Prayas (Energy Group) has submitted comments on Adani Electricity Mumbai Limited's (AEML) application to modify its distribution license to include parts of Dharavi Re-Development Area—a 2.5 square kilometer area currently served by two distribution licensees: BEST and TPC-D. The area is undergoing large-scale redevelopment where existing infrastructure will be demolished. 

The operation of three parallel distribution licensees poses significant risks: cherry-picking of consumers, network duplication challenges and increased complexity in power procurement planning. PEG urges the Commission to avoid allowing multiple distribution licensees within the same area of supply, which will result in sub-optimal outcomes. Instead, we propose conducting a competitive bidding process where all interested licensees (existing and new) submit bids for wheeling charges for 15 years. The bids should cover capital works, network rollout plans, and O&M expenses. The entity with the lowest wheeling charges is awarded the licence is the area subject to network costs being capped at bid levels  and not subject to "cost-plus" treatment. This approach would ensure competitive wheeling charges for consumers, avoid legal disputes around network rollout, prevent network duplication, and eliminate cherry-picking risks.