It should be noted that concurrently lapsed on 16 September 2011 the time-limit for submitting responses in a public consultation on fundamental electricity data transparency. Released document ‘Public Consultation Document Guidelines On Fundamental Electricity Data Transparency’ referred to the ERGEG Advice Comitology Guidelines on Fundamental Electricity Data Transparency Ref: E10-ENM-27-03 of 7 December 2010. The said consultation as well as ERGEG advice are closely related to REMIT and constitute the input to the future implementing acts of the Commission.

 

In the consultation document the European Commission posed certain important questions. Very interesting issue is touched for instance in the following:

 

‘Points 4.3.2.4 and 4.3.2.5 of ERGEG's guideline require publishing ex-ante information on planned and ex-post information on the unplanned unavailability of generation units including the name of the generation units, location, bidding area, available capacity during the event, installed capacity, etc. Do you consider that publishing this information on a unit-by-unit base would be likely to create any competition concerns? If yes, how does this concern relate to the potential benefit this information yields to market participants? Could this concern be remedied in a way which would nevertheless enable market participants to properly assess such an important change in a supply fundamental (e.g. by publishing data in aggregated form, for instance per production type and balancing zone)?’

 

The open questions were also asked about any major problems or policy issues related to transparency going beyond ERGEG's advice. Furthermore, I’m particularly interested in contributions received as regards question asking whether participants consider that definitions are complete and clear enough to avoid any potential problems when applied (contributions received are not published so far). It is probable that manifold problems will come to light only when the REMIT Regulation comes into force. I expect that the wording of the definitions and the manner of their application to the institutions of the energy market will cause many headaches.