Improve the rules to connect more and faster - Rule-maker’s and system operator’s views

By Yannick Phulpin, Rainer Korte, Samir Saxena, Rabindra Nath Shaw

In November 2024, CIGRE launched Working Group C5.39, convened by Dr Rabindra Nath Shaw, to investigate and benchmark the regulatory arrangements for non-firm grid connection in a diversity of jurisdictions.

Complementary to this ongoing work, four executive professionals accepted to share their experience and ideas to realize the energy transition as fast, affordable, and fair as possible. The interview was conducted to complement the activities of WG C5.39 by presenting diverse expert viewpoints on non-firm grid access. It is not intended to promote or endorse any specific organisation or commercial interest.

This article presents the views of Rainer Korte, Commissioner with the Australian Energy Market Commission, and Samir C. Saxena, Chairman of Grid Controller of India. The next Issue of Electra will present the view of Alex Boyd, President and CEO of the PSC Group, and Arne Wohlschlegel, President and Managing Director of SIEMENS Energy Canada.

Y. Phulpin: Rainer, Australia has a long experience of non-firm grid connection. How has the regulation of non-firm connection developed?

R. Korte: The National Electricity Market on the East Coast of Australia is a zonal energy-only electricity market with security-constrained central dispatch. Open-access arrangements mean that network connections are essentially non-firm, as transmission-scale generation assets are exposed to local dispatch prices and dispatched depending on network availability. Asset owners must forecast the likelihood of network congestion and anticipate future developments that may impact congestion when developing their business cases.

The replacement of ageing coal plants and the increasing penetration of wind and solar resources (for example, the state of South Australia, with a population of nearly 2 million people and a gigawatt-scale power system, generates 75% of its annual electricity demand from wind and solar resources, and at times is powered entirely by rooftop solar) are leading to growing network congestion and the need for transmission investment.

Y. Phulpin: Samir, the India power system includes 176 GW of wind and solar and must connect an additional 216 GW by 2030. How do you address this challenge?

Samir C. Saxena: Since renewable projects get built much faster than transmission, India's primary approach is to proactively plan transmission based on RE potential. This forward planning approach ensures timely availability of transmission and allows us to grant firm access to the new plants. However, whenever generation outpaces transmission development, we ensure that the power is evacuated to the extent possible by providing non-firm access. Now, we have started granting firm access to complementary technologies on shared transmission infrastructure —for instance, a solar plant during the day and a wind or battery storage plant at night - to optimize transmission utilization.

To accelerate the energy transition and make it affordable, India has developed the General Network Access reform in 2022. It defines two categories of users: existing assets and new users that go through the conventional connection process benefit from a General Network Assets (GNA). Users can also opt for a connection with Temporary-General Network Access (T-GNA), which means they will have less priority of dispatch than GNA grantees during specific periods called “solar hours”.

Y. Phulpin: How did you operationalize non-firm grid access to mitigate the risk for investors?

R. Korte: One challenge is to ensure that network development keeps pace with the growth of new connections. The Integrated System Plan, prepared by the Australian Energy Market Operator (AEMO) serves as a roadmap for the Australian energy transition and sets out an optimal development path, including major transmission investments required, to meet customer demand and federal and state government emissions reduction targets.

Other measures to improve locational investment signals and reduce congestion have included the publication of enhanced locational information by AEMO to enable developers to undertake comprehensive congestion studies as part of their financial due diligence, as well as the development of Renewable Energy Zones (targeted geographical areas intended to guide and concentrate new renewable energy investment). Renewable Energy Zones introduce strong coordination between network development and new generation assets, which provides greater assurance of sufficient export capacity to the generators hosted within the REZ. They thus face a lower risk of congestion due to a shortage in export capacity.

Developers are also increasingly managing congestion risk and improving operational efficiency by developing hybrid projects that include battery energy storage.

Samir C. Saxena: India has operationalized non-firm grid access through its General Network Access (GNA) regulations, which mitigate risk by prioritizing regulatory certainty and transparent, predictable rules. The framework defines two distinct access products: General Network Access (GNA) which provides long-term rights for periods of more than eleven months, while Temporary GNA (T-GNA) offers short-term flexibility for periods from a single time-block (15-minute) up to 11 months. For day-ahead scheduling, GNA transactions have the highest priority, followed by T-GNA and market transactions. This is strengthened by a detailed real-time curtailment priority, where T-GNA is curtailed before GNA, and conventional generation is curtailed before renewables within each category. The framework provides an ex-ante curtailment signal, informing grantees of their allocated corridor on the day before dispatch (D-1) and the priority. This is complemented by innovative rights like "Solar and Non-Solar Hour Access" to structurally reduce congestion risk and optimize transmission utilization.

Y. Phulpin: Both systems feature a different approach to balance simplicity and efficiency. How do you maximize equity between network users?

R. Korte: The security-constrained central dispatch and open access arrangements place existing and new users on an equal footing. It means that all asset owners must consider congestion risks at all stages of their asset's lifetime. Maintaining a clear, transparent, and unbiased network planning and development process is crucial for fostering users’ trust, mitigating risk, and ensuring fairness.

Improving the visibility and market participation of price-responsive resources, including household solar, batteries, and flexible load, is also critically important for efficiency and to deliver the overall lowest cost outcomes.

S.C. Saxena: In the Indian framework, equity between network users is maximized by ensuring all participants have transparent access to a clear set of rules, while fairly allocating costs and maximizing the value of shared infrastructure. The primary tool for this is the published curtailment hierarchy, where all users, new and existing, understand their risk profile based on predictable priority rules: General Network Access (GNA) has priority over Temporary GNA (T-GNA), and renewable generation has priority over conventional sources.

Fairness in cost allocation is addressed by having new generators initially bear the financial risk for any required network augmentation through bank guarantees, which prevents transmission builds with possibility of not being utilised and imposing such costs on users. We further enhance equity by maximizing the use of shared assets through innovative regulations like "Solar and Non-Solar Hour Access" for sharing transmission infrastructure, and by introducing a portal where GNA holders can voluntarily indicate unused GNA quantum for other grantees to use and allow existing grid capacity to be used more efficiently.

Y. Phulpin: Thank you so much for sharing your experience. This content will feed the ongoing works of WG C5.39 convened by Dr Rabindra Nath Shaw, with targeted Technical Brochure Publication by the end of 2026.

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