Last edition, we asked: what happens when the binding constraint shifts from firming at the generation layer to deliverability at the transmission layer? Deliverability is not one problem. It is three layers that must simultaneously align — and the layer most invisible to capital allocators is the one that fails most quietly and most expensively.
In 2024, the IEA tracked 1,650 GW of solar and wind projects in advanced development globally that were waiting for grid connection. That figure is not a planning horizon estimate. It is capacity in advanced development that cannot yet dispatch at scale — because the infrastructure between the asset and the load is the binding constraint. But "infrastructure" is doing too much work. The constraint is not only wires. It is wires, contracts and rules — and they fail independently.
Generation capacity is being built faster than the transmission system can absorb it. This is not a technology problem. It is a sequencing failure — across three distinct layers.
Most infrastructure investment addresses Layer 1. Most project finance addresses Layer 2. Layer 3 is where the gap lives.
Vietnam wasted 364 GWh of solar energy in 2020. Grid congestion in southern provinces was real — but the framing understates the failure. The dispatch framework had not yet evolved enough to dynamically accommodate solar output at that scale. The bottleneck was not only physical; it was also the governance of how power was dispatched. Reform took until Decree 57 in 2025 to begin materialising.
Fortune reported Liberty Utilities disclosed NV Energy would no longer provide a major portion of its power supply after May 2027, raising concern for ~49,000 Lake Tahoe customers — in the context of rising data centre demand (Google, Apple, Microsoft at Tahoe-Reno Industrial Center). NV Energy disputes that residents will lose service. The structural signal holds: where data centres can offer a scale and load profile that residential customers cannot match, and load-allocation rules offer no protected access, small-scale users have limited leverage.
NEM connections pipeline hit 64 GW (Dec 2025) against a transmission system expanding materially slower than generation deployment. SA curtailed 38% of utility-scale solar in 2025. REZ projects (HumeLink, EnergyConnect, QNI Connect) are the structural response — lead times 2028–2032.
FiT-driven solar concentrated in the south while load sits in the north. 220 renewable plants cut production by end-2023; 20 overloaded points on 220/110 kV lines. Quang Tri wind curtailment reached exceptionally high levels in late 2025. Decree 57 DPPA reform is a structural improvement — not yet a physical grid fix.
Rajasthan (~34 GW operational base) saw peak-hour solar curtailment reach 51.5% in 2025 amid 18–20 month transmission delays. Of 340 GW planned ISTS network, only 48 GW is complete and 112 GW remains in planning.
TNB investing RM45B in grid 2025–2027. CRESS improves the third-party access pathway, but grid-access charges (SAC) and implementation rules remain material bankability variables. From the project-delivery side: grid connection is slower than equipment supply — the bottleneck is the queue, not the generation side.
- 1Curtailment is non-linear on IRR.For projects with market-price exposure, curtailment during peak solar hours creates a non-linear revenue drag — lost generation volume at peak disproportionately reduces revenue because peak hours carry the highest spot prices.Curtailment assumptions must be stress-tested at state or sub-state level, not national averages. India's national figure of 0.12% masks Rajasthan's 51.5% peak-hour reality.
- 2Transmission delay risk is now a first-order bankability risk.Think about what an 18-to-24 month construction-to-revenue gap actually means in a project finance stack: extended interest-only periods, reserve accounts eaten before the asset earns a dollar, or sponsor equity bridges that were never in the original model.Lenders who don't stress-test this explicitly may be mispricing risk. Most aren't stress-testing it explicitly.
- 3Co-located structures change the debt structure.A co-located generation + BESS + grid access project is a single infrastructure asset with multiple revenue streams: capacity payments, energy arbitrage, grid services, non-curtailable delivery value.The appropriate structure is a unitised project with blended debt tenor — longer on generation and storage, shorter on grid access if it carries regulatory risk.
- 4The aggregator lane requires capital across all three layers.Generation alone is commoditised. Firming alone does not solve the delivery problem. Grid access alone is a toll road without traffic.The capital structure of a genuine aggregator looks less like a renewable energy fund and more like a vertically integrated utility with a project finance wrapper.
- 5Vietnam's DPPA mechanism opens a new revenue architecture, with caveats.Decree 57 (March 2025) allows direct sales to large industrial consumers outside EVN offtake. Projects with BESS or flexible dispatch may receive priority grid access.Curtailment risk remains under Virtual DPPA structures and compensation terms are not yet clear. Structural improvement — not yet a physical grid fix.
- 6RE support mechanisms in SEA carry policy interruption risk.Philippines ERC temporarily suspended GEA-AII collection (₱0.0371/kWh) for May–June 2026 citing consumer affordability pressure. Fund balance ~₱466.49M as of 5 May was sufficient to cover RE facility payments.Government-administered RE levies are politically exposed to consumer price pressure — a revenue risk standard bankability models rarely stress-test explicitly.
- 7Layer 3 risk is now a front-of-model bankability condition.I've heard this framed as a documentation issue — just add a curtailment clause and move on. It isn't. In practice, lenders in SEA increasingly look for either a buyer who contractually pays through curtailment events, or an explicit curtailment compensation mechanism from day one — not as a fallback, but as a pre-condition for debt sizing.Mid-market APAC data centre operators competing against hyperscalers for grid access face the same structural dynamic as Lake Tahoe's customers: scale confers governance-access advantage, not just procurement advantage.The entity that navigates Layer 3 on behalf of mid-market operators — securing dispatch priority, curtailment compensation and direct contracting rights — is not just an energy intermediary. It is a governance intermediary. That is the aggregator lane, properly defined.
The aggregator thesis running through this newsletter since Edition 2 has arrived at its structural answer. It is not a PPA aggregation play. It is a grid access architecture play — built on three stacked layers, each requiring separate capital allocation, but collectively creating something that individual project finance cannot replicate: a non-curtailable, firmable, clean energy delivery path to load.
Vietnam's DPPA reform is the most advanced policy signal. Australia's REZ framework is the most structured procurement architecture. India's scale creates the largest addressable market. Malaysia is the cross-border logistics layer. No single market has all three conditions simultaneously — which is why the aggregator entity, if it emerges, will likely be regional rather than country-specific.
That is where multilateral development finance institutions, green bonds and blended finance structures come in. And that is where Edition 8 goes.
Sources
| Term | Full name | Plain English |
|---|---|---|
| AEMO | Australian Energy Market Operator | Manages Australia's NEM; oversees grid connections and dispatch |
| APG | ASEAN Power Grid | Regional electricity interconnection initiative across Southeast Asia |
| BESS | Battery Energy Storage System | Large-scale batteries that store and release electricity to firm up renewable generation |
| CRESS | Corporate Renewable Energy Supply Scheme | Malaysia's framework for corporate clean energy procurement from the grid |
| DPPA | Direct Power Purchase Agreement | Allows renewable generators to sell power directly to large consumers, bypassing the state utility |
| ERC | Energy Regulatory Commission | Philippines' independent electricity sector regulator |
| EVN | Electricity of Vietnam | Vietnam's state-owned electricity utility and primary grid operator |
| FiT | Feed-in Tariff | Government-set price paid to renewable energy generators per unit of electricity produced |
| GEA-AII | Green Energy Auction Allowance | Per-kWh levy in the Philippines that funds payments to renewable energy facilities |
| IEA | International Energy Agency | Paris-based intergovernmental body tracking global energy data and policy |
| IRENA | International Renewable Energy Agency | Intergovernmental body supporting the global renewable energy transition |
| IRR | Internal Rate of Return | Annualised return on an investment — primary metric for infrastructure project viability |
| ISTS | Inter-State Transmission System | India's high-voltage national transmission network evacuating large-scale renewable generation |
| NEM | National Electricity Market | Australia's main electricity grid covering eastern and south-eastern states |
| NLDC | National Load Dispatch Centre | Vietnam's national grid dispatch authority managing real-time power system operations |
| PDP8 | Power Development Plan 8 | Vietnam's national energy master plan for 2021–2030 with vision to 2045 |
| PPA | Power Purchase Agreement | Long-term contract fixing the price and volume of electricity between a generator and a buyer |
| REZ | Renewable Energy Zone | Designated areas in Australia with strong renewable resources, supported by coordinated transmission investment |
| SAC | System Access Charge | Fee developers pay TNB to transport power across Malaysia's grid under the CRESS scheme |
| TNB | Tenaga Nasional Berhad | Malaysia's national electricity utility and grid operator |