Rajasthan Renewable Energy Corporation Limited (RRECL) put out the 'Draft of New Rajasthan Solar Energy Policy, 2019' on its website for public consultation in September, 2019. The policy lists a target of 50 GW by 2025-26 which includes 25 GW in the state by 2022. In response to this, our comments on this draft policy highlight, that this is an ambitious target and should be supplemented by comprehensive capacity expansion and production cost simulations which can model system dispatch in these years (2022 and 2026) and determine how this amount of solar generation can be reliably integrated into the Rajasthan system considering its load profile, load growth and existing and future system flexibility. We also highlight that significant changes in transmission planning would be expected with such high solar targets. A detailed note on ‘The need and importance of a new framework and long term perspective for transmission planning’ to incorporate the increasing renewable energy targets is also part of this submission as an Annexure.

The draft policy also recommends a new Rajasthan Renewable Energy Development Fund. It proposes a new levy of Rs 2.5-5 lakhs/MW per year for the entire life-cycle of the project, but exempts DISCOM PPA projects from it. Considering the 5-10% increase in costs for OA and CPP solar projects from this levy, there is a possibility of projects moving away to either other states or to other technologies like wind power which do not have this levy. Hence it is important to debate whether a levy on only one specific generation technology, namely solar is the best way forward. Other options including a levy on all generation technologies or shifting it to consumers rather than generators could also be considered.