KERC published the draft first amendment to Forecasting, Scheduling and DSM regulations for Solar and wind generation sources Regulations on 8th August, 2022 and asked for public comments within 30 days. The Commission has proposed to amend these regulations of 2015 after seven years. However, without an Explanatory Memorandum and accompanying detailed analysis of the past experience of implementing F&S regulations (especially when SLDC hsas been issuing DSM bills since Dec 2018), it is difficult to effectively comment on many of the proposals. A detailed analysis of the past data would have helped generate more critical debate amongst stakeholders and given stronger analytical support to the amendments.

The framework of F&S is very significant for the state, especially when the state is one of the leading states in terms of total installed RE capacity (16 GW as of July 2022) and the state has recently set a target of adding 10 GW of additional RE capacity by March 2027. Also, the penetration of solar and wind power in the state grid is breaching 50% of total demand at a few instances of the year. Hence, an effective F&S framework is very critical for the state’s grid reliability.

In this context, we have made certain suggestions to the Commission for an effective F&S framework and its implementation in the state, some of which are briefed below:

1. Reducing tolerance and deviation bands and revising DSM charges supported by a comprehensive study
2. The entire cost of deviation caused due to wind and solar should be finally passed back to the generators, thereby allaying the fears of the DISCOM which would have had to bear the brunt in the absence of this provision. We feel that this is the right approach and absolutely necessary for the reliable growth of renewables in the long run.
3. Stopping the aggregation practice in Karnataka is appropriate given the high tolerance band with no penalties of 15% (proposed 10%). This is in sync with the prevalent practices in other states of the country. SLDC should determine the impact of aggregation of deviation errors for RE generators in the state after analysing the past data. If aggregation is to be continued, the error bands would have to be tightened much more, subject to analysis of past data (with and without aggregation).
4. Moving towards intra-state ABT based accounting (in line with CERC framework)
5. Enhancing role of SLDC in form of better data reporting, analysis of collected and available data and smoother implementation of regulations.