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					</table>A new staff paper by the Central Electricity Regulatory Commission (<a href="https://cercind.gov.in/" target="_blank" rel="noopener">CERC</a>) has suggested that grid connectivity for renewable energy projects be given only if they have signed power purchase agreements. As another option, it has been recommended that an auction regime be introduced for all connectivity allocations.
These suggestions have been made in the context of 31.8 GW of renewable energy projects that have secured tentative grid connectivity in the absence of power purchase agreements(PPA)  as of June 2025.
When pending applications are included, this number climbs to nearly 45.3 GW, representing a very large block of connectivity that has not yet translated into firm offtake in India’s transition pipeline.
<a href="https://mercomindia.s3.ap-south-1.amazonaws.com/wp-content/uploads/2025/11/Tentative-Connectivity-Granted-Based-on-LoA-but-Without-PPA-as-of-June-2025.png"><img loading="lazy" decoding="async" class="aligncenter wp-image-87208 size-full" src="https://mercomindia.s3.ap-south-1.amazonaws.com/wp-content/uploads/2025/11/Tentative-Connectivity-Granted-Based-on-LoA-but-Without-PPA-as-of-June-2025.png" alt="Tentative Connectivity Granted Based on LoA but Without PPA as of June 2025" width="529" height="305" srcset="https://mercomindia.s3.ap-south-1.amazonaws.com/wp-content/uploads/2025/11/Tentative-Connectivity-Granted-Based-on-LoA-but-Without-PPA-as-of-June-2025.png 529w, https://mercomindia.s3.ap-south-1.amazonaws.com/wp-content/uploads/2025/11/Tentative-Connectivity-Granted-Based-on-LoA-but-Without-PPA-as-of-June-2025-300x173.png 300w" sizes="auto, (max-width: 529px) 100vw, 529px" /></a>
The staff paper suggests removing the letter of award (LoA) basis for eligibility altogether, allowing connectivity only when PPAs are already signed. LoAs alone do not demonstrate project certainty and therefore should not lock transmission resources.
The second is a larger system change under which all connectivity allocation would shift to auctions, replacing the LoA, land, and land plus bank guarantee routes. Such auctions would explicitly attach timelines and financial consequences, turning connectivity into a market mechanism rather than an administrative gate.
Under this model, developers would be required to achieve financial closure at least six months before the auction-linked commercial operation date and to submit land documents by the commercial operation date, with commercial operation date timelines set by the auction award itself.
What is Driving the Move
Under the general network access (GNA) framework, renewable energy generating stations and energy storage projects can obtain interstate transmission system connectivity through three routes. They can use a LoA or a signed PPA issued by a renewable energy implementing agency. They can also apply based on land availability or through a land-plus-bank-guarantee pathway, in which land is submitted later.
Under the land-plus-bank-guarantee route, developers initially submit a bank guarantee tied to capacity, i.e., ₹1 million (~$11,203)/MW up to 1,000 MW, and beyond that a bank guarantee of ₹1 billion (~$11.2 million) plus ₹500,000 (~$5,601)/MW for capacity over and above 1000 MW, with land documents allowed to be submitted later within the prescribed timelines.
The LoA route was meant to speed up early-stage project allocation. However, the staff paper notes that connectivity awarded purely on LoAs is increasingly getting stranded. Many developers hold connectivity for long periods while their PPAs remain unsigned. Since developers generally begin implementing projects only after securing PPAs, the allocated bays and transmission margins remain idle.
This has two system-wide consequences. First, transmission assets planned or already built for these projects remain underutilized, creating avoidable costs. Second, other ready projects are blocked from accessing available connectivity, forcing fresh transmission planning and delaying project timelines.
Stakeholder Suggestions 
Renewable energy implementing agencies (REIA) have urged the regulator to allow developers a liability-free exit if PPAs are not signed within a year of LoA issuance. They also support reallocating relinquished connectivity through auctions, arguing that bidding would identify developers willing to commit to clear timelines and even pay for early access.
They suggest additional reuse pathways for stranded bays, such as allowing the same developer to back existing connectivity with another LoA/PPA from the same or a different implementing agency, or even a third-party offtaker, in cases where at least 50% of the required land is already secured, typically with a two-year commissioning window or up to GNA operationalisation, whichever is later
A joint committee of the Ministry of Power and the Ministry of New and Renewable Energy has suggested a structured window for older LoAs. For LoAs older than 12 months, the committee proposes a three-month period in which developers must either surrender connectivity without penalty or shift to a merchant mode pathway with reset timelines. If no choice is made, connectivity would be cancelled.
Moving to merchant mode would reset the scheduled commercial operation date to two years from the date the developer opts in, and the switch would be one-way, requiring a no-objection certificate from the concerned implementing agency if the developer later migrates to the land or land-plus-bank-guarantee routes. The committee’s rolling three-month window would operate in batches until the legacy LoA stock is exhausted.
The committee also allows limited swaps of LoA-linked connectivity within the same corporate group under specific conditions.
Proposal on LoA-based Connectivity
The staff paper lays out three options for projects that have held LoA-based connectivity for more than 12 months without signing a PPA. Developers must choose within one month of the decision taking effect. If no choice is made within this period, the connectivity will be treated as surrendered.
<ul>
<li>Convert to land route and keep connectivity</li>
</ul>
Developers may exit the LoA route while retaining their allotted connectivity by shifting to the land-based pathway. This is positioned as a continuation option for serious developers whose PPAs were delayed for reasons beyond their control.
To use this option, the developer must apply within one month and submit a no-objection certificate from the concerned implementing agency confirming that the PPA was not signed. The earlier LoA becomes invalid for future connectivity claims.
Existing connectivity bank guarantees remain applicable, and a new performance bank guarantee of ₹1 million (~$11,203)/MW must be submitted. A new scheduled commercial operation date must be set within 18 months of the conversion date.
The developer must submit land documents within 12 months and achieve financial closure within 15 months. Delays on land or financial closure can be condoned only up to three months with milestone extension charges of ₹1,500 (~$17)/MW/day.
Commercial operation delays can be condoned only for up to six months, with milestone extension charges of ₹5,000 (~$56)/MW/day. Missing these deadlines would lead to the revocation of connectivity and encashment of the guarantees. If only part of the connectivity is converted, any remaining capacity not backed by land documents will be revoked in accordance with existing rules.
<ul>
<li>Substitute with another LoA that has a signed PPA</li>
</ul>
This option targets cases where the same developer or corporate group has another LoA that has progressed to a signed PPA, but with a later commissioning schedule. The staff paper proposes a substitution so that a real PPA can back stranded connectivity holding.
The developer may replace the delayed LoA with another LoA that has a signed PPA, provided the firm start date of connectivity under the substituted PPA is at least six months later than the original LoA schedule.
Substitution can be allowed only where the connectivity and access configuration remain technically compatible, including solar or non-solar-hour access and storage-linked access, where relevant. If substitution uses a parent/subsidiary PPA within a corporate group, the original connectivity grantee retains full responsibility for compliance and any penalties.
The staff paper also notes that substitution should not be used to alter the approved access type for charging or drawal from the ISTS, except under the applicable GNA change provisions.
Financial closure must be achieved at least six months before the scheduled date under the substituted PPA or its firm start date, whichever is later. Failure to meet this requirement would trigger the revocation of connectivity and the encashment of the connectivity fee.
Where the substituted PPA capacity is smaller than the connectivity held, any excess bays or automatic transfer switch that cannot be backed down must be surrendered or shifted to the land-conversion route, and bank guarantees tied to any unawarded bays/ automatic transfer switch are to be treated under the staff’s surrender/return rules.
If the connectivity capacity exceeds the substituted PPA capacity, the excess must be surrendered or shifted via the conversion route.
This pathway is designed to avoid wasting connectivity where a developer has a genuine offtake elsewhere but faces timing mismatches across tenders.
<ul>
<li>Surrender and auction the capacity</li>
</ul>
Developers may surrender stranded LoA-based connectivity within one month. In such cases, the Central Transmission Utility of India (CTUIL) would encash the first connectivity bank guarantee but return the second and third guarantees.
The surrendered capacity would be auctioned and allocated to new developers. The staff paper proposes CTUIL as the nodal agency, while auctions would be run through established bidding platforms used by implementing agencies or other approved entities.
The base auction price is set at ₹300,000 (~$3,361)/MW, reflecting the typical guarantee exposure for such connectivity. Bids would be called as a premium over this base price, and the highest premium would win.
Two timeline categories are proposed. If the relevant substation is already commissioned or expected to be commissioned within 12 months, the winning project must achieve commercial operation within 12 months. If substation commissioning is more than 12 months away, the project must be commissioned within 24 months or upon substation readiness, whichever is later.
The minimum bid size is 50 MW. An earnest money deposit equal to 5% of the base price bank guarantee would be required, and a performance guarantee equal to 10% of the base price bank guarantee would be required for winners.
A bid processing fee of ₹500,000 (~$5,601) plus taxes applies, winners must deposit the bid amount within three days of being declared successful, and the connectivity agreement must be signed within one month of the award.
Winning bidders must also submit required technical connection data and meet land and financial-closure milestones. If a winning bidder fails to sign the connectivity agreement within the deadline or does not furnish the performance guarantee on time, the earnest money deposit is encashed, the award is cancelled, and the capacity is reallocated through a fresh auction.
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 LoAs for all renewable energy projects for which PPAs and PSAs are not feasible by November 30, 2025.
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CERC Favors Grid Connectivity Only to Renewable Energy Projects with PPAs

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					</table>Punjab State Electricity Regulatory Commission (<a href="https://pserc.gov.in/" target="_blank" rel="noopener">PSERC</a>) has rejected a solar power company’s plea seeking compensation to offset the financial and commercial impact of increasing central goods and services taxes (CGST) on solar cells.
Background
Petitioner SAEL Solar Solutions had entered into a power purchase agreement (PPA) with Punjab State Power Corporation (PSPCL) on June 21, 2022, to supply 50 MW of power at a tariff of ₹2.65 (~$0.031) per unit.
It filed a petition to get compensation on account of a ‘change in law’ because of an increase in CGST for solar cells from 5% to 12%.
Per the PPA, a ‘change in law’ is deemed to have occurred when any event increases or decreases project costs. The change in law notice must be sent within 60 days from the date of occurrence.
The petitioner also submitted that it was entitled to carrying costs because of rising capital expenditure, which increased debt and equity requirements.
PSPCL argued for SAEL’s plea to be dismissed. The petitioner issued the ‘change in law’ notice in November 2022, after 60 days from signing the PPA.
Commission’s Analysis
The Commission observed that the central tax rate change, which was issued in September 2021, before the e-reverse auction process of the bidding conducted on October 22, 2021, cannot be considered a ‘change in law’ under the PPA.
It noted that the petitioner’s notice to PSPCL did not fulfill the 60 days from the ‘change in law’ event” time limit even from the PPA date.
Additionally, it did not contain details of the ‘change in law’ and its effect on project costs. The notice also did not include supporting documentary evidence.
The Commission dismissed the petitioner’s request for a grant of carrying cost and interest on it.
In September 2024, PSERC <a href="https://www.mercomindia.com/punjab-sets-separate-additional-surcharges-for-full-and-partial-open-access" target="_blank" rel="noopener">issued</a> separate additional surcharge rates for full and partial open access power consumers. It approved a surcharge of ₹1.29 (~$0.015)/kWh for both full and partial open access consumers, including those utilizing green energy, for using open access beyond the contract demand maintained with the distribution licensee.
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Punjab Commission Dismisses Solar Company’s Compensation Plea

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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 updated the Approved List of Models and Manufacturers (ALMM) for solar photovoltaic modules, adding 3,015 MW of new capacity.
The cumulative module manufacturing capacity stands at 67,401 MW.
New entries to the list included <a href="https://bvgindia.com/" target="_blank" rel="noopener">BVG India</a> adding 367 MW, <a href="https://www.klkindia.com/" target="_blank" rel="noopener">KLK Ventures</a> adding 33 MW, and <a href="https://www.sanenergy.in/" target="_blank" rel="noopener">SAN Energy and Solution</a> adding 27 MW to the total added capacity.
<a href="https://cms.mercomindia.com/ireda-to-raise-%e2%82%b950-billion-through-qip-for-green-energy-growth/" target="_blank" rel="noopener">Rayzon Solar</a>, <a href="https://sovasolar.com/" target="_blank" rel="noopener">Sova Solar</a>, <a href="https://www.sparksolar.in/" target="_blank" rel="noopener">Spark Solar Technologies</a>, <a href="https://swelectes.com/shpv/" target="_blank" rel="noopener">Swelect HHV Solar</a>, and <a href="https://www.vikramsolar.com/" target="_blank" rel="noopener">Vikram Solar</a> increased their capacity by 1,369 MW, 765 MW, 82 MW, 76 MW, and 296 MW, respectively.
<a href="https://emmvee.com/" target="_blank" rel="noopener">Emmvee Energy</a>, <a href="https://www.raajventures.com/" target="_blank" rel="noopener">Rajratna Ventures</a>, <a href="https://www.orbenergy.com/" target="_blank" rel="noopener">ORB Energy</a>, <a href="https://www.renewsysworld.com/" target="_blank" rel="noopener">Renewsys India</a>, and <a href="https://www.renew.com/" target="_blank" rel="noopener">ReNew</a> were included in the provisional ALMM list with an applied capacity of 6,495 MW.
The ALMM increased to 90 module manufacturers after these additions.
MNRE had <a href="https://www.mercomindia.com/solar-module-capacity-under-almm-mw" target="_blank" rel="noopener">updated</a> the ALMM earlier this month. These updates included an addition to the provisional ALMM featuring Insolar Limited with a capacity of 1,525 MW and Visaka Industries (ATUM Division) with a capacity of 16 MW. Waaree Energies and Mundra Solar Energy, part of the Adani Group, were also incorporated into the ALMM, adding an applied capacity of 11,610 MW per year.
In December 2024, MNRE <a href="https://www.mercomindia.com/solar-module-capacity-under-almm-expands-to-62765-mw" target="_blank" rel="noopener">expanded</a> the ALMM by adding 2,271 MW of solar module capacity. Bluebird Solar, Novasys Greenergy, ReNew Photovoltaics, and Saatvik Green Energy are the companies that added capacities.
The ministry also <a href="https://www.mercomindia.com/list-ii-for-solar-cells-into-force-from-june-2026" target="_blank" rel="noopener">introduced</a> List-II for solar cells ALMM. It will be effective from June 1, 2026. The inclusion of solar cells in ALMM addresses the growing domestic production capacity. Projects mandated to use ALMM-enlisted modules (List-I) must ensure these modules are manufactured using cells from List-II. Exceptions are provided for projects with bid submission deadlines preceding the issuance of this order, exempting them from the List-II requirement, irrespective of their commissioning date.
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MNRE Adds 3 GW of Solar Module Capacity to ALMM

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					</table>The Central Electricity Regulatory Commission (<a href="https://www.cercind.gov.in/" target="_blank" rel="noopener">CERC</a>) relaxed rules, allowing ACME Solar (<a href="https://www.acme.in/" target="_blank" rel="noopener">ACME</a>) to switch the connectivity of its 300 MW solar power project to the land route, considering their substantial progress and commitment to the project.
The Commission also noted that failure to achieve financial closure or compliance with the order would revoke connectivity if the 10% equity release is not attained.
Background
ACME Solar Holdings (ASHPL) and ACME Sikar Solar (ASSPL) submitted a petition under Section 79 of the Electricity Act, 2003. Central Transmission Utility of India (CTUIL) was the respondent in the case.
The petitioners made the following requests:
<ul>
<li>They sought permission to utilize the connectivity granted by CTUIL for their other project by exercising authority under regulations 41 and 42 of the GNA Regulations 2022.</li>
<li>They also request an interim injunction against CTUIL from revoking the connectivity granted to them on May 10, 2022, based on the letter of award issued by Maharashtra State Electricity Distribution Company (<a href="https://www.cercind.gov.in/" target="_blank" rel="noopener">MSEDCL</a>) on December 14, 2021, throughout the ongoing petition.</li>
</ul>
On May 6, 2021, MSEDCL initiated a tender for procuring power from solar power projects through competitive bidding.
On July 30, 2021, ACME Solar applied to CTUIL for Stage I Connectivity for its 300 MW project in Bikaner, Rajasthan, to 400/220 kV Bikaner 2 of CTUIL/PGCIL as per the CERC connectivity Regulations 2009.
On September 10, 2021, CTUIL granted Stage I connectivity to ACME Solar for its 300 MW project at Bikaner II pooling station.
On December 14, 2021, ACME Solar received a letter of award from MSEDCL for a 300 MW capacity project with a tariff of ₹2.42 (~$0.029)/kWh for 25 years from the commercial operation date (CoD).
ASHPL established a special purpose vehicle (SPV), ASSPL, to set up the project and sign a power purchase agreement (PPA) with MSEDCL.
On February 1, 2022, ASHPL applied to CTUIL for Stage II Connectivity for its 300 MW project in Bikaner, Rajasthan, with a proposed connectivity start date of September 30, 2023.
On March 11, 2022, the Maharashtra Electricity Regulatory Commission (MERC) approved the procurement of 500 MW of power by MSEDCL and adopted a tariff of ₹2.42 (~$0.029)/kWh through competitive bidding.
On March 21, 2022, ASHPL requested MSETCL to issue a No Objection Certificate (NOC) for its 300 MW project to enable ASHPL to seek long-term access (LTA) from CTUIL.
On March 28, 2022, ASHPL applied to CTUIL for LTA for its 300 MW project with a proposed LTA start date of September 30, 2023.
On April 28, 2022, during the &#8220;6th Consultation Meeting for Evolving Transmission Schemes in Northern Region,&#8221; CTUIL considered the proposal for granting LTA of 300 MW to ASHPL with a start date of September 30, 2023, noting that NOC from STU (MSETCL) had not been granted.
On May 10, 2022, CTUIL granted Stage II connectivity to ASHPL for 300 MW capacity from Bikaner II, with a proposed start date of September 30, 2023.
On May 26, 2022, a transmission agreement for connectivity was signed between CTUIL and ASHPL.
On June 15, 2022, CTUIL granted LTA to ASHPL for the project, subject to the condition that if the NOC from STU is not available or effective by the LTA start date (March 31, 2024), transmission charges would be billed to ASHPL until NOC is available and effective.
On June 27, 2022, the LTA agreement was signed between CTUIL and ASHPL.
On July 4, 2022, ASHPL wrote to MSETCL regarding additional documents for NOC submission for finalizing the LTA application in CTUIL for its 300 MW Project.
On July 12, 2022, MSETCL issued a conditional NOC for LTA for ASHPL&#8217;s 300 MW project due to ongoing network strengthening projects.
On July 12, 2022, CTUIL issued an amendment to the Stage II connectivity, specifying the ISTS substation and bay.
On August 2, 2022, MSETCL reiterated the unavailability of unconditional NOC due to ongoing network strengthening projects.
On August 10, 2022, ASSPL issued a Force Majeure Notice to MSEDCL due to uncertainty in power evacuation caused by MSETCL&#8217;s conditional NOC.
On August 12, 2022, MSETCL reiterated the unavailability of unconditional NOC due to ongoing network strengthening projects.
On August 31, 2022, CTUIL revised the connectivity start date to November 25, 2023, and on December 26, 2022, CTUIL amended the LTA start date to May 15, 2024.
The 180-day period from the Force Majeure notice lapsed on January 29, 2023, leading ASHPL to terminate the PPA with MSEDCL.
On February 21, 2023, ASHPL issued a termination notice to MSEDCL but received no response.
On May 3, 2023, ASHPL submitted a format transition undertaking to CTUIL for LTA conversion under the GNA regulations 2022.
The petitioners said the inability to utilize the existing connectivity dated May 10, 2022, is due to Force Majeure events beyond the Petitioners&#8217; control and for reasons not attributable to them.
Allowing CTUIL to revoke the connectivity granted to ASHPL would penalize the petitioners for events beyond their control and for reasons not attributable to them. Regulation 24.6(c) stipulates that connectivity granted to a renewable energy generating station will be revoked if the LoA or PPA, based on which connectivity was granted, is terminated before the COD of the Project.
Given the unique circumstances of the present case, the petitioners prayed that the Commission should exercise its power to relax (Regulation 41) and power to remove difficulties (Regulation 42) under the GNA Regulations 2022 and allow the utilization of connectivity granted under the LoA route on May 10, 2022, to the petitioners for the development of other projects.
Commission Analysis
The Commission notes that the issue is whether the petitioner is entitled to retain the connectivity granted at the Bikaner II Substation. The petitioner asserts their commitment to utilizing the connectivity, citing significant progress such as land acquisition, financial closure approval, and EPC contracts.
However, CTUIL contends that the petitioner&#8217;s requests fall outside the current regulatory framework, highlighting the absence of provisions for transferring connectivity between projects under different routes.
The petitioner was initially granted connectivity for a 300 MW project at the Bikaner II Substation based on a LoA issued by MSEDCL, which has since been terminated.
While regulations allow for conversion of connectivity from the land route to the LoA/PPA route, there are no provisions for converting connectivity granted under the LoA/PPA route to any other route.
Regulation 24.2 of the GNA Regulations states that connectivity granted based on the LoA or PPA shall be revoked if the LoA or PPA is terminated.
Considering MERC&#8217;s Order permitting the termination of the PPA due to a Force Majeure event, the termination of the PPA is not the petitioner&#8217;s fault. Additionally, the petitioner has made progress in project implementation.
The petitioner has made significant progress in implementing the project, including land acquisition and equipment procurement, with a target commissioning date of September 1, 2024.
While regulations don&#8217;t allow for conversion of connectivity from the LoA route to another, the petitioner&#8217;s earnest efforts and progress warrant consideration.
In light of this, the Commission exercised its power under Regulations 41 and 42 of the GNA Regulations to relax provisions and allow conversion to the Land route, subject to the following conditions:
<ol>
<li>Within four weeks, the petitioner must submit land documents for full 300 MW connectivity. Failure will result in connectivity revocation.</li>
<li>The project must be commissioned within six months from this order, considering elapsed time and progress. Financial closure and 10% equity release must be achieved within three months; failure results in connectivity revocation.</li>
<li>Relaxed timelines don&#8217;t affect liabilities under the sharing regulation 2020; project implementation must adhere to specified timeframes.</li>
<li>Treatment of submitted Bank Guarantees follows GNA Regulations.</li>
</ol>
Recently, CERC <a href="https://www.cercind.gov.in/" target="_blank" rel="noopener">issued</a> draft regulations to determine fees and charges to be collected by regional load despatch centers (RLDCs) from generating companies, distribution companies (DISCOMs), bulk consumers, inter-state transmission licensees, buyers, sellers, and inter-state trading licensees, settlement nodal agency, and any other users.
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