Response to the CRE on incentivising financially Balancing Responsible Parties and financing balancing reserves

Overall, we support the switch to 30-minute intraday cross-zonal gate closure time (IDCZGCT) and encourage its swift and coordinated implementation across Europe. Even though RTE has a derogation for implementation until January 2029, we emphasise the need for change as soon as possible to match the current implementation speed across Europe. Slower implementation in France consequently slows down implementation in the neighbouring countries.

We generally support the need for clear imbalance signals for balancing responsible parties (BRPs) and call for harmonisation of imbalance settlement methodologies on common denominators.

We strongly favour option 1 compared to the others, as it appears to be the most adequate, and as it does not add any further unnecessary complexity and uncertainty. Moreover, with option 1, we expect projects to help with balancing in the near future. Option 3 could still be possible, but would need a clear understanding of the impacts on the imbalance price. We are strongly against Option 2, as it would be highly complex to implement, retroactive, and there is a lack of visibility for BRPs on penalties.

We request faster, more reliable data to help balance the system, notably as we move closer to real-time and we integrate more RES.

Additionally, with a shorter IDCZGCT, we get closer to real-time, and market participants will also be more balanced closer to Gate Closure Time.