Comments and Suggestions on Repowering of Wind Turbines.

Ref: TNERC/2019/04

Date: 26 Nov 2019

Tamil Nadu  Electricity Regulatory Commission,

Egmore

Chennai - 600008.

Hon’ble Commission,

Ref: Petition filed under section 62 (1) (a), 63 and 86 (1) (b) of the Electricity Act, 2003 – Comments and Suggestions on Repowering of Wind Turbines.

We, the Taxpayers of India, thank you for giving us this opportunity to present our comments on the above petition.

We would like to record the great appreciation that we have, on the wonderful services that TNERC has been spearheading in the last one and a half decades of Electricity business in this state of Tamil Nadu. Not to mention the yeoman service TNERC has done in bringing a huge Wind investment into the state of Tamil Nadu to make it the number one state in the country.

Most of the systems and processes that TNERC introduced in Tamil Nadu, have been adopted across the nation and the world. WE APPRECIATE ALL OF THIS AND MORE, IN NO SMALL MEASURE.

Perspective:

1.    Wind is renewable source of energy and is a preferred source because of its low carbon footprint. Citizens, tax payers and common people of this country will benefit by using such a source of power.

Comments:

1.       As per the Clause 4.0 for Type 1 (B) on Repowering WEG’s not exceeding the installed capacity in the petition:

WEG’s under wheeling agreements, it is proposed to adopt the Wind Energy Tariff Order No.6 of 2018, dt: 13.04.2018 for wheeling and banking since all the repowered WEG’s are considered as new WEG’s as per the MNRE guidelines. And so the banking of one month with encashment of unutilized energy at 75% of Tariff at the end of the month is proposed.

Our suggestions:

The earlier order in this regard for unutilized banked energy with encashment was fixed at 75%. However, our study on your earlier orders also do not explain the reason for reducing the rate to 75%. There being no clear sanctity for reduction of the rate by 25%. Therefore, we request you to retain the same at 100% of the FIT rate applicable to the generators.

2.  As per Clause 4. Generation, it is proposed that the generators under PPA with DisCom can continue being with them at the latest tender discovered rate and those under wheeling can continue to do so with the tariff structures as already decided by the Honorable Commission.

Our suggestions:

As per MNRE guidelines, all the repowered WEG’s are considered to be new WEG’s. Hence, the generators may choose between PPA and Wheeling agreement. If the generators are willing to supply to TANGEDCO at the tender discovered rate, then TANGEDCO may choose to sign the PPA irrespective of, whether the generator was under PPA or wheeling agreement earlier. Similarly, even if the generator is in the PPA, he may be given the option to choose either of the options.

So the clause 4. Generation. C. may be added thus.

“4. Generation.

            C. The generator may choose either PPA or wheeling agreement and sign the respective agreements on acceptance of the Distribution Licensee at the tariffs mentioned in Clause A and B”.

3.  Clause 4. Type II on Repowering WEG’s exceeding the installed capacity has indicated that if there is a delay in connectivity, the generator is not eligible for any compensation whatsoever.

Our suggestions:

We suggest the addition of the following clauses:

1.    Every communication to the Distribution Licensee should be appropriately acknowledged and replied to within 15 working days, where applicable. If there is no response from the Licensee for more than 15 days for a permission / license / rights, then it would be treated as granted.

2.    Distribution Licensee shall be given the option to establish an entity for an equivalent Gas based power generation or power storage system for power smoothening and grid stabilisation, in line with the increase in wind power generation. And the generators shall be requested to hold shares as investments, in such a power generation system that will run during lean wind season, thereby, nullifying the low generation. Cost of the system can be apportioned on the generators and they will continue to hold the shares of such a company. This will benefit both the stake holders.

We thank you for your patient reading of this submission.

Thanking you and best regards

For India Taxpayer

President