An Coimisiún um Rialáil Fóntas Commission for Regulation of Utilities. Decision Paper.

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1 An Coimisiún um Rialáil Fóntas Commission for Regulation of Utilities REQUEST FOR AMENDMENT (RfA) BY THE CRU OF EirGrid TSO and TSO Proposal for the Determination of LFC Blocks on the Synchronous System of Ireland/Northern Ireland (Under the System Operation Guideline) Decision Paper Reference: CRU18123 Date Published: 27/06/2018 Closing Date: N/A 0

2 Table of Contents 1 Introduction Commission for Regulation of Utilities Introduction to Decision and legal context The EirGrid and proposal Proposal by System Operators (EirGrid & ) Consultation phase CRU Regulatory Authority position Conclusion and Request for Amendment Next Steps

3 1 Introduction 1.1. Commission for Regulation of Utilities The Commission for Regulation of Utilities (CRU) is Ireland s independent energy and water regulator. The CRU s mission is to regulate water, energy and energy safety in the public interest. Further information on the CRU s role and relevant legislation can be found in here. 2 Introduction to Decision and legal context This document provides detail on the decision of the Commission for Utility Regulation (CRU), on the proposal on Load Frequency Control (LFC) Structure for the synchronous area of Ireland and Northern Ireland, in accordance with Article 141(2) of the Commission Regulation (EU) 2017/1485 of 2 nd August 2017 establishing a guideline on electricity transmission system operation (System Operation Guideline or SOGL). The proposal was jointly submitted 12 th January 2018 by the Irish Transmission System Operator (TSO) EirGrid and the Northern Ireland TSO,, in line with Article 5 (1) and Article 6(3) (g) of the SOGL. The CRU has worked closely with the Utility Regulator of Northern Ireland in the development of this decision. As per article 141(2) of the SOGL, all TSOs of a synchronous area shall jointly develop a common proposal regarding the determination of the LFC blocks, which shall comply with the following requirements: (a) a monitoring area corresponds to or is part of only one LFC area; (b) a LFC area corresponds to or is part of only one LFC block; (c) a LFC block corresponds to or is part of only one synchronous area; and (d) each network element is part of only one monitoring area, only one LFC area and only one LFC block. 2

4 3 The EirGrid and proposal 3.1 Proposal by System Operators (EirGrid & ) The Load Frequency Control (LFC) Block proposal as submitted constitutes the TSOs common proposal and outlines the proposed LFC Block blocks, LFC area and LFC monitoring area for the synchronous are of Ireland /Northern Ireland. (IE/NI). The proposal outlines the TSOs proposal to have one LFC Block, one LFC area and one monitoring area across the synchronous area. The CRU agrees with the proposal to have one LFC Block and one LFC area. In reviewing the proposal to have only one monitoring area across the synchronous area the CRU have considered the monitoring responsibilities of EirGrid in line with their licensed activities (Condition 3 of EirGrid Licence) and the requirement to closely coordinate with in achieving the required levels of monitoring and safe system operation. The CRU has also taken into consideration the approaches adopted by other European TSOs and Regulatory Authorities. In this regard it is noted that, elsewhere in Europe, where there are multiple TSOs within a bidding zone there are multiple monitoring areas, in addition no other proposed monitoring area includes two Member States. 3.2 Consultation phase EirGrid and conducted a public consultation on their proposed LFC Block Structure from 29 th November 2017 and closed on the 8 th January One response was received to this consultation, and the TSOs addressed the concerns of the respondent in their final submitted proposal to the Regulatory Authorities. The TSOs proposal submitted detail which outlined that there would be one monitoring area, one LFC area, and one LFC Block within the existing Allisland Synchronous area. This proposal outlined the following TSO responsibilities for each structure as per the below table. The responsibilities of TSOs in relation to Load Frequency control and monitoring are outlined in the SOGL, specifically as follows; for TSO of a monitoring area in Article 141(3), for TSOs of each LFC area in Article 141(4), for TSOs of each LFC Block in Article 141(5), and for TSOs of each synchronous area in Article 141(6) 3

5 These Articles and subsequent articles essentially require a variety of frequency control processes and activities from the relevant TSOs as outlined in Table 2 below; Table 2: Outline of requirements according to monitoring area, LFC area, LFC Block and Synchronous Area New agreements will require to be drafted between the relevant TSOs regarding responsibilities for processes and activities as outlined within Article 141 (and other articles) of the SOGL. In essence a LFC Block agreement, an LFC Area agreement and a Synchronous Area agreement will be required. The TSOs are due to prepare and submit the relevant sections of these documents to the Regulatory Authorities during September

6 4 CRU Regulatory Authority position The CRU has reviewed the TSOs proposal in accordance with the requirements of SOGL, the wider objectives of the Regulation (EC) No 714/2009 and our statutory duties and obligations and has liaised with the Utility Regulator of Northern Ireland in this decision as per the requirements of Article 6 (7) of the SOGL. The CRU consider that the proposals to create designate the All-island system as one LFC Block, and one LFC area is in line with current operational practice, and will best align with system operation processes and procurement mechanisms for reserve services. In reviewing the proposal to have only one monitoring area across the synchronous area the CRU have considered the operational responsibilities of EirGrid in line with their licensed activities (Condition 3 of EirGrid Licence) and the requirement to closely coordinate with in achieving the required levels of monitoring and safe system operation. Also, the CRU consider that the proposal is aligned with other Member States approached. As outlined above and as required by Article 6 (7) of SOGL, the CRU have closely cooperated and coordinated with the Utility Regulator of Northern Ireland in order to reach agreement on this proposed request for amendment. The CRU considers that in line with the licensed activities of EirGrid that their responsibilities only extend to full operational monitoring on the EirGrid transmission system, i.e. within the jurisdiction of Ireland, and therefore will seek to ensure that EirGrid as licensed TSO in Ireland discharges its functions efficiently. The CRU recognises that there is currently close coordination between the EirGrid and in monitoring the All-island synchronous area and that this will continue with the implementation of an LFC Block and an LFC Area. 5 Conclusion and Request for Amendment The CRU hereby requests an amendment of the LFC Block proposal by EirGrid to ensure that two monitoring areas are established, and that EirGrid is solely responsible for the monitoring of its transmission system only, in line with its licensed activities. The CRU decision requests the following TSO responsibilities for each structure as per the below table: Country TSO (full company name) TSO (short name) Monitoring Area LFC Area LFC Block Ireland EirGrid EIRGRID EIRGRID EIRGRID + EIRGRID + Northern Ireland System Operator for Northern Ireland EIRGRID + EIRGRID + 5

7 In accordance with Article 7 (6) of SOGL, the TSOs must make the amendments necessary to address this request for amendment and submit the amended proposal to the RAs within two months of this decision. 6 Next Steps The TSOs must submit the amended proposal to the RAs within two months after publication of this decision. Following receipt of the amended proposal, a decision will be issued by the RAs. If you have any queries regarding the information contained within this paper, please contact mcloonan@cru.ie 6