CERC Determines fees for issuance of Renewable Energy Certificates

In a recent amendment in the Regulation 11 of the REC Regulations, CERC determined the fees and charges payable by the eligible entities for participation in the scheme for, registration, eligibility of certificates, issuance of certificates, and other matters connected there with.  Following are some of the highlights of the regulation:

 

a)      Fees and charges other than those for issuance of certificates would be continued as they are at present until further orders.

 

b)      The fee for issuance of certificate for the period from 22.4.2013 till the date of issuance of next order by the Commission was determined at the rate of Rs 10/certificate.

 

c)      The fee for issuance of certificate for the period from 1.4.2015 till the date of issuance of next order by the Commission was to be regularized at the rate of Rs 4/certificate.

 

d)      The fees for issuance of certificate for the period from 1.1.2017 until further orders is determined to be Rs 2/- per certificate.

 

The regulation can be accessed here.

Rajasthan Proposes Wind Tariff for FY 2016-17

The Rajasthan Electricity Regulatory Commission (RERC) recently proposed the new tariff for wind energy sources, which will be applicable for the projects commissioned during FY 16-17. The tariff will be applicable for 25 years.  The details of the tariff proposed are in the table below:

 

 

Below are the some graphs on the year-wise tariff’s of CERC and RERC for wind energy and the % changes in the tariffs over the years.

 

Note: All figures of CERC relate to wind zone-2 as defined by CERC, and all RERC tariffs relate to Wind Power Plants located in districts other than Jaisalmer, Jodhpur & Barmer districts.

It can be noticed from the graphs above that RERC has constantly increased Wind tariffs over the last three FYs except for the current FY, while CERC wind tariffs have risen a bit in terms of %.

Rajasthan has a wind power potential of 5050 MW’s and with these tariffs proposed, it will become an attractive destination for setting up Wind projects.

The Tariff proposed by RERC can be read here.

 

 

Analysis of CERC’s 4th Amendment to REC Regulations

CERC published the 4th Amendment to REC regulations in end-March. These regulations will have a significant impact on the RECs markets going forward, as a large portion of the existing capacity under the mechanism will become in-eligible for RECs.

In summary, the following projects will no longer be eligible for RECs:

  • Open access projects that avail concessional wheeling or banking benefit
  • Captive or self-consumption projects commissioned before 29 Sept 2010 or after 31 March 2016 (ie, before the RECs regulations first amendment when captive projects were made eligible and after this amendment)
  • Captive or self-consumption projects commissioned between 29 Sept 2010 or after 31 March 2016 but avail concessional wheeling or banking benefit

Our analysis suggests that several projects will become ineligible for RECs. The largest impact will on bio-fuel co-gen projects and biomass projects, as a large portion of these projects are captive or self-consumption projects commissioned prior to 29 Sept 2010. Older wind projects under group-captive mechanism (predominantly in TN and Maharashtra), and captive small hydro projects will also be impacted.

Solar projects are likely to have minimal impact as most projects are commissioned after 2010.

Source: REC Registry website; REConnect Analysis

 

This will lead to significant reduction in RECs issued. Our estimate suggests that the reduction could be as high as 40-50% of existing RECs issuance (in FY 15-16, total non-solar RECs issued were 73.6 lakh).

As a result, it is likely that demand for RECs will outstrip supply on an annualized basis during FY 16-17. However, large existing inventory of RECs will ensure that for FY 16-17 trading prices remain at floor-price and clearance remains low.

Note: The above issuance and demand are cumulative for the year (it does not include existing inventory of RECs)

Source: REC Registry website; REConnect Analysis

 

The regulation can be accessed here.

 

 

 

CERC determines Benchmark Capital Cost Norm for Solar PV and Solar Thermal power projects applicable during FY 2016-17

The Central Electricity Regulatory Commission vide its final order on 23rd March, 2016 determined the Benchmark Capital Cost Norm for Solar PV and for Concentrated Solar Power (CSP) projects for 2016-17. In case of determining the capital cost for Solar Photo voltaic, many parameters were considered like the Land cost and cost of PV modules etc.

The graph below depicts the change in the total capital cost from FY 2012-13 to FY 2016-17 and the % change year on year. The capital cost of Solar PV has decreased approximately by 68%  from  FY 2012-13.

 

 

In case of Solar Thermal, Commission had proposed to retain the benchmark capital cost of Solar Thermal power projects at INR 12.0 Crore / MW for FY 2016-17 (which remained the same in FY14-15 and FY 15-16). After reviewing all the comments and suggestions the Commission came up with the following order:

“Given the nascent stage of technology for Solar Thermal, the Commission has proposed to retain the benchmark cost without any decrease. At this point, it is not feasible to further increase these prices. The Commission decides to retain the benchmark capital cost for Solar Thermal power projects at INR 12.0 Crores / MW for FY 2016-17.”

The final order for FY 14-15 can be accessed here.

The final order for FY 15-16 can be accessed here.

The final order for FY 16-17 can be accessed here.

CERC (Terms and Conditions for Exchange of ESCerts) Regulations, 2016xchange of ESCerts) Regulations, 2016

Background

An important part of the Perform, Achieve, and Trade (PAT) mechanism for Energy Efficiency is the ‘trading’ aspect. PAT Cycle I was completed last year and the next logical step in the process is the trading of Energy Saving Certificates (ESCerts).  For a detailed analysis of the PAT scheme, see our Newsletter  Vol. 47 January 2015.

 

The actual ‘trading’ may soon become a reality as CERC recently came out with draft regulations that will govern such trading on power exchanges. A brief analysis is below:

 

Draft Regulation:

The draft Regulations has proposed to assign the responsibilities to BEE, CERC and POSOCO:

 

BEE:BEE shall discharge the role of Administrator of ESCerts and shall provide assistance to the Commission in the matters involving exchange of ESCerts on Power Exchanges and shall coordinate with the Power Exchanges and Registry for smooth interface for Exchange of ESCerts

 

CERC : CERC would function as the Market  Regulator.  In its role as Market Regulator, the draft Regulations proposes to  approve the procedure for interface activities between Power Exchanges and Registry, Administrator and Registry, and Registry and Designated Consumer And monitor the operations and performance of Power Exchanges with regard to exchange of ESCerts ;

 

POSOCO: During the introduction of Renewable Energy Certificates ( RECs) , POSOCO was mandated to act as the Registry.  Ministry of Power has assigned the

function of Registry of ESCerts trading to POSOCO for the exchange of ESCerts on the Power Exchanges .  In its capacity as the Registry for ESCerts, POSOCO is envisaged to discharge the following important functions:

 

  • Assistance in registration process of ESCerts including crediting of ESCerts to DCs after approval from MoP,
  • Guidance on dealing in the process of ESCerts trading/ exchange
  • Coordination and information dissemination with DCs, Power Exchanges, BEE and Regulator (i.e. CERC)

 

Issuance of ESCerts:

  • The DCs would be issued ESCerts in electronic form in a cycle period for achieving specific energy consumption less than the energy consumption norms and standards notified by the Central Government for the cycle period, under Energy Conservation Rules, and subsequent cycles, who have held such certificates in Registry accounts.

 

  • The DC’s whose specific energy consumption shall be more than the prescribed energy consumption norms and standards specified for a cycle period and subsequent cycles and who wish to comply with the prescribed energy consumption norms and standards using ESCerts in lieu of implementing energy conservation and energy efficiency improvement measures shall be entitled to purchase the ESCerts to meet compliance with the norms and standards prescribed under

 

The Certificate issued to eligible entities by the Government on the recommendations of the Bureau could be transacted on any of the Power Exchanges by the ESCerts holder.

It’s important to note that BEE has proposed that ESCerts have no floor or forbearance price. Pricing will therefore be determined purely through demand and supply of ESCerts. Initial analysis suggests that there will be significant oversupply of ESCerts, leading to low prices. However, its important to note that companies have the choice to ‘bank’ ESCerts to the next cycle – this feature may have the effect of a floor price as if the trading price is lower than the cost of achieving energy savings, the company will be better off banking the certificates rather than trading them.

 

The regulation can be accessed here.

 

HPERC Declares APPC for 2015-16

The Himachal Pradesh Electricity Regulatory Commission (HPERC) recently came up with its order on the Average Pooled Power Purchase Cost (APPC) for the financial year 2015-16.

The definition of APPC followed by HPERC is in line with the CERC definition and can be read as:

Pooled Cost of Purchase means The weighted average pooled price at which the distribution licensee has purchased the electricity including cost of self-generation, if any, in the previous year from all the energy suppliers long-term and short-term, but excluding those based on renewable energy sources, as the case may be.”

The APPC for the financial year 15-16 has been determined as Rs. 2.31 per Unit, by the commission which shall continue for further period with such variation or modification as may be ordered by the Commission for the next financial year.

The APPC for FY 15-16 is 3.12% higher as compared to the APPC of FY 14-15.The graph given below depicts the APPC’s determined by HPERC over last four years and how the APPC rates have increased over the past three years :

The HPERC order can be accessed here.

Analysis of Model Regulations on Forecasting and Scheduling of Wind and Solar Generating Stations at State Level

As you may be aware, CERC had notified forecasting and scheduling (F&S) regulation for inter-state sale of power a few months back. Now, with the intent of having compatible regulations, the Forum Of Regulators (FOR) has come up with model regulations. It is expected that states will adopt this model regulation or something on these lines in the near future.

Executive Summary:

  • Forecasting and scheduling will be required by all wind and solar project, regardless of the date of commissioning and capacity
  • Deviations will be calculated on the basis of total available capacity
  • Penalty is a fixed amount beyond the error range (10% in case of new projects, 15% in case of old projects)
  • Settlement will be done through the “Qualified Coordinating Agency” or QCA.

Detailed Analysis:

Forum of Regulators have recently come up with model regulation for forecasting and scheduling and deviation settlement mechanism. The primary objective is two fold: a) facilitate large-scale grid integration of solar and wind generating stations, and b) maintaining grid stability and security.

Highlights of the model regulation are below:

-          All solar and wind generators connected to State grid have to provide day-ahead and week-ahead schedule

-          Revisions can be made on a one-and-half hourly basis.

-          Payment for generation shall be as per actual generation (this is different from the inter-state regulation, where payment is on the basis of scheduled generation). .

-          The deviation slab has been narrowed for upcoming projects (i.e., +/-10%) but has been kept as (+/-)15% for existing generators at Intra-state level

-          Penalty is calculated at fixed amounts per unit (whereas, for Inter-state it is calculated as a percentage to PPA rate)

-          RPO accounting can continue as per existing arrangement, and needs no change.

Applicability of Regulations

All wind and solar generators connected to the State grid are covered:

  • regardless of date of commissioning,
  • including those connected via pooling stations
  • selling power within or outside the state.

Detailed Mechanism defined for Deviation Settlement

Deviation calculation both for Inter-state and Intra-state has been kept as :

*Available Capacity would ideally be the Installed Capacity, unless any of the turbines are on outage. Similarly for solar panels.

In case of Intra-State transmission, Penalty Mechanism for existing generators :

In case of Intra-State transmission, Penalty Mechanism for up-coming generators :

The detailed Regulation can be accessed here.

 

OERC Draft DSM Regulations 2015

In order to maintain grid discipline and grid security as envisaged under the Indian Electricity Grid Code and Orissa Grid Code, Orissa released its first draft Deviation Settlement Mechanism Regulations on 23rd September 2015.

The Regulations are applicable to:

  • All Generating Stations including Solar and Wind Generators in the state of Orissa, except the Inter-state Generating Stations connected to Inter-State Transmission system.
  • All CGPs in the state of Orissa, with capacity of 5 MVA and above
  • All Distribution/Trading Licensees in the state of Orissa.
  • All Open Access Customers (Above 5 MW) in the state of Orissa.

The charges for the Deviations for all the time-blocks has been classified as:

A. For all generators except wind and solar, and all buyers in the state

The charges payable for deviation, will be UI linked and is worked out on the average frequency of a time-block at the rates specified as per CERC (Deviation Settlement Mechanism and related matters) Regulations, 2014 and amendments thereto.

B. For the Intra State Wind and Solar Energy Generators

These entities will be treated differently, and the error resulting from the deviations, will not be penalized based on the UI mechanism, but by a mechanism very similar to the recent amendments to CERC Inter State Forecasting, Scheduling and Imbalance Handling Regulation of 2015.

The detailed deviation linked penalty mechanism has been proposed as below:

The commission has invited comments and suggestions till 22nd October 2015.

The relevant regulation can be accessed here.

Wind & Solar Forecasting & Scheduling Regulations 2015

To overcome the difficulties related with managing the infirm wind and solar power, the Central Electricity Regulatory Commission introduced the provisions for wind/solar power forecasting under the Indian Electricity Grid Code in May 2010. The mechanism was promoted as the Renewable Regulatory Fund (RRF) mechanism. The mechanism was originally intended to be implemented by January 2011, which got four extensions (Jan’12, Jul’12, Feb’13, July’13) before it could get even started.

The mechanism finally got implemented from 15th July, 2013 and subsequently got caught under the litigations as the Wind Associations challenged the decision of CERC to implement such regulations for wind power plants connected under the intra-state networks. Finally, the commercial settlement related with the mechanism finally went to temporary suspension mode in Feb’14.

The mechanism also attracted lot of resistance from various stakeholders due to the reasons represented in the block diagram below.

CERC Forecasting and Scheduling Regulations 2015

The CERC, on 05th April 2015 proposed new framework for the Forecasting, Scheduling and imbalance handling of Wind and Solar Energy generating projects at inter-state level, and finalized the same through notification on 7th August, 2015, to make major amendments to the Deviation Settlement Regulations (DSM) Regulation 2014 and the IEGC Regulation 2010. The highlights of the same are given below:

Error calculation methodology:

The error calculation methodology used earlier and the proposed one are compared below:

The penalty mechanism as per the new regulation is as follows:

  • For single PPA agreements, the fixed rate shall be the PPA rate between the generator and buyer, and in case of multiple PPA’s, the weighted average shall be taken.
  • For Open Access transactions for RE, where consumer is not claiming RPO, or in case of captive power, the fixed rate shall be the APPC rate at the national level.

The existing wind capacity of 23.7 GW[1], most of which comes under the control area of the state, whereas in case of solar, approximately 200 MW odd capacity out of 4 GW[2] comes under the control area of RLDCs. With the central government thrust on large additions year-on-year, in future, large inter-state projects will come under purview of the new inter-state forecasting regulation. However, the regulation for accommodating the capacity connected with the state control area can be expected to be announced soon as the CERC in its closing remarks of the final regulation has expressed the desire for the same.

We are expecting the Intra-state regulation to come soon, along with the implication of the commercial settlement. With the implementation of the Inter-state regulation becoming applicable from 1st November 2015, and possibly, the soon to come Intra-state regulation, it is a huge task at hand for all stakeholders, especially for those generators for whom forecasting and scheduling will be something new to oblige to, when the new regulations are implemented. It also calls for more efficient approach in terms of huge data management schema, automation of operations, forecasting techniques and error handling & response.

As an experienced Co-ordinating agency we have geared up to the new regulations in all way possible, and would like to deliver our value oriented in-house services as per expectations of stakeholders, and even beyond.

The IEGC Amendment can be accessed here.

The DSM Regulation can be read here.

The Statement of Reasons from CERC can be understood here.


[1] As per MNRE data on 30.06.2015

[2] As per MNRE data on 30.06.2015

Analysis of the 5th Amendment to REC Regulations

Background:

Recently, CERC proposed the 5th amendment to REC regulations. The gist of proposed changes is:

  • Captive generators and portion of power for self-consumption will no longer be eligible for RECs
  • If an open access (OA) project avails concessional wheeling, banking or cross-subsidy benefits, it will not be eligible for RECs

These changes have been proposed in the context of an REC market that faces significant oversupply. As on June 30 2015, RECs worth 2,650 crore remain unsold, and clearing percentages in many months are well below 5%. In most months, more RECs have been issued than redeemed, further aggravating the problem of over-supply.

In the explanatory memorandum, CERC has elaborated on the thinking behind the proposed amendment. The memo states:

Lack of RPO enforcement has been one of the major reasons for the high level of unsold REC inventory. However, it is also important to analyze the supply side aspects and understand whether the right beneficiaries (as was envisaged while introducing REC framework) are participating and able to compete in the REC market. It remains a fact that a major portion of the REC inventory is contributed by the CGPs. Also, developers under third party model are able to leverage the concessional benefits while participating under 
REC framework.” (Emphasis added)

and,

“Around 51% of the projects under the CGP route were commissioned before the first notification (14 January 2010) of the REC Regulation. These projects must have computed their financial viability without the REC benefit.” 


The proposed changes will have far-reaching implications on the REC market structure. As per data provided in the Explanatory Memo approximately 41% of the capacity (under captive generation) will be completely excluded from RECs markets, and a significant portion of OA capacity (19% of total) will be impacted.

Analysis by REConnect Energy suggests that annual RECs generation may fall from 96.25 lakhs in FY 14-15 to 54.30 lakhs per year after the amendment.

Table: Annual RECs Issuance

 Sources: REC registry website; REConnect analysis

Note: Annualized redemption is assumed to be 2X times redemption is FY 14-15. Increase is expected due to SC order and Electricity Act amendment.

Impact on Open Access (OA) projects:

The proposed amendment is contrary to the provision in the draft Electricity Amendment bill (EA Bill) in the Parliament, and of many state policies.

The EA Bill says:

Sec 42(4):

“The open access consumers procuring electricity from renewable energy sources shall not be required to pay the surcharge for open access for such period as may be prescribed by the Central Government”

 Surcharge in the above context means cross-subsidy surcharge (CSS).

 If the EA Bill is to be passed by the Parliament, the impact of the 5th Amendment will be to make all RE projects in OA ineligible for RECs. This will discourage OA in renewable energy – something that goes against one of the principle objectives of the EA and of CERC (to encourage market development in the electricity sector).

Further, many states allow concessional cross-subsidy or exemption from cross-subsidy as a way to promote open access in RE projects. For example, Rajasthan’s solar policy exempts solar projects under open access from CSS. Similar provisions exist in many state policies.

Renewable Energy projects will not be viable under open access without concessional CSS provided by the states. States realize this – and therefore the concession exists in the first place. If RECs benefits were to be denied to such projects, it’s the equivalent of giving from one hand and taking from another. The net result of the amendment will be to completely finish-off the OA market for RE power – this is something that will be contrary to one of the fundamental pillars of the Electricity Act.

Further, in many existing OA transactions, prices are likely to have been negotiated knowing the fact that the RE project will get revenue from RECs. Such projects may suddenly become unviable. In many states with low tariffs, such projects will not remain competitive without RECs and therefore risk becoming NPAs.

Impact on Captive Generating (CGP) projects:

As mentioned above, the impact on CGPs of the amendment will be drastic. All CGP’s will be considered ineligible for RECs benefits. However, in proposing the amendment, CERC has failed to consider the case of two categories of projects–

(1)   CGPs set up specifically to meet RPO requirements, and

(2)   CGPs under the group captive mechanism

Since CERC amended the RECs regulation to allow self-retention of RECs by obligated entities, many companies have set up CGPs in one state and meet their obligation in other states through retention of RECs. This approach has multiple benefits – it has encouraged setting up of new RE capacity, and also helps the obligated entity manage its compliance costs.

The proposed amendment will take away this benefit to obligated entities. This is erroneous on three counts – (a) the CGP is likely to have been setup by the obligated entity to meet RPO across units. Such an investment, made in good faith keeping in mind existing regulations, may become redundant after the regulation, (b) it will discourage setting up of large new RE capacities as obligated entities will not be able to meet RPO in states that have low RE resources, and (c) it will take away a valid means for obligated entities to comply with RPO, leaving them with very limited options – buying of RECs.

Group captive projects, on the other hand, also face difficulties due to the amendment. In many group captive projects, the primary investment is made by an investor, and power prices are determined through negotiations. Further, such projects tend to be long term in nature as they involve an element of equity investment by the consumer. A sudden change in RECs eligibility is likely to make such projects unviable, and result in severe losses to investors who set up projects assuming a stable RECs regime.

Overall, we believe that while CERC’s intent to correct the supply imbalance in the RECs market is needed, the unintended consequence of the 5th amendment on open access and captive projects will be harmful to the growth of the renewable energy industry.

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