Archives for Consultation Responses

Europex Feedback on the Inception Impact Assessment on the Digital Levy

Brussels, 10 February 2021 | Europex supports the Commission’s overall objective to ensure a fair taxation of the digital economy in line with the wider G20 and OECD discussions and welcomes the opportunity to comment on the scope of the initiative. As stated in the Inception Impact Assessment (IIA), it is important that the Commission accurately determines the scope and definition of digital activities, transactions and entities subject to the digital levy. This is a crucial part of the preparatory work for a legislative proposal, considering the great variety of business models and companies active in the digital economy. While
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Europex response to the review of RED II on the promotion of the use of energy from renewable sources

Brussels, 9 February 2021 | Europex welcomes this opportunity to contribute to the Commission consultation of the Review of RED II on the promotion of the use of energy from renewable sources. In this paper we extract critical points raised in the consultation questionnaire that underpin the need to modify RED II and explain how such a review will support the integration of renewable energy sources while minimising unnecessary market distortions. RED II needs to be modified to align it with the clear market-based approach taken by the Electricity Regulation and Directive and with the cost-efficient decarbonisation objectives of the
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Europex Consultation Response: Updating the EU Emissions Trading System

Brussels, 4 February 2021 | Europex welcomes the opportunity to participate in the Commission’s public consultation to update the EU Emission Trading System (EU ETS) and align it with the increased decarbonisation targets. The EU ETS is Europe’s most successful policy to combat climate change and the key carbon pricing instrument to reduce greenhouse gas (GHG) emissions at least cost. To this end, it is important to ensure that this revision strengthens the role of the EU ETS and continues to commit to strong market principles that safeguard the undistorted price signals, efficiency, transparency and liquidity of the emissions market.
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Public Consultation for the Revision of the Guidelines on State aid for Environmental protection and Energy 2014-2020 (EEAG)

Brussels, 7 January 2021 | Europex recognises the need to review the EEAG guidelines in the context of the European Green Deal initiatives and the objective of achieving climate neutrality by 2050. The revised guidelines should build on the clear market design framework as set out in the Clean Energy Package and take particular care to avoid undue distortions of competition in the Internal Energy Market. Despite the high fixed cost structure of renewables as well as the need for predictable revenue streams, market-based remuneration of renewables in the energy market offers the most cost-efficient way of achieving decarbonisation, especially
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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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