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Rajasthan is strengthening its regulatory framework for clean energy through improved policies relating to captive and third-party sale renewable energy (RE) projects. To encourage the adoption of green power solutions and streamline the accompanying process, the Rajasthan Renewable Energy Corporation (RREC), as the state’s nodal agency for the development of RE, has issued a standard operating procedure (SOP). Acting as a guide, this SOP covers aspects such as project registration, power evacuation approvals, battery energy storage system (BESS) obligations, annual captive compliance verification and commissioning of projects.

To register a project, the developer or power producer must submit an online application to the RREC. The application must be accompanied by the requisite fees and documents, including a certificate demonstrating a minimum net worth of INR10 million (USD 111,000) per megawatt (MW). Once the application is accepted, the RREC will register the project under the Rajasthan Integrated Clean Energy Policy, 2024 (RICEP), and issue a letter of registration to the applicant.

Rajasthan SOP streamlines evacuation approvals

The SOP requires developers, once registered, to submit detailed power evacuation plans, including single line diagrams, covering the generating plant and consumers’ drawl points. The RREC then sends these power evacuation plans for technical feasibility assessment. For projects installed within the consumer’s premises, the plans are evaluated by the concerned distribution company (DISCOM), whereas if the project is located outside the premises, the plans will be sent to Rajasthan Rajya Vidyut Prasaran Nigam (RVPN) or the relevant DISCOM, with the drawl-end plan being forwarded to the concerned DISCOM for its examination. These assessments will consider grid capacity, bay availability, voltage levels and the adequacy of evacuation infrastructure. The concerned DISCOM, pursuant to site visits, will issue its technical feasibility assessment, covering the commissioning status of the plant, the consumer’s drawl patterns, physical progress, captive status, status of approval from the chief electrical inspector to the government and supporting photographs.

Once the developer receives the power evacuation approval from the RVPN or the concerned DISCOM, and submits the detailed project report, relevant land documentation, a shareholding agreement of captive consumer or a certificate issued from a chartered accountant (CA), and power purchase agreement or undertaking for third-party sale, the project shall be deemed in-principle cleared. Additionally, developers are required to furnish a security deposit of INR100,000 per MW, which is refundable on the timely commissioning of the project. The RREC then issues the final approval and the project must then be commissioned within the validity period of the evacuation approval.

BESS integration requirements under RICEP

The integration of BESS with RE projects stands out under the SOP. Under the RICEP and the Rajasthan Electricity Regulatory Commission (Terms and Conditions for Green Energy Open Access) Regulations, 2025, RE projects with an installed capacity of more than 5MW and connected to the state transmission utility or DISCOM network must install a BESS with a minimum capacity of 5% of the RE capacity of at least two hours of storage backup. Captive RE projects having capacity above 100% and up to 200% of the contract demand have to install a BESS capable of storing at least 20% of the energy generated by the incremental capacity of the plant.

On completion of project installations, the developers must submit to the RREC the CEIG’s approvals and evidence of the captive status of the consumers as required under the Electricity Rules, 2005. This includes shareholding agreements, CA certificates, proposed consumption patterns and proof of investment by captive consumers.

Consumers must then execute transmission agreements with RVPN or Central Transmission Utility of India Limited and wheeling and banking contracts with the relevant DISCOM.

Annual captive compliance verification framework

The SOP reiterates the annual verification process for consumers to maintain their captive status. The consumers must submit their bills or auditors’ reports confirming that they have consumed at least 51% of the energy generated by the captive project and must provide CAs’ certificates proving their 26% equity investment. Non-compliance with this will deem the relevant capacity of the project as a third-party sale, thereby making the consumers liable to pay additional surcharges and cross subsidy surcharges.

Utkarsh Mishra is a senior associate and Jahnavi Tolani is an associate at Sarthak Advocates & Solicitors