NGET would like to reopen the discussion around CP191 which details amendments to Rule 2.3.5, 2.3.8 and 2.3.10 to allow the use of distributed connected generation output data to calculate de-rating factors relevant to Technology Class Weighted Average Availability (TCWAA), rather than incorrectlyusing the closest transmission generation technology.
Using transmission level data for distribution level generation is not appropriate. The current rules force a de-rating factor on distribution generation that is not based on their operation but on the operation of another group of generators. The aim of the rule change proposed is to use appropriate data, where possible, to improve the accuracy of de-rating factors. We would welcome further consideration with Ofgem and BEIS’ independent PTE to ensure the correct de-rating factors are used in Capacity Marketmodelling and auctions.