The Forum of Regulators (FoR) has notified the Model Regulations for Calculation of Open Access and Banking Charges for Green Energy Open Access Consumers, in line with the Ministry of Power’s (MoP) Electricity (Promoting Renewable Energy through Green Energy Open Access) Rules, 2022. The model regulation provides a framework for the computation of transmission charges, wheeling charges and cross-subsidy surcharge (CSS) for consumers availing green energy open access.
The working group constituted to frame the regulations studied and analysed the issues and challenges around the implementation of the green open access rules issued by the MoP. It also sought and examined the comments of various state electricity regulatory commissions (SERCs) on the green open access rules, and analysed open access and banking charges across states. The group has suggested various permissible charges under green open access to promote green energy while meeting the prudent costs of the distribution licensee, as well as a methodology for calculation of green energy open access charges and banking charges.
Details of the draft model regulation
The FoR’s model regulations are to be called the State Electricity Regulatory Commission (Methodology for Determination of Green Energy Open Access Charges) Regulations, 2022. They will be applicable when allowing open access to electricity generated from green energy sources, including the energy from non-fossil fuel-based waste-to-energy plants for use in intra-state transmission systems (InSTS) or distribution systems or both, which are incidental to the inter-state transmission of electricity. The charges on green energy open access consumers will include transmission charges, wheeling charges, CSS, standby charges wherever applicable, banking charges, and other fees and charges such as state load despatch centre (SLDC) fees and scheduling charges, as well as deviation settlement charges as per the relevant regulations of the commission.
Transmission charges: For use of the interstate transmission system (ISTS), transmission charges will be specified by the central commission from time to time. Meanwhile, for use of InSTS, transmission charges for long-term/medium-term green energy open access, will be computed as the total transmission system charges (TTSC) divided by peak load served (PLS). The TTSC for InSTS will be the sum of the annual revenue requirement (ARR) or annual transmission service charge of transmission licensee(s) in the state approved or adopted by the commission, while PLS is the peak load served by the state transmission system during the year. In the case of multiple transmission licensees in the states, the ARR for all the transmission licensees will be pooled together to compute the TTSC. Transmission charges will be calculated as Rs per kW per month, or Rs per MW per day.
Transmission charges for short-term green energy open access will be computed as TTSC divided by energy transmitted by the transmission licensee during the year. They will be computed in Rs per kWh and will be charged on the actual energy transmitted.
In cases where a dedicated open access transmission system has been constructed for the exclusive use of an open access consumer, the transmission charges will be worked out by the transmission licensee and approved by the appropriate commission. In addition to transmission charges, intra-state transmission losses will be applicable to consumers seeking green energy open access. It will be determined as the average of 52-week intra-state transmission losses for the previous financial year, as approved by the commission.
Wheeling charges: Wheeling charges for long-term/medium-term/short-term green energy open access will be computed as the wheeling ARR divided by energy wheeled during the year. Distribution licensees will need to maintain separate accounting records for the wire and retail supply businesses, and prepare an allocation statement based on the allocation ratio specified by the commission, for determination of the wheeling ARR for the wire business and the wheeling charges thereof. Wheeling charges for green energy open access will be computed in Rs per kWh and will be charged on the actual energy wheeled. In addition to wheeling charges, wheeling losses will be applicable to consumers seeking green energy open access and will be determined as the average of 52-week wheeling losses for the previous year.
CSS: If the green energy open access facility is availed by a cross-subsidising consumer of a distribution licensee of the state, then such consumer, in addition to transmission and wheeling charges, will pay CSS as determined by the commission. It will be payable monthly, based on the actual energy drawn during the month through open access. The surcharge will be payable to the distribution licensee in the area where the consumer was availing supply before seeking open access. The CSS will be determined in accordance with the formula specified in the Tariff Policy, 2016 and amended from time to time. The CSS will not exceed 20 per cent of the tariff or average billing rate applicable to the category of consumers seeking green energy open access. The CSS will not be levied in case distribution access is provided to a person who has been availing green power from a plant established as a captive generation plant for their own use. Further, CSS and additional surcharge will not be applicable in case power produced from a non-fossil fuel-based waste-to-energy plant is supplied to the open access consumer.
Standby facility and charges: In case a green energy open access consumer is unable to procure/schedule power from the generating sources with whom they have power procurement agreements due to outages of generators, transmission systems and the like, the standby arrangement will be provided to the consumer by the distribution licensee in the area of supply. The standby charges for such an arrangement will be 125 per cent of the normal tariff in the consumer category. Standby charges will not be applicable if the green energy open access consumers give notice regarding the standby arrangement to the distribution licensee at least a day in advance of gate closure of the day-ahead market on D-1 day, D being the day of delivery of power.
Banking facility and charges: Banking facility will be provided to consumers availing green energy open access. Any surplus energy from a green energy generating station after set-off will be banked with the distribution licensee. The banking facility, including injection of surplus energy and drawal of banked energy, will be subject to scheduling. The banking charges will be adjusted in kind at 8 per cent of the energy banked. The banking of energy will be permitted only on a monthly basis as per calendar months.
The credit for banked energy will not be permitted to be carried forward to subsequent months and will be adjusted during the same month as per the energy injected in the respective time-of-day (ToD) slots determined by the commission. Further, the energy banked during peak ToD slots will be permitted to be drawn during peak as well as off-peak ToD slots.
However, the energy banked during off-peak ToD slots will only be permitted to be drawn during off-peak ToD slots by paying the banking charges, and from off-peak ToD slots to peak ToD slots by paying additional charges as may be specified by the appropriate commission. Any unutilised surplus banked energy at the end of a month will be considered as lapsed. However, the renewable energy generating station will be entitled to renewable energy certificates to the extent of the lapsed energy.
Other charges: A consumer availing green energy open access will also need to pay applicable SLDC fees and charges, scheduling charges, and renewable energy deviation settlement charges.
To conclude, the adoption of a common calculation methodology for open access charges will bring consistency in the charges levied on green energy open access customers across all states, promote greater adoption of green energy open access. The FoR model regulation is a welcome move to harmonise the green energy open access framework across the country.