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Position Papers

EPIA reply to the European Commission's public consultation on Retail Energy Markets

EPIA sees the Commission’s policy document which will follow this consultation as the trigger for fostered competition in retail electricity markets. More offers centered on the energy component of electricity bills are not enough. A real change of paradigm is needed, from commodity-based to services-based markets. In such markets, consumption and production of electricity should no longer be treated differently, as services will be based on a mix of both.

EPIA reply to the public consultation on the Draft guidelines on environmental and energy aid for 2014-2020

Date : February 2014
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State Aid rules should not replace energy policy. While these guidelines should only set the conditions under which aid for energy and environment may be considered compatible with the Treaty, the current set of proposals on renewable energy (RES) appears to go far beyond the framework defined in the relevant European legislation. Several provisions would indeed unduly constraint Member States’ capabilities to reach their 2020 binding renewable targets. In particular, the technology neutral-bidding process that Member States would have to implement when granting support to “deployed” renewable electricity technologies is constraining their choices and could undermine the very objective of helping a mix of different technologies mature and achieve their full competitive potential.

EPIA reply to the public consultation on Commission Regulation declaring certain categories of aid compatible with the internal market

Date : February 2014
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EPIA welcomes the general objective of the Commission Regulation (GBER) to clarify under which conditions investment aid could be exempted from the notification requirement of Article 108(3) of the Treaty. However, the fact that both the current draft Commission Regulation and the draft Guidelines on environmental and energy aid for 2014-2020 apply to operating aid is confusing. The Commission should therefore clarify under which conditions operating aid mechanisms should be notified or not.

EPIA contribution to the ACER pre-consultation "Energy Regulation: a bridge to 2025"

Date : December 2013
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EPIA welcomes this pre-consultation that opens a debate on the necessary adjustments in the electricity system. The crucial role of flexibility, the weak link between wholesale and retail electricity markets and the increasing importance of the latter are rightly identified by ACER as some of the main challenges ahead. Regulators play a central role in ensuring that the delicate balance between market and regulation is struck. Hence, they should take the lead – under ACER and CEER umbrellas – in the debate on the future system design. EPIA is conducting an internal analysis of system design features and options allowing for further sustainable PV growth in Europe and is willing to continue exchanging on this with ACER and its members.

EPIA Reply to ENTSO-E Consultation on Ten Year Network Development Plan (TYNDP) 2030 Visions

Date : September 2013
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EPIA agrees with ENTSO-E that it is important to base the identification of electricity infrastructure projects of the next 10-15 years on robust forecasts for generation and demand. EPIA however questions the value of a new scenario-making exercise performed by the network of transmission system operators coming in addition to quite a few already published projections. EPIA believes that the Energy Roadmap 2050 prepared by the European Commission is an authoritative piece of work and regrets that ENTSO-E has not taken it as the basis for project identification and has decided to produce its own “visions”.

Reply to the ENTSO-E Public Consultation on the draft Electricity Balancing Network Code

Date : August 2013
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EPIA submitted its proposals for amendments to the Electricity Balancing Network Code drafted by the European Network of Transmission System Operators (ENTSO-E). By setting some common principles for the provision of balancing services, this Network Code could foster PV participation in system operation in Europe. In particular, the distributed nature and the inherent variability of PV electricity should be reflected in this Network Code.

Position Paper on self-consumption

Date : July 2013
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The European Commission has recently called for strategies in order to empower consumers. EPIA believes that unleashing the full potential of self-consumption across Europe will make a significant contribution to achieve this objective. This briefing paper explores the benefits of self-consuming PV-generated electricity, as well as the remaining barriers and challenges for the deployment of self-consumption throughout Europe.

Responses to the European Commission Green Paper: “A 2030 framework for climate and energy policies”

Date : July 2013
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The European Commission is expected to present new proposals for a 2030 framework for climate and energy policies by the end of this year. EPIA responded to the official public consultation, highlighting in particular the importance of a legally binding EU target of 45% for the share of renewable energy by 2030.

Comments on the European Commission’s draft General Block Exemption Regulation (GBER) proposal

Date : July 2013
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The European Commission’s Directorate General in charge of Competition presented a draft proposal for a new General Block Exemption Regulation, as part of the modernisation of the EU State Aid policy. Several of the provisions proposed in Article 34 remain of high concern for EPIA.

Response to DG ENER Working Paper: “The future role and challenges of Energy Storage”

Date : February 2013
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On 14 January 2013 the European Commission published a Working Paper identifying the need for a European strategy to advance energy storage development and deployment. EPIA – the European Photovoltaic Industry Association – welcomes this paper and wishes to complement its conclusions with some comments and recent findings on the specific case of electricity storage.

Contribution to the Public Consultation on Generation Adequacy, Capacity Remuneration and the Internal Energy Market

Date : February 2013
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The European Commission presented in November 2012 its communication on the internal energy market. EPIA has responded by underlining a key message: The internal market should be readied to attain the strategic EU goals of liberalisation, decarbonisation and integration of renewables. EPIA also stresses that the balance between supply and demand of electricity in the system should be considered in a wide context, taking into account the contribution made to it by photovoltaics and other renewables. The potential of flexibility resources – including demand side management, storage and interconnection – should be fully tapped into as a precondition to further steps in ensuring generation adequacy. Any form of capacity remuneration should be granted only when duly justified and reversible; it should be based on competitive awarding procedures and on a coordinated European approach, consistent with the internal market.

Joint response to ENTSO‐E’s ‘2030 Visions'

Date : December 2012
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In the context of ENTSO‐E’s work in developing ‘2030 Visions’, the cost benefit analysis methodology to build scenarios and the System Operation and Adequacy Forecast (SOAF) reports, we welcome the ambition of ENTSO‐E to move away from a bottom-up methodology in order to adopt a truly European approach. We recognise that progress has been achieved in this respect but we are concerned that current efforts still fall short in meeting with EU policy renewable energy and climate objectives and expected stakeholder involvement. This response paper outlines these concerns and suggests further improvements.

To receive older position papers, please contact us at info@epia.org.


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Alexandre Roesch
EPIA
Contact
Alexandre Roesch
Head of Regulatory Affairs
@ : a.roesch@epia.org
T. : +32 (0)2 709 55 22

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