MERC Provides Key Clarifications On Rooftop Renewable Energy And Green Energy Open Access Regulations, Directs MSEDCL To Act

Introduction

Aiming to increase the acceptance of renewable energy across the state, the Maharashtra Electricity Regulatory Commission (MERC) has issued critical clarifications to resolve uncertainty in its rooftop solar and green energy open access systems. The regulator responded to stakeholder concerns about the implementation of the MERC (Grid Interactive Rooftop Renewable Energy Generating Systems) (First Amendment) Regulations, 2023 and the MERC (Distribution Open Access) (Second Amendment) Regulations, 2023 in order dated 19 May 2025 (Case No. 231 of 2023).1 Together with instructions to the Maharashtra State Electricity Distribution Company Ltd. (MSEDCL) to operationalise the rules, these clarifications represent a crucial first step towards simplifying renewable energy integration in Maharashtra’s power sector.

Explanation (Key Points)

Banking Charges for Customers Using High Voltage:

Consumers connected at high-tension (HT) or extra-high-voltage (EHV) levels availing net metering must pay banking charges equivalent to wheeling losses—7.5% for HT and 12% for low-tension (LT) systems, MERC clarified. This guarantees distribution licensees recover costs for banking services until grid support charges are levied, in line with previous orders (Case No. 322 of 2019).

Group net metering definition of “Same Consumer”:

The commission denied claims that family members or separate businesses—even with shared PAN—qualify and limited group net metering to legally identical entities. Government departments—e.g., PWD, municipal bodies—were exempt from bureaucratic obstacles, however, allowing connections under different official designations to engage without name-change formalities.

Merc maintained strict eligibility for refunding surplus energy credits:

Consumers had to show three consecutive years of rising credits, emphasising its use in offsetting captive consumption, this prevents treating net metering as a revenue source.

Group Net Metering Energy Allocation:

To balance consumption at satellite connections, the regulator banned pooling surplus energy from several primary solar systems. Every main installation has to independently serve its allocated group to avoid complicated billing situations.

Entities aggregating 100 kW across several connections must be the same legal person or government department. Family-owned links or sister concerns with separate registrations remain unacceptable, guaranteeing GEOA benefits match statutory consumer definitions under the Electricity Act, 2003.

Unused banked energy lapses monthly, clearing uncertainty about whether cycles were annual. This corresponds with previous changes (2019) and stabilises grid management by avoiding long-term energy carry-forwards.

Low-Tension Consumer Requirements:

GEOA for LT consumers calls for time-of–day (ToD) metering. Should a participant leave a multi-connection GEOA configuration and cause the group to drop below the 100 kW limit, the facility shuts down right away without allowing any grace period.

Consumers have to predefine energy allocation percentages for GEOA at the beginning, with no mid-term adjustments permitted. This guarantees consistency for distribution licensees but restricts consumer flexibility dealing with operational changes.

Conclusion

MERC’s clarifications support Maharashtra’s dedication to a shift towards renewable energy. The order lowers regulatory risks for consumers and developers by separating banking charges, eligibility criteria, and billing procedures. Nonetheless, MSEDCL’s legal challenge against the rooftop rules and lack of implementation circulars despite instructions highlight its reluctance and create continuous challenges. The commission’s position emphasises the need of utilities matching state-level energy transition targets even while discussions on jurisdiction—e.g., PIL admissibility—continue. Effective implementation by MSEDCL and other licensees will decide whether these systems release Maharashtra’s rooftop solar and open access potential or stay mired in procedural delays going forward.