Energiateollisuus Statement on Draft Finnish FNA Report (2026)

The industry association Energiateollisuus’ consultation response (case no. 2380/040503/2026, dated 31 Aug 2026) to Energiavirasto’s consultation on the draft Finnish national FNA report. According to a search-index copy of Energiavirasto’s consultation notice (16 Jul 2026, comments due 31 Aug 2026), the draft was prepared by Fingrid at the request of the Ministry of Economic Affairs and Employment and covers the study years 2030 and 2035; Energiavirasto approves the final report before it goes to ACER and the Commission. The draft itself is not publicly retrievable: the consultation page returned 404 on 5 Oct 2026 and no PDF copy was found, so the notice text is not in the raw folder. This statement is therefore the only public place where the draft’s wording appears, through three passages it quotes in English. Process background: Source - Energiavirasto Finnish FNA Process Documents (2025-2026).

What the statement quotes from the draft

• Summary. Demand-side response “was excluded from the portfolio of flexible resources considered in the assessment due to uncertainties regarding its practical availability and utilisation”. A sensitivity analysis indicated that “if full demand side response potential were assumed to be available at all times, uncovered ramping needs would be reduced to nearly zero”.
• Section 2.2.4. Demand response “is expected to only participate in day-ahead market and it is not included as flexible resource due to lack of data and uncertainties”.
• Section 5. “The results indicate that future flexibility needs cannot be met solely with the resources currently assumed to be available, highlighting the potential need for additional flexible capacity in the Finnish power system.”

The statement also says the draft assumes renewable forecast errors stay at roughly today’s level through the whole study period, that it uses ERAA 2024 starting assumptions, that DSO results are shown as per-company averages, and that it is built on Energiavirasto’s market report for 2024.

Energiateollisuus’ main points

1. DSO results. Show the DSOs’ summed flexibility needs, not only per-company averages, and state how many network companies took part.
2. Level of detail. The report is “fairly general” relative to the analysis behind it; more background and detailed results are needed to use it.
3. ERAA 2024. Its assumptions do not fully match the industry’s view of the future system; hydrogen and electrolysers, data centres, storage and electrifying industry should be treated more fully, on both the need and the supply side.
4. Demand response left out. Excluding it gives an incomplete picture and may lead to overestimated needs. The association asks, at minimum, for a sensitivity analysis, and asks that the section 5 conclusion on additional capacity be removed or qualified, because the draft cannot separate real resource shortage from the effect of the scoping choice.
5. Forecast errors. Market actors have strong incentives to improve forecasts and better data and AI-based methods may help, so the report should assess the assumption’s effect and describe qualitatively how better forecasts would change the needs.
6. Barriers and flexible connections. The current regulatory framework does not sufficiently support Flexible Connection Agreements; they should be possible for new and existing connections and, where technically and economically justified, as permanent arrangements. The report should treat barriers to using flexibility more broadly, including technology-neutral rules and equal access for all flexibility resources.
7. System protection. Reviewing the technical requirements of järjestelmäsuoja (system protection) could release a large amount of flexible resources quickly and might materially reduce the flexibility need the FNA identifies.
8. Outdated data. The draft rests on Energiavirasto’s market report for 2024, although the 2025 edition was published on 10 Jul 2026.

Reading notes

• Energiateollisuus is the Finnish energy industry association and argues from that position. Its claim that leaving out demand response may overstate needs is an argument about the draft, not a finding, and the numeric results of the draft are not quoted anywhere in the statement.
• No Finnish need volumes (MW or MWh) are public in any document found. The final approved report had not been located as of 5 Oct 2026.

Relevance to existing wiki topics

• Flexibility Need Assessment — the Finnish first cycle; a contrast with Sweden, where FNA 2026 covers only distribution-network needs
• Demand Response — a national FNA that scopes demand response out of the resource portfolio, with a sensitivity case showing it would nearly remove uncovered ramping needs
• Flexible Connection Agreements — Finnish industry asks for permanent flexible connections