PUBLIC RESPONSE TO ARR - TARIFF FOR FY 2010-11

The Secretary

DERC, Viniyamak Bhawan, C-Block

Shivalik, Malviya Nagar,

New Delhi - 17

Ref: Public notice in HT dated 17.1.10

Dear Sir,

Following observations which are common to all Licensees be considered before taking up ARR. Format for presentation of ARR data is not the same, therefore comparison and making observation for an ordinary consumer is difficult. Hence, more details in terms of fixed charges and category wise recovery, in a standard format, be made available for reasonable feedback.

4. Discoms had proposed tariff increase from 50% to 70% whereas no increase had been proposed by NDMC. Discoms in private sector had already implemented four increases taking it almost to twice the tariff in July 2002. At the same time there is no increase in NDMC area since 2002. So why the consumers with DISCOM should suffer when tariff, quality of supply and grievance redressal, are much better in NDMC.

5. AT and C, loss calculations are not correct, when major consumption in DISCOM offices as well as sub-stations not recorded. This stand is confirmed in the petition with CIC on the RTI by Shri H.L. Kalsi. However metering be done now in all discom offices as well as sub-stations and these figures be accounted for since July 2002. It will have repercussion on previous increase in tariff, and suo-moto refund.

6. Levy of fixed charges differ between DISCOMS & NDMC. The date of implementation is also different. It was made effective during 2004 in DISCOMs whereas during 2008 in NDMC. The rate of fixed charges is Rs. 2/- Per kw in NDMC against Rs. 12/- per kw in DISCOMs. Discrepancy be rectified before approval of ARR for 2010-11.

7. Fixed charges are not part of regular tariff, therefore it’t of receipts and expenditure, be projected separately and not as a part of total revenue.

8. The Services being rendered against fixed charges, not elaborated as on date. How long consumer is expected to pay fixed charges, be projected as the same are not part of consumption tariff.

9. Crors-subsidy in tariff, was basically introduced to support agriculture. Therefore, commercial and industrial sector, pays higher tariff whereas domestic sector contribute at par. As regards agriculture area in Delhi, it had reduced to 1% whereas commercial & Industrial revenue, increased to more then 40%. This amounts to undue benefit to licensee, hence bifurcation of revenue in different categories be made public in the ARR.

10. Replacement of electro-mechanical meters by electronic meters, is yet to be implemented in domestic sector of NDMC. On the contrary, DISCOMs carried out replacement twice i.e from electro-mechanical meters to electronic meters and subsequently electronic meters to digital meters. It appears that technology improvement is not required in VIP areas under NDMC, else DISCOM motive is different which may be made clear.

11. There is no transparency in DISCOMs under private sector particularly in tendering and salary structure. Norms and delegations of ECGRF are not available on website. Hence accountability in power sector is low, inspite of DERC performance standards, tilted in favour of Licensees.

12. Consumers are bound to bear discretionary higher pay package for employees. After seven years of operations pay-scales/perks are yet to be standardized, especially when govt. holds sharing of 49%. Salaries, without norms, should not be considered in ARR.

13. Merger of different categories in tariff and reduction of slabs, are not acceptable, while looking at ARR

B. L. Poddar R. N. Gupta

Acting President General Secretary