a
fizz-$53195;
Postbus 718, 6800 AS Arnhem, Nederland DATUM 14 september 2018
Autoriteit Consument en Markt UW REFERENTIE
T.a.v. de heer dr. F.J.H. Don ONZE REFERENTIE REC-N 18-051
Postbus 16326 BEHANDELD 0005a
2500 BH DEN HAAG TELEFOON DIRECT
BETREFT Voorstellen op basis van artikel 118 van de Verordening (EU) 2017/1485 (GL SO)
Geachte heer Don,
Hierbij ontvangt u drie voorstellen die door de gezamenlijke TSO's van de synchrone zone "Centraal Europa"
zijn opgesteld op basis van de Verordening (EU) 2017/1485 van 2 augustus 2017 tot vaststelling van
richt-snoeren betreffende het beheer van elektriciteitstransmissiesystemen (op basis van de Engelse titel afgekort
als: GL SO). Het betreft:
. "All CE TSOs' proposal for the dimensioning rules for FOR in accordance with Article 153(2) of the
Commission Regulation (EU) 2017/1485 of 2 August 2017 establishing a guideline on electricity
trans-mission system operation" dd. 8 augustus 2018;
. "All CE TSOs’ proposal for the limits on the amount of exchange and sharing of FRR between
synchro-nous areas in accordance with Article 176(1) and Article 177(1) of the Commission Regulation (EU)
2017/1485 of 2 August 2017 establishing a guideline on electricity transmission system operation" dd. 8
augustus 2018;
. "All CE TSOs' proposal for the limits on the amount of exchange and sharing of RR between
synchro-nous areas in accordance with Article 178(1) and Article 179(1) of the Commission Regulation (EU)
2017/1485 of 2 August 2017 establishing a guideline on electricity transmission system operation" dd. 8
augustus 2018.
Bij elk van deze voorstellen is een Explanatory Note gevoegd. Ook is een document bijgevoegd waarin
ver-antwoording wordt afgelegd over de verwerking van de ontvangen zienswijzen ter gelegenheid van de
con-sultatie door ENTSO-E van 30 maart tot en met 3 mei 2018. Het voorstel en de bijlagen bevatten geen
ver-trouwelijke gegevens en kunnen integraal door u gepubliceerd worden.
Voor de goede orde merken wij op dat over het voorstel voor de aanvullende eigenschappen van FCR
over-eenkomstig artikel 154, tweede lid van de GL SO, zoals bedoeld in artikel 118, eerste lid, onderdeel b, van
de GL SO nog geen overeenstemming is tussen de TSO's van de synchrone zone "Centraal Europa". De
komende maanden zal aan dit voorstel verder worden gewerkt en zodra het voorstel beschikbaar is, zal het
alsnog ter goedkeuring aan u worden aangeboden.
TenneT TSO B.V. Bezoekadres Utrechtseweg 310, Arnhem Postadres Postbus 718. 6800 AS Arnhem Factuuradres Postbus 428, 6800 AK Arnhem Handelsregister Arnhem 09155985
a TenneT TSO B.V.
; I e n n e I DATUM 14 september 2018
a: Taking power ur’rhbrf 7. ONZE REFERENTIE REC-N 18-051
”GINA 2 van 2
U wordt verzocht de bijgevoegde voorstellen goed te keuren krachtens artikel 6, eerste lid, van de GL SO.
European Network or
Transmissron System Operators e n S
O. for Eleotrrcrty
All CE TSOs’ proposal for the dimensioning rules
for FCR in accordance with Article 153(2) of the
Commission Regulation (EU) 2017/1485 of 2
August 2017 establishing a guideline on
electricity transmission system operation
08.08.2018
‘J
A11 CE TSOs’ proposal for the dimensioning rules for FCR in accordance with
e n
t
S 0
Article 153(2) of the Commission Regulation (EU) 2017/1485 of 2 August 2017 establishing a guideline on electricity transmission system operation
Contents
1
Whereas... 3
2
Article 1 Subject matter and scope ... 3
3
Article 2 Definitions and interpretation... 4
4
Article 3 Dimensioning rules for the TSOs of th synchronous area CE...4
5
Article 4 Publication and implementation of the FCR dimensioning rules proposal ...4
6
Article 5 Language ... 5
All CE TSOs’ proposal for the dimensioning rules for FCR in accordance with
e n
t
S O .
Article 153(2) of the Commission Regulation (EU) 2017/1485 of 2 August 2017 establishing a guideline on electricity transmission system operation
All Transmission System Operators of synchronous area Continental Europe are taking into account the
following;
7
Whereas
8
(1)
This document is a common proposal developed by all Transmission System Operators of
9
synchronous area CE (hereafter referred to as “TSOs”) regarding the development of a proposal for
10
the dimensioning rules for FCR (hereafter referred to as “FCR dimensioning rules proposal”) in
11
accordance with Article 153 of the Commission Regulation (EU) 2017/1485 of 2 August 2017
12
establishing a guideline on electricity transmission system operation (hereafter referred to as “SO
13
GL”).
14
15
(2)
The FCR dimensioning rules proposal takes into account the general principles and goals set in the
16
SO GL as well as Regulation (EC) No 714/2009 of the European Parliament and the Council of
17
13 July 2009 on conditions for access to the network for cross—border exchanges in electricity
18
(hereafter referred to as “Regulation (EC) No 714/2009”). The goal of the SO GL is the
19
safeguarding of operational security, frequency quality and the efficient use of the interconnected
20
system and resources. It sets for this purpose rules to determine the reserve capacity for FCR
21
required for the synchronous area CE, which shall cover at least the reference incident, and also set
22
rules to determine the shares of the reserve capacity on FCR required for each TSO of CE as initial
23
FCR obligation.
24
25
(3)
The scope of the FCR dimensioning rules proposal is to establish rules to dimension the reserve for
26
FCR required, while respecting the requirements set in Article 153(2) of the SO GL.
27
28
(4)
According to Article 6 of the SO GL, the expected impact of the FCR dimensioning rules proposal
29
on the objectives of the SO GL has to be described. It is presented below. The proposed FCR
30
dimensioning rules proposal generally contributes to the achievement of the objectives of the
31
Article 4(1) of the SO GL.
32
33
(5)
In particular, the FCR dimensioning rules proposal responds to the objectives of SO GL to
34
determine common operational security requirements, and to ensure the conditions for maintaining
35
operational security and frequency quality level throughout the Union, by establishing rules for the
36
adequate dimensioning capacity for FCR, which is essential to stabilize the system frequency at a
37
stationary value after any imbalance between generation and consumption.
38
39
(6)
In conclusion, the FCR dimensioning rules proposal contributes to the general objectives of the SO
40
GL to the benefit of all market participants and electricity end consumers.
41
42
SUBMIT THE FOLLOWING FCR DIMENSIONING RULES PROPOSAL TO ALL REGULATORY
43
AUTHORITIES:
44
Article 1
45
Subject matter and scope
46
The FCR dimensioning rules as determined in this proposal shall be considered as the common proposal of
47
all TSOs of CE in accordance with Article 153(2) of SO GL.
“
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
82
83
84
85
86
87
88
All CE TSOs’ proposal for the dimensioning rules for FCR in accordance with
e n
t
S 0
Article 153(2) of the Commission Regulation (EU) 2017/1485 of 2 August 2017 establishing a guideline on electricity transmission system operation
Article 2
Definitions and interpretation
1. For the purposes of the FCR dimensioning rules proposal, terms used in this document shall have the
meaning of the definitions included in Article 3 of the SO GL, Article 2 of Regulation (EC) 714/2009,
Article 2 of Directive 2009/72/EC and Article 2 of Commission Regulation (EU) 543/2013.
2. In this FCR dimensioning rules proposal, unless the context requires otherwise:
a) the singular indicates the plural and vice versa;
b) the table of contents and headings are inserted for convenience only and do not affect the
interpretation ofthis FCR dimensioning rules proposal; and
c) any reference to legislation, regulations, directive, order, instrument, code or any other enactment
shall include any modification, extension or re—enactment of it then in force.
Article 3
Dimensioning rules for the TSOs of th synchronous area CE
The FCR dimensioning for the synchronous area CE in positive and negative direction is equal to the
reference incident of 3000 MW, according to S0 GL article 153(2b.i).
The shares of the reserve capacity on FCR required for each TSO P,- as initial FCR obligation for a
considered calendar year t shall be based on the following expression, according to Article 153(2d) for all
TSOs in SA CE:
Gi,t—2 + Li,t—2
Pl,t FCRdlmenswnmg (Gu,t—2+Lu,t—2>
With:
0 Pi,t being the inital FCR obligation for TSO i for the calendar year t ;
o FCRdimensioning being the FCR dimensioning value calculated for synchronous area CE;
0 Gi,t_2 being the electricity generated in the control area 1' (including the electricity production for
exchange of reserves and scheduled electricity production from jointly operated units or groups)
during the second last calendar year with respect to the considered year t;
0 Li,t_2 being the electricity consumption in the control area 1' during the second last calendar year
with respect to the considered year t;
0 Gu,t_2 being the total (sum of) electricity production in all control areas of the synchronous area
CE during the second last calendar year with respect to the considered year t;
0 Lu,t_2 being the total consumption in all control areas of the synchronous area CE during the
second last calendar year with respect to the considered year t.
Every year but not later than March 31th, each TSO of the synchronous area CE shall provide to each other
the data regarding the generation and consumption in its control area in the previous calendar year.
Article 4
Publication and implementation of the FCR dimensioning rules proposal
1. The TSOs shall publish the FCR dimensioning rules proposal without undue delay after all NRAs have
approved the proposal or a decision has been taken by the Agency for the Cooperation of Energy
Regulators in accordance with Article 6 (1) and (8) of the SO GL.
All CE TSOS’ proposal for the dimensioning rules for FCR in accordance with
e n
t
S O .
Article 153(2) of the Commission Regulation (EU) 2017/1485 of 2 August 2017 establishing a guideline on electricity transmission system operation
89
2. The TSOs shall implement the FCR dimensioning rules proposal provided one month after the
90
regulatory authorities have approved the proposal in accordance with Article 6(3) SO GL or a decision
91
has been taken by the Agency in accordance with Article 6(8) SO GL.
92
Article 5
93
Language
94
The reference language for this FCR dimensioning rules proposal shall be English. For the avoidance of
95
doubt, where TSOs need to translate this FCR dimensioning rules proposal into their national language(s),
96
in the event of inconsistencies between the English version published by TSOs in accordance with Article 8
97
of the SO GL Regulation and any version in another language, the relevant TSOs shall, in accordance with
98
national legislation, provide the relevant national regulatory authorities with an updated translation of the
99
FCR dimensioning rules proposal.
100
‘
European Network or
Transmissron System Operators e n S
O. for Eleotrrcrty
All CE TSOs’ proposal for the limits on the
amount of exchange and sharing of FRR between
synchronous areas in accordance with Article
176(1) and Article 177(1) of the Commission
Regulation (EU) 2017/1485 of 2 August 2017
establishing a guideline on elect
08.08.2018
All CE TSOs’ proposal for the limits on the amount of exchange and sharing of
e n
t
S O ‘
FRR between synchronous areas in accordance with Article 176(1) and Article 177(1) of the Commission Regulation (EU) 2017/1485 of 2 August 2017 establishing a guideline on elect
Contents
1
Whereas... 3
2
Article 1 Subject matter and scope ... 4
3
Article 2 Definitions and interpretation... 4
4
Article 3 Limits on the amount of exchange and sharing of FRR between synchronous ...5
5
Article 4 Publication and implementation of the FR limits on exchange and sharing between
6
synchronous areas proposal ... 5
7
Article 5 Language ... 5
%
All CE TSOs’ proposal for the limits on the amount of exchange and sharing of
e n
t
S O .
FRR between synchronous areas in accordance with Article 176(1) and Article 177(1) of the Commission Regulation (EU) 2017/1485 of 2 August 2017 establishing a guideline on elect
All Transmission System Operators of synchronous area Continental Europe are taking into account the
following;
8
Whereas
9
(1)
This document is a common proposal developed by all Transmission System Operators of
10
synchronous area CE (hereafter referred to as “TSOs”) regarding the development of the limits on
11
the amount of exchange and sharing of FR between synchronous areas involving Continental
12
Europe (hereafter referred to as “FRR exchange and sharing limits between synchronous areas”) in
13
accordance with Articles 176(1) and 177(1) of Commission Regulation (EU) 2017/1485
14
establishing a guideline on electricity transmission system operation (hereafter referred to as “SO
15
GL”). This proposal is hereafter referred to as “FRR limits on exchange and sharing between SA
16
proposal”.
17
18
(2)
The FRR exchange and sharing limits between synchronous areas proposal takes into account the
19
general principles and goals set in the SO GL, as well as Regulation (EC) No 714/2009 of the
20
European Parliament and of the Council of 13 July 2009 on conditions for access to the network for
21
cross—border exchanges in electricity (hereafter referred to as “Regulation (EC) No 714/2009”). The
22
goal of the SO GL is the safeguarding of operational security, frequency quality and the efficient
23
use of the interconnected system and resources. For this purpose, it sets requirements for limits on
24
the amount of exchange as well as sharing of aFRR and mFRR between synchronous areas.
25
26
(3)
The FRR limits on exchange and sharing between synchronous areas proposal takes into account
27
the load—frequency control structure of each synchronous area in accordance with Article 139 of SO
28
GL. The operation of load—frequency control processes is based on operational areas, where every
29
area has their individual responsibilities with respect to the LFC structure. The superior structure is
30
the synchronous area in which frequency is the same for the whole area.
3 1
32
(4)
Article 176(1) and 177(1) of SO GL require all TSOs of each synchronous area to define a method
33
to determine limits for the exchange and sharing of FR with other synchronous areas in the
34
synchronous area operational agreement. In particular:
35 o In accordance with Article 176(1), the method to determine limits for the exchange of FR
36
shall take into account the operational impact between the synchronous areas; the stability of
37
the FRP of the synchronous area; the ability of the synchronous area to comply with the
38
frequency quality target parameters defined in accordance with Article 127 and the FRCE
39
target parameters defined in accordance with Article 128 of SO GL; and the operational
40
security.
41
o In accordance with Article 177(1), the method for determining the limits for sharing of FR
42
shall take into account: the operational impact between the synchronous areas; the stability of
43
the FRP of the synchronous area; the maximum reduction of FR that can be taken into
44
account in the FR dimensioning rules in accordance with Article 157 as a result of the FR
45
sharing; the ability of the TSOs of the synchronous area to comply with the frequency quality
46
target parameters defined in accordance with Article 127 and the ability of the LFC blocks to
47
comply with the FRCE target parameters defined in accordance with Article 128; and the
48
operational security.
49
50
(5)
The scope of the FR limits on exchange and sharing between synchronous areas proposal is to
51
establish the limits on the amount of exchange and sharing of FR between synchronous areas in
All CE TSOs’ proposal for the limits on the amount of exchange and sharing of
e n
t
S O .
FRR between synchronous areas in accordance with Article 176(1) and Article 177(1) of the Commission Regulation (EU) 2017/1485 of 2 August 2017 establishing a guideline on elect
52
order to respect operational security. This proposal does not apply to exchange or sharing of FR
53
within a synchronous area.
54
55
(6)
According to Article 6(2)(d)(ix) of the SO GL, it requires all TSOs to develop methodologies,
56
conditions and values included in the synchronous area operational agreements in Article 118
57
concerning the definition of limits on the amount of exchange of FR between synchronous areas
58
in accordance with Article 176(1) SO GL and limits on the amount of sharing FRR between
59
synchronous areas in accordance with Article 177(1) SO GL. The hereafter presented exchange
60
and sharing between synchronous areas proposal shall define the requested methodologies,
61
conditions and values.
62
63
(7)
The FRR limits on exchange and sharing between synchronous areas proposal is to respond to the
64
objective of SO GL pursuant to Article 4(1) to ensure the conditions for maintaining a frequency
65
quality level of all synchronous areas throughout the Union, by permitting exchange and sharing
66
between synchronous areas under certain limits in order to avoid detrimental effect on each
67
synchronous area.
68
69
(8)
In conclusion, the FR limits on exchange and sharing between synchronous areas proposal
70
contributes to the general objectives of the SO GL to the benefit of all market participants and
71
electricity end consumers.
72
73
SUBMIT THE FOLLOWING FRR LIMITS ON EXCHANGE AND SHARING BETWEEN
74
SYNCHRONOUS AREAS PROPOSAL TO ALL REGULATORY AUTHORITIES:
75
Article 1
76
Subject matter and scope
77
The FRR limits on exchange and sharing between synchronous areas as determined in this proposal shall be
78
considered as the common proposal of all TSOs of CE in accordance with Article 176 and 177 of the SO
79
GL. This proposal does not apply to exchange and sharing of FR within the synchronous area CE.
80
Article 2
81
Definitions and interpretation
82
1. For the purposes of the FRR limits on exchange and sharing between synchronous areas proposal,
83
terms used in this document shall have the meaning of the definitions included in Article 3 of the SO
84
GL, Article 2 of Regulation (EC) 714/2009, Article 2 of Directive 2009/72/EC and Article 2 of
85
Commission Regulation (EU) 543/2013.
86
87
2. In this FRR limits on exchange and sharing between synchronous areas proposal, unless the context
88
requires otherwise:
89
a) the singular indicates the plural and vice versa;
90
b) the table of contents and headings are inserted for convenience only and do not affect the
91
interpretation of this FRR limits on exchange and sharing between synchronous areas proposal; and
92 c) any reference to legislation, regulations, directive, order, instrument, code or any other enactment 93 shall include any modification, extension or re—enactment of it then in force.
“
All CE TSOs’ proposal for the limits on the amount of exchange and sharing of
e n
t
S O .
FRR between synchronous areas in accordance with Article 176(1) and Article 177(1) of the Commission Regulation (EU) 2017/1485 of 2 August 2017 establishing a guideline on elect
94
Article 3
95
Limits on the amount of exchange and sharing of FR between synchronous
96
1. A reserve receiving TSO of a LFC block involved in the exchange of aFRR and mFRR between
97
synchronous areas, where synchronous area of Continental Europe is the reserve receiving synchronous
98
area, shall ensure that at least 50 % of its total combined FRR capacity resulting from the aFRR and
99
mFRR dimensioning rules according to the Article 157 of the SO GL and before any reduction due to
100
the sharing of aFRR and mFRR according to Article 157(2) of the SO GL remains located within its
101
LFC block.
102
103
2. Each TSO of a LFC block shall have the right to perform sharing of aFRR and mFRR with a LFC block
104
in an adjacent synchronous area. In particular:
105
a) where the synchronous area CE is the reserve receiving synchronous area, the sharing of aFRR and
106
mFRR is possible within the limits set by the aFRR and mFRR dimensioning rules in Article
107
157(1), Article 157(2)(j, k) and Article 158 of the SO GL.
108
i.
In case of sharing and pursuant to Article 157(2)(j, k) of the SO GL, the reduction of the
109
positive (resp. negative) reserve capacity on FRR of a LFC block shall be limited to the
110
difference, if positive, between the size of the positive (resp. negative) dimensioning incident
111
and the reserve capacity on FRR required to cover the positive (resp. negative) LFC block
112 imbalances during 99 % of the time, based on the historical records referred to Article
113
157(2)(a). Additionaly, the reduction of the positive reserve capacity shall not exceed 30 % of
114
the size of the positive dimensioning incident;
115
b) where synchronous area CE is the reserve connecting synchronous area, no limits shall apply.
116
Article 4
117
Publication and implementation of the FRR limits on exchange and sharing between
118
synchronous areas proposal
119
1. The TSOs shall publish the FRR limits on exchange and sharing between synchronous areas proposal
120
without undue delay after all NRAs have approved the proposal or a decision has been taken by the
121
Agency for the Cooperation of Energy Regulators in accordance with Article 6(8) of the SO GL.
122
123
2. The TSOs shall implement the FRR limits on exchange and sharing between synchronous areas
124
proposal provided one month after the regulatory authorities have approved the proposal in accordance
125
with Article 6(3) SO GL or a decision has been taken by the Agency in accordance with Article 6(8)
126
S0 GL.
127
Article 5
128
Language
129
The reference language for this FRR limits on exchange and sharing between synchronous areas proposal
130 shall be English. For the avoidance of doubt, where TSOs need to translate this FRR limits on exchange and
131
sharing between synchronous areas proposal into their national language(s), in the event of inconsistencies
132
between the English version published by TSOs in accordance with Article 8 of the SO GL Regulation and
133
any version in another language, the relevant TSOs shall, in accordance with national legislation, provide
134
the relevant national regulatory authorities with an updated translation of the FR limits on exchange and
135
sharing between synchronous areas proposal.
136
European Network of
Transmisston System Operators e n S
O. for Eleotnctty
All CE TSOs’ proposal for the limits on the
amount of exchange and sharing of RR between
synchronous areas in accordance with Article
178(1) and Article 179(1) of the Commission
Regulation (EU) 2017/1485 of 2 August 2017
establishing a guideline on electr
08.08.2018
‘g
All CE TSOs’ proposal for the limits on the amount of exchange and sharing of
e n
t
S O .
RR between synchronous areas in accordance with Article 178(1) and Article 179(1) of the Commission Regulation (EU) 2017/1485 of 2 August 2017 establishing a guideline on electr
Contents
1
Whereas... 3
2
Article 1 Subject matter and scope ... 4
3
Article 2 Definitions and interpretation... 4
4
Article 3 Limits on the amount of exchange and sharing of RR between synchronous areas...5
5
Article 4 Publication and implementation of the RR limits on exchange and sharing between synchronous
6
areas proposal ... 5
7
Article 5 Language ... 5
All CE TSOs’ proposal for the limits on the amount of exchange and sharing of
e n
t
S O .
RR between synchronous areas in accordance with Article 178(1) and Article 179(1) of the Commission Regulation (EU) 2017/1485 of 2 August 2017 establishing a guideline on electr
All Transmission System Operators of synchronous area Continental Europe are taking into account the
following;
8
Whereas
9
(1)
This document is a common proposal developed by all Transmission System Operators of
10
synchronous area CE (hereafter referred to as “TSOs”) regarding the development of the limits on
11
the amount of exchange and sharing of RR between synchronous areas involving Continental
12
Europe (hereafter referred to as “RR exchange and sharing limits between synchronous areas”) in
13
accordance with Article 178(1) and 179(1) of Commission Regulation (EU) 2017/1485 of 2
14
August 2017 establishing a guideline on electricity transmission system operation (hereafter
15
referred to as “S0 GL”). This proposal is hereafter referred to as “RR limits on exchange and
16
sharing limits between synchronous areas proposal”.
17
18
(2)
The R exchange and sharing limits between synchronous areas proposal takes into account the
19
general principles and goals set in the SO GL/Regulation as well as Regulation (EC) No 714/2009
20
of the European Parliament and of the Council of 13 July 2009 on conditions for access to the
21
network for cross—border exchanges in electricity (hereafter referred to as “Regulation (EC) No
22
714/2009”). The goal of the SO GL is the safeguarding of operational security, frequency quality
23
and the efficient use of the interconnected system and resources. For this purpose it sets
24
requirements for limits on the amount of exchange as well as sharing of RR between synchronous
25
areas.
26
27
(3)
The RR limits on exchange and sharing between synchronous areas proposal takes into account the
28
load—frequency control structure of each synchronous area in accordance with Article 139 of SO
29
GL. The operation of load—frequency control processes is based on operational areas, where every
30
area has their individual responsibilities with respect to the LFC structure. The superior structure is
31
the synchronous area in which frequency is the same for the whole area.
32
33
(4)
Article 178(1) and 179(1) of SO GL require all TSOs of each synchronous area to define in the
34
synchronous area operational agreement a method to determine limits for the exchange and sharing
35
of R with other synchronous areas. In particular:
36 o In accordance with Article 178(1), the method to determine limits for the exchange of RR shall
37
take into account the operational impact between the synchronous areas; the stability of the
38
RRP of the synchronous area; the ability of the synchronous area to comply with the frequency
39
quality target parameters defined in accordance with Article 127 and the FRCE target
40
parameters defined in accordance with Article 128 of SO GL; and the operational security.
41
o In accordance with Article 179(1), the method for determining the limits for sharing of RR
42
shall take into account: the operational impact between the synchronous areas; the stability of
43
the RRP of the synchronous area; the maximum reduction of R that can be taken into account
44
in the RR dimensioning rules in accordance with Article 160 as a result of the RR sharing; the
45
ability of the TSOs of the synchronous area to comply with the frequency quality target
46
parameters defined in accordance with Article 127 and the ability of the LFC blocks to comply
47
with the FRCE target parameters defined in accordance with Article 128; and the operational
48
security.
49
‘5
All CE TSOs’ proposal for the limits on the amount of exchange and sharing of
e n
t
S O .
RR between synchronous areas in accordance with Article 178(1) and Article 179(1) of the Commission Regulation (EU) 2017/1485 of 2 August 2017 establishing a guideline on electr
50
(5)
The scope of the RR limits on exchange and sharing between synchronous areas proposal is to
51
establish the limits on the amount of exchange and sharing of RR between synchronous areas in
52
order to respect operational security.
53
54
(6)
According to Article 6(2)(d)(x) of the SO GL, it requires all TSOs to develop methodologies,
55
conditions and values included in the synchronous area operational agreement in Article 118
56
concerning the definition of limits on the amount of exchange of RR between synchronous areas in
57
accordance with Article 178(1) SO GL and limits on the amount of sharing FRR between
58
synchronous areas in accordance with Article 179(1) SO GL. The hereafter presented exchange and
59
sharing between synchronous areas proposal shall define the requested methodologies, conditions
60
and values.
61
62
(7)
The R limits on exchange and sharing between synchronous areas proposal responds to the
63
objective of SO GL to ensure the conditions for maintaining a frequency quality level of all
64
synchronous areas throughout the Union, by permitting exchange and sharing between synchronous
65
areas under certain limits in order to avoid detrimental effects on each synchronous area.
66
67
(8)
In conclusion, the RR limits on exchange and sharing between synchronous areas proposal
68
contributes to the general objectives of the SO GL and to the benefit of all market participants and
69
electricity end consumers.
70
71
SUBMIT THE FOLLOWING RR LIMITS ON EXCHANGE AND SHARING BETWEEN
72
SYNCHRONOUS AREAS PROPOSAL TO ALL REGULATORY AUTHORITIES:
73
Article 1
74
Subject matter and scope
75
The RR limits on exchange and sharing between synchronous areas as determined in this proposal shall be
76
considered as the common proposal of all TSOs of CE, in accordance with Article 178 and 179 of the SO
77
GL. This proposal does not apply to exchange or sharing of RR within the synchronous area CE.
78
Article 2
79
Definitions and interpretation
80
1. For the purposes of the RR limits on exchange and sharing between synchronous areas proposal, terms
81
used in this document shall have the meaning of the definitions included in Article 3 of the SO_GL,
82
Article 2 of Regulation (EC) 714/2009, Article 2 of Directive 2009/72/EC and Article 2 of Commission
83
Regulation (EU) 543/2013.
84
85
2. In this RR limits on exchange and sharing between synchronous areas proposal, unless the context
86
requires otherwise:
87
a) the singular indicates the plural and vice versa;
88
b) the table of contents and headings are inserted for convenience only and do not affect the
89
interpretation of this RR limits on exchange and sharing between synchronous areas proposal; and
90 c) any reference to legislation, regulations, directive, order, instrument, code or any other enactment
91
shall include any modification, extension or re—enactment of it then in force.
All CE TSOs’ proposal for the limits on the amount of exchange and sharing of
e n
t
S O .
RR between synchronous areas in accordance with Article 178(1) and Article 179(1) of the Commission Regulation (EU) 2017/1485 of 2 August 2017 establishing a guideline on electr
92
Article 3
93
Limits on the amount of exchange and sharing of RR between synchronous areas
94
1. A reserve receiving TSO of a LFC block involved in the exchange of RR between synchronous areas,
95
where synchronous area CE is the reserve receiving synchronous area, shall ensure that at least 50 % of
96
its total RR capacity resulting from the RR dimensioning rules according to the Article 160 of the SO
97
GL and before any reduction due to the sharing of RR according to Article 160(5) of the SO GL,
98
remains located within its LFC block.
99
100
2. Each TSO of a LFC block shall have the right to perform sharing of R with a LFC block in an
101
adjacent synchronous area. In particular:
102
a) in case the synchronous area CE is the reserve receiving synchronous area, the sharing of R is
103
performed within the limits set by the RR dimensioning rules in Article 160(4,5) and in Article 161
104
of the SO GL.
105
b) in case the synchronous area of CE is the reserve connecting synchronous area, no limits shall
106
apply.
107
Article 4
108
Publication and implementation of the RR limits on exchange and sharing between
109
synchronous areas proposal
110
1. The TSOs shall publish the RR limits on exchange and sharing between synchronous areas proposal
111
without undue delay after all NRAs have approved the proposal or a decision has been taken by the
112
Agency for the Cooperation of Energy Regulators in accordance with Article 6(8) of the SO GL.
1 13
114
2. The TSOs shall implement the RR limits on exchange and sharing between synchronous areas proposal
115
provided one month after the regulatory authorities have approved the proposal in accordance with
116
Article 6(3) SO GL or a decision has been taken by the Agency in accordance with Article 6(8) SO GL.
117
Article 5
1 18
Language
119
The reference language for this RR limits on exchange and sharing between synchronous areas proposal
120 shall be English. For the avoidance of doubt, where TSOs need to translate this RR limits on exchange and
121
sharing between synchronous areas proposal into their national language(s), in the event of inconsistencies
122
between the English version published by TSOs in accordance with Article 8 of the SO GL Regulation and
123
any version in another language, the relevant TSOs shall, in accordance with national legislation, provide
124
the relevant national regulatory authorities with an updated translation of the RR limits on exchange and
125
sharing between synchronous areas proposal.
126
‘
European Network or
Transmissron System Operators e n S
O. for Etectrrcrty
Explanatory note for the FCR dimensioning rules
proposal
08.08.2018
Explanatory note for the FCR dimensioning rules proposal
3 n
t
S O .
Explanatory note
1
An appropriate amount of FCR available in the synchronous area is essential to stabilize the system
2
frequency at a stationary value after any imbalance between generation and consumption.
3
The basic criterion used for FCR dimensioning is to withstand the reference incident in the synchronous
4
area by containing the system frequency within the maximum frequency deviation and stabilizing the
5
system frequency within the maximum steady—state frequency deviation.
6
The reference incident is defined as the maximum expected instantaneous power deviation between
7
generation and demand in the synchronous area for which the dynamic behaviour of the system is designed.
8
This expected instantaneous power deviation includes the losses of the largest power generation modules or
9
loads, loss of a line sector or a bus bar, or loss of a HVDC interconnector. The SO GL (Article 153 (2b.i))
10
sets the reference incident for CE to 3000 MW in both directions.
11
This criterion assumes a balanced situation when the incident occurs. In order to consider prior imbalances
12
derived from changes in demand, renewable generation or the market—induced imbalances, the
13
dimensioning of FCR capacity can be calculated by combining the probability of forced instantaneous
14
outages with the probability of used FCR due to the already existing frequency deviations (not associated
15
with generation trips).
16
The SO GL (Article 153 2(c)) allows the possibility for the synchronous area CE to define and apply a
17
dimensioning approach to calculate the reserve capacity on FCR that must at least cover the reference
18
incident, and based on the principle of covering the imbalances in the synchronous area that are likely to
19
happen once in 20 years. This probabilistic methodology assumes the following starting hypothesis such as
20
full activation time of automatic FRR, tripping rates of the generation plants, patterns of load, generation
21
and inertia (including synthetic inertia), which are difficult to estimate and have a strong influence on the
22
results.
23
On the other hand, in the recent past, the FCR capacity dimensioned in CE (equal to the reference incident
24
3000 MW in both directions) has proven to be enough to ensure the conditions for maintaining the
25
frequency quality level and respecting the operational security requirements.
26
For all these exposed above, the FCR dimensioning capacity in CE shall be equal to the reference incident
27
for positive and negative directions.
28
According to the Article 153(2) of Commission Regulation (EU) 2017/1485 establishing a guideline on
29
electricity transmission system operation, by 12 months after entry into force of this Regulation, all TSOs
30
of a synchronous area shall jointly develop a common proposal regarding the dimensioning rules for FCR,
31
which shall comply with the following requirement:
32
o The reserve capacity for FCR required for the synchronous area shall cover at least the reference
33 incident and, for the CE and Nordic synchronous areas, the results of the probabilistic dimensioning
34
approach for FCR carried out pursuant to point (c);
35
o For the CE and Nordic synchronous areas, all TSOs of the synchronous area shall have the right to
36
define a probabilistic dimensioning approach for FCR taking into account the pattern of load, generation
37
and inertia, including synthetic inertia as well as the available means to deploy minimum inertia in
real-38
time in accordance with the methodology referred to in Article 39, with the aim of reducing the
39
probability of insufficient FCR to below or equal to once in 20 years.
40
This proposal takes into account all the previous requirements.
41
Finally, and according to the Article 6(3) this proposal shall be subject to approval by all regulatory
42
authorities of the synchronous area CE.
“
European Network or
Transmissron System Operators e n S
O. for Electrrcrty
Explanatory note for the limits on the amount of
exchange and sharing of FRR between
synchronous areas
08.08.2018
Explanatory note for the limits on the amount of exchange and sharing of FR
6 n
t
S O .
between synchronous areas
Explanatory note
1
Regarding Article 3:
2
The exchange and sharing of aFRR and mFRR between synchronous areas is a process TSOs do not foresee
3
to be implemented, at least before the implementation of the corresponding balancing platform performing
4 cross—border activation of aFRR and mFRR, according to EB GL. In this sense, TSOs at a first stage are not
5
able to perform security assessment of such exchange or sharing. TSOs’ intention is not to block any kind
6
of initiative in future, this is why the only rules considered for exchange or sharing of aFRR or mFRR,
7
where receiving synchronous area is synchronous area CE, are the same rules applied to LFC Blocks within
8
the synchronous area CE itself: i.e. at least 50% of the FR capacity resulting from the FRR dimensioning
9
rules shall remain located in the LFC block in case of exchange. For the avoidance of doubt this limit is
10
applicable to the sum of sharing and exchange with TSOs from within and outside the synchronous area.
11
When synchronous area CE is the reserve connecting synchronous area, no limits are foreseen at this stage.
12
This proposal relies on the fact that if such an exchange or sharing of aFRR and mFRR is going to be
13
implemented in the future, specific security analysis studies will be needed in any case. Respective
14
requirements and a corresponding notification process among TSOs as well as procedures for reservation of
15
cross—border transmission capacities will have to be elaborated. Particularly, the ability of the synchronous
16
area to comply with the frequency quality target parameters defined and the FRCE target parameters
17
defined in accordance to Articles 176 and 177 of SO GL shall be considered. In this context additional
18
requirements in terms of limited amount of mFRR might be necessary, leading to amendments of this
19
proposal. In such a case, TSOs’ concerns would be as anticipated as possible with national regulatory
20
authorities.
‘5
European Network or
Transmissron System Operators e n S
O. for Electrrcrty
Explanatory note for the limits on the amount of
exchange and sharing of RR between
synchronous areas
08.08.2018
Explanatory note for the limits on the amount of exchange and sharing of RR
6 n
t
S O .
between synchronous areas
Explanatory note
Regarding Article 3:
The exchange and sharing of RR between synchronous areas is a process TSOs do not foresee to be
implemented at least before the implementation of the corresponding balancing platform performing cross—
border activation of RR according to EB GL. In this sense TSOs, at a first stage are not able to perform
security assessment of such exchange or sharing. TSOs’ intention is not to block any kind of initiative in
future, this is why the only rules considered for exchange or sharing of RR where receiving synchronous
area is synchronous area CE are the same rules applied to LFC blocks within the synchronous area CE
itself: i.e. at least 50% of the RR capacity resulting from the RR dimensioning rules shall remain located in
10
the LFC block in case of exchange.
11
When synchronous area CE is the reserve connecting synchronous area, no limits are foreseen at this stage.
\OOO\IO\Ul-I>UJN>—A
12
This proposal relies on the fact that if such an exchange or sharing of R is going to be implemented in the
13
future, specific security analysis studies will be needed in any case and respective requirements and a
14
corresponding notification process among TSOs as well as procedures for reservation of cross—border
15
transmission capacities will have to be elaborated. Particularly, the ability of the synchronous area to
16
comply with the fiequency quality target parameters defined and the FRCE target parameters defined in
17
accordance to articles 178 and 179 of SO GL shall be considered. In this context, additional requirements in
18
terms of limited amount of RR might be necessary leading to amendments of this proposal. In such a case,
19
TSOs’ concerns would be as anticipated as possible with national regulatory authorities.
“
e n ts 0Q
06 July 2018
All TSOs’ proposals for the Policy on Load Frequency Control and Reserves (LFCR) of the Synchronous Area
Framework Agreement in accordance with Article 118 of Commission Regulation (EU) 2017/1485 of 2 August
2017 establishing a Guideline on Electricity Transmission System Operation:
0 Article A-1 pursuant to Article 118 paragraph 1 (a) the dimensioning rules for FCR in accordance with
Article 153.
0 Article A-2 pursuant to Article 118 paragraph 1 (b) additional properties of FCR in accordance with Article
154(2).
0 Article A-5 pursuant to Article 118 paragraph 1 (z) the methodology to determine limits on the amount of
exchange of FRR between synchronous areas defined in accordance with Article 176(1) and the
methodology to determine limits on the amount of sharing of FRR between synchronous areas defined in
accordance with Article 177(1).
0 Article A-6 pursuant to Article 118 paragraph 1 (aa) the methodology to determine limits on the amount of
exchange of RR between synchronous areas defined in accordance with Article 178(1) and the
methodology to determine limits on the amount of sharing of RR between synchronous areas defined in
accordance with Article 179(1).
Response to public consultation comments received during the consultation held 30 March — 03 May 2018.
Remarks:
(i)
identical comments from different stakeholders have been grouped where possible, to improve the readability;
(ii)
the references to the articles and paragraphs are based on the versions of the proposals that were submitted to public consultation (see the
consultation at ENTSO-E consultation hub).
entsofl
06 July 2018
W”.
No Article Specified Comment/ Suggestion Change in Response Reviewer
Article Article yes/no affiliation
1 A—1 3 EDF considers that this article does not require any change or clarification. No Thank you very much for your comment. EDF
EDF agrees with the FCR dimensioning for the synchronous area Your input is noted.
Continental Europe in positive and negative direction to be equal to the reference incident of 3000 MW, according to SO GL article 153(2b.i) and as stated in Article 3 of Article Al FCR Dimensioning. EDF also agrees with the shares of the reserve capacity on FCR required for each TSO, as defined in Article 3 of Article A1 FCR Dimensioning.
2 A—1 3 The proposed Article prescribes in Article 3 ”The FCR dimensioning for the No The reference incident is currently defined ENGIE
synchronous area Continental Europe in positive and negative direction is equal to the reference incident of 3000 MW, according to SO GL article 153(2b.i)”. However, the reference incident is defined as the maximum expected instantaneous power deviation between generation and demand in the synchronous area for which the dynamic behavior of the system is designed. This expected instantaneous power deviation includes the losses of the largest power generation modules or loads, loss of a line sector or a bus bar, or loss of a HVDC interconnector.
According to ENGIE, it is necessary to change this article in order to add the definition ofthe reference incident. Setting the reference incident for Continental Europe to 3000 MW in both directions is not satisfying since the production units may change over the years (for instance, with the commissioning of the largest Nuclear Power Plant in France, or the increasing amount of wind production in the North Sea).
ENGIE notes that the Article does not retain the option to use the probabilistic approach. ENGIE strongly disagrees that the absence of incidents in the recent past is a reassurance for the future. ENGIE asks ENTSOE to clarify its position, and to define a time schedule to implement the probabilistic approach.
as 3.000 MW in Article 153 (2)(b)(i) so GL, a
change of this parameter is not possible. A definition of reference incident is not needed, since it is described in S0 GL.
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06 July 2018
“in”.
No Article Specified Comment/ Suggestion Change in Response Reviewer
Article Article yes/no affiliation
3 A—2 Whereas The Whereas (3) is in our opinion not complete. The last sentence of GL 50 Yes Comment acknowledged. The proposed VBG
(3) Art. 154.2 was not inserted in this text of the Whereas. With respect to transitional period has been considered and Article 154 of SO GL which determines only FCR technical minimum defined in Article 4 Publication and
requirements, all TSOs of a synchronous area have the right to specify, in Implementation accordingly to enable
the synchronous area operational agreement, common additional proper adaptation.
properties ofthe FCR required to ensure operational security in the synchronous area, by means of a set of technical parameters AND within
the ranges in Article 15(2)(d) of COMMISSION REGULATION (EU) 2016/631
of 14 April 2016 establishing a network code on requirements for grid connection of generators and Articles 27 and 28 of COMMISSION REGULATION (EU) 2016/1388 of 17 August 2016 establishing a Network Code on demand connection. TO BE COMPLETED WITH :” The TSOs shall apply a transitional period for the introduction of additional properties, defined in consultation with the affected FCR providers. In this document, nothing is mentioned about this obligation. It has to be adapted by insertion of this obligation Also in this document the meaning the wording ”AND” of Art.154.2 of GL $0 is not respected.
4 A—2 General We request all TSOs to justify the provisions’ necessity and proportionality, No in general The legal consistency between 50 GL and Eurelectric statement especially in case of retrospective application of requirements. Yes in details RfG has been checked.
regarding It is in particular important to notice that:
whole We also request all TSOs to consider the legal consistency in the setting of — RfG does not prevent to establish
article the methodology by respecting the 50 GL and RfG scopes. It is not the additional FCR properties for other
purpose of any deliverable resulting from the application of 50 GL to impose any requirements in terms of constructive capabilities. For legal consistency, any deliverable developed under $0 GL should only deal with the operation of the system, strictly in the respect of either the declared constructive capabilities for the existing units/groups or of the RfG requirements for new units.
If all TSOs assess it is necessary to apply the article 154 for setting new requirements to existing units, it can only be done after a clearjustification for the necessity and proportionality of such provision. This justification should provide evidence that the solution proposed is the optimal one — and both necessary and proportionate — whether the requirement proposed is copy/pasted from REG, whether it is ”within the range” of RfG requirements as described in article 154, or whether there is no real
production units than mentioned in Art. 15 RfG (Type C and D production modules).
As long as the requirements set in Table 4 of RfG can technically be applied to other units than Type C and D and at the same time that
application does not affect compliance to Art. 13 RfG by the relevant units, there is no inconsistency.
Article 154(6) imposes an obligation on all FCR providing units, both new and existing, to be able to activate FCR
06 July 2018
entso.
uriume Slnlmriahlr (nunrt miNo Article Specified
Article Comment/ Suggestion
Change in Article yes/no
Response Reviewer
affiliation
additional need requested. within the frequency ranges defined in
Article 13(1) RfG, nevertheless the respective time periods have to be determined by the T505 taking into account the technical boundary conditions of the respective FCR providing units or FCR groups. — In order to comply with EB GL as well,
all additional FCR Properties should be applied for any FCR delivering
production units, existing and newly connected, in a non—discriminatory way and should ensure to create a level playing field for all FCR providing producers,
— FCR properties that do not result from RfG, should be included as additional properties as long as they are necessary and applied in a non— discriminatory way and not conflicting with RfG requirements.
entsod
«Hum» Sunmnghlr {uar-lrl06 July 2018
No Article Specified Comment/ Suggestion Change in Response Reviewer
Article Article yes/no affiliation
5 A—2 General ENGIE appreciates the consultation on the Synchronous Area Operational Yes Additional Properties have been defined ENGIE
statement Agreement proposal. We are in favor of a market as large and diversified as based on operational experiences and to regarding possible in order that FCR need could be provided in an optimum way. As a ensure operational security also going
whole consequence, according to ENGIE, the minimum technical requirements for forward.
article FCR product shall stay as standard as possible. However, if TSOs assess that
the current standard properties for frequency containment reserves do not It is the intention to define requirements meet the operational security in the synchronous area, then the additional which do not need individual interpretation. requirements have to be defined in consultation with the affected FCR We tried to consider the comments as far providers, and, if it is not possible, TSO shall specify the requirements for an as possible (e.g. transitional period). additionnal standard product that matches their needs, on top of the FCR
volumes. In addition to the Eurelectric answer, that ENGIE fully supports, For further details please refer to the
we submit the following comments. response to comment No 4.
Article 154.2 of the SOGL specifies that: ”All TSOs of a synchronous area shall have the right to specify, in the synchronous area operational agreement, common additional properties ofthe FCR required to ensure operational security in the synchronous area, by means of a set of technical parameters” and ”within the ranges in Article 15(2)(d) of Regulation (EU) 2016/631 and Articles 27 and 28 of Regulation (EU) 2016/1388. Those common additional properties of FCR shall take into account the installed capacity, structure and pattern of consumption and generation of the synchronous area. The TSOs shall apply a transitional period for the introduction of additional properties, defined in consultation with the affected FCR providers.” Which means that:
0 The additional requirement have to ensure operational security. 0 Those additional requirements have to be within the ranges defined in Article 15(2)(d) ofthe RfG NC
0 Those additional requirements have to be defined in consultation with the affected FCR providers during a transitional period.
6 A—2 General No alternative wording on this article but a comment in relation to it and Yes There is probably a misunderstanding Compagnie
Statement the general basic remark described in questions n° 6 to 10 "AZ—additional concerning the scope of RfG and SO GL. Nationale ClU
regarding
properties of FCR". The choice of keeping 3000MW as an incidental
According to Article 2 (1)(e) SO GL, the rules Rhone (CNR)
whole reference and as a need for FCR volume should not mean that ENTSOE also and requirements of SO GL are applicable article needs to specify new requirements that are more restrictive but, above all, to active power providing units, whereas
retroactive for existing plants (which have historically proved their worth), RfG gives basic requirements for new units, bringing them to no longer have ability. The impact ofthe proposals of the which have to be fulfilled as preconditions
entsod
«rimmi- Sunmnghlr {unrlrzwrl06 July 2018
No Article Specified Comment/ Suggestion Change in Response Reviewer
Article Article yes/no affiliation
consultation and link with SO GL brings concretely in the case of run of river for connection. These RfG requirements hydros existing of the National Company of the Rhone to remove them should not be mixed up with conditions for from the factory with ability (because not being able to be totally rebuilt at prequalification of reserves, which are the equipment level). This is not acceptable especially since the debate and procured to safeguard operational security. the transposition of the n code validated that the new requirements only However the requirements proposed do in apply to new units and that existing units were defined in the context of principle not go beyond the existing Policy 1
past requirements (excluding substantial changes) and in addition a transitional period has
been defined to enable proper adaptation of existing providing units where necessary. The reference to RfG does no longer exist in the Article.
Nevertheless, the requirements were adapted as far as possible to take the comments into account.
7 A—2 General In the past, almost all FCR supplying units were not coherent with the wide Yes Please refer to answer of comment No.6. VGB Statement frequency ranges and durations imposed by RfG NC for NEW units and FCR
regarding has worked perfectly over the last 10 years and more. So experience has whole proved that no correlation exists between the two sets of requirements. article By stipulating those additional requirements, ENTSOE is imposing the RfG
NC on existing units.
Such retrospective action on existing units has never been the intention of and was never allowed by the European Commission.
VGB proposes to delete Art.3.2 of this document.
8 A—2 General First of all, and as a general principle, EDF considers that using provisions No in general Please refer to answer of comment No.4 EDF
Statement from RfG and extending their application without due justification, to Yes in details and No.6.
regarding existing units under SOGL is not acceptable (please see answer to Q7). whole Here, this article introduces, precisely with the sentence ’shall rise linearly article or quicker’, an additional requirement, in terms of constructive capabilities,
that goes even beyond the provisions of the Network Code Requirement for Generators’ (RfG), since the latter only requires two parameters in terms of dynamic performances: the initial delay and the time for full
06 July 2018
entsod
«rimmi- Sunmnghlr {unrlrzwrlNo Article Specified
Article Comment/ Suggestion
Change in Article yes/no
Response Reviewer
affiliation activation (respectively t1 & t2 in Figure 6 of article 15 of the RfG — see
hereunder). Furthermore without any clue justification, this requirement is justified neither for new units, nor for existing ones.
EDF would however like to underline that this Policy 1 document could be the opportunity to serve the purpose of harmonization for Frequency Sensitive Mode (FSM) requirements in operation. In fact, the RfG code left a lot of FSM requirements as non—exhaustive (to be defined at national level within a predefined range). Setting for operation strictly the same value for these FSM requirements (see IGD on FSM, in particular the droop) would ensure a level—playing field at European level (see the position paper presented in GC —European Stakeholder Committee on 09/12/2016). In summary, EDF considers that this paragraph, under the current circumstances and lack ofjustifications, should be removed.
In conclusion, EDF recalls any deliverable developed under SOGL should only deal with the operation of the system, strictly in the respect of either the declared constructive capabilities for the existing units/groups or of the
RfG requirements for new ones. If ENTSO—E wants to apply the article 154 from S0 GL (FCR technical minimum requirements) for setting new requirements to existing units, this can by no means be done by copy/pasting some RfG requirements. Considering all the above, EDF believes that there is currently no justification underpinning the TSOs’ proposal. In any case, CBA or detailed justification should provide evidence that the solution proposed is the optimal one — and both necessary and proportionate.
From a technical point of view, this requirement would lead to only two solutions for all existing FCR providing units/groups that are not compliant with this requirement: either a retrospective application of the
requirement, or no more possibility to participate to FCR services. The upgrade for some of these units could prove difficult or even impossible due to technical constraints. Moreover, there is absolutely no link between FCR capability and this requirement: indeed, many existing units/groups have been capable of providing frequency sensitive mode (FSM) for many years, without the capability to withstand unlimited time at
06 July 2018
entso.
llrlmhle Sunmliahlr funnrl m1No Article Specified
Article Comment/ Suggestion
Change in Article yes/no
Response Reviewer
affiliation 51Hz, for example.
As a consequence, imposing such a requirement would lower the liquidity for this product, and as a result would most probably increase the cost for the system and in the end for consumers.
In summary, EDF considers that this paragraph, under the current circumstances and lack ofjustifications, should be removed.
entsod
06 July 2018 Krlialllr Sunmrvahlr {unrlrtlrrl
No Article Specified Comment/ Suggestion Change in Response Reviewer
Article Article yes/no affiliation
9 A—2 General Note below [1] valid for the various questions on the requested Yes Please refer to answer of comment No.4 Compagnie
Statement requirements and the 50 GL interpretation of section 154 in particular. and N0. 6. Nationale ClU
regarding
As part of the general remark made in question 5 above we can not accept
Rhone (CNR)
whole that the articles described in this consultation and the interpretation of 50
article GL require retroactive application of the new requirements on existing units with the impact of inaptitude of our existing units that have proven themselves in the past. And all the more so since the debates and the transposition of the n code have clearly defined that the new
requirements are only necessary for new installations. The existing facilities (excluding substantial modifications) retained the past requirements and their past capacity.
This fundamental remark (with very high stakes and impact: losses of existing facilities such as that of the CNR without real justifications and after historical investment and a impossibility of modification on the part of an impact of the global equipment of the plant) is the one we ask to study for all the following questions ofthe consultation and on the application of the SOGL code article 154 and especially for the remark at the end of the text (identified [2]). Thank you
We ask you to take into account the consistency of texts and perimeters between 50 GL and RfG. The purpose of the SO GL application is not to impose requirements in terms of constructive capabilities. 50 GL should only deal with the operation of the system, the constructive capabilities are and have been dealt with in the n for new units. For existing units the requirements remain those declared and in accordance with the historical test requirements. For the operation of the system it is not normal that $0 GL imposes a deletion of existing capable facilities that have perfectly fulfilled their role previously.
Moreover, the answers and numerical requirements requested or on particular tests can not be in the context of hydraulic power plant and particularly old existing (or it is not possible to renovate everything) to be of the same order as units with power electronics. The mechanics, the
hydraulic effects (of water on the blades, of the hydraulics on the
