There are proposals to amend the MERC Regulations on distribution open access and grid interactive rooftop systems. These amendments are required to implement Central Government Rules to promote green energy will potentially enable more consumers to access competitive green supply options. However, the proposed amendments could also pose several challenges for MSEDCL and its network users. The main changes and challenges relate to metering and energy accounting, safety, scheduling and balancing, and revenue loss for MSEDCL. Further, the different mechanisms for green procurement (open access, captive, net metering) have different techno-commercial frameworks, especially related to balancing banking and energy accounting. Presently, some frameworks are more concessional than others. These frameworks need to be harmonized and aligned with the ground realities of MSEDCL’s network, especially its large rural consumer base.
To address these challenges a comprehensive framework with different treatment for consumers connected to HT and LT network is proposed in the two Prayas submissions. The frameworks needs to consider various mechanisms for green procurement together. In this context, our comments in these two submissions are:
Limit green open access to HT consumers in Maharashtra: as the metering infrastructure is robust to manage balancing, wheeling and energy accounting requirements necessary to implement the Green Open Access Rules. Over time, with improvements in the LT network, open access can be extended to LT consumers. This would imply that LT consumers with load > 100 kW should apply for HT connections.
Provide Clear regulations, procedures and practice directions: especially for areas where is less clarity (operationalizing open access to consumers with multiple connections, having formats which are aligned in centralized portal but also ask important information related to safety concerns, dues with DISCOM, provision of model agreements for wheeling, banking, net billing and other services, etc.)
Net metering should be limited to small consumers with load less than 10 kW subject to the payment of a fixed charge (say Rs. 250/kW/ month) on RE capacity contracted by the consumer. This fixed charge, called a supply obligation charge, is to compensate for grid support, standby services and loss of revenue for DISCOMs.
Consumers with load > 10 kW should have a choice between net billing and banking subject to payment of a monthly fixed supply obligation charge (say Rs. 250/kW) on RE capacity contracted by the consumer. This is also applicable for captive, including off-site captive. HT Open Access consumers are to be exempt from this Supply Obligation Charge.
Energy accounting for banking, net billing to be different for HT and LT consumers: ToD slot wise for LT consumers, based on 30 minute AMI meter data for HT consumers with load less than 1 MW and based on 15 minute SEM data for those with load > 1 MW.
Banking charge to be levied as percentage (say, 8%) of non-DISCOM energy consumed (generation minus wheeling if applicable) for LT consumers and as a percentage (say, 20%) of energy banked for HT consumers, where quantum of energy banked can be estimated based on 30/15 min data.
Retain standby charges on captive and zero concessions on open access charges: Renewable energy growth and non-DISCOM procurement in Maharashtra is mainstreamed and can stand on its own economic proposition. This concessional treatment for standby, CSS and AS should not be given.
Fix CSS at rates adequate to compensate DISCOMs but such that it does not increase more than 50% of the CSS in which the open access agreement was signed: This will help implement Rule 9 (2) in a simple manner and will incentivize long term open access.
The two submissions can be downloaded. Each is cross referenced as an Annexure to another given that models to encourage non-DISCOM green procurement should be addressed in an integrated manner for balanced and smooth implementation.