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India Energy Storage Alliance (IESA), a leading alliance working in the space of energy storage, electric vehicle, renewable integration & microgrids has submitted its comments/recommendations on the proposed Draft Electricity (Amendment) Bill, 2020 recently.

The recommendations submitted to the Ministry of Power (MoP) has been put forward by consulting over 100+ energy storage ecosystem players from IESA. The proposed amendment has tried to addressed series of challenges facing the sector and provided measures to improve regulatory discipline, private sector participation, next-gen reforms, financial health of DISCOMs and given a thrust on the renewable energy sector among others.

Debi Prasad Dash, Executive Director, India Energy Storage Alliance (IESA), pointed out, “IESA welcomes the amendment in the Electricity Act, 2003 by the MoP. We have proposed the ministry to have a clear policy framework regarding energy storage in the act. India has emerged as one of the fastest-growing markets for renewable energy and energy storage technologies could be the key enabler for RE integration and grid stability. Defining energy storage under the electricity act could be helpful to start ancillary services & frequency regulation through energy storage as a flexible asset. It will also help to enable electric vehicles (EV) charging infrastructure, V2G concepts and microgrids integration with expanded grid connectivity in the long run. We hope the ministry will consider IESA’s recommendations to make the Indian electricity grid more resilient and reliable.”

The Draft Electricity (Amendment) Bill, 2020 was floated by the MoP, Government of India, on April 17, 2020, to amend the Electricity Act. The MoP had requested the stakeholders to provide their comments/suggestions on the draft bill within 21 days from the date of release of the draft bill which later got extended to June 5, 2020. IESA is happy to support and will be actively engaged with the Ministry, whenever required to create a robust power sector that will support the push towards rapid development and self-reliance.

However, several current issues and technology developments in the recent years were majorly missing from the amendment. IESA highlighted these issues and recommendations in their submission on behalf of the energy storage and electric vehicle industry. Some top IESA suggestions on the proposed bill are as follows:

1. Defining Energy Storage – IESA has recommended to define energy storage appropriately in the Electricity Act. The definition should factor in flexible nature and applications, and its categorisation as generation, transmission and/or distribution asset.

2. Mentioning National Energy Storage Mission/Policy in the Act –The policy for energy storage sector has evolved over the past few years in India and there is expected to be significant performance improvement in energy storage technologies and cost reduction over the next decade. With MNRE releasing multiple tenders that include storage and with National Mission on Transformative Mobility and Battery Storage looking to set up 50 GWh advanced energy storage manufacturing capacity, it is highly recommended to include direction from the Electricity Act to frame policy framework required for adopting storage technologies in suitable areas.

3. Storage Purchase Obligation – Instead of a Hydro Purchase Obligation which includes a significant environment and operational limitation, Storage Purchase Obligation (SPO) should be advocated. SPO can comprise of various existing and emerging cost-effective solutions that provide appropriate flexibility.

DISCOMs should be free to choose a specific form of procurement, either hybrid RE + storage or RE and storage independently.

4. Power Quality – It should be the duty of every supply licensee to ensure power quality (covering voltage, harmonics, frequency, surges, etc.) as per norms prescribed by the relevant authority. The licensee shall be allowed to offer different qualities at different price points subject to regulatory approval as well as meeting a minimum power quality as mandated. Power quality might require the creation of new services and markets, such as ancillary services, and these need to be enabled by the relevant authorities within 2 years.

5. Control of Transmission and Use of Electricity –There shall be automatic exemptions for allowed micro-grids, renewable generation, back-up power, energy storage, electric vehicles, as well as other allowed uses as added to this list from time to time [by the Central or State Electricity Regulatory Commission(s)].

6. Smart Grids –. Building upon the National Smart Grid Roadmap released by MoP, all states shall produce roadmaps to enable the following: Consumer production participation, renewable energy integration (subsidies, feed-in-tariffs or generation-based incentives), future grid connectivity with micro-grids, EV (V2G and charging infra integration with utilities), differentiated supply (time of use, guaranteed supply, power quality, demand response or dynamic load management.

7. Allow the Aggregation of Open Access Electricity, and Access to Renewable Energy – Section 42 of the Electricity Act provides a minimum threshold on contract demand, this should be removed especially for EV charging when the aggregated contract demand is more than 1 MW. Currently the policy allows for open access to avail RE within the state only after paying the cost component to DISCOMs as fixed by SERC, this clause should be relaxed as market forces would then ensure competition and drive in systemic efficiency.

8. Inclusion of Missing Definitions in Electricity Act – The Electricity Act should define terms which are used widely in the Act but remain undefined, such as Renewable Energy, Net metering, Cogeneration, Storage, Energy banking, Must-run status, Renewable Energy Certificate, Reliability, Flexibility, Grid Balancing.

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