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.

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.