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Partnership to Advance Clean Energy-Deployment

(PACE-D)

Third Knowledge Exchange Workshop

Support for Implementation of Renewable Purchase Obligation

(RPO) Compliance Monitoring and Web Tool Development for

Rajasthan Renewable Energy Corp. Ltd. (RRECL)

June 30, 2016

Background

Rajasthan Scenario: Summary of RPO Regulations

PACE-D TA Program’s Support to Rajasthan in Developing RPO

Compliance Framework

Designing RPO Compliance Reporting Framework:

Approach for Reporting Framework

Structure and Role of the State Level Working Group

Role of State Level Working Group

Web Tool Functionalities: Key Parameters and Requirements

Key Issues to Be Addressed

Web Tool Screen Shots

Current Status and Way Forward

2

In This Presentation

3

Maharashtra and Rajasthan were among the initiators of RPO movement in the country.

By 2009-10, almost all the Indian states notified their RPO regulations.

RE installed capacity has increased from around 15 GW to 47 GW in the last five years

with a CAGR of ~25 percent.

Compliance of RPO by the obligated entities is a critical factor for sustainable growth of RE

sector in India.

RPO: A Key Driver for Growth of RE Sector

4

Objective for Developing RPO

Compliance Monitoring Framework

In line with mandate under EA 2003 and policies thereof, 29 States/UTs have specified

obligation for purchase of renewable energy by obligated entities.

RPO compliance monitoring is crucial to ensure that RPO targets are met and to ensure

that the non-compliance is brought to the Regulators in a timely manner.

While RPO compliance monitoring for DISCOM takes place through the annual

performance review exercise before the SERC, the compliance monitoring for other

obligated entities like captive consumers and OA consumers is far from satisfactory.

Moreover, the RPO compliance review process is undertaken with significant time lag.

Presently, RPO compliance reporting up to FY15 (or FY14 in few cases) has been

undertaken.

Out of 29 Commissions and 10 State ERCs have initiated Suo-Motu proceedings for

reviewing the compliance status of RPO by OA and captive consumers.

Hence, there is need for process driven and technology-based solutions to address

this challenge.

Possible solution could be in the form of a web-based tool to monitor, record and

report the real time compliance status of RPO by obligated entities to State

Commissions.

5

RPO Compliance Monitoring:

Status in Key States

Maharashtra Gujarat Chhattisgarh Madhya

Pradesh

Uttarakhand Rajasthan

CPP/OA consumers

recognized as OEs in RPO regulations

Y

OA: 1 MVA

and above

CPP: 1 MW and above

Y

CPP: 5

MW and

above and OA

Y

CPP/OA: 1

MW and

above

Y Y

Y

CPP/OA: 1

MW and

above

Suo-moto initiatives/

order by SERC on

RPO compliance monitoring

Y Y N

Only for

solar

RPO

(order on petition)

Y Y

Enforcement on

OEs for non-compliance of RPO

Y N N INR

25,000 INR 20,000

Surcharge

of INR 3.59/kWh

SNA initiatives for

RPO compliance

data collection and reporting

Y N Y N Y Y

Standard forms/

formats for RPO

compliance data collection

Y N Y N Y Y

Sr.

No .

Regulation/

Order No. Name of the Regulation/Order Highlights

1 66/23-Mar-2007 Renewable energy obligation RPO targets for year 2007 to 2012 were stipulated.

2 16-Jun-2010 State agency for RE projects RRECL nominated as the State Agency for

Accreditation and Recommending the RE Projects.

3 82/23-Dec-2010

Renewable Energy Certificate and

Renewable Purchase Obligation Compliance

Framework

Details of REC and RPO Compliance framework for

Rajasthan.

4 86/24-May-2011 RE Obligation (First Amendment) RPO targets for year 2011 to 2014 were stipulated.

5 31-Aug-2012 Date of pronouncement of High Court Order

on CPPs and OAs

CPPs approached Rajasthan High Court against the

RERC RPO obligation on CPP and OA consumers

and to pay surcharge in case of shortfall, which High

Court rejected.

6 108/30-May-2014 RE Obligation (Second Amendment) RPO targets for year 2014-15 to 2016-17 were

stipulated.

7 112/18-Mar-2015 RE Obligation (Third Amendment) Amendment in Regulation 2 and 4.

8 2015

Supreme Court Judgment upholding Hon’ble

Rajasthan High Court Judgment and RERC

RPO Regulations & applicability to CPP/OA

users

RERC RPO regulations falls within the Act and the

regulation have been enacted to promote RE which

principle is enshrined in the Act, The National

Electricity policy, 2005 and the Tariff Policy 2006.

9 2016

RERC (Renewable Energy Certificate and

Renewable Purchase Obligation Compliance

Framework) (First Amendment) Regulations,

2016

RERC invited suggestions/comments on Draft First

Amendments to RPO Regulations, 2016 by Feb 04,

2016. The amendments cover utilisation of Fund by

RVPN for transmission/evacuation augmentation.

Background: RPO for CPP/OA Users in Rajasthan

7

RPO Trajectory

CPP and OA consumers with total capacity of

10 MW and above:

CPP and OA consumers with capacity of 1

MW and above, but less than 10 MW:

Obligated Entities

1. Distribution licensee including deemed licensee

2. Open access consumer

3. Captive consumer of a captive power plant of

installed capacity one MW and above Sr.

No. Year

Obligation Expressed as

Percentage of Energy

Consumption

Non Solar Solar Total

1 2014-15 7.5 1.5 9.00

2 2015-16 8.2 2.00 10.20

3 2016-17 8.9 2.5 11.40

Sr.

No. Year

Obligation Expressed

as Percentage of

Energy Consumption

1 2014-15 9.00

2 2015-16 10.20

3 2016-17 11.40

Penalty on Non-Compliance

OE to deposit into a separate fund, to be created

and maintained by such OE, as RPO charge as

the Commission may determine on the basis of the

shortfall in units of RPO and the forbearance price

decided by CERC

Liable for penalty as may be decided by the

Commission under section 142 of EA-03

Section 142: … such person shall pay, by way of

penalty, which shall not exceed one lakh rupees

for each contravention and in case of continuing

failure with an additional penalty which may

extend to six thousand rupees for every day during

which the failure continues …

Rajasthan Scenario: Summary of RPO Regulations

8

PACE-D Technical Assistance Program: Support to RRECL for RPO Compliance Framework

Clean energy Policy and Regulatory Support is one of the focal areas of the

USAID PACE-D TA Program.

The Program is focusing on strengthening the organizational, institutional and

resource capabilities of State Nodal and Designated Agencies in four states:

Rajasthan, Madhya Pradesh, Haryana and Karnataka.

As a part of this initiative, the Program is supporting Rajasthan SNA (RRECL) in

the development of RPO compliance monitoring and reporting framework (RPO -

CMR):

Assistance in RPO Compliance Reporting Cell formation in RRECL.

Assistance in formation and coordination for State Level Working Group.

Assistance in designing the data collection forms/formats and approval from RERC.

Assistance in developing the documents: Accreditation Guidebook for Obligated

Entities., URS Document and Web Tool Hosting Requirement for RRECL.

Assistance in design of basic framework for RPO CMR.

Assistance in development of a web based tool for RPO compliance reporting.

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Captive Consumer

• To submit RPO accreditation application

• To submit quarterly data in format specified by

RRECL in soft as well as hard copy

• To Comply RPO obligation annually

SLDC

• Submit the following RPO data in soft as well as in hard copy to RRECL: OA consumer RPO verification

and validation data quarterly • Attend quarterly RPO meeting at

RRECL

Open Access

• To submit RPO accreditation application

• To submit quarterly data in format specified

by RREL in soft as well as hard copy

• To Comply RPO obligation annually

DISCOMs

• Submit the following RPO data in soft as well as in hard Copy to RRECL: CPP RPO verification and

validation data quarterly OA consumer RPO verification

and validation data quarterly Their own RPO data quarterly

• Comply RPO obligation annually • Attend quarterly RPO meeting at

RREL

RRECL • Quarterly collect RPO data from

CPP, OA consumers and DISCOMs • Verify and validate RPO data

from DISCOMs, SLDC • Arrange quarterly meetings of

DISCOMs, SLDC • Submit quarterly and annually

compiled data to RERC for approval

• Accredited CPP and OA consumers data

• Publish annually CPP, OA consumers & DISCOMs data

Role and Responsibilities Under

RPO/REC Regulations

10

Step 1: RPO

Reporting Cell

Step 2: Form/

Format Design

Step 3: Manual for

Obligated Entities

Step 4: Reporting

Framework Design Step 5: Development

of a Web Tool Step 6: Compliance

Reporting to RERC

Cell Structure,

Role and

Responsibilities

of Members

Formats for RPO

Compliance Data

Collection From

OEs

Protocol for Data Collection

and M&V, Process for OE

(CPP/OA) Accreditation, List of

OE and Updating the OE List

Quarterly

Reporting to

RERC

RPO information

manual for OEs

Approach for RPO Compliance

Reporting Framework Development

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Accreditation Process: Role of RRECL

Application for availing accreditation by obligated entity to the state agency.

Application shall contain details of obligated entity, owner/operator, location, monthly

and annual consumption (past period and ensuing year), metering arrangement,

connectivity (drawl point) and declaration.

Separate application for each consumption/drawl point of obligated entity.

Obligated

Entity RRECL SLDC

Verification Prior to

Accreditation for TOA Application for

Accreditation

DISCOMs

EI

Verification Prior to

Accreditation for CPPs

Verification Prior

to Accreditation for DOA

Confirmation of

Accreditation

Intimation of

Accreditation

Intimation of

Accreditation

12

Structure for State Level Working

Group

Working Group to address various potential issues faced in monitoring,

verification and compliance of RPO of all the obligated entities including the

captive consumers and OA consumers.

State Level Working Group, constituted by GOR, DOE with following members:

1 Principal Secretary, Energy Chairman

2 MD, RRECL Member

3 Director (Technical), RVPN Member

4 Chief Engineer (RSLDC) Jaipur Member

5 Director (Engineering)/Secretary/Representative from

RERC Member

6 Chief Engineer (RDPPC) Jaipur Member

7 SE (Commercial), Jaipur DISCOM Member

8 SE (Commercial), Ajmer DISCOM Member

9 SE (Commercial), Jodhpur DISCOM Member

10 Chief/Sr. Electrical Inspector, Jaipur, Rajasthan Member

11 Director (Technical), RREC, Jaipur Member Convener

12 Representative From PACE-D TA Program Consultant

Role of State Level

Working Group

Accreditation Process and Conditions: To develop mechanism for listing and

accreditation of CPP and OA consumers and set rules for accreditation of CPP and OA

consumers.

Data Requirement and Information Sharing Protocol: To develop mechanism for

establishing data flow and information exchange between various entities involved (OA

consumers to DISCOMs, CPPs to Electrical Inspector’s Office, DISCOMs to RRECL and

Electrical Inspector’s Office to RRECL), and to verify RPO compliance by CPP and OA

consumers.

Inputs for Functional Design of RPO Web Tool: RRECL with support of the Program is

developing Web tool. However, functional requirements, user rights, reporting requirement

etc. will be approved by the Working Group.

Monitoring and Review Mechanism: To meet on bi-monthly basis to review and, modify

the mechanism, if found necessary.

Guidance and Support to State Agency: To provide continued assistance to RRECL in

verification of RPO compliance by CPP and OA consumers.

Convenor: RRECL shall act as a convenor of the Working Group, it shall arrange for

secretarial support to Working Group, maintain minutes of Working Group meetings and be

responsible for co-ordinating and reporting the developments to GOR on bi-monthly basis.

Key Issues to Be Addressed for RPO

Compliance Monitoring and Reporting

1. Identification of obligated entities and listing.

2. Verification of data submission by CPP consumers.

3. Verification of data submission by OA consumers.

4. Practical difficulties in monthly data submission.

5. Design and development of standard data formats.

6. Standard methodology for energy accounting and computation of RPO

compliance of obligated entities.

7. Lack of check on double accounting of RPO compliance.

8. Lack of streamlined RPO related data flow between OEs and RRECL.

9. Lack of awareness among obligated entities.

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Representation of

Data to Web

Based Online User

Interface

Defining System

Users and Their

Categories and

Access Rights

(Accreditation

Process)

Presentation of Data

in User Friendly

Format (Excel/PDF)

1 2 4 3

Regular Update of

Data -

Consumption,

Generation and

Procurement

(Forms/Formats)

Monitoring,

Verification and

Validation Protocol

and Information

Exchange

Classification of Data

Based on Obligated

Entity/Type/DISCOM/

Location

Scalable System to

Incorporate

Future/Upcoming

Obligated Entities

Alarm, Report

Generation, etc.

5 6

9

7

Mail Services, System

Security and

Compliance

Reporting, Report

Generation, etc.

Admin. Interface for

Incorporating New

Systems and Changes

10

8

Web Tool Functionalities for RPO

Compliance Monitoring:

16

Database Web API

Application

Server

Browser

Software Interface: Client on Internet

Web Browser, Operating System (any)

Web Server

IIS, Operating System (Windows)

Data Base Server

PostgreSQL, Operating System

(Windows)

Development End

Visual Studio, Operating System

(Windows)

Hardware Interface:

Technologies:

RDBMS: Relational Database

Management System

MVC: Model View Controller

Bootstrap: Front-End

Framework

Server Processor RAM Disk

Space

Application

All Intel or AMD

(1 GHz or

Higher)

4 GB 100

GB

Database

All Intel or AMD

(1 GHz or

Higher)

6 GB 100

GB

Web Tool Functionalities for RPO

Compliance Monitoring: Key Requirements – Software and Hardware Interface

17

State Agency DISCOM Open Access

Consumer

CPP User

Conventional Energy Renewable Energy

Solar Wind Biomas

s

Coal Nuclear

Total Energy Consumed

Obligated Entities

Own Generation/Purchase

Hydro

C

RECs

RPO Compliance: Functional Flow Diagram … 1/2

Log In

Total Energy Consumed

C

RPO Compliance

Add REC Information, (If

required)

View Monthly Report and

Download

Upload Signed Monthly Report

View and Verify by State

Agency

Monthly/Yearly Report

Generate

Submit to RERC

Note:

• All records should be

maintained as per financial

year.

• No information will be

saved without relevant

documents.

• Predefined grace period for

data entry.

• RPO compliances not

applicable for energy

procured from DISCOM.

State

Agency

RPO Compliance: Functional Flow Diagram … 2/2

Other Issues

Practical Difficulties in Monthly Data Submission:

– Consensus to be evolved for making data submission on

Monthly/quarterly basis.

– Regulations may have to be suitably amended to revise the frequency of

data submission on monthly/quarterly basis with month-wise break-up for

the quarter.

Lack of Awareness Among Obligated Entities:

– RRECL should initiate periodic consultation process for generating

awareness among CPP and OA consumers.

– RRECL to prepare manual for obligated entities (RPO Manual is

prepared).

– DISCOMs/SLDC should sensitize OA consumers about RPO compliance

requirement at the time of grant of open access permission.

– EI should sensitize CPP consumers about RPO compliance requirement

at the time of registration of CPP.

20

Web Tool Screen Shots: Work Under Progress

Registration Screen

State Agency: Roles

21


Verification

Obligatory Entities:

Periodic Consumption

22


Reports: Compliance Report

Contact Us:

Help: Documents

Current Status:

Institutional structure at RRECL is put in place.

Following documents have been developed and are shared with RRECL:

Standard Forms and Formats for RPO Compliance Data Collection.

Accreditation Guidebook for Obligated Entities.

Web Tool Hosting Requirement.

User Requirement Specification Document has been prepared and would be shared with RRECL

soon.

Collection of data for identification of obligated entities (CPP and OA consumers) is under process.

Design of basic framework for RPO compliance monitoring and reporting for RRECL has been

developed.

Web tool for RPO compliance monitoring has been developed. Testing is in progress.

Way Forward:

First Meeting of State Level Working Group took place in March 2016. Interactions/Feedback from

RRECL team during the course of RPO Web tool development.

Showcasing of Beta version of the RPO Web tool for Working Group being planned soon.

RPO Web Tool for RPO compliance monitoring to be finalized in consultation with the Working

Group.

23

Current Status and

Way Forward

24

Thank You

Anurag Mishra Senior Clean Energy Specialist

USAID/India

Email: [email protected]

Nithyanandam Yuvaraj Dinesh Babu Chief of Party

PACE-D TA Program


Ajit Pandit Lead Consultant - Policy and Regulations

PACE-D TA Program
