The Ministry of Power invited comments and suggestions from the public on the draft amendment of National Tariff Policy (NTP).  With the imminent amendment of the Electricity Act, many changes in industry structure and operations are expected which will have wide-spread ramifications. Therefore any amendment to the National Tariff Policy must be in consonance with final amendments to the Electricity Act. The National Tariff Policy should support, and provide direction to large scale structural changes in the sector. Prayas comments on the draft amendment highlights this need for coherent approach and urges MoP to issue another draft of the National Tariff Policy post amendment of the Electricity Act, 2003 and seek public consultation on the same as well. Additionally, this preliminary submission covers following issues.

1. Lack of clarity on important issues in the proposed Electricity Act Amendment which are not addressed in the draft NTP amendment:  This includes the possibility of market determination of supply tariffs, clarity on proposed ceiling tariffs, recovery and settlement of CSS etc. To reduce ambiguity, the need for guidelines in the NTP to facilitate protection of small consumer interests, for the provider of last resort etc., is also emphasised.
2. Ensuring competition in generation is preserved in letter and spirit:  Comments on promoting competitive bidding for expansion projects, protecting the sanctity of contracts by not incorporating provisions for compensatory tariff and enabling sale of non-requisitioned power in short markets on a profit sharing basis.
3.  Promotion of renewable energy technologies: Comments on encouraging competitive bidding especially for wind, setting disaggregated, equitable RPO targets considering capacity addition, national commitments, state-wide realties, cost considerations as well as financial viability of utilities
4. Need for provisions to, promote Open Access and increase accountability of power sector agencies: Comments on need for an absolute uniform cap on CSS which reduces automatically over time and the need to institute tariff surcharge to finance independent monitoring of utilities.
5. To protect interest of small consumers towards 24*7 Power For All: To guarantee a minimum level of electricity consumption, BPL tariffs can be applicable for a minimum of 360 units/year and a maximum of 1200 units/year. To encourage productive activities, tariffs across consumer categories can be telescopic but uniform within slabs of consumption for consumers using less than 300 units with a connected load of less than 10 kW. Most importantly, the provision for allocation of low cost power should be extended to all consumers with a connected load less than 10 kW rather than just BPL and agricultural consumers.
6. To ensure tariff certainty and financial viability of distribution companies: To ensure tariff certainty and long term planning, tariffs to be fixed for a 3 year MYT period subject to quarterly adjustments for fixed pre-determined parameters. Additional suggestion to ensure that all costs  more than 3 years old to be disallowed, unless born out of a judicial pronouncement. This will ensure utilities regularly file true-ups and would save the consumers from tariff shocks.