To,
The Secretary,
DERC, Viniyamaki Bhawan, C-Block,
Malvya Nagar,
New Delhi.
Sir,
At the outset I wish to state that this
Draft on Performance of DISCOMS - is just an Eyewash - as this draft touches only Peripheral issues .... while the Key Points of Performance Standards and a rotten infrastructure have been left unattended. I am filing my objections UNDER PROTEST and more so to make it a matter of OFFICIAL RECORD for posterity, than for any expectation of any meaningful outcome, giving relief to long suffering citizens.
Some of the more important Key Points that have not been adequately addressed are page wise .....
Page 12 - Explanation: Past cases where 3 phase connections have been given for loads less than 10 kW, no changes are contemplated by these Regulations.
Unfair to over 25 Lakh existing consumers -
This is discriminatory and open to challenge in the High Court as willful omission to benefit DISCOMS. Please refer to the minutes of earlier Public Hearing, over three years of correspondence and the meeting held at DERC in Sept. 2011, it has been clearly brought to the notice of the Commission that due to Residual Back Flow consumers are being fleeced 25% to 40% extra due to fast running meters. DERC had issued an Ad. in leading Dailies on 24th Dec. 2011 addressing the issue in an oblique manner, beyond the comprehension of common consumer.
DERC through this Draft is trying to make this practice of making unearned Profits a permanent affair.
Page 15 - In case "no-due certificate" is not obtained by the previous owner, the applicant before purchase of property may approach the Business Manager of the Licensee for a "no-dues certificate". The Business Manager shall acknowledge receipt of such request and shall either intimate in writing outstanding dues, if any, on the premises or issue "no-dues certificate" within one month from the date of application.
Not Fair ...... No dues certificate should be given within 7 working days ...... Property Transactions are Cost/Time Sensitive and with records being computerised, it should not be difficult for DISCOMS to comply.
Page 36 - WIRING - (ii) At the time of testing of installation, if the Licensee's representative finds that there is a defect in the consumer wiring, he shall serve notice in writing to make such modifications as are necessary to render the installation safe. (iii) The connection shall be energized only on removal of the defect. (iv) The licensee shall disseminate information with respect to Earth leakage in internal wiring for consumer benefit,
as also about the need to maintain distinct phase and neutral wires per metered network within the premises.
Not Fair..., Giving an escape route to DISCOMS ........ We had clearly asked for DISCOMS to give separate Neutral upto each Metering Point as per relevant Act/Code. This Draft does not talk of Residual Back Flow resulting in unearned 25% to 40% extra profits by DISCOMS ..... the Licensee disseminating information about the need to maintain distinct phase and neutral .....
does not explain to the lay man that he may have to foot the bill of his neighbours heavy load consumption. We had also asked for imposition of punitive penalties in case of non compliance and refund unearned profits over the past three years since Electronic meters were installed. This should be treated as a criminal offence of willful cheating and dealt under Criminal law including imprisonment.
Page 60 - 55 Direct Theft .....
Unacceptable - DISCOMS are supposed to curb theft and take all steps needed and
RWAs support strict action against power thieves ........ However DISCOMS should not be allowed to seek enhanced Tariffs on account of Theft.
They should bear the cost as business loss, as they were supposed to control theft ..... just as a shopkeeper is not supposed to charge the consumer for the materials stolen or pilfered from his shop. DISCOMS can be at the most be allowed a Fixed 3% Distribution loss. This step alone will make DISCOMS stop thefts due to Political Considerations.
Zero Theft should be a part of Guaranteed Performance Standards.
Page 61 - (v) Lodging of FIR/Complaint in Special Court. FIR shall be got lodged immediately by the A.O. in the police station on the proforma attached as Annexure-XV immediately with in 24 hrs. after detection of theft and subsequent disconnection of supply. In case of non filing of FIR then the licensee may file complaint before the Special Court within 72 hours of the disconnection of supply.
Discriminatory - Law should be same for any theft ......... when consumer steals clear provisions are mentioned ........ whereas due to
Residual Back Flow DISCOMS are also stealing from consumers and no such provisions are laid out.
Page 78 -Voltage Complaints - xiii The Area Assistant Manager/Designated Officer shall ascertain if the problem can be rectified by changing the Tap position of the transformer or proper control of the capacitors installed in the system and if possible, he shall do so. However, in case the Assistant Manager finds that problem is due to deficiency in the distribution system requiring up-gradation of distribution lines, transformers, capacitors etc., he shall inform the District Manager for taking further necessary action.
Vague - In our past correspondence and in Public Hearings, RWAs have been demanding strict Compliance in the
Matching of Neutral to the Absolute Earth Potential as per relevant Act/Code. This alone is the main cause of Fluctuations and Spikes, resulting in damaging expensive household appliances like TV, Fridge, Ac etc and unnecessary expenditure on Voltage Stabilizers.
Performance Standards pertaining to Stable and uninterrupted 24X7 Power was one of the reason why Privatization was done. Consumers should be compensated for the losses due to Fluctuations and Spikes and be a
part of Schedule I of Guaranteed Performance Standards.
In the absence of any punitive provisions DISCOMS do not find it important to invest in such infrastructure.
Pages on Guaranteed standards of performance -
Inadequate - These are just peripheral issues ..... though important .....
but in the absence of Substantive issues like Theft, Residual Back Flow, lack of uninterrupted 24X7 power keeping the Inverter industry alive and burning a hole in the consumers pocket, Neutral not being matched to the Absolute Earth Potential hurting the consumer, Ugly Overhead Wiring spoiling the city scape etc without which the purpose of privatisation is defeated and is proving very costly to the consumers.
Unless all these issues are made a part of Guaranteed standards of performance ...... the whole exercise will remain just an EYEWASH.
This is without prejudice to any other submission that may be submitted at the time of hearing.
Warm Regards,
Rajiv Kakria
Mob.: 09810275168