The Rajasthan Electricity Regulatory Commission (RERC) has dismissed a petition filed by Hindustan Zinc Limited (HZL) against Ajmer Vidyut Vitran Nigam Limited (AVVNL) concerning the eligibility of behind-the-meter (BTM) captive solar power plants for concessional electricity tariff benefits.
HZL operates captive solar plants at its Agucha Gulabpura and Debari facilities in Rajasthan. The company has a 22 MW solar plant at Agucha, Bhilwara, commissioned in 2019, and a 12 MW solar plant at Debari, commissioned in 2017. Both plants are ground-mounted and captive, with the electricity generated being supplied directly to HZL’s internal 11 kV network.
The dispute arose from the interpretation of Paragraph 2.46.3 of the RERC Tariff Order dated July 26, 2024. The provision allows power-intensive industrial consumers with a billing demand of 1 MVA or more to receive concessional tariffs when their combined load factor, considering solar generation and Discom supply, is at least 50%, subject to a minimum 40% load factor from Discom supply alone.
AVVNL had initially provided HZL concessional tariff benefits amounting to ₹5.78 crore for its Agucha facility and ₹3.12 crore for Debari. However, following an RERC order dated December 31, 2025, in Petition No. 2333/2025, the Discom determined that BTM solar generation was not eligible for the concessional tariff mechanism. It subsequently recovered the earlier benefits through HZL’s electricity bills.
HZL challenged the recovery before the RERC, arguing that the 2024 Tariff Order did not exclude BTM captive solar plants from the concession. The company stated that its plants satisfied the requirements for captive generation under the Electricity Rules, 2005. It also submitted that joint meter readings were regularly carried out in the presence of Discom officials.
The company sought cancellation of the recovery through energy bills and a refund of ₹8.90 crore along with interest at 14% per annum. HZL also raised issues concerning billing demand and sought its restriction to 75% of the contract demand.
AVVNL argued that BTM solar plants are consumed entirely within the consumer premises and do not undergo energy accounting at the grid interface. According to the Discom, joint meter readings were conducted for the purpose of assessing State Electricity Duty and did not establish eligibility for tariff concessions.
In its order dated September 28, 2026, the RERC bench comprising Chairman Dr. Rajesh Sharma and Members Hemant Kumar Jain and Vijay Pal Singh upheld AVVNL’s position.
The Commission observed that BTM solar generation is internally consumed and is not accounted for at the grid interface. It reiterated its December 2025 position that tariff incentives cannot be extended to BTM systems by implication when such systems are not expressly covered by the applicable tariff order.
The Commission further clarified that recognition of a facility as a captive power plant under the Electricity Rules, 2005 does not by itself establish eligibility for load-factor-based tariff concessions.
On HZL’s claims relating to billing demand, excess charges and refund with carrying costs, the RERC directed the company to approach the Consumer Grievance Redressal Forum under the RERC Regulations, 2021. The petition was disposed of without any order as to costs.
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