Analysis of RERC's order on the Forecasting & Scheduling Regulations

Rajasthan Electricity Regulatory Commission published an order announcing judgments to the current Forecasting & Scheduling regulations post several petitions filed over issues stated below along with the resolutions:

• Adjustment of inter-state and intra-state power

One of the main issues under consideration was the order in which inter-state and intra-state power were adjusted on pooling stations where electrical separation is not possible. The earlier regulation resulted in significantly higher DSM for the inter-state portion. RERC changed this to adjust inter-state and intra-state DSM in the ratio of such power. The order states the following:
“in case of electrical separation not being possible, then a combined schedule of inter and intrastate transaction with bifurcated interstate (with state wise bifurcation) and intrastate (with Discoms/ deemed licensee wise bifurcation) schedule shall be allowed and actual generation of the connected generators shall be considered and adjusted in the ratio of inter and intrastate schedules.” – Paragraph 247 in the order

• Billing on schedule and recovery of revenue component in DSM

The second major issue raised by the petitioners was that for inter-state power, billing on the schedule was not yet operational. This caused a problem as DSM calculations also included recovery or payment of revenue relating to the difference between the scheduled and actual generation. In its order, RERC has laid down procedures for certifying of schedules by the
SLDC – this will enable billing on schedule. However, since DSM has been made applicable from Oct 2018, the onus will now be on NVVN/ SECI to ensure that past billing on schedule is settled.

• Timelines for DSM implementation

RERC has waived off DSM charges till September 30, 2018, and has made it applicable from Oct 2018, based on the below schedule:

Similar relief has also been provided for DSM charges for inter-state power (Paras 279 A and B). 
This is a significant relief provided to generators by the honorable RERC. 
RERC further said that SLDC will be re-calculate DSM based for the above timelines till Nov 15 after which comments shall have to be submitted to SLDC in 15 days. The generators will be required to make DSM payments in one month from the issue of final bills.
“This means SLDC is directed will revise the bills towards deviation charges already issued by it and raise fresh bills on all Generators/QCA accordingly. Bills till August 2019 shall be raised by 15th November 2019 by giving Generators/QCA 15 days for filing objections and Generators/QCA shall deposit the amount within 30 days of issue of finalized bills.”
Other than the above issues, other key points which have been discussed in the order are as follows:

• RERC rejected the request for “Aggregation” of schedules stating 

“The Commission agrees with the view of the SLDC that Aggregation at State level would result in no deviation charges for the error band of +/- 15% for such a large penetration of Renewable Energy and such magnitude would be detrimental to the stability of the Grid. This would result in a huge liability of DSM charges on the State Discoms, which will otherwise have to be passed on to the end consumers” (Para 180). RERC also deleted the clause relating to the virtual pool in the original regulations (Para 185). 
RERC has directed all generators to install check meters at RVPN GSS within 4 months (Para 191). The specifications of the new ABT meter, DCU (Data Concentrator Unit) and meter box along with Modems are available on RVPN’s website and the same is to be integrated with servers of STOMS control center at SLDC.