- The introduction of the PICASSO and MARI platforms for the exchange of standard balancing energy products is progressively widening the pool of Balancing Service Providers (BSP) on which TSOs can rely to keep the electricity grid in balance.
- To further increase the liquidity on these balancing platforms, while preserving a level playing field at EU level, Eurelectric supports a more agile and harmonised set of rules for the prequalification of BSPs and Reserve Providing Units and Groups (RPUs/RPGs) under their control. Such framework should apply equally to all market participants, regardless of their size.
- Eurelectric welcomes ENTSO-E’s initiative to align national prequalification rules further and supports measures designed to shorten the prequalification process and reduce access barriers to national balancing markets.
- However, repeated references to national Terms & Conditions in the current Common Harmonisation Proposal continue to create the potential for diverging TSO practices. This carries the risk that BSPs competing across borders are subject to different requirements, undermining the level playing field.
- Eurelectric therefore calls on TSOs to conduct a comparative assessment of prequalification and ex-post verification practices across Europe. Based on this assessment, the development of principles at EU level should be expedited to ensure that RPUs and RPGs across the Union meet the same standards of reliability and quality, thereby guaranteeing the equivalent quality of standard balancing products.
- Our proposals reflect Eurelectric’s commitment to an efficient and fair framework for balancing energy products:
- Harmonisation cycles: a comparative assessment of TSO practices leading to the harmonisation of substantial prequalification requirements is a precondition for Eurelectric to accept moving to a biannual survey cycle.
- Simplification of pre-qualification requirements: beyond our proposal for shorter prequalification timelines, a simplified prequalification procedure should be envisaged when BSPs prequalify RPUs/RPGs of the same technology as RPUs they have already prequalified, subject to equal treatment for all BSPs.
- Ex-post verification: access conditions and substantial requirements of the ex-post verification process need to follow harmonised principles at EU level to ensure that the activations of RPUs/RPGs are representative of their genuine market activity. ACER and TSOs should consult stakeholders on principles for e.g., the minimum number of activations and the quality of activations based on the abovementioned comparative assessment.
- BSP switching: we broadly agree to the conditions for BSP switching in the same LFC. However, Art. 8(1)(c) should be strengthened to clarify that the BSP taking over an RPU or RPG already operates an RPU or RPG with an identical technology. The transfer of the prequalification status should further be understood as a full transfer without any change to the assets’ technical or functional scope.  Â
- Re-prequalification: requirements for re-prequalification should be precise, proportionate and limited to detected issues or identified changes. In addition, like other qualification processes, TSOs discretion in defining additional triggers should be restricted. Â