Brussels, 10 November 2010 | Europex appreciates the efforts of ERGEG and the expert group in drafting the Draft Framework Guidelines (FG) on Capacity Allocation and Congestion Management (CACM) for Electricity and the accompanying initial impact assessment. We welcome the opportunity to provide our views on the draft framework guideline. The CACM FG is focused on methods to calculate capacities (e.g., ATC/NTC or FB) and on the definition of zones to solve problems with congestions in the grid. However, the developments over the last years, namely the growth of renewable generation and its impact on grid congestions should not be ignored. As this trend will certainly continue and even intensify, we believe that the CACM FGs would be the right place to start the discussion on how to create comprehensive rules to deal with this challenge. It is not clear that the proposed measures (improved capacity calculation methodology and redefinition of zones) will be able to solve the current and future problems without additional measures to deal with the impact of renewables.
The present document provides comments and suggestions for improvement of the proposed text of the CACM FG. Additional remarks that could also contribute improving the CACM FG for a better integrated European electricity market are also given. Responses to questions are limited to those we understand to be of crucial relevance for power exchanges. We believe 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.
Please find the whole consultation response attached.