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					</table>The Central Electricity Regulatory Commission (<a href="https://cercind.gov.in/" target="_blank" rel="noopener">CERC</a>) recently issued an order clarifying issues raised by the Central Transmission Utility of India (<a href="https://www.ctuil.in/" target="_blank" rel="noopener">CTUIL</a>) and renewable developers under the GNA Regulations.
CTUIL, in its submission, highlighted the difficulties of implementing GNA Regulations and requested clarification on a few aspects.
Some of the key issues raised by CTUIL are as follows:
Issue 1: Processing under Grant of Connectivity, Long-term Access, and Medium-term Open Access in Interstate Transmission and Related Matters Regulations, 2009 post-April 5, 2023.
CTUIL argued that scheduling and billing processes have not yet commenced as per the Grid Code and CERC (Sharing of intr-State transmission charges and losses) Regulations of 2020. Therefore, CTUIL has taken steps to address tasks such as finalizing allocation, fulfilling the Section-68 requirement for the dedicated line, and activating Long-term Access (LTA) after April 5, 2023. These measures are being implemented under the 2009 Connectivity Regulations to ensure a seamless process for granting, operationalizing, and scheduling cases without disruptions.
Commission’s response
The Commission noted that as of April 5, 2023, power scheduling was still governed by the Indian Electricity Grid Code Regulations of 2010 for Long-Term Access (LTA), Medium Term Open Access (MTOA), and Short-Term Open Access (STOA). The Indian Electricity Grid Code Regulations of 2023, pertaining to scheduling under GNA, will be effective from October 1, 2023. This means that there exists a period from April 5, 2023, to September 30, 2023, during which entities seeking power scheduling may rely on the effectiveness of LTA, MTOA, or STOA.
Considering that the 2009 Connectivity Regulations will be repealed from October 1, 2023, the Commission permitted CTUIL to carry out the necessary activities under the 2009 Connectivity Regulations. These activities are crucial for ensuring a smooth transition during the interim perio Following the implementation of the Grid Code 2023 and the initial modification to the Sharing Regulations 2020, all actions must adhere strictly to the GNA Regulations.
Issue No.2: Retention of bank guarantee submitted under the 2009 Connectivity Regulations vs. submission of Conn-BGs (connectivity bank guarantee) under GNA Regulations.
CTUIL submitted that where two different bank guarantee amounts are required to be maintained under the 2009 Connectivity Regulations and the GNA Regulations, the higher of the bank guarantee amounts is being kept with CTUIL until the scheduling, billing, and relinquishment start as per the GNA Regulations.
Commission’s response
The Commission observed that the 2009 Connectivity Regulations will be repealed from October 1, 2023. For the transition period from April 5, 2023, to October 1, 2023, the Commission clarified that the higher bank guarantee under the 2009 Connectivity Regulations or the GNA Regulations would be considered by CTUIL for compliance. From October 1, 2023, bank guarantees will be modified in accordance with the GNA Regulations.
Issue 3: Conn-BG1 for cases covered under GNA Regulations.
CTUIL stated that entities falling under Regulation 37.3(3) are obligated to provide a Conn-BG1 with a value of ₹5 million (~$60,162) and a Conn-BG3 at ₹200,000 (~$2,406)/MW when there has been no prior provision of a construction bank guarantee for LTA. However, if such an entity has already submitted a Conn-BG1 for connectivity under 2009 regulations, there would be a situation where two Conn-BG1s are in place if another Conn-BG1 is also acquired under Regulation 37.3(3) of the GNA Regulations. CTU has received numerous representations requesting an exemption from the requirement to submit a new Conn-BG1 under the GNA Regulations in cases where a Conn-BG1 has already been submitted under the 2009 Connectivity Regulations.
Commission’s response
The Commission observed that construction bank guarantees provided under the 2009 Connectivity Regulations must be transformed into Conn-BG1 and Conn-BG2 per the GNA Regulations. In cases where an entity has not submitted any construction bank guarantee to CTUIL under the 2009 Connectivity Regulations, they will be obligated to provide a Conn-BG1 valued at ₹5 million (~$60,162) and a Conn-BG3 at ₹200,000 (~$2,406)/MW.
However, situations may arise where an entity has already submitted a Conn-BG1 worth ₹5 million (~$60,162) but has not furnished any construction bank guarantee under the 2009 Connectivity Regulations. In such instances, providing an additional Conn-BG1 under the GNA Regulations will not be required.
Issue 4: Conn-BG requirement for generating stations connected to the intrastate transmission system, which are not covered under Regulation 4.1 of the GNA Regulations.
CTUIL submitted that generating stations connected to the intrastate transmission system, whose LTA was granted on a target basis and became effective as of April 5, 2023, may be required to submit Conn-BG3 for ₹200,000 (~$2,406)/MW for the generating stations connected to the interstate transmission system.
Commission’s response
CERC observed that entities falling under Regulation 17.1(vi) of the GNA Regulations, for whom the LTA to the target region was already effective at the time of transition, will also be treated per the stipulations outlined in Regulation 37.6(2) of the GNA Regulations.
Issue 5: Advancement of the terminal bay for start-up power or injection of infirm power.
CTUIL said that Regulation 10.8 of the GNA Regulations provides that elements of the Automatic Transmission System (ATS) can be identified for early commissioning for the requirement of start-up power/injection of infirm power. A bay at the ISTS end may also be required besides ATS. Accordingly, the same needs to be incorporated into the regulations.
Commission’s response
The Commission emphasized that an entity might require certain components of the ATS before the agreed-upon start date of connectivity as specified in the connectivity agreement agreed that to initiate start-up power withdrawal or infirm power injection, an entity can request the commercial operation date of the terminal bay to be before the agreed-upon connectivity start date specified in the connectivity agreement.
Issue 6: Bifurcation of GNA as ‘within the region’ and ‘from outside the region’ under the application of GNA by entities covered under Regulation 17.1 (iii) of the GNA Regulations.
CTUIL suggested that GNA is to be applied in the case of entities, indicating bifurcation ‘within the region’ and ‘from outside the region’ as per Regulation 20.1. However, entities applying GNA for drawal of Round-the-Clock power have expressed difficulty in indicating the within and outside region GNA at the application stage due to scheduling of renewable power from different sources located in different regions during various points in time. Hence, GNA can be utilized solely for planning purposes for entities both ‘within the region’ and ‘from outside the region.’
Commission’s response
The Commission clarified that a drawee Designated Interstate Customer (DIC) can request a schedule from anywhere in India up to its GNA quantum, where such injection point may be ‘within the region’ or ‘from outside the region.’ Once such an entity has placed a scheduling request with the Regional Load Despatch Center (RLDC) and there is a constraint in the transmission system due to which a full schedule, as requested by all drawee DICs in the region cannot be accommodated, RLDC should allocate the transmission corridor as follows:
<ul>
<li>In case of constraint in the transmission system ‘from outside the region,’ the transmission corridor will be allocated proportionately to the ‘outside the region’ bifurcation of all such drawee DICs.</li>
<li>In case of constraint in the transmission system ‘within the region,’ the transmission corridor will be allocated proportionately to the total GNA quantum for such drawee DICs.</li>
</ul>
Issue 7: Bifurcation of GNA as ‘within the region’ and ‘from outside the region’ for states.
CTUIL suggested that while bifurcating the GNA deemed for each state, if the proportionate GNA ‘from outside the region is less than outside LTA/MTOA contracts, then the GNA ‘outside the region’ may be made equal to outside LTA/MTOA contracts.
Commission’s response
The Commission accepted CTUIL&#8217;s proposal. Additionally, any required modifications will be executed within the deemed GNA capacity within the region to ensure that the overall balance remains intact.
Issue 8: Timeline for processing new applications until October 1, 2023.
CTUIL submitted that the transition process needs to be completed before the fresh applications under GNA Regulations are processed due to their higher priority as per their original date of application. Accordingly, relaxation for processing new applications beyond the timelines specified in the GNA Regulations for an initial four months must be provided.
Commission’s response
The Commission noted that the transition of current applicants with connectivity, LTA, and MTOA to comply with the GNA Regulations involves multiple steps. To ensure the seamless implementation of the GNA Regulations, new applications can be handled once the transition cases are resolved. Recognizing that this transition process may span three to four months, the Commission extended the time for processing new applications received between April 5, 2023, and October 1, 2023. Beyond October 2023, these applications will be processed according to the timelines specified in the GNA regulations.
Issue No. 9: Connectivity by entities under Regulation 4.1 of the GNA Regulations, which are renewable energy generating stations or renewable power park developers.
Commission’s response
The Commission noted that, given the nature of power purchase agreements (PPAs), which are to be executed between the procurer and the selected bidder, it is appropriate to regard the PPA signed by the procurer as a valid document per regulation 5.8(xi) of the GNA Regulations. The Commission instructed its staff to initiate the process of amending the regulations to enable a more considered view of projects falling under such guidelines. Until this modification is finalized, a renewable energy generation facility will be eligible to request connectivity by submitting the PPA or opting for either of the other options involving land or bank guarantees.
Issue 10: Change in location by entities covered under Regulation 4.1 of the GNA Regulations, which are renewable energy generating stations or renewable power park developers.
CTUIL submitted that the provision for submission of registered title deeds or land documents was introduced in the GNA Regulations vide the First Amendment. Currently, the regulatory prescription is for submitting 50% of the land required for the project capacity for which connectivity is sought. Under the regulations, the remainder of the land required for the project is not required to be submitted to CTU at any stage post-grant of connectivity.
Commission’s response
The Commission recognized that, on occasion, adjustments to the designated land location for which connectivity has been approved may be necessary due to various factors. These factors could include alterations in the coordinates of the substation, proximity to the ISTS substation, a higher capacity utilization factor at different land locations, and unforeseen practical challenges in securing the complete land parcel near the initial land location. It said modifying the land parcel&#8217;s location while keeping the point of connectivity with the ISTS and the connectivity start date unchanged would be permissible and would not result in the cancellation of connectivity.
Issue 11: Change in requirement of Conn-BG3 in view of the order dated September 5, 2023.
CTUIL submitted that generation projects that have completed five years from commissioning, their respective Conn-BG requirements shall become NIL per the said CERC order dated September 5, 2023.
Commission’s response
The Commission stated that the contention of CTUIL generation projects that have completed five years from commissioning, their respective Conn-BG requirements, should become nil is incorrect. The entities must submit Conn-BGs as per the GNA Regulations.
Recently, CERC <a href="https://www.mercomindia.com/pending-provisions-gna-regulations-effect-october-1-2023" target="_blank" rel="noopener">notified</a> that certain provisions of the GNA Regulations and the First Amendment to the GNA Regulations 2022 will come into effect from October 1, 2023.
Subscribe to Mercom’s real-time <a href="https://mercomindia.com/product/mercoms-renewable-energy-regulatory-updates/" target="_blank" rel="noopener">Regulatory Updates</a> to ensure you don’t miss any critical updates from the renewable industry.

CERC Resolves Difficulties in Implementing GNA Regulations

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					</table>The Central Electricity Regulatory Commission (<a href="https://cercind.gov.in/" target="_blank" rel="noopener">CERC</a>) recently rejected a solar generator&#8217;s plea seeking an extension of the start date of medium-term open access (MTOA).
It said that the transmission charges towards MTOA should be billed to the buyer only after the generating station&#8217;s commercial operation date.
The Commission added that the bills corresponding to the capacity not commissioned, raised to the Haryana Power Purchase Center (HPPC) by the Central Transmission Utility (CTU), were contrary to the provision of the &#8216;Sharing Regulations.&#8217; Accordingly, it directed CTU to revise the bills and raise them on the petitioner.
Avaada Energy and Avaada RJHN had filed a petition seeking an extension of the start date of MTOA and restrain the CTU from taking any coercive measures for the non-operationalization of 114.25 MW out of the total 240 MW on the premise that the start date of MTOA was February 1, 2022.
Background
Avaada Energy was declared the successful bidder in a tender <a href="https://mercomindia.com/haryana-retender-300-mw-solar/" target="_blank" rel="noopener">floated</a> by HPPC to procure 300 MW of power from solar projects. Later, HPPC issued a letter of intent to purchase 240 MW of solar power from the proposed solar power project.
Avaada Energy applied for Stage I and Stage II connectivity, which CTU granted.
Avaada RJHN, a special purpose vehicle of Avaada Energy, entered into a power purchase agreement (PPA) with HPPC on July 6, 2020, for the supply of 240 MW of solar power.
For evacuation of the power from its project, the petitioner applied for long-term access (LTA) for 240 MW from January 5, 2022, which CTU granted. However, CTU informed Avaada Energy that the LTA would likely be operationalized only on September 25, 2022. Accordingly, Avaada Energy applied for MTOA for evacuation of power, which CTU granted for the period from February 1, 2022, to November 30, 2026.
Since the solar generator achieved the commercial operation of only 125.75 MW by the end of January 2022, it requested CTU for an extension of time for the part operationalization of MTOA for the balance of 114.25 MW up to May 23, 2022.
Avaada Energy submitted that the MTOA of the contracted capacity being 240 MW (out of which 125.75 MW capacity has already been commissioned), had been delayed due to the outbreak of COVID-19 and resultant lockdown, which were considered &#8216;force majeure&#8217; events.
Commission&#8217;s analysis
The Commission observed that Avaada Energy had requested CTU for part operationalization of MTOA upto 125.75 MW from February 1, 2022, and postponement of the balance of 114.25 MW upto May 23, 2022.
The Commission noted that as on February 1, 2022, the part capacity of the petitioner was already operational (125.75 MW) and was covered under the waiver of ISTS charges under the sharing regulations; hence no liability of transmission charges was due for such capacity. However, 114.25 MW was not commercial as on February 1, 2022, for which the petitioner was liable to pay transmission charges.
The state regulator noted that the petitioner had referred to &#8216;force majeure&#8217; events such as delay of supply from Chinese manufacturers and Covid-19 while requesting an extension of the start date of MTOA. It said that the petitioner had not placed any force majeure notice on record, nor does the MTOA agreement or the connectivity regulations have any provision for force majeure.
It said that the MTOA agreement and the connectivity regulations do not have any provision to defer the start date of LTA or MTOA.
The MTOA agreement as per Regulation 13 of the sharing regulations, provides that transmission charges should be according to CERC norms. Moreover, per the sharing regulations, the petitioner had agreed to share and pay all the applicable transmission charges of the existing transmission system from the commencement of MTOA.
The transmission charges towards MTOA should be billed to the buyer only after the commercial operation date of the generating station. CERC observed that the bills that corresponded to the capacity not commissioned and raised to HPPC by CTU were contrary to the provisions of the sharing regulations. Accordingly, CERC directed CTU to revise the bills and raise the bills on the petitioner per law.
In December 2020, the Haryana Electricity Regulatory Commission had <a href="https://mercomindia.com/haryana-regulator-open-access-solar/" target="_blank" rel="noopener">issued</a> an order extending the scheduled commissioning date for a 50 MW open access solar project in the state. It had also approved the PPA for the project meant to help HPPC meet its renewable purchase obligation (RPO) targets.
Subscribe to Mercom&#8217;s real-time <a href="https://mercomindia.com/product/mercoms-renewable-energy-regulatory-updates/" target="_blank" rel="noopener">Regulatory Updates </a>to ensure you don&#8217;t miss any critical updates from the renewable industry.

CERC Denies Start Date Extension of Medium-Term Open Access for a Solar Project

The Maharashtra Electricity Regulatory Commission (<a href="https://www.merc.gov.in/" target="_blank" rel="noopener noreferrer">MERC</a>) has rejected a wind power developer’s petition contesting the Maharashtra State Electricity Distribution Company Limited’s (<a href="https://www.mahadiscom.in/" target="_blank" rel="noopener noreferrer">MSEDCL</a>) decision to reject open access to its customers.
The consumers had applied for additional power over the contracted demand. On this, the Commission ruled that distribution licensees can only allow it only if the resultant power flow could be accommodated in the existing distribution system.
Background: 
AMJ Land Holdings had filed a petition stating that its consumers were wrongly denied permission to obtain open access power from its wind power projects in the state.
The 4.6 MW of wind projects are located at Satara and Sangli in the state of Maharashtra. The company sought the Commission’s directions to MSEDCL to grant open access to the extent sought by its consumers Jehangir Hospital and Pudumjee Paper Products Limited.
The petitioner explained that MSEDCL had granted medium-term open access permissions for 1.25 MW of wind power to Jehangir Hospital from April 1, 2016, to March 31, 2017. It also approved its application for short-term open access for December 2017 for an additional 1.25 MW of power from the petitioner’s projects.
However, the DISCOM rejected the hospital’s application for 1.25 MW of power through short-term open access for January 2017, citing that it was already availing medium-term open access for 1.25 MW and that the date was not specified in the short-term application.
The petitioner noted that it had also applied for short-term open access for the same capacity for February 2017, which was accepted. It argued that the grounds on which January’s application was rejected was arbitrary.
Another consumer submitted a short-term application for 5 MW of power from a conventional source through open access in May 2017. However, only 1.4 MW of this was approved. It went on to explain that Pudumjee Paper Products had also asked for medium-term open access in January 2017 for 2.1 MW of open access power from its projects between May 2017 to March 2018, but this was not granted by the MSEDCL, either.
The petition, citing these examples, argued that MSEDCL arbitrarily rejected open access applications on its “whims and fancies” without a valid ground. It sought the Commission to direct MSEDCL to grant open access to the extent sought by Jehangir Hospital. The company also expected compensation in the form of credit notes or payment at the preferential tariff from the MSEDCL for the unadjusted power injected into the grid in January and May of 2017.
Commission’s Stand: 
Upon analysis, the Commission said that short-term open access could only be allowed if the final power flow can be accommodated in the existing system as per the provisions of its Distribution Open Access regulations.
It cited practice directions from October 2016, which stated that if a consumer does not revise their contract demand with the distribution licensee, it may be assumed that it seeks open access over and above the contracted demand. In this case, the distribution licensee can allow any excess open access power if the existing distribution system can accommodate the resultant power flow.
The Commission also noted that the resultant power flow has to be examined for each application on an individual basis to see if it can be accommodated in the distribution system for each particular month or period. It said that these need not necessarily be based on open access granted for previous months.
The MERC opined that the rejection of Jehangir Hospital’s application for January 2017 was appropriate on account of the issues caused by the resultant power flow and the date not being mentioned in the application.
It went on to state that the Pudumjee Paper Product’s application for May 2017 was also restricted as the distribution system could not accommodate the resultant power flow as per the MSEDLC’s calculations.
Having said this, the Commission went on to say that licensees can grant short or medium-term open access if the resultant power flow is higher than what the system can accommodate and that they can inform the applicant of any upgrades that the system may require. In this regard, it observed that the annual banking facility for renewable generators is not being used ideally to the extent that it could be under this provision.
It noted that consumers sought more open access power than their contracted capacities as the capacity utilization factor (CUF) of renewable energy generators is very low and that higher generation capacity is required for meeting energy needs. It said that contracting renewable capacity at multiple times of the consumer load would be a deterrent to the stability of the grid and the quality of the power.
It concluded, stating that since the MSEDCL did not technically delay the medium-term open access, there was no need to issue any direction to it for doing so. With this, the Commission dismissed the petition.
In April, the Maharashtra Electricity Regulatory Commission <a href="https://mercomindia.com/maharashtra-open-access-additional-surcharge/" target="_blank" rel="noopener noreferrer">announced</a> various charges payable by open access consumers for the financial year 2020-21 to 2024-25. The MSEDCL said that consumers were buying a considerable amount of power under open access, and on the other hand, it has tied up a sufficient amount of power to meet the expected demand by considering the overall growth in the state.
Previously, MERC had <a href="https://mercomindia.com/maharashtra-discom-open-access-captive-wind-generators/" target="_blank" rel="noopener noreferrer">issued</a> a common order for five petitions filed because of a dispute regarding the denial of short and medium-term open access by MSEDCL citing the non-installation of individual special energy meters for their captive windmills.
Read all about India’s open access segment for solar power <a href="https://mercomindia.com/adoption-solar-open-access-roadblocks/" target="_blank" rel="noopener noreferrer">here</a>.
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Image credit: Unsplash

Maharashtra Regulator on Additional Open Access Power Over Contracted Demand

In response to a petition by ACME Holding, the Central Electricity Regulatory Commission (<a href="http://www.cercind.gov.in/" target="_blank" rel="noopener noreferrer">CERC</a>) has asked Power Grid Corporation of India Limited (PGCIL) to notify ACME the date of operationalization of medium-term open access (MTOA) so that it can take appropriate steps for the synchronization of its solar project.
The commission has directed the respondent to file its reply by October 10, 2019. The PGCIL has also been directed by CERC to not take any coercive measures against the petitioners (ACME) until the next date of hearing, which is on October 15, 2019.
Background
ACME Solar Holdings Limited and ACME Chittorgarh Solar Energy Private Limited, jointly filed a petition seeking to quash the letter dated July 2, 2019, issued by PGCIL, directing the petitioners to open the letter of credit.
The first petitioner, ACME Holding, had participated in the bidding process <a href="https://mercomindia.com/msedcl-retenders-1-gw-solar-meet-rpo/" target="_blank" rel="noopener noreferrer">initiated</a> by Maharashtra State Electricity Distribution Company Limited (<a href="http://www.mahadiscom.in/" target="_blank" rel="noopener noreferrer">MSEDCL</a>) for 1 GW of solar power projects through competitive bidding. Later, it was <a href="https://mercomindia.com/l1-tariff-1gw-solar-auction-msedcl/" target="_blank" rel="noopener noreferrer">declared</a> a successful bidder to develop a 250 MW solar project, which is located at Badisid in Rajasthan.
The lowest tariff quoted was ₹2.71 (~$0.0401)/kWh in the auction held by MSEDCL to develop 1 GW of solar projects in the state. This was the lowest solar tariff for a grid-connected solar PV project in Maharashtra. ReNew Power and ACME Solar Holdings had <a href="https://mercomindia.com/l1-tariff-1gw-solar-auction-msedcl/" target="_blank" rel="noopener noreferrer">quoted</a> ₹2.72 (~$0.0402)/kWh to develop 250 MW each.
In 2018, PGCIL granted stage -I and stage-II connectivity to ACME Holdings.
On August 23, 2018, ACME Holdings made an application to PGCIL for granting long-term access (LTA). The PGCIL then requested ACME Holdings to apply for MTOA (medium-term open access) since the LTA was not ready to which the firm complied.
However, later in January 2019, PGCIL intimated ACME about the grant of MTOA against the already applied LTA for the evacuation of 250 MW of solar power.
Through its letter dated July 2, 2019, PGCIL informed ACME Holdings that it needs to furnish a letter of credit for ₹256.5 million (~$3.62 million) in favor of PGCIL towards payment security mechanism.
The petitioner has mentioned that, to date, PGCIL has not indicated the date of the operationalization of MTOA. As per the MTOA agreement, PGCIL is required to put into operation its assets by September 16, 2019.
According to the petition, “ACME Holdings is required to give at least 30 days’ notice to MSEDCL for synchronization, but due to non-responsiveness of PGCIL, ACME Holdings has been compelled to forego its right of early commissioning of its generating station.”
The petitioner has expressed apprehension that PGCIL may cancel the MTOA granted to ACME Holdings, which will have a “detrimental financial impact on the project.”
Based on these developments, the ACME Holdings and ACME Chittorgarh Solar Energy Private Limited filed a petition requesting the commission to quash the letter dated July 2, 2019, issued by PGCIL and hold that it is illegal and arbitrary. It has requested the commission to declare that the petitioner is not liable to open any letter of credit as a payment security mechanism.
The petitioners also requested the commission to direct PGCIL to allow the company to connect, synchronize, test, and commission its project without demanding the letter of credit and further direct it to not to take any coercive action, including the termination or cancellation of LTOA or MTOA.
After going through the petition, the commission has asked PGCIL to file its reply and in the meantime, not initiate any coercive action against ACME. It has also directed PGCIL to inform ACME about the likely date of operationalization of the MTOA so that it can make necessary preparations. It has provided 15 days for PGCIL to notify the date of operationalization of the MTOA.

CERC Rules in Favor of Solar Developer ACME, Asks PGCIL To Grant Medium-Term Open Access

The National Thermal Power Corporation (<a href="https://www.ntpc.co.in/" target="_blank" rel="noopener">NTPC</a>) is going to procure 1,000 MW of renewable energy on a short-term basis. NTPC has issued a tender to procure power from the existing solar photovoltaic (PV) power projects and wind power projects of cumulative capacity up to 1,000 MW. Selection of power generators will be carried out through reverse bidding.
The minimum offered capacity from a single renewable energy project will be 50 MW and in multiples of 10 MW thereafter. A bidder can offer power from multiple solar and wind power projects. A single bidder must quote one tariff for all the projects that he/she intends to sell power from. A single bidder can choose to supply the entire capacity that the NTPC is looking to procure, 1,000 MW.
The bid-submission deadline is December 20, 2018. The solar PV or wind projects can be located anywhere in India. Bidders must indicate the location of the projects at the tie of bidding. Renewable energy projects having interstate transmission system (ISTS) connectivity will be eligible for participating in this tender.
The entire cost of transmission, including the cost of construction of line, wheeling charges, losses will be borne by the power generator and will not be reimbursed by NTPC or met by the state transmission utility (STU)/central transmission utility (CTU)/ distribution company (DISCOM).
The responsibility of getting medium term open access (MTOA) to the transmission system owned by the CTU will lie with NTPC and will be at the cost of NTPC.
The bidders will have to submit bids quoting a fixed levelized tariff for entire power purchase agreement (PPA) duration of one year. This will be the “First Round Tariff Bid” of the bidder after which the shortlisted bidders will be invited for the reverse auction. The ceiling limit for “First Round Tariff Bid” will be ₹2.67 (~$0.037)/kWh. Any bid with “First Round Tariff Bid” higher than the ceiling limit of ₹2.67/kWh will be rejected.
According to NTPC, the PPA will be signed between NTPC and successful bidders. The PPA will be executed within 120 days of the date of issue of Letter of Intent. Separate PPA will be executed between NTPC and power generator for each project.
The PPA will be for a period of one year from the scheduled date of commencement of supply of power. The PPA will be extendable up to six months if mutually agreed by NTPC and power generator. The PPA tariff will remain fixed for entire duration of PPA.
A <a href="https://mercomindia.com/ntpc-tender-1-2-gw-solar-maharashtra/" target="_blank" rel="noopener">few weeks ago</a>, NTPC tendered 1,200 MW of interstate transmission system (ISTS)-connected solar photovoltaic (PV) projects to be developed in the western region of the country. The bid-submission deadline is December 19, 2018. <a href="https://mercomindia.com/ntpc-tender-60mw-solar-130mw-wind-hybrid/" target="_blank" rel="noopener">Before that</a>, it invited bids for the development of wind-solar hybrid power project at NTPC, located in Kudgi, Karnataka.
<a href="https://mercomindia.com/merc-msedcl-renewable-bidding/" target="_blank" rel="noopener">Similarly, back in December 2017</a>, Maharashtra State Electricity Distribution Company Limited (<a href="https://www.google.com/url?sa=t&amp;rct=j&amp;q=&amp;esrc=s&amp;source=web&amp;cd=1&amp;cad=rja&amp;uact=8&amp;ved=0ahUKEwi3tv6uoJXYAhVD8IMKHepjCLoQFggpMAA&amp;url=http%3A%2F%2Fwww.mahadiscom.com%2F&amp;usg=AOvVaw2QxivFcdTQaLrnZ2QmlQTP" target="_blank" rel="noopener">MSEDCL</a>) had won the approval to procure wind, solar, and bagasse‑based cogeneration power at a rate discovered through a tariff‑based competitive bidding process. The Maharashtra Electricity Regulatory Commission (<a href="https://www.google.com/url?sa=t&amp;rct=j&amp;q=&amp;esrc=s&amp;source=web&amp;cd=1&amp;cad=rja&amp;uact=8&amp;ved=0ahUKEwjA_q--oJXYAhWI2YMKHfUxA-EQFggpMAA&amp;url=http%3A%2F%2Fwww.mercindia.org.in%2F&amp;usg=AOvVaw1c9yQPF60gFUZwOCtJu29q" target="_blank" rel="noopener">MERC</a>) approved MSEDCL’s petition so that the agency could effectively procure the power it needs to meet its Renewable Purchase Obligation (RPO). Rates could be discovered for the procurement of power on a short-term, medium-term, and long-term basis.
<a href="https://mercomindia.com/ntpc-acme-solar-tariff-dispute-2-gw-auction/" target="_blank" rel="noopener">Meanwhile</a>, NTPC and project developer ACME Solar have been embroiled in a legal battle pertaining to a recent solar auction for the development of 2 GW of solar projects.
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NTPC to Procure 1,000 MW of Power from Existing Solar and Wind Projects on Short-Term Basis

The Maharashtra Electricity Regulatory Commission (<a href="http://www.mercindia.org.in/" target="_blank" rel="noopener">MERC</a>) has announced open access charges for consumers in the state. These charges are applicable from September 1, 2018.
MERC fixed the open access charges in response to a petition filed by Maharashtra State Electricity Distribution Co. Ltd (<a href="https://www.mahadiscom.in/" target="_blank" rel="noopener">MSEDCL</a>) in the matter of mid-term review for aggregate revenue requirement (ARR) of financial year (FY) 2015-16 and FY 2016-17, provisional truing-up of ARR of FY 2017-18 and revised projections of ARR for FY 2018-19 and FY 2019-20.
In its petition, MSEDCL had proposed a processing fee as well as operating charges for open access. To justify the proposed hike in open access charges, the MSEDCL in its petition stated, “As per MERC Distribution Open Access Regulation 2016, an open access consumer can avail open access from multiple generators and multiple sources. Due to this, number of applications have increased. MSEDCL has developed online system for submission of application for availing open access.”
<a href="https://mercomindia.com/wp-content/uploads/2018/09/open.png"><img loading="lazy" decoding="async" class="aligncenter size-full wp-image-11316" src="https://mercomindia.com/wp-content/uploads/2018/09/open.png" alt="" width="464" height="207" srcset="https://cms.mercomindia.com/wp-content/uploads/2018/09/open.png 464w, https://cms.mercomindia.com/wp-content/uploads/2018/09/open-300x134.png 300w" sizes="(max-width: 464px) 100vw, 464px" /></a>
“The number of consumers availing short term open access are more, the consumers apply every month and upload the required documents in the online system having 50 to 100 MB capacity. Thus, MSEDCL has to purchase additional storage space to save all the documents every month in the online system. A separate IT system is developed for proper operation of the online system for submission and processing of open access applications. MSEDCL has developed online system for paying the processing fees with the application. Thus, MSEDCL must pay service charges to the service provider of online payment system,” stated the petition.
While reviewing the petition, MERC was of the view that most of the above activities fall under normal activities of MSEDCL as a licensee. MERC also opined that there are a few services required to be provided by MSEDCL to open access consumers, where MSEDCL may incur some costs. The commission also noted that MSEDCL introduced various online facilities for the benefit of the open access consumers.
<a href="https://mercomindia.com/wp-content/uploads/2018/09/open2.png"><img loading="lazy" decoding="async" class="aligncenter size-full wp-image-11317" src="https://mercomindia.com/wp-content/uploads/2018/09/open2.png" alt="" width="470" height="206" srcset="https://cms.mercomindia.com/wp-content/uploads/2018/09/open2.png 470w, https://cms.mercomindia.com/wp-content/uploads/2018/09/open2-300x131.png 300w" sizes="(max-width: 470px) 100vw, 470px" /></a>
In its final order, the MERC approved slightly lower charges of open access than what had been proposed by MSEDCL.
<a href="https://mercomindia.com/merc-clarifies-terms-granting-open-access-solar/" target="_blank" rel="noopener">Recently</a>, in a ruling, the MERC had clarified that the nodal agency will grant medium-term open access (MTOA) or short-term open access (STOA) in the existing distribution system only if the resultant power flow can be accommodated.

MERC Sets Open Access Charges for Maharashtra

A ruling by the Maharashtra Electricity Regulatory Commission (<a href="http://www.mercindia.org.in/" target="_blank" rel="noopener">MERC</a>) has clarified that the nodal agency will grant medium-term open access (MTOA) or short-term open access (STOA) in the existing distribution system only if the resultant power flow can be accommodated.
The MERC heard a petition filed by Roha Dyechem Pvt. Ltd. (RDPL) seeking MERC’s directions to Maharashtra State Electricity Distribution Company Limited (<a href="http://www.mahadiscom.in/" target="_blank" rel="noopener">MSEDCL</a>) regarding the terms of open access permissions.
What Was the Case About?
RDPL set up 15 MW solar photovoltaic (PV) project in two phases (10 MW and 5 MW) in the 30 MW solar park located in Akola district. RDPL intended to use solar energy under open access at its Mumbai plant.
RDPL submitted its open access application of 10 MW for self-use. However, the request was not granted by MSEDCL, citing excessive resultant power flow.
According to MSEDCL, RDPL submitted its application on February 2, 2018 seeking STOA for the project from March 1, 2018 to March 31, 2018. However, it was observed that the resultant power flow, taking into consideration various factors like the contract demand and solar generation capacity utilization factor (CUF) was 3.928 MVA whereas the power which could be accommodated as per the metering constraint is only 2.85 MVA.
MSEDCL had requested RDPL to confirm the STOA demand or a contract demand to be processed so that the resultant power flow could be accommodated into the existing distribution system. RDPL did not submit the compliance as requested by MSEDCL within the stipulated period.
Instead, RDPL requested MSEDCL to consider the allotment of open access for 5 MW for the period of March 1, 2018 to March 31, 2018 which was granted by MSEDCL.
RDPL again submitted application for STOA of 10 MW. When being asked by MSEDCL to reconsider, the firm approached MERC.
The Ruling
MERC did not accept the plea of RDPL to direct MSEDCL to grant open access permission for the quantum of 10 MW from its solar PV project.
The MERC directed MSEDCL to examine the issue afresh in a holistic manner, considering all provisions and metering infrastructure and to inform the petitioner (RDPL) accordingly.
In <a href="https://mercomindia.com/solar-power-companies-open-access-net-metering/" target="_blank" rel="noopener">June 2018</a>, the MERC also clarified that generators cannot use both open access and net metering simultaneously, and reiterated that the benefits of net-metering are limited to rooftop solar installations of only up to 1 MW.

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