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

Ember's response to the public consultation on the Flexibility Needs Assessment (FNA) methodology, arguing that the current draft focuses too narrowly on renewable energy surplus and fails to sufficiently address the broader goal of decarbonising the electricity system.

• Ember argues that the FNA methodology's focus on reducing renewable energy source (RES) curtailment is inconsistent with Regulation (EU) 2019/943 and Article 19e(1) of the EMDR, which requires the assessment of flexibility needs to "decarbonise the electricity system". Ember suggests the methodology should instead cover both RES surplus and undersupply by shifting demand.
• Ember recommends renaming "flexibility network needs" and "flexibility needs" to "non-fossil flexibility network needs" and "non-fossil flexibility needs". This change is intended to align with the objective of defining national objectives for non-fossil flexibility under Art 19f, signal a clear direction to investors, and avoid "incentivising sunk investments".
• The document expresses concern that the current methodology may lead to the underestimation of storage and flexibility technologies and the overestimation of flexible fossil assets, potentially leading to "stranded assets". Ember proposes integrating the FNA into the ERAA/NRAA process as an ex-post modelling exercise to allow for optimised dispatch between fossil and non-fossil assets.
• Ember criticizes the draft methodology for lacking data transparency and accessibility. It proposes that non-confidential data, the complete list of input data (Table 1), and assessment results be made public, following the standards of the Ten-Year Network Development Plan (TYNDP) and the ERAA.
• Ember suggests several technical improvements to the methodology: including definitions for "operational limits" (incorporating grid enhancing technologies like dynamic line rating) and "national targets for RES integration", requiring TSOs to provide data for all years in the ERAA/NRAA time horizon, and establishing a revision cycle for the methodology every five years starting in 2026/2027.

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} }