Network Gas Supply Emergency Acceptances Guidance Note |
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Guidance Note: Network Gas Supply Emergency Acceptances
Where a BM Unit includes Generation plant which has been notified of a Load Shedding instruction from the Gas System Operator (GSO) during a Stage 2 or 3 Network Gas Supply Emergency (a “gas curtailment”), it is likely that that the BM Unit will be unable to generate, and, if the generator had already sold that power, the Lead Party of the BM Unit would be exposed to a potentially unmanageable Imbalance Charge, especially if the gas curtailment lasts for longer than just a few Settlement Periods. To mitigate this risk, the Load Shedding instruction will be treated as a type of Bid for BSC purposes.
Acceptance Data relating to these Network Gas Supply Emergency Acceptances (NGSEA) will be processed in two stages:
Directly following a Load Shedding Instruction, NGESO will construct a Bid Offer Acceptance(s) (BOAs) which reflect the effect of the Load Shedding instruction on the Generator and submit them into Settlement; and
At a time after the event, a Panel Committee will review all evidence provided by the Lead Party and any Subsidiary Parties to any BM Units impacted by the Load Shedding Instruction, and may direct further changes to Settlement data relating to those BM Units.
Initial Settlement of NGSEAs
A Load Shedding Instruction from the Gas System Operator will be settled initially as one or more Bids (NGSEAs).
This will ensure that the Lead Party and any Subsidiary Parties of a BM unit affected by a gas curtailment would not be subject to imbalance charges, which could be extremely large and so could result in those parties becoming insolvent.
NGESO will construct a BOA (or BOAs if the gas curtailment is sufficiently lengthy) to action the NGSEA, which will effectively bring the FPN for that BM Unit down from the submitted value to the revised level following the gas curtailment – usually this would be either ‘0 MW’ or the Stable Export Limit (SEL) for the BM Unit.
[Issue 105]The approved solution recognises that there may be an NGSEA issued to a power station for which NGESO is unable to construct a BOA (e.g. because it is part of a Supplier BM Unit that is not required to submit Physical Notifications). In this case the Bid cannot be included in the initial Settlement process, but BOA data will be constructed in the subsequent review of NGSEAs (described below), and entered into a later Settlement Run.
NGESO would use ‘best endeavours’ to submit each BOA to the SAA by the end of the second full working day after the initial Settlement Period affected by the gas curtailment (‘D + 2’), and no later than by ‘D + 3’, so that the BOA(s) will be processed in the Interim Information (II) Settlement Run for that Settlement Date, ensuring that no imbalance charges would accrue as a result of the BM Unit being unable to generate power sold before the gas curtailment.
Elexon’s credit-monitoring processes will not ‘know’ about the Acceptances until they are processed in the II Settlement Run. Prior to that, the Credit Cover Percentages for the affected Lead Party and/or Subsidiary Parties may increase, as Metered Data shows the BM Units were not generating. Elexon is obliged (in accordance with Section M3.4.3C of the BSC) to take the gas curtailment into account, and not authorise placing the Parties into Credit Default if any apparent shortage of Credit Cover is caused by the gas curtailment.
If, for any reason, BOA(s) could not be entered into SAA in time to be processed in the II
Settlement Run, Elexon would continue to ensure that the
Lead Party and/or
Subsidiary Parties were not inappropriately placed into
Credit Default as a result of the gas curtailment (as per BSC Section M3.4.3C). The BOA(s) would be loaded before the
Initial Settlement Run (SF), which would ensure that Parties were not invoiced for inappropriate Imbalance Charges as a result of the gas curtailment. The BOA(s) would be processed in accordance with Section 3.4 of
BSCP18 “Corrections to Bid-Offer Acceptance Related Data”.
Subsequent review of NGSEAs
After an NGSEA has been received and processed by the SAA, each BOA entered into Settlement will be reviewed by the Generation Curtailment Validation Committee (GCVC) Panel Committee. The scope of this review may include:
The Final Physical Notifications (FPNs) submitted by the Lead Party to the NETSO, which should (for the duration of the Load Shedding) reflect the power station’s contractual position prior to receiving the Load Shedding instruction. Where this is not the case the GCVC may direct changes to the FPN data used in Settlement. This could include changes to the FPN for the first three Settlement Periods of Load Shedding (where Gate Closure rules may prevent the Lead Party from ensuring that the FPN matches the contractual position);
The Bid Prices submitted by the Lead Party to the NETSO, which should (for the duration of the Load Shedding) reflect the saving in Avoidable Costs as a result of being unable to deliver the contracted power position. Where this is not the case the NGSESVC may direct changes to the Bid Prices used in Settlement. This could include changes to the Bid Prices for the first three Settlement Periods of Load Shedding (where Gate Closure rules may have prevented the Lead Party from updating their Bid Prices to reflect the impact of Load Shedding); and
The Acceptance Data submitted to Settlement by the NGESO.
The GCVC will be empowered to direct that changes be made to any P448 BOA, and also create data for power stations that received a Load Shedding instruction but were unable to submit FPNs or Bid Prices. Any such changes shall be entered into Settlement before the Final Reconciliation Settlement Run (RF) for the relevant Settlement Date. Please note that a post-SF amendment to a P448 BOA would not require a Trading Dispute be raised to implement it, unlike other Emergency BOAs which are processed in accordance with BSCP18.
What should I do if a power station in my BM Unit receives a Load Shedding instruction?
If a power station in your BM Unit receives a Load Shedding instruction, there are several things that you should do:
You must tell the market what’s happened through MEL re-declarations and REMIT notifications.
You must submit Physical Notifications that reflect the position immediately before the Load Shedding instruction was received, if you haven’t done so already (although it is recognised that Gate Closure may prevent you from doing so for the first three affected Settlement Periods).
Grid Code Modification GC0160 allows the Lead Party of a BM Unit affected by a Load Shedding Instruction to do this, rather than be required to submit Physical Notifications that reflect the position resulting from the Load Shedding Instruction.
[Issue 105]You should continue to submit appropriate Bid Prices, which for purposes of P448 means Bid Prices that reflect the saving in Avoidable Costs as a result of the power output being curtailed. It is recognised that Gate Closure may prevent you from updating your Bid Prices for the first three affected Settlement Periods.
You should contact
Elexon at the earliest opportunity by one of your Category A Authorised Persons sending an email to Elexon’s
Settlement and Invoicing Team (
Settlement.Invoicing@elexon.co.uk) and the
BSC Service Desk (
bscservicedesk@cgi.com). You will receive an incident number (in the format ‘REQUKnnnnnnnnnn’) in the automatic response from the Service Desk. Please quote this reference number in any correspondence regarding this.
Elexon will then liaise with you and the NGESO to agree the detail of the P448 BOAs which NGESO will issue to the
Settlement Administration Agent (SAA), as set out in the next section. This process and the information that you will need to provide is set out in in Section 3.5 of
BSCP18 “Corrections to Bid-Offer Acceptance Related Data”.
You must retain records as set out in BSC Section G6.1.2 i.e. such records as may reasonably be expected to assist the GCVC in performing its duties records, including:
relating to the volume of Active Energy bought and/or sold by the Lead Party at the Bid-Offer Acceptance Time for the Network Gas Supply Emergency Acceptance;
that demonstrate (or may allow theGCVCto infer) which BM Unit(s) the Lead Party would have used to deliver that Active Energy; and
that demonstrate (or may allow theGCVCto estimate) the Avoidable Costs that the Lead Party incurred or saved as a result of the Network Gas Supply Emergency Acceptance
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