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Twenty-four hours advanced planning horizon

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Good intentions…

…apparently motivated creators of Law of Ukraine "On the market of electric energy" (ukr. Закон України "Про ринок електричної енергії" від 13.04.2017, № 2019 - VIII)  with regard to fining of electric power producers on "green" tariff for 24-hours generation imbalances into the grid in relation to (attention!) prognosis (!), accepted and concerted (!) with the "assured customer" from a producer. Responsibility for forecast precision is attached to... a producer (!). And it is done, on a larger scale… (quote) With the aim to limit the influence of electric energy producers’ support on "green" tariff on electric energy prices – according to Chapter XVII ( - 19/page7).

That’s quite an honest statement. The essence of innovations is that in two years the market of electric power starts working on "twenty-four hours advance" basis with fines either for prognoses non-presentation or for non-fulfillment of such provided prognoses. Fines will be imposed by “guaranteed buyer” (for which read: natural monopolist, at least at regional scale, because buyer is oblenergo), which, in addition to all other, has “… other rights…”.

The Law does not contain a word about mechanisms of data collection and analysis for short-term prognosis of generation according to electric power needs. There is not a word also about mandated informational database, algorithms, methodology and other grounds for prognostication on "twenty-four hours advance" basis, nothing about communication means and reliable dedicaded channels of such information transfers. What is more, in Ukraine there is no infrastructural base for such weather prognosis (which, actually, is the one and only basis for solar and wind power generation), responsibility of such third parties that provide data for these prognoses is not mentioned. There are no provisions about acceptable accuracy of such meteorological data for prognostication. There are no mentions about the structure of supervisory control, monitoring and short-term prognostication for making and consumption of electric power, there are no rules of priority on distribution of stakes among market participants, no regulations about levers of management for different types of generation traffic from different owners, as it organized, for example, in Germany (see pic. 1 in Economy of Energy Independence Good intentions to make "better" without corresponding prepared infrastructure conduct us on the former way of "resulted as usual".


Stick without any carrots

In addition, the Law enters, on larger account, only stick without any carrots. And this stick is placed into hands of "assured buyer", but the buyer is not liable for guaranted terms of assured delivery of "green" electricity into grid. Practical example: an accident within grid section where the a "green" energy producer is connected, is removed by organization, that does not have any liability for "assured" acquisition of this "green" energy. This is another legal entity, as a rule, local  Power Distribution Zone (ukr. - район електричних мереж, РЕМ, rus. - район электрических сетей, РЭС), which has a contract with oblenergo on electrical network maintenance. During accident removal process this section of network, naturally, becomes disconnected, and the "green" solar station also becomes disconnected completely, despite of the all beforementioned "prognoses". How many days will such "force-majeure" last and whether there such disconnection will be considered as an "act of God", and who determines this circumstance – these are matters nobody can define: neither producer of "green" electricity nor "assured" buyer, nor maintenance service provider company (the latter, as famous Gaidai’s character would say, commonly doesn’t give a hoot about someone’s losses).  

And this situation of someone’s irresponsibility with other’s fining happens pretty often. A week-long outage of a local solar station because of, for example, wire breakage in a local network after high wind or from a thunderstorm is quite real and frequent situation of practical generation on small solar stations (SSSs).

Thus Law enters fines for actual hourly deviation from concerted prognosis charts on hours advance basis. Hourly deviation! (see p. 5, article 71 of the Law, - 19/paran1472#n1472). And obligates a producer "…to carry financial liability for imbalances of electric power"… towards a customer.  The Law suggests other participants of electro-generation market to set 10 % from "their monthly amount of electric power allotment during corresponding period of  prior year" as the base for minimum allotment of electric power (see Fines are envisaged for "green energy" producers, if there are any deviation from ratified prognosis, 10 % fine for solar power stations (20% for wind power stations). For large producers with 5%+ share in general energetic balance of the country, accordingly, possible deviation will be 5%  (solar power stations) and 10 %  (wind power stations). The Law claims (see p. 11, chapter on transitional provisions - 19/page7), that:

«Compensation share… (from) "green" tariff producers to guaranred buyer for the costs of imbalance settlement is calculated as:

  • to 31 December, 2020 - 0 percents;
  • from 1 January, 2021 - 10 percents;
  • from 1 January, 2022 - 20 percents;
  • from 1 January, 2023 - 30 percents;
  • from 1 January, 2024 - 40 percents;
  • from 1 January, 2025 - 50 percents;
  • from 1 January, 2026 - 60 percents;
  • from 1 January, 2027 - 70 percents;
  • from 1 January, 2028 - 80 percents;
  • from 1 January, 2029 - 90 percents;
  • from 1 January, 2030 - 100 percents»


But while, according to data of State energy efficiency agency (ukr. - Держенергоефективність) for the first half-year of 2017, already 1635 private houses in Ukraine are equipped by solar panels and it is almost 4 times more than 2016 installations amount. How all this fining will affect on motivation of small producers of electricity (home stations with installed power no more than 30 kW) to join more actively into the process of "public" production of ecologically clean energy on "green" tariff? There is no chance to say that. How this matter will complicate lives, what additional costs it will charge and what problems will it create even to professional producers of "green" electric power? That quite obvious. How "…limitation of influence of support for producers of electric energy on "green" tariff…" corresponds with "Power strategy of Ukraine to 2035: Safety, energy efficiency, competitiveness" (issued by ukrainian Government in spring of this year), that prescribes to increase shares of renewable energy in energy balance of the country to 25% till 2035 -  the answer is also too clear. A stick only never promotes any realized motivation without carrots.

Quite massive report named "Adapting Market Design to High Shares of Variable Renewable Energy" on the problems of forecasting and about other factors, impedimental to wide coexistence of RES and traditional generation in grids of different level, was published in June 2017 by International Renewable Energy Agency (IRENA), it is publicly available to download here (click to open pdf-file):



"Where is this street, where is this house"?

In Law of Ukraine "On the market of electric energy" there is such an enigmatic phrase, that, they say, anything, that is not clearly stated here, regarding prognostication of solar electro-generation and fined imposing order, is regulated, let’s say, "according to market rules". There is no sighs, how is that "market" defined, and who is in charge there, and who actually formalizes these "market rules".

It is necessary to acknowledge that in Ukraine now there is NOT any system of instant automatic monitoring of local meteorological data in online mode, suitable for hour-based and daily prognostication of PV-generation. 

According to data from IEA report within "PV - power Systems Program", use of mesoscale meteorological models "probably does not improve quality of prognostication". Post-processing of data (mainly spatial averaging and error correction) can relatively decrease invalidity of local estimation on 15- 25%, but however for short- and medium-term prognostication it still will be no less than 25-30%.

In Ukraine there is no system of automated processing and distribution of data among concerned parties (neither on generation prospects of market participants nor about weather conditions). There is also nothing about acknowledged and non-conflicting rules of concordance for generation amounts. There is no clear forecasting mechanism of energy consumption in local networks on the same hour-scope base. There is not even reliable statistics on RES in Ukraine. There is no solid infrastructure of stations for surface cloudiness monitoring, unified into coordinated informational network.

There is no permanent simultaneous satellite watching system to track motion and thickness of clouds above all territory of Ukraine. There is no publicly accessible National database for short-term prognostication of weather and local solar luminosity. There are no certificated software data complexes. The Law doesn’t give any clues about financial sources for creation and development of mandated systems of prognostication and accounting of VRE. There is no long-term experience of research and optimization for such systems. And all these "no" are quite possible to continue and to expand.

But fines are already here, stipulated in the Law. It discourages, for sure. Will "harshness of laws" be compensated again by their non-fulfillment, or fines will be simply appointed to every producer of solar electricity by monopolistic "Guaranteed Buyer"?

Construction of industrial solar power plants
Equipment for solar power plants
Investments in renewable energy

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