In continuation of All India Power Engineers' Federation comments to subject cited documents, we wish to submit further comments and documents which may be considered as our additional comments to Ministry of Power
1. Article in Economic & Political Weekly, Mumbai, dated 10th October 2020
1.1 The article titled Electricity (amendment) Bill 220 “inviting a bigger crisis” in by three faculty members of National Institute of Advanced Studies, Bengaluru. This article while dealing with Electricity (Amendment) Bill 2020 also deals with Privatisation of distribution.
1.2 The following portion of Article is quoted as they directly related to Privatization of Distribution.
QUOTE “EXPENSIVE ‘MUST-RUN’ RENEWABLE ENERGY
The miscalculated demand growth forecast is however only one of the problems. The other reason is that there has been a significant increase in the flow of RE into the grid, especially solar energy, in the last few years. This increase is based on chasing centrally determined targets for RE and not on a scientific study of whether that much energy is required, given newly commissioned and planned thermal capacity. While RE technologies were new and more expensive some years back and special incentives were needed to absorb them into the grid at that time, these incentives remain in place although costs for new plants have reduced significantly. For example, solar and wind energy plants enjoy a “must-run” status as per the central government’s Grid Code, which is mandatory for all states, that is, all energy produced by solar and wind energy plants must be absorbed by the DISCOMs, irrespective of its cost.
Thus, it is the central government’s must-run directive to the states through the CERC, mandating a higher share for solar and wind power into their respective grids that have led to higher power procurement costs for the DISCOMs. The DISCOMs in South India have been particularly affected by this since they were at the forefront of inviting and incentivising private capital in high-priced RE because of their natural resource ¬advantage. For example, in Tamil Nadu, about 15%–30% of the total energy is being supplied by wind and solar energy plants depending on the month. While wind ¬energy is cheaper, the average cost of solar power in Tamil Nadu is more than 6/kWh, about 50% higher than the average cost of thermal power in the state. While newer solar plants are relatively cheaper, the DISCOMs are still bound by high-cost PPAs signed with RE developers before 2016.2 This has meant lower and slower cost recovery for the producers on the one hand (at least in cases where long-term PPAs do not exist) and higher power procurement costs for DISCOMs, even when lower-cost power is available.
Again, it was the CEA’s inflated demand projections that led the DISCOMs to enter into long-term PPAs with both thermal and renewable generators. The combined impact of high power purchase costs under the old RE contracts and fixed cost compensation to thermal generators (with PPAs) in the face of low demand growth is solely attributable to the policies of the two central agencies for which the DISCOMs are now being held ¬accountable.
The high cost of power procurement will continue in the ¬future unless there is a change in the status afforded to RE plants or a reduction in variable costs of existing plants, which would require a reduction in the cost of coal. Neither is likely in the immediate future with or without the Electricity (Amendment) Bill of 2020. It is not clear how the situation will be different for these new distribution sub-licensees unless they are given special concessions, not awarded to the DISCOMs. For example, it is possible that a distribution sub-licensee, free of any obligation of older contracts that the DISCOM is bound by, purchases newer low-cost solar power leaving the DISCOMs with high-priced RE from older renewable plants as well as fixed costs of thermal plants with whom it has signed PPAs.”
QUOTE “COST OF OPERATION
The second claim for promoting private sub-licensees in electricity distribution is to reduce the cost of operation, that is, reduce the aggregate technical and commercial losses. For this to be possible, two things are needed. First, an improvement in billing and collection efficiency and second, an investment in distribution infrastructure such as transformers, and low-voltage distribution lines.
In November 2015, the central government introduced the Ujwal DISCOM Assurance Yojana (UDAY) mainly to enable the DISCOMs to reduce their aggregate technical and commercial (AT&C) losses as well as reduce the gap between the average cost of supply (ACS) and the average revenue realised (ARR). According to the MOP (2020), the overall AT&C loss and ACS–ARR gap for 26 UDAY states and seven union territories for financial year (FY) 2016–17 were 23.96% and 48 paise per unit, respectively which has reduced to 18.19% and 27 paise per unit, respectively in FY 2019–20. The remarkable improvement of 29% in the AT&C losses and 44% reduction in ACS–ARR gap in just three years (FY 2016–17 to FY 2019–20) indicates how most DISCOMs in India have improved their operational performance while 16 state governments have also taken over 75% of the outstanding debt of the DISCOMs as on 30 September 2015 (MOP 2019). There is no doubt that these 16 states, which have cumulatively taken on a debt of more than 2.08 lakh crore, have indeed supported these DISCOMs to reduce their interest costs and improve their credit ratings. Therefore, the claim that only privatisation will succeed in such a vital sector is patently false to begin with.
The privatisation of the DISCOMs and the introduction of new private electricity distributors in the form of franchisees have been tried in the past and have largely been unsuccessful. DISCOMs were not only separated from the erstwhile state electricity boards and made into companies, but in many states they were also segregated regionally to make them operationally smaller and more manageable to facilitate privatisation. However, private distributors were only interested in urban clusters with bulk consumers. And even in these, while improvements in billing efficiency were seen in some areas, franchisees were unable and/or unwilling to invest large amounts of money on infrastructure as the profit margins would inevitably be too narrow.”
QUOTE “PRIVATISATION, DISTRIBUTION FRANCHISEES AND THEIR PITFALLS
Other than Odisha, Delhi, and Mumbai, no other state’s utility could be privatised. In Andhra Pradesh, attempts of the then incumbent political party (the Telugu Desam Party) to privatise the sector since 1996 were met with widespread protests eventually costing the party the subsequent elections (Suri 2013). Mumbai is an island city, with no agricultural consumption, making it much easier to manage, but the experience of privatised electricity distribution there has also been problematic with frequent protests against continuous increases in tariffs (Nair 2018; PTI 2009). In Odisha, after years of failed ¬attempts to manage the sector, and three failed attempts at private management, electricity distribution has reverted to the state (Mahalingam 2002; Dubash et al 2018). The experience in Odisha has demonstrated that this experiment in a ¬region with a diverse set of consumers, largely rural, and a smaller industrial consumer base, has been a dismal failure. In Delhi, privatisation had to be propped up with generous handouts from the taxpayer, far in excess of what was initially proposed. And despite this, and the advantage of a non-agrarian consumer base, privatisation only partially succeeded in redu¬cing power procurement costs but failed in transferring those benefits to consumers (Dubash and Rao 2006; Singh 2005).
When privatisation did not work, the model of distribution franchisees was introduced, where the state-run utilities would subcontract a section of the network to private companies or other agencies, much like what is proposed now. These subcontractors were expected to improve the losses and collection of bill payments in these regions, something the distribution utilities had been unable to do. However, after it was first introduced many years back, this model could be employed only in a few regions where agriculture consumption was low, for example, in Bhiwandi, Agra and Ahmedabad. Even in these regions, this model has had a sketchy experience (Thakur et al 2017; Chitnis et al 2009). The experience of distribution franchisees shows that while some billing and collection efficiencies could be addressed by the franchisees, reducing technical losses would require significant capital expenditure which, without the ability to pass on to consumers, the franchisee will have no incentive to undertake. The grand plans of encouraging rural franchisees came to a swift and quiet end some years back as private companies did not see profit in supplying electricity to a largely poor population unable to pay the full cost of electricity.
Therefore, even after cherry-picking only urban agglomerations for franchising electricity supply, this model could not work. The character of electricity consumption in India itself is such that many consumers still cannot pay the full cost of electricity and for small- and medium-scale manufacturing units, especially in the informal sector, electricity constitutes a significant proportion of input costs. Large consumers have exited the grid because of the open access policies introduced by the central government in the Electricity Act, 2003, making their own arrangements for cheaper electricity supply. Therefore, distribution companies do not even have the benefit of consumers who can pay the full cost and more for electricity, such that the electricity supply business can be financially viable, if not profitable. In such a situation, undertaking capital expenditure to improve line losses also becomes an expensive proposition with no guarantee of equivalent returns.
The claim of privatisation improving efficiency and reducing costs is dependent on the assumption that there will be competition among different distributors who will then have an incentive to reduce costs. For a business with a wires ¬monopoly, this is a difficult proposition to begin with (Ranganathan 2005). The bid to introduce private sub-licensees in the form of franchisees at an earlier time has also been a failure in most cases, with either an inability to reduce costs, or an inability to transfer the cost reduction benefits to consumers. With the proposed amendment, it is reasonable to assume that history will repeat itself, with traders being interested only in areas where consumers can pay, that is, in cities, or areas within cities where poor consumers are at a minimum. This would mean that DISCOMs once again would be left with the poorest segment of consumers to serve, with no cross-subsidising consumers to be able to distribute the burden, or the ability to avail the option of cross-subsidies itself.
The changes that have been carried out so far in the sector have already been one of the main reasons for the current ¬financial crises of the DISCOMs. In many states, the regional breakdown of distribution utilities have also weakened them financially as they have been unable to depend on the economically advanced regions of the state to cover the losses from their economically backward counterparts. The new policy will only exacerbate the problem further.”
QUOTE “ IRRATIONAL ‘RATIONALISATION OF TARIFFS’
DISCOMs contend with large sections of consumers who cannot pay the full cost of electricity, such as small and middle peasants, poor urban and rural domestic consumers, and even to an extent some household-based or small enterprises. They usually depend on charging higher tariffs to consumers with the ability to pay, that is, large industrial and commercial consumers, and use that revenue to cross-subsidise the poorer consumers.
However, the state’s ability to cross-subsidise has been curtailed by the centre over the years. The Electricity Act of 2003 itself mandated an “elimination of cross-subsidy,” which was later amended to a “progressive reduction in cross-subsidy.” What the New Electricity (Amendment) Bill, 2020 proposes is nothing less than a catastrophic game-changer, considering the ground realities in India. The amendments envisage that the SERCs will determine tariffs without allowing cross--subsidies which means, each category of consumer will pay what it costs to serve that category. State governments wishing to subsidise particular categories of consumers should do so through direct transfer of the subsidy amount into the beneficiary accounts through the DBT (direct benefit transfer) mechanism.
These proposals are acutely problematic. The most glaring impact of this would be to charge the steepest tariffs for rural consumers, for whom electricity supply entails long transmission and distribution lines, attendant line-losses and cost of various step-down transformers. Industrial consumers using high tension and extra high tension lines will have much lower costs to serve and hence their tariffs will be cheaper. This would be patently inequitable since electricity is not a luxury that rural consumers can do without, but a basic human necessity, and hence they would have to be supplied at affordable prices regardless of the costs to serve them.
Expecting the states to directly subsidise them is virtually asking for the impossible, considering the precarious state of state finances. On the one hand, with the implementation of the goods and services tax (GST), revenue streams of states have been squeezed and states are increasingly dependent on the centre for money which often does not get released on time (ET Bureau 2020). On the other hand, poor consumers—residential, agricultural, other categories of consumers (even amenity providers like public health centres and government schools)—form a significant proportion of electricity users in most states and cannot afford to pay high costs for electricity. To expect the state governments to foot both the subsidy and cross-subsidies directly and immediately is infeasible and ¬impractical, to say the least.
The inability to provide this basic necessity to households is likely to cost state-level representatives heavily. The central government while being responsible for the problem will however bear no responsibility for the consequences.
Besides, the DBT scheme is also not proven to be successful across sectors. Its administration in a data-scarce environment is difficult, and effective and timely delivery of benefits is a problem. In the case of the electricity sector, the transfers will be done by cash-strapped state governments and it is reasonable to assume that this will not happen on time, if at all. So the DISCOMs (and definitely the private sub-licensees) will either cut off the power supply to consumers who cannot pay on time or if they cannot do so for political reasons, the problem of under-recovery will not be solved in any case. If state DISCOMs cannot ensure the timely disbursal of subsidies from the state, how will individual consumers ensure the same? If tariff hikes can lead to protests in relatively higher income pockets of Mumbai, why will the same not play out across the country? Additional problems of households that live in rented premises where meters may be in someone else’s name further compound the problem. The old anti-subsidy ideological refrain in a new form is once again only likely to worsen the situation in the power sector.”
QUOTE “STATE–CENTRE RELATIONSHIP IN THE POWER SECTOR
Another major concern about this new bill is that it seeks to centralise control over the power sector more aggressively than ever attempted before. This has been happening in creeping doses over the years through central policies binding on states, but the slew of amendments proposed in the bill indicates the encroachment of the centre into the states’ domain, in contravention of the provisions of the Constitution.
First, the bill seeks to wrest the power of appointment of the chairperson and members of the SERCs from the state governments to vest it in a central selection committee controlled by the central government. The bill proposes that the selection committee—common for the CERC, Appellate Tribunal for Electricity (APTEL) and the proposed Contract Enforcement Authority—will be headed by a chairperson, a judge, to be nominated by the chief justice of the Supreme Court, two serving secretaries to the Government of India (GoI), one of whom would also be the convener of the -selection committee and two chief secretaries of state governments to be appointed in the alphabetical order of states (that is, Andhra Pradesh, Arunachal Pradesh will go first and so on), both for one year each. There are many problems with this arrangement. There is a conflict of interest in having the same committee select the chairpersons and members of all regulatory bodies in the power sector. Also, to those familiar with the ¬Indian bureaucratic hierarchy, it is clear who will call the shots when there is a tie between two serving secretaries to the Goi and two chief secretaries of states, the latter being junior to the former two. Thus, virtually the centre controls the selection of state regulators and could control regulatory decisions at the state level, seriously jeopardising regulatory independence. Regulatory literature is legion on the need for a robust and impartial selection process for the independence of regulatory institutions.
Second, the bill categorically fixes a time frame for state regulators to approve a tariff petition. If the SERC fails to fix tariffs within 60 days of receiving a tariff revision petition, the revision sought in the petition would be deemed to have been approved. Setting unrealistic time limits for the state commissions to fix tariffs, considering the tortuous process involved in the collation of documents and verification of financial claims by the utilities and following due procedures, including public consultation, is a draconian proposal which hits at the root of regulatory remit at the state level.
Third, the proposed amendments empower the regional load dispatch centres (regional LDC) to withhold dispatch of power to states unless payment for power is made in advance by the DISCOMs. This means that the national LDC which will have powers to direct state LDCs could deny scheduling power if the DISCOMs fail to put up payment security. This is clearly in the interest of private sector RE developers who can now arm-twist the DISCOMs which are already caught in the cleft between “must-run” renewables and idling costs of backed down thermal power. It is a catch-22 situation for the DISCOMs that face penalties if they do not offtake renewable power offered by the must-run generators and face financial ruin if they do.
Fourth, the power of the state commissions to adjudicate upon disputes pertaining to contracts is proposed to be taken away and vested in a new regulatory authority called the Electricity Contract Enforcement Authority, whose members and the chairperson will be selected by the same selection committee referred to above. Perhaps this move has been prompted by concerns expressed by the Chief Minister of Andhra Pradesh Y S Jaganmohan Reddy who contemplated reopening high-cost solar PPAs or by the Supreme Court order of 2017 which dismissed CERC’s order awarding compensatory tariff to two IPPs when their coal procurement costs went up consequent to a foreign government decision. Whatever the trigger, this binds the state governments even tighter into a debt spiral not all of which is their own making.
It is ironical that the central government that has saddled the states with PPAs incorporating infructuous idling charges for thermal plants not dispatched due to lower than estimated demand (by CEA, a central agency) and expensive renewable contracts fortified with must-run diktat, should now set up a well-armed regulator under its control to ensure that these ¬iniquitous contracts are enforced with strict penalties that would further cripple the already ailing state governments.”
QUOTE “CONCLUSIONS
The last 20 years have exposed the inefficiency of the central government in electricity planning, power sector financing, national tariff policy, and in developing an equitable national RE policy. The proposed amendments are nothing but a desperate attempt by the government to cover up the policy miscalculations of the past decades while simultaneously protecting the interests of power generators, both thermal and ¬renewable, at the cost of state distribution companies. The centralisation of powers envisaged in the proposed bill is ¬intended to penalise the state-owned DISCOMs for the faults of the central government and its agencies. The entire burden of the unrealistically ambitious renewable targets set ostensibly to please the international community is sought to be passed on to the states with the new regulatory authority wielding the stick to discipline them.
Therefore, the proposed amendments in the New Electricity (Amendment) Bill, 2020 are not only thoroughly anti-people, but they will also do nothing to stem the crises in the sector and will only accelerate its deterioration. In the era of climate change, energy transitions, and rapid economic changes, what is required is good integration between the production, transmission, and distribution segments of the sector. The need for robust planning at all levels of government and significant state intervention to ensure the expansion of access to affordable and reliable electricity to all segments of consumers cannot be emphasised enough. This cannot be done without the strong presence of the state government and other relevant state entities.
Given that the power sector and the economy as a whole face an immediate crisis in light of the COVID-19 pandemic and a long-term crisis because of unresolved issues, the government must hold off on passing any legislation hastily, especially when the states are busy fighting a more urgent battle against COVID-19. As we emerge from the more immediate crisis, wider consultation, and a more scientific and less ideological appro¬ach to deal with the travails of the power sector is urgently needed.”
1.3 AIPEF Comments : The subjects of high cost power (as against proposal of Ministry of Power to give subsidized power to private docosms), high cost of renewable RPO Power, pitfall of privatisation, tariff structure & conclusion have been dealt in our earlier comments. The above quoted sections of EPW article are to be considered along with our earlier comments.
2. Paper on Reform of the Power Sector Orissa by N. Sree Kumar
The paper (Attached) analyses various aspects of Orissa Reforms in Privatisation of Orissa with World Bank. Performance of discoms has been analyzed. The conclusion given at Sr. No. 5 are given as under.
(Quote)
“5. LESSONS AND ALTERNATIVES IN THE ALL-INDIA CONTEXT
Many states have used the 'Orissa Model' for reforming their power sectors. The reform act and many procedures were almost copied. After it became clear that the 'Orissa Model' has limitations, there has been some caution in blindly following it. However, reforms are being pursued vigorously, with 19 of the 28 states having established Regulatory Commissions and the Electricity Act 2003 enacted in June 2003. It is therefore important to look closely at the Orissa reform process to understand the positives and negatives. This could give some idea of the possible alternatives when reforming the power sector, for which there is an urgent need.
5.1 Criticism of the Reform Process
Non-Participatory and Hasty Process: The entire process of evolution and detailing of the model was completed in an extremely hasty manner. The process was conducted without any semblance of public debate or participation. Further, the model lacked the sound analytical basis that was necessary to address the techno-economic and institutional complexities of the sector. Projecting privatisation as the solution to distribution inefficiencies and pushing the privatisation process is a good case of this haste and lack of debate. As remarked by some, the reform model was not built through a consensus process; rather, consensus was sought over a prescribed reform model.
Sabotage-Prone Regulatory System: The regulatory system in this model is expected to play a critical role in discouraging non-competitive behaviour by market players. However, because of many lacunae - mainly inadequate and discretionary provisions for transparency, accountability, and public participation - these regulatory structures were prone to sabotage and high-jacking by strong market players. A detailed study of the proceedings of the commission and study of orders would prevent this happening any further.
Impact on Developmental Aspirations of the Disadvantaged: The vast majority of disadvantaged people in developing countries do not have access to electricity. The model treats electricity as a tradable commodity to be purchased, without subsidy, by those who can afford it. As a result, the model effectively puts severe constraints on the aspirations of disadvantaged areas that require electricity as a key input for their development but cannot afford to buy it at commercial prices. At a broad level, reports indicate that rural electrification efforts have slowed down. The impact of reforms on rural electrification and poor consumers needs to be assessed in field surveys.
Impact on Democratic Rights of Disadvantaged: By conceptualising electricity as a private good that market players should and can supply, the model takes this core developmental sector out of the realms of public affairs and of 'politics'. The model divests the state - which is somewhat amenable to political pressures by disadvantaged sections - of its control over the sector. Further, it substitutes the state with independent regulatory mechanisms that are technocratic and legalistic. This further marginalises the disadvantaged sections as they lack the techno-economic and legal capabilities necessary to influence the working of these regulatory institutions. Effectively, the model constrains democratic rights of the disadvantaged to influence decisions in a sector that involves critical societal interests.
5.2 Limitations of the World Bank Model/ Privatisation as the Solution
The state’s withdrawal from the sector and privatisation are key components of the World Bank model. It has been demonstrated that mere changes in the ownership of utilities will not empower the public to effectively challenge the powerful members of the unholy alliances controlling the sector. In fact, there is a danger that, with the entry of powerful corporations, the new and equally (if not more) powerful and equally unholy alliances of corporations, politicians, and bureaucrats might take over control of the sector’s governance. The situation after the entry of Enron and other IPPs has demonstrated that this apprehension is not ill-founded. Thus, the solution of privatisation does not effectively address the core malady haunting the sector, its governance crisis.
In a way, even the protagonists of privatisation acknowledge this. They agree to the need for stringent and independent regulation to keep in check the ‘non-competitive behaviour’ of private players, especially in view of the natural monopoly in the Indian power sector, which is likely to persist at least for some decades to come.
In this model, the regulation is to be independent of the state (i.e. from political interference) and ‘investor-friendly’. This is because the main objective guiding the design of the regulatory system in this scheme is to protect private players and investors from state "interference". Such a system will not automatically serve the purpose of protecting consumers, and the disadvantaged sections of the population in particular. This is mainly because such a system does not pay the necessary attention to the special needs of these sections. Neither does it emphasise creating space for these sections in the regulatory process and building their capabilities to utilise this space. This effectively excludes them from participating. Thus the new regulatory system becomes an unrestricted domain for investors and private players. Further, as our earlier study of the World Bank’s Orissa model demonstrates, the regulatory institutions in this model are severely prone to sabotage by powerful vested interests.
In short, neither privatisation nor the accompanying ‘independent’ regulation envisaged by the World Bank and its followers is geared to address and resolve the core malady plaguing the sector.
5.3 The Core Remedy: Democratisation of Sector Governance
According to our diagnosis, at the root of the financial and performance crises in the electricity sector lies the governance crisis manifested in the form of the take-over of the governance functions (decision making, implementation of decisions and regulation) by unholy alliances of powerful interests. Further, our diagnosis also suggests that at the root of this take-over of governance functions lies a lack of transparency, accountability, and public participation.
Thus in order to address the financial and performance crisis in a fundamental manner, we need to eliminate the control of the alliances of vested interests over the three governance functions. To be more precise, these requirements should be articulated as: complete transparency towards the public, direct accountability primarily not towards investors but towards the public and meaningful public participation in all three functions. This makes the process essentially ‘public-friendly’ as against the ‘investor-friendly’ process envisaged by the World Bank.
In other words, opening up the governance functions along these criteria is the core remedy for resolving the financial, performance, and governance crises besetting the sector. How would it eliminate these ills? It would bring about the direct and effective control of people, on the three governance functions and would thus help ensure that governance functions are geared to serve the public interest. This direct public control over the governance functions could be called “democratisation of governance”. Thus, as we saw earlier, the core remedy lies not in sector privatisation, but rather in the democratisation of the sector’s governance”. (Unquote).
2.1 AIPEF Comments The conclusion of this paper as given in Para 5.3 is most important, as under
“In other words, opening up the governance functions along these criteria is the core remedy for resolving the financial, performance, and governance crises besetting the sector”.
“Thus, as we saw earlier, the core remedy lies not in sector privatisation, but rather in the democratisation of the sector’s governance”.
3. The paper by Navroz K. Dubash presented at a workshop on the Politic of Necessity held at oxford, Septemebr 9-10, 2005, Titled “The New Regulatory Policies of Electricity in India : Independent, Embedded or Transacendent ? ” is attached and may be seen. The paper deals with analysis of regulatory functions in the electricity industry the following extracts of this paper are given as under, as a conclusion of the findings.
“CONCLUSION
India, and the electricity sector in particular, was certainly swept up in the larger enthusiasm for demonstrating hospitality to foreign investors during what Stiglitz has called the “Roaring Nineties.” Nudged along with the help of both carrot and stick by the World Bank, independent regulation was injected into the Indian political lifestream without much fuss or debate, through its operationalization in one poor, and relatively off-the-beaten-path state. The attempt to displace historically embedded politic relationships around which the sector was organized simply by overlaying a new, and relatively weak, institution quickly proved unrealistic as regulators displayed minds of their own. Ironically, from an investor-first perspective, the ideal solution quickly morphed from regulatory independence to more thorough subjugation of regulators to explicitly investor-friendly policy directives. In other words, there was a “right” and a “wrong” form of state capture”.
4 AIPEF Concluding remarks
The subject of privatization is of fundamental importance. To deal such a vast and important subject we have to examine past instances and how various authorities have been dealing and commenting thereon. In compiling these comments we have quoted extensively from various authorities who have extensively researched the subject of privatization of power, and analysed past instances . The papers submitted with these comments and quoted from are from Economic and Political Weekly, Prayas Energy Group, and National Institute of Public Finance and Policy. We believe that GOI must study and take guidance from these Papers which AIPEF is submitting as a part of its comments and response to MoP Standard Bidding Documents for privatizing Distribution. We believe that the authors of these papers have vast experience and knowledge in their respective fields and stress that GoI may consider their viewpoints as contained in the papers submitted.
Thank you with regards.
Sincerely Yours
Shailendra Dubey
Chairman
CC:
1. Sri Vishal Kapoor, MoP, New Delhi.
2. Sri Narender Singh, MoP, New Delhi.