The Rajasthan DISCOMs have filed petitions for the determination of ARR and tariffs for the year FY20. As the average cost of supply is projected to be Rs. 8.45/kWh the DISCOMs are proposing to raise tariffs by 11.82% on an average. This would entail a significant increase in fixed charges for most consumers. Such a step would make tariffs inequitably high for small consumers and further incentivise commercial and industrial consumers to invest in captive options and reduce their dependence on the DISCOMs. The DISCOMs are facing a financial crisis with cumulative revenue gaps in excess of Rs. 36,000 crores since the launch of UDAY . Further, the working capital borrowings of the DISCOMs is also upwards of Rs. 24,000 crores. Given such strained finances, risk of losing cross subsidy revenue, the tariff design should be such as to protect the interest of small consumers while ensuring recovery for the DISCOMs. Given the unsustainably high average cost of supply, sales migration to more competitive supply options by larger consumers is inevitable. The regulatory commission can reduce the power procurement and investment planning risk faced by DISCOMs by ensuring these consumers reduce their dependence for longer durations bringing in more certainty in demand. This could also help potentially reduce the average cost of supply in the future. Our comments and suggestions outlined in the submission are made in this context and focus on planning,  tariff design, implementation of ToD metering, need for revision in methodology for estimating  metered and unmetered agricultural demand and revision of sales migration charges.