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NHPC Limited - Central Electricity Regulatory Commission. NHPC-Comments... · 2019-09-17 ·...

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No. --- -Nttte0mm1:tPT/20191/J&'.3 Central Electricity Regulatory Commission, 3 rd & 4th Floor, Chanderlok Building, 36 - Janpath, New Delhi- 110 001 tr.JeTJ t/fdf (1{Ntf ... "<t>T NHPC Limited (A Government of India Enterprise) 'IiR/ Ph one : ___ __ ___ __ _______ Sub:- Comments on "Proposed framework for Real-Time Market for Electricity" - Regg. Ref:- Public notice RA-14026(1l)/2/2018/CERC dated 06.08.2019 Sir, In reference to above public notice dated 06.08.2019, the comments I suggestions of NHPC on Proposed framework for Real-Time Market for Electricity" is enclosed at Annexure-I for further necessary action. Thanking You, Yours Faithfully, S.P. Rathour) General Manager (Comml.)- PT ""11(,,,11 : lfI Q\ <ti1",i1t<R1 , - 121 003, Regd. Office : NHPC Office Complex, Sector-33, Faridabad - 121 003, Haryana CIN : L401 01 HR 1975GOI032564 ; Website : www.nhpci ndia.com E-ma i l: [email protected].i n; EPABXNo.:0129-2588110/2588500 illll>llldi if; 1912 :gj'"lf('f iIR I Dial 1912 for Complaints on Electricity
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Page 1: NHPC Limited - Central Electricity Regulatory Commission. NHPC-Comments... · 2019-09-17 · Comments I Suggestion on Draft notification for 6th amendment of IEGC'2010 S.N. I Existing

~ ~./ Ref. No. ----Nttte0mm1:tPT/20191/J&'.3

~retary Central Electricity Regulatory Commission, 3rd & 4th Floor, Chanderlok Building, 36 - Janpath, New Delhi- 110 001

tr.JeTJ t/fdf ~flI~s (1{Ntf ... ~ if"~ "<t>T ~)

NHPC Limited (A Government of India Enterprise)

'IiR/ Phone : ________________ _

~/ D'tl~.W:26t9------

Sub:- Comments on "Proposed framework for Real-Time Market for Electricity" - Regg.

Ref:- Public notice RA-14026(1l)/2/2018/CERC dated 06.08.2019

Sir,

In reference to above public notice dated 06.08.2019, the comments I

suggestions of NHPC on Proposed framework for Real-Time Market for

Electricity" is enclosed at Annexure-I for further necessary action.

Thanking You,

Yours Faithfully,

c::n~~ ~~9 S.P. Rathour)

General Manager (Comml.)- PT

~ ""11(,,,11 : lfI ~ Q\ ~ ~ <ti1",i1t<R1 , ~-33, ",flC:I~IC: - 121 003, ~~IlIU" Regd. Office : NHPC Office Complex, Sector-33, Faridabad - 121 003, Haryana

CIN : L401 01 HR 1975GOI032564; Website : www.nhpcindia.com E-mail: [email protected]; EPABXNo.:0129-2588110/2588500

~ ~ ~ illll>llldi if; ~ 1912 :gj'"lf('f iIR I Dial 1912 for Complaints on Electricity

Page 2: NHPC Limited - Central Electricity Regulatory Commission. NHPC-Comments... · 2019-09-17 · Comments I Suggestion on Draft notification for 6th amendment of IEGC'2010 S.N. I Existing

Comments on Clause/Provisions of Explanatory Memorandum

S.N. Clause/Provisions of Explanatory Memorandum Comments /Suggestion

1. Point no. 3.1.5 (Introduction of Gate Closure and Real time Revision of Schedule in case of Forced Outage may be retained market) as 4th time block. Outage of uniUPlant leads to high DSM It is proposed that any revision in schedule made in odd time blocks charges liability to Generators. Forced outage can occur at any shall become effective from 7th time block onwards, and any revision time and Generator has to bear loss due to reasons beyond its in schedule made in even time blocks shall become effective from 8th control. time block onwards, counting the time block in which the request for revision has been received to be the first one. In other words, once the real time market commences for any specific half-hour delivery period, the revision in schedule for that half hour (two time blocks) shall not be permitted.

2. Point no. 3.1 .10 (Intra-day segment of power exchange) Clarification on whether bidding for particular time block can be Existing intra-day segment of power exchange would continue to done simultaneously at Intra Day and Real Time market as both clear the continuous transactions except for the time blocks for which are different products of Power Exchange. the real-time market Operates.

3. Point No. 3.1.11 (Forced Outage) Suitable procedure to be provided for Generators who want to In case offorced outages the generator can participate in the Real compensate the loss to its beneficiary /clients on account of Time Market and buy power for the beneficiary to honour its Forced outage of its units in respect of Long Term/ Medium commitment Term/Short Term schedule of Generator.

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Page 3: NHPC Limited - Central Electricity Regulatory Commission. NHPC-Comments... · 2019-09-17 · Comments I Suggestion on Draft notification for 6th amendment of IEGC'2010 S.N. I Existing

Comments I Suggestion on Draft notification for 6th amendment of IEGC'2010

S.N. I Existing Provisions

1

2

Clause (18) of Regulation 6.5

Revision of declared capability by the ISGS(s) having two part tariff with capacity charge and energy charge and requisition by beneficiary (ies) for the remaining period of the day shall also be permitted with advance notice. Revised schedules! declared capability in such cases shall become effective from the 4th time block, counting the time block in which the request for revision has been received in RLDC to be first one.

Sub clause (a) of clause 18 of Regulation 6.5

Notwithstanding anything contained in Regulations 6.5.18, in case of Forced outages of a unit, for those stations who have a two part tariff based on capacity charge and energy charge for long term and medium term contracts, the RLDC shall revise the schedule on the basis of revised declared capability. The revised declared capability and the revised schedules shall become effective from the fourth time block, counting the time block in which the revision is advised by ISGS to be first.

Draft provisions

Substituted

Revision of declared capability by the ISGS(s) having two part tariff with capacity charge and energy charge and requisition by beneficiary (ies) for the remaining period of the day shall also be permitted with advance notice. Any revision in schedule made in odd time blocks shall become effective from 7th time block and any revision in schedule made in even time blocks shall become effective from 8th time block, counting the time block in which the request for revision has been received by the RLDCs to be the first one. Substituted

"In case of forced outages of a unit, for those stations who have a two part tariff based on capacity charge and energy charge for long term and medium term contracts, the RLDC shall revise the schedule on the basis of revised declared capability. The revised declared capability and the revised schedules shall become effective from the time block and in the manner as specified in Regulation 6.5.18."

Comments ISuggestion

In Hydro Power Plants sudden change in inflow of water may require to increase or decrease the generation which can easily be done by 4th Time block as per existing clause.

It is proposed to retain the existing clause for optimization of water inflow.

Power Plants have to wait for 7th ! 8th time blocks for getting it schedule revised in case of forced outage. Outage of uniUPlant leads to high DSM charges liability to Generators. Forced outage can occur at any time and Generator has to bear loss due to reasons beyond its control.

It is proposed to retain the existing clause for optimization of water inflow.

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Page 4: NHPC Limited - Central Electricity Regulatory Commission. NHPC-Comments... · 2019-09-17 · Comments I Suggestion on Draft notification for 6th amendment of IEGC'2010 S.N. I Existing

3 Clause 19 of Regulation 6.5 Substituted

Notwithstanding anything contained in In case of forced outage of a unit of a Regulations 6.5.18, In case of forced generating station (having generating outage of a unit of a generating station capacity of 100 MW or more) and selling (having generating capacity of 100 MW or power under Short Term bilateral transaction more) and selling power under Short (excluding collective transactions through Term bilateral transaction (excluding power exchange), the generator or electricity collective transactions through power trader or any other agency selling power from exchange), the generator or electricity the unit of the generating station shall trader or any other agency selling power immediately intimate the outage of the unit from the unit of the generating station along with the requisition for revision of shall immediately intimate the outage of schedule and estimated time of restoration of the unit along with the requisition for the unit, to SLDC/RLDC, as the case may be. revision of schedule and estimated time The schedule of beneficiaries, sellers and of restoration of the unit, to SLDC/RLDC, buyers of power from this generating unit as the case may be. The schedule of shall be revised accordingly. The revised beneficiaries, sellers and buyers of power schedules shall become effective from the from this generating unit shall be revised time block and in the manner as specified in accordingly. The revised schedules shall Regulation 6.5.18. The SLDC/RLDC as the become effective from the 4th time block, case may be, shall inform the revised counting the time block in which the schedule to the seller and the buyer. The forced outage is declared to be first. The original schedule shall become effective from SLDC/RLDC as the case may be, shall the estimated time of restoration of the unit. inform the revised schedule to the seller However, the transmission charges as per and the buyer. The original schedule shall original schedule shall continue to be paid for become effective from the estimated time two days. of restoration of the unit. unit. However, the transmission charges as per original schedule shall continue to be paid for two days.

Power Plants have to wait for 7th 18th time blocks for getting it schedule revised in case of forced outage. Outage of unit/Plant leads to high DSM charges liability to Generators. Forced outage can occur at any time and Generator has to bear loss due to reasons beyond its control.

It is proposed to retain the existing clause for optimization of water inflow.

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Page 5: NHPC Limited - Central Electricity Regulatory Commission. NHPC-Comments... · 2019-09-17 · Comments I Suggestion on Draft notification for 6th amendment of IEGC'2010 S.N. I Existing

Provided that the schedule of the buyers and sellers shall be revised after forced outage of a unit. only if the source of power for a particular transaction has clearly been indicated during short-term open access application and the said unit of that generating station goes under forced outage.

Provided also that the provisions of these sub regulations in respect of revision of schedule by electricity traders and any other agency (except the generating station) shall be operative with effect from 1st July2012.

Provided that the schedule of the buyers and sellers shall be revised after forced outage of a unit. only if the source of power for a particular transaction has clearly been indicated during short-term open access application and the said unit of that generating station goes under forced outage.

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