The Ministry of Power on the 24th of August 2017  released a consultation paper to discuss issues pertaining to open access. This is a welcome initiative and provides a framework to all actors for a way forward to address issues with sales migration. In this context, Prayas (Energy Group) submitted comments and suggestions to the Ministry. Some comments and suggestions include:

1. Suggestions to ensure a phase-wise transition away from short term open access.
2. Widening the scope of the consultation paper to include captive sales migration.
3. DSM mechanism for distribution open access consumers to address scheduling issues.
4. Ensuring certainty in CSS and using CSS design to encourage long term open access.
5. Need for transition support for DISCOMs facing sales migration as CSS, Additional surcharge will not compensate for loss of revenue.
6. Suggestions for a process and methodology followed by SERCs to determine additional surcharge.
7. Designing standby charges to provide standby services and encourage open access consumers to find alternate standby options.
8. Phase-wise removal of concessions on cross subsidy surcharge, additional surcharge, wheeling and transmission charges in the absence of subsidy support to compensate DISCOM for costs incurred.
9. Need for innovative tariff solutions and comments on how increasing fixed charges will be counter-productive for the DISCOM in its efforts to prevent sales migration.
10. Need for data and information from open access consumers, generators, trading licensees, DISCOMs, ERCs, SLDCs to better understand and prepare for emerging trends.
11. Need for a market monitoring committee constituted by every ERC with experts and representatives of DISCOM, traders, SLDC, ERC, open access and captive generators and consumers which releases an annual report with inter-state and intra-state market trends.
12. Methodology for determination of energy banking charges for renewable energy based open access.

Please find below Ministry of Power's consultation paper and Prayas (Energy Group)'s comments on the same.