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Polish Wind Energy Association

PWEA

PWEA is an association of the leading companies active on the wind energy market in Poland: investors, developers, turbine and component manufacturers, both from Poland and abroad.

Lobbying Activity

Response to Revision of the EU’s electricity market design

23 May 2023

PWEA welcome the overall objective to evolve the current design with market-based solutions, keeping the fundamentals of the short-term electricity markets, marginal pricing, and the merit order. PWEA supports the focus on improving consumer protection and improving measures to mitigate risk in renewable investments. For the most cost-efficient projects to be developed first, PWEA believes that investment decisions should mainly be market-driven and not based on government support. In our opinion, a functioning forward market is the basis for risk mitigation in a growing Power Purchase Agreement (PPA) market. Thus, it is key that Contracts for Difference (CfDs) do not displace forward markets and commercial PPAs. Direct price support schemes for new investments must be limited to two-way CfDs. CfDs can be an appropriate way to support investments in new capacity where investments are not forthcoming on a market basis, and where investments are necessary to reach energy and climate goals. In that case, a two-way CfD would make the support element more dynamic and ensure that support is only provided when needed. It must be ensured that the distribution of the revenues is designed in such a way that it does not distort price signals. Being subject to price signals is key for customers to reduce energy consumption in times of scarcity, for facilitating the green shift and be less reliant on fossil fuels. Thus, it is important that such distribution does not distort price signals. Commercial tools such as PPAs in combination with financial instruments are and should remain the main tool in the market for producers and customers to mitigate risk. PWEA therefore supports that Member States shall facilitate the continued development of PPAs. We are especially in favor of facilitating for more credit-support schemes in order to reduce the financial risks and accelerate demand, which currently constitutes one of the main barriers for developing the PPA market. We note that it would also be important to avoid mandatory standardized requirements for PPA agreements as one of the main benefits with PPAs is that they can be tailor-made and accommodate desired deliveries and risk aversion for both parties. To improve liquidity in the intraday market and ensure equal access to such opportunities for trade, we support the proposed amendments to share order books between market operators within a bidding zone after the gate closure time of the intraday markets. In our opinion, peak shaving objective is already secured through the products which already exists in the balancing markets. Thus, we find it unnecessary to introduce a new product at this time. Furthermore, we believe system operators are better suited to identify the products and services with which they need to operate the transmission and distribution systems, and that specific products should not be outlined in the legislative framework. PWEA supports more transparency on grid capacity The Commission has proposed several amendments concerning TSOs and DSOs publication of information relating to available capacity for new investments, both by amending Article 50 and Article 57 in the Electricity Regulation 23, and proposing an amendment to the Electricity Directive Article 3124 . In light of the increasing need for more capacity to ensure new connections in the coming years, we support this proposal with the aim of ensuring more transparency. The Commission has proposed an amendment to Article 19(2)25, where TSOs can use congestion income to compensate offshore generation plant operators if access to the interconnected markets is limited due to reduced capacity on the interconnector. For the sake of harmonization, PWEA is of the opinion that the same rules should apply for production on land and offshore. Thus, we do not support a proposal which opens up for different compensation schemes depending on the characteristics of the power plant.
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Meeting with Dominique Ristori (Director-General Energy)

14 Sept 2018 · energy policy

Meeting with Dominique Ristori (Director-General Energy)

10 Apr 2018 · Energy policy

Meeting with Dominique Ristori (Director-General Energy) and WindEurope

8 Feb 2018 · Renewables in Poland

Meeting with Dominique Ristori (Director-General Energy)

5 Dec 2017 · Energy policy developments

Meeting with Dagmara Koska (Cabinet of Vice-President Maroš Šefčovič), Juraj Nociar (Cabinet of Vice-President Maroš Šefčovič)

16 Mar 2016 · RES potential in Poland

Meeting with Miguel Arias Cañete (Commissioner)

23 Feb 2016 · policy developments on renewable energy at EU level and in Poland