1. Introduction:

A National Energy Policy has become critical for any country.  The initiative by NITI Aayog to prepare a draft NEP (DNEP) is wholly welcome, as it comes at a critical juncture in India’s post-independence era.  DNEP considers the energy scenario by 2040 whereas Integrated Energy Policy (IEP) of 2011 had done so for year 2031-32.  Whereas DNEP has many good points and recommendations, it can be improved considerably through the feedback from the larger civil society and the domain experts. In a nutshell it can be said that the draft would have become vastly more credible from the overall perspective of nation’s welfare objectives if it were to consider the issues impacting the demand and supply of energy from social and environmental (Climate Change) perspective. It is fondly hoped that the vast number of recommendations/comments to be received from the individuals and the CSOs will be positively considered by the NITI Aayog, and a much more inclusive energy policy will emerge from a diligent review.

  1. Overarching Comments:

2.1          True objectives of National Energy Policy (NEP)

Recently, George Monbiot a prolific writer from UK on energy, environment, and Climate Change has said: “We cannot hope to address our predicament without a new worldview. We cannot use the models that caused our crises to solve them. We need to reframe the problem.”   The energy sector, which is a major contributor to GHG emissions and which is also intricately linked to the accelerated depletion of our natural resources, will need a paradigm shift in the way we deal with it.

True objectives of NEP, in the Indian scenario, can be stated as follows: (a) to laydown clear policies/ directions in choosing a set of most appropriate energy technologies to meet the legitimate demand of energy of all sections of our society on a sustainable basis at the lowest overall cost to the society;  (b) this has to be done keeping in view the twin goals of ensuring equitable welfare requirements of all sections and the proper upkeep of our natural environment in the context of the looming threats of Climate Change; (c) it should fully comply in letter & spirit with all the relevant Acts of our Parliament and the associated rules/polices, including International obligations.

In view of the fact that energy is considered essential for the overall development of our society, and since energy is also a major contributor to Climate Change, the NEP cannot succeed in its overall objective of contributing to the welfare of our communities, unless it takes all possible policy initiatives to minimise the deleterious impacts associated with Climate Change.

In analysing the draft NEP proper identification of the primary approach needed in the formulation of such a critical national level policy can be of help. In this context the following five issues can be considered as essential:

(i)     Rational approach in projecting a realistic energy demand and the associated issues

(ii)    Correct approach in the choice of suitable technologies and the effective usage of the associated global knowledge

(iii)   Diligent analysis of the costs and benefits associated with of each of these technologies from a societal perspective

(iv)  Social and environmental impact analysis in the background of the relevant global experience

(v)    Compliance check with the relevant Acts, rules, and policies.


Overview of DNEP

The analysis of the DNEP is best done considering the highlights of its projection by 2040.  Some of the key implications projected by DNEP by 2040 (page 98) are:

  • Share of non-fossil fuel based capacity in electricity: 57% – 66%
  • Per capita energy demand: 503 kgoe/capita in 2012 to 1055-1184 kgoe/capita in 2040.
  • Energy related Emissions per capita: 2 tons of Carbon Dioxide Equivalent/capita in 2012 to 2.7-3.5 tons of Carbon Dioxide Equivalent/capita in 2040
  • Per capita electricity consumption: 887 kWh in 2012 to 2911-2924 kWh in 2040
  • CAGR of electricity supply (Ambitious scenario): 5.5% between 2012-2040
  • CAGR of primary energy supply (Ambitious scenario): 3.6% between 2012-2040
  • Overall Import dependence (including non-commercial energy): 31% in 2012 to 36%-55% in 2040.
  • Reduction in emissions intensity: 45%-53% by 2030 from 2005 levels


2.2 Energy Demand Projection Concerns – the need to contain the demand

From these bullet points two issues stand out as clear indicators of all the major concerns for the future, if our energy sector were to proceed as projected in NEP.  Nearly 3 times increase in per capita energy related emission by 2040, as projected in NEP, is a very poor reflection of our national priorities as far as human health and the upkeep of our natural resources are concerned. For a much increased population by 2040, such a high per capita emission not only means huge health implications, but also vastly increased exploitation of our natural resources, which are already a concern as in 2017, and as reflected by the unacceptable pollution levels of air, water and land. If our energy resource import dependence should become as high as 55% by 2040, the foreign exchange burden will be enormously high, and the energy security can remain only as a niche term in books.

It is essential that DNEP, as a critical national policy, should consider the implications of such vast increases in GHG emissions and the import bill from social, environmental and economic perspective in the long run.  Such implications are:

  • Critical elements of our natural resources will be vastly degraded; probably reaching a point of no return much before 2040;
  • With so much fossil fuel burning what will be the status of air quality, and the contamination of land and fresh water bodies; similarly how much of our natural forests will be left by 2040?
  • While the growth in population, urbanisation and industrialisation are already putting extreme pressure on the population density parameters, can the land diversion for all these additional power/energy plants and the associated infrastructure improve the scenario in any way?

Whereas the total energy demand between 2012 (as the reference year) and 2040 is projected to grow between 2.7 and 3.2 times, the draft projects that only 17% energy savings is feasible by 2040 between the BAU and ambitious scenario (Table 4 of DNEP).  When we objectively consider the gross inefficiency prevailing in energy production, transportation/transmission /distribution, and utilisation in different sectors of our economy, the potential to reduce the overall demand through measures such as efficiency improvement, demand side management (DSM) and conservation can be seen as huge. Hence, the savings feasible between the BAU and ambitious scenario could be much higher; likely to be much more than 25%.  Suitable policy interventions in this context will help to reduce the overall energy demand to a much lower level than that is projected by 2040.

The electricity sector alone is known to have the potential to reduce its demand by as high as 40% through efficiency improvement measures. But DNEP has assumed only 6.5% reduction in demand by 2040 (DNEP table 6).  Additionally, the share of electricity in total energy demand by 2040 is assumed as only 26% by DNEP (DNEP table 7), whereas the global projections say that by 2050 more than 60% of global energy consumption is likely to be in the form of electricity.  Keeping the convenience of using electricity, the zero pollution at the point of usage, and the fact that much of electricity can be obtained by renewable energy (RE) sources, it is highly desirable to have a high percentage of electricity in the national energy basket. Similarly, the sectors such as transport, pumps & tractors and buildings also have huge potential in energy demand reduction.  Hence, all possible efforts should be put into reducing the total energy demand by vastly more than 17% of the BAU scenario in 2040.

Additionally, it must be stated that the high T&D loss of around 22 percent in electricity sector, against a global average of less than 10 percent and best practices of less than 5 percent, is not a matter of pride for India, which is striving to excel in various fields. Targeted reduction of aggregate technical & commercial (AT&C) loss to a minimum of 10 percent by 2030 should be one of the major targets in the policy.

DNEP also indicates that the demand for coal may go up by 2.5 times.  It indicates that the overall import dependence (including non-commercial energy) may go up from 31% in 2012 to 36% -55% in 2040.  The combined effect of burning all these hydro carbons (in solid, liquid and gaseous forms) in vastly increased quantities by 2040 will result in a tremendous addition to GHG emissions, which will be a hugely negative factor from the Climate Change perspective.  No amount of technological advancement in the so called ‘clean coal/energy’ technologies will be able to bring down the GHG emissions to a much lower level, which is unquestionably needed by 2040.  This scenario will negate the letter and spirit of India’s INDC to UNFCCC, and its ambition to become a global leader.  The continued dependence on the import of hydro carbons, which in India’s case already has huge concerns w.r.t the foreign exchange considerations, will have increased economic and energy security implications.  Such increased foreign exchange burden is also against the efforts of the present govt. to minimise the import bill.

Whereas the nuclear power has not enjoyed the much needed public confidence even after about 5 decades of its introduction in India, its negligible percentage in the national electricity capacity basket (about 2%), the enormous capital cost, the need to depend on imported fuel/technology, and the costs/risks associated with nuclear accident/spent fuel, cannot make it a suitable technology for a densely populated and poor country like India.   Similarly, dam based hydro power plants have many issues of concern to our densely populated society, such as the forced displacement, loss of forests & agricultural lands, and the degradation of river ecology.  The renewable energy (RE) sources too, if not managed properly, have the issues of ecology and land diversion.

Additionally, the unlimited energy demand growth has huge economic and natural resource implications, such as forest felling, mining related issues, land diversion, people’s displacement, enormous costs of transmission systems, pollution loading etc.

The considerations such as taking the per capita energy consumption to a much higher level, additional employment creation potential, and adding to GDP growth rate etc. should not become the primary objectives of our national energy policy.  Such considerations will distort the primary objective of NEP, which is to ensure the minimum quantum of energy that is required to eradicate poverty at the lowest overall societal cost while not compromising the health of our environment.  It is a well-known fact that the linkage between the per capita energy consumption and HDI is not true under all situations, and that it is true only at very low consumption level. Whereas there is a belief that the industries and commerce alone can add considerably to the employment opportunities, it is pertinent to know what Tamil Nadu State Action Plan on Climate Change has said. It says: “Global development experience reveals that one percent growth in agriculture (and associated activities?) is at least two or three times more effective in reducing poverty than the type of same growth emanating from non-agricultural sector.”  In this context, there is a serious case to consider only those economic activities which demand minimum energy and natural resources for employment generation opportunities.

The high GDP growth rate paradigm, which has been practiced by the successive governments for decades, has created many intractable problems for the country including the unsustainable exploitation of our natural resources and contamination of air, water and land, and all the associated issue for the vulnerable sections of our society, as highlighted in a World Bank report of June 5, 2013 on India’s economy.

Reference documents on efficiency and DSM issues:

(I) “Power Sector Road Map for Tamil Nadu – 2050”; April 2016; (http://mitramaadhyama.co.in/archives/2791)

(ii) “Integrated Power Policy”, Sept. 2012; (http://freebookculture.com/?p=172)

Energy/Water nexus: In recent years the close relationship between the usage of energy and water are getting highlighted for obvious reasons; so much so, that in US the ‘Nexus of Energy and Water for Sustainability (NEWS) Act of 2014’ was enacted and defines the term energy-water nexus as the link between energy efficiency and the quantity of water needed to produce fuels and energy, and the quantity of energy needed to transport, reclaim, and treat water. As per UN, because of the undisputed relationship between the usage of water and energy, there is a clear imperative of effectively managing both these aspects of our life keeping in view the impact of Climate Change in order to achieve the equitable development of all sections.

Water–Energy Nexus

As per an editorial in Current Science of April 2014 (“International World Water Day 2014, Focus: Water–Energy Nexus”) ‘Energy and water are closely intertwined. It takes a great deal of energy to supply water, and a great deal of water to supply energy’.  This article also points out that water consumed for energy production, according to International Energy Agency (IEA, 2013), will increase from 66 billion cubic metres (bcm) at present to 135 bcm by 2035. Out of this global energy related water demand, it is estimated that more than half of this consumption will be by coal-fired thermal power plants, about 30% by bio fuel, whereas oil and gas-based production will account for 10%.  Renewable energy generation, such as wind and solar photovoltaic power, accounts for less than 1% of water consumption for energy production. While power generation, as indicated above, requires large supply and utilization of water resources, energy itself is required for pumping, transporting, treatment and desalination of water. Agriculture, including irrigation, mining of coal and lignite, hydraulic-fracking, manufacturing and construction industries, use as much as 37% of the electrical energy produced.

India, being a water stressed country, should carefully consider this nexus between energy and water for the true welfare of the growing population, and take all feasible options to contain their combined impact on our communities.

After considering all these grave concerns associated with energy sources and electricity production technologies in a holistic manner, it has to be emphasised that there are certainly limits to how much the nature can provide to meet our escalating demands.  Hence, energy demand management should receive much higher priority in the energy policy than it has been in our country.

2.2          Energy Supply Options/ Technologies – the relevance of social and environmental perspectives

Keeping in view the continued growth of the already huge population base; unmet energy demand of about 25% of the population; the socio-environmental impacts of vast growth in energy demand; and the Climate Change considerations etc. the primary approach should be to determine the minimum quantum of energy required by our society to eliminate the poverty at the lowest overall societal cost on a sustainable basis.  Hence, the objective should not be to meet the unlimited amount of energy demanded by few sections of the society, but to determine a manageable limit to the total energy demand of the entire society.

The country cannot afford the increase in the hydro carbon demand by vast margins as projected in DNEP.  One of the most feasible options to reduce this demand is the fuel switching for transport sector, which has been discussed briefly in the DNEP.  Whereas the deployment of electric vehicles (EV) is passingly mentioned, this option needs to be supported by a concerted action plan to minimise the liquid and gaseous hydro carbon import dependence. The maturity of this technology can be gauged by the fact that France has decided to ban the sale of gas and diesel Vehicles by 2040, and many countries, including India, have plans to massive introduction of EV vehicles by 2030. In July 2017, Volvo announced it would phase out production of petrol/diesel-only cars from 2019 in favour of electric cars.  Energy storage technology, led by vehicle battery technology, is going through unprecedented progress and has provided confidence to transport industry to aspire for EV technology as the mainstay by 2030.  Keeping in view the pollution impacts and foreign exchange burden of liquid and gaseous hydro carbon, India should plan for massive induction of EV vehicles by 2040.

Bio-fuels, in an agrarian country like India, have huge potential.  Expert opinion indicates that it is possible to supply transportation fuel (at least 30%), rural electrification, waste to energy conversion, rural employment, reduction in air pollution, improving the soil fertility and rain water recharge by encouraging bio fuel.  NEP should lay down clear, ambitious and time-bound bio-fuel development /usage program.  Rural energy supply for cooking can be based on this source.  However, the competing demand on land for growing bio-fuel plants should be managed in such a way that the food security is not affected in any way.  Very specific and unambiguous guidelines should be stipulated in the policy.

Railways, being a major consumer of diesel, can eliminate its usage completely by rapid electrification of its routes, and by optimally utilising its estates, such as railway platforms, buildings etc., for roof top solar PV systems.  Indian Railways is already on an ambitious program of electrification, and this should be hastened by adequate investments.

Many of the heating and cooling applications in industries have the potential to be supplied by solar and bio-energy. Adequate encouragement is needed.

Gaining from the domestic and international experience it is safe to state that the usage of coal, diesel and gas in electricity generation can and must be minimised by 2040.  Coal usage has been on a steep downward slope across the globe since 2010, and many countries have plans to completely stop its usage before 2040.  India, with a vast potential of renewable energy (RE) sources, and a low per capita energy need, is uniquely placed to make an early move from a coal dependent energy scenario to an RE dependent scenario. Whereas all fossil fuels have the concerns associated with GHG emissions, pollution of land, air and water, the liquid and gaseous fuels also have the import dependence issues.  The TAPI gas pipeline and other similar proposals to import gas from gas rich regions have many difficult issues to contend with and may not be resolved in the near future.  Hence, they cannot be seen as feasible options beyond immediate future.

The advocacy on ‘Clean Coal’ technology has remained very feeble basically because the CO2 emission cannot be eliminated completely.  Technologies such as CCS and CBM have proven to be very costly, inefficient, and most of the pilot projects have been discontinued. The issue of safely keeping the sequestered CO2 away from the atmosphere has not been addressed satisfactorily.   Similarly, the hydraulic fracture (or shale gas or fracking) as a technology, has been associated with huge controversies such as pollution of underground water. Several countries have banned or declared moratorium on hydro-fracturing of shale. Physicians, Scientists and Engineers have been in the forefront opposing unconventional fossil fuels such as shale gas for environmental reasons alone.  GO no. 186 dated 08.10.2015 of Tamil Nadu government questions the very wisdom in the inclusion of CBM as part of energy policy.  In this context, these unconventional technologies on the usage of hydro carbons also cannot be considered as suitable for the Indian scenario.

Three reports/news articles as in the box below may indicate the seriousness of the issues associated with fossil fuels in general and coal power in particular.

The debt threat lurking behind India’s zombie power plants   


A Reuters analysis of India’s power output data shows over 50 coal- and gas-fired power plants in India are largely mothballed, or operating at a bare minimum.  After steel, power firms make up the second-biggest portion of India’s $150 billion mountain of bad debts.  India’s stalled or stranded power projects account for nearly 50 gigawatts of electricity production capacity.

India will take atleast 6 years to cap toxic emissions from power plants.


The nation’s power industry regulator says a countrywide roll out of equipment to lower sulfur dioxide emissions won’t be completed until 2023. And that’s only one of the the four types of pollutants plants must cap.

 The coal truth: how a major energy source lost its power in Britain https://www.theguardian.com/business/2017/jul/19/how-coal-lost-power-britain

“Only five years ago, the fuel was generating more than 40% of the UK’s electricity, but new analysis by Imperial College London reveals coal supplied just 2% of power in the first half of 2017.  More than 1,000 deep mines and nearly 100 surface ones operated until the early 1960s – today there are just 10 tiny mines left.  Pollution laws and carbon taxes have forced large, ageing plants to close in the past five years, with three major ones closing in 2016 alone.”

Similarly, the dam based hydro power from Nepal and Bhutan has some limitations, and is also constrained by domestic considerations such as environment and people’s displacement. Our experience of imported nuclear power technology has so far been highly discouraging.  Due to cost and time over-runs associated with land acquisition, local opposition, environmental clearance etc. the price of electricity from dam based hydro and nuclear reactors have already become very high as compared to the RE sources. Additionally, all these conventional technology electricity sources are dependent on large unit sizes and complex integrated power grid, which has been known to be against the principle of energy justice amongst different communities such as urban and rural areas.


Major issues with conventional technology electricity sources

                                 (Source: author’s compilation from various sources)

Fossil Fuels (coal, gas, diesel)  Dam Based Hydro         Nuclear Power
Economic Issues Huge pressure on natural resources such as land, water and minerals; reduced agricultural production; ever increasing capital and operating costs; fast depleting fossil fuels Demands large tracts of forests and agricultural land; water logging; impacts fishing income Demands large tracts of forests and agricultural lands; huge capital costs; long term waste management costs; vast  requirements of fuels and technology
Social  Issues Peoples’ displacement and Health; denial of access to natural resources for the poor Peoples’ displacement and Health; denial of access to natural resources for the poor Peoples’ displacement and health; denial of access to natural resources for the poor


Global warming; pollution of land and water and air; large quantity of ash; radiation from ash Methane emission, submersion and fragmentation of forests Mining related pollution; radiation emission; GHG emission in the overall life cycle

India has a huge potential in RE sources such as solar, wind, bio-mass and ocean energy, which need all the possible policy interventions and budgetary support for some more years.  As compared to the massive direct/indirect subsidies received by fossil fuel industry for nearly hundred years, RE sources are not expected to need them for many more years.  If the policies and regulatory measures to effectively deal with the social and environmental costs/issues associated with fossil fuels were to be in place, the RE sources may present themselves as vastly cheaper even in 2017.

Whereas the complete elimination of fossil fuel usage in Indian scenario may be difficult in the foreseeable future because of multiple reasons, a high percentage of RE sources is considered techno-economically feasible by 2040/50. A number of reports from around the world have shown the techno-economic feasibility of very high percentage of RE sources in the electricity grid as at present, and of 100% RE sources with suitable modifications in the sector.  The issues such as seasonality of wind power and the non-availability of solar power during night hours have already been satisfactorily addressed through effective usage of energy storage facilities, such as batteries, pumped storage hydro, concentrated solar power (CSP) systems etc.  Additional measures such as demand response techniques, better interconnection with different climatic zones, effective usage of EVs etc. can make the RE based electric system adequately reliable. A number of reports /simulations /practical experiences from around the world on the high percentage penetration of RE sources in the existing electricity grids /scenarios should be able to provide us with the necessary level of confidence

References on high percentage RE penetration: 

(i)“Roadmaps for 139 Countries and the 50 United States to Transition to 100% Clean, Renewable Wind, Water, and Solar (WWS) Power for all Purposes by 2050 and 80% by 2030”; Prof. Mark Z. Jacobson and others; Stanford University



(ii) “Comparing electricity production costs of renewables to fossil and nuclear power plants in G20 countries”,  Greenpeace Germany ;


(iii) (https://www.theguardian.com/australia-news/2017/jul/10/ambitious-clean-energy-target-will-mean-lower-electricity-prices-modelling-says); energy analysis firm RepuTex.

(iv) “Pathways to Integrate 175 Gigawatts of Renewable Energy into India’s Electric Grid”; Ministry of Power;



In order to move towards a very high percentage of REs in the energy sector, including that in electricity sector, NEP should come up with a definitive and much more ambitious target of GHG emission reduction by 2040/50 and RE source capacity addition, backed by clear targets at 5 years interval.  This will go a long way not only in vastly improving our energy scenario but also in drastically reducing the contamination of our natural resources while enhancing the status of our country at the global level by drastically reducing the GHG emissions.  Adequate clarity in such a policy will also help to attract investments and to change the electricity generation capacity scenario in the country by a considerable margin with coal, gas and nuclear power capacity at very low levels, if not eliminated completely.  The objective of NEP should be to advocate major changes to the data provided in Table 10 and 11 of DNEP, and these tables can look clearly dominated by RE sources, and not by any of the conventional energy sources.

The findings of a recent study from the Department of Energy (DOE) of US (as in the box item below in July 2017) have concluded that coal and nuclear power are uneconomic. But the advocates of coal and nuclear power in India may argue that the scenario of US is different to ours. While the two societies are not exactly similar, the associated issues from the electricity sector’s perspective are not totally irrelevant to each other either. There is a lot India can learn from US’s experience, and it can avoid many of the humongous costs which US has incurred in its developmental pathways.

“Coal and nuclear are uneconomic — more bombshells from Perry’s draft grid study”



A leaked draft of US Energy Secretary Rick Perry’s grid study belies the attack on renewable energy. Among other things this report say: “ … a large fraction of America’s aging fleet of coal and nuclear plants are simply not economic to operate anymore.”  “..  the marginal cost of generation for many nuclear plants is higher than the cost of most other generators in the market.” “High levels of wind penetration can be integrated into the grid without harming reliability.”  It’s really no surprise that the DOE staff has concluded that the renewables are not threatening grid reliability. After all, many countries around the world, such as Germany, have integrated far higher percentages of solar and wind than we have, while maintaining high reliability.


2.3          Future electric power system – the need for a paradigm shift

Keeping in view the number of vexatious issues of the centrally controlled and fossil fuel based integrated electricity grid system the future electric power system can be expected to be a federation of a large number of micro-grids/smart grids enabled by suitable ICT and protection technologies.  Such micro-grids can be expected to be electrically connected to each other directly (to the adjacent grids) or through local distribution and grid transmission lines. An indication of the future electric power system can be ascertained by two news items in the box item below.

“Market transformation will end dominance of electrical utilities, regulators predict”


3 Questions: The future of the electric utility


Three current megatrends in energy which are deeply interconnected: decentralization, digitalization, and decarbonisation, can indicate the basic characteristics of the future electricity system.  India’s national energy policy cannot afford not to take cognisance of such developments elsewhere, and hence they should be studied diligently and factored in NEP accordingly.

Electricity Generation

The power network of 2040 should have a large number of small size roof top SPVs OR wind turbines OR community based bio-energy/CSP type solar power plants, because of which the need for a stronger/reliable integrated grid will increase, but the nature of the grid will be different. There can be very few conventional technology power plants such as few gas based plants, dam based hydel plants, and pumped storage plants, which are already constructed and which have long life cycles.

The chief scientist Dr. Alan Finkel’s report on the future of the national electricity market in Australia gives a glimpse of how profound the change will be in future. The report cites data suggesting that by 2050, 30% to 45% of annual electricity consumption could be supplied by consumer-owned generators alone; namely, rooftop solar photovoltaic and battery storage.

Electricity Transmission

It is credible to forecast that instead of the need for more of high voltage transmission corridors transferring large chunks of power over hundreds/thousands of kM, the electricity grid of the future will be required to be strong and reliable at lower voltage levels, and may be basically designed to connect a large number of mini/micro grids.  In view of large number of small size roof top SPVs OR wind turbines OR community based bio-energy/CSP type solar power plants, and mini/micro grids expected in future, the distribution system will have to discharge a very critical role in maintaining the stability of the network in connecting power sources and consumers, and in ensuring reliable and quality supply in the most optimal way.

Electricity Distribution

In order to minimise the distribution losses the distribution companies can be expected to have much higher ratio of 11 kV to LT lines as compared to what it is at present, and much larger number of pole mounted distribution transformers of appropriate size to cater to the requirements of individual consumers. High Voltage Distribution Systems (HVDS), which are already in practice in places like Delhi, to avoid unauthorized use of grid electricity, can become the mainstay of the system. Each mini/micro grid can be expected to become a Smart Grid and equipped with suitable ICT and protection systems to be able to be connected to the adjacent smart grid or the integrated grid. In such a scenario the reliability of supply to individual consumers can be expected to be of very high order, because of the essential need to keep a reliable connectivity at all times to individual generators who may supply the excess electricity to the grid.


Agricultural Pump-sets

At the national level agricultural sector is known to be consuming about 25-30% of the annual electricity mostly for water pumping, and is generally associated with very low overall efficiency.  Since water pumping for agriculture is needed mostly during the day time of the summer months, solar power pump-sets are highly suitable.  100% shifting of agricultural loads to distributed solar power system will lead to a massive reduction on the integrated grid demand (if connected for isolated operation), will reduce the T&D losses to a low level, and will vastly improve the voltage profile everywhere. Roof-top mounted or locally installed solar pump-sets also have the potential to turn around the economics of distribution companies by relieving them of the burden of the associated subsidies year after year.  Such fuel switching has the potential to minimise/eliminate the demand for diesel in agricultural sector.


2.4          Future transportation system

If suitable policy interventions and support are provided early, it is reasonable to project that the number of petrol and diesel passenger vehicles/trucks will come down drastically by 2040, and that they will be replaced by efficiently run mass public transportation facilities such as metro rail system, sub-urban and long distance electrified rail systems, and battery operated cars, buses and trucks.  Bio-fuels are also projected to have the credible techno-economic potential to support about 30% of the transportation needs.  At present it is hard to find adequate encouragement for the production and usage of bio-fuels in the country.  There is huge potential for the sustainably produced bio-fuels, without impacting the food production, and this potential should be optimally harnessed to minimise the import dependence for liquid and gaseous hydrocarbons. However, there are uncertainties still persisting with the technological feasibility of replacing fossil fuel needs of aviation and shipping lines. It is hoped that in the near future suitable technological solution will be found.

  1. Other Issues of concern which need to be addressed by NEP

The discussions in DNEP have thrown many other issues of concern to our society, when we consider the true welfare of our communities on a sustainable basis.  The past practice of centralised efforts to meet the unlimited demand for energy of tiny sections of our society have already led to very many problems, including that of energy injustice, accelerated depletion of our natural resources, and pollution related issues. Such issues need careful consideration in NEP.

Energy Demand Management

  • Is it in the true interest of our society that the share of manufacturing in our GDP should go up to 25% from the present level of 16%? Can we not avoid the implications associated with the resource mobilisation, pollution loading, and much higher energy demand by opting for benign economic activities?
  • The dichotomy prevailing in the Indian energy scenario is made clear in IESS modelling. Why should we accept a much higher increase in per capita energy consumption by 2040 as a foregone conclusion, while we also say that energy demand could be brought down over the default scenario by 17% by suitable interventions? When we objectively consider our huge population base, gross inefficiency prevailing in energy sector, alarming rate of natural resource depletion, the global warming implications etc., maintaining the per capita energy consumption at about the same level as on today or even reducing it while aiming to lift our masses from the clutches of poverty at the same time should become the primary plank of energy policy.  In this context, it can be said that both the Integrated Energy Policy (IEP) of 2011 and the draft National Energy Policy (NEP) have started on a wrong footing.


Key objectives

  • The energy policy should not have the specific objective of feeding to the goal of rapid economic growth. High GDP growth rate paradigm year after year can only lead to very high energy demand in few decades time with all the other attendant risks/costs to the society.
  • A lot more focus on all aspects of energy efficiency will be needed. This aspect also indicates the vast scope for containing the energy demand growth as compared to the ‘do-nothing’ scenario.  Energy efficiency, demand side management (DSM) and energy conservation measures must have the highest priority in our efforts to provide energy/electricity to all by 2022. As National Electricity Policy has rightly stated, these measures should form the fundamental planks of our energy policy.


  • The projection of vastly higher coal production/consumption by 2040 can be said to be clearly against the letter and spirit of Paris agreement on Climate Change.  No argument should be able to support such a growth in coal production/consumption, if our society is serious about the impacts of Climate Change and the immediate pollution impacts on the health of our people.  NEP should be very clear and unambiguous on the need to contain GHG emissions. It should seriously consider the peak coal year much before 2030 instead of looking for ways to meet the ever growing demand for coal by the industry even after 2040.
  •   In a paper in Nature of 28 June 2017 with the title “Three years to safeguard our climate” a group of prominent scientists, policymakers, and corporate leaders have issued a warning that if the world doesn’t set greenhouse gas emissions on a downward path by 2020, it could become impossible to contain climate change within safe limits. Being the third largest GHG emitter, India cannot continue to ignore such science based warnings to reduce the GHG emissions.  In view of the suitable alternatives available to replace the coal, the country should seriously embark on such replacement at the earliest.

Renewable Energy (RE)

  • REs will need the continued monitory/policy support for many more years, if not for decades, in order to minimise the GHG emissions from the energy sector. Having pushed our environment to a dangerous level through reckless burning of fossil fuels all these years, the society should not hesitate to pay any needed additional costs to make the REs the mainstay of the power sector, and to mitigate/adapt Climate Change.
  • All these years, while considering large role for dam based hydro power and nuclear power in the country, the overall cost to the society from social, economic and environmental perspectives have not been carefully/objectively considered through the diligent economic decision making tools such as “costs and benefits analysis” and “options analysis”.   When such diligent decision making tools are objectively deployed, REs will find themselves largely beneficial as compared to nay of the conventional energy sources.
  •   The statement in section 6.5.3 that ‘grid based electricity is preferable to renewable solutions, and that the efforts would be made to first electrify villages by extension of grid’ should be carefully reviewed. The grid based electricity has led to the denial of energy justice to rural India, and the grid extension to remote villages is officially recognised also as uneconomical. Rural India will be well served by distributed RE sources in micro-grid/mini-grid mode in most cases. There are already many such good examples in Bihar and elsewhere.  As a matter of fact it will be easy and cost effective to meet all the electricity needs of rural India, including that of agricultural sector, through distributed RE sources, such as roof top SPVs, community based bio-mass units, small size hydel power units etc. supported by mini-/micro-grids.  Such an approach will eliminate all the concerns associated with the national grid extension to rural areas.
  • While comparing the large size RE sources such as solar/wind power parks with distributed RE sources, it should be kept in mind that in addition to requiring vast tracts of land, the large size RE sources also need additional dedicated transmission lines, which will be in use for a small percentage of time in a day (such as about 6-8 hours a day for solar power park).  In view of this potential wastage of the financial resources due to low utilisation factor of the associated transmission systems, and also for the ease of grid integration, it will be necessary to plan for a large no. of small or medium size REs (say of the size less than 5 MW) or roof top SPV systems all over the grid, preferably very close to the existing HT/LT lines. Such a distribution of the generating sources will also assist in overcoming the voltage instability, which is haunting the grid operators now. Additionally, the distributed kind of RE sources, such as roof top SPV systems and community based bio-mass units will encourage the general population to bear the cost of such plants (at least to a large extent) as PROSUMERS, thereby vastly reducing the financial burden of the government.

Nuclear Power

There is a critical need for DNEP to effectively deploy the economic decision making tools, such as ‘costs and benefits analysis’ and ‘options analysis’ to determine the realistic life-cycle cost of nuclear power and also to satisfactorily address the main concerns of safety before persisting with the statement that “nuclear power technology as being the only base load power source offering green energy, needs to be promoted even if its share in the overall mix is not high enough now”.  Without convincing the public on such issues, the energy policy cannot be expected have people’s approval.

NEP should make concrete recommendation to stop spending the colossal amounts (and the scarce natural resources too) on propping up the fossil fuel and nuclear power technologies, and to spend a small percentage of such saved resources to make the RE sources much more useful to our society. 

Reference material on issues of concern on nuclear power:

  • “An overview of nuclear power in the context of additional capacity to Kaiga NPP”


  • Amory Lovins: Nukes Not the Answer


Other critical issues in electricity sector

  • Keeping in view the credible social, economic and environmental concerns of conventional electricity production technologies the only option left for the country is to get all of its electricity and much of energy from renewable energy sources as early as possible. Such a transformation requires massive and concerted efforts in making the production transmission/transportation and utilisation of electricity highly efficient with huge emphasis on demand side management and energy conservation. The constraints of our natural elements will not permit an unlimited growth in energy/electricity production/consumption even through RE sources. NEP should be based on this fundamental reality and should be clearly stated so.
  • While advocating an effective energy policy for the nation, the primary focus should be on technical feasibility, sustainability, and the lowest overall cost to the society, instead of getting obsessed with the upfront financial costs alone. In this background adequate investment to minimise the Global Warming impacts of conventional power plants is considered worth the “huge financial cost”. Hence, the upfront financial cost of the required transformation of the country’s energy sector can be said to be insignificant when we consider the ecological & economic costs of not quickly transforming our developmental paradigm.

‘The Economics of Climate Change’ by Sir Nicholas Stern, 2006

As Sir Nicholas Stern has said in his advice to the UK govt. the Climate Change could have very serious impacts on growth and development of a densely populated and resource constrained society like India. The benefits of strong, early action on climate change clearly outweigh costs.  This review has estimated that certain scenario of Global Warming may result in poor countries like India suffering economic costs of about 20 % of its GDP, whereas the mitigation of the same now can be achieved at a cost of about 1% of present GDP.  The Review also indicates that the more we delay in addressing the Global Warming the higher we will have to spend in mitigation of the same in future.

  • The policy guidelines to move our energy sector to the 2040/50 scenario through clear and definitive policy objectives should be spelt out in as much details as possible so that private investors can take confidence required for such long term investments. Such policy guidelines will require due diligence and effective consultation with various stakeholder groups before finalising the policy framework.

Overseas Engagements:

  • As compared to the DNEP statement that with high import dependence for commercial primary energy supplies, NEP should be aiming to minimising the need to import energy/energy resources for multiple reasons. In order to do so the emphasis should be on: (i) minimising the total demand for energy; and (ii) to optimally and sustainably harness the resources available within the country. Sadly, as of now there is not much of a focus to reduce the total demand for energy itself, but only to identify different technologies to meet the ever growing demand.  Instead of trying to shift the total demand for transportation fuels to electric vehicles (EV) and batteries, the focus should be to minimise the transportation fuel need itself, by suitably modifying our urban areas and the location of industries/ commerce; adequate development of rural areas; huge emphasis on mass/ public transportation & railways; and suitably designed disincentive to private passenger vehicles.
  • Knowing well the serious concerns associated with nuclear power technology, including the overseas technology/fuel, it is truly unfortunate that the official policy has been to increase the nuclear capacity and to import the nuclear fuels at enormous societal costs. In view of the fact that there are much benign options, NEP should clearly lay down guidelines to move away from this costly/risky path.
  • At a time when the world is clearly moving away from coal power dependency, and when the IPCC has unequivocally asked for massive reduction in the usage of fossil fuels, and when many of the coal power plants in the country are either operating at very low PLF or have become stranded assets, the country has not yet identified a target year to stop the import of coal. This issue needs to be addressed effectively.
  • The public do not get to read about any R&D efforts in India in the areas such as: advanced battery and other energy storage technologies; micro/smart grid and associated technologies; ocean & geothermal energy; Concentrated Solar Power (CSP); small size wind turbines; efficient & convenient solar cookers, etc.. NEP should laydown concrete action plan to effectively invest adequate resources in the associated R&D efforts, and also to consider suitable overseas engagement.
  • One area where India should invest adequately in R&D efforts with overseas engagement is the Ocean Energy technology. With a coastline of about 7,500 kM the potential for the ocean energy to meet a substantial percentage of electricity requirements of the coastal areas is huge. Adequate focus is needed in this regard.
  • Another area, which India seems to have neglected, is the Geo-thermal potential in the country. New Zealand and Iceland, which have vast experience in this sector, should be considered for overseas engagement to gain from their experience.

Air Quality and other environmental concerns

Instead of looking only at air quality as a consequential effect of energy production/usage, there is a need to take an objective look at the various elements of our environment: air, water, agricultural land and forest in general, and the phenomenon of Climate Change in particular.  With DNEP’s projection for the burning of vast quantities of fossil fuel by 2040, it will be impossible to keep air quality at acceptable standards.  Burning of such vast quantities of fossil fuels will have huge deleterious impacts on other elements of the environment too, while lowering the credibility of India’s Climate Change leadership claims/aspirations.

Since the human health is the critical part of human welfare and is intricately linked to a clean environment, and also since energy production/usage is known to impact the environment in various ways, all the associated issues need to be considered in a holistic way.  Hence, the ecological and economic costs to the overall society in the choice of a technology should be the primary consideration instead of the upfront financial costs.  The goal of mitigation and adaptation to Climate Change should be at the focal point in the policy making process on energy.

Issues of social and environmental concerns: Climate Change perspective

The draft NEP may indicate to most readers that it has not given due importance to the social and environmental issues of the future energy pathway.  The fossil fuel sectors have the issues of forest felling and pollution of air, land and water, while the dam based hydro power has the issues of forest drowning, obstruction & pollution of rives, and Methane emission as the major concerns. Nuclear power has very many issues including the radiation contamination due to accident. All these three conventional electricity sources have some common issues of forced displacement of project affected families and reduction in forest cover. Fossil fuels and dam based hydro power also have the GHG emission concerns. Ever increasing capital and operating costs for all of them have made them costlier than RE sources. These issues must be objectively factored in the NEP, because all these concerns will only be exacerbated because of the projected impacts of Climate Change.

Unabated Climate Change Would Reverse the Hard-Earned Development Gains in Asia: ADB

Unabated climate change would bring devastating consequences to countries in Asia and the Pacific, which could severely affect their future growth, reverse current development gains, and degrade quality of life, according to a report produced by the Asian Development Bank (ADB) and the Potsdam Institute for Climate Impact Research (PIK).


NEP should not ignore the grave warnings of such credible reports from around the world on the serious implications to the vulnerable sections of our society, and hence should clearly advocate effective measures to make the national energy scenario a very effective pathway for the true development of our communities, instead of ignoring the social and environmental issues in its eagerness to meet the unlimited demand for energy, as the developing countries have done in the previous century.

Energy needs of rural India – the need to assign appropriate value for human and animal energy

Since the energy needs/demands of our rural areas is minimum and since the rural areas need a lot more focus in our developmental pathways, having been largely neglected since independence, the NEP should  put the rural energy needs on a special pedestal, and put in place all possible measures to meet the same satisfactorily.  When we assign the appropriate economic value to the human and animal energy usage, which is still vogue in vast tracts of rural India, the emergent scenario will become clearly interesting and visible in a different context.  The realisation of such a vast contribution to GDP should enable us to put a reduced emphasis on employment generation potential of conventional/commercial energy sources.  In view of the fact that a well-considered deployment of RE sources will lead to vast employment generation opportunities, the relevance of the conventional energy sources in the context of employment generation potential also should lose its importance.

A Greenpeace India report of 2010 “Taking Charge” has shown ten case studies on the application of small-scale, decentralised renewable energy systems in India in 2010. It says: “Taking Charge is a selection of case studies of small-scale, decentralised renewable energy systems in India in 2010, which captures some of the remarkable human and social elements that have shaped these pioneering projects”.  The strength of these stories lies in their diversity. One is a diversity of the context in which they are based, including the geography of the place, and its social fabric.  Another strength is the diversity of solutions applied. Each of these renewable energy projects has worked because they are tailored to fit the local needs and conditions. Perhaps most interesting is the diversity of energy governance that these stories demonstrate, and the economic models that they have developed.

With regards to energy for cooking in rural and semi-urban areas, it is desirable that biomass (firewood/bio-mass in the form of fuel pellets) shall have significant role, provided that efficient, smokeless chullahs can be supplied to these areas, as this energy resource is available to many people in rural India at no cost or low cost.  There are many shining examples of providing suitable, sustainable and easily accessible RE sources to our rural and semi-urban communities, as in the Greenpeace report in the box item, and each one of them should be effectively expanded to address the energy needs of the majority of our population.

Our rural areas can be put on a path of sustainable and adequate development, if their needs, including the energy needs, are met largely through the locally available resources, and also if we enable them to be in effective control of such resources.  NEP should engage effectively with people/NGOs/institutions working on rural development issues to prepare the credible energy road map for the rural India.

  1. India Vision 2040

The energy scenario for 2040/50 should be the one where effective policy measures and regulatory framework are in place to provide clean, equitable and sustainable energy at realistic cost with the primary focus on to lift the vulnerable sections of our society out of the clutches of the poverty and ill-health.  As can be observed from the experiences from around the world since 2010, there is an undeniable preference for the individuals/communities to have effective control on their energy demand/supply issues.  NEP should take a careful look at this issue from the Indian perspective, and formulate suitable policies/guidelines.

NEP cannot be seen as rational, if it projects enormous increase in the dependence on imports and vastly increased GHG emissions, as late as 25 years later. With an increased dependence on overseas supply, the energy security cannot be better than what it is now. Hence, all possible efforts to minimise our total energy demand without compromising our welfare goals, and to meet such a demand by domestic resources at the lowest overall societal cost should become the primary plank of our energy policy. India is endowed with huge potential in RE sources, and hence the dependence on overseas supply should come down drastically by 2040 instead of increasing.

Energy mix: It is incomprehensible that the overall share of fossil fuels is projected to come down from 81% in 2012 just to 78% in ambitious pathway in 2040; with all the planning and policy interventions will the drop of just 3% share of fossil fuels acceptable, whereas the total energy supply would have registered 2.7 to 3.2 time increase?  This means a vast increase in GHG emissions in absolute terms. What will be our role in combating the global warming threats? With so much of fossil fuel burning will the quality of our air any better than the present quality because of which we already have serious health concerns?  Transportation should be largely dependent on non-fossil fuels, and the focus should be on efficient mass transport options, and EVs.  Bio-fuels should have their rightful place.  Rural energy needs should be met largely by the locally available resources, and all the technological and financial support needed in that regard should be in place by 2040 so as to make the rural India self-sufficient.

Structure of the energy sector by 2040/50: At the global level it is projected that by 2050 more than 60% of the energy consumption is likely to be in the form of electricity because of the ease, absence of pollutants at the point of usage, and the fact that all of the electricity demand can be met through RE sources. Hence, our efforts should be to increase the share of electricity much higher than that projected; say between 50 – 60% by 2040/50.  NEP should consider recommending action plan to indicate such an ambitious but feasible target.

DNEP states: “The coastal south and west India, being close to the oil/gas rich West Asia, will witness a more significant role of LNG, including imported coal based plants.“  Such dependence on imported coal and oil will be against the long term national interests, and against the present policy of the govt. to eliminate coal import. Such projected dependence must be drastically reduced by optimally harnessing the domestic resources of energy.

  1. Summary
  • The initiative of NITI Aayog to prepare the draft NEP has come at a critical juncture in India’s developmental pathway. This is a great opportunity to diligently review our developmental priorities in view of the fact that whereas energy is considered as an important ingredient in HDI index, it also has huge impact on every critical element of our society including that of health, food, environment and the looming threats of Climate Change.  Hence, utmost care and due diligence is required in finalising the national energy policy so as to ensure equitable, healthy and sustainable developmental opportunities for all sections of the society.
  • Various elements of NEP should fully comply in letter & spirit with all the relevant Acts of our Parliament and the associated rules/polices, including the international obligations.
  • Such care and due diligence can be realised only if various stake holder groups are effectively consulted. To enable this NITI Aayog should have consultation meetings with stake holder groups in every state capital, and only then suitably modify the DNEP to correctly reflect the societal strengths and constraints.
  • Being a tropical country with the great tradition of simple living and high thinking, India’s huge population has per capita energy needs at very modest level (may even be termed as very low in global terms); thus necessitating simple, uncomplicated and affordable energy sources to meet the expectations of the diverse but poor communities spread over a large geographical area.
  • The energy needs of such simple living communities can largely be met through distributed type of locally available RE sources and supported by micro/mini grids, which will be most optimal when owned, operated and managed by the local communities. The rural communities only need the initial financial and technical help to get suitable tools and mechanisms to make them self-sufficient.
  • Keeping in proper perspective the social, environmental, economic and inter-generational issues associated with a business as usual scenario, the energy pathways for the future should become environmentally friendly and people centric. Fossil fuels and nuclear energy cannot be a part of our energy policy beyond 2040.
  • Diligent application of ‘costs and benefits analysis’, ‘options analysis’, and ‘life cycle cost analysis’, while taking into account all the direct and indirect costs and benefits to the society, will establish the true usefulness of a given energy resource/technology.
  • NEP should make concrete recommendations to stop spending the colossal amounts (and the scarce natural resources) on fossil fuel and nuclear power technologies, and spend a small percentage of such saved resources to make the RE sources the mainstay of our energy scenario by 2040.
  • Our overseas engagement should be largely focused on making the RE sources widely acceptable to our communities.
  • A diligently prepared final product (NEP), with specific guidelines and time-lines, will greatly benefit our society by making it dynamic and by reviewing it at regular intervals with the effective contributions from stakeholder groups.


Shankar Sharma

Power Policy Analyst, Mysore


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