John France
Energy Trading - Operations
Bridget Morgan
Ofgem
9 Millbank
London
SW1P 3GE
Date 7th February 2003
Reference jrf/bettagcode2.doc
Dear Bridget,
Ofgem/DTI - Consultation on the Development of a Grid Code
to apply under BETTA
In response to the above consultation document dated December 2002 I have the following comments on behalf of Powergen UK plc. The comments are primarily made in the same order as requested in consultation sections 4.13 and 5.39.
- General comments
Powergen are supportive of the development of a GB GCode, governed by a single GCode Review Panel (GB GCRP), and using the existing E&W GCode as the primary basis for development of the GB GCode. Also, it is appropriate that the GB System Operator (GB SO) as single body should be licenced to have in force a GB GCode at all times.
- Specific comments
a) section 4.13
- the proposal that the GB System Operator should be the “owner” of the GB GCode and that the GB GCode should be under the governance of a single panel
To minimise costs there is a need for simplicity, a one-stop shop for compliance issues, and to avoid having split or multi GCode “ownership” licence obligations. Thus our preference is that the single body licenced to have such a GB GCode in force at all times should be the GB SO.
- initial views on the role of the transmission owners in relation to data management issues raised
The GB SO and three TO’s structure must not be allowed to create any major issues regarding data management. Separation within a business with a number of electricity related licences, including a transmission licence, would provide suitable ring fencing of data such as planning data, modification applications, etc. where confidentiality and conflict of interest would otherwise be of some concern.
We are firmly of the opinion that all data requirements placed on Users of the transmission system should be explicitly identified within the GB GCode. This may comprise data items solely for use of the GB SO with a sub-set of data for use of the appropriate TO. Such data supplied pursuant to the GB GCode should be treated as commercial-in-confidence by the GB SO and/or the relevant TO. However, where there is a justified need to pass on whole or parts of such data between the GB SO and one or more TO’s, then licence obligations should be placed on the GB SO and TO’s to ensure User confidentiality is retained.
- The proposal that the basis for development of the GB GCode should be the existing E&W GCode together with consideration of separate regional technical requirement
Unlike the Scottish GCode, the E&W GCode has seen many changes since privatisation both for technical reasons and also for commercial reasons such as the introduction of NETA. Thus the E&W GCode already contains the technical requirements to support the E&W trading arrangements. We see this as a persuasive reason to adopt the E&W [NETA] GCode as the basis for development of the GB GCode.
In order to minimise costs and also to support GB wide trading and transmission arrangements, the continuation of separate regional and technical requirements should ideally be avoided as far as possible unless rigorously justified. This should be adopted as a principle for developing enduring arrangements for a GB GCode. However, we recognised that BETTA timescales may make retention of some limited regional differences unavoidable in the short term.
b) Paragraph 5.39
- the composition of the GCode Review Panel (GCRP)
It is noted that the current GCRP composition differs between E&W and Scottish GCRP, and that separation of SO and TO roles under BETTA will require consideration of the appropriate TO representation on the GB GCRP. It would seem appropriate to allow for limited TO representation on the GB GCRP, but this should be a proportionate representation and not unduly oppressive with respect to GB GCRP business.
Historic evidence shows that the over-whelming GCRP technical business is largely focussed on SO to Generator issues, which we suggest is unlikely to change significantly under BETTA. Thus we view the proposed increase to seven generator representatives on the GB GCRP panel as outlined in 5.7 as fully justified and sensible.
Paragraph 5.8 notes the Ofgem document 64/02 Governance of electrical standards – Final proposals. The list of “standards” which will eventually come under GCode governance is not yet agreed, but could embrace a wide spectrum of standards, specifications and procedural activities. The originator [or in the case of BS, IEC, etc. the selector] of many appropriate standards remains likely to be the GB SO or TO’s. However, Generators as developers and also the DNO’s also have considerable experience of standards/specifications and their use.
Thus we would argue that the use of “technical advisers” to GCRP members is likely to be far more effective than appointing a specific GB GCRP member for standards and specifications.
- including a panel function to minimise regional differences in the GB GCode
As stated above, the continuation of separate regional and technical requirements should ideally be avoided as far as possible unless fully justified as technically required and/or cost effective. Thus the GB GCode Constitution should include a function to seek to minimise regional differences unless so justified.
- document structure
We are satisfied with the E&W GCode structure and would agree with the Ofgem/DTI observation that there is no compelling reason to change from this common structure. We are comfortable with the proposal to include an Introductory section [or sections] in the GB GCode, provided it [or they]:
a) are for information only, and
b) do not form part of the GCode for compliance purposes
- defined terms
We would agree with the general adoption of E&W terminology and that demand forecast requirements for E&W GCode should be based on the prevailing E&W GCode provisions.
- balancing codes
We are generally comfortable with the E&W codes being adopted in the GB GCode.
- communications requirements
We would agree that the E&W communication requirements as provided in cc6.5.8 – electronic data communication facilities should apply in the GB GCode to all BM Participants.
- Ancillary Services
We accept the Ofgem/DTI proposal in 5.23 that the requirements currently embodied in the E&W GCode should be applied to generators in Scotland. However, we note that this may place new obligations on generating plant in Scotland which have agreed alternative performance criteria or those that do not match the more detailed E&W GCode requirements. It would be for Ofgem to consider the efficacy of using derogation from the GB GCode where appropriate.
Powergen support “market solutions” rather than obligatory GCode requirements for such as the Mandatory frequency response and reactive power. Thus the enduring GB GCode solution should allow for removal of the mandatory nature of these services by developing appropriate commercial market based arrangements.
- planning codes and data submission
We believe there are two major factors that have dictated the differences in planning codes and data submission requirement between Scotland and E&W. These two reasons are the treatment of 132kV in Scotland as the transmission voltage, i.e. rather than 275/400kV in E&W, plus the continual developments in trading arrangements in E&W.
We do not accept that significant differences in planning codes and data submission requirements are due to geographical or even technical reasons. Thus such differences should ideally be rationalised and avoided wherever possible.
As a general principle, specific regional requirements should be located separately within the GB GCode text to ensure Users can easily identify any additional requirements. This might also assist minimise future GB GCode amendments should any 132kV and/or 275/400kV assets owned by Scottish TO’s be divested in the future.
We would fully support the GB GCode adopting E&W Planning Code “Week 24” of the calendar year timing for data submissions.
- interconnectors
We believe that the GB arrangements for interconnectors should be based on the current provisions applying in E&W. Thus the GB GCode should not include any further special provisions for interconnector BM Units.
- MW levels for data requirements
Throughout the E&W GCode the defined terms Large, Medium and Small [Power Stations] are used to differentiate both technical requirements and data requirements. In many respects this simple categorisation of power stations by size gives E&W Generators clear MW bands for all GCode compliance requirements. Whether or not a power station is Embedded [i.e. connected at 132kV or less] is also used to further vary some data requirements.
We believe that the requirements for connectees to the 275/400kV E&W transmission system should be extended to the 275/400kV levels in Scotland.
We note the use of 5MW in SHETL and 30MW in SPT in Scotland as the level for “central despatch”, although we are unsure of the technical justification. The equivalent limit in E&W for data requirements is 50MW where BM Units at Large and Medium Power Stations are required to submit physical notifications. It would be preferable and less confusing if we can retain consistent terms, definitions and MW thresholds across the whole BETTA system. We thus support the continued use of the defined terms such as Large, Medium and Small Power Stations. It should be possible to conform most of the requirements for Medium (50-100MW) and Large (>100MW) Power Stations. For Small Power Stations (<50MW) it would be preferable to have a standard set of minimum requirements, supplemented by additional regional TO area requirements in Scotland where justified by legitimate operational reasons.
- operating codes
We support the Ofgem/DTI view that the E&W operating codes will form the basis of the GB GCode operating codes. However, we would wish to emphasise that Safety, Safety Co-ordination, and Numbering and Nomenclature of HV Apparatus are all of paramount importance. Minimum or no change will have minimum impact on most Users, but will need to be managed carefully by the GB SO and TO(s). We accept that no change is not fundamental to the BETTA market arrangements. Further consideration of an enduring solution is to be recommended.
- planning and licence standards
To minimise costs imposed on Users, we suggest that common standards should apply wherever possible across the three TO areas, accepting that more onerous standards may be necessary in limited cases within different TO areas. However, any differences must be fully justified technically to Ofgem and/or the GB GCode panel.
- current ongoing modifications
We note the two modification proposals highlighted in 5.3.6 and that Ofgem intend to capture these (and any other modification proposals) within the drafting consultations for the GB GCode.
Yours sincerely
John France, Energy Trading – Operations