Maharashtra State Power Generation Company Ltd (MSPGCL) has filed a petition for true up of FY18 and FY19, provisional true up for FY20 and ARR for the 4th MYT Control Period (FY21-FY25). The petition along with copy of the public notice can be downloaded from here. Given the issues discussed in the petition, major submissions by Prayas (Energy Group) related to coal availability and quality, compliance to environmental norms, reporting and planning include:

• Coal tolling or Case IV bidding [allocation of coal meant for MSPGCL plants to Private Generating Stations] to be undertaken only after its necessity is establish and no costs on account of coal tolling is to be borne by consumer
• Procurement of coal through MoUs, e-auctions or imports to be disallowed based on issues with MSPGCLs assumptions on coal quality, projections for generation
• Disallow request by MSPGCL for relaxation on availability norms due to poor coal receipt as stated by MSPGCL and persistent water shortages
• Requirement for coal beneficiation to improve coal materialisation to be disallowed until details and cost-benefit analysis shows this is a prudent investment
• The petition underestimates fait accompli variable costs (such as transport costs) while projecting variable charges for the MYT period in the petition which needs to addressed by the ERC and the utility
• The Commission should ensure timely compliance to new environmental norms, failing which capital expenditure and capitalisation after FY22 is disallowed by the Commission
• Commission to initiate a suo-motu process for smooth commissioning of pollution control equipment
• Need for periodic reporting of developments on Gare Palma II and capacity in the pipeline
• MSPGCL to submit detailed of fuel utilisation plan in compliance with MYT regulations
• MSEDCL and the MSPGCL need to develop a joint action plan on management of surplus capacity with uncertain demand