Comments on Retail Tariff Order for 2013-14 issued by JKSERC on 25-04-2013 For JK PDD On Line Engineers 1.

The Commission has rejected the proposal of PDD to introduce kVAH billing for load above 20kW in Industrial and Non Domestic Commercial Category on the grounds that infrastructure like Tri-vector meters are not available at the installations with load 20kW to 100kW. I think even if Commission waits for next 20 years, 100% tri-vector metering is not going to take place unless kVAH based tariff is introduced. I remember when we introduced kVAH based tariff in 2007 for loads above 100kW, it took us around two years to complete kVAH based metering for these loads. J&K is was one of the five states in whole country which had introduced kVAH tariff. Perhaps Commission does not know that thread throw type LT meters (Pridigy type) which we installed at big LT installations have got kVAH billing facility. J&K is the only state which is paying around 60 crores per anum for purchase of Reactive Energy from Northern Grid. The reason being that sufficient capacitors are not installed in the system to neutralize reactive power demand of consumers. kVAH based billing has inherent mechanism to penalize the consumers who do not use Shunt Capacitors. Last year Commission rejected our proposal to introduce ToD tariff for loads 1MW above inspite of instructions from Planning Commission and inspite of the fact that nearly 100% installations with load 1MW and above have got tri-vector meters which have ToD facility. The Commission has introduced a BPL category in Domestic Category for consumption upto 30 units per month. I fail to understand the logic behind this categorization. Can somebody show me one BPL household in the state which is metered and is compliant and paying as per metered tariff. Otherwise also the tariff of this slab was kept low to give benefit to life line consumers. In the next slab, it is not 31 to 100 but upto 100 units which means the general consumers will not get benefit of this slab. This is going to complicate the billing system. The script of NIC billing software is required to be re written for which NIC needs some experienced person as the writers of present software have already left state unit of NIC.

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The commission has unnecessarily introduced two part tariff in domestic category. This will discourage honest domestic consumer who come forward and disclose their load voluntarily. With more than 90% meters in domestic category bypassed, I think the net effect of reducing minimum charges from Rs. 40 per kW to fixed charges of Rs. 5 per kW will result into loss of revenue. The commission instead of eliminating minimum charges in Domestic Category should have increased these charges heavily so as to ensure some recovery even if meter is bypassed. We have to be realistic. It seems that Commission is not aware of the ground realities. Comment of the Commission at clause 3.110 conveys that any commercial installation registered with industries department can be charged under Industrial Category. This contradicts the very definition of Industrial Tariff which defines Industrial Category as where raw materials are converted to finished goods. This is going to open a Pandoras box. We have already well connected IT people demanding Industrial Tariff. In fact they gave already got industrial tariff under IT policy illegally because Commission does not know it. It is now matter of implementation only Printing presses and medical diagnostic centers have registration with industries department. Hotels will hopefully get this registration in near future. In fact getting this registration in J&K is not a big deal. At the end of the day, the commercial tariff will be left for Channi Wala, Nanwaii, Dood Wala, Sabzi Wala and likes. This move of the Commission is going to cause huge revenue loss to the department and benefit influential and well connected big Commercial Consumers of the state. The Commission has introduced Separate category namely LTIS II in order to provide relief to Atta Chakkis, Rice huskers, Oil expellers, cotton grinning, etc in rural and unorganized sector having load upto 10 HP (7.46 kW). LTIS I would include all LT industrial consumers except those covered under LTIS II., I,e above 20 HP. Commission has kept energy charges for LTISI and LTIS II same but given relief in fixed charges only (diff of Rs, 27 per kW). This bifurcation is not going to give much relief to these consumers but will definitely complicate introduction of kVAH billing in future. We were almost prepared for kVAH billing for loads above 20 kW but above 10kW it will be extremely difficult.

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