RERC Rules Against Load Factor Rebate Claim For Behind-The-Meter Solar Plants In Rajasthan

The Rajasthan Electricity Regulatory Commission (RERC) has dismissed a petition filed by M/s Shree Cement Ltd. against the Jaipur Vidhyut Vitran Nigam Ltd. (JVVNL) concerning the denial of a load factor rebate for its captive solar power plant. The petition, which was under consideration throughout late 2025, focused on whether solar energy generated “behind the meter” should be counted when calculating a consumer’s total load factor for discounted electricity rates.

Shree Cement operates a grinding unit in Jobner with a contract demand of 7.40 MVA. The company has an internal captive solar plant of 7.08 MW, which was commissioned in March 2023. In December 2024, Shree Cement recorded a load factor of 43.42% from the Discom supply alone. The company argued that when its internal solar consumption was added, the cumulative load factor rose to 57.49%. According to the RERC Tariff Order issued on July 26, 2024, consumers who achieve a Discom load factor of at least 40% and a combined load factor of 50% are eligible for a lower energy charge. Shree Cement contended that JVVNL ignored this provision and billed them at Rs 7.008 per unit instead of the rebated rate of Rs 6.048 per unit.

JVVNL responded by stating that the petition was essentially a billing dispute, which should have been taken to a Settlement Committee under Section 142 of the Electricity Act, rather than to the Commission. On the merits of the case, the Discom argued that the rebate only applied to solar plants connected to the grid via net metering or open access. JVVNL maintained that Shree Cement’s plant was “behind the meter” and internal, and therefore its generation could not be considered at the grid interface for claiming incentives.

Shree Cement attempted to demonstrate grid connectivity by presenting an approval from the Rajasthan Rajya Vidyut Prasaran Nigam Ltd. (RVPN) for “parallel operation.” The company argued that this synchronization with the grid meant the Discom’s claim of no connectivity was incorrect.

The Commission, however, sided with JVVNL. RERC clarified that “parallel operation” is a technical consent for system protection and does not meet the regulatory requirements for energy accounting or eligibility for tariff benefits. The Commission noted that the 2024 Tariff Order intended the rebate for grid-connected rooftop solar (RTS) plants and non-co-located captive plants, and not for behind-the-meter installations.

The ruling emphasized that behind-the-meter plants already enjoy a “privileged position” because they allow self-consumption without paying open access charges or other financial obligations that remote plants face. Therefore, such installations cannot be treated the same as grid-connected captive plants for rebate purposes unless the regulations explicitly allow it.

Finding no violation of the Tariff Order, the Commission disposed of Shree Cement’s petition on December 31, 2025. The decision clarifies that rebates under the RERC Tariff Order are meant only for plants with clear grid connectivity and do not extend to internal behind-the-meter solar generation. This ruling reinforces the distinction between self-consumption from captive solar plants and incentives meant for grid-connected installations, providing clarity to industrial consumers and Discoms regarding eligibility for load factor rebates.

The case also highlights the importance of understanding regulatory provisions when claiming benefits, especially in situations where technical approvals, such as parallel operation, do not automatically confer tariff advantages. The Commission’s decision ensures that behind-the-meter consumers continue to enjoy self-consumption benefits, while rebates are preserved for grid-linked solar projects, maintaining a fair and consistent framework for electricity tariff incentives in Rajasthan.

The petition’s dismissal marks a key precedent in how captive solar plants are treated under RERC regulations, particularly in the context of load factor-based energy charges. It underscores the need for clear definitions of connectivity and eligibility for financial incentives under the Tariff Order.