Page 31- (Para 3)- Transmission & Distribution Loss- Reduction Plan:-

                  There is a need to identify technical loss so as to call the rest as theft. Honest consumers have to bear the technical losses being the part of cost of delivery. But passing on of the burden of theft to honest consumer is neither ethical nor justified. In case of a theft in our neighborhood, we cannot be asked to compensate him. It is the Govt. who has to come to the rescue of the honest consumer. Theft is a law & order problem and its consequent loss should either be borne by Govt. or UPPCL or by both.

The age old menace of theft cannot be controlled in one go and realizing this fact Hon’ble Commission, while passing order on ARR for 00-01 gave time schedule of 7(seven years) to bring down the T&D loss to 20.5% and for the year 2002-03 it was fixed at 29.5% which should be adhered to for ARR under scrutiny. 

1.      Page 31 (Para 3.2) – Restatement of Losses:-  That it is not clear as what is being explained in the table 17. Does it mean that any reduction in consumption in domestic and commercial results into higher T & D losses or it is an indication that theft proposed to be controlled could not be controlled and UPPCL is helpless regarding availability of data with Billing Agency and lack of uniform platform for data base with them. It is certainly an adverse remark on the management and not on billing agencies. It was for commercial wing of UPPCL to ensure common platform –Unix is most suitable, as it is virus resistant. 

2.      Page 42-Energy Audit :– That in financial accounting, accounting comes first and then comes the audit. But in energy which means input and consumption at the same time, the energy audit could be the source of energy accounting. Measurement of energy received and consumed could accurately be done by fully operational and properly calibrated meters at each input/output, point of transmission, and consumption. But what is needed is the identification of two points between which theft/pilferage takes place.

      The UPPCL has proposed 100% metering, replacement of old and damaged meters and feeder, mapping i.e. line charting. Line Chart is the recognized method of energy audit which could be the identification mark of each consumer on record who could be identified with the codified pole/feeder / transformer. 

5.  Page 43 Remote Metering:- Metering of each meter at a prefixed interval is a must. It could be done by visit of Meter Reader physically or by Meter Reading Instrument by downloading directly from the meter or by remote metering system. Metering by MRI and remote system would be possible only if 100% electronic meters with remote sensing facility are installed.

a.       That metering system is governed by section 20 of Electricity Act 1910 as well as by Electricity Supply Code. Commission has recently approved UP Electricity Supply Code-2002 (Distribution Code) which is now part of the law. Any metering system including system of meter reading must conform to the legal provisions.

b.      That according to section-26 of the Electricity Act-1910 it has to be a correct meter. The U.P. Electricity Supply Code –2000, chapter-6- clause 6.4 lays down “meter shall be read by an authorized representative of the licensee once in every billing cycle. The licensee shall issue proper identity cards to the meter readers. The meter reader shall also record the meter reading in the meter card at the consumer end.” Thus use of remote metering system will be illegal besides this, consumer having no knowledge of data of meter reading and there being no provision of MRI and its accuracy and testing requirements, its use for meter reading will not be as per the law. Besides use of remote sensing meter reading can not indicate as to why the meter is not functioning i.e. is it dead, or burnt etc, similarly MRI being an instrument which has to be connected to meter for downloading of meter and this would be another violation of law because every meter has to be sealed in such a manner that nothing could be attached to it without breaking the seal. The accuracy and use of the equipment could be questioned unless there is a provision in the law for its use and method of testing and inspection. Furthermore MRI would differ from meter to meter. It would therefore be advisable to re-examine all its legal aspects.

c.       Page 45(Para 4.3.5.2.)  Focus on Small and Medium Industries: – There is a mention of  “Potential to improve billing and collection of Small and Medium Industries Consumers, but there is no data given for this potential. There is no mention of   improvement in quality of supply or of correct billing.” To improve billing and collection smells of increased harassment. We therefore submit that the schedule of the visit should be made known beforehand and survey should also be signed by two independent witness preferably representatives of industry associations In case of any dispute visiting squad should not disconnect the power and levy the penalty unless the consumer has been heard by the higher authority.

7. Page (47)-(Para 4.3.5.3.7.)-Human Resource –Along with staffing requirements the norms of assessment of productivity should also be laid down.

8.     Page 47 (para 4.3.5.3.7) – That it would be desirable to have “ approach paper” on new initiative and  public opinions and suggestions may be invited.

9.       Page 48 (para 5 and 6) – Energy sales forecast:- That there is no forecast. It is merely repetition of actuals in 2001-2002.

         That temporary connection is one of the biggest sources of theft of power. All over the State every day one or the other public functions, mela jagran and private functions takes place, which are supposed to take temporary connections. The number of such temporary connections are very high. The system of its accounting is  unknown. It is a very hard experience for those who want to honestly have a temporary connection, get back the security and have the final settlement done. Therefore generally people apply the short cuts.  There is no discussion on either the actual consumption or initiative for system improvement. It is not clear as to which category of consumers the consumption of temporary connections, is added to. The system for temporary connections is therefore required to be simplified and made transparent.

10.      Page 56 (para 5.11) Large and Heavy power:-That in ARR discussion, UPPCL has shown concern and pointed out the trend of industrial consumer getting disconnected and shifting to alternative sources of supply thus adversely affecting its revenue. But no  action plan has been proposed to arrest this trend. Even attempts have not been made to explain the causes of such a trend. It is essential that special attention is given to arrest this trend. That most important action could be the introduction of “pay as you consume” tariff and withdrawal of MCG which is the cause of harassment. Further the UPPCL should treat them as their important customer.

11.   Page 56 (para 5.14)- Bulk supply:–That it has been pointed out that KESCO despite it being headed by a Civil   Servant, is one of the biggest defaulter. It is a matter of great concern.

12.      Page 70 para 6.6- Provision For Bad And Doubtful Debts:-

      That it is a beautiful example, as to how the financial jugglery could be used to mislead administration. Provision of Bad and Doubtful Debts has a relationship with  “past accumulated receivable” and not with current years sale of power. The percentage relationship of provision of bad and doubtful debts is misleading, because if you treat part of incremental receivable or current year assessment as bad and doubtful, you are trying to justify the false assessment .It is not clear as why age wise details of receivable have so nicely been avoided. Hon’ble Commission may direct UPPCL to present that data  along with its plan to recover it or write it off.

13  Page 72 (para 6.9)- others details:

                 That UPPCL may be asked to provide the details of Rs 9.67 crore giving names of the consultancy assignments and  methods of consultants selection.

D. Comments On Tariff Design: 

1.         Minimum Charges- According to ARR, the principle of minimum charges is to stop pilferage. It is not however clear as to how this would stop pilferage by those consuming more than the MCG. On the other hand MCG leads to wastage and it acts against the laws of conservation of energy. We refer to the message of Hon’ble Prime Minister of India which he gave recently that “saving one Unit of electricity is equivalent to producing one unit”. Hence the very concept of MCG in present power situation is Anti National.   MCG cannot be effectively used as tools to stop pilferage. You need honest field staff of UPPCL and fool proof metering system. MCG is against the principles of simplified tariff also and needs to be given farewell. It is an open knowledge that  there is a huge gap in demand and supply of electricity in the State. The whole concept of minimum charges carries conviction only, and only if, matching guarantees of minimum availability of power supply go along with it. A countrywide review of the electricity tariffs reveals that as a matter of policy, no minimum charges are specified if fixed/demand charges are stipulated, and vice versa. Either of them serves to fix the lower minimum that a consumer pays, for his share of the line losses.

The following mathematical workout quantifies average power consumption by a light engineering workshop :-

A 1 HP motor running continuously for 7½ hrs in one shift in a day (normal working conditions in small industries in these days of industrial recession ) for 23 days in a month ( after deducting holidays and weekly rests ) consumes ( 746 Watts x 7.5 Hrs x 23 Days ) Wh, or 128.7 units /month. Now consider the following factors which are very significant in the present day power management scenario :

(i)                   In general engineering industries only about half of their installed machines / appliances are in use simultaneously at any given point of time.

(ii)                 Total contracted load is calculated by adding up the power rating of EACH & EVERY appliance.

(iii)         Power supply is made available for only about half of the day.