Open Networks Project 2018 Work Plan Consultation innogy renewables UK response

Transcription

1 Farina Farrier Energy Networks Association 6th Floor, Dean Bradley House 52 Horseferry Road London SW1P 2AF Fruzsina Kemenes Policy Manager innogy renewablesuk ltd. Submitted electronically to 23 rd February 2018 Open Networks Project 2018 Work Plan Consultation innogy renewables UK response Dear Farina, Innogy renewables UK welcomes the opportunity to respond to your consultation on the Open Networks Project 2018 plan. Please find our response to your specific questions below. We have an overarching concern with the proposals of the ONP for 2018 to flag upfront. We will seek your response to this in your finalised plan publication. This document states that: in developing work stream x products, the work starts from the position that functionality is delivered through existing DNO organisations. This runs counter to stakeholder feedback (ourselves included) on last year s consultation into potential commercial principles and the 6 market models - which showed a clear preference for either model 3 - NETSO coordinates or model 5 joint procurement / dispatch. We are very disappointed that the ONP has ignored this feedback and request that it reshapes the work plan to consider Model 3 and 5 as the assumed starting point for this phase of activities. If you have any questions please contact me, Kind Regards, Fruzsina Policy Manager Innogy Renewables UK Limited Innogy Renewables UK Limited Windmill Hill Business Park Whitehill Way Swindon Wiltshire SN5 6PB Registered Office Innogy Renewables UK Limited Windmill Hill Business Park Whitehill Way Swindon Wiltshire SN5 6PB Registered in England and Wales no

2 Q1. Which specific areas of 2018 work or Products are most important to you and why? Due to the radical change that the ONP project aims for a carefully designed set of steps all need to progress concurrently. It seems bizarre to rank these- they should all be necessary steps to the DSO world (be they small or big ticket products ). As an observation, many of the products in WS2 are things that should be happening regardless of the ONP. Good practice guides and agreement on terminology regarding connections are expected (arguably should already be available) but are not specifically fundamental to the ONP project itself. As a distributed renewables and storage business we will most directly benefit from: Distributed Services Procurement - for clarity is this being delivered by SNAPs amongst other activities? What is the unique commitment on this front from the ONP Regional Service Requirements Operational Data & Control Architectures - This is fundamental for enabling services procurement/ other products Management of Capacity ~ network businesses should not overstate the need for reinforcement (and create costs for network users) because of underutilised capacity. However for stakeholders to understand this issue please can the ONP response to this consultation set out what is the cost impact of this unused capacity currently? 2.2b Additional linked Product: System user profiling in network design. E.g. do DNOs profile wind and solar connectees in terms of system use- reinforcement needs etc. when planning reinforcements? There should be studies to inform their thinking to best maximise existing capacity on networks. The ONP and Access Task Force must ensure that action to make this a reality is taken by one of them Provision of Constraint Information this is a fundamental ground stone for any unfirm connection offers. A priority to address as it should already be the norm that boundaries and scope of constraints are set out at the point of contract between any network company and the user Independent Review of DSO Models including CBA given that network companies have a vested interest in the model it is essential that an independent third party conducts this review. In addition to reviewing the models set by the ENA the consultants should be given freedom to suggest one improved alternative model should this exist. We agree with EnergyUK and others that that the assumption across all Workstreams that functionality is developed through existing DNO organisations is one which may distort the outcomes of the project and an unbiased review of potential future DSO models. The suggestion above would overcome this issue DSO function trials we welcome ongoing trials but caveat that trials must not lock in a particular DSO model. Learnings from trials should feed into the wider review of models. 2

3 Q2. Are there any other areas of work or Products you would like to see included in the Open Networks Phase 2 workplan and if yes, why and how should they be prioritised compared with other work? 2.2b Additional linked Product: System user profiling in network design. E.g. do DNOs profile wind and solar connectees in terms of system use- reinforcement needs etc. when planning reinforcements? There should be studies to inform their thinking to best maximise existing capacity on networks. The ONP and Access Task Force must ensure that action to make this a reality is taken by one of them. 2.9 Add coordinated outage planning as a further desirable product for Coordinate between network companies so as to minimise impact (outage duration) for connected parties. 3.2 Product under this original entry should be a publication to explain findings to stakeholders. An important aspect of the DSO models is understanding how such regional operation will be funded for each model. This needs to be researched and explained at this early stage of sifting through DSO model options. 3.7 As an additional linked Product there needs to be a clear framework on assessing the outcomes of trials-asap. We are not clear on what happens once a trial is complete. Can projects just run on indefinitely? Who does the IPR on the trials belong to? While the trials are a key step that is welcome they should not lock the system into a DSO model without the wider assessment of DSO models endorsing this path. Q3. Should any areas of work or Products be removed or deferred and if yes, why? No some of these Products have been worked on by the DER-DNO Steering committee for a number of months/ years. Yet their timelines for delivery are still towards Q4.. its not clear why the delay. Q4. Do you agree with the proposed Products for wider consultation and what other work should be consulted on and why? See comment boxes. Q5. Have you any feedback on the proposed timescales for delivery and consultation through Phase 2? The timescales appear reasonably spaced for ONP consultations. We do however request that BEIS, Ofgem the SO and the Open Networks project coordinate their individual consultations amongst themselves there is no particular period of the year that becomes overburdened with consultations. We are concerned about the capacity to input into all relevant consultations given the Charging and Access Reviews and the high number of industry modification proposals being processed under Open Governance. Q6. How would you like to provide input to the Open Networks Project and be kept informed of developments? The first year of the ONP was not well communicated. We can see and welcome that there is a recognition that communication to stakeholders needs to be a key commitment for The webinar was a good method of communicating- including the open Q&A enabled two way discussion. There could also be open workshops ahead of consultations to refine the ideas that the network companies propose via the ONP consultations. We encourage ONP speakers to attend and provide input into trade association 3

4 meetings (each trade association now has a flexibility related working group). Consultations are a useful way to input with time to think about the feedback. Ofgem should notify industry when these consultations occur- although they are third party led (ENA) these consultations are of wide energy sector interest and stakeholder capture is in the interest of the regulator. The ONP is of national interest and as Ofgem will be developing the regulatory framework for DSOs this type of promotion makes sense. Feedback on additional Planned Products for 2018 : Where these comments are for the attention of Ofgem-please can you pass these points on. 1) T-D Processes WS1 Products Description Timescale 1 Investment Processes 2 Distributed Services Procurement 3 Industry Framework Interactions 4 Reliability Standards & Emergency Requirements Enable a whole system approach utilising a range of investment and operability options across T&D. Extended Networks Options Assessment (NOA) process for transmission network reinforcement to include distribution sourced options. Framework for providing contract visibility, conflict resolution and service optimisation across T&D networks. Consider the operational exchanges to schedule and despatch services. Ensure that Open Networks outputs are reflected into code & framework development including European Network Code adoption and BSC modifications. Ensure that emerging Whole System investment & operational processes maintain security of supply across T&D and cover requirements under emergency conditions. Establish a whole system approach to Future Energy Scenarios. Define and publish regional service requirements and constraint heat maps. 1.1 Support this, and assume that the extended NOA would consider non-build solutions based on procurement of DER solutions. Please confirm this. 1.3 As an underlying principle we support alignment with EU codes and networks policy. 5 Whole System FES This is important as the FES is used as an input into numerous policies. 6 Regional Service This is essential the service requirements of the Requirements networks need to be analysed and communicated before the launch of system service solutions. The outlook on system needs should be 5 years minimum and ideally 15 years (with an indication of uncertainties the further out the projections go). 7 ANM Information Establish processes to capture ANM system status and performance for investment planning purposes. 8 System Wide Review the feasibility of putting in 1.8 We expect this to be a relatively quick win 4

5 Resource Register place a system-wide resource register for GB generation, storage and flexible demand (T&D). 9 TSO-DSO Transmission Impacts 10 Current Practice for Flexible Resources Complete work to replace Statement of Works and embed updated TSO-DSO processes across GB. Review current DNO approaches to flexibility queue management and publish a document to stakeholders to clarify DNO practice at present on handling flexibility in connection queues. given the TEC register and because most DNOs already publish generation connection status registers. The register needs to be updated with a set regularity and maintained on an ongoing basis by all network companies. It needs to be promoted and easily accessible & 1.11 Unclear if there is a difference between 10 and Facilitating Connections Action Plan and Report 12 TSO/DSO & DER Data Requirements 13 Operational Data & Control Architectures Develop gap analysis and action plan for flexible resources in connection queues (including storage as per action 1.6 from the Smart Systems and Flexibility Plan) and publish to stakeholders. In light of DSO-TSO changes (Statement of works), consider revisions to existing data exchange processes. Also, update the data requirements to be provided from DER customers when they apply for a connection and after they agree a connection from the DNO. Further develop the architectures and mechanisms for operational data exchange. This will support other products. 2) T-D Customer Experience WS2 Products 1 Good Practice ahead of Connection Applications 2 Management of Capacity Description Review network operator approaches for handling prospective connection applications and publish good practice paper for supporting customers pre-application. Identify and review options for managing and planning capacity that may be contracted for but may not be being used by customers. Capacity clawback position paper will be provided to Ofgem & BEIS. 2.2 Additional linked Product: System user profiling in network design. E.g. do DNOs profile wind and solar connectees in terms of system usereinforcement needs etc. when planning reinforcements? There should be studies to inform their thinking to best maximise existing capacity on networks. The ONP and Access Task Force must ensure that action to make this a reality is taken by one of them. 5

6 3 Explanation of Terms & Definitions 4 Information on Flexibility Services 5 Good Practice Following Connection Applications 6 Guidance on Post Connection Changes 7 Provision of Constraint Information Produce a document that explains commonly used terms such as 'firm and unfirm'. This would be published and used by network operators going forward to provide greater clarity for customers. Review how information should be provided to customers on potential DNO requirements for flexibility services. Review approaches for handling customer connections in the postapplication phase and agree good practice around areas including connection queue management. Provide guidance to customers on the impacts of changes to DER operational regimes. Notice on when and how distribution energy project ops set up changes should be notified to DNOs. Review what information on constraints and curtailment would be useful to customers, what can be provided and establish good practice for network operators. We will respond to the consultation, please see our full response for detailed feedback. We have concerns about allowing storage to queue jump for example, even where storage can only queue jump where it has been demonstrated that it would alleviate network constraints it would need to be very clear in the connection offer how long the storage has been contracted to undertake this service. The behaviour of storage cannot be predicted with great certainty unless it is contracted behaviour. Very supportive of this. 2.7 The deliverable should be a commitment from network companies to provide more transparent info on curtailment and constraints by Q (Product otherwise insufficient). 2.9 Add coordinated outage planning as a further desirable product for Coordinate between network companies so as to minimise impact (outage duration) for connected parties Product Updates Review the changes to connection arrangements agreed through WS1 s 2017 Product 6 and update WS products (including journey maps) if required. 3) DNO to DSO Transition, WS3 Products Description Timescale 1 SGAM Modelling of DSOs and DER Procurement Future DSO Model: Smart Grid Architecture Model SGAM modelling to fully describe and scope the models for DER services procurement. This Analysis (Started in Phase 1). 3.1 Product should be a write-up of the model outputs so that stakeholders understand options. 6

7 2 Further SGAM Modelling of DSO Functionality 3 Market Agnostic DSO Elements 4 Independent Review of DSO Models including CBA 5 DSO Model Validation & Review 6 Key Enablers for DSO 7 Further Trials to Address Gaps in DSO Functionality 8 Preferred DSO Models & Proposed Implementation Plan Further modelling to address stakeholder feedback on Commercial Principles and to cover further areas of DSO functionality. Complete Assessment of Market Agnostic elements of DSO functionality such that no regrets DSO implementation actions can be brought forward. Independent assessment of the transition to different DSO models. As well as cost benefit analysis (CBA), this should include dimensions such as UK/EU regulatory compliance, sustainability, customer satisfaction, complexity, Smart Network indicators and impacts on vulnerable consumers. The assessment is intended to compare models and underpin regulatory impact assessments. Detailed review of SGAM outputs to ensure these provide a sound basis for DSO direction setting and implementation. Public consultation on market models and next steps. Identify and document key enablers to implement DSO functionality (e.g. IT systems, comm s infrastructure, organisational changes, contract requirements, regulatory changes, funding). These would support comparisons and feed into the implementation plan. Identify and initiate further trials to address any gaps. This will look to utilise ongoing projects including those approved as part of the 2017 NIC competition that will be aligned through the ON project - Fusion, Electricity Flexibility and Forecasting System and Transition. If necessary, further projects would also be considered. Draw on earlier work to determine elements of DSO Models that have been agreed by NO s & Stakeholders and develop and propose an Implementation Plan..2 Product should be a publication to explain findings to stakeholders. An important aspect of the DSO models is understanding how such regional operation will be funded for each model. This needs to be researched and explained at this early stage of sifting through DSO model options. 3.4 The independent assessment of DSO models needs to assess these models in the context of the whole system- specifically assessing the interaction with whole system operation is important. 3.4 This regulatory impact assessment of the DSO model report needs to be factored in to Ofgem s own 2018 work plan. 3.6 Cross network (i.e. DSO to TSO and DSO to DSO and DSO to DNO communications, IT etc. should all be investigated. 3.7 As an additional linked Product there needs to be a clear framework on assessing the outcomes of trials-asap. We are not clear on what happens once a trial is complete. Can projects just run on indefinitely? Who does the IPR on the trials belong to? While the trials are a key step that is welcome they should not lock the system into a DSO model without the wider assessment of DSO models endorsing this path. Ofgem must review the models and respond to the Independent review before further work is done to propose an implementation plan. 7