P448 ‘Mitigating Gas Supply Emergency Risks’
Formal title: Protecting Generators subject to Firm Load Shedding during a Gas Supply Emergency from excessive Imbalance Charges
The war in Ukraine and resultant gas shortages in Europe significantly increases the risk of Generators in GB being prevented from generating this winter (due to Firm Load Shedding during a Gas Supply Emergency). If that happens Generators are likely to incur massive Imbalance Charges and credit cover requirements, potentially causing them to become insolvent. Even if such an Emergency does not occur, the risk that it could occur is likely to force Generators to reduce their forward and Day Ahead trading, reducing liquidity in electricity markets, and raising costs for electricity consumers.
This Modification proposes to address these risks by allowing such Firm Load Shedding instructions to be settled as Bids. A new Panel Committee will validate the Bid Payments and Imbalance Charges after the event, to verify that Generators have been protected from Imbalance Charges caused by events outside their control, but have not profited from the arrangements.