MSEDCL has filed its petition for cost approvals and tariff determination for the 5th Control Period (FY26 to FY30). MSEDCL has projected a cost reduction in the future years primarily due to significant capacity addition such that 44% of the power procurement is met by renewable energy. To ensure effective grid integration of RE, MSEDCL has also proposed addition of storage capacity and a ToD tariff trajectory where off-peak rebates of about Rs.2/unit is provided during solar hours. All other ToD slots are considered peak periods with ToD surcharges. MSEDCL has also proposed a reduction in tariffs for some categories, especially small domestic.  In addition, MSEDCL has proposed a slew of rebates to encourage consumption from the DISCOM. It has proposed several changes in existing charges and frameworks for open access, captive and net metering consumers. Some of our comments and suggestions relate to increasing accountability for DISCOM performance and efficiency. Examples include: 

1. Consideration of power procurement costs, especially the variable cost for thermal power plants in the control period.
2. Deficiencies and issues with the Resource Adequacy Plan submitted by MSEDCL
3. Methodological issues with Agricultural Demand Estimation by MSEDCL for FY23 and FY24 as well as projections till FY30
4. Distribution Loss reduction targets to be set by MERC till 2030 to ensure benefits of accurate metering, capital investments and increased O&M translate to loss reduction
5. Regular monitoring of fullfilment of RDSS conditionalities as it will impact capex requirement. Similarly tracking of RE capacity addition progress, RE CUFs to ensure power procurement costs are as projected. 

Other comments are relate to charges for various services provided by the DISCOM and proposed tariffs. Some examples include: 

1. Introduction of Grid Support Charges from a pre-defined effective date of 1st April 2027.
2. For green open access and net metering consumers, allowing off-peak to peak ToD slot banking with payment of banking charges of about Rs. 3.5/unit of energy unbanked.
3. Exempting consumers below 10 kW who opt for ToD from ToD slot-wise banking restrictions and charges. Also exempting domestic net metering consumers with load less than 2 kW from different telescopic energy charges as proposed by MSEDCL.
4. Increasing day-time ToD rebates to Rs.3/unit by 2030 and introducing seasonal variation in ToD.

We also have comments on addressing several implementation challenges related to green open access, smart metering and net metering so that consumers benefit from these provisions. 

Our comments and suggestions are towards increasing performance accountability of MSEDCL and introducing measures for cost-reflective pricing for various services provided by MSEDCL for consumers availing net metering, open access and captive and to protect interest of small consumers. This is all to ensure that the proposal for reducing costs over the control period and integrating significant RE capacity becomes a reality and meets the states developmental, fiscal goals.