case no.2 of 2003 - infraline

MERC Tariff Order for MSEB – FY 2003-04

Introduction & Salient Features

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Bef ore the MAHARASHTRA ELECTRICITY REGULATORY COMMISSION

World Trade Centre, Centre No.1, 13th Floor, Cuffe Parade, Mumbai – 400 005 Email: [email protected]

Website: www.mercindia.com

Case No.2 of 2003

IN THE MATTER OF Determination of Tariff [2003-04] applicable to various categories of consumers of the

Maharashtra State Electricity Board

Shri P.Subrahmanyam, Chairman Shri Jayant Deo, Member. Dr. Pramod Deo, Member

Date of Order: March 10, 2004

O R D E R

The Maharashtra Electricity Regulatory Commission, in exercise of the powers vested in it under Section 29 of the Electricity Regulatory Commissions Act, 1998 and all other powers enabling it in this behalf, and after taking into consideration all the objections, responses of the MSEB, issues raised during the Public Hearings, and all other relevant material, determines the tariff for supply of electricity by the Maharashtra State Electricity Board for retail distribution as under.

BRIEF HISTORY:

The Maharashtra State Electricity Board (MSEB) submitted a Petition for approval of the Annual Revenue Requirement for FY 2003-04 (ARR Petition)on April 7, 2003 under affidavit dated April 3, 2003 to the Maharashtra Electricity Regulatory Commission (Commission) for the revision of its Retail Distribution Tariff with effect from April 1, 2003, keeping in view the requirements of Section 59 of the Electricity (Supply) Act, 1948. The MSEB filed only the ARR Petition in April 2003 as against the Commission's directive to file the ARR and Tariff Petition for FY 2003-04 by December 2002. On receipt of the ARR Petition, the Commission held an admissibility hearing in the presence of S.26 Consumer Representatives on April 24, 2003. Although a specific Tariff Proposal was not submitted by the MSEB, the Commission admitted the Petition to avoid delay in processing of the Petition, with the following conditions:



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(a) The Petition would be taken up for Technical Validation on May 13, 2003, subject to MSEB fulfilling data requirements; Consumer Representatives should submit their requirement of data by May 2, 2003 to MSEB through the Commission, for inclusion and submission by MSEB before May 9, 2003;

(b) MSEB should also prepare and submit a detailed Tariff Proposal taking into account, inter alia, the various directives and guidelines given by the Commission in earlier Orders, including the alternatives regarding T&D loss charges (Circle-wise and State-wide) as minuted in the Record of Proceedings held on October 7, 2002.

On receipt of the additional data and information and Tariff Petition from MSEB on June 30, 2003, the Commission held a Technical Validation Session in the presence of S.26 Consumer Representatives on July 1, 2003. During the Technical Validation Session held on July 1, 2003 at Mumbai, the following persons / officials were present: Sr. No. Name of person/ official

DESIGNATION AND INSTITUTION

MSEB Officials: - 1 Shri Asoke Basak Chairman, MSEB 2 Shri A.B. Shethji Technical Member (T&D), MSEB 3 Shri M.N. Bapat Technical Director (Distribution), MSEB 4 Shri G.P. Gunnapar Chief Engineer (Tariff Regulatory Cell),

MSEB 5 Shri V.L. Sonawane Superintending Engineer (Tariff Regulatory

Cell), MSEB 6 Shri M.R. Ambhore Technical Member (Generation), MSEB 7 Shri C.N. Gudap Chief Engineer (Distribution), MSEB 8 Shri Anil Deshkar Jt. Secretary, MSEB 9 Shri J.K. Shrinivasan Jt. Chief Accounts Officer, MSEB 10 Shri A.V. Deshpande Chief Accounts Officer, MSEB 11 Shri S.P. Vahalkar Dy Chief Accounts Officer, MSEB 12 Shri H.A. Patil Chief Engineer (Commercial), MSEB 13 Shri V.V. Kulkarni Accounts Officer, MSEB 14 Shri B.N. Farkade Chief Engineer (SLDC), Kalwa, MSEB 15 Shri S.S. Kulkarni Executive Engineer (SLDC), Kalwa, MSEB 16 Shri A. Krishna Rao Member (Accounts), MSEB 17 Shri P.V. Kulkarni Technical Director (EHVP), MSEB 18 Shri A.G. Khonde Executive Engineer, MSEB 19 Shri A.B. Chapalge Dy. Chief Engineer, (Generation

Works)MSEB



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Sr. No. Name of person/ official

DESIGNATION AND INSTITUTION

20 Shri S.V. Ramakrishna Director (IT), MSEB 21 Shri B.M. Kumbhar Dy. Director, MSEB 22 Shri V.M. Baswante Executive Engineer, MSEB 23 Shri C.P. Katkuri Director of Accounts, MSEB 24 Shri R.N. Sonar Chief Accounts Officer (BA), MSEB 25 Shri S.J. Ambekar Dy Chief Accounts Officer (BA), MSEB 26 Shri U.S. Mane Addl. Director (IT) , MSEB 27 Shri V.W. Deshpande Jt. Director (IT) , MSEB 28 R.B. Kshirsagar Executive Engineer, MSEB 29 Shri P.H. Aher Executive Engineer, MSEB 30 Shri K.A. Sukumaran Steno, MSEB CONSUMER

REPRESENTATIVES: -

31 Shri R.B. Goenka President, Vidarbha Industries Association 32 Dr. Ashok Pendse Mumbai Grahak Panchayat 33 Dr. S.L. Patil Secretary General, Thane Belapur Industries

Association 34 Shri Shantanu Dixit Member, Energy Group, Prayas CONSULTANTS: -

35 Shri Sameer S. CRISIL 36 Shri B. Shesan CRISIL 37 Shri Palaniappan M. Manager, ICRA 38 Shri Suresh Gehani Manager, ICRA 39 Shri Ajit Pandit Manager, ICRA 40 Shri Anand Desai Manager, ICRA 41 Shri Jain Chirag A.F. Ferguson & Co. OTHER OFFICIALS: -

42 Shri M.S. Dave Assistant General Manager, Tata Power Company Ltd.

43 Shri T.P. Mohan Senior Manager, Tata Power Company Ltd. 44 Shri C.A. Colaco Tata Power Company Ltd. 45 Shri Vivek Kejriwal Manager, Tata Power Company Ltd.

During the Technical Validation session, the Commission and the Consumer Representatives identified several discrepancies and data gaps and directed MSEB to submit a consolidated ARR and Tariff Petition alongwith additional data and clarification. Subsequently, the MSEB, vide letter ref. TRC/TRP 03-04/24623, submitted the Revised ARR and Tariff Revision Petition (Petition) for FY 2003-04 on July 23, 2003 under affidavit dated July 21, 2003 in three volumes.



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In line with the Regulations and practice established by the Commission in previous tariff determination exercises, the Public Notice was issued in newspapers for inviting suggestions and objections from interested parties. The Public Notice was published in Asian Age, Economic Times, Financial Express, Maharashtra Times and Times of India in Mumbai; Indian Express, Dainik Samna, Gavkari, Kesari, Lok Mat, Lok Satta, Sakal, Tarun Bharat and Tudhari in all editions of Maharashtra and in leading local newspapers in each of the six Revenue Divisions of the State. The Public Notice appeared in most of the newspapers on August 4, 2003. Copies of the MSEB’s Petition and its summary were made available for inspection/purchase to members of the public throughout the State of Maharashtra in the MSEB's Executive Engineers' offices and on the MSEB’s website (www.msebindia.com). The last date for filing the written objections was fixed as September 3, 2003, which allowed a period of one month to the public to enable them to file their objections. The Public Notice specified that the suggestions/objections, either in English or Marathi, may be filed in the form of affidavits to the Commission along with proof of service on MSEB. It was specifically stated in the Public Notice that if any objector wanted to be heard in person, he would be invited to the Public Hearings. MSEB was given an opportunity to reply to the party's suggestion/objection by September 18, 2003. The concerned party was also allowed to submit a rejoinder to MSEB by October 3, 2003. By the above Public Notice, the Commission also admitted objections filed during the Public Hearing. To facilitate the interested objectors who find it difficult to submit their objections within the above stipulated time, it was also clarified that they were permitted to file their objections upto October 21, 2003 and could also participate in the Public Hearing at Mumbai. This was also announced during the Public Hearings held at various Divisional Headquarters. The Commission also made necessary arrangements to receive the affidavits and objections and to record all the oral submissions on audiotapes and videotapes at the Public Hearings.

The consumers, by a Public Notice, were also informed of the dates of the Public Hearings as follows:

Sl. Revenue Divisions Date of Public Hearing. 1 Amravati October 9, 2003 at 11.00 hrs 2 Nagpur October 10, 2003 at 10.00 hrs 3 Aurangabad October 13, 2003 at 10.00 hrs 4 Nashik October 15, 2003 at 10.00 hrs 5 Pune October 17, 2003 at 10.00 hrs 6 Mumbai October 20 and 21, 2003 at 11.30 hrs



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The Commission received a large number of written objections expressing concern about the proposed upward revision in the Tariff charges, the working of the MSEB and a host of other issues. The Commission received a total of 792 objections, 628 on affidavit and 64 without affidavits. Those objectors who filed their affidavits and also indicated that they would like to be heard in person, were called for the Public Hearing at the respective headquarters of Revenue Divisions in which they were located.

The category-wise and revenue division-wise number of consumers/institutions who submitted their objections to the MSEB’s Tariff Revision for 2003-04 is detailed in the Table below:

Interest Groups Amra-vati

Aurang-abad

Konkan Nagpur Nashik Pune Total

Consumer

1 3 8 3 10 14 39

Consumer Association 1 2 8 1 8 7 27

Consumer Representative

3 1 1 5

Industry

2 3 10 2 7 11 35

Industry Association 3 2 14 2 4 8 33 Railway

2 2

Lift Irrigation Society 1 602 16 19

Political Party

2 3 4 2 11

Trade Union

1 1 2 1 1 6

Panchayat, Nagar Palika, Nagar Parishad, Municipality

1 1 5 7

Others

5 2 1 8

Total

8 13 56 11 643 61 792

The Commission, vide letter dated September 29, 2003, separately requested the Government of Maharashtra to indicate its commitment regarding subsidy with respect to Maharashtra



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State Electricity Board's tariff. The GoM’s response, through its Industries, Energy & Labour Department, vide letter No. RCA, 2003/CR 174/NRG-3, is quoted below:

“Under Section 65 of the Electricity Act, 2003, it is stated that, "If the State Government requires the grant of any subsidy to any consumer or class of consumers in the tariff determined by the State Commission under section 62, the State Government shall notwithstanding any direction which may be given under section 108, pay, in advance and in such manner as may be specified, the amount to compensate the person affected by the grant of subsidy in the manner the State Commission may direct, as a condition for the licence or any other person concerned to implement the subsidy provided for by the State Government."

It is clear from the above that the sequence as intended by the Act is that the Commission first determines the tariff under section 62 after which the State Government would decide about the grant of subsidy.

At the moment, the issue of granting subsidy for the year 2003-04 based on the existing rates is under consideration of Government. Before the issue is decided, it is very difficult for Government to take a view as to the subsidy it would like to give after revision of rates by the Commission. Usually Government would be anxious to know the net tariff payable by the subsidized consumers after accounting for the subsidy and hence would find it difficult to commit subsidy amount without knowing the tariff fixed by the Commission”.

The Commission has ensured that the due process contemplated under the law has been followed at every stage meticulously and an adequate opportunity was given to all the persons concerned to file their say in the matter. The Commission, after taking into consideration all the objections, including the submission of the Government of Maharashtra, responses of the MSEB, issues raised during the public hearings, and all other relevant material, has issued the Operative part of the Order on December 1, 2003. The Commission hereby makes the following Tariff Order. 1. The revised tariffs will be applicable from December 1, 2003, and will continue to be in

force till further revision in tariffs. The net increase in revenue to the MSEB from the revised tariffs is Rs. 186 crore, if the revised tariffs had been made applicable from April 1, 2003, which amounts to an average tariff increase of around 1.5%.



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2. The matter of specifying the ‘Terms and Conditions of Supply’ for the MSEB is before the Commission, which is being taken up separately.

3. The Commission had directed the MSEB to comply with its directives given in the earlier Tariff Orders and issued separately from time to time. However, the Commission is very unhappy with the performance of the MSEB in this regard. Despite the Commission’s strong warning that it would be constrained to take serious action if there was slippage in compliance with the directives, the MSEB has not shown its willingness to comply with these directives in the true spirit. The Commission expresses extreme displeasure with the MSEB’s non-compliance of its directives, despite several reminders in this regard. The top management of the MSEB is urged to take urgent steps to comply with these directives expeditiously.

4. The Commission also directs that henceforth, the Commission will conduct quarterly reviews of the MSEB’s compliance with the directives. The MSEB’s senior officers would be expected to attend these compliance review meetings. Further, in case the MSEB desires any clarification on any directive issued by the Commission, the MSEB should request such clarification within a month of the directive being issued, failing which it will be assumed that the MSEB does not require any clarifications, and the MSEB will be required to comply with the directives expeditiously, both in letter and in spirit.

5. Energy accounting by itself has no meaning, unless the MSEB analyses the energy accounting data and holds the concerned officers responsible for the excess losses in that zone/circle. The Commission has noted that there are several instances where the meters installed are not being read on a monthly basis. The Commission reiterates that the MSEB should hold the concerned employees responsible for the T&D losses in the respective circles/zones, and consider departmental proceedings against these employees after following due disciplinary procedure. The monitoring of the circle-level losses should continue and the MSEB should continue to submit the circle-level energy accounting data on a monthly basis, and circles should operate on ‘profit centre’ basis.

6. For projecting the energy requirement, the Commission has considered the T&D loss level of 36.62%, which is the T&D loss level proposed by the MSEB despite the uncertain quality of data in this regard, for want of a better alternative. With the sales during FY 2003-04 projected by the Commission at 39710 MU, the total energy requirement to be met through generation and power purchase is expected to be about 62652 MU. This is in line with the energy handled by the MSEB’s system in the recent past.

7. The net generation from MSEB’s own stations as projected by the Commission is 46470 MU as compared to 45983 MU projected by the MSEB. The Commission has considered



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the generation from Hydel Stations at the same level achieved during FY 2002-03, and the generation from the thermal stations based on the ‘ability to generate’ factor.

8. Considering the actual power purchase from April to July 2003 and the month-wise purchase based on merit order scheduling, the total power purchase approved by the Commission for FY 2003-04 is 16182 MU.

9. Though the MSEB has projected load shedding of 1079 MU in FY 2003-04, the Commission is of the opinion that there is no need to resort to load shedding in FY 2003-04, as there is sufficient energy available through own generation and power purchase to meet the projected sales at the T&D loss levels considered by the MSEB.

10. The MSEB had considered a 5% increase in the fuel costs and power purchase costs over the actual costs incurred in FY 2002-03, while projecting the expenditure for FY 2003-04. The Commission has approved the total generation and power purchase costs for FY 2003-04 considering the quantum of actual generation and power purchase for the period of April to July 2003 and estimating the generation and power purchase costs from August 2003 to March 2004 based on a simulation of merit order dispatch and actual average generation and power purchase costs for the period of April to July 2003, subject to heat rate norms and transit loss component. As the actual costs have been considered, the Commission has not considered any escalation in the fuel prices and power purchase costs for the balance period. Further, if there is any change in the fuel prices and power purchase costs vis-à-vis the costs considered by the Commission, the MSEB will recover/refund the same through the FOCA mechanism.

11. The Commission has considered a reduction of 1% in the station heat rate over the levels considered in the Tariff Order for FY 2001-02, as it still continues to be above the norm.

12. In previous Tariff Orders, the Commission had disallowed the transit loss component as a legitimate expense while computing the generation cost. However, the Hon’ble High Court of Mumbai has held that transit losses are a legitimate expense, and the permissible level of transit losses should be determined by the Commission. The Commission has considered transit losses based on the actual level of station-wise transit losses and has assumed a trajectory for reduction in transit losses.

13. The Commission has considered drawal of additional long-term loans to the extent required for capital expenditure and to fund the shortfall in repayment obligations vis-à-vis the provision for depreciation, if any. The opening balance of long-term loans for FY 2003-04 has been computed accordingly, leading to a reduction in the interest costs. Further, the Commission has also disallowed the interest on bonds raised for investment in Dabhol Power Company (DPC), on principles consistent with those considered in the earlier Tariff Orders.



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14. The net working capital requirement has been estimated as Rs. 546 crore, by applying the

same principles as in the previous Tariff Order. Considering an average interest rate of 10% for working capital loan, which is the interest rate considered by the MSEB for such loans, the working capital interest allowable has been projected as Rs. 54.6 crore.

15. The Commission has considered provisioning for bad debts at the rate of 1.5% of the sales billed during FY 2003-04, in line with the principles considered in the past Tariff Orders.

16. The Commission has projected lower level of ‘Other expenses’ as compared to the MSEB’s projections, as it has considered interest on security deposit at the average of the past three years’ and lower level of miscellaneous expenses.

17. The Commission has considered the mandatory surplus at the rate of 4.5% of the Net Fixed Assets, at Rs. 433 crore.

18. The net revenue to be recovered through tariffs on sale of electricity have been projected after reducing the Annual Revenue Requirement, due to the following reasons: Revenue earned through FOCA for additional expenses in FY 2003-04 Other Income

19. The Commission has deducted the amount recovered through FOCA for additional expenses incurred in the months of April, May and June 2003 amounting to Rs. 135 crore, from the revenue requirement of FY 2003-04, as the actual generation and power purchase costs incurred during this period have been considered for projecting the total costs in FY 2003-04. Any additional amount recovered by the MSEB through the FOCA formula for increase in costs in FY 2003-04 after June 2003, if any, will be adjusted against the FOCA recoverable henceforth.

20. The Commission has considered a higher Other Income of Rs. 1067 crore as compared to the MSEB’s projection of Rs. 1022 crore, mainly on account of higher projection of interest on delayed payment and recovery from theft of power and wheeling charges.

21. All the directives issued by the Commission in the previous Tariff Orders issued in May 2000 and January 2002 are still applicable, and the MSEB is directed to comply with the same in letter and in spirit.

22. The net revenue requirement allowed by the Commission for FY 2003-04 to be recovered through tariffs is Rs. 12174 crore. The revenue from existing tariff works out to Rs. 12030 crore, leaving an uncovered gap of Rs. 144 crore, with the existing tariff. If the revised tariffs were to be charged for the entire year, then the additional revenue recovered through revised tariffs would be Rs. 144 crore. However, in the current year, the revised tariffs will be in force for only four months of FY 2003-04.

23. The Commission has introduced high load factor incentive and reclassified certain consumer categories, the impact of which cannot be assessed accurately at this point in



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time with the available data. The Commission has hence determined the category-wise tariffs such that the additional revenue recoverable in the remaining four months of FY 2003-04 with revised tariffs is around 62 crore, as compared to the requirement of Rs. 48 crore. However, in case there is any revenue shortfall compared to the Commission’s projections due to the tariff classification changes and other rebates given in this Order, the Commission will consider it in the future.

24. The Commission has adopted certain principles, which are in continuation of the process of tariff rationalisation initiated in the previous Tariff Orders. In general, the movement of tariffs towards the average cost of supply has been maintained, such that inter-class cross-subsidy is reduced gradually, while at the same time ensuring that no consumer category is subject to a tariff shock. The Commission has also further reduced the intra-class cross-subsidy, by reducing the difference between the highest and lowest slab rates.

25. As all the hitherto un-metered consumer categories have been metered, except LT agriculture, the Commission has specified flat rate tariffs only for the un-metered LT agriculture category. The difference in metered tariff and the flat rate tariffs has been increased to incentivize un-metered consumers to opt for metering.

26. The Commission has considered an average consumption norm of 1300 hours/HP/year in case of flat rate LT agricultural consumers, based on the available sample energy audit data submitted by the MSEB. The Commission has attempted to determine the flat rate tariffs for agriculture category such that the tariffs reflect the actual consumption pattern. This has been done by specifying circle-wise differential flat rate tariffs linked to the agriculture consumption norm as established by the energy audit data for that circle. To start with, the Commission has specified two tariff levels, viz. lower tariff for circles with consumption norm lower than the average consumption norm of 1300 hours/HP/year, and higher tariffs for circles with consumption norm higher than the average consumption norm of 1300 hours/HP/year. The Commission hopes that this will incentivize the shift to metered consumption at a faster rate.

27. In the Tariff Order issued in January 2002, the Commission had initiated the process of levying the ‘T & D loss Charge’ for all consumers, in proportion to the average realisation from that category. By introducing this charge, the Commission intended to create awareness among the consumers regarding the additional cost of the excess T&D losses by levying this charge in an explicit manner. Hence, a more or less uniform T & D loss charge had been levied to start with. Moreover, the Commission had declared its intent to differentiate between the various circles/zones for the levy of the T & D loss charge, based on the T & D losses exhibited by the circle/zone in question. As an interim measure, in January 2003, the Commission had declared that 11 circles with T&D loss levels lower than the target loss level of 26.87% would be exempted from payment of



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T&D loss charges. It should be noted that T&D loss charge was not an additional charge and was a part of the regular tariff, which the consumers were always paying though the separation of tariff due to excess T&D losses was not indicated explicitly earlier.

28. The Commission is of the view that the T&D loss charge concept has achieved a certain level of success in that the stakeholders are certainly much more aware of the extent of the problem, and atleast some circles have shown some improvement in the T&D loss levels. However, the Commission is of the view that the T&D loss charge concept cannot be a long-term solution and the problem has to be addressed in some other manner, and hence the T&D loss charge has been withdrawn for all consumer categories in all circles, with effect from December 1, 2003.

29. The problem arises in the assessment of the losses itself. Even if the Commission were to take a strict view that only the technical losses should be allowed and all the commercial losses should be to the MSEB’s account, the problem remains with the assessment of the technical losses. Though the MSEB has submitted in the past that the technical losses could be in the range of around 21%, this number has to be verified through load flow studies. In the absence of any certainty on this issue, the Commission is constrained to accept the target loss level at 26.87% for the purposes of this Order.

30. If the cost of all the excess losses were disallowed, then it is most likely that the MSEB will be unable to meet its daily requirements and will be unable to supply power to its consumers. This is not in the consumers’ interest, and till a viable alternative emerges, the MSEB has to continue to supply electricity to the consumers in the State. The Commission is of the opinion that a pragmatic decision has to be taken in the best long-term interest of the electricity consumers in the State as well as the MSEB. Moreover, this is a transition period and the MSEB is likely to be restructured in line with the principles enunciated in the EA 2003.

31. In this context, the Mumbai Grahak Panchayat (MGP), a S.26 consumer representative has suggested that if the MSEB needed ‘Oxygen’ in the form of tariffs to recover the cost of the excess losses, the consumers would be willing to contribute the same, provided the Commission treated this contribution as a Regulatory Liability owed by the MSEB to the consumers, as this was not part of the MSEB’s rightful revenue requirement. The Commission has given serious thought to this suggestion, and is of the opinion that this may solve the current predicament.

32. The Commission is of the opinion that only subsidizing consumers should contribute to the Regulatory Liability, which would have to be returned by the MSEB in future. Hence, the Regulatory Liability Charge (RLC) has been designed such that all the subsidizing categories contribute the same amount of RLC to keep the MSEB afloat. Subsidized categories cannot be expected to contribute to the Regulatory Liability as they have yet to



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move towards the average cost of supply. Thus, for subsidizing categories, a separate component of tariff has been shown as ‘Regulatory Liability Charge’ which will be used by the MSEB for funding the cost of the excess T&D losses, which will be returned to these consumer categories in future through tariffs.

33. The Regulatory Liability requirement is equal to the cost of the excess losses, i.e. the cost of additional power purchase required on account of the higher energy input requirement. The T & D loss level proposed by the MSEB for FY 2003-04 is 36.62%, as compared to the target of 26.87% set by the Commission. The balance losses of 9.75% equivalent to 6107 MU are thus excess losses vis-à-vis the targets.

34. The net cost of the excess energy input requirement is Rs.947 crore (6107 MU at an average rate of Rs. 1.55 per unit). Thus, there is a need to contribute Rs. 947 crore towards the Regulatory Liability over a period of one year. The average rate of contribution works out to 50 paise per unit for the subsidizing categories, viz. LT commercial, LTPG, HTP I, HTP II and Railways.

35. In future, when the T&D losses are reduced, then the RLC will be returned to these consumer categories through reduction in tariffs. The Commission clarifies that the contribution through RLC will not be recorded and maintained separately for each individual consumer and the category as a whole is expected to get the contribution back.

36. The average cost of supply for FY 2003-04 works out to Rs. 2.83 per unit, which is lower than the average cost of supply considered in FY 2001-02, on account of the lower level of T&D losses considered for tariff determination, as well as the removal of the cost of excess losses while computing the average cost of supply.

37. The Commission has reduced the cross-subsidy between different consumer categories and tariff for all subsidised categories has been specified at least equal to 50% of the average cost of supply.

38. The Commission has attempted to increase the recovery from fixed charges, which ranged around 35% of the fixed costs in the existing tariffs, to around 40% in the revised tariffs. The energy charges have been adjusted in such a way that the average realisation from each consumer category approaches the average cost of supply, while at the same time ensuring that no consumer category faces a tariff shock.

39. The energy charge to be levied for net sale to the TPC has been increased to match the highest cost of power purchase, i.e. 299 p/u.

40. The tariff applicable for sale to Mula Pravara Electric Co-operative Society (MPECS) has been retained at the existing levels. The Commission is separately forwarding a Report on the viability of the MPECS to the Government of Maharashtra (GoM).

41. The rebates/incentives such as power factor incentive, bulk discount and prompt payment incentive have been retained at the existing levels. The power factor penalty has been



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modified such that the penalty is levied in a graded manner similar to the power factor incentive.

42. The Commission is of the opinion that the MSEB faces a threat from movement of consumers having very high consumption to captive generation, under the provisions of the Electricity Act, 2003 (EA 2003). In order to incentivize such high consumption consumers who also contribute a steady load to the MSEB system, the Commission has introduced a Load factor incentive for consumers having Load Factor above 75% based on contract demand. Consumers having load factor over 75% upto 85% will be entitled to a rebate of 0.75% on the energy charges for every percentage point increase in load factor from 75% to 85%. Consumers having a load factor over 85 % will be entitled to rebate of 1% on the energy charges for every percentage point increase in load factor from 85%. The total rebate under this head will be subject to a ceiling of 15% of the energy charges for that consumer. Further, the load factor rebate will be available only if the consumer has no arrears with the MSEB, and payment is made within seven days from the date of the bill or within 5 days of the receipt of the bill, whichever is later.

43. The Commission directs the MSEB to compile data on reactive power consumption by all consumer categories where electronic meters are already installed, as the Commission intends to introduce kVARh tariffs in the subsequent Order. The kVARh consumption data for each billing cycle should be submitted alongwith the next ARR and Tariff Petition.

44. The Commission has increased the differential between tariff applicable for peak hour consumption and off-peak hour consumption by 20 paise per unit, respectively, and off-peak times for the HTP-I and HTP-II categories by 10 paise per unit for peak. The Commission also directs that MSEB should install ToD meters for all consumers with a connected load of over 20 kW, so that ToD tariffs can be availed by these consumers at their option.

45. In the FY 2000-01 Tariff Order, the Commission has directed the MSEB to charge domestic tariffs from certain professional categories if these professionals were using part of their residences for professional work. The Commission clarifies that the domestic tariffs will be applicable only to residential premises used by professionals like Lawyers, Doctors, Chartered Accountants, etc. except for nursing homes and surgical wards/clinics, in furtherance of their professional activity in their residences.

46. The Commission has reclassified the HTP I category to include only those HT industrial and other HT consumers situated in the Mumbai Metropolitan Region (MMR) and Pune Metropolitan Region (PMR), as defined by the State Government. The balance HT industrial and other HT consumers would be classified under HTP II category.



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47. In line with the recently announced IT and ITES Policy announced by the GoM and the stated philosophy of the Commission in previous Orders, the Commission has included the Low Tension IT industry and IT enabled services (as defined in the GoM Policy) in the LTPG category, for purposes of tariff.

48. The seasonal category will include all consumers who opt for a seasonal pattern of consumption, without the need for further approval from the Commission. The consumers should approach the MSEB for classification under the seasonal category if their business is such that electricity requirement is seasonal in nature. The shift from seasonal to normal connection and vice-versa can be done only once each year, at the beginning of the year.

49. The additional standby charges of Rs. 20 per kVA per month will be applicable to HT industrial consumers with captive generating units synchronized with the MSEB grid, only on the extent of standby demand, and not the entire contract demand as prevalent currently.

50. The Commission had initiated the process of levying a ‘Reliability Charge’ to begin with, on HTP-I and HTP-II consumers who have been provided with ToD meters, within urban agglomerations in the State, on consumers receiving power supply through Express Feeders and also those within MIDC areas. The MSEB was allowed to impose an additional charge of 25 paise per kWh to these consumers and ensure that they get uninterrupted power supply. However, the MSEB has not progressed very far in implementing the Reliability Charge, even though it would have resulted in additional revenue, which could have been gainfully employed in strengthening/augmenting the system to improve the quality of supply to consumers. MSEB should use the revenue realised from the Reliability Charge to create a fund which can be used to improving the voltage profile and reliability of supply.

51. Conservation of energy through energy efficiency is very essential, to bridge the gap between demand and supply. The objective of energy efficiency is two fold, viz. to increase the generation through energy efficiency at the generation level, and to manage the demand through Demand Side Management (DSM) techniques, which include load shaping as well as reduction in the consumption levels through use of energy efficient devices. The detailed plan should be submitted to the Commission within three months of this Order.



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Table 1: Tariff Hike for FY 2003-04

Description MSEB Proposal MERC Approval

Tariff Increase in Rs. Crore* 1462 186

Overall Tariff Increase in %* 12.5% 1.5%

* - if revised tariffs were applicable for the entire year

Table 2: Energy Input Requirement (MU)

MSEB Commission

Sales

Metered 32112 32818

Unmetered 8403 6893

Total Sales 40515 39710

T&D Losses 23407 22942

Energy Input Requirement 63922 62652

T&D loss as a % of energy requirement 36.62% 36.62%$

$ - Based on MSEB’s submission, against target level of 26.87%



16

Table 3: Annual Revenue Requirement for FY 2003-04

Sr No

Expense Head MSEB Proposal

(Rs. Crore)

MERC Approval (Rs.Crore)

Remarks

1 Generation 4243 4104 MSEB has considered higher than normative heat rate, transit losses, and escalation in fuel costs

2 Power Purchase 3493 3132 MSEB has considered higher power purchase quantum and escalation in power purchase costs

3 Employee Costs 1695 1655 MSEB has projected higher employee costs despite reducing trend

4 Administration & General expenses

145 139

5 Operation & Maintenance 738 737 6 Depreciation 1585 1578 MSEB has considered a higher

weighted average rate 7 Interest cost 1308 1126 MSEB has considered higher loans

and higher interest on working capital 8 Lease Rental 85 85 9 Provision for doubtful debts 250 181 MSEB has considered provisioning at

the rate of 2% of revenue from sale of electricity

10 Other Expenses 248 206 MSEB has considered higher interest expenditure on consumers’ security deposit

Total Expenses 13790 12943 Add: Surplus 433 433 Total Revenue Requirement 14223 13376 Reduction in Revenue Requirement Revenue earned through

FOCA for FY 2003-04 135 April to June 2003

Other Income 1022 1067 MSEB has projected lower income from interest on delayed payment

Net Revenue Requirement to be recovered through tariffs

13201 12174

Revenue from Existing tariff

12030

Tariff Increase Required 144 Cost of excess T&D losses 947 Average Cost of Supply –

excluding cost of excess T&D losses (Rs./unit)

2.83



17

Table 4: Summary of LT Tariff (Effective from December 1, 2003)

Consumer Category Demand Charge (Rs/KVA/month) or

(Rs/HP/month) or (Rs/service connection per month)

Energy Charge

(p/u)

Regulatory Liability Charge

(p/u)

Domestic (LD 1) 0-30 Units Rs. 20 per service connection 125 31-300 Units 290 Above 300 units (only balance Units)

Single Phase: Rs. 40 per service connection; Three Phase: Rs. 100 per service connection; Additional Fixed charge of Rs. 100 per 10 KW load or part thereof above 10 KW load shall be payable.

400

0

Non Domestic (LD2) 0-100 Units 240 101-200 Units 315 Above 200 units (only balance Units)

Single Phase: Rs. 100 per service connection; Three Phase: Rs. 150 per service connection; Additional Fixed Charge of Rs. 150 per 10 KW load or part thereof above 10 KW load shall be payable. Optional LTMD based Tariff will be available for all consumers.

410

50

General Motive Power (LTP-G) – Base Tariff 0-1000 Units 230 Above 1000 Units (only balance Units)

Rs. 60 per HP (Rs. 80.5 per kW) per month for 50% of sanctioned load; Optional MD based tariff will be available for all consumers, irrespective of Contract demand, at Rs. 220/kVA/month

250 50

OPTIONAL TOD TARIFF

2200 hrs – 0600 hrs -75 0600 hrs – 0900 hrs 0 0900 hrs – 1200 hrs 50 1200 hrs – 1800 hrs 0 1800 hrs – 2200 hrs

0

90 Public Water Supply Urban P. W. Schemes

Rs. 60 per HP per month 240 0



18



Energy Charge

(p/u)


(p/u)

Rural P. W. Schemes

Grampanchayat Rs. 25 per HP per month 100 Metered Tariff (incl. ‘C’ Class Municipal Council)

Rs. 35 per HP per month 150

Street Light Tariff Grampanchayat & Municipal Council

210

Municipal Corporation

Rs. 30 per kW per month

250

0

Agriculture Flat Rate Tariff Category 1 circles* Rs. 180 per HP per month Category 2 circles$ Rs. 150 per HP per month

0 0

Metered Tariff (incl. Poultry Farms)


*Category 1 Circles (with consumption norm above 1300 hours/HP/year)

1 Chandrapur 4 Latur 7 Osmanabad 2 Jalna 5 Nanded 8 Parbhani 3 Kolhapur 6 Nashik 9 Sangli

$Category 2 Circles (with consumption norm below 1300 hours/HP/year)

1 Ahmednagar 10 Buldhana 19 Pune (U) 2 Akola 11 Dhule 20 Ratnagiri 3 Amravati 12 Gadchiroli 21 Satara 4 Aurangabad 13 Jalgaon 22 Sindhudurg 5 Aurangabad (U) 14 Kalyan 23 Solapur 6 Beed 15 Nagpur (R) 24 Vasai 7 Bhandara 16 Nagpur (U) 25 Wardha 8 Bhandup 17 Pen 26 Vashi 9 Bhiwandi 18 Pune (R) 27 Yavatmal



19

Notes: FOCA shall be applicable to all categories of consumers. FOCA will be determined

monthly based on the FOCA Formula approved by the Commission. Billing Demand for LTPG and other LT categories opting for MD based tariff :

Monthly Billing Demand will be the higher of the following:

i. Actual Maximum Demand recorded in the month during 0600 hours to 2200 hours ii. 75% of the highest billing demand recorded during preceding eleven months

iii. 50% of the Contract Demand.



20

Summary of HT Tariff Effective from December 1, 2003

Consumer Category Demand Charge (Rs/KVA/month)

Energy Charge

(p/u)

Regulatory Liability

Charge (p/u)

HTP – I (Industrial - BMR/PMR) Base Tariff

350 215 50

HTP – II (Industrial – Others) Base Tariff

330 210 50

ToD Tariff (for HTP-I & HTP-II)


0

100 Seasonal Category 350 300 0 HTP – III (PWW-BMR/PMR)

350 215 0

HTP – IV (PWW-Others) 330 210 0 ToD Tariff (for HTP-III & HTP-IV)


0

100 HTP - V (Railway Traction) 0 335 50 HTP – VI Residential Complex 220 Commercial Complex

125 350

0

HTP VII (Agriculture)1 Metered Tariff (incl. Poultry, agriculture High tech)

25 130 0

Tata Power Company 600 299 0 Mula Pravara Electric Co-op Society

200 150 0

Inter State Sale 0 260



21

Notes:

1. HTP VII category includes HT Lift Irrigation Schemes irrespective of ownership 2. FOCA shall be applicable to all categories of consumers. FOCA will be determined

monthly based on the FOCA Formula approved by the Commission 3. Billing Demand definitions:

HT Categories (HTP-I, HTP-II, HTP-III, HTP-IV) Monthly Billing Demand will be the higher of the following: i) Actual Maximum Demand recorded in the month during 0600 hours to 2200 hours

ii) 75% of the highest billing demand recorded during preceding eleven months

iii) 50% of the Contract Demand.

Seasonal Category

During Declared Season


i) Actual Maximum Demand recorded in the month during 0600 hours to 2200 hours

ii) 75% of the Contract Demand

iii)50 kVA.

During Declared Off-season

Monthly Billing Demand will be the following:

i) Actual Maximum Demand recorded in the month during 0600 hours to 2200 hours

4. HT Industrial consumers having captive generation facilities synchronized with the grid will pay additional demand charges of Rs. 20 per kVA per month only for the standby contract demand component.



22

5. Incentives

5.1.2 a) Power Factor Incentive

Whenever the average power factor is more than 0.95, an incentive shall be given at the rate of 1% (one percent) of the amount of the monthly energy bill (excluding FOCA charge, demand charge, electricity duty and regulatory liability charge) for every 1% (one percent) improvement in the power factor above 0.95. For PF of 0.99, the effective incentive will amount to 5% (five percent) reduction in the energy bill and for unity PF, the effective incentive will amount to 7% (seven percent) reduction in the energy bill. The power factor incentive is also applicable for LTP-G consumers who opt for LTMD tariff. Such incentives shall not be applicable for the Railways.

5.1.2 b) Bulk discount

If the consumption of any industrial consumer (availing TOD tariff and having no arrears with the MSEB) exceeds one million units per month, the consumer will get a rebate of 1% on his energy bill (excluding FOCA charge, demand charge, electricity duty and regulatory liability charge) for every one million unit consumption above one million unit subject to a maximum of 5%. The rebate will, however, be allowed only if the bill is paid within seven days from the date of the bill or within 5 days of the receipt of the bill, whichever is later.

6. Disincentives

6.1.1 a) Power factor Penalty

Whenever the average power factor is less than 0.9, penal charges shall be levied at the rate of 2% (two percent) of the amount of the monthly energy bill (excluding FOCA charge, demand charge, electricity duty and regulatory liability charge) for first 1% (one percentage point) fall in the power factor below 0.9, beyond which the penal charges shall be levied at the rate of 1% (one percent) for each percentage point fall in the power factor below 0.89. Such disincentives shall not be applicable for the Railways. The power factor penalty is also applicable for LTP-G consumers who opt for LTMD tariff.

After issue of the Operative Order, the Commission issued a Clarificatory Order on the newly introduced Load Factor Surcharge, in response to queries raised by the MSEB and certain consumers, the details of which have been reproduced below:



23

The Load Factor incentive is limited to HTP-I and HTP-II categories only. Further, the load factor rebate will be available only if the consumer has no arrears with the MSEB, and payment is made within seven days from the date of the bill or within 5 days of the receipt of the bill, whichever is later. However, this incentive will be applicable to consumers where payment of arrears in instalments has been granted by the MSEB, and the same being made as scheduled. The MSEB has to take a commercial decision on the issue of how to determine the time frame for which the payments should have been made as scheduled, in order to be eligible for the Load Factor incentive. The Load Factor has been defined below:

Load Factor = Consumption during the month in MU___________

Maximum Consumption Possible during the month in MU

Maximum consumption possible = Contract Demand (kVA) x Actual Power Factor

x (Total no. of hrs during the month less planned load shedding

hours*)

- Interruption/non-supply to the extent of 60 hours in a 30 day month has been built in the scheme.



24

OBJECTIONS ON POINTS OF LAW AND PROCEDURE AND THE FINDINGS OF THE COMMISSION

Acceptance of Petition in the context of Pending Public Interest Litigation

N.N.Kale and Associates have requested the Commission not to accept the present Proposal until Public Interest Litigation (PIL) dated March 15, 2003 and application for rejecting the Proposal dated May 5, 2003 have been disposed off. The Commission appreciates the points made by N. N. Kale and Associates regarding the acceptability of the Tariff Petition in the background of the pending PIL and also because of the fact that the MSEB’s Tariff Petition has not been certified by a Cost Accountant. However, the Commission is of the opinion that the mere fact that there is a pending litigation is not sufficient reason for not accepting the Tariff Petition. Moreover, the High Court has not granted any stay on the filing of the Tariff Petition by the MSEB. Approval of Terms and Conditions of Supply Several consumer associations have pointed out that the Proposal has been submitted before approval of the Terms and Conditions of Supply. They have highlighted that MSEB has not submitted the Terms and Conditions of Supply before August 30, 2003 for approval of the Commission. They have pointed out that the Mumbai High Court has ordered the State Commission to necessarily take into consideration the Terms and Conditions of Supply of electricity in so far as they add to the cost of electricity. They have stated that the Terms and Conditions of Supply cannot be separated from the tariff determination process as SLC charges, service connection charges, supervision charges would have an impact on revenue requirement. Various remedies suggested by consumers to deal with the situation are - reject the Tariff Proposal, consider existing "Terms and Conditions of Supply" while approving tariff, carry out public hearing for both the Proposal and the Terms and Conditions of Supply and Commercial Circulars together. The MSEB has submitted that a proposal in respect of the ‘Conditions and Miscellaneous Charges for Supply of Electrical Energy’ as well as Commercial Circulars as prescribed in previous Tariff Order shall be submitted to the Commission in due course. As regards the Terms and Conditions of Supply, the Commission has been of the view that any delay in the issue of the Tariff Order by the Commission would make the implementation



25

of the Tariff Order difficult, as only 4 months of the current year are remaining. Thus, the Commission is severely constrained to consider this Tariff Order without processing the Terms and Conditions of Supply. The Commission will approve the Terms and Conditions of Supply separately.

ORGANISATION OF THE ORDER

The Order of the Commission regarding the determination of tariff is broadly divided into three parts. The first part consists of a brief history of the tariff determination process and the subsequent quasi-judicial process that it underwent and the operative Order of the Commission passed on December 1, 2003, and the clarifications thereon issued by the Commission. It also gives the framework used by the Commission in evolving the tariff policy, Order and the schedule. It also contains the various objections raised on points of law and procedure during both the phases of public hearings before the Commission and the Commission’s findings thereon. For the sake of convenience, a list of abbreviations with their expanded forms is appended. The second part of the Order lists out the various objections raised by the Objectors in writing as well as during the Public Hearings before the Commission. They have been broadly categorized into seventeen issues and, for the sake of convenience, the various points have been classified under an index, along with page numbers, where the relevant objections have been dealt with. The various objections have been stated briefly, the response of the MSEB has also been stated and the findings of the Commission on each of these points have also been given. The third part of the Order comprises the Commission’s analysis and its decisions on the MSEB’s proposal for revision of Retail Distribution Tariff for FY 2003-04. It briefly enumerates the tariff issues involved, examines the revenue projections of the MSEB, the various cost estimates for the year 2003-04 and the Commission’s reasoning for arriving at acceptable figures with reference to the figures given by the MSEB. Part three also comprises various annexures to this order, comprising of Annexure-I and Annexure-II. Lastly, the philosophy of the determination of domestic tariff, LT tariff and HT tariff has been specified to estimate the income of the MSEB.


Abbreviations 26

List of Abbreviations used in the Tariff Order

A&G Administration & General ABT Availability Based Tariff AP Andhra Pradesh APDRP Accelerated Power Development and Reform Programme APERC Andhra Pradesh Electricity Regulatory Commission ARR Annual Revenue Requirement BEE Bureau of Energy Efficiency BSES Bombay Suburban Electric Supply CAG Comptroller And Auditor General CAGR Compounded Annual Growth Rate CBR Conduct of Business Regulations CEA Central Electricity Authority CERC Central Electricity Regulatory Commission CII Confederation Of Indian Industry CIL Coal India Ltd. CPP Captive Power Plant CPSU Central Public Sector Units DPC Dabhol Power Company DPS Delayed Payment Surcharge E(S) Act or ESA Electricity (Supply) Act, 1948 EA 2003 The Electricity Act, 2003 EDP Electronic Data Processing EHV Extra High Voltage ERC Act Electricity Regulatory Commissions Act, 1998 FC Fixed Cost FCA Fuel Cost Adjustment FOCA Fuel and Other Cost Adjustment FY Financial Year GFA Gross Fixed Assets GoM Government of Maharashtra HP Horse Power HT High Tension (or High Voltage) HTP High Tension Power Hz Hertz


Abbreviations 27

ICWAI The Institute of Cost and Works Accounts of India IEGC Indian Electricity Grid Code IPP Independent Power Producer IREDA Indian Renewable Energy Development Agency IT Information Technology Section IT & ITES Policy, 2003 IT & ITES Policy, 2003 issued by Energy & Labour Department of the

Government of Maharashtra vide Resolution No. ITP-2003/CR-3311/IND-7, Mantralaya, Mumbai - 400 032 dated July 12, 2003.

IWEA Indian Wind Energy Association kcal Kilo Calories kg Kilograms kV Kilo Volt kVA Kilo Volt Ampere kW Kilo Watt kwh Kilo Watt Hour LD1 Residential or Domestic LT category LD2 Non-Domestic LT category LDC Load Despatch Centre LIS Lift Irrigation System LNG Liquefied Natural Gas LS Load Shedding LT Low Tension (or Low Voltage) LTP-G Low Tension Motive Power Group – General Motive Power MD Maximum Demand MEDA Maharashtra Energy Development Agency MES Military Engineering Services MGP Mumbai Grahak Panchayat MIDC Maharashtra Industrial Development Corporation MkCal Million Kilo Calories MMP Master Metering Plan MMR Mumbai Metropolitan Region MOD Merit Order Dispatch MPECS/Mula Pravara Mula Pravara Electricity Co-operative Society MSEB Maharashtra State Electricity Board MU Million Units (million kWh)


Abbreviations 28

MVA Mega Volt Ampere MW Mega Watts NFA Net Fixed Assets NGO Non Government Organisation NPC Nuclear Power Corporation NTC National Textile Corporation NTPC National Thermal Power Corporation O&M Operation & Maintenance OLC On Line Capacity PD Permanently Disconnected PF Power Factor PFC Power Finance Corporation PLF Plant Load Factor PMR Pune Metropolitan Region PPA Power Purchase Agreement PWW Public Water Works REC Rural Electrification Corporation, New Delhi REDAM Renewable Energy Developers Association of Maharashtra RLC Regulatory Liability Charge ROR Rate of Return RR Revenue Requirement SD Security Deposit SERC State Electricity Regulatory Commission SLC Service Line Charges SSI Small Scale Industry STP Software Technology Park T&D Transmission & Distribution TDL charge T&D Loss charge ToD Time-Of-Day TPC Tata Power Company TPS Thermal Power Station UI Unscheduled Interchange VC Variable Cost WTO World Trade Organisation


Index 29

PART II: OBJECTIONS RECEIVED, MSEB’s RESPONSE AND THE

COMMISSION’S RULING

1 TARIFF CATEGORY-WISE REPRESENTATIONS .............................................. 32

1.1 INDUSTRY................................................................................................................... 32

1.2 SEASONAL CONSUMERS ............................................................................................. 35

1.3 DIFFERENTIATION BASED ON LOCATION .................................................................... 36

1.4 POWER LOOM............................................................................................................. 38

1.5 AGRICULTURE............................................................................................................ 39

1.6 RAILWAY TRACTION .................................................................................................. 42

1.7 DOMESTIC POWER SUPPLY TO RAILWAYS................................................................... 44

1.8 HTP-VI CATEGORY................................................................................................... 45

1.9 MULA PRAVARA ELECTRIC CO-OPERATIVE SOCIETY (MPECS) ................................ 47

1.10 OTHER CATEGORIES ................................................................................................ 48

1.11 CONSUMER CATEGORIZATION ................................................................................ 50

2 TARIFF DESIGN AND RATES .................................................................................. 54

2.1 GUIDELINES, COST OF SUPPLY/CROSS SUBSIDY, SUBSIDY......................................... 54

2.2 LEVY OF FIXED CHARGES .......................................................................................... 57

2.3 FUEL AND OTHER COSTS ADJUSTMENT (FOCA) ....................................................... 62

2.4 TIME OF DAY (TOD) TARIFF ...................................................................................... 63

2.5 BULK DISCOUNT ........................................................................................................ 65

2.6 POWER FACTOR (PF) INCENTIVE/PENALTY CHARGE ................................................. 67

2.7 RELIABILITY CHARGE ................................................................................................ 68

2.8 OTHERS ...................................................................................................................... 69

3 TARIFF SETTING PROCEDURE............................................................................. 70

4 TRANSMISSION AND DISTRIBUTION LOSSES .................................................. 73

5 REVENUE/REVENUE ARREARS ............................................................................. 78

6 QUALITY OF SUPPLY/SERVICE............................................................................. 83

7 GENERATION AND POWER PURCHASE ............................................................. 88


Index 30

8 EXPENDITURE ............................................................................................................ 93

9 INFORMATION SYSTEMS AND METERING ....................................................... 98

10 T&D LOSS CHARGE (TDL).................................................................................. 101

11 SECURITY DEPOSIT (SD) .................................................................................... 103

12 SERVICE LINE CHARGES (SLC) ....................................................................... 104

13 CAPITAL INVESTMENT ...................................................................................... 105

14 ENERGY CONSERVATION AND DEMAND SIDE MANAGEMENT(DSM) 106

15 TRIFURCATION OF MSEB.................................................................................. 108

16 DATA DISCREPANCY/INSUFFICIENCY.......................................................... 109

17 NON-COMPLIANCE WITH COMMISSION DIRECTIVES............................ 110

PART III: COMMISSION’S ANALYSIS AND DECISION ON THE MSEB’S

PROPOSAL

18 APPLICABILITY OF TARIFF REVISION FOR REMAINING PART OF THE

YEAR................................................................................................................................... 114

19 AVERAGE COST OF SUPPLY ............................................................................. 115

20 GOVERNMENT OF MAHARASHTRA SUBSIDY............................................. 115

21 CROSS-SUBSIDY REDUCTION........................................................................... 116

22 RATIONALIZATION OF CATEGORIES ........................................................... 117

23 TIME OF THE DAY TARIFF ................................................................................ 117

24 METERING .............................................................................................................. 119

25 COMPLIANCE WITH COMMISSION’S DIRECTIVES BY MSEB................ 120


Index 31

26 PROJECTED ENERGY INPUT REQUIREMENT............................................. 124

26.1 SALES PROJECTIONS ............................................................................................. 124

26.2 ENERGY AUDIT ANALYSIS AND T&D LOSSES ...................................................... 131

26.3 ENERGY INPUT REQUIREMENT.............................................................................. 168

27 EXPENDITURE PROJECTIONS.......................................................................... 169

27.1 GENERATION AND POWER PURCHASE COSTS........................................................ 169

27.2 OTHER HEADS OF EXPENDITURE........................................................................... 193

27.3 ANNUAL REVENUE REQUIREMENT ....................................................................... 200

28 REDUCTION IN ANNUAL REVENUE REQUIREMENT................................ 202

28.1 REVENUE EARNED THROUGH FOCA .................................................................... 202

28.2 OTHER INCOME..................................................................................................... 202

28.3 NET REVENUE REQUIREMENT............................................................................... 202

29 TARIFF DESIGN PRINCIPLES............................................................................ 203

29.1 TREATMENT OF EXCESS T&D LOSSES .................................................................. 204

29.2 GENERAL TARIFF DESIGN PRINCIPLES .................................................................. 207

29.3 ENERGY CONSERVATION ...................................................................................... 213

29.4 RELIABILITY CHARGE ................................................................................... 214

30 REVENUE PROJECTIONS ................................................................................... 221

31 TARIFF HIKE FOR FY 2003-04............................................................................ 221

32 INCENTIVES AND DISINCENTIVES ................................................................. 222

32.1 INCENTIVES........................................................................................................... 222

32.2 DISINCENTIVES ..................................................................................................... 223

32.3 OTHER CHARGES .................................................................................................. 224

33 APPENDIX I 34 APPENDIX II 35 APPENDIX III 36 APPENDIX IV 37 APPENDIX V 37 ANNEXURES


Objections Received, Mseb’s Response And The Commission’s Ruling 32

PART II: OBJECTIONS RECEIVED, MSEB’s RESPONSE AND THE

COMMISSION’S RULING

1. TARIFF CATEGORY-WISE REPRESENTATIONS

1.1 Industry

1.1.1 Objections

The industrial sector has strongly objected to the tariff increase proposal of MSEB on the

grounds that the Proposal is against the basic principles of cost reflective tariff and

progressive elimination of cross subsidy established by the Commission in its past Tariff

Orders.

They have contended that the current tariff has been restricting their ability to compete in the

domestic as well as global market. Captive Power Producers Association has pointed out that

the HT consumption has declined by 2.8% during the past year as industry has been moving

through recession and being forced to pay above the average cost of supply. Several small-

scale industry associations have also brought out that the present tariff is affecting their

viability and existence of their units. Pimpri Chinchwad Small Industries Association has

mentioned that 4,000 out of 7,000 SSIs within Pimpri Chinchwad have closed down. The

objectors have submitted that the MSEB, like any other industrial organisation, must accord

the highest priority to cost reduction and productivity improvement to enable reduction in the

tariffs which would help industries in Maharashtra to remain economically viable.

Mahratta Chamber of Commerce and Industry, Finolex Industries Limited and several others

have pointed out that the effective tariff increase proposed by the MSEB for HT industrial

category works out to 23-26%, considering increase in MD charges and energy charges, as

against the average tariff increase of 12.5% projected by MSEB. They have added that if the

proposed increase in HT industrial tariff is accepted, then the tariff to HT industrial

consumers would move further away from the average cost of supply.

The Indian Ferro Alloy Producers’ Association has represented that Ferro Alloy industry

should be accorded a separate category with a special tariff considering high cost of power in

total cost of finished product. Presently, the industry has been operating at 50% of its total



capacity, mainly due to rock bottom prices in international market and high power tariff

prevailing in India. The Association has submitted that to be competitive in the international

and domestic markets, the industry requires power at competitive prices. Power cost in

Maharashtra, at equivalent rate of 8 -10 cents, has been 3-4 times that of Europe, South

Africa, Australia, USA and Canada. Power cost in Maharashtra has to be also competitive

vis – à - vis other States such as Andhra Pradesh, Orissa, West Bengal, Chhattisgarh,

Meghalaya, etc., which have implemented special tariffs for the ferro alloy industry. The

Association has suggested that industry should be offered tariffs such that it is the lower of

international tariffs and NTPC rates. The tariff should be based on actual T&D losses incurred

by MSEB in supplying power to these industries and should not account for any cross

subsidies.

R L Steels Limited has brought out that the steel industry, whose major inputs are steel and

electricity, is faced with severe competition from China, whose end product price is at the

same level as the raw material cost in India, and has hence been facing a survival problem. If

the industry has to close down on account of higher tariff, MSEB would lose paying

consumers.

Maharashtra Elektrosmelt Limited has requested the Commission to consider telescopic

incentive for maintaining high load factor. They have proposed a discount of 40% for a load

factor range of 50 to 60%, and 50% for load factor greater than 60%.

Maharashtra State Coop Textile Federation Limited has also represented that under the

Agreement on Textile and Clothing (ATC), all quotas restricting textile trade are going to be

eliminated by December 31, 2004 with one global market. To compete effectively, they

would need electricity at internationally competitive rates.

Century Enka Limited, Garware Polyester Ltd, R L Steels Limited and several other

industrial consumers have requested for a separate tariff category for EHV consumers, with

lower tariff as compared to tariff of other industrial consumers supplied at 11kV and 33kV

connection. Lower tariff to EHV consumers is justified on account of lower investments in

infrastructure, lower cost of maintenance and substantially lower transmission and

distribution losses.



Industry has also brought out that any further increase in tariff may force them to opt for

cheaper sources of power such as CPP or other sources in pursuit of competitiveness.

1.1.2 MSEB’s Response

MSEB has responded that the Tariff Proposal has been used as a means of informing the

Commission and the public as to how the MSEB intends to improve its financial viability

through tariffs. The MSEB has added that the Tariff Proposal has detailed the reasons that

have compelled it to propose the tariff hike.

On the issue of separate tariff category for ferro-alloy industries, MSEB has pointed out that

such a move is against the principles of tariff rationalization established by the Commission

in its earlier Tariff Orders.

1.1.3 Commission’s Ruling

The Commission is aware of the problems faced by the industrial consumers and has taken

due care while framing the tariffs. The Commission has rejected MSEB’s Proposal for

increasing tariff for subsidizing categories and has continued the process of gradually

reducing the cross-subsidy burden on subsidizing consumers, including industrial consumers.

The aim of the Commission, while determining the tariffs, has been to ensure that the overall

tariff for the subsidizing consumers is reduced in relation to the average cost of supply.

The Commission is of the opinion that the MSEB faces a threat from movement of

consumers, having very high consumption, to captive generation, under the provisions of the

Electricity Act, 2003 (EA 2003). In order to incentivize such consumers with high level of

steady consumption to remain with the MSEB, the Commission has introduced a Load factor

incentive for consumers having Load Factor above 75% based on contract demand. The

details of the Load factor incentive have been elaborated in the Section on General Tariff

Design Principles, subsequently.

As regards determination of separate tariffs for the EHV and HV category, the Commission

earlier had commissioned a study to determine the voltage-level wise cost of supply. The



study has remained inconclusive on account of data inadequacy. Hence, the Commission has

been constrained to continue, except for rationalising definition, the present tariff

categorisation for HT consumers. However, the Commission would progressively work

towards determining voltage-wise cost to serve and subsequently consumer-wise cost to

serve. The Commission hereby directs MSEB to start maintaining Voltage-level wise asset

classification.

1.2 Seasonal Consumers

1.2.1 Objections

Freshtop Fruits Limited has requested to categorize themselves as HTP-II Seasonal Consumer

Category as their export activity is limited to grape season which lasts for a period of 60 days

in a year. Several other consumers have also approached the Commission to categorise them

as Seasonal Consumers and approve the same status.


MSEB has refrained from responding on this issue, stating that no specific objection has been

raised with reference to the Tariff Proposal.


The Commission clarifies that the seasonal category will include all such manufacturers /

processors who opt for a seasonal pattern of consumption, including but not restricted to those

as defined by the Commission earlier, without the need for further approval from the

Commission. The consumers should approach the MSEB for classification under the seasonal

category if their business is such that electricity requirement is seasonal in nature. The shift

from seasonal to normal connection and vice-versa can be done only once each year, at the

beginning of the year. Further for a seasonal consumer during Declared Off-season.



1.3 Differentiation based on Location

1.3.1 Objections

Adv. M. G. Kimmatkar of Vidarbha Statutory Development Board (VSDB) has suggested

that the ‘tariff’ should not be uniform across the MSEB’s license area. The consumers in

regions away from the generating stations must pay the transmission and distribution

expenses. Vidarbha Iron and Steel Corporation Limited has pointed out that industry in their

region have been incurring cost of transportation on its inputs and outputs as it is away from

source and market. However, they do not get any compensating benefit for being closer to

electricity generating units. The principle of “User Pays” should be rigidly applied to ensure

financial and economic justice to Vidarbha. Further, VSDB has pointed out that the tariff

should be structured to compensate the Vidarbha Region for the economic loss and

environmental degradation arising out of generation of power. Industries in Vidarbha region

have sought relief to boost their commercial viability on the grounds that the generation assets

of the MSEB are primarily concentrated in the Vidarbha region, while the load centres are

located in Western Maharashtra. Thus, consumers of Vidarbha region should not be required

to bear the cost of T&D losses sustained in the transport of energy to Western Maharashtra.

Other consumers in the region have requested to extend this concept to categories other than

industrial HT tariff category as well.

VSDB has pointed out that the large cross-subsidies to specific sections such as, power loom

industries and lift irrigation schemes, which are located in Western Maharashtra, directly or

indirectly results in cross-subsidy by underdeveloped region to developed regions of Western

Maharashtra. To prevent such a situation, the different cross-subsidy should be calculated for

each region separately and the tariff increase for each region should be made proportional to

the subsidy level received by the region.

Chamber of Marathwada Industries and Agriculture has requested the Commission to clarify

applicability of HTP-I category to Nashik, Aurangabad, Waluj, Chikalthana, Chitegaon in

light of the Commission’s Order to consider all industrial consumers even above 500 kVA

outside Mumbai and Pune under HTP-II Category.



Citizens Forum has represented that reducing the difference in tariff between HTP-I and HTP-

II category would have an adverse impact on backward areas. Several objectors have also

complained about the acute discrimination in load shedding practiced by the MSEB between

Mumbai/Pune and other less-developed areas, despite the same tariffs being proposed for the

two regions.


The MSEB has submitted that it has adhered to the stand taken by the Commission in its

previous Tariff Orders that the consumers located near pit head sites should not be charged

lower rates than those situated farther away. The MSEB has added that the Generating

Stations happen to be in the eastern part of the State, as the fuel source is available there

locally, while the generation is done for the benefit of the entire State and should be made

available on equitable basis without any preferential treatment to any of the grid constituents.

Further, the Maharashtra State grid is being treated as a single unit with pooled resources.

MSEB has submitted that the current classification of HTP-1 and HTP-II has been based on

classification as per tariff circular approved by the Commission. MSEB has further clarified

that narrowing gap in fixed charges for HTP I and II is essential to facilitate tariff

rationalisation and reduction of categories in near future.


As discussed in the earlier Orders, the Commission is of the opinion that differential tariffs

for selected regions is not advisable, as this can give rise to similar demands from other

regions as well. The Commission is of the opinion that VSDB’s suggestion that the tariff for

each region should be computed separately based on the cross - subsidy given by that region

is not practical, as each region has a different consumer mix, and the inter-region cross-

subsidy is difficult to assess. However, the Commission has decided to retain the HTP-I and

HTP-II categories, with higher tariffs for HTP-I category. The Commission has also

reclassified the HTP I category to include only those HT industrial and other HT consumers

situated in the Mumbai Metropolitan Region (MMR) and Pune Metropolitan Region (PMR),

as defined by the State Government. HTP-I tariff will not be applicable to urban



agglomeration and units having a contract demand of over 500 kVA outside MMR/PMR

region. The balance HT industrial and other HT consumers would be classified under HTP II

category.

The Commission has continued to reduce cross subsidy for subsidizing categories and has

correspondingly reduced tariff for the HTP-I and HTP-II categories. However, tariff

differential between these two categories has been continued.

1.4 Power Loom

1.4.1 Objections

The power loom Associations have submitted that the situation in the textile industry is

already bleak because of the recession and have requested the Commission to reduce demand

charges to Rs.15 to 40/HP/month as against the prevalent demand charge of Rs.60/HP/month

and MSEB Proposal of Rs.100/HP/month. They have also requested to maintain tariff at

Rs.2.9/unit. Some others have proposed a reduction upto Rs.1/unit.

Janata Dal (Secular) has highlighted that against the norm of 182 units/HP/month, estimated

consumption including load shedding works out to only 160 units/HP/month based on actual

consumption of 141 units evident from meter reading and 19 units of unmet demand on

account of load shedding. They have requested the Commission to consider this fact while

levying a flat rate tariff.

Mill Owners Association has represented against special treatment being given to power loom

industry. They have pointed out that same power tariff rate should be applicable to producers

of the same article, regardless of their size.


The MSEB has submitted that the current proposal for tariff revision for all categories is

based on a certain level of revenue gap and tariff principles. By this proposal, the MSEB has

been trying to achieve a mandatory surplus of 4.5% and not been targeting super normal

profits. If any category feels that the tariffs are unreasonable, it can approach the State

Government for subsidy.




The ERC Act, 1998 and the EA 2003 clearly state that the Commission cannot show undue

preference towards a particular consumer category. At the same time, the Commission is

bound to safeguard the interests of the consumers while maintaining the financial viability of

the MSEB. The Commission has been revising tariff in accordance with the principle of

gradual reduction of cross subsidy without exposing any consumer category to tariff shock. If

consumers find that the tariffs determined by the Commission cannot be borne by them, they

can approach the State Government for a sector specific subsidy.

The Commission has discontinued the practice of flat rate tariff for power loom category as

the MSEB has confirmed earlier that all the consumers in this category have been provided

with meters. On the issue of demand charge, the Commission clarifies that it has maintained

demand charge at the same rate, which is applicable on 50% of sanctioned load in case of

LTP-G category, under which the power loom industry is classified. In addition, the

Commission has also offered the option of demand charges based on billing demand instead

of sanctioned load.

1.5 Agriculture

1.5.1 Objections

Prof. N D Patil of Maharashtra Rajya Veejgrahak Shetkari Sabha and Bhartiya Shetkari

Kamghar Paksh has submitted that the flat rate charged to agriculture pumps and cooperative

irrigation scheme in Maharashtra has been on higher side as compared to other States in India.

This has resulted in closing down of several cooperative lift irrigation schemes. Indoli

Paradashik Nal Pani Purvata Sansthan has submitted that increase in tariff through last Order

has increased their bill from Rs.12,000-14,000 to Rs.75,000-85,000, which they cannot

afford. If such a tariff increase continues, they would be forced to resort to tanker water

distribution. They have pleaded to reduce tariff to Rs.500/HP/year. Harishchandra Sahakari

Federation Limited has submitted that all cooperative lift irrigation schemes should be

considered under LT tariff category instead of HTP VII category to maintain parity with other

individual offtakers. They have also highlighted that MSEB has been saving Rs.40,000 per

connection by supplying at a single point.



Harishchandra Sahakari Federation Limited has submitted that the agriculture tariff category

should not be formed with HP rating of pump as a basis. HP rating of a pump typically

depends on water depth, and distance in addition to area under irrigation. Classification based

on HP rating of pump amounts to differentiation amongst farmers who has no control over

either water level or distance. Hence, instead of charging higher to farmer with higher HP

pump, all the farmers should be charged at the same rate. Some agriculture consumers have

also submitted that electricity charge should not be levied on standby pumps.

Janata Dal (Secular) has represented against MSEB’s claim of usage of agricultural pump for

1,477 hours for FY 2001-02 and 1,576 hours for FY 2002-03. They have quoted MSEB’s

metered consumption for agriculture as a reference. Metered LT agriculture pumps, with a

total load of 1,211,822 HP had shown consumption of 584,089,013 units for FY 2002-03.

This translated to 646 hours of usage. Similarly, HTP-VII category, a100% metered category,

demonstrated usage for only 2,346 hours as against norm of 3,600 hours. Pravara Institute of

Research and Education in Natural and Social Science has also submitted that the proposed

consumption norm for irrigation pump does not take into account actual hours of availability

of water due to prescribed rotation and allowed hours for lifting water and hence appears to

be on higher side.

Some of the sugarcane cultivators have submitted that the State Government should subsidise

cost of power beyond Rs.900/HP as the State Government is earning Rs.13,152/Acre of

sugarcane crop as against farmer’s earning of Rs.1800/Acre.

Shri. Shriram M Sane has objected to MSEB’s proposal to not increase HP based tariff for

agriculture. He has requested the commission to specify a formula to remove cross

subsidisation in a time bound manner.






Government for subsidy.



On the suggestion of levy of uniform rate for all metered agriculture consumers, MSEB has

submitted that the uniform rate per HP is in place for all LT Agricultural consumers since

January 2002.

On the issue of mismatch in the number of hours of operations of unmetered and metered

agricultural, MSEB has explained that the metered consumer would be more conscious of the

level of consumption than the unmetered consumers. It may also be the case that higher the

level of annual electricity consumption, the more profitable it would be for the consumer to

pay unmetered tariff. With this background, MSEB has proposed to make unmetered tariffs

higher than metered tariff.


The Commission would like to highlight that the flat rate tariffs charged to LT/HT agriculture

and Lift Irrigation Schemes are substantially lower than the average cost of supply and these

categories are being cross subsidized by other consumer categories such as HT industries,

LTP-G, commercial and Railways. The Commission is of the view that the tariffs should

gradually move towards the average cost of supply and had initiated the process of increasing

the agricultural tariffs in the past two Tariff Orders, towards this objective. The Commission

has always ensured that the tariff increase is gradual, so that no consumer category is faced

with a tariff shock. The increase in agricultural tariffs towards the average cost of supply has

been continued in this Order also; however, the rise is gradual so as to avoid tariff shock. If

consumers find that the tariffs determined by the Commission cannot be borne by them, they

can approach the State Government for a sector specific subsidy.

Further, slabs based on the HP rating of the pumpset have been eliminated in the previous

Tariff Order based on suggestions received from consumers and the same flat rate tariff per

HP was made applicable to all LT agricultural consumers, irrespective of the connected load

rating of the pump.

Based on the improved metering of agriculture feeders and consequent availability of

consumption information, the Commission has decided to levy differential flat rate tariffs for

different consumption bands. As a first step, the Commission has decided to levy differential



flat tariffs in two slabs based on average consumption of group of circles. The Commission

would further fine-tune this tariff during the next review with improvement in metering of

agriculture feeders. The ultimate objective is to move all consumers to metered tariff and

abolish flat rate tariffs.

Due to difficulty in distinguishing between stand-by pumps and working pumps for the

purpose of flat-rate tariff, the Commission is not in a position to specify tariffs separately for

working pumpsets only. The Commission advises consumers to shift to metered tariff so that

they get billed on actual consumption, and avoid being billed on flat rate basis on the entire

connected load including standby charges.

1.6 Railway Traction

1.6.1 Objections

Railways have strongly objected to the tariff increase proposed and have pointed out that they

are a bulk consumer and the single largest consumer of electricity and are likely to consume

980 Mn units and pay Rs.431 Crore during FY 2003-04. The principles of “higher the

voltage, lower the tariff” for HT supply should be applied to Railway traction as well.

Railways have argued that supplying power to Railway traction load is comparatively more

economical to MSEB than supplying similar power to other bulk consumers as bulk of power

is supplied at higher voltage and corresponding cost of transmission is also lower due to

lower network length. Cost of billing and collection is also less due to bulk consumption at

single location. They have also quoted Article 287 of the Constitution stating that prices

charged to the Railways should be less than that charged to other bulk consumers. However,

MSEB has increased railway traction tariff with an average annual hike of 13.7% over past 13

years and charged Railways 85% more than their average cost of supply during FY 2002-03.

They have argued that the unreasonably high traction tariff would make the operation of

electric traction costlier than diesel, which would not be in the national and environmental

interest. Railways have proposed to reduce the tariff to a reasonable level taking into account

MSEB’s average cost of supply to Railways either based on own generation (estimated

around Rs 3.5/unit) or based on power purchased from CPSUs (estimated at Rs 3.12/unit).



Railways have requested the Commission to extend ceiling on bulk discount to maximum of

5% as available to other bulk consumers. Presently they have been offered 1% rebate if their

consumption exceeds one million units. Railways have also pointed out that they have been

using electricity at off-peak hours thereby indirectly helping MSEB to improve overall load

factor. They have requested for the Time of Day Tariff option.

Railways have requested that interest should not be charged Delayed Payment Surcharge

(DPS). DPS and interest amounts to double penalty. DPS should be applicable after 15 days

of the date of delivery of the bill to the consumer. They have further requested that the

surcharge at the same rate should also be levied for delay in payment of charges by MSEB as

well.

Central Railways have pointed out that they are forced to pay PF penalty as electronic meters

erroneously record PF below 0.72 by adding both leading and lagging kVArh. Since leading

kVArh is beneficial to MSEB grid, they have submitted that meter should be programmed

such that leading kVARH is either ignored or subtracted from lagging kVARH while

measuring overall Power Factor.

Western Railways have requested the Commission to direct MSEB to improve the billing

system so as to generate single consolidated bill for all the 90 connections of Western

Railway, which could save administrative load of both Western Railway and MSEB and

avoid any delay in payment arising out of postal delays.


On the issue of tariff revision for Railways, MSEB has submitted that it has already detailed

the reasons that have compelled it to propose tariff hikes for categories currently paying

above the average cost of supply.

On the issue of ToD tariffs for Railways, MSEB has submitted that ToD tariff cannot be

levied for Railways as Railways are being levied a single part tariff without demand charges.

Further, the demand is for a very short period.

With reference to the practice of charging DPS and penal interest for late payment, MSEB

has submitted that the MSEB has been levying DPS as a deterrent to prompt the consumer to



pay energy bills in time. Any reduction in this charge or its removal might result in delaying

the MSEB’s dues, which is not desirable. The DPS is a one-time levy charged by the MSEB.

In case the consumer continues to default, a penal interest is then charged.

On the issue of installation of electronic meters, MSEB has submitted that they have issued

necessary instructions to the SE (TCC), Pune to investigate the matter.


The Commission had initiated the process of tariff rationalization and cross-subsidy reduction

through its previous Tariff Orders, and has continued the process in this Order as well. The

Railways’ tariff has been determined such that there is a reduction in the tariff in relation to

the average cost of supply. Further, the Commission has also maintained bulk discount and

prompt payment incentive at the same rate and conditions.

The Commission has offered the Time of Day rate to categories, which are capable of shifting

their load. Since, the schedule of trains is determined based on need of common public and

not based on optimization of electricity tariff, the Commission has not offered ToD rate to the

Railways.

The Commission clarifies that the DPS is levied for only the first month, and thereafter the

interest is levied on the outstanding amount for continued delay in payment.

1.7 Domestic power supply to Railways

1.7.1 Objections

The Railways have brought out that not much progress on segregation of meters for staff

quarters in MSEB area has been achieved despite Commission’s initial Order dated May 5,

2000 and further directive to expedite the same vide last Tariff Order. The Railways have

requested the Commission to direct MSEB to expedite segregation of domestic load. Till such

time that the segregation is done, all such connections where Railways have already paid

segregation charges, the Commission should direct MSEB to charge at LD-1 rates with

retrospective effect.




MSEB has not addressed this issue in its response.


The Commission has taken serious note of the MSEB’s lapse in not implementing the

Commission’s Order. The Commission directs MSEB to explain this non-compliance by

submitting to the Commission the status report and the reasons for failure. The Commission

hereby directs MSEB to apply LD-1 tariff for connections where Railways have already paid

segregation charges with effect from date of initial commitment by MSEB. In line with EA

2003 provisions i.e., principle of fixation of tariff on the basis of cost-to-serve and franchisee

model, MSEB in future can prepare a scheme beneficial to both.

1.8 HTP-VI Category

1.8.1 Objections

Several representations have been received from HTP-VI category for reduction in existing

HTP-VI tariff to promote bulk purchase and retail distribution by third party such as local

authority, panchayat institution, users association, cooperative societies, NGOs and

franchisees. This could reduce subsidy by converting lower consumption LD category to HT

category and promote efficiency as well.

Military Engineering Services (MES) has requested the Commission to introduce separate

tariff category for bulk supply to MES in the cantonments/military/naval/air force

stations/defence establishments in Maharashtra State against present categorisation of their

load as HTP-VI-domestic or HTP-VI-commercial and industrial. They have pointed out that

load in Defence Establishment is predominantly domestic. They have also sought a further

relief of Rs.0.97/unit as they maintain their own distribution system. They have requested for

a levy of tariff to Military/Airforce/ Naval hospitals at a lower rate as that of Ashwini

Hospital of Defence. They have sought a higher incentive for maintaining high power factor

and load factor. They have also pointed out that electricity consumed by MES should be

exempt from any taxes/duties as per provisions of the Article 287 of the Constitution of India

and ED levied erroneously by MSEB should be refunded/adjusted against their future

electricity bills. MES has brought out that though MSEB had agreed to apply HTP-VI tariff



for all establishments since September 1, 1998, they have substantially delayed levy of tariff

at HTP-VI rate for some of their connections and has accordingly sought refund of around Rs.

5 Crore for excess tariff charged.


MSEB has pointed out that creation of new tariff/category for MES would be against the

principle of tariff rationalisation. MSEB has submitted that it has classified the connections

based on the nature of the load. The MSEB had taken into consideration the advantages that it

enjoys on account of connection to MES while classifying the connection to a particular

category. MSEB have pointed out that MES cannot be a deemed to be a licensee as the phrase

“Government Company or the company” (under Section 14, paragraph 6 of EA 2003) are for

entities which may be formed under Section 131(2) of EA 2003. MSEB has further clarified

that MES have not been enjoying power factor incentive as it has been offered to consumers

having power factor above 95%.

MSEB has responded that it collects the duty on behalf of the State Government, which

decides the rate and concessions on duty to be given, if any.


The Commission has maintained the effective average tariff for HTP-VI category at earlier

levels, in line with the principle espoused in the previous Tariff Order. The HTP-VI category

specifically promotes bulk purchase and retail distribution and the Commission agrees with

the merit of bringing tariff for this category to the level of Cost to Serve. In the absence of

reliable data to work out Cost-to-Serve for each of the category, the Commission has

maintained tariff at earlier levels, and not charged Regulatory Liability Charge (as applied to

industrial and commercial category). It has also rationalised industrial tariff, thereby reducing

the difference between domestic and industrial tariff in line with philosophy of moving

towards average cost of supply.

As regards the delay in converting some of the connections to HTP -VI category, it amounts

to a billing dispute and the MES should approach the Forum separately under the appropriate

Regulations, viz. Consumer Grievance Redressal Forum and Ombudsman Regulations,

2003, under S.181 of the EA 2003. As regards the levy of taxes and duties including



electricity duty, it is outside the purview of the Commission, and the MES may approach the

GoM in this regard. In line with EA 2003 provisions i.e., principle of fixation of tariff on the

basis of cost-to-serve and franchisee model, MSEB in future can prepare a scheme beneficial

to both.

1.9 Mula Pravara Electric Co-operative Society (MPECS)

1.9.1 Objections

The Mula Pravara Electric Co-operative Society (MPECS) has opposed the current tariff of

Rs.1.50/kWh as energy charge and demand charges of Rs.200/kVA for the Society. The

MPECS has submitted that 82% of its consumers are from the agricultural category, and, as

the MSEB tariff is applicable to its consumers also, the current tariff would result into a loss

of around Rs.90 Crore for the society. On the other hand, other objectors have requested to

increase the tariff for MPECS such that it reaches average cost of supply by January 10, 2007

as per previous Order. They have further requested to freeze supply level of all defaulting

customers till they settle their dues.


As regards freezing of supply to Mula Pravara, MSEB has submitted that it had issued a

disconnection notice to MPECS. On submission of proposal by Government of Maharashtra

(GoM) to the Commission in this matter, a hearing was held on August 29, 2003. The

Commission had observed during the hearing that MSEB might reconsider the action in light

of the steps proposed by Government of Maharashtra.

MSEB has submitted that no tariff hike has been proposed for Mula Pravara as it is a bulk

consumer of the MSEB having different mix of consumer, predominantly agriculture. As per

the MSEB’s understanding, Mula Pravara classifies its consumers on the same basis as the

MSEB’s consumers and levies the same tariffs.


The tariff applicable for sale to Mula Pravara Electric Co-operative Society (MPECS) has

been retained at the existing level. The Commission has separately forwarded a Report on the

viability of the MPECS to the Government of Maharashtra.



1.10 Other categories

1.10.1 Objections

Several Consumer Associations have represented against increase in rates for residential,

commercial, small-scale business, cooperative lift irrigation scheme, small power loom, small

flour mills, etc. The objection is on the ground that increase in tariff is unaffordable,

unsustainable and in several cases tariff proposed has been higher compared to other States.

Khamgaon Nagar Parishad has opposed tariff increase to HTP IV category stating that any

increase is not affordable since they are a ‘no profit, no loss’ organisation. Several Municipal

Corporations have represented against proposed hike in tariff for water supply scheme and

street lighting categories. Savada Nagarpalika has requested to revert back to flat rate tariff

instead of metered tariff for water supply schemes since these schemes are operated on ‘no

profit, no loss’ basis.

Several domestic consumers have stated that effective rise for this category works out to

24.52% as compared to overall increase of 12.5%. One of the consumers has suggested

reducing number of slabs to 3 from 4 for LD 1 category. Slabs should be categorised as a first

slab for single bulb consumers (0-30 units); second slab for consumers using lamps, fans, TV,

refrigerator, iron, heating pad/oven, water geyser (30-250 units); and third slab for consumers

using additional accessories such as air conditioner, microwave (>250 units). Third slab

should subsidise first slab and middle slab should be charged at the average cost of supply

and category as a whole should be charged at the average cost of supply. Janata Dal (Secular)

has suggested creation of a separate category for single bulb consumers, public association

and Software Technology Park (STP) to give them special benefit.

Kolhapur District Cine Distributors Association has requested the Commission to maintain

tariff at earlier rate of Rs. 3.59/unit to enable their survival. Citizens Forum has also brought

out that the proposed increase of Rs.0.65/unit for LD 2 category will adversely affect small

shopkeepers and small commercial establishments. They have added that the increase in

charges for the slab of 201-500 units under LD 2 category could have been avoided by

improving efficiency of the system.



Mumbai Grahak Panchayat has suggested that HTP VII, Power looms, agriculture (10-25 HP

and >25 HP) should only be offered metered tariff instead of unmetered tariff at option.


With reference to the objection that the proposed tariff revision is unsustainable, MSEB has

stated that it has proposed tariff hike in accordance with Section 59 of erstwhile E(S) Act,

which states that the MSEB needs to set its tariffs in such a way that it can recover a

minimum of 4.5% of its Net Fixed Assets in any year of account over and above all expenses

chargeable to revenue in that year. The MSEB has not proposed tariff revision to make

supernormal profits. Also, linking the level of tariff revision for a consumer category to the

affordability of the same to the members of that consumer category is not a principle required

either under the erstwhile ERC Act, 1998 or EA 2003. If any consumer category feels that the

tariffs are unaffordable, it can approach the State Government for providing of subsidy as

required under law.

MSEB has further submitted that comparison of tariffs in isolation would not be proper since

determination of tariff inter alia would depend upon many factors, such as generation

capacity, hydro-thermal ratio of generation capacity, cross-section of consumer mix,

availability and quality of supply, the quantum of statutory revenue surplus, socio-economic

condition of the respective State, geographical situations, etc. Since, all these factors differ

across various States, a simple comparison of the electricity tariff is not proper.

With reference to billing based on flat rate tariff, the MSEB has submitted that meterisation of

all consumers is a directive given by the Commission. Further, the EA 2003 also mandates

the meterisation of all consumers within a specific time period.


The Commission has considered all representations from various consumer categories and

has ensured that the tariff revision is within reasonable limits. Due care has been taken to

ensure that there is no tariff shock to any consumer category while implementing the revised

tariffs.. At the same time, the Commission is committed to reducing cross-subsidies over a

period of time, by moving the tariffs applicable to various consumer categories towards the

average cost of supply. The Commission has reduced the effective tariff for subsidizing



categories viz. commercial, LT and HT Industrial, HT Public Water Works and Railway

Traction categories. The Commission has reduced tariff for HT Public Water Works such that

they converge to the average cost of supply. The Commission has increased the tariff

applicable to LT Public Water Works and street-lighting categories, as the average tariff is

below the average cost of supply, while ensuring that these categories are not subject to a

tariff shock.

The Commission has limited the average tariff increase for LD 1 category to 6% and moved

the tariffs closer to the average cost of supply. Intra-class subsidy amongst domestic

consumption slabs has been further rationalized. The intra-class cross subsidy for the first slab

(i.e. upto 30 units of consumption) has been continued as this slab affects consumers in the

lifeline category.

The Commission has discontinued flat rate tariff for HTP-VII category as 100% metering has

been achieved, and the entire consumption of this category is metered. However, flat rate

tariffs have been continued for the agriculture category, as most of the LT agricultural

consumers (around 18 lakh) are yet to be metered. The Commission has discussed the issues

related to metering in a subsequent Section.

1.11 Consumer Categorization

1.11.1 Objections

There are several representations for clarity on definition and differentiation amongst various

tariff categories.

Vidarbha Industries Association has pointed out that MSEB has been refusing to apply

General Motive Power tariff to industries having industrial registration but not having motive

load. For software industries, non-domestic tariff is being applied instead. They have

suggested that the name of LTP-G category should be changed to L.T. Industrial tariff. As per

the IT and ITES policy, 2003, Easypack Software Inc. has pointed out that IT and IT Enabled

Service units will be entitled for the supply of power at industrial rates.

Vidarbha Industries Association has requested for permitting connected load upto 100 HP

under LTP-G category. Additionally, they have sought a clarification on validity of MSEB’s



approach of applying HT tariff, if connected load is found more than 67 HP/50 kW during

spot inspection. Hotel and Restaurant Association has also requested the Commission to

enhance the limit from 50 kVA to 100 kVA for categorisation as a HT consumer, as many

small-scale industrial and commercial establishments, including hotels and restaurants, have

been burdened with the cost of becoming a HT consumer.

Rashtriya Grahak Sanghatana has highlighted several other issues related to billing

categorisation. Residential accommodations in residential schools are being charged

according to LD-2 commercial tariff. The offices of professionals such as advocates, doctors,

practicing engineers etc, are being charged as per LD-2 tariff in spite of the direction of the

Commission.

Nashik Flora Private Limited has objected to MSEB’s restrictive application of concessional

tariff category to a limited class of consumers who undertake restricted activities like, ‘Tissue

Culture’, ‘Green House’, and ‘Mushroom Cultivation’. It has pointed out that Department of

Agricultural and Co-operative, Government of India, has defined ‘High-Tech Agriculture’ as

“any agriculture/horticulture technology, which uses modern technology making it less

environment dependent and has the capacity to produce high quality of any

agriculture/horticulture crop”, and which can inter-alia include (other than Tissue Culture,

Green House, Mushroom) such other technologies like genetically modified crop varieties,

micro-propagation, production and use of F1 Hybrid seeds, drip-irrigation/fertigation, organic

farming, vermiculture, bio-fertilisers, mechanical production systems, hi-tech post harvest

technologies, etc.

Venkateshwara Hatcheries Private Ltd has represented that though HTP VII tariff category

covers poultry, MSEB has been applying this definition selectively to activities of producing

eggs and broilers but not for operations connected with breeding and hatching. It has

requested to extend HTP VII to cover entire operations of poultry. They have also quoted the

Supreme Court verdict in Commissioner of Income Tax vs. Venkateshwara Hatcheries

Private Limited that stated that poultry, being a natural process, does not qualify to be treated

as an industrial undertaking.

New Era Development Institute has requested the Commission to clarify whether HTP VI

category includes residential schools/charitable or religious institutions as they are supplied



electricity through HT connection. They have pointed out that MSEB is wrongly applying

HTP-II tariff to the Institute while they are not an industry.

Shree Om Estate Developers has requested to clarify the tariff category for electricity

provided to open spaces/play grounds in housing societies/gardens. It has requested to

consider them either under LT-AG or Street Lighting category. Rashtriya Grahak Sanghatana

has pointed out that public gardens and open spaces created as per the directions of Town

planning authorities have been charged as per LD-2 tariff, which is erroneous.


MSEB has submitted that it is classifying consumers based on detailed tariff booklet, which

has been approved by the Commission. MSEB cannot change the classification of any

consumer without permission of the Commission. As a result, the MSEB has suggested that

the objector can separately approach the Commission for change in classification.

MSEB has clarified that tariff applied to LTP-G consumer having sanctioned load upto 67 HP

(100 HP wherever applicable) is the same as LTP-G tariff approved by the Commission.

With reference to the objection on levying residential tariff to Advocates and Doctors, MSEB

has submitted that the Commission has approved the tariff consumer categorisation.

MSEB has responded that the Street Lighting tariff is applicable for street lighting services of

Gram Panchayats, Municipal Councils and Corporations. Hence, even if part of the

requirement is for lighting the roads inside the premises of the objector, it cannot be allowed a

Street Lighting tariff. Likewise, the private gardens within the premises cannot be allowed

LT-AG tariff.


The consumers in the Information Technology (IT) and Information Technology Enabled

Services (ITES) sector are currently classified under the commercial category and charged

accordingly. As the commercial category is a subsidizing category, the tariffs are high for

these categories. The Commission has been receiving applications from such consumers

requesting that they should be classified under LT industrial category, for the purposes of

tariff determination. In July 2003, the GoM announced the IT and ITES Policy, 2003 for



promoting business and enterprise in the IT industry, to make Maharashtra the most favoured

destination for investments in the IT and ITES industry. In the context of the infrastructure

support to the IT and ITES sector, the Policy specifies under Clause 4.2 (h) that, “Levying of

power charges on IT and ITES units at industrial rates and notifying IT and ITES units as a

separate category of consumers through MERC”.

In line with the IT and ITES Policy announced by the GoM and the stated philosophy of the

Commission in the previous Orders, the Commission has included the Low Tension IT

industry and IT enabled services (as defined in the GoM Policy) in the LTP-G category, for

purposes of tariff determination. The Commission has decided against creation of a new

category for IT and ITES sector, in line with its stated philosophy of reducing the number of

consumer categories and consumption slabs, over a period of time.

On the issue of categorizing industries with higher connected load under LTP-G category, the

Commission is of the view that the existing classification should be retained. The

Commission has already stated its intention of moving towards voltage-level cost based tariffs

in the future. As the cost of supply at higher voltages is lower, the consumers will benefit if

connections are taken at higher voltages. Moreover, for serving higher loads, HT connection

is desirable due to lower T&D losses. Hence, the Commission has retained the existing

provisions of classification of industries having connected load over 100 HP under HT

category.

In the FY 2000-01 Tariff Order, the Commission has directed the MSEB to charge domestic

tariffs from certain professional categories if these professionals were using part of their

residences for professional work. The Commission clarifies that the domestic tariffs will be

applicable only to residential premises used by professionals like Lawyers, Doctors,

Chartered Accountants, etc. except for nursing homes and surgical wards/clinics, in

furtherance of their professional activity in their residences.

The Commission also clarifies that the existing definition of ‘High-Tech Agriculture’, viz.

units undertaking tissue culture, green house, mushroom cultivation, etc. activities, shall

continue to be in existence. The Commission hereby clarifies that the existing definition of

Poultry shall continue to be retained for the purposes of tariffs.



As regards tariff applicable to residential accommodation within residential schools, the

Commission clarifies that the levy of tariff at LD-1 rate is not possible as they are not metered

separately. The Commission directs the MSEB to segregate the residential connections and

levy LD-1 tariff on such residential accommodations.

The Commission clarifies that certain public gardens and open spaces that have been created

as per the directions of Town Planning authorities would continue to be charged at LD-2

tariffs or tariff applicable to temporary connections as at present, if they are used for non-

commercial activities. The MSEB cannot be expected to subsidize such consumer categories

that are used normally for commercial purposes.

2. TARIFF DESIGN AND RATES

2.1 Guidelines, Cost of Supply/Cross subsidy, Subsidy

2.1.1 Objections

TARIFF GUIDELINES

Several objectors have stated that the tariff revision proposal is against the provisions of the

Indian Electricity Act and erstwhile E(S) Act. Tata Motors as well as several Consumer

Associations have brought out that MSEB’s Tariff Proposal is a violation of basic guidelines

such as, tariff reflective of cost of supply, complete removal of cross-subsidy/subsidy by 2005

and inefficiency on part of utility not being passed on to diligent consumers. Industry

Associations have suggested rejecting the Proposal on the ground that it is arbitrary,

discriminatory, illegal and violating the spirit and objective of the legislation. All the

consumers of subsidising categories have strongly objected to the tariff increase proposed for

subsidising consumers on the ground that they are paying consumers.

Several Consumer Associations have requested to adopt Multi-Year Tariff system of 3 to 5

years. This would enable industry to work with a long-term perspective.

COST OF SUPPLY/CROSS SUBSIDY

Several industries and the Railways have vehemently opposed the tariffs proposed, as they

are not aligned to the costs incurred to serve them. They have argued that HT consumers



have to bear a much higher burden in comparison to the cost of supply. The Railways have

further contended that being an EHT consumer, the cost of supply to the Railways is

considerably lower than that for other consumer categories. Industry Associations have

further argued that the non-computation of consumer category-wise costs is not allowing the

design of tariffs based on cost imposed by different categories on the system. They have

stated that this is in violation of the statutory provisions of the EA 2003, ERC Act, and E(S)

Act.

Industrial Associations have argued that cross-subsidy is being provided to subsidised

categories at the expense of industry. They have put forth that cost of such subsidy should be

borne by the Government rather than being loaded onto industry. The current proposal is seen

as further increasing the cross subsidy provided by industry. Several consumers have

contended that it is necessary to curb inefficiency in the MSEB than allowing across the board

hike for all categories of consumers. Vidarbha Chamber of Commerce and Industry has

presented a view that cross subsidy should not exist as Constitution of India specifies, “for act

of one person, other persons cannot be held responsible”. Thane Small Scale Industries

Association and Kalyan Ambernath Manufacturers’ Association have highlighted that MSEB

Proposal does not meet basic requirement of the ERC Act, 1998 of charging atleast 50% of

the average cost of supply by 2002 (i.e. within 3 years after 1/4/98, i.e. the date of ERC

ordinance/Act went into effect).

Industrial consumers have requested to continue reduction in cross subsidy for HT consumes

in line with the Commission’s guidelines.

SUBSIDY

Akhil Bhartiya Grahak Panchayat has pointed out that amount of subsidy/subventions from

Government has not been accounted while proposing the tariff hike. Several consumers have

highlighted that if the Government wishes to subsidise particular categories, it should

explicitly fund that subsidy out of the State budget and deposit the same with MSEB in

advance. Prayas has specifically sought clarity on decision of offering subsidy for agriculture

and power loom consumers with quantum and schedule of their payment.



Government of Maharashtra has stated that it would decide about the grant of subsidy after

determination of tariff by the Commission under section 62 of EA 2003. The issue of granting

subsidy for FY 2003-04 based on existing rate is under consideration of the Government.

Government is anxious to know the net tariff payable by the subsidised consumers after

accounting for the subsidy and hence would find it difficult to commit subsidy amount

without knowing the tariff fixed by the Commission.






Government for subsidy. The MSEB has added that the rationale for the proposed tariff

revision has been explained in detail in the Tariff Petition, and it has been forced to propose

tariff increase even for subsidizing categories as these are paying categories and tariff

increase for subsidized categories does not result in significant additional revenue for the

MSEB.

On the issue of the Government subsidy, MSEB has submitted that the Government declares

subsidy separately for each year. While the subsidy for FY 2000-01, FY 2001-02 and FY

2002-03 has been declared, the Government is yet to declare the subsidy amount for FY

2003-04 to the MSEB or to the Commission.


The Commission is of the view that determination of category-wise cost of supply at this

point in time is not possible considering the quality of data available with the MSEB. Such

an exercise will involve a lot of assumptions, and the results may not be reflective of the

actual conditions prevailing. In the present tariff determination exercise, the Commission has

continued tariff determination, such that the average tariffs for subsidising categories is

reduced and the average tariffs for subsidised categories is increased in relation to the

average cost of supply. The Commission has increased tariff for all subsidised categories

such that no category pays below 50 % of the average cost of supply. The Commission



accepts the MSEB’s reasoning that it is not appropriate to compare the average cost of supply

across Utilities/Countries, without considering the impact of other factors influencing the cost

parameters. As the Commission had indicated in the previous Tariff Orders, the reduction of

cross-subsidy is a gradual process and cannot be achieved overnight.

The Commission is in agreement with the merit of adopting Multi-Year Tariff system and is

actively considering the same. The Commission believes that a regulatory oversight is

essential during the transition period to facilitate speedy implementation of adequate metering

and billing systems, loss reduction/efficiency improvement initiatives and cost reflective

tariffs. These measures would improve the quality of data available to enable long-term

projection of costs and revenues to consider multi-year tariff implementation at an appropriate

time. Therefore, the Commission believes that ‘Cost-Plus’ basis of regulation with regulatory

oversight is appropriate to ensure prudency of expenditure during the transition period.

2.2 Levy of Fixed Charges

2.2.1 Objections

Nag Vidarbha Chamber of Commerce has submitted that there should be no fixed charge levy

on consumers since consumer bears fixed cost at the time of taking up meter connection.

Since, HT connection has a higher utilisation ratio as compared to that of LT connection,

Hotel and Restaurant Association have requested to adjust levy of demand charges to HT

consumer such that the rate would be discounted by atleast 25% to that of LT consumer rate

in a phased manner over 2 years.

Most consumer categories have represented against proposed hike in demand charges.

Vidarbha Chamber of Commerce and Industry has pointed out that proposed demand charge

increase is quite steep for single shift and double shift industries. For example, proposed

increase for HTP-I and II category translates to 180 % increase for single shift category of

100 kVA billing demand. They have requested for consideration of differential demand rate

for different time zones to flatten the load curve. They have proposed to levy 30 % of

demand charge for A shift (0600-1400 hrs) operations, 50% of demand charge for B shift

(1400-2200 hrs) operations, and 20% of demand charge for C shift (2200-0600 hrs)



operations. Industries Association of Young Entrepreneurs has also pointed out that with

current level of demand charges, many SSI units and HTP-II consumers have been paying as

much as 100% to 200% of energy charges as fixed charges per month.

Industries Association of Young Entrepreneurs has represented that the method for

determining connected load by adding up the rated load of all the installed equipments is

faulty, as most machines in engineering and small scale industries are provided with over

capacity motor and many machines are service machines sparingly used for 8-10 hrs in a

month. IDEA Cellular Limited has objected to MSEB Proposal for withdrawal of optional

LTMD Tariff for LD-2 (Commercial) category.

Garware Polyester Limited has requested to compensate proposed increase in fixed charges

by reduction in energy charges. MIDC Industrial Association has suggested implementing

concept of minimum charges instead of fixed charges such that minimum charge is recovered

only when energy consumption is on lower side.

Vidarbha Industries Association has brought out that profitability should be linked to

production and supply. Janata Dal (Secular) has pointed out that urban areas and rural areas

have been facing average load shedding of 3-4 hours and 6-8 hours per day, respectively.

Several consumers have requested the Commission to not levy demand charges atleast for the

period MSEB is not able to supply reliable electricity, citing basic commercial principles.

Several industrial consumers have pointed out that demand charge, based on 75 % of highest

billing demand for last 11 months, penalise consumers for next 11 months. While consumer

can be penalised for that particular month when it exceeds maximum billing demand, it is

unfair to penalise him for subsequent 10 months. Vidarbha Chamber of Commerce and

Industry has also requested to exempt payment of demand charges for the period of industry

shutdowns with a cap of 1 month in a year.

Several industrial consumers such as Finolex Industries Limited, Pudumjee Pulp and Paper

Mills Limited with Captive Power Plant have represented against levy of standby demand

charges of Rs 20/kVA by highlighting that the said charge is against the recent policy

initiative of promotion of Captive Power Plants. Levy of such additional charge is

unjustified as MSEB is not burdened with additional demand when the captive generating



unit is non-functional, so long as consumer’s Maximum Demand does not exceed Contract

Demand. Pudumjee Pulp has added that the MSEB is charging the additional Rs. 20/kVA on

the entire Billing Demand, even though the Billing Demand has never exceeded the Contract

Demand, which effectively means that no standby facility is being provided. As the Company

is already paying demand charges on the Billing Demand, the Company has stated that levy

of additional demand charges on Rs. 20/kVA on the entire billing demand, simply because the

Company’s captive generation facility is synchronized with the grid, is unfair. A similar

charge towards synchronisation is not envisaged under EA 2003 either. Maharashtra

Elektrosmelt Limited has requested to levy such additional demand charge of Rs 20/kVA only

on declared capacity of CPP and not on full monthly billing demand.

Tata Power Company (TPC) has requested that the MSEB Proposal of standby charge to TPC

for tariff of Rs. 600/kVA on a quantum of 550 MVA should not be firmed up while

considering revenue requirement since the matter is subjudice. They have also highlighted

that they are being charged Rs. 600/kVA while HTP-I consumers are being charged

335/kVA/month as demand charge.


On levy of fixed charges, the MSEB has submitted that, for supplying power to any

consumer, the MSEB is required to incur capital expenditure to put up the required

infrastructure and should, therefore, have a right to receive at least some assured revenue

from the investment. The MSEB has contended that it cannot reduce or remove the

infrastructure created for the consumer, if he is likely to consume less energy. Further MSEB

has been carrying out load shedding, if at all, to maintain the grid frequency within acceptable

levels and preventing damage to infrastructure and inconvenience to consumers. It is not the

MSEB’s infrastructure, which is incapable of supplying the power, rather there is inadequate

supply to match the consumer demand. Thus, the fixed/demand charges should not be linked

to the level of load shedding.

On the issue of LTMD tariff for Non-Domestic i.e L.D.2 category, MSEB has confirmed that

they have not proposed any change in existing scheme of allowing LTMD tariff to

Commercial connections.



With reference to levy of additional standby demand charge for captive plants synchronised

with the grid, MSEB has submitted that MSEB grid is required to provide short-term

assistance to the captive generator whenever CPP connected to grid is out for

repairs/overhaul. This casts an obligation on the MSEB to maintain additional reserve

capacity for all the CPPs in the State, which will be used when the need arises. Hence, the

captive generator is required to pay Rs. 20, as demand charges per month per kVA of the

installed capacity of the CPP and standby generating sets, to the MSEB, in addition to the

normal monthly contract demand charges if connected with MSEB system.

With reference to putting on hold the approval of standby charge to TPC, MSEB has

submitted that it has been providing the standby facility to TPC even at the cost of not

supplying to its own consumers whenever circumstances have demanded for it. For this

facility, according to the MSEB, the existing standby charges are justified.


The Commission has already elaborated the rationale for levy of demand charges in its

previous Tariff Orders. A major part of the costs of the MSEB, apart from the cost of fuel for

own generation and variable cost of power purchase, is fixed in nature and the ratio of fixed

to variable costs currently stands at 53:47. Though the consumer accesses electricity at any

time he desires, the MSEB’s infrastructure (physical infrastructure as well as employees,

administration, etc.) has to be permanently available, and related costs incurred irrespective of

the level of consumption by individual consumers, and these expenses thus comprises the

fixed costs of the MSEB.

The Commission has continued the process of increasing the recovery of fixed costs by levy

of fixed charges to consumers, to safeguard the MSEB from steep fluctuations in revenue

with varying consumption over time. The revised fixed/demand charges have been designed

to recover around 40% of MSEB’s fixed costs, as compared to the existing level of recovery

of around 35% of fixed costs. The balance fixed costs are recovered through energy charges.

Thus, for any disruption in supply, the MSEB is effectively losing out on the recovery of

fixed costs to that extent. If MSEB is not allowed to recover fixed cost for the period of

interruptions and low voltage period, it would further affect the financial viability of MSEB.

At the same time, the Commission does not intend that the consumers should suffer for the



poor quality of supply from the MSEB, and hereby directs the MSEB to take all possible

measures to maintain the voltages within the prescribed limits, and to limit the load shedding

hours to the minimum.

The Commission has reduced the cross-subsidy by reducing the effective tariff to industry

(for both LT and HT categories). As regards the suggestion of flattening of load curve

through restructuring of demand charges, the Commission has increased the differential in

Time of Day tariff between peak and of-peak hours, to further incentivize consumers to shift

to off-peak hours. Higher consumption during peak hours puts considerable investment

burden on MSEB to make available additional generation, transmission and distribution

facilities which remains unutilised during off-peak hours of operation. The Commission has

continued recovery of fixed charges through demand charges, as against the suggestion of

introducing minimum charges, as the Commission is of the view that recovery of fixed charge

through demand charge mechanism is more scientific as compared to minimum charge

mechanism. The detailed rationale for removal of minimum charges that has been given in the

first Tariff Order issued by the Commission in May 2000 still holds good.

As regards levy of demand charges to LT Industrial category, the Commission would like to

clarify that demand charges are levied only on half of the connected load to consumers opting

for HP based tariff. However, this category has also been offered Optional MD based tariff,

irrespective of connected load. As regards definition of connected load, the Commission

clarifies that the connected load shall mean “the sum of the rated capacities of all energy

consuming apparatus duly wired and connected to the power supply system, including

portable apparatus in the consumer’s premises, excluding standby devices connected through

change-over switches” or as prescribed under Supply Code under EA,2003. The connected

load shall not include the load of spare plug sockets, stand by or spare energy consuming

apparatus installed authorisedly through change over switch which cannot be operated

simultaneously, and load exclusively meant for fire fighting purposes. The equipment which

is under installation and not connected electrically, equipment stored in

warehouse/showrooms either as spare or for sale is not to be considered as “connected load”.



The Commission has considered the representations of several industrial consumers in the

context of charges applicable for stand by facility extended to the consumers by the MSEB.

The Commission hereby orders that the additional standby charges of Rs. 20 per kVA per

month will be applicable to HT industrial consumers, with captive generating units

synchronised with the MSEB grid, only on the extent of standby demand, and not the entire

contract demand as prevalent currently. Moreover, the Commission accepts the rationale put

forth by Pudumjee Pulp, that the standby charges should be levied only if there is actual

standby facility being extended by the MSEB. There is no merit in the MSEB’s practice of

levying additional demand charges of Rs. 20 /kVA on the entire billing demand, despite the

fact that the billing demand has never exceeded the contract demand. In such cases, the

MSEB is not really offering any standby facility, and is only supplying within the consumer’s

contract demand. Hence, standby charges will be levied on such consumers on the standby

component, only if the consumer’s demand exceeds the contracted demand.

The Commission retains the standby charge to TPC at the existing levels, as the matter is

subjudice.

2.3 Fuel and Other Costs Adjustment (FOCA)

2.3.1 Objections

Solapur Manufacturers Association has pointed out that the current mechanism of levy of

FOCA charges might lead to a discrepancy in recovery vis-à-vis actual excess cost incurred

by MSEB since it is being levied on future consumption of units for next quarter instead of

actual consumption in the past quarter. They have requested to modify FOCA recovery

mechanism to account for actual consumption of each consumer for respective period.

Shetkari Sahakari Sooth Girni Ltd has requested for intimation of FOCA charges in advance

to help them in their budget planning.

Pudumjee Pulp and Paper Mills Limited has sought a confirmation from MSEB that no

FOCA charge would be applicable immediately upon revision of MSEB tariff. Additionally,

they have suggested recovering FOCA charges only from subsidised categories, as a measure

to bridge the gap between average cost of supply and tariff charged.




The MSEB has said that the FOCA is being implemented as per the Formula approved by the

Commission from time to time. The projections for determining Annual Revenue

Requirement are based on the best estimates of the MSEB. If the actual expenses during the

period match with the projected figures, the FOCA would indeed turn out to be zero. The

FOCA formula itself has a crosscheck such that the MSEB does not over recover or under

recover any amount included for levy under FOCA.


After due consideration, the Commission has specified levy of FOCA charge on current

consumption of units and not on past actual consumed units. Matching of FOCA recovery

with the actual “Fuel and Other Cost Adjustment” is ensured for MSEB as a whole. Any over

or under recovery of FOCA is adjusted on rolling basis. Recovery of FOCA is not matched at

the consumer level to maintain simplicity of billing process.

The consumers will appreciate that since FOCA charge represents variation in actual costs

from the Commission’s estimates to determine Annual Revenue Requirement and Tariff, it

cannot be calculated in advance. As regards the suggestion of levying FOCA charge only on

subsidised consumer categories, the Commission is not inclined to adopt this approach, and

the FOCA will be applicable to all consumer categories. Reduction in cross-subsidy is being

undertaken through the tariffs, and it does not make economic sense to levy FOCA charges

only to subsidized categories. The MSEB incurs higher/lower costs for the entire generation

and purchase of energy which is supplied to all the consumers, and hence all the consumers

should be levied FOCA charges, as applicable.

2.4 Time of Day (ToD) Tariff

2.4.1 Objections

Industry has objected to MSEB Proposal of hiking tariff during peak hours, without giving

any corresponding rebate in the off-peak and night hours. Continuous process industry has

represented against increase in peak hour charges without corresponding reduction in off -

peak charges, as it would affect them substantially as they have no control over shifting of



load. Vindhya Paper Mills Limited has suggested that ToD tariff should not be made

applicable to continuous process industry.

Saf Yeast Company Private Limited has pointed out that incentive offered for nighttime

consumption is not commensurate with the sacrifice it has to make to modify its production

programme. Several industrial consumers, such as Maharashtra Elektrosmelt Limited and

Tata Motors, have suggested increasing the concession during off-peak hours. They have also

suggested making night concession rates applicable for full 24 hours on national holidays and

weekly off days.

The Railways have argued that they should be offered ToD tariff in line with HT consumers

as their consumption improves the load factor during off-peak hours.


Keeping in mind the significant increase in peak loads, MSEB has proposed to increase the

difference between peak period and off-peak period tariffs to further incentivise shift in

consumption. This would also help relieve the existing levels of load shedding that the MSEB

has to resort to during peak period for maintaining system frequency between 49.5 Hz to 50.5

Hz.

On the issue of ToD tariffs for Railways, MSEB has submitted that ToD tariff cannot be

levied for Railways as Railways are being levied a single part tariff without demand charges.

Further, the demand is for a very short period.


The Commission had introduced ‘Time of Day’ (ToD) tariffs for HT consumers in the first

Tariff Order, with a view to flatten the demand curve. The Commission had increased the

differential between tariff applicable for peak hour consumption and off-peak hour

consumption in the previous Tariff Order, on the basis of the encouraging response to the

implementation of the ToD tariffs in the first Order. This has resulted in further reduction in

the difference between the peak and off-peak loads, and hence the Commission has further

increased the differential between tariff applicable for peak hour consumption and off-peak

hour consumption by 20 paise per unit.



The Commission also directs MSEB to take steps in installing ToD meters for all consumers

with a connected load of over 20 kW by December 2004. Such ToD meters will be read

every billing cycle for all parameters and monthly-consolidated information shall be

submitted by MSEB to monitor the trend. However, billing will be done as per the option

exercised by the consumer.

The Commission has offered the Time of Day tariff to categories which are capable of

shifting their load. In case of Railways, since the schedule of trains is determined based on

need of mass public movement and not based on optimisation of electricity tariff, the

Commission has not offered ToD rate to the Railways, as the Railways will not be able to

shift their load. Moreover, the Commission has reduced the tariffs applicable to Railways

based on the principle of gradual reduction in cross-subsidy.

2.5 Bulk Discount

2.5.1 Objections

Chamber of Marathwada Industries and Agriculture has brought out that the reduction in bulk

discount to 50% of existing levels for HT consumers proposed by MSEB might result in

further fall in consumption of HT category at a higher rate. Industry Associations and

consumers have requested the Commission to continue with current bulk discount scheme.

Vidarbha Industries Association has also requested to apply such discounts on T&D loss

charges, FOCA charges, and demand charges in addition to the energy charges. They have

also suggested relaxing eligibility criteria of bulk discount from 10 lakh units to 5 lakh units

of consumption and applying graded structure with higher incentive for higher consumption.

Western Railway has also requested for bulk discount at par with other industrial consumers.

Ispat Industries has argued that if discounts are not provided to consumers who are in arrears,

it will only discourage them to make prompt payments, as they will feel that these arrears can

be adjusted against their security deposit with the MSEB. However, if the discounts are

offered, it will ensure that the consumer makes prompt payment for the current bill. They

have further suggested that billing process should be de-linked from the credit control

process, as both are separate issues.




Over past 3 years, MSEB has observed that the discounts given were of a substantial level,

which has defeated the primary objective of providing liquidity to the MSEB. Also, higher the

level of bulk discounts, higher is the level of tariff hike required for other categories as well.

However, keeping in mind that the bulk discounts in a way have been providing a lower

effective tariff for bigger consumers whose realisation was above the average cost of supply,

the MSEB has proposed that current discounts be halved.

MSEB has strongly opposed to de-linking billing process from the credit control process.


The ERC Act, 1998 as well as the recently enacted EA 2003 provide for differential tariff for

different consumers on the basis of the total consumption. The bulk discount is a rebate given

to consumers who have very high consumption, and need to be retained in the MSEB fold to

ensure adequate revenue to the MSEB. Hence, the Commission had introduced the bulk

discount in its first Tariff Order, which has been continued in this Order also.

The Commission has rejected MSEB’s Proposal of reduction in bulk discount and continued

bulk discount in its present form. The discount is offered only on the energy charges, and is

not offered on other elements of tariff as other tariff components have a specific purpose. The

Commission has decided to continue with the existing practice of linking the bulk discount

incentive to prompt payment, to improve the liquidity of the MSEB. It is the duty of the

consumers to pay their bills on time. Further, the bulk discount will be available only if the

consumer has no arrears with the MSEB, and payment is made within seven days from the

date of the bill or within 5 days of the receipt of the bill, whichever is later. However, this

incentive will be applicable to consumers where payment of arrears in instalments has been

granted by the MSEB, and the same being made as scheduled. The MSEB has to take a

commercial decision on the issue of how to determine the time frame for which the payments

should have been made as scheduled, in order to be eligible for the Bulk Discount.

The Commission clarifies that the Railways are bulk consumers and are eligible for the bulk

discounts, provided that separate metering points would continue to be treated as separate

consumers for the purposes of computing the bulk discount.



2.6 Power Factor (PF) Incentive/Penalty Charge

2.6.1 Objections

Prayas has expressed its agreement with MSEB Proposal of reduction in PF incentives as it

has achieved its purpose. However, several industrial consumers have objected to reduction in

PF incentive to 50% of existing levels, as such reduction would not reward customers

appropriately for investments made by them. Ispat Industries Limited has further pointed out

that increase in power factor has a positive impact on MSEB as it increases the billed units of

MSEB. Consumers have suggested adopting graded incentive structure to provide maximum

benefits for better utilisation of power. Vidarbha Industries Association has requested the

Commission to pass on the benefit of PF incentives to LT consumers including LTP-G

consumers.

Vidarbha Industries Association has pointed out that MSEB has been charging PF penalties

even to LTP-G consumers as per the Terms and Conditions of Supply even while the same

has not been provided in Commission’s Tariff Orders. Vidarbha Chamber of Small Scale

Industries has suggested introducing penalties for power factor on all categories of

consumers.


The MSEB has responded that presently average power factor for HTP-I and HTP-II is at

97% in any month. As the system power factor has improved over the past 3 years since the

first Tariff Order, the MSEB has proposed to reduce the extent of incentive/penalty so that

overall financial burden on the consumers through tariff is reduced.

MSEB has clarified that the PF penalty applied on LTP-G consumers having LTMD meters

but not opting for LTMD tariffs for the month of July 2003 was Rs. 2,82,731 and the total

number of such consumers who were levied the penalty was 164.


An appropriate tariff signal in the form of a Power Factor (PF) incentive can be a key driver

for optimum utilisation of resources and Energy Conservation. The Commission introduced

the PF incentive in May 2000 by way of a 1% rebate in energy tariff for every %



improvement in PF above 0.95. In the January 2002 Tariff Order, the incentive was further

enhanced for industrial users achieving a PF level of 0.99 and unity. The PF then improved

dramatically from 0.94 to 0.97 and has remained steady at that level ever since, indicating that

industries are making a determined effort to conserve energy by improving the efficiency of

their power usage. The Commission has estimated that this has resulted in a release of around

100 MW of generating capacity, and recurring savings of over 200 million units in

Transmission & Distribution losses alone.

The Commission has hence decided to continue the PF incentive, as consumers would have

envisaged continuity of incentive to offset the cost of installing capacitors to improve the PF.

In addition, the Commission has revised PF penalty to a graded structure to further incentivize

consumers to commit investments to maintain high power factor. The PF penalty would be at

2% for PF of 0.89, and further additional 1% for every percentage point decrease in PF. The

Commission also clarifies that the PF incentive and disincentives are applicable to LTP-G

consumer who opt for LTMD tariff.

2.7 Reliability Charge

2.7.1 Objections

Vidarbha Industries Association has represented against levy of reliability charge of 25 paise

per unit for consumers who get uninterrupted power supply in any billing cycle on the

grounds that MSEB should not get rewarded for performing its basic duty of providing

uninterrupted supply within a band of declared voltage and declared frequency, as per Rules

54 and 55 of Indian Electricity Rules, 1956. Instead, several consumers have requested for

levying a penalty on MSEB for its failure to supply reliable and quality power. Maharashtra

Chamber of Commerce and Industry has suggested levying a penalty charge on MSEB in

form of “Load Shedding - Discount”. Vindhya Paper Mills Limited has requested for

Tripping Rebate to compensate consumers drawing supply from express feeders for any trips.

Anjangaon Surji Grahak Panchayat has further requested to make MSEB responsible for

failure of consumer’s equipment attributable to voltage/frequency fluctuations.




MSEB has submitted that it is waiting for the Commission to finalise exact definition of

reliability, before levying the Reliability Charge. Further, the MSEB has clarified that it

makes all efforts to maintain the voltage at the specified levels. As regards frequency,

however, the MSEB has stated that it is a constituent of the Western Grid and the frequency

of the entire Western Grid is subject to fluctuations on account of the supply and demand

mismatches in the grid, and hence it has no control over the frequency, beyond a certain level.


The Commission had initiated the process of levying a ‘Reliability Charge’ to begin with, on

HTP-I and HTP-II consumers who have been provided with ToD meters, within urban

agglomerations in the State, on consumers receiving power supply through Express Feeders

and also those within MIDC areas. The MSEB was allowed to impose an additional charge of

25 paise per kWh to these consumers whenever it is able to supply uninterrupted power

supply. Collection of reliability charge would have resulted in additional revenue, which

could have been gainfully employed in strengthening/augmenting the system to improve the

quality of supply to consumers. However, the MSEB has not progressed very far in

implementing the Reliability Charge. The Commission’s detailed analysis and directions in

this context are discussed in the subsequent Section dealing with the levy of Reliability

Charges.

2.8 Others

2.8.1 Objections

Citizens Forum has requested for extension of concession on electricity duty beyond 7 years

for Marathwada region to avoid any adverse impact on industries.

Janata Dal (Secular) and several other consumers have objected to interest on delayed

payment at 12-18% as ruling deposit interest rate is of the order of 9%.




MSEB has clarified that it collects electricity duty on behalf of the State Government, which

fixes the rate and concessions.

MSEB has submitted that the interest on delayed payment is being levied as per the

Commission Order dated January 10, 2002.


As regards the extension of concession in electricity duty for the Marathwada region, the

matter is outside the purview of the Commission, and is a subject matter to be discussed with

the GoM.

As regards the interest on delayed payment, the Commission is of the opinion that the interest

rate on delayed payment should be higher than the ruling interest rate to discourage

consumers from delaying payment, as it is the duty of the consumers to pay the electricity

bills on time. The consumers should not treat the MSEB as a source of working capital

funding.

3. TARIFF SETTING PROCEDURE

3.1.1 Objections

N.N.Kale and Associates have requested the Commission to reject the MSEB’s Petition on

account of the delay in submission of the Proposal by approximately 8 months. Alternatively,

they have requested the Commission to not grant retrospective tariff revision and/or make

revised tariff valid upto March 31, 2005. Janata Dal (Secular) has also requested to not

implement the tariff revision with retrospective effect.

They have requested the Commission to not accept the Proposal on the ground that the

Proposal cannot be utilised for determining tariffs in the absence of certification by a Cost

Accountant. They have also objected to the appointment of a specific foreign management

accounting firm by MSEB despite the matter being under consideration of the Commission.

They have requested the Commission to issue guidelines for appointment of foreign

consultants.



Tata Power Company (TPC) has requested to defer revenue filing till the Commission frames

its Regulations under the EA 2003. They have pointed out that MSEB is a deemed State

Transmission Utility and a Licensee under EA 2003, and the MSEB’s tariff determination

would be governed by S.64 of EA 2003, which states that the Tariff Petition should be made

in the manner specified by the Regulations. TPC has stated that hence, the Proposal cannot be

considered until the Commission frames its Regulations.

Anjangaon Surji Grahak Panchayat has pointed out that MSEB has not adhered to the Commission’s Order of submitting the Proposal in Marathi in addition to English. Submission of Part III of the Proposal only on CD has affected people without access to computers. Electricity Consumers Association has suggested circulating the Proposal upto Subdivision Office for ensuring higher public participation in the tariff setting process. They have also requested for 45 to 60 days time to file objections. Association of Regular Payers of Electricity Bills has brought out that the cost of filing an objection is Rs. 440, which is unaffordable to most consumers.


On the issue of submitting the Proposal under EA 2003, MSEB has pointed out that under

Section 61 of EA 2003, the Commission will have to specify the terms and conditions for

tariff determination. While making this terms and conditions, the Commission would be

guided by CERC specified principles and methodologies and the National Electricity Policy

and Tariff Policy. Section 61 also specifies that until such Terms and Conditions are framed

by the Commission or the passage of one year after the appointed date (June 10, 2003),

whichever is earlier, the Terms and Conditions for determination of tariff under E(S) Act,

1948 and ERC Act, 1998 as they stood immediately before the appointed date, shall continue

to apply. Thus, the MSEB’s Proposal under Section 59 should be acceptable under law.

The MSEB has said that Section 59 of the erstwhile E(S) Act, 1948 states that the MSEB can

adjust its tariffs every year, such that it earns the mandated surplus on the Net Fixed Assets.

However, it is within the purview of the Commission to decide on the issue of Multi-Year

Tariffs.

On the issue of retrospective tariff revision, MSEB has submitted that it has neither requested

for tariffs to be charged retrospectively nor requested to fill the revenue gap within 4-6

months for which the Tariff Order would be applicable during FY 2003-04.



With regards to the cost audit, the MSEB has submitted that it has already appointed ICWAI

for studying the existing accounting and costing records at Nashik, Uran and Koyna power

stations and devising a system to facilitate compliance with the directives of the Commission.

The implementation of the scheme at above 3 stations was expected to start from Sep-03 and

at balance stations from Dec-03. With regards to the objection to the appointment of a certain

firm, MSEB has submitted that the process was carried out transparently through a

competitive bidding process and need not be questioned by the objector.

MSEB has submitted that it has filed the Proposal in English as per Conduct of Business

Regulations of the Commission. Further, it has publicised salient features of the Proposal in

Marathi.


As brought out in earlier Orders, the Commission is of the opinion that no tariff hike should

be allowed with a retrospective effect and has accordingly issued the Tariff Order effective

from December 1, 2003. The Commission is aware of the implications of not allowing the

tariff hike with retrospective effect on the financial viability of MSEB and accordingly

repeats its advice to MSEB to approach the Commission for a tariff hike, if needed, for the

ensuing year before commencement of December of the previous year.

As regards the certification of the Tariff Petition by a Cost Accountant, the Commission had

directed the MSEB to get the Tariff Petitions as well as the FOCA Applications certified by a

Cost Accountant. Though the MSEB has been submitting FOCA statements certified

accordingly, it has not done so for the Tariff Petition. However, the Commission is of the

opinion that this is not sufficient ground for rejecting the Petition, more so, considering the

MSEB’s financial health and urgent need for additional revenue. The Commission reiterates

its directive to MSEB to submit subsequent Tariff Petitions after certification by a Cost

Accountant. It should also be noted that once the MSEB’s successor entities are corporatized,

the Utilities will have to ensure certification by Cost Accountants.

As regards the formulation of Regulations by the Commission under the EA 2003, a

Committee has been formed, which has representation of the Utilities in the State as well as



the S.26 consumer representatives. Under the guidance of the Committee, the Regulations are

being drafted in line with the requirements of the EA 2003, for the Commission’s

consideration and guidance. It should be noted that the existing regulations that are not

inconsistent with the EA 2003 will continue to be in existence.

The Commission does not wish to specify any procedure for appointment of consultants by

the MSEB, as the MSEB is subject to regular audits by the concerned authorities and would

have to adhere to the guidelines in this regard that have been specified by the relevant

authorities.

4. TRANSMISSION AND DISTRIBUTION LOSSES

4.1.1 Objections

Janata Dal (Secular) has pointed out that though MSEB had agreed to reduce T&D loss by

7.5%, MSEB has actually achieved only 0.9% reduction. Hence, excess loss of 6.6%

translating to cost of Rs. 1,254 Crore should be disallowed. Navi Mumbai Action Committee

has highlighted that MSEB should have reduced losses by 15% by FY 2002-03, which could

have translated to savings of Rs 1,506 Crore obviating the need for tariff hike in this Proposal.

Vidarbha Chamber of Small Scale Industries has requested to restrict T&D losses to 21.87%

for tariff consideration and disallow power purchase expenses on account of excess T&D

losses.

Tata Motors has requested to set T&D loss reduction target of atleast 5% per annum.

Examples cited, from actual performance of other electricity utilities on loss reduction target

per year in percentage terms, are Andhra (3.4%), Haryana (4.44%), Karnataka (4%), and

Rajasthan (3.75%). MSEB’s effort of bringing down losses in Pune from 29% to 15% should

be institutionalised across Maharashtra. Several other consumers have also suggested higher

reduction target of 6% to 10% per annum.

Several consumers have objected to MSEB stand of focusing on metering benchmark for

accurate estimation of T&D losses rather than targeting reduction of T&D loss. Janata Dal

(Secular) has brought out that both should be independently pursued to achieve the end goal.

Prayas has highlighted that focus on T&D loss reduction cannot be deferred till MSEB



completes metering as it might take around 5 years to complete metering at the present rate.

In addition, issue of continuous reading of meter has to be separately addressed.

Estimation of agriculture consumption: Prayas has brought out that to improve the accuracy

of estimation of T&D losses, estimation of agriculture consumption is an important element.

To improve the estimates of agricultural consumption, Prayas has requested the Commission

to direct MSEB or outside agency to collect data on crops and water source in the sample

areas under 5,000 DTs, and to direct MSEB to ensure monthly readings of all Distribution

Transformers being sampled for agricultural estimates. They have further requested the

Commission to commission a census of agricultural pumps in the State.

Energy Audit: Prayas has suggested that the Commission should initiate an independent audit

of the EA system of MSEB for a sample of two urban and two non-urban circles so as to

familiarise itself with ground realities and validate MSEB data. Regulatory scrutiny should

also include things such as billing software.

Tata Motors has stated that MSEB is complacent on reduction of T&D losses. They have

highlighted that against estimated theft of Rs.2,868.85 Crore, MSEB has claimed recovery of

Rs. 11 Crore in FY 2001-02 and set a target of just Rs. 5.09 Crore for FY 2002-03 and Rs.

7.03 Crore for FY 2003-04. Navi Mumbai Action Committee has requested MSEB to

announce the improvements carried out through the vigilance machinery. Tata Motors has

further requested to direct MSEB to put before all the consumers the efforts/actions taken by

MSEB to arrest the theft of electricity under the following heads:

a. Number of FIRs filed. b. Number of Panchnamas. c. Number of people arrested. d. Number of cases filed in the Court of Law. e. Organisational structure created by MSEB to drive the movement to arrest the theft. f. Amounts recovered.

Solapur Manufacturers Association has highlighted several points, which indicate inadequacy

of efforts on part of MSEB to control theft and reduce line losses:

Faulty meters for RCI consumers are still almost 11% of total consumers. Average billing for 22.36% of consumers is still being continued.



Many meters in sub-stations are not working, or having errors. The accuracy level of meters and C.T.P.T.s are not as specified for consumers.

Several suggestions have been offered by various consumers to control technical portion of T&D losses:

Utilise portable truck mounted unit fitted with instruments to spot T&D problems. Involve private organisations for metering. Use of Aerial Bunched Cable could reduce theft by tapping. Use of small step down transformer with supply from secondary side reduces chances by

tapping/hooking. Use of ACSR/AS conductor with lower electrical resistance. Meter each distribution transformer (total 1.84 Lakh) and month wise reporting of energy

billed and energy measured at each transformer. Use of ‘Songir’ pattern, developed by a MSEB employee, across the State.

Akhil Bhartiya Grahak Panchayat has suggested charging 50% of T&D loss to concerned

employees instead of consumers. MSEB Workers Federation has brought out the constraints

in curbing commercial portion of T&D losses in terms of not getting proper co-operation

from Government authorities, police protection and help to implement the measures.

Several consumers have stated that MSEB should identify authorities and responsibilities for

implementation of Jan Mitra scheme, incentives/disincentives for the reduction/increase in the

distribution losses of the DTCs, and the reduction in the distribution losses achieved.

During the public hearings, several objectors stated that the level of corruption within MSEB

is very high, and that MSEB should take strict action against such employees, to facilitate

reduction in T&D losses, and reduce the extent of tariff revision required.


MSEB has taken a stand that the target specified by the Commission is not achievable within

a short time frame, and that T & D loss can be better estimated and controlled through

increase in metering and systems improvement. The MSEB has submitted that it has

proposed improvement in the proportion of the metered consumption (which is measurable)

as a benchmark in lieu of reduction in T & D losses, which are only estimates and guesswork.

In this regard, the MSEB has set for itself a target for increasing metered consumption from

44 % in FY 2001-02 to 47 % in FY 2003-04 as a percentage of net energy input. The MSEB



has further submitted that the high level of T&D losses can be attributed to the following

reasons:

Overloading of T&D lines due to higher reactive power flow over the lines Overloading of power and distribution transformers Inadequate sub-transmission and distribution network High HT to LT ratio which is 1:2.26 as against the maximum acceptable ratio of 1:1

On the issue of focusing on reduction of T&D losses as the performance parameter instead of

metered consumption, MSEB has submitted that exact level of losses in a system can be

measured only when 100% metering is achieved, when all the meters are accurate, all the

readings are taken accurately and at the same instant. MSEB has submitted that unless T&D

losses are accurately established, a reduction trajectory cannot be prescribed for the MSEB. In

Maharashtra, almost 18 lakh consumers (agricultural) are unmetered which causes additional

uncertainty in the determination of T&D losses. The MSEB has added that it is currently

undertaking efforts to achieve 100% meterisation and improvement in metering and billing

efficiency through a variety of measures detailed in Section 3 of the Proposal.

The MSEB has submitted that the agricultural consumption estimate has been based on a

sample of 4,668 DTC meters whose readings are being taken on a monthly basis. The MSEB

has further submitted that its estimates of agricultural consumption are based on the ‘official’

connected load of the pumps. However, numerous instances have been found where the actual

load is higher than that officially registered with the MSEB. The MSEB has added that it is

not physically possible to police such a vast distribution network, in order to prevent illegal

tapping by certain consumers.

With reference to the issue of not utilising the Songir pattern, MSEB has submitted that the

practice is only useful in order to check that actual load by consumer does not exceed the

sanctioned load, and does not directly help in controlling the T&D losses and is practically

difficult to implement all over the State. Further, the MCB is normally being provided along

with the meter. The MSEB has submitted that it has initiated ‘Jan Mitra’ concept amongst its employees. On

implementation of this concept, the Lineman/Asst. Lineman/Helper would become the local

guardian for the area under their control with respect to DTCs and consumers. The concept



would help to drive the performance of the MSEB right from the grass root level. The Jan

Mitra would be responsible and accountable for the metering, billing and collection

performance for the entire Subdivision.


The Commission is deeply concerned with the continuing high level of T&D losses in the

MSEB system, and has taken a serious view of the MSEB’s non-compliance of the

Commission’s directive to reduce the T&D loss. In order to determine the level of allowable

T&D losses, in today’s field condition, one has to assess the total T&D losses within the best

possible accuracy level instead of envisaging an ideal situation. Even if the Commission were

to take a strict view that only the technical losses should be allowed and all the commercial

losses should be to the MSEB’s account, the problem remains with the assessment of the

technical losses. Though the MSEB has submitted in the past that the technical losses could

be in the range of around 21%, this number has to be verified through load flow studies. In

the absence of any certainty on this issue, the Commission is constrained to accept the target

loss level at 26.87% for the purposes of this Order.

If the cost of all the excess losses were disallowed, then it is most likely that the MSEB will

be unable to meet its daily requirements and will be unable to supply power to its consumers.

This is not in the consumers’ interest, and till a viable alternative emerges, the MSEB has to

continue to supply electricity to the consumers in the State. The Commission is of the opinion

that a pragmatic decision has to be taken in the best long-term interest of the electricity

consumers in the State as well as the MSEB. The mechanism for addressing the cost of excess

losses has been explained in detail while discussing Regulatory Liability Charge in the

section on Tariff Design.

The Commission does not find merit with MSEB’s suggestion on focusing to the extent of

metering rather than the T&D losses, since it is observed that even in fully metered area (such

as Pune, Nagpur) or category (such as residential, industrial and commercial) there are

substantial billing errors indicating deficiency of management. Hence, the Commission

directs MSEB to achieve the T&D loss reduction target as well as the metering targets.



The Commission is of the opinion that energy accounting by itself has no meaning, unless the

MSEB audits and analyses the energy accounting data and holds the concerned officers

responsible for the excess losses in that zone/circle. The Commission is extremely concerned

about the allegations of corruption within the MSEB, and directs the MSEB to verify these

claims and initiate strict disciplinary action against such employees found guilty of indulging

in corrupt practices. The Commission has noted that there are several instances where the

meters installed are not being read on a monthly basis. The Commission reiterates that the

MSEB should hold the concerned employees responsible for the T&D losses in the respective

circles/zones, and consider departmental proceedings against these employees after following

due disciplinary procedure. The monitoring of the circle-level losses must continue and the

MSEB should continue to submit the circle-level energy accounting data on a monthly basis,

and circles should operate on ‘profit centre’ basis.

The Commission further directs the MSEB to devise and widely publicise efforts

undertaken/actions taken by MSEB to control theft of electricity, on a quarterly basis. The

Commission also directs MSEB to undertake a cost-benefit analysis of various suggestions

for controlling technical portion of T&D losses and to submit to the Commission cost-benefit

analysis and investment proposal.

5. REVENUE/REVENUE ARREARS

5.1.1 Objections

BILLING

Consumers have complained that MSEB has been avoiding meter reading by charging

consumers on estimated consumption basis under the pretext of faulty meter. To control such

practices, Janata Dal (Secular) has suggested that MSEB should not be allowed to raise a

second consecutive bill on the basis of estimated consumption wherever a faulty meter is

reported. Meter replacement should be made mandatory before raising second bill. In

addition, meter reading/checking should be carried out in presence of consumer. Mumbai

Grahak Panchayat (MGP) has suggested that practice of average bill/estimate bill should be

gradually discontinued by ensuring monthly billing. Prayas has requested that MSEB should

be directed to follow the Commission’s Order regarding discontinuation of average billing.



Prayas has observed that B-80 billing1 seems to be very large in certain circles such as

Pune(U) of around Rs 80 Crore. Prayas has requested MSEB to clarify the stage at which

these adjustments reflect in actual billing. Consumers have suggested delegating B-80

adjustment approval at the Divisional level from the current Zonal level. Prayas has requested

MSEB to specify reasons that lead to credit billing for consumers and amount of credit bill for

all LT consumers in each zone.

Prayas has observed that the temporary customers such as construction meters have been

highly problematic and responsible for a large revenue loss. MSEB should immediately

explore ways of giving pre-paid meters to such customers. MSEB should provide a

connection to the applicant of temporary connection only for the period for which other

associated permissions (such as Corporation’s permission for construction) are available.

Tata Motors and several Consumer Associations have suggested several improvements in

billing/metering. Some of the suggestions are spot billing, offer of prepaid meters, bill using

digital camera, employ automatic meter reading system, map consumers to a

meter/pole/transformer/block/taluka/district to improve analysis, use of check meters for HT

consumers, use of meter with MRI prints for HT consumers and use of hi-precision, hi-tech

electronic meters for all LT consumers.

Pimpri Chinchwad Small Industries Association has objected to the attitude and conduct of

the Flying Squad. It has requested that an engineer having knowledge of theft detection

should accompany such Flying Squads.

REVENUE GENERATION

Mumbai Grahak Panchayat has suggested that MSEB should look at alternative sources of

revenue such as, utilisation of existing sites for advertisement; offering consultancy services

to third party for generation, transmission and distribution and reallocation of offices,

establishment for revenue, to improve viability of its operations.

1 B-80 billing refers to the practice of adjusting the consumers’ bills based on representation by the consumers. As the revenue has already

been booked based on the original bill sent to the consumers, the MSEB records the change in the consumer’s bills in a Form known as B-

80. At the end of the year, the amount of adjustment under B-80 is adjusted against the revenue billed to correctly record the actual amount

billed by the MSEB.



REVENUE ARREARS

Vidarbha Industries Association has highlighted that MSEB has not complied with directive

of reducing receivables to 5 months of sales. Revenue arrears have actually been increasing

over past 3 years. It has increased from Rs. 5,907 Crore in FY 2000-01 to Rs. 7,113 Crore in

FY 2001-02 and Rs. 8,765 Crore in FY 2002-03. Mumbai Grahak Panchayat has further

highlighted that revenue arrears of top 20 defaulters have increased to Rs. 341 Crore in FY

2002-03 from Rs. 326 Crore in FY 2001-02. These arrears are outstanding for months ranging

from 2 to 175. Moreover, Prayas has pointed through ‘aging analysis’ that close to 40%

arrears (about Rs. 3,300 Crore) are more than 3 years old. This has been interpreted as a lack

of commitment to collect receivables, improper and inadequate billing and failure to curb

theft of electricity. The objectors have stated that this would lead to a strain on the finances of

the MSEB and would punish paying consumers.

Prayas has highlighted that the arrears of Rs. 865 Crore with government and public bodies

are high and a problematic issue. As it is being argued that they cannot be disconnected, being

public services, the Commission should direct Government of Maharashtra to pay the

electricity bills of local bodies directly to MSEB rather than giving money to these bodies to

pay to MSEB. Nashik Industries and Manufacturers Association has also highlighted the need

for recovering revenue arrears from bulk consumers like Mula Pravara, water supply

schemes, Municipal Corporations, Grampanchayat. Prayas has also highlighted that the

GoM’s policies and actions have affected recovery from agriculture and power loom

consumers and arrears from these categories have reached around Rs.3,300 Crore.

Tarapur Industrial Manufacturers’ Association has objected to practice of prompt

disconnection followed by MSEB for collection of revenue arrears while late payment is

attributable to MSEB for reasons such as a wrong bill, a cumulative bill for 4-5 months at one

go, a misplaced bill by MSEB, bill not reaching in time, etc. They have suggested that MSEB

should not disconnect the power for atleast 48 hours as customer is anyway paying DPS for a

month’s period. Janata Dal (Secular) has pointed out that as MSEB has security deposit

equivalent of 1 bill’s amount, they should disconnect only after outstanding exceeds 2 bills’

amount. Anjangaon Surji Grahak Panchayat has also suggested that atleast 15 days notice

should be given prior to disconnection.




With reference to various issues related to metering/billing, MSEB has submitted that the

practice of average billing has been carried out under certain conditions such as faulty meter,

locked premises, meter not at site, meter changed, etc. Presently, average billing on account

of faulty meters is around 10.98%. The MSEB has also submitted that they have been

undertaking all measures to reduce the level of average billing through meter replacement

drive. The MSEB has further stated that the T&D losses have actually reduced in areas where

such drives have been completed with full cooperation of the consumers.

With reference to problems of billing, MSEB has submitted that it is in the process of

decentralising printing of bills by creating facilities at billing unit level. This would reduce

burden at each centre and help early correction of abnormal bills leading to reduction in

consumer complaints. Along with energy audit, this would greatly facilitate introduction of

accountability at the billing unit level. This system is being introduced in phased manner and

has been implemented at 50 locations at sub-division level. The remaining locations are

targeted to be covered during FY 2003-04 in a phased manner.

On B-80 adjustments, MSEB has submitted that it has been undertaking conscious efforts to

ensure that the adjustment practice does not give rise to inefficient practices. The level of B-

80 adjustments has been brought down over the years.

With regards to credit billing, the MSEB has clarified that credit billing has been undertaken

in following circumstances:

The consumer may have been billed a higher amount which is paid by him fearing disconnection but subsequently the consumption and billing has been corrected, The consumer have paid an advance amount for a period longer than the billing cycle, The consumer has been charged higher amount on account of practice of rounding off to the nearest ten rupees.

On the objection that flying squads harass the people, MSEB has submitted that the flying

squads have been established to check consumers’ load and also detect cases of energy

pilferage. The MSEB has added that it is not the intention of the MSEB to cause

inconvenience the consumers through such checks.



MSEB has objected to two months notice for disconnection stating that it would lead to

increase in its liquidity problems. On the issue of 15 days notice period for payment of bills,

MSEB has submitted that current practice is as per law. Even EA 2003 prescribes a period of

15 days before effecting disconnection.

The MSEB has submitted that it is taking all effective steps to improve its arrears position in

exercise of the powers conferred to it under section 24 of the erstwhile Indian Electricity Act,

1910. The growth in arrears with respect to those categories where MSEB has a free hand in

effecting disconnection has actually been negative in recent times. The MSEB has been able

to exercise control over the arrears from Domestic, Commercial and Industrial consumers

through disconnections. In other categories, there are inherent constraints in effecting

disconnections such as social reasons and law and order problems. Additionally, a MIS

program has been initiated for effective, efficient reporting and working. Energy Audit

Systems have been installed in 400 kV to 66 kV, express feeders and MIDC feeders. MSEB

has added that it has initiated disciplinary action against erring employees. MSEB has also

undertaken an aggressive metering program.


The Commission had given a directive to MSEB to discontinue the practice of billing

consumers on the basis of average billing. The Commission hereby emphasises that the

MSEB is required to comply with the directives expeditiously, both in letter and in spirit.

MSEB should also try and incorporate the suggestions on improving billing practice after

undertaking the cost benefit analysis.

As regards the suggestions regarding the qualifications of the flying squad, the Commission

advises MSEB to define the qualification criteria for the team, and impart the necessary

training to the team to increase the effectiveness of the flying squad.

The Commission has taken serious note of the increase in receivables. The Commission

reiterates its directive to disconnect all defaulting consumers who are having high

receivables. At the same time, the Commission also appreciates that disconnection will be

difficult in case of Mula Pravara, Street Lighting and PWW consumers. The GoM should

support the MSEB by directing these Public Utilities to pay their dues on time. To this



effect, the Commission had recommended in the previous Order that the GoM should create a

separate budgetary provision for payment of electricity dues, at the time of determining the

budget for these local bodies, as against the existing practice of clubbing the electricity

payments under ‘Miscellaneous Expenses’. Subsequently, the GoM has already issued such

Orders. However, the Order is not being implemented fully, resulting in mounting arrears

from these consumers. The Commission directs that the Order should be implemented in

letter and in spirit, to ensure that the MSEB’s receivables are brought under control.

6. QUALITY OF SUPPLY/SERVICE

6.1.1 Objections

LOAD SHEDDING

Prayas has questioned the reliability of quantum of load shedding claim by MSEB. MSEB has

claimed that out of total load shedding of 7,836 MU, only 34% of it can be considered as

actual loss. Analysing this, Prayas has pointed that with claimed shift of load, off-peak hour

load should have increased by 2,500 MW. However, this does not tally with actual increase

observed in off-peak load. Prayas has highlighted the need for installation of electronic data

storage meters for all 11 kV feeders at estimated cost of Rs. 40 Crore to remove inaccuracy in

Energy Audit data and load shedding.

Some of the consumers have requested for equitable load shedding across all areas of the

State. Additionally, they have requested the Commission to make MSEB accountable for load

shedding and make it pay compensation to the consumers.

QUALITY OF SUPPLY

Industry has put forth several problems related to interruptions, voltage and frequency

fluctuations and has requested the Commission to direct MSEB to improve power reliability

and consistency to achieve benchmark figures. Due to the poor quality of supply and low

voltage, the meters tend to record a higher consumption as compared to the actual usage.

Finolex Industries Limited has pointed that it experienced few hundreds of power

failures/voltage dips over last 10 years on 220 kV supply, which resulted in tripping of their

plant. Despite having 2 circuits of 220 kV feeders, it experienced 10 shutdowns of long



duration, simultaneously on both circuits in second quarter of 2003. They have requested for a

small quantum of power, necessary for safeguarding critical equipment, during cascade

tripping. Several agricultural consumers have highlighted that the intermittent supply has

affected them by making them redraw water multiple times, as water reached only partial

distance at the time of interruptions.

Western Railway has requested the Commission to direct MSEB to compensate Railway for

losses incurred by Railway due to requirement of regulating trains during the period of

interruptions.

Industry has pinpointed maintenance-related problems causing interruptions and has

requested the Commission to direct MSEB to improve their maintenance. Tarapur Industrial

Manufacturers’ Association mentioned that the increase in power interruptions in Tarapur

region is attributable to partial execution of planned maintenance activities. Tata Motors has

highlighted that MSEB has not used facility of APDRP as effectively as that of many other

SEBs. Mumbai Grahak Panchayat has highlighted that MSEB has been spending 2% of

revenue for operation and maintenance of power system as compared to 5% by TPC, 11% by

BSES, 11% by BEST. Unless and until MSEB improves O&M expense on distribution,

availability would not improve. Prayas has pointed that the Commission should seek

compliance from MSEB that it actually spends allowed O&M costs for the purpose of

maintenance.

Finolex Industries and some other Associations have made several technical suggestions to

improve reliability such as,

Carry out hot line washing (instead of dry wiping) of insulators 4-5 times during January to May period to protect them against high humidity and salty weather condition.

Consider replacement of present disc type insulators alongwith their hardware by long-rod type insulators to have a long creepage length

Replace corroded GI earthing conductors Make adequate spares available to carry out maintenance/replacement of old overhead

lines, wires, jumpers etc. Repair 35,000 failed transformers which are currently lying in un-repaired condition to

reduce overloading of grid system. Use 3 phase scheme in rural areas instead of single phase scheme to reduce failure rate.



QUALITY OF SERVICE

Several consumer associations have requested the Commission to direct MSEB to issue a new

connection within stipulated time after receipt of payment based on ‘demand estimate’, and

also to simplify the procedure of issuing new connections. Consumers have complained that

for obtaining a new connection for a building, they end up submitting the same papers to 4

level of offices viz. Circle office, Division office, Subdivision office and Section office.

Nashik Industries and Manufacturers Association has observed that MSEB’s inefficiency in

quick processing of HT and LT applications could be a reason for the lower growth rate in

sales. Mumbai Grahak Panchayat has requested to introduce a Tatkal scheme for meeting

requirement of immediate connection albeit with an additional charge, say, 25% more.

Consumers have complained that MSEB does not have a proper system to attend to customer

complaints, and the MSEB sometimes takes 6 to 10 hours for restoration of power even in

case of line faults.

Consumers have also pointed that MSEB many a times did not purchase and install certain

equipment, which were mandatory to use. While issuing a connection, if consumer is required

to employ his own equipment, the same should be adjusted in his bill.


MSEB has accepted that it has been resorting to load shedding whenever frequency deviations

are beyond a limit to ensure the security and avoid collapse of entire grid. With reference to

load shedding and loss of sales data, the MSEB has clarified that any shifting of load can

happen in off-peak hours in addition to night hours. Further, almost 70-80% of the 11 kV

feeders have been installed with electronic meters and the rest would be metered in due

course.

On frequency and voltage fluctuations, the MSEB has submitted that, presently, there is a gap

between the demand and online capacity in the system. The demand is skewed with high

peaks in the daily pattern leading to frequency deviations. The MSEB has further submitted

that it is working in the integrated grid of Western region at EHV level and the frequency

profile of the system is not entirely under its control. However, the MSEB has added that it

continuously makes efforts to have proper coordination with the grid partners. The MSEB has



put forth that the low voltage problems arise in situations where power needs to be supplied to

remote locations and distribution transformers are overloaded in those locations. It has added

that addressing these problems would require significant capital expenditure.

The MSEB has listed down the reasons for less on-line capacity as under:

Restrictions on the use of water in Koyna Hydro stations Less supply of gas to Uran Gas Turbine Power Generating Station Poor coal quality Overloading of Transmission and Distribution Network and transformers Pre-arranged shut downs for routine maintenance More reactive loading on the T&D system

On reliability of supply, the MSEB has submitted that it has been putting in sincere efforts to

provide reliable power. However, interruptions are unavoidable due to inherent technical

problems such as natural breakdowns, maintenance works, local transmission/distribution

capacity constraints, forced load shedding to match supply with demand, etc. Further, its

transmission and distribution network is mostly overhead and is, therefore exposed to natural

as well as human interference resulting in breakdowns. The MSEB has further submitted that

new projects are being carried out for increasing capacity in generation and T&D network

augmentation.

On the issue of disruption in supply leading to burning of pumps, MSEB has submitted that

all the electrical components have to be designed for voltage and frequency fluctuations as

per IS specifications. The grid frequency has been within the permissible levels. Therefore,

the electrical component should not cause production loss unless they do not have the

requisite tolerance levels. Therefore, there is no question of the MSEB giving any

compensation to the consumers.

To address the quality problems, MSEB has submitted that it is carrying out new projects

such as, R&M and augmentation schemes, execution of Parli and Paras TPS extension, for

increasing generation capacity to bridge the demand-supply gap. It has also initiated projects

for augmenting T&D network, e.g. construction of new EHV sub stations, increase in

transformation capacity, additional EHV capacitors, APDP and APDRP programs in six

districts each, district integration programs, etc.



With reference to inadequacy of expenditure on R&M, the MSEB has pleaded that the

Commission should not set unrealistic targets. To take care of the disallowed expenses in

Tariff Orders, the MSEB has been cutting down on R&M works and borrowing more funds

than planned, for financing its expenses not included in the Revenue Requirement. Such

practices, if continued, would have long-term implications for the efficiency of the MSEB’s

infrastructure and its ability to render good quality service to its consumers.

With reference to the specific problems of reliable supply pointed out by Finolex Industries

Limited, MSEB has submitted that the failures were attributable to stormy weather, heavy

rains and the presence of red soil. The interruptions were due to bad weather and not bad

maintenance. The MSEB has however taken up the matter and has decided to replace the

insulators on this line. This would need the active cooperation of the objector too.


The Commission has taken up the matter of load shedding separately with MSEB. The

Commission has discussed this aspect in detail in the Section on Generation and Power

purchase expenses.

The Commission has taken a serious note of the complaints against the MSEB’s quality of

supply. The Commission would like to stress upon the MSEB that the consumers’

expectations of reliable supply is justified in the context of demanding year-on-year increase

in tariffs. The Commission has also approved O&M expenditure equivalent to 3% of the

opening level of Gross Fixed Assets and directs the MSEB to utilise this budget for the

approved purpose so as to meet consumers’ expectations.

Issues related to grant of connection shall be taken up alongwith the approval of the “Terms

and Conditions of Supply”, and the revised Regulations on “Supply Code” being drafted in

line with the provisions of the EA 2003. Under the EA 2003, the Commission has to approve

the Supply Code and the regulations thereof. Also, Regulations for redressal of consumer

complaints and grievances have been issued in December 2003, viz. Consumer Grievance

Redressal Forum and Ombudsman Regulations, 2003, under S.181 of the EA 2003.



7. GENERATION AND POWER PURCHASE

7.1.1 Objections

Rashtriya Grahak Sanghatana has pointed out that the increase in generation expenses of Rs.

151 Crore and power purchase expenses of Rs. 726 Crore amounting to total Rs. 877 Crore

should not be considered as additional expense as it would also earn additional revenue. Tata

Motors has questioned the steep rise of 11% in generation costs. In their assessment, cost of

generation should be around Rs. 3,955 Crore as against Rs. 4,143 Crore projected by MSEB

based on generation cost of Rs. 0.86/unit in line with earlier years.

GENERATION:

Several consumers have objected to low capacity utilisation of Uran Generating Plant, despite

it being the lowest variable cost generator available with the MSEB. N.N.Kale and Associates

has highlighted that Uran plant is under utilised with PLF of 55.29% despite incremental

capital cost for use of alternate fuel being only Rs. 20 Crore.

Maharashtra Rajya Consumers Association and others have suggested various measures for

improvement of availability and overall reduction of generation cost. Some examples are

optimum utilisation of available generation capacity, import of better quality coal (estimated

additional availability of 400 MW), setting up of coal washaries, utilisation of balance Uran

capacity (400 MW), improvement of power factor in rural area (estimated additional

availability of 1,000 MW) and use of “circuit breaker” as suggested under “Songir” pattern.

Ispat Industries Limited has pointed that an increase in the plant load factor of the generating

station to a reasonable level of 80% would imply an additional availability of 319.7 Mn units

and a resultant saving of Rs. 71 Crore in the power purchase cost.

N.N.Kale and Associates has pointed that Honourable High Court has upheld transit loss of

coal as a component of generation cost and requested the Commission to ascertain actual

transit loss after accounting for liability of coal suppliers for supplying lower quality coal.



POWER PURCHASE:

N.N.Kale and Associates has brought out that MSEB needs to depend on Central Sector share

to the extent of 35.07%. They have requested the Government of Maharashtra to publish

long-term plan for achieving no load shedding and self-sufficiency.

Tata Motors has brought out that the cost of power purchase should come down to Rs. 3,247

Crore (@Rs 1.81/unit) as against Rs. 3,494 Crore projected by MSEB as DPC is not in

operation. It also pointed that the MSEB has included income tax of Rs. 140 Crore payable to

NTPC and of Rs. 11 Crore payable to NPC in the purchase cost even though the Commission

in its Order dated July 31, 2001 disapproved it.

Nashik Industries and Manufacturers’ Association has pointed that the rate of ad-hoc power

purchase of 480 MUs from sugar mills/windmills at Rs. 3.17/unit is high as compared to PTC

rate of Rs. 2.29/unit which has resulted in a burden of Rs. 43.6 Crore to consumer. As this

burden has been arising out of the Government Policy, the burden should be recovered from

State Government as a subsidy instead of passing on to the consumers.

Tata Motors has suggested that MSEB should pay a rebate of minimum Rs 2/unit for units

generated during peak period and abolish synchronisation charge of Rs 20/kVA/month for HT

industrial CPP for encouraging consumers to run their DG sets during peak hours.

MERIT ORDER DESPATCH:

N.N.Kale and Associates has requested comparison of merit order despatch approach

followed by Maharashtra with that of other States in India to ensure adoption of best suitable

approach.

UNSCHEDULED INTERCHANGE (UI) CHARGES

Balaji Electro Smelters Limited has pointed that MSEB has paid UI charges of Rs. 150

Crore for the period Dec ’02 to Mar ’03 and of Rs. 18 Crore for the period Apr ’03 to May

’03. They have sought detailed justification for month-wise UI charges. Balaji Electro

Smelters Limited has requested to clarify whether UI charge is levied as a penalty or as a



part of tariff as claimed by MSEB. If UI charge is a penalty on MSEB, the same should not be

passed on as a component of NTPC tariff.

OBJECTIONS OF TATA POWER COMPANY (TPC)

MSEB is currently charging Rs. 600 per kVA per month for a standby support to TPC of 550

MVA. TPC has submitted to the Commission that it should not firm up quantum and rate of

standby charge to TPC till such time the matter has been conclusively resolved by

Honourable High Court of Bombay. TPC has highlighted that though the Commission has

approved a rate of purchase of Rs. 2.65/kwh by MSEB from TPC with effect from September

15, 2001, whereas MSEB’s Proposal has built up purchase cost at Rs. 2.5/kWh. Further TPC

submitted for the Commission’s consideration that the rate of Rs. 2.5/kWh should be linked to

fuel price of Rs. 9,500/Ton. TPC has requested the Commission to equate the rate payable by

MSEB to TPC for purchase of power with the rate payable by TPC to MSEB since such sale

amounts to inter utility exchange. It also highlighted that the MSEB Proposal did not envisage

any revenue income from such sales to TPC. Alternatively, it suggested that the energy rate

payable by TPC to MSEB should be fixed based on weighted average fuel cost of MSEB per

unit plus extra high tension transmission losses.

TPC has also requested that the generation of 32 MUs from Supa wind power plant should be

accounted in non-conventional purchase indicated by MSEB without deduction of wheeling

charges of 12% in accordance with the Wind Power Policy in force.


The MSEB has submitted that it has achieved the highest ever thermal generation in FY 2000-

01 with the PLF improving from 72.78% in FY 2000-01 to 74.34% and 71.94% in FY 2001-

02 and FY 2002-03, respectively. However, because of lower hydro generation capacity and

load pattern, thermal capacity was required to be backed down during low load period and,

hence, higher PLF could not be achieved. It has further submitted that all its thermal power

plants have qualified for cash awards from the Government of India for FY 2000-01 for

reduced specific oil consumption.

With reference to the objection that generation at Uran has not been increased, the MSEB

has submitted that out of 912 MW of capacity, only about 450 MW is being utilized. A



significant amount of capacity of Uran Plant is lying idle because of lack of supply of gas. 4

units of 120 MW each in association with 240 MW of WHR have been commissioned in

recent years and the plant availability has been greater than 90%. Barring, 1 unit of 60 MW,

all other units are available. If the supply of gas is increased, it can lead to higher generation

at Uran Plant. This would help the MSEB in addressing the problems of load shedding to

some extent. The MSEB is taking up the matter of additional gas supply on a continuous basis

with Ministry of Power and Ministry of Petroleum and Natural Gas.

With reference to use of imported coal and option of coal washery, the MSEB has submitted

that it has recently procured imported coal for usage at Koradi and Nashik thermal power

plant. Further, a proposal for washed coal from SECL is under consideration.

MSEB has responded that Income Tax to NTPC/NPC has been paid as per CERC Tariff

Orders and the same has been passed on to MSEB’s consumers.

On the cost of power purchase from TPC, MSEB has submitted that the purchase rate has

been assumed based on average rate of power purchase in FY 2002-03. Any changes in per

unit cost of power purchase from TPC would only increase the revenue gap for the MSEB.

Further, this rate should be compared with rates from alternate sources such as PTC before

considering their proposal. With reference to proposed tariff for sale of energy to TPC, the

MSEB has strongly opposed such a suggestion. With reference to suggestion that generation

at Supa wind farm should be accounted as a power purchase by MSEB without deduction of

wheeling charges, MSEB has submitted that the existing treatment of the windmill is as per

the existing Policy and cannot be relaxed in a particular case.


While computing the generation and power purchase cost, the Commission has given due

weightage to the objections received. The MSEB had considered a 5% increase in the fuel

costs and power purchase costs over the actual costs incurred in FY 2002-03, while

projecting the expenditure for FY 2003-04. The Commission has approved the total

generation and power purchase costs for FY 2003-04 considering the quantum of actual

generation and power purchase for the period of April to July 2003 and estimating the

generation and power purchase costs from August 2003 to March 2004 based on a



simulation of merit order dispatch and actual average generation and power purchase costs for

the period of April to July 2003, subject to heat rate norms and transit loss component. As the

actual costs have been considered, the Commission has not considered any escalation in the

fuel prices and power purchase costs for the balance period. Further, if there is any change in

the fuel prices and power purchase costs vis-à-vis the costs considered by the Commission,

the MSEB will recover/refund the same through the FOCA mechanism.

The Commission has considered a reduction of 1% in the station heat rate over the levels

considered in the Tariff Order for FY 2001-02, as it still continues to be above the norm. In

previous Tariff Orders, the Commission had disallowed the transit loss component as a

legitimate expense while computing the generation cost. However, the Honourable High

Court of Mumbai has held that transit losses are a legitimate expense, and the permissible

level of transit losses should be determined by the Commission. Relevant paragraphs of the

Honourable High Court’s Order have been quoted below:

“While we agree with the learned counsel appearing for the respondents that MSEB should

strive to bring down the loss under this head, at the same time, we cannot ignore that transit

loss of coal claimed by MSEB is consistent with the Accounting rules. Even the Central

Electricity Authority has in its report of October 2001 opined that coal loss in transit at 3%

will have to be considered while calculating the tariff. According to MSEB, the transit loss is

caused mainly due to loss of moisture in the coal during transit. This loss according to Board

is beyond their control. We find merit in the submission of Mr. Diwan. In our view, MERC

was in error in denying the claim to MSEB for transit loss in coal. However, the percentage

of loss has to be necessarily determined by MERC on the basis of evidence before it and after

hearing the parties. It is not disputed that the exercise to determine coal transit loss for the

year 2000-2001 is academic as period is already over. Needless to say that MSEB will have

the right to claim coal transit loss for subsequent years”.

The Commission has considered transit losses based on the actual level of station-wise transit

losses and has assumed a trajectory for reduction in transit losses. It has accordingly

determined transit losses for 2003-04 and subsequently.

The Commission is of the opinion that the Uran gas plant should be utilised to the maximum

capacity to obviate the need for load shedding. It is ironic that generating capacity remains



idle due to lack of fuel, despite a part of the State being in darkness. The Commission had

directed the MSEB to submit the detailed Cost-Benefit-Analysis of converting the Uran plant

into a multi-fuel generating facility, as well as the economics of operating the plant with

different fuels. The MSEB has submitted its Report, wherein it has stated that the conversion

of the Uran plant into a multi-fuel generating facility is unviable, considering the lack of gas

availability. The Commission is of the opinion that though gas availability is a constraint at

present, in the near future, additional gas is likely to be available, and the MSEB should

utilize the additional gas to fully utilize the generation capacity at Uran.

The Commission has noted the effort undertaken by MSEB for import of coal and use of

washed coal. The Commission directs MSEB to submit a complete implementation plan for

partial replacement of domestic unwashed coal with imported coal/washed coal to the extent

feasible. MSEB is also advised to evaluate the option of sourcing surplus power from

consumers having captive generation facilities, during peak hours and off-peak hours.

The Commission’s ruling on UI charges is detailed in the section on Generation and Power

Purchase, subsequently.

The Commission retains the standby charge to TPC at the existing levels since the matter is

subjudice. The energy charge to be levied for net sale to the TPC has been increased to match

the highest cost of power purchase, i.e. 299 p/u.

8. EXPENDITURE

8.1.1 Objections

Krishna Valley Chamber of Industry and Commerce has highlighted that actual expense for

FY 2001-02 has been at a variance of Rs. 988 Crore with that of the Commission’s Order

indicating laxity in curbing expenses. They have argued that the MSEB has always been

harping on tariff increase without any mention of efforts undertaken for curbing expenses.

INTEREST EXPENDITURE

Navi Mumbai Action Committee has pointed that the average interest cost at 13% is quite

high. Mumbai Grahak Panchayat (MGP) has specifically pointed that the interest rate of

14.62% and 14.36% on PFC and Private bonds respectively has been high in the current



interest rate regime. If a call option is available for these bonds then interest cost can reduce

by Rs. 108 Crore by assuming 3% reduction in interest rate. MGP has requested the

Commission to direct MSEB to restructure borrowings. Prayas has further brought out that

the interest and guarantee fees for SPA Bank and private bonds worked out to 17% and 32%

of the principal amount. As it seemed at a higher level, MSEB should specifically clarify

these expense items. Pudumjee Pulp and Paper Mills Limited has highlighted that the interest

on loans taken by MSEB for buying DPC equity should not be allowed.

Tata Motors has pointed that the interest on working capital should be Rs. 26.84 Crore against

MSEB’s claim of Rs 51.77 Crore. This is estimated based on working capital requirement of

1 month of HT Consumers Bill, 2 months of LT consumers bill, 15 days of fuel oil and coal

stock and 15 days of generation costs less available Security Deposit with MSEB.

Tata Motors has highlighted that the interest paid on Security Deposit was Rs. 41.61 Crore for

FY 2001-02 against a claim of Rs. 75.39 Crore for FY 2003-04. Based on FY 2001-02

expense, this interest element would work out to Rs. 41.61 Crore on security deposit base of

Rs. 1455 Crore for FY 2003-04.

Mr. K B Dange has requested to reduce interest burden of Rs. 466.19 Crore on Government

loans by converting State Government loan to equity as such loans were granted for various

developmental activities, such as development of Harijan Bastis, rural electrification, release

of connections to agriculture pumps, etc., which were obligatory on part of the State

Government.

ADMINISTRATIVE, EMPLOYEE AND OTHER EXPENSES (A&G EXPENSES)

Rashtriya Grahak Sanghatana has brought out that actual A&G expenses for FY 2001-02

were higher by Rs. 111 Crore than the approved expenses. MSEB has further proposed an

increase of Rs. 234 Crore for FY 2003-04, which is not justifiable. Another consumer has

submitted that the MSEB should find ways and means to reduce the salary and wages to

bring them in line with commensurate salary level in society. MSEB has currently been

spending Rs. 1,87,000 per employee as against prescribed minimum wage of Rs. 45,000 per

annum. Nashik Industries and Manufacturers’ Association has pointed that the employee



expense should have reduced by Rs. 52 Crore as approximately 3,500 employees have been

retiring every year and there has been no significant recruitment.

Mumbai Grahak Panchayat has submitted that the MSEB should not be allowed any increase

in manpower unless a broad bench marking, such as, number of employees per circuit km,

number of employees for every lakh consumers, etc., is carried out. Navi Mumbai Action

Committee has requested MSEB to pubilcise system for improving employee efficiency such

as, productivity norms, stiff targets, and process for monitoring targets.

Mr. S. M. Sane has pointed that the National Productivity Council (NPC) Report, submitted

by MSEB on January 23, 2001, stated that except for one ratio relating to manpower, all the

other ratios (around 30) were higher for the MSEB in comparison to the national average. The

Report did not mention the application of Industrial Engineering techniques for assessment of

manpower requirement. MSEB Workers Federation pointed that the Report was not adopted

by MSEB, as it was established that the conclusions drawn were based on wrong data and

information. Maharashtra State Apprentice Kruti Sameeti (affiliated to MSEB Workers

Federation) has requested to remove freeze on employee addition as work has increased on

account of supply at additional levels of voltage; operationalisation of Khaparkheda and

Chandrapur power station; increase in number of consumers, etc. It has requested permission

for filling up some important vacant posts, having an impact on delivery of service. They

have also suggested giving a chance to young apprentices alongwith a possibility of

permanent absorption if they are found to contribute positively.

REVENUE SURPLUS

Pudumjee Pulp and Paper Mills Limited has objected to Revenue Surplus allowed by the

State Government, as EA 2003 does not provide for it. They have requested the Commission

to review technical/commercial performance before allowing the Revenue Surplus. They have

pointed that in a competitive market, MSEB should not ask for the Revenue Surplus while it

has not been able to recover bills.

OTHERS

Vidarbha Industries Association has pointed that the Consumer’s contribution towards

capital costs and outright contribution, which is a non-refundable amount, should not be



projected as a liability. They have suggested considering it as revenue against sale of power

wherever corresponding capital expenditure has not been committed.

Vidarbha Industries Association has opined that the depreciation claimed should have been

lower by Rs. 156 Crore, as depreciation should not be allowed on consumer contribution,

grants and subsidies, which were projected at Rs. 3,027.74 Crore. Vidarbha Industries

Association has also pointed that the MSEB Balance Sheet carried an excess gratuity liability

of Rs. 235.71 Crore based on actuarial valuation. They have suggested adjusting this excess

liability against revenue requirement for FY 2003-04.

Nashik Industries and Manufacturers’ Association has pointed that the amount of Rs. 91.81

Crore has been paid to the State Government as guarantee charges. Since power development

work is obligatory duty of the State Government, the guarantee charges should be waived off.

Vidarbha Industries Association has highlighted that there has been a reducing trend of write

off of bad debts for past 2 financial years. They have opined that the provision should have

been less than Rs. 170 Crore. Nashik Industries and Manufacturers’ Association has pointed

that the provision for bad debt should be limited to 1.5% of revenue from sale of electricity as

per the Commission’s guideline.


With reference to exercising put option for bonds having high interest rates, MSEB has

submitted that it has consistently been interacting with various financial institutions for

exploring avenues for interest rate reduction. Many institutions, like HDFC, PFC, IFCI, REC

and DCC banks, etc., have effected the interest rate reduction. However, certain other lenders,

such as LIC and the Government of Maharashtra, whose lending rates are 14% and 14.25%

respectively, have been unwilling to reduce the interest rate despite efforts by the MSEB.

With regards to the guarantee fees, the MSEB has clarified that this fee has been levied on

interest payable plus the average loan outstanding. With regards to the interest payable on

DPC bonds, the MSEB has submitted that the inclusion is sought taking into consideration



that the DPC plant is currently lying idle and is locked in litigation. Until the plant is revived

and starts operation, the Commission should allow the interest outgo.

On the issue of working capital interest, MSEB has clarified that there are also consumers

having billing cycle of 3 and 6 months in addition to billing cycles of 1 and 2 months.

Additionally, even for HT consumers with 1 month billing cycle, actual working capital

requirement ranges from 1 to 2 months since bill is not immediately raised upon consumption

by HT consumers.

The MSEB has submitted that the growth in administrative expenses has been partly arrested

by not filling in vacant posts and reduction in overtime payment. This has been made possible

through measures such as banning recruitment (in Class III and IV), stopping payment of

overtime to administration staff, deploying additional staff to certain areas/activities in order

to give better service to consumers, imposing travel discipline amongst the employees, etc.

On recruitment, the MSEB has submitted that it has been currently under directive of the

Commission to cut down on its recruitment in the Pay Group III and IV categories. The

MSEB has proposed hike in Salary and DA as per recent trends in employee expenses.

On the issue of bad debts provisioning, the MSEB has submitted that keeping in mind the

age-wise position of expected arrears, it has decided to make adequate provisioning of

doubtful debts at Rs. 250 Crore for FY 2003-04.


The Commission has analysed each head of expenditure in detail with a view to determine the

prudency of the same. The Commission’s detailed analysis and rationale for approved

expenditure against each head is discussed in the Section on Expenditure Projections.

In the context of the high interest rates on GoM loans, the Commission, in its previous Order,

has already directed the MSEB to reduce the interest cost by renegotiating and refinancing the

high interest bearing loans, including that given by the GoM.

As regards freeze on employment imposed by the Commission, it should be noted that the

Commission has not frozen employment. The Commission had directed the MSEB to



conduct industrial engineering studies in this connection, as recommended in the

Rajadhyaksha Committee Report. However, the Commission noted that its directives

restricting recruitment to Group III and IV posts had been interpreted as preventing MSEB

from filling the backlog of vacant posts reserved for backward classes, inspite of State

Government Orders from time to time. The Commission hence issued a Clarificatory Order

dated 21.4.2003 to the Tariff Order issued by the Commission in May 2000. In the

Clarificatory Order, the Commission clarified that its directives restricting recruitment in

Groups III and IV of MSEB did not apply to recruitment to fill the backlog of posts reserved

for backward classes to the extent of the vacancies carried forward upto May 5, 2000, i.e. the

date of the Commission’s original Order, since such vacancies have been carried forward

from recruitment exercises which predate that Order. However, this was subject to the

condition that the total number of employees in Groups III and IV as on May 5, 2000 would

not exceed as a result.

MSEB is directed to complete the industrial engineering study and submit the new norms

within six months.

9. INFORMATION SYSTEMS AND METERING

9.1.1 Objections

INFORMATION SYSTEM

Janata Dal (Secular) has submitted that all MSEB offices should maintain a copy of official

Circulars, display Commercial Circulars on Notice Board in the MSEB’s local offices and

make them available to consumers on payment of nominal charges.

Prayas has highlighted the need for authentic reporting and streamlining of reporting. Prayas

has pointed that the change in reporting format by MSEB has been making comparison and

analysis difficult. They have requested the Commission to direct MSEB to submit all periodic

reports, including monthly energy audit reports, billing and revenue reports on affidavit. Any

change in the numbers should be taken up by the Commission seriously. It has requested the

Commission to direct MSEB to submit progress reports in specific formats, which would

improve the information available with the Commission and the public.



It has been highlighted that the MSEB has not submitted Audited Balance Sheet for FY 2002-

03. Mr. S R Paranjape has further requested the Commission to direct MSEB to provide

audited statements alongwith a specific explanation for violation of approved limit on

expenditure on each of the sub-heads and a specific note on shortfall in projected revenue

under various sub-heads. Tata Motors has also suggested that the MSEB should start

publishing financial results every 6 months like a corporate.

METERING

Finolex Industries Limited has pointed that the MSEB has stopped testing of HV/EHV Meter

(TOD). They have suggested checking of all parameters (kWh, kVAh and kVA MD) for

accuracy atleast once a year. They have requested that the data from TOD meters should be

retrieved once a month and copy should be made available to HT consumer on chargeable

basis for study of load pattern.

Consumers have highlighted that the MSEB has not come up with 100% meterisation

programme and have requested MSEB to provide time schedule of Meterisation program.

Hotel and Restaurant Association (Western India) has requested the Commission to lay down

a specific time frame for MSEB to switch over to metered system. Panchayat Sameeti,

Baglan, has requested to carry out metering of all agriculture transformers to enable more

accurate estimation of losses and agriculture consumption.

Hotel and Restaurant Association has requested the Commission to direct MSEB to consider

installing common meters for building/society/industrial estate wherever the consumer is

willing to take up retail distribution responsibility.

Tata Motors and several Consumer Associations have suggested several improvements in

metering. Some of the suggestions offered are:

Use prepaid meters. Employ automatic meter reading system. Map consumers to a meter/pole/transformer/block/taluka/district to improve analysis. Use check meters for HT consumers. Use meter with MRI prints for HT consumers and use hi-precision, hi-tech electronic

meters for all LT consumers.




MSEB has submitted that except for a base of about 18 lakh LT agriculture consumers, all the

remaining consumers have been metered. However, the meterisation program for LT

agriculture is slowing down due to resistance from cultivators and local leaders. There have

also been instances of removal of installed meters forcefully by mobs as reported by the field

offices. The MSEB has indicated that as such, the meterisation program may not be

completed by December 2004. Out of 18,793 agriculture consumers above 10 HP, 8,757

numbers are metered and 10,011 are unmetered as on June 30, 2003. In HT LIS category, all

the consumers are provided with meters.

MSEB has further submitted that an aggressive metering program is underway wherein the

procurement of meters is being increased manifold. This would help the MSEB in better

measurement of its T&D losses and taking appropriate actions to curb such losses. The

MSEB has further adopted target of metered consumption at 50.2% of the proposed energy

input for FY 2003-04 against 44.2% in FY 2000-01 and 46.4% in FY 2002-03.

On the issue of providing a copy of the meter data retrieved for billing purpose, MSEB has

submitted that such data is retrieved in doubtful cases. As such, the data can be provided to

the consumer if he requires it for a particular month and for a specific purpose.


The Commission agrees with the need for authentic reporting and streamlining of reporting.

The Commission directs MSEB to submit all periodic reports, including monthly energy audit

reports, billing and revenue reports on affidavit. The Commission has noted that in the past,

the MSEB has been submitting periodic reports in different formats for different periods,

making it difficult to analyse the data submitted. The Commission directs the MSEB to

submit all periodic reports in a consistent format.

The Commission is of the opinion that 100% metering is a must to ensure proper energy

accounting and identification of losses, and had set targets accordingly, in previous Tariff

Orders. The Commission directs the MSEB to adhere to the deadline for achieving 100%

metering. The MSEB may consider innovative solutions like group metering, feeder level

metering, etc. to achieve the metering targets.



As brought out by several consumers, the MSEB should ensure operation of all connected

meters by necessary testing. MSEB should also ensure reading of meters during every billing

cycle. As the meter data is retrieved in all cases, particularly for consumers with ToD meters

MSEB should share the recorded meter data with the consumers if the consumer desires to

have a copy.

10. T&D LOSS CHARGE (TDL)

10.1.1 Objections

Several consumer associations have represented against levy of T&D charge, its

implementation and MSEB’s Proposal to introduce uniform T&D loss charges across the

State. They have submitted that a common consumer should not be penalised for MSEB’s

sole failure in controlling T&D losses. They have pointed that Rs. 868 Crore out of total gap

of Rs. 1,463 Crore is attributable to excess T&D losses.

Several Consumer Associations have further requested to fine tune application of T&D loss

charge by considering loss level at a smaller geographic unit such as, MSEB division, sub-

station, distribution transformer, etc. The industrial segment has also represented against

clubbing of industry with others in determination of loss level and requested to fine-tune it

according to loss level attributable to them at its incoming feeder such as, EHV feeder, MIDC

feeder, feeder associated with industrial belt, etc. Further fine-tuning is suggested to account

for population mix of HT, LT, domestic, commercial and agricultural consumers; distance of

consumer from generating units; distance of consumer from substation. Industry in Vidarbha

region has sought an exemption from this charge, as T&D loss attributable to them would be

quite less on account of their proximity to generation units.

Shetkari Sahakari Sooth Girni Limited has brought out that selective charging of T&D loss on

certain circles creates unfair difference in cost between competitors for no direct fault of

honest manufacturers. Vidarbha Industries Association has suggested structuring of T&D loss

charge as incentive rather than as a penalty. Century Enka has pointed that the practice of

billing transformer losses at 220 kV to EHV consumers in addition to TDL charge amounts to

double accounting and hence should be discontinued.



Several consumers have mentioned that the MSEB has not paid its share of 50% of T&D Loss

charges i.e. Rs. 636 Crore. So, MSEB should not be allowed to charge the same to other

consumers.

Prayas has requested the Commission to rework the T&D Loss (TDL) charge and make the

revenue neutrality (or lack of it) explicit in the Order. They have extended their support to

graded TDL charge as linked to losses in the area with a ceiling of Rs. 0.50 per unit.

The Mumbai Grahak Panchayat (MGP), a Section 26 consumer representative, has suggested

that if the MSEB needs ‘Oxygen’ in the form of tariffs to recover the cost of the excess losses,

the consumers would be willing to contribute the same, provided the Commission treated this

contribution as a Regulatory Liability owed by the MSEB to the consumers, as this is not part

of the MSEB’s rightful revenue requirement.


MSEB has submitted that it is against the philosophy of differential T&D loss charges. MSEB

has opined that such a proposal would be inequitable on its part and discriminating against

certain sections of the society. The factors responsible for variation in T&D losses across

areas are HT consumption as a percentage of total consumption; the ratio of length of HT

distribution lines to the length of LT distribution lines, and consumer mix. It would be unfair

to levy differential T&D loss charge on consumers who have no control on these factors.

With regards to bearing of 50% of excess T&D loss, MSEB has mentioned that the monetary

component of the 50% i.e. Rs. 636 Crore was reduced from the ARR while determining

tariffs.


T&D losses are a very critical factor affecting the tariff determination process. The

Commission has dealt with all these issues in detail in the Section on T&D losses, which also

includes a detailed analysis of the energy audit data submitted by the MSEB and the T&D

loss levels at various levels.



11. SECURITY DEPOSIT (SD)

11.1.1 Objections

Nagpur Power and Industries Limited has objected to recovery of security deposit to the

existing level of billing cycle plus 1 month. Consumers have strongly objected to MSEB’s

Proposal of increasing security deposit from 1-3 months to 2-6 months while MSEB pays

interest at the rate of 3.5%. MIDC Industrial Association has found the requirement of 2-3

months of security deposit for LT consumers discriminatory as compared to 1 month

requirement for HT consumers.

Anjangaon Surji Grahak Panchayat has pointed that the MSEB has been required to pay

interest at the rate applicable to bank deposits on consumer’s deposits as per EA 2003. Some

consumers have suggested that the MSEB should pay interest at a rate of 9% to 18%. Some

other consumers have requested linking this interest rate to postal savings interest rate or bank

interest rate or penal interest rate charged by MSEB.

Century Enka Limited has suggested that the MSEB should accept Bank Guarantee or

revolving Letter of Credit in place of deposit. Century Enka has also observed that if the

security deposit earlier paid becomes excess of one month’s consumption, MSEB has not

been granting or subsequently delaying refund of the excess deposit. They have submitted

that the MSEB should lay down transparent procedure for calculation of refund of excess

security deposit and refund the same within one month of claim by way of adjustment in the

electricity bill/direct payment.


MSEB has pointed that the Commission has allowed security deposit corresponding to the

average of 3 months of billing or the billing cycle period, whichever is lower. On the issue of

proposed change in security deposit, MSEB has clarified that the change in levels of security

deposit is being proposed for only those categories whose billing cycle is more than 3 months.

The change is not proposed for industrial consumers.

The MSEB has also submitted that the Supreme Court, in one of its rulings, has found the

collection of security deposit from consumers as justified. Though it is not binding on the



MSEB to pay any interest on such security deposits, the MSEB has argued that it still pays

interest to the consumers at the rate of interest allowed on post office savings account. The

MSEB has further argued that it recovers this interest paid through the Annual Revenue

Requirement, and thus any further increase in the interest rate payable would only result in a

higher revenue requirement and consequently higher tariffs.

MSEB has further submitted that it prefers security deposit from consumers as it provides it

with ready cash for meeting the working capital needs. If bank guarantee/letter of credit

facility were to be extended, then the need for working capital borrowings would be higher

which would also increase the revenue requirement of the MSEB and the tariffs.


The Commission had reduced the rate of interest on delayed payment in the past Tariff

Orders. The consumers should appreciate that if the MSEB starts paying a higher rate of

interest on the Security Deposit to match the rate of interest on delayed payment, then the

additional expense incurred on this account will have to be adjusted through tariffs. The

Commission has also retained the quantum of Security Deposit at earlier levels so that the

consumers are not burdened further. The issue of refund of Security Deposit shall be

addressed alongwith the approval of the Terms and Conditions of Supply.

12. SERVICE LINE CHARGES (SLC)

12.1.1 Objections

Vidarbha Industries Association has suggested that the Service Line Charges should not be

linked to Connected Load as loading of network is determined by specified Maximum

Demand by consumer rather than the Connected Load, which could be three to four times

higher than the Maximum Demand established by the consumer. The Service Connection

Charges in addition to the Service Line Charges should not be levied. The supervision charges

of 15% should be linked to labour component only as provided in the Model Conditions of

Supply in IE Rules 1956 Schedule VI (5). The Schedule states that ‘if a consumer desires to

have the position of the existing service line altered, the Licensee shall carry out the work and

charge the consumer the cost of the additional material used and the labour employed plus

15% of the latter as supervision charges.



Additionally, they have requested the Commission to consider refund of Service Line Charges

since service line becomes the property of Licensee.

Vidarbha Chamber of Small Scale Industries has pointed that the MSEB should not charge

Service Line Charges for restoration of Contract Demand wherever they have been collected

once from the consumer and not refunded at the time of reduction of Contract Demand, which

is the prevailing practice.

Tata Motors has pointed that the MSEB has not considered Service Line Charge and Service

Connection charge as revenue generated in the Tariff Petition. Tata Motors have estimated the

revenue from these heads at Rs 38.54 Crore and Rs 21.04 Crore, respectively.


MSEB has submitted that the Service Line Charges and Service Connection Charges are of

capital receipt nature and hence cannot be included in the Revenue Income projection.


The Commission is of the opinion that the determination and payment of Service Line

Charges is within the scope of the ‘Terms and Conditions of Supply’. The Commission will

take up this issue alongwith approval of the ‘Terms and Conditions of Supply’ after the issue

of this Tariff Order. The Commission also clarifies that the income from SLC and service

connection charges are a capital receipt in the books of the MSEB, and cannot be recorded as

revenue receipts. Further, the Capital Base is reduced to that extent, while computing the

reasonable return.

13. CAPITAL INVESTMENT

13.1.1 Objections

Prayas has submitted that it would be the Commission’s responsibility to ensure that the

consumers are protected from high cost of an investment and ‘usefulness’ and ‘prudence’ of

the investment has been established in advance to avoid improper investment decisions.

‘Disallowance’ at a later stage could be costly for MSEB and would also affect service

quality. To cite an example, Prayas has pointed that the expansion plan for Parali and Paras



Generating Unit has been projected at a cost of nearly Rs 5 Crore/MW, which would be too

high for an expansion plan.

Prayas has also requested to establish prudence and usefulness test for all new EHV

investments in past 3 years. They have requested the Commission to obtain details of loading

of the EHV substations and lines and availability of the equipment (in % time). They have

further requested to investigate and disallow capitalisation of a part of such investment where

new EHV substation is highly unloaded to ensure protection of consumer interest.

MSEB should seek the Commission’s permission on capacity addition and provide advance

information on its plans, options considered, and competition encouraged during the process.


The MSEB has submitted that per MW cost for expansion project is actually Rs. 4.21 Crore

including interest during construction. Further, the expansion project has been located at Parli

to utilise existing facilities.


The Commission agrees that the ‘usefulness’ and the ‘prudence’ test have to be established in

advance to avoid improper investment decisions. The Commission hereby directs the MSEB

to provide details on its investment plan for approval of the Commission. The Commission

will evaluate all prospective investments. Though the Commission has been asking the MSEB

to justify its investments in the past, the MSEB has not come forward and given the requisite

Cost-Benefit Analysis.

14. ENERGY CONSERVATION AND DEMAND SIDE MANAGEMENT (DSM)

14.1.1 Objections

Vrikshawallee, a ‘not for profit’ NGO, has highlighted that existing tariff structure does not

provide enough incentive for widespread implementation of DSM schemes across the State.

Citing international experience, it has suggested that the MSEB should adopt principles of

integrated resource planning and strive to acquire demand-side resources, renewable energy

resources alongwith traditional supply-side resources. Demand-side resources include



measures to change the electricity load shape by adopting a wide range of end use

technologies or options. The demand-side technologies and options that are likely to be most

cost-effective in Maharashtra are those that reduce the load during MSEB’s peak period, such

as, peak clipping, load shifting, strategic energy conservation, etc. Examples include

improving efficiency of Irrigation Pump (IP) sets; installing energy-efficient lamps and

lighting systems; replacing domestic electric water heaters with solar thermal water heating

systems; improving efficiency of street lighting by installing solar photovoltaic systems, LED

lighting, high efficiency sodium vapour lamps, or combinations thereof; installing energy

efficient pumping systems in Municipalities; inducing industries to shift electricity loads from

peak to non-peak periods. For development of such demand-side resources, MSEB should

pay an amount equal to alternative cost of an equivalent amount of supply-side resources for

measures that provide sustained, quantifiable and measurable benefits to system.


The MSEB had submitted that it had initiated pilot schemes for demand side management and

energy conservation. However, in the meantime, since MEDA has been designated as the

implementation agency to carry out all energy conservation measures in the State of

Maharashtra, the MSEB has shared details of the planned pilot schemes with MEDA.


Managing the demand through DSM techniques, which include load shaping as well as

reduction in the consumption levels through use of energy efficient devices, is very essential,

to bridge the gap between demand and supply. The World Bank has already conducted studies

in this regard, which should be used by the MSEB to formulate appropriate DSM schemes.

The Commission directs the MSEB to come forward with concrete schemes to implement

DSM in the State. This will also enable the MSEB to undertake Least Cost Planning in the

future, and will enable the MSEB to manage its demand to match its supply. The MSEB

should encourage the use of energy efficient devices, and publicize the benefits to the

consumer through appropriate publicity media.



15. TRIFURCATION OF MSEB

15.1.1 Objections

N.N.Kale and Associates has requested the Commission to advise MSEB for formation of an

Expert Committee to facilitate trifurcation. The Committee should ensure coordination with

the GoM, the MSEB and the Commission to expedite the process of trifurcation and do the

auditing of valuation of assets, valuation of intangible assets, valuation of inventories,

physical verification of the fixed assets and its valuation, valuation of shares, study of the

remarks of the auditors, funds from the GoM, Loans and advances, etc.

Kolhapur Zilla Dalap-Kandap Girni Malak Sangh has opposed the privatization of MSEB.

Maharashtra State Apprentice Kruti Sameeti (affiliated to MSEB Worker’s Federation) has

objected to trifurcation as well as privatisation. They have expressed the view that more

autonomy and freedom from political interference would enable MSEB to provide better

service. However, several consumers have suggested that atleast distribution wing of MSEB

should be privatised immediately. Vidarbha Chamber of Small Scale Industries has suggested

decentralising manpower and responsibilities of MSEB in their failure areas for sometime to

improve their performance. However, it has also requested that the Commission should not

allow privatisation wherever efficiency is demonstrated by MSEB.


MSEB has not addressed this issue in its response.


The EA 2003 has mandated the corporatization of the vertically integrated Utilities and the

separation of the State Transmission Utility (STU). The Government of Maharashtra and

MSEB have been working on the restructuring of the MSEB and the corporatization of the

MSEB’s successor entities. Under the EA 2003, the Commission has a proactive role in this

process and the Commission will offer its suggestions to the GoM at the appropriate time.



16. DATA DISCREPANCY/INSUFFICIENCY

16.1.1 Objections

Prayas has highlighted a large variation in the T&D losses as given in the Energy Audit

reports and losses reported in the Tariff Proposal. It has pointed that such variation would

have large financial implications for the Transmission Utility and end consumers in the open

access regime.

Vidarbha Industries Association has questioned revenue calculation for sub-categories of LD-

1. It has argued that considering 29,24,493 consumers in sub-category of 0-30 units, and

considering maximum consumption of 30 units, annual consumption could work out to

around 1,052.8 Mn units. However, MSEB has mentioned sale of 2,932 Mn units against this

sub-category. If these additional units were considered as part of next sub-category,

incremental revenue generation would be Rs. 310 Crore with average sale price of Rs.

2.75/unit.

Tata Motors has questioned reliability of number of customers and units sold pointing out

data discrepancy. They have requested MSEB to submit correct data with proper backup.

Ispat Industries Limited has highlighted that MSEB has not provided cost of supply either on

HT/LT basis and/or on consumer category basis. Tata Motors has also pointed that consumer

category wise revenue data has not been provided. Consumers have brought out that data

related to ToD tariff, power factor incentive and penalty, bulk discount and captive and

seasonal consumers have been clubbed together with parent category. Each of these data

elements needs to be separated for each category to get a realistic realisation of all tariff

categories.

Vidarbha Industries Association has pointed that the MSEB is required to provide open

access on chargeable basis under EA 2003 and such charges are to be determined by the

Commission. Since, this will have an impact on tariff, open access proposal should be cleared

before tariff revision. Vidarbha Industries Association has also requested MSEB to submit

provisional accounts for FY 2002-03 and FY 2003-04 for public hearing.




With reference to inference on the domestic category consumption, MSEB has submitted that

the consumption of 2,932 MU pertained to not only the consumers in the first slab but all the

other slabs too. This is because the domestic tariff is telescopic in nature, and the first 30 units

for all consumers are charged at the same rate.

On the issue of variation in number of consumer, connected load and units consumed, MSEB

has clarified that comparing numbers that were projected for a year to the numbers that

actually materialised is not proper.

MSEB has submitted that the items of ToD tariff, power factor incentive, bulk discount,

captive and seasonal consumers have been kept together as these

incentives/penalties/additional charges have been uniformly applied across the relevant

categories and hence have been kept together instead of showing them separately for each

category.

On the issue of open access revenues, the MSEB has submitted that the distribution level

open access, timing and extent, needs to be granted by the State Commission while taking

into consideration existing levels of cross-subsidies. Any revenue arising out of transmission

level open access can be taken care of in the future Filings.


The Commission has considered all these issues and the MSEB has submitted necessary

clarifications on the same to the Commission.

17. NON-COMPLIANCE WITH COMMISSION DIRECTIVES

17.1.1 Objections

N.N.Kale and Associates has pointed that the MSEB compliance report excludes directives

from May-02. Additionally, MSEB should submit compliance report certified by Cost and

Management Accountant.

Prayas has pointed out that the MSEB has not complied fully with following directives of the

Commission:



Directive Status and implication

DSM and Fund for agricultural DSM

MSEB has not completed work as per schedule given in the directive. MSEB has not implemented DSM plan for buildings. MSEB has not created fund for agricultural and PWW DSM.

Application of “Reliability Charge” on HT industry

MSEB has not implemented this Order. Prayas has estimated the loss to MSEB in the range of Rs. 200 Crore per annum.

Discontinue average billing

MSEB has continued to issue bills based on average consumption. The excess money charged due to this method (especially for the very small rural residential consumers) should be refunded.

Audit of express feeders and MIDC areas

Nearly 70 express feeders (out of around 200) have demonstrated consistent problem for 4 out of 12 months even though MSEB claimed that it has been doing energy audit for past 3 years.

Cost audit of MSEB generation plants

MSEB has given only limited consultancy and actual audit expected to start only by end of 2003.

Feasibility studies for Uran liquid fuel and imported coal

MSEB has started importing coal in limited quantity.

Janata Dal (Secular) has pointed that the MSEB has not complied with the following

directives issued by the Commission in previous Orders:

Reduction in T&D loss Reduction in load shedding Spot billing, reduction in billing cycle time Reduce outstanding to 5 months Reduce T&D losses by 5% every year, and15-16% within 2-3 years Take action against employees responsible for T&D loss Promote energy saving devices



Other consumers/associations have also pointed that following additional directives have also

not been complied with:

• Pay fine of Rs. 7 Crore as prescribed in last Tariff Order

• Improve system reliability

Prayas has urged the Commission to fix responsibility for non-compliance of the

Commission’s Order by MSEB. In case of ‘Cost Audit’ and other such cases, where the

Utility has not taken timely action of carrying out required studies, the Commission should

directly appoint consultant and ask the Utility to pay for the costs.

Tata Motors have submitted that the MSEB should submit implementation plan for “Jan

Mitra Concept”. They have opined that not more than 1 year should be allowed for

implementation in totality.


MSEB has submitted that it has undertaken all possible efforts to comply with the directives

of the Commission. The MSEB has further submitted that it may take more time (than

directed) for achieving certain directives over others, however, the MSEB has never wilfully

disobeyed the Commission’s directives.

With regards to the ‘Cost Audit’, the MSEB has submitted that it has already appointed

ICWAI for studying the existing accounting and costing records at Nashik, Uran and Koyna

power stations and devising a system to facilitate compliance with the directives of the

Commission. The MSEB has added that the system suggested by ICWAI is being

implemented in a phased manner at the above stations.


The Commission had directed the MSEB to comply with its directives given in the earlier

Tariff Orders and issued separately from time to time. However, the Commission is very

unhappy with the performance of the MSEB in this regard. Despite the Commission’s strong

warning that it would be constrained to take serious action if there was slippage in compliance



with the directives, the MSEB has not shown its willingness to comply with these directives

in the true spirit. The Commission expresses extreme displeasure with the MSEB’s non-

compliance of its directives, despite several reminders in this regard. The Commission may be

constrained to reject further Tariff Petitions if the Commission’s directives are not complied

with.

The MSEB should submit compliance reports on a quarterly basis. Henceforth, the

Commission will conduct periodic reviews of the MSEB’s compliance with the directives.

Further, in case the MSEB desires any clarification on any directive issued by the

Commission, the MSEB should request such clarification within a month of the directive

being issued, failing which it will be assumed that the MSEB does not require any

clarifications, and the MSEB will be required to comply with the directives expeditiously,

both in letter and in spirit.


Commission’s Analysis & Decision on MSEB’s Proposal 114

PART – III: COMMISSION’S ANALYSIS AND DECISION ON THE MSEB’S PROPOSAL

18. APPLICABILITY OF TARIFF REVISION FOR REMAINING PART OF THE YEAR

S.59 of the E (S) Act states that the MSEB shall adjust its tariffs so as to ensure that the total

revenues in any year of account shall, after meeting all properly chargeable expenses, leave

the mandatory surplus on its Net Fixed Assets. The MSEB has requested the Commission to

grant tariff revision effectively for all twelve months of the year, which would imply a overall

tariff increase of 12.5%.

The Commission, in its previous Tariff Order, had clearly indicated to the MSEB that it

should file the Tariff Petition for FY 2003-04, by December 2002, to enable the Commission

to issue the Tariff Order by March end, and the revised tariff could be applicable for the entire

year. However, for various reasons, the MSEB has delayed filing the Tariff Petition, and

consequently, the Commission has been forced to issue the Tariff Order on December 1,

2003.

The Commission has been consistently of the view that the tariffs should not be applied

retrospectively. Acceptance of the MSEB’s proposal to apply the revised tariffs such that the

entire year’s additional revenue requirement is recovered in the balance period of the year,

would amount to levying retrospective tariff on the consumers, and the Commission has

hence rejected this request of the MSEB. Moreover, if the tariffs are determined in such a

manner, then there is a real possibility of the MSEB over-recovering its revenue in the

coming year, as the monthly revenue generation is likely to be higher than its expenses.

Further, MSEB is entitled to recover any difference between actual generation and power

purchase expenses (equivalent to 55-60% of total expense), including certain other expenses

(under ‘Z’ category with prior approval) and the expenditure projected by the Commission on

these heads, through the approved FOCA mechanism, subject to performance benchmarks.

Thus the Commission has enabled the Board to recover permissible expenditure from time to

time (monthly) avoiding any adverse impact on MSEB’s finances or refund excess recovery

facilitating consumer to pay towards actual approved expenditure.



The Commission thus rules that the revised tariffs would be applicable for 4 months of FY

2003-04, i.e., from December 1, 2003 to March 31, 2004, and till such further time as the

MSEB does not approach the Commission for tariff revision.

19. AVERAGE COST OF SUPPLY

The Commission, in its previous Tariff Order dated January 10, 2002, had stated that the

tariffs would gradually approach the average cost of supply, and that the Commission would

attempt to continue the process of elimination of the cross-subsidy in five years. The

Commission is of the view that considering the data availability, the average cost of supply

method is the most suitable methodology for the present. However, in the long-term, the

Commission desires to link the tariffs to the voltage-wise and category-wise cost of supply, as

they reflect the true cost incurred to supply to different consumer categories. The MSEB is

directed to maintain cost details such that it enables the computation of voltage-level and

consumer level cost of supply.

20. GOVERNMENT OF MAHARASHTRA SUBSIDY

The MSEB’s tariff proposal has not assumed any subsidy from the GoM. The Commission

had written to the GoM in September 2003, asking the GoM to indicate its subsidy

commitment and the consumer categories that would benefit from the GoM’s subsidy. The

GoM in its response dated October 13, 2003, indicated that the issue of granting subsidy for

FY 2003-04 based on existing rates was under consideration of the GoM. Further, the GoM

indicated that it would be in a position to specify the category-wise subsidy only after the

Commission determined the tariff. Subsequently, on October 20, 2003, the GoM wrote to the

Commission that it had taken the decision to continue to charge agricultural and power loom

consumers at the same subsidized rate announced by the GoM for FY 2002-03, till a final

decision was taken by the GoM in this regard.

In the light of these communications from the GoM, the Commission has not considered any

subsidy from the GoM, and has determined the tariffs for these categories in line with the

philosophy of cross-subsidy reduction outlined in previous Tariff Orders and continued in this

Order. In case, the GoM desires to give subsidy to any consumer category subsequent to this

Order, the modalities for the same will have to be submitted to the Commission for its

approval.



21. CROSS-SUBSIDY REDUCTION

In its Tariff Petition, the MSEB has stated that it has adopted the following philosophy for

proposing category-wise tariffs:

1. “The tariffs have to reflect costs, and the proportion of subsidized consumers must reduce.

2. While tariff rationalisation should continue, thought also needs to be given to the paying culture amongst the Board’s consumers. Hiking tariffs for consumers who have a weaker paying track record would hardly do justice to the Board’s financial position. If this is not done, the Board’s cash losses will keep on mounting in spite of getting year on year tariff hikes.

3. Tariff rationalisation should incentivize metered consumption vis-à-vis un-metered consumption for agricultural consumers”.

On page II of its Tariff Petition, the MSEB has stated that “the T&D loss reduction targets

will be feasible only if the existing distortion in tariffs is corrected and metered tariffs are

made more attractive vis-à-vis metered tariffs.”

On the same page, the MSEB has commented that “while tariff rationalisation must continue,

the Board has taken into consideration that certain consumer categories have exhibited a

better payment track record than others have in the past. Keeping in mind the Board’s

inability to disconnect certain consumer categories which have a poor payment record, the

Board has proposed tariff hikes for consumer categories which are above the average cost of

supply. If this is not done, the Board’s cash losses will keep on mounting in spite of getting

year on year tariff hikes”.

As is obvious, the MSEB’s above statements are contradictory, and are also against the tariff

philosophy clearly enunciated by the Commission in previous Tariff Orders. Neither has the

MSEB proposed any substantial difference in the metered tariffs vis-à-vis un-metered tariffs.

The Commission has adopted certain principles, which are in continuation of the process of

tariff rationalisation initiated in the previous Tariff Orders. In general, the movement of

tariffs towards the average cost of supply has been maintained, such that inter-class cross-

subsidy is reduced gradually, while at the same time ensuring that no consumer category is



subject to a tariff shock. The Commission has also further reduced the intra-class cross-

subsidy, by reducing the difference between the highest and lowest slab rates. The MSEB has

installed meters for all the hitherto un-metered consumer categories except LT agriculture. In

the absence of metering, the Commission has been constrained to specify flat rate tariffs for

the un-metered LT agriculture category, and the tariff for other categories is based on meter

reading. The difference in metered tariff and the flat rate tariffs has been increased to

incentivize un-metered consumers to opt for metering.

The Commission has considered an average consumption norm of 1300 hours/HP/year in case

of flat rate LT agricultural consumers, based on the available sample energy audit data

submitted by the MSEB. The Commission has attempted to determine the flat rate tariffs for

agriculture category such that the tariffs reflect the actual consumption pattern. This has been

done by specifying circle-wise differential flat rate tariffs linked to the agriculture

consumption norm as established by the energy audit data for that circle. To start with, the

Commission has prescribed two tariff levels, viz. lower tariff for circles with consumption

norm lower than the average consumption norm of 1300 hours/HP/year, and higher tariffs for

circles with consumption norm higher than the average consumption norm of 1300

hours/HP/year. The Commission hopes that this will incentivize the shift to metered

consumption at a faster rate.

22. RATIONALIZATION OF CATEGORIES

The MSEB has not proposed any reduction/rationalization in the number of categories and

slabs. The Commission has however, reduced a few categories and slabs, which is described

in detail in the section on category-wise tariffs.

23. TIME OF THE DAY TARIFF

The Commission had introduced the ToD tariffs for HT industrial categories in its first Tariff

Order dated May 5, 2000. In the past Order, the ToD consumption of the HTP-I and II

categories had reached levels such that the HT industrial category had matched the

normative levels, i.e. the actual consumption during the hours 2200 to 0600 hours was

around 33%, as compared to the normative share in that period, i.e. 8 hours during the day

translates to 32.5% of the total hours during the day. The Commission had extended the ToD

tariff for more categories as well as increased the differential between the peak and off-peak



hours, consequent to the beneficial impact on the load curve, with the objective of sifting

more industrial load as well as the load of other categories. The MSEB has submitted the ToD

consumption data for different consumer categories for FY03 in the Tariff Proposal. The

analysis of the ToD data is presented in the following graph:

The graph below shows that the consumption of the HT industrial and HT water works

categories, i.e. HTP I and II and HTP III and IV, have shifted due to the ToD tariff, such that

they have almost matched the normative level of consumption at different time slots during

the day. The load of the other categories where the ToD tariffs are available, i.e. Other HT

and LTP-G category, needs to be flattened further. The Commission has hence further

increased the differential in ToD rates for all categories, to smoothen the load further. The

ToD tariff for LTP-G category will be applicable for only those consumers who opt for the

LTMD based metering.

ToD Consumption Pattern

0.00%5.00%

10.00%15.00%20.00%25.00%30.00%35.00%40.00%45.00%

% C

onsu

mpt

ion

HTP I & II 32.45% 38.47% 12.42% 16.66%

HTP III & IV 32.76% 38.55% 12.45% 16.23%

Other HT 29.13% 42.33% 12.39% 16.16%

LTP-G 27.78% 41.74% 15.18% 15.29%

Normative 33.33% 37.50% 12.50% 16.67%

2200-0600 0600-0900 & 1200 - 1800

0900-1200 1800-2200



24. METERING

The MSEB has managed to meter all the hitherto un-metered consumer categories, except

LT agriculture. As compared to the status at the time of the Tariff Order issued on January

10, 2002, the MSEB has installed meters at all power loom connections, and all HTP-VII

consumers. Moreover, the MSEB has also submitted that it has replaced around 55 lakh

meters across all categories, out of a total metered consumer base of around 1.13 crore,

which amounts to around 50% of the meters being replaced. However, during discussions

with the Commission, the MSEB was not able to satisfactorily explain the rationale for the

massive meter replacement programme and the benefits achieved due to the meter

replacement.

The target dates for 100% metering have repeatedly been pushed back by the MSEB. On the

one hand, the MSEB claims that accurate T&D loss assessment can be done only after 100%

metering has been done, while on the other hand, the MSEB continues to maintain that 100%

metering may not be achieved even by the extended date of December 2004. The MSEB has

now submitted that the meterisation programme for LT agriculture is slowing down due to

resistance from cultivators and local leaders. The MSEB has added that some field offices

have reported instances of removal of installed meters forcefully by mobs.

Further, the MSEB has still not made any commitments as regards 100% metering of LT

agricultural consumers, apart from stating that metering is achievable only if the flat rate

tariff is substantially higher than the metered tariff for these categories. The original target

dates for achieving 100 % metering of LT agriculture consumers, viz. initially May-June

2003, and later December 2003, and have all passed, without any significant progress in

metering of LT agriculture consumers. This is despite the fact that the MSEB has repeatedly

claimed that the problem of low metering is the root cause for inaccurate determination of

T&D losses.

It may be noted that in view of the provision of grant of open access under the Electricity Act,

2003 (EA 2003), it is essential that the meters on all transaction on and above 11 kV network,

including DTC, are provided with communication ability, eg. GSM, to ensure real time

monitoring of (1) Energy Flows, (2) Energy Accounting and Auditing, and (3) Capacity

Utilization of Transmission Corridors. The centralized control for energy accounting and



auditing should be placed at identified important regional points and load dispatch centre. The

MSEB should inform the Commission on the current status and implementation schedule for

the above, as well as submit periodic compliance reports. The Commission has also

prescribed AMR meters in its recent Wind Order and Bagasse Clarificatory Order. The

MSEB should also take the initiative to provide all consumers with power line

communication card to facilitate automation of metering and billing system.

The Commission hereby reiterates its earlier directive to the MSEB to achieve 100% metering

of LT agriculture consumers at the earliest, assigning priority to the appropriate DTC

metering and close monitoring to arrive at statistically significant output for assessed

agricultural consumption, and operating hours.

25. COMPLIANCE WITH COMMISSION’S DIRECTIVES BY MSEB

The Commission had directed the MSEB to comply with its directives given in the earlier

Tariff Orders and issued separately from time to time. The MSEB has submitted a compliance

statement, wherein it has detailed the various actions taken by the MSEB subsequent to the

Commission’s directives and the status of implementation of the various directives issued by

the Commission.

The Commission is very unhappy with the performance of the MSEB in this regard. Despite

the Commission’s strong warning that it would be constrained to take serious action if there

was slippage in compliance with the directives, the MSEB has not shown its willingness to

comply with these directives in the true spirit. The Commission expresses extreme displeasure

with the MSEB’s non-compliance of its directives, despite several reminders in this regard.

All the directives issued by the Commission in the previous Tariff Orders issued in May 2000

and January 2002 are still applicable, and the MSEB is directed to comply with the same in

letter and in spirit. The top management of the MSEB is urged to take urgent steps to comply

with these directives expeditiously.

The status of the various directives given by the Commission in the previous Tariff Orders

and the directives issued in this Order have been summarized below:



The MSEB is directed to install meters for all the flat rate categories, viz. LT and HT agriculture, Power loom and Municipal Councils – the MSEB has metered all categories except LT agricultural consumers.

The MSEB is directed to provide name Badges for all MSEB staff interacting with the Public – the MSEB has cited a Departmental Circular stating that name badges have to be worn, but the circular has remained only on paper; the Commission would like the MSEB to realise that mere issuance of circulars is not sufficient and implementation has to be ensured.

The MSEB is directed to provide separate meters for Domestic Supply to Railways and bill accordingly – In this case too, the MSEB has cited the issuance of a Circular to justify the compliance.

The MSEB is directed to disconnect Supply to consumers who have arrears amounting to over 75 days of average billing – the MSEB has not implemented this directive in the true spirit.

The MSEB is directed to reduce T & D losses to 26.87% - The performance of the MSEB in this regard and the Commission’s treatments of the same have been discussed in detail in subsequent sections.

The MSEB is directed to Implement DSM Schemes – MSEB has only involved MEDA to conduct studies on DSM but has not come up with concrete schemes for implementing DSM

The MSEB is directed to levy Reliability Charges for HT industry - MSEB has not implemented this directive. The Commission’s analysis of this issue has been discussed in detail in a subsequent Section.

The MSEB is directed to discontinue Average Billing - MSEB has continued to issue bills based on average consumption.

The MSEB is directed to take all possible steps to reduce incidences of Load Shedding – The extent of load shedding has not reduced and has in fact increased over the past two years

The MSEB is directed to reduce outstanding receivables to 5 months of billing – The outstanding arrears have increased over the past two years

The MSEB is directed to start maintaining Voltage-level wise asset classification data to enable the computation of the consumer-wise cost to serve.

The MSEB is directed to levy LD-1 tariff for connections where Railways have already paid segregation charges with effect from date of initial commitment by MSEB.

The MSEB is directed to segregate the residential connections in case of existing common connections for domestic and commercial purposes, and levy LD-1 tariff on such residential accommodations.



The MSEB is directed to take all possible measures to maintain the voltages within the prescribed limits, and to limit the load shedding hours to the minimum.

The MSEB is directed to install ToD meters for all consumers with a connected load of over 20 kW byDec’2004, so that ToD tariffs can be availed by these consumers at their option. Such ToD meters will be read every billing cycle for all parameters and monthly-consolidated information shall be submitted by MSEB to monitor the trend.)

The Commission reiterates its directive to MSEB to submit subsequent Tariff Petitions after certification by a Cost Accountant.

MSEB is directed to complete the industrial engineering study and submit the new norms within six months.

The MSEB is directed to achieve the T&D loss reduction target as well as the metering targets. The monitoring of the circle-level losses must continue and the MSEB should continue to submit the circle-level energy accounting data on a monthly basis, and circles should operate on ‘profit centre’ basis.

The Commission hereby reiterates its earlier directive to the MSEB to achieve 100% metering of LT agriculture consumers at the earliest, assigning priority to the appropriate DTC metering and close monitoring to arrive at statistically significant output for assessed agricultural consumption, and operating hours

MSEB is directed to submit Circle-wise estimates of pump-running hours of unmetered agricultural consumers on a quarterly basis. The first such report (for the entire year 2003-04) should be submitted to the Commission by the end of May, 2004.

MSEB is directed to submit on a six monthly basis information on_

o Category-wise RLC.

o Circle-wise and total T&D loss level in units as well as percentage.

The first such report for the entire year 2003-04 should be submitted by the end of May, 2004 and should also include total TDL charges (Circle-wise). Subsequent reports should be submitted within 2 months of the close of the half-year. The MSEB should ensure that the meters on all transactions on and above 11 kV

network, including DTC, are provided with communication ability, eg. GSM, to enable real time monitoring of (1) Energy Flows, (2) Energy Accounting and Auditing, and (3) Capacity Utilization of Transmission Corridors. The centralized control for energy accounting and auditing should be placed at identified important regional points and load dispatch centre. The MSEB should inform the Commission on the current status and implementation schedule for the above, as well as submit periodic compliance reports. The Commission has also prescribed AMR meters in its recent Wind Order and Bagasse



Clarificatory Order. The MSEB should also take the initiative to provide all consumers with power line communication card to facilitate automation of metering and billing system.

The MSEB is directed to undertake a cost-benefit analysis of various suggestions for controlling technical portion of T&D losses and to submit to the Commission cost-benefit analysis and investment proposal.

The Commission further directs the MSEB to devise and widely publicise efforts undertaken/actions taken by MSEB to control theft of electricity, on a quarterly basis.

The Commission directs that the Order should be implemented in letter and in spirit, to ensure that the MSEB’s receivables are brought under control.

The MSEB is directed to utilise the O&M budget for the approved purpose so as to meet consumers’ expectations.

The MSEB is directed to submit a complete implementation plan for partial replacement of domestic unwashed coal with imported coal/washed coal to the extent feasible.

The MSEB is directed to submit all periodic reports, including monthly energy audit reports, billing and revenue reports on affidavit. The Commission directs the MSEB to submit all periodic reports in a consistent format.

The Commission hereby directs the MSEB to provide details on its investment plan for approval of the Commission. The Commission will evaluate all prospective investments.

The Commission directs the MSEB to come forward with concrete schemes to implement DSM in the State. The detailed plan, to promote energy efficiency at the consumer end, should be submitted to the Commission within three months of this Order.

The Commission is also very concerned about the allegations of corruption within the MSEB, and directs the MSEB to examine these and initiate strict disciplinary action against the employees found guilty of corrupt practices.

The Commission also directs that henceforth, the Commission will conduct quarterly reviews

of the MSEB’s compliance of the directives. The MSEB’s senior officers would be expected

to attend these compliance review meetings. Further, in case the MSEB desires any

clarification on any directive issued by the Commission, the MSEB should request such

clarification within a month of the directive being issued, failing which it will be assumed that

the MSEB does not require any clarifications, and the MSEB will be required to comply with

the directives expeditiously, both in letter and in spirit.



26. PROJECTED ENERGY INPUT REQUIREMENT

The energy input required by the MSEB is the summation of the total sales and the T & D

loss allowed by the Commission.

26.1 Sales Projections

The Commission has applied the same methodology used in the previous Tariff Orders to

project the category-wise sales. The sales to metered category of consumers have been

projected by applying the ten-year Compounded Annual Growth Rate (CAGR) over the base

sales to the respective category in FY 2002-03, except in cases where no visible trend was

noticed or where the sales projected by the Commission was almost the same as that projected

by the MSEB. In such cases, the Commission has accepted the sales projected by the MSEB.

The sales in FY 2002-03 have been adjusted for the loss in sales due to load shedding as

submitted by the MSEB, and the 10 year CAGR has been applied to the total sales, including

the assessed loss in sales due to load shedding. The sales to un-metered category of

consumers have been projected by multiplying the consumption norm with the projected

connected load for that category in FY 2003-04. The number of consumers in different

categories has been projected based on the ten-year CAGR, along the same lines as the

projection of metered consumption.

The category-wise sales have been apportioned to different slabs on the same basis as the

average monthly slab-wise sales over the past 4 years, viz. FY 1999-00 to FY 2002-03. The

number of consumers in different slabs has also been projected in the same manner. In case of

HT consumers, the sales in different time slots have been apportioned to different ToD slots

based on the actual ToD consumption pattern exhibited by these categories in FY 2002-03.

The categories and the category-wise sales projections have been summarised below, and

discussed in detail subsequently.

26.1.1 LT Category

The total sale to the LT consumer category has been summarized in the Table below. The

total sale to LT category projected by the Commission is lower than that projected by the

MSEB due to the fact that the Commission has applied the revised norm of 1300

hours/HP/year for LT agricultural consumption, based on the analysis discussed in the



pervious Section. The Commission’s sales projections for other categories have been higher

than that projected by the MSEB.

Projected Sales to the LT Category (FY 2003-04) (in MU)

Category MSEB Projections – FY 2003-04*

Actual Sales – FY 2002-03$

10 year CAGR

MERC Estimate – FY 2003-04

Domestic 7863 8087 8.58%*** 8781

Non-domestic 1763 1812 7.85%*** 1954

LTP-G (incl Power loom)

3294 3411 3640

Public Water Works

481 473 481

Agriculture (including Poultry)

10145 9645 7787$$

Street Lighting 567 589 7.85%*** 635

Temporary 0 11 0

Total LT Category 24113 24028 23278

Note: * - Without Load Shedding

$ - After accounting for loss in sales due to Load shedding $$ - Revised norm of 1300 hrs/HP/year *** - including un-met sales as submitted by the MSEB on account of load shedding

It should also be noted that the Commission has not considered any loss in sales on account of

load shedding, as the merit order simulation conducted by the Commission based on the T&D

loss levels allowed by the Commission and energy input requirement shows that there is

enough energy available to meet all the requirement. In this context, the Commission notes

that its directives on online monitoring of power flow for appropriate energy accounting and



upgrading of on-line information database in its first Tariff Order are yet to take effect. Till

date various field feeders are not automatically monitored and/or controlled from the LDC.

LDC operates on a roster schedule drawn up based on field report. Therefore, the element of

judgement can have substantial errors and omissions though MSEB is trying to justify the

same unnecessarily from time to time. It is essential for MSEB to clarify and rationally

establish the load shedding figures and energy loss due to such load shedding.

The MSEB should analyse consumer category-wise demand curve on a broader basis so as to

arrive at the projected integrated load curve, since it is possible that the connected load

figures are a major source of inaccuracy, and cannot be the representative base for the load

shedding, units lost and demand projections, resulting in anomalous projections at times.

The category-wise sales projections, slab structure and slab-wise consumption have been

discussed below:

Domestic Category

The Commission has reduced the number of slabs in this category, from four slabs to three

slabs, by clubbing two consumption slabs, viz. 31-300 units and 101-300 units. The estimated

slab-wise consumption is given below. It should be noted that the slab-wise consumption

indicated in the Table below is the total consumption by all consumers in that slab, and not

the consumption of consumers falling within that slab only. For instance, in the Table below,

the consumption of 3583 MU indicated against the slab of 1-30 units includes the

consumption of consumers falling in the slab 1-30 units, as well as the consumers falling

within the higher slabs.

Domestic Category: Slab-wise consumption (in MU)

Monthly Consumption


1 – 30 units 3583 31 – 300 units 4352 Above 300 units 846 Total 8781



Non-domestic Category

The Commission has retained the three slabs in this category, as shown below:

Non-domestic Category: Slab-wise consumption (in MU)

Monthly Consumption


1 – 100 units 827 101 – 200 units 259 Above 200 units 868 Total 1954

LTP-G Category

This category has two sub-categories, viz., LT industrial and power loom category. The

Commission had merged the power loom category with the LT industrial category in the

previous Tariff Order. At that time, most of the power loom consumers were un-metered, and

hence, the Commission has specified, both metered tariffs and un-metered tariffs, for this sub-

category. Subsequently, all the power loom consumers have been metered, and the MSEB has

submitted the metered consumption of this category.

The Commission has reduced the number of slabs within LTP-G category from three to two,

by merging the last two slabs, viz. 1001-15000 units slab and the slab for over 15000 units.

The projected slab-wise consumption has been given in the following table:

LTP-G Category: Slab-wise consumption (in MU)

Monthly Consumption


LT Industrial* 1 – 1000 units 1668 Above 1000 units 1973 Total 3641

Note: * - includes power loom metered consumption



Public Water Works (PWW) Category

This category has two sub-categories, viz., Urban PWW and Rural PWW. The entire

consumption in this category is metered. The rural PWW category has further sub-classes,

viz. Grampanchayat and ‘C’ Class Municipal Councils. The projected consumption of the

different categories is as follows:

Public Water Works Category: sub-category-wise consumption (in MU)

Sub-Category MERC Estimate – FY 2003-04

Urban PWW 35.60 Rural PWW Gram Panchayat 149 Other rural PWW, incl ‘C’ Class Municipal Council

297

Total 481.60

Agricultural Category

A major portion of the consumption in this category is un-metered, and is charged on flat rate

basis. The consumption norm for un-metered LT agricultural consumption has been discussed

in detail in the earlier section on T & D loss. The Commission has applied this consumption

norm of 1300 hours/HP/year to assess the consumption from the un-metered category.

The MSEB has also projected a certain shift in connected load from the un-metered category

to the metered category in FY 2003-04, and has projected the metered consumption on the

basis of the existing metered consumption and the additional metered load. The Commission

has considered the shift in connected load from un-metered to metered, as considered by the

MSEB. In the Section on T&D loss and energy audit of LT agricultural consumption, the

Commission has discussed the consumption pattern of metered agricultural consumers, and

the fact that the consumption of metered consumers is lower than that of un-metered

consumers. However, on analysis of the consumption projected by the MSEB for metered

LT agricultural consumers, the Commission has found that the MSEB has projected



substantially higher consumption by the metered consumers, at around 990 hours/HP/year.

The average consumption norm of metered agricultural consumers is around 500

hours/HP/year. This overestimation leads to underreporting of the T&D losses. The

Commission has hence projected the consumption of metered agricultural consumers on the

basis of the consumption norm of 500 hours/HP/year.

The Commission has attempted to determine the flat rate tariffs for agriculture category such that the tariffs reflect the actual consumption pattern. The Commission has created two sub-categories within the un-metered category, viz. first sub-category comprising circles with a consumption norm lower than the average norm of 1300 hours/HP/year, and the second sub-category comprising circles with a consumption norm higher than the average norm of 1300 hours/HP/year.

LT Agriculture Category: sub-category-wise consumption (in MU)

Sub-Category MERC Estimate – FY 2003-04 Flat Rate Tariff 6893 Circles with consumption norm < 1300 hours/HP/year

4480

Circles with consumption norm > 1300 hours/HP/year

2413

Metered Tariff* 865 Total 7757

Note: * - includes LT Poultry

Street Lighting Category

The Commission had merged the Grampanchayats and the ‘A’, ‘B’ and ‘C’ class

Municipal Councils into one sub-category. The projected sales have been apportioned to

the sub-categories based on the actual average consumption during FY 1999-00 to FY

2002-03, as follows:



Street lighting Category: sub-category-wise consumption (in MU)

Sub Category MERC Estimate – FY 2003-04

Grampanchayats and Municipal Councils

357

Municipal Corporation Areas

278

Total 635

26.1.2 HT Category

Projected Sales to the HT Category (FY 2003-04) (in MU)

Category MSEB Projections – FY 2003-04*

Actual Sales – FY 2002-03$

10 year CAGR


HTP-I 6644 6482 2% 6644 HTP-II 6217 6066 6217 HTP-III (PWW) 637 607 1.6% 637 HTP-IV (PWW) 394 376 7.8% 394 HTP-V (Railway Traction)

980 934 4.3% 980

HTP-VI 310 292 310 HTP-VII (Agri. & related categories)

582 552 582

Mula Pravara 638 631 5.7% 667 Inter-State 0 18 0 Total HT Category 16402 15958 16431

The total sales to the HT consumers have been summarized in the above Table. The sale

projected by the Commission is marginally higher than that projected by the MSEB on

account of the higher sales projected for Mula Pravara. For the other categories, the MSEB’s



projections have been accepted as they are in line with the CAGR and the Commission’s

projections. The Commission has already presented the ToD consumption pattern for the

different HT categories in earlier sections, while detailing the philosophy on ToD tariffs.

26.1.3 Total Sales

The Commission has thus projected the total sales in FY 2003-04 as 39710 MU.

26.2 Energy Audit Analysis and T&D Losses

The MSEB has submitted data corresponding to the Energy Audit Studies undertaken by it in

FY 2001-02 and FY 2002-03 across number of zones/circles and at various voltage levels.

The findings of the Energy Audit study have been reported under the following five

categories depending on the voltage level of the feeders and the category of consumers

served:

LT – Agriculture feeders MIDC feeders Express feeders EHV level feeders Division level feeders

26.1.4 Approach and Methodology for Analysis

The Commission has analysed the entire data compiled and presented by the MSEB,

corresponding to each of the above categories in terms of the sample size, sample coverage,

and sample characteristics together with the limitations thereof.

For the purpose of analysis, the sample data provided by the MSEB was further filtered. For

example, in case of some of the feeders, very few data readings (say two readings

corresponding to two months) were available. The Commission is of the opinion that, to be

able to judge consistency or draw any inference regarding consumption pattern, at least 10 to

12 months data should be available, as the consumption pattern varies across the season.

Hence such data readings were ignored for the purpose of analysis. Accordingly, filtering

criteria for considering sample reading for data analysis was determined for each category, as

elaborated subsequently.



26.1.5 Output Parameters for Analysis

For LT – Agriculture feeders

The MSEB has a sizeable number of unmetered agricultural consumers of around 18 lakh. As

a result, it is very critical that the consumption of this category is estimated as accurately as

possible. The accuracy of estimation for this category would determine the accuracy of

estimation of T&D losses as well, as this is the only un-metered category. The purpose of the

Energy Audit data analysis for the LT-Agriculture feeders was: -

1. To evaluate the norm for operating hours per HP per annum and estimate the consumption of the LT-agricultural category in the State.

2. To observe variation, if any, in the operating norm across zones, circles and divisions.

For all other feeders (MIDC level, Express feeders, EHV level, Division level)

The objective of the Energy Audit data analysis for all other feeders was: -

3. To assess loss level on zone/circle basis. 4. To monitor trend in loss level. 5. To highlight zones/circles that report higher level of losses consistently.

26.1.6 Analysis

LT – Agriculture Feeders

Sample characteristics (sample size, sample coverage, and sample limitation)

The MSEB has broadened the Energy Audit sample to cover 4,668 LT-Agricultural feeders as

compared to 1,701 feeders in FY 2000-01. The sample covered six (6) zones and twenty-five

(25) circles. The zones covered were Amravati, Aurangabad, Beed, Kolhapur, Nashik and

Nagpur. Out of the average total connected load of 76.8 lakh HP reported under LT-

Agricultural category, around 0.77 lakh HP was sampled during FY 2001-02 and out of the

average total connected load of 75.6 lakh HP reported under LT-Agricultural category,

around 1.5 lakh HP was sampled during FY 2002-03. This represents a sampling ratio of 1%

and 2% for FY 2001-02 and FY 2002-03, respectively. There has been an improvement in

sampling as compared to 0.4 % in FY 2000-01. The zones wherein sample energy audits

have been conducted account for 95 % of the connected load in the State. Uncovered zones



such as Kalyan, Konkan, Pune (U), Nagpur (U), Bhandup (U) represent only the balance 5%

of the total connected load of the State.

In this context, there have been discussions regarding the sampling pattern applied by MSEB,

and whether the sampling pattern follows accepted statistical sampling techniques. The

Commission is of the opinion that though the sampling has not been done properly, there is

no alternative but to use the available sampling data to assess the LT agricultural consumption

in the State. Ideally, the entire consumption should have been metered, had the MSEB met its

own commitments given in earlier Tariff Petitions under affidavits and adhered to the

directives of the Commission in earlier Tariff Orders. In the absence of 100% metering, the

Commission has been constrained to proceed based on the data submitted by the MSEB.

The information provided corresponding to particular feeders included zone name, circle

name, village name, transformer number, meter serial number, number of pump sets

connected, connected load, and the consumption recorded over a period. The MSEB has

submitted readings for FY 2001-02 and FY 2002-03. The time period covered by the readings

vary from one month to twelve months during a Financial Year.

Based on this information, average consumption per month and average consumption per HP

per month for a particular feeder was computed. The MSEB has confirmed that the feeders

covered under the study expressly catered only to LT-agricultural load. The consumption in

terms of energy units was measured on the LT side of the distribution transformer.

Filtering criteria

For the purpose of the analysis, the Commission has continued with the filtering criteria

adopted in the previous Order. The Commission has considered only those feeders for which

the readings were reported for a period of at least.300 days (i.e. data readings for at least 10

months). The rationale for setting 300 data readings as the filtering criteria was to account for

the seasonal variations in the consumption pattern, since the annual operating norm per HP is

being assessed. The number of qualified readings exceeding 300 days of monitoring, has

improved from 755 in FY 2000-01 to 1,742 in FY 2001-02 and 3,770 in FY 2002-03.



These qualified readings were categorised into various intervals of operating hours/HP/annum

as shown in the Table below. The terminal data readings that corresponded to less than 300

operating hours/annum (i.e. less than 1 operating hour/day) and those greater than 3,000

operating hours/annum (i.e. greater than 8 operating hours/day) were ignored and the balance

data was considered for the analysis. The Commission has applied this filter to consider only

those readings which are representative of the usage by LT-agricultural consumers. Any over

or under usage could be attributable to several other reasons such as error in reading,

operational problem with meter, use for purpose other than agricultural pump, etc. To remove

a bias arising of such readings, all readings outside the filter have been ignored. The

Commission has continued with the same filter that was used in the last Order despite a

request from the MSEB to consider readings upto 3,600 operating hours/HP/annum as the

Commission is of the opinion that any usage over and above 3,000 operating hours/HP/annum

may not be representative of LT-agricultural consumption. With the application of this filter,

the total number of sample readings available for arriving at the norm for LT-agricultural

consumption has reduced to 1,352 (29% of sample reading data set) in FY 2001-02 and 2,833

(61% of sample reading data set) in FY 2002-03. This represents an improvement over 586

readings (34% of sample reading data set) available in FY 2000-01.

Table: Categorisation of LT-Agricultural Feeder Readings for FY 2001-02

Operating Hours/ HP/Annum

Nagpur Nashik Auran-gabad

Amra-vati

Kolha-pur

Beed No. of data

readings <=300 35 46 1 21 22 8 133 300<hrs<=700 48 82 16 55 71 33 305 700<hrs<=1100 30 62 25 68 72 49 306 1100<hrs<=1500 13 71 24 56 57 38 259 1500<hrs<=1900 10 55 13 38 54 24 194 1900<hrs<=2300 6 33 9 17 43 22 130 2300<hrs<=2500 5 20 3 6 11 14 59 2500<hrs<=3000 2 34 15 8 17 23 99 3000<hrs<=3600 1 36 6 2 24 9 78 >3600 6 86 11 21 44 11 179





Amra-vati

Kolha-pur

Beed No. of data

readings Total Data Readings

156 525 123 292 415 231 1742

Data Readings between 300 hrs and 3000 hrs

114 357 105 248 325 203 1352



Table: Categorisation of LT-Agricultural Feeder Readings for FY 2002-03



Amra-vati

Kolha-pur

Beed No. of data

readings <=300 99 19 4 81 90 19 312 300<hrs<=700 230 61 22 160 130 25 628 700<hrs<=1100 135 103 26 145 121 57 587 1100<hrs<=1500 76 116 42 105 102 36 477 1500<hrs<=1900 45 110 37 75 103 42 412 1900<hrs<=2300 50 86 35 48 72 39 330 2300<hrs<=2500 12 43 16 19 32 18 140 2500<hrs<=3000 16 80 20 41 52 50 259 3000<hrs<=3600 16 84 24 19 48 9 200 >3600 28 189 17 65 102 24 425 Total Data Readings

707 891 243 758 852 319 3770

Data Readings between 300 hrs and 3000 hrs

564 599 198 593 612 267 2833

Observations

The summary of the Commission’s analysis is reported under the following Table.

Circle-wise Assessment

The circle-wise assessment for FY 2001-02 and FY 2002-03 is presented in the Tables below:



Table: Circle-wise Summary for FY 2001-02

Zone Circle No. of pumps

Connected load of the

sample (HP)

Average consumption/month/HP

(Units)

Average operating hours/HP/

annum Nagpur Wardha 1,719 1,481 48.05 773 Bhandara 1,680 2,256 74.67 1,201 Chandrapur 1,089 171 87.12 1,401 Gadchiroli 832 195 34.31 552 Nagpur ® 3,081 1,441 43.35 697 Nashik Ahmednagar 2,073 2,360 77.58 1,248 Nashik 4,391 7,713 95.93 1,543 Dhule 2,399 3,706 70.43 1,133 Jalgaon 4,248 6,570 77.38 1,245 Aurangabad Parbhani 1,174 1,622 103.30 1,662 Aurangabad 1,744 2,994 77.36 1,244 Jalna 1,351 1,695 81.74 1,315 Amravati Buldhana 2,127 3,195 69.28 1,114 Akola 1,859 2,445 80.29 1,292 Amravati 2,770 4,367 75.20 1,210 Yavatmal 2,056 2,571 65.97 1,061 Kolhapur Solapur 1,611 2,586 76.44 1,230 Kolhapur 2,579 4,494 82.41 1,326 Sangli 4,168 4,072 84.67 1,362 Pune ® 1,133 3,233 80.30 1,292 Satara 3,357 6,143 71.44 1,149 Beed Osmanabad 1,041 3,428 81.51 1,311 Nanded 1,497 2,668 89.58 1,441 Beed 962 1,806 71.47 1,150 Latur 1,652 3,741 99.69 1,604



Table: Circle-wise Summary for FY 2002-03

Zone Circle No. of pumps

Connected load (HP)

Average consumption/month/HP

(Units)

Average operating hours/HP/

Annum Nagpur Wardha 1,716 5,483 50.98 820 Bhandara 2,003 5,197 81.67 1,314 Chandrapur 1,105 2,828 57.93 932 Gadchiroli 912 3,781 69.69 1,121 Nagpur ® 3,240 9,600 59.74 961 Nashik Ahmednagar 2,091 3,421 106.89 1,719 Nashik 4,139 9,876 108.05 1,738 Dhule 2,361 7,045 94.05 1,513 Jalgaon 4,003 11,021 86.62 1,393 Aurangabad Parbhani 1,411 3,899 100.82 1,622 Aurangabad 1,630 4,909 95.47 1,536 Jalna 853 2,142 89.42 1,438 Amravati Buldhana 2,160 6,654 74.84 1,204 Akola 2,086 7,204 70.57 1,135 Amravati 2,732 8,533 70.13 1,128 Yavatmal 2,209 6,566 78.73 1,266 Kolhapur Solapur 5,477 3,749 83.15 1,338 Kolhapur 3,957 10,024 86.17 1,386 Sangli 5,022 11,416 105.90 1,703 Pune ® 2,911 3,418 74.40 1,197 Satara 4,526 12,709 78.49 1,263 Beed Osmanabad 1,058 3,662 84.94 1,366 Nanded 1,529 3,289 107.33 1,726 Beed 857 2,009 78.40 1,261 Latur 1,502 5,816 105.23 1,693

As evident from the above Tables, the average operating hours per HP per annum varied

from 552 (for Gadchiroli circle) to 1,662 ( for Parbhani circle) in FY 2001-02. In FY 2002 -

03, the average operating hours per HP per annum varied from 719 (for Wardha circle) to



1,738 (for Nashik circle). In the Table below, the Commission has summarized its analysis of

the trend in consumption pattern in these circles over FY 2001-02 and FY 2002-03.

Table: Norm (Operating Hours/HP/Annum) across circles over financial years

Zone Circle MSEB Proposal Commission’s Assessment FY 01-02 FY 02-03 FY 00-01 FY 01-02 FY 02-03 Nagpur Wardha 737 737 829 773 820 Bhandara 1,303 1,443 1,781 1,201 1,314 Chandrapur 2,102 1,024 943 1,401 932 Gadchiroli 994 1,159 1,483 552 1,121 Nagpur (Rural) 751 1,018 1,051 697 961 Nashik Ahmednagar 1,693 1,817 1,651 1,248 1,719 Nashik 1,805 1,723 1,699 1,543 1,738 Dhule 1,410 1,698 1,431 1,133 1,513 Jalgaon 1,446 1,495 1,325 1,245 1,393 Aurangabad Parbhani 1,782 1,767 1,456 1,662 1,622 Aurangabad 1,255 1,664 1,276 1,244 1,536 Jalna 1,373 1,420 847 1,315 1,438 Amravati Buldhana 1,335 1,220 875 1,114 1,204 Akola 1,273 1,197 1,021 1,292 1,135 Amravati 1,308 1,284 1,085 1,210 1,128 Yavatmal 1,156 1,398 1,085 1,061 1,266 Kolhapur Solapur 1,426 1,695 1,205 1,230 1,338 Kolhapur 1,436 1,444 1,313 1,326 1,386 Sangli 1,694 2,000 1,358 1,362 1,703 Pune (Rural) 1,551 1,514 NA 1,292 1,197 Satara 1,179 1,396 1,175 1,149 1,263 Beed Osmanabad 1,501 1,493 719 1,311 1,366 Nanded 1,562 1,810 1,462 1,441 1,726 Beed 1,408 1,256 747 1,150 1,261 Latur 1,706 1,604 1,324 1,604 1,693

Comparison of the assessed consumption norm over these 3 years throws up several

interesting results.



Average operating hours per HP per annum for some circles such as Wardha, Nashik, Jalgaon, Parbhani, Amravati, Solapur, Kolhapur and Satara have demonstrated a consistent trend over 3 years.

Though the Commission has assessed the norm for FY 2002-03 at 1,455 operating hours/HP/annum against the MSEB’s Proposal of 1,576, the circle-wise norm for most circles except for Solapur, Sangli and Pune (Rural) follows almost the same trend as that of MSEB’s Proposal.

Average operating hours per HP per annum for some circles such as Chandrapur, Gadchiroli, Nagpur (Rural), Ahmednagar, Dhule have demonstrated a contradictory trend over 3 years. A substantial reduction (increase) in the norm was observed during FY 2001-02 and again a substantial increase (reduction) in the norm was observed during FY 2002-03. It is also pertinent to note that the sampled load had increased substantially for these circles during FY 2002-03. The increase in sampled load could partly explain this contradictory trend.

Some of the circles such as Bhandara, Jalna, Buldhana, Akola, Osmanabad and Beed have demonstrated substantial change in trend between FY 2000-01 and FY 2001-02. However, these circles have maintained the trend of FY 2001-02 in FY 2002-03. The substantial change in FY 2001-02 could be attributable to an improvement in sample quality and consequent better representation of agricultural load of the circle.

The consumption in most circles in FY 2002-03 has been higher than that assessed for FY 2000-01 and FY 2001-02. This may be attributed to the drought prevailing in most areas of the State in FY 2002-03. The Commission has also assessed the consumption pattern of metered LT agricultural consumers, to see if the same trend is seen in their consumption too. The analysis has shown that in the case of metered LT agricultural consumers too, the consumption norm is higher in FY 2002-03 as compared to FY 2000-01 and FY 2001-02.

Zone-wise/State-wide Assessment

The zone-wise norm of operational hours/HP/annum can be arrived at by multiplying circle-

wise norm with the weights of the connected load of each circle. Similarly the State-wide

norm can be derived by multiplying zone-wise norm with the weights of the connected load

of each zone.

The zone-wise norm would be true representative of a zone, if all the circles were given due

representation in the chosen sample. In this connection, it is important to understand the



sampling characteristics adopted by the MSEB. The following Table analyses the sampling

coverage across circles:

Table: Analysis of sampling coverage across circles

Sample % No. of circles Name of circles <1% 4 Aurangabad, Osmanabad, Pune ®, Solapur 1%-3% 11 Ahmednagar, Beed, Sangli, Dhule, Jalna, Jalgaon, Latur,

Nanded, Nashik, Parbhani, Satara 3%-5% 4 Amravati, Buldhana, Kolhapur, Nagpur ® 5%-10% 5 Akola, Bhandara, Gadchiroli, Wardha, Yavatmal >10% 1 Chandrapur

From the Table, it is evident that sampling was non-uniform and sample does not exhibit the

characteristics of a statistically random sample and hence does not truly represent the sample

of LT-agricultural load in the zone/State. Out of 25 circles being monitored, only 11 circles

were close to the average of 2%.

If the zonal/State level norm is worked out based on the connected load of the sample, the

norm would get influenced by the norm of the circles having higher representation in the

sample. To avoid this sampling bias, zonal average has been derived based on total connected

load in the circle instead of the connected load of the sample of the circle.

For the circles, where sampling was not carried out, the MSEB has proposed the norm of

737.37 hours/HP/annum for FY 2001-02 and 831 hours/HP/annum for FY 2002-03. The

Commission has considered the same norms in the absence of any other data available for

validation. As only 5% of the connected load across the State was not sampled, it would have

little impact on the State-wide norm.



Table: Zone-wise Summary for FY 2001-02

Zone Total connected load averaged during the financial year (HP)

Average consumption/month/

HP (units)

Average operating hours/HP/annum

Nagpur 3,18,778 56.09 902 Nashik 23,38,708 81.94 1,318 Aurangabad 8,86,960 86.09 1,385 Amravati 5,76,677 72.09 1,160 Kolhapur 24,56,067 78.79 1,267 Beed 11,05,983 84.90 1,366 Others 1,23,937 45.84 737.37 Total 78,07,110 80.20 1,290

Table: Zone-wise Summary for FY 2002-03

Zone Total connected load averaged during the financial year (HP)

Average consumption/month/

HP (units)

Average operating hours/HP/annum

Nagpur 3,05,394 64.59 1,039 Nashik 22,98,199 100.57 1,618 Aurangabad 8,87,326 95.49 1,536 Amravati 6,05,135 73.61 1,184 Kolhapur 23,66,352 84.27 1,355 Beed 11,02,557 93.15 1,498 Others 93,203 54.15 871 Total 76,58,166 90.45 1,455

As evident from the above Tables, the average operating hours per HP per annum varied from

902 (for Nagpur zone) to 1,385 (for Aurangabad zone) in FY 2001-02. In FY 2002-03, the

average operating hours per HP per annum varied from 1,039 (for Nagpur zone) to 1,618 (for

Nashik zone). In the Table below, the Commission has summarized its analysis of the trend in

consumption pattern in these zones over FY 2001-02 and FY 2002-03.



Table: Norm (Operating Hours/HP/Annum) across zones over financial years

Zone MSEB Proposal Commission’s Assessment

FY 01-02 FY 02-03 FY 00-01 FY 01-02 FY 02-03 Nagpur 1,024 1,115 1,178 902 1,039 Nashik 1,610 1,696 1,488 1,318 1,618 Aurangabad 1,417 1,625 1,300 1,385 1,536 Amravati 1,252 1,274 1,002 1,160 1,184 Kolhapur 1,442 1,629 1,258 1,267 1,355 Beed 1,569 1,526 1,281 1,366 1,498 Others 737.37 871 737.37 871 Total 1,477 1,576 1,244 1,290 1,455

Unlike the circle-wise norm, the zone-wise norm demonstrates a relatively consistent

consumption level across the years, except for Nashik, Nagpur and Beed, where the

consumption has increased over the years. Individual aberrations at the circle levels have been

averaged out at the zonal level.

Inference

1. The sampling coverage across circles is non-uniform and the sample does not represent a

statistical random sample. For arriving at a zone-wise and the State-wide norm, the

sampling bias was countered by using total connected load of the circle in place of the

connected load of the sample in the circle.

2. The MSEB should improve the quality of the sample using random sampling techniques

and make sample more representative of the LT-agricultural load in the circle/zone/State.

3. Based on the analysis of furnished data, it can be deduced on aggregate basis that the

average operating hours per HP per annum for LT-agricultural consumption was 1,290 in

FY 2001-02 and 1,455 in FY 2002-03.

4. For LT-agriculture metered category for FY 2001-02, the MSEB has reported total

consumers at 2.8 lakh, connected load at 10,58,028 HP and sales at 387 MU. This

translates to a norm of 491 operating hours/HP/annum. Similarly, for FY 2002-03, the

MSEB has reported total consumers at 3.5 lakh, connected load at 13,98,825 HP and



sales at 604 MU. This translates to a norm of 579 operating hours/HP/annum. This is

logical, as only those consumers whose consumption is substantially lower would opt for

metering under the Optional Regime.

5. Increase in operating hours per HP per annum in FY 2002-03 over FY 2001-02 is

apparent across most circles. MSEB has projected 7% increase in average operating hours

per HP per annum for FY 2002-03. The Commission has assessed the same at 13%, based

on its analysis of the energy audit data. Even LT-agriculture metered category has

demonstrated 18% increase in average operating hours per HP per annum in FY 2002-03.

The agricultural consumption could vary with several factors such as district-wise rainfall

pattern, timing of rainfall, ground water level, cropping pattern, etc. The increase in

consumption in FY 2002-03 seems to be attributable to the effect of a “Drought Year”.

Because of a drought during FY 2002-03, water levels would have gone down resulting in

increase in average operating hours for LT-agricultural consumption. The average

operating hours of 1,290 for FY 2001-02 was in line with the assessment of average

operating hours of 1,244 for FY 2000-01. The change in FY 2001-02 could have been

attributable to improved sampling coverage of 1%. Based on this, the Commission is of

the opinion that the circle-wise norm for FY 2001-02 is more representative of the LT-

agricultural consumption amongst the three financial years.

6. In this context, it is interesting to note the following observations that have been made in

the objections filed against MSEB’s Tariff Petition:

Average operating hours is dependent on variety of factors such as crop category, distance of field from water source, season, etc. Higher connected load (HP) does not necessarily mean higher operating hours and higher consumption.

The MSEB’s assessed consumption norm for LT irrigation pumps does not take into account actual hours of availability of water due to prescribed rotation and allowed hours for lifting water and correspondingly appears to be on higher side.

To improve the estimate of agriculture consumption, data on crops and water source in the sample areas, should be collected. A census of agricultural pumps in the State should also be conducted.

The MSEB should ensure monthly readings of all distribution transformers being sampled for assessment of agricultural consumption.



In the previous tariff process for FY 2001-02, the MSEB had submitted energy audit data of

1,701 feeders, and the consumption norm used for assessing LT-agricultural consumption in

FY 2001-02 was 1,250 hours per HP per annum. The estimate was arrived at on a ‘best effort’

basis, based on the available data. The MSEB has increased the sample size to 4,668 feeders,

which is a relatively larger and more representative sample, and the Commission is of the

opinion that the estimate based on the larger sample is more realistic. Based on the 4,468

feeders, the MSEB has assesssed a consumption norm of 1,477 hours per HP per annum and

1,576 hours per HP per annum for FY 2001-02 and FY 2002-03, respectively. The

Commission, based on the methodology explained in this Section, has assessed the LT-

agricultural consumption norm at 1,290 and 1,455 operating hours per HP per annum for FY

2001-02 and FY 2002-03, respectively. The Commission has already discussed the rationale

for considering the assessed consumption norm in FY 2001-02 as relatively more

representative of LT-agriculture consumption in the State. Hence, the Commission has

considered an average consumption norm of 1300 hours/HP/annum to estimate the

consumption of unmetered LT-agricultural consumers for FY 2003-04.

The Commission has attempted to determine the flat rate tariffs for the LT-agricultural

category such that the tariffs reflect the actual consumption pattern. To start with, the

Commission has specified two categories of circles, viz. circles with consumption norm lower

than the average consumption norm of 1300 hours/HP/year, and circles with consumption

norm higher than the average consumption norm of 1300 hours/HP/year. This is intended as a

signal to the higher consumption circles that their consumption is higher and hence, they

should pay a higher flat rate tariff. In case, agricultural consumers in these areas feel that their

consumption is lower, then they should opt for metering and pay the tariff applicable to

metered consumers. The following Table summarises the information for these two categories

of circles:



Table: Categorisation of circles for structuring differential flat rate tariff for LT-

agricultural consumers

Slab based on average operating hours/HP/annum

Total average connected load during the FY

(HP)

% of connected

load

No. of circles

Norm (Operating hours/HP/annum)

Hrs > 1300 hours/HP/Annum

26,60,698 35% 9 1458

Hrs<1300 hours/HP/Annum

44,97,468 65% 27 1188

Total 76,58,166 100% 36 1290

The Commission is of the opinion that, in future, the categorisation, consumption norm and

the tariff have to reflect the improved sampling coverage and the Commission’s objective of

making tariff reflective of the average cost of supply.

MIDC LEVEL FEEDERS


The MSEB has submitted Energy Audit data of MIDC level feeders for FY 2001-02 and FY

2002-03. Since FY 2002-03 represents the most recent status of Energy Audit, the data

pertaining to FY 2002-03 has been analyzed as follows:

The MSEB has submitted Energy Audit data corresponding to 81 MIDC circles spread over

11 zones and 34 circles. The zones covered were Amravati, Aurangabad, Beed, Bhandup,

Kalyan, Kolhapur, Konkan, Nagpur, Nagpur-Urban, Nashik and Pune-Urban. The

information provided corresponding to particular feeder substation included zone name, circle

name, MIDC area, energy sent out and billed energy (HT and LT) for each month. Based on

the above information, the loss for the particular feeder for each month has been reported. The

feeders covered under the study catered to LT as well as HT industrial load. The energy units

were measured on the LT side of the distribution transformer.



The feeders covered under the study have recorded total consumption of 3,822 MU and 3,724

MU at substation end and consumer end, respectively. The list of zones and circles covered

for the purpose of Energy Audit of MIDC Feeders is presented in the following Table:

Table: Coverage of MIDC feeders

Zone Circle MIDC Feeders

(No)

Zone Circle MIDC Feeders

(No) Amravati Akola 1 Konkan Ratnagiri 3 Amravati 1 Sindhudurg 1 Buldhana 2 Kolhapur Solapur 2 Yavatmal 1 Kolhapur 6 Aurangabad (U) Aurangabad ® 1 Pune ® 3 Aurangabad (U) 2 Sangli 3 Jalna 1 Satara 4 Parbhani 1 Nagpur Bhandara 2 Beed Latur 1 Chandrapur 1 Nanded 6 Nagpur ® 2 Osmanabad 1 Wardha 1 Bhandup (U) Bhandup (U) 1 Nagpur(U) Nagpur (U) 2 Bhiwandi 1 Nashik Ahmednagar 3 Vashi 6 Dhule 1 Kalyan Kalyan 5 Jalgaon 2 Pen 4 Nashik 6 Vasai 1 Pune (U) Pune (U) 3

Total: 81 MIDC feeders

Filtering criteria

All of the MIDC feeders have reported data for more than 9 months. 76 MIDC feeders have

reported data for all 12 months of the financial year. Hence, all the feeders have been

considered for the purpose of analysis.



Observations

Circle-wise/Zone-wise Assessment

The following Table aggregates the losses at the circle/zone level to identify the regions,

which have demonstrated relatively higher level of losses:

Table: Circle-wise assessment of loss level in MIDC

Zone Circle Units Sent (MU)

Loss level (%)

FY 02-03 Apr-02 to Sep-02

Oct-02 to Mar-03

FY 02-03

Amravati Akola 27 5.3% 4.7% 5.0% Amravati 19 4.8% 5.1% 5.0% Buldhana 36 3.5% 3.5% 3.5% Yavatmal 2 3.3% 3.9% 3.7% Zone total 84 4.4% 4.3% 4.3% Aurangabad (U) Aurangabad (U) 286 1.7% 1.6% 1.7% Aurangabad (R ) 35 2.9% 3.7% 3.5% Jalna 167 0.6% 0.4% 0.5% Parbhani 3 4.9% 4.7% 4.8% Zone total 492 1.4% 1.5% 1.4% Beed Latur 21 1.5% 1.2% 1.3% Nanded 40 2.8% 1.3% 2.0% Osmanabad 1 15.7% 4.8% 10.4% Zone total 62 2.7% 1.3% 1.9% Bhandup (U) Bhandup (U) 10 -0.3% 2.2% 1.0% Vashi 632 2.7% 2.6% 2.6% Bhiwandi 16 5.0% 4.0% 4.5% Zone total 657 2.7% 2.7% 2.7% Kalyan Kalyan 228 3.6% 2.0% 2.8% Vasai 279 2.2% 2.6% 2.4% Pen 287 -0.3% 0.8% 0.2% Zone total 793 1.7% 1.8% 1.7% Kolhapur Kolhapur 203 1.7% 1.8% 1.7% Pune (R ) 95 2.0% 1.6% 1.8%



Zone Circle Units Sent (MU)

Loss level (%)

FY 02-03 Apr-02 to Sep-02

Oct-02 to Mar-03

FY 02-03

Sangli 75 3.5% 3.4% 3.5% Satara 118 3.8% 3.6% 3.7% Solapur 69 2.0% 1.6% 1.8% Zone total 559 2.5% 2.3% 2.4% Konkan Ratnagiri 56 0.4% -0.6% -0.1% Sindhudurg 4 3.6% 4.7% 4.2% Zone total 60 0.7% -0.3% 0.2% Nagpur Bhandara 5 4.6% 2.2% 3.3% Chandrapur 13 -1.6% 1.5% -0.3% Nagpur (R ) 67 0.5% 1.6% 1.0% Wardha 10 4.9% 5.2% 5.1% Zone total 94 0.8% 2.0% 1.4% Nagpur (U) Nagpur (U) 146 4.5% 2.1% 3.3% Zone total 146 4.5% 2.1% 3.3% Nashik Dhule 16 3.6% 3.9% 3.7% Jalgaon 107 8.1% 5.8% 6.9% Ahmednagar 92 6.0% 3.3% 4.6% Nashik 493 3.7% 3.8% 3.8% Zone total 708 4.7% 4.1% 4.4% Pune (U) Pune (U) 168 2.8% 3.3% 3.0% Zone total 168 2.8% 3.3% 3.0%

Amravati, Bhandup (U), Nagpur (U), Nashik and Pune (U) zones have exhibited relatively higher loss levels.

Beed, Konkan, Nagpur and Nagpur (U) zones have exhibited variation in loss levels across half yearly periods. Rest of the circles have exhibited relatively consistent loss levels across half yearly periods.

Circles having significant consumption such as Nashik, Nagpur (U), Satara, Jalgaon, Ahmednagar, Sangli, Buldhana, Aurangabad (R), Akola, Amravati, etc. have exhibited relatively higher loss levels on an annual basis.



The summary of the analysis of the annual loss levels exhibited by MIDC feeders has been

shown in the Table below: Specific MIDC feeders having abnormal loss ranges have been

identified in the Table below.

Table: Categorisation of circles according to loss level

% Loss Range No. of MIDC Areas

MIDC Areas

Below -2% 1 Ratnagiri-Konkan (-5%) -2% to 0% 4 Additional Mahad-Kalyan (-0.6%), Roha-Kalyan (-0.3%),

Chandrapur-Nagpur (-0.3%), Hadapsar-Pune, (-0.7%) 0% to 5% 68 5% to 10% 7 Jalgaon (old)-Nashik (8.8%), Jalgaon (new)-Nashik

(6.4%), Dindori-Nashik(7,7%) Above 10% 1 Osmanabad-Beed (10.4%) Total 81

Losses reported were within range of 0% to 5% for 68 MIDC areas. Balance 13 MIDC areas exhibited losses outside the band of 0% to 5%.

Though a wide variation in the loss levels was observed at the MIDC feeder level, the variation is lower when the data is aggregated at circle/zonal level. Similarly, a wide variation in loss levels was also observed in monthly reported data, which reduces if the data for half-yearly or yearly period is considered.

Inference

It is important to identify the MIDC areas that report high level of losses consistently and/or

report drastic variations in the losses.

The MSEB should analyse the reasons for the gross variations in the level of reported losses

and submit a report to the Commission along with the ‘Action Taken Report’ within 2 months

of the issue of this Tariff Order.



Express Feeders


The MSEB has submitted Energy Audit data of express feeders for FY 2001-02 and FY 2002-

03. Since, FY 2002-03 represents the most recent status of Energy Audit, the data pertaining

to FY 2002-03 has been analyzed as follows:

The MSEB has submitted Energy Audit data corresponding to 217 express feeders (total of

2,139 sample readings) spread over 11 zones covering 29 circles. The zones covered were

Amravati, Aurangabad, Beed, Bhandup, Kalyan, Kolhapur, Konkan, Nagpur-Rural, Nagpur-

Urban, Nashik and Pune-Urban. The information provided corresponding to particular feeder

included zone name, circle name, HT industrial consumer sub-station, energy sent out and

billed energy for each month. Based on the above information, the loss for the particular

feeder for each month has been reported. The feeders covered under the study catered only to

HT industrial load.

The feeders covered under the study have recorded total consumption of 4,842 MU and

4,831 MU at substation end and consumer end, respectively. The list of zones and circles

covered for the purpose of Energy Audit of Express Feeders is presented in the following

Table:

Table: Coverage of Express Feeders

Zone Circle No. of feeders

Zone Circle No of feeders

Amravati Akola 4 Konkan Ratnagiri 3 Amravati 3 Sindhudurg 2 Buldhana 2 Nagpur (U) Nagpur (U) 2 Yavatmal 5 Nagpur(R) Bhandara 6 Aurangabad Aurangabad 8 Chandrapur 15 Beed Jalna 2 Gadchiroli 2 Bhandup Nanded 3 Nagpur (R) 18 Kalyan Vashi 13 Wardha 8



Zone Circle No. of feeders

Zone Circle No of feeders

Kalyan 4 Nashik Ahmednagar 10 Pen 18 Dhule 14 Kolhapur Vasai 1 Jalgaon 5 Kolhapur 12 Nashik 13 Pune (R) 7 Pune (U) Pune (U) 20 Sangli 9 Satara 3 Total No. of Express Feeders: 217 Solapur 5

The following Table indicates the consistency of readings for feeders:

Readings reported for months

No. of feeders % of Feeders being monitored

0 to 3 38 18% 3 to 6 14 6% 6 to 9 18 8% 9 to 12 147 68% Total 217

Partial availability of readings were attributed to several reasons such as commencement of

monitoring during the financial year, meter temporarily disconnected, meter reading not

reported, meter problem, no load on meter, etc. Out of the sample of 217 feeders, monitoring

of 15 feeders has commenced during FY 2002-03. Around 31 feeders reported no readings for

continuous period of atleast 6 months during FY 2002-03.



The following Table indicates zone-wise distribution of readings:

Table: Categorisation of zone-wise readings

Zone No. of feeders

No. of readings available

Loss range

< -3% -3% to -2%

-2% to -0.5%

-0.5% to 2%

2% to 3%

> 3%

Konkan 5 30 3% 0% 7% 70% 3% 17% Bhandup 13 110 12% 8% 25% 51% 1% 3% Kalyan 23 258 2% 3% 32% 55% 7% 2% Nashik 42 388 4% 4% 18% 64% 8% 3% Kolhapur 36 275 1% 4% 26% 63% 4% 2% Pune (U) 20 215 16% 8% 21% 48% 3% 3% Aurangabad 10 99 1% 0% 11% 87% 1% 0% Nagpur® 49 467 2% 2% 14% 75% 5% 3% Beed 3 26 8% 0% 0% 92% 0% 0% Nagpur (U) 2 12 0% 0% 0% 100% 0% 0% Amravati 14 101 4% 1% 9% 86% 0% 0% Total 217 1981 4% 4% 19% 66% 5% 2%

Out of 1981 sample readings across 217 feeders, 66% of the readings were within the range of -0.5% to 2% and 85% of the readings were within the range of -2% to 2%.

Out of 11 zones, 6 zones have reported more than 66% of the readings within the loss level of -0.5% to 2%. These zones are Konkan, Aurangabad, Nagpur ®, Beed, Nagpur (U) and Amravati.

Konkan, Kalyan, Nashik and Nagpur ® have reported more than 7% of the readings with loss levels higher than 2%.

Bhandup, Kalyan, Nashik, Kolhapur and Pune (U) have reported more than 19% of the readings with loss levels between -2% to -0.5%.

Bhandup, Pune (U) and Beed have reported more than 4% of the readings with loss levels less than -3%.



Filtering criteria

The number of express feeders for which the MSEB has provided data is limited

(approximately 188-200 per month). Further, as these express feeders cater to only HT-

industrial load on dedicated basis at very high voltage levels, the loss levels as well as error in

readings should be minimal. Accordingly, the Commission has continued to consider a range

of – 0.5% to + 2% as the acceptable range for the losses (referred to as Acceptable Loss

Range).

Observations

Circle-wise/Zone-wise Assessment

The following Table aggregates the losses at the circle level to identify the regions which

were outside the acceptable loss range of – 0.5% to + 2%. The Table segregates the readings

which are outside the loss range (denoted as Category A) and the readings which are within

the loss range (denoted as Category B) and computes the loss % for both categories.

Table: Circle-wise assessment

Zone Circle Total consumption billed in MU (FY 2002-03)

Cat B/ Total

Loss % (FY 2002-03)

Total Cat A Cat B Cat A Cat B Konkan Ratnagiri 123 0 123 100% NA -0.16% Sindhudurg 1 1 0 0% 3.71% NA Zone total 124 1 123 99% 3.71% -0.16% Bhandup Vashi 231 157 74 32% -1.34% 0.35% Zone total 231 157 74 32% -1.34% 0.35% Kalyan Kalyan 149 27 122 82% 1.88% 0.60% Pen 1,119 213 907 81% 0.50% 0.45% Vasai 3 3 0 0% 2.97% 0.00% Zone total 1,272 243 1,029 81% 0.69% 0.47% Nashik Nashik 162 74 87 54% 2.61% -0.12% Ahmednagar 125 15 109 88% -0.96% -0.04% Jalgaon 24 0 24 100% NA 0.68% Dhule 49 29 20 41% -1.00% 0.29% Zone total 360 119 241 67% 1.30% 0.03%



Zone Circle Total consumption billed in MU (FY 2002-03)

Cat B/ Total

Loss % (FY 2002-03)

Total Cat A Cat B Cat A Cat B Kolhapur Kolhapur 68 15 53 78% -1.40% 0.76% Sangli 14 9 4 32% 0.23% 0.90% Pune ® 214 72 142 66% 1.51% 0.21% Solapur 45 0 45 100% NA 0.17% Satara 12 12 0 4% -1.68% 0.42% Zone total 352 108 245 69% 0.67% 0.33% Pune (U) Pune (U) 700 163 537 77% -2.49% 0.49% Zone total 700 163 537 77% -2.49% 0.49% Aurangabad Aurangabad 219 1 217 99% 2.54% 0.52% Jalna 38 0 38 100% NA 1.21% Zone total 256 1 255 99% 2.54% 0.62% Nagpur ® Chandrapur 466 77 390 84% 1.22% 0.21% Gadchiroli 38 2 35 94% -0.88% 0.05% Wardha 324 3 321 99% -0.65% 0.48% Nagpur ® 291 106 185 64% -1.17% 0.70% Bhandara 319 0 319 100% NA 0.14% Zone total 1,438 188 1,250 87% -0.17% 0.33% Beed Nanded 11 5 7 59% -4.32% 0.61% Zone total 11 5 7 59% -4.32% 0.61% Nagpur (U) Nagpur (U) 7 0 7 100% 0.00% -0.11% Zone total 7 0 7 100% 0.00% -0.11% Amravati Yavatmal 51 0 51 100% NA -0.16% Amravati 9 0 8 95% -1.08% 0.05% Akola 1 0 1 73% -1.76% 1.02% Buldhana 17 0 17 100% NA 0.91% Zone total 78 1 77 99% -1.39% 0.12% Total 4,831 985 3,846 80%

The feeders exhibiting loss levels within the acceptable range of -0.5% to 2%, account for 66% of the total feeders, and 80% of the total consumption of the express feeders sampled. Bhandup, Nashik, Kolhapur, Pune (U) and Beed zones have exhibited relatively higher consumption beyond Acceptable Loss Range. Out of these, Bhandup, Pune (U) and Beed



zones have losses below -0.5%. However, Nashik and Kolhapur zones have demonstrated loss levels within Acceptable Loss Range, which is attributable to off-setting of negative loss levels of some feeders with positive loss levels of other feeders. Following circles represented relatively higher consumption outside the Acceptable Loss Range:

Zone Circle Cat B/ Total

Loss % corresponding to Cat A

Konkan Sindhudurg 0% 3.71% Bhandup Vashi 32% -1.34% Kalyan Vasai 0% 2.97% Nashik Nashik 54% 2.61% Dhule 41% -1.00% Kolhapur Sangli 32% 0.23% Pune ® 66% 1.51% Satara 4% -1.68% Pune (U) Pune (U) 77% -2.49% Nagpur ® Nagpur ® 64% -1.17% Beed Nanded 59% -4.32% Amravati Akola 73% -1.76%

Out of the above circles, Sindhudurg, Vasai and Nashik circles have exhibited loss levels exceeding 2%. Sangli and Pune ® circles have exhibited loss levels within the Acceptable Loss Range, which was attributable to off-setting of negative losses of some feeders with positive losses of other feeders within the circle. Rest of the feeders exhibited negative loss percentage below -0.5%

The MSEB has clarified that the negative loss is attributable to following factors:

The substation end metering equipment is functioning at lower accuracy level due to high CT ratio installed, whereas the consumer end metering equipment is functioning correctly as consumer end CT ratio is selected based on its contract demand.

The bus PT is mounted at the center of the bus whereas sub-station end metering is installed in control room (minimum 100 meters away). The drop in voltage to the metering terminal leads to negative recording.

The VA burden on CT due to its long secondary cable affects the functioning.

Further, the MSEB has stated that the installation of independent metering CT and PT for

express feeder in the switchyard is not only capital intensive but also restricts its provision



due to space available in the switchyard. However, care is being particularly taken to keep

watch on the consumption of express feeders having negative loss.

Inference

The MSEB must focus on express feeders demonstrating loss levels outside Acceptable Loss

Range to identify reasons for abnormal loss level and take necessary corrective action.

Further, the Commission does not accept the reasons put forth by the MSEB to justify the

recordings of negative losses, and directs that the calibration of the meters at the sub-station

and the consumer end should be synchronised, so that there is no error in measurement due to

differences in calibration.

EHV Level Feeders


The MSEB has submitted Energy Audit data corresponding to EHV level feeders. The

information provided included energy import, energy export and loss for each month from

April 2001 to March 2003.

Observations

The following Table summarises the monthly energy received and monthly energy sent out by

the MSEB as a whole. Monthly energy received from all sources includes internal generation

net of auxiliary consumption, inter-State import and import from TPC. Monthly energy sent

out includes energy sent out to distribution, EHV consumers, Mula Pravara, export to TPC

and inter-State export. Loss at EHV level is calculated as the difference between energy

received and energy sent out.



Table: Monthly loss level

Month FY 2001-02 Month FY 2002-03 Total

Energy Receipt (MU)

Total Energy

Sent Out (MU)

% Loss Total Energy Receipt (MU)

Total Energy

Sent Out (MU)

% Loss

Apr-01 5905 5607 5.0% Apr-02 5840 5380 7.5% May-01 5900 5613 4.9% May-02 5523 5085 7.9% Jun-01 5125 4847 5.4% Jun-02 5053 4720 6.6% Jul-01 5334 4993 6.4% Jul-02 5330 4956 7.0% Aug-01 4994 4830 3.3% Aug-02 5168 4814 6.8% Sep-01 5363 5054 5.8% Sep-02 5256 4990 5.1% Oct-01 5667 5328 6.0% Oct-02 5369 4990 7.1% Nov-01 5998 5626 6.2% Nov-02 6118 5553 9.2% Dec-01 6077 5711 6.0% Dec-02 6239 5672 9.1% Jan-02 6248 5824 6.8% Jan-03 6157 5644 8.3% Feb-02 5838 5578 4.5% Feb-03 5619 5213 7.2% Mar-02 5838 5578 4.5% Mar-03 6172 5634 8.7% SUM 68289 64588 5.4% SUM 67844 62652 7.7%



The following Chart captures energy received, energy sent out and percentage loss level on

monthly basis:

26.2.3.4.1.1 Chart: Loss Level

Inference

The Energy Audit at EHV level feeders has indicated an increasing trend in losses from 5% in

April 2001 to 8.7% in March 2003. The loss levels are quite high for EHV feeders

transmitting electricity at 132 kV.

The MSEB should identify the reasons for increase in loss level and submit to the

Commission its plan to achieve reduction in loss level commensurate with the technical loss

level of the system.

Division Level Feeders


From January 2002 onwards, the MSEB has been submitting circle-wise Energy Accounting

data to the Commission, in addition to Energy Accounting data on the MIDC feeders,

express feeders and EHV feeders. The MSEB has submitted Energy Audit data

corresponding to 121 divisions across 11 zones and 36 circles. The zones covered were

Amravati, Aurangabad, Beed, Bhandup (U), Kalyan, Kolhapur, Konkan, Nashik, Nagpur,

Nagpur (U) and Pune (U). The information provided corresponding to particular feeder

01000200030004000500060007000

Apr

-01

Jun-

01

Aug

-01

Oct

-01

Dec

-01

Feb-

02

Apr

-02

Jun-

02

Aug

-02

Oct

-02

Dec

-02

Feb-

03

Ener

gy (M

U)

0.0%

2.0%

4.0%

6.0%

8.0%

10.0%

Loss

(%)

Total Energy Receipt Total Energy Sent Out % Loss



included zone name, circle name, division name, input energy, billed energy (HT and LT) and

the unmetered or assessed energy (connected load and consumption norm) for each month.

The readings have been provided for a period from April 2001 to March 2003. Based on the

above information, loss for the particular feeder for each month has been reported. The

feeders covered under the study catered to LT as well as HT load. The energy units were

measured on the LT side of the distribution transformer.

Filtering Criteria

All division level feeders have been considered for the purpose of analysis as readings were

reported for the period from April 2001 to March 2003 for all feeders.

Computation of Zone-wise/Circle-wise T&D Losses

The Commission has analysed the month-wise Energy Accounting data submitted by the

MSEB. The Commission has also analysed the Merit Order Despatch data submitted by the

MSEB to compute the energy input into the transmission and distribution network. The

transmission loss in the system has been assessed as the difference between the total energy

input as recorded in the Merit Order Despatch data and the summation of the total energy

input recorded by the different Divisions. This aggregate transmission loss has been

apportioned to the different zones/circles in proportion to their share of the energy input.

The distribution loss in each zone/circle has been computed as the difference between the

energy input and the energy billed for that zone/circle. The T&D loss of the zone/circle has

been computed as the difference between the total energy input into the circle after

apportioning the transmission loss, and the energy billed, as a percentage of the total energy

input in that zone/circle.

As a part of the Energy Audit data corresponding to the division level feeders, the MSEB has

submitted an assessment of unmetered consumption including unmetered agricultural

consumption. This assessment of unmetered agricultural consumption was not based on

Energy Audit data for LT - agricultural feeders and hence has not been consistent with the

LT-agricultural norm proposed by the MSEB. The Commission, in its earlier Order for

levying T&D loss charges on the basis of differential (circle/zone) T&D losses dated January

9, 2003 (TDL Order), had noted this inconsistency. Despite this, the MSEB has continued to



use a separate basis for assessment of unmetered agricultural consumption. In order to ensure

consistency, the Commission has assessed unmetered LT-agricultural consumption based on

derived norm for LT-agricultural consumption for each of the circles based on the sample

data submitted by the MSEB alongwith the Tariff Proposal for FY 2003-04. The Commission

also directs the MSEB to utilize information available from Energy Audit data on LT-

agricultural feeders for assessing unmetered LT-agricultural consumption for future

submissions.

The norm for LT-agricultural consumption has been derived on an annual basis. If an annual

norm were applied for assessing 6 monthly T&D loss, it would lead to a wrong estimation of

the T&D loss. The same is evident from following Table:

Energy Balance (MU) Apr-Sep Oct-Mar FY 02-03 1. Gross Energy Input 29,613 33,505 63,118 2. Metered+ Assessed unmetered energy 19,013 19,053 38,066

Metered Energy included in (2) above 14,483 14,787 29,270 Assessed LT-Agriculture Energy included in (2) above

4,220 4,103 8,323

3. T&D Loss 10,601 14,451 25,052 4. T&D Loss (%) 35.8% 43.1% 39.7%

The above Table represents data for first half, second half and full FY 2002-03. Second half

of FY 2002-03 has demonstrated an increase in metered consumption. However, the LT

agricultural consumption demonstrated a decline as it has been assessed based on average

connected load during the half-year and circle-wise annual norm of LT-agricultural

consumption. This is not correct, as agricultural consumption would vary across seasons. This

in turn would lead to a wrong estimation of T&D loss for half yearly period.

To avoid such misleading results, assessment period for T&D loss should coincide with

assessment period for the norm of unmetered LT-agriculture consumption, which is presently

1 year. Hence, T&D loss have been calculated for the full financial year and not for 6 monthly

period. In the TDL Order, the Commission had calculated T&D loss for the period of 6 month

as data was available only for 6 months.



Observations

Assessment of Circle-wise T&D Losses

For assessing the Zone-wise/Circle-wise T&D losses, the circle classification as used in the

TDL Order has been used to compare the improvements and deterioration across circles. The

circles were classified in following groups:

Group I: Circles that reported T&D loss below 26.87% in the TDL Order Group II: Circles that reported T&D loss above 26.87% and below 39.49% in the

TDL Order Group III: Circles that reported T&D loss above 39.49% in the TDL Order

Group I Circles: In the TDL Order, 11 circles had reported T&D loss levels below the

Commission’s performance benchmark (26.87%). The performance of this group of circles in

FY 2002-03 is as follows:

Table: Group I Circles

Sr. No. Circles Apr-02 to Sep-02 (TDL Order)

FY 2002-03

1 Sangli 18.6% 27.5% 2 Chandrapur 21.2% 20.7% 3 Vashi 21.3% 21.1% 4 Pen 21.9% 21.1% 5 Ratnagiri 22.6% 24.3% 6 Nagpur 23.3% 25.2% 8 Wardha 24.5% 24.1% 9 Pune (U) 24.8% 23.2% 10 Vasai 25.9% 27.0% 11 Bhandup 26.0% 26.7%

Most circles in this group except Kolhapur, Vasai and Sangli Circles continued to report

T &D loss levels below 26.87%. T&D loss of Sangli circle has been assessed at a

substantially higher level as compared to that reported for the TDL Order. T&D loss of



Ratnagiri, Nagpur, Vasai and Bhandup circles have been assessed to be marginally higher as

compared to that considered in the TDL Order. T&D loss of the rest of the circles have been

assessed to be marginally lower than the levels considered in the TDL Order.

Group II Circles

In the TDL Order, 13 circles had reported T&D loss levels ranging between 26.87% and

39.49%. Performance of this group of circles in FY 2002-03 is as follows:

Table: Group II Circles


FY 2002-03

12 Ahmednagar 28.4% 47.2% 13 Aurangabad (R) 29.7% 46.1% 14 Nashik 31.4% 40.8% 15 Pune (R) 32.0% 43.1% 16 Satara 32.1% 38.3% 17 Buldhana 34.5% 45.0% 18 Gadchiroli 34.7% 40.0% 19 Solapur 36.6% 51.2% 20 Jalna 37.3% 43.5% 21 Sindhudurg 37.8% 32.8% 22 Kalyan 38.8% 39.0% 23 Jalgaon 38.9% 55.2% 24 Nagpur (U) 39.2% 38.1%

T&D loss of most of the circles in this group except Sindhudurg, Kalyan, Nagpur (U) have

been assessed to be substantially higher as compared to that considered in the TDL Order.

Sindhudurg and Nagpur (U) were the only circles in this group, which have reported

improvement as compared to the TDL Order.

26.2.3.5.1.1 Group III Circles

In the TDL Order, 12 circles had reported T&D loss levels above 39.49%. Performance of

this group of circles in FY 2002-03 is as follows:



Table: Group III Circles


FY 2002-03

25 Nanded 40.5% 51.9% 26 Bhandara 40.9% 38.5% 27 Yavatmal 41.4% 48.2% 28 Aurangabad (U) 41.9% 41.3% 29 Amravati 43.8% 46.7% 30 Latur 45.1% 52.9% 31 Parbhani 47.6% 61.8% 32 Dhule 47.8% 59.1% 33 Akola 50.6% 51.6% 34 Osmanabad 51.0% 54.1% 35 Beed 53.3% 66.5% 36 Bhiwandi 58.5% 57.6%

Out of this group of circles, only Bhandara, Aurangabad (U) and Bhiwandi circles have shown losses marginally lower than the loss level considered in the TDL Order. The T&D loss of Akola circle has been assessed to be marginally higher. T&D loss of the remaining circles have been assessed to be substantially higher.

In the TDL Order, the Commission had noted the following:

“As regards the circles with T & D losses above 39.49%, they will have to put in greater

efforts to ensure that the T & D losses are brought down substantially, or else face a steep

increase in the T & D loss charges, on account of the graded T & D loss charge to be

implemented subsequently. The Commission is also of the opinion that T & D losses of above

50% are absolutely unacceptable, and the MSEB should put in concentrated efforts to bring

down the loss levels to benchmark levels, within the shortest possible time, else, the

Commission may be compelled to take drastic punitive action.”

The Commission is extremely unhappy with the performance of the MSEB in curtailing

T&D losses in these circles. The Commission reiterates that the MSEB should put in



concentrated efforts to bring down the loss levels to benchmark levels, within the shortest

possible time.

Assessment of percentage metering and losses

For the purpose of the analysis and in order to gain some insight into percentage metering and

T&D loss performance, the feeders under Rural and Urban zones are clubbed separately. The

zones clubbed under each category are –

Rural Zones - Nagpur, Aurangabad, Amravati, Kolhapur, Beed, and Nashik

Urban Zones - Kalyan, Nagpur-Urban, Bhandup, Konkan*, and Pune-Urban.

Konkan Zone has been considered under Urban category as the divisions reported under

Konkan are Chiplun, Ratnagiri and Kudal which fall under urban/semi-urban category.

The summary of findings over the period April 2001 to March 2003 is reported under the

following Tables, separately for rural and urban zones.

Table: Rural zone summary

FY 2001-02 FY 2002-03 Zone %

M(c) %

Losses %

UM(c) % M(c)/ [M(c)+ UM(c)]

% M(c)

% Losses

% UM(c)

% M(c)/

[M(c)+ UM(c)]

Nagpur 63% 31% 6% 91% 67% 28% 5% 93% Aurangabad 32% 46% 23% 58% 30% 48% 21% 59% Amravati 38% 45% 17% 69% 38% 48% 14% 72% Kolhapur 36% 38% 26% 58% 37% 39% 24% 61% Beed 14% 60% 26% 36% 17% 56% 27% 39% Nashik 26% 53% 21% 55% 28% 50% 22% 56% Rural Zones 33% 46% 21% 61% 35% 44% 20% 63% Note: I. M(c) Means Metered Consumption And UM(c) Means Unmetered Consumption.

ii. % M(c) and % UM(c) are reported as percentage of Energy Input (EI) measured at the feeder grossed up by allocated transmission loss.



Table: Urban zone summary

FY 2001-02 FY 2002-03 Zone %

M© %

Losses %

UM© % M©/ [M©+ UM©]

% M©

% Losses

% UM©

% M©/ [M©+ UM©]

Kalyan 68% 30% 2% 97% 70% 29% 1% 99% Nagpur (U) 62% 36% 2% 97% 61% 38% 0% 99% Bhandup (U) 61% 37% 2% 97% 64% 36% 0% 99% Pune (U) 72% 26% 2% 97% 76% 23% 1% 99% Konkan 69% 27% 4% 95% 73% 26% 1% 98% Urban Zones

66% 32% 2% 97% 68% 31% 1% 99%

Note: i. M(c) means Metered consumption and UM(c) means Unmetered consumption.

ii. % M(c) and % UM(c) are reported as percentage of Energy Input (EI) measured at the feeder grossed up by allocated transmission loss.

Summary of all zones (Rural and Urban) indicates that 44% of the energy input is metered

energy, losses are 41% and unmetered energy accounts for 14% in FY 2001-02. This has improved marginally during FY 2002-03, where 46% of the energy is metered, losses are 40%, and unmetered energy accounts for 14%.

There is a clear distinction in terms of percentage of metered energy between urban zones (average 68%) and rural zones (average 35%).

Metering carried out over the period FY 2000-01 to FY 2002-03 has improved the metered consumption by 2% for the MSEB as a whole. It is surprising to note that metered consumption has declined in Aurangabad and Nagpur (U) zone.

Further, as is evident from the Table, in urban zones where unmetered energy is negligible (0 – 1%), the reported losses are still as high as 23% - 38%.

Future Directions

The MSEB should appropriately utilise the circle-wise/zone-wise LT-agricultural norm

determined from the sample of LT-agricultural feeders in assessment of unmetered

consumption to improve accuracy of assessment of circle-wise/zone-wise loss levels.

Further, the MSEB should modify the sample size in line with statistical sampling norms, to



ensure that the results of the energy audit are truly representative of the pattern of agricultural

consumption in the entire State. Any abnormal variation in assessment results as compared to

LT-agricultural norm should be highlighted and analysed. The MSEB should monitor 12

month moving average of T&D loss and metered consumption every month. The MSEB may

consider using T&D loss level and metered consumption at a divisional/circle/zonal level as a

performance measure.

26.1.7 Conclusion

The Commission appreciates the MSEB’s efforts to make available Energy Accounting data

for the period of 2 years from April 2001 to March 2003. MSEB should further strive to

reduce error readings to increase the database of monitored feeder readings. The MSEB

should further progress from Energy Accounting (i.e. compilation of data) to Energy Audit

(i.e. to utilize Energy Accounting data to reduce the high level of losses on identified feeders).

The MSEB has not submitted any concrete action plan to address the high level of losses

demonstrated by particular areas. The MSEB should apply the principles of ‘ABC Analysis’

and identify the areas, which will generate the maximum revenue at the least cost and

undertake loss reduction programmes in these areas immediately. This is eminently possible

considering the level of metering improvement required for the limited number of Express

Feeders, EHV Feeders and the MIDC areas. It should also be easier to control the losses in the

urban areas due to the concentrated nature of the load and the T&D infrastructure. As regards

the EHV feeders, the MSEB should identify the reasons for increase in loss and submit to the

Commission its plan to achieve reduction in loss level commensurate with the technical loss

level of the system.

Energy Accounting by itself has no meaning, unless the MSEB analyses the Energy

Accounting data and holds the concerned officers responsible for the excess losses in that

zone/circle. The Commission has noted that there are several instances where the meters

installed are not being read on a monthly basis. The Commission reiterates that the MSEB

should hold the concerned employees responsible for the T&D losses in the respective

circles/zones, and consider departmental proceedings against these employees after

following due disciplinary procedure. The monitoring of the circle-level losses should



continue and the MSEB should continue to submit the circle-level Energy Accounting data on

a monthly basis, and circles should operate on ‘profit centre’ basis.

The Commission also notes the MSEB’s achievement of energy audit of 4,668 sample of LT

agricultural feeders. The MSEB should ensure that meters are read regularly to take full

advantage of the available sample. Further, the MSEB should improve the quality of the

sample using statistical random sampling techniques for making the sample more

representative of the LT-agricultural load in the circle, zone and State.

As regards the T&D loss reduction targets, the MSEB has repeatedly argued before the

Commission during the tariff process that unless 100% metering is achieved, the loss levels

cannot be estimated and appropriate action cannot be taken. On the contrary, the MSEB wants

to scrap the parameter of T&D losses altogether. The fallacy in the MSEB’s argument is

evident from the fact that the T&D losses in 100% metered zones range between 26 % and 38

%. The Commission does not agree with the MSEB’s suggestion of focusing on metering

target only and directs the MSEB to pursue T&D loss reduction target as well as the metering

target.

It is imperative for survival of the MSEB that it improves its performance especially in the

area of T&D loss as improvement in metering and billing and check on collusion will result in

substantial improvement of revenues to the MSEB.

26.3 Energy Input Requirement

The MSEB has projected a system loss of 36.62% for FY 2003-04. The treatment for the high

losses of the MSEB has been discussed in the section on Revenue Requirement. However, for

Energy Input projections, the Commission has considered the T&D loss level of 36.62%.

With the sales during FY 2003-04 projected by the Commission at 39710 MU, the total

energy requirement to be met through generation and power purchase is expected to be about

62652 MU.

The total energy input requirement as proposed by MSEB and as approved by the

Commission for FY 2003-04 is as follows:



Energy Input Requirement in FY 2003-04 (MU)

As projected by MSEB Commission’s Approval Sales Metered 32112 32818 Unmetered 8403 6893$

Total Sales 40515 39710 T&D Losses 23407 22942 Energy Input Requirement 63922 62652 T&D loss as a % of energy requirement

36.62% 36.62%

Note: $ - After adjusting for revision in the LT agricultural consumption norm to 1300 hours/HP/year

27. EXPENDITURE PROJECTIONS

The major head of expenditure is generation and power purchase expenses, which account for

around 52% of the total revenue requirement of the MSEB in FY 2003-04. The other

expenses include repair and maintenance expenses, employee expenses, administration and

general expenses, depreciation, interest and lease rent. The Commission has detailed the

allowed expenditure on each of these heads and the overall revenue requirement of the MSEB

as approved by the Commission in the subsequent sections.

27.1 Generation and Power Purchase Costs

The generation and power purchase cost comprises around 54% of the total estimated revenue

requirement. Hence, it is important to ensure that power is generated and purchased strictly

following the Merit Order Dispatch philosophy while maintaining system stability.

27.1.1 Sources of Power

The MSEB has two sources of firm power, viz.

MSEB’s own generating stations Purchase from Central Generating Stations



In addition to the above sources, the MSEB can buy some infirm power from Tata Power

Company (TPC), Power Trading Corporation (PTC) and other sources such as non-

conventional sources including co-generation, wind power and surplus power from captive

plants.

27.1.1.1 MSEB’s Own Generating Stations

The total capacity of the MSEB’s owns generating stations is 9711 MW and the station-wise

break-up of total capacity is as follows.

Generation Capacity of MSEB’s Own Generation Stations

Station Derated Capacity (MW) Khaparkheda 840 Paras 58 Bhusawal 478 Nasik 910 Parli 690 Koradi 1080 Chandrapur 2340 Total Thermal 6396 Gas Thermal 912 Hydel Stations 2430 Total MSEB 9738

27.1.1.3 Central Generating Stations

Central Generating Stations (CGS) comprise of stations belonging to the National Thermal

Power Corporation (NTPC) and the Nuclear Power Corporation Ltd. (NPC). The MSEB has

got a firm share allocation for drawal of power from four stations of NTPC and two NPC

Stations. Further, the MSEB has got some share in the unallocated power of NTPC. The

MSEB’s total share in Central Generating Stations is summarized in the following Table:



MSEB’s Share of Central Generating Stations Capacity

Station Total Capacity (MW) MSEB’s share (MW) NTPC Korba S.T.P.S 2100 674 Vindhyachal S.T.P.S 2260 812 Kawas S.T.P.S 656 228 Gandhar S.T.P.S 657 224 NPC Kakrapar A.P.S 440 160 Tarapur A.P.S 320 255

27.1.1.3 Dabhol Power Company

The MSEB had entered into a Power Purchase Agreement with the Dabhol Power Company

(DPC) for purchase of power. The total installed capacity of the DPC station (Phase I) is 740

MW. However, the DPC plant has been shut down from May 29, 2001 onwards, since the

MSEB has rescinded the PPA with the DPC. The MSEB has not considered any purchase of

power from the DPC, and accordingly, the Commission too has not considered any purchase

of power for FY 2003-04.

27.1.2 Generation and Purchase of Power

The MSEB has estimated the total generation and power purchase costs for FY 2003-04 based

on monthwise simulation of merit order dispatch.

The Commission has approved the total generation and power purchase costs for FY 2003-04 considering actual generation and power purchase cost for the period of April to July 2003 and estimating the generation and power purchase cost from August 2003 to March 2004 based on a simulation of merit order dispatch and actual average generation and power purchase costs for the period of April to July 2003, subject to heat rate and transit loss norms.

The cost of power in respect of Generating Companies and Generating Stations, analysed

and approved by the Commission in the following paragraphs, are based on extant rules and

orders of appropriate authorities and other relevant factors. They do not supplant the



jurisdiction of other statutory authorities like the Central Electricity Regulatory Commission

to determine the rate of power generated by Central Sector Generating Stations, changes in

statutory rates like income tax, water cess and changes in contractual provisions.

17.1.3 Actual Generation and Power Purchase from April 2003 – July 2003

Quantum of Power from the MSEB’s owned plants

MSEB has generated 16423 MU from its own plants during April 2001-July 2003. The table

below summarises the generation from each thermal station and hydel source during the

period, the PLF approved by the Commission for FY 2001-02, and the actual PLF achieved in

FY 2001-02 and FY 2002-03.

PLF of Own Generating Stations

Station Generation during April – July 2003

2001-02 2002-03

Gross Generation

(MU)

PLF Commission Approved

PLF

Actual PLF Actual PLF

Khaparkheda 2104 85.8% 72.2% 68.9% 83.6% Paras 148 87.4% 71.6% 71.6% 58.7% Bhusawal 878 62.9% 78.8% 80.3% 61.9% Nasik 2046 77.0% 64.8% 71.0% 67.0% Parli 1279 63.5% 72.3% 73.2% 75.7% Koradi 2198 69.7% 62.9% 64.5% 65.2% Chandrapur 5383 78.8% 78.8% 79.2% 74.1% Total Thermal 14036 75.2% 73.2% 73.6% 71.9% Gas Thermal 1311 49.2% 45.5% 46.2% 48.7% Hydel Stations 1076 Total MSEB 16423

As observed from the above Table, the actual generation for the period of April 2003 to July

2003 has improved (in terms of PLF) as compared to the generation levels approved by the

Commission for FY 2001-02 and the actual generation levels achieved during FY 2001-02

and FY 2002-03.



Quantum of Power Purchase

During the period of April-July 2003, MSEB has purchased power from the four NTPC

stations, atomic power stations of Tarapur and Kakrapar, Tata Power Company and from

other sources such as wind, co-generation, etc. The total quantum of power purchased during

the period is 5427 MU and the power purchased from each source is summarised below:

Actual Power Purchases

Actual Net Drawal from April-July 2003 (MU)

NTPC Korba S.T.P.S. 1517 Vindhyachal S.T.P.S 1368 Gandhar G.P.S 351 Kawas G.P.S. 425 sub-total (NTPC) 3662 NPC Tarapur A.P.S. 369 Kakrapar A.P.S. 641 Sub-total (NPC) 1010 Eastern Region 108 Tata Power Co. 14 PTC 524

Ad-hoc Purchase 109

Total 5427

27.1.4 Generation and Power Purchase Estimation from August 2003 to March 2004

The generation and power purchase from August 2003 to March 2004 have been projected

based on a simulation of merit order dispatch in order to minimize the cost of generation and

power purchase.

The stepwise methodology adopted by MSEB for estimating energy input, load shedding and

T&D losses and for carrying out the merit order dispatch simulation is as follows:



i) Derivation of Month-wise hourly Load Curves by applying a growth rate of 4.3% over

load curves during FY 2002-03 after making adjustments for load shedding.

ii) Energy Availability Projections that provides the maximum possible extent of

generation from each plant.

iii) Merit Order Stack Up, i.e. based on the variable cost of generation or power purchase

from each station, the plants have been arranged in merit order.

iv) Estimation of month-wise hourly Generation and Power purchase schedule and Load

shedding considering the demand based on load curves, energy availability and merit

order stack up. The variable cost is calculated at load point, i.e. including the

normative transmission loss.

v) Estimation of Total Energy Input Projections based on hourly generation and power

purchase schedule.

vi) T&D losses estimation based on Total Energy Input Projections, Estimated Metered

Consumption and Assessment of un-metered consumption.

The stepwise methodology adopted by the Commission for estimating energy input, load

shedding and T&D losses and for carrying out the merit order dispatch simulation is as

follows:

i) Estimation of Metered Consumption and Assessment of Un-metered Consumption.

ii) Total Energy Requirement Projections based on Consumption and T&D Loss levels

considered by Commission for computing energy input requirement.

iii) Derivation of month-wise hourly load curves from the load during previous year after

making adjustments for load shedding and based on the variation in sales, energy

input and considering actual power generated and purchased from April 2003 to July

2003.

vi) Energy Availability Projections that provides the maximum possible extent of

generation from each plant.



vii) Merit Order Stack Up, i.e. based on the variable cost of generation or power purchase

from each station, the plants have been arranged in merit order. The variable cost is

calculated at load point, i.e., including the normative transmission loss.

viii) Estimation of month-wise hourly Generation and Power purchase schedule and Load

shedding considering the demand based on load curves, energy availability and merit

order stack up.

The major difference in the methodology adopted by the MSEB and the Commission is that

MSEB has estimated T&D losses based on the Total Energy Input Projections derived from

hourly generation and power purchase schedule. MSEB’s approach assumes Energy Input as

the base, and derives the T&D loss as the difference between the energy input and sales. This

is incorrect, as the MSEB should first assess how much energy is required and then plan the

generation and power purchase accordingly, to meet the energy input requirement. Hence, the

Commission has considered allowable T&D losses in addition to the estimated sales to

determine the total energy input requirement.

27.1.5 Merit Order Dispatch Simulation

The Commission has carried out the merit order dispatch simulation in five modules in a

manner similar to the one as carried out by MSEB with some change in principles. The

methodology and the principles adopted by the Commission for carrying out merit order

dispatch simulation for optimisation of total generation and power purchase cost are as

follows:

27.1.5.1 Module 1: Demand Schedule

It is necessary to explain here, the peculiarity of the electricity business. Electricity cannot be

stored; hence it is required to be generated when consumers use it. The consumption is not

uniform throughout the day. Consumption depends upon the activity and the time at which it

is normally performed by the society (lighting in the evening, irrigation as per cropping

season, hot water geysers in the morning, ironing in the afternoon/evening, day hours for

business, schools, offices and shift working of factories, etc.). Therefore the system demand

varies from hour to hour in a day and it also varies across seasons.



The MSEB has derived month-wise hourly load curves by applying a growth rate of 4.3%

over load curves during the previous year 2002-03 after making adjustments for load

shedding. The Commission has derived month-wise hourly load curves from the actual load

curves during the previous year after making adjustments for load shedding and based on the

growth in energy input after adding the allowed T&D losses to the projected sales. This

output of this module provides month-wise hourly demand of the system.

27.1.5.2 Module 2: Availability Schedule

In this Module, the maximum possible generation from each station during every month has

been projected considering various factors.

27.1.5.2.1 MSEB’s Thermal Stations

The maximum possible generation during every month from MSEB’s thermal stations has

been estimated based on the ‘ability to generate’ factor for each station and factoring the

planned outages during the respective month. The ability to generate for the station takes into

account various factors such as Forced Outages, Partial Outages, Fuel Quality, System

Demand, System Problems and Fuel Shortage. The MSEB has submitted that they have

accounted for these factors based on the analysis of past data.

The Commission has projected the ability to generate factor based on the past three years

availability taking into account the planned outages and other factors responsible for the

unavailability of stations. The Commission has considered the actual outages for the period

April to July 2003 and the planned outages for the period August 2003 to March 2003 based

on the details provided by MSEB.

The stationwise ‘ability to generate’ factor as considered by MSEB and as approved by the

Commission is summarised in the following Table:



Ability to Generate of Own Generating Stations

Ability to Generate Factor Station MSEB Projection Commission’s Approval Koradi 0.8030 0.8720 Nasik 0.8150 0.9530 Bhusawal 0.7815 0.8940 Parli 0.8905 0.9650 Chandrapur 0.7970 0.9320 Paras 0.7410 0.9390 Kaparkheda 0.7590 0.9190 Uran 0.5529 0.5529

27.1.5.2.2 MSEB’s Hydro Stations

MSEB has assumed the hour-wise possible generation from all hydro stations similar to that

in the corresponding month in FY 2002-03. With this assumption, the total annual generation

from hydro stations works out to 4077 MU. The Commission has observed that the actual

generation from hydel stations during the first four months of the year i.e. April 2003 to July

2003 is lower than the hydel generation during the corresponding period in the previous year.

The Commission has therefore increased the hydel generation during the period August 2003

to March 2003 as compared to the hydel generation during the corresponding period in the

previous year and has approved the net generation target of 4079 MU for FY 2003-04 which

is almost at the same level as proposed by MSEB for FY 2003-04.

27.1.5.2.3 Central Generating Stations

The maximum possible generation from NTPC and NPC plants has been projected based on

the availability of these Stations. The Commission has considered the availability of NTPC

and NPC Stations to be the same as that considered by MSEB.



27.1.5.2.3 Module 3: Merit Order Stack – up

In this Module, all the Stations available during the period are required to be prioritized in

“merit order”. The merit order stack up of the Stations has been done based on the variable

cost of power generation or power purchase as the fixed costs of each plant (whether of own

generation or of power purchase) are to be incurred by the MSEB irrespective of quantum of

generation or power purchase.

Further, the merit order stacking has been done on the load centre variable cost of each

station, as the objective of the merit order stack up is to consider the cost of generation and

power purchase from any station to the grid. The load centre variable cost has been estimated

by adding transmission loss component to variable cost of generation or power purchase.

27.1.6 Variable cost of MSEB’s Stations

The MSEB has projected the variable costs of its own stations considering 5% increase over

the actual variable costs incurred during FY 2002-03. These variable costs projected by

MSEB are inclusive of transit loss component.

The Commission has projected the variable cost of MSEB stations based on the average of

actual fuel costs from April-July 2003 subject to heat rate and transit loss norms.

27.1.6.1 Heat Rate

The Commission had directed the MSEB to improve the heat rate of its generating stations

gradually, and accordingly considered a 1% improvement in the heat rate in the previous

Tariff Orders in FY 2000-01 and FY 2001-02. Accordingly, the Commission has considered

a reduction of about 1% in the station-wise heat rate from the heat rate figures approved by

the Commission in its Tariff Order for FY 2001-02. The Commission notes that the average

heat rate for the MSEB’s thermal stations is considerably higher than the CEA prescribed

heat rate of 2500 kcal/kWh. For the Uran gas based station, the Commission has considered

the heat rate same as that approved in its Tariff Order for FY 2001-02. The stationwise heat

rate approved by the Commission for FY 2001-02, actual heat rate achieved during FY

2001-02 and FY 2002-03, actual heat rate achieved during April-July 2003 and the heat rate

approved by the Commission for FY 2003-04 is summarised in the following Table:



Heat Rate for MSEB Stations (Kcal/kwh)

FY 2001-02 Station Approved Actual

2002-03 Actual

Apr-July 03 Actual

Commission’s Approval for FY

2003-04 K’kheda – I&II 2753 2787 2752 2718 2725 Paras 3232 3603 3486 3261 3200 Bhusawal 2763 2809 2746 2848 2735 Nasik 2690 2687 2673 2676 2663 Parli 2676 2678 2729 2730 2649 Koradi 3026 3091 3023 3105 2996 Chandrapur 2527 2757 2570 2587 2502 Total Thermal 2702 2717 2717 2737 2675 Gas Thermal 1966 2001 2001 2019 1966

The Table below summarizes the station-wise variable cost as projected by MSEB and as

approved by the Commission.

27.1.6.2 Transit Loss

In previous Tariff Orders and FOCA Computations, the Commission had disallowed the transit loss component as an expense while computing the variable cost of generation. However, the Hon’ble High Court of Mumbai in its Order dated February 24, 2003 in the matter of MERC Appeal No. 1 and 2 of 2001 has held that transit losses are a legitimate expense, and the permissible level of transit losses has to be determined by the Commission on the basis of evidence before it and after hearing the parties.

The Commission has examined the actual transit loss of all the thermal stations of MSEB based on the month-wise coal cost statements submitted by the MSEB during the Tariff Process and for approval of FOCA Computations. The station-wise actual transit loss for the FY 2001-02 and FY 2002-03 determined based on coal cost statements submitted by MSEB are as follows:



Actual Transit Loss during FY 02 and FY 03 based on Coal Cost Statements

Station FY 2001-02 FY 2002-03 Koradi 3.25% 1.77% Nasik 2.31% 0.96% Bhusawal 2.59% 0.98% Parli 3.37% 2.80% Chandrapur 2.54% 2.12% Paras 4.56% 3.08% Kaparkheda 3.13% 1.75%

The transit losses of all the MSEB thermal stations during FY 03 have reduced substantially

as compared to actual transit losses for FY 02 mainly due to the improvement efforts initiated

by MSEB. For two stations, i.e. Bhusawal and Nasik, the extents of actual transit losses

during FY 03 are less than 1%. The Commission is of the opinion that the transit loss level of

less than 1% is reasonable and MSEB should reduce the transit losses for all the stations

below 1% in gradual manner.

The pattern of stationwise transit loss projected by MSEB for FY 04 in its Tariff Proposal

does not match the actual stationwise transit loss for FY 03. The Commission highlighted this

discrepancy to the MSEB and directed MSEB to provide clarification in this regard. However,

the response/clarifications provided by MSEB in this regard were not satisfactory. The

Commission is further examining this matter in detail. However, in order to avoid delay in the

issue of the Tariff Order, the Commission has considered transit losses based on actual transit

loss for FY 03 based on coal cost statements and assuming a trajectory of reduction in Transit

Losses. Any variation in transit losses approved by the Commission and the transit loss level

computed based on the detailed examination of the issue will be adjusted in Fuel and other

Cost Adjustment Formula.

The transit loss reduction trajectory considered by the Commission for reduction in transit

losses is as follows:

- Reduction of 0.5% p.a. for stations with actual transit loss level above 3% - Reduction of 0.4% p.a. for stations with actual transit loss level between 2-3% - Reduction of 0.3% p.a. for stations with actual transit loss level between 1-2%



- Actual transit loss for stations with actual transit loss level below 1%

The summary of station wise transit loss as considered by MSEB in its Tariff Petition and the transit loss as considered by the Commission for projecting the variable cost of generation is provided in the following Table:

Transit Loss level for FY 2003-04

Station MSEB Petition Commission’s Approval Koradi 1.77% 1.47% Nasik 2.80% 0.96% Bhusawal 0.96% 0.98% Parli 1.77% 2.40% Chandrapur 1.77% 1.72% Paras 0.98% 2.58% Kaparkheda 3.08% 1.45%

Note: In some instances, the transit loss allowed by the Commission is higher than that asked for by the MSEB, which is on account of the discrepancy discussed earlier. Any upward/downward correction in the numbers will be adjusted through the FOCA mechanism, after a thorough analysis of the same.

27.1.6.3 Variable Cost of Generation and Power Purchase

Based on the above analysis, the Commission has projected the variable cost of generation

and power purchase as follows:

Variable Cost per unit for MSEB’s Stations (Rs/kwh)

Station MSEB’s Projections VC per unit

Commission’s Approval VC per unit

Koradi 1.1256 1.2205 Nasik 1.3080 1.4164 Chandrapur 0.8266 0.7237 Paras 1.2182 1.2299 Parli 1.3016 1.2836 Bhusawal 1.1580 1.1525 Khaperkheda 1.0261 0.9239 GTPS Uran 0.6993 0.6742

Note: VC indicates Variable Cost



As observed from the above Table, there is a substantial difference in the variable cost of

some of the generating stations as approved by the Commission and as projected by the

MSEB. The Commission has approved the stationwise variable cost based on the average fuel

cost for April to July 2003, considering stationwise approved heat rate and transit loss

component.

27.1.6.4 Variable cost of NTPC and NPC Stations

The MSEB has projected the variable cost of NTPC and NPC stations based on the actual

variable cost of these stations for the period July 2002 to March 2003. The Commission has

projected the variable cost of NTPC and NPC stations based on actual average variable costs

of these stations from April-July 2003. The Table below summarises the Variable Cost of

NTPC and NPC Stations as projected by MSEB and as considered by Commission

Variable Cost for NTPC and NPC Stations (Rs/kwh)

Station MSEB’s Projections VC per unit

Commission’s Approval VC per unit

NTPC-Vindhyachal I 0.8046 0.7913 NTPC-Vindhyachal II 0.7569 0.7352 NTPC-Korba 0.4968 0.5250 NTPC-Kawas 2.7913 2.4486 NTPC-Gandhar 1.0855 1.1460 NPC-Kakrapar 2.9629 2.9911 NPC-Tarapur 0.9446 0.9446

Note: VC indicates Variable Cost

As observed from the above Table, there is a substantial difference in the variable cost of

some of the stations as approved by the Commission and as projected by the MSEB. The

Commission has approved the station-wise variable cost based on the actual average variable

cost for April to July 2003.

Based on the variable costs projected and considering transmission losses, the merit order

stack-up as projected by MSEB for FY 2003-04 is as follows:



Merit Order Stack as proposed by MSEB for October 2001-March 2002

Station

Load Centre VC per unit (paise/kWh)

VC per unit (paise/kWh)

Transmission Losses

Hydro 0.00 0.00 1.30% Korba 52.41 49.68 5.49% Uran 71.00 69.93 1.52% Vindhyachal II 79.85 75.69 5.49% Vindhyachal I 84.88 80.46 5.49% Chandrapur 87.23 82.66 5.52% Tarapur 95.90 94.46 1.52% Khaparkheda 108.24 102.61 5.49% Gandhar 114.51 108.55 5.49% Koradi 118.74 112.56 5.49% Bhusawal 122.20 115.80 5.52% Paras 128.54 121.82 5.52% Nasik 132.80 130.80 1.52% Parli 137.35 130.16 5.52% Kawas 294.45 279.13 5.49% Kakrapar 312.55 296.29 5.49%

The MSEB has also included must-run stations in the merit order stack-up. However, the

Commission has not included must-run stations in the merit order stack-up. Based on the

variable costs projected and considering associated transmission losses, the merit order stack-

up as projected by the Commission for the period of August 2003-March 2004 is as follows:



Merit Order Stack as approved by Commission for August 2003-March 2004

Station

Load Centre VC per unit (paise/kWh)

VC per unit (paise/kWh)

Transmission Losses

Korba 55.38 52.50 5.49% Chandrapur 76.36 72.37 5.52% Vindhyachal II 77.56 73.52 5.49% Vindhyachal I 83.46 79.13 5.49% Khaparkheda 97.46 92.39 5.49% Gandhar 120.89 114.60 5.49% Bhusawal 121.61 115.25 5.52% Koradi 128.75 122.05 5.49% Paras 129.78 122.99 5.52% Parli 135.45 128.36 5.52% Nasik 143.79 141.64 1.52% Kawas 256.31 244.86 5.49%

27.1.7 Module 4: Generation & Power Purchase Schedule and Estimation of Load

Shedding

From Module 1, the representative load curve for the month that gives the demand during

each hour of the representative day is available and from Module 2 the maximum possible

generation from each station is known. The Stations have been arranged in order of priority

under Module 3.

The generation and power purchase schedule and quantum of load shedding has been

estimated based on the above inputs and the principles of merit order dispatch. Following are

the principles considered for merit order dispatch.

i) The Commission has considered following stations as ‘must run’ stations:

- Hydro stations as their variable cost is zero - Nuclear Plants of NPC because of technical constraints



- Uran Gas based plant of MSEB because of wastage of gas in these plants in case of non-utilisation of gas.

ii) The Thermal stations are necessarily required to run at least at a minimum level below

which their operation becomes unstable and also requires costly oil support. The

Commission has approved the minimum generation from the MSEB’s coal based

stations at a minimum of 70% of their maximum possible capacity as proposed by the

MSEB.

From the total load required during each hour of the representative load curve, the generation

from ‘must run’ stations and minimum necessary generation from MSEB’s coal based

stations is allocated to each hour of the day, and the balance requirement for each hour is

estimated.

For this hourly balance requirement, the remaining capacities of the first plant in the order of

priority as per merit order stack-up is allocated and the balance requirement is estimated. This

process is repeated until the hourly demand is met. The sample of merit order scheduling for

the month of January 2004 is enclosed at Exhibit-1.

The outcome of this Module provides the monthwise total generation from MSEB’s own

stations, quantum of power purchase from NTPC and NPC Stations. The monthwise

generation from MSEB’s own stations and quantum of power purchase from NTPC and NPC

stations is enclosed at Exhibit-2.

27.1.8 Quantum of Generation from MSEB’s owned plants

Considering the actual generation from April-July 2003 and the monthwise generation based

on merit order scheduling, the total net generation approved by the Commission for FY 2003-

04 is 46470 MU. The table below summarises the net generation approved by the

Commission and as projected by the MSEB for FY 2003-04.



Net Estimated Generation

MSEB Net Generation

Projections for 2003-04 (MU)

PLF as per MSEB

Proposal

Commission’s Approval for

2003-04 (MU)

PLF as Approved by

MERC

Khaparkheda 4948 73.4% 5471 81.3% Paras 316 69.1% 345 75.3% Bhusawal 2899 76.9% 2802 74.4% Nasik 5303 72.9% 4680 64.5% Parli 3948 72.2% 3538 64.8% Koradi 6020 70.5% 3918 69.1% Chandrapur 14433 76.2% 15693 82.9% Total Thermal 37868 74% 38431 75.1% Gas Thermal 4039 51.8% 3961 51%

Hydel Stations 4077 4079 Total MSEB 45983 46470

As observed from the above Table, the net generation from MSEB’s own stations as approved

by the Commission is 487 MU higher than that projected by MSEB. The Commission has

increased the generation from some of the thermal stations based on ability to generate factor

and by applying the merit order dispatch simulation.

27.1.9 Estimate of Power Purchase

Considering the actual power purchase from April-July 2003 and the monthwise purchase

based on merit order scheduling, the total power purchase approved by the Commission for

2003-04 is 16182 MU. The Table below summarises the net power purchase approved by the

Commission and as projected by the MSEB for year 2003-2004.



Estimate of Power Purchases (MU)

Net Drawal estimated by MSEB in FY2003-04

Commission’s Approval for FY 2003-04

NTPC Korba S.T.P.S. 4494 4501 Vindhyachal II S.T.P.S 3046 2727 Vindhyachal I S.T.P.S 2373 2081 Gandhar G.P.S 936 818 Kawas G.P.S. 714 457 sub-total (NTPC) 11563 10515 NPC Tarapur A.P.S. 1231 1187 Kakrapar A.P.S. 1703 1772 Sub-total (NPC) 2935 2959 Eastern Region 108 Tata Power Company 658 104 Power Trading Corporation 2304 2127 Other Sources (Non-conventional etc)

480 300

Total 17940 16183

27.1.10 Load Shedding

The MSEB has projected load shedding of 1079 MU in FY 2003-04. However, based on the

merit order simulation based on the demand projections and the allowable T&D loss level

considered by the Commission, the Commission is of the opinion that there is no need to

resort to load shedding during FY 2003-04, as there is sufficient energy available through

own generation and power purchase to meet the projected sales at the T&D loss levels

considered by the MSEB.



27.1.11 Generation and Power Purchase Cost

27.1.11.1 Generation Cost:

The Commission has estimated the total generation costs in the following manner:

Actual Generation Costs for the period April 2003 – July 2003, subject to Heat Rate and

Transit Loss Norms

Projected Generation for the period August 2003 – March 2004 multiplied by variable

cost per unit as derived earlier in Section “Merit Order Stack-up”

The total variable costs of generation from MSEB’s station as approved by the Commission

and as projected by MSEB are as follows:

Generation Cost Estimates (Rs. Crore)

Variable cost of power for MSEB stations for

FY 2003-04


2003-04 Khaparkheda 508 505 Paras 38 42 Bhusawal 336 323 Nasik 694 663 Parli 514 454 Koradi 678 720 Chandrapur 1193 1136

Total Thermal 3960 3844

Gas Thermal 282 267 Total Generation Cost

4243 4111

27.1.11.2 Power Purchase Cost:

27.1.11.2.1 Power Purchase Cost for Central Generating Stations:

The Commission has estimated total power purchase cost in the following manner:



Actual stationwise Power Purchase Costs from April 2003 –July 2003 The variable charges based on the Projected Purchase for the period August 2003 – March

2004 multiplied by variable cost per unit as derived earlier in Section “Merit Order Stack-up” Fixed Charges in line with the CERC Orders The Income Tax payable to NTPC has been considered as Rs 95 Crore based on average

of actual income tax of NTPC stations during last two years as against Rs 140 Crore projected by MSEB The Income Tax payable to NPC has been considered as Rs 16.9 Crore based on actuals

for FY 02 as against Rs 22 Crore projected by MSEB For NTPC stations, Incentives have been included in the fixed charges in line with the

ABT Order Transmission charges payable to PGCIL has been projected based on the actual

transmission charges for the period April to July 2003 on pro-rata basis

27.1.11.2.2 Power Purchase from Power Trading Corporation (PTC)

The MSEB has estimated a total power purchase of 2304 MU from PTC during FY 2003-04.

The Commission has considered the power purchase from PTC considering the actual

purchase during April to July 2003 and estimating the power purchase for the period August

2003 to March 2004 based on copy of agreements with PTC as submitted by MSEB. The

actual power purchase from PTC during April to July 2003 is 524 MU. The estimated power

purchase from PTC based on the agreements executed with MSEB works out to around 1603

MU. Thus, the total power purchase considered by the Commission from PTC during the year

2003-04 is 2127 MU.

The Commission has estimated the total power purchase cost for purchase of power from

PTC considering the actual power purchase costs for the period April to July 2003 and

estimating the power purchase costs for the period August 2003 to March 2004 considering

estimated power purchase and power purchase rate per unit (based on agreements with PTC).

The total power purchase cost as estimated by the Commission for purchase of power from

PTC and similar other sources during FY 2003-04 is Rs 466 Crore as against the total power

purchase cost of Rs 527 Crore, projected by the MSEB.



It should be noted that the Commission has stated that the above quantum of power purchase

has been considered from PTC based on the Tariff Petition filed by the MSEB. In practice,

the MSEB can source the allowed quantum of power either from PTC or other sources, at the

rate specified above. The Commission has issued an Order in the matter of agreement of

purchase of power by MSEB through M/s Koyela Energy Resources Pvt. Ltd., on January 1,

2004. In this Order, the Commission ruled that as it had approved power purchase to the

extent of 2127 MU (net of transmission losses) with a ceiling of Rs. 466 crore for FY 2003-

04. Hence, no specific approval on case to case basis is required from the Commission for

purchases from such sources provided that they are contained within the above ceilings of

total quantum and total cost upto 31.03.2004, subject to such purchases being in accordance

with the relevant provisions of the EA 2003.

27.1.11.2.3 Power Purchase from Eastern Region (ER)

The MSEB has purchased 108 MU from Eastern Region at a total cost of Rs 19 Crore during

the period April to July 2003. The MSEB in its Petition had not projected any purchase from

Eastern Region. However, as the Commission has projected the total power purchase for the

FY 2003-04 considering the actual power purchase for the period April to July 2003, the

power purchased from Eastern Region during April to July 2003 has been considered by the

Commission while estimating the total energy input and power purchase cost.

27.1.11.2.4 Power Purchase from Tata Power Company (TPC)

The MSEB has estimated net purchase of 658 MU from TPC. However, the actual purchase

during first 4 months of FY 2003-04 i.e., from April 2003 to July 2003 is 13 MU as against

the purchase of 87 MU during the corresponding period of the previous year. The

Commission, considering the actual purchase during FY 2002-03 and during the first four

months of 2003-04 has estimated the total purchase of 104 MU for FY 2003-04. MSEB has

estimated the total power purchase cost of Rs 165 Crore @ Rs 2.50/kwh. Considering the

same unit rate of Rs 2.50/kwh, the Commission has approved the power purchase cost of Rs

26 Crore.



27.1.11.2.5 Power Purchase from other sources

The MSEB has estimated power purchase of 480 MU from other sources (non-conventional,

CPP etc). However, the actual purchase during first 4 months of FY 2003-04 i.e., from April

2003 to July 2003 is 109 MU out of total surplus power of 349 MU from these sources. The

commission has considered atotal purchase of 300 MU from other sources considering the

actual purchase during April to July 2003 and estimated power purchase for the period

August 2003 to March 2004. The MSEB has estimated the total power purchase cost of Rs

152 Crore @ Rs 3.17/unit. The MSEB has submitted that the unit cost of Rs 3.17/kWh has

been considered based on the MERC approved rate and escalation for purchase from

cogeneration stations. Considering the same unit rate of Rs 3.17/kwh, the Commission has

approved the power purchase cost of Rs 95 Crore.

27.1.11.2.6 Unscheduled Interchange (UI) Charges

During the period April to July 2003, MSEB has been billed Rs 44 crore as Unscheduled

Interchange (UI) Charges on account of underdrawals and overdrawals during the period. The

Commission has considered these actual UI Charges for the period April to July 2003 while

estimating the power purchase costs. After due consideration, the Commission is of the view

that a certain level of UI charges are unavoidable, due to gird requirements and the demand-

supply situation at that point in time. However, at the same time, it should be noted that since

the implementation of Availability Based Tariff (ABT) in the country, the grid discipline has

improved substantially, and most other States are managing their energy requirements such

that the incidence of paying UI charges is minimized. Moreover, there is an opportunity for

the MSEB to purchase power at times of high frequency at very cheap rates, and the MSEB

should actively explore this option to reduce its costs. The MSEB should maintain grid

discipline as envisaged under the ABT regime. The MSEB, on the other hand has been

incurring substantial expenditure on account of UI charges, which cannot be allowed in toto.

Hence, the Commission has allowed UI charges at a normative level of 1% of total energy

input requirement.

In this context, the Commission would also like to inform the MSEB and the consumers that

the Commission is considering the scope for implementing intra-State ABT along the lines of

the inter-State ABT mechanism that has been implemented with good results across the



country. The Commission is of the view that the intra-State ABT mechanism may facilitate

segregation of UI charges among DISCOMs, as well as facilitate open access transactions.

The Summary of total Power Purchase expenses as estimated by MSEB and as approved by

Commission is as follows:

Estimate of Power Purchase Expenses (Rs. Crore)

MSEB’s projections forFY 2003-04


2003-04 NTPC Korba S.T.P.S. 351 370 Vindhyachal II S.T.P.S 390 333 Vindhyachal I S.T.P.S 332 301 Gandhar G.P.S 316 315 Kawas G.P.S. 313 229 Income Tax Payable 140 95 Sub-Total (NTPC) 1842 1643 NPC Tarapur A.P.S. 127 118 Kakrapar A.P.S. 516 541 Sub-total (NPC) 643 659 Eastern Region 19 Tata Power Co. 165 26 Power Trading Corp. 527 466

Other Sources 152 95

Power Grid Transmission Charges

165 180

UI Charges --- 44

Total 3494 3132



27.1.12 Total Generation and Power Purchase Expenses

The total Generation and Power Purchase Cost for FY 2003-04 as projected by MSEB

and as approved by the Commission is summarised below:

Total Generation and Power Purchase Cost

FY 2003-04 MSEB Commission’s

Approval Total Generation Cost (Rs Cr) 4243 4111 Generation Cost per unit (Rs/kwh) 0.93 0.885 Power Purchase : - Fixed Costs (Rs Cr) 1080 1029 - Variable Costs (Rs Cr) 2413 2103 Total Power Purchase Cost (Rs Cr) 3493 3132 Total Generation and Power Purchase Cost (Rs Cr)

7736 7243

Generation and Power Purchase Cost per unit (Rs/kWh)

1.21 1.16

The details regarding actual power generation and purchase cost for first 4 months and

expenses projected for next 8 months as considered by the Commission have been attached at

Appendix 5 to enable the MSEB to claim FOCA accordingly.

27.2 Other Heads of Expenditure

27.2.1 Employee Expenses

The MSEB has projected employee expenses of Rs. 1695 crore in FY 2003-04, net of

capitalization. The MSEB has projected a 5.2% increase in most heads of employee expenses,

with the DA amounting to 47% of basic salary. It should be noted that the actual expenditure

on basic salary in FY 2001-02 is lower than that projected by the MSEB and allowed by the



Commission. Further, the basic salary expenditure in FY 2002-03 was lower than the

expenditure actually incurred in FY 2001-02. This shows that there is a reducing trend in the

basic salary expenditure. However, considering the fact that the reducing trend cannot

continue, the Commission has considered a normative 2% increase in basic salary, with DA at

47% of basic salary. The other heads of employee expenditure, such as overtime, other

allowance and staff welfare have been considered at the levels projected by the MSEB as the

MSEB is in the best position to estimate these expenses and the projected expenses are in line

wit the trend observed in the recent past. The employee expenses have been capitalized at the

average capitalization rate observed in the past three years.

The total employee expenditure allowed by the Commission is Rs. 1655 crore, net of

capitalization. The details of the employee expenditure allowed by the Commission in the

past and the actual expenditure incurred by the MSEB over the past four years are presented

in the following Table:

Table: Employee Expenses over the past four years

Tariff Order Actual MSEB

Tariff Order

Salaries 382.22 875.19 806.51 787.59 829.10 806.51Overtime 48.44 45.24 40.78 41.47 43.66 43.66Dearness Allowance 603.91 332.57 318.67 349.61 391.27 380.61Other Allowances 133.95 156.97 151.80 146.90 154.64 154.64Bonus/ Ex gratia 0.42 30.77 0.00 0.00 0.00 0.00Sub Total 1168.94 1440.74 1317.76 1325.57 1418.66 1385.42

Medical Expenses Reimbursement 5.12 5.59 6.03 5.94 6.18 6.18Leave Travel Allowance 7.75 8.47 4.26 4.09 4.25 4.25Earned Leave Encashment 47.46 32.11 18.06 49.42 18.77 18.77Terminal Benefits 406.80 295.68 407.30 379.66 394.85 385.60Staff Welfare & Others 13.70 6.12 16.27 15.60 16.22 16.22

Total 1649.77 1788.71 1769.68 1780.28 1858.93 1816.44

Less : Capitalised 175.48 229.22 151.75 132.70 164.12 161.45Capitalisation Rate (as % of employee expenses) 10.64% 12.81% 8.58% 7.45% 8.83% 8.89%Net Employee Expenditure 1474.29 1559.49 1617.93 1647.58 1694.81 1654.98

Pay revision provision 210.00Arrears to be provided in Tariffs 144.35

Net Employee Cost chargeable to revenue 1474.29 1703.84 1617.93 1647.58 1694.81 1654.98

Particulars

FY02 FY04

FY01 FY03



27.2.2 Administration and General (A & G) Expenses

The MSEB has projected A & G expenses of Rs. 145 crore in FY 2003-04, net of

capitalization. The MSEB has projected an increase of 4.2% over the actual expenditure in

FY 2002-03, based on the increase in expenditure in FY 2002-03 over expenditure in FY

2001-02. However, the actual expenditure in FY 2001-02 has been higher than the

expenditure allowed by the Commission in the Tariff Order. The Commission is of the view

that A&G expenses can and should be controlled by the MSEB, and it cannot simply allow an

increase over the actual expenses in FY 2002-03. The Commission has hence considered a

year-on-year (YoY) increase of 4.2% over the A&G expenses allowed by the Commission in

FY 2001-02, to determine the A&G expenses for FY 2003-04. The A&G expenses have been

capitalized at the average capitalization rate observed in the past three years.

The net Administration and General expenses approved by the Commission are Rs.139 crore.

The details of the A&G expenditure allowed by the Commission in the past and the actual

expenditure incurred by the MSEB over the past four years are presented in the following

Table:

Table: A&G Expenses over the past four years


Tariff Order

1 Rent Rates & Taxes 15.71 15.00 18.71 19.73 20.56 16.292 Insurance 5.32 5.32 4.65 12.56 13.09 5.783 Telephone & Postage etc. 10.29 12.13 10.83 10.78 11.23 13.174 Legal charges,Audit fee, consultancy,

technical fee, professional charges 7.17 5.25 8.76 8.67 9.03 5.705 Conveyance & Travel 32.63 37.34 33.22 32.10 33.45 40.556 Miscellaneous 55.29 54.95 61.49 59.27 61.76 59.677 Freight 0.65 1.00 0.56 0.52 0.54 1.098 Purchase related Expenses 11.26 12.00 11.30 12.18 12.69 13.03

Total 138.32 142.99 149.52 155.81 162.36 155.27

Less capitalisation 15.93 23.44 16.86 14.75 17.40 16.70Capitalisation Rate (as % of total A & G exp) 11.52% 16.39% 11.28% 9.47% 10.72% 10.75%A & G Revenue Expenditure 122.39 119.55 132.66 141.06 144.96 138.58

FY02 FY04

Particulars FY01 FY03

27.2.3 Depreciation Expenses

The MSEB has projected depreciation expenses of Rs. 1585 crore. The actual depreciation

charged over the past three years as a percentage of the opening gross block of assets works



out to 6.36% on an average, and the Commission has applied this percentage to arrive at the

allowable depreciation. The depreciation expenditure allowed by the Commission is Rs. 1578

crore.

27.2.4 Operations and Maintenance (O & M) Expenses

The MSEB has projected O & M expense to the extent of Rs. 738 crore, net of capitalization,

which is about 3% of the Gross Fixed Assets (GFA) at the beginning of the year. The

Commission is of the opinion that O & M expenses to the extent of 3% of GFA are

permissible and necessary for a system of this size. The MSEB is directed to concentrate on

its network assets in the process of conducting O & M activities. The O&M expenses have

been capitalized at the average capitalization rate observed in the past three years, which is

slightly higher than the capitalization rate assumed by the MSEB.

The O & M expenditure allowed by the Commission is Rs. 737 crore. The O&M expenditure

allowed by the Commission in the past and the actual expenditure incurred by the MSEB over

the past four years are presented in the following Table:

Table: O&M Expenses over the past four years


Tariff Order

i) O.B. of Gross Fixed Assets 20251.77 22679.00 22600.20 23727.08 24827.39 24827.39ii) R&M Expenses 455.61 680.37 586.66 640.46 737.70 737.11

% of (i) to (ii) 2.25% 3.00% 2.60% 2.70% 2.97% 3.00%

Sl. FY01 FY03Particulars

FY02 FY04

27.2.5 Lease Rent

The MSEB has projected expenditure on account of lease rentals paid to the GoM for the use

of the dams for hydel generation, at the same level as in previous years, i.e., Rs. 85 crore. The

MSEB has submitted that the GoM has already appointed a Committee to decide the scientific

basis for fixing the lease rent in respect of various hydro power stations already handed over

and to be handed over to the MSEB. The MSEB has submitted that the matter is in progress.

For the time being, the Commission has considered the lease rent expenditure as Rs, 85 crore.



27.2.6 Interest Expenditure

The MSEB has projected total interest expenditure of Rs. 1308 crore, including working

capital interest and net of capitalization. The interest on long term loans has been projected on

the basis of the outstanding loan, the loan drawal programme for FY 2003-04, and the

effective interest rate applicable on loans from various sources. The MSEB has submitted

details of institutional borrowings, with break-up of loans drawn from nationalised banks and

foreign currency loans, etc., as well as the repayments and borrowings scheduled for FY

2002-04. The interest has been projected based on the average outstanding during the year.

In its previous Tariff Orders, the Commission had disallowed the interest expenditure on

loans taken by the MSEB for investment in the Dabhol Power Corporation (DPC), on the

ground that the investment was not a part of the regulated business of the MSEB. In its Tariff

Petition for FY 2003-04, the MSEB has cited Section 59 of the ESA, and has stated that “Any

expenses actually incurred by the Board as a result of carrying on its operations under the

Act would have to be considered by MERC for its tariff and revenue requirement

determination process. The operations of the Board are also guided by the powers of GoM

under Section 78(A) of the Act to issue directives. The Board would like to bring to the

attention of MERC the fact that the Board’s investment in DPC was a consequence of a

directive issued to it by the Govt. of Maharashtra (GoM) under Section 78(A) of the same

Electricity (Supply) Act, 1948. The GoM had directed the Board to invest in share capital of

enterprises involved in or concerned with the business of generation, transmission or

distribution of power in the State of Maharashtra. Hence, apart from its own operations with

respect to generation, transmission and distribution of energy, the acquisition of 30% equity

stake in DPC was a mandated business of the Board under the realm of the Act.

Consequently, the interest expense incurred by the Board was a result of an operation carried

out under the Act and has to be considered by MERC in the tariff and revenue requirement

determination process.”

The Commission does not agree with the MSEB’s interpretation of Section 59 of the ESA and

its arguments in favour of including the interest expenditure on account of investment in

DPC. The Commission has disallowed this expenditure while estimating the total interest

expenditure.



On analysis of the loans taken by the MSEB in FY 2002-03 and projected for FY 2003-04,

the Commission has determined that the MSEB has been taking loans to meet its revenue

shortfall apart from the projected capital expenditure. The Commission is of the opinion that

this method of computation results in increasing the revenue gap further, and is inappropriate.

Further, as the Commission is matching the revenue requirement through the revised tariffs,

there is no need to consider additional loans to fund the revenue gap. Additional loans cannot

be allowed to make up for the loss in revenue due to the late submission of the Tariff Petition.

Hence, the Commission has considered additional loans to the extent of the projected capital

investment only, by proportionately reducing the amount of additional loan from each

institution.

The Commission has computed the interest on long-term loans based on the average balance

of the outstanding loans (average of opening and closing levels of long- term loans during the

year) and the average interest rate applicable on these loans as submitted by the MSEB. The

Commission has considered the same rate of capitalization projected by the MSEB.

27.2.6.1 Interest on Working Capital

The MSEB has submitted that its working capital borrowings have been much less than the

actual working capital requirement, as the MSEB has been defering its payments, to match its

inflows. The MSEB has submitted that it has become more difficult in the recent past to defer

payments, as its suppliers have become commercially oriented. The working capital

requirement of the MSEB is on account of need to fund receivables and its inventory. The

MSEB has projected working capital requirement, based on 2 months receivables and 15 days

of generation costs. The MSEB has submitted that the average security deposit has been

estimated and subtracted from the working capital requirement, and the net working capital

requirement has been estimated as 0.75 x (Current Assets – Current Liabilities), in line with

the Commission’s computation in the previous Tariff Order. The Commission has computed

the net working capital requirement on the same basis, at an interest rate of 10%, as projected

by the MSEB. The net working capital requirement has been estimated as Rs. 546 crore, and

the working capital interest has been projected as Rs. 55 crore.

The total interest expense allowed by the Commission for FY 2003-04 is Rs. 1126 crore, net of capitalisation.



27.2.7 Provision for Doubtful Debts

The total receivables of the MSEB amounted to Rs. 8765 crore as on 31 March 2003, which is equivalent to almost 9 months of sales revenue in FY 2002-03. The Commission had directed the MSEB to reduce the receivables in a time-bound manner. The Commission had set the MSEB a target of reducing the receivables to an equivalent of 5 months of the sales revenue in FY 2001-02. The Commission had further specified that the MSEB should reduce the receivables every year in this fashion, and the permissible limit would be only 2 months of receivables. On the contrary, the receivables of the MSEB have increased to almost 9 months of sales revenue. This is clearly unacceptable, and the MSEB should take urgent steps to redress the situation, rather than give excuses for the situation it finds itself in.

The MSEB has projected the provision for doubtful debts at Rs. 250 crore, which is around

2% of the revenues from revised tariffs projected by the MSEB for FY 2003-04. The

Commission is of the view that a provision equivalent to 1.5% of projected revenue in the

year is reasonable, and has hence allowed a provision of Rs. 181 crore in FY 2003-04,

considering the revenue from sale of electricity with existing tariffs being applicable for 8

months and revised tariffs being applicable for 4 months in FY 2003-04.

27.2.8 Other Expenses

The MSEB has projected other expenses of Rs. 248 crore in FY 2003-04. The Commission

has accepted the MSEB’s projections of Other Expenses, except on two heads. The average

interest expenditure incurred by the MSEB on consumers’ security deposits over the past

three years works out to 3.32%, as compared to the MSEB’s projection of 5.1%. Hence, the

Commission has considered the quantum of security deposit and the average interest rate of

3.32%, to project the interest on consumer’s security deposit. The Commission has also

reduced the miscellaneous expenses to normative levels. The total Other Expenses allowed by

the Commission for FY 2003-04 is Rs. 206 crore. The details of the Other Expenditure

allowed by the Commission in the past and the actual expenditure incurred by the MSEB over

the past four years are presented in the following Table:



Table: Other Expenses over the past four years


Tariff Order

1 Interest on consumers' security deposit (Sch.12) 46.32 61.67 40.36 41.48 75.39 48.26

2 Commitment charges(Sch.12) 1.87 2.00 1.76 1.93 1.92 1.923 Bank Charges/commission for

remittances (Sch.12) 45.05 54.52 53.98 37.85 41.64 41.644 Guarantee charges(Sch.12) 62.21 93.68 85.89 92.65 91.81 91.815 Loss on exchange rate

variations(Sch.15) 12.29 13.00 11.53 4.79 10.25 10.256 Tax on sale of electricity (Sch.15) 28.57 0.00 0.00 0.00 0.00 0.007 Write-off of deferred revenue

expenditure(Sch.15) 18.52 18.50 13.95 0.10 0.10 0.108 Recovery cost of agricultural

consumers (Sch 15 & 18) 0.21 0.00 0.17 0.00 0.00 0.009 Others 4.48 11.30 60.31 85.30 27.23 12.29

10 Penal interest on late payment of Government guarantee fee 0.00 Total 219.52 254.67 267.95 264.10 248.34 206.27

ParticularsSl FY01 FY03

FY02 FY04

27.2.9 Surplus

The MSEB is entitled to earn a mandatory surplus at the rate of 4.5% on its Net Fixed Assets

at the beginning of the year, as per S. 59 of the E (S) Act, and the GoM’s gazette notification

in this regard. The Commission has hence, considered the surplus at the rate of 4.5% on the

NFA at the beginning of the year, as Rs. 433 crore, which is the same as the MSEB’s

projections.

27.3 Annual Revenue Requirement

The Annual Revenue Requirement of the MSEB is the summation of all the expenses and the

surplus as specified above, and has been summarized below:



Annual Revenue Requirement in FY 2003-04 (Rs. Crore)

Sr No

Expense Head MSEB Proposal

(Rs. Crore)

MERC Approval (Rs.Crore)

Remarks

1 Generation 4243 4104 MSEB has considered higher than normative heat rate, transit losses, and escalation in fuel costs

2 Power Purchase 3493 3132 MSEB has considered higher power purchase quantum and escalation in power purchase costs

3 Employee Costs 1695 1655 MSEB has projected higher employee costs despite reducing trend

4 Administration & General expenses

145 139

5 Operation & Maintenance 738 737 6 Depreciation 1585 1578 MSEB has considered a higher

weighted average rate 7 Interest cost 1308 1126 MSEB has considered higher loans

and higher interest on working capital 8 Lease Rental 85 85 9 Provision for doubtful debts 250 181 MSEB has considered provisioning at

the rate of 2% of revenue from sale of electricity

10 Other Expenses 248 206 MSEB has considered higher interest expenditure on consumers’ security deposit

Total Expenses 13790 12943 Add: Surplus 433 433 Total Revenue Requirement 14223 13376

Thus, the total revenue requirement projected by the Commission for FY 2003-04 is Rs.

13376 crore.



28. REDUCTION IN ANNUAL REVENUE REQUIREMENT

The net revenue to be recovered through tariffs on sale of electricity has been projected

after reducing the Annual Revenue Requirement, due to the following reasons:

1. Revenue earned through FOCA for additional expenses in FY 2001-02

2. Other Income

28.1 Revenue Earned through FOCA

The Commission has deducted the amount recovered through FOCA for additional expenses

incurred in the months of April, May and June 2003 amounting to Rs. 135 crore, from the

revenue requirement of FY 2003-04, as the actual generation and power purchase costs

incurred during this period have been considered, subject to performance norms, for

projecting the total costs in FY 2003-04. Any additional amount recovered by the MSEB

through the FOCA formula for increase in costs in FY 2003-04 after June 2003, if any, will

be adjusted against the FOCA recoverable henceforth.

28.2 Other Income

The MSEB has projected revenue from ‘Other Income’ to the extent of Rs. 1022 crore in FY

2003-04. The Commission has accepted the MSEB’s projections of Other Income, except in

certain cases. The MSEB has projected a lower income from ‘recovery from theft of power’

and ‘wheeling charges’ as compared to the actual income in previous years, while the

Commission has projected income at previous years’ levels. In the case of ‘interest from

consumers’ and ‘other receipts’, the MSEB’s projections were substantially lower than the

CAGR. Hence, the Commission has considered a normative increase of 10 % in these revenue

streams.

The total ‘Other Income’ projected by the Commission is Rs. 1067 crore.

28.3 Net Revenue Requirement

Thus, the net revenue requirement allowed by the Commission for recovery through tariff in

FY 2003-04 is Rs. 12174 crore. The average cost of supply for FY 2003-04 works out to Rs.



2.83 per unit, after removing the cost of the excess T&D losses. The cost of excess T&D

losses has been computed as follows:

The excess T&D loss, i.e. the difference between the allowed T&D loss level of 26.87% and

the actual T&D loss of 36.62% considered for estimating the energy input requirement,

amounts to 9.75% of energy input, which amounts to 6107 MU. The cost of this excess

quantum of energy has been computed at the average power purchase cost of Rs. 1.55 per

unit, which amounts to Rs. 947 crore. The Commission has provided for a new mechanism,

i.e. Regulatory Liability Charge (RLC), to recover the cost of the excess T&D losses. The

details of the Regulatory Liability Charge have been discussed in the subsequent Section on

Tariff Philosophy.

The revenue from existing tariff works out to Rs. 12030 crore. Thus, there is an uncovered

revenue gap of Rs. 144 crore in FY 2003-04, with the existing tariff. If the revised tariffs were

to be charged for the entire year, then the revenue gap to be recovered through revised tariffs

would be Rs. 144 crore. However, in FY 2003-04, the revised tariffs will be in force

for only four months, as the Commission has always maintained that the tariffs cannot be

revised retrospectively.

The Commission has introduced high load factor incentive and reclassified certain consumer

categories, the impact of which cannot be assessed accurately at this point in time with the

available data. The Commission has hence determined the category-wise tariffs such that the

additional revenue recoverable in the remaining four months of FY 2003-04 with revised

tariffs is around 62 crore, as compared to the requirement of Rs. 48 crore. However, in case

there is any revenue shortfall compared to the Commission’s projections due to the tariff

classification changes and other rebates given in this Order, the Commission will consider it

in the future.

29. TARIFF DESIGN PRINCIPLES

Apart from the general tariff design principles that the Commission has been following over

the years, the Commission has in this Order also taken a decision regarding the recovery of

the cost of excess T&D losses. In the following paragraphs, the Commission has discussed

the problem of excess T&D losses, the genesis of the decisions taken by the Commission in



the past vis-à-vis T&D Loss Charge, the results of the levy of T&D loss charge, and the need

for a different approach to the problem.

29.1 Treatment of Excess T&D losses

In the Tariff Order issued in January 2002, the Commission had initiated the process of

levying the ‘T & D loss Charge’ for all consumers, in proportion to the average realisation

from that category. By introducing this charge, the Commission intended to create awareness

among the consumers regarding the additional cost of the excess T&D losses by levying this

charge in an explicit manner. Hence, a more or less uniform T & D loss charge had been

levied to start with. Moreover, the Commission had declared its intent to differentiate between

the various circles/zones for the levy of the T & D loss charge, based on the T & D losses

exhibited by the circle/zone in question. As an interim measure, in January 2003, the

Commission had declared that 11 circles with T&D loss levels lower than the target loss level

of 26.87% would be exempted from payment of T&D loss charges. It should be noted that

T&D loss charge was not an additional charge and was a part of the regular tariff, which the

consumers were always paying, though the separation of tariff due to excess T&D losses was

not indicated explicitly earlier.

The Commission is of the view that the “T&D loss charge” concept has achieved a certain

level of success in that the stakeholders are certainly much more aware of the extent of the

problem, and atleast some circles have shown some improvement in the T&D loss levels.

However, the Commission is of the view that, after having achieved the objective of bringing

the issue of T&D loss in sharp focus, continuing levy of T&D loss charge, though withdrawn

for certain circles earlier, cannot be a long-term solution in absence of accurate energy

accounting and difficulty in realistic assessment. Therefore, the problem has to be addressed

in some other manner, which will not create a situation unviable for MSEB to provide service

at least at today’s level but also will be driven for reduction in T&D loss to remain viable as a

commercial entity. Hence, as an interim measure, the T&D loss charge has been withdrawn

for all consumer categories in all circles, with effect from December 1, 2003.

The problem arises in the assessment of the losses itself. Even if the Commission were to take

a strict view that only the technical losses should be allowed and all the commercial losses



should be to the MSEB’s account, the problem remains with the assessment of the technical

losses. Though the MSEB has submitted in the past that the technical losses could be in the

range of around 21%, this number has to be verified through load flow studies. In the absence

of any certainty on this issue, the Commission is constrained to accept the target loss level at

26.87% for the purposes of this Order.

If the cost of all the excess losses were disallowed, then it is most likely that the MSEB will

be unable to meet its daily requirements and will be unable to supply power to its consumers.

This is not in the consumers’ interest, and till a viable alternative emerges, the MSEB has to

continue to supply electricity to the consumers in the State. The Commission is of the opinion

that a pragmatic decision has to be taken in the best long-term interest of the electricity

consumers in the State as well as the MSEB. Moreover, this is a transition period and the

MSEB is likely to be restructured in line with the principles enunciated in the EA 2003. The

Commission hopes that the restructuring will help the successor entities achieve the T&D loss

reduction as envisaged, due to better accounting of energy at different interconnection points

and implementation of profit centre concept, such that the T&D losses are reduced in absolute

MU terms.

In this context, the Mumbai Grahak Panchayat (MGP), a S.26 consumer representative has

suggested that if the MSEB needed ‘Oxygen’ in the form of tariffs to recover the cost of the

excess losses, the consumers would be willing to contribute the same, provided the

Commission treated this contribution as a Regulatory Liability owed by the MSEB to the

consumers, as this was not part of the MSEB’s rightful revenue requirement. The

Commission has given serious thought to this suggestion, and is of the opinion that this

interim measure may solve the current predicament. However, this is only an interim measure

and not intended to replace the differential T&D loss charge mechanism.

The circle-level energy audits should continue, and the MSEB should operate these circles as

profit-centres with adequate monitoring. Once, more reliable estimates of circle-level T&D

losses are possible, the Commission may revert to the differential T&D loss charge

mechanism.

As regards the Regulatory Liability, the Commission is of the opinion that only subsidizing

consumers should contribute to the Regulatory Liability, which would have to be returned by



the MSEB in future. Hence, the Regulatory Liability Charge (RLC) has been designed such

that all the subsidizing categories contribute the same amount of RLC to keep the MSEB

afloat. Subsidized categories cannot be expected to contribute to the Regulatory Liability as

they have yet to move towards the average cost of supply. Thus, for subsidizing categories, a

separate component of tariff has been shown as ‘Regulatory Liability Charge’ which will be

used by the MSEB for funding the cost of the excess T&D losses, which will be returned to

these consumer categories in future through tariffs.

The Regulatory Liability requirement is equal to the cost of the excess losses, i.e. the cost of

additional power purchase required on account of the higher energy input requirement. The T

& D loss level proposed by the MSEB for FY 2003-04 is 36.62%, as compared to the target

of 26.87% set by the Commission. The balance losses of 9.75% equivalent to 6107 MU are

thus excess losses vis-à-vis the targets.

The net cost of the excess energy input requirement is Rs.947 crore (6107 MU at an average

rate of Rs. 1.55 per unit). Thus, there is a need to contribute Rs. 947 crore towards the

Regulatory Liability over a period of one year. The average rate of contribution works out to

50 paise per unit for the subsidizing categories, viz. LT commercial, LTPG, HTP I, HTP II

and Railways.

In future, when the T&D losses are reduced, then the RLC will be returned to these consumer

categories through reduction in tariffs. The Commission clarifies that the contribution through

RLC will not be recorded and maintained separately for each individual consumer and the

category as a whole is expected to get the contribution back.

MSEB is directed to submit on a six monthly basis information on:

1. Category-wise RLC. 2. Circle-wise and total T&D loss level in units as well as percentage.

The first such report for the entire year 2003-04 should be submitted by the end of May, 2004

and should also include total TDL charges (Circle-wise). Subsequent reports should be

submitted within 2 months of the close of the half-year.



29.2 General Tariff Design Principles

The Commission has adopted certain general principles, which are in continuation of the process of tariff rationalisation initiated in the previous Tariff Orders, and the provisions of the ERC Act, 1998, and the EA 2003. In general, the movement of tariffs towards the average cost of supply has been maintained such that inter-class cross-subsidy is reduced within the indicated time-frame of 5 years. The Commission has also attempted to ensure that even the intra-class cross-subsidy, i. e., subsidy given by consumers in other slabs within the same category is reduced, by reducing the difference between the highest and lowest slab rates as well as reduction in the number of slabs to the extent possible.

The rebates/incentives such as power factor incentive, bulk discount and prompt payment incentive have been retained at the existing levels. The power factor penalty has been modified such that the penalty is levied in a graded manner similar to the power factor incentive.

The Commission is of the opinion that the MSEB faces a threat from movement of consumers having very high consumption to captive generation, under the provisions of the Electricity Act, 2003 (EA 2003). The ERC Act, 1998, as well as the EA 2003 provide for differentiation between consumers on the basis of their load factor, while determining their tariff. Hence, in order to incentivize such high consumption consumers who also contribute a steady load to the MSEB system, the Commission has introduced a Load factor incentive for consumers having Load Factor above 75% based on contract demand. Consumers having load factor over 75% upto 85% will be entitled to a rebate of 0.75% on the energy charges for every percentage point increase in load factor from 75% to 85%. Consumers having a load factor over 85 % will be entitled to rebate of 1% on the energy charges for every percentage point increase in load factor from 85%. The total rebate under this head will be subject to a ceiling of 15% of the energy charges for that consumer. The Commission is of the opinion that the load factor rebate will enable the high consumption industrial consumers to reduce their costs, and will also ensure that these consumers are retained by the MSEB.

This incentive is limited to HTP-I and HTP-II categories only. Further, the load factor rebate will be available only if the consumer has no arrears with the MSEB, and payment is made within seven days from the date of the bill or within 5 days of the receipt of the bill, whichever is later. However, this incentive will be applicable to consumers where payment of arrears in instalments has been granted by the MSEB, and the same being made as scheduled. The MSEB has to take a commercial decision on the issue of how to determine the time frame for which the payments should have been made as scheduled, in order to be eligible for the Load Factor incentive.



The Load Factor has been defined below:




x (Total no. of hrs during the month less planned load shedding hours*)

* - Interruption/non-supply to the extent of 60 hours in a 30 day month has been built in the

scheme.

It should be noted that the load factor incentive will not give additional weightage for cases

where the consumer exceeds the contract demand in a particular month, and will be computed

only on the basis of the Contract Demand in kVA.

The Commission has increased the differential between tariff applicable for peak hour consumption and off-peak hour consumption by 20 paise per unit, respectively, and off-peak times for the HTP-I and HTP-II categories by 10 paise per unit for peak. The Commission also directs that MSEB should install ToD meters for all consumers with a connected load of over 20 kW, so that ToD tariffs can be availed by these consumers at their option.

In the FY 2000-01 Tariff Order, the Commission has directed the MSEB to charge domestic tariffs from certain professional categories if these professionals were using part of their residences for professional work. The Commission clarifies that the domestic tariffs will be applicable only to residential premises used by professionals such as Lawyers, Doctors, Chartered Accountants, etc. except for nursing homes and surgical wards/clinics, in furtherance of their professional activity in their residences.

The original philosophy behind creation of two categories, viz. HTP-I comprising consumers located in the load centres of Mumbai (Mumbai Metropolitan Region – MMR) and Pune Metropolitan Region (PMR), and HTP-II comprising all other HT industrial and general HT consumers, was to encourage industrial growth in the backward regions of the State, by giving the benefit of lower electricity tariffs for industries set up in the non-BMR/PMR areas. However, over a period of time, the MSEB has modified the classification of HTP-I to include industrial consumers whose contract demand is above



500 kVA and situated outside MMR and PMR, but situated in Thane, Pune, Raigad districts, urban agglomerations of Nasik and Aurangabad including industrial estates located in these regions. By doing so, several industrial consumers have been brought under HTP-I category, which has a higher tariff. This is not in consonance with the original idea behind creation of these two separate categories. The Commission has hence reclassified the HTP I category to include only those HT industrial and other HT consumers situated in the Mumbai Metropolitan Region (MMR) and Pune Metropolitan Region (PMR), as defined by the State Government. The balance HT industrial and other HT consumers would be classified under HTP II category.

In July 2003, the GoM announced the IT and ITES Policy, 2003 for promoting business and enterprise in the IT industry, to make Maharashtra the most favoured destination for investments in the IT and ITES industry. In the context of the infrastructure support to the IT and ITES sector, the Policy specifies under Clause 4.2 (h) that, “Levying of power charges on IT and ITES units at industrial rates and notifying IT and ITES units as a separate category of consumers through MERC”. In line with the recently announced IT and ITES Policy announced by the GoM and the stated philosophy of the Commission in previous Orders, the Commission has included the Low Tension IT industry and IT enabled services (as defined in the GoM Policy) in the LTPG category, for purposes of tariff.

In the context of classification of State Government sponsored Lift Irrigation Schemes (LIS) under the HTP-II category, and the other LIS being classified under HTP-VII, the Commission is of the opinion that there is no rationale for classifying the LIS schemes under different categories on the basis of their ownership. The MSEB’s Tariff Schedule includes all HT agricultural pumping loads and does not exclude any particular segment of LIS. The Commission hence rules that all the Lift Irrigation Schemes (LIS) will be classified under the HTP-VII category, irrespective of ownership.

The seasonal category will include all consumers who opt for a seasonal pattern of consumption, without the need for further approval from the Commission. The consumers should approach the MSEB for classification under the seasonal category if their business is such that electricity requirement is seasonal in nature. The shift from seasonal to normal connection and vice-versa can be done only once each year, at the beginning of the year.

The additional standby charges of Rs. 20 per kVA per month will be applicable to HT industrial consumers with captive generating units synchronized with the MSEB grid, only on the extent of standby demand, and not the entire contract demand as prevalent currently. In case there is no standby demand, and the captive unit is synchronized with the grid only for export of power, then the additional standby demand charges of Rs. 20 per kVA will not be applicable.



As all the hitherto un-metered consumer categories have been metered, except LT agriculture, the Commission has specified flat rate tariffs only for the un-metered LT agriculture category. The difference in metered tariff and the flat rate tariffs has been increased to incentivize un-metered consumers to opt for metering.

As stated earlier, the Commission has been compelled to continue with the flat rate tariffs for LT agriculture category, as the MSEB has not complied with the Commission’s directives given in earlier Tariff Orders, regarding 100% metering of all consumers. Further, despite the Commission’s directive to meter all the agricultural DTCs, this has not yet been achieved, and even the meters on the sample feeders are not read regularly. Hence, the Commission has been constrained to assess the consumption norms based on the energy audits of the sample feeders provided by MSEB. The Commission is aware that there are consumers who consume less/more than the average consumption norm assessed for the entire State, as the average consumption norm is a weighted average consumption norm. This is also supported by the fact that the average consumption of around 4 lakh LT agricultural metered consumers is only around 500 hours/HP/year. The Commission has hence been constrained to introduce differential flat rate tariff for LT agricultural consumers so as to move towards a tariff which reflects the consumption pattern in some way, in the absence at present of 100% metering.

The Commission has considered an average consumption norm of 1300 hours/HP/year in case of flat rate LT agricultural consumers, based on the available sample energy audit data submitted by the MSEB. The Commission has attempted to determine the flat rate tariffs for agriculture category such that the tariffs reflect the actual consumption pattern. This has been done by specifying circle-wise differential flat rate tariffs linked to the agriculture consumption norm as established by the energy audit data for that circle. To start with, the Commission has specified two tariff levels, viz. lower tariff for circles with consumption norm lower than the average consumption norm of 1300 hours/HP/year, and higher tariffs for circles with consumption norm higher than the average consumption norm of 1300 hours/HP/year. The Commission hopes that this will incentivize the shift to metered consumption at a faster rate.

The Commission would like to add that with higher level of DTC metering and with increase in the sample size, based on statistical sampling techniques, the tariff bands as well as the classification of consumers within the consumption bands may undergo a change. MSEB is directed to submit Circle-wise estimates of pump-running hours of unmetered agricultural consumers on a quarterly basis. The first such report (for the entire year 2003-04) should be submitted to the Commission by the end of May, 2004.



The energy charge to be levied for net sale to the TPC has been increased to match the highest cost of power purchase, i.e. 299 p/u. The tariff applicable for sale to Mula Pravara Electric Co-operative Society (MPECS) has been retained at the existing levels. The Commission is separately forwarding a Report on the viability of the MPECS to the Government of Maharashtra (GoM).

The Commission directs the MSEB to compile data on reactive power consumption by all consumer categories where electronic meters are already installed, as the Commission intends to introduce kVARh tariffs in the subsequent Order. The kVARh consumption data for each billing cycle should be submitted alongwith the next ARR and Tariff Petition.

The Commission directs the MSEB to collect and submit relevant data regarding the consumption of defence category, which is currently classified under HTP II and HTP VI, in different areas. In the subsequent Order, the Commission intends to move all such consumer categories to a tariff structure similar to that applicable to HTP VI category, where the consumer is responsible for the sub-distribution, billing and collection. This data should be submitted alongwith the next ARR and Tariff Petition.

The Commission has attempted to increase the recovery from fixed charges, which ranged around 35% of the fixed costs in the existing tariffs, to around 40% in the revised tariffs. The energy charges have been adjusted in such a way that the average realisation from each consumer category approaches the average cost of supply, while at the same time ensuring that no consumer category faces a tariff shock. However, considering the extremely low levels of the existing tariffs of categories such as agriculture, rural PWW, etc., it is inevitable that the tariff hike for these categories will be considerably steeper than that for other categories. The movement of the category-wise average realisation towards the average cost of supply has been shown in the Table below:



29.2.1.1.1.1 Table: Movement of Average Realization towards Average Cost of Supply

CategoryExisting

TariffRevised

TariffExisting

TariffRevised

Tariff(a) (b) (c) (d)=(b)/(a) (e)=(c)/(a) (f)=(e)-(d)

LT CategoryDomestic (LD-1) 2.83 2.62 2.79 93% 99% 6%Non-domestic (LD-2) 2.83 4.46 3.91 158% 138% -19%General Motive Power 2.83 3.36 2.83 119% 100% -19%Public Water Works

Urban PWW 2.83 2.67 2.82 94% 100% 5%Rural PWW 2.83 1.36 1.54 48% 55% 6%

Agriculture 2.83 1.45 1.94 51% 69% 17%Street Lighting 2.83 2.18 2.41 77% 85% 8%Sub Total LT 2.83 2.46 2.57 87% 91% 4%

HT CategoryHTP-I 2.83 3.79 3.09 134% 109% -25%HTP-II 2.83 3.68 2.90 130% 103% -27%HTP-III 2.83 3.19 2.78 113% 98% -14%HTP-IV 2.83 3.06 2.78 108% 98% -10%HTP-V (Railway Traction) 2.83 4.15 3.35 147% 118% -28%HTP-VI 2.83 2.65 2.64 94% 94% 0%HTP-VII (Agriculture) 2.83 1.00 1.41 35% 50% 15%Mula Pravara 2.83 2.08 2.08 73% 73% 0%Sub Total HT 2.83 3.83 3.20 136% 113% -22%

Average Realisation

(Rs./unit)

Ratio of Average Realisation to

Average Cost of Supply (%)

Percentage point increase/ decrease in Tariff w.r.t Avg. CoS

Average Cost of Supply (excluding

cost of excess T&D losses)

(Rs./unit)

Note: Revised tariff excludes Regulatory Liability Charge, applicable to the following categories - non-

domestic, LTP-G, HTP-I, HTP-II, Railways

The Commission has thus reduced the cross-subsidy between different consumer categories and tariff for all subsidised categories has been specified at least equal to 50% of the average cost of supply. The above method of viewing the tariff revision with respect to the relationship with the average cost of supply is the appropriate method, as compared to the method of looking at the tariff increase in percentage terms with respect to the existing tariff. For instance, the tariff hike for LT and HT agriculture would appear to be substantial, simply because the existing tariff levels are very low. Any tariff hike over a small base is bound to appear very high.

The Commission would like to highlight the MSEB’s approach to tariff determination, and the inconsistent approach followed by the MSEB in this regard. MSEB has been proposing a different tariff philosophy in each Tariff Petition. In its first Tariff Petition



for FY 2000-01, the MSEB had proposed a substantial increase in the tariffs of subsidized categories. In its second Tariff Petition, the MSEB proposed a substantial reduction in the number of categories and proposed a severe tariff rationalization, where the tariffs of subsidized categories such as domestic and agriculture, would reach the average cost of supply in a single year, and the tariffs of the subsidizing categories would be reduced substantially. In the current Tariff Petition, the MSEB has proposed that the tariffs for the subsidizing categories should be increased, as the subsidized categories, mainly LT agriculture segment has a poor payment record, and any increase in tariff for these categories would not result in increased liquidity for the MSEB.

The Commission finds the approach extremely inconsistent, and against the principles of tariff determination required to be followed under the ERC Act, 1998. Moreover, the MSEB cannot shift the burden of its inefficiency in collection of its bills, to the subsidizing categories, on the ground that they have a better payment record. The Commission would like to stress here that it has consistently followed the approach of gradual reduction in cross-subsidy and avoidance of tariff shock to any consumer category.

The MSEB has also stated that the flat rate tariffs should be substantially higher than the metered tariffs or LT agriculture category, in order to incentivize the shift to metered consumption, which in turn would enable more accurate assessment of T&D losses. However, the MSEB has not proposed any substantial increase in the flat rate tariffs, to widen the differentia; between the flat rate and metered tariffs. The Commission, while determining tariffs, has kept this in mind, and has increased the differential between flat rate and metered tariffs.

The Commission has introduced high load factor incentive and reclassified certain consumer categories, the impact of which cannot be assessed accurately at this point in time with the available data. The Commission has hence determined the category-wise tariffs such that the additional revenue recoverable in the remaining four months of FY 2003-04 with revised tariffs is around 62 crore.

It should be noted that all the provisions of the previous Tariff Order issued on January 10, 2002 are still valid, unless explicitly modified/introduced through this Order.

29.3 Energy Conservation

Conservation of energy through energy efficiency is very essential, to bridge the gap between demand and supply. The objective of energy efficiency is two fold, viz. to increase the generation through energy efficiency at the generation level, and to manage the demand through Demand Side Management (DSM) techniques, which include load shaping as well as reduction in the consumption levels through use of energy efficient



devices. The Commission directs the MSEB to conduct a detailed study of the potential benefits that could accrue from measures to improve the energy efficiency. The Commission directs the MSEB to prepare a detailed plan to promote energy efficiency at the consumer end and to quantify the potential benefits from these measures. The detailed plan should be submitted to the Commission within three months of this Order.

29.4 RELIABILITY CHARGE

The Commission had initiated the process of levying a ‘Reliability Charge’ to begin with, on HTP-I and HTP-II consumers who have been provided with ToD meters, within urban agglomerations in the State, on consumers receiving power supply through Express Feeders and also those within MIDC areas. The MSEB was allowed to impose an additional charge of 25 paise per kWh to these consumers and ensure that they get uninterrupted power supply. However, the MSEB has not progressed very far in implementing the Reliability Charge, even though it would have resulted in additional revenue, which could have been gainfully employed in strengthening/augmenting the system to improve the quality of supply to consumers.

In this context, the Commission has had discussions with the MSEB officials on the MSEB’s preparedness to implement levy of Reliability Charge and the proposed modalities for the same. The Commission asked the MSEB to submit a concrete proposal addressing the areas like (i) time frame, (ii) requirement of investment, manpower and its sources, (iii) locations to be covered initially, (iv) number of consumers to be covered, (v) revenue collection through reliability charges, (vi) system improvements required to be undertaken by ploughing back the revenue earned through reliability charges, (vii) value addition to the central system, and (viii) dispute resolution mechanism.

The Commission also suggested that the MSEB should define the term “reliability charge”, frequency and voltage and other parameters, to ensure that the consumers are offered a value added proposition. Further, the Commission suggested that once the terms were defined, certain agreed parameters such as frequency, voltage, etc. should be guaranteed by the MSEB. In case the MSEB is unable to offer such guarantees in the first year, then there should be a commitment to achieve them within a fixed time period by upgradation of system utilizing the revenue earned through reliability charges. The Commission suggested the setting up of ‘dispute resolution cells’ at the Divisional/Zonal level itself and authorize the circle-in-charge.

During the discussions, the MSEB stated that any system improvement project takes about two to three years for completion. The MSEB added that though the frequency is beyond local control, voltage regulation improvement can be targeted and achieved within a shorter



span of time. The MSEB agreed to chalk out a comprehensive plan addressing the issues spelt out by the Commission and other points, and place the same before the Commission for its approval. The MSEB also assured the Commission that the project will be implemented after the Commission’s approval. However, the MSEB has not submitted its Proposal in this regard and has consequently lost an opportunity to garner additional revenue that could have been gainfully employed in improving the network infrastructure to enable better quality supply to the consumers. The MSEB is directed to approach the Commission with the Comprehensive Plan for levy of the Reliability Charge, at the earliest.

The MSEB should ensure that a copy of the Tariff Order is available with each billing unit and the concerned Chief Engineer and Superintending Engineer, to ensure proper implementation of the Tariff Order.

The revised tariff applicable for all categories of consumers from December 1, 2003 has been shown below. The comparison of existing tariff and the tariff determined by the Commission has been presented in Appendix 1.



Summary of LT Tariff (Effective from December 1, 2003)



Energy Charge

(p/u)


(p/u) Domestic (LD 1)

0-30 Units Rs. 20 per service connection 125 31-300 Units 290 Above 300 units (only balance Units)

Single Phase: Rs. 40 per service connection; Three Phase: Rs. 100 per service connection; Additional Fixed charge of Rs. 100 per 10 KW load or part thereof above 10 KW load shall be payable.

400

0

Non Domestic (LD2) 0-100 Units 240 101-200 Units 315 Above 200 units (only balance Units)

Single Phase: Rs. 100 per service connection; Three Phase: Rs. 150 per service connection; Additional Fixed Charge of Rs. 150 per 10 KW load or part thereof above 10 KW load shall be payable. Optional LTMD based Tariff will be available for all consumers.

410

50

General Motive Power (LTP-G) – Base Tariff 0-1000 Units 230 Above 1000 Units (only balance Units)

Rs. 60 per HP (Rs. 80.5 per kW) per month for 50% of sanctioned load; Optional MD based tariff will be available for all consumers, irrespective of Contract demand, at Rs. 220/kVA/month

250 50





Energy Charge

(p/u)


(p/u) OPTIONAL TOD TARIFF 2200 hrs – 0600 hrs -75 0600 hrs – 0900 hrs 0 0900 hrs – 1200 hrs 50 1200 hrs – 1800 hrs 0 1800 hrs – 2200 hrs

0

90 Public Water Supply Urban P. W. Schemes


Rural P. W. Schemes Grampanchayat Rs. 25 per HP per month 100 Metered Tariff (incl. ‘C’ Class Municipal Council)


0

Street Light Tariff Grampanchayat & Municipal Council

210

Municipal Corporation

Rs. 30 per kW per month

250

0

Agriculture Flat Rate Tariff Category 1 circles* Rs. 180 per HP per month Category 2 circles$ Rs. 150 per HP per month

0 0

Metered Tariff (incl. Poultry Farms)


*Category 1 Circles (with consumption norm above 1300 hours/HP/year) 1 Chandrapur 4 Latur 7 Osmanabad 2 Jalna 5 Nanded 8 Parbhani 3 Kolhapur 6 Nashik 9 Sangli



$Category 2 Circles (with consumption norm below 1300 hours/HP/year) 1 Ahmednagar 10 Buldhana 19 Pune (U) 2 Akola 11 Dhule 20 Ratnagiri 3 Amravati 12 Gadchiroli 21 Satara 4 Aurangabad 13 Jalgaon 22 Sindhudurg 5 Aurangabad (U) 14 Kalyan 23 Solapur 6 Beed 15 Nagpur ® 24 Vasai 7 Bhandara 16 Nagpur (U) 25 Wardha 8 Bhandup 17 Pen 26 Vashi 9 Bhiwandi 18 Pune ® 27 Yavatmal

Notes:

FOCA shall be applicable to all categories of consumers. FOCA will be determined monthly based on the FOCA Formula approved by the Commission.

Billing Demand for LTPG and other LT categories opting for MD based tariff :


iv. Actual Maximum Demand recorded in the month during 0600 hours to 2200 hours v. 75% of the highest billing demand recorded during preceding eleven months

vi. 50% of the Contract Demand.

The definition of Connected Load will be as under:

Connected Load (CL) shall mean sum of the rated capacities of all energy consuming

apparatus duly wired and connected to the power supply system including portable apparatus

in the consumer’s premises. Further, CL shall be calculated after allowing a tolerance of 5%.

CL shall not include load of spare plug sockets, stand by or spare energy consuming

apparatus installed authorisedly, through change over switch, which cannot be operated

simultaneously and load exclusively meant for firefighting purposes. Equipment under

installation and not connected electrically, equipment stored in warehouse/showrooms either

as spare or for sale is not to be considered as ‘CL’.



Summary of HT Tariff Effective from December 1, 2003

Consumer Category Demand Charge (Rs/KVA/month)

Energy Charge

(p/u)

Regulatory Liability

Charge (p/u)

HTP – I (Industrial - BMR/PMR) Base Tariff

350 215 50

HTP – II (Industrial – Others) Base Tariff

330 210 50

ToD Tariff (for HTP-I & HTP-II)


0

100 Seasonal Category 350 300 0 HTP – III (PWW-BMR/PMR)

350 215 0

HTP – IV (PWW-Others) 330 210 0 ToD Tariff (for HTP-III & HTP-IV)


0

100 HTP - V (Railway Traction) 0 335 50 HTP – VI Residential Complex 220 Commercial Complex

125 350

0

HTP VII (Agriculture)1 Metered Tariff (incl. Poultry, agriculture High tech)

25 130 0

Tata Power Company 600 299 0 Mula Pravara Electric Co-op Society

200 150 0

Inter State Sale 0 260



Notes:

1. HTP VII category includes HT Lift Irrigation Schemes irrespective of ownership 2. FOCA shall be applicable to all categories of consumers. FOCA will be determined

monthly based on the FOCA Formula approved by the Commission 3. Billing Demand definitions:

HT Categories (HTP-I, HTP-II, HTP-III, HTP-IV)

Monthly Billing Demand will be the higher of the following: iv) Actual Maximum Demand recorded in the month during 0600 hours to 2200 hours v) 75% of the highest billing demand recorded during preceding eleven months vi) 50% of the Contract Demand.

Seasonal Category

During Declared Season


i) Actual Maximum Demand recorded in the month during 0600 hours to 2200 hours ii) 75% of the Contract Demand iii) 50 kVA.

During Declared Off-season

Monthly Billing Demand will be the Actual Maximum Demand recorded in the month during 0600 hours to 2200 hours

4. HT Industrial consumers having captive generation facilities synchronized with the grid

will pay additional demand charges of Rs. 20 per kVA per month only for the standby

contract demand component.



30. REVENUE PROJECTIONS

In FY 2003-04, the MSEB will earn revenue for 8 months with existing tariff, while the

revised tariffs will be applicable for 4 months. The total revenue from sale of electricity has

been detailed below:

(Rs. Crore)

Sr. Revenue from Sale of Electricity FY 2003-04 1 Existing Tariffs for 8 months 8020 2 Revised Tariffs for 4 months 4072 Total 12092

The detailed revenue calculations with the existing and revised tariff have been given in

Appendices 2 and 3, respectively.

31. TARIFF HIKE FOR FY 2003-04

Description MSEB Proposal MERC Approval Tariff Increase in Rs. Crore* 1462 186

Overall Tariff Increase in %* 12.5% 1.5%

* - If Revised Tariffs Were Applicable For The Entire Year

The overall tariff hike approved by the Commission amounts to 1.5%, over the revenue billed

with the existing tariff. The consumers should appreciate that though the overall rate is 1.5%,

the impact for each consumer category will differ, in relation to the difference between the

average realization and the average cost of supply. Similarly, the impact of the revised tariffs

will differ from one consumer to another in the same category in relation to the consumption

level. For subsidized categories such as domestic, agriculture and LT PWW, the tariff hike

will be higher than 4%. This is inevitable, as the Commission is mandated by the provisions

of the ERC Act to move all tariffs towards the average cost of supply. The movement of the

category-wise average realization towards the average cost of supply has been shown in the

Table in the Section on General Tariff Philosophy. To enable the consumers to assess the

impact of the revised tariffs on their monthly bills, the Commission has computed the change

in the monthly bills for sample levels of consumption for each category, which is presented as

Appendix 4.



32. INCENTIVES AND DISINCENTIVES

32.1 Incentives

32.1.1 Power Factor Incentive

Whenever the average power factor is more than 0.95, an incentive shall be given at the rate

of 1% (one percent) of the amount of the monthly energy bill (excluding FOCA charge,

demand charge, electricity duty and regulatory liability charge) for every 1% (one percent)

improvement in the power factor above 0.95. For PF of 0.99, the effective incentive will

amount to 5% (five percent) reduction in the energy bill and for unity PF, the effective

incentive will amount to 7% (seven percent) reduction in the energy bill. The power factor

incentive is also applicable for LTP-G consumers who opt for LTMD tariff. Such incentives

shall not be applicable for the Railways.

32.1.2 Bulk discount

If the consumption of any industrial consumer (availing TOD tariff and having no arrears with the MSEB) exceeds one million units per month, the consumer will get a rebate of 1% on his energy bill (excluding FOCA charge, demand charge, electricity duty and regulatory liability charge) for every one million unit consumption above one million unit subject to a maximum of 5%. The rebate will, however, be allowed only if the bill is paid within seven days from the date of the bill or within 5 days of the receipt of the bill, whichever is later. However, this incentive will be applicable to consumers where payment of arrears in instalments has been granted by the MSEB, and the same being made as scheduled. The MSEB has to take a commercial decision on the issue of how to determine the time frame for which the payments should have been made as scheduled, in order to be eligible for the bulk discount.

32.1.3 Load Factor Incentive

The Commission has introduced a Load factor incentive for consumers having Load Factor above 75% based on contract demand. Consumers having load factor over 75% upto 85 % will be entitled to a rebate of 0.75 % on the energy charges for every percentage point increase in load factor from 75% to 85%. Consumers having a load factor over 85 % will be entitled to rebate of 1% on the energy charges for every percentage point increase in load factor from 85 %. The total rebate under this head will be subject to a ceiling of 15% of the energy charges for that consumer. This incentive is



limited to HTP-I and HTP-II categories only. Further, the load factor rebate will be available only if the consumer has no arrears with the MSEB, and payment is made within seven days from the date of the bill or within 5 days of the receipt of the bill, whichever is later. However, this incentive will be applicable to consumers where payment of arrears in instalments has been granted by the MSEB, and the same being made as scheduled. The MSEB has to take a commercial decision on the issue of how to determine the time frame for which the payments should have been made as scheduled, in order to be eligible for the Load Factor incentive.

The Load Factor has been defined below:




x (Total no. of hrs during the month less planned load shedding hours*)

* - Interruption/non-supply to the extent of 60 hours in a 30 day month has been built in the

scheme.

The Commission has introduced this incentive to reward consumers contributing a steady

load to the MSEB system, and to incentivize such consumers to remain with the MSEB. In

cases, where the billing demand exceeds the contract demand, the MSEB’s system is

subjected to stress and load management will become more difficult. Hence, in case the

billing demand exceeds the contract demand in any particular month, then the Load Factor

incentive will not be payable in that month.

32.2 Disincentives

32.2.1 Power factor Penalty

Whenever the average power factor is less than 0.9, penal charges shall be levied at the rate of

2% (two percent) of the amount of the monthly energy bill (excluding FOCA charge, demand

charge, electricity duty and regulatory liability charge) for first 1% (one percentage point) fall

in the power factor below 0.9, beyond which the penal charges shall be levied at the rate of

1% (one percent) for each percentage point fall in the power factor below 0.89. Such



disincentives shall not be applicable for the Railways. The power factor penalty is also

applicable for LTP-G consumers who opt for LTMD tariff. The power factor penalty is not be

applicable in case of LTP-G consumers, in cases where there is no metering equipment to

measure the power factor.

32.3 Other Charges

Reconnection Charges, delayed payment charges, penalty for exceeding contract demand,

penalty for exceeding sanctioned load and power factor penalty for LTP-G consumers not

having instruments to measure the Power Factor shall remain unchanged.

32.3.1 Service Line Charges

The MSEB should continue to charge Service Line Charges (SLC) as per the guidelines prevailing as on 5th August 1999, i. e. the date the Commission came into existence, till such time as the SLC are modified by the Commission.

The Commission acknowledges the efforts taken by the Consumer Representatives, viz. (i) Prayas, (ii) Mumbai Grahak Panchayat, (iii) Thane Belapur Industries Association and (iv)Vidarbha Industries Association and the various individuals, corporates and associations for their valuable contribution to the tariff process.

The Commission would also like to put on record, the efforts of its advisors, ICRA Advisory Services.

This Tariff Order shall come into force with effect from December 1, 2003.

Sd/

PRAMOD DEO Member

Sd/

JAYANT DEO Member

Sd/

P. SUBRAHMANYAM Chairman, MERC

Sd/

(A. M. KHAN) Secretary, MERC



Sl Existing Categories & Slabs Demand Charges (Rs/HP/kVA per month)

Energy Charges (p/u)

T & D loss charge (p/u)

Sl Commission's Approval Demand Charges (Rs/HP/kVA per month)

Energy Charges (p/u)

Regulatory Liability Charge (p/u)

1 Domestic (LD 1) 1 Domestic (LD 1)

0-30 units 20 100 10 0-30 units 20 125 0 31-100 units 30 255 20 31-300 units 40 290 0 101-300 units 30 295 20 > 300 units 40 400 0 > 300 units 30 455 20 Additional Fixed Charge - 3 phase Additional Fixed Charge - 3 phase 100 Additional Fixed Charge - CL>10 kW per 10 kW Additional Fixed Charge - CL>10

kW 100 per 10 kW

2 Non Domestic (LD 2) 2 Non Domestic (LD 2)

0-100 Units 70 250 30 0-100 Units 100 240 50 101 to 200 Units 70 410 30 101-200 units 100 315 50 > 200 units 70 500 30 > 200 units 100 410 50 Additional Fixed Charge - 3 phase 125 Additional Fixed Charge - 3 phase 150 Additional Fixed Charge - CL>10 kW

125 per 10 kW

Additional Fixed Charge - CL>10 kW

150 per 10 kW

3 General Motive Power (LTP-G) 3 General Motive Power (LTP-G)

0-1000 Units 60 240 25 0-1000 Units 60 230 50 1001-15000 Units 60 300 25 >1000 Units 60 250 50 >15000 Units 60 340 25 Optional MD based tariff 220 Rs/kVA/month Optional MD based tariff 220 Rs/kVA/month Optional ToD Tariff Optional ToD Tariff 2200 hrs - 0600 hrs -50 2200 hrs - 0600 hrs -75 0600 hrs - 0900 hrs 0 0600 hrs - 0900 hrs 0 0900 hrs - 1200 hrs 30 0900 hrs - 1200 hrs 50 1200 hrs - 1800 hrs 0 1200 hrs - 1800 hrs 0 1800 hrs - 2200 hrs 60 1800 hrs - 2200 hrs 90 (Power loom included in LTP - G)

Power loom (Unmetered) 450

4 Public Water Supply 4 Public Water Supply Urban P. W Schemes 60 225 0 Urban P. W Schemes 60 240 0 Rural P. W Schemes Rural P. W Schemes Grampanchayat 20 75 0 Grampanchayat 25 100 0 'C' class Municipal Councils & Metered

30 140 0 'C' class Municipal Councils - metered

35 150 0

5 Agriculture (incl Poultry) 5 Agriculture

Flat Rate Tariff (Rs/HP/month) 110 0 10 Flat Rate Tariff (Rs/HP/month) a Circles with cons. norm<1300

hours/HP/yr 150 0 0

b Circles with cons. Norm>1300 180 0 0



hours/HP/yr Metered Tariff 10 90 10 Metered Tariff (incl Poultry) 15 110 0

6 Street Light Tariff 6 Street Light Tariff Grampanchayat, A, B, C Class MC

20 170 0 Grampanchayat, A, B, C Class MC 30 210 0

Municipal Corporation 20 250 0 Municipal Corporation 30 250 0

7 HTP - I 325 285 30 7 HT - I 350 215 50 2200 hrs - 0600 hrs -75 2200 hrs - 0600 hrs -85 0600 hrs - 0900 hrs 0 0600 hrs - 0900 hrs 0 0900 hrs - 1200 hrs 50 0900 hrs - 1200 hrs 60 1200 hrs - 1800 hrs 0 1200 hrs - 1800 hrs 0 1800 hrs - 2200 hrs 90 1800 hrs - 2200 hrs 100

8 HTP - II 300 280 30 8 HTP - II 330 210 50 Seasonal Consumers 350 270 30 Seasonal Consumers 350 300 0

9 HTP - III 300 265 0 9 HTP - III 350 215 0

10 HTP - IV 250 255 0 10 HTP - IV 330 210 0 Optional ToD Tariff (HTP -III & IV)

Optional ToD Tariff (HTP -III & IV)

2200 hrs - 0600 hrs -50 2200 hrs - 0600 hrs -85 0600 hrs - 0900 hrs 0 0600 hrs - 0900 hrs 0 0900 hrs - 1200 hrs 30 0900 hrs - 1200 hrs 60 1200 hrs - 1800 hrs 0 1200 hrs - 1800 hrs 0 1800 hrs - 2200 hrs 60 1800 hrs - 2200 hrs 100

11 HTP - V (Railway Traction) 0 415 0 11 HT - V (Railway Traction) 0 335 50

12 HTP - VI 12 HTP - VI Residential Complex 100 220 20 Residential Complex 125 220 0 Commercial Complex 100 350 30 Commercial Complex 125 350 0

13 HTP VII (Agriculture & Related) 13 HT - VII (Agriculture & Related) Flat Rate Tariff (Rs/HP/month) 200 0 10 Metered Tariff 10 90 15 Metered Tariff 25 130 0

14 HTP IX (TEC) 600 290 0 14 HTP IX (TPC) 600 299 0

15 Mula Pravara Electric Co-op Soc.

200 150 0 15 Mula Pravara Electric Co-op Soc. 200 150 0

16 Inter State Sale 0 260 0 16 Inter State Sale 0 260 0



Revenue from Existing Tariff - April 2003 to November 2003 Existing Tariff Applicable for months

Sl Category of Consumers Number of Consumers Contract demand kW / kVA/HP

Energy Charge

Ps/U

T & D loss

Charge (p/u) or

Rs/HP/month

Revenue from

demand charge Rs Cr

Revenue from

energy charge Rs

Cr

Revenue from T & D loss

charge Rs Cr

Total Revenue

Rs Cr

Average Realisat

ion (Rs/unit)

Average Cost of Supply (Rs/unit)

Ratio of avg realisation to avg cost of supply (%)

1 2 3 4 5 6 7 8 9 10 11 12 13 LT Category

1 Domestic (LD 1) 0-30 Units 2813758 3592 0 20 100 10 45.0 239 13.41 298 31-100 Units 4979547 3010 0 30 255 20 119.5 512 22.47 654 101-300 Units 1413115 1353 0 30 295 20 33.9 266 10.10 310 Consumption above 300 units 168468 848 0 30 455 20 4.0 257 6.33 268 Addnl Fixed Charge for 3 phase consumers CL < 10 kW 80495 75 4.8 5 CL > 10 kW 22821 75 2.5 3 Sub Total Domestic 9374888 8781 209.9 1274.5 52.3 1536.7 2.62 2.83 92.84%

2 Non Domestic (LD 2) 0-100 Units 651808 827 0 70 250 30 36.5 138 9.10 183 101-200 units 172647 259 0 70 410 30 9.7 71 2.84 83 Consumption above 200 units 128309 868 0 70 500 30 7.2 289 9.54 306 Addnl Fixed Charge for 3 phase consumers CL < 10 kW 43638 125 4.4 4 CL > 10 kW 14733 125 3.7 4 Sub Total Non-Domestic 952764 1954 0 0 0 61.4 497.7 21.5 580.6 4.46 2.83 157.60%

3 General Motive Power (LTP-G) 0-1000 Units 230996 1668 0 60 240 25 267 17.18 284 1001-15000 Units 39668 1438 0 60 300 25 288 14.81 302 Above 15000 Units 5900 535 0 60 340 25 121 5.51 127 Sub Total General Motive Power 276564 3640 4225201 60 101 676 37 815 3.36 2.83 118.71%

5 Public Water Supply (a) Urban P. W Schemes 3372 35.60 20777 60 225 0 1.00 5.34 0.00 6.34

Sub total 3372 35.60 20777 1.00 5.34 0.00 6.34 2.67 2.83 94.44%

(b) Rural P. W Schemes



Grampanchayat 2291 149 12225 20 75 0 0.20 7.45 0.00 7.65 Metered Tariff 36226 297 214436 30 140 0 5.15 27.72 0.00 32.87 Sub Total 38517 446 226661 100 5.34 35.17 0.00 40.51 1.36 2.83 48.19% Sub total PWW 41889 482 247438 6 41 0 46.85 1.46 2.83 51.61%

6 Agriculture Flat Rate Tariff (Rs/HP/month) 1719172 6893 7107145 110 0 10 625.43 0.00 49.69 675.12 1.47 Metered Tariff 575262 865 2317694 10 90 10 18.54 51.87 3.88 74.29 1.29 Sub Total Agriculture 2294434 7757 9424839 644 52 53.57 749 1.45 2.83 51.26%

7 Street Light Grampanchayat, A, B & C Class Municipal Council 357 0 20 170 0 0.00 40.48 0.00 40.48 Municipal Corporation Areas 54899 278 0 20 250 0 0.00 46.35 0.00 46.35 Sub Total Street Light 66764 635 346500 20 6 87 0.00 92 2.18 2.83 77.14%

8 Poultry Farms 6602 30 65684 10 90 10 0.53 1.80 0.12 2.44 1.22 2.83 43.17%

Total Low Tension 13013905 23280 14309662 1029 2629 165 3823 2.46 2.83 87.12%

HT Category

1 HTP - I 3241 6644 1758200 325 285 30 457 1189.78 33.62 1680.53 3.79 2.83 134.19% 2200 hrs - 0600 hrs 0 4163 0 -75 -208.15 0600 hrs - 0900 hrs 0 2468 0 0 0.00 0900 hrs - 1200 hrs 0 1593 0 50 53.11 1200 hrs - 1800 hrs 0 2468 0 0 0.00 1800 hrs - 2200 hrs 0 2137 0 90 128.24

2 HTP - II 4799 6185 1533600 300 280 30 368 1082.91 64.82 1515.80 3.68 2.83 130.02% Power Factor Incentive -101.93 Power Factor Penalty 5.20 Bulk Discount -20.67

2(a) Seasonal category 239 32 185157 350 270 30 52 5.76 0.56 58.16

2(b) Captive Consumers 375921 20 6 6.01



3 HTP - III 129 637 99900 300 265 0 24 111.30 0.00 135.28 3.19 2.83 112.67% 2200 hrs - 0600 hrs 338 -50 -11.26 0600 hrs - 0900 hrs 199 0 0.00 0900 hrs - 1200 hrs 128 30 2.57 1200 hrs - 1800 hrs 199 0 0.00 1800 hrs - 2200 hrs 167 60 6.69

4 HTP - IV 444 394 70200 250 255 0 14 66.22 0.00 80.26 3.06 2.83 108.07%

5 HTP - V (Railway Traction) 980 0 415 0 0 271.13 0.00 271.13 4.15 2.83 146.78%

6 HTP - VI Residential Complex 306 293 71000 100 220 20 6 42.97 1.54 50.19 Commercial Complex 39 17 6000 100 350 30 0 3.97 0.12 4.56 Sub Total HTP VI 345 310 77000 6 47 2 55 2.65 2.83 93.70%

7 HTP VII (Agriculture) Flat Rate Tariff (Rs/HP/month) 200 0 10 0 0.00 0.00 0.00 Metered Tariff 938 554 209651 10 90 15 2 33.24 2.03 36.94 Sub Total HTP VII 938 554 209651 2 33 2 37 1.00 2.83 35.38%

8 HTP VIII Poultry Layers & Broilers 41 11 5351 10 90 15 0.04 0.66 0.09 0.79 1.07 2.83 38.01%

9 HTP IX (TEC) 1 0 550000 600 290 0 264 264.00

11 SP-I Agri (HT/LT) HighTech 34 17 8315 10 90 15 0.07 1.02 0.14 1.23 1.08 2.83 38.35%

13 Mula Pravara Electric Co-op Soc. 1 667 160000 200 150 0 26 66.67 0.00 92.27 2.08 2.83 73.43%

14 Inter State Sale 4 0 0 0 260 0 0 0.00 0.00 Total High Tension 10216 16431 4657374 1219 2876 103 4197 3.83 2.83 135.52%

Grand Total 13024121 39711 18967037 2248 5504 268 8020 3.03 2.83 107.15%



Appendix 4: Change in Monthly Bills (excluding Electricity Duty)

Monthly Bill Category Monthly Consumption (Units)

Connected Load (HP) / Billing demand (kVA)

Existing Tariff

(Rs.)

Revised Tariff

(Rs.)

Change

(Rs.) (a) (b) (c) (d) (e) (f)=(e)-(d)

15 38.0 38.75 0.75 Domestic 70 180.0 193.5 13.5

100 360.0 390.0 30.0 Commercial 250 1080.0 985.0 -95.0

1000 50 4250.0 4300.0 50.0 LTP-G 5000 50 17650.0 16300.0 -1350.0

Urban PWW 10000 50 26500.0 27000.0 500.0 PWW – Gram Panchayat

2000 10 1900.0 2250.0 350.0

LT Agri. (Un-metered) -Cons. Norm<1300 hrs -Cons. Norm>1300 hrs

7.5 952.5

952.5

1125.0

1350.0

172.5

397.5

LT Agri. (metered) 275 7.5 377.5 415.0 37.5 Street Lighting (Gram Panchayat)

20000 50 37000.0 43500.0 6500.0

Street Lighting (B & C Class MC)

20000 50 37000.0 43500.0 6500.0

Street Lighting (Municipal Corporation)

20000 50 53000.0 51500.0 -1500.0

HTP-I 125000 500 Rs 5.64 lakh Rs 5.01 lakh -63000.0 HTP-II 125000 500 Rs 5.46 lakh Rs 4.89 lakh -57000.0 HTP-III 125000 500 Rs 4.94 lakh Rs 4.44 lakh -50000.0 HTP-IV 75000 250 Rs 2.61 lakh Rs 2.40 lakh -21000.0 Railways 1000000 Rs 42.5 lakh Rs 38.5 lakh -Rs. 4.0 lakh HTP-VI (Residential)

50000 250 Rs 1.50 lakh Rs 1.41 lakh -8750.0

HT Agri. (metered) 15000 150 18750 23250 4500.0 Mula Pravara 60000000 145 Rs 9.00 Crore Rs 9.00

Crore 0



Appendix 5 : Details of Generation and Power Purchase Cost

A. Actuals for the period April 2003-July 2003

(i) Generation & Generation Parameters for MSEB’s Own Stations: -

Station Gross

Generation Aux. Cons.

Net. Generation

Total Cost

MU % MU Rs. Cr Khaparkheda 2104 8.50% 1925 178 Paras 148 9.70% 134 16 Bhusawal 878 10.00% 790 91 Nasik 2046 9.00% 1862 264 Parli 1279 9.70% 1155 148 Koradi 2198 9.80% 1983 242 Chandrapur 5383 7.60% 4974 360 Gas Thermal 1311 2.40% 1279 86

(ii) Power Purchase - CGS Stations [Actuals for the period April – July 2003]: -

Net Purchase Total Cost (Rs.Cr)

April – July 2003 April – July 2003

Tarapur 369 35

Kakrapar 641 192

Korba 1517 127

Vindhyachal 1369 185

Kawas 425 144

Gandhar 351 114

Notes: -

(a) All the generation and power purchase costs for the period of April – July 2003 have been

considered at actuals as submitted by MSEB subject to Approved Heat Rate and Transit Loss

Norms.

(b) From August 2003-March 2004, the station wise quantum of energy, variable cost per unit and

Fixed Cost (only for NTPC stations) has been projected separately. FOCA computations in all

respects including quantum of energy generated or purchased will be w.r.t. month -wise

projected figures.



B. Projections for the period August 2003-March 2004: -

(i) Generation & Generation Parameters for MSEB’s Own Stations: -

Heat

Rate

Aux

Cons

Var.

Cost

Net Generation Total

Gen. Cost Station

Kcal/

kwh

% Rs./

kwh

Aug-03 Sept-03 Oct-03 Nov-03 Dec-03 Jan-04 Feb-04 Mar-04 (Rs. Cr.)

K’Kheda 2719

8.50%

0.9239

394

394 407 440 572 575 519 575 328

Paras 3200 9.70% 1.2299 0 25 28 36 35 36 33 40 26

Bhusawal 2735 10.00% 1.1525 270 216 242 308 293 302 287 318 232

Nasik 2663 9.00% 1.4164 382 370 382 353 359 364 408 479 399

Parli 2649 9.70% 1.2836 351 306 339 421 417 296 269 364 306

Koradi 2996 9.80% 1.2205 400 470 440 586 622 641 595 591 478

Chandrapur 2502 7.60% 0.7237 1097 1235 1623 1430 1505 1623 1466 1623 776

Gas Thermal (Gas) 1966 2.40% 0.6742 350 339 350 339 350 350 317 350 181



(ii) Power Purchase - CGS Stations [Projections for the period August 2003-March 2004]: -

Net Purchase Var.

Cost

Total Var.

Cost.

Fixed

Cost

Incentive (Rs. Cr/month) Total

Cost

Aug-

03

Sep-

03

Oct-

03

Nov-

03

Dec

-03

Jan-

04

Feb-

04

Mar-

04 Rs. /kwh Rs. Cr.

Rs. Cr. Aug-

03

Sep-

03

Oct-

03

Nov-

03

Dec-

03

Jan-

04

Feb-

04

Mar-

04 Rs. Cr.

Tarapur 107 104 107 104 107 107 97 107 0.94 77 Included in Variable Cost 77

Kakrapar 152 147 152 147 152 152 137 152 2.99 338 Included in Variable Cost 338

Korba 401 388 401 388 401 401 362 401 0.53 157 83 0.48 0.20 0.48 0.20 0.48 0.48 0 0.48 243

Vindhyachal 470 366 432 468 483 483 437 483 0.77 263 183 0.29 0 0.25 0.25 0.57 0.57 0 0.57 449

Kawas 0 0 0 34 0 0 0 0 2.45 8 78 0 0 0 0 0 0 0 0 86

Gandhar 51 8 39 81 72 82 75 83 1.15 53 147 0 0 0 0 0 0 0 0 200


ANNEXURE - I 236

ANNEXURE - I List of Objectors to the MSEB ARR and Tariff Petition for FY 2003-04 S.No. Name and Address of the Objector Remarks

01 Shri Niranjan B.Agrawal, Vidarbha Chamber of Commerce & Industry, Shrawgi Towers, Tilak Road, Akola- 444001, Amravati

On Affidavit

02 Shri Mahendra Darda, Vidarbha Chamber of Small Scale Industries, Darda Pipe Factory, Yavatmal - 445001, Amravati

On Affidavit

03 Shri Raghunath Kaparthi, Managing Director, Balaji Electro Smelters Ltd. Plot No.B-18, MIDC, Yavatmal-445001, Amravati

On Affidavit

04 Shri Kiran Paturkar, MIDC Industrial Association, MAH-749, 1980 (F-915), P-12, MIDC, Amravati-444605

On Affidavit

05 Shri Sudhir Shridhar Raut, Chairman, Khamgaon Nagar Parishad, Khamgaon, Dist-Buldhana-444303, Amravati

On Affidavit

06 Shri Baban Sonasa Khandare, Secretary, Akhil Bhartiya Grahak Panchayat, Post Anjangoan, Surgi, Amravati

On Affidavit

07 Shri Kawish B. Dange, Plot No. 1, Hingaspure Nagar, Dastur Nagar, MIDC Road, Amravati – 444 606

On Affidavit

08 Shri Jayantilal Khushalchand Ginning & Pressing Factory – Main Road, Tal, Murtizapur, Dist. Akola, Amravati

On Affidavit

09 Shri Pramod Kumar Agarwal, Executive Member, Rice Millers Association, Rice Bhawan, Gourakshan Market, Gondia- 441 601

On Affidavit

10 Shri Nathu.G.Rambhad, C-76 & 77, MIDC, Nagpur- 440 028 On Affidavit 11 Shri Mohan Sharma, Working President, Maharashtra State Electricity

Board -Workers Federation, C/o Vidyut Karmachari Sahakari Path Sanstha, Nelson Chowk, Chhaoni, Nagpur- 440013

On Affidavit

12 Shri Viren Chandak, Hon.Secretary, Nag Vidarbha Chamber of Commerce, Temple Road, Civil Lines, Nagpur - 01

On Affidavit

13 Shri M.D.Saraf- M.D. Vidarbha Iron & Steel Corpn. Ltd., 46 (A&B) MIDC Industrial Estate, Nagpur- 440 028

On Affidavit

14 Shri R.B. Goenka, Member, Vidarbha Industries Association, R.K.Engineering Services, 816, Nehru Nagar, Nagpur- 440 009

On Affidavit

15 Dr.G.M. Nashikkar, President, Grahak Panchayat Nagpur City, Nagpur

On Affidavit

16 Shri Sanjay Shriram Pillai, MSEB Workers Federation, Near Sitaram Maharaj Mandir, Nelson Chowk, Nagpur-440013

On Affidavit

17 Shri R.S.Savarkar, C/o Kale Sirs House, Jajuwadi, Post & Tal. Aarve, Dist. Wardha - 442001, Nagpur

Without Affidavit

18 Shri Sharma Vishwa Prakash, 13, Gittikhadan-Gonewada Road, Nagpur-440015

Without Affidavit

19 Shri Subodh Jayaratnam Garjalwar, Mauja Salori, Yensa Block, Tal. Varora, Dist. Chandrapur,Nagpur

Without Affidavit


ANNEXURE - I 237

S.No. Name and Address of the Objector Remarks 20 Shri C.J. Pathak - Vice President, Garware Polyester Ltd., L - 6,

Shikalthana Industrial Area, Dr. Abasaheb Garware Marg, Aurangabad-431 210

On Affidavit

21 Shri Shankar Zunzunwala, Chamber of Marathwada Industries & Agriuclture, Bajaj Bhawan, P-2, MIDC Area, Station Road, Aurangabad-431005

On Affidavit

22 Shri Narendra Kumar Gupta, R.L.Steels Ltd. F-18/19, MIDC Area, Chikalthana, Aurangabad- 431 210

On Affidavit

23 Shri S.K.Chaudhari, Hon.Secretary, Industries Association of Young Enterpreneurs, P-25, MIDC, Chikalthana, Aurangabad- 431 210

On Affidavit

24 Shri Moreshwar Save, Citizens Forum, Aurangabad, C/o Anjali Complex, Khadkeshwar, Aurangabad-431 001.

On Affidavit

25 Shri Deepak D. Pathak, MIDC, Latur On Affidavit 26 Shri A.H. Khan, 40-15-83, Khadkeshwar, Aurangabad 431 001. Without

Affidavit 27 Shri Pradeep Jaiswal, (M.P. Of Lok Sabha), Parliamentary Standing

Committee on Human Resource Development Consultative Committee on Civil Aviation House Committee-Narali Bagh, Aurangabad – 431 001

Without Affidavit

28 Prof. Madhav Hande – Deshmukh, 5, Viraj Residency, Youth Hostel Lane, Station Road, Aurangabad

Without Affidavit

29 Shri Sayyed Jahiroddin, MSEB – Workers Federation, Madhyavarti Office, Workers Federation Bhavan, Khadkeshwar, Aurangabad – 431 001

Without Affidavit

30 Youth Republican (RPI), 28, Vasundhara Colony, Nandanvan Colony, Chhavani Parisar, Aurangabad – 431 002

Without Affidavit

31 Shri Chandrakant Kole, Aurangabad Without Affidavit

32 Maharashtra Rajya Veej Sangharsh Samiti, Aurangabad Without Affidavit

33 Shri Sahebrao Baban Kawade, Harishchandra Sahakari Pani Purawatha Sansthan Sahakari Federation Ltd., Amrutnagar, Post-Tal- Sangamnner, Dist- Ahmednagar - 422 608

On Affidavit

34 Shri Mukutrao Patil, Chairman, Uttar Maharashtra Veej Grahak Seva Sahakari Sanstha Maryadit, Varun Shopping Centre, 1 - Gurudatta Nagar, Deopur, Dhule - 424002

On Affidavit

35 Shri Vinita Dharkar, Nashik Industries & Manufacturers Association, NIMA House, P-14, MIDC, Satpur, Nashik- 422 007

On Affidavit

36 Shri Shyam Dashrath Patil, Narmada Bachhau Samarthan Andolan, Ashoknagar, Jamnagiri Road, Dhule- 424001

On Affidavit

37 Shri S.V.Palande, General Manager, Hoganas India Ltd. D-96/97, MIDC,Ahmednagar–414111

On Affidavit


ANNEXURE - I 238

S.No. Name and Address of the Objector Remarks 38 Shri Mohammad Haroon Mohd.Sabir, President, The Malegaon Yantra

Magh- Sarojanik Veej Grahak Sangh, Post Box. No.14, Communist Party of India, Malegaon, Nashik- 423203

On Affidavit

39 Shri Nimba Murlidhar Kadam, Powerloom Factory, Gut No.152, Kusumba Road, Dayane, Tal-Malegaon, Dist- Nashik- 423203

On Affidavit

40 Shri Ansari Noorul Amin Mohd.Sabir, Manager, The Industrial Co-operative Association Ltd., 1398/1 Kidwai Road, Islampura, Malegaon, Nashik.

On Affidavit

41 Shri Prashant Khandkekar, Chief Officer, Muncipal Council Chalisgaon, Chalisgaon, Jalgaon-424101

On Affidavit

42 Shri Annasaheb Unnde, Pravara Institute of Research & Education in Natural & Social Sciences (PIRENS), Loni Bk. Tal-Rahata, Dist- Ahmednagar-413736

On Affidavit

43 Shri Ramesh V. Kulkarni, Managing Director, The Mula Pravara Electric Co-operative Society Ltd, Shrirampur-413709, Ahmednagar

On Affidavit

44 Shri D.P. More, Pachora Nagar parishad, Pachora, Dist-Jalgaon On Affidavit 45 Shri Shaikh Yusuf Mohmed, Near Urdu School, Gosaviwadi, Nashik

Road, Nashik - 422101 On Affidavit

46 Shri Atmaram G. Bhamare, C/o Bhamare shopping Centre, Near S.T. Stand, Thaharabad, Nashik

On Affidavit

47 Shri Shankarrao Bharambe, Bhartiya Kissan Sangh, Sayykheda Road, Ozar (Migh), Tal-Niphad, Nashik

On Affidavit

48 Shri Champalal Indraraj Sand, Vice Chairman, Bhartiya Kisan Sangh Maharashtra Pradesh, Post Sakura, Tal- Rahata, Ahmednagar-423107

On Affidavit

49 Dr. Vasant N. Pawar, Nationalist Congress Party, ‘Gauttam’ New Pandit Colony, Sharanpur Road, Nashik – 422 022

On Affidavit

50 Shri Ramesh M. Pawar, President, Nashik District Industries & Exporters’ Association, MIDC Ambad, Nashik – 422 010

On Affidavit

51 Adv. A.K.Nikkam, Chairman, & Shri Madhavrao Boraste & Ors. Niphad Upsa Jalsinchan Sansthan Sangh, Nashik, At Post Sakoremig, Tal. Niphad, Dist. Nashik

On Affidavit

52 Shri Uttamsingh J. Shinde, At Post Nandurdhameshwar, Tal. Niphad, Dist. Nashik

On Affidavit

53 Shri Balu D. Boraste, At Post Sakore, Tal. Niphad, Dist. Nashik On Affidavit 54 Shri Chndrakant M. Phade, At Post Lalwadi, Tal. Niphad, Dist. Nashik On Affidavit 55 Shri Vithalnana Shankhapal, At Post Karsul, Tal. Niphad, Dist. Nashik On Affidavit 56 Shri Damudada Tarle, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 57 Shri Arjun Devram Tarle, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 58 Shri Narayan Babu Pagar, At Post Harsul, Tal. Niphad, Dist. Nashik On Affidavit 59 Shri Rambhau Krishna Gaikwad, At Post Kathergaon, Tal. Niphad, Dist.

Nashik On Affidavit

60 Shri Pandurang N. Kangne, At Post Lalwadi, Tal. Niphad, Dist. Nashik On Affidavit 61 Shri Popat Shankar Takate, At Post Karsul, Tal. Niphad, Dist. Nashik On Affidavit


ANNEXURE - I 239

S.No. Name and Address of the Objector Remarks 62 Shri Murlidhar J. Mahale, At Post Sakore, Tal. Niphad, Dist. Nashik On Affidavit 63 Shri Sadashiv P. Garud, At Post Konkangaon, Tal. Niphad, Dist. Nashik On Affidavit 64 Shri Rambhau Y. Boraste, At Post Sakore, Tal. Niphad, Dist. Nashik On Affidavit 65 Shri Bhika Bhau Boraste, At Post Sakore, Tal. Niphad, Dist. Nashik On Affidavit 66 Shri Hari K. Walunj, At Post Varhedarna, Tal. Niphad, Dist. Nashik On Affidavit 67 Shri Pandurang G. Gorade, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 68 Shri Karbhari A. Boraste, At Post Sakore, Tal. Niphad, Dist. Nashik On Affidavit 69 Shri Ramdas M. Shinde, At Post Vadalinajik, Tal. Niphad, Dist. Nashik On Affidavit 70 Shri Kashinath G. Gavali, At Post Kolgaon, Tal. Niphad, Dist. Nashik On Affidavit 71 Shri Pundlik K. Matsagar, At Post Pimplas, Tal. Niphad, Dist. Nashik On Affidavit 72 Shri Rameshwar B. Ghotekar, At Post Kolgaon, Tal. Niphad, Dist.

Nashik On Affidavit

73 Shri Babu K. Nagare, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit 74 Shri Bapu B. More, At Post Konkangaon, Tal. Niphad, Dist. Nashik On Affidavit 75 Shri Namdeo G. Mogal, At Post Shingave, Tal. Niphad, Dist. Nashik On Affidavit 76 Shri Yashwant D. Gavali, At Post Kolgaon, Tal. Niphad, Dist. Nashik On Affidavit 77 Shri Vasant M. Rajore, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 78 Shri Bhikaji D. Sangole, At Post Kurudgaon, Tal. Niphad, Dist. Nashik On Affidavit 79 Shri Kamlakar L. Ghotekar, At Post Kolgaon, Tal. Niphad, Dist. Nashik On Affidavit 80 Shri Kedarnath K Ghotekar, At Post Kolgaon, Tal. Niphad, Dist. Nashik On Affidavit 81 Shri Gangadhar Y. Gawali, At Post Kolgaon, Tal. Niphad, Dist. Nashik On Affidavit 82 Shri Bajirao G. More, At Post Konkangaon, Tal. Niphad, Dist. Nashik On Affidavit 83 Shri Pandurang B. Boraste, At Post Sakore, Tal. Niphad, Dist. Nashik On Affidavit 84 Ahri Murlidhar B. Hire, At Post Chatori, Tal. Niphad, Dist. Nashik On Affidavit 85 Shri Mahadev D.Mandalik, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit 86 Shri Habibbhai V. Shaikh, At Post Sakore, Tal. Niphad, Dist. Nashik On Affidavit 87 Shri Rangnath B. Boraste, At Post Sakore, Tal. Niphad, Dist. Nashik On Affidavit 88 Shri Ramkrishna B. Boraste, At Post Sakore, Tal. Niphad, Dist. Nashik On Affidavit 89 Shri Ramchandra P. Gade, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit 90 Shri Dinkar G. More, At Post Konkangaon, Tal. Niphad, Dist. Nashik On Affidavit 91 Shri Dashrath G. More, At Post Konkangaon, Tal. Niphad, Dist. Nashik On Affidavit 92 Shri Ashok S. More, At Post Konkangaon, Tal. Niphad, Dist. Nashik On Affidavit 93 Shri Baban M. Shinde, At Post Kundewadi, Tal. Niphad, Dist. Nashik On Affidavit 94 Shri Ramrao Y. Takote, At Post Karsul, Tal. Niphad, Dist. Nashik On Affidavit 95 Shri Murlidhar B. Kale, At Post Kathergaon, Tal. Niphad, Dist. Nashik On Affidavit 96 Kothure Sahakari Upsa Jalsinchan Sanstha Ltd. At Post Kothure, Tal.

Niphad, Dist. Nashik On Affidavit

97 Shri Bhima H. Tarle, At Post Chandori, Tal. Niphad, Dist. Nashik

On Affidavit

98 Shri Sampat G. Gade, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit


ANNEXURE - I 240

S.No. Name and Address of the Objector Remarks 99 Shri Kishan Trambak Jhoman, At Post Chandori, Tal. Niphad, Dist.

Nashik On Affidavit

100 Chitleshwar Sahakari Upsa Jalsinchan Sanstha, At Post Chitegaon, Tal. Niphad, Dist. Nashik

On Affidavit

101 Shri Vishwanath H. Shelar, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit 102 Shri Eknath H. Tarle, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 103 Jaykisan Sahakari Upsa Jalsinchan Sanstha, At Post Chandori, Tal.


104 Shri Sharadchandra D. Mule, At Post Kothure, Tal. Niphad, Dist. Nashik On Affidavit 105 Late Shri Tatyasaheb Boraste, At Post Chandori, Tal. Niphad, Dist.

Nashik On Affidavit

106 Shri Ganpat D. Bhikule, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit 107 Shri Namdeo B. Gaikhe, At Post Konkangaon, Tal. Niphad, Dist. Nashik On Affidavit 108 Shri Baburao V. Gaikwad, At Post Konkangaon, Tal. Niphad, Dist.

Nashik On Affidavit

109 Shri Kailash R. Shinde, At Post Konkangaon, Tal. Niphad, Dist. Nashik

On Affidavit

110 Shri Manikrao V. Boraste, At Post Sakore, Tal. Niphad, Dist. Nashik

On Affidavit

111 Shri Ashok S. Naik, At Post Sarole Thadi, Tal. Niphad, Dist. Nashik

On Affidavit

112 Shri Shivaji K. Sandhan, At Post Rasalpur, Tal. Niphad, Dist. Nashik On Affidavit 113 Shri Prahlad G. Vadgule, At Post Kathargaon, Tal. Niphad, Dist. Nashik On Affidavit 114 Shri Rangnath R. Shankhpal, At Post Karsul, Tal. Niphad, Dist. Nashik On Affidavit 115 Shri Ashok R. Vadgule, At Post Jalgaon, Tal. Niphad, Dist. Nashik On Affidavit 116 Shri Manik D. Sangole, At Post Tamaswadi, Tal. Niphad, Dist. Nashik On Affidavit 117 Shri Chandrakant G. Sangole, At Post Tamaswadi, Tal. Niphad, Dist.

Nashik On Affidavit

118 Shri Walu L. Sanap, At Post Tamaswadi, Tal. Niphad, Dist. Nashik

On Affidavit

119 Shri Shrihari D. Paradhi, At Post Tamaswadi, Tal. Niphad, Dist. Nashik On Affidavit 120 Shri Narayan A. Nagare, At Post Kuradgaon, Tal. Niphad, Dist. Nashik On Affidavit 121 Shri Shankar Ramaji Khaire, At Post Chitegaon, Tal. Niphad, Dist.

Nashik On Affidavit

122 Shri Dondiram V. Bhosale, At Post Sarole khurd, Tal. Niphad, Dist. Nashik

On Affidavit

123 Shri Ramprasad M. Sangale, At Post Kathargaon, Tal. Niphad, Dist. Nashik

On Affidavit

124 Shri Laxman P. Mogal, At Post Rasalpur, Tal. Niphad, Dist. Nashik On Affidavit 125 Smt. Kashibai T. Tarle, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 126 Shri Ranganath M. Takate, At Post Karsul, Tal. Niphad, Dist. Nashik On Affidavit


ANNEXURE - I 241

S.No. Name and Address of the Objector Remarks 127 Shri Vijaykumar R. Gambhire, At Post Dharangaon, Tal. Niphad, Dist.

Nashik On Affidavit

128 Shri Vishwanath U. Shinde, At Post Tamaswadi, Tal. Niphad, Dist. Nashik

On Affidavit

129 Shri Najir I. Shaikh, At Post Nandurdhameshwar, Tal. Niphad, Dist. Nashik

On Affidavit

130 Shri Shankar V. Sanap, At Post Lalwadi, Tal. Niphad, Dist. Nashik On Affidavit 131 Shri Baburao R. Wagh, At Post Kasber Sukene, Tal. Niphad, Dist.

Nashik On Affidavit

132 Shri Macchindranath G. Pund, At Post Dharangaon, Tal. Niphad, Dist. Nashik

On Affidavit

133 Shri Balasaheb K. Shankhapal, At Post Karsul, Tal. Niphad, Dist. Nashik On Affidavit 134 Shri Laxman Narayan Bhonsale, At Post Sarole Khurd, Tal. Niphad,

Dist. Nashik On Affidavit

135 Shri Parvat B. Bhosale, At Post Sarole Khurd, Tal. Niphad, Dist. Nashik On Affidavit 136 Shri Tukaram P. Khaire, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit 137 Shri Pandharinath R. Wagh, At Post Kolgaon, Tal. Niphad, Dist. Nashik On Affidavit 138 Shri Balnath B. Shinde, At Post Nanduramdhameshwar, Tal. Niphad,


139 Shri Madhav B. Dangale, At Post Naduramdhameshwar, Tal. Niphad, Dist. Nashik

On Affidavit

140 Shri Bhausaheb R. Gambhire, At Post Dharangaonvir, Tal. Niphad, Dist. Nashik

On Affidavit

141 Shri Keshav P. Bhosale, At Post Vamasgaon, Tal. Niphad, Dist. Nashik On Affidavit 142 Shri Popat N. Shevkar, At Post Sukene, Tal. Niphad, Dist. Nashik On Affidavit 143 Shri Vishnu W. Bharote, At Post Tamaswadi, Tal. Niphad, Dist. Nashik On Affidavit 144 Shri Ajit D. Shinde, At Post Kurudgaon, Tal. Niphad, Dist. Nashik On Affidavit 145 Shri Vithoba S. Tarle, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 146 Shri Waman B. Mogal, At Post Kothure, Tal. Niphad, Dist. Nashik On Affidavit 147 Shri Kantilal H. Aware, At Post Tamaswadi, Tal. Niphad, Dist. Nashik On Affidavit 148 Shri Namdeo D. Sangle, At Post Kuradgaon, Tal. Niphad, Dist. Nashik On Affidavit 149 Shri Shivaji A. Arote, At Post Tamaswadi, Tal. Niphad, Dist. Nashik On Affidavit 150 Shri Rajaram K. Sangale, At Post Kuradgaon, Tal. Niphad, Dist. Nashik On Affidavit 151 Shri Shivaji S. Sangamner, At Post Sukene, Tal. Niphad, Dist. Nashik On Affidavit 152 Shri Jagan D. Sanap, At Post Labani, Tal. Niphad, Dist. Nashik On Affidavit 153 Shri Haribhau T. Sanap, At Post Lalwadi, Tal. Niphad, Dist. Nashik On Affidavit 154 Shri Raghunath G. Arote, At Post Tamaswadi, Tal. Niphad, Dist. Nashik On Affidavit 155 Shri Annasaheb D. Wagh, At Post Kathargaon, Tal. Niphad, Dist. Nashik On Affidavit 156 Shri Jairam B. Shevkar, At Post Sukene, Tal. Niphad, Dist. Nashik On Affidavit 157 Shri Popat Bhikaji Mogal, At post Kothure, Tal. Niphad, Dist. Nashik

On Affidavit


ANNEXURE - I 242

S.No. Name and Address of the Objector Remarks 158 Shri Vishwas J. Gawali, At Post Narayan Tembhi, Tal. Niphad, Dist.

Nashik On Affidavit

159 Shri Janemiya S. Patel, At Post Chatori, Tal. Niphad, Dist. Nashik On Affidavit 160 Umrale Sahakari Upsa Jalsinchan Sanstha Ltd., At Post Umrale, Tal.


161 Waghad Sahakari Upsa Jalsinchan Sanstha Ltd. At Post Umrale, Tal. Niphad, Dist. Nashik

On Affidavit

162 Shri Parashram S. Bhosale, At Post Sarole Khurd, Tal. Niphad, Dist. Nashik

On Affidavit

163 Shri Trambak D. Shelar, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit 164 Shri Narayan P. Kute, At Post Saikheda, Tal. Niphad, Dist. Nashik On Affidavit 165 Smt. Muktabai T. Shevkar, At Post Sukene, Tal. Niphad, Dist. Nashik On Affidavit 166 Shri Narayan B. Shelar, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit 167 Shri Sadashiv T. Shevkar, At Post Sukene, Tal. Niphad, Dist. Nashik On Affidavit 168 Shri Yadav M. Kathe, At Post Sukene, Tal. Niphad, Dist. Nashik On Affidavit 169 Shri Ramnath M. Dangale, At Post Naduramdhameshwar, Tal. Niphad,


170 Shri Pandurang K. Fade, At Post Lalwadi, Tal. Niphad, Dist. Nashik On Affidavit 171 Shri Parshram M. Rajole, At Post Wadali Najik, Tal. Niphad, Dist.

Nashik On Affidavit

172 Shri Rajaram G. Sangole, At Post Tamaswadi, Tal. Niphad, Dist. Nashik On Affidavit 173 Smt. Anusaya P. Kulthe, At Post Tamaswadi, Tal. Niphad, Dist. Nashik On Affidavit 174 Shri Shivaji R. Nikam, At Post Chitagaon, Tal. Niphad, Dist. Nashik On Affidavit 175 Shri Ramrao M. Shinde, At Post Tamaswadi, Tal. Niphad, Dist. Nashik On Affidavit 176 Shri Virendra V. Jain, At Post Kathargaon, Tal. Niphad, Dist. Nashik On Affidavit 177 Shri Vasant V. Mogal, At Post Shingave, Tal. Niphad, Dist. Nashik On Affidavit 178 Shri Sukha T. Lokhande, At Post Shimpi Takli, Tal. Niphad, Dist.

Nashik On Affidavit

179 Shri Pundlik K. Sangale, At post Tamaswadi, Tal. Niphad, Dist. Nashik On Affidavit 180 Shri Murlidhar P. Dabhade, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit 181 Shri Khanderao A. Dele, At Post Shingave, Tal. Niphad, Dist. Nashik On Affidavit 182 Shri Jhavarebua K. Rayate, At Post Shingave, Tal. Niphad, Dist. Nashik On Affidavit 183 Shri Karbhari P. Kare, At Post Songaon, Tal. Niphad, Dist. Nashik On Affidavit 184 Shri Kashinath S. Hujare, At Post Chehadi, Tal. Niphad, Dist. Nashik On Affidavit 185 Shri Bhau G. Barve, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 186 Shri Nivrutti P. Gite, At Post Shingave, Tal. Niphad, Dist. Nashik On Affidavit 187 Shri Jaganath D. Ghotekar, At Post Khedale June, Tal. Niphad, Dist.

Nashik On Affidavit

188 Shri Dashrath B. Mogul, At Post Sukene, Tal. Niphad, Dist. Nashik On Affidavit 189 Shri Balu S. Dele, At Post Shingave, Tal. Niphad, Dist. Nashik On Affidavit 190 Shri Pundlik D. Sanap, At Post Shingave, Tal. Niphad, Dist. Nashik On Affidavit


ANNEXURE - I 243

S.No. Name and Address of the Objector Remarks 191 Shri Parshuram N. Ghotekar, At Post Kolgaon, Tal. Niphad, Dist. Nashik On Affidavit 192 Shri Shankarrao V. More, At Post Konkangaon, Tal. Niphad, Dist.

Nashik On Affidavit

193 Shri Damu D. Ghosade, At Post Chandori, Tal. Niphad, Dist. Nashik

On Affidavit

194 Shri Balasaheb W. Gawali, At Post Narayantembhi, Tal. Niphad, Dist. Nashik

On Affidavit

195 Shri Nivrutti A. Mogul, At Post Kothure, Tal. Niphad, Dist. Nashik On Affidavit 196 Shri Haribhau D. Karad, At Post Jalgaon, Tal. Niphad, Dist. Nashik On Affidavit 197 Shri Manaji B. Ghotekar, At Post Kolgaon, Tal. Niphad, Dist. Nashik On Affidavit 198 Shri Dadasaheb Karad & Kakasaheb Mogul Upsa Jalsinchan Sanstha, At

Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit

199 Shri Laxman S. Tarle, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 200 Shri Shriram G. Bairagi, At Post Konkangaon, Tal. Niphad, Dist. Nashik On Affidavit 201 Shri Kisan K. Pagere, At Post Jivale, Tal. Niphad, Dist. Nashik On Affidavit 202 Shri Kashinath V. Ghadavaje, At Post Sakore, Tal. Niphad, Dist. Nashik On Affidavit 203 Shri Shriram B. More, At Post Konkangaon, Tal. Niphad, Dist. Nashik On Affidavit 204 Shri Balkrishna F. Kotame, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 205 Shri Baburao T. Nathe, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 206 Shri Shivaji B. Kotame, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 207 Shri Kashinath G. Sanap, At Post Lalwadi, Tal. Niphad, Dist. Nashik On Affidavit 208 Shri Shripat K. Avad, At Post Kuradgaon, Tal. Niphad, Dist. Nashik On Affidavit 209 Shri Madhav L. Tarle, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 210 Shri Khanderao R. Salve, At Post Sundarpur, Tal. Niphad, Dist. Nashik On Affidavit 211 Mamleshwar Sah. Upsa Jalsinchan Sanstha Limited - At Post Pimpalsa

Ramche, Tal. Niphad, Dist. Nashik On Affidavit

212 Shri Dilip V. Jhalte, At Post Vadalinajik, Tal. Niphad, Dist. Nashik On Affidavit 213 Shri Trambak P. Tarle, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 214 Shri Madhukar V. Derle, At Post Shingave, Tal. Niphad, Dist. Nashik On Affidavit 215 Shri Tukaram G. Sanap, At Post Shivare, Tal. Niphad, Dist. Nashik On Affidavit 216 Shri Balchand M. Nathe, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 217 Shri Mhatarba D. Bhoj, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 218 Shri Manik B. Jhalte, At Post Vadali, Tal. Niphad, Dist. Nashik On Affidavit 219 Shri Shivaji S. Avad, At Post Sundarpur, Tal. Niphad, Dist. Nashik On Affidavit 220 Shri Sukhdeo P. Hire, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 221 Shri Murlidhar B. Derle, At Post Karanji, Tal. Niphad, Dist. Nashik On Affidavit 222 Shri Tukaram S. Gholap, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 223 Shri Ramnath D. Gaikwad, At Post Konkangaon, Tal. Niphad, Dist.

Nashik On Affidavit

224 Shri Dhondi G. Tarle, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 225 Shri Ravindra P. Sathe, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit


ANNEXURE - I 244

S.No. Name and Address of the Objector Remarks 226 Shri Rangnath R. Nirwade, At Post Narayantembi, Tal. Niphad, Dist.

Nashik On Affidavit

227 Shri Pandurang G. Sanap, At Post Shingave, Tal. Niphad, Dist. Nashik On Affidavit 228 Shri Shankar K. Avad, At Post Kurudgaon, Tal. Niphad, Dist. Nashik On Affidavit 229 Shri Damodar D. Gite, At Post Khedalejung, Tal. Niphad, Dist. Nashik On Affidavit 230 Shri Eknath Karbhari Pagare, At Post Jivhale, Tal. Niphad, Dist. Nashik On Affidavit 231 Shri Khanderao M. Wagh, At Post Kuradgaon, Tal. Niphad, Dist. Nashik On Affidavit 232 Shri Namdeo N. Mogal, At Post Kothure, Tal. Niphad, Dist. Nashik On Affidavit 233 Shri Ramrao S. Rajole, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 234 Shri Karbhari Shivram Shelar, At Post Chitegaon, Tal. Niphad, Dist.

Nashik On Affidavit

235 Shri Ramnath P. Gavali, At Post Kolgaon, Tal. Niphad, Dist. Nashik On Affidavit 236 Shri Raghunath N. Shelke, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 237 Shri Karbhari R. Jadhav, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 238 Shri Gangadhar T. Shinde, At Post Shingave, Tal. Niphad, Dist. Nashik On Affidavit 239 Shri Madhukar S. Tarle, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 240 Shri Rambhau Y. Boraste, At Post Sakore Mig, Tal. Niphad, Dist. Nashik On Affidavit 241 Shri Santu G. Lavande, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit 242 Smt. Saraswati P. Boraste, At Post Konkangaon, Tal. Niphad, Dist.

Nashik On Affidavit

243 Shri Kisanbhau Tarle, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 244 Shri Sakharam Raoji Jadhav, At Post Chandori, Tal. Niphad, Dist.

Nashik On Affidavit

245 Shri Pandit D. Tarle, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 246 Smt. Laxmibai B. Korade, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 247 Shri Balu T. Nimbalkar, At Post Karanji, Tal. Niphad, Dist. Nashik On Affidavit 248 Shri Madhukar M. Raite, At Post Shingave, Tal. Niphad, Dist. Nashik On Affidavit 249 Shri Laxman V. Boraste, At Post Sakore, Tal. Niphad, Dist. Nashik On Affidavit 250 Shri Vasant K. Derle, At Post Pimplas, Tal. Niphad, Dist. Nashik On Affidavit 251 Shri Vithalnana Shankhapal, At Post Karsul, Tal. Niphad, Dist. Nashik On Affidavit 252 Shri Laxman K. Walunj, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 253 Shri Balu K. Kharat, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 254 Shri Vasant M. Rajole, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 255 Shri Bandu D. Barade, At Post Sakhalewadi, Tal. Niphad, Dist. Nashik On Affidavit 256 Shri Pandit B. Sangole, At Post Talawade, Tal. Niphad, Dist. Nashik On Affidavit 257 Shri Babasaheb D. Sanap, At post Lalwadi, Tal. Niphad, Dist. Nashik On Affidavit 258 Shri Fakira G. Sangamner, At Post Kherwadi, Tal. Niphad, Dist. Nashik On Affidavit 259 Shri Pandharinath M. Derle, At Post Shingave, Tal. Niphad, Dist. Nashik On Affidavit 260 Shri Rajaram M. Shinde, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 261 Shri Digamar K. Gare, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit


ANNEXURE - I 245

S.No. Name and Address of the Objector Remarks 262 Shri Raosaheb D. Patil, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 263 Shri Ramchandra T. Godase, At Post Wadalinajik, Tal. Niphad, Dist.

Nashik On Affidavit

264 Shri Popat K. Kokate. At Post Pimplas, Tal. Niphad, Dist. Nashik On Affidavit 265 Shri Gangadhar B. Gadakha, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 266 Shri Sahebrao W. Mogal, At Post Shingawe, Tal. Niphad, Dist. Nashik On Affidavit 267 Shri Ashok B. Jhalte, At Post Wadalinajik, Tal. Niphad, Dist. Nashik On Affidavit 268 Shri Damutatya Gaikwad, At Post Konkangaon, Tal. Niphad, Dist.

Nashik On Affidavit

269 Shri Tatyaba D. Derele, At Post Shingawe, Tal. Niphad, Dist. Nashik On Affidavit 270 Shri Murlidhar P. Nirbhavane, At Post Sarolethadi, Tal. Niphad, Dist.

Nashik On Affidavit

271 Shri Ganpat S. Ramane, At Post Chehedi, Tal. Niphad, Dist. Nashik On Affidavit 272 Shri Nana Bhagat Jadhav, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 273 Shri Shivshankar M. Korade, At Post Chandori, Tal. Niphad, Dist.

Nashik On Affidavit

274 Shri Karbhari R. Wagh, At Post Kathargaon, Tal. Niphad, Dist. Nashik On Affidavit 275 Shri Vithal B. Bhandare, At Post Dusabe Sukene, Tal. Niphad, Dist.

Nashik On Affidavit

276 Shri Gangadhar B. Ghotekar, At Post Khedle Junge, Tal. Niphad, Dist. Nashik

On Affidavit

277 Shri Vithoba Yesu Kshirsagar, At Post Karsul, Tal. Niphad, Dist. Nashik On Affidavit 278 Shri Suresh V. Matsagar, At Post Pimplas, Tal. Niphad, Dist. Nashik On Affidavit 279 Shri Ramchandra D. Warkhede, At Post Chandori, Tal. Niphad, Dist.

Nashik On Affidavit

280 Shri Damu R. Murkute, At Post Mhalsakhore, Tal. Niphad, Dist. Nashik On Affidavit 281 Shri Madhukar T. Gayakhe, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 282 Smt. Amruta Pandharinath Tarle, At Post Chandori, Tal. Niphad, Dist.

Nashik On Affidavit

283 Shri Popat V. Warkhede, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 284 Shri Govind M. Sangale, At Post Tamaswadi, Tal. Niphad, Dist. Nashik On Affidavit 285 Shri Karbhari B. Pagore, At Post Jivhale, Tal. Niphad, Dist. Nashik On Affidavit 286 Shri Sadashiv T. Dound, At Post Lonwadi, Tal. Niphad, Dist. Nashik On Affidavit 287 Shri Baburao G. Khapare, At Post Urgaon, Tal. Niphad, Dist. Nashik On Affidavit 288 Shri Damodar G. Khajare, At Post Urgaon, Tal. Niphad, Dist. Nashik On Affidavit 289 Shri Madhukar M. Bhor, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 290 Shri Baburao G. More, At Post Konkangaon, Tal. Niphad, Dist. Nashik On Affidavit 291 Shri Sukhdeo Shankar Sangale, At Post Tamaswadi, Tal. Niphad, Dist.

Nashik On Affidavit

292 Shri Gotiram M. Derle, At Post Shingave, Tal. Niphad, Dist. Nashik On Affidavit 293 Shri Manohar A. Kulkarni, At Post Pimplas, Tal. Niphad, Dist. Nashik On Affidavit


ANNEXURE - I 246

S.No. Name and Address of the Objector Remarks 294 Shri Bhausaheb K. Adsare, At Post Karanji, Tal. Niphad, Dist. Nashik On Affidavit 295 Shri Trambak S. Shettye, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 296 Shri Laxmibai S. Warkhede, At Post Chandori, Tal. Niphad, Dist. Nashik

On Affidavit

297 Shri Dashrath K. Garode, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 298 Shri Murlidhar B. Kale, At Post Jalgaon, Tal. Niphad, Dist. Nashik On Affidavit 299 Shri Baburao B. Hire, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 300 Shri Gopal S. Gayakhe, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 301 Shri Arjun S. Gorade, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 302 Shri Trimbak M. Fad, At Post Mhalsakore, Tal. Niphad, Dist. Nashik On Affidavit 303 Shri Gopala S. Gayakhe, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 304 Shri Kisan B. Warkhode, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 305 Shri Fakira B. Bhadsare, At Post Karanji, Tal. Niphad, Dist. Nashik On Affidavit 306 Shri Nivrutti K. Tarle, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 307 Shri Popat S. Tarle, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 308 Shri Sampatrao G. Somavandhi, At Post Sundarpur, Tal. Niphad, Dist.

Nashik On Affidavit

309 Shri Trambak B. Bhane, At Post K. Sukene, Tal. Niphad, Dist. Nashik On Affidavit 310 Shri Chiman D. Sanap, At Post Shingave, Tal. Niphad, Dist. Nashik On Affidavit 311 Shri Fakira Malhari Tarle, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 312 Shri Shankar Baban Kumbhar, At Post Konkangaon, Tal. Niphad, Dist.

Nashik On Affidavit

313 Shri Lahanu Bhau Hire, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 314 Shri Sampat M. Gadakha, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 315 Shri Shivaji P. Gadakha, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 316 Shri Kishan T. Kshirsagar, At Post Khadumalegaon, Tal. Niphad, Dist.

Nashik On Affidavit

317 Shri Ramnath D. Bharote, At Post Tamaswadi, Tal. Niphad, Dist. Nashik On Affidavit 318 Shri Shivaji R. Nathe, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 319 Shri Trambak G. Kutane, At Post Nanduramdeshwar, Tal. Niphad, Dist.

Nashik On Affidavit

320 Shri Devaji B. Pawar, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 321 Shri Balwant S. Bhandwad, At Post Kuradgaon, Tal. Niphad, Dist.

Nashik On Affidavit

322 Shri Dattatraya S. Garode, At Post Warhedearana, Tal. Niphad, Dist. Nashik

On Affidavit

323 Shri Sitaram L. Gaikwad, At Post Jivhale, Tal. Niphad, Dist. Nashik On Affidavit 324 Shri Vithoba B. Sanap, At Post Shivare, Tal. Niphad, Dist. Nashik On Affidavit 325 Shri Bhika G. Derle, At Post Shingave, Tal. Niphad, Dist. Nashik On Affidavit 326 Shri Namdeo Y. Ghorpade, At Post Sarolekhurd, Tal. Niphad, Dist.

Nashik On Affidavit


ANNEXURE - I 247

S.No. Name and Address of the Objector Remarks 327 Bhairaonath Sahakari Upsa Jalsinchan Sanstha, At Post Chandori, Tal.


328 Jay Malhar Upsa Jalsinchan Sanstha, At Post Pimpalgaon, Nipani, Tal. Niphad, Dist. Nashik

On Affidavit

329 Shri Pandharinath S. Ghotekar, At Post Khedalejunjhe, Tal. Niphad, Dist. Nashik

On Affidavit

330 Shri Vishnu Mahadu More, At Post Konkangaon, Tal. Niphad, Dist. Nashik

On Affidavit

331 Shri Kashinath A. Boraste, At Post Sakore, Tal. Niphad, Dist. Nashik On Affidavit 332 Shri Bhaskar B. Bhabade, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit 333 Shri Chandrabhan B. Boraste, At Post Sakore, Tal. Niphad, Dist. Nashik On Affidavit 334 Shri Balwant B. Khandve, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit 335 Shri Bhaskar K. More, At Post Konkangaon, Tal. Niphad, Dist. Nashik On Affidavit 336 Shri Pandurang D. Garud, At Post Konkangaon, Tal. Niphad, Dist.

Nashik On Affidavit

337 Shri Raghunath S. Gaikwad, At Post Konkangaon, Tal. Niphad, Dist. Nashik

On Affidavit

338 Shri Uttam R. Dawange, At Post Sakore, Tal. Niphad, Dist. Nashik On Affidavit 339 Shri Manik G. More, At Post Konkangaon, Tal. Niphad, Dist. Nashik On Affidavit 340 Shri Dinkar K. More, At Post Konkangaon, Tal. Niphad, Dist. Nashik On Affidavit 341 Shri Dashrath L. Boraste, At Post Sakore, Tal. Niphad, Dist. Nashik On Affidavit 342 Shri Namdeo K. Wabale, At Post Konkangaon, Tal. Niphad, Dist. Nashik On Affidavit 343 Shri Kondaji P. Gade, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit 344 Shri Damu Abaji Tarle, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 345 Shri Dattu K. Sanghan, At Post Kohure, Tal. Niphad, Dist. Nashik On Affidavit 346 Shri Rambhau P. Kadam, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit 347 Shri Balu S. Lawande, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit 348 Shri Murlidhar G. Pingal, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit 349 Shri Shaikh B. Tamboli, At Post Konkangaon, Tal. Niphad, Dist. Nashik On Affidavit 350 Shri Ramkrishna H. Gaikwad, At Post Konkangaon, Tal. Niphad, Dist.

Nashik On Affidavit

351 Shri Dashrath W. Boraste, At Post Sakore, Tal. Niphad, Dist. Nashik On Affidavit 352 Shri Dhondiba R. Dongare, At Post Kurdagaon, Tal. Niphad, Dist.

Nashik On Affidavit

353 Shri Sampat S. Mali, At Post Pimplas, Tal. Niphad, Dist. Nashik On Affidavit 354 Shri Nivruti D. Sukhade, At Post Pimplas, Tal. Niphad, Dist. Nashik On Affidavit 355 Shri Ramnath S. Khalkar, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 356 Shri Vithal P Gothekar, At Post Kolgaon, Tal. Niphad, Dist. Nashik On Affidavit 357 Shri Dattatraya S. Boraste, At Post Sakore, Tal. Niphad, Dist. Nashik On Affidavit 358 Shri Khanderao S. Boraste, At Post Sakore, Tal. Niphad, Dist. Nashik On Affidavit 359 Shri Mahadu B. Gade, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit


ANNEXURE - I 248

S.No. Name and Address of the Objector Remarks 360 Shri Bhaskar K. Sangale, At Post Tamaswadi, Tal. Niphad, Dist. Nashik On Affidavit 361 Shri Pandhari Y. Gunjal At Post Mhalsakore, Tal. Niphad, Dist. Nashik On Affidavit 362 Shri Dattatraya B. Korade, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 363 Shri Dattatraya G. Gawali, At Post Narayan Tembhi, Tal. Niphad, Dist.

Nashik On Affidavit

364 Shri Popat D. Mogal, At Post Kohure, Tal. Niphad, Dist. Nashik On Affidavit 365 Shri Pandharinath M. Tajane, At Post Pimplas, Tal. Niphad, Dist. Nashik On Affidavit 366 Smt. Tarabai K. Pawar, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit 367 Shri Radho B. Tarle, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 368 Shri Suresh K. Karad, At Post Jalgaon, Tal. Niphad, Dist. Nashik On Affidavit 369 Shri Motiram D. Katkade, At Post Kurudgaon, Tal. Niphad, Dist. Nashik On Affidavit 370 Shri Santu M. Pingal, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit 371 Shri Raghunath B. Takate, At Post Karsul, Tal. Niphad, Dist. Nashik On Affidavit 372 Shri Punja M. More, At Post Konkangaon, Tal. Niphad, Dist. Nashik On Affidavit 373 Shri Sopan Tawaji Bhalerao, At Post Chandori, Tal. Niphad, Dist.

Nashik On Affidavit

374 Shri Somnath V. Ghotekar, At Post Khedalejhunge, Tal. Niphad, Dist. Nashik

On Affidavit

375 Shri Bandu S. Dalvi, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit 376 Shri Sudam K. Kale, At Post Pathkhed, Tal. Niphad, Dist. Nashik On Affidavit 377 Shri Dattu G. Shinde, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 378 Shri Eknath S. Danage, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit 379 Shri Pundlik K. Sangale, At Post Kurudgaon, Tal. Niphad, Dist. Nashik On Affidavit 380 Shri Waman G. Gaikwad, At Post Konkangaon, Tal. Niphad, Dist.

Nashik On Affidavit

381 Shri Kishan D. Thange, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit 382 Shri Yashwant V. More, At Post Konkangaon, Tal. Niphad, Dist. Nashik On Affidavit 383 Smt. Mirabai D. Satbhai, At Post Rasalpur, Tal. Niphad, Dist. Nashik On Affidavit 384 Shri Nivrutti D. Aaher, At Post Pimplas, Tal. Niphad, Dist. Nashik On Affidavit 385 Shri Kishan R. Sangale, At Post Kaghargaon, Tal. Niphad, Dist. Nashik On Affidavit 386 Shri Trambak A. Boraste, At Post Sakore, Tal. Niphad, Dist. Nashik On Affidavit 387 Shri Pandurang D. Dongare, At Post Kurudgaon, Tal. Niphad, Dist.

Nashik On Affidavit

388 Shri Raosaheb D. Sakpal, At Post Kasrul, Tal. Niphad, Dist. Nashik On Affidavit 389 Shri Raghunath S. Malode, At Post Sakore, Tal. Niphad, Dist. Nashik On Affidavit 390 Shri Manik R. Boraste, At Post Sakore, Tal. Niphad, Dist. Nashik On Affidavit 391 Shri Babu M. Loknar, At Post Konkangaon, Tal. Niphad, Dist. Nashik On Affidavit 392 Shri Pratap B. Rajole, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 393 Shri Raosaheb D. Somvanshi, At Post Sudanpur, Tal. Niphad, Dist.

Nashik

On Affidavit


ANNEXURE - I 249

S.No. Name and Address of the Objector Remarks 394 Shri Ramgir Sudamgir Gosavi, At Post Konkangaon, Tal. Niphad, Dist.

Nashik On Affidavit

395 Shri Karbhari K. Wabale, At Post Konkangaon, Tal. Niphad, Dist. Nashik

On Affidavit

396 Shri Kisan Tatya Gaikwad, At Post Konkangaon, Tal. Niphad, Dist. Nashik

On Affidavit

397 Shri Ramchandra K. Barve, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit 398 Shri Prakash B. Chopda, At Post Sakora, Tal. Niphad, Dist. Nashik On Affidavit 399 Shri Arun Parshuram Jhalate, At Post Wagli najik, Tal. Niphad, Dist.

Nashik On Affidavit

400 Shri Pandharinath M. Rayate, At Post Khadakmalegaon, Tal. Niphad, Dist. Nashik

On Affidavit

401 Shri Baburao A. Khule, At Post Lonwadi, Tal. Niphad, Dist. Nashik On Affidavit 402 Shri Bhika A. Kanve, At Post Tamaswadi, Tal. Niphad, Dist. Nashik On Affidavit 403 Shri Shantaram G. Ghotekar, At Post Konkangaon, Tal. Niphad, Dist.

Nashik On Affidavit

404 Shri Vithoba D. Bhambare, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit 405 Shri Ramnath L. Gaikwad, At Post Jivale, Tal. Niphad, Dist. Nashik On Affidavit 406 Shri Vasant E. Jadhav, At Post Karsul, Tal. Niphad, Dist. Nashik On Affidavit 407 Sarpanch Grampanchayat, At Post Karanji, Tal. Niphad, Dist. Nashik On Affidavit 408 Shri Laxman B. Avare, At Post Tamaswadi, Tal. Niphad, Dist. Nashik On Affidavit 409 Smt. Sitabai N. Kadale, At Post Wadali, Tal. Niphad, Dist. Nashik On Affidavit 410 Shri Bajirao S. Kadam, At Post Wadali, Tal. Niphad, Dist. Nashik On Affidavit 411 Smt. Sitabai R. Dhondge, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit 412 Smt. Rakhambai L. Tarle, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 413 Shri Waman D. Pagere, At Post Jiwale, Tal. Niphad, Dist. Nashik On Affidavit 414 Shri Punja H. Ghumare, At Post Khedalejhunge, Tal. Niphad, Dist.

Nashik On Affidavit

415 Shri Prabhakar M. Adsare, At Post Karanji, Tal. Niphad, Dist. Nashik On Affidavit 416 Shri Tramabak N. Bhambare, At Post Chitegaon, Tal. Niphad, Dist.

Nashik On Affidavit

417 Shri Madhav B. Bhambare, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit 418 Shri Tatyaba P. Mhaske, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit 419 Shri Shivaji Namdeo Takate, At Post Karsul, Tal. Niphad, Dist. Nashik On Affidavit 420 Shri Ramchandra S. Sanap, At Post Shingave, Tal. Niphad, Dist. Nashik On Affidavit 421 Shri Balaji S. Gambhire, At Post Dharangaon, Tal. Niphad, Dist. Nashik On Affidavit 422 Shri Govind K Bhoj, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 423 Shri Bandu D. Aaher, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 424 Smt. Narmdabai S. Bhoj, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 425 Shri Pandit P. Ghotekar, At Post Kolgaon, Tal. Niphad, Dist. Nashik On Affidavit 426 Shri Balkrishna S. Shelar, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit


ANNEXURE - I 250

S.No. Name and Address of the Objector Remarks 427 Shri Malhari R. Sanap, At Post Lalwadi, Tal. Niphad, Dist. Nashik On Affidavit 428 Smt. Draupadabai B. Guawali, At Post Kherlejunge, Tal. Niphad, Dist.

Nashik

On Affidavit

429 Shri Hari R. Saraode, At Post Konkangaon, Tal. Niphad, Dist. Nashik On Affidavit 430 Shri Nivrutti B. Pade, At Post Lalwadi, Tal. Niphad, Dist. Nashik On Affidavit 431 Smt. Laxmibai W. Barve, At Post Kohure, Tal. Niphad, Dist. Nashik On Affidavit 432 Shri Eknath D. Sangole, At Post Tamaswadi, Tal. Niphad, Dist. Nashik On Affidavit 433 Shri Ashok N. Gaikwad, At Post Konkangaon, Tal. Niphad, Dist. Nashik On Affidavit 434 Shri Raghunath S. Gade, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit 435 Shri Janardan Y. More, At Post Shirasgaon, Tal. Niphad, Dist. Nashik On Affidavit 436 Shri Dhondiram R. Nale, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 437 Shri Ashok Gangadhar Boraste, At Post Sakore, Tal. Niphad, Dist.

Nashik On Affidavit

438 Smt. Babyabhai K. Dhemse, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 439 Shri Kondaji A. Jhalte, At Post Wadali, Tal. Niphad, Dist. Nashik On Affidavit 440 Shri Rangnath S. Gaikwad, At Post Konkangaon, Tal. Niphad, Dist.

Nashik On Affidavit

441 Shri Laxman G. Gaikwad, At Post Konkangaon, Tal. Niphad, Dist. Nashik

On Affidavit

442 Shri Dagu R. Mogal, At Post Kohure, Tal. Niphad, Dist. Nashik On Affidavit 443 Shri Sitaram M. Gade, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit 444 Shri Daulat W. Shinde, At Post Kaghargaon, Tal. Niphad, Dist. Nashik On Affidavit 445 Shri Murlidhar T. Pawar, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit 446 Shri Rambhau P. Kadam, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit 447 Shri Laxman K. Londe, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 448 Shri Phakira A. Khandwe, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit 449 Shri Daulat M. Gade, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit 450 Shri Badshah D. Shaikh, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit 451 Shri Lalu P. Bhandage, At Post Konkangaon, Tal. Niphad, Dist. Nashik On Affidavit 452 Shri Kisan D. Gade, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit 453 Shri Bhika N. Gaikwad, At Post Konkangaon, Tal. Niphad, Dist. Nashik On Affidavit 454 Smt. Ambabai P. Khaire, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit 455 Shri Krishna G. Bhoye, At Post Mhasagaon, Tal. Niphad, Dist. Nashik On Affidavit 456 Shri Sakharam N. Gande, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit 457 Shri Bhika M. Bhhapkar, At Ppost Ttalwade, Tal. Niphad, Dist. Nashik On Affidavit 458 Smt. Anandibai Namdeo Gawali, At Post Mhsagaon, Tal. Niphad, Dist.

Nashik On Affidavit

459 Shri Dhondibhai P. Shaikh, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit 460 Shri Bandu S. Dalvi, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit 461 Shri Motiram L. Hujare, At Post Chehadi, Tal. Niphad, Dist. Nashik On Affidavit


ANNEXURE - I 251

S.No. Name and Address of the Objector Remarks 462 Shri Sahebrao P. Heere, At Post Chatori, Tal. Niphad, Dist. Nashik On Affidavit 463 Shri Manik K. More, At Post Konkangaon, Tal. Niphad, Dist. Nashik

On Affidavit

464 Shri Bhikaji N. Gaikwad, At Post Konkangaon, Tal. Niphad, Dist. Nashik

On Affidavit

465 Shri Nivrutti N. Raut, At Post Konkangaon, Tal. Niphad, Dist. Nashik On Affidavit 466 Smt. Tarabai B. Gaikwad, At Post Konkangaon, Tal. Niphad, Dist.

Nashik On Affidavit

467 Shri Bhika S. More, At Post Konkangaon, Tal. Niphad, Dist. Nashik On Affidavit 468 Shri Kishan L. Gambhire, At Post Dharangaon Vir, Tal. Niphad, Dist.

Nashik On Affidavit

469 Shri Balkrishna S. Waghchoure, At Post Karsul, Tal. Niphad, Dist. Nashik

On Affidavit

470 Shri Ramnath T. Padghule, At Post Darnasawangi, Tal. Niphad, Dist. Nashik

On Affidavit

471 Shri Santu G. Hire, At Post Chatori, Tal. Niphad, Dist. Nashik On Affidavit 472 Shri Dilip M. Gaikwad, At Post Konkangaon, Tal. Niphad, Dist. Nashik On Affidavit 473 Shri Laxman S. Warkhede, At Post Saongaon, Tal. Niphad, Dist. Nashik On Affidavit 474 Shri Govind K. Jadhav, At Post Konkangaon, Tal. Niphad, Dist. Nashik On Affidavit 475 Shri Rangnath S. Dhemse, At Post Kherwadi, Tal. Niphad, Dist. Nashik On Affidavit 476 Shri Eknath K. Aawhad, At Post Dharangaon Vir, Tal. Niphad, Dist.

Nashik On Affidavit

477 Shri Ramchandra M. Bodke, At Post Saikheda, Tal. Niphad, Dist. Nashik On Affidavit 478 Shri Sampat Hari Saronde, At Post Konkangaon, Tal. Niphad, Dist.

Nashik On Affidavit

479 Shri Pandharinath R. Mogal, At Post Kohure, Tal. Niphad, Dist. Nashik On Affidavit 480 Shri Namdeo S. More, At Post Konkangaon, Tal. Niphad, Dist. Nashik On Affidavit 481 Trambak Y. More, At Post Konkangaon, Tal. Niphad, Dist. Nashik On Affidavit 482 Shri Babu T. Gaikwad, At Post Konkangaon, Tal. Niphad, Dist. Nashik On Affidavit 483 Shri Ramdas G. Shinde, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit 484 Shri Jankiram R. Poraje, At Post Konkangaon, Tal. Niphad, Dist. Nashik On Affidavit 485 Shri Khanderao B. Loknar, At Post Konkangaon, Tal. Niphad, Dist.

Nashik On Affidavit

486 Shri Narayan P. Sangale, At Post Khuradgaon, Tal. Niphad, Dist. Nashik On Affidavit 487 Shri Ramrao N. More, At Post Konkangaon, Tal. Niphad, Dist. Nashik On Affidavit 488 Shri Appa Baburao Gaikwad, At Post Kokangaon, Tal. Niphad, Dist.

Nashik On Affidavit

489 Shri Shivaji N. Gaikwad, At Post Konkangaon, Tal. Niphad, Dist. Nashik On Affidavit 490 Shri Barku S. Loknar, At Post Konkangaon, Tal. Niphad, Dist. Nashik On Affidavit 491 Shri Sampat T. Warkhede, At Post Saongaon, Tal. Niphad, Dist. Nashik On Affidavit 492 Shri Bahuso S. More, At Post Konkangaon, Tal. Niphad, Dist. Nashik On Affidavit


ANNEXURE - I 252

S.No. Name and Address of the Objector Remarks 493 Shri Waman P. More, At Post Konkangaon, Tal. Niphad, Dist. Nashik On Affidavit 494 Shri Shivram R. More, At Post Konkangaon, Tal. Niphad, Dist. Nashik On Affidavit 495 Shri Karbhari K. Shelar, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit 496 Shri Sukhdeo B. Bhapkar, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit

497 Shri Mahadeo S. Kanmahale, At Post Chitegaon, Tal. Niphad, Dist. Nashik

On Affidavit

498 Shri Gangadhar L. Gawali, At Post Narayan Tembhi, Tal. Niphad, Dist. Nashik

On Affidavit

499 Shri Suresh B. Sanap, At Post Lalwadi, Tal. Niphad, Dist. Nashik On Affidavit 500 Shri Subhash V. Nimbalkar, At Post Karanji, Tal. Niphad, Dist. Nashik On Affidavit 501 Shri Rajaram D. Derle, At Post Shingawe, Tal. Niphad, Dist. Nashik On Affidavit 502 Shri Manohar B. Nagare, At Post Jalgaon, Tal. Niphad, Dist. Nashik On Affidavit 503 Shri Narayan H. Salwe, At Post Kathargaon, Tal. Niphad, Dist. Nashik On Affidavit 504 Shri Manaji M. Shinde, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit 505 Shri Devram S. Ghadape, At Post Manjargaon, Tal. Niphad, Dist. Nashik On Affidavit 506 Shri Chhabildas V. Shinde, At Post Shingawe, Tal. Niphad, Dist. Nashik On Affidavit 507 Shri Madhav B. Jhalte, At Post Wadali Najik, Tal. Niphad, Dist. Nashik On Affidavit 508 Shri Dattatraya S. Shinde, At Post Kathargaon, Tal. Niphad, Dist. Nashik On Affidavit 509 Shri Shankar R. Pingal, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit 510 Shri Shrihari V. Mogal, At Post Kohure, Tal. Niphad, Dist. Nashik On Affidavit 511 Shri Savliram M. Rajole, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 512 Shri Malik D. Mogal, At Post Kohure, Tal. Niphad, Dist. Nashik On Affidavit 513 Shri Dattu S. Gadakh, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 514 Shri Namdeo N. Ghumare, At Post Sakore, Tal. Niphad, Dist. Nashik On Affidavit 515 Shri Nivrutti K. Ghadge, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 516 Shri Shankar G. Gambhire, At Post Dharangaon Vir, Tal. Niphad, Dist.

Nashik On Affidavit

517 Shri Baburao L. Ghotekar, At Post Kolgaon, Tal. Niphad, Dist. Nashik On Affidavit 518 Shri Gangadhar T. Soman, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 519 Shri Bapu Y. More, At Post Konkangaon, Tal. Niphad, Dist. Nashik On Affidavit 520 Shri Popat S. Gadakh, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 521 Shri Pandhrinath N. More, At Post Konkangaon, Tal. Niphad, Dist.

Nashik On Affidavit

522 Shri Waman N. Boraste, At Post Sakore, Tal. Niphad, Dist. Nashik On Affidavit 523 Shri Vasant S. Thorat, At Post Jivhale, Tal. Niphad, Dist. Nashik On Affidavit 524 Shri Rangnath G. Likale, At Post Jivhale, Tal. Niphad, Dist. Nashik On Affidavit 525 Shri Karbhari H. Gawali, At Post Narayantembhi, Tal. Niphad, Dist.

Nashik On Affidavit

526 Shri Kashinath S. Wagh, At Post Kathargaon, Tal. Niphad, Dist. Nashik On Affidavit 527 Shri Ramdas S. Shinde, At Post Chatori, Tal. Niphad, Dist. Nashik On Affidavit


ANNEXURE - I 253

S.No. Name and Address of the Objector Remarks 528 Shri Balu R. Kadam, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit 529 Shri Bhaskar M. Mogal, At Post Mouje Sukene, Tal. Niphad, Dist.

Nashik On Affidavit

530 Shri Rajaram N. Dabhade, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit 531 Shri Parshuram M. More, At Post Konkangaon, Tal. Niphad, Dist.

Nashik On Affidavit

532 Shri Pandharinath B. Gaikwad, At Post Jivhale, Tal. Niphad, Dist. Nashik

On Affidavit

533 Shri Shivaji P. More, At Post Konkangaon, Tal. Niphad, Dist. Nashik On Affidavit 534 Shri Arjun D. More, At Post Konkangaon, Tal. Niphad, Dist. Nashik On Affidavit 535 Shri Vithoba B. Tarle, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit 536 Shri Trambak M. Warkhede, At Post Chatori, Tal. Niphad, Dist. Nashik On Affidavit 537 Shri Govindrao G. Sukhade, At Post Pimplas, Tal. Niphad, Dist. Nashik On Affidavit 538 Shri Bhaskar D. More, At Post Konkangaon, Tal. Niphad, Dist. Nashik On Affidavit 539 Shri Chandrakant K. Boraste, At Post Sakore, Tal. Niphad, Dist. Nashik On Affidavit 540 Shri Shankar G. Borade, At Post Thergaon, Tal. Niphad, Dist. Nashik On Affidavit 541 Shri Daulat L. Sabale, At Post Khedlejunge, Tal. Niphad, Dist. Nashik On Affidavit 542 Shri Vishnu T. Gangurde, At Post Konkangaon, Tal. Niphad, Dist.

Nashik On Affidavit

543 Shri Vasant S. Jhalate, At Post Wadali, Tal. Niphad, Dist. Nashik On Affidavit 544 Shri Ramrao J. Gaikwad, At Post Konkangaon, Tal. Niphad, Dist. Nashik On Affidavit 545 Shri Shankar G. Lawand, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit 546 Shri Vijay A. More, At Post Konkangaon, Tal. Niphad, Dist. Nashik On Affidavit 547 Shri Parvatrao S. Deshmukh, At Post Chitegaon, Tal. Niphad, Dist.

Nashik On Affidavit

548 Shri Pundlik K. Loknar, At Post Konkangaon, Tal. Niphad, Dist. Nashik On Affidavit 549 Shri Baburao N. Shinde, At Post Kathargaon, Tal. Niphad, Dist. Nashik On Affidavit 550 Shri Shankar S. Heer, At Post Chatori, Tal. Niphad, Dist. Nashik On Affidavit 551 Shri Dattatraya M. Gambhir, At Post Dharangaon Vir, Tal. Niphad, Dist.

Nashik On Affidavit

552 Shri Balu P. Shinde, At Post Tamaswadi, Tal. Niphad, Dist. Nashik On Affidavit 553 Shri Madhav R. Geete, At Post Rasalpur, Tal. Niphad, Dist. Nashik On Affidavit 554 Shri Laxman D. Aarote, At Post Tamaswadi, Tal. Niphad, Dist. Nashik On Affidavit 555 Shri Kacharu P. Gade, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit 556 Shri Narayan W. Patole, At Post Chehadi, Tal. Niphad, Dist. Nashik On Affidavit 557 Shri Sampat T. Shinde, At Post Karanjgaon, Tal. Niphad, Dist. Nashik On Affidavit 558 Shri Radhakrishna k. Patil, At Post Kathargaon, Tal. Niphad, Dist.

Nashik On Affidavit

559 Shri Sukhdeo G. Sanap, At Post Shiware, Tal. Niphad, Dist. Nashik On Affidavit 560 Shri Pandurang S. Tarle, At Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 561 Shri Gangadhar B. Gaikwad, At Post Jiwhale, Tal. Niphad, Dist. Nashik On Affidavit


ANNEXURE - I 254

S.No. Name and Address of the Objector Remarks 562 Shri Shaikh M. Babamiya, At Post Konkangaon, Tal. Niphad, Dist.

Nashik

On Affidavit

563 Shri Pundlik G. More, At Post Konkangaon, Tal. Niphad, Dist. Nashik On Affidavit 564 Shri Kailash B. Gawali, At Post Konkangon, Tal. Niphad, Dist. Nashik On Affidavit 565 Shri Laxmibai K. Mandlik, At Post Konkangaon, Tal. Niphad, Dist.

Nashik On Affidavit

566 Shri Dattu S. Thange, At Post Chittegaon, Tal. Niphad, Dist. Nashik On Affidavit 567 Shri Ahilaji N. Thikale, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit 568 Shri Ganpatrao L. Hire, At Post Charoli, Tal. Niphad, Dist. Nashik On Affidavit 569 Shri Tukaram H. Rayate, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit 570 Shri Ramu D. Tikale, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit 571 Shri Muralidhar B. Dabhade, At Post Chittegaon, Tal. Niphad, Dist.

Nashik On Affidavit

572 Shri Trambak G. Pingale, At Post Chittegaon, Tal. Niphad, Dist. Nashik On Affidavit 573 Shri Bala Bhau Dabhade, At Post Chittegaon, Tal. Niphad, Dist. Nashik On Affidavit 574 Shri Jaganath G. Dhoble, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit 575 Shri Narhari Nathu Gade, At Post Chittegaon, Tal. Niphad, Dist. Nashik On Affidavit 576 Shri Murlidhar P. Takate, At Post Karsul, Tal. Niphad, Dist. Nashik On Affidavit 577 Shri Vishnu F. Shelar, At Post Chittegaon, Tal. Niphad, Dist. Nashik On Affidavit 578 Shri Yashwant Annji Lonar, At Post Konkangaon, Tal. Niphad, Dist.

Nashik On Affidavit

579 Shri Yashwant B. Deshmukh, At Post Chittegaon, Tal. Niphad, Dist. Nashik

On Affidavit

580 Shri Mhasu Vithoba Gade, At Post Chittegaon, Tal. Niphad, Dist. Nashik On Affidavit 581 Shri Sampat R. Gade, At Post Chittegaon, Tal. Niphad, Dist. Nashik On Affidavit 582 Shri Balu P. Gaikwad, At Post Konkangaon, Tal. Niphad, Dist. Nashik On Affidavit 583 Shri Vijay Kondaji More, At Post Konkangaon, Tal. Niphad, Dist.

Nashik On Affidavit

584 Shri Baburao H. Gade, At Post Chittegaon, Tal. Niphad, Dist. Nashik On Affidavit 585 Shri Parshuram R. Kadam, At Post Chittegaon, Tal. Niphad, Dist. Nashik On Affidavit 586 Shri Rangnath N. More, At Post Konkangaon, Tal. Niphad, Dist. Nashik On Affidavit 587 Shri Baburao G. Dalvi, At Post Chittegaon, Tal. Niphad, Dist. Nashik On Affidavit 588 Shri Hari S. More, At Post Konkangaon, Tal. Niphad, Dist. Nashik On Affidavit 589 Shri Ganpat A. Gade, At Post Chittegaon, Tal. Niphad, Dist. Nashik On Affidavit 590 Shri Pandit R. Dhonde, At Post Konkangaon, Tal. Niphad, Dist. Nashik On Affidavit 591 Shri Kisan S. Shelar, At Post Chittegaon, Tal. Niphad, Dist. Nashik On Affidavit 592 Shri Jagannath S. Alode, At Post Sakore, Tal. Niphad, Dist. Nashik On Affidavit 593 Shri Sudhakar R. Alode, At Post Sakore, Tal. Niphad, Dist. Nashik On Affidavit 594 Shri Rangnath B. Pawar, At Post Karsul, Tal. Niphad, Dist. Nashik On Affidavit 595 Shri Ramrao K. More, At Post Konkangaon, Tal. Niphad, Dist. Nashik On Affidavit


ANNEXURE - I 255

S.No. Name and Address of the Objector Remarks 596 Shri Shankar R. Shankarpal, At Post Karsul, Tal. Niphad, Dist. Nashik On Affidavit 597 Shri Karbhari R. Hadpe, At Post Manjargaon, Tal. Niphad, Dist. Nashik On Affidavit 598 Shri Baburao S. Kadam, At Post Chittegaon, Tal. Niphad, Dist. Nashik On Affidavit 599 Shri Shaikh E. Balam, At Post Chittegaon, Tal. Niphad, Dist. Nashik On Affidavit 600 Shri Pandharinath D. Agale, At Post Chittegaon, Tal. Niphad, Dist.

Nashik On Affidavit

601 Shri Eknath S. Ekade, At Post Chittegaon, Tal. Niphad, Dist. Nashik On Affidavit 602 Shri Bhikaji P. More, At Post Konkangaon, Tal. Niphad, Dist. Nashik On Affidavit 603 Shri Damu B. Nagare, At Post Sathadi, Tal. Niphad, Dist. Nashik On Affidavit 604 Shri Kashinath M. Pingale, At Post Chittegaon, Tal. Niphad, Dist. Nashik On Affidavit 605 Shri Pandharinath N. More, At Post Konkangaon, Tal. Niphad, Dist.

Nashik On Affidavit

606 Shri Madhav G. Kadam, At Post Chittegaon, Tal. Niphad, Dist. Nashik On Affidavit 607 Shri Uttam N. More, At Post Konkangaon, Tal. Niphad, Dist. Nashik On Affidavit 608 Shri Trambak B. Gite, At Post Chittegaon, Tal. Niphad, Dist. Nashik On Affidavit 609 Shri Ramnath Y. Shinde, At Post Tamaswadi, Tal. Niphad, Dist. Nashik On Affidavit 610 Shri Kisan P. Shinde, At Post Tamaswadi, Tal. Niphad, Dist. Nashik On Affidavit 611 Shri Anil K. Kadam, At Post Chittegaon, Tal. Niphad, Dist. Nashik On Affidavit 612 Shri Vithoba R. More, At Post Konkangaon, Tal. Niphad, Dist. Nashik On Affidavit 613 Shri Khanderao G. Shinde, At Post Jalgaon, Tal. Niphad, Dist. Nashik On Affidavit 614 Shri Shankar V. Sangale, At Post Tamaswadi, Tal. Niphad, Dist. Nashik On Affidavit 615 Smt. Narmada S. Baste, At Post Kasrul, Tal. Niphad, Dist. Nashik On Affidavit 616 Shri Manik N. More, At Post Konkangaon, Tal. Niphad, Dist. Nashik On Affidavit 617 Shri Balasaheb T. Mali, At Post Gajarwadi, Tal. Niphad, Dist. Nashik On Affidavit 618 Shri Lahu J. More, At Post Konkangaon, Tal. Niphad, Dist. Nashik On Affidavit 619 Shri Uttam N. Kadlug, At Post Wadalinajik, Tal. Niphad, Dist. Nashik On Affidavit 620 Shri Dinkar D. Shelar, At Post Chittegaon, Tal. Niphad, Dist. Nashik On Affidavit 621 Shri Kashinath S. Pawar, At Post Chittegaon, Tal. Niphad, Dist. Nashik On Affidavit 622 Shri Waman S. Wagh, At Post Kathargaon, Tal. Niphad, Dist. Nashik On Affidavit 623 Shri Eknath H. Gade, At Post Chittegaon, Tal. Niphad, Dist. Nashik On Affidavit 624 Shri Pandurang S. Lawande, At Post Chittegaon, Tal. Niphad, Dist.

Nashik On Affidavit

625 Shri Vaman G. Kadam, At Post Chittegaon, Tal. Niphad, Dist. Nashik On Affidavit 626 Niphad Sahakari Upsa Jalsinchan Sahakari Sangh, At Post Chandori, Tal.


627 Shri Ramnath S. Dabhade, At Post Chittegaon, Tal. Niphad, Dist. Nashik On Affidavit 628 Shri Punja N. Gade, At Post Chittegaon, Tal. Niphad, Dist. Nashik On Affidavit 629 Shri Punjaji Y. Borade, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit 630 Shri Ahilaji P. Shinde, At Post Berwadi, Tal. Niphad, Dist. Nashik On Affidavit 631 Shri Gulabbhu V. Shaikh, At Post Sakore, Tal. Niphad, Dist. Nashik On Affidavit


ANNEXURE - I 256

S.No. Name and Address of the Objector Remarks 632 Shri Popat N. Gade, At Post Chittegaon, Tal. Niphad, Dist. Nashik

On Affidavit

633 Shri Bhausaheb D. Shinde, At Post Tamaswadi, Tal. Niphad, Dist. Nashik

On Affidavit

634 Shri Sudam B. Ghagote, At Post Khedale June, Tal. Niphad, Dist. Nashik On Affidavit 635 Chairman, Sanjivani Jalsinchan Sanstha, At Post Chandori, Tal. Niphad,


636 Shri Arun G. Boraste, At Post Sakori, Tal. Niphad, Dist. Nashik On Affidavit 637 Shri Sham M. Sangale, At Post Tamaswadi, Tal. Niphad, Dist. Nashik On Affidavit 638 Shri Balasaheb D. Hagote, At Post Khedale Junje, Tal. Niphad, Dist.

Nashik On Affidavit

639 Smt. Jayashree B. Gite, At Post Kothure, Tal. Niphad, Dist. Nashik On Affidavit 640 Shri Daulat B. Somavanshi, At Post Sundarpur, Tal. Niphad, Dist.

Nashik On Affidavit

641 Shri Shankar K. Pagare, At Post Nanduramadhameshwar, Tal. Niphad, Dist. Nashik

On Affidavit

642 Shri Bhalchandra K. More, At Post Konkangaon, Tal. Niphad, Dist. Nashik

On Affidavit

643 Shri Baburao G. More, At Post Konkangaon, Tal. Niphad, Dist. Nashik On Affidavit 644 Shri Yeshwant P. Wagh, At Post Ranwad, Tal. Niphad, Dist. Nashik On Affidavit 645 Shri Bhagwant L. Kadam, At Post Chittegaon, Tal. Niphad, Dist. Nashik On Affidavit 646 Shri Popat R. Themse, At Post Kharewadi, Tal. Niphad, Dist. Nashik On Affidavit 647 Shri Gulabrao J. Wagh, At Post Karsul, Tal. Niphad, Dist. Nashik On Affidavit 648 Shri Chimanrao B. Kathe, At Post K. Sukene, Tal. Niphad, Dist. Nashik On Affidavit 649 Shri Dadaraoji Matsagar, At Post Pimpas, Tal. Niphad, Dist. Nashik On Affidavit 650 Shri Murlidhar P. Gavli, At Post Kolgaon, Tal. Niphad, Dist. Nashik On Affidavit 651 Shri Husan Shaikh Abdulla, At Post Sundarpur, Tal. Niphad, Dist.

Nashik On Affidavit

652 Shri Kashinath S. Pawar, At Post Chitegaon, Tal. Niphad, Dist. Nashik On Affidavit 653 Shri A.K.Sharma, The Malegaon Co-operative Spinning Mills Ltd.

P.B.No.29, Malegaon-423 203 Without Affidavit

654 Shri Vijay N. Pagar, Savada Nagar Palika Tal-Raver, Dist- Jalgaon Without Affidavit

655 Shri Vijay N.Pagar, Faizpur Muncipal Council, Faizpur, Dist- Jalgaon-425503

Without Affidavit

656 Shri Rajaram R. Chawhanke, Kopargaon Taluka Peeth Girni Malak Chalak Sangh, C/o.2495 Anant Vijay Flour Mill Sanjay Nagar Kopargaon, Dist- Ahmednagar

Without Affidavit

657 Shri Mayank Tandon, Gen.Manager, Freshtrop Fruits Limited, Unit No-1, Gat No. 171, Village Jaulke, Bombay Agra Road, P.B.No.1, Post Ozar-422 207

Without Affidavit


ANNEXURE - I 257

S.No. Name and Address of the Objector Remarks 658 Shri Shriram C.Chokhani, Chairman, Sudal Industries Ltd., A-5, MIDC,

Ambad Industrial Area, Mumbai - Nashik Highway, Nashik 422 010

Without Affidavit

659 Shri Dilip Lunawat, Comm.Manager, Shree Vindhya Paper Mills Ltd., Somani Nagar, Duskheda, Bhusawal - 426203

Without Affidavit

660 Shri V.S.Chowdhari, Mobeen Ahmed Ali Asghar Haji, Ghar No.820, Gali No.13, Navapura, Near Modern Khanawal, Malegaon, Nashik

Without Affidavit

661 Shri Jayantsingh D. Patil, Prashant Residency, Flat No. 5, Indira Nagar, Nashik

Without Affidavit

662 Shri B.C. Gavit, Raver Nagar Parishad, Raver, Tal. Raver, Dist. Jalgaon Without Affidavit

663 Davi Aaghadi Nashik District, Nashik District, Nashik Without Affidavit

664 Shetkari Mandal Bhadgaon, Tal. Bhadgaon, Dist. Jalgaon Without Affidavit

665 Shri Vasantrao Mahajan, Chairman, Raver Yawal Taluka Agricultural Pump Owner’s Association, Dist. Jalgaon, Chinawal – 425505

Without Affidavit

666 Shri Bhaunana Sakharam Pagar, Plot No. 20, Nagre Mala, Hanumanwadi, Near Raka Nursery, Panchvati, Nashik

Without Affidavit

667 Shri Madan Bhaskarrao Matsagar & Shri Ashok Mohanrao Matsagar- Plot No.2/3, Radhanagar Chaudhary, Mala Hanumanwadi, Near Raka Nursery, Panchvati, Nashik

Without Affidavit

668 Shri Keshavrao V. Dhikle, Gram Panchayat Pimpri Sayyad, Tal. Dist. Nashik

Without Affidavit

669 Shri Pramod C. Mohole, Member, Maharashtra State Grahak Kalyan Nidhi Samiti Grahak Sangh, 403, Satbhai lane, Ahmednagar

Without Affidavit

670 Shri Brijlal Bansal, Chairman, Ban – Bro Metals Pvt. Ltd. – L – 4, MIDC, Ahmednagar

Without Affidavit

671 Shri J.D. Patil, Freedom Fiighter & chairman, Janta Dal, Dist. Jalgaon

Without Affidavit

672 Shri Raghunath S. Aadhav, Raghukul Apmt; Ground Floor, Opp. Seva Kunj, Panchvati, Nashik – 3

Without Affidavit

673 Shri Ashok N. Gujar, Secretary to Rajya Sanghtan, 4 – Pride Monarch, Near Mhsoba Temple, Nashik Road, Nashik

Without Affidavit

674 Shri Jeevan Vaishampayan, Nashik District Grahak Panchayat, 4, Shalimar Housing Society, Pumping Station, Gangapur Road, Nashik – 422 005

Without Affidavit

675 Shri A. D. Shirsat, 3/71, Old CIDCO, New Nashik – 422 009 Without Affidavit

676 Shri Arun N. Bhalerao, G.S. Maharashtra Rajya Magasvargiya Vidyut Karmachari Sanghatan – Falak Complex, Flat No. 6, Near Dattamandir Bus Stop, Nashik Road, Nashik

Without Affidavit


ANNEXURE - I 258

S.No. Name and Address of the Objector Remarks 677 Shri.Nishikant N. Kale, 29 - Meghana Housing Society, Bodhi, TC Lane

No.7, Shankarnagar No.2, Pune - 411 009 On Affidavit

678 Shri J.S.Arora, Director (Oper.) Finolex Industries Ltd. D-1/10,MIDC, Chinchwad, Pune- 411 019

On Affidavit

679 Shri Suresh N.Tendulkar, Prakash Fabricators, 1034 'E', Rajaram Road, P.B.No.207, Kolhapur-416 008

On Affidavit

680 Shri Rajaram B. Patil, Kolhapur Zilla Dalap-Kandap Girni Malak Sangh, Padmashri Apt. 1011 'K' Sangar Galli, Near Padmaraje Girls High School, Mangalwar Peth, Kolhapur

On Affidavit

681 Shri Sadashiv B. Desai, Chairman, Shiroli Manufacturers Association, P-12, Shamak Building, MIDC, Shiroli, Kolhapur- 416 122

On Affidavit

682 Shri B.R.Khedekar, Akhil Bhartiya Grahak Panchayat, 43/90, Navasahyadri Society, Pune- 411 052

On Affidavit

683 Shri Ved P. Leekha, Director, Pudumjee Pulp & Paper Mills Ltd. Thergaon, Chinchwad, Pune- 411 033

On Affidavit

684 Shri Vishwanath R. Agarwal, Veej Darwad Virodhi Sangarsh Samiti, 11/197, Main Road, Ichhalkaranji, Dist - Kolhapur – & Shri Rajgonda Patil, Chairman, Ichhalkaranji Powerloom Weavers Co-op. Association Ltd., 11/197, Main Road, Ichalkaranji, Kolhapur

On Affidavit

685 Shri Shriram Madhukar Sane, B-2/402, Shweta Apartment, Between Jaideo Nagar & Sharada Math, Sinhagad Road, Pune- 411 030

On Affidavit

686 Shri Yogesh S. Kulkarni, Chairman, Gokul Shirgaon Manufacturers Association, P-35 MIDC, Gokul Shirgaon, Kolhapur-416234

On Affidavit

687 Shri Shrikant D. Dudhane, Hon.Secretary, Kolhapur Engg. Association, 1243/46-47, Shivaji Udyamnagar, Kolhapur- 416 008

On Affidavit

688 Shri Balkrishna Sapkal, President, Pimpri Chinchwad Small Industries Association, 1597, Flat 206, Station Road, Opp. Krupp India, Pimpri, Pune- 411 018

On Affidavit

689 Shri Vinayak Rajaram Kuber, Krishna Valley Chamber of Industries & Commerce, Plot No. 33-34-35 (Kupwad Block), MIDC Area, Sangli-416436

On Affidavit

690 Prof. N.D.Patil, Chairman, Maharashtra Rajya Veejgrahak Shetkari Sabha & Bhartiya Shetkari Kamgar Paksh, Kutir, V.V. Rao Marg, Near Mantralaya, Nariman Point-21

On Affidavit

691 Shri Damodar L. Nalla, General Secretary, Solapur Zilla Yantramag Dharak Sangh, No. 23, Basement, Markandeva Shopping Complex, Opp. Old Octroi Naka, Akkalkot Road, Solapur - 6

On Affidavit

692 Shri D.K. Abhyankar, Director General, Mahratta Chamber of Commerce, Industries & Agriculture, P.O.Box No.525, Tilak Road, Pune 411 002

On Affidavit

693 Shri Vijay Grover, IDEA Cellular Ltd. Birla Tata AT & T Ltd. 11/1, Sharada Centre, Karve Road, Erandwane, Pune- 411 004

On Affidavit

694 Shri Raghunath Patil, Chairman, Shriram Sahakari Pani Puravata Sansthan Maryadit, Post Talbid, Tal- Karad, Dist- Satara

On Affidavit


ANNEXURE - I 259

S.No. Name and Address of the Objector Remarks 695 Shri Anandrao Shinde, Chairman, Preeti Sangam Sahakari Pani Puravata

Mandal Ltd., Tal-Karad, Dist-Satara

On Affidavit

696 Shri Narendra Salunkhe, Secretary, Indoli Paradashik Naal Pani Puravata Sansthan, Indoli, Tal- Karad, Dist- Satara

On Affidavit

697 Shri Anandrao Mahadevrao Desai, Shri Bhagyalaxmi Sahakari Pani Puravata Sansthan Maryadit, Post Aaryewadi-Gamyewadi, Tal-Karad, Dist-Satara-415119

On Affidavit

698 Shri Bhanudas Shankar Pawar, Shri Jyotirlinga Sahakari Pani Puravata Sansthan Maryadit, Post- Caregaon, Tal-Karad-415120

On Affidavit

699 Shri Sampatrao Baburao Kolekar, Jyotrilinga Sahakari Upsa Jalsinchan Sansthan Maryadit Post Kiroli, Tal-Koregaon, Satara-

On Affidavit

700 Shri Bhiku Gyandeo Salunkhe, Krushnai Sahakari Pani Puravata Sansthan Maryadit, Chorjavadi, Tal-Karad, Satara-415 109

On Affidavit

701 Shri Vithalrao Jaisingh Thorat, Shri Koteshwar Sahakari Pani Puravata Sansthan Maryadit, Kotri, Tal-Karad, Satara

On Affidavit

702 Shri Shivaji Ramchandra Nikkam, Aakeshwar Sah.Pani Puravata Sansthan Maryadit, Tambhe, Karad, Satara

On Affidavit

703 Shri Shankar Nivruti Nalvade, Yashvantrao Chavan Sah.Pani Puravata Sansthan Maryadit, Post-Hanumanvadi, Tal-Karad, Satara

On Affidavit

704 Shri Sanjay Dagdu Chavan, Sangam Sah.Pani Puravata Sansthan Maryadit, Vanvasmachi, Tal-Karad, Satara

On Affidavit

705 Shri Sanjay Shankar Mulgaonkar, Shri Sajureshwar Sahakari Pani Puravata Sansthan Maryadit, Post-Sajur, Karad, Satara

On Affidavit

706 Shri Badshah Abbas Shaikh, Shriram Sah. Upsa Jalsinchan Sansthan Maryadit, Post- Taalved, Karad, Satara-415109

On Affidavit

707 Shri Sampat Ganpat Surve, Shri Chandrasen Sah.Pani Puravata Maryadit, Post-Vasantgad, Sakurdi, Karad, Satara.

On Affidavit

708 Shri Shivaji Maruti Shinde, Bhiravnath Sah.Pani Puravata, Sanstha, Maryadit, Post-Kase, Karad, Satara

On Affidavit

709 Shri Manohar Bhaskarrao Shinde, Go-Ka-Ksah.Pani Puravata Mandal, Malkapur Karad, Satara

On Affidavit

710 Shri Gulabrao Baburao Kasurde, New Era Development Institute, 95, Kanga Hill, Panchagani-412805, Miraj, Satara

On Affidavit

711 Shri Jayant Nivruti Patil, Shree Om Estate Developers, Venkatesh Nagar, Behind Amarai, Sangli – 416416

On Affidavit

712 Shri Anil M. Tade, President, Rashtriya Grahak Sanghatana, C/o. Atcon, Tilak Chowk, Harabhat Road, Sangli-416416

On Affidavit

713 Shri Mohan Tikaram Borole, A-1, Abhimanshree Hsg.Society, Pune- 411 008

On Affidavit


ANNEXURE - I 260

S.No. Name and Address of the Objector Remarks 714 Shri Kiran M Tarlekar, Chairman, VEETA Powerloom Industries

Sahakari Sangh Maryadit, Mayani Road, P.O. Veeta, Dist- Sangli, Tal- Khanapur- 415311

On Affidavit

715 Shri Gyan Mal Jain, Sr.Vice President, Century Enka Ltd. P.B.No. 17, Bhosari, Pune- 411 026

On Affidavit

716 Shri Girish Sant, Prayas, Pune-411004 On Affidavit 717 Shri Arun Bhosale, Venkateshwara Hatcheries Pvt.Ltd. Venkateshwara

House, S.No.114/A/2, Pune-Sinhagad Road, Pune-411 030 On Affidavit

718 Shri Shankarrao R. Landge, Shetkari Sahakari Sooth Girni Maryadit, Sangole, Solapur, Sangli- 413307

On Affidavit

719 Shri Vinod Kumar Goyal, Sant Gyaneshwar Steels Pvt.Ltd. Gat.No. 1076/77, Golegaon Road, Tal.Khed, Dist-Pune

On Affidavit

720 Shri Mohan Baburao Kulkarni, Asst. General Manager, TATA Motors Ltd., Pimpri, Pune-411 018

On Affidavit

721 Shri Ramesh Parkhi, Chairman, Veej Grahak Sangh, 9996-V, Sadashiv Peth, Pune-30

On Affidavit

722 Shri Shashank Shripad Gadgil, 1789 - Sadashiv Peth, Pune- 30 On Affidavit 723 Shri Atul Bakshi, Secretary, Solapur Manufacturers Association, 129/130

Industrial Estate, Hotgi Road, Solapur-413003 On Affidavit

724 Shri Shivaji Pandurang Raut, 172-B, S.T. Colony, Satara On Affidavit 725 Shri Laxman Ganpat Gunvare, Village Aagote, No.1, Tal-Indapur,

Dist-Pune On Affidavit

726 Shri G. S. Chavan, Managing Director, Sahyadri Sahakari Sakhar Karkhana, Yashwantnagar - 415 115 Tal. Karad, Dist. Satara

On Affidavit

727 Shri Vijay H. Mulgund, Maharashtra Vij Kamgar Mahasangh, 185, Shanivar Peth, Pune

On Affidavit

728 Shri Cyrus S. Ruttonsha, Yojana, Off Deccan College Road, Yerwada, Pune - 411 006

Without Affidavit

729 R.M.Mohite Textiles Ltd. Ambapwadi Phatta, Off. NH - 4, P.B.No.1, Vadgaon, Tal. Hatkanangale, Dist -Kolhapur-416112

Without Affidavit

730 Madhav Gopal Adkar, 298, Budhwar Peth, Pune -2 Without Affidavit

731 Shri Ruturaj Ingale, Kolhapur Indus. Cine Exhibitors Association, C/o Sangam Chitra Mandir, Kolhapur-416001

Without Affidavit

732 Shri K. Balasubramaniam, Flat No.18, Poonam Chambers CHS, Opp.Bhagwat Gita Mandir, Kharalwadi, Pimpri, Pune-18

Without Affidavit

733 Shri Devichand Babutmalji Jain, New 1254, Bhavani Peth, Pune- 411042

Without Affidavit

734 Shri Bhaskarrao Gyanoba Shinde, Freedom Fighter, Malkapur, Karad, Satara

Without Affidavit

735 Shri Ajit Hari Vanarse, Bhartiya Janta Party, Wai Shahar - 339, 'Punnaye', Madli Aali, Wai, Dist-Satara

Without Affidavit


ANNEXURE - I 261

S.No. Name and Address of the Objector Remarks 736 Shri Dhairyashil Murlidhar Taware, Pune Without

Affidavit 737 Shri M.S. Narayana Hindustan Antibiotics Ltd. Pimpri, Pune 411 018.

Without Affidavit

738 Shri Pratap Ganpatrao Hogade, Janata Dal (Secular), 10, C.D.O.Barex, Near Yogakshem, LIC Road, Churchgate, Mumbai-400 020

On Affidavit

739 Brig. V.K.Sharma, President of India Represented by Chief Engineer (Navy) - 26, Assaye Building, Colaba, Mumbai - 400 005

On Affidavit

740 Shri Babanrao B.Chaure & Shri A.S. Deshpande, Maharashtra Chamber of Commerce & Industry, Oricon House, 6th floor, 12 K.Dubhash Marg, Fort, Mumbai-

On Affidavit

741 Shri Shailesh Vasant Palkar, 907, Laxmisunder, Anand Nagar, P.O. Tal. - Poladpur, Raigad-402303

On Affidavit

742 Shri Vijay Kumar Tamhane, Secretary General, The Millowners' Association, Elphinstone Building, 10 - Veer Nariman Road, Mumbai- 400 001

On Affidavit

743 Shri T.S.Sundarsen, Secretary General, The Indian Ferro Alloy Producers' Assocaition, 1B, Haji Moosa 20 - Dr. E. Moses Road, Patrawala Industrial Estate, Mahalaxmi, Mumbai- 11

On Affidavit

744 Shri Ram Mehrotra- Chief Electrical Dist. Engineer, Central Railway, 2nd floor, Parcel Office Building, Electrical Branch, CST, Mumbai

On Affidavit

745 Shri K. Rangrajan, Universal Ferro & Allied Chemicals, Liberty Building, Sir Vithaldas Thackersay Marg, Mumbai - 400 020

On Affidavit

746 Prof. N.D.Patil, Chairman, Maharashtra Rajya Veejgrahak Shetkari Sabha & Bhartiya Shetkari Kamgar Paksh, Kutir, V.V. Rao Marg, Near Mantralaya, Nariman Point-21

On Affidavit

747 Smt. Sujata Soparkar, Honorary General Secretary, Thane Small Scale Industries Association, TSSIA House, Plot No.P-26, Road 16/T, Wagle Indl. Estate, Thane- 400 604 & Kalyan Ambernath Manufacturers Association, Plot No. 7, Commercial Zone, MIDC Phase - I, Dombivali, Dist. Thane – 421 203

On Affidavit

748 Shri Varsha Raut, Secretary, Mumbai Grahak Panchayat, Grahak Bhawan, Sant Dnyaneshwar Park, Behind Cooper hospital, JVPD Scheme, Juhu -Vile Parle, Mumbai- 400 056

On Affidavit

749 Shri S.V. Sodal, Secretary (Irrigation Dept.), GoM, Mantralaya, Mumbai - 400 032

On Affidavit

750 Shri D.D.Tiwari, Sr. Manager (Admin & HR) Deepak Fertilizers & Petrochemicals Corporation Ltd., Plot K-1, MIDC Industrial Area, Taloja, A.V. 410208, Raigad

On Affidavit

751 Shri S.N.Goswami, Member, Tarapur Industrial Manufacturers Association, Recreation Centre, MIDC Tarapur Indl.Area, Dist- Thane – 401506

On Affidavit


ANNEXURE - I 262

S.No. Name and Address of the Objector Remarks 752 Shri K.S.S. Narayanan, Navi Mumbai Action Committee, B/19, Reshma

Co-operative Housing Society, Sector 9A, Vashi, Navi Mumbai- 400 703

On Affidavit

753 Shri Gautam P.Khandelwal, Nagpur Power & Industries Ltd. 20th Floor, Nirmal, Nariman Point, Mumbai-400 021

On Affidavit

754 Smt.Rita Sahu, Dy.Chief Electrical Engg. Western Railway, Office of Chief Electrical Engineer, 5th floor, Churchgate Station Builidng, Churchgate, Mumbai-20

On Affidavit

755 Shir Vivek Nair, President, Hotel & Restaurant Association (Western India), 4, Candy House, Mandlik Road, Mumbai - 400 001

On Affidavit

756 Shri Chandulal Sumeria, General Secretary, Halari Powerloom Owners & Weavers Association, 1280, Shri Complex, 2nd floor, Agra Road, Narpoli, Bhiwandi, Thane

On Affidavit

757 Shri S.N. Patankar, President, Vrikshwallee, 1, Keshav Apartment, Datta Mandir Road, Chandani,Thane-400 601

On Affidavit

758 Shri Aqeel Akhtar Ansari, President, Bhiwandi Powerloom Owners & Weavers Welfare Trust, 167, Shandar Textile Market, Opp. Mamta Hospital, Agra Road, Bhiwandi, Thane-421302

On Affidavit

759 Shri Ravi K. Anand, Secretary, Electricity Consumers Association, 103, Hiranandani Indl. Estate, Kanjur Marg, Mumbai-78

On Affidavit

760 Shri Ashok Khinvasara, Director (Corporate Dev.), ISPAT Industries Ltd., Nirmal, 7th floor, Nariman Point, Mumbai - 400 021

On Affidavit

761 Shri S.B.Bauskar-Tech.Director, Maharashtra State Co-operative Textile Federation Ltd., Vakil House, 2nd floor, 18, Shri Shivsagar Ramgulam Marg, Ballard Estate, Mumbai - 1

On Affidavit

762 Shri P.B.Thatte, Director, Saf Yeast Co.Pvt.Ltd. 419, Swastik Chambers, Chembur, Mumbai - 400 071

On Affidavit

763 Shri Ashvin V Treasurer, Indian Inhabitant, B - 2/401, Harsidh Park, Pawar Nagar, Thane-400 601

On Affidavit

764 Shri A.G.Sontakke, President, Murbad Manufacturers Association, M/s. Dinesh Plastics Works, Plot No. F/53, MIDC, Murbad-421 401

On Affidavit

765 Shri Krihna Bhoyar, President, Maharashtra State Apartice Kruti Sameeti, E - 6, MSEB Colony, Bhingare, Panvel, Raigad-410206

On Affidavit

766 Shri Shakeel A. Ansari, Secretary, Maharashtra Electricity Consumers Association, 27, Pauls Compound, Opp. Asbibi, Kalyan Road, Bhiwandi-421 302

On Affidavit

767 Shri Ashok Kumar, Company Secretary, Maharashtra Elektrosmelt Ltd. 10-Nirmal, Nariman Point, Mumbai - 400 021

On Affidavit

768 Shri Sadashiv B. Desai, Chairman, Shiroli Manufacturers Association, P-12, Shamak Building, MIDC, Shiroli, Kolhapur- 416 122

On Affidavit


ANNEXURE - I 263

S.No. Name and Address of the Objector Remarks 769 Shri Champshi M. Shah, New Bombay Ispat Udyog P. Ltd. 1, Sundaram,

Satyam Shivam Sundarm Complex, M.G. Road, Ghatkoper (E), Mumbai –400077

On Affidavit

770 Shri Ramesh S. Chavan, President, Kudal MIDC Industries Association, B-35, MIDC, Kudal, Sindhudurg – 416 550

On Affidavit

771 Shri Girish Sant, Prayas, Pune-411004 On Affidavit 772 Shri B.R.Khedekar, Akhil Bhartiya Grahak Panchayat, 43/90,

Navasahyadri Society, Pune- 411 052 On Affidavit

773 Consumer

Without Affidavit

774 Shri Arun Sharaf, Dombivli Kalyan Gharmalak Seva Sangh, 7, Shramsaphalya, Gupte Cross Road, Dombivli (West) - 421 202

Without Affidavit

775 Shri S.M.Trehan, Chairman, Confederation of Indian Industry, (Western Region), 105 - Kakad Chambers, 132 - Dr. Annie Besant Road, Worli, Mumbai - 400 018

Without Affidavit

776 Shri Vinod Shah, Convener, Captive Power Producers Association, CPPA Secretariat, Mukund Limited, Belapur Road, Thane – 65

Without Affidavit

777 Dr. S.L.Patil, Secretary General, Thane Belapur Ind. Association, Plot No. P-14, MIDC, Rabale Village, P.O.Ghansoli, Navi Mumbai- 400701

Without Affidavit

778 Tata Power Company Ltd, Bombay House, 24 Homi Mody Street, Mumbai - 400 001

Without Affidavit

779 Shri S.S.Nayak, Chairman, Thane Manufacturers Association, TMA House, Plot No.6, Main Road, Wagle Inds..Estate, Thane- 400 604

Without Affidavit

780 Shri M.G. Varade, 505/A-Wing, Breeze, 3rd Cross Lane, Lokhandwala Complex, Andheri (W), Mumbai- 400 058 & Shri A.R.Bapat, C-73, Lokmanya C.H.S., Veer Savarkar Road, Thane (W) -400 602

Without Affidavit

781 Shri G.V.Patil, A-2/1,Chitanya Soc. Ganeshnagar, Manpada Road, Dombivali (East), Thane-421201

Without Affidavit

782 Raigad District Grahak Takrar Nivaran Samiti- Hanuman Aali, Pen, Raigad-402 107

Without Affidavit

783 Shri M.G. Kimmatkar, Expert Member, Vidarbha Statutory Development Board, B-23/1, South Ambazari Road, Nagpur-22

Without Affidavit

784 Shri Mohandas Naidu, LokMorcha Nagpur, A.K. Gopalan Bhavan, Shanivari, Cotton Market, Nagpur – 440 017

Without Affidavit

785 Shri S.R. Paranjape, D2-203, Gomati Society, Lokgram, Kalyan (E) – 421 306

Without Affidavit

786 Shri A.K.Sharma, The Malegaon Co-operative Spinning Mills Ltd. P.B.No.29, Malegaon-423 203

Without Affidavit

787 Shri Anant Kulkarni, Member, Pimpri Chinchwad Small Ind. Ass.- Amit Engineers, 30/13, D-II, M.I.D.C., Pune-411019

Without Affidavit

788 Shri Pradyumn Kaul, B-3, Ploughshare Apmt; Sitladevi Temple Road, Mahim, Mumbai – 400 016

Without Affidavit


ANNEXURE - I 264

S.No. Name and Address of the Objector Remarks 789 Shri Purushottam R. Patil, Member, Gram Panchayat, Kusur, Tal.

Vaibhavwadi, Dist. Sindhudurg Without Affidavit

790 Shri Subhash G. Vairagade, Shivsena Office Gate No. 2, Thermal Power Board Colony, MSEB Koradi, Tal. Kamathi, Dist. Nagpur – 441 111

Without Affidavit

791 Shri Vasantrao L. Mahajan, All India Banana Growers Association of India, Chinawal, Tal. Raver, Dist. Jalgaon – 425 505

Without Affidavit

792 Shri Shankar B. Shinde, Krushi Kanya Sahkari Pani Purvatha Yojana Maryadit – Nanduri Dumala, Tal. Sangamner, Dist. Ahmednagar

Without Affidavit

case no.2 of 2003 - infraline

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