Haryana announces its final DSM regulations for wind and solar, 2019

Haryana Electricty Regulatory Commission announced the DSM regulations for wind and solar, 2019 along with the statement of reasons recently post the draft discussion paper in 2018. The summary of the regulations is as below:

Title: Haryana Electricity Regulatory Commission (Forecasting, Scheduling and Deviation Settlement and related matters for Solar and Wind Generation) Regulations, 2019.

Applicability:

  • From the date of publication in the official gazette.
  • Levy and collection of DSM Charges shall commence after six months from the date of publication in the official gazette.

Regulation to be applicable on:

Regulations will apply to all Wind and Solar Energy Generators in Haryana connected to a particular Pooling Sub-Station, or that of an individual Generator connected to some other Sub-Station not be less than 1 MW to the Intra-State Transmission /Distribution System, including those connected through Pooling Sub-Stations, and using the power generated for self-consumption or sale within or outside the State  combined installed capacity of the Solar or Wind Generators.

Deviation Accounting: The deviation accounting will be carried out based on the Available

Capacity:- 

Point of forecasting: Pooling sub-stations and /or Intra-state transmission/distribution system.

Aggregation: No provision of Aggregation, unlike AP and Karnataka where it is allowed.

Role of QCA:

  • Meter reading and data collection and its communication, and coordination with the Distribution Licensees, the SLDC and other agencies
  • De-pooling of amount among other generators
  • Settlement of the Deviation Charges specified in these Regulations with the SLDC on behalf of the Generators.

Revisions:

  • 16 revisions to be submitted for both wind and solar generators starting from 0.00 hours of the day.
  • All the revisions are effective from the 4th time-block

Key points:

  • The Deviation Charges shall be paid within ten days from the issuance of the invoice along with a statement of account by the SLDC, failing which an interest of 0.4% per day for each day shall be levied for the period of delay.
  • In case of any curtailment communicated by the SLDC due to line maintenance or other reasons in certain time blocks of a day, the QCA shall be responsible for curtailing the generation at the site and revising the Schedule accordingly, failing which the SLDC shall revise the Schedule as required.

Inter- & Intra-state deviation settlement transactions:

  • Deviations in respect of Inter-State and Intra-State transactions shall be accounted for separately at each Pooling Sub-Station.
  • Inter-State transactions at a Pooling Sub-Station shall be permitted only if the concerned Generator is connected through a separate feeder.
  • The QCA will submit a separate schedule on behalf of the generator for its energy generation to the SLDC and the concerned RLDC.
  • The SLDC will prepare the deviation settlement account for such generator on the basis of measurement of the deviation in the energy injected and its impact at the state periphery.

Deviation Charges for Intra-state sale of power

Deviation Charges for Inter-state sale of power

Deviation charges for under- or over-injection for intra-state transmission and selling/consuming power outside Haryana

Deviation Charges in case of under-injection

Deviation Charges in case of over-injection

*The fixed rate is the PPA rate determined by the commission, in case of multiple PPAs, the fixed rate shall be the weighted average of the PPA rates.

The tentative date for the DSM charges to be levied is supposed to be six months i.e. 1st December 2019, after the regulations get notified in the Gazette.

CERC issues draft Deviation Settlement Mechanism and related matters – fifth amendment, regulations, 2019

CERC recently notified draft DSM & related matters amendments after MSEDCL, MPPMCL, & WBSEDCL filed a petition before the Delhi High Court challenging the legality & validity of certain provisions on the DSM 4th amendments, regulations 2018 which were notified in November 2018 & came into effect from 1st January 2019.

According to the petition, there were issues pertaining to the operation of clauses 7(1), 7(10) & 7(11a). Post-hearing of the petitions & examining it, the Commission proposed these amendments, the highlights of which are as below:

Issue: Sign change norms in case of sustained deviation and imposition of additional surcharge for such violation under Regulation 7(10) and 7(11)(a)

The commission in the DSM (4th amendment) regulations, 2018, provided for 6th time blocks for change of sign in case of sustained deviation in one direction. Similarly, a new proviso was added to regulation 7(10), which specifies the additional surcharges of 20% of the daily base DSM payable/receivable to be levied for each violation of sign change norms.

Post receiving comments from various stakeholders, the commission suggests creating a framework seeking to discourage the entities from leaning on the grid to meet their demand-supply gap.

Amendment – Regulation 7 (10): “In the event of sustained deviation from the schedule in one direction (positive or negative) by any regional entity (buyer or seller), such entity shall correct its position in the manner as specified under clauses (a) and (b) of this Regulation.”

(a) Up to 31.03.2020, if the sustained deviation from schedule continues for 12 time blocks, the regional entity (buyer or seller), shall correct its position by making the sign of its deviation from schedule changed or by remaining in the range of +/- 10 MW with reference to its schedule, at least once, latest by13th time block.

Provided that each violation of the requirement under this clause shall attract an additional charge of 10% on the time block DSM payable/receivable as the case may be.

(b) From 01.04.2020, if the sustained deviation from schedule continues for 6 time blocks, the regional entity (buyer or seller), shall correct its position, by making the sign of its deviation from schedule changed or by remaining in the range of +/- 10 MW with reference to its schedule, at least once, latest by 7th time block.

In case of the above violations occur additional charges will be applied as below:

No. of violations in a day Additional Charge Payable
From first to fifth violation For each violation, an additional charge @ 3% of daily base DSM payable / receivable
From sixth to tenth violation For each violation, an additional charge @ 5% of daily base DSM payable / receivable
From eleventh violation onwards For each violation, an additional charge @ 10% of daily base DSM payable / receivable

Counting of the number of sign changes violations under clauses stated above will start afresh at 00.00 Hrs. for each day.

These charges will not be applicable to:

  • Renewable energy generators which are regional entities
  • Run of river projects without pondage
  • Any infirm injection of power by a generating station prior to CoD of a unit during testing and commissioning activities, in accordance with the Connectivity Regulations.
  • Any drawal of power by a generating station for the start-up activities of a unit.
  • Any inter-regional deviations.
  • A forced outage of a generating station in case of collective transactions on Power Exchanges.

Amendment: In order to implement these amendments two new definitions have been included in Regulation 2, clause (1) sub-clause (gb) & (qa):

“(gb) “Daily Base DSM” means the sum of charges for deviations for all time blocks in a day payable or receivable as the case may be, excluding the additional charges under Regulation 7”.

“(qa) “Time Block DSM” means the charge for deviation for the specific time block in a day payable or receivable as the case may be, excluding the additional charges under Regulation 7”

Issue 2: Daily Deviation limit and the additional charge for its violation under Regulation 7(1)

The Commission has specified through the 4th amendment to DSM Regulations a daily volume limit of 3% of the total schedule for the drawee entity and 1% for the generators for deviation from the schedule in energy terms during a day. In addition to this, an additional charge of 20% of the daily base DSM payable/receivable for such violation was prescribed.

The commission is of the view, that countries like Europe & the United States of America have a very narrow range in order to ensure quality power supply to consumers and maintain good infrastructure. Similarly, it is necessary on the part of utilities to comply with the policy instructions of the government so as to secure adequate generation resources in different time zones to meet demand, rather than simply relying on the grid providers of reserves.

However, since the timeline of this implementation is not immediate, Regulation 7 (1) is deleted.

“Provided also that from a date not earlier than one year as may be notified by the Commission, the total deviation from schedule in energy terms during a day shall not be in excess of 3% of the total schedule for the drawee entities and 1% for the generators and additional charge of 20% of the daily base DSM payable/receivable shall be applicable in case of said violation.”

Issue: Clarification on the Area Clearing Price (ACP) in case of inter-regional and international exchange and clarification with respect to the applicability of cap rate for various types of fuel plants.

The Commission is of the view that DSM charges for an entity falling in different bid areas should be computed based on the daily average ACP of the bid area in which the entity has the largest proportion of its demand. Similarly, the charges for inter-regional deviation and cross-border and for deviation in respect of cross-border transactions should be computed on the basis of the unconstrained market clearing price in Day-Ahead Market.

Also, the Cap rate for the charges for deviation for the generating stations, irrespective of the fuel type and whether such generating stations are regulated by the Commission or not, will not exceed 303.04 Paise/kWh. The Commission has decided to continue with the already available reference of 303.04 Paise/kWh.

Further, it is proposed to discourage over-injection during high grid frequency, a generating station should not be paid for over-injection if the frequency is between 50.05 Hz and 50.10 Hz, and any over-injection when the grid frequency is 50.10 Hz and above, will attract the payment of DSM charges equivalent to frequency at 50 Hz or the cap rate of 303.04 Paise/kWh whichever is lower.

The public hearing for the draft regulation amendment is scheduled to take place on 22nd May 2019.

 

Tamil Nadu announces (Forecasting, Scheduling and Deviation settlement and Related Matters for Wind and Solar Generation) Regulations, 2019

Executive summary:

  • The accuracy band is narrower compared to other states and compared to the Model FOR Regulations
  • However, the per unit DSM charge is also lower compared to other regulations (in these aspects TN regulation is similar to that of Gujarat)
  • Total DSM charge is capped at Rs 0.05/unit on an annual basis
  • Aggregation is not allowed

Applicability:

  • From the date of publication in the official gazette.
  • Forecasting tool to be established in three months period.
  • Levy and collection of DSM Charges shall commence after six months from the date of publication in the official gazette.

Regulation Applicable on all Wind and Solar Energy Generators (excluding Rooftop PV Solar power projects) in Tamil Nadu

Deviation Accounting:  The deviation accounting will be carried out based on the Available Capacity:-                                                                            

Generation =  Absolute Error in % = 100 X Actual Generation –  Scheduled/ Available Capacity (AvC)

Point of Forecasting: Plants connected to the Intra-State Transmission System or Distribution System, including those connected through Pooling sub-stations, and using the power generated for self-consumption or sale within or outside the State.

Aggregation: Unlike in Karnataka and AP, Tamil Nadu’s regulation does not have a provision to provide an aggregated forecast.

Role of a QCA:

  • Meter reading and data collection and its communication, and coordination with the Distribution Licensees, the SLDC and other agencies;
  • De-pooling of Deviation Charges within the constituent Generators of the Pooling sub-station and settlement of payments/receivables.
  • Settlement of the Deviation Charges specified in these Regulations with the SLDC on behalf of the Generators.

Revisions:

  • The QCA may revise the Schedule of Generators connected to the Intra-State Transmission Network (excluding collective transactions) by giving advance notice to the SLDC.
  • 16 revisions are permitted for Generators starting from 00.00 Hrs of the All the revisions are effective from the 4th time-block.

Other Key Points:

  • The total deviation charges remitted on account of deviations by a wind / solar generators through QCA into State Deviation Pool Account (Wind and Solar) in a financial year shall be capped at the Ceiling Rate of 5 paise per unit, and excess DSM charges beyond this limit shall be remitted back to the generator.
  • Every QCA shall pay the total amount of Deviation Charges pertaining to the Pooling Sub-station to the SLDC, and collect it from the concerned Generators in proportion to their actual generation.
  • Provided that the onus of ensuring the payment of the Deviation Charges to the SLDC by the QCA shall remain that of the concerned Generators.
  • The QCA shall de-pool the Deviation Charges against each Generator in proportion to the actual generation by the generators.
  • The SLDC will share the curtailment information with the QCA id any, via an IT-enabled communication system; failing which the DSM for subsequent time blocks will not be charged by the SLDC.
  • Further, it is the QCAs responsibility to provide the correct schedule on the basis of curtailment.
  • If the QCA is unable to do so, the SLDC will change the schedule as per the curtailed values.

Important differences between intrastate and interstate transactions:

  • The deviations for Inter-State and Intra-State transactions at Pooling Station will be accounted for separately. Separate schedules will be sent for the interstate to SLDC and RLDC.
  • The Inter-State transactions will be settled on the basis of their scheduled generation and will be considered only if the Inter-state capacity is connected to the STU via the separate feeder.
  • The Generator will pay the Deviation Charges for under or over injection applicable within Telangana in case of deviations in the State DSM Pool.

Deviation Charges in case of under or over-injection for sale/supply of power within the State

Deviation Charges in case of under or over-injection for sale/supply of power outside the State

  • Deviations in respect of Inter-State and Intra-State transactions for each source of RE i.e. wind and solar Generation shall be accounted for separately at each Pooling Sub-Station.
  • The SLDC shall provide separate energy and Deviation Accounts for Inter-State and Intra-State transactions in respect of wind and solar Generation to the QCA, who shall settle the Deviation Charges with the concerned Generators.

The TNERC Regulation for Forecasting & Scheduling, 2019 has not provided a summary of timelines designating the activities to QCA and SLDC, to be accomplished within the following stipulated duration.

 

MERC announces amendments in the Forecasting, Scheduling and Deviation Settlement for Solar & Wind Generation, Regulations 2018

Maharashtra Electricity Regulatory Commission (MERC) has announced a notification in accordance with the Principal regulations MERC (Forecasting, Scheduling and Deviation Settlement for Solar and Wind Generation) Regulations, 2018. In accordance with regulation 1.2 of the principal regulations, the commission has notified that the effective date of commercial arrangement will be 1st July 2019. This has come after Commission has noted the concern raised by Stakeholders during the meeting dated 26 February 2019 regarding the short time available for implementation of the Regulations and also the submission made by MSLDC about its preparedness to rollout the Commercial Arrangement by 30 June 2019.

Further, the commission has also announced amendments in the implementation of Procedure under MERC (Forecasting, Scheduling and Deviation Settlement for Solar and Wind Generation) Regulations, 2018.

The clause 7.1 of the said Detailed Procedure specified the MSLDC fee and charges including scheduling fee and the re-scheduling fee payable by QCA to MSLDC. The said issues were highlighted by REConnect also, how the rates stated by MSLDC are exceptionally high and unfair.

A meeting was held by the commission with the stakeholders where they stated their concern regarding the high charges and how these charges are not so high in other states like Andhra Pradesh, Karnataka, Madhya Pradesh & Rajasthan.

The commission has announced the updated fees and charges related to scheduling charges, the abstract of which is as follows:

MPERC announces Amendments to the (Forecasting, Scheduling, Deviation Settlement Mechanism and related matters of Wind and Solar Regulations, 2018

Madhya Pradesh has recently announced the first amendment of the (Forecasting, Scheduling, Deviation Settlement Mechanism and related matters of Wind and Solar generating stations) Regulations, 2018. The commission has invited comments for the same till 14th March 2019. The Commission shall arrange a public hearing, if required, on 15.03.2019 at 11:30 AM at Commission’s Office.

The regulatory commission has also issued the procedure detailed the operating procedure for implementation of MPERC (forecasting, scheduling, deviation settlement mechanism and related matters of wind and solar generating stations) regulations, 2018.

The summary of the amendments in the DSM regulations are as follows:

Principal regulation

Proposed amendments

Regulation 2 (g) ‘Deviation’ in a time-block for a Seller means its total actual injection minus its total  scheduled generation and for a Buyer means its total actual drawal minus its total scheduled drawal, and shall form part of the State Energy Accounts to be prepared by
SLDC.
Regulation 2 (g) ‘Deviation’ in a time block for a Seller means its total actual injection minus its total scheduled generation.”
Regulation 2 (j) “Gaming’ in relation to these regulations, shall mean intentional misdeclaration of declared capacity by any seller in order to make an undue  commercial gain through Charge for Deviations; Regulation 2 (j) the word ‘declared’ shall be substituted by the word ‘available’.
Regulation 3 (2) These Regulations shall be applicable to Seller(s) and Buyer(s) involved in the transactions facilitated through short-term open access or medium-term open access or long-term open access in intra-state transmission or distribution of electricity (including intra-state wheeling of power), as the case may be, in respect of all wind generators having a combined installed capacity of 10 MW and above and solar generators with an installed capacity of 5 MW and above including those connected via pooling stations and selling power within or outside the State.
Regulation 3 (2) … Provided that these Regulations shall also be applicable to all wind & solar  generators selling power outside the State under open access and having a combined installed capacity of 1 MW and above.”

Regulation 4 (7) All State Entities shall make necessary arrangements for putting up suitable meters,
capable of recording energy flows at 15-minutes intervals, at the points of injection and drawal.
Regulation 4 (7) …providing AMR facility for data downloading remotely at SLDC.”

New added clauses 4(8) & (9)

“ (8) All wind or solar generators including those connected via pooling station shall have to appoint a common QCA which may be one of the generators or mutually agreed agency. If generators fail to appoint a common QCA within a period of one month from the date of issue of notice by SLDC, then SLDC shall advise the concerned licensee for disconnection of pooling station/feeder from the grid.  The licensee shall disconnect the pooling station/feeder from the Grid under intimation to SLDC.

(9) In case more than 50% wind or solar generators including those connected via pooling station have consented for a particular QCA, then remaining generators shall have to appoint the same agency as a QCA. In case of non-compliance of SLDC  instructions, SLDC shall advise the concerned licensee to disconnect the defaulting generators from the Grid The licensee shall disconnect the pooling
station/feeder from the Grid under intimation to SLDC.”

Regulation 5 (c) Settlement Period: Preparation and settlement of ‘Deviation Pool Accounts’ shall be undertaken on weekly basis coinciding with mechanism followed for regional energy accounts.

…Till such time, but not later than three months from the date of the notification, the complete weekly ABT meter data is received through AMR System or manual data download by MRI, the State Load Despatch Centre shall prepare and issue  Deviation Charges Account on monthly basis.
Regulation 10(1) Governance Structure and constitution of State Power Committee (1) Within three months from the date of notification of these Regulations, the State Load Despatch Centre shall formulate Operating Procedures and Business Rules for the constitution of State Power Committee, which shall be approved by the State
Commission
Regulation 10(1) is substituted as under:
“(1) Within two months from the date of notification of these Regulations, the State
Load Despatch Centre shall formulate “a State Power Committee and its functions” and submit to the for approval.”Commission  

Uttar Pradesh announces Deviation Settlement Mechanism Regulations, 2018

Uttar Pradesh Electricity Regulatory Commission (UPERC) recently announced the (Forecasting, Scheduling, Deviation Settlement and Related Matters of Solar and Wind Generation Sources) Regulations, 2018

The key points of the regulations are as below:

  • The regulations are applicable to all solar (excluding rooftop solar covered under UPERC RSPV regulations) and wind energy plants in Uttar Pradesh connected to the intra-state transmission system and having an installed capacity of 5 MW & above.
  • The solar or wind generation plants with an installed capacity of 5 MW or more, using the power generated for captive consumption will also be covered under these regulations.
  • Each pooling station having a minimum combined installed capacity of 5 MW will have one QCA, However, in case a particular solar or wind generator having a capacity of 50 MW or more, then such generators will act as a QCA provided that such generator is connected alone to a pooling station.
  • Wind and solar generators under these regulations will be required to provide metering with a provision for recording and storing all the load survey and billing parameters for every 15-mn time block as specific in CEA regulations governing metering.
  • A penalty will be imposed in case of failure of generator/QCA to provide data as directed by SLDC or error in the data provided as below:

  • In case of failure of the generators/QCA comply with the above timelines, a penalty of INR 25,000/- per day will be levied.
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