Position Paper

We need an integrated systems perspective to fully harness flexibility in the Electricity Market Design.

The undersigned organisations include Eurogas, Cogen Europe, EBA, EUGINE, EUTurbines, and Hydrogen Europe and represent multiple energy carriers and integrated energy solutions.

While demand response and electricity storage can contribute to a certain extent to address short-term flexibility needs, we need a range of non-fossil and low-carbon flexibility services to ensure the lowest cost and most optimal balancing of supply and demand over all timeframes.

In this context, the electricity market should not be regarded as a silo within the energy system. Instead, the considerations laid down in the “EU Strategy for Energy System Integration” should be taken seriously.

The quickest path to an affordable and climate-neutral power system is a flexibility that can be provided via an integrated energy system approach that adequately considers the benefits of a decarbonised gas system and of existing and less carbon-intensive solutions.

We encourage negotiators to consider the benefits of an integrated energy system and the efficiency and flexibility it generates, with the aim to accelerate decarbonisation, increase energy resiliency and protect consumers from price shocks. Optimising existing infrastructure, including through the integration of renewable gases and fuels should be allowed to contribute to the flexibility objectives.