ACER recommendations to the Network Code on Requirements for Generators – EUTurbines Comments

13 March 2024

EUTurbines welcomes the recommendations proposed by ACER on the Network Code Requirements for Generators (NC RfG), which brings forth significant improvements in terms of harmonising and future-proofing the grid connection requirements at EU level.
Notwithstanding, manufacturers encounter challenges due to the inconsistent and unclear requirements, coupled with the lack of a practical perspective in the NC RfG text. This results in heightened complexities when testing turbine capabilities.
As the association representing manufacturers of turbine-based gas and steam power plants in the EU, EUTurbines has historically offered valuable technical and practical insights for the revision of the NC RfG. We would like to highlight several issues that could impede the establishment of a level playing field among various manufacturers and technologies.

Our Recommendations
1. Reinstate the original definition of “Power-generating facility”
2. Update the definition of “Synchronous compensation operation”
3. Extend the adaptation period for new generating plants contracts
4. Ensure appropriate system availability to maintain present frequency limits
5. Considering trade-offs in response-times to LFSM-O events
6. Clear definition for LFSM-O closed loop control functionality
7. More inclusive drafting process for Implementation Guidance Documents

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