Presentation - SEMO

MOD_17_18 Version 2 Transitional Provisions for Cutover 21st June 2018 Summary Information - Proposal This proposal seeks to make two Code changes related to the transition from SEM to I-SEM The first change is to define the initial SEM and Final ISEM Billing and Capacity Periods since these will be partial billing weeks and capacity months and do not therefore conform to the normal definitions which has implications for the rules governing invoice and Make Whole Payment calculations This first part of the proposal also seeks to make provision for a specific treatment within capacity whereby energy limited and storage units have optimised Eligible Availability based on a MWh limit which is a Trading Day value pro rated to a partial Settlement Day

The Second change is to provide for the cancellation of the final Within Day MSP Software Run in order to allow time for cutover activities related to the Interconnectors to take place ahead of the early I-SEM day ahead activities Summary Information Justification (Billing and Capacity Periods) It is necessary to define partial Billing and Capacity Periods for the final SEM and Initial I-SEM periods since they will not be full calendar weeks/months The overall approach to the Cutover Time in Part C only treats Trading/Imbalance Settlement Periods in terms of where Parts A and B apply and the definitions of Billing and Capacity Periods state a complete period in each case so this proposal aims to make the treatment of these periods around the Cutover Time more explicit This is with a view to clarifying Billing and Capacity Period aggregations for Invoicing and also cost recovery via weekly Make Whole Payments on a Billing Period basis

The change applied to Make Whole Payments is to ensure that Generator Units recover any difference where Market Production Costs exceed Energy Payments under Part A in isolation and likewise any difference where Make-Whole Payment Operating Cost exceeds MakeWhole Payment Revenue under Part B in isolation In addition, as currently written the rules apply of Trading Day energy limits and storage capacities to the final 18 hours of each Part A Capacity Period (06:00 00:00) Since the Cutover Time is at 23:00, 17/24 of these limits should be applied (06:00 23:00) Summary Information Justification (MSP Software Cancellation for final Within Day run) The final Within Day MSP Software Run is due to be published by 09:30 on the day prior to the first ISEM Trading Day and this is only 13.5 hours prior to the first ISEM Trading Period and four hours prior to the first Balancing Market Gate Closure One/1.5 hours prior to the first I-SEM Day Ahead Gate Closure The Final Ex Ante Two MSP Software Run is due to be published at 13:00 two days prior to the first I-SEM Trading Day or 34 hours prior to the first I-SEM Trading Period There are a number of cutover activities required that would be either difficult to deliver on time to

avoid delays, or entirely unachievable if the final Interconnector traded positions are not known until 09:30 Day Ahead In order to initialize the Interconnectors within the I-SEM systems it is necessary to determine the initial flow which is governed by the final SEM position, this activity interacts with other activities in terms of database cutovers, configuration of various Market and System Operator applications etc. It is expected that in order to efficiently/optimally manage the cutover of the Interconnectors a System Operator Trade will be required which is better managed ahead of time and may be difficult to enact and/or more expensive if it cant be done until after the final Within Day Run Summary Information Justification (MSP Software Cancellation for final Within Day run) This proposed cancellation is also in an effort to prudently manage dispatch of the overall system and it is likely that the first Indicative Operations Schedule will be more prone to change if this Interconnector cutover activity is not carried out prior to it being determined

An EDIL outage is required for roughly three hours on the day before the first Trading Day to facilitate cutover activities in system dispatch which will further delay any update to issuance of Dispatch Instructions based on any updates to the schedules In order to carry out the activities associated with Interconnector cutover (determine and execute any SO Trade, determine the optimal dispatch of the Interconnector and the wider system, determine and reflect initial flow in the I-SEM systems) more time is needed prior to the early I-SEM activities than will be available if the final Within Day run goes ahead If done later this will coincide with other cutover activities and may detract from their delivery whereas if it is done earlier it will not run in series with such activities By cancelling the final WD MSP Software run the final traded position on the Interconnectors will be known 20.5 hours sooner which will facilitate these activities while accepting that 5 hours of Within Day Trading would be lost (which may be mitigated by Interconnector Participants knowing this ahead of time so they may be able to move some of this trade into Ex Ante 2) Note that Commercial Offer Data submitted to this gate window will still apply if the run is cancelled

Legal Drafting Alternatives Some alternative legal drafting approaches have been put forward and while we retain a slight preference for the submitted drafting we dont have a strong view either way and therefore wish to share the alternatives so that they may be considered by the committee Transitional Billing/Capacity Periods Proposed Wording example (final Part A Billing Period definition overwritten) means the period commencing at 00:00 on Sunday of the week containing the Cutover Time and ending at the Cutover Time. It is the period of time over which Trading Payments and Trading Charges are based for the final Part A billing period. Alternative Wording example (retains existing definitions but caveats them) In Part A, any Billing Period and any Capacity Period that would, save for the provisions of this Section 12, end after the Cutover Time, shall end at the Cutover Time.

Legal Drafting Alternatives Cont. Cancellation of Final Within Day MSP Software Run Proposed Wording The Market Operator shall determine that an MSP Software Run Cancellation shall apply in respect of the Within Day One MSP Software Run for the Trading Day which contains the Cutover Time. The result of this MSP Software Run Cancellation shall be as detailed in Part A clause 4.82H. Alternative Wording Where the Trading Day includes the Cutover Time a MSP Software Run Cancellation shall be deemed to apply to the Within Day One MSP Software Run.

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