Open Access Regulations & Operationalization

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Open Access Regulations & Operationalization IIT Kanpur 27 th April 2017 For Public Use

Indian Power Market Historical Perspective Pre 2003 Bundled Utilities Single buyer model Few transactions (month-wise) Generation Licensed activity 2003-2008 Unbundling of SEBs. Emphasis on market Development Large no. of transactions Bilateral market Trading on Day and ToD basis Post 2008 Power Exchanges commence Multilateral transactions Different products at PXs to manage power portfolios

Legislative Enabler for Operationalization of Power Markets Electricity Act, 2003 Intent of the Act was to promote competition by freeing all possible avenues of procurement and sale of power: De-licensing of generation Development of a multi-buyer multi-seller market in power Trading licensed activity. Non Discriminatory open access Development of Power Market Section 66 of the Electricity Act 2003 gives powers to the regulatory commissions to develop the power market including trading

Provision for Open Access in Electricity Act 2003 Section 2(47) of the Act defines Open Access to mean non-discriminatory provision for the use of transmission lines or distribution system or associated facilities with such lines or system by any licensee or consumer or a person engaged in generation in accordance with the regulations specified by the Appropriate Commission Section 42 of the Act is central to open access and reads as follows: "(2)The State Commission shall introduce open access in such phases and subject to such conditions,(including the cross subsidies, and other operational constraints) as may be specified within one year of the appointed date by it and in specifying the extent of open access in successive phases and in determining the charges for wheeling, it shall have due regard to all relevant factors including such cross subsidies, and other operational constraints

Opportunities for 1. Generating Companies No license required for developing a Gen station; could sell power to any person through OA; Easy change in purchaser in the event of default in honoring contract by purchaser. 2. Consumers Buy power from anywhere could explore cheaper sources; specially useful for high demand IND / COM consumers. Industrial houses could consolidate power supply to plants at various locations & build captive power plant to achieve economy

Why Open Access? Provision of non discriminatory open access Opening up of the electricity market Increase in the choices for all the stakeholders A vibrant, dynamic and competitive market Supply of power to all Optimal use of resources

Regulations for Development of Open Access Availability based tariff (ABT) introduced in 1998. ABT is a commercial mechanism in which fixed and variable cost components are treated separately. And variable cost is paid as per the schedule and the Difference between schedule and actual is paid as per system condition(frequency) known as unscheduled interchange (UI). Power is scheduled by SLDC s on merit order based on the variable cost. All earlier Acts and Rules enacted were repealed by enactment of Electricity act 2003 CERC (Procedure, Terms & Conditions for grant of Trading License and other related matters) Regulations, 2004. CERC (Sharing of Inter State Transmission Charges and Losses) Regulations, 2010. CERC (Grant of Connectivity, Long-term Access and Medium-term Open Access in inter-state Transmission and related matters) Regulations,2009. CERC (Deviation Settlement Mechanism and related matters) Regulations, 2014. CERC Open-Access regulation,2008-included collective transaction for mechanism of operation of PX keep the identity of buyer/ seller unknown to bidders CERC (IEGC) regulations 2010 (IEGC Grid code)

Policy Initiative for Market Development National Electricity Policy, 2005 ~15% of new generation can be sold outside PPA To increase the depth of power markets Additional alternative to generators and licensees/consumers to sell/purchase power which would facilitate reduction in tariff in long run As power markets develop, financing projects with competitive generation costs outside long-term PPA would be feasible Development of Power Market by Central and State Commission with due consultation with stakeholders CSS: the amount of surcharge and additional surcharge levied from consumers who are permitted open access should not become so onerous that it eliminates competition. National Tariff Policy 2006 & 2016 Tariff to be +/-20% of cost of supply by 2010-11 CSS to be within 20% of tariff

Nodal Agency for Open Access Nature of Contract Tariff Structure Nodal Agency Long Term Medium Term Two Part Tariff Either Two part or Single Tariff POWERGRID for Inter state & STUs for Intra State Short Term Single Tariff Buyer RLDC for Inter State & SLDCs for Intra State Power Exchange Single Tariff NLDC for Day Ahead Market & RLDCs for Term Ahead Market

Open Access Segregation Spatial Division Among states or regional entities CERC Regulations Interstate open access Intrastate open Access Within state boundaries SERCs Regulations Long Term Medium Term Bilateral Advance STOA Bilateral FCFS STOA DAM (Co) Continge ncy STOA > 12 years 3 months 3 years Intraday 3 months Nodal agency : CTU Nodal Agency: RLDCs (Bilateral Transactions) NLDCs (Collective Transaction) Transmission availability: i. Advance booking ii. First cum first served iii. Collective transaction availability of transmission capacity due to inherent design margin, variation in power flow and in-built spare capacity.

Criteria for Allowing Access Long-Term Access Based on transmission planning criteria stipulated in the Indian Electricity Grid Code. Medium & Short Term Access Subject to availability of transmission capacity due to inherent design margin, margin available due to variation in power flow and margin available due to in-built spare capacity. Allotment Priority of long term customers higher than that of Medium term & Short term customers.

Open Access in Inter-State Transmission Regulation Implemented w.e.f. 6-May-2004, revised Regulations w.e.f 1 st April 2008 and amended in May 2009. Last amended in 2015 Products Monthly bilateral Advance /FCFS Day ahead bilateral Collective Transactions through Power Exchange Intra day bilateral Nodal Agency Bilateral : RLDCs & Collective : NLDC Transmission Charges moved from Contract Path to Point of Connection for Collective/Bilateral Other Commercial Issues Handing deviations from schedule Payment security Collection and disbursement of charges

Grant of Open Access by SLDC Thrust on Empowerment of SLDCs SLDC Concurrence [Clause 8] NOC/Standing Clearance to be obtained by State Utilities/Intra-State Entities Conditions to be verified by SLDC Existence of metering and accounting infrastructure Availability of Surplus transmission capacity SLDC to communicate clearance within 3 working days Deemed Clearance- in case of Non-communication SLDCs may charge appropriate fee for such NOC/Standing Clearance (as per SERC or Rs. 2000 (Bilateral) or Rs. 5000 (Collective)if not notified by SERC)

Open Access: Current Scenario

Intra State OA Framework: Technical requirements As per state specific open access regulations States Minimum Load Feeders Other Conditions Himachal Pradesh 1 MW and Above Haryana Uttarakhand 0.5 MW and above 100 kva and above Independent feeder or Mixed Feeder (all on Mixed to opt for OA) OA consumers have to submit daily schedule of power to be purchased through Open Access to SLDC with copy to DISCOM by 10 am for the next day Madhya Pradesh, DD & DNH, Southern Region 1 MW and Above Connectivity Min 11 KV ABT Special Energy Meters required No special condition

Intra State OA Framework: Technical requirements As per state specific open access regulation for northern region States Minimum Load Feeders Other Conditions Punjab & Gujarat The quantum of drawl OA Consumer from DISCOM during any time block of a day shall not exceed the admissible drawl of electricity by the OA Consumer from the distribution licensee in such time block wherein the schedule for Open Access drawl is the maximum Delhi Provision of partial & full Open Access Rajasthan 1 MW and Above Independent or Mixed Feeder OA consumers have to submit daily schedule of power to be purchased through Open Access to SLDC with copy to DISCOM by 10 am for the next day. The schedule so given shall be uniform at least for a period of 8 hours and the minimum schedule during the day shall at any time not be less than 75% of the maximum schedule of the day Uttar Pradesh Maharashtra Intrastate transmission congestion Day ahead is allowed subject to RTC condition. No provision of RTC in Regulations

Strong and Growing Base of Participants IEX IS THE #1 EXCHANGE IN THE WORLD IN TERMS OF NUMBER OF PARTICIPANTS 4067 3773 3390 2956 3614 3377 1910 2963 1237 2584 924 1748 89 251 1053 702 52 Mar'09 Mar'10 Mar'11 Mar'12 Mar'13 Mar'14 Mar'15 Mar'16 Oct'16 Active Participants Open Access Consumers Open Access Consumers Across States And Spread Across Industries Others, 111 Haryana, 355 Madhya Pradesh, 38 Karnataka, 137 Rajasthan, 263 Gujarat, 270 Paper, 2% Cement, 4% Other, 24% Textile, 25% Chemical, 10% Uttarakhand, 65 Telangana, 123 Andhra Pradesh, 103 Punjab, 189 Tamil Nadu, 105 Auto Components, 12% Total Active Open Access Consumers: 1759 (as on Oct 16) Metal, 23% 17

Volume in % MCP in Rs/kWh Share of OA Consumer in Total Purchase 70% 60% 5.19 6 5 50% 40% 30% 20% 3.56 3.54 3.49 2.73 3.51 2.73 2.41 4 3 2 10% 0% 6% 33% 43% 43% 61% 44% 61% 59% 1 0

States Allowing Open Access Haryana: High CSS and additional surcharge Punjab: High CSS, AS and high wheeling charges (same for all voltage) Gujarat Charges applicable on the reserved quantum (OA requested) & additional surcharge Rajasthan- Tough Regulations, High CSS & AS Tamil Nadu, West Bengal: Very High CSS SLDC Hindrance Uttar Pradesh, Bihar, Jharkhand - Approvals not given

New Tariff Policy by MoP - Impact on CSS The new tariff policy notified by MoP on Jan 16 proposed amendments in the formula for calculation of CSS by States: Earlier the Cross Subsidy Surcharge was calculated using the difference between the industrial tariff and cost of top 5% power purchase but as per the new formula, the CSS is being calculated as the difference between the tariff and the weighted average cost of power In case of Gujarat, Particulars FY 15-16 Old Formula FY 16-17 New Formula Industrial Tariff (T) Rs 7.41/unit Rs 7.26/unit Weighted average cost of Power (C) Rs 6.07/unit (top 5% only) Rs 3.76/unit CSS = (T-C x Factor) Rs 0.59/unit Rs 2.95/unit However, the provision also mandates that CSS should be not more than 20% of the tariff. Therefore for the FY 16-17, Gujarat has fixed the CSS at Rs. 1.41 per unit.

New Tariff Policy by MoP Cross subsidy and additional surcharge shouldn t be barrier to competition Formula to calculate CSS S= T [C/ (1-L/100) + D+ R] T: tariff payable by consumer including RPO C: per unit weighted average cost of power purchase by the Licensee, including RPO D: aggregate of transmission, distribution and wheeling charge L: aggregate of transmission, distribution and commercial loss R: per unit cost of carrying regulatory assets (if applicable) CS Surcharge capped at 20% of tariff

Open Access framework v/s Discom tariff The Open Access framework has been designed to compensate Discoms against all charges (cross subsidy, transmission, stranded assets etc) except for Energy Cost. Therefore, a comparison of the charges payable by Open Access consumers (after including APPC) should be equivalent to their industrial tariff. However, as per details in the ARR, it is found that in many states, the sum total of OA charges and APPC is higher that the industrial tariff. This highlights that Open Access charges are being set higher to restrict Open Access in the States.

Gujarat comparison Gujarat Rs./unit Rs./unit APPC (Average Pooled Cost of Power 3.29 Purchase) HT Tariff 5.50 State losses 4.00% Rebates/Discounts Wheeling Losses 10.00% Transmission Charges 0.12 Voltage Rebate (1% on DC & EC) 0.06 Wheeling Charges 0.14 Power Factor Rebate (2.5% on EC) 0.1375 Cross Subsidy Surcharge 1.45 ToD Concession 0.4 Additional Surcharge 0.49 Total APPC and other charges 5.99 Total Tariff Payable 4.91

CSS for Industrial Consumers State Discom Voltage level CSS FY 17 FY 18 11 1.61 1.65 APSPDCL 33 1.36 1.43 Andhra 132 1.30 1.35 Pradesh 11 1.54 1.72 APEPDCL 33 1.35 1.57 132 1.29 1.38 11 0.54 1.31 Assam APDCL 33 0.54 1.31 132 0.54 1.31 11 0.79 1.79 NBPDCL 33 0.78 1.74 Bihar 132 0.69 1.60 11 0.77 1.79 SBPDCL 33 0.78 1.74 132 0.69 1.60 11 1.21 1.26 Chhattisgarh CSPDCL 33 1.21 1.26 132 1.16 1.68 Maharashtra MSEDCL 220 1.16 1.68 11 1.79 1.8 33 1.64 1.65 >=66 1.62 1.63 Gujarat All 11/ 22/33 1.45 1.44 Madhya P All All 1.44 1.54

Rate (Rs./kWh) Break Even/Viability Rate Comparison (Post FY 17-18 Tariff Revision) 5 Old New 4 4.32 4.44 4.05 3 3.54 3.09 3.71 3.373.36 2.96 2.87 3.29 2.702.69 2.68 2 2.20 2.29 2.15 1.95 1.88 1.84 1 1.23 1.34 0 Data for 33kV Old: Bid rate as per old tariff order I New: Bid rate as per FY 17-18 tariff order

Additional Surcharge - Provisions Electricity Act 2003 Section 42. (Duties of distribution licensee and open access): --- (1) It shall be the duty of a distribution licensee to develop and maintain an efficient, coordinated and economical distribution system in his area of supply and to supply electricity in accordance with the provisions contained in this Act. --------- (4) Where the State Commission permits a consumer or class of consumers to receive supply of electricity from a person other than the distribution licensee of his area of supply, such consumer shall be liable to pay an additional surcharge on the charges of wheeling, as may be specified by the State Commission, to meet the fixed cost of such distribution licensee arising out of his obligation to supply. National Tariff Policy 2016 8.5.4 The additional surcharge for obligation to supply as per section 42(4) of the Act should become applicable only if it is conclusively demonstrated that the obligation of a licensee, in terms of existing power purchase commitments, has been and continues to be stranded, or there is an unavoidable obligation and incidence to bear fixed costs consequent to such a contract.

DNH Additional Surcharge- Calculation Methodology: Average fixed cost allocated to contracted/connected load instead of energy consumption Description Unit Value Total Capacity Contracted MW 1062 A Total Fixed Cost liability Rs Crore 1117.9 B Total Connected Load for all consumers MVA 1574.59 C Average Fixed cost liability (A/B) Rs./kVA 7099.83 D Retail Tariff- Demand Charge for ET/EHT consumers (275x12 Rs/kVA/year) Rs./kVA 3300 E Short Recovery of Fixed Cost liability (C-D) Rs./kVA 3799.83 F Energy Usage 1 kva load (PF 92.5% &LF 1) kwh 8103 G Additional Surcharge (E/F) Rs/kWh 0.47 Fixed charges per kva (Rs/KVA) = Total Fixed charges (A) / Total contracted load (B) Short Recovery of Fixed cost liability (Rs/KVA) = Fixed charges/kva (C) - demand charges/kva (D) Additional Surcharge: (Fixed charges/kva (C) - Demand charges/kva (D)) (Energy used for 1 KVA @ 100% LF & 92.5% PLF)

Rajasthan - AS Calculation Methodology: Effective fixed Charge of back down allocated to OA quantum Past year data considered for computation Effective Fixed Charge = (Wt. Avg of time block wise total generation back down (A) X fixed cost of such generation) Additional Surcharge= Effective fixed cost (D) x Back down due to OA (C)/ Total OA (B) Generation Back down (MU) Open Access Agg. (MU) Back down due to OA (MU) (A) (B) (C ) Apr-15 496 461 313 May-15 419 545 321 Jun-15 446 377 242... Dec-15 425 485 300 Jan-16 376 428 253 Total 4826 4,363 2,852 Effective Fixed Charges (D) 1.23 Rs/kWh Additional Surcharge 0.80 Rs/kWh Flaws with this methodology : Contract Demand charges deduction not done Liability of stranded capacity not distributed equally among all consumers (Total Contracted Demand)

Enablers for facilitating implementation of Open Access Legislative Open Access Charges Operational Strengthen Sec 11, 37, 108 to remove ambiguity and facilitate OA Sec 11: OA to generators restricted by state government by citing extraordinary circumstances Sec 37: State governments can direct LDC to restrict power sale outside state in lieu of maintaining smooth and stable supply Sec 108: Directions of state government will prevail where public interest is involved Sec 42(4) : Define uniform methodology of determination of additional surcharge Strengthen EA 2003 by expanding, restricting and/or clarifying scope under certain statues concerning OA

Enablers for facilitating implementation of Open Access Legislative Open Access Charges Operational Sec 42 (2) :.Provided also that such surcharge and cross subsidies shall be progressively reduced in the manner as may be specified by the State Commission Tariff Policy 8.3.2: Tariff to be +/-20% of cost of supply by 2010-11 NEP, 2005 Sec 5.8.3:..the amount of surcharge and additional surcharge levied from consumers who are permitted open access should not become so onerous that it eliminates competition. Implement existing statutes in EA 2003 and NTP 2006

Enablers for facilitating implementation of Open Access Legislative Open Access Charges Operational Equip SLDCs Use revenue accrued to SLDC from OA consumers for Infrastructure development, automation, capacity and capability building. 100 OA consumers imply a yearly revenue of appx Rs 9 crores to SLDC Leverage technology solutions and automate processes for NOC issuance, energy scheduling and energy settlement IEX has introduced SLDC interface to help manage NOCs of customers in the state of Punjab and Tamil Nadu. The same can be adopted for other states Open Access Registry (OAR) OAR will bring in transparency and facilitate faster transactions using automatic rule-based open access clearance while removing manual discretions

Open Access Registry Framework Integrated IT based system All OA approvals automated Function as an interacting medium between the OA Participants, Trade Intermediaries/PXs and National/Regional and State LDCs. Central mechanism for consolidating and settling transactions instead of the NLDC/RLDCs settling each trade individually. Maintain current status of NoCs, STOA Approval for participants and Record of Information will be available to CERC, System Operators, OA Customers, Traders and PXs. Stakeholders OA Applicants LDCs Regulators OAR Financial Institution s (in future) Store information of all OA granted Info on inter-state corridor available for STOA as uploaded by NLDC/RLDC Info on availed STOA corridor

Benefits of OAR No need to issue separate clearances for bilateral and collective Reduced transaction cost and less paperwork Information of beneficiary and transactions is readily available Easy record keeping, facilitates movement & safekeeping of approvals Enabler for progressive, investor friendly image and easy customer interface Reduces chances of fraud Faster and efficient scheduling and change over from one segment to another. For OA accounting and database Operated & maintained by independent body

Open Access is a win-win solution for all stakeholders Industries Reliable power supply Source cheaper power Save the value of lost load (VOLL) Open Access Benefits State utilities (Discom & SLDC) Cost savings, need not have to buy costly power as per merit order Serve retail consumers better Financial gains through open access charges State Increase in per capita consumption Revenue addition in terms of taxes Build up in generation capacities Employment generation Promote industrial & economic growth Retail Consumers Increased availability Better reliability of power Benefits trickle down to consumers in terms of low prices of products

Thank You for your attention www.iexindia.com Best Power Exchange in India Enertia Awards 13 Best Performing Power Exchange Power Line Awards 13 & 12 Best E-enabled consumer platform India Power Awards 09

Cross Subsidy Surcharge - NTP Surcharge formula: S = T [ C (1+ L / 100) + D ] Where S is the surcharge T is the Tariff payable by the relevant category of consumers; C is the Weighted average cost of power purchase of top 5% at the margin excluding liquid fuel based generation and renewable power D is the Wheeling charge L is the system Losses for the applicable voltage level, expressed as a percentage