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Submission on draft CERC (Terms and Conditions of Tariff) Regulations 2024
The Central Electricity Regulatory Commission published the draft notification on the Multi Year Tariff (MYT) Regulations for the control period FY25-FY29 on 4th January 2024, and invited public comments on the same.
The draft regulations, and related processes have taken several positive actions and steps in the right direction. However, it is crucial to further strengthen flexibility measures, target incentives, safeguard consumer interests and ensure clarity in the MYT regulations – given the fast paced changes in the sector and the impact of these regulations on multiple stakeholders across the country for the next five years and beyond.
Towards this, PEG's inputs included the following suggestions:
- Encourage new capacity addition through Section 63 and consider Section 62 capacity additions only with fresh beneficiary consent
- Ensure public process is carried out for cost approval and tariff determination of central generators
- Reintroduce availability linked fixed cost recovery across high/low demand seasons with separate and appropriate weights
- Revise the suggested PLF incentives such that they are targeted and modest
- Consider GCV 'As Billed' for ECR calculations and penalise non-compliance with existing regulations regarding publication of data on fuel procurement
- Cap blending of fuel without beneficiary consent based on impact on ECR
- Cap input price of coal from integrated mines at the CIL notified price for the corresponding grade
- Allow costs related to Emission Control systems based on adherence to the revised emission norms
Note and Presentation for the 19th SAC meeting of APERC
The 19th meeting of the State Advisory Committee of APERC was held at Tirupati on 13/2/2024. This was held to seek inputs from SAC members on the petitions by utilities on Aggregate Revenue Requirement (ARR), annual retail tariff and Mutli Year Tariff for the wires business. Prayas (Energy Group) submitted a note before the meeting and made a presentation during the meeting. Key points include the importance of a multi-year resource planning, rigour in sales forecast, better measures to improve the quality of supply and attention to electricity safety.
Comments on Late Payment Surcharge Rules Amendment 2023
The Ministry of Power has suggested amendments to Rule 7 and Rule 9 of the Late Payment Surcharge (LPS) Rules, 2022 in order to strengthen payment discipline by DISCOMs to generators and to enable better utilisation of un-requisitioned capacity.
Prayas (Energy Group)'s comments on the Draft Late Payment Surcharge (LPS) and Related Matters (Amendment) Rules 2023, proposed by the Ministry of Power, emphasize the need for clarity and feasibility in the implementation of the amendments to Rules 7 and 9 of the 2022 LPS Rules.
Suggestions were made to address two key implementation challenges:
- Allowing sufficient time for DISCOMs to obtain a stay in case of disputed amounts from the appropriate authority.
- Accounting for significant variation in approved and actual energy charges in bidding framework and gain and loss sharing for URS capacity.
The aim of these suggestions is towards a fair and balanced system that serves the interests of both DISCOMs and generators in an equitable and fair manner.
Comments on Draft Electricity (Rights of Consumers) Second Amendment Rules, 2023
This submission is in response to the letter dated 13/12/2023 from the Ministry of Power seeking comments on the Draft Electricity (Rights of Consumers) Second Amendment Rules, 2023, which is also available on the MoP website.
The draft amendment specifies time limits for some consumer services, where it was not specified in the principal Rules and proposes to tighten some. It also simplifies the procedure for connection for roof top solar systems upto 10 kW. We broadly feel that this amendment is a good step, but strongly request MoP to provide explanatory memorandum giving the justification and objective for such amendments.
Our earlier related Submissions:
Comments on Draft Electricity (Right of Consumers )Amendment Rules, 2023
Comments and Suggestions on Draft Electricity (Amendment) Rules, 2022
Comments on Draft Electricity (Right of Consumers) Amendment Rules, 2021
Comments and Suggestions on the Draft Electricity (Rights of Consumers) Rules, 2020
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