EUAA Submission: Changes to Reserve Level Declaration Guidelines Draft Report

EUAA Submission: Changes to Reserve Level Declaration Guidelines Draft Report

Emily Wood | March 21, 2024

‘… AEMO are proposing to change both the model for calculation of the forecasting uncertainty measure (FUM) and add an additional time of day input variable.

The use of the FUM is a critical component in the declaration of a forecast lack of reserve in the short term projected assessment of system adequacy (ST PASA) and pre-dispatch PASA (PD PASA) timeframes.  The EUAA has long voiced our concern about the apparent conservatism imbedded in AEMO forecasting that leads to the seeming over utilization of market mechanisms such as LOR.  The lack of a transparent mechanism to review the forecasting against actual dispatch outcomes does not assist AEMO in defending its apparent conservatism.

The EUAA understands that AEMO conducted a “Review of the Reserve Level Declaration Guidelines” in August 2023, for which the current Draft Report is based.  However, we have been unable to find this “Review” on AEMO’s website, making it difficult to know whether the recommendations in the Draft Report are the full extent or whether further changes are needed to the Guidelines in addition to the changes in the FUM calculation.  The EUAA prefers transparent processes where these types of documents are readily available, particularly when they are quoted references in the subsequent reports, as the Review was in the Draft Report.

The EUAA supports the addition of a time-of-day input and highly recommend that in addition to time of day the calculation should also include for seasonal impacts.  This would require that Figure 1 of the Draft Report be replicated on a seasonal basis noting this will further improve the application of uncertainty regarding solar PV output.

The other critical area of the FUM value is the use of a 95% certainty factor….’

Please download attachment to read full submission.

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