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In a representation to the chairperson, Central Electricity Authority, and secretary, Ministry of Power and NRE, Government of India, with copy to the Minister for Power and NRE, and the vice chairman, NITI Aayog, Shankar Sharma, a well-known power and climate policy analyst, has said that National Electricity Plan (Draft) Generation Vol- I for years 2022-27 is another example of "missed opportunity in moving towards sustainability."
He says, the draft has "no apparent reference can be noticed to the overall welfare of all sections of our population, including flora, fauna and biodiversity; and is without objectively addressing the critical needs with regard to the worsening climate emergency".
Sharma underlines, "The massive concerns (economics as well as energy security issues) associated with the import of fossil fuels in the case of coal and natural gas power technologies; fuel and technology in the case of nuclear reactors; and of rare earth minerals for REsources and energy storage batteries, must be of critical consideration."
Text:
This has reference to the National Electricity Plan (Draft) Generation Vol- I for years 2022-27 released in Sept. 2022 for public comments. In this regard, please objectively consider my feedback, as in the PDF enclosed.I am an electrical engineer, and a power sector professional with over 4 decades of experience in India, New Zealand, and Australia, including a few years in Karnataka Electricity Board and Central Electricity Authority. I had the opportunity to provide my feedback earlier on National Electricity Policy, few generation plans, Integrated Energy Policy, and National Energy Policy.
Whereas, my detailed feedback/comments on the draft plan are as in the enclosed PDF, my brief comments for a overview of concerns are as follows:
a). Electricity generation plan in India should be seen as a critical policy document, which will have tactical and strategic importance not only for electricity production, but also for the associated T&D networks, other infrastructure facilities, and even for the end usage of electricity. In summary, if handled diligently, the generation plan can be a critical document in the overall welfare of our communities, since the electricity sector, as a whole, impacts the sustainable harnessing of natural resources, pollution/ contamination of air, water, and soil, and also the community health; and of course, our actions on addressing the fast-looming threats of climate change.
b). But I am sad to say that the present draft can be seen as yet another example of missed opportunity in moving towards sustainability, and can be seen as resulting in policy incongruence with the larger welfare perspective of our people, and many provisions of Acts, rules, policies, and of the very Constitution. It is hard to notice any qualitative improvements over the approach taken in the previous plans.
c). The objective, for the concerned authorities, seems largely to fulfil CEA's obligation under section (4) of the Electricity Act 2003; may be just in letter, but not spirit. No apparent reference can be noticed to the overall welfare of all sections of our population, including flora, fauna and biodiversity; and is without objectively addressing the critical needs w.r.t the worsening climate emergency. It is almost impossible to notice any due diligence in the consideration of the overall cost to the country by the proposed model of demand-supply scenario, which is largely based on conventional technology electricity sources; and is without any serious consideration of the overall costs and benefits analysis w.r.t every one of the available techno-economically viable options, so as to sustainably meet our legitimate demand for electricity. The absence of adequate focus on overall efficiency in the power sector, Demand Side Management and energy conservation measures can also be seen as self-evident.
d). It should be of massive concern to the people of our country, that the avoidable and humongous costs to our communities (in the form of social, environmental, and economic costs) from the ongoing policy of continuing with the demand-supply model based on conventional technologies such as fossil fuels, dam based hydro power, nuclear power, the ever growing and complex integrated power networks, and the associated infrastructures, have been rarely, if ever, deemed as worthy of diligent discussions by our authorities. It is deplorable that such a policy of what appears to be lack of due diligence/ effective consultations with the stakeholders is continuing despite the associated feedback from the public in the past.
e). It should also be a serious concern from the overall welfare perspective of our people, that there are no discussions or diligently prepared policy documents available to the public, including the present plan document draft, to satisfactorily explain as to why successive governments are continuing to invest massively on conventional technology energy sources at humongous costs to the society, and why suitable alternatives available to our society have not been implemented.
f). The massive concerns (economics as well as energy security issues) associated with the import of fossil fuels in the case of coal and natural gas power technologies; fuel and technology in the case of nuclear reactors; and of rare earth minerals for REsources and energy storage batteries, must be of critical consideration in the overall energy policy of the country and for Atma Nirbharta; but rarely, if ever, the associated issues have been objectively deliberated on in our country. The draft of the plan document is seen as no exception in this regard.
g). In the true context of an enormous number of reports/ computer simulations from around the globe on the enormous socio-economic benefits of early transition to renewable energy sources (RES), and in the context of unacceptable and unsustainable costs associated with conventional technology power sources, it is hugely deplorable that there is no policy statement or explanation as to why our authorities are persisting with the BAU scenario all these years. The concerned authorities have refused to explain as to why the draft National Energy Policy in 2017 has not been finalised yet, and how the much-touted net-zero carbon target of 2070 can be achieved without a diligent approach based on a credible timeline for smaller targets. Such continuing indifference of our authorities in sharing the applicable policy framework with the people of the country, even in critical sectors like energy/ electricity, cannot be in the true interest of our people.
h). It is interesting to notice that the draft plan itself has recorded a lot of policy statements, global experiences and data on many associated issues, which should unambiguously indicate that the BAU scenario in the power sector with continued reliance on conventional technology power sources cannot be the best option for our people, and that RES are the most attractive and sustainable source of electricity. For example: Section 6.0 of the draft plan says: “To promote human welfare with social and economic development, the supply of electricity needs to be secure and have a low impact on the environment to achieve sustainable development. Renewable energy plays a key role in achieving the set objectives, especially in mitigating climate change. Renewable energy sources are clean, inexhaustible and due to technological innovation becoming competitive with fossil fuel-based sources. Renewable energy sources are vital for combating climate change and limiting its devastating effects.”
There is no explanation as to why authorities have preferred to add massive capacities of coal and nuclear in planning
i). The draft plan itself has listed some “financial parameters” of costs associated with various power generation technologies in India under section 5.10. The capital cost of nuclear power is shown as the highest among all the available technologies, whether in capital cost, or O&M cost, or construction time. Solar and wind (onshore) are shown as having vastly better cost and benefit parameters than coal and nuclear power. Also, as per the latest report of Lazard’s Levelized Cost of Energy Analysis, the levelized cost of solar, wind PLUS energy storage facilities can be competitive or even better than new coal and nuclear.
j). The draft plan indicates that the total CO2 emissions projected will increase from 910 million tonnes in 2020-21 to 1,030 million tonnes in the year 2026-27, and to 1,180 million tonnes in 2031-32. The draft plan document has dedicated one entire chapter (Chapter7) to discuss the chronic issues associated with demand and supply of coal and natural gas for power generation, from which it is evident that due to multiple reasons, these two fuels, even with increased imports, cannot be good/ reliable sources to meet the growing demand for electricity generation, and hence the PLF of those power plants is likely to be abysmally low (only about 24% in case of gas based power plants, and about 60% in coal power plants in 2022) with huge economic consequences.
k). A glaring anomaly in the supply side discussion in this plan draft is the complete absence of information on nuclear fuel. It appears that CEA/ power Ministry has simply accepted what DAE has stated/ claimed on the “huge” potential of nuclear power (despite un-imaginably high costs to the society), and that it has no qualms about hiding the associated concerns from the public’s gaze.
l). In the context of such glaring admissions in the draft plan itself, it is deplorable that there is no explanation as to why the authorities have preferred to add massive capacities of coal and nuclear in the planning period, instead of solar and wind power capacities. There is no discussion whatsoever, as to why such massive and avoidable societal level costs associated with coal and nuclear power technologies are inevitable to our communities.
m). Global experience, as well as our own experience since independence, should clearly establish that the capital cost itself of RES is much less as compared to coal, gas and nuclear power sources; and that such a gap will continue to widen in view of the fast-dwindling fuels and environmental concerns. Small size and distributed type of RES, enabled by micro/ mini/ smart grids, will be most attractive to our communities, and only RES can be sustainable in the long-term. The calamitous implications of climate change should be at our focus in all the associated policies, practices and economic decision-making processes.
n). An issue of massive concern from the perspective of true welfare of our people is the deplorable practice of successive governments to continue to ignore the critical need to take stakeholders/ our people into confidence in all such planning documents. The concerned authorities continue to ignore the Constitutional obligation to explain how the planning details are effectively supported by relevant policy documents, and through diligent cost-benefits analysis.
All such issues of strategic importance to our communities can be well addressed only if the associated policies / practices/ decision making processes are seen as inherent parts of a diligently prepared National Energy Policy, and only if the overall objective is to keep at our focus the true welfare of all sections of our society, including flora, fauna and general environment.
l). In the context of such glaring admissions in the draft plan itself, it is deplorable that there is no explanation as to why the authorities have preferred to add massive capacities of coal and nuclear in the planning period, instead of solar and wind power capacities. There is no discussion whatsoever, as to why such massive and avoidable societal level costs associated with coal and nuclear power technologies are inevitable to our communities.
m). Global experience, as well as our own experience since independence, should clearly establish that the capital cost itself of RES is much less as compared to coal, gas and nuclear power sources; and that such a gap will continue to widen in view of the fast-dwindling fuels and environmental concerns. Small size and distributed type of RES, enabled by micro/ mini/ smart grids, will be most attractive to our communities, and only RES can be sustainable in the long-term. The calamitous implications of climate change should be at our focus in all the associated policies, practices and economic decision-making processes.
n). An issue of massive concern from the perspective of true welfare of our people is the deplorable practice of successive governments to continue to ignore the critical need to take stakeholders/ our people into confidence in all such planning documents. The concerned authorities continue to ignore the Constitutional obligation to explain how the planning details are effectively supported by relevant policy documents, and through diligent cost-benefits analysis.
All such issues of strategic importance to our communities can be well addressed only if the associated policies / practices/ decision making processes are seen as inherent parts of a diligently prepared National Energy Policy, and only if the overall objective is to keep at our focus the true welfare of all sections of our society, including flora, fauna and general environment.
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