interdependencies  with  other  barriers.  The  assessment 
concentrates on the COBRA Cable interconnector. The export cable connecting the DE OWF to the 
interconnector has no dual functionality. 

▪  Option 1 "Export system with interconnector functionality": The COBRA Cable interconnector is 
a hybrid cable system, which allows for the transmission of electricity from the German OWF to 
the Dutch and Western Danish markets. Hence, the cable system only provides interconnector 
functionality between the Dutch and Western Danish bidding zone with leftover capacities.  

▪  Option 2 "Interconnector with export system functionality": The COBRA cable interconnector is a 
hybrid cable system, which allows for the transmission of electricity from the German OWF to the 
Dutch  and  Western  Danish  markets  only  with  leftover  capacities.  Hence,  the  cable  system 
primarily provides  interconnector functionality between the  Dutch  and Western Danish bidding 
zone. 

▪  Option 3 "Interconnector (with dedicated bidding zone)": Cable systems linking the German OWF 
to shore are interconnectors. This option is included for compatibility with the market arrangement 
of a dedicated bidding zone, where the OWF only feeds electricity to the dedicated bidding zone 
and interconnectors link the dedicated bidding zone to the Netherlands and Denmark. 

 
 
 
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NL national 
legal / 
regulatory 
coverage 

DE national 
legal / 
regulatory 
coverage 

DK national 
legal / 
regulatory 
coverage 

EU legal / 
regulatory 
coverage 

Option 1: Export cable 
with IC functionality 

Option 2: IC with export 
cable functionality  

Option 3: Interconnector 
(with dedicated bidding 
zone) 

Potentially covered as NL 
regulation does not 
expressly prohibit dual 
functionality of cables but 
legal / regulatory feasibility 
to be validated 

Potentially covered as NL 
regulation does not 
expressly prohibit dual 
functionality of cables but 
legal / regulatory feasibility 
to be validated 

Covered under NL 
regulation as regular 
interconnector, but legal 
coverage of connection 
involving new bidding 
zone to be validated  

Covered under DE 
regulation as regular 
interconnector, but legal 
coverage of connection 
involving new bidding 
zone to be validated 

Not covered as DE 
regulation does not allow 
for dual functionality since 
cable systems linking two 
bidding zones are defined 
as ICs and must solely 
have that purpose and 
export cables are defined 
as connections between 
technical installations 
solely for the uptake, 
transmission and 
distribution of electrical 
energy for general supply 

Not covered as DE 
regulation does not allow 
for dual functionality since 
cable systems linking two 
bidding zones are defined 
as ICs and must solely 
have that purpose and 
export cables are defined 
as connections between 
technical installations 
solely for the uptake, 
transmission and 
distribution of electrical 
energy for general supply 

Potentially covered but 
needs to be validated 
since both export cables 
and ICs a part of the same 
regulatory regime and 
subject to approval by the 
ministry 

Potentially covered but 
needs to be validated 
since both export cables 
and ICs a part of the same 
regulatory regime and 
subject to approval by the 
ministry 

Covered under DK 
regulation as regular 
interconnector, but legal 
coverage of connection 
involving new bidding 
zone to be validated 

Covered under Electricity 
Directive because cable 
functions as regular 
interconnector such that 
maximum capacity is 
made available to market 
participants 

Not covered under 
Electricity Directive 
because it does not 
include an add. definition 
for hybrid cable systems; 
EU Regulation 714/2009 
prescribes that "maximum 
capacity of the 
interconnections […] shall 
be made available to 
market participants" with 
clarity needed whether 
"maximum" refers to 
nominal or leftover 
capacities of cable 
systems in hybrid projects 

Not covered under 
Electricity Directive 
because it does not 
include an add. definition 
for hybrid cable systems; 
EU Regulation 714/2009 
prescribes that "maximum 
capacity of the 
interconnections […] shall 
be made available to 
market participants" with 
clarity needed whether 
"maximum" refers to 
nominal or leftover 
capacities of cable 
systems in hybrid projects 

 
 
 
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Potential for 
curtailment of 
OWF 

Option 1: Export cable 
with IC functionality 

Option 2: IC with export 
cable functionality  

OWF can transmit 
electricity at full 
generation capacity, and 
thus no business case 
implications and 
minimised curtailment 

OWF can transmit 
electricity depending on 
leftover capacity of cable 
systems, and thus 
negative business case 
implications due to 
additional curtailment 

Option 3: Interconnector 
(with dedicated bidding 
zone) 

No business case 
implications 

Potential for 
congestion  

of IC 

Capacity available for 
trade is significantly 
reduced, and thus 
negative business case 
implications for IC 
functionality of the entire 
cable system 

Compensation  Due to joint development 
of transmission assets in 
hybrid project, 
optimisation of business 
case of cable system as a 
whole given; potentially no 
additional compensation 
necessary 

Third party 
access 

Third party access only 
given for leftover 
capacities after 
transmission of electricity 
from OWF to shore 

Full capacity is available 
for trade, and thus no 
business case 
implications for IC 
functionality of the entire 
cable system 

Full capacity is available 
for trade, and thus no 
business case 
implications for IC 
functionality of the entire 
cable system 

Due to foregone revenues 
from additional 
curtailment, additional 
compensation for OWF 
required 

No additional 
compensation required 

Third party access given 

Third party access given 

Impact on 
EU's energy 
policy targets 

Priority on primary targets 
of diversification and 
integration of RES as well 
as on GHG emission 
reductions over secondary 
target of maximised IC 
capacity 

Priority on secondary 
target of maximised IC 
capacity over primary 
targets of diversification 
and integration of RES as 
well as on GHG emission 
reductions  

Primary targets of 
diversification and 
integration of RES as well 
as on GHG emission 
reductions and secondary 
target of maximised IC 
capacity are prioritised 

 
 
 
 
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Summary 

Option 1: Export cable 
with IC functionality 

Option 2: IC with export 
cable functionality  

Not covered under 
existing EU and DE 
regulation, but potentially 
covered under NL and DK 
regulation; potential for 
negative business case 
implications for IC may 
necessitate additional 
compensation 

Not covered under 
existing EU and DE 
regulation, but potentially 
covered under NL and DK 
regulation; negative 
business case 
implications for OWF 
necessitate additional 
compensation 

Option 3: Interconnector 
(with dedicated bidding 
zone) 

Covered under existing 
EU as well NL, DE and 
DK regulations with 
validation for connection 
to dedicated bidding zone 
needed and no business 
case implications 

Table 31: COBRA Cable – Assessment of options for hybrid cable system classification 

In  summary,  the  interaction  with  stakeholders  shows  that  all  three  options  –  an  export  cable  with 
interconnector functionality (Option 1), an interconnector with export cable functionality (Option 2) as 
well  as  an  interconnector  (with  dedicated  bidding  zone)  (Option  3)  –  have  advantages  and 
disadvantages. Both, Option 1 and 2 require changes in the European and potentially in the national 
legal and regulatory frameworks. By contrast, Option 3 is based on the existing legal and regulatory 
framework  for  interconnectors  and  therefore  does  not  require  changes  to  European  and  national 
regulation if the connection of an interconnector to a new bidding zone is covered. However, Option 
2 has unfavourable implications for the business case of the OWF developer since the developer has 
no priority access to transmission capacity. Contrary, in Option 1, interconnector trade has no priority 
on the cable system resulting in unfavourable implications for the business case of the interconnector. 
In Option 3, the OWF feeds electricity to the new bidding zone and the interconnectors link the new 
bidding zone to other the Netherlands and Denmark, and thus there are no business case implications 
for  the  OWF  and  interconnectors.  Furthermore,  in  contrast  to  Option  1,  Option  2  prioritises  the 
secondary EU energy policy target of maximised electricity interconnection capacity over the primary 
targets of diversification and integration of RES as well as greenhouse gas emission reduction, while 
Option 3 prioritises both targets.  

Considering the results of the interaction with the stakeholders, the selection and / or implementation 
of the appropriate mitigation option for the COBRA Cable hybrid project must also take into account 
the interdependencies between the individual barriers. 

5.4.5 

Failure of developers to align planning across assets and countries 

The barrier "failure of developers to align planning across assets and countries" is divided into three 
subtopics, geographical alignment, technical alignment and timing alignment. The three subtopics are 
addressed individually in the following. 

Geographical alignment 

This subtopic of the barrier is relevant for the COBRA Cable hybrid project. 

In  summary,  the  interaction  with  stakeholders  shows  that  there  is  no  specific,  tangible  mitigation 
option to address the barrier of failed geographical alignment across assets and countries, but rather 
that a process towards the mitigation of the barrier must be followed. The process consists of the 
continuous  exchange  between  project  developers  and  other  stakeholders  to  allow  for  the 
achievement of early-stage, geographical alignment. 

 
 
 
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Considering the results of the interaction with the stakeholders, the mitigation process to be followed 
for the COBRA Cable hybrid project must also take into account the interdependencies between the 
individual barriers. 

Technical alignment 

This subtopic of the barrier is relevant for the COBRA Cable hybrid project. 

In  summary,  the  interaction  with  stakeholders  shows  that  there  is  no  specific,  tangible  mitigation 
option to address the barrier of failed technical alignment across assets and countries, but rather that 
a  process  towards  the  mitigation  of  the  barrier  must  be  followed.  The  process  consists  of  the 
continuous  exchange  between  project  developers  and  other  stakeholders  to  allow  for  the 
achievement of early-stage, technical alignment. 

Considering the results of the interaction with the stakeholders, the selection and / or implementation 
of the appropriate mitigation option for the COBRA Cable hybrid project must also take into account 
the interdependencies between the individual barriers. 

Timing alignment 

This subtopic of the barrier is not relevant for the COBRA Cable hybrid project. 

In the context of the COBRA Cable hybrid project, timing alignment is not relevant since the COBRA 
Cable interconnector is planned to be commissioned in 2019, with construction and installation having 
commenced in 2017. Therefore, it is not possible to align the time lines of a connection of the OWF 
to the interconnector with the development of the interconnector.  

5.4.6  Uncertainty about responsibility and rules to provide access to maritime 

space for OWFs (location selection, site pre-investigation and tender 
execution)  

The barrier "uncertainty about responsibility and rules to provide access to maritime space for OWFs 
(location selection, site pre-investigation and tender execution)" is divided into two subtopics, location 
selection and site  pre-investigation as  well as tender  execution. The two subtopics are addressed 
individually in the following. 

Location selection and site pre-investigation 

This subtopic of the barrier is relevant for the COBRA Cable hybrid project. 

To address this barrier, three mitigation options are assessed with regard to their applicability (Table 
32) – excluding the implications of interdependencies with other barriers. However, it is also possible 
that site pre-investigation has already taken place in this specific example, as leftover areas in an 
otherwise tendered cluster are considered for the OWF location. 

▪  Option 1 "Dutch and / or Danish responsibility": The Netherlands and / or Denmark conduct the 
location selection and site pre-investigation for the OWF site in the German Cluster 8 as part of 
the  respective  centrally  organised  pre-investigation  models,  following  standardised  national 
processes and timelines. Site decisions determine where OWF development can take place.  

▪  Option  2  "German  responsibility":  Germany  conducts  the  location  selection  and  site  pre-
investigation for the OWF site  in the German Cluster 8 as  part  of the centrally  organised  pre-
investigation  based  on  the  Spatial  Grid  Development  Plan,  following  standardised  national 
processes and timelines. Site decisions determine where OWF development can take place. 

 
 
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▪  Option  3  "Responsibility  of  OWF  developer":  The  potential  OWF  developer  conducts  location 
selection and site pre-investigation for the OWF site in the German Cluster 8 within the context 
of an open-door approach. All costs of the pre-investigation and site selection process are borne 
by  the  OWF  developer.  Following  the  final  site  decision  by  the  potential  OWF  developer,  the 
candidate applies for the necessary licenses to develop the OWF based on the results of the pre-
investigation. The extent to which a government shapes and controls the investigations that are 
part of the open-door process by specific regulatory requirements that must be met varies across 
the Netherlands, Germany and Denmark. 

Option 1: Dutch and / or 
Danish responsibility 

Option 2: German 
responsibility 

Option 3: Responsibility 
of OWF developer 

Legal / 
Regulatory 
coverage 

Not covered by DE 
legislation and regulation 

Covered by DE legislation 
and regulation, can 
potentially become part of 
special tender process 
("Sonderausschreibung") 

Not covered by DE 
legislation and regulation 

Costs 

Costs are with NL / DK  

Costs are with DE 

Process 

Timeline 

Unclear process as DE 
OWF site must be 
included in central 
development plan in NL 
(National Water Plan) and 
in processes in DK, 
especially if both countries 
jointly pre-investigate the 
potential site 

Unclear timeline in NL 
(National Water Plan) and 
DK, expecting possible 
delays due to additional 
coordination between NL, 
DE and DK 

Clear process as OWF 
site is included in Spatial 
Grid Development Plan in 
DE by standard 
procedure, maybe even 
with lean processes under 
DE special tender process 
("Sonderausschreibung") 

Clear timeline as OWF 
site is included in central 
DE Spatial Development 
Plan for tender post-2030, 
but shorter timeline under 
DE special tender process 
("Sonderausschreibung") 
possible; leftover area 
then potentially tendered 
by 2023 

Costs are with OWF 
developer 

Clear process as no new 
process is necessary, but 
alignment with DE Spatial 
Development Plan 
required 

Unclear timeline as 
timeline is determined by 
OWF developer and 
alignment with DE Spatial 
Development Plan 
required 

 
 
 
 
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Option 1: Dutch and / or 
Danish responsibility 

Option 2: German 
responsibility 

Option 3: Responsibility 
of OWF developer 

Coordinated 
use of 
offshore areas 

Weakens coordinated use 
of limited offshore areas 
since shared responsibility 
of NL and DK potentially 
hinders effective usage 
(maximisation of societal 
benefits) of sites in DE  

Strengthens coordinated 
use of limited offshore 
areas, potentially 
maximising the societal 
benefit of overall wind 
potential in DE, and is 
most suitable as case site 
has already been pre-
investigated 

Summary 

Not covered in DE 
legislation and regulation, 
and unclear processes 
and timelines as 
coordination between NL / 
DK and DE needs to take 
place  

Covered in DE legislation 
and regulation, and clear 
processes and timelines in 
DE 

Weakens coordinated use 
of limited offshore areas 
since shared responsibility 
potentially hinders 
effective usage 
(maximisation of societal 
benefits) of sites; potential 
decrease in quality of 
investigation, as OWF 
developer fears sunk 
costs, and thus performs 
cost-efficient investigation 

Not covered in DE 
legislation and regulation, 
and unclear processes 
and timelines as additional 
alignment with DE Spatial 
Grid Development Plan 
required 

Table 32: COBRA Cable – Assessment of options for location selection and site pre-investigation 

In summary, the interaction with stakeholders shows that both options  – assigning responsibility to 
Dutch and / or Danish authorities (Option 1), assigning responsibility to German authorities (Option 
2) and assigning responsibility to OWF developer (Option 3) – have advantages and disadvantages. 
Both, Option 1 and 3, are not covered in German legislation and regulation in contrast to Option 2. 
Additionally, only Option 1 has a clear process and timeline whereas processes and timelines in are 
unclear due to additional alignment between the Netherlands and Denmark (Option 1) and alignment 
with the German Spatial Grid Development Plan (Option 3). 

Considering the results of the interaction with the stakeholders, the selection and / or implementation 
of the appropriate mitigation option for the COBRA Cable hybrid project must also take into account 
the interdependencies between the individual barriers. 

Tender responsible party 

This subtopic of the barrier is relevant for the COBRA Cable hybrid project. 

To address this barrier, three mitigation options are assessed with regard to their applicability (Table 
33) – excluding the implications of interdependencies with other barriers. 

▪  Option  1  "Dutch  and  /  or  Danish  responsibility":  The  Netherlands  (RVO)  or  Denmark  (DUR) 
execute  the  tender  for  the  OWF  site  in  the  German  EEZ  as  a  one-stop  shop  authority  either 
following Dutch or Danish tender process specifications or German tender process specifications. 

▪  Option 2 "German responsibility": Germany (BNetzA) executes the tender for the OWF site in the 
German EEZ as a one-stop shop authority following German tender process specifications based 
on the Spatial Grid Development Plan.  

 
 
 
 
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Option 1: Dutch and / or Danish 
responsibility 

Not covered by DE legislation and 
regulation 

Legal / 
regulatory 
coverage 

Option 2: German responsibility 

Covered in DE legislation and regulation 
but special provisions need to be made 
regarding the planned grid connection of 
the OWF 

Costs 

Costs are with NL / DK  

Costs are with DE  

Process 
efficiency 

Unclear process efficiency since it 
depends on familiarity of responsible 
party with the tender process (either 
Dutch, Danish or German) 

Public opinion  Negative, as public opinion in Germany 

Other 

can be opposed to surrendering 
sovereignty over the German EEZ  

Potential OWF site might already be 
part of the DE Spatial Grid Development 
Plan, if it is integral part of a larger OWF 
site or linked to other DE sites – unclear 
whether NL or DK can efficiently 
conduct tender of part of a larger site 
and / or is allowed to do so  

Efficient process since responsible party 
is familiar with tender process  

Positive, as public opinion in Germany 
in favour of maintaining sovereignty over 
the German EEZ 

As potential OWF site is a leftover area 
(part of a larger OWF site), it might 
already be included in DE Spatial Grid 
Development Plan and German process 
might apply 

Summary 

Not covered in DE legislation and 
regulation, unclear process efficiency 
and DE public opinion potentially 
opposed 

Covered in DE legislation and 
regulation, efficient process and DE 
public opinion in support  

Table 33: COBRA Cable – Assessment of options for tender responsible party 

In summary, the interaction with stakeholders shows both options  – assigning responsibility for the 
tender execution to Dutch and / or Danish authorities (Option 1) and German authorities (Option 2) – 
have advantages and disadvantages. Assigning responsibility to Dutch or Danish authorities (Option 
1) is not covered in German legislation and regulation, requires alignment and is not supported by the 
public. Assigning responsibility to German authorities (Option 2) is covered in German legislation and 
regulation, does not require alignment and is supported by the public. 

Considering the results of the interaction with the stakeholders, the selection and / or implementation 
of the appropriate mitigation option for the COBRA Cable hybrid project must also take into account 
the interdependencies between the individual barriers. 

5.4.7  Uncertainty about responsibility and rules to provide access to maritime 

space for OWFs (tender design) 

This barrier is relevant for the COBRA Cable hybrid project. 

To address this barrier, four mitigation options are assessed with regard to their applicability (Table 
34) – excluding the implications of interdependencies with other barriers. 

 
 
 
 
 
 
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▪  Option  1  "Strict  design  with  aligned  requirements  and  without  hybrid-specific  uncertainties":  A 
tender  design  with  strict  pre-qualification  requirements  implies  that  extensive  pre-qualification 
requirements  are  defined  to  ensure  hybrid-specific  and  general  capabilities  to  develop  the 
COBRA Cable hybrid project. The requirements are aligned among the Netherlands, Germany 
and Denmark, including a jointly agreed set of financial requirements and a certain set of both 
Dutch,  German  and  Danish  rules  related  to  the  OWF  site  (e.g.  environmental  details)  and  a 
certain set of both Dutch, German and Danish rules related to the grid connection of the OWF 
(e.g.  technical  and  operational  details  such  as  system  integration  or  frequency  control). 
Furthermore,  all  uncertainties  arising  from  the  hybrid  character  of  the  OWF  development  are 
clarified prior to the tender. 

▪  Option 2  "Strict design  with aligned requirements": A tender design  with strict  pre-qualification 
requirements implies that extensive pre-qualification requirements are defined to ensure hybrid-
specific and general capabilities to develop the COBRA Cable hybrid project. The requirements 
are  aligned  among  the  Netherlands,  Germany  and  Denmark,  including  a  jointly  agreed  set  of 
financial requirements and a certain set of both Dutch, German and Danish rules related to the 
OWF site (e.g. environmental details) and a certain set of both Dutch, German and Danish rules 
related to the grid connection of the OWF (e.g. technical and operational details such as system 
integration or frequency control).  

▪  Option  3:  "Strict  design  without  hybrid-specific  uncertainties":  A  tender  design  with  strict  pre-
qualification  requirements  implies  that  extensive  pre-qualification  requirements  are  defined  to 
ensure  hybrid-specific  and  general  capabilities  to  develop  the  COBRA  Cable  hybrid  project. 
Furthermore,  all  uncertainties  arising  from  the  hybrid  character  of  the  OWF  development  are 
clarified prior to the tender. 

▪  Option 4 "Lenient design with aligned requirements and without hybrid-specific uncertainties": A 
tender design with lenient pre-qualification requirements is chosen, implying that only limited pre-
qualification requirements are defined to ensure competition and low prices. The requirements 
are  aligned  among  the  Netherlands,  Germany  and  Denmark,  including  a  jointly  agreed  set  of 
financial requirements and a certain set of both Dutch, German and Danish rules related to the 
OWF site (e.g. environmental details) and a certain set of both Dutch, German and Danish rules 
related to the grid connection of the OWF (e.g. technical and operational details such as system 
integration or frequency control). Furthermore, all uncertainties arising from the hybrid character 
of the OWF development are clarified prior to the tender. 

 
 
 
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Legal / 
regulatory 
coverage 

Alignment of 
requirements 

Option 1: Strict 
design, aligned 
requirements and 
no uncertainties 

Option 2: Strict 
design and 
aligned 
requirements  

Not covered and 
potential 
amendments to 
national legislation 
and regulation 
necessary since 
multiple countries 
are involved in 
defining tender 
design 

Not covered and 
potential 
amendments to 
national legislation 
and regulation 
necessary since 
multiple countries 
are involved in 
defining tender 
design 

Financial 
requirements 
aligned; technical 
and operational 
requirements 
defined by the NL 
and DK; 
environmental 
requirements 
defined by DE 

Financial 
requirements 
aligned; technical 
and operational 
requirements 
defined by the NL 
and DK; 
environmental 
requirements 
defined by DE 

Option 3: Strict 
design and no 
uncertainties 

Covered and no 
amendments to 
national legislation 
and regulation 
necessary since 
only one country is 
involved in defining 
tender design 

No alignment of 
requirements 

Option 4: Lenient 
design, aligned 
requirements and 
no uncertainties 

Not covered and 
potential 
amendments to 
national legislation 
and regulation 
necessary since 
multiple countries 
are involved in 
defining tender 
design 

Financial 
requirements 
aligned; technical 
and operational 
requirements 
defined by the NL 
and DK; 
environmental 
requirements 
defined by DE 

Hybrid-
specific un-
certainties 

All uncertainties 
arising from hybrid-
specific setup are 
clarified, e.g. 
liability, applicable 
jurisdiction, grid 
connection 
responsibility, RES 
subsidy scheme 

Uncertainties 
arising from hybrid 
character of 
development not 
entirely clarified 
such that 
uncertainty remains 
for OWF developer 

All uncertainties 
arising from hybrid-
specific setup are 
clarified, e.g. 
liability, applicable 
jurisdiction, grid 
connection 
responsibility, RES 
subsidy scheme 

All uncertainties 
arising from hybrid-
specific setup are 
clarified, e.g. 
liability, applicable 
jurisdiction, grid 
connection 
responsibility, RES 
subsidy scheme 

 
 
 
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Realisation 
probability 

Option 1: Strict 
design, aligned 
requirements and 
no uncertainties 

Option 2: Strict 
design and 
aligned 
requirements  

Applying OWF 
developers are 
aware of all 
specifications and 
requirements and 
can align planning 
and financing right 
from the beginning 

Applying OWF 
developers are 
aware of all 
specifications and 
requirements and 
can align planning 
and financing right 
from the beginning  

Option 4: Lenient 
design, aligned 
requirements and 
no uncertainties 

Applying OWF 
developers are not 
aware of most 
specifications and 
requirements, 
which might result 
in significant cost 
overruns / delays 
after the tender 
process 

Option 3: Strict 
design and no 
uncertainties 

Applying OWF 
developers are 
aware of all 
specifications and 
requirements and 
can align planning 
and financing right 
from the beginning; 
however, it is 
questionable 
whether an OWF 
connected to two 
countries can be 
tendered without 
alignment of tender 
requirements 

Cost efficiency  Due to strict 

requirements and 
specifications, less 
developers 
expected to apply – 
cost efficiency of 
offers expected to 
decrease with 
fewer applicants 

Legal and 
regulatory 
coverage to be 
assessed and 
potentially 
decreases cost 
efficiency 

Summary 

Due to strict 
requirements and 
specifications, less 
developers 
expected to apply – 
cost efficiency of 
offers expected to 
decrease with 
fewer applicants 

Due to strict 
requirements and 
specifications, less 
developers 
expected to apply – 
cost efficiency of 
offers expected to 
decrease with 
fewer applicants 

Due to lenient 
requirements and 
specifications, 
many developers 
expected to apply – 
cost efficiency of 
offers expected to 
increase with more 
applicants 

Legal and 
regulatory 
coverage to be 
assessed and 
decreases cost 
efficiency, 
particularly due to 
remaining hybrid 
uncertainties 

Legal and 
regulatory 
coverage given, but 
with limited chance 
of realisation due to 
non-consideration 
of two countries' 
interest in defining 
tender 
requirements 

Legal and 
regulatory 
coverage to be 
assessed and 
strongly decreases 
probability of 
project realisation  

Table 34: COBRA Cable – Assessment of options for tender design 

In summary, the interaction with stakeholders shows that all four options – a strict or lenient tender 
design  with  aligned  requirements  and  certainty  about  hybrid-specific  characteristics  of  the  OWF 
development (Option 1 and 4), a strict tender design with aligned requirements (Option 3) as well as 
a  strict  tender  design  with  certainty  about  hybrid-specific  characteristics  of  the  OWF  development 
(Option  2)  –  have  advantages  and  disadvantages.  While  a  tender  design  with  strict  requirements 
(Options 1, 2 and 3) increases the probability of successful project implementation, a tender design 

 
 
 
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with  lenient  requirements  (Option  4)  decreases  the  cost  of  implementation  through  competition. 
Furthermore, certainty about hybrid-specific characteristics of  the OWF development (Options 1, 3 
and  4)  increases  the  probability  of  successful  project  implementation  and  decreases  the  cost  of 
implementation by reducing the risk premium otherwise demanded by OWF developers in terms of 
subsidies. Lastly, aligned requirements (Options 1, 2 and 4) aid in ensuring the interoperability of the 
OWF with the other assets of the hybrid project and thereby increase the probability of successful 
hybrid project implementation. 

Considering the results of the interaction with the stakeholders, the selection and / or implementation 
of the appropriate mitigation option for the COBRA Cable hybrid project must also take into account 
the interdependencies between the individual barriers. 

5.4.8  Discrepancies in responsibilities and requirements for balancing 

In  the  context  of  the  COBRA  Cable  hybrid  project,  there  is  no  discrepancy  in  the  applicability  of 
national balancing responsibility  and requirements in the shorter term. Since each generator must 
always be part of only one bidding  zone according to the existing CACM regulation and since the 
participation of one generator in different bidding zones at different times would be highly challenging 
for the operation of the entire energy system, an OWF physically connected to multiple bidding zones 
can only commercially feed its electricity into one bidding zone. Furthermore, the topic is addressed 
in  the  Clean  Energy  Package.  It  is  likely  that  no  further  barrier  mitigation  regarding  balancing 
responsibilities  and  requirements  is  needed  for  the  implementation  of  the  COBRA  Cable  hybrid 
project. However, in the longer term the translation into Dutch, German and Danish law needs to be 
assessed in detail by the project-specific stakeholders. 

5.4.9  Discrepancies in priority dispatch regulation and compensation 

In  the  context  of  the  COBRA  Cable  hybrid  project,  there  is  no  discrepancy  in  the  applicability  of 
national priority dispatch regulation. Since each generator must always be part of only one bidding 
zone  according  to  the  existing  CACM  regulation  and  since  the  participation  of  one  generator  in 
different bidding zones at different times would be highly challenging for the operation of the entire 
energy system, an OWF physically connected to multiple bidding zones can only commercially feed 
its electricity into one bidding zone. Furthermore, the topic is addressed in the Clean Energy Package. 
It is likely that no further barrier mitigation regarding priority dispatch regulation and compensation is 
needed for the implementation of the COBRA Cable hybrid project. However, in the longer term the 
translation into Dutch, German and Danish law needs to be assessed in detail by the project-specific 
stakeholders. 

5.4.10  Discrepancies in curtailment regulation and compensation 

In the context of COBRA Cable hybrid project, there is no discrepancy in the applicability of national 
curtailment  regulation  and  compensation.  Since  each  generator  must  always  be  part  of  only  one 
bidding zone according to the existing CACM regulation and since the participation of one generator 
in different bidding zones at different times would be highly challenging for the operation of the entire 
energy system, an OWF physically connected to multiple bidding zones can only commercially feed 
its electricity into one bidding zone. Furthermore, the topic is addressed in the Clean Energy Package. 
It  is  likely  that  no  further  barrier  mitigation  regarding  curtailment  regulation  and  compensation  is 
needed for the implementation of the COBRA Cable hybrid project. However, in the longer term the 
translation into Dutch, German and Danish law needs to be assessed in detail by the project-specific 
stakeholders. 

 
 
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5.4.11  Lack of regulated revenues for anticipatory investments 

This barrier is not relevant for the COBRA Cable hybrid project. 

In  the  context  of  the  COBRA  Cable  hybrid  project,  additional  anticipatory  investments  beyond  the 
EBRD funding to support a future OWF connection to it are not expected. 

5.4.12  Uncertainty about applicable RES subsidy scheme 

This barrier is relevant for the COBRA Cable hybrid project. 

To address this barrier, five mitigation options are assessed with regard to their applicability (Table 
35) – excluding the implications of interdependencies with other barriers. 

▪  Option 1 "Dutch subsidy scheme": According to EU Directive 2009/28/EC, the Dutch government 
can fund the German OWF included in the hybrid project with a premium tariff through the SDE+ 
scheme  (sliding  feed-in  premium),  potentially  with  statistical  transfers  between  the  involved 
countries. 

▪  Option 2 "German subsidy scheme": The German government awards the OWF included in the 
hybrid  project  a  premium  tariff  (sliding  feed-in  premium),  potentially  with  statistical  transfers 
between the involved countries. 

▪  Option  3  "Danish  subsidy  scheme":  According  to  EU  Directive  2009/28/EC,  the  Danish 
government  awards  the  OWF  included  in  the  hybrid  project  a  premium  tariff,  potentially  with 
statistical transfers between the involved countries. 

▪  Option  4  "Joint  project  between  the  Netherlands,  Germany  and  Denmark":  According  to  EU 
Directive 2009/28/EC Member States may co-fund an energy project that relates to the production 
of  electricity  from  renewable  energy  sources.  In  this  context,  a  joint  project  implies  that  the 
Netherlands, Germany and Denmark are financing parts of the hybrid project by applying their 
own national subsidy schemes. 

▪  Option 5 "No subsidy scheme": The OWF included in the COBRA Cable hybrid project is tendered 
without a subsidy scheme (i.e. comparable to zero-subsidy bids) and neither a subsidy scheme 
of the Netherlands, Germany nor Denmark nor a joint project is needed. 

 
 
 
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Option 1: 
Dutch 
subsidy 
scheme  

Option 2: 
German 
subsidy 
scheme  

Option 3: 
Danish 
subsidy 
scheme  

Legal / 
regulatory 
provisions 

Not covered by 
NL legal and 
regulatory 
regime as 
OWF is located 
in DE  

Not covered by 
DK legal and 
regulatory 
regime as 
OWF is located 
in DE 

Potentially 
covered by DE 
legal and 
regulatory 
regime but 
clarification 
required with 
regard to need 
for statistical 
transfers due 
to and 
applicability 
despite 
onshore 
connection 
points in the 
NL and DK 

Costs 

Costs borne 
only by the NL  

Costs borne 
only by DE  

Costs borne 
only by DK  

Mechanism 

Sliding feed-in 
premium 

Sliding feed-in 
premium 

Feed-in tariff 

Project 
bankability 

Bankability 
ensured 
through 
subsidy 
scheme 

Bankability 
ensured 
through 
subsidy 
scheme 

Bankability 
ensured 
through 
subsidy 
scheme 

Option 4: 
Joint project 
between NL, 
DE and DK  

Covered by EU 
Directive 
2009/28/EC on 
a European 
level but legally 
binding 
document 
between NL, 
DE and DK 
needs to be 
formulated to 
establish joint 
project 

Costs borne 
jointly by the 
NL, DE and DK 

Sliding feed-in 
premium in NL, 
DE and feed-in 
tariff in DK  

Bankability 
ensured 
through joint 
project 

Option 5: No 
subsidy 
scheme 

Covered in 
national legal 
and regulatory 
regime 

No costs must 
be borne by 
the NL, DE and 
DK 

No mechanism 
necessary 

Bankability of 
project 
depends on 
other offtake 
securities, 
such as long-
term power 
purchase 
agreements 

 
 
 
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Option 1: 
Dutch 
subsidy 
scheme  

Option 2: 
German 
subsidy 
scheme  

Option 3: 
Danish 
subsidy 
scheme  

Public opinion  Dutch public 

opinion can be 
opposed to 
funding DE 
OWF with NL 
public funds 

Danish public 
opinion can be 
opposed to 
funding DE 
OWF with DK 
public funds 

German public 
opinion can be 
opposed to 
funding DE 
OWF without 
DE connection 
with DE public 
funds 

Timeline 

Summary 

Uncertain 
timeline as 
OWF inclusion 
into NL 
National Water 
Plan necessary 
but process not 
established 

Not covered in 
NL legal and 
regulatory 
regime, 
bankability 
ensured but 
public opinion 
potentially 
opposed and 
uncertain 
timeline 

Uncertain 
timeline as 
OWF site is 
foreseen in DE 
central plans 
(leftover area) 
and potentially 
included in a 
special tender, 
but with 
unknown date 

Potentially 
covered in DE 
legal and 
regulatory 
regime, 
bankability 
ensured but 
public opinion 
potentially 
opposed and 
uncertain 
timeline 

Uncertain 
timeline as 
OWF inclusion 
into DK plans 
necessary but 
process not 
established 

Not covered in 
DK legal and 
regulatory 
regime, 
bankability 
ensured but 
public opinion 
potentially 
opposed and 
uncertain 
timeline 

Option 5: No 
subsidy 
scheme 

Public opinion 
neutral since 
no public funds 
used  

Uncertain 
timeline as 
OWF site is 
foreseen in DE 
central plans 
(leftover area) 
and potentially 
included in a 
special tender, 
but with 
unknown date 

Covered in 
national legal 
and regulatory 
regime but 
bankability only 
ensured with 
offtake 
securities and 
uncertain 
timeline 

Option 4: 
Joint project 
between NL, 
DE and DK  

Public opinion 
in NL, DE and 
DK can be 
opposed to 
funding RES 
generation 
potentially 
transmitted to 
other countries 
with public 
funds 

Uncertain 
timeline in DE 
as OWF site is 
foreseen in DE 
central plans 
(leftover area) 
but joint project 
must be 
established 

Covered in EU 
and national 
legal and 
regulatory 
regime with 
legal 
agreement 
required, 
bankability 
ensured but 
public opinion 
potentially 
opposed and 
uncertain 
timeline 

Table 35: COBRA Cable – Assessment of options for RES subsidy schemes 

In summary, the interaction with stakeholders shows that all five options – applying a Dutch (Option 
1), German (Option 2) or Danish subsidy scheme (Option 3) to the German OWF, establishing a joint 
project (Option 4) as well as tendering the OWF site without a subsidy scheme (i.e. comparable to 
zero-subsidy  bids) (Option  5)  – have advantages and disadvantages. While applying the Dutch or 

 
 
 
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Danish  subsidy  scheme  are  not  covered  under  the  respective  national  legislation  and  regulation, 
applying  the  German  subsidy  scheme  or  no  subsidy  scheme  are  (potentially)  covered.  For  the 
German subsidy scheme, it needs to be clarified whether statistical transfers between the involved 
countries are required. While the bankability of the OWF supported under Options 1 to 4 is given, the 
bankability of an OWF tendered without a subsidy scheme (Option 5) largely depends on the ability 
of the OWF developer to obtain offtake securities like power purchase agreements. Establishing a 
joint project between the Netherlands, Germany and Denmark is legally covered and provides the 
necessary bankability but might be problematic due to the extended timeline which is needed to agree 
the  specifications  of  the  scheme  and  to  formulate  a  legally  binding  document  between  the 
Netherlands, Germany and Denmark.  

Considering the results of the interaction with the stakeholders, the selection and / or implementation 
of the appropriate mitigation option for the COBRA Cable hybrid project must also take into account 
the interdependencies between the individual barriers. 

5.4.13  Limited engagement of public stakeholders 

The  barrier  "limited  engagement  of  public  stakeholders"  is  divided  into  two  subtopics,  formalised 
public support and financial support. The two subtopics are addressed individually in the following. 

Formalisation of commitment from public stakeholders  

To address this barrier, two mitigation options are assessed with regard to their applicability (Table 
36) – excluding the implications of interdependencies with other barriers. 

▪  Option  1  "Memorandum  of  Understanding  (MoU)":  A  Memorandum  of  Understanding  is  a 
formalisation of the goodwill of the involved parties in form of a non-binding agreement. An MoU 
addresses  barriers  by  formalising  the  agreements  of  the  involved  parties  with  regard  to  the 
implementation  of  required  actions  to  overcome  the  barriers.  It  can  involve  all  project 
stakeholders,  such  as  OWF  developers,  TSOs,  national  ministries  and  NRAs  as  well  as  the 
European Commission. 

▪  Option 2 "Hybrid Asset Network Support Agreement (HANSA)": A project-specific Hybrid Asset 
Network  Support  Agreement  is  a  legally-binding  commitment  to  adapt  national  legislation  and 
regulation in the future, and thus provides legal certainty to developers. European legislation and 
regulation can only be adapted via a project-specific HANSA if all Member States of the European 
Union  sign  the  agreement.  It  only  directly  involves  public  stakeholders,  such  as  national 
ministries. 

Option 1: Memorandum of 
Understanding (MoU) 

Option 2: Hybrid Asset Network 
Support Agreement (HANSA) 

Required effort  Some interaction and alignment 

required among project developers and 
stakeholders to facilitate signing of 
agreement 

Provided 
certainty 

Intentional character of signed 
agreement sufficient for hybrid projects 
in early development stage  

Significant interaction and alignment 
among political project stakeholders 
required to facilitate signing of 
agreement 

Legally binding commitment to topics 
covered by signed agreement directly 
facilitates project development, but is 
only required at a later development 
stage of hybrid projects 

 
 
 
 
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Option 1: Memorandum of 
Understanding (MoU) 

Option 2: Hybrid Asset Network 
Support Agreement (HANSA) 

Summary 

Reasonable effort to align agreement 
required prior to signing and non-legally 
binding commitment sufficient in early 
project development stages 

Significant effort for alignment of 
agreement required prior to signing but 
provides legal certainty and therefore 
suitable in later development stages 

Table 36: COBRA Cable – Assessment of options for formalisation of commitment from public stakeholders 

In  summary,  the  interaction  with  stakeholders  shows  that  both  options  –  a  project-specific 
Memorandum  of  Understanding  (Option  1)  and  a  project-specific  Hybrid  Asset  Network  Support 
Agreement (Option 2) – have advantages and disadvantages. While less effort is usually required to 
align  and  sign  a  project-specific  MoU,  an  MoU  is  not  legally  binding,  and  thus  the  commitment  of 
public stakeholders provides limited certainty, for example, about legal and regulatory changes for 
project developers (Option 1). However, while a project-specific HANSA provides legal certainty about 
the commitment of stakeholders to implement legal and regulatory changes, the alignment process 
requires more effort (Option 2).  

Considering the results of the interaction with the stakeholders, the selection and / or implementation 
of the appropriate mitigation option for the COBRA Cable hybrid project must also take into account 
the interdependencies between the individual barriers as well as the development stage of the hybrid 
project. 

 Financial support 

This subtopic of the barrier is relevant for the COBRA Cable hybrid project. 

In  summary,  the  interaction  with  stakeholders  shows  that  there  is  no  specific,  tangible  mitigation 
option  to  address  the  barrier  of  limited  financial  support,  but  rather  that  a  portfolio  of  support 
programmes is available and their usage needs to be increased to facilitate the implementation of 
hybrid projects. In the past, hybrid project development and / or considerations, such as the Combined 
Grid Solution Kriegers Flak in the Baltic Sea and the Interconnector tie-in COBRA Cable in the North 
Sea,  indicate  that  such  support  is  required  to  de-risk  and  thereby  allow  for  the  realisation  of  pilot 
projects. In this context, financial support can come in various forms, such as co-financing for early-
stage feasibility studies, scoping studies or R&D, co-financing of development and construction or 
guarantees  for  the  operational  phase.  Generally,  financial  support  programmes  are  available  on 
national and European level and should be as specifically targeted at hybrid projects as possible. The 
target is to increase the awareness for and the usage of existing financial support programmes and 
thereby foster the development of hybrid projects. 

Considering the results of the interaction with the stakeholders, the mitigation of this barrier for the 
COBRA  Cable  hybrid  project  must  also  take  into  account  the  interdependencies  between  the 
individual barriers. 

5.4.14  Uncertainty regarding the UK market 

The barrier "uncertainty regarding the UK market" is divided into two subtopics, UK Capacity Market 
and UK Cap and Floor regime as well as EU internal energy market. The two subtopics are addressed 
individually in the following. 

UK Capacity Market and Cap and Floor regime 

This subtopic of the barrier is not relevant for the COBRA Cable hybrid project. 

 
 
 
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In the context  of the COBRA Cable hybrid project, no commercial nor public UK stakeholders are 
involved. Thus, there is no uncertainty regarding the UK Capacity Market and Cap and Floor regime 
for the specific hybrid project idea. 

EU internal energy market 

This subtopic of the barrier is not relevant for the COBRA Cable hybrid project. 

In the context  of the COBRA Cable hybrid project, no commercial nor public UK stakeholders are 
involved. Thus, there is no uncertainty regarding the participation in the EU internal energy market 
for the specific hybrid project idea. 

5.4.15  Disproportionate allocation of costs and benefits across involved 

stakeholders 

This barrier is relevant for the COBRA Cable hybrid project. 

In  summary,  the  interaction  with  stakeholders  shows  that  there  is  no  specific,  tangible  mitigation 
option  to  address  the  barrier  of  disproportionate  allocation  of  costs  and  benefits  across  involved 
stakeholders,  but  rather  that  a  process  towards  the  mitigation  of  the  barrier  must  be  followed. 
Generally, the process consists of the identification and alignment of cost and benefit categories, the 
determination of the initial allocation of costs and benefits, the agreement on a re-allocation of costs 
and benefits as well as – if required and available – the usage of CEF funding to ensure the individual 
incentivisation of all stakeholders. This can build on the existing process for Cost Benefit Analyses 
(CBA) and Cross-Border Cost Allocations (CBCA) as defined by ENTSO-E for cross-border electricity 
interconnectors, which needs to be adjusted according to the specifications of each individual hybrid 
project. The process should allow for the incentivisation of all relevant stakeholders to implement the 
hybrid project. 

Considering the results of the interaction with the stakeholders, the mitigation process to be followed 
for the COBRA Cable hybrid project must also take into account the interdependencies between the 
individual barriers. 

5.4.16  Uncertainty about legislative regime for power-to-gas and related 

infrastructure  

This barrier is not relevant for the COBRA Cable hybrid project. 

In  the  context  of  the  COBRA  Cable  hybrid  project,  it  is  currently  not  planned  to  include  power 
conversion to gas and / or gas transmission solutions. Thus, there is no need for and consequently 
no uncertainty regarding the legislative regime for power conversion to gas and gas transmission for 
the specific hybrid project idea. 

5.5  DE OWF to NL 

Throughout  stakeholder  interaction,  12  out  of  16  barriers  are  identified  to  be  relevant  for  the 
implementation  of  the  DE  OWF  to  NL  hybrid  project  idea.  The  results  of  the  interaction  with 
stakeholders with regard to all barriers – relevant and not relevant – are summarised in the ensuing 
subchapters.  

5.5.1  Discrepancies in national grid connection responsibility 

The barrier "uncertainty about responsibility for project development" is divided into three subtopics, 
grid  connection  responsibility,  responsibility  for  the  development  and  construction  of  the 

 
 
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interconnector  and  responsibility  for  the  operation  of  the  interconnector.  The  three  subtopics  are 
addressed individually in the following. 

Grid connection responsibility 

This subtopic of the barrier is relevant for the DE OWF to NL hybrid project. 

To address this barrier, three mitigation options are assessed with regard to their applicability (Table 
37) – excluding the implications of interdependencies with other barriers.  

▪  Option 1 "TenneT TSO B.V. is responsible": The Dutch TSO, TenneT TSO B.V., is responsible 

for the connection of the German OWF to the Dutch onshore grid. 

▪  Option  2  "TenneT  TSO  GmbH  is  responsible":  The  German  TSO,  TenneT  TSO  GmbH,  is 

responsible for the connection of the German OWF to the Dutch onshore grid. 

▪  Option 3 "TenneT TSO B.V. and TenneT TSO GmbH are responsible": The Dutch TSO, TenneT 
TSO B.V., and the German TSO, TenneT TSO GmbH, are jointly responsible for the connection 
of the German OWF to the Dutch onshore grid. 

Legal / 
regulatory 
coverage 

Option 1: TenneT TSO 
B.V. is responsible 

Option 2: TenneT TSO 
GmbH is responsible 

Not covered in NL (OWF 
location defines 
responsibility) as well as 
DE legislation and 
regulation (OWF location 
and onshore connection 
point define responsibility) 
– EU network codes, such 
as "HVDC Connections" 
and "Requirements for 
generators", support 
technical standardisation 

Not covered in DE 
legislation and regulation 
(OWF location and 
onshore connection point 
define responsibility) – EU 
network codes, such as 
"HVDC Connections" and 
"Requirements for 
generators", support 
technical standardisation 

Option 3: TenneT TSO 
B.V. and TenneT TSO 
GmbH are responsible  

Not covered in NL (OWF 
location defines 
responsibility) as well as 
DE legislation and 
regulation (OWF location 
and onshore connection 
point define responsibility) 
– EU network codes, such 
as "HVDC Connections" 
and "Requirements for 
generators", support 
technical standardisation 

Costs 

Costs are with NL, 
including liability for grid 
connection delay or 
unavailability of grid  

Costs are with DE, 
including liability for grid 
connection delay or 
unavailability of grid 

Costs are with NL and DE, 
including liability for grid 
connection delay or 
unavailability of grid 

Financial risk 

Financial risk in case of 
delay or failure of grid 
connection is with TenneT 
TSO B.V., and thus with 
the NL, therefore no risk 
towards project realisation 

Financial risk in case of 
delay or failure of grid 
connection is with TenneT 
TSO GmbH, and thus with 
DE, therefore no risk 
towards project realisation  

Financial risk in case of 
delay or failure of grid 
connection is with TenneT 
TSO B.V. and TenneT 
TSO GmbH, and thus with 
the NL and DE, therefore 
no risk towards project 
realisation  

 
 
 
 
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Development 
risk 

Operational 
risk 

Market-specific 
expertise 

Option 1: TenneT TSO 
B.V. is responsible 

Option 2: TenneT TSO 
GmbH is responsible 

Alignment of development 
not needed for a single 
developer and also not 
across parts of entire 
cable system due to 
congruent responsibilities, 
therefore low risk towards 
project realisation 

Alignment of operations 
not needed for a single 
developer and also not 
across parts of entire 
cable system due to 
congruent responsibilities, 
therefore low risk towards 
project realisation 

Alignment of development 
not needed for a single 
developer but across parts 
of entire cable system due 
to differing responsibilities, 
therefore uncertain risk 
towards project realisation 

Alignment of operations 
not needed for a single 
developer but across parts 
of entire cable system due 
to differing responsibilities, 
therefore uncertain risk 
towards project realisation 

Knowledge on general 
and project-specific grid 
connection and 
operational requirements 
partially given for TenneT 
TSO B.V. in the NL 

Knowledge on general 
and project-specific grid 
connection and 
operational requirements 
partially given for TenneT 
TSO GmbH in DE 

Option 3: TenneT TSO 
B.V. and TenneT TSO 
GmbH are responsible  

Alignment of development 
needed for multiple 
developers and 
additionally across parts 
of entire cable system due 
to differing responsibilities, 
therefore uncertain risk 
towards project realisation 

Alignment of operations 
needed for multiple 
developers and 
additionally across parts 
of entire cable system due 
to differing responsibilities, 
therefore uncertain risk 
towards project realisation 

Knowledge on general 
and project-specific grid 
connection and 
operational requirements 
given for TenneT TSO 
B.V. and TenneT TSO 
GmbH in the NL and DE, 
respectively 

Risk for OWF 
developer 

No financial risk for OWF 
in case of delays or failure 
in grid connection, as 
compensation is 
guaranteed by regulation 
in the NL  

No financial risk for OWF 
in case of delays or failure 
in grid connection, as 
compensation is 
guaranteed by regulation 
in the DE  

No financial risk for OWF 
in case of delays or failure 
in grid connection, as 
compensation is 
guaranteed by regulation 
in the NL and DE 

First 
connection 
charges and 
G-charges 

Summary 

Shallow first connection 
charges and no G-
charges in the NL and 
shallow to super-shallow 
first connection charges 
and no G-charges in DE 

Shallow first connection 
charges and no G-
charges in the NL and 
shallow to super-shallow 
first connection charges 
and no G-charges in DE 

Shallow first connection 
charges and no G-
charges in the NL and 
shallow to super-shallow 
first connection charges 
and no G-charges in DE 

Not covered under NL and 
DE legal and regulatory 
regime, but with low risk 
towards project realisation 

Not covered under DE 
legal and regulatory 
regime and with uncertain 
risk towards project 
realisation 

Not covered under NL and 
DE legal and regulatory 
regime and with uncertain 
risk towards project 
realisation 

Table 37: DE OWF to NL – Assessment of options for grid connection responsibility 

 
 
 
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In  summary,  the  interaction  with  stakeholders  shows  that  all  three  options  –  to  allocate  the 
responsibility to TenneT TSO B.V. (Option 1),  to TenneT TSO GmbH (Option 2) as well  as to the 
consortium  of  TenneT  TSO  B.V.  and  TenneT  TSO  GmbH  (Option  3)  –  have  advantages  and 
disadvantages. However, the allocation of responsibility to the Dutch (Option 1) and German entity 
(Option 2) as well as to the Dutch and German entities together (Option 3) still require clarification 
regarding the legal and regulatory coverage. The risk towards project realisation is low for Option 1 
but uncertain for Options 2 and 3. Furthermore, the inclusion of the relevant TSOs in Option 3 ensures 
required market-specific expertise, in contrast to Options 1  and 2. However, all  options  insure  the 
OWF developer in case of a delay or a failure of its grid connection. 

Considering the results of the interaction with the stakeholders, the selection and / or implementation 
of the appropriate mitigation option for the DE OWF to NL hybrid project must also take into account 
the interdependencies between the individual barriers. 

Responsibility for development and construction of interconnector 

This subtopic of the barrier is not relevant for the DE OWF to NL hybrid project. 

Due  to  the  radial  connection  of  the  German  OWF  to  the  Dutch  onshore  grid,  no  interconnector  is 
included in the hybrid project. 

Responsibility for operation of interconnector 

This subtopic of the barrier is not relevant for the DE OWF to NL hybrid project. 

Due  to  the  radial  connection  of  the  German  OWF  to  the  Dutch  onshore  grid,  no  interconnector  is 
included in the hybrid project. 

5.5.2  Uncertainty about regulation deriving from jurisdiction over cross-border 

cable systems 

This barrier is relevant for the DE OWF to NL hybrid project. 

To address this barrier, two mitigation options are assessed with regard to their applicability (Table 
38)  –  excluding  the  implications  of  interdependencies  with  other  barriers.  The  assessment 
concentrates on the jurisdiction applicable to the export cable system. The OWF underlies German 
jurisdiction in line with the installation exploiting wind as a natural resource within the German EEZ. 

▪  Option 1 "Dutch jurisdiction's regulations": In addition to European law, Dutch jurisdiction applies 
to the export cable system from the OWF to the Dutch onshore connection point, thus including 
the part of the cable system geographically located in the German EEZ. 

▪  Option  2  "German  jurisdiction's  regulations":  In  addition  to  European  law,  German  jurisdiction 
applies to the export cable system from the OWF to the Dutch onshore connection point, thus 
including the part of the cable system geographically located in the Dutch EEZ and territorial sea. 

▪  Option 3 "Alignment of jurisdictions' regulations": Based on negotiations between the Netherlands 
and Germany, a new combination of regulations applies to the export cable system from the OWF 
to the Dutch onshore connection point  – in addition to European law. The new combination of 
regulations  over  the  cable  systems  can  potentially  be  based  on  existing  interconnector 
agreements. 

 
 
 
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Rights and 
duties in DE 
EEZ during 
operation 

Rights and 
duties in NL 
EEZ during 
operation 

Rights and 
duties in NL 
territorial sea / 
onshore 
during 
operation 

Hybrid project 
requirements 

Timeline 

Other 

Summary 

Option 1: Dutch 
jurisdiction's 
regulations 

Option 2: German 
jurisdiction's 
regulations 

Uncertainty and thus 
alignment required since 
neither country has clear 
jurisdiction since cable 
crosses NL territorial sea 
but also serves 
exploitation of the DE 
EEZ 

Uncertainty and thus 
alignment required since 
neither country has clear 
jurisdiction since cable 
crosses NL territorial sea 
but also serves 
exploitation of the DE 
EEZ 

Uncertainty and thus 
alignment required since 
neither country has clear 
jurisdiction since cable 
crosses NL territorial sea 
but also serves 
exploitation of the DE 
EEZ 

Uncertainty and thus 
alignment required since 
neither country has clear 
jurisdiction since cable 
crosses NL territorial sea 
but also serves 
exploitation of the DE 
EEZ 

No uncertainty since the 
NL has jurisdiction and NL 
operational rules apply 
since cable crosses NL 
territorial sea  

Uncertainty and thus 
alignment required since 
the NL has jurisdiction 
and NL operational rules 
apply since cable crosses 
NL territorial sea  

Alignment of operational 
rules between the NL and 
DE required because of 
connection of DE OWF to 
the Dutch market via an 
export cable system  

Alignment of operational 
rules between the NL and 
DE required because of 
connection of DE OWF to 
the Dutch market via an 
export cable system 

Option 3: Alignment of 
jurisdictions' 
regulations, based on 
existing IC agreement 

Alignment required to 
combine operational rules 
deriving from jurisdictions 
of the NL and DE for DE 
EEZ through 
involvement of the NL and 
DE 

Alignment required to 
combine operational rules 
deriving from jurisdictions 
of the NL and DE for NL 
EEZ through 
involvement of the NL and 
DE 

Alignment required to 
combine operational rules 
deriving from jurisdictions 
of the NL and DE for NL 
territorial sea through 
involvement of the NL and 
DE 

No additional alignment of 
operational rules required  

Alignment may extend 
timeline of project 

Alignment may extend 
timeline of project 

Alignment may extend 
timeline of project 

Uncertainty and thus 
alignment required to 
ensure applicability of 
Option 1 since no clear 
rules apply in the NL and 
DE EEZs 

Uncertainty and thus 
alignment required to 
ensure applicability of 
Option 2 since no clear 
rules apply in the NL and 
DE EEZs 

Provisions for assigning 
liability in case of grid 
connection failure need to 
be implemented 

Alignment required to 
ensure applicability of 
Option 3 since no clear 
rules apply in the NL and 
DE EEZs 

 
 
 
 
 
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Table 38: DE OWF to NL – Assessment of options for regulation deriving from jurisdiction deriving from cross-
border cable systems 

In summary, the interaction with stakeholders shows that all three options  – the agreement on the 
applicability of operational rules to the export cable system based on German (Option 1) or Dutch 
jurisdiction (Option 2) as well as the alignment of regulations deriving from the Dutch and German 
jurisdiction (Option 3) – have advantages and disadvantages. While chances of an agreement among 
the Netherlands and Germany on a single jurisdiction are limited, the alignment of regulations deriving 
from two jurisdictions can be a lengthy process. Yet, Option 3 reflects the interest of both countries in 
the alignment and can potentially build on existing agreements established for the interconnectors 
between the Netherlands and Germany. 

Considering the results of the interaction with the stakeholders, the selection and / or implementation 
of the appropriate mitigation option for the DE OWF to NL hybrid project must also take into account 
the interdependencies between the individual barriers. 

5.5.3  Uncertainty about market arrangements 

This barrier is relevant for the DE OWF to NL hybrid project. 

To address this barrier, five mitigation options are assessed with regard to their applicability (Table 
39) – excluding the implications of interdependencies with other barriers. 

▪  Option 1 "Commercial flows to the Dutch market": With commercial flows to the Netherlands, the 
German OWF is always commercially evacuating its electricity to the Dutch market, and thus into 
the bidding zone to which the OWF is physically connected. 

▪  Option 2 "Commercial (virtual) flows to home market": With commercial (virtual) flows to its home 
market, this is, Germany, the German OWF always transmits its electricity commercially to the 
German market, and thus into the bidding zone in which the OWF is physically located.  

▪  Option 3 "Dynamic flows to high-price market": With a dynamic flow to the high-price market, the 
German  OWF  always  commercially  transmits  its  electricity  to  the  higher-price  market  of  the 
Netherlands and Germany.  

Option 1: Commercial 
flows to the Dutch 
market 

Option 2: Fixed (virtual) 
access to home market 

Option 3: Dynamic flows 
to high-price market 

Legal / 
regulatory 
coverage 

Not covered under 
existing market regulation 

Not covered under 
existing market regulation  

Not covered under 
existing market regulation, 
particularly in violation of 
CACM requirement of 
stability of bidding zones 
across market time 
frames 

 
 
 
 
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Option 1: Commercial 
flows to the Dutch 
market 

Option 2: Fixed (virtual) 
access to home market 

Option 3: Dynamic flows 
to high-price market 

Price 
determination 

Dutch market price 
applies 

Home market price 
applies  

Price effects 

Effect of decreasing 
prices in NL as OWF 
produces at close to zero 
marginal costs 

Effect of decreasing 
prices in home market, as 
OWF produces at close to 
zero marginal costs  

Price 
discrimination 
of OWFs 

Discriminatory against 
hybrid OWF if DE market 
price is higher than NL 
market price, which it 
receives 

Not discriminatory against 
any OWF as hybrid OWF 
and other OWFs in DE 
bidding zone receive 
same prices 

Price determination 
problematic when 
transmission of generated 
electricity to high-price 
market not possible 
(limited capacity) – 
alternative price 
determination needed 

Effect of decreasing 
prices in the high-price 
market, as OWF produces 
at close to zero marginal 
costs 

Discriminatory against 
any other OWF in the DE 
bidding zones, as hybrid 
OWF always receives 
high price of NL or DE 
market 

Compensation  Negative business case 

implications for hybrid 
OWF from price 
discrimination, and thus 
additional compensation 
necessary 

No business case 
implications for hybrid 
OWF, and thus no 
additional compensation 
necessary 

No business case 
implications for hybrid 
OWF, and thus no 
additional compensation 
necessary 

Outages 

No backup cable system 
available 

No backup cable system 
available 

No backup cable system 
available 

Summary 

Legal and regulatory 
coverage not given, 
discriminatory against 
hybrid OWF and negative 
business case 
implications for OWF from 
price discrimination 

Legal and regulatory 
coverage not given, not 
discriminatory against any 
OWF and no negative 
business case 
implications for OWF 

Legal and regulatory 
coverage not given, 
discriminatory against 
other OWFs and no 
negative business case 
implications for OWF 

Table 39: DE OWF to NL – Assessment of options for market arrangements 

In  summary,  the  interaction  with  stakeholders  shows  that  all  three  options  –  the  OWF  always 
commercially evacuating electricity to the Dutch market (Option 1) or to the German market (Option 
2)  as  well  as  the  OWF  commercially  evacuating  electricity  to  the  higher-price  market  of  the 
Netherlands and Germany (Option 3) – have advantages and disadvantages. Legal and regulatory 
coverage  is  not  given  for  all  options,  with  Option  3  violating  the  European  CACM  requirement  of 
stability of bidding zones across market time frames. In case of commercial (virtual) flows to Germany 

 
 
 
 
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(Options 2 and 3) there may be a need for onshore grid reinforcements. Furthermore, due to negative 
business  case  implications  from  price  discrimination  in  Option  1,  additional  compensation  for  the 
hybrid OWF is required. 

Considering the results of the interaction with the stakeholders, the selection and / or implementation 
of the appropriate mitigation option for the DE OWF to NL hybrid project must also take into account 
the interdependencies between the individual barriers. 

5.5.4  Uncertainty about hybrid cable system classification 

This barrier is not relevant for the DE OWF to NL hybrid project. 

In the context of the DE OWF to NL hybrid project, the included cable system has no interconnector 
functionality. Thus, the cable system only serves one distinct and legally defined function, which is 
providing for the  transmission  of electricity generated  by the OWF in the hybrid  setup to shore. In 
consequence, there is a definition and applicable rules for the cable system under national and EU 
law. 

5.5.5 

Failure of developers to align planning across assets and countries 

The barrier "failure of developers to align planning across assets and countries" is divided into three 
subtopics, geographical alignment, technical alignment and timing alignment. The three subtopics are 
addressed individually in the following. 

Geographical alignment 

This subtopic of the barrier is relevant for the DE OWF to NL hybrid project. 

In  summary,  the  interaction  with  stakeholders  shows  that  there  is  no  specific,  tangible  mitigation 
option to address the barrier of failed geographical alignment across assets and countries, but rather 
that a process towards the mitigation of the barrier must be followed. The process consists of the 
continuous  exchange  between  project  developers  and  other  stakeholders  to  allow  for  the 
achievement of early-stage, geographical alignment. 

Considering the results of the interaction with the stakeholders, the mitigation process to be followed 
for the DE OWF to NL hybrid project must also take into account the interdependencies between the 
individual barriers. 

Technical alignment 

This subtopic of the barrier is relevant for the DE OWF to NL hybrid project. 

In  summary,  the  interaction  with  stakeholders  shows  that  there  is  no  specific,  tangible  mitigation 
option to address the barrier of failed technical alignment across assets and countries, but rather that 
a  process  towards  the  mitigation  of  the  barrier  must  be  followed.  The  process  consists  of  the 
continuous  exchange  between  project  developers  and  other  stakeholders  to  allow  for  the 
achievement of early-stage, technical alignment. 

Considering the results of the interaction with the stakeholders, the selection and / or implementation 
of the appropriate mitigation option for the DE OWF to NL hybrid project must also take into account 
the interdependencies between the individual barriers. 

 Timing alignment 

This subtopic of the barrier is relevant for the DE OWF to NL hybrid project. 

 
 
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In  summary,  the  interaction  with  stakeholders  shows  that  there  is  no  specific,  tangible  mitigation 
option to address the barrier of failed timing alignment across assets and countries, but rather that a 
process towards the mitigation of the barrier must be followed. The process consists of the continuous 
exchange between project developers and other stakeholders to allow for the achievement of early-
stage, timing alignment.  

Considering the results of the interaction with the stakeholders, the selection and / or implementation 
of the appropriate mitigation option for the DE OWF to NL hybrid project must also take into account 
the interdependencies between the individual barriers. 

5.5.6  Uncertainty about responsibility and rules to provide access to maritime 

space for OWFs (location selection, site pre-investigation and tender 
execution)  

The barrier "uncertainty about responsibility and rules to provide access to maritime space for OWFs 
(location selection, site pre-investigation and tender execution)" is divided into two subtopics, location 
selection and site  pre-investigation as  well as tender  execution. The two subtopics are addressed 
individually in the following. 

Location selection and site pre-investigation 

This subtopic of the barrier is relevant for the DE OWF to NL hybrid project. 

To address this barrier, three mitigation options are assessed with regard to their applicability (Table 
40) – excluding the implications of interdependencies with other barriers.  

▪  Option  1  "Dutch  responsibility":  The  Netherlands  conduct  the  location  selection  and  site  pre-
investigation  for  the  OWF  site  in  the  German  EEZ  as  part  of  the  centrally  organised  pre-
investigation based on the National Water Plan, following standardised national processes and 
timelines. Site decisions determine where OWF development can take place.  

▪  Option  2  "German  responsibility":  Germany  conducts  the  location  selection  and  site  pre-
investigation  for  the  OWF  site  in  the  German  EEZ  as  part  of  the  centrally  organised  pre-
investigation  based  on  the  Spatial  Grid  Development  Plan,  following  standardised  national 
processes and timelines. Site decisions determine where OWF development can take place. 

▪  Option  3  "Responsibility  of  OWF  developer":  The  potential  OWF  developer  conducts  location 
selection and site pre-investigation for the OWF site in the German EEZ within the context of an 
open-door  approach.  Following  the  final  site  decision  by  the  potential  OWF  developer,  the 
candidate applies for the necessary licenses to develop the OWF based on the results of the pre-
investigation. The extent to which a government shapes and controls the investigations that are 
part of the open-door process by specific regulatory requirements that must be met varies across 
the Netherlands and Germany. 

 
 
 
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Option 1: Dutch 
responsibility 

Option 2: German 
responsibility 

Legal / 
regulatory 
coverage 

Not covered by DE 
legislation and regulation 

Covered by DE 
legislation and 
regulation, can 
potentially become part 
of special tender process 
("Sonderausschreibung") 

Costs 

Costs are with NL  

Costs are with DE 

Process 

Unclear process as DE 
OWF site must be 
included in central 
development plan in NL 
(National Water Plan)  

Timeline 

Unclear timeline in NL 
(National Water Plan), 
expecting possible 
delays due to additional 
coordination between NL 
and DE 

Coordinated 
use of 
offshore areas 

Weakens coordinated 
use of limited offshore 
areas since responsibility 
of NL potentially hinders 
effective usage 
(maximisation of societal 
benefits) of sites in DE 

Clear process as OWF 
site is included in Spatial 
Grid Development Plan 
in DE by standard 
procedure, maybe even 
with lean processes 
under DE special tender 
process 
("Sonderausschreibung") 

Clear timeline as OWF 
site is included in central 
DE Spatial Development 
Plan for tender post-
2030, but shorter 
timeline under DE 
special tender process 
("Sonderausschreibung") 
possible; leftover area 
then potentially tendered 
by 2023 

Strengthens coordinated 
use of limited offshore 
areas, potentially 
maximising the societal 
benefit of overall wind 
potential in DE, and is 
most suitable as case 
site has already been 
pre-investigated 

Option 3: 
Responsibility of OWF 
developer 

Not covered by DE 
legislation and regulation 

Costs are with OWF 
developer 

Clear process as no new 
process is necessary, 
but alignment with DE 
Spatial Development 
Plan required 

Unclear timeline as 
timeline is determined by 
OWF developer and 
alignment with DE 
Spatial Development 
Plan required 

Weakens coordinated 
use of limited offshore 
areas since shared 
responsibility potentially 
hinders effective usage 
(maximisation of societal 
benefits) of sites; 
potential decrease in 
quality of investigation, 
as OWF developer fears 
sunk costs, and thus 
performs cost-efficient 
investigation 

 
 
 
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Summary 

Option 1: Dutch 
responsibility 

Option 2: German 
responsibility 

Not covered in DE 
legislation and 
regulation, and unclear 
processes and timelines 
as coordination between 
NL and DE needs to take 
place  

Covered in DE legislation 
and regulation, and clear 
processes and timelines 
in DE 

Option 3: 
Responsibility of OWF 
developer 

Not covered in DE 
legislation and 
regulation, and unclear 
processes and timelines 
as additional alignment 
with DE Spatial Grid 
Development Plan 
required 

Table 40: DE OWF to NL – Assessment of options for location selection and site pre-investigation 

In summary, the interaction with stakeholders shows that both options  – assigning responsibility to 
Dutch authorities (Option 1), assigning responsibility to German authorities (Option 2) and assigning 
responsibility to OWF developer (Option 3)  – have advantages and disadvantages. Both, Option 1 
and 3, are not covered in German legislation and regulation in contrast to Option 2. Additionally, only 
Option 1 has a clear process and timeline whereas processes and timelines in are unclear due to 
additional alignment between the Netherlands (Option 1) and alignment with the German Spatial Grid 
Development Plan (Option 3). 

Considering the results of the interaction with the stakeholders, the selection and / or implementation 
of the appropriate mitigation option for the DE OWF to NL Cable hybrid project must also take into 
account the interdependencies between the individual barriers. 

Tender responsible party 

This subtopic of the barrier is relevant for the DE OWF to NL hybrid project. 

To address this barrier, three mitigation options are assessed with regard to their applicability (Table 
41) – excluding the implications of interdependencies with other barriers.  

▪  Option 1 "Dutch responsibility": The Netherlands (RVO) conducts the tender execution for the 
OWF site in the German EEZ as one-stop shop authority following either Dutch tender process 
specifications  or  German  tender  process  specifications.  All  costs  of  the  tender  execution  are 
borne by the Dutch government. 

▪  Option 2 "German responsibility": Germany (BNetzA) conducts the tender execution for the OWF 
site  in  the  German  EEZ  as  one-stop  shop  authority  following  German  tender  process 
specifications based on the Spatial Grid Development Plan.  

Option 1: Dutch responsibility 

Option 2: German responsibility 

Legal / 
regulatory 
coverage 

Not covered by DE legislation and 
regulation 

Covered in DE legislation and regulation 
but special provisions need to be made 
regarding the planned grid connection of 
the OWF 

Costs 

Costs are with NL  

Costs are with DE  

 
 
 
 
 
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Option 1: Dutch responsibility 

Option 2: German responsibility 

Process 
efficiency 

Unclear process efficiency since it 
depends on familiarity of responsible 
party with the tender process (either 
Dutch or German) 

Public opinion  Negative, as public opinion in Germany 

Other 

can be opposed to surrendering 
sovereignty over the German EEZ  

Potential OWF site might already be 
part of the DE Spatial Grid Development 
Plan, if it is integral part of a larger OWF 
site or linked to other DE sites – unclear 
whether NL can efficiently conduct 
tender of part of a larger site and / or is 
allowed to do so  

Efficient process since responsible party 
is familiar with tender process  

Positive, as public opinion in Germany 
in favour of maintaining sovereignty over 
the German EEZ 

As potential OWF site is a leftover area 
(part of a larger OWF site), it might 
already be included in DE Spatial Grid 
Development Plan and German process 
might apply 

Summary 

Not covered in DE legislation and 
regulation, unclear process efficiency 
and DE public opinion potentially 
opposed 

Covered in DE legislation and 
regulation, efficient process and DE 
public opinion in support  

Table 41: DE OWF to NL – Assessment of options for tender responsible party 

In summary, the interaction with stakeholders shows both options  – assigning responsibility for the 
tender execution to Dutch authorities (Option 1) and German authorities (Option 2) – have advantages 
and disadvantages. Assigning responsibility to Dutch authorities (Option 1) is not covered in German 
legislation  and  regulation,  requires  alignment  and  is  not  supported  by  the  public.  Assigning 
responsibility to German authorities (Option 2) is covered in German legislation and regulation, does 
not require alignment and is supported by the public. 

Considering the results of the interaction with the stakeholders, the selection and / or implementation 
of the appropriate mitigation option for the DE OWF to NL hybrid project must also take into account 
the interdependencies between the individual barriers. 

5.5.7  Uncertainty about responsibility and rules to provide access to maritime 

space for OWFs (tender design) 

This barrier is relevant for the DE OWF to NL hybrid project. 

To address this barrier, four mitigation options are assessed with regard to their applicability (Table 
42) – excluding the implications of interdependencies with other barriers. 

▪  Option  1  "Strict  design  with  aligned  requirements  and  without  hybrid-specific  uncertainties":  A 
tender  design  with  strict  pre-qualification  requirements  implies  that  extensive  pre-qualification 
requirements are  defined to ensure hybrid-specific and general capabilities to develop the DE 
OWF to NL hybrid project. The requirements are aligned among the Netherlands and Germany, 
including a jointly agreed set of financial requirements and a certain set of both Dutch and German 
rules related to the OWF site (e.g. environmental  details) and a certain set of both Dutch and 
German rules related to the grid connection of the OWF (e.g. technical and operational details 
such as system integration or frequency control). Furthermore, all uncertainties arising from the 
hybrid character of the OWF development are clarified prior to the tender. 

 
 
 
 
 
 
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▪  Option 2  "Strict design  with aligned requirements": A tender design  with strict  pre-qualification 
requirements implies that extensive pre-qualification requirements are defined to ensure hybrid-
specific and general capabilities to develop the DE OWF to NL hybrid project. The requirements 
are  aligned  among  the  Netherlands  and  Germany,  including  a  jointly  agreed  set  of  financial 
requirements and a certain set of both Dutch  and German rules related  to the  OWF site (e.g. 
environmental  details)  and  a  certain  set  of  both  Dutch  and  German  rules  related  to  the  grid 
connection  of  the  OWF  (e.g.  technical  and  operational  details  such  as  system  integration  or 
frequency control).  

▪  Option  3:  "Strict  design  without  hybrid-specific  uncertainties":  A  tender  design  with  strict  pre-
qualification  requirements  implies  that  extensive  pre-qualification  requirements  are  defined  to 
ensure  hybrid-specific  and  general  capabilities  to  develop  the  DE  OWF  to  NL  hybrid  project. 
Furthermore,  all  uncertainties  arising  from  the  hybrid  character  of  the  OWF  development  are 
clarified prior to the tender. 

▪  Option 4 "Lenient design with aligned requirements and without hybrid-specific uncertainties": A 
tender design with lenient pre-qualification requirements is chosen, implying that only limited pre-
qualification requirements are defined to ensure competition and low prices. The requirements 
are  aligned  among  the  Netherlands  and  Germany,  including  a  jointly  agreed  set  of  financial 
requirements and a certain set of both Dutch  and German rules related  to the  OWF site (e.g. 
environmental  details)  and  a  certain  set  of  both  Dutch  and  German  rules  related  to  the  grid 
connection  of  the  OWF  (e.g.  technical  and  operational  details  such  as  system  integration  or 
frequency control). Furthermore, all uncertainties arising from the hybrid character of the OWF 
development are clarified prior to the tender. 

Legal / 
regulatory 
coverage 

Alignment of 
requirements 

Option 1: Strict 
design, aligned 
requirements and 
no uncertainties 

Option 2: Strict 
design and 
aligned 
requirements  

Not covered and 
potential 
amendments to 
national legislation 
and regulation 
necessary since 
multiple countries 
are involved in 
defining tender 
design 

Financial 
requirements 
aligned; technical 
and operational 
requirements 
defined by the NL; 
environmental 
requirements 
defined by DE 

Not covered and 
potential 
amendments to 
national legislation 
and regulation 
necessary since 
multiple countries 
are involved in 
defining tender 
design 

Financial 
requirements 
aligned; technical 
and operational 
requirements 
defined by the NL; 
environmental 
requirements 
defined by DE 

Option 3: Strict 
design and no 
uncertainties 

Covered and no 
amendments to 
national legislation 
and regulation 
necessary since 
only one country is 
involved in defining 
tender design 

No alignment of 
requirements 

Option 4: Lenient 
design, aligned 
requirements and 
no uncertainties 

Not covered and 
potential 
amendments to 
national legislation 
and regulation 
necessary since 
multiple countries 
are involved in 
defining tender 
design 

Financial 
requirements 
aligned; technical 
and operational 
requirements 
defined by the NL; 
environmental 
requirements 
defined by DE 

 
 
 
 
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Hybrid-
specific un-
certainties 

Realisation 
probability 

Option 1: Strict 
design, aligned 
requirements and 
no uncertainties 

Option 2: Strict 
design and 
aligned 
requirements  

Option 3: Strict 
design and no 
uncertainties 

Option 4: Lenient 
design, aligned 
requirements and 
no uncertainties 

All uncertainties 
arising from hybrid-
specific setup are 
clarified, e.g. 
liability, applicable 
jurisdiction, grid 
connection 
responsibility, RES 
subsidy scheme 

Uncertainties 
arising from hybrid 
character of 
development not 
entirely clarified 
such that 
uncertainty remains 
for OWF 
developers 

All uncertainties 
arising from hybrid-
specific setup are 
clarified, e.g. 
liability, applicable 
jurisdiction, grid 
connection 
responsibility, RES 
subsidy scheme 

All uncertainties 
arising from hybrid-
specific setup are 
clarified, e.g. 
liability, applicable 
jurisdiction, grid 
connection 
responsibility, RES 
subsidy scheme 

Applying OWF 
developers are 
aware of all 
specifications and 
requirements and 
can align planning 
and financing right 
from the beginning 

Applying OWF 
developers are 
aware of all 
specifications and 
requirements and 
can align planning 
and financing right 
from the beginning  

Applying OWF 
developers are not 
aware of most 
specifications and 
requirements, 
which might result 
in significant cost 
overruns / delays 
after the tender 
process 

Applying OWF 
developers are 
aware of all 
specifications and 
requirements and 
can align planning 
and financing right 
from the beginning; 
however, it is 
questionable 
whether an OWF 
connected to 
foreign country can 
be tendered without 
alignment of tender 
requirements 

Cost efficiency  Due to strict 

requirements and 
specifications, less 
developers 
expected to apply – 
cost efficiency of 
offers expected to 
decrease with 
fewer applicants 

Due to strict 
requirements and 
specifications, less 
developers 
expected to apply – 
cost efficiency of 
offers expected to 
decrease with 
fewer applicants 

Due to strict 
requirements and 
specifications, less 
developers 
expected to apply – 
cost efficiency of 
offers expected to 
decrease with 
fewer applicants 

Due to lenient 
requirements and 
specifications, 
many developers 
expected to apply – 
cost efficiency of 
offers expected to 
increase with more 
applicants 

 
 
 
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Summary 

Option 1: Strict 
design, aligned 
requirements and 
no uncertainties 

Option 2: Strict 
design and 
aligned 
requirements  

Legal and 
regulatory 
coverage to be 
assessed and 
potentially 
decreases cost 
efficiency 

Legal and 
regulatory 
coverage to be 
assessed and 
decreases cost 
efficiency, 
particularly due to 
remaining hybrid 
uncertainties 

Option 4: Lenient 
design, aligned 
requirements and 
no uncertainties 

Legal and 
regulatory 
coverage to be 
assessed and 
strongly decreases 
probability of 
project realisation  

Option 3: Strict 
design and no 
uncertainties 

Legal and 
regulatory 
coverage given, but 
with limited chance 
of realisation due to 
non-consideration 
of one country's 
interest in defining 
tender 
requirements 

Table 42: DE OWF to NL – Assessment of options for tender design 

In summary, the interaction with stakeholders shows that all four options – a strict or lenient tender 
design  with  aligned  requirements  and  certainty  about  hybrid-specific  characteristics  of  the  OWF 
development (Option 1 and 4), a strict tender design with aligned requirements (Option 3) as well as 
a  strict  tender  design  with  certainty  about  hybrid-specific  characteristics  of  the  OWF  development 
(Option  2)  –  have  advantages  and  disadvantages.  While  a  tender  design  with  strict  requirements 
(Options 1, 2 and 3) increases the probability of successful project implementation, a tender design 
with  lenient  requirements  (Option  4)  decreases  the  cost  of  implementation  through  competition. 
Furthermore, certainty about hybrid-specific characteristics of the OWF development (Options 1, 3 
and  4)  increases  the  probability  of  successful  project  implementation  and  decreases  the  cost  of 
implementation by reducing the risk premium otherwise demanded by OWF developers in terms of 
subsidies. Lastly, aligned requirements (Options 1, 2 and 4) aid in ensuring the interoperability of the 
OWF with the other assets of the  hybrid project and thereby increase the probability of successful 
hybrid project implementation. 

Considering the results of the interaction with the stakeholders, the selection and / or implementation 
of the appropriate mitigation option for the DE OWF to NL hybrid project must also take into account 
the interdependencies between the individual barriers. 

5.5.8  Discrepancies in responsibilities and requirements for balancing 

In  the  context  of  the  DE  OWF  to  NL  hybrid  project,  there  is  no  discrepancy  in  the  applicability  of 
national balancing responsibility  and requirements in the shorter term. Since each generator must 
always be part of only one bidding  zone according to the existing CACM regulation and since the 
participation of one generator in different bidding zones at different times would be highly challenging 
for the operation of the entire energy system, an OWF physically connected to multiple bidding zones 
can only commercially feed its electricity into one bidding zone. Furthermore, the topic is addressed 
in  the  Clean  Energy  Package.  It  is  likely  that  no  further  barrier  mitigation  regarding  balancing 
responsibilities  and  requirements  is  needed  for  the  implementation  of  the  DE  OWF  to  NL  hybrid 
project. However, in the longer term the translation into Dutch and German law needs to be assessed 
in detail by the project-specific stakeholders. 

 
 
 
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5.5.9  Discrepancies in priority dispatch regulation 

In  the  context  of  the  DE  OWF  to  NL  hybrid  project,  there  is  no  discrepancy  in  the  applicability  of 
national priority dispatch regulation in the shorter term. Since each generator must always be part of 
only one bidding zone according to the existing CACM regulation and since the participation of one 
generator in different bidding zones at different times would be highly challenging for the operation of 
the  entire  energy  system,  an  OWF  physically  connected  to  multiple  bidding  zones  can  only 
commercially  feed  its  electricity  into  one  bidding  zone.  Furthermore,  the  topic  is  addressed  in  the 
Clean  Energy  Package.  It  is  likely  that  no  further  barrier  mitigation  regarding  priority  dispatch 
regulation  is needed for the implementation of the  DE OWF to NL hybrid project. However,  in the 
longer term the translation into Dutch and German law needs to be assessed in detail by the project-
specific stakeholders. 

5.5.10  Discrepancies in curtailment regulation and compensation 

In  the  context  of  the  DE  OWF  to  NL  hybrid  project,  there  is  no  discrepancy  in  the  applicability  of 
national  curtailment  regulation  and  compensation  in  the  shorter  term.  Since  each  generator  must 
always be part of only one bidding  zone according to the existing CACM regulation and since the 
participation of one generator in different bidding zones at different times would be highly challenging 
for the operation of the entire energy system, an OWF physically connected to multiple bidding zones 
can only commercially feed its electricity into one bidding zone. Furthermore, the topic is addressed 
in  the  forthcoming  Clean  Energy  Package.  It  is  likely  that  no  further  barrier  mitigation  regarding 
curtailment  regulation  and  compensation  is  needed  for  the  implementation  of  the  DE  OWF  to  NL 
hybrid project. However, in the longer term the translation into Dutch and German law needs to be 
assessed in detail by the project-specific stakeholders. 

5.5.11  Lack of regulated revenues for anticipatory investments 

This barrier is not relevant for the DE OWF to NL hybrid project. 

In  the  context  of  the  DE  OWF to  NL  hybrid  project,  anticipatory  investments  are  not  required  and 
therefore the barrier does not exist for this specific hybrid project.  

5.5.12  Uncertainty about applicable RES subsidy scheme 

This barrier is relevant for the DE OWF to NL hybrid project. 

To address this barrier, four mitigation options are assessed with regard to their applicability (Table 
43) – excluding the implications of interdependencies with other barriers. 

▪  Option 1 "Dutch subsidy scheme": According to EU Directive 2009/28/EC, the Dutch government 
can fund the German OWF included in the hybrid project with a premium tariff through the SDE+ 
scheme  (sliding  feed-in  premium),  potentially  with  statistical  transfers  between  the  involved 
countries. 

▪  Option 2 "German subsidy scheme": The German government awards the OWF included in the 
hybrid  project  a  premium  tariff  (sliding  feed-in  premium),  potentially  with  statistical  transfers 
between the involved countries. 

▪  Option  3  "Joint  project  between  the  Netherlands  and  Germany":  According  to  EU  Directive 
2009/28/EC  Member  States  may  co-fund  an  energy  project  that  relates  to  the  production  of 
electricity  from  renewable  energy  sources.  In  this  context,  a  joint  project  implies  that  the 
Netherlands and Germany are financing parts of the hybrid project by applying their own national 
subsidy schemes. 

 
 
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▪  Option 4 "No subsidy scheme": The OWF included in the DE OWF to NL hybrid project is tendered 
without a subsidy scheme (i.e. comparable to zero-subsidy bids) and neither a subsidy scheme 
of the Netherlands and Germany nor a joint project is needed.  

Option 1: Dutch 
subsidy scheme 

Option 2: German 
subsidy scheme 

Legal / 
regulatory 
provisions 

Not covered by NL 
legal and regulatory 
regime as OWF is 
located in DE  

Potentially covered 
by DE legal and 
regulatory regime 
but clarification 
required with 
regard to need for 
statistical transfers 
due to and 
applicability despite 
onshore connection 
point in the NL 

Option 4: No 
subsidy scheme 

Covered in national 
legal and regulatory 
regime 

Option 3: Joint 
project between 
NL and DE 

Covered by EU 
Directive 
2009/28/EC on a 
European level but 
legally binding 
document between 
NL and DE needs 
to be formulated to 
establish joint 
project 

Costs 

Costs borne only 
by the NL  

Costs borne only 
by DE  

Costs borne jointly 
by the NL and DE 

Mechanism 

Sliding feed-in 
premium 

Sliding feed-in 
premium 

Project 
bankability 

Bankability ensured 
through subsidy 
scheme 

Bankability ensured 
through subsidy 
scheme 

Sliding feed-in 
premium in the NL 
and DE 

Bankability ensured 
through joint project 

Public opinion  Dutch public 

opinion can be 
opposed to funding 
DE OWF with NL 
public funds 

German public 
opinion can be 
opposed to funding 
DE OWF without 
DE connection with 
DE public funds 

Public opinion in 
NL and DE can be 
opposed to funding 
RES generation 
potentially 
transmitted to other 
countries with 
public funds 

No costs must be 
borne by the NL 
and DE 

No mechanism 
necessary 

Bankability of 
project depends on 
other offtake 
securities, such as 
long-term power 
purchase 
agreements 

Public opinion 
neutral since no 
public funds used  

 
 
 
 
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Timeline 

Summary 

Option 1: Dutch 
subsidy scheme 

Option 2: German 
subsidy scheme 

Uncertain timeline 
as OWF inclusion 
into NL National 
Water Plan 
necessary but 
process not 
established 

Not covered in NL 
legal and regulatory 
regime, bankability 
ensured but public 
opinion potentially 
opposed and 
uncertain timeline 

Uncertain timeline 
as OWF site is not 
foreseen in DE 
central plans but 
potentially included 
in a special tender 
and with unknown 
date 

Potentially covered 
in DE legal and 
regulatory regime, 
bankability ensured 
but public opinion 
potentially opposed 
and uncertain 
timeline 

Option 4: No 
subsidy scheme 

Uncertain timeline 
as OWF site is not 
foreseen in DE 
central plans but 
potentially included 
in a special tender 
and with unknown 
date 

Covered in national 
legal and regulatory 
regime but 
bankability only 
ensured with 
offtake securities 
and uncertain 
timeline 

Option 3: Joint 
project between 
NL and DE 

Uncertain timeline 
in DE as OWF site 
is not foreseen in 
DE central plans 
and joint project 
must be 
established 

Covered in EU and 
national legal and 
regulatory regime 
with legal 
agreement 
required, 
bankability ensured 
but public opinion 
potentially opposed 
and uncertain 
timeline 

Table 43: DE OWF to NL – Assessment of options for RES subsidy schemes 

In summary, the interaction with stakeholders shows that all four options – applying a Dutch (Option 
1) or German (Option 2) subsidy scheme to the German OWF, establishing a joint project (Option 3) 
as well as tendering the OWF site without a subsidy scheme (i.e. comparable to zero-subsidy bids) 
(Option 4) – have advantages and disadvantages. While applying the Dutch subsidy scheme is not 
covered under Dutch legislation and regulation, applying the German subsidy scheme or no subsidy 
scheme are (potentially) covered. For the German subsidy scheme, it needs to be clarified whether 
statistical transfers between the Netherlands and Germany are required. While the bankability of the 
OWF supported under Options 1 to 3 is given, the bankability of an OWF tendered without a subsidy 
scheme (Option 4) largely depends on the ability of the OWF developer to obtain offtake securities 
like power purchase agreements. Establishing a joint project between the Netherlands and Germany 
is  legally  covered  and  provides  the  necessary  bankability  but  might  be  problematic  due  to  the 
extended timeline which is needed to agree the specifications of the scheme and to formulate a legally 
binding document between the Netherlands and Germany.  

Considering the results of the interaction with the stakeholders, the selection and / or implementation 
of the appropriate mitigation option for the DE OWF to NL hybrid project must also take into account 
the interdependencies between the individual barriers. 

5.5.13  Limited engagement of public stakeholders 

The  barrier  "limited  engagement  of  public  stakeholders"  is  divided  into  two  subtopics,  formalised 
public support and financial support. The two subtopics are addressed individually in the following. 

Formalisation of commitment from public stakeholders  

This subtopic of the barrier is relevant for the DE OWF to NL hybrid project. 

 
 
 
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To address this barrier, two mitigation options are assessed with regard to their applicability (Table 
44) – excluding the implications of interdependencies with other barriers. 

▪  Option  1  "Memorandum  of  Understanding  (MoU)":  A  Memorandum  of  Understanding  is  a 
formalisation of the goodwill of the involved parties in form of a non-binding agreement. An MoU 
addresses  barriers  by  formalising  the  agreements  of  the  involved  parties  with  regard  to  the 
implementation  of  required  actions  to  overcome  the  barriers.  It  can  involve  all  project 
stakeholders,  such  as  OWF  developers,  TSOs,  national  ministries  and  NRAs  as  well  as  the 
European Commission. 

▪  Option 2 "Hybrid Asset Network Support Agreement (HANSA)": A project-specific Hybrid Asset 
Network  Support  Agreement  is  a  legally-binding  commitment  to  adapt  national  legislation  and 
regulation in the future, and thus provides legal certainty to developers. European legislation and 
regulation can only be adapted via a project-specific HANSA if all Member States of the European 
Union  sign  the  agreement.  It  only  directly  involves  public  stakeholders,  such  as  national 
ministries. 

Option 1: Memorandum of 
Understanding (MoU) 

Option 2: Hybrid Asset Network 
Support Agreement (HANSA) 

Required effort  Some interaction and alignment 

required among project developers and 
stakeholders to facilitate signing of 
agreement 

Provided 
certainty 

Intentional character of signed 
agreement sufficient for hybrid projects 
in early development stage  

Significant interaction and alignment 
among political project stakeholders 
required to facilitate signing of 
agreement 

Legally binding commitment to topics 
covered by signed agreement directly 
facilitates project development, but is 
only required at a later development 
stage of hybrid projects 

Summary 

Reasonable effort to align agreement 
required prior to signing and non-legally 
binding commitment sufficient in early 
project development stages 

Significant effort for alignment of 
agreement required prior to signing but 
provides legal certainty and therefore 
suitable in later development stages 

Table 44: DE OWF to NL – Assessment of options for formalisation of commitment from public stakeholders 

In  summary,  the  interaction  with  stakeholders  shows  that  both  options  –  a  project-specific 
Memorandum  of  Understanding  (Option  1)  and  a  project-specific  Hybrid  Asset  Network  Support 
Agreement (Option 2) – have advantages and disadvantages. While less effort is usually required to 
align  and  sign  a  project-specific  MoU,  an  MoU  is  not  legally  binding,  and  thus  the  commitment  of 
public stakeholders provides limited certainty, for example, about legal and regulatory changes for 
project developers (Option 1). However, while a project-specific HANSA provides legal certainty about 
the commitment of stakeholders to implement legal and regulatory changes, the alignment process 
requires more effort (Option 2).  

Considering the results of the interaction with the stakeholders, the selection and / or implementation 
of the appropriate mitigation option for the DE OWF to NL hybrid project must also take into account 
the interdependencies between the individual barriers as well as the development stage of the hybrid 
project. 

 
 
 
 
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 Financial support 

This subtopic of the barrier is relevant for the DE OWF to NL hybrid project. 

In  summary,  the  interaction  with  stakeholders  shows  that  there  is  no  specific,  tangible  mitigation 
option  to  address  the  barrier  of  limited  financial  support,  but  rather  that  a  portfolio  of  support 
programmes is available and their usage needs to be increased to facilitate the implementation of 
hybrid projects. In the past, hybrid project development and / or considerations, such as the Combined 
Grid Solution Kriegers Flak in the Baltic Sea and the Interconnector tie-in COBRA Cable in the North 
Sea,  indicate  that  such  support  is  required  to  de-risk  and  thereby  allow  for  the  realisation  of  pilot 
projects. In this context, financial support can come in various forms, such as co-financing for early-
stage feasibility studies, scoping studies or R&D, co-financing of development and construction or 
guarantees  for  the  operational  phase.  Generally,  financial  support  programmes  are  available  on 
national and European level and should be as specifically targeted at hybrid projects as possible. The 
target is to increase the awareness for and the usage of existing financial support programmes and 
thereby foster the development of hybrid projects. 

Considering the results of the interaction with the stakeholders, the mitigation of this barrier for the 
DE  OWF  to  NL  hybrid  project  must  also  take  into  account  the  interdependencies  between  the 
individual barriers. 

5.5.14 

 Uncertainty regarding the UK market 

The barrier "uncertainty regarding the UK market" is divided into two subtopics, UK Capacity Market 
and UK Cap and Floor regime as well as EU internal energy market. The two subtopics are addressed 
individually in the following. 

UK Capacity Market and Cap and Floor regime 

This subtopic of the barrier is not relevant for the DE OWF to NL hybrid project. 

In the context of the DE OWF to NL hybrid project, no commercial nor public UK stakeholders are 
involved. Thus, there is no uncertainty regarding the UK Capacity Market and Cap and Floor regime 
for the specific hybrid project idea. 

EU internal energy market 

This subtopic of the barrier is not relevant for the DE OWF to NL hybrid project. 

In the context of the DE OWF to NL hybrid project, no commercial nor public UK stakeholders are 
involved. Thus, there is no uncertainty regarding the participation in the EU internal energy market 
for the specific hybrid project idea. 

5.5.15  Disproportionate allocation of costs and benefits across involved 

stakeholders 

This barrier is relevant for the DE OWF to NL hybrid project. 

In  summary,  the  interaction  with  stakeholders  shows  that  there  is  no  specific,  tangible  mitigation 
option  to  address  the  barrier  of  disproportionate  allocation  of  costs  and  benefits  across  involved 
stakeholders,  but  rather  that  a  process  towards  the  mitigation  of  the  barrier  must  be  followed. 
Generally, the process consists of the identification and alignment of cost and benefit categories, the 
determination of the initial allocation of costs and benefits, the agreement on a re-allocation of costs 
and benefits as well as – if required and available – the usage of CEF funding to ensure the individual 
incentivisation of all stakeholders. This can build on the existing process  for Cost Benefit Analyses 
(CBA) and Cross-Border Cost Allocations (CBCA) as defined by ENTSO-E for cross-border electricity 

 
 
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interconnectors, which needs to be adjusted according to the specifications of each individual hybrid 
project. The process should allow for the incentivisation of all relevant stakeholders to implement the 
hybrid project. 

Considering the results of the interaction with the stakeholders, the mitigation process to be followed 
for the DE OWF to NL hybrid project must also take into account the interdependencies between the 
individual barriers.  

5.5.16  Uncertainty about legislative regime for power-to-gas and related 

infrastructure  

This barrier is not relevant for the DE OWF to NL hybrid project. 

In  the  context  of  the  DE  OWF  to  NL  hybrid  project,  it  is  currently  not  planned  to  include  power 
conversion to gas and / or gas transmission solutions. Thus, there is no need for and consequently 
no uncertainty regarding the legislative regime for power conversion to gas and gas transmission for 
the specific hybrid project idea.

 
 
Disclaimer 

This study was prepared by Roland Berger within the scope of the project entitled "Development of 
the  North  Seas  offshore  energy  potential  –  a  cluster-based  approach"  under  the  Contract  no. 
ENER/B1/2016-326,  commissioned  by  the  Directorate-General  for  Energy  of  the  European 
Commission. 

This document has been prepared for the European Commission. However, it reflects the views only 
of the authors, and the Commission cannot be held responsible for any use which may be made of 
the information contained therein. 

Roland Berger acts as commercial advisor, no legal advice is provided. 

© 2018 Roland Berger GmbH. All rights reserved.