Introduction

‍The regulatory environment for renewable energy in India is undergoing a paradigm shift with the introduction of the Green Energy Open Access Rules. These rules aim to democratize access to green power, lowering the eligibility limit for consumers. This white paper dissects the policy framework, analyzing the implications for smaller C&I consumers and the challenges regarding cross-subsidy surcharges and grid availability.

Democratizing Access: Lowering the 1 MW Threshold

‍Previously, only large industries with a connected load of over 1 MW could purchase power via Open Access.

• New Thresholds: Recent policies propose lowering this limit to 100 kW. This opens the market to small and medium enterprises (SMEs), allowing them to procure green power and reduce costs.
• Timely Approvals: The rules mandate a unified portal for time-bound approvals (typically 15 days). This addresses a major bottleneck where DISCOMs previously delayed permissions to prevent high-paying consumers from leaving the grid.
• Metering and Settlement: The shift requires upgrading metering infrastructure to smart meters capable of 15-minute time-block recording for accurate deviation settlement.

The Challenge of Surcharges and Landed Cost

‍While the policy encourages open access, the financial viability depends on "landed cost."

• Cross-Subsidy Surcharge (CSS): This is a charge levied on open access consumers to subsidize agricultural and residential users. The volatility of CSS is a major risk factor for investors.
• Additional Surcharge (AS): Levied to recover the fixed cost of stranded power assets of the DISCOM. The Green Energy rules attempt to cap or limit these surcharges for green power, but state-level implementation varies.
• Green Attributes: The policy clarifies that the "Green Attributes" (Carbon Credits/RECs) remain with the consumer, which is vital for multinational companies reporting under global sustainability frameworks like CDP or RE100.

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