Tata Power Co. Ltd (TPC-D) and Adani Electricity Mumbai Ltd (AEML) have submitted Multi-Year Tariff petitions for Truing Up of FY 2022-23 and FY 2023- 24, Provisional Truing Up for FY 2024-25 and approval of ARR and Tariff for FY 2025-26 to FY 2029-30. The Public Notice invites comments and suggestions on the same. TPC-D and AEML are parallel licensees and supply electricity in a common area of supply of Mumbai. The recent MERC MYT Regulations 2024 provide a methodology and the scenarios which are conducive for implementation of ceiling tariffs in case of parallel licensees.

We strongly believe that in case ceiling tariff approach is to be implemented anywhere, it should be first implemented in Mumbai since it has well developed distribution network and both licensees are operating as parallel licensees for several years.

This approach will also ensure that any issues and challenges that may arise in the implementation of a ceiling tariff are tested out in a more mature distribution system such as Mumbai before even considering for other parts of Maharashtra. Further, it is important to note that while parallel licensing will increase consumer choice, it will not be limited to the same and should extend to other options such as open access, captive and grid interactive RE.

Accordingly, we recommend the following to the Commission -

• Provide detailed operational guidelines on ceiling tariffs in Mumbai as part of the MYT Tariff Order for the ensuing Control Period,
• Appoint a working group/committee to monitor progress and highlight implementation aspects which monitor progress and highlight implementation aspects which need to be addressed in a timely manner,
• To not introduce ceiling tariff in other parts of Maharashtra until it has been implemented and is operational in a smooth manner in Mumbai,
• Address operational and procedural challenges in availing open access, net metering options in Mumbai and publish detailed data regularly (every 6 months) on the number of applications received and rejected for open access, captive and grid interactive RE.