EUROPEX

Response to ACER public consultation on technical requirements for data reporting under REMIT and to ACER Guidelines for the registration of Registered Reporting Mechanisms and for the registration of Regulated Information Services

In its response EUROPEX highlighted to be necessary that from day one of the full implementation of REMIT, market participants should be required to report all trading data including orders from all market places – be they exchanges or brokers. Otherwise, there would be a sincere threat of regulatory arbitrage and infringement with regard to the level playing field between orders traded through exchanges and/or brokers. See more...

7 May 2013

Response to EC (DG ENER) Consultation Paper on Generation Adequacy, Capacity Mechanisms and the Internal Market in Electricity

Europex welcomes and broadly supports the public consultation of the European Commission. The considerable development of electricity production from (intermittent) renewable energy sources has led to a critical need to ensure consistency throughout Europe on some aspects of the energy policy. This is necessary to avoid significant market distortions that could otherwise lead to an inefficient use of transmission capacities, decreased competition and a degraded price formation resulting in higher cost for the community and possibly lower security of supply. See more...

14 Feb 2013

Response to EC (DG ENER) Public Consultation on the Implementation of Data and Transaction Reporting Framework for Wholesale Energy Markets

In responding to EC public consultation, EUROPEX showed its concerns stating that the European Commission seems to be under the impression that Energy Exchanges can be considered as market participants under REMIT. We do not agree with this interpretation as it would clearly create a conflict of interest between the role and responsibility of Energy Exchanges as entities that bring together market participants’ buying and selling interests... furthermore, it considers to be absolutely necessary that from the start of the full implementation of REMIT all contracts and orders are collected from all market places – be it exchanges or brokers. See more...

07 Dec 2012

Response to the Gas Regional Initiative North-West consultation on implicit allocation in the gas market

EUROPEX responded to the above consultation agreeing with the National Regulatory Authorities’ vision and analysis on the current issues related to the allocation of cross border capacity and its effects on the gas market. Contractual congestion combined with the absence of a liquid secondary market of capacity is an issue if it prevents cross-border arbitrages that would otherwise be done by other shippers (that currently cannot book short term capacity). However, this is more related to the CMP guidelines implementation than to the implicit allocation debate. See more...

06 Nov 2012

Position in the context of the stakeholder consultation by DG ENER on the implementation of the Data and Transaction Reporting Framework for Wholesale Energy Markets

EUROPEX submitted to the European commission (DG ENER) its position paper regarding the role and responsibilities of organised market places vis-à-vis market participants in general and under REMIT in particular, stressing that Energy Exchanges cannot be considered as market participant as they do not enter into transactions nor do they place orders themselves but only provide a platform for trading. In this respect, they are correctly cited as an example under ‘organised market place’ in RECITAL 20 of REMIT. The scope of REMIT has been clearly defined by the European Parliament and the Council of the European Union. Any modification of the scope and objectives of the framework regulation by the European Commission would jeopardize the correct implementation of REMIT itself.

We are highly supportive of REMIT and are keen to support its implementation as efficiently as possible. This also involves the provision of both transaction and fundamental data to ACER as stipulated in REMIT. See more...

02 Nov 2012

Response to ACER public consultation on Transaction Reporting under REMIT

EUROPEX submitted its contribution to the ACER's public consultation on Transaction Reporting under REMIT underlining that implementation of REMIT and specifically the setting up of the reporting infrastructure will lead to a high level of necessary investments and considerable efforts for all involved stakeholders, be it market participants, market platforms or ACER itself. The further development should therefore be moved forward with a keen sense of proportion in order to further improve energy trading while not risking disproportional burdens which could have a negative impact on the further development of the energy markets. See more…

31 July 2012

Response to ACER public consultation on Draft Framework Guidelines on Electricity Balancing

EUROPEX submitted its contribution to the ACER's public consultation on Draft Framework Guidelines on Electricity Balancing Market, arguing that the Balancing network code should set the minimum level of harmonization required for efficient and integrated cross-border balancing, while leaving as much as possible room for local variations where deemed necessary. See more...

25 June 2012

Response to ENTSOG public consultation on Draft Network Code on Gas Balancing

EUROPEX has submitted its response to the public consultation, stressing that introduction of Virtual Trading Points on which the Network Users and the TSOs are able to buy and sell entry-paid gas is crucial to the development of a properly functioning market. It allows pooling the market liquidity on virtual hubs to which all registered shippers will equally access, allowing them to source or sell gas and to take balancing actions without necessarily having to book and/or nominate capacity. This lowers the entry barrier to supply consumers and fosters competition. It is also consistent with the Gas Target Model endorsed by the Madrid Forum. See more...

12 June 2012

Response to ENTSOE public consultation on Network Code on Capacity Allocation and Congestion Management for electricity

EUROPEX has kept closer dialogue with ENTSOE over the drafting process of the Network Codes on Capacity Allocation and Congestion Management (CACM) and has formally submitted its response to the public consultation, highlighting that CACM Network Code should not aim at putting obligations/requirements on the Power Exchanges. If obligations must be put on Power Exchanges then they should be only in their role of performing the Market Coupling Operator function. In addition, the Network Code is not the proper document to define functions and to designate entities to perform them, as this is the precise objective of the Governance Guideline. See full document…

23 May 2012

Response to ACER public consultation on REMIT Registration Format

In line with our answer to the CEER consultation last year on the “Europe-wide Energy Wholesale Trading Passport” we explicitly welcome the registration approach by REMIT.

In our position at that time we stated that “from our point of view it seems to be more appropriate that a passport has the nature of registration rather than of a certification/licensing system."... We therefore plead that the registration process is as clearly defined as possible, and coordinated with ESMA, excluding the risk of imposing new or double requirements over the course of time “through the backdoor” (no “silent licencing regime”). In order to create fully integrated energy markets, the overall principle should always be that the well-functioning of the wholesale energy markets is not disproportional limited but further facilitated. See more...

21 May 2012

Response to the PwC/Ponton question list on REMIT - Technical Advice for setting up a data reporting framework

EUROPEX submitted its response to the questionnaire of PwC in cooperation with Ponton Consulting, working for the European Commission (DG Energy) on drafting technical advice for the set-up of data reporting framework for REMIT. Energy exchanges welcome the recognition within REMIT that the respective data owners are responsible for data reporting (e.g. traders, power plant operators, TSOs), while allowing for the possibility that third parties can act on their behalf (e.g. brokers, Energy Exchanges, etc.) and highlights that are well suited and highly committed to help market participants to fulfil their reporting requirements. See more...

30 Apr 2012