Eurelectric welcomes the possibility to present our views on the harmonized methodology. However, we regret that the public consultation takes place during the summer months, even though the methodology needs to be submitted only in December 2022. Prolonging the public consultation would provide more time for a thorough analysis. We hope ENTSO-E will at least organize a public workshop on the matter in September / October 2022, or a bilateral meeting.
Firstly, we want to point out the difference that makes when we reserve Day- Ahead CrossZonal Capacity (DA CZC) for Balancing Capacity (BC) instead of Day Ahead Market (DAM). The two products compete for the same CZC but differ in their nature, the allocation of DA CZC to DAM implies dispatch of energy and optimization of energy flows among borders while the allocation of DA CZC to BCM does not imply directly dispatch of energy as such capacity may not be activated.
Historically, with regards to the three methodologies, Eurelectric was of the opinion that only co-optimisation could be of consideration (i.e. a process of simultaneously bidding and clearing in both the balancing capacity market and day-ahead market final target of a 1 step co-optimisation process fully allowing advanced multilateral linking of bids) on the condition of it being implemented under the principle of multi-lateral linking of BCM and DAM bids.