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Article Row TSO Reviewer Comment / Question (description Category Comment / Clarification / Justification Change Status Article
number (please use as specific as possible, please) in Article Owner
email address)

All All VUEN hubert.peter@vu Abbreviation "SO GL". The Improvement SO GL and GL SO can and have both be No done all
Document Documents en.at Regulation (EU) 2017/1485 is named suggested used vice versa. NRAs did not ask to
a guideline on electricity transmission change SO GL into GL SO for already
system operation. Therefore the submitted proposals, so the drafting team
abbreviation "GL SO" seems to be also stays with SO GL in this project
more appropriate.
Response to Swissgrid cherry.yuen@sw We don’t agree to the standard Clarification “FCR has the function of a reserve of no done all
Public issgrid.ch response to stakeholders “FCR has needed last resort…" has been removed.
Consultation 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.
A-1 (article) 74, 78 VUEN hubert.peter@vu The calculation of "electricity Clarification The expression "electricity consumption" No done Alberto Gil
(dimensionin en.at consumption" is not defined. I assume needed is used in the Entso-e web, and used by
g rules for "total load" according to Regulation the Data Expert Group, and published in
FCR) (EU) 543/2013 Art.2(27) is meant with the Power Statistic web.
"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.
A-1 (article) 42 50Hertz Torsten.benzin It is stated that this requires the Clarification The mentioned text (SUBMIT THE No done Alberto Gil
(dimensionin @50hertz.com approval of all NRAs, but that goes needed FOLLOWING FCR DIMENSIONING
g rules for too far. According to Art. 6 (3) (d) (ii) RULES PROPOSAL TO ALL
FCR) SO GL, the proposal under Art. 153 REGULATORY AUTHORITIES:) was
SO GL only requires the approval of provided in the original template (and is
the NRAs from the affected region, in common for all the rest A articles), if the
this case CE NRAs. That should be legal team considers necessary can be
clarified. changed, however, be aware that article
A7 has been already sent to the NRAs.
A-2 (article) 85 Terna temistocle.baffa Terna kindly requests to change the Improvement Suggestion accepted Yes done Alexander
(FCR scirocco@terna.i sentence: suggested Stimmer
additional t "shall provide technical evidence
properties) 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.
A-2 (article) 98 Terna temistocle.baffa Terna kindly requests to change the Improvement Suggestion accepted Yes done Alexander
(FCR scirocco@terna.i sentence: suggested Stimmer
additional t "limited energy reservoirs shall not be
properties) 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.
A-2 (article) 99 Terna temistocle.baffa Terna kindly requests to introduce, Clarification Suggestion accepted, "in fact" will be Yes done Alexander
(FCR scirocco@terna.i starting from the full-stop at the end of needed deleted Stimmer
additional t sentence on row 99, the following:"In
properties) 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.
A-2 (article) 105 Terna temistocle.baffa Terna kindly requests to change the Improvement Suggestion accepted Yes done Alexander
(FCR scirocco@terna.i sentence: suggested Stimmer
additional t "The FCR provider shall ensure that
properties) 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.
A-2 (article) Swissgrid cherry.yuen@sw Swissgrid looks forward to a Acknowledged No done Alexander
(FCR issgrid.ch consolidated version for further Stimmer
additional commenting.
properties)
B-1 50 - 51 ESO IKezhov@ndc.b Is it possible to provide some info how Clarification Adjusted in the explanatory note yes done Axel
(explanatory g the factor 2.1898 is calculated? needed Grüneberg
note) (FRCE (Tennet)
target
parameters)
A-2 (article) 91-92 Elia bernard.campio Even if we understand the reasoning Clarification The intention of the formulation was to no done Alexander
(FCR n@elia.be behind the requirement to take into needed leave some room on how to implement it. Stimmer
additional account possible under frequency
properties) 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.
B-1 Table 2 ESO IKezhov@ndc.b Is it possible to provide some info how Clarification Adjusted in the explanatory note yes done Axel
(explanatory g the factors 1.0364 and 1.96 are needed Grüneberg
note) (FRCE calculated? (Tennet)
target
parameters)
B-1 (article) 69 PSE robert.trebski@p the table should take into account the Improvement Names and abbreviations adjusted yes done Axel
(FRCE target se.pl entries and divisions set out in the A-7 suggested acoording to A-7. Grüneberg
parameters) methodology and documents related (Tennet)
to it
B-1 (article) 69 VUEN hubert.peter@vu LFC-Block Name and belonging LFC- Editorial Names and abbreviations adjusted yes done Axel
(FRCE target en.at Areas should match the names in the change acoording to A-7. Grüneberg
parameters) All-TSO LFC-Block determination (Tennet)
proposal. (e.g: AT)
B-1 (article) General 50Hertz Torsten.benzin According to the wording of Art. 128 Clarification Adjusted to CE TSOs Agreement on yes done Axel
(FRCE target @50hertz.com SO GL, this agreement is not a needed FRCE target parameters Grüneberg
parameters) "proposal" and, in my opinion, does (Tennet)
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.
B-1 (article) 73 50Hertz Torsten.benzin The Publication does not take place Improvement Adjusted to Article 8 (2) of SO GL yes done Axel
(FRCE target @50hertz.com according to Art. 5 SOGL, as suggested Grüneberg
parameters) described in Art. 4 of the Agreement. (Tennet)
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.
B-1 (article) 72 50Hertz Torsten.benzin Article 4 (1) of the Agreement is Clarification Article 4 has been redrafted . Reference yes open Axel
(FRCE target @50hertz.com incomprehensible in the sense that needed to Art. 5 SO GL has been deleted. Grüneberg
parameters) this provision can be read as if the CE (Tennet)
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.
B-1 (article) 50Hertz Torsten.benzin The agreement itself lacks the Improvement Adjusted yes done Axel
(FRCE target @50hertz.com provision that the determination of the suggested Grüneberg
parameters) values takes place annually. It is (Tennet)
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.
B-1 (article) 69 RTE julien.gaudin@rt to use the same TSO name in the Improvement Names and abbreviations adjusted yes done Axel
(FRCE target e-France.com table as for the proposal A-7 suggested acoording to A-7. Grüneberg
parameters) (Tennet)
B-1 (article) 67 RTE julien.gaudin@rt - It should be added that the target Improvement The comment was discussed with the no done Axel
(FRCE target e-France.com values are reevaluated every year suggested respresentative in drafting team from Grüneberg
parameters) based on FCR obligation distribution. RTE. Drafting Team conculded that (Tennet)
- The methodology should be part of Article 128 (1) of SO GL requires to
the main proposal (since this is the specify the values for the FRCEquality
methodology which should be target parameters.
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.
B-1 6 RTE julien.gaudin@rt For monitoring purpose, it should Clarification The distribution of FRCE quality target no done Axel
(explanatory e-France.com probably added the methodology for needed parameters of LFC blocks to the LFC Grüneberg
note) (FRCE LFC blocks with more than one LFC areas is a part of the LFC block (Tennet)
target area. Should we publish one final operational agreement. Article 118 (1d) of
parameters) table per LFC area apliyng the SO GL requires only the definition of
distribution rule of the LFC block OA. these parameters on LFC block level.
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.
B-1 (article) 67 Elia bernard.campio - It should be added that the target Improvement The comment was discussed with the no done Axel
(FRCE target n@elia.be values are reevaluated every year suggested respresentative in drafting team from Grüneberg
parameters) based on FCR obligation distribution. Elia. Drafting Team conculded that Article (Tennet)
- The methodology should be part of 128 (1) of SO GL requires to specify the
the main proposal (since this is the values for the FRCEquality target
methodology which should be parameters.
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.
B-2 (article) 78 ESO IKezhov@ndc.b Is it possible to provide a numeric Clarification Several studies were performed by the No done Alberto Gil
(FCR g example for this? needed SG SF, evaluating not only the suitability
exhaustion of this methodology, but also the
risk) 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/S
F/Shared%20Documents/171122_TOP_
9.1_FCR.pptx&action=default
B-2 (article) 72 Terna temistocle.baffa Terna kindly observes that the Improvement Long lasting frequency deviations were Yes done Alberto Gil
(FCR scirocco@terna.i methodology does not include the suggested not explicitily mentioned in the wording,
exhaustion t "long lasting frequency deviations but indeed they are implicity considered
risk) events" as operational situations in the model, as the real distribution of
resulting in an underestimation while frequency deviation is used.
assessing the risk of exhaustion of
FCR.

Rationale: simultaneous occurrence

of long lasting events and generation
tripping to be taken into account.
B-2 (article) 128 Terna temistocle.baffa Terna kindly observes that the Improvement This methodology assumes a correct No done Alberto Gil
(FCR scirocco@terna.i methodology does not enclose the suggested deployement of FRR, so after an
exhaustion t contribution of Limited Energy imbalance (for instance, due to the trip of
risk) Reservoirs FCR providers to the a generator, changes in demand, or in
Frequency Containment Process renewables) the FRR shall take over the
within the risk assessment modelling. FCR in 15 minutes (Time to restore
frequency), which is the minimum
Rationale: the risk of energy possible values of the availability for LER
exhaustion and the consequent lack units.
of FCR provision should be taken into This hypothesis is essential, and we have
account. 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
B-2 (article) 78 RTE julien.gaudin@rt to adapt the sentence to say "this is Editorial Done Yes done Alberto Gil
(FCR e-France.com the methodology" even if written in change
exhaustion comprehensive way. Otherwise it
risk) seems there is a methodology
described elswhere.
B-3 (article) 51 RTE julien.gaudin@rt The list of tasks taken over by SGSF Improvement The list of tasks is regularly being yes done Andreas
(nomination e-France.com should be added for avoidance of suggested specified between the synchronous area Walczuch
of a doubt. monitor and SG SF on request and
synchronous should not therefore not be predefined.
area monitor) An according precision has been added
to the article
B-4 (article) 68 RTE julien.gaudin@rt proposal to add "for avoidance of Clarification Good suggestion. Article was adapted as yes done Bernard
(calculation e-France.com doubt, the ramping period shall apply needed proposed. Campion
of the control to any change of control program", or
program) to list all the cases: market,
countertrading, cross-border
redispatch, balancing program
interchange, offset in case of
extraordinary procedure.
B-6 (article) 133 ESO IKezhov@ndc.b What is the reason to choose 200 Clarification These are typical values for indication. It no done Julien
(load- g sec. as upper limit for integral time needed should not be considered as upper limit Gaudin
frequency- constant? for integral time constant. (RTE)
control The value of 200 sec. is coming from the
structure) former Policy 1.
intention was not to rediscuss theses
values and keep it exactly the same from
former Policy 1.
B-6 (article) 153 - 154 ESO IKezhov@ndc.b Please to synchronize the explanation Improvement Improvement accepted. The table and yes done Julien
(load- 155 - 156 g text about LFC Input in Table 1 with suggested formulas are aligned. Gaudin
frequency- 157 - 158 explanations about formulae 1, 2 and (RTE)
control 3 from Operation Modes of the
structure) Frequency Restoration Controller.
B-6 (article) 174 - 175 ESO IKezhov@ndc.b Is the 1 minute window a part of the Clarification Answer is No. the distribution should be yes done Julien
(load- g 15 minutes window ? Does the 1 needed on 1min resolution and not on 15min Gaudin
frequency- minute window contain the highest resolution. (RTE)
control average ACE? Is the 15 minute Clarification was added to the document:
structure) window movimg and what is it step (1 it is about calculatin the difference per
or 15 minutes)? Let to solve the minutes, of the 1min-average of ACEol
following case for CE: all LFC areas and the 15min average of ACEol of the
are balanced and the frequency is 50 corresponding quarter of hour (see
Hz. The LFC time interval is 1 footnote No. 4).
second. At the instant t1 150 MW Definition of quarter of hour is the same
generation is lost in i-th area. The as for the FCR risk methodology
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?
B-6 (article) 176 - 177 ESO IKezhov@ndc.b Let to solve a similar case for CE, but Clarification Answer is No. the distribution should be yes done Julien
(load- g with negative ACE: all LFC areas are needed on 1min resolution and not on 15min Gaudin
frequency- balanced and the frequency is 50 Hz. resolution. (RTE)
control At the instant t1 150 MW load is lost Clarification was added to the document:
structure) in i-th area. The frequency will rise it is about calculatin the difference per
with 150 / 28000 ≈ 5.4 mHz. Let the K minutes, of the 1min-average of ACEol
factor for i-th area is 377 MW / Hz. and the 15min average of ACEol of the
The ACE for this are will be -(150 corresponding quarter of hour.
+377*5.4*e-3) ≈ -152 MW. Let to Definition of quarter of hour is the same
accept also for simplicity the ACE as for the FCR risk methodology
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?
B-6 (article) 67 RTE julien.gaudin@rt to add the number to the figure Editorial Added to the document yes done Julien
(load- e-France.com change Gaudin
frequency- (RTE)
control
structure)
B-6 (article) 135 RTE julien.gaudin@rt for consistency with B3, SGSF shall Improvement modified in the document yes done Julien
(load- e-France.com be replaced by "synchronous area suggested Gaudin
frequency- monitor according to B3" (RTE)
control
structure)
B-6 (article) 154, 158, RTE julien.gaudin@rt formulas shall be aligned with Improvement see comment 32 yes done Julien
(load- 168 e-France.com variables defined in the table 1 suggested Gaudin
frequency- (RTE)
control
structure)
B-6 (article) 103 Swissgrid cherry.yuen@sw Swissgrid proposes to have better Improvement clarification was added to the text with a yes done Julien
(load- issgrid.ch clarification of the Coordinated FRCE suggested footnote added to the figure about the Gaudin
frequency- calculation in the Control Process mandatory arrow (RTE)
control diagram (Figure 2 on page 30) in the
structure) 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.
B-6 (article) 67 Elia bernard.campio The number of the related figure is Editorial see comment 35 yes done Julien
(load- n@elia.be missing in the sentence change Gaudin
frequency- (RTE)
control
structure)
B-6 (article) 135 Elia bernard.campio for consistency with B3, "SGSF" Improvement see comment 36 yes done Julien
(load- n@elia.be should be replaced by "synchronous suggested Gaudin
frequency- area monitor according to B3" (RTE)
control
structure)
B-7 (article) 104, 140 RTE julien.gaudin@rt to replace SGSF by synchronous Editorial sensible suggestion. yes done Cherry
(methodolog e-France.com area monitor change Yuen
y to reduce (Swissgrid)
the electrical
time
deviation)
B-7 (article) 104, 140 Elia bernard.campio for consistency with B3, "SGSF" Editorial sensible suggestion. yes done Cherry
(methodolog n@elia.be should be replaced by "synchronous change Yuen
y to reduce area monitor according to B3". (Swissgrid)
the electrical In addition, on row 104, for clarity,
time replace "starting at 0 a.m." by
deviation) "starting at 00:00"
B-9 (article) 108 Terna temistocle.baffa Terna kindly requests to delete the Improvement Reference to Art. 152(13) deleted as this yes done Alexander
(operational scirocco@terna.i threshold of 375 MW since this is not suggested is not an obligation in context of Art Stimmer
procedure to t an oblication pursuant to Art.152(13) 118(1)(n). The threshold itself will be kept
reduce of the SO GL. Furthermore it is not a as it is only used in combination with
frequency prescription according to the declared alert state as indication of the
deviations) extraordinary procedure in force for potential impacting TSO
frequency monitoring and
countermeasures in case of large
steady-state frequency deviations.

B-9 (article) 87-88 Terna temistocle.baffa Terna kindly request to align the Improvement there was a request to allow for a direct no done Alexander
(operational scirocco@terna.i suggested approach with the currently suggested trigger in case of emergency; the Stimmer
procedure to t used procedure. In particular, it's procedure concering delayed retrofit was
reduce always the Coordination Centre to explicitly requested to be not included in
frequency trigger Stage 2 and not single TSOs B-9 but just implicitly as part of
deviations) suggesting the Coordination Centre to “Activation of additional mFRR or RR”
trigger the Stage 2. Furthermore, the (due to all this discussions and different
contents of the Additional views on the procedure…). Nevertheless,
supplementing procedure for current formulation allows to activate the
activation of reserves for delayed supplementary procedure under Stage 2
retrofit TSOs are not reflected and should therefore be in line with
explicitly in the SAFA. Should we Terna’s view
consider them included in the Stage
2?
B-9 (article) 129 Terna temistocle.baffa Terna asks to change the sentence Improvement "record" replaced by "take note" yes done Alexander
(operational scirocco@terna.i "The Coordination Centre shall record suggested Stimmer
procedure to t the information…". In particular,
reduce substitute the word "record" with "take
frequency note" or something similar. Otherwise
deviations) the term "record" paves the way to
many interpretations. For instance,
what kind of recording is to be
performed by the Coordination
Centre? written recording? Phone
recording? Other?
B-9 (article) 165 Elia bernard.campio for consistency with B3, "SGSF" Editorial done yes done Alexander
(operational n@elia.be should be replaced by "synchronous change Stimmer
procedure to area monitor according to B3"
reduce
frequency
deviations)
B-9 (article) 168 Elia bernard.campio For TSOs taking part to the cross- Clarification Real time ACE has been deleted yes done Alexander
(operational n@elia.be border aFRR energy exchange, the needed Stimmer
procedure to ajusted ACE taking into account the
reduce activations for cross-border purposes
frequency might not be known in real-time.
deviations) Moreover, this value might be a bit
approximative
B-10 (article) 144 PSE robert.trebski@p Is the duration of the trail phase Clarification replaced "All TSOs" by "The relevant yes done Jan
(roles and se.pl included in the duration of the whole needed TSO" Cernohors
responsibiliti process? Since the trial phase covers ky
es of "All TSO .." and not "Each TSO",
Imbalance there is a real risk that the trial phase
Netting and will last a long time due to the still
cross-border attaching TSO
FRR and RR)
B-10 (article) 154 PSE robert.trebski@p We are asking for clarification Clarification yes, the task is valid for each TSO no done Jan
(roles and se.pl regarding the reporting process: needed individually Cernohors
responsibiliti should any individual TSO be ky
es of reported? If so, see the previous note.
Imbalance
Netting and
cross-border
FRR and RR)
B-10 (article) 151 PSE robert.trebski@p We are asking for clarification of Clarification yes, this is a process other than no done Jan
(roles and se.pl exactly what Additional Process is. Is needed mentioned earlier. Every new process Cernohors
responsibiliti this a process other than mentioned with cross-border relevance should have ky
es of earlier? been notified to CSO as current practice
Imbalance before implementation
Netting and
cross-border
FRR and RR)
B-10 (article) 86 Terna temistocle.baffa Terna would like to point out that Improvement Operational Security Analysis is a SOGL yes done Jan
(roles and scirocco@terna.i limiting to write "Operational Security suggested definition and is therefore used. Cernohors
responsibiliti t Analysis " is very generic. Therefore, Reference to SO GL definition has been ky
es of we propose to better specify by listing added to article
Imbalance what has to be contained (at least a
Netting and condensed description of the
cross-border minimum contents).
FRR and RR)
B-10 (article) 128 Terna temistocle.baffa The sentence is unclear. Affected Improvement Wording changed in a way that limits can yes done Jan
(roles and scirocco@terna.i TSO should be able to define limits suggested be requested in general Cernohors
responsibiliti t for the exchange and sharing of ky
es of reserves of other LFC Areas/Blocks
Imbalance (mostly neighbouring TSO of Affecting
Netting and TSOs should declare themselves as
cross-border Affected TSOs) , since it's the
FRR and RR) 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.
B-10 (article) 137-138 Terna temistocle.baffa The terms "new process proposal" Clarification yes, this is a process other than no done Jan
(roles and scirocco@terna.i are not clear. Is this referring only to needed mentioned earlier. Every new process Cernohors
responsibiliti t "Additional processes" as reported in with cross-border relevance should have ky
es of rows 103-112 and 151-157 or is been notified to CSO as current practice
Imbalance referring also to processes as before implementation
Netting and Imbalance Netting, Cross-border
cross-border activation of reserves, Exchange and
FRR and RR) 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.
B-10 (article) 101 RTE julien.gaudin@rt to add "at least" three months in Improvement "at least" added yes done Jan
(roles and e-France.com advance suggested Cernohors
responsibiliti ky
es of
Imbalance
Netting and
cross-border
FRR and RR)
B-10 (article) 132 RTE julien.gaudin@rt to replace SGSF by synchronous Improvement replaced SG SF by Synchronous Area yes done Jan
(roles and e-France.com area monitor suggested Monitor Cernohors
responsibiliti ky
es of
Imbalance
Netting and
cross-border
FRR and RR)
B-10 (article) 161 RTE julien.gaudin@rt the sentence is not clear if we shall Clarification general change of all article 4 of all B yes done Jan
(roles and e-France.com publish the proposal without undue needed articles according to guidace of legal Cernohors
responsibiliti delay or if we shall list and publish the expert team ky
es of roles and responsibilities of TSOs
Imbalance already performing imbalance
Netting and netting,…
cross-border proposal is to rephrase clearly: "The
FRR and RR) TSO shall publish this proposal of
roles and responsibilities of..."
B-10 (article) 132 Elia bernard.campio for consistency with B3, "SGSF" Editorial replaced SG SF by Synchronous Area yes done Jan
(roles and n@elia.be should be replaced by "synchronous change Monitor Cernohors
responsibiliti area monitor according to B3" ky
es of
Imbalance
Netting and
cross-border
FRR and RR)
B-11 (article) 69-70 Terna temistocle.baffa Terna would like to stress that with Improvement Good remark. This hot-stand-backup is yes done Bernard
(requirement scirocco@terna.i the establishment in the following suggested indeed necessary. It is foreseen in the Campion
s concerning t years of the European Platforms for PICASSO project.
the the activation of reserves (aFRR, I adapted the Article in order to take your
availability, mFRR, RR) pursuant to EB GL, the suggestion into account: "The Frequency
reliability hot-stand-by-backup system should Restoration Controller of aFRR shall be
and be foreseen for these Platforms. operated on-line and shall have a very
redundancy Therefore we suggest to change the high reliability. The tools for activation of
of the following sentence: mFRR and RR shall be operated on-line
technical "A hot-stand-by-backup system must and shall have a very high reliability as
infrastructur be available to take over the control well. A hot-stand-by-backup system must
e) function in case of an outage or fault be available to take over the control
of the main system." function in case of an outage or fault of
into the main system. This requirement
"A hot-stand-by-backup system must applies as well for all European
be available for all European Platform Platform performing a cross-border
performing a cross-border FRR and FRR and RR activation process."
RR activation process, to take over
the control function in case of an
outage or fault of the main system."
B-11 (article) 119-121 Terna temistocle.baffa Terna would like to ask why TSOs Clarification Solution found via bilateral agreeement no done Bernard
(requirement scirocco@terna.i "shall publish the requirements needed between Terna and Bernard. No change Campion
s concerning t concerning the availability, reliability in article.
the and redundancy of the technical
availability, infrastructure proposal". Unless an
reliability already existing obligation is force, we
and suggest not to publish such sensible
redundancy information and then to remove the
of the lines from 119 to 121.
technical
infrastructur
e)
B-11 (article) 90-91 VUEN hubert.peter@vu The text "Substitute measurements Clarification Formulation of MLA OH was used. yes done Bernard
(requirement en.at and reserve equipment shall be needed Measurement requirements have been Campion
s concerning available in parallel to the primary precised.
the measurement and substitute
availability, measurements." is a tightening of
reliability the requirements compared to the
and existing OH Policy 1 where substitute
redundancy measurements are obligatory for all
of the TIE-LINES with significant impact to
technical SECONDARY CONTROL. Is this
infrastructur intentional and in any case feasible,
e) 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.
B-11 (article) 77 RTE julien.gaudin@rt to adapt "frequency measurements Improvement Good proposal. The sentence online 76- yes done Bernard
(requirement e-France.com available in real time from at least two suggested 77 was modified as follows: "For each Campion
s concerning different geographical locations LFC Area of CE synchronous Area, the
the available within the LFC area" related TSO shall have frequency
availability, measurements from at least two
reliability different geographical locations
and available within this LFC Area."
redundancy
of the
technical
infrastructur
e)
B-12 (article) 65 RTE julien.gaudin@rt the sentence is not clear. Maybe to Improvement suggestion implemented yes done Alexander
(common e-France.com split the sentence into two phrases: suggested Stimmer
rules for the All common rules for the operation in
operation in Normal State and Alert State reflect
normal state the target of load-frequency-control to
and alert reduce frequency deviations. Those
state) rules refer to the operational
procedures to reduce frequency
deviation according to B-9
Operational Procedures to Reduce
Frequency Deviation.
B-16 (article) 57 ESO IKezhov@ndc.b I didn't find the word "compensation" Clarification Formulation was missleading and has yes done David
(technical g about the providing synchronous area needed been adjusted according to wording in Whitley
design of the neither in 173(3), nor in 153. Could article 173(3)
frequency you please to comment what has to
coupling be compensated (is this some back-
process) up process)?