A petition has been filed before the Gujarat Electricity Regulatory Commission (GERC) by Surya Roshni Ltd., seeking clarification on the applicable regulations governing their 750 KWP rooftop solar photovoltaic (PV) project. The project was commissioned on May 11, 2022, in Kutch, Gujarat. The date of commissioning plays a central role in the dispute, as it precedes the enforcement of the GERC (Net Metering Rooftop Solar PV Grid Interactive Systems) (Third Amendment) Regulations, 2022, which came into effect on May 31, 2022.
Surya Roshni Ltd. explained that prior to the commissioning of the plant, a provisional Grid Interconnection Agreement had been signed on May 7, 2022, with Paschim Gujarat Vij Company Limited (PGVCL). This agreement was executed in anticipation of changes to the existing net metering framework and in line with the Gujarat Solar Power Policy, 2021.
The petitioner argued that on the date of commissioning, the prevailing regulations were the GERC Net Metering Regulations, 2016, along with its Second Amendment issued in 2020. They have requested PGVCL and Gujarat Urja Vikas Nigam Limited (GUVNL) to enter into a fresh agreement governed by these earlier regulations. However, PGVCL’s response focused on banking charges, which Surya Roshni Ltd. claimed were not relevant to the central issue of the applicable regulations.
According to Surya Roshni Ltd., the Third Amendment regulations themselves specify that projects commissioned before their effective date must be governed by the regulations applicable at the time of commissioning. They informed the Commission that they have been charged Rs. 42,98,259 as banking charges for the 28,65,506 units of energy generated between May 11, 2022, and December 31, 2024. The company has requested the Commission to determine the appropriate regulations for their case, confirm whether the banking charges are legally applicable, direct PGVCL to sign a fresh agreement under the previous framework, and order a refund of the charges already paid.
Representing PGVCL argued that a previous Order issued by the Commission on June 11, 2021, in Petition No. 1396 of 2021, already permitted the levying of banking charges for wheeling under the Gujarat Solar Policy. She stated that this Order pre-dates the interconnection agreement and is relevant for the current matter, thus justifying the charges being collected by PGVCL.
In response, Surya Roshni Ltd. countered that the June 2021 Order pertains to wheeling and not to projects governed by net metering. They asserted that if PGVCL’s logic of applying the 2020 policy holds, then the latest Renewable Energy Policy of 2023 by the Government of Gujarat should also be applicable from its effective date. They maintained that only the Second Amendment to the Net Metering Regulations, 2020, applies to their project and not the 2021 Order cited by PGVCL.
During the hearing, the Commission noted that GUVNL, the second respondent, was not present. It granted both parties—Surya Roshni Ltd. and PGVCL—four weeks to submit their final written arguments. The matter has now been reserved for a final order. The Commission’s order was signed on July 21, 2025.
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