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Comments and suggestions on TNERC draft amendment of Tariff Regulations 2021

Author(s): Prayas (Energy Group) Publication Date: April, 2021

TNERC invited public comments on its draft amendments to its Tariff Regulations. The proposed revision is being carried out to be consistent with, and account for better norms in the regulations of the central and other state electricity regulatory commissions. Such revision of the regulations is a positive step. PEG submitted some comments and suggestions towards better implementation and clarity of the suggested amendments and toward ensuring a robust power sector in the state. These suggestions include:

  • Ensuring changes in O&M expenses, such that they are linked to inflation calculated based on a composite method instead of current prescribed rates, and encourage improvements in efficiency.
  • Providing clarity on provision of bad and doubtful debts, regarding the change in level of such debt that can be written off and removal of suggested the provision of including subsequent payments as part of non tariff income.
  • The provision allowing compensation to any generating station directed by the SLDC that operates below the target plant availability factor but at/above technical minimum, is a positive step, but should extend to all generators operating in the state. Thus, it maybe better placed in the grid code, and referenced in the tariff regulations of the state.
  • Providing clarity on levy of usage-based wheeling charges.
  • Reporting by the utility must include details on fuel adjustment charges
  • Carrying out a clear seperation of accounts for the generation and distribution functions.
  • Preparing a mandate for annual submission of crucial operational and performance data.
  • Providing a consolidated MYT framework that includes a 5 year MYT period and specifies data formats for submission
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