Initial Modification Report No.39. Transfer of Exit Capacity between Northern Ireland Exit Points to permit Secondary Trading of Exit Capacity
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1 Initial Modification Report No.39 Transfer of Exit Capacity between Northern Ireland Exit Points to permit Secondary Trading of Exit Capacity 30 th September 2016 Please find below Initial Modification Report No.39 prepared and published by Premier Transmission Ltd (PTL) as required under Section 3 of the PTL Transportation Code Modification Rules. PTL received the Modification Proposal from AES Ballylumford Limited (AES) on 26 th August and the full text of AESs proposal is attached to this document in Appendix 1. PTL fully recognises the important contribution of the power station load to the NI gas market and that the long term sustainability of the power stations is critical to the long term sustainability of both the gas and electricity markets. However, it considers that many of the issues raised in the proposal are seeking to treat the symptoms of the issues identified by the generators rather than the outright causes (which appear to be how power stations are remunerated for operating costs in the wholesale electricity market). The recent Exit Review conducted by the Utility Regulator concluded that the most appropriate place to address these issues is the i-sem market design. If the Utility Regulator decides to direct that the proposal should be further developed, it would entail a significant programme of work which could not be completed quickly (and more appropriately considered in the context of a single code and single IT system). In addition, PTL would highlight that the proposal is much more complex to assess, develop and implement than it may at first appear, because it would have to be done based on a detailed assessment of the physical capability of the respective TSO networks and because of the need to develop and consult on business rules. Please see section E and G for a full description of PTL s opinion. A Description of the nature and purpose of the modification The purpose of this Modification Proposal is to permit the Secondary Transfer of Exit Capacity on a daily basis between Exit Points on the Northern Ireland gas transmission system (to include the PTL SNIP, BGTL transmission system, GNI (UK) transmission system and the Gas to the West transmission system). Please see Appendix 1 for the full text of AESs proposal. B How the modification better facilitates the relevant objective AESs View AES considers that the Relevant Objective, (condition 2.4 of the PTL Licence) will be better facilitated by the Licensee s Network Code as a result of this modification as follows: PTL Initial Modification Report No th September
2 The implementation of this modification could provide a benefit to Gas Generators in allowing them to recover some legitimately incurred costs that currently cannot be recovered. This also reduces future financial uncertainties. Benefits the security of supply in Northern Ireland by helping to remunerate the increasing costs of existing gas fired generating plants due to their increasingly intermittent operation as a result of ongoing renewable penetration. This make the long term viability of these plants more predictable and hence more stable. Provides for improved investment signals for future gas fired generation in Northern Ireland. To meet the requirements associated with intermittent renewable generation, gas fired generation is currently the only viable option. Potential investors will want to see a regime whereby incurred costs associated with requirement to hold fixed Annual Exit Capacity can be recovered from the Market. Allows the most efficient use possible of existing gas assets and puts in place the conditions for a functioning secondary market to trade exit capacity. PTLs View PTL does not consider that, overall, the Relevant Objective would be better facilitated as a result of this modification, for the reasons set out in detail in section G below. C The clauses of the Transportation Code that require amendment The proposed modification would require changes to Section 1B of the PTL Transportation Code to provide for at least the following: capacity transfers of one-day duration capacity transfers between NI Network Exit Points Depending on the development of the detailed rules and processes, further changes may also be required to other areas of the PTL Transportation Code. D Impact on other Designated Pipeline Operator s Network Codes: Coolkeeragh ESB Ltd (Coolkeeragh) has raised an equivalent Modification Proposal to the GNI (UK) Code. At present the NI TSOs are working towards the implementation of the Single Code and the Single IT System, both to be managed and administered via a Contractual Joint Venture (CJV) between the NI TSOs. The delivery date for these arrangements is 1 st October The NI TSOs recommend that this Modification Proposal and Coolkeeragh s Modification Proposal should not be developed or implemented in advance of that date and that the post go-live period for the CJV would be a more appropriate juncture to appraise this modification in the context of a single code and single IT system. Please see section E for more details of a proposed programme for development of these proposals. If the Utility Regulator directs that the modification proposal is to be developed, consulted upon and potentially implemented before October 1 st 2017, then changes would be required to each of the PTL Transportation Code, the GNI (UK) Code and the WTL Code. Changes may also be required to the BGTL Code in respect of shorter notice periods for information transfer between the NI TSOs. PTL Initial Modification Report No th September
3 If the Utility Regulator directs that the modification proposal should be developed according to the programme recommended by the NI TSOs, or another programme with a delivery date after 1 st October 2017, then the changes would be made to the Single Code. It should be noted that the same logic applies in respect of changes to IT systems. Should implementation be directed prior to October 2017 then changes would be required to both Aligne and GTMS NI. These systems are stand-alone systems so there be significant complications (and costs) in developing the functionality to facilitate exit capacity transfers across the various NI gas transmission networks. Should implementation post October 2017 be directed, then this would allow the changes to be delivered on the Single IT System and hence be more efficient. E The date proposed for implementation AES proposes that the implementation date should be 1 st October In PTLs view, implementation by 1 st October 2016 is not possible because of the requirement for initial analysis, development of business rules (which should be consulted upon) as well as IT systems development lead times. In addition, it should be noted that the resources of the NI TSOs are fully committed to the development of the CJV, Single Code and Single IT System at this time. As noted above, the NI TSOs do not support implementation of this proposal, and they have major concerns about their resource availability to progress its development at this time. Therefore, should the Utility Regulator direct that the proposal should be further developed, then the NI TSOs request that a longer timetable be adopted, as further described below. The following indicative timetable sets out the necessary components of a programme to develop the Modification Proposals, along with indicative dates which are intended to provide a guide to the minimum timescales that the NI TSOs consider are required: Initial Business Rules Development Oct 17 Dec 17 Network Analysis/Impact Assessment Oct 17 Dec 17 Informal Consultation/Industry Meetings Dec 17 Jan 18 Formal Business Rules Consultation Feb 18 Legal Text Development March 18 Formal Consultation on Legal Text April 18 FMR / Utility Regulator Approval May 18 IT Requirements Specification March 18 IT Development & Testing June - August 18 IT Implementation/Go Live c. August 18 earliest, to October 18 latest This indicative programme would defer the start of development until the CJV, Single Code and Single IT System have been implemented, recognising the workload involved. It would then seek to provide a minimal period for development and analysis followed by progression of the proposal through the necessary stages of legal text and IT development as quickly as possible, aiming for implementation between August and October PTL Initial Modification Report No th September
4 The above programme also assumes successful and timely delivery of the Single IT System in particular. Should there be any delays or teething problems, then the start of such a programme would need to be deferred. However, the NI TSOs are of the view that, if required, implementation should be possible by October 2018 at the latest. F How to Respond Please send responses no later than 28 th October 2016 to: Lauren Skillen-Baine: Lauren.Skillen-Baine@mutual-energy.com Premier Transmission Limited First Floor, The Arena Building 85 Ormeau Road Belfast BT7 1SH G PTLs Opinion on the Modification Proposal Primary Purpose of the Proposal PTL considers that the benefits sought by the proposer are primarily concerned with the long term financial viability of, and consequently investment in, power stations in Northern Ireland and the remuneration of same in the electricity market. Whilst this is undoubtedly a very important issue for the Northern Ireland energy market, and one which is key to its long term sustainability, it does not in itself form part of the Relevant Objective 1 in the Licences of the NI Gas Transporters, in relation to the gas transmission system. PTL notes the conclusions of the recent Exit Review 2 conducted by the Utility Regulator were, essentially, that: the legitimate issues concerning funding and investment for power generators arise from the operation of the electricity market; and that attempts to address them should be, in the first instance, focused on developments of the i-sem arrangements. Whilst considering a number of issues and questions, the Exit Review focussed on whether short term capacity products should be introduced, for power stations. Generators supported the introduction of such products, as an opportunity to recover costs and improve profitability and stability for power stations, given the requirement to hold annual Exit Capacity. PTL considers that this modification proposal is an alternative proposition which is aimed at addressing the same underlying issues which lead to the Exit Review and requests for short term capacity products. It therefore believes that the same conclusion, that the issues should be addressed in the first instance in the i-sem arrangements, applies here. It also notes that the Exit 1 The definition of Relevant Objective (section 2.4 of the PTL Licence) refers to the secure, safe, reliable, efficient and economic development and operation and maintenance of the Network with due regard to the environment, and the promotion of effective competition between Users. 2 PTL Initial Modification Report No th September
5 Review did not rule out that there may be merit in reform of the gas exit arrangements, but that this was not assessed as necessary from a gas industry perspective. Efficient use of Capacity? The proposal suggests that implementation would allow the most efficient use of existing gas assets. PTL observes that there is no operational/physical problem with inefficient use of existing gas pipeline assets which is hindering Shippers (or otherwise resulting in capacity being unavailable) that this proposal would address or improve. Exit Capacity in the pipeline is made available on the basis that the amount available at a point reflects the ability of the network to deliver gas to that particular point, and the technical capacities of each Exit Point are carefully measured in order to ensure that the amount of Exit Capacity product commercially sold reflects the physical reality of what is available and hence can be delivered by the NI TSOs. The NI TSOs have discussed the two Modification Proposals which have been raised, and have fundamental concerns that any mechanism which introduces a divergence between the physical capability of the network at a particular point and the commercial product at that point: would be better suited to address issues of constraint management, which is not the context of this proposal; may give rise to unintended consequences, including artificial constraints and underrecovered revenues (and consequently larger bullet payments ); is much more complex to design and implement than may at first appear. These concerns are explored further below. Physical Efficiency? The secondary trade mechanism proposed allows the notional transfer of capacity from one point to a different point on the network. Obviously, physical capacity cannot be simply re-located on the network. Furthermore, it cannot be simply assumed that one unit of capacity at one location on the network is physically equivalent to one unit of capacity at another location, in terms of its impact on the wider day-today operation of the network, or the availability of capacity at other neighbouring or downstream points on the network. It would be essential to ensure that any transfer mechanism accurately reflected the physical capability and limits of the network. In the relatively simple NI Network configuration, this may not be too difficult to accomplish, but it is nonetheless vital, to ensure that there is no risk of unintended physical or operational consequences, and that the safe operation of the network can be maintained. Therefore, in order to offer capacity transfers between exit points, the appropriate ratio of physical equivalence between each pair of network points would first need to be determined along with the limits of applicability in respect of each specific point. This would probably be best investigated PTL Initial Modification Report No th September
6 using a network analysis-based approach 3 in order to design the parameters of such a scheme, Once the parameters had been obtained, a full impact assessment should also be carried out. The NI TSOs could undertake such a programme of analysis and investigation to explore for example whether allowing a transfer of capacity from one network point to another could mean that there may be more network capacity which could then made available at the recipient point, or other points on the network, i.e. that a potential physical efficiency benefit might be available. It would also explore the extent to which allowing a transfer would then limit what could be made available at other nearby or downstream Exit Points. Transferrable amounts would have to be limited to minimise the risk of causing difficulties elsewhere. Without pre-empting the conclusions of any analysis it is possible to observe, in order to manage any operational risk appropriately, the end result of such a process would very likely be that the quantities of capacity available to be transferred would be very low indeed, so as to potentially render the transfer process of very limited value to any party. In any event, it should not be possible to transfer capacity to an Exit Point to a level which, combined with the capacity already sold at the recipient Exit Point, exceeded the technical capacity available there. Were there a physical situation where the network was so constrained that there could be potential benefits to be gained in terms of moving physical capacity around the network in order to physically maintain supplies to particular parts of the network, then the NI TSOs may even recommend considering the development of such an approach as a possible means of alleviating physical constraints. However, this is not the situation which the proposal is seeking to address. Commercial Efficiency The proposal is explicitly seeking to address a question of commercial efficiency, concerning the redistribution of costs of capacity between Shippers. It focuses on the transfer of un-used capacity (already built and sold, but not being used on a day) and assumes that this can be achieved without considering the wider physical or commercial consequences. The NI TSOs would not be able to support a purely commercial model because, as described, Exit Capacity is a physical product, and hence there is a risk of unintended operational consequences unless the parameters of a transfer model are rooted in an assessment of the physical capability of the network which is likely to result in only small quantities of capacity being available to transfer. Coolkeeragh s proposal also suggests that the TSO is not affected since the capacity being transferred has already been sold at the regulated tariff. It is indeed the case that the NI TSOs will generally obtain their allowed revenue, including by means of the year end reconciliation process where necessary. However, both the Utility Regulator and the broader energy industry may wish to consider the potential re-distributional impact of allowing parties to access capacity on a short term basis through a secondary market, 3 The capacity substitution regime in GB provides an illustration of this issue, albeit in a much more complex network. PTL Initial Modification Report No th September
7 hence reducing revenue from annual capacity and either increasing unit prices for all parties and/or increasing the level of reconciliation payment required by all parties at the end of the year. This is notwithstanding that the NI TSOs fully appreciate the significance to the generators of the issues that they face concerning recovery of costs under the i-sem arrangements. New Investment The proposal suggests that implementation would provide for improved investment signals for future gas fired generation in Northern Ireland and refers to the commercial benefit of being able to recover some of the costs of fixed Annual Exit Capacity for new Shippers. Once again this is a commercial concern rather than a physical one. Coolkeeragh s proposal also suggests that users with non-coincident peaks may, by transferring capacity between themselves, create the opportunity for optimisation of the network. By contrast, where such users both have to book peak capacity, the system may be over-built. The NI TSOs consider that it is generally the case, especially with new large loads connected to the high pressure system, that investors would expect the network design to guarantee to deliver peak loads. Where peak capacity is not an absolute physical requirement for a new end user, an interruptible product would be more suited to addressing this need, and the capability of the network to deliver gas to that point could accordingly be specifically designed to be less-thanpeak. Administrative and Systems Complexity Any transfer mechanism would be complex to administer and potentially opaque for Shippers, since it would need to reflect any physical limitations determined in the analysis described above. Where the ratio of equivalence was not 1:1 for any pair of points, then it would be necessary to ensure that the IT system facilitated transfers on the correct basis, and also that the IT system applied any other limits appropriately, including not exceeding the technical capacity at the recipient point for any transfers. Whilst network analysis is needed to fully assess the issues, it is likely that the availability of physical capacity at an Exit Point on a day could vary depending on whether any capacity at that point or nearby points had been transferred away to another. It would therefore be necessary for the available capacity at a point to be a dynamic variable, capable of varying each day. The system requirements to administer any such mechanism would therefore be extensive, as they would need to incorporate a live update of the availability of capacity as well applying the appropriate limits between each pair of points at which transfers might be nominated and any consequential changes at neighbouring points. Unintended Consequences Since as described above, the NI TSOs would insist that any transfer mechanism was based on a physical assessment of the capability and limits of the network, it is also the case that transfers between network points could lead to the artificial/commercial creation of physical constraints, and it would be vital that this potential impact should be properly assessed and the risks managed. PTL Initial Modification Report No th September
8 The NI TSOs would also need to consider, when designing and defining the technical capacity of new points, how to take into account the possibility of exit capacity transfers occurring. This would consequently bring into question how the existing levels of technical capacity are defined. Conclusion PTL considers that the issues faced by the Northern Irish power generators are vitally important, and should be addressed with urgency by the industry, in the context of the i-sem as recommended in the conclusion of the Exit Review. PTL fully recognises the important contribution of the power station load to the NI gas market and that the long term sustainability of this sector is critical to the long term sustainability of both the gas and electricity markets but considers that many of the issues raised in the proposal are seeking to treat the symptoms of the issues identified by the generators rather than the outright causes (which appear to be how power stations are remunerated for operating costs in the wholesale electricity market). To summarise: The proposal is complex to assess, develop and implement because it must be done based on a detailed assessment of the physical capability of the network, otherwise it would introduce unacceptable operational risk and the potential for unintended consequences; Consequently, should the Utility Regulator direct it, any development of the proposal would require extended timescales as set out in section E above and should be considered after the CJV go live ; The proposal brings into question how the technical capacities of new points should be defined as well as the definitions of technical capacity for existing points; In PTL s view, the proposal does not support the Relevant Objective of the NI TSO s Gas Transporter Licences; and Any attempt to address the valid concerns of the Generators should follow the route concluded upon by the Utility Regulator and focus on the development of the i-sem. PTL Initial Modification Report No th September
9 Appendix 1: AESs Proposed Modification PROPOSED MODIFICATION TO THE PTL TRANSPORTATION CODE Modification Number: 39 Modification Title: Modification Proposer: Transfer of Exit Capacity between Northern Ireland Exit Points to permit Secondary Trading of Exit Capacity AES Ballylumford Limited Modification Representative: Donald Murray Phone Number: Address: Date Submitted to PTL: 26 August 2016 Proposed Implementation Date: 1 October 2016 Description of the nature and purpose of the modification: The purpose of this Modification Proposal is to permit the Secondary Transfer of Exit Capacity on a daily basis between Exit Points on the Northern Ireland gas transmission system (to include the PTL SNIP, BGTL transmission system, GNI (UK) transmission system and the Gas to the West transmission system). How the modification better facilitates the relevant objective: The implementation of this modification could provide a benefit to Gas Generators in allowing them to recover some legitimately incurred costs that currently cannot be recovered. This also reduces future financial uncertainties. Benefits the security of supply in Northern Ireland by helping to remunerate the increasing costs of existing gas fired generating plants due to their increasingly intermittent operation as a result of ongoing renewable penetration. This make the long term viability of these plants more predictable and hence more stable. Provides for improved investment signals for future gas fired generation in Northern Ireland. To meet the requirements associated with intermittent renewable generation, gas fired generation is currently the only viable option. Potential investors will want to see a regime whereby incurred costs associated with requirement to hold fixed Annual Exit Capacity can be recovered from the Market. Allows the most efficient use possible of existing gas assets and puts in place the conditions for a functioning secondary market to trade exit capacity. PTL Initial Modification Report No th September
10 The clauses of the Transportation Code that require amendment: Premier Transmission Limited Transportation Code (V6.5) 8 th July 2015 Section 1B Exit Capacity Clause 1B.9.6 delete clause Clause 1B.9.3(a) modified to allow for transfer for one complete (gas) day. Will also need to consider additional clause(s) to permit transfer between NI Transporters systems (i.e. PTL / BGTL / GNI (UK) and GTW). PTL Initial Modification Report No th September
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