In response to Public Notice issued by the Commission, only three written objection were received till the last date of objections mentioned in the public notices. The Commission believes that active public participation will help in developing awareness and understanding about the regulatory process and the approach underlying the decision-making process of the Commission. The Commission has provided adequate opportunity to all the concerned persons / organisations to put forward their views and objections on the filings made by the Licensee. Shri R.C.Barar, Past President on behalf of Faridabad Industrial association, Faridabad, Shri Sajjan Kumar, DSP on behalf of the Superintendent of Police, Hisar and the staff of the Commission on behalf of the public presented their views during public hearing. A list of interveners is given in Annexure – 4.
(A) Sh. R.C. Barar, Past President of Faridabad Industries Association, Faridabad submitted their comments on the ARR of DHBVNL for FY 2005-06 vide their office letter No. FIA/2005/322, dated 16.9.2005. Shri R.C.Barar and Shri G.C.Narang on behalf of Faridabad Industries Association also presented their observations during the public hearing at Bhiwani on 5.10.2005. DHBVNL submitted their reply vide office Memo No. Ch-Spl-I/SE/RA, dated 30.9.2005. The comments of FIA and the reply of DHBVNL thereon are also given below in regard to the important issues:
a. Licensee has projected interest on consumer security but in actual no interest is being paid to any consumer.
Reply of the licensee - As per standing instructions, the interest on Consumer security is adjusted by the respective Operation Sub Divisions in the energy bills of respective consumers in normal course of business. The detail of provision made and interest on meter security GH-48.3 adjusted by Sub Division is as under: -
(Rs. in millions)
Years Debit Credit (provisions made)
FY 2004-05 2.56 2.18
FY 2003-04 1.37 2.36
FY 2002-03 1.73 2.65
The debit amount shows adjustment of interest in consumer’s accounts.
Where the interest has not actually been adjusted the matter is being looked into with SDO, XEN, and SE concerned. The instructions to the SDO and XEN (Operations) has already been issued vide memo No.CAO/A&R/429-62 dated 6.4.2005 and memo No. CAO/A&R/1498-1521 dated 15.7.2005 that the amount of previous outstanding on account of interest on meter security deposits up to 31.3.2005 must be adjusted in the account of concerned consumers.
b. There is a reduction in MU of electricity sold from 7565.67 in FY 2004-05 to 7345.87 in 2005-06; the major shortfall is in the unmetered agriculture category. It needs to be clarified as to the procedure by which less electricity will be sold to unmetered users in the agriculture field
Reply of the licensee - For load forecast purpose, the guidelines of the Commission are being followed. The licensee has worked out the sale forecast on the basis of connected load and ALF. These two parameters take into account all other factors like number of consumers and specific consumption.
c. Projected Distribution Loss of 31% for FY 2005-06 need to be spelt out zone wise and action contemplated to reduce these losses. The licensee should adopt AT&C losses to indicate T&D Losses. There has been practically no improvement in the losses during the last five years.
Reply of the Licensee - During FY 2004-05 actual reduction losses has been worked out to be 32.66%. The licensee has projected Distribution Losses as 31% during FY 2005-06. The same shall be achieved by making comprehensive metering plan that will replace dead, old and defective Electro-Mechanical Meters with Electronic Meters. Bifurcation / trifurcation of lengthy and overloaded feeders, detection of thefts, providing meters near the main gate of premises, augmenting the overloaded transformers and augmenting and making new substation of various categories under various schemes etc. The point of adoption of AT&C Losses to indicate the T&D Losses has been noted for future.
d. Running hours for the flat rate consumers have been considered 10-12% higher in comparison to those of metered tube-well i.e. 5.88 hrs. / day against 5.28 hrs./day for metered tube-well connections.
Reply of the Licensee - As per the sample study conducted by the licensee the average running hours of flat rate tube-well works out to be 6.75 hrs./ day against 4.83 hrs./day of metered tube wells, thereby the flat rate tube-well run 25 to 30% more as compared to the metered one. But Nigam has considered only 10-12% more than the metered one.
e. The earning of the licensee should be encouraged by way of improved collection efficiency and cut in T&D Losses. DHBVNL has to be made accountable for supply of energy and collection thereof.
Reply of the Licensee - There were problematic villages, which were not paying their energy bills due to agitation by BKU/KSS resulting into low realisation. Now most of the consumers have opted for the settlement scheme and it is anticipated that the collection efficiency will touch the projected figures.
f. The industries are not getting quality supply as they never get 440V and frequency level is also not maintained at 50 cycles. As a result of low voltage and low frequency many sophisticated equipments installed at the industry premises are damaged. It was also mentioned that since massive agriculture inductive load is put on the system at the time of agriculture season, capacitor bank of high capacity MVAR could be installed by various sub stations to maintain constant voltage and frequency level. The Nigam should charge from the consumers as per the actual supply of energy i.e. there should be proportionate reduction in the tariff charges whenever the Nigam is not able to supply electrical energy as per their stipulated tariff conditions.
Reply of the licensee - As per tariff, we are to supply energy at 400 volts 50 cycles with average regulation +/-5%. It will not be correct to assume that due to low voltage and low frequency, specific equipments are damaged. It is a matter of record and the experience that the sophisticated equipments are damaged only due to high voltage/ frequency. No such cases of loss due to low voltage have been reported from the field so far. The Nigam invariably does not resort to the Power Regulatory Measure, but in the outage of various powerhouses feeding the Northern Grid, we are constrained to adopt Power Regulatory measure.
g. The Electricity Act 2003 makes it mandatory to install meters at all points of Distribution & Transmission. The utility should be asked to give a time frame by when all the meters will be installed.
Reply of the licensee - As far as 100% metering plan is concerned, every consumer has already been metered and every new connection is being given metered supply whether it is domestic, commercial or agriculture. The Nigam is facing difficulties for installation of meters on flat rate tube-wells due to stiff resistance from the farmers. Nigam has sought extension of time up to June 2006 for providing meters in flat rate tube-wells also
(B) Shri M.N.Ajaya Kumar, Secretary General of NCR Chamber of Commerce and Industry, Gurgaon raised the following issues vide their office letter dated 23.9.2005. DHBVNL replied to the observations vide office Memo No. Ch-Spl-I/SE/RA, dated 30.9.2005. The comments of NCR Chamber of Commerce and Industry and reply of DHBVNL thereon are given below in regard to the important issues :
a. Relief for power cut to industries in MMC, PF
Industrial consumers are to pay Minimum charges during the month, even if there is scheduled / unscheduled power cut and system low voltage, forcing them to switch over to DG sets. Thus, even when they do not get full power supply for the whole month, they are made to pay MMC and penalty for low PF for the full month. For this some parameters need to be defined and consumers should get proportionate relief in MMC & PF in case of outages and low voltage.
Reply of the licensee - It will not be correct to assume that due to power cut, the industries are not able to cover the MMC. As per the existing instructions and tariff rates supply of power @ two hours a day can cover the MMC charges. If there is any specific case, the same may be brought to the notice of this office. In general, there is no power cut to the extent that it does not cover the MMC in any month so far.
b. In the case of Bulk Supply consumers, a rebate of 15% in the tariff should be given to the domestic and non-domestic consumers. This is needed, as the department is not incurring an expenditure on maintenance of system.
Reply of the Licensee - DHBVNL is charging the tariff approved by the Commission. There were different categories under bulk supply - BS (DS) and BS(NDS) which were merged in a single bulk supply tariff.
c. Those requiring new Bulk Supply / Industrial connections are made to deposit service connection charges and share cost of the sub- station from which supply is given and also made to erect the feeder by themselves at their own cost, which is contrary to the instructions. The instructions need to be amended to the extent that in case the feeder is erected by the consumer, no service connection charges should be taken. Regarding the share cost, the licensee is supposed to provide power to the consumer and for this substation, wherever required, is to be constructed by them. The expenditure incurred on the construction of sub-station is already accounted for while framing the tariff and no additional charges should be taken from the consumer.
Reply of the Licensee - The content seems not to be in consonance with the latest instructions regarding service connection charges and share cost. Presently, the licensee is not charging any share cost of sub-station. Only the service connection charges are being charged as per the load. However there is a provision whenever the independent feeder is erected by the consumer then he is allowed rebate in the service connection charges equal to the cost of feeder or service connection charges, whichever is less. If there is any specific case, the same may be brought to the notice of this office.
Regarding system laid by HUDA and private colonisers, DHBVNL mentioned that no O&M charges are levied on any such colony of HUDA and or private coloniser of deposit work or at their own.
Other issues raised by the intervenors related to data, which was provided by the licensee.
(C) Shri Sajjan Kumar, DSP on behalf of the Superintendent of Police, Hisar also submitted their objections vide their office Memo No. 14806 dated 29.9.2005. It was mentioned that 600 residential houses are situated in the New Police Line Colony, Barwala Road, Hisar, which have been provided electricity at Bulk supply tariff, which is higher than the domestic tariff. So, all their residential units should be provided electricity at domestic tariff. It was also mentioned that no matter is under dispute and pending before any consumer forum or civil court. However, no relief has been granted due to which incumbents of police lines are facing recurring financial losses and due to this very fact, there is resentment amongst the police officers.
During the public hearing on 5.10.2005 or thereafter no reply was submitted by DHBVNL on the objection raised by the Superintendent of Police, Hisar.
(D) The staff of the Commission also made a detailed submission during the public hearing on the various aspects of the ARR.
The Commission has ensured that the due process contemplated under the law is followed at each and every stage and adequate opportunity is given to all the stakeholders.
