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					</table>The Ministry of New and Renewable Energy (<a href="https://mnre.gov.in/" target="_blank" rel="noopener">MNRE</a>) has asked state power transmission utilities to publish details of spare transmission capacity at regular intervals in the public domain.
Publishing the spare transmission capacity available at the states&#8217; 400 kV/220 kV/132 kV substations will improve transparency and ease of doing business. It will also enable renewable energy developers to plan their projects effectively.
In a letter to the chiefs of the transmission utilities of the states, MNRE drew attention to the Central Transmission Utility of India&#8217;s (CTUIL) regular publication of spare transmission capacity available for granting connectivity to renewable energy projects at interstate transmission system substations.
MNRE also pointed out that the Rajasthan state transmission utility had recently <a href="https://www.mercomindia.com/rajasthan-may-have-13-gw-of-spare-grid-capacity-for-renewables-in-fy-2026" target="_blank" rel="noopener">published</a> the latest status of spare transmission capacity available within the state. “This initiative has enhanced visibility for RE developers and facilitated the timely assessment of investment opportunities,” the letter said.
According to the details published, Rajasthan has an estimated spare transmission capacity of up to 13 GW in the financial year (FY) 2026 for future renewable energy projects. The state will have up to 1.4 GW of spare transmission capacity in FY 2027 and up to 3.9 GW of capacity in FY 2028. The available transmission capacity will drop to 1.9 GW by FY 2029.
Transmission capacity constraints have adversely impacted renewable energy projects, especially in solar-rich Rajasthan and Gujarat. According to Grid-India’s ‘Operational Feedback on Transmission Constraints (April-June 2025)’ report, a delay of over 18 months in commissioning a transmission system strengthening program <a href="https://www.mercomindia.com/transmission-system-delay-stalls-evacuation-of-8-1-gw-renewables-in-rajasthan" target="_blank" rel="noopener">created</a> bottlenecks for evacuating 8.1 GW of power from a renewable energy zone in Rajasthan. The Phase II (Parts E, G, and G1) transmission system strengthening project was scheduled for completion in November 2023, but remains uncommissioned.
From March to September 2025, nearly 4 GW of wind-solar energy was <a href="https://www.mercomindia.com/cerc-admits-solar-developers-plea-for-compensation-due-to-power-curtailment" target="_blank" rel="noopener">curtailed</a> in Rajasthan due to delays in transmission projects.
In October, the Central Electricity Regulatory Commission <a href="https://www.mercomindia.com/cerc-admits-solar-developers-plea-for-compensation-due-to-power-curtailment" target="_blank" rel="noopener">admitted</a> petitions from solar developers seeking compensation for power generation losses and financial losses resulting from power curtailment due to inadequate transmission systems. They sought directions to the Power Grid Corporation of India and CTUIL to compensate them until the operationalization of the associated transmission system.

MNRE Asks States to Publish Available Spare Power Transmission Capacity

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					</table>The Central Transmission Utility of India (<a href="https://ctuil.in/" target="_blank" rel="noopener">CTUIL</a>) has released a draft procedure for renewable energy developers seeking to change the declared energy source of their projects after receiving connectivity to the interstate transmission system (ISTS).
The draft procedure follows the provisions of the CERC Connectivity and GNA Regulations, 2022. It applies to solar, wind, hybrid, and storage projects seeking to modify their source composition without altering the connectivity quantum.
Stakeholders can submit their comments by December 27, 2025.
Scope 
The procedure covers projects that already possess ISTS connectivity and now wish to shift from solar to wind, convert to a hybrid configuration, or add or remove storage.
Such changes are permitted only when the total megawatt capacity remains unchanged.
Only projects that are not yet commissioned or injecting power are eligible to apply.
Key Conditions 
Developers may request a change of source only once per connectivity grant. The request cannot be for the increase in approved connectivity or to extend the start date.
Applications must be submitted within 18 months of in-principle connectivity approval or 18 months before the firm&#8217;s start date for connectivity, whichever is later.
CTUIL has also aligned the timelines with the one-time relaxation <a href="https://www.mercomindia.com/cerc-issues-key-relaxations-to-ease-implementation-of-gna-regulations" target="_blank" rel="noopener">issued</a> by CERC on December 8, 2025.
Requests must be filed through the National Single Window System portal using the format CONN SC. Until the portal is updated, applications will be accepted and timestamped at midnight on the date of submission.
For projects with solar-hour-based access, a source change can be approved only if the non-solar-hour access has not already been allocated to another entity. When both a source change request and a new connectivity application for non-solar hours are received at the same location, priority will be based on their timestamps.
Developers cannot seek approval for configurations that require more land than what has already been submitted. The only exception is when the power purchase agreement or letter of award mandates the new source. No application fee is charged for source change proposals.
Obligations After Approval
Once CTU approves a source change, the developer must submit updated technical connection data at least one year before the scheduled commissioning of the reconfigured project. Failure to do so can lead to the revocation of connectivity for that capacity.
A revised connectivity agreement reflecting the new configuration must be signed within 30 days of approval.
Rejection
Requests can be rejected if the revised configuration requires more capacity than is available at the relevant substations or in the transmission network. Proposals can also be turned down if system studies indicate technical infeasibility.
CTU is required to record and communicate reasons for rejection in each case.
Required Documents 
Applicants must provide a cover letter explaining the need for a source change, a board resolution, updated project and land details, revised financial closure information, and updated technical parameters. A declaration confirming that connectivity capacity remains unchanged and that CEA standards will be met is also mandatory.
Recently, CTUIL <a href="https://www.mercomindia.com/ctuil-issues-draft-norms-for-change-in-control-of-grid-connectivity" target="_blank" rel="noopener">issued</a> a draft procedure for seeking approval of changes in control of grid connectivity grantees before the commercial operational date of renewable energy projects.
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CTUIL Issues Draft Rules for Changing Renewable Energy Source for ISTS Projects

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					</table>The Central Transmission Utility of India (<a href="https://ctuil.in/" target="_blank" rel="noopener">CTUIL</a>) has revoked grid connectivity of 24 grantees with a total renewable energy capacity of 6,343 MW since 2022.
Minister of State for New and Renewable Energy Shripad Yesso Naik told Parliament that CTUIL had clarified that the cancellations were not due to a shortfall in transmission planning to meet the 2030 non-fossil capacity target, but because of developer delays.
India has <a href="https://www.mercomindia.com/india-become-carbon-neutral-2070" target="_blank" rel="noopener">set</a> a target of installing 500 GW of non-fossil energy capacity by 2030.<a href="https://mercomindia.s3.ap-south-1.amazonaws.com/wp-content/uploads/2025/12/Picture1-3.png"><img loading="lazy" decoding="async" class="aligncenter wp-image-87659 size-full" src="https://mercomindia.s3.ap-south-1.amazonaws.com/wp-content/uploads/2025/12/Picture1-3.png" alt="State-wise Details of Renewable Energy Connectivity Revoked by CTUIL Since 2022" width="903" height="406" srcset="https://mercomindia.s3.ap-south-1.amazonaws.com/wp-content/uploads/2025/12/Picture1-3.png 903w, https://mercomindia.s3.ap-south-1.amazonaws.com/wp-content/uploads/2025/12/Picture1-3-300x135.png 300w, https://mercomindia.s3.ap-south-1.amazonaws.com/wp-content/uploads/2025/12/Picture1-3-768x345.png 768w, https://mercomindia.s3.ap-south-1.amazonaws.com/wp-content/uploads/2025/12/Picture1-3-650x292.png 650w, https://mercomindia.s3.ap-south-1.amazonaws.com/wp-content/uploads/2025/12/Picture1-3-624x281.png 624w, https://mercomindia.s3.ap-south-1.amazonaws.com/wp-content/uploads/2025/12/Picture1-3-600x270.png 600w" sizes="auto, (max-width: 903px) 100vw, 903px" /></a>
According to CTUIL, the Central Electricity Regulatory Commission (CERC) has 16 petitions by power generators seeking protection against the revocation of connectivity.
Earlier this month, CERC <a href="https://www.mercomindia.com/cerc-backs-grid-connectivity-revocation-for-inoxs-300-mw-wind-projects" target="_blank" rel="noopener">upheld</a> CTUIL’s decision to cancel transmission connectivity for Inox Green Energy Services’ 300 MW wind projects at Bhuj II pooling substation in Gujarat. The Commission directed Inox Green to reapply for connectivity with CTUIL, since it had failed to demonstrate any progress in land acquisition or financial closure for the projects.
CTUIL stated that 259 GW of non-fossil capacity is already connected to the grid.
It added that the interstate transmission system for evacuating 172 GW of renewable energy is under construction, with bids for 19 GW already in process.
The government is working with states to develop intrastate transmission systems in time to evacuate 152 GW of renewable energy.
Recently, CTUIL <a href="https://www.mercomindia.com/ctuil-issues-draft-norms-for-change-in-control-of-grid-connectivity" target="_blank" rel="noopener">issued</a> a draft procedure for seeking approval of changes in control of grid connectivity grantees before the commercial operational date of renewable energy projects.
In another bid to reduce the stalling of projects due to connectivity issues, the Grid Controller of India in October <a href="https://www.mercomindia.com/grid-india-proposes-transmission-margin-for-full-t-gna-capacity-utilization" target="_blank" rel="noopener">proposed</a> to mandate an adequate margin in the transmission system to enable the scheduling of power projects up to their full temporary-General Network Access capacity.
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CTUIL has Revoked Grid Connectivity for 6.3 GW of Delayed Renewable Projects

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					</table>The Central Transmission Utility of India (<a href="https://ctuil.in/" target="_blank" rel="noopener">CTUIL</a>) has issued the draft procedure for seeking approval of the change in control of grid connectivity grantees before the commercial operational date of renewable energy projects.
Stakeholders must send their feedback on the draft procedure before December 17, 2025.
A connectivity grantee is the entity that has received the final grant of connectivity and has signed the connectivity agreement with CTUIL.
The procedure applies to all renewable energy generation stations (excluding hydro generating stations) or energy storage systems (excluding pumped storage projects). It also applies to new and existing grantees who have not commissioned projects for the full connectivity granted to them.
Entities that have been issued a final grant of connectivity and signed a connection agreement will be eligible to seek a change in control of connectivity.
If the change in control of the connectivity is made without prior approval, or if the application is made after the change has been effected, it will lead to the revocation of connectivity and the encashment of the bank guarantee.
To receive approval for a change in control of connectivity, the transferee entity must submit a formal undertaking confirming it will assume all regulatory obligations currently resting with the original connectivity grantee.
Additionally, the transferor and the transferee must certify that the proposed change in control does not amount to trading or ‘benami’ (anonymous) transfer of connectivity rights.
The transferor must submit the proposed change in control structure, as well as the identities and credentials of the new entities that will assume control.
The transferor and the transferee must have no outstanding defaults or violations under the general network access (GNA) regulations.
CTUIL will only consider a change in control of the connectivity grantee if the connectivity grantee is admitted to insolvency or liquidation proceedings, or due to governmental or statutory transfers, or to step-in rights of the lender arising from the connectivity grantee&#8217;s default.
It may also consider applications for change-in-control if a connectivity grantee is a consortium/joint venture and there is a change in the consortium/joint venture&#8217;s shareholding.
Applications arising from the exit of a foreign company from India and a change in a company&#8217;s shareholding can also be considered by CTUIL.
The applications must be submitted at least 90 days before the proposed change.
The applicants will be responsible for the authenticity, accuracy, and completeness of all information submitted to CTUIL.
They will indemnify, defend, and hold harmless the CTUIL and its officers against all losses, liabilities, damages, penalties, costs, and expenses arising directly or indirectly from this transfer of connectivity.
If the change in control of connectivity is granted based on false, misleading, or incomplete disclosure, CTUIL will revoke the approval and cancel the connectivity granted to the applicant. It will encash the bank guarantee furnished under the GNA regulations and initiate appropriate action, including blacklisting and reporting the matter to the Central Electricity Regulatory Commission.
In another bid to reduce stalling of projects due to connectivity issues, the Grid Controller of India in October <a href="https://www.mercomindia.com/grid-india-proposes-transmission-margin-for-full-t-gna-capacity-utilization" target="_blank" rel="noopener">proposed</a> to mandate an adequate margin in the transmission system to enable the scheduling of power projects up to their full T-GNA capacity.
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CTUIL Issues Draft Norms for Change in Control of Grid Connectivity

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					</table>The Central Electricity Regulatory Commission (<a href="https://cercind.gov.in/" target="_blank" rel="noopener">CERC</a>) has upheld Central Transmission Utility of India’s (CTUIL) decision to cancel transmission connectivity for <a href="https://www.inoxgreen.com/" target="_blank" rel="noopener">Inox Green Energy Services</a>’ 300 MW wind projects at Bhuj II pooling substation in Gujarat.
The Commission directed the petitioner, Inox Green, to reapply for connectivity with CTUIL, since it had failed to demonstrate any progress in land acquisition or financial closure for the projects.
Background
In 2018, received a letter of award from Solar Energy Corporation of India (SECI) to set up 200 MW and 100 MW wind projects in Kutch, Gujarat, under Tranche III and Tranche IV auctions.
It formed six special-purpose vehicles (SPVs) for 300 MW and signed power purchase agreements with SECI.
Inox said that due to various factors beyond its control, the projects were delayed. SECI acknowledged the factors behind the delay by granting multiple extensions.
Inox said it has made considerable investments in executing the wind projects, including developing a 220 kV transmission line and substations, purchasing a 150 MVA transformer, and acquiring land for pooling substations.
SECI had extended the time for obtaining financial closure because the Gujarat government had delayed allotting land for the projects.
In 2020, in view of the delay in operationalizing the long-term access, SECI extended the time for financial closure and the scheduled commercial operation date (SCOD) from November 2019 to April 2020.
Further, SECI extended the SCOD by another 30 days due to the COVID-19 lockdown. In December 2020, SECI extended the SCOD until October 2021.
When SECI refused to grant further extensions, Inox approached the dispute resolution committee (DRC), which refused to grant any relief.
In 2022, CTUIL issued transmission connectivity under long-term access to the petitioner for its projects.
In 2024, the Power Ministry approved the installation of the dedicated overhead transmission line, including the transmission system.
Further, CTUIL sent a notice to Inox for the payment of one-time general network access (GNA) charges of ₹100,000 (~$1,119)/MW. It also issued an invoice for payment of bilateral charges of ₹80 million (~$895,280) against the transmission facility developed for the projects.
Inox said that CTUIL’s interconnecting common evacuation infrastructure was originally scheduled to be commissioned in 2019 but was rescheduled to 2022. The delay led lenders to refuse to fund the projects due to uncertainty over connectivity. It said that the delay in granting connectivity also increased the cost of wind turbine generators.
After multiple follow-ups with Inox, CTUIL invoked the bank guarantee, and the petitioner paid ₹30 million (~$335,730) toward one-time GNA charges.
In 2025, CTUIL also revoked the project’s connectivity and withdrew the GNA granted to the petitioner.
SECI said that, since the projects were not commissioned even six months after the SCOD, i.e., February 2023, the developer was liable to pay liquidated damages.
SECI recovered the liquidated damages by encashing the performance bank guarantee submitted by Inox. However, SECI did not cancel the PPAs.
SECI added that if the petitioner commits to completing the wind projects and the utilities purchase power in accordance with the tariffs set out in the PPAs, it will enter into a tripartite agreement and consider a mutual settlement proposal.
The petitioner approached the Commission to issue an appropriate direction to the respondents to refrain from revoking the 300 MW Stage II connectivity and long-term access. Alternatively, it pleaded with the Commission to allow it to retain the 300 MW of connectivity granted through the land bank guarantee route.
It also sought directions to CTUIL to reserve the 300 MW connectivity at the 220 kV Bhuj pool and not allot it to any other entity.
The petitioner also asked the Commission to prevent any coercive action against it for failing to commission the 300 MW of projects and to prevent the imposition of any penalties.
Commission’s Analysis
The Commission said the petitioner failed to submit documents proving that the projects were completed within the extended scheduled date and that financial closure had been reached.
The Commission noted that the DRC examined the projects&#8217; progress and found that the petitioner failed to justify the delay in their execution. It said that Inox’s inability to complete land acquisition or achieve financial closure on the projects demonstrated a lack of seriousness..
The petitioner was unable to submit details of land acquisition for the projects, and the DCR found no merit in its plea for a further extension of the SCOD,
The Commission said that Inox delayed approaching the Commission by three months, even after the DRC issued an unfavorable report.
The Commission noted that the petitioner has been holding onto the connectivity for six years. CTUIL should have revoked the connectivity when it failed to commission the projects by 2023.
Upholding CTUIL’s decision to revoke the connectivity, the Commission ordered Inox to apply afresh for connectivity with CTUIL.
Recently, the government <a href="https://www.mercomindia.com/government-to-cancel-reia-awarded-projects-without-ppa-psa-prospects" target="_blank" rel="noopener">directed</a> renewable energy implementing agencies to close all legacy bids and cancel the letters of award for all renewable energy projects for which PPA and power sale agreements are not feasible by November 30, 2025.
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CERC Backs Grid Connectivity Revocation for Inox’s 300 MW Wind Projects

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					</table>The Central Electricity Regulatory Commission (<a href="https://cercind.gov.in/" target="_blank" rel="noopener">CERC</a>) has permitted special purpose vehicles (SPVs) or subsidiaries of renewable energy companies to submit land and financial closure documents in place of their parent companies for the grant of connectivity and general network access.
The decision will be effective until the third amendment to the Connectivity and General Network Access (GNA) to ISTS Regulations, 2022, is formally notified.
Background
The petitions were filed by Oyster Renewable Energy (<a href="https://www.oysterrenewable.com/" target="_blank" rel="noopener">OREPL</a>) and Avaada Energy (<a href="https://avaada.com/" target="_blank" rel="noopener">AEPL</a>), along with their SPVs, Oyster Green Hybrid One (OGHOPL) and Avaada MPSustainable2 (AMSPL), respectively, for approval of their land documents.
The Central Transmission Utility of India (<a href="https://www.ctuil.in/" target="_blank" rel="noopener">CTUIL</a>) granted final connectivity to both parent companies in April 2024. However, when the SPVs submitted land documents between March and April 2025, CTUIL rejected them because Regulation 11A required such documents to be in the name of the parent company.
OREPL, which is implementing a hybrid renewable project in Agar, Madhya Pradesh, through its SPV (OGHOPL), submitted that it had already invested ₹7.8 billion (~$90.48 million) in the project, acquired 70% to 97% of the land, and completed up to 31% of the erection work.
Similarly, AEPL, which won a Solar Energy Corporation of India tender, applied for 50 MW connectivity and submitted all project documents through its SPV, AMSPL.
CTUIL maintained that it was bound by the current regulations but expressed no objection to acting on specific or generic directions from the Commission.
Commission’s Analysis
CERC noted that it had used its relaxation powers to allow similar SPV submissions in previous orders. It found that there was no regulatory or commercial risk in allowing land and financial closure documents from SPVs if they are wholly owned subsidiaries of the connectivity grantee.
Recognizing that the draft third amendment to the GNA Regulations already proposes such flexibility, the Commission relaxed Regulations 11A (1) and 11A (2), permitting SPVs to submit the required documents.
The Commission also mandated CTUIL to return the land bank guarantees within seven days of receiving the documents. However, connectivity bank guarantees will be released only after the commercial operation date.
CTUIL was directed to verify the legal status of SPVs and process all submissions accordingly.
Recently, CERC <a href="https://www.mercomindia.com/cerc-approves-tariffs-for-ntpcs-1170-mw-wind-solar-hybrid-projects" target="_blank" rel="noopener">approved</a> tariffs ranging from ₹3.28 (~$0.038) to ₹3.29 (~$0.038)/kWh for NTPC’s 1,170 MW of wind-solar hybrid power projects.
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CERC Allows Project SPVs to Submit Land Documents for ISTS Connectivity

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					</table>The Central Transmission Utility of India (<a href="https://ctuil.in/" target="_blank" rel="noopener">CTUIL</a>) has proposed that a minimum of 3 acre/100 MWh will be considered the benchmark for establishing a battery energy storage system (BESS) project.
Land documents corresponding to a minimum of 1.5 acre/MWh, considering 50% of the land requirement, must be submitted along with applications for connectivity to the interstate transmission system (ISTS) network on the land route for BESS projects.
Currently, there is no minimum criterion for land for BESS capacity. However, a benchmark for the land requirement for BESS is required to process ISTS connectivity applications received on the land route under the standalone ESS category.
Per clause 4.1 of the Central Electricity Regulatory Commission’s “Connectivity and GNA” regulations, 2022, solar, wind, hybrid, and standalone BESS are eligible to connect to the ISTS network under the land route.
In August 2023, the Central Electricity Authority, CTUIL, and industry stakeholders decided that the land requirement for solar and wind developers would be 3 acre/MW and 0.25 acre/MW, respectively.
To finalize the land requirement for standalone BESS projects, information on the land requirement was sought by CTUIL from BESS developers who had applied on the National Single Window System portal under the category “Renewable energy generating stations (REGS) with ESS.”
The land requirement will vary based on factors such as layout (land for battery container, power conversion system, and transformer), current technology, capacity, safety regulations, infrastructure needs, and future expansion. Based on these factors, CTUIL arrived at the average 3 acre/100 MWh figure.
CTUIL has invited feedback from stakeholders on the proposed land requirement for BESS projects.
It has also sought suggestions and comments on the timelines for the financial closure of REGS, other than hydroelectric and pumped hydro storage projects, for the in-principle grant of ISTS connectivity. It has been proposed that the financial closure of these projects should be achieved six months before the projects’ scheduled date of commercial operation or start of connectivity under the General Network Access Regulations.
With the growing share of variable solar and wind power in the energy mix, BESS projects are seen as <a href="https://www.mercomindia.com/battery-energy-storage-key-to-indias-renewable-energy-future" target="_blank" rel="noopener">bridging</a> the gap between generation and consumption while maintaining grid balance.
The government <a href="https://www.mercomindia.com/government-enhances-bess-capacity-target" target="_blank" rel="noopener">enhanced</a> BESS&#8217;s viability gap funding (VGF) program from 4,000 MWh of storage capacity to 13,200 MWh by 2028. The VGF is capped at ₹2.7 million (~$32,114)/MWh or 30% of the capital cost, whichever is lower.

CTUIL Proposes 3 Acre/100 MWh as Land Requirement for BESS Projects

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					</table>The Central Electricity Regulatory Commission (<a href="https://cercind.gov.in/" target="_blank" rel="noopener">CERC</a>) recently issued an order clarifying issues raised by the Central Transmission Utility of India (<a href="https://www.ctuil.in/" target="_blank" rel="noopener">CTUIL</a>) and renewable developers under the GNA Regulations.
CTUIL, in its submission, highlighted the difficulties of implementing GNA Regulations and requested clarification on a few aspects.
Some of the key issues raised by CTUIL are as follows:
Issue 1: Processing under Grant of Connectivity, Long-term Access, and Medium-term Open Access in Interstate Transmission and Related Matters Regulations, 2009 post-April 5, 2023.
CTUIL argued that scheduling and billing processes have not yet commenced as per the Grid Code and CERC (Sharing of intr-State transmission charges and losses) Regulations of 2020. Therefore, CTUIL has taken steps to address tasks such as finalizing allocation, fulfilling the Section-68 requirement for the dedicated line, and activating Long-term Access (LTA) after April 5, 2023. These measures are being implemented under the 2009 Connectivity Regulations to ensure a seamless process for granting, operationalizing, and scheduling cases without disruptions.
Commission’s response
The Commission noted that as of April 5, 2023, power scheduling was still governed by the Indian Electricity Grid Code Regulations of 2010 for Long-Term Access (LTA), Medium Term Open Access (MTOA), and Short-Term Open Access (STOA). The Indian Electricity Grid Code Regulations of 2023, pertaining to scheduling under GNA, will be effective from October 1, 2023. This means that there exists a period from April 5, 2023, to September 30, 2023, during which entities seeking power scheduling may rely on the effectiveness of LTA, MTOA, or STOA.
Considering that the 2009 Connectivity Regulations will be repealed from October 1, 2023, the Commission permitted CTUIL to carry out the necessary activities under the 2009 Connectivity Regulations. These activities are crucial for ensuring a smooth transition during the interim perio Following the implementation of the Grid Code 2023 and the initial modification to the Sharing Regulations 2020, all actions must adhere strictly to the GNA Regulations.
Issue No.2: Retention of bank guarantee submitted under the 2009 Connectivity Regulations vs. submission of Conn-BGs (connectivity bank guarantee) under GNA Regulations.
CTUIL submitted that where two different bank guarantee amounts are required to be maintained under the 2009 Connectivity Regulations and the GNA Regulations, the higher of the bank guarantee amounts is being kept with CTUIL until the scheduling, billing, and relinquishment start as per the GNA Regulations.
Commission’s response
The Commission observed that the 2009 Connectivity Regulations will be repealed from October 1, 2023. For the transition period from April 5, 2023, to October 1, 2023, the Commission clarified that the higher bank guarantee under the 2009 Connectivity Regulations or the GNA Regulations would be considered by CTUIL for compliance. From October 1, 2023, bank guarantees will be modified in accordance with the GNA Regulations.
Issue 3: Conn-BG1 for cases covered under GNA Regulations.
CTUIL stated that entities falling under Regulation 37.3(3) are obligated to provide a Conn-BG1 with a value of ₹5 million (~$60,162) and a Conn-BG3 at ₹200,000 (~$2,406)/MW when there has been no prior provision of a construction bank guarantee for LTA. However, if such an entity has already submitted a Conn-BG1 for connectivity under 2009 regulations, there would be a situation where two Conn-BG1s are in place if another Conn-BG1 is also acquired under Regulation 37.3(3) of the GNA Regulations. CTU has received numerous representations requesting an exemption from the requirement to submit a new Conn-BG1 under the GNA Regulations in cases where a Conn-BG1 has already been submitted under the 2009 Connectivity Regulations.
Commission’s response
The Commission observed that construction bank guarantees provided under the 2009 Connectivity Regulations must be transformed into Conn-BG1 and Conn-BG2 per the GNA Regulations. In cases where an entity has not submitted any construction bank guarantee to CTUIL under the 2009 Connectivity Regulations, they will be obligated to provide a Conn-BG1 valued at ₹5 million (~$60,162) and a Conn-BG3 at ₹200,000 (~$2,406)/MW.
However, situations may arise where an entity has already submitted a Conn-BG1 worth ₹5 million (~$60,162) but has not furnished any construction bank guarantee under the 2009 Connectivity Regulations. In such instances, providing an additional Conn-BG1 under the GNA Regulations will not be required.
Issue 4: Conn-BG requirement for generating stations connected to the intrastate transmission system, which are not covered under Regulation 4.1 of the GNA Regulations.
CTUIL submitted that generating stations connected to the intrastate transmission system, whose LTA was granted on a target basis and became effective as of April 5, 2023, may be required to submit Conn-BG3 for ₹200,000 (~$2,406)/MW for the generating stations connected to the interstate transmission system.
Commission’s response
CERC observed that entities falling under Regulation 17.1(vi) of the GNA Regulations, for whom the LTA to the target region was already effective at the time of transition, will also be treated per the stipulations outlined in Regulation 37.6(2) of the GNA Regulations.
Issue 5: Advancement of the terminal bay for start-up power or injection of infirm power.
CTUIL said that Regulation 10.8 of the GNA Regulations provides that elements of the Automatic Transmission System (ATS) can be identified for early commissioning for the requirement of start-up power/injection of infirm power. A bay at the ISTS end may also be required besides ATS. Accordingly, the same needs to be incorporated into the regulations.
Commission’s response
The Commission emphasized that an entity might require certain components of the ATS before the agreed-upon start date of connectivity as specified in the connectivity agreement agreed that to initiate start-up power withdrawal or infirm power injection, an entity can request the commercial operation date of the terminal bay to be before the agreed-upon connectivity start date specified in the connectivity agreement.
Issue 6: Bifurcation of GNA as ‘within the region’ and ‘from outside the region’ under the application of GNA by entities covered under Regulation 17.1 (iii) of the GNA Regulations.
CTUIL suggested that GNA is to be applied in the case of entities, indicating bifurcation ‘within the region’ and ‘from outside the region’ as per Regulation 20.1. However, entities applying GNA for drawal of Round-the-Clock power have expressed difficulty in indicating the within and outside region GNA at the application stage due to scheduling of renewable power from different sources located in different regions during various points in time. Hence, GNA can be utilized solely for planning purposes for entities both ‘within the region’ and ‘from outside the region.’
Commission’s response
The Commission clarified that a drawee Designated Interstate Customer (DIC) can request a schedule from anywhere in India up to its GNA quantum, where such injection point may be ‘within the region’ or ‘from outside the region.’ Once such an entity has placed a scheduling request with the Regional Load Despatch Center (RLDC) and there is a constraint in the transmission system due to which a full schedule, as requested by all drawee DICs in the region cannot be accommodated, RLDC should allocate the transmission corridor as follows:
<ul>
<li>In case of constraint in the transmission system ‘from outside the region,’ the transmission corridor will be allocated proportionately to the ‘outside the region’ bifurcation of all such drawee DICs.</li>
<li>In case of constraint in the transmission system ‘within the region,’ the transmission corridor will be allocated proportionately to the total GNA quantum for such drawee DICs.</li>
</ul>
Issue 7: Bifurcation of GNA as ‘within the region’ and ‘from outside the region’ for states.
CTUIL suggested that while bifurcating the GNA deemed for each state, if the proportionate GNA ‘from outside the region is less than outside LTA/MTOA contracts, then the GNA ‘outside the region’ may be made equal to outside LTA/MTOA contracts.
Commission’s response
The Commission accepted CTUIL&#8217;s proposal. Additionally, any required modifications will be executed within the deemed GNA capacity within the region to ensure that the overall balance remains intact.
Issue 8: Timeline for processing new applications until October 1, 2023.
CTUIL submitted that the transition process needs to be completed before the fresh applications under GNA Regulations are processed due to their higher priority as per their original date of application. Accordingly, relaxation for processing new applications beyond the timelines specified in the GNA Regulations for an initial four months must be provided.
Commission’s response
The Commission noted that the transition of current applicants with connectivity, LTA, and MTOA to comply with the GNA Regulations involves multiple steps. To ensure the seamless implementation of the GNA Regulations, new applications can be handled once the transition cases are resolved. Recognizing that this transition process may span three to four months, the Commission extended the time for processing new applications received between April 5, 2023, and October 1, 2023. Beyond October 2023, these applications will be processed according to the timelines specified in the GNA regulations.
Issue No. 9: Connectivity by entities under Regulation 4.1 of the GNA Regulations, which are renewable energy generating stations or renewable power park developers.
Commission’s response
The Commission noted that, given the nature of power purchase agreements (PPAs), which are to be executed between the procurer and the selected bidder, it is appropriate to regard the PPA signed by the procurer as a valid document per regulation 5.8(xi) of the GNA Regulations. The Commission instructed its staff to initiate the process of amending the regulations to enable a more considered view of projects falling under such guidelines. Until this modification is finalized, a renewable energy generation facility will be eligible to request connectivity by submitting the PPA or opting for either of the other options involving land or bank guarantees.
Issue 10: Change in location by entities covered under Regulation 4.1 of the GNA Regulations, which are renewable energy generating stations or renewable power park developers.
CTUIL submitted that the provision for submission of registered title deeds or land documents was introduced in the GNA Regulations vide the First Amendment. Currently, the regulatory prescription is for submitting 50% of the land required for the project capacity for which connectivity is sought. Under the regulations, the remainder of the land required for the project is not required to be submitted to CTU at any stage post-grant of connectivity.
Commission’s response
The Commission recognized that, on occasion, adjustments to the designated land location for which connectivity has been approved may be necessary due to various factors. These factors could include alterations in the coordinates of the substation, proximity to the ISTS substation, a higher capacity utilization factor at different land locations, and unforeseen practical challenges in securing the complete land parcel near the initial land location. It said modifying the land parcel&#8217;s location while keeping the point of connectivity with the ISTS and the connectivity start date unchanged would be permissible and would not result in the cancellation of connectivity.
Issue 11: Change in requirement of Conn-BG3 in view of the order dated September 5, 2023.
CTUIL submitted that generation projects that have completed five years from commissioning, their respective Conn-BG requirements shall become NIL per the said CERC order dated September 5, 2023.
Commission’s response
The Commission stated that the contention of CTUIL generation projects that have completed five years from commissioning, their respective Conn-BG requirements, should become nil is incorrect. The entities must submit Conn-BGs as per the GNA Regulations.
Recently, CERC <a href="https://www.mercomindia.com/pending-provisions-gna-regulations-effect-october-1-2023" target="_blank" rel="noopener">notified</a> that certain provisions of the GNA Regulations and the First Amendment to the GNA Regulations 2022 will come into effect from October 1, 2023.
Subscribe to Mercom’s real-time <a href="https://mercomindia.com/product/mercoms-renewable-energy-regulatory-updates/" target="_blank" rel="noopener">Regulatory Updates</a> to ensure you don’t miss any critical updates from the renewable industry.

CERC Resolves Difficulties in Implementing GNA Regulations

The Central Electricity Regulatory Commission (<a href="https://cercind.gov.in/" target="_blank" rel="noopener">CERC</a>) recently approved the execution of the proposed transmission system for the evacuation of 8 GW of power from solar energy zones and wind energy zones in the southern region.
CERC directed the Central Transmission Utility of India Limited (<a href="https://powermin.gov.in/en/content/central-transmission-utilityctu" target="_blank" rel="noopener">CTU</a>) to ensure that the transmission system matches the progress of generation projects. The transmission charges and treatment of the mismatch between the commercial operation date of the generating stations and the transmission system should be governed by the CERC Regulations, 2020.
The central regulator said that if the generating projects are not commissioned and the transmission system is commissioned, the CTU may seek appropriate remedies such as grants and subsidies from the Government of India or the state governments until the associated generating projects achieve the commercial operation date.
CTU must submit a quarterly progress report regarding the execution of the transmission program to the Union Ministry of Power and the Central Electricity Authority (<a href="https://cea.nic.in/?lang=en" target="_blank" rel="noopener">CEA</a>).
The Power Grid Corporation of India Limited (<a href="https://www.powergrid.in/" target="_blank" rel="noopener">PGCIL</a>) had filed a petition to execute transmission infrastructure for 18.5 GW of solar and wind energy zones in the southern region. After filing the petition, CTU became a separate entity carved out of PGCIL.
Background
In 2018, the Ministry of New and Renewable Energy constituted a sub-committee to identify interstate transmission system (ISTS) connectivity for renewable energy projects from the potential solar energy zones and wind energy zones of about 50 GW and 16.5 GW, respectively.
Out of 66.5 GW potential, 18.5 GW was envisaged to be developed in the southern region, including 10 GW of solar generation and 8.5 GW of wind generation.
The Tamil Nadu Generation and Distribution Corporation (TANGEDCO), in its submission, said that the gestation period for the development of generation projects was relatively shorter as compared to the transmission systems.
The Power System Operation Corporation (POSOCO) stated that as more than 70% of solar dispatch was considered in the southern region, solar generation dispatch in other regions should also be around this value. However, lesser solar generation (around 4,435 MW) was considered in the northern region. In contrast, the northern region&#8217;s total installed solar generation capacity was expected to be around 35 GW by 2021-22.
The Solar Energy Corporation of India (<a href="https://www.seci.co.in/" target="_blank" rel="noopener">SECI</a>), in its submission, stated that it had so far awarded renewable projects for a total capacity of 25.04 GW, of which 14.24 GW was of solar and 10.8 GW was for wind/hybrid.
The nodal agency added that the transmission infrastructure development needed to be started much ahead of the generation projects as the gestation period of renewable projects was much shorter than the development of transmission facilities.
POSOCO said that it was evident from CTU&#8217;s affidavit that 10.5 GW out of the proposed 18.5 GW was put on hold due to non-receipt of long-term access (LTA) applications.
Commission&#8217;s analysis
The Commission observed that CTU had proposed the transmission system for 10.5 GW of solar and wind energy zones in the southern region &#8211; Koppal (2.5 GW), Karur (2.5 GW), Gadag Part-A (2.5 GW), Gadag Part-B (2.5 GW), and Tuticorin-II (500 MW).
It noted that SECI had supported the petitioner&#8217;s proposal. On the other hand, TANGEDCO, the Karnataka Power Transmission Corporation, and the Tamil Nadu Transmission Corporation (TANTRANSCO) opposed the proposal and suggested several modifications before implementing the transmission program.
The central regulator noted that CTU had submitted that it was seeking approval to undertake the execution of a transmission system for only 8 GW in the solar and wind energy zones in the southern region, namely, Koppal (2.5 GW), Karur (2.5 GW), Gadag (2.5 GW) and Tuticorin-II (500 MW).
It observed that the scaling down of the transmission system from 18.5 GW to 8 GW raised a serious question on the entire transmission planning and approval process. There was a gross lack of due diligence by statutory planning agencies such as CTU and intermediary agencies like SECI and the competent authority that approved the program for 18 GW.
The regulator, however, approved the execution of the proposed transmission system for 8 GW of power from the southern region&#8217;s solar and wind energy zones.
In May last year, CERC had <a href="https://mercomindia.com/cerc-approves-construction-transmission-systems/" target="_blank" rel="noopener">passed</a> an order granting regulatory approval to PGCIL for setting up transmission systems under the second phase of its transmission program for solar energy zones in Rajasthan.
Subscribe to Mercom&#8217;s real-time <a href="https://mercomindia.com/product/mercoms-renewable-energy-regulatory-updates/" target="_blank" rel="noopener">Regulatory Updates </a>to ensure you don&#8217;t miss any critical updates from the renewable industry.

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