Wholesale energy market: Union’s protection against market manipulation

Dear Sir or Madam, Please find the attached the position of GRTgaz Deutschland GmbH regarding the consultation on the wholesale energy markets improving EU protection against market manipulation. GRTgaz Deutschland GmbH completely endorses the position of FNB Gas e. V.

CMCE welcomes the European Commission proposal to review the REMIT framework. We understand the broader context of this initiative is related to the energy price crisis and specifically to the functioning of the EU electricity markets.

Position of the Polish Electricity Association (PKEE) in response to ECs proposal for a regulation of the EP and of the Council amending Regulations (EU) No 1227/2011 and (EU) 2019/942 to improve the Unions protection against market manipulation in the wholesale energy market.

Dear Sirs, Please find in the enclosed file Balkan Gas Hub EAD opinion on ECs proposal for revision of the Regulations (EU) No 1227/2011, Regulations (EU) No 1348/2014 and Regulations (EU) 2019/942. Balkan Gas Hub ЕAD operates trading platforms servicing the needs of the natural gas markets within the Balkan gas hub.

Renewables Norway represents the renewable industry in Norway. We welcome the European Commission's (EC) intention to strengthen transparency in the European market. REMIT is a complex and technical legislation, and market participants (MPs) expect a robust regulation that is easy to understand and implement. We welcome some of the proposed updates to the regulation, for instance, the part on algorithmic trading.

Enagas welcomes the European Commissions proposal to amending Regulation (EU) 1227/2011 and Regulation (EU) 2019/942, as part of the revision of the electricity Market Design. As a general overview, Enagás point of view is that: - some of the amendments proposed to REMIT revision are not directly linked to the Electricity market Design, and should not be linked to it; - some of the amendments proposed comes from the…

The PGE Group would like to highlight the following issues with regard to the proposed changes in the Regulation on wholesale energy market integrity and transparency and the Regulation establishing a European Union Agency for the Cooperation of Energy Regulators: 1.

The ÖBB welcomes the European Commission’s initiative to increase market transparency and integrity in order to prevent manipulation. However, for some schemes, we see a disproportionate interference with the rights of market participants. For more information, please refer to the Annex.

Filed in German · English published by the European Commission

Although we share the objectives of the revision to improve the functioning and transparency of the EU market, the proposal presents some shortcomings. We therefore would like to suggest below a few possible avenues to address the most relevant ones. The proposal includes several amendments to the constitutive elements of REMIT.

HSE Group proposes the amended REMIT Regulation to include: a mandate to ACER to define, in close cooperation with National Regulatory Authorities, thresholds for the identification of events which constitute inside information for the purposes of its publication, a clearer definition of contracts for the supply and distribution of electricity or natural gas for the use of final customers being considered wholesale…

EFET welcomes the publication of the draft Regulation on Wholesale Energy Market Integrity and Transparency (REMIT II). The further development of the REMIT framework is key to enhancing confidence in the integrity and transparency of EU wholesale energy markets. Still, certain areas of the proposal require changes to meet this objective: 1.

In general, the Austrian Federal Economic Chamber sees the EU initiative to reform the electricity market design positive. Although, our market design has worked well in the past and has yielded low energy prices for the final customers, it has shown its limitations in the current energy crisis.

Please find the attached the position of GASCADE Gastransport GmbH regarding the consultation on the wholesale energy markets improving EU protection against market manipulation (consultation on REMIT). GASCADE Gastransport GmbH completely endorses the position of FNB Gas e. V.

Dear Sirs, The co-signed associations FIA, FIA EPTA and ISDA appreciate the opportunity to comment on the European Commissions REMIT proposal. We support the recent changes to the original proposal made in the latest Council text dated 5th May but would like to highlight some additional concerns that remain. In particular, we recommend: 1.

Intercontinental Exchange Inc., on behalf of itself and its subsidiaries (ICE), appreciates the opportunity to comment on the Commission consultation on Wholesale energy markets improving EU protection against market manipulation. In summary, ICE strongly recommends the Commission: Remove prohibitions and requirements related to financial instruments which are already subject to EU financial regulation (i.e.

| 1 | Skagerak Kraft (Skagerak) welcomes the European Commission's (EC) intension to strengthen transparency in the European market. The Regulation on Wholesale Energy Market Integrity and Transparency (REMIT) is a complex and technical legislation, and market participants (MPs) expect a robust regulation that is easy to understand and implement.

DEAR Sir or Madam, Please find the attached position of Nowega GmbH in the consultation of REMIT. Nowega GmbH completely opposes the position of FNB Gas e.V. in the consultation on the European Commissions proposal for amending Regulations (EU) No 1227/2011 and 2019/942 and fully support all proposals made therein. Best regards [name removed]H

Filed in German · English published by the European Commission

Dear Sirs, Please find in the enclosed file Bulgartransgazs opinion on ECs proposal for revision of the Regulations (EU) No 1227/2011, Regulations (EU) No 1348/2014 and Regulations (EU) 2019/942. Our major concerns regarding the proposal are: - Urgency of the revision process and the scope of the proposed changes; - Inclusion of the inside information collection in the REMIT fee regime; - New enforcement and…

Dear Representatives of the European Commission Dear Representatives of the DG Energy EPEX SPOT has been a supporter of a centrally coordinated European market surveillance system since its early inception and continue to deeply value REMITs contribution to the transparency and integrity of European wholesale markets in electricity and gas.

ENTSOG was founded in line with Regulation (EC) 715/2009 and has played a key role in facilitating integration of the European gas markets, ensuring technical interoperability, and providing security of supply by gas infrastructure planning.

Dear Sir or Madam, Please find the attached position of Open Grid Europe GmbH in the consultation of REMIT. Open Grid Europe GmbH completely endorses the position of FNB Gas e. V. in the consultation on the European Commissions proposal for amending Regulations (EU) No 1227/2011 and 2019/942 and fully supports all proposals made therein. Best regards [name removed] Europe

Please find attached the statement of Thyssengas GmbH in the consultation on REMIT. Thyssengas GmbH, headquartered in Dortmund, is one of the leading gas transmission system operators in Germany. Thyssengas covers a significant proportion of the energy needs of many important industrial operations and provides heat to millions of people across the country.

Please find enclosed the comments of Thyssengas GmbH in the consultation on REMIT. Thyssengas GmbH, established in Dortmund, is one of the leading gas transmission system operators in Germany. Thyssengas accounts for a significant share of the energy supply of many major industrial plants and of the heat supply to millions of people across the country.

Filed in German · English published by the European Commission

Ladies and gentlemen, terranets bw GmbH fully supports the position of FNB Gas e.V. in the REMIT consultation and fully supports all the suggestions made therein. You will therefore find a copy of the position below.

Filed in German · English published by the European Commission

Please find enclosed the comments of bayernets GmbH in the consultation on REMIT. Bayernets GmbH is a German transmission system operator. As part of the European gas transport system, we transport gas efficiently, safely and environmentally safe through southern Germany. Bayernets GmbH fully supports the position of TSO Gas e.V.

Filed in German · English published by the European Commission

Please find enclosed the statement of bayernets GmbH in the consultation on REMIT. bayernets GmbH is a German transmission system operator. As part of the European gas transmission system, we transport gas through Southern Germany efficiently, safely and in an environmentally friendly way. bayernets GmbH completely endorses the position of FNB Gas e. V.

Ladies and gentlemen, in addition to the comments sent yesterday in English, we enclose the comments of FNB Gas in German with the request that it be taken into account in the consultation procedure. Yours sincerely, [name removed]

Filed in German · English published by the European Commission

On behalf of the main Romanian electricity producers, representing more than 70% of the national generation sector: We support cooperation between ACER, the National Regulatory Authorities (NRAs) and other competent financial authorities, which would increase the efficiency of electricity market monitoring and facilitate the detection of potential deviations from Regulation 1227/2011.

Dear Sirs, please find attached the FNB Gas's opinion on the European Commissions proposal for amendment of the Regulations (EU) No 1227/2011 and 2019/942 in English. If you have any questions, please do not hesitate to contact us. Best regards [name removed]iber Gas e.V. [address removed] Tel.: [phone removed] Fax.: [phone removed] E-Mail: [email removed] Website: https://fnb-gas.de/