1. Short Term Testing Mod 65_08 Modification Committee 25 th November 2010

2. Modification Objective  To modify SEM rules to allow Within-Day testing to be settled through SEM  Within-Day testing currently not considered in SEM, even though it provided for in Grid Code  Current workaround:  DIs with test flags issued in EDIL  DIs with test flags do not get sent to and profiled in SEM systems  This results Uninstructed Imbalance Payments by Generators  Modification is to remove this cost for generators © EirGrid & SONI 20102

3. Background  Mod 65_08 was submitted in November 2008  Mods meeting on December 1 st 2008: a working group was established  Two working group sessions were arranged during 2009.  The final working group report concluded that further investigation and discussion of the issues be investigated by SEMO and the TSOs.  An impact assessment was carried out  Changes to the original drafted Modification (V2)  Modifications Committee unanimously recommended for approval at Dec. 3 rd 2009 Modifications Meeting (#25)  Subject to further investigation of wording, full costs & implementation  Insufficient information available for FRR 3

4. Mod 65_08 Application for Short Term Test Status Application for Short Term Test status  Subject to approval by TSO  Generator does not make any submission to the Market Operator.  TSO approval for single contiguous number of Trading Periods in a single Trading Day is required.  Can be approved any time up until the end of the relevant Trading Day. Short Term Test status must:  Last at least 4 Trading Periods in a given Trading Day.  If spanning two Trading Days, be submitted for each Trading Day. Units under Short Term Test  Variable Price Makers, Variable Price Takers, Pumped Storage, Interconnector Units, Demand Side Units, IRCU and Autonomous Units cannot have Short Term Test status.  If Unit has Short Term Test status, it cannot be considered as Under Test. © EirGrid & SONI, 2009. 4

5. Mod 65_08 Submission and Publication Requirements Participant to provide  COD for all Price Maker Generator Units, even if they have Under Test status (allows for within day change to Short Term Test). TSO to provide (Ex-Post):  TEST dispatch instruction and TSTO dispatch instruction for each Generator Unit in the relevant Trading Day. o To the Market Operator by 14:00 on TD+1. o Market Operator to publish Short Term Test Notifications as submitted by the relevant TSO by 14:00 on TD+1. © EirGrid & SONI, 2009. 5

6. Mod 65_08 Impacts on MSP Software  Calculation of Availability and Minimum Stable Generation for Price Makers –Availability = Minimum Stable Generation = DQ during Short Term Test.  Calculation of Schedule Demand for Ex Post MSP Software Runs –Add Short Term Test status where ‘Under Test’ is referenced.  Calculation of MSQs for use in Settlement –MSQ=DQ during Trading Periods where a Unit has Short Term Test status. © EirGrid & SONI, 2009. 6

7. Mod 65_08 Impacts on MSP Software © EirGrid & SONI, 2009. 7 100 200 Short Term Test status 80 MSP Scheduling (between Min Avail And Max Avail) MSP Scheduling (between Min Avail And Max Avail) MSP Scheduling fixed to DQ during Short Term Test Trading Periods Availability Minimum Stable Generation Dispatch Quantity (DQ)

8. Mod 65_08 Settlement  No Start Up Cost recovered during Short Term Test period  No Make Whole Payments apply during periods of Short Term Test status  MSQ=DQ during Short Term Test period  Specific provision: MSQ for PPTGs equal to DQuh during Short Term Test period  Subject to Testing Charges during Short Term Test period  No Constraint Payments during Short Term Test period (as DQ=MSQ)  Eligible Availability set as normal © EirGrid & SONI, 2009. 8

9. Mod 65_08 Version 2 Definition of Short Term Test: May only occur where it is initiated and proposed by a Participant Eligible Availability: EA is set to the Availability Profile for the Generator Unit for duration of Short Term Test Only applicable to Predictable Price Makers and Predictable Price Takers TEST and TSTO dispatch instructions to indicate the start and the end of the Short Term Test period. © EirGrid & SONI, 2009. 9

10. Impact Assessments SEMO: In the region of €467k EirGrid and SONI: €60k approximately 10

11. Benefits of Mod 65_08: Grid Code caters for Within Day Test, but currently not provided for in SEM. Mod 65_08 would align SEM with Grid Code Avoid current workaround Avoid Uninstructed Imbalance Payments by Generators Submission of COD for Generator Unit Under Test Enable a generator to come off test in SEM earlier than the Unit Under Test End date with the relevant System Operator’s approval. Greater testing flexibility © EirGrid & SONI, 2009. 11

12. Thank you 12

13. Scenarios 13

14. Scenarios 1.Unit is on and reduces Output for Short Term Test 2.Unit is on and increases Output for Short Term Test 3.Unit is on and goes off for Short Term Test 4.Unit is off and comes on for Short Term Test only 5.Unit comes on for Short Term Test and stays on in market and dispatch 6.Unit comes on for Short Term Test and stays on in market but not in dispatch 7.Unit comes on for Short Term Test and stays on in dispatch but not in market © EirGrid & SONI, 2009. 14

15. Scenario 1 – Unit is on and reduces Output for Short Term Test © EirGrid & SONI, 2009. 15  Unit is on prior to Short Term Test.  Unit Output is reduced for Short Term Test period:  No Start-Up = No Start Up Costs.  No Make Whole Payments.  MSQ=DQ, hence no Constraint Payment.  Testing Charges due.  No issues with the Modification for this Participant- supplied Scenario. Output Time DQ=MSQ Short Term Test

16. Scenario 2 – Unit is on and increases Output for Short Term Test © EirGrid & SONI, 2009. 16  Unit is on prior to Short Term Test.  Unit Output is increased for Short Term Test period:  No Start-Up = No Start Up Costs.  No Make Whole Payments.  MSQ=DQ, hence no Constraint Payment.  Testing Charges due.  No issues with the Modification for this Participant- supplied Scenario. Output Time DQ=MSQ Short Term Test

17. Scenario 3 – Unit is on and goes off for Short Term Test © EirGrid & SONI, 2009. 17  Unit is on prior to Short Term Test.  As a result of test initiated by the Participant, the Unit goes off for Short Term Test period and returns at the end of the test:  Participant decision to go off for the Short Term Test, hence no Start Up Costs should be applicable.  No Make Whole Payments.  MSQ=DQ, hence no Constraint Payment.  Testing Charges due during Short Term Test.  No issues with the Modification for this Participant- supplied Scenario. Output Time DQ=MSQ Short Term Test

18. Scenario 4 – Unit is off and comes on for Short Term Test only © EirGrid & SONI, 2009. 18  Unit is off prior to Short Term Test.  As a result of a test initiated by a Participant, the Unit comes on for Short Term Test period and goes off at the end of the test:  Participant decision to come on for the Short Term Test, hence no Start Up Costs should be applicable.  No Make Whole Payments.  MSQ=DQ, hence no Constraint Payment.  Testing Charges due during Short Term Test.  No issues with the Modification for this Participant- supplied Scenario. Output Time DQ=MSQ Short Term Test

19. Scenario 5 – Unit stays on © EirGrid & SONI, 2009. 19  Unit is off prior to Short Term Test, with MSQ=DQ=0.  As a result of test initiated by the Participant, the Unit comes on for Short Term Test period:  No Make Whole Payments.  MSQ=DQ, hence no Constraint Payment.  Testing Charges due during Short Term Test.  Unit stays on in the market (MSQ>0) and physically (DQ>0), Start Up Costs not paid but no forced loss.  TSO may dispatch the Unit at the end of the Short Term Test as required. As already ON, no Dispatch Start will have occurred. Unit will receive Constraint Payments after the test, if applicable (MSQ ≠ DQ). Output Time DQ=MSQ Short Term Test

20. Scenario 6 – Unit stays on in market © EirGrid & SONI, 2009. 20  Unit is off prior to Short Term Test, with MSQ=DQ=0.  As a result of test initiated by Participant, the Unit comes on for Short Term Test period:  No Make Whole Payments.  MSQ=DQ, hence no Constraint Payment.  Testing Charges due during Short Term Test.  MSQ>DQ after test, hence constrained down.  After the Short Term Test period, the Unit is scheduled in the market (MSQ>0) and is dispatched off (DQ = 0).  TSO may dispatch the Unit at the end of the Short Term Test as required, including dispatching OFF. Unit will receive Constraint Payments (down in this case) after the test, if applicable. Output Time DQ=0 Short Term Test MSQ>0

21. Scenario 7 – Unit stays on in dispatch © EirGrid & SONI, 2009. 21  Unit is off prior to Short Term Test, with MSQ=DQ=0.  As a result of test initiated by Participant, the Unit comes on for Short Term Test period:  No Make Whole Payments.  MSQ=DQ, hence no Constraint Payment.  After test, Unit is dispatched up and will receive Constraint Payments – no Dispatch Start is relevant (no avoidable loss).  Testing Charges due during Short Term Test.  After the Short Term Test period, the Unit is scheduled off in the market (MSQ=0) and is dispatched by the TSO (DQ>0).  TSO may dispatch the Unit at the end of the Short Term Test as required. Unit will receive Constraint Payments after the test, as in this case (DQ>MSQ after test). Output Time DQ>0 Short Term Test MSQ=0

22. Outcome of Scenario Consideration  The definition of a Short Term Test:  May only be initiated by a Participant.  Agreed by the relevant System Operator.  If the System Operator requires to test a Unit from a Grid Code perspective, this will not be performed via a Short Term Test:  Dispatch Instructions will be supplied to match the required test.  If a Unit is required to start, a Dispatch Start will be paid (not a Short Term Test).  Unit will receive Constraint Payments if applicable. © EirGrid & SONI, 2009. 22