Ancillary Services in Electricity Markets€¦ · Frequency Control Ancillary Services A certain...

02-03-2016 Side 1

Department of Electrical Engineering, IIT Kanpur (INDIA)

Ancillary Services in Electricity

Markets

S.N. Singh, Professor

Department of Electrical Engineering

Indian Institute of Technology Kanpur

Email: [email protected]

02-03-2016 Side 2


Ancillary Services

• The literal meaning of the word ancillary is providing

support or help.

• Generally, the System Operator (SO) manages ancillary

services for ensuring security, reliability, stability and

quality of the power supply to the consumers.

• Ancillary services can be provided by generators, Load

Serving Entities (LSEs) and transmission operators.

• Ancillary services are classified, procured and

remunerated depending upon the operational practices of

the Electricity Supply Industry (ESI).

02-03-2016 Side 3


• NERC defines Ancillary Services as

“An Interconnected operation services necessary to effect transfer of electricity between purchasing and selling entities, and which a transmission provider must include in an open access transmission tariff.”

• Ancillary services consist of services required for

- Maintaining generation and load balance (frequency control)

- Maintaining Voltage and reactive power support

- Maintaining generation and transmission reserves

- Emergency preparedness (system restart & stability control)

Ancillary services cost may be about 10% of total generation and transmission cost. Most of it are required for power balancing/frequency regulation, loss make-up and voltage/reactive power support.

02-03-2016 Side 4


Classification of Ancillary Services

SRAS

Secondary FC

Primary FC

Tertiary FC

Ancillary Services

PFCAS

NCAS FCAS

VCAS

Primary VC

Secondary VC

Tertiary VC

Ref: Guide to ancillary services in the National Electricity Market, National Electricity Market Management Company.

02-03-2016 Side 5


Frequency Control Ancillary Services

A certain amount of active power, called frequency control reserve, is kept available to perform this task.

Three levels of control are generally used to achieve FCAS:

Primary frequency control (a response period of 5 to10s),

Secondary frequency control (10s to 15min ) and

Tertiary frequency control (10 to 30min).

Frequency control reserves required to perform above control tasks can be of

positive frequency control reserve and

negative frequency control reserve.

02-03-2016 Side 6


Network Control Ancillary Services

These are the services required to maintain the network parameters within permissible range.

VCAS are required for supporting the voltage to be maintained within the permissible limit. Three levels of control are generally used to achieve VCAS:

Primary voltage control,

Secondary voltage control and

Tertiary voltage control.

Power flow control AS (PFCAS) are needed for the purpose of improving Available Transfer Capability (ATC) and the performance of real time operation considering network constraints.

02-03-2016 Side 7


MVAr

Under excitation limit

Pg G

SgQg

Qg E

Qg

op

D

C

B A O

MW

Field current limit

Qgmin

Pgmax

F

Armature current limit

02-03-2016 Side 8


System Restart Ancillary Services

These are the services related to backup capacity of the system and the capacity that is required to return the system to a normal operation after a major blackout.

02-03-2016 Side 9


Technologies Used for Provision of AS

Ancillary Services Technologies Used

FCAS Governor, AGC, Rapid unit loading,

Rapid unit unloading, Demand side load

shedding

NCAS Generators, Capacitors, Inductors,

Synchronous condensers, FACTS

controllers

SRAS Generators

02-03-2016 Side 10


Procurement of Ancillary Services Compulsory Provision

• As part of connecting conditions, a fixed amount of ancillary services is provided.

• Consequences: (i) volume of service provided may exceed what is actually needed, (ii) potentially low cost providers are treated on the same basis as more expensive one.

Market Based Provision

• Bilateral contracts: (i) this form of procurement lacks transparency, (ii) this type of negotiation can be long-term, complex and costly, (iii) because of high transaction cost of contracts, price and volume often remain fixed for a long time.

• Both tendering process and creation of a spot market enhance transparency and foster competition.

02-03-2016 Side 11


Remuneration of Ancillary Services The remuneration for an ancillary service may combine

several components to reflect the various costs of

ancillary service provider such as

• Availability price

• Utilization price

• Fixed cost

• Variable cost

• Opportunity cost

02-03-2016 Side 12


Remuneration of Ancillary Services

Remuneration Methods

• Regulated price (set by regulator or SO and usually same for

all providers): it is justified when market power is issue but it

reflects imperfect cost as cost changes with time and condition.

• Pay as Bid price (the supplier receives the price of its

accepted offer): It is good when the quality of the ancillary

services offered is highly differentiated. However, it does not give

providers an incentive to bid their marginal cost, except when

market concentration is low.

• Common clearing price (all the successful providers are paid

the price of the most expensive accepted or the least expensive

rejected offer)

02-03-2016 Side 13


• While designing an ancillary services

market, a number of aspects have to be

considered,

• Time frame of the market,

• Type of the market (bilateral or competitive bid

based),

• Type of procurement (sequential or simultaneous),

• Settlement rules (price based or bid type, price based

on usage type, marginal price or pay as bid),

• Recovery (charging) scheme (uplift in energy charge,

use of system charge or other methods)

02-03-2016 Side 14


International Practices

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England & Wales Electricity Market

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• The restructuring process of the electric supply

industry (ESI) began in 1989 in order to reduce

the government intervention in the economy, and

total liberalization was reached in 1991.

• It was known as UK Pool. New Grid Company

(NGC) was responsible Market clearing, providing

the transmission system and ancillary services

02-03-2016 Side 17


Competing GeneratorsAncillary Services

Distributors

Power Exchange (PX) System Operator

(SO)

Transmission Facilities

ControlMonitor

DispatchBid

ForecastSell

NGC

02-03-2016 Side 18


New Electricity Trading Arrangement (NETA) in UK

• Before the March 2001, any generator

exporting more than 50 MW on to the system is

required to hold a generation licence and to

trade its output via an open commodity market,

the Electricity Pool.

• CfDs were essentially financial instruments, the

main purpose of which is to hedge risk

• After March 2001, New wholesale electricity

trading arrangements (NETA) was introduced .

02-03-2016 Side 19


• In the NETA design the old day- ahead pool based on a coordinated - spot market with a market- clearing price was replaced by a three- and- a half- hour ahead balancing system with a complex pricing scheme that features pay- as- bid mechanism with rules intended to penalise imbalances.

• The governance arrangements that supported NETA include the establishment of a Balancing and Settlement Code (BSC) Panel, to oversee the Code and to to provide or procure a range of operational and administrative services, both directly and through contracts with service providers.

02-03-2016 Side 20


The new arrangements include:

• Forward and futures markets

• a Balancing Mechanism in which the NGC, as system

operator, accepts offers of and bids for electricity

close to real time to enable it to balance the system;

• a Settlement Process for charging participants whose

contracted positions do not match their metered

volumes of electricity, for the settlement of accepted

Balancing Mechanism offers and bids and for clearing

costs of balancing the system.

• Ancillary service is managed by NGC and the cost

associated with the provision of AS are transferred

to the Consumers through transmission payment.

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Two major Ancillary Services

• Frequency Controlled o Primary frequency regulation

o Secondary frequency regulation

o Tertiary frequency regulation

• Voltage Control

• Replacement or supplementary reserve

02-03-2016 Side 22


Frequency Control

Required to keep the frequency between 49.5 and 50.5 Hz.

During contingency, frequency is allowed to drop under 49.5 Hz, but

for not more than 1 minute.

Primary frequency regulation is mandatory for all generators with

installed capacity of over 50MW.Generators are set for a droop of 3–5%.

Secondary frequency regulation is considered as a commercial service

and it is not considered as a mandatory provision.

Generators provide it using AGC.

The consumers pay through an increase in their electricity tariff

which includes capacity, operation and compensation.

02-03-2016 Side 23


•NGC responsible for managing ancillary services.

•The costs associated recovered from the consumers through uplift in

transmission payment mechanism.

Voltage Control:

Provision: all the generation units with a capacity over 30 MW.

Voltage must be kept within the range of Vnom+- 10% for 400, 275

and 132 kV networks and the power factor (PF) between 0.85

capacitive and 0.95 inductive.

The ratio of capacity price to operation price is approximately 1:2.

02-03-2016 Side 24


Technical aspects of ancillary services provision in England and Wales

Primary FCAS Secondary FCAS VCAS

Response time 10s 30s Instantaneous

Duration 20s 30min Not specified

Provider Generators and large

customers with load

shedding

Generators with

AGC and load

shedding

Generators with capacities over

30MW

Monitoring Continuous,

frequency must always be

between 49.5 Hz to 50.5 Hz

Daily monitoring Voltage range must be kept

between Vnom + 10% for 400,

275 and 132 kV transmission

system

Necessary

amount

Generation droop between

3% to 5% sensibility to

frequency changes smaller

than + 15 mHz

Annually

determined by

system operator

Based on historical levels,

assigned in MVAr for every

hour

Commitment Mandatory for generators

with capacities over 50 MW

Optional Mandatory to keep the power

factor between 0.85 (capacitive)

and 0.95 (inductive)

02-03-2016 Side 25



Main costs

identified

Insignificant and

difficult to

determine

Low costs, difficult

to determine

capacity and operation

Transaction

mechanism

Annual bilateral

contracts

Annual bilateral

contracts, and

competitive auctions

an auction and offer

mechanism operated on a

semester basis

Payment to

providers

For capacity,

usage (spot price)

and compensation

if applied

For capacity,

operation (spot

price) and

compensation

For capacity, usage

Customer’s

payments

Through an uplift

charge

Through an uplift

charge

Through an uplift charge

Price

discovery

US $3.9/MWh US $4.3/MWh Capacity between

$0/MWArh and 0.58/MVArh,

usage $1.31/MVArh

Economic aspects of ancillary services provision in England and Wales

02-03-2016 Side 26


California Deregulation Process

02-03-2016 Side 27


• On March 31, 1998 California became the first sate to offer all customers a choice of electric service providers. There are three significant characteristics in California Model.

- A Zonal approach is applied to simplify the transmission pricing scheme, including nodal and congestion charge assessing.

- Multiple separate energy forward markets, each with a supply and demand portfolio managed by a Scheduling coordinator (SC) or PX, have been introduced.

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28

Competing GeneratorsAncillary Services

Distributors

California PX

System Operators

(SO)

Transmission systems

Scheduling

Co-ordinators

(SC)

Brokers

ControlMonitor

DispatchBid

ForecastSell

California ISO

02-03-2016 Side 29


CALIFORNIA ASM

Four types:

1. regulation up,

2. regulation down,

3. spinning reserve

4. non-spinning reserve.

♦ Ancillary Services: RT and DA

♦ Co-optimized with energy in both RT and DA

♦ Spinning and non-spinning reserves with scarcity pricing

♦ Regulation

02-03-2016 Side 30


After the power market crisis of 2001, the Californian ISO (CAISO)

redesigned its electric energy market. It then introduced the concept of

available capacity (ACAP), whose objective is to allow the ISO to verify

in advance the availability of enough resources to satisfy the customer

load as well as reserves. In the new market structure, the energy market,

the ancillary service market and the congestion management market are

jointly optimized.

Voltage Control

The ISO procures reactive power support services on long-term

contracts from reliable must-run generating units. The actual short-term

requirement is determined on a day-ahead basis, after the real power

market is settled and the energy demand and schedules are known.

The generators are mandated to provide reactive power within the

power factor range of 0.90 lag to 0.95 lead.

02-03-2016 Side 31


Frequency Control

Primary frequency regulation and secondary frequency regulation

are not mandatory services.

There exists up and down service regulation.

The costs associated with this service correspond to capital,

operation, fuel, and reduced efficiency costs, etc.

For secondary frequency regulation, the service must be available

in 10 min and should be supported for at least 2 hours.

The system operator calculates the quantity required of the service

according to a criteria that takes care of demand and contingency.

The quantity required generally comes close to 3% of the

maximum demand of the system.

02-03-2016 Side 32


Primary FCAS Secondary FCAS VCAS Response

time Instantaneous 10min 1min

Duration Not limited 2h Without limit Provider Generators Generators Generation, transmission

and distribution companies

Monitoring Through Area Control Error (ACE)

In charge of system operator Transmission lines must operate according to the limits established by SO

Necessary amount

According to the system’s demand, between 5% and 12% demand, up and down

According to CAISO: more than 5% of hydraulic generation +7% of the other generation sources. Considering main contingencies

Determined by the SO according to voltage and reactive power levels

Commitment Optional Optional Mandatory to keep the pf between 0.9 capacitive and 0.95 inductive

Technical aspects of ancillary services provision in California

02-03-2016 Side 33



Main costs

identified

Capital, fuel,

equipment lifetime

reduction,

maintenance and use

Capacity,

operation and

opportunity costs

Capacity and operation

Transaction

mechanism

Competitive auctions Competitive

auctions

Annual bilateral contracts

Payment to

providers

For capacity, usage

(spot price)

Capacity payment

and operation

payment for real

time dispatch

According to capacity and

use, only if its provision is

out of the requested PF

Customer’s

payments

According to project

demand

According to

project demand

According to CAISO

project demand

Price discovery For capacity, up: US

$16/MW, and down:

US $20/MW

For capacity US

$2.3/MW

Not specified

Economic aspects of ancillary services provision in California

02-03-2016 Side 34


ASTRALIA ANCILARY SERVICE MARKET(AEMO)

02-03-2016 Side 35


In order to best meet these challenges a new organisational

structure was developed:

ExchangeOperations

Market Development

Metering

Settlements

Settlement Residue

Registration

Prudentials

Power Exchange

Bidding

PASA

Optimisation (SPD)

Communications

Real time monitoring

Market Administration

Systems

Market Systems

Board and Executive

Corporate Services

Business Systems

Management and Support Services

ParticipantsJurisdictions End Users

Stakeholders

Power System Operation

Power System Dispatch

Power System Planning

Ancillary Services

Reserve Trader

System Operations

Services

• AEMO operates 8 separate markets for the delivery of frequency

control ancillary services (FCAS)

• purchases network control ancillary services (NCAS) and

system restart ancillary services (SRAS) under agreements with

service providers

02-03-2016 Side 36


Australian Deregulation Process

• In Australia, the deregulation of the electrical system began in

1998. As part of this process, the National Electricity Market

(NEM) was created, in order to increase competition at every

stage of the electricity production and distribution.

• The National Electricity Market Management Company Limited

(NEMMCO) is the system operator and the ancillary services

market administrator .

• Initially, ancillary services were traded through long-term bilateral

contracts between NEMMCO and the services suppliers.

• Since 2001, frequency control ancillary services are traded in

competitive spot markets

• The payments are collected from customers only or from

customers and generators on a 50% to 50% shared basis

02-03-2016 Side 37

Department of Electrical Engineering, IIT Kanpur (INDIA) FCAS market • Through competitive bidding

• Payments include payments for availability and for the delivery of the

services

• normal operating band of frequency: 49.9 Hertz to 50.1 Hertz.

• Frequency control divided into two reasonably distinct subsets:

• Regulation:

• correction of the generation / demand balance in response to

minor deviations in load or generation.

• controlled centrally from one of AEMO’s two National Dispatch

and Security Centers.

• Provided through AGC action.

• Contingency:

• correction of the generation / demand balance following a major

contingent event such as the loss of a generating unit or a large

transmission element

• It’s a locally controlled action like, Generator Governor

Response, Load shedding, Rapid Generation.

02-03-2016 Side 38


• Dispatch- based on merit order of cost.(i.e., The highest cost offer

to be enabled will set the marginal price for the FCAS category.)

• During period of high demand:

co-optimization algorithm is followed

(as it may be necessary for Dispatch center

to move the energy target of a scheduled

generator or load in order to minimize

the total [(of energy plus FCAS] cost)

02-03-2016 Side 39


The FCAS offers and bids must comply with similar bidding rules

that apply to the energy market:

• Offers / Bids can consist of up to 10 bands with non-zero MW

availabilities;

• Band prices must be monotonically increasing;

• Band prices must be set by 12:30 on the day prior to the trading day

for which the offer/bid applies;

• Band availabilities, enablement limits and breakpoints can be rebid

under rules similar to those applying to the energy market.

• Ancillary service plant dispatched between an enablement limit and a

corresponding breakpoint can be moved in the energy market in order

to obtain more FCAS.

• For example, if a generator was dispatched between the upper

enablement limit and the upper break point, SPD may “constrain” the

unit in the energy market in order to obtain more FCAS, provided

this led to the lowest overall cost.

02-03-2016 Side 40


NCAS • Voltage Control

• Synchronous Compensator: a generating unit that can generate

or absorb reactive power while not generating energy in the

market;

• Generation Mode: a generating unit that can generate or absorb

reactive power while generating energy in the market.

• Network Loading Control

• to control the flow on interconnectors to within short term

limits

• can be controlled through the use of Automatic Generation

Control or Load Shedding.

02-03-2016 Side 41


System Restart (SRAS)

• Provided by two separate technology

1. General Restart Source: a generator that can start and supply

energy to the transmission grid without any external source of

supply.

2. Trip to House Load: a generator that can, on sensing a system

failure, fold back onto its own internal load and continue to

generate until AEMO is able to use it to restart the system.

02-03-2016 Side 42


Payments • Both are long term contract ancillary services

• paid for through a mixture of:

• Enabling Payments – made only when the service is specifically

enabled

• Availability Payments – made for every trading interval that the

service is available.

02-03-2016 Side 43


Primary FCAS Secondary FCAS VCAS Response time Between 6s and 60s 5min Instantaneous

Duration 90s Not specified Not specified Provider Generators with AGC Rapid generation

and load shedding Generators and syn. condensers

Monitoring Frequency monitoring. A range of 50+0.1 Hz is allowed

Performance testing and monitoring

Permanent monitoring of generators and reactive plants

Necessary amount

Determined by NEMMCO according to operational procedures

Determined by NEMMCO according to operational procedures

According to reactive power demand and energy consumption

Commitment Minimum is mandatory, optional provision is paid

Optional Mandatory to keep the pf between 0.9 capacitive and 0.93 inductive

Technical aspects of ancillary services provision in Australia

02-03-2016 Side 44


Primary FCAS Secondary FCAS VCAS Main costs identified

Capital and opportunity Capital and opportunity Investments and operation

Transaction mechanism

Competitive offers mechanism managed by NEMMCO

Competitive offers mechanism managed by NEMMCO

Annual bilateral contracts

Payment to providers

According to the measured quantity provided multiplied by clearing price

Enabling and compensation

Payments for availability, enabling and compensation

Customer’s payments

According to ‘causer pays’ methodology, based on the contribution towards frequency deviation

Recovery is prorated over all participants. All payments for contingency raise and lower services are recovered from generators and customers

Payments by customers according to their load on pro rata basis

Price discovery The clearing price as determined by SPD. Bid cap US $20/MWh

The clearing price as determined by SPD. Bid cap US $30/MWh

US $0.2/MVArh

Economic aspects of ancillary services provision in Australia

02-03-2016 Side 45


• Primary frequency regulation and voltage control services are

mandatory in all the studied markets, except for primary frequency

regulation in California.

• The response time demanded from the suppliers is directly related

with the price that the consumers pay for the service (faster response

is at higher price).

• The mechanisms used to manage the provision of the AS are bilateral

contracts or competitive offers

• The most important costs associated to frequency regulation

correspond to investments, operation, and reduced efficiency and

opportunity costs.

• Voltage control costs are mainly associated to investment, operation,

maintenance and opportunity costs.

Conclusions

02-03-2016 Side 46


02-03-2016 Side 47


Ancillary Service Market in India

02-03-2016 Side 48


Proposed Ancillary Services in India

•Frequency Control Ancillary Services (FCAS)

•Network Control Ancillary Services (NCAS)

•Power Flow Control Ancillary Services (PFCAS)

•Voltage Control Ancillary Services (VCAS)

•System Restart Ancillary Services (SRAS)

02-03-2016 Side 49


Frequency control ancillary Service

•IEGC band – 49.2 to 50.3 Hz

•Primary Response : FGMO

•Secondary Response :LFC/AGC (Absent by Design)

•Tertiary Response

•Availability Based Tariff (ABT)

•Use of Un-Requisitioned Surplus •Scheduled to the ‘POOL’

•Merit order

•Peaking Gas Stations

•Pumped Storage Plants

02-03-2016 Side 50


Network Control Ancillary Services (NCAS)

Power Flow Control Ancillary Services (PFCAS)

• To maintain the power flow through an interface within the physical limit.

[FACTS controllers]

Voltage Control Ancillary Services (VCAS)

• Primary voltage control: Automatic local control [AVR, SVC]

• Secondary voltage control: coordinates the actions of local

regulators in order to manage the injection of reactive power within a

regional voltage zone

• Tertiary Voltage Control: manual optimization of reactive power flows

across the power system

• Activated under contingency situation

System restart ancillary services (SRAS)

02-03-2016 Side 51


Execution of frequency support ancillary services

1. Eligibility Criteria

• All sellers and regional entities which are part of scheduling and

deviation settlement mechanism for real and reactive power.

• NOC issued by concern SLDC/RLDC to take part in power

exchange for participation in the ancillary service market.

2. Market Platform

• Through competitive bidding

3. Bidding and price discovery

• Window for bid in FSAS to be open after closure of DAM.

• Bids to be invited in a day ahead basis (time block wise bid with

quantum and price quote).

• Bid to be placed for standard time blocks of 2 hrs.

• Payment: pay as bid

02-03-2016 Side 52


Time Line for Frequency Support ancillary service Market

1800 hrs-2000hrs

• Bid call session

• Closed Double Sided Bidding

• Members can Submit, edit, modify, delete buy & sell bids

2000hrs -21.00hrs

• PX to provide information to the nodal agency

• Combined stack bid to be prepared by the nodal agency based on bids received from PXs.

2200hrs

• Scheduling

• Once dispatch decision is taken, PXs to calculate area clearing price based on transmission network available.(Pays IN)

D+1

• Accounting and settlement

• PX makes payment to bidders in proportion of the quantum of overdrawal. (Pays OUT)

02-03-2016 Side 53


Dispatch of FSAS bids in real time

•If the frequency remains 0.05 Hz below the lower operating frequency

range as specified in the IEGC for two consecutive time-blocks, the

nodal agency to give instructions to the FSAS provider to despatch in the

third time block for despatching generation from the fifth time block.

• If the frequency remains at 50.0 Hz for two consecutive time blocks,

after kicking-in of the FSAS, the nodal agency to give instructions for

withdrawal of FSAS.

• The generation despatched under FSAS would be given a despatch

certainty for 8 time blocks (i.e. 2 hours).

• In case withdrawal instructions are given by the nodal agency before

the completion of 2 hours, 50% of the bid price to be paid to the seller

for the period falling short of 2 hours.

• Further, in case a seller, whose power has been scheduled, fails to

provide the committed generation in real-time then the seller would be

liable to pay 1.5 times the bid price or the applicable UI rate whichever

is higher.

02-03-2016 Side 54


•No commitment charges payable to the bidders for making itself

available in the FSAS market.

•Upper limit of UI rate to be the ceiling price for the scheduled bid.

•The energy despatched under FSAS would be deemed to be delivered at

the Regional periphery.

•Any over injection by the FSAS provider shall not be paid for.

NODAL AGENCY: NLDC

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Voltage Control Ancillary Services (VCAS) Execution

•To be through PX.

•Payment to be made on pay-as-bid subject to maximum ceiling rate of

reactive energy.

•Payment to be as per regulation 6.6 of CERC (IEGC) Regulation, 2010.

NODAL AGENCY: NLDC

Execution of Black Start Ancillary Services (BSAS)

•The generators to be paid for one day capacity charges on the day of

providing the BSS, as determined by the Commission.

•The energy charges to be paid at twice the energy charges determined

by the Commission for the volume of energy supplied during the

restoration process.

•Other flexible generators providing BSAS to be paid fixed and energy

charges on the normative figure to be specified separately.

NODAL AGENCY: NLDC

02-03-2016 Side 56


Issues

• Need for ancillary Service

• Payment Risk

• Linkage to the UI ceiling Rate

• Possible Breach of PPAs

• Load Management by Utilities

• Market Design

• Commitment Charge

• Forecasting

02-03-2016 Side 57


Points of concern • How would FSAS be incentive compatible?

• Will FSAS act as a cheaper alternative than UI for grid indiscipline?

• Pay as Bid Vs Uniform Price Auction?

• Since, bids for FSAS market would open after the DAM closes, the

‘owners’ of capacity would prefer to sell electricity in the DAM first

and offer unsold capacity in for FSAS market. Clearly, supply side

would have less flexibility to address the needs of FSAS market. It is

important to make demand side bidding an integral part of the FSAS

mechanism.

• FSAS as a Substitute for UI Mechanism?

• Can be used as a option market along with UI mechanism.

• Develop it further to augment/replace UI mechanism in future

• Sharing of Revenue from FSAS

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• Criteria for deployment and withdrawal of FSAS

• Reduce Bid Span Granularity

• Need for Effective Market Monitoring

• Uncertainty of Despatch and Commitment Charges

• Payment to plants "identified to be despatched" or

"despatched"

02-03-2016 Side 59


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