Gati Vidhi – December 2025

Supreme Court holds that balanced, expert-led conservation is key to protecting the Great Indian Bustard

The Supreme Court of India, vide its judgment dated 19.12.2025 in MK Ranjitsinh & Ors. vs. Union of India & Ors., Writ Petition (Civil) No. 838 of 2019, concerning the protection of the Great Indian Bustard (“GIB”), has held that conservation of critically endangered species must be pursued through scientifically informed, expert-driven measures, while simultaneously balancing sustainable development and renewable energy expansion.

After reconsidering its earlier directions on blanket undergrounding of power lines, and upon examining the reports of an Expert Committee, the Supreme Court issued directions governing habitat protection, power transmission infrastructure, and renewable energy activities.

Directions and observations of the Supreme Court in this judgment:

• The Supreme Court accepted the Expert Committee’s revised delineation of priority areas, fixing the GIB priority area at 14,013 sq. km in Rajasthan and 740 sq. km in Gujarat.
• The Court upheld the principle that blanket undergrounding of all power lines is neither feasible nor scientifically justified, and instead endorsed a targeted, area-specific mitigation approach.
• The recommendations of the Expert Committee relating to in-situ and ex-situ conservation, grassland restoration, habitat consolidation, and community participation were directed to be implemented forthwith.
• The Court approved the creation of dedicated powerline corridors in sensitive regions to minimise habitat fragmentation and cumulative ecological impact.
• It was directed that 80 km of identified 33 kV power lines in Rajasthan be undergrounded immediately, and that other critical 33 kV lines be mitigated as per expert recommendations.
• Specific 66 kV and above transmission lines in the revised priority areas were directed to be rerouted through powerline corridors in a time-bound manner.
• All approved mitigation measures, including undergrounding and rerouting, were directed to be completed within a period of two years.
• The Court accepted that no mitigation is required for existing and future 11 kV and below lines within 100 metres of settlement boundaries and permitted mitigation elsewhere through insulated or horizontally configured cables, rather than mandatory undergrounding.
• The Supreme Court declined to mandate universal installation of Bird Flight Diverters (BFDs), noting their unproven efficacy for GIBs in the Indian context, and directed that further scientific studies and pilot projects be undertaken before any final decision.
• Within the revised priority areas, the Court prohibited new wind turbines, new solar parks or plants above 2 MW, and expansion of existing solar parks, while allowing limited relaxation for small, community-level renewable projects.
• The Court declined to impose a blanket judicial ban on mining activities, observing that mining is already regulated under existing environmental and mineral laws, and that authorities must remain mindful of the ecological sensitivity of GIB habitats.
• The Court emphasised the importance of long-term monitoring, continued climate change impact studies, and strengthening institutional capacity through bodies such as the Eco Task Force.
• A significant observation was made that Corporate Social Responsibility has evolved into Corporate Environmental Responsibility, and that industries must internalise environmental and species-protection costs as part of sustainable development.
• The Inspector General, Wildlife Division, Ministry of Environment, Forest and Climate Change, was designated as the key authority for oversight and implementation of the Court-approved measures.

Supreme Court holds that power supplied after synchronisation is firm power entitled to full tariff

The Supreme Court of India, vide its judgment dated 16.12.2025, in, Tamil Nadu Generation and Distribution Corporation Ltd. v. M/s Penna Electricity Ltd. Civil Appeal No. 5700 of 2014, held that electricity supplied continuously from a generating unit after synchronisation with the grid constitutes “firm power” and is therefore entitled to both fixed and variable charges, even if the Power Purchase Agreement specifies a later commercial operation date (“COD”). Dismissing the appeal filed by TANGEDCO, the Court affirmed the concurrent findings of the Tamil Nadu Electricity Regulatory Commission (“TNERC”) and the Appellate Tribunal for Electricity (“APTEL”).

The dispute concerned power supplied by Penna Electricity Ltd. from its gas turbine unit between 29.10.2005 and 30.06.2006, a period prior to the COD of 01.07.2006 stipulated in the PPA. TANGEDCO contended that such supply was “infirm power” attracting only fuel cost. Rejecting this argument, the Court held that under the applicable tariff regulations, COD can be determined unit-wise, and “infirm power” refers only to electricity generated prior to the commercial operation of the unit, not the entire project. Once the gas turbine unit was synchronised and began supplying power continuously and reliably on 29.10.2005, the supply qualified as firm power. The Court further held that PPAs must conform to the Electricity Act, 2003 and tariff regulations, and cannot override statutory provisions. It criticised the parties for failing to obtain mandatory regulatory approval of the amended PPA under Section 86(1)(b), observing that the 2004 amendment amounted to a substantially new agreement requiring such approval.

The Supreme Court also rejected TANGEDCO’s reliance on correspondence suggesting acceptance of infirm power tariff, holding that estoppel or waiver cannot defeat statutory entitlements of continuous supply. Reaffirming that tariff fixation is a matter of regulatory determination and not private negotiation, the Court held Penna Electricity Ltd. entitled to fixed charges for 153 million units supplied during the disputed period. While noting that ₹50 crore had already been paid pursuant to interim orders, the Court directed that any remaining balance be paid within 12 weeks.

MoC has invited comments / suggestions to the proposed amendment of the Mines and Minerals (Development and Regulation) Act, 1957

MoC has, vide its notice dated 12.12.2025, proposed to amend the Mines and Minerals (Development and Regulation) Act, 1957(“Act”). The said Act was last amended in August 2025.

In view of the statutory, policy and procedural reforms needed in the Coal Mining Sector in India, the MoC has proposed to bring necessary amendments in the said Act.

The salient features of the proposed amendment are as follows:

1. The definition of mining operations has been proposed to be amended to include conversion of coal / lignite.
2. Review of maximum area provided for prospecting license and mining lease under Section 6 of the Act to accommodate modern mining needs, promote strategic investments and enable adoption of future-ready technologies.
3. Maximum period for which a mining lease may be granted shall be increased from 30 years to 50 years and based upon the life of mine, there will be no requirement to obtain renewal of such mining leases. However, the mining leases which have already been granted may be renewed as per the existing provisions.
4. Removal of 50% ceiling as provided under Section 8 (5) of the Act in case of coal and lignite to enable disposal of legacy stock of minerals that cannot be used captively.
5. Undertaking a comprehensive review of the existing legal, administrative and technological framework to consider the revision of powers of the officers of the coal companies and security officers in the realm of illegal mining, transportation, trade or storage of illegally raised coal, to curb such activities more effectively.

The MoC has invited comments / suggestions on the proposed amendment within 30 days from the date of publication of this notice.

A copy of the notice dated 12.12.2025 can be viewed here.

MoC has invited comments / suggestions to the revised Draft Coal Exchange Rules, 2025

The Ministry of Coal (“MoC”) has, vide its notice dated 19.12.2025, issued the revised Draft Coal Exchange Rules, 2025 (“revised Draft Rules”). Reforms are being carried out in the coal sector with focus on promoting competitive markets for sale of coal in light of the increased availability of domestic coal. Thus, the MoC has proposed to establish Coal Exchange(s) under the relevant provisions of the Mines and Minerals (Development and Regulation) Amendment Act, 2025. Accordingly, the MoC has issued the revised Draft Rules.

The salient features of the revised Draft Rules are as follows:

1. Applicable to Coal Exchange, market participants other than Coal Exchange and delivery-based Contracts as approved by the Authority i.e. the Coal Controller Organisation from time to time.
2. The Coal Exchange shall be established and operated with an objective to design coal supply contracts and facilitate transactions of such contracts, ensure fair, transparent, neutral, efficient and robust price discovery and dissemination and ensure efficient and timely supply of coal.
3. The applicant for establishing a Coal Exchange shall be a company limited by shares or deemed to be incorporated under the provisions of the Companies Act, 2013 and shall have a net worth of minimum Rs. 100 crores at all times.
4. Provides a detailed procedure regarding the processing of applications and provides for approval or rejection of the application within 90 days from the date of application.
5. Ceiling on the shareholding pattern for the equity shareholders of the Coal Exchange which is 5% in case of individual members and 49% in case of all members.
6. The Coal Exchange shall function according to the by-laws and business rules approved by the Authority from time to time.
7. Provides for provisions regarding risk management of Coal Exchange, information dissemination and transaction reporting by Coal Exchange, etc.

The stakeholders can send their comments / suggestions on the revised Draft Rules within 30 days of publication of this notice.

A copy of the revised Draft Rules can be viewed here.

PNGRB rolls out a new unified tariff structure for natural gas transportation with effect from 01.01.2026

The Petroleum and Natural Gas Regulatory Board (“PNGRB”) has, vide Press Release dated 16.12.2025, notified a new unified tariff structure for natural gas transportation, aimed at boosting the adoption of cleaner fuels across India. The revised framework will come into effect from 01.01.2026 and is expected to significantly lower transportation costs for Compressed Natural Gas (“CNG”) and Piped Natural Gas (“PNG”) consumers.

Under the new regime, PNGRB has rationalized the existing tariff structure by reducing the number of tariff zones from three to two, up to 300 km and beyond 300 km. PNGRB has notified transportation tariffs of Rs. 54.00/MMBTU (up to 300 km) and Rs. 102.86/MMBTU (beyond 300 km). However, CNG and Domestic PNG consumers nationwide will be charged the Zone-1 tariff of Rs. 54.00/MMBTU, resulting in nearly 50% lower transportation charges for consumers located beyond 300 km.

The revised tariff regime is expected to reduce City Gas Distribution (CGD) sector transportation costs by approximately Rs. 1000 crore annually. This cost rationalisation is likely to translate into lower delivered prices, with CNG becoming cheaper by Rs. 1.25 – Rs. 2.50 per kg and Domestic PNG by Rs 0.90 – Rs. 1.80 per SCM, directly benefiting consumers.

The Press Release dated 16.12.2025 can be accessed here.

MERC allows Petition seeking benefit of rooftop net-metering during periods of availing open access under the MERC (Distribution Open Access) Regulations, 2016

In M/s Sou Sushila D. Ghodawat Charitable Trust (SSDGCT) v. MSEDCL, Case No. 219/2024, vide order dated 01.12.2025, the Maharashtra Electricity Regulatory Commission (“MERC”) has held that the regulatory framework under the second amendment to the MERC (Distribution Open Access) Regulations, 2016 now allows simultaneous net-metering and open access transactions.

In this case, SSDGCT is connected to MSEDCL’s distribution network with total contract demand of 1050 KVA and has availed partial open access since January 2024 for sourcing power from 1.25 MW wind turbine generator. In the year 2020, it commissioned a rooftop Renewable Energy (RE) generating system at its premises of capacity of 748.80 kWp (560 KW AC). SSDGCT filed a Petition before MERC alleging that MSEDCL denied the facility of net metering to it despite the same being extended under the MERC (Distribution Open Access) (Second Amendment) Regulations, 2023 (“DOA Second Amendment Regulations”). MSEDCL delayed issuing the circular for the implementation of the DOA Second Amendment Regulations.

MERC clarified that pursuant to the DOA Second Amendment Regulations, the earlier requirement of gross metering adjustment of rooftop solar generation during open access period stands deleted and the regulatory framework now allows simultaneous net-metering and open access transactions. MERC held that the consumer was entitled to net-metering benefits for rooftop solar generation notwithstanding procurement of power through open access. MERC further held that statutory benefits cannot be denied on account of such procedural lapses or delays and failure to timely implement the amendment could not prejudice the consumers’ rights to avail benefits under it.

MERC has directed reconciliation of excess billing and grant of credit adjustments with interest, reinforcing regulatory certainty for consumers opting for rooftop solar generation alongside open access procurement.

The order dated 01.12.2025 can be accessed here.

TGERC invites objections / suggestions / comments on the Petition filed by TGGENCO seeking approval for true-up of generation tariff for FY 2024 – 25 and determination of annual tariff for FY 2026 – 27

TGERC has, vide public notice dated 20.12.2025, invited objections / suggestions / comments to the Petition filed by TGGENCO seeking approval for true-up of generation tariff for FY 2024 – 25 and determination of annual tariff for FY 2026 – 27. The Petition has been filed in accordance with the Electricity Act, 2003 and the applicable Tariff Regulations, and covers reconciliation of approved and actual fixed charges, including O&M expenses, depreciation, interest, return on equity, and other cost components for TGGENCO’s generation business.

The objections / suggestions / comments along with supporting material must be submitted on or before 10.01.2026. The public hearing is scheduled on 22.01.2026.

The public notice can be accessed here.

TGERC invites objections / suggestions / comments on the Petition filed by SCCL seeking approval for true-up of tariff for FY 2024 – 25 and determination of annual tariff for FY 2026 – 27

TGERC has, vide public notice dated 20.12.2025, invited objections / suggestions / comments to the Petition filed by the Singareni Collieries Company Limited (SCCL) seeking approval for true-up of tariff for FY 2024 – 25 and determination of annual tariff for FY 2026 – 27 in respect of STPP Phase-I & II (2 × 600 MW). The Petition covers reconciliation of actual costs with approved tariff components, including fixed and energy charges, as well as the proposed tariff for the upcoming control period, in accordance with the Electricity Act, 2003 and applicable Tariff Regulations. 

The objections / suggestions / comments along with supporting material must be submitted on or before 10.01.2026. The public hearing is scheduled on 22.01.2026.

The public notice dated 20.12.2025 can be accessed here.

TGERC invites objections / suggestions / comments on the Petition filed by TPGENCO seeking approval for determination of capital cost and provisional tariff

TGERC has, vide public notice dated 19.12.2025, invited objections / suggestions / comments to the Petition filed by Telangana Power Generation Corporation Limited (“TPGENCO”) seeking approval for determination of capital cost and provisional tariff in respect of Unit-2 (800 MW) of Yadadri Thermal Power Station (“YTPS”) for the period FY 2024 – 25 to FY 2028 – 29, and Unit-1 (800 MW) of YTPS for FY 2025 – 26 to FY 2028 – 29. The Petition has been filed under the provisions of the Electricity Act, 2003 read with the applicable Tariff Regulations, and relates to recovery of capital cost and associated tariff components for electricity supplied to the TGDiscoms.

The objections / suggestions / comments along with supporting material must be submitted on or before 09.01.2026. The public hearing is scheduled on 21.01.2026.

The public notice dated 19.12.2025 can be accessed here.

TGERC invites objections / suggestions / comments on the Petition filed by TPGENCO seeking approval of additional capital expenditure incurred for its thermal power stations

TGERC has, vide public notice dated 19.12.2025, invited objections / suggestions / comments to the Petition filed by TPGENCO seeking approval of additional capital expenditure incurred for its thermal power stations, including Bhadradri Thermal Power Station (BTPS) and Kothagudem Thermal Power Station (KTPS). The Petition relates to capitalisation of costs towards construction of quarters, ash pond bunds, and associated infrastructure works, proposed under various project stages in accordance with the Electricity Act, 2003 and the applicable Tariff Regulations.

The public notice can be accessed here.

TGERC invites objections / suggestions / comments on the Petitions filed by TGSPDCL and TGNPDCL seeking approval for levy of Additional Surcharge for the first half (H1) of FY 2026 – 27

TGERC has, vide public notice dated 19.12.2025, invited objections / suggestions / comments to the Petitions filed by TGSPDCL and TGNPDCL seeking approval for levy of Additional Surcharge for the first half (H1) of FY 2026 – 27. The proposed surcharge is aimed at recovery of fixed costs arising from stranded capacity, particularly in the context of consumers availing open access.

The objections / suggestions / comments along with supporting material must be submitted on or before 09.01.2026. The public hearing is scheduled on 21.01.2026.

The public notice dated 19.12.2025 can be accessed here.

TGERC invites objections / suggestions / comments on the Petition filed by TGDiscoms seeking consent for the procurement of 800 MW share from the 2400 MW Telangana Super Thermal Power Station Stage – II

The Telangana Electricity Regulatory Commission (“TGERC”) has, vide public notice dated 18.12.2025, invited objections / suggestions / comments to the Petition filed by the Southern Power Distribution Company of Telangana Limited (“TGSPDCL”) and Northern Power Distribution Company of Telangana Limited (“TGNPDCL”) seeking approval for the procurement of 800 MW power from the 2400 MW Telangana Super Thermal Power Project (“STPP”) Stage-II.

The proposal involves procurement of power from one unit of the STPP and approval of the draft Power Purchase Agreement (PPA) proposed to be executed with NTPC for a period of 25 years.

The objections / suggestions / comments along with supporting material must be submitted on or before 01.01.2026. The public hearing is scheduled on 08.01.2026.

The public notice dated 18.12.2025 can be accessed here.

CERC issues a public notice granting extension on stakeholder comments on staff paper addressing delayed PPAs under the GNA framework

Central Electricity Regulatory CERC (“CERC”) issued a public notice dated 15.12.2025 extending the last date for submission of comments and suggestions to 26.12.2025 on its Staff Paper titled “Proposal for allocation of Connectivity granted (on LoA route) where the signing of the PPA/PSA is getting delayed.” The Staff Paper examines a growing concern under CERC (Connectivity and General Network Access to the Inter-State Transmission System) Regulations, 2022 (“GNA Regulations”), where large volumes of connectivity have been granted to renewable energy projects on the basis of Letters of Award (“LoAs”), but Power Purchase Agreements (“PPAs”) have not been executed for extended periods. As of June 2025, approximately 31.8 GW of connectivity (and up to 45.34 GW including pending applications) has been granted on the LoA route without corresponding PPAs, resulting in sub-optimal utilisation of the transmission system.

The Commission has noted that delayed PPA signing leads to transmission infrastructure remaining blocked despite readiness, while other developers willing to commission projects within timelines are unable to secure connectivity due to evacuation constraints. The Staff Paper proposes a framework to deal with such legacy LoA-based connectivity. The proposals include multiple pathways for developers, such as migration from the LoA route to land-based routes with revised milestones, substitution of LoAs with PPAs signed under other LoAs within the same corporate group, or exit and surrender of connectivity, while introducing milestone-linked obligations, performance bank guarantees, and milestone extension charges.

A key feature of the proposal is the introduction of an auction mechanism for reallocation of surrendered connectivity, recognising connectivity as a scarce resource. Vacated connectivity would be auctioned with strict commissioning timelines, minimum bid sizes, and financial commitments, with proceeds used to offset transmission charges and support ancillary services. Looking ahead, CERC has also sought stakeholder views on reforming future connectivity grants, including proposals to discontinue LoAs as a basis for connectivity, restrict eligibility to PPAs only, or move entirely to an auction-based allocation framework.

The CERC procedure can be accessed here.

CERC issues Removal of Difficulties Order providing key clarifications under the GNA Regulations

CERC has issued a Suo Moto Removal of Difficulties order dated 08.12.2025 in Petition No. 14/SM/2025 under the GNA Regulations. Following the Third Amendment of the GNA Regulations (effective from 09.09.2025), which introduced the solar-hour and non-solar-hour access framework, several RE developers and industry associations highlighted operational challenges, under the GNA Regulations. On consideration of these concerns, the CERC has issued the following key clarifications and directions: 

1. Relaxation of Regulation5.11(b) of the GNA Regulations

The timeline for submission of application under Regulation 5.2 or Regulation 5.11(a) for converting an REGS (with or without ESS) or RPPD, based on solar source or an RHGS with a combination of solar source with another source (with or without ESS), as an entity with solar hour access, under Regulation 5.11(b), has been extended from three months to 5.5 months from the date of effect of the Third Amendment i.e., 09.09.2025. 

2. SCOD Declaration for RPPDs 

The timeline under Regulation 37.10(g) of the GNA Regulations for RPPDs, which are yet to achieve generation capacity of the total quantum of Connectivity, to furnish the SCOD of the generating station under the Renewable Power Park has been extended from three months with an additional two and half months from the date of effectiveness of the Third Amendment, as a one-time measure. 

3. Relaxation of Regulation 5.1 of the GNA Regulations

The CERC has relaxed Regulation 5.1 of the GNA Regulations, allowing RE developers to install additional inverters, WTGs or equivalent equipment for meeting technical requirements at the Point of Injection, without being considered as an additional capacity for purpose of seeking additional Conn-BGs or trigger compliance under Regulation 5.8, whether applied under Regulation 5.1 or Regulation 5.2 of the GNA Regulations 2022. 

4. ESS Charging Prior to CTU Drawal Studies 

ESS projects that have been granted Connectivity with ‘NIL’ drawal, due to pending CTU’s drawal studies, as well as REGS with ESS transitioning under Regulation 37.10(e) of the GNA Regulations, may draw charging power from the Grid under T-GNA up to their granted connectivity quantum, based on the margins, until CTU completes the drawal study and any required augmentation. Once the study is completed, drawal will shift to GNA as per the quantum approved. CTU has accordingly been directed to complete these studies within four months from the issuance of the order. 

5. Change of Land Parcels under Regulation 5.8 of the GNA Regulations 

Regarding changing the location of land parcels under Regulation 5.8 or Regulation 11A of the GNA Regulations, the Third Amendment limits the number of availing the option to only one time per entity. The CERC has clarified in this regard that the restriction will not consider the changes made in land parcels prior to the effectiveness of the Third Amendment, and any entity which has already changed land parcels before the said amendment shall also be eligible to seek change once, post the effectiveness of the third amendment.

6. Eligibility to make application for Non-Solar Hour Access

REGS or RPPDs based on solar source or a combination of solar source with another source, (with or without ESS), with in-principle or final  grant of connectivity, effective GNA, or pending applications of connectivity applied before the effectiveness of the Third Amendment, are eligible to apply for additional capacity for non-solar hour access under the Right of First Refusal (“ROFR”) through an application under Regulation 5.11(a) or 5.2 of the GNA Regulations. The timeline under Clause (4) of Annexure IV of the GNA Regulations has also been extended to 5.5 months, in line with the extension of the timeline under Regulation 5.11(b), from the effectiveness of the Third Amendment. The CERC also clarified that RPPDs may seek non-solar hour access under the ROFR mechanism only under the GNA Regulations.

7. Change in Energy Source, Regulation 9.3 of the GNA Regulations

Regulation 9.3 of the Third Amendment of the GNA Regulations, permits change of renewable energy source to be carried out only once for a connectivity grantee, by making an application to the Nodal Agency for approval for such change within 18 months from the in-principle grant of Connectivity or 18 months prior to the firm start date of connectivity whichever is later. As such restrictions on number and timeline were not provided prior to the Third Amendment; in order to address the issue where an entity was not given final grant of connectivity till issuance of third amendment and 18 months from in- principle grant expired, the CERC has allowed all entities with in-principle connectivity granted prior to the Third Amendment a one-time opportunity to change their energy source under Regulation 9.3, regardless of any prior source changes or expiry of the earlier timeline.

8. Land BG Cases, Regulation 11A of the GNA Regulations

Regulation 11A(1) as amended under the Third Amendment of the GNA Regulations, requires land documents to be submitted to the Nodal Agency within 18 months of issuance of in-principle connectivity or 12 months of final connectivity, whichever is earlier, or nine months from the date of issuance of tentative coordinates where the tentative or final coordinates were not provided with the final grant. The CTU has in this regard informed that the timeline of 9 months shall be applicable only for cases where final grant of Connectivity has been issued, otherwise the 18 months period from in-principle grant shall apply.  The CERC clarified that if CTU delays issuing the final grant and has not provided coordinates to such entity, the entity must be given at least nine months from the communication of tentative coordinates to submit land documents. The CTUIL has been directed to apply this extended timeline accordingly.

RERC approves Draft Procedure for Grant of Green Energy Open Access

The Rajasthan Electricity Regulatory Commission (“RERC”) vide its order dated 12.12.2025 in Petition No. 2357/2025 has approved and notified the final Procedure for Grant of Green Energy Open Access under the RERC (Terms and Conditions for Green Energy Open Access) Regulations, 2025 (“Procedure”). The Procedure has been finalised after a detailed public consultation process, taking into account comments and suggestions received from stakeholders.

The Commission has clarified that the Procedure applies to long-term, medium-term and short-term green energy open access transactions within the State and also extends to cases where intra-State transmission or distribution systems are incidental to inter-State transmission, including transactions under General Network Access (GNA) and Temporary GNA. To ensure seamless implementation, RERC has directed interoperability between national platforms such as NOAR and GOAR and the State portal, thereby avoiding duplication and facilitating ease of compliance.

The Order delineates the roles and responsibilities of Rajasthan Rajya Vidyut Prasaran Nigam Ltd (“RVPNL”), the State Load Dispatch Centre and the distribution licensees, while emphasising transparency through mandatory public disclosure of GEOA related information. In relation to captive and group captive projects, the Commission has adopted a pragmatic approach by permitting provisional recognition at the pre-approval stage, subject to annual verification of captive status in accordance with the Electricity Rules, judicial pronouncements and directions issued from time to time.

Addressing practical implementation challenges, the Commission has introduced flexibility in connectivity requirements. Green energy open access applications may now be processed on the basis of connectivity feasibility approval, with conditional approvals permitted prior to establishment of physical connectivity, subject to completion within the prescribed timelines.

The Order provides a detailed clarification on Battery Energy Storage System requirements. RERC has reaffirmed the mandatory installation of BESS for new renewable energy projects and clarified that captive projects exceeding 100% and up to 200% of contract demand must install BESS equivalent to 20% of the energy generated by the additional capacity, calculated at normative CUF or PLF. Behind-the-meter installations continue to be included for capacity calculations, and operation of BESS will remain subject to directions of the SLDC or the distribution licensee in the interest of grid security.

The Commission has also clarified the treatment of existing open access consumers. Existing arrangements may continue until their expiry, while any additional capacity or open access sought thereafter must be governed by the GEOA framework. A one-time option has been provided to enable voluntary migration of existing agreements into the GEOA regime for their remaining tenure.

The RERC draft procedure can be accessed here.