AGEP - Report On ASEAN Grid Code Comparison Review, 2018

REPORT ON
ASEAN GRID CODE

COMPARISON REVIEW
REPORT ON ASEAN GRID CODE
COMPARISON REVIEW
Report on ASEAN Grid Code Comparison Review
Editors:
• ASEAN Centre for Energy (ACE)
• Deutsche Gesellschaft für Internationale Zusammenarbeit (GIZ) GmbH
• Dr. Thomas Ackermann, Dr. Eckehard Troester and Peter-Philipp Schierhorn,
Energynautics GmbH
Published by:
ASEAN Centre for Energy (ACE)
Deutsche Gesellschaft für Internationale Zusammenarbeit (GIZ) GmbH
ACE Building, 6th floor

Complex Directorate General of Electricity
Jl. HR. Rasuna Said kav.7-8 Jakarta, Indonesia
Tel: (62-21) 527 8027 | Fax: (62-21) 529 6382
www.agep.aseanenergy.org
www.facebook.com/sustainableenergyforasean
October 2018
4
ACKNOWLEDGMENT
The Report on ASEAN Grid Code Comparison Review was prepared under the overall guidance of
Ir. Dr. Sanjayan Velautham, Executive Director of ACE and Maria-José Poddey, Principal Advisor for AGEP,
GIZ. The Report development was managed by Rizky Fauzianto (GIZ), Muhammad Shiddiq (ACE) and Melati
Wulandari (GIZ).
The Report was developed with the assistance of Dr. Thomas Ackermann, Dr. Eckehard Troester, and Peter-
Philipp Schierhorn (Energynautics GmbH) as the consultant.
Valuable feedback was also provided by ACE colleagues Badariah Yosiana, Septia Buntara and GIZ
colleagues Rizky Fauzianto and Intan Cinditiara.
The report has benefited from input by representatives from power utilities and regulatory bodies in six
ASEAN Member States, i.e. Cambodia, Lao PDR, Malaysia, Singapore, Thailand, and Vietnam participated
in The Second ASEAN Regional Renewable Energy Grid Integration Training held on 13-15 August 2018 in
Bangkok. This training is the follow-up from the first training held in Jakarta on 20-21 March 2018 and also
will be continued with the third training which is planned to be held in Kuala Lumpur on February 2019. Their
comments and suggestions were of great value and have helped shape the final report.
Special thanks and appreciation are extended to the Head of ASEAN Power Utilities/Authorities (HAPUA),
PT. Perusahaan Listrik Negara (PLN) Persero, Tenaga Nasional Berhad (TNB), Electricity Generating Authority
of Thailand (EGAT), Metropolitan Electricity Authority (MEA) and Provincial Electricity Authority (PEA).
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DISCLAIMER
The Report on ASEAN Grid Code Comparison Review was prepared by the ASEAN Centre for Energy
(ACE) and Deutsche Gesellschaft für Internationale Zusammenarbeit (GIZ) GmbH with technical assistance
from Energynautics GmbH, as international consultant, with the support of the German Federal Ministry for
Economic Cooperation and Development (BMZ) through the ASEAN-German Energy Programme (AGEP).
The material featured in this publication is provided “as is.”
All reasonable precautions have been taken by ACE and GIZ to verify the reliability of the material featured
in this publication. Neither ACE nor any of its officials, agents, data or other third-party content providers or
licensors provide any warranty, including the accuracy, completeness or fitness for a particular purpose or
use of such material. As to the non-infringement of third-party rights, they accept no responsibility or liability
with regard to the use of this publication and the material featured therein. The ASEAN Member States
(AMS) or the individuals and institutions that contributed to this report are not responsible for any opinions or
judgements the report contains.
The information contained herein does not necessarily represent the views, opinions or judgements of the
AMS or of the individuals and institutions which contributed to this report. Nor is it an endorsement of any
project, product or service provider. The designations employed and the presentation of material herein
do not imply the expression of any opinion on the part of ACE nor GIZ concerning the legal status of any
region, country, territory, city or area or of its authorities. Nor do they concern the delimitation of frontiers or
boundaries.
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FOREWORD
Endorsed by the Joint Ministerial Statement of the 35th ASEAN Ministers on Energy Meeting (AMEM) held
in Pasay City, the Philippines in September 2017, the ASEAN Member States (AMS) have shown their
commitment on advancing the energy transition in ASEAN towards a secure, accessible, affordable and
sustainable energy future. To accelerate the transition, the AMS endeavour to reduce energy intensity and
increase the deployment of renewable energy (RE). For that purpose, the AMS move forward with the ASEAN
Plan of Action for Energy Cooperation (APAEC) 2016–2025 that sets a target to increase the RE component
to 23% by 2025 in the ASEAN total primary energy supply (TPES) and to initiate a multilateral electricity trade
in at least one sub-region by 2018. For ASEAN to achieve the targets, the share of RE in power generation
should reach around 42%, according to the 5th ASEAN Energy Outlook.
To meet the APAEC targets and the growing electricity demand, ASEAN initiated a regional electricity
interconnecting arrangement through the ASEAN Power Grid (APG) project under the ASEAN Vision
2020. The project is carried out by Heads of ASEAN Power Utilities/Authorities (HAPUA) as one of ASEAN
Specialised Energy Bodies (SEB). The region believes that an ASEAN-wide aspirational RE target and the
integration of energy infrastructure can assist to boost the energy market in AMS.
To support this action plan and to counter-measure the challenges of grid-connected RE technologies, the
ASEAN-German Energy Programme (AGEP)—a jointly implemented project by ASEAN Centre for Energy
(ACE) and Deutsche Gesellschaft für Internationale Zusammenarbeit (GIZ) GmbH on behalf of the Federal
Ministry for Economic Cooperation and Development (BMZ)—published a report that reviews market,
regulations, standards and procedures to conduct a safe and reliable operation of grid integration in ASEAN,
especially Indonesia, Malaysia, Thailand. The report features comparison of the three Member States’ grid
codes with international standards, as well as captures important aspects of grid code and provides key
recommendations towards the implementation of a regional grid code. The recommendation could provide
a consistent regional framework for system planning, transmission connections and operational rules to be
followed by grid users and other stakeholders.
ACE and GIZ hope that the Report on ASEAN Grid Code Comparison Review would be useful as reference
to all stakeholders, especially the policymakers, independent power producers, utilities, and grid operators in
understanding the power system in ASEAN. We believe that such reference could support the establishment
of an ASEAN multilateral electricity trade, as envisioned by the APG project.
Maria-José Poddey Dr. Sanjayan Velautham

Principle Advisor for AGEP Executive Director
GIZ ASEAN Centre for Energy
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TABLE OF CONTENTS
Acknowledgment........................................................................................................................................................ 5
Disclaimer .................................................................................................................................................................. 6
Foreword .................................................................................................................................................................. 5
List of Abbreviations.................................................................................................................................................. 9
List of Measurement................................................................................................................................................ 10
1. Introduction........................................................................................................................................................ 12
1.1 Background and Objective............................................................................................................................... 12
1.2 Introduction to Grid Codes............................................................................................................................... 12
1.3 Relationship Between Grid Codes, Policy and Project Development.......................................................... 13
2. Grid Codes and Interconnection International Standards............................................................................. 16

2.1 EU Network Codes............................................................................................................................................. 16
2.2 Other International Harmonisation Efforts...................................................................................................... 17
3. Grid Codes and Interconnection Standards in the ASEAN............................................................................ 20

3.1 Indonesia............................................................................................................................................................ 23
3.1.1 Power Markets.......................................................................................................................................... 23
3.1.2 Applicable Grid Code Documents.......................................................................................................... 23
3.1.3 Grid Code Development........................................................................................................................... 24
3.1.4 Requirements for Generators.................................................................................................................. 24
3.1.5 Connection Process................................................................................................................................. 25
3.1.6 Compliance Mechanisms......................................................................................................................... 26
3.2 Malaysia.............................................................................................................................................................. 27
3.2.1 Power Markets.......................................................................................................................................... 27
3.3 Thailand.............................................................................................................................................................. 35
3.3.1 Power Markets.......................................................................................................................................... 35
3.4 Comparison between the Grid Codes of Indonesia, Malaysia, Thailand, and International Good Practice........ 41
4. Recommendations............................................................................................................................................. 46
4.1 Indonesia............................................................................................................................................................ 46
4.2 Malaysia.............................................................................................................................................................. 46
4.3 Thailand.............................................................................................................................................................. 47
4.4 International / ASEAN........................................................................................................................................ 48
References ................................................................................................................................................................ 49
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LIST OF ABBREVIATIONS
AC Alternating Current
ACE ASEAN Centre for Energy
ACER Agency for the Cooperation of Energy Regulators
AGC Automatic Generation Control
AGEP ASEAN-German Energy Programme
AMS ASEAN Member States
ASEAN Association of Southeast Asian Nations
APAEC ASEAN Plan of Action for Energy Cooperation
AVR Automatic Voltage Regulator
CCGT Closed-Cycle Gas Turbine
CRIE Comisión Régional de Interconexión Eléctrica
DC Direct Current
DSO Distribution System Operator
DT Distribution Transformer
EGAT Electricity Generation Authority of Thailand
ENTSO-E European Network of Transmission System Operators for Electricity
ENTSO-G European Network of Transmission System Operators for Gas
ERC Energy Regulatory Commission (Thailand)
EU European Union
EWEA European Wind Energy Association
FIT Feed-in tariff
FRT Fault Ride-Through
GIZ Deutsche Gesellschaft für Internationale Zusammenarbeit / German International Cooperation
GSO Grid System Operator
HV High Voltage (> 50 kV)
IDNO Independent Distribution Network Operators
IPP Independent Power Producer
LFSM-O Limited Frequency Sensitive Mode for Overfrequency
LV Low Voltage (< 1 kV)
LVRT Low Voltage Ride-Through
MEA Metropolitan Electricity Authority (Thailand)
MPE Moeller-Poeller Engineering
MV Medium voltage (1 – 50 kV)
NEDA New Enhanced Dispatch Arrangement
NORDEL Association of Nordic Electric System Operators
PEA Provincial Electricity Authority (Thailand)
PLN Indonesian State-Owned Power Utility (Perusahaan Listrik Negara)
PPA Power Purchase Agreements
PSS Power System Study
PV Photovoltaics
RE Renewable Energy
REGP Renewable Energy Generation Plants
RMER Regulations for the Central American regional market (Regulación del Mercado Eléctrico
Regional)
RNO Regional Network Operators
RSO Regional System Operators
SCADA Supervisory Control and Data Acquisition
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SEB Sarawak Energy Berhad, vertically integrated utility of Sarawak (Malaysia)
SESB Sabah Electricity Sdn. Bhd., vertically integrated utility of Sabah/Labuan (Malaysia)
SPP Small Power Producer
TNB Tenaga Nasional Berhad, vertically integrated utility of the Malay Peninsula (Malaysia)
TPES Total Primary Energy Supply
TSO Transmission System Operator
UNITEN University Tenaga Nasional (Engineering university of Malaysia)
VRE Variable Renewable Energy
VSPP Very Small Power Producer
LIST OF MEASUREMENT
GW Giga Watt
Hz Hertz
kV Kilo Volt
kW Kilo Watt
LV Low Voltage
Ms Millisecond
MW Mega Watt
PU Per Unit (Nominal Voltage)
V Volt
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1. INTRODUCTION
1.1 Background and Objective

A key recommendation in this report is the setting up of a Grid Code recommendation towards a regional grid
code, which though nonbinding will provide a consistent regional framework for system planning, transmission
connections, and operational rules to be followed by grid users and other stakeholders. Keeping in view the
technical complexity, this study also underlines the need of a regional institution to facilitate the co-ordination of
system planning and implementation.
The electric power system is a large, complex system involving many entities executing their respective activities
and responsibilities. With multi-stakeholders perspective such as the generation, transmission, and distribution
licensees, system operators, traders, and other participants in the system, the stakeholders should function
in proper co-ordination with each other; they should follow the regulations, standards, and procedures for
the safe and reliable operation of the grid. Grid codes provide basic design criteria and operational rules and
responsibilities to be followed by the generating stations, transmission utilities, and distribution utilities.
There are many rules and criteria in every grid code which deal with generation, transmission, distribution,
protection, metering, maintenance, buying and selling of power, ancillary services, etc. Grid Code documents
of varying countries depends on the past practices of its respective electricity sector, the present hierarchical
structure of its electricity sector, energy sources available, and its legal, technical, and commercial aspects
etc. With cross-border power trade there is expectation to increase and thereby additional cross-border power
transmission system interconnections are expected to be built. It is of paramount importance that the power grids
of each AMS are integrated through a harmonised/co-ordinated effort of grid codes for smooth, optimal, secure,
and reliable power system operations.
Based on detailed analyses, some grid code recommendations have been developed which provide basic criteria
for system planning, connection, and operational rules and responsibilities to be followed by the generating
stations, transmission utilities, and distribution utilities, while simultaneously keeping in view international
experience and considering the technical complexity involved with respect to grid code harmonisation and
integrated planning and operation of a regional power systems in ASEAN.
1.2 Introduction to Grid Codes

Grid codes are regulatory documents governing power system operations and the involved stakeholders.
Internal documents and bilateral agreements between different parties dealing with these issues have been in
existence probably since the first electrical power system started operating. However, grid codes consolidating
all necessary requirements in a transparent form were first developed with the unbundling of power systems
in Europe in the late 1990s. While in traditional power systems, generators, grid and other infrastructure were
typically owned and operated by the same utility company – a structure that is still prevalent in many parts of
the world – an open energy market with multiple active entities requires clear and transparent guidelines and
communication between the stakeholders.
The term “grid code” itself is rather generic, and the definition may vary from country to country and from
operator to operator. A grid code can be comprise of different sub-codes, such as a (generator and/or demand)
connection code, an operating code, a planning code, or even further regulations such as market and balancing
codes. In the following, the term shall refer to the documents guiding connection of loads and generators, system
operations, and planning. Grid codes may exist for both the transmission system and the distribution system, or
even for each voltage level individually (Germany, for example, has individual codes for the 0.4 kV low voltage
grids, the 10/20 kV medium voltage grids, the 110 kV sub-transmission level, and the 220/380 kV transmission
grids). [1][2][3]
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Grid codes are typically developed under the lead of the grid or system operator, but as they directly impact the
operations of all stakeholders in the system it is an international good practice to form a stakeholder committee
that becomes involved in the development. System stakeholders, besides the system operator, may include
generator owners/operators, load customers (especially large ones, such as the Distribution System Operators
or DSOs in the transmission system), other operators (such as the Transmission System Operators or TSOs/
system operators in case of a distribution grid code1), generator manufacturers, and government agencies
(especially the regulator).
A first grid code draft is in most cases developed by an internal group of the TSO or DSO, or a consultant hired by
the respective operator. This is then presented to stakeholder committees and revised in multiple rounds. In most
cases, approval from the regulatory agency is necessary as a last step before the grid code can enter into force.
Grid codes are living documents due to the fact that the techno-economic landscape is constantly changing and
developing. It is important to note here that grid codes are typically only applicable to generators (as well as
some other facilities) connected to the system after the document has entered into force, but not retroactively,
and the same is true for any updates.2 Grid codes need to look ahead and include potential future developments,
but will also have to be constantly revised and updated as real life circumstances can develop very different to
the forecast. It is advisable to have meetings at least annually of the stakeholder committee where the necessity
for updates and revisions can be decided. [4]
1.3 Relationship Between Grid Codes, Policy and Project Development

As grid code documents govern the relationship between different power system stakeholders, these entities’
operations are directly affected:
• The grid/system operator must ensure that other stakeholders cannot compromise secure and stable
system operations;
• The government, often in the form of the regulatory agency, needs to set up regulations for sustainability
and efficiency of the power sector (this includes targets for renewable energy and the corresponding
incentives);
• Generator owners and operators have the primary interest of producing and selling power with a profit
margin, either to a single buyer (utility) or on a free electricity market.
The grid code needs to carefully balance these interests. Requirements for generators need to be strict enough
to ensure operational security at all times at future points in time and thus need to consider planned and expected
development, including renewable energy targets. However, overly strict requirements may, depending on the
electricity market structure, lead to either high electricity prices and inefficient system operation as each technical
requirement incurs additional cost, or to a lack of investments. The latter may result in either a capacity shortage or,
in the case of renewable energy, simply in governmental renewable energy targets not being reached.
As compliance with technical requirements that are necessary for system stability is not a primary interest of the
generator owner, operator, or project developer, the system operator needs to be equipped with the adequate
compliance mechanisms to enforce the requirements. These can include the following:
• Requirement for a project developer to deliver documents to the system operator during the planning
stage (before the final connection grant) of the project that prove or indicate grid code compliance of the
planned equipment;
• Requirement to deliver third party certification (national or international) that proves compliance with
requirements before commissioning of the generating unit;
• Requirement to deliver validated simulation models at some stage of the connection process;
1
As the behaviour of generators in the distribution grid impacts system stability, which is the responsibility of the TSO, TSO involvement in distribution code
development is especially important.
2
As a rule of thumb, it is usually cheaper overall to request technical capabilities that may be relevant in the future from new assets, than to retrofit existing assets
once a problem appears.
13
• Requirement for compliance tests during commissioning – these can either be conducted or supervised
by the system operator staff, or conducted by the generator operator alone, and in the latter case
documentation needs to be delivered to the system operator;
• Right of the system operator to refuse or postpone connection if the unit cannot prove compliance, and
right to disconnect an already commissioned unit if the operator can prove non-compliance.
Describing compliance mechanisms in the grid code itself is necessary, but not sufficient, as the system operator
must have a legal basis to enforce the code. A lack of compliance mechanisms leads to an unenforceable and
thus worthless grid code. [4]
Credit: GIZ
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2. GRID CODES AND INTERCONNECTION
INTERNATIONAL STANDARDS
2.1 EU Network Codes

ENTSO-E, The European Network of Transmission System Operators for Electricity (there is also an ENTSO-G
for the natural gas network), describe the EU Network Codes as follows:
Network codes are a set of rules drafted by ENTSO-E, with guidance from the Agency for the Cooperation
of Energy Regulators (ACER), to facilitate the harmonisation, integration and efficiency of the European
electricity market. Each network code is an integral part of the drive towards completion of the internal
energy market, and achieving the European Union’s 20-20-20 energy objectives of:
• at least a 40 percent cut in greenhouse gas emissions compared to 1990 levels.
• at least a 27 percent share of renewable energy consumption.
• at least a 27 percent energy savings compared with the business-as-usual scenario.3
The EU Network Codes have been under development for several years. They are the first large scale attempt
at harmonising international grid codes, with the target of ensuring a coherent regulatory framework for power
system operations in all EU member countries. As of 2018, all eight codes have entered into force and have
been signed by the EU Commission into European law (see Figure 1).
The code families
Connection Operations Market

Demand Connection Code • Emergency and Restoration • Capacity Allocation & Conges-
High Voltage Direct Current System Operations • tion Management •
Connections • Forward Capacity Allocation •
Requirements for Generators • Electricity Balancing •
Entered into force Awaiting entry into force
Figure 1:
EU Network Codes. 4
The EU Network Codes are neither a regional nor international grid code. All EU member countries retain their
own grid codes but must harmonise them with the EU Network Codes within three years of implementation.
The Codes themselves are a framework that defines the structure and content of grid code documents and
the rights and responsibilities of stakeholders (which have been subject to European law since 1998). The
Connection and Operations code groups (see Figure 1) mostly specify the “what”, but not the “how” – it is,
for example, clearly defined which requirements for generators have to be included in the grid code, but
specific technical parameters are still the responsibility of each individual TSO. Guidelines on parameters and
collections of (current) parameters and values of specific requirements in different countries are included in
the Codes.
The Codes also directly govern issues that require inter-TSO cooperation, such as frequency control,
contingency events, and allocation of interconnector capacity, but even here the structures, communication
pathways, and necessary bilateral agreements are defined, but the final execution is up to the individual
member country and their TSO. [5]
3
https://electricity.network-codes.eu/network_codes/
4
Source: https://electricity.network-codes.eu/network_codes/
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2.2 Other International Harmonisation Efforts

As mentioned in the previous section, the EU Network Codes are the first large scale effort to harmonise
international grid codes. However, harmonisation has been an issue for a number of years, and there are
several international grid code documents:
• The Association of Nordic Electric System Operators (NORDEL), comprising Denmark, Finland,
Norway, and Sweden, published the Nordic Grid Code in 2007. It is subtitled “Nordic collection of
rules” and is basically a document that compiles, summarizes and compares the grid codes applicable
in Sweden, Norway, Finland and the eastern part of Denmark (which is synchronized with the Nordic
system, while the west is connected to the Central European system).[6]
• The Central American interconnected system operates under common market and balancing rules
(Regulación del Mercado Eléctrico Regional, RMER) set by the Comisión Régional de Interconexión
Eléctrica, or CRIE, an international body that governs and regulates power system operations in the
region (similar to ACER in Europe). The RMER also contain technical criteria that directly impact grid
code requirements in the member countries.
• The European Wind Power Association, formerly the European Wind Energy Association (EWEA),
published a generic grid code document in 2009 which attempted to define the scope of a grid code
for wind power. EWEA has subsequently also been involved in the development of the EU Network
Codes, which follow a similar approach. [7]
Harmonisation efforts in other parts of the world are just starting out. Particularly for smaller countries,
harmonised development can be beneficial for several reasons. Bundling of resources allows for faster
learning and reduces the cost imposed by the code development process of each individual country, while
similar requirements in several countries offset the low individual market power and can more easily force new
developments on the manufacturers’ side.5 [4]
Credit: Powergrid Asia/GIZ

5
Example: If a new requirement is introduced in a large market, manufacturers will try to quickly offer the capability at a competitive price. For a smaller market, they
may instead choose to simply withdraw as the additional income does not recover development costs.
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3. GRID CODES AND INTERCONNECTION
STANDARDS IN THE ASEAN
There is no regional/international grid code in the ASEAN region. Each ASEAN member state and power utility
develops grid codes and interconnection standards within their domain. Based on a desktop research, as of
April 2015, seven member-states of ASEAN (Cambodia, Indonesia, Malaysia, the Philippines, Singapore,
Thailand, and Vietnam) have already developed grid codes and/or interconnection standards so far.
This does not mean that Brunei Darussalam, Lao PDR, and Myanmar do not possess any technical
requirements for connecting power plants to their power network. However, for these countries, codes
or standards that govern the grid connection issue have not been published. Based on interviews and
discussions, the information that such documents exist as internal documents and are used on a case-by-case
basis for bilateral negotiations between utility and applicants for connection.
Credit: GIZ/Dirk Ostermeier
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Table 1:
List of transmission codes, distribution codes, and interconnection standards / guidelines in the ASEAN region
(as of August 2018)
Grid Codes Notes
Country Interconnection Guidelines/
Transmission Code Distribution Code
Standards
Cambodia  Cambodia Grid -  General Conditions for -
Code (2009) Connecting Solar Generation
Sources (2018)
Indonesia  Ja-Ma-Li Grid  Distribution  PLN’s Interconnection  Ja-Ma-Li: Jawa-Madura-
Code (2007) Code Guideline for RE Bali
 Sumatera Grid  PLN; state-owned power

Code (2008) utility
 Sulawesi Grid
Code (2008)
Malaysia  Malaysian Grid  Malaysian Peninsular Malaysia, Sabah &  Malaysian Grid Code is
Code (2013) Distribution Labuan applicable to Peninsular
Code (2012)  Technical Guidebook on Malaysia only
 Sabah Grid Code Grid-Interconnection of PV
(2011)  Electricity power generation to LV & MV  Sabah Grid Code is
Ordinance networks applicable for Sabah &
 Electricity (2007) Labuan
Ordinance  Technical Guidebook for the
(2007)3 Connection of Generation to  Under Law of Sarawak
the Distribution Network Chapter 50 - Electricity
Ordinance Section 36 -
 Renewable Energy (Technical Two rules are gazette:
& Operational Requirements) - Electricity Rules
Rules 2011 + 2014 (1999)
Amendment - Electricity (State Grid
Code) Rules (2003)
 Guidelines on Large Scale
Solar Photovoltaic Plant For  Malaysian Distribution
Connection to Electricity Code is applicable to
Networks Peninsular Malaysia,
Sabah & Labuan.
Sarawak Malaysian Distribution
 Distributed Generation Code limits DG connection
Interconnection Guidebook to 30 MW and connection
version 1.02 to distribution network only
 Subsidiary of Renewable
Energy Act, 2011
Philippines  Grid Code (2007)  Distribution  Interconnection Standard -
Code (2011) for Micro-Scale Generation
 VRE Grid (<100 kW) (2013)
Code (as an
addendum; 2013)
Singapore  Transmission - - -
Code (2017)
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Grid Codes Notes
Country Interconnection Guidelines/
Transmission Code Distribution Code
Standards
Thailand  EGAT’s IPP Code  PEA’s  ERC Solar Rooftop  EGAT: Electricity
(> 90 MW) Interconnection Regulation (with technical Generation Authority
Code requirements from PEA and Thailand, state-owned
 EGAT’s SPP MEA as appendix; 2013) power utility (generation
Connection Code  MEA’s and transmission)
(10-90 MW) Interconnection
Code  IPP: Independent Power
Producer (>90 MW)
 ERC: Energy Regulatory

Commission, energy
regulator
 MEA: Metropolitan
Electricity Authority,
state-owned power utility
(distribution)
 PEA: Provincial Electricity

Authority, state-owned
power utility distribution
 SPP: Small Power

Producer (10-90 MW)
 VSPP: Very Small Power

Producer (<10 MW)
Vietnam  Grid Code (2016)  Distribution  Technical Manual for -
Code (2010) Interconnecting Wind Power
to Vietnam Power System
Due to limited data and resources, translations of grid code documents from Malaysia, Thailand, and Indonesia
were analysed in the following sections. Additional data was collected via literary research on and offline.
The PV connection rules for Cambodia and the transmission code of Singapore were also provided in the
English language, but were not analysed in detail. The following high level assessments can be made from a
quick scanning of both documents:
• The PV connection requirements for Cambodia were very rudimentary, and prescribed a focus on self-
consumption of (industrial) consumers installing PV systems. The technical requirements for power
quality are up to the standards of international good practice, and the code contains an extensive (2
seconds) LVRT requirement which is lacking from most other codes in the region. It is however not a
comprehensive document providing an adequate guideline for large scale PV integration.
• The Singaporean transmission code is structurally up to the standards of international good practice, but
it is very focused on operational procedures and the communication between the utility and stakeholders.
Technical requirements for generators are explicitly up to bilateral agreements between utility and
generator owner/IPP. This is adequate for the connection of large conventional units, and considering
the small size of the country, also in case of the connection of few large renewable units. However, this
procedure makes requirements non-transparent and may thus reduce investor interest. If an increase in
renewable generation is planned, requirements for such generators should be published.
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3.1 Indonesia
3.1.1 Power Markets

The Indonesian power system is vertically integrated, with the Indonesian state-owned utility company
Perusahaan Listrik Negara (PLN) owning and operating transmission and distribution grids as well as the
majority of generation. Privately owned generation (Independent Power Producers, IPP) is allowed, and tariffs
are set by the Power Purchase Agreements (PPA) between PLN and the respective IPP, but these are subject
to regulation. For the IPPs, PLN acts as a single buyer. Capacities for IPP generation are usually set by PLN
and appointed through competitive tenders. PLN currently owns 41 GW of generating capacity, with another
14 GW being IPP owned. Furthermore, there is a considerable amount of captive (industrial) generation
capacity that is usually not connected to the public grid.
Indonesia is split up into several synchronous systems due to its topology as an island state. PLN is in charge
of the dispatch schedules for power plants and is required to determine the least cost dispatch for each grid.
There is no power market. Consumer prices are heavily regulated by the government.
Under the Electricity Law No. 30/2009, the electricity tariffs in Indonesia differs between each operating area
and there is no longer any uniform tariff throughout Indonesia. The tariffs are also set by customer’s needs
and the available installed power capacity. These different tariffs are also the result of different subsidy
arrangements.
3.1.2 Applicable Grid Code Documents

PLN published three different grid code documents for its main grids in 2007 and 2008, applicable to the
transmission systems of Java-Madura-Bali, Sumatera, and Sulawesi. It is notable that there seem to be no
grid codes governing the grids on Kalimantan and Papua (rural states which are fractured into many small
systems) and the smaller Indonesian islands.
There is an additional connection code for Renewable Energy Generation Plants (REGP), Guidelines for
Connecting Renewable Energy Generation Plants to PLN’s Distribution System code, which is applicable
to RE installations with an installed capacity of less than 10 MW connected to the distribution grid in all of
Indonesia. This document was published by PLN in 2014. This is an additional document to the Indonesian
Electric Distribution Code from 2009, which specifies technical rules for the distribution grids, but has only
rudimentary requirements for generators.
Table 2:
Applicable grid code documents Indonesia.
Region Grid Code Specific Requirement for RE Generation
Ja-Ma-Li (Jawa- Ja-Ma-Li Grid Code (2007), Indonesian PLN’s Interconnection Guideline for RE
Madura-Bali) Electric Distribution Code (Lampiran Pedoman Penyambungan PLT) –
Sumatera Sumatera Grid Code (2008), Indonesian applicable to distribution grids up to 20 kV only
Electric Distribution Code
Sulawesi Sulawesi Grid Code (2008), Indonesian
Electric Distribution Code
Kalimantan Indonesian Electric Distribution Code unclear
Papua Indonesian Electric Distribution Code
Other islands Indonesian Electric Distribution Code
23
3.1.3 Grid Code Development
Grid codes in Indonesia are developed by state utility PLN as the sole operator of grids, and grid code
development is mandated by the government. Documents are approved by the Ministry of Energy and Mines.
No details are known about the development process or involvement of stakeholders.
The REGP grid code was developed by PLN in coordination with USAID, involving a number of international
consultants.
A clear grid code development and revision strategy is advisable, especially as the transmission grid codes
are more than ten years old and in need of revision.
3.1.4 Requirements for Generators

The most important requirements imposed on generators under the three grid code documents are given in
Table 3. The requirements in the REGP code are more detailed than those in the older transmission grid codes.
Table 3:
Requirements for generators under the different Indonesian grid code documents.
Requirements for Generators
RE Power
Characteristic Grid Code Sumatera Grid Code JaMaLi
Generation
Applicable to All entities connected to the transmission grid (20-500 kV).
RE generators <10
MW connected to 20 Generators grouped in small (<30 Generators grouped in small
kV and below MW), medium (30-100 MW), and (<50 MW), medium (50-200
large (>100 MW). MW), and large (>200 MW).
Permissible voltage ±5 % Vn for 500 kV, +5/-10%
+5%/-10% Vn ±10 % Vn
range in the grid Vn for 20-150 kV
Frequency Range for 47.5 – 51.0 Hz full 47.5 – 52.0 Hz online
generators output 49.0 – 51.0 Hz full output
Voltage range for Trip below 0.85 and
Not specified
generators above 1.10 p.u.
Overfrequency
Droop control, not specified for > 51.0 Hz
behaviour
Adjustable trip setting
Underfrequency
Droop control, not specified for < 48.5 Hz
behaviour
Active power control Remote controllability Governor for primary control,
Governor for primary control,
required from wind Automatic Generation Control
AGC connection for large
turbines, ramp rate (AGC) connection for large and
generators
limit for PV, medium generators
Power Factor 0.85 lagging
0.90 leading
Voltage control Not allowed, power
factor should be Automatic Voltage Regulator (AVR)
controlled
Fault behaviour / LVRT Trip at undervoltage Not specified
Flicker Pst = 1.0
Plt = 0.8
Total Harmonic
5% 3%
Distortion
Supervisory Control PLN may require
and Data Acquisition installation for units > Required, but no protocols specified
(SCADA) connection 250 kW
24
All three documents are very brief when it comes to technical requirements and may have to be expanded as
PLN gather more operational experience with renewable energy. There are no inherently bad requirements in
either code that present a major barrier for renewable energy. However, the active power control provisions
for the transmission grid require rather advanced functionalities from wind turbines, such as full frequency
control while running at curtailed setpoints. Looking ahead, this is a good idea, but it may have to be clarified
under which circumstances these functionalities will actually be used, and the requirements may have to be
expanded to contain more specifics.
The following requirements that may be crucial to grid stability were found to be lacking from the documents:
• The transmission codes require no specific fault behaviour from generators. Generators may currently
trip outside of the given frequency range, and no provisions are given for under or over voltage events.
This is particularly true for the introduction of renewable generation connected to the transmission
grid, such as wind power plants or utility scale solar installations, requirements for Fault Ride Through
(FRT) and time limited operation outside of the normal frequency range should be added. [8]2013[9]
• SCADA connection is required under the transmission codes, but no information on the used protocols
is given in the connection code (lists of signals that need to be transmitted are included in an annex to
the code).
• The REGP code sets requirements for off-unity power factor operation of generators, but requires
them to, under normal conditions, control power factor and not voltage. This is rather non-specific and
should be revised.
3.1.5 Connection Process

A large part of PLN Interconnection Guideline for RE (applicable to the distribution grid) is dedicated to the
application and connection process for small renewables. The processes are clearly defined and described
and contain the requirements for documents to be exchanged, the definitions of responsible parties, and time
schedules for each step.
The defined process is in line with good international practice. Most notably, the document specifies conditions
for applicability for a fast track connection process for small generators. Based on these conditions, the
generator can be connected directly, or a clearly defined set of studies may have to be performed. The
developer is responsible for the studies, which are then reviewed by PLN. If the studies reveal “adverse
system impacts” of the connection, PLN can assign an alternative connection point for the facility. The initial
connection point is defined as the nearest grid access point geographically. This is the standard approach in
many countries, although it could be further improved by following the German example:
• The initial connection point as the nearest point geographically, unless the developer or the grid
operator can prove that connection is cheaper at another connection point (example: original
connection point requires river or road crossing);
• In case the initial connection point is used, or the connection point is shifted due to the results of one
of the connection studies, the developer pays the connection cost;
• Either developer or grid operator may request to shift the connection point for other reasons but must
then pay an additional cost.
Moreover, a clear definition of “adverse system impact” should be added, as it is currently lacking from the
document. This requirement may lead to legal issues once PLN refuses connection on the basis of this
provision without having provided a clear definition.
Notably, this process is clearly defined only for renewable energy generators connected to the distribution grid.
Moreover, the document specifies that it may not be applicable in isolated power systems, i.e. small systems
on more remote islands such as Kalimantan, Sulawesi, or Papua.
25
For the transmission grids, the connection process is only loosely defined in the corresponding code
documents.6 The transmission codes only dictate that the developer needs to submit a set of data on the
installation and declare compliance with the grid code, and that PLN is authorized to run compliance tests. The
exact process seems to be left to bilateral negotiations. With the traditional assumption being that only large
power stations that need long planning processes are connected to the transmission grid, this is sufficient.
However, with Indonesia’s 23 percent renewable energy target for 2025 [10], the number of wind power plants
and the utility scale of PV installations that will be connected to voltage levels above 20 kV (likely 70 or 132
kV) can be expected to rise. At least for such installations, a defined connection process similar to the one for
the distribution grid (albeit adapted to higher voltage specifics) should be put in place.
The transmission grid codes specify the following:

“Grid Users must pay all installation costs of connecting facility to the Grid.”
With a revision of the connection process, this should be replaced with a more specific provision. This is
particularly true for renewable energy, where the topic of connection cost has been debated internationally
over the past two decades. Most countries have switched from deep connection charge, where a new
generator pays for all grid investments linked to the connection, to shallow connection charge, where the
generator pays for the direct connection to the grid, but other grid reinforcement costs are recovered via grid
fees from the users. The latter has generally been deemed more appropriate, as grid reinforcement benefits
more than one party. With deep connection charges, in the case of several generating facilities connecting to
the grid sequentially, only one of them will bear the cost while the others are riding free.
3.1.6 Compliance Mechanisms

The transmission codes contain no specifications on compliance mechanisms. It is clear from the codes that
the generator is required to comply with the requirements presented, but there are no specific descriptions of
the application and connection process, the required documentation, or the compliance tests that need to be
conducted. It is clear that PLN is authorized to conduct compliance tests, but a lack of clarity concerning these
may present a barrier to investments in renewable energy.
The REGP code is clearer on this matter, especially concerning the connection process (see section 3.1.5). PLN
is required to connect renewable energy generators of less than 10 MW to the distribution grid, and the process
of application is well defined. Concerning compliance, PLN accepts type certificates from accredited testing
agencies which are specified in a governmental decree (Minister Regulation 5/ESDM/2014 on Procedures for
Electricity Accreditation and Certification). These agencies are required to perform and validate the tests given
in Table 4. The tests can either be performed in the laboratory or in the field as part of the commissioning tests.
In the latter case, the accredited test agency has to be present for the commissioning (of the first unit, if the
certificate is then valid, no tests need to be performed on future installations of the same type).
In the case of non-certified equipment being installed, PLN is authorized to conduct all tests during
commissioning. Generally, commissioning is to be supervised and approved by PLN. PLN may also require
periodic re-testing to ensure enduring compliance.
The compliance requirements in the REGP code are generally in line with the standards of international good
practice. Similar provisions should be adapted to suit the transmission codes.
6
There may be provisions in the Grid Codes for the transmission grids on Java/Bali/Madura, Sumatera and Sulawesi, but only the Connection Code parts of these
codes were made available to the consultant in English. These lack defined connection processes.
26
Table 4:
PLN type test
Synchronous Induction
Type Test Inverter
Generator Generator
Response to distribution abnormal voltage X X X
Response to distribution abnormal frequencies X X X
Anti-islanding X X X
Loss of control circuit X X X
Synchronization X 1 1
Reset relay X X X
Short circuit X X X
Power factor X X X
Connection integrity X X X
Surge withstand capability X X X
Harmonic distortion X X X
Flicker X X X
Inrush current - X -
DC injection - - X
DC isolation - - X
X: Required
1: Required for all self-excited induction generators, and inverters that operate as voltage sources when connected to the Distribution System
3.2 Malaysia
3.2.1 Power Markets

The Malaysian system is vertically integrated, with utility Tenaga Nasional Berhad (TNB) owning and operating
transmission grids and the majority of generation and distribution grids on the Malay Peninsula and supplying
more than 80 percent of Malaysian demand. TNB acts as an electricity retailer as well. Differing from other
countries in the region, TNB is not fully state owned. In the states of Sarawak and Sabah/Labuan (both on
Borneo), the role of the vertically integrated utility is fulfilled by Sarawak Energy Berhad (SEB, formerly state
owned, privatized) and Sabah Electricity Sdn. Bhd. (SESB, owned in majority by TNB and in minority by the
federal state of Sabah). IPP operations are permitted with the respective utility acting as the single buyer. The
share of IPPs is comparatively high (ca. 50 percent of total generation) with lucrative tariffs and take-or-pay
contracts7 granted since the partial privatisation of the power sector in the 1990s.
As of 2017, the Malaysian Energy Commission (regulatory agency) has undertaken the first step towards
a free wholesale power market by introducing the New Enhanced Dispatch Arrangement (NEDA). This
requires the utilities to determine the least cost dispatch with a marginal payment for utility owned generators,
IPPs (who are now allowed to bid with their actual generation cost), IPPs with expired PPAs and industrial
generators (which usually have no PPAs but can now bid into the market). The result is a marginal power
market with a single buyer in each grid.
7
Utility has to buy a certain amount of power annually from the IPP mandatorily.
27
Figure 2:
Malaysian power system with three different operators (from left to right: TNB, SEB, SESB).

As mentioned, the Malaysian system is split up into two synchronous zones, the peninsular grid run by
TNB, and the grid of Sarawak, Sabah, and Labuan, run by SEB and SESB. Accordingly, different grid code
documents are applicable. The Malaysian Grid Code and the Malaysian Distribution Code, published by TNB
in 2013 and 2012, are applicable to TNB grids on the peninsula,8 while there are separate Sabah and Labuan
Grid Code published by SESB. No information was provided for the state of Sarawak. Additionally, TNB has
published the Technical Guidebook for the Connection of Generation to the Distribution Network in 2005,
which is not an applicable regulatory document, and the Technical Guidebook on Grid Interconnection of PV
Power Generation to LV & MV Networks. The legal status of the latter is unclear, but it provides technical
requirements for the connection of PV to TNB’s distribution networks.
As an additional document, the Renewable Energy (Technical and Operational Requirements) Rules 2011,
published by the Malaysian federal government with amendments and re-publishing in 2014, outlines the legal
rules for connecting renewable energy sources to the grids. It is a legal document that sets the background
for the grid code documents itself but does not set detailed technical requirements (despite its name). It does
however describe connection processes and time schedules, and it limits renewable generation units to a
size of 30 MW. The Guidelines on Large Scale Solar Power Plants for Connection to the Transmission and
8
The exact applicability of the Malaysian Distribution Code is unclear, as it is sometimes stated that it also applies in Sabah/Labuan.
28
Distribution Electricity Networks, published by the Regulatory Commission in 2016 and revised in 2017, allows
PV generators between 30 - 50 MW to connect and it specifies that they must fulfil the requirements from the
Malaysian Grid Code on the peninsula and the Sabah and Labuan Grid Code in Sabah and Labuan.
It is notable that the Malaysian Grid Code and the Sabah and Labuan Grid Code are inspired by the Irish grid
code and share structure, layout, and wording with that document. [11] The same heritage line is recognized
for the Malaysian Distribution Code and the Irish distribution code. Neither of the three documents is however
a word for word copy but has been adjusted to the local conditions.
Table 5:
Applicable grid code documents in Malaysia.
Peninsular • The Malaysian Grid Code (2013) • Technical Guidebook on Grid-Interconnection of
PV power generation to LV & MV networks
• The Malaysian Distribution Code (2012)
• Renewable Energy (Technical & Operational
Requirements) Rules 2011 + 2014 Amendment
• Guidelines on Large Scale Solar Power Plants for

Connection to the Transmission and Distribution
Electricity Networks (2017)
Sabah/ • Sabah and Labuan Grid Code (2011) • Renewable Energy (Technical & Operational
Labuan Requirements) Rules 2011 + 2014 Amendment
• The Malaysian Distribution Code (2012)
• Guidelines on Large Scale Solar Power Plants for
Connection to the Transmission and Distribution
Electricity Networks (2017)
Sarawak • Under Law of Sarawak Chapter 50 - -
Electricity Ordinance Section 36 - Two rules
are gazette:
- Electricity Rules (1999)
- Electricity (State Grid Code) Rules (2003)

The grid code for Sabah and Labuan was published by the Energy Commission (Suruhanjaya Tenaga),
the Malaysian energy regulator, and developed with the involvement of US consulting company Parsons
Brinckerhoff. The grid code itself authorizes SESB as the sole utility to appoint a grid code panel. It specifies
which stakeholder representatives are to be included in the panel. It also contains rules under which additional
parties may request participation in the panel. The panel is to review and revise the grid code constantly. This
is in line with international standards of good practice.
According to the code, the panel shall include:

• A Chairman, appointed by the Commission;
• A representative from the office of the Commission;
• A person appointed by the Commission;
• Two persons representing the Grid System Operator (GSO) and Regional System Operators (RSOs);
• A person representing SESB’s Transmission Network Operator;
• A person representing SESB’s Distribution Network Operator;
• A person representing the Independent Distribution Network Operators (IDNOs);
• Three persons representing IPPs;
• A person representing the Single Buyer;
• A person representing SESB’s generation division;
• A person representing the Interconnected Parties;
• A person representing the Regional Network Operators (RNOs).
29
The peninsular Malaysian Grid Code and the corresponding Malaysian Distribution Code contain the same
provisions on development and the grid code panel. The provisions can be traced back to the common
heritage of all three documents in the Irish grid code and distribution code, indicating good knowledge of
international standards of good practice on behalf of the development panels while Grid code development in
Sarawak is unclear based on the provided information. [11]
Apart from that, Malaysia also has the TNB PV Guidebook which was developed by TNB and University
Tenaga Nasional (UNITEN). It requires compliance of PV units with the Distribution Code. Concerning the
development process and revisions to the document, stakeholders cannot directly impact revisions of the
PV Guidebook, but they can do so by requesting reviews of the Distribution Code. The technical guidebook
contains no directly applicable regulations, but elaborates on the requirements set by the grid code and
includes more detailed examples for installation of units and the application of grid code requirements. It
is thus recommended to revise this guidebook with every update of the Distribution Code to keep the two
documents aligned and ensure that no outdated information is presented in the Guidebook.
To complement that Guidebook, the Guidelines on Large Scale Solar Power Plants for Connection to
the Transmission and Distribution Electricity Networks were developed and published by the Regulatory
Commission. There seems to be no stakeholder involvement, but the document mainly states that large PV
plants are subject to the applicable grid codes. In addition to the guideline, the government also developed
The Renewable Energy (Technical and Operational Requirements) Rules of 2011 which is part of the federal
energy legislation. However, the stakeholder involvement is not really clear.

The requirements for generators outlined by the respective grid code documents are given in Table 6. The
Sabah/Labuan grid code only addresses requirements for generators very briefly and is thus not included.
The lack of detailed requirements in that document are a primary gap in the Malaysian grid code landscape
that should be addressed as soon as possible. It may be sensible to adopt an adapted Malaysian Grid Code
for Sabah/Labuan (and likely Sarawak as well), as it is structurally similar (same heritage) but much more
detailed. Local peculiarities of either system may be distinguished in the (revised) code.
Table 6:
Requirements for generators under the different Malaysian grid code documents.
The Malaysian The Malaysian Grid Code
Characteristic TNB PV Guidebook
Distribution Code
PV connected to LV All generators > 50 MW,
and MV distribution Malaysian distribution grid renewables “not designed for
Applicable to
grids (230 V – 33 kV) 230 V – 33 kV voltage or frequency control”
owned by TNB are exempt.
+10%/-6% Vn for LV ±5% Vn for 500 kV
Permissible voltage
+10%/-6% Vn ±5% Vn for MV ±10% Vn for 275 and 132 kV
range in the grid
±10% Vn at contingencies ±6% Vn below 132 kV
49.5 – 50.5 Hz steady 49.5 – 50.5 Hz full output
Frequency Range
49 – 51 Hz state 47.5 – 52.0 Hz online
for generators
47.0 – 52.0 Hz short term 10s at 47.0 – 47.5 Hz
Voltage range for +10%/-15% Vn for LV
±10% Vn is implied ±10% Vn is implied
generators ±10% Vn for MV
Overfrequency
Trip at 50.5 Hz (Droop control)
behaviour Shall withstand short term
Underfrequency frequency events May reduce output below 49
Trip at 49.5 Hz
behaviour Hz, but must stay online
30

The Malaysian The Malaysian Grid Code
Characteristic TNB PV Guidebook
Distribution Code
Speed governor for Droop control 3-5%, must be able
Active power
none synchronous units > 5 to receive frequency setpoint,
control
MW AGC connection required
0.85 lagging
Power Factor 0.90 lagging + leading 0.90 lagging + leading
0.95 leading
Not allowed, but AVR for generators >
power factor must 5 MW, otherwise 0.90 AVR, specifications by system
Voltage control
be 0.9 lagging when lagging unless otherwise operator
output is above 50% specified
Fault behaviour / Trip at undervoltage < May be required by
-
LVRT 0.85 p.u. distributor for units > 30 MW
LV: Pst < 1.0, Plt < 0.8 Pst < 0.8, Plt < 0.6
Flicker MV: Pst < 0.9, Plt < Pst < 0.9, Plt < 0.7 Pst < 1.0, Plt < 0.8 (below 132
0.7 kV)
Total Harmonic 5% THD, plus limits 5% for LV
3%
Distortion from IEC 61727-2003 6.5% for MV
Required for units > 2 Can be required by
SCADA connection Required
MW distributor
54 kW per LV feeder,
not more than 90% of - -
transformer rating
Penetration limit
85% of daytime load
and 90% of transformer - -
rating for MV
While scope, terminology, structure and a large part of the wording of the two (transmission) grid codes and
the distribution code have obviously been adopted from Irish grid code documents, the technical requirements
for generators differ significantly from the original. Several requirements have been adapted to the
specifications of the Malaysian system. Generally, set requirements are adequate (as far as this can be stated
without further detailed power system analysis). However, the following issues should be revised:
• Renewable generators “not designed for frequency and voltage control” are exempt from the
requirements in the Malaysian Grid Code. International good practice is to also set mandatory
requirements for renewable generators, which may differ in some cases from those for synchronous
(conventional) generators. Modern inverter based renewable generators can also participate in voltage
and frequency control. (This is mitigated to some degree by the Guidelines on Large Scale Solar
Power Plants for Connection to the Transmission and Distribution Electricity Networks, which states
that PV plants between 30 and 50 MW must fulfil the applicable grid codes, including frequency and
voltage control requirements.)
• None of the grid code documents contain Low Voltage Ride Through (LVRT) requirements. For
voltage levels of 11 kV and above, these should be mandatory. As by the Distribution Code, TNB is
authorized to request LVRT from generators > 30 MW (which would, under the current rules, always be
conventional generators), although it is not strictly required. [8]2013[12]
• The Distribution Code sets no direct rules for active power controllability of generators (apart from the
requirement for a speed governor for synchronous generators > 5 MW). All units connected to 11 kV
and above should be able to receive active (and reactive) power set points per remote control.
• Voltage control from generators < 5 MW is neither required nor allowed. Even if the functionality is
currently not used, the capability to control the voltage at the connection point with reactive power
should be required for the future.
31
It should be noted that the Irish distribution code [11], which inspired the Malaysian Distribution Code, is itself
rather weak on requirements for distributed generators, as small distributed generation from solar or hydro
sources is not common in Ireland (wind turbines are governed by the Irish transmission grid code). TNB has
thus issued the PV Guidebook which sets more detailed requirements. These are not always adequate, with
the following issues identified:
• PV generators are required to disconnect at 49.5 Hz and 50.5 Hz. This is a) not compliant with the
grid codes and b) inherently a bad idea. At rising shares of PV, a frequency deviation may lead to
the loss of all PV in the synchronous system and thus to a blackout.9 International standards of
good practice is to require PV to stay online until 47.5 or 47.0 Hz on the low frequency side, and
gradually reduce output power at severe over-frequency, in this case likely starting at 50.5 Hz
while staying online (Limited Frequency Sensitive Mode for Over-frequency, LFSM-O). [13]”non-
dropping-particle”:””,”parse-names”:false,”suffix”:””}],”container-title”:”15th Wind Integration
Workshop”,”id”:”ITEM-1”,”issued”:{“date-parts”:[[“2005”]]},”title”:”Necessary Time Response of LFSM-O
to Ensure Frequency Stability in the ENTSO-E Continental Europe Synchronous Area”,”type”:”paper-
conference”},”uris”:[“http://www.mendeley.com/documents/?uuid=64f6f2d1-486b-4a0c-a39f-d603
a9d38692”]}],”mendeley”:{“formattedCitation”:”[13]”,”plainTextFormattedCitation”:”[13]”,”previously
FormattedCitation”:”[13]”},”properties”:{“noteIndex”:0},”schema”:”https://github.com/citation-style-
language/schema/raw/master/csl-citation.json”}
• Voltage control from PV generators is neither required nor allowed. Even if the functionality is currently
not used, the capability to control the voltage at the connection point with reactive power should be
required for the future.
• PV penetration limits for feeders should be determined on a regular basis. Instead of setting fixed
limits, additional studies may be mandated by the grid code or guidelines if a certain threshold is
crossed.
It is recommended to rework these requirements, then integrate them into the Distribution Code and make
them applicable not only to PV generators, but also to all other types of distributed generation. Generally, a
consolidation of requirements for generators should be considered to provide a coherent framework of rules.

The Renewable Energy (Technical and Operational Requirements) Rules 2011 stipulate the following for the
connection process of renewable generators to the distribution grid:
• Generators with an installed capacity of > 72 kW must apply to the operator for a connection point
before they can apply for the feed-in tariff. The operator must process the application within 21 days
from the payment of an application charge. Connection can be refused on technical grounds.
• For generators with an installed capacity of > 180 kW, this application process may involve a Power
System Study (PSS) and the operator is not bound to the 21 days limit. The applicant bears the cost
for the study. Connection can be refused on technical grounds.
The process is also depicted in the PV Guidebook, as displayed in Figure 3. Furthermore, the Rules dictate
the connection point to be the geographically nearest grid access point by default. The operator may set
another connection point on the basis of the power system study conducted and must justify it with technical
reasons. In case of a disagreement between applicant and operator, the case can be reviewed by the
regulator after appeal. If the operator insists on a different connection point at a lack of discrete technical
reasons, the installation will be connected there, but the operator bears the additional cost compared to the
default connection point.
This entire process is in line with international standards of good practice, however, it is unclear which rules
apply to generators below the threshold of 72-kW. Besides this process, the Rules also specify that the
9
Germany had a requirement for all PV to disconnect at 50.2 Hz, and an expensive retrofitting scheme had to be implemented when maximum PV generation
exceeded the amount of primary reserves in the system. Germany currently has more than 40 GW of PV installed, the instantaneous loss of which (which could have
happened before the retrofit) would instantly lead to a pan-European blackout.
32
developer will have to pay for all costs related to the connection, including grid reinforcements. This is a deep
connection charge model and may present a barrier to renewable energy integration (compare to section 3.1.5
where the model and its implications are explained).
Not Complete
Start 1. Prepare documents

Receive and Process
2. Fill in form EG1/
EG1PV check Payment
Complete
3. Submit to RE dept.
TNB TNB (RE) TNB (RE)
RE Developer
Technical Process PSS 1. Pay fees

Feasibiity • Register in PSS list 2. Submit a copy of
Study • Start Count day 1 HWR
Asset Management TNB (RE) RE Developer

Dept.
Approval by Issue of Developer

PSS Approval Apply to SEDA
Committee Letter for Quota
Approved
Not Approved
Issue of
Non-approval
Letter
Figure 3:
Application process set forth by the PV Guidebook.
RE developers are required to provide the following details when applying for the Power Systems Study (PSS):
• RE Developer General Information
• RE Plant/facility Installer Information
• Details of Installation Equipment:
i) Photovoltaic equipment
ii) Step-up transformer
iii) Circuit breaker rating
iv) System Compliance
The Guidelines on Large Scale Solar Power Plants for Connection to the Transmission and Distribution
Electricity Networks contain even more detailed process descriptions, including draft PPAs, guidelines on
the tendering of PV capacities, connection point specifications, asset demarcation specifications and the
entire application and connection process. This is obviously a very well thought out document that exceeds
international standards of good practice and should be used as a template for other types of generators as well.
33
Government Policy
LSS - 1000MVx by 2020 implemented in 4 years
Target COD in 2017, 2018, 2019, 2020 Issunance of Request for Proposal (RFP) Award
Annual cap is 200MWx for Peninsula and 50MWx for Sabah/
Labuan • ST will invite the short listed participants to participate in RFP stage. ST issues conditional letter of award (CLOA)
• Bidders will receive the RFP documents including PPA, LSS Guidelines & to winning bidders.
NDA form.
• Potential connections (nodal points) to TNB/SESB network will be provide.
• The LSS developer is fully responsible to
Implementation Mechanism • acquire land or submit certified and executed Site/Lease Agreement over
• Guidelines issued by ST as provided under Section 50C of ESA 1900 Land Tile. PPA Signing
(Amendment 2015). • obtain ROW & permits from relevant local authorities, the required Upon successful negotiations, bidder will enter
• Competitive bidding by ST Interconnection Facility (IF) dan network reinforcement up to the Point of into a contract with TNB/SESB
• Bidding exercises to be conducted annually as per depicted in Diagram 1. Common Coupling (PCC).
• Take and pay, energy only PPA for 21 years (non FIT) and the price is firm • design, construct, commission, test and complete LSS plant.
throughout 21 year period • All costs associated with the connection of LSS and power system studies,
• Developers to build, own & operate (BOO). shall be borne by the LSS developer.
• Foreign ownership is less than or equal to 49%. PPA effective date
• To optimize land usage for other economic activities (eg: agriculture)
• Capacity range of 1MVx - 50MWx.
• Connected to Distribution (1-29MWx) or Transmission (30MWx-50MWx)
network. Submission of Request for Proposal (RFP) Financial Close
• 2017-2018: Capped at accumulative of 50MW (Peninsular) and 10MW • Bidders submit the following to ST:
(Sabah/Labuan) per successful bidder. • All documents as specified in RFP
• Estimated quota as follows (at sole direction of ST): • Financial commitment letters
• Certified copy of site agreement for facility & route survey for
Project Implementation
Peninsular interconnection ROW • Initial Operation Done (IOD)
LSS Bidding Cycle 2017 - 2018 • Approved PSS study by Grid Owner/Distribution Licensee • Testing and commissioning
• Consortium arrangement (if any)
Category 1MWac - 5MWac 6MWac - 29MWac 30MWac - 50MWac
• Declaration of energy production
Allocation [10MW(5%)] [100MW (50%)] [90MW(45%)] • Maximum Annual Alllowable Quantity (MWh) for 21 years
LSS Bidding Cycle 2019 - 2020 • To submit financial model
Commercial Operation Date
Category 1MWac - 5.99 MWac 6MWac - 9.99MWac 10MWac - 29.99MWac
Allocation [36 MWac (10%)] [144 MWac (40%)] [180 MWac (50%)]
Sabah/Labuan Evaluation criteria

LSS Bidding Cycle 2017 - 2018 • Levelised cost of energy (LCOE)
• Compliance with technical standard and regulatory requirements
Category 1MWac - 5MWac 6MWac - 10MWac
• Fulfil the technical requirements as per RFP
Allocation 10MWac (20%) 40MW (80%)
LSS Bidding Cycle 2019 - 2020
Category 1MWac - 5.99 MWac 6MWac - 10.00 MWac
Pre-Qualification (Pre-Q)
• To evaluate company’s financial & technical capability
• ST will advertise a call for RFQ
• RFQ evaluation document will be issued by ST
Figure 4:
Tendering, application, connection, and commissioning process from the Guidelines on Large Scale Solar Power Plants for
Connection to the Transmission and Distribution Electricity Networks.
The grid code documents simply prescribe an agreement between operator and applicant/developer for the
connection point which does not contradict the legal rules (and which specifies how the agreement is reached
for renewable generators). This leaves the connection point procedure for non-renewable generation open to
negotiations.
Concerning the connection process itself, none is specified in the Distribution Code, while a large set of
planning studies and a connection timeline is included in the Grid Code, which is currently not applicable
to renewables. Both should in future revisions be brought in line with the legal rules and the procedures
described in the PV Guidebook. The importance of this for renewable energy development depends on the
renewable energy plans for Malaysia. If renewables are to be limited to 30 MW and below and connection to
the distribution grid, the existing rules are sufficient (albeit a revision of the connection cost scheme should
be considered). If large scale wind power applications are planned, additional rules for the transmission grid
may become necessary, and these should be based on the Guidelines on Large Scale Solar Power Plants for
Connection to the Transmission and Distribution Electricity Networks.

With its heritage in the Irish grid code [11], which prescribes extensive compliance tests by the grid operator
during the commissioning phase of a generating unit, the Malaysian Grid Code (currently applicable to all
generators > 50 MW connected to TNB’s grids on the Peninsula, as well as to large PV plants as defined
by the Guidelines on Large Scale Solar Power Plants For Connection to the Transmission and Distribution
34
Electricity Networks) contains a full set of specifications for such tests. Like the Irish grid code, the tests are
very focused on active and reactive power controllability. Tests are to be conducted under supervision of TNB
at commissioning and repeated at least every five years as well as include the following:
• Frequency response tests;
• Black start tests where applicable;
• Dispatch accuracy tests (response to AGC signal);
• Availability tests;
• Additional tests of all control systems upon specification by TNB.
Detailed procedures for action in cases of non-compliance are also given. Renewables are however exempt
from the rules set forth in the Malaysian Grid Code, which is inadequate.
The distribution code and the PV Guidebook state that TNB, together with a representative from the regulator, shall
conduct power quality measurements, anti-islanding tests, and equipment functional tests on generators connected
to the distribution grid, and that the developer is responsible for proving grid code compliance of inverters.
Overall, the Malaysian grid code documents do contain compliance mechanisms, but these are still somewhat
lacking in clarity concerning the exact responsibilities and the compliance testing process. Future grid code
revisions should include a clear set of compliance tests conducted by either the developer or by TNB along
with rules for documentation of compliance and commissioning tests. Moreover, a focus should be put on
type testing and certificates, so that not every single new installation has to be tested, but only first-time
installations of a certain equipment type. Especially for small PV installations, detailed compliance tests
(especially those required to be conducted by both TNB and the regulator) can become a major obstacle to
development, quickly exhausting resources at TNB and the regulator and leading to long waiting times. This
can be prevented with the introduction of a type testing and certification scheme, either by TNB themselves
(testing the first installation only) or through certificates issued by accredited third parties. The concept of type
testing is mentioned in the PV Guidebook, but is not sufficiently reflected in the grid codes themselves.
3.3 Thailand
3.3.1 Power Markets

Thailand’s power system is partially vertically integrated. Transmission grids and a considerable share of
generators are owned and operated by state utility EGAT (Electricity Generation Authority of Thailand),
who are also in charge of the bulk of electricity sales, while distribution grids and retail are operated by the
Metropolitan Electrical Authority (MEA) in the greater Bangkok area, and the Provincial Electrical Authority
(PEA) in the rest of the country. Both the distribution and retail companies are state owned. Privately owned
generation is classified into IPPs (in this case operator of large power stations >90 MW), Small Power
Producers (SPP, >10 MW) and Very Small Power Producers (VSPP, ≤10 MW). With a total of ca. 20 GW of
installed capacity, IPP, SPP and VPP own a larger share of generation than EGAT, who own just over 15 GW.
For the IPPs and SPPs, EGAT acts as a single buyer, while VSPPs sell to MEA or PEA (see Figure 5). MEA
and PEA act as EGAT’s largest customers.
35
Generation SPP EGAT IPP Import VSPP
(% installed capacity) (7%) (47%) (38%) (5%) (3%)
Transmission EGAT (100%)
ERC
PEA MEA Direct Customers
Distribution (70%) (30%)
users users
Figure 5:
Enhanced singe buyer mechanism in Thailand. [14]
As EGAT is responsible for determining a least cost dispatch,10 there is no power market. Power plants are
granted energy and capacity (availability) payments. SPPs can also sell their power directly to customers that
are located close to the plant. VSPPs usually sell their power to the distribution companies MEA and PEA.
Electricity prices for consumers are heavily regulated by the Energy Regulatory Commission.

All three utilities publish their own grid codes as listed in Table 7. The main applicable documents are the
EGAT Grid Code of 2014, the PEA Interconnection Code of 2016 and the MEA Interconnection Code of 2015.
Not all documents were made available in the English language, but a number of other auxiliary documents
were provided:
• The EGAT code was provided in its 2012 version in English (translation of 2008 Thai version) and in its
2014 version in Thai;
• The MEA code was only provided in Thai;
• A document on grid code requirements for generators, published by EGAT in 2008, was provided in
English – it contains more detailed requirements than the 2012/14 EGAT grid code, and its applicability
is unclear;
• An ERC document containing the requirements for solar rooftop installations from the current MEA and
PEA grid codes, compiled with the assistance of GIZ, is provided;
• A report by German consultants Moeller-Poeller Engineering (MPE) was provided, which apparently contains
the requirements from the 2014 EGAT code (which differ from the 2012 requirements only in detail).
10
Description of the least cost dispatch methodology from 2012: http://docshare.tips/egat-power-plant-dispatching-in-thailand-2012_58ac0984b6d87f0a728b56c7.html
36
Table 7:
Applicable grid code documents in Thailand.
Distribution PEA’s Interconnection Code ERC Solar Rooftop Regulation (with technical requirements from
grids PEA and MEA as appendix; 2013)
MEA’s Interconnection Code
Transmission EGAT Grid Code 2012/2014 Grid Code Requirements for Electrical Grid Connection 2008
grid (applicability unclear)

Grid codes in Thailand are developed continuously by the utilities EGAT, MEA, and PEA under supervision
of the regulator ERC. There seems to be some communication on requirements between EGAT and the
two distribution operators, as EGAT requirements are mentioned in the PEA code, and some requirements
for general power system stability are included in the distribution codes. No information about stakeholder
involvement is provided in any of the distribution codes.
The 2012 EGAT code contains a section on grid code review, which requires EGAT to set up an internal
grid code panel which is to keep the grid code under review as well as analyse and address suggestions for
updates from users and ERC. This is generally a good requirement but could be more specific and should in
the future include clearly defined review intervals and a defined pathway to enter suggestions to the grid code
panel. Direct stakeholder involvement in the grid code panel is recommended.11

The requirements for generators under the three different grid code documents are listed in Table 8. The PEA
requirements are incomplete and partially filled in from the MPE report and the ERC PV document. PEA and
the MEA code are structurally similar, but it cannot simply be assumed that the missing requirements are also
the same. The EGAT requirements are from the 2012 EGAT Grid Code and have been updated with the 2014
requirements from the MPE report as marked wherever appropriate. Additional requirements for wind turbines
from EGAT’s 2008 publication were added wherever such requirements were missing from the 2012/14 EGAT
grid codes – applicability of that document is questionable (instances are marked clearly).
Table 8:
Requirements for generators under the different Thai grid code documents. Requirements in cursive marked with * are taken
from secondary sources (such as the MPE grid code report and the ERC annexes), requirements in cursive marked with **
are taken from EGAT’s 2008 interconnection requirements that may no longer be applicable. Explanation in the text.
PEA Interconnection MEA Interconnection
Characteristic EGAT Grid Code
Code Code
Applicable to Generators connected Generators connected
Generators connected to EGAT
to PEA distribution grid to MEA distribution grid
transmission grid (≥ 69 kV)
(230V – 115 kV) (230V – 115 kV)
Permissible voltage ±3 % Vn regular (115 kV)
±5% Vn regular (MV + HV)
range in the grid ±5% Vn regular +7/-3% Vn emerg. (115 kV)
±10% Vn regular (LV)
±10% Vn emergency -2 %/- 9 % Vn regular (MV)
±10% Vn emergency
+9/-2% Vn emerg. (MV)*
Frequency range for 49.5 – 50.5 Hz full output 49.0 – 51.0 Hz (PV/VSPP)
generators 47.0 – 52.0 Hz
47.0 – 52.0 Hz online 47.0 – 52.0 Hz
Voltage range for 0.9 – 1.1 p.u. unlimited
generators 0.9 – 1.1 p.u.* 0.5 – 0.9 p.u. for 2 s
1.1 – 1.2 p.u. for 1 s
11
If such requirements are not already part of the 2014 grid code. The MPE report does not address this issue.
37
PEA Interconnection MEA Interconnection
Characteristic EGAT Grid Code
Code Code
Over-frequency Droop control, over-frequency
behaviour sensitivity Trip immediately (VSPP),
Trip immediately (VSPP),
others must comply with
Underfrequency Stay connected, output reduction adjustable trip setting
EGAT grid code
behaviour allowed
Active power control Remote control required
AGC connection and governor
for > 1 MW and all HV ?
(droop control) required
connected units
Power Factor 0.85 leading + lagging (synchronous)
0.85 leading
0.9 leading + lagging (inverter)
0.85 lagging*
0.95 leading + lagging (inverter connected to LV)
Voltage control Required, remote controllability
Q(U) characteristic
required ?
selectable by operator
AVR for wind turbines**
Fault behaviour / 150 ms for generators >
625 ms at 15% Vn for wind
LVRT 500 kW connected to MV -
turbines**
and above
Flicker Pst = 0.8 and Plt = 0.6 for 115 kV
and above
- IEC 61000-3-3 (2008)
Pst = 1.0 and Plt = 0.8 for below
115 kV
Total Harmonic Specified (probably 5%),
2.45% for 69 kV
Distortion lacking from English 5%
1.5% for 115 kV and above
translation
SCADA connection Required for > 1 MW and
Required, includes signal list all HV connected units, ?
includes signal list
Penetration limit 15% of DT load for LV
- 75% of transf. load MV 15% of DT load for LV and
120/230 MW per circuit MV
for single/double 115 kV
Simulation model IEEE block diagram required for
thermal and Closed-Cycle Gas
- ?
Turbine (CCGT) plants, detailed
specifications
Like the Malaysian grid codes, the EGAT Grid Code of 2012 inherits some structural similarities from the Irish
grid code, but in this case content and wording differ drastically, implying a separate development with merely
some inspiration from the Irish document.
The EGAT grid code is clearly aimed at conventional generation, as evidenced by specifications for simulation
models for thermal (steam) and CCGT plants and corresponding data sheets, but there is no mention of
renewable generators. This is also reflected in the frequency control requirements, which demand an AGC
connection for automatic dispatch and secondary control as well as a speed droop for primary control, but they
do not address the further implications this would have for VRE installations (requirements to operate in delta-
controlled mode, requirement for adequate active power controls).
Interestingly enough, the EGAT requirements from 2008 (which may no longer be applicable) contain a section
on requirements for wind turbines. This exempts wind turbines from frequency control duties, requires them
to be controllable by the operator, and sets specific voltage control requirements to the Automatic Voltage
Regulator (AVR) that differ from the standard values. Moreover, this document requires LVRT of 625 ms at 15
percent voltage at the connection point. The latter requirement in particular is important. If this document is
38
no longer applicable, these requirements should be re-introduced in the EGAT grid code as soon as possible.
They may be expanded by more advanced frequency control requirements (LFSM-O immediately, delta control
and full frequency sensitivity for later) and also applied to other renewable generators connected to EGAT’s
grid, such as large-scale PV installations. Simulation model requirements akin to those for conventional power
plants should also be added.
The EGAT grid code lacks defined requirements for behaviour outside of the normal voltage range (which
could be adapted from the PEA/MEA codes, which contain such requirements). The over frequency section
requiring generators to “control frequency to below 52 Hz” implies that an over frequency output reduction is
necessary but lacks specifications thereof.
The PEA grid code is the newest and most advanced of the three grid code documents and is generally in line
with international standards of good practice. It addresses all necessary issues in sufficient detail and even
includes an LVRT requirement for units > 500 kW. The only thing it currently lacks is an LFSM-O requirement,
and it is recommended to include this and replace the “must trip at over frequency” requirement in the next
version with it. It is advisable for both MEA and EGAT to study the PEA grid code and streamline their own
documents with it. However, as mentioned in section 3.2.4 on the Malaysian grid codes, fixed generation
penetration limits for the distribution grid (that are part of the PEA code as well) have been proven to be an
unnecessary barrier to renewable integration in other countries. These should be replaced with requirements
for more detailed studies at high penetration levels.

The EGAT grid code specifies the connection process at a very high level only. The document is aimed at
large conventional generators, thus a reliance on bilateral negotiations for each connection was apparently
deemed acceptable by EGAT. The documents that are to be supplied by the developer to EGAT before
and after the signing of a PPA are specified in annexes to the code, but no further detail on application and
approval are given. The procedure for the final connection, after completion of the installation, is given in
slightly more detail with some time limits. However, for the further opening of the market to renewables, a
more clearly defined process with timetables should be included. The older 2008 EGAT guideline contains a
brief section on application and connection as well as an application template but is not very specific on the
subject either.
The PEA grid code is rather nonspecific on the application and connection process, simply stating that a) the
developer has to submit the technical specifications of the installation according to templates provided before
connection, and b) PEA will assess the connection request for feasibility on technical grounds. Moreover, a
number of compliance tests are specified for the commissioning phase (see section 3.3.6). The MEA grid code
was not made available in English, but it is assumed that the regulations there are not any more specific.
A fast track application and connection procedure is addressed in the ERC Solar Rooftop Regulation. This
is only applicable to VSPP using rooftop PV. Installations are being tendered until a fixed target capacity is
exhausted. The regulation focuses strongly on the specifics of the power purchases between MEA and PEA
and the VSPP and contains all necessary templates for application but does not have a time schedule. It
states rather nonspecifically that:
To be in order, the Power Distributor shall manage upon the received applications in a manner as deemed
necessary and appropriate.
This leaves the connection process completely open to the utility.

Generally, the Thai grid codes lack clearly defined application and connection processes, which may become
a barrier to renewable energy development. This issue should be addressed as soon as possible.
39
As the newest and most advanced grid code document, the PEA grid code contains specifications of
compliance tests for generators to be connected to the PEA grid. For inverter-based generation, there is a
list of laboratory type tests (see Table 9) and detailed descriptions of the parameters of each test, as well as
a requirement for field testing of each unit (anti-islanding, load rejection and recovery tests, power quality
measurements). The lab type tests have to be carried out only once, and after a successful test the unit type is
approved and can be freely installed. The test must be carried out by the PEA laboratory, or alternatively PEA
can, after inspection, approve test results from other parties. There is no clear guideline PEA have to follow for
approval or disapproval of a third-party certificate, and this is recommended to be added in future revisions.
Unfortunately, the PEA does require compliance for all generator types, but does not specify compliance
mechanisms for non-converter based generators. These should be added and kept in line with the converter
compliance test mechanisms, which are largely in line with international standards of good practice. Moreover,
the consequences of non-compliance are not sufficiently clear, and units will probably not be allowed to
connect. The code should also include provisions for repeated testing and a clause that PEA may disconnect
generators if they can be proven to be non-compliant at a later point in time, as well as conditions for
reconnection after such a measure.
Table 9:
Laboratory type tests required by PEA for grid code compliance of converters.
No Test Topic Evaluation Procedure
1. Active Power Control Topic No. 12.1
2. Reactive Power Control and Methodology Topic No. 8.1.2
3. Under/Over frequency protection Topic No. 8.2
4. Voltage Fluctuation Topic No. 8.3
5. Harmonics Topic No. 8.4
6. DC Supply Topic No. 8.5
7. Low Voltage Ride Through Topic No. 12.2
8. Under/Over voltage Prevention Topic No. 12.3
9. Anti-Islanding Topic No. 12.4
10. Response to Utility Recovery Topic No. 12.5
The EGAT Grid Code prescribes no details for commissioning tests, but it authorises EGAT to request
compliance tests from generators at commissioning and also repeatedly during generator lifetimes. This is
a necessary but not sufficient requirement. To ensure equal treatment of generators, a list of commissioning
tests should be defined. EGAT could consult the requirements in PEA’s grid code here.
40
3.4 Comparison between the Grid Codes of Indonesia, Malaysia, Thailand, and
International Good Practice
Table 10 summarizes the collected information about the three different countries about organisational
structures and requirements involving grid code development and compliance and compares them to
international good practices.
Table 10:
Structural comparison, connection processes and compliance.
International
Indonesia Malaysia Thailand
good practice
Three privately owned State owned, vertically
Single state owned
vertically integrated utilities, integrated utilities for
Organisational vertically integrated
marginal market with single transmission, rural and urban
structure utility, single buyer
buyer for all generators distribution, single buyer for
for IPPs under PPA
(including IPPs) IPPs under PPA or FIT
Separate codes
Transmission for separate
Each utility issues Single code from sole utility Single code for
grid code synchronous
systems their own guidelines entire system, or
for transmission and coordinated T and
Single document, distribution D codes
Distribution Each distributor issues
additional code for
grid code their own code
RE
Code for
islands or Not yet common,
None None None
isolated but should be
systems
Responsible Utility, with some Utility with
party for documents developed regulatory
Utility Utility
grid code by the regulator supervision or
development independently regulator
Stakeholders can appeal
Stakeholder to internal panel of the
Clearly defined
involvement Clearly defined grid code transmission utility
Not defined grid code revision
in grid code revision panels
panels
revisions Not defined for distribution
codes
Connection Not defined Defined process
Loosely defined, requires
process in provided Bilateral negotiations with time
bilateral negotiations
transmission grid documents schedules for
Connection Clearly defined all loads and
Clearly defined for PV Fast track connection generators on all
process for renewable
only process for PV only voltage levels
distribution grid generators only
Connection Unclear, could be
Deep Not clearly defined Shallow
charge model interpreted either way
Default
Geographically Geographically
connection Geographically nearest Not defined
nearest nearest
point
Type Type certification
For generators < Mentioned, but not Only for inverter-based
certification for for all generators
10 MW specified generators
compliance should be possible
Commissioning Defined for
Only for inverter-based Only at lack of
tests by generators < 10 MW, All generators
generators type certificate
operator possible for all others
Periodic re-
Yes Yes Not specified Yes
testing
41
The following noteworthy differences and similarities between the different countries can be observed:
• All countries have a vertically integrated utility structure but are open to IPP generation.
• Indonesia has one utility responsible for the entire country whereas Malaysia has three. These operate
the entire system, including transmission grid, distribution grid, and large shares of generator capacity.
Thailand on the other hand has one utility for the transmission grid, connected generators, and two
different distributors.
• Indonesia and Malaysia have a multitude of different grid codes applicable to different geographical
areas and operators, while Thailand has clearly defined codes for the transmission grid and the urban
and rural distribution grids respectively.
• None of the countries have a grid code applicable to islands and isolated systems, although such
systems are present in all countries.
• In all countries, the utility is responsible for the development of the grid code. Malaysia and Thailand
have stakeholders participating and regulators supervising the process, while both of these are
lacking in Indonesia.
• All countries have defined connection processes for renewable generators to be connected to the
distribution grid, but lack such provisions for connection to the transmission grid.
• The connection charge model is either undefined or defined as a deep charge model, and both are
impractical with growing shares of renewable generation and IPP participation. The default connection
point is defined as the one closest geographically in two of the three countries. Specifications for the
deviation from this point (which is necessary in some cases) are lacking in all three.
• Type certificates are a known concept to all utilities, but these lack clear definitions and are in all
cases limited to small renewable generation.
• Commissioning tests should be mandatory for all generators, but are required only in Malaysia, while
they are only required from small renewables in the other countries.
• Periodic re-testing of grid code compliance is lacking only in Thailand.
A brief summary of the technical requirements for renewable energy generators in all three countries,
distinguished between connections to transmission and distribution grids, are given in below Table 11.
Table 11:
Technical requirements for RE. Green are recommended (up to a certain voltage level, not all requirements necessary for LV
connected RE), orange is not recommended. X = clearly defined, (X) = not fully defined, - = lacking.
Indonesia Malaysia Thailand
Requirement
Transmission Distribution Transmission Distribution Transmission Distribution
Over frequency output
- - X - X -
reduction LFSM-O
Droop control (full
X - X (X) X -
frequency sensitivity)
Remote controllability (X) (X) X - X X
Reactive power X X X X X X
Voltage control - X X - X (X)
LVRT - - - (X) (X) (X)
Fixed over frequency trip - - - X - (X)

Mandatory fast under
- X - - - -
voltage trip
Limit to RE installation size (X) (X) X X - -
Penetration limit - - X X - X
42
It is clearly observable that the grid codes in Thailand are the most advanced and compliant with international
standards of good practice to a higher degree than the codes in the other countries. The Thai codes,
especially the transmission code and the rural distribution code, include the most recommended provisions
and the least number of impractical specifications.
Credit: ASEAN Centre for Energy
43
44
45
4. RECOMMENDATIONS
4.1 Indonesia
Consolidated from section 3.1, the following general recommendations can be given for the development of
grid codes in Indonesia:
• Introduction of a grid code or at least a grid code framework for isolated systems (small islands and remote
areas), as these may benefit the most from renewable integration. VRE can generate with cheaper cost
than the diesel generators used in these grids.
• Development of grid codes for Kalimantan and Papua.
• Harmonisation of all Indonesian grid code documents so that every area has a transmission and a
distribution code with the same structure. Alternatively, a pan-Indonesian grid code could be developed, with
requirements differentiated by area where necessary and appropriate (similar to the EU network Codes).
• Power system stakeholders such as IPPs and manufacturers should be involved in the grid code
development process. The regulator should require PLN to set up a grid code panel involving the different
PLN departments as well as stakeholder representatives.
Additionally, the following requirements or lack thereof in currently applicable grid code documents present
major barriers to renewable energy (and general IPP) development and should be reconsidered:
• All grid codes lack defined fault behaviour for generators, which may endanger system stability in the future. The
introduction of an LVRT requirement for generators connected to MV and above in particular is highly recommended.
• Dedicated requirements for renewable generators only exist for units > 10 MW and are connected to the
distribution grid. Similar requirements should be developed for larger installations, especially in the wake
of current wind power development in Sulawesi.
• The renewable connection code for the distribution code currently prohibits voltage control from
generators. This should urgently be revised; new generators should be required to be able to control
voltage at the connection point. This feature may become important in the future and is an easy and
relatively cheap requirement, but may be expensive to retrofit later.
• Clear application and connection processes for IPPs should be defined and described in the grid codes.
• The question of shallow vs. deep connection charge is currently not sufficiently addressed by the grid
codes. Requirements may be interpreted either way. Shallow connection charge is of the international
standard of good practice for the reasons described in section 3.1.5.
4.2 Malaysia
grid codes in Malaysia:
• Introduction of a grid code or at least a grid code framework for isolated systems (small islands and remote
areas), as these may benefit the most from renewable integration. VRE can generate at a cheaper cost
than the diesel generators used in these grids.
• Analyse and update of the Sarawak grid code.
• Harmonisation of all Malaysian grid code documents so that every area has a transmission and a
distribution code with the same structure. A pan-Malaysian grid code may be difficult due to different
utilities in different areas but could also be achieved (Germany has common codes for four TSOs as well).
• Renewables are currently limited to < 30 MW and connection to the distribution grid, except for PV
installations, which may be up to 50 MW and connected to the transmission grid. Depending on renewable
energy policy, this should be revised. A revision would incur the need for more detailed requirements
for wind generators connected to the transmission grid, which do not exist yet. Renewables (except PV
between 30 - 50 MW) are currently exempt from the transmission code, which is not feasible if they are
allowed to be connected to the transmission grid in the future.
46
• Requiring all renewables to immediately disconnect at 50.5 and 49.5 Hz is an inherently bad idea that will
dangerously jeopardise system stability at rising shares of renewables. This must be revised immediately
and replaced with a requirement for over frequency power reduction.
• All grid codes lack defined fault behaviour for generators, which may endanger system stability in the
future. The introduction of an LVRT requirement for generators connected to MV and above in particular is
highly recommended.
• The codes currently prohibit voltage control from small generators (< 5 MW). This should urgently be
revised. New generators should be required to be able to control voltage at the connection point. This
feature may become important in the future and is an easy and relatively cheap requirement, but may be
expensive to retrofit later.
• Compliance mechanisms exist but should be more detailed. Type tests for renewables should be
introduced to save the resources that would be required to field test every single installation.
• The codes applicable to distribution grids set fixed limits on the generator penetration on distribution
feeders which are intended to prevent reversed power flows. Reversed power flows can negatively impact
system operation but are not inherently dangerous. A fixed limit is a severe barrier to the development
of decentralised renewable energy. The limits should be replaced with a requirement for more detailed
connection studies if generation penetration crosses a certain threshold.
4.3 Thailand
grid codes in Thailand:
• The PEA grid code (provincial distribution grids) is the newest and most advanced applicable grid code.
The next reviews of the EGAT transmission code and the MEA (urban) distribution code should aim to
streamline those codes with the PEA code.
• Power system stakeholders such as IPPs and manufacturers should be involved in the grid code
development process. The regulator should require PEA and MEA to set up grid code panels involving
MEA, PEA, and EGAT as well as stakeholder representatives. With rising shares of renewable generation
in the distribution grid, the involvement of EGAT as the power system operator is crucial.
• The analysed version of the EGAT transmission code is completely geared towards large conventional
power plants and lacks requirements for renewable energy. According to information provided by GIZ, the
newest iteration (from 2017) re-introduced requirements for renewables, which were already present in the
2008 code.
• The introduction of mandatory over frequency output reduction for all generators should be considered for
all grid codes. Currently, the requirement for large conventional generators exists but is very unspecific,
while renewables must trip at 47 and 52 Hz. The latter is less dangerous than the provisions in the
Malaysian grid code, as the trip frequencies are far away from the normal operational frequency but should
nonetheless be reconsidered.
47
4.4 International / ASEAN
Currently, the regulatory environment for renewable energy in the AMS in general and in Thailand, Malaysia and
Indonesia in particular is made up from a variety of different documents, making it as a challenge to navigate
for developers. All power system stakeholders would profit from a harmonisation of grid code documents, but
the process needs to start within each country. Thailand, largely a single synchronous system, possesses a
consistent grid code framework, but the codes in Malaysia and Indonesia are splintered into a multitude of
different documents for different operators (Malaysia) and different synchronous systems (both). Streamlining
these documents into a single national framework would be a first step towards better code applicability.
Most of the power utilities in ASEAN are state owned with single buyer market environment. The power
utilities are responsible for grid code development with or without supervision of a regulator depending on
each country’s legislation. Grid codes are developed based purely on practical experience and thus reflect the
current grid conditions. Thus, the code of the Thai Provincial Electrical Authority (PEA) is the most advanced
code as PEA has already connected a significant share of renewable generation to their network in the past
decade, while other countries and operators lag far behind. Communication between different utilities, sharing
of experiences, analysing international experience, and good practice and developing grid codes with a look
into the future are a new concept to most operators, but should be highly encouraged. As there is a dire need
for revisions in most grid code documents in the region, it is recommended to set up an ASEAN grid code
committee with the involvement of the power utilities, operators, and regulators within ASEAN as a platform to
share experience and knowledge for initiating the harmonisation of grid codes.
A special case deserving additional attention is grid codes for small isolated power systems. Many countries
in the ASEAN, the foremost being Indonesia and the Philippines, are island nations with a multitude of mini-
grids mainly powered by diesel gensets. With the high cost of electricity from diesel generation, these grids
will profit from cheap renewable generation first, but also impose a set of unique integration challenges.
While some high-VRE islands have existed for at least the last 20 years, most of these were pilot
installations that came at high effort and cost. The large-scale development of high-VRE island systems is
just starting out, and the ASEAN region with its many islands may be at the forefront of this development.
It is therefore highly recommended to set up an international body or enhance the existing association/
organisation in the region dealing with mini-grid integration issues. This body should also develop a grid
code framework for small island systems.
48
REFERENCES
[1] J. Suckow and J. C. Boemer, “Status of Revision of the VDE-AR-N 4105 Application Rule for the
Connection of Distributed Generation to Low Voltage Networks,” in 6th Solar Integration Workshop.
[2] VDE/FNN, “Summary of the Draft VDE-AR-N 4120:2017-05,” no. Mai, pp. 1–3, 2017.
[3] VDN - Verband der Netzbetreiber e.V., “TransmissionCode 2007: Network and System Rules of the
German Transmission System Operators.” 2007.
[4] IRENA, “Scaling Up Variable Renewable Power: The Role of Grid Codes,” in 6th Solar Integration
Workshop, 2016, pp. 1–106.
[5] EU Commission, “EU Network Codes for Electricity.” EU Commission / ENTSO-E, Brussels, 2018.
[6] Nordel, “Nordic Grid Code 2007,” vol. 2007, pp. 69–74, 2007.
[7] Ewea, “Generic Grid Code Format for Wind Power Plants,” Interface, no. November, p. 27, 2009.
[8] S. Wachtel et al., “Fault-ride-through requirements for wind power plants in the ENTSO-E network code
on requirements for generators,” IET Renew. Power Gener., vol. 9, no. 1, pp. 18–24, 2015.
[9] T. Ackermann, N. Martensen, T. Brown, P.-P. Schierhorn, F. G. Boshell, and M. Ayuso, “Scaling up
variable renewable power : The role o f grid codes,” 2016.
[10] S. H. W. P. Yudha, “Can Indonesia Reach 23 % Renewable Energy By 2025?,” GlobeAsia, Jakarta,
2017.
[11] EirGrid, “EirGrid Grid Code, version 6,” 2015.
[12] R. Ogiewa and M. Fischer, “The Underestimated Relevance of Wind Turbine Fault Ride Through,” in
16th Wind Integration Workshop, 2017, vol. 7, no. 2010, pp. 687–691.
[13] J. Lehner, “Necessary Time Response of LFSM-O to Ensure Frequency Stability in the ENTSO-E
Continental Europe Synchronous Area,” in 15th Wind Integration Workshop, 2005.
[14] R. Pacudan, “Electricity Price Impacts of Feed-in Tariff Policies: The Cases of Malaysia, the Philippines
and Thailand,” Darussalam, Brunei, 2014.
49
Credit: GIZ
50
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REPORT ON

ASEAN GRID CODE

ACE Building, 6th floor

Maria-José Poddey Dr. Sanjayan Velautham

2. Grid Codes and Interconnection International Standards............................................................................. 16

3. Grid Codes and Interconnection Standards in the ASEAN............................................................................ 20

1.1 Background and Objective

1.2 Introduction to Grid Codes

1.3 Relationship Between Grid Codes, Policy and Project Development

2.1 EU Network Codes

The code families

Connection Operations Market

Entered into force Awaiting entry into force

2.2 Other International Harmonisation Efforts

Credit: Powergrid Asia/GIZ

Credit: GIZ/Dirk Ostermeier

 Sumatera Grid  PLN; state-owned power

 ERC: Energy Regulatory

 PEA: Provincial Electricity

 SPP: Small Power

 VSPP: Very Small Power

3.1.1 Power Markets

3.1.2 Applicable Grid Code Documents

3.1.4 Requirements for Generators

3.1.5 Connection Process

The transmission grid codes specify the following:

3.1.6 Compliance Mechanisms

3.2.1 Power Markets

3.2.2 Applicable Grid Code Documents

• Guidelines on Large Scale Solar Power Plants for

3.2.3 Grid Code Development

According to the code, the panel shall include:

3.2.4 Requirements for Generators

Requirements for Generators

3.2.5 Connection Process

Start 1. Prepare documents

Technical Process PSS 1. Pay fees

Asset Management TNB (RE) RE Developer

Approval by Issue of Developer

Sabah/Labuan Evaluation criteria

3.2.6 Compliance Mechanisms

3.3.1 Power Markets

Transmission EGAT (100%)

3.3.2 Applicable Grid Code Documents

3.3.3 Grid Code Development

3.3.4 Requirements for Generators

3.3.5 Connection Process

This leaves the connection process completely open to the utility.

Voltage control - X X - X (X)

LVRT - - - (X) (X) (X)

Fixed over frequency trip - - - X - (X)

Credit: ASEAN Centre for Energy

This publication is supported by:

A joint cooperation between:

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