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REVIEW OF MARKET INFORMATION TO FACILITATE EFFICIENT ELECTRICITY SPOT AND FUTURES TRADING DECISION PAPER 22 nd July 2014 ENERGY MARKET AUTHORITY 991G Alexandra Road #01-29 Singapore 238164 www.ema.gov.sg
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REVIEW OF MARKET INFORMATION TO FACILITATE EFFICIENT ELECTRICITY SPOT AND FUTURES TRADING

DECISION PAPER

22nd July 2014 ENERGY MARKET AUTHORITY

991G Alexandra Road #01-29 Singapore 238164

www.ema.gov.sg

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Disclaimer: The information contained in this document is subject to change and shall not be

treated as constituting any advice to any person. It does not in any way bind the

Energy Market Authority (‘EMA’) to grant any approval or official permission for any

matter, including but not limited to the grant of any exemption nor to the terms of any

exemption. EMA reserves the right to change its policies and/or to amend any

information contained in this document without prior notice. Persons who may be in

doubt about how the information in this document may affect them or their commercial

activities are advised to seek independent legal advice or any other professional advice

as they may deem appropriate. EMA shall not be responsible or liable for any

consequences (financial or otherwise) or any damage or loss suffered, directly or

indirectly, by any person resulting or arising from the use of or reliance on any

information contained in this document.

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REVIEW OF MARKET INFORMATION TO FACILITATE EFFICIENT ELECTRICITY SPOT AND FUTURES TRADING

DECISION PAPER

1. INTRODUCTION

1.1 An extensive amount of market information is currently made available by the

Energy Market Company (‘EMC’)1 and the Power System Operator (‘PSO’)2. The

information can be classified under two broad categories:

a. Market information which is made available to spot market participants and

also non-market participants who subscribes to EMC’s data subscription

services (‘data subscribers’);3 and

b. Market information which is made available only to spot market participants

or a subset of spot market participants, more specifically the commercial

generation companies (‘gencos’).

1.2 The Energy Market Authority (‘EMA’) has reviewed the existing market

information including the specification and publication timeline thereof. The objective is

to enhance data transparency which will facilitate efficient trading and risk management

for participants in our wholesale electricity market (i.e. the spot market), and also the

electricity futures market. In this regard, EMA has conducted a public consultation to

seek comments and feedback on the following two proposals:

Proposal 1: All data subscribers to be given the same market information which is currently provided to spot market participants or gencos.

Proposal 2: All data subscribers and spot market participants to be given

aggregated energy offer information.

1.3 This paper sets out EMA’s decisions on the two proposals after taking into

account the comments received (refer to Appendix 1 for the comments and EMA’s

responses).

1 EMC operates the spot electricity market under an electricity licence granted by EMA.

2 PSO, which is a division of EMA, is responsible for ensuring secure operation of the power system and

reliable supply of electricity to consumers in Singapore. In this regard, PSO directs the operation of the high-voltage transmission system, controls the dispatch of registered facilities in the spot market, co-ordinates outage of generation and transmission facilities (including the release of these facilities for maintenance, testing, commissioning and repair). 3 The various subscription service packages offered by EMC can be viewed at the following EMC

website: https://www.emcsg.com/data

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2. RECAP OF EXISTING MARKET INFORMATION

2.2 Chapter 6 of the Market Rules4 sets out the information to be published by EMC

to facilitate the physical operation of the power system and the dispatch of registered

facilities to meet electricity demand/load (refer to Table 1 for the list of such

information). Currently, all spot market participants and data subscribers have access

to such information5 which is in respect of the actual/real-time dispatch schedule

(‘RTDS’) for each half-hourly dispatch period, and the following 3 look-ahead

schedules:

a. The short-term schedule (‘STS’), at any point in time, covers twelve

consecutive dispatch periods from the end of the current dispatch period.

b. The pre-dispatch schedule (‘PDS’):

i. at any point in time before 12:00 hours in a given day, covers all dispatch periods from the end of the current dispatch period till the end of the current dispatch day; and

ii. at any point in time at or after 12:00 hours in a given day, covers all dispatch periods from the end of the current dispatch period till the end of the following day.

c. The market outlook schedule (‘MOS’), at any point in time in a given day,

covers the dispatch periods from that point in time till the end of the following 6th day.

2.3 Chapter 5 of the Market Rules requires PSO to periodically assess and report on

the adequacy and security of the power system, and also to co-ordinate and approve

the planned outage schedules of registered facilities. In this regard, PSO prepares and

issues (through EMC) the following reports to spot market participants only:

a. Adequacy and Security Assessment (‘ASA’) reports which provide PSO’s

forecast of system demand (MW), available generation capacity, overhaul

and de-rated generation capacity, available regulation capacity and available

reserve capacity in each reserve class:

4 The Market Rules are available at the following EMC website: https://www.emcsg.com/marketrules

5 All spot market participants have access to the information by logging into a secured area of EMC’s

website. Non-market participants (i.e. data subscribers) can also access the same information by subscribing to EMC’s data subscription services.

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Table 1: List of information currently available to spot market participants and EMC’s

data subscribers

S/No. Information Reference Remarks

1 Total load a. Total load, prices and system shortfalls for MOS, PDS and STS are projected information.

b. The information in respect of the MOS is published by EMC by 9:00 hours of each day.

c. The information in respect of the PDS is published by EMC not later than 15 minutes prior to the start of the first dispatch period of the PDS.

d. The information in respect of the STS is published by EMC not later than 25 minutes prior to the start of the first dispatch period of the STS.

2 Total transmission losses

3 Total reserve requirement by reserve class

4 Total regulation requirement

5 Energy price associated with each market network node at which a generation registered facility or generation settlement facility is located

6 Uniform Singapore Energy Price (‘USEP’)

7 Reserve price for each reserve class and reserve provider group

8 Regulation price

9 Any system energy shortfall

10 Any system reserve shortfall, by reserve class

11 Any system regulation shortfall

12 List of security and generation constraints applied for market-clearing

13 Advisory notices EMC will publish advisory notices as soon as practicable pertaining to the following events for any dispatch period in the current MOS, PDS and STS:

a. any surplus or shortfall in energy, regulation or reserve by reserve class;

b. any major equipment outage, load shedding or other abnormal condition in the power system that the Power System Operator (‘PSO’) considers material is occurring or is likely to occur;

c. communications warning advisory notices of difficulties which market participants are experiencing, or EMC considers a significant probability that market participants will experience, in delivering or receiving communications to or from EMC or PSO; and

d. price warning advisory notices that the prices calculated or released to market participants may be subject to revision.

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i. There are two types of ASA reports: (1) the Daily ASA report which

sets out the half-hourly forecast over a rolling 14-day period beginning

at the end of the current day; and (2) the Monthly ASA report which

sets out the daily forecast over a rolling 12-month period commencing

from the following month.

ii. PSO will prepare and issue to all spot market participants (through

EMC) the Daily ASA report by 17:00 hours on the same day, and the

Monthly ASA report by 5 business days before the end of the current

month.

iii. PSO may, at any time, issue an updated Daily ASA report or Monthly

ASA report to incorporate changes that, in the opinion of PSO, are

materially significant.

b. Annual Outage Plan which consists of the Annual Generator Outage

Programme (‘AGOP’) and the Annual Equipment Outage Programme

(‘AEOP’). The AGOP and AEOP respectively set out the planned outage

schedule in respect of all market participants’ generating units and non-

generating equipment (e.g. transmission/switch-house equipment and

designated load registered facilities):

i. PSO will issue, by 15th September of the current year, a provisional

AGOP and AEOP for consultation with the market participants. PSO,

after the consultation, will decide on the final version of the AGOP and

AEOP, and issue them (through EMC) by 15th October of the current

year.

ii. PSO will update and issue the AGOP and AEOP as and when required

taking into account ad hoc outage requests or delays in completion of

maintenance work.

2.4 In addition to the above market information provided under the Market Rules,

PSO will prepare and issue directly to gencos only, a Projected Gas Curtailment

Schedule (‘PGCS’) to facilitate their operational responses (e.g. adjusting the

maintenance schedule of their generation facilities, preparing to run-up their steam

power plants, etc). The PGCS sets out aggregated gas curtailment information in terms

of the percentage reduction in total piped natural gas (‘PNG’) supply to Singapore in

bands of 5% (from 0% to 100%) on an hourly basis and up to the end of the following

year:

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i. To prepare the PGCS for next year, each PNG importer is required to

submit to PSO, by 15th August of the current year, the planned

upstream maintenance schedule affecting gas supply to Singapore

during the next year. PSO will de-conflict over-lapping upstream

maintenance before issuing the PGCS by 15th October of the current

year.

ii. As and when a PNG importer receives any official notice from its

upstream gas seller conveying any information or updates on any

incident, event or activity (planned or unplanned) affecting the quantity

of PNG available for supply to Singapore, the PNG importer is required

to inform PSO:

(1) within 2 hours following receipt of the official notice if the gas

supply to Singapore over the next 48 hours is affected; and

(2) no later than 17:00 hours in the next business day following

receipt of the official notice, or at least 48 hours before the

associated change in gas supply to Singapore, whichever is

earlier, if the gas supply to Singapore beyond the next 48 hours is

affected.

iii. If there is any change to the PGCS based on the update from any PNG

importer, PSO will issue (via email) to the gencos the updated PGCS:

(1) within 2 hours following receipt of the PNG importer’s update if the

gas supply to Singapore over the next 48 hours is affected; and

(2) no later than 17:00 hours in the next business day following

receipt of the PNG importer’s update, or at least 48 hours before

the associated change in gas supply to Singapore, whichever is

earlier, if the gas supply to Singapore beyond the next 48 hours is

affected.

3. EMA’S DECISION ON PROPOSAL 1

3.1 Any person can choose to become a data subscriber of EMC to access the

market information as set out in Table 1. Access to other market information such as

the ASA reports, AGOP and AEOP is currently restricted to spot market participants,

and the PCGS to gencos only.

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3.2 There is no commercial sensitivity or adverse impact on market competition or

national security if access to the ASA reports, AGOP, AEOP and PGCS is extended to

any data subscriber or non-genco market participant. Furthermore, disclosure of such

information will help to eliminate the significant information asymmetry that currently

exists and may also provide pro-competitive benefits to futures market participants.

3.3 Hence, EMA has decided that all data subscribers and spot market

participants shall be given access to the ASA reports, AGOP, AEOP and PGCS

through EMC. The coverage of the AGOP and AEOP will also be extended to

look-ahead 3 years (instead of 1 year currently) with effect from 2015.6

4. EMA’S DECISION ON PROPOSAL 2

4.1 Currently, spot market participants’ price-quantity energy offers are not

disclosed. The disclosure of such information could facilitate efficient trading in the spot

and futures market, but could also increase the likelihood of exercise of market power

or concerted activities among spot market participants to elevate pool price.

4.2 Table 2 summarises the offer information disclosure practices in various

competitive electricity markets with electricity futures trading in the US and Asia Pacific.

While offer information is generally released, the details and time lag varies across

different markets. Most competitive electricity markets in the US release unit-specific

energy offer data with a 3-month time lag and units’ identify masked. In comparison,

Australia and New Zealand currently release offer data by units (including identity) on a

short time-lag of 2 days and 2 weeks respectively. There is no clear pattern to disclose

more offer information as the electricity markets become more mature.7

4.3 The key concern with releasing energy offer information is that it could lead to

strategic bidding behaviours, especially during tight supply situations. This can be

mitigated by aggregating the energy offer information and delaying data release which

may in turn trigger dynamic responses among the spot market participants, making it

more difficult for spot traders to characterise and understand the dynamic response

effect for strategic bidding.

6 PSO will adopt the same process and timeline to prepare and issue, by 15

th October of the current

year, the final AGOP/AEOP for next year and a provisional AGOP/AEOP covering the following two years. E.g. by 15

th October 2014, PSO will issue the final AGOP/AEOP for 2015 and provisional

AGOP/AEOP for 2016 and 2017. 7 In several competitive electricity markets in the US, the delay in the release of offer data was shorten

from 6 months to 3 months in 2008/2009 and the 3-month delay practice has been maintained since then. In the Alberta Electricity Market, the Market Surveillance Administrator is reviewing to release less granular offer information to prevent collusive behaviour.

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Table 2: Offer data disclosure practices in competitive electricity market with futures trading 8

Posting Time Lag

Form of Disclosure

Unit-specific offers with IDs

Unit-specific offers with masked IDs

Offers aggregated by zone

At end of each trading hour

AESO block-wise energy

offer data NYISO day-ahead energy offer data

1-day lag Australian NEM energy offer

2-day lag

ERCOT energy supply and demand curve

2-week lag New Zealand energy offer

2-month lag AESO energy market merit order

3-month lag MISO day-ahead and real-time cleared energy offer

and bid data

ISO-NE energy offer data

NYISO energy offer data

CAISO energy offer data

4-month lag PJM daily energy bid data

4.4 On balance, EMA has decided to make available aggregated energy offer

information to all data subscribers and spot market participants through EMC

with a 4-week time-lag. The aggregated energy offer information (also referred to as

the “energy offer stack”) will show, for each half-hour period and based on all offers

considered for the RTDS, each distinct offer price (in $/MWh) and the total offer

capacity (in MW) at that price. With this information, external futures traders would be

able to carry out fundamental modeling and value-at-risk assessments in order to enter

and trade in our futures market, making it more liquid and efficient. The 4-week delay

would be adequate for short-term tight market conditions to normalise and mitigate

informational feedback for strategic bidding in our spot market.

4.5 EMA will continue to monitor all gencos’ bids closely and will not hesitate to take

swift enforcement actions against any genco exhibiting anti-competitive behaviours.

8 Acronyms: Alberta Electric System Operator (‘AESO’); California Independent System Operator

(‘CAISO’); Electric Reliability Council of Texas (‘ERCOT’); ISO New England (‘ISO-NE’); Midwest ISO (‘MISO’); New York ISO (‘NYISO’); Pennsylvania, Jersey, Maryland Power Pool (‘PJM’).

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5. IMPLEMENTATION SCHEDULE

5.1 EMC will implement the abovementioned decisions of EMA by end September

2014. The templates of the ASA reports, AGOP, AEOP, PGCS and aggregated energy

offer information to be made available by EMC to all data subscribers and spot market

participants are as shown in Appendix 2.

* * *

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APPENDIX 1

No. Respondent Feedback EMA’s Response

1(a) YTL

PowerSeraya

We suggest that EMA look into the provision of

indicative information on gas, transmission, load and

generation facilities outages for time periods beyond

that covered by the AGOP, AEOP and PGCS so as to cover

the time periods for which electricity futures apply. We

understand that such information so far forward is only

indicative and subject to further confirmation by the

information providers.

The coverage of the AGOP and AEOP will be extended to look-

ahead 3 years instead of 1 year currently. PSO will adopt the

same process and timeline to prepare and issue, by 15th

October of the current year, the final AGOP/AEOP for the next

year and a provisional AGOP/AEOP covering the following two

years. The provisional AGOP and AEOP will be based on

updates as provided by the relevant parties and hence only

indicative.

1(b) YTL

PowerSeraya

With respect to insider trading, would gencos be allowed

to buy electricity futures for the purpose of hedging of

their planned/unplanned generation capacity outages

before information on those planned/unplanned

generation capacity outages is disseminated to the

market?

Prior knowledge of upstream fuel disruptions before

such information is disseminated to the market would

allow holders of such prior knowledge to buy electricity

futures before such information is disseminated,

knowing that the electricity futures prices would be

higher after such information is disseminated to the

market, thereby affording them the opportunity to then

sell the electricity futures and close out the position at a

profit. What measures will be used to detect and prevent

such cases of insider trading, including by proxies?

The Monetary Authority of Singapore (‘MAS’) is the regulator

in respect of the trading of financial derivative products

including electricity futures. MAS has affirmed that there is no

need to prohibit or regulate insider trading of all commodity-

based derivative products including electricity futures, in line

with international practices by regulators in major overseas

futures markets.

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2(a) Senoko Energy The proposal increases the disclosure of NEMS

information to non-NEMS participants to help “eliminate

the significant information asymmetry that currently

exists and may provide pro-competitive benefits to

futures market participants”. The Consultation Paper

does not explicitly consider or address the information

advantages that non-NEMS participants may hold over

others that participate in the futures market. For

example, gas-market players (both upstream and

midstream) hold price sensitive information that could

be traded-on prior to it being known by NEMS

participants. Senoko believes that it would be inherently

unbalanced for NEMS information to have a high degree

of transparency while other important information is not

required to be disclosed. This issue raises the question

of how “insider-trading” would be regulated (if at all) in

the futures market. We request regulatory guidance on

this matter prior to the commencement of the electricity

futures market.

The Monetary Authority of Singapore (‘MAS’) is the regulator

in respect of the trading of financial derivative products

including electricity futures. MAS has affirmed that there is no

need to prohibit or regulate insider trading of all commodity-

based derivative products including electricity futures, in line

with international practices by regulators in major overseas

futures markets.

2(b) Senoko Energy At a more technical level, the proposal entails gencos

providing provisional AGOPs so that the AGOP horizon

covers 3-years in total. While Senoko can provide

provisional plans for the 2 additional “out-years” we will

not be able to do so with the same level of accuracy as

the “next year” AGOP (due to difficulties in estimating

equivalent operating hours and scheduling contractors).

Therefore, we request that gencos be able to amend

their out-year plans without requiring prior PSO approval

(i.e., only notification is required).

Provisional AGOPs will be based on updates as provided by the

relevant parties and hence only indicative.

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2(c) Senoko Energy One of the arguments supporting the disclosure of offer

information is that it would enable interested parties to

conduct fundamental market modelling. Typically,

modelling relies on use of historic data sets, so we

suggest that EMA/EMC release a number of years of

historic offer data at the commencement of the trial

period. More fundamentally, to enable non-NEMS

participants to deeply understand the electricity price

formation process Senoko believes that it will be

necessary to make additional information available

regarding electricity and gas network capacities and

dynamics (with the necessary “anonymisations” for

physical security requirements).

The aggregated energy offer information to be made available

by EMC will cover 16 consecutive months of historical data.

3(a) SembCorp

Cogen

EMA has stated in Paragraph 1 of the Consultation Paper

that the objectives of the review on disclosure of market

information is to facilitate the efficient trading and risk

management for market participants :

(i) in the Singapore wholesale electricity market (i.e.

spot market); and

(ii) the electricity futures market.

The objective of the current review is not intended to

release additional information to the public.

The current disclosure of the ASA reports, AGOP, AEOP

and PGCS to only spot market participants is align with

the EMA’s first objective stated above.

The objective of EMA’s review is to enhance data transparency

which will in turn facilitate efficient trading and risk

management for participants in our electricity spot and futures

market. There is no commercial sensitivity or adverse impact

on market competition or national security if access to the ASA

reports, AGOP, AEOP and PGCS is extended to any person.

There is no reason to delay access by the person until he

becomes a spot or futures market participant as suggested by

Sembcorp Cogen. On the contrary, the person would require

such information to decide whether to participate in our spot

or futures market.

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We do not agree with the disclosure of the ASA reports,

AGOP, AEOP and PGCS to all data subscribers. To meet

the second objective of the EMA as stated in Paragraph 1

of the paper, the disclosure of the ASA reports, AGOP,

AEOP and shall be limited to only data subscribers who

are market participants in the Electricity Futures Market.

A market participant in the Electricity Futures Market

can be identified by demonstrating that it has a “live”

Trading Account with any of the Clearing Members of

SGX and with Initial Margin provided for the purpose of

trading the Electricity Futures product.

3(b) SembCorp

Cogen

There is insufficient evidence (i.e. it appears that we are

only relying on a feedback from SGX stated in Paragraph

12) in the consultation paper to show that the availability

of energy offer information will attract more players to

enter and create liquidity in the futures market.

In Paragraph 13, EMA has clearly stated that the

quantification of incremental benefits and costs of

releasing more data is still controversial in many

matured electricity market.

In the absence of any concrete evidence that availability

of energy offer will definitely create liquidity in the

futures market and no cost and benefit analysis to

support the release of more information, we propose to

remain status quo.

The aggregated energy offer information that EMC will make

available with a time-lag will enable external futures traders to

carry out fundamental modeling and value-at-risk assessments

in order to enter and trade in our futures market, making it

more liquid and efficient. The 4-week delay would be

adequate for short-term tight market conditions to normalise

and mitigate informational feedback for strategic bidding in

our spot market.

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With the non-availability of such information to

everyone in the wholesale and futures market, we

believe that level playing field is preserved.

3(c) SembCorp

Cogen

We would appreciate if the EMA could provide an

illustration of what will be provided. It is not clear from

Paragraph 16 how the information will be presented.

Refer to Appendix 2 for the template of the aggregated energy

offer information to be made available by EMC.

4(a) Keppel

Merlimau

Cogen

The consultation paper proposed that the availability of

information to enhance data transparency will facilitate

efficient trading and risk management for market

participants in the Singapore electricity wholesale and

futures market. Keppel seeks to clarify how an efficient

trading market will benefit the industry as a whole.

Firstly, depending on the characteristic of the derivative

product, the traded market may not provide the best risk

management tool for the market participant.

Furthermore, unlike the bigger and more mature

markets in the United States or Australia, the Singapore

market has limited market participants and consists of

mainly of gas fired power plants. The lack of participants

and alternatives makes the Singapore market susceptible

to the exercise of market power by bigger or more

privilege players.

Secondly, an efficient trading market does not necessary

benefit Singapore market participants, given the physical

constraint of the electricity network and limited

infrastructure interconnectivity of the gas network.

An electricity futures market will provide more options for

spot market participants and contestable consumers to

manage pool price risk. This would enhance competition in

both wholesale and retail electricity markets, especially if

independent electricity retailers can secure hedges in the

futures market to compete against incumbent retailers with

affiliated generation assets. The issues highlighted by Keppel

such as market power and physical network constraints, if they

exist, will be addressed specifically e.g. by increasing the

vesting contract level if there is market power concerns, and

building new network capacity to alleviate transmission

constraints. Such issues are not relevant to the introduction of

the electricity futures market to bring forth the above

mentioned benefits.

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Instead, it may give rise to speculation and market

volatility, caused by speculators who exploit the

inefficiency of the physical network. Hence, it is in the

industry’s interest to resolve the physical limitations of

the market before attempting to pursue trading

efficiency.

Lastly, it is in Keppel’s opinion that efficient trading

cannot occur given the constraints in the Singapore

electricity grid which enable certain market participants

to be entrenched in more favorable position to response

to price signal as compared those constrained by their

electricity dispatch.

The proposal to make available information to all data

subscribers is under the assumption that greater

information transparency would attract more players

hence creating liquidity in the electricity market. We

seek the EMA to provide further justification that the

provision of such information would indeed attract more

players to enter and create the necessarily liquidity,

bearing in mind that physical infrastructure inefficiency

will restrict the effectiveness of the trading market as a

risk management tool.

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4(b) Keppel

Merlimau

Cogen

Keppel disagrees with the disclosure of the same market

information, which is currently being provided to spot

market participants or Gencos only, to any data

subscriber. Keppel is concerned that the release of the

sensitive information such as system availability and gas

availability to the public may compromise system

security and have a negative effect on the market.

Release of commercially sensitive information i.e.

upstream seller’s gas curtailment information, would

subject the affected buyers to pay higher prices for

alternatives because the seller is aware of the buyer’s

shortage and will exploit this vulnerability.

This exploitation is exacerbated by the lack of gas

infrastructure which restricts the number of viable

alternative available to the affected party. The lack of

interconnection of the gas network isolates gas buyers

from potential gas seller who are located in separate

networks. The lack of interconnection in the Singapore

gas network creates an unequal access among the gas

buyers. Buyers with less access are subjected to greater

exploitation by sellers as compared to buyers with

greater accessibility. Unless there is an efficient

infrastructure to support physical trade enabling gas-on-

gas competition, critical information such as shortage of

gas will be always remain commercially-sensitive to all

gas buyers and sellers. Release of commercially sensitive

information would cause duress to affected parties, who

are not able to mitigate it through physical mean and

EMA does not think there is commercial sensitivity or adverse

impact on market competition or national security to publish

the ASA reports, AGOP, AEOP and PGCS.

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8 | P a g e

cause more harm to the market.

Keppel would like EMA to share with us its assessment

that there would be no commercial sensitivity, adverse

impact on market or national security if the suggested

information is extended to any data subscriber. Keppel

wishes to reiterate the confidentiality and commercially

sensitive nature of the information on individual

upstream gas seller’s curtailment, which EMA had

committed to keep confidential in the PGSC’s request.

Keppel would like to point out that the provision of the

upstream gas seller’s curtailment information for the

purpose of PGSC was intended for updating Gencos on

the overall gas supply situation so that they can step-up

their operational response. The respective gas importers

should be consulted and consent be given before such

information be utilizes for other purposes other than the

original intent.

4(c) Keppel

Merlimau

Cogen

Keppel does not agree with the publishing of aggregate

energy offer information.

We would like to point out that given the relative small

market and limited participants in the Singapore market,

aggregation of data does not necessary protect or ensure

confidentiality of the individual commercially sensitive

information. Keppel would like to point out that energy

offer information specific to each generating unit is the

operational intellectual property of the respective

The energy offer information to be made available by EMC is

aggregated i.e. it will not divulge the offers of individual

generating units. Furthermore, delaying the release by 4 weeks

would be adequate for short-term tight market conditions to

normalise and mitigate informational feedback for strategic

bidding in our spot market.

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Gencos, and should remain undisclosed to the other

participants.

The proposed 4-week time-lag data, though delayed, can

nevertheless be interpreted to gather the bidding

strategy of the individual players. Keppel would like to

seek greater clarity on the format of the aggregated

energy offer information before further commenting the

proposal.

Likewise to the point of lack of participants and

alternatives, Keppel is concerned that the release of

bidding information may also encourage the exercise of

market power in both the electricity spot market and the

futures market. Unless there are clearly defined rules on

anti-competitive behaviour, it is difficult for EMA to

ascertain whether certain bidding behaviour is anti-

competitive or due to operational needs.

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APPENDIX 2

Monthly ASA Report

Prepared on [date] at [time] 12 MONTHS ADEQUACY AND SECURITY ASSESSMENT REPORT

Page [no.] of 12

DATE

DEMAND FORECAST (MW) AVAILABLE

CAPACITY

(MW)

BASED ON FORECAST AVAILABLE CAPACITY OVERHAUL

CAPACITY

(MW) SYSTEM NORTHEAST NORTHWEST SOUTHEAST SOUTHWEST

PRIMARY

RESERVE

(MW)

SECONDARY

RESERVE

(MW)

CONTINGENCY

RESERVE

(MW)

REGULATION

(MW)

Month M+1 to M+12

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Daily ASA Report

Prepared on [date] at [time] 14 DAYS ADEQUACY AND SECURITY ASSESSMENT REPORT

Page [no.] of 14

DATE PERIOD

DEMAND FORECAST (MW) AVAILABLE

CAPACITY

(MW)

BASED ON FORECAST AVAILABLE CAPACITY OVERHAUL

CAPACITY

(MW) SYSTEM NORTHEAST NORTHWEST SOUTHEAST SOUTHWEST

PRIMARY

RESERVE

(MW)

SECONDARY

RESERVE

(MW)

CONTINGENCY

RESERVE

(MW)

REGULATION

(MW)

Day D+1 to D+14

TOTAL DAILY ENERGY FORECAST: [ ] MWh

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AGOP

[APPROVED / PROVISIONAL] ANNUAL OVERHAUL PROGRAM OF GENERATING UNITS FOR YEAR [Y / Y+1 / Y+2 / Y+3]

YEAR Y

GENERATING UNIT JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC GENERATING COMPANY 1

UNIT 1A

UNIT 1B

UNIT 1C

UNIT 1D

UNIT 1E

UNIT 1F

GENERATING COMPANY 2

UNIT 2A

UNIT 2B

UNIT 2C

UNIT 2D

P..

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AEOP

[FINAL / PROVISIONAL] ANNUAL EQUIPMENT OUTAGE PLAN FOR YEAR [Y / Y+1 / Y+2 / Y+3]

400KV CIRCUITS

S/No CIRCUITS OUTAGE PERIOD

COMPANY REMARKS FROM END

1 2 P

230KV CIRCUITS

S/No CIRCUITS OUTAGE PERIOD

COMPANY REMARKS FROM END

1

2

P

66KV CIRCUITS

S/No CIRCUITS OUTAGE PERIOD

COMPANY REMARKS FROM END

1

2

P

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400/230KV TRANSFORMER & 400KV SHUNT REACTORS

S/No TF & SR OUTAGE PERIOD

COMPANY REMARKS FROM END

1 P

230/66KV TRANSFORMER & 230KV SHUNT REACTORS

S/No TF & SR OUTAGE PERIOD

COMPANY REMARKS FROM END

1

2

P

66/22KV TRANSFORMER

S/No TF & SR OUTAGE PERIOD

COMPANY REMARKS FROM END

1 P

Page 2 of 9

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400KV SWITCHGEAR

S/No TF & SR OUTAGE PERIOD

COMPANY REMARKS FROM END

1 P

230KV SWITCHGEAR

S/No TF & SR OUTAGE PERIOD

COMPANY REMARKS FROM END

1 P

66KV SWITCHGEAR

S/No TF & SR OUTAGE PERIOD

COMPANY REMARKS FROM END

1

2

P

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PGCS

PROJECTED GAS CURTAILMENT SCHEDULE (1 JAN YYYY – 31 DEC YYYY) Updated on: dd/mm/yyyy hh:mm hrs

From To Total Amount of Upstream Gas Curtailment (i.e. Total Reduction in

Supply) [date] [time] [date] [time] [0-5% / 6-10% / 11-15% / P.]

P

While PSO/EMA has made every reasonable effort to reflect the most current and accurate information in the Projected Gas Curtailment Schedule at the time of publication, no guarantees

for the currency or accuracy of information are made. It should be noted that system conditions are dynamic and the information may change with little or no notice after the time of

publication. PSO/EMA shall not be liable for any claims or losses suffered as a result of the use of or reliance on the information given in the Projected Gas Curtailment Schedule.

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ENERGY OFFER STACK

TOTAL ENERGY OFFER CAPACITY FOR [Date D]

Date Period Lowest to Highest

Offer Price ($/MWh)

Total Offer Capacity At Specified Offer Price (MW)

D 1 D 1 D P D 1 D 1 D P D 2 D 2 D 2 D P D P D P D P D P D P D P D P D P D P D P D P D P D 48 D P D P


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