"We would like to place on record that this proposal is highly in favour of private DISCOMs, protecting their business interest and undermining general consumers' interest and clean energy development benefits. We have submitted our objections to the commission and are hopeful of a robust and ambitious net metering policy. Further we also demand a public consultation on the revised proposal involving all stakeholders including domestic consumers," said Abhishek Pratap, Senior Campaigner, Greenpeace India.
Following are clauses in the proposal where we have serious concerns and would like the commission to look into and make suitable amendments so that both the interest of DISCOMs and consumers are protected while NCT of Delhi will be taken take out of the looming electricity crisis through massive uptake of rooftop solar.
Clause 3.2 - Capacity Limits: The proposal seeks to limit the capacity of rooftop solar PV to the sanctioned load of the consumers. There is no clear explanation given in the proposal for limiting the capacity. If the capacity is limited to the sanctioned load, then in practical sense, it is about self-consumption and nothing can be fed into the grid. The proposal, in its introduction, talks about global best practices on rooftop solar PV projects but the capacity limits are contradictory to that. Therefore, we urge DERC to amend this provision of capacity limit with sanctioned load of the consumers to available roof-space of the building.
Clause 3.4 - Restrictions on level of overall or local grid penetration: This provision seeks to limit the overall cumulative capacity to 15 % of the total capacity of the particular distribution transformer. There is no clear technical reasoning for such limitation. Although, the provision talks about large number of rooftop solar impacting the local grid from technical, safety and security issues, these do not stand convincing from technical point of view. If high number of rooftop solar proliferates in a particular distribution transformer, there will be requirement for upgrading such transformers to accept such loads. Highly efficient transformers which can accept high level of distributed generation are available in the market. Instead of upgrading local distribution infrastructure to meet the demand of rooftop solar, the provision of limiting the cumulative capacity of rooftop solar PV is not in the direction of taking NCT of Delhi out of power crisis. Therefore, we urge DERC to remove this provision from the proposal or provide higher cumulative capacity for rooftop solar PV for particular distribution transformers in the range of minimum 40 %.
Clause 4 (ii) - Energy Accounting: The provision seeks to cap electricity generated from a rooftop solar system at 90 % of the electricity consumption by the eligible consumer at the end of settlement period. On the other hand, no carry forward provision is provided to the eligible consumers. We have serious concern over this provision in the proposal as this is heavily loaded in favour of DISCOMs and will push back individual consumers from early adoption of rooftop solar. This provision in conjunction with capacity limits acts as disincentive for general consumers to go for rooftop solar and creates a disabling environment for solar energy in NCT of Delhi. Therefore, we urge DERC to remove this provision from the proposal or provide carry forward for excess electricity generation for next financial year along with this provision.
Clause 4 (iii) – Billing and Payment: The provision seeks to provide lowest applicable tariff across all slots for the consumer to feed solar electricity into the grid. This is another objectionable provision in the proposal which acts as disincentive for general consumers to go for rooftop solar. This provision also stands in contradiction with introduction of this proposal which seeks to make rooftop solar in NCT of Delhi at a global standard. General norms in global best practices are to provide highest available tariff to encourage consumers to go for solar electricity generation and feed into the grid at peak time. Therefore, we urge DERC to replace lowest applicable tariff across all slots with highest applicable tariff across all slots to create incentive for general consumers for solar electricity generation.
No mention of target: The entire proposal lacks in terms of overall vision and roadmap for development of rooftop solar PV projects in the NCT of Delhi. Although proposal seeks to establish proliferation of rooftop solar PV in Delhi, there is no mention of target for electricity generation from rooftop solar system. Therefore, we would urge DERC to provide electricity generation target from rooftop solar in the revised proposal which should be at least 2 GW by year 2020.
Notes:
Greenpeace roadmap for solar rooftop in NCT of Delhi:
http://www.greenpeace.org/india/Global/india/report/2013/Rooftop-Revolution.pdf
Greenpeace comments and suggestions on the DERC proposal on Net Metering and Connectivity with respect to Rooftop Solar PV projects
http://www.greenpeace.org/india/en/publications/Comments-and-suggestions-on-the-DERC-proposal-on-Net-Metering-and-Connectivity-with-respect-to-Rooftop-Solar-PV-projects/
Contact:
Abhishek Pratap, Senior Campaigner, Renewable Energy, Greenpeace India
Shashwat Raj, Senior Media Officer, Greenpeace India