Ember’s response to the public consultation on the Flexibility Needs Assessment (FNA) Methodology
Summary
Background
Ember submitted feedback to ENTSO-E and the DSO Entity on the Flexibility Needs Assessment (FNA) Methodology. The draft methodology was published for public consultation on 8 November 2024.
The revised Electricity Market Regulation (EU) 2019/943 requires Member States to define an indicative national objective for non-fossil flexibility, including the respective specific contributions of both demand response and energy storage to that objective (Article 19f). The national objective shall be based on the assessment of flexibility needs, to be carried out every two years by the Member States (Article 19e). The Regulation entrusts ENTSO-E and the EU DSO entity to define the data type, data format and methodology for the analysis of the flexibility needs. This was the subject of the public consultation.
Ember’s full response can be downloaded, and the key messages are summarised below.
Key points
- The methodology does not consider trade-offs between fossil assets and non-fossil alternatives, due to the use of a predefined profile of surplus renewable electricity. This risks overestimating the use of fossil assets, and underestimating the optimal capacity of storage and flexibility technologies. To address this issue, we propose that the FNA is incorporated into the resource adequacy assessments, as an ex-post modelling exercise using the same framework and models.
- Ember disagrees with the fundamental objective of the proposed FNA methodology, that is, addressing “surplus” renewable power. This is not well-aligned with the Electricity Market Regulation which states the FNA’s objective is to estimate flexibility needs to “decarbonise the power system” (Article 19e). The methodology should shift from merely addressing surplus renewable energy to covering RES undersupply by shifting demand or RES surplus generation, better reflecting that decarbonisation is not only about flexibility capacities but about shifting energy or demand to better align with RES generation patterns.
- Ember strongly expresses its disappointment that the draft FNA methodology neglects the crucial aspect of data transparency and accessibility. The complete list of input data (Table 1) and the results of the assessment should be made publicly available, in line with the EU’s commitment to data transparency, and following the standard set by the ERAA and TYNDP.