We at REAR would like make you aware about the draft released by RERC i.e. RERC (Grid Interactive Distributed Renewable Energy Generating Systems) Regulations, 2020 and asked for suggestions/comments/objections on the same. We would like to draw your attention on one major section i.e. Sec (3) which is as below:-
3. Scope and Applicability
Provided that, Net Metering arrangement under these Regulations shall be allowed to LT Domestic consumers, LT Agriculture consumers and LT Public Street Lighting Service category only:
Which means after 31.03.2021, net- metering will be allowed above mentioned category only So would like focus on few probable reasons for amendment of the same or at least defer it for one year i.e. till March 2022;
1. More time required to adopt new regulations:-For consumers other than mentioned above, there should be given some more time to opt for net-metering, may be till March 2022. Going solar for C&I consumer is a capital intensive decision which cannot be taken in any hassle. We are sure if given a reasonable time, the adaptation of solar in C&I Sector will boost in one year and will contribute to the national mission.
2. Non availability of material: - Considering the present situation, wherein there is uncertainty in the prices as well as the availability of major equipments due serious supply chain level disruptions & shortage of raw materials like cells, glass, aluminium etc for the last year because of covid19 which impacted manufacturing as well as imports.
3. Sudden price hike of vital equipments: - The projects which have been finalized are also on hold due to sudden rise in prices of modules and even module mounting structure due to price hike of Iron & Steel in the last few months. Even union minister writes to PM about the possible delay in the ongoing projects under various schemes due to sudden rise in steel prices.
4. Liquidly & Cash Flow:-The Companies working in Solar Industry (mainly Residential, commercial & Industrial Sector i.e. for rooftop projects up to 1 MW) are the smaller companies mainly MSMEs which are already grappling with problems like low liquidity or cash flow amid the crisis brought in by the COVID-19 pandemic.
5. MSMEs got impacted:- As MSMEs are the backbone of any country’s economy, such rules shall completely result in the collapse of such local business. Besides, the manpower and manufacturing units in business will also be affected adversely and will incur excessive losses to already liquidity deficit companies.
6. Sudden Change is damaging for Industry :-If given a reasonable time, there would be no hue & cry among the stakeholders and people will have sufficient amount of time to decide on which arrangement they want to adopt i.e. Gross metering or Behind the meter after doing the due diligence. The shortage of time will definitely have the negative impact on the achievement of target and will de-motivate the solar Industry. Businesses are built on long term predictable policies and sudden change in policy will put the Solar Industry in trouble.
7. Negative Impact on Employment & Revenue Generation :-As per a report by NRDC & CEEW, India’s renewable energy workforce has grown five-fold in the past five years i.e. from 2014 to 2019 and acceptance of net-metering among C&I consumers played a vital role in this. It is expected to generate 450,000 jobs by 2022 to achieve the target of 175 GW. In the report, it was recommended to strengthen support for decentralized renewable energy projects such as rooftop solar, which have a higher job creation potential and the draft is totally opposite of the recommendations, which will have huge negative impact in terms of employment and revenue generation to the state.
8. Difficulty in RPO compliance by Discoms: - Discoms are already lagging to meet their RPO compliances, after this policy since the solar installation will drop further, it would be tougher for Discom to meet RPO in future.
9. Industries/Institutions having seasonal or irregular load:- Industries/Institutions having seasonal or irregular load will have no options but to reduce their capacity to 20-30% from now due to restriction on net-metering and lower tariff in gross metering, which will increase its payback by 3-4 times as compared to net-metering arrangement.
10. Should be extended to Social Sector as well as and when applicable:- The net metering may also be extended to Social Sector / Not for Profit Organization and government sector consumers like it has been done in state of Uttar Pradesh also.
Note: - Request you all to send an e-mail to firstname.lastname@example.org asap. Last date to submit comments is 15.01.2021.