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.
As the main objective is decarbonisation, clear rules are needed to determine the renewable character of both electricity and RFNBOs, including hydrogen which is likely to play a key role in the future energy mix.
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 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.
Europex explicitly welcomes and fully supports the Commission’s legislative proposal to extend the derogation in Article 199a of the VAT Directive allowing Member States to apply the domestic reverse charge mechanism (DRCM) to transactions in electricity, gas, emission allowances and Guarantees of Origin (GOs).
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 welcome this opportunity to provide input to the ENTSO-E and EU DSO proposal for a Network Code on Cybersecurity aspects of cross-border electricity flows.
We believe it is crucial that the illiquid market and Large-In-Scale (LIS) transactions waiver methodologies will consider the unique characteristics of commodity trading, one of them being the important role of pre-arranged trading for the development of on-screen trading.
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.
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