Sales migration in India has steadily grown in the last five years, driven by open access and captive consumption. While states such as Maharashtra, Rajasthan, Karnataka and Tamil Nadu witnessed this steady growth, the open access consumption in Madhya Pradesh has remained considerably lesser in comparison. Despite this, it is important to note that rapidly falling prices of renewable energy-based generation sources will continue to incentivise consumers to migrate. Therefore, the proposed draft of Madhya Pradesh Electricity Regulatory Commission (Terms and Conditions for Intra-State Open Access in Madhya Pradesh) Regulations, (Revision-I) 2021 is a very welcome initiative. Some positive proposals include a willingness to reduce the eligibility for open access consumers to less than 1 MW in the near future, detailed application procedure and a prescribed time schedule for processing the same, and maintaining a separate head of account for revenue earned from short-term open access consumers to be used for strengthening of the distribution system. There are areas where more clarity is needed to ensure smoother implementation and areas where additional changes are recommended. Key suggestions include:
- Lowering the eligibility barrier for open access to 500 kW at present
- Dedicated web portal for online application and payment
- Penalties for the nodal agency in case of delays in processing applications
- The Committee to have at least one independent member apart from respective members from SLDC, STU and Commission
- Medium-term certainty in open access charges, progressive increases in short-term open access (STOA) charges for wheeling and transmission, a ceiling of 2.5 rupees per unit for total open access charges (CSS+AS)
- Enabling provisions to aid participation in G-TAM and RTM
- Treatment of over-injection/under-injection by deemed open access and captive consumers
- Specific measures to utilise the revenue from STOA consumers
- Five-year validity for these regulations