TNERC issued a consultative paper to discuss the approach on procurement of solar power by the distribution licensee and the related issues of open access (OA), and invited public comments on the same. Prayas submitted comments and suggestions towards the effective implementation of the procurement mechanism, clarity of process, and towards addressing existing and future concerns to ensure a robust RE sector. The highlights are summarised as follows:

• A banking framework based on a per-unit banking charge that extended to new solar projects was suggested to ensure RE is encouraged, while reflecting the services provided by the DISCOM.
• It was proposed that concessions provided to RE, such as those provided for cross subsidy surcharge and OA charges, should come with clear sunset clauses. These waivers should be phased out in a planned manner, so that solar generators have certainty in the medium term, while ensuring the growth of RE is not driven by concessions.
• A revision in the framework of parallel operation charges and its integration with stand by charges was suggested. It was also suggested that POC be parameterized based on demand charges, to ensure compensation to the DISCOM in the future as well.
• To ensure a more comprehensive solution to issues pertaining to OA, a revision of the Grid Connectivity and Intra-State Open Access Regulations 2014 was suggested, subject to public consultations.
• Despite the impact of sale migration on the states power sector, there is little data reporting on this front. To ensure transparencyand a better understanding of trends, the reporting of crucial parameters was suggested. Further, it was suggested that the collected data should be available on the Commission's website.