Archives for Consultation Responses

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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Europex feedback on the Preparation of the EU Hydrogen Strategy

Brussels, 8 June 2020 | Europex welcomes the Commission’s initiative to develop a dedicated EU Hydrogen Strategy. We are convinced that traded markets can and will act as enablers for a future usage of hydrogen on a broader scale, including in those sectors where it still has very limited penetration such as transport, buildings and power generation. Given the importance and complexity of the topic, there should be strong stakeholder involvement in both the development and implementation of the EU Hydrogen Strategy. It is key that the integration of hydrogen into the Internal Energy Market is considered from the beginning
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Europex response to the Commission consultation in preparation of an EU Strategy on Energy System Integration

Brussels, 4 June 2020 | Europex supports a vision of an integrated energy system in which the various energy carriers or forms of energy (electricity, gas, liquids, heat, cold etc.) can be linked with each other as well as with the end use sectors (buildings, mobility, industry, agriculture, households) in order to optimise the energy system as a whole, i.e. producing, transporting and consuming energy in the most sustainable and cost-efficient way possible. To enable this goal, well-functioning energy and environmental markets are required to stimulate competition and innovation, allowing the most efficient technologies to emerge. When developing regulation to
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Europex response to Commission consultation on the review of the MiFID II/MiFIR regulatory framework

Brussels, 18 May 2020 | Europex fully supports the underlying policy 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”. However, more than two years after the MiFID II / MiFIR framework started to apply, we believe that these objectives have not yet fully materialised as far as commodity derivatives markets are concerned, notwithstanding the heavy burden already imposed on the industry. This concerns in particular the MiFID II position limits and position management regime as well as the MiFIR pre-trade
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Europex response to the Commission consultation on the priority list for the development of network codes and guidelines on electricity for the period 2020-2023 and on gas for 2020 (and beyond)

Brussels, 14 May 2020 | Europex, the Association of European Energy Exchanges, welcomes the opportunity to take part in the present consultation. Our response addresses the proposed priorities for new electricity network rules on cybersecurity and demand-side flexibility.   Please download the full consultation response below.
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Europex response to ACER consultation on bidding zone review methodology

Brussels, 24 April 2020 | The bidding zone review and resulting decision on the configuration has fundamental consequences for the electricity market in all timeframes. Europex welcomes the opportunity to provide input into ACER’s public consultation on the methodology and assumptions to be used in the bidding zone review process. It is important to ensure that there is robust and transparent analysis supporting both the development of the alternative configurations and their evaluation against the CACM criteria. The assessment of the configuration impact on market efficiency, competition, liquidity and overall welfare must consider both short-term and forward markets, and use
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