Draft First Amendment to the TGERC (Terms and Conditions of Open Access), Regulation – EQ
Summary:
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**1. Regulation Overview**
* **Purpose:** To amend the **TGERC (Terms and Conditions of Open Access) Regulation, 2024** (Principal Regulation No. 1 of 2024).
* **Primary Driver:** To align the state regulation with the **Central Electricity Regulatory Commission (CERC) Procedure for Implementation of REC Mechanism 2024** and clarify the beneficiary of Renewable Energy Certificates (RECs) for banked energy under Green Energy Open Access (GEOA).
**2. Context & Problem Statement**
* **Original Provision (Clause 33.5):** Under the 2024 regulation, RECs for unutilized banked energy were to be issued to the **GEOA consumer** (the entity consuming the power).
* **Central Guideline (CERC 2024):** The CERC’s procedure mandates that RECs for surplus/unutilized banked energy be issued to the **Renewable Energy Generator**.
* **Request for Change:** The Telangana State Load Despatch Centre (TGSLDC), following clarifications from the National Load Despatch Centre (NLDC) and the CERC procedure, approached the TGERC to amend the state regulation accordingly.
**3. Core Amendments**
Two specific clauses of the 2024 Open Access Regulation are being modified:
1. **Amendment to Clause 14.11 (Treatment of Early Injected Energy):**
* **New Wording:** Any energy injected into the grid by a GEOA applicant **between the date of grant of open access and the date of signing the wheeling agreement** will not be paid for. This energy will be classified as **”inadvertent power”**.
* **Implication:** This prevents generators from claiming payment for energy supplied before formal commercial arrangements (wheeling agreement) are in place, protecting the distribution licensee.
2. **Amendment to Clause 33.5 (Beneficiary of RECs for Banked Energy):**
* **New Wording:** A proviso is added stating that the **Renewable Energy Generating Station** (the power plant) will be entitled to RECs for the unutilized banked quantum of energy.
* **Implication:** This shifts the economic benefit of RECs from the consumer to the generator. It aligns state policy with national REC mechanisms and provides a direct incentive to renewable energy producers for their surplus generation.
**4. Expected Outcomes**
* **Regulatory Harmonization:** Ensures Telangana’s open access framework is consistent with the national REC framework, reducing ambiguity and legal challenges.
* **Clarity for Stakeholders:** Provides clear rules for the treatment of energy injected during the interim period and for the ownership of environmental attributes (RECs).
* **Incentive for RE Generators:** By granting RECs to generators, the amendment strengthens the financial viability of renewable energy projects opting for open access, encouraging investment.
* **Procedural Streamlining:** Aligns state procedures (managed by TGSLDC) with national guidelines (NLDC/CERC), facilitating smoother administrative processing.
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