RERC Finalizes Green Energy Open Access Rules With Amendments

The Rajasthan Electricity Regulatory Commission (RERC) has finalised the procedure for granting Green Energy Open Access after conducting public consultations with concerned stakeholders. The state power regulator notified the Green Energy Open Access regulations on May 21, 2025.

Earlier, RERC had directed the state nodal agency—Rajasthan Rajya Vidyut Prasaran Nigam Ltd (RVPNL), the State Transmission Utility (STU)—to issue a detailed procedure. The STU subsequently published the draft procedure on August 28, 2025. After reviewing the draft and hearing stakeholders’ views, RERC has now finalised the procedure for Green Energy Open Access.

Following are some of the key changes made by the state commission after public consultations:

1. Removing GNA Applicability Bottlenecks

The state commission addressed issues related to applicants registered under the General Network Access (GNA) regime for the inter-state transmission network. The commission noted that GNA and T-GNA are applicable at the inter-state level, and short-term, medium-term, and long-term open access applications could involve both.

RERC has proposed adding a new provision to Clause 1.4 of the draft procedure. It stated, “Provided that for transactions involving inter-State Transmission (State Network incidental to the inter-State Transmission ), the Procedure shall also be applicable to the Registration and applications made for the grant of Green Energy Open Access by availing General Network Access (GNA) or Temporary General Network Access (T-GNA).”

2. Interoperability From NOAR to GOAR Portal

The new procedural norms also address ease of portability from the National Open Access Registry (NOAR) to the Green Energy Open Access Registration (GOAR) portal. RERC stated that for inter-state open access consumers already registered under NOAR, the nodal agency should take steps to ensure interoperability between the NOAR, GOAR, and the state portal. Data available on NOAR/GOAR will be deemed valid for the state portal.

3. Conditional Open Access (for Grid Connectivity Issues)

The new procedures specify that the requirement of valid grid connectivity for availing Green Energy Open Access may be relaxed for new upcoming entities that do not have prior connectivity, subject to conditions. Such entities must submit a valid connectivity feasibility approval. Conditional open access may be granted, but physical connectivity must be achieved at least 30 days prior to the intended date of power flow.

This provision was introduced after stakeholders highlighted that in certain cases—such as when entities hold pre-construction approvals like building plans, fire NOCs, or consent to establish—the requirement of prior grid connectivity before GEOA should not apply.

4. Removing Difficulties for Entities With Multiple Connections

The procedural norms also address challenges faced by smaller entities with multiple power connections, particularly the burden of paying GEOA application charges separately. RERC has added a new provision to address this issue.

It stated, “Provided the Entities with multiple connections aggregating 100 kW or more located in same electricity division of a distribution licensee shall be eligible to submit a unified Green Energy Open Access Application covering all such connections. In such cases application fee will be charged as: 1. Base Fee: Rs. 1,00,000/- (covering first injection point and drawal point) 2. Incremental Fee: Rs. 10,000/- for each additional drawal point thereafter.”

5. Eligibility of Hybrid Projects

The RERC notification clarified that hybrid projects will be eligible for Green Energy Open Access. The quantum of GEOA will be based on the connectivity quantum of the hybrid project, irrespective of the capacities of individual components.

“A new proviso may be added after the first para of Clause 5.1. This will ensure that, for hybrid renewable energy projects, the Green Energy Open Access (GEOA) is determined based on the total connectivity of the hybrid project rather than the capacities of individual components. This provides clarity in eligibility and calculation, simplifies accounting, and avoids disputes regarding the allocation of geos across multiple RE sources. Hybrid setup,” the report said.

6. Additional Capacity for BESS

The procedural norms state that for captive power plants with capacity above 100 percent and up to 200 percent of contract demand, the demand for BESS will be calculated based on a minimum of 20 percent of the energy generated at normative CUF/PLF, as per the RERC Renewable Energy Tariff Regulations, 2020.

7. Security Deposits

The state GEOA procedural rules now specify that for captive plants, security deposits must exclude charges for cross-subsidy surcharge and additional surcharge, provided consumers submit an undertaking regarding the status of their power plants.

8. Force Majeure Events

The rulebook clarifies that cancellation and bank guarantee encashment for failure to sign the commercial agreement will not apply if the failure is attributable to events beyond the applicant’s control (force majeure events).

9. Cancellation Process and Restoration

The rules state that before cancellation, the nodal agency must issue a 15-day default notice to allow the applicant to cure the defect. If the issue is not resolved, open access will be suspended. During the suspension period, the consumer will remain liable for fixed and transmission charges but may apply for restoration by clearing all dues and paying a restoration fee of ₹25,000.