CERC proposes Fourth Amendment to GNA Regulations

The Connectivity and General Network Access (GNA) Regulations govern access to the ISTS and form the backbone of India’s electricity transmission framework. Given the rapid growth of renewable energy projects, battery storage systems and hybrid generation assets, CERC has proposed a number of amendments to address practical challenges encountered by developers in obtaining, maintaining and utilising ISTS connectivity.

1. Withdrawal of Connectivity in case of Material Delay: One of the most significant proposed changes is the developer’s ability to withdraw connectivity requests where there is a substantial delay between the expected and actual grant of connectivity. Under the Amendment, where the period between the “likely start date of connectivity” given in the in-principle grant and the start date specified in the final grant of connectivity is two years or more, the applicant may withdraw the entire connectivity quantum. They can obtain a refund of all connectivity bank guarantees and land bank guarantees, provided the request is made within 30 days of receipt of the final connectivity grant. This becomes particularly relevant for renewable energy developers whose project economics, financing arrangements and contracted timelines may be affected by transmission delays.

2. Energy Storage Systems and Non-Solar Hour Access: The Amendment introduces several changes specifically targeting ESS. Most notably:

• • ESS projects are required to maintain a minimum discharge capability equivalent to twice the connectivity quantum (in MWh);

• • ESS developers may install renewable energy generating stations exclusively for charging the storage facility without having to separately satisfy certain land and financial closure requirements applicable to such charging facilities; and

• • a reduced connectivity-related bank guarantee requirement of INR 5 lakh/MW has been proposed for ESS projects (other than pumped storage projects).

These Amendments indicate an increasing regulatory focus on storage infrastructure agrid flexibility. Further, the Amendment proposes a new framework permitting generating stations, renewable energy generating stations and ESS projects to seek non-solar hour access instead of full-day access in specific circumstances. Until now, regulatory provisions primarily contemplated solar-hour-based access arrangements. The proposed change seeks to accommodate projects that are designed to supply power during evening or non-solar periods, including storage-backed renewable energy projects.

3. Multi-Location Renewable Energy Projects: The Amendment also seeks to address challenges faced by developers implementing renewable energy projects across multiple locations under a single Letter of Award (LoA) or Power Purchase Agreement (PPA). Under the proposed framework:

• • connectivity may be sought across one or more locations based on a common LoA or PPA;

• • developers may combine LoA/PPA-backed capacity and land-backed capacity within a single connectivity application; and

• • additional flexibility has been introduced for allocation of connectivity quantum across various project locations.

These changes are likely to benefit large renewable energy developers implementing geographically dispersed solar, wind and hybrid projects. Furthermore, the Amendment seeks to rationalize compliance requirements under the connectivity regime. It clarifies that technical compliance capacity required at the point of injection will not be counted towards installed capacity for connectivity purposes. Further, certain land and bank guarantee requirements may not apply where additional capacity is merely intended to satisfy technical requirements, and revised timelines have been proposed for land documentation and financial closure submission after the effectiveness of GNA.

4. Transferability of GNA: The Amendment introduces a new mechanism permitting the transfer of GNA where the underlying load connected to the transmission or distribution system is sold to another entity. In such circumstances, the existing GNA may be transferred to the new owner of the load, subject to clearance of outstanding dues and fulfilment of regulatory conditions.

They also provide relief to connectivity grantees by accelerating the release of certain connectivity bank guarantees. Instead of releasing guarantees in five equal instalments over a five-year period, the Amendment proposes that the relevant connectivity bank guarantees be returned within one week after completion of one year from the declaration of commercial operation of the corresponding generating capacity.