Evropska komisija je v okviru strategije za energetsko unijo lani predstavila nov energetski sveženj glede preoblikovanja energetskega sistema Evrope. V okviru tega je jeseni 2015 potekalo javno posvetovanje o vprašanju, kakšna naj bi bila nova zasnova trga z električno energijo, da bi zadovoljila pričakovanja odjemalcev, prinesla resnične koristi od nove tehnologije in olajšala vlaganja, predvsem v obnovljive vire energije in nizkoogljično proizvodnjo energije; ter da bi upoštevala medsebojno odvisnost držav članic EU na področju energetske zanesljivosti.

V okviru javnega posvetovanja o novi zasnovi trga z električno energijo je Ministrstvo za infrastrukturo pripravilo okvirni odziv Slovenije, ki ga je posredovalo Evropski komisiji in ga v originalni obliki v angleškem jeziku objavljamo v nadaljevanju.

Slovenia’s contribution on a New Energy Market Design proposal

Electricity market prices do not include the CO₂ costs, which make renewable energy less competitive in relation to conventional sources. Instead of internalizing external costs we have introduced support schemes for renewables. However, new technologies failed to meet the decreasing market price of electricity. Paradoxically, energy market prices continue to decrease also because of subsidizing new technologies. Moreover, questions on additional capacity market mechanisms have entered our agenda and we cannot resist asking ourselves whether these will result in a further decrease of energy market prices ?

We believe that subsidies should be gradually diminished and that income of supported renewable producers should reflect market price of their energy. Including adequate CO₂ price in the cost of electricity would be thus very helpful.

We also need to solve the issue of intermittency of renewable energy. A necessary step if we want to realize the shift away from fossil-based technologies and make the EU the world leader in renewable energy. However, solving the intermittency issue will be costly and it needs to be adequately internalized in the market price of renewable energy as well.

Regulated prices are incompatible with the idea of integrated and fully functioning energy market. Since numerous Member States have regulated prices for end consumers, this represents a reason for concern.

In relation to capacity mechanisms Slovenia is concerned and reserved. On the one hand, we are reserved because we see low energy prices as a reason for capacity market introduction. The introduction of capacity markets will result in a final price of electricity being less correlated with the market price of electricity. Furthermore it will cause even further market price drop. Besides that, the introduction of capacity markets in one or some Member States changes the position of production companies in those Member States. Since we have an integrated market, producers from other Member States will not have the same conditions. Eventually all Member States would have to introduce capacity markets resulting in a phenomenon already observed in a case of use of the network charge for producers.

On the other hand, Slovenia is concerned because some Member States have already introduced capacity measures – whether or not introduction of capacity mechanism is in line with the acquis – therefore it may be late to discuss this issue. An overall introduction of capacity measures in all Member States may thus be unavoidable. Nevertheless, Slovenia strongly supports the Commission in its intention to develop harmonised methodology to assess power system adequacy and align different adequacy standards across the EU.

Turning to short term electricity markets, Slovenia principally supports harmonisation of short-term and balancing markets, at least on a regional level. However, not all network codes have been adopted yet and their full implementation is only to be realised. In this manner we would like to stress, that we should focus on the swift and full implementation of the third energy package along with the adoption and implementation of the network codes which is still under way. Scarcity pricing is a step in a right direction.

Regional cooperation is a valuable tool and we should try and fully exploit the potential it offers. System security can namely be expensive in small systems and regional cooperation could be beneficiary. It is extremely important when solving problems to which there are no national solutions such as cross border infrastructure projects or projects with regional importance. Regional cooperation is very important also in cases where we see possible synergies. There are several examples where such regional cooperation has helped to deliver results, such as better security of supply at a lower cost. Looking for system security in the form of system reserve at the regional level instead of looking for national solutions has helped to secure a better and more cost-efficient solution also for Slovenia. For example, our TSO has an agreement with participating countries for the tertiary reserve. There has also been some cooperation on balancing energy with Austrian TSO.

Countries develop cooperation where interests are shared. It is essential that relevant countries in the region find their common interest and cooperate in bringing projects to a successful end. Further use should be made of the existing regional structures and see how these could be of service when dealing with specific regional problems.
 
The Republic of Slovenia supports regional cooperation in the field of security of supply; however, national responsibility for security of supply should remain a basic principle.

In the EU cross-border electricity flows have been increasing and do not serve anymore only as a mechanism to overcome system insufficiencies. Income from congestion charges could be effectively used to build the missing cross-border links and upgrade the EU electricity system. In order to do that, a mechanism for remuneration of transit costs should be put in place, for instance, an enhanced ITC mechanism. Otherwise only customers from transit countries would pay for high network charges.

The Republic of Slovenia believes it would be necessary to enhance ACER's competencies. An enhanced role of ACER would be necessary to enable effective functioning of the integrated markets and cross border infrastructure. We believe that this would contribute to well-functioning of the internal energy market and cross border infrastructure in the future. The reinforcement of the powers of ACER should include the power to adopt directly applicable and binding decisions on EU-level initiatives and cross-border issues and the introduction of enforcement powers to ensure compliance with such decisions. Furthermore, we believe ACER should arbitrate in regional and EU level disputes. Last but not least, we have to stress that enhancing ACER’s regulatory and establishing arbitrary powers includes also adequate strengthening of the Agency with needed additional human resources.

Thus, we would like to stress the following guidelines related to the new market design:

1. Fully functional internal energy market with an effective and strong ETS should be a core element of a (new) energy market design.
2. ETS along with the recently established market stability reserve should set an adequate price on CO₂ emissions to encourage energy efficiency, low-carbon technology investments and CO₂ emissions reductions.
3. Technological neutrality and competitiveness should represent main principles for a cost-effective energy transition.