Response ID ANON-NXHE-RQXK-S Submitted to Public Consultation on Flexibility Needs Assessment Methodology

Ember argues that the draft FNA methodology focuses too narrowly on "surplus" renewable power rather than the broader goal of decarbonising the electricity system. The organization advocates for renaming flexibility needs to "non-fossil flexibility network needs" to signal a shift away from fossil assets and avoid stranded investments. Ember also calls for greater data transparency, the inclusion of cost-efficiency metrics, and the integration of the FNA into the existing ERAA/NRAA modelling process to better optimize the dispatch between fossil and non-fossil assets.

• Ember contends that the draft methodology's focus on addressing "surplus" renewable power is inconsistent with Regulation (EU) 2019/943 and EMDR Art 19e, which aim to "decarbonise the electricity system".
• To align with 2030 and 2050 objectives and avoid incentivising sunk investments, Ember recommends renaming "flexibility network needs" to "non-fossil flexibility network needs".
• Ember criticizes the draft for neglecting data transparency and accessibility, proposing that non-confidential input data and assessment results be made public, similar to the standards of the TYNDP and ERAA.
• The current methodology is viewed as a risk to investment signals, potentially underestimating storage and flexibility technologies while overestimating flexible fossil assets; Ember proposes incorporating the FNA into the ERAA/NRAA process as an ex-post modelling exercise to optimize dispatch.
• Ember suggests that guiding criteria must include cost elements to ensure flexibility is provided in a "cost-efficient manner", noting that current metrics are too technical and ignore implications for consumers.

APA

Cremona, E. (2024). Response ID ANON-NXHE-RQXK-S Submitted to Public Consultation on Flexibility Needs Assessment Methodology. Ember. https://ember-energy.org/app/uploads/2024/12/Ember-response-FNA-methodology.pdf

Chicago

Cremona, Elisabeth. Response ID ANON-NXHE-RQXK-S Submitted to Public Consultation on Flexibility Needs Assessment Methodology. Ember, 2024. https://ember-energy.org/app/uploads/2024/12/Ember-response-FNA-methodology.pdf.

Wikipedia

{{cite press release |last1=Cremona |first1=Elisabeth |title=Response ID ANON-NXHE-RQXK-S Submitted to Public Consultation on Flexibility Needs Assessment Methodology |publisher=Ember |date=6 December 2024 |url=https://ember-energy.org/app/uploads/2024/12/Ember-response-FNA-methodology.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{cremona2024response, author = {Cremona, Elisabeth}, title = {{Response ID ANON-NXHE-RQXK-S Submitted to Public Consultation on Flexibility Needs Assessment Methodology}}, publisher = {Ember}, year = {2024}, month = dec, url = {https://ember-energy.org/app/uploads/2024/12/Ember-response-FNA-methodology.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }