區(qū)域電力系統(tǒng)整合的體制架構(gòu)-英

InstitutionalArchitecture

forRegional

PowerSystem

IntegrationGovernment,

Utilityand

Regulator

RolesIncollaborationwithINTERNATIONAL

ENERGYAGENCYTheIEAexaminesthefullspectrumofenergyissuesIEA

membercountries:IEA

associationcountries:includingoil,gasandcoalsupplyandAustraliaAustriaArgentinaBrazildemand,renewableenergytechnologies,electricitymarkets,energyefficiency,accesstoenergy,demandsidemanagementandmuchmore.Throughitswork,theIEAadvocatespoliciesthatwillenhancethereliability,affordabilityandsustainabilityofenergyinitsBelgiumChinaCanadaEgyptIndiaIndonesiaKenyaMoroccoSenegalSingaporeSouth

AfricaThailandUkraineCzech

RepublicDenmarkEstoniaFinlandFranceGermanyGreeceHungaryIrelandItalyJapan31membercountries,13

associationcountriesandbeyond.KoreaLithuaniaLuxembourgMexicoNetherlandsNew

ZealandNorwayPolandPortugalSlovak

RepublicSpainSwedenSwitzerlandRepublic

of

TürkiyeUnited

KingdomUnited

StatesThis

publication

and

anymap

included

herein

arewithout

prejudiceto

thestatus

of

or

sovereignty

overany

territory,to

thedelimitationof

internationalfrontiers

and

boundaries

andto

the

name

of

any

territory,cityor

area.The

EuropeanCommission

alsoparticipatesin

thework

of

the

IEASource:

IEA.International

Energy

AgencyWebsite:

InstitutionalArchitecturefor

Regional

PowerSystemIntegration:

Government,

UtilityandRegulatorrolesAbstractEstablishing

appropriate

institutional

architecture

is

important

to

integrate

powersystems

across

bordersand

facilitate

electricity

trading,

as

even

if

the

necessaryinfrastructure

is

in

place,

it

does

not

automatically

follow

that

it

is

being

used

toexchangepower

effectively.The

co-ordinationof

allstakeholders

–governments,utilities1

and

regulators

–

is

required

within

jurisdictions,

as

is

the

creation

ofregionalentitiesto

supportandoverseetheintegrationprocess.This

report

therefore

examines

stakeholder

roles

at

different

stages

of

cross-border

integration

to

enable

multilateral

power

trade.

As

energy

regulators

are

ourmain

audience,

we

focus

on

their

roles

and

responsibilities

after

briefly

addressingthoseof

governmentsand

utilities.This

document

was

developed

under

the

Regulatory

Energy

TransitionAccelerator

(RETA)

initiative,

which

aims

to

enhance

the

capacity

of

regulators

toincrease

the

speed

of

clean

energy

transitions.

It

is

part

of

a

series

of

guidancenotes

prepared

by

the

IEA,

the

World

Bank’s

Energy

Sector

ManagementAssistance

Program

(ESMAP)

and

IRENA

to

help

key

stakeholders

navigate

thechallenges

associated

with

regional

power

system

interconnections,

by

providinganalytical

outputs

and

examples

of

best

practices

for

regulatory

frameworks

andmechanisms.

These

notes

focus

on

the

soft

infrastructure

of

cross-border

powerexchange,

in

accordance

with

the

priority

topics

identified

through

a

surveyof

regulators

in

February-March

2023.1

In

this

paper,

a

utility

is

any

entity

that

performs

activities

related

to

electricity

supply

and

system

operations,

in

eithertransmissionordistribution.

Theseactivities

canbecarriedout

by

thesameentity

inthecaseofvertically

integratedutilitiesorseparatedinregionswheretheenergy

sectorisunbundled.PAGE|

1InstitutionalArchitecturefor

Regional

PowerSystemIntegration:

Government,

UtilityandRegulatorrolesIntroductionIntegrating

power

systems

at

the

regional

level

offersmany

benefitsCross-border

integration

of

power

systems

has

long

been

recognised

as

a

keystrategy

to

strengthen

electricity

security,

make

electricity

more

affordable

andscaleupaccessto–andintegrationof–renewableenergyresources.Interconnecting

power

systems

makes

generation

capacity

from

a

widergeographical

area

available

to

meet

demand

and

maintain

frequency.

Thisdecreases

dependency

on

specific

generators,

and

capacity

reserves

canpotentiallybeshared,

boostingtheresilienceofthebroader

system.Integrating

power

systems

also

increases

system

efficiency

through

economies

ofscale

and

price

convergence,

and

by

allowing

existing

generation

sources

to

beused

more

efficiently.

Providing

joint

access

to

a

wider

range

of

electricitygeneration

resources

can

reduce

total

operating

costs.

In

Europe,

for

example,

itis

estimated

that

cross-border

electricity

trade

delivered

EUR

34

billion

more

inwelfare

benefits

in2021thanif

nationalmarkets

had

beenisolated.Finally,

larger

power

systems

can

integrate

greater

volumes

of

weather-dependant

variable

renewable

energy

because

their

wider

geographical

coveragenaturally

smooths

the

variability

of

the

underlying

resource.

This

can

also

enablesupply

diversification

and,

where

complementary

exists,

allow

renewable

energysources

to

be

used

more

efficiently.

Additionally,

interconnection

gives

powerproducers

access

to

a

wider

range

of

customers,

which

can

strengthen

investmentconfidence

and

boost

the

adoption

of

renewables.

Thus,

when

coupled

withdecarbonisation

policies,

interconnection

can

accelerate

CO2

emissionsreductions.Establishing

multilateral

power

trading

requires

political,technical

and

institutional

co-ordinationInrecognitionofthesebenefits,multiplejurisdictionsaroundtheworldhave

beenworkingtowardspowergridinterconnectionand

multilateral

powertrading.In

thisreport,

jurisdictional

borders

can

be

international

or

domestic,

and

our

assessmentofregionalintegrationincludescasesinAustralia,

theUnitedStates

andCanada.Multilateral

power

trading

requires

the

establishment

of

harmonised

rules

and/oragreements

among

multiple

jurisdictions,

and

international

experience

has

shownthat

a

common

set

of

political,

technical

and

institutional

minimum

requirementsneed

to

be

met.

Political

requirements

encompass

the

creation

of

political

will

andPAGE|

2InstitutionalArchitecturefor

Regional

PowerSystemIntegration:

Government,

UtilityandRegulatorrolesintergovernmental

agreements

from

participating

countries,

while

technicalrequirements

cover

rules

and

regulations

to

ensure

the

effective

operation

ofcross-border

trade.

For

instance,

grid

codes

must

be

harmonised,

capacityallocation

and

calculation

methodologies

developed,

and

data

collection

andinformation-sharing

systems

instituted.

Institutional

requirements

refer

tomultilateralpowertrade

mechanismssuchasdisputeresolutionandsettlements.Minimum

requirements

for

establishing

multilateral

power

trade?

Politicalwill?Harmonisedtechnicalstandards(grid

codesforinterconnectors)?

Co-ordinationof

tradearrangements?

Intergovernmentalagreement(s)?Settlement

andpayment

mechanism?

Wheelingmethodology?

Common

workinglanguage?

Third-partyaccessagreements?Datacollectionandinformation-sharingsystems?

InterconnectorcapacitycalculationmethodologyIEA.

CCBY

4.0.Source:IEA(2019),

Establishing

Multilateral

Power

Trade

in

ASEAN.The

integration

of

tradingrules

andmechanisms

can

be

divided

intothreelevels:early-stage,shallowanddeepharmonisation,dependingon:thelevelof

interconnectivitywithneighbouringcountriesthenatureandorganisationof

powertradingarrangements

the

degree

of

technical

harmonisation

of

grid

or

market

operation

rules,

grid

codes,tariffsanddatasharingthedegreeof

co-ordinationinplanningand

investmenttodevelopinfrastructuretheamount

of

institutionalarchitectureinplaceanditsenforcementpower.

Identifying

the

main

characteristics

of

each

stage

is

helpful

to

understand

thechanges

and

minimum

requirements

needed

to

transition

to

higher

levels

ofmarket

integration.PAGE|

3InstitutionalArchitecturefor

Regional

PowerSystemIntegration:

Government,

UtilityandRegulatorrolesCross-border

power

grid

and

market

integration

levelsEarly

stageShallowDeepIntegration

levelInterconnected

gridslinkseveralneighbouring

countries.Regional

interconnection

isfragmentedand

often

underutilised.Most

countriesinthe

region

areinterconnected

and

participate

intrade.Useof

regional

infrastructuregradually

increases.InterconnectioninfrastructureBilateralpower

trade

startsbetween

twocountries,with

limited

volume.Planning

happens

at

a

national

level,possibly

with

specific

regional

agreementstodevelop

priorityinfrastructure.Planning

isoptimised

with

a

regionalperspective.

Harmonisedmethodologiesmay

be

usedfornational-level

planning.National

investments

aresomewhatco-ordinated

with

an

optimisedregional

investmentplan.Planning&

investmentco-ordinationSome

harmonisationof

regulatorypracticesand

technical&

market

rulesexists.(Common

data

acquisitionandsupervisionprotocols

are

inplace.)Harmonisedregulations

and

technical&market

rules,including

gridcodes,exist.(Interoperable

and

similar

digitalTechnicalharmonisationSimple

rulesare

agreed

upon

fortheoperation

of

theinterconnected

grids.technologies

and

platforms

are

inplace.)Regional

markets

are

fullycompetitive,cost-reflective

and

offer

various

products.Transmission

pricingevolvesShort-termmarkets

oftensupplementlong-termPPAs.

Transmission

pricingspreads

costs

evenly

across

allusers.Commercialtrading

&market

designLong-term

bilateralPPAspredominate.tobe

more

granular.Regional

regulatory

bodies

and/or

steeringcommittees

are

inplacebut

faceenforcement

challenges.Enforceabilityof

regional

regulatory

bodiesand/or

steering

committees

isat

anextended

level.InstitutionalarchitectureBilateralagreements

are

popular,

with

nostrongsupranational

entityinvolved.ExamplesGreater

Mekong

SubregionLTMS-PIPSAPP,

WAPP,

EAPP,MEREU

Internal

Market,WEIMIEA.

CCBY

4.0Notes:EAPP

=EasternAfricaPowerPool.LTMS-PIP=LaoPDR-Thailand-Malaysia-SingaporePowerIntegrationProject.SAPP=SouthernAfricanPowerPool.

WAPP

=WesternAfricanPowerPool.

WEIM

=WesternEnergy

ImbalanceMarket

(USA).Source:AdaptedfromWorldBank(forthcoming),BeyondBorders:PowerGridInterconnections&Regional

ElectricityMarketsfortheSustainableEnergyTransition(workingpaper).PAGE|

4InstitutionalArchitecturefor

Regional

PowerSystemIntegration:

Government,

UtilityandRegulatorrolesKey

milestones

mark

the

lengthy

regional

power

systemintegration

processIt

can

take

a

long

time

for

a

fully

integrated

regional

electricity

market

tomaterialise,

usually

decades,

as

exemplified

by

the

EU

integrated

regionalelectricity

market.

The

process

typically

starts

with

a

bilateral

cross-borderelectricity

trade

arrangement

before

an

explicit

expression

of

interest

fromgovernments

and

utilities

in

multilateral

power

trading,

usually

in

the

form

of

amemorandum

of

understanding

(MoU),

kicks

off

a

regional

market

initiative.

Insome

cases,

the

MoU

already

specifies

the

creation

of

institutions

such

as

aregional

system

operator

and

a

regional

regulator

and

defines

their

respectiveroles.Establishment

of

a

regional

regulator

–

or

sometimes

co-operation

among

nationalregulators

–

can

incite

substantial

progress

by

creating

consensus

on

theoperational

aspects

of

cross-border

trade.

Beyond

this

point,

institutional

andorganisational

co-ordination

are

crucial

for

successful

integration

and

operation,with

regional

structures

being

granted

greater

power.

This

often

leads

to

theharmonisationofmarketrulesandregulationsat

the

regionallevel.Historical

milestones

ofselected

regional

power

system

integration

initiatives167APG20MEREAPPWAPPSAPPEU507209397306019201940Firstbilateraltrade1960198020002020IntergovernmentalMoUEstablishmentofregionalregulatorIEA.

CCBY

4.0Notes:APG=ASEAN

PowerGrid.

MER=MercadoEléctricoRegional.EAPP=EasternAfricaPowerPool.

WAPP

=WestAfricanPowerPool.SAPP=SouthernAfricanPowerPool.EU=EU

InternalElectricityMarket.Achieving

these

milestones

and

meeting

the

requirements

described

above

callsfor

the

active

participation

of

multiple

stakeholders

–

governments,

utilities

andregulators

–

across

jurisdictional

boundaries

because,

in

addition

to

physicalinterconnectors,

consensus

is

needed

on

system

operations

and

the

relatedPAGE|

5InstitutionalArchitecturefor

Regional

PowerSystemIntegration:

Government,

UtilityandRegulatorrolesregulations.

Therefore,

reaching

a

deeper

level

of

integration

is

often

an

iterativeprocess

in

which

stakeholder

consensus

on

changes

and

their

implementation

isgraduallyachieved.Regional

institutions

tasked

with

improving

and

strengthening

the

system

at

theregional

level

may

thus

be

the

best

placed

to

instigate

the

successive

waves

ofchangein

thisevolution.Role

of

governmentsGovernments

provide

the

political

impulse

for

cross-border

power

system

integrationNational

(or

supranational)

governments

provide

the

legal

and

political

foundationfor

interconnection

projects,

with

their

political

will

and

leadership

supporting

theearly

stages

of

the

process.

Intergovernmental

agreements

such

as

MoUs

andjoint

statements,

which

sometimes

encompass

the

creation

of

regional

institutions,typically

initiate

the

actions

needed

to

fulfil

political

requirements.

Like

any

othercross-border

activity,

interconnectors

cannot

be

constructed

or

operated

withouttheconsensus

of

allparticipatingcountries.In

the

ASEAN

region,

member

states

signed

an

intergovernmental

MoU

in

2007to

establish

regional

power

trade,

followed

by

subregional

agreements

for

specificinterconnectionprojects

(e.g.the

LTMS-PIP

and

theBIMP-PIP).

ASEANMemberStates

are

currently

in

the

process

of

extending

this

initial

MoU

until

2025.Similarly,

the

Central

American

Electricity

Market

Framework

Treaty,

signed

bythe

region’s

six

national

governments

in

1996,

provided

the

political

impetus

toformally

create

a

regional

competitive

power

market

(MER),

turning

decade-longfeasibility

studies

and

local

power

trading

into

a

co-ordinated

regional

powerintegrationprocess.In

some

areas,

dedicated

platforms

for

governments

facilitate

diplomatic

efforts

toformulate

consensus

among

countries

involved

in

regional

interconnections.

InAfrica,

the

Regional

Economic

Communities

provide

institutional

support

formarket

integration

and

accelerate

the

creation

of

international

consensus.

In

2006,the

Economic

Community

of

West

African

States

(ECOWAS)

took

the

lead

increating

the

West

African

Power

Pool

(WAPP).

Two

years

later,

the

ECOWASRegional

Electricity

Regulatory

Authority

(ERERA)

was

created

within

theframework

of

the

ECOWAS

Energy

Protocol

and

the

WAPP

to

regulate

cross-border

electricity

connections

and

trade,

acting

as

a

central

regulatory

entity

withthe

authority

to

make

legally

binding

decisions.

In

the

case

of

Central

America’sMER,

the

Central

American

Integration

System

(SICA)

was

created

in

1993

as

aregionalandpoliticalorganisation.However,

the

role

of

governments

is

not

only

to

forge

intergovernmentalagreements.

They

also

endorse

regional-level

regulations

on

cross-border

trade,PAGE|

6InstitutionalArchitecturefor

Regional

PowerSystemIntegration:

Government,

UtilityandRegulatorrolesstandards

and

market

design

(if

a

market

is

in

place).

For

instance,

both

EUmember

states

and

the

EU

Parliament

will

discuss

and

amend

the

currentEuropean

Commission

proposal

for

EU

electricity

market

reform

to

reach

aconsensus.Furthermore,

when

regulations

are

adopted,

governments

bear

the

ultimateresponsibility

for

ensuring

that

regional

agreements

are

transposed

into

nationalregulations.

For

example,

France’s

government

was

obligated

to

revise

its

nationalEnergy

Code

to

clarify

the

role

of

local

regulatory

authorities

in

line

with

relevantEuropeandirectives.Apart

from

laying

the

legal

and

institutional

foundation

for

cross-borderinterconnectors,

governments

can

support

integration

projects

by

promoting

andsimplifying

transmission

investments.

For

instance,

every

two

years

the

EuropeanCommission

endorses

a

list

of

Projects

of

Common

Interest

to

simplify

planningand

streamline

permit-granting

to

facilitate

the

commissioning

of

cross-borderintegrationprojects.Role

of

utilitiesElectricity

utilities

and

power

system

operators

are

thedriving

force

behind

regional-level

technicalharmonisationAs

utilities

bear

primary

responsibility

for

constructing

and

operating

powersystems

to

ensure

the

delivery

of

secure

supplies,

collaboration

among

them

iscrucial

to

develop

cross-border

interconnections.

Utilities

developinterconnections

and

assess

their

impacts,

share

their

knowledge

of

the

systemfor

regional

power

system

planning,

and

adjust

their

technical

standards

toharmonise

with

other

utilities

in

the

region.

These

actions

and

roles

satisfy

thetechnicalrequirementsfor

cross-borderpowertrading.Effective

co-ordination

is

necessary

to

assess

the

energy

security

impacts

ofinterconnection

in

regional

power

system

integration.

Typically,

utilities

assessimpacts

on

frequency

stability,

violation

of

thermal

limits,

voltage

profiles

andshort-circuit

strengths,

although

the

methods

and

criteria

adopted

vary

by

utility.Assessment

findings

determine

the

techno-economic

feasibility

of

aninterconnection

project

and

technology

selection,

but

may

also

incite

modificationsto

national

power

system

plans

or

operating

procedures

(procurement

of

reservesanddeterminationofthermallimits,

grid

codes,

communicationprotocols,etc).As

a

second

step,

utilities

may

also

assess

dispatch

and

market-clearing

impacts,as

the

injection

or

offtake

of

power

at

the

interconnector

may

affect

domesticdynamics.

The

results

of

these

various

studies

often

shape

the

design

of

cross-border

trade

agreements

and

rules

on

how

interconnection

capacity

is

allocatedandused.PAGE|

7InstitutionalArchitecturefor

Regional

PowerSystemIntegration:

Government,

UtilityandRegulatorrolesUtilitiescanalsobeinvolvedinregionalpowersystemplanning,consideringtheirtools

and

knowledge

of

the

system.

This

work

must

be

performed

jointly

withplanning

authorities

to

ensure

that

energy

infrastructure

meets

both

cross-sector(electricity,

gas,

transport,

heating,

climate,

etc.)

and

regional

co-ordinationobjectives.Depending

on

final

regional

arrangements,

utilities

may

need

to

adjust

their

owngrid

codes,

operational

procedures,

database

structures,

communicationprotocolsandgridmodelling

methodologies.

Toharmonisearrangementsamongdifferent

utilities,

working

groups

and

task

forces

made

up

of

representatives

ofeachutility(andideally

of

theregulator)

shouldbeconvened.A

regional

association

of

utilities,

system

operators

and

planning

co-ordinators,

oran

independent

system

operator,

may

eventually

be

needed

to

ensure

all

workstreams

are

harmonised

and

guided

by

a

single

strategic

outlook.

Establishingsuch

a

regional

institution

makes

it

easier

to

aggregate

local

power

systemdevelopmentplansintoaregionalproject.In

Europe,

the

European

Network

of

Transmission

System

Operators

forElectricity

(ENTSO-E)

is

responsible

for

drafting

Europe-wide

development

plans,a

process

that

involves

all

relevant

local

transmission

system

operators

(TSOs).Meanwhile,

the

United

States

currently

has

seven

regionaland

state

independentsystem

operators

(ISOs)

and

regional

transmission

organisations

(RTOs)2

tooversee

regional

planning,

pricing

and

wholesale

power

markets.

Local

utilitiesarepartoftheseRTOs

and

ISOs.Similarly,

theAssociation

of

Power

Utilities

of

Africa

(APUA)

unitesAfricanpowerutilities

and

was

important

in

establishing

the

Central

Africa

Power

Pool

in

2003and

the

Eastern

Africa

Power

Pool

in

2005.

The

Heads

of

ASEAN

PowerUtilities/Authorities

(HAPUA)

in

Southeast

Asia

and

the

Association

ofMediterranean

Transmission

System

Operators

(Med-TSO)

in

theMediterraneanregionplay

similarroles.Role

of

regulatorsRegulator

mandates

differ

regionally

and

locally

and

canevolveAlong

with

governments

and

utilities,

regulators

are

also

key

stakeholders

incross-border

power

market

integration.

They

can

be

independent

or

part

of

thecentral

government,

for

instance

within

a

department

of

the

ministry

in

charge

of2

The

California

Independent

System

Operator

(CAISO),

Midcontinent

Independent

System

Operator

(MISO),

IndependentSystem

Operator

New

England

(ISO-NE),

New

York

Independent

System

Operator

(NYISO),

PJM

Interconnection,SouthwestPowerPool(SPP)and

theElectricReliabilityCouncilofTexas(ERCOT).PAGE|

8InstitutionalArchitecturefor

Regional

PowerSystemIntegration:

Government,

UtilityandRegulatorrolesenergy.

We

discuss

the

roleof

regulators

independentlyof

governmentsbecauseregulatorybodieshavedistinctiveroles.Although

there

is

no

single

ideal

configuration,

a

number

of

theoretical

andempirical

arguments

support

the

creation

of

independent

regulators

to

benefitenergy

consumers.

Many

deficiencies

can

be

attributed

to

a

lack

of

regulatoryindependence,

whichisa

power

sectorchallenge

almost

all

developingcountriesface

according

to

the

Global

Electricity

Regulatory

Index.

However,

asestablishing

an

independent

institution

requires

time

and

resources,

it

issometimesnotthemosteffectivesolutionwhenquick

actionisneeded.Global

experience

has

shown

that

successful

regional

market

integration

involvesadopting

a

regulatory

framework

to

enable

co-ordination

among

nationalregulators,

market

operators

and

system

operators.

Where

a

regional

regulatoryentity

has

been

designated,

it

is

a

key

institution

for

cross-border

power

exchangesbecauseit

facilitates

fulfilmentofthe

technical

and

institutional

requirements,

withitsfunctionsgenerally

covering:Regulatory

oversight

of

regional

electricity

infrastructure

development

and

powergrid

planning,

by

reviewing

(through

technical

or

planning

process

reviews)

andapprovingplansadvanced

bytheregionalplanning

entity.

Harmonisation

of

investment

recovery

methodologies

(e.g.

for

transmission

costallocation,

transmission

pricing

and

wheeling

charges)

among

interconnectedjurisdictions.

Definition

and

regulation

of

the

regional

market

framework

(e.g.

tradingmechanismsandsettlements,marketrules).

Monitoring

of

electricity

markets

and

market

participants

to

ensure

transparency,compliance

with

market

regulations

and

fair

competition,

and

the

designation

ofdispute

resolution

methods

(potentially

also

including

an

arbitration

role

forregulators).A

regulator’s

role

varies

depending

on

whether

power

system

integration

effortsoccur

within

the

regulator’s

own

jurisdiction

or

involve

multiple

regulatedjurisdictions.

When

an

overarching

regulatory

entity

(national

or

supranational)coexists

with

local

regulators(subnational

or

national),

the

latter