The Maharashtra Electricity Regulatory Commission put out the draft Renewable Purchase Obligation, Its Compliance and Implementation of Renewable Energy Certificate Framework Regulations, 2019 and the Explanatory Memorandum on 26th October, 2019 for public comments. The draft regulations propose to increase the RPO from 15% in 2019-20 to 25% by 2024-25 coupled with explicit incentives and disincentives to achieve this.

We welcome the publication of this draft regulation as it is key for the growth of the renewable energy sector in the state and is equally crucial for managing the cost of power procurement for DISCOMs given the low price discovery of wind and solar power and the increasing cost of conventional sources of power. Secondly, we also support the approach of strongly increasing the minimum procurement levels for renewable energy given its wide ranging social and economic benefits for the state as well as for the DISCOMs and consumers.

We propose that the Commission can consider an even higher RPO of 30% by 2025. Comparing the long term fixed and total price of solar and wind power at ~ Rs 2.75/kWh (which is likely to reduce further in the coming years) with only the variable price of existing and new thermal power plants (which is certain to increase in the coming years) , it is amply clear that substantially increasing the share of RE is a significant cost saving measure for the DISCOMs. We also feel that there is a need and importance of specifying a long term (2030) guiding target in regulations, as this will allow for stakeholders to be better prepared and further aid in long term planning for associated infrastructure such as land, transmission, road and water connectivity etc. Our detailed submission on these draft regulations is attached below.