Dated: 8-11-2011
To,
The Secretary,
DERC, Viniyamaki Bhawan, C-Block,
Malvya Nagar,
New Delhi.
Subject: Public Notice inviting Objections/Suggestions on Draft MYT Regulation 2012 to 2015.
Sir,
The Public Hearing should be a forum to address the genuine suggestions/inputs of the Public, rather than an exercise to showcase a facade of Inclusive Process. We the RWA's have been in the past submitting our concerns and have always tried to give constructive support to arrive at a fair decision. There seems to be an attempt to keep the public involved in paper pushing, where as our previous objections and suggestions are yet to be addressed. I see no reason to keep parroting our objections.
The ground situation has not changed and most of our earlier objections still stand unanswered. We seek a single common Public Hearing in a large hall so that all the stake holders can voice their concerns together and exchange views and research.
A few of our earlier concerns yet to be suitably addressed are :-
1. DISCOMS keep asking for tariff hike but remain quite about reducing tariffs on account of reduction in Distribution losses. Distribution losses should be borne by the DISCOMS as it is their responsibility to curb theft and leakages. We can grant them a nominal 3% cost on account of Distribution loss as per international practice.
2. There should be no tariff enhancement till CAG Audit establishes the true state of Finances and Institute of Chartered Accountants (ICA) establishes the inventory and Tariff Determination Procedure. DISCOMS will be in no hurry to furnish records to CAG and ICA and will try to delay the process and keep earning heavy profits.
3. They are also charging Twice under the same head by way of Fixed Charge for having incurred capital expenditure and getting 16% return on capital expenditure. Earlier this was Minimum Charge and was adjusted if the consumption exceeded minimum usage. All the infrastructure is in place and even after charging the recent Load Enhancement Security Deposit, DISCOMS have collected Crorers of Rupees and have not installed higher load meters nor have they changed any wires/cables. Therefore Fixed Charge should be abolished as we had demanded in all previous Hearings.
4. 11 years on they have yet not adhered to the Performance Standards on Quality, Stability, Reliability, Cheaper Power, Curbing Theft (in theft prone areas), Beautification of city (ugly over head wires still dot the skyline) and Setting up Power Plants. First they should perform as per the agreed Performance Standards then only we look at any other demand.
5. Rampant power cuts are keeping the Inverter Industry alive and the consumer foots the bill for charging and maintaining inverters amounting to average Rs. 1200/- per month.
6. Independent investigation involving RWAs into the compatibility of distribution technology and the design of electronic meters vis the use of Common Neutral for separate connections and residual flow being recorded and charged to the consumer.
7. Field Survey/Awareness Campaign involving RWAs to establish if they have matched the Absolute Earth Potential to the Neutral for stable power supply as per relevant Act/Code. Consumers are paying a heavy price due to expensive equipment being burnt and burdened with the additional cost of buying, running and maintaining stabilisers.
8. Field Survey/Awareness Campaign involving RWAs to establish that DISCOMS have provided separate neutral to each consumer up to the Metering Point as per relevant Act/Code.
9. Transparency in the DISCOMS procurement/tendering process for equipment and Power Purchase. DISCOMS should place on website details of power purchased ie. Source, Price, Quantity etc. so that consumers can keep track of competitive prices from the Power Exchange.
10. End Monopoly and invite more DISCOMS for healthy competition, which should have been done year 2005 onwards. Renegotiate the terms of Partnership Agreement.
The list is long ....... WHY SHOULD WE KEEP ON APPEARING BEFORE DERC IF THE ANSWERS STILL ELUDE US. We cannot be a party to the Pretence of Public Hearing and according Credibility to a Regulatory Mechanism that the Government and DISCOMS have no regard for.
This is without prejudice to any other submission that may be submitted at the time of hearing.
Warm Regards,
sd/-
Rajiv Kakria
Chairman, E-Block GK-I, RWA
Greater Kailash-I, New Delhi-110048
