What's in the EU-UK Brexit deal on energy?

It may be Boxing day, but I've had a quick look

Title VIII: Energy is the key section (page 156 onwards)

▶️ Standard stuff on commitment to competition, unbundling and customer choice

▶️ UK Capacity Market no longer needs to try to integrate overseas Capacity providers & vice versa

(Article ENER.6, Clause 3, page. 160)

▶️ Existing "exemptions" for selected interconnectors will continue to apply.

This means that these interconnectors can continue to sell capacity rights ahead of time, rather than all through close to real-time markets.

(Article ENER.11, page 162)

▶️ No network charges on individual interconnector transactions (as now)

▶️ But, UK cannot participate in EU procedures for capacity allocation and congestion management (more on this later)

(Article ENER.13, page 163)

Gas trading: looks like the UK stays in the existing PRISMA gas trading platform.

Not my specialist area, but is this because PRISMA isn't an EU institution (unlike electricity market coupling)?


(Article ENER. 15, page 164)

▶️ Network development: Parties to cooperate, including on interconnectors, but not much detail.
▶️ Security of Supply: Parties to cooperate, again not much detail. Can't see any references to a solidarity principle.

(Articles ENER. 16 and ENER. 17, page 165)

Cooperation between TSOs & Regulators:
- UK TSOs (i.e. National Grid) to cooperate with EU TSOs through cooperation with ENTSO-E and ENTSOG but not membership
- UK regulator (@Ofgem) to cooperate with EU regulators through ACER. Again, no UK membership

(Articles ENER.19+20)

New cooperation forum between UK and EU on offshore renewable energy.

Looks like UK no longer a member of North Seas Energy Cooperation, so a new forum is needed.

(Article ENER 23, page 169-170).

See summary of our report on Future of North Sea :

Final provisions, incl. termination (!)

Title on Energy ceases on 30 June 2026. Although can be extended to 31 March 2027 & again to 31 March 2028.

Seems linked to general termination provisions of the deal, including a reference to 🐟🐟 (Article FISH.17)

(ENER 33, p.172)

Onto Annexes. Only Annex ENER-4 is interesting. Covers day-ahead market coupling over interconnectors.

Market coupling ceases on 1 Jan 2021. Will be replaced by April'22 with "Multi-region loose volume coupling"

New term for many https://t.co/oSVDDiWFw9

Annex ENER-4 p.784

If I understand it correctly, new system will produce net flows on the interconnectors, rather than prices.

Creates a risk that interconnectors flow the "wrong way" (i.e. from high prices to low prices).

Algorithm is separate to EU day-ahead market coupling (EUPHEMIA)

Timeline to develop new system:
▶️ By April 2021: CBA and outline technical proposals
▶️ By November 2021: Technical proposals
▶️ By April 2022: System starts operating


Other provisions in the deal:

▶️ New Specialised Committee on Energy to discuss/implement some bits of the energy title and annexes (page 12)

▶️ Commitment to carbon pricing in the section on "level playing field"

[Title XI, Article 7.3, page 202]

▶️ Lots of sensible provisions, much to gain for both sides
▶️ Market coupling will be weaker, even with new system (Apr 2022)
▶️ Welcome focus on North Sea
▶️ Need to understand more on termination provisions

See more in our recent paper:


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