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Energy Thursday: Redispatching anew – an update to the TNC

kancelaria prawo energetyczne Adam Madejski Senior Associate
31 lipca 2024
Energy Thursday: Redispatching anew – an update to the TNC

Polskie Sieci Elektroenergetyczne S.A. has published the IRiESP Update Sheet No. 2/2024, the most important element of which is the expansion of the provisions concerning the rules for introducing redispatch and the payment of compensation to generators for it. It is safe to say that the proposed amendment will have a positive impact on the increasingly used non-market redispatch, primarily by indicating the criteria for introduction and regulating the grid of terms. A new annex is also planned to comprehensively regulate the rules for calculating and paying compensation to generators subject to redispatch.

New definitions, clarification of premises

According to the update charter, several new definitions are to be introduced. This is important from a systemic point of view, since the ordering of the procedure for introducing redispatch first requires standardizing the understanding of the various elements and events in this procedure. The following definitions will be added:

        1. network constraints
        2. work plan,
        3. redispatch order,
        4. non-market redisposition,
        5. redisposed resource.

The update charter also implies clarifying the rationale for the application of redistribution vis-à-vis existing regulation in the Energy Law. The following conclusions follow:

  1. the basic rationale for triggering redispatch is the criteria indicated in Article 13 (3) of Parliament and Council Regulation (EU) 2019/943,
  2. redispatching is used to balance the supply of electricity with the demand for electricity or to ensure the security of operation of the electricity grid,
  3. non-market redispatching is allowed if market solutions would involve disproportionately high costs, at least twice as high as the costs of introducing non-market redispatching.

Redispatching may be direct – to entities connected to the transmission network, or indirect – to entities connected via distribution networks.

Criteria for applying redistribution

Update Sheet No. 2/2024 contains a detailed regulation of the process of issuing redispatch orders, from preparatory through executive aspects to evaluation.

First of all, a distinction is made between redispatching to balance supply and demand, and to ensure the safety of network operation. This is an important distinction, because in terms of the method of introduction, a different procedure will be used. For balancing demand with supply, the TSO should specify the duration of redispatch expressed in clock hours, for installations with a capacity of more than 200 kW individually, and for installations with a capacity of less than 200 kW collectively. The use of clock hour durations is to last until the end of 2025, to be replaced after that date by balancing energy settlement periods (OREB). In addition, the command will be able to be issued no later than 30 minutes before a given clock hour, and after 2025. – 15 minutes before a given OREB.

A very important solution proposed in the update charter is cost ranking, the purpose of which, in short, is to select generation resources against which the application of non-market redispatch will bring the least financial burden to operators. The following are to be taken into account:

      1. participation in support schemes,
      2. the content of the provisions of grid connection agreements,
      3. projected costs of unit non-market redispatch based on market data, prices from support schemes and prices of certificates of origin on the POLPX.

The update introduces explicit categorization in terms of priority for being subject to non-market redispatch – the order is to be determined by:

      1. energy law provisions introducing categories based on installed electric capacity – Article 9c (7c)(1),
      2. the unit cost determined by the cost ranking,
      3. the fact of inclusion in the obligation to have an active power regulation system.

Separate criteria have been formulated for electricity storage facilities – only those units that meet the following criteria together will be subject to non-market redispatch:

  1. is connected to the transmission network or to the 110 kV distribution network;
  2. has the ability to remotely control active power;
  3. is metered at least in terms of the level of charge of the MEE and the active power injected and withdrawn into the grid.

Of course, the update charter still introduces a number of additional procedures, including additional criteria, applied optionally by the TSO. Within the scope of this publication, however, it is impossible to describe comprehensively the entirety of the proposed changes.

Rules for calculating compensation

Appendix K2 to Update Sheet 2/2024 contains detailed rules for calculating compensation for non-market redispatch, depending on the technology of the generation unit – photovoltaic, wind power, biogas plants and electricity storage.

In addition to the regulations, which duplicate, in a sense, the energy law regulations, the following issues are worth noting:

  1. correspondence and the process of handling applications for compensation payments will be entirely electronic,
  2. an appendix will contain the data that should be included in the application for compensation depending on the type of generation source,
  3. it will be possible for the generator to question the correctness of the settlements made by the operator or for the operator to reject the compensation payment application – the complaint will be considered within 60 days,
  4. DSOs will be required to prepare monthly compensation reports, showing data on redistributions entered and compensation processed,

As for the method of calculating compensation for each type of installation, both for PV sources, wind sources and biogas plants, the method is based on the concept of the value of lost revenue, the amount of which depends on the prices of certificates of origin, participation in support schemes and the value of electricity not fed into the grid during the redispatch period. In this regard, the Annex introduces a number of formulas and formulas for calculating compensation – separate methods are to apply for each source.

Compensation for electricity storage owners is also based on the concept of lost revenue, but in this case the provisions are to refer explicitly to energy not sold due to the introduction of redispatch.

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Energy Thursday: Redispatching anew – an update to the TNC
31 July 2024

Polskie Sieci Elektroenergetyczne S.A. has published the IRiESP Update Sheet No. 2/2024, the most important…

kancelaria prawo energetyczne Adam Madejski Senior Associate
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