Andhra Pradesh DISCOMs filed a petition to review Commission's tariff order for the year FY21. The petition focusses on review of APERC's decisions with respect to the treatment of renewable energy in power purchase projections, observations on the variable nature of RE and the must run incetive proposed by the DISCOMs. Our submission in the matter contends that the DISCOMs do not have sufficient grounds for review in many matters. Having said that, our submission also highlights that prompt and prudent action would be required from the Commission to manages certain challenges with increased RE procurement and the financial distress facing the DISCOMs. These are necessary actions for sector development and are not limited to this review petition. Some of these actions include:

• amendment to forecasting and scheduling (F&S) regulations after wide public consultation keeping in mind RE development in the state;
• tracking the status of REMC in APSLDC and seeking periodic reports to track implementation of F&S regulations
• levy of quarterly fuel adjustment charges to enable recovery of prudent costs in a periodic manner
• revision of APERC regulations to compensate generators for heat rate degradation/ auxiliary consumption increase due to part load operation
• timely approval for short-term power procurement from various sources with adequate prudence checks
• detailed scrutiny of power procurement costs, unmetered agricultural sales, revenue impact due to sales migration and impact of backing down during true-up process
• reviewing plans and providing policy advice in the light of 10 GW of solar capacity addition planned by GoAP to meet agricultural demand.