Proposal for rationalization of Unscheduled Interchange (UI) price vector Section-A: Background
Transcription
Proposal for rationalization of Unscheduled Interchange (UI) price vector Section-A: Background
POWERGRID Proposal for rationalization of Unscheduled Interchange (UI) price vector Section-A: Background 1. Honorable CERC, in its order dated 15th January 2007 in the petition 145/2006 had directed ED (SO & NRLDC), POWERGRID to deliberate the issue of enhancement of the Unscheduled Interchange (UI) prices in consultation with the RLDCs and SLDCs and submit a consolidated proposal to the Commission by 25th January 2007. 2. Northern Regional Load Despatch Centre (NRLDC) had earlier submitted petition no. 4/2006 on 13th January 2006 for review of frequency linked UI price vector and implementation of a payment security mechanism for UI charges. Subsequently on the Commission’s direction vide letter dated 27th January 2006, a detailed proposal on this issue was submitted on 01st March 2006. A copy of this was also forwarded to the stakeholders on 13th March 2006 as directed by the CERC vide their letter dated 08th March 2006. 3. The benefits that would accrue on implementation of the NRLDC’s proposal in petition no. 4/2006 as enumerated in the proposal [Executive Summary, Page 6] are as under: “Implementation of the above proposal would facilitate grid security further, considering the ER-NR interconnection expected by June 2006 It would provide strong incentive to harness all latent generation and/or trade the same through Short Term Open Access (STOA). It would give a strong signal for capacity addition as any developer could have only a Power Purchase Agreement (PPA) for 70-80% of his output and trade the balance. It would encourage the state utilities to forecast their load accurately and make plans to meet the load accordingly. It would send strong price signal for energy conservation and demand side management. It would bring some orderliness in load shedding and ensure that areas covered by under-frequency relays (UFRs) are exempt from load shedding thereby enhancing grid security. It would facilitate introduction of Free Governor Mode of Operation of generating units.” 4. CERC conducted an oral hearing on the petition number 4/2006 on 27th April 2006 wherein the Commission ordered as follows. [Section 13] “...We have also taken note of the views of the petitioner and the respondents on the question of revision of UI rates as also on payment security mechanism and reserve our orders on these aspects. For the time being the existing UI rates shall continue to be applied. The grid situation shall be observed for three weeks to gauge the impact of various disciplinary measures ordered today. If the situation does not improve to whole satisfaction of the concerned authorities, the proposal to revise the UI rates in order to induce grid discipline shall be taken up. Even during the intervening 25th January 2007 Page 1 of 14 POWERGRID three weeks, if State Utilities indulge in overdrawals against the direction of RLDCs the latter will be free to file the cases of indiscipline before this Commission.” 5. Based on the above order in petition no. 4/2006, NRLDC filed petition no. 25/2006 in the matter of ‘endangering grid security by undisciplined over drawal from the grid’. This was heard on 09th May 2006 and action under Section 142 of Electricity Act (EA) 2003 was taken against the respondent (and subsequently also upheld by the Appellate Tribunal for Electricity in Appeal number 88 of 2006). The matter was referred to an Adjudicating Officer who after due enquiry ordered action under Section 29 of the EA 2003 against the respondent. 6. Frequency profile (% of time frequency remained in the IEGC band of 49.0-50.5 Hz) of all the regional grids in the country since April 2006 is as below: Month April 2006 May 2006 June 2006 July 2006 August 2006 September 2006 October 2006 November 2006 December 2006 January 2007 Percentage of time frequency remained between 49.0-50.5 Hz South North Central (NorthEastEast-West grid) 25.9 65.1 76.2 86.3 96.8 95.6 81.6 97.5 98.7 70.5 97.7 99.4 60.8 97.8 99.2 95.9 98.6 90.2 89.5 88.8 99.3 87.2 89.6 71.7 87.9 *Combined North-East-West-Northeast grid The gradual deterioration in frequency profile in the last two years would be clear from the graph below. After some respite in May 2006, the frequency profile in Northern Region again deteriorated till 25th August 2006. It improved after the synchronization with Central Grid at 1220 hrs of 26th August 2006. This was mainly on account of good monsoon in East, West and South resulting in reduced power demand. The surplus power could be transferred to Northern region through the AC and DC interconnection. The frequency regime started deteriorating w.e.f 09th October 2006 with the tapering of hydro generation as well as increase in demand in all regions. 25th January 2007 Page 2 of 14 POWERGRID 7. POWERGRID submitted details of overdrawal of all constituents for the period 09th to 15th October 2006 to CERC as directed in their letter dated 17th October 2006. 8. SRLDC filed petition number 145/2006 in November 2006 in the matter of ‘ensuring secure and reliable operation of Southern Regional Grid by maintaining the grid frequency above 49.0 Hz. and review of the UI price vector’. This was heard by CERC on 11th January 2007. 9. The issue of revision of UI price vector has been under discussion throughout the year 2006 in different fora. Relevant extracts from these meetings is listed at Section G below. 10. The stakeholders concerns that are mentioned in the CERC order dated 27th April 2006 [Section 11] are stated below: “Notwithstanding shortage of power, grid security is of paramount concern.” “Any increase in UI ceiling rate would further tend to escalate the price of traded electricity. Simultaneously, there is also an urgent need to curb overdrawals and to remove the impression on the part of the utilities to consider regional grid as infinite source of power. Therefore, stronger commercial measures are required to curb overdrawing and to ensure full scheduling of liquid fuel generation.” 25th January 2007 Page 3 of 14 POWERGRID “Differential UI rates scheme will not result in zero sum of UI account matrix. It will result in system operator ending up with a surplus amount.” “There is a general apprehension that even after increase in UI price, it would be difficult to curb overdrawals completely. Therefore, under such situations all measures from grid stability point of view like automatic disconnection of load through frequency sensitive relays in the event of low grid frequency should be strengthened.” 11. On 19th December 2006 CERC conducted a public hearing on the creation of Power Exchange (PX) in India. It emerged during the consultations that trading through PX would have to coexist with short-term open access and the Unscheduled Interchange mechanism. 12. With the background mentioned above and the experience gained after the formation of synchronous North-Central Grid, a proposal for review of UI price vector is enumerated in subsequent sections. This is in compliance to the direction issued by CERC vide order dated 15th January 2007 in the petition 145/2006. Section-B: General principles of revised UI vector as agreed among five RLDCs 1. CERC order dated 15th January 2007 was received by POWERGRID on 19th January 2007. Thereafter it was communicated by all RLDCs to SLDCs and they were requested to forward their proposals. 2. Responses were received from UPPCL, PSEB, BSEB, WBSEB, DVC, JSEB, APTRANSCO, KPTCL, and TNEB. PSEB sought more time to study the issue while KPTCL informed that the matter was under the approval of their management. DVC, WBSEB and JSEB have proposed increase in UI rates from the viewpoint of grid security although no formal proposal has been submitted while others have shown reservation in increase of UI rate. 3. The SLDCs other than DVC, WBSEB and CSEB, who have responded, are generally in an ‘overdrawal’ mode. This response of constituents have been changing depending on the state’s power supply position viz. if the state is in surplus it would support enhancement of UI rates and if it is in a severe shortage situation it would resist any enhancement. However there is a concern as to how the grid security issue would be addressed by SLDCs notwithstanding their statutory responsibilities under Section 32 and 33 of the Electricity Act 2003. 4. The five RLDCs and Corporate System Operation, POWERGRID had an intensive discussion on the subject through the video conferencing sessions on 22nd and 23rd January 2007. The consensus that emerged in these discussions is as under. a. The UI price vector should be a simple curve so that it is easy to comprehend and administer. b. The UI price vector should be in the nature of a commercial signal that complements security. The mechanism should bring economy and efficiency through merit order generation and it should be consistent with the frequency linked despatch guidelines. 25th January 2007 Page 4 of 14 POWERGRID c. The vector should facilitate voluntary generation dispatch through commercial signal in accordance with the Indian Electricity Grid Code (IEGC) clause 6.2.8 [“When the frequency falls below 49.5 Hz, the generation at all ISGS (except those on peaking duty) shall be maximized, at least up to the level which can be sustained, without waiting for an advise from RLDC.”] d. The unrequisitioned liquid fuel generation is being despatched and scheduled to overdrawing states at frequency below 49.5 Hz. This is being done by RLDCs in accordance with the direction of the Honourable Commission in petition no. 4/2006. However, the liquid fuel generation should get voluntarily dispatched below 49.5 Hz without any need for post facto revisions. e. Demand side management through a commercial signal in the price vector is required between 49.5 to 49.0 Hz in accordance with IEGC clause 5.4.2. [“...the constituents shall endeavour to restrict their net drawal from the grid to within their respective drawal schedules whenever the system frequency is below 49.5 Hz. When the frequency falls below 49.0 Hz, requisite load shedding (manual) shall be carried out in the concerned State to curtail the over-drawal.”]. f. g. h. i. j. k. l. m. n. The rate at 49.0 Hz should be such that it brings out the latent generation, provides incentives for NegaWatts (NW) and thus dissuade overdrawal from the grid. This is also necessary to ensure grid security. Physical regulation and petitions for non-compliance have their own limitations and therefore they are to be sparingly used. The dynamics of the fuel price variations in the UI price vector could be incorporated through indexing of the UI rates to reduce distortions resulting from externalities. However for the time being, impact on UI mechanism on account of fuel price variations are to be incorporated by periodic revision through a consultative process. The present UI rates between 50.5 Hz to 49.8 Hz viz. zero at 50.5 Hz and 210 paise/kWh at 49.8 Hz could continue. In order to harness all available generation on bar including generation on liquid fuel below 49.5 Hz, the UI rate around 49.3 Hz has to correspond to the variable cost of generation on liquid fuel. In view of acute shortage and in order to harness the latent generation available in ISGS (through efficiency gains and design margins), the cap of 101%/105% on generation above the Declared Capability (DC) might be removed. The compensation for the extra generation over and above the DC would have to be suitably designed. The state utilities could be compensated as per the proposed UI rates for under drawal from grid. The UI price vector should be uniform in all regions. A suitable payment security mechanism in the form of credit instrument is necessary. Other issues like- ‘different buy-sell rate’, ‘geographical differential rates’, ‘congestion management through differential UI rate’, ‘different peak/offpeak rate’, ‘cap on UI volume’ are very intricate issues and could be discussed after observing the grid performance with the revised UI rate and development of organized marketplace [PX] in India. 25th January 2007 Page 5 of 14 POWERGRID Section C: UI rate proposal The UI rates proposed are as under: i) ii) iii) Above 50.5 Hz At 49.80 Hz Below 49.02 Hz : zero (no change vis-a-vis existing) : 210 paise/kwh (no change) : Not lower than 930 paise/kwh (existing level is 570 paise/kwh) Between 49.02 Hz and 49.8 Hz, the UI rate could vary in any manner (linear or exponential), with or without any kinks at intermediate points. The only requirement is that there should be a strong signal for full dispatch of all the combined cycle power plants operating on naphtha (energy cost of the order of 650 paise/kwh) by 49.3 Hz. There was a general agreement that in view of the acute energy shortage in the entire country, efforts must be made to conserve fuel and avoid operation above 50 Hz to the extent possible. NRLDC had expressed similar views in petition no. 4/2006. However in the absence of any cap on UI volumes, this might result in network congestion in case Northern region load centre based power plants start backing down as per the frequency linked despatch guidelines. Hence we do not propose any change in the UI rate between 49.8 Hz to 50.5 Hz. The rationale for the ceiling rate below 49.02 Hz is indicated in Section D below. Section D: 1. Rationale for the UI ceiling rate below 49.02 Hz suggested at not lower than 930 paise/kwh in Section C above. Should there be separate steeper rates below 49.0 Hz ? In the earlier deliberations in RPC fora and Ministry of Power, a suggestion for having different UI rates below 49.0 Hz was advocated by many stakeholders. We feel that this is inconsistent with the IEGC provisions where the need to maintain frequency in the 49.0 –50.5 Hz band is emphasized. With the formation of the extended North Central grid, there is a need to further restrict the operation band to 49.5 to 50.0 Hz so that a frequency change does not lead to large changes in line flows. The UI price mechanism should give strong signals to maintain the frequency within this band instead of 49.0-50.5 Hz. The operation below 49.0 Hz is to be treated as a violation of the IEGC and addressed as such. In fact the Appellate Tribunal for Electricity in its order dated 28th September 2006 in Appeal no. 88 of 2006 has pronounced as under: ‘36. It appears that this submission of the learned senior counsel is purportedly based on Clause 6.4.7 of IEGC, which, inter-alia, provides that deviations from the ex-power plant generation schedules shall be appropriately priced through the UI mechanism. But the learned senior counsel for the appellant overlooked the mandate of clause 6.4.4, which prescribes that when the frequency falls below 49 Hz requisite load shedding 25th January 2007 Page 6 of 14 POWERGRID shall have to be carried out to curtail the overdrawal. Up to a frequency of 49.0 Hz, system can be controlled by UI but below that it must be controlled by the stringent provisions of section 142 of the Act, as the safety and the security of the grid cannot be jeopardized since it affects the other beneficiaries.’ Therefore any proposal for stretching UI price vector below 49.0 Hz, if implemented, would be a serious threat to grid security. This has also been covered in Section 5.9.8 of ABT Order dated 4th January 2000 of the CERC. However, the commercial signal below 49.5 Hz itself should be strong enough to avoid operation below 49.0 Hz. 2. Rationale for UI rate at 49.0 Hz: This issue has been discussed at several stages and is briefly reproduced below. i. ECC Report, Feb 1994: Section 4.6.4 of page 4-19 of the Report under ‘Frequency Linked UI tariff option’ states ‘Specifically, UI would be priced in this scheme as follows: Pit head incremental cost when frequency is greater than 50.3 Hz. Load center incremental cost when frequency is between 49.7 Hz and 50.3 Hz. Diesel generation incremental cost when frequency is below 49.7 Hz.’ Thus the ECC Report considers the diesel generation incremental cost as the highest cost to be payable for imbalances below 49.7 Hz. ii. CERC order dated 4th January 2000 in petition no. 1/99: Again Section 5.9.7 of this order indexes the UI rate to diesel generation. The UI ceiling rate worked out as per this methodology was 420 paise/kwh when diesel prices were Rs. 13.33 per litre. iii. CERC order dated 16th January 2004 in petition no. 67/2003: Again the UI rate has been indexed to diesel generation cost. The UI ceiling rates worked out to 600 paise/kwh when the diesel prices were Rs. 21 per litre. iv. Petition no. 4/2006 filed by NRLDC in January 2006 and detailed proposal in March 2006: NRLDC had also suggested that the UI ceiling rate should be indexed to diesel prices which worked out to 950 paise/kwh based on diesel price of Rs. 33.65 per litre. v. MERC order on CII proposal to harness captive generation during peak hours to make Pune load shedding free: In order dated 2nd March 2006 in case no. 29 of 2005 and order dated 16th May 2006 in case no. 1 of 2006 issued by the MERC, the average fuel efficiency of captive sets in Pune industrial area has been assumed as 3.49 kwh/litre and with the average diesel rate of Rs. 38 per litre, a rate of Rs. 11.04 per kwh has been approved by MERC. vi. Agreements for unrequisitioned liquid fuel generation from NTPC combined cycle plants signed in the recent past: These agreements have 25th January 2007 Page 7 of 14 POWERGRID been signed for rates ranging from 746 paise/kwh to 874 paise/kwh ex-power plant. Open Access charges, scheduling charges and transmission losses are borne by the buying utility. In case of drawal of power through the UI mechanism, no transmission charges and transmission losses are payable. Considering the present UI ceiling rate of 570 paise/kwh, these agreements have not translated into scheduling. If one considers a rate of 750 paise/kwh ex-power plant and a pan India power transfer through Open Access, leading to an incremental loss of say 20% over three regions, the rate at the buyer’s periphery would be 940 paise/kwh. The UI rates need to be more than this value to ensure that the plant is despatched at that low frequency level. Since April 2006, NRLDC has been directed to ensure that the liquid fuel within the region is despatched fully whenever the frequency is low and the extra generation be booked to the overdrawing constituents. In case the UI ceiling rate is lower than 930 paise/kwh, this mode of centralised despatch would continue. Already suggestions have been made for extending this arrangement to liquid fuel stations outside the region also. This is not in conformity with the operating philosophy of decentralized despatch adopted in the country and provides scope for disputes. This is also not in conformity with the spirit of Section 28(3) a of the Electricity Act 2003. The diesel generation rate worked out through some of the above references is tabulated below (based on Jan-07 price levels) In view of all the above facts, the UI ceiling rate below 49.02 Hz has to be greater than 930 paise/kwh. Incidentally all the calculations in the table above do not include the fixed charge component of 160 paise/kwh that had been considered while working out 420 paise/kwh and 600 paise/kwh. Further in the latter case, the fuel efficiency of diesel generation has been considered as 5 kwh/litre by CERC, which would be the case for a combined cycle plant. Although internal combustion diesel engines of this 25th January 2007 Page 8 of 14 POWERGRID efficiency are available worldwide, their percentage would be very small. The MERC order no. 29 of 2005 on Pune captive generation gives 3.49 litres/kwh as the industry average for that belt and compares well with the figures listed in NRLDC petition no. 4/2006. Section E: Stakeholder concerns voiced in the past Several issues like undue gains to ISGS for generation beyond DC and up to 101% of DC , traded prices going up and grid security issue would not get resolved through enhanced UI prices have been raised in the past. 1. Generation beyond Declared Capacity (DC) by ISGS: It is proposed that to harness all the latent generation from coal fired stations in the form of efficiency gains through lower auxiliary consumption and the inherent design margins, caps on the generation above Declared Capability is removed. At the same time to avoid any undue profits to the generator on account of a rise in UI ceiling charges, the following checks are suggested on UI charges payable to ISGS for generation above Declared Capability (DC). a. For coal fired thermal stations: i. In case DC Consumption) >= Capacity on bar/(1-Normative Aux. No 101/105% cap but all UI payments would be restricted to a rate per kwh specified by the Commission or UI rate whichever is lower. ii. In case DC<Capacity on bar/(1-NAC) b. 101/105% cap on UI and all UI payments would be restricted to a rate per kwh specified by the Commission or UI rate whichever is lower. For gas fired and hydro stations: 101/105% cap on UI and all UI payments would be restricted to a rate per kwh specified by the Commission or UI rate whichever is lower. 1. Prices of traded power vis-a-vis UI rates: UI price is in the form of a vector and it varies from 0 to the ceiling rate depending on the frequency. Therefore comparison of the ceiling rate with traded price is inappropriate. Further only 5-6% of the total electrical energy exchanged in the country is through short term trading and UI and the balance 94% is through long term contracts. Short term trading and UI is used by state utilities to balance their portfolios on the day of operation. As on date, the additional power that is available in the grid is only on account of liquid fuel and embedded generation, which has to be harnessed in case load shedding is to be minimized. Notwithstanding the present UI ceiling rate of 570 paise/kwh, short term traded prices have already breached this UI ceiling value. 25th January 2007 Page 9 of 14 POWERGRID Any constituent overdrawing in large quantities in a shortage scenario would naturally object to the UI rates being enhanced while any constituent who has a balanced portfolio (with a small quantum of short term trades and UI) and maintaining his drawal within schedule need not be unduly concerned about the UI rates. 2. Grid security: The UI price signal should be strong enough to harness all the latent generation and discourage unlimited overdrawals at low frequency. On account of vividness bias, this aspect affecting grid security is not recognized and the more visible traded prices is only seen. A strong price signal for NegaWatts, which has to be periodically reviewed by the Commission, would greatly complement grid security. Ultimately this price signal should get translated to the retail level and the process has already started in some states with the implementation of intra-State ABT and this needs to be expedited. The same has to be strengthened at the wholesale level also. Signals at both these levels would only enhance grid security. We believe that the issue should be seen as one of enhancement in grid security and not as one of enhancement in UI prices. Section-F: Related Issues that could be taken up at a later stage 1. Congestion management through UI mechanism: The regional grids in India are by and large congestion free. In fact the entire Unscheduled Mechanism as implemented in the Indian grid presupposes a constraint less transmission system. However subsequent to the formation of the North-central grid, the problem of line overloads in a few pockets has been experienced on certain occasions. The identifiable reasons for occasional transmission constraints are as below: (i) (ii) (iii) (iv) (v) (vi) (vii) Long years of congestion free operation leading to an inadequate appreciation of the line loading aspects of system security Sharp changes in the interchange with the grid due to bulk load regulation and start-stop of hydro units at the hour boundaries. Huge gap in the demand and supply and the pressure to meet the demand General perception of UI as an infinite source Market distortion caused by the difference in the ceiling UI rate and the marginal cost of generation from liquid fuel Absence of line-loading/transmission component in the UI mechanism Skewed despatch scenario under abnormal conditions. In India no congestion management tools such as Locational Marginal Pricing (LMP) exists and the UI mechanism does not have a ‘line-loading component’ as brought out by the Joint Inadvertent Interchange Task Force (JIITF) Report1. Congestion is presently being handled through real-time operation in line with section 7.5.10 of the IEGC and section 6.4.9 of the IEGC. (UI to be curtailed first followed by short term bilateral followed by long term contracts). 1 The White Paper issued by the Joint Inadvertent Interchange Task Force (JIITF) constituted by the North American Electric Reliability Council (NERC) on 10th May 2002 has divided the issue of Inadvertent Interchange into three components viz. the frequency component, line loading component and the energy component. In the Indian context, the frequency linked UI mechanism has bundled the energy component and the frequency component. 25th January 2007 Page 10 of 14 POWERGRID A cap on UI volumes had been proposed by NRLDC in petition no. 4/2006 to address the issue of line loading. However caps have their limitations and result in market distortion. Therefore further studies are required in this area of congestion management. Thus UI is as at present (for the time being) not being envisaged as a congestion management tool and a uniform frequency linked UI price vector is proposed for all the regions in India. Section G: Extracts from meetings at Ministry of Power, RPC and other forum regarding UI rates. “Higher penal rate below 49.0 Hz would act as a deterrent for over drawal from the grid.” Chief Secretary, Government of Punjab Minutes of the meeting taken by Secretary (Power), Government of India [7.1 (vi)], 6th May 2006 “Freezing UI rate at 49.0 Hz was proving to be counter productive as the state is forced to under draw from the Regional grid on account of overdrawal of other states and the gap equivalent to underdrawal is required to be filled with naphtha based generation which is costing about Rs. 7-7.50 per kwh. The UI rate below 49.0 Hz should therefore be increased and there should be a cap on the price of traded power.” Principal Secretary (Energy), Government of Haryana Minutes of the meeting taken by Secretary (Power), Government of India [8.1 (ii)], 6th May 2006 “Enhanced penal rate below frequency of 49.0 Hz as suggested by Haryana would be necessary.” Secretary (Energy), Government of Rajasthan Minutes of the meeting taken by Secretary (Power), Government of India [9.1(viii)], 6th May 2006 “Enhanced penal rate for frequency below 49.0 Hz will be desirable. But there should be capping on price of traded power also.” Principal Secretary, Government of Uttar Pradesh Minutes of the meeting taken by Secretary (Power), Government of India [10.1(xvi)], 6th May 2006 “Other constituents of Northern Region also expressed unanimity in regard to need for higher UI arte below 49.0 Hz. Secretary (Power) agreed to bring the opinion of Northern Regional constituents to the notice of CERC, who is already seized with the matter.” Minutes of the meeting taken by Secretary (Power), Government of India [8.2], 6th May 2006 “Since it was unanimous view to have enhanced penal rate below frequency of 49.0 Hz., the matter will be referred to CERC for appropriate action.” Secretary (Power), Government of India Minutes of the meeting taken by Secretary (Power), Government of India [12 (viii)], 6th May 2006 25th January 2007 Page 11 of 14 POWERGRID “Surplus power of Captive Power Plants (CPPs) needs to be tapped with mitigation of cost of power from CPPs with proper dispensation from the concerned Electricity Regulatory Commission for this purpose keeping the consumers duly informed about the efforts made by the distribution utility to supply power to avoid load shedding by procuring costlier power during the periods of high demand...” Secretary (Power), Government of India Minutes of the meeting taken by Secretary (Power) to review the operational discipline in Northern and Western Regions [3(iv)], 20th October 2006 Secretary (Energy), Rajasthan suggested substantial enhancement in price of UI charges below 49.0 Hz to deter the states from overdrawing energy from the grid. Minutes of the meeting taken by Secretary (Power) to review the operational discipline in Northern and Western Regions [7.], 20th October 2006 “CE, TNEB said that the present rate is also high and suggested UI rate of zero paise above 50.3 Hz.” Section 3.5.3, Minutes of 118th TCC meeting of SRPC 17th March 2006 “Director (Tr. & GO), APTRANSCO said that at present the costly Naptha generation was not being scheduled even at very low frequency, and with the suggested increase in rates at low frequency the costly generation may be injected into the grid. He suggested a decline in slope after 50 Hz to discourage ISGS injection at higher frequencies.” Section 3.5.3, Minutes of 118th TCC meeting of SRPC 17th March 2006 “The constituents fully appreciated the need for curtailment of overdrawals and providing commercial deterrents by way of penalties for frequencies below 49.0 Hz.” Section 1.1, Minutes of 140th SRPC meeting 18th March 2006 “WRLDC proposed to increase the U.I. rates by 1.5 times for deviation at or below 49 Hz; to levy a penalty of Rs.1 lakh per time block whenever the overdrawal during any time block is more than 200 MW and the average frequency is less than 49 Hz. ” Section 4, Special meeting of WRPC 13th January 2007 “The utilities were generally of the view that imposition of financial deterrents might not help in bringing in grid discipline...Regarding increasing the UI rates, it was felt that it may boost the rates of power available through bilateral trading.” Section 5, Special meeting of WRPC 13th January 2007 Section H: Extracts from SLDC responses received against CERC order dated 15th January 2007 “APTRANSCO is of the view that increase in UI prices is not required as it results in (i) bench mark price for power traders and increase in power purchase cost (ii) any further increase UI price will not address the power system operational issues fully.” Chief Engineer/Comml., Transmission Corporation of Andhra Pradesh 25th January 2007 Page 12 of 14 POWERGRID Letter no. CE/COmml/APPCC/pet-srldc/D.No. 383/07 24th January 2007 “Increasing the Ui prices will only result in abnormal increase in the price of surplus power available and offered for sale through the traders... TNEB is of the view that any increase to the existing UI rates need not be attempted for the present under the guise of secure grid operation.” Executive Director /Operation, Tamil Nadu Electricity Board Letter no. ED/O/SE/LD&GO EG/A7/CERC/D/95/07 23rd January 2007 ”Suitable enhancement of UI may kindly be considered for more security and more reliable operation of the grid.” Chief Engineer, SLDC, Damodar Valley Corporation Letter dated 24th January 2007, in reply to ERLDC’s message no. GM/OPRN dated 02nd January 2007 “For many a period of the day, grid frequency is remaining below 49.0 Hz. This indicates that some of the constituents are not controlling overdrawal at low frequency. Grid discipline is being weakened. Increase in UI rates may compel them to reduce overdrawal and in turn to maintain frequency with permissible range.” Chief Engineer, SLDC, West Bengal State Electricity Board Letter dated 24th January 2007 in reply to ERLDC’s message no. GM/OPRN dated 02nd January 2007 “The Unscheduled interchange has been imposed to maintain grid discipline. The present trend of frequency is quite below than it was before synchronization with N.R. Considering safety and stability of transmission network, if ERLDC feels change in U.I. charges, may be considered.” SCE, SLDC (for Chief Engineer, SLDC), Jharkhand State Electricity Board Message no. 118 dated 24th January 2007 “On pragmatic grounds too and in the light of recent experiences, it doesn’t seem advisable to enhance the UI rates further.” Chief Engineer (Power System), Uttar Pradesh Power Corporation Letter no. 24/CE(PS)/NRLDC/EE-2 24th January 2007 “The revision of the Unscheduled Interchange (UI) is not necessary on All India basis as the present system of UI is working satisfactorily...Further also Bihar is not having any generation of its own and have to depend heavily on its share in the generation of the Central Sector and in the event of the planned shutdown of any of the unit of the Central Sector generating station, the respondent BSEB have to depend on UI to meet its essential load in the state” Chief Engineer, Trans. (O & M), Bihar State Electricity Board Letter no. Com/CERC-602/2006/70, dated 24th January 2007 25th January 2007 Page 13 of 14 POWERGRID Section I: List of references 1. ECC Report: ‘Study of Bulk power and transmission tariffs and transmission regulations’ February 1994 2. CERC order dated 4th January 2000 on Availability Based Tariff (ABT) 3. CERC order dated 16th January 2004 on ‘Terms and Conditions of Tariff with effect from 1st April 2004’ 4. CERC order dated 15th July 2004 on amendment to ‘Terms and Conditions of Tariff with effect from 1st April 2004’ 5. Electricity Act 2003 6. Indian Electricity Grid Code (IEGC)-December 2005 issue with amendments 7. Petition no. 4/2006 filed by NRLDC 8. CERC order dated 27th April 2006 in petition no. 4/2006 9. CERC order dated 9th May 2006 in petition no. 25/2006 10. Appellate Tribunal for Electricity order dated 28th September 2006 in Appeal no. 88 of 2006 11. CERC order dated 15th January 2006 in petition no. 145/2006 12. North American Electric Reliability Council (NERC) Inadvertent Interchange: A White Paper prepared by the Joint Inadvertent Interchange Task Force: Draft 5d, 10th May 2002 25th January 2007 Page 14 of 14