The Ministry of New and Renewable Energy (MNRE) has issued a clarification regarding the applicability of the Approved List of Models and Manufacturers (ALMM) for solar power plants installed to charge Battery Energy Storage Systems (BESS). The clarification comes in response to two specific queries. The first question asked whether a private sector enterprise installing a solar plant solely to charge a BESS would be exempted from ALMM requirements, referring to MNRE’s Office Memoranda (O.M.) dated 7 October 2022 and 9 December 2024. The second question sought to know whether such a solar project would be classified as a ‘Behind the Meter’ installation.

After examining the matter, MNRE clarified that any solar plant charging an Energy Storage System (ESS) that is either directly or indirectly supplying electricity to the grid will not be considered a behind-the-meter system. According to MNRE’s guidelines, a behind-the-meter solar project must be used solely for captive consumption by a consumer or group of consumers. Since these ESS-connected plants could eventually supply power to the grid, they do not fall under this category. As a result, such solar projects are not eligible for exemption from ALMM requirements for 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.