Following on from several individual statements, a group of industry bodices have now issued a joint statement (here on the EEX site) providing suggested amendments to the new exemption calculations. The statement is issued by Europex, EFET, Eurelectric, BDEW , EnergyUK and Eurogas.
In addition to recommendations on changing the actual thresholds (to 25% for capital employed, and 15% for market share), there are suggestions on how to adjust the scope of activity in consideration when making the calculation, for example by risk weighting exchange traded and cleared trades. There is also a section on the impacts of changes to emissions rules on the ETS.
This follows many other objections, including statements already issued by EurElectric, and this press release from EFET. EEX also issued this press release welcoming the latest statement. As already stated in many earlier posts, it will be interesting to see what level of compromise is reached when then final RTS is published in July.