HSA | Projects, Energy & Infrastructure Monthly Newsletter | November 2025

LEGAL & POLICY UPDATES

Gujarat Electricity Regulatory Commission notifies the Net Metering Rooftop Solar PV Grid Interactive Systems (Fifth Amendment) Regulations, 2025

• Gujarat Electricity Regulatory Commission (GERC) through its notification dated November 3, 2025, has issued the Fifth Amendment to the Net Metering Regulations, 2016, exercising its rule-making powers under Sections 61, 66, 86(1)(e) and 181 of the Electricity Act, 2003. The amendment formally modifies the Principal Regulations and applies statewide from the date of publication.
• The amendment primarily revises procedural requirements governing connectivity for rooftop solar installations, especially those being deployed under the Government of India's PM Surya Ghar Muft Bijli Yojana.
• A significant change has been introduced under Regulation 7, where a new proviso eliminates the need for consumers under the PM Surya Ghar scheme to execute a separate written connectivity agreement with the Distribution Licensee. Instead, such consumers will automatically be deemed to be governed by the terms and conditions of the Principal Regulations once the rooftop system is commissioned.
• The date of commissioning of the rooftop PV system is now deemed to be the commencement date of the contractual relationship between the consumer and the DISCOM. The earlier requirement of signing a formal agreement has been replaced with a simplified communication process to reduce delays and paperwork.
• In place of a full agreement, the concerned DISCOM must provide a written acknowledgment to the applicant, recording (a) the commencement date of the deemed agreement, and (b) the applicable rate at which surplus energy injected into the grid will be purchased. This requirement ensures compliance documentation without imposing a full contract execution process.
• Regulation 8(2) has been substituted in entirety, clarifying that the connectivity level for rooftop PV systems must follow the voltage-level provisions prescribed under the GERC Electricity Supply Code 2015, as updated from time to time. This alignment avoids conflicting technical rules and provides uniform standards for interconnection across the State.
• The amendment simplifies procedural requirements for rooftop installations, particularly under the central PM Surya Ghar program, and aligns connectivity norms with existing supply-code standards.

APERC Issues Draft First Amendment to Renewable Energy Tariff Regulations, 2025 (Regulation No. 6 of 2025) dated November 18, 2025

• APERC had earlier notified the APERC (Terms and Conditions for Tariff Determination from Renewable Energy Sources) Regulation, 2025 (Regulation No. 6 of 2025), published in the Andhra Pradesh Gazette on September 12, 2025.
• After issuing the Principal Regulation, APERC undertook a performance review of operational small hydro generating stations across the State.
• This operational review showed that the normative CUF of 40% prescribed in Clause 27 of the Principal Regulation does not match the actual CUF achieved by many small hydel projects, considering prevailing hydrological flow conditions.
• APERC noted that several small hydro stations in Andhra Pradesh are operating below the 40% CUF normative benchmark, making the existing CUF unrealistic for tariff-setting purposes.
• APERC further observed that the CERC (RE Tariff) Regulations, 2024 prescribe 30% CUF for small hydro projects in Andhra Pradesh, indicating that the national regulatory framework has already recognized lower achievable CUF levels.
• APERC found it necessary to ensure that the State's tariff framework is aligned with ground performance, avoids overestimation of generation, and provides realistic tariff signals for investors and utilities.
• Therefore, under its powers under Sections 61, 62, 86(1)(b) and 181 of the Electricity Act, 2003, APERC issued the Draft First Amendment to the Principal Regulation.
• The Draft Amendment specifies the Short Title, Extent, and Commencement as follows:
  • It shall be called the First Amendment to the APERC RE Tariff Regulations, 2025.
  • It extends to the entire State of Andhra Pradesh.
  • It comes into force on the date of publication in the Andhra Pradesh Gazette.
• The Draft Amendment proposes a complete substitution of Clause 27 of the Principal Regulation. The substituted Clause 27 reads as "It shall be projectspecific and shall not be less than 30% (Project specific).
• This amendment replaces the earlier minimum CUF of 40% with a minimum project-specific CUF of 30%, creating flexibility for actual project conditions.

Ministry of Power Issues Comprehensive Policy for Co-firing of Biomass Pellets & Torrefied MSW Charcoal in Coal-based Thermal Power Plants

• MoP has issued a Letter dated November 07, 2025 wherein it provided a Comprehensive Policy for co-firing biomass pellets and torrefied charcoal made from Municipal Solid Waste (MSW) in coal-based Thermal Power Plants (TPPs), replacing the 2021 biomass co-firing policy and its 2023 modification.
• The policy's objective is to Reduce GHG emissions, Promote utilisation of surplus agricultural residue and MSW, Support the Swachh Bharat Mission, Address biomass supply-chain constraints, stubble-burning issues, and TPP operational difficulties.
• Mandatory co-firing from FY 2025-26:
  • All coal based TPPs of power generation utilities in the NCR shall on annual basis use 5% blend (by weight) of biomass pellets and additional 2% blend (by weight) either from biomass pellets and/or torrefied MSW charcoal.
  • TPPs in other region shall on annual basis use 5% (by weight) biomass pellets and/or torrefied MSW charcoal.
• A Biomass pellets may be non-torrefied, semi-torrefied (VM >22–40%), or fully torrefied (VM <22%), subject to OEM suitability.
• The percentage of biomass/torrefied MSW blending may be revised in future based on fuel availability and TPP performance.
• Exemptions/relaxations may be granted on a case-by-case basis by a Committee headed by Chief Engineer (TE&TD), CEA, with members from CAQM, NTPC, BHEL, CPRI, MoP.
• For TPPs set up under Section 63 of the Electricity Act, 2003, any increase in Energy Charge Rate (ECR) due to co-firing is eligible under Change in Law, and cost shall pass through the ECR. Additional ECR impact will not affect Merit Order Dispatch (MOD) and DISCOMs may fulfil Renewable Consumption Obligations (RCO) through co-firing-based generation.
• Eligible biomass sources include agro-residue from crops like paddy, soya, cotton, bajra, moong, mustard, sesame, til, maize, sunflower, jute, coffee, coconut shell, groundnut shell, castor seed shell, plus horticulture waste, leaves, plant/stem trimmings, pine needles, elephant grass, sarkanda, etc.
• For TPPs in NCR and adjoining areas, at least 50% of raw material used in pellets must be rice paddy residue sourced exclusively from NCR and nearby areas.
• MoP has referenced the Revised Model Contract for Biomass use in TPPs (MoP letter dated January 06, 2023), which may be updated periodically.
• MoP will notify benchmark regional prices for biomass pellets; TPPs may be procure Aw3at benchmark prices or through transparent competitive bidding.

Ministry of Petroleum and Natural Gas Invites Public Consultation on LNG Amendment Rules 2025

• On October 24, 2025, the Ministry of Petroleum and Natural Gas (MoPNG), Government of India issued a public notice inviting comments on the Draft Petroleum and Natural Gas Regulatory Board (Eligibility Conditions for Registration of Liquefied Natural Gas Terminal) (Amendment) Rules, 2025 (LNG Amendment Rules 2025). The draft seeks to modify the Petroleum and Natural Gas Regulatory Board (Eligibility Conditions for Registration of Liquefied Natural Gas Terminal) Rules, 2012 (Conditions for Registration Rules).
• The proposed amendments are issued under the legal framework of the Petroleum and Natural Gas Regulatory Board Act, 2006 (PNGRB Act). Under Section 11(b) of the PNGRB Act, the Board is empowered to register entities intending to establish or operate LNG terminals. In addition, Section 15(1) requires that such entities meet the eligibility conditions prescribed by the Board before submitting an application for registration.
• MoPNG states that the amendments are necessary in light of India's growing energy demand, limited domestic gas production, and the strategic importance of LNG in enhancing the country's natural gas availability. The draft rules emphasize commercial transparency, equitable access, and the public interest, aiming to ensure that LNG terminal operators provide non-discriminatory access and maintain transparent operations.
• The draft introduces stricter eligibility criteria, requiring entities or their parent/promoter companies to have a minimum net worth of INR 1,500 crore for each of the preceding three financial years and experience in completing an infrastructure project exceeding INR 1,000 crore or operating a hydrocarbon project over INR 600 crore within the last five years. Additionally, applicants intending to operate an LNG terminal must maintain a credible plan to hold storage capacity at least 10% above daily regasification requirements, which must be made available upon direction of the Central Government. Existing LNG terminal operators predating the establishment of PNGRB must also furnish details of their facilities as prescribed.

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