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Proposal for the bidding & activation
process and balancing energy products for
the bid ladder platform
1. Introduction to this document
The goal of the bid ladder project is to set up a platform where Market Players can bid in all available
flexibility.
In contrast to the current CIPU-process the new platform should:

Allow bids from flexibility not covered by a CIPU-contract;

Allow bids from load and RES flexibility;

Allow bids from flexibility connected to the distribution grid.
Therefore the new bidding process & platform should:

Be a simple process with low entry barriers;

Break the link between the offered bids and production schedules sent by BRPs (cfr. CIPU);

Anticipate the upcoming evolutions of the future European Network Codes.
This document is describing the design of the bid ladder platform regarding:

Product definition;

Bidding process;

Congestion management process;

Activation & settlement process;

Pre qualification TSO/monitoring products;
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2. Table of content
Contents
1.
Introduction to this document.......................................................................................................... 1
2.
Table of content ................................................................................................................................ 2
3.
Context of the bid ladder platform ................................................................................................... 3
Products which can be offered on the bid ladder platform ................................................................. 3
Belgian Balancing market: context ....................................................................................................... 4
European Balancing market: context.................................................................................................... 6
Balancing platform & competition........................................................................................................ 9
4.
Current bidding process and balancing energy products ............................................................... 10
Introduction ........................................................................................................................................ 10
Overall Bidding Process....................................................................................................................... 10
Characteristics of intraday & day ahead nominations ........................................................................ 11
Bidding Volumes & Prices ................................................................................................................... 11
Using regulation capacity – activation of free balancing bids ............................................................ 12
5.
Survey – Assessment of proposal ................................................................................................... 14
Main characteristics of the initial product proposal ........................................................................... 14
Survey organization ............................................................................................................................ 14
List of questions and summary of answers......................................................................................... 15
6.
Proposal for the design of the new bid ladder platform ................................................................ 19
Balancing Energy Products .................................................................................................................. 19
Bid characteristics ............................................................................................................................... 23
Process for the bid ladder platform .................................................................................................... 27
7.
Appendix – Exhaustive answers from all Market Players ............................................................... 35
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3. Context of the bid ladder platform
Products which can be offered on the bid ladder platform
To maintain the balance between generation and consumption in the Belgian control area Elia uses 3
different kind of Ancillary services:



Primary reserves (R1) or Frequency Containment Reserves
Secondary Reserves (R2) or automatic Frequency Restoration Reserves
Tertiary Reserves (R3) or manual Frequency Restoration Reserves
For more information regarding these products please consult the product sheets
http://www.elia.be/en/products-and-services/product-sheets
The manual reserve (R3) enables Elia to cope with a significant or systematic imbalance in the control
area and/or resolve major congestion problems. Unlike the primary and secondary reserves, the tertiary
reserve is activated manually at Elia's request.
There are 2 types of manual reserves:


Pre-contracted reserves or ancillary services; these reserves receive a capacity payment to
compensate them not to participate to the long term, day ahead and intraday electricity
markets. This flexibility is exclusively used by Elia;
Non-contracted reserves or bids; as these reserves don’t receive a capacity fee only the residual
remaining flexibility (after market participation in previous market time frames) will be offered
to the balancing market.
Contracted
Reserves
s
Non Contracted Reserves/Bids
In a first stage the bid ladder platform will only deal with the non-contracted reserves. On
the long run possibly also the bids from pre-contracted reserves shall be offered on the bid
ladder platform.
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Belgian Balancing market: context
In continental Europe there exist several ways how the balancing management is performed by TSOs.
Apart from central dispatch systems we make a distinction between 2 different methodologies;

Pro-active balancing markets; in this market design the TSOs are taking over the balancing
responsibility from the market in an early stage (e.g. 1 hour before delivery time). TSOs are
performing imbalance forecasts and try to anticipate on important imbalances by activating
slow balancing energy products (Replacement Reserves).

Re-active balancing markets; in these kind of markets TSOs incentivize market players to restore
the balance of their perimeter even in real-time. Therefore balancing actions by TSOs consist in
activation of fast reserves with short activation durations. Consequently replacement reserves
are rarely used by TSOs in re-active balancing markets.
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Similar to the Netherlands Elia opted for a re-active market design for the development of the balancing
market as Elia believes this is the most efficient solution. In their final report of the Electricity Balancing
impact assessment study the European Commission acknowledges that re-active market design is the
most efficient solution.1
The balancing actions of a TSO in a re-active balancing market consist of fast reserves with
short activation durations.
1
“Impact Assessment on European Electricity balancing Market”; Final report March 2013; Conclusions 2 & 4 on
page 115
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European Balancing market: context
To date, the arrangements for the procurement and remuneration of balancing services have been
mainly governed by national legislation and regulation. Conversely, the role of European rules has been
largely limited to technical conditions on the definition and provision of system and ancillary services,
such as those stipulated in the UCTE Operation Handbook. This situation will change in the future.
Indeed, the third energy package has introduced the concept of so-called Framework Guidelines (FG)
and Network Codes (NC), which have to be developed by ACER and ENTSO-E, respectively. Whilst the
Framework Guidelines establish a set of general principles, which the Network Codes shall comply with,
the Network Codes themselves will create a comprehensive set of binding rules.
In total, ENTSO-E plans to develop a set of nine different network codes, which are basically matching a
set of corresponding Framework Guidelines. Some of these documents will also impact the balancing
process as well as the procurement and use of operational reserves, such as the Network Code on LoadFrequency Control and Reserves, the Network Code on Operational Security, or the Network Code on
Operational Planning and Scheduling. For the scope of this bid ladder platform, the Framework
Guidelines on Electricity Balancing (FG Electricity Balancing) and the associated Network Code (NC
Electricity Balancing) are of primary importance.
LFC Code
The recently developed Network Code for Load Frequency Control & Reserves2 (compare chapter 5.2)
has introduced a set of harmonised control processes for load-frequency control for the entire EU. The
NC differentiates between three processes, which are each supported by a dedicated set of operational
reserves. The main purpose of the three different processes and the corresponding reserves are as
follows:

Frequency Containment Reserves (FCR) comprises of operational reserves which are activated to
contain system frequency after an incident inside a pre-defined band. FCR are based on the
automated, decentralised response of the governor controls on individual generators with a full
activation time of 10-30 seconds.

Frequency Restoration Reserves (FRR) are operational reserves used to restore system
frequency to its nominal value and, where applicable, the power balance to the scheduled value.
This process involve of manually-instructed services (manual FRR) as well as automatically-
2
ENTSO-E. Draft Network Code for Load Frequency Control & Reserves. Working Draft. Draft V2. Brussels.
23.01.2013
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instructed services (automatic FRR). The latter are based on the centralised control of particular
generating units (or loads).

Replacement Reserves (RR) replace the activated restoration reserves in order to restore the
available reserves in the system
This definition of frequency control processes and reserves is limited to the first hour after an incident,
whereas it is assumed that market participants will be responsible for balancing possible deviations
themselves through the intra-day market thereafter.
The bid ladder platform is focusing on reserves which belonging to the category of Frequency
Restoration.
Framework Guidelines on Electricity Balancing
The FG Electricity Balancing was developed by ACER in 2011/2012, and a final version was approved by
ACER on 18 September 2012.3 Subsequently, the European Commission formally invited ENTSO-E start
developing the Network Code on Electricity Balancing on 21 December 2012. A first draft of the NC
Electricity Balancing was published by ENTSO-E on 20 February 2013, and the final document has to be
submitted to the Commission in December 2013.
The FG Electricity Balancing principally focus on three main areas, i.e.:

Activation and cross-border exchange of balancing energy,

Procurement and cross-border exchange of contracted reserves,

Imbalance settlement.
In general, the FG Electricity Balancing specify that the TSOs establish an European wide integrated
cross-border balancing market where TSOs balance the system in a coordinated way in order to use the
most efficient balancing resources taking into account cross-border transmission capacities. Besides
promoting cross-border exchange of balancing services, the rules of the NC Electricity Balancing shall
also facilitate the wider participation of demand response and renewable sources of energy.
The TSOs shall be responsible for procuring balancing services from balancing service providers (BSPs)
which are responsible to meet the terms and conditions adopted by the TSO.
In addition, the FG Electricity Balancing also establishes some other requirements, which generally apply
to the procurement and use of balancing services. Among others, the FG Electricity Balancing call for the
3
ACER. Framework Guidelines on Electricity Balancing. FG-2012-E-009. 18 September 2012
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use of standardised balancing products, although TSOs may still use specific local products if standard
products prove to be insufficient.
The stipulations of the Framework Guidelines on balancing and the required developments as a
consequence of the future network code on Electricity Balancing shall directly affect the design of the
bid ladder as this platform shall be the gateway to exchange manual activate reserves with other
countries. Indeed on the long run the bid ladder platform need to communicate with other platforms in
order to share balancing bids, create European Common Merit order lists and guarantee the use of the
most efficient balancing resources.
Because the bid ladder platform shall be used to exchange manual reserves we need to consider that
the product design and processes – as proposed in this document - might be modified in order to stay
compliant with the European standards. Hence the platform should be developed in such a way that the
characteristics of the balancing products can be easily changed in order to respect the future definition
of European Standard Balancing Products. Moreover in order to facilitate the cross-border exchange of
balancing energy it might be required that also bidding and activation processes need to be harmonised
with other countries.
The upcoming years – due to cross-border harmonisation – the bid and activation rules of the bid ladder
platform will be modified in order to stay compliant with the European standards. Hence the platform
will be developed in such a way that it will be possible to perform the required modifications in a flexible
way.
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Balancing platform & competition
The economic theory states that the following assumptions are important when developing a
competitive market
Assumptions behind a Perfectly Competitive Market
1. Many suppliers each with an insignificant share of the market – this means that each firm is too small relative to the overall
market to affect price via a change in its own supply – each individual firm is assumed to be a price taker;
2. An identical output produced by each firm – in other words, the market supplies homogeneous or standardised products that
are perfect substitutes for each other. Consumers perceive the products to be identical;
3. Consumers have perfect information about the prices charged by sellers in the market– so if some firms decide to charge a
price higher than the ruling market price, there will be a large substitution effect away from this firm;
4. All firms (industry participants and new entrants) are assumed to have equal access to resources (technology, other factor
inputs) and improvements in production technologies achieved by one firm can spill-over to all the other suppliers in the
market;
5. There are assumed to be no barriers to entry & exit of firms in long run – which means that the market is open to
competition from new suppliers – this affects the long run profits made by each firm in the industry. The long run equilibrium
for a perfectly competitive market occurs when the marginal firm makes normal profit only in the long term;
6. No externalities in production and consumption so that there is no divergence between private and social costs and benefits;
Source; http://www.tutor2u.net/economics/content/topics/competition/competition.htm
Characteristics which should be considered when developing the bid ladder platform are:



Develop a platform where standardised products are offered by Providers. This enables Elia to
compare identical products and activate the most cost-efficient solution.
All offered bids should be published in a transparent way in order to allow Providers to evaluate
the position of their bids on the merit order list relative to bids from other Providers.
The process to offer flexibility to the bid ladder platform should be easy with a low entry barrier.
Likely a B2B and B2C interface needs to be developed.
The bid ladder platform should allow Providers to offer their flexibility by submitting standard
products to a platform which can easily be accessed. Elia will publish in a transparent way the
available balancing bids and the use of it.
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4. Current bidding process and balancing energy products
Introduction
Currently the volume & price of the non-contracted tertiary reserves (free balancing bids) are
communicated to Elia through the contractual & operational framework of CIPU4, which includes
flexible volumes on mainly the traditional large (spinning) power generation units (>25MW). Only ARP’s
responsible for injection are able to sign a CIPU-contract & offer non-contracted reserves (balancing
bids) on all power plants incorporated in this contract5. A power plant is mandatory to be included in
such a CIPU-contract if one of the following conditions is fulfilled:

If the nominal power of a power plant is larger or equal to 25MVA;

If the power plant is directly connected to the TSO-grid;

If the power plant is connected to the DSO-grid & has a significant impact on the TSO-grid;

If the power plant wishes to deliver ancillary services for contracted reserves.
The objective of the CIPU contract is threefold and describes the information exchanges & means in
order to allow:

Network planification (maintenance & outages management);

Congestion management (preventing & avoiding congestions from Y-1 up until real-time;
calculation of cross-border capacities);

Balancing management (assuring the real-time balance in D of the Belgian control area with
balancing bids (free prices); calculation of contracted reserves);
Overall Bidding Process



4
Current prequalification consist of the signature of the CIPU contract.
In day ahead before 14pm the ARP must nominate for each CIPU power unit for every quarter
hour of day D the required data in the day-ahead nomination files for Elia to determine the
maximum upward and/or downward volume that can be activated per quarter hour and the
corresponding price for usage in real-time (day D).
From day ahead 18pm & during intraday the day-ahead nominations can be updated per power
plant up until 1 hour prior to delivery during the intraday/exploitation procedure through
IDPCR6
CIPU = ‘Coordination of Injection of Power Units’
Since 2012 it is possible to offer non-contracted reserves provided by smaller units by means of an Aggregated
PowerPlant (APP)
6
IDPCR = Intraday Production Change Request. This nomination replaces the day-ahead nomination (if existing)
and will serve as the new basis for imbalance tariff calculation if the IDPCR is accepted by Elia
5
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

Elia activates free balancing bids based on a techno-economical ranking as explained in the
balancing rules published on the Elia website (http://www.elia.be/en/products-andservices/balance/balancing-mechanism).
Remuneration of the activated energy is based on the nominated prices (pay-as-bid).
Characteristics of intraday & day ahead nominations












Pnominated [MW] for each quarter hour
Pmax_available [MW] for each quarter hour
Pmin_available [MW] for each quarter hour
Upward ramping rate [MW/min] for each quarter hour
Downward ramping rate [MW/min] for each quarter hour
Incremental bid (I-bid) prices [€/MWh] & Decremental bid (D-bid) prices [€/MWh] for each
quarter hour
Separate startup-price [€] & startup-fuel type for the delivery day (not reflected in I-bid prices)
Average Power Plant efficiency as specific fuel consumption (sfc) in [GJ_th/MWh_el] for the
delivery day
Fuel type for the delivery day (in D-1) or for each quarter hour (D) through configurations
Power plant unit type
Electrical zone (locational information)
EAN-code, indicating the TSO-grid access point as well as the specific power unit
Bidding Volumes & Prices

Bidding volumes are derived in an implicit way for each quarter hour & for each power plant by
Elia based on the production schedules (Pnom) and available maximum power (Pmax_available)
and minimum power (Pmin_available). The latter is illustrated in the following figure, in which
all input data was communicated by the ARPs.

All determined volumes are considered divisible.

Because the available margin is determined by Elia based on ex-ante nominations and technical
characteristics it might be possible to have differences between the calculated margin and real
physical available margin. Therefore firmness of these implicit offered balancing bids cannot be
guaranteed by the providers.
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
Bidding prices are sent per power unit in D-1 and per power plant in D by the provider and may
be updated until 1 hour prior to delivery time.
Using regulation capacity – activation of free balancing bids

All I-bid- and D-bid-volumes are ranked in a techno-economical merit order. When an activation
of these free balancing bids is required, Elia will start with the activation of the cheapest bid for
I-bids or the most expensive in case of D-bids.

The maximum delivery period is one hour, but in practice volumes are only activated on a
quarter-hour basis & prolonged each quarter if necessary.

The speed of the activation is based on the resp. power plant’s contractual ramping rate
[MW/min]:

Instant activation via a common IT-interface (Probid) for XMW per quarter hour (QH) (red
dashed line) & possible prolonging of previous activations per QH.
o In reality the blue curve will be +/- the physical power activated. This blue line will be
determined by the contractual ramping rate or slope of the activation. The energy
delivered, i.e. the surface under the blue curve, will be used in the remuneration and
correction of the ARP’s imbalance perimeter. This concept is called the ‘billable margin’
(BM)
o Remark: this blue curve is not the effective measured power but calculated
contractually for each activation.
Activation remuneration of non-contracted balancing bids

The remuneration for activation is calculated based on the:
o Free activation prices offered for intraday balancing I- and D-bids
o The activated energy, calculated according to the billable margin (BM) concept.
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Activation control & penalties

The effective activation of free balancing bids is not verified through a specific activation
control, availability control nor through direct penalties. The ARP’s imbalance perimeter is
corrected with the billable margin. This means that when the energy is not activated, the ARP
supplying the free balancing bids will be in imbalance and has to pay the marginal imbalance
tariff, which is determined by the most expensive activated means of overall regulation capacity
(contracted & non-contracted). The remaining imbalance might even lead to a situation in which
the TSO activates the next (often more expensive) bid on the merit order.
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5. Survey – Assessment of proposal
In order to involve stakeholders in the design of the bid ladder platform a survey was launched. The
survey consisted of an initial proposal by Elia and a set of questions. After consideration of the feedback
of stakeholders a final design proposal has been developed by Elia.
Main characteristics of the initial product proposal
Elia elaborated a first draft proposal of standard products for which some fundamental characteristics
were submitted to Market Players opinion








Portfolio bidding of 15 minutes or 30 minutes standard products
Bid minimum size of 5MW
Divisible bid or not
Availability period
Bid price
Bid direction (i.e. I / D bid)
Type of flexibility and locational information
Conditional bid or not
Survey organization
Elia enforced the following process towards Market Players:




08/05: Survey sent out
29/05: Update of the survey (additional question regarding pricing mechanism)
04/06: Deadline for answers
Week 17/06: 4 additional answers received
The panel of consulted and answering Market Players is the following...
Type
Description
Consulted Parties
Answers
GU
Grid Users: Consumer & Aggregator
14 including 1 association
5
BRP
Balance Responsible Party & Supplier
7 including 1 association
RES
Renewable (Wind & CHP)
3 including 2 associations
3 including 1
association
1
DSO
Distribution System Operator
4
0
Exchange
Power Exchange
1
1
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List of questions and summary of answers
Question 1:
As explained, the minimum bid size on the bid ladder platform shall be 5MW. Do you agree with this
proposal?
Summary of the received answers
Most of the MP agree with 5MW (including DSM):
 Some request a minimum size at 100kW to reduce entry barriers for new entrants while others
consider a threshold below 5MW as operational difficult;
 Some request that bids offers have 1 decimal after comma.
Elia new
Minimum size at 1MW with every bid in multiples of 0,1MW
proposal
Question 2:

In case of divisible products a TSO activates only a part of the total activated volume

In case of indivisible products a TSO can only activate the full offered amount or nothing
Do you think indivisible products are required? Why?
Summary of the received answers
Market Players confirm the indivisibility is an important parameter to represent the technical and
economic specifications of the appliances or sources. Divisible and indivisible bids could over time
cohabitate to allow the maximum of flexibility
Elia new
No modification
proposal
Question 3:
Flexibility provided by load or production might have a fixed cost each time it is requested. There are
two ways of dealing with these fixed costs:

Allow conditional bids: Providers are allowed for the same unit to send multiple bids in which
the start cost is valuated each time for a different volume of activation. In such a case Elia will
not activate other bids once one of the bids has been activated

Allow to send separate start costs next to an activation price. In such a case Elia need to
perform an optimization in order to put this bid into competition with other bids without fixed
costs.
Elia believes that conditional bids are the most pragmatic solution.
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Do you agree with this?
Summary of the received answers
Conditional bid is also requested to deal with fixed costs through the most pragmatic way.
No several remunerations of fixed cost when an activation of bid is prolonged
Elia new
Non-conditional and conditional bids with prolongation price
proposal
Question 4:
Elia believes that working with standard balancing energy products is the best solution to develop a
balancing market for manual reserves. Do you support this idea?
Summary of the received answers
All of the MP are in favor of Standard products with no additional technical characteristics
But different kind of opinion about activation duration: some MPs state that the focus should be on
15min while others (RES) prefer products with longer duration
Elia new
 1 fast standard product (15’)
proposal
 3 Slow standard products (>15’)
 Emergency products
Question 5:
There are 2 different ways for sending in bids to a platform:


Sending in a bid per quarter-hour; (current system)
Sending in a bid with an availability period (ex. 06:00 -> 10:45) (current proposal)
Do you have a strong preference for one of the solutions?
Summary of the received answers
Question not understood by all MP however based on the correct received answers, Elia concludes that
the platform should offer maximum flexibility for sending bids (96 bids of 15’ or 1 bid of 96x15’)
Elia new
Availability period per quarter-hour
proposal
Question 6:
Do you agree with the standard products Elia is proposing? If not, which characteristics should be added
to the product definition? Please explain why?
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Summary of the received answers
New characteristics requested:
 to have a maximum activation period with maximum consecutive activations
 to authorize linked-bids to deal with start cost
 to propose long activation time
Elia new
 Maximum activation number
proposal
 Prolongation price
 Slow standard product
Question 7
In our current proposal we are proposing to settle the balancing energy in a pay-as-bid scheme.
However the platform will be developed in order to allow an easy switch to a pay-as-cleared
mechanism.
The final pricing mechanism shall be determined in function of:


the required market design to allow cross-border exchange of balancing energy with
neighbouring TSOs.
the NC on balancing and related harmonisation process (cf. proposition of ENTSOe tbd 1year
after NC on balancing enters into force).
Do you agree with the approach to start with a pay-as-bid mechanism and leave sufficient opening for
future evolutions?
Summary of the received answers
Most of MP are in favor to pay as cleared from the beginning to attract more offers, to favor
competitive prices, to be compliant with the NC, to be aligned with the settlement applied on the
Dutch market
Elia new
Pay as bid but flexible platform which can be easily switched to pay-as-cleared
proposal
Question 8:
Do you have other remarks regarding the proposal of Elia? Please explain the 3 most important issues or
concerns.
Summary of the received answers
Firmness
It should be clearly stated that the products will be firm only after the Balancing GCT,
as described in the NC Balancing.
Elia comments
We will respect the stipulations of the final NC on balancing
Compensation How activations will be considered in the imbalance volume calculation of a BRP.
18 | P a g e
model for
imbalance
settlement
Compatibility
between
Balancing and
Intraday
market
Non-BRP vs
BRP
Penalty for
load
subscription
Scope Noncontracted
Reserves
Aggregation
threshold
Elia comments
As explained further in the note the “block-product” shall be used
for the imbalance volume calculation. Hence during ramping-up
and ramping-down the provider shall be in imbalance. This is
consistent with the fact that will not remunerate the ramping
energy due to activation (only offered product).
The continuous Intraday market is currently offering 15’ products tradable until 5’
before delivery which is in overlap with the Bid Ladder that allows bid selection as from
1h before delivery.
Having this risk of refusal by Elia in the last hour before delivery would clearly put MP
in a position where they will have to choose either for ID or the balancing and will be
detrimental to the functioning of ID (Cf. situation in NL).
Elia comments
Considering that all Fast Standard Products shall be activated close
to real-time and that Slow Standard Products shall be rarely
activated we don’t expect negative effects on the functioning of ID
markets. Nevertheless as liquidity on the intraday markets has the
highest priority for Elia, we will closely monitor interactions
between the 2 markets in order to avoid detrimental effects. The
most optimal solution for avoiding interactions between both
markets is the correct time setting of the Intraday and balancing
Gate Closure Times.
Deal carefully when developing a proper compensation mechanism for large scale
development of activating reserves at distribution level in long term.
Some Market Parties ask Elia to develop also a solution that can be reachable for nonBRPs.
Elia comments
This solution is currently under analysis
There should be a compensation/exemption of any penalties linked to off-take
subscription. If load needs to include this in their price it means an unacceptable
discrimination vs. production.
Elia comments
Remark is not relevant for the design of the bid ladder platform.
Only affects the level of the bid price
Request to integrate also contracted reserves (R3load, R3prod, 3DP) on the bid ladder
platform
Elia comments
On the long run they shall be part of the bid ladder platform as the
NC on balancing is stipulating that all manual reserves need to be
shared with other TSOs except specific reserves (like ICH & R3DP).
In a first step we will concentrate on the non-contracted reserves.
It is stated by Elia that for all units bigger than 25 MW the prequalification shall be
done in a non-aggregated way. This threshold penalizes Aggregators that are mainly
aggregating units bigger than 25MW. This threshold could then limit:
 The reliability of bid offered on the Bid ladder
 The added value of the aggregation
 The number of sites eligible for offering on the Bid ladder
Elia comments
The limit which is determining an individual technical prequalification or not shall be based on the volumes which might be
offered on the Bid ladder and not anymore on the total power of
the unit
19 | P a g e
6. Proposal for the design of the new bid ladder platform
As explained in the introduction, this section shall design all aspects of the bid ladder platform. It will
start with a description of the different products and the bidding process. Later on will be described
other aspects of the platform.
Balancing Energy Products
The bid ladder platform shall allow the submission of 3 different kind of balancing energy products to
Elia:



A fast standard product;
Slow Standard products;
Emergency products.
These 3 different types of balancing product should allow capturing all possible flexibility which might be
used for balancing purposes. Hence all balancing actions shall be performed through the bid ladder
platform while the existing CIPU-process shall only be used for congestion management.
All types of products shall be “block”-products which doesn’t reflect necessary the physical constraints
of resources. Differences between the product and physical reality need to be considered in the price
when offering a product to Elia.
Elia believes that the use of high standardised balancing energy products is a key characteristic of a wellfunctioning balancing market as well as a precondition to facilitate international harmonisation. These
product definitions should allow:



Providers to compare the bids they have sent with bids from other providers;
Elia to be transparent in the publication of;
o the available balancing energy bids;
o how the offered balancing energy products were activated;
A fair valuation of bids in a merit order list;
o in our proposal providers needs to price themselves the differences between the
standard product and physical reality in their offered bid price;
o In case of open product specifications it would be Elia’s responsibility to correctly
valuate the offered balancing energy products into a merit order list;
Another important reason why Elia proposes standard balancing energy products is the fact that
currently the Netherlands is also using highly standard products. A step towards this direction would
facilitate a future collaboration between the Dutch and Belgian balancing markets.
The total activation time of standard products is not exceeding one hour. There are 2 reasons for this:
20 | P a g e


Article 67 (3) of the Network Code CACM states that the intraday gate closure time should not
be later than 1 hour before real time. Hence hourly balancing energy products can only be
activated on a moment where the cross-border intraday market is still active.
As explained in section 3 a re-active balancing market will rarely use balancing energy products
with long activation duration as it incentivizes market parties to fulfil the replacement role.
Logically on the long run the Gate Closure Time for cross-border intraday markets should gradually move
up closer to real time. As a consequence the slow standard products need to disappear one by one in
order to avoid overlaps with the intraday markets and balancing shall be performed only with fast
standard products. Hence it is utmost important that providers which are having slow flexibility
resources- which currently can only be offered through these slow standard products – take the
necessary steps (contractual, organisational, technical,...) in order to enable these resources for being
offered through the fast standard products as soon as possible.
The 3 product categories can be distinguished by 2 parameters: duration & activation time.
Fast standard product
Fast products are having an activation time of 1*15 min and are having an activation delay of 0*15 Min.
This product is the most important balancing product as it shall be used prior to the other balancing
energy products
21 | P a g e
Slow standard products
Slow products are having always an activation delay of 1*15 Min and are having different activation
times. We expect slow products to be transitory as on the long run the Intraday Gate Closure Time shall
move closer to real-time.
There are 3 different slow standard products which might be offered to Elia:

Delay of 1*15 Min and an activation time of 1*15 Min

Delay of 1*15 Min and an activation time of 2*15 Min

Delay of 1*15 Min and an activation time of 3*15 Min
22 | P a g e
Activation of slow standard products is exceptional and subject to specific rules (to be decided in the
balancing rules7). At least these products shall be used in case there are no volumes available anymore
of the fast standard product.
Emergency Products
The Grid Code is imposing that all power units with an installed capacity bigger than 75 MW are offering
all remaining flexibility to Elia. Although Elia is focusing on a re-active balancing approach it could be
required for Elia to activate reserves which cannot be offered through standard products in exceptional
circumstances. Therefore Elia is keeping the option to activate other reserves than the standard
products via the bid ladder platform.
In the current balancing process Elia is requesting additional volumes for upwards and downwards
regulation when:


Day ahead analysis is showing a risk for incompressibility (lack of downwards regulating
reserves) or shortness (lack of upwards regulating reserves);
During operation it appears that all available standard reserve products are activated.
In both cases a balancing warning is sent out and published on the website.
Once the bid ladder platform is active all power units >75 MW need to assure that – after a balancing
warning has been sent out by Elia - all remaining flexibility is sent to the bid ladder platform in order to
be compliant with the Grid Code. In order to facilitate this, Providers are free to choose the delay and
activation time of their bids.
77
Example lasting imbalances anticipated and 30min products are cheaper than 15min products
23 | P a g e
Bid characteristics
In this section will be described how the different products – as previously described – might be offered
to the bid ladder platform.
Each bid of balancing energy shall consist of the following characteristics:
Category
Characteristics
Mandatory
Unit
Values
Product
Type
Delay
Yes
15 Min
Integer (0;1;2;3;....)/ multiple of 15 Min
Activation time
Yes
15 Min
Integer (0;1;2;3;....)/ multiple of 15 Min
Only possible to be>0 in case the delay of the bid >0
Volume
offered
Bid Size
Yes
MW
1 decimal (5,0; 5,1;5,2;...;6,0;....) Minimum 1,0 MW
Positive value means produce more of consume less
Negative value means produce less or consume
more
Availability
Price
Congestion
management
Divisibility
No
NA
Yes or No; default value shall be set to Y
Availability
period
Yes
Time
Start time (xx:xx) & End Time (xx:xx) where the
minutes are multiples of quarter-hours
Maximum
Activation Time
No
15 Min
Integer (0;1;2;3;....)/ multiple
max value for availability period
Conditionality
No
NA
Link to other bid n°
Activation Price
Yes
€/MWh
Positive or negative with one decimal
Prolongation
Price
No
€/MWh
Positive or negative with one decimal
Locational
information
Y/N
EAN
Mandatory for resources >25MW
Type of flex
Yes
NA
Load, Production or combination
of
15
Min
24 | P a g e
Product Type


Delay
This parameter is indicating the delay between an activation request and the start of the bid. The
value is considered to be as a multiple of 15 minutes.
Ex. “1” would mean that the bid – in case of activation – will be only considered 15 minutes after
the activation request. “0” would mean that there’s no activation delay (“fast standard
product”).
Activation time
This parameter is indicating the minimum activation duration of a bid once it gets activated. The
value is considered to be a multiple of 15 minutes.
Ex. “1” would mean that the bid must be activated for at least 15 minutes. “2” would mean that
the bid must be activated for at least 30 minutes.
The activation time can only be longer than 15 minutes for “slow standard products”.
Offered Volume
 Bid Size
This parameter is indicating the amount of power which is offered through the bid. Each bid shall at
least offer 1,0 MW. The offered volume shall have 1 decimal. A bid can consist of several units less
than 1 MW, i.e. regulating flexibility can be aggregated.
The direction of the bid (+/-) is included in the Bid Size:

o Bid Size with “+” meaning that a Provider wants to produce more or consume less
o Bid Size “–“ meaning that a Provider wants to produce less or consume more
Divisibility
This parameter is indicating whether a bid can be partially activated or not. The default value of this
parameter shall be set to divisible. The option of non-divisibility might lead to a situation in which
Elia skips a bid on the merit order due to technical constraints (e.g. volume mismatch between offer
and request).
Example of divisible and indivisible bids
Bid 10 MW @80 €/MWh
In case indivisibility: Elia is only allowed to activate the full 10MW
In case of divisibility: Elia is allowed to activate 5MW or more up till 10MW (min. activation size 5 MW)
Availability
 Availability period
This parameter is indicating the period a bid is valid (ex. 06:00 until 10:45). A period shall always
start and end at a quarter-hour. The maximum availability period is 24 hours.
 Maximum activation time
25 | P a g e

This parameter is indicating the maximum number of times a bid can be called off during the
availability period. A prolongation of an activated bid is also considered in this limitation, hence
Providers can limit the total activation duration of a bid.
Ex. “3” means that a bid can be activated 3 times during the availability period. In this case this
means also that after the bids gets activated; the activation can be prolonged 2 times.
Conditionality
This parameter gives the possibility to send in exclusive bids; if one bid gets activated the other bids
aren’t activable anymore.
Example of conditional bids
Flex unit of 100MW with a variable cost of 60 €/MWh & with a fixed cost of 5.000€
The Provider might send in multiple conditional bids (each time the fixed cost is covered by a different volume) ; once one gets activated
the others will not be activable anymore. These bids cannot be combined with each other and thus are exclusive (‘either…or…’):
Bid 1: offer 100 MW @110€/MWh
(indivisible)
Bid 2: offer 50 MW @160€/MWh
(indivisible)
Bid 3: offer 25 MW @260€/MWh
(indivisible)
Price


Activation Price
This is the price which will be paid for the activation of a bid
o In case of a positive price the Provider will receive money for an upwards activation and
needs to pay money for a downwards activation;
o In case of a negative price the Provider will pay money for an upwards activation and
will receive money for a downwards activation.
The Prolongation Price
Providers have the option to give – next to the activation price – a prolongation price. In case Elia
requests to activate a bid - which was already activated in the current time frame -in the next time
frame, the Prolongation Price shall be considered if available. This optional price is giving the
opportunity for Providers to consider that all fixed costs only need to be recovered once in the first
activation.
Congestion management

Locational information
In this field Providers have to indicate the locational information of the resources which are
delivering the flexibility of the bid.
In a first stage the obligation to send location information shall be only applicable for units lager
than 25MW. (Units which have signed a CIPU contract).
26 | P a g e

The required information for units smaller than 25 MW still needs to be discussed with the DSO. As
long as there’s no conclusion no location information is required for smaller units.
Flex Type
In this fields Provider needs to indicate whether the bid is composed from flexibility provided by
generation, load or both.
27 | P a g e
Process for the bid ladder platform
Technical prequalification
All potential resources which might be offered to the bid ladder platform need to pass first a technical
prequalification. There shall be a reassessment in case requirements or equipment change and within a
time frame of at least five years.
For all units which are individually able to offer more than 25 MW bids to the platform this
prequalification shall be done in a non-aggregated way. For units with smaller available bidding volumes
the prequalification may be done in an aggregated way.
In the prequalification the following rules need to be respected for all standard products:



A bid shall be based on physical regulation;
Once the physical regulation used for the delivery of a bid is at the requested power level, it
should be capable to maintain the requested delivery at a stable power level;
Once the delivery of a bid is finished, the physical regulation used for the delivery of a bid should
be capable of going back to their normal level within 15 minutes and stay there;
For the fast standard products an additional rule is applicable:

The physical regulation used for the delivery of a bid should be capable of ramping up to its full
offered capacity within 15 minutes from the order;
The figures below give some example of (aggregated) resources which are respecting the criteria (green)
or which aren’t allowed doing this (red):
Fast standard product
28 | P a g e
Slow standard products
All Providers need to ensure that each of their bids is able to fulfil the technical requirements of the bids
they are offering. In order to enforce compliancy, a liability clause shall be foreseen in the BSP contract.
Also Elia shall perform prequalification tests as follows;


Test the volume of resources which are compliant with the rules regarding standard products;
This test shall be done individually for units which are individually able to offer more than 25
MW bids to the platform. For units with smaller available bidding volumes other units the check
shall be performed in an aggregated way.
A separate check shall be performed to prequalify the fast standard products. This test shall be
done individually for units which are individually able to offer more than 25 MW bids to the
platform. For units with smaller available bidding volumes the check shall be performed in an
aggregated way.
A Balancing Service Provider is not allowed to offer more balancing energy products than the
prequalified volumes and can only use resources which participated in the prequalification process.
A Provider shall ensure that –if required - the monitoring of the bids is possible. Upon Elia’s request, the
Provider shall be able to supply real-time measurements of the activated bids and the relevant
reference power production or consumption for each providing unit, for each providing group or each
providing unit which is individually able to offer more than 25 MW bids to the platform. In case of an
aggregated bid the Provider shall be able to provide aggregated/non-aggregated active power data to
check the activation of the bid.
29 | P a g e
Bidding process
Elia’s proposal is to have the following operational rules for the bidding process:





Providers are allowed to submit bids after 18h00 day ahead;
Bids can be modified, updated & removed up till the Balancing Gate Closure Time which shall:
o be after the Intraday Cross Border Gate Closure Time;
o ensure sufficient time for common processing of Balancing Energy Bids
After the Balancing Gate Closure Time all available bids on the bid ladder platform shall be firm.
This means once Elia requests an activation of a bid, its price and offered volume cannot be
modified anymore. Firmness implies that, irrespective of the physical reality, at the moment of
the activation Elia shall consider the activation of the offered volume in the BRP perimeter by
performing an adjustment.
After the Balancing Gate Closure Time the volume and price of Balancing Energy Bids can only
be changed by providers upon approval of Elia.
In the future, when the bid ladder platform will be integrated with a cross border platform, a
modification of a bid is only valid once the corresponding bid on the cross border platform has
been modified.
Explanation:



Firmness of products offers different advantages:
o It facilitates transparency on the real available volumes. In case of non-firmness there
might be substantial differences between the offered volumes and the real available
volumes;
o Elia needs to perform the balancing in the most cost-efficient way. This is not possible in
case prices aren’t guaranteed;
o Firm volumes are also reducing the number of activation requests by Elia in case an
imbalance occurs. Indeed this allows a faster activation of the required volumes which
are needed to resolve imbalances;
o As the bid ladder platform allows portfolio bidding, Elia believe that firmness shouldn’t
represent an issue for Providers;
Although Elia strongly believes that all non-contracted resources should be first offered & used
on the intraday markets, Elia will still allow the submission of bids on a day ahead basis. The
most important reason for that is that for organisational reasons not all Providers are able to
submit in bids each hour. The freedom to update & modify bids should enable Providers to offer
their flexible resources also on the XB intraday markets.
In a perfect functioning balancing market (in a normal system state) it should be possible to
accept modifications of bids close-to-real time. However due to the operational and technical
aspects of balancing markets and the close relationship with grid security Elia cannot exclude
30 | P a g e

that, in exceptional circumstances, modifications of bids wouldn’t be accepted. In such a case
Elia shall transparently communicate the underlying reason for this.
Once a cross-border balancing market is active, Elia will transfer bids in a firm way to a cross
border platform. In this context it is important that all firm bids on the cross border platform
correctly reflect the available firm bids on the local platforms. Therefore a Provider can only get
a confirmation of his modification request once this has been correctly considered in the merit
order lists of the cross-border platform.
31 | P a g e
Congestion management
When activating bids on the bid ladder platform, Elia shall consider information regarding network
constraints in order to avoid new additional congestions. This approach is compatible with the
Framework Guidelines on Balancing as published on September 2012: ““The Network Code on Electricity
Balancing shall require that locational information of balancing resources is used to further optimize the
balancing of the system and perform security analysis to avoid internal and cross-border congestions”.
Moreover within a couple of years, balancing energy bids will be shared with other TSOs on cross-border
common merit order lists. In this context is not logic to increase locally the congestions costs in order to
decrease the balancing cost of other TSOs.
Based on the locational information and type of flexibility Elia shall perform ex ante an analysis in order
detect if there are bids which might create additional local congestions. As on the bid ladder platform
portfolio bidding is allowed Elia will perform the network analysis by considering the worst case scenario
per bid; e.g. Elia shall consider that bid size can be fully activated at each location in the bid.
Example
Received incremental bids
Bid A1 100MW @80 /MWh
Bid B1 100MW @70 /MWh
Bid B2 100MW @60 /MWh
Location A, B, C
Location A
Location D
Network constraints
Network constraint on location B & D
Result
Bid A1 100MW @80 /MWh
Bid B1 100MW @70 /MWh
Bid B2 100MW @60 /MWh
Location A, B, C
Location A
Location D
In case a bid is set to unavailable the Provider shall be informed and gives him the possibility to send in a
new bid, with the remaining flexibility, resources which aren’t located at a network constraint. In the
example above Bid A1 is set to unavailable as there a network constraint on location B. However the
provider of this bid is allowed to send in a new bid with the flexibility resources on the locations A & C.
Ex post all network constraints which affected bid shall be published in a transparent way.
32 | P a g e
In order to guarantee correct locational information a liability clause shall be foreseen. In case of
manifest abuse, Providers might be excluded (partially) for a certain period from the bid ladder
platform.
All actions on the bid ladder platform shouldn’t overlap with the congestion management which is
currently handled through the CIPU-process:


Activation of bids on request of Elia shouldn’t cause congestions as ex ante a network analysis
shall be performed in order to avoid this;
A congestion bid requested by Elia in the CIPU-process on a specific location might affect the
availability of the offered bids for balancing on the bidladder platform. The Provider should have
the possibility to actualize the affected bids on the bid ladder platform, therefore corresponding
bids will not be activated for limited time period (ex. 10 min).
The final solution for all units including those smaller than 25 MW (including flexibility connected to the
DSO-grid) is still under discussion with the concerned parties and shall be communicated to the
Providers at least 1 year before this solution gets into operation. Independent from this solution once
the bid ladder platform goes into operation we shall at least require that all bids which are sourced from
power units larger than 25MW8 shall include the locational information.
8
All power plants larger than 25MW are having the obligation to sign a CIPU contract.
33 | P a g e
Activation
Elia’s proposal is to have the following operational rules for the activation process:








For each operational quarter-hour per standard product a regulation curve (merit order) shall be
established for the up-regulating bids using the principle of placing the cheapest bid first, and
for the down-regulating bids using the principle of placing the most expensive bid first.
All lists shall be published ex-ante per quarter-hour with the following restrictions:
o Only consider the maximum activation time once a bid becomes unavailable; a bid shall
be consider as available for each quarter-hour during the availability period
o Only consider the cheapest conditional bid
o Only consider the activation price and not the prolongation price
Ex-post all activated bids shall be published.
Elia shall in principle first activate all fast standard products. Activation of slow standard
products is exceptional and subject to specific rules (to be decided in the balancing rules9).
In case of congestions Elia will use the locational information to filter out those I and/or D bids
that would increase or cause congestions. This information will be published to allow Providers
to alter the composition of their bids (by excluding flexibility located at congested access
points).
Elia can skip individual bids in the regulation curve in case of a mismatch between the required
regulation volume and the offered indivisible bid size (e.g. need for 50 MW of regulation power
whereas the next bid on the curve is an indivisible 200 MW bid).
Activation request shall be requested to start by preference at the beginning of a quarter-hour
(except in case of urgent need due to large imbalances).
The activation notice can be as short as 1 min.
Example; a quarter-hour bid available for 15:00 to 15:15 can still be activated at 14:59
99
Example lasting imbalances anticipated and 30min products are cheaper than 15min products
34 | P a g e
Settlement
Our proposal is to have the following rules for the settlement process:


Settlement shall be done by applying a pay-as-bid mechanism; this could be reviewed in the
future depending on NC and related harmonisation process (cf. proposition of ENTSOe tbd 1year
after NC on balancing enters into force). Hence the bid ladder platform shall be developed in
order to allow easily a switch to a different pricing mechanism.
To calculate the delivered energy we shall consider the product which has been offered (i.e.
block product) to and activated by Elia, hence not the physical reality10.
For the imbalance adjustments Elia will also apply the offered products (i.e. block product) when
calculating the imbalance volumes of the corresponding BRP.
10
Hence the concept of billable margin –as explained in chapter 4 – shall disappear.
35 | P a g e
7. Appendix – Exhaustive answers from all Market Players
Question 1:
As explained, the minimum bid size on the bid ladder platform shall be 5MW. Do you agree with this
proposal?
Company
ARP_1
DSM_1
Answer
Rationales
No
In short term, the development of the market for distributed load and
generation to provide ancillary services and the activation of new sources of
system flexibility should be the objective. The market should be open for all
potential flexibility providers.
The minimum bid size could be considered as an entry barrier for BSP/BRP, but
also for grid users wanting to offer back-to-back balancing capacity to Elia. In
this fase of opening the market, the introduction of entry barriers must be
avoided. Therefore it would be beneficial not to enforce a fixed minimum bid
size. If the bid ladder product description would require this anyway, a
minimum size in the range of 0,1MW up to 1MW would attract more market
parties and further activate flexibility from the demand-side or distributed
generation. Additionally, smaller bid sizes could result in lower bid prices, better
reflecting technical and economic characteristics, which would yield a more
efficient activation of reserves by Elia.
On the top of this, in case flexibility capacity activation is fully automated, there
shouldn’t be any rational to apply a minimum bid size like 5 MW
In long term, this bid size could always be reconsidered from an efficiency
improvement perspective for Elia.
No
As stated in the introduction to this document, there should be no entry barrier
to this mechanism. As mentioned by ELIA during the last taskforce meeting,
5MW is a proposition based on the observation of the other European DR
markets. We believe it is not a proper benchmark for building a new mechanism
as European DR markets are old mechanisms built for production and not for
consumption. They are moreover soon to be renewed with the coming
European Balancing Code. DSM_1 believes that ELIA ought better take into
consideration more mature markets regarding demand side participation such
as the American ones where the threshold is often 100kW. In Texas for
instance, ISO ERCOT has long built a 100kW threshold mechanism where
demand plays a huge role : in 2008 during a large windturbine production
forecast error, more than 1GW of demand came into action within 10 min to
prevent a severe blackout to happen.
In addition, European TSOs are trying hard to lower these thresholds as well
(see Denmark, Germany) : they are mainly struggling because of IT related
issues, which is why DSM_1 believes that ELIA would be better off building a
mechanism with the lowest threshold possible right from the start.
36 | P a g e
ARP_2
Yes
DSM_2
RES_1
Yes
Yes
ARP_3
Yes
Power
N/A
Exchange_1
DSM_3 &
No
DSM_4
DSM_1 also believes that 5MW is large enough a threshold to prevent new BSP
or even small BRP to provide flexibilities to the system through this mechanism.
Of course, it is the role of a BSP to aggregate large volumes of flexibilities, but it
is a matter of being allowed to start small and grow.
One of the main arguments for a 100kW threshold over a 5MW threshold is the
kind of flexibility that ELIA wants to see developed in the medium term. With
such an energy only mechanism, flexibilities from diesel engines cannot be
offered successfully most of the time because of a marginal price exceeding
250€/MWh. Process flexibilities on the other hand have a lower marginal price
and are the only ones able to find value on the mechanism with no fixed
premium paid. They are usually automated and widely distributed hence the
need for a small threshold like 100kW.
Finally, 100kW is also the minimum size of a bid on the SPOT market. We
believe that Belpex and EPEX implemented such a minimum lot size because it
made sense to trade even such a small amount of power. Choosing this
threshold would also help to perform the integration of the different markets
(no change of size required between unselected intraday offers and bids on the
bid ladder).
ARP_2 is of the opinion that a product with a size of 5 MW is in line with the
existing products. By proposing products of 5 MW Elia is going for a pragmatic
operational approach - which ARP_2 supports - because precisely activating and
controlling volumes of power below 5 MW is operationally difficult. Ideally, and
in practice, volumes of 25 MW should be activated at a time.
No motivations
We zullen altijd moeten aggregeren om dit vermogen bij elkaar te krijgen.
Gemiddeld 3 installaties igv op/af schakeling en minimum 10 installaties igv
reduceren.
Graag wel de 5 MW als start niveau waarbij vanaf dan 100 kW kan worden
aangeboden en verrekend.
Normaal zullen het volle eenheden zijn die worden geschakeld. (gaande van 800
kW tot 4000 kW).
No motivations
No answers



A 1 MW threshold would be better for those consumers that would
want to offer directly to Elia. Now all these consumers with less than 5
MW will need to go via the aggregators which limits the numbers of
bidding parties for Elia.
Does 5 MW minimum means that that is for ELIA the minimum
divisibility. If a block is activated by ELIA: always at least 5 MW?
What is main reason for limiting to min. 5 MW?
37 | P a g e
Question 2:

In case of divisible products a TSO activates only a part of the total activated volume

In case of indivisible products a TSO can only activate the full offered amount or nothing
Do you think indivisible products are required? Why?
Company
ARP_1
DSM_1
ARP_2
Answer
Rationales
Yes
It is important that flexibility providers can include the additional elements to
their bids representing the technical and economic specifications of the
appliances or sources offering the flexibility. The operation of both distributed
generation, e.g., CHPs, and flexible load, e.g., cooling or water pumping, are
characterized by temporal aspects. It is important that these seasonal as well as
intraday requirements can be reflected by entering indivisible bids.
Yes
Indivisible products are quite often encountered in demand side management
where you curtail or enhance ON/OFF processes. Even with aggregated
flexibilities from demand, say of 15MW, you cannot always guarantee that your
portfolio can provide 1 or 2 or…or 14MW if required by ELIA. This might be
achievable with very large aggregates but not in the short term. Indivisible
products are necessary to get demand to participate to the process.
Divisibility issues only occur with marginal price setter flexibilities. DSM_1
would understand that should this happen, divisible products are activated
although more expensive in €/MWh than an indivisible one.
For instance, if only 5MW are needed at some point, and ELIA has an 8MW
indivisible product at 80€/MWh and a 10MW divisible offer at 120€/MWh at its
disposal, DSM_1 considers that the divisible offer should be selected by ELIA. If,
all other things being equal, the 10MW divisible offer was at 140€/MWh,
DSM_1 considers that the 8MW indivisible offer should be activated.
Yes
First of all ARP_2 is convinced that most value will be captured by the
introduction of the bid ladder itself. The design of this bid ladder should – as
general rule – be as lean and transparent as possible.
In theory divisible products can be useful in order to more accurately optimize
in function of the TSO’s needs and the physical assets’ characteristics. At the
same time it leads to a more complex market: it will be difficult for market
participants to interpret the bid ladder as an optimization will be necessary to
determine which marginal price applies at which call-up size. This trade-off
(transparency versus optimization) will need to be made.
Furthermore, ARP_2 wants to point out that:
 some pragmatism will be needed in order to have the characteristics of
the physical assets reflected in indivisible products: bid size, …;
 one should prevent that bids, which are set as indivisible for pricing
reasons, would not be activated while in practice these bids could be
divided;
 some types of bids are really considered as AON (All Or None) because
of the price submitted or the technology associated; this is the case for
38 | P a g e
DSM_2
Yes
RES_1
Yes
ARP_3
Yes
Power
N/A
Exchange_1
DSM_3 &
Yes
DSM_4
example for:
o bids linked with a start cost;
o for technical limitation (non-stable running mode below Pmin);
o for technical reasons (shut down of some technology – ex:
windmills, industrial processes).
ARP_2 believes that indivisible bids are necessary but that both types of bids –
divisible and non-divisible – could over time cohabitate to allow the maximum
of flexibility to be offered to Elia via the bid ladder. Anyhow ARP_2 is of the
opinion that bids have to be activated by a minimum of 5 MW: divisibility below
this level should not be made possible.
For many industrial consumers, it is sub-optimal to run their equipment at
levels other than maximum or minimum capacity. This implies a preference for
full curtailment of power of running machinery, rather than partial curtailment.
To capture all potential of power flexibility on the demand-side, we believe it
hence would be useful to have indivisible products.
Kans op activeren van half motorvermogen vermijden. Motoren worden vooral
bekeken als aan/uit installaties. Op/af-regelen (reduceren) is op dit ogenblik op
een beperkt aantal installatie voorhanden.
In case of indivisible products offered divisibly, if partially activated by the TSO,
the full activation will take place because of technical reasons. Normally, the
corrected BRP portfolio will go in imbalance in the 'good' direction. The
imbalance price for this quarter hour will be either his bid price, or better.
However, the alfa coefficient might interfere, and make the resulting price
uneconomically for the bidder. The BRP will always be on the wrong side of the
alfa-coefficient, meaning that he will be long @ the positive price (while
negative price will be set by him), and the other way around.
Hence, you could offer indivisible products only, but then the alfa should be
corrected as well. In case you offer divisible products, you should integrate
them in to one bid ladder, but the last order should always be divisible (which
will complicate the publication process, not the calculation).
No answers
Industrial consumers will sometimes need to know upfront what the potential
consequences of an activation will be as certain flexibility in the process might
be a fixed nr. of MWs. Eg. If Elia would only activate 3 out of the 5 MW offered
it means that the industrial client will shutdown 5 MW as it is fixed but will only
be remunerated for 3 MW.
It is hence also necessary for a correct valuation of the bids (in part of the offers
39 | P a g e
Question 3:
Flexibility provided by load or production might have a fixed cost each time it is requested. There are
two ways of dealing with these fixed costs:

Allow conditional bids: Providers are allowed for the same unit to send multiple bids in which
the start cost is valuated each time for a different volume of activation. In such a case Elia will
not activate other bids once one of the bids has been activated

Allow to send separate start costs next to an activation price. In such a case Elia need to
perform an optimization in order to put this bid into competition with other bids without fixed
costs.
Elia believes that conditional bids are the most pragmatic solution.
Do you agree with this?
Company
ARP_1
DSM_1
ARP_2
Answer
Rationales
Yes
Conditional bids are indeed the most programmatic way to deal with fixed
costs. Conditional bids valuating fixed costs are also more transparent than the
introduction of separate offers for start-up costs.
Elia should also consider condition bids between quarter hour, in order to take
into consideration maximum activation time per day, or start and stop costs of
the flexibility units.
Yes
DSM_1 agrees with this approach. On top of the greatest simplicity compared
to the suggested alternative, this solution can enable a load aggregator to bid in
different combinations of its portfolio without penalizing neither cheap nor
expensive offers.
If for instance an aggregator has 5MW available at 80€/MWh (typical process
curtailment price) and 5MW available at 250€/MWh (typical diesel engine
marginal price without margins), the aggregator can bid in 5MW at 80€/MWh
and 10MW at 165€/MWh through the use of conditional offers.
Yes
ARP_2 believes that Elia is the best placed party to determine which volume of
power is needed for balancing the country while market parties are the best
placed to calculate the costs associated to their bids. If the time period is fixed
and only the volume can vary to integrate the start cost, the option of
conditional bids is indeed the best option. This is the reason why ARP_2 agrees
with the proposal of Elia to include mutual exclusive conditional bids.
Nevertheless ARP_2 urges Elia to analyze the implications of this proposal
further in detail, especially paying attention to the following:
 market participants may want to use conditional bids to reflect nonmonotonous marginal cost curves etc. potentially leading to a large
number of conditional bids possibly in combination with the option of
divisibility - resulting in complicated interdependencies;
 this rather complex option should not lead to the exclusion of some
volumes of the bid ladder;
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
DSM_2
RES_1
Yes
Yes
ARP_3
Yes
Power
N/A
Exchange_1
DSM_3 &
DSM_4
No
the way the different bids are presented on the screens should be
carefully assessed as a MW can appear in several conditional bids.
DSM_2 fully endorses this proposal
Igv motoren zal activatiekost verlagen als langer kan gedraaid worden.
Minimum activatietijd hebben de leden toch liefst op minimum op 90 min.
No motivations
Pragmatic aspect of it will be highly dependent of the solution implemented for
the Bid ladder.
We support that for market parties conditional bids make a lot of sense and
represent an attractive solution. However depending on the solution this type
of bid will generate implementation challenge with regards to the visibility for
the TSO’s and market parties as well as any matching algorithm.
It might be the most pragmatic solution but from a cost perspective point of
view it is probably not the most suitable option.
Eg. if a bid for a 15 min. period is selected and the same unit is selected for the
consecutive 15-min. periods, the unit will see its start-up costs being
remunerated several times. In full market functioning, you should have
sufficient ‘other’ bids that are lowered priced from units that do not have startup costs anymore, but when activating such an expensive bid, it means the
market is already tight and the probability to prolong it is quite high (overpaying
in consecutive hours).
It would interesting to do an impact analysis on what is the most cost-efficient
solution:
 Conditional bids incl. start-up costs
 Bids with separate start-up costs
 Conditional bids but for longer products (1h, multiple hours) incl. startup costs and activate on both sides when needed.
41 | P a g e
Question 4:
Elia believes that working with standard balancing energy products is the best solution to develop a
balancing market for manual reserves. Do you support this idea?
Company
ARP_1
Answer
Rationals
Yes
In order to activate the most sources of flexibility in the most efficient way, two
aspects must be balanced:
 Standardization of balancing energy products: Working with
standardized balancing energy products is indeed the best solution to
develop a well-functioning, open and transparent market for reserves.
This will also facilitate the reserves activation process by Elia.
 Products realistically reflecting the techno/economic characteristics:
When certain elements, inherent to the operation of flexibility cannot
be included when offering balancing energy products, it could restrict
some sources of flexibility from participating to that market.
Therefore we support the idea of having standard balancing energy products, as
long as indivisible and conditional bids are allowed and as long as Elia is willing
to extend these standard balancing products to new market evolution along
the time.
DSM_1
Yes
DSM_1 believes that ELIA’s approach is correct. There is a need for standard
products in order to provide liquidity and to enable real time transparent
technico-economical ranking of the offers.
However, careful definition of the products is required so as to enable both
consumption and production flexibility to participate to the bid ladder.
Standard products are also critical to send a clear and lasting signal to the
market so as to enable investment in demand side management technologies.
ARP_2
Yes
ARP_2 fully supports this idea.
DSM_2
Yes
Yes; will result in liquidity & transparency
RES_1
Yes
Ja, op standard producten maar het maakt het niet eenvoudig om met
substantieel vermogen deel te nemen in de onbalansregeling wanneer slechts
voor 15 – 30 min geschakeld wordt. Er zal mijn inziens geopteerd worden om
de geschakelde posities 90-120 min aan te houden.
Mijn vermoeden is groot dat hier voor weinig interesse gaat zijn bij de tuinders
om hierop te schakelen. Kunnen we een goed reduceer systeem uitrollen dan
bestaat de kans dat we +10 MW (op/af) bij elkaar krijgen.
ARP_3
Yes
No motivations
Power
Yes
This is absolutely vital to guarantee liquidity and facilitate transparency.
Exchange_1
We however don’t support the proposition to have 15 minutes and 30 minutes
products. We understand that the reason why Elia is proposing 30 minutes
product is to better reflect the costs for such product that will probably be
cheaper.
We believe that this measure will not work in favor of the liquidity of the 15
minutes products. So either 30 minutes will cannibalize 15 minutes product or
30 minutes product will not exist.
Rather we would propose to think about linked 15 min product that is priced
42 | P a g e
DSM_3 &
DSM_4
Yes
differently if 2 linked 15 minutes products are activated consequently by the
TSO’s.
In general we support the idea of working with standard products as this is the
most transparent and also quite simple.
However we firmly believe that longer time products will be necessary in order
to attract industrial demand. Being activated for only 15 min. will for a lot
processes not be possible. Especially if the ramping up/down periods are not
compensated in the BRP unbalance invoice, however this is not clear in the
explanation.
This together with the min. 5MW threshold makes the product not very
attractive.
Further to this:
 Making products too standard might force all consumers to go via
aggregators which will reduce the nr. of bidding parties
 Make sure that the product requirements are not stricter to what the
grid really needs
43 | P a g e
Question 5:
There are 2 different ways for sending in bids to a platform:


Sending in a bid per quarter-hour; (current system)
Sending in a bid with an availability period (ex. 06:00 -> 10:45) (current proposal)
Do you have a strong preference for one of the solutions?
Company
ARP_1
DSM_1
ARP_2
Answer
Rationales
No
It is important that the way for sending in bids to the bid ladder platform is not
restricting from participating to the platform or to include specific
characteristics of some sources of flexibility. Furthermore, it should be
considered that the way of sending in bids can easily be implemented in an
automated way.
Yes
DSM_1 strongly believes that the best solution lies with the current system of a
bid per quarter hour. It is more flexible than the current proposal, and there are
a few points to also consider:
 During the last taskforce meeting, we have heard arguments against
the current system of a bid per 15 min timestep because stakeholders
needed to fill in 96 values a day. This cannot be a valid reason for
choosing the other model when information technologies are so easily
accessible to all stakeholders no matter their size.
 It is very hard to change from an availability period based structure to a
15min based one. Stakeholders in France for instance would like to
move from a period based model to an hourly or half-hourly based
model to better stick to SPOT market prices dynamics while dispatchers
at RTE would like to keep the availability periods to stick with the
dynamics of the national load curve.
 It is better for the development of demand side management that bids
can be offered and modified as close to real-time as possible.
Availability period model are a barrier to the development of offers
from demand site whose flexibility might not be present during a full
availability period. In addition, if a problem occurs on site, the
aggregator should be granted the possibility to remove offers quickly so
as not to default in case of an activation by ELIA, and to offer the bids
again when the situation is back to normal on site. An availability period
model prevents offers to be made available after the beginning of a
period.
 Finally, DSM_1 believes that a 15min based model suits more an energy
only mechanism than an availability period based model. With the
latter often comes the need to pay an availability fee, which implies a
need for a D-1 gate closure. This is too far away from real-time to
enable fast DR from load to get developed.
Yes
Although this shouldn’t be a stumble block, it makes sense to keep the quarterhourly nominations as this makes the transition for existing market participants
44 | P a g e
DSM_2
No
RES_1
ARP_3
No
Yes
Power
N/A
Exchange_1
DSM_3 &
Yes
DSM_4
easier because no changes to existing systems necessary. For new market
entrants the cost of implementing one or the other should be the same.
But, bid in availability window allows aggregators & industrial consumers to
reduce the amount of time they have to spend on submitting bids.
No motivations
We would be sending bids per quarter-hour. It is the market standard, which
allows for a good combination of the systems we operate in day-ahead,
intraday,... the rest of the market.
Question: In this case can this product be activated for multiple periods?
No strict preference. Bit more in favor of current proposal
45 | P a g e
Question 6:
Do you agree with the standard products Elia is proposing? If not, which characteristics should be added
to the product definition? Please explain why?
Company
ARP_1
DSM_1
ARP_2
Answer
Rationales
No
We suggest to consider other characteristics, as listed below:
Generation/load shifting aspects: Some types of generation or load have a
minimum or maximum (scheduled) number of operating hours per day.
Upward or downward activation of these types of flexibility will create intraday
shifting effects. This is especially the case with the new sources of flexibility that
will be offered on the bid ladder platform. It would be interesting for Elia to
schedule these load shifting effects in order to avoid to create new imbalances
in the upcoming hours.
Temporal conditional aspects: Conditional offers are now suggested for
increasing the volume (expressed in MW) offered during one quarter and
correspondingly reducing the activation prices. This condition only affects one
period. It would be interesting to allow temporal conditional offers for
increasing the period of activation (expressed in quarters) keeping the activated
volume (expressed in MW) constant. This would be realistic when the cost of
keeping the activated volume online in the upcoming quarter is different from
the cost in the previous quarter.
Exclusive bids/maximum activation period/maximum consecutive activations:
Some types of generation or load have a minimum or maximum (scheduled)
number of operating hours per day. This means that upward or downward
regulation can only be activated during a limited period, e.g., 2 hours per day or
4 quarters consecutively. It would be interesting if flexibility providers could
indicate how often, or how long it can be activated.
No
In line with the answers to the previous questions, DSM_1 believes that to get
demand to participate massively to the bid ladder, there is a need for simpler
and more flexible products.
If 15 to 30min mobilization times are a good thing, the minimum size of the
products should be of a 100kW with every bid in multiples of 100kW.
There should not be an availability period for a bid but the aggregators should
be allowed to nominate a 15min based program which is more flexible and
sticks more to the reality of on-site constraints.
No
ARP_2 is clearly in favor of 15 minutes blocks. The half-hourly product has
limited upside potential and would add complexity to the market and make
additional optimizations necessary to correctly interpret the bid ladder.
A more useful option would be to have linked bids: these bids would only
become active when a previous bid has been selected. This could be useful for a
prolongation of a power plant: when a power plant has been started in a
previous quarter, the price for the following quarter will be lower. It is obvious
that a clear and transparent selection procedure has to apply.
On top of that ARP_2 still has some questions with regard to the proposed
product:
46 | P a g e

DSM_2
RES_1
Yes
N/A
ARP_3
Yes
Power
No
Exchange_1
DSM_3 &
N/A
DSM_4
As the activation time is 1 minute for both products, isn’t Elia excluding
certain technologies or even R3 reserves?
 Elia defends in this document the reason why hourly products are not
withheld in the standard products as it concerns mainly a reactive
balancing. But could a situation occur in case of a structural
incompressibility (for example) where certain products with a block period longer than half-hour due to the technology would be called in a
pro-active way (as they are structural and substantial)? Will the
proposed restriction not exclude an important part of the flexibility,
also outside the Elia balancing zone?
 How could one integrate in these 2 products a maximum activation
period? Ex. 2 hours activation per day?
 Elia refers to the cross border platforms, but current cross border intraday doesn’t allow quarter hourly products (although available in
Germany). Is the idea to evolve towards quarter hourly exchange cross
border. Potentially the 15 minutes bids of Elia could be arbitraged
against hourly cross border bids.
Simple, transparent products have been proposed by ELIA. We endorse this.
Ik zou geven dat een block-bid (cfr belpex & intraday) interessant kan zijn voor
ons (minimale runtime) maar op dat moment komen we buiten de re-active
balancing market en zullen jullie ons doorverwijzen naar de intradaymarket.
No motivations
NO –Cf. our answer at question 4.
As already mentioned : A longer time product will be needed (1 – 4h) and take
the risk of having to do bi-directional activation given current sometimes very
long same NRV – direction system imbalance.
Furthermore there should also be a compensation/exemption of any penalties
linked to offtake subscription. If load needs to include this in their price it
means an unacceptable discrimination vs. production.
Some additional elements to focus on:
 cross border alignment: Nl alignment is nice but as Tennet is first
netting Germany, it doesn’t bring the expected results to Belgium
 Focus more on pushing GRD’s on correctly allocating solar to
perimeters.
 Having experience with the German feed now (50 hz), why not push
towards feed-in (for system stability)…
47 | P a g e
Question 7
In our current proposal we are proposing to settle the balancing energy in a pay-as-bid scheme.
However the platform will be developed in order to allow an easy switch to a pay-as-cleared
mechanism.
The final pricing mechanism shall be determined in function of:


the required market design to allow cross-border exchange of balancing energy with
neighbouring TSOs.
the NC on balancing and related harmonisation process (cf. proposition of ENTSOe tbd 1year
after NC on balancing enters into force).
Do you agree with the approach to start with a pay-as-bid mechanism and leave sufficient opening for
future evolutions?
Company
ARP_1
DSM_1
ARP_2
DSM_2
RES_1
ARP_3
Answer
Rationales
N/A
No answers
Yes
DSM_1 agrees with such a pragmatic approach, which enables the development
of a new mechanism without waiting for a final version of the NC.
No
The proposed settlement mechanism is pay-as-bid, while the NC ‘Balancing’
(article 22) is clearly in favor of marginal pricing (pay-as-cleared). While ELIA
recognizes that it could have to be reviewed in the future, the current wording
of the proposal seems to underestimate the clear preference in the NC
‘Balancing’ for marginal pricing. It would thus be a missed opportunity not to
bring the settlement process in line with practices on European level.
Moreover, since this proposal has the explicit goal of converging the Belgian
and Dutch reserve markets (page 11 §1), it should be pointed out that Tennet
currently uses marginal pricing for its settlement process.
N/A
No answers
N/A
No comments
Yes
It is ok to start with a pay-as-bid scenario.
However, as liquidity increases, a switch to a pay-as-cleared mechanism should
follow (if allowed for by the NC etc...).
N/A
No answers
Power
Exchange_1
DSM_3 &
N/A
DSM_4
We believe that it would be good to perform an impact analysis on the effect of
moving to a pay-as-cleared system for the bid ladder/free reserves. In case the
additional cost of it is relatively limited we believe moving to pay-as-cleared
would have following advantages:
 easier for consumers to bid in – now they will need to perform an
analysis of the /gamble on the expected price the others will bid in at.
Energy companies can more easily perform this analysis than
consumers due to info asymmetry (more feeling with intraday OTC
trade, modelling, ...)
48 | P a g e


risk of destroying welfare by bids that are not competitive although
their underlying cost is cheaper than the most expensive bid selected
(effect of bad bid price analysis –see a))
discrimination between system imbalance priced marginally vs. bids
price pay-as-bid. This will create an additional complexity for bidding as
one need to choose between not bidding to the bid ladder (or at very
high price) and go in imbalance as the remuneration on the imbalance
market is expected to be higher. So this might reduce volumes again.
49 | P a g e
Question 8:
Do you have other remarks regarding the proposal of Elia? Please explain the 3 most important issues or
concerns.
Company
ARP_1
DSM_1
Issues
Issue 1
Communication requirements and protocols: The different phases in the CIPU framework
long ahead of real-time should indeed be avoided to simplify the bidding procedure and
related IT requirements. However, the development of entirely new IT requirements
should be avoided.
Issue 2
We welcome the current concern at Elia level and expressed during the task force
regarding the “Vol d’énergie”. This issue should be carefully dealt with and a proper
compensation mechanism should be set up supporting large scale development of
activating reserves at distribution level in long term.
Issue 1
The question of the separation between BSP and BRP is not treated. It is however a critical
point if ELIA wants BSPs to actively participate to the balancing of the grid.
France has implemented this system back in 2003 and is going one step further with the
new NEBEF rules that are currently submitted to remarks from the stakeholders.
We believe that demand side management is not the field of expertise of electricity
suppliers and that ELIA would greatly benefit from giving BSP an official status. Nowadays,
suppliers do not seem to see the value in demand side management and hence do not try
and sign agreements with BSPs to exploit the flexibilities within their portfolio. This
situation of monopoly is what prevents demand side management to grow properly and
quickly.
Issue 2
The pricing of an offer on the proposed architecture of the bid ladder is difficult, nearly
impossible without taking a risk on the price. Even under the hypothesis of an activation
only at multiples of 15min, there are uncertainties associated with the determination of
the price of an offer that needs to be deposited until one hour before possible activation.
The bidder is not in position to know an hour in advance the negative imbalance price nor
the positive imbalance price that he needs to incorporate back into his bid price to break
even. This is also a good reason to consider again the relationship between BSP and BRP
because this pricing issue and the separation question are somehow related.
50 | P a g e
ARP_2
DSM_2
RES_1
ARP_3
ARP_2 wants to put forward following issues and concerns:
 Elia foresees the option to spread the starting cost (if any) over a variable volume
via the conditional bids, but how will Elia allow to take into account the starting
costs on consecutive products linked to the same asset? In this case, not the
volume but the time is a variable parameter to define the offer. As offers could
vary from quarter-hour to quarter-hour, the merit order could change and
activation of assets could also change every quarter-hour.
 The goal of the bid ladder is to include a bigger volume of flexibility from the
market which is currently not included in the CIPU, did Elia make the analysis if all
assets under the CIPU will be conform the proposed standardized products?
 Regarding the firmness of the bids (page 13) the proposal is a bit fuzzy about
when exactly a bid is firm. On the one hand, ‘All bids sent on the bid ladder
platform shall be firm’, however, ‘Bids can be modified, updated & removed up
till 1 hour before real time’. It should be more clearly stated that the balancing
products shall be firm only after Balancing Gate Closure Time, again in line with
the NC ‘Balancing’ (article 17.1).
 The first remark concerns the overlap with the intraday market. As it’s possible to
trade until 5 minutes before the real time on the Continuous Intraday Market and
the bids are ‘blocked’ 1 hour ahead by Elia on the balancing market, coordination
is needed. ARP_2 would recommend to sit together with Elia, Belpex and Market
Parties to see how the market design should look like with regard to this
important overlap. ARP_2 pleads for no overlap on the two markets.
 Elia must ensure that use of type and locational information (page 11) does not
result in discriminatory behavior. Deviating from the economically optimal call-up
should be an exception and subject to proper publication, reporting and
regulatory supervision.
Issue 1
We would appreciate a pilot with DSO connected load, to check feasibility in parallel to
operational roll-out for TSO connected load.
No issues
Issue 1
reserved capacity (R3 production and R3 dynamic load) should be allowed to participate
in the bid ladder process. It allows them to recover variable costs at the time of activation,
instead of at the time of auctioning the reserve capacity, which allows for lower
reservation prices (better for society in general through the tariffs).
51 | P a g e
Elia remains certain of its reserves, for this capacity is still offered in the balancing market
(so prohibited from participating to the free market).
Issue 2
A B2C interface for this kind of work seems unnecessary to me. From a practical point of
view, no one will be using it. However, the B2B should be kept as simple as possible.
Power
Issue 1
Exchange_1 Power Exchange_1 has major concerns with regards to the operational rules proposed in
page 13:
 Opening of Bid Ladder in Day Ahead 18.00 can only be conceived if an integration
exists with ID platform (Cf. discussion in bilateral meeting and reaction of the MP
in the Bid ladder TF in March)
 It looks odd to freeze the bid ladder (no new entry and update) if the activation
time of the bid offered is =< 15 minutes. 20 minutes seems more reasonable and
would let the opportunity to solve the imbalance observed via ID market. In your
proposition implicitly you stop the ID market 1 hour before delivery where today
it is 5 minutes before delivery
Issue 2
It is not clear in the proposal when the firmness should be guaranteed. By deduction we
understand that firmness can only be guaranteed an hour before delivery for 2 reasons:
1.
firmness guaranteed before that
2. Elia will not activate bid prior to an hour before delivery
Having this risk of refusal by Elia in the last hour before deliverywould clearly put MP in a
position where they will have to choose either for ID or the balancing and will be
detrimental to the functioning of ID (Cf. situation in NL)
Should Elia go in this direction, you are implicitly stopping the ID option an hour before
delivery (cf. above). Market parties will not take the risk. We see this behavior already
today with the IDPCR. (Given the fact that deviation might be refused after an hour.)
DSM_3 &
DSM_4
Issue 3
The proposal described in this document looks very similar to the solution developed by
Tennet in 2000. Is there a willingness to be as close as possible to Tennet model to have
quickly a cross border market?
We would have thought that the TF would have been used to develop a new Bid ladder
concept aiming to achieve the objective set by the TSO’s (this including an efficient
interaction with the intraday market to limit reactive balancing actions). As expressed
earlier to Elia bilaterally and in the TF we believe that the model as currently develop by
Tennet is not well functioning with the intraday market (Cf. presentation attached to the
mail and presented during our last bilateral meeting)
We would also like to point out that Tennet expressed their willingness to discuss this
issue with us (cf. minutes of our meeting with Tennet in September sent earlier) in the
framework of the cross border initiative
Issue 1
Longer time products might be required for following reasons:
 If an industrial process needs a min. of 2h at a given level in order to stabilize.
52 | P a g e

DSM_5
With a 15-min. product it would mean that he would be 1h 45 in positive
imbalance and hence the spread between belpex and positive imbalance price
should be taken into account in the bid which is difficult. Also as the BRP is
corrected he will have an impact which might complicate BSP/consumer & BRP
relationship.
Solve the issue of start-up costs being remunerated several times in case of
prolonged activation of the same unit
Issue 2
The issue of compensating/exemption of the penalty linked to offtake subscription is
important.
Other practical points:
 18h00 why not allow earlier introduction ? (that is then on your screens only
activated after 18:00 hrs?
 Direction of the bid : it would perhaps be less confusing for load and still
understandable for generation if the convention would be “sell” iso “+” and “buy”
iso “-“
 Type of flexibility : We do not see what additional value this information brings to
congestion management if you already have the locational information.
 Provide real-time measurement of bid activation, reference consumption: iso
putting the threshold at 25 MW of active power output we would prefer that you
need to perform this in case you intend to put bids of more than 25MW on the
platform
 in case of XB-platform I do not really see why having at this moment still a local
and XB-platform ? Why not bid in directly to the XB-platform. Which would avoid
the delays in terms of confirmation of changes to bids.
Article 67 (3) of the Network Code CACM states that the intraday gate closure time should
not be earlier than 1 hour before real time. Hence hourly balancing energy products can
only be activated on a moment where the cross-border intraday market is still active.
Issue 1
It is stated by Elia that for all units bigger than 25 MW the prequalification shall be done in
a non-aggregated way. This threshold penalizes Aggregators that are mainly aggregating
units bigger than 25MW. This threshold could then limit:
 The reliability of bid offered on the Bid ladder
 The added value of the aggregation
 The number of sites eligible for offering on the Bid ladder
Issue 2
Concerning the products:
 we are in favor of having long activation time (slow standard products);
 About emergency product, is it possible to have an activation delay upper than
15min? or an activation time upper than 45min?
Issue 3
We would like to have a consultation in order to discuss several topics about non-BRPs
becoming active on the Bid Ladder:
 Mechanism to control actual activation
 Mechanism to deal with the “vol d’énergie”
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
Aggregation modalities