Increasing Capacity Behind Connection Points Liaison Group Meeting 03 March 2016
Increasing Capacity Behind Connection Points 1. Over-installing capacity (within CER approved limits) • using the same or different technology as the contracted unit • MEC remains unchanged but Installed Capacity increases 2. Adding capacity (additional MEC) • using the same or different technology as the contracted unit • MEC increases and Installed Capacity increases Presenting today on a number of issues identified by the SOs.
EXISTING POLICY FRAMEWORK
Increasing Installed Capacity • CER/14/047 – “Decision on Installed Capacity Cap” – Generators are not allowed to export in excess of MEC – Generators can install up to 120% of their contracted MEC – CER/14/047 supersedes • COPP Section 2.2 over-installation limit of 105% and • COPP Section 2.3 “… a full application form including specifics of exact plant to be installed, should be provided the SOs no later than 240 business days before energisation” as CER/14/047 applies to connected applicants as well as contracted applicants and repowering applicants. Note: the 240 days notice was intended to allow for submission of pre- energisation data hence we assume “energisation” in this context applies to energisation of the new capacity and not of the connection.
Hybrid Plant • COPP Section 6 – Hybrid rules apply to mixed technology and can be applied in two ways: 1. Retain existing MEC but over-install up to 120% of contracted MEC; or 2. Apply to increase MEC under GPA or non-GPA process depending on qualification for same. – In both cases, the applicant must comply with “Change in Installed Capacity” provisions in Section 2 of COPP (superseded by CER-14-047) and “Change in Generation Type” provisions in Section 9 of COPP.
Hybrid Plant • COPP Section 6 – Where there is no increase in MEC being requested process is via a modification to existing offers / agreements. • COPP 6.3.1 states that Hybrids shall be subject to the basic principal of central dispatch under the Grid Code and must be disaggregated by technology/fuel type. – Where there is an increase in MEC being requested the process is via the application process and may be GPA or Non-GPA. • If the new technology does not comply with the Non-GPA rules then the offer for an MEC increase cannot be processed until the next Group Processing project commences.
COPP Rules S9 - Change of Generation Type • Two scenarios: i. a change in type prior to energisation; and i. a change in generation type after a facility has been energised.
COPP S9 - Change of Generation Type Pre-Energisation • Pre-Energisation - generally only processed as per a new application where “ there are not considered to be any undue adverse impacts on either system, or on other users” . • Assessment includes the following considerations: – Where there is any change in priority dispatch status the party has gained no material advantage over other similar applications based on the original application; – Where other non firm generation connected or contracted to the system is not materially adversely affected in that the level (and in particular value) of anticipated constraints and curtailment would not rise significantly; – Where there is a change from being renewable to non-renewable or vice versa the party has gained no material advantage over other similar applications based on the original application; and
COPP S9 - Change of Generation Type Pre-Energisation – Where there is no appreciable anticipated increase in load factor from the old plant to the new plant, taking account of all other generation connected or contracted, which is expected to lead to significant or material additional network requirements being identified. • Question: CER/14/047 considered issues where capacity is being over-installed using the same technology and determined that constraints and curtailment levels were not materially impacted. Where different technology types are being used are there other considerations to be taken into account?
COPP S9 - Change of Generation Type Post-Energisation • Post-energisation - generally only processed as per a new application where “ there are not considered to be any undue adverse impacts on either system, or on other users” • Assessment includes the following considerations: – The access rights attributable would not in any case exceed the MW capacity currently contracted to the site / unit; – That access rights would be transferable such that, given all other generation connected or contracted, no significant or material additional network requirements would be expected to be identified (reflecting size, running regime but also generation technology and its effect on network stability);
COPP S9 - Change of Generation Type Post-Energisation – That access rights would be transferable such that other non firm generation connected or contracted to the system would not be adversely affected in that the level (and in particular value) of anticipated constraints or curtailment would not rise significantly; and – The SO would be given 2 years notice as to when a transfer of access rights is scheduled by a customer to take place. A failure to do so would consequently result in delays in facilitating the transfer of access rights or may mean that the network has changed to such a degree that a transfer is no longer feasible, or that the access rights have been offered to another project.
Summary of Applicable Policy • Where additional technology is the same, CER/14/047 applies: – Some issues need to be considered and are outlined in the following slides. • Where additional technology is different, then COPP Sections 2, 6 and 9 apply and CER/14/047 may apply if no MEC increase is being sought: – Applications may be processed as modifications if no MEC increase is being requested and as non-GPA or GPA if a MEC increase is being requested; – A range of issues arise which are considered in the following slides.
ADDITIONAL ISSUES TO BE CONSIDERED
List of considerations where over-installation involves no change in technology type • The additional capacity is installed as part of the existing unit: – No major issues – minor modifications required to meters / RTUs etc. – Implications for ownership of the new unit – Special Purpose Vehicles for new capacity are not allowed as this results in a sharing of connection points which is prohibited. • If customer wishes to install additional capacity as a separate unit then it raises questions: – How is MEC apportioned across multiple units? – How is Firm Access apportioned across multiple units? – How does it impact subsidies / feed in tariffs – does DCENR require the “new unit” to apply for a different subsidy e.g. REFIT II? – Implications for ownership of the new unit – Special Purpose Vehicles for new capacity are not allowed as this results in a sharing of connection points which is prohibited
Additional considerations where over installation involves a change in technology type • Additional capacity must be installed as a separately controlled unit per COPP rules: – How is MEC apportioned across multiple units? – What does this mean for the firmness of the new and old units? – How does it impact subsidies / feed in tariffs – the new unit may receive different subsidies? – Dispatch priority may be different for new and old units in a tie break situation. – Implications for ownership of the new unit – Special Purpose Vehicles for new capacity are not allowed as this results in a sharing of connection points which is prohibited.
Additional considerations where over installation involves a change in technology type – Which technology has priority where the availability of both units exceeds MEC and who determines this - the owner, SO, DCENR and SEMC all have an interest. • DCENR - e.g. a 100 MW MEC site is made up of 30 MW solar unit and 90 MW wind unit and both are fully available – if solar is allowed to generate then this increases overall subsidy costs (assuming a higher REFIT). • Forecasting output – we need to know which technology is likely to generate and availability of system services from that technology. • Application of tie break rules depend on which technology is being utilised. • If the site is fully firm and EirGrid need to constrain the unit for transmission reasons – the more expensive the unit generating, the higher the costs to End Users. • One technology may offer better system services than the other.
Apportioning MEC • How should a connection point MEC be apportioned across multiple units behind a single connection point? • MEC cannot be changed “ dynamically” – it is part of the SEM registration process and systems and the TUoS billing system. It is also part of the EirGrid control centre energy management system. • Initial thinking was that the MEC of each unit cannot exceed the summation of the connection point MEC however this could have an undesirable consequence: – e.g. a 100 MW MEC site is made up of 30 MW solar unit and 90 MW wind unit. If MEC is allocated as 20 MW to solar and 80 MW to wind then when solar output is 0% and wind is 100% the output from the wind unit is still limited to 80 MW and the 10 MW available wind is effectively stranded.
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