SAFA RG CE - Comments on LFC&R Part A + B Articles

Contact
Andreas Walczuch
andreas.walczuch@amprion.net
Yannick Jonat
yannick.jonat@amprion.net
Lena Friedrichsen
Lena.Friedrichsen@p3-group.com
Markus Besser
Markus.Besser@p3-group.com

Description
This workbook lists comments received from several parties on the Policy on LFC&R Part A + B Articles
Framework Agreement (SAFA). The objective is to transparently show the status and response for eac

Versioning

Date Person Description

7/24/2018 Yannick/Lena Gathering and categorisation of comments on the
Policy on LFC&R Part A + B Articles
FC&R Part A + B Articles of Synchronous Area
us and response for each comment.

Commenting Phase
omments on the 9th July - 23rd July
s 2018
Received comments

Article Row number TSO Reviewer (please use email address)

All Document All Documents VUEN hubert.peter@vuen.at

Response to Public Consultation Swissgrid cherry.yuen@swissgrid.ch

A-1 (article) (dimensioning rules 74, 78 VUEN hubert.peter@vuen.at

for FCR)
A-1 (article) (dimensioning rules 42 50Hertz Torsten.benzin@50hertz.com
for FCR)

A-2 (article) (FCR additional 85 Terna temistocle.baffascirocco@terna.it

properties)

A-2 (article) (FCR additional 98 Terna temistocle.baffascirocco@terna.it

properties)
A-2 (article) (FCR additional 99 Terna temistocle.baffascirocco@terna.it
properties)

A-2 (article) (FCR additional 105 Terna temistocle.baffascirocco@terna.it

properties)

A-2 (article) (FCR additional Swissgrid cherry.yuen@swissgrid.ch

properties)
B-1 (explanatory note) (FRCE 50 - 51 ESO IKezhov@ndc.bg
target parameters)
A-2 (article) (FCR additional 91-92 Elia bernard.campion@elia.be
properties)

B-1 (explanatory note) (FRCE Table 2 ESO IKezhov@ndc.bg

target parameters)
B-1 (article) (FRCE target 69 PSE robert.trebski@pse.pl
parameters)
B-1 (article) (FRCE target 69 VUEN hubert.peter@vuen.at
parameters)
B-1 (article) (FRCE target General 50Hertz Torsten.benzin@50hertz.com
parameters)

B-1 (article) (FRCE target 73 50Hertz Torsten.benzin@50hertz.com

parameters)

B-1 (article) (FRCE target 72 50Hertz Torsten.benzin@50hertz.com

parameters)

B-1 (article) (FRCE target 50Hertz Torsten.benzin@50hertz.com

parameters)

B-1 (article) (FRCE target 69 RTE julien.gaudin@rte-France.com

parameters)
B-1 (article) (FRCE target 67 RTE julien.gaudin@rte-France.com
parameters)

B-1 (explanatory note) (FRCE 6 RTE julien.gaudin@rte-France.com

target parameters)

B-1 (article) (FRCE target 67 Elia bernard.campion@elia.be

parameters)

B-2 (article) (FCR exhaustion risk) 78 ESO IKezhov@ndc.bg

B-2 (article) (FCR exhaustion risk) 72 Terna temistocle.baffascirocco@terna.it

B-2 (article) (FCR exhaustion risk) 128 Terna temistocle.baffascirocco@terna.it

B-2 (article) (FCR exhaustion risk) 78 RTE julien.gaudin@rte-France.com

B-3 (article) (nomination of a 51 RTE julien.gaudin@rte-France.com

synchronous area monitor)

B-4 (article) (calculation of the 68 RTE julien.gaudin@rte-France.com

control program)

B-6 (article) (load-frequency- 133 ESO IKezhov@ndc.bg

control structure)

B-6 (article) (load-frequency- 153 - 154 ESO IKezhov@ndc.bg

control structure) 155 - 156
157 - 158
B-6 (article) (load-frequency- 174 - 175 ESO IKezhov@ndc.bg
control structure)

B-6 (article) (load-frequency- 176 - 177 ESO IKezhov@ndc.bg

control structure)

B-6 (article) (load-frequency- 67 RTE julien.gaudin@rte-France.com

control structure)
B-6 (article) (load-frequency- 135 RTE julien.gaudin@rte-France.com
control structure)
B-6 (article) (load-frequency- 154, 158, 168 RTE julien.gaudin@rte-France.com
control structure)
B-6 (article) (load-frequency- 103 Swissgrid cherry.yuen@swissgrid.ch
control structure)

B-6 (article) (load-frequency- 67 Elia bernard.campion@elia.be

control structure)
B-6 (article) (load-frequency- 135 Elia bernard.campion@elia.be
control structure)
B-7 (article) (methodology to 104, 140 RTE julien.gaudin@rte-France.com
reduce the electrical time
deviation)

B-7 (article) (methodology to 104, 140 Elia bernard.campion@elia.be

reduce the electrical time
deviation)
B-9 (article) (operational 108 Terna temistocle.baffascirocco@terna.it
procedure to reduce frequency
deviations)

B-9 (article) (operational 87-88 Terna temistocle.baffascirocco@terna.it

procedure to reduce frequency
deviations)

B-9 (article) (operational 129 Terna temistocle.baffascirocco@terna.it

procedure to reduce frequency
deviations)
B-9 (article) (operational 165 Elia bernard.campion@elia.be
procedure to reduce frequency
deviations)

B-9 (article) (operational 168 Elia bernard.campion@elia.be

procedure to reduce frequency
deviations)

B-10 (article) (roles and 144 PSE robert.trebski@pse.pl

responsibilities of Imbalance
Netting and cross-border FRR and
RR)

B-10 (article) (roles and 154 PSE robert.trebski@pse.pl

responsibilities of Imbalance
Netting and cross-border FRR and
RR)

B-10 (article) (roles and 151 PSE robert.trebski@pse.pl

responsibilities of Imbalance
Netting and cross-border FRR and
RR)

B-10 (article) (roles and 86 Terna temistocle.baffascirocco@terna.it

responsibilities of Imbalance
Netting and cross-border FRR and
RR)

B-10 (article) (roles and 128 Terna temistocle.baffascirocco@terna.it

responsibilities of Imbalance
Netting and cross-border FRR and
RR)
B-10 (article) (roles and 137-138 Terna temistocle.baffascirocco@terna.it
responsibilities of Imbalance
Netting and cross-border FRR and
RR)

B-10 (article) (roles and 101 RTE julien.gaudin@rte-France.com

responsibilities of Imbalance
Netting and cross-border FRR and
RR)

B-10 (article) (roles and 132 RTE julien.gaudin@rte-France.com

responsibilities of Imbalance
B-10 (article)
Netting (roles and FRR and 161
and cross-border RTE julien.gaudin@rte-France.com
responsibilities
RR) of Imbalance
Netting and cross-border FRR and
RR)

B-10 (article) (roles and 132 Elia bernard.campion@elia.be

responsibilities of Imbalance
Netting and cross-border FRR and
RR)

B-11 (article) (requirements 69-70 Terna temistocle.baffascirocco@terna.it

concerning the availability,
reliability and redundancy of the
technical infrastructure)

B-11 (article) (requirements 119-121 Terna temistocle.baffascirocco@terna.it

concerning the availability,
reliability and redundancy of the
technical infrastructure)
B-11 (article) (requirements 90-91 VUEN hubert.peter@vuen.at
concerning the availability,
reliability and redundancy of the
technical infrastructure)

B-11 (article) (requirements 77 RTE julien.gaudin@rte-France.com

concerning the availability,
reliability and redundancy of the
technical infrastructure)

B-12 (article) (common rules for 65 RTE julien.gaudin@rte-France.com

the operation in normal state and
alert state)

B-16 (article) (technical design of 57 ESO IKezhov@ndc.bg

the frequency coupling process)
Comment / Question (description as specific as possible, please)

Abbreviation "SO GL". The Regulation (EU) 2017/1485 is named a guideline on

electricity transmission system operation. Therefore the abbreviation "GL SO"
seems to be more appropriate.

We don’t agree to the standard response to stakeholders “FCR has the function
of a reserve of last resort and has therefore to be available also in cases where
FRR is not activated correctly”.
FCR is the “first” resort with relatively small amount of the fast control reserves
dimensioned for the relatively small frequency deviations and to support other
slower measures with much bigger amount. If all reserves are exhausted there
will be automatic load responses and forced load shedding. Therefore FCR is by
no means “last” resort. We would also like to point out that Swissgrid agrees
entirely what the Swiss stakeholder EKZ has written, in particular their last
sentence “Additionally we feel the existing grid codes for FRR are sufficient and if
enforced adequately will render reserve mode less relevant or obsolete
altogether”. The second part of the standard response “FCR has the function of a
reserve of last resort…” must be removed.
We don’t agree to the standard response to stakeholders “FCR has the function
of a reserve of last resort and has therefore to be available also in cases where
FRR is not activated correctly”.
FCR is the “first” resort with relatively small amount of the fast control reserves
dimensioned for the relatively small frequency deviations and to support other
slower measures with much bigger amount. If all reserves are exhausted there
will be automatic load responses and forced load shedding. Therefore FCR is by
no means “last” resort. We would also like to point out that Swissgrid agrees
entirely what the Swiss stakeholder EKZ has written, in particular their last
sentence “Additionally we feel the existing grid codes for FRR are sufficient and if
enforced adequately will render reserve mode less relevant or obsolete
altogether”. The second part of the standard response “FCR has the function of a
reserve of last resort…” must be removed.

The calculation of "electricity consumption" is not defined. I assume "total load"

according to Regulation (EU) 543/2013 Art.2(27) is meant with "electricity
consumption".
To avoid ambiguity the calculation of "electricity consumption" should be clearly
defined or the term "total load" with a reference to the definition in (EU)
543/2013 Art.2(27) should be used.
It is stated that this requires the approval of all NRAs, but that goes too far.
According to Art. 6 (3) (d) (ii) SO GL, the proposal under Art. 153 SO GL only
requires the approval of the NRAs from the affected region, in this case CE NRAs.
That should be clarified.

Terna kindly requests to change the sentence:

"shall provide technical evidence demonstrating why a longer time is needed"
into
"shall provide technical evidence TO THE RESPECTIVE TSO demonstrating why a
longer time is needed"

Rationale: for avoidance of doubts it shall be introduced in the text which entity
the power generating facility owner shall provide technical evidence
demonstrating why a longer time is needed.

Terna kindly requests to change the sentence:

"limited energy reservoirs shall not be considered as LER"
into:
"limited energy reservoirs shall not be considered LER as a whole"

Rationale: please consider that being a LER is a technical feature, not an

operational feature. E.g. a LER will need to shift its FCR activation in a point in
time, a non-LER won’t need to do so.
Please also consider that considering a LER “virtually a non-LER” implies the
possibility to bridge the law (e.g. art. 156.9) and allows storage system with e.g.
5min time period providing FCR. This is not acceptable.
Terna kindly requests to introduce, starting from the full-stop at the end of
sentence on row 99, the following:

"In fact, in case FCR providing units or FCR providing groups with LERs should
have to compensate a possible lack of energy and hence a lack of FCR they shall
be able to shift FCR avtivation to providing units or providing groups with
unlimited energy reservoirs. In any case the shifting of FCR avtivation shall
guarantee continuity of the FCR provision. By the way the technical entities with
limited energy reservoirs of the FCR providing unit or FCR providing group shall
respect the minimum time period of FCR full activation according to art. 156(9),
156(10) and 156(11) of the SO GL. "

Rationale:

"SHIFTING CONCEPT"
it is appropriate to leave unchanged the previous technical specification and the
concept of the “shifting” of the FCR provision as it constitutes a reference for
assuring the LERs provision’s compliance to normal state opeartions. Please also
consider that this topic was appreciated during public consultation (e.g. by
NUVVE and SmartEn) and that the SAOA team’s responses do not foresee any
change in this regard.

"GUARANTEE OF CONTINUITY"
This additional requirement is appropriate to ensure FCR provision continuity.
Please also consider that this topic was not questioned during public
consultation.

Terna kindly requests to change the sentence:

"The FCR provider shall ensure that FCR providing units or FCR providing groups
with limited..."
into:
"According to art. 156(9) of the SO GL, the FCR provider shall ensure that FCR
providing units or FCR providing groups with limited..."

Rationale: the clarification is needed to avoid any doubt: it is up to TSO to

decide, as SO GL mentioned, and not up to the FCR provider. By the way where
no period as been determined at least 15min applies.

Swissgrid looks forward to a consolidated version for further commenting.

Is it possible to provide some info how the factor 2.1898 is calculated?

Even if we understand the reasoning behind the requirement to take into
account possible under frequency load-shedding actions, we have concerns
about the practical implementation for BSPs and DSOs / TSOs to check for each
of their decentralized FCR providing unit or group if this unit / group is afected or
not by these frequency load shedding actions. We invite all other TSOs to think
about the enforceability of such requirement.

Is it possible to provide some info how the factors 1.0364 and 1.96 are
calculated?
the table should take into account the entries and divisions set out in the A-7
methodology and documents related to it
LFC-Block Name and belonging LFC-Areas should match the names in the All-TSO
LFC-Block determination proposal. (e.g: AT)
According to the wording of Art. 128 SO GL, this agreement is not a "proposal"
and, in my opinion, does not require any approval from the NRAs. Nevertheless,
the document still talks about "proposal" and "approval" in certain places, what
seem to be copy-paste errors. Furthermore, what is problematic is that even the
SO GL is inconsistent and also speaks of a proposal in Art. 118 (1) (d) SO GL.
Nevertheless, we should standardize the wording in the document and only
speak - as in the title - of the CE TSOs agreement.

The Publication does not take place according to Art. 5 SOGL, as described in Art.
4 of the Agreement. As it is not a proposal, it shall be published in accordance
with Art. 8 para. 2 (b) SO GL. That should be corrected in any case.

Article 4 (1) of the Agreement is incomprehensible in the sense that this

provision can be read as if the CE TSOs are using the majority voting pursuant to
Article 5 SO GL, what 50Hertz does not agree with. Since this is an agreement (in
the context of SAFA) and not just a proposal of a methodology, it cannot depend
on majority voting, but unanimity. Each TSO has to agree to the agreement,
otherwise it will not be reached. Article 4 of the agreement should be amended
accordingly.

The agreement itself lacks the provision that the determination of the values
takes place annually. It is mentioned in the preamble and then in the
Explanatory document, but that should be a rule of the contract itself, as
required in the SO GL.

to use the same TSO name in the table as for the proposal A-7
- It should be added that the target values are reevaluated every year based on
FCR obligation distribution.
- The methodology should be part of the main proposal (since this is the
methodology which should be approved not the results) and the way the results
are determined every year should be proposed.
- The table with the results should be updated and annexed every year,
otherwise we will have to vote on the entire policy every year for updating this
table.

For monitoring purpose, it should probably added the methodology for LFC
blocks with more than one LFC area. Should we publish one final table per LFC
area apliyng the distribution rule of the LFC block OA. In this case, each LFC area
will be monitored based on the same criteria. Or should we publish the table and
monitor it on LFC block level, in this case the way the LFC block assess the
criteria should be further described.

- It should be added that the target values are reevaluated every year based on
FCR obligation distribution.
- The methodology should be part of the main proposal (since this is the
methodology which should be approved not the results) and the way the results
are determined every year should be proposed.
- The table with the results should be updated and annexed every year,
otherwise we will have to vote on the entire policy every year for updating this
table.

Is it possible to provide a numeric example for this?

Terna kindly observes that the methodology does not include the "long lasting
frequency deviations events" as operational situations resulting in an
underestimation while assessing the risk of exhaustion of FCR.

Rationale: simultaneous occurrence of long lasting events and generation

tripping to be taken into account.
Terna kindly observes that the methodology does not enclose the contribution
of Limited Energy Reservoirs FCR providers to the Frequency Containment
Process within the risk assessment modelling.

Rationale: the risk of energy exhaustion and the consequent lack of FCR
provision should be taken into account.

to adapt the sentence to say "this is the methodology" even if written in

comprehensive way. Otherwise it seems there is a methodology described
elswhere.

The list of tasks taken over by SGSF should be added for avoidance of doubt.

proposal to add "for avoidance of doubt, the ramping period shall apply to any
change of control program", or to list all the cases: market, countertrading,
cross-border redispatch, balancing program interchange, offset in case of
extraordinary procedure.

What is the reason to choose 200 sec. as upper limit for integral time constant?

Please to synchronize the explanation text about LFC Input in Table 1 with
explanations about formulae 1, 2 and 3 from Operation Modes of the Frequency
Restoration Controller.
Is the 1 minute window a part of the 15 minutes window ? Does the 1 minute
window contain the highest average ACE? Is the 15 minute window movimg and
what is it step (1 or 15 minutes)? Let to solve the following case for CE: all LFC
areas are balanced and the frequency is 50 Hz. The LFC time interval is 1 second.
At the instant t1 150 MW generation is lost in i-th area. The frequency will drop
with 150 / 28000 ≈ 5.4 mHz. Let the K factor for i-th area is 377 MW / Hz. The
ACE for this are will be -(-150 -377*5.4*e-3) ≈ 152 MW. Let to accept also for
simplicity the ACE moves from instant t1 with ACE = 152 MW to instant t2 = t1 +
15 min with ACE = 0 MW with linear change. The highest 1 minute average ACE
will be 152 - 152*4.5/900 = 151.24 MW. The 15 minute ACE will be 152/2=76
MW. The difference will be 75.24 MW, corresponding to the minimum required
amount of aFRR. Is this correct?

Let to solve a similar case for CE, but with negative ACE: all LFC areas are
balanced and the frequency is 50 Hz. At the instant t1 150 MW load is lost in i-th
area. The frequency will rise with 150 / 28000 ≈ 5.4 mHz. Let the K factor for i-th
area is 377 MW / Hz. The ACE for this are will be -(150 +377*5.4*e-3) ≈ -152
MW. Let to accept also for simplicity the ACE moves from instant t1 with ACE = -
152 MW to instant t2 = t1 + 15 min with ACE = 0 MW with linear change. The
lowest 1 minute average ACE will be -(152 - 0.76) = -151.24 MW. The 15 minute
average ACE will be -76 MW. The difference will be -75.24 MW, corresponding to
the minimum required amount of aFRR. Is this correct?

to add the number to the figure

for consistency with B3, SGSF shall be replaced by "synchronous area monitor
according to B3"
formulas shall be aligned with variables defined in the table 1

Swissgrid proposes to have better clarification of the Coordinated FRCE

calculation in the Control Process diagram (Figure 2 on page 30) in the
description text. To be precise, the mandatory ACE arrow leading to the box of
this coordinated calculation is only mandatory when there is no coordinated
calculation.

The number of the related figure is missing in the sentence

for consistency with B3, "SGSF" should be replaced by "synchronous area

monitor according to B3"
to replace SGSF by synchronous area monitor

for consistency with B3, "SGSF" should be replaced by "synchronous area

monitor according to B3".
In addition, on row 104, for clarity, replace "starting at 0 a.m." by "starting at
00:00"
Terna kindly requests to delete the threshold of 375 MW since this is not an
oblication pursuant to Art.152(13) of the SO GL. Furthermore it is not a
prescription according to the extraordinary procedure in force for frequency
monitoring and countermeasures in case of large steady-state frequency
deviations.

Terna kindly request to align the suggested approach with the currently used
procedure. In particular, it's always the Coordination Centre to trigger Stage 2
and not single TSOs suggesting the Coordination Centre to trigger the Stage 2.
Furthermore, the contents of the Additional supplementing procedure for
activation of reserves for delayed retrofit TSOs are not reflected explicitly in the
Terna
SAFA. asks to we
Should change the sentence
consider "The Coordination
them included in the Stage 2?Centre shall record the
information…". In particular, substitute the word "record" with "take note" or
something similar. Otherwise the term "record" paves the way to many
interpretations.
for For instance,
consistency with B3, "SGSF"what kindbe
should of replaced
recordingbyis "synchronous
to be performed
areaby the
Coordination
monitor Centre?
according written recording? Phone recording? Other?
to B3"

For TSOs taking part to the cross-border aFRR energy exchange, the ajusted ACE
taking into account the activations for cross-border purposes might not be
known in real-time. Moreover, this value might be a bit approximative

Is the duration of the trail phase included in the duration of the whole process?
Since the trial phase covers "All TSO .." and not "Each TSO", there is a real risk
that the trial phase will last a long time due to the still attaching TSO

We are asking for clarification regarding the reporting process: should any
individual TSO be reported? If so, see the previous note.

We are asking for clarification of exactly what Additional Process is. Is this a
process other than mentioned earlier?

Terna would like to point out that limiting to write "Operational Security Analysis
" is very generic. Therefore, we propose to better specify by listing what has to
be contained (at least a condensed description of the minimum contents).

The sentence is unclear. Affected TSO should be able to define limits for the
exchange and sharing of reserves of other LFC Areas/Blocks (mostly
neighbouring TSO of Affecting TSOs should declare themselves as Affected
TSOs) , since it's the exchange and sharing of reserves of other TSOs that has an
impact on the Affected TSO. Therefore, Terna asks to check if the proposed
formulation is valid.
The terms "new process proposal" are not clear. Is this referring only to
"Additional processes" as reported in rows 103-112 and 151-157 or is referring
also to processes as Imbalance Netting, Cross-border activation of reserves,
Exchange and Sharing of reserves?
For the sake of clarity, we kindly ask to clearly state that the new process
proposal in line 137 does not refer to Imbalance Netting, Cross-border activation
of reserves, Exchange and Sharing of reserves.

to add "at least" three months in advance

to replace SGSF by synchronous area monitor

the sentence is not clear if we shall publish the proposal without undue delay or
if we shall list and publish the roles and responsibilities of TSOs already
performing imbalance netting,…
proposal is to rephrase clearly: "The TSO shall publish this proposal of roles and
responsibilities of..."

for consistency with B3, "SGSF" should be replaced by "synchronous area

monitor according to B3"

Terna would like to stress that with the establishment in the following years of
the European Platforms for the activation of reserves (aFRR, mFRR, RR) pursuant
to EB GL, the hot-stand-by-backup system should be foreseen for these
Platforms. Therefore we suggest to change the following sentence:
"A hot-stand-by-backup system must be available to take over the control
function in case of an outage or fault of the main system."
into
"A hot-stand-by-backup system must be available for all European Platform
performing a cross-border FRR and RR activation process, to take over the
control function in case of an outage or fault of the main system."

Terna would like to ask why TSOs "shall publish the requirements concerning the
availability, reliability and redundancy of the technical infrastructure proposal".
Unless an already existing obligation is force, we suggest not to publish such
sensible information and then to remove the lines from 119 to 121.
The text "Substitute measurements and reserve equipment shall be available in
parallel to the primary measurement and substitute measurements." is a
tightening of the requirements compared to the existing OH Policy 1 where
substitute measurements are obligatory for all TIE-LINES with significant impact
to SECONDARY CONTROL. Is this intentional and in any case feasible, eg. in case
of lower voltage tie-lines (< 110 kV)?
Furthermore the meaning of "...available in parallel to the primary measurement
and substitute measurement" is unclear. Does that mean it is required to have a
primary measurement with a substitute measurment and reserve equipment
and a further substitute measurement also with primary and subtitute
measurement and reserve equipment?
I propose to delete "and substitute measurements" at the end of the sentence
to avoid misunderstandings.

to adapt "frequency measurements available in real time from at least two

different geographical locations available within the LFC area"

the sentence is not clear. Maybe to split the sentence into two phrases:
All common rules for the operation in Normal State and Alert State reflect the
target of load-frequency-control to reduce frequency deviations. Those rules
refer to the operational procedures to reduce frequency deviation according to
B-9 Operational Procedures to Reduce Frequency Deviation.

I didn't find the word "compensation" about the providing synchronous area
neither in 173(3), nor in 153. Could you please to comment what has to be
compensated (is this some back-up process)?
Processing comments

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Comment / Clarification / Justification

SO GL and GL SO can and have both be used vice versa. NRAs did not ask to change SO GL
into GL SO for already submitted proposals, so the drafting team also stays with SO GL in this
project

“FCR has the function of a reserve of last resort…" has been removed.

The expression "electricity consumption" is used in the Entso-e web, and used by the Data
Expert Group, and published in the Power Statistic web.
The mentioned text (SUBMIT THE FOLLOWING FCR DIMENSIONING RULES PROPOSAL TO ALL
REGULATORY AUTHORITIES:) was provided in the original template (and is common for all
the rest A articles), if the legal team considers necessary can be changed, however, be aware
that article A7 has been already sent to the NRAs.

Suggestion accepted

Suggestion accepted
Suggestion accepted, "in fact" will be deleted

Suggestion accepted

Acknowledged

Adjusted in the explanatory note

The intention of the formulation was to leave some room on how to implement it.

Adjusted in the explanatory note

Names and abbreviations adjusted acoording to A-7.

Names and abbreviations adjusted acoording to A-7.

Adjusted to CE TSOs Agreement on FRCE target parameters

Adjusted to Article 8 (2) of SO GL

Article 4 has been redrafted . Reference to Art. 5 SO GL has been deleted.

Adjusted

Names and abbreviations adjusted acoording to A-7.

The comment was discussed with the respresentative in drafting team from RTE. Drafting
Team conculded that Article 128 (1) of SO GL requires to specify the values for the
FRCEquality target parameters.

The distribution of FRCE quality target parameters of LFC blocks to the LFC areas is a part of
the LFC block operational agreement. Article 118 (1d) of SO GL requires only the definition of
these parameters on LFC block level.

The comment was discussed with the respresentative in drafting team from Elia. Drafting
Team conculded that Article 128 (1) of SO GL requires to specify the values for the
FRCEquality target parameters.

Several studies were performed by the SG SF, evaluating not only the suitability of this
methodology, but also the sensibility of the input data.
The fully study can be found in the following link in the Entso-e SharePoint .
https://extra.entsoe.eu/SOC/SF/_layouts/15/WopiFrame.aspx?sourcedoc=/SOC/SF/Shared
%20Documents/171122_TOP_9.1_FCR.pptx&action=default

Long lasting frequency deviations were not explicitily mentioned in the wording, but indeed
they are implicity considered in the model, as the real distribution of frequency deviation is
used.
This methodology assumes a correct deployement of FRR, so after an imbalance (for
instance, due to the trip of a generator, changes in demand, or in renewables) the FRR shall
take over the FCR in 15 minutes (Time to restore frequency), which is the minimum possible
values of the availability for LER units.
This hypothesis is essential, and we have to reflect it somehow, as otherwise we are
transferring cost to the FCR units.

Adittionally, in the case of long lasting frequency deviations, in order to consider the
contribution of LER, would be necessary:
1º) to estimate the % of LER in the system (agreed on this values is difficult, and has
a high impact on the final result).
2º) to add possible remedial actions as defined in the Extraordinary procedure.

Modelling both variables is complicated (specially remedial actions), and an error in the their
estimation could lead to wrong results.
Finally, SG SF after long discussions agreed on not consider the effect of LER.

The question on a potential improvement of the methodology (e.g. incl. LER in the context of
long lasting frequency deviations) will be raised again in the SG SF. As of now the according
methodology experts from SG SF concluded that the methodology can't be improved even
further. The answer and the action related to the comment in row 72 cannot be accpted by
Terna

Done

The list of tasks is regularly being specified between the synchronous area monitor and SG SF
on request and should not therefore not be predefined. An according precision has been
added to the article

Good suggestion. Article was adapted as proposed.

These are typical values for indication. It should not be considered as upper limit for integral
time constant.
The value of 200 sec. is coming from the former Policy 1.
intention was not to rediscuss theses values and keep it exactly the same from former Policy
1.

Improvement accepted. The table and formulas are aligned.

Answer is No. the distribution should be on 1min resolution and not on 15min resolution.
Clarification was added to the document:
it is about calculatin the difference per minutes, of the 1min-average of ACEol and the 15min
average of ACEol of the corresponding quarter of hour (see footnote No. 4).
Definition of quarter of hour is the same as for the FCR risk methodology

Answer is No. the distribution should be on 1min resolution and not on 15min resolution.
Clarification was added to the document:
it is about calculatin the difference per minutes, of the 1min-average of ACEol and the 15min
average of ACEol of the corresponding quarter of hour.
Definition of quarter of hour is the same as for the FCR risk methodology

Added to the document

modified in the document

see comment 32

clarification was added to the text with a footnote added to the figure about the mandatory
arrow

see comment 35

see comment 36

sensible suggestion.

sensible suggestion.
Reference to Art. 152(13) deleted as this is not an obligation in context of Art 118(1)(n). The
threshold itself will be kept as it is only used in combination with declared alert state as
indication of the potential impacting TSO

there was a request to allow for a direct trigger in case of emergency; the procedure
concering delayed retrofit was explicitly requested to be not included in B-9 but just implicitly
as part of “Activation of additional mFRR or RR” (due to all this discussions and different
views on the procedure…). Nevertheless, current formulation allows to activate the
supplementary procedure under Stage 2 and should therefore be in line with Terna’s view
"record" replaced by "take note"

done

Real time ACE has been deleted

replaced "All TSOs" by "The relevant TSO"

yes, the task is valid for each TSO individually

yes, this is a process other than mentioned earlier. Every new process with cross-border
relevance should have been notified to CSO as current practice before implementation

Operational Security Analysis is a SOGL definition and is therefore used. Reference to SO GL

definition has been added to article

Wording changed in a way that limits can be requested in general

yes, this is a process other than mentioned earlier. Every new process with cross-border
relevance should have been notified to CSO as current practice before implementation

"at least" added

replaced SG SF by Synchronous Area Monitor

general change of all article 4 of all B articles according to guidace of legal expert team

replaced SG SF by Synchronous Area Monitor

Good remark. This hot-stand-backup is indeed necessary. It is foreseen in the PICASSO

project.
I adapted the Article in order to take your suggestion into account: "The Frequency
Restoration Controller of aFRR shall be operated on-line and shall have a very high reliability.
The tools for activation of mFRR and RR shall be operated on-line and shall have a very high
reliability as well. A hot-stand-by-backup system must be available to take over the control
function in case of an outage or fault of the main system. This requirement applies as well
for all European Platform performing a cross-border FRR and RR activation process."

Solution found via bilateral agreeement between Terna and Bernard. No change in article.
Formulation of MLA OH was used. Measurement requirements have been precised.

Good proposal. The sentence online 76-77 was modified as follows: "For each LFC Area of CE
synchronous Area, the related TSO shall have frequency measurements from at least two
different geographical locations available within this LFC Area."

suggestion implemented

Formulation was missleading and has been adjusted according to wording in article 173(3)
Change in Article Status Article Owner

No done all

no done all

No done Alberto Gil

No done Alberto Gil

Yes done Alexander Stimmer

Yes done Alexander Stimmer

Yes done Alexander Stimmer

Yes done Alexander Stimmer

No done Alexander Stimmer

yes done Axel Grüneberg (Tennet)

no done Alexander Stimmer

yes done Axel Grüneberg (Tennet)

yes done Axel Grüneberg (Tennet)

yes done Axel Grüneberg (Tennet)

yes done Axel Grüneberg (Tennet)

yes done Axel Grüneberg (Tennet)

yes open Axel Grüneberg (Tennet)

yes done Axel Grüneberg (Tennet)

yes done Axel Grüneberg (Tennet)

no done Axel Grüneberg (Tennet)

no done Axel Grüneberg (Tennet)

no done Axel Grüneberg (Tennet)

No done Alberto Gil

Yes done Alberto Gil

No done Alberto Gil

Yes done Alberto Gil

yes done Andreas Walczuch

yes done Bernard Campion

no done Julien Gaudin (RTE)

yes done Julien Gaudin (RTE)

yes done Julien Gaudin (RTE)

yes done Julien Gaudin (RTE)

yes done Julien Gaudin (RTE)

yes done Julien Gaudin (RTE)

yes done Julien Gaudin (RTE)

yes done Julien Gaudin (RTE)

yes done Julien Gaudin (RTE)

yes done Julien Gaudin (RTE)

yes done Cherry Yuen (Swissgrid)

yes done Cherry Yuen (Swissgrid)

yes done Alexander Stimmer

no done Alexander Stimmer

yes done Alexander Stimmer

yes done Alexander Stimmer

yes done Alexander Stimmer

yes done Jan Cernohorsky

no done Jan Cernohorsky

no done Jan Cernohorsky

yes done Jan Cernohorsky

yes done Jan Cernohorsky

no done Jan Cernohorsky

yes done Jan Cernohorsky

yes done Jan Cernohorsky

yes done Jan Cernohorsky

yes done Jan Cernohorsky

yes done Bernard Campion

no done Bernard Campion

yes done Bernard Campion

yes done Bernard Campion

yes done Alexander Stimmer

yes done David Whitley

TSO # comments
ESO 8
PSE 4
Terna 14
VUEN 4 #
50Hertz 5
RTE 15 Elia; 8
Swissgrid 2
Elia 8 Swissgrid; 2
Energinet 0
Mavir 0
Tennet 0
SUM 60

RTE; 15

50Hertz;
 # comments
Elia; 8 ESO; 8

Swissgrid; 2
PSE; 4

RTE; 15
Terna; 14

50Hertz; 5 VUEN; 4