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BEFORE THE CHHATISGARHSTATE ELECTRICITY REGULATORY
COMMISSION, RAIPUR
Petition For Revision of Miscellaneous
& General Charges
Submitted to
Chhattisgarh State Electricity Regulatory Commission
November 2014
Chhattisgarh State Power Distribution Company Limited
O/o Executive Director (Commercial),
Vidyut Sewa Bhawan (3rd Floor),
Dangania, Raipur – 492013
CSPDCL
i
CHHATTISGARH STATE POWER DISTRIBUTION COMPANY LIMITED, RAIPUR
(A Government of Chhattisgarh Undertaking)
Regd. Off. : Vidyut Sewa Bhawan, 3rd floor Dangania, Raipur – 492 013
Tel: 0771-2574441, Fax: 0771-2574442, Email: cecomcspdcl@rediffmail.com
Ref: _________________________
Dated: __ November 2014
To,
The Secretary,
Chhattisgarh State Electricity Regulatory Commission,
Irrigation Colony, Shanti Nagar,
Raipur, Chhattisgarh - 492 001
Dear Sir,
Subject:
Submission of Petition for the Approval of Schedule of revised Miscellaneous
& General Charges to be levied by CSPDCL
As per the provisions under section 43, 45 & 46 of Electricity Act, 2003 and various relevant
provisions under Chhattisgarh State Electricity Supply Code, 2011 including amendment
called as “Chhattisgarh State Electricity Supply Code (First Amendment) 2013” which has
come into effect from 1st January 2014 to govern distribution and supply of electricity th
Chhattisgarh State Distribution Company Limited (CSPDCL) proposes revision in schedule of
Miscellaneous & General Charges for approval of the Hon’ble Commission.
The following documents are enclosed here for the kind perusal and approval by the Hon’ble
Commission:
1. Formal Petition and with Affidavit verifying the petition.
2. Petition Fee of Rs_________ (Rupees _________ only) in terms of Cheque
no._________ Dated___________ drawn on_________.
We request the Hon’ble Commission to kindly admit the aforesaid petition and proceed
further in the matter at the earliest. We would also request the Hon’ble Commission to kindly
CSPDCL
ii
provide us an opportunity of personal hearing to further clarify/explain our submissions
under the enclosed petition.
Thanking You,
Yours Faithfully,
For Chhattisgarh State Power Distribution Company Limited, Raipur
(Authorized Signatory)
Executive Director (Commercial) -CSPDCL
Enclosed: As above
CSPDCL
iii
CHHATTISGARH STATE ELECTRICITY REGULATORY COMMISSION, RAIPUR
Filing No. ______________
Case No. ______________
IN THE MATTER OF
SUBMISSION OF PETITION FOR THE APPROVAL OF SHEDULE OF REVISED MISCELLANEOUS
& GENERAL CHARGES TO BE LEVIED BY CSPDCL
PETITIONER
CHHATTISGARH STATE POWER DISTRIBUTION COMPANY LIMITED, RAIPUR (HEREINAFTER
REFERRED TO AS ‘CSPDCL’ OR ‘THE PETITIONER’);
THE ‘PETITIONER’ RESPECTFULLY SUBMITS THAT:
1. The Petitioner is a distribution licensee for wheeling and retail supply of electricity in
the areas as notified by the Government of Chhattisgarh (GoCG) under the CSEB
Transfer Scheme Rules, 2010.
2. As per the provisions under section 43, 45 & 46 of Electricity Act 2003 and various
relevent provisions under Chhattisgarh State Electricity Supply Code, 2011 including
amendments as issued by the Hon’ble Commission; the Chhattisgarh State
Distribution Company Limited proposes redetermination of the Schedule of
Miscellaneous & General Charges for approval by the Hon’ble Commission.
3. The Petitioner CSPDCL is accordingly filing this Petition for Approval and Revision of
Miscellaneous & General Charges.
CSPDCL
iv
PRAYER TO THE HON’BLE COMMISSION:
The Petitioner respectfully prays to the Commission:
a. Admit the petition of Chhattisgarh State Power Distribution Company Limited (CSPDCL),
Raipur.
b. To condone any inadvertent omissions/ errors/ shortcomings and permit the Petitioner
to add/ change/ modify/ alter this filing and make further submissions as may be required
at a future date.
c. To allow further submissions, addition and alteration to this Petition as may be
necessitating from time to time.
d. Treat the filing as complete in view of substantial compliance as also the specific requests
for waivers with justification placed on record;
e. And pass such other and further orders as are deemed fit and proper in the facts and
circumstances of the case.
Date: ___ November 2014
Petitioner
Executive Director (Commercial)
CSPDCL, Raipur
CSPDCL
v
Table of Contents
1.
BACKGROUND ..................................................................................................................................... 7
REGULATORY PROVISIONS ............................................................................................................................... 7
2.
PROPOSAL FOR MISCELLANEOUS & GENERAL CHARGES ................................................. 9
3.
METER HIRE CHARGES ................................................................................................................... 9
Detailed Methodology ................................................................................................................................... 9
Assumptions .................................................................................................................................................. 9
Detailed Calculation ................................................................................................................................... 10
Proposed Charges ....................................................................................................................................... 10
4.
OTHER WORK ORIENTED CHARGES......................................................................................... 10
Detailed Methodology ................................................................................................................................. 10
Assumptions ................................................................................................................................................ 11
Detailed Calculation ................................................................................................................................... 12
Proposed Charges ....................................................................................................................................... 13
5.
TESTING CHARGES FOR VARIOUS EQUIPMENT ................................................................... 14
Detailed Methodology ................................................................................................................................. 14
Assumptions ................................................................................................................................................ 14
Detailed Calculation ................................................................................................................................... 16
Proposed Changes ...................................................................................................................................... 16
6.
SERVICE CONNECTION CHARGES ............................................................................................. 19
Detailed Methodology ................................................................................................................................. 19
Detailed Calculation ................................................................................................................................... 19
Proposed Charges ....................................................................................................................................... 19
7.
APPLICATION PROCESSING FEE AND SPECIAL METER READING ................................. 20
Detailed Methodology Application processing ........................................................................................... 20
Detailed Methodology Special Meter Reading ........................................................................................... 20
Proposed Charges ....................................................................................................................................... 21
8.
CHARGES FOR STANDBY FEEDER MAINTENANCE .............................................................. 21
Detailed Methodology ................................................................................................................................. 22
Detailed Calculation ................................................................................................................................... 22
Proposed Charges ....................................................................................................................................... 22
9.
CHARGES FOR MAINTENANCE OF STREET LIGHT .............................................................. 23
Detailed Methodology ................................................................................................................................. 23
Detailed Calculation ................................................................................................................................... 23
Proposed Charges ....................................................................................................................................... 23
10.
SUMMARY OF PROPOSED CHARGES ......................................................................................... 24
11.
SYSTEM STRENGTHNING CHARGES ......................................................................................... 28
12.
SUPPLY AFFORDING CHARGES ................................................................................................... 31
13.
PRAYER ............................................................................................................................................... 34
CSPDCL
vi
PETITION FOR DETERMINATION OF MISCELLANEOUS & GENERAL CHARGES
1.
BACKGROUND
1.1
As per the provisions under section 43, 45 & 46 of Electricity Act 2003 and various
relent provisions under Chhattisgarh State Electricity Supply Code, 2011 including
amendments as issued by the Hon’ble Commission; the Chhattisgarh State Power
Distribution Company Limited proposes redetermination of the Miscellaneous &
General Charges by the Hon’ble Commission.
1.2
These charges are proposed in lieu of the other than obligators services to be provided
by CSPDCL to the Consumer. Also, rental / cost recovery on equipment’s provided and
maintained by CSPDCL for exclusive use of consumers.
1.3
The existing Miscellaneous & General Charges, as levied by the CSPDCL, are as
approved under the order dated 10.08.2007 by Hon’ble Commission. These charges
were determined 7 years back, since then due to large variation in material, transport
and manpower costs the revision has become inevitable.
Regulatory Provisions
1.4
Following are the provisions under Electricity Act 2003 enabling licensee to recover
the charges from the consumers for various services other than power supply.
a) Section 43 (2) states that “It shall be the duty of every distribution licensee to
provide, if required electric plant or electric line for giving electric supply to the
premises specified in sub-section (1): Provided that no person shall be entitled
to demand, or to continue to receive, from a licensee a supply of electricity for
any premises having a separate supply unless he has agreed with the licensee
to pay to him such price as determined by the Appropriate Commission.”
b) Section 45 (3b) states that “The charges for electricity supplied by a distribution
licensee may include: (b) a rent or other charges in respect of any electric meter
or electrical plant provided by the distribution licensee.”
CSPDCL
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PETITION FOR DETERMINATION OF MISCELLANEOUS & GENERAL CHARGES
c) Section 46 “(Power to recover expenditure): The State Commission may, by
regulations, authorise a distribution licensee to charge from a person requiring
a supply of electricity in pursuance of section 43 any expenses reasonably
incurred in providing any electric line or electrical plant used for the purpose of
giving that supply.”
1.5
Sections under chapter 4 of Chhattisgarh State Electricity Supply Code, 2011 and other
relevant sections under the first amendment in supply code called as “Chhattisgarh
State Electricity Supply Code (First Amendment) 2013” which has come into effect
from 1st January 2014.
1.6
The various charges are estimated by taking the actual cost of the material and the
cost of labour & manpower involved for each of the work to comply with the
provisions under various regulations and Electricity Act 2003. The cost of various
equipment’s and apparatus are taken as per the latest standard schedule of rates
adopted by the CSPDCL in FY 2014-15.
CSPDCL
Page 8
PETITION FOR DETERMINATION OF MISCELLANEOUS & GENERAL CHARGES
2.
PROPOSAL FOR MISCELLANEOUS & GENERAL CHARGES
The CSPDCL has proposed various charges taking into consideration the actual costs
of the material and the cost of labour and time required for completion of each task.
The cost of various equipment and apparatus are taken as per the latest standard
schedule of rates adopted for FY 2014-15, and the cost of manpower is as per the
prevailing actual cost of manpower engaged.
3.
METER HIRE CHARGES
Detailed Methodology
3.1
As per the Clause 8.7 of Chhattisgarh State Electricity Supply Code, 2011, the licensee
has to supply the meters and associated equipment and maintain the metering system
in proper working condition. The consumer, in turn, has to pay monthly hire charges
to the utility (CSPDCL) as approved by the Commission. Relevant Clause is stated
below:
“8.7 The licensee shall install the meter and metering equipments, to consumer’s
premises at the time of serving new connection or at any other time as required. The
licensee shall keep the meter in proper working condition and the consumer shall pay
the monthly rent, if any, for the meter and metering equipments at the rate approved
by the Commission as per miscellaneous charges from time to time. If the licensee fails
to keep the meter or metering equipment in proper working condition, the consumer
shall not be liable to pay the meter rent for the period the meter remains defective.”
Assumptions
3.2
In the current proposal, the average serviceable life of electronic meter is considered
to be approximately 15 years (as approved in order dated 10th August 2007 petition
number: 40/2006). The cost of additional expenditure incurred towards replacement
of defective meters per year is also added at permissible rate of 2.5% to the capital
investment required to maintain the normal and correct operation of meters after the
guarantee period of 5.5 years for LT meters (on the basis of latest supply orders of the
vendors as well as approval by the Hon’ble Commission in its order dated 10th August
2007).
CSPDCL
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PETITION FOR DETERMINATION OF MISCELLANEOUS & GENERAL CHARGES
3.3
The installed meters require regular testing which is a common feature in the
operations of the licensee. Therefore, the cost of testing LT consumer meters, at least
3 test in its serviceable life has been taken in the current proposal.
3.4
For arriving at the cost of meter and metering equipment, the actual cost as per the
latest purchase order or the schedule of rates of the CSPDCL for the FY 2014-15 has
been considered for the LT meters. In addition to the cost of meter for LT, cost of
additional equipment (i.e. modem cost, and CT & PT) to be borne by CSPDCL while
providing meter has also been considered. Further, testing charges has been
considered based on the type of meter. The detail calculations of testing charges have
been shown in the subsequent sections.
Detailed Calculation
3.5
The detailed calculation has been provided in the Annexure – 1.
Proposed Charges
3.6
The proposed charges shall be applicable to all consumers.
3.7
The proposed Meter Rent (rounded up to nearest multiple of 5) is summarized below:
Table 1: Meter Hire Charges
Meter Hire charges
Proposed
% Increase/Decrease
10
20
100%
10-40 Amp meters
25
50
100%
20-100 Amp meters
50
50
0%
Three Phase LT CT meter
70
120
71%
Single phase meters
Existing
Three Phase LT meters
4.
OTHER WORK ORIENTED CHARGES
Detailed Methodology
4.1
The other work oriented charges cover’s the following services:
I. Shifting of meter/ meter board within the same premises
II. Replacement of fuse / meter glass / meter reading cards
CSPDCL
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PETITION FOR DETERMINATION OF MISCELLANEOUS & GENERAL CHARGES
III. Reconnection after disconnection or disconnection on consumer’s request.
IV. Resealing of meters, MD indicators and instruments of the Board in the
consumer's premises, if seal is found accidently broken
V. Re-rating of installations at the request of the consumer
VI. Testing of Installations
The charges have been computed based on the number of jobs executable in a day along with
the proportional cost of manpower and transport involved in undertaking such activity.
Assumptions
4.2
The above services are work-oriented, and involve services of technical staff employed
by CSPDCL. It appears reasonable and justified that these charges be calculated on the
basis of the man hours of staff required for carrying out the job (Similar methodology
used by the Hon’ble Commission in its order dated 10th August 2007). Therefore,
average emoluments for different technical staff have been considered based on
existing pay scale. On the basis of the staff involved in the job, emoluments of staff
and maximum number of jobs can be undertaken per day the charges have been
computed.
4.3
It may kindly be noted that for replacement of fuses and meter cards, services of one
helper is required. Accordingly these charges have been proposed on the basis of the
number of jobs carried out during working hours per day in a month of 24 days, and
the salary/wages of the persons deployed for the services. The assumption on number
of jobs which can be performed in a day with the proposed manpower has been
tabulated below:
Particulars
Other work oriented jobs
Shifting of meter/meter board in the same premises. ( at the
consumer's request)
Re-sealing of cut outs provided on meter board in the consumer's
premises.
Replacement of fuses/meter reading card:
Replacing consumer's cut out fuses (LT)
Replacement of missing meter reading card (LT)
CSPDCL
Number
of jobs
14
35
20
20
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PETITION FOR DETERMINATION OF MISCELLANEOUS & GENERAL CHARGES
4.4
Similarly for disconnection and reconnection of supply on consumer’s request
required up to 25 HP/19 kW, the services of lineman and helpers are required. The
charges have accordingly been proposed on the basis of the number of jobs which can
be carried out in a day and the wages/salary of employed manpower. For the
disconnection/reconnection of power supply above 25 HP/19 kW in addition to
lineman and helper, charges for involvement of a Junior Engineer is also required to
be included.
4.5
Similarly, for disconnection and reconnection of HT Connection upto 5 MVA or above,
the services of E.E (O&M) of the area, E.E (Testing), concerned A.E. and other support
staff has been considered. Therefore, these charges have been computed taking into
account their wages/salary and efficient number of jobs possible to be undertake in a
day. Further, instead of services of Driver, services of hired vehicle (jeep) have been
considered. The assumptions on number of jobs has been tabulated below:
4.6
Particulars
Number of jobs
Single phase LT connection
20
3-Phase LT connection upto 25 HP/19 KW
10
3-Phase LT connection above 25 HP/19 KW
6
HT Connection upto 5 MVA
3
HT Connection above 5 MVA
2
The services offered to single and three-phase consumer under “re-rating/checking of
installation/equipment done at the request of the consumer” has been computed
taking into consideration one Junior Engineer and Lineman. The number of jobs may
be undertaken per days for single phase consumer has been considered to be 8 and 4
for three phase consumers. Accordingly the cost for rendering the services has been
computed taking into account the proposed manpower and number of jobs
executable in a day as per the above assumption.
4.7
Service under “Testing as subsequent testing of installation, or testing of an extension
to the existing installation, or if the wiring contractor or his representative fails to be
present during initial testing of a new installation or subsequent testing”, CSPDCL has
considered the cost of Junior Engineer, Lineman and Helper and taken the assumption
of 8 jobs executable in a day for the purpose of calculating charges.
Detailed Calculation
4.8
The detailed calculation has been provided in the Annexure – 2:
CSPDCL
Page 12
PETITION FOR DETERMINATION OF MISCELLANEOUS & GENERAL CHARGES
Proposed Charges
4.9
The proposed other charges (rounded off to nearest multiple of 5) is summarized
below:
Table 2: Other Work Oriented Charges
S. No
1
2
Particulars
Existing
Proposed
% Increase
70
170
143%
25
70
180%
25
55
120%
-
55
-
Single phase LT connection
60
120
100%
3-Phase LT connection up to 25 HP/19 KW
150
240
60%
3-Phase LT connection above 25 HP/19 KW
500
665
33%
HT Connection up to 5 MVA
1750
2860
63%
HT Connection above 5 MVA
2500
6150
146%
Single phase connection
150
370
147%
Three phase connection
300
730
143%
200
500
150%
Shifting of meter/meter board in the same
premises
Re-sealing of cut outs of the meter board in the
consumer’s premises, if seal is found broken
Replacement of fuses/meter reading cards
3
Replacing consumer's cut out fuses (LT)
Replacement of missing meter reading card
(LT)
Either Disconnection or Reconnections on
consumer’s request:
4
Re-rating / checking of installation / equipment
were done at the request of the consumer
5
6
Testing of installations:
Testing as subsequent testing of installation, or
testing of an extension to the existing
installation, or if the wiring contractor or his
representative fails to be present during initial
testing of a new installation or subsequent
testing
CSPDCL
Page 13
PETITION FOR DETERMINATION OF MISCELLANEOUS & GENERAL CHARGES
4.10
Other work oriented charges are basically the services which are provided by CSPDCL’s
technical staff along with the required labour. As it can be seen from the above, there
is a considerable increase in all the charges viz-a-viz the existing charges which is
mainly attributable to increase in employee cost.
5.
TESTING CHARGES FOR VARIOUS EQUIPMENT
Detailed Methodology
5.1
CSPDCL is currently recovering the testing charges of various equipment including
meters based on the charges approved by the Hon’ble Commission. To revise these
existing charges of various equipment’s, following two components have been
revisited as considerd by Hon’ble Commission in the order dated 10th August 2007:
(1)
Wages of staff deployed to carry out the testing
(2)
Cost of proportionate utilization of testing instruments for carrying out the
tests.
Assumptions
5.2
Employee costs have been derived considering the number of technical personals
involved in testing activity and the number of possible jobs may be carried out during
the day. The number of days in a month has been considered to be 24 days for
computing the employee cost.
5.3
The replacement/utilization costs of testing equipment have been worked out on
activity basis considering serviceable life of 15 years and the number of activities to
be conducted under a particular test.
5.4
The Testing Charges proposed for conducting individual tests have been computed as
the sum of utilization cost of equipment and the cost of employees involved for a
particular test divided by number of jobs possible in a day. The aforesaid proposed
charges for testing are in respect of tests carried out in the laboratory. Different
equipment used in testing have been tabulated below:
Testing charges
Single phase meter
CSPDCL
Equipment Required
1. ERSM Acc CL 0.1
2. Phantom Loading Kit (Voltage current
source)
Page 14
PETITION FOR DETERMINATION OF MISCELLANEOUS & GENERAL CHARGES
Testing charges
3Ph. 4 wire meter, without CT
LT CT (each)
3 Ph, 4 Wire meter, with CTs
Tri-Vector meter
33 KV or 11 KV Metering Equipment
(Combined CT-PT Unit)
220 KV or 132 KV Metering Equipment (CT
or PT Set)
O/C, E/F Relay per element testing
BDV
HT CT/PT (Ratio, polarity, IR) each unit
ABT meter
Transformer Testing (Power Transformer),
Routine test at site, the site being located
at the H.Q of E.E (STM)
Transformer Testing (Power Transformer),
Routine test at site, the site being located
away from H.Q of E.E (STM)
Substation Testing (33/11 KV)
(Commissioning charges)
CSPDCL
Equipment Required
1. ERSM Acc CL 0.1
2. Phantom Loading Kit (Voltage current
source)
1. Primary Injection Kit
2. Multimeter
1. ERSM Acc CL 0.05
2. Phantom Loading Kit (Voltage current
source)
1. ERSM Acc CL 0.05
2. Phantom Loading Kit (Voltage current
source)
1. Complete CT/PT testing kit
2. Multimeter
3. Megger
1. Complete CT/PT testing kit
2. Multimeter
3. Megger
Multi-Purpose loading Kit
Oil Testing Kit (BDV)
1. Complete CT/PT testing kit
2. Multimeter
3. Megger
1. ERSM Acc CL 0.05
2. Phantom Loading Kit (Voltage current
source)
1. Power Analyzer
2. Phantom Loading
3. Megger
4. Oil testing kit
5. Earth Megger
6. Multi-purpose testing Kit
1. Power Analyzer
2. Phantom Loading
3. Megger
4. Oil testing kit
5. Earth Megger
6. Multi-purpose testing Kit
1. Power Analyzer
2. Phantom Loading
3. Megger
4. Oil testing kit
5. Earth Megger
6. Multi-purpose testing Kit
Page 15
PETITION FOR DETERMINATION OF MISCELLANEOUS & GENERAL CHARGES
5.5
The possible number of jobs in a day for different tests has also been provided below:
Testing charges
Single phase meter
3Ph. 4 wire meter, without CT
LT CT (each)
Tri-Vector meter
33 KV or 11 KV Metering Equipment (Combined CT-PT
Unit)
220 KV or 132 KV Metering Equipment (CT or PT Set)
O/C, E/F Relay per element testing
BDV
HT CT/PT (Ratio, polarity, IR) each unit
ABT meter
5.6
Possible Number of jobs in a
day
15
15
15
3
2
2
7
14
6
1
In case of testing of “3 Ph, 4 wire meter, with CTs”, CSPDCL has considered the sum of
individual 3 Ph, 4 wire meter test and 3 number of LT CT tests while calculating the
charges, which is similar to what Hon’ble Commission has considered in its order dated
10th August 2007.
Detailed Calculation
5.7
The calculation of testing charges has been based on the above assumptions
considering the cost of employees and equipment with different number of possible
jobs as discussed above. The breakup of the same with calculations has been provided
in the Annexure – 3.
Proposed Changes
5.8
CSPDCL has proposed some changes in the existing nomenclature. CSPDCL requests
Hon’ble Commission to approve the changes:
a)
CSPDCL has proposed to change the nomenclature from “33/11 KV metering
equipment” to “33 KV or 11 KV Metering Equipment (Combined CT-PT Unit)”.
The change has been proposed as the metering equipment also contains both
CT and PT units and thus it would require simultaneous testing of both these
units.
b)
CSPDCL has proposed to change the nomenclature from “132/220 KV
metering equipment” to “220 KV or 132 KV Metering Equipment (CT or PT
CSPDCL
Page 16
PETITION FOR DETERMINATION OF MISCELLANEOUS & GENERAL CHARGES
Set)”. The changes have been proposed as the metering equipment consists of
CT and PT unit separately and CSPDCL has considered testing of one unit while
computing the charges.
c)
CSPDCL has also proposed to change the nomenclature from “HT CT (Ratio,
Polarity, IR, BDV) each unit” to “HT CT/PT (Ratio, Polarity, IR) each unit”. The
change has been proposed as BDV testing charges has been proposed
separately and CSPDCL has proposed to charge the consumer separately in
case BDV testing is requested.
5.9
Testing charges are services which are provided by CSPDCL’s technical staff along with
the labour required. As it can be seen from the computation provided in the Annexure
-3, all the charges have increased with respect to the existing charges on the account
of increase in employee cost. The increase in employee cost has been on the account
of impact of pay revision in recent years. Also, there is very little impact of equipment
cost as it is spread for 15 years. Therefore, CSPDCL would like to request Hon’ble
Commission to consider the proposal.
5.10
By adopting the aforesaid basis, the existing as well as proposed testing charges
(rounded off to nearest multiple of 5) are indicated here as under:
Table 3: Testing Charges
Particulars (Rs.)
Existing
Proposed
% increase
Single phase meter
130
360
177%
3Ph. 4 wire meter, without CT
200
360
80%
LT CT (each)
170
350
106%
3Ph. 4 wire meter, with CT's
880
1400
60%
Tri-Vector meter
33 KV or 11 KV Metering Equipment (Combined CTPT Unit)
220 KV or 132 KV Metering Equipment (CT or PT Set)
1200
1840
53%
2680
3510
31%
3750
4980
33%
O/C, E/F Relay per element testing
400
770
93%
BDV
320
370
16%
HT CT/PT (Ratio, polarity, IR) each unit
1000
1170
17%
CSPDCL
Page 17
PETITION FOR DETERMINATION OF MISCELLANEOUS & GENERAL CHARGES
Particulars (Rs.)
Transformer Testing (Power Transformer), Routine
test at site, the site being located at the H.Q of E.E
(STM)
Transformer Testing (Power Transformer), Routine
test at site, the site being located away from H.Q of
E.E (STM)
Substation Testing (33/11 KV) (Commissioning
charges)
5.11
Existing
Proposed
% increase
-
4,900
-
-
4,900
Transport
charges for
the work on
actual basis.
-
-
12,640
-
The below charges are calculated on a lower side as more time and resource is
required to be deployed in case testing is carried out in the premises of the consumers,
which involves cost of transportation and constrain on existing resources. CSPDCL has
taken minimum cost of one helper and one TA Gr-1 for carrying-out such activity on
per day basis. The proposed charges are given below:
Table 4: Equipment Testing Charges
Particulars
Existing
Equipment tested at site, Rs. 800/- per day or part thereof
the site being located at
and the transport charges for
the Head Quarter of the
the work on actual basis.
MT Division.
Equipment’s tested at
Rs. 800/- per day or part thereof
site, the site being
and transport charges along with
located away from H.Q of TA & DA admissible to the staff
E.E. (MT)
involved. The counting of days
shall be from the starting of
journey till the return from the
journey for the work on actual
basis.
CSPDCL
Proposed
Rs. 2800/- per day or part
thereof and the transport
charges for the work on
actual basis.
Rs. 2800/- per day or part
thereof and the transport
charges for the work on
actual basis.
Page 18
PETITION FOR DETERMINATION OF MISCELLANEOUS & GENERAL CHARGES
6.
SERVICE CONNECTION CHARGES
Detailed Methodology
6.1
Service connection charges are payable by the consumers for connecting the premises
where connection is required from the nearest distribution mains. As per the
Chhattisgarh State Electricity Supply Code, 2011 section 4.2 to 4.6, on
request/application by owner or occupier of any premises located in the licensee’s
area of supply, has to provide supply to such premise. The cost of providing such
supply is to be recovered from the consumer based on actual material required for
proving the supply and also a service connection charges related to the labour and
supervision charges cost.
6.2
LT consumers are permitted to lay service lines through licensed electrical contractors
with material procured by them. CSPDCL recovers 15% supervision charges on the
standard cost of estimates and these charges are recovered on the total costs, of
material and labour.
6.3
Therefore, CSPDCL has revised the supervision charges for service connection based
on the latest cost of material from SOR and labour cost approved for the FY 2014-15.
Detailed Calculation
6.4
The detailed calculation has been provided in the Annexure – 4:
Proposed Charges
6.5
The details of service connection charges based on the revised cost of material and
labour is summarized below:
Table 5: Service Connection Charges
Particulars (Rs )
Single Phase
Three phase (upto 5 KW)
Connected load upto 25 HP
Connected load above 25 HP
CSPDCL
Existing
200
Proposed
570
% Change
185%
365
510
1170
1180
221%
131%
Page 19
PETITION FOR DETERMINATION OF MISCELLANEOUS & GENERAL CHARGES
6.6
As discussed above the cost of providing such service is based on the material used
for the purpose of providing service connection to the consumer. The cost of such
materials has increased compared to the year in which the existing charges were
proposed which can be seen in below table. The complete break-up of existing cost
has also been provided in the Annexure-4 along with the calculation for due
consideration.
Table 6: Cost Comparison
Estimated Cost Including Labour Cost
(Rs.)
Single Phase
Previous
Cost
1321
Existing Cost
% Change
3821
189%
Three phase (upto 5 KW)
Connected load upto 25 HP
2419
7811
223%
Connected load above 25 HP
3399
7841
131%
7.
APPLICATION PROCESSING FEE AND SPECIAL METER READING
Detailed Methodology Application processing
7.1
Once a prospective consumer submits an application for electric connection for his
installation, various procedural activities/paperwork is required to be done by
CSPDCL. Further, survey of consumer premises is done by the line staff (in case of LT
consumer) and engineer (In case of HT/EHT consumers). These works involve much
efforts & valuable time at various levels. Thereafter if aspirant consumer doesn’t avail
connection due to any reason, the utility efforts are turned to waste.
7.2
As these charges are levied on the account of technical staff being involved in these
activities, CSPDCL has proposed to increase the rates based on the average increase
in actual employee cost from time of fixing existing charges.
Detailed Methodology Special Meter Reading
CSPDCL
Page 20
PETITION FOR DETERMINATION OF MISCELLANEOUS & GENERAL CHARGES
7.3
Once a consumer submits an application for meter reading, CSPDCL will require its line
staff to undertake this activity under the supervision of executive staff. These works
involve much efforts & valuable time at various levels. CSPDCL has proposed to
increase the rates based on the average increase in actual employee cost from time
of fixing existing charges.
Proposed Charges
7.4
Application processing fee and special meter reading is a service which is provided by
CSPDCL’s administrative and technical staff, where technical staff has to conduct a
survey of the premises or visit their premises for meter reading which requires
additional efforts. All these charges have increased with respect to the existing
charges on the account of increase in employee cost, which has been considered while
computing such charges.
7.5
The proposed charges is summarized below:
Table 7: Application Processing Fee and Special Meter Reading
Particular (Rs.)
Existing
Proposed
% impact
Application Processing Fee
LT Industrial consumer
LT consumer (Other than Industrial
and BPL consumer)
HT Consumers
1,000
2,280
130%
200
455
130%
5,000
11,410
130%
25
55
120%
250
L.T Rs 25
H.T Rs 250
570
L.T Rs 55
H.T Rs 570
130%
Special Meter Reading
L.T Connection
L.T Connection
Surcharge for inaccessibility of meter
for reading as per notice
8.
130%
CHARGES FOR STANDBY FEEDER MAINTENANCE
CSPDCL
Page 21
PETITION FOR DETERMINATION OF MISCELLANEOUS & GENERAL CHARGES
Detailed Methodology
8.1
In line with the methodology adopted by the Commission in previous order, CSPDCL
has considered the normative Operation and Maintenance Expenses allowed by
Central Electricity Regulatory Commission in prevailing regulations.
8.2
As the standby feeder provided to South Eastern Railways is Double Circuit (Single
Conductor), equivalent rate for same as approved by the CERC has been proposed to
be considered.
Detailed Calculation
8.3
The Normative O&M approved by CERC for Double Circuit (Single Conductor) line is Rs
0.336 Lakh per KM, the same has been divided into 12 months in a year to calculate
the monthly cost. Accordingly, the normative O&M charges per KM per month comes
out to be Rs 2,800/-.
Proposed Charges
8.4
The proposed charges for Standby feeder maintenance is summarized below:
Table 8: Standby Feeder Maintenance
Particulars
Existing Charges
Proposed Charges
% Increase
/Decrease
Stand-by
feeder
maintenance charges for
220 KV or 132 KV
consumers (KM/Month)
2,125
2,800
32%
CSPDCL
Page 22
PETITION FOR DETERMINATION OF MISCELLANEOUS & GENERAL CHARGES
9.
CHARGES FOR MAINTENANCE OF STREET LIGHT
Detailed Methodology
9.1
To meet out the expenses in the activities on requisition made by the local body or
the government or any organisation made responsible by the government, for
maintaining public street lights, the utility has to deploy its resources to maintain,
repair and replace the public streetlights. Accordingly, following charges on street light
point basis are proposed which may be billed in addition to the tariff charges to the
concerned consumer depending upon the work of maintenance under taken by the
utility line staff in any month.
9.2
Therefore, CSPDCL would like to revise the charges as cost pertaining to this activity
has increased and actual cost needs to be reflected.
9.3
There has been drastic reduction in the number of filament lamp posts in recent times
as most of these have been replaced by CFL lamps. Therefore, CSPDCL would also like
to submit that the nomenclature of “filament lamp point” be changed to “lamp
point”.
Detailed Calculation
9.4
The detailed calculation has been provided in the Annexure – 5:
Proposed Charges
9.5
Maintenance of street light is a service which is provided by CSPDCL’s technical staff
as discussed above. All the below charges have increased with respect to the existing
charges on the account of increase in employee cost, which is the main cost driver for
these charges. Therefore, CSPDCL requests Hon’ble Commission to consider the above
cost parameter while revisiting the charges for maintenance of street light.
9.6
The proposed charges for maintenance of street lights (per point) is summarized
below:
Table 9: Maintenance of Street Light
Maintenance of Street
Light (Per points)
Existing Charges
Proposed Charges
% Increase
/Decrease
Lamp point
20
60
200%
Single tube light point
45
120
167%
Multiple tube light point
60
160
167%
CSPDCL
Page 23
PETITION FOR DETERMINATION OF MISCELLANEOUS & GENERAL CHARGES
Maintenance of Street
Light (Per points)
Special Lightings like
MV/SV lamp point
Existing Charges
Proposed Charges
% Increase
/Decrease
90
240
167%
10.
SUMMARY OF PROPOSED CHARGES
10.1
The various charges (both existing as well as proposed) have been summarized in the
below mentioned table:
Proposed Charges (in Rupees)
Sl.
No.
Particulars
A
Meter Hire Charges
1
2
a.
b.
Single Phase meter
3- Phase LT meter
10-40 Amp meter
20-100 Amp. Meters
3 Phase LT CT meter
11 KV Metering System
33 KV Metering System
132 KV Metering System
220 KV Metering System
Other work oriented jobs
Shifting of meter/meter board in the
same premises. (Even at the consumer's
request)
Re-sealing of cut outs provided on meter
board in the consumer's premises, if seal
is found broken.
Replacement of fuses/meter reading
card
Replacing consumer's cut out fuses (LT)
Replacement of missing meter reading
card (LT)
Disconnection/Reconnection
Single phase LT connection
3
B.
1
2
3
a)
b)
4
a)
CSPDCL
Approved Charges
effective from
01.09.2007
Proposed
(Per Month)
10
20
25
50
70
720
1,140
8,900
19,600
50
50
120
Same as existing
Same as existing
Same as existing
Same as existing
70
170
25
70
25
55
-
55
60
120
Page 24
PETITION FOR DETERMINATION OF MISCELLANEOUS & GENERAL CHARGES
Sl.
No.
b)
c)
d)
e)
5
a)
b)
6
C
1
2
3
4
5
6
7
8
9
10
11
12
13
Particulars
3-Phase LT connection up to 25 HP/19
KW
3-Phase LT connection above 25 HP/19
KW
HT Connection upto 5 MVA
HT Connection above 5 MVA
Re-rating/checking
of
installation/equipment done at the
request of the consumer
Single phase connection
Three phase connection
Testing of installation For the subsequent
testing of installation, or testing of an
extension to the existing installation, or if
the
wiring
contractor
or
his
representative fails to be present during
initial testing of a new installation or
subsequent testing
Testing charges
Single phase meter
3Ph. 4 wire meter, without CT
LT CT (each)
3Ph. 4 wire meter, with CT's
Tri-Vector meter
33 KV or 11 KV Metering Equipment
(Combined CT-PT Unit)
220 KV or 132 KV Metering Equipment
(CT or PT Set)
O/C, E/F Relay per element testing
BDV
HT CT/PT (Ratio, polarity, IR) each unit
ABT meter
Transformer
Testing
(Power
Transformer), Routine test at site, the
site being located at the H.Q of E.E (STM)
Transformer
Testing
(Power
Transformer), Routine test at site, the
site being located away from H.Q of E.E
(STM)
CSPDCL
Approved Charges
effective from
01.09.2007
Proposed
150
240
500
665
1,750
2,860
2,500
6,150
150
370
300
730
200
500
130
200
170
880
1,200
360
360
350
1,400
1,840
2,680
3,510
3,750
4,980
400
320
1,000
9,310
770
370
1,170
Same as Existing
-
4,900
-
4,900 (Transport
charges for the work
on actual basis)
Page 25
PETITION FOR DETERMINATION OF MISCELLANEOUS & GENERAL CHARGES
Sl.
No.
14
D
1
Particulars
Substation
Testing
(33/11
KV)
(Commissioning charges)
Additional charges for testing at site
Equipment tested at site, the site being
located at the Head Quarter of the MT
division
Approved Charges
effective from
01.09.2007
Proposed
-
12,640/-
800
"Rs 2800/- per day
or part thereof and
the transport charges
for the work on
actual basis."
800
"Rs 2800/- per day or
part thereof and
the transport charges
for the work on
actual basis."
2
Equipment tested at site, the site being
located away from H.Q. of EE (MT)
E.
Contest fee
1
LT meter
1.5 times of testing
charges
1.5 times of testing
charges
2
HT meter
2 times of testing
charges
2 times of testing
charges
F.
1
2
Special Meter Reading
L.T. Connection
H.T. Connection
55
570
3
Surcharge for inaccessibility of meter for
reading as per notice
G.
Replacement of Burnt meter
25
250
L.T. Rs. 25
H.T. Rs. 250
Cost of Meter
Cost of Meter
H.
SUPERVISION CHARGES FOR SERVICE
CONNECTION AND OTHER WORKS
1
2
(i)
(ii)
Single Phase
Three phase (up to 5 KW)
Connected load up to 25 HP
Connected load above 25 HP
200
570
365
510
1,170
1,180
3
(15% on actual cost of
Work got done by consumer's contractor
material + actual
labour charges)
CSPDCL
L.T. Rs. 55
H.T. Rs. 570
(15% on actual cost
of material + actual
labour charges)
Page 26
PETITION FOR DETERMINATION OF MISCELLANEOUS & GENERAL CHARGES
Sl.
No.
4
Shifting of connection
I.
Hiring of Board's Plant and Equipment
1
For initial agreement period
2
J
1
2
K.
For subsequent period of agreement
Transfer of Name
LT consumer
HT consumer
HT/LT tariff books
L.
1
Application processing fees
LT Industrial consumer
LT consumer (Other then Industrial and
BPL consumer)
2
3
M
N.
O.
1
2
3
4
1
Particulars
HT Consumers
Service charge for dishonoured cheque
Stand-by feeder maintenance charges
220 KV or 132 KV consumers
(KM/Month)
Maintenance of Street Light (Per points)
Lamp point
Single tube light point
Multiple tube light point
Special Lightings like MV/SV lamp point
Approved Charges
effective from
01.09.2007
Proposed
(15% on actual cost of
material + actual
labour charges)
(15% on actual cost
of material + actual
labour charges)
2% per month on
Current schedule of
rates
2% per month on
Current schedule of
rates
Twice the above
Twice the above
100
2000
30
Same as Existing
Same as Existing
501
1000
2,280
200
455
5000
11,410
Rs. 200/- or 0.55% of
the amount of
dishonoured cheque,
which ever in higher
Rs. 200/- or 0.55% of
the amount of
dishonoured cheque,
which ever in higher
2,125
2,800
20
45
60
90
60
120
160
240
Nominal hike proposed to cover the increased cost of printing and stationery over the years
CSPDCL
Page 27
PETITION FOR DETERMINATION OF MISCELLANEOUS & GENERAL CHARGES
11.
SYSTEM STRENGTHNING CHARGES
11.1
Commission in its First Amendment to supply code, 2011 has allowed utility to charge
system strengthening charges to Multi-Consumer Complex and Housing colonies as
per the following provisions.
“Clause 4.52:
Supply to Multi-Consumer Complex and Housing colonies-Special conditions:
(i) A building or a group of buildings which normally require(s) one or more than one
LT connection and for a total load of 50 KW or above, assessed as per clause 4.51 of
this Code, shall be treated as multiconsumer complex for the purpose of electric supply.
A multi-consumer complex shall include residential, non-residential and commercial
complexes, housing colony, office complexes, educational and training institutions etc.
(ii) Supply to a multi-consumer complex shall be arranged through a separate
distribution transformer of adequate capacity but not less than 100 KVA on a space
provided by the applicant. In case of higher capacity, the distribution transformer
capacity should be 200 KVA or 315 KVA which is generally used by distribution licensee.
(iii) The external electrification such as extension of 11 KV line, distribution transformer
sub-station and laying LT lines/cables within the colony shall be done by developer/
builder/housing society/group of consumers/ consumer, who applies for the
connection at it's own cost.
(iv) If the applicant wants to construct indoor transformer sub-station then applicant
may do so provided that transformer shall be of dry type apart from being energy
efficient and all safety measures as per prevailing rules and regulations should be taken
up and followed as required. In such case, cable required for connecting overhead line
of the licensee to HV terminal of indoor transformer shall be provided by applicant. If
an applicant wants to lay 11 KV and/or LT line through underground cable within the
colony beyond the sub-station or distribution transformer, it shall be permitted to do so
subject to the condition that the relevant Indian Standards are followed. Any capacity
of distribution transformer installed by the applicant should be of 100 KVA or 200 KVA
or 315 KVA which is generally used by distribution licensee and its entire cost shall be
born by applicant.
(v) If the load of the colony / multi consumer complex;
CSPDCL
Page 28
PETITION FOR DETERMINATION OF MISCELLANEOUS & GENERAL CHARGES
a. is below 1500 KW, the applicant shall pay system strengthening charges as per
miscellaneous and general charges approved by the Commission. Till such
charges are approved by the Commission, the licensee shall recover system
strengthening charges @ Rs. 4500/- per KW. Cost of extension of 11 KV Line up
to 2 km outside the colony area shall be born by licensee and beyond 2 km shall
be born by the applicant.
………………………”
11.2
Based on the above provisions proposed by the Hon’ble Commission, CSPDCL has
computed the actual cost of providing such service to the said consumers on Rs. /kW
basis. The computation consists mix of cost incurred towards 1 X 3.15 MVA Substation
and line cost of 11 KV of 2 KM, 1X5 / 2X5 MVA Substation and line cost of 33 KV of 3
KM and 2X5 MVA Substation and line cost of 33 KV of 5 KM.
Table 10: System Strengthening Charges
Requirement
Load
Applied
(in KW)
500
1000
1500
Substation
Line
1 X 3.15
MVA
1 X 3.15
MVA
1 X 3.15
MVA
11 kV
(2 KM)
11 kV
(2 KM)
11 kV
(2 KM)
33 kV
(3 KM)
33 kV
(3 KM)
33 kV
(3 KM)
33 kV
(3 KM)
33 kV
(5 KM)
33 kV
(5 KM)
33 kV
(5 KM)
2000
1 X 5 MVA
2500
1 X 5 MVA
4000
2 X 5 MVA
4500
2 X 5 MVA
7500
2 X 5 MVA
8000
2 X 5 MVA
9000
2 X 5 MVA
Cost of
Recovery Rate
Charges for
100%
@ 4500
recovery at
different
loads
Substation
per kM line
S/S plus
Line cost
9124801
616360
10357521
21.72%
20,715
9124801
616360
10357521
43.45%
10,358
9124801
616360
10357521
65.17%
6,905
10808116
815603
13254925
67.90%
6,627
10808116
815603
13254925
84.87%
5,302
17240640
1631206
22134258
81.32%
5,533
17240640
1631206
22134258
91.49%
4,918
17240640
1631206
25396670
132.89%
3,386
17240640
1631206
25396670
141.75%
3,174
17240640
1631206
25396670
159.47%
2,822
Average
CSPDCL
7,000/-
Page 29
PETITION FOR DETERMINATION OF MISCELLANEOUS & GENERAL CHARGES
11.3
The average realisation based on the above scenarios is Rs 7000/ KW. Therefore, it is
submitted that the above charges are on a higher side as compared to charges
considered by the Hon’ble Commission in the First Amendment as actual prevailing
costs have been considered by the CSPDCL.
11.4
It is evident from above that:
(1)
The maximum recovery is of 65% only at the charges of Rs 4500/kW currently
considered by the Commission in case load is lower than 1500 KW.
(2)
To ensure substantial recovery considering the above mix of load, the charges
should be above Rs 7,000 per kW.
11.5
Thus, considering the above mentioned facts, CSPDCL would like to propose the
system strengthening charges of at least Rs 7,000/- per kW so as to ensure recovery
of substantial cost incurred.
CSPDCL
Page 30
PETITION FOR DETERMINATION OF MISCELLANEOUS & GENERAL CHARGES
12.
SUPPLY AFFORDING CHARGES
12.1
Hon’ble Commission in its First Amendment in supply code, 2011, has allowed utility
to charge supply affording charges to small/cottage industries up to 25 HP load as per
the following provisions.
“Clause 4.56:
Supply to small/cottage industry up to 25 HP except stone crusher special provisions
for urban and rural area:
The licensee shall provide connection to small/cottage industries up to 25 HP load on
payment of supply affording charges as approved by the Commission in the
miscellaneous and general charges. Till these charges are approved by the
Commission, the licensee shall recover supply affording charges @ Rs. 2000/- per HP.
This supply affording charges shall be payable by the small/cottage industry consumer
up to 25 HP load on per HP basis even if any extension is required or not. The Licensee
shall provide distribution transformer, if required. The licensee shall, also provide 11
KV line/LT line 0.5 km in urban area and 1 km in rural area. The cost of the line more
than 0.5 km in urban area and 1 km in rural area shall be recovered from applicant(s)."
12.2
Based on the above provisions proposed by the Hon’ble Commission, CSPDCL has
computed the actual cost of providing such service to the said consumer on Rs. /HP
basis. The computation consists of cost incurred for distribution transformer of 25 KVA
rating and line cost of 11 KV.
Table 11: Cost of Transformers
Calculation of Supply affording charges up to 25 H.P
Transformer Cost ( 25 KVA)
The cost of 1 KM 11 KV line
Maximum load which can be catered
140826
616360
25 HP
Table 12: Charges ( Rs /HP)
Transfor
mer
25 KVA
CSPDCL
Cost of transformer and wire
Length (KM)
Total Cost with 15 HP
Transformer (Rs )
0.5
29,934
4,49,006
Rs/ HP
Load (HP)
20 HP
25 HP
22,450 Rs/ 17,960 Rs/
HP
HP
Page 31
PETITION FOR DETERMINATION OF MISCELLANEOUS & GENERAL CHARGES
Cost of transformer and wire
Load (HP)
25 KVA
1
50,479 37,859 Rs/ 30,287 Rs/
7,57,186
Rs/ HP
HP
HP
12.3 It is submitted that the above charges are on a higher side as compared to charges
considered by the Commission in the First Amendment as actual prevailing costs has
been considered by the CSPDCL.
12.4
However, the actual expenditure incurred by CSPDCL in consumer category of
small/cottage industries up to 25 HP load i.e. the LV-5 category of Tariff Schedule is
reproduced below.
Table 13: Actual Cost Incurred
Particulars
FY 2012-13
FY 2013-14
Total
1106
1002
2108
8677.78
6901.05
15578.84
11631.60
9727.73
20891.22
Avg Load applied per case
10.52
9.71
9.91
Total Expenditure incurred
425506
484563
910069.00
293
252
545
2697.98
2461.36
5159.34
4050.79
3500.22
6918.67
Avg Load applied per case
13.83
13.89
12.69
Total Expenditure incurred
35377199
34530489
69907688.00
1399
1254
2653
11375.76
9362.41
20738.17
15254.90
12554.99
27809.89
Avg. Load applied per case
10.90
10.01
10.48
Total Expenditure incurred
35802705.00
35015052.00
70817757.00
2346.96
2788.93
2546.50
No. of Cases
Load
approval
case
Load
(in kW)
Load
(in HP)
No. of Cases
For
Extension
case
Load
(in kW)
Load
(in HP)
No. of Cases
Load
(in kW)
Load
(in HP)
Total
Charges/HP
12.5
It is evident from above that,
(1)
On an average, approximately 12 HP load is applied per application.
(2)
The average charges incurred by CSPDCL has increased by more than Rs. 400/in past two years.
CSPDCL
Page 32
PETITION FOR DETERMINATION OF MISCELLANEOUS & GENERAL CHARGES
12.6
Thus, considering the above mentioned facts, CSPDCL would like to propose the
supply affording charges of Rs 3,000/- per HP considering the increasing trend seen
in previous years.
CSPDCL
Page 33
PETITION FOR DETERMINATION OF MISCELLANEOUS & GENERAL CHARGES
13.
PRAYER
13.1
In view of above, it can be safely inferred that various components associated with
determination of Miscellaneous & General charges have undergone considerable
change over a period of 7 years. Thus, there is an urgent requirement of revision of
these charges.
13.2
CSPDCL thus requests the Hon’ble Commission to:
a) Admit the petition of Chhattisgarh State Power Distribution Company Limited
(CSPDCL), Raipur and determine & approve the proposed charges.
b) To condone any inadvertent omissions/ errors/ shortcomings and permit the
Petitioner to add/ change/ modify/ alter this filing and make further
submissions as may be required at a future date
c) To allow other existing charges which have not been proposed for revision as
per the prevailing rates only.
d) To allow further submissions, addition and alteration to this Petition as may be
necessitating from time to time.
e) Treat the filing as complete in view of substantial compliance as also the
specific requests for waivers with justification placed on record;
f) And pass such other and further orders as are deemed fit and proper in the
facts and circumstances of the case.
BY APPLICANT
CSPDCL
Page 34