Stephan Wachtel, GE Representing the EWEA Working Group Grid Code Regulations

1. The draft ENTSO-E NC RfG and its potential im-pact on cost-effective grid support by wind power Stephan Wachtel, GE Representing the EWEA Working Group Grid Code Regulations EWEA 2012 Annual Event

2. The EWEA Working Group Grid Code Regulation (WG GCR) • Main objective: Harmonisation and Improvement of Grid Code Requirements for Wind Turbine Generators and Wind Power Plants in EU • The WG is formed as an internal EWEA working group with representatives from manufacturers, developers, operators, consultants and test & research institutes. • Established in 2006, 5.. 6 meetings p. y. typically in Brussels • Convenor: Frans van Hulle, Technical Expert for EWEA • Representing EWEA at ENTSO-E level with regard to Network Codes including User Group meetings and consultations • 400 individual comments & proposal to the public NC RfG consultation were collected by WG, 70 provided to ENTSO-E as official EWEA response. For further information please contact: Paul Wilczek, EWEA: pwi@ewea.org

3. (Hi)Story of a decade of Grid Code developments in the EU • Highly diverse and detailed codes appear constantly • Inadequate formulations and definitions • Codes change frequently (“moving target”) • Lots of interpretations & discussions arise constantly for individual projects • Lack of justification e.g. by cost-benefit analyses Consequence: • Lack of common best practice (routine & consolidation) • All involved stakeholders face high, exceeding costs for products and projects • Deficits in Grid Codes endanger long term system security (and this the real BIG money)

4. EWEA Generic Grid Code Format The proposed improved way forward • Wind related complete document. • A sequential and structural commonly agreed best practice • Sharp and clearspecifications • Reference to POC And the desired pathway... • Constructive engineering dialogue with ENTSO-E • National codes could be adopted gradually over a relative long time period (wind part) • Revision or changes would have been relative easy • Technical numbers could be adopted/changed gradually

5. Grey Zones: Cross-check ENTSO-E draft NC RfG vs. GGCF Legend:  Meets GGCF  Slight mismatch  Strong mismatch or even not addressed at all by ENTSO-E not addressed at all by ENTSO-E, but not critical General Items Steady State Performance Dynamic Performance

6. Further thoughts on the NC RfG • The NC RfGis not yet a sharp and clear specification in all respects • It results from ENTSO-E deliberations rather than dialogue with relevant stakeholders and this is a weakness. Incomplete TSO understanding of generator issues (and vice versa) leads to sub-optimal proposals and encourages conflict (confrontational ENTSO-E/stakeholder meetings and over 6000 comments on the draft NC) • Mechanism for revision are subject to procedures of EU Laws. • Technical numbers are hard coded into the NC ( inflexible) or left for determination by Relevant TSOs (possibly not transparent and unfair) • National Codes must be adapted over a specified and relatively short period which may affect the quality of the outcome and will impact on the resources of all stakeholders.

7. Key principles for a Grid Code: complete, unambiguous, open On the other hand: Openness is necessary to enable the development of more cost-effective technologies On the one hand: Lack of completeness and ambiguous language leads non-cost effective solutions The right balance must be found. Complete, well defined, explicit Enables cost-effectiveness Within a “solid precise frame”: Maximum space for the development of cost-effective technologies and solutions Gaps Costs!!

8. Developing cost-effective solutions need ALL relevant information Connection Requirements and Processes Connection requirements determine key conditions for the development of cost-effective grid-support by wind power. But further information, determined in other Networks Codes need to be known, too! Based on this an overall and fully transparent cost-benefit- analyses could be support. System Operation Ancillary Services & Remuneration System Planning

9. Ongoing tasks for EWEA: Next steps ENTSO-E / ACER / EC 3-year workprogramfor NC-drafting • The NC “RfG” is just one important Code among 15 further ones • EWEA will participate atfur-ther stakeholder consultations • The EWEA GGCF will be developed and promoted as a template and best practice for implementation of enforced NCs on national level.

10. Summary & Conclusions • The wind industry proved: Wind power successfully supports power system security (even under existing EU grid codes and their deficits) • Proposals by EWEA to improve the draft NC RfG and to overcome identified critical deficits are available. • At the end the entire set of NCs will answer this: Will the Network Codes enable or block the development of cost-effective grid support by wind power? • EWEA will continue to constructively participate in the stakeholder consultation during the whole developing & drafting process and national implementation.