In the matter of Removal of Difficulties in giving effect to certain provisions of CERC (Connectivity and General Network Access to the ISTS) Regulations, 2022 – EQ

Summary:

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# **1. Background**

The Central Electricity Regulatory Commission (CERC) considered multiple representations from Renewable Energy Developers (RE Developers) and industry associations regarding operational challenges arising from the newly introduced framework of *Solar Hour Access* and *Non-Solar Hour Access* under the Third Amendment to the GNA Regulations.

The Commission examined issues raised and issued a series of clarifications, relaxations, and directions to CTUIL under its powers to remove difficulties (Regulation 42) and to issue practice directions (Regulation 44).

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# **2. Issue 1 – Extension of timelines for conversion to Solar Hour Access**

Regulation 5.11(b) required RE generators (solar-based) and RPPDs to convert to *solar-hour access entities* within **3 months + 1 week** from the amendment’s effective date (09.09.2025), with an ROFR application window of 3 months.

Industry requested extension citing:

* Need for internal decision-making time
* Large CAPEX commitments
* Pending market visibility (PPAs, tenders)
* Land bank guarantees
* Site-level due diligence
* Supply chain constraints (particularly BESS)
* Pending CTUIL/NLDC procedures

### **CERC Decision**

✔ **One-time extension of 75 days (2.5 months)**
✔ ROFR + conversion window extended to **5.5 months (from 09.09.2025)**
✔ Similar extension given for RPPD SCOD declaration under Regulation 37.10(g).

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# **3. Issue 2 – Additional Inverter/Equipment Capacity for Reactive Compliance**

Developers highlighted that extra inverters/WTGs (beyond connectivity quantum) are installed *only* to satisfy:

* reactive power compliance at POI
* internal losses (DTL)
These do not increase active power injection.

CTUIL, however, was treating this as “installed capacity” and was insisting applications under Regulation 5.2.

### **CERC Decision**

✔ **Relaxation of Regulation 5.1 for REGS only**
✔ Additional inverters/WTGs installed solely for technical compliance **will NOT be treated as additional generation capacity**.
✔ No additional Conn-BGs required.
✔ CTUIL must verify such capacity at CONN-4 stage and ensure active injection does not exceed connectivity quantum.

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# **4. Issue 3 – ESS Drawal During Interim Period**

ESS applicants under Regulation 5.2 were receiving final connectivity intimations with drawal quantum marked “NIL”, due to pending CTUIL drawal studies.
RLDCs consequently disallowed charging from the grid via T-GNA.

### **CERC Decision**

✔ ESS and REGS+ESS may **draw charging power under T-GNA**, limited to existing margins, until CTUIL completes drawal study.
✔ CTUIL must complete drawal studies **within four months** from the order.
✔ Post study, drawal must be as per final GNA drawal quantum.

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# **5. Issue 4 – Change of Land Parcels (Regulation 5.8)**

Earlier, developers could change land parcels multiple times. Third Amendment restricted this to **only one change**.

Developers requested allowance for one post-amendment change since earlier changes occurred when no restriction existed.

### **CERC Decision**

✔ Changes made prior to 09.09.2025 **will not count**.
✔ Every entity is allowed **one fresh land parcel change after the Third Amendment’s effectiveness**.

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# **6. Issue 5 – RPPD Eligibility for Non-Solar Hour Access (ROFR cases)**

Developers sought clarity on RPPD rights to apply for non-solar hour access, especially under ROFR.

### **CERC Decision**

✔ RPPDs (solar source or hybrid with solar) are:

* eligible to apply for non-solar hour access **only under ROFR provisions**, i.e., under Regulation 5.11(b),
* **not eligible** to apply independently under Regulation 5.11(a) (fresh NSH access).
✔ Clause (4) of Annexure IV (ROFR applications for in-process connectivity cases) gets same extended timeline: **5.5 months**.

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# **7. Issue 6 – Energy Source Change (Transition Cases)**

Before the Third Amendment, source change (e.g., wind ↔ solar) had:

* no deadline
* no cap on number of changes

After the amendment, Regulation 9.3 restricts:

* one source change only
* must be within 18 months of in-principle grant or 18 months before firm start date

Developers with pending applications were stuck due to new constraints.

### **CERC Decision**

✔ Entities granted in-principle connectivity **before 09.09.2025** get **one fresh opportunity** to change source after the amendment,
✔ **even if**:

* they changed source earlier, or
* 18-month window expired.

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