The Honourable Madhya Pradesh Electricity Regulatory Commission (‘MPERC’) published its order for the first amendment of Forecasting & Scheduling regulations, and for approving the operational procedures in MP.

Executive Summary

  • The key contention of generators and QCAs in MP was that DSM was implemented even before the “Detailed Procedures” were approved by the Commission. Clause 6.5 of the regulations had required that:

“The plan for data telemetry, formats of forecast submission and other details in this regard shall be provided in the Detailed Procedure to be prepared by SLDC and approved by the State Commission

Since approved procedures were not available, it was also requested that DSM charges be waived off till approved procedures are provided by the Honourable Commission.

  • In the recent order, MPERC has approved the procedures and provided them as part of the order. 
  • However, the order is silent on the waiver of past DSM pertaining to the period prior to approved procedures being available. Our interpretation of the current order is that past DSM charges will be payable by generators. 
  • Several states have waived, extended or given concessions in past DSM charges where generators or QCA’s had faced issues or problems.
  • Other points in the order:

    • The Order says that intra-day revisions are to be restricted to 16 revisions in a day at an interval of 1.5 hrs (in line with CERC guidelines). Earlier, there was no restriction on the number of revisions.
    • Detailed requirements for metering, AMR installation and meter readings provided. Till AMR is fully in place, meter readings to be done on a monthly basis.

     

    • MPERC has asked QCA’s to submit payment security in the form of Bank Guarantee towards the settlement of DSM charges. Payment security has to be provided for Solar at Rs.10,000/MW and for Wind at Rs. 40,000/MW.

     

    • Various other clarifications have been provided on procedural matters.

    Waiver of DSM charges prior to amendment order:

    As mentioned above, since approved procedures were not available, generators and QCAs requested MEPRC that DSM charges be waived off till implementation procedures are approved. However, the current order is silent on the waiver of past DSM. 

    The following are examples of the approach taken by other states where generators or QCA’s faced issues or problems in the implementation of F&S regulations.

  •   Rajasthan: Decisions on payment of DSM by RERC:
  • In Maharashtra, MERC has granted additional time for commercial implementation of DSM – to be effective from Jan 1, 2020. 
  • In Tamil Nadu, SLDC has already requested TNERC to commence commercial implementation from 1.04.2020 and the mock implementation is commenced from 1.01.2020 to  31.03.2020.