Archives for Consultation Responses

Europex Feedback to the Amendment of the EU Emissions Trading System Inception Impact Assessment

Brussels, 26 November 2020 | Europex welcomes the Commission’s initiative to review the EU Emissions Trading System (EU ETS) to align it with the increased decarbonisation climate targets for 2030 and net zero by 2050. The emissions and energy markets will be key in delivering on Europe’s climate ambitions and scaling up innovative low-carbon technologies as well as renewable energy sources for electricity (RES). As Europe’s most successful policy to combat climate change, the EU ETS is the right tool to incentivise emissions reductions where they are most efficient and to promote investments in clean technologies, providing consistent carbon pricing
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Public consultation on the ACER study on efficient price formation and easy market entry and participation for new players and smaller actors in electricity markets

Brussels, 1 November 2020 | The objective of this consultation is to gather views and information from stakeholders regarding the ongoing ACER study on efficient price formation and easy market entry and participation for new players and smaller actors in electricity markets, developed in accordance with Article 15 of Regulation (EU) 2019/942. Europex welcomes the opportunity to provide input to the process of identifying barriers and developing indicators. We provide below our responses to selected questions in the consultation.
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Europex response to ACER and ENTSOG consultation on EU Gas Balancing Suspected Misconduct

Brussels, 19 October 2020 | Europex fully supports effective implementation of the BAL NC which lays the foundation for market-based balancing. We therefore welcome the process initiated by ACER and ENTSOG to tackle balancing misconduct and mitigate the risk of defaulting network users. In the attached document we provide our responses to the consultation questions as contained in the consultation document.
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Europex response to public consultation on the revision of the Energy Taxation Directive (ETD)

Brussels, 14 October 2020 | Europex supports a revision of the Energy Taxation Directive (ETD) in order to enable the transition towards climate neutrality. This is an important opportunity to ensure that energy taxation policy supports the objectives of the Internal Energy Market and ensure that consumers can benefit from incentives provided by price signals from the electricity and gas wholesale markets. The energy mix is changing, with higher shares of renewable gas and electricity. In a sector integration context, electricity and gas will increasingly compete as energy carriers. Against this backdrop, our response focuses on two aspects – the
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Europex response to the EU Offshore Renewable Energy Strategy

Brussels, 24 September 2020 | Europex fully supports the development of a comprehensive EU strategy on offshore energy, which is needed to help scale up offshore energy deployment and ultimately contribute to the decarbonisation of the European energy system. While there are many important issues that the strategy must address, our response focuses on the following regulatory and market aspects: a) Integration of offshore energy into the market / financing models; b) Building up the necessary grid infrastructure; c) Regulatory aspects of hybrid or joint offshore projects; d) Developing offshore wind as part of wider energy system integration efforts. The
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Feedback to DG ENER-Trinomics-LBST draft study “Sector Integration – Regulatory Framework for Hydrogen”

Brussels, 11 September 2020 | Europex fully supports efforts in this study to identify the appropriate EU regulatory framework for dedicated hydrogen networks and markets. Traded hydrogen markets, supported by certificates for hydrogen (based on GOs), have the potential to play a key role in the decarbonisation of the EU energy system. The first priority is the development of both supply and demand of hydrogen, enabling access to hydrogen for a wide variety of actors from all sectors. However, while hydrogen markets may well develop on a regional basis, or in clusters, it is important to already put in place
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Europex response – REMIT fee design & implementation consultation

Brussels, 24 July 2020 | Europex welcomes the opportunity to take part in the present consultation. Below we provide our input to the Commission’s online questionnaire in an amended format to facilitate its publication on the Europex website. Europex considers the following points, among others, to be of key importance: Charging the fees directly to Market Participants would the most efficient approach with RRMs collecting the fee as intermediaries. There would be significant risk of distortion of competition between different types of RRMs should the fee be charged directly to RRMs; The fee calculation must not discourage trading on regulated
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Europex response to Revision of Regulation (EU) 347/2013 on guidelines for trans-European energy infrastructure (TEN-E Regulation)

Brussels, 13 July 2020 | Europex fully supports efforts to ensure trans-European energy infrastructure is fit-for purpose and consistent with the 2050 climate neutrality objective. The TEN-E Regulation and related CEF Energy funding has made important contributions towards improved connection levels of the Internal Energy Market, allowed energy to be traded across borders and increased security of supply. We believe the revised TEN-E Regulation should now reflect the needs of a rapidly evolving energy system, with a view to enabling the integration of higher shares of renewable energy, at a more decentralised level. Greater integration between the different energy sources
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Europex Response to the ESMA MiFID II / MiFIR Review Report on the Transparency Regime for Non-Equity Instruments and the Trading Obligation for Derivatives

Brussels, 12 June 2020 | Europex fully supports the objectives of MiFID II / MiFIR and the G-20 Pittsburgh commitments to “improve the functioning and transparency of financial and commodity markets and address excessive commodity price volatility”. We equally agree with the general intention of the MiFIR pre-trade transparency regime which is meant to work towards this larger policy objective. However, we believe the current calibration of the illiquid (“IL”) and Large in Scale (“LIS”) waiver thresholds severely limits the development of niche and nascent contracts traded on secure and transparent exchanges and cleared through risk mitigating CCP clearing houses.
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Europex response to Commission consultation paper for the EU climate ambition for 2030 and for the design of certain climate and energy policies of the European Green Deal

Brussels, 11 June 2020 | Europex, the Association of European Energy Exchanges, welcomes the opportunity to take part in the present consultation. The European Green Deal must be a central pillar of the EU’s recovery efforts in the aftermath of the COVID-19 pandemic and in response to the looming climate and environmental crisis. Against the background of the intended 2030 Climate Target Plan and its subsequent legislative implementation, the opportunity should now be taken to put in place a coherent EU-wide policy framework to deliver the raised emissions reduction ambition at the least cost. With this in mind, it is
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