Network operators in the Netherlands are under unprecedented pressure. The energy transition demands the fastest possible expansion of the electricity grid, yet the Netherlands Authority for Consumers and Markets (ACM) has concluded that the investment plans of Enexis, Liander, Stedin and TenneT were insufficiently substantiated. The regulator sent the four organisations back to the drawing board with a clear message: provide clearer, more transparent justification for where the billions in investment are going and why.
This may sound like an administrative correction, but it touches a fundamental tension: the need to build quickly clashes with the societal expectation that choices must be explainable. As stakeholder and environmental management specialists, we encounter this tension daily — in conversations with municipalities asking why their industrial estate does or does not receive priority, or residents who cannot understand why a transformer station is planned next to their neighbourhood.
The lessons from the ACM review extend well beyond financial reporting. They go to the heart of good stakeholder and environmental management. Here are six of them.
1. Transparency starts not at the press conference, but at the investment justification
The ACM found that network operators could not adequately demonstrate on what basis prioritised investments had been made. That problem is not just internal — it cascades outward. If a network operator has no clear written rationale for choosing to reinforce region A before region B, it also cannot defend that choice to a province or municipality that disagrees.
Good stakeholder and environmental management starts with an investment logic that is documented and shared across the organisation. Without that foundation, every piece of external communication is built on sand.
2. Prioritisation decisions are societal decisions — treat them as such
When network operators must allocate limited grid capacity, they make choices with major societal consequences. A business park waiting years for transport capacity loses jobs and investment. A neighbourhood lower on the waiting list has fewer opportunities to connect solar panels or heat pumps.
The Energy Act 2026 introduces formal prioritisation criteria, but the social legitimacy of those criteria requires more than legislation alone. Network operators must be able to explain how they apply those criteria in practice. Organisations that do not communicate about prioritisation leave a vacuum that fills with speculation and distrust.
3. Involve local and regional authorities early in the planning process
In several regions, current grid congestion is generating conflicts between network operators and municipalities or provinces over the siting of new infrastructure. Transformer stations, switching stations and cable corridors meet objections that could partly have been avoided if plans had been shared earlier with local government.
An investment plan aligned only internally and with central government is missing a crucial link. Provinces and municipalities are not just licensing authorities — they are the parties that must reserve space for energy infrastructure in their environmental visions and plans. Early consultation is not a courtesy; it is a strategic necessity.
4. Share bad news early and proactively
One of the most consistent complaints from residents and local administrators is that they receive information about plans affecting them too late. This applies equally to delays, revised timetables or changes in location.
The instinct to wait for internal certainty before communicating is understandable but counterproductive. It is far better to communicate uncertainty yourself than to allow the community to pick up that information through other channels — fragmented, incomplete or distorted. Proactive communication about difficult news builds more trust than deferring it.
5. Make the connection between investments and living environment effects visible
Network operators work within technical and financial frameworks. Residents and local decision-makers think in terms of their living environment: noise, land use, visual impact, safety perception. These two worlds speak different languages.
The improvement programme that network operators have launched following the ACM review provides an opportunity to bridge that gap more effectively. Not just by publishing more information, but by showing how an investment decision translates into concrete effects on the living environment — and how those effects were weighed. A project environmental management plan that makes this connection visible is a powerful tool for any stakeholder manager.
6. Document the societal case — not just the technical case
In legal proceedings and permitting processes, it is increasingly insufficient to argue that an investment is technically necessary. Courts, objections committees and environmental agencies also test for proportionality and public interest. A transformer station that fits technically at location X is not automatically permitted if the public interest case has not also been demonstrated.
Network operators who better document their investment rationale — at the ACM’s request — are simultaneously building a stronger foundation for their permitting processes. These two questions are not separate worlds: they reinforce each other.
From regulatory moment to cultural change
The ACM review is a formal moment in an ongoing regulatory framework. But the lessons it offers go beyond an improvement plan for investment documentation. They point to a cultural question: to what extent are network operators — organisations traditionally oriented towards technical and internal processes — willing and able to make their choices genuinely explainable to the society that depends on them?
The energy transition allows no time for a gradual cultural shift. Projects must move faster, and public support is not a luxury but a prerequisite for progress. Stakeholder and environmental management that begins at the investment planning stage — not just at the permit application — is the direction the sector must take.
In practice, we see that organisations that invest early and structurally in transparency and stakeholder communication face less delay in the permitting phase. The ACM has now confirmed the same from the financial side: explainability is not optional — it is a prerequisite.