Multiple companies and one LLP have applied for parallel licenses in different areas across Maharashtra in FY23 and FY25. These include Navi Mumbai, Palghar, Vashi, Thane and adjoining areas, Pune, Nashik, Chhatrapati Sambhaji Nagar, Nagpur Municipal Corporation and adjoining areas, and Solapur Municipal Corporation. These proposed areas constitute about half of the total MSEDCL sales and 2/3rd of MSEDCL HT sales in Maharashtra. After almost 2 years of the initial filing, the Commission has issued public notices on 23 June 2025 prima facie accepting and admitting the initial applicants qualify for grant of parallel licenses. The Commission has also issued public notices on 24 June 2025 and 20 October 2025 and inviting comments and objections to the fresh applications filed in FY25. The present submission is in response to these public notices. 

The submission argues that grant of parallel licenses is premature and unwarranted given the far-reaching implications on the development of the sector. In our previous submissions (here and here), on this issue, we had raised several critical issues which are not yet addressed. These include network rollout and power procurement decisions accounting for significant cost burden and investment lock-ins which will be passed on to consumers in a cost-plus framework. Without consideration and clarity provided for several aspects and clear frameworks for operation of multiple distribution licensees in parallel, there could be underutilization of assets, resource lock in due to poor planning and cherry picking of consumers. This parallel licensing proposal also poses financial risks for MSEDCL in recovery of its regulatory assets, demand projections and RA plan which is already approved by the Commission. Furthermore, the new MYT regulations which introduce the concept of 'ceiling tariffs' has resulted in more uncertainty as highlighted in our previous submission.. The utilities also recognised the difficulties with this ceiling tariffs approach as detailed in the present submission. The applications and data gap responses to the Commission and objections are deficient and fail to address the concerns and challenges raised such as financial estimations, justifications and assumptions made for demand projections and power procurement planning and timeline for meeting universal supply obligations. Considering all these factors, the submission urges the Commission to reject all applications for parallel licenses and explore other avenues of introducing competition in the sector, such as, operationalization of green open access in letter and spirit, undertaking competitive bidding like approach to strengthen sub-transmission network and improving O&M of the same.