President’s Message

Dear Member,

On behalf of the Tamil Nadu Electricity Consumers’ Association, I welcome the release of the National Generation Adequacy Plan (NGAP) 2026–27 to 2035–36 (March 2026). This Plan is a timely and vital roadmap that recognizes the twin imperatives of securing sufficient generation capacity for economic growth and accelerating the clean energy transition. For large industrial, commercial and institutional consumers who depend on stable high-voltage supply, the NGAP’s comprehensive treatment of capacity projections, reserve margins, and resource mixes offers both reassurance and a clear signal of the system changes ahead.

What we appreciate

• Evidence-based forecasting: The Plan’s load and demand-side scenarios are grounded in recent economic and electrification trends. Sensible sensitivity cases for high growth and high electrification give consumers a realistic range of outcomes to prepare for.
• Diversification of resources: The deliberate emphasis on a balanced portfolio—conventional generation for baseload/firming, expanding renewables, energy storage (short- and medium-duration), and targeted flexible gas capacity—aligns with consumers’ needs for reliability while lowering long-run costs.
• Focus on flexibility and inertia solutions: Recognition of the operational challenges of high renewable penetration (frequency control, ramping, and inertia) and concrete proposals for ancillary service markets, fast-ramping capacity, synchronous condensers and storage deployment are especially welcome.
• Attention to transmission and interconnection: Strengthening transmission, regional interconnects, and distribution reinforcement are correctly identified as critical enablers of adequacy and resilience for high-tension users.
• Stakeholder engagement and phased implementation: The plan’s staged procurement windows and iterative review points provide room to adapt as technology costs and demand trajectories evolve.

Our concerns and recommended priorities

While the NGAP is a constructive blueprint, several areas need stronger emphasis and clearer implementation pathways to protect consumers and ensure system reliability.

1. Clearer procurement timelines and risk-sharing

• Recommendation: Publish firm timelines for competitive procurement of firm capacity and storage, with transparent allocation of development and market risk. High-tension consumers need signals about potential capacity costs and the likelihood of new capacity entering service by specified epochs.

2. Firm capacity (capacity credit) methodology

• Concern: The method for assigning capacity credit to variable renewables and storage must be conservative and transparent to avoid overestimating available firm capacity.
• Recommendation: Adopt conservative, probabilistic capacity accreditation with independent verification and frequent reassessments as fleet characteristics change.

3. Ancillary services markets and pricing

• Concern: Current arrangements may not fully compensate flexibility and fast-response resources that provide essential services for large users.
• Recommendation: Fast-track market reforms to value inertia, fast frequency response, ramping capability and black-start services. Encourage contracting mechanisms that enable high-tension consumers to secure priority or dedicated reliability services where needed.

4. Transmission and interconnection delivery risk

• Concern: Transmission build-out is on the critical path. Delays will constrain the benefits of new generation and increase congestion risk for large users.
• Recommendation: Prioritise transmission projects that relieve bottlenecks affecting major industrial corridors, and create contingency plans (including targeted distributed resources and demand-side options) if transmission construction lags.

5. Affordability and cost allocation

• Concern: The transition could impose uneven cost burdens if procurement and network costs are allocated without regard to ability to pay or usage patterns.
• Recommendation: Advocate for transparent cost-allocation principles that protect trade-exposed and essential service consumers. Explore targeted subsidies, time-of-use reforms, and demand-response incentives that reduce peak-driven procurement needs.

6. Demand-side measures and industrial participation

• Opportunity: The Plan recognizes demand response and energy efficiency but should do more to mobilize large consumers as active system participants.
• Recommendation: Enable large consumers to participate in capacity markets, pay-for-performance demand-response programs, and bilateral contracts for reliability services. Encourage investment in behind-the-meter storage and controllable loads with clear revenue pathways.

The way forward: actions we will pursue

• Active engagement: The Association will participate constructively in all consultation windows, procurement design forums and regulatory rulemaking to ensure consumers’ reliability and cost concerns are heard.
• Collaborative advocacy: We will work with system operators, regulators, generators and transmission planners to accelerate firm capacity procurement, secure transmission priorities and design ancillary service markets that value flexibility.

Closing

The NGAP 2026–27 to 2035–36 is a critical step toward a reliable, cleaner power system. It balances ambition with pragmatism, but success will depend on disciplined procurement, transparent accreditation, prompt transmission delivery, and active involvement of major consumers. Our Association stands ready to collaborate with policymakers, operators and industry to turn the Plan’s promise into dependable, affordable power for the businesses and communities we represent.

With Regards,
L. Santhosh
President