CERC Updates GNA Rules to Boost Renewable and Storage Integration

The Central Electricity Regulatory Commission (CERC) has reaffirmed its commitment to reforming India’s transmission infrastructure with the consolidated Connectivity and General Network Access (GNA) to the Inter-State Transmission System (ISTS) Regulations, 2022, along with its First, Second, and Third Amendments, the most recent of which was notified on August 31, 2025. These regulations mark a transformative overhaul of the country’s transmission access framework, replacing the dated 2009 Connectivity Regulations with a future-ready, non-discriminatory, and perpetual GNA model.

The consolidated GNA regulations provide the policy backbone for India’s ambitious target of 500 GW of non-fossil fuel energy by 2030, by enabling seamless integration of renewable energy, energy storage systems (ESS), and conventional power into the ISTS. Through a streamlined digital process via the National Open Access Registry (NOAR), strengthened financial safeguards like bank guarantees (BGs), and access provisions for solar, wind, hybrid, and storage projects, the new framework ensures balance between grid stability, market efficiency, and ease of access.

Broad and Inclusive Eligibility Criteria

Eligibility is expansive yet structured to avoid speculative projects and ensure grid reliability. Key eligible applicants include:

Generating Stations (including REGS and RHGS, with/without ESS): Minimum capacity of 10 MW (with relaxation to 5 MW for clustered or lead generator-based setups, including special conditions for NE Region and Sikkim).
Captive Generating Plants/Standalone ESS: Minimum 50 MW drawal/injection.
Intra-State Entities/Consumers: Minimum 50 MW, subject to Standing Clearance from SLDC.
RE Implementing Agencies (REIAs): Minimum aggregate 50 MW for power procurement/resale.
RE Clusters/Hybrids: Minimum 5 MW through Lead ESS/Generators.
Deemed Eligibility: Existing Long-Term Access (LTA) holders automatically transitioned to GNA.

Third Amendment Highlights:

Entities below 10 MW (especially distributed solar) can now aggregate access through Renewable Power Park Developers (RPPDs), promoting small-scale inclusion and co-located ESS for better reliability.

Simplified Application Process

All applications are handled digitally through the CTU and NOAR portals, with full timestamping and transparent processing. Key aspects:

Monthly batching; cutoff: 2400 hrs on the last day of each month.
Digital signature by authorized signatory required.
Scrutiny timeline: 10 working days, with 7-day window for rectifying deficiencies (without losing timestamp).
In-Principle Grant within 45–60 days after scrutiny.
Final Grant issued within 15 days after BG submission and necessary clearances.
Key Documents include board resolutions, affidavits, land/LOA documents (≥100 MW), PPAs for REIAs, SLDC clearances for intra-state applicants, and BG details.

Third Amendment Additions:

Includes mandated max injection/drawal data for ESS-equipped REGS and real-time publication of bay utilization by RLDCs.

Application Fees & Charges

Application fees remain affordable to ensure wide participation:
₹5,00,000 + GST per application (non-refundable).
STUs are exempt from fees for GNA applications.
Forfeiture: 20% if deficiencies are not rectified; balance refunded within 15 days.
Transmission Charges: Post-grant, usage-based as per Sharing Regulations, 2020. No upfront charges for GNA.
T-GNA extensions incur no fees, but RLDC charges may apply.

Robust Processing & Withdrawal Framework

Applications undergo thorough scrutiny with clear timelines and rules for withdrawal:

CTU Scrutiny: 10 working days; classifies deficiencies.
Withdrawal Rules:

Pre In-Principle: 50% fee forfeiture.
Post In-Principle, Pre-Final: 100% fee + 5% BG forfeiture.
Post-Final, Pre-Agreement: 100% fee + 15% BG forfeiture.
Partial Withdrawal: Allowed if minimum thresholds are met. BG and land documents released proportionally.
Third Amendment: Eases penalties for partial withdrawals due to RE constraints; applications inactive for 6 months are auto-withdrawn via NOAR.

Bank Guarantee Structure to Ensure Accountability

BGs safeguard project seriousness and fund system expansion:

Conn-BG1: ₹50 lakh – General security.
Conn-BG2: For terminal bays and ATS – ₹1–12 crore per bay + 30–50% ATS cost.
Conn-BG3: ₹2 lakh/MW for ISTS strengthening or ESS.

Refund Conditions:

BG1 after land acquisition,
BG2 after bay commissioning,
BG3 upon operationalization.

T-GNA: Nominal RLDC BG only.

Third Amendment: Allows renewable source changes (e.g., solar to wind) post-approval; reduces forfeiture for partial withdrawal.

Diverse Access Options for Grid Flexibility

Access types under the GNA Regulations:

GNA – Long-term, perpetual open access to ISTS.
GNA-RE – Renewable-specific access.
T-GNA – Temporary access up to 3 months (extendable).
T-GNA-RE – Temporary access for renewables.
Solar/Non-Solar Hour Access – Introduced via Third Amendment:

Solar Hour: Peak solar injection (weekly blocks by NLDC).
Non-Solar Hour: Full-day drawal for wind/ESS projects.

Hybrid and ESS setups benefit from mixed access and co-location flexibility.

Monitoring & Compliance for Grid Reliability

Compliance is enforced via rigorous monitoring:

Quarterly Progress Reports to CTU on land, commissioning, BGs.
NOAR Integration for scheduling, metering, and energy accounting.
Deviation Monitoring by RLDC/SLDC as per DSM Regulations.
Audits on promoter details and shareholding to curb speculative filings.

Penalties:

Non-compliance beyond 6 months: BGs forfeited, eligibility revoked.

Third Amendment: Requires solar hour updates based on weather data and reallocates idle cluster bays to optimize infrastructure usage.

Third Amendment—A Major Leap for Renewable Integration

Notified on August 31, 2025, the Third Amendment enhances flexibility and transparency:

Clusters of ISTS Substations: Geographically grouped for shared bays.
Solar Hour Access: Defined by NLDC based on weekly insolation data.
Eligibility Expansion: Sub-10 MW via RPPDs and Lead Generators.
Operational Flexibility: Allows post-approval switching of renewable source types.
Ease of Compliance: BG and land document rules relaxed for partial capacity issues.
Transparency Mandates: RLDCs to publish bay utilization data.

Transition Provisions:

Existing applications to align within 1 month.
In-principle grantees to update BGs and promoter details within 2 weeks.

Strategic Importance for India’s Energy Future

The GNA regulations are foundational to India’s decarbonization and grid modernization goals:

Access Simplification: GNA replaces LTA/MTOA; approval time halved.
RE Promotion: Provisions for hybrid/ESS mitigate variability.
Investor Confidence: BG norms ensure project seriousness.
Grid Resilience: Linked to DSM/Grid Codes; optimizes ₹2.5 lakh crore ISTS investments.
Consumer Benefits: Open access becomes faster and cheaper.

In 2025, with 20 GW RE additions annually, the GNA framework is credited with reducing curtailments by 30% year-on-year and supporting India’s net-zero vision, especially through ESS mandates.