Clean Energy Package Article 13 EU/2019/943: Treatment and Compensation of Renewables for Constraint and Curtailment

Last year, the SEM Committee determined which renewable (and HE CHP) generators can still qualify for Priority Dispatch. This decision was set out in SEM-20-072, which implements part of Article 12 of Regulation EU/2019/943 of the Clean Energy Package.

There is now uncertainty how renewables with Priority Dispatch need to trade in energy markets to be scheduled for dispatch, and how they will be subject to, and compensated (if at all) for redispatch, i.e. constraint and curtailment.

The SEM Committee has published:

A proposed decision on the treatment of renewable generation that do not qualify for Priority Dispatch (SEM-21-027) in scheduling and dispatch; and

A consultation paper (with strong minded-to positions) on the compensation of renewable generation which are dispatched away from their energy/market position. These minded-to positions are the SEM Committee’s view on the implementation of compensation for redispatch under Article 13 of Regulation EU/2019/943.

Article13 makes a distinction between:

Market based redispatch, where the TSO use a commercial merit order to determine who should be dispatched down first; and

Non-Market based redispatch, where the TSO uses non market rules to determine how to turn down generators.

This course intends to clearly and simply describe the concepts behind the Regulation and the SEM Committee’s position on the level of compensation proposed to be paid to generators when constrained or curtailed.

It will also identify material uncertainties around the overall proposals that necessitate clarification.

**Note** This course is not intended to propose consultation response strategies for individual market participants, but will clearly draw out the implications for different generators, e.g. between new renewables without Priority Dispatch and old generators without Priority Dispatch.

Attendees should be in a position to qualitatively assess the SEM Committee’s proposals against their own interests in the industry, and develop informed responses to the SEM Committee’s Proposed Decision and Consultation.

• Controllable REFIT, RESS, ROC and merchant wind and solar generators
• Dispatchable generators
• HE CHP generators (either separate or through a DSU)
• Traders and providers of PPAs

• The requirements of Article 12 and 13 (with a focus on Article 13) of the EU Regulation EU/2019/943
• The SEM Committee’s interpretation of those Articles’ requirements, in the light of the SEM design
• The qualitative impact of these proposed decisions and minded to positions on overall dispatch. This will be evaluated layering on the PPA provider – generator relationship, rather than assessing just the impacts between trader and market.
• Identification of any gaps and inconsistencies of the SEM
• Committee’s positions
• Critical evaluation of timelines for next steps

Hugh Mullany is director of Mullany Energy since 2003. He has advised    over 250 clients from all aspects of the electricity market in Ireland and Northern Ireland, providing, amongst other services, independent advice on route-to-market services for generators, system services, the wholesale market design, and renewable energy support schemes.

He has advised c. 2GW of renewable projects on their Power Purchase Agreements in Ireland.