ISLAMABAD: Uch Power Company Limited has voiced its opposition to NEPRA’s plan to include it in the National Transmission and Despatch Company’s (NTDC) proposed Operating Reserve Policy. In comments submitted on the matter, Uch Power argues that their Power Purchase Agreements (PPAs), classified as Legacy Contracts under the Grid Code 2023, should be exempt from the new policy due to inconsistencies between the Grid Code and their agreements.
Uch Power claims that the policy conflicts with their PPAs and cites pending exemption applications submitted to the Grid Code Review Panel (GCRP) on March 21 and September 5, 2023. They believe the policy should not be enforced until the GCRP makes a decision on these application
The power company has adopted this stance in its comments in the matter of operating reserve policy submitted by the NTDC.
According to M/s Uch, the Operating Reserve Policy is derived from OC 5.4.13 of the Grid Code 2023. It has consistently been the position of the Companies that their Power Purchase Agreements (PPAs), which are categorized as Legacy Contracts under the Grid Code, are exempt from the application of the Grid Code 2023, particularly in cases where there are inconsistencies or conflicts between the PPA and the Code.
The power company is of the view that in this instance, there are clear conflicts between the provisions of the Grid Code 2023 and the Operating Reserve Policy itself, which acknowledges these inconsistencies. Therefore, the policy cannot be applied to the Companies as it conflicts with their PPAs.
Additionally, , as per NEPRA’s determination of March 21, 2023, and NTDC’s request
of September 5, 2023, the Companies submitted exemption applications to the Grid Code Review Panel (GCRP). These applications sought exemptions from the provisions of the Grid Code 2023, including OC 5.4 related to the Operating Reserve Policy.
” The applications are still pending before the GCRP, and we believe that the draft Operating Reserve Policy cannot be enforced on the Companies until the GCRP reaches a decision on the pending applications, ” said, Arif Chaudhry, Senior Manger Engineering Uch in his letter to Registrar NEPRA.
He said that the draft Operating Reserve Policy notes that its application will result in deviation of actual delivered energy from Dispatch instructions” and that there is “no downward compensation of net dispatch & delivered energy and CPPA-G (will) charge liquidity damages in case dispatch level is below instructed limits.” The policy further notes that this issue will be resolved by CPPA-G through amendments in the respective PPAs after the Operating Reserve Policy is approved. In our view, the policy should not be approved until these significant concerns related to existing PPAs are addressed, as the
policy will be ineffective and unimplementable if not first reconciled with existing
agreements.
The power company has also given a reference according to which Operating Reserve Policy subsection 2.1 Frequency Control Description para (b) the Active Power Frequency Response shall be capable of having a Governor Droop between 2% and 12%. whereas Uch PPA Schedule 5 Technical Limits, subsection 1.3 c the governor droop is adjustable in the range of 2.0% to 8.0% with droop characteristics ±0.5%.
The frequency ranges are provided in Operating Reserve Policy but nothing is mentioned about grid voltage levels, in fact during grid disturbance with sharp changes
in grid frequency causes huge voltage fluctuations resulting in over fluxing of
generating units and consequently tripping.
” We suggest NTDC discuss and re-verify numbers for all plants which are declared as
having reserve capacity. These operating reserves may not be applicable on Uch/Uch-II Power (Pvt.) Limited, ” Mr. Chaudhry added. Ends
