ACER关于ENTSO-E平衡实施框架联合协调提案的协商

commonharmonisation Eurelectric represents the interests of the electricity industry in Europe. Our work covers all major issues affecting our sector.Our members represent the electricity industry in over 30 European countries. We cover the entire industry from electricity generation and markets to distribution networks and customer issues. We alsohave affiliates active on several other continents and business associates from a wide variety of sectors with a direct interestin the electricity industry. We stand for The vision of the European power sector is to enable and sustain:-A vibrant competitive European economy, reliably powered by clean, carbon-neutral energy-A smart, energy efficient and truly sustainable society for all citizens of Europe We are committed to lead a cost-effective energy transition by: investingin clean power generation and transition-enabling solutions, to reduce emissions and actively pursue efforts tobecome carbon-neutral well before mid-century, taking into account different starting points and commercial availability of keytransition technologies; transformingthe energy system to make it more responsive, resilient and efficient. This includes increased use ofrenewable energy, digitalisation, demand side response and reinforcement of grids so they can function as platforms andenablers for customers, cities andcommunities; acceleratingthe energy transition in other economic sectors by offering competitive electricity as a transformation tool fortransport, heating and industry; embeddingsustainability in all parts of our value chain and take measures to support the transformation of existing assetstowards a zero carbon society; innovatingto discover the cutting-edge business models and develop the breakthrough technologies that are indispensableto allow our industry to lead this transition. Harmonisation ofbalancingimplementation frameworks KEYMESSAGES •The introduction of the PICASSO and MARI platformsfor the exchange of standard balancing energy products is progressively widening the pool ofBalancing Service Providers (BSP) onwhich TSOs can rely to keep the •To further increase the liquidity on these balancing platforms, whilepreserving a level playing field at EU level,Eurelectric supports a more agile and harmonised set of rulesfor the prequalification of BSPs andReserve Providing Units and Groups (RPUs/RPGs) under their control. Suchframework should applyequallyto all market participants, regardless of their •EurelectricwelcomesENTSO-E'sinitiativeprequalification rules furtherand supports measures designed to shorten theprequalificationprocess and reduce access barriers to national balancing •However, repeated references to national Terms & Conditions in thecurrent Common Harmonisation Proposal continue to create the potentialfor diverging TSO practices.This carries the risk thatBSPscompetingacross •Eurelectric therefore calls on TSOs to conduct acomparative assessment of prequalification and ex-post verification practices across Europe. Based on this assessment, the development of principles at EU level should beexpeditedto ensure that RPUs and RPGs across the Union meet the samestandards of reliability and quality, thereby guaranteeing the equivalentquality of standard balancing products. •Our proposalsreflectEurelectric’scommitment to an efficient and fair frameworkfor balancing energy products: 1.Harmonisation cycles: a comparative assessment of TSO practices leading totheharmonisation of substantial prequalification requirements is apreconditionforEurelectrictoacceptmoving to a biannual survey cycle.2.Simplification of pre-qualification requirements:beyond our proposal for 3.Ex-post verification:access conditions and substantial requirements of the ex-post verification processneed to follow harmonised principles at EU level toensure thattheactivations ofRPUs/RPGsarerepresentative of their genuine 4.BSP switching:webroadlyagree to the conditions for BSP switching in thesame LFC. However,Art. 8(1)(c) should be strengthened to clarify thattheBSP taking over an RPU or RPG alreadyoperates an RPU or RPG with an 5.Re-prequalification:requirements for re-prequalification should beprecise,proportionate and limited todetected issues or identified changes. In addition,likeotherqualification processes, TSOsdiscretion in defining additional ConsultationTopicsandQuestions Topic1:Frequencyofstakeholdersurvey AccordingtoArticle20(2)(a)ofthemFRRIFandaFRRIF,thestakeholdersurveytoidentifyashortlistofprioritisedharmonisationneedsshouldbeorganisedeveryyear.InArticle20(2)(a)oftheProposals,theTSOsproposethatastakeholdersurveyshouldbe ACERconsidersthatconductingthestakeholdersurveyeverythreeyearscouldresultindelaysinthefurtherharmonisationprocess.Therefore,ACERintendstoreviseArticle20oftheProposalsinordertoreducetheintervalofthestakeholdersurveyfromeverythree 1.1DoyouagreewithACER’sproposedmodificationtoreducethefrequencyofthestakeholdersurveytoevery two years? ☐