TAMIL NADU ELECTRICITY REGULATORY

COMMISSION

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Order on procurement of Solar power
and Related Issues

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Order No. 9 of 2020 dated 16-10-2020
 BEFORE THE TAMIL NADU ELECTRICITY REGULATORY COMMISSION
PRESENT: Thiru M.Chandrasekar - Chairman
Dr.T.Prabhakara Rao - Member
Thiru K.Venkatasamy - Member/Legal
Order No. 9 /2020, dated 16-10-2020

In the matter of : Order on procurement of Solar power and Related

issues
In exercise of the powers conferred by sections 181, 61 (h), and 86 (1) (e) of

the Electricity Act 2003, (Act 36 of 2003), read with the National Electricity Policy,

the Tariff Policy and Commission’s Power Procurement from New and

Renewable Sources of Energy Regulations, 2008, the Commission, after issue

of consultative paper for public view on “Order on procurement of Solar power

and Related issues” inviting comments from stakeholders, and after examining

the views of all stakeholders, the views expressed by the Members of the State

Advisory Committee on the Consultative Paper in the meeting held on

20/03/2020, issues this suo motu Tariff Order on Solar Power.

This order shall take effect on and from the 16th of October, 2020.

Sd./- Sd./- Sd./-

(K.Venkatasamy) (T.Prabhakara Rao) (M.Chandrasekar)
Member/Legal Member Chairman

(By Order of the Tamil Nadu Electricity Regulatory Commission)

Sd.-
(S.Chinnarajalu)
Secretary

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 CONTENTS
Para Description Page

1.0 Overview 5

2.0 Legal framework 7

2.1 Related provisions of Electricity Act,2003 7

2.2 Related provisions of National Electricity Policy 8

2.3 Related provisions of Tariff Policy 9

3.0 Competitive bidding vs preferential tariff 12

4.0 Procurement of solar power on expiry of control period 13

of solar tariff order of 2019

5.0. Issues related to open access 16

5.1 Transmission, Wheeling charges & Scheduling and 17

System operation charges and Line losses
5.2 Cross subsidy surcharge 19

5.3 Reactive Power charges 19

5.4 Grid Availability charges 20

5.4.1 Charges for start up power supplied by the Distribution 20

licensee
5.4.2 Stand by charges 20

5.5 Energy Accounting and Billing Procedure 20

5.6 Energy Wheeling Agreement and Fees 23

5.7 Security Deposit 24

5.8 Power Factor Disincentive 24

5.9 Metering 24

5.10 Connectivity and Evacuation of Power 25

5.11 Harmonics 25

5.12 Parallel Operation Charges 26

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6.0 Plant capacity limitations 26

7.0 Applicability of this order 27

8.0 Control period/Tariff period 27

9.0 Directions 27

10.0 Acknowledgment 28

Annexures

I List of stakeholders who furnished comments 29

II Summary of comments received from stakeholders 32

III List of members present in the State Advisory 47

Committee Meeting held on 20.03.2020

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 TAMIL NADU ELECTRICITY REGULATORY COMMISSION

Order on Procurement of Solar power and Related issues

1.0 Overview

1.1 Commission in exercise of the powers vested under the Electricity Act,2003

and in compliance with the mandate of the Act to promote renewable energy has

been issuing tariff orders in respect of various sources of renewable energy

since 2006. These orders on renewable energy sources covered tariff

determination for purchase of power by the Distribution licensee, its promotional

aspects and related issues.

1.2 The conducive policies of the Central and State Government for promotion

of renewable power has helped the sector achieve remarkable progress.

1.3 The total capacity of renewable power in the State is 14144.35 MW of

which solar power constitutes 4043.45 MW. The Government of India has fixed

a target of 175,000 MW of renewable capacity by 2022. The target fixed for

solar power by Government of India is 100,000 MW through deployment of

40,000 MW of rooftop solar projects and 60,000 MW of large and medium scale

solar projects. The targeted capacity for this State is 8971 MW by 2022.

Commission issued the last tariff order on solar power on 29.3.2019 vide Order

No.5 of 2019. The control period of Order No.5 of 2019 on solar power expired

on 31.3.2020. The validity of the Order No.5 of 2019 dt.29.3.2019 has been

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extended upto the date of issue of the next order vide Commission’s Order No.4

of 2020 dt.31.3.2020.

1.4 Preferential tariffs played a major role in promoting solar power in the initial

stage. Over the last few years, there is a shift from the feed in tariff regime to

tariff based competitive bidding and reverse auctions. The price per unit of solar

power which was around Rs.4 fell to Rs. 2.97 per unit in February 2017 in the

bidding conducted for the Rewa Solar power plant in Madhya Pradesh and fell

further to Rs.2.44 per unit in the auction held for the Bhadla Solar park in

Rajasthan in May 2017. Since then, the tariffs obtained through competitive

bidding and reverse auctions have hovered around Rs.3 per unit.

1.5 The Solar Energy Corporation of India (SECI) has been conducting

competitive biddings for solar power and many projects have been contracted

through reverse auctions. The tender awarded by SECI to develop 2 GW solar

power projects with manufacturing facility for 500 MW in December 2019 (Azure

power) was at a tariff of Rs.2.92 per unit. The DISCOMS in many of the States

have commenced procurement of solar power through State conducted biddings

and are also purchasing solar power through the biddings conducted by SECI.

1.6 Commission issued a consultative paper discussing the approach for

procurement of solar power by the Distribution Licensee and on related issues of

open access and invited comments from stakeholders. Commission also

conducted a State Advisory Committee meeting and discussed the issues in the

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consultative paper. The list of stakeholders who furnished comments is annexed

with this order as Annexure I and the summary of the comments received from

the stakeholders is annexed as Annexure II. The list of members present at the

State Advisory Committee (SAC) meeting held on 20/03/2020 is enclosed as

Annexure III. Considering the important comments/suggestions received from the

stakeholders and the SAC Members, legal provisions, present scenario in the

country, orders passed by other State Electricity Regulatory Commissions,

Central Electricity Regulatory Commission, Commission issues this order after

due deliberations.

2.0 Legal framework:

2.1 Related Provisions of Electricity Act, 2003

2.1.1 Relevant provisions of Electricity Act, 2003 are reproduced below:

“Section 3(1): The Central Government shall, from time to time, prepare the National
Electricity Policy and tariff policy, in consultation with the State Governments and the
Authority for development of the power system based on optimal utilisation of resources
such as coal, natural gas, nuclear substances or materials, hydro and renewable sources
of energy.

Section 61: The Appropriate Commission shall, subject to the provisions of this Act,
specify the terms and conditions for the determination of tariff, and in doing so, shall be
guided by the following, namely:-

……………………………………………………………………………………………

(h) the promotion of cogeneration and generation of electricity from renewable

sources of energy;

(i) the National Electricity Policy and tariff policy:

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Section 62(1): The Appropriate Commission shall determine the tariff in accordance
with the provisions of this Act for –

(a) supply of electricity by a generating company to a distribution licensee:

Section 62(2): The Appropriate Commission may require a licensee or a generating

company to furnish separate details, as may be specified in respect of generation,
transmission and distribution for determination of tariff.

Section 62(5): The Commission may require a licensee or a generating company to

comply with such procedure as may be specified for calculating the expected revenues
from the tariff and charges which he or it is permitted to recover.

Section 63: Notwithstanding anything contained in section 62, the Appropriate Commission
shall adopt the tariff if such tariff has been determined through transparent process of bidding
in accordance with the guidelines issued by the Central Government.

Section 86(1)(e): The State Commission shall promote cogeneration and generation of
electricity from renewable sources of energy by providing suitable measures for
connectivity with the grid and sale of electricity to any person, and also specify, for
purchase of electricity from such sources, a percentage of the total consumption of
electricity in the area of a distribution licensee;”

2.2 Related Provisions of National Electricity Policy

2.2.1 Relevant provisions of National Electricity Policy are reproduced below:

“Section 5.2.20 Feasible potential of non-conventional energy resources, mainly small

hydro, wind and bio-mass would also need to be exploited fully to create additional
power generation capacity. With a view to increase the overall share of non-conventional
energy sources in the electricity mix, efforts will be made to encourage private sector
participation through suitable promotional measures.

Section 5.12.2 The Electricity Act 2003 provides that co-generation and generation of
electricity from non-conventional sources would be promoted by the SERCs by providing
suitable measures for connectivity with grid and sale of electricity to any person and also
by specifying, for purchase of electricity from such sources, a percentage of the total
consumption of electricity in the area of a distribution licensee. Such percentage for
purchase of power from non-conventional sources should be made applicable for the
tariffs to be determined by the SERCs at the earliest. Progressively the share of

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electricity from non-conventional sources would need to be increased as prescribed by
State Electricity Regulatory Commissions. Such purchase by distribution companies shall
be through competitive bidding process. Considering the fact that it will take some time
before non-conventional technologies compete, in terms of cost, with conventional
sources, the Commission may determine an appropriate differential in prices to promote
these technologies.”

2.3 Related Provisions of Tariff Policy

2.3.1 Relevant provisions of Tariff Policy, 2016 are reproduced below:

Para 6.4 “(1) Pursuant to provisions of section 86(1)(e) of the Act, the Appropriate
Commission shall fix a minimum percentage of the total consumption of electricity in the
area of a distribution licensee for purchase of energy from renewable energy sources,
taking into account availability of such resources and its impact on retail tariffs. Cost of
purchase of renewable energy shall be taken into account while determining tariff by
SERCs. Long term growth trajectory of Renewable Purchase Obligations (RPOs) will be
prescribed by the Ministry of Power in consultation with MNRE.

……….

(i) Within the percentage so made applicable, to start with, the SERCs shall also reserve
a minimum percentage for purchase of solar energy from the date of notification of this
policy which shall be such that it reaches 8% of total consumption of energy, excluding
Hydro Power, by March 2022 or as notified by the Central Government from time to
time.

………

(iii) It is desirable that purchase of energy from renewable sources of energy takes place
more or less in the same proportion in different States. To achieve this objective in the
current scenario of large availability of such resources only in certain parts of the
country, an appropriate mechanism such as Renewable Energy Certificate (REC) would
need to be promoted. Through such a mechanism, the renewable energy based generation
companies can sell the electricity to local distribution licensee at the rates for
conventional power and can recover the balance cost by selling certificates to other
distribution companies and obligated entities enabling the latter to meet their renewable
power purchase obligations. The REC mechanism should also have a solar specific REC.

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 (iv) Appropriate Commission may also provide for a suitable regulatory framework for
encouraging such other emerging renewable energy technologies by prescribing separate
technology based REC multiplier(i.e granting higher or lower number of RECs to such
emerging technologies for the same level of generation).Similarly, considering the
change in prices of renewable energy technologies with passage of time, the Appropriate
Commission may prescribe vintage based REC multiplier (i.e granting higher or lower
number of RECs for the same level of generation based on year of commissioning of
plant).

(2) States shall endeavor to procure power from renewable energy sources through
competitive bidding to keep the tariff low, except from the waste to energy plants.
Procurement of power by Distribution Licensee from renewable energy sources from
projects above the notified capacity, shall be done through competitive bidding process,
from the date to be notified by the Central Government.

However, till such notification, any such procurement of power from renewable energy
sources projects, may be done under Section 62 of the Electricity Act, 2003.”

2.4 Regulation 4 of the Power Procurement from New and Renewable Sources
of Energy Regulation, 2008, specifies as follows:

“(1) The Commission shall follow the process mentioned below for the determination of
tariff for the power from new and renewable sources based generators, namely;-

a) initiating the process of fixing the tariff either suo motu or on an application filed by
the distribution licensee or by the generator.
b) inviting public response on the suo motu proceedings or on the application filed by the
distribution licensee or by the generator.
c) (Omitted)
d) issuing general / specific tariff order for purchase of power from new and renewable
sources based generators.

“(2) While deciding the tariff for power purchase by distribution licensee from new and
renewable sources based generators, the Commission shall, as far as possible, be guided
by the principles and methodologies specified by:
(a) Central Electricity Regulatory Commission
(b) National Electricity Policy

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(c) Tariff Policy issued by the Government of India
(d) Rural Electrification Policy
(e) Forum of Regulators (FOR)
(f) Central and State Governments

(3) The Commission shall, by a general or specific order, determine the tariff for the
purchase of power from each kind of new and renewable sources based generators by the
distribution licensee. …
Provided where the tariff has been determined by following transparent process of
bidding in accordance with the guidelines issued by the Central Government, as provided
under section 63 of the Act, the Commission shall adopt such tariff.
…….”

2.5 Since the issue of the consultative paper, the Central Electricity Regulatory

Commission has issued the RE Tariff Regulations 2020 on 23.6.2020. The

Central Commission in its Regulations on Tariff determination for renewable

energy sources has not fixed any generic tariff for wind and solar power.

2.6 CERC in the Statement of reasons provided for the RE Tariff Regulations

2020 has observed as follows:

“..As regards determination of generic tariff for solar PV projects and wind projects, the

Commission is of the view that under the prevailing market conditions, when most of the

solar and wind projects are being set up primarily through competitive bidding,

determination of generic tariff based on norms will not provide right price signals…”

However, the Central Commission has set financial and operational norms that

would serve as ceiling norms for determination of project specific tariff.

2.7 Government of India has issued guidelines for tariff based competitive

bidding process for procurement of power from grid connected solar power

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projects vide resolution No. 23/27/2017-R&R-1 dt.3.8.2017 and amendments

issued from time to time.

3.0 Competitive bidding vs preferential tariff

3.1 In the Order No.2 of 2016, Commission permitted the distribution licensee to

procure solar power through competitive bidding following Government of India

guidelines if better rates than that determined by the Commission could be

realized. Subsequently, Commission accorded approval to the Distribution

licensee to proceed with reverse bidding fixing the preferential tariff as the ceiling

price. In the subsequent orders issued by the Commission every year from 2017

to 2019, Commission has determined feed in tariffs that reflect the market price,

keeping in view of the statutory provisions of the Act that provide for

determination of tariff and the fact that the tariff could serve as a ceiling price

for procurement of solar power by the Distribution Licensee.

3.2 SECI has been consistently conducting competitive biddings since the year

2017. NTPC and many of the States have conducted competitive biddings and

awarded the contracts for development of solar power plant. To mention a few,

the Maharashtra ERC has approved State bid tariffs under section 63 of the

Electricity Act 2003 at prices ranging from Rs.2.90 to Rs.3.30 per unit in May

2020. Gujarat ERC in July 2020 has adopted tariffs of Rs.2.61, Rs.2.62 and

Rs.2.64 discovered in the biddings conducted by Gujarat Urja Vikas Nigam Ltd..

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The tariffs discovered through bidding for the past two years are all less than the

National level Average Pooled Power Purchase Cost and are generally lower

than cost plus tariffs.

4.0 Procurement of solar power on expiry of control period of solar tariff

order of 2019

4.1 The Electricity Act, 2003, the National Electricity Policy and the Tariff Policy

2016 all have key enabling provisions that facilitate competitive bidding and

these stipulations on competitive bidding aim to provide electricity at reasonable

and competitive rates. With different tariffs being discovered in each competitive

bidding, most State Electricity Regulatory Commissions have not determined

tariffs under the regulated mechanism but have preferred procurement through

competitive bidding. The Central Electricity Regulatory Commission has not

determined any generic tariff for solar power since 2017. Karnataka Electricity

Regulatory Commission determined solar tariff for grid connected solar PV

projects less than 5 MW capacity in the order dt.1.8.2019 at Rs.3.08 per unit

effective till 31st March 2020. The validity of the above order has been extended

upto 31st March 2021. Many other State Electricity Regulatory Commissions

have adopted the tariffs discovered through competitive biddings by the

DISCOMS or the tariffs discovered in the competitive biddings conducted by

SECI. Commission has also approved Distribution Licensee’s proposal for

purchase of solar power from SECI at a tariff of Rs.2.78 per unit in June 2020.

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4.2 The Tamil Nadu Solar Energy Policy 2019 (para 8.1.1) states, “The solar

energy is fed into the grid for energy sales to the distribution licensee or a third

party under the open access facility or for captive consumption under open

access. In the case of distribution licensees, the solar energy fed into the grid will

be purchased by the distribution licensee at the prevailing solar energy tariffs as

determined by the TNERC or a tariff determined by a bidding process….”

4.3 Suggestions from stakeholders vary from welcoming the step towards

competitive bidding to requesting the Commission to determine tariffs for

capacities below 5 MW. One of the stakeholders have remarked that there is a

declining trend in the number of solar projects owing to the artificially low prices

discovered in competitive bidding that has caused re-negotiation of PPAs by

DISCOMS and is of the view that after the removal of ceiling for bidding, the

tariffs may increase to the level of Rs.3.50 per unit. Views of the Commission are

dealt in para 4.5 of this order.

4.4 Para 2.1 of Guidelines of tariff based competitive bidding process for

Procurement of power from Grid connected Solar power projects is extracted

below:

“2.1 Applicability of guidelines:

2.1.1. These Guidelines are being issued under the provisions of Section 63 of the

Electricity Act, 2003 for long term procurement of electricity by the „Procurers‟, from

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grid-connected Solar PV Power Projects (‘Projects’) having size of 5 MW and above,

through competitive bidding.”

4.5 Competitive bidding process is a transparent process that may reduce the

power procurement cost of the licensee and also take care of consumer interest

due to the fact that they capture the market conditions. The project developers

utilize the resources adopting advanced and efficient technology. The tariffs

being discovered through competitive biddings are generally lower than cost plus

tariffs. Ministry of New and Renewable Energy has recently removed the ceiling

tariffs in a competitive bidding process. This may aid in awarding contracts to

viable projects of any capacity.

4.6 In view of the reasons mentioned above, and keeping in view the principles

and provisions on competitive bidding in the Tariff Policy, Electricity Act 2003,

Commission’s Regulations and the Central Commission’s Regulations,

Commission permits procurement of solar power by the Distribution Licensee,

for compliance of RPO requirement, through the competitive bidding route under

section 63 of the Electricity Act 2003 following the bidding guidelines issued by

the Central Government by adopting ceiling tariffs that are obtained in the Tariff

based competitive bidding process conducted by SECI and approved by the

Commission for adoption. If the competitive bidding is not successful, the

licensee may go for a bidding without prescribing a cap after obtaining prior

approval from the Commission to conduct the bidding. The Distribution licensee

may also procure power from the projects contracted through competitive

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bidding process by SECI, the nodal agency that floats tenders and conducts e-

reverse auction for procurement of power from solar and wind power projects,

with prior approval of the Commission. In the case of smaller capacity plants not

covered in the bidding guidelines, the licensee may conduct a separate

competitive bidding seeking prior approval from the Commission.

4.7 For any deviation from the bidding guidelines, the Licensee shall obtain prior

approval from the Commission. Where the licensee conducts the bidding, Energy

Purchase Agreement, billing and payment shall be as per the terms in the

bidding. Sharing of CDM benefits shall be at 100% in the first year and thereafter

reduced by 10% every year till the sharing becomes equal(50:50) between the

developer and consumer

4.8 If the rates obtained are comparable and below the variable cost of power

from conventional fuel based power sources, the licensee may procure over and

above the limit of the RPO.

5.0 Other related issues for projects under captive wheeling/open access

1. Open access charges – Transmission and Wheeling, Line losses

2. Cross subsidy surcharge

3. Reactive power charges

4. Grid availability charges

5. Energy Accounting and Billing Procedure

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6. Energy wheeling agreement and fees

7. Security Deposit

8. Power factor disincentive

9. Metering

10. Connectivity and evacuation of power

11. Harmonics

12. Parallel Operation charges

5.1 Transmission, Wheeling charges & Scheduling and System operation

charges and Line losses

5.1.1 Transmission, Wheeling and Scheduling & System Operation charges are

generally regulated by the Commission’s Tariff regulations, Open access

regulations and Commission’s order on open access charges issued from time to

time. However, as a promotional measure, under section 86(1) (e) of the Act, the

Commission in the first three tariff orders adopted 30% in each of the

transmission, wheeling and scheduling and system operation charges, 40% in

the order dt.28.3.2018 and in the last tariff order No.5 of 2019 dt.29.3.2019,

Commission adopted 50% of that applicable for conventional power in each of

the charges.

5.1.2 The tariffs of solar power are lower than that of conventional power plants.

The concessions granted are being subsidized by other users of the network and

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ultimately borne by the consumers. In the consultative paper, Commission

proposed to levy 100% of the charges applicable for conventional power in each

of the charges i.e transmission, wheeling charges, scheduling and system

operation charges. Stakeholders have viewed that levy of charges to the extent

of 100% as applicable for conventional power increases the per unit charges

from 46 paise to 92 paise, and given the low yield in solar power generation

caused by diurnal variations, this may affect the viability of the project. Many of

the stakeholders have suggested to retain the existing charges.

5.1.3 It is seen that the stakeholders have evaluated the increase in charges

against the solar tariff of Rs. 3 per unit whereas the actual adjustment of power

generated is against the retail tariff. Concessions provided to the solar power

generators actually devolve on other stakeholders. Concessions can at best be

provided during the initial stages of development of solar power projects.

However, in view of the widespread situation caused by covid 19 pandemic with

many restrictions in place for movement of public and lockdown announced by

the Central/State Governments, Commission decides to retain the rates of open

access charges as per the order No.5 of 2019. The levy of charges shall be at

50% of that applicable for conventional power in each of the charges i.e

transmission, wheeling charges, scheduling and system operation charges.

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5.1.4 In respect of the plants availing Renewable Energy Certificates (REC),

100% of the respective charges as specified in the relevant orders shall apply.

5.1.5 Apart from these charges, the SPGs shall have to bear the actual line

losses in kind as specified in the respective orders of the Commission and as

amended from time to time.

5.2 Cross subsidy surcharge

5.2.1 The Commission in its other tariff orders related to different sources of

renewable power and in the orders for solar power has increased the levy of

cross subsidy surcharge fixed initially at 50% to 60% and then to 70% in the last

tariff order issued in order No.5 of 2019 to third party open access consumers. In

the consultative paper issued, Commission proposed to levy 100% of cross

subsidy surcharge applicable to conventional power. Many stakeholders have

requested to retain the existing cross subsidy surcharge i.e at 70%. Commission

decides to retain existing rates of levy of cross subsidy surcharge. The levy of

cross subsidy surcharge shall be at 70% of the charges applicable to

conventional power

5.3 Reactive Power Charges

5.3.1 Commission decides to adopt the reactive power charges as specified in

its Order on Open Access charges issued from time to time.

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5.4 Grid Availability Charges

5.4.1 Charges for the start-up power supplied by the distribution licensee

5.4.1.1 The question of start up power does not arise for Solar PV generators.

Any Power drawn during the non generating period of solar power i.e beyond

7.00 AM to 6.00 PM shall be charged at HT industrial tariff. Power drawn during

the solar generating period of 7.00 AM to 6.00 PM in excess of generation shall

also be charged at HT industrial tariff.

5.4.2 Stand by charges

5.4.2.1 If the drawal by the captive user or third party buyer exceeds generation,

the energy charges and demand charges shall be regulated as per the

Commission’s Open Access regulation and Commission’s regulations on

Deviation Settlement Mechanism (DSM) and other relevant orders.

5.5 Energy Accounting and Billing Procedure

5.5.1 The energy accounting shall be regulated by the Commission’s

Regulations on open access, DSM and Order on open access. If a solar power

generator utilizes power for captive use or if he sells it to a third party, the

distribution licensee shall raise the bill at the end of the billing period for the net

energy supplied.

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5.5.2 In the consultative paper, Commission proposed to adopt the provisions in

the Tamil Nadu Solar Policy 2019 for all those SPGs commissioned from the

date of this order i.e wheeling of energy for solar power will be permitted only

during the generation of electricity and will be adjusted slot/block to slot/block for

the billing period, and to charge excess consumption at the tariff applicable to

the consumer subject to the terms and conditions of supply. Commission also

proposed a cap on payment for unutilized energy generated.

5.5.3 Most of the stakeholders have requested to retain the energy accounting

as in the previous tariff orders citing financial impacts that would be caused, the

fact being investments were made keeping in mind the provisions at the time of

commissioning of the power plant. Some of the stakeholders have pointed out

that solar energy generation is more predictable than wind energy generation,

and therefore to remove the cap on excess generation and permit adjustment of

energy from higher to lower slot. The Solar power projects with advanced

technology in generation and conversion capacity of invertors are capable of

producing constant generation. The generated energy is being adjusted against a

retail tariff higher than the cost of generation of solar power. The provisions in the

Solar Policy 2019 could well be implemented.

5.5.4 However, on account of the unprecedented situation that arose due to

the outbreak of the covid19 pandemic with many restrictions in pubic movement

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in place, Commission decides not to amend the energy accounting procedure

being followed.

5.5.5 The Energy accounting procedure as specified in the Order No. 5

of 2019 dt.29.3.2019 is retained.

5.5.6 Commission has notified the Regulations on Deviation Settlement

Mechanism(DSM) for RE wind and Solar, and all other sources on 20.3.2019.

The commercial mechanism will come into effect from a date to be notified by the

Commission. Till such time the DSM is implemented in the State, if a solar power

generator utilizes power for captive use or if he sells it to a third party, the

distribution licensee shall raise the bill at the end of the billing period for the net

energy supplied. The licensee shall record the slot wise generation and

consumption during the billing period. Slot wise adjustment shall be for the billing

period. Peak hour generation can be adjusted to normal hour or off peak hour

consumption of the billing period and normal hour generation can be adjusted to

off peak hour consumption of the billing period. Excess consumption will be

charged at the tariff applicable to the consumer subject to the terms and

conditions of supply.

5.5.7 When DSM is implemented, the licensee shall record the time block wise

generation and consumption during the billing period. Time block wise

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adjustment shall be made for the billing period. Excess consumption will be

charged at the tariff applicable to the consumer subject to the terms and

conditions of supply.

5.5.8 After the billing period, the excess energy generated but not consumed,

may be sold at the rate of 75% of the respective solar tariff fixed by the

Commission in the respective orders to the generators and where no tariff is fixed

at 75% of latest tariff discovered in the competitive bidding. If there are more

than one tariffs discovered through bidding process, the weighted average tariff

shall be considered for payment.

5.5.9 Capping of solar generating capacity - Commission decides not to

implement any cap on payment for the excess generation/unutilised energy.

5.6 Energy Wheeling Agreement and fees

5.6.1 The format for Energy Wheeling Agreement, application and agreement

fees, procedure and terms & conditions shall be governed by Commission’s

following regulations in force and as amended from time to time:

1. Tamil Nadu Electricity Regulatory Commission’s Grid Connectivity and Intra

State Open Access Regulations, 2014

2. Power Procurement from New and Renewable Sources of Energy

Regulations, 2008.

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5.7 Security deposit

5.7.1 As regards the security deposit to be paid by captive /third party user, the

Commission proposes to retain the present arrangements i.e. charges

corresponding to two times the maximum net energy supplied by the distribution

licensee in any month in the preceding financial year shall be taken as the basis

for the payment of security deposit.

5.8 Power Factor disincentive

5.8.1 Power factor disincentive may be regulated for the power factor recorded

in the meter at the user end as specified in the relevant regulations/orders in

force.

5.9 Metering

5.9.1 The Commission proposes that metering and communication shall be in

accordance with the following regulations in force and any specific orders of the

Commission on metering and ABT whenever issued:

(1) Central Electricity Authority (Installation and Operation of Meters) Regulations

2006 and as amended from time to time.
(2) Tamil Nadu Electricity Distribution and Supply Codes
(3) Tamil Nadu Electricity Grid Code
(4) Tamil Nadu Electricity Regulatory Commission’s Grid Connectivity and Intra
State Open Access Regulations, 2014

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5.10 Connectivity and Evacuation of power

5.10.1 The provisions contained in Central Electricity Authority (Technical

Standards for Connectivity to the Grid) Regulations,2007 and Central Electricity

Authority (Technical Standards for Connectivity of the Distributed Generation

Resources) Regulations,2013, and its amendments shall be complied with. The

connectivity and power evacuation system shall be provided as per the Act/

Codes/ Regulations/orders in force.

5.11 Harmonics

5.11.1 The SPGs shall follow the CEA (Technical Standards for Connectivity of

the Distributed Generation Resources) Regulations,2013 in respect of

harmonics. It is the responsibility of the generator to provide adequate filtering

mechanism to limit the harmonics within the stipulated norms. It shall be done

before connecting the generator to the grid and the harmonics shall be measured

by the respective distribution licensee during the commissioning. If the SPGs

inject the harmonics beyond the stipulated limit, they shall pay a compensation of

15% of applicable generation tariff rate to the distribution licensee in whose area

the plant is located till such time it is reduced within the stipulated limit. The

distribution licensee is responsible for measurement of harmonics with standard

meters and issue notices for payment of compensation charges if the harmonics

is beyond the stipulated limit. In the consultative paper, a minimum of 15 days

notice period was proposed for payment of compensation charges. Stakeholders

25
have requested for a time period of 90 days for payment of compensation

charges. Commission decides that a minimum of 30 days notice period shall be

given for payment of compensation charges.

5.12 Parallel operation charges

5.12.1 In the consultative paper, levy of 100% parallel operation charges to the

SPGs who require parallel operation was proposed. In view of the economic

slowdown, Commission decides to retain the existing rates. The SPGs who opt

for parallel operation with the grid shall pay 50% of applicable parallel operation

charges to the distribution licensee as specified in relevant regulations/orders of

the Commission.

6.0 Plant Capacity limitations

6.1 The Commission in previous tariff orders for solar power have limited the

purchase by the distribution licensee from solar power plants of 1 MW capacity

and above. The Commission decides to adopt the same in this order also.

Commission decides that the solar projects covered by this order shall be of

capacity 1 MW and above.

26
7.0 Applicability of this order

7.1 This Order shall come into force from the date of issue i.e from

16.10.2020. The open access charges and other terms and conditions specified

shall be applicable to all the SPGs, irrespective of their date of commissioning.

8.0 Control period/Tariff period

8.1 Regulation 6 of the Power Procurement from New and Renewable

Sources of Energy Regulations, 2008 of the Commission specifies the

following:

“The tariff as determined by the Commission shall remain in force for such

period as specified by the Commission in such tariff orders and the control

period may ordinarily be two years.”

8.2 The Commission decides that the control period of this order shall be until

31.3.2021 and the tariff period shall be as per the bidding guidelines.

9.0 Directions

9.1 Quarterly reports on the quantum of energy wheeled from the solar

generators for captive consumption and third party sale, and on the quantum of

excess generation and payments made shall be furnished to the Commission

by Tamil Nadu Transmission Corporation(TANTRANSCO)/State Load Despatch

Centre(SLDC). Similar report on the solar energy purchased shall be furnished

by the distribution licensee.

27
10.0 Acknowledgement

10.1 The Commission acknowledges with gratitude the contribution of the

officers and staff of the Commission, the valuable guidance provided by the SAC

members and the efforts taken by the stakeholders in offering their suggestions.

The Commission is indebted to the valuable inputs offered by the Tamil Nadu

Generation and Distribution Corporation Ltd.

(By order of Tamil Nadu Electricity Regulatory Commission)

Sd./-
(S.Chinnarajalu)
Secretary
Tamil Nadu Electricity Regulatory Commission

28
 Annexure I

S.No. Name / Organisation

1. Thriu.N.Murugesan, President, The South India Spinners Association,

Coimbatore.

2. Thiru.S.Neelakanta Pillai, Madipakkam, Chennai – 600091.

3. Thiru.R.Ethiraj, Director / Generation, TANGEDCO, Chennai

4. Dr.K.Selvaraju, Secretary General, The Southern India Mills

Association, Coimbatore – 641018.

5. Thiru.L.Narasim Prasad, Chief Advisor / Systems & Operations –

Director ( Systems & Operations) Chennai Metro Rail Ltd, Koyambedu,
Chennai -600 107.

6. Thiru.Martin Scherfler, Co-founder, Auroville Consulting, Auroville, Tamil

Nadu – 605101.

7. Thiru.N.Pradeep, Vice President, Tamil Nadu Electricity Consumer’s

Association, Coimbatore – 641018.

8. Chief General Manager / Commercial, NLC India Limited, Chetpet,

Chennai – 600 031.

9. M/s. Dev International, Coimbatore – 641048.

10. M/s.Grand Solar Pvt Ltd, Sun In Power On, Kilpauk, Chennai – 600 010.

11. Thiru.P.M.Ramesh

12. Thiru.K.M.Senthil

13. Thiru.R.Sri Harshan

14. Thiru.R.M.Azhal

15. Thiru.G.Vinoth

16. Thiru.S.Balashankar
29
17. Thiru.S.Kamal

18. Thiru.J.Kesavaraj

19. Thiru.S.Shanmuga Rajavel

20. M/s.R.S.Yarns and Power Private Limited,P.N.Road, Tirupur – 641602.

21. M/s.Tamil Nadu Solar Power Generators Association, Nandanam,

Chennai – 600036
.
22. M/s.Tamil Nadu Solar Energy Developers Association, T.Nagar,
Chennai - 600 017.

23. M/s.National Solar Energy Federation of India, New Delhi – 110019.

24. Thiru.U.Arunachalam, Managing Director, Kovai Solar Power Private

Limited & Southern Power Solutions, Coimbatore.

25. M/s.Swelect Energy Systems Limited, Mylapore, Chennai – 600004.

26. M/s.Greenam Energy Private Limited, Guindy, Chennai – 600032.

27. M/s.Southern Power Solutions, Peelamedu, Coimbatore – 641004.

28. M/s.Kovai Solar Power (P) Ltd, Coimbatore – 641018.

29. Thiru.R.Veeraprakash

30. Thiru.S.Sahayaraj, Chief Executive Officer, Euphoria Green

Technologies.

31. Thiru.Kalkibharadan

32. M/s.U-Solar Clean Energy Solutions, Pvt Ltd, Bangalore – 560001.

33. M/s.India Tax Payer, Coimbatore – 641002.

34. Members of TamilNadu Solar Power Generator’s Association

(TANSPA), Chennai.

35. M/s.Distributed Solar Power Association, New Delhi – 110020.

30
36. Thiru.S.Jeyabalan, Managing Director, JK Solar, JK Technology,
Madurai – 625020.

37. M/s.Statkraft Markets Private Limited, New Delhi – 110017.

38. Thiru.K.M.Senthil

39. Thiru.K.S.Venkatagiri, Executive Director, Confederation of Indian

Industry, Hyderabad – 500084.

40. CBPUR Renewable Energy Projects Pvt. Ltd.

41. Thiru.Deepak Krishnan, Associate Director, Energy Program, World

Resources Institute India, Bengaluru- 560004.

42. M/s.Continuum Wind Energy (India) Pvt Ltd, Egmore, Chennai –

600008.

43. Dr.Anoop Singh,Professor,Centre for Energy Regulation,IIT,Kanpur.

44. M/s.TVS Eurogrip

45. Citizen consumer and civic Action Group,Chennai

31
 Annexure II

Abstract of comments received from stakeholders on the Consultative

Paper on ‘Procurement of Solar power and Related issues’

1. Procurement of solar power

Prayas (Energy Group)

The competitive bidding route is a welcome step and should be the default mode
of procurement going forward. Commission may also consider directing the
DISCOMs to appropriately modify the bidding documents so that procurement is
not just based on least cost of generation, but could better reflect the best value
for the TN system considering its load shape and other aspects like need for
flexibility, transmission availability etc. Given the changing demand-supply mix in
the state, the Commission may also consider directing the DISCOMs to initiate
competitive bidding based procurement of RE + Storage capacity in the future.

Statkraft

There is a declining trend in solar investment in the country and Tamil Nadu state
in last two years owing to artificially low tariffs discovered in few central agencies
conducted bids which have led to a plethora of issues for the existing and
prosperous developers with Discoms re-negotiating signed PPAs, introducing
unreasonably low ceiling tariffs in bids etc. There has been a reduction in the rate
of decline of in solar module costs and this has been offset by various factors like
unfavorable exchange rates, increasing cost of capital, increased difficulty and
cost for procuring land etc. This has now led to the Hon’ble Ministry of New and
Renewable Energy removing the ceiling tariff provisions from bids to be
conducted henceforth. The tariffs are expected to increase to levels of around
Rs.3.5/kWh.

32
Thiru A.D.Thirumurthy
Commission shall not allow bidding for procurement of solar power unless the
distribution licensee submits a report on RPO met till such date and future
requirement. DISCOM shall include generation from rooftop solar plant (under
Net Feed-in and net meter category) and also captive consumption category.

Auroville Consulting, Citizen consumer and civic Action Group

Cost plus tariffs may be considered for small and medium solar energy capacity.
As per Tamil Nadu Solar Energy Policy gross feed in shall be allowed at all
voltage levels. This calls for gross feed-in tariffs that consider real cost of small
and medium capacity solar generation. Solar feed in tariffs may be determined
for capacity ranges of (1-10 KW),(11-100 KW),(101-500 KW)(501-1000 KW)
utilizing MNRE benchmark costs.

Tamil Nadu Electricity Consumer’s Association(TECA)

Has requested to fix tariff for projects upto a capacity of 25 MW. Capping of
1 MW for Solar rooftops may be removed.

The Southern India Mills Association(SIMA)

Has requested to fix the feed in tariff citing low tariffs in competitive bidding.

CBPUR Renewable Energy Projects Pvt. Ltd.

The size of the projects impacts the economies of scale and is a main factor in
determination of tariff that affects the feasibility of Solar power projects. Cost per
MW for a 50/100MW project cannot be taken as a benchmark for a 1 or 2MW
project.

33
TANGEDCO
Citing MNRE’s clarification letter dt.12.1.2018 which clarified that States can
consider procuring power from solar and wind projects of less than the defined
threshold in the bidding guidelines through feed in tariff, and the RPO targets
fixed, TANGEDCO has requested to fix feed in tariffs for solar projects of
capacity upto 5 MW. For capacity above 5 MW, TANGEDCO has concurred to
procure power through the bidding route of through SECI.

Other Stakeholders
Few other stakeholders have requested to determine tariffs for capacities below
5 MW.

2. Transmission,Wheeling,Scheduling and System Operation Charges

National Solar Energy Federation of India Confederation of Indian

Industry,SWELECT Energy Systems

Commission’s proposal of withdrawing promotional measures by increasing open

access charges from 50% to 100% of that applicable of conventional sources is
a huge discouragement to the existing and new Solar Energy Generators.
Levying 100% charges does not differentiate non conventional from conventional
sources of energy. The increase in levy from 50% to 100% increases the open
access charges from 46 paise per unit to 92 paise per unit. Given the seasonal
and diurnal variation in solar power generation, the yield is lower compared to
other renewable energy sources. The charges may be retained at 50% of that
applicable for conventional power.

34
Kovai Solar Power (p) Ltd., Southern Power Solutions, Thiru Veeraprakash,
Dev Solar , Euphoria Green Technologies,JK Solar

Transmission and Wheeling charges may be levied on energy instead of

capacity.

Dr. Anoop Singh,Professor,IIT,Kanpur

Additional cost on account of removal of exemptions for wheeling and intrastate

transmission charges would only reduce the cost advantage for Captive and OA
consumers but would not eliminate it. Further cost reduction in cost of RE
projects and increasing tariff of such consumers in future would negate any
adverse implications of the proposed amendments. The additional revenue to the
utilities on account of removal of above exemptions would be much smaller as
compared to the total cost of power procurement of the state and the revenue
gap. increasing share of energy injection by Variable Renewable Energy (VRE)
sources is placing stress on system operation on account of variability and
uncertainly associated with the electricity generation from such sources. The
state's grid code and the applicable regulations for forecasting and deviation
settlement should be tightened to ensure that the generators improve the
forecasting accuracy and bear the financial impact on account of deviations due
to forecasting error. This would improve grid operation and reduce overall
financial impact on the sector due to the associated uncertainty.

Thiru A.D.Thirumurthy
Increase of charges by 50% will lead to unnecessary stress in operating the
plant and in turn repayments to banks. Very negligible circuit length is exclusively
utilised by the RE sector. Charges may be levied on energy generation basis
instead of on capacity.

35
Distributed Solar Power Association
Commission may retain the discount in each of the charges as the solar plants
built for private consumption does not have the scale to achieve low tariffs.

CBPUR Renewable Energy Projects Pvt. Ltd.

Commission may fix charges at 50% of that applicable for conventional power
for each of the charges especially for projects with capacities less than 5 MW in
order to achieve the targeted capacity.

TECA

Charges may be fixed on energy basis.

Tamil Nadu Solar Energy Developers Association

Withdrawal of promotional measures and increasing open access charges is

huge discouragement to the existing and new solar power generators.
Transmission and wheeling charges may be levied on energy instead of capacity.

The South India Spinners Association

Solar irradiance is not available for 24 hours. The PLF of 18% to 24% depends
on the location of plant. The proposed 50% increase in open access charges will
increase the existing open access charges by 100%.

SIMA
Increasing the OA charges by another 50% by treating solar power on par with
conventional power will give a great shock to the investors. Commission may
retain the present status.

36
Tamil Nadu Solar Power Generator’s Association(TANSPA)
The proposal to levy 100% charges will be a huge discouragement for future
projects and huge financial blow for already commissioned projects. The
proposed increase in charges will result in an increase of 0.46 paise per unit.
Open access charges alone would work out to 30% of solar tariff. All open
access charges may be fixed on per unit basis considering that the CUF of solar
power plant is very low. The charges may be maintained at the present level.

TANGEDCO
Has accepted the proposal of the Commission.

3. Cross Subsidy Surcharge

National Solar Energy Federation of India Confederation of Indian Industry,

SWELECT Energy Systems
Cross subsidy surcharge increases from Rs.1.39 to Rs.1.98. The overall incrase
in open access charges is Rs.1.05. The primary objective of harnessing solar
power and promoting solar power gets defeated.CSS may be maintained at the
same level.

Kovai Solar Power (p) Ltd., Southern Power Solutions,Thiru Veeraprakash,

Dev Solar , Euphoria Green Technologies, JK Solar, The South India
Spinners Association
Cross subsidy surcharge may be maintained at existing levels.

Thiru A.D.Thirumurthy
Cross Subsidy Surcharge may be maintained at 70% to promote solar plants.

37
Distributed Solar Power Association
Commission may continue the promotional measures and retain existing cross
subsidy surcharges.

CBPUR Renewable Energy Projects Pvt. Ltd.

Commission may levy 50% of that applicable for conventional power.

Tamil Nadu Solar Energy Developers Association

Withdrawal of promotional measures and increasing open access charges is

huge discouragement to the existing and new solar power generators. Existing
levels may be retained.

TECA

Commission may issue guidelines for complete elimination of Cross Subsidy

Surcharge.

SIMA

The current level of cross subsidy surcharge may be retained.

TANSPA

Levy of 100% Cross subsidy surcharge will be a huge financial blow for future
projects and already commissioned projects.

Auroville Consulting, Citizen consumer and civic Action Group

The cross subsidy levels for solar energy may be kept at the existing levels and
may be revisited when at least 80% of the Tamil Nadu Solar Energy Policy 2019
targets have been achieved.

TANGEDCO
Has concurred with the views of the Commission.

38
4. Reactive charges

TANGEDCO
Has concurred with the proposal.

5. Grid availability charges

TANGEDCO
Has accepted the tariff proposed for the generating and non generating period.
Has accepted the proposal on standby charges.

NLC India Limited

During summer Solar generation starts as early as 5.15 A.M and ends as late as
6.50 P.M. Therefore, considering the whole year non generating period should be
defined as beyond 5.00 A.M to 7.00 P.M. However, billing shall be on net energy
generated by the solar plant. Only if net import is higher, excess drawal should
be charged.

6. Energy Accounting

National Solar Energy Federation of India Confederation of Indian Industry,

SWELECT Energy Systems
Banking facility is not available for Solar power. Atleast, energy adjustments
slot/block to slot/block and adjustment from higher slot to lower slot should be
made available without which open access would become unviable. The existing
mode of energy adjustment may be retained. The cap on excess generation may
be removed. The proposed system of energy adjustment will discourage new
investors. Promotional measures made available to the already commissioned
plants may be retained.

39
Kovai Solar Power (P) Ltd., Southern Power Solutions, Thiru Veeraprakash,
Dev Solar, Euphoria Green Technologies,JK Solar

The proposal of energy adjustment will discourage investors and developers in

investing in Solar power.

SIMA

In the case of Solar there is no banking facility and therefore no cap need be
fixed on excess generation.

Dr.Anoop Singh,Professor,IIT,Kanpur
Following two options can help ameliorate the financial loss to generators while
also addressing concerns of the distribution utility and the system operator.
- Payment for excess energy injection to be linked to the prevailing rate under
the deviation settlement mechanism.
- Such excess energy to be either paid for REC equivalent price (floor price) or
equivalent RECs be allocated to the generators.

Tamil Nadu Solar Energy Developers Association

Without the prevailing mechanism of adjustment of energy, harnessing of solar

power would be unviable. Adjustment of energy on the basis of block/slot to
block/slot and higher to lower slot may be allowed. Cap on excess energy
generation may be removed.

Thiru A.D.Thirumurthy
Commission may allow higher to lower slot adjustment for at least 10 years of
plant operation to achieve viability. Commission may propose deferred
consumption charges for adjusting higher slot generation to lower slot
consumption which would be additional revenue to DISCOM. Renewable energy
is to be promoted to reduce carbon emission and contain the climate change.

40
Changes in the adjustment methodology, increasing the charges will deter further
growth in the RE sector especially solar projects. This activity is against Global
agenda and National agenda of reducing carbon emission. Until the energy
storage technology becomes viable existing adjustment pattern can be allowed.

The South India Spinners Association

Imposition of conditions is a huge discouragement to the Solar project
developers. While banking facility is not available, at least the adjustment of
energy on basis of block/slot to block/slot and higher slot to lower slot for excess
generated power may be allowed. Cap on excess generation may be removed.

Distributed Solar Power Association

Commission may retain the existing energy accounting procedure.

CBPUR Renewable Energy Projects Pvt. Ltd.

Commission may retain the existing energy accounting allowing inter slot
adjustments. The excess energy may be sold at 100% of the respective solar
tariff fixed by the Commission in the respective orders to the generators or at the
prevailing Average Power Purchase Cost (APPC) price.

Tamil Nadu Solar Producers Association, Tamil Nadu Solar Power

Generators Association

The proposal to only allow slot/block to slot/block adjustment and remove the
present arrangement where production during normal slot can be adjusted
against normal slot or off-peak slot, hugely discourages the Solar Industry. While
grid stability might be stated as the reason for such a proposal, it is pertinent to
note that Solar energy production is more firm and predictable than wind. But the
removal of adjustment of Normal slot production against off-peak slot

41
consumption has been proposed only for Solar. The present arrangement of
energy adjustment may be retained.

TECA
Commission may issue guidelines for energy banking of excess power and
adjustment of energy on basis of block/slot to block/slot and higher slot to lower
slot for excess generated power. Cap on excess generation may be removed.

Auroville Consulting, Citizen consumer and civic Action Group

For the excess energy flow, the following options may be offered to the
generator: (i) carry over to the next financial year and (ii) payment at APPC .
Payment at APPC may be justified on the ground that if renewable power is
available at the same average rate as conventional power , renewable energy
should be given a preference on account of its contribution to achieving the State
Policy and RPO targets.

TANGEDCO
Has accepted the views of the Commission. However, with reference to the
request for fixing of feed in tariff for small projects, has suggested to make
payment at 75% of FiT where there is no tariff. Further, TANGEDCO seeks to
adopt normative CUF to cap generation in respect of SPGs under wheeling
category to prevent misuse through addition of solar panels and also to specify
penalty for unauthorized connections.

7. Security Deposit
TANGEDCO
Generators who wheel under captive category shall make a security deposit of
an amount equivalent to energy to be wheeled under open access during the

42
previous financial year at the appropriate tariff as a safety measure in case of
failure to fulfil the captive status.

8. Power Factor Disincentive

TANGEDCO
Has concurred with the views of the Commission.

9. Metering
TANGEDCO
Has accepted the proposal of the Commission.

10. Connectivity and evacuation

TANGEDCO
Has accepted the proposal of the Commission.

SIMA
TANGEDCO enforces backing down of solar power plants. A suitable
compensation mechanism may be evolved to protect the interest of solar
generators.

11. Harmonics
SIMA
Harmonics are measured by the Distribution Licensee before connecting the
generator to the grid failing which 15% compensation is levied for payment
within a notice period of 15 days. Time limit to provide harmonics may be
enhanced to 90 days from the proposed 15 days.

43
12. Parallel Operation Charges

TANGEDCO
Has suggested that both REC generators and non REC generators may pay
100% of applicable parallel operation charges.

NLC India Limited

The clause should be specific that it is not applicable for SPGs under sale to
Board category.

SIMA
Parallel operation charges are only when solar panels are installed within same
premises and the power consumed within the premises. Has requested not to
levy parallel operation charges where solar energy is wheeled after transmission
to the grid. In other cases, has requested to levy the present rates of 40% of the
charges.

Thiru A.D.Thirumurthy
Parallel operation charges may be levied at 50% of that applicable for
conventional power plants since solar plants operate only during day time when
compared to other conventional plants which operate for 24 hours. The solar
plant which does not export does not have any impact on the grid but stabilises
the grid voltage and reduces the losses.

44
13. Applicability
National Solar Energy Federation of India Confederation of Indian Industry,
SWELECT Energy Systems

The promotional measures / benefits made available to Solar Project Developers

as per TNERC Order at the time of synchronization of the Solar PV Plant, which
are already commissioned, may be extended without any revision.

CBPUR Renewable Energy Projects Pvt. Ltd.

The applicability of the incentives/charges may be for a period of not less than
15 years from the date of commissioning/Commercial operation date(COD)..This
will provide a much needed boost in the capacity addition and in the process
strengthen the grid resulting in improved power quality, as well as aid in local job
creation

The South India Spinners Association

The promotional benefits made available at the time of commissioning of the
solar power plants may be extended without any revision.

TANSPA
Investment decisions of Solar plants already commissioned were taken keeping
in mind the provisions prevailing at the point of commissioning of the plants.
Changing any of the provisions will affect the financial prospects. If adjustments
in lower slots is not allowed almost 50% of the energy cannot be adjusted and
will get paid at 75% of solar tariff. The capital cost was substantially higher three
to four years back. Hence, the concessions applicable at the time of
commissioning of the plant be extended without any revision for the already
commissioned solar power plants.

45
U-Solar Clean Energy Solutions
A solar plant takes 6 to 9 months to set up and commission the plant. A lot of
financial resources are committed based on a certain policy. Removing of all
concessions alters the economics of any plant. Date of implementing such
changes may be deferred.

Other stakeholders
Harnessing of solar power and utilizing the same through open access would be
unviable without the prevailing energy adjustment methodology, increased
transmission charges, cross subsidy surcharge, parallel operation charges and
the proposed cap in generation. The generated energy may be allowed to be
utilized in lower time slots.

46
 Annexure III
State Advisory Committee Meeting held on 20.3.2020

Members present

Sl.No. Name

1. Thiru. M.Chandrasekar, Chairman, TNERC

2. Thiru. Dr.T.Prabhakara Rao, I.A.S., (R), Member, TNERC

3. Thiru. K.Venkatasamy, Member, TNERC

4. Thiru. Vikram Kapur, I.A.S., CMD, TANGEDCO Ltd., and

Chairman, TANTRANSCO, and Principal Secretary to
Government, Energy Department

5. Thiru. M.R.Krishnan, Deputy Director, Consumer Association of

India,Chennai
6. Thiru S..Sankaranarayanan,General Manager,Tamil Nadu
Energy Development Agency

7. Ms.V.Geetha, Additional Secretary to Government, Energy

Department, Government of Tamil Nadu

8. Thiru A.Jesu Thayanand, Under Secretary to Government, Co-

Operation, Food and Consumer Department

9. Thiru T.Vijayarangan,Secretary,Anna Labour Union,Chennai

47