I-SEM Programme
Change Request & Impact Assessment Form / JCR362
Section 1: CHANGE REQUEST DETAILS (to be completed by CR Originator)
CR Title: / Revised I-SEM Go Live Date
CR Description & Reason for submission: / Background:
The I-SEM Project is currently scheduled to Go Live on 23 May 2018. This date was established as a result of the Stocktake, undertaken in 2016, and predicated upon a number of assumptions. In particular, the Stocktake noted that:
•the central systems and processes which support the I-SEM [were] targeted to be delivered by end 2017;
•this [would] support a four month Market Trial (running in parallel to the existing SEM) starting in January 2018; and
•I-SEM [would then be] planned to Go Live during May 2018.
In some instances these assumptions subsequently proved incorrect. For example, it was necessary to specify the market systems before the detail in the Trading & Settlement Code (TSC) had been agreed and drafted. The assumptions made proved to be remarkably robust, with the notable exception of Settlements, where material changes to the systems built proved necessary in order to align those system designs to the TSC. These changes were successfully delivered to plan and introduced into the Market Trial from early February 2018. However, the management and vendor focus on delivering this significant change imposed costs and other challenges to the fixing of defects in the rest of the Market Management System.
As a result of the delivery challenges to the central market systems, including finding solutions to the large number of defects identified in the comprehensive testing process, the Go Live date was flagged as being “at risk” in February 2018. On 21 March, the SEM Committee (SEMC) reaffirmed this risk to Market Participants.
Since then the SEMC, along with the Regulatory Authorities and TSOs, has been liaising with Market Participants to assess whether a revision of the scheduled Go Live date would be necessary to ensure the effective transition to the I-SEM.
The feedback from Market Participants and the TSOs is that the transition to the new market would require an extension to the I-SEM Go Live date. While the SEMC considers it important that the Market is launched as soon as possible, particularly as all other components of the I-SEM project are ready, it takes the views of stakeholders on market and system preparedness seriously. The SEMC also accepts that the TSOs’ assessment of system readiness before Go Live is critical to the project’s success.
At its meeting on 12 April 2018, the SEMC acknowledged the significant work by all market participants, Transmission System Operators (TSOs) and the Regulatory Authority teams to progress the I-SEM project to the final stage of systems testing and trials in advance of Go Live.
However, recognising the realities of thechallenges facing the central market systems and the need to allow adequate testing of Market Participants‘ IT systems, the SEMC has decided, subject to the approval of this Change Request, that the Market will now go live on 1 October 2018. The timetable for future capacity auctions, including the T-4 auction, remains unchanged. A revised timetable for FTR auctions is currently being determined, and will be advised through a separate change request.
The SEMC has advised the Department of Communications, Climate Action and Environment and the Department for the Economy accordingly. This additional period is seen as essential to allow for residual IT system issues to be resolved and for a longer period of Market testing and trialling that will ensure the arrangements for the I-SEM go-live are effective.
Purpose of this JCR:
The purpose of this JCR is to propose and give effect to the changes which are required to the outstanding Milestones in the I-SEM Plan.
The need for additional Milestones will be considered and discussed with the PMG; if they prove necessary, those new Milestones will be introduced through one or more additional Change Requests.
This JCR proposes a revised Go Live date, and associated interim milestones, as follows:
•the completion of testing, and release of central market systems with no priority defects into the Market Trial environment in June 2018;
•an additional circa three month period for Market Trial;
•in parallel to the extended Market Trial, completion of certification of the balancing engine by early July 2018;
•a four week cutover period for the introduction of the new central market systems during September 2018.
In determining the revised date, the RAs and TSOs have taken account of the following factors:
•an additional planned software drop during May 2018 that was not included in the existing programme, to allow for the completion of the (known) defects that have been identified by the TSOs as priority defects for Go Live;
•the request from participants for a ‘clean unscripted period’ of a minimum of 7-8 weeks for them to complete Market Trialling;
•the resolution of any further defects arising from the Market Trial or the Balancing Market Certification process;
•likely pressures on resource availability arising from the summer holiday period;
•the preference to avoid a Go Live during the summer period; and
•the preference for the first full day of trading to be the 1st of the quarter.
In line with Section 5.2 of the I-SEM Change Control process, this change request is being progressed through the Fast Track Change Control process, with a five day period for impact assessment. This approach has been discussed with the EAI, and (as required by the process), has been approved by the I-SEM Joint Project Board. It was also outlined at the PMG Meeting of 12 April 2018, as being the process which would be followed in the event that the SEMC took a decision to modify the Go Live date. This will allow ratification of the change as soon as possible, and thus provide stability for all parties in undertaking any resultant replanning.
Proposed Changes:
The following milestones are proposed to be added or dates revised as a result of this change:
•New Milestone - #175 All Priority Defects Fixed and Deployed into Market Trial – Fri 1 June 2018
•#9 BM Engine Certification Complete - Fri 6 July 2018
•#86 Market Readiness Confirm Go-Live and Cutover, FTRs- Wed 22 August 2018
•#87 Market Trial Complete - Sun 30 September 2018
•#250 I-SEM Go-Live - Mon 1 October 2018
The following outstanding milestones remain unchanged:
•#119 SEMOpx Procedures Finalised - Thu 26 April 2018
•#215 MRC Approval (noting the date has already been reported as having slipped to 30 April 2018) – Mon 2 April 2018
Note that in the case of Milestone #87, the detail of Market Trial operations and coverage is specified in the I-SEM Market Trial Participant Guide (to be updated under change control to reflect the new timeline, once approved) and the detail of how and when cutover out of Market Trial occurs is detailed in the I-SEM Participant Cutover Guide (also to be updated under change control). Hence, in accordance with that Cutover Guide, it is likely that cutover of systems/markets will occur progressively over the final month of September 2018, but that as a minimum, the Balancing Market will continue running in the Market Trial until the Milestone Baseline Date of 30 September 2018.
Discussions are underway with the ICOs to determine the revised dates for the FTR Auctions. A further JCR will be raised to change these milestones once revised dates are identified.
On approval of the revised dates, above, the following documents will be updated and reissued under Change Control:
•Market Trial Plan
•I-SEM Market Trial Participant Guide
•I-SEM Participant Cutover Guide
•I-SEM Readiness Criteria, Governance and Contingency
CR Originating Party: / I-SEM Joint Project Board
CR Sponsor Name: / I-SEM Joint Project Board
CR Originator Names: / Simon Grimes / Helen Mounsey
CR Originator Email: /
CR Originator Phone:
CR Date Raised: / 20 April 2018 / Date Required: / ASAP
Section 2: CHANGE REQUEST LOGGING (to be completed by CCC / JPLG)
CR ID: / JCR_362
JPLG Date: / 18 April 2018
CR Priority: / Minimum / Moderate / Significant / X
Impacted Organisation(s): / Core Parties: / Other Impacted Parties (please list):
TSO / X
RAs / X
ICO / X
PLGs:
PMG / X
BLG
TLG
Date issued for IA: / 20 April 2018
Due Date for IA completion: / 27April 2018
Section 3: IMPACT ASSESSMENTS (to be completed by relevant party)
CR Impact Assessment
A total of eight Impact Assessments were received from Market Participants. Of these, two were submitted with a request to be considered in confidence and in accordance with the Change Control Procedure, will not therefore be reproduced in this document. All others are detailed below.
Additionally, a summary of the 44 issues raised in the impact assessments and responses to each of them, is included at the end of Section 3, below. Many of the key issues where presented at the Project Managers’ Group meeting which was held on 9 May, 2018.
The Impact Assessments were very welcome and useful; participants are kindly thanked for submitting them. The Impact Assessments have been fully considered in making a determination on this JCR, as can be seen in the changes made to that detailed in the original proposal.
Section 3: IMPACT ASSESSMENT (to be completed by relevant party)
Name, email and phone number of person completing IA (if different from CR Originator): / Aughinish Alumina Ltd.
Date IA completed and returned: / 24 April 2018
CR Impact Assessment
Aughinish welcomes the proposed revised I-SEM Go-Live of 1 October 2018.
We require a functioning test environment to ensure the market delivers what is the intention of the TSC.
We can only rely on the BM Engine Certification for confidence in the Central Market System.
The earlier the CMS is certified the sooner we can complete our tests.
We suggest the BM Engine Certification should be in early June rather than the proposed 6th July.
CR Estimated Time Impact / Target Date for Completion
CR Estimated Cost Impact (please state £ or €)
Section 3: IMPACT ASSESSMENT (to be completed by relevant party)
Name, email and phone number of person completing IA (if different from CR Originator): / Viridian
Date IA completed and returned: / 27th April 2018
CR Impact Assessment
Include suggested process, impact on dependencies, project schedule, project scope, identify individuals/organisations involved.
CR Estimated Time Impact / Target Date for Completion
Viridian would like to ensure the following is included as part of detailed re-planning of the I-SEM programme:
•No cessation of Market Trials activities, and it continues to run all markets producing the required data/report outputs
•While we welcome the continual running of the Balancing Market through September, it should be accepted that at the point SEMOpx markets are no longer running Market Trials as an activity ends – the level 2 milestone should reflect this rather than state Market Trials is running until the end of September
•BM certification should be brought forward to 18th June. This allows 2 weeks of testing following final release on 1st June – following the PMG on 24th April we understand that certification is a 1 week activity. While BM certification is outstanding there is a risk that the code baseline may have significant issues that need resolved negating validity of market trial activities up to the point certification is achieved.
•Market retains a Go/No Go decision checkpoint on 22nd August, but a final decision is made w/c 3rd Sept. This gives sufficient time for participants to assess their readiness against the stable central systems. This is 4 weeks prior to go-live and aligns with previous timelines.
•Additional governance should be introduced to ensure we do not repeat the challenges we have encountered over the last few months:
•Identify mandatory milestones to ensure that 1st October can be achieved
•A clear approach for dealing with missed milestones
•Introduce independent readiness reviews
•Align Market Trials auctions as they will be when markets are live; 168hr exercise should have markets running as per times in live, this should continue outside of the 168hr exercise for the duration of market trials though if this cannot be achieved then sufficient time should be left between the various auctions and submissions as they would in a real world operation.
•Provision for restarts of 168hr trial if robust criteria are not achieved. Given misalignment between the market trial team and participants on this activity, as evident in recent PMGs, it may be of value holding a workshop to realign expectations.
CR Estimated Cost Impact (please state £ or €)
The delay of the I-SEM programme will have significant impact of Viridian I-SEM delivery costs.
Section 3: IMPACT ASSESSMENT (to be completed by relevant party)
Name, email and phone number of person completing IA (if different from CR Originator): / ESB
Date IA completed and returned: / 27th April 2018
CR Impact Assessment
ESB recognises the continued commitment and effort by EirGrid and the RAs to deliver the I-SEM programme and acknowledges the revised timelines as a prudent response to the difficulties experienced by the central systems to ensure the successful go-live of the new market for all participants.
Having reviewed this JCR we would note the following:
  • A minimum period of 8 weeks, in July and August, must be protected to allow all participants’ business users to execute Unscripted Market Trails on stable Central Systems and their own stable systems. Acceptable entry and exit criteria for Market Trials should be agreed between participants and SEMO to ensure good governance and transparency.
  • Everything must be done to ensure that I-SEM goes live successfully on the 1st October. A key element of this is early, accurate and transparent reporting of progress by EirGrid and all Participants.
  • Experience during market trials and before have raised significant concerns for participants especially in regards to SEMOPx’s service provider EPEX and the algorithm EUPHEMIA. The RA/SEMO project plan allows for certification of the Capacity and Balancing Markets and readiness of Central Systems. However the plan is silent on certification of Euphemia for I-SEM and approval that the governance of the algorithm is appropriate for I-SEM.
  • (Milestone 175) It is critical that the release of fully tested central market systems with no priority defects into Market Trials is completed by the 1st June 2018 to allow time for downstream impacts and changes to be made by participants ensuring a successful October 1st Go-Live
  • Contingency plans should be put in place in the event that key Central Market systems have not passed full testing and/or are not stable by June 1st.
  • Market connectivity must remain in place with markets running as they are in Market Trials today to allow participants complete quality End 2 End testing during the month of May. Market Reports must continue to be published as advertised and the QBOA information will continue to be published (even if wrong while fixes are being investigated)
  • It is imperative to the successful execution of Market Trials that the “Trading Day” reflects the real position as closely as possible. The Gate closures for EPEX Day Ahead Market are not reflective of live operations putting further pressure on participants to successfully test their operational procedures. It is critical that either the DAM gate closure is brought back to the real world timeline or the whole day is shifted to reflect the change to the DAM gate closure.
  • The Balancing Market certification milestone is proposed for the 6th July, given the importance of this milestone and the confidence in readiness it will provide participants an earlier BM certification milestone should be introduced for mid-June to checkpoint progress against BM certification and provide transparency.
  • A view should be provided by SEMO of outstanding defects that are not being planned to be delivered for 1st June and what the release plan is for these pre/post Go-Live. This should allow that participants can review and input into the categorisation of any such defects and allow participants to proactively manage any knock on effects in participant systems.
  • Due to the effort involved in co-ordinating and planning a successful cutover to I-SEM, 4 weeks must be protected for cutover activities and Market Trails should not be allowed to bleed into this time. As such, a new milestone should be introduced for 1st September to mark the completion of Market Trails/commencement of Cutover. The detailed cutover plan should be published before to 1st of June to allow participants to plan their respective cutovers plans.
  • Given the impact of I-SEM, input should be sought from participants and included in formulating the overall criteria for market readiness. As such, any revised readiness milestone should allow adequate time for participants to objectively assess overall market readiness.
  • Given the importance of I-SEM to Ireland an external review of quality of the Central Market Systems should be undertaken prior to Go-Live.

CR Estimated Time Impact / Target Date for Completion
CR Estimated Cost Impact (please state £ or €)
Section 3: IMPACT ASSESSMENT (to be completed by relevant party)
Name, email and phone number of person completing IA (if different from CR Originator): / Brookfield Renewable
Date IA completed and returned: / 27th April 2018
CR Impact Assessment