India currently stands 4th globally in renewable energy installed capacity as per theREN21 Renewables 2022 Global Status Report. With a target of achieving 500 GW of non-fossil fuel capacity as declared in the COP26, the next half century would witness the Indian energy sector crossing the rubicon, due to an unprecented growth in the field of generation as well as demand. The Ministry of Power and the CERC taking in cognisance these multifaceted developments, have thus embarked on the journey to strengthen the energy highway of our country i.e. the national grid. For this herculean labour, they have chosen a novel approach by overhauling the erstwhile connectivity mechanism to bring in a new regime of general network access (GNA). This blog aims to understand the measures taken by the central government for the fortification of the national grid over the years, and explain the importance of GNA for the new green India’s grid management.
India took its first step in the modern energy world on November 1, 2021, when the Hon’ble Prime Minister made hisannouncement at the United Nation’s Climate Change Conference in Glasgow(“COP-26”) and pledged that India would add non-fossil fuel energy aggregating to 500 GW capacity by the end of 2030. This proclamation heralded a new dawn for renewable energy in India and made the country the global renewable energy growth flagbearer. The ensuing months saw massive growth in the Indian renewable energy space through private investment and special measures taken by the central government through schemes likeJawaharlal Nehru National Solar Mission andPradhan Mantri Kisan Urja Suraksha, both of which have been instrumental in adding renewable energy capacity in the country over the past years, with over 100GW of renewable energy added in the year 2021 alone.
However, the newly added renewable energy capacity through solar, wind, hybrid farms, and even rooftop projects brought into focus the tardy state of the transmission systems of the Indian power sector. The policymakers realized that a robust transmission system is fundamental for the successful harnessing of green energy, reducing the cost of power delivery and enhancing the reliability of the power sector. Thus, they began concentrated efforts to expand the current infrastructure and revamp the method of transmission planning and providing grid connectivity.
Expanding the Infrastructure
Over the last years, the central government has made concentrated efforts to expand transmission infrastructure in line with the target of generation of the 500 GW of non-fossil fuel capacity by 2030, as announced atCOP26.
Additionally, the respective state transmission utilities took further measures for the upgrading and augmentation of intra-state power transmission and sub-transmission power networks. The national electricity grid in India has recorded significant progress in terms of physical expansion of the grid and in terms of technology, making the country’s electricity gridone of the most extensive synchronous grids in the world. As of February 2023, the total transmission line length (at the 220 kV level and above) stood at468,977 CKm, the total transformation capacity stood at 11,58,875 MVA. In the period between 2015-16 and 2021-22, the transmission line length has grown at a compound annual growth rate (CAGR) of nearly 5 percent, while substation capacities have grown at 8.8 percent, respectively. The interregional transfer capacity has also grown considerably from 58,050 MW in 2015-16 to 112,250 MW in 2021-22, recording a CAGR of 15 percent.
The central government promulgated various schemes and undertook heavy capital expenditure for the construction of transmission infrastructure in the country. The leading schemes launched by the Ministry of power are highlighted as follows:
- Integrated Power Development Scheme (IPDS)– The main objective of the IPDS scheme is to strengthen the sub-transmission and electricity distribution network in India, particularly in urban areas. Additionally, it aims to complete the metering of distribution transformers/feeders/consumers, provide enterprise resource planning (ERP), and enable information technology updates in the electricity infrastructure of urban towns. The Scheme has enabled the strengthening of the electricity distribution system in 524 circles, the construction of over 23,000 CKm of HT Lines, and 979 new power substations.
- Deendayal Upadhyay Gram Jyoti Yojana (DDUGJY)– The union government enacted DDUGJY with a focus on rural electrification. The central government undertook efforts in collaboration with various state governments to electrify all the inhabited census villages, and in the process, they constructed around 4,207 substations (including augmentation), 6,08,840 distribution transformers, and laid down 4,81,945 CKm of LT transmission lines all over India.
- Comprehensive Scheme for strengthening of transmission and distribution systems in Arunachal Pradesh, Sikkim– Under this Scheme, the Government of India undertook the entire capital expenditure for the construction of electricity transmission systems in the north-eastern states. The project was executed through POWERGRID, a public sector undertaking under the Ministry of Power. The Scheme aims to create a reliable power grid and improve the north-eastern states’ connectivity to the upcoming load centers and extend the benefit of grid connectivity to the villages and towns of Arunachal Pradesh and Sikkim.
- North Eastern Region Power System Improvement Project (NERPSIP)– Under NERSIP, the Government of India along with the World Bank are undertaking efforts for the capacity building and construction of power infrastructure in six (6) north-eastern states of India, i.e., Assam, Manipur, Meghalaya, Mizoram, Tripura, and Nagaland. The Scheme aims to provide connectivity to the north-eastern states and contribute to economic development, and increase per capita consumption of power.
However, the above-mentioned schemes for the augmentation of transmission structures are only ad-hoc exercises and may prove to be an example of putting the cart before the horse if the method of grid planning and system of providing connectivity are not made responsive to the growing energy supply and demand. Thus, to ensure that the transmission system constantly is updated and robust in comparison to the prevalent power demands, we need to ensure the transmission system planning and strengthening are done in a concurrent fashion. The central government has realized this lacuna and consequently undertaken measures to revamp the grid planning and connectivity regulations.
History of Grid Planning in India
The Indian power grid system was managed on a regional basis in the 1960s, wherein the individual state electricity grids were interconnected to five regional grids, which spanned the entire country. The regional grids were classified as the Northern, Eastern, Western, North-eastern, and Southern Grids. These regional grids were instrumental in the transmission of surplus electricity between the states connected to each regional grid. However, with the industrialization measures underway as per the sixth five-year plan, the constraints in power transmission were visibly felt, and the Government of India, in 1980, formed theRajadhyaksha Committee under the chairmanship of Shri V.G Rajadhyaksha. The Committee recommended extensive power sector reforms and called for the integration of the regional grids. Consequently, the government initiated the formation of a national power grid under the aegis of a newly incorporated Power Grid Corporation of India Limited. Simultaneously, as time passed and the economy of the country grew with liberalization in the 1990s, the power consumption in the country also saw a tremendous boost, and the union government, with the rising demand, felt the urgent need for a synchronous national electricity grid and they undertook massive operations for connecting all the five regional grids. In the initial stages, these regional grids were connected through direct high-voltage current (HVDC) back-to-back links; however, in later stages, to facilitate uninterrupted operations, they were upgraded to high-capacity synchronous links.
This augmentation of the infrastructure by the union government and the creation of a national grid laid down the outline for the future growth of the transmission system; however, despite these reforms, the fundamental cause of the infrastructure lacunae was still not addressed. The transmission policy framework in India was still not in congruence with the market dynamics and the steadily growing electricity volumes, and thus these steps by the union government only proved to be a cure performed in an ad-hoc manner.
The government of India, in the latter part of 2014, realized the urgent need for the revamping of transmission planning systems and took steps to build sufficient transmission capacity to support future energy demand growth of the country. TheCentral Electricity Regulatory Commission (“CERC”) thus, in September 2014, issued a staff paper on transmission planning, connectivity, long/medium term open access, and other related issues to discuss a new paradigm of transmission system planning called general network access (“GNA”) and the Ministry of Power notified GNA under theElectricity (Transmission System Planning, Development and Recovery of Inter-State Transmission Charges) Rules 2021 (“Electricity Rules 21”). Additionally, the CERC came out with the revamped connectivity regulations titledCERC (Connectivity and General Network Access to the Inter-State Transmission System) Regulations which were issued in June 2022 (“GNA Regulations”), which came into effect onOctober 15, 2022 except for Regulations 23 to 24, 26 to 36, 37.9, 38, 40, and 43, whose date of commencement shall be notified separately. The main aim of the Electricity Rules 21 and the GNA Regulations is to introduce a new regulatory regime in the power sector with the fundamental objective of addressing the lacunae in the growth and maintenance of the power transmission system. The regulators, thus, are now poised to plan and develop the transmission system in congruence with the growth of electricity generation and demand load. This step is aimed at making the transmission system a harbinger of growth and not a brake on the economic development of the nation.
Overhaul of Grid Planning- What is GNA?
General Network Access, or GNA, is essentially a process of transmission system planning in which the power sector constituents are given easier access to the transmission network without specifying the contracted source of purchase/sale. This new method of transmission planning is aimed at ensuring that a sufficient transmission system is developed in the country, which is significant as India is on the cusp of the renewable energy revolution. Thus, GNA is non-discriminatory access to the inter-state transmission system (“ISTS”) to a designated customer (i.e., all users of the ISTS, including transmission and distribution licensees), granted by the central transmission utility (“CTU”), i.e., Power Grid Corporation of India Limited (POWERGRID) for a maximum limit of energy draw and injection for a particular period of time, without having to specify the injection and draw point.
However, this definition is unable to explain the novel character of GNA, and thus we would first need to understand how transmission planning was done as per the previous regulations. As per the previous regulations, energy-generating companies used to apply for long-term open access to the ISTS based on their existing power purchase agreements with discoms/other energy consumers. As per the quantum of power to be injected into the ISTS, the CTU would require only the long-term open access (“LTOA”) applicants to construct a dedicated transmission system to the point of connectivity, while the medium term (“MTOA”) and short term open access (“STOA”) open access were provided within the available margins without any system strengthening. This lopsided approach made the transmission system growth fundamentally linked with the quantum of LTOA applications. Additionally, the market dynamics in the Indian power structure further led to a massive imbalance in the transmission system, as the state transmission utilities gravitated towards STOA and MTOA, and the number of LTOA applications declined steadily over the years.
The earlier approach to transmission system planning based on the number of LTA applications failed to provide for adequate transmission capacity due to the changing market dynamics in India, further coupled with the poor financial condition of the state distribution companies. Over the past years, electricity volumes traded in the short-term market witnessed a steady compounded annual growth rate of 7.6 percent, and the volumes grew at a healthy rate from 65.9 billion units (BU) in 2009-10 to 137 BU in 2019-20. Additionally, the state electricity distribution companies were averse to entering into long-term power purchase agreements to keep the tariffs competitive and keep their financial obligations in check. Furthermore, the launch of new initiatives in electricity exchanges like real-time markets, the green day ahead, and electricity futures has further led to an increase in STOA and MTOA applicants. This constant decline in long-term power purchase agreements, and other market reforms introduced in India, have led to a proliferation of STOA and MTOA applications from generating companies, and the policymakers realized that in the future, the STOA and MTOA could not be contained in the existing margins of the transmission system capacity.
What are the Advantages of shifting to GNA?
The new approach to transmission planning under GNA would enable the current market model of state distribution companies to continue, i.e., they can keep purchasing electricity under short-term and medium-term contracts without the constraints of the non-availability of the ISTS network. GNA would further lead to steady growth in the short-term power purchase market, as particularly evidenced by the grant of temporary GNA (T-GNA) under the GNA Regulations. T-GNA, as per the detailed procedure notified by the Power System Operation Corporation Limited, is an open access right provided to an eligible purchasing entity for any duration from a one-time block and up to eleven (11) months.
For the power generating companies GNA would provide flexibility in selling the power generated as the GNA Regulations do not require them to specify the injection point and drawal point (though at the time of applying for connectivity to the ISTS, the applicant would need to indicate the preferred point of connection with the ISTS along with the maximum quantum to be interchanged with the ISTS). The erstwhile ISTS open access regulations required generators to identify a consumer prior to the grant of open access. However, the states most often did not adhere to their power procurement obligations and thus compelled the generating companies to sell the power on unplanned networks. The modified approach to morphing LTOA, MTOA, and STOA into GNA would thus help in the planning and development of adequate transmission capacity and benefit both generating companies and power-drawing entities.
GNA would be a crucial driver for the growth of renewable energy in India as not only will it solve the current constraints of the power transmission system, it would open the renewable energy market for the entire country and solve the problem of excess capacity and power curtailment during peak seasons. For example, as per a recent report by the Centre for Science and Environment, the renewable-rich state of Tamil Nadu, which has the nation’s highest wind capacity of 9.6 GW, is unable to fully accommodate the peak wind energy generation during the monsoon season as the intra-state grid has few interconnections with the national grid. Power curtailment for wind energy generating companies averaged at around 30-35 percent during the five-year period of 2012-2015, and currently, it hovers around at an average of 20-25 percent. The curtailment of capacity leads to massive losses to developers and poses a significant challenge to the growth of renewable energy projects in the country. Furthermore, with the crowding of the current transmission infrastructure, despite the increase in installed wind capacity, the actual generation by power companies has decreased. This is a vital indicator of the decreasing capacity utilization factor of renewable energy plants and points to the main culprit for the same, i.e., the curtailment of power generation. GNA would open the gates of investment in the power transmission sector and provide ISTS connectivity to renewable energy generators. The newly constructed evacuation infrastructure would prove to be a boon not only for the growth of renewable goals for India but for the sustenance of the current investment in the renewable energy space.
Key Features of Electricity Rules 21 and GNA Regulations
The key provisions introduced under the Electricity Rules 21 are explained hereinbelow:
i) Planning and Approvals–
a. The Central Electricity Authority of India (CEA) is mandated to draw up short-term electricity development plants annually on a rolling basis for upto next ten years for the development of the transmission system and coordinate the activities of other planning agencies for the optimal utilization of resources in the interest of the growth of the national economy and for providing reliable and affordable electricity. The CEA shall also prepare ten-year perspective plans every alternate year in consultation with the Central Transmission Utility (CTU), State transmission utilities (STU), system operators, generation and distribution companies, and other stakeholders.
b. CTU is mandated to draw plans for the ISTS for up to five years on a rolling basis, in which it shall identify specific transmission projects mandated to be executed and monitor their implementation timelines after consultation with the CEA. CTU shall study the progress of generation capacity in various parts of the country and take note of the GNA requests made by designated inter-state customers and monitor any signals of congestion in any part of the ISTS. The planning for the ISTS shall be done in congruence with the GNA requests of the states and the power-generating companies.
a. The Central Electricity Regulatory Commission (CERC) was empowered to notify regulations for the grant of GNA. These regulations would enable generation or distribution companies or ISTS consumers to sell or buy power from any generator or distribution company connected to the national grid.
b. The regulations to be notified by CERC shall specify the duration for which GNA is to be granted, as well as the procedure and the fees.
c. During the transition to GNA, all existing LTOA grantees shall be considered as having sanctioned GNA for that designated interstate customer.
d. The regulations would specify that the costs of the connectivity system would be borne by the connecting entity, and the costs of strengthening the system shall be part of the system costs and shall be recovered in the power tariff.
iii) Recovery of ISTS Charges-
a. The entire ISTS would be treated as one integrated system, and any designated ISTS customer seeking GNA shall be required to pay one time GNA charge as prescribed by the CERC along with the per MW tariff as monthly transmission charges.
b. The designated ISTS customers must pay the monthly transmission charges for the capacity of GNA sanctioned to them at normal rates. To ensure that the entities do not under-declare their GNA capacity, the rules provide for an additional charge of at least 25 percent higher rates (as may be determined by the CERC) for any excess drawal or injection over and above the sanctioned GNA capacity.
c. The transmission charges shall be levied in a manner that they are fully recovered, and the CERC shall true up the total ISTS charges every month based on reports of the CTU regarding addition or reduction in generation or transmission capacity.
As per Rule 4 of theElectricity Rules 21, the CERC has issued the GNA Regulations. Certain novel features introduced by the GNA Regulations have been highlighted hereinbelow:
- Parallel connectivity- While the erstwhile connectivity regulations barred an entity from obtaining connectivity for the same capacity from both ISTS and intra-state transmission systems. The GNA Regulations allow a generating station connected/intending to connect to the intra-state transmission system to obtain connectivity to the ISTS.
- No requirement of a separate transmission approval- The GNA Regulations remove the requirement of procuring a separate open access approval for entities that have been granted connectivity under the new procedure. However, we have to analyze this provision harmoniously with the Electricity (Promoting Renewable Energy Through Green Energy Open Access) Rules,2022(Green Energy OA Rules), notified by the CERC on June 6, 2022. Since the GNA Regulations grant deemed open access to renewable energy generating entities with a capacity of 50MW and above, the Green OA rules provide for a separate procedure for open access for renewable generating entities with an installed capacity of 100MW and above. Thus, we can observe that applicants outside the ambit of GNA Regulations would need to comply with the open access procedure provided in the Green Energy OA Rules.
- Transfer of Connectivity – The GNA Regulations allow a parent company to utilize the connectivity granted to its subsidiary, and vice versa; a subsidiary can do the same for connectivity obtained by its parent company. The erstwhile connectivity regulations only allowed the connectivity obtained by the parent company to be used by a 100% subsidiary. Furthermore, the GNA regulations allow the transfer of connectivity after the commissioning of the project, and a renewable energy generating entity can split its connectivity into parts (with a minimum capacity of 50MW for each part) after the commercial operation of each part.
The CERC is in the process of introduction of a bundle of reforms which started with Electricity Rules 21 and the GNA Regulations, and the current regulatory regime is being completely overhauled, albeit at a glacial speed. The CERC has only recently on April, 01, 2023, notified the new regulations for the collection of transmission charges and billing for the designated inter-state customers and other users of the inter-state grid as per the CERC (Sharing of Inter-State Transmission Charges and Losses) First Amendment Regulations 2023. Through this amendment CERC aims to move from the earlier system of LTOA,MTOA and STOA to a unified GNA wherein the yearly transmission charges shall be shared by the designated inter-state customers in proportion to their quantum of GNA.
The concept of GNA is a novel measure in our electrical ecosystem and thus would have its own pangs of parturition. Experts believe that in the initial years, the sector regulators would face issues in accurately estimating the GNA requirements for their annual rolling plans. Electricity demand forecasting in India has become a complex process due to many factors; chief among them is the emergence of prosumers which is continuously increasing with the spurt of decentralized generation, net metering, and the growing trends towards electrification of transport, agriculture, and day to day activities. Similarly, state utilities would face challenges in assessing the number of interstate open-access consumers and matching them with the continuous growth of renewable energy suppliers.
Thus, GNA cannot be seen as an elixir of life for the entire electricity transmission system, however with steady planning and continuous endeavours to forecast demand and supply in the initial years, over the next ten years, GNA can prove to be a steady foundation for building the nations green economy and deliver access to reliable, affordable energy for all.
About the Author
Mr. Anurag Mawai, is an advocate practising in the field of projects, infrastructure and energy laws.
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Preferred Method of Citation
Anurag Mawai, “Transmission System Reforms- A Plinth for Green India” (IJPIEL, 19 April 2023)