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Sustainable Energy Transformation Series
MAKING
SENSE
OF
KUSUMOpportunities & challenges in delivering water
and energy security for agriculture in Tamil Nadu
Sustainable Energy Transformation Series
September 2019
Making
Sense
of
KUSUM
Opportunities & challenges in delivering water
and energy security for agriculture in Tamil Nadu
ACKNOWLEDGMENT
This publication forms part of the Sustainable Energy
Transformation, Tamil Nadu (SET-TN) series of documents and
activities. SET aims to facilitate higher clean energy deployment
in the State by working with all stakeholders in order to find
sustainable and equitable solutions. SET is a collaborative
initiative by Auroville Consulting (AVC), Citizen consumer and
civic Action Group (CAG), the World Resources Institute India
(WRI).
Author
Martin Scherfler, Auroville Consulting
Reviewers
Deepak Krishnan, World Resources Institute India
Harsha Meenawat, World Resources Institute India
Toine van Megen, Auroville Consulting
K. Vishnu Mohan Rao, Citizen consumer and civic Action Group
Designer
Ribhu Roy, Auroville Consulting
Suggested Citation: Auroville Consulting. 2019. Making
Sense of KUSUM. Opportunities & Challenges in delivering
water and energy security for agriculture in Tamil Nadu.
Making Sense of KUSUM1
TABLE OF CONTENTS
1. BACKGROUND												 2
2. KUSUM COMPONENT A											 4
	
	2.1 Proposed												 4
	2.2 Critique												 5
	2.3 Alternative												 7
3. KUSUM COMPONENT C								 		 9
	3.1 Proposed												 9
	3.2 Critique												10
	3.3 Alternative												11
4. SUMMARY AND CONCLUSION										13
Making Sense of KUSUM 2
The agricultural sector in Tamil Nadu accounts for about 20% of the state’s electricity
consumption. Electricity supply, in the state, is free of cost to the farmers. Though the
subsidy burden for the free electricity to agricultural consumers is partially shouldered
by the state Government 1
, the primarily subsidy burden rests with the state-owned
electricity utility, Tamil Nadu Generation and Distribution Corporation (TANGEDCO).
To compensate for the revenue loss for electricity supply to the agricultural sector, and
to other subsidy consumer categories such as the domestic consumers, TANGECO
levies higher tariffs on other electricity consumer categories such as the commercial
and industrial ones.
With the rapid cost decline of renewable energy over the last decade, an electricity
market reform (Electricity Act of 2003) and the advent of rooftop solar, procuring
electricity from the distribution companies (Discoms) increasingly becomes a
less attractive option for the commercial and industrial consumers (C&I), and the
high end residential consumers. There is a trend of C&I consumers migrating to
alternative options such as procuring electricity via the open access mechanism or
by transitioning, to the extent possible, to captive (rooftop) solar energy. With the
threat of an increasing migration of high paying electricity consumers towards more
affordable alternatives, TANGEDCO is faced with the challenge of keeping up the
subsidized power supply to the agricultural and domestic sector, and this in the
face of dwindling revenue. To make things worse, electricity consumer prices have
not been revised on an annual basis. The last tariff revision, in Tamil Nadu, was in
the financial year 2017. Consumer tariffs determined in 2016-17 are still applicable
today, in 2019. As the cost of electricity supply has increased and no increase of
consumer tariffs took place, TANGEDO’s financial health is substantially affected.
1) TAGNEDCO receives a subsidy of INR 2,850 for each HP of sanctioned agricultural pump load. In the financial
year 2017-2018, this subsidy amount accounted for INR Core 3,432. With an estimated electricity consumption for the
agricultural sector of 12,544 MU (Approved sales figure from TANGEDCO as per Tariff order 2017) and an average
cost of supply in the same year. The total cost of electricity supply to agriculture amounts to 9,671.42 INR CRORES
(as per the ACOS Calculated from P&L Balance sheet for 2017-18 which is 7.71 INR/kWh). The subsidy by the state
Government makes up for 35.480% percent of this cost, the remaining cost is being shouldered by TANGEDCO.
1. BACKGROUND
WHY THIS PAPER?
Making Sense of KUSUM3
2) Ministry of New and Renewable Energy (MNRE). 2019. Guidelines for Implementations of Pradhan Mantri
Kisan Urja Surakha evam Uttham Mahabhiyan Scheme. F.No. 32/645/2017-SPV Division. Accessed under:
https://mnre.gov.in/sites/default/files/webform/notices/KUSUMguidelines.pdf
In July 2019, the Ministry of New and Renewable Energy (MNRE) released the
guidelines for its new flagship program ‘Pradhan Mantri Kisan Urja Suraksha evam
Utthan Mahabhiyan’ (KUSUM)2
. KUSUM is presented as a scheme that primarily
aims at benefiting farmers. The scheme has the following three components.
This report aims at delivering a cost-benefit analysis of KUSUM Component A and B and
possible alternatives, taking all major stakeholders - the DISCOM, the generator, the farmer
and the state Government – into consideration. Component B is not scope the analysis, as
this report focuses on the grid-connected component of Kusum. The analysis is being done
in the context of Tamil Nadu, but may be relevant for the majority of the other Indian states.
The proposed alternatives attempt to build upon the strength of the KUSUM approach by
introducing selected modifications in the scheme in order to better bring out its full potential.
Setting up of 10,000
MW of Decentralized
Ground / Stilt Mounted
Grid Connected Solar or
other Renewable Energy
based Power Plants
Installation of 17.50
Lakh Stand-alone
Solar Agriculture
Pumps
Solarisation of
10 Lakh Grid
Connected
Agriculture Pumps
Component A Component B Component C
KUSUM COMPONENT A
Setting up of 10,000 MW of Decentralized Ground/Stilt
Mounted Grid Connected Solar or other Renewable Energy
based Power Plants
Making Sense of KUSUM 6
Component A aims at the promotion of distributed
renewable energy generation (DREG) in the
capacity range of 500 kW to 2 MW. The scheme
also provides flexibility to allow DREG smaller
than 500 kW. Though the focus is on distributed
solar, other renewable generation technologies
are permitted as well. According to the guidelines,
KUSUM Component A is expected to result in
savings on transmission system requirement and
in a reduction of transmission and distribution
(T&D) losses.
Financing of the DREG under Component A is
primarily envisioned by individual farmers, group
of farmers, cooperatives, panchayats, Farmer
Producer Organisations (FPO), and Water User
Associations (WUA).
2.1 PROPOSED
3) As per TNERC Forecasting, Scheduling and Deviation Settlement for Solar and Wind generation regulations, 2017
the following deviation settlement applies: At Rs. 0.25 per unit for the shortfall or excess beyond 10% and upto 20% +Rs.
0.5 per unit for the shortfall or excess beyond 20% and up to 30% + Rs. 1.00 per unit for the balance energy beyond 30%
To compensate the generator for the revenue loss
on account of ‘off-take constraints’, the guideline
suggests that the DISCOM will procure excess
generation (beyond the forecasting estimate) equal
tothegenerationlossoccurredatthepowerpurchase
agreement (PPA) tariff in the succeeding 3 years.3
However, the generator is not eligible for
compensation in case the back-down is on account
of events impacting grid security or the safety of
any equipment, personnel or other such conditions.
A designated state entity will facilitate access
to financing, application and competitive
bidding processes and the development of the
DPRs. The scheme proposes a competitive
bidding where the pre-fixed levelised
tariff will be the ceiling tariff for bidding.
Waste land shall be used for the solar projects.
However, the guidelines suggest, that in case
fertile agricultural land is being developed for
solar energy generation, then co-location of crop
and solar energy generation should be done.
This requires elevated mounting structures
and appropriate spacing between the solar
modules to allow sufficient sunlight to
penetrate to the ground for the crops to grow
Offtake constraints due to back-down is proposed
to be compensated based on the following formula:
(Average Generation per hour during the Contract
Year) × (Number of hours of grid unavailability
during the Contract Year)]
Minimum Generation Compensation =
50% of [ (Average Generation per hour during the
month) × (Number of back-down hours during the
month) ] × PPA tariff
A sample power purchase agreement in the
annexure of the KUSUM guidelines,
introduces A generation compensation in
the case of grid back-down. It distinguishes
between generation compensation for
(i) Offtake constraints and
(ii) Generation compensation due to back-down.
The guidelines also mention that the DISCOM or
other private entities may take up the development
of DREG. A procurement based incentive
(PBI) of 0.40 INR/kWh or INR 6.60 lakhs/MW/
year, whichever is lower, has been introduced.
This PBI will be disbursed by the Ministry of
Power to the DISCOM for a five-year period.
‘Generation compensation for off-take
constraints compensates for the revenue loss
of the generator due to temporary transmission
unavailability. It is being calculated as:
Each is differently determined.
Making Sense of KUSUM7
The promotion of distributed renewable
energy generation (DREG), solar and other
renewables, is a welcome move. Equally so is
the flexibility given to the states in implementing
this scheme. The procurement based incentive
(PBI) for 5 years may set the right signals to the
DISCOM in actively promoting this scheme.
Insisting on a dedicated evacuation infrastructure
(e.g. a dedicated feeder) for the DREG, however, is
a counterproductive move. One key advantage of
DREG is the fact that production and consumption
of electricity occur at the same location, or in close
vicinity to each other, thereby reducing T&D losses
and optimizing the utilization of existing electrical
distribution infrastructure.The requirement for
a dedicated feeder for evacuation of electricity
generated by the DREG results in unnecessary
infrastructure costs and occupies valuable
DISCOM substation bays.
There will be many cases where there is no space
for the installation of one or more additional feeder
bays.
A highly relevant introduction is the proposed
‘generation compensation’. Unfortunately, the
actual proposed design of the compensation
mechanisms is rather convoluted and complex.
Generators should simply be compensated for the
deemed generation loss at the fixed tariffs as per the
PPA. Transmission planning is in the hands of the
DISCOMs,whowillhavetoensurethattransmission
expansion and capacity addition are well planned
and integrated. The DISCOM shall not permit
interconnection of DREG at a specific grid node in
the first place, if transmission congestion can be
expected. Making data about current transmission
constraints and future expansion plans available
in the public domain to Independent Power
Producers (IPPs) would be a much needed service.
2.2 CRITIQUE
In the case of backing down generators due to
transmission constraints, the generators shall
be fully compensated for their losses. Equally so
with the back-down due to off-take constraints.
It is the responsibility for the grid operator to
ensure uninterrupted grid-availability. Generators
need to be compensated for 100% of their
deemed generation losses due to gird back-down.
A certain percentage of grid back-down maybe
factored into the tariff itself. Instead of assuming
a 100% grid availability in the tariff determination,
a 97% grid availability can be assumed. This
would take care of grid back-down due to
monthly maintenance shut-downs and safety
concerns. Additional hours of back-down (beyond
the 97%) should be fully compensated for as
deemed generation at the tariff as per PPA.
The scheme proposes that individual farmers,
groups of farmers, cooperatives, panchayats,
Farmer Producer Organisations (FPO), and Water
User Associations (WUA) become renewable
energy producers. Despite the proposed support
by a designated state agency to facilitate access
to finances and provide techno-commercial
services, it is rather doubtful that the proposed
target group has the necessary cash equity
available to invest into energy generators and
the technical and administrative capacity. It also
remains to be seen, whether financing institutions
are willing to provide debt on a project financing
basis, especially to individual the farmers.
Considering that DISCOMS have a history
of delaying payments to independent power
producers - as per June 2019 this was in the
tune of 53,790 INR Crores 4
- the perceived risk
in relation to the possible return on investment
(refer to Table 1), for both, the bank and the
farmers, maybe too high to invest into KUSUM C.
4) Ministry of Power. https://www.praapti.in
Making Sense of KUSUM 8
5) TNERC. 2019. Order on generic tariff for Solar power and related issues. Order No. 5 of 2019 dated 29 -03-2019.
Accessed from: http://www.tnerc.gov.in/orders/Tariff%20Order%202009/2019/Solar-5-29-03-2019.pdf
6) Mericom India. Maharashtra Retenders 750 MW of Solar for Agricultural Feeders Due to Lack of Response https://
mercomindia.com/maharashtra-ag-feeder-solar-retender/
7) TNERC. 2019. Order on generic tariff for Solar power and related issues. Order No. 5 of 2019 dated 29 -03-2019.
Accessed from: http://www.tnerc.gov.in/orders/Tariff%20Order%202009/2019/Solar-5-29-03-2019.pdf
Figure 1 Cost-Benefit Analysis per kW solar capacity by Stakeholder | Kusum Component A
As per the solar tariff order by the Tamil Nadu
Regulatory Commission, the solar energy tariff for
the year 2019-20 has been determined at INR 3.04
per kWh. This solar tariff of INR 3.04 per kWh will
be the ceiling tariff for the proposed competitive
bidding. The TNERC solar tariff order considers a
capital cost of INR 3,35,000,000 per MW of solar
Asthecapitalcostofsmallerrenewablegeneratorsis
typicallyhigherthanthecapitalcostoflargersystems,
and considering the fact that the compensation
mechanism for losses due to off-take are not
covering the actual costs of generation, KUSUM
Component A may not attract any participation
It is financially not feasible for the generators.
Recent competitive biddings from 750 MW of its
solar feeder program in Maharashtra had an upper
ceiling tariff of INR 3.25 per kWh, however due to
lack of response, retendering will have to be done.
A per kW solar capacity cost-benefit analysis
undertaken, on the basis of the assumptions that
were used by TNERC in their Solar Tariff order 2019
and changing three of these assumptions, indicates
a post-tax internal rate of return (IRR) of 7% (refer
to Table 1) for the renewable energy generator and
an actual loss of 20% on the discounted cumulative
cash flow (NPV) over a 25-year time period.
In the proposed alternative the following
assumptions are modified:
The scheme in its current design primarily benefits
the DISCOM and the farmers with available non-
agricutlral land to lease next to a substation.
The generators - whether they are individual
farmers, groups of farmers, cooperatives,
panchayats, Farmer Producer Organisations
(FPO), Water User Associations (WUA) or
independent power producers however, are
unlikely to come forward and make investments.
The recommendation that only waste-land shall be
taken for project development is well appreciated.
The guidelines also open-up the possibility of using
agricultural land under the conditions that the solar
plant will be erected on stilts (e.g. on an elevated
structure) and that enough spacing between the
solar modules is required to allow the co-location
of crop production and solar energy production.
Overall, such an approach will result in additional
costs, and as it is a new approach, with little
research and piloting, one would do well in initiating
R&D projects, that would develop the techno-
commercial know-how for such an approach,
before commencing a commercial roll-out.
(i) instead of a 100% grid-availability, a 97% grid-
availability was assumed, (ii) a 1% of annual
electricity generation decrease on account of
solar panel degradation was introduced and
(iii) the capital cost per MW solar capacity was
increased by a 5% from INR 33,500,000 to INR
35,175,000. KUSUM Component A may simply fail
due to the fact that the financials do not work out.
43
-20
100
Savings 25 years (in %)
DISCOM GENERATOR FARMER
Gains 25 years (in %) Gains 25 years (in %)
Making Sense of KUSUM9
Permitting the interconnection of any DREG at
the high-tension (HT) and the low-tension (LT)
distribution network, as it is a common practices
in many other countries, is recommended.
DREG should be incentivized to connect at the
HT and LT side of the distribution transformer.
The locational value of distributed generation,
in particularly the avoidance of transmission
(and distribution) losses, may be priced and
used to provide an incentive to the generator.
2.3 ALTERNATIVE
8) Calculated as per TANGEDCO Revenue account for the year 2017-18. Profit & Loss Statements.
Figure 2 Cost Benefit Analysis per kW solar capacity by stakeholder | Alternative to KUSUM Component A
100
Suitable interconnection points may be determined
by the DISCOM based on load characteristics and
distributionnetworkcapacity.Feederanddistribution
transformer metering, if non-existent, could be
introduced by the DISCOM simultaneously with the
deployment of Component A. Interconnecting the
DREG at the existing distribution network avoids
capital expenses for a dedicated feeder, it benefits
theDISCOMasitavoidsanunnecessaryoccupation
of substations bays, reduces transmission and
distribution losses and results in a load reduction
upstream from the point of interconnection,
which in turn may not require upgrading the
transmission and distribution infrastructure.
With an Average Power Purchase (APP) cost of INR 5.65
and an average transmission loss of 8%, the locational
value or the DREG can be priced at INR 0.45 per kWh. This
locational value advantage can be shared 50-50 with the
generator, resulting in an incentive of INR 0.23 per kWh for
the generator (refer to Table 3). This locational incentive
could make the scheme successful. Compared to an IRR
for the generator of 7% as per the suggested approach
under KUSUM guidelines, the proposed alternative with
the locational value of solar increases the IRR to a 10%
And there is a cumulative cash flow gain of 22% instead
of a loss of 20%. Whereas the gains to the DISCOM
show a moderate reduction from 43% gains to a 39%.
The state implementation agency may take on a proactive
role in supporting individual farmers and others in the
bidding process (bulk procurement) for the entire allocated
target under KUSUM Component A - it could identify the
land, facilitate the grid-interconnection application, prepare
the PPAs and ensure timely payment by the DISCOM. It
could also facilitate the availability of low cost financing.
As for the co-location of solar energy and agriculture,
it is recommended that pilot projects are undertaken
before large deployment if this approach is undertaken.
The DISCOM and the generator may share the
savings on transmission (and distribution losses).
39
22
Savings 25 years (in %)
DISCOM GENERATOR FARMER
Gains 25 years (in %) Gains 25 years (in %)
Making Sense of KUSUM 10
9) Discounted Savings (NPV) on account of reduction in cost of electricity supply
10) Discounted savings (NPV) on account of subsidy reduction
Table 1 Cost-Benefit Analysis per kW solar capacity by Stakeholder - KUSUM Component A
Savings 25 years (%)
Savings 25 years (%)
DISCOM9
STATE GOVERNMENT10
Component A : Alternative
64,29069,587 3943
00 00
Component A
Savings 25 years (INR)
Savings 25 years (INR)
Making Sense of KUSUM11
Post Tax IRR
Gains 25 years (INR)
Gains 25 years (INR)
Payback
Gains 25 years (%)
Gains 25 years (%)
GENERATOR11
FARMER12
1315
1001001,5421,542
10
7
2319
-2078
22
-20
11) Discounted cumulative cash flow gain/loss
12) Discounted cumulative cash flow gain on account of lease of land to generator
Making Sense of KUSUM13
KUSUM COMPONENT C
Solarisation of 10 Lakh Grid Connected Agriculture Pumps
Making Sense of KUSUM 14
KUSUM Component C promotes grid-connected
solar for agricultural service connections (behind-
the-meter). The guidelines recommend to size
the solar system at twice the pump’s capacity
in horsepower (HP). Lower solar capacity is
permitted as long as the solar capacity in kW does
not fall below the pump capacity in HP. The farmer
will utilize the solar energy generated to meet
the electricity required for irrigation needs and
the solar energy surplus is injected into the grid.
The guidelines for KUSUM Component C provide
flexibility to introduce net-metering - where the
farmer may also draw electricity from the grid, if
and when required - or to limit the pump operation
to electricity drawn from solar generator only.
DISCOMs will purchase excess power from the
farmer at the rate decided by the respective state.
States may also formulate state specific
policies for grid connected solar pumps,
customised to the specific needs of the
respective State, as long as the broader
framework provided by MNRE are kept in mind.
Feeder-wise implementation is recommended.
States can set a minimum target of pumps to be
solarized per feeder. Feeders under KUSUM C will
have a ‘must-run status, to provide uninterrupted
daytime (sunshine hours of a day) power supply.
Thecentralfinancialassistance(CFA),a30%capital
subsidy, is limited for pumps of up to 7.5 HP. Pumps
with a higher capacity are permitted; however, the
maximum capital subsidy will be limited to the
subsidy applicable for 7.5 HP pumps. In addition to
the subsidy provided by the Central Government,
the state Government is required to support the
scheme with a 30% subsidy share. The remaining
40% of capital cost is expected to come from the
farmer via a 10% equity and a 30% debt financing.
The priority is set on small and marginal
farmers. The guideline also recommends to
give priority to farmers already using micro-
irrigation systems or those that are about to
adapt micro-irrigation in order to minimize water
usage and energy consumption for irrigation.
Possibilities would be explored by implementing
agencies for convergence of KUSUM Component
C with schemes on promotion of micro-irrigation
system and replacement of agriculture pumps with
energyefficientpumps.Themodalityforcoordinating
with respective Ministries/Departments will have
to be worked out by the implementation agency.
There is a domestic content requirement
for the solar system components under the
KUSUM C Component. A remote system
performance monitoring has been mandated.
3.1 PROPOSED
Making Sense of KUSUM15
In the context of the net feed-in mechanisms
of Tamil Nadu and the tariff as per TNERC
order for net-feed in of INR 2.28 per kWh, the
farmer’s IRR would be -19% over a 25-year
time period (refer to Table 2). The only possible
benefit for the farmer here is a reliable day-time
3-phase power supply, if that is made part of the
scheme implementation. The current design
on KUSUM C primarily benefits the DISCOMS
and appears to not be attractive to the farmer
In the case of Tamil Nadu, the State Government
would have to shoulder an additional capital outlay
on top of the currently provided subsidy of INR
2,850/year per connected HP, for the 30% capital
subsidy for the solar system provided to the
farmer without any direct gains from the scheme.
The scheme justifies the re-introduction
of electrical service connection meters for
participating farmers. This is expected to help
This presents a severe risk factor in further
increasing ground water extraction on account
of agriculture and accelerating the dire
water shortage in many parts of the country.
the DISCOM and the state greatly in getting a
better grip on the actual electricity consumption
that can be attributed for the agricultural sector.
A challenge for KUSUM Component C may be the
insistence on domestic content requirement for
the solar cells, solar modules and the balance of
the system. There is uncertainty on whether the
local manufacturing capacity is sufficient to deliver
the required solar cells, solar modules, balance
of system etc. in order to meet the KUSUM
targets. The domestic content requirement
will defer access to low interest capital from
international development banks., and may
risk a lawsuit by the World Trade Organization
As electricity is free of cost for the agricultural
consumers, the suggested financing model
(with a 40% contribution by the farmer) are
unlikely to work. The farmer simply has no
incentive to invest into solar energy generation,
despite the high capital subsidy that is provided.
The attempt to converge KUSUM with ongoing
micro-irrigation and efficient pumps schemes
presents a great opportunity to improve water
and energy efficiency. However, the guidelines
are silent on how this will be achieved, and
there may be a great risk that the proposed
convergence will be ignored altogether
3.2 CRITIQUE
Note: Under KUSUM Component C the farmer and the generator are identical.
Figure 3 Cost-Benefit Analysis per kW solar capacity by Stakeholder | KUSUM Component C
Savings 25 years (%)
DISCOM
Savings 25 years (%)
STATE
GOVERNMENT GENERATOR
Gains 25 years (%)
FARMER
Gains 25 years (%)
115
-248-55 248
Making Sense of KUSUM 16
The introduction of advanced irrigation control
systems, that delivers climate based and crop
specific irrigation schedules along with the micro-
irrigation should be considered. Such advanced
irrigation control systems can be programmed
in tune with the proposed time-of-use tariff
This will optimize the farmer’s income from
the proposed solar farmer incentive, contribute
to an advanced demand response program
of the DISCOM and possibly also increase
the crop yield of participating farmers.
Mandating advanced inverter functions under
this scheme presents another opportunity.
This would greatly benefit grid operations.
In return for providing a 30% capital subsidy,
the State Government may benefit from phasing
Examples of ToU export credit and import debit
factors:
1) Solar energy export credit factor during low
demand: 1.00 INR/kWh
2) Solar energy export factor during high demand:
1.50 INR/kWh
3) Grid energy import factor during low demand:
1.00 INR/kWh
4) Grid energy import factor during high demand:
1.50 INR/kWh
3.3 ALTERNATIVE
13) Auroville Consulting. 2019. Water-Energy-Land-Livelihood (WELL) Nexus. Energy as lever towards a sustainably
integrated resource management for Tamil Nadu’s Agricultural Sector.
Alternatively, a third party may invest into the solar
system and sell the gross-generated solar energy
to the DISCOM. In order to make this approach
acceptable to the farmer, a ‘solar farmer incentive’
designed to motivate the farmer to reduce its water
and electricity consumption can be introduced
Such an incentive may further be enhanced
by adding a time-of-use (ToU) component.
Such an incentive maybe be designed as:
out the subsidy disbursement to the DISCOM
for the farmers participating under KUSUM
Component C. This approach promises to
create a stronger incentive for the State to
commit to the 30% capital subsidy requirement.
The convergence of KUSUM with micro-irrigation
schemes and efficient pump schemes will require
inter-departmental coordination within the State
Government. It is highly desirable that drip
irrigation, where possible, will be mandated for
farmers participating under KUSUM Component A.
(Netsolarexport×Solarenergyexportcreditfactors)
- (Grid energy import × Grid import debit factor)
Figure 4 Cost-Benefit Analysis per kW solar capacity by Stakeholder | Alternative to KUSUM Component C
Savings 25 years (%)
DISCOM
Savings 25 years (%)
STATE
GOVERNMENT GENERATOR
Gains 25 years (%)
FARMER
Gains 25 years (%)
69 67
45 50
Making Sense of KUSUM17
Table 2 Cost-Benefit Analysis per kW solar capacity KUSUM C and proposed alternative
Component C : AlternativeComponent C
DISCOM9
STATE GOVERNMENT10
GENERATOR11
FARMER12
Savings 25 years (INR)Savings 25 years (INR)
30,344
93,919
69
115
Savings 25 years (INR)Savings 25 years (INR)
-16,200
45
-55
13,505
Gains 25 years (%)
Post Tax (IRR) Payback
Gains 25 years (INR)
16
-19
4,326
-13,409
67
-248
21
9
Gains 25 years (%)Gains 25 years (INR)
4,326
-13,409 -248
50
Making Sense of KUSUM 18
SUMMARY AND CONCLUSION
While KUSUM presents a healthy initiative in
turning the challenges related to free or subsidised
electricity supply into an opportunity towards
water and energy security, the current guidelines
appear to be rushed and not well-thought out.
Some elements in the guidelines, such as the
insistence on a dedicated feeder, the tariff
setting for competitive bidding and compensation
for power back-out in Component A, or in the
case of Component C the investment recovery
model for the farmer and the lack of strategy for
interdepartmental coordination to ensure that water
conservation technologies are fully integrated,
are risk factors and gaps that may not allow the
scheme to deliver on what is has promised to do.
What KUSUM promised to deliver is: an
income increase and reliable day-time power
supply for the farmers, the promotion of DREG,
the reduction in the cost of supply and the
reduction in transmission and distribution losses.
Though it will be finally the responsibility of the
various states to design and implement state
specific implementation models, these gaps
may need to be addressed at the central level.
With some specific modifications to the proposed
KUSUM Components A & C, these can be
turned into workable and scalable solutions.
Table 3 below compares KUSUM Component
A and C with its suggested alternatives
Though the proposed alternatives provide a
slightly lesser revenue gains to Discoms, they
make the schemes viable in providing shared
benefits to all stakeholders. KUSUM A & C, as
formulated in the guidelines, run the risk of not
taking off due to multiple program constraints such
as the domestic content requirement, insufficient
rate of return to the generators and farmers.
A moderately reduced revenue gain for the
Discoms greatly increases the chances for
the program to succeed. A program that is
not implemented does not benefit anyone.
As per the cost benefit analysis in the table 3 and
4 below, the suggested alternatives to KUSUM
Components A and C promise a well- rounded
approach that delivers benefits to all stakeholders.
The suggested alternative to KUSUM Component C
requiresalongergestationtime,asasmallersystems
take more time for implementation but overall this
alternative delivers the most promising results.
Kusum fails to address the interlinkages between
water, energy, land and livelihood. Especially
the lack of a coherent approach to address over-
extraction of ground water resources by the
agricultural sector remains a big concern. No
attempt for an interdepartmental approach was
undertaken. Additionally the introduction of a life-
cycle approach, that ensures proper disposal
and recycling of the solar equipment is lacking.
Making Sense of KUSUM19
14) Solar Net feed-in tariffs as per TNERC (Order on generic tariff for Solar power and related issues.)
15) Proposed gross feed-in tariff for RESCO with the 60% capital subsidy under KUSUM Component C
Notes: Under Component C the Generator and Farmer are the same entity.
Table 3 Comparison of KUSUM Schemes A, C and possible alternatives
14 15
Making Sense of KUSUM 20
OVERVIEW
Table 4 Cost-Benefit Analysis for various stakeholders per kW Solar
Savings 25 years (INR
Savings 25 years (INR
Savings 25 years (%)
Savings 25 years (%)
DISCOM9
STATE GOVERNMENT10
Component A
Component A
Alternative Component C
Component C
Alternative
115
69
43 39
93,919
30,344
69,587 64,290
13,505
-16,20000 -55
45
00
Making Sense of KUSUM21
Notes: Under Component C the Generator and Farmer are the same entity.
Gains 25 years (INR)
Gains 25 years (INR)
Gains 25 years (%)
Gains 25 years (%)
Post Tax (IRR) Payback
GENERATOR11
FARMER12
-248
21
9
15 13
-19
16
7 10
4,626
1,542 1,542 -13,409 50100 100
-248 67-20 22-13,409 4,326-2,078 2,319
Making Sense of KUSUM 22
1. Ministry of New and Renewable Energy (MNRE). 2019. Guidelines for Implementations of Pradhan Mantri Kisan
Urja Surakha evam Uttham Mahabhiyan Scheme. F.No. 32/645/2017-SPV Division. Accessed under: https://mnre.gov.
in/sites/default/files/webform/notices/KUSUMguidelines.pdf
2. Ministry of Power. Praapti. https://www.praapti.in
3. TNERC. 2019. Order on generic tariff for Solar power and related issues. Order No. 5 of 2019 dated 29 -03-2019.
Accessed under: http://www.tnerc.gov.in/orders/Tariff%20Order%202009/2019/Solar-5-29-03-2019.pdf
4. Mericom India. Maharashtra Retenders 750 MW of Solar for Agricultural Feeders Due to Lack of Response.
Accessed under: https://mercomindia.com/maharashtra-ag-feeder-solar-retender/
5. TNERC. 2019. Order on generic tariff for Solar power and related issues. Order No. 5 of 2019 dated 29 -03-2019.
Accessed under: http://www.tnerc.gov.in/orders/Tariff%20Order%202009/2019/Solar-5-29-03-2019.pdf
6. Auroville Consulting. 2019. Water-Energy-Land-Livelihood (WELL) Nexus. Energy as lever towards a
sustainably integrated resource management for Tamil Nadu’s Agricultural Sector. Accessed under: https://www.
aurovilleconsulting.com/system/attachments/190813_WELL_Nexus_single.pdf?1565756467
7. TNERC. 2019. Order on Rooftop Solar Generation. Accessed under: http://www.tnerc.gov.in/orders/Tariff%20
Order%202009/2019/Solar-25-03-2019.pdf
8. TNERC. 2019. Order on Rooftop Solar Generation. Accessed under: http://www.tnerc.gov.in/orders/Tariff%20
Order%202009/2019/Solar-25-03-2019.pdf
REFERENCES
Sustainable Energy Transformation Series
September 2019

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Making sense of kusum

  • 1. Sustainable Energy Transformation Series MAKING SENSE OF KUSUMOpportunities & challenges in delivering water and energy security for agriculture in Tamil Nadu
  • 2. Sustainable Energy Transformation Series September 2019 Making Sense of KUSUM Opportunities & challenges in delivering water and energy security for agriculture in Tamil Nadu
  • 3. ACKNOWLEDGMENT This publication forms part of the Sustainable Energy Transformation, Tamil Nadu (SET-TN) series of documents and activities. SET aims to facilitate higher clean energy deployment in the State by working with all stakeholders in order to find sustainable and equitable solutions. SET is a collaborative initiative by Auroville Consulting (AVC), Citizen consumer and civic Action Group (CAG), the World Resources Institute India (WRI). Author Martin Scherfler, Auroville Consulting Reviewers Deepak Krishnan, World Resources Institute India Harsha Meenawat, World Resources Institute India Toine van Megen, Auroville Consulting K. Vishnu Mohan Rao, Citizen consumer and civic Action Group Designer Ribhu Roy, Auroville Consulting Suggested Citation: Auroville Consulting. 2019. Making Sense of KUSUM. Opportunities & Challenges in delivering water and energy security for agriculture in Tamil Nadu.
  • 4. Making Sense of KUSUM1 TABLE OF CONTENTS 1. BACKGROUND 2 2. KUSUM COMPONENT A 4 2.1 Proposed 4 2.2 Critique 5 2.3 Alternative 7 3. KUSUM COMPONENT C 9 3.1 Proposed 9 3.2 Critique 10 3.3 Alternative 11 4. SUMMARY AND CONCLUSION 13
  • 5. Making Sense of KUSUM 2 The agricultural sector in Tamil Nadu accounts for about 20% of the state’s electricity consumption. Electricity supply, in the state, is free of cost to the farmers. Though the subsidy burden for the free electricity to agricultural consumers is partially shouldered by the state Government 1 , the primarily subsidy burden rests with the state-owned electricity utility, Tamil Nadu Generation and Distribution Corporation (TANGEDCO). To compensate for the revenue loss for electricity supply to the agricultural sector, and to other subsidy consumer categories such as the domestic consumers, TANGECO levies higher tariffs on other electricity consumer categories such as the commercial and industrial ones. With the rapid cost decline of renewable energy over the last decade, an electricity market reform (Electricity Act of 2003) and the advent of rooftop solar, procuring electricity from the distribution companies (Discoms) increasingly becomes a less attractive option for the commercial and industrial consumers (C&I), and the high end residential consumers. There is a trend of C&I consumers migrating to alternative options such as procuring electricity via the open access mechanism or by transitioning, to the extent possible, to captive (rooftop) solar energy. With the threat of an increasing migration of high paying electricity consumers towards more affordable alternatives, TANGEDCO is faced with the challenge of keeping up the subsidized power supply to the agricultural and domestic sector, and this in the face of dwindling revenue. To make things worse, electricity consumer prices have not been revised on an annual basis. The last tariff revision, in Tamil Nadu, was in the financial year 2017. Consumer tariffs determined in 2016-17 are still applicable today, in 2019. As the cost of electricity supply has increased and no increase of consumer tariffs took place, TANGEDO’s financial health is substantially affected. 1) TAGNEDCO receives a subsidy of INR 2,850 for each HP of sanctioned agricultural pump load. In the financial year 2017-2018, this subsidy amount accounted for INR Core 3,432. With an estimated electricity consumption for the agricultural sector of 12,544 MU (Approved sales figure from TANGEDCO as per Tariff order 2017) and an average cost of supply in the same year. The total cost of electricity supply to agriculture amounts to 9,671.42 INR CRORES (as per the ACOS Calculated from P&L Balance sheet for 2017-18 which is 7.71 INR/kWh). The subsidy by the state Government makes up for 35.480% percent of this cost, the remaining cost is being shouldered by TANGEDCO. 1. BACKGROUND WHY THIS PAPER?
  • 6. Making Sense of KUSUM3 2) Ministry of New and Renewable Energy (MNRE). 2019. Guidelines for Implementations of Pradhan Mantri Kisan Urja Surakha evam Uttham Mahabhiyan Scheme. F.No. 32/645/2017-SPV Division. Accessed under: https://mnre.gov.in/sites/default/files/webform/notices/KUSUMguidelines.pdf In July 2019, the Ministry of New and Renewable Energy (MNRE) released the guidelines for its new flagship program ‘Pradhan Mantri Kisan Urja Suraksha evam Utthan Mahabhiyan’ (KUSUM)2 . KUSUM is presented as a scheme that primarily aims at benefiting farmers. The scheme has the following three components. This report aims at delivering a cost-benefit analysis of KUSUM Component A and B and possible alternatives, taking all major stakeholders - the DISCOM, the generator, the farmer and the state Government – into consideration. Component B is not scope the analysis, as this report focuses on the grid-connected component of Kusum. The analysis is being done in the context of Tamil Nadu, but may be relevant for the majority of the other Indian states. The proposed alternatives attempt to build upon the strength of the KUSUM approach by introducing selected modifications in the scheme in order to better bring out its full potential. Setting up of 10,000 MW of Decentralized Ground / Stilt Mounted Grid Connected Solar or other Renewable Energy based Power Plants Installation of 17.50 Lakh Stand-alone Solar Agriculture Pumps Solarisation of 10 Lakh Grid Connected Agriculture Pumps Component A Component B Component C
  • 7. KUSUM COMPONENT A Setting up of 10,000 MW of Decentralized Ground/Stilt Mounted Grid Connected Solar or other Renewable Energy based Power Plants
  • 8. Making Sense of KUSUM 6 Component A aims at the promotion of distributed renewable energy generation (DREG) in the capacity range of 500 kW to 2 MW. The scheme also provides flexibility to allow DREG smaller than 500 kW. Though the focus is on distributed solar, other renewable generation technologies are permitted as well. According to the guidelines, KUSUM Component A is expected to result in savings on transmission system requirement and in a reduction of transmission and distribution (T&D) losses. Financing of the DREG under Component A is primarily envisioned by individual farmers, group of farmers, cooperatives, panchayats, Farmer Producer Organisations (FPO), and Water User Associations (WUA). 2.1 PROPOSED 3) As per TNERC Forecasting, Scheduling and Deviation Settlement for Solar and Wind generation regulations, 2017 the following deviation settlement applies: At Rs. 0.25 per unit for the shortfall or excess beyond 10% and upto 20% +Rs. 0.5 per unit for the shortfall or excess beyond 20% and up to 30% + Rs. 1.00 per unit for the balance energy beyond 30% To compensate the generator for the revenue loss on account of ‘off-take constraints’, the guideline suggests that the DISCOM will procure excess generation (beyond the forecasting estimate) equal tothegenerationlossoccurredatthepowerpurchase agreement (PPA) tariff in the succeeding 3 years.3 However, the generator is not eligible for compensation in case the back-down is on account of events impacting grid security or the safety of any equipment, personnel or other such conditions. A designated state entity will facilitate access to financing, application and competitive bidding processes and the development of the DPRs. The scheme proposes a competitive bidding where the pre-fixed levelised tariff will be the ceiling tariff for bidding. Waste land shall be used for the solar projects. However, the guidelines suggest, that in case fertile agricultural land is being developed for solar energy generation, then co-location of crop and solar energy generation should be done. This requires elevated mounting structures and appropriate spacing between the solar modules to allow sufficient sunlight to penetrate to the ground for the crops to grow Offtake constraints due to back-down is proposed to be compensated based on the following formula: (Average Generation per hour during the Contract Year) × (Number of hours of grid unavailability during the Contract Year)] Minimum Generation Compensation = 50% of [ (Average Generation per hour during the month) × (Number of back-down hours during the month) ] × PPA tariff A sample power purchase agreement in the annexure of the KUSUM guidelines, introduces A generation compensation in the case of grid back-down. It distinguishes between generation compensation for (i) Offtake constraints and (ii) Generation compensation due to back-down. The guidelines also mention that the DISCOM or other private entities may take up the development of DREG. A procurement based incentive (PBI) of 0.40 INR/kWh or INR 6.60 lakhs/MW/ year, whichever is lower, has been introduced. This PBI will be disbursed by the Ministry of Power to the DISCOM for a five-year period. ‘Generation compensation for off-take constraints compensates for the revenue loss of the generator due to temporary transmission unavailability. It is being calculated as: Each is differently determined.
  • 9. Making Sense of KUSUM7 The promotion of distributed renewable energy generation (DREG), solar and other renewables, is a welcome move. Equally so is the flexibility given to the states in implementing this scheme. The procurement based incentive (PBI) for 5 years may set the right signals to the DISCOM in actively promoting this scheme. Insisting on a dedicated evacuation infrastructure (e.g. a dedicated feeder) for the DREG, however, is a counterproductive move. One key advantage of DREG is the fact that production and consumption of electricity occur at the same location, or in close vicinity to each other, thereby reducing T&D losses and optimizing the utilization of existing electrical distribution infrastructure.The requirement for a dedicated feeder for evacuation of electricity generated by the DREG results in unnecessary infrastructure costs and occupies valuable DISCOM substation bays. There will be many cases where there is no space for the installation of one or more additional feeder bays. A highly relevant introduction is the proposed ‘generation compensation’. Unfortunately, the actual proposed design of the compensation mechanisms is rather convoluted and complex. Generators should simply be compensated for the deemed generation loss at the fixed tariffs as per the PPA. Transmission planning is in the hands of the DISCOMs,whowillhavetoensurethattransmission expansion and capacity addition are well planned and integrated. The DISCOM shall not permit interconnection of DREG at a specific grid node in the first place, if transmission congestion can be expected. Making data about current transmission constraints and future expansion plans available in the public domain to Independent Power Producers (IPPs) would be a much needed service. 2.2 CRITIQUE In the case of backing down generators due to transmission constraints, the generators shall be fully compensated for their losses. Equally so with the back-down due to off-take constraints. It is the responsibility for the grid operator to ensure uninterrupted grid-availability. Generators need to be compensated for 100% of their deemed generation losses due to gird back-down. A certain percentage of grid back-down maybe factored into the tariff itself. Instead of assuming a 100% grid availability in the tariff determination, a 97% grid availability can be assumed. This would take care of grid back-down due to monthly maintenance shut-downs and safety concerns. Additional hours of back-down (beyond the 97%) should be fully compensated for as deemed generation at the tariff as per PPA. The scheme proposes that individual farmers, groups of farmers, cooperatives, panchayats, Farmer Producer Organisations (FPO), and Water User Associations (WUA) become renewable energy producers. Despite the proposed support by a designated state agency to facilitate access to finances and provide techno-commercial services, it is rather doubtful that the proposed target group has the necessary cash equity available to invest into energy generators and the technical and administrative capacity. It also remains to be seen, whether financing institutions are willing to provide debt on a project financing basis, especially to individual the farmers. Considering that DISCOMS have a history of delaying payments to independent power producers - as per June 2019 this was in the tune of 53,790 INR Crores 4 - the perceived risk in relation to the possible return on investment (refer to Table 1), for both, the bank and the farmers, maybe too high to invest into KUSUM C. 4) Ministry of Power. https://www.praapti.in
  • 10. Making Sense of KUSUM 8 5) TNERC. 2019. Order on generic tariff for Solar power and related issues. Order No. 5 of 2019 dated 29 -03-2019. Accessed from: http://www.tnerc.gov.in/orders/Tariff%20Order%202009/2019/Solar-5-29-03-2019.pdf 6) Mericom India. Maharashtra Retenders 750 MW of Solar for Agricultural Feeders Due to Lack of Response https:// mercomindia.com/maharashtra-ag-feeder-solar-retender/ 7) TNERC. 2019. Order on generic tariff for Solar power and related issues. Order No. 5 of 2019 dated 29 -03-2019. Accessed from: http://www.tnerc.gov.in/orders/Tariff%20Order%202009/2019/Solar-5-29-03-2019.pdf Figure 1 Cost-Benefit Analysis per kW solar capacity by Stakeholder | Kusum Component A As per the solar tariff order by the Tamil Nadu Regulatory Commission, the solar energy tariff for the year 2019-20 has been determined at INR 3.04 per kWh. This solar tariff of INR 3.04 per kWh will be the ceiling tariff for the proposed competitive bidding. The TNERC solar tariff order considers a capital cost of INR 3,35,000,000 per MW of solar Asthecapitalcostofsmallerrenewablegeneratorsis typicallyhigherthanthecapitalcostoflargersystems, and considering the fact that the compensation mechanism for losses due to off-take are not covering the actual costs of generation, KUSUM Component A may not attract any participation It is financially not feasible for the generators. Recent competitive biddings from 750 MW of its solar feeder program in Maharashtra had an upper ceiling tariff of INR 3.25 per kWh, however due to lack of response, retendering will have to be done. A per kW solar capacity cost-benefit analysis undertaken, on the basis of the assumptions that were used by TNERC in their Solar Tariff order 2019 and changing three of these assumptions, indicates a post-tax internal rate of return (IRR) of 7% (refer to Table 1) for the renewable energy generator and an actual loss of 20% on the discounted cumulative cash flow (NPV) over a 25-year time period. In the proposed alternative the following assumptions are modified: The scheme in its current design primarily benefits the DISCOM and the farmers with available non- agricutlral land to lease next to a substation. The generators - whether they are individual farmers, groups of farmers, cooperatives, panchayats, Farmer Producer Organisations (FPO), Water User Associations (WUA) or independent power producers however, are unlikely to come forward and make investments. The recommendation that only waste-land shall be taken for project development is well appreciated. The guidelines also open-up the possibility of using agricultural land under the conditions that the solar plant will be erected on stilts (e.g. on an elevated structure) and that enough spacing between the solar modules is required to allow the co-location of crop production and solar energy production. Overall, such an approach will result in additional costs, and as it is a new approach, with little research and piloting, one would do well in initiating R&D projects, that would develop the techno- commercial know-how for such an approach, before commencing a commercial roll-out. (i) instead of a 100% grid-availability, a 97% grid- availability was assumed, (ii) a 1% of annual electricity generation decrease on account of solar panel degradation was introduced and (iii) the capital cost per MW solar capacity was increased by a 5% from INR 33,500,000 to INR 35,175,000. KUSUM Component A may simply fail due to the fact that the financials do not work out. 43 -20 100 Savings 25 years (in %) DISCOM GENERATOR FARMER Gains 25 years (in %) Gains 25 years (in %)
  • 11. Making Sense of KUSUM9 Permitting the interconnection of any DREG at the high-tension (HT) and the low-tension (LT) distribution network, as it is a common practices in many other countries, is recommended. DREG should be incentivized to connect at the HT and LT side of the distribution transformer. The locational value of distributed generation, in particularly the avoidance of transmission (and distribution) losses, may be priced and used to provide an incentive to the generator. 2.3 ALTERNATIVE 8) Calculated as per TANGEDCO Revenue account for the year 2017-18. Profit & Loss Statements. Figure 2 Cost Benefit Analysis per kW solar capacity by stakeholder | Alternative to KUSUM Component A 100 Suitable interconnection points may be determined by the DISCOM based on load characteristics and distributionnetworkcapacity.Feederanddistribution transformer metering, if non-existent, could be introduced by the DISCOM simultaneously with the deployment of Component A. Interconnecting the DREG at the existing distribution network avoids capital expenses for a dedicated feeder, it benefits theDISCOMasitavoidsanunnecessaryoccupation of substations bays, reduces transmission and distribution losses and results in a load reduction upstream from the point of interconnection, which in turn may not require upgrading the transmission and distribution infrastructure. With an Average Power Purchase (APP) cost of INR 5.65 and an average transmission loss of 8%, the locational value or the DREG can be priced at INR 0.45 per kWh. This locational value advantage can be shared 50-50 with the generator, resulting in an incentive of INR 0.23 per kWh for the generator (refer to Table 3). This locational incentive could make the scheme successful. Compared to an IRR for the generator of 7% as per the suggested approach under KUSUM guidelines, the proposed alternative with the locational value of solar increases the IRR to a 10% And there is a cumulative cash flow gain of 22% instead of a loss of 20%. Whereas the gains to the DISCOM show a moderate reduction from 43% gains to a 39%. The state implementation agency may take on a proactive role in supporting individual farmers and others in the bidding process (bulk procurement) for the entire allocated target under KUSUM Component A - it could identify the land, facilitate the grid-interconnection application, prepare the PPAs and ensure timely payment by the DISCOM. It could also facilitate the availability of low cost financing. As for the co-location of solar energy and agriculture, it is recommended that pilot projects are undertaken before large deployment if this approach is undertaken. The DISCOM and the generator may share the savings on transmission (and distribution losses). 39 22 Savings 25 years (in %) DISCOM GENERATOR FARMER Gains 25 years (in %) Gains 25 years (in %)
  • 12. Making Sense of KUSUM 10 9) Discounted Savings (NPV) on account of reduction in cost of electricity supply 10) Discounted savings (NPV) on account of subsidy reduction Table 1 Cost-Benefit Analysis per kW solar capacity by Stakeholder - KUSUM Component A Savings 25 years (%) Savings 25 years (%) DISCOM9 STATE GOVERNMENT10 Component A : Alternative 64,29069,587 3943 00 00 Component A Savings 25 years (INR) Savings 25 years (INR)
  • 13. Making Sense of KUSUM11 Post Tax IRR Gains 25 years (INR) Gains 25 years (INR) Payback Gains 25 years (%) Gains 25 years (%) GENERATOR11 FARMER12 1315 1001001,5421,542 10 7 2319 -2078 22 -20 11) Discounted cumulative cash flow gain/loss 12) Discounted cumulative cash flow gain on account of lease of land to generator
  • 14. Making Sense of KUSUM13 KUSUM COMPONENT C Solarisation of 10 Lakh Grid Connected Agriculture Pumps
  • 15. Making Sense of KUSUM 14 KUSUM Component C promotes grid-connected solar for agricultural service connections (behind- the-meter). The guidelines recommend to size the solar system at twice the pump’s capacity in horsepower (HP). Lower solar capacity is permitted as long as the solar capacity in kW does not fall below the pump capacity in HP. The farmer will utilize the solar energy generated to meet the electricity required for irrigation needs and the solar energy surplus is injected into the grid. The guidelines for KUSUM Component C provide flexibility to introduce net-metering - where the farmer may also draw electricity from the grid, if and when required - or to limit the pump operation to electricity drawn from solar generator only. DISCOMs will purchase excess power from the farmer at the rate decided by the respective state. States may also formulate state specific policies for grid connected solar pumps, customised to the specific needs of the respective State, as long as the broader framework provided by MNRE are kept in mind. Feeder-wise implementation is recommended. States can set a minimum target of pumps to be solarized per feeder. Feeders under KUSUM C will have a ‘must-run status, to provide uninterrupted daytime (sunshine hours of a day) power supply. Thecentralfinancialassistance(CFA),a30%capital subsidy, is limited for pumps of up to 7.5 HP. Pumps with a higher capacity are permitted; however, the maximum capital subsidy will be limited to the subsidy applicable for 7.5 HP pumps. In addition to the subsidy provided by the Central Government, the state Government is required to support the scheme with a 30% subsidy share. The remaining 40% of capital cost is expected to come from the farmer via a 10% equity and a 30% debt financing. The priority is set on small and marginal farmers. The guideline also recommends to give priority to farmers already using micro- irrigation systems or those that are about to adapt micro-irrigation in order to minimize water usage and energy consumption for irrigation. Possibilities would be explored by implementing agencies for convergence of KUSUM Component C with schemes on promotion of micro-irrigation system and replacement of agriculture pumps with energyefficientpumps.Themodalityforcoordinating with respective Ministries/Departments will have to be worked out by the implementation agency. There is a domestic content requirement for the solar system components under the KUSUM C Component. A remote system performance monitoring has been mandated. 3.1 PROPOSED
  • 16. Making Sense of KUSUM15 In the context of the net feed-in mechanisms of Tamil Nadu and the tariff as per TNERC order for net-feed in of INR 2.28 per kWh, the farmer’s IRR would be -19% over a 25-year time period (refer to Table 2). The only possible benefit for the farmer here is a reliable day-time 3-phase power supply, if that is made part of the scheme implementation. The current design on KUSUM C primarily benefits the DISCOMS and appears to not be attractive to the farmer In the case of Tamil Nadu, the State Government would have to shoulder an additional capital outlay on top of the currently provided subsidy of INR 2,850/year per connected HP, for the 30% capital subsidy for the solar system provided to the farmer without any direct gains from the scheme. The scheme justifies the re-introduction of electrical service connection meters for participating farmers. This is expected to help This presents a severe risk factor in further increasing ground water extraction on account of agriculture and accelerating the dire water shortage in many parts of the country. the DISCOM and the state greatly in getting a better grip on the actual electricity consumption that can be attributed for the agricultural sector. A challenge for KUSUM Component C may be the insistence on domestic content requirement for the solar cells, solar modules and the balance of the system. There is uncertainty on whether the local manufacturing capacity is sufficient to deliver the required solar cells, solar modules, balance of system etc. in order to meet the KUSUM targets. The domestic content requirement will defer access to low interest capital from international development banks., and may risk a lawsuit by the World Trade Organization As electricity is free of cost for the agricultural consumers, the suggested financing model (with a 40% contribution by the farmer) are unlikely to work. The farmer simply has no incentive to invest into solar energy generation, despite the high capital subsidy that is provided. The attempt to converge KUSUM with ongoing micro-irrigation and efficient pumps schemes presents a great opportunity to improve water and energy efficiency. However, the guidelines are silent on how this will be achieved, and there may be a great risk that the proposed convergence will be ignored altogether 3.2 CRITIQUE Note: Under KUSUM Component C the farmer and the generator are identical. Figure 3 Cost-Benefit Analysis per kW solar capacity by Stakeholder | KUSUM Component C Savings 25 years (%) DISCOM Savings 25 years (%) STATE GOVERNMENT GENERATOR Gains 25 years (%) FARMER Gains 25 years (%) 115 -248-55 248
  • 17. Making Sense of KUSUM 16 The introduction of advanced irrigation control systems, that delivers climate based and crop specific irrigation schedules along with the micro- irrigation should be considered. Such advanced irrigation control systems can be programmed in tune with the proposed time-of-use tariff This will optimize the farmer’s income from the proposed solar farmer incentive, contribute to an advanced demand response program of the DISCOM and possibly also increase the crop yield of participating farmers. Mandating advanced inverter functions under this scheme presents another opportunity. This would greatly benefit grid operations. In return for providing a 30% capital subsidy, the State Government may benefit from phasing Examples of ToU export credit and import debit factors: 1) Solar energy export credit factor during low demand: 1.00 INR/kWh 2) Solar energy export factor during high demand: 1.50 INR/kWh 3) Grid energy import factor during low demand: 1.00 INR/kWh 4) Grid energy import factor during high demand: 1.50 INR/kWh 3.3 ALTERNATIVE 13) Auroville Consulting. 2019. Water-Energy-Land-Livelihood (WELL) Nexus. Energy as lever towards a sustainably integrated resource management for Tamil Nadu’s Agricultural Sector. Alternatively, a third party may invest into the solar system and sell the gross-generated solar energy to the DISCOM. In order to make this approach acceptable to the farmer, a ‘solar farmer incentive’ designed to motivate the farmer to reduce its water and electricity consumption can be introduced Such an incentive may further be enhanced by adding a time-of-use (ToU) component. Such an incentive maybe be designed as: out the subsidy disbursement to the DISCOM for the farmers participating under KUSUM Component C. This approach promises to create a stronger incentive for the State to commit to the 30% capital subsidy requirement. The convergence of KUSUM with micro-irrigation schemes and efficient pump schemes will require inter-departmental coordination within the State Government. It is highly desirable that drip irrigation, where possible, will be mandated for farmers participating under KUSUM Component A. (Netsolarexport×Solarenergyexportcreditfactors) - (Grid energy import × Grid import debit factor) Figure 4 Cost-Benefit Analysis per kW solar capacity by Stakeholder | Alternative to KUSUM Component C Savings 25 years (%) DISCOM Savings 25 years (%) STATE GOVERNMENT GENERATOR Gains 25 years (%) FARMER Gains 25 years (%) 69 67 45 50
  • 18. Making Sense of KUSUM17 Table 2 Cost-Benefit Analysis per kW solar capacity KUSUM C and proposed alternative Component C : AlternativeComponent C DISCOM9 STATE GOVERNMENT10 GENERATOR11 FARMER12 Savings 25 years (INR)Savings 25 years (INR) 30,344 93,919 69 115 Savings 25 years (INR)Savings 25 years (INR) -16,200 45 -55 13,505 Gains 25 years (%) Post Tax (IRR) Payback Gains 25 years (INR) 16 -19 4,326 -13,409 67 -248 21 9 Gains 25 years (%)Gains 25 years (INR) 4,326 -13,409 -248 50
  • 19. Making Sense of KUSUM 18 SUMMARY AND CONCLUSION While KUSUM presents a healthy initiative in turning the challenges related to free or subsidised electricity supply into an opportunity towards water and energy security, the current guidelines appear to be rushed and not well-thought out. Some elements in the guidelines, such as the insistence on a dedicated feeder, the tariff setting for competitive bidding and compensation for power back-out in Component A, or in the case of Component C the investment recovery model for the farmer and the lack of strategy for interdepartmental coordination to ensure that water conservation technologies are fully integrated, are risk factors and gaps that may not allow the scheme to deliver on what is has promised to do. What KUSUM promised to deliver is: an income increase and reliable day-time power supply for the farmers, the promotion of DREG, the reduction in the cost of supply and the reduction in transmission and distribution losses. Though it will be finally the responsibility of the various states to design and implement state specific implementation models, these gaps may need to be addressed at the central level. With some specific modifications to the proposed KUSUM Components A & C, these can be turned into workable and scalable solutions. Table 3 below compares KUSUM Component A and C with its suggested alternatives Though the proposed alternatives provide a slightly lesser revenue gains to Discoms, they make the schemes viable in providing shared benefits to all stakeholders. KUSUM A & C, as formulated in the guidelines, run the risk of not taking off due to multiple program constraints such as the domestic content requirement, insufficient rate of return to the generators and farmers. A moderately reduced revenue gain for the Discoms greatly increases the chances for the program to succeed. A program that is not implemented does not benefit anyone. As per the cost benefit analysis in the table 3 and 4 below, the suggested alternatives to KUSUM Components A and C promise a well- rounded approach that delivers benefits to all stakeholders. The suggested alternative to KUSUM Component C requiresalongergestationtime,asasmallersystems take more time for implementation but overall this alternative delivers the most promising results. Kusum fails to address the interlinkages between water, energy, land and livelihood. Especially the lack of a coherent approach to address over- extraction of ground water resources by the agricultural sector remains a big concern. No attempt for an interdepartmental approach was undertaken. Additionally the introduction of a life- cycle approach, that ensures proper disposal and recycling of the solar equipment is lacking.
  • 20. Making Sense of KUSUM19 14) Solar Net feed-in tariffs as per TNERC (Order on generic tariff for Solar power and related issues.) 15) Proposed gross feed-in tariff for RESCO with the 60% capital subsidy under KUSUM Component C Notes: Under Component C the Generator and Farmer are the same entity. Table 3 Comparison of KUSUM Schemes A, C and possible alternatives 14 15
  • 21. Making Sense of KUSUM 20 OVERVIEW Table 4 Cost-Benefit Analysis for various stakeholders per kW Solar Savings 25 years (INR Savings 25 years (INR Savings 25 years (%) Savings 25 years (%) DISCOM9 STATE GOVERNMENT10 Component A Component A Alternative Component C Component C Alternative 115 69 43 39 93,919 30,344 69,587 64,290 13,505 -16,20000 -55 45 00
  • 22. Making Sense of KUSUM21 Notes: Under Component C the Generator and Farmer are the same entity. Gains 25 years (INR) Gains 25 years (INR) Gains 25 years (%) Gains 25 years (%) Post Tax (IRR) Payback GENERATOR11 FARMER12 -248 21 9 15 13 -19 16 7 10 4,626 1,542 1,542 -13,409 50100 100 -248 67-20 22-13,409 4,326-2,078 2,319
  • 23. Making Sense of KUSUM 22 1. Ministry of New and Renewable Energy (MNRE). 2019. Guidelines for Implementations of Pradhan Mantri Kisan Urja Surakha evam Uttham Mahabhiyan Scheme. F.No. 32/645/2017-SPV Division. Accessed under: https://mnre.gov. in/sites/default/files/webform/notices/KUSUMguidelines.pdf 2. Ministry of Power. Praapti. https://www.praapti.in 3. TNERC. 2019. Order on generic tariff for Solar power and related issues. Order No. 5 of 2019 dated 29 -03-2019. Accessed under: http://www.tnerc.gov.in/orders/Tariff%20Order%202009/2019/Solar-5-29-03-2019.pdf 4. Mericom India. Maharashtra Retenders 750 MW of Solar for Agricultural Feeders Due to Lack of Response. Accessed under: https://mercomindia.com/maharashtra-ag-feeder-solar-retender/ 5. TNERC. 2019. Order on generic tariff for Solar power and related issues. Order No. 5 of 2019 dated 29 -03-2019. Accessed under: http://www.tnerc.gov.in/orders/Tariff%20Order%202009/2019/Solar-5-29-03-2019.pdf 6. Auroville Consulting. 2019. Water-Energy-Land-Livelihood (WELL) Nexus. Energy as lever towards a sustainably integrated resource management for Tamil Nadu’s Agricultural Sector. Accessed under: https://www. aurovilleconsulting.com/system/attachments/190813_WELL_Nexus_single.pdf?1565756467 7. TNERC. 2019. Order on Rooftop Solar Generation. Accessed under: http://www.tnerc.gov.in/orders/Tariff%20 Order%202009/2019/Solar-25-03-2019.pdf 8. TNERC. 2019. Order on Rooftop Solar Generation. Accessed under: http://www.tnerc.gov.in/orders/Tariff%20 Order%202009/2019/Solar-25-03-2019.pdf REFERENCES
  • 24. Sustainable Energy Transformation Series September 2019