CENTRAL ELECTRICITY REGULATORY COMMISSION

NEW DELHI

Petition No. 200/MP/2019

Coram:

Shri P.K. Pujari, Chairperson

Shri Arun Goyal, Member
Shri P. K. Singh, Member

Date of Order: 26th November, 2021

In the matter of:

Petition under Section 38(2) of the of the Electricity Act, 2003 read with Section
79(1)(c) and Section 79(1)(k) of the Act, along with (i) Central Electricity Regulatory
Commission (Grant of Regulatory Approval for execution of Inter-State Transmission
Scheme to Central Transmission Utility) Regulations, 2010; (ii) Regulation 111 & 114
of the Central Electricity Regulatory Commission (Conduct of Business) Regulations,
1999 and (iii) Central Electricity Regulatory Commission (Sharing of Inter-State
Transmission Charges and Losses) Regulations, 2010 for execution of the
Transmission System for 18.5 GW of Solar and Wind Energy Zones in Southern
Region.

And

In the matter of

Power Grid Corporation of India Limited,

Registered office: B-9, Qutab Institutional Area,
Katwaria Sarai, New Delhi.
and
Corporate office: Saudamini, Plot No. 2, Sector-29,
Gurgaon (Haryana) - 122 001.
..….Petitioner

Vs

1. Tamil Nadu Generation and Distribution Corporation Ltd,

(Represented by its Chairman)
NPKRR Maaligai, 800, Anna Salai,
Chennai – 600 002.
2. Transmission Corporation of Andhra Pradesh Limited (APTRANSCO),
(Represented by its Chairman)
Vidyut Soudha,
Hyderabad– 500082.

Order in Petition No. 200/MP/2019 Page 1

3. Kerala State Electricity Board Limited (KSEB),
(Represented by its Chairman)
Vaidyuthi Bhavanam, Pattom,
Thiruvananthapuram – 695 004.

4. Karnataka Power Transmission Corporation Limited (KPTCL),

(Represented by its Chairman)
Kaveri Bhavan,
Bangalore – 560 009.

5. Electricity Department,
Government of Goa,
(Represented by Chief Engineer (Electrical))
Vidyuti Bhawan,
Panaji, Goa 403001.

6. Electricity Department
Government of Pondicherry,
(Represented by its Chief Secretary)
Pondicherry – 605001.

7. Eastern Power Distribution Company of Andhra Pradesh Limited (APEPDCL),

(Represented by its Managing Director)
P&T Colony, Seethmmadhara,
Vishakhapatnam, Andhra Pradesh.

8. Southern Power Distribution Company of Andhra Pradesh Limited (APSPDCL),

(Represented by its Managing Director)
Srinivasasa Kalyana Mandapam Backside,
Tiruchanoor Road, Kesavayana Gunta,
TIRUPATI-517 501, Chittoor District, Andhra Pradesh.

9. Central Power Distribution Company of Andhra Pradesh limited (APCPDCL),

(Represented by Its Managing Director)
Corporate Office, Mint Compound,
Hyderabad – 500 063, Andhra Pradesh.

10. Northern Power Distribution Company of Andhra Pradesh Limited (APNPDCL),

(Represented by Its Managing Director)
Opposite NIT Petrol Pump,
Chaitanyapuri, Kazipet, Warangal- 506 004, Andhra Pradesh.

Order in Petition No. 200/MP/2019 Page 2

11. Bangalore Electricity Supply Company Limited (BESCOM),
(Represented by its Managing Director)
Corporate Office, K.R.Circle,
Bangalore – 560 001, Karnataka.

12. Gulbarga Electricity Supply Company Limited (GESCOM),

(Represented by its Managing Director)
Station Main Road, Gulburga,
Karnataka.

13. Hubli Electricity Supply Company Limited (HESCOM),

(Represented by Its Managing Director)
Navanagar, PB Road,
Hubli, Karnataka

14. MESCOM Corporate Office,

(Represented by Its Managing Director)
Paradigm Plaza, AB Shetty Circle,
Mangalore – 575 001, Karnataka.

15. Chamundeswari Electricity Supply Corporation Limited (CESC),

(Represented by Its Managing Director)
# 927, L J Avenue, Ground Floor,
New Kantharaj Urs Road,
Saraswatipuram,
Mysore – 570 009, Karnataka.

16. Transmission Corporation of Telangana Limited,

(Represented by Its Managing Director)
Vidhyut Sudha, Khairatabad,
Hyderabad - 500082.

17. Tamil Nadu Transmission Corporation,

(Represented by its Chairman)
NPKRR Maaligai, 800, Anna Salai
Chennai – 600 002.

18. Solar Energy Corporation of India Limited

(Represented by its Chairman)
D-3, A Wing, 1st Floor, Religare Building, District Centre, Saket,
New Delhi – 110017.
…..Respondents

Order in Petition No. 200/MP/2019 Page 3

Parties present:
Shri M. G. Ramachandran, Sr. Advocate, PGCIL and SECI
Ms. Tanya Sareen, Advocate, SECI
Shri Ravi Nair, Advocate, SECI
Shri S. Vallinayagam, Advocate, TANGEDCO and AP Discoms
Ms. Stephania Pinto, Advocate, BESCOM, HESCOM, KPTCL
Shri Shahbaaz Husain, Advocate, BESCOM, HESCOM, KPTCL
Shri Anil Kr Meena, CTUIL
Shri Ankush Patel, CTUIL
Shri Swapnil Verma, CTUIL
Shri Subir Sen, CTUIL
Shri Shreedhar Singh, SECI
Shri Kaustav Roy, SECI
Shri R. K. Aggarwal, SECI
Ms. R. Ramalakshmi, TANGEDCO
Shri R. Srinivasan, TANGEDCO
Dr. R. Kathiravan, TANGEDCO

ORDER

The present Petition has been filed by the Petitioner, Power Grid Corporation

of India Limited (PGCIL) under Section 38(2) of the Electricity Act, 2003 (hereinafter

referred to as the “2003 Act”) read with Section 79(1)(c) and 79(1)(k) of the 2003 Act

for grant of Regulatory approval for execution of the transmission system for 18.5

GW of Solar and Wind Energy Zones in Southern Region (SR). Subsequent to filing

of this petition, Central Transmission Utility of India Limited (CTUIL) has become a

separate entity that has been carved out of PGCIL and is the Central Transmission

Utility in terms of the 2003 Act. Therefore, the Petition is treated as having been filed

by CTUIL. The Petitioner has made the following prayers:

“(a) Grant Regulatory approval for taking up implementation of identified transmission

system at Enclosure - VII.
(b) Grant of approval for recovery of transmission charges of the assets through CERC
(Sharing of Transmission charges and losses for ISTS) Regulations, 2010 and its
amendment(s) notified by CERC from time to time.
(c) Grant of approval for inclusion of the above system under the TSA notified by
CERC”

Order in Petition No. 200/MP/2019 Page 4

Submission of the Petitioner

2. The Petitioner has mainly submitted as under:

a) The Government of India has set a target of establishing 175 GW of

renewable energy (RE) capacity by 2022, which includes 100 GW solar and 60
GW wind capacity. Ministry of New and Renewable Energy (MNRE) vide its
order dated 8.6.2018 had constituted a sub-committee to identify ISTS
connectivity for renewable energy projects from the potential Solar Energy
Zones (SEZs) and potential Wind Energy Zones (WEZs) of about 50 GW and
16.5 GW respectively. SEZs and WEZs envisaged in seven RE-rich States,
namely, Tamil Nadu, Andhra Pradesh, Karnataka, Gujarat, Rajasthan,
Maharashtra and Madhya Pradesh were identified by Solar Energy Corporation
of India (SECI) in association with MNRE and in consultation with RE power
developers.

b) In respect of 66.5 GW solar and wind generation potential, region-wise

transmission system for evacuation of power from solar and wind power
projects has been planned as under:
Sr. No. Region RE Capacity (GW)
Phase - I Phase - II Total
1. Northern Region 8.9 11.1 20
2. Western Region 10.5 17.5 28
3. Southern Region 10 8.5 18.5
Total 29.4 37.1 66.5

c) Out of 66.5 GW potential, 18.5 GW is envisaged to be developed in

Southern Region, which includes 10 GW of solar generation and 8.5 GW of
wind generation, both in Phase-I and Phase-II. The details of SEZs and WEZs
along with phasing as per transmission system planning is as under:

Order in Petition No. 200/MP/2019 Page 5

 State/ District Solar Wind Total
(GW)
Phase-1 Phase-2 Phase-1 Phase-2
(GW) (GW) (GW) (GW)
2020 2021 2020 2021
Andhra Pradesh
Kurnool 2.5 2 1 5.5
Ananthpuram 2.5 2.5
Karnataka
Koppal 2.5 2.5
Gadag 2.5 2.5
Bidar 2.5 2.5
Tamil Nadu
Karur 1.5 1 2.5
Tirunelveli 0.5 0.5
Total 2.5 7.5 6 2.5 18.5

d) Out of the 18.5 GW identified SEZs and WEZs, transmission system

for evacuation of 8.5 GW of power from Phase-I and Phase-II Wind Energy
Zone in Southern Region and additional 1.5 GW of Phase-I of Solar Energy
Zone in Kurnool area totalling Renewable Energy Zone of 10 GW (as part-A
Transmission Schemes) and 8.5 GW of SEZ in Karnataka and Andhra Pradesh
(as part-B Transmission Schemes) were agreed in the 1st and 2nd SRSCT
(Southern Region Standing Committee on Transmission) meetings held on
07.09.2018 and 10.06.2019, respectively. It was also decided in the said
meetings of SRSCT that the schemes would be taken-up for implementation as
ISTS consequent to grant of LTA by the Petitioner.
e) The proposed Transmission System includes following elements:

Part - A:

1. Tirunelveli and Tuticorin Wind Energy Zone (Tamil Nadu) (500MW):

(i) Addition of 1x500 MVA, 400/230kV ICTs (4th) at Tuticorin-II GIS sub-
station.

**Operation of Tuticorin Pooling Station – Dharmapuri (Salem) 765kV D/C line

(presently operating at 400kV) at its rated voltage. (i.e. 765kV) & 5th ICT (500
MVA) at Tuticorin-II PS would be reviewed for dispersal of more than
2000MW RE generation

Order in Petition No. 200/MP/2019 Page 6

2. Karur / Tiruppur Wind Energy Zone (Tamil Nadu) (2500MW):
(i) Establishment of 5x500 MVA, 400/230 kV Karur Pooling Station (at a
location in between Karur Wind zone and Tiruppur wind zone)
(ii) LILO of both circuits of Pugalur – Pugalur (HVDC) 400 kV D/c line (with
Quad Moose ACSR Conductor) at Karur PS
(iii) 9 Nos. of 230 kV line bays for interconnection of wind projects
(iv) 2x125 MVAr, 400 kV Bus reactors at Karur PS

3. Koppal Wind Energy Zone (Karnataka) (2500MW):

(i) Establishment of 5x500 MVA, 400/220 kV pooling station near Munirabad
/suitable location in Koppal distt.
(ii) Pooling station (near Munirabad /suitable location in Koppal distt.) -
Narendra (New) 400 kV D/c Line (with Quad Moose ACSR conductor)
(iii) 9 Nos of 220kV line bays for interconnection of wind projects
(iv) 2x125 MVAr, 400kV bus reactor at Pooling station (near Munirabad
/suitable location in Koppal distt.)
(v) Adequate space provision for future expansion

4. Kurnool(AP) WEZ (3000MW) and SEZ (1500MW) :

(i) Establishment of 3x1500 MVA, 765/400 KV and 9x500 MVA 400/220kV
Pooling station at suitable location in Kurnool Distt. (Kurnool-III)
(ii) Kurnool-III Pooling station - Kurnool(new) 765 kV D/c Line
(iii) Kurnool-III PS - Maheshwaram(PG) 765 kV D/c Line
(iv) 220 kV line bays for interconnection of wind projects (15 nos)
(v) 1x330 MVAr (765kV) & 1x125MVAr (400kV) bus reactor at Kurnool-III PS
(vi) 240 MVAr Switchable line reactors at both ends of Kurnool-III PS –
Maheshwaram (PG) 765 kV D/c Line

Part B :

1. Transmission scheme for SEZ in Andhra Pradesh (3500 MW)

a) Ananthapur and Kurnool SEZ (Ananthapur-2500 MW & Kurnool-1000
MW)
(i) Establishment of 7x500 MVA, 400/220 kV Ananthpur pooling station at
suitable border location between Anantapur & Kurnool Distt
(ii) Ananthpur PS - Kurnool-III PS 400 kV (High capacity equivalent to quad
moose) D/c Line
(iii) Anantapur PS - Cuddapah 400 kV (High capacity equivalent to quad
moose) D/c Line with suitable line reactors
(iv) 220 kV line bays for interconnection of wind/solar projects (12 nos)
(v) 2x125 MVAr (400kV) bus reactor at Anantapur PS

2. Transmission Scheme for Solar Energy Zone in Karnataka (5000 MW)

a) Gadag SEZ (2500 MW)
(i) Establishment of 5x500 MVA, 400/220 kV Gadag Pooling Station
(ii) Gadag PS - Koppal PS 400 kV (high capacity equivalent to quad moose)
D/C Line
(iii) Gadag PS - Narendra (new) PS 400 kV (high capacity equivalent to quad
moose) D/C Line
(iv) 220 kV line bays for interconnection of solar projects (8 nos)
(v) 1x125MVAr (400 kV) bus reactor at Gadag PS
(vi) Upgradation of Narendra New to its rated voltage of 765kV level
alongwith 2x1500 MVA, 765/400kV ICTs and 1x330 MVAr Bus Reactor

Order in Petition No. 200/MP/2019 Page 7

 (vii) Upgradation of Kolhapur (PG) to its rated voltage of 765kV level
alongwith 2x1500 MVA transformer and 1x330 MVAr Bus Reactor
(viii) Upgradation/charging of Narendra new - Kolhapur (PG) 765 kV D/c line
(initially charged at 400 kV) to its rated voltage of 765 kV along with 1x330
MVAr switchable Line Reactor on Kolhapur (PG) end of each circuit

b) Bidar SEZ (2500 MW)

(i) Establishment of 3x1500 MVA, 765/400 kV and 5x500 MVA, 400/220 kV
pooling station at suitable border location near Bidar.
(ii) Bidar PS – Maheshwaram (PG) 765 kV D/C line along with 1x240 MVAr
switchable Line Reactor on Bidar PS end of each circuit.
(iii) 220 kV line bays for interconnection of solar projects (8 nos).
(iv) 1x240 MVAr (765kV) & 1x125 MVAr (400 kV) bus reactor at Bidar PS.

3. Common Transmission System Strengthening in Southern Region for

export of power from Solar & Wind Energy Zone in Southern Region
(i) Upgradation of Tuticorin PS to its rated voltage of 765kV level alongwith
2x1500 MVA, 765/400kV ICTs and 1x330 MVAr Bus Reactor
(ii) Upgradation of Dharmapuri (Salem New) to its rated voltage of 765kV
level alongwith 2x1500 MVA, 765/400kV ICTs and 1x240 MVAr Bus Reactor
(iii) Upgradation of Madhugiri (Tumkur) to its rated voltage of 765kV level
alongwith 2x1500 MVA, 765/400kV ICTs and 1x240 MVAr Bus Reactor
(iv) Upgradation/charging of Tuticorin PS - Dharmapuri (Salem New) 765 kV
D/c line (initially charged at 400 kV) to its rated voltage of 765 kV along with
1x330 MVAr switchable Line Reactor on both end of each circuit.
(v) Upgradation/charging of Dharmapuri (Salem New) - Madhugiri (Tumkur)
765 kV 2xS/c line (initially charged at 400 kV) to its rated voltage of 765 kV
along with 1x330 MVAr switchable Line Reactor on Dharampuri (Salem New)
end of both ckts.
(vi) Upgradation/charging of Madhugiri (Tumkur) - Narendra New 765 kV D/c
line (initially charged at 400 kV) to its rated voltage of 765 kV along with
1x330 MVAr switchable Line Reactor on both end of each circuit.
(vii) Conversion of 400 kV Line Reactors installed on 765 kV circuits/ lines
(initially charged at 400 kV) mentioned at Sl No. vi, vii, viii and ix into 400 kV
bus Reactor with suitable arrangements at respective substations.

f) It was also discussed in the said meetings of SRSCT that

transformation capacity at various stations and certain elements would be
reviewed based on applications for LTA. The transmission system as agreed in
the meetings of SRSCT would serve as broad master plan for integration of RE
generation in Tamil Nadu, Karnataka and Andhra Pradesh for a period up to
2021-22 and their implementation would be undertaken in stages. Considering
the large scale capacity additions from RE sources in Southern States,
completion of generation projects from conventional sources by 2021-22 and
the likely electricity demand in the year 2021-22, the load generation balance
for Southern Region was prepared collectively by the constituents for the year
2021-22 in the joint study meeting held on 01/02 of May, 2019 at SRPC,

Order in Petition No. 200/MP/2019 Page 8

Bengaluru along with CEA, SRPC, CTU & POSOCO.

g) As per the Central Electricity Regulatory Commission (Terms and

Conditions for Tariff determination from Renewable Energy Sources)
Regulations, 2017, minimum 22% Capacity Utilization Factor (CUF) for wind
farms and 19% CUF for Solar PV projects is required to be considered.
Accordingly, the RPO obligations shall be met by States / Union Territories from
RE generation including ISTS connected RE generation by 2021-22.

h) Further, from the load-generation sheet, it is observed that during the

evening peak load conditions, Southern region may have deficit conditions and
require import of power of about 6800 MW from NEW grid. Accordingly, the
transmission system within Southern region and the inter-regional links
between SR Grid and NEW Grid shall have to be robust and flexible enough to
facilitate import of power to meet the power deficit during the evening peak
conditions and also facilitate export of surplus power of about 29,000 MW
during high RE & off-peak conditions.

i) After meeting RPO obligations, 15,000 MW to 17,000 MW of surplus

power can be exported from Southern Region with up-gradation of existing/
under implementation sub-stations from 400 kV to 765 kV rated voltage level
and charging of corresponding transmission lines to their rated voltage at 765
kV level. However, for export of surplus power of 29,000 MW from Southern
Region, inter-regional system strengthening may also be required. For further
transfer of power within Western Region and beyond to Northern Region or
Eastern Region, transmission system augmentation may be required, which
shall be identified based on all-India studies.

j) Part-A transmission system was discussed with the stakeholders in the

1st meeting of SRSCT held on 07.09.2018 wherein it had been agreed that the
scheme would be implemented as ISTS, consequent to grant of LTA by the
Petitioner. Subsequently, the transmission system was also discussed and
agreed in the 2nd meeting of National Committee on Transmission
(04.12.2018), in the 3rd meeting of Empowered Committee on Transmission

Order in Petition No. 200/MP/2019 Page 9

 (21.12.2018), in the 35th SRPC meeting (02.02.2019), in the 4th meeting of
Empowered Committee on Transmission (12.07.2019) and in the 36th SRPC
meeting (12.07.2019).

k) Part-B transmission system was discussed with the stakeholders in the

2nd meeting of SRSCT held on 10.06.2019. The scheme has also been
discussed in the 36th SRPC meeting held on 12.07.2019.

l) The details of the scheme, its justification, estimated cost and impact
on tariff, results of the system studies, study assumptions, stakeholders’
consultation and approval details were published on the Petitioner’s website on
10.07.2019.

m) The estimated cost of the proposed transmission system is Rs.9,485

crore.

n) n) Ministry of Power, Government of India, vide letter ref. 25-11/2/2019-

PG dated 11.7.2019 issued directions under Section 107 of the 2003 Act and
conveyed the following:
“2. As the gestation period of RE projects is much shorter in comparison to the
implementation period of the transmission facilities and significant quantum of
RE capacity targeted to be tendered out in the current financial year, it is
necessary that the present system of transmission planning and implementation
for RE projects need to be carried out in Mission Mode. The transmission
activities need to be started much ahead of the generation so that both of them
are completed in matching time-frame to achieve the target set by Govt. of India.
Thus, in the said background, it has been decided by the Government to accord
the identified transmission schemes for aforementioned 66.6 GW of RE
generation, comprising around 28 GW under Phase – I and 38.5 GW under
Phase – II as ‘Projects of National Importance’.”

Further, it has also been directed that:

“Prior requirement of LTA applications and associated BGs, to be deferred for

the interim period till the RE project is awarded to successful bidder, for taking up
the implementation of associated transmission systems for balance RE Capacity
under 66.5 GW of RE. It is however, clarified that the due regulatory procedure
of LTA and Connectivity will be followed by the successful bidder”.

o) In line with the aforesaid direction of the Ministry of Power, the

Petitioner has filed the present Petition for regulatory approval under proviso

Order in Petition No. 200/MP/2019 Page 10

 3(1)(i) read along with proviso 8 (Power to Relax) and proviso 9 (Power to
remove difficulties) of Central Electricity Regulatory Commission (Grant of
Regulatory Approval for execution of Inter-State Transmission Scheme to
Central Transmission Utility) Regulations, 2010 (in short, “the Regulatory
Approval Regulations”).

p) The Petitioner has calculated cost of energy considering only solar

CUF and capacity of 8,900 MW, whereas capacity in the petition is 18.5 GW
comprising of solar and wind which have different CUF. Project Inception
Report provides that the annual transmission charges for the subject scheme at
an estimated cost of about Rs.9,485 crore would be about Rs.1,614 crore.

Hearing dated 25.07.2019

3. The Commission admitted the Petition during the hearing held on 25.07.2019

and sought certain information from Petitioner.

4. The Petitioner vide affidavit dated 02.08.2019 submitted that it had not

received any LTA application for the transmission system till date and in absence of

LTA applications, no information pertaining to signing of PPAs was available with the

Petitioner. The Petitioner also submitted that comments had been received from

Karnataka Power Transmission Corporation Limited (KPTCL) vide their letter dated

30.7.2019 wherein KPTCL concurred with the proposed transmission scheme and

opined that as agreed in 2nd SRSCT meeting, the transmission schemes should be

implemented consequent to grant of LTA applications by the Petitioner.

5. The Petitioner vide affidavit dated 01.10.2019 has submitted that based on

the inputs from MNRE/SECI, a meeting was held in CEA on 30.8.2019 for

prioritization of the already identified transmission systems with the 66.5 GW

potential RE capacity. During the meeting, it was informed that the generation

Order in Petition No. 200/MP/2019 Page 11

projects are scheduled for commissioning by December 2020, December 2021 and

beyond 2021. Accordingly, the phasing and location-wise details as regards 18.5

GW RE generation potential planned to be implemented in Southern Region has

been worked out. Estimated cost of transmission system to be implemented by

December 2021 (for 10.5 GW) is Rs.4,435 crore, while the same to be implemented

beyond December 2021 (8 GW) is Rs.4207 crore.

Submissions by Respondent No.1 TANGEDCO

6. The Respondent No. 1, Tamil Nadu Generation and Distribution Corporation

(TANGEDCO) vide affidavit dated 9.8.2019 has submitted as under.

a) The Regulation 3(1) of the Regulatory Approval Regulations clearly

mandates that schemes under ISTS should be evolved in consultation with
CEA and beneficiaries. The proposed schemes in the present petition are
evolved based on erroneous inputs and assumptions and are also inconsistent
with the studies conducted in other regions viz. Western and Northern Regions.

b) Proposed transmission system for integrating the assessed RE

potential of 66.5 GW needs a detailed analysis and examination. The proposed
up-gradation schemes will create a huge redundancy in the transmission
system which is uneconomical, inefficient and unwarranted. Since the schemes
have not been agreed to by TANGEDCO due to the deficiencies in the planning
studies, it was not concurred in the Standing Committee and SRPC meetings
and a request was made to conduct All India based joint studies to finalise the
schemes.

c) The scheme would give a tariff shock to the distribution utilities.

d) During the 2nd meeting of SRSCT held on 09.07.2018 at Bangalore,

TANGEDCO strongly opposed the proposal for common transmission system
strengthening in Southern Region since the study was not carried out on All
India basis. However, it was recorded in the minutes of the meeting, which

Order in Petition No. 200/MP/2019 Page 12

were issued one day before the 35th TCC meeting, that the above schemes are
agreed by the Committee. Subsequent to the communication of the minutes of
the meeting, the same proposal was brought in the 35th meeting of the TCC
and 36th meeting of the SRPC.

e) During the 35th TCC meeting held on 11.7.2019 and 36th SRPC
meeting held on 12.7.2019, the Petitioner included the subject “Up-gradation
proposal” as an additional agenda to the 35th meeting of the TCC without giving
any time to the beneficiaries to analyse the proposal. TANGEDCO vehemently
opposed the proposal as the system studies were not carried out on All India
basis.

f) The Ministry of Power has issued directions to CERC to give regulatory

approval to the schemes proposed by the Petitioner. These directions are
illegal and patently wrong. Directions under Section 107 of the Act can be
policy decisions taken by the Government of India and not regulatory orders. If
the Commission is to act as per the directions of MoP under Section 107 of the
Act, there is no necessity for approval by the Commission. The Act does not
provide for such interference with the jurisdiction of the Commission in matters
relating to grant of regulatory approval. Grant of approval requires a detailed
consultative process as provided under the Regulations and Rules read with
the Act. A regulatory approval by the Commission will entitle the Petitioner to
claim tariff for the transmission system. In matters relating to determination of
tariff, it is the Commission which is the only authority recognized under the Act.
No direction can be given to the Commission in matters where the end result
will be payment of tariff by consumers. At best the policy decision of
Government under section 107 of the Act can have only guiding value. The
policy decision of GOI cannot be extrapolated to direct a Regulator to act in a
certain manner to benefit a particular Public Sector Undertaking i.e. the
Petitioner. Moreover, there shall be benefit purely of financial nature to the
petitioner from the tariff it will be entitled to get once the transmission scheme is
approved by the Commission. The tariff to be claimed by the Petitioner
subsequent to the approval of the scheme will be borne by the consumers.
Therefore, any direction under Section 107 of the Act cannot bind the

Order in Petition No. 200/MP/2019 Page 13

 Commission in its duty to conduct prudent check before grant of approval to the
scheme.

g) The above becomes all the more crucial because the transmission
system as proposed by PGCIL was opposed by TANGEDCO, which the
Petitioner did not consider. Moreover, the objections of TANGEDCO were not
even recorded in the minutes of meeting. To this effect, TANGEDCO has
written two letters to the Standing Committee expressing its concern that the
objections raised by TANGEDCO were not recorded in the minutes of the 2nd
meeting of SRSCT held at Bengaluru on 10.7.2019.

h) TANGEDCO has prayed that the Petition may be dismissed and a joint
study involving all stakeholders be conducted by the Petitioner. The Petitioner
may be directed to place on record the detailed RE potential assessment report
of NIWE or SECI or other agencies.

Rejoinder of the Petitioner to the submissions of TANGEDCO

7. Petitioner vide affidavit dated 14.10.2019 has submitted the rejoinder to reply of
Respondent No. 1 TANGEDCO and has submitted as below.

a) The Petitioner has diligently carried out consultation with all the
stakeholders which is also evident from the submissions of the Respondent
itself.

b) Gestation period for development of generation projects is quite small

as compared to development of transmission system and, therefore, the
requirement of transmission system to facilitate evacuation of power from
renewable energy generations on potential basis is required to be assessed in
advance.

c) The Respondent has been a party to all the Joint Study meetings and
Standing Committee meetings wherein the transmission system was evolved in
consultation and after deliberations with the stakeholders. Further, the load-
generation balance of the Southern Region has been formulated after

Order in Petition No. 200/MP/2019 Page 14

considering the inputs provided by the Respondent and STUs during Joint
Study meeting held at SRPC, Bengaluru during 1st & 2nd May 2019. The
Respondent had not raised any contention or reservations on the referred Load
Generation Balance (LGB) as is evident in the minutes of the Joint Study
meeting. Based on LGB worked out by the respective STUs during the Joint
study meeting, the comprehensive transmission scheme was evolved for
integration of RE generation of 18.5 GW in Southern Region. Further, it was
also identified that for export of large surplus power of Southern Region,
additional inter-regional links and strengthening in NEW (North-East-West) Grid
may be required for supply of power to beneficiaries in WR, NR & ER. The
same shall be identified subsequently on the basis of all India system studies
as per the requirements.

d) At this juncture, when proposal was discussed and deliberated in

SRPC, TANGEDCO raised objections to the transmission scheme. It is quite
evident that such objections raised by the Respondent are afterthoughts and
mainly guided by the anticipated enhanced commercial liability which
TANGEDCO is expecting with the implementation of transmission system. It
may be noted that the Respondent has not rejected the technical requirement
of the transmission system for integration of RE generations of Southern
Region and only seeking all India studies for identification of requirement of the
inter-reginal links which shall be done in due course along with the realization/
harnessing of the RE potential. Further opposition of the transmission system
may lead to stranding of RE generations.

e) The proposed transmission systems are either (i) generation linked or

(ii) system strengthening due to operational constraints or to meet the load
requirements in view of load growth projections as per Electric Power Survey of
Central Electricity Authority. The Respondent itself has faced severe problems
in the past due to lack of sufficient inter-regional lines between NEW grid and
SR grid and within region between S1 & S2 areas.

f) In the absence of firm drawl points for the various potential REZs in

Order in Petition No. 200/MP/2019 Page 15

 Southern Region, the joint studies were conducted which were focused on
identification of immediate integration of generation projects in REZs with ISTS.
Further three scenarios Peak Load, Off-peak Load and maximum RE
generation were worked out along with the stakeholders in the Joint Study
meeting. The load flow studies were conducted in the most critical case and the
same were included in the report circulated to STUs, DISCOMs, CEA,
POSOCO, SRPC and also uploaded on the CTU website. The transmission
system evolved in such scenario shall cater to generally all other scenarios
supporting generation in other regions wherein the transmission system shall
be less constrained.

g) Notwithstanding the above, the behaviour of the planned system on a

common all India file to identify any additional transmission system/ reactive
power requirement with detailed Load Generation Balance shall also be
assessed after firming up the drawl points and quantum of power transfer.
Further import/ export requirements shall be identified/ determined through all
India studies in due course in association with CEA and other stake holders.

h) In accordance with the paragraph 5.3.1 of the Detailed Procedure for

Connectivity to projects based on Renewable Energy sources to ISTS “the
terminal bays at the ISTS sub-station shall be under the scope of transmission
licensee owning the ISTS sub-station”. Accordingly, the number of downstream
feeder bays at 220 kV or 230 kV has been considered in the proposed scheme.

i) CTU/CEA has considered RE potential as per the information provided

by MNRE in consultation with the SNA/STU/CEA/NIWE through various
meetings wherein the representative of Tamil Nadu was also present.

Observations of POSOCO

8. The Petitioner has submitted that on uploading the details of the transmission

system on its website, POSOCO vide letter dated 24.8.2019 has observed as

follows:

Order in Petition No. 200/MP/2019 Page 16

a) After comparing both cases [Case-1 (NR):- All India 21-22 RE Ph-2
CTU REZ ALT12 updated rev5 Alt 2; Case-2 (SR):- PSSE-2021-22 Off
Peak_ll_website], it is found that the load generation balance (LGB) considered
in southern region's RE transmission planning case is drastically different from
the LGB considered in northern region's RE planning case.

b) As seen, generation in northern region has been reduced to only 31678

MW in SR RE transmission planning study case. This has resulted in increase
in NR Import from 2270 MW in NR transmission planning study case to 36500
MW in SR transmission planning study case. Though import of 36,000 MW by
northern region is a possible scenario, the same is highly unlikely to occur in
high RE scenario as northern region is also expected to have significant
capacity of renewable generation by 2021-22. As transmission planning studies
have been carried out for high RE scenario, the generation of 31.6 GW
considered in northern region seems improbable. Further, the RE planned
under SEZs and WEZs in northern region has not even been completely
modelled in the study case.

c) Further, generation in ER has also been increased from 10809 MW in

NR transmission planning case to 25024 MW in SR TS planning case. ER
being a net exporter during the high RE period is also highly unlikely.

d) In addition to different LGB assumptions, the network topology is also

vastly different in these two cases.

e) With the significant change in LGB and network topology in the two
study cases, the direction of inter-regional as well as intra-regional flows is also
changing significantly. The vast difference in LGB and network topology in 2
cases may result in overlooking of potentially insecure real-time operating
conditions and may lead to RE curtailment in future. Therefore, even in case of
region-specific studies, there is a need to ensure that the base case files must
correspond to a common scenario on All India basis.

f) The issue was also highlighted by POSOCO in the meeting of the 2nd
Standing Committee on Transmission of SR held on 10.06.2019 where it was

Order in Petition No. 200/MP/2019 Page 17

decided that all-India studies would be conducted with the participation of CEA,
CTU, POSOCO and concerned beneficiaries/ STUs for evolution of additional
(over and above the above proposed scheme) transmission scheme for export
of power from Southern grid to rest of all-India grid.

g) Subsequently, vide email dated 16.07.2019, CEA requested POSOCO

to share operational and SCADA data of last 3 years for carrying out All India
Studies. The data was shared by POSOCO with CEA vide email dated
25.07.2019. However, the All India Studies as decided in 2nd Standing
Committee on Transmission of SR are yet to be carried out.

h) The transmission planning scheme (for 18.5 GW RE in SR) uploaded

by CTU on its website mentions that the Off-peak LGB (for 2021-22 time frame)
finalized in the joint study meeting held on 1st & 2nd May 2019 at SRPC,
Bengaluru has been considered for study purpose. However, LGB considered
in the case is different from the one decided in the meeting.

i) It has been mentioned by CTU in the study assumptions (uploaded on

CTU website) that dispatch of 80% of the installed capacity has been
considered for the prioritized WEZs & SEZs for evolving the transmission
system for immediate evacuation. However, different dispatch in case of solar
generation has been observed in the case.

j) As more than 70% solar dispatch is considered in southern region,

solar generation dispatch in other regions should also be around this value.
However, it has been observed that very less solar generation (around 4435
MW) has been considered in northern region, whereas total installed solar
generation capacity in northern region is expected to be around 35000 MW by
2021-22.

k) The Swing Bus Generation (CGPL Mundra) in the case is -9283 MW.
The capacity of the plant is 4150 MW. Even if 55% generation (technical
minimum) is considered at CGPL Mundra, a change of around 12,000 MW has
to be made in LGBR. Such large change in LGBR will result in significant
change in tie line flows especially in WR-SR corridor.

Order in Petition No. 200/MP/2019 Page 18

l) Flow on HVDC Talcher-Kolar is 1000 MW, Bhadrawati is 100 MW &
Gazuwaka is 200 MW. All three HVDC flows are towards SR. When SR is
exporting around 28 GW, there is scope of reversing flows on these HVDCs.
Any constraint arising in SR or other regions due to reversal of power in these
HVDCs may also be identified and addressed during the planning stage itself.

m) High voltage at many 765 kV and 400 kV buses viz., Cuddapah,

Nellore PS, Bidar, Kurnool, Solapur, and Thiruvalem etc. has also been
observed.

n) Voltages as high as 440 kV can be seen at 400 kV Koyambedu and

400 kV Manalmedu. It is evident that reactive power compensation is not
enough to control the over-voltage during the low wind & solar period. There is
need for additional reactive power compensation to take care of the high
voltages.

o) A total of 13 STATCOM devices are planned/ under operation across

the Indian grid. However, out of 13 STATCOMs, only 5 have been modelled in
the case while STATCOMs at Hyderabad, Udumalpet, Trichy, Kishanganj,
Solapur, Satna, Aurangabad, Satna and Gwalior have not been modelled in the
case.

p) Further, in base case, 26 additional STATCOMs with max. 9999 VAR

support have been modelled. Out of these 26 additional STATCOMs, 18 have
been kept “on” in the case. Most of these STATCOMs have been placed at
both ends of HVDC terminals and it seems that they have been modelled as a
replacement of filters.

q) The transmission planning studies have been carried out only for high
RE scenario in which SR is exporting around 28 GW of power to Western and
Eastern Region. This scenario will change completely during low RE period
when SR will become the net importer. This reversal of power in low RE period
may lead to system constraints which might have got overlooked as system
behaviour in low RE scenario has not been studied. Already in the high RE

Order in Petition No. 200/MP/2019 Page 19

 scenario study case of CTUIL, high voltages to the tune of 440 kV have been
observed in SR. The problem is bound to be more severe in low RE period.
Therefore, low RE scenario needs to be studied in order to identify and address
system constraints like high voltage nodes, reversal of power etc. during the
planning stage itself so that the additional system required for addressal of
these issues also comes within the same time frame.

Petitioner’s response to POSOCO’s observations

9. The Petitioner has submitted the response to POSOCO’s observation as

follows:

a) The load-generation scenario for Southern Region was prepared

collectively by the constituents for the year 2021-22 in joint study meeting held
on 1st and 2nd May 2019 at SRPC, Bengaluru along with CEA, SRPC &
POSOCO wherein the data file has been prepared as per the above scenario.
The dispatches of the various generations were considered in consultation with
the respective States.

b) As per the above scenario, system studies were carried out for off-peak
scenario wherein Southern Region was expected to be surplus by 29700 MW.
However, during the course of studies, it was observed that 1500 MW
generation at NP Kunta has been reflected in State of Andhra Pradesh as well
as ISTS-RE in the above-considered LGB. Accordingly, it was reviewed in the
preparation of PSSE file, thereby reducing the net export to 27,900 MW.
Further, total load and losses of 43,900 MW have been considered in the data
file.

c) Total RE potential in Kurnool and Ananthapuram zone is 8 GW (SEZ-5

GW & WEZ-3 GW) and, accordingly, dispatch of 6.4 GW i.e., 80 % of RE
potential has been considered in the Kurnool & Ananthapuram zone.

d) Further Talcher-Kolar HVDC flow was considered after consultation

with the States in the Joint Study meeting looking into Talcher-II generation.

e) Regarding high loading on inter-regional links and in certain corridors in

Order in Petition No. 200/MP/2019 Page 20

 Western Region, it is to mention that the transmission system has been
identified for immediate connectivity and integration of RE generation potential
as provided by MNRE/SECI in Tamil Nadu, Karnataka and Andhra Pradesh.
Further, additional transmission system augmentation shall be required for
export of surplus power of 27900 MW from Southern Region and further
transfer of power within Western region and beyond to Northern region or
Eastern Region and the same shall be identified upon identification of drawal
states. In addition to above transmission system requirements, the
transformation capacity augmentation shall also be identified at 765 kV and 400
kV sub-stations on regular basis. This has already been mentioned in the
proposal uploaded on CTU website & 2nd SR SCT held on 10.07.2019.
f) Reactive power planning and fault level analysis is being carried out by
the Petitioner as a part of regular exercise. As part of the same, number of
reactors have already been identified at various ISTS and STU sub-stations.
Further schemes for controlling the short circuit level at Nellore, Neyveli
complex and Thiruvelam were also agreed in Standing Committee on
Transmission. Nevertheless, a comprehensive study for the same is being
taken-up for the future timeframe.

g) A number of inter-regional links viz., Bidar-Parli (new) PG 765 kV D/c,

Raichur-Sholapur 765 kV 2nd D/c, Narendra - Kolhapur 765 2" D/c and
Kolhapur (PG) - Pune GIS 765 kV D/c lines were proposed in the system
studies to cater to the export requirement of 27,900 MW as per the load-
generation scenario. In the absence of above IR links, the "N-1" criteria under
the Transmission Planning Criteria is not met by the presently under-
construction/ planned IR links between NEW-SR Grid. However, as per the
decision in the 2nd meeting of SRSCT, the above IR links shall be finalized
based on the transfer requirements and firming-up of generation projects.

Submissions of Solar Energy Corporation of India (SECI)

10. The Respondent No. 18, Solar Energy Corporation of India (SECI) vide

affidavit dated 22.10.2019 has submitted as under:

a) SECI has, so far, awarded RE Projects for a total RE capacity of 25.04

Order in Petition No. 200/MP/2019 Page 21

GW out of which 14.24 GW is of solar and 10.8 GW is of wind/ hybrid. The
total commissioned capacity is 6.59 GW which includes 5.0 GW of solar, 1.58
GW for wind and balance capacities are under various stages of
commissioning.

b) During 2019-20, so far, RE projects for a capacity of 6.10 GW have

already been awarded and four tenders for a total capacity of 10.6 GW are
under different stages of bidding and award process. These tenders will be
awarded during the period between November-December 2019 and thereafter
bidding for a further capacity of around 6 GW will be carried out for their
award by March 2020. Tenders are being invited by SECI on regular basis for
a capacity in lot size of 1.2-1.8 GW and at any point of time, there are 3-4
tenders at various stages of procuring. During 2019-20, award for a capacity
of around 15-20 GW is planned upto March 2020. Similar trend for inviting of
bids and award will be followed during 2020-21 and it is expected that
capacities of around 20-25 GW will be bid and awarded.

c) SECI has initiated the work of aggregating public and/or private land
with the help of respective State Governments, to facilitate the land availability
to the developers in the RE rich potential areas so as difficulties are not faced
by the developers at a later date which is one of the reasons of delay in
commissioning of RE Projects. Already the Government of AP, Karnataka,
Rajasthan and Gujarat have responded positively and work of identification
and securing land around the proposed CTU sub-station is on.

d) Since significant quantum of RE capacity is targeted to be tendered in

the current financial year, it is necessary that the present system of
transmission planning and implantation of RE projects need to be carried out
in Mission Mode. The transmission activities need to be started much ahead
of the generation so that both of them are completed in matching time frame
to achieve the target set up by Government of India as the gestation period of
RE projects is much shorter (18 months) in comparison to the implementation
period of the transmission facilities.

Order in Petition No. 200/MP/2019 Page 22

 e) The RE developers are allowed directly to apply for Stage-II
connectivity to CTU on the basis of award received from SECI and, thereafter,
they apply for LTA. Therefore, LTA applications for the planned transmission
capacity of 18.5 GW in Southern Region is scheduled to be utilized by the RE
developers progressively matching to the award of RE capacities in the same
manner as is happening in NR and WR.

f) As per SECI’s bidding documents, scheduled COD for RE Project will

be 18 months from the date of signing of PPA. PPA will be signed within a
period of 90 days from the date of issue of LOA. Accordingly, commissioning
of generating plants will be achieved for the total target capacity of 66.5 GW.

Further submissions by Respondent TANGEDCO

11. TANGEDCO vide affidavit dated 29.10.2019 has further submitted as follows:

a) The hasty planning process of the Petitioner and CEA and the
consequential upshot in the form of study report and the power evacuation
proposal for the Wind Energy zones and Solar energy zones establishes that
these agencies have neither applied any rational planning philosophies nor
followed any regulatory/ planning guidelines for creation of efficient and optimal
transmission system.

b) The transmission schemes need to be developed based on the citing of

the generation projects and the location of the beneficiaries/ target
beneficiaries. TANGEDCO has been consistently raising the issue of
assessment of developable RE potential and the prospective beneficiaries for
the surplus generation capacity in each region before all the forums. The
Petitioner has not shared the above basic input data obtained from the
concerned authorised agencies which is very vital for the planning study.

c) It is obvious that the gestation period of RE generation projects is

short. However, commissioning of RE projects largely depends on (i) availability
of suitable land for development of RE projects and (ii) tie-up with beneficiaries.

Order in Petition No. 200/MP/2019 Page 23

 d) As far as the instant petition is concerned, the proposed transmission
schemes for all the three Regions viz. Southern, Western and Northern Region
are evolved purely based on mythical scenarios without following any planning
philosophies. The central issue is that the Petitioner has manipulated the all
India network data to conveniently suit its illegitimate proposals/ schemes in the
three Regions. The planning process has also been criticised by POSOCO
which is responsible for seamless operation of Indian power system.

Petitioner’s response to TANGEDCO’s further submissions

12. The Petitioner vide affidavit dated 20.11.2019 has responded to the specific

queries raised by TANGEDCO. It has submitted that POSOCO has not denied the

necessity of requirement of the referred transmission scheme and has only raised

queries related to the study file which were adequately replied by the Petitioner vide

letter dated 01.10.2019. The Petitioner has submitted that behaviour of the planned

system on a common all India file to identify any additional transmission system

including strengthening of IR links/ reactive power requirement with detailed Load

Generation Balance shall also be assessed after firming up drawl points and

quantum of power transfer. Further, import/ export requirements shall be identified/

determined through all India studies in due course in association with CEA and other

stakeholders.

Hearing dated 11.12.2019

13. During the hearing held on 11.12.2019, learned counsel for TANGEDCO and

AP Discoms submitted that the Petitioner has not addressed the queries raised by

the Respondent, TANGEDCO. Learned counsel further submitted that the

Respondents have also not received the All India Study results.

Order in Petition No. 200/MP/2019 Page 24

14. During the hearing, the Commission observed that despite specific direction
dated 15.10.2019, SECI has provided only generic information not specific to SR,
where the transmission system in the present petition proposed to be built.
Therefore, the Commission directed the Petitioner to furnish the following details for
instant transmission scheme:

(a) Details of the identified land;

(b) Status of the RE bidding process; and
(c) Status of implementation of transmission system (including awarding
schedule of different transmission elements).

15. On directions of the Commission, the Respondent, SECI has, vide affidavit

dated 26.12.2019, submitted that land is identified only for a part of the capacity and

submitted the details of such identified land and also submitted the status of the RE

bidding process. Similarly, the Petitioner has, vide affidavit dated 26.12.2019,

submitted the detailed status of the Implementation of transmission system.

Submissions of the Petitioner vide affidavit dated 7.1.2020

16. In compliance of ROP of hearing dated 11.12.2019, the Petitioner vide

affidavit dated 7.1.2020 has submitted additional information as under:

a) A meeting was held on 18.10.2019 at CEA for discussions on Load-

Generation balance (LGB) to carry out All India Studies for upcoming RE
capacity. The study files, load-generation scenario assumptions considered in
the studies and study results were circulated to all the constituents in the
Southern Region and POSOCO for their observations/ comments/ suggestions
vide email dated 19.11.2019.

b) LGB & system studies were discussed in the joint study meeting held
at CEA on 21-22 November 2019, wherein POSOCO representative and SR
constituents requested for some more time to forward their comments/
observations on the all-India load-generation scenario for RE integration.

Order in Petition No. 200/MP/2019 Page 25

 c) Comments were received from POSOCO vide letter dated 29.11.2019
and the same were discussed in a meeting was held with participation from
CEA, POSOCO & CTU at CEA on 10.12.2019 wherein detailed deliberations
were held on the observations received. After detailed deliberations,
considering the variations in generation and demand in various regions, 9
scenarios were prepared for the months of June 2021, August 2021 and
February 2022 for afternoon peak, evening peak and night off-peak scenario. It
was further decided that the scenarios prepared as per the deliberations shall
be circulated to SR constituents for their comments/ observations/ suggestions
and shall be discussed/ deliberated with the Southern Region constituents.

d) All-India studies circulated to SR constituents vide email dated

19.11.2019 were discussed in the 1st SRPCTP meeting held on 16.12.2019 at
Hyderabad wherein it was informed that CTU has not received any comments/
observations/ suggestions from any of the SR constituents on the circulated All-
India system studies except POSOCO.

e) After the 1st SRPCTP meeting held on 16.12.2019, comments have

been received from TSTRANSCO vide email dated 18.12.2019 and
TANTRANSCO vide email dated 23.12.2019.

f) As per the inputs from MNRE/SECI, a meeting was held in CEA on

30.08.2019 for prioritization of the already identified transmission system with
66.5 GW potential RE capacity.

Submissions of TANGEDCO vide affidavit dated 6.2.2020

17. TANGEDCO vide affidavit dated 6.2.2020 has submitted as follows:

a) Though SECI vide its affidavit dated 24.12.2019 has furnished the land
availability details and status of bidding, as far as Tamil Nadu is concerned,
SECI has not furnished any land details for the proposed 2.5 GW RE capacity
and has rather stated that the developers will arrange land directly. Neither has
SECI provided details of developable potential available in Tirunelveli and
Pugalur area.

Order in Petition No. 200/MP/2019 Page 26

 b) With regard to potential areas in Andhra Pradesh and Karnataka, SECI
has not furnished any commitment given by the concerned State governments
regarding allotment of land for the purpose of development of ISTS connected
RE projects. SECI has to bring such details on record. Further, there is no
successful bid awarded by SECI so far in respect of Southern Region.

c) SECI is mandated/ liable to apply for Connectivity/ LTA for the purpose
of evolving transmission schemes and procurement and selling of power from
the RE generators. Without such arrangements, CTU cannot proceed with
development of transmission schemes.

d) TSTRANSCO has pointed out in its comments that the demand

projections are wrong and the major load on account of lift irrigation project has
not been considered in the study case which will further reduce the surplus
available in the region. Also, it has been pointed out from the study conducted
by Telangana that the inter-regional lines are loaded below 30% during 2021-
22 timeframe. The stranded capacity in SR after relinquishment of LTA by IPPs
is 6,665 MW and, hence, it has been requested to re-plan the transmission
proposal without new investment on 765 kV and 400 kV sub-stations by utilising
the redundant capacity.

e) During 36th TCC and 37th SRPC meetings held on 31.1.2020 and
1.2.2020 at Hyderabad, CTU confirmed that eight scenario studies will be
shared and deliberated in a special meeting shortly. Further, it was informed
that the proposed presentation by SECI will be made on 11.2.2020 at
TANGEDCO head office and all the SR constituents were requested to
participate in the presentation and deliberate the issues.

Submissions of KPTCL vide affidavit dated 7.2.2020

18. Karnataka Power Transmission Corporation Limited (KPTCL), vide affidavit

dated 7.2.2020, has submitted as under:

a) During 1st SRPC (TP) meeting held on 16.12.2019, it was agreed that
further studies will be conducted by the Petitioner for 6 different scenarios of

Order in Petition No. 200/MP/2019 Page 27

 load generation with all-India PSSE file for analysis and evaluation of
transmission scheme after receipt of comments from STUs on the circulated
PSSE file w.r.t transmission network. Additionally, during the discussion at the
meeting, SECI informed that KREDL has initiated the process for acquisition of
land and stated that the project is likely to be wind/ solar hybrid type. Hence,
SECI shall firm up the type of the generation proposed at Koppal and in case
wind project is considered necessary, wind study report will to be furnished to
ascertain the quantum of generation possible after duly considering
commissioned and sanctioned wind projects by KREDL. If there is any change
in type of generation proposed in Koppal, necessary joint studies have to be
conducted before taking up the project for execution.

b) Proposed transmission scheme of SEZs at Gadag, Koppal and Bidar in

Karnataka shall be taken up for implementation only after firming of LTA by the
Petitioner with due revision/ modification in transmission scheme based on the
output of the studies conducted by the Petitioner for different scenarios of all
India network as discussed in 1st SRPC (TP) meeting of CEA.

Hearing dated 12.02.2020

19. The learned counsel for the Respondent, TANGEDCO submitted that a

meeting was held with SECI, CTU and NIWE on 11.2.2020 at TANGEDCO

headquarter in relation to the issues in the present Petition and also the issue related

to availability of land was discussed. Learned counsel further submitted that

TANGEDCO has not agreed to the transmission system covered in the Petition. In

the said meeting, SECI and CTU have stated to revise RE capacity since NIWE had

submitted that while arriving at wind potential, availability of land has not been

factored into. Accordingly, the RE potential for Wind Energy Zones in Tamil Nadu is

to be re-assessed. CTU agreed to conduct nine (09) scenario studies and to share

the study report during the meeting. Learned counsel raised apprehension on the

land availability in Karur and suggested that SECI should take LTA.

Order in Petition No. 200/MP/2019 Page 28

20. The Representative of SECI submitted that land availability in Karur is limited

and not corresponding to indicated potential. In Koppal, the land availability is not an

issue and SECI would invite the tender shortly. As regards Ananthpur and Kurnool,

while the land availability is there, the Government of Andhra Pradesh has presently

put the land on hold. As regards Gadag and Bidar, there are no issues pertaining to

land and SECI has received favourable response.

21. After hearing the parties, the Commission directed the Petitioner to confirm

whether there are any issues regarding the specified locations and whether the

transmission system at above three places, namely Koppal, Gadag and Bidar can be

implemented without the complete system.

Submissions of the Petitioner vide affidavit dated 4.5.2020

22. The Petitioner vide affidavit dated 4.5.2020 has submitted the details of

identified land and status of the RE bidding process as under:

a) SECI, vide its letter dated 25.2.2020, has stated that the Government
of Andhra Pradesh has informed that it is not in a position to give land at
Kurnool/ Anantapur area to SECI for developments of renewable power parks.

b) SECI has requested to consider grant of regulatory approval while

putting the construction of transmission system infrastructure for Kurnool/
Anantapur on hold till clarification and/or approval from MNRE/ Government of
AP is received to implement the RE generation projects as planned. SECI has
further stated that there is no issue with respect to land availability at other
locations (Koppal, Gadag and Bidar area in Karnataka) and, therefore,
transmission system for Koppal, Gadag and Bidar REZ can be implemented
without the complete system envisaged for 18.5 GW in Southern Region.

c) During meeting held on 11.2.2020 at TANGEDCO headquarters for

discussion on various issues related to identification of RE potential in Southern

Order in Petition No. 200/MP/2019 Page 29

Region, TANGEDCO told that the transmission system may be planned only
based on LTA applications and not by the potential assessed by SECI/MNRE.
In response, CTU informed that not a single application has been received for
the entire assessed potential of 18.5 GW in Southern Region. TANGEDCO
insisted that the system must be planned based on the developable potential
and that the implementable RE potential must be ascertained before evolving
proposals. Also, concurrence from the State Nodal Agency and Expression of
Interest (EoI) from the developer must be obtained. KPTCL expressed concern
over additional wind potential of about 20,172 MW projected by NIWE/SECI.
KPTCL stated that only based on the technical assessment and without
verifying the ground realities, SECI projected RE potential for 2.5 GW in Koppal
(Phase-I) and 2.5 GW each at Gadag and Bidar districts (Phase-II).
Considering this theoretical potential, CTU has identified Transmission system
and seeking Regulatory Approval from CERC without receipt of LTA
applications from RE generators or REIA under CERC Regulations. This
unnecessary investment in the transmission system will have commercial
implications on transmission charges by stakeholders which will in turn burden
the DISCOMS and ultimately the consumers of the States. Also, KPTCL opined
that during Off-peak condition, the proposed generation at Koppal WEZ and
Gadag SEZ along with State's RE generation, mainly wind, may lead to
congestion in the 400 kV and 220 kV network of Karnataka. Further, KPTCL
also stated that in Koppal area, government land may not be available for wind
generation projects though there is possibility of private land for solar
generation projects. TANGEDCO insisted for implementation of the proposed
transmission schemes in phased manner. It was also informed that around
3000 MW spare capacity is available in the STU network already established
for evacuation of RE due to poor response from developers. CTUIL replied that
out of 6 nos. 500 MVA CTs proposed for their Tuticorin pooling station, only 3
nos. 500 MVA CTs were approved while 4th ICT is under regulatory approval
and stated that 5th & 6th ICT will be taken up depending on the requirements. It
was stated that the transformer capacity, augmentation can be done in 15-18
months’ time and can be implemented in matching timeframe of the RE
generation projects and therefore, shall only be implemented on grant of LTA

Order in Petition No. 200/MP/2019 Page 30

 by CTU.

Hearing dated 11.06.2020

23. During the hearing held on 11.06.2020, in response to the specific query of

the Commission as to why SECI doesn't apply for connectivity/ LTA as per the

Regulations which can be subsequently transferred to successful bidders/

developers, the representative of SECI submitted that for Koppal, tender of 2500

MW for setting up of a Solar Project in Solar Park has already been issued and it

would be the Solar Park Developing Agency who would be applying for connectivity

and LTA. Similar action will be taken for Gadag also. The representative of SECI

further submitted that there are other tenders for around 11,000 MW capacity (out of

which, 2000 MW Wind tender on 9.7.2020, 2000 MW Solar tender on 22.6.2020 and

5000 MW RTC tender on 3.7.2020) are under process and the RE generators/

developers are expected to come up thereunder and apply for connectivity.

24. The representative of CTUIL submitted that the results of All India Studies

were uploaded on its website as well as circulated to stakeholders for comments/

observations in December 2019. He further submitted that CTU has complied with

the provisions of the Central Electricity Regulatory Commission (Planning,

Coordination and Development of Economic and Efficient Inter-State Transmission

System by Central Transmission Utility and other related matters) Regulations, 2018

(in short, “the 2018 Transmission Planning Regulations”) and status of RPC

recommendations has already been submitted. The representative of CTU further

added that Koppal PS which was initially planned for Wind Energy Zone as per

potential identified by SECI/MNRE, has now been covered in the Solar Energy Zone

generation potential pursuant to issuance of SECI's tender for Solar Projects.

Order in Petition No. 200/MP/2019 Page 31

Additional submissions of KPTCL vide affidavit dated 4.5.2020

25. Respondent No. 4 Karnataka Power Transmission Corporation Limited

(KPTCL) vide affidavit dated 22.6.2020 has made following additional submissions:

a) The solar and wind energy potential schemes were discussed in the
37th SRPC meeting held on 1.2.2020. TSTRANSCO informed that it had added
3600 MW Renewable Energy generation during the last three years without any
additional transmission lines in the system by adopting distributed generating
schemes. TSTRANSCO had addressed a letter to CTU requesting to plan RE
generation in Telangana in distributed manner to utilize the existing
transmission system. The proposed dedicated EHV transmission system may
contribute high voltages in the network and lead to increase in PoC rates.

b) KPTCL endorsed the views of TSTRANSCO as regards adopting

distributed solar generating schemes and stated that it is good for system
operation. In few cases, there was fall of 650 MW generation (from 1850 MW to
12001 MW) observed at Pavagada Solar Park and they had managed with
available hydro generation.

c) In the absence of generators, SECI should apply for LTA for

developable potential as assessed by SECI and only upon grant of LTA by
CTU, the transmission system may be taken for implementation.

d) No works are proposed by KPTCL in the downstream network for the

transmission system for 18.5 GW of Solar and Wind Energy Zones in the
Southern Region.

Hearing dated 6.8.2020

26. The learned senior counsel for the Petitioner submitted that a meeting was

held on 23.07.2020 with CEA, CTU and POSOCO regarding All-India system studies

for discussing all 9 different scenarios and to also take a view on the comments

received from constituents on earlier studies that were circulated on 20.5.2020.

Order in Petition No. 200/MP/2019 Page 32

Detailed system studies for all 9 scenarios were uploaded on CTU`s website and the

same were circulated to Southern Region constituents on 3.8.2020. On the basis of

All-India studies, it has been found that the requirement of the identified transmission

system for 18.5 GW REZ in Southern Region has not changed and that such system

shall be required in case the potential as envisaged by SECI materializes.

27. In response to a specific query of the Commission as to how availability of

land for setting up the projects was being ensured, the representative of SECI

submitted that except for the cases where the tenders are issued for setting up Solar

Parks, the RE developers are themselves responsible for acquiring the requisite

lands. In case of Solar Parks, Solar Park Implementing Agency identifies the land.

He further submitted that SECI has already received letters from the Karnataka Solar

Power Development Corporation Limited (KSPDCL) dated 17.6.2020 and

Government of Andhra Pradesh dated 8.7.2020 indicating the availability of land in

the States of Karnataka and Andhra Pradesh respectively. As per letter from

KSPDCL, owners of 8310 acres of land in Gadag have expressed their interest to

sign the agreement with SECI, whereas for Bidar, 2885 acres of land has been

identified. For Koppal also, land requirement of about 12000 acres has been

identified, though the letter for which is not on record.

28. In response to the Commission`s query regarding identification of areas

where the issue of availability of land is not there, the representative of SECI stated

that for Koppal and Gadag in the State of Karnataka, there is no issue regarding

availability of land.

29. Learned senior counsel for TANGEDCO submitted that TANGEDCO has

already pointed out that there is no land available for development of solar/ wind

Order in Petition No. 200/MP/2019 Page 33

farms in the identified REZ in Tamil Nadu. He added that the Petitioner ought to be

directed to prepare a checklist for each of the identified REZ in the States of Andhra

Pradesh, Karnataka and Tamil Nadu indicating the availability of land, status of

bidding and whether LTA applications have been received. The identified

transmission system should be approved and taken-up for implementation based on

the above assessment and not merely on the basis of projections made by SECI.

30. Learned counsel for Karnataka Power Transmission Corporation Limited

(KPTCL) submitted that transmission system relating to Koppal, Gadag and Bidar

REZs may be taken up after finalization/ firming-up of LTAs and till RE generators

apply for LTA, SECI should apply for the LTA in accordance with applicable

Regulations.

31. After hearing the parties, the Commission directed the Petitioner and SECI to

furnish the following information on affidavit:

a) Land identified by solar park developer, if any, at each location;

b) Availability of land other than land identified by solar park developer at
each location; and
c) Based on assessment of land availability and expected LTA applications,
recommended priority of the transmission systems to be taken up.

32. In response, the Petitioner vide affidavit 26.8.2020 has submitted as under:

a. Adequate land is available for establishment of wind/solar power

generation in Koppal and Gadag (Part-A & Part-B). LTA applications are yet
to be received by the CTU. Presently, no ISTS infrastructure is available in
Koppal & Gadag area. Therefore, the identified transmission system is required
for integration as well as evacuation of renewable energy from these zones.
Accordingly, implementation of identified transmission system for Koppal and
Gadag REZ may be taken-up on priority.

Order in Petition No. 200/MP/2019 Page 34

 b. Implementation of the transmission system for Kurnool and Ananthapur
REZ may be taken-up as and when location specific bidding is issued by
SECI for development of RE projects. Accordingly the same may be put on-
hold now.
c. Implementation of the identified transmission system in all other RE
zones may be kept on hold.

Hearing dated 15.4.2021

33. Learned counsel for the Respondent No.1, TANGEDCO submitted that the

Respondent is not only objecting to the transmission schemes relating to Karur and

Tuticorin REZs as located in the State of Tamil Nadu but also for the other REZs,

where there are no LTA applications since as per the Central Electricity Regulatory

Commission (Sharing of Inter-State Transmission Charges and Losses) Regulations,

2020 (in short, “the 2020 Sharing Regulations”), TANGEDCO will be required to

share its costs on the proportionate basis. It was further submitted that in RPC

meetings, the constituents have opposed to the implementation of such schemes

without the LTA applications and that as per the Petitioner's own affidavit dated

26.8.2020, there is no land availability in the State of Tamil Nadu.

34. Power Company of Karnataka Limited (PCKL) which represents all the

ESCOMs in Karnataka vide affidavit dated 28.4.2021 has submitted as under:

a) Yearly Transmission Charges (YTC) for the proposed transmission

system should be included in the National Component as per the 2020 Sharing
Regulations.

b) RPO equivalent capacity requirement of Karnataka for the financial

year 2021-2022 is 9810 MW. However, the State has already established
installed capacity of about 14890 MW from Renewable Energy Source as on
August 2020. As Karnataka ESCOMs have already fulfilled RPO, they have not
entered into any PPA towards purchase of the renewable energy power

Order in Petition No. 200/MP/2019 Page 35

 proposed to be developed by CTUIL.

c) The proposed transmission system is being developed purely for inter-

State sale of power, and as such CTUIL shall ensure that ESCOMs are not
solely burdened with any additional transmission charges for having
constructed the line/ project in Karnataka State or due to any downstream lines
that may constructed on need basis at a later date.

Submissions of the Petitioner vide affidavit dated 29.4.2021

35. The Petitioner vide affidavit dated 29.4.2021 has submitted as follows:

a) During meeting with CEA regarding development of Common

Transmission System for Connectivity, held on 16.10.2020 for review of 66.5
GW RE linked Transmission schemes and 12th meeting of the Monitoring
Committee on Inter-State Transmission System (ISTS) for 66.5 GW REZs held
on 22.10.2020, it was decided that transmission system identified for
integration of REZ may be taken-up for implementation after grant of LTA.

b) It was also decided that the transmission system for evacuation of

power from RE sources in Bidar, Karur, Kurnool and Anantapur area may be
put on hold due to non-availability of LTA applications.

c) Subsequently, Connectivity/ LTA applications have been received in

Koppal, Gadag and Karur REZ. The details of quantum of Stage-II connectivity
and LTA granted/ agreed for grant in these REZs are as below:

Order in Petition No. 200/MP/2019 Page 36

 St-II
LTA
REZ connectivity Remarks
(MW)
(MW)
• For 300MW, Connectivity & LTA respectively
sought from 15-01-2022 & 01-10-2022.
Koppal 600 300
• Connectivity for 300MW sought from
01.08.2022.***
Gadag 160 0 Connectivity sought from 01.05.2022.
Karur 310 100 LTA sought from 01.06.2022.
The Tuticorin-II PS has been implemented with
2x500 MVA ICTs as part of Green Energy
Corridor for total potential of 2.5 GW. Further
based on requirement 1x500 MVA ICT-3 is
under advanced stage of implementation.
Tuticorin 1880.1 1100.1 Against this potential, LTA of 950.1 MW has
been granted & under operation and additional
LTA of 150 MW is agreed for grant in Tuticorin
Area. However, no LTA application is received
against potential of 500 MW for which regulatory
approval of 4th ICT at Tuticorin-II PS is sought.
Kurnool 0 0
Anathapur 0 0
*** Application made on 31.03.2021 by Ayana Renewable Power Six Pvt Ltd

d) Implementation of the transmission scheme for Karur/ Tiruppur Wind

Energy Zone (Tamil Nadu) and Gadag may be taken-up on priority as per
phasing and timelines decided during 4th NCT meeting held on 20.01.2021.

e) Regulatory approval may be considered for execution of the proposed

transmission system for Koppal, Gadag, Karur and Tiruniveli/Tuticorin.

f) Further, CTU shall request SECI to coordinate with the concerned

authorities in Karnataka and Tamil Nadu Governments for finalization of the
lands.

g) Matters concerning Bidar in Karnataka and Ananthapur, Kurnool in

Andhra Pradesh and common transmission system strengthening in Southern
region shall be deferred for the present and the Petitioner will file the
necessary pleadings and seek regulatory approval in such places
progressively as and when Stage-II connectivity/ LTA applications mature in
the same manner as in the case of Koppal, Gadag and Karur.

h) The Petitioner sought the details from respective generation project

Order in Petition No. 200/MP/2019 Page 37

 developers (ReNew Surya Ojas Pvt Ltd at Koppal, JSW Renew Energy Ltd at
Karur and Vena Energy Vidyuth Private Limited at Gadag) and status of land
availability for establishment of RE generation projects submitted by the RE
generation applicants at Koppal, Gadag and Karur has been submitted.

i) The Petitioner is proceeding to place these developments in the

meeting of the SRPC and will place before the Commission, the developments
and outcome of the decision in the said meeting.

Submissions of SECI vide affidavit dated 225.2020

36. SECI vide affidavit dated 22.6.2021 has submitted the consolidated updated

information in regard to the location of the identified sub-station for transmission

system for renewable energy project in southern region; the land availability

identified by renewable energy park developer; and priority of transmission system to

be taken up based on land availability and expected LTA (Long Term Access)

Application as under:

Sl. Location Land availability Availability of land Priority of

No. of /identified by RE other than land identified Transmission System
Identified park developer by park developer as to be taken up based on
Sub- station as submitted by submitted by SECI and land availability and
SECI Stage II Connectivity/LTA expected LTA
applications
1 Koppal RE Karnataka Solar RE developers are 900MW Stage -II
Zone, Power acquiring land themselves connectivity and 300 MW
Karnataka Development to set up the projects based LTA already granted.
(2500MW): Corporation Ltd. on awards won by them
(KSPDCL) has through competitive bidding. Application under
confirmed the land process for further 300
availability of A1. Stage-II connectivity MW stage-II Connectivity
13000 acres. The granted: 900 MW & 300 MW LTA
land requirement
for establishment 1. ReNew Surya Ojas Pvt Accordingly, the
of 2500 MW RE is Ltd: 300 MW(start implementation of
estimated around date:15.01 .2022) transmission system for
9,000-10,000 2. Adani Renewable Energy Koppal REZ for 2500 MW
acres only. Holding Fifteen Ltd: 300 is required to be taken-up
MW(start date: 30.12 .2022) on priority.
Therefore, land is 3. Ayana Renewable Power
available as Six Private Ltd: 300 MW
identified by RE (start date:01.08.2022) d
park developer.
A2. Stage-II connectivity

Order in Petition No. 200/MP/2019 Page 38

 The location application under
specific bids for process: 300 MW
some pooling
stations, including 1. Renew Solar Power Pvt.
Koppal PS have Ltd:300MW(start date:
been invited and 30.10.2022)
are in process of
being completed. B1. LTA granted: 300 MW

1.ReNew Surya Ojas Pvt

Ltd- 300 MW(start date:
01.10.2022 or availability of
common transmission
system for LTA whichever is
later)

B2. LTA Application under

process: 300 MW

1. Renew Solar Power

Pvt Ltd 300 MW (Start date:
30.10.2022)

More stage-II
connectivity/LTA are
expected.
2 Gadag RE KSPDCL vide RE developers are 460MW Stage -II
Zone, letter dated acquiring land themselves connectivity already
Kamataka 17.06.2020 has to set up projects based on granted
(2500MW) confirmed the land the award of the project LTA applications under
availability for through competitive bidding. process for 460 MW
8310 acres,
however total land A. Stage-II connectivity Accordingly, the
requirement for granted: 460 MW implementation of
establishment of 1. Vena Energy Vidyuth Pvt transmission system of
2500 MW RE is Ltd:160 MW (start date : phase-I (1000 MW) for
estimated around 01.05.2022) Gadag REZ is required to
9,000 acres. 2. Renew Solar Power Pvt. be taken-up on priority.
Ltd: 300MW(start date: Phase-II (1500 MW) of
The location 30.10.2022) the scheme to be taken
specific bids for up for LTA applications
some pooling B. LTA Application under beyond 1000 MW at
stations including process be taken based Gadag/1500 MW at
Gadaq PS have on total LTA : 460 MW Koppal PS. Part-B to be
been invited and taken based on total
are in process of 1. Vena Energy Vidyuth Pvt LTA applications at
being completed. Ltd: 160 MW(start date: Gadag/Koppal PS.
31.03.2023)

2. Renew Solar Power Pvt.

Ltd: 300MW (start date:
30.10.2022)

More stage II connectivity/

LTA are expected.
3 Karur / No land is RE developers are 460 MW Stage -II
Tiruppur identified for RE acquiring land themselves connectivity & 100 MW
Wind Energy park. The RE against awards won through LTA already granted.
Zone (Tamil developers to competitive bidding.

Order in Petition No. 200/MP/2019 Page 39

 Nadu) arrange land on Accordingly, the
(2500MW) : their own. implementation of phase-
A. Stage-II connectivity I of transmission system
The location granted:460 MW for Karur / Tiruppur PS is
specific bids for 1. JSW Renew Energy Ltd. required to be taken-up
some pooling 310MW(start date: on priority. Phase-II of the
stations have been 31.10.2022) scheme would be taken
invited and are 2. JSW Future Energy Ltd: up after receipt of LTA
also in process 150 MW (start date: beyond 1000 MW.
and it also 31.10.2022)
includes Karur /
Tiruppur PS. B. LTA granted: 100 MW
1. JSW Renew Energy
Ltd:100 MW (start date:
01.06.2022 or availability of
common transmission
system for LTA whichever is
later)

More stage II connectivity/

LTA are expected.
4 Tirunelveli No land is RE developers are Total stage-II
and Tuticorin identified by any acquiring land themselves Connectivity for
Wind Energy RE park developer against awards won through 2259.3MW & LTA for
Zone (Tamil or by State competitive bidding. 1100.1 MW has been
Nadu) Government for granted at Tuticorin.
(500MW) development of Connectivity of 1000.1 MW Further, application for
RE park. & LTA for 950.1 MW enhancement of 40 MW
already operationalized at stage-II Connectivity for
The project Tuticorin. Further, following JSW Renew Energy Ltd
developers will stage-II & LTA has been is under process.
arrange land on granted:
their own. Existing Tuticorin PS has
A. Stage-II connectivity transformation capacity of
The location granted: 1259.2 MW 3x500 MVA.
specific bids for 1.GRT Jewellers (India) Pvt Implementation of 4th
some pooling Ltd:150MW(start 1x500 MVA, 400/230kV
stations have been date:15.12.2021) ICT at Tuticorin would be
invited and are 2.NTPC:230 MW (start taken up after receipt of
also in process date: 01.09.2021) LTA applications beyond
and it also 3.JSW Renew Energy Ltd: 1500 MW.
includes Tuticorin 500MW (start
PS. date:31.10.2022)
4. JSW Future Energy
Ltd:300MW(start date:
31.10.2022)
5.Viento Renewables Pvt
Ltd: 79.2 MW (start date:
15.03.2022)

B. LTA granted: 150 MW

1. GRT Jewellers (India) Pvt
Ltd: 150MW (start date:
01.01.2022)
5 Bidar RE KSPDCL vide RE developers are No application for
Zone (2500 letter dated acquiring land themselves connectivity /LTA is
MW) : 17.06.2020 has against awards won through received at this location.
confirmed the land competitive bidding.
availability for only Implementation of the

Order in Petition No. 200/MP/2019 Page 40

 2885 acres, transmission may be
however total land taken up on receipt of
requirement for Stage-II connectivity
establishment of /LTA.
2500 MW RE is
estimated around
9,000 acres.
6 Kurnool(AP) Government of AP RE developers are No application for
Wind Energy vide letter dated acquiring land themselves connectivity /LTA is
Zone 08.07.2020 against awards won through received at this location.
(2500MW) intimated for land competitive bidding. Implementation of the
availability of transmission may be
Kurnool(AP) 1,00,611 acre. The taken up on receipt of
Wind Energy land availability as Stage-II connectivity /
Zone intimated by State LTA.
(500MW) Government of
and Solar A.P. is much more
Energy Zone than the required
(1500MW) land for
development of
Ananthapur RE capacity.
and Kurnool
SEZ
(Ananthapur-
2500 MW &
Kumool-
1000 MW)

Hearing dated 25.06.2021

37. The Petitioner submitted that, based on information filed by SECI, the

implementation of transmission systems for Koppal REZ and Phase-I of Gadag REZ,

Karur/ Tiruppur PS are required to be taken on priority. For Bidar REZ and Kurnool

REZ, since no application for connectivity/ LTA has been received, implementation of

transmission systems is proposed to be taken up after the receipt of applications for

Stage-II connectivity/ LTA.

38. TANGEDCO submitted that despite the Commission’s direction vide RoP for

the hearing dated 15.04.2021 to conduct SRPC meeting for discussing the

developments and implementation of transmission scheme in phase-wise manner

with constituents of Southern Region and to place on record the minutes of the

meeting, no such meeting has been conducted. TANGEDCO further submitted that:

Order in Petition No. 200/MP/2019 Page 41

 (a) Government of Tamil Nadu has already indicated non-availability of
land for RE projects. As per the affidavit of SECI, for REZs in Tamil Nadu, the
land acquisition has been left to the developers. However, there is no
confirmation from the developers regarding land being firmed up.

(b) These transmission schemes are evolved based on the assessed

potential of RE by NIWE/SECI instead of evolving a proposal based on realistic
developable potential duly considering the land availability, already exploited
potential and other issues including the adequacy of existing intra-State and
ISTS networks.

(c) No all India study compiling the proposals of all three regions (WR, NR
and SR) has been done and the studies which have been undertaken are in
fragmented manner for each of these three regions. Also, the studies
undertaken were on the basis of year 2020-21 scenario on the basis of 19th
Electric Power Survey (‘EPS’) projections. However, considering the fresh
studies ought to be conducted as per revised projections and time horizons
beyond 2023.

(d) As is indicative from the minutes of the 4th NCT meeting, based on the
insistence of PFCCL and SECI citing the grounds of RoW and RE generations
respectively, NCT has agreed for inclusion of two 500 MVA ICTs and LILO of
both 400 KV ckt. of Pugalur-Pugalur (HVDC) line at Karur pooling station
instead of CTU’s original proposal of single 500 MVA capacity under Phase-I
along with LILO of one 400 kV line at Karur. This is not as per the provisions of
the 2018 Transmission Planning Regulations.

39. During the hearing, the Commission directed the Petitioner to co-ordinate with

the secretariat of RPC and directed SRPC to hold the RPC meeting within 15 days

from the date of issuance of RoP in order to discuss the developments and

implementation of the transmission schemes in phase-wise manner with the

constitutes of the Southern Region and the Petitioner was directed to file the minutes

of meeting in this regard. The Commission also directed the Petitioner and SECI to

Order in Petition No. 200/MP/2019 Page 42

furnish the available details regarding acquisition of land by the RE developers in the

States of Tamil Nadu and Karnataka. The Commission further directed the Petitioner

to ensure that any investment be made only after the existing system is utilized.

Additional submissions of TANGEDCO vide affidavit dated 6.7.2021

40. TANGEDCO vide affidavit dated 6.7.2021 has additionally submitted as

under:

a) Land availability is not firmed up / confirmed with the State government

authorities.
b) The proposal is devoid of comprehensive All India study combining the
proposals of all the three regions, ie, Southern Western and Northern regions
and study has been conducted in a fragmented way for each of the three
regions.
c) The adequacy of the existing transmission system (Both ISTS and Intra
state transmission) is not ascertained based on the present network conditions.
d) There is no RE generator / identified beneficiary and neither SECI nor
the Solar / Wind power park developer has applied for LTA with CTU as per
their projections.
e) It is evident from the affidavit dated 29.04.2021 filed by the Petitioner
that a total of 10.5 GW out of the proposed 18.5 GW is put on hold due to non-
receipt of LTA applications. Based on the firmed up generation capacity and
time line of implementation, a fresh study needs to be conducted and a fresh
proposal needs to be approved by the RPC on transmission and concurred by
the RPC.

f) Karnataka Discoms have already fulfilled their RPO and the installed
capacity in the State is 14890 MW against RPO equivalent of 9810 MW and,
hence, none of the Discoms have entered into any PPA to avail the RE power
from the proposed projects. Similarly, TANGEDCO has RE installed capacity of
13029 MW and additional 1000 MW is under implementation and has not
entered into any PPA to avail the RE power from the proposed projects. The
Petitioner has not furnished any data on State-wise installed capacity, RPO and

Order in Petition No. 200/MP/2019 Page 43

possible PPA tie-up with State Discoms in Southern Region, Western Region
and Northern Region for the proposed RE capacity addition of 66.5 GW and
also in the target Region, if any.

g) Under these circumstances, without firm tie-up within the Region or in

any other Region, the investment in the generation projects would become
redundant. In the absence of identified beneficiaries, the inter-regional
transmission schemes would become a National waste and will create
unnecessary operational problems like over voltage issues and idle charging of
major transmission lines. The Indian power sector has already witnessed such
a huge mess in implementing the High capacity power transmission corridors.

h) Under the 2020 Sharing Regulations, the cost of transmission assets

created under NC-RE across the country are shared among DICs in the ratio of
LTA+MTOA quantum. TANGEDCO’s share in NC-RE is in the range of 8.5%-
9% on all India basis. Since there is a huge financial liability fastened on
TANGEDCO on account of these RE assets established across the country
without reaping any benefit, this proposal will cause irreparable damages to
TANGEDCO and its end consumers.

i) It is observed from the minutes of the 4th NCT meeting submitted by

the Petitioner along with the affidavit dated 29.04.2021 that CTU had proposed
to install 1x500 MVA with LILO of one circuit of Pugalur-Pugalur(HVDC) 400 kV
D/c line considering the connectivity requirement of 310MW in the first phase
and also stated that N-1 criteria is not applicable for RE generators. However,
PFCCL and SECI had insisted for 2x500 MVA transformer capacity and LILO of
both the circuits of 400 kV D/c lines citing the reliability and RoW issues and to
attract response of the bidders for substation projects. NCT had accepted the
contentions of PFCCL and SECI and approved the proposal. NCT cannot bend
the provisions of Planning criteria and Regulations to suit the requirements of
the bid process coordinators. These issues should have been deliberated in the
Regional Transmission Planning Committees and the concurrence of the
concerned State Utilities should have been obtained.

Order in Petition No. 200/MP/2019 Page 44

 Information submitted by SECI vide affidavit dated 15.7.2021

41. Respondent No. 18 SECI, vide affidavit dated 15.7.2021, has submitted status

of the land arranged (as per the information received from RE developers) as

follows:

Sl. Name of Location Capacity Quantum of Land (in Acres ) required /Govt.
No. RE & State Granted by CTU order issued or acquired/under process
Developer to RE developers
(MW)

Stage-II LTA Required Acquired under REMARK

Process

1. JSW KARUR/ 270 100 550 256 294

Tamilnadu
2. JSW KARUR/ 150* Yet to 308 52 256
Tamilnadu apply
3 JSW Tuticorin/ 540 540* 1100 368 732
Tamilnadu
4 JSW Tuticorin/ 300* Yet to 610 121 489
Tamilnadu apply
5 GRT Tuticorin/ 150 150 550 220 330
Jewellers Tamilnadu
6. RENEW Koppal/ 300 300 868.24 Under G.O.
Karnataka progress available for
113.55 MW
from KREDL
7 RENEW Koppal/ 300 300* 515.6 Under G.O.
Karnataka progress available for
157.245 MW
from KREDL
8. Ayana Koppal/ 160 Yet to 626 Under 126 acres on
Karnataka apply progress purchase &
520 acres
through lease
9. Adani Koppal/ 300* Yet to - - - Land
Karnataka apply identified and
acquisition
start post
signing of
PPA

Order in Petition No. 200/MP/2019 Page 45

Sl. Name of Location Capacity Quantum of Land (in Acres ) required /Govt.
No. RE & State Granted by CTU order issued or acquired/under process
Developer to RE developers
(MW)

Stage-II LTA Required Acquired under REMARK

Process

10. VENA Gadag/ 160 160* 400 GO Under G.O. issued

Karnataka issued progress 128.7 MW for
entire land
for wind
project for
solar no G.O.
required from
Government
of Karnataka
11. RENEW Gadag/ 300* 300* 557 GO Under G.O.
Karnataka issued progress available for
301.455 MW
from KREDL

Information submitted by the Petitioner vide affidavit dated 28.7.2021

42. The Petitioner vide affidavit dated 28.07.2021 has submitted additional

information mainly as below:

a) As per the directions of this commission, a special meeting of SRPC

was held on 14.07.2021 to discuss development and implementation of the
transmission schemes in phase-wise manner with constitutes of the Southern
Region.

b) During the meeting, CTU proposed transmission system for 10.5 GW

solar & wind energy zones in Southern Region viz. Koppal (2.5 GW), Karur (2.5
GW), Gadag Part-A (2.5 GW), Gadag Part-B (2.5 GW) and Tuticorin-II (0.5
GW)

c) Following was recommended by SRPC in the minutes of the meeting;

(i) Revised study is needed to be carried out by CTUIL in consultation
with CEA based on the 2022-23 scenarios as well as considering
the transmission system planned by STUs.

Order in Petition No. 200/MP/2019 Page 46

 (ii) Impact on the transmission charges of the States due to the
implementation of transmission schemes for integration/ evacuation
of the REZ would be apprised to the States by CTUIL.

(iii) The transmission scheme for integration of REZ, finalised by SRPC

(TP) based on the revised study would be implemented in a
phased manner strictly based on the LTA granted.

d) Regulatory approval may be granted to undertake phase-wise

execution based on receipt of corresponding LTA applications of the
proposed transmission system for 8 GW SEZ and WEZ in Southern Region,
namely, Koppal (2.5 GW), Karur (2.5 GW), Gadag (2.5 GW) and Tuticorin-II
(0.5 GW).

Information submitted by SECI vide affidavit dated 8.9.2021

43. Respondent No. 18, SECI vide affidavit dated 8.9.2021 has submitted the

status of grant of connectivity and LTA at the Pooling Stations in Southern Region

(SR) and the quantum of new capacities concluded in the Competitive Bidding [e-

Reverse Auction (eRA) result] of Hybrid Tranche-IV Scheme and Tranche-XI Wind

Scheme held on 23.08.2021 and 02.09.2021, respectively. The successful bidders in

the said schemes will also avail the facilities of the identified pooling stations as

detailed in the table below:

Project capacity Tender under bidding

Sub-Station
awarded (MW)
KARUR 420
KOPPAL 1800 600 MW RE park tender pre-bid meeting held
and bids yet to be opened a awarded
GADAG 1110 600 MW RE park tender pre-bid meeting held
and bids yet to be opened & awarded
TUTICORIN 1140

TOTAL SR 4470

Order in Petition No. 200/MP/2019 Page 47

Information submitted by the Petitioner vide affidavit dated 15.9.2021

44. The Petitioner vide affidavit dated 15.9.2021 has submitted that a meeting

was held on 11.8.2021 under the chairmanship of Member (Power Systems), CEA

wherein the requirement of the phasing of transmission system associated with

Koppal REZ was also discussed. During the meeting, SECI informed as follows:

“Out of 1200 MW Stage-ll connectivity granted at Koppal P.S., LT A for 600 MW has
already been granted. Discussions for PSA signing with Rajasthan for additional 600
MW is expected to be concluded (by 13.08.2021) and LTA application for the same
shall be submitted to CTU shortly. In addition, the following bids are in pipeline:
(i) 1200 MW Hybrid pan-lndia tender whose e-RA was scheduled in third week
of August’2021
(ii) 1200 MW SECI-XI Wind I STS location specific tender (Gadag,Koppal,
Kallam and Rajgarh) whose e-RA would be scheduled after 1200 MW Hybrid
pan-lndia tender.
(iii) 600 MW Solar Park tender for Koppal.
(iv) 600 MW Solar park tender for Gadag.

It is expected that conclusion of above bids would result in LTA of more than 1500 MW
at Koppal P.S. Accordingly, the bidding may be carried out for Transmission Scheme
for evacuation of total identified potential of 2500 MW for Koppal REZ instead of
phasing the scheme."

45. The Petitioner has submitted that total Stage-ll connectivity of 1200 MW and

LTA of 600 MW has already been granted at Koppal PS. Additionally, application for

grant of Stage-II connectivity for 110 MW has been received by the Petitioner at

Koppal PS in the month of August 2021.

Hearing dated 17.9.2021

46. The matter was heard on 17.9.2021 and the order was reserved. The

Petitioner was directed to furnish certain information and documents on affidavit.

47. In compliance, the Petitioner vide affidavit dated 08.10.2021 has submitted as

under:

Order in Petition No. 200/MP/2019 Page 48

a) Based on the deliberations in the special SRPC meeting held on
14.07.2021 on the implementation of the transmission schemes in phase-wise
manner in the prioritized REZ in SR, CTUIL carried out studies for integration of
8 GW of REZ in Koppal, Gadag, Karur and Tuticorin REZ wherein LTA
applications have been received and same was discussed in the 3rd SRPC (TP)
meeting held on 24.8.2021. Details of the connectivity and LTA granted are as
follows:
REZ Stage-II Connectivity (MW) LTA (MW)
Koppal 1200 600
Gadag 460 460
Karur 420 100
Tirunelveli/ Tuticorin 2220.1 1640*
* LTA of 540 MW granted with 4th ICT at Tuticorin-II PS

b) In the 3rd SRPC (TP) meeting held on 24.8.2021, transmission system

(at Annexure-I of this order) was agreed to be undertaken for phase-wise
implementation based on receipt of corresponding LTA applications for 8 GW
solar & wind energy zones in Southern Region viz. Koppal (2.5 GW), Karur (2.5
GW), Gadag (2.5 GW) and Tuticorin-II (0.5 GW) , as detailed below.

A. Transmission scheme for Evacuation of power from RE sources in Koppal

Wind Energy Zone (Karnataka) (2500MW):
• Establishment of 3x500 MVA, 400/220 kV pooling station near Munirabad
/suitable location in Koppal distt.
• Pooling station (near Munirabad /suitable location in Koppal distt.) - Narendra
(New) GIS 400 kV D/c Line (with Quad Moose ACSR conductor)
• 400 kV GIS line bays at Narendra (new) for Koppal PS- Narendra (New) GIS PS
400 kV D/c line
• 5 Numbers of 220 kV line bays for interconnection of wind projects#
• 2x125 MVAr, 400 kV bus reactor at Pooling station (near Munirabad /suitable
location in Koppal Distt.)
• Space provision for additional future expansion
o Space for future 400kV line bay with switchable line reactor: 6 nos.
o Space for future 400/220kV ICT along with associated bay: 3 nos.
o Space for future 220kv line bay: 7 nos.
Commissioning schedule of 18 months
• Augmentation of 2x500 MVA, 400/220 kV ICTs at pooling station near
Munirabad /suitable location in Koppal distt.
• 4 Numbers of 220 kV line bays for interconnection of wind projects
Commissioning schedule of 24 months.

Order in Petition No. 200/MP/2019 Page 49

B. Transmission scheme for evacuation of power from Gadag SEZ (2500 MW) -
Part A:
Phase-I (1000 MW):
• Establishment of 400/220 kV, 2x500 MVA Gadag Pooling Station
• Gadag PS - Narendra (new) GIS PS 400 kV (high capacity equivalent to quad
moose) D/C Line
• 400 kV GIS line bays at Narendra (new) for Gadag PS- Narendra (New) GIS
PS 400 kV D/c line
• 220 kV line bays for interconnection of solar projects (4 nos)
• 1x125MVAr (400 kV) bus reactor at Gadag PS
• Future provisions * :
o Space for 400 kV Line bay with switchable line reactor: 8 nos.
o 400/220kV ICT along with associated bay: 4 nos.
o 220 kV:
o Bus sectionalizer bay: 2 nos. (One no. bay for each Main Bus)
o Bus coupler bay: 2 nos.
o Transfer Bus coupler bay: 2 nos.
o Space for future 400/220kV ICT bay: 4 nos.
o Space for future line bay: 8 nos.
The schedule of implementation would be matching with schedule of RE
developers or 18 months from the date of transfer of SPV whichever is later.

Phase-II (1500 MW):

• Augmentation of 400/220 kV, 3x500 MVA ICTs at Gadag Pooling Station
• Gadag PS - Koppal PS 400 kV (high capacity equivalent to quad moose) D/C
Line
• 400 kV line bays at Koppal PS for Gadag PS- Koppal PS 400 kV D/c line
• 220 kV line bays for interconnection of solar projects (4 nos)
Phase-II scheme shall be taken up only after receipt of Connectivity/LTA
applications beyond 1000 MW at Gadag or beyond 1500 MW at Koppal P.S.

*Note – Future provisions under Gadag Solar Energy Zone, Karnataka (2500 MW),
Part -A Phase-I (1000 MW) include space provisions for Phase-II (1500 MW) also

C. Transmission Scheme for Evacuation of power from RE sources in Karur/

Tiruppur Wind Energy Zone (Tamil Nadu) (2500 MW):
Phase-I (1000 MW):
• Establishment of 2x500 MVA, 400/230 kV Karur Pooling Station (at a location
in between Karur Wind zone and Tiruppur wind zone)
• LILO of both circuits of Pugalur – Pugalur (HVDC) 400 kV D/c line (with Quad
Moose ACSR Conductor) at Karur PS
• 4 Numbers of 230 kV line bays for interconnection of wind projects
• 2x125 MVAr, 400 kV Bus reactors at Karur PS
• Space provision for Phase-II :
o 400/230kV ICTs along with bays: 3 nos.
o 230kV line bays: 5 nos.
o 230 kV Bus Sectionaliser bays : 2 nos.

Order in Petition No. 200/MP/2019 Page 50

 • Adequate space provision for future expansion for
o 400/230kV ICTs along with bays: 3 nos.
o 400kV line bays: 6 nos.
o 230kV line bays: 7 nos
The schedule of implementation would be matching with schedule of RE
developers or 18 months from the date of transfer of SPV whichever is later.

Phase-II (1500MW):
• Augmentation of 3x500 MVA, 400/230 kV ICTs at Karur PS
• 5 Numbers of 230 kV line bays for interconnection of wind projects
Phase-II scheme to be taken up only after receipt of Connectivity/LTA applications
beyond 1000 MW at Karur.

D. Tirunelveli and Tuticorin Wind Energy Zone (Tamil Nadu) (500 MW):
• Addition of 1x500 MVA, 400/230kV ICTs (4th) at Tuticorin-II GIS sub-station.

c) Regarding mapping of the transmission scheme, CTUIL has submitted

that the overall scope of works required for evacuation of 8 GW REZ in
Southern Region that had been submitted by the Petitioner vide affidavit dated
26.08.2020 remains same. However, for clarity, “400 kV line bays at Narendra
(new) for Gadag PS-Narendra (New) PS 400 kV D/c line” and “400 kV line bays
at Koppal PS for Gadag PS- Koppal PS 400 kV D/c line” have now been
explicitly mentioned under the scope of Phase-I and Phase-II of the
“Transmission Scheme for Solar Energy Zone in Gadag (1000 MW),
Karnataka- Part A” respectively approved in the 4th NCT meeting held on
20.01.2021 & 28.01.2021 as well as MOP gazette dated 19.07.2021.

d) Considering CUF of 20%, tentative renewable power generated per

annum from the RE projects for Phase-I shall be about 8760 MU [Energy in MU
= (5000x0.20x8760) / 103] and for Phase-II, the same shall be about 5256 MU
[Energy in MU = (3000x0.20x8760) / 103].

e) Estimated cost of proposed transmission system is about Rs.1628

crore (Phase-I: Rs.1267 crore and Phase-II: Rs.361 crore). Further, expected
increase in transmission charges per MW for DICs comes to be about Rs.1720
per MW of LTA per month for Phase-I transmission system and about Rs.490
per MW of LTA per month for Phase-II transmission system.

f) Details of the expected increase in transmission charges are as under:

Order in Petition No. 200/MP/2019 Page 51

Sr. REZ Scheme Phase-I Phase-II Total
No.
Potential Cost Levelized Potential Cost Levelized Potential Cost Levelized
(MW) (Rs.crore) (@15%) (MW) (Rs.crore) (@15%) (MW) (Rs.crore) (@15%)
cost cost cost
(Rs.crore) (Rs.crore) (Rs.crore)
1. Koppal 2500 647 97.1 2500 647 97.1
(Karnataka)
2. Gadag 1000 338 50.7 1500 262 39.3 2500 600 90.0
Part-A
(Karnataka)
3. Karur / 1000 245 36.8 1500 99 14.9 2500 344 51.6
Tiruppur
(Tamil Nadu)
4. Tirunelveli 500 37 5.6 500 37 5.6
and
Tuticorin
(Tamil Nadu)
Total 5000 1267 190.1 3000 361 54.2 8000 1628 244.2

g) Following details are submitted towards calculation of increase in

transmission charges:
(i) Total all India LTA quantum (A) (August 2021) = 101904 MW
(ii) RE LTA under waiver (B) = 9800 MW
(iii) Tariff payable by LTA beneficiaries = (A) minus (B) = 92104 MW
(iv) Increase in transmission charges on account of Phase-I:
Rs.190.1/(92104x12) crore = about Rs.1720 per MW of LTA/month
(v) Increase in transmission charges on account of Phase-II:
Rs.54.2/(92104x12) crore = about Rs.490 per MW of LTA/month
(vi) Increase in transmission charges on account of Phase-I and Phase-II:
Rs.244.2/(92104x12) crore = about Rs.2210 per MW of LTA/month

h) Tentative timelines of two phases of the transmission scheme identified

for four REZs are as under:

i)Koppal Wind Energy Zone, Karnataka (2500 MW)

• 3x500 MVA, 400/220 kV ICTs at Koppal PS and 5 Numbers of 220 kV
line bays for interconnection of wind projects - April 2023 (assuming 18
months from considering grant of regulatory approval and award of the
scheme in October 2021)
• Balance 2x500 MVA, 400/220 kV ICTs at Koppal PS and 4 Numbers
of 220 kV line bays for interconnection of wind projects – October 2023

Order in Petition No. 200/MP/2019 Page 52

 (assuming 24 months from considering grant of regulatory approval and
award of the scheme in October 2021)
ii)Gadag Solar Energy Zone, Karnataka (2500 MW), Part -A
• Phase-I - June 2023 (assuming 18 months from considering grant of
regulatory approval in October 2021 and award of the scheme in
December 2021)
• Phase-II - To be taken up only after receipt of Connectivity/ LTA
applications beyond 1000 MW at Gadag or beyond 1500 MW at Koppal
P.S.

iii)Karur/ Tiruppur Wind Energy Zone (Tamil Nadu) (2500 MW)

• Phase-I - June 2023 (assuming 18 months from considering grant of
regulatory approval in October 2021 and award of the scheme in
December 2021)
• Phase-II - To be taken up only after receipt of Connectivity/ LTA
applications beyond 1000 MW at Karur

iv)Tirunelveli and Tuticorin Wind Energy Zone (Tamil Nadu) (500 MW)
• March 2023 matching with the generation schedule (assuming 15
months from considering grant of regulatory approval in October 2021 and
award of the scheme in December 2021)

Analysis and Decision

48. The Petitioner had initially submitted that 18.5 GW solar (10 GW) and wind

(8.5 GW) generation potential is envisaged to be developed in Southern Region

progressively by 2021 in Phase-I and Phase-II. The Petitioner had submitted that

scheme was discussed and agreed in the 35th SRPC meeting and 36th SRPC

meeting held on 02/02/2019 and 12/07/2019, respectively and 4th meeting of

Empowered Committee on Transmission held on 12/07/2019. The Petitioner had

also submitted that the details of the scheme, its justification, estimated cost and its

tariff impact, results of the system studies, study assumptions, stakeholder

consultation/ approval details etc. were published on the Petitioner’s website in terms

of the 2018 Transmission Planning Regulations. The estimated cost of the proposed

transmission system was Rs.9,485 crore. The Petitioner prayed for regulatory

Order in Petition No. 200/MP/2019 Page 53

approval under Regulation 3(1)(i) read with Regulation 8 (Power to Relax) and

Regulation 9 (Power to remove difficulties) of the Regulatory Approval Regulations.

49. The Respondent SECI had supported the proposal of the Petitioner. On the

other hand, the Respondents TANGEDCO, KPTCL, PKCL and TANTRANSCO had

either opposed the proposal of the Petitioner or had suggested several modifications

to be made before implementing the proposed transmission scheme. Primary

opposition of the Respondents were regarding lack of transparency in preparing the

proposal, lack of availability of land, lack of PPAs, uncertain status of generation

projects and lack of applications for LTA/ connectivity by generation projects. There

was also question as to the requirement and demand for such RE power and likely

impact on transmission charges. POSOCO had also submitted its comments,

primarily related to system studies and assumptions therein, to the Petitioner when

the same was uploaded on the website of the Petitioner.

50. Several hearings were held in the matter and views of the Petitioner and the

Respondents were taken on record. During the period of pendency of this petition, a

number of meetings were also held at various levels to discuss the issues involved in

the Petition. The Commission, through record of proceedings of hearings, sought

various information and the same were submitted by the Petitioner, SECI and other

respondents. As these have been reproduced in the earlier part of the order above,

the same are not repeated for sake of brevity.

51. During the hearing dated 25.06.2021, the Commission directed the Petitioner

to co-ordinate with the SRPC secretariat and also directed SRPC to hold the RPC

meeting with the constituents of the Southern Region within 15 days from the date of

Order in Petition No. 200/MP/2019 Page 54

issuance of RoP of the hearing, to work out the phase-wise implementation of the

transmission schemes. The Petitioner was directed to file the minutes of meeting in

this regard. The Commission also directed the Petitioner and SECI to furnish the

details of available land and acquisition of land by the RE developers in the States of

Tamil Nadu and Karnataka. The Commission further directed the Petitioner to plan

the transmission system in a manner so as to ensure that any investment be made

only after the existing system is utilized.

52. In accordance with the above directions, the Petitioner vide affidavit dated

28.07.2021, has submitted that it is now seeking regulatory approval to undertake

phase-wise execution of transmission system for only 8 GW based on receipt of

corresponding LTA applications in the solar and wind energy zones in Southern

Region, namely, Koppal (2.5 GW), Karur (2.5 GW), Gadag (2.5 GW) and Tuticorin-II

(0.5 GW). The Petitioner has submitted that the estimated cost of proposed

transmission system is about Rs.1,628 crore (Phase-I: Rs.1,267 crore and Phase-II:

Rs.361 crore).

53. The Petitioner has subsequently submitted that it has discussed the proposed

revised scheme for 8 GW (revised from erstwhile proposal of 18.5 GW) in the 3rd

SRPC (TP) meeting held on 24.08.2021 and the scheme was agreed to be

undertaken for phase-wise implementation based on receipt of corresponding LTA

applications.

54. We observe that after a number of hearings in the matter over a period of two

years, on the persistent queries of constituents in various RPC meetings and in the

hearings of the Commission and on the analysis of various factors including

Order in Petition No. 200/MP/2019 Page 55

availability of land, comprehensive All India study and applications for LTA as

directed by the Commission, CTUIL has finally scaled down the proposal of

transmission system for regulatory approval from 18.5 GW to 8 GW.

55. We are of the view that this scaling down of the proposal of transmission

system for regulatory approval from 18.5 GW to 8 GW raises a serious question

mark on the entire process of transmission planning and approval. In our view, there

was gross lack of due diligence by statutory planning agencies such as CTUIL and

intermediary agency like SECI and the competent authority which approved the

scheme for the 18 GW. The basic ingredients of planning, namely availability of land,

applications for LTA, comprehensive All India study and respecting the view-points of

stakeholders, especially those who finally bear the cost of the transmission system

through transmission charges were conveniently neglected and overlooked. It was

the persistent nudging by the Commission and repeated voicing of concerns of the

stakeholders that led these agencies to accept the reality, albeit reluctantly, and

revise the scheme downwards.

56. We observe that the estimated cost of the originally proposed 18.5 GW

transmission system was Rs.9,485 crore, whereas the estimated cost of the scaled

down transmission system of 8 GW is only Rs.1,628 crore. Thus, because of scaling

down of the transmission system to 8 GW, the expected additional annual

transmission charges would be substantially lower than what would have been with

the transmission system of 18.5 GW. Thus, had the Commission not taken the view

that it took, the consumers would have been unnecessarily burdened with additional

Order in Petition No. 200/MP/2019 Page 56

transmission charges and there would have been un-necessary capital expenditure

incurred and in addition, there could have been stranded assets.

57. At this juncture, it is pertinent to consider the direction issued by the Ministry

of Power, Government of India, vide letter ref. 25-11/2/2019-PG dated 11.7.2019

under Section 107 of the 2003 Act. Section 107 of the 2003 Act is extracted under:

“Section 107. (Directions by Central Government): (1) In the discharge of its

functions, the Central Commission shall be guided by such directions in
matters of policy involving public interest as the Central Government may give
to it in writing. (2) If any question arises as to whether any such direction
relates to a matter of policy involving public interest, the decision of the
Central Government thereon shall be final.”

58. Therefore, in matters of policy involving public interest, the Commission is

guided by the directions issued by the Central Government under the said section.

Similar provisions are contained in Section 108 of the 2003 Act. With regard to the

directions of the State Government under Section 108 of the 2003 Act, we also like

to take note of the observations of the Appellate Tribunal in its judgment dated

4.10.2012 in Appeal No. 200 of 2011 (M/s Maruti Suzuki India Ltd. vs Haryana

Electricity Regulatory Commission & Ors.) as under:

“28. Section 78A of Electricity (Supply) Act 1948 and Section 12 of DERA 2000 were
similar to Section 108 of the 2003 Act. These sections are set out as under:

Section 108 of the Electricity Act, 2003

108. Directions by State Government.—(1) In the discharge of its functions, the State
Commission shall be guided by such directions in matters of policy involving public
interest as the State Government may give to it in writing.
(2) If any question arises as to whether any such direction relates to a matter of
policy involving public interest, the decision of the State Government thereon shall
be final.

29. The Hon’ble Supreme Court in the case of APTRANSCO vs Sai Renewable
Energy Pvt. Ltd. [(2011)11SCC 34] has held that State Commission is not bound by
any policy directions issued by the Government under the Act if such directions

Order in Petition No. 200/MP/2019 Page 57

hamper the statutory functions of the Commission. The relevant extracts of the
Hon’ble Supreme Court’s judgment dated 8.7.2010 is quoted below:

“27. The Reform Act, 1998 was enacted, primarily, with the object of
constituting two separate corporations; one for generation and other for
transmission and distribution of electrical energy. The essence was
restructuring, so as to achieve the balance required to be maintained in regard
to competitiveness and efficiency on the one part and the social objective of
ensuring a fair deal to the consumer on the other. This Act is also intended for
creation of a statutory regulatory authority. Section 3 of the Act requires the
State Govt. to establish by notification a Commission to be known as Andhra
Pradesh Electricity Regulatory Commission. This was done by notification
dated 3rd April, 1999. As already noticed, Section 11 detailed the functions of
the Regulatory Commission and primarily it had advisory as well as regulatory
functions. In terms of Section 11(1)(c) it was required to issue licenses in
accordance with the provisions of the Act and determine the conditions to be
included in the license. However, 11(1)(e) gave it much wider power and duty
to regulate the purchase, distribution, supply and utilization of electricity, the
quality of service, the tariff and charges payable keeping in view both the
interest of the consumer as well as the consideration that the supply and
distribution cannot be maintained unless the charges for the electricity supplied
are adequately levied and duly collected. In terms of Section 11(1)(l) it was to
undertake all incidental or ancillary things to the functions assigned to it under
the provisions of the Act. Section 12 of the Act vests the State Govt. with the
power to issue policy directions on matters concerning electricity in the State
including the overall planning and co- ordination. All policy directions shall be
issued by the State Govt. consistent with the objects sought to be achieved by
this Act and, accordingly, shall not adversely affect or interfere with the
functions and powers of the Regulatory Commission including, but not limited
to, determination of the structure of tariffs for supply of electricity to various
classes of consumers. The State Govt. is further expected to consult the
Regulatory Commission in regard to the proposed legislation or rules
concerning any policy direction and shall duly take into account the
recommendation by the Regulatory Commission on all such matters. Thus the
scheme of these provisions is to grant supremacy to the Regulatory
Commission and the State is not expected to take any policy decision or
planning which would adversely affect the functioning of the Regulatory
Commission or interfere with its functions. This provision also clearly implies
that fixation of tariff is the function of the Regulatory Commission and the State
Govt. has a minimum role in that regard. Chapter VII of this Act deals with tariff.
In terms of Section 26(2), the Regulatory Commission, in addition to its power
of issuing licence, is entitled to fix terms and conditions for determination of the
licensee's revenue and tariffs by regulations which are to be duly published.
The expression 'tariff' has not been defined in any of the Acts, with which we
are concerned in the present appeals, despite the fact that the expression 'tariff'
has been used repeatedly in both the Acts. Under the Electricity Act, 2003
'tariff' has neither been defined nor explained in any of the provisions of the Act.
Explanation (b) to Section 26 of the Reform Act, 1998 states what is meant by
'tariff'. This provision states that 'tariff' means a schedule of standard price or

Order in Petition No. 200/MP/2019 Page 58

 charges or specified services which are applicable to all such specified services
provided to the type or types of customers specified in the 'tariff' notification.
This is an explanation to Section 26 which deals with licenses, revenues and
tariffs. In other words, this explanation may not be of greater help to the Court
in dealing with the case of generating companies. Similarly, the expression
'purchase price' has neither been defined nor explained in any of the afore-
stated Acts.” {Emphasis added}.

30. Thus, the judgments cited by the Appellant as above have been overruled by the
Hon’ble Supreme Court in APTRANSCO vs Sai Renewable Energy Pvt. Ltd.
[(2011)11SCC 34].

31. Further, this Tribunal in Polyplex Corporation vs Uttrakhand Electricity

Regulatory Commission in Appeal no. 41, 42 and 43 of 2010 has held that

“The State Commission is independent statutory body. Therefore the policy

directions issued by the State Government are not binding on the State
Commission, as those directions cannot curtail the power of the State
Government (sic Commission) in the matter of determination of tariff. The State
Government may have given any such policy direction in order to cater to the
popular demand made by the public but while determining tariff the State
Commission may take those directions or suggestions for consideration but it is
for the State Commission which has statutory duty to perform either to accept
the suggestion or reject those directions taking note of the various
circumstances. It is purely discretionary on the part of the State Commission on
acceptability of the directions issued by the State Government in the matter of
determination of tariff.”

59. We observe that SECI, vide affidavit dated 22.6.2021, has submitted status of

land availability at the proposed locations for scaled down 8 GW as follows:

(a) Koppal - Karnataka Solar Power Development Corporation Ltd.

(KSPDCL) has confirmed the land availability of 13,000 acres. The land
requirement for establishment of 2,500 MW RE is estimated around 9,000-
10,000 acres only.

(b) Gadag - KSPDCL vide letter dated 17.06.2020 has confirmed the land
availability for 8,310 acres. However, total land requirement for establishment
of 2500 MW RE is estimated around 9,000 acres. Further RE developers are
acquiring land themselves to set up the projects based on awards won by them
through competitive bidding.

Order in Petition No. 200/MP/2019 Page 59

 (c) At Karur and Tirunelveli/ Tuticorin, no land is identified for RE park and
the RE developers shall themselves arrange land.

60. The Petitioner is seeking from the Commission the Regulatory Approval for

the transmission system as given in paragraph 47(b) above under the provisions of

Regulation 3(1)(i) of the Regulatory Approval Regulations. The relevant provisions

of Regulation 3 are extracted under:

“3. Scope and applicability

(1)These regulations shall apply to:
(i) an ISTS Scheme proposed by Central Transmission Utility, for which
generators have sought long-term access as per the Central Electricity
Regulatory Commission (Grant of Connectivity, Long-Term Access and Medium
Term Open Access to the Inter-State Transmission and Related Matters)
Regulations, 2009, and for which consultation with Central Electricity Authority
and beneficiaries if already identified has been held for setting up the ISTS
Scheme, but for which Power Purchase Agreements with all the beneficiaries
have not been signed on the date of application.
(ii) an ISTS Scheme for system strengthening/up-gradation, identified by Central
Transmission Utility to enable reliable, efficient, co-ordinated and economical
flow of electricity within and across the region for which consultation with Central
Electricity Authority and beneficiaries if identified has been held.
(iii) ISTS Scheme proposed by CTU, for which the Central Government
authorised Solar Power Park Developer has sought long term access, and for
which consultation with CEA and beneficiaries wherever identified has been
held for setting up the ISTS scheme and the Solar Power Park Developer
undertakes to bear all liabilities on behalf of the solar power generators to be set
up in the Solar Park.

(2)These regulations shall not apply to ISTS Scheme, for which all the beneficiaries/
respective STUs have signed Bulk Power Transmission Agreement to share the
transmission charges.”

61. Regulation 3(1)(i) provides that the Regulatory Approval Regulations shall

apply to the ISTS scheme proposed by the Petitioner for which the generators have

sought LTA. However, for the identified transmission system proposed to be

constructed by the Petitioner, full quantum of LTA has not been sought by the

generators.

58. The Petitioner vide affidavit dated 08.10.2021 has submitted the details of

location-wise Connectivity and LTA granted as under:

Order in Petition No. 200/MP/2019 Page 60

 Capacity Stage-II Connectivity LTA
REZ (MW) (MW)
Koppal 2.5 GW 1200 600
Gadag 2.5 GW 460 460
Karur 2.5 GW 420 100
Tirunelveli/ Tuticorin 0.5 GW 2220.1 1640*
* LTA of 540 MW granted with 4th ICT at Tuticorin-II PS

62. The Petitioner has submitted the estimated cost of proposed transmission

system for 8 GW REZ is about Rs.1,628 crore (Phase-I: Rs.1267 crore; Phase-II: Rs.

361 crore). Further, expected increase in transmission charges per MW for DICs

comes out to be about Rs.1,720 per MW of LTA per month for Phase-I transmission

system and about Rs.490 per MW of LTA per month for Phase-II transmission

system. The Petitioner has submitted that considering CUF of 20% in case of RE

projects, tentative renewable power generated per annum from such RE projects for

Phase-I shall be about 8760 MU and for Phase-II, the same shall be about 5256 MU.

The Petitioner has also submitted the implementation plan for proposed transmission

system at each location along with tentative timelines of two phases of the

transmission scheme identified for REZs at the proposed four locations.

63. As noted above, the prayers of the Petitioner in the instant Petition for grant of

Regulatory approval does not squarely fall under the provisions of Regulation 3(1)(i)

of the Regulatory Approval Regulations since LTA for capacity has not been sought

by generators. However, the Petitioner during hearing on 21.8.2019 prayed to

exercise the Power to relax under Regulation 8 of the Regulatory Approval

Regulations.

64. With due regard to the guiding principle of promoting renewable energy as

enshrined under Section 61(h) of the Act, we, in exercise of our Powers under

Order in Petition No. 200/MP/2019 Page 61

Regulation 8 of the Regulatory Approval Regulations, relax the provisions of

Regulation 3(1)(i) of the Regulatory Approval Regulations and grant Regulatory

approval for execution of the proposed transmission system (along with proposed

timelines and phasing) for 8 GW as given in Annexure-I to this order.

65. Having done so, the issues and concerns expressed by the Respondents and

other stakeholders are also required to be balanced while granting such relief. The

Commission is guided by the principles, as provided under Section 61(d) of the Act

i.e. safeguarding of consumer’s interest and at the same time, recovery of the cost

of electricity in a reasonable manner. Thus, the Commission has a statutory

responsibility to balance the interest of developers and consumers of electricity.

66. In view of above, it is directed that Petitioner shall ensure that the

transmission system is taken up for implementation matching with progress of

generation projects. We observe from various minutes of meetings of SRPC,

SRSCT, NCT and ECT that the transmission schemes are agreed for

implementation after receipt of LTA. The recovery of transmission charges as well

as treatment of mismatch between COD of generating station and transmission

system shall be governed by provisions of the Central Electricity Regulatory

Commission (Sharing of inter-state transmission charges and losses) Regulations,

2020 as amended from time to time. The regulatory approval granted in this order is

subject to the condition that the distribution companies and consumers shall be

liable for payment of transmission charges after the renewable generating stations

achieve COD. In case the generating stations as envisaged do not materialize and

transmission system is commissioned, CTUIL may seek appropriate remedies such

Order in Petition No. 200/MP/2019 Page 62

as grants and/or subsidies from GOI/ State Governments till the associated

generating stations achieve COD. CTUIL may also approach the Commission for

appropriate relief and directions.

67. CTUIL shall submit quarterly progress report as regards execution of the

transmission scheme to the Ministry of Power, GOI and CEA. The report shall

contain pace of construction of transmission systems and the extent of LTAs

granted and PPAs signed.

68. Petition No. 200/MP/2019 is disposed of in terms of the above. The Annexure-I

given herein after shall for part of the order.

Sd/ Sd/ Sd/

(P. K. Singh) (Arun Goyal) (P.K. Pujari)
Member Member Chairperson

CERC Website S. No. 578/2021

Order in Petition No. 200/MP/2019 Page 63
 Annexure-I
i) Transmission scheme for Evacuation of power from RE sources in Koppal Wind
Energy Zone (Karnataka) (2500MW)

• Establishment of 3x500 MVA, 400/220 kV pooling station near Munirabad /suitable

location in Koppal distt.
• Pooling station (near Munirabad /suitable location in Koppal distt.) - Narendra (New) GIS
400 kV D/c Line (with Quad Moose ACSR conductor)
• 400 kV GIS line bays at Narendra (new) for Koppal PS- Narendra (New) GIS PS 400 kV
D/c line
• 5 Nos of 220 kV line bays for interconnection of wind projects#
• 2x125 MVAr, 400 kV bus reactor at Pooling station (near Munirabad /suitable location in
Koppal Distt.)
• Space provision for additional future expansion
o Space for future 400kV line bay with switchable line reactor: 6 nos.
o Space for future 400/220kV ICT along with associated bay: 3 nos.
o Space for future 220kv line bay: 7 nos.
Commissioning schedule of 18 months

• Augmentation of 2x500 MVA, 400/220 kV ICTs at pooling station near Munirabad /suitable
location in Koppal distt.
• 4 Nos of 220 kV line bays for interconnection of wind projects
Commissioning schedule of 24 months.

ii) Transmission scheme for evacuation of power from Gadag SEZ (2500 MW) - Part A :

Phase-I (1000 MW) :

• Establishment of 400/220 kV, 2x500 MVA Gadag Pooling Station

• Gadag PS - Narendra (new) GIS PS 400 kV (high capacity equivalent to quad moose)
D/C Line
• 400 kV GIS line bays at Narendra (new) for Gadag PS- Narendra (New) GIS PS 400
kV D/c line
• 220 kV line bays for interconnection of solar projects (4 nos)
• 1x125MVAr (400 kV) bus reactor at Gadag PS
• Future provisions * :
o Space for 400 kV Line bay with switchable line reactor: 8 nos.
o 400/220kV ICT along with associated bay: 4 nos.
o 220 kV:
o Bus sectionalizer bay: 2 nos. (One no. bay for each Main Bus)
o Bus coupler bay: 2 nos.
o Transfer Bus coupler bay: 2 nos.
o Space for future 400/220kV ICT bay: 4 nos.
o Space for future line bay: 8 nos.

Order in Petition No. 200/MP/2019 Page 64

 The schedule of implementation would be matching with schedule of RE developers or 18
months from the date of transfer of SPV whichever is later.

Phase-II (1500 MW):

• Augmentation of 400/220 kV, 3x500 MVA ICTs at Gadag Pooling Station

• Gadag PS - Koppal PS 400 kV (high capacity equivalent to quad moose) D/C Line
• 400 kV line bays at Koppal PS for Gadag PS- Koppal PS 400 kV D/c line
• 220 kV line bays for interconnection of solar projects (4 nos)
Phase-II scheme shall be taken up only after receipt of Connectivity/LTA applications
beyond 1000 MW at Gadag or beyond 1500 MW at Koppal P.S.

*Note – Future provisions under Gadag Solar Energy Zone, Karnataka (2500 MW), Part -A
Phase-I (1000 MW) include space provisions for Phase-II (1500 MW) also

iii) Transmission Scheme for Evacuation of power from RE sources in Karur/ Tiruppur
Wind Energy Zone (Tamil Nadu) (2500 MW) :

Phase-I (1000 MW) :

• Establishment of 2x500 MVA, 400/230 kV Karur Pooling Station (at a location in

between Karur Wind zone and Tiruppur wind zone)
• LILO of both circuits of Pugalur – Pugalur (HVDC) 400 kV D/c line (with Quad Moose
ACSR Conductor) at Karur PS
• 4 Nos. of 230 kV line bays for interconnection of wind projects
• 2x125 MVAr, 400 kV Bus reactors at Karur PS
• Space provision for Phase-II :
o 400/230kV ICTs along with bays: 3 nos.
o 230kV line bays: 5 nos.
o 230 kV Bus Sectionaliser bays : 2 nos.
• Adequate space provision for future expansion for
o 400/230kV ICTs along with bays: 3 nos.
o 400kV line bays: 6 nos.
o 230kV line bays: 7 nos
The schedule of implementation would be matching with schedule of RE developers or 18
months from the date of transfer of SPV whichever is later.

Phase-II(1500MW) :

• Augmentation of 3x500 MVA, 400/230 kV ICTs at Karur PS

• 5 Nos. of 230 kV line bays for interconnection of wind projects
Phase-II scheme to be taken up only after receipt of Connectivity/LTA applications beyond
1000 MW at Karur.

iv) Tirunelveli and Tuticorin Wind Energy Zone (Tamil Nadu) (500 MW):
Addition of 1x500 MVA, 400/230kV ICTs (4th) at Tuticorin-II GIS sub-station.

Order in Petition No. 200/MP/2019 Page 65