The Central Electricity Regulatory Commission has published draft regulations on the Terms and Conditions of Tariff for the period April 1, 2014 to March 31, 2019. On 6th December 2013, it issued a public notice inviting comments, suggestions and objections to the draft regulations. Attached below are the comments and suggestions in this regard submitted by Prayas Energy Group.

Our comments are focused on three main issues: (1) norms for heat rates and the need to improve the performance of coal power plants; (2) the equity base (gross or net) on which return should be calculated; and (3) asymmetric distribution of hydrological risk for hydro-electric power plants. The entire submission can be downloaded by clicking on the link below. Our submission regarding the approach paper published in this regard can be downloaded from here.