Objections to BESCOM’s proposed tariff hike of Rs.0.75 per unit

Dear Madam/Sir
We request you to use the below content to file your/organisation objections.
.............................................................................
29th October 2010

The Receiving Officer
KARNATAKA ELECTRICITY REGULATORY COMMISSION
6th & 7th Floor, Mahalaxmi Chambers, # 9/2, M.G.Road, Bangalore 560 001

Objections to BESCOM’s proposed tariff hike of Rs.0.75 per unit

Reference: BESCOM’s application to KERC dated 13/8/2010

Reasons for objections

1.KERC regulations not adhered to:

a.Late filing and no reasons given: After Tariff order 2009 was issued on 25/11/09 the present filing should have been filed by BESCOM in Dec 2009, but was filed in mid August 2010. No reason is provided. As a measure of penalty for late filing it would be appropriate that the new tariff if at all, is made applicable only for the remainder period of FY 11 and that no regulatory asset is created for the period 1/4/10 to the date of issue of the Tariff order 2010.

b.No Annual Review of performance for FY10: As per clause 2.8 of 2006 Regulation, BESCOM should have filed an application for annual performance review for FY 10 by 30/11/2009. They did not file even along with the present filing. Therefore Interest & finance charges approved for FY 10 now needs to be deleted from FY 11 expenditure. Without the annual review any deficit or surplus of FY 10 cannot be taken forward to the second control period.

c.Non-submission of data for conducting prudence checks on completed capita works in FY 10: Was neither submitted by 31/3/2010 nor along with the present filing.

2.Balance Sheet (form A-2 at page 164 of ERC filing) without explanation:

a.Increase in fixed assets in FY 10 is not proportional to availability of funds. As against the availability of loan funds of Rs. 976.18 cr, the gross block is estimated to go up only by Rs. 376.82 cr. No explanation for such low asset creation when higher levels of funds are deployed.

b.Capital works in progress: During FY 10, capital works in progress was only 187.91 cr against availability of loan funds of Rs. 976.18 cr. No explanation.

c.Assets not in use: Conveniently shown entry in this column as zero for all the years FY 9 to FY 13. Not furnished figures with appropriate explanations.

d.Receivables against sale of power: Entry against this column is consistently very high in the range of 1700 cr for all the years FY 10 to FY 13. No explanation for keeping such heavy amounts pending realization. No explanation on action to be taken to bring down the figures drastically.

e.Other current liabilities: FY 09 figures are 572.25 cr. In FY10 the figure has jumped steeply to 1232.49 cr. No explanation for such a steep increase in other current liabilities.

3.Faulty forecast:

a.There is a consistent negative growth w.r.t the forecast:
i.2006 forecast of 20343 MUs for FY 10; ended up in 17222 MUs actuals in FY 10 .
ii.Whopping minus 18%. No explanation.

b.Not buying additional power when shortage is anticipated. This resulted in extensive load shedding and “choking” of consumers

c.Has referred to the KERC Load Forecasting regulations of 2009, implying that they have followed these regulations. But it is clear that they have not done so. The regulations calls for periodic forecasts and are supposed to contain both peak load (MW) and energy (MUs) in these forecasts. There is no evidence that this has been done at all.

4.Substandard quality of Service:

a.Basically no definition for ‘quality’
b.Frequent load shedding – with out justifiable reasons
c.Absence of load shedding schedule
d.Continued restricted power supply to certain categories of customers (6 hour, 8 hour, 20 hour and 22 hour supply)
e.Failure to forecast near correctly.
f.Distribution system failure – loss of 16%

5.Incorrect cost projection based on incorrect facts/figures/reasoning – Savings that can be effected

a.Assumption of availability of hydel power 20% less than normal presuming bad monsoon while all the reservoirs except Supa are near full with copious rain continuing even now.. Taking only 10 % less, availability of hydel power, saving will be 125 crores.

b.There is mismatch between the input cost increase which is around 13% and the proposed rate increase of 25%, hence we object to the increase proposed.

c.Unacceptable down sizing of power supply from KPCL Thermal: From 7836.79 MU in FY 08 to 7071 MU in FY 10. Now to 6583 MU in FY . If 7071 MU is supplied , savings will be Rs 26 crores

d.Short term purchases of 3265 MU (794 MU @ Rs. 5.60 per unit and 2471 MU @ Rs. 3.50) which works out to 17% of total proposed purchases of 23,039MU.
i.At normal times 17% is a very high figure for short-term purchases.
ii.Why purchase at Rs. 5.60 while available at Rs. 3.50 per unit.
iii.Purchasing all short term purchase at Rs. 3.50 / unit saves Rs. 167 crores.

6.Formula not stuck to while working O&M:

a.In Tariff order 2009 dt 25/11/2009 on the revised ERC and Retail Supply Tariff for FY 10, KERC had worked out the O&M Expenses for FY 10 by applying the formula @ 509.73 crores. This will be the basis for working out the O&M expenses for the control period FY 11 to FY 13 and not the so-called actual figures. The calculations shown are not correct.

b.Employee’s revision of pay scales from 1/4/10 (FY11) (additional expenditure of 89.48 cr)when the pay revision commission/committee is yet to be constituted can be postponed by FY12 with this, (O&M) expenses in FY 11 works out to only 581.86 cr & not Rs. 723.77cr proposed by BESCOM. Savings in (O & M ) cost will be Rs 142 crores

7.After deducting Rs. 593.61 cr as Govt subsidy, the net gap projected by BESCOM FY 11 as Rs. 1074 cr can be brought down to Rs. 396 cr by the savings in expenses. This may only need a small percentage increase if at all, to bridge the gap

8.Unscientific and discriminatory proposal to impose uniform increase in per unit charges across all categories of consumers (viz 0.75 p/unit or any increase determined by KERC) to meet the Gap:

a.Weaker sections of society who consume in the 2 slabs of 0 to 30 units and 31 to 100 units per month are forced with 33% increase in tariff while the middle and upper class who would consume above 100 units will pay about 22% more.

b.By adopting increase in the same percentage basis for all categories and sub categories analomies such as in (a) above will be minimised .

Prayer:

Keeping all the above factors in view we pray:
-There be no hike OR if at all - in the range of Rs. 0.20 to Rs. 0.25 per unit
-To increase to safeguard the interests of the weaker section of the society there be no increase in the lowest 2 slabs (up to 100 Units).

For/On behalf of
- Sd -

INVITATION

INVITATION
To a Roundtable Discussion on


BESCOM’s proposal to increase consumer tariff by 75 paise per unit for the financial year 2011- 2012 under Multi year tariff scheme and asking stakeholders to file objections by 4th November 2010


We cordially invite you to this discussion and with your feedback and suggestions, wish to finalise comments & objections on BESCOM’s proposal.

Date: Monday 25th October 2010
Venue: Shikshakara Sadana, Mysore Bank Circle, Bengaluru 1
Programme schedule:
3PM: Welcome and objectives
3.10PM to 3.45PM: Presentation of the proposal
3.45 to 4.45PM: Open discussion
4.45PM to 4.50PM: Summery and next steps
4.45PM to 5PM: Vote of thanks

Presenters of the Proposal

Sri. A Raja Rao
Former Executive Director, BHEL

Sri. Y V Aswathanarayana
Former Advisor - Works, Railway Board, Ministry of Railways

CIVICs work on ‘Participatory Planning and Budgeting in a Ward’

There are number of stakeholders in a ‘Participatory Planning’ at the ward level - people/communities, organized groups, elected representatives, ward officials, etc., It is important that all are involved in the process for its success and continuity. It is a challenge. We have started with one ward – Sagayapuram (Ward 60) in Bengaluru/Bangalore .

We started with the Bruhath Bengaluru Mahanagara Palike (BBMP) officers – the zonal commissioner, chief engineer and others. The idea was shared and we were encouraged by the positive response. Then we identified active RWAs in the ward and arranged for an interactive session with RWAs and BBMP officials on 16^th January 2010. The concept was shared and all accepted that a ward plan has to be developed involving people from each and every area in the ward. This was the beginning of the next challenge – bridging the social divide in the ward.

Social composition of Ward 60 is complex matrix. Southern part is well developed and inhabited by middle/upper class families while the northern part is underdeveloped and inundated with little dwellings – as can be seen from the ward map. The biggest challenge was in bringing different sections of society on a single platform to collectively plan for the ward.

While the RWAs are active in southern part, it took a while to convince them that a plan for the ward can’t be a plan drawn only by them but people and communities from different areas need to be involved. They appreciated this point and agreed to work with northern sections. The first hurdle was crossed.

The second step was to identify individuals/groups in the northern part that are simply oblivious to the idea of ‘participation’ and then bring them around to sit with organized RWAs. We succeeded after numerous forays into the northern area, known for notorious activities. The concept was shared with individuals and organizations of the northern section. Collectively they now have formed a Federation of Civil Societies of Sagayapuram – Ward 60 (FCSS-Ward 60). The RWAs from the south agreed that from the budget meant for the ward, the already developed portion, where they are from, needs only maintenance work while the bulk of it has to go to the poorer portion, the northern portin, for development works.

This was followed with area-wise meetings with people, identification and assessment of requirements, especially in the under-developed areas – Sagaypuram layout, Bagalur layout, Gidappa block, Pillanna garden layout, MS slum area - with active participation of RWAs. A cumulative list of required works was prepared for each area. The list was prioritized for each area in couple of ensuing meetings. And finally first, second and third priority list of works for the areas were finalized in the meeting. Later the requirements were put into drawings and were budgeted.

Thus a ‘Programme of Works (PoW) for the year 2010-2011 for Ward 60’ was evolved by the people/organizations. The PoW was presented to the newly elected councilor Ms. Palaniyammal V, who inturn handed it over to the urban local body, the BBMP, represented by its Executive Engineer in an open meeting with people of the ward on 7^th May 2010. Both the Councillor and the Executive Engineer have assured to adopt this PoW for the coming year. The PoWs were officially submitted to the BBMP with formal letters – records of which would facilitate further follow up – if necessary through RTI.   

This is only the beginning! We hope to build on this model and perfect it to suit various situations in different wards and push it through the council as a model process in other wards of Bengaluru. And in the mean time we hope an enabling piece of legislation in the form of Bengaluru Regional Governance Bill will be put in place to back this up. It is also noteworthy that the local government, state government and the central government have signed a tripartite MoA under JNNURM that a ‘public participation law’ will be enacted – a mandatory reform, which is due. We hope this process would help to realise the participation of people in governance as envisaged under the Nagarapalika Act (74^th Constitutional Amendment Act).  

CIVIC Bangalore has great pleasure in inviting you to the release of and consultation on a study report on ‘Implementation of BSUP-JNNURM projects in Bengaluru’ and the release of ‘A Compendium of Government Schemes for the Urban Poor’

CIVIC Bangalore

has great pleasure in inviting you

to the release of and consultation on a study report on

‘Implementation of BSUP-JNNURM projects in Bengaluru’

and the release of

‘A Compendium of Government Schemes for the Urban Poor’

Presided by

Dr. A. Ravindra, IAS (Retd.)

Urban Advisor to Chief Minister of Karnataka

Honourable Chief Guests

Sri S. K. Nataraj

Worshipful Mayor of Bengaluru

&

Sri Dayananda, N.

Deputy Mayor of Bengaluru

Guests of Honour

Sri Bharat Lal Meena*, IAS

Commissioner, BBMP

Sri G. V. Kongwad, IAS

Secretary, Housing Department, GoK

Date: Saturday 22nd May 2010 Time: 2.30 PM to 6.00 PM

Venue: Senate Hall, Central College, Dr. Ambedkar Veedhi, Bangalore

ALL ARE WELCOME

* Awaiting confirmation


Programme Schedule

2.30PM – 3.00PM Tea and registration
3.00PM-3.10PM Welcome & briefing on the objectives of the consultation CIVIC
3.10PM-3.30PM Screening of documentary film on BSUP-JNNURM in Bangalore CIVIC
3.30PM-3.50PM Presentation on the research findings on BSUP-JNNURM in Bangalore Kavita Kanan, Researcher
3.50PM-4.30PM Presentation on BSUP implementation by grassroots organizations and community representatives Community representatives/ workers from the slums
4.30PM-5PM Open discussion on road map for implementation through participation, accountability and transparency
5PM-5.05PM Remarks about the Compendium Lakshmikantha - CIVIC
5.05PM-5.10PM Release of books:1. BSUP-JNNURM study report2. Compendium of government schemes for the Urban Poor Chief Guests: Worshipful Mayor & Deputy Mayor of BBMP
5.10PM-5.40PM Remarks by Chief Guests
5.40PM-5.55PM Chairperson’s remarks Dr. A. Ravindra
5.55PM- 6PM Vote of thanks CIVIC


CIVIC Bangalore
(Citizens’ Voluntary Initiative for the City)
# 6, Kasturi Apartments, 35/23 Langford Road Cross, Shanthinagar
Bangalore 560025

Email: info@civicspace.in URL: www.civicspace.in
Tel: 22110584 / Telefax: 41144126
Cell Nos: 97318 17177/ 9739439220 / 9880963996

BWSSB has no plan to implement 600 crore project

So reveals an RTI inquiry into its MPIC (Monthly Programme Implementation Calendar). While 3 outcomes of this mammoth spending looks specific, the 4^th

which says – slum development for 300 slums by 2013 is vague. Monthly activities that would achieve the financial and physical targets are conveniently overlooked. This is precisely how adhoc measures are resorted to. 

Also wonder if these forms are real, meaning were submitted to the finance commission, and if so wonder how it accepted such grossly underdone statements.

One template from the agri sector shows how an MPIC looks like. This is a very crucial tool in tracking each sector spending. 

Will keep pursuing these and particularly of the BWSSB, again through RTI to its logical end – to put a planning process in BWSSB.

That is one way of using RTI in a creative way. 

Other segments needs to be addressed to. More we use RTI, more we learn to put it to good use - not just as a tool for info, but to bring in systemic changes, the way govt functions. Just the begining!

Impact of CIVICs work on education in a short span of 6 months

Education is a new domain to CIVIC. While learning and understanding the processes involved, the engagement has brought about a few significant changes. CIVIC has concentrated and been interacting with the 4 schools to which the children from Deshyanagar and Rajeevgandinagar go to. Two schools are in Ward 60 (Sagayapuram) and another two in Ward 55 (Devasandra). They are administered under South Zone of State Education Dept. These schools are:

- Government Primary School, Cox town, Ward 60
- Government High School, Cox town, Ward 60
- Government Primary School, K. R. Puram, Ward 55
- Government High School, K. R. Puram, Ward 55

We began by asking these schools for their mandatory suo motu disclosure under Section 4(1)(b) of the Right to Information Act. As these were not available, we filed an appeal with the Karnataka Information Commission (KIC). The hearing of the appeals came up in the KIC on 06.01.2010. The KIC in its order KIC 9059 & 9058 PTN 2009 dated 6-01-2010 has directed the Secretary, Primary & Secondary Education and the Commissioner for Public Instruction to prepare a template for implementing the suo motu disclosure in all schools in the State and train all schools in it. This decision has a statewide implication. It also asked CIVIC to help these schools prepare their suo motu disclosure.

In the meantime, we observed the infrastructure of the schools and the implementation of the midday meal programme in them. We spoke to School Development and Monitoring Committee (SDMC) members in the schools on how they could improve these. We realized that the SDMCs needed to be empowered and started training the SDMC members on the “Roles and Responsibilities of SDMC Members” as per the contents of Gazette notification: No: ED122PBS2004, Bangalore, Dated 14th June 2006. We have conducted these workshops in two schools so far. This had quick impacts:

- The SDMC members gained a clearer understanding of their roles and responsibilities, especially on the implementation of SSA. For instance, after one SDMC meeting, a head-mistress of one of the schools asked the SDMC members to come to school once again to sign the cheque for the completed construction work of the school toilet. The members asked the head-mistress why this issue had not been discussed in the SDMC meetings and how the work had been given to external agencies without the consent of the SDMC. It was decided that the head-mistress should provide clarifications / appropriate reasons in this regard at the next meeting.

- Immediately after the training at K. R. Puram High school, the president of the SDMC, who was ineligible to hold the post as his daughter had already passed out of the school, made way for a new president, whose child was still in the school.

- School children, who were not represented on the SDMCs as per the rules for constituting SDMCs, were made members.

- The ‘Mahithi Sindhu’ programme, which was not running for months in KR Puram Hoigh School due to want of a computer teacher, got activated in the school after CIVIC intervened with Department of State Educational Research and Training (DSERT) on 13th Nov 2009. It was followed up with an RTI enquiry on 25th Nov 2009. A new teacher was appointed on 7th Dec 2009. Now the classes are being held regularly

- In KR Puram Hoigh School, soon after the SDMC training, the SDMC took measures to improve the washing facilities for children for the midday meal. All children had to wash at a single tap as three taps were dysfunctional. The defunct taps were replaced and sinks installed.

Significant Impact of JnNURM intervention in Deshyanagar

The Karnataka Slum Clearance Board (KSCB) in its projects under 1^st and 2^nd phase slums (totaling 33 slums in Bangalore) under JNNURM had not budgeted for Transit Stay Arrangement for the beneficiaries. The beneficiaries were told to fend for themselves in the construction period which ranges from 12-15 months, in some cases even more – putting enormous economic, social, physical and physiological pressures on the urban poor families.

Now the KSCB has taken a conscious decision to budget this component in all the slums coming under the 3^rd phase – as a direct result of intervention in Deshyanagar - as admitted by the officials. From now on all the families where JNNURM projects will be taken up by the KSCB, it would make sure that all the families would get proper accommodation, water and sanitation facilities in the transit phase.

How did this come about? The following events happened in that date wise sequence:

1. People met and submitted a request to the Commissioner, KSCB on 21^st May 2009 details on the JnNURM-BSUP housing project that is being implemented by KSCB in Deshyanagar slum. People didn’t have a clue on the project details. A major request was made to provide transit stay arrangement to the residents immediately, before beginning any construction work. He assured the residents that the arrangements will be made for transit stay in a week’s time. He asked the residents to clear a portion of the land so that construction of one block could begin. The residents honoured his word and 42 families cleared a portion of the site on the next day, 22^nd May 2009 itself. The promise was never met.

2. The Technical Director, KSCB came and addressed the people on 3^rd June 2009. Apart from other assurances he promised transit stay arrangement with water and toilets by 8^th June 2009. The promise was never met.

3. Four (joint) letters to KSCB from the Deshyanagar People’s Committee, CIVIC and Mythri dated 21st May 2009, 1^st June 2009, 9^th June 2009 and 15^th June 2009, requesting inter alia for provision of transit stay arrangements for those displaced by KSCB from Deshyanagar slum were submitted. No action was taken by any officers.

4. KSCB was asked under RTI with life and liberty clause on the action taken report on each of these four letters on 19^th June 2009. The KSCB did not reply in 48 hours.

5. CIVIC filed a petition with Karnataka Human Rights Commission on 20^th June 2009. The honourable member has asked the KSCB to arrange for the transit facilities by 6^th July and file an interim report. The case is coming for hearing in August.

6. On 22^nd June 2009, the Technical Director and the Assistant Executive Engineer orally instructed the families to put up their huts in the opposite BBMP office space, assuring that they will take care of any untoward incidents. The families put up their in the evening. The next day, on 23^rd June 2009 they were thrown out to the pavement again. No official of the KSCB took any responsibility. They were shunted from their original place to pavements and to another and back to the pavement - with out taking any responsibility for this unnecessary physical and psychological stress.

7. The Chief Information Commissioner sent a summons to the KSCB on 24^th June to appear for hearing on 30^th June 2009. In the interim period the KSCB sent a letter of explanation to CIVIC suppressing the truth – that the families had vacated on their own.

8. On 30^th June 2009, The Chief Information Commissioner heard the case and directed the KSCB to provide the transit stay arrangement by 10^th July 2009 and to appear for the hearing on the same day with a status report.

9. On 2^nd July 2009, for the first time, KSCB officials ask for a meeting with the community. The Executive Engineer (EE) and Assist. Executive Engineer (AEE) discussed with the people. The EE admitted that it was a fault by the KSCB that it did not make provision in the budget under JNNURM in the first and second phase implementation. The EE admitted that with the experience of Deshyanagar the KSCB has consciously made a decision to budget this component in all the projects from the third phase.

This is a major transformation in the approach while implementation of NURM by the KSCB. However the families of Deshyanagar continue to live on the pavements – after 40 days of displacement. The KSCB officials continue to assure that they will find a place sooner than later.

Many questions remain unanswered w.r.t Deshyanagar slum project. A few noteworthy are:

- The DPR obtained under RTI from KSCB put the project cost at Rs.6.23 crores and this is already sanctioned from the centre. Now the KSCB is saying that the project cost is about Rs.2.43 crores. An explanation was sought as to where will the remaining amount of Rs.3.8 crores, which is sanctioned by the centre to this project of Deshyanagar will go. The EE opined that he is not clear on this. The AEE said that the DPR is being ‘reworked’ now. The EE assured that he would provide the ‘reworked’ DPR immediately.

- The guidelines suggest the land title be given to the families in the name of women. There KSCB has told the people that they will be given only possession certificate – after clearing the beneficiary contribution.

- The KSCB has collected Rs.5100 from each of the 112 families in March 2008 – 15 months before the project started on the ground. The families are struggling to payback this loan.

- The operation & maintenance cost is not discussed with families. Even the EE and AEE don’t have a clue.

CIVIC is trying to get to the bottom of this mess. It along with the people’s committee and Mythri is pressing hard to get the transit arrangement as quickly as possible.