APTRANSCO has made certain observations in adopting the Clauses viz., 2.1 (a), 2.1 (j), 4.1, 6.3 and 2.1 (aa) of the APERC Forecasting and Scheduling regulations, in day to day operation of grid with mix of VRE generation and conventional generation. A detailed report was prepared by APSLDC consolidating difficulties faced by them in day to day operation of the grid and requested suitable amendments to the said Regulation’. The Commission invited public comments on the report submitted by APSLDC vide its public notice dated 13.02.2020.
Our submission has two critical points.
- Any amendment in the F&S regulations should only be done after APERC commissions an independent study analysing the experience in implementing the F&S regulations, with a focus on forecasted and actual generation and deviation therein. The data should be placed in the public domain for further independent analysis.
- APERC may consider an approach wherein the cost of deviation caused due to wind and solar is finally passed back to these generators, thereby allaying the fears of the DISCOM which would have had to bear the brunt of DSM penalties in the absence of this provision. Such an approach is followed in Maharashtra.