Additional suggestions on indian electricity grid code proposed to be ...

7. Clause 6.4 (21)The meters used at interconnections are termed as “interface meters” inCentral Electricity Authority (installation and operation of meters)Regulations, 2006. Accordingly, term ‘special energy meters’ used in thisclause and wherever appearing in the proposed IEGC should be replacedby the term “interface meters”. It may be pointed out that UI regulationsissued by CERC already used the term interface meters.8. Clause 6.4 (28)Commercial implications of inter-regional exchanges of power getreflected in the REA, UI accounts and Reactive Energy account preparedby RPC Secretariat concerned. Therefore, it appears that intention in theproposed IEGC is that NLDC should maintain statistics of inter-regionalexchanges of power. If so, the provision regarding energy accountingmay be reworded appropriately.9. Clause 6.5 (19)It is noted that in the UI regulations, a limit has been put on under injectionby the generator. To do so, the generators must have facility to revisetheir declaration in case of forced outages. However, this clause ofproposed IEGC allows only generator with two part tariff and long termcontract to revise their schedule in case of forced outage. Therefore tohave a level playing field and to enable generators to generate close totheir schedule, generators supplying through bilateral transactions underopen access should be given right to revise declaration in case of forcedoutages. Since such events are not so common in a well maintainedgenerating station, a limit say once per day may also be specified for thispurpose.10. Clause 6.5 (23)Wind forecasting tools are independent of the generating plant of the windfarms and therefore, there appears to be no technology related reason forproposal to exempt wind farms for which PPAs have already been signedfrom the requirement of wind forecasting. This exemption appears to havebeen made on the consideration that it will upset existing commercialagreements. In this regard, it needs no emphasis that new regulatoryinitiatives can always override prevailing contracts, like when ABT wasimplemented it altered the agreed commercial arrangement betweenexisting generating stations and their beneficiaries.5

Also, there appears to be ambiguity in the provisions regardingrevision of schedules due to two separate provisions- one regardingeffectiveness of the revision from the sixth time block and the otherregarding scheduling on 3 hour time slot basis. It is suggested thatrevision of the schedule should be effective only from the beginning ofnext 3 hour time slot, provided notice to this effect is given at least fourtime blocks in advance.12. Annexure I (Complimentary Commercial Mechanism)To bring in more clarity, it is suggested that Commercial Mechanismregarding renewable sources should be made part of a separateAnnexure.From para 1 and 2 of the Annexure, it appears that this mechanism isapplicable to ISGS only as no mention has been made about transactionsmade using access to ISTS. However, in para 4 regarding Renewablesources, it appears that these provisions are applicable to renewableISGS as well as to renewable energy sources supplying power usingaccess to ISTS. This aspect may be looked into while finalizing the IEGC.From para 5, it appears that in some cases, Renewable Regulatorycharge would be payable while in some other cases, it would bereceivable. Therefore, it is suggested that there should be a provision forcreation of a Renewable Energy Charge pool on the lines of UI pool.Also, it is suggested that there is need to relook into sharing of UIcharges between buying state and wind/solar generator particularly forover-injection exceeding 30%. In shortage conditions, when frequencymay be low (and hence UI rate will be high), the proposed provision mayprovide perverted incentive for the wind/solar generator to under-declarecapability and get lower schedules. Thereafter, he may over-inject beyondschedule in excess of 30% to earn undue money. This is particularly truesince no check is proposed on the forecasting tool of the wind/solargenerator. One way out could be to specify the requirement for forecastingtool that it will be free from manual intervention and forecasting resultsshould be recorded in such a manner that they can not be tampered with.If such technological requirement is not feasible, the proposed commercialmechanism may be re-casted to avoid such gaming.In para 6, it is proposed that for wind/solar generators, a maximumdeviation of 50% will be allowed in a time block. However, consequencesof deviations beyond 50% are not clear. Generally, grid security may beendangered only in case of over-injection. Such provision, withoutadditional financial implications may not serve the desired purpose.6