Proposed registration requirement on suppliers to facilitate generators CfD requirements

weedyhospitalΗλεκτρονική - Συσκευές

25 Νοε 2013 (πριν από 3 χρόνια και 6 μήνες)

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DRAFT


This should not be taken to represent DECC Policy


Proposed
registration
r
equirement
on suppliers to facilitate generators
CfD requirements


1.

This paper proposes
a solution to facilitate the correct registration for embedded generators with
CfDs and data flow of their metered output for CfD settlement purposes.


Context:


2.

To retain generation benefits,
(
independent
)

embedded
generators not wish to become a party
to
the BSC.

As such
an
e
mbedded generator

s
metering system is

registered on
the

BSC via a
licenced
supplier

on the Supplier Metering Registration S
ervice

(SMRS)
.
This registration process
allows them to engage in the trade of electricity on the Total System.


3.

Under t
his

arrangement
,
natural incentives

should exist for both
generator and supplier
:


a)

generator sells
output
to supplier

(in or outside of a P
ower
P
urcha
sing
A
greement (PPA)
)
at
wholesale price

b)

supplier sells
output
to retail customer
/
s

under supplier contracts

at retail price

c)

in line with their BSC requirement,
the
supplier
pass
es

on metered data
on behalf of their
embedded generator
to
the
BSC S
ettlement
A
gent

for settlement purposes
.


4.

However,
independent generators argue that
there is
currently
no requirement on t
he supplier

(
who may also be

i
ndependent)
,
to undertake activities outside of the BSC, including in the CfD
scheme.




Issue:

5.

In
order to support CfD settlement, suppliers will need to carry out registrations in a manner
consistent with CfD requirements

(placed on generators through their contract)
. This will include
the registration of an ‘Additional BM Unit(s)’ on the generator’s

behalf, and assigning them to the
generator’s metering systems
,

measuring
only gross input and gross
output from CfD assets
(rather th
an letting them default to the s
upplier’s Base BM Unit

or their Additional BM Unit(s)
registered for GSP Group purposes
).



6.

CfD contracts are
private law
,

bilateral
contracts
between
individual
low
-
carbon
generators and
the Counter Party body.
As such
Independent

g
enerators are worried that a
binding
requirement
does not exist
on suppliers
(
i.e. third parties)
outside of the
ir

existing
BSC obligations
to
register
m
etering
s
ystems and BM Units in a manner consistent with CfD requirements
.


7.

In this instance, suppliers may likely charge generators a fee to carry out this activity or reflect to
cost in the overall

PPA discount.

Proposed
Solution:

8.

DECC is minded that t
here
is sufficient
incentive
for supplier
s

to
facilitate CfD settlement



the
sustainability of the
ir

arrangement with the generator will in part depend on the generator
accessing CfD support.


9.

Generally speaking,

s
uppliers will broker a deal with the generator who can offer supply to
them
at lowest cost and at the quantity required.
Access to a CfD will ensure that l
ow carbon generators

will be in far better position to compete
on the market with their fossil
-
base
d competitors,

as the
ir

fixed strike price and top
-
up payments make their projects
both
bankable

and competitive
.




DRAFT


This should not be taken to represent DECC Policy


10.

However, it is e
qually in the low carbon generator’s best interest to facilitate such a deal (whether
it be with a supplier or directly
with the market) that will allow it to meet its CfD requirements.

Therefore issues associated with cost impacts should factor into a generator’s investment
decision.


11.

To facilitate the necessary separation and flow of metered output for CfD settlement in l
ine with
proposed metering arrangements for
BSC
-
trading generators
, the follow steps are
required
:

a.

Suppliers
will be
obligated
to register an “Additional BM Unit
(s)
” on
behalf of an
embedded
generator for CfD purposes.
The registration of this type of BM U
nit will
ensure that metered
output data is kept distinct and separate for CfD settlement; and

b.

The BSC Settlement Administration Agent (i.e. an agent of the BSC Settlement Agent) will
be ob
ligated to transfer finalised metered output

values for each settle
ment period (on
completion of all BSC collection, data aggregation and calculations exercises)
to the C
fD
Settlement Agent
.

Suppliers will not be required to facilitate the flow of data for settlement.


12.

DECC will work with the relevant bodies to undertake the necessary
BSC
code modifications to
ensure the above processes are possible.