The DERC has released draft RPO regulations in an order dated 28/07/2017. Following are the salient features of the regulation:


  1. RPO Compliance:

  • Aggregate from the gross purchases from generating stations by Obligated entities shall be considered as the quantum of RE purchase for RPO compliance.

  • All the power produced from Waste-to-energy plants shall be procured by the distribution licensee. This will also contribute towards RPO compliance.

  • Quarterly reports shall be submitted by the obligated entities which will include parameters such as capacity addition, generation and purchase of electricity from RE sources. The same shall also be posted on their website.

  1. Role of SNA:


  • Protocol development for regular information collection from RE generating companies, obligated entities, SLDC, chief electrical inspector, ets.

  • RE procurement and RPO compliance reports on a monthly basis by obligated entities which shall also go on their websites. This shall be done by the 10th of the next month.

  • It shall also receive information on or before 30th April from captive users who are consuming electricity generated from captive generating plants about electricity consumption and purchase from RE sources.

  • The same shall be applicable for open access consumers.

This regulation isn’t very different from the previous RPO regulation which was released in October 2012.

The order can be accessed here. The public notice can be accessed here.


The Ministry of Power (MoP) has released the guidelines for procurement of power from grid connected solar PV power projects. The guidelines are applicable to solar PV projects of size 5 MW and above. The purpose of these guidelines is to provide a direction for proper electricity procurement by distribution licensees and to protect the interest of the consumers. Also to make this process transparent and uniform.


Following are the salient features of the guidelines:


  • The appropriate Commission shall be CERC only in case if the distribution licensee is located in more than one state

  • SERCs will be the appropriate commission in case if there is a single distribution licensee.

  • The conditions to be met by the procurer are as follows:

  • The bid document should be prepared in accordance with the guidelines of MoP and the Standard Bidding Documents.

  • Clearances need to be procured from the end procurer, the agency developing the solar park.

  • Procurer has to specify where the project has been set up.

  • The bid structure shall be as follows:

  • The bids will be designed in terms of packages where the minimum will be 50 MW and the bids may be in energy quantity or power capacity terms.

  • The procurer may opt for either ‘tariff as bidding parameter’ or ‘VGF as the bidding parameter’.

  • The PPA period should not be less than 25 years and it can be in terms of energy or power. Repowering will be allowed from time to time for the duration of the PPA.

  • In case of default by the power generator, it shall be liable to pay the solar power generator as written in the PPA. Also, in such a case, the lender shall be allowed to exercise their right to substitution as per the substitution agreement provided in the PPA.

  • In case if the procurer is at default, it shall give its part of the PPA to a third party in the given time. In case if that is not done, the solar generators have a choice to terminate the PPA.

  • Once the procurer calls for bids, a single stage bidding process shall be followed. The procurer can also chose if an e-reverse auction shall be held. It is the responsibility of the procurer to give the details of the bidding process in case of a Solar park specific project.

  • For bid submission and evaluation, the bidders may form a consortium and chose a leader who shall be the focal point of contact. Also, for evaluation of bids, the procurer may form a committee. The technical and price bids shall be submitted separately along with a bid guarantee. Minimum number of bidders should be two and a proper methodology shall be followed for bid evaluation.

  • A 30 day period shall be given for bid submission from the issuance of RfS document. A table containing the time table for bid process is given in the guidelines attached below.

  • Bank guarantees such as earnest money deposit and performance bank guarantee need to be submitted.

The guidelines can be accessed here.


Andhra Pradesh Electricity Regulatory Commission (APERC) has released its forecasting, scheduling and Deviation settlement of solar and wind generation on 21/08/2017.

Executive Summary:

★ Applicability:

○ Regulation is effective from Aug 21st, 2017.

○ SLDC to issue detailed guidelines for QCA registration, scheduling procedures, communication protocols and formats etc., on or before Dec 1st, 2017.

○ Forecasting, Scheduling and Deviations Settlement shall commence from Jan 1st, 2018.

Further, generators commissioning on or after Jan 1st, 2018 shall not be allowed to be commissioned unless they start providing schedules as per this regulation.

○ Levy and collection of DSM Charges shall commence from Jul 1st, 2018

★ Regulation Applicable on: All the GRID Connected Wind and Solar Power Generators in AP.

★ Deviation Accounting:

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

★ Virtual Pool: To enable benefits of larger geographical area and diversity, aggregation of forecast is permitted under “Virtual Pool” where Generators have an option to account for their deviations at an aggregated level through a Qualified Coordinating Agency (QCA).

○ A similar provision is also permitted in Karnataka by Hon. KERC in its final regulation which is already being implemented w.e.f 1st June 2017.


★ Role of a QCA:

○ Provide forecast, schedules and periodic revisions;

○ Coordination with DISCOM/STU/SLDC for metering, data collection, communication/issuance of dispatch/curtailment;

○ Commercial settlement of DSM charges and de-pooling of charges among generators;

○ All other ancillary and incidental matters.

★ Important differences between wind and solar power scheduling:

○ 16 revisions (excluding collective transactions) are permitted starting from 00:00 Hrs of the     day for Wind Generators

○ 9 revisions (excluding collective transactions) are permitted starting from 05:30 Hrs upto 19:00 Hrs of the day for Solar Generators

○ All the revisions are effective from the 4th time-block

○ Aggregation “seems” to be allowed between wind and solar generation as the concept of virtual pool aims to capture not only the larger geographical area but also the diversity (among different asset class).


★ Important differences between intrastate and interstate transactions:

○ Wind and Solar generators having common interface meter at a pooling station but carrying out both – interstate and intrastate transactions at the same pooling station, the scheduling for the same shall to be carried out separately.

○ Approved open-access capacity (in MW) in such cases alone shall be considered as AvC for the purpose of DSM charges calculations.

■ Observation: Since the regulation permits common interface meter for such transactions and AvC determination is also clarified, the DSM charges may be computed in pro-rata basis for such pooling station as the common interface meter would only provide Pooling Station level actual generation.


○ Further, aggregation is permitted only for similar type of transactions i.e., interstate transactions are not allowed to be aggregated with intrastate transactions for the purpose of DSM charges determination.

○ QCA shall separately settle DSM charges for intrastate and interstate transactions.

★ Determination of DSM Charges for INTRASTATE transactions:

Note: DX is the absolute error in kWh for a given error band starting from X% as outlined in column 2.

 ★ Determination of DSM Charges for INTERSTATE transactions: 

Note: DX is the absolute error in kWh for a given error band starting from X% as outlined in column 2.


The Tamil Nadu Electricity Regulatory Commission (TNERC) has determined the distribution and transmission tariff for FY 2017-18. The last time they had determined tariff was in 2014 which means that the tariff has changed after 3 years. The energy charges for different categories is as follows:



The tariff for industrial and domestic categories hasn’t changed at all. Same is the case with domestic tariff.


Wheeling Charges: 21.06 Paisa/Unit

Wheeling loss: 2.45%

Cross subsidy surcharge: 1.67 Rs/kWh

The transmission tariff was also determined by the TNERC. It is as follows:


Transmission charges: 3037.30 Rs/MW/day

Transmission loss: 3.81%


The distribution and generation tariff can be accessed here. The transmission tariff can be accessed here.


The Indian Energy Exchange (IEX), so as to provide the obligated entities more number of ways to fulfill their RPO compliance, had proposed to the CERC to allow the existing renewable energy generators to trade RE on IEX.


For the same, it had proposed that the following contracts including Green Day Ahead Market (G-DAM) which includes Solar and non-solar day ahead market be introduced. If the bid made in the G-DAM is not cleared or cleared partially, they can bid in DAM. Also, in lieu of the bid cleared in DAM, the seller will get equal number of RECs.

This order was rejected by the CERC and the following reasons were given for the same:

  • As per CERC, the status regarding the availability of surplus power is not clear. Also, based on the experiences in the past, it can be established that such trade will not lead to addition of new RE capacity.

  • The IEX has supposed that there are no discrepancies in the forecasting and scheduling for RE generators which is not the case. Therefore, their suggestions of remove the need for revision flexibility during the day is not valid.

  • Based on the suggestions of IEX which mentioned that in case if the bid made in the G-DAM is not cleared or cleared partially, they can bid in DAM, it can be assumed that the situation will lead to registration of RE sellers for FIT route as well as REC mechanism. This will demand that a system be established where there is proper accreditation, registration, accounting of RE generation and settlement mechanism.

  • The G-DAM market may dissuade the buyers from entering into long term contracts which provide comfort to RE investors.

  • The guidelines related to the timelines for scheduling of power traded will have to be amended as per IEX which the commission felt will be an unnecessary step right now.

  • IEXs recommendations assume that the the green power traded in G-DAM will follow the same scheduling procedure as that followed by conventional power. Therefore, the commission feels that there is no need to introduce a separate segment for trading.

The order can be accessed here.


For a developed country, the one debate that always remains when considering emission control is the impact it will have on the economic development. To solve this problem in a country like India where industrial development is unavoidable, Niti Ayog is planning to put a cap on PM 2.5 emissions from industries. Under this scenarios there may be industries which which will find it easier to comply with the limits and ones for which it will be challenging. Therefore, they are proposing a trade of emission permits of PM 2.5.


Those industries which will be able to reduce more than the desired limit will be able to trade their emission permits to those industries which will not be able to reduce emission to the desired limit. This is going to be a way of ensuring continued economic growth along with emission reduction. It is being proposed that the Central Pollution Board of India (CPCB) will be able to keep a track of the emissions by implementing continuous emission monitoring systems. China has also started carbon trading recently for the same reason.


Cap and trade has been used for other GHGs and in other countries to reduce harmful emissions. This seams to be a great way to encourage emission reduction since it involves trade and therefore, competition among industries of various kinds without hampering their growth.


Our previous analysis which talks about climate change mitigation and industrial development can be accessed here. The article covering the news about the same can be accessed here


In a recent analysis in the Financial Express, those discoms which are a part of the Ujjwal Discom Assurance Yojna (UDAY) scheme have seen a reduction in their financial losses by 21.5%.  This amounts to a saving of Rs 40,295 Cr for FY 2017. Even the states which were earlier burdened due to huge financial losses have witnessed a drop in the losses by a significant percentage. For example, Tamil Nadu saw a decrease of Rs 3,783 Cr in its losses which is a decrease of about 35%. The liquidity profile of the discoms has also improved, as per the ICRA.


The power ministry opined on this matter saying that “with more projects being awarded, there should be a palpable difference on the metering front – a vital area which helps to reduce technical losses and minimize outages”.  As of now, the number of distribution transformers being metered are just 45% of the target to be met by December 2017. Therefore, they are hoping that the situation will improve further.


Our previous analysis on the completion of one year of the UDAY scheme can be accessed here.


DERC has released an order determining the terms and conditions for open access charges for FY 2017-18. Following are the salient features of the order:


  • Eligibility: Short Term Open Access (STOA) is applicable to consumers having a contract demand of 1 MW and above connected at 11 kV or above.

  • Metering Arrangements: The distribution licensee shall provide check meters of the same specifications as the check meters. The distribution licensee shall provide ABT compliant special energy meters at the point of drawal. The formats for availing open access approvals have also been notified

  • The 60 day timeline has also been defined for the procurement, testing and installation of ABT meters.

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The previous open access policy was announced in 2005. As of now, there are close to 60 clients in Delhi in Open Access which are trading power. As per the last policy, the quantum of energy traded had to be constant which is not the case anymore.

Earlier, an undertaking used to be taken in case of a mixed feeder which is still the case. Also, the SNAs asked for Bank Guarentee which included open accessed charges which is also still the case.

The order can be accessed here.


Supreme Court allowed conditional trading of Non-solar RECs on July 14, 2017 (our blog on the same can be accessed here). Demand was expected to be low for two reasons – 1) obligated entities are required to pay at old RECs rate (Rs 1500/ REC); and 2) compliance is required to be done by March to obligated entities have enough time to comply even after the final order of Aptel is received.

However, demand for Non-solar RECs was robust. In total 4.95 lakh RECs were bought (110.76 % higher than July 2016), and clearing ratios on IEX and PXIL were 4.31% and 3.52% respectively. Higher demand was primarily driven by demand for some utilities where state regulators had given RPO enforcement orders in recent months.

Solar RECs were not traded as the stay imposed by the Supreme Court remains in force in the case of Solar RECs.


The government of India assigns dedicated funds which is linked to specific cess. This kind of cess One such fund is the National Clean Energy and Environment Fund. In a recent move, there was a diversion of the funds collected as tax for the National Clean Energy and Environment Fund to the states that lost revenue because of GST. Through this move, the unspent funds which were to be used by MNRE have been diverted. This means that from next year, India will not have a National Clean Energy and Environment Fund. Some individuals working in the sustainability sector argued that this amount could have been used in the development of clean coal technologies.

This action is also going to pose a risk to the MNRE as 98% of its budget of which comes from this fund. Not only that, this fund has also aided India in meeting its commitment towards the Paris Agreement. Now that the United States has withdrawn from the Paris Agreement, the Clean Energy fund was the only aid which India had to meet its obligations by 2020. Since it does not exist anymore, out fight to protect the environment has become an even bigger challenge.


The article covering the same can be accessed here

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