Maharashtra State Power Generation Company Ltd (MSPGCL) filed a midterm review petition for the final true up of FY FY20, FY21 and FY22, provisional true up of FY23, and approval of revised tariff for FY24 and FY25. Given the issues discussed in the petition and towards prudent, efficient operations, Prayas (Energy Group) made a submission on the following:

• The unrealisitcally high growth claimed for coal-based generation for the remaining control period should be revised and realistic, analysis-based projections must be adopted. This could also result in signifcant savings in ARR.
• The projected need for expensive imported coal must be rexamined, as generation without any coal imports is still in excess of required generation, when realisitc growth rates are considered. Given sector trends, the need for such demand of imported coal is unsubstantiated.  
• The variation in GCV between loading and unloading continues to be high, and improving this condition is the responsibility of the generator itself as per the conditions of the generator's fuel supply agreements. Since little improvement has been seen despite provisions from the Commission, relaxations in coal quality beyond that in MERC's Regulations should be disallowed.
• Improvements in coal supply management through requiring entire ACQ entitlement, consideration of e-auction, and publishing of Fuel utilisation plan as required by regulation is recommended.
• In light of its impact on the generating company's finances and the Late Payment Surcharge Rules, recovery of dues from MSPGCL should be addressed through a dedicated public process.
• Cost approval for Gare Palma II should take place through a seperate public process, in which the MDO contract is also made available for public review. Given that it is a captive mine, costs approved should be capped at CIL notified price.
• MSPGCL should submit a detailed cost-benefit analysis of coal beneficiation, it is yet to do so despite being directed by the Commission during the MYT process.
• Age-based retirement of plants has been reconsidered, and Remaining Life Assessment and Renovation & Modernisation is being considered for old plants. Given the extent of impact, such decisions must be based on comprehensive analysis and related capitalisation must be subject to public review.
• Station-wise plans towards adherence to environmental norms and status of compliance must be regularly reported on the generator's website.
• Rigorous and diligent TVS with a wide variety of stakeholders is crucial and could have addressed many lacunae raised as part of this submission.
• With growing role of renewables, in order to ensure MSPGCL's relevance as a state generating company, MSPGCL should reconsider its business model to include cleaner technologies such as renewables and storage.

Additional submissions were also made in this matter.