Can my discom make me hold my open access quantity fixed for a number of time blocks, and how does that show in Scope 2?

Yes, if it is imposed. The Green Energy Open Access Rules, 2022 allow a minimum number of time blocks, not more than twelve, in which you shall not change the quantum drawn. They do not say who imposes it, so check your state regulation and approval order. Use above the quantum comes from the discom at the grid factor.

What the Rules allow

• The second proviso to Rule 5(2) of the Green Energy Open Access Rules, 2022 says reasonable conditions such as the minimum number of time blocks, which shall not be more than twelve time blocks, for which the consumer shall not change the quantum of power consumed through open access may be imposed.
• The stated purpose is to avoid high variation in the demand the discom has to meet.
• It says may be imposed and does not say by whom. Our reading: whether a hold applies, and for how many blocks up to twelve, is for your state's regulation and the discom. The Rules do not define the length of a time block.

What a hold does to your Scope 2 numbers

Our reading, not a line from the Rules: during a hold your scheduled open access units stay fixed while your plant load moves. The two can differ in both directions.

If you use less than the scheduled quantum, the surplus goes to banking or to whatever your state's rules say for surplus. It covers none of your consumption unless the discom adjusts it against your load. See the banking and deviation pages.

If you use more, the extra comes from the discom at the factor you use for uncovered grid units.

The Greenhouse Gas Protocol Scope 2 Guidance asks that instruments be issued and redeemed as close as possible to the period of energy consumption. Our reading: a fixed quantum that does not follow your load is where that test gets tight.

What to keep

• The approval order and any condition in it on time blocks.
• The scheduled quantum for each block from the monthly energy account.
• Metered consumption for the same blocks, if your meter data gives it.
• The units the discom finally adjusted against your load for the month.

A twelve-block hold, two ways

• Assumed for the example: a block is 15 minutes, so 12 blocks = 12 x 15 = 180 minutes = 3 hours. Your state's block length may differ.
• Scheduled and held: 2.0 megawatts (MW) x 3 hours = 6.0 megawatt hours (MWh)
• Load falls to 1.4 MW: use = 1.4 x 3 = 4.2 MWh. Covered: 4.2 MWh. Surplus: 6.0 minus 4.2 = 1.8 MWh to banking or your state's surplus rule
• Load rises to 2.6 MW: use = 2.6 x 3 = 7.8 MWh. Covered: 6.0 MWh. Uncovered: 7.8 minus 6.0 = 1.8 MWh = 1,800 kilowatt hours (kWh)
• Uncovered carbon dioxide (CO2): 1,800 kWh x 0.675 kilograms (kg) per kWh = 1,215 kg = 1.215 tonnes

The figures are an example. The grid factor 0.675 kg CO2 per kWh is for financial year 2025-26.

What Senseible does here

Senseible keeps electricity bills and renewable purchase records side by side, so location-based and market-based Scope 2 figures can be reported from the same data. Add scheduled and metered quantities from your discom statement. Certificate retirement proof stays with the buyer.

• Open access deviation units in Scope 2
• Green open access charges
• Open access power on the bill
• How to apply on the green open access portal
• Emissions calculators

Sources: Ministry of Power, Electricity (Promoting Renewable Energy Through Green Energy Open Access) Rules, 2022, Gazette notification of 6 June 2022, Greenhouse Gas (GHG) Protocol, Scope 2 Guidance (2015), Table 7.1 Scope 2 Quality Criteria and Chapter 10

Last reviewed 2026-11-05. Time block length and any hold are set in state regulations and approval orders. Read yours before using the example.