All RR TSOs' consultation on amended RRIF

Overview

The TSOs performing the reserve replacement process ('RR TSOs') are launching a public consultation from 21 September to 21 October 2020 on their proposal for an amendment of the implementation framework for a European platform for the exchange of balancing energy from replacement reserves ('RRIF'). The RR TSOs seek stakeholders' views on the proposed amendment to the RRIF and, more generally, on the RR process.

The RR TSOs propose the following changes:

• Designation entity – Art.10: Amendment to enable all RR-Platform TSOs to be regarded as operators of the platform.
• Counter-activations – Art.13(5): Postponement of the date set for the minimisation of the counter-activations.
• Interconnection controllability – Art. 3(b) & 11(3): The activation and settlement of bids for satisfying the controllability of interconnection will be compliant with the latest versions of the pricing methodology and the TSO-TSO settlement methodology as approved by ACER and published in January and July 2020.

The consultation includes the RR TSOs' proposal for an amended RRIF, including the designation letter (annex to the RRIF).  

Why We Are Consulting

RRIF proposed amendments

Interconnector controllability - Art. 3(b):

• Original: The RR TSOs will be allowed to submit a desired flow range for specific interconnectors, which will be respected, if possible by the optimization algorithm. The RR TSOs submitting a desired flow range will cover the costs of enforcing such a flow.
• Proposed amendment: The RR TSOs will be allowed to submit a desired flow range for specific interconnectors, which will be respected, if possible, by the optimization algorithm. The RR TSOs submitting a desired flow range will cover the costs of enforcing such a flow. In accordance with the approved methodologies pursuant to Article 30(1) and Article 50(1) of the EBGL, these principles will be applied until 1 July 2022.

Interconnector controllability - Art. 11(3)

• Original: Controllability of interconnection: According to Article 3(2)(d) of the EBGL, the RR TSOs will be allowed to submit a desired flow to RR-Platform for a specific interconnection. The activation of bids for satisfying the controllability of interconnection is an activation of bids for purposes other than balancing and should be settled according to Article 30 of the EBGL. 
• Proposed amendment: Controllability of interconnection: According to Article 3(2)(d) of the EBGL, the RR TSOs will be allowed to submit a desired flow to RR-Platform for a specific interconnection. The activation of bids for satisfying the controllability of interconnection is an activation of bids for purposes other than balancing and should be settled according to Article 30 of the EBGL. In accordance with the approved methodology pursuant to Article 30(1) of the EBGL, from 1 July 2022, the process for settlement of all activated bids will be aligned with the process set out in that methodology. 

Rules for governance and operation of entity operating the platform and proposed appointed entity - Art. 10

• Original: (1) Appointed Entity: RR TSOs shall appoint one entity which is composed by one or more TSOs or one or more companies owned by TSOs for operating:
  (a) The AOF defined in Article 5 of this RRIF in accordance with Article 19(4) of EBGL. 
  (b) the Cross-zonal capacity function defined in Article 5 of this RRIF in accordance with Article 19(4) of EBGL. 
  (c) the TSO-TSO settlement function defined in Article 5 of this RRIF in accordance with Article 19(4) of EBGL. 
  (2) Governance rules: 
  (a) The rules concerning the governance of the Implementation project and RR-Platform shall ensure that no RR TSO benefits from unjustified economic advantages through the participation to the Implementation project and/or RR-Platform. Each RR TSO whether it is a Member or an Observer has a representative in the Steering Committee and (expert) groups.
  (b) Each RR TSO shall carry out the common governance principles of the Implementation project and RR-Platform by means of the Steering Committee of the Implementation project and the RR-Platform, which is the decision-making body of the Implementation project and the RR-Platform with the right to take any binding decision on any matter or question related to the governance and operation of the Implementation project and the RR-Platform. The Steering Committee will notably:
  i. Provide guidance and binding decisions on the Implementation project and/or RR-Platform;
  ii. Inform ENTSO-E;
  iii. Inform NRAs;
  iv. Validate analysis and outputs from the expert groups.
  v. Ensure stakeholders' involvement. 
  vi.  Assess the well-functioning of the market and make sure that harmonization is enhanced when necessary.
  (3) Decision making: an effective coordination and decision-making process to resolve any conflicting positions within the Implementation project or the RR-Platform will be set up based on the following rules:
  (a) In accordance with Article 4(4) of the EBGL, if the regions concerned are composed of more than five RR Countries and no consensus is reached among Members deciding on proposals for terms and conditions or methodologies in accordance with Article 5(3) of the EBGL, they shall decide by qualified majority. Since the Implementation project and/or RR-Platform is composed of more than five RR Countries, decision shall require majority of: 
  i. Members representing at least 72% of the RR Countries concerned; and 
  ii. Members representing RR countries comprising at least 65% of the population of the concerned region. 
  (b) A blocking minority for decisions in accordance with Article 5(3) of the EBGL must include at least a minimum number of Members representing more than 35% of the population of the participating RR countries, plus Members representing at least one additional RR Country concerned, failing of which the qualified majority shall be deemed attained.
  (4) Operation rules:
  (a) The operation rules will be agreed between the RR TSOs as introduced in Article 10(1) of this RRIF.
  (b) These operation rules will be compliant with the RRIF and will elaborate on technical details on how:
  i. the RR TSOs, that will have at least one interconnected neighbouring RR TSO, will use the RR-Platform;
  ii. the local systems will be connected to the RR-Platform. The RR TSOs will also outline operational aspects such as exception handling, fall-back measures; and
  iii. to raise and escalate incidents.
• Proposed amendment: 'RR TSOs shall appoint the entities that operate the RR Platform as further described in the designation letter in the annex. 

Rules for governance and operation of entity operating the platform and proposed appointed entity - Annex

• Original: N/A
• Proposed amendment: Annex - Designation letter pursuant to Article 19(3) of the EBGL

Daily clearings - Art. 11(5)(a)

• Original: At the go-live of the RR-Platform, the number of daily gates will be 24. The RR TSOs will reduce the cross-border scheduling steps to less than 60 minutes for the borders included in the Region. The deadline will be the date required by the EBGL for using the European Platform for exchange of mFRR and the date required by the CACM regulation for the intraday cross zonal gate closure frequency definition.
• Proposed amendment: At the go-live of the RR-Platform, the number of daily gates will be 24. The RR TSOs will reduce the cross-border scheduling steps to less than 60 minutes for the borders included in the Region. The deadline will be the date required by the EBGL for using the European Platform for exchange of mFRR which is still subject for possible derogation and the date required by the CACM regulation for the intraday cross zonal gate closure frequency definition.

Counter-activations - Art. 13(5)

• Original: For the go-live of the RR-Platform the AOF will allow the counter activations. No later than twelve months after the go-live of the RR-platform, the AOF will minimise the counter activations which at least may not serve the balancing purpose. All the RR TSOs may request an amendment from this requirement to all RR NRAs as allowed by Article 6(3) of the EBGL. This request shall be duly justified and supported by an analysis performed by the RR TSOs.
• Proposed amendment: For the go-live of the RR-Platform the AOF will allow the counter activations. No later than twenty-four months after the go-live of the RR-platform, the AOF will minimise the counter activations which at least may not serve the balancing purpose. All the RR TSOs may request an amendment from this requirement to all RR NRAs as allowed by Article 6(3) of the EBGL. This request shall be duly justified and supported by an analysis performed by the RR TSOs.