Archives for Position Papers

Net zero at least cost: energy and emissions markets at the core of cost-efficient decarbonisation

Brussels, 17 February 2020 | Achieving a climate neutral economy by 2050 presents a significant challenge that will require fundamental changes across many sectors. Open, competitive, transparent and liquid power, gas and emissions markets are among the core tools necessary to reach the EU’s 2050 net zero target cost-efficiently. Agreement on the 2050 neutrality objective itself represents an important milestone which we explicitly welcome. To help achieve this, close attention must be paid to the instruments and mechanisms required, including how to trigger the necessary innovation and investment and to achieve decarbonisation at the least cost to the consumer, the
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A market-based approach to local flexibility – design principles

  Brussels, 12 February 2020 | Increasing the share of renewable energy generation in the energy mix is vital for decarbonisation, yet intermittent renewables such as wind and solar power can put pressure on the capacity of local and regional grids, requiring costly grid management measures from the network operators, both TSOs and DSOs. At the same time, decentralised resources are being deployed at an increasing rate, including, among others, storage assets and electric vehicles interacting with the grid. Active customers will increasingly be able to offer demand-side flexibility, either directly or through aggregation services. Ways must be found of
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MiFIR Pre-Trade Transparency: Call for a Methodology for the Conversion of LIS Notional Values to Lots

Brussels, 15 July 2019 | Europex and its members are committed to working with ESMA and the NCAs to ensure that markets continue to become more transparent in line with the policy objectives of MiFID II/MiFIR. In this context, we take note of the recently published “ESMA Supervisory Briefing on compliance with MiFIR pre-trade transparency requirements in commodity derivatives” and welcome ESMA’s commitment to review the currently inappropriately calibrated pre-trade transparency regime. As stated at earlier occasions, the enforcement of full compliance should be postponed until after the review of RTS 2 as otherwise irreparable damages would be caused to
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The “Road from Sibiu”: making use of markets for a cost-efficient and innovation-driven transition to full climate neutrality by 2050

Brussels, 9 May 2019 | Today, a long and intense debate on the “Future of Europe” that started two years ago in Rome comes to a close at a European Council summit in Sibiu. One of the key topics of this strategic exchange has been Europe’s future climate and energy policy, notably with regard to the EU’s Clean Planet for All strategy and the overall United Nations Framework Convention on Climate Change process. In this context, we call upon the European leaders gathered today in Sibiu to keep up with their Paris commitments and to include a strong recognition of
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Article 13 (9) of the Electricity Regulation: The basic implementation phase for reconfigured bidding zones should be 24 instead of 12 months

Brussels, 8 November 2018 | Ensuring bidding zones are configured efficiently is necessary in order to address long-term structural congestion. However, any change to the configuration of bidding zones has a fundamental impact on the functioning of wholesale electricity markets. While the change itself, once implemented, may bring about overall benefits the transition process itself comes at a cost which is ultimately passed on to the electricity consumers. In order to minimise this cost and to leave the market enough time to adapt, the implementation phase needs to be appropriate and must guarantee a smooth transition. Recent experience has shown
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Capacity allocation in Article 14 of the Electricity Regulation recast: Setting the right principles to maximise transmission capacity available for trading in order to foster further market integration

Brussels, 8 November 2018 | In the EU’s internal energy market, the amount of trade between bidding zones is constrained by the amount of available cross-zonal transmission capacity. Maximising the amount of the cross-zonal capacity available to the market, while respecting necessary operational security standards, is therefore a prerequisite for achieving an efficient integrated internal energy market and realising the associated increase in welfare. In this context, the process to calculate and allocate capacity on the bidding zone borders is vitally important. However, there is significant scope to improve the current situation. The ACER 2017 Market Monitoring Report (MMR) compared
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Electricity market design – Europex positions on the Electricity Regulation, Electricity Directive and the ACER Regulation

Brussels, 11 October 2018 | The trilogue negotiations for the electricity market design files (the draft recasts of the Electricity Regulation, Electricity Directive and ACER Regulation) are well under way. At this stage it is crucial that all parties can agree on workable solutions grounded in market realities. Overall, this is an opportunity to ensure that wholesale markets are efficient, accessible and are ready to meet the challenges of the energy transition. This paper raises five aspects emerging from the negotiations so far which we believe are necessary to address or maintain. A comparison of the positions of the Commission,
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Common energy sector statement – Keeping EU energy and emissions markets protected from VAT fraud beyond 2018

Urgent need to confirm the extension of the derogation for a domestic reverse charge mechanism for electricity, gas and emission allowances in Art. 199a of the VAT Directive Brussels, 4 September 2018 | Missing Trader Intra-Community Value Added Tax fraud remains a persistent threat to the integrity and well-functioning of electricity, gas and emission allowance markets in Europe. Billions of euros had been defrauded from European Exchequers before the Council of the EU decided on the introduction of a derogation from the VAT Directive for electricity, gas and emission allowance transactions. The derogation enables Member States to apply the Domestic
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The Essential Tasks of Third Party Market Operators/Facilitators in the Electricity Market (update)

Brussels, 16 August 2018 (updated)| In a number of EU Member States/EEA countries, certain functions related to the operation of the electricity market, which are necessary for the electricity market to work efficiently, are carried out by non-TSO third parties rather than by TSOs. These third parties, also called “Third Party Market Operators/Facilitators”or“Delegated Operators”, and the vital roles they play,are recognised in the European Network Codes and Guidelines. The tasks performed by these third parties include, among others, imbalance calculation and settlement, data publication related to electricity balancing markets and issuing of the rules related to balancing markets. These tasks
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MiFIR pre-trade transparency regime: making it work for commodity derivatives – recommendations

Brussels, 25 June 2018 | The purpose of this paper is to provide ESMA and National Competent Authorities with specific recommendations in support of their work with regard to amending certain parts of Regulation 2017/583 (‘RTS 2’)1, relating to the MiFIR pre-trade transparency regime for non- equity products. Europex members have long argued that, in its present form, the regime is not fit for purpose and cannot be applied to trade registration facilities in energy derivatives markets. Should these pre- arranged trades be no longer reported to regulated markets for clearing purposes, this would compromise their vital role in supporting
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