Karnataka solar rooftop PV regulation

Electricity markets have always witnessed a tussle between the utilities and the regulators, Karnataka state is no different. The electricity regulator has always been among the first in the country in implementing progressive policies in the Renewable Energy (RE) sector. However, the progress of all the plans has been disheartening and in most cases it is due to lack of co-operation from the utility in the state. A case in point is the solar rooftop projects, in spite of having the highest Feed-in Tariff (FiT) of ₹ 9.56/kWh in the country in 2013, there was a lack of adoption for well over a year. The reason, Distribution Companies (DISCOMs) came up with an implementation plan nearly a year after the order.

Karnataka Electricity Regulatory Commission (KERC) has recently drafted a regulation to address the concerns of domestic residents living in apartment complexes with shared roofs and electrical connections. The proposed regulation intends to offer existing solar rooftop owners in shared roofs an option to increase their capacity and also new residents who wish to install a bigger system by aggregating the contract demand of multiple households in the building.

The proposed regulation aims to fill all the gaps existing in the current system which hinders adoption of solar rooftop system in residential complexes. The proposed tariff at Average Pooled Power Purchase cost (APPC) which is currently at ₹ 3.97/kWh for BESCOM will raise eyebrows considering the FiT is at ₹ 7.08/kWh for domestic consumers.

Will the regulations have a positive impact?

• The regulation is likely to have a positive impact because it removes the regulatory hurdle currently preventing residential complexes in implementing the system.
• Residential complexes tend to install solar as a way to reduce their energy bills and hence the type of metering or tariffs wouldn’t matter much.
• The regulation would however impact early adopters who will have to surrender their individual Power Purchase Agreements (PPA) if the complex as a whole is going for a bigger system in the common roof.

Overall, the regulation is definitely a good step but I believe there are technical challenges like metering involved in the implementation phase which only the DISCOMs can solve. I had a conversation with a regulator in KERC prior to the drafting of this regulation discussing issues related to solar rooftop in the state. He clearly admitted that at their level they can only bring in the best-fit regulation considering all stakeholders in mind but the final implementation is out of their purview. The comments to this draft regulation are open till 5^th July post that there could be a revised regulation coming up.

Check the proposed regulation:Here

Forecasting and scheduling of renewable energy in India

Karnataka Electricity Regulatory Commission (KERC) has mandated Forecasting and Scheduling (F&S) for wind and solar assets in the state with penalties for deviation from the 1st of this month. The current regulations are applicable to all wind generators with a cumulative capacity of 10MW and above and all solar generators with an installed capacity of 5MW and above.

Why need F&S?

The concern raised by the lobby of wind developers might seem justified against penalties for deviations which add to the cost of energy, but a stringent F&S mechanism will only enable the grid to accept more Renewable Energy (RE).

F&S could reduce RE curtailment

Increasing RE will lead to local and system level congestion in the existing Indian grid and it will be essential to curtail wind and solar during those periods. Curtailment generally is attributed to the grid’s inability to absorb RE generation but what goes unnoticed is the surplus generation from RE that is beyond what is forecast and scheduled leading to a shortage of grid transfer capability. A significant part of RE curtailment is in fact considered economic in that case.

Adding flexibility to the system in the long run

• Accurate F&S will lead to creating an economic system where utilities could offer tariff incentives to increase consumption during peak wind/solar generation periods.
• It could also lead to efficient use of traditional power assets.
• A better inter-state coordination in managing power demand and delivering other grid ancillary services will become a possibility. Regional co-ordination has been a key to the success of RE integration in US.

Regulatory dimension

The regulator’s objective of delivering energy at the lowest possible cost shall always remain. At times, the intermittent nature of RE has caused the thermal power plants to provide flexibility by operating at a lower PLF thereby adding to the cost of energy and not to mention associated emissions (which is against the climate commitments). The F&S regulation will enable to enforce a better grid discipline by managing congestion which will provide value to the generators in the long run.  The next step for the regulators at state level would be to narrow the deviations by reducing the band and increasing the penalties. There is also a need for synchronisation of intrastate and interstate F&S regulations for better accounting and settlement.

The F&S regulations are not new for RE in India, Indian Electricity Grid Code made provisions in 2010. The current regulations based on the proposal from CERC in 2015 have been under draft across a few states. Rajasthan, Gujarat and Tamil Nadu have even implemented F&S on a voluntary basis. Karnataka has once again led the way in official implementing a timely regulation (with penalties) although it is likely to lose again on the market to other states that come up with a better regulation like Tamil Nadu’s proposal of a narrow band of ±10% for wind and ±5% for solar. One thing for sure can be guaranteed, a better grid discipline.

Energy as a Service

In the last few weeks two big announcements caught my attention. Incidentally both of them happened to be Electric Vehicle (EV) charging stations. The first one garnered more attention because the union Minister for Roads inaugurated what was claimed to be ‘ The first public EV charging station’ in India (Nagpur). Following that, India’s largest power generating company NTPC announced its foray into EV charging stations.  Interestingly these are not the first EV charging stations, they are quite a few and in fact a website hosts a list of all such stations. Most of them are Mahindra showrooms considering they have the only 2 EV models manufactured in India.

Are we in a hurry or already late?- The missing gaps

The development in this space are encouraging but is this model sustainable or is it just a stop-gap arrangement tiding the wave of excitement in this sector? Before concluding on that here are a few open points:

• The Electricity Act (2003) doesn’t permit sale of electricity unless you are registered as a distribution licensee. In this case, the energy resale to charge batteries is categorically not allowed.
• Standards for charging stations are yet to be formalised. Public charging stations have to be compatible with a host of vehicles and chargers. Automotive Research Association of India (ARAI) has only recently finalised the standards for AC charging while the DC charging standards are yet to be announced.

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  The range of standards: Cty-IEA EV outlook 2017

• Bharat Charger: The charger for India, a DHI initiative under the vision to get an all-electric fleet by 2030 has proposed a standard for charger. The initiative is laudable considering the grand vision but we are yet to have a final specification on that.

Energy as a Service (EaaS)

In spite of having a few gaps in the system both at the regulatory and technical front it is quite interesting to see the so called ‘public EV charging stations’ springing up in the country. As in any nascent market development it could be due to either of the two reasons; there is a significant demand for these or the businesses’ are keen to be front-runners in this space. I believe it is more of the latter and a little probe into these businesses have confirmed the same. While the developed world is trying to create a market for these, India has already begun what will be called ‘Energy as a Service (EaaS)’ business model.

How else does one account the amount of electricity dispensed at these stations to charge the batteries without being termed a ‘resale’? Only the ones being setup by Tata Power Delhi Distribution could escape being termed a resale. (However the 5 stations setup by them offers charging free of cost to Mahindra vehicles). The charging stations at Mahindra showrooms are as expected, ‘free’ with the costs in built in the sale. Similarly the charging station at Nagpur is an exclusive model developed in partnership with OLA.

The EV charging stations although not a perfect model for EaaS, is a good starting point. In due course, the charging stations would start differentiating in terms of the source of power, charging frequencies, time of charging etc. which would provide customers a wide range of choice, something we have been used too in other new-age services. However, in order to create a sustainable business model, the charging stations have be to be compliant within the regulatory and technical frameworks in due course.