Asociación de empresas de energía eléctrica, aelec

We hereby express our agreement with the methodology already established by the Regulation for calculating emissions of electricity as a CBAM good. The use of the CO2 emission factor (resulting from dividing the CO2 emission data of the electricity sector by the gross electricity generation based on fossil fuels in the relevant geographic area), by default, is the best approach, as marginal technologies (in general…

aelēc welcomes the launch of this consultation as new challenges emerge on the European electricity system triggering the needs on stable and clear regulatory frameworks to contribute to its stable and secure operation.

Overall, we are concerned that the draft increases reporting burden without commensurate surveillance benefit. Exposure reporting is the clearest example. The notion of flagging prima facie unjustified trading behaviour implies a de facto hedge benchmark and sanctioning deviations.

We welcome the Commission proposal for Implementing Regulation on interoperability requirements and non-discriminatory and transparent procedures for access to data required for customer switching, as a necessary tool to promote competition and good functioning ok the EU electricity supply market.