TNERC invited public comments on two of its consultative papers, one on the procurement of solar power and the other for the procurement of wind. PEG's comments and suggestions on both papers are attached. Our observations on the proposals in the submission focussed on:

• Ensuring procurement based on competitive bidding for wind and solar and encouraging solar+storage procurement
• Shift from 'in-kind' energy banking to a per unit charge determined based on the difference between power purchase cost at the time of banking of energy and its drawal . It is suggested that banking services should be provided not only to wind-based captive generators but should be extended to all solar generators as well as open access users.
• Concessions for future projects should be discontinued but to be retained for existing projects to ensure regulatory certainty for investors.
• Need for revision in parallel operation charges and the framework for standby services provided to ensure adequate compensation for grid services provided.
• Need for registration of all 'behind the meter' solar PV projects
• Need for an online portal for tracking application for open access, captive to streamline and increase accountability for processes.
• Introduction of seasonal variation in time of day tariffs to account for change in load due to renewable energy and need to take measures to extend ToD regime to a wider set of consumers.
• Need for re-assessment of wheeling loss and change in methodology for estimation of cross-subsidy surcharge.