CERC issued the Draft Connectivity and General Network Access to the Inter-State Transmission System Regulations, 2022 (Fourth Amendment) to strengthen the regulatory framework for connectivity to the inter-State Transmission System by introducing provisions for energy storage systems, streamlined compliance requirements, transfer of GNA, revised timelines, and procedural clarifications. The proposed amendments aim to facilitate efficient grid integration of renewable energy while enhancing transparency, operational efficiency, and certainty for stakeholders.

Our comments of the draft amendment briefly include:

1. Future-ready approach to ESS requirements: Gradually increase minimum storage duration for standalone storage 
2. Flexibility in connectivity applications by ESS: While there should be generally no mandate for installation of RE capacity for standalone ESS charging, a mandate for installing RE capacity for charging ESS can be considered for RoFR applications (non-solar hr access)
3. Need of more clear provisions for transfer of GNA, especially related to multiple drawal points in case of Agricultural DISCOMs 
4. Provide alternative options to connectivity applicant before closure of such application in case no augmentation is identified by CTU through interconnection studies
5. Need of timely publication of explanatory memoranda alongside future draft regulations to improve transparency and stakeholder engagement

The detailed submission are provided in the attached document.