EASE Response to ENTSO-E Stakeholder Consultation on FCR CBA

EASE submitted a response to the ENTSO-E stakeholder consultation on the "All CE and Nordic TSOs’ results of CBA in accordance with Art.156(11) of the Commission Regulation (EU) 2017/1485 of 2 August 2017" report. 

EASE welcomes the efforts of ENTSO-E and the TSOs of the CE and Nordic synchronous areas to propose assumptions and methodology for the CBA to be conducted, in order to assess the time period required for FCR providing units or groups with limited energy reservoirs to remain available during alert state.

EASE supports setting Tmin for FCR providers with LER to 15 minutes, however, EASE notes that the methodology itself should be re-assessed before it is possible to carry out the CBA and based on that, to discuss the results. Therefore, EASE would like to draw the attention to the number of assumptions and design choices in the methodology leading to biased results in disadvantage of FCR units with limited energy reservoir, both coming from the methodology and CBA.