Rajasthan Rajya Vidyut Utpadan Nigam Limited (RVUN) filed a petition for ARR approval for 2023-2024 and true up for 2021-2022. Given our regulatory engagement on similar matters in other states and towards prudent, efficient operations, Prayas (Energy Group) made a submission on the following:

• Toward transparency in operation and better stakeholder engagement in the tariff process, RVUN should submit data in accessible excel files, in formats as required by the RERC. ARR approval should be sought for the generating company, in addition to each generating station.
• Rigorous and diligent technical validation session with a wide variety of stakeholders (including consumer groups) is crucial toward early identification of error and lapses in the petition.
• A robust MYT process for the control period, instead of annual tariff determination, will provide regulatory clarity for all stakeholders, reduce process iterations for the utility and regulatory burden for the Commission, and enable improved operations.
• Preparation of a comprehensive fuel utilisation plan for the control period, and regular publishing of status of adherence to such a plan, is crucial toward ensuring optimum fuel utilisation, realising cost savings, and even planning for shortage scenarios.
• The unrealisitcally high growth claimed for coal-based generation for FY23 and FY24 should be revised and realistic, analysis-based projections must be adopted.
• In light of its impact on the generating company's finances and the Late Payment Surcharge Rules, recovery of dues from distribution companies should be addressed through public consultation on the matter.
• With growing renewables and to ensure RVUN's relevance as a state generating company, plans regarding expansion to include cleaner technologies such as renewables and storage must be considered and reported.
• Given the impact of coal quality on cost and operations of the generator, GCV at both loading and unloading should be tracked, and the GCV loss between the two must be limited, towards increasing generator accountability. The related regulation could also be amended to ensure prudence of coal cost.