HPSEBL submits that as per Regulation 4(1) (quoted below) of HPERC (Renewable power Purchase Obligation and its compliance) (Third Amendment) Regulations 2017.
“The distribution licensee shall during each financial year, purchase such quantum of electricity (in kWh) from renewable energy sources as is not less than the quantum of electricity (in kWh),The same worked out as per the table below:-
Table 60 Minimum Quantum of purchase in percentage from RE sources of total consumption
Year Non-Solar Solar Total
2016-17 9.50% 2.50% 12.00%
2017-18 9.50% 4.75% 14.25%
2018-19 10.25% 6.75% 17.00%
The RPPO will be on total consumption of electricity by an obligated entity, excluding consumption met from hydroelectric sources of power.
Accordingly, HPSEBL has purchased power from renewable sources (non-solar & solar) in order to meet its obligation of 9.50 % from non-solar and 4.75 % from solar power for the FY 2017-18 and 10.25% from non-solar and 6.75 % from solar power for the FY 2018-19.
The details of net shortfall/surplus of HPSEBL in respect of non-solar RE obligation during FY 18 and FY 19 is as per the table below:
Table 61 RE (Non-Solar) Power Purchase for FY 18 & FY 19
Sr. No. Description Quantum
(in MUs)
Quantum (in MUs)
1 Financial Year 2017-18 2018-19
2 a. HP's consumption within the State (including
Hydro) (Annexure 4.1) 9351.38 10070.75
b. Consumption met from Hydro sources (Annexure
4.1) 7740.03 7259.44
c. HP's requirement within the State excluding hydro
(Annexure 4.1) 1611.35 2811.31
3 Non- Solar Renewable Power Purchase Obligations 9.50 10.25
4 Non- Solar Renewable Power Purchase Obligations (in
MUs) (Annexure 4.1) 153.08 288.16
5
Detail of Purchase of Non-Solar R.E. Power by HPSEBL including own generation
a. HPSEBL's own generation from 25MW & below
projects (excluding free power) (Annexure 4.2) 326.46 322.01 b. Power purchased (Net saleable energy) from IPP
owned SHPs of 25 MW & below capacity (excluding 1171.68 1232.25
Sr. No. Description Quantum (in MUs)
Quantum (in MUs) projects under REC) (Annexure 4.3)
c. Free power entitlements of GoHP in HPSEBL's SHPs
of 25MW & below capacity (Annexure 4.2) 24.84 43.39 d. Free power entitlements of GoHP in IPP owned SHPs
of upto 25MW capacity purchased by HPSEBL (Annexure 4.4)
92.18 96.42
Total Non-Solar R.E. purchased (a+b+c+d) 1615.16 1694.06
6 Non-Solar RE sold outside its area of supply as RE
(Annexure 4.5) 1231.85 1469.05
7 Total Non-Solar RE purchased for supply and utilized to
meet own RPPO (5-6) 383.31 225.01
8 Net shortfall(-)/surplus (+) in meeting own Non Solar
RE Obligation for FY 18 and FY 19 (7-4) 230.23 -63.15 The detail of power purchased from own generation (including free power), IPPs and GoHP free power from IPPs are attached as Annexure 4.2, Annexure 4.3 and Annexure 4.4 respectively. The RE power sale and HP‟s requirement within in the State is attached as Annexure 4.5 and Annexure 4.1 respectively.
In line with the HPERC Order dated 17.07.2017 regarding adjustment of surplus/shortfall of RE Certificates or renewable energy with respect to Renewable Purchase Obligation of FY 2016-17 in FY 2017-18, HPSEBL submits that the shortfall of 131.72 MUs in Non-Solar RPPO during FY 2016-17 may be adjusted against the surplus of 230.23 MUs for FY 2017-18. The balance surplus quantum of 98.51 MUs in respect of FY 2017-18 may be considered for issuance of RE certificates for FY 2017-18 on purchase of RE Power (Non-solar) beyond its RPPO and to issue certificate as per format 3.1.1 of the Central Agency. Further, HPSEBL submits to allow for the adjustment of deficit of 63.15 MUs for FY 2018-19 against the RE Certificates (non-solar), which HPSEBL shall receive in respect of the balance surplus quantum of 98.51 MUs for FY 2017-18.
In respect of Non-Solar RPPO deficit of 164.60 MUs for FY 2015-16, HPSEBL submits that same may be adjusted against the RE Certificates (Non-Solar) which HPSEBL received against the surplus Non-Solar Power of 182.77 MUs for FY 2014-15. It is pertinent to mention here that HPERC vide its order dated 05.01.2018 allowed for the adjustment of deficit of 164.60 MUs against the available inventory of RE Certificates (non-solar) which HPSEBL received for purchase of RE Power beyond non-solar RPPO. However, the prevalent Regulations of HPERC have no provision for such adjustments and thus the same was not allowed by the State Agency, that is, Directorate of Energy. Accordingly, HPSEBL sold the RE Certificates (non-solar) for FY 2013-14 through IEX as the same were due for expiry in February 2020.
Accordingly, HPSEBL submits before Hon‟ble Commission to consider the adjustment of deficit of 164.60 MUs in respect of FY 2015-16 against the RE Certificates (non-solar) of 182.77 MUs for FY 2014-15.
The detail of net shortfall/surplus of HPSEBL in respect of solar RE obligation during FY 18 and FY 19 is as per the table below:
Table 62 Computation of shortfall/surplus of HPSEBL in respect of solar RE obligation
Sr. No. Description Quantum
(in MUs)
Quantum (in MUs)
1 Financial Year 2017-18 2018-19
2
a. HP's consumption within the State (including Hydro)
(Annexure-4.1) 9351.38 10070.75
b. Consumption met from Hydro sources (Annexure-4.1) 7740.03 7259.44 c. HP's requirement within the State excluding hydro
(Annexure-4.1) 1611.35 2811.31
3 Solar Renewable Power Purchase Obligations 4.75 6.75
4 Solar Renewable Power Purchase Obligations (in MUs)
(Annexure-4.1) 76.54 189.76
5
Detail of Purchase of Solar Power by HPSEBL
a. Purchased from SECI Solar power Project (M/s
ACME Rajdhani Power Pvt. Ltd) (Annexure 4.6) 42.36 41.19 b. Purchased from NTPC (Singrauli Solar Power Project)
(Annexure 4.6) 21.33 20.42
c. IPP Owned Solar Plants in HP through Long Term
PPAs (Annexure 4.6) 0.36 2.16
d. HPPCL owned Bera Dol Solar Plant through Long
Term PPA (Annexure 4.6) 0.00 13.74
e. Solar Rooftop in the State (Annexure 4.6) 0.82 0.78
Total Non-Solar R.E. purchased (a+b+c+d+e) 64.86 78.29
6 Solar RE sold outside its area of supply as RE Power 0.00 0.00
7 Total Solar RE purchased for supply and utilized to meet
own RPPO (5-6) 64.86 78.29
8 Net shortfall (-)/ Surplus (+) in meeting own Solar RE
Power Purchase Obligation for FY 2017-18 (7-4) -11.68 -111.47 The details of solar power purchased from different sources by HPSEBL is as per Annexure 4.6.
From the table above, HPSEBL has a deficit in meeting its solar RPPO during FY 18 and FY 19 to the tune of 11.68 MUs and 111.47 MUs respectively. In respect of deficit of 11.68 MUs during FY 18 HPSEBL proposes to meet this deficit by RE Certificates (solar) which HPSEBL received against the surplus solar power of 15.28 MUs during FY 2016-17. In respect of deficit to the tune of 111.47 MUs for FY 19, HPSEBL requests Hon‟ble Commission to allow for the carry forward of same for ensuing years. HPSEBL submits that main reasons for non-compliance RPPO are as detailed below:
HPSEBL has issued consent letter to 16 No. entrepreneurs (IPPs) for development of Solar Projects aggregating to 34.4 MW, upto December 2015. Thereafter, no consent has
been given by HPSEBL in compliance to HPERC office letter dated 20.05.2016. HPSEBL had received 209 No. applications from prospective Solar Developers aggregating to 438 MW, for the consent of HPSEBL. However, the consent was denied as HPSEBL had enough tie-ups to meet the Solar RPPO.
In addition to this, HPSEBL gave consent to SECI during FY 2014-15 for procurement of 50 MW solar power. However, there was no development by SECI till 2019 and thus the consent was withdrawn by HPSEBL.
After the withdrawal of consent from SECI, it was decided that a new solar scheme shall be floated by GoHP and power from these projects shall be procured by HPSEBL to meet out its Solar RPPO. Accordingly, in September 2018, HIMURJA launched a scheme for 20 MW solar power from the projects in capacity range of 250 kWp t 500 kWp. The scheme is under implementation currently and HPSEBL has executed PPAs with the Project Developers. These projects will be commission by March 2020 and thus HPSEBL shall have enough power to meet out its future Solar RPPO.
It is pertinent to mention here that in view of the revised RPPO targets recently another scheme has been launched by HIMURJA for 28 MW Solar Power Projects ranging from 250 kWp to 500 kWp and power from these projects will also be procured by HPSEBL.
Thus, HPSEBL will have sufficient power from solar resources to meet out its Solar RPPO.
In addition to above, during FY 2018-19 the generation from hydro sources reduced significantly compared to the anticipated generation targets of Tariff Order. Thus, the consumption from non- hydro sources increased thereby increasing the quantum of solar and non-solar RPPO. Moreover, during the years HPSEBL procured around 500 MUs power through IEX to meet out the hydro power deficit which is also being treated as non-hydro power for RPPO calculations.
In view of the forgoing facts, it is evident that non- compliance of Solar RPPOs during FY 2018-19 was mainly on account of unforeseen circumstances and is not attributable to HPSEBL. Thus, HPSEBL submits before the Hon‟ble Commission to allow for the carry forward of deficit of 111.47 MUs of FY 2018-19 for ensuing years.
Submission of HPSEBL before Hon’ble Commission
a) To allow for the adjustment of shortfall of 131.72 MUs in non-solar RPPO during FY 2016-17 against the surplus of 230.23 MUs for FY 2017-18 and allow for issuance of RE certificates of balance surplus, that is, 98.51 MUs for FY 2017-18 on purchase of RE Power (Non-solar) beyond its RPPO and to issue certificate as per format 3.1.1 of the Central Agency.
b) To allow for the adjustment of deficit of 63.15 MUs for FY 2018-19 against the RE certificates (non-solar), which HPSEBL shall receive in respect of the balance surplus quantum of 98.51 MUs for FY 2017-18.
c) To allow for the adjustment of deficit of 164.60 MUs for FY 2015-16 against the RE Certificates (non-solar) from available inventory of HPSEBL.
d) To allow for the adjustment of deficit of 11.68 MUs for FY 2017-18 in solar RPPO against the RE Certificates (solar) issued for FY 2016-17 on purchase of RE Power (solar) beyond its RPPO.
e) To allow for the carry forward of deficit of 111.47 MUs for FY 2018-19 to the ensuing years.