Axpo rejects the paradigm shifts associated with the planned amendments to the ordinance for fundamental reasons. A premature call-up of reserve power plants leads to a distortion of the market, while Swissgrid's activities in the areas of electricity generation, distribution and trading or its participation in electricity suppliers contradict the unbundling of the transmission grid and thus the central principle of the liberalized electricity market.
Axpo welcomes the planned amendment to the Electricity Act, but emphasizes that the regulations must be more comprehensive and should take into account the entire expansion of the electricity grid at all voltage levels. Focusing exclusively on the transmission grid is not enough to successfully master the challenges of the energy transition. Axpo is calling for an acceleration of procedures and a clear definition of responsibilities. In addition, the distribution grid infrastructure must be given greater focus, as it plays a central role in the security of supply.
There are no valid methodological reasons for switching to an experimental method for calculating the WACC for grid installations and plants for the generation of renewable energy. The low individual consumer savings are offset by uncertainties that may lead to further interventions and inhibit investments.
The blanket decree is a necessary but not sufficient step on the way to a renewable energy future. Axpo supports this compromise. Unfortunately, the amendment to the Spatial Planning Ordinance does not create the necessary conditions for achieving the energy policy objectives.
Axpo welcomes the adaptation of the FMIA to the development of international standards. In order to ensure equivalence and avoid distortions of competition, divergent regulations should be harmonized in all areas.
Axpo is supporting the Act on a Secure Electricity Supply from Renewable Energy Sources and considers it to be an important - even if not sufficient - step towards a secure electricity future. However, the planned implementation of the Electricity Act is problematic and is unlikely to help achieve the objectives defined in the Act. The proposed amendments to the ordinance do not create the necessary legal and planning certainty and in some cases even worsen the investment climate.
The amendment to the Electricity Supply Act is intended to limit the economic risks of companies in the electricity industry that are deemed systemically important as a result of exceptional market situations. The far-reaching requirements are internationally unprecedented and give the impression that all conceivable risks can be avoided. Targeted regulation should focus on the existence of appropriate risk management and apply to all relevant market participants for reasons of equal treatment.
The amendment to the Electricity Supply Act creates the legal basis for the participation of reserve power plants, emergency power groups and CHP plants - in addition to hydropower plants - in the electricity reserve. Because further plants are to be contracted to replace the temporary reserve power plant in Birr after 2026 and the necessary project planning work must begin quickly, compensation is provided for the project developers in the event that the bill fails politically. Axpo welcomes this provision, but because of the urgency of the necessary project planning work, is also in favour of compensation in the event that prospective permits are ultimately not granted. Axpo is critical of the promotion of CHP plants, which is also provided for in the bill, because the plants are unsuitable as supplementary reserve power plants and existing incentive measures to reduce emissions would thus be weakened.