On 18th May 2012, Maharashtra Electricity Regulatory Commission (MERC) issued a public notice inviting suggestions/objections from all stakeholders regarding a Suo Motu proceeding on issues concerning Open Access (MERC case no 50 of 2012). By a letter dated 30th November 2011, the Ministry of Power, Government of India, has requested all state Electricity Regulatory Commissions to take necessary steps for immediately implementing the provisions relating to open access under the 2003 Act. The purpose of the Suo-motu proceeding is to develop an approach for implementing open access based on public consultation. In this context, Prayas has made the following submission which highlights areas of caution and also provides a possible framework, necessary for such a transition.