The Rajasthan Electricity Regulatory Commission (RERC) issued a discussion paper on ‘Framework for Large Scale Integration of Renewable Energy using Energy Storage Systems and its impact on Tariffs’ in March 2021, and invited public comments on the same to facilitate the requisite regulatory intervention.

Firstly, we welcome this pro-active and timely initiative from RERC given that this topic is extremely critical for the future growth of the RE sector. Further, we fully acknowledge the need for further flexibility in the system as a means of reliably integrating cost-effective renewables and the important role that energy storage can play in this regard. Increasing Battery Storage Systems is a key way of increasing flexibility and in line with the ‘National Mission on Transformative Mobility and Battery Storage’ approved by the Cabinet in March, 2019. Additionally, the price of batteries has fallen sharply, by 87% in real terms in the last decade from $1,100/kWh in 2010 to $137/kWh in 2020. By 2023, prices are predicted to be $100/kWh and $ 61/kWh by 2030. To take advantage of these global developments, it is important to kick start the deployment of large scale batteries and other economic storage solutions and gain valuable experience and reap its multiple reliability and economic benefits.
As noted in the paper, energy storage systems can be located with generation assets or be deployed as Transmission / Distribution elements or even be deployed at the consumer location behind the meter. In all the cases, storage systems can provide a variety of services like energy shifting / peak load management, a host of ancillary services like frequency and reactive power control, black start etc., increase system flexibility to absorb more variable RE and reduce curtailment, improve reliability & resiliency and even defer capital expenditures in certain cases. To further add to the regulatory complexity, storage systems can be set up in a manner that they can provide such multiple services through a single project/asset. Our suggestions to accelerate the deployment of cost-effective storage as detailed in the submission.