Stage 02:04: WorkgroupCode Administrator Consultation Consultation -Connection Volume and 3 Use of System Code Connection(CUSC) and Use of System Code (CUSC) What stage is this CMP213 Project document at? InitialInitial Written 01 Assessment 02 Workgroup TransmiT TNUoS Consultation WorkgrWorkgroupoup 03 Report Developments 04 Code Administrator Consultation Draft CUSC 05 Modification Report Final CUSC Consultation Responses 06 Modification Report Published on: 10th April 2013 Any Questions? Contents Contact: Adelle McGill 1. Workgroup Consultation Responses…………………………….…..3 Code Administrator About this document adelle.mcgill@ nationalgrid.com This document contains the responses to the Workgroup Consultation which took place between 07 December 2012 and 15 January 2013. 01926 653142 Proposer: Ivo Spreeuwenberg Document Control Company National Grid Version Date Author Change Reference 1.0 10 April 2013 Code Administrator Publication to Industry 1. Workgroup Consultation Responses CUSC Workgroup Consultation Response Proforma CMP213 - Project TransmiT TNUoS Developments Industry parties are invited to respond to this consultation expressing their views and supplying the rationale for those views, particularly in respect of any specific questions detailed below. Please send your responses by 15 January 2013 to [email protected] . Please note that any responses received after the deadline or sent to a different email address may not receive due consideration by the Workgroup These responses will be considered by the Workgroup at their next meeting at which members will also consider any Workgroup Consultation Alternative Requests. Where appropriate, the Workgroup will record your response and its consideration of it within the final Workgroup report which is submitted to the CUSC Modifications Panel. Respondent: Marc Murray e-mail: [email protected] phone: 0131 524 1431 Company Name: Aquamarine Power Please express your views Aquamarine Power is the technology developer of the Oyster regarding the Workgroup Wave Power technology, which captures energy from near shore Consultation, including waves and converts it into clean sustainable electricity. A rationale. Scottish company, based in Edinburgh, we were established in 2005 with a clear mission; to make marine renewable energy (Please include any issues, mainstream through rapid and responsible commercialisation of suggestions or queries) the Oyster wave energy converter technology. Aquamarine Power has secured to date, through its associated development company Lewis Wave Power and its Brough Head Wave Farm Ltd development partner SSE Renewables, grid capacity of over 240MW for a number of projects based on the Scottish Islands. In common with the majority of planned projects (>95%) in the nascent wave industry, cost competitive and viable island connections are intrinsic to establishing the long term potential of this emergent new source of reliable renewable energy. We believe that the CMP 213 objectives of competition, cost reflectivity and reflecting transmission developments has been too narrowly interpreted by the working group and fails to address some of the key challenges facing the emergent wave industry and more generally the Scottish Islands; specifically: • The narrow interpretation of competition fails to take into account how the actions proposed by the workgroup in both the original and amended versions will impact competition between various forms of electrical generation technologies. Both the original and amended proposals create an artificially high barrier to entry to the UK energy market for wave technologies. Fundamentally the proposals are handing an unfair competitive advantage to other generation technologies which are not locational dependent. • Cost reflectivity has been too loosely applied when considering island technologies to “normal” onshore connections, with island connections facing localised charges that would not be charged for an onshore connection. Again artificially raising the barrier to entry for island developments, including wave technologies. There need to be comparable treatment with wider assets. At the very minimum we agree with the suggestion that HVDC connection costs should be treated in the same manner as AC connections (i.e. removal of the HVDC elements that are not included in the locational signal for an AC transmission network) • In terms of reflecting transmission developments, the Scottish Islands have been categorised or treated the same as an offshore wind development (as they both need HVDC connections). We believe that this is unwarranted and that the charging arrangements for the Scottish Islands should be considered separately to the offshore connections. The Scottish Islands need to be treated as the exception to the rule, taking into account their special circumstances. The islands should be treated as a strategic asset that requires a connection solution that encourages renewable connections on the islands, rather than creating a barrier to development. The distinct message is that the CMP 213 has failed to find a solution to the Scottish Island connection issue; instead the proposals more generally raise the barrier to achieving a sustainable solution to connecting the islands. • Finally we believe that other fundamental considerations should have been taken into account, such as security of supply and sustainability, which, although key criteria for both National Grid and Ofgem, have been given much less weighting than the heavy focus on locational cost reflectivity. A long term cost effective solution needs to be identified for the islands (without reliance on temporary support mechanisms such as ROCs or capping), which the workgroup has failed to address. Do you believe that the As stated before we believe that both proposals are inadequate proposed original better to address the Scottish Islands solution; specifically: facilitate the Applicable CUSC (a) Both methodologies present an artificial barrier to wave Objectives? Please include technologies to effectively compete within the UK generation your reasoning. market, with the resultant effect of reducing the UK’s security of supply. (b) The locational element in both charging methodologies has effectively “double accounted” transmission assets for island connections – effectively over charging on locational elements – we disagree with the over emphasis on locational charging and specifically seek more elements of the islands connections to be socialised (recognising it as a national asset, rather than a company asset which an offshore connection would be) Do you support the proposed For the Scottish Islands elements, we do not support either implementation approach? If approach. Instead a more fundamental solution to the Scottish not, please state why and Islands connections needs to be implemented, including the provide an alternative consideration of socialising the HVDC connection as part of the suggestion where possible. wider UK asset infrastructure (i.e. being the exception to the rule that treat connections beyond the nearest MITS station as local works) Specific questions for CMP213 Q Question Response 1 Do you believe that the Workgroup No, we believe that the scope of the review was too has fully considered the range of narrowly interpreted by the workgroup. In essence all options for addressing how charging that was considered was how Scottish renewable and structures should be applied English base loads interacted, failing to address/ geographically to areas dominated investigate the impact of diversity of generation types. by one type of generation, including The amended version effectively heightens the barrier on local circuits? If not, what other to Scottish Island connections. options would you like the Workgroup to consider and why? In addition the ability of different generation technologies being able to share the same transmission infrastructure (e.g. wave and wind) based on the intermittency of the generation characteristics needs to be considered (particularly on the local island networks). Q Question Response 2 Do you believe that the Workgroup has sufficiently reviewed all the necessary options on how a sharing factor (i.e. ALF) could be calculated. Are there any areas that you think may need further development? If so, please specify along with an associated justification. 3 On the subject of whether intermittent generation should be exposed to a Peak Security element of the tariff, do you have any views in addition to those discussed by the Workgroup? 4 Do you consider that the Workgroup As question 1 has adequately set out and considered all relevant options and potential alternatives on the sharing aspect of this modification proposal? If not, what other options would you like the Workgroup to consider and why? 5 What are your overall views on how best to reflect the differential impact of generators with distinct characteristics on incremental network costs into the TNUoS charging methodology? 6 Do you believe that the Workgroup has considered all relevant options and potential alternatives for how the expansion factor (i.e. unit cost) for an HVDC circuit paralleling the AC network should be calculated for inclusion in the TNUoS charging calculation? If not, please provide suggestions with an associated justification. Q Question Response 7 Do you believe that the Workgroup has satisfactorily considered all the options and potential alternatives for how an HVDC circuit paralleling the AC network