Please see our response to selected questions attached.
Setting the correct level of ambition for 2040 based on a thorough impact assessment is important to ensure a clear investment outlook as well as to build on the existing decarbonisation framework in a well-structured manner.
Europex welcomes this opportunity to comment on the future design of the European electricity market. Please see our response to selected questions.
Europex welcomes the opportunity to provide feedback to IOSCO’s consultation on compliance carbon markets. Carbon markets play a key role in facilitating decarbonisation at least cost and ensure a high level of competition and innovation.
Demand response, and more generally system flexibility, play a key role in achieving the EU’s decarbonisation targets and securing future system stability as volatile electricity production from renewables will need to increase substantially in the years to come.
We remain critical of how this draft policy paper addresses and assesses the overall functioning of the electricity forward market and the proposals put forth to approach the identified shortcomings.
As the main objective is decarbonisation, clear rules are needed to determine the renewable character of both electricity and RFNBOs, including hydrogen which is likely to play a key role in the future energy mix.
We do not agree with the view that a system where on one side of any trade (buy side or sell side) there is always the same party should be considered multilateral simply because the system is operated by a third party (draft ESMA opinion no. 24).
Europex welcomes the opportunity to participate in this consultation and provide detailed input to the ACER proposal. Please note that we respond only to the selected questions listed in the attached document.
Europex explicitly welcomes and fully supports the Commission’s legislative proposal to extend the derogation in Article 199a of the VAT Directive allowing Member States to apply the domestic reverse charge mechanism (DRCM) to transactions in electricity, gas, emission allowances and Guarantees of Origin (GOs).
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