Europex welcomes the opportunity to participate in this consultation and provide detailed input to the ACER proposal. Please note that we respond only to the selected questions listed in the attached document.
Europe is currently facing a severe shock to its energy markets, the reasons for which are diverse, ranging from global demand and supply fundamentals in the early stages and now strongly influenced by the Russian invasion of Ukraine.
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.
Europex fully supports the EU target design for balancing energy markets, including the implementation of cross-border marginal pricing. However, during the transition to the European balancing platforms, we acknowledge the potential risks of ‘exaggeratedly high’ balancing prices, as described by the TSOs.
Bidding zones are a fundamental part of the electricity market design in Europe. Adequate attention must be paid to the development of alternative bidding zone configurations as well as their assessment.
To ensure that the policy objectives set out in the Green Deal get delivered at least cost and that the EU’s internal market principles are upheld, State Aid rules need to find the right balance between supporting decarbonisation projects and minimising distortion of competition and trade in the Internal Energy Market.
We believe that a 2030 energy system that can meet these challenges must be characterised by undistorted and freely forming price signals from the energy market, efficient use of within-zone and cross-zonal transmission to balance supply and demand locally and regionally as well as increased use of storage and flexibility on the demand side.
Independent Aggregators (IAs) have the potential to provide an additional means of accessing the market for small producers and end consumers, including prosumers, small-scale RES
The Capacity Allocation & Congestion Management (CACM) Guideline provides a vital set of rules for the operation of cross-border electricity markets and sets the basis
Europex does not see adequate justification to extend the HAR Article 59 compensation caps to LTTR remuneration during decoupling events.
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