TO
MR PETAR ILIEV
EXECUTIVE DIRECTOR OF
NEK

COPY
MRS TEMENUZHKA PETKOVA
MINISTER OF ENERGY

Dear Mr. Iliev,

Last week was announced a tender for the sale of electricity from NEK EAD platform for bilateral contracts BNEB organized on June 19, 2019 The term of delivery, and declared by the seller deviations give grounds to suppose that this is the power generated from renewable energy sources with a power of between 1 and 4 MW.
Welcoming the decision that electricity can be sold on the free market, we disagree with the way you plan it.
AOBE of opinion is that such a large amount of (potentially over 390 MW) at the specified lead of 98 MW and opportunities to secure future payments by insurance, will rise further speculation as it will be purchased by a single buyer. In the current difficulties in the generation of electricity from coal and expensive emission allowances if and further create conditions for concentration, respectively controlled limited supply, the market will experience chronic power shortages and prices would be easily manipulated.
However, precisely to avoid such risks, the National Assembly passed legislative amendments backing the realization of electricity generated from renewable power between 1 and 4 MW of the free market. Reasons for its decision, the legislature clearly declares that the whole market determine prices and more liquidity in the energy market. Despite initial intentions release of the free market to start with the beginning of the new pricing period, unfortunately, it was delayed by one quarter. Therefore, by the end of September 2019 namely NEK will dispose of this electricity.
Given the foregoing, logically, rationally and market adequately NEK to sell electricity generated from renewable power between 1 and 4 MW, fully exchange segment “Market day ahead.” Recall that this is the segment and recognized by the EC and the Bulgarian legislation to determine the reference market price for past periods. In addition, if NEK adequately structured package short-term products – as a weekly peak around 5MVt products (following, for example, the profile of small photovoltaic) products with different (+) deviations, etc., small volumes (cumulatively to 15 20%) can be placed and the platform for bilateral agreement. This will avoid the possibilities of market manipulation, of what we were repeatedly witnesses.