The Maharashtra Electricity Regulatory Commission (MERC) has published draft Electricity Supply Code and Standards of Performance of Distribution Licensees including Power Quality Regulations, 2020 for public comments. These new regulations will replace the Electricity Supply Code and Other Conditions of Supply Regulations, 2005 and Standards of Performance of Distribution Licensees, Period for Giving Supply and Determination of Compensation Regulations, 2014.

Prayas (Energy Group) submitted comments and suggestions towards ensuring the accountability of Distribution Companies and enhancing consumer interests. In these draft regulations, some positive measures such as data privacy of smart meters, automatic compensation for certain parameters, provision for greater details in consumer bills have been introduced. But some other measures could be improved, such as upward revision of compensation amounts for violation of standards of performance. Some other comments and suggestions from the submission have been highlighted below:

• Performance standards and supply and service quality:

- Periodic revision of performance standards through consultative processes
- Reduction of gap between rural and urban performance standards
- Tracking of reliability of supply at feeder level and for different consumer categories

• Compensation payment for violating standards of performance:

- Compensation rates to have automatic upward revision and no ceiling should be provided on such rates
- Removal of eligibility criteria for receiving automatic compensation
- Need for reporting formats for automatic compensation payments

• Provisions for connections and disconnections:

- Assistance kiosks need to be instituted in DISCOM offices to help new applicants fill out online applications for new connections
- DISCOMs should conduct surveys in their service areas to determine norms for sanctioned load and diversity factor for new connections- only minimum limit should be mentioned in regulations and such regulations should not curtail consumers’ freedom to choose

• Concerns regarding metering and billing:

- Smart meter roll-out plans only after approval of capitalisation plans by MERC
- Data privacy and anonymisation of smart meter data before being hosted on websites or shared with third parties
- Burnt meter costs to be borne by licensees when cause is attributed to them

• Public review of quality of supply and standards of performance:

- Based on third party audits of standards of performance reports, Commission to conduct public consultation process
- Automatic compensation cases can be discussed at public hearings

• Accountability for force majeure events:

- Based on field verification, licensees should issue public notices, clearly specifying the intended date for resuming services. If services are not fully resumed within such time, consumers should be compensated for the same.
- Consumers should not be billed during disruption of service

• Need for reporting electrical accidents:

- Accident details to be part of standards of performance reports