o   This clause was not part of standard Bid document by MNRE and was added by AVVNL as an additional clause.

o   There is no such rule/act/law prevailing in Rajasthan according to which the Electrical Contractor License is mandatory for Solar Project Installation and daily a lot of projects are being interconnected with grid by Discoms without asking for any such license.

o   There are around 700 EPC players/Installers working in Rajasthan out of which around 200 EPC players are directly or indirectly working with Govt Schemes related to Solar Rooftop for the last 5-6 Years and hence, their competency as far as solar project installation is concerned could not be challenged. 

o   Since, the tender is based on SBD released by MNRE and there was no mention of requirement of Electrical contractor license as an eligibility criterion to participate in the bid. Even MNRE added an Open Category, just to give chance to new entrepreneurs; however, this clause will defeat the motive of MNRE.

o   Solar being a priority sector, govt has special emphasis on it and trying to boost the sector in all manner be it installation as well as job creation. Lot of initiatives have been taken by Govt for education, training, capacity building like Suryamitra, Skill Council for Green Jobs, NISE etc. but no where there is a requirement of Electrical contractor license to install solar.

o   There are already a vendor rating framework developed The Vendor Rating Framework (VRF) is developed by the MNRE-USAID Partnership to Advance Clean Energy Deployment PACE-D 2.0 RE Program, along with CII- Godrej Green Business Centre (CII-Godrej GBC) and the National Renewable Energy Lab (NREL). This framework will benchmark various rooftop solar (distributed solar) engineering, procurement and construction companies (EPCs or vendors) on a uniform set of parameters, which will provide a sense of the quality of the work carried out by these firms.  Electrical Contractor License is nowhere is the criteria mentioned as per the said framework.

o   Vendors are just responsible for installation of system and in no way responsible for any connectivity with grid. Discom is responsible for net-metering/ interconnection of the system with grid after proper due diligence as per the required parameters.

o   Clause 1.11 of the tender already mentions the responsibilities of empanelled vendors as far as safety is concerned, "The vendor shall take entire responsibility of electrical safety of the installations including connectivity with the grid and follow all the safety rules and regulations applicable as per Indian Electricity Act-2003 and prevailing CEA guidelines and amendments, it shall be responsibility of the vendor to take NOC from concerned authority and engage person as per provisions as per in CEA Rules and Regulations. The Empanelled vendor shall ensure proper safety of all the workmen, material, plants and equipment belonging to him/her. In case any accident occurs during the construction / erection or during guarantee period for work undertaken by Empanelled Vendor thereby causing any minor or major or fatal accident will be the responsibility of the Empanelled Vendor. The successful Vendors shall follow and comply with the employer’s safety rules relevant provisions of applicable laws pertaining to the safety of workmen, employees, plant and equipment. The Empanelled vendors shall also arrange all certificates and test reports of the module and inverter and other equipment.

o   The tender is released as per MNRE vide Order No. 318/331/2017 – Grid Connected Rooftop Dated 20th August 2019, for achieving cumulative capacity of 40 GW RTS plants by 2022 and Discoms are just working as Nodal Agencies to facilitate the smooth implementation of the Scheme without defeating the aim and objective of the scheme. 

o   Getting Electrical Contractor license in Rajasthan is very cumbersome and lengthy process and need at least Rs. 8-10 Lacs ( 7.5 Lacs Solvency for Class-B and other expenses and in no way required for solar project installations.