MoP consultation paper on Open Access

Ministry of Power (MoP) recently invited comments on a consultation paper on issues related to Open Access (OA). Electricity Act (2003) which provides non-discriminatory Open Access (OA) to all consumers for use of evacuation infrastructure has been caught up with regulatory hurdles at every stage of implementation.  State utilities who are on the losing side as consumers migrate through OA have ensured the market mechanism fails to take-off.

The MoP committee which has come up with this consultation paper has categorized the issue along the tariff structure and consumer behaviour

Frequent shifting of Open Access consumers

The argument of frequent consumer shifting is accepted to an extent considering the fact, short term Open Access clients are unable to project their load demand to utilities. The proposal calls for OA clients to schedule for power requirement 24 hrs prior to seeking OA clearance to ensure state utilities are prepared to meet the demand.

Cross Subsidy Surcharge

Cross Subsidy Surcharge (CSS) has always been a major point of debate and there have been multiple revisions to the formula that calculates this charge. Owing to an increase in OA transactions CSS charges are already high. The proposal is to limit the CSS to 20% of consumer tariff and introduce category wise CSS. The proposal also calls for CSS based on time of day, peak, normal and off-peak which is quite interesting.

Additional Surcharge

Additional Surcharges are increasing across states after every tariff revisions owing to an increased capacity of stranded assets bound by long term Power Purchase Agreements (PPA). A calculation method based on a revised definition of stranded asset (based on capacity stranded on account of OA) and amortization of assets has been proposed to remove the potential double accounting of charges to consumers.

Stand-By charges

In recent times BESCOM has charged OA clients with a high temporary tariff on account of classifying the power sold to them under stand-by charges. Although the existing regulations at the state level forbid such charges, BESCOM has incurred the wrath of OA consumers for the past few months. The proposal calls for definition of stand-by charges based on a two part tariff with the upper limit set at 125% of the consumer tariff under the category.

Tariff design and rationalisation

In the end the paper clearly acknowledges the fact, the failed two-part tariff structure has lead to the overall collapse of the market mechanism and OA. A better structured tariff structure would have limited the damage of OA shift on the state utilities. (Read more about the inefficient electricity tariff structure from an earlier post)

Overall, the paper calls for a major revamp of the OA regulations and it brings out a need to align with the recommendations in the National Tariff Policy (NTP,2016). The consultation paper has been dubbed as anti Open Access by multiple stakeholders but I see this as a frank assessment of our tariff structures and gives an opportunity to rectify the basic flaws in the existing inefficient tariff structure.

Read more: MoP Consultation Paper

 

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Will Wind-Solar hybrid projects take off?

In the run-up leading to a record installation of wind and solar projects in India 2016 saw a slew of major announcements from the Government. One of the policies that received much fanfare was the announcement of Wind-Solar Hybrid policy. However, its been well over an year and yet there seems to be no final regulation on that front.

Highlights from draft national wind-solar hybrid policy (2016)

  • Wind-solar hybrid capacity target of 10GW.
  • The policy envisages wind-solar hybrid integration at both the DC and AC side.
  • Hybridization of existing wind/solar project permitted provided the total capacity is within the evacuation limit.
  • Tariff for power generated could be FiT fixed by state regulators or discovered through competitive tariff.
  • All fiscal incentives available for wind/solar to be provided for hybrid projects.

Following up on the announcement at the national level, Andhra Pradesh (AP) released its draft wind-solar hybrid policy in 2016. AP govt. went ahead with finer definitions of capacities and other functional modalities but, there is no update on the final policy yet.

  • Target of 3000MW of wind-solar hybrid capacity by 2019-20.
  • System integration permitted in pooling sub-station or co-injection after inverter.
  • The hybrid policy also to look at other emerging technologies like energy storage systems.
  • At locations where wind density is higher, solar capacity to be lower and vice versa.
  • APTRANSCO to consider evacuation based on ampacity rather than MVA/MW connectivity.
  • No additional charges to be levied if additional wind/solar capacity is below the sanctioned transmission capacity.
  • Policy envisages both DC and AC integration. Also supports existing/allotted projects to be integrated as hybrid project.
  • Capacity split between wind and solar to be in the ratio 1:0.6 to 1:1.5
  • Wind and solar generation to be metered separately and paid based on the tariff set by state regulator for different voltage levels at project site.
  • 25 year exemption of transmission, distribution and cross subsidy charges for captive/ open access.
  • Must run status for hybrid projects. (Read more about the latest issue with must-run status)

solarAnother state, Gujarat,  released a draft version of wind-solar hybrid policy in early 2017 but is yet to be finalized. Gujarat, unlike AP lacked clarity even in the draft policy. The basic requirement of allowing wind and solar to use the same evacuation system was being challenged with metering allowed only at the pooled sub-station level. Globally, wind-solar hybrid projects have taken off pretty well (read more about a project by juwi). In India, NTPC has taken the lead role with a project ongoing near its thermal plant in Karnataka which was won by Siemens-Gamesa, 2MW wind and 1.37MW of solar. (Read more)

In order to enable large scale development of wind-solar hybrid projects, there is a need for clarity on the tariff (and metering) considering the recent low tariffs in India (More on solar tariffs in India). Power evacuation has to be on a common transmission line unlike the one proposed by Gujarat state. Its high time the regulators open up the forums for discussion on the draft policies and finalise the regulations, until then the hybrid projects are likely to stay grounded.

 

 

 

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 4th 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.

GTG

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.