REPUBLIC OF ESTONIA
MINISTRY OF EcoNoMIc AFFAIRS
AND COMMUNICATIONS
Kadri Sirnson
[email protected]
Our Ref: 30.08.2022 No 17-9/2022/5357-1
European Comrnission,
Rue dc la Loi 200, 1040
Brussels, Beigium
Dear Commissioner Simson,
Due to the ongoing Russian aggression towards Ukraine, European energy markets are working
under severe distress. Understandably, such extraordinary conditions also reveal some
shortcomings of the cornmon energy market regulation. Estonia is concerned about the functioning
of the electricity market and some of the rccent corresponding trends we find worrying. It is our
responsibility to seek and find solutions to the shortcomings in the system to maintain the public
trust towards Energy Union.
The electricity prices on the Nord Pool power exchange in the Baltic and Finnish region have
recently reached extremely high leveis and the same trends are emerging in other EU Member
States. This has raised valid questions and concerns across the whole region. The most notable and
extreme price hike so far took place recently on the 17hh1 of August, where the price of electricity
on the Nord Pool Baltic power exchange peaked at € 4,000 per megawatt-hour. Price fluctuations
on this scale are highly problematic for our economy and for the society as a whole. Therefore, to
avoid the occurrence of such events in the future, 1 would kindly ask you and your team to take
into consideration the following observations.
Firstly, the market transparency needs to be increased. This would be crucial in order to restore
public confidence in the market system. Even when considering the general underlying causes of
the increased energy prices, it is difficult to understand and justify the extraordinaiy peaks and
extrerne fluctuations on the electricity market. Therefore, 1 kindly ask the Commission to analyse
and employ different possibilities to improve the transparency of the functioning of the
power exchange and electricity market. In our view, to ensure higher transparency, more
information should he made public on the bids placed on the power exchange, including but not
limited to their origin, source and volume. We agree that such publication should also be made in
such way that fair competition and functioning of the market would not bejeopardized, but we are
certain a solution can be found here.
Secondly, 1 see a need for immediate changes to the price setting regulation for determining
the maximum hourly clearing price of power exchanges. In our view, the current system
whereby the hourly price ceiling is automatically raised once the previous ceiling is reached,
cannot be considered reasonable at these times. The price ceiling should function in a way that it
protects the market from cxtreme fluctuations and is raised only if the previous ceiling is
Suur-Arneerika 1 / 10122 Tallinn / ESTONIA
Phone: +372 625 6342 / Fax: +372 631 3660 / E-rnail:
[email protected] / http://www.nikm.ee
unsustainable over a longer period oftime. As it is currently, an extreme and questionable short
terrn price hike, which reaches the price ceiling. autornatically triggers a raise in the price ceiling.
At the same time the reason for the fluctuation might not have been rnarket-driven and therefore
also no fundamental reasons requiring a raise in the price ceiling for the times to come. Therefore,
1 would kindly ask the Comrnission to explore possible alternatives that on the one hand could
provide the necessary safeguards for investments and energy producers, but on the other hand
would not overburden the consumers by facilitating ever higher extrerne prices that serve no
purpose. Considering the previous, an increase in the price ceiling should perhaps not be an
automatic process and should instead be preceded by a thorough analysis, establishing that raising
the price ceiling is necessary to ensure the efficiency of the market in the long-terrn. The electricity
markets in the EU are regulated by the Electricity Regulation and by the corresponding delegated
acts. Therefore, we encourage the Comrnission to consider proposing changes to related
regulations in order to ensure the better functioning of the electricity market and to encourage
investments into new generation capacities.
Thirdly, we would also highlight some of our initial concerns regarding the recent
announcement by some of the countries in the EU or in the EEA to possibly restrict electricity
trade and the availability of capacity, which in our view could he significantly
counterproductive towards the functioning of an efficient common energy market. While we of
course understand the concerns of energy security in light of the upcoming winter. we strongiy
believe that the steps taken should not he at the cost of dismantling the common energy market,
which has been built up over the years. We would kindly ask the Commission to take an active
role in safeguarding the work done so far and to ensure that ali steps taken are based on wider
solidarity and not on unilateral short-terrn gains.
We are grateful for considering our questions and concerns and we are looking forward to youi
feedback.
With best regards,
Riina Sikkut
Minister of Economic Affairs and Infrastructure
Katry Ahi
+372 625 6374
[email protected]
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