Brussels, 23 May 2012 | Europex welcomes the consultation by ENTSO-E on Capacity Allocation and Congestion Management for Electricity (CACM), which follows the previous consultation on Draft Framework Guidelines by ERGEG and the respective initial impact assessment as well as the consultation by ACER on the same topic. It is our understanding that the CACM Network Code should not aim at putting obligations/ requirements on the Power Exchanges. If obligations must be put on Power Exchanges, then this should be only done in their role of performing the Market Coupling Operator function. In addition, The Network Code is not the proper document to define functions and to designate entities to perform them, as this is the precise objective of the Governance Guideline. Overlaps of the CACM Network Code with the Governance Guidelines is not acceptable and should be avoided. Including articles in the Network Code that overlap with issues of the Governance Guideline and making sure that the texts are compatible is not an acceptable solution, since it will complicate, not only the approval process of both documents, but the future evolution of them.
Please find the whole consultation response attached.