Regional reporting on electricity interconnections management and use in 2008 in FUI region The creation of a single European electricity market has come up against a major obstacle, which is the lack of sufficient interconnections between Member States. Looking forward to solutions to solve this major obstacle, National Regulatory Authorities should at least ensure that congestion management methods currently applied in Europe are efficient. This regional report on electricity interconnections management and use mainly aims to provide”a detailed evaluation of the economic efficiency of congestion management methods for the year the data is taken from” at a regional level. It should ideally complete the Compliance report exercise undertaken at European level. This regional report should also help National Regulatory Authorities to reach not only a common understanding about the functioning of congestion management methods, but also a common view about the best way to further improve their functioning. 1 Structure of the report 1. Cross-border flows of the FUI region in 2008..................................................3 Within the region..............................................................................................................................3 Ratio average cross-border capacity / installed generation capacity per country...........................4 2. Congestion management methods in the FUI region .....................................5 a. b. c. c. d. 3. General description of congestion management mechanisms ...........................................7 Table 2 Publication of the rules for allocation and nomination procedures.....................................7 Long and medium term capacities..........................................................................................8 Day-ahead capacities..............................................................................................................10 Intraday capacities..................................................................................................................11 Balancing exchanges .............................................................................................................11 Economic efficiency of congestion management methods .........................13 a. b. c. d. e. 4. Global figures ..........................................................................................................................13 Competition indicators ...................................................................................................................13 Long and medium term capacities........................................................................................16 Day-ahead capacities..............................................................................................................19 Consistency of nominations with price differentials.......................................................................19 Intraday capacities..................................................................................................................21 Balancing exchanges .............................................................................................................22 Cross-border balancing reserves ..................................................................................................22 Capacity calculation and management of cross-border flows.....................25 a. Principles of the capacity calculation method by TSOs .....................................................25 General capacity calculation procedure ........................................................................................25 Evolution of the net transfer capacity ............................................................................................26 Comparison between the NTC and the offers made at the long and medium capacity auctions .27 c. Costs for ensuring the compatibility of the cross-border flows with grid security.........27 d. Curtailments occurred in 2008 ..............................................................................................28 2 1. Cross-border flows of the FUI region in 2008 The region comprises two Direct Current interconnectors (cable) the IFA and Moyle interconnections. The Interconnexion-France-Angleterre (IFA) is currently the only interconnector in the France-UK-Ireland (FUI) region connecting two Member States and subject to the requirements of EU legislation and the Congestion Management Guidelines (CMGs). A joint mechanism for the allocation and use of long-term interconnection capacity has been in place on IFA since April 2001. Recent improvements on the IFA include the introduction of a new capacity management system (CMS) in October 2009 in charge of the allocation and the nomination for the account of NGIL and RTE. At this occasion a new set of rules was implemented and approved by the regulators. The Moyle Interconnector is located within the UK, but links the BETTA and SEM markets. While it is not classified as an interconnector under EU legislation, Moyle has implemented some of the EU requirements for interconnectors such as third part access rights. Under its licence Moyle makes capacity available to the market in accordance with access arrangements which are subject to the approval of NIAUR. Within the region (155 GWh) IR GB GWh 299.1 TWh (700 GWh) 481GWh 11671GWh FR 495.5 TWh This graph allows us to assess the importance of cross-border commercial flows with respect to the total consumption of each country/region. 3 Ratio average cross-border capacity / installed generation capacity per country 1 In the conclusions of the Barcelona summit of March 2002 , the European council agrees the target for Member States of a level of electricity interconnections equivalent to at least 10% of their installed production capacity by 2005. The following table enables to monitor whether this ratio is reached. Interconnectors in the FUI Region Interconnectors are either operating, under construction or being contemplated within the FUI region or between the FUI region and other regions are shown below. Operational • IFA – Linking France to Great Britain - Operational Since 1986 • Moyle Interconnector – Linking Northern Ireland and Scotland (intra – UK) Operational Since 2002 Under Construction • Britned – Linking the Netherlands and GB – To begin Operation in early 2010 • East West – Linking Ireland and GB – To begin Operation in mid 2012 Table 1 Ratio between average interconnection capacities and installed generation capacity 2 France GB Ireland Export capacity / 3 generation capacity 11.9% 2.9% 0.71% 4 Import capacity / generation capacity 8.2% 2.5% 4% Source: CER, CRE, Ofgem, NIAUR First, it must be recalled that the computation does not distinguish the different production technologies. This means that one MW in wind generation has the same weight as one MW in nuclear generation. This table shows that none of the three FUI countries is complying with the 10% minimum level in the import direction. New interconnection lines are being built on the Irish-British border and a new interconnector between the Netherlands and GB is being developed as well. 1 http://ue.eu.int/ueDocs/cms_Data/docs/pressData/en/ec/71025.pdf 2 The export capacity is the hourly average D-2 NTC of all interconnections in the export direction. 3 The generation capacity is the total installed generation plants. 4 The import capacity is the hourly average D-2 NTC of all interconnections in the import direction. 4 Congestion management methods in the FUI region The France, Ireland and UK electricity REM is led by the British Energy Regulator (Ofgem) and aims to integrate the national markets in the three countries. Annual electricity consumption in the France, Ireland and UK electricity REM is about 780 TWh around 30% of the EU 25 electricity market. The focus of the work in the FUI region to date has been on transparency, ensuring compliance of the UK/France interconnector with the CMG requirements and harmonisation with other European borders and on access of the GB and French system operators respectively to each other’s balancing markets. At present, the FUI region contains the following national/cross national markets: French Market France has the second biggest wholesale electricity market in the European Union with volumes on the wholesale market (including cross border imports) amounting to 450 TWh a year in 2007 (accounting for 127% of French demand), with the majority of power (some 80%) being generated by nuclear power stations. The state-owned utility, Electricité de France (EDF), dominates the French market in both generation and supply sectors. Most wholesale activity takes place over the counter through bilateral contracts or through intermediaries, with the Powernext exchange facilitating day ahead (spot), intra-day and futures trading. After gate closure, RTE operates the balancing mechanism. The French market is highly interconnected market with total cross border flows in 2007 equivalent to 16% of domestic consumption. Nuclear plants typically generate at low marginal cost thus making France a significant exporter of power to its neighbours. In 2007, France exported 65.5 TWh and imported 10.4 TWh. France is market price coupled with Belgium and the Netherlands since November 2006. Powernext began operating intra-day markets in 2007 and in April 2009 Powernext and the German EEX power exchange merged their entire spot trading activities. BETTA The electricity market in GB is known as the British Electricity Trading and Transmission Arrangements (BETTA). BETTA is a self-dispatch, balancing market with average annual generation (including cross border imports/exports) of 350 TWh. Market participants are encouraged to self-balance before gate closure and are required to submit ex ante physical contract notifications on a half-hourly basis, one hour in advance of each trading half hour. Generators and suppliers who do not meet their contractual agreements are exposed to potentially penal system buy prices and system sell prices, both of which aim to reward participants whose imbalance contributes towards system balance and penalise those that move the system away from balance. 5 Most trading of electricity takes place either internally (since most generators in GB have broadly matching supply businesses), through over the counter (OTC) platforms or through direct ‘structured contracting’, with power exchanges such as APX, which caters for 5% of electricity traded. These power exchanges operate up to one hour before the physical delivery of power and constitute the GB day-ahead market. After that point, generation and demand are balanced by National Grid who act as the only counterparty to trades for the hour before real time and in real time itself. Transactions under this balancing mechanism account for less than 2% of electricity traded. National Grid is allowed to trade as a participant in BETTA so as to reduce its exposure to the penal prices of the balancing mechanism and has an incentive to do so. The BETTA market has relatively low levels of interconnection compared with other European markets, with current levels at 3% of consumption. SEM The SEM is the all-island electricity market for Ireland and Northern Ireland with average generation of 38 TWh a year. The SEM is a gross mandatory pool with day ahead gate closure into which bids are optimised over the whole day with an ex-post single market clearing price (SMP). Generators, including interconnector users, submit bids into the SEM by 10 am on the day before trading. The SEM is an ex-post market, with a significant time lag between the submission of offers and real time dispatch and the publication of market prices and quantities (though IC users are notified of their firm dispatch quantities two hours after gate closure). It is the scheduling and pricing software, in combination with bids by interconnector users, that determines interconnector flows. The SEM does not currently have a day-ahead market, one of the consequences of which is that users of interconnectors in the SEM have no indication of the SMP when it comes to settling their position in neighbouring markets. Furthermore the SEM does not currently allow for trading after gate closure. 6 a. General description of congestion management mechanisms Table 2 Publication of the rules for allocation and nomination procedures France – GB GB – France Website http://www.rtefrance.com/htm/fr/offre/telecharge/ifa_access_rules_definitive_issue_v6.pdf http://www.nationalgrid.com/NR/rdonlyres/5DEEDCE2-52FC-453C-988FF1973B9F696F/37205/IFAAccessRulesv7025September20091.pdf GB – Ireland Ireland – GB http://www.nienergyholdings.com/The_Moyle_Interconnector/Access_Arrangements.php Source: CER, CRE, Ofgem, NIAUR Table 3 Main features of allocation procedures France – GB GB – France GB – Ireland Ireland – GB Long term Explicit Auctions Explicit Auctions Medium term Explicit Auctions Explicit Auctions Dayahead Explicit Auctions N/A Intraday Balancing N/A Bilateral contrat between TSOs (BASA) N/A N/A Source: CER, CRE, Ofgem, NIAUR 7 b. Long and medium term capacities MAIN CHARACTERISTICS OF THE LONG & MEDIUM TERM CAPACITY RIGHTS: TRADABILITY AND FIRMNESS As for any commodity, the price that the market operators are willing to pay to obtain this commodity depends on the intrinsic characteristics of the product sold: the more reliable the product sold is (firmness, compensation in the event of curtailment, etc.) and easy-to-use (existence of a secondary market, nomination procedure, financial/physical nature, etc.), the more valuable it is. A secondary market is organized on IFA only. The bilateral transfer allows market participants to trade between themselves whole or part of a product, i.e. a product can be sliced down by steps of 1MW and of 1hour. The two resale possibilities allow market players to sell back the acquired capacities to the auctions held by the TSOs at a shorter timeframe (long term to medium term or long and medium term to daily). In this case, the whole product is proposed and it cannot be sliced down. Since the implementation of the new auction rules on IFA in October 2009, the long and medium term products which have not been nominated are automatically proposed at the concerned daily auction. The revenues generated by the resale of the non nominated capacities are given back to the initial holder. Table 4 Tradability and firmness: main characteristics of the long & medium term capacity rights Secondary market Bilateral transfers (i.e. reassignmen 5 ts) Resale of long to medium term Resale of long & medium term 6 to daily France – GB GB – France GB – Ireland Ireland – GB yes, on request Yes Yes, on request No No No Compensation for curtailments of allocated but not nominated capacities Based on the price paid according to the rules explain below(*) No (**) Compensation for curtailments of nominated capacities Compensation in case of daily auction cancellation Based on the price paid according to the rules explain below(*) No No (**) No Source: CER, CRE, Ofgem, NIAUR (*) For the 2007/08 period at the French-English border, the Products are not guaranteed to be firm, the capacities allocated for different products / periods of time have a target availability rate defined in the auction specifications. Also the Long-term and daily capacity is not nominated firmly: actors tell TSOs on D-1 if they intend to nominate acquired capacity. They can change their nominations at any of the six intraday gate closures, within the intraday transfer limits defined by the interconnection transmission system operators (RTE on the French side and NGET on the English side). On this basis, RTE and NGIL calculate, ex-post, the actual availability of each type of capacity for each market player. The impact of a reduction in long- or short-term capacity thus varies from player to player, depending on the types of capacity he holds and the nominations he has made. The TSOs then compare the rate of actual availability of capacity each player holds with the rate of target availability defined for every type of acquired capacity. 5 Please specify if there is an organized anonymous market, or if bilateral transfers are facilitated with the publication of the names of capacity holders, or if there are no specific arrangements 6 Please specify if the resale is on request or automatic (i.e. UIOSI) 8 If the actual availability at the end of the product period proves to be below target, holders are reimbursed by TSOs for the capacity shortfall, based on the price they had paid for the capacity. Conversely, when actual availability proves to be above target, capacity holders must repay the TSOs for the additional capacity made available. st This mechanism changed on the 1 of October 2009 with the implementation of the new IFA rules. Long and medium term capacities are now nominated firmly from 16h30 in D-2 until 9h30 on D-1. If curtailments occur before or after the nomination stage the capacity price will be reimbursed to the holders. It should be noted that the capacities are curtailed pro rata for all users in the following order: intraday capacities are reduced first, then the daily capacities and finally the long term capacities. (**) Capacity on Moyle is not firm. In the event of curtailment, by the system operator, there is no financial reimbursement for users. ORGANISATION RESPONSIBLE FOR ALLOCATION, SECONDARY MARKET AND NOMINATION TSOs concerned by a same border share the following different tasks: auction, resale and nomination. Table 5 Organization responsible for allocation, secondary market and nomination Annual auction Monthly auction Resale through subsequent auctions Bilateral transfer Nomination NGIL/RTE NGIL/RTE (nomination to one TSO only at a time) France – GB GB – France GB – Ireland Ireland – GB NGIL/RTE NGIL/RTE SONI SONI NGIL/RTE Source: CER, CRE, Ofgem, NIAUR 9 c. Day-ahead capacities st Until the 1 October 2009, a band of 24 hours were offered at the daily auctions. There are now products allocated on an hourly basis. There are no products allocated at the daily stage on MOYLE. Table 6 Main characteristics of the day-ahead capacity rights Secondary market Bilateral 7 transfers Resale of daily capacity to 8 intraday France – GB yes, on request Yes, on request Not applicable (NA) NA GB – France GB – Ireland Ireland – GB Compensation for curtailments of allocated but not nominated capacities Based on the price paid according to the rules explain above (*) Compensation for curtailments of nominated capacities Based on the price paid according to the rules explain above (*) NA NA Source: CER, CRE, Ofgem, NIAUR (*) see compensation mechanisms described under the long and medium term capacities section Under the new IFA rules, capacity allocated in the day-ahead auction that is not nominated is, in practice, lost for the holder due to the “Use-It-Or-Lose-It” rule. Day-ahead capacity rights cannot be or resold to the next timeframe (intraday) however transfers are allowed. Regarding firmness, day-ahead capacity rights are not firm the compensation is the same as the one described in the long and medium term capacities section. The application of the “Use-It-Or-Lose-It” rule between the day-ahead stage and the intra-day stage aims to incentivising market players to use all their capacity in the day-ahead timeframe. This can be explained by the importance of the day-ahead electricity market compared to the one of the intra-day market in terms of liquidity, number of participants... Table 7 Organization responsible for allocation, secondary market and nomination France – GB GB – France GB – Ireland Ireland – GB Daily auction Resale through subsequent auctions Bilateral transfer Nomination NGIL/RTE NGIL/RTE NGIL/RTE NGIL/RTE N/A N/A N/A N/A Source: CER, CRE, Ofgem, NIAUR 7 Please specify there is an organized anonymous market, or if bilateral transfers are facilitated with the publication of the names of capacity holders, or if there is no specific arrangements 8 Please specify if the resale is on request or automatic (i.e. UIOSI) 10 c. Intraday capacities In 2008, no intraday mechanism was in place in the FUI region. st Since the 1 of October 2009, the new IFA rules have implemented two explicit auctions to allocate capacities in the intraday timeframe. The first auction is held from 19h00 to 19h30 in D-1 and covers hours from 00h00 to 13h59. The second auction is held in D from 08h20 to 08h50 and covers hours from 14h00 to 23h59. Bilateral transfers in intraday timeframe have been implemented under the new IFA rules. d. Balancing exchanges The development of balancing trades between neighbouring countries is actively supported because these trades: - help to improve security of supply, - allow a reduction of the imbalance settlement price by providing the TSO with cheaper supplies and by increasing competition on the balancing market, - constitute a step towards the integration of the balancing mechanisms acknowledged as th necessary if the internal market in electricity is to work properly (conclusions of the 13 9 Florence Forum and European Commission Communication of 10 January 2007 ). Table 8 Organisation of balancing exchanges Cross-border procurement of reserves Cross-border balancing energy Model implemented: Fee to access TSO-TSO, TSOinterconnection Provider, regional capacity balancing market Emergency contract France – GB No TSO-TSO Yes Yes GB – France No TSO-TSO Yes Yes GB – Ireland Yes TSO-TSO Yes Yes Ireland – GB Yes TSO-TSO Yes Yes Source: CER, CRE, Ofgem, NIAUR Since March 2009, the “interim solution” of the BALIT TSO-TSO balancing model, that improves reciprocal access to cross border balancing services in England and France, has been implemented. 10 This allows TSOs to exchange six prices per day, compared to only one previously under the BASA contract. Regulators are currently reviewing experiences with the Interim solution with the TSOs concerned. Regulators will also approve the methodology for an appropriate remuneration scheme for use of the 9 COM(2006) 851 final 10 BASA BAlancing Services Agreement is an emergency contract from the French perspective but an TSO-TSO exchange model from an UK perspective 11 IFA infrastructure for balancing services as soon as they receive required information. It was expected that an “enduring solution” with more prices and greater automation should be finalised and implemented in November 2009. However, this has been delayed to November 2010 while a feasibility study on adding 2 hours balancing products within enduring solution is undertaken by the TSOs. On the Moyle Interconnector, NGC are currently putting in place a solution for a more developed form of SO-SO Trading, potentially allowing, firm trades day ahead for SONI. 12 2. Economic efficiency of congestion management methods a. Global figures Competition indicators This section compares the actual congestion income (i.e. the auction revenue), which reflects the market participants’ inclination to pay, with an indicator of the theoretical congestion income, whose 11 calculation is based on ex-post hourly price differentials between the national markets. Ideally, the actual congestion income should equal the theoretical (ex-post) congestion income. In reality, that is not generally the case, because of: - - the difficulty the market participants experience with forecasting day-ahead price differentials, and all the more so, for one month or one year ahead; the market participants’ preference for trades of longer-term products (such as baseload and peakload products of a day), along with the difficulty or even impossibility for the market participants to carry out arbitrage in hourly steps; economic failures in the interconnected markets (small number of participants, information asymmetry, size differences). Thus, the numbers presented in the following tables give an indication about the potential inefficiency of the congestion management methods. Moreover, an inter-temporal monitoring of the ratio between the real income revealed by market mechanisms and this theoretical congestion income could be useful to reveal congestion management mechanism failures, incompatibility between market designs, or lack of competition at 12 the interconnection. It could also be used to evaluate the impact of modifications of the interconnection access rules and changes in national market designs and to assess, whether, and to what extent, the process is evolving towards the establishment of an internal electricity market. Table 9 Actual and theoretical congestion rents Actual congestion rent or auction revenues (M€) France – GB GB – France GB – Ireland Ireland – GB 180,7 24,8 N/A Ex-post assessment of the congestion 13 rent (M€) 372,4 20,8 N/A Ratio actual / ex-post assessment of congestion rent 49% 119% N/A Source: CER, CRE, Ofgem, NIAUR 11 For the UK, peak and off-peak OTC prices published by Platts are used. 12 The monitoring of this ratio will be more precise if a distinction is made between the different timeframes according to which the capacities are allocated (see sections 1.b and c). 13 The theoretical congestion income for export from market A to market B is the sum of the whole interconnection capacity allocated (i.e. all the different timeframes taken together) multiplied by the price differential between the two markets, for all the hourly steps in the year when the market B price is higher than the market A price. 13 Table 10 Capacity holders and users France – GB GB – France GB – Ireland* Ireland – GB* Number of interconnection capacity 14 holders Largest 15 share Sum of the three largest shares 24 23 5 2 19 27 27 75 50 53 70 100 *These are annual figures Source: CER, CRE, Ofgem, NIAUR Prices attributed to interconnection capacities Allocation mechanisms by auction, whether explicit or implicit, mean that the value the market gives to interconnection capacities can be estimated. The average hourly price revealed by the auctions for each interconnection MW, for all timeframes, is 16 one way of comparing the various interconnections within the FUI region . Notably, it can be used: - within the perspective of investment in new interconnection lines; as an indication, the cost of constructing an alternative current interconnection line is 300 to 500k€/MW, and 600k€ to 17 800k€/MW for direct current ; - to improve the method used by TSOs for sharing export capacity on their borders Table 11 Prices attributed to interconnection capacities Average prices €/MWh €/MW France – GB 10,41 GB – France 1,45 GB – Ireland 8,50 Ireland – GB 1,16 Note: annual average rate GBP-euro used : 1.26 91 484 12 767 74,50 10.16 Total €/MW 104251 84,66 Source: CER, CRE, Ofgem, NIAUR Congestion level In order to investigate whether the interconnection is used in an efficient (i.e. coherent with the economic signal given by the price difference) way, it is useful to assess whether the net flow on the interconnector is coherent with the price spread. In addition, an indication is given about the level of use of the interconnector when the former condition is met. The first two columns of the following indicate when the use of the interconnection is coherent with a significant price differential and the level of utilisation of the interconnection capacity (partial utilisation versus maximum utilisation). Theoretically, in such a case, the interconnection should be used at the maximum. Potential reasons why that may be not the case are: lack of transparency, flexibility, the forecast errors of traders. The 14 This figure is the number of user companies whatever the relationship between them (for example : subsidiaries) 15 The largest share corresponds to the largest percentage of nominated capacities made by one user all products taken together. 16 The figures in the following table take into account all the revenues and all the allocated capacities at the different timeframes. 17 Estimations based on the most recent constructions. The total cost of interconnection infrastructure is likely to vary widely according to the length of the link, scale of the associated work (construction work on stations, upgrading of national links, dismantling of existing links, etc.), the nature of the environment (plains, mountains, etc.), and adaptation to planning constraints (landscaped pylons, burial, modification of the route, etc.). In addition, the commercial capacity available may be less than the technical capability of the link and fluctuates according to the change in flows on the grid. 14 last column of the following table indicates when the use of the interconnection (net scheduled flow) is not coherent with the economic signal given by the price differential. Table 12 Consistency of cross-border flows and price differentials Interconnection between France & GB Ireland & GB Percentage of time when the net scheduled flow is coherent with a significant price differential and 18 capacity is: not used at the maximum 47% Percentage of time when the net scheduled 19 flow is not coherent with the price differential used at the maximum 39% 10% Imports- 75%, exports - 60% Note -on Moyle IC only 25% of the variation in daily average imports can be explained by the variation in the daily average price differential over period 01/11/07 – 31/12/08 40% of the variation in exports can be explained by variations in the price differential 20 for this period 18 A price spread is assumed to be significant in this respect if it is greater or equal to a positive price spread of 1€/MWh. Moreover, the capacity taken into account for the computation corresponds to the nominated capacities of the sum of all products taken together. 19 The net scheduled flow is the difference between the nominations made in both directions; reductions or curtailments are taken into account. 20 In the absence of a day- ahead price and power exchange in the SEM, it is not at present possible to calculate this for the SEM – GB. The SEM is a gross mandatory pool with day ahead gate clsoure in which bids are optimised over the whole day with an ex-post single market clearing price that is calculated 4 days after the trading day. 15 b. Long and medium term capacities On all the interconnections within the FUI region, capacities are allocated on several different timeframes. The long-term products on offer are generally as follows: - long term capacity: a capacity band allocated for the whole of the next year (calendar year and business year are allocated; - medium term capacity: a capacity band is allocated for the next month, quarter or season (monthly quarterly or seasonal auctions); Holding long-term capacities is one of the main methods for market operators to gain a lasting position on a foreign market. In this regard, improving the quality of the products offered by the TSOs and maximising interconnection capacities are important challenges for developing competition and constructing the European electricity market. As for any commodity, the price that the market operators are willing to pay to obtain this commodity depends on the intrinsic characteristics of the product sold: the more reliable the product sold is (firmness, compensation in the event of curtailment, etc.) and easy-to-use (existence of a secondary market, nomination procedure, financial/physical nature, etc.), the more valuable it is. Market operators wishing to participate in long-term auctions can consider two price references in order to determine their willingness to pay for the capacity. On the one hand, if they are involved in long-term arbitrages, they can consider the price differential of forward products available on the day of the auction. On the other hand, if they are interested in shorter-term arbitrages, this initial value has to be supplemented by their estimate, for the period in question, of price differential volatility on an hourly, (or daily, weekly, etc.) basis. As National regulatory Authorities usually does not have access to these estimates, which differ for every market operator, this report considers the theoretical value of capacities, calculated ex-post, based on volatility of hourly price differentials. When the operators’ forecasts do not materialise, typically in the case of unexpected weather conditions (heat wave, very cold spell, etc), this value may be lower than the weighted average auction price. With this exception, the weighted average price revealed by annual (or monthly) auctions must, in principle, be: - at least the same order of magnitude as the price differential of annual (or monthly) forward products, observed on the date the auction is held; - lower than the theoretical capacity value, calculated ex-post based on the hourly price 21 differential between the organised markets throughout the year (or month) . 21 The theoretical value of the annual (or monthly) export capacity from market A to market B is the average of the price differential between the two markets over all the hourly steps in the year (or month) during which the market B price is higher than the market A price. 16 Table 13 Competition indicators for long term auctions Capacity sold (MW) Number of participant 22 s to the auction Number of capacity holders 17 12 France – GB 900 GB – France 900 17 11 GB – Ireland Ireland – GB 257 18 5 2 5 2 Ex-post Weighte Ratio actual / Forward assessme d ex-post price nt of the average assessment differential congestio price of congestion 23 n rent (€/MWh) (€/MWh) rent 24 (€/MWh) (*) 7,10 21,52 33% (*) 1,86 1,21 154% N/A N/A N/A Profit of participants realizing perfect arbitrages 25 (€/MWh) 14,42 -0,65 N/A Source: CER, CRE, Ofgem, NIAUR (*) Lack of the same reference between UK and France to define the forward price differential Table 14 Competition indicators for medium term auctions France – GB GB – France GB – Ireland Ireland – GB Average capacity sold (MW) Average number of participan ts to the auctions Average number of capacity 26 holders Weighted average price (€/MWh) 900 900 61 31 26 26 2 2 24 22 1 2 13,07 1,21 Ratio actual / ex-post assessme nt of congestio n rent 91% 398% Profit of participants realizing perfect arbitrages 27 (€/MWh) 4,85 0,06 Source: CER, CRE, Ofgem, NIAUR 22 This figure is the number of participating companies whatever the relationship between them (for example : subsidiaries) 23 The price differential is the one observed on the auction day and computed based on the results of the power exchanges or, if there is no such possibility, on the estimates based upon OTC trades. Given that OTC trades make up a large proportion of trades in the GB market, the price differential may be over-stated. 24 The theoretical value of the capacity for export from market A to market B is the sum of the interconnection capacity multiplied by the price differential between the two markets, for all the hourly steps in the year when the market B price is higher than the market A price. 25 This figure corresponds to the maximum profit that an actor that bought the same capacity every month could have earned. The average profit of participants realizing perfect arbitrages is the hourly average of the difference between the differential spot price if positive, zero otherwise - and the weighted average prices of the monthly capacities. 26 This figure is the number of user companies whatever the relationship between them (for example : subsidiaries) 27 This figure corresponds to the maximum profit that an actor that bought the same capacity every month could have earned. The average profit of participants realizing perfect arbitrages is the hourly average of the difference between the differential spot price if positive, zero otherwise - and the weighted average prices of the monthly capacities. 17 Secondary markets On some borders, there are secondary capacity markets, which enable the holders of long-term capacities to sell on or transfer their products. Two mechanisms coexist: - resale of capacities: long-term capacities can be sold on at daily auctions (at hourly time intervals), at the request of holders of capacities at least 2 days before day D (the original holder of the capacity then receives the daily auction price); similarly, annual capacities can be sold on in the form of a band, at monthly auctions; - transfer of capacities (or reassignments): the operators can trade long-term capacities bilaterally over a period of their choice (hourly time intervals). Table 15 Resale of annual capacities to monthly auctions number of operators using this service France – GB GB – France GB – Ireland Ireland – GB 0 0 N/A N/A proportion of operators using this service compared with the number of holders of long-term capacities 0 0 N/A N/A average capacity resold (MW) average share of long-term capacities 0 0 0 0 N/A N/A N/A N/A Source: CER, CRE, Ofgem, NIAUR Table 16 Resale of long and medium term capacities to daily auctions number of operators using this service France – GB GB – France GB – Ireland Ireland – GB 1 2 N/A N/A proportion of operators using this service compared with the number of holders of long-term capacities 3% 6% N/A N/A average capacity resold (MW) average share of long-term capacities 50 3% 76 4% N/A N/A N/A N/A Source: CER, CRE, Ofgem, NIAUR Table 17 Bilateral transfers of long and medium term capacities number of operators using this service France – GB GB – France GB – Ireland Ireland – GB 0 0 1 0 proportion of operators using this service compared with the number of holders of long-term capacities 0 0 20% 0 average capacity transferred (MW) average share of long-term capacities 0 0 0 0 42 15 0 0 Source: CER, CRE, Ofgem, NIAUR 18 The previous tables allow regulators to analyse the secondary market use and its importance. This enables us to see whether the actors really need those services and/or whether there exists difficulties in the use of those services. Although the secondary market for the IFA interconnection is free of charge for users, very few operators used this mechanism in 2008. The secondary market as it existed in 2008 on IFA interconnection allows the operators to resell or transfer to one another only 24-hour capacity bands (in accordance with the products sold on the primary capacities market). The lack of flexibility of the product, because of the impossibility of transferring or reselling capacities in hourly intervals, could explain why there was little interest among the operators in the resale mechanism on this interconnection. c. Day-ahead capacities The value of the daily capacities, hour by hour, should be viewed in relation to the hourly price differential between the markets. In reality, because the daily explicit auctions take place before the prices are fixed on the organised markets, those taking part in the auctions can only use estimates of the price differential, and this could partially explain the difference between the auction result and the price differential. This is one characteristic of the separation of the energy and transmission markets (allocation by explicit auctions). Table 18 Competition indicators Average capacity sold (MW) France – GB GB – France GB – Ireland Ireland – GB 149 122 N/A Average number of 28 participants to the auctions N/A Average number of capacity 29 holders 2 2 N/A Profit of participants realizing perfect 30 arbitrages (€/MWh) 6,73 0,81 N/A Source: CER, CRE, Ofgem, NIAUR Consistency of nominations with price differentials The following table should be read as follows: - the first column gives the annual average for nominations in the opposite direction to the price differential; - the second column, for the number of hours when the price differential was in a particular direction, gives the ratio of the number of hours during which the nominations were in the opposite direction; 28 This figure is the number of participating companies whatever the relationship between them (e.g. subsidiaries). 29 This figure is the number of user companies whatever the relationship between them (e.g. subsidiaries). 30 This figure corresponds to the maximum profit that an actor that bought the same capacity every day could have earned. The average profit of participants realizing perfect arbitrages is the hourly average of the difference between the differential spot price if positive, zero otherwise, - and the weighted average price of the daily capacities. 19 - the third column gives the annual average capacity not nominated in the direction of the price differential; - finally, the fourth column gives the number of hours during which the capacity was not fully nominated in a particular direction divided by the number of hours during which the price differential was in the same direction. Ideal use of daily capacities would correspond for each hour in the year to: - maximum use in the direction of the price differential: the rate of use of these capacities (nominated capacities divided by available capacities) should be equal to 1; - no use in the opposite direction to the price differential: the rate of use should then be zero. So the ideal use of capacities described above would therefore produce all zeros in the four last columns. Table 19 Consistency of nominations with price differentials Average capacity used in the opposite direction to the price differential (MW) 653 288 N/A N/A France – GB GB – France GB – Ireland Ireland – GB Proportion of hours concerned 75% 16% N/A N/A Average capacity Proportion not used in the of hours price differential concerned direction (MW) 402 98% 1559 100% N/A N/A N/A N/A Source: CER, CRE, Ofgem, NIAUR Table 20 Simultaneous nominations in both directions IFA MOYLE Number of concerned actors 11 Number of hours 3120 0 0 Average concerned capacity (MW) 68 0 Source: CER, CRE, Ofgem, NIAUR Table 21 Estimate of the loss associated with the absence of netting between long-term capacity nomination and day-ahead allocation The netting of long-term capacities allows for long-term capacity nominated in the opposite direction to be reallocated at the daily auctions. Netting is a requirement of Regulation (EC) No 1228/2003. Loss due to the absence of netting (M€) France – GB GB – France Netting not applied GB – Ireland Ireland – GB N/A N/A Total Total N/A N/A N/A Source: CER, CRE, Ofgem, NIAUR 20 Table 22 Day-ahead price convergence % of time where daily price differential is lower than 1 €/MWh 3% N/A Source: CER, CRE, Ofgem, NIAUR France & GB Ireland & GB Table 23 Estimate of the “loss in social welfare” associated with the absence of implicit methods 31 The “loss in social welfare” associated with the absence of market coupling between two borders is estimated as follows: for each hour, it is the product of the positive part of the price differential between the exchanges and the daily capacity that remains unused or is used in the opposite direction. This estimate should be considered with caution (see the inset below). However, it does at least give an idea of the scale of this loss of social welfare on each border. Within the region France – GB GB – France GB – Ireland Ireland – GB Loss in social welfare (M€) Total (M€) 50,12 24,88 75,01 N/A Total N/A 75,01 Source: CER, CRE, Ofgem, NIAUR Inset – Limitations of this estimate • The estimate assumes “all else being equal” and in particular it does not take account of the possible change in behaviour of the market operators in the organised markets following the introduction of market coupling. It is difficult to make an ex ante assessment of the impact of introducing market coupling on the buying and selling offer strategies of market operators in the organised markets. • The estimate does not take account of market resilience, i.e. the impact on prices of altering the volumes exchanged. Better use of daily capacities would lead to price convergence; the figures given in Table 13 are therefore the upper bounds of actual loss of social welfare, which can only be estimated precisely using aggregated curves of supply and demand on each market. d. Intraday capacities Access to cross-border intraday trades offers operators greater flexibility for balancing their position when coping with an unexpected event, and also enables them to engage in short-term arbitrages. In 2008, no intraday mechanism was in place in the FUI region. 31 Or loss of collective surplus. 21 e. Balancing exchanges Cross-border balancing reserves First indicators for the balancing cross border exchanges are whether it is possible at all to contract generation capacities abroad and the share it represents. Regarding the possibility of contracting balancing reserves abroad this depends firstly on the permission and secondly on technical or organisational feasibility according to the relevant national balancing and/or scheduling regimes. Reasons why this is not allowed or technically limited may be further investigated by regulators. Table 24 Cross-border balancing reserves Share of (secondary and tertiary) reserves contracted abroad (%) 0% 0% 0% Source: NG, RTE, SONI France GB Ireland Table 25 Exchange of balancing energy The following table gives information on the flows that occurred both in normal and emergency situations. The objective is to see to what extent actors or TSOs are active. In 2008, flows are all under the BASA contract. BASA allows TSOs to exchange one price per day. These flows are explained by the fact this contract is not used to the same extent, RTE use BASA as an emergency contract but NG use BASA as TSO-TSO exchange model. 32 France – GB 33 GB – France GB – Ireland Ireland – GB Cross-border balancing Upward Downward balancing balancing energy (GWh) energy (GWh) 235.5 0 0 61.7 N/A N/A N/A N/A Emergency contracts Upward Downward balancing balancing energy (GWh) energy (GWh) 0.05 0 0 1.18 N/A N/A N/A N/A Source: NG, RTE, SONI Table 26 Cross-border competition As shown in table 25, the amount of energy exchanged between France and GB is very small. Nonetheless, due to the size of the balancing markets, foreign market players, and in particular German and Swiss market players, represent a non-negligible source of competition within the French balancing markets. France GB Ireland Market share of FUI foreign market participants (upward balancing energy) 13% 0% N/A Market share of FUI foreign market participants (downward balancing energy) 12% 0% N/A Source: NG, RTE, SONI 32 As an upward offer is a flow to the country activating the offers and downward offer is a flow from the country activating the offers, these figures refer to UK TSO’s activation of French upward offers and RTE’s emergency activation of UK downward offers. 33 These figures refer to RTE’s emergency activation of UK upward offers and UK TSO’s activation of French downward offers. 22 Table 27 Unused interconnection capacity after intraday trade gate closure The following table gives information on the theoretically available capacity for cross-border balancing exchanges. It allows assessing whether there are considerable opportunities left. The available capacity is the average of daily NTCs netted by all previous exchanges (long term to day ahead). The second column indicates the percentage of hours when this remaining capacity is higher than 100 MW. France – GB GB – France GB – Ireland 34 Ireland – GB Average available capacity 580 2916 Percentage of time when available capacity is over 100 MW 35% 100% 371 98 Source: NG, RTE, SONI Table 27 shows that interconnection capacity available for balancing exchanges is not an impediment for developing cross-border balancing. Indeed, the available capacity unused after intraday gate closure is on average very significant and most of the time, depending on the interconnection, higher than 100 MW. Furthermore, it should be reminded that balancing needs and prices are not always correlated with day-ahead / intraday trades. Therefore, even if interconnection capacity was saturated on one direction, balancing exchanges could still be possible and valuable on the other direction. Table 28 Estimate of inefficiencies Table 28 details the information given in the previous table in computing the available capacities when the price signal is positive but low and positive and high. This allows us to better appreciate the potential to develop the cross-border exchanges. 36 France – GB 37 GB – France GB – Ireland Ireland – GB Percentage of time when interconnection capacity available 35 is over 100 MW and difference between upward balancing prices is over 2 €/MWh 26% 33% N/A Percentage of time when interconnection capacity available is over 100 MW and difference between upward balancing prices is over 50 €/MWh 16% 5% N/A Source: NG, RTE, SONI 34 During 2008 flows on the Moyle were low, from July to Oct the net flow on the interconnector was export from SEM. This current situation (August 09) is all capacity has been sold (410MW) and is being used. The connection agreement from Ireland to GB is 80MW, restricting exports to this level 35 Due to the unavailability of UK marginal prices, these balancing prices differences are calculated by the difference between UK imbalance settlement prices (500MWh marginal) and French weighted average price. 36 UK TSOs could have activated French upward balancing offers at a better cost 37 RTE could have activated UK upward balancing offers at a better cost 23 38 France – GB 39 GB – France GB – Ireland Ireland – GB Percentage of time when interconnection capacity available is over 100 MW and difference between downward balancing prices is over 2 €/MWh 24% 33% N/A Percentage of time when interconnection capacity available is over 100 MW and difference between downward balancing prices is over 50 €/MWh 4% 2% N/A Source: NG, RTE, SONI 38 As for downward regulation, electricity flow and merit order are reversed, this row means that RTE could have activated UK downward balancing offers at a better cost 39 UK TSOs could have activated French downward balancing offers at a better cost 24 3. Capacity calculation and management of cross-border flows The question of capacity levels is a very difficult one, and a major challenge for the development of the European energy market. The challenge in the short term is to optimise the use of existing infrastructure by making available to the market operators “the maximum capacity of the interconnections and/or the transmission networks affecting cross-border flows […], complying with safety standards of secure network operation” (Article 6(3) of Regulation (EC) No 1228/2003). On direct current interconnections such as the interconnector between GB and France, the full amount of capacity is offered to the market irrespective of transmission system conditions. If there is an equipment outage the maximum capacity less this amount will be made available however DC capability is not a function of the AC systems to which it is connected. In the longer term the challenge is to develop new transmission infrastructure. For regulated interconnector investment this requires coordination by the TSOs to identify investment needs, authorisation from relevant bodies to build the new lines and coordination how the investment should be financed. For merchant investment, exemptions must be sought and approved by the Commission for the investment to go ahead. a. Principles of the capacity calculation method by TSOs General capacity calculation procedure In the SEM, the Interconnector owner calculates the Available Transfer Capacity for each half hourly trading period in the trading day and this is published by 10.00am on D-2. 25 Table 29 Application of Use-It-Or-Lose-It and netting As a reminding, the so called “Use It Or Lose It” principle implies that long-term rights are lost if they are not nominated40 and the netting of long-term capacities allows for long-term capacity nominated in 41 the opposite direction to be reallocated at the daily auctions . Between long term capacity nomination and day-ahead allocation Between dayahead capacity nomination and intraday allocation UIOLI Netting UIOLI Netting NO NO NO NO NO NO France – GB GB – France GB – Ireland Ireland – GB Between intraday allocation and nomination UIOLI Netting NO NO NO NO NO NO Source: NG, RTE, SONI b. Net transfer capacity Evolution of the net transfer capacity The data given in the following table give insights about the way the NTC computed two days before the delivery day evolves compared to the previous years. The average permits to judge whether the capacity increase or decrease. The first and last deciles permit to understand whether the daily NTC evolve in a range close to the average and whether the average is close to one of those two thresholds. Table 30 Evolution of the net transfer capacity over time 2008 France – GB GB – France GB – Ireland Ireland – GB 2007 2006 Average NTC First decile Last decile Average NTC First decile Last decile 1912 1584 450( winter) / 410 Summer 80 mw 1500 0 2000 2000 1881 1805 450( winter) / 410 Summer 80 mw 1500 1500 2000 2000 Average NTC First decile 1835 1500 1821 1500 450( winter) / 410 Summer 80 mw Source: NG, RTE, SONI 40 In order to check whether the UIOLI is applied, the capacity offered at the sub timeframe (for example, day ahead) must take into account the capacity not nominated at the upper timeframe (for example, year ahead) Example: 50 MW sold in the year ahead auction and only 30 MW are nominated at a particular day: the day ahead auction for that particular day must .offer the ATC computed plus the 20 MW non nominated. The UIOLI is cumulative with the netting. 41 In order to check whether the netting is applied, the capacity offered in a direction in the sub time frame (for example, day ahead) must take into account the capacity nominated in the opposite direction in the upper time frame (for example, year ahead) Example: 50 MW of the year ahead capacities are nominated from A to B for a particular day. In the day ahead auction for that particular day, the capacity offered from B to A must offer the ATC computed plus the 50 MW nominated in the other direction. The netting is cumulative with the UIOLI. 26 Last decile 2000 2000 The previous comparison enables to know whether the net transfer capacity is stable for a year to another and whether within a year the net transfer capacity varies in an important way. This allows us to appreciate the difficulty for TSOs to allocate a high level of long-term capacities. Comparison between the NTC and the offers made at the long and medium capacity auctions The indicators computed in the following table are designed to give insights about the risk taken by TSOs in order to optimize the level of long- and medium-term capacities. The second and third columns enable us to see whether TSOs took actions in order to maintain the level of the allocated capacities and its level and whether reductions occurred and the duration over the year. The fourth and fifth columns allow comparing the yearly capacity allocated to the capacity that would have been allocated if specific measures (such as curtailments, counter-trading, buy back strategy by TSOs…) were applied less than 1% of the time in one month (about 8 hours in only one month). The sixth and seventh columns allow comparing the yearly and monthly capacities allocated along the year to the average capacity that would have been allocated if specific measures were applied less than 1 % of the time in every month (about 8 hours every month). Table 31 Comparison between the NTC and the offers made at the long and medium capacity auctions Average of Number of Minimum Number of the sum of Average hours Yearly first the yearly hours first where percentile capacity where and percentile counter– offered observed reductions monthly observed trading (MW) for one occurred capacities monthly occurred month offered France – GB N/A 900 1800 1800 1867 GB – France 900 1764 1800 1805 GB – Ireland N/A N/A N/A N/A N/A N/A Ireland – GB *Non available Source: NG, RTE, SONI Remark: Those figures enable to know the importance of countertrading actions undertaken by TSOs to guarantee the firmness of allocated capacities or nominations, as well as the occurrence of the reductions. They also enable to compare the offered capacities (yearly and monthly) to the level of capacity that could be made available with a small and arbitrary level of redispatching. Nevertheless, it should be highlighted that to be able to correctly assess to which extent TSOs are maximizing or not the level of long and medium capacities, further information would be needed regarding the cost of additional redispatching actions. c. Costs for ensuring the compatibility of the cross-border flows with grid security TSOs operating AC interconnectors regularly have to deal with situations where not all the long-term capacities they have allocated can be physically used, because that would jeopardise the safety of the grid. Five tools are potentially available for them to cope with these constraints are described below however they are not always applicable or available for TSOs operating DC interconnectors: - Repurchase of capacities by the TSOs: the TSOs could participate in the secondary market like any other operators, enabling them to buy back the “excess” capacity allocated to the market operators. For the TSOs this means outsourcing the management service of the secondary market, which has to be provided in the form of an anonymous organised market. At present this facility is not available to the TSOs. - Curtailment of the allocated capacities: subject to payment of compensation, holders of longterm capacities can have some of their transfer rights reduced. On the IFA long term rights 27 are not curtailed to maintain transmission system security, IFA curtailment only occurs where there is a capability reduction resulting from DC equipment failure. - Countertrading by the TSOs on D-1: the TSOs could use existing allocation mechanisms to trade in the opposite direction to the price differential, to remove the constraint. This would be particularly easy in a market-coupling situation because it is the TSOs who convey the trades, but this procedure is not used at present. - Redispatching: the TSOs can activate offers through the balancing mechanisms on both sides of the border, to lift the constraints. - Changing the topology of the grid: the TSOs can use phase-shifting transformers installed on certain lines to redirect flows on the grid in real time. It should be noted that this function isn’t available to DC interconnector operators. Not all these tools are equivalent or as effective as one another for dealing with the constraints. Repurchasing capacity and reducing capacity only work if the decision to do so is made far enough in advance – and in any case before the long-term capacities are nominated – as a preventive measure that helps to guarantee the safety of the grid. To the extent that they can only have an indirect impact on the physical flows, without any guarantee that the change this causes to the physical flows will actually lift the constraint, these tools cannot in any way be seen as last-resort curative solutions to guarantee the safety of the grid. On the other hand, since they have a direct impact on the physical flows and on the constraints, redispatching and changing the topology of the grid are the only effective curative actions to guarantee the safety of the grid approaching real time. All these tools have a cost for the TSOs: for example, installing phase-shifting transformers to change the grid topology amounts to a substantial fixed cost. Redispatching also has a cost, which is that of the offers activated in the balancing mechanism. These offers have to be activated in increasing price order so that, in accordance with point 1.3 of the new guidelines for Regulation (EC) No 1228/2003, the action taken by the TSOs is economically efficient. Table 32 Costs of ensuring compatibility of cross-border flows with grid security Redispatching and counter-trading costs (M€) France – GB GB – France GB – Ireland Ireland – GB N/A Compensation for curtailments (k€) No compensation N/A Compensation for auction cancellations No compensation N/A Capacity buying 42 back costs no formal buy back mechanism in FUI N/A N/A Source: NG, RTE, SONI d. Curtailments occurred in 2008 Table 33 Capacity curtailments France – GB GB – France GB – Ireland Ireland – GB Number of curtailments 207 1780 1 1 Average duration (h) 41 61 2 2 Number of impacted days 96 12 1 1 Average capacity curtailed (MW) 689 591 0 75 Source: NG, RTE, SONI 42 During 2008, the GB TSO bought long term capacity back from IFA users on a few occasions at a cost of £130,000. 28
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