In a significant development, the Ministry of Power (MoP) has introduced the much-awaited paradigm of general network access (GNA) in interstate transmission. GNA is not a new concept and has been under discussion for the past few years. To recall, the Central Electricity Regulatory Commission (CERC) had published a staff paper on the subject in 2014 and notified draft regulations on grant of connectivity and GNA to the interstate transmission system (ISTS) in November 2017. In a move to ensure that sufficient transmission capacity is built to support future demand growth, the MoP has now introduced GNA under the Electricity (Transmission System Planning, Development and Re-covery of Inter-State Transmission Charges) Rules, 2021 in a gazette notification dated October 1, 2021. As per the notification, “Transmission planning should be such that the lack of availability of the transmission system does not act as a brake on the growth of different regions. The transmission system shall be planned and developed matching with growth of generation and load, as far as possible and while doing the planning, care shall be taken that there is no wasteful investment.”
GNA would essentially overhaul the process of transmission system planning by giving power sector constituents easier access to the transmission network across the country. The move is aimed at ensuring adequate development of the transmission system, especially in the wake of increasing renewable energy penetration. The expansion of the country’s renewable energy programme hinges on the creation of matching transmission infrastructure for evacuation of power from large-scale wind and solar parks.
What exactly is GNA? The latest rules define GNA as non-discriminatory access to the ISTS, as requested by a designated interstate customer (DIC) (all users of the ISTS, including state transmission and distribution licensees) and granted by the central transmission utility (CTU) for a maximum injection or drawal in megawatts and for a specific period. Simply put, GNA enables the planning and implementation of the transmission system based on the power requirement of a generator or a drawee without knowing the contracted source of purchase/sale.
This brings us to the next question – so how was transmission planning being done so far? At present, gencos apply to the ISTS for long-term access (LTA), based on their supply tie-ups with discoms/target beneficiaries. Medium-term open access (MTOA) and short-termn open access (STOA) are carried out within the available margins without any system strengthening. The transmission capacity is added to the ISTS only based on the quantum specified in the LTA application.
However, the existing approach to transmission planning needed to be reviewed, especially considering the growth of STOA/MTOA transactions in recent years as well as the country’s ambitious renewable energy drive. The subsequent sections discuss the deficiencies in the existing transmission planning methodology and the new rules released by the ministry…
Transition to GNA – Needs and drivers
The present approach to transmission planning, based on LTA, does not ensure the creation of adequate transmission capacity. Since MTOA and STOA are operated using margins in the existing system and do not mandate the creation of additional transmission capacities, there are instances of congestion and curtailment of power. This assumes greater importance considering the growth in electricity volumes traded in the short-term market, which have increased from 65.9 BUs in 2009-10 to 137 BUs in 2019-20 – recording a healthy CAGR of 7.6 per cent.
Further, there has been a change in discoms’ power procurement strategy in recent years. Discoms are hesitant to enter into long-term power purchase agreements (PPAs) with gencos (as is evident from the lack of long-term PPA bids in the market) and prefer shorter-tenure contracts at competitive prices to optimise their costs. As a result, the volumes of short-term transactions have increased and are expected to continue growing in the near term. In addition, the launch of new market-based segments such as real-time markets and green day-ahead markets in recent times and the likely launch of electricity futures in the near term means that STOA/MTOA can no longer be operated within just the margins of the existing transmission capacity.
A transition to GNA would provide the much-needed flexibility to power-drawing state entities in purchasing electricity under contracts of varying durations without the limitations of ISTS network availability. GNA is also likely to facilitate power evacuation from merchant capacities and further encourage the growth of the short-term market. S.K. Soonee, adviser, Power System Operation Corporation Limited (POSOCO), says, “Long-term, short-term and medium-term open access would be morphed and would undergo a major change with GNA. This would be a big change as far as transmission is concerned for those who want to secure access, for planners as well as grid operators.”
For generators too, there will be enhanced flexibility in sales since target beneficiaries will not have to be specified. At present, gencos need to declare their point of supply or the target region based on which the transmission network is set up. However, states often do not adhere to their power procurement commitments, compelling gencos to sell on unplanned networks, while power deficit may remain unserved due to transmission constraints. It would help in the planning and development of adequate transmission system capacity, both for generators and for drawing entities.
Soonee adds, “We know that transmission evacuates generation and meets the load, but now transmission is to be seen as an enabler for minimising the cost of power. The ultimate objective is that everyone should have access to the power market and be able to manage their portfolios properly. To minimise costs, only efficient plants should run and inefficient plants should be shut down. So, planners need to analyse if the all-India market provides cheaper power, can it be drawn, and the costly units shut down. In another scenario, where prices could be very high in the market and the state has a lot of temporary surpluses, can it sell that in the market? Therefore, planners need to assess the transmission capability, import as well as export. This is where the concept of GNA comes in. It is a very big-ticket reform that will change the way transmission is perceived.”
GNA is also crucial for supporting the country’s renewable energy programme. At present, power evacuation from renewable energy projects is hampered by transmission constraints in renewable-rich states. For instance, as per a report by the Centre for Science and Environment, the intra-state grid in Tamil Nadu is not capable of accommodating the peak wind generation during the monsoon season due to low demand in the state, while the excess power cannot be transmitted to other states due to the few interconnections with the ISTS, leading to curtailment of 20-25 per cent. GNA is expected to increase investments in the transmission segment by providing hassle-free access to the ISTS network to renewable energy generators. An ICRA note released last year stated that an investment of Rs 1.8 trillion is expected over the five-year period from FY2021 to FY2025 in the transmission segment at the all-India level, driven by the need for evacuation infrastructure for renewable energy projects.
Key features of the new rules
The key features of the new rules are as follows:
Planning and approvals: The Central Electricity Authority (CEA) will draw up short-term electricity system development plans annually, on a rolling basis, for up to the next five years. It will also prepare 10-year perspective plans every alternate year, in consultation with the CTU, the state transmission utilities (STUs), system operators, generation and distribution companies, and other stakeholders, and based on its growth forecast for electricity demand and supply.
After due consultation, the CTU will annually draft the ISTS development plan for five years, identifying the specific transmission projects that need to be implemented after considering the CEA’s plans and examining the progress in generation capacity and demand across the country, the GNA requested by the DICs, signs of congestion in the ISTS, and the difficulties in obtaining right of way (RoW) for the development of transmission corridors. While transmission must be planned and developed to meet generation and load growth, over-investment must be avoided.
The CTU-identified ISTS projects will be placed before the central government-appointed National Committee on Transmission (NCT), which will give its recommendations to the central government. The latter will then approve the projects with their implementation timelines based on the NCT’s recommendations or otherwise in the case of strategic transmission projects.
Connectivity: The CERC must notify the GNA regulations, including the duration for which GNA can be granted as well as the procedure and fees. During the transition to GNA, all existing ISTS LTA customers are deemed to be GNA customers. New applications have to be made for a specific capacity and period. The costs of the connectivity system to the network will be borne by the connecting entity and the costs of system strengthening will be part of the system cost and recovered in tariff.
Recovery of ISTS charges: The entire ISTS will be treated as one integrated system. Any DIC seeking GNA has to pay the CERC-prescribed one-time charge plus the per MW tariff (also fixed by the CERC) as monthly transmission charges. DICs must pay monthly charges for the GNA capacity sanctioned to them at normal rates, and excess drawal or injection will be charged at least 25 per cent higher rates, as determined by the CERC. This will ensure that the entities do not underdeclare their GNA capacity. Transmission charges must be levied in a way that they are fully recovered and the CERC will true up the total ISTS charges every month based on CTU reports regarding additions or reductions in generation or transmission capacity and the number or capacity of GNA consumers.
The liability to pay transmission charges will be effective from the date the GNA gets operationalised. The CTU will be responsible for billing collection and disbursement of transmission charges based on the CERC’s regulations. The DICs may be allowed to relinquish their GNA (fully or partly) on making advance payment of reasonable relinquishment charges (fixed by the CERC) and after ensuring that other DICs are not burdened. Further, GNA capacity can be shared, sold or purchased from any other DIC customer as per the CERC regulations. The central government may waive ISTS charges and losses for notified sources of energy for a specified duration.
Likely issues and the way forward
While the concept of GNA would bring in various benefits for grid participants, there could be certain issues in its implementation, at least in the initial years. Sector experts believe that it may not be possible for states to accurately estimate GNA requirements because of uncertainty in the assessment of demand, which has become quite variable. Demand forecasting is becoming increasingly complex with the emergence of prosumers due to the growth of decentralised generation, net metering and greater focus on energy efficiency. A growing trend towards the electrification of transport, agriculture and cooking is further likely to impact demand in the coming years.
State discoms also find it challenging to assess the number of open access customers that may source power from outside the state, thereby impacting accurate assessment of GNA requirements. Similarly, the power requirement or supply of/from captive consumers is difficult to gauge accurately. Demand variability, coupled with supply variability due to the growth of renewables will present a double whammy for system planners and may lead to overplanning of the ISTS. It is, therefore, essential that the cost implications of transmission planning are studied thoroughly for various load generation scenarios. Also, in the case of default by gencos, care must be taken that the additional expenditure on the transmission system is not passed on to the beneficiaries. It is expected that minor modifications arising out of uncertainties in demand estimations will be accommodated in the GNA.
Overall, these challenges are likely to be overcome in the near to medium term as market participants gain greater experience with this new transmission planning paradigm. GNA marks a new era in the transmission planning process and is expected to deliver on its objective of easier access to the national grid to all.