Archives for Consultation Responses

Europex response to ACER’s public consultation on the “Proposed Changes to Electronic Formats for Transaction Data, Fundamental Data and Inside Information Reporting”

Brussels, 8 November 2017 | Europex welcomes the opportunity to take part in ACER’s public consultation on the Proposed Changes to Electronic Formats for Transaction Data, Fundamental Data and Inside Information Reporting. As a matter of principle, Europex supports the effort of ACER to enhance data quality for monitoring purposes and to implement a simplification of the reporting format. Despite these improvements, however, we would like to highlight that any change(s) to the already established reporting format will: create implementation costs which will be passed on to market participants and end consumers; increase system operation risks; potentially affect the reliability
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Europex response to ENTSO-E’s public consultation on Key Organisational Requirements, Roles and Responsibilities (KORRR)

Brussels, 1 December 2017 | Europex has submitted its response to ENTSO-E’s public consultation on the All TSOs’ proposal for the Key Organisational Requirements, Roles and Responsibilities (KORRR) relating to Data Exchange in accordance with Article 40(6) of the Commission Regulation (EU) 2017/1485 of 02 August 2017 establishing a Guideline on Transmission System Operation (SO GL). Europex suggests deleting Article 19 of the present proposal. We understand the approach to mention all involved parties in the data exchange process. However, the obligation for NEMOs to share market results and cooperate with TSOs is already stipulated in other EU legislation, including
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VAT fraud – A persisting threat to gas, electricity and emissions trading. Need for a prolongation of existing derogation and an extension to all Member States

Brussels, 31 May 2017 | The VAT fraud in energy and emissions trading continues to pose a serious threat to European Exchequers and energy and emissions markets alike. The existing preventive mechanisms, like the derogations enabling Member States to implement a domestic reverse charge mechanism on gas, electricity and emissions transactions between taxable persons and taxable dealers as resellers, need to be continued and further extended. Active action must be taken by the European Commission, the Council of the EU and the relevant bodies at Member State level to protect energy and emissions trading from a repetition of large scale
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Europex response to DG COMP consultation on “Interim Report of the Sector Inquiry on Capacity Mechanisms”

Brussels, 6 July 2016 | Europex welcomes the opportunity to provide feedback on the present CRM Interim Report. We are committed to further engage in a dialogue with the European Commission and other stakeholders on this important matter, which has far reaching implications for the efficiency of the wholesale electricity market and the security of supply in the rapidly changing European power system. Our members are predominantly active in different regional and local settings with different fundamental needs and purposes. This is also reflected in the different scopes of CRMs, including the more limited strategic reserves. Nevertheless, a set of
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Europex responds to ACER public consultation on REMIT – Functioning and Usefulness of the European Register of Market Participants

Brussels, 22 April 2016 | Europex welcomes the opportunity to respond to ACER’s public consultation on the “Functioning and Usefulness of the European Register of Market Participants” under REMIT. While we generally support the proposal put forward by ACER to improve the quality and utility of the CEREMP data, we would like to highlight a number of concerns in reaction to Question 5 and Question 12 of the present consultation. Please find the consultation response attached.
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