MSPDCL has expressed concerns about net metering regulations causing financial losses and proposed a transition to gross metering, alongside recommendations to limit solar capacity and enforce wheeling charges. However, the document argues that distributed rooftop solar systems can benefit the grid by flattening load curves and supporting energy stability while helping MSCDCL meet its solar purchase obligations. Ultimately, it advocates for both net and gross metering options for consumers and highlights the necessity of promoting solar energy to achieve national climate goals.

1. Response to demands/suggestions of MSEDCL about Distributed Grid-tied Solar Systems in
MTR petition filed before the commission:
MSEDCL has mentioned that Net metering regulation are causing financial loss to MSEDCL. MSEDCL
has suggested shifting to gross metering. Further, MSEDCL has suggested that,
1. ‘the cumulative capacity to be allowed at a particular distribution transformer shall not exceed 15% of the
peak capacity of the distribution transformer instead of present 40% and maximum capacity limit of 50%
of consumer’s sanctioned load/contract demand for individual roof top installation need to be added in the
Principal Regulations.’
2. ‘MSEDCL further suggests that the electricity generated from a solar rooftop system shall be capped
cumulativelyat90%oftheelectricityconsumptionbytheeligibleconsumerattheendoftherelevantbilling
period.’
3. ‘MSEDCL humbly requests Hon’ble Commission to allow MSEDCL to levy wheeling charges on rooftop
energy consumption.’
I would like to take attention of MSEDCL and Commission to relevant points.
 State wide Peak load in MSEDCL occurs in daytime. Solar generation follows a bell shaped
curve with time and peak generation matches the peak demand. So, with increase in
number of rooftop solar systems, MSEDCL can supply to more number of consumers
without having to invest crores of rupees on infrastructure (i.e. grid upgrades). This is a
financial benefit to MSEDCL.
 Rooftop solar systems shall contribute in flattening the load curve. So, they positively
contribute in stabilizing the grid. This will also help in reduction in peak prices of
electricity, for consumers of MSEDCL.
 A target of 40,000 MW of grid-connected solar PV was set by Central Cabinet on 17th June,
2015. In break-up, a target of 4,700MW was allotted for Maharashtra. MSEDCL is Licensee
for Maharashtra (except some parts of Mumbai). 147 MW of PV systems are commissioned
in the state under net metering arrangement (as per the latest data provided by MSEDCL
officials). PV systems have a low CUF of about 19%. So, the resultant contribution of net-
metered PV systems in the total energy mix is very small.
 MSEDCL has never complied with solar purchase obligation (SPO) under RPO target set
by commission in last Eight Years. If consumer is not an obligated entity and if he allows,
units generated by his Rooftop systems can be calculated towards fulfilling MSEDCL’s
RPO. MSEDCL has a liability of ₹260 Crores towards fulfilling RPO. So, without any
investment, rooftop solar systems will be a benefit in fulfilling MSEDCL’s SPO obligation.

2. While planning for achieving SPO, MSEDCL considers 4,700 MW of rooftop Solar systems
to be operational by 2021-22. (This is according to a submission by MSEDCL).
 Rooftop solar systems generate power at point of consumption. Excess, if any, is fed to
grid. This power fed to grid is consumed by adjacent consumers of DisCom. In rarest of
rare case, it is fed back from a transformer. In such case also, it is consumed in adjacent
transformer. So, technical (transmission) losses of power are very low.
 India is growing at faster rates. Energy consumption is set to rise correspondingly. India is
aiming for 100% electric vehicles by 2030, according to National Electric Mobility Plan. So,
use of electricity shall increase at a higher rates. So, DisComs sale of electricity is set to rise.
In view of above points, distributed generation systems shall be beneficial.
 Solar power makes energy security position of the nation better. As pointed out by
MSEDCL, Solar systems are a cheaper source of energy.
 Allowing only 15% of capacity of DTC would deprive remaining 85% consumers connected
on the same transformer from going solar.
 Government of India is promoting solar power on global platform. Maharashtra is
renowned as progressive state of the country. This turnaround, which is against solar
promotion policies of GoI and GoM, will take nation far away from achieving its goals of
solar grid-tied systems.
Global climate change is one of the biggest threat facing human existence. To reduce carbon emission
as committed in INDC of India in Paris agreement, renewables should have higher contribution in
Energy mix. Huge amounts of investments are required to achieve this, as most of renewable
technologies are capital intensive. Small systems installed by individuals and MSMEs collectively
amounts to big investments. According to MSEDCL, ‘Solar net-metering is a cost to MSEDCL and Non
net-metering consumers of MSEDCL’. But, demoting solar is a costlier mistake. Environmental loss
cannot be recovered at any cost. So, considering all these issues MSEDCL should take a positive stand
about solar rooftops. Both net and gross metering should be allowed in the state. Decision whether to
avail net or gross metering arrangement should be left to consumer. I request commission not to allow
– (a) reduction in PV system capacities based on DTC and Sanctioned Load or contract demand; and
(b) 90% cap on generation in billing period.
I want to speak at public hearing at _________________________, on ____th of August, 2018. I request
commission to consider the same.