Response to consultation on all CE and Nordic TSOs’ results of CBA for FCR providing LER units

ENTSO-E Consultation the CBA approved Methodology for minimum activation times for FCR providing units with a limited energy reservoir (LER)

In the consulted report, ENTSO-E presents a series of options regarding the procurement of FCR from units with a limited energy reservoir, e.g., storage. smartEn’s main concern in the presented Methodology is the limitation, and even reduction of the current share, of LERs providing FCR and relying on traditional sources. Another concern is the cost assumptions made in the report, which might indicate that FCR provided by LERs is priced higher than the one provided by traditional units. Together with other assumptions in this report, if this CBA is adopted, it would make LERs, and decentralized resources, less attractive than their traditional counterparts.

Public Consultations & Open Letters

  • smartEn welcomes the public consultation on the reform of the EU’s electricity market design (EMD), which very much highlights the increasing role of demand-side flexibility and active consumers in a centralised energy system. smartEn  framed its reply around five pillars: 1. Strengthen consumer empowerment 2. Maximise District Self-Balancing 3. Unlock the value of demand-side resources in wholesale energy and ancillary services markets 4. Support investments with capacity remuneration arrangements 5. Combine renewables support schemes with distributed flexibility smartEn encourages the Commission to duly take these recommendations into account in view of the legislative proposal.

  • smartEn welcomes the Action Plan’s core objective to develop a market for Demand Side Flexibility, which is key to boost consumers’ participation and increase system efficiency. It is a key opportunity to support the ‘Fit for 55’. As a first priority the Action Plan should support the uptake of digital technologies capable of communicating with the grid and second, create a EU data-sharing infrastructure with a common EU energy data space, based on data transparency and interoperability. This should cover: Prosumers data from both smart meters and sub-meters as the latter are key to ensure full coverage of Demand Side Flexibility potential System operators essential data on network constraint and energy mix in order to give appropriate signal on when it is best to activate Demand Side Flexibility. The governance framework needed to ensure equal data access should be based on stakeholder engagement. Finally, Cybersecurity is a prerequisite for all data driven business models and should ensure the operational security of the entire energy system, from end to end.

  • Read the whole response.

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