ORDER - Maharashtra State Electricity Distribution Co. · PDF fileApproval of MSEDCL Schedule...

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Before the MAHARASHTRA ELECTRICITY REGULATORY COMMISSION World Trade Centre, Centre No.1, 13th Floor, Cuffe Parade, Mumbai 400 005 Tel. No. 022 22163964/65/69 – Fax 022 22163976 E-mail [email protected] Website: www.mercindia.org.in Case No. 70 of 2005 In the matter of Approval of MSEDCL Schedule of charges ORDER Dated: September 8, 2006

Transcript of ORDER - Maharashtra State Electricity Distribution Co. · PDF fileApproval of MSEDCL Schedule...

Before theMAHARASHTRA ELECTRICITY REGULATORY COMMISSION

World Trade Centre, Centre No.1, 13th Floor, Cuffe Parade, Mumbai 400 005Tel. No. 022 22163964/65/69 – Fax 022 22163976

E-mail [email protected] Website: www.mercindia.org.in

Case No. 70 of 2005

In the matter of

Approval of MSEDCL Schedule of charges

ORDERDated: September 8, 2006

IN THE MATTER OF

Approval of MSEDCL Schedule of charges

Table of Contents

Sr. No. Description Page No.

SECTION-I1 Preface 12 Background 23 Regulatory Process 3

SECTION-II COMMENTS AND SUGGESTIONS RECEIVED

DURING PUBLIC PROCESS AND COMMISSION’SRULING

4 Service Connection Charges 4Service connection charges for overhead LT supply 4Service connection charges for overhead HT supply 8Service connection charges for underground LT supply 9Service connection charges for underground HT supply 9Cost of meter & meter box 10

5 Service Line Charges 116 Miscellaneous & General Charges 16

Installation testing fee 17Reconnection Charges 17Changing location of meters within the same premises 18Testing of meters 19Replacement of meter cards for HT consumers 19Penalty for cheque bouncing 20Temporary meters/hiring of meter charges 20Penalty for Harmonics variation above normal limits 21Hiring charges for CT/PT unit, CT metering cabinet,HT metering cabinet, Transformers & capacitors;Testing of LT CT’s, transformers, CT/PT units, relays,switchgears, transformer oil and LT & HT capacitors;Charges for standby transformer

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7 Application registration and processing charges 23

Sr. No. Description Page No. SECTION-III

COMMISSION’S ANALYSIS, TARIFFPHILOSOPHY AND DECISION ON ITEMWISESCHEDULE OF CHARGES

8 Service Connection Charges 24Service connection charges for overhead LT supply 24Service connection charges for overhead HT supply 26Service connection charges for underground LT supply 26Service connection charges for underground HT supply 27Cost of meter & meter box 27

9 Service Line Charges 2710 Miscellaneous & General Charges 29

Installation testing fee 29Reconnection Charges 30Changing location of meters within the same premises 30Testing of meters 31Replacement of meter cards for HT consumers 31Penalty for cheque bouncing 31Temporary meters/hiring of meter charges 32Penalty for Harmonics variation above normal limits 32Hiring charges for CT/PT unit, CT metering cabinet,HT metering cabinet, Transformers & capacitors;Testing of LT CT’s, transformers, CT/PT units, relays,switchgears, transformer oil and LT & HT capacitors;Charges for standby transformer

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11 Application registration and processing charges 3212 Applicability and Validity 33

13 Appendix-I 34

ANNEXURE

AnnexureNo.

Description PageNo.

1 Service Connection Charges for new Overheadconnection

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2 Service connection charges for new Undergroundconnection

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3 Cost of Meter and Meter Box 384 Miscellaneous and General charges 395 Application Registration & Processing charges 40

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Before theMAHARASHTRA ELECTRICITY REGULATORY COMMISSION

World Trade Centre, Centre No.1, 13th Floor, Cuffe Parade, Mumbai 400 005Tel. No. 022 22163964/65/69 – Fax 022 22163976

E-mail [email protected] Website: www.mercindia.org.in

Case No. 70 of 2005

IN THE MATTER OFApproval of MSEDCL’s Schedule of Charges

Dr. Pramod Deo, ChairmanShri A. Velayutham, MemberShri S. B. Kulkarni, Member

ORDER

Dated: September 8, 2006

Preface:

Presently, Maharashtra State Electricity Distribution Company Limited (MSEDCL) isrecovering various charges from the consumers for the services, besides supply,provided to them as per the MSEB’s Conditions and Miscellaneous Charges forSupply of Electrical Energy. Most of these charges are in force since July 1999,except Service Line Charges, which are in force since 1991.

Till the enactment of Electricity Act (EA), 2003, MSEB was a vertically integratedelectricity board, having activities of Generation, Transmission and Distribution ofelectricity in the State of Maharashtra, formed under the provisions of Electricity(Supply) Act, 1948.

The Government of Maharashtra notified the Provisional Transfer Scheme underSection 131 (5) (g) of the EA, 2003, on 6th June 2005, under which the four successorCompanies of the erstwhile MSEB, including MSEDCL, the distribution arm, wereformed. The MSEDCL has been registered with the Registrar of Companies, Mumbaion 31st May 2005 bearing certificate U40109 MH 2005 PLC 153645 under theCompanies Act, 1956.

Section 50 of EA, 2003 provides that the State Electricity Regulatory Commission,hereinafter referred to as the Commission shall specify an Electricity Supply Code tobe adhered to by the Distribution Licensee in the State. Accordingly, the MaharashtraElectricity Regulatory Commission (MERC) has issued Electricity Supply Code andOther Conditions of Supply Regulations, 2005 effective from January 20, 2005.

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As per Regulation No. 18 of the Supply Code Regulations, the distribution licenseesare required to file with the Commission for approval, a ‘Schedule of Charges’ forsuch matters required by the distribution licensee to fulfill its obligation to supplyelectricity to consumers under the Act and other relevant Regulations.

Accordingly, MSEDCL submitted the ‘Schedule of Charges’ payable by itsconsumers vide letter dated 2nd April 2005, and subsequently by their letter dated15th June 2005, the Terms & Conditions of Supply, for the approval of theCommission.

The Commission in exercise of the power vested in it under the provisions of MERC(Electricity Supply Code and Other Conditions of Supply) Regulations, 2005 and allother powers enabling it in this behalf, and after taking in to consideration, all thesubmissions made by MSEDCL, all the objections and issues raised during publichearing, the responses of MSEDCL, and all other relevant material, herebydetermines the Schedule of Charges for various services provided by MSEDCL.

I: Background and Process

1.1 MSEDCL’s Proposal:MSEDCL has proposed that, the existing charges categorized in three broadcategories, namely, (a) Service Connection Charges, (b) Service Line Charges and (c)Miscellaneous and other Charges are to be continued.

They have given the proposed charges on the following assumptions:a) The proposed “Schedule of Charges” is worked out on cost plus basis.b) For working out the Service Connection Charges, the cost data referred is as per actual CPA (Central Purchase Agency) rates and has been compared with the retail rates.c) Cross-subsidization is not resorted to (except in isolated cases).d) For working out the Service Line Charges the costing of the works required for release of supply is worked out on average basis.e) A uniform rate per kW is arrived at and this rate is taken on average pro-rata basis.f) The rate per kW remains the same for Urban and Rural areas.g) Due weightage is given to practical usage of electricity in Urban areas, rural areas and kaccha / pukka premises also (pukka with RCC Slabs / roofs).h) Proposed recovery of Service Line Charges in respect of Agricultural Connections are based on the actual cost.i) The Service Line Charges are worked out considering the network /Infrastructure requirements of 22 / 11 KV downwards.j) Since the cost of infrastructure is worked out on average basis, a major rationalization has been carried out in the different categories of erstwhile Service Line Charges.k) The miscellaneous and general charges are worked out on notional basis.

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1.2 Regulatory Process:

On receipt of the proposal, after due scrutiny, the Commission in line with regulation18 of Supply Code decided to invite public comment/suggestions on the draftSchedule of Charges. Accordingly, a public notice dated 23rd January 2006 invitingsuggestions and objections from interested parties was published in Asian age,Business Standard, The Free Press Journal, Economic Times & Maharashtra Times inMumbai; Indian Express, Dainik Samna, Loksatta, Sakal, Navakal, Lokmat,Navbharat & Ratnagiri Times in all editions of Maharashtra on 25th January 2006.

MSEDCL was also advised to make available copies of MSEDCL’s petition, forinspection and acquiring to the members of public at MSEDCL’s office and also hostthe same on MSEDCL’s web site (www.mahadiscom.in). The last date of filingwritten objection was fixed as 23rd February 2006, which allowed a period of onemonth to the public to enable them to file their objections.

The Commission received 42(forty two) written objections/comments regardingproposed Schedule of Charges submitted by MSEDCL. The Commission alsoadmitted objections filed during the Public hearing, which was held on 28th February2006 in Mumbai. List of Objectors to the MSEDCL’s proposal on ‘Schedule ofCharges’ is annexed at Appendix-I. Based on the various objections received andproceedings during Public Hearing, the Commission directed MSEDCL to submittheir response within 15(fifteen) days. MSEDCL finally submitted their response on10th April 2006, interalia, revising rate schedules of certain items based onobjections/suggestions received during public hearing.

The Commission has ensured that the due process contemplated under law to ensuretransparency and public participation, has been followed at every stage meticulouslyand an adequate opportunity was given to all the persons concerned to file their say inthe matter.

The Commission after taking into consideration all the objections, including thesubmissions and responses of MSEDCL, issues raised during the Public Hearing andall other relevant material, issues the order as per following structure having threesections.

Section I covers Preface, Background and Regulatory Process.

Section II is covering –• MSEDCL’s proposal, dealt itemwise• Under each item the objections received• MSEDCL’s response to such objections• The Commission’s ruling on each item.

Section III is covering –• Commission’s Analysis and Tariff Philosophy towards determination of itemwise charges• Applicability and Validity.

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II - Item-wise, proposal of MSEDCL, summary of objections received, responsefiled by MSEDCL and the Commission’s ruling is as under:

Item: Service Connection Charges

1) Service Connection Charges for overhead LT Supply.

1.1 MSEDCL’s Proposal1.1.1 The proposed Service Connection Charges are enclosed at annexures to the

proposal dated 2nd April 2005.1.1.2 In the proposed charges, the fixed length of service wire is 30 (thirty) metres

and variable charges are proposed to be made applicable only up to further15(fifteen) metres.

1.1.3 The Service Connection Charges are worked out at actuals based on CPA (Central Purchase Agency) rates for various components. However, it is

proposed to continue with the existing Service Connection Charges for loadsup to 0.5 kW & for HT consumers.

An option is proposed to be given to the consumers to procure the required materialand make payment of only 10% of normative service connection charges to theMSEDCL towards overall supervision and connection release charges.

Proposed charges for abovesaid purpose by MSEDCL are indicated in Annexure – 1.

1.2 ObjectionsMumbai Grahak Panchayat (MGP) mainly objected to the escalated rates of thematerials required for releasing new connections. According to MGP the chargesshould have been at CPA rates & not at retail prices, which according to them arehigher than CPA by about 30 % to 50 %. They have further commented that this kindof higher charges would discourage the consumers from paying for the material &instead they may choose to buy it from the market on their own. In this process theefficiency of the Distribution network may get affected resulting in higher T & D/System losses.

They have further stated that variable charges should not be based on cost of 30metres of cable & other material; instead it should be on actual materials required.They have also said that the charges should be at CPA rates plus direct charges of5%. This suggestion, according to them if accepted by the licensee, would generatemore revenue by way of reduction in energy loss and thereby through the charges(additional sales) collected from the consumers.

Vidarbha Industries Association (VIA) has strongly opposed levying of ServiceConnection Charges on the ground that when the licensee has separately proposedvarious charges under different heads i.e. Service Line Charges, Applicationprocessing charges, Cost of Meter, supervision charges etc., then there is nojustification of collecting service connection charges from the consumer. Duringpublic hearing Shri R. B. Goenka suggested that service wire upto the length of 30metres should be provided free of cost.

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Maharashtra Rajya Veej Grahak Sanghatana in principle has no objection to thelevying of Service Connection Charge, but their objection is for the proposal ofminimum 30 metres length of the service line. They have requested to reconsider theminimum length of the service line. They have also objected to the working of theService Connection Charges on the basis of retail prices, which are higher by about30 %.

Solapur Zilla Yantramag Dharak Association has offered identical comments as thatof Maharashtra Rajya Veej Grahak Sangathana.

Maharashtra Electricity Consumers Association (MECA) stated that most of the timethe licensee does not have the required material in its stock and the consumers areasked to buy the same at their own cost. Hence MSEDCL should not be permitted tolevy any charges towards Service Connection, and instead the licensee may ask theconsumers to buy the material and levy only the supervision charges @ 2 % of thelabour charges.

Industrial Co- operative Association Ltd, Malegaon has a general objection to theSchedule of Charges stating that it will have adverse effect on power loom industry.

Nasik Industries & Manufacturers Association (NIMA) has stated that it is a normalpractice of the licensee to ask the consumer to provide the required material andhence MSEDCL do not incur any expenditure on this work. Shri MadhukarBrahmankar suggested that Service Connection Charges should be totally dropped &MSEDCL has no authority to collect such an amount from the consumers to constructand develop its own assets.

Kolhapur Zila Dalap-Kandap Girani Malak Sangh has suggested that the licenseemay levy Service Connection Charges at reasonable rate only where the distributionnetwork is not available and in other cases they should levy the charges atconcessional rates. They have objected to the practice of asking consumer to buy thenecessary material, as the consumer purchases the same of inferior quality to save hismoney, which will finally have adverse effect on distribution system.

Tata Motors Ltd. has suggested that Service Connection Charges to be recovered byMSEDCL should be based on average /normative rates worked out by consultantslike SICOM & not on the estimate of a local engineer of the licensee. Besides, theapplication form for electric supply should clearly define the MSEDCL’s scope ofwork and the material required under Service Connection Charges to ensure totaltransparency to the consumer.

Maharashtra State Power loom Federation has objection to minimum length of 30metres service line, saying that in many cases it is very much less than 30 metres.They also have objected to retail rates indicated in the respective annexures to theproposal, which are 30 % higher than that of CPA rates.

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Shri Pankaj Muni, Kamalesh Shah, Sunil Saraf have jointly submitted their objectionsto the costing based on 30 metres length and have said that the charges should bebased on estimated cost of actual work involved. And if at all it has to be normativethen it should be irrespective of length involved and not in two parts. They have alsoraised objection to the prices, which are on higher side by 25 to 30 % than that ofbulk purchaser.

Shri Nikit Abhyankar representing Shri Khedkar of Akhil Bharatiya GrahakPanchayat (ABGP) stated that he has not received SICOM’s comments and annexureH of proposed Schedule of Charges from MSEDCL, as was published in the publicnotice and on this ground itself the Commission should reject the proposed Scheduleof Charges. He had no specific comment on Service Connection Charges.

Malegaon Power loom & Sarvajanik veej Grahak Sangh objected to the proposedSchdule of Charges and requested the Commission to reject the proposal ofMSEDCL.

Malegaon Industries & Power loom Association pointed out that the proposal hasbeen submitted by the MSEDCL after the given period of one month of notificationwithout giving any reasoning /explanation for such delay. Hence prima facie it needsto be dismissed.

Shri Ashwin Treasurer on behalf of Thane Small Scale Industries Associationsubmitted that Service Connection Charges should not be recovered from theconsumer at the time of extension of load.

Shri Ravi Anand of Electrical Consumers Association (ECA) stated that it is the dutyof Licensee to bring supply upto distributing mains and beyond that the cost is to beborne by the consumer. He further stated that MSEDCL should submit a freshproposal considering market rates.

1.3 MSEDCL’s Response

1.3.1 MSEDCL has clarified about the distinction between distribution mains andservice connection with the help of various provisions of EA, 2003. MSEDCL hasmade a submission to the Commission that for the purpose of determination ofSchedule of Charges the distribution main should be considered as the nearestavailable and technically feasible distribution network to which theapplicant/consumer can be connected. It is also required to make distinction betweenapplicability of Service Connection Charges, Service line charges and the estimatedactual cost.

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1.3.2 Service Connection Charges are payable by the applicant for connecting thepremises where connection is required to the nearest distribution infrastructure and itdoes not include any cost towards any additional infrastructure work for providingsupply to the applicant. MSEDCL has pointed out that the recovery of SCC ispermitted under regulation no. 3.3.1 of the Supply Code Regulations issued byMERC.

If the distribution main is available from where electric line is required to be providedto the applicant’s premise or some plant is required to be set up, such expenses can berecovered as Service Connection Charges by the distribution licensee.

1.3.3 As regards rates of materials, MSEDCL has clarified that they purchase variousmaterials through their Central Purchasing Agency (CPA); the time involved inarranging the purchases is significantly higher considering the process of tendering ithas to follow. Therefore MSEDCL has empowered the local offices to purchase thenecessary items from the local retail market so as to meet the supply obligation statedabove. The cost available in the local market is higher by 30% to 40 % on an averageas compared to the bulk procurement CPA rates.

MSEDCL further submitted that the CPA rates used for the calculation of SCC at thetime of proposal have under gone significant change since the time of filing and needto be revised. MSEDCL is willing to consider the revised CPA rates, without anyescalation for retail rates for computation of Schedule of Charges.

1.3.4 The actual work involved for providing connection to different consumers mayvary depending upon factors such as the type of consumer, required load, voltagelevel and distance. Hence the Schedule of Charges is generalized provision applicableto all the consumers, as it cannot be made specific to individual consumer on a case-to-case basis. MSEDCL has given the reference of Regulation 3.3.1 of the SupplyCode Regulation in respect of recovery of such expenses on the basis of average ornormative rates.

MSEDCL has also indicated their agreement to consider 20 metres as averagenormative length in place of the average normative length of 30 metres of the serviceconnection. The revised schedule submitted is based on 20 metres as the averagenormative length & revised CPA rates.

1.4 Commission’s RulingIn order to simplify the procedure while releasing the connection, the Commissionhas decided to dispense with the measurement linked variable charges. TheCommission has further decided to rationalize the normative charges by reducing theload slabs proposed by MSEDCL. The normative Service Connection Charges asapproved by the Commission are indicated in Annexure-1.

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The Commission approves a rate of 1.30% of the normative charges to be recoveredtowards supervision charges in case MSEDCL permits an applicant to carry out theworks through a Licensed Electrical Contractor.

In case a consumer applies for an additional load/contract demand i.e. extension ofload and if the release of additional load/contract demand entails any works, theCommission allows MSEDCL to recover the normative charges for the totalload/contract demand (existing as well as additional load) as per the applicable loadslabs indicated in Annexure - 1 and 2. [For detailed Ruling refer Section-III (1)]

2) Service Connection Charges for overhead HT Supply.

2.1 MSEDCL’s proposalThe existing Service Connection Charges are proposed to be maintained as perexisting rates for HT consumers.Proposed charges by MSEDCL are indicated in Annexure – 1.

2.2 ObjectionsIspat Industries Ltd has demanded calculations/ working sheets for ServiceConnection Charges in respect of EHV/Industrial loads. Secondly they have statedthat these charges should not be levied in the case of additional load sanction, whereMSEDCL do not invest on lines/connection.

Malegaon Industries & Power loom Manufacturers Association has objected to retailrates, which are about 30% higher than that of CPA. They have further contended thatthe working sheet of Service Connection Charges for HV/EHV supply is notprovided.

Shri R B Goenka on behalf of VIA stated that even the SCC of Rs. 30000/- (Rupeesthirty thousand) presently being collected up to the load of 1000 kVA by theMSEDCL from HT consumers, has no justification whatsoever, and such ServiceConnection Charges should be waived off.

2.3 MSEDCL’s responseMSEDCL has proposed to continue with the same service connection charges as arepresently applicable to high-tension consumers and therefore working sheet for thesame has not been submitted. MSEDCL has proposed Service Connection Chargesapplicable to the high-tension consumers at the flat rate of Rs.30000/- for the first1000 kVA and further at the rate of Rs. 20/- per kVA for Contract demand exceeding1000 kVA. They have further stated that the rate of Rs. 20/- per kVA may thereforenot to be interpreted as variable charge.

2.4 Commission’s RulingThe Commission decides to introduce only two slabs namely a) upto 500 kVA & b)above 500 kVA and directs MSEDCL to charge in two slabs i.e. upto 500 kVA &above 500 kVA as indicated in Annexure-1. [For detailed Ruling refer Section-III (2)]

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3) Service Connection Charges for underground LT Supply.

3.1 MSEDCL’s ProposalAs per the existing practice, applicant is required to procure all the materials andmake payment to the MSEDCL as per normative charges proposed in the respectiveannexure to the proposal.Proposed charges by MSEDCL are indicated in respective annexure of the proposal.

3.2 ObjectionsMalegaon Industries & Power loom Manufacturers Association has objectedto levy of charges for underground service connections stating that in the case whenapplicant is supplying the required material, it is not clear whether the proposedsupervision charges are based on the material cost or on the labour charges.

Kolhapur Zila Dalap Kandap Girani Malak Sangh has suggested thatunderground connection should be done by the licensee himself instead of asking theconsumer to do it & recover the charges from the consumer in installments.

Shri Pankaj Muni, Kamalesh Shah, Sunil Saraf have demanded details of charges forunder ground cable so that the proposal can be studied.

3.3 MSEDCL’s responseFor providing underground service connection, it has been proposed that theprospective consumer shall bring his own material and shall be liable to onlysupervision charges, which shall be 15% of the cost of labour. In view of the above,the working sheets for estimation of the service connection charges for undergroundservices, has not been annexed.

3.4 Commission’s RulingMSEDCL has proposed some normative rates for underground LT connectionswithout furnishing any working sheets for the same, if applicant brings all serviceconnection materials. In absence of the working sheets, the Commission has workedout the rates for new underground LT supply based on the market rates of thematerials and work estimation. The normative rates approved by the Commission areindicated in Annexure-2. In case MSEDCL permits an applicant to carry out theworks, the MSEDCL may recover supervision charges at the rate of 1.3% of thenormative rates indicated in Annexure-2. [For detailed Ruling refer Section-III (4)]

4) Service Connection Charges for underground HT Supply.

4.1 MSEDCL’s ProposalMSEDCL has not indicated charges for underground connections for HT consumers.

4.2 ObjectionsNo specific comments/objections were raised either in written submissions or duringpublic hearing on this item.

4.3 MSEDCL’s ResponseThere is no response from MSEDCL on this item.

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4.4 Commission’s RulingIn absence of any proposal for underground HT supply, the Commission has workedout the rates based on the market rates of the materials and work estimation. Thenormative rates approved by the Commission are indicated in Annexure-2. [Fordetailed Ruling refer Section-III (4)]

Item: Cost of meter and meter box

5.1 MSEDCL’s ProposalMSEDCL has proposed rates for various types of meters with & without box in theirSchedule of Charges as indicated in Annexure -3.

5.2 ObjectionsMECA suggested that MSEDCL should install protective device for the meter toavoid frequent burning of the meter.

NIMA has expressed their strong objection on this issue stating that it is the propertyof the licensee under the provisions of Electricity Act, 2003 & IE Rules, 1956 and itis illegal to recover the cost of such equipments.

Kolhapur Zila Dalap Kandap Girani Malak Sangh has suggested that the licensee maylevy appropriate price of the meter and the meter box but MSEDCL should havetransparency in the levy of such charges.

Maharashtra State Power loom Federation has not commented on the proposedcharges for meter & meter box but they have cited one case of Bhivandi where evenat present the collected cost of the meter is more than the proposed cost in theschedule of charges under consideration for the approval of MERC.

Dr. Ashok Pendse on behalf of MGP said that the proposed charges for Meter aremuch higher than the market rates. For example, single-phase electromagnetic metercosts about Rs. 200 /- in the market, where as MSEDCL is asking Rs. 1000/- for thesame.

5.3 MSEDCL’s responseCost of meter is applicable only in case the consumers opt to purchase the meter fromthe licensee or in case of burnt or lost meter, since as per the Supply CodeRegulations 14.2.4, except in the case of a burnt meter or a lost meter, the distributionlicensee shall not be authorized to recover the price of the meter more than onceduring the continuance of supply to the consumer.

5.4 Commission’s RulingThe Commission directs MSEDCL not to recover any cost towards meter and meterbox except where the consumer opts to purchase the meter from MSEDCL and incase of lost and burnt meter (Regulation 14.1 & 14.2 of Supply Code). The chargesapplicable in case the consumer elects to purchase the meter from MSEDCL & in

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case of lost and burnt meter are indicated at Annexure-3. [For detailed Ruling referSection-III (5)]

Item: Service Line Charges

6.1 MSEDCL’s Proposal

The proposed Service Line Charges has been worked on the basis of averageexpenditure that would be required for creating infrastructure.The average cost of 11 / 22 KV line, distribution transformer and the Low Tensionline are considered with diversity factor of 1.3. The working details of average costper KW are given in respective annexures enclosed with the proposal. In case of new/ existing town ship loads, specially in respect of CIDCO, MIDC, MHADA coloniesand also township developments by private entities, the total infrastructuredevelopment costs on normative basis have been considered after taking into accountthe 33 KV network also, since that will be required for release of such supplies. Thedetails of the normative service line charges in respect of these types of townships aregiven in separate annexures enclosed with the proposal.

The different sub-categories in residential and commercial segments have beenrationalized and the practical loading pattern for Urban and Rural areas have beenconsidered differently for arriving at the service line charges. Specific weightage isgiven to fact that practically the usage of electricity in rural area for the domesticactivities is lower than that of urban areas.

MSEDCL has also proposed that the rate for kaccha constructions including huts andslums will be half of the rates given in respective annexures for both urban and ruralareas.

MSEDCL has further proposed to carry out rationalization in respect of differentcategories of HT & LT industries and apply a uniform rate of Rs. 650 per kVA(existing rate for normative service line charges for EHV consumers or non-SSIconsumers). Further, the rates for industries will be half in rural areas. These rates areproposed irrespective of geographical location of the industry, only categorizationbeing urban and rural areas, as will be notified by the Government. This is proposedin order to encourage industrial growth in rural areas.

MSEDCL has proposed to introduce service line charges in respect of agriculturalconnections. The details for the infrastructure development required for release ofagricultural connections on average basis are also given.

6.2 ObjectionsVIA has objected to the levy of these charges saying that it is against the provisionsunder the Electricity Act, 2003. Shri R B Goenka stated that under the Section 46,Section 42(1) and Section 43(2) of EA, 2003, it is the duty of the licensee to provideinfrastructure. There should be a threshold beyond which the scope of the consumershould start. This scope of consumer should start beyond the distribution mains. He

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also cited Section 43 of EA, 2003, “It shall be the duty of every distribution licenseeto provide, if required electric plant or electric line for giving electric supply to thepremises, specified in sub section (1)”. He stated that MSEDCL can recover the costof plant and equipment only if the consumer requires dedicated or express feedersspecifically used by him. He further added that the MSEDCL has taken the cost of 33KV Sub station, 33 KV lines, Distribution transformer, etc. for arriving the normalcost. However as per the provisions of EA, 2003, MSEDCL cannot charge 33kV &11kV infrastructure beyond distribution mains. Further the expenditure incurred by the licensee for the development & strengtheningof the distribution network /infrastructure becomes the part of ARR and is dulyconsidered by way of appropriate provision in tariff rates.

Shri S D Damle suggested that since the collection of Service Line Charges is forbuilding a healthy distribution system, MERC should permit the licensee to levy suchcharges at fair & reasonable rates. He has further said that the amount so collectedunder the head SLC by any sub division of the licensee must be spent in the same subdivision for the improvement / strengthening of distribution network and not for anyother assets like buildings, vehicles etc. Also this kind of utilization of the funds asabove should be monitored and controlled.

Maharashtra Rajya Veej Grahak Sanghatana, Solapur Zilla Yantramag DharakAssociation, Maharashtra State Power loom Federation and Halari Power loomOwners and weavers Association have strongly objected to these charges on theground that other licensees do not seem to levy this charge.

MECA has objected to the levy of these charges stating that it is contrary to theprovisions under section 42 of EA, 2003 and hence this proposal should be rejected.

Malegaon Industries & Power loom Manufacturers Association has stated thatSection 42 of the EA, 2003 provides that the infrastructure development is the duty ofthe licensee. Shri Shahid Ansari requested that the proposal should be rejected, as itwas not submitted within specified time after the MERC notification.

NIMA has stated that unit charges are inclusive of generation, transmission &distribution cost, hence separate Service Line Charges should not be demanded fromthe consumers. They have further stated that if these charges are levied, the initialcost of new connection will become very high and prospective consumers will tend toresort to pilferage /theft for not getting service line from the licensee. Shri MadhukarBrahmankar objected to the classification on the basis of Rural /Urban area. He addedthat SLC and SCC should not be recovered from the farmers. Also SLC should not becollected at the time of additional load requirement, as there are no infrastructureactivities involved.

Tata Motors Ltd. has stated that these charges are justified only when the costs of theitems required for service line are not getting reflected /included under capital workprovisions made under ARR, because MSEDCL normally receives the finance /fundsfrom REC/PFC or other financial institution for such type of work.

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Shri U M Joshi & S W Pasarkar, members of MGP, Thane Division have objectedsaying that it is against the law. Shri Ujwalraj Joshi submitted that they have notreceived feedback regarding copy of proposal from MSEDCL. MSEDCL’s proposalon SLC does not mention regarding penalty, which may be considered.

Shri Pankaj Muni, Kamalesh Shah, Sunil Saraf have objected on the ground that asper Supply Code Regulations & provisions under Section 42 of EA, 2003, it is theresponsibility of the licensee to develop the infrastructure

MGP has strongly objected to the levy of these charges as it goes against theprovisions under section 42(1) of Electricity Act 2003. The existing method ofcharging SLC & SCC should be scrapped and only SCC should be allowed inaccordance with provisions of the law.Dr. Ashok Pendse explained the difference between the Service Connection Chargesand the Service Line Charges. He raised several objections against the proposedService line charges with following reasons:

a) In open access system, whenever it becomes effective, the MSEDCL will be able to recover the cost of Service line from anybody who gets the supply through that line.

b) He referred to the preamble of APDRP in which four objectives are mentioned: i) Reduction in T & D Losses,

ii) Increase in collection efficiency, iii) Increase in the consumer mass /no. of consumers and iv) Convenience to consumers.

The third objective of APDRP relates basically to capital expenditure. TheCommission is allowing expenditure for works covered under APDRP for developinginfrastructure, as developing infrastructure is the responsibility of utility. If theCommission accepts this principle then there cannot be any SLC at all, simply on theground that it is the responsibility of the utility to lay the network. He further statedthat he is aware of financial difficulty faced by MSEDCL as on today. Under thecircumstances, the Commission may partially approve some of the charges, whichcan be recovered from the consumers, like Regulatory Liability Charge and refund itto the consumers after six months. This can be a temporary measure, as the MSEDCLmay not be having Capital expenditure sanctioned for distribution networkdevelopment. As a principle, it is the responsibility of the Distribution Licensee todevelop necessary infrastructure.

c) Dr. Pendse further stated the need for defining the point from which theresponsibility of the consumer starts. He added that this can happen at differentvoltage levels and once it is defined and accepted by the Commission for MSEDCL,the same will be applicable to other utilities like BEST, TPC, REL as there should bea common methodology.

d) He raised objection about the method of charging on the basis of the square feetarea of the premises for which the supply is required. He also stated that there shouldnot be any discrimination on the basis of the locality such as whether it is in CIDCO,

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MHADA or any other society. The charges should be on the basis of the loadrequirement and not on the basis of a carpet area. He also stated that the other utilitieslike Telecom, Income tax dept.& Water supply do not levy charges based on thecarpet area.

Shri Nikit Abhankar stated that he is also of the same opinion as that of Dr. Pendse,that the licensee cannot recover the cost of infrastructure development from theconsumers. It has to be passed on through the ARR in the tariff revision process.Hence this item should be excluded from the proposal.

Shri Bhalachandra on behalf of ISPAT stated that the basis of calculation of SLC &SCC be made available to the consumers. He also said that in case of additional loadsanction, the SLC or SCC should not be charged. His point was that there is nospecific time frame stipulated for categorization of Urban / Rural to take effect andrequested MERC to expedite it. He said that ISPAT Industry be categorized underRural area whereby SLC rates will be half. This categorization should be madeeffective with retrospective effect, whereby the already paid SLC at higher rate berefunded or adjusted against the SLC required for additional load. His next point wasabout the penalty for excess demand, which is proposed three times of SLC. Hesubmitted that penalty for exceeding the contract demand is a Tariff issue and it is notclear as to how it can be linked with SLC. Finally he requested the Commission thatin case any new consumer is brought under SLC then correspondingly SLC should bereduced to EHV consumers.

Shri Faizan Ahmad Azmi of Maharashtra State Power loom Federation, Bhiwandistated that as per their knowledge other distribution companies in the State do notrecover SLC from the consumers. He further stated that as per Supply Code, theDistribution Licensee should not take SLC. He also mentioned that the CPA ratesshown in the proposal are 30 % higher.He also pointed out that in Bhiwandi SLC from non-SSI power looms is beingcollected at the rate of Rs 1300/- per HP instead of Rs 650/- as shown in the proposaland requested the Commission to look in to the matter and direct the MSEDCL torefund the excess amount collected so far.

Shri Chandulal J. Sumaria of Halari Power loom Owners and weavers Associationsubmitted that the actual collection and the rates mentioned by MSEDCL in theproposal are different and requested the Commission to conduct an enquiry.

Shri Ashwin Treasurer of Thane Small Scale Industries Association submitted that asper Section 43 of EA, 2003 and Regulation 3.3 of supply code, service line only fromDistribution main has to be charged to the consumer. For augmentation in distributioncapacity, it is to be charged on pro rata basis. He further stated that in case ofdedicated line only a small cost towards transformer be recovered from the consumer.There cannot be transformer cost involved in every service connection charges. He further stated that as regards the issue of type of the structure i.e. Kachha-pucca, the licensee has not studied the Act and Regulations. The entire Schedule isirrational & arbitrary. The method of charging on the basis of square foot area isdebatable and should not be considered for approval.

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6.3 MSEDCL’s responseMSEDCL has attempted justification for levy of Service line Charges and referredto Regulation nos. 3.3.2, 3.3.3 & 3.3.4 of Supply Code Regulations.

The proposed charges include normative expenditure towards HT line, DistributionTransformer and the cost of additional infrastructure to be created for bringingdistribution network closer to the applicant’s premises.

MSEDCL has also clarified that it would recover the actual estimated expenditurefrom the consumers on proportionate basis, in case it is necessary to augmenttransformer capacity in the substation and /or augment the capacity of subtransmission and distribution system for providing power supply to the consumers.

MSEDCL has clarified that for a dedicated distribution system, the MSEDCL wouldrecover the actual estimated expenditure from the consumer as stipulated underRegulation 3.3.3 of the Supply Code Regulations.

As regards objections raised by various members of the public on the issue ofdifferential charges for Rural –Urban, Kutchha – Pukka structures, MSEDCL in theirresponse has mentioned that this is the concession offered by the licensee to a weakersection of the society so that they are able to have access to the electricity asstipulated under the National Electricity Policy & Plan. It is a business practiceadopted by MSEDCL for ensuring speedy implementation of the national goal ofpower for all.

MSEDCL has interpreted the provisions of Section 45 of EA, 2003 that though thedistribution licensee has to provide electric line, or electric plant required for thepurpose of giving supply to the consumer, the cost of the same has to be paid by theconsumer.

MSEDCL has further added that the licensee is entitled to recover charges towards anelectric line or electric plant or electric line up to Distribution main, in case nearbydistribution mains is not available, and such charges are being claimed by thedistribution licensee as SLC charge. The said claim according to MSEDCL isperfectly legal and proper.

The Service line Charges are to be recovered towards providing power supply facilityat appropriate voltage level up to the applicant’s premises and for recovery of costtowards the relevant common network.

The SLC Charges are required to be recovered from the applicant, as it is extraburden on the distribution licensee to provide electricity to the consumer, asDistribution licensee is duty bound to supply electricity on the request of theconsumer. MSEDCL further submitted that section 46 read with section 43 of theElectricity Act, 2003, means that expenses required for electric plant or line can berecovered along with reasonable expenses required for laying such line or plant.

MSEDCL submitted that most of the capital expenditure schemes financed by REC orPFC are primarily directed at system augmentation and improvement and not forexpansion.

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6.4 Commission’s RulingThe Commission totally rejects MSEDCL’s proposal to recover Service Line Chargesfrom the prospective consumers except in cases of consumers requiring dedicateddistribution facility. As per the provisions of the Act, developing infrastructure is theresponsibility of Licensee. The Commission, therefore directs that the cost towardsinfrastructure from delivery point of transmission system to distributing mains shouldbe borne by MSEDCL. The recurring expenses related to the capital investment oninfrastructure shall be considered during ARR determination. [For detailed Rulingrefer Section-III (6)]

Item: Miscellaneous & General Charges

MSEDCL’s proposalMSEDCL has proposed enhancement of existing charges for some items. Theproposal also includes few items which are added for the first time in schedule ofcharges. Charges proposed by MSEDCL are listed in Annexures-4 and 5.

ObjectionsDuring the public hearing some of the objectors offered general comments on entireSchedule of Miscellaneous & General Charges.

Maharashtra Rajya Veej Grahak Sanghatana and Solapur Zilla Yantramag DharakAssociation have said that the Miscellaneous & General Charges should be based onaverage expenditure.

NIMA has objected to these Charges, as the same are totally unjustified.

Malegaon Industries & Power loom Manufacturers Association has stated that somecharges like relay testing, transformer testing, switchgear testing, service call charges,capacitor hiring charges, etc. are optional and there is no provision in the Act to levythese charges.

Specific objections were raised on some of the individual items of the Miscellaneous& General Charges.

Item wise Summary of Objections received, Response filed by MSEDCL and rulingof Commission is as under:

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7) Installation testing fee

7.1 Objection

ABGP, Pune has stated that first testing before giving connection should be free ofcharge.

7.2 MSEDCL’s Response The report of installation testing will be provided to the consumer.

7.3 Commission’s RulingThe Commission directs MSEDCL not to charge any amount for first inspection andtesting of consumer’s installation at the time of giving new connection. For all thesubsequent tests & inspection of the consumer’s installation as per the provisionsunder rule 53 of I E Rules, 1956, the charges proposed by MSEDCL are approved.[For detailed Ruling refer Section-III (7)(i)]

8) Reconnection Charges

8.1 ObjectionsMGP has said that there is a need for escalating these charges but not at the proposedrates, which are 315 % to 1600 % higher than existing rates.

VIA has stated that the proposed charges are very high and have not been justifiedwith any calculations of expenses incurred by MSEDCL for these services.

Kolhapur Zila Dalap Kandap Girani Malak Sangh has objected to the proposedreconnection charges saying that the same are 3 to 16 times higher than existing rates.The licensee may levy appropriate charges after duly checking the reason fordisconnection.

ABGP, Pune has stated that maximum charges may be Rs.1000/-.

Maharashtra State Power loom Federation & Shri Halari Power loom Owners andweavers Association have objected to the proposed reconnection charges saying thatthe same are 3 to 16 times higher than existing rates. The licensee may levyappropriate charges after duly checking the reason for disconnection.

Veej Grahak Samiti has objection to the proposed charges saying that the same arevery high.

Shri Sandeep Pasarkar stated that at times the disconnection is done withoutfollowing proper legal procedure. In such cases the ‘deterrent’ principle should beapplied to the concerned staff also and not only against the consumers. If it is a lapseon the part of the staff member the reconnection charge should be recovered from himand 50 % of that be refunded to the consumer and rest 50 % be retained by theMSEDCL.

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Solapur Zilla Yantramag Dharak Association stated that the Miscellaneous &General Charges are 3 to 16 times higher than existing rates and the charges shouldbe based on actual expenditure.

8.2 MSEDCL’s ResponseHigher charges have been proposed for reconnection of power supply as, such higherreconnection charges may, up to certain extent, act as a deterrent factor and may,motivate the consumers to pay the energy bills on time. This is for encouragingprompt payment and to discourage consumer from becoming defaulter.

8.3 Commission’s RulingThe Commission views the existing charges to be reasonable and reflecting the costinvolved based on the material and work estimation. However, in order to furtherrationalize the charges, Commission directs MSEDCL to recover reconnectioncharges as indicated in Annexure-4. [For detailed Ruling refer Section-III (7)(ii)]

9) Changing location of the meters within the same premise

9.1 ObjectionsMGP has suggested that the charge should be Rs.50 plus the cost of required materialif the location change is done at the request of the consumer. If the licensee wants todo it for his or her own reasons then entire cost including post meter work should beborne by the distribution licensee.

Veej Grahak Samiti has objected that the proposed rate of Rs. 100/- is very high.Existing rate of Rs. 30/- is in order.

9.2 MSEDCL’s ResponseThe charges for changing of location of meter are charged as per lump sum chargesand hence work sheet is not provided.

9.3 Commission’s RulingConsidering the average cost of material and labour involved in shifting of meter, thenormative charges of Rs. 100/- proposed by MSEDCL appears to be reasonable andthe Commission approves the proposed charges with the condition that this shouldcover the total cost including the cost of material required for changing the location ofthe meter at the behest of the consumer.

The charges for changing the location of meter within the premise will be applicableonly in cases where the shifting is to be done at the request of the consumer.However, when MSEDCL seeks to have the location changed on justified groundsuch as safety requirement etc., then the cost of such shifting shall be entirely borneby MSEDCL. [For detailed Ruling refer Section-III (7)(iii)]

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10) Testing of meters

10.1 ObjectionsMGP has stated that there is no data provided to work out the scope and cost oftesting. The consumer may be charged only if it is being done at his request and thelicensee should test the meter at least once in a year, at their own cost.

VIA has stated that the MSEDCL has not given any justification for the proposedcharges and also it is not clearly specified as to when these charges are to be paid bythe consumer.

MECA has suggested that the charges be revised to Rs. 25/- (Rupees twenty five)for single-phase meter, Rs. 50/- (Rupees fifty) for three phase meter, and Rs.100 /-(Rupees hundred) for H T purpose.

Veej Grahak Samiti has objected to the present system of testing the meters atMSEDCL stating that it is very old and there is no improvement in it, hence this hikeshould not be allowed.

ABGP, Pune has suggested that testing charges be fixed as Rs. 50/- (Rupees fifty) forsingle phase meter, Rs. 200/- (Rupees two hundred) for Poly phase meter, Rs.300/-(Rupees three hundred) for LT MD and Rs. 500/- (Rupees five hundred) for Tri-vector meter.

Shri Ashwin Treasurer of Thane Small Scale Industries Association said that as perRegulation 3.3.7 of Supply Code Regulations, the service line and the meter has to bemaintained by the licensee and as such they can not charge anything for testing ofmeter. He further added that the testing charges could be recovered from theconsumer, only if the consumer challenges the meter accuracy; it is tested in hispresence and found to be working in order and not in any other circumstances.

10.2 MSEDCL’s responseThere is no specific response from MESDCL on this issue.

10.3 Commission’s RulingThe Commission approves the charges for testing of meters as proposed byMSEDCL. [For detailed Ruling refer Section-III (7) (iv)]

11) Replacement of meter cards for HT consumers

11.1 ObjectionsMGP stated that meter card is the requirement of the licensee. Hence the chargeshould be levied only if the card is damaged or lost and not otherwise.

Veej Grahak Samiti has objected that the rate of Rs.25/- (Rupees twenty five) is notjustified & should be rejected.

Malegaon Industries & Power loom Manufacturers Association has stated that it isnot clear whether charges proposed are for damaged or lost meter card?

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11.2 MSEDCL’s ResponseThe charges for replacement of meter card are proposed for damaged or lost metercard.

11.3 Commission’s RulingMSEDCL has reportedly installed TOD meters to all HT consumers. The meters havedata storage with downloading features and data can be collected as and whenrequired. In view of above separate meter card may not be necessary. However, if theMSEDCL intends to continue this practice of maintaining the cards for HT consumer,they may do so at their own cost. In view of above, the Commission rejects theproposed charges for replacement of meter card for HT consumer. [For detailedRuling refer Section-III (7) (v)]

12) Penalty for cheque bouncing

12.1 ObjectionsMGP has stated that the penal charges should be on actuals levied by bank fordishonoured payment.

VIA has suggested that the penal charges should be based on actuals levied by thebank.

Maharashtra Rajya Veej Grahak Sanghatana, Veej Grahak Samiti and Solapur ZillaYantramag Dharak Association have stated that the charges proposed areunreasonable and should be rejected.

ABGP, Pune stated that these charges may be deleted as Negotiable Instruments Actcan take care of this problem.

12.2 MSEDCL’s ResponsePenalty of cheque bouncing though covered under the Negotiable Instrument Act isincluded in schedule of charges as these are the charges for expenses incurred byutility and also to have deterrent effect on the concerned consumer.

12.3 Commission’s RulingThe Commission approves the charges towards compensation of bank charges andMSEDCL’s administrative charges towards each of such specific cases as indicated inAnnexure-4. [For detailed Ruling refer Section-III (7) (vi)]

13) Temporary meters /hiring of meters charges13.1 ObjectionVeej Grahak Samiti has stated that these charges are not justified. It would be in orderif processing fee up to Rs.20/- (Rupees twenty) and meter rent of Rs.20/- (Rupeestwenty) is levied.

13.2 MSEDCL’s ResponseMSEDCL has responded to the objection regarding processing fees for temporaryconnection. However, there is no mention about hiring charges for meter inMSEDCL’s response.

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13.3 Commission’s RulingRegulation 3.3.6 empowers the licensee to recover all expenses reasonably incurredfor the purpose of giving temporary supply & for the purpose of discontinuance ofsuch temporary supply.Since the entire cost for temporary connection is to be borne by consumer, theCommission rejects the proposed charges for hiring of meter in case of Temporaryconnection. [For detailed Ruling refer Section-III (7) (vii)]

14) Penalty for Harmonics variation above normal limits

14.1 MSEDCL’s Proposal:MSEDCL has proposed penalty for Harmonics variation above normal limit of 3% asindicated in Annexure – 4.

14.2 Objections:Shri R.B. Goenka representing VIA submitted that the proposed limit of variationabove 3% in harmonics is without any technical justification. He further said that thelevel of the variation in Harmonics depends upon the fault level of supply system andpenalty for harmonics is a part of tariff determination process.

ABGP, Pune stated that as penalty for harmonics is a tariff related issue, the chargesmay be deleted.

14.3 MSEDCL’s ResponseThe suggestion regarding penalty for exceeding normal limit of harmonics will becharged as per MERC directives.

14.4 Commission’s rulingAs the Penalty for Harmonics is a tariff related issue, like that of power factor, theCommission in absence of any substantiated proposal, does not accept proposed penalcharges at this stage. [For detailed Ruling refer Section-III (7) (viii)]

15 Hiring charges for CT/PT unit, CT metering cabinet & HT metering cabinet,Transformers & capacitors; Testing of LT CT’s, CTPT unit, relays, 11/22kVswitchgears, transformers, transformer oil and LT & HT capacitors; Chargesfor standby transformer.

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15.1 MSEDCL’s proposal:The detailed rates as proposed by MSEDCL are indicated in the table below:

MISCELLANEOUS & GENERAL CHARGESSr.No.

Particulars Proposed (Rs.)

1 Hiring Charges per monthCTPT unit/setHT metering cubicle11Kv22kV33kV

50% cost of T/F as SecurityDeposit Plus 3% cost of T/F as

monthly rent.

2 Transformer hiring Charges 50% cost of T/F as SecurityDeposit plus 3% cost of T/F asmonthly rent

Testing of LT CT's 100 per setTesting of CTPT unitsa) At MSEDCL's laboratory 1500b) Testing & sealing of CTPT Unit 5000

3

c) At MSEDCL's filter unit centre laboratory & manufacturers/ consumer s premises

5000

Relay TestingAt site 600 per element or 1000 for

Complete Relay inclusive oftransport

4

At MSEDCL's laboratory 200 per elementor 500 for Complete Relay

5 11/22 kV Switchgear testingcomplete per Breaker

5000

6 Transformer Testing includingoil testing at site

i) Dist.Transformer 3000ii) Power Transformer 10000iii) Dist.Transformer Testing including

oil testing at MSEDCL's filter unit1000

7 Transformer oil Testingat MSEDCL's laboratory

a. Dielectric test; First sample 100

Subsequent sample 50Acidity test; First sample 50b.Subsequent sample 30

c. Crackle test; First sample 100 Subsequent sample 1008 Service Call

Charge for attendance of fuse manat consumers premises

200 per person(for every 4Hrs. or part thereof)

9 Capacitor Hire Charges(per KVAR per month)

10

10 Testing of LT capacitors 10 per KVAR11 Testing HT capacitors at cons.

premises on cons. request3000

( per MVAR or part thereof )

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15.2 ObjectionsMGP has stated that the proposed charges for CT/PT are almost double. As far asother items added for the first time are concerned, the basis of working out thesecharges is not given. As regards other items, Mumbai Grahak Panchayat has statedthat these are all optional items. It is the responsibility of the licensee and there is noprovision in the Act, hence it should not be granted. They further stated that Servicecall charges should be Rs. 50/- (Rupees fifty) per hour instead of Rs. 200/- (Rupeestwo hundred) per 4 (four) hours and part thereof.

VIA has stated that the proposed charges should be based on the cost of equipmentwith a calculation for interest and depreciation on the cost of equipment. They furtherstated that the proposed charges are very high and without any basis of calculations.

Veej Grahak Samiti has objected that the proposed rates are very high and there is aneed to consider the basic cost of the equipment and the hiring charges levied on it,hence this proposal should not be sanctioned. It is the responsibility of the licenseeand hence even existing charges should be abolished.

15.3 MSEDCL’s ResponseHiring charges are optional charges and will be applicable only when the consumerwill opt to hire any of the equipment owned by MSEDCL.

15.4 Commission’s RulingCharges proposed for providing various types of equipments to the consumer are onhire basis and charges for testing of equipments belonging to consumer cannot beconsidered under Schedule of Charges, as these are non-regulatory items generating‘other income’ for the licensee.

Item: Application registration and processing charges

16.1 ObjectionsMGP has stated that there is no justification/ reasoning for the rise of 100 to 500 %,hence existing charges may be continued.

ABGP, Pune stated that the processing charges should be minimum. They havesuggested charges of Rs. 10/- (Rupees ten) to 25/- (Rupees twenty five) for LTconsumers & Rs. 100/- (Rupees hundred) for HT consumers.

VIA has stated that these charges should be based on actual quantum of workinvolved. Shri R B Goenka stated that the MSEDCL should carryout following worksafter payment of application processing fees by the consumer:

i) Inspection of consumer’s point of supply and survey lines to be erected. ii) Preparation of layout and the drawings for the works to be carried out. iii) Provide specification of the equipments along with the bill of quantities of material to the consumer for carrying out the work. iv) Detailed cost estimate along with the demand note for supply of power with calculation of security deposit to be paid by the consumer.

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16.2 MSEDCL’s ResponseMSEDCL has responded that the rates of processing fees are calculated on lump sumbasis.

16.3 Commission’s RulingThe Commission allows MSEDCL to collect the amount towards the applicationprocessing or receipt thereof at nominal rates as indicated in Annexure-5. [Fordetailed Ruling refer Section-III (8)]

III - COMMISSION’s ANALYSIS, TARIFF PHILOSOPHY AND DECISION ON ITEMWISE SCHEDULE OF CHARGES

Service Connection Charges:

1) Service Connection Charges for overhead LT Supply.MSEDCL has proposed two separate charges towards cost involved inreleasing new connections namely, Service Connection Charges (SCC) &Service Line Charges (SLC). It becomes necessary to clearly distinguishbetween the works involved in SCC & SLC.

As per the EA, 2003, ‘Distribution system’ means ‘the system of wires andassociated facilities between the delivery points on the transmission lines orthe generating station connection and the point of connection to theinstallation of the consumers [Section 2(19)]. Further, ‘Distributing main’has been defined as ‘the portion of any main with which a service line is, or isintended to be, immediately connected [Section 2(18)].

Section 42(1) of the Act stipulates that ‘it shall be the duty of the distributionlicensee to develop and maintain an efficient, co-ordinated and economicaldistribution system in his area of supply .’.

From the schedule of charges proposed by MSEDCL it is observed thatService Line Charges basically covers the cost of infrastructure between thedelivery points on the transmission lines and the distributing mains. Whereas,Service Connection is interpreted as a link between Licensee’s nearestdistribution points (i.e. distributing main) to the point of supply at consumer’spremises, which also includes other accessories, i.e. any apparatus connectedto any such line for the purpose of carrying electricity & SCC covers costinvolved in providing service connection from distributing mains.

As regards collecting charges for the cost of works involved in releasing newconnection, Section 46 of EA, 2003 provides that the State Commission may byRegulation, authorise the Distribution Licensee to charge from a person requiringsupply of electricity, any expenses reasonably incurred in providing any electricityline or electricity plant used for the purpose of giving that supply.

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Thus as per the Act, powers are vested with the Commission to formulate Regulationsspecifying the principles for recovering the expenses involved in releasing theconnection which are set out in Regulation 3 of MERC (Supply Code and OtherConditions of Supply) Regulations, 2005.

Regulation 3.3.2. of Electricity Supply Code authorizes the Distribution licensee torecover all expenses reasonably incurred in laying down service line from thedistribution mains to applicant’s premises from the applicant.Thus the applicant is required to pay the entire cost of Service connection line fromthe distribution main to his premise.

MSEDCL has proposed to recover SCC at normative rates based on the sanctionedload/Contract Demand (kW/kVA). The rates are worked out on the basis of averagecost involved in releasing the connection to consumer in these load slabs. In theoriginal proposal the charges for 30 metres length were worked out on the basis ofcost for standard bill of materials involved for providing 30 metres of serviceconnection. However, in the light of objections received, MSEDCL has reworked thecharges based on 20 metres service connection length & latest rates of materials.

The proposal of MSEDCL to recover charges on normative basis is in line with theRegulation 3.3.1 of Supply Code Regulations. However, MSEDCL has proposed avariable component based on per metre cost of connection, for providing serviceconnection of length more than 30 meters. By measurement-linked charges, the verypurpose of providing normative charges would be defeated.

In order to simplify the procedure while releasing the connection and to avoiddiscretion and disputes at field level, the Commission has decided to dispense withthe measurement linked variable charges. Commission has further decided torationalize the normative charges by reducing the load slabs proposed by MSEDCL.The normative Service Connection Charges as approved by the Commission areindicated in Annexure – 1.

MSEDCL has proposed to recover 10% of the normative SCC towards overallsupervision and connection release charges, where consumer opts to procure therequired material.

MSEDCL has not furnished any worksheets/calculations for the proposed recovery of10% of normative SCC.

While Regulation 3.3.8 of Supply Code Regulations provides that DistributionLicensee may permit an applicant to carry out works through a Licensed ElectricalContractor, the Licensee in that case, is not entitled to recover expenses relating tosuch portion of works so carried out by the applicant. The Licensee shall be entitledto recover only the supervision charges not exceeding the 15% of the cost of labour.

MSEDCL in their calculation sheets has already worked out supervision charges,involved in releasing the service connection for different load slabs. From theworksheets it is seen that the average supervision charges are in the range of 1.30 to1.35% of the total estimated cost involved.

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In view of above, the Commission approves a rate of 1.30% of the normative chargesto be recovered towards supervision charges in case MSEDCL permits an applicant tocarry out the works through a Licensed Electrical Contractor.

In case a consumer applies for an additional load/contract demand i.e. extension ofload and if the release of additional load/contract demand entails any new works, theCommission allows MSEDCL to recover the normative charges for the totalload/contract demand (existing as well as additional load) as per the applicable loadslabs indicated in Annexure - 1 and 2.

2) Service Connection Charges for overhead HT Supply.The Commission has observed that the charges proposed under this item arenot supported with any details or any calculations, though several objectorshave raised this issue during public hearing. The reasoning given byMSEDCL for non-submission of working sheets is vague and evasive. In theabsence of any calculation, the Commission has verified the reasonability ofthe proposed charges based on market rates and work estimation.MSEDCL has proposed Rs. 30000/- for a single slab of 1000 kVA. This willcause a burden on the consumers like a Small Scale Industry or a small andmedium enterprise with a Contract Demand in the range of 200-500 kVA. Inview of above, the Commission decides to introduce two slabs andaccordingly directs MSEDCL to charge in two slabs i.e. namely upto 500kVA & above 500 kVA. The rates approved by the Commission are indicatedin Annexure – 1.

3) Service Connection Charges for underground LT Supply.As per Section 42 read with 43 of the Act, it is the duty of every DistributionLicensee to provide electric plant or electric line for giving supply to thepremises of an applicant. As such, MSEDCL’s proposal to ask consumer tobring material itself is irrational and contradictory to the provisions of the Act.The Commission, therefore directs MSEDCL to procure and use its ownmaterial for releasing the underground service connection particularly inurban and potentially urban areas to ensure safety, reliability and efficiency,unless an applicant opts and MSEDCL permits him to carry out the worksthrough a Licensed Electrical Contractor.

Further, MSEDCL has proposed some normative rates for underground LTconnections without furnishing any working sheets for the same, if applicantbrings all service connection materials. In absence of the working sheets, theCommission has worked out the rates for new underground LT supply basedon the market rates of the materials and work estimation. The normative ratesapproved by the Commission are indicated in Annexure-2. In case MSEDCLpermits an applicant to carry out the works, the MSEDCL may recoversupervision charges at the rate of 1.3% of the normative rates indicated inAnnexure-2.

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4) Service Connection Charges for underground HT Supply.In absence of any proposal for underground HT supply, the Commission hasworked out the rates based on the market rates of the materials and workestimation. The normative rates approved by the Commission are indicated inAnnexure-2.

5) Cost of meter & meter boxAs per Section 55 of the Act, it is the responsibility of licensee to supplyelectricity through installation of correct meter in accordance with theregulations made in this regard by the Authority i.e. CEA.

The Government of India has notified CEA (Installation & Operation ofMeters) Regulation, 2006 on 17th March 2006. As per Regulation 6(2)(a) ofCEA (Installation & Operation of Meters) Regulation, 2006, ‘consumermeters shall generally be owned by the licensee .

The above provision implies that meter for new connection should beprovided by the licensee and the cost of meter & meter box shall be borne bythe licensee, except where a consumer elects to purchase the meter fromlicensee. The Commission approves the rates proposed by MSEDCL asindicated in Annexure-3, which would be applicable only in case of a burnt ora lost meter or where a consumer opts to purchase the meter from MSEDCL.

6) Service Line Charges:A "service-line" is defined in Section 2(61) of the EA 2003 as under:

"service-line" means any electric supply line through which electricity is, or isintended to be, supplied -

(a) to a single consumer either from a distributing main or immediately from theDistribution Licensee's premises; or

(b) from a distributing main to a group of consumers on the same premises or oncontiguous premises supplied from the same point of the distributing main;

In the light of above definition, the terminology ‘Service Line Charges’ used byMSEDCL is totally misleading, as the charges proposed under the head ‘Service LineCharges’ basically covers the cost of infrastructure from transmission boundary uptodistributing mains and does not involve cost of ‘service line’.

MSEDCL has been collecting so called Service Line Charges from the consumerssince 1991 probably due to limited budget provision under State Plan for capitalworks and paucity of funds for developmental purpose.

MSEDCL has proposed to continue with Service Line Charges from all categories ofconsumers at normative rates. The normative rates are worked out based on theaverage cost involved in providing infrastructure and covers cost of electric plant andelectric line from delivery points on transmission lines upto distribution mains.

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Strong objections were raised during public hearing on MSEDCL’s proposal torecover SLC from prospective consumers for new connection or for releasingadditional load. The objectors quoted various sections of the Act namely Section 42and 43 wherein it has been clearly specified that it shall be the duty of the distributionlicensee to develop and maintain an efficient distribution system and to provide, ifrequired, electric plant or electric line for giving electric supply to the applicant’spremises. Responding to the objections, MSEDCL has admitted that distribution licensee hasto provide electric line or electric plant in case of necessity. However, they havemisinterpreted Section 45 of the Act. As per MSEDCL, Section 45 of the Actprovides that consumer has to pay the cost of electric plant provided by the licensee. Section 45 of the Act basically covers tariff related charges such as fixed chargesand rent or other charges in respect of meter or electric plant provided by thedistribution licensee.

As regards recovery of expenditure incurred for providing electric plant or electricline, separate provision is made under Section 46 which reads as under. “The State Commission may, by regulations, authorize a distribution licensee tocharge from a person requiring a supply of electricity in pursuance of section 43 anyexpenses reasonably incurred in providing any electric line or electrical plant usedfor the purpose of giving that supply.

As per this Section, powers are vested with the Commission to make Regulations todecide the principles and mechanism for charging consumer for expenses incurred inproviding infrastructure i.e. electric line or electric plant used for giving supply torespective consumer.

Expenses that are incurred by a licensee while providing supply and which are akin to"service-line", may be charged by licensees from consumers, as specifically approvedby the Commission while according its approval to the ‘schedule of charges’ in termsof Section 46 of the EA, 2003 read with the Electricity Supply Code. The expensesreasonably incurred by licensees in connecting a service line with the distributingmain (or portion of the main) are to form part of the ‘schedule of charges’ which arespecifically required to be approved by the Commission while according its approvalin terms of Section 46 of the EA, 2003 read with the Electricity Supply Code.

However, expenses that a licensee incurs for putting the necessary electric linesconnecting the transmission boundary to the distribution mains, should be included inthe cost of fixed assets for the purposes of arriving at the capital base during theprocess of determination of annual revenue requirement of the licensee under Section45 read with Section 62 of the EA, 2003 and cannot be charged by licensees undertheir ‘schedule of charges’. In other words, the licensee cannot be allowed to levyfixed charge in addition to the charge for the actual electricity supplied, without suchcharges being approved by the Commission under the provisions of Section 62 of theEA, 2003. Such expenses for putting the necessary electric lines connecting thetransmission boundary to the distribution mains, being a fixed charge cannot belevied under the ‘schedule of charges’ which follow a separate ARR and tariffdetermination process under Section 46 of the EA, 2003 read with Section 62 of EA,2003.

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While there is no denial that expenditure on infrastructure needs to be adequatelycompensated to the licensee, it is necessary to have a clear demarcation or limit topass on the burden to the individual consumer. The extent to which the cost is to berecovered has already been stipulated in the Regulation 3.3.2 of Supply CodeRegulations. As per the principles laid down in this Regulation, the licensee shall beauthorized to recover all expenses reasonably incurred on works for laying serviceline from the distribution mains to the applicant’s premises. MSEDCL has separatelyproposed to recover these charges under the head SCC and Commission has approvedthe same subject to certain validation/modifications and on rationalisation.

As regards expenditure incurred on 33kV & 11kV infrastructure beyond distributionmains, which forms a distinct part of wheeling business i.e. system of wires andassociated facilities, there is no provision in the Supply Code Regulations allowinglicensee to recover it from prospective consumers. The expenditure incurred onupstream of the distribution mains may be claimed through ARR. The Commission,therefore rejects the proposal, devoid of any legal authority, of MSEDCL to recoverSLC from the prospective consumers except in cases of consumers requiringdedicated distribution facility.

MSEDCL in their response has explained the differential service line charges forRural – Urban and Kuchha - Pukka structures stating that this is the concessionoffered by MSEDCL to a weaker section of the society so that they are able to haveaccess to the electricity as stipulated under the National Electricity Policy and Plan.This social aspect has already been taken care of by Ministry of Power, Governmentof India by introducing schemes like Rajiv Gandhi Gramin Vidyutikaran Yojana.However, Section 62(3) of the Act clearly stipulates that ‘The AppropriateCommission shall not, while determining the tariff under this Act, show unduepreference to any consumer of electricity but may differentiate according to theconsumers load factor, power factor, voltage, total consumption….’.

MSEDCL has proposed separate service line charges for MHADA, CIDCO coloniesetc. They have also proposed service line charges for supply to agricultural pumpsthrough conventional system and through HVDS. However since the levy of SLC toconsumer is totally disallowed, the Commission does not find it necessary to go intomerits and details of calculations /work sheet submitted by MSEDCL related toService Line Charges to different categories of consumers.

7) Miscellaneous & General Charges

i) Installation testing fee:

Regulation 9 of supply code provides that the wiring of consumer’s premises shallconform to the standards specified in the Indian Electricity Rules, 1956. As per Rule47, it is the duty of the supplier to inspect & test applicant’s installation beforeconnecting the supply. As per Rule 53(1), the cost of first inspection & testing of aconsumer’s installation carried out in pursuance of the provisions of Rule 47 shall beborne by the supplier & the cost of every subsequent inspection & test shall be borneby the consumer.

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In view of above, the Commission directs MSEDCL not to charge any amount forfirst inspection and testing of consumer’s installation at the time of giving newconnection. For all the subsequent tests & inspection of the consumer’s installation asper the provisions under rule 53 of I E Rules, 1956, the charges proposed byMSEDCL are approved. MSEDCL should provide copy of the report of Installationtesting to the concerned consumer.

ii) Reconnection Charges:Section 56 of Electricity Act, 2003 empowers the licensee to discontinue electricsupply to the consumer for non- payment of electricity bills after following the dueprocedure laid down under the Act. It further says that the supply can be discontinueduntil such charge or other sum, together with any expenses incurred by him in cuttingoff and reconnecting the supply, has been paid.

MSEDCL has not furnished any details about average cost incurred in disconnectionand reconnection of the supply. Instead MSEDCL in their response dated 10th April2006 has mentioned that higher reconnection charges have been proposed to motivatethe consumers to pay their energy bills on time. MSEDCL is of the opinion that suchcharges may up to certain extent, act as a deterrent factor and encourage theconsumers for prompt payment. However, the Commission is of the opinion thattimely disconnection of supply for default against valid dues itself would work asdeterrent to the consumer. Considering the provision in the Act, wherein it isexpressly mentioned that the licensee can recover the cost incurred for cutting of andreconnecting supply, the irrational high charges as proposed by MSEDCL are notjustified. MSEDCL has not furnished any calculations about the cost involved indisconnection and reconnection. The Commission views the existing charges to bereasonable and reflecting the cost involved. However, in order to further rationalizethe charges, Commission directs MSEDCL to recover reconnection charges asindicated in Annexure-4.

iii) Changing location of the meters within the same premise:Considering the average cost of material and labour involved in shifting of meter, thenormative charges of Rs. 100/- proposed by MSEDCL appears to be reasonable andthe Commission approves the proposed charges with the condition that this shouldcover the total cost including the cost of material, labour, all other costs etc. requiredfor changing the location of the meter.

The charges for changing the location of meter within the premise will be applicableonly in cases where the shifting is to be done at the request of the consumer.However, when MSEDCL desires to have the location changed, then the cost of suchshifting shall be entirely borne by MSEDCL.

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iv) Testing of meters:Supply Code Regulation 14.4 covers testing & maintenance of meters. As perregulation 14.4.1, the distribution licensee shall be responsible for periodic testing &maintenance of all consumers’ meters. As per regulation 14.4.2, the consumer may, upon payment of such testing charges asmay be approved by the Commission under regulation 18, request the distributionlicensee to test accuracy of the meter.As per regulation 14.4.3, the distribution licensee shall provide a copy of meter testreport within a period of two months from the date of request for the testing of themeter by the consumer.

As per regulation 14.4.4, in the event of the meter being tested & found beyond thelimits of accuracy as prescribed under Regulation 8 of CEA (Installation & Operationof Meters) Regulation, 2006 under section 55 of the Act, the distribution licenseeshall refund the testing charges paid by the consumer & adjust the amount of bill inaccordance with the results of the test. Subject to the above provisions in the SupplyCode Regulations, the Commission approves the charges for testing of meters asproposed by MSEDCL.The testing charges approved shall be applicable only in case the consumer requeststhe Licensee to test the meter as mentioned above, and the expenditure towards firsttesting prior to release of new connection (even if the meter is purchased by theconsumer) and all routine testing as per Regulation 14.4.1 shall be borne byMSEDCL.

v) Replacement of meter cards for HT consumers:MSEDCL has reportedly installed TOD meters to all HT consumers. The meters havedata storage with downloading features and data can be collected as and whenrequired. In view of above separate meter card may not be necessary. However, if theMSEDCL intends to continue this practice of maintaining the cards for HT consumer,they may do so in their own commercial interest at their own cost since such HTconsumers are of higher revenue potential for MSEDCL. In view of above, theCommission rejects the proposed charges for replacement of meter card for HTconsumer.

vi) Penalty for cheque bouncing:When a cheque is dishonoured, it is considered to be a serious offence as per Section138 of the Negotiable Instruments Act. The issuer of such cheque can also face legalaction. As MSEDCL is not an authority to impose any punishment for such offenceunder the law, they are not authorized to levy any Penal charges. However, they mayrecover charges towards bank charges and administration expenses towards bouncingof cheque. The cheque bouncing charges varies from bank to bank and are in therange of Rs. 25/- (Rupees twenty five) to Rs. 250/- (Rupees two hundred and fifty).The Commission, therefore approves the charges towards compensation of bankcharges and MSEDCL’s administrative charges as indicated in Annexure-4.

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vii) Temporary meters /hiring of meters charges:Regulation 3.3.6 empowers the licensee to recover all expenses reasonably incurredfor the purpose of giving temporary supply & for the purpose of discontinuance ofsuch temporary supply. Since the entire cost for temporary connection is to be borneby consumer, the Commission rejects the proposed charges for hiring of meter in caseof Temporary connection.

viii) Penalty for Harmonics variation above normal limits:As the Penalty for Harmonics is a tariff related issue like that of power factor, theCommission in absence of any substantiated proposal, does not accept proposed penalcharges at this stage.

ix) Hiring charges for CT/PT unit, CT metering cabinet & HT metering cabinet,Transformers & capacitors; Testing of LT CT’s, CTPT unit, relays, 11/22kVswitchgears, transformers, transformer oil and LT & HT capacitors; Chargesfor standby transformer:

Hiring charges are optional charges and will be presumably applicable only when anyof the equipment owned by the consumer fails and he opts under exigent condition tohire the equipment from MSEDCL. MSEDCL has not included these items in theirTerms & Conditions Of Supply. Though leasing of equipments on hire basis inexigencies would be beneficial to both i.e. consumer and the licensee, these items arematters of mutual consent of MSEDCL and consumer. The Commission, thereforedoes not consider these items as a part of Schedule of Charges as these items fallunder non-regulatory services resulting in ‘other income’ for the Licensee.

8) Application registration and processing charges:As per Supply code regulation 4, in respect of Application for supply, the applicant isrequired to submit various documents and details. Besides, as per regulation no.4.1(ix), consumer is required to pay fee for processing the application or receiptthereof, based on schedule of charges approved by the Commission under regulation18.

Following activities are involved in processing the application as mentioned inRegulation 5 of Supply Code:i) study of technical requirements of giving supply,ii) inspect the premises,iii) joint inspection along with an applicant to fix the position of service, mains,

meters, sanction of load, etc.

However, all the above activities fall under normal activities of the Licensee’s staff.As the expenditure on the staff is covered under ARR, the Processing fee should notinclude the expenditure towards the staff employed for processing the application toavoid double accounting. At the same time the Commission feels that there should bea minimum barrier to discourage frivolous or non-serious consumers.

In view of above, the Commission allows MSEDCL to collect a token amounttowards the application processing or receipt thereof as indicated in Annexure-5.

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Applicability & Validity:The entire Schedule of Charges as approved by the Commission shall be applicablewith effect from September 8, 2006 and will continue to remain in force till furtherorders.

MSEDCL is directed to promptly disseminate instructions upto sub-division level tostop recovering charges at existing rates & issue necessary commercial circular(vetted by the Commission) within 7 days from the date of this order. This circular sodispatched should also be made available on MSEDCL’s website.

Sd/- Sd/- Sd/-(S. B. Kulkarni) (A. Velayutham) (Dr. Pramod Deo)Member Member Chairman, MERC

(Malini Shankar) Secretary, MERC

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APPENDIX -I

List of Objectors to the MSEDCL’s Schedule of Charges

Sr. No. Name & address of the objector1 Dr. Ashok Pendse, Mumbai Grahak Panchayat, Mumbai2 Shri R. B. Goenka, Vidarbha Industries Association, Nagpur3 Shri S.D Damle, Pune4 Secretary, Lok Sanskriti, Kalyan5 Shri Vinayak Shrikrishna Mahajan, Ratnagiri.6 Bapuji B. Ghorpade, Social Activist, Dist. Kolhapur7 Shri Chandulal J. Sumaria, Shri Halari Powerloom Owners &

Weavers Association, Thane.8 Shri Damodar Nalla, Solapur Zilla Yantramag Dharak Sangh9 Shri Pratap Hogade, Maharashtra Rajya Veej Grahak

Sanghatana, Ichhalkaranji, Kolhapur10 Shri Ravikant Madan Raut, Chaul Raut Ali, Taluka Alibag.11 Shri Anil Gachke, Electrical Contractors’ Association of

Maharashtra, Mumbai.12 Shri Sanjeev Potdar, Kolhapur Engineering Association,

Kolhapur13 Shri Sunil Bhattase, President, Laxmi Industrial

Manufacturers Association, Kolhapur14 Shri V. B. Jain, Co-Operative Industrial Estate Ltd., Pachora,

Dist. Jalgaon.15 Shri Shaikeel Ansari, Maharashtra Electricity Consumers

Association, Bhivandi16 Shri Pradeep Bhide, Vice President, Ispat Industries Limited17 Shri Satish Khare, Nagpur18 Shri Ashok Dhivre, The Consumers Right Protection,

Education and Research Council, Sakri Road, Dhule.19 Shri Maulana Shakeel Ahmed Vazir Jawahar, The Malegaon

Powerloom & Sarvajanik Veej Grahak Sangh, Malegaon,Nashik.

20 Shri Er. Shahid Ansari, President, The Malegaon Industries &Powerloom Manufacturers Association, Malegaon, Nashik

21 Shri Sajid Ansari, President, Malegaon Powerloom UdyogViks Samitee, Malegaon, Nashik.

22 Shri Nimba Kadam, President, Malegaon PowerloomFederation Committee, Malegaon.

23 Shri Ansari Neerul Amin Mohamed Sabir, The Industrial Co-operative Association Ltd., Malegaon

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Sr. No. Name & address of the objector24 Shri Madhukar Brahmankar, Nashik Industries &

Manufacturers Association, Nashik.25 Shri Shaikh Yusuf Mohammad, Nashik Road, Nashik26 Shri Rajaram Bapusaheb Patil, Chairman, Kolhapur Zilla

Dalap-Kandap Girni MalakSangh, Kolhapur.27 Shri Tukaram Govind Jadhav, Khanapur, Sangli28 Shri More Sachin Eknath, Pune29 Shri M.B. Kulkarni, Asst G..M., Tata Motors Ltd., Pune.30 Shri B.R. Khedkar, Akhil Bharatiya Grahak Panchayat, Pune31 Shri Ujwalraj Joshi, Mumbai Grahak Panchayat, Thane

Division, Thane.32 Shri Faizan Ahmed Azami, Chairman, Maharashtra State

Powerloom Federation, Bhiwandi.33 Shri Pankaj D. Muni / Sri Kamlesh Shah / Sunil J. Saraf, Vile

Parle, Mumbai34 The Secretary, Hamdard Grahak Panchayat, Malegaon

Branch, Nashik.35 Secretary, The Malegaon Consumers Complaints Satisfaction

Society, Malegaon36 Shri Shaikh Asif Shaikh Rasheed, Mayor, Malegaon

Municipal Corporation, Malegaon.37 Shri Shrikant Khadilkar, Veej Grahak Samitee, Nashik38 Shri Ravi Anand, Electricity Consumers Association39 Shri Lalji K. Dwivedi, Pudumjee Pulp & Paper Mills Ltd.,

Chinchwad, Pune.40 Shri Laxman Ganpat Gunavare, Shetkari Parishad, Pune.41 Shri Sudhir T. Badgujar, Mahatma Phule Multipurpose

Krishak Mandal, Dhule.42 R.R. Atkale, Pune43 Shri Ashwin Treasurer, Thane Small Scale Industries

Association44 Shri Hemant J. Ganpat