Europex and the All NEMO Committee appreciate the opportunity to engage in this dialogue concerning the review of CACM GL. The rules established in CACM are partly the result of successful collaboration in preceding years between exchanges and TSOs in establishing targets models, including the implicit allocation in DA and ID timeframes and further laying the foundations for multi-regional coupling. The formalisation of these rules in CACM on capacity allocation, congestion management and cross-zonal trade in electricity has been a crucial step towards a genuinely integrated electricity market.
Continuing these efforts, the CACM review should build on successfully implemented concepts, including what has been learnt from exchanges, TSOs, regulators and other stakeholders. For example, while capacity calculation methodologies (CCMs) are defined at regional level, relevant improvements that are worth harmonising should be brought into the CACM guideline (e.g. consideration of remedial actions in capacity calculation, other aspects related to flow-based capacity calculation and so on).
Evolution, rather than revolution, is needed. Changes to CACM should aim to retain what is already working well or currently being implemented. Coherence with other NCs and GLs is important, and some aspects can be further clarified. The proposed changes should not delay or block current development. The costs already spent on implemented solutions and roles of NEMOs and TSOs should be taken into account.
Where detailed rules have been established in the Clean Energy Package / Electricity Regulation (ER) (e.g. 70% cross-zonal capacity threshold, rules for conducting the bidding zone review etc.), the CEP should take precedence and CACM should cross-reference to this legislation rather than attempt to duplicate it or risk adding conflicting new elements.
Please see below our feedback per ACER scoping area. NEMO-related topics of MCO governance, SDAC and SIDC and cost are purposefully not dealt with here.