It’s a much needed step by NLDC as it enhances the platform for a better market price discovery. This change would be beneficial for the generators and to the obligated entities, since if the RECs are not traded in the current month, they would not have to wait for an entire month to clear the REC’s.
Also it would promote the developers to meet their RPO as we have seen many regulatory actions coming up in the form of compliance orders and proceedings in several states like Orissa, Kerala, MP and Maharashtra recently.
We also feel that the bi-monthly REC trading could be intensified if quarterly or at least half yearly compliance of RPO is made compulsory instead of yearly. This would push the obligated entities more to gear up and fulfill their obligation and thus benefit the REC market.
Detailed trade results are tabled below for your kind reference.
Non-Solar RECs
Solar RECs
REConnect Energy is the market leader in the REC Market in India, with 36% market share and a portfolio of over 3 GW RE. We have been recently acknowledged with the REC Trader of the Year 2014.
Team REConnect
]]>As per the recent CERC amendment dated 10.07.2013 to REC Regulation, which specifies that the renewable generating plant would be eligible for issuance of RECs from COD or from the date of registration whichever is later. The said amendment is as follows:
“10 (1) After registration, the renewable energy generation plant shall be eligible for issuance of Certificates under these Regulations from the date of commercial operation or from the date of registration of such plant by the Central Agency whichever is later.”
However, the main regulation also quotes:
“7 (1) The eligible entities shall apply to the Central Agency for Certificates within three months after corresponding generation from eligible renewable energy projects.”
The language used is ‘eligible entities’ and not ‘registered entities’. Irrespective of the date of registration, an eligible entity is entitled to apply for RECs within three months from the date of commissioning and generation of electricity as Regulation 7 (1) has not been made subject to Regulation 5 (1) of the REC Regulations which describes only the eligibility and registration for certificates.
A perusal of the above regulation does not show that there is limit to RECs being issued against generation only after the date of registration since the registration process is merely procedural with a view to verify and confirm that the substantive conditions under the REC Regulations have been fulfilled. But, fulfillment is not from the date of registration, but from when the generation of electricity commences.
The APTEL has held that the regulations has to be interpreted and applied in the light of the object to promote the renewable generators and not in a restrictive manner to deprive the generators of any benefit that may be available to them.
As a result, the APTEL has said that Appellants would be entitled to the REC for the electricity generated from COD and the same ought not to be postponed to the generation after completion of the procedural formalities of registration.
The order may only have a small positive impact in number of RECs issued, and issuance of RECs will not be affected by delays in registration process by SNAs.
The order can be accessed here.
Contributed by Venkataramana Mutharasu
]]>1. REC registration applications
a. Recommendation by SA for Registration of Project under REC Mechanism in the format prescribed to be furnished along with the application.
b.Claim for refund to be made within 15 days from the day of payment. Claim made later will not be entertained.
c. Format of the declaration has been modified (Refer to the Order).
2. REC Issuance applications :
This procedure shall be applicable to all Eligible Entities, who have received Certificate of Registration? from the Central Agency, and shall be eligible to avail Renewable Energy Certificates from the date of commercial operation or from the 00:00 hrs of next day of Registration date of such plant by the Central Agency whichever is later.
This deviates with the 2nd amendment of the REC regulations which says
“After registration, the renewable energy generation plant shall be eligible for issuance of Certificates under these Regulations from the date of commercial operation or from the date of registration of such plant by the Central Agency whichever is later”
a. Central Agency shall not issue RECs during the trading session at the Power Exchange.
b. The Eligible Entity shall apply for issuance of RECs within six (6) months from the month in which RE was generated and injected into the electricity grid. At least 6 clear working days are available to Central Agency for considering the application.
c. ?The application for issuance of Renewable Energy Certificates may be made on 10th, 20th and last day of the month.
3. Retention of RECs:
a. SA to accept application for retention of RECs and shall issue ‘certificate of purchase’ of RECs to the buyer.
b. Eligible entity to apply it online from 1st to 5th of every month.
c. Hard copy of the application has to be submitted by 9th of every month to SA.
d. SA to check the proposed volume and application by 15th of every month.
e. SA to inform CA of list of RECs which will be by 22nd of every month.
4. REC Accreditation application:
The RE generator shall obtain a certificate from the concerned distribution Licensee for the connected load in case of co-generation plants. The Distribution Licensee shall issue such certificate within 15 days from the date of application by the RE Generator and the RE Generator shall submit it to State Agency along with application for accreditation.
]]>
Particulars | Amount in Rs. |
Processing Fees (One Time) | 1000 |
Registration Charges (One time upon registration) | 5000 |
Annual Charges | 1000 |
Revalidation charges at the end of 5 years | 5000 |
Table 1 : Fees & Charges for Registration
While there was no change in registration charges, the issuance fee for RECs charged by NLDC was reduced to Rs. 4 per certificate. This is going to continue for a period of one year with effect from 01.04.2014.
Summary of changes –
Fees & Charges for Registration – Same as in Table 1 (Till further orders).
Issuance fee – Rs. 10 per certificate ( till 31.03.2014).
Issuance fee – Rs. 4 per certificate (from 01.04.2014 to 31.03.2015).
The order can be read by clicking here.
An article in Economic Times can be read here.
What is RRF?
The Renewable Regulatory Fund (RRF) regulations require wind and solar projects that meet certain criteria to forecast and schedule their power on a day-ahead basis. This requirement will have significant operational and financial implications for the projects – the task of forecasting wind and solar power which are essentially variable in nature and dependent on many site-specific weather factors is complex in nature. At the same time, the scheduling, reconciliation and financial settlement requirements will also require on-ground coordination and liaisoning.
For basics on RRF mechanism, see our past newsletter –?Newsletter Vol. XIV October 2011
What are the challenges faced by projects in implementing forecasting and scheduling?
As per order from CERC of Jan 2013, projects were required to start forecasting and scheduling their power from July 1, 2013. However, certain challenges remain that need to be ironed out (see last section).
There are several approaches and models for forecasting generation. It will be very important for projects to choose the appropriate one keeping in mind the accuracy required and operational costs (that can go up significantly depending on the level of real-time data needed). Solar projects in general should opt for correlation based models with basic weather data inputs considering the relative stability in day-to-day generation and no financial implications for deviations. Wind projects must choose carefully between very sophisticated real-time forecasts (which are expensive to run) and models that balance past data with periodic generation inputs.
Once fully functional, projects will need to ensure that they forecast and schedule their power, and also have a ‘Coordinating Agency’ appointed to manage the logistical requirements for scheduling, reporting and settlement.
The scheduling and forecasting has to be done on a pooling substation basis, which will often have turbines with multiple owners. The task of ‘de-pooling’ so that the settlement of charges can be done appropriately amongst all the owners within the wind farm will also be a challenging one.? The data flow diagram for a typical forecasting mechanism can be explained below:
What is the status of implementing RRF???
The most recent pronouncement from CERC required RRF to be operational from July 1, 2013. However, based on our on-ground experience several challenges remain:
Project level – the level of accuracy achieved by various projects that have done trials leaves a lot to be desired. In such a scenario, projects may immediately face financial obligations
Infrastructure level – challenges remain in preparedness at all levels – at the coordinating agency and at some SLDCs in terms of preparedness. Various wind farms also have multiple owners, and de-pooling and the relevant reporting and contractual requirements are not yet in place in the majority of cases.
Clarity in regulations – CERC order of Jan 2013 stated as follows:“
We direct the staff of thee Commission to initiate the process for necessary amendments to the Grid Code in the light our decisions given in this Order. We direct NLDC to align the “Procedures for implementation of the mechanism of Renewable Regulatory Fund”” in accordance with our above directions and put up thee revised Procedures for approval of the Commission expeditiously. All concerned agencies are directed to gear up for implementation of the RRF mechanism w.e.f. 1.7.2013.
Pooling stations are to be regarded as “building blocks” as per recent order. Applicability of RRF is on pooling stations commissioned after May 3rd 2010. In case a pooling station was commissioned (say) 20 years back and two new feeders have been connected to the same after May 3rd 2010. Will the new feeders be eligible for participating in RRF mechanism?
At present, there is nothing strongly mentioned to address his particular issue as per current orders and same needs clarity as far as the operationability is concerned.
For full details of requirements under RRF and services offered in RRF management by REConnect, please contact us at?[email protected].
]]>Key Stakeholders :
REC Process Overview:
Process Steps:
Fee and Charges for REC Process :
Process | Payable to | Fee |
---|---|---|
Application fees for Accreditation | State Nodal Agency | Rs. 5,000 |
AccreditationCharge | State Nodal Agency | Rs. 30,000 |
Annual Charge | State Nodal Agency | Rs. 10,000 |
Application fees for Registration | Central Agency | Rs. 1,000 |
RegistrationCharge | Central Agency | Rs. 5,000 |
Annual Charge | Central Agency | Rs. 1,000 |
REC Issuance Charge | Central Agency | Rs.10/ Certificate |