Brussels, 7 June 2011 | Europex welcomes the consultation by the Agency for the Cooperation of Energy Regulators (ACER) which follows the previous consultation by ERGEG on the Draft Framework Guidelines (FG) on Capacity Allocation and Congestion Management for Electricity (CACM) and the respective initial impact assessment. It is our understanding that FG on CACM should be strictly limited to the matters of capacity calculation, capacity allocation and congestion management in different timeframes and should avoid mixing its scope with issues related to governance and the transparency and integrity of markets. These matters are dealt with elsewhere.
In addition, we raise the attention to ACER and the Regulators that the Target Models for electricity trading should always be defined in a flexible manner, allowing their adaptation to upcoming markets needs and evolutions. This is especially important for emerging markets such as the intra-day one which is still evolving in some countries and will therefore require flexibility of design. Beside the avoidance of too prescriptive descriptions of market designs, this requirement should be reflected by clear and manageable revision clauses to the Target Models proposed in the Framework Guidelines.
Please find the whole consultation response attached.