Madhya Pradesh Electricity Regulatory Commission (MPERC) called for public comments and suggestions on the tariff petition submitted by the Madhya Pradesh (MP) DISCOMs vide a public notice dated 31st May 2019. Prayas (Energy Group) comments and suggestions on the matter focus on:

1. Need to initiate crucial regulatory processes: MPERC has extended the control period of the Multi Year Tariff (MYT) regulations by one year for the current tariff determination process. To ensure certainty in costs, incentives for efficiency improvements and reduced risk for all stakeholders, it is important that the Multi Year Tariff process extends for a control period of 4-5 years. Thus the process for drafting regulations for the next control period should be initiated as soon as possible. Further, true-ups provide a true assessment of the financial predicament of the DISCOMs, success of efforts towards sale of surplus and impact due to delay in subsidy payments. True-ups have not taken place for the DISCOM for over four years and should be initiated before the next control period to assess the extent of financial stress and performance issues.
2. Need for tariff rationalisation to protect interest of small consumers: MP DISCOMs have proposed simplifying tariff design by removing separate categories for rural and urban consumers for all LV categories and merging various sub-categories. However, such measures should be be followed with efforts to ensure that rural consumers get the same quality of supply and service as urban consumers. Some suggestions to amend the MYT regulations and the Standards of Performance Regulations are proposed in this submission. MP DISCOMs have proposed  a tariff increase of about 11% for all consumers which could make power unaffordable for many and alternate options viable for some.  Some suggestions regarding tariff design to ensure affordability for small consumers are also detailed.
3. Need for re-assessment of agricultural consumption: While agricultural sales account for around 38% of the total sales, there seems to be lack of sufficient data to back the robustness of the Discoms’ sales projections. Given its financial implications and the relationship with distribution loss estimation, it is crucial that the commission initiate a study to assess agricultural consumption based on feeder input data and sample surveys. 
4. Need to increase accountability and clarity on rising power procurement costs: There has been a wide variation and sharp increase in power procurement cost from various sources in the recent past but the underlying reasons for this are not clear. Further, the status of compliance with MoEFCC norms as well as efforts for coal rationalisation is not documented. The Commission should ensure statutory compliance and track the reasons for varying trends in costs and performance.
   PEG submission on the matter can be found in the link below.