HERC: reject Eleven Power — comments on the Independent Expert Committee report

HERC invited comments on the Independent Expert Committee report of 7 August 2026 by interim order of 3 September 2026. EEFI’s earlier written objections and oral submissions in Petition No. 30 of 2026 are adopted. This filing answers the Report only.

The Report is advisory. A line that the licence “may be considered for grant” is not an entitlement. The sixth proviso to Section 14 permits a second licensee. It does not require one. Public interest, universal service, an own distribution system, and the position of DHBVNL require refusal.

Gurugram and Nuh together hold about 35 per cent of DHBVNL sales and more than 42 per cent of its revenue. The applicant is a 2025 company with about ₹1 crore paid-up capital. Eighty-four per cent of the stated CAPEX sits in years three to five. Nuh on the map does not discharge obligation in Nuh. CSS and additional surcharge do not apply to a full switch-over. Haryana has no migration code. Mumbai Tata Power is not a template for a paper network over DHBVNL’s paying circles.

EEFI prays that the petition be rejected; that the gaps recorded by the Committee be treated as grounds for refusal, not conditions subsequent; and that DHBVNL continue as the distribution licensee for the area.