Αρχική Αναθεωρημένο Εθνικό Σχέδιο για την Ενέργεια και το Κλίμα (ΕΣΕΚ)Εθνικό Σχέδιο για την Ενέργεια και το Κλίμα (ΕΣΕΚ) – αναθεωρημένη έκδοσηΣχόλιο του χρήστη Sympower | 13 Σεπτεμβρίου 2024, 10:33
  • Σχόλιο του χρήστη 'Sympower' | 13 Σεπτεμβρίου 2024, 10:33

    Sympower contribution to Greece’s National Energy & Climate Plan (please check specific proposals at the end of the text) Sympower is a flexibility service provider that helps customers adapt successfully towards the energy transition. By combining proprietary software and hardware, we provide an end-to-end solution that offers real-time monitoring and balancing of electricity supply and demand. Our software platform manages over 1,5 GW of flexible distributed energy resources in 10+ countries (Sweden, Finland, Norway, Denmark, Netherlands, Poland, Hungary, Czechia, Greece and Italy). We operate in the Greek balancing market with 70MW of demand-side assets aiming to facilitate the participation of more than 300 MW by the end of 2024. First of all, we would like to express our support towards seeing the Greek government submitting a revised version of its previous national energy and climate plan (NCEP) including ambitious targets and proposals on how to address the 5 dimensions of the energy union, namely 1) decarbonisation 2) energy efficiency 3) energy security 4) internal energy market and finally 5) research, innovation and competitiveness. The NCEP submitted includes an overview of those technologies that are expected to lead to climate neutrality as well as their outlook over the next years decades and until reaching year 2050. As the NCEP acknowledges, (table ΕΣ 1, p. 21 & 22 ) demand response services are considered among those technologies that is of utmost importance to face a rapid increase if Greece wants to achieve its energy & climate goals. Demand response, and in general, flexibility providers, can offer multiple benefits not only for the energy system itself but also on an environmental and socio-economical level. Energy security The electricity grid needs flexibility to keep the system balanced at all times. On one hand, the massive introduction of RES into the energy market and the move towards a decentralised, renewable-based energy system create the need for increasing rates of flexibility that cannot be provided solely by the declining, traditional sources, namely fossil-based electricity plants. At the same time, current energy targets foresee increasing rates of the electrification of energy demand that, for a successful energy transition, will have to be met by renewable energy supply. Both of the above will necessitate significant rates of flexibility embedded into the energy system that will provide for a stable, reliable and sustainable energy system. It is therefore crucial that providers of flexibility services, such as demand side response,, become active or benefit from a supportive legislative and regulatory framework, in order to unlock flexibility for balancing the electricity network. Demand-side resources have already proven their role and will continue to be crucial in providing the necessary capabilities for the security of the supply, both for resource adequacy and operational security. Environmental benefits On a direct level, it is true that fossil-fueled power plants (especially gas) still play an important role in balancing the grid. These power plants do this by constantly adjusting their production to the demand for electricity. To be able to have flexible production, the plants need to run at a lower capacity. For example, when a power plant occasionally has to ramp up its production by 10%, it can only run at 90% of its full capacity. Therefore, electricity production is less efficient, because the higher the production of power plants, the higher the efficiency of that production. In this regard, when more and more ancillary services are provided by demand-side flexibility instead of power plants, these plants will be able to run at a higher capacity and electricity is produced more efficiently. Therefore, less CO2 is emitted due to electricity production. In this way, carbon emissions are directly reduced by demand response for ancillary services. On an indirect level, flexibility is a major instrument for the energy transition. Based on the most recent projections, energy consumption mostly as a result of electrification needs to double by 2045. Meeting electrification needs involves incorporating many new types of variable loads alongside climate goals which require expanding intermittent renewable energy capacity. Therefore, maintaining existing inflexible low-carbon production presents a significant challenge necessitating greater system flexibility. In this scenario, demand-side flexibility serves as a crucial bridge in aligning variations in non-dispatchable renewable energy sources with electricity demand as well balances variable loads with inflexible, low-carbon production. This enables the accommodation of more fossil-free and low-carbon production, especially in the short term, where there is a high demand for flexible resources to be quickly implemented. Furthermore, increasing demand side flexibility can further support long-term decisions on a cleaner national energy mix. If demand-side flexibility demand response can provide grid balancing services, peak shaving, etc. for less than the running costs of a fossil fuel plant, an important part of the business case for those fossil fuel plants disappears. This can lead either directly to the plant closing earlier than otherwise or to it being forced to charge more for the electricity that it produces. In this way the overall price of fossil electricity is increased in the market, and therefore making a better business case for renewables. To give one clear example of this: various studies have found that the grid can accommodate about 30% of annual electricity demand from inflexible, variable generation sources (i.e. wind and solar) without alternative ways of balancing the supply and demand of electricity. Any higher than this, and wind or solar production must be curtailed, because most electricity plants have a minimum output and cannot produce less than that minimum. Otherwise, plants have to be turned down completely. Demand response makes the energy system more flexible and this allows a higher penetration of renewable energy while minimising curtailment. Its fast, fossil-free and cost-effective implementation can help manage fluctuations in both energy production and consumption while addressing constraints in both production and grid availability across various markets and time periods. Socio-economic benefits: The rise of renewables in energy generation has created a new reality in energy prices for both consumers and producers: on the one hand, very high & often sky-rocketing prices when renewables are not able to cover the existing demand (i.e. a huge cost burden for consumers) and that expensive fossil-fuelled plants are called upon to cover residual demand and low, on the other hand often negative prices when renewable energy sources produce a high quantity of electricity that cannot be consumed at that moment, nor stored for later and exceeds demand, leading to an oversupply of electricity (i.e. low return of investment for renewable producers). With more renewable energy entering the market, these phenomena are expected to become more often and more frequent and intense. Apart from the profound importance of generating more electricity from renewable sources to mitigate high electricity prices negative prices are a challenge of the energy transition requiring systemic approach solutions and signalling the need for a more conducive policy framework for a flexible electricity system. With the right policies favouring demand-side flexibility in place, consumers would be incentivised to invest in flexible assets, such as e-boilers or batteries, and work with flexibility service providers to profit from negative prices. In a scenario combining negative electricity prices with demand-side response, commercial and industrial consumers can use their flexibility to perform energy-intensive tasks during periods of negative prices, like charging batteries or operating machinery. In view of the above and considering the current NECP provisions put under public consultation we would like to urge the Greek government to consider the following measures when it comes to demand side response & flexibility: -> Set clear & incremental targets for Demand Side flexibility. As also mentioned in the European Commission’s Recommendation (Dec 2023) of the draft updated integrated NECP which specifically calls for “[...] clear objectives and targets for demand response to improve the flexibility of the energy system, in light of an assessment of the flexibility needs and describe specific measures to facilitate energy system integration in the context of Article 20a of Directive (EU) 2018/2001 as amended[...], the need for clear, measurable targets is crucial towards achieving our highly ambitious energy and climate policy targets. Setting clear and measurable flexibility targets, with a specific focus on leveraging demand-side solutions, creates a roadmap for immediate action. These targets are more than just goals; they are a powerful signal to investors, developers, and consumers.This can then foster informed decision-making and swift action from all stakeholders. -> Supportive market design. The Greek government in cooperation with the NRA and the TSO/DSO will need to further enhance the market design that encourages end users' participation in offering their flexibility by: 1)Removing barriers should start from granting full market access to demand-side flexibility (which could be considered a low hanging fruit) and in particular aggregated forms so as to enhance efficiency & reliability. Offering demand response services is often hindered by technical barriers which do not enable demand response to express its whole flexibility potential. An example is the current methodology for ancillary services (mFRR and aFRR) that does not enable Demand Response to express its whole flexibility potential. In a typical Demand Response portfolio, the flexible assets usually represent a minor share compared to the total consumption capacity under the main metering point. For this minor share to be fully reflected and correctly evaluated, methodologies that rely on the use of dedicated metering devices i.e.sub-meters will need to be promoted by the Greek TSO. 2) Tangible stand alone incentives will need to be provided to consumers to electrify and adjust their energy consumption patterns regularly, both implicitly and explicitly. (a) for instance the Polish TSO has announced a scheme where consumers are remunerated for voluntarily & temporarily increasing their power consumption when there is an electricity generation surplus https://www.pse.pl/uslugi-dsr/interwencyjne-ofertowe-zwiekszenie-poboru-mocy-przez-odbiorcow b) the French NRA has implemented NEBEF since 2014 to provide incentives for Demand Side response participation in energy markets https://www.services-rte.com/en/learn-more-about-our-services/participate-nebef-mechanism) Furthermore, aligning these incentives with broader goals (zero carbon emission, energy efficiency, grid stability, etc.) is crucial for further encouraging stakeholders’ participation. For this to be realised, (counter) incentives that push consumers back to re-gasification (i.e. using natural gas for their operation instead of electricity) will need to be phased out entirely. Along with failing to achieve the climate objectives, no tangible demand response/flexibility can occur if consumers are pushed towards returning to fossil fuels for their production lines. 3)To ensure RES curtailments are diminished, it is crucial that flexibility is properly incentinvized. Most recent projections foresee an even higher rate of RES curtailments compared to the one mentioned under the NECP. The Greek government needs to provide a suitable framework that will enable harnessing the full potential of technologies’ providing flexibility services. For instance, a PV being curtailed in the wholesale market could compensate its economic loss through offering ancillary services in the balancing markets, thus significantly improving its business case. For this to happen though, a favourable framework for providing flexibility services will need to be in place. Specific measures could include setting up non-fossil flexibility support schemes (as prompted also by Article 19g of the revised EC Regulation 2019/943), allow bidding with negative prices on the mFRR down segment or a wider national capacity remuneration mechanism that would promote the participation of flexibility services -> While the installation of smart meters in households is a prerequisite for offering demand response services at low voltage (households & small customers/industry), we find that this measure will not instantly unlock demand response’s full potential at this level. Without the necessary education and smart devices’ equipment, a smart meter cannot act as a silver bullet suddenly making demand response happen for low voltage customers. The Greek government should therefore consider and promote the use of smart systems (not just smart meters) that could enable the expansion of demand side services for low-voltage customers. -> As prompted by Article 19e of EU Regulation 2019/943, assign the NRA or a different body with the task to adopt a report on the estimated flexibility needs for a period of at least the next 5 to 10 years at national level, in view of the need to cost effectively achieve security and reliability of supply and decarbonise the electricity system considering (as mentioned in the Article) “[..] the potential of non-fossil flexibility such as demand response and energy storage, including aggregation and interconnection, to fulfill the flexibility needs, both at transmission and distribution levels [...] and “[...] evaluate the barriers for flexibility in the market and propose relevant mitigation measures and incentives, including the removal of regulatory barriers and possible improvements to markets and system operation services or products;[...] Readily, available, cost-effective and fossil-free flexibility solutions is a win-win solution compared to the traditional approach of relying on fossil fuels or length and costly infrastructure development. This is not a future solution; it's a critical capability we need right now. The current and growing demand for flexibility in our energy system cannot be ignored.