The Gujarat Electricity Regulatory Commission (GERC) has heard a petition filed by two renewable energy project developers seeking clarification and modification of the Associated Transmission System Bank Guarantee (ATS BG) requirement under Gujarat Energy Transmission Corporation Limited’s (GETCO) Connectivity Procedure, 2025.
The petition, registered as Petition No. 2634 of 2026, has been filed by Special Purpose Vehicles (SPVs) M/s. Saraca Asoca Renewables Pvt. Ltd. and M/s. BA Prerna Renewables Pvt. Ltd. The matter was heard by the Commission comprising Chairman and Members.
The dispute relates to Clause 5.7(iv) of the Connectivity Procedure, which requires renewable energy developers to submit an ATS BG of ₹20 lakh per MW. The petitioners argued that their 70 MW solar project, planned at the 400 kV Babarzar Pooling Station, falls under Clause 5.1(ii) of the procedure, which applies to substations planned by the State Transmission Utility (STU).
The developers stated that the Babarzar Pooling Station was part of GETCO’s long-term transmission plan up to 2032 and was already under construction before they submitted their connectivity applications. According to them, such state-planned substations do not involve project-specific transmission risks because they are developed independently by the STU.
The petitioners argued that ATS BG requirements are justified only for developer-driven transmission infrastructure covered under Clause 5.2, where stranded asset risks may arise if developers withdraw after infrastructure investments are made. They claimed that imposing ATS BG on state-planned substations creates an unnecessary financial burden on renewable energy developers.
They further highlighted that developers are already required to provide multiple financial securities, including security deposits and land-related bank guarantees, which together can result in a cumulative financial commitment of nearly ₹40 lakh per MW. According to the petitioners, such requirements may create entry barriers for new investors and impact Gujarat’s renewable energy expansion plans, including its target of achieving 120 GW renewable energy capacity by 2030.
The petitioners also referred to Section 39 of the Electricity Act, 2003, stating that overall transmission planning responsibility lies with the State Transmission Utility and should not be transferred to individual generators.
However, GETCO opposed the petition and questioned its maintainability. GETCO argued that the petition was effectively a delayed review application against the Connectivity Procedure, which was approved by GERC on August 4, 2025, after a detailed public consultation process.
GETCO maintained that the ATS BG is an essential mechanism to prevent speculative applications and ensure that only serious developers reserve transmission capacity. The utility informed the Commission that several planned substations, including Mota Asarana, Maglana, and Dhank, had witnessed large numbers of applications followed by withdrawals, creating challenges in transmission planning and risks of stranded infrastructure.
GETCO also submitted that around 36 developers seeking approximately 3,000 MW of connectivity have already provided ATS BGs, demonstrating that genuine developers are able to comply with the requirement.
The petitioners, in their rejoinder, clarified that they were not challenging the validity of the Connectivity Procedure but only seeking a limited interpretation of the provisions under Sections 86(1)(k) and 94 of the Electricity Act, 2003, based on the actual risk associated with different categories of transmission infrastructure.
The Commission examined the relevant provisions of the Connectivity Procedure, including Clauses 5.1, 5.2, 5.7, 7.3, 7.6, and 7.7, and noted the distinction between seeking clarification and seeking review or modification of an approved regulatory framework. The matter remains under consideration before GERC.
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