The Telangana Electricity Regulatory Commission (TGERC or the Commission) notified the draft Resource Adequacy (RA) regulations, 2025 on 15th November 2025, and invited comments on the same. These regulations provide a framework for Telangana DISCOMs to plan their power procurement in a cost-optimal manner while taking cognizance of available technologies, given the cost reductions in standalone BESS by ~75% since 2022 and the emergence of cost competitive Solar+ESS and FDRE contracts to provide close to round-the clock supply, as well as changes in demand. We welcome the publication of these draft regulations which has incorporated the following forward-looking frameworks:

1. Requiring distribution licensees to develop and prepare long-term 10 year rolling RA plans.
2. Requiring distribution licensees to constitute a dedicated planning cell for Resource Adequacy within three months of the notification of these regulations.
3. Introducing demand response measures as a potential supply resource to meet distribution licensee resource adequacy requirement.

Considering these, Prayas (Energy Group)'s comments and suggestions highlight areas where more clarity is needed to enable a smooth rollout of implementation of the RA regulations. In addition, we suggest certain changes towards ensuring a robust and transparent resource planning and cost-effective power procurement as highlighted below:

1. Strengthening effective demand forecasting for multiple time horizons by preferable having 15-min block-wise forecasting and ensuring that demand is not forecasted based on a single historical CAGR.  
2. The need for levy of penalties for non-compliance to resource adequacy requirement after a trial period (1 - 2 years) of capacity building and training during which no penalties are levied.  
3. Harmony between resource adequacy regulations and existing regulatory frameworks for power procurement including MYT regulations 2023, TGERC approved resource and business plans for Telagana DISCOMs, TRANSCO and GENCO, Government of Telangana Clean and Green Energy Policy 2025 and Renewalble Purchase Obligation Regulations of TGERC and orders of the MoP.
4. Clarity over responsibilities and timelines.
5. Leveraging wider sector expertise in the country to finalise RA studies and procurement plans.
6. Ensuring that RA studies and power procurement plans are approved via a transparent public hearing as part of the tariff regulatory process. Additionally, ensure that the demand forecasts, sales forecasts, power purchase costs, T&D loss trajectory and all assumptions used as part of the RA process are consistent with those used for the approval of Distribution licensee aggragate revenue requirement.  
7. Clarity on the definitions and implementation of Resource Adequacy Requirement and Planning Reserve Margin
8. Need for a more robust capacity creding framework and experimenting with effective load carrying capability (ELCC) methodologies.
9. Nature and allowability of contracts and power procurement.
10. Need for enhanced transparency.
11. Ensure that the requisite explanatory memorandum is published along with any draft regulations. Also ensure that the record of proceedings is published along with the TGERC resource adequacy regulations once it is notified.