Joint public consultation on methodologies for assessing electricity resource adequacy
ACER - Osservazioni Elettricità Futura del 27 maggio 2020
1.1 Do you think that policies and measures contributing to indirectly restricting wholesale price formation (as referred to in Article 10(4) of Reg. (EU) 2019/943) should be reflected in ERAA? Yes/No
1.2 Please elaborate on your previous answer To perform a correct analysis, we believe that every market rule that is in force at the time of ERAA execution - wholesale price restriction policies included - must be taken into account. Yet, these policies should automatically be reflected in ERAA only if their impact on price formation is straightforward and unequivocally recognized. Moreover, it should be considered that some of the measures mentioned in Article 10(4) are aimed at ensuring the correct functioning of wholesale and balancing markets so they should not be considered as inducing undue limitations to price formation. These measures - whilst contributing to an efficient short-term dispatching - are not expected to be relevant for the long-term choices (investment, maintenance, retirement), hence they are not impacting on ERAA conclusions. In fact, the level of scarcity prices (maximum magnitude of it) is not expected to solve the missing money issue (i.e. the inherent uncertainty in predicting scarcity events and related difficulty in budgeting new peak investment or even discourage retirement decisions on the mere basis of scarcity rent expectations).