Independent working paper and policy brief on LTTR reform, FCA 2.0, and bidding-zone sequencing ahead of the Florence Forum (28–29 May 2026).
Core arguments
- The €1.83 billion transfer identified by ACER across 2015–2024 appears to emerge systematically from the current LTTR auction design.
- Mandatory TSO issuance without a reserve price can produce persistent clearing below fair-value levels.
- If bidding-zone splits proceed before FCA reform, Article 30’s mandatory-issuance default automatically extends to Europe’s largest congestion borders.
- The paper argues FCA reform should therefore precede major zone reconfiguration.
- A targeted amendment pathway under Regulation 2016/1719 is proposed, including transparency reforms, revised issuance rules, FTR obligations, and voluntary counterparties.
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