1

 Issued on July 6, 2011, entitled:

“Resolution Adopting the Amended Rules on

the Definition and Boundaries of Connection
Assets for Customers of Transmission
Provider” (“Resolution No. 16”)

2
 PIPPA seeks the following amendments to
Resolution 16:

◦ First: Replacement of Diagram 4 of Annex C with

Diagrams 4-A and 4-B (*Main amendment being
sought)

◦ Second: Revision of the definition of “Connection

Assets” in Section 2.0 of Annex A

◦ Third: Inclusion of the definitions of “Generator”,

“Distribution Utility” and “Load Customer” in Section
2.0 of Annex A

3
 Replace Diagram 4 of Annex C with Diagrams 4-A and
4-B

PIPPA’s Reasons:

 Proposed Diagrams 4-A and 4-B distinguish between

assets that are shared with another Generator and those
that are not, whereas Diagram 4 does not.

 Unlike Diagram 4, the Proposed Diagrams are consistent

with Section 4.2 of Annex A:

“Connection Assets for Generation Customers of

Transmission Provider include those assets from the last
Single Mechanical Connection of a User System or
Equipment of a Generator, at its Connection Point, to the
last Single Mechanical Connection which is not shared
with another Generator within the Grid”.

4
 The Published Diagram erroneously classifies connection assets
such as switchyard or related facilities as transmission assets if
another customer of NGCP happens to be connected to those
facilities, even if that other customer is merely a load customer of
NGCP and is not itself a GenCo …

5
 Proposed Diagrams 4-A & 4-B:

6
 ◦ “Connection Assets (CA): Those assets that are put in place
primarily to connect a Customer/s to the Grid and used for
purposes of Transmission Connection Services for the
conveyance of electricity which if taken out of the System, will
only affect the Customer connected to it and will have minimal
effect on the Grid, or other connected Customers. For the
avoidance of doubt, Connection Assets exclude a User System
or Equipment or other Facilities owned by a Customer such as a
Load Customer or a Generator, which User System or
Equipment or other Facilities shall remain owned by such
Customer.” (Proposed revisions underscored)

NGCP’s argument:
 “NGCP disagrees with the proposal of PIPPA. NGCP proposes that the
existing definition be retained.”

PIPPA’s counterargument:
 It is in the interest of all concerned that the boundaries of “Connection
Assets” are clearly defined, especially considering the significant
investments required for the construction of new plants to address the
country’s rapidly increasing energy requirements.

7
“Generator: Has the same meaning as Generation Company under the
Philippine Grid Code, which is a person or entity authorized by the ERC
to operate a facility used in the generation of electricity.”

“Distribution Utility: Has the same meaning given to this in the

Philippine Grid Code, which is an Electric Cooperative, private
corporation, government-owned utility, or existing local government
unit that has an exclusive franchise to operate a Distribution System.”

“Load Customer: A Distribution Utility or other End User that receives

electricity through the Grid.”

NGCP’s argument:
 “NGCP is in a position that it is best practice to cross reference the definition with
the primary document.”

PIPPA’s counterargument:
 Resolution 16 does not say which document should be cross-referenced for the
definition of these terms; not ideal considering the myriad ERC issuances existing

8
 NGCP’s proposed solution: revise the definition of “Connection Assets
for Generation Customers of Transmission Provider” to make it
consistent with Diagram 4, Annex C of Resolution 16:

“Connection Assets for Generation Customers of Transmission

Provider include those assets from the last Single Mechanical
Connection of a User System or Equipment of a Generator, at its
Connection Point, to the last Single Mechanical Connection which is
not shared with another Generator Customer within the Grid.”
(Section 4.2, Annex A)

PIPPA Counter:
 NGCP’s proposal is unusual. It is Diagram 4 that should be amended
and not the definition in Section 4.2, because the diagram was meant
to illustrate the definition, and not the other way around.

 The existing definition in Section 4.2 is consistent with the definitions

contained in previous issuances of the ERC (Resolutions 25 as and 41)
pursuant to which the GenCos have designed their Generation Plants.

9
 Diagram 4 is “consistent with Section 9 of the EPIRA”,
which provide:

“A generation company may develop and own or operate

dedicated point-to-point limited transmission facilities
that are consistent with the TDP : Provided, That such
facilities are required only for the purpose of connecting
to the transmission system, and are used solely by the
generating facility, subject to prior authorization by the
ERC ...” (Section 9 of EPIRA; emphasis supplied in NGCP
presentation)

“With an End-user connected at the Generator’s

switchyard, the Generator is already performing
a Transmission Function”

10
o NGCP assumes that the switchyard facilities of a
Generation Plant are “transmission facilities” -- but
they are not

o The ERC’s Subtransmission Guidelines, as amended,

provides:

‘Transmission Assets’ shall refer to the grid-wide

electrical infrastructure through which electricity flows
in large quantities between generators or generating
plants consisting of several units or blocks of
generators and the many more dispersed load centers.
*** (Emphasis supplied)”

o Thus, functionally, an asset is not a “Transmission

Asset” simply because it happens to connect one
generation plant to a DU

11
o The “dedicated point-to-point limited facilities” referred to
in Section 9 of the EPIRA and its IRR refers to a line
(composed of wires, poles or towers, insulators, line
hardware) used to connect a Generation Plant to the grid
or to a DU system without any entity connected in
between

- They do not include the switchyard of the Generation

Plant at which one end of the line happens to be
connected.

o The switchyard of the Generation Plant forms part of the

GenCo’s User System (Section 5.4.4.1 of the Amended
Grid Code)

12
 Power Transco/NGCP
plant/Customer Switchyard or
-owned Substation
Switchyard or
Substation (User
System)

13
 The definition of “Connection Assets” in
Section 2.0, Annex A of Resolution 16 is
consistent with the definition of connection
assets in other jurisdictions

 Inpractice, there is a broad diversity in

connection assets, which depends on the
intended operational and business purposes
they will serve.

14
 In most jurisdictions connection assets are established
through a connection process, pursuant to “grid
investment agreement” between the grid asset owner
and the connecting customer.

 The type and complexity of the connection assets, and

ownership “who provides what” is flexible - a matter of
negotiation through the grid investment agreement.

 The definition of “Connection Assets” is not a physical

or a technical definition, but rather a term that signifies
the assets that the connecting customer must provide
for himself or, if provided by the grid owner, then
assets to which full cost recovery will apply, as set out
in the grid investment agreement.

15
 SHALLOW CONNECTION DEEP CONNECTION SHALLOWISH CONNECTION

GRID GRID GRID

SHARED-USE ASSETS SHARED-USE ASSETS SHARED-USE ASSETS

GR CA

GR CA
GR CA
CA
CA CA

G G G

CA CONNECTION CUSTOMER PAYS FOR

GR COST SHARED AMONG GRID USERS

16
17
 Connection assets are links in the electricity
network that are constructed to connect one grid
customer at a location in the network.

 There is a broad diversity in types of assets which

serve as connection assets, ranging from entire
switchyards and transmission lines, to as simple as
the conductors that link a generator to a
transmission switchyard. The form depends on the
purpose they will fulfil.

18
 For example, if the need to connect a new power plant to the
grid causes the construction of a switchyard, then the
purpose of that switchyard is that of a connection asset.

 In contrast, if the grid company requires a new switchyard to

be constructed to increase grid capacity or reliability, then
that switchyard is a grid asset.

One cannot be assumed to be the other, because each is

created to fulfil separate technical purposes.

 Some customers want complex connection assets to provide

more flexibility and reliability through redundant plant.
Others want the absolute bare minimum because they are not
so concerned about reliability/availability but more concerned
about the initial cost.

19
 Is the definition of “Connection Assets for Generation
Customers of Transmission Provider” in Section 4.2,
Annex A of Resolution 16 consistent with the definition
of connection assets in other jurisdictions?

o There is a wide diversity in the forms and the extent

of connection assets of power plants in other
jurisdictions.

o There is also wide diversity in the forms and extent

of connection assets of distribution customers,
which may in turn, connect generation with the grid.

20
 POW
ER PL
ANT
CONNECTION
ASSET

21
The 500 kV Connection Assets of ~ 320 km of 500 kV Transmission
Nam Theun 2 Corporation - Laos Line Connecting NT2 to EGAT RE2
Substation

22
 At; Industry Parks - Steel Mills – Oil & Gas Facilities – Pulp & Paper
Mills – Sugar Refineries – Mines – Port Facilities – Municipal
Substations - - - - Etc.
Transmission Grid

EXPORTING TO THE GRID

G1 CAPTIVE POWER PLANT G2

ESTABLISHED OR TAKEN OVER BY IPP

INDUSTRY-OWNED
SWITCHYARD

SUPPLYING LOCAL DEMAND

23
 All of the power plant projects completed by my
AECOM T&D Group in the last four or five years have
been Hybrid and Embedded generation projects.

 These were: NT2, Banpu, McKee, Mokai, Nga Awa

Purau, Ngatamariki, Rotokawa, Condong,
Broadwater, and Norske Skog.
 None of these are direct connected generators.
All these generators are connected to NO/NSP via
HV Switchyard owned by either the Generator or
the Industrial Customer.

 No one questions that a Distribution Company “Grid

User” owns switchyards for its distribution business
purposes. Why should we question that a Generation
Company would own switchyards?

24
NGCP Comment:
The Report does not consider NGCP’s main argument that …
“Resolution 16 did not reclassify the Genco Switchyard and other
related facilities into transmission assets”.

AECOM Reply:
 Energy law very young law and due for change, according
to: “not what is, but what could be” , i.e., music industry and
national postal service vis-à-vis banking/financial services

 The Australian Energy Market Commission (AEMC) has in

the Transmission Frameworks Review ‐ Chapter 11, called
for contestable ownership of power plant switchyards , to
end the economic inefficiencies and the asymmetry in
negotiating power between connection proponents and the
Grid Company

25
 The switchyards should be transferred to NGCP
because of “Competitive Purposes”.

◦ “The generator is already competing with the

transmission provider”; and

◦ DU’s connected to Grid via generator-owned

asset cannot procure and compete for the
lowest priced electricity”
• “Owner of generator-connection asset can deny access
between competing generators/RES”;
• “No alternative source of supply if generator connection to
the grid is unavailable”; and
• “The alleged ‘savings’ of the DUs can easily be wiped out by
uncompetitive pricing.”

26
 GenCos are not in competition with NGCP

◦ “Competitive purposes” refers to competition among

Generation Companies.

• reason for transferring ownership of the assets to a third

party (i.e. NGCP) – so that a GenCo cannot control the
ability of another GenCo to supply electricity to the Grid
• transferring ownership of these assets to NGCP unfairly
favors one competitor (NGCP) against the other (GenCo)

 GenCos do not compete with the DU’s

• No DU is compelled to purchase electricity from a particular
GenCo, whether or not it is directly connected to the DU
• A direct connection to a GenCo benefits the DUs and their
customers because of “cheaper electricity” - No PDS charges
• Frequently, DUs directly connected to a GenCo are also
connected to the Grid via another line

27
 A switchyard is part of a power plant, if it has
been built primarily for the purpose of
conducting the business of power generation.

o New power plant is developed near its fuel source. It will

have a switchyard – for its own operational & business
purposes – reliability, maintenance, expansion, etc.

 A switchyard is not part of a power plant if it has

been built primarily for the purposes of the
shared grid, even if power plant connects to it.

28
 In a contestable generation environment, the purposes
for which a power plant owner owns a switchyard, are
his own. We can presume they are related to the way he
wants to conduct his business.

 His commercial art, must be private and confidential in

the normal commercial sense. We can just say the
switchyard is a part of his business. If he no longer
requires it, he could choose to sell it to a willing buyer.

 In contrast, the grid owner would rightly construct a

switchyard once it has completed a formal planning
process, which demonstrates the need for a defined,
least-cost augmentation of the system.

29
 Before the deregulated electricity system, the
Generation Development Group of the vertically
integrated electricity company always specified
and developed a switchyard as a part of a power
station development.

 The job of the Transmission Group was to

develop only grid substations and switching
stations in order to strengthen and increase grid
capacity.

30
NGCP Comment:
“We need to own the power station switchyards because we
rely for grid security on the correct performance of
equipment that is owned by NGCP”

AECOM Reply:
 this is a narrow view which is not in keeping with the
realities which underpin grid security.
 The continued maintenance of grid security is, and will
always be, utterly reliant on plant and equipment which is
owned and operated by grid users
 Rather than improving security, the modified facilities
would increase the complexity and decrease the rationality
of the systems,

31
 “The acquisition of a power plant’s switchyard
does not affect Grid Security.”

 There are no means by which the acquisition of a

grid-user customer’s assets could be justified
under a regulated, grid investment process.

 If there is a need for any asset, then the Grid

Investment Process ensures that grid company
can fund its own asset.

32
 G G

CA CA

CA

CA
G

G
GRID
GRID
SHARED-USE
EXPANSIONASSETS
CA

CA
G

G
CA CA

G G
CA CONNECTION CUSTOMER PAYS FOR

GR COST SHARED AMONG GRID USERS

33
1. Demonstration of the need for an addition to the grid
through a process of engineering and economic assessment
by valid means. For example, simulation.

2. Consideration of a range of valid alternative solutions, to

determine the solution with the least cost.

3. Demonstrating that the cost of the proposed solution will

return benefits to grid users that are in excess of the cost
imposed by the proposed solution.

 Investment proposals are subjected to a Regulatory

Investment Test – (RIT).

34
35
36
 I know of no mandate by which it could disrupt its
customers’ businesses by breaking them up.

 I know of no cases wherein Power Plant switchyards

have been compulsorily acquired from Power Plant
Owners by the Grid Company.
 I have been Expert Witness in the break up of a Power
Generation Business wherein the High Court decided that:-
“Any assets created as part of Power Plant are parts of the
Power Plant and must remain with the Power Plant in the
division of assets to be sold separately.”

 Transferring ownership of power plant switchyards

would DECREASE RELIABILITY and INCREASE THE
COST of the grid for users and the public.

37
38
Mostly - the only effective
approach is to undertake a
Complete Rebuild.

39
40
 There are many and better ways of improving
grid reliability other than increasing the
number of assets

Better designs - better materials – more standardisation –

Reliability Centred Maintenance – (FMECA) – clear and
exacting systems performance requirements – better
condition monitoring and testing – better in-service
training of engineers – stricter compliance and reporting –
proactive investigations of non-compliances – well
developed codes and standards of performance –
 and also: “N-1 and “N-2”

41
 For the Transmission Industry; the formal consideration
of reliability centres on “N-1” and “N-2”, which is not
efficient.

 Other reliability techniques are not formally

implemented within utilities. Grid reliability would
benefit from any and all of the initiatives listed on the
previous slide.

 Current initiatives being undertaken by utilities include:

o Changing the utility’s culture from being “CAPEX-led” to

being “Services-led” with “Asset Management” as the
focus.
o Improving the quality of organisational function e.g.,
training and adopting PAS55, is the current target for
leading utilities.

42
 No effect on grid security if a power plant’s
switchyard connects the plant to the grid and at
the same time directly connects the plant to a
distribution utility, if correctly engineered and
adequate planning and operational processes are
followed.

 There is a recognised commercial problem - the

reduction in Grid Company Revenues resulting
from such connections.

o The commercial concerns of the grid

company can be addressed, but not by
restricting connections.

43
 Direct connection to a DU enhances a power
plant’s operational efficiency.
o Serving local load reduces transmission losses
and therefore increases power plant efficiency

 Most System Operators formally practice

“Locational Marginal Pricing” (LMP) to weight
the bid-prices in favour of power plants that
are closest to the load prior to determining
the order of dispatch.

o The method of determining LMPs is to consider

the system losses.

44
 Many technical advantages of connecting a
DU directly to the switchyard of a power plant

o The main advantage is an improvement the

efficiency of the utilisation of the transmission
grid assets.
o There is also a general improvement in the
reliability of supply for the local distribution
customers, if the facility is effectively
engineered.

 There are no disadvantages.

45
NGCP Comment:
“Institutional arrangements such as MOA’s recommended by
AECOM as the least cost solution to grid reliability will not
capture the peculiarities in the switchyard operations ”

AECOM Reply:
 (In my experience,) both power plant owners and grid
owners contract out this kind of work (O&M) to the same
qualified third parties operating in the commercial services
sector, with satisfactory results.

 Conversely, the failure to do so, creates a poverty of ideas

and points of view, promoting frailty in the approaches
being practiced, which not only creates inefficiency, but can
lead to a decrease in grid security

46
 Hybrid embedded generation (where a power
plant is connected to a grid and at the same
time directly connected to a distribution
utility or other end user) is allowed in other
jurisdictions

o In fact, it is very actively encouraged by

governments, and actively facilitated by
Electricity Regulators through preparation of
suitable codes and standards for planning,
connections and operations.

47
 Issues in determining whether or not hybrid &
embedded generation should be allowed:
o Precedent – they existed in isolation before the grid, and
continue operation after grid connection
o Requirement for green energy, and energy efficiency
o Advances in technology have created many new forms
o Effective international standards have been prepared
allowing ease of connection and operation.

 Issues in determining why they are not allowed:

o Opposition from Grid Companies about loss of revenue and
increasing operational complexity of the grid
o Lack of grid planning processes that allow for the effects
and the needs of HG/EG
o Poor technical administration of connection processes
o Misplaced concerns about the security impacts on the grid

48
49
 Hybrid & embedded generation is encouraged in –
All States of the European Union - The United Sates
–Australia - New Zealand - The Pacific Islands - Parts
of Asia – e.g. Singapore, Laos. It is the Future
LV DA
Distribution
MV Bus
Distribution DA
Bus Low Voltage
Sub-trans Network
Distribution DA
Bus Distribution LOAD
DG
Network
Transmission Sub-trans LOAD DG DMR
DG
Network Network
LV Load
LOAD DG DMR Bus
DG
MV Load
DG Bus
CG LOAD DMR
Sub-trans
Transmission
Load Bus
Load Bus DMR

50
51
 Considerations for allowing hybrid embedded
generation:

o Effective technical arrangements – and Least

Cost!

o Negotiations between PP Owner and the

Connecting Party. Less costly for the
community than grid supply. Improves
community support for the PP Development.

o Sometimes, there is a government agency

requirement to offer supply to local
communities.

52
 How were hybrid embedded plants connected
the grid and to a distribution utility or other
end user?

o Preparation of Appropriate Codes of Practice

for technical and commercial administration of
the connections

o Current Best Practice in my opinion is

according to IEEE Standard 1547 – 2003
Standard for Interconnecting Distributed
Resources with Electric Power Systems.

53
 Review

54
NGCP Comment: There is no such thing in the Philippines as
“Hybrid Generator” as defined by the Report

AECOM Reply:

 I agree with NGCP’s research on the definition of Hybrid

Generation. However, this point was canvassed in full with
PIPPA at the earliest stage of consultation, and the Hybrid
generation being referred to in the report is fully applicable
to the Philippine context.

 In fact, we bracket the terms Hybrid and Embedded when

referring to generators in the Philippine context, and
indeed, in the context of other countries’ power systems,
as technically one and the same.

55
 Diagram 4 Annex C effectively prevents DUs from
directly connecting to a Generation Plant that also
supplies electricity to the Grid -

 DUs are allowed by the Distribution Code to connect to a

generation facility and that in so doing it does not compete
with transmission:

“Section 2.8.1 Interconnection and Operating Agreement

of Distribution Service and Open Access Rules (DSOAR),
states: "A generator shall execute an appropriate
agreement with the DU governing the interconnection and
operation of generating facilities“

 Diagram 4 Annex C will make electricity in the

Philippines even more expensive than it already is -

 by unnecessarily requiring consumers to pay PDS charges

even when they are directly connected to a generator

56
 Diagram 4 Annex C will not make electricity
more expensive

 It is not appropriate for Gencos to promote

their power plants to local communities by not
paying Power Delivery Services (PDS) Charges
o The PDS is only about 10% of the household cost of
electricity. Savings can easily be achieved without “by-
passing the grid”
o PECO has one of the highest electricity rates in the
Philippines even though it “by-passes” the grid and remains
a captive customer of PEDC
o VECO should have entered into a supply contract with a
cheaper plant like KSPC

57
 Summary of the increase and decrease to VECO’s customers
bill in VECO’s application for the 138kv Connection Asset – a
36km 138kV line between CEDC and VECO’s Colon
substation shows a net decrease of P0.0744/kwhr.

 NGCP’s assertions on cost-savings are misplaced.

• The DU should do BOTH: (a) reducing the PDS charges it
passes on to its customers, AND (2) procuring least-cost
power supply
• In approving supply contracts, the ERC already sets
stringent efficiency caps
• Generators are already forced to be as efficient as they
can reasonably be by the efficiency caps
• A 10% reduction in generation costs, simply by efficient
operations, is quite farfetched
• Lastly, a savings of 10% is already very significant to
consumers, especially residential consumers. It should be
encouraged

58
 Diagram 4 Annex C will discourage
construction of new Generation Plants with
large generating capacities -
◦ new and large generation plants are necessary to
address rapidly increasing electricity needs;

◦ larger plants produce more electricity at lower

costs;

◦ local governments will hesitate to allow the

construction of a large generation plant w/out
direct benefit to constituents;

◦ no DU can fully absorb the entire output of a large

Generation Plant

59
 Resolution 16 will not prevent large capacity power projects

o NGCP receives several System Impact Study applications

from prospective large capacity generation proponents
o it is NGCP’s position that all large generation plants with an
aggregate connected capacity of more 20MW should be
grid connected and not embedded to the DU’s system.

PIPPA’s Counter-Arguments:

 At present there are power plants greater than 20MW and are
embedded in a DU system. The operation of these plants did
not cause any severe disturbance to the grid during normal
operation. There should be proper ramping up/down to
avoid disturbance in the frequency. A direct connection to
the grid won’t solve the problem if they do not follow the
proper procedures.

60
NGCP Comment:
 It is not true that transmission cost will increase with certainty
due to unchallenged technical position of single owner who will
have no opportunity or cause to optimize the way it provides its
service (citing its VECO case analysis)
 When a DU is directly connected to the switchyard where a grid
connected generation plant also connects, such DU also directly
benefits from the grid.

AECOM Reply:
 Based on experience, the contestable model for provision and
ownership of certain Grid assets has provided assets with lower
capital costs and therefore, according to the remuneration
models for grid owners, it should wash out as lower costs for grid
users;
 Grid Owners tend to promote capital/asset intensive solutions,
and are generally backward in applying techniques which require
fewer assets but would achieve the equivalent results

61
o “ensure and accelerate the total electrification of the country”;

o “ensure the quality, reliability, security and affordability of the

supply of electric power”;

o “ensure transparent and reasonable prices of electricity in a

regime of free and fair competition and full public accountability
to achieve greater operational and economic efficiency”;

o “enhance the inflow of private capital and broaden the

ownership base of the power generation ... sector”

o “protect the public interest as it is affected by the rates and

services of electric utilities and other providers of electric
power”;

o “provide for an orderly and transparent privatization of the

assets and liabilities of the National Power Corporation”

62
I. Resolution 16 be amended to convey the following intent:

 Assets constituting assets at the boundary of the shared transmission grid

shall be classified as either:
a. Dedicated Connection Assets; or
b. Identified User Shared Assets

WHERE:

 Dedicated connection assets are transmission assets: developed

and constructed for the purpose of connecting an Identified User
Group to an existing transmission network used exclusively by
the relevant identified user group and for which the costs of
developing, constructing, operating and maintaining are not
recoverable from the broader customer base as charges for
prescribed transmission services.

63
 Identified user shared assets are those parts of a substation which,
while forming part of the shared network, are required solely for the
connection of an identified user group. More precisely, identified
user shared assets are shared assets developed and constructed for
the purpose of connecting an identified user group to an existing
transmission network, but not used exclusively by the relevant
Identified User Group.

 Wherein an Identified User Group shall refer to any group of

transmission customers who have (entered into) an agreement to
share a common grid connection point wherein they have contracted
for transmission services as a single grid customer1. The Identified
User Group shall be treated for grid planning and operational
purposes as a single Hybrid Grid Customer.

1 Wherein a grid connection point may comprise a single or a multiple

interconnection with the shared grid, with the security, reliability and
capacity, considered appropriate under normal, prevailing grid planning
criteria.

64
 DCA
CG

SHARED CONNECTION
Identified

ASSETS
User Group
SHARED-USE
EG
TRANSMISSION ASSETS

EG
Distributor, or a
EG

DCA
Large Industrial
Customer

CONNECTION CUSTOMER CAN OWN

GR COST SHARED AMONG GRID USERS

CG LARGE CENTRAL GENERATORS

EG EMBEDDED GENERATORS

DCA DEDICATED CONNECTION ASSETS

LOAD CUSTOMER

65
 Asset type Description Paid for by Contestability

Shared assets
Identified user shared assets
Dedicated connection assets
Used by the broad base of
consumers.
Required for connecting an
Identified User Group.
Required and used
exclusively by connecting
generator or load.
All market customers
(through Transmission
Charges).
Identified User Group and
All grid customers, through
Transmission Charges[1] .
Connecting generator or
connecting load.
Built, owned and operated by
Transmission Grid Owner or
Franchisee.
Transmission Grid Owner or
Franchisee accountable[1] for
operation, control and
maintenance. Construction and
ownership contestable.
Construction, ownership and
operation contestable.

[1]
The proportion to be assessed in proportion to the use of the shared assets by the Identified User Group relative to other customers of the Shared Network.
[2]
For avoidance of doubt “accountable” shall mean responsibility for ensuring adequate standards are met, but it shall not be taken to mean direct
responsibility for carrying out operating ad maintenance services.

Wherein Contestable shall mean proponent party (or parties’) access to

alternative means of construction, ownership, operation and maintenance
which may be selected and/or negotiated with the Transmission Grid
Owner or Franchisee, subject to the observance of standards set by the
Transmission Grid Owner or Franchisee.

66
 TO SIMPLIFY AND DIVERSIFY THE MEANS OF CONNECTING
TO THE TRANSMISSION GRID, SO AS TO REDUCE COSTS
AND IMPROVE COMPETITION, BY FACILLITATING THE
COMPETITIVE ASPECTS OF THE SUPPLY AND CONSUMPTION
OF ELECTRICITY

 TO IMPROVE THE BALANCE OF POWER IN NEGOTIATIONS

FOR GRID SERVICES BETWEEN THE GRID COMPANY AND
GRID USERS

 TO ENSURE THAT ACCOUNTABILITY FOR GRID SECURITY

AND RELIABILITY REMAINS FIRMLY WITH A SINGLE
IDENTIFIABLE ENTITY, NAMELY THE GRID COMPANY

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Thank you

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