The Maharashtra Electricity Regulatory Commission (MERC) had issued a draft notification to amend the existing Solar Roof-top Net Metering Policy of 2015. The new draft policy is completely discouraging the adoption of Solar Roof-top as it shall not be any more economical to invest in Solar Roof-top in Maharashtra.

Through this notification, MERC is trying to eliminate competition by killing the roof-top solar net metering arrangement which has just started gaining momentum in the state while on the other hand the Central government led by Hon'ble Prime Minister of India Mr. Narendra Modi is talking about accomplishing 40,000 MW of Roof-top Solar by 2022. Moreover, this notification, if gazetted, shall also have a huge Socio-economic impact as hundreds of employed professionals in the Solar roof-top segment shall be loosing their jobs in a matter of no time. Moreover, MSEDCL which stands to be the biggest gainer in this objective shall be left with no competition and can, in the near future, increase electricity rates at their discretion. This point needs to be noted by the competition commission of India as well.

Moreover the Section 9 of the Electricity Act of 2003 clearly states and i quote " “Notwithstanding anything contained in this Act, a person may construct, maintain or operate a captive generating plant and dedicated transmission lines Provided that the supply of electricity from the captive generating plant through the grid shall be regulated in the same manner as the generating station of a generating company. “ The commission hereby in some manner is trying to take away the fundamental right of a legitimate power user by making it mandatory to sell all power generated on the roof-top of the system owner.

Another point which we would like to clearly highlight that in the EM (Explanatory Memorandum) in Para 3

“The present regulatory framework is focused on self-consumption, and higher installation levels of GRPV systems is mainly by the commercial and industrial consumers, whose retail tariffs are  much higher than the cost of energy delivered by GRPV systems.”

The Commission here is mentioning higher retail tariffs for Industrial and commercial users, and we agree on it completely, however, the point here to be noted is that why the retail tariffs are higher?? The commission is silent on this. This is because of high Cross Subsidy Surcharge (CSS) and very abnormally high Distribution Losses. This Clearly states that (Maybe indirect) that commission is trying to recover revenue in form of CSS and other distribution losses from a Captive Generator who has already invested in their own self-generating power plants wherein their Distribution losses are almost negligible. We firmly believe that there are various bye-laws in the Electricity Act of 2003 which might probably cease the commission to enable such an arrangement of enforcing a captive generator to sell its own generated power mandatorily to the Distribution licensee.

On behalf of the all the members of Solar Association, we urge all the stakeholders of the Solar Industry to sign this petition and help us raise our concerns and strongly condemn the desired amendment and while request the Honorable Commission to continue with the existing policy of Solar Roof-top net Metering of 2015.

On behalf of Solar Association Groups, we humbly appeal to all Citizens of Maharashtra specially the Industry Owners, Commercial Entity owners to kindly Sign this petition and raise your voice against this one-sided and biased draconian Draft Regulation announced by the Regulator. Kindly send your objections to remerc@merc.gov.in and kindly mark a CC to secretary@merc.gov.in and solarassociation0@gmail.com with info mentioning "Submitting my Stern Opposition towards the draft Regulation of MERC Grid-Interactive Rooftop Renewable Energy Generating Systems".

While we strongly appeal the commission to continue with the existing Solar Roof-top Net Metering Regulations of 2015 and if there are genuine concerns of the commissions then they can discuss/share the same with the various stakeholders and come up with solutions wherein Solar players and the DISCOMS  can look forward co-exist in a more conducive environment.

Solar Association