The Maharashtra Electricity Regulatory Commission (MERC or Commission) issued a notice inviting comments from the public on its proposed draft Multi Year Tariff (MYT) Regulations, 2015. The broad objectives of MYT exercise is to facilitate better planning and thereby allow for greater certainty regarding both, tariffs and costs. If implemented properly, this should help to identify certain important areas of concern as well as improvement. However, the experience of past MYT implementation does not boost confidence in this regard. The attached submission while highlighting key lacunae in the past and proposed MYT regulations, argues for the following:

• Co-relating MYT exercise with supply & service quality and financial performance of the utility, benefits of which should accrue to consumers in the form of predictable costs and reliable service
• Stronger provisions to demonstrate commitment to transparency, accountability and public participation
• Better mechanism for regulating fuel cost and power purchase expenses
• Better tracking and monitoring of crucial data and
• Suggestions for dealing with the impending crisis that Mahadiscom and its small consumers are likely to face.