The proposed regulations replace existing guidelines in the matter and  provide a comprehensive framework which  is integral in ensuring that major capital investments go through appropriate prudence checks. Many aspects of the proposed regulations such as indicative lists for what qualifies to be capex scheme, specific data formats, codified asset replacement procedure, treatment of sister concerns or group companies in competitive bidding processes and having a web-based portal for approval and tracking major capital investment projects are welcome.

However, with the significant investments expected in the future especially with transition related techno-economic changes, it is crucial that the regulations clearly specify, reiterate and codify the critical role of the commission in approval of investment plans, selection of appropriate investments, monitoring of capitalization and post-facto impact assessment. Transparent sharing of information and public consultation would also need to be emphasised given the impact on tariff, cost of supply and supply and service quality to consumers.

In this context, this submission provides comments and suggestions on provisions where more clarity is needed or some measures that could be further improved.