Solar Roof-top generation project: Consequences on aggressiv

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shineseb
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Solar Roof-top generation project: Consequences on aggressiv

Post by shineseb »

KSEBEA/Generation/Solar/2018/ 17.11.2018
To
The Chairman & Managing Director
KSEB Limited.

Sir,

Sub: Solar Roof-top generation project: Consequences on aggressive penetration of solar in the grid and direct investment by KSEBL in the roof top Solar project: follow up action- reg.
Ref: 1. Our Letter dated 08/08/2018 on the subject matter to that office.
2. Study report on “Solar integration and management of generation resources in
Kerala Grid” by Er C. P. George, Vice President, KSEBEA & Deputy Chief
Engineer, KSEBL.

Considering the consequences of the solar integration in Kerala Grid, as brought out in the study report cited under reference-2, we have requested KSEBL as per ref-1 to refrain from the direct investment in solar projects based on following facts :
● With the present available generation resources we have around 224 Million Units of excess electricity per annum during the day time.
● With the additional 500MW roof top Solar during the day time, the excess shall increase to 954MU per annum and with 1000MW, the excess shall be 1684 MU.
● The availability of excess solar from roof top shall end up in surrendering the cheaper power from available from Central generating stations to maintain the “Load Generation Balance” and will result in huge financial loss to KSEBL, in addition to the complexities of system operation
We may point out that, citing the requirement of meeting of the ‘Renewable energy Purchase Obligation’ (RPO) with respect to the solar component as the prime reason for advocating the direct investment of KSEBL in the solar project is baseless and misleading. The real data on RPO requirement shall expose the irrelevance of this argument and the integrity of the individuals aggressively promoting the investment by KSEBL in the project.

The table below, which is based on Hon. KSERC’s (Renewable Energy) Amendment
Regulations, 2017, provides some insight into the actual requirement of ‘Solar RPO’ for KSEBL.

Financial year Consumption
(excluding hydro power) Solar RPO Requirement of Solar Capacity in MW for the RPO energy
% of total consumption (excluding hydro) MU
2018-19 13833 2.75 380 261

As per the KSERC’s (Renewable Energy) Amendment Regulations, 2017, Solar energy during 2018-19 is estimated as 380 MU. Based on the average energy production from the solar plant in Kerala, the estimated requirement of solar capacity for generation of 380MU is 261 MW only. As per the data available in KSEBL official website, we have 118MW of Solar available with us as of now in Kerala and various projects upto 21MW is nearing completion. In addition, 70 MW floating solar by NTPC Kayamkulam and 50 MW floating solar by NHPC along with the grid connected solar roof top from individual consumers are getting integrated to the system in a big way. Accordingly, we will have more than 261 MW of solar plants in the State during this financial year.
Another important aspect is the introduction of “renewable generation obligation” and mandatory requirement of bundled purchase of renewable energy for the future purchases of electricity from coal and lignite sources. Moreover, tariff policy recommends bundled sale of renewable energy even by the existing coal and lignite generators by setting up additional renewable generation plants. Solar REC (Renewable Energy Certificate) is one of the best options to comply the RPO requirement and it is abundantly available for Re.1/- per unit. As per the KSERC’s (Renewable Energy) Amendment Regulations, 2017; the net levelized tariff for Solar PV is Rs.5.08 per unit in Kerala. With electricity available in the market at much cheaper rate during the off - peak hours, the best option is direct purchase of solar from short term market or the RPO requirement REC (Renewable Energy Certificate) route. In short, we may point out that, there is absolute clarity in evaluating the adverse consequences in the policy of direct investment by KSEBL in the roof top solar generating plants.
Despite the adverse consequences predicted by the evaluation, aggressive campaign for the solar project named “Soura” is under way through KSEBL official website and various media in the name of KSEBL. It is observed that the options are meant for the direct investment in solar roof top and campaign is also for the same. Moreover KSEBL staff, KSEBL infrastructure and KSEBL establishment are widely used to promote the project without proper authorization and clarity.
KSEBL is now functioning as three independent Strategic Business Units (SBU) namely SBU-Generation, (SBU-G), SBU –Transmission(SBU-T) and SBU- Distribution(SBU-D) and have to function strictly in accordance with the provisions of the relevant rules framed by the Central and the State Governments, the regulations framed by the Central and State Electricity Regulatory Commissions and the mandatory standards framed by Central Electricity Authority. Hence the infrastructure, establishment and the staff need to be used and accounted for the exclusive business envisaged. Any exchange of assets, HR, finance, infrastructure and material need to be accounted appropriately to ensure transparency and accountability. We have not come across a system and establishment that is devised for implementing the solar project based on a legitimate order. It is also observed that KSEBL infrastructure and establishment are illegally used for promoting the project and the relevant expense is not accounted separately. Moreover, as we have already pointed out, the project in its present form is not in the best interests of KSEBL and disruptive in performing the original goals envisaged by various provisions in the Electricity Act and its subordinate regulations.
In view of the above, we request that
1. The proposed “Soura” project may be segregated from the functions and activities of KSEBL.
2. Illegal use of KSEBL infrastructure, establishment, staff and facilities for the project may be ordered to be stopped immediately.
3. The involvement of KSEBL staff with the project shall be allowed only on deputation basis.
4. All such activities in the field offices in connection with the “Soura” project may be ordered to be stopped forthwith and KSEBL activity may be limited to the grid connectivity as envisaged by the KSERC regulations.

Yours Sincerely,


General Secretary


Copy submitted to:
1. The Chief Secretary, Government of Kerala. (chiefsecy@kerala.gov.in)
2. The Principal Secretary, Finance, Government of Kerala (prlsecy.fin@kerala.gov.in)
3. The Principal Secretary, Power, Government of Kerala. (prlsecy.pwr@kerala.gov.in)
4. The Secretary, Kerala State Electricity Regulatory Commission, Thiruvananthapuram (kserc@erckerala.org)
george.prothasis
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Re: Solar Roof-top generation project: Consequences on aggre

Post by george.prothasis »

Solar has become a mode of propaganda for misusing the KSEBL assets, establishment and infrastructure for other business. KSEBL is envisaged to do any capital investment or other business with out encroaching the envisaged function of KSEBL. There need to be clear demarcation of accounts and utilisation of staff when the organisation intent to do ang business other than those envisaged by. It.
But it is observed that the distribution establishment , the facilities and the staff are aggressively used and engaged in canvassing and spreading the projects which shall be detrimental to the performance of the organization in future.

Aggressive penetration of solar shall risk the financial stability of the organization by ending up at excess generation during day time which shall lead to surrendering of cheaper power from central generating station.
The intermittency and unpredictability of the solar shall. Lead to grid operational issues and economical operation of the grid shail be at risk. More over higher penetration of solar is feasible only with smart grid technology or face the risk of freequent grid collapse.

More over we have enough solar availabe in the market at the rate of Rs.3/- per unit, why should KSEBL invest for solar generation that cost Rs.5.10/-grid parity in Kerala as per KSERC.

Just an evaluation of the existing solar projects done by KSEBL will provide us with the per unit cost involved in solar generation by KSEBL.

More over the infrastructure costs
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