CERC published a staff paper on the mehanism for compensation on account of Change in Law for compliance with the Revised Emission standards notified by the MoEFCC, with respect to Competitively Bid Thermal generating stations, and invited comments on the same. Prayas submitted suggestions towards better implementation of the suggested mechanism for Section 63 plants, which included that:

  1. The compensation should be subject to timely adherence to the revised norms, as per the MoEFCC deadline
  2. The compensation should only be allowed if the Emission Control System (ECS) has been operational for a minimum threshold duration
  3. In addition to the mentioned eligibility criteria, the compensation mechanism should only apply to generating stations with PPA cut-off date before 7th December 2017, and to generating station's whose environment clearance does not already mandate ECS installation
  4. Compensation should also be allowed for alternate methods (other than ECS) of compliance to the revised environmental norms

The suggested mechanism also includes some progressive provisions which benefit electricity consumers.