Must-run or merit order despatch?

The proposed regulations from the Madhya Pradesh state electricity regulator (draft regulation) has brought the debate of merit-order vs must-run for Renewable Energy (RE) projects to main stream yet again. Incidentally, the draft National Energy Policy (NEP) proposed by NITI Aayog hints at withdrawal of must-run status for RE in the long run leading up to 2040( Read Why NEP is missing the big picture?). The draft NEP also proposes to withdraw other RE oriented benefits like non-levy of inter-state transmission charges.

Indian Electricity Grid Code (IEGC)

” All renewable energy power plants, except for biomass power plants, , and non-fossil fuel based cogeneration plants whose tariff is determined by the CERC shall be treated as ‘MUST RUN’ power plants and shall not be subjected to ‘merit order despatch’ principles”.- IEGC, 2010

The point of debate will be, are the current solar and wind tariffs determined by CERC for this regulation to hold good?

The 4^th amendment of IEGC in 2016 brings back the discussion on ‘Merit order despatch’ however, it is only referenced to highlight the need from a technical minimum operation of thermal power plants.

The proposed amendment to the MP state government order on ‘Cogeneration and Generation of Electricity from Renewable Sources of Energy’ proposes, “The generation from Co-generation and Renewable Sources of Energy shall be subject to “Scheduling” and “Merit Order Despatch Principles” as decided by the Commission from time to time.”

The NREL study ‘ Greening the Grid’ clearly argues for a case of must-run for renewable energy projects or to radically shift to a merit-order despatch that considers production costs and not tariffs. The variable costs of existing fossil fleet is less considering they are paid an annual fixed availability cost. The study further recommends having an limit on annual curtailment hours embedded in the PPA to protect RE developers.

RE curtailment in 2022 could be between 8-16GW. (NREL)

What is required?

Merit order at regional & national level based on production costs and not just variable tariffs!

Regional coordination of resources will result in low variable cost resources from one state to displace expensive generation in other states. It is likely to happen considering a large part of recent ‘record-breaking’ renewable energy projects are slated in to come only in a few states in India. The NREL study concludes that having merit-order with scheduling and despatch optimized at regional and national level could result in a savings of 2.8% (₹ 6300CR) and 3.5% (₹7800CR) respectively by 2022 under the 175GW RE scenario.

Policy makers should envisage an alternate to merit-order despatch that is based on production costs and not just variable tariffs which will boost the confidence of RE developers who currently hedge their financial risks to anticipated curtailment.

National Energy Policy: India

NITI Aayog recently released the draft National Energy Policy (NEP) for public consultation. The NEP has been a work in progress for nearly 2 years. The NEP once finalized will replace the Integrated Energy Policy formulated by the erstwhile planning commission in 2008.

The objectives

• Develop a long term road-map (up to 2040) to provide clarity to all concerned stakeholders.
• Energy access at affordable prices
• Improved energy security and independence
• Promote sustainability
• Foster economic growth

Considering the NEP is being drafted at a time when India’s ambitious energy targets for the short term are underway, it tries to unify the objectives of 175GW of Renewable Energy (RE) target by 2022, 24×7 Power for All for 2022 and 100 smart cities by 2022. The NEP also reigns in the objectives from India’s Nationally Determined Commitments (NDC) to the Paris climate deal (know more) of 33%-35% emissions intensity reduction by 2030 in comparison to 2005 levels and non-fossil fuel based energy capacity increase to 40% by 2030. Not to forget, the vision of 100% Electric Vehicle (EV) fleet by 2030.

Analysis and outcomes

NITI Aayog’s approach to the planning is noteworthy considering the use of energy modelling tool, India Energy Securities Scenario- 2047 where the supply and demand scenarios of Business As Usual (BAU) and NITI ambition for 2040 is simulated.

• Gross Domestic Product (GDP) to grow at around 8% up to 2040.
• Energy demand (across sectors) to grow from 4926 TWh (2012) to 13,192-15,820TWh by 2040.
• Share of electricity in energy demand to be 23.2%-26.1% (2040) from 16% (2012).
• Energy demand will increase 2.7-3.2 times by 2040.
• Per capita electricity consumption to increase from 887kWh (2012) to 2,911-2,924kWh in 2040.
• Installed coal based generation capacity to grow to 330-441GW by 2040 from 192GW in FY 17.
• RE generation capacity to reach 597-710GW in the same period.
• Nuclear power generation capacity expected to increase from the current capacity of 6.7GW to 22.48GW by 2030.
• The RE capacity is expected to account 50%-56% of total capacity by 2040.

Key policy recommendations

NEP, as expected recommends a slew of policies for RE projects, fuel sourcing, air quality and energy technology and Human Resource Development (HRD).

• Gradual withdrawal of ‘must-run’ status and other supports such as non-levy of inter-state transmission charges for RE projects.
• Cross-subsidy bill should be equally shared between industrial clients and large domestic consumers in the short term and totally removed by 2040. (If reforms like UDAY are successful!)
• EVs and energy storage are emerging technologies and should be suitably incentivised through time of use tariffs and related policies.
• Accelerated Depreciation(AD) and Feed-in-Tariffs (FiT) are appropriate tools to drive RE growth in the near term.
• Need to redefine the concept of ‘Electrification’ in electrification programmes like DDUGJY.
• Coal will be phased out as declining energy storage costs is making variable RE viable.
• Efficient use of Direct Benefit Transfer (DBT) to provide vulnerable consumers in the sector to foster ‘Equity’ and in turn sustainability.

Recommendations for meeting the ‘uncertainty’ and ‘variability’ challenges in RE integration:

• Upgrade grid technology– System operators at Central and State level to undertake the process
• Upgrade grid operation protocols– Update grid codes and shift scheduling & dispatch from 15min to 5min
• Expand balancing areas– Move from state to regional level grid operations
• Upgrade grid planning practices– Green Energy Corridors
• Balancing resources-estimation, procurement, dispatch– Ancillary services regulations

Open points

Renewable Purchase Obligation (RPO)– NEP believes RPO will be one of the major drivers for RE in the short term but doesn’t provide a road-map to what happens when RPO ceases beyond 2020-22.

Regional inter-connection– RE being geography dependent will be concentrated only in about 8-10 states. Although this is acknowledged there is a lack of clarity on how regulations could drive inter-regional capacity transfers beyond the period when non-levy of inter-state transmission charges ceases.

Must-run status– One of the recommendations is to move away from classifying RE as ‘must-run’ but little thought is given to the current state of RE curtailment in spite of being ‘must-run’.

Electric Vehicles– NITI Aayog could have provided suitable recommendations to bring energy storage under the ambit of electricity act and proposed to permit energy resale to promote development of EV charging infrastructures.

Overall, the NEP draft is a good starting point backed by suitable analysis and modeling although it misses out on making a strong policy statement. Hopefully the missing gaps in policy recommendations and road-map are plugged in due course of stakeholder consultation.

The draft document: National Energy Policy

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