Procurement Plan – Comments Table Participant: Genesis Power
Issue/Comment The rule reference at the end of this “rule 4.11.1.1A” is incorrect. Suggested solution/wording Should be 4.11.5.1.
Rule/Clause Assessment methodology for frequency regulating reserves clause 30 Right to terminate clause 54
Limitation of liability clause 56
Genesis understands that the System operator would like certainty to the length of any ancillary service contract. But we also believe that there can be other reasons for wishing to terminate a contract other than changes to EGR’s. This clause in an unintelligible dog and should be shot a dawn. I guess I should really say: This clause does not allow for an easy read nor convey any clear message.
Allow a termination of contract clause with enough time to allow the System Operator to re-procure that service. Genesis suggests 3 Months would be an appropriate length of notice for termination. The liability of either the System Operator or the Ancillary Service Agent to the other for obligations arising under this (/the) ASP contract that also arise under the rules and Regulations shall be limited to the liability (including limits on liability) as provided in the rules and Regulations. The liability of either party to the other for obligations arising under this (/the) ASP contract (that do not arise under the rules and Regulations) is as set out below. The second reference to “ancillary service agent” should be changed to “System Operator”. The order of priority to allow quick removal of barriers to these markets should be;
Clause 59
Comment on competitive
Ancillary service procurement contract is bilateral, therefore ancillary service agent cannot have liability to itself Genesis believes that the order of priority of these initiatives needs to be changed a little.
Genesis Submission re Ancillary Services Procurement Plan
pressures and degree of market innovation involved Clause 68
Item 4, 1&3, 5, 2 Item 2 While AGC has always been seen by the System Operator as the holy grail, Genesis believes that there is a significant amount of work to be done to allow block dispatch groups to be AGC controlled. Having implemented the direct feed of dispatch instructions into the governors at Huntly we know that when cold units are starting, low ramp rates can and do have significant problems. To this end our units are not selected to auto dispatch until they are full ramp capable. To exclude non AGC controlled plant from the frequency keeping role would remove both of Genesis block dispatch groups from the frequency keeping market. Item 4 On the other hand, to allow multiple non-AGC controlled plant to perform the frequency keeping role would remove barriers to market. Genesis has pioneered cross station frequency keeping during the last three years using both thermal/hydro and hydro/hydro combination to provide the service. During one instance when Huntly was not removed from service as dispatch for 1 hr, all three of our sites shared the role with no effect on frequency quality. We believe that there should be tests conducted under the supervision of the System Operator to demonstrate the ability to cross share between
Genesis Submission re Ancillary Services Procurement Plan
Genesis and other North Island frequency keeping providers to prove this concept. We do not see why three or four stations can not be providing this service at once in the North Island. Item 3 and 1 Provided the technical issues with the HVDC being either the binding contingent or extended contingent risk can be solved, Genesis supports the move to single markets for reserve and frequency keeping. Genesis supports the ongoing improvement to SPD and RMT. In particular we believe there is an opportunity to extend the optimisation to include Frequency keeping. As detailed above (Ref clause 68) Genesis believes that there are a number of technical issues to be discussed by the industry as a whole before we could support the move to full AGC control. Does the reference to price mean that the by ½ hour clearing price of the frequency keeping market will be advised to the board and therefore be published to the market. If so Genesis supports this initiative. One of the functions of an open and transparent market is the publication of the price. The frequency market as it stands does not have the necessary function. The wording of this clause leads Genesis to believe that each unit must have a 10MW/minute ramp rate.
Clause 69 and 70
Allow the co-optimisation of energy, reserve and frequency keeping together.
Clause 71
System Operator reporting to the board Clause 72.1
Publish to the market the ½ clearing price for frequency keeping.
A1 Frequency Regulating Reserve Clause 76.1
Change “that each have” to “where each site has”
Genesis Submission re Ancillary Services Procurement Plan
Genesis Submission re Ancillary Services Procurement Plan