Europex welcomes this opportunity to comment on the future design of the European electricity market. Please see our response to selected questions.
Europex’s strong conviction is that risk transfer mechanisms are most needed during periods of heightened uncertainty and volatility, as it is at such times that risks in the underlying commodity and financial markets are most acute.
Please find our detailed position paper attached:
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.
Imposing restrictions on who may or may not participate in the EU ETS would significantly weaken the market, putting at risk the EU’s ability to meet its climate goals in a cost-efficient manner.
This response has been compiled by EACH, EFET, Eurelectric, Eurogas and Europex and reflects the views of their respective memberships
We do not agree with the view that a system where on one side of any trade (buy side or sell side) there is always the same party should be considered multilateral simply because the system is operated by a third party (draft ESMA opinion no. 24).
Europex is fully aligned with the core objectives of the Principles to ensure that commodity derivatives markets can serve their fundamental role of facilitating fair and efficient price discovery and hedging in a transparent, secure and well-regulated trading environment, while remaining free from market manipulation and other abusive practices.
We support ACER’s approach to delete Article 59(5) of the proposal, which proposes a cap on remuneration of LTTRs in case of fallback allocation. We do not see adequate justification to extend the HAR Article 59 compensation caps to LTTR remuneration during decoupling events.
We welcome the opportunity to provide feedback to ESMA’s draft proposals for the review of RTS 21 and ITS 4 as well as the proposal for new technical standards for position management controls. Europex’ members have gained extensive experience with the implementation of the MiFID II position limit regime and position management provisions.
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