HERC 2025: Haryana Expands GEOA Eligibility — Multiple Connections Can Now Aggregate

Haryana sits at the centre of one of India's most active C&I power markets. From Manesar's auto component manufacturers to Gurgaon's IT campuses, Karnal's food processors and Faridabad's heavy industries, the demand for cleaner, cheaper electricity has been growing rapidly. The state's two distribution licensees — Uttar Haryana Bijli Vitran Nigam (UHBVN) and Dakshin Haryana Bijli Vitran Nigam (DHBVN) — operate under tariff structures that make industrial power notably expensive relative to renewable open access alternatives.

Until early 2025, however, the gateway to renewable open access in Haryana had a meaningful entry barrier: the 100 kW contracted demand threshold. That kept many mid-sized consumers — small manufacturers, retail chains, hospitality groups — locked out of green energy open access, even when their cumulative consumption across multiple units would have easily cleared the bar.

The 2025 amendment to the HERC Green Energy Open Access Regulations (originally notified in 2023) changes that, alongside several other adjustments that directly affect Haryana C&I economics.

Context: why GEOA matters in Haryana

Green Energy Open Access (GEOA) is the regulatory pathway that allows consumers to purchase renewable electricity from any RE generator — solar, wind, hybrid, biomass — over the state grid, rather than from their DISCOM. For Haryana industrial consumers paying ₹7.50–8.50 per unit to UHBVN/DHBVN, the savings from GEOA — even after wheeling, transmission, and applicable surcharges — typically run 25–30%.

The original HERC GEOA Regulations 2023 set the eligibility floor at 100 kW of contracted demand per connection. Consumers above this floor could opt in; smaller consumers could not.

The 2025 amendment — what changed

The amendment introduces three key changes:

1. Aggregation of multiple connections within the same electricity operation division of the same distribution licensee, to collectively meet the 100 kW threshold.
2. DSM relief for long-term open access in solar and wind, with deviation handling shifted from DSM charges to standby charges capped at 25% of energy charges.
3. Extension of Additional Surcharge exemption for offshore wind energy until December 2032.

Multi-connection aggregation explained

This is the headline change. Under the amended regulation, a consumer who has multiple electricity connections within the same operation division of UHBVN or DHBVN can aggregate the contracted demand across those connections to meet the 100 kW eligibility threshold.

Example: A retail chain operating four stores in the same DHBVN operation division, each with 30 kW contracted demand, has total aggregate demand of 120 kW. Previously, none of the individual connections qualified for GEOA. With the amendment, the chain can aggregate and procure renewable energy under open access for the combined 120 kW load.

For multi-location consumers — pharma chains, retail, hospitality, IT campuses with multiple buildings — this opens a meaningful new procurement channel.

DSM relief for long-term OA solar & wind

The second important change addresses a long-standing pain point for solar and wind open access consumers: Deviation Settlement Mechanism (DSM) charges. Solar and wind are inherently variable. When actual generation differs from the scheduled quantum, DSM charges kick in — and they can be punitive.

The amended regulation provides that DSM charges shall not apply to long-term open access transactions for solar and wind. Instead, any deviation will be treated as drawal under standby provisions, with charges capped at 25% of the applicable energy charges.

For long-term solar and wind OA consumers — typically 12+ year arrangements — this provides predictable, capped exposure rather than the volatile DSM exposure they faced under the unamended regime. It materially improves the bankability of long-term renewable PPAs in Haryana.

What this means for Haryana C&I consumers

Three implications stand out:

1. The addressable market for renewable open access has expanded. Consumers previously excluded by the 100 kW per-connection floor — particularly multi-site retail, hospitality, healthcare, and SME manufacturers — now have a pathway.
2. Long-term renewable PPAs are de-risked. The DSM cap at 25% of energy charges removes a major source of cost uncertainty, making long-term solar and wind contracts substantially more bankable.
3. Open access economics in Haryana have improved. Combined with the offshore wind Additional Surcharge exemption, the net effect of the 2025 amendment is to lower the all-in cost of green power for Haryana C&I consumers.

That said, the underlying economics of captive and group captive power remain stronger than even amended open access. Captive consumers continue to enjoy statutory exemption from Cross-Subsidy Surcharge and Additional Surcharge under Section 9 of the Electricity Act — exemptions that GEOA, even after the 2025 amendment, does not fully replicate.

For Haryana industries serious about long-term power cost reduction, the right question is not "open access or DISCOM?" but "what mix of captive, open access, and DISCOM best fits my load profile?" The HERC 2025 amendment makes open access more attractive within that mix — but it doesn't change the basic captive advantage.