Chandigarh, 8 August : I, being a responsible resident of the State of Haryana submit the following objections: 1) I make it clear right from the onset that I disapprove this notice. This public notice violates the Section 87 of the Electricity Act 2003. I understand and know as per Electricity Act 2003 State Advisory Committee is constituted by the State Commission. “The objectives of the State Advisory Committee shall be to advise the commission on Major questions of policy.
HERC has not constituted the State Advisory Committee, whose advice to the Commission is mandatory on the issue of revision of tariff. This public notice and public hearing on the revision of tariff is illegal.
2) Public notice of Tariff must have been given in widely published newspapers with viewable space, i.e. the pages that relate to Haryana because you are to send the message to the common man of Haryana. Unfortunately, but intentionally, the HERC gave notice on the Punjab section of the newspaper, The Tribune was chosen for the job. The reason can be best known to the Commission, since the visible purpose seems to hide the notice from the people of Haryana.
3) As per the Standard of Performance Regulations, under section 57 of the Electricity Act 2003, the HERC may, after consultation with the licensees and persons likely to be affected, specify standards of performance of a licensee or a class of licensees. I am sure that the HERC, being the regulator have issued guidelines/directions about Standard of Performance to the utilities, but these regulations have never been brought to the notice of the consumers by the HERC or the utilities. “The Standard of Performance shall specify the minimum standards of service with reference to quality, continuity, and reliability of services that a licensee shall achieve in discharge of his obligations as a licensee.
Standard of Performance must specify the guaranteed standards of performance for which consumers against whom no arrears are pending on the date of violation are eligible for handsome compensation in case the licensee fails to achieve the Standard of Performance.
4) I am surprised that there is no mechanism existing with the distributing companies, i.e. UHBVNL, DHBVNL for the purpose of preparing cost of service model. The tariff proposed is not supported by any cost estimates, which are essential for filing requirements. Therefore, I wonder how the cost is calculated, and through which methodology. It is also unfortunate that once the World Bank studied the cost of service in 1999for three months i.e. January to March as an adhoc survey. Utilities yet depend on that adhoc survey even after 9 years. Cost of service study survey is mandatory, but the utilities are sleeping and harming the interests of the consumers.
5) As per the HERC regulations, the tariff proposal should establish impact on the typical consumers but this has not been done. In its absence the proposal is adhoc, and the instant proposal utilities have deliberately worked to keep the consumers in dark.
6) The power utilities from the very beginning have been adopting telescopic pattern for the calculation of tariff and billing. But now these utilities have taken a “U” turn and shifted to non-telescopic pattern. The HERC, instead of highlighting or explaining the people, tried to hide this shifting of pattern of billing. The word non-telescopic has been lowest priority of the commission in the public notice. How can I say that HERC is for the interests of the consumers? It is a solid proof about where the interest of the HERC lies. Non-telescopic is the death knell of the consumers’ interests. It would mean that no consumer of any category of three slabs would be benefited if he is out of that slab by even a single unit. In telescopic, the billing pattern was as such benefit of every slab was passed to the consumers.
7) As distribution and transmission licensees are having around 28% loss level against the benchmark of 13 to 15% given their status operating system. 1% T&D loss is equivalent to Rs 90 crores, which is only due to ill maintained and over loaded feeders across the state. About Rs 1400 crores, is a cost that honest consumers are burdened with. In last 10 years, utilities have failed to achieve the loss reduction targets given to them form time and again.
8) Collection efficiency is about 80% only, resulting in 20% of the revenue running into thousands of crores, uncollected. Consequently, demand for tariff hike unjustified. Why should the consumers pay for the inefficiency of the utilities and bear with their poor quality?
9) T&D losses: The transmission and distribution losses are running around 28% for a long time, and efforts have never been made by the utilities to reduce the strain. It seems to be the case of theft, which is not possible without the connivance of the staff of the utilities. The honest consumers are being punished for the misdeeds of others, which includes the staff of the utilities or the hidden powers. No responsibility has been fixed in the last 10 years on any of the officers of the utilities who are responsible for the T&D losses. They have gone Scot free and even rewarded with promotions and lucrative postings for a long time without any justifiable contributions or improvements in the system.
10) Consumer dissatisfaction: Utilities/HERC should know the level of dissatisfaction amongst the consumers throughout the state. The reports of newspapers of last few month speaks well about the performance of the utilities where agitation, dharnas, protest rallies, even manhandling/firing by police is an everyday affair. Incompetence, corruption, high handedness, lack of responsibility on the part of utilities is a reality and proved fact, and HERC being in hand in glove with utilities will not be allowed to burden the consumers with additional inefficiency of Rs 522 crores.
11) No. of feeders having line losses slab of % wise ending 12/07:
No. of feeders having line losses more than 25%= 684
No. of feeders having line losses more than 50%= 145
No. of feeders having line losses more than 70%= 17
No. of feeders having line losses more than 90% = 13
No. of feeders having line losses more than 25%= 657
No. of feeders having line losses more than 50%= 144
No. of feeders having line losses more than 70%= 31
No. of feeders having line losses more than 90% = 1
12) HERC/ Consumer Grievances Redressal Forum/ Ombudsman: Consumers of the state at large are not aware of HERC/CGRF/ Ombudsman and their functions and no efforts have been made to apprise the general public in this connection. Secondly, the office of CGRF are at Hisar/Panchkula and it is difficult for anyone who is aware of their existence to reach at far places and for the convenience of the general public their office may be located at every District Headquarters.
13) Why the distributing companies are putting domestic meters outside the house premises on electricity poles? HREC has asked utilities in so many words that the installation of real-time display unit must be on the entrance of the house. There are numerous complaints regarding highly poor quality meters belonging to unscrupulous manufacturers. If some consumer complaints against these meters, they are tested only in utilities labs, which are already sinking in corrupt practices. Therefore, why these sub standard meters are not tested in the Bureau of Indian Standard Labs.
14) In the absence of any mechanism to calculate the electricity supplied to the agricultural tube wells, especially in case of un-metered tube wells, whose tariffs are calculated flat rates, these flat rate tube wells are nearly 80% in the state. This year the power utilities have demanded more than 2400 crores of rupees as a subsidy from the Government, which is totally absurd. The calculation regarding un-metered supplied tube wells have been on the basis of a tube well consuming continuously for 5.37 hours a day for 365 days, i.e. approx 1960.05 hours a year, which is highly unrealistic. The facts reveal that a farmer from village Kalirawan, District Hisar, calculated power supplied in a week to his tube well by using a stop watch. Shockingly, the result was 12 hours a week, which makes it to 12*52 = 624 hours a year. Therefore, a shocking gap of 1336 hours. Now what on earth is the Government thinking? We are aware of the fact that the farmer does not require electricity for the whole year continuously. Many times, the utilities provide 5-6 hours of interrupted power supply on alternate days. It also differs from crop to crop, e.g. Paddy requires more supply of water. There are some lean periods and during rainfalls totaling many months, when the farmers do not require electricity for their tube wells. Sometimes due to fault in feeders, sub stations, transformers, tube well motors, and other electrical equipments the power is not supplied to the farmer for so many days. Many times, the farmers use diesel etc. in case of power failures, which is highly usual. Finally, in this case, I conclude that all thefts of power in case of other categories of consumers are booked in the farmers’ account whose tube wells are on flat rates. The theft, which is on higher side, is shown on lower side. Actually, if there existed any mechanism to verify the power consumed in agricultural sector, the subsidy required must have come down just to 700-800 crores.
15) In view of the above facts, I demand that the instant proposal to revise the tariff to the tune of Rs 522 crores may be rejected. The utilities may be asked to improve their performance and the guilty responsible for the chaos may be punished and inefficient, corrupt, “dadas” may be removed from lucrative postings.