The Gujarat Electricity Regulatory Commission (GERC) has proposed amendments to its Green Energy Open Access (GEOA) regulations, focusing on banking charges for renewable energy generators. Initially, the Commission set banking charges at ₹1.50 per unit until March 31, 2025, as per its 2024 regulations. However, due to ongoing studies on a suitable banking framework, GERC has now extended this charge for an additional six months until September 30, 2025, or until new charges are notified.
A public consultation process was conducted, inviting comments and objections from stakeholders. Various stakeholders, including renewable energy developers and power distribution companies, participated in the consultation and a public hearing held on February 25, 2025. Several stakeholders argued that banking charges should be based on a percentage of banked energy rather than a fixed rate per unit. They pointed out that many states follow an 8% banking charge in kind, as recommended by the Forum of Regulators (FOR). Some also highlighted that the current charge lacks sufficient technical study or background calculations, calling for a fairer mechanism based on actual costs.
Other stakeholders argued that the existing ₹1.50 per unit charge unfairly burdens renewable energy consumers. They claimed that additional costs, such as backing down conventional power plants, are already recovered through an extra surcharge on open-access consumers. Additionally, the capacity utilization factor (CUF) of hybrid renewable energy projects is higher than standalone solar, making uniform banking charges unjustified.
Some objectors raised questions regarding the regulatory process, questioning whether banking charges could be implemented without a detailed cost study or a formal tariff determination. They suggested that until a structured study is completed, an 8% charge in kind should be applied as an interim measure. Another suggestion was to base banking charges on the marginal cost of power purchase to avoid placing undue financial pressure on smaller consumers who cannot install solar generation.
One proposal recommended calculating banking charges based on the difference between market-clearing prices and the average solar power rate from recent auctions. This method, stakeholders argued, would provide a fairer charge structure reflective of real market conditions. However, GERC clarified that these suggestions fall under the broader framework study currently in progress. Until that study is completed and finalized through public consultation, the existing charge of ₹1.50 per unit will remain in place.
The Commission acknowledged stakeholders’ concerns and reaffirmed its commitment to a comprehensive analysis of banking charges. It assured that a draft framework paper would be published for public feedback before finalizing any changes. Until then, the Commission deemed it necessary to maintain the current banking charges for six more months to ensure stability and continuity in the open access framework.
The Commission directed its office to publish the final version of the Gujarat Electricity Regulatory Commission (Terms and Conditions for Green Energy Open Access) (Second Amendment) Regulations, 2025, in the official gazette. The decision was signed by Chairman Anil Mukim and members Mehul M. Gandhi and S. R. Pandey on March 28, 2025, at Gandhinagar.
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