The three Rajasthan DISCOMs have filed petitions under tha multi year tariff (MYT) petitons for FY22 to FY24. The DISCOMs have not proposed any tariff hike but have proposed measures to rationalise tariff. Further, even at proposed tariffs, the cumulative revenue gap before the DISCOMs at the end of FY21 is Rs. 68,600 crores which is slated to be recovered from consumers in future years. With no tariff increase, the revenue gap is slated to increase by another Rs. 13,000 crores in the MYT period. Thus, it is imperative that the utilities commit to measures to save a minimum average of Rs. 4000 crores in savings each year in the multi-year tariff period. These could be through measures to rationalise power procurement costs, reduce the cost of supply to agriculture through aggressive adoption of solar feeder, ensuring sustained and significant efforts for loss reduction by reassessing agricultural demand estimation and adopting equitable, risk sharing frameworks to enable sales migration. Some of these measures are also discussed in this submission. With the average cost of supply at Rs. 9.17/unit, it is crucial that measures to rationalise tariffs protect small consumers. However, measures proposed by the utilities adversely impact small consumers. The submission also discusses a few ideas to protect small consumers from undue tariff burden.

Key suggestions in the submission include:

• Need to initiate process for assessment of agricultural demand methodologies based on surveys and feeder level AMR/ AMI data
• Measures to solarise agricultural feeders under Kusum Component A and C
• Recalibrate ToD slots and ToD tariffs to account for daily and seasonal changes in load due accounting for RE availability
• Extending ToD tariff regime for consumers with connected load > 10 kW in a phase-wise manner
• Need for regulatory scrutiny and review of franchisees
• Suggestions for 3 tier PoC charges for captive consumers
• Rationalisation of domestic tariff and tariffs for small consumers to reduce extent of fixed charges
• Measures for regulatory accountability for quality of supply and service
• Accountability for subsidy payments
• Tariff design suggestions in the face of shrinking cross subsidy