Archives for Consultation Responses

Joint consultation response on the future of emissions trading in the UK

12 July 2019 | EFET, the Federation of European Energy Traders, and Europex, the Association of European Energy Exchanges welcome the opportunity to take part in the present consultation on the future of emissions trading in the UK, launched by the Department for Business, Energy and Industrial Strategy (BEIS). Importantly, we would like to highlight that the basic principles of continuity and predictability of carbon pricing are key for preserving well-functioning electricity, gas and emissions markets in the United Kingdom. The prevailing uncertainty about the continued participation of the UK in the EU ETS post-Brexit, and about the way in
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Europex response to the EC Targeted Consultation for the Evaluation of the Guidelines on State Aid for Environmental Protection and Energy 2014-2020 (EEAG)

Brussels, 10 July 2019 | Europex, the Association of European Energy Exchanges, welcomes the opportunity to respond to the European Commission’s consultation in the context of the Evaluation of the Guidelines on State Aid for Environmental Protection and Energy 2014-2020. Europex supports theEuropean Commission’s goal to bring the guidelines in line with new electricity market developments and to ensure the market integration of renewables, a stable regulatory framework for investments in renewables and a cost-efficient achievement of the set renewable targets. It is worth recalling that power exchanges are increasingly central to the cost-efficient integration of renewable energy sources in
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Europex response to the ESMA call for evidence on position limits in commodity derivatives

Brussels, 5 July 2019 | Europex, the Association of European Energy Exchanges, welcomes the opportunity to contribute to the ESMA call for evidence on position limits and position management in commodity derivatives. Europex has actively participated in previous public consultations on the MiFID II/MiFIR package, including on the position limit regime as well as on its implementing legislation and the related regulatory guidance. The present call for evidence offers an important opportunity to review the regime 18 months after its entry into application. Importantly, Europex supports the policy objectives of MiFID II/MiFIR to ensure transparency and prevent abuse in commodities
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Europex response to the CEER Public Consultation on Regulatory Challenges for a Sustainable Gas Sector

Brussels, 17 May 2019 | Europex is pleased to contribute to the present consultation on a sustainable gas sector and welcomes the associated stakeholder dialogue. We are convinced that gas will continue to play an important role in the future energy mix as a flexible source of energy, able to compensate for the growing share of intermittent renewable sources and to act as a large-scale energy carrier. In view of the EU’s 2030 and 2050 climate and energy goals, it is clear that the gas sector will have toundergo a transformation process and that renewable and decarbonised gases will play
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Europex response to the Commission consultation on the revision of the EU ETS state aid guidelines

Brussels, 16 May 2019 | The EU ETS plays a vital role as the EU’s primary instrument for reducing greenhouse gas emissions cost-effectively while incentivising innovation and change. Importantly, well-functioning emissions markets, as part of a clear and stable climate policy framework, provide long-term predictability for companies. Keeping to such a clear framework will not only minimise the risk of carbon leakage but create additional investments and opportunities in Europe. Hence, while they may be considered necessary to tackle the risk of carbon leakage as a consequence of the transnational EU ETS, national measures to compensate sectors at particular risk
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Europex response to the CEER Public Consultation on Dynamic Regulation to Enable Digitalisation of the Energy System

Brussels, 14 May 2019 | The CEER Consultation Paper on Dynamic Regulation to Enable Digitalisation of the Energy System elaborates on the implications of digitalisation for the energy sector and for consumers in particular. It considers the changes that may be needed to empower and unlock the benefits of digitalisation for consumers and to protect them against the risks. Selected highlights from the Europex response to the consultation are included below. B1. What impact do you consider that digitalisation will have on the energy system and which are the most important? Digitalisation will enable the emergence of new business models
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Europex feedback at intermediate stage of Commission study on sector coupling

Brussels, 20 March 2019 | Europex, the Association of European Energy Exchanges, welcomes the opportunity to provide feedback at this intermediate stage of the Commission study on “Potentials of sector coupling for decarbonisation – Assessing regulatory barriers in linking the gas and electricity sectors in the EU”. A cross-sectoral approach, including electricity and gas both conventional and renewable, is necessary in order to develop more system flexibility, to free up unused cross-sectoral potential and to increase the coordination and competitiveness between the gas and electricity sectors. Developing and enhancing this potential is a pre-condition for successfully implementing the energy transition
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Europex response to the BMF consultation on MiFID II experiences

Brussels, 15 March 2019 | Europex, the Association of European Energy Exchanges, welcomes the opportunity to contribute to the present consultation on MiFID II / MiFIR experiences1. In the following, we would like to share our concerns on three main aspects: 1) pre-trade transparency requirements for commodity derivatives, 2) position limits for commodity derivatives and 3) the scope of the hedging exemption in relation to the previous two points. 1) Pre-trade transparency requirements for commodity derivatives (MiFIR, Arts. 8 & 9) Europex members have long argued that the MiFIR pre-trade transparency regime in its present form is not fit for purpose
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Europex response to the Commission consultation on the strategy for long-term EU greenhouse gas emissions reductions

Brussels, 9 October 2018 | Europex, the Association of European Energy Exchanges, welcomes the opportunity to participate in the present forward-looking consultation. In our response, we would like to underline the importance of stable and predictable energy and climate policies in the mid-century perspective. The development of a strategy for long-term EU greenhouse gas emissions reduction is an important step in this process and should provide guidance for short- and mid-term action. The fight against climate change, the energy transition and the need for cost-efficient decarbonisation brings unprecedented challenges which the entire energy sector and society at large have to
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Europex response to the CEER Public Consultation on the draft 3D Strategy and CEER 2019 Work Programme

Brussels, 9 August 2018 | Europex welcomes the efforts by the Council of European Energy Regulators to address upcoming challenges of the energy sector with a 3D strategy. An increasingly interconnected and interdependent European Internal Energy Market requires enhanced cross-border cooperation. The energy transition and digitalisation bring unprecedented challenges which the entire sector has to address. We believe that the regulatory framework should keep focusing on reducing emissions, keeping costs low and maintaining a high level of security of supply. At the same time, it should encourage innovation and change and support new opportunities stemming from these fundamental developments. A
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