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
