Volume 01

Issue 01 (Jul 2018)

Issue 02 (Oct 2018)

Issue 03 (Jan 2019)

Issue 04 (Apr 2019)

Volume 02

Issue 01 (Jul 2019)

Issue 02 (October 2019)

Comments

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  Volume 01 Issue 01 (Jul 2018)

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  Offshore Wind

  • Competitive bidding for offshore wind should be the only basis for its development
  • Cost of dedicated transmission line from offshore pooling station to the CTU/STU network can be supported by viability gap funding from the corresponding Regional Deviation Pool Account Fund. A specific normative amount should be pre-specified in the bid document
  • NLDC should, in cooperation with IMD and NIWE, set up a dedicated centre for monitoring and forecasting of generation

  Amendments to Tariff Policy, 2016 (Draft) released by Ministry of Power

  • The tariff principles should emphasise competition and efficiency in the sector
  • To optimise power purchase cost, trade of un-requisitioned power, separately for peak and off-peak hours, should be promoted through competitive bidding
  • SERCs should have the flexibility to adopt more stringent operational and financial norms than those laid by CEA/CERC. Operational norms should be delinked from past performance
  • MYT Regulations should continue to provide for sharing of benefits from performance improvement of utilities
  • A regulatory framework for demand forecasting and efficient power procurement planning should be adopted
  • To manage the underutilisation of generation capacity resulting in un-requisitioned surplus, the policy should provide for intra- and inter-regional reassignment/swapping of capacity under existing PPAs by DISCOMs
  • Adoption of RECs as a tool for RPO compliance would deepen the REC market
  • TOD tariff should be adopted for EV charging by all consumers. A separate category may be created for EV charging stations
  • Reliability-based tariff and TOD tariff should beimplemented for consumers with load above 10 kWacross all consumer categories
  • Direct benefit transfer, which would not only help reduce the subsidy burden of the State Government but also address inefficient consumption, should be implemented in a transparent manner
  • Deployment of smart energy meters should be based on a cost-benefit analysis and follow an implementation strategy targeting large consumers in a stratified manner. Prepaid meters must be mandated for defaulters and temporary users
  • Distribution utilities should adopt a bottom-up approach by setting distribution transformer level AT&C loss reduction targets

  Terms and Conditions of Tariff Regulations (Consultation Paper) by CERC

  • Incentive on early completion of project should be replaced with penalty for delay as the currentframework places additional burden on consumers but allows full recovery of ROE even in case of delayed projects
  • Benchmarking of capital and operating costs should be based on best national and international practices
  • Technical minimum operating capacity and heat rate compensation for operating below normative level should be fixed based on a certified third party assessment
  • Allowable ROE should be periodically revised as per appropriate risk evaluation approach

  Deviation Settlement Mechanism and Related Matters (4^th Amendment) Regulations, 2018 (Draft) by CERC

  • Area-specific Market Clearing Price (MCP) can be used for differentiated DSM price vector in the case of market splitting.
  • The ultimate goal should be a vibrant ancillary services market that renders DSM 'irrelevant'
  • The resultant short-term spurt in price vector may need to be smoothened by migrating gradually from the existing deviation price to ACP in a period of 6 months or so
  • Effectiveness of an inter-state DSM needs to be supported with an analogous and effective intra-state ABT regime that should also be reflected in RE deviations
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  Volume 01 Issue 02 (Oct 2018)

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  Additional Draft Amendments to Tariff Policy, 2016 Simplification of Tariff Categories and Rationalization of Retail Tariff by Ministry of Power

  • In a DBT regime as proposed in the draft amendments to Tariff Policy (May, 2018), low tariff for lower consumption categories should be done away with, else it will diminish the efficacy of DBT
  • The proposed amendments should mandate time-ofday (ToD) tariff for consumers with load above 10 kW (to be further reduced to 5 kW gradually), with appropriate metering
  • ToD-based or dynamic tariff should be adopted for all consumers with smart meters to harness their potential especially to manage their electricity demand
  • A detailed impact assessment of the proposed tariff categorisation on revenue realisation by utilities, and consumers' bills should be undertaken
  • Reliability-based tariff should be implemented in place of proposed 24×7 electricity supply mandate. Moreover, the 24×7 supply clause leaves room for interpretation without relating it to the 'demand' (contracted/sanctioned load) of the consumer
  • Penalty for exceeding sanctioned load should be at least twice the fixed charge on additional load for encouraging consumers to get their sanctioned load revised

  Central Electricity Regulatory Commission (Planning, Coordination and Development of Economic and Efficient Inter-State Transmission System by Central Transmission Utility and Other Related Matters) Regulations, 2018 by the Central Transmission Utility(CTU)

  • Transmission planning should also consider the expected impact of cross-border electricity trade
  • Impact of technological disruptions, on account of uncertain demand for EV charging, smart-grids and storage should also be taken into consideration
  • Integration of renewable energy resources characterised by intermittency and uncertainty necessitates advances in planning and operation of electricity grid to minimise the adverse impacts of significant variations in RE generation
  • Disaster management and recovery planning strategy must be in place to reduce the impact of unforeseen events

  Amendment of RSPV (Gross & Net Metering) Regulations, 2015 (UPERC Concept Paper) by Ministry of New and Renewable Energy (MNRE)

  • Solar power banking can have adverse impact on the finances of DISCOMs and on system scheduling. However, a ToD provision for both injection and drawl can help ameliorate such impacts
  • RSPV installation process should be implemented through an online portal to facilitate its speedy adoption
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  Volume 01 Issue 03 (Jan 2019)

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  Regulatory Guidelines and Standards for Electric Vehicle Charging Infrastructure by Ministry of Power (MoP)

  • The rigidity of the area grids (3 km × 3 km or 25 km × 25 km) for installation of EV charging stations is undesirable. The choice of grid size or distance for setting up PCS should be flexible and based on feasibility studies, considering EV clustering, travel patterns, availability of parking space, vehicle characteristics, economics of ridership, etc. Existing parking stations at public and semi-public places should be identified first for setting up PCS under publicprivate partnership (PPP) framework. This would help avoid high incidence of land cost in initial phases
  • EV charging roll-out strategy should be flexible and account for expected growth in EV population, capacity of onboard battery, feasibility of battery swapping, ridership, availability of space, etc. It should also be compatible with EV roll-out across vehicle user segments, cab aggregators, food delivery services, postal services, and other logistic services with a predictable range of travel
  • A study by IIT Kanpur evaluated business models for EV charging infrastructure for two highways and a metropolitan city. The study suggested that bidding parameters based on Viability Gap Funding (VGF) may be used for setting up EV PCS under PPP framework. Furthermore, it was also found that the absence of time-of-day (ToD) based tariff may significantly alter the demand profile in future
  • Competitive bidding-based PPP framework using VGF as a bidding parameter should be used for setting up EV infrastructure
  • Tariff (including ceiling tariff) for EV charging should be a part of Tariff Policy. Moreover, EV charging, especially for PCS and fast private charging, should be a separate consumer category with ToD-based tariff to ensure that such infrastructure does not adversely affect the load curve in future
  • A separate tariff category for EV charging infrastructure would facilitate determination of tariff by ERCs and maintaining a database of PCS. This would also provide for innovation in tariff design, especially ToD tariff
  • The identified State Nodal Agency should facilitate setting up of EV charging infrastructure under PPP framework instead of taking charge of setting up such infrastructure using public funds
  • Automobile agencies or industry associations also play a constructive role in the preparation of an integrated and phased development plan for EV charging infrastructure
  • Requirement of amenities should be applicable for EV charging stations located on highways. For urban locations, adequate amenities may be made mandatory for PCS with large charging infrastructure

  National Wind-Solar Hybrid Policy by Ministry of New and Renewable Energy (MNRE)

  • A hybrid system would improve the overall power generation profile as wind and solar generation profiles can complement one another, moderate the overall variability and economise the CAPEX accounted, thus making it more conducive for grid integration
  • However, resource intensity for a given or prospective project site may not be optimal for both wind and solar simultaneously, leading to compromise in efficiency. Thus, availability of project sites with optimal wind as well as solar energy might pose a challenge for deploying hybrid systems
  • A mechanism for apportionment of RPOs and RECs into solar and non-solar needs to be designed. Apportionment of scheduling of power in case of separate PPAs for solar and wind also needs to be addressed, especially for existing plants to be hybridised. This can be done:
    • ☼ As per the Agreement between the two parties of the PPA
    • ☼ As declared by the generator
    • ☼ By adopting normative generation schedule
    • ☼ By installing separate transformers and metering infrastructure
  • Each of the above methods has its own shortcomings. For instance, provision for separate metering/transformer would dilute the economic gains of hybridisation
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  Volume 01 Issue 04 (Apr 2019)

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  Key Features of Central Electricity Regulatory Commission(Cross Border Trade of Electricity) Regulations, 2019

  • Coordination between system operator and transmission utilities of the interconnected countries, specifically for the grant of short-term, medium-term and long-term open access, needs to be ensured so that two nodal agencies do not end up giving uncoordinated open access for the same interconnection up to the pooling stations of the respective countries
  • Provisions for determination of tariff for import of electricity in the case of hydro projects located in neighbouring countries need to be clarified in the context of small projects, multiple projects, and less than 100% allocation of a single or multiple hydro projects. The role(s) of intermediaries (like traders) may also be specified
  • Scope and modalities of dispute resolution, including arbitration, may be pre-specified to avoid conflicts thereafter. For example, in case a legal recourse has been resorted to by any of the affected parties of their respective country, either or both of them getting a favourable outcome may complicate the dispute resolution process unless modalities of arbitration are able to address this beforehand
  • It is not clear as to which International Arbitration Centre (IAC) is referred to in the regulations, as such IACs are located within India as well as in other locations like Singapore, Hong Kong, London, etc
  • In the case of CBTE, taxes, duties, etc. may be applicable both within the exporting as well as the importing entity. However, Section 30(3) refers to those applicable within India only
  • The regulations are designed from the Indian perspective – for both import and export of electricity. However, regulatory provision for ‘transit’ of electricity needs to be detailed out as well
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  Volume 02 Issue 01 (Jul 2019)

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  Delhi Electricity Regulatory Commission (DERC) (Group Net Metering and Virtual Net Metering for Renewable Energy) Guidelines, 2019

  • Group/Virtual Net Metering guidelines, while being beneficial to consumers, would provide further impetus to the harnessing of RE resources
  • The scheme could be made more attractive by allowing REC credits in lieu of net RE injected to the grid. These could be accumulated and later sold through the registered members of the power exchanges
  • Key features of the scheme, particularly sharing of RE credit, should be facilitated through online mode. Further, participation of consumers with respect to RE sharing can be authenticated through consumer's registered mobile number
  • The guidelines should provide for the determination of incremental cost for replacing a partially or fully depreciated meter, and for writing off a meter which has completed its useful technical life
  • For consumers with ToD meter, provision for moderating surplus units should be replaced with ToD based price
  • Peak, off-peak and normal hours should be clearly defined. Given the dynamic nature of system demand profile, seasonal definition for the same may also be adopted
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  Volume 02 Issue 02 (Oct 2019)

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  Pradhan Mantri Kisan Urja Suraksha evem Utthan Mahabhiyan (PM KUSUM)

  • Use of agricultural land for setting up of solar modules (on stilts) in arable land would either lead to encourage unabated conversion of arable land affecting local employment for agricultural labour and long term food production.
  • Farming activity cannot be effectively continued on the piece of land, used to deploy solar panels (even on stilts). Shadow from fruit plantation would also reduce CUF over the lifetime of the solar plants. These land selections should ensure minimal loss of arable land. GPS boundary marking of the site could be mandated to avoid such land conversion.
  • DISCOM to publish substation-wise data on location (including GPS), unique asset number, total capacity, available surplus capacity, capacity allocated for REPP, including details of plant location, plant size, date of application, date of LoA, status of EMD & PBG post 30-day limit after LoA and actual date of deposit EMD & PBG, date of installation, date of synchronisation, meter ID etc.
  • In case the feeding substation is not repaired within the time limit set under SoP, approved by respective SERC, the RPG should be paid for deemed generation of power based on suitable norms for that area.
  • The enforceability of minimum CUF 15% is questionable as the guidelines do not specify the repercussion of failure to do so. Also, radiation level for identifying low solar radiation zones should be predetermined as the respective SERC may decide levelised tariff otherwise investment for setting up plants in such zones would be inefficient as well as uneconomical.
  • It should be specified whether EMD/PBG will be applicable on pro-rata basis in case of part MW capacity.
  • The procedural complexity particularly in the context of PPA, EMD, PBG and PBI needs to be minimized for the farmers/cooperatives/panchayats/FPO/WUA, who would face significant transaction cost in dealing with multiple offices located in urban/semi-urban centres.
  • The mechanism for enabling replacement of owned/rented diesel pump sets needs to be clearly enunciated.
  • Given the poor financial state of most of the DISCOMs across the country, payment of PBI should be implemented under a direct benefit transfer scheme on monthly basis.
  • A large number of states provide rotational power supply to farmers primarily during night hours ensuring adequacy of supply as well as cheaper cost of power purchase. Ensuring the must run status to REPP by keeping feeders ON during day time, in the near term, would impose additional day time system load for which the DISCOM may have to undertake relatively costly power procurement. Presence of single REPP would force the DISCOM to keep the feeders ON during day time, which may not be feasible as feeder separation has been implemented by most states allowing curtailment of power during the day.
  • Most small and marginal farmers may not use micro irrigation system.
  • Process of sanction and implementation of the scheme should be streamlined by the respective State Nodal Agencies for RE through a web-/mobile- based system.

  UPERC Captive and Renewable Energy Generating Plants(CRE) Regulations, 2019

  • DISCOMs' concern for the value of banked and drawn power has been addressed adequately by implementing ToD based drawl against banking of energy. Given the reduction in risk exposure of DISCOMs, banking charges may be reduced. Dispatchable RE (excluding solar and wind) should be subjected to same, if not lower the banking charges.
  • Seasonality of banked energy should also be considered for drawl if power banked during surplus months is to be drawn during high demand months.
  • The upper limit of 2/kWh rate for purpose of unutilised banked power by DISCOM, though appropriate for solar and wind, is low in case of SHP and MSW plants and may be appropriately revised.