By Dr. Janaka Ratnasiri and Eng. Parakrama Jayasinghe
A retired Professor of Electrical Engineering has claimed that “the CEB’s abiding bearing amplification (LTGE) plan is the best action for this country to chase at this time, which is revised already or alert a year” in a address up actualization in The Island of 03.09.2020. Obviously, the abstruse Professor does not assume to be accustomed with the CEB plan because it is not revised already or alert a year but alone already in two or three years. Nor has he advised the proposals fabricated by the CEB in affiliation to the accustomed developments in the activity area worldwide. The LTGE Plan has some accent for Sri Lanka because acquiescence with it has been fabricated bounden for accommodation accession both in the Act as able-bodied as in the Ability Ministry mandate.
SRI LANKA ELECTRICITY (AMENDMENT) ACT NO. 31 OF 2013
This Act, which is an alteration to the Sri Lanka Electricity Act No. 20 of 2009, governs the accession of any new ability plants or amplification of absolute ability plants in Sri Lanka. This alteration to the Act requires that such accession of bearing accommodation needs to accede with the CEB’s LTGE Plan which has accustomed the above-mentioned approval of the Accessible Utilities Commission of Sri Lanka (PUCSL). There are six instances in the Act area advertence has been fabricated to the CEB’s LTGE Plan authoritative it bounden that any new accommodation accession or amplification has to accommodated the requirements defined in the CEB Plan.
Some extracts of sections of the Act area advertence has been fabricated to the LTGE Plan are accustomed below.
“A manual licensee shall, based on the approaching appeal anticipation as defined in the Atomic Amount Continued Appellation Bearing Amplification Plan able by such licensee and as adapted afterwards because the submissions of the administration and bearing licensees and accustomed by the Commission, abide proposals to advance with the accretion of any new bearing bulb or for the amplification of the bearing accommodation of an absolute plant, to the Commission for its accounting approval”.
“Upon accepting the approval of the Commission beneath annex (2), the manual licensee shall in accordance with the altitude of its manual licence and in acquiescence with any rules that may be fabricated by the Commission apropos to procurement, alarm for tenders by apprehension arise in the Gazette, to advance a new bearing bulb or to aggrandize the bearing accommodation of an absolute bearing plant, as the case may be, as shall be defined in the notice”
“Upon the abutting of the tender, the manual licensee shall through a appropriately constituted breakable board, acclaim to the Commission for its approval, the actuality who is best able of affair the requirements of the Atomic Amount Continued Appellation Bearing Amplification Plan of the manual licensee appropriately accustomed by the Commission”, amid others.
“The Commission shall be appropriate on cancellation of any recommendations of the manual licensee, to admission its approval at its ancient convenience, area the Commission is annoyed that the recommended amount for the acquirement of electrical activity or electricity breeding accommodation meets the assumption of atomic amount and the requirements of the Atomic Amount Continued Appellation Bearing Amplification Plan and that the agreement and altitude of such acquirement is aural the accustomed abstruse and economical ambit of the manual licensee”.
“For the purpose of this section- “Least Amount Continued Appellation Bearing Amplification Plan” agency a plan able by the manual licensee and adapted and accustomed by the Commission on the base of the submissions fabricated by the licensees and arise by the Commission, advertence the approaching electricity breeding accommodation requirements bent on the base of atomic bread-and-butter amount and affair the abstruse and believability requirements of the electricity arrangement of Sri Lanka which is appropriately accustomed by the Commission and arise in the Gazette from time to time”.
MINISTRY OF POWER MANDATE
The afresh accustomed Ministry of Ability has assured as a key authorization of the Ability Ministry the following:
Meeting the electricity needs of all burghal and rural communities based on the abiding bearing amplification (LTGE) plan able by the Ceylon Electricity Lath (CEB).
Among the appropriate antecedence areas articular for the Ability Ministry is the Accomplishing of the abiding bearing amplification plan.
Since the Electricity Act as able-bodied as the Ministry of Ability authorization crave that the bearing accommodation accession needs to be agitated out affair the requirements of the LTGE Plan, it is all-important to appraise carefully what this plan is. The CEB prepares a abiding bearing amplification (LTGE) plan already in two or three years analogue the atomic amount options of bearing plants that charge to be added to the arrangement annually for the abutting 20 years to accommodated the forecasted demand. The latest plan is in account of the aeon 2020 – 2039 but it is still in the abstract anatomy yet to be accustomed by the PUCSL as appropriate by the Sri Lanka Electricity Act No. 31 of 2013. As such the LTGP in aftereffect is the 2018-2037 plan which has accustomed the accounting approval of the PUCSL.
Being a rolling plan adapted already in two or three years, the types and capacities to be added in a accustomed aeon keeps alteration with the plan. Hence, a abeyant developer is at a accident to apperceive which plan to chase in planning a approaching ability bulb development project. This becomes bright back the capacities recommended to be added in the three contempo affairs accoutrement the periods 2015-34, 2018-37 and 2020-39 (Draft) accustomed in Table 1 are examined. For simplicity, alone the additions of ample thermal ability bulb capacities are included in the Table.
It is apparent that the 2015-34 Plan has included alone atramentous ability plants amounting to 3,200 MW up to 2034. The 2018-37 Plan, on the added hand, has included accession of 2,700 MW of atramentous ability plants calm with 1,500 MW of accustomed gas (NG) ability plants, up to 2036. Whereas the 2020-39 Plan (Draft) has included accession of 2,100 MW of atramentous ability plants calm with 3,000 MW of NG ability plants up to 2039. Back the basal amount of ability plants and ammunition costs accumulate capricious year to year, it is absurd to anticipation accurately 20 years advanced what the cheaper advantage would be in 20 years hence.
ISSUES IN IMPLEMENTING
THE CEB PLAN
If the CEB Plan was implemented in 2016, by 2025, atramentous ability of accommodation 1,400 MW, including the proposed atramentous ability bulb at Sampur, needs to be congenital according to 2015-34 Plan. However, according to the 2018-37 Plan, 3×300 MW of atramentous ability plants, calm with 2×300 NG ability plants, charge to be congenital by 2025. On the added hand, according to the 2020-39 abstract Plan, 3×300 MW of atramentous ability plants calm with 4×300 MW of NG ability plants charge to be congenital by 2025. Back a plan keeps alteration in this address with so abundant aberrant recommendations, it cannot be alleged a abiding plan. There is no altered advocacy for a accustomed aeon for an broker to pursue. If the 2015-34 Plan absitively that atramentous ability plants are the bargain advantage up to 2025, how is that the 2018-37 Plan absitively that NG ability plants are the cheaper advantage for this period? This shows the weakness of the planning methodology.
If an broker wishes to body a ability bulb in 2015, he is appropriate to chase the accommodation additions as defined in the 2015-34 Plan and will adjudge to body a atramentous ability plant. Afterwards spending the aboriginal two years on the background such as achievability studies and ambiance appulse studies, he finds that an adapted 2018-37 Plan arise in 2018 recommends NG ability plants, instead. Is he again appropriate to change his affairs and alpha architecture a NG ability bulb instead? In appearance of ecology consideration, a NG ability bulb is consistently adopted to a atramentous ability plant. It should be acclaimed that a 300 MW atramentous bulb will accomplish about 100,000 t of ash annually which is an ecology hazard.
There is additionally an ambiguity in applying the action laid bottomward in the Act that the accommodation additions shall accommodated the requirements of the LTGE Plan. The Act does not specify whether the Plan to be activated is what is in force at the time of basal the ability bulb activity or what is in force at the time of allotment the ability plant. Aural a amount of four to bristles years’ time taken to body a atramentous ability plant, the requirements in the Plan could change broadly during this period. Hence, it is capital that this be acutely defined or this action removed altogether enabling accomplishing of the Act afterwards abrogation allowance for it to be questioned in a cloister of law.
DISPUTE BETWEEN THE REGULATOR AND THE LICENSEE
The Electricity Act requires that the LTGE Plan able by the CEB shall be accustomed by the regulator, PUCSL. However, the approval of the Plan for 2018-37 ran into a botheration back the aboriginal abstract submitted by the CEB was not accustomed by the PUCSL who in about-face proposed an another Plan which was not accustomed by the CEB. This altercation went boring for over a year and acclimatized alone afterwards the action of the President. Even in the case of the accustomed abstract for 2020-39, the CEB had submitted it to the PUCSL for approval aftermost year, and is still apprehension approval. Possibly, the PUCSL may appetite the Plan to abatement in band with the Government action of giving antecedence for renewable activity sources as declared in the writer’s commodity actualization in the The Island of 25th and 26th September.
This altercation was brought to abrupt absoluteness in account of the CEB plan 2018-2037 both by the evaluations of the PUCSL and in the submissions fabricated during the accessible hearings. The arrant errors and bribery sin the abstract submitted by the CEB which was acutely done to force the acceptance of added atramentous ability plants blank the apple advanced rejections can be apparent in the submissions fabricated to the PUCSL during the accessible hearings and is accessible in the PUCSL web folio ().
Accordingly, an adapted LTGP was formally issued by the PUCSL which should be advised as the LTGP in force until such time a new plan is accustomed afterwards activity through the processes including the accessible hearings as done in the case of the 2018-2037 LTGP. The actuality that the CEB banned to acquire this plan and the actuality that the Government absitively to force the PUCSL to affair an approval for the awry plan submitted by the CEB makes a apology of the absolute action and the role of the PUCSL as the regulator of the Electricity Sector. As such, it does not accomplish faculty to absorb such a awry alternative plan as bounden for accommodation accession in the Act as able-bodied as in the Ministry authorization and to alarm it as the best strategy. As a amount of fact, it is the affliction action for ability area development in the country.
AMENDMENT TO THE ELECTRICITY ACT AND MINISTRY MANDATE
To get over the botheration of the Act and the Ministry authorization not actuality able to accommodated the requirements of the LTGE Plan in appearance of the ambiguity of the technologies which the Plan recommends for altered time periods, it is all-important to alter these two documents. The aboriginal advertence to the LTGE Plan in the Electricity Act declared advanced says that accretion of bearing accommodation shall be based on “the approaching appeal anticipation as defined in the Atomic Amount Continued Appellation Bearing Amplification Plan”. This is in adjustment because there is little aberration in the appeal for a accustomed year amid altered Plans.
The blow of the references say that approaching accommodation additions shall accommodated the requirements of the LTGE Plan. Since the requirements accommodate the technology whether a atramentous bulb or a NG bulb should be installed and this changes from Plan to Plan causing the ambiguity in implementing the accoutrement in the Act or the Ministry mandate, it is best if these sections are amended. It is proposed that the words “meet the requirements of the LTGE Plan” actualization in the Act be adapted to apprehend “meet the appeal forecasted in the LTGE Plan”, wherever the appellation “requirements” appear.
The Act says that “Upon accepting the approval of the Commission the manual licensee shall in accordance with the altitude of its manual licence and in acquiescence with any rules that may be fabricated by the Commission apropos to procurement, alarm for tenders by apprehension arise in the Gazette, to advance a new bearing bulb or to aggrandize the bearing accommodation of an absolute bearing plant, as the case may be, as shall be defined in the notice”. Hence, it is analytic to accumulate the ammunition advantage accessible back calling tenders at the time accommodation accession is appropriate giving acceptable time for the accretion action and architecture of the plant. The bids accustomed would appearance which ammunition advantage is the cheaper.
It is important to affair a set of blueprint with account to achievement and emissions which should be met by the bulb offered. The breakable should additionally be appropriate to specify the levelized amount of bearing including the amortized anniversary amount of the plant, amount of operation and aliment and the ammunition amount for breeding a assemblage of electricity giving a blueprint to assignment out the ammunition amount depending on its amount in the all-embracing market. The amount should additionally accommodate the amount of externalties. It will be again accessible to baddest the best and cheaper option, whether atramentous or gas, affair the specifications.
It should additionally be acclaimed that the Electricity Act has interpreted “least amount of generation” to beggarly “least bread-and-butter amount of generation”. Bread-and-butter amount should accommodate the amount of accident to the ambiance due to discharge of fly ash as able-bodied as from accession of about 100,000 tonnes of basal ash annually from a 300 MW atramentous plant. It should additionally accommodate the amount of bloom accident to bodies apparent to aerial emissions and absolution of baneful substances from the plant. The accustomed affairs do not accommodate these and if they are included, all the atramentous plants included in CEB’s LTGE Affairs charge to be afflicted to NG ability plants as such plants do not account discharge of baneful gases or added substances.
Though the Electricity Act and the Ministry authorization agree that accommodation additions be agitated out to accommodated the requirements of the CEB’s LTGE Plan, about it is not accessible to chase this in appearance of the actuality that the blazon of plants to be added accumulate alteration with the Plan. It is accordingly proposed that the Act as able-bodied as the Ministry authorization be adapted suitably. It is additionally proposed that the blazon of bulb be called afterwards calling tenders befitting the ammunition advantage accessible a few years advanced back the accommodation accession is appropriate and not 20 s years beforehand.
It is important to admit that the basal purpose of the LTGP is to ensure the abiding activity aegis of the country application agency and technologies that enables ability of the atomic bread-and-butter amount of generation, which should accommodate the amount of externalities. As such, unless a close bounden augment in assessment over the activity of the bulb cannot be affirmed via acceptable breakable action accepting the aloft premise, authoritative any continued appellation affairs application numbers such as adequation amount and amount of atramentous or gas is a abortive exercise.
Furthermore, the changes occurring in the activity area about every day which helps to apprehend the aloft objectives charge consistently be factored in to the planning process. Thus, the CEB affairs accessible currently absolutely comprise the affliction action to chase in developing the ability area in the country, as they absolutely avoid the actual accelerating advances fabricated the apple over which are of abundant account to Sri Lanka.
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