Tamil Nadu Electricity Regulatory Commission (TNERC) has proposed new regulations for the implementation of Green Energy Open Access (GEOA) rules in the state, and is a welcome initiative. This includes positive proposals such as minimum eligibility limit of sanctioned demand of 63 kVA, energy accounting on a 15-minute time-block basis, and disallowing banking during peak hour blocks.

Prayas (Energy Group)’s comments and suggestions in this matter highlight areas where more clarity is needed to ensure smooth implementation and also suggest additional changes that can be made to safeguard the interests of the DISCOMs, whilst promoting a competitive environment for alternate sources of supply. 

Some of the important issues highlighted include: 

1. Connectivity for both Open Access and Captive consumers should only remain at HT level.
2. A clear sunset clause on concessions on intra-state wheeling and transmission charges.
3. A balanced banking framework where banking charge to be levied is around 10-12% an in-kind charge on energy wheeled (and not energy banked); and any unutilised surplus banked energy to lapse at the end of month.
4. Aspects of the MoP rules not incorporated in the regulations - such as the provision of multiple connections for consumers aggregating to 100 kW or more, ceiling limit on Cross-Subsidy Surcharge, etc should be clarified by the Commission.

The detailed comments can be found in the attached file.