The Ministry of Power on the 24th of August 2017 released a consultation paper to discuss issues pertaining to open access. This is a welcome initiative and provides a framework to all actors for a way forward to address issues with sales migration. In this context, Prayas (Energy Group) submitted comments and suggestions to the Ministry. Some comments and suggestions include:
- Suggestions to ensure a phase-wise transition away from short term open access.
- Widening the scope of the consultation paper to include captive sales migration.
- DSM mechanism for distribution open access consumers to address scheduling issues.
- Ensuring certainty in CSS and using CSS design to encourage long term open access.
- Need for transition support for DISCOMs facing sales migration as CSS, Additional surcharge will not compensate for loss of revenue.
- Suggestions for a process and methodology followed by SERCs to determine additional surcharge.
- Designing standby charges to provide standby services and encourage open access consumers to find alternate standby options.
- Phase-wise removal of concessions on cross subsidy surcharge, additional surcharge, wheeling and transmission charges in the absence of subsidy support to compensate DISCOM for costs incurred.
- Need for innovative tariff solutions and comments on how increasing fixed charges will be counter-productive for the DISCOM in its efforts to prevent sales migration.
- Need for data and information from open access consumers, generators, trading licensees, DISCOMs, ERCs, SLDCs to better understand and prepare for emerging trends.
- Need for a market monitoring committee constituted by every ERC with experts and representatives of DISCOM, traders, SLDC, ERC, open access and captive generators and consumers which releases an annual report with inter-state and intra-state market trends.
- Methodology for determination of energy banking charges for renewable energy based open access.
Please find below Ministry of Power's consultation paper and Prayas (Energy Group)'s comments on the same.