Maharashtra Electricity Regulatory Commission issued draft MERC (Renewable Purchase Obligation, its Compliance and Implementation of Renewable Energy Certificate Framework) (First Amendment) Regulations, 2023 on 5th August, 2023 and asked for public comments by 25th August, 2023, but later extended the last date to 4th September, 2023.

Considering the national target of 500 GW non-fossil fuel capacity by 2030 and that renewables (mainly wind and solar) will account for the bulk of that addition due to their low cost of generation, the proposed amendment to the MERC RPO regulations is very timely and welcome. The draft amendment proposes a RPO trajectory for 2024-30 in line with the MoP guideline in this regard. Maharashtra has and can continue to play a big role in contributing to this national goal through various initiatives, one of which is the regulation on RE purchase by the obligated entities in the state.
Our suggestions and comments on the proposed draft amendment are detailed in the submission but the important suggestions are noted below.

• While we appreciate the long-term RPO trajectory target of 43.3% by 2030 and the very timely and necessary 4% Energy Storage Obligation by 2030, we suggest having one generic/composite RPO target rather than introducing new and separate resource wise RPO categories.
• Carry forward provisions undermine effective compliance. This has resulted in a cumulative shortfall of 25,569 MU across the 4 DISCOMs in Maharashtra as of March, 2022 which is 19% higher than the entire RE procurement in 21-22.
• RPO non compliance penalty should be high enough and be effectively imposed to deter non-compliance.
• Making the compliance verification process timebound and adding forward looking aspects such as directing all Obligated Entities to submit a quarterly or six monthly RE and storage procurement calendar for the next 2-3 years would be important to hold DISCOMs more accountable to their future RE and storage procurement planning.