TSERC announces APPC cost for FY 2018-2019

Telangana State Electricity Regulatory Commission (TSERC) announces its average pooled purchase cost for the year FY 2018-19. The APPC cost of INR 4.097/kWh for FY 17-18 will be continued for this financial year as well. In an order followed by a petition by TSSPDCL and TSNPDCL which had requested the commission to consider the pooled cost of power purchase in FY 2017 – 2018 for FY 2018 – 2019 as per the regulations stated in Electricity Act 2003. The average power purchase pooled cost of INR 4.06/kWh was discovered by both the DISCOMs.

The petitioners were of the opinion that post to the formation of Telangana in 2014 all regulations, decisions, directions or orders issued by the erstwhile APERC were adopted until any of the regulation were altered, repealed or amended under the jurisdiction of the State of Telangana. This also included renewable power purchase obligations (RPPO), for which the commission issued regulations fixing the RPPO to be met by the obligated entities from FY 2018-19 to FY 2021-22.  

To which the commission replied that “Pooled cost of power purchase’ means the weighted average pooled price at which the distribution licensee has purchased electricity in the previous year from all the long-term energy suppliers excluding the purchases based on liquid fuel. Provided that the purchases from traders, short-term purchases and purchases from renewable sources shall not be taken into account while determining pooled cost of power purchase.”

The discoms further stated that policies like the state solar power policy 2015 & industrial policy allow a solar net metering & other incentives to be applicable for 25 years and a customer availing for this mechanism will be paid back at the APPC cost decided by the commission on a yearly basis.

Apart from Telangana, Southern states of Karnataka and Tamil Nadu have also recently announced their APPC cost for the FY 2018-2019.

CERC announces regulations for implementation of Interstate Transmission System in the country

The Central Electricity Regulatory Commission (CERC) recently announced a regulation called the 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 which came into effect from July 2018. The objectives of the regulation are to:

(1) Lay down the broad principles, procedures, and processes to be followed for planning and development of an efficient, coordinated, reliable and economical system of an inter-State transmission system (ISTS) for smooth flow of electricity from generating stations to the load centers;

(2) Ensure wider participation of stakeholders in the planning process and specify the procedures for stakeholders consultation and participation;

(3) Specify procedures to bring about transparency in the planning process; and

(4) Demarcate the roles and responsibilities of various organizations in line with the Act for meeting the above objectives;

The regulation states responsibilities of the concerned entities like the Central Transmission Utility, Transmission Licensees, Regional Power Committee (RPC), RLDCs, NLDCs & SLDCs respectively and their roles in implementing the above-stated objectives of the regulations. This regulation is in accordance with other CERC regulations like Central Electricity Regulatory Commission (Procedure, Terms, and Conditions for grant of Transmission License and other related matters Regulations), 2009; Central Electricity Regulatory Commission (Grant of Regulatory Approval for execution of Inter-State Transmission Scheme to Central Transmission Utility Regulations), 2010; and the Tariff Regulations issued by the Central Commission from time to time under section 61 of the Act.  

Further, the regulation has mentioned the process for the planning of the inter-state transmission and lastly, there are details provided for the process to be followed by CTUs and transmission licensee for application filing in order to start inter-state transmission.

The regulation has come well in time as there have been recent solar PV auctions with Interstate Transmission System connected solar projects. The regulations have also considered the augmentation of renewable capacity addition and Renewable Purchase Obligation with respect to each state in the country.

Andhra Pradesh Government asks the state discoms to accept full power from the wind developers

Andhra Pradesh Government has asked the state DISCOMs to take all the power the wind developers produce and further pay for it, irrespective of the Capacity Utilization Factor (CUF) of the developer’s project. In one of the state’s order regarding the feed-in-tariff for wind energy, the CUF was discovered at 23.5% for an average wind project. Post this, the state DISCOMs interpreted it as a directive to accept only the quantity of power a wind plant would generate it is was 23.5% and reject any additional power supplied. If the plant, produced more power by adopting efficiencies that led to a higher CUF, the DISCOMs would reject it.

After this development, the MNRE Secretary had written to the Principal Secretary in Andhra Pradesh’s Energy Ministry in December 2017 that “the generic tariff determined by the Andhra Pradesh Electricity Regulatory Commission (APERC) may have taken 23.5% CUF as average CUF in the state for wind power projects and therefore, it is likely that there may be certain sites where CUF is more than the average CUF”. Recently Mr.Jain (MNRE) wrote to the Andhra Pradesh Electricity Regulatory Commission (APERC), as well as all state discoms, that “in the view of Secretary, MNRE’s letter, discoms have to treat wind power as must-run stations and take the entire power from them without curtailment.”

Due to the previous announcement from the APERC, the developers had assumed that about 2,000 MW of projects which had been turned down by the state’s discoms would have turned into Non-Performing Assets.

Despite the letter, some people in the industry feel that the bigger problem is of ‘backdown’ – discoms’ refusal to take wind power at times citing non-availability of grid capacity which has gone unaddressed and the MNREs letter won’t be of much help to the developers.

Maharashtra joins the list of states with final Forecasting and Scheduling regulations

Recently Maharashtra became the latest state to publish final Forecasting and Scheduling (F&S) regulations. These regulations were published in the State Gazette on July 20, 2018. With this, all supposedly “RE rich” states except Gujarat and Tamil Nadu have finalized their F&S regulations.

The detailed summary of the regulations is as below:

Regulation Applicable on All grid-connected Wind and Solar Power Generators with pooling station capacity not less than 5MW or that of an individual Generator connected to some other Substation, shall not be less than 5 MW.

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

Available Capacity (AvC) = 100/Actual Generation – Scheduled Generation AbsoluteError in %

Point of Forecasting: Pooling Station or STU Feeder where injection is made.

Keypoints

  • No Aggregation – Clause 5.13 specifies the aggregation of schedules at Pooling Substation level only, and not of multiple pooling station capacity.
  • Further charges in case of shortfall in DSM pool – Clause 12.1 (d) specifies that any shortfall in the aggregate amount of Deviation Charge payable by Solar and Wind Energy Generators at the State periphery and the amount receivable from them by the Pool Account shall be recovered in proportion to their deviation reflected at the State periphery.

Sr.

No.         

Absolute Error in %age terms in 15-minute time block                               Deviation Charge payable to Pool Account for Wind/Solar Generation
1 < = 15%

None*

2 >15% but <=25% At Rs. 0.50 per unit for the shortfall or excess beyond 15% and up to 25%
3 >25% but <=35% At Rs. 0.50 per unit for the shortfall or excess beyond 15% and up to 25% + Rs. 1.00 per unit for the balance energy beyond 25% and up to 35%
4 >35%

At Rs. 0.50 per unit for the shortfall or excess beyond 15% and up to 25% + Rs. 1.00 per unit for the shortfall or excess beyond 25% and up to 35% + Rs. 1.50 per unit for the balance of energy beyond 35%      

Role of a QCA:

  • Provide day ahead, weak ahead and intra-day forecast, schedules and periodic revisions;
  • Coordination with DISCOM/STU/SLDC for metering, data collection, communication/issuance of dispatch/curtailment.
  • De-pooling of charges among generators
  • Commercial settlement of DSM charges and all other ancillary and incidental matters.
  • The QCA shall furnish weekly meter readings to the SLDC by 00.00 hours on Thursday of the previous week, in addition to the data provided to the SCADA Centre, for the purpose of energy accounting under these Regulations.

Revisions:

  • 16 revisions are permitted starting from 00:00 Hrs of the day for Wind & Solar Generators
  • All revisions will be effective from the 4th time-block

Important differences between intrastate and interstate transactions:

  • The sale of power within Maharashtra by Solar and Wind Energy Generators connected to the Intra-State Transmission Network shall be settled by the Procurers on the basis of their actual generation.
  • The sale or of power outside Maharashtra by Solar and Wind Energy Generators connected to the Intra-State Transmission Network shall be settled by the Procurers on the basis of their scheduled generation.
  • Inter-State transactions at a Pooling Sub-station shall be permitted only if the concerned Generator is connected through a separate feeder. In that case, a separate Schedule will have to be provided for its energy generation.
  • The Generator shall pay the Deviation Charges applicable within Maharashtra in case of deviations in the State DSM Pool Account, the consequences of such deviation at the Inter-State level being governed by the CERC Regulations governing the Deviation Settlement Mechanism and related matters.

Telangana announces final DSM regulations for wind and solar

Recently TSERC announced regulations on wind and solar forecasting, scheduling regulations, 2018. This is the final regulation and with this Telangana became the sixth, and latest, state to implement Forecasting and Scheduling regulations.

The detailed summary of the regulations is as below:

  • Title of the Regulation: Telangana State Electricity Regulatory Commission (Forecasting, Scheduling, Deviation Settlement and Related Matters for Solar and Wind Generation Sources) Regulations, 2018.The Telangana Forecasting regulation has been finalized within two months of the release of draft regulation.
  • 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 grid-connected Wind and Solar Power Generators (except Rooftop PV Solar Power Projects) connected to a pooling substation of the capacity not less than 5 MW irrespective of commissioning date.
  • Deviation Accounting:  The deviation accounting will be carried out based on the Available Capacity:
  • Absolute Error in % =   100 x  Actual Generation – Scheduled Generation  ⁄ Available Capacity (AvC)
  • Point of Forecasting: Pooling Station or STU Feeder where the injection is made.
  • Aggregation: Unlike in Karnataka and AP, Telangana’s order of F&S does not have a provision to provide an aggregated forecast.
  • Role of a QCA:
      • Provide day ahead, week -ahead schedule generator wise and aggregated schedule for each pooling station and the periodic intraday revisions.
      • Coordination with DISCOM/STU/SLDC for metering, data collection, communication/issuance of dispatch/curtailment;
  • Provide day ahead, week- ahead schedule generator wise and aggregated schedule for each pooling station and the periodic intraday revisions.
      • Coordination with DISCOM/STU/SLDC for metering, data collection, communication/issuance of dispatch/curtailment;
      • De-pooling of charges among generators:
      • Commercial settlement of DSM charges on a weekly basis and
      • All other ancillary and incidental matters.
  • Revisions:
      • 16 revisions are permitted for Wind Generators starting from 00:00 Hrs of the day.
      • 9 revisions are permitted for Solar Generators starting from 05.30Hrs of the day.
      • All the revisions are effective from the 4th time-block.
  • Other Key Points:
    • DSM Settlement will be done on a Weekly basis, with Meter data to be provided by SLDC, and verification to be done in coordination with SLDC.
    • After recovering DSM amounts, if there is a gap between the actual commercial impact for the state as a result of deviation of wind and solar generation, such amount will be further recovered from each generator.
    • The wind and solar generator or the QCA will provide payment security to SLDC by the way of BG or revolving LC which will cover the DSM payment for 6 months.
    • De-pooling will be done in proportion to energy injected in each time block by each generator.
    • The QCA will only be forecasting on PSS level. Aggregation to create a virtual pool/aggregate of multiple substations is not allowed. States like A.P and Karnataka have allowed Aggregation in their final regulations.
  • 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 have to 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

Sr. No

Absolute Error

DSM Charges Payable to State Pool Account
1 ≤ 15% None
2 >15% but ≤ 25% At Rs. 0.50 per unit
3 >25% but ≤ 35% At Rs. 1 per unit
4 >35% At Rs. 1.50 per unit

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

Inter-state Deviation Charges will follow the same mechanism as defined by CERC (PPA linked). However, the final deviation settlement for Inter-state generators shall be done by SLDC on the basis of deviations and its impact at state periphery.

The TSERC Regulation for Forecasting & Scheduling, 2018 has provided a summary of timelines designating the activities to QCA and SLDC, to be accomplished within the following stipulated duration.

Sr. No. Activity/Milestone Action By Duration (Months)
1 Technical Specification and Information Sharing protocol by QCA to SLDC SLDC 3
2 Forecasting tool, alternate means of communication, formats for submission SLDC 3
3 Forecasting tools to be established by QCAs QCA 3
4 Guidelines for registration of QCA, data exchange between QCA and SLDC SLDC 2
5 Manner of making State Pool Account and settlement thereof SLDC 3
6 Detailed Procedures covering plan for data telemetry SLDC 3
7 Trial Run –During this period all parties shall comply with the above All 6
8 Commencement of commercial arrangement. All 6

 

ANALYSIS OF APTEL ORDER ON REC PRICING AND MULTIPLIER

Order in the case of REC pricing and vintage multiplier has now been uploaded on the ApTel’s website. Following is a quick summary of the same:
ApTel has rejected all prayers of the RE generators. Specifically, it has held:
–       Pricing: ApTel found no issues with the change in methodology by CERC when they used bid-discovered prices as against CERC determined generic tariffs.
The order states: “
“In view of the growing competition and induction of latest technologies, more and more generators are participating in the auctions/bids with considerable reduced cost of generation. Thus, the Central Commission in specifying REC prices, has shifted to bid discovered prices in place of earlier generic tariff fixed by it when the RE sector specially solar was in infancy stage.”
 
And
“We have carefully considered the contentions of all the parties and note that under the prevailing market scenario, the prices of RECs cannot be kept artificially high to burden the end consumers. Further, if the prices of RECs are kept high without aligning them with the market reality and current cost of electricity, the obligated entities may not purchase the RECs and try to fulfil their RPOs by other means.”
–       Vintage Multiplier – The ApTel has said that providing vintage multiplier is the “discretion” of CERC, and said that the CERC has provided “cogent reasoning” in its order, and further that the ApTel found “no unjustness in specifying the floor and forbearance prices of REC and discontinuation of the Vintage Multiplier”

–       In our opinion, the justification of price reduction is also to some extent based on factually incorrect premise. For example, the order says:
 
It is also noteworthy that sufficient time has been given to RE generators to sell their RECs at the power exchange but perhaps in anticipation of selling them at better prices has resulted into unsold REC inventory.”
 
            And further,
 
“Another important fact is that among the three routes available for RE generators, the REC capacity is dominated by RE generators operating under CGP and OA route rendering APPC route as the last choice”
 
We believe that this order will have a significant adverse impact on projects and investors that have invested in REC projects. An immediate impact will be that such project will have to bear heavy losses on the existing inventory of RECs – the losses will be particularly heavy for solar projects.
It also does not bode well for future investment in the REC mechanism, as falling RE prices are an irreversible trend. Does this mean that REC projects will have to bear losses of such reduction every year?

UPDATE ON HEARING ON PRICE AND TRADING OF SOLAR RECS IN APTEL

We attended the hearing at ApTel today. The court has dismissed all the petitions – implying that the CERC order remains as is. More details will be available once the final order is uploaded on the ApTel’s website (generally by end of day or tomorrow).
Since the stay on trading for Solar RECs was till the order of ApTel, it stands automatically vacated, and trading will resume from this month (unless a fresh stay is obtained by the generators).
We will provide a very detailed analysis of the order once it becomes available.

REVISION OF REC PROCEDURES BY CERC

Central Electricity Regulatory Commission (CERC) has released Model Guidelines for Accreditation of a Renewable Energy Based project or Distribution Licensee, as the case may be under REC mechanism. These regulations shall be applicable to all renewable energy based projects of generating companies which are grid connected. All sources recognized and approved by the Ministry of New and Renewable Energy shall come under these regulations. Following are the major changes proposed in the procedures:

 

  1. Those renewable energy based Captive Generating Plants which do not fulfill the criteria as prescribed in the Electricity Act, 2005, shall not be eligible for accreditation for the energy generated by the plant for self consumption.

  1. Ownership of existing valid RECs shall be transferable by the central agency in case of change of legal status of registered entity. The procedures include the following conditions as change of legal status:

Change from partnership to company, Pvt. Limited to Public Limited, new entity subsequent to demerger, change in ownership of the company and asset sale/ transfer to another company, etc.”

  1. Revision of formats for Recommendation (checklist) from state agency and declaration.

  2. Application for revalidation or extension of validity of existing RECs shall be done at least three months in advance,prior to the expiry of existing registration by generating companies and distribution licensees.

  3. In case of reduction of the registered capacity of the RE generating plants, the application should be submitted online.

REC TRADE RESULTS FEBRUARY 2018

Non-solar demand was significantly higher than inFebruary 2017, and also last month. In total 23.58 lakh RECs were traded (125.85% higher than February 2017, and 91.61% higher than in January 2018), and clearing ratios on IEX and PXIL were 19.84% and 69.80% respectively. Total traded value was Rs 353 crores*.

REConnect shifted its major volume on PXIL in a timely manner this trade session due to higher demand as compared to IEX.

The written submission for the case on stay of trading of solar RECs has been done and the judgment is reserved.

*This value is calculated considering the rate of Rs 1500 per REC out of which Rs 1000 go to the generator and Rs 500 goes to CERC

Trading of solar RECs continues to be suspended due to the stay imposed by the Supreme Court.

Telangana releases draft RPO policy for the first time

Telangana State Electricity Regulatory Commission (TSERC) has released draft regulations for the compliance of Renewable Purchase Obligations for the state. These regulations are first of its kind in the state. Before this, the state was following RPO percentages determined by APERC (Andhra Pradesh Electricity Regulatory Commission) through its latest regulation.

 

Comments on these regulations are invited till 9 February 2018.

 

The RPO percentages determined in the regulation are as follows:

In the order, the RPO percentages were only given in terms of total of both solar and non-solar percentages. As per the National Tariff Policy 2016, the solar RPO percentage for states across the country shall reach 8% whereas in the mentioned order, the total RPO percentage (including solar and non-solar is 7.5% ie. 0.5% lower.

The RPO trajectory declared by TSERC as compared to that declared by MoP  for the FY 2018-19 can be seen below:

 
The draft regulation can be accessed here. The public notice can be accessed here.
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