Comments on Draft CERC (Sharing of ISTS Charges and Losses) (First Amendment) Regulations, 2022 Public Hearing
Relevant provisions of the draft sharing regulations regarding transmission charges for T-GNA, applicable charges for collective transactions, and proposed mechanisms for embedded entities and GNA Grantees are discussed. Key issues include the uncertainty in determining exceeding drawl schedules and the need for a recovery mechanism. Suggestions are made for clarity and accountability in the regulations.
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Comments on Draft CERC (Sharing of ISTS Charges and Losses) (First Amendment) Regulations, 2022 Public Hearing : 10thOctober,2022 1
Relevant Provisions of Draft Sharing and GNA Regulations 11. Transmission Charges for T-GNA (Sharing Regulations) (2) Transmission charges for T-GNA shall be payable by drawee embedded entities located in the State, as per the last published T-GNA rate for the State, (3)Transmission charges for T-GNA paid by an embedded intra-State entity during a month shall be reimbursed in the following billing month to the State in which such entity is located. (4)Transmission charges for T-GNA collected in a billing month, shall be reimbursed to the DICs in proportion to their share in the first bill in the following billing month. 34.TransmissionchargesforT-GNA(GNARegulations) 34.2 Transmission charges for T-GNA in case of bilateral and collective transactions, shall be payable only at the point of drawl as per the last publishedTransmissionchargesrateforT-GNAfortheStatewheresuchpointofdrawlislocated: Providedthatundercollectivetransactions,transmissionchargesforT-GNAshallbepayablefordrawlschedulesmorethanGNAquantumor T-GNAquantumorboth,asapplicable. 34.4PaymentofTransmissionChargesforT-GNA: .. (c)Undercollectivetransactions,thepowerexchangeshalldepositthetransmissionchargesforT-GNAwiththenodalagencybythe2400Hrs of(D+2)day,(D)beingthedayoftheapplicationforgrantofT-GNA: 2
T-GNA Charges Applicable for Collective Transactions Power exchange to collect the T-GNA charges from: Drawee embedded entities (even if the total drawal of the state is within GNA) and deposit the amount with NLDC for reimbursing to the state in which the entity is located GNA Grantees of the state for the drawl schedules more than GNA quantum or T-GNA quantum or both as applicable. Transmission charges collected shall be deposited with the nodal agency at the end of D+2, D being the day of application Key Issues: Power Exchange will not be able to ascertain whether the drawl schedules of any entity is exceeding the GNA or not and the T-GNA charges to be collected from the entity As per the Draft Procedure, NLDC will work out the inter-State transmission charges for scheduling of T-GNA transactions on the basis of total MW at the regional periphery. Sharing Regulations and Detailed Procedure should provide the mechanism to recover the T-GNA charges from the GNA Grantees participating in the collective transactions 3
Proposed Mechanism For intra-stateembedded entity: Power Exchange to levy the T-GNA charges from the embedded entity as per the published T-GNA charges of the State as per Regulation 11(2). Exchange to deposit the amount with NLDC which is to be passed on to CTU for reimbursement to State in the following billing month 11 (3) For GNA Grantees: If Drawl is within the GNA of the State: No T-GNA charges shall be collected from the GNA Grantees If Drawl exceeds the GNA of the State: NLDC will allocate the excess drawl of the State across Power Exchanges based on the cleared volume of the GNA Grantees of the Exchanges Respective Exchange will recover the T-GNA charges from the GNA Grantees of the State in ratio of their cleared volume Exchange will pass this amount to NLDC as the T-GNA charges for the State within D+2 days in terms of Regulation 34.2 and 34.4(c) of GNA Regulations. Adjustments amongst the drawee entities located in the State who are GNA grantees to be done by STU/SLDC considering actual utilisation of GNA by respective intra-state entity on monthly basis 4
Illustration State GNA 5000; GNA Scheduling 4500 MW X Y Z Embedded Entity GNA Grantees Total Cleared Volume in PXs Exchange 1 Exchange 2 Exchange 3 Total Exchange Collective Vol more than GNA+TGNA 50 50 0 100 100 200 200 500 200 100 200 500 100 450 350 400 1200 350 350 400 1100 100 700 Exchange 1 350 Exchange 2 350 Exchange 3 400 Total 1100 Cleared Volume of the GNA Grantees Allocation of T-GNA Charges in ratio of Cleared Volume of GNA Grantees across Power Exchanges T-GNA charges across Entities in ratio of Cleared Volume of respective Power Exchange 223 223 255 700 X Y Z 32 64 127 100 323 32 127 64 0 223 0 64 318 318 100 800 127 127 0 255 Intra-State Entity T-GNA Charges Collected by the Power Exchanges T-GNA Charges towards reimbursement to State as per Regulation 11(3) T-GNA Charges towards reimbursement to DICs as per their first bill as per Regulation 11(4) 100 700 5
Proposed Amendments in Draft Sharing Regulations 11. Transmission charges for T-GNA (2) Transmission charges for T-GNA shall be payable by drawee embedded entities located in the State, as per the last published T-GNA rate for the State, along with other charges or fees as per GNA Regulations and the Transmission Deviation charges, if any as per these regulations in following manner: a) For Advance and Exigency Application Category, Transmission Charges for T-GNA shall be payable by the applicant to the concerned nodal agency. For Collective transactions, power exchange shall collect the Transmission Charges from states for T-GNA as indicated by Nodal Agency under Regulation 34.2 of CERC GNA Regulations from the GNA Grantees of the State in proportion to their drawl schedules through the exchange. b) (3) Transmission charges for T-GNA paid by an embedded intra-State entity during a month shall be reimbursed in the following billing month to the State in which such entity is located. (4) Transmission charges for T-GNA collected from in a billing month after adjustment of Clause (3) of this Regulation, shall be reimbursed to the DICs in proportion to their share in the first bill in the following billing month. (5) The inter-se settlement between drawee entities located in the State who are GNA grantees shall be done by STU/SLDC considering utilisation of GNA by respective intra-state entity on monthly basis. Detailed Procedure may also incorporate the proposed mechanism to provide clarity in the levy and collection of T-GNA charges from the entities participating in collective transactions for smooth functioning of the market Detailed Procedure may also incorporate the proposed mechanism to provide clarity in the levy and collection of T-GNA charges from the entities participating in collective transactions for smooth functioning of the market 6
