State

Minimum Charges Range ( Equivalent to Units / KW / month )

Fixed / Demand Charges ( Units / KW or KVA / month )

Load Level LMV-6

Existing MCGunits/BHP/Mth

Prop MCGunits/BHP/Mth

In the tables above, the figures have been calculated by dividing the slab amounts proposed with the corresponding energy charge rate, and further dividing by 0.746 to convert from BHP base to KW.

PROPOSAL :-

In view of the situation explained above there is no justification for minimum consumption guarantee hence should be scraped.

            Minimum charges’ adjustment

While the proposed rate schedule specifies rebates and penalties for timely and late payment of bills respectively, no such safeguards are specified in the case of adjustment of minimum charges, which is always a cause of harassment of the consumers.

            PROPOSAL :-

A rebate of 10 % should be available for timely payment of minimum charges. And if the licensee fails to adjust these charges in the last bill of the financial year, such amount should carry 2 % interest per month until the actual adjustment thereof.

  2.        Peak Hour penal tariff:-    The power supply in the State is so erratic that any peak hour restrictions have lost their sanctity. On many occasions, power is made available to the industrial sector only during these timings. In this background, stipulating a penal tariff for usage during these hours is unethical. Nowhere in India are any such penalties imposed on the industry. In fact, such peak hour restrictions, if any, are limited to the bulk consumers, and NOT individual entities. Logically also, such restrictions are retrograde in nature, if power is not assured during rest of the period. And in the absence of such commitment, peak hour restrictions only serve as a means of harassment to the consumers, and hence deserve summary abrogation.

3.               Demand Changes:- It has been stated that rural domestic consumers do not get power at peak, hence issue of “demand changes”  dose not arise. In fact this is the fact that demand charges in addition to energy charges should be claimed from those who are allowed to use energy in peak hours, because it increases the demand. Demand or contracted or connected load in other cases is used for system planning, system loading charges and grid discipline.

For HV-2 consumers, demand charges are proposed to be raised by 47 %, i.e. from Rs. 170/KVA/month to Rs 250/KVA/month for supply at 11 KV, which is too steep, and not at all justified, especially in view of poor supply position.

Fixed charges, per se, were introduced to mitigate revenue shortfall due to line losses. Now, when UPPCL itself makes public declarations that line losses have been curtailed, and that they were being further brought down by better line management, there is absolutely NO JUSTIFICATION to raise the fixed charges being levied on industrial consumers. Even if the original criteria were to safeguard against improper metering due to mechanical types of meters, the same does no longer hold good after the near total replacement of such equipment with digital electronic instruments.

The existing tariff scale should, therefore, be maintained in the new proposals as such.

4.   Page 78 (Para 8.6) Small & Medium Power –LMV-6:- That the consumers under this     category having a connected load above 50 and up to 100 BHP is the worst hit as would be clear from the following data :                                                                                                           (Rs in crores)          

   In other words there will be about 100% extra burden on consumers under LMV-6 having load above 50 BHP over those having load up to 50 BHP.

The qualifying criteria of at least one motive load of 3 BHP or above, or a single load of 2 KW or above carries no logic, and should be done away with, especially in view of IT based industries of today, where micro machines of low individual power rating are the order of the day, as against the obsolete equipments which consumed more power. Also, when metering is being done with help of digital electronic meters, such a retrograde provision only serves as a means of harassment of the consumer at the hands of field intelligence staff.

The option of applicability of LMV-6 tariff should be made available up to 100 BHP connections as per the present practice. The proposed tariff limits this tariff only upto 50 BHP. Shifting 50 BHP plus consumers to HV-2 tariff implies that they will have to install their own transformers to take supply at 11 KV or above. And small industries just can not afford this kind of expenses to install AND maintain their own infrastructure for this purpose, which needs expert and professional handling.

All LMV-6 consumers should have the choice to opt for TVM/MDI tariff class, irrespective of their contracted load.  The proposed tariff limits this choice only to connections  above  25 BHP.

We also submit that a single tariff for LMV-2, LMV-6, and HV-2 be made applicable to simplify the tariff structure . The slabs of 0-25, 25-50, 50-100  and above 100 BHP should be eliminated.

5.      Page 17 (Para 8) Minimum changes: - We are opposed to the very concept of MCG. Reasons have been explained  above. Further it is not clear as to why MCG should be higher in case of those consumers who might opt for TVM. In fact it should be less.

6.      Uniform Units:- For sake of simplicity, and for easy comprehension, all tariffs should be expressed in uniform units, that is to say, in either BHP or KW for connections without TVM/MDI, and in terms of KVA for those with TVM/MDI.

7.   Page 19 –HV-2 – That despite the fact that industrial load is shifting / not forthcoming, there is no plan, either through tariff design or otherwise, to provide incentive to the industries to continue to be with the UPPCL. This could be done through rationalized and simplified tariff design, or through direct and indirect incentives. In this connection we propose following rationalization and incentives.

                                                               i.      Demand Charges: There is no justification for DC on those not opting for restricted power supply. This could be suitably  merged in the unit rates and demand should only be used for load , grid discipline and penalties for its frequent violation.

                                                             ii.      Consumers opting for restricted hours supply: There should not be    any difference in unit rate, however demand charges could be levied extra.

                                                            iii.       Minimum charges : As explained earlier it leads to unnecessary consumption and has no justification. Instead, the unit rate be suitably amended and system of rebate for a minimum consumption per KW per month / year be introduced. It will work as a check on pilferage / misuse and help industries from getting out of sickness.

                                                           iv.      Special Rebate to Sick Industries: - Industries declared sick by BIFR or State level authorized committee, should be allowed a rebate upto 50% from the declared date of sickness for a period of 2 / 3 years with certain conditions that payment are made regularly.

                                                             v.      Temporary Reduction of load : Indian economy is so uncertain that there is wide fluctuations in demand specifically in export oriented industries. Temporary reduction in load / demand may be allowed  for a period upto one year without any charges provided such a situation (like lack of orders) is certified by some competent authority .