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(ON YOUR LETTERHEAD)

Date :
To,
Secretary,
Maharashtra Electricity Regulatory Commission,
13th Floor, World Trade Centre, Centre No 1,
CUFFE PARADE, MUMBAI 400005
SUB: Objections and suggestions as invited by MSEDCL in compliance of the Hon’ble Commission’s directions in case no 217 of 2024

Dear Sir,
We would like to file our comments as under
1. Revised ToD timing :
a. We would request to maintain the old time slots and make changes in the tariff structure
b. Maintain off peak time zone as per earlier time slot i.e. 10 PM to 6 AM and allow power adjustment in the night hrs also.
2. Revised Telescopic Billing :
a. DISCOM has not invested in the solar installation within the premises and as such they have no right on the power produced by the same. As such power generated and consumed should not be accounted for the monthly consumption of prosumer.
b. DISCOM should only raise bill for the power supplied by them as per the approved tariff slabs.
3. Grid Support Charges :
a. Formula for GSC calculations given by MERC refers only to the power exported and not generated. As such if GSC is charged , it should only be on exported units and not generated units.
b. In MYT petition (case 322 ) 2019 has shown losses of 12% on LT and 7.5% on HT consumers and the same are compensated by way on banking charges hence no more charge payable under GSC now.
c. GSC is only applicable from 10 kw to 999 kw and large power plants are not charges with GCS hence it is discriminatory. This should be scrapped.
4. KVAH Billing for LT Consumers :
a. Small LT consumers with sanctioned load from 20 kva to 100 kva are large in numbers and the technical skills at such consumers is very less. It is very difficult for them to maintain power factor above 0.95. Putting APFC at such small loads is also difficult. Hence KWH billing should continue for LT consumers.
b. More difficult is the case with LT domestic category. Hence LT billing should continue on KWH only.
We request you pass orders in the public interest and oblige.
Yours faithfully
For ______________

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