Europex welcomes this opportunity to comment on the future design of the European electricity market. Please see our response to selected questions.
The tasks performed by delegated operators include, among others, imbalance
calculation and settlement, data publication related to electricity balancing markets and
issuing of the rules related to balancing markets and imbalance settlement.
We would like to take this opportunity to offer additional guidance to ensure that these emergency measures are not adopted without due consideration of their short- and mid-term effects.
Following the urgency legislation in the gas sector, notably regarding gas storage and gas demand reduction in the spring and early summer, the European Commission
Demand response, and more generally system flexibility, play a key role in achieving the EU’s decarbonisation targets and securing future system stability as volatile electricity production from renewables will need to increase substantially in the years to come.
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.
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.
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