Electricity Metering: The Search for Unification Continues

02.05.2025

An open discussion between representatives of energy companies to discuss a critical issue that arose as a result of discrepancies in the accounting of electricity volumes in the Market Management System (MMS) administered by NPC “Ukrenergo” was held by Energy Club on April 30.

The inconsistency in the accuracy of data used by NPC “Ukrenergo” as the Commercial Metering Administrator (CMA) and the Settlement Administrator (SA) creates significant difficulties for market participants in conducting their business activities and settlements.

Having received an official appeal from member company LLC “ENERGY 365”, Energy Club initiated a professional discussion to find effective solutions and ensure the stable and transparent functioning of the energy market, the need for which was expressed by 12 Club member companies.

The primary questions requiring urgent answers are NPC “Ukrenergo’s” position on the necessity of unifying metering processes and ways to resolve the problem, the role of the National Energy and Utilities Regulatory Commission (NEURC) in settling this issue, and overall steps needed to eliminate existing discrepancies and ensure transparent electricity metering.

Participants in the discussion included Yuriy Pidlisnyi, head of LLC “ENERGY 365”, and Olha Nedina, an expert on Guarantees of Origin for Electricity (GOE), the retail market, and verification of commercial electricity metering data from the Commerce Department of PrJSC “Ukrhydroenergo”.

Voicing the problem, the meeting moderator – Energy Club Vice President Valerii Bezus – noted that it has existed for almost two years with no clear prospect for resolution, specifically concerning the technical alignment between the functional blocks of the market management system.

As Yuriy Pidlisnyi emphasized, this is not the first discussion of the problem on the Energy Club platform, including with representatives of the National Regulator. The head of LLC “ENERGY 365” expressed hope that the business community’s opinion has been heard. “The implemented legislative changes are intended to solve the problem in the future but do not provide a clear understanding of what to do with the amounts accrued over the previous two years. There must be a basis for correcting discrepancies, but considering the legislation in force at that time, there is none. Consequently, the problem that arose two years ago remains, and it can only be resolved if NPC ‘Ukrenergo’ makes the appropriate changes to the settlement systems, especially since there is a NEURC decision,” said Yuriy Pidlisnyi.

Olha Nedina, the expert from PrJSC “Ukrhydroenergo’s” Commerce Department, identified several painful issues for energy market participants requiring coordination and offered proposals on the important issues raised during the discussion according to the set topic:

1. According to the Commercial Metering Code for Electricity, approved by NEURC Resolution No. 311 dated March 14, 2018, the Commercial Metering Administrator (hereinafter – CMA) ensures central aggregation and certification of commercial metering data and transmits certified commercial metering data to the Settlement Administrator (hereinafter – SA) and market participants in the volume necessary and sufficient for them to conduct settlements and issue invoices to their counterparties. Market participants and the SA use exclusively certified data on the volumes of generated, supplied, transmitted, distributed, withdrawn, consumed, imported, and exported electricity, obtained from the CMA and stored by it for each Commercial Metering Point (CMP). Since July 2024, the CMA began generating commercial metering data for PrJSC “Ukrhydroenergo” where electricity output/input volumes are specified in kWh with an accuracy of three decimal places (equivalent to six decimal places when converted to MWh). However, the SA calculates electricity imbalance volumes in MWh with an accuracy of only three decimal places. Due to this, PrJSC “Ukrhydroenergo” experiences an electricity balance disruption for settlement periods starting from July 2024, meaning the volumes of electricity supply/purchase do not match the volumes of sale/consumption. PrJSC “Ukrhydroenergo” has repeatedly appealed to the SA requesting a change in the rounding precision in MWh from three to six decimal places in calculations. In response, NPC “Ukrenergo” reported that the subject of rounding in the “Settlement” module of the Market Management System (hereinafter – MMS) includes, among other things, commercial metering data and activation command data for each energy account, and that rounding is carried out according to the Instruction on Rounding in Balancing Market Settlements (hereinafter – Instruction), published on the official website of NPC “Ukrenergo”. According to the Instruction, the volume of electricity is expressed in MWh according to mathematical rounding rules with an accuracy of three decimal places. However, it does not specify how the rounding of commercial metering data regarding electricity input/output is performed (per CMP, per resource object, total for all objects of a market participant) and at what stage netting occurs (before or after rounding). Thus, PrJSC “Ukrhydroenergo” cannot verify the accuracy of the imbalance volume calculation and form its own electricity balance. Proposal: When conducting settlements, change the rounding precision in the Instruction from three decimal places in MWh to six decimal places and recalculate past periods, or detail step-by-step the rounding process for commercial metering data generated in kWh with up to 3 decimal places, in order to bring the data to a whole number.
2. The electricity market consists of three main components:
   • Electricity generation-consumption;
   • Electricity sale-purchase;
   • Commercial electricity metering – the component that allows confirmation of the facts and volumes of electricity purchase and sale. According to the Commercial Metering Code, approved by NEURC Resolution (hereinafter – CMC), electricity metering must be organized so that, in addition to the main metering points owned by the responsible party whose meter data is transmitted and displayed in the Datahub, verification nodes must also be installed by the adjacent market participant. Furthermore, all elements of these nodes must comply with all CMC requirements. Today, under conditions of constant shelling of the energy system and certain risks to installed main electricity metering points, these requirements are particularly relevant. Moreover, properly equipped verification electricity metering nodes facilitate the reconciliation of commercial electricity metering data between adjacent market participants and prevent conflicts on this basis. Proposal: We ask esteemed adjacent market participants to pay more attention to equipping verification electricity metering nodes. In particular, adhere to the specified equipment accuracy classes and do not miss verifications.
3. PrJSC “Ukrhydroenergo” has a rather extensive structure. As of today, the Company comprises 9 stations, consequently, 16 commercial boundaries with 10 adjacent market participants. The performance of commercial metering service provider (hereinafter – CMSP) functions for the Company with such an extensive structure was entrusted to an independent CMSP, which is a respected professional company whose main business activity is precisely the provision of commercial metering services. However, today, the following situation is observed in the field of commercial metering. To strengthen control over the registers of commercial metering points (hereinafter – CMPs), the number of those with access to these registers was artificially limited. All independent CMSPs were excluded from the circle of authorized entities, leaving only system operators as CMSPs with the function of Administrator of Commercial Metering Points (hereinafter ACMP). Thus, in our case, instead of having one reliable independent CMSP operate all CMPs of the extensive structure, the ACMP function is dispersed among a significant number of adjacent system operators, not all of whom are sufficiently professional in this area. To illustrate the problem, I will provide a specific example. According to the Laws of Ukraine “On the Electricity Market” and “On Alternative Energy Sources”, a market for guarantees of origin for electricity produced from renewable energy sources (hereinafter – GOE) was introduced in Ukraine in 2024. Starting from August 2024, the process of creating registry accounts in the Guarantees Register on the G-REX platform by the Regulator was supposed to begin. Data regarding producers of clean energy were to be entered into the Register directly from the Datahub based on generation sites modeled by system operators acting as ACMPs. The result of the system operators’ work was that, as of mid-July 2024, due to errors made during modeling, only 4 (four) stations of the Company were included in the Register. We initiated active work to correct these errors in the Datahub and encountered situations where system operator specialists assigned to perform such work simply did not know what needed to be done in each specific case to eliminate the error. And one can understand them. The matter is new for everyone. And, frankly speaking, it is not the core activity of a system operator. Unlike independent CMSPs. Proposal: Today, in the Ukrainian electricity market, there are not that many highly qualified independent CMSPs whose main activity is commercial metering, who have many years of experience in this field and a reputation as reliable and professional CMSPs. Considering the aforementioned, we deem it appropriate to grant the ACMP function and full rights for its execution to at least a few highly qualified independent commercial metering service providers, selected through the strictest selection process.
4. While the Commercial Metering Code requires hourly electricity metering in the wholesale electricity market of Ukraine, there is no such requirement in the retail market. The settlement period in the retail market for household consumers is one month. In organized market segments, the price of electricity is formed hourly. At the same time, for a household consumer, it remains practically the same throughout the settlement month. If hourly electricity metering existed for household consumers, and the price changed hourly depending on the market price, this would undoubtedly encourage consumers to consume electricity much more responsibly and would contribute to reducing peak loads in the system. Proposal: Consider the issue of finding mechanisms to achieve hourly electricity metering for everyone in Ukraine.

Energy Club’s constructive position is to discuss current problems in a professional field and provide market participants with the opportunity to receive feedback from the regulator and ultimately make decisions that will contribute to the development of the energy market.

Therefore, to resolve the aforementioned problem that was the topic of the meeting, Energy Club will turn to lawyers, with whose help an appeal will be prepared to the relevant authorities.