BIA STANDPOINT ON DRAFT LAW ON AMENDMENT AND SUPPLEMENT TO THE ENERGY ACT

BIA has sent to the Minister of Energy a standpoint within the public consultations of the Draft Law on amendment and supplement to the Energy Act, published on 27.07.2023.

First of all, we welcome the definition for the first time in the national legislation of the concepts and entities "civil energy community", "active customers" and "aggregators", respectively - their recognition as parties to electricity transactions.

In the motives submitted to the EA, there is no justification and motivation for the proposal to abolish the granting of a single license for the organization of an electricity exchange market (§15, Art. 43, para. 1, item 2). To the extent that such a step would theoretically promote competition and, consequently, improve conditions for consumers, it could be accepted as appropriate. From this point of view, an analysis and a reasoned assessment of the costs and benefits of such an act is necessary.

We support the increasing use of low-carbon energy sources, but note that there is a lack of information and justification for postulating a mandatory purchase of 60% of electricity from low-carbon sources in the formation of LV supply (§23, Art. 97, para. 4).

BIA has also presented its motives on eliminating cross-subsidies to household consumers at the expense of businesses, implementing and executing a previously approved action plan to eliminate cross-subsidies and fully liberalise the electricity market. The parameters of electricity market liberalisation included in the Electricity Act raise a number of issues that have no solution or justification in the proposed Bill.

Last but not least, it is advisable that the consideration, discussion and adoption of changes to legislation in a particular area, where they are related, should take place in an integrated and synchronised manner - simultaneously. From this point of view, we are referring to the changes being made to the Energy Act, the Renewable Energy Sources Act and the Energy Efficiency Act.