The Chhattisgarh Electricity Regulatory Commission (CSERC) issued draft RPO-REC regulations on 26th February, 2021 along with an Explanatory Memorandum and invited public comments on the same. Firstly, we welcome the publication of these draft RPO regulations which remain the bedrock of RE growth in the country.
The important points in our submission are:

1. RPO should be levied on co-generation from fossil fuel plants
2. Total consumption for DISCOMs should be redefined as the total procurement of electricity from all sources instead of total sales alone.
3. CSERC to specify targets of ~25-26% by 2025-26 rather than just rely on GoI to give guidance on this issue.
4. CSERC should specify one composite RPO and merge solar/non-solar RPOs.
5. Considering all the economic, social and environmental risks of large hydro-power, it should not be considered as a renewable energy resource for the purpose of the RPO and, hence, should not be made part of the non-solar RPO.
6. CSERC should notify a much lower price for power (~ Rs 2.5/kWh) under the REC route.

Prayas (Energy Group)’s detailed comments and suggestions are detailed in the submission.