Draft (Second) Amendment to UI Regulations, 2011

Submission on behalf ofPOSOCO

Evolution of the Operational Frequency Band

July 2002 : 49 Hz- 50.5 Hz Revision of UI Rate in April 2004, Oct 2004, April 2007, Jan 2008

April 2009: 49.2 Hz-50.3 Hz

May 2010 : 49.5 Hz- 50.2 Hz

2011 : Proposed 49.7 Hz to 50.2 Hz

NLDC 2

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Upto 18th October 2011

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Upto 18th October 2011

Amendment of Regulation 5(2) of Principal Regulations

Proposed Amendment

In view of the proposed change in the IEGC in the lower limit of the UI band from 49.5 Hz. to 49.7 Hz., the UI price vector steps have been changed from .02 Hz. to .01 Hz. and the charges for UI have also realigned.

POSOCO Comments: The amendments are in line with the proposed IEGC

mandated frequency Band.

New provisions of UI regulations is a welcome step……

Merits/Essentiality towards this would be submitted in detail during the submission on IEGC amendment.…….

04/21/23 11POSOCO

Amendment of Regulation 5(5) of the Principal Regulations

Proposed Amendment

“The infirm power injected into the grid by a generator which has not identified a buyer for the infirm power during the testing prior to COD of units / station from other generating stations shall be paid at UI rates for power injected in to the grid consequent to testing for a period not exceeding 3 months, subject to ceiling of Cap rates corresponding to the fuel used for such generation as specified in the Schedule “A” of this Regulation.”

Suggestion Infirm Power should not be scheduled

Past Orders have emphasized that Infirm Power should not be Scheduled Frequent Start/Stop operation and Uncertainty of operation Scope of Interplay between UI rates v/s contracted rates Difficulty in case of Revision, particularly if traded through Power Exchange

Lower UI rate for infirm power Induce generator to declare DOCO at the earliest To take permission of CERC in case of exceeding 3 months along with time limit introduce some commercial disincentive also

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Amendment of Regulation 5(5)……….contd…

Suggestions contd… Payment of UI rates based on mixing/bending etc. .….. Determination of UI Rate should not be subjective /

unduly complicated Mixed/Imported coal/RLNG, blending of different varieties, ratio of

fuel consumption Difficult to certify, administer all this All such complexities can be avoided, that too when it is for a limited

period only,

Other issues related to infirm power: Definition of COD of generators whose tariff is not determined by

the Hon’ble Commission Injection under UI by generators without PPA after COD

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Amendment of Regulation 5(5) of Regulations ……contd.

Regulation 5(5) may be amended as follows:

“(5) The infirm power injected into the grid by a generator during the testing prior to COD of units / station shall be paid at UI rates for power injected in to the grid consequent to testing, subject to ceiling of Cap rates corresponding to UI rate at frequency below 50.01 Hz. and not below 50 Hz. as specified in the Schedule “A” of this Regulation.

Provided that, the unit shall be declared under commercial operation by the generating station or seller within three months of first synchronization. For injection of infirm power beyond 3 months, the generating station or seller shall obtain prior approval of the Commission.

Provided that infirm power from a unit shall not be adjusted with injection from other units”

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Amendment of Clause 2(f) of Schedule A of Principal Regulations

Clause 2(f) may be amended as follows:

“(f) In terms of clauses (5) of Regulation 5, The cap rates for the infirm power injected into the grid beyond schedule by a generating station or seller prior to COD of unit shall be paid at UI rates subject to ceiling of cap rates corresponding to UI rate at frequency below 50.01 Hz. and not below 50 Hz., i.e. Rs.1.65 per kWh.”

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Amendment of Regulation 7 of the Principal Regulations

Suggestions towards textual modifications:

Regulation 7(1)

The words and figures “frequency below 49.85Hz”

may be replaced by “frequency below 49.80Hz”

Regulation 7(9)

‘Accounts’ may be replaced by ‘Statement’

‘Paid’/ ‘Received’ may be replaced by ‘Payable’/

‘Receivable’

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Other Issues

Reference Frequency for IR UI Computation

( May be added after Regulation 9 (1)) UI transactions between SR-ER and SR-WR

Based on UI rates as per the frequency of the respective regions Differential amount to be transferred to PSDF

Drawl of power before synchronization of 1st Unit

(Regulation 5(5))

Time period may be specified

Under-injection by generating stations/sellers (Regulation 7(3) (b))

During low frequency Under injection as harmful as over drawl

Review of rates to dissuade under-injection04/21/23 POSOCO 19

Thank You

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