Change of Tariff Slabs

The Secretary,

DERC, Viniyamaki Bhawan, C-Block,

Malvya Nagar,

New Delhi.

 

Subject: Change of Tariff Slabs ......... Rectifying a Mistake ....... in contravention of Section 62 of Electricity Act-2003.

 

Sir,

 

The proposed public hearing for refixation of slabs/tariff is in contravention of sub section (4) of section 62 of Electricity Act, 2003 as amended up to date that postulates as under:-

 

4) No tariff or part of any tariff may ordinarily be amended, more frequently than once in any financial year, except in respect of any changes expressly permitted under the terms of any fuel surcharge formula as may be specified'

 

The Press Note also highlights the complete non application of mind by the Commission at the time of fixing tariff under which the slabs were revised.

 

As per Para 8.2.1 of the National Tariff Policy it was obligatory on the part of the Commission to institute a system of independent scrutiny of financial and technical data submitted by the licensees.

 

Therefore, you are requested to please clarify in exercise of which power of any of the Act, Rules and Policies the Public Hearing for restructuring of the Tariff Slabs is being held.

 

Further for your future reference I wish to Remind you of the Rationale for having a Slab System.

 

1. SLABS ARE FOR AVERAGING POWER PURCHASE COST:- Slabs were made to Average out the Power Purchase costs of DISCOMS ........ You may not be aware of the Fact .... but it is common Knowledge that Power Purchase Cost vary between Re. 1.08 per unit to as much as Rs. 6 per Unit or more.

 

2. 80% OF POWER PURCHASED IS FOR LESS THAN Rs. 2/- PER UNIT:- It is to be noted that 80% of the power purchased by DISCOMS is at under Rs. 2/- per  unit as per various credible sources and Power Exchange Data. It was for this Reason that we have been demanding in several DERC Public Hearings that DISCOMS be made to place on the website  on a WEEKLY BASIS total Power Purchased, What Price, what Quantity and what Source. Our information shows the expensive Power Purchased by DISCOMS during Peak Load is a mere 20% of total Power consumed in Delhi during Peak Summers and Winters.

 

3. PROTECT THE INTEREST OF PRUDENT RETAIL CUSTOMER:- Slab System was introduced not only to Average Out but also  to Protect the Interest of the Prudent/Conservative Small Retail Customer and to encourage and give incentives  to customers to stay within the lower slab to CONSERVE ENERGY.

 

4. ONE CITY - ONE TARIFF - ONE TREATMENT:- Slabs should be in tune to todays ground reality ...... last year we had demanded that Slab System of NDMC area be applied in the rest of Delhi as was the case during DVB Days. DERC to benifit the DISCOMS changed the Slab system of NDMC Area also, while NDMC never asked for any Tariff Revision as they were in Profits. What pressure was DERC working under and what Data was placed before it by NDMC that they took this decision of changing their slabs and Tariff or was it to deflect criticism on our demand for ONE CITY - ONE TARIFF which stands even TODAY.

 

5. WHY SHOULD CUSTOMER PAY FOR GOVERNMENT/DISCOMS APATHY :- Customers today have to shell out money for consuming upto 200 units per month just to overcome Governments and DISCOMS short comings. They are forced to use  Water Pumps to draw water that too in Peak Summer Months, RO System/Water Purifiers are needed all year round due to poor Quality of water, Mosquito repellents too need Power to run, Inverters and Voltage Stabilizers have to be installed and consume Power, night lamps and other lights are left on at night in the absence of Street Lights etc. DERC should have the first slab at 200 units @ Re. 1.25 per unit.

 

6. RIGHT TO EDUCATION - 100 UNITS FREE TO EVERY STUDENT: Today all the students use computers and to encourage a Knowledge Society this Welfare step must be taken and give relief to parents.

 

7. STOP SUBSIDISING THE POWER GUZZLERS AND CHARGE THEM COMMERCIAL RATES:- Fewer Slabs and at higher levels Penalize the Prudent and lower Consuming Customers and benefits the energy Guzzlers consuming over 1000 units. It is because of Energy Guzzlers that DISCOMS have to buy expensive Power during Peal Load periods. The current Tariff of Rs. 6.10 per unit in Slab of over 400 units should be raised to 700 units and the price lowered. Energy Guzzlers should be charged Commercial Rates of power for all units consumed beyond 1000 units ..... in the current system these high consumers are actually subsidised by the prudent customer.

 

8. SUGGESTED SLABS & TARIFFS TILL CAG AUDIT ESTABLISHES THE TRUE PICTURE:- Keeping NDMC structure of 2011 as Bench Mark till CAG Audit. New slabs/pricing ......  0  to 200 units @ Rs.1.25 per Unit. 201 to 300 units @  Rs. 2.10 per unit. Next 100 units @ Rs.3.00 per unit. Next 100 units @ Rs. 4.10 per unit. 500 to 700 units @ Rs. 5.15 per unit. 700 to 1000 units @ Rs.6.10. Beyond 1000 units should be charged Commercial Rates at highest slab to curb Extravagant use of Scarce Resource.

 

IT IS EXPRESSLY BROUGHT TO YOUR NOTICE THAT POWER TARIFFS HAVE BEEN CONSTANTLY FALLING SINCE 2009 ONWARDS AS THERE HAS BEEN A HUGE CAPACITY BUILDUP. DISCOMS HAVE NOT BEEN PRUDENT IN THEIR POWER PURCHASE AGREEMENTS AND HAVE BEEN INDULGING IN CARTALIZATION AND FAVOURING SISTER CONCERNS TO GIVE THEM WINDFALL PROFITS.

 

This is without prejudice to any other submission that may be submitted at the time of hearing.

 

Warm Regards,

 

sd/-

 

Rajiv Kakria