Please refer to the MoP notice dated 09 Oct by which the last date for submission of comments on Subject cited matter has been extended to 12 Oct. AIPEF had requested for extending date to 31 March 2021 . The date of 12Oct is not agreed to  on account of the following.

1. MoP has not explained anywhere why it is rushing ahead with Privatising Distribution  while not giving sufficient time to stakeholders for comments.

2.   States have the Constitutional right to decide on Distribution structure as Electricity is a Concurrent subject . Any proposal by the MoP that goes against the Constitution has to be legally examined which necessarily requires time.

3.   MoP is trying to rush through a proposal that lacks not only Constitutional Validity but also merit and denying adequate time for detailed reply on merits.

4.   Previous experiments on privatization which failed miserably require detailed study and analysis for purpose of analysis/comments. Giving inadequate time will deny us the opportunity to submit detailed comments on the basis of past experience.

5.   MoP has made a fundamental error of first directing UTs to privatise and then after several months delay issuing S B D s . This anomalous situation also requires analysis  for which extra time is required.  This is a classic situation where two wrongs do not make a right.

6.  The concept of competitive bidding  for Distribution  is not compatible either with sec 63 or any other section of E Act 2003 . This legal issue requires legal study for which time is required.

On account of above factors and other issues raised earlier AIPEF again requests that  time for comments/objections may be extended to 31 March 2021.

Thank you with regards.

Yours sincerely

Shailendra Dubey

Chairman