Response to Consultation on on the priority list for the development of network codes and guidelines

18. May 2020. EPEX SPOT welcomes the opportunity to participate in the consultation on the priority list for the development of network codes and guidelines on electricity for the period 2020-2023 and on gas for 2020 (and beyond) by the European Commission.

EPEX SPOT welcomes that the implementation of existing regulation remains a priority for the European Commission, as the Clean Energy Package already contains valuable targets for demand-side flexibility. A network code for flexibility should only be established with the goal to further streamline an effective implementation of the Clean Energy Package and other relevant regulations. The scope of a potential network code for flexibility should be limited and carefully defined. While a certain degree of harmonisation and procedures is helpful, a too narrow regulation through network codes for demand-side flexibility might restrict regulatory competition and might result in an inefficient solution.

If a network code for demand-side flexibility is deemed necessary to further streamline an effective implementation of existing regulations, the following points should be considered. A network code for demand-side flexibility should:

• incentivise market based flexibility procurement, as detailed in the Clean Energy Package
• include the creation of transparent and non-discriminatory flexibility markets
• acknowledge the benefits of market operations by neutral third parties
• not aim to be all-encompassing by addressing any conceivable feature so as not to run the risk to hamper further development of innovative solutions. This holds especially true for product standardisations.

You can find the full response in the PDF document attached and in the Download Center of our website, in the section publications.