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In its move to amend the Net Metering Regulations 2015, on 24th August Nepra (National Electric Power Regulatory Authority) issued a notice in the form of a draft SRO to change the word National Average Power Purchase Price (NAPP) to National Energy Purchase Price (NEAP) without explaining the rationale behind this move. Those familiar with the issue started talking about its impact on bills of Roof-Top Solar Generators since the current NAPP of Rs 19.32 per unit at which excess surplus is bought will be reduced to Rs 9 per unit only.

When the news reached the media, it gave the impression that a reduction had already taken place which led to a Press Release issued on 16th September, clarifying that no change had taken place and that its impact will be on 20,700 consumers across Pakistan who have been allowed Net Metering as per the regulations approved by NEPRA. It further explained that the proposed amendment would not have any impact on self-consumption as well as netting off the units and that it only applies to the excess units sold by Net Metering consumers. Additionally, the impact of cost paid of excess units would be shared by remaining consumers of the grid.

In the meantime, on 18th September, a press conference was held in Gujranwala (home to over 2,000 Net Metering consumers) during which Energy Minister Khurram Dastgir commenting on reports of changes in the net metering system, said that there is no such thing on the cards right now and no changes are being made for domestic solar energy users.

However, that message did not reach Nepra, as prior to the September 24th closing date to receive comments, it issued a notice on 21st September announcing a public hearing on 27th September at 11:45 am. No data was provided prior to the hearing on the Authority’s website, and it was expected that data will be shared during the hearing.

However, participants got the clear impression that Nepra officials had neither studied the comments submitted by Net Metering Consumers across Pakistan, nor provided any data of surplus units bought by the 11 Discos during fiscal year 2021-22.

Among two slides shared, one proposed reduction in surplus unit price from Rs 19 to 9 and the other was a payback period of 3.8 years of a 10-kw system which currently stands at 4.8 years. The Nepra Chair spoke for 20 minutes to 50 participants present in person and Zoom audience of over 200 and key among his comments was that the purpose of Net Metering facility is self-consumption and not to make profit by selling surplus units at the same price of Rs 19 per unit. Therefore, the difference of Rs 10 collected will be distributed among the 36 million consumers who do not have net metering.

Thereafter, during interaction of 70 minutes with 10 participants physically present, the most significant issue highlighted was that the Government has signed 25 years’ contracts with the Solar IPPs having upto 100 MW installations which also require financial guarantees and indexation of purchase price with US$ and as a result based on 2021 rate revisions, they were being offered purchase price between Rs 34 and Rs 25.

Moreover, since these projects were installed far away from the grids, there were huge line losses. In response to a question regarding the substantial difference between peak and off-peak rates, the Chairman in clear terms underscored the need for installing batteries.

A couple of Advocates argued that if the contracts with the Solar IPPs cannot be renegotiated then why are Solar Installers with 7 years’ licences being subjected to this amendment, which will be an infringement of their vested rights. The Nepra Chair appreciated this legal point and assured that the Authority will examine it.

The Chairman then commenced taking questions and a participant from Karachi said that while 10 Discos are on one path for implementation of the Net Metering Regulations by charging the GST on Net Units, he pointed out that K-Electric is charging GST on Gross Units. Since there were similar complaints, the Chairman hinted that with respect to the issues highlighted against K-Electric, he might have to conduct a separate hearing in Karachi.

The Chairman then suddenly announced that we will only take a couple of more questions since this session needs to be concluded as another meeting is scheduled at 1:45 p.m. Fortunately, among the many hands raised, I was given the floor wherein appreciating the Chairman’s love for Green Energy and the Green Flag, I said that batteries are already polluting the environment and therefore his recommendation to install batteries is against the very principle of Green Energy.

Solar Generators are supplying at Rs. 19.32 per unit to nearby transformers which with zero-line loss is being sold to a neighbor at Rs. 28 per unit during off peak hours and back to the generators at Rs 34 per unit during peak hours. True Net-Metering in other countries means that after the export in off-peak hours, the meter runs backward till the credit is exhausted.

However, in our case, to discourage use of UPS and batteries and to curtail the outflow of foreign exchange thereof, a wheeling charge of up to 10% be added to the price of off-peak units which can then be offset against the peak hours’ units.

Agreeing with the Chair that Net Metering should not be used as a tool to make profit, I proposed that instead of Net Metering Benefit in cash, an option to carry forward the units be allowed which will provide an ability to use the surplus units in the summer which were exported in the winter.

I also suggested that besides continuing contribution by the Roof-Top Solar Generators in reducing the CO2 carbon emissions, they be encouraged to donate surplus units to nearby mosques or to a not-for-profit community clinic. This proposal was moved by the writer at a PIDE online seminar on 24th September which was attended by 80 high profile professionals.

Vice Chancellor PIDE, Dr Nadeem ul Haq, moderating the webinar, gladly endorsed the suggestion. It is hoped that the Chairman Nepra too will consider the proposal, and this could be a feather in his cap as Pakistan would be the first country to adopt it.

Finally, reacting to 468MW generated by 20,000 + Roof Installers, assuming 500MW for simplicity’s sake, then according to an expert within Nepra, PVs generation capacity is 16% which works out to 80MW whereas Roof -Top Solar Net exported surplus may not be more than 25% which is 20 MW only.

Nepra’s response to this was that according to K-Electric Net Surplus is only 4%. Though hearing concluded in haste leaving many participants disappointed, to get my answer for the exact quantum of surplus units exported by Roof-Top Solar Generators, I learnt in a subsequent hearing (convened to hear the CPPA-G Petition) that Rs. 92 million was mentioned for total net export of units. Therefore, as provided in an XL sheet from CPPA-G to Nepra, in the month of August 2022, total surplus units exported by 28,000 Net Metering Generators to XW-DISCOS stood at 4.8 million units which at Rs 19.32 per unit works out Rs 93 million. If Nepra was to reduce the price to Rs 9 per unit, then Rs 10.32 difference will result in saving of Rs 50 million a month which, according to Chairman Nepra, if distributed among 36 million consumers, will be Rs 1.39 on a monthly basis or Rs 17 maximum per year which is next to nothing.

Surely, besides tariff experts, if an accountant was associated with this exercise, based on simple mathematics he would have advised against this amendment.

Even over the next 5 years when the Authority expects that Roof-Top Solars will add 500 MW each year, this figure will be below Rs 100 since the country is already in the grip of high tariff and per capita income in real terms will continue to decline. Thus, as opposed to offering Rs 17 per year, as a custodian and protector of 36 million consumers, perhaps it is about time that Nepra rose to the stature of asking the Federal Government to stop collecting TV license fees of Rs 35 per month instead. This burden lies on former Information Minister Sheikh Rashid who convinced the then Finance Minister Shaukat Aziz to introduce a monthly fee of Rs. 25 which was subsequently increased to Rs. 35. Removing this fee will straight away provide relief of Rs. 420 a year also to lifeline consumers who are already paying a sum to cable operators. Hopefully, this way Nepra will also help PTV stand on its own feet.

The views expressed in this article are not necessarily those of the newspaper

Copyright Business Recorder, 2022

Author Image

Moin M Fudda

The writer is a solar licence generator and a founder of Group “Save the Planet via Green Energy”.

Comments

Comments are closed.

Bilal Saleem Oct 07, 2022 08:55am
Regulators and policy makers in Pakistan are generally making policies while sitting in the drawing rooms without knowing the actual ground realities. Before making policies, they should forecast both long term and short term impact of the changes on Pakistan as a whole instead of investigating the problems created by those policies after its implementation.
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Muhammad Tayyab Oct 07, 2022 08:55am
Excellent analysis of 500 MW generation by 28,000 Roof Top Solar Installerers which results in only 20 MW net export without line losses to the 11 DISCOS in the country. So why reduce the per unit rate from Rs. 19 to Rs.9 of them whereas Solar IPP'S are getting Rs. 36 per unit with huge line losses. Also correctly pointed that these 28,000 installation are spread throughout the country making the environment Green and instead of encouraging why Authority is on the path of stopping it for the benefit of DISCOS
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Tajammul Hussain Chishti Oct 07, 2022 09:47am
Very well expressed the point of View of Roof Top Solar Energy Producers ,well done Moin A Fudda Sahib
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Pervaiz Kazi Oct 07, 2022 10:21am
Mr. Fudda, Thank you of this article. Another point to note in my opinion, The cost to generate electricity for IPP's and WAPDA remains the same 24 hours of the day, be it Hydel, Wind or Thermal. Peak rates are punitive and should not be the applied. The way net metering works here makes no sense and you are right every where in the world the meter running reverse while exporting should net off the units consumed in the 24 hour cycle. In our case this is why we don't have a Net metering in true essence due to peak and off peak rates.
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wz Oct 07, 2022 10:26am
the govt has already made us their mind and just formalities being done by calling this public hearing etc. its another move to please the IPP nothing else the govt has already made it difficult to import solar units and many companies have their import consignments stuck at port. i see this going to court where hopefully some sense will prevail because clearly we cant see any of it at NEPRA
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Nasir Raza Oct 07, 2022 10:42am
About regulators Chiefs and decisions makers on the concerned boards they even jointly can't take a sensible approach to the issues highlighted in press and electronic media. Looking at the attitudes and running the show in public hearing chairman NEPRA needs lot of training on social sciences and behaviour in public hearing . NEPRA management has so much spare time and NO ISSUES, involved in a small developing area of alternate energy where it's long way to go achieving a sizeable area of electricity production to become a viable alternative energy resource. It is also noticed that in english drafting of various regulatory notifications and directives very poor language is used creats interpretation issues. NEPRA needs lot off improvements in management and attitudes
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Ali Aziz Oct 07, 2022 12:14pm
If Chairman (more correctly EnergyHitman) NEPRA had called the meeting on such an important topic he should have cancelled the other meeting conveniently scheduled around lunch time. Moreover, as a person who wants to go Green and save money on outrageously high price gouging by KE, I am totally confused whether to install solar panels on my roof or suffer the indignities of frequent policy reversals. The government is inconsistent and unreliable and keeps tinkering with how to skin the consumers because neither the politicians ( beggars in suit) nor the incompetent and corrupt bureaucracy believes in global heating and climate change.
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Maqsood Ansari Oct 07, 2022 12:16pm
While one could potentially find it feasible to understand the Government's side of the story, it is mind-boggling how such policy changes are devised, when considerable third party interest has been generated. Thousands of homes and offices across Pakistan have invested in solar panels, only to find down the road that the benefit promised to them has been reduced by the Government. Are we now expected to spend millions more converting these net-metering solar setups to hybrid net-metering solar setups, installing batteries?
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Nasir Raza Oct 07, 2022 12:20pm
NEPRA is hostage in hands of incompetent bureaucracy they are not aware of environmental friendly green and clean energy resources in the current horrific DISASTERS due to climate change in PAKISTAN
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Feisal Ali Oct 07, 2022 12:21pm
Excellent article covering well all aspects of the NEPRA hearing. We need to move to a distributed mode of power to avoid transmission losses., energy which requires no imported fuels, is GREEN, Does not require any govt guarantees or price indexation linked to the $ and does not bind our and future generations through 25 year contracts. Despite all these advantages NEPRA is targeting residential rooftop installations less than 25 KW. WHY WHY WHY ???
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Shehzad Oct 07, 2022 12:22pm
The way the NEPRA Chairman conducted public hearing on change of solar definition from NAPPP to NAEPP was disappointing. It was obvious that he was doing it under the pressure of DISCOS and that too namely KE. The person who talks loudly/emotionally about not bowing to pressure and boasting neutrality shows there is some smoke behind the fire. Ones conduct should reflect neutrality so that you don’t have to repeat it again and again about being neutral and not bowing to the pressure. While NEPRA being so agile to change the definition from NAPPP to NAEPP but the way Chairman NEPRA was surprised to know the way KE does net metering which is differently than all the other DISCOS of Pakistan reflects he has no clue about what he was talking. Further, KE has stopped survey/net metering already in anticipation of lowering of tariff by NEPRA so that they don't have to pay higher tariff for the interim period.
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Shehzad Oct 07, 2022 12:25pm
The way the NEPRA Chairman conducted public hearing on change of solar definition from NAPPP to NAEPP was disappointing. It was obvious that he was doing it under the pressure of DISCOS and that too namely KE. The person who talks loudly/emotionally about not bowing to pressure and boasting neutrality shows there is some smoke behind the fire. Ones conduct should reflect neutrality so that you don’t have to repeat it again and again about being neutral and not bowing to the pressure. While NEPRA being so agile to change the definition from NAPPP to NAEPP but the way Chairman NEPRA was surprised to know the way KE does net metering which is differently than all the other DISCOS of Pakistan reflects he has no clue about what he was talking. Further, KE has stopped survey/net metering already in anticipation of lowering of tariff by NEPRA so that they don't have to pay higher tariff for the interim period.
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Tajammul Hussain Chishti Oct 07, 2022 12:27pm
I appreciate the efforts being done by Mr. Moin M Fudda and his team to analysed the scenario very wisely. They are fighting against any move from NEPRA to favor DISCOs and Penalizing the Roof Top Solar Power Generators. Government of Pakistan and Minister of Power, Mr. Khurram Dastagir must take an immediate action to protect and support Green Energy Producers who have invested huge amount to install Roof Top Solar Panels on their houses and industries.
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Shehzad Oct 07, 2022 12:31pm
The way the NEPRA Chairman conducted public hearing on change of solar definition from NAPPP to NAEPP was disappointing. It was obvious that he was doing it under the pressure of DISCOS and that too namely KE. The person who talks loudly/emotionally about not bowing to pressure and boasting neutrality shows there is some smoke behind the fire. Ones conduct should reflect neutrality so that you don’t have to repeat it again and again about being neutral and not bowing to the pressure. While NEPRA being so agile to change the definition from NAPPP to NAEPP but the way Chairman NEPRA was surprised to know the way KE does net metering which is differently than all the other DISCOS of Pakistan reflects he has no clue about what he was talking. Further, KE has stopped survey/net metering already in anticipation of lowering of tariff by NEPRA so that they don't have to pay higher tariff for the interim period.
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Tajammul Hussain Chishti Oct 07, 2022 12:44pm
I really appreciate the efforts being done by Mr. Moin M Fudda and his team for analysing the scenario very wisely. They are fighting against any move from NEPRA to favour DISCOs and penalizing the Roof Top Solar Power Generators. Government of Pakistan and Minister if Power Mr. Khurram Dastagir must take immediate action to protect and support Green Energy Producers who have invested huge amount to install Roof Top Solar Panels on their houses and industries.
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Munawar Oct 07, 2022 12:55pm
"If Nepra was to reduce the price to Rs 9 per unit, then Rs 10.32 difference will result in saving of Rs 50 million a month which, according to Chairman Nepra, if distributed among 36 million consumers, will be Rs 1.39 on a monthly basis or Rs 17 maximum per year which is next to nothing." *The above calculation by the writer explains all.*
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Emad Oct 07, 2022 02:48pm
Thank you Moin Sahab, Indeed you working hard to save our investment already made for solar
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Moinuddin Haider Oct 07, 2022 04:14pm
Following key takeaways from the Article If Minister had categorically said in the press conference that nothing is on the card to change the Net Metering Rules then either he mentioned it casually or NEPRA did not take the Minister's statement seriously and went ahead with the Public Hearing. Knowingly that there were 250+ participatints in one of the well attended hearing, why instead of listening in defending the Notice which did not contain any facts, why Chairman spoke at length and not dividing time among the participants. Abrupt closure of the meeting left a bad taste and gave the impression of Chairman acting as a Dictator and not a Professional. At more than one occasion, Chairman advised people to install batteries to use in peak hours. Does he not know that batteries are harmful to environment and State Bank is not allowing industries to open LC's for import of spare parts for machineries so how can country afford to spend Foreign Exchange on import of batteries. Thus, why can't off peak units be adjusted against peak hour units if need be by allowing DISCOS to charge 10% extra for storage. Why can't Solar Generators be allowed to carry forward the units and donate the surplus as suggested by Writer to give back something to the community instead of being forced to sell it to DISCOS. Finally, on behalf of 200+ members of Karachi Net Metering Group I had written several letters to the then Energy Minister Omer Ayub and Chairman NEPRA also about K-Electric which he denied receiving. Since my hand remain raised and among many I too was not given an opportunity to express, I recall Chairman NEPRA saying that country has 41,000 MW of generation and does not need to buy from Solar Installers instead it can take away surplus units free of cost. If that is the case then as an Independent Regulator why does he not submit before the PM that Sir we don't need extra 10,000 MW Solar energy now in the Grid and our focus should be to manufacture Solar Panels which India, Turkey and even Bangladesh are doing it successfully.
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Murtaza Ahmed Ali Oct 07, 2022 04:22pm
Excellent Analysis. 1. Clear case of Discrimination between Solar IPPs and Rooftop Solar Installations. Solar IPPs are selling at Rs 22, whereas Rooftop Solar Consumers are asked to sell at Rs 9. People Unfriendly policies of NEPRA and Discos, against its own Consumers. 2. Pakistan Gross Savings rate is lowest at <4%. Rooftop Solar encourages Investment / Savings into Productive Capital Assets and must be encouraged to increase our Domestic Savings rate
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Moinuddin Haider Oct 07, 2022 06:34pm
@Maqsood Ansari, correct because NEPRA chair repeatedly made a case to install batteries. Instead after hearing the participants, NEPRA should now get from the State Bank Foreign Exchange spending on import of Batteries and Hybrid inverters. Surely Chairman then only would be well informed and withdraw his statement and allow off peak hours unit netting with peak hours which will discourage use of batteries
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Shahid Gani Oct 07, 2022 07:14pm
As against taking away Rs. 50 million per month from solar generators and distributing Rs. 1.40 per month to each of the 36 million consumers, stopping collection of PTV licence fee of Rs. 35 per month is an instant benefit. But it is hard to believe that Chairman and members of NEPRA at the mercey of Federal Government for extension of their tenure will utter a single word on the subject. Given that Sindh High Court has recently stopped K-Electric's illegal recovery of KMC's dues, it is about time that a group of barristers acting in the Public Interest file a Petition before the Supreme Court to stop PTV fee collection of Rs. 35 from residential and Rs. 60 per month from commercial consumer. After all with exclusive rights of cricket series in the country and upcoming world T-20, PTV with a professional management and marketing team must stand on its feet and like private channals no longer be a burden on at least 36 million consumers who Chairman NEPRA rightly wants to help.
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Abrar Ahmed Oct 07, 2022 09:21pm
Awesome. Elaborate though but each sentence has its own weight in terms of the context. Nevertheless, I see this case going to courts because someone sitting in NEPRA or the DISCOs is against the development of this country.
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Abrar Ahmed Oct 07, 2022 09:23pm
A good case against NEPRA in the Supreme Court ought to be to pay Roof top exporters Rs 36 per unit, just like the Solar IPPs, otherwise, its a case of discrimination against general public vs IPPs by NEPRA
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Abdullah Oct 07, 2022 11:26pm
Nepra is ensuring that monopoly of IPPs and Discos is further entrenched in energy sector. They do not really have an issue with net metering per se but the fact that the people who install net metering are honest, tax-paying customers who pay their electricity bills. If they did not have solar/net-metering, they would be paying lacs of bill so IPPs and Discos are losing 'potential' profit. Completely sick mentality of bureaucrats and highlights the state of the country. Mindless, wasteful consumption being promoted over value-creating production.
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Concerned Oct 08, 2022 09:47am
@Murtaza Ahmed Ali, this is what monopolies are for.
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Salman Oct 08, 2022 11:01am
Very pertinent and timely. It is difficult to imagine that they (NEPRA and other decision makers) are discouraging clean energy through their policies and actions at a time when the country is amongst the top country significantly affected by climate change. Also, interests of roof top solar power generators should be protected who have already huge incurred cost on a certain policy pretext and shouldn't be subjected to further cost and losses in the name of batteries and adjustment of net metering rate. This is gross injustice.
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Mujahid Mirza Oct 08, 2022 11:08am
Thank you very much Mr. Moin for this detailed article. I also appreciate the efforts of the people who attended the conference and pleaded their case in a professional manner.
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اMuhammad Arif Oct 08, 2022 01:15pm
I was the first person invited to speak over Zoom at NEPRA hearing and talked about 10 DISCOS following on one path of collecting GST on units in accordance with the Net Metering Regulations whereas K-Electric on the pretext of having been advised by two Tax Advisors was collecting on Gross. During a meeting with KE management some people got the impression that with a narrow mind it was concerned about loss of Revenue since Net Metering was being availed by Bill paying customer and hence together with charging of GST on Gross Units, it was discouraging Net Metering by demanding high connectivity and meter charge of Rs. 150,000 which other 10 DISCOS were doing it at less than Rs. 50,000. Gen Moinuddin Sir, you are right as I have seen letters you have written behalf of the Net Metering Group about which Chairman NEPRA showed his ignorance. Later on when KE management realised that despite its tactics to delay the installation of Net Metering, number of customers had surpassed 4,000, KE Board approved formation of a subsidiary under the name and style of KE Solar. Without giving any consideration that utility had the huge monopoly of Generation and Distribution over the largest city of the country, yet NEPRA quickly granted the the license to KE Solar with which small players are finding it difficult to compete because Company is now giving priority for connections to the customers of its subsidiary. Did NEPRA ever specified in check and balances and has carried out independent Audit. Perhaps not because NEPRA officials had a soft corner towards the KE. It is about time that Competition Commission take a notice of grant of this licence otherwise small players will knock at its door. Another example of tuning blind eye towards KE is not taking a notice of a report in the Financial Times still on Google that Wotton Cricket, received funding of $ 1.3 million from Abraaj Group which eventually were sent to the PTI and “expensed the cost to a holding company of Abraaj through which it owned K-Electric,” both operated by Naqvi. Also according to the webdesk report of 13th September 2022, the channel aired the news that on 6th of September, the Auditor General in his report had said that during the three years of the PTI rule, at least Rs173.74 billion worth of RLNG was supplied to K-Electric without signing an agreement. The report said that the officials failed to provide the record of the agreement despite repeated requests. Now that the PTI
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Moiz ferozpurwla Oct 09, 2022 08:02am
While Nepra is buying from private generating companies at such high rates than why should not Nepra buy from SOLAR generating people at the same price. Private SOLAR generators too have invested in generating energy. Because of kickbacks from private Mafia companies they buy at higher prices. Than why not from SOLAR producers.
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