Archives for Consultation Responses

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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The need to simplify and streamline reporting obligations under EMIR, MiFID II/MiFIR and REMIT – Europex response to Commission fitness check on supervisory reporting

Brussels, 14 March 2018 | Europex welcomes the opportunity to take part in the “fitness check on supervisory reporting” of the European Commission and to discuss the effectiveness and efficiency of existing EU-level supervisory reporting requirements. We deeply believe in the simplification and streamlining of regulatory reporting. Electricity and gas derivative contracts are covered by reporting obligations stemming from four pieces of legislation: namely EMIR, MiFID II/MiFIR, REMIT and MAR. This constitutes a heavy reporting burden for energy exchanges and clearing houses as well as for market participants. Consequently, there is a need to streamline the requirements in order to
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Europex response to the consultation on the ‘First Edition Bidding Zone Review’

Brussels, 9 March 2018 | Europex’ response is divided into two parts. Comments on the content of the draft report for public consultation are provided first, followed by comments concerning the process of the First Edition Bidding Zone review. 1. Feedback on the First Edition Bidding Zone Review: Draft report for public consultation Selection of expert-based bidding zone configuration: Configuration selection is a vital part of the review, which defines the framework of the study. The selection of the four alternative expert-based configurations developed by the TSOs is described in section 4.1, taking each scenario in turn. It is explained
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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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