The Rajasthan Electricity Regulatory Commission (RERC) has dismissed a petition filed by Shree Cement Limited against Jaipur Vidyut Vitran Nigam Limited (JVVNL), rejecting the company’s request to reduce its contracted power demand to qualify for higher captive renewable energy capacity under the Rajasthan Electricity Regulatory Commission (Green Energy Open Access) Regulations, 2025. The Commission ruled that existing behind-the-meter captive renewable energy installations cannot automatically benefit from the revised 200% capacity limit without formally migrating to the new regulatory framework and meeting its requirements.
The petition was filed under Section 142 of the Electricity Act, 2003, alleging that JVVNL had violated the Green Energy Open Access (GEOA) Regulations, 2025, by rejecting the company’s application to reduce its contracted demand. Shree Cement operates a grinding unit at Jobner with a contracted power demand of 7.40 MVA from JVVNL. The facility also has an existing 7.08 MW captive solar power plant installed behind the meter since March 2023.
Following the notification of the GEOA Regulations in 2025, Shree Cement approached JVVNL in January 2026, seeking to reduce its contracted demand by 50% to 3,540 KVA. The company proposed installing a Battery Energy Storage System (BESS), arguing that the reduced contract demand would allow its existing solar capacity to fall within the 200% renewable captive capacity limit permitted under the new regulations.
The regulations allow consumers to establish renewable captive power plants with capacities of up to 200% of their contracted demand, subject to installing a BESS for capacity exceeding 100%. However, JVVNL rejected the application, maintaining that the proposed reduction was inconsistent with the applicable regulatory provisions.
Before the Commission, Shree Cement argued that the 200% capacity provision should also apply to existing behind-the-meter captive renewable energy consumers. It contended that the regulations permitted existing consumers to reduce their contracted demand and use the revised limit. The company also referred to the saving clause under Regulation 31 and the legal principle of mutatis mutandis to support the application of the new provisions to its existing installation.
JVVNL opposed the petition, stating that captive renewable energy plants installed under the earlier regulatory framework remain subject to the 100% contract demand limit. It argued that the 200% provision was intended for new renewable capacity additions and could not be used to modify existing arrangements merely by reducing contracted demand. The utility further submitted that such a reduction would primarily lower fixed electricity charges without encouraging additional renewable energy generation.
In its order dated November 4, 2026, a three-member RERC bench comprising Chairman Dr. Rajesh Sharma and members Hemant Kumar Jain and Vijay Pal Singh rejected Shree Cement’s arguments. The Commission clarified that existing consumers seeking benefits under the 200% capacity provision must formally migrate to the GEOA Regulations, 2025, through the prescribed one-time conversion mechanism and fulfil all applicable conditions.
RERC also observed that the higher capacity limit was introduced to encourage additional renewable energy generation, not to increase the permissible capacity ratio through reductions in existing contracted demand.
The Commission further noted that Shree Cement had previously submitted the same proposal during public consultations, which was rejected in an order dated December 12, 2025. Considering the non-disclosure of this material information, RERC dismissed the petition as devoid of merit.
