Reason for Mod_33_11

1. Mod_33_11Temporary exclusion of Interconnector Error Unit Testing Charges from Settlement calculationsModifications Committee Meeting11 October 2011

2. Reason for Mod_33_11 • Mod_10_11: Interconnector Under Test was recommended for approval by the Modifications Committee on June 28th 2011 • RA Decision of 21st July directed modification to be implemented • Mod_10_11 cannot be incorporated into the CMS until after SEM R2.0.0 (July 2012) – earliest date it can be incorporated is October 2012 release • Therefore SEMO investigated implementing a temporary manual workaround to allow the application of Testing Tariffs during EWIC commissioning

3. Mod_10_11 • In assessing a potential manual workaround for Mod_10_11, it was found that as the Total Payments made to a Generator for a given Settlement Day d DAYPUud, (paragraph 6.122) feed into the Currency Cost smear (paragraph 6.136A). Therefore, a manual workaround including this smear would be extremely difficult to implement. • In addition, it was discovered that the vendor assessment of the Option 1 implementation of Mod_10_11 had not taken the feed through of DAYPUud to the Currency Cost calculation into account. • The original assessment was €59,200 + Testing. • The inclusion of the feed through to the Currency Cost smear increased the impact assessment to €76,960 + Testing.

4. Mod_33_11 – Manual Workaround for Mod_10_11 • In order to facilitate a temporary manual workaround of Mod_10_11, SEMO proposes to temporarily exclude the Testing Charges applied to EWIC from the Currency Cost smear (paragraph 6.136A) • The materiality of doing so was assessed based on the testing profile applied to Britned (EWIC testing profile is not yet available) • SEMO looked at the same period this year (June/July 2012), the Total Energy Payments for that period, the average weekly SMP, the total Currency Costs and the Energy Payments and impact of additional Currency Costs associated with Testing Charges if the EWIC was testing during that period. • SEMO estimated the weekly [(Energy Payment + Testing Charge)/ Total Energy Payments]* Total Currency Costs using the Britned profile and the Total Energy Payments from a similar period this year and compared them to the value with no Testing Charges included.

5. Weekly Currency Costs for Interconnector Error Unit Weekly Currency Costs week number

6. Overview of Total Weekly Currency Costs Weekly Currency Costs Week number

7. Mod_33_11 – paragraphs affected by DAYPUud • 6.122: Exclusion of IEU Testing Charges from DAYPud (Total Generator Payments) so that they are not fed through to the Currency Cost smear. • Payments for Generator Units on a Daily Basis • 6.122 The Total Payments (DAYPUud) made for Generator Unit u for Settlement Day d shall be calculated • as follows: • DAYPUud = ENPUud + CONPud+ UNIMPUud- TCHARGEUud • Where • 1. ENPUud is the Total Energy Payment made for Generator Unit u for Settlement Day d; • 2. CONPUud is the Constraint Payment made for Generator Unit u for Settlement Day d; • 3. UNIMPUud is the Total Uninstructed Imbalance Payment made for Generator Unit u for Settlement • Day d; • 4. TCHARGEUud is the Testing Charge for each Generator Unit u excluding Interconnector Error • Units for Settlement Day d.

8. Mod_33_11 – paragraphs affected by DAYPUud • 6.124 : Testing Charge is added back in to Invoice for Energy Payments: This requires a manual workaround – either as a line item on an invoice or as a separate FT item.

9. Mod_33_11 – paragraphs affected by DAYPUud • 6.141: Inclusion of IEU Testing Charge in the Balancing Cost. • No need to add clause to mod. Manual workaround will take care of this • 6.153 The Unsecured Bad Debt Energy Charge: This has not be included in the mod as it is deemed highly unlikely to occur. • 6.187 The Actual Generator Exposure : The impact of the Testing Charges on CRM has been deemed to be of low materiality and would not warrant a manual workaround and so has been excluded from the mod.