In light of the recent developments in the sector in conjunction with the changes introduced through the Electricity (Rights of Consumers) Amendment Rules, 2024, Tamil Nadu Electricity Regulatory Commission (TNERC) has proposed new regulations for Grid Interactive Solar PV Systems (GISS), which include various forward-looking frameworks like Virtual Net-Metering (VNM) arrangement for distribution licensees (DISCOM) and government/local bodies, Group Net-Metering (GNM) arrangement for domestic consumers, etc.

Considering this, Prayas (Energy Group)’s comments and suggestions highlight areas where more clarity is needed to enable smooth rollout of the regulations. In addition, we suggest certain changes towards ensuring a balanced framework for all stakeholders while facilitating the growth of the grid-interactive Renewable Energy (RE) sector. Our comments are broadly focussed on following aspects:
1. Applicability of Regulations (Inclusion all RE sources under ambit of the regulation; Clarification of capacity limits under different metering arrangements)
2. Energy accounting framework (Need for banking charges; Increase temporal granularity in energy accounting for large consumers)
3. VNM (Clarification of the eligibility criteria to avail and install project under VNM; Relaxation of ""no pending arrear"" condition for public bodies; Clarification for the rate of compensation of unutilised/unadjusted banked energy)
4. Behind-The-Meter (BTM) systems (Timelines for registration of BTM systems , Levy of network charges and standby charges on BTM systems)

Detailed comments can be accessed in the document attached in this page.