Europex welcomes ACER’s recognition of the importance of long-term forward hedging and efficient, liquid, and transparent forward markets as central features of the Internal Electricity Market – both of which contribute significantly to the overall welfare benefits of the integrated European electricity market. However, 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.
While the aim of this paper is to review the Forward Capacity Allocation Guideline (FCA GL) model in the EU, its scope seemingly extends far beyond this narrow mission to also review the forward power markets, including MIFIDII/MIFIR/EMIR regulated financial markets. In addition to the concerns expressed throughout the rest of this response, we urge ACER to carefully consider what this process seeks to accomplish and the overarching effects such a broad review could have.
Please see our full response for more detail.