The India Energy Exchange filed a regulatory compliance application before CERC to allow complex bid orders. CERC vide its public notice dated 15th May 2019, sought comments on the matter. Many of the new bid order types proposed by IEX should be introduced in the exchanges as they can potentially encourage flexible resources, enable increased participation from renewable energy generators and recognise/address constraints of thermal generators.

However, it is crucial that its introduction take place after significant public consultation, deliberations with key users of the exchanges such as open access, captive consumers and the electricity distribution companies. Further, processes and mechanisms need to be put in place to address the computational requirements to ensure constrained price discovery with complex bid orders. Mechanisms would also be needed to minimise the risk of sub-optimal outcomes, especially with respect to price discovery and sufficiency in quantum cleared.

Prayas (Energy Group)'s comments and suggestions highlight and discuss many of these issues and suggest a way forward.