TNERC invited public comments on its draft amendment to the terms and conditions for determination of Tariff Regulations. The amendment was to enable separate ARR filings for the SLDC. While such a crucial step is important to ensure independent operations of the SLDC, our submission also suggests a more consolidated revision of tariff regulations such that the tariff determination process is clearly detailed and the process is reflective of the changes in the state and the sector. Some suggestions offered towards this end were as follows:

• Extend the Multi Year Tariff control period from three years to five years to ensure medium term planning and accountability of performance parameters
• Define the specific norm for each year of the Control Period to be met for performance parameters such as availability, plant load factor, station heat rate, transit loss, distribution loss, auxiliary consumption, operation and maintenance, etc., in the tariff regulations itself
• Require the DISCOM to provide base and peak demand estimation and a corresponding power procurement and capacity addition plan for the next ten years on a rolling basis
• Outline the principle and mechanism for the determination of additional surcharge and wheeling charge for open access consumers
• Specify data formats in which the licensee must report data pertaining to sales and performance