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Open Access In Interstate Transmission system Principal Regulation 2008( 25 th Jan’2008)

Open Access In Interstate Transmission system Principal Regulation 2008( 25 th Jan’2008) Amendment Regulation 2009(20 th May’2009) Order-Removal of difficulties,(28 th June,2011) Order-Amendment to CTU procedure 28 th Oct,2009. H K CHAWLA, DGM NRLDC, POSOCO.

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Open Access In Interstate Transmission system Principal Regulation 2008( 25 th Jan’2008)

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  1. Open Access In Interstate Transmission system Principal Regulation 2008( 25th Jan’2008) Amendment Regulation 2009(20th May’2009) Order-Removal of difficulties,(28th June,2011) Order-Amendment to CTU procedure 28th Oct,2009 H K CHAWLA, DGM NRLDC, POSOCO NRLDC: POSOCO

  2. Transmission System • Electricity is a concurrent subject – central and State Govt. responsible for its development • Pursuant to electricity sector reforms, erstwhile monolithic entities vertically disintegrated into separate cos. Responsible for • Generation, • Transmission and • Distribution • Transmission utilities created at Central and State level • Central Transmission Utility (POWERGRID) – Inter-State transmission system • State Transmission Utility – Intra-State Transmission System

  3. Transmission System • Plays Central Role in supply of electricity • Backbone for electricity market development • Crucial for big country like India – generation resources and loads are scattered • Optimal harnessing of available resources

  4. Evolution of Power Market in India Ancillary Market Transmission Pricing (PoC)2011 PX 2008 Open Access 2004 ABT 2002-03 IEGC Feb.’2000

  5. Significant Feature of Electricity Act, 2003 • Generation has been delicensed and captive generation freely permitted.i.e. Any generating company may establish, operate and maintain a generating station without obtaining a licence under this Act with only exception that it should comply with the technical standards relating to connectivity with the grid. 2. No person shall(a) transmit electricity; or(b) distribute electricity; or(c) undertake trading in electricity,unless he is authorised to do so by a licence issued, exceptions informed by authorised commissions through notifications 3 Open access in transmission with provision for surcharge for taking care of current level of cross subsidy, with the surcharge being gradually phased out.

  6. Significant features…Contud • 4. The state government required to unbundle State Electricity boards. However they may continue with them as distribution licensees and state transmission utilities • 5. Setting up state electricity regulatory commission (SERC) made mandatory • 6. An appellate tribunal to hear appeals against the decision of CERC's and SERC's • 7 Metering of electricity supplied made mandatory • 8 Trading as, a distinct activity recognised with the safeguard of Regulatory commissions being authorised to fix ceiling on trading margins.

  7. DEFINITION OF “OPEN ACCESS” IN THE ELECTRICITY ACT, 2003 (Section 2(47) of Electricity Act 2003) .“Open Access” means the non-discriminatory provision for the use of transmission lines or distribution system or associated facilities with such lines or system by any licensee, or consumer, or a person engaged in generation in accordance with the regulations specified by the Appropriate Commission”. CTU Functions 38(2)(d) STU Functions 39(2)(d) Transmission Licensees duties 40(c) Distribution licensee duties 42(2)

  8. EA Section11 (Directions to generating companies) 11. (1) The Appropriate Government may specify that a generating company shall, in extraordinary circumstances operate and maintain any generating station in accordance with the directions of that Government. • Explanation. - For the purposes of this section, the expression “ extraordinary circumstances” means circumstances arising out of threat to security of the State public order or a natural calamity or such other circumstances arising in the public interest. (2) The Appropriate Commission may offset the adverse financial impact of the directions referred to in sub-section (1) on any generating company in such manner as it considers appropriate

  9. Open Access in Transmission System • Three scenarios arise • Generation already connected to the grid and harnessing margins available in transmission capacity for its optimal utilisation – Short Term Open Access • Existing/New customers seeking transfer on Medium Term Basis – Medium term open access • New generation developer seeking connectivity and power transfer through the grid – Long Term Access

  10. STOA,MTOA and LTA • Salient Features of LTA , MTOA and STOA • STOA – 3 months, • MTOA – 3 Months to 3 Years • LTA – 12 to 25 years • STOA/MTOA utilization of margins in the existing transmission system • LTA is not limited, in case of constraints requisite strengthening is identified and built • LTA customers are provided firm access rights to the grid with higher priority than the MTOA/STOA customers

  11. Short Term Open Access Open Access… Railways • Transmission Users/Customers are offered numerous products to suit requirement • Advanced reservation • First-cum-first served • Day ahead • Contingency

  12. Present Market at a Glance Short Term Open Access Medium TermMarket Long TermMarket Bilateral Transaction Contingency Transaction Collective Transaction Day Ahead Transaction 12-25 Yr 3months -3Years After Clearance of PX 3 month ahead Day Ahead ahead On the day of operation Term ahead Schedules Balancing Market ( UI ) ( Real Time Operation )

  13. LEGAL FRAMEWORK [SECTION-9(2)]Captive Generation • Every person, who has constructed a captive generating plant and maintains and operates such plant, shall have the right to open access for the purposes of carrying electricity from his captive generating plant to the destination of his use • Provided that such open access shall be subject to availability of adequate transmission facility and such availability of transmission facility shall be determined by the Central Transmission Utility or the State Transmission Utility, as the case may be

  14. Electricity Act(Sections 38/39/40/42) CTU / STU/Transmission licensee/Distribution licensee • To provide non-discriminatory open access to its transmission system for use by- (i) any licensee or generating company on payment of the transmission charges; or (ii) any consumer as and when such open access is provided by the State Commission under sub-section (2) of section 42, on payment of the transmission charges and a surcharge thereon, as may be specified by the Central Commission/State Commission. • CTU shall not engage in generation/trading. • STU shall not engage in trading • Transmission Licensee shall not engage in trading

  15. Regulation 2: Definitions • “bilateral transaction” means a transaction for exchange of energy (MWh) between a specified buyer and a specified seller, directly or through a trading licensee or discovered at power exchange through anonymous bidding, from a specified point of injection to a specified point of drawl for a fixed or varying quantum of power (MW) for any time period during a month • “collective transaction” means a set of transactions discovered in power exchange through anonymous, simultaneous competitive bidding by buyers and sellers; • “regional entity” means a person whose Scheduling ,metering and energy accounting is done at the regional level; • “intra-State entity” means a person whose metering and energy accounting is done by the State Load Despatch Centre or by any other authorized State utility;

  16. Regulation 2: Definitions….contd • “short-term customer” means a person who has availed or intends to avail short term open access • “short-term open access” means open access for a period up to one (1)month at one time • Short term access applications allowed up to 3 months in advance considering ATC/TTC issues.

  17. Regulation 2: Definitions….contd • “State network” means network owned by the State Transmission Utility, distribution licensee or any other person granted licence by the State Commission to construct, operate and maintain the transmission system; • “State utility” (means a State Transmission Utility, or )a State Electricity Board,or Electricity Department of the State, or a State Government organization authorized to sell or purchase electricity on behalf of the State; • “time block” means 15 minutes time period specified in the Grid Code for the purposes of scheduling and despatch; and

  18. Draft Notification:Amendment of Regulation 2 of Principal Regulations: (1) A new sub-clause shall be inserted after sub-clause (g) of clause (1) of Regulation 2 of Principal Regulations as under, namely: “(g-a) “Intra-day transaction/contingency transaction” means the transaction which occurs on day (T) after the closure of day ahead transaction window and the delivery of power is on the same day (T) or next day (T+1) and which are scheduled by Regional Load Despatch Centre or National Load Despatch Centre.” (2) The sub-clause (h) of clause 1 of Regulation 2 of the Principal Regulations shall be substituted as under, namely- "(h) “Intra-State entity" means a person whose metering is done by the State Transmission Utility or the distribution licensee as the case may be and the accounting is done by State Load Despatch Centre or any other authorized State Agency. “ .

  19. Regulation 3: Scope • The long-term-customer and the medium-term customer shall have priority over the short-term customer for use of the inter-State transmission system. • The short-term customer shall be eligible for short-term open access over the surplus capacity available on the inter-State transmission system after use by the long-term customer and the medium-term customer, by virtue of • inherent design margins; • margins available due to variation in power flows; and • Margins available due to in-built spare transmission capacity created to cater to future load growth or generation addition.

  20. Regulation 4: Detailed Procedure • Subject to the provisions of these regulations, the Central Transmission Utility, till the Regional Load Despatch Centre is operated by it and thereafter the Government company or any authority or corporation notified by the Central Government under subsection (2) of Section 27 of the Act: shall, after obtaining prior approval of the Commission, issue the detailed procedure to operationalise open access and on any residual matter not covered under these regulations

  21. Regulation 5: Nodal Agency • The nodal agency for bilateral transactions shall be the Regional Load Despatch Centre of the region where point of drawal of electricity is situated and in case of the collective transactions, the nodal agency shall be the National Load Despatch Centre.

  22. CTU PROCEDURES NODAL AGENCY • For Short-Term Customers • RLDC of the Region in which the drawal point is located. • For Long & Medium Term Customers • Central Transmission Utility (CTU), if its system is used • Transmission Licensee/ STU of the region in which the drawl point is located when CTU system is not involved.

  23. Regulation 6: Submission of STOA Application • A short-term customer or the power exchange (on behalf of buyers and sellers) intending to avail of STOA for use of the transmission lines or associated facilities for such lines on the ISTS, shall make an application to the nodal agency • The application for a bilateral transaction shall contain the details, such as • names and location of supplier and buyer, • contracted power (MW) to be scheduled and interface at which it is referred to, • point of injection, • point of drawal, • starting time block and date, • ending time block and date, and • such other information that may be required in the detailed procedure. • The application for a collective transaction shall contain the requisite details in accordance with the detailed procedure.

  24. GENERAL CONDITIONS/APPLICATION SUBMISSION • As per OA regulations Dtd. 25/01/08 w.e.f 01/04/08 & OA Amendment Regulations Dtd. 20/05/09 & as per order-amendment to CTU procedure Dtd.28/10/09 • RLDC will check if connectivity with CTU/ ISTS or STU system (as the case may be) is established, necessary metering is in place, transfer capability upto the CTU network for power flow of the quantum of injection/drawal applied for is available on the date of application and whether the applicant has undertaken to abide by the Central Electricity Authority (Technical Standards for Connectivity to the Grid) Regulations, 2007. • Application to be submitted to:: • Nodal RLDC where point of drawal is situated • & also to all RLDCs involved in the transaction • Application Contents • Details:: Buyer / Seller / Point of injection/ point of drawal / Contracted power at supplier interface/ date/ time period (as per (Format-I-Application for scheduling) alongwith application fee/SLDC concurrance

  25. Regulation 7: Application Fee • An application made for each bilateral transaction or the collective transaction shall be accompanied by a non-refundable fee of Rupees five thousand (` 5000/-)only • Provided that the fee for bilateral transaction on the day of the application or may be deposited within three working days of submission of the application.

  26. Regulation 8: Concurrence of SLDC for bilateral and collective transactions • When a Proposed bilateral transaction has a State utility or an intra-State entity as a buyer or a seller • concurrence of the SLDC shall be obtained in advance and submitted along with the application to the nodal agency in the form as in the detailed procedure. • When a State utility or an intra-State entity proposes to participate in trading through a power exchange, it shall obtain • a “no objection” or a prior standing clearance from the SLDC in the form as in the detailed procedure, specifying the MW up to which the entity may submit a buy or sell bid in a power exchange.

  27. Regulation 8: Concurrence of SLDC for bilateral and collective transactions…..contd 3(a) For obtaining concurrence or ‘no objection’ or prior standing clearance : • Application before the SLDC • SLDC to Acknowledge receipt of the application, either by e-mail or fax, or any other recognised mode ,within twenty four hours from the time of receipt of the application. 3(b) SLDC shall verify the following, namely- • existence of infrastructure necessary for time-block-wise energy metering and accounting in accordance with the provisions of the Grid Code in force, and • availability of surplus transmission capacity in the State network. 3(c) SLDC to convey concurrence/ ‘no objection’ / prior standing clearance • Within three (3) working days if infrastructure exists • Within seven (7) working days for a first time STOA Customer • Deficiency within two (2) working days for a defective/incomplete application

  28. Regulation 8: Concurrence of SLDC for bilateral and collective transactions…..contd • In case of SLDCs refusal ( When Application is in order but necessary infrastructure or surplus transmission capacity is not there.) • To be communicated, within the period of three (3) working days or seven (7) working days(First Time) • Reasons for such refusal: In case of no Communication by SLDC • Concurrence shall be deemed to have been granted: In case of deemed Concurrence grant by SLDC • the applicant while making application shall submit to the nodal agency an affidavit (in the format provided in the detailed procedure), duly notarised, declaring that – • (a) the SLDC has failed to convey any deficiency or defect in the application or its refusal or concurrence or ‘no objection’ or prior standing clearance

  29. Regulation 8: Concurrence of SLDC for bilateral and collective transactions…..contd • (b) necessary infrastructure for time-block-wise energy metering and accounting in accordance with the provisions of the Grid Code in force, is in place; and enclosing with the affidavit – • (i) a copy of the complete application after removal of deficiency or rectification of defects, if any communicated, made to the SLDC for seeking concurrence or ‘no objection’ or prior standing clearance, as the case may be, and • (ii) a copy of the acknowledgement, if any, given by the SLDC, or any other evidence in support of delivery of the application.

  30. Draft Notification: Amendment of Regulation 8 of the Principal Regulations: (1) Clause (2) of Regulation 8 of the Principal Regulations shall be substituted as under, namely: “(2) When a State utility or an intra-State entity proposes to participate in trading through power exchange(s), it shall obtain No Objection or Prior Standing Clearance from the concerned State Load Despatch Centre in such form as may be prescribed in the Detailed Procedure, specifying the aggregate MW up to which the State utility or intra- State entity may submit buy or sell bid(s) in the power exchange(s) taken together.” (2) A new clause shall be inserted after clause (2) of Regulation 8 of Principal Regulations as under, namely: “(2A) No Objection or Prior Standing Clearance obtained by the State utility or intra-State entity from the State Load Despatch Centre can be used for collective transaction for day ahead on Power Exchange and/or for bilateral intra-day transaction/contingency transaction in OTC market or on the Power Exchange market.

  31. Provided further that while making application to SLDC for obtaining No Objection or Prior Standing Clearance for collective transactions for day ahead or for bilateral intra-day transaction/contingency transaction, the applicant shall certify that he agrees to ensure that aggregate quantum in each time block of 15 minutes for all the bid(s) in collective transactions ( day ahead contracts on Power Exchange(s)) and/or for intra-day / contingency transactions (in OTC market and/or Power Exchange Market) shall not exceed the quantum for which No Objection or Prior Standing Clearance has been granted.” (3) Two provisos shall be added after the first proviso to sub-clause (a) of clause (3) of Regulation 8 of the Principal Regulations as under, namely: “Provided further that while making application to the SLDC for obtaining Concurrence for bilateral transactions (except for intra-day transaction/contingency transactions), an affidavit in the format prescribed in the Detailed Procedure, duly notarized, shall be submitted, along with the application, declaring that: (i) There is a valid contract with the concerned persons for the sale of the power under the proposed transaction for which concurrence is applied and; (ii) There is no other contract for sale of the same power as mentioned in (i) above.”

  32. Provided further that while making application to the SLDC for obtaining no objection or prior standing clearance incase of collective transactions, the affidavit shall include the declaration (i) There is no other contract for sale of the same power for which no objection or prior standing clearance s applied. (4) The following proviso shall be added at the end of sub-clause (b) of clause (3) of Regulation 8 of the Principal Regulations, namely: “Provided that in case of application for obtaining concurrence for bilateral transactions (except for intraday transaction/contingency transaction), the State Load Despatch Centre shall also consider the affidavit submitted regarding existence of valid contract for the transaction as per last proviso to sub-clause (a) of clause (3) of this regulation.” (5) Sub-clause (c) of clause (3) of Regulation 8 of the Principal Regulation (excluding the proviso) shall be substituted as under, namely: “Where existence of necessary infrastructure, availability of surplus transmission capacity in the State network and submission of existence of valid contract as per second proviso to sub-clause (a) of clause (3) of this regulation has been established, the State Load Despatch Centre shall convey its concurrence or ‘no objection’ or prior standing clearance, as the case may be, to the applicant by e-mail or fax, in addition to any other usually recognised mode of communication, within three (3) working days of receipt of the application:”

  33. (6) In clause (4) of Regulation 8 of Principal Regulations, the following shall be added after the words "unavailability of surplus transmission capacity in the State network", namely, "or non-submission of the affidavit in accordance with second proviso to sub-clause (a) of clause (3) of this regulation". (7) Second Proviso to clause (4) of Regulation 8 of Principal Regulations shall be substituted and two new provisos shall be added after the second proviso as under, namely: “Provided further that where concurrence or ‘no objection’ or prior standing clearance, as the case may be, is deemed to have been granted by the State Load Despatch Centre, the applicant such as the State utility or the intra-State entity or short term customer as the case may be, shall submit to the nodal agency (concerned Regional Load Despatch Centre) in case of bilateral transactions and the power exchange in case of collective transactions for day ahead or for bilateral intra-day transaction/contingency transaction through power exchange, the following on affidavit in the format provided in the detailed procedure at least three days in advance: (a) Declaring that the State Load Despatch Centre has failed to convey any deficiency or defect in the application or its refusal or concurrence or ‘no objection’ or 'prior standing clearance', as the case may be, within the specified time,

  34. (b) Declaring that necessary infrastructure for time-block-wise energy metering and accounting in accordance with the provisions of the Grid Code in force, is in place; and (c) enclosing the following documents – (i) a copy of the complete application made to the State Load Despatch Centre for seeking 'concurrence' or ‘no objection’ or 'prior standing clearance', as the case may be 6 (ii) Deficiency or defect in the application, if any, communicated by the State Load Despatch Centre and the action taken to remove or rectify the defect or deficiency; and (iii) a copy of the acknowledgement, if any, given by the State Load Despatch Centre, or any other evidence in support of delivery of the application to the State Load Despatch Centre. Provided further that the Power Exchange shall forward the copy of the affidavit alongwith the documents received from the State utility or the intra- State entity or short term customer as the case may be, to the nodal agency (National Load Despatch Centre) at least two days before the delivery: Provided further that the concerned Regional Load Despatch Centre in case of bilateral transactions and concerned power exchange in case of collective transaction for day ahead or for bilateral intra-day transaction/contingency transaction through power exchange shall forward the copy of the affidavit alongwith the documents to the concerned SLDC on the same day it is received.”

  35. SUBMISSION OF APPLICATION RLDC concurrance - Bilateral Transaction having a State Utility or an intra-state Entity as a Buyer/Seller in other region:: concurrence of the concerned Regional Load Despatch Centre(s). - Nodal applications to be considered first before giving other concurrance - Reasons for refusal

  36. CTU PROCEDURES Entities which are making Application for the first time must submit the “One- Time” information as per enclosed format (FORMAT-VIII: “Registration Form) to the concerned nodal RLDC. Application - through online Any amendment/modification fresh Application Applications not accorded the Acceptance: stand disposed off with suitable intimation to the concerned Applicant(s) All costs/expenses/charges associated with the Application, including Bank Draft, shall be borne by the Applicant. Incomplete / vague Application summarily rejected No charges payable for a transaction shall be adjusted by against any other payments/charges. The Applicant shall abide by the provisions of The Electricity Act, 2003, Indian Electricity Grid Code and CERC Regulations, as amended from time to time Applicant shall keep each of the SLDCs/ RLDCs indemnified GENERAL CONDITIONS

  37. Categories & Time Line For Open Access M0 M1 M2 M3 DOP DL-10 DL-5 DL DL+5 DOP-4 Adv Application for M1 DOP-1 FCFS CONTINGENCY Adv Application for M2, Approvals for M1 Adv Application for M3, Approvals for M2 Approvals for M3 Day Ahead / PX LEGEND: DOP : Day of Operation DL : Last day of M0

  38. Regulation 9: Procedure for Advance Scheduling for bilateral transactions

  39. ADVANCE SCHEDULING • Advance Scheduling – 3 months in advance • Separate Application – • Month wise - each transaction • Time Line for submission • Last date for submission ( -10 / -5 / 0 days prior to end of current month MO – for transaction in M1, M2, M3) • Cut-off time of application: 17:30 Hrs. of last day (Day 0) • Request for concurrence (RLDC) – by 12:00 Hrs.(Day 1) (Format- III) • Concurrence - by 20:00 Hrs(Day 1) • Congestion Information to Applicant – 12:00 Hrs(Day 2)-Format-IV(Congestion information-Advance scheduling) • Revised Request/re-routing – 11:00 HRs.(Day3)-Format-V-Request for revision due to congestion) • E-bidding – in case of Congestion (Day 4) • Acceptance/Refusal of Scheduling Request – (Day5)-Format-VI-Acceptance for scheduling

  40. Regulation 10 Congestion Management : e- Bidding Procedure • Invitation of Bids from the concerned applicant • period of congestion • RTS/IR corridor expected to get over stressed • Only Registered Users • User ID & Password • Electronic submission • Bid Closing time as specified • Single Price Bid • No Modification/withdrawal once submitted • Bid Price • – In addition to Open Access Transmission charges - Multiples of Rs. 10/ MWh . ( Min. Rs. 10/MWh) • Mandatory - Non-participation (Deemed to withdrawl of Application) • Acceptance - Decreasing order of Price Quoted • Equal Price Bids – Pro-rata • Applicant getting approval < request  Charges as quoted • Applicant getting approval=request  Charges as paid by last applicant getting approval = request

  41. E Bidding in NRLDC • 1 During processing of  Advance applications in August 2009, Congestion was observed in WR-NR Corridor in all the 96 time blocks for all the    days of Sept-2009.2  Total no of applications were  15(BRPL-1,Lanco- 1,NVVN-3, PTC-1,TATA- 7 and Venergy-1,Mittal processor-1). The Max margin available was 17 MW and min 1 MW.3 On 23.08.2009 ,NRLDC intimated to all the applicants about the congestion, mentioning the total applied quantum and available margin.4 After seeing the margin, all the applicants except NVVNL and BRPL revised their applied quantum  as Nil.5 For NVVNL and BRPL, E-bidding was carried out at 17.00hrs of 24.08.2009.. 6  NVVNL & BRPL  bidded  their transmission charges as Rs10/MWh & Rs 270/MWh respectively (Above Rs 80/MWh).7   In E-bidding an amount of Rs 1435590/( 5317 MWh quantum @ Rs 270/MWh) was collected from BRPL &  was further disbursed to CTU.

  42. Regulation 11,12,&13 Procedure for FCFS, Day ahead & Contingency bilateral transactions

  43. “FIRST-COME-FIRST-SERVED”(FCFS) • Scope • FCFS shall be considered only when transactions are commencing & terminating in the same calender month. • Separate Application for each month • To be submitted 4 days prior to date of Scheduling • Processing time – 3 days on FCFS basis • Applications received during last 10 -5 days of month of M0 for M1 would be considered only after complete processing of Advance transactions for M1 • Application Received up to 1730 hrs in a day to be processed together – same priority • Application Received after 17:30 Hrs. - to be considered as received next day • Congestion Management – pro-rata

  44. Regulation 12: DAY-AHEAD • Applications received within 3 days prior to the day of Scheduling and up to 15:00 Hrs. of the day immediately preceding the day of scheduling shall be treated as same priority • Processing only after processing of the Collective Transactions of the Power Exchange (s) • Congestion Management – Pro-rata

  45. Regulation 13: CONTINGENCY • Buying Utility/Trader on its behalf to make an Application to the Nodal RLDC • To be considered after 1500 hrs of the day immediately preceding the day of scheduling.All applications received up to 18.00 Hrs shall be clubed together. • In case of intra-day/same day – scheduling from 6th time block • Congestion Management – Pro-rata

  46. Regulation 14: Revision of Schedule • Only in case of “Advance Scheduling” or “First-Cum-First Served basis” • Accepted schedule for Day-Ahead ,Contingency & Advance transactions shall be revised or cancelled once in case of tripping of generators > 100MW as per Cl.6.5.19 of IEGC. • Revision w.e.f 4th time block of intimation to RLDC • Generator to furnish expected restoration time from which original schedules would become effective. • For period of revision/cancellation upto two days:: Original transmission/operating charges • For period of revision/cancellation > two days:: Transmission Charges and Operating Charges for the period beyond two (2) days shall be payable as per the revised accepted schedule and for the first two (2) days as per the original schedule. • Margin Available – released for scheduling of eligible Open Access Transactions

  47. EXAMPLE OF DOWNWARD REVISION

  48. Regulation 15: CURTAILMENT IN CASE OF TRANSMISSION CONSTRAINTS • Transmission constraint or to maintain grid security • Curtailed in the manner, which in the opinion of RLDC, would relieve transmission constraints/ enhance grid security • Curtailment priority :: STOA(bilat)Collective(PX)MTOALTA • In case of reallocation of GOI share leading to corridor constraints • Rerouting allowed without curtailment of existing transactions • Pro-rata refund of Transmission Charges • No revision of operating charges

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