Offshore Transmission: Industry Briefing - Ofgem · Offshore Transmission: Industry Briefing...

Offshore

Transmission:

Industry Briefing

7 October 2011 Offshore Transmission Workshop

23 January 2013

Purpose

www.ofgem.gov.uk

Open discussion of ongoing policy development

Chatham House rules (non attributable)

focus is on good ideas, not company positions

nothing said today is binding

Consultation and decision papers set out our positions - we look

forward to formal responses

Context

www.ofgem.gov.uk

Offshore Platform

Offshore Transmission Owner (OFTO)Onshore TO Generator

Connection to onshore network

132 kV Cable33 kV Inter Array Cables

Onshore Substation

PAC/NAO

reports NSCOGI/

Renewable

trading

EMR &

CfDs Brown &

Laidlaw

reports

Project

bond /

guarantees Financial

markets PF2 &

review

of RPI

Update on tender rounds 1 and 2

www.ofgem.gov.uk

Round Project Status

1

Barrow (90MW) Closed (September 11)

Robin Rigg (East & West) (180MW) Closed (March 11)

Gunfleet Sands (I &II) (173MW) Closed (July 11)

Sheringham Shoal (315MW) PB appointed

Ormonde (150MW) Closed (July 12)

Greater Gabbard (504MW) PB appointed

Thanet (300MW) PB appointed

Walney I (184MW) Closed (October 11)

Walney II (184MW) Closed (September 12)

2a

Lincs (270MW) PB appointed

London Array (630MW) PB appointed

Gwynt-y-Mor (576MW) ITT underway

2b West of Duddon Sands PQ underway

Tender round ‘3’ and beyond

www.ofgem.gov.uk

Policy development via consultation during 2012

Legal framework developed

Expect next tenders to be Generator build, starting from mid

2013

In discussions on OFTO build – more welcome

Looking ahead to coordination and hybrid projects

First half of 2013 is drawing together lessons & setting out

refreshed approach

Regulating transmission Aims

Development of economic and efficient network

Value for money for present and future consumers

outputs, innovation and incentives

Components of infrastructure applied to electricity transmission:

Design System design

Asset design

Build Procure Need for

Project manage Scope for competition? coordination

Finance Debt and equity

Operate Availability

System operation

Overview of current licence policy consultation

www.ofgem.gov.uk

Published end Nov 2012, closes 22 Feb 2013

Focused on following elements of Generator build licence (intention to

focus on OFTO build licence later in 2013):

Policy area Proposal

Revenue framework Keep 20 yr revenue term (but will review for

integrated networks)

Refinancing 2 possible options:

i) no gain share mechanism (status quo);

i) gain share mechanism

Indexation of revenue to RPI 3 possible options:

i) 100% indexation (status quo);

ii) Biddable indexation;

iii) Fixed proportion indexed

Overview of current licence policy consultation

www.ofgem.gov.uk

Policy area Proposal

Availability incentive Preferred option of capacity weighting

mechanism

Detail of mechanism tbc over coming months

(to be covered in today’s final workshop)

Incremental capacity

incentive

Intention to remove current minor

remuneration term.

Intention to retain current 20% remunerated

capex term, but keep under review

Transmission losses View that losses mainly influenced by

transmission asset design rather than

operation

Agenda

www.ofgem.gov.uk

10.35 – 12:15: Coordination policy (Jon Parker)

Workshop 1: User Commitment Changes

Workshop 2: Gateway Process for anticipatory

investment

12.15 – 13.00: Lunch

13.00 – 14.30: Cost Assessment workshop session (Roger Morgan)

14.30 – 15.15: Energy Bill implementation: generator

commissioning clause (DECC – Duncan Stone;

Ofgem – Alison Russell)

15:15 – 15.30: Coffee break

15.30 – 16.30: Optional: Availability incentive workshop session

(Hannah Evans)

10

Offshore Transmission

Coordination Project

Jon Parker

Senior Manager, Offshore Coordination Policy

Offshore Transmission Coordination

Jon Parker

www.ofgem.gov.uk

Joint Coordination Project during 2011/12 to assess the potential costs, risks

and benefits that may arise from the development of a coordinated offshore

and onshore electricity transmission network

This found that increased coordination could be beneficial, particularly for

larger and more distant from shore projects

The project also considered potential barriers that could hinder efficient

coordination opportunities being taken forward under the current regulatory

regime

As a result, Ofgem published a consultation in March 2012 setting out

possible changes to the offshore regime to better support efficient network

coordination

In July 2012 Ofgem published an open letter providing an update on our

thinking and seeking further industry views

Context

www.ofgem.gov.uk

„It is vital that offshore networks are considered in conjunction with onshore

networks in order to achieve a coordinated national transmission system that

efficiently integrates all generation sources, both onshore and offshore.‟

‘Each zone has to be considered on its merits and timing of decision points‟

„The issue of anticipatory capital investment needs to be addressed... A

robust and consistent process is required to evaluate the options for

anticipatory investment at each decision point.‟

„The potential savings from integrated development [£0.5-3.5bn] are most

significant under the most ambitious generation developmental scenarios, with

the corollary that anticipatory investment and stranding risk is also greatest in

absolute terms‟

Potential benefits and risks of coordination

Potential benefits and risks of coordination

www.ofgem.gov.uk

Potential barriers identified

• NETSO‟s role in connection offer process

• Enhancements to ODIS Designing an

efficient network

• Clarity on framework for coordinated investments within the OFTO regime – main focus of our consultations

Anticipatory investment

• TNUoS methodology needs to reflect coordinated offshore networks

• Changes made to user commitment through CMP192

Charging and user

commitment

• Clarity on regulatory treatment for generation and transmission that sit across different regimes

Regulatory interfaces

• Devolved matter

• DECC and CLG considering guidance on associated development in E&W

Consenting

• Industry-led groups discussing standardisation Technology

www.ofgem.gov.uk

GFAI

Category 1: Generator-Focused Anticipatory

Investment (GFAI)

Investment led by a developer which would enable the

later connection of specific future offshore generation, e.g.

through oversizing.

Category 2: Developer-led Wider Network Benefit

Investment (Developer-led WNBI)

Investment led by developers providing wider network

benefit, e.g. reinforcement of the wider network (onshore

or offshore) through, for example, boundary transfers via

offshore links.

Category 3: Non developer-led WNBI

Investment in wider network benefit assets not related to a

specific connection offer or where the developer(s) do not

have the appetite to develop the project.

Framework for coordinated investment -

proposed investment categories

www.ofgem.gov.uk

Our December 2012 consultation put forward:

Potential changes needed to the user commitment framework to

appropriately share costs and benefits of Generator Focussed

Anticipatory Investment (GFAI) whilst adequately protecting consumers

An Ofgem gateway process at pre-construction and construction stages

for assets requiring Wider Network Benefit Investment (WNBI), linked to

our current cost assessment process

Allow a potential route to fund TOs for carrying out pre-construction works

through RIIO

These proposals are intended enable greater coordination where economic

and efficient, working with current industry and Ofgem processes where

practical

Current consultation

www.ofgem.gov.uk

Investment routes walk-through

Generator-build OFTO-build Generator-build OFTO-build

Ofgem

tenderOfgem tender

Ofgem

tender

Construction

Works

Construction

Works

Construction

Works

Construction

Works

Construction

Works

Construction

Works

Ofgem

tenderOfgem tender Ofgem tender

Cost recovery

for pre-

construction

and

construction

works,

Constructed

and

commissioned

assets enter

operational use

Constructed

and

commissioned

assets enter

operational

use

Constructed and

commissioned

assets enter

operational use

Constructed

and

commissioned

assets enter

operational use

Constructed and

commissioned

assets enter

operational use

Constructed

and

commissioned

assets enter

operational

use

Key Developer NETSO Onshore TO

OFTO Ofgem Proposed new

process

*presented from the lead developer's perspective, that is, the developer

undertaking the GFAI on behalf of a later generator**Potential process, subject to further development

Ofgem tender

Construction Works

Constructed and

commissioned assets

enter operational use

Generator-build OFTO-build OFTO-build (lead option)

Ofgem gateway 1

Ofgem gateway 2 Ofgem gateway 2

Preliminary works Preliminary works Preliminary worksPreliminary works

with cost recovery

Straightforward radial

connections for a single

phase windfarm

Connections with GFAI*Connections with

developer-led WNBI

Non developer-led

WNBI**

Connection Application Connection Application Connection Application

Connection Offer Connection Offer Connection Offer

Ofgem gateway 1

Background system planning plus optioneering for connection

leads toidentification of GFAI for

second generator


leads toidentification of WNBI and

development of high-level needs case

Background system planning plus optioneering

leads toidentification of

WNBI and

development of high-level needs case


Connection Agreement

Transfer of

preliminary

works assets,

including WNBI

elements

Transfer of preliminary

works assets

Transfer of

preliminary

works assets,

including GFAI

elements

Transfer of assets

Transfer of assets,

including WNBI

elements

Transfer of assets,

including GFAI elements

Connection Agreement Connection Agreement

User commitment for onshore works for developer's needs

User commitment for onshore works for developer's needs

User commitment

for offshore works for

developer's

needs

User

commitment

for offshore

works for

developer's

needs

User

commitment

for offshore

works for

developer's

needs

User

commitment for GFAI for later generation

project applies post transfer

User commitmentfor onshore works for

developer'sneeds

User commitment

for GFAI secured from

later generator

www.ofgem.gov.uk

Workshop 1: potential changes to user commitment to support coordination

Overview of why user commitment changes may be needed [10 mins]

Break out group discussions of key questions [25 mins]

Feedback [15 mins]

Workshop 2: gateway approach

Overview of potential gateway approach [5 mins]

Break out group discussion of key questions [25 mins]

Feedback [15 mins]

Factsheets on your tables provide an overview and useful diagrams/tables for reference

Workshop structure

18



Jon Parker


Potential changes to user commitment

to support offshore coordination

What issues need to be addressed?

www.ofgem.gov.uk

Stranding risk

• Clear and appropriate allocation

• Protection of consumers

Cost recovery

• Greater certainty for developers undertaking coordinated investments

Options considered and impacts addressed

www.ofgem.gov.uk

Developer

(builder)

Later Generator Consumer

User commitment

type

arrangements

Greater certainty

on cost recovery,

subject to cost

assessment

Provides user

commitment for

assets built for its

benefit

Protected as

onshore

Up front cost

benefit

assessment

Greater certainty

on cost recovery,

subject to cost

assessment

Does not allocate

stranding risk to

party best placed

to manage it

Minimal protection

provided to

consumers

Additional cost

assessment

criteria in the

tender exercise

No improvement

to certainty of cost

recovery as reliant

on later generator

Does not allocate

stranding risk to

party best placed

to manage it

Protected as

assets only

transferred if later

generator meets

criteria

Current offshore user commitment liabilities

Wider liability

(zonal charge)

Attributable

liability: onshore

TO works *

Attributable

liability:

Offshore

transmission

assets

OFTO build

Generator build

* In the event that the offshore transmission assets connect directly into an onshore substation, and

no work is required by the onshore TO, there would no attributable liability under generator build.

GSP

Nearest existing MITS node

Generator build

OWF

1

OWF

2

Current user commitment arrangements under

Generator build

www.ofgem.gov.uk

No gap - developer bears construction cost for its first and

later project(s)

Potential gap – OFTO pays developer for

transmission assets, does developer then

provide user commitment for its later

project(s)?

Gap - lead developer bears constructions

costs for other party‟s later project(s), other

party does not provide user commitment

Potential gap – OFTO pays developer for

transmission assets, does second generator

then provide user commitment for its later

project(s)?

Single party

Multiple parties

Pre-transfer to OFTO

Post-transfer to OFTO

Round Table discussion and feedback

www.ofgem.gov.uk

Question 1:

Do you agree that user commitment arrangements offer the best way to provide

greater certainty to developers on cost recovery for GFAI assets while protecting

consumers?

Question 2:

Have we identified the right gaps in current user commitment arrangements and are

there any barriers to addressing these?

24



Jon Parker


Proposal to support developer-led wider network benefit investment: Ofgem

gateway assessments

www.ofgem.gov.uk

Proposed approach

Key barrier: lack of clarity on how developer-led WNBI will be treated during a

tender exercise

We are currently consulting on:

Introducing two voluntary Ofgem assessment gateways as part of a tender

exercise to give developers early clarity on our approach to cost assessment

At gateways Ofgem would review rationale for including the WNBI in a

developer‟s design solution at both preliminary works and construction stage

We are also seeking views on the potential to support some types on low cost

WNBI outside gateway assessment, through setting a de minimis threshold. This

is subject to further work but we welcome early stakeholder input.

www.ofgem.gov.uk

Proposed approach

Consultation sets out proposals for:

• A role for the NETSO and TO‟s in supporting the needs case for WNBI at the

gateway assessments and in monitoring changes in the needs case

• Assessment criteria including: economic needs case; timing, scope and

technical readiness; proposal for ETSO-developer engagement; developer‟s

commitment to triggering a tender exercise

• Timing of gateways will be flexible and triggered by developers when they

have sufficient information to enable us to conduct an informed assessment

www.ofgem.gov.uk

Round table discussion and feedback

Question 1:

What needs to be addressed for gateways to work effectively?

Question 2: What are your views on how a de minimis threshold should work, while ensuring consumers are not exposed to significant stranding risk?

28

www.ofgem.gov.uk

Consultation closes on 1st March – encourage formal responses

Intend to publish final proposals in key areas this spring, with further policy

development and implementation actions expected over the coming year

We are keen to continue engaging closely with industry on potential changes

needed to the industry frameworks to ensure these happen as quickly as

possible, including on integrated TNuOS charging and user commitment

Next steps

29



Jon Parker

Senior Manager, Offshore Coordination Policy Cost Assessments

Roger Morgan

Agenda

Xx

www.ofgem.gov.uk

Summary of progress to date

Cost assessment guidance document

Developments to the cost assessment process breakout sessions on the

following:

Process improvements

Assessing transmission asset design

Use of benchmarking

We will conclude today‟s session with feedback from each breakout group

Progress to date

Completed cost assessments: Barrow, Robin Rigg, Gunfleet Sands, Walney I &

II and Ormonde

We are progressing final cost assessments: Sheringham Shoal, London Array,

Greater Gabbard, Lincs and Thanet

Key themes/issues:

cable installation cost overruns

IDC adjustments (duration/imposition of caps)

cost allocations between generation & transmission assets

developers require clarity and guidance on process

Ofgem’s cost assessment guidance

This document covers the following:

Guidance on our cost assessment process that will apply to all cost

assessments

The range and types of issues that are considered in cost assessments

How we determine whether costs and economic and efficient

We intend to keep this guidance under review and will update this

periodically

Cost assessment process development

Key Issues:

emerging technologies

pressure to drive down costs per MWh

flexibility in our approach e.g. early engagement and certainty over

treatment of costs

to respond to these challenges and policy developments elsewhere

will require further thinking of how we conduct cost assessments

Today‟s workgroups will discuss:

Group 1: Process improvements

Group 2: Assessing transmission asset design

Group 3: Benchmarking

Breakout groups

30 minute task:

Each group to discuss questions and discussion points that have

been prepared

Record findings on flipcharts provided

Pick a spokesperson to present findings

Each group in turn to explain findings to the wider group

Ofgem will summarise and set out proposed next steps

35



Jon Parker


Energy Bill implementation:

The Generator Commissioning clause

Alison Russell & Duncan Stone

Agenda

1. Overview of generator commissioning clause – DECC

• Background

• Purpose

• Scope

• Duration of exception

• Means of implementation

2. Implementation of generator commissioning clause – Ofgem

• Modification of Codes & Agreements

• Completion Notice

• Expected Code and Licence Changes

3. Questions

Background

OFTO-builders will have a transmission licence in advance of commissioning

However, generator-builders will have a generation licence, so cannot also

obtain a transmission licence

The completion notice concept, utilised in the clause, is already part of the

legislative framework

Purpose

The clause amends section 4 of the Electricity Act 1989 to create an

exception in certain circumstances to the prohibition of participating in the

transmission of electricity without a transmission licence

The exception will:

provide generator-builders with confidence that they can commission

transmission assets lawfully

ensure that renewable electricity can continue to flow

facilitate the timely transfer of transmission assets to OFTOs

enable the full commencement of the offshore transmission regime

Scope

The exception can apply in relation to generator-build projects that are

qualified into a tender exercise but are not yet transferred to an OFTO

A transmission system is considered generator-built if it is or has been

constructed or installed by one, or a combination of, the following:

The current developer in relation to the tender exercise and who is

operator of the generating station

An associated body corporate of the current developer

A previous developer

An associated body corporate of the previous developer

A sub-contractor of the above

The exception could apply to projects that are „in flight‟ at entry into force,

and their 18 months would start to run on receipt of a completion notice.

Duration of Exception

This is described as the “commissioning period” and comprises:

The period before a completion notice is issued in respect of a

transmission system; and

18 months starting on the day the completion notice is issued

One completion notice will be issued in relation to each qualifying project‟s

transmission system, so if the qualifying project is staged the notice will not

be issued until it is possible to make all stages available for transmission

The draft clause consulted on last summer allowed 12 months for transfer

post-completion notice, but this was amended as a result of feedback

However the 18 months can be reduced to 12 between 2–5 years after entry

into force, though would only apply to projects yet to be qualified

Means of implementation

The clause will come into force 2 months after Royal Assent. We currently

anticipate Royal Assent by the end of 2013.

For the clause to be effective, it is likely that there will need to be changes to

licences, codes and/or agreements

These documents will need to be reviewed holistically and, if necessary,

changed speedily, which does not lend itself to standard industry processes

The SoS power to make such changes expires on 17 April 2013

Rather than extend those powers, Government recognises Ofgem‟s

expertise in this area and decided to grant it a specific, targeted power to

amend relevant codes and agreements following consultation.

Agenda

1. Overview of generator commissioning clause – DECC Background

Purpose

Scope

Duration of exception


2. Implementation of generator commissioning clause – Ofgem Modification of Codes & Agreements

Completion Notice

Expected Code and Licence Changes

3. Questions

Modification of Codes or Agreements

• The clause includes powers for the Authority to modify codes (or the

agreements which give effect to them) where the modifications are

necessary or desirable to implement this clause

• The powers last for 7 years

• The Authority must consult, which can be done prior to the passing of the

Energy Act 2013, and provide reasons after making such modifications

• Licence modifications must be made using existing processes

Indicative timelines – subject to Parliament

Bill passes through both Houses and amendment stage during 2013

Royal Assent - anticipated

end 2013

Code changes identified Informal

consultation Formal

consultation

Codes modified

post assent

Licence changes identified Informal consultation Statutory

consultation Licence Direction

Aligned to codes

Stakeholder engagement during identification and consultation processes

Completion notice

• Concept already exists in the Transmission Licence

• A completion notice (CN) is given to the Authority by the co-ordination licence

holder (NETSO) and sets out that it would be possible to transmit electricity

by making the system available

• Further work is needed on exact timing of CN issuance, but:

• Our initial view is on completion of Stage 2 acceptance (or equivalent)

for the last stage of the qualifying project

• The arrangements will need to ensure commissioning is equivalent to

the TO standards as the assets become (OF)TO assets.

• These standards are currently set out in the STC or NGET internal

documentation

Expected Code & Licence changes - 1

Currently, formal transmission commissioning obligations and processes sit

within STC/STCPs or NGET internal documents

Only SO/TOs are signatories to STC, generators are not party to or

bound by it

Generator commissioning is carried out under auspices of the relevant

commissioning panel

As assets ultimately become transmission assets, the commissioning

requirements for generator developers must meet the same standards as

those imposed on TOs

NGET & Ofgem are working through the possible impacts of the

commissioning requirements on industry codes


Detailed evaluation ongoing and will be consulted upon, however, some

changes have initially been identified

Commissioning process equivalents to STCPs will need to be applied to

developers – current thinking is that this might best sit under the Grid

Code and relevant associated documents

Some changes may be needed to other industry codes and documents,

not yet defined, and changes would be minimised where possible

Codes which are not expected to need changes:

STC – but it may provide source material

Distribution codes

Minor changes may be required to the NGET Transmission Licence and

possibly Generation Licence conditions, but this is still under evaluation


Change process:

We expect to consult and engage with stakeholders on changes

We welcome input to identify changes and issues, formally and

informally

We would like to understand stakeholder preference for engagement: for

example

Seminar(s) plus informal/formal written consultations; or

A stakeholder (non-decision making) group which meets at regular

intervals – perhaps bi-monthly plus formal consultation

If a stakeholder group type approach - to make it practical, a

smaller group of representatives would be helpful

Representatives‟ commitment would be essential in surfacing

issues and debating potential solutions

Agenda

1. Overview of generator commissioning clause – DECC

Background

Purpose

Scope

Duration of exception


2. Implementation of generator commissioning clause – Ofgem

Modification of Codes & Agreements

Completion Notice

Expected Code and Licence Changes

3. Questions

For discussion during questions:

1. Is Stage 2 Acceptance (or equivalent) the best trigger for the issue of the

Completion Notice?

2. Transmission commissioning arrangements are set out in the STCPs –

equivalent arrangements could be applied to generators via the Grid Code,

does that cause any concern – if so, what?

3. If not via the Grid Code/essential licence changes, what would be the best

way to formalise these arrangements

4. Is there a preferred way to engage with industry stakeholders on this work?

a. Informal and formal consultation ?

b. Formal consultation plus working group (non decision making)?

Illustration of a phased project

Phase 2

Onshore

Substation 1

Onshore

Substation 2

Wider electricity

transmission

system

Offshore

Substation

Platform 1

Offshore

Substation

Platform 2

= Stage 1

= Stage 2

= Stage 3

Key:

Notes:

1) Three distinct stages of the

transmission asset build out.

2) Build out of stages occurs

consecutively with stages

electrically linked.

3) Stages 1 & 2 provide capacity to

carry export power.

4) Stage 3 adds additional security to

transmission system.

Phase 1

Onshore

Substation 3

Offshore

Substation

Platform 3

Phase 1 Phase 2

= Single stage

52



Jon Parker


Availability Incentive

Hannah Evans

Context

www.ofgem.gov.uk

Reviewing incentive mechanism to ensure it is fit for purpose for future projects

Building on:

May 12 consultation

Stakeholder feedback

Further internal analysis

Propose to adopt capacity weighting mechanism

Incentivises behaviour that maximises export, while retaining a simple

mechanism providing an appropriate risk profile for OFTOs.

Retain the 10% and 50% revenue caps

Not retrospective

Overview of capacity weighting proposal

www.ofgem.gov.uk

0% 20% 40% 60% 80% 100%

Pen

alt

y

Capacity of outage

axb

a = intercept point where a = 1 is the status quo. We expect a ≥

1

b = steepness of curve where b=1 is a straight line, and as b

increases so does the steepness. We expect

b ≥ 1

x = capacity of outage where 100% means that the transmission

system is completely unavailable, and for

example 25% means that only one of four

circuits is unavailable.

Note that we propose that for now, the same weighting level will apply to all OFTO

configurations, so that there would not be a bespoke weighting for each OFTO.

Capacity weighting proposal - Example

www.ofgem.gov.uk

0% 20% 40% 60% 80% 100%

Pen

alt

y

Capacity of outage

axb

5

20

25

Outages and Penalties

For outages of 1 hour:

100% outage (4 cables) = 25 penalty points

50% outage (2 cables) = 5 penalty points

25% outage (1 cable) = 1 penalty point

Comparison

100% outage (4 cables) for 1 hour = 25

penalty points

Vs.

4x 25% outages (1 cable) for 1 hour each = 4

penalty points

Example: 4 parallel export cables of equal capacity.

Planned and unplanned outages differential

www.ofgem.gov.uk

Feedback and analysis suggests that there may be merit in differentiating

between planned and unplanned outages, where unplanned outages were

penalised more than planned outages.

We do not currently propose to introduce a differential in penalties between

planned and unplanned outages, but we would welcome feedback on whether

this could be of benefit in the future.

We are particularly keen to understand your views on whether a mechanism

such as this could and would have a positive impact on OFTO behaviour, and

also what impact it may have on the bids at tender stage.

Use of TEC as measurement of maximum availability

www.ofgem.gov.uk

As outlined in our November 12 consultation, TEC may not be an appropriate

measure of maximum availability in the future. This applies to the more

integrated networks in particular.

Although we do not currently propose to move away from using TEC, we would

welcome your views on what the key issues and benefits are for using TEC as

the measure for maximum availability.

This includes what additional considerations (if any) should be made to more

integrated networks.

We also welcome views and comments on what other measures could be used

instead of TEC in the future.

Future plan

www.ofgem.gov.uk

Consultation closes on 22nd February

Position statement due in Spring 2013

First draft of licence, including availability incentive algebra due later in 2013

Model to be published alongside the draft licence

Ongoing work on integrated networks considerations (including use of TEC)

Overview of key points for discussion

www.ofgem.gov.uk

What are your views on whether to introduce a penalty differential between

planned and unplanned outages?

What should the penalties be for differing capacity outages?

i.e. Do you have any views what are the optimum/possible values of the

intercept point (a) and the steepness of the curve (b)?

How might the availability incentive need to change (if at all) to take account of

integrated offshore networks?

Going forward, do you think that the use of TEC for maximum availability will

remain appropriate?

Increasing steepness (b)

Increasing intercept point (a)

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