YOUR ASSET IN THE NEM, HOW TO MAXIMISE VALUE AND MINIMISE RISK - WHITEPAPER BIDDING - Overwatch Energy

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YOUR ASSET IN THE NEM, HOW TO MAXIMISE VALUE AND MINIMISE RISK - WHITEPAPER BIDDING - Overwatch Energy
WHITEPAPER

YOUR ASSET IN
THE NEM, HOW TO
MAXIMISE VALUE
AND MINIMISE RISK
PART THREE
BIDDING
YOUR ASSET IN THE NEM, HOW TO MAXIMISE VALUE AND MINIMISE RISK - WHITEPAPER BIDDING - Overwatch Energy
2 OVERWATCH ENERGY: WHITEPAPER

BIDDING

THIS WHITE PAPER IS THE THIRD IN A FOUR-PART SERIES BY
OVERWATCH ENERGY THAT HELPS YOU MAXIMISE YOUR VALUE
AND MINIMISE YOUR RISK IN THE NATIONAL ELECTRICITY
MARKET OR NEM. IN PART 1 WE LOOKED AT THE RULES -
WHAT THEY SAY ABOUT OPERATING PLANT AND WHAT THAT
MEANS YOU NEED TO DO. IN PART 2 WE CONSIDERED ASSET
PERFORMANCE AND HOW YOU CAN MAXIMISE THE VALUE OF
YOUR INVESTMENT.
IN THIS PART 3 WE LOOK AT BIDDING IN MORE DETAIL WHILE IN
PART 4 WE WILL EXAMINE WHAT CHANGES ARE COMING UP IN
THE MARKET THAT YOU NEED TO BE AWARE OF.
Photos courtesy of Lincoln Gap Wind Farm, with thanks to Nexif Energy.

PART 3 - BIDDING
You’ve done the hard work - found a great site, developed the project, got the key contracts and finance
sorted, battled through construction, registration and commissioning - now sit back and enjoy your rewards
for the next 20-25 years.
Unfortunately, it’s not that easy and not something that can simply be done by a piece of software
automatically all the time under all circumstances! You are now operating a power station in a wholesale
market which is getting more complex by the month and will continue to evolve. How do you turn those
assumptions in the financial model into reality and make sure you don’t fall foul of the rules?

1. YOUR OBLIGATIONS                                                      3.7B: “… submit…in accordance with the
Before diving into the different aspects of bidding,                     timetable, the plant availability…notify…as
it’s important to understand your legal obligations                      soon as [you become] aware of any changes”
as a NEM participant, which for bidding can be                           3.8.2(a): “…submit generation dispatch
categorised into two types: availability bidding                         offers…for each trading day”
and commercial bidding. For these, clauses 3.7B,
                                                                         3.8.22A(a): “…not make a dispatch
3.8.2(a) and 3.8.22A of the NER should always
                                                                         offer, dispatch bid or rebid that this false,
be front of mind which indicate you need to:
                                                                         misleading or likely to mislead.”
YOUR ASSET IN THE NEM, HOW TO MAXIMISE VALUE AND MINIMISE RISK - WHITEPAPER BIDDING - Overwatch Energy
BIDDING: PART THREE 3

                                                             As we noted in this recent article, these Rules
                                                             come with large civil penalties so the consequences
                                                             of not understanding or following them can be
    Key Points
                                                             very costly. Bearing this in mind, we now look at
    • A
       vailability bidding is not a ‘set                    availability bidding, bidding for commercial reasons,
      and forget’ activity. It requires                      rebid reasons and the role of automation.
      communication with onsite O&M
      providers to inform AEMO of                            2. AVAILABILITY BIDDING
      planned and unplanned outages.                         In this section, we consider the three types of
                                                             availability bidding that together comprise the
    • D
       aily offers of energy price and                      Projected Assessment of System Adequacy
      volume must be submitted before                        bids or PASA. These cover three different time
      the next trading day. If you don’t                     horizons: pre-dispatch (PD), short-term (ST) and
      submit a daily offer then AEMO uses                    medium term (MT). See Table 1 for a summary.
      the last energy bid you submitted.                     The PASA is the main method AEMO uses
      Relying on the rollover of your                        to forecast the adequacy and reliability of the
      availability bids can cause you errors.                power system, but it also helps you make smarter
                                                             decisions for spot trading and outage planning.
    • U
       nderstanding the do’s and don’ts
      when it comes to rebidding is                          AEMO uses the information you provide to
      crucial, as rebids are an area of great                prepare an Unconstrained Intermittent Generator
      focus from AEMO and the AER.                           Forecast or UIGF for dispatch, pre-dispatch and
                                                             PASA forecasts. So, if that changes by any more than
                                                             6MW below the nameplate rating then as a semi-
                                                             scheduled generator you should inform AEMO.

                                                             Table 1: AEMO must prepare a UIGF for the purpose of
                                                             dispatch, pre-dispatch and the PASA. This table summarises
                                                             the scope, responsibility and AEMO timelines for semi-
                                                             scheduled generator availability obligations.

                                         RESOLUTION/                    UPDATE                 METHOD TO
TYPE            TIME HORIZON             GRANULARITY                    FREQUENCY              UPDATE

Dispatch        The next 5 minutes       5 Min Dispatch Interval        Every 5 minutes        SCADA/Self Forecast

5 Minute
                The next hour            5 Min Dispatch Interval        Every 5 minutes        SCADA/Self Forecast
Pre-dispatch

30 Minute       Current and following                                                          EMMS – intermittent
                                         30 Min Trading interval        Half-hourly
Pre-dispatch    trading day                                                                    generation availability bid

                                                                                               EMMS – intermittent
STPASA          6 trading days ahead     30 Min Trading interval        Half-hourly
                                                                                               generation availability bid

                                                                        Generally 4 times      EMMS – MTPASA
MTPASA          24 months                Trading day
                                                                        per day                availability bid
YOUR ASSET IN THE NEM, HOW TO MAXIMISE VALUE AND MINIMISE RISK - WHITEPAPER BIDDING - Overwatch Energy
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BIDDING

                                                                  Photos courtesy of Lincoln Gap Wind Farm, with thanks to Nexif Energy.

    Common Misunderstandings
    The intermittent generation availability bid through the EMMS Portal is used to calculate
    UIGF for the 30-minute pre-dispatch, STPASA and MTPASA timeframes. However, in the
    dispatch and 5-minute pre-dispatch timeframes AEMO uses only your SCADA or self-
    forecasting feed to determine availability.
    This means that you cannot influence your availability in dispatch through availability
    bidding. Instead, you must ensure that your SCADA accurately reflects your availability or
    that an Energy Offer is submitted to accurately represent what the plant can/will do in the
    future.
    This is important. Overwatch often finds errors in SCADA, turbine and inverter set-ups that
    lead to errors in availability that only get picked up by careful monitoring or detailed analysis
    by experienced NEM operators.
    Furthermore, the resulting FCAS regulation costs that mount up each month are sometimes
    wrongly attributed to other matters such as AWEFS or ASEFS – prompting further expense
    in self-forecasting when the problem and solution could well have been closer to home.
YOUR ASSET IN THE NEM, HOW TO MAXIMISE VALUE AND MINIMISE RISK - WHITEPAPER BIDDING - Overwatch Energy
BIDDING: PART THREE 5

2.1 Keeping Up to Date                                   For this you should consider things like plant lifecycle
Within the Electricity Market Management                 works and various reasons for de-rating when
System or EMMS Portal, Participants must update          establishing this forecast; and when the timing of site
the Energy Availability section when there are           works changes, make sure you have systems and
expected changes in plant events, such as:               processes in place to update your availability bid.
• Changes in the number of available turbines
  or inverters
• Planned or unplanned outages of the
  semi-scheduled generator as a whole unit
• Changes in environmental conditions, for
  example de-rating due to high temperatures                    Availability Bidding –
  or wind speeds                                                Who Should Do It?
• Generator specific requirements from the                      Whilst O&M contractors often know
  Network Service Provider or AEMO –                            about plant availability, they do not
  for example Hold-Point levels                                 always have the necessary knowledge
• Transformer, DVAR or synchronous condenser                    or experience with AEMO market
  outages                                                       systems to submit availability bids.
It is clear that lots of things can cause changes in            It can also be a frustrating activity
availability so regular communication between your              which means it simply doesn’t get
bidding team and your site staff or O&M contractors             done as frequently as it should.
is critical to meet the requirements of clause                  On the other hand your trading team
3.7B(b), Note that with the increasing penetration
                                                                are familiar with the AEMO systems
of renewables the UIGF is becoming more and
                                                                and can provide valuable market
more important for AEMO’s system adequacy
planning on a short-term horizon and failure to                 intelligence about the best times to
inform AEMO of any changes to your PASA is a                    schedule any maintenance works – which
civil penalty that attracts a fine with a $10m cap.             can reduce your cost of down-time.
                                                                Both teams have a part to play and
                                                                Overwatch works hard with its clients to
2.2 Intelligent Planning                                        improve understanding, communication
For commercial reasons it also pays to make                     and co-ordination with asset managers,
sure your plant operations staff discuss planned                owners and O&M contractors to achieve
maintenance and outages with your trading staff                 the best results for scheduling downtime.
so they coincide with market prices that suit your
commercial arrangements. For example, if you have
some merchant exposure you may not want to have
your asset out of service during high spot prices just
because it suits the schedule of an O&M contractor.
Thinking further ahead, for semi-scheduled
generators the time horizon for MTPASA is 2 years.
YOUR ASSET IN THE NEM, HOW TO MAXIMISE VALUE AND MINIMISE RISK - WHITEPAPER BIDDING - Overwatch Energy
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3. COMMERCIAL BIDDING                                    As discussed in our prior papers, there are many
In addition to keeping your availability bidding         factors that impact your BEP and your gross margin.
correct you must submit daily energy offers              The important ones are generation volume, regional
and maintain rebidding standards in accordance           reference price, regulation FCAS costs (and so
with guidelines. In practice, AEMO uses the              CPF), contingency FCAS costs, and constraints.
last energy bid you submitted and will roll this         As PPAs become more complex, including multiple
forward if you fail to submit a bid - which could        off-takers across an asset and with some merchant
be costly if that is not what you intended.              exposure as well, it can be challenging to establish
You could do nothing more than a static ‘set             your best BEP. Furthermore, as market conditions
and forget’ energy bid. However, if you want to          change with more renewable generation, factors
meet forecast returns you will almost certainly          you may previously have ignored such as constraints,
need to regularly adjust your bid in response            contingency FCAS costs and negative pricing may
to market conditions. This approach is also              need to come into play to preserve your margin.
likely to be in breach of clause 3.2.8(a).               Overwatch increasingly sees bidding strategies
To help describe commercial decision making we use       being regularly revised for these kinds of reasons,
the term breakeven price or BEP. The value of your       so next we look in more detail at three of these
BEP is influenced by the financial contracts you have    key factors: negative prices, FCAS and constraints.
in place and the specific terms of those contracts but
condensing these into a BEP guides how your asset
should be dispatched to maximise commercial value.
YOUR ASSET IN THE NEM, HOW TO MAXIMISE VALUE AND MINIMISE RISK - WHITEPAPER BIDDING - Overwatch Energy
BIDDING: PART THREE 7

3.1 Negative prices                                    To complicate matters many recent PPAs have
Figure 1 shows the increasing frequency of             clauses that shift negative price risk back to the
negative pricing over the last 21 years, providing     generator. And, whilst you could bid at your
a clear signal that your generation costs are          negative LGC value, you would still be vulnerable
no longer always ‘free’. With a Market Price           to costly FCAS and revenue-eroding constraints.
Floor of $-1,000/MWh, the NEM can be a                 A set-and-forget approach is fraught with danger.
dangerous market for unwitting Participants.

Figure 1: Increasing frequency of negative priced
trading intervals in the National Electricity Market
over the last 20 years (Jan 2000-April 2021).
YOUR ASSET IN THE NEM, HOW TO MAXIMISE VALUE AND MINIMISE RISK - WHITEPAPER BIDDING - Overwatch Energy
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BIDDING

                                                                     Photos courtesy of Lincoln Gap Wind Farm, with thanks to Nexif Energy.

3.2 FCAS liability                                       This recent Queensland event shows how volatile
The two FCAS costs incurred by generators are            and costly contingency FCAS costs can be, with
regulation FCAS - recovered by AEMO using a              some wind and solar generators incurring huge
causer-pays methodology and raise contingency            bills if they did not already have the systems
FCAS - recovered from generators in proportion           in place to respond quickly and intelligently.
to their share of generation in each trading interval.   Different to contingency costs, regulation
Therefore, avoiding contingency FCAS costs is            FCAS costs depend on your causer-pays factor
often a trade-off with energy price. If your share       (CPF) and how accurately your asset follows its
of contingency FCAS cost per MWh is greater              dispatch target. An operator with a good CPF
than your PPA or energy price, then you may              has a variety of things in place including well-
want to reduce your generation by rebidding              commissioned plant, good quality SCADA, data
– maybe even to the Market Price Cap.                    and communications, good self-forecasting and a
                                                         constant and careful eye on dispatch outcomes.
Interestingly, for semi-scheduled generators no
explicit mechanism exists other than rebidding           If an asset is not following its dispatch target – for
to higher price bands, to allow you to reduce            example a SCADA problem, then a temporary
your generation where FCAS costs outweigh                and last resort can be to rebid the asset in a
PPA revenue. This can lead to some interesting           manner that reflects its actual output.  Whilst
outcomes during times of high contingency                not a permanent solution, the underlying
FCAS and high energy prices – as observed                causes of deviation should be urgently rectified.
in Queensland in late May 2021.                          This is another example of how quick and
                                                         intelligent rebidding can improve your profit.
YOUR ASSET IN THE NEM, HOW TO MAXIMISE VALUE AND MINIMISE RISK - WHITEPAPER BIDDING - Overwatch Energy
BIDDING: PART THREE 9

In Figure 2 Global Roam have ranked solar
farms for their FCAS costs in 2020.  The high
variability shows that some do a better job
than others in managing these costs – with
direct consequences for their investors.

                                                                                           Figure 2: A plot
                                                                                           comparing the estimated
                                                                                           proportion of FCAS costs
                                                                                           to AEMO spot revenue
                                                                                           for solar farms within
                                                                                           the NEM in 20201 .

3.3 Rebidding to Manage Constraints                     dispatched ‘out of merit order’ means. If you don’t
Having considered how to avoid having to pay to         rebid to manage this then other generators may
transmit your product and how to avoid excessive        be exporting ahead of you and at your expense.
costs in your production, managing constraints
could be regarded as how to avoid blockages in
getting your product to market. Congestion or
system strength constraints can lead to curtailment
                                                                Knowing Where to Look
or uneconomic dispatch of generation out of                     You may wish to rebid generation
merit order. What can you do about this?                        below the nodal price – as opposed to
As the network becomes more congested and                       the RRP, to improve the likelihood of
AEMO needs to maintain system security, your                    being dispatched. If your trading staff
generation may be constrained ‘on’ or ‘off ’ if a               are not watching the nodal price then
constraint comes into force or ‘binds’. This creates            you will not be able to control this.
a separate price signal called a nodal or local price
in addition to the Regional Reference Price (RRP).
Crucially, it is this nodal price that determines       1Source: Marcelle Gannon, 2021. WattClarity by Global-
whether you get dispatched even though you              Roam. Ranking solar farm FCAS costs in the NEM in
will be paid based on the RRP. This is what being       2020. URL: https://wattclarity.com.au/articles/2021/04/
                                                        ranking-solar-farm-fcas-costs-in-the-nem-in-2020/
YOUR ASSET IN THE NEM, HOW TO MAXIMISE VALUE AND MINIMISE RISK - WHITEPAPER BIDDING - Overwatch Energy
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3.4 Five-Minute Dispatch and                            Figure 3 highlights the volatility that can occur in
Thirty-Minute Settlement                                dispatch prices for both energy and contingency
In Part 2 we alluded to the skills needed to            FCAS markets and how this variability can
understand how energy revenues and FCAS costs           heavily impact settlement outcomes.
are calculated under the 30-minute settlement           In this example for the 16:30 dispatch interval,
process. The transition to 5-minute settlement          energy prices start very high - close to the market
for energy will change this skill but that does not     cap in the first dispatch interval - good for spot
happen until October. Irrespective, aspects of market   energy revenue - but so do FCAS prices – bad
volatility that drive the 5/30 challenge still make     for generator costs. Both markets then diverge
it worth examining for bidding post October.            significantly over the following five dispatch
                                                        intervals to arrive at the final settlement prices.

                                                                                       Figure 3: Screenshots of
                                                                                       Ez2View (Global Roam)
                                                                                       showing volatility in QLD
                                                                                       dispatch prices and
                                                                                       corresponding trading
                                                                                       prices for Energy, Raise
                                                                                       60 second and Raise 6
                                                                                       second markets for trading
                                                                                       intervals 16:30 and 17:00
                                                                                       on the 10th of April.
BIDDING: PART THREE 11

Knowledgeable and experienced traders look               In our experience, good ABS will assist your trading
for and understand the underlying market                 team and will handle most situations that occur in
dynamics that shape these types of situations            the NEM most of the time. It does not replace
and how best to respond. This might mean not             the legal or commercial requirement to have an
rebidding at the first price signal and avoiding         experienced human operator to communicate
action that might itself change market prices            with AEMO or to intervene when it fails.
or cause large on/off swings in plant output.
In summary, good owners understand in detail             5. REBID REASONS
how they earn revenue and incur costs not just in        As rebidding is likely to remain a focus of
their commercial contracts but also in their NEM         the AER we finally want to emphasise the
operations. They then put arrangements in place          importance of good rebidding practices. The
to take greater control of these NEM revenues            NER has strict rules that must be followed
and costs, in turn improving their profitability.        such as following a specific format, providing a
                                                         clear and valid rebid reason and keeping good
                                                         records of circumstances related to the rebid.
4. AUTO-BIDDING SOFTWARE
                                                         Whatever your reason for rebidding – plant
You can bid by updating AEMO’s EMMS portal,              outage, avoiding negative energy prices or
which should only be done by someone                     high FCAS costs, you need to understand and
who understands the NER requirements for                 follow the NER and the AEMO Guidelines.
bidding. However, there are also now several
options for so-called auto-bidding software
(ABS), where algorithms determine and submit
your bids without human intervention.
We do not compare ABS vendors here but highlight
two very important points. Firstly, not all algorithms
are created equal so it is essential to understand
what any software does and more crucially, does
not do. If you are contemplating deploying ABS,
be sure to ask lots of questions about what inputs
the software uses and how the algorithm treats the
ever-increasing variety of asset and market-driven
commercial scenarios you will need it to manage.
Secondly, remember that ABS only rebids for
commercial reasons. It provides no compliance
function and does nothing to monitor or correct
any deviations from any dispatch instruction.
12 OVERWATCH ENERGY: WHITEPAPER

BIDDING

                                            6. BIDDING AND THE FUTURE
                                            Hopefully this paper has given you some flavour
Don’t Mislead the Market                    of how bidding is important for compliant
                                            and profitable operations.  The challenge is
In 2015 the requirement to make offers
                                            not in how to type some text in the AEMO
“in good faith” was updated to include
                                            portal but rather to understand the rules and
the prohibition against making false or     the commercial drivers behind that text.
misleading offers, as well as introducing
the requirement that changes to offers      Bidding is likely to remain important for years
be made as soon as practicable after        to come. In our last paper in this series we
                                            will delve more into this future – covering not
changes in material circumstances.
                                            just 5 minute settlement but other changes
                                            on the horizon that a successful power
                                            station owner will need to understand.
BIDDING: PART THREE 13

GET IN TOUCH

Jonathon Dyson                                      James Tetlow
Jonathon.Dyson@OverwatchEnergy.com.au               James.Tetlow@OverwatchEnergy.com.au
+61 438 411 295                                     +61 429 972 077
Level 14
88 Phillip Street
Sydney NSW 2000
www.overwatchenergy.com.au

ACKNOWLEDGEMENTS
This White Paper has been written by Jonathon
Emerick and the team at Overwatch Energy
who spend a lot of their time bidding for their
clients. Thank you also to Global Roam, providers
of ez2view, for reproduction of their images.
81300/0721

For further information call 1300 636 669 or visit overwatchenergy.com.au
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