The Central Electricity Regulatory Commission (CERC) recently issued an order clarifying certain issues raised by Grid-India related to the implementation of General Network Access (GNA) regulations for projects connected to both state and central transmission utilities.

In its submission, Grid-India highlighted the difficulties of implementing GNA Regulations and requested clarification on a few aspects.

Some of the key issues raised by Grid-India are as follows:

Generating station connected to both STU and CTU system

Issue: Scheduling of Kanti Bijlee Utpadan Nigam

Grid-India raised concerns regarding Kanti Bijlee Utpadan Nigam Limited (KBUNL) Stage-II. KBUNL, currently considered a regional entity, generates 390 MW of power. However, it has been granted General Network Access (GNA) for only 121.6 MW, connectivity and Long Term Access to ISTS for 126 MW and 121.6 MW, respectively. It has dual connectivity, connecting with both the State Transmission Utility (STU) in Bihar and the Central Transmission Utility (CTU) for interstate transmission. The host state has the right to receive 289 MW of power from KBUNL, with 101 MW allocated for supply outside Bihar.

The primary challenge lies in how the Eastern Regional Load Dispatch Center (ERLDC) schedules the entire 390 MW of power from KBUNL, especially when deemed GNA is limited to 121.6 MW for interstate transmission. This issue becomes more intricate when Bihar does not request its allocated power. In such cases, KBUNL may face difficulties selling surplus power in the day-ahead market or scheduling it for other beneficiaries.

Commission’s Analysis

In KBUNL’s specific case, it has been granted Connectivity and Long Term Access to ISTS for 126 MW and 121.6 MW, respectively, with the remainder of the capacity effectively managed by the state system. Consequently, ERLDC could consider GNA equal to the installed capacity of KBUNL minus 126 MW for scheduling power from KBUNL’s bus bar.

In scenarios where KBUNL intends to transmit more than 126 MW of power to ISTS, it must obtain a “No Objection Certificate” (NOC) from Bihar. This certificate allows power scheduling outside the state, subject to wheeling charges as per SERC regulations.

Given KBUNL’s regional entity status, the power capacity will be scheduled at the generating station’s bus bar. The generator must submit the NOC to CTUIL and ERLDC to facilitate this process.

The generator is also allowed to surrender its connectivity to the host state and increase connectivity to ISTS, ensuring it does not exceed the installed capacity by paying applicable state charges as per SERC regulations.

This methodology applies to similar cases with comparable circumstances.

Issue: Scheduling of Dhariwal Infrastructure

Grid-India raised concerns about operating the first unit at Dhariwal Infrastructure (DIL) power station following the CERC order in the petition. According to this order, this unit falls under the jurisdiction of WRLDC for scheduling, and it was directed to consider any power injection from this unit as occurring through the STU network.

Maharashtra SLDC and STU have both consented to these arrangements. The Maharashtra state’s GNA calculation involved meter data from 2017-20 when the first unit was solely connected to the STU network and considered an intrastate entity. This unit has physical connectivity with STU and CTU but is not deemed as GNA. The CTU has approved a deemed GNA of 270 MW, and an additional 30 MW GNA application for another unit is under process.

DIL faced challenges due to the absence of GNA for its 39 MW merchant capacity since the implementation of the latest CERC GNA Regulations. It applied for an additional GNA of 39 MW to continue inter-state transactions through InSTS by paying a bank guarantee of ₹78 million (~$936,907). They requested the Commission to resolve this scheduling difficulty for 39 MW of merchant capacity from the first unit.

Commission’s Analysis

The CERC order mentioned that MSLDC and MSETCL had no objection to the proposed arrangement, provided that connectivity issues, commercial arrangements, scheduling, control area issues, transmission charges, and losses are addressed. WRLDC and Grid-India also saw no technical issues. Still, they suggested that DIL could surrender STU connectivity for the first unit and obtain an additional 300 MW ISTS connectivity from CTU for more scheduling flexibility.

In this context, it’s noted that DIL’s first unit was initially connected only to the STU system. The power station is scheduled by RLDC and is considered a regional entity. DIL has applied for the conversion of its connectivity to ISTS to GNA. The challenge is treating power beyond 300 MW, considering its connectivity to ISTS has been converted into GNA. This power may be sold to the host state or outside it.

Based on the CERC order and the consent of MSLDC and MSETCL, the Commission suggested that for scheduling power to the host state, RLDC should consider the quantum of connectivity with the host state as GNA at the generation busbar, including the connectivity quantum with STU.

However, if DIL wishes to schedule power outside the host state for more than 300 MW, it should be considered flowing through Maharastra’s transmission system. DIL would need an NOC from SLDC of Maharashtra to ensure the available capacity in the STU system to evacuate such power. They must also pay wheeling charges in case power exceeding 300 MW is scheduled to ISTS.

DIL’s application for additional GNA should be closed, and any bank guarantees submitted should be returned.

Issue: GNA_RE for the entity drawing renewable energy

Delhi Metro Rail Corporation (DMRC) has been availing power from the Rewa Ultra Mega Solar (RUMSL) project through Open Access since 2019, using the inter-state transmission network. CTU granted Long Term Access (LTA) to the solar power park developer for 99 MW, and DMRC obtained NOC for Long Term Open Access Power from DTL (STU) for 25 years.

DMRC’s average power consumption for operating metro trains in Delhi is 200MW, with a maximum of 250 MW. DMRC has 15 substations in Delhi, with direct connections to Delhi Transco Limited (DTL) substations at 66 and 220 kV levels. It draws 99 MW of solar power through open access, scheduling it in 15-minute blocks from 6:00 AM to 6:00 PM, and obtain the remaining energy from DISCOMs.

Delhi SLDC provisionally allocated GNA to DMRC, but there is no provision for GNA_RE allocation for entities exclusively using renewable energy. DMRC sought directions to ensure that its existing open access arrangement is covered in the new regime and that GNA_RE for 99 MW is granted.

The relevant GNA regulations state that entities covered under certain clauses may apply to GNA_RE for power drawn exclusively from renewable sources, and DMRC’s power consumption falls under this clause.

Regulation 18.1 of the GNA Regulations discusses the allocation of GNA to intra-state entities. DMRC has received provisional GNA from Delhi SLDC.

However, the transition of deemed GNA to GNA_RE for entities drawing power exclusively from renewable sources under the 2009 Connectivity Regulations is not explicitly addressed in the GNA Regulations.

Commission’s Analysis

Considering the regulations and DMRC’s situation, the central regulagtor suggested that entities transitioning from the 2009 Connectivity Regulations to the GNA Regulations, which qualify for GNA_RE, should have the option to convert their deemed GNA to GNA_RE. This should be a one-time provision during the transition, subject to proof of eligibility and an NOC from the host State’s SLDC to ensure adequate capacity in the STU system.

Any such consideration for GNARE, however, is subject to the condition that an entity having GNARE cannot have T-GNA or GNA as per the GNA Regulations.

Entities with GNARE can schedule power from any renewable source as per the regulations. Based on its specific contract with REWA, DMRC’s existing NOC for scheduling from 6 AM to 6 PM will suffice until it obtains a new NOC for scheduling power within 24 hours under GNARE.

Recently, CERC notified that certain provisions of the GNA Regulations and the First Amendment to the GNA Regulations 2022 will come into effect from October 1, 2023.

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