The Central Electricity Regulatory Commission (henceforth the Commission or the CERC) published the draft notification on the second amendment to the Multi Year Tariff (MYT) Regulations on 1st December 2025, and invited public comments on the same. The draft amendment includes revisions to provisions with regard to Integrated mines and the inclusion of Energy Storage Systems (ESS) with thermal power plants and transmission licensees.

Prayas (Energy Group)'s submission was aimed towards improving clarity, efficiency and prudence, and included the following:

• Publish an explanatory memorandum to ensure reasoned public engagement
• Provide clarity with regard to the operational and legal implications of co-locating ESS with thermal power plants, ensuring that ESS is separate from the TPP
• Ensure that co-located ESS, additional to existing capacity is only considered if demand for such capacity is beneficiary led with requisite regulatory approval
• Mandate that ESS projects should only be considered through the Tariff Based Competitive Bidding route
• Disallow consideration of prices of alternative coal sources without clarity on permissibile alternatives, which should be limited to domestic sources 

With the explanatory memorandum being made available, Prayas (Energy Group) also made an additional submission on the matter, which included the following inputs:

• On the co-location of BESS with TPPs, it must be ensured that BESS addition is system operator/procurer led, contingent on cost-benfit analysis, and only considered through the Tariff Based Competitive Bidding route
• Incentives for production of coal from integrated mines at any level should be disallowed
• Ensure accountability and transparency safeguards for entities participating in the regulatory sandbox