UPERC Admits India’s First Regulatory Petition for Retrofitting Storage into Commissioned Renewable Projects: Petition No. 2355 of 2026

Executive Summary

The Uttar Pradesh Electricity Regulatory Commission (UPERC) has admitted Petition No. 2355 of 2026, invoking the Commission’s regulatory powers to seek directions on the integration of energy storage into operational renewable energy assets. Lead petitioner Fourth Partner Energy Private Limited, appearing alongside Lalganj Power Private Limited and Fourth Partner Solar Power Private Limited, presented the case during a hearing on May 14, 2026. The proceedings mark the first formal regulatory examination of the technical and legal frameworks required for retrofitting storage into already commissioned projects.

The Core Dispute: Technical and Regulatory Gaps

The petitioners identified specific regulatory and technical voids that currently impede the installation of Battery Energy Storage Systems (BESS) at operational Renewable Energy Generating Stations (REGS). While existing frameworks address storage integration at the project’s inception, the following gaps were raised during the hearing:

• Connectivity Procedure Limitations: The 2025 Connectivity Procedure is restricted to technical assessments conducted at the initial stage of the connectivity application. It lacks a defined mechanism to regulate or contemplate the subsequent integration of BESS with a project that is already connected and commissioned.
• Operational Conflicts: Ambiguity exists between Long-Term Open Access (LTOA) approvals and the associated Bulk Power Transmission Agreements (BPTA) or Bulk Power Wheeling Agreements (BPWA)—which permit 24-hour power injection—and the Forecasting Procedure, which limits solar capacity availability to specific daytime hours. There is no clear regulatory treatment for capacity management once BESS enables injection outside of traditional solar hours.
• Certification Ambiguity: The petitioners cited a lack of clarity regarding whether behind-the-meter modifications require a fresh Chief Electrical Inspector to Government (CEIG) certificate. They contend that because BESS installation does not increase the approved generation capacity or connectivity quantum, it should be treated legally as a modification or extension of an existing REGS rather than a new generation asset.

Proposed Technical Mechanism

The petition defines the BESS installation as a “behind the meter” technical modification intended to operate entirely within existing project infrastructure. The petitioners explicitly assert that this mechanism will not result in any increase to the approved generation capacity of the project or the approved connectivity quantum originally granted to the station.

Current Procedural Status and Regulatory Timeline

Following the admission of Petition No. 2355 of 2026, the Commission has directed the respondents—Uttar Pradesh Power Corporation Limited (UPPCL), Uttar Pradesh Power Transmission Company Limited (UPPTCL), and Uttar Pradesh State Load Despatch Centre (UPSLDC)—to file formal replies.

The Commission has established the following procedural timeline:

• Respondent Replies: 4 weeks from the date of the order.
• Petitioner Rejoinder: 2 weeks following the filing of respondent replies.

The matter is scheduled for its next hearing on July 14, 2026.