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The document advocates for a more coherent institutional framework within the EU to ensure that energy market design supports the 2030 and 2050 climate goals. It identifies a disconnect between the IEM's focus on free movement of gas and electricity and standalone climate legislation. Key recommendations include creating an independent regional institution (IRSO) for least-cost system balance, strengthening the independence and mandate of National Regulatory Authorities (NRAs), and expanding the oversight roles of ACER and ENTSO-E to explicitly incorporate flexibility and demand-side measures.

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  • The current legal arrangements of the Internal Energy Market (IEM) do not sufficiently integrate environmental protection, as the IEM focuses on a single market for gas and electricity while climate policies are developed through separate legislation.
  • To meet 2030 climate and energy targets, institutional actors including ENTSO-E and ACER must have legal duties to ensure their tasks and network plans are consistent with EU policy goals.
  • The document proposes the creation of an Independent Regional System Operator (IRSO) to facilitate least-cost delivery of system balance and resource sharing across borders, moving beyond voluntary regional cooperation.
  • There is a critical need to reinforce the independence of National Regulatory Authorities (NRAs) from national governments to maintain market confidence, potentially through increased oversight by ACER or the Commission.
  • The role of Distribution System Operators (DSOs) and local energy markets requires a thorough review to ensure the integration of renewables, storage, and demand response, and to improve consumer rights and tariff design.
  • Current market monitoring by ACER is deemed insufficient due to lack of resources and data access, suggesting a need for enhanced real-time monitoring, possibly by an independent non-governmental entity.

Cite the original document

APA
Roberts, J., & Skillings, S. (2016). The market design initiative. ClientEarth. https://www.clientearth.org/media/fxzbs3rw/ce-market-design-initiative-8pp-web.pdf
Chicago
Roberts, Josh, and Simon Skillings. The market design initiative. ClientEarth, 2016. https://www.clientearth.org/media/fxzbs3rw/ce-market-design-initiative-8pp-web.pdf.
Wikipedia
{{cite report |last1=Roberts |first1=Josh |last2=Skillings |first2=Simon |title=The market design initiative |publisher=ClientEarth |date=October 2016 |url=https://www.clientearth.org/media/fxzbs3rw/ce-market-design-initiative-8pp-web.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}
BibTeX
@techreport{roberts2016market, author = {Roberts, Josh and Skillings, Simon}, title = {{The market design initiative}}, institution = {ClientEarth}, year = {2016}, month = oct, url = {https://www.clientearth.org/media/fxzbs3rw/ce-market-design-initiative-8pp-web.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }

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