The Ministry of New and Renewable Energy (MNRE) has clarified with respect to the applicability of the Approved List of Models and Manufacturers (ALMM) on solar power plants that are installed to charge Battery Energy Storage Systems (BESS). One can understand it as the clarification of two exact questions. Question 1 was whether a business operation in the private sector that only installs a solar power plant to charge a BESS will be exempted with respect to the ALMM requirement as provided in the Office Memorandum (O.M.) dated 7-Oct-2022 and 9-Dec-2024 by MNRE. The second question was meant to find out whether such a solar project would fall under the Beehive installation classed as Behind the Meter.
Considering the issue, MNRE explained that a solar plant will not be considered a behind-the-meter system in the event it charges an Energy Storage System (ESS) that is directly or indirectly feeding power into the grid. As set out by the guidelines of MNRE, a behind-the-meter solar venture can only be utilized in captive consumption by a consumer or collection of consumers. These ESS-connected plants do not fit under this category, since the ESS-connected plants might be providing power to the grid in the future. Consequently, these solar projects cannot be considered to be exempt from the ALMM requirements of solar PV modules.
MNRE further explained that the ALMM applicability for solar PV cells used in these kinds of projects depends on whether the corresponding ESS project is itself exempted from ALMM for cells. If the ESS project being charged by the solar power plant is exempt from ALMM for PV cells under the guidelines mentioned in the O.M. dated 9 December 2024, then the solar plant supplying power to it will also be exempt. However, if the ESS project is not exempt from ALMM requirements, then the solar plant feeding it must also comply with ALMM obligations for PV cells.
This clarification was issued with the approval of the Secretary of MNRE and is intended to remove ambiguity in the implementation of ALMM guidelines concerning solar power plants connected to energy storage systems. It reaffirms the government’s position on ensuring that only approved solar modules and cells are used in grid-connected projects unless a clear exemption is granted, especially in the context of private projects involving energy storage.
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