Using peak-shaving products under normal market circumstances – our input

07 May 2025

EUTurbines provided input to the ACER public consultation on the impact of developing peak-shaving products on the Union electricity market under normal market circumstances, mandated by the last review of the EU electricity market design rules.

EUTurbines largely agrees with the ACER view that extending peak shaving to be used in normal market circumstances will not have any positive impact on security of supply or protecting consumers. We also express concern that focusing exclusively on downward flexibility could undermine system adequacy and decarbonisation objectives. Such an approach risks penalising flexible generation and deterring investment, while neglecting the role of implicit demand-side response.

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