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.
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 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.
Together with the All NEMO Committee, we welcome this opportunity to provide input on ACER’s draft Framework Guideline on electricity sector-specific rules for cybersecurity and
Europex welcomes the opportunity to provide feedback to the Commission’s public consultation on the draft delegated act for amending the ancillary activity exemption (AAE) in
Europex fully supports this review of the legislative framework to design competitive decarbonised gas markets and ensure that gas markets contribute to the decarbonisation of
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
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