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Energy Networks Association Open Networks Project Advisory Group 12 th April 2018 1

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Energy

Networks

Association

Open Networks Project – Advisory Group12th April 2018

1

Welcome & IntroductionsNigel Turvey – ENA Open Networks Project Chair

2

The Advisory Group is essential to our project to:

• Ensure stakeholders are aware and taking the Project into account;

• Request input from stakeholders to improve the quality of our products;

• Increase awareness about project risks & issues, ask for views on risks & issues and collaboratively resolve where appropriate.

It will provide input to:

• Steering Group on project scope, progress, risks & issues;

• Workstreams with deliverable comments/feedback.

We will seek to send information in advance of meetings to ensure that views can be sought by trade associations in advance. Our objective is to encourage open feedback from you all across all of our work.

Thank you for the continued input.

Advisory Group ToR Reminder

3

The intention of the bulk of this meeting is to split the Advisory Group into 3 break-out groups to discuss the materials.

Each break-out group will discuss the material from workstreams for just under an hour, then the facilitators will move on to

discuss their material with another break-out group. We will have 3 of these sessions, so each break-out group will discuss all of

the material in turn.

Consultation Response Summary - Nigel Turvey (WPD SG Member)

Breakout Group 1 - Sotiris Georgiopoulos (UKPN WS Lead), Kyle Murchie (SSEN WS Member) & Nigel Turvey (WPD SG

Member)

• Upcoming consultation on best practice for connecting flexible resources (WS1 Product 10)

• Whole system investment planning case studies & methodology (WS1 Product 1)

Breakout Group 2 - John West (ENA Technical Lead) & Steve Atkins (SSEN WS Member)

• Definition of commonly used terms in the industry (WS2 Product 3)

• DSO functions (WS3)

Breakout Group 3 - Steven Gough (SSEN WS Member) & Manuel Castro (EATL Representative)

• Case study for SGAM models (WS3)

Today’s Agenda & Approach

4

Response to Consultation on the 2018 Programme of

WorkNigel Turvey – ENA Open Networks Project Chair

5

Consultation Responses

ENA responses to the 2018 public consultation will be released and published shortly.

6

Breakout Session 1Part I: Upcoming consultation on best practice for

connecting flexible resources (WS1 P10)

7

Purpose

• Update on work to date.

• Discuss Advisory Group members’ experiences; do they align with the initial findings?

• Walk through consultation questions.

• Gain feedback on the proposed questions and whether there is anything missing.

8

Background

Licences and their associated new connections processes were originally written with traditional demand and generation in mind. Through the last regulatory period (DPCR5) and into RIIO-ED1, the penetration of a variety of non-traditional DERs has increased.

While changes have been made to processes and a number of connections related documents, the way in which such DER technologies are treated and their capabilities considered is not believed by the regulator to be clear and transparent. The Smart Systems and Flexibility Plan published in July 2017 presents the following Issue and Action 1.6.

The licensees have committed to addressing the fair treatment of all flexibility point collaboratively through Workstream 1 of the ENA Open Networks Project.

Issue: Network connection rules were not designed with storage in mind, which can lead to a number of issues including a

lack of understanding of how storage connections should be treated (by both network operators and connecting

customers) and the cost and time of connecting.

Action: We expect network operators and industry to continue to improve network connections for storage – in particular,

acting now to clarify the connection process (including for domestic and co-located storage), increasing transparency

about where to connect, and implementing better queue management. Ofgem will use the Incentive on Connections

Engagement 27, an incentive developed under the RIIO28 framework, to assess if distribution network operators are

addressing these issues and ensure they are engaging with connection stakeholders and responding to their needs.

9

Product Outcomes

Product 10 seeks to achieve the following through publication of a short report:

• Definition of the problem / opportunity;

• Clarification of the present treatment of flexibility;

• Outline the next steps to be considered.

Workstream 1 Product 10 is succeeded by Product 11 which will look at the developments required from the

present position to facilitate the promotion of storage and or other applicable Distributed Energy Resources

(DERs) where it can assist others to connect more quickly and cheaply.

Product 11 proposes the following outcomes which were included in the 2018 ON Project Initiation Document

(PID) consultation:

• Gap Analysis - Identify gaps in DER management processes (application to energisation) and develop

workplan to close gaps;

• Communication of Findings - Develop a Good Practice Guide and roadmap to provide an overview of the

findings and actions identified for treatment of DER connections in the DSO environment;

• Action Plan - Carry out further action plan for Flexible Resources.

10

The Opportunity

11

The Opportunity

12

Key Findings

Do licensees treat storage any differently from other technologies?

No. Storage (non-domestic scale) would generally be treated in the same manner as any other export and or import connection

of similar capacity size by all DNOs.

How do you treat a formal connection application for flexibility (DG, Storage, DSR Load, etc.) in a constrained area?

Any formal connection application will be progressed in the same manner by each individual DNO. The connection will be

designed to accommodate the full import and/or export requirements of the application and any works required to accommodate

this under passive operation will be identified. Where this is significantly more expensive than usual, or where the customer has

specified a preference for an “Alternative” or “Flexible” connection, an alternative connection will be offered, either in lieu of, or in

addition to the standard connection offer.

How do you treat a formal connection application for flexibility (DG, Storage, DSR Load, etc.) in a un-constrained area?

Simply, if a customer (storage or otherwise) does not cause a constraint then they will be offered a solution commensurate with

the requirements on their application form.

13

Timeline

Mar Apr May June July Aug Sep Oct Nov Dec

ON AG

Key

P10

P11

Consultation

Report Write up

Scoping

Review

Consultation

Launch

ON SG

Review &

Sign-off

Product

alignment

Whiteboard

session

Gap analysis

Roadmap and Good Practice Guide

Action plan

WS2 P5

Consultation

Consultation

Analysis

Consultation

14

Consultation Questions

We propose to ask the following questions in the consultation to help the team refine the focus of P11 and validate the current direction of travel. Are these the right questions? What else would the Advisory Group like to see?

1. Do you agree that there are opportunities in the existing connections process for storage and other DER to be promoted?

2. Under what circumstances do you think customers/flexibility/storage service providers should be promoted up the queue?

3. A number of products outlined in the Phase 2 Work Program and associated consultation seek to develop the existing queue management processes and connections journey. Do you believe these go far enough or are there gaps? If there are gaps, what are they?

4. With promotion of flexibility in mind, does the definition of the problem outlined in the associated report align with your thinking? What additional elements would you suggest be incorporated to add value to future work?

5. The conclusion suggests that the issue is less with the existing queue management processes and more to do with market certainty, tender requirements, service availability and T&D network constraints. Do the findings of DNO practices align with your experiences to date?

6. The next stages include a detailed gap analysis, roadmap, good practice guide and action plan. What information could we include as part of these outputs to provide customers with the tools to help progress through the connections queue?

15

Breakout Session 1Part II: Whole system investment planning case

studies & methodology (WS1 P1)

16

• Update on work to date

• Aims of Product 1

• Provide an overview to the Advisory group on the case studies proposed for Phase 1

• Discuss further expansion to include markets

Purpose

17

In the past…

• Investment planning has traditionally occurred wholly within the Transmission or Distribution networks

• Planning processes were developed around the model of large transmission connected generation with power flowing from the transmission network to distribution

…and now…

• This model has now changed, with large volumes of distribution connected generation and a subsequent change to network flows

• This results in different network challenges to manage in planning timescales and uncertainty of what the best solution is

...what is needed?

• This drives the need to develop new approaches to investment planning to unlock the potential value of flexible, whole system ways of working to realise benefits for consumers

• Last year the workstream published a report on short term solutions for Whole System Investment Planning

• This year Product 1 is building on the actions detailed in this report and developing solutions for the medium and long term

Background

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• The aim of the work package is to develop the methodologies and processes to enable a whole system approach to investment planning utilising a range of investment and operability options across T&D. Builds on Open Networks WS1 (2017) Product 3

• Phase 1 of this product includes the development and ‘delivery’ of a number of short-term case studies to address regional issues on the transmission system.

o Develop detailed processes and interfaces for Regional NOA.

o Develop models & methodology to assess T&D network capability and to carry out CBAs for Regional NOA.

o Develop regional example(s) based on DNO network options to use in regional NOA process.

• Phase 2 will look to further develop the medium/longer term whole system investment planning models. These are currently under development with a consultation planned in 2018.

o Further evolve longer-term whole system framework for investment planning including DER options for whole system investment. Consult on these.

o Agree information requirements (costs, network info & resource visibility) for whole system investment planning & propose ongoing models.

Aims of Product 1

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• To apply the learnings from the Regional Development Programmes

• To develop NOA processes to address additional system needs e.g. reactive power

requirements during high volts scenarios

• To explore non-transmission solutions for the benefit of end consumers

• To identify any regulatory blockers and potential requirements for changes in RIIO-T2/

ED2 regulatory incentives

• To improve planning processes across Transmission and Distribution through sharing

lessons with the Open Networks Project

Aims of High Volts Case Studies

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• It is becoming more challenging for the system operator to contain high volts within SQSS limits on the transmission network. The occurrences where the system is being operated at its limits are increasing and voltage excursions outside the SQSS limits are becoming more frequent.

• The possible root causes are:o Synchronous generators are being displaced by renewable energy sources and embedded generation

which provide less reactive support.

o Active and reactive demands are reducing year on year with the trend expected to continue for the foreseeable future.

o Available options to mitigate high volts are gradually being depleted.

• The problem is expected to worsen and the risk of the system becoming non-compliant is very likely unless mitigation measures are implemented.

High Voltage Challenge

21

High Level Process

22

Mar Apr May June July Aug Sep

Modelling of Tx network

Publish conclusions

of High Volts Case

Study

Identify system needs

Prioritisation of sites

Key

SO

TO

DNO

All

SO & DNO

SO & TO

Engage DNOs

Write up report

Initial engagement

teleconferences

Share model outputs and Mvar

exchange at GSPs with DNOs

Development of Tx solutions

Cost of Tx solutions

Sharing of DNO

forecastsComparison of

model data

Agree model data and model

parameters for assessment

Development and

Assessment of Dx

solutions

Costing of DNO

solutions

Cost Benefit

Analysis

Consideration of

operational solutions

Draft Timeline – Detailed Project Planning is Ongoing

23

Breakout Session 2Part I: Definitions of commonly used terms in the

industry (WS2 P3)

24

Product 3: Context

• This work aims to provide greater clarity around terms and definitions that are commonly used by network operators and stakeholders.

• For example:

o Terms such as “firm” and “unfirm” are widely used to describe customer connection arrangements but meanings may be unclear.

o Other terms such as “Maximum Entry Capacity” and “Transmission Entry Capacity” look similar but are used to describe different aspects of what network capacity is available to customers.

o Occasionally, terms might be defined differently across network code documentation. For example, the definition for “distribution system” is worded differently in codes such as the BSC and the DCUSA.

• The terms and definitions we identify will be documented, published and used by network operators to provide greater clarity for customers.

25

Product 3: Approach [1]

• The Product 3 team is using a two-pronged approach – bottom-up & top-down –to identify problematic areas.

• Work is underway on a bottom-up review of terms in main industry sources including the Grid Code, Distribution Code, Balancing & Settlement Code etc.

o Is covering 1000+ defined terms across codes to identify commonly used terms that are problematic

o Is identifying terms used differently in different codes or at T & D

• We are also carrying out a top-down identification of terms that may be unclear.

o For example, terms such as “firm”, “unfirm”, “constraints” and “curtailment” are widely used when describing network arrangements.

26

Product 3: Approach [2]

• We propose to produce and publish a document containing the more commonly used terms that are problematic for stakeholders.

• The definitions to be provided in this document aren’t intended to replace terms and definitions used in industry reference documents such as code frameworks. Rather, the document would provide a working definition for terms used within Open Networks

• The document would indicate whether each term is specific to Open Networks or whether there are also legal or codified definitions in place and where these can be referenced.

• This document would be shared within network companies and with stakeholders to encourage consistent use of terms. This would include network company individuals interfacing directly with stakeholders on areas of work impacted by the Open Networks work.

27

Product 3: Questions for today

The following 4 slides provide some examples of potentially problematic Terms and Definitions. Please consider:

• Is this a good approach?

• Would it help to produce a glossary of terms relating to the Open Networks project?

• Do the attached examples provide a good starting point for a document?

• What other terms and definitions used by network operators are unclear and would benefit from being defined?

• Are there terms used by network operators in different ways?

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Problematic Terms & Definitions [1]:Examples relating to connections & constraints

Area Term Definition

Connections & Constraints

System Constraint A limitation on the use of a System due to lack of transmission capacity or other System conditions.

System Constraint Group

A part of the National Electricity Transmission System which, because of System Constraints, is subject to limits of Active Power which can flow into or out of it.

Constraints Restrictions on the ability of a network to transport energy, for example due to thermal or voltage limitations

Curtailment A reduction in output, for example of an embedded generator, to manage a network thermal constraint.

Constraint Managed Zones

Areas where peaks in demand or distributed generation are managed without needing to reinforce the network.

Firm (More Secure) Connections

Often a dual circuit connection to maintain availability in the event of a fault on one circuit. If the local distribution network is constrained, the customer may also opt to contribute to network reinforcement to address this.

Unfirm (Less Secure) Connections

Often a single circuit connection to reduce initial costs and accept the outage effects of faults and maintenance.

29

Problematic Terms & Definitions [2]: Further examples relating to network connections and capacity

Area Term Definition

Supply Points Grid Supply Point A connection point at which the Transmission System is connected to a Distribution System.

GSP Group The Distribution System(s) which are connected to the Transmission System at Grid Supply Point(s) which fall within one Group of GSPs.

Bulk Supply Point A point of supply from a Transmission System to a Distribution System.

Network Capacity Maximum Export Capacity The maximum amount of electricity which is permitted to flow into the Distribution System through a Connection Point (or Connection Points).

Transmission Entry Capacity The figure set out in the relevant Bilateral Connection Agreement or Bilateral Embedded Generation Agreement.

Registered Capacity The normal full load power deliverable by a Power Station.

Outages & Intertripping

System Outage A planned or unplanned interruption to the flow of electricity through a Transmission or Distribution system implemented to enable inspections, alterations, maintenance, repairs or additions to that system.

Intertrip A system to automatically disconnect a generator or demand from the network when a specific event occurs.

System to Demand (or Generation) Intertrip Scheme

An intertrip scheme which disconnects Demand (or Generation) when a System fault has arisen to prevent abnormal conditions occurring on the System.

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Problematic Terms & Definitions [3]: Examples relating to services supporting system operation

Area Term Definition

Services to Support System Operation

Flexibility Modifying generation and/or consumption patterns in reaction to an external signal (such as a change in price) to provide a service within the energy system.

Balancing Services 1 Includes ancillary services, offers and bids made in the balancing mechanism, and other services available to the GBSO to assist in co-ordinating and directing the flow of electricity over the national electricity transmission system.

Ancillary Service 1 Services such as any authorised electricity operator may be required to have available as ancillary services pursuant to the Grid Code; and services as any authorised electricity operator or person making interconnector transfers may have agreed to have available as being ancillary services.

The Grid Code identifies System and Commercial Ancillary Services.

System Ancillary Service 2

Ancillary Services which are required for system reasons and which must be provided by Users in accordance with the Grid Code Connection Conditions or if the User has agreed to provide them under a Bilateral Agreement

Commercial Ancillary Service 2

Other Ancillary Services, utilised by NGET if a User (or other person) has agreed to provide them under an Ancillary Services Agreement or a Bilateral Agreement with payment being dealt with under an Ancillary Services Agreement.

Product A specific service with a set of defined requirements. Often the term “Product” is used interchangeably with “Service”

Note 1 – This definition abbreviates the Transmission Licence definition.

Note 2 - This definition abbreviates the Grid Code definition.

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Problematic Terms & Definitions [4]: Examples of a term defined in different places

Term Source Definition

Distribution System

DCUSA The meaning given to that term in the Distribution Licences, and means:(a) in respect of each DNO Party or IDNO Party, that Party’s Distribution System; and(b) in Section 2A (unless the context otherwise requires), the Company’s Distribution System.

BSC Means:(i) all or part of a distribution system in Great Britain operated by a Licensed Distribution System Operator; and(ii) all or part of any other distribution system in Great Britain for which the condition is satisfied that all entry/exit points are subject to registration in SMRS pursuant to the provisions of the MRA; provided that: …..

MRA The meaning given to that term in the Electricity Distribution Licence.

Distribution Network

DCUSA Means collectively, the Distribution Systems of the DNO Parties and the IDNO Parties.

Transmission System

BSC The meaning given to the term ‘ National Electricity Transmission System’ in the Transmission Licence except that prior to the BETTA Effective Date every reference to Great Britain and Offshore in such term shall be deemed to be a reference to England and Wales.

32

Breakout Session 2Part II: Proposed Updates to DSO Functions (WS3)

33

Updates to DSO Functions

Cover:

• Recap of DSO Functions

• Proposed Updates following SGAM Work1. Network Operation to include activities relating to Fault Levels and

Power Quality.

2. System Defence & Restoration to clarify wording.

3. Service Optimisation and related activities to replace Service Provision.

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Recap of DSO Functions

DSO Functions

System Co-ordination

Network Operation

Investment Planning

Connections &

Connection Rights

System Defence &

Restoration

Services / Market

Facilitation

Service Provision

Charging

DSO Functions:

• Produced by WS3, Sept 2017

• 8 functions

• 41 activities related to these

functions

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Why Update These Functions?

3 of the functions and their related activities are being updated to reflect wider stakeholder feedback and the detailed assessment and review of the DSO models that has been carried out as part of the SGAM modelling.

• For the Network Operation and the System Defence & Restoration functions, the proposed changes more accurately reflect the DSO activities.

• For the Service Optimisation function we are also taking on board feedback that DSO’s should not be acting as commercial service providers. Aspects of this function relating to commercial service provision have been removed.

We welcome your feedback on the proposed changes. If the proposed changes are generally agreed, we propose to reissue the DSO Functional Requirements document. These changes will then be reflected in the SGAM modelling accordingly.

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Network Operation Function

No.DSO Functions

Description Activities Description

2 Network Operation

Operate the electricity distribution network to maintain a safe and secure system. Ensure that network powerflowsremain within limits and that the network operates within acceptable voltage limits. Ensure that the network remains secure against credible evets such as circuit trips and generation loss. Identify and manage current and future risks.

Coordinate and collaborate with Great Britain System Operator (GBSO) to manage potential conflicts to support whole system optimisation. Respond to customer needs.

Operate network within thermal ratings.

Use network asset rating and powerflow information and operate local distribution network assets within ratings.

Operate network within voltage limits. Model network powerflows and operate distribution network assets within secure voltage limits.

Operate network to maintain dynamic stability.

Operate distribution networks such that the network and its connected resources (eg generators) remain stable for secured faults.

Operate network within fault level limits

Model network infeeds and contingencies to ensure that equipment and connected resources remain within short circuit ratings and within protection limits.

Operate network to meet other power quality criteria.

Review and monitor potential for other power quality problems including harmonics and unbalance and operate network to avoid these.

Operate network taking account of ongoing asset condition.

Monitor the condition of assets and adjust operation on the basis of latest condition.

Operate network to minimise losses. Model network powerflows to ensure that losses on distribution network are minimised.

Enable network outages to provide access to assets and resources.

Forward planning and ongoing operation to ensure that network security is maintained during network outages and outages of key DER.

Optimised use of assets and dispatch of services

Utilise available resources in the most efficient way to operate within network limits.

It is proposed to update this function by adding 2 activities related to fault level management and

power quality. The additions are highlighted above.

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System Defence & Restoration Function

It is proposed to update this function by:

i) Making clear Network Contingency Planning here covers High Impact Low Probability events, and

ii) Including Voltage Reduction in the description of Resilience activities.

The updated sections are highlighted.

No.DSO Functions

Description Activities Description

5 System Defence & Restoration

Enhance whole system security through the provision of local and regional flexible services. Provide system resilience to very low probability but high consequence events using risk based approaches.

Provide the means to re-establish the wider synchronous area in the event of widespread disruption.

Loss of Mains & other Protection Arrangements

Ensuring the design and implementation of DER connection arrangements that have adequate resilience to network disturbances. This includes the specification of connection interface protection arrangements (including Loss of Mains) and compliance testing.

Network Contingency Planning for High Impact Low Probability (HILP) Events

Forward planning to ensure network has the capability to remain resilient against high consequence events such as extreme weather.

Resilience (Voltage Reduction, LFDD, HFGD)

Providing whole system network resilience and defence through the design and implementation of mechanisms including Voltage Reduction, Low Frequency Demand Disconnection (LFDD) and High Frequency Generation Disconnection (HFGD).

Resilience (Islanding) Providing local and whole system network resilience and defence through the design and implementation of islanding mechanisms to enable local areas of network to remain in service in the event of a wider system incident.

Black Start Enabling whole system network re-establishment following a major system incident through the staged energisation of local networks. This could include the block loading of larger generators as part of wider Black Start plans.

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Service Optimisation Function

It is proposed to revise the previous Service Provision function to Service Optimisation. The revised

description emphasises the need to provide access for flexibility services and to select the right mix

of services. 4 activities and related descriptions have also been updated. The changes are

highlighted above.

No. DSO Functions Description Activities Description

7 Service Optimisation

Ensure system needs can be efficiently met across all timescales by identifying network requirements, understanding the limitations of network assets and providing network access for additional flexibility services from smart solutions and DER services. Ensure whole system optimisation and resilience through the optimal selection of flexibility services.

Smartgrid network flexibility Enable flexibility services through novel utilisation of existing networkcomponents.

Service access management How services will be selected and managed by network operators depending on capacity constraints. Includes prioritisation methodologies (e.g. LIFO, technical best, economic best).

Service selection Transparency of decisions and actions when choosing the optimal selection of flexibility services. May include a framework/rules/criteria.

T-D co-ordination How issues and solutions on both T & D are co-ordinated to enable efficient whole system outcomes.

Conditions/process of market failure Identifying when last resort provisions should be enacted.

Regulation & competition frameworks Identifying the rules for managing and remunerating last resort service provision. Putting in place methodologies to ensure that these continue to be efficient against other solutions.

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Function Description

1 System Co-ordination Operate local and regional areas and co-ordinate energy and power transfers with other networks and systems to enable whole system planning, operation and optimisation across different timescales. System Co-ordination could include local actions to support thermal, voltage and frequency management across networks including actions to minimise losses, manage constraints and provide capability.

2 Network Operation Operate the electricity distribution network to maintain a safe and secure system. Ensure that network powerflows remain within limits and that the network operates within acceptable voltage limits. Ensure that the network remains secure against credible evets such as circuit trips and generation loss. Identify and manage current and future risks.

Coordinate and collaborate with Great Britain System Operator (GBSO) to manage potential conflicts to support whole system optimisation. Respond to customer needs.

3 Investment Planning Identify capacity requirements on the distribution network and secure the most efficient means of capacity provision to customers.

Co-ordinate with the GBSO and Transmission Owners to identify whole system options. These would include commercial DER options as well as distribution network investment.

4 Connections & Connection Rights

Provide fair and cost effective distribution network access that includes a range of connection options that meet customer requirements and system needs efficiently.

DSO Functions – September 2017

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Function Description

5 System Defence & Restoration

Enhance whole system security through the provision of local and regional flexible services. Provide system resilience to very low probability but high consequence events using risk based approaches. Provide the means to re-establish the wider synchronous area in the event of widespread disruption.

6 Services / Market Facilitation

Interface with the GBSO and other network operators to enable the development of distribution capacity products, the creation and operation of local network service markets and to enable DER access/participation in wider services for whole system optimisation.

Facilitate local and national markets to access and settle services through auctions and other market arrangements for whole system efficiency. Ensure these arrangements are fair and transparent.

Provide information and control system infrastructure to facilitate local and national markets and service provision.

7 Service Provision Access services on behalf of others, or provide services to others, where doing so is necessary to maximise whole system efficiency, and protects competition. Use own services to manage other risks on the network and contribute to resilience.

8 Charging Sets Distribution Use of System prices for local network. Determines Point of Connection.Determines connections charges and informs of Transmission reinforcement charges (if applicable)Consideration to Exit Charging (dependent on size, variations and apportionment)

DSO Functions – September 2017

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Breakout Session 3Case Study for SGAM models

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Case Studies

EATL will deliver a presentation on the day that demonstrates the application of the Smart Grid Architecture Model (SGAM) to an Open Networks case study that relates to the transition from DNO to DSO. These case studies will include:

• DSO World A: DSO Coordinates

• DSO Function: Network Operation

• DSO Activity: Operate network within thermal ratings

• DSO Process: Activation of distributed energy resources for D-network thermal

constraint management

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Wrap-UpNigel Turvey – ENA Open Networks Chair

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Wrap Up

• There are some challenges ahead if we want to meet our carbon targets while providing a safe and secure energy grid at an affordable price

• However, by enabling flexible networks we can address these; open up new markets for customers for low carbon and innovative technologies; and deliver efficient network costs for consumers

• We are working together and dedicated to making this work with input from stakeholders in an open and transparent way

We welcome feedback from all our stakeholders. If you have any comments that you would like to

share, please feel free to submit them to [email protected].

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AOB/Close

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