BEFORE THE - Infraline

MERC Tariff Order for MSEB – FY 2001-02 

BEFORE THE 

MAHARASHTRA ELECTRICITY REGULATORY COMMISSION 

World Trade Centre, Centre No.1, 13 th Floor, Cuffe Parade, Mumbai-400 005 

Case No.1 of 2001 

IN THE MATTER OF 

Determination of tariff [2001-02] applicable to various categories of consumers of the 

Maharashtra State Electricity Board 

Mr. P.Subrahmanyam, Chairman 

Mr. Venkat Chary, Member, 

Mr. Jayant Deo, Member. 

Date of Order: January 10, 2002 

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, 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 proposal seeking a tariff 

revision of about 37%, on 15 th March 2001 to the Maharashtra Electricity Regulatory 

Commission (MERC) for the Revision of its Retail Distribution Tariff with effect from 1 st 

April 2001, keeping in view the requirements of Section 59 of the Electricity (Supply) Act, 

1948. The Commission could not take up the proposal for immediate consideration since 

Prayas, Pune, representing consumer interests, had filed Case No.8 of 2000 before the 

Commission on 7 th October 2000 seeking various documents related to MSEB’s agreements 

with Independent Power Producers. Prayas filed a further application in this Case on 3 rd 

April 2001 praying that any application from the MSEB for revision of tariff may not be 

considered by the Commission in the meanwhile, and this case was sub-judice before the 

Commission. The matter was discussed in the 24 th Meeting of the Commission held on 15 th 

June 2001. During the meeting, it was observed that “in the light of the recent developments, 

particularly in the context of the MSEB’s dispute with the Dabhol Power Company, the entire 

presumption and arithmetic may undergo a sea-change and, consequently, the MSEB might 

like to revise the tariff proposal submitted on 15 th March 2001. Therefore, the MSEB should 

Introduction and Salient Features 1


be asked as to whether it would like to revise the proposal or continue with the same 

proposal”. 

Subsequently, the MSEB vide its letter No.MERC/Tariff/32581 dated 31 st August 2001 

submitted on affidavit the Revised Tariff Revision Proposal for the year 2001-02 in three 

volumes. On receipt of the proposal, the Commission held a Technical Validation Session in 

the presence of Consumer Representatives recognised under Section 26 of the Electricity 

Regulatory Commissions Act, 1998, on 11 th September 2001. During the Technical 

Validation Session, it was decided that the matter should be put through the Public Hearing 

procedures in a transparent manner and, therefore, a Public Notice should be issued for 

inviting objections from interested parties. The Commission also prescribed that objections 

should be filed on affidavit. The GoM was intimated about the course of action to be initiated 

on the Tariff Revision Proposal of 2001-02 of the MSEB at the initial stage itself (before the 

Public Hearings) and the Commission had requested the GoM to actively participate in the 

hearings. 

During the Technical Validation Session held on 11th September 2001 at Mumbai, the 

following persons / officials were present: 

Sr. Name of person / official Designation & Institution. 

01 Shri Girish Sant Member, Energy Group, Prayas 

02 Shri Shantanu Dixit Member, Energy Group, Prayas 

03 Shri Ashok Pendse Mumbai Grahak Panchayat 

04 Shri Goenka Vidarbha Industries Association 

05 Shri Vinay Bansal Chairman, MSEB 

06 Shri A. Krishnarao Member (Accounts), MSEB 

07 Shri Vidyadhar Kanade Secretary, MSEB 

08 Shri A.K. Pampattiwar Technical Director, MSEB 

09 Shri S.G. Bakshi Chief Engineer, MSEB 

10 Shri V.D. Apte Chief Engineer, MSEB 

11 Shri A.B. Bhalerao Chief Engineer, MSEB 

12 Shri S.J. Amberkar, Dy Chief Accounts Officer, MSEB 

13 Shri A.D. Palamwar Chief Engineer, MSEB 

14 Shri S.P. Vihalkar Dy Chief Accounts Officer, MSEB 

15 Shri. Sameer CRISIL, Consultant, MSEB 

16 Shri G.S. Limaye SE, MSEB 

17 Shri R.S. Lade JE, MSEB 

18 Shri S.Y. Ruge DOP, MSEB 

19 Shri S.Y. Patil Addl. Director (Per) 

20 Shri V.S. Moghe SE, MSEB 

21 Shri H.A. Patil SE, MSEB 



22 Shri R.M. Agrawal CE, MSEB 

23 S.D. Kondejkar CE, MSEB 

24 Smt. Lakshmi Gopalan Jt Secretary [Energy], Govt of Maharashtra 

25 Shri S.N. Manekar Under Secretary [Energy], Govt of Maharashtra 

26 Shri K.R. Shriram, Advocate Legal Counsel, MERC 

27 Shri M. Palaniappan Sr. Analyst, ICRA, Consultant, MERC 

28 Shri Balawant Joshi AGM, ICRA, Consultant, MERC 

29 Shri Suresh Gehani Manager, ICRA, Consultant, MERC 

30 Shri Nishikant N Kale ICWA 

31 Shri Ashwin Treasurer, Convenor, TDIPF 

32 Shri Prakash T. MSEB 

33 Shri S.R. Panikar ES, MSEB 

The Public Notice was published in the Times of India, Maharashtra Times, Loksatta, Indian 

Express, Business Standard, Economic Times, Financial Times in Mumbai, and in leading 

local newspapers in each of the six Revenue Divisions of the State. The Public Notice 

appeared in various newspapers on 12 th & 13 th September 2001. A press conference was also 

convened on 9 th September 2001 by the MSEB to disseminate the information to a wider 

audience in the State. Copies of the MSEB’s proposal 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. The last date for filing the written objections was fixed 

as 25 th September 2001, which allowed a period of 14 days to the public to enable them to 

file their objections. 

The entire Proposal, including worksheets was also put on the official website of the MSEB 

in downloadable format. 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 16 th October 2001 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 Public Notice advised objectors to also mail copies of their objections, written either in 

English or in Marathi, to the 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. 

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 3 rd October 2001 at 10.00 hrs 

2 Nagpur 4 th October 2001 at 10.00 hrs 

3 Aurangabad 6 th October 2001 at 10.00 hrs 

4 Nashik 8 th October 2001 at 10.00 hrs 

5 Pune 9 th October 2001 at 10.00 hrs 

6 Mumbai 15 th & 16 th Oct 2001 at 11.30 hrs 

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. Many of these objections were not in the format prescribed by the Commission, but 

the Commission, using its inherent powers, decided to take cognizance of all the objections, 

irrespective of whether they fulfilled the proper procedure or not so as to meet the ends of 

justice. 

The Commission received a total of 533 objections: 381 on affidavit and 152 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. In addition, the Commission also admitted 

objections filed during the public hearing (refer Annexure I). 

The category-wise and revenue division-wise number of consumers/institutions who 

submitted their objections to the MSEB’s Tariff Revision for 2001-02 is detailed below in the 

Table: 

Interest Groups Amravati Nagpur Aurangabad Nashik Pune Konkan Total 

Consumers 2 4 1 1 8 41 57 

Individuals 4 1 2 6 2 72 88 

Industries 2 6 2 4 8 35 57 

Lift Irrigation Societies - 1 - - - 75 76 

Municipalities - - - - 1 6 7 

Political Parties - 1 1 1 2 7 12 

Railways - 1 - - - 2 3 

Trade Unions - 1 - - - 5 6 

Others - - - - 2 225 227 

Total 8 16 6 12 23 468 533 

The MSEB was given an opportunity to file its replies to the objections. 

The Government of Maharashtra, through the Energy Department, on the last day of the 

Public Hearing held at Mumbai on 16 th October 2001, made a submission to permit it to make 



an affidavit and presentation before the Commission in the matter. The request was accepted 

by the Commission and it was allowed to make its presentation on 25.10.2001. On the 

request of the GoM, this date was further extended upto 31.10.2001 and again upto 5 th 

November 2001. The Government of Maharashtra submitted its affidavit on 5 th November 

2001. The Commission held a meeting in this matter on 20 th November 2001, during which 

the request of the GoM was considered and it was permitted to file a further affidavit upto 4 th 

of December 2001. It was also decided to initiate the public hearing procedure in order to 

avoid any ambiguity in the minds of the public. 

The Government had informed the Commission vide its letter No.VNA- 

2001/CR(1624)/NRG-3 dated 25.9.2001 that except in matters relating to subsidy for 

agricultural and power loom consumers, it had no intention of providing subsidy to any other 

consumers and, as such, it did not feel the need to participate in the public hearing 

proceedings. The Commission further observed that, due to the delay on account of the GoM, 

the MSEB is incurring heavy revenue losses, which, in turn, would have its effect on the 

GoM’s finances also. As per the provisions of the ERC Act, 1998, tariff determination is not 

within the ambit of the GoM and, therefore, it cannot issue any directive specifically in the 

matter of tariff determination. Before issuing any such directive, it would be advisable for the 

Government to examine the matter through legal experts. GoM’s attention was drawn to the 

apex court’s judgement in Real Food Products Ltd & Others vs A.P. State Electricity Board 

& Others, which is very relevant in respect of the Commission’s role in the determination of 

electricity tariff. Under the scheme of the ERC Act, 1998, the GoM’s role is confined to that 

of granting subsidy under Section 29(5) of the ERC Act, 1998 which states: 

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 this section, the State 

Government shall pay 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 license or any other 

person concerned to implement the subsidy provided for by the State Government. 

The GoM’s affidavit dated 5 th November 2001 inter alia stated that 

Government of Maharashtra have received representations from public representatives 

pointing out interalia that the tariff as proposed by MSEB are on higher side in respect of 

certain categories of consumers viz. Domestic, Agricultural, Powerloom Streetlight and 

Public Water Works consumers…. 

GoM has taken note of apprehensions expressed by Public Representatives and has come to 

conclusion that the proposed tariff in respect of certain categories of consumers, as 

mentioned above, is indeed on higher side and there may be strong resentment against it by 

public at large which may also lead to some law and order situations. This issue is required 

to be examined in depth as it involves the interest of public at large. 



Therefore, the Commission further observed, it is essential to put the entire affidavit of the 

GoM through the public hearing process or alternatively the GoM should send a copy of its 

affidavit, at its cost, to all the objectors who have participated in the already concluded public 

hearing proceedings / other interested objectors and such objectors should be allowed 

sufficient time to send their rejoinders to the Commission. The Commission, in turn, will 

examine the rejoinders before coming to a conclusion in the matter. This will delay the 

entire process further and the Commission may not be able to release the Order before 

January 2002. The Joint Secretary (Energy), GoM agreed to this suggestion of sending the 

GoM affidavit to all the objectors at its cost. 

The Commission issued a Public Hearing Notice on 2 nd 

December 2001, which was 

published in the Times of India, Maharashtra Times in Mumbai and two prominent local 

newspapers in each of the Revenue Divisions. The Public Hearing was held on 24 th 

December 2001 from 10.30 hrs onwards at World Trade Centre, Mumbai. The Commission 

received in all 240 objections on affidavit in the matter of the GoM’s affidavits dated 5 th 

November 2001 and 3 rd December 2001. [List of objectors at Annexure – II] 

The Commission ensured that the due process contemplated under the law was 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, hereby makes the following tariff order. 

1. The revised tariffs will be applicable from January 1, 2002. The Commission expects that 

the MSEB will not approach the Commission for tariff revision for FY 2002-03. 

2. The MSEB has submitted in the current tariff proposal that it will achieve 100% metering 

for powerlooms by March 2002 and for the LT agricultural category within three years 

from now. The Commission is not fully convinced about the MSEB’s seriousness in 

implementing these targets. The Commission hereby directs the MSEB to achieve the 

metering targets as per schedule. In case there is slippage in the achievement of 

these targets, the Commission will be constrained to take serious action in the 

matter. 

3. The Commission has applied the norm of 1250 hours per HP per annum, as against 1600 

hours in the tariff order of 5th May 2000 to estimate the consumption of un-metered LT 

agricultural consumers. 



4. The Commission notes with satisfaction that the MSEB has initiated the process of 

energy audits. However, the energy audit data submitted by the MSEB shows that it has 

not made appreciable efforts to reduce the T&D losses. 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 areas (Urban, MIDC, Express 

Feeders) range between 25 and 35 percent. The Commission takes serious note of the fact 

that T&D losses in a city like Pune are thrice that of Mumbai. The MSEB is hereby 

directed to carry out intensive energy accounting and auditing for all circles/zones 

and to submit monthly reports along with ‘Action Taken Report’ after fixing 

accountability. 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. 

5. For energy input projections, the Commission has considered the T&D loss level of 

39.49%. With the sales during FY 2001-02 projected by the Commission at 37000 MU, 

the total energy requirement to be met through generation and power purchase is expected 

to be about 61145 MU. 

6. The Commission has approved the total generation and power purchase costs for FY 

2001-02 considering the quantum of actual generation and power purchase for the period 

of April to September 2001 and estimating the generation and power purchase costs from 

October 2001 to March 2002 based on a simulation of merit order dispatch and actual 

average generation and power purchase costs for the period of April to September 01, 

subject to heat rate norms and removal of transit loss component. The Commission has 

considered a reduction of 1% in the stationwise heat rate. 

7. The net generation from MSEB’s own stations as projected by the Commission is 44708 

MU as compared to 44025 MU projected by the MSEB. The Commission has considered 

the generation from Hydel Stations and some of the thermal stations based on the ‘ability 

to generate’ factor. 

8. Considering the actual power purchase from April-September 2001 and the monthwise 

purchase based on merit order scheduling, the total power purchase approved by the 

Commission for FY 2001-02 is 15794 MU, including purchase from TPC, which is 248 

MU higher than that projected by the MSEB. The Commission has increased the quantum 

of power purchase mainly to reduce the load shedding. 

9. The total load shedding for the period of October 2001 to March 2002 as considered by 

the Commission is 398 MU as against 1885 MU projected by the MSEB. The 

Commission directs the MSEB to take all necessary steps to further reduce the load 

shedding in the State. 



10. (a) The Commission has disallowed the pay revision arrears to the extent of Rs. 100 

crore, in line with the previous Order. The MSEB is free to pay the arrears by earning 

additional revenue, through efficiency improvements. 

(b) The Commission is of the view that the MSEB’s consumers have already paid the 

Electricity Duty and it is the responsibility of the MSEB to forward the same to the 

GoM. At the same time, there is no gainsaying the fact that the GoM has delayed 

payment of subsidy and this affects the liquidity of the MSEB. The GoM has clarified 

that it normally adjusts the Electricity Duty against payment of subsidy, and the late 

payment of subsidy was one of the causes of the late payment of Electricity Duty by 

the MSEB. The Commission has, therefore, not allowed this expenditure in the 

revenue requirement of the MSEB for FY 2001-02. 

11. The average security deposit has been considered as current liability and the net working 

capital requirement has been estimated as Rs. 502 crore. Assuming an average interest 

rate of 12.5%, the working capital interest allowable has been projected as Rs. 62.8 crore. 

12. The Commission also directs the MSEB to consider innovative methods such as spot 

billing, opening of more collection centres, voluntary deposit schemes, authorizing 

more agencies such as Lions Club, Rotary Club, etc., to collect payments, to reduce 

the billing and collection cycle, thus improving the cash flows of the MSEB. 

13. The Commission requests the GoM to make a separate budgetary provision for payment 

of electricity bills while drawing up the budgets of the local bodies, as against the existing 

practice of clubbing electricity payments with other miscellaneous expenses. The GoM 

has to either ensure that these payments are made on time, or it should materially and 

morally support the MSEB in its disconnection drives against the local bodies and Mula 

Pravara Electric Co-operative Society. 

14. The Commission also directs the MSEB to disconnect all consumers whose names 

appear in the defaulters’ lists for the second time, and submit the details of the same 

to the Commission along with the copy of the defaulters’ lists. 

15. The Commission has set the MSEB a target for reducing the receivables to an 

equivalent of 5 months of the sales revenue in FY 2001-02 from the existing levels of 

6 month’s equivalent of receivables. 

16. The GoM has recently issued a gazette notification increasing the mandatory surplus to 

4.5% of the Net Fixed Assets at the beginning of the year. The Commission has allowed 

the surplus at the rate of 4.5%, at Rs. 493.18 crore. 

17. 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: 

• Excess T & D loss 

• Revenue earned through FOCA for additional expenses in FY 2001-02 

• Other Income 



18. The MSEB has submitted that the estimated T & D losses are 39.49%. The target for T & 

D losses as set by the Commission by the end of FY 2000-01, was 26.87%, the balance 

losses of 12.6% are thus excess losses vis-à-vis the targets. The losses are equivalent to 

7772 MU of energy input requirement. 

19. The Commission has hence taken a very stringent view of the excessive commercial 

losses and has decided to reduce the allowed revenue requirement of the MSEB 

correspondingly. However, there is no denying the fact that a section of the MSEB’s 

consumers are also partly responsible for the high level of losses. The consumers who 

indulge in connivance/theft of energy are directly responsible, while the honest paying 

consumers who do not raise their voices to complain or are apathetic or look the other 

way are also indirectly responsible for this phenomenon. At the same time, no single 

consumer category can be held responsible for the high level of T& D losses. Taking into 

consideration all these factors and in the context of the socio-economic ethos in which the 

MSEB has to function, it appears to the Commission that the time has now come to 

confront this menace of increasing T & D losses in a more direct manner. 

20. The Commission is of the opinion that the procedure indicated in S.51 of the Bombay 

Police Act, 1951, can be adopted suitably to tackle the existing situation of T & D losses 

in the MSEB serviced areas, and all the consumers are to be held equally responsible. The 

Commission has decided to apportion the cost of this excess loss equally (50% each) to 

the MSEB and the consumers. The cost of the excess losses is the cost of additional 

power purchase required on account of the higher energy input requirement. 

21. The net cost of the excess energy input requirement is Rs.1271.8 crore (7715 MU at an 

average rate of Rs. 1.649 per unit). Thus, the MSEB will have to bear 50% of this amount 

(Rs. 635.9 crore), by way of corresponding reduction in the revenue requirement, while 

the MSEB’s consumers will have to pay the remaining 50% through a special charge. 

22. The Commission has decided to recover this portion of the revenue requirement through a 

new charge called ‘T & D loss Charge’, which will be a variable charge and charged from 

all consumers of the MSEB, except for public utilities and Mula Pravara. This charge will 

be in addition to the Energy Charge and the Demand Charge determined by the 

Commission. The intention of the Commission is to stress upon the consumers that, but 

for this loss, the effective tariffs would have been much lower. The Commission hopes 

that this will provoke the paying consumers to bestir themselves and to rise and act 

against the pilferage of energy by others, through use of moral suasion. It is no secret that 

even earlier the consumers were paying for the higher losses through the energy charge 

and demand charge, but if the charge is levied explicitly, it is expected to come more 

readily to notice and would bring about the desired salutary effect of combating power 

thefts. It is the Commission’s view that there is an urgent need for civil society to bring its 



relentless social pressure to bear upon the power thieves and bring them to heel in the 

shortest possible time. 

23. The Commission has considered the MSEB’s viewpoint that the losses have not actually 

increased from 31.9% to 39.4%, but the losses have been better estimated based on 

improved level of energy audit. Though the Commission desired to set a target for further 

reduction in T & D losses by 4% to 5% in FY 2001-02, it has not done so as a special 

case for this year, considering the special circumstances prevailing and the estimation 

involved in the calculation of T & D losses, in the absence of 100% metering. However, 

the Commission will set targets for future years, with the intention of reaching the CEA 

norms for T & D loss levels of 15% to 16% in 2 to 3 year’s time. 

24. The Commission has found that the MSEB has disregarded its directives on seven counts, 

viz. metering of flat rate consumers, ToD meter installation for HT industrial category, 

provision of name badges, domestic supply to Railways, disconnection of supply to 

consumers for arrears over 75 days, to desist from issue of commercial circulars without 

the prior approval of the Commission, and data on public institutions and ‘Kutir Jyoti’ 

consumers. The Commission has disallowed revenue to the MSEB for the above noncompliance 

at the rate of Rs. 1 crore for each act of non-compliance amounting to Rs. 7 

crore. This amount should be deposited in a special account together with the Energy 

Conservation Fund, discussed subsequently in paragraph number 51. 

25. All the relevant directives issued by the Commission in the previous Tariff Order of 

May 2000 are still applicable, and the MSEB is directed to comply with the same 

before 31 st March 2002. 

26. The Commission has deducted the amount recovered through FOCA for expenses 

incurred in July 2001 from the revenue requirement of FY 2001-02, amounting to Rs. 9.5 

crore. Additional amount recovered by the MSEB through the FOCA formula for increase 

in costs in FY 2001-02 after September 2002, if any, will be adjusted against the FOCA 

recoverable henceforth. 

27. The Commission had issued an Order on December 5, 2001, permitting the MSEB to 

charge FOCA for the period of January to March 2001, amounting to Rs. 127.6 crore, 

over 3 months, starting from December 2001. However, the MSEB has been unable to 

charge the FOCA as the bills for December have already been issued. Hence, to avoid 

confusion, the Commission has included the FOCA amount of Rs. 127.6 crore in the 

Annual Revenue Requirement of FY 2001-02, to be recovered through the revised tariffs. 

However, due to the applicability of the revised tariffs for only 3 months of FY 2001-02, 

the MSEB will be unable to recover the full FOCA amount, by this method. The 

Commission has hence allowed interest at the rate of 12.5% on the balance amount, and 

added it to the net additional revenue to be recovered through revised tariffs. 



28. The net revenue requirement allowed by the Commission for FY 2001-02 is Rs. 11644.4 

crore. The average cost of supply for FY 2001-02 works out to Rs. 3.15 per unit. The 

revenue from existing tariff works out to Rs. 11192.4 crore. Thus, there is an uncovered 

gap of Rs. 452 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. 

452 crore. However, the revised tariffs will be in force for only three months of FY 2001- 

02. Accordingly, the additional revenue recoverable in the remaining three months of FY 

2001-02 with revised tariffs is thus Rs. 119 crore. 

29. The Commission has adopted certain principles, which are in continuation of the process 

of tariff rationalisation initiated in the previous Tariff Order. In general, the movement of 

tariffs towards the average cost of supply has been maintained, such that inter-class crosssubsidy 

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. 

30. The Commission had set metering targets for several categories, including power loom, 

‘C’ Class municipalities, etc., which should have been completed within six months time, 

and the Commission had projected revenue for these categories based on metered tariff in 

the previous Tariff Order. The Commission has maintained the same practice on this 

occasion also, and has also set flat rate tariffs to be charged in the interim period. The flat 

rate tariffs have been set such that the consumers have an incentive to opt for metering. 

31. The Commission has 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 intends to create awareness among the consumers regarding 

the additional cost of the losses by levying this charge in an explicit manner. Hence, a 

more or less uniform T & D loss charge has been levied to start with. However, in the 

next Tariff Order, the Commission intends 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. The Commission is aware that it is unfair that a consumer 

residing in a circle/zone, which has a considerably lower loss level, should pay the same 

T & D loss charge as a consumer residing in a high T & D loss circle/zone. 

32. The Commission directs the MSEB to submit circle/zonal level energy audits for all 

zones on a monthly basis to the Commission, along with the ‘Action Taken Report’ 

for each circle/zone. The Commission intends to levy a ‘circle/zone-wise T & D loss 

Charge’ latest by 1 st October 2002 instead of the across-the-board T&D loss charge. The 

Commission has also not levied the T & D loss charge for public utilities like railways, 



PWW, Street lighting and Mula Pravara Society, as they do not have any incentive to 

pilfer energy. 

33. The MSEB should hold the concerned employees responsible for the T& D losses in the 

respective zones, and the MSEB may consider recovering the T & D loss charge from 

these employees after following due disciplinary procedure. 

34. The Commission has ensured that the tariffs for all subsidised categories (except Rural 

PWW and HT agriculture) are almost equal to 50% of the average cost of supply. 

35. The Commission has attempted to increase the recovery from fixed charges, which 

ranged around 30% of the fixed costs in the existing tariffs, to around 35% 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. 

36. The Commission has also attempted to ensure that the flat rate tariffs are higher than the 

metered tariffs, to act as an incentive for opting for metered tariff, even if it results in a 

reduction in the tariffs for metered category, which is already subsidised. 

37. The Commission had stated in the previous Tariff Order dated May 5, 2000, that it 

intended to create a separate category for single-bulb consumers and retain the tariffs for 

this category at a lower level. Due to the unavailability of reliable data on the number of 

such consumers, the Commission has retained the Fixed Charges for the lowest slab (1-30 

units per month) in domestic category at the same level, while marginally increasing the 

energy charges, to protect this category of consumers. 

38. It is observed from the consumption pattern as well as the projected consumption, that as 

compared to the total industrial consumption (including LT and HT), the consumption of 

the non-domestic category is only around 10%, which most probably does not indicate the 

true picture. In the previous Tariff Order, the Commission had desired to consider 

favourably the plea of the software industry and such other consumers. Keeping in mind 

the above, the Commission has offered optional LTMD based tariff with all its incentives 

and disincentives (ToD, PF incentive, PF penalty, etc.) to the non-domestic category. The 

Commission feels that this will not only result in improving the metering technology but 

also bring in buoyancy in the revenue collection from this category through improved 

metering and billing. This will also help the system by shift of load to the night time offpeak 

hours by those commercial consumers who are operating for 24 hours every day. In 

future, after considering the results of this step, the Commission intends to extend this 

LTMD based tariff to all LT consumers. 

39. The flat rate tariff for HTP-VII (agriculture) has been kept higher than the flat rate for LT 

agriculture, to account for the higher consumption of the HT agriculture category. 

40. The Railway Traction tariff has been adjusted such that the average realisation is lower 

than the average realisation for HTP-I category. 



41. The energy charge to be levied for net sale to the TPC has been reduced to match the 

highest cost of power purchase, i.e., 290 p/u. 

42. The tariffs for the seasonal category have been determined such that these consumers will 

pay a higher demand charge during the specified season, according to the normal billing 

demand definition, and, during the off-season, the minimum billing equivalent to 50% of 

contract demand will not be applicable. 

43. As regards the PWW tariffs, the Commission sees no justification for their tariffs to be 

considerably higher than the average cost of supply, as these are public utilities, and, in 

most cases, do not charge the residents commensurately with the costs incurred. The 

Commission has adjusted the HT PWW tariffs such that the average realisation from 

these categories is almost equal to the average cost of supply. 

44. The Commission has also introduced the two-part tariff regime for hitherto single-part 

tariff categories such as Mula Pravara, Street Lighting and Grampanchayat (Rural PWW). 

45. The Billing Demand definition in case of HT industrial consumers has been modified by 

removing the clause of ‘minimum 50 kVA’. For seasonal consumers, the minimum 

billing demand of 50 kVA will continue to apply, during the off-season. 

46. The Demand Charges in the case of Mula Pravara will be levied on the cumulative 

Maximum Demand at all the 22 points of supply. The average realisation from Mula 

Pravara has been adjusted such that it reaches the average cost of supply in 5 years’ time. 

47. The Commission is of the view that the increase in HTP VI consumers is beneficial to the 

MSEB as the residential/commercial complexes maintain the entire distribution 

infrastructure as well as look after the billing and collection functions. The MSEB has to 

bill only a single consumer and invest in the distribution infrastructure only upto the point 

of main supply to the Complex. With this objective in mind, the Commission has 

designed the tariff for HTP VI category such that the overall average realisation from the 

category reaches the cost of supply, while at the same time ensuring that the residential 

consumers do not have a higher tariff than the domestic category. 

48. The Commission has increased the difference in the ToD rates for peak and off-peak 

times for the HTP-I and HTP-II categories. The Commission has also introduced ToD 

tariff for LTP-G, HTP-III and HTP-IV categories, in line with the direction set by the 

Commission in the previous Tariff Order of May 5, 2000. The ToD tariff for the LTP-G 

category is optional as most of the smaller units such as flour mills and fabrication shops 

may find it difficult to shift their consumption to off-peak hours. 

49. The Commission has also extended the optional LTMD tariff to all LTP-G consumers, 

irrespective of the connected load, as the levy of demand charges on billing demand is 

more scientific than the levy on the connected load, as all the equipment are unlikely to 

be used at the same time, which is reflected by the low load factor of the category. For 

consumers who do not opt for LTMD tariff, the demand charges will be applicable for 



50% of the connected load. The MSEB should bill all consumers supplied at LT level in 

this category as per the LTP-G or LTMD tariff as applicable. 

50. In response to the oft-repeated demand for supply of reliable, uninterrupted power to 

MSEB consumers, similar to the situation prevailing in Greater Mumbai in the license 

areas of the TPC, BEST and the BSES, the Commission has 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 

scheme will be operational with effect from 1 st April 2002. The MSEB should submit to 

the Commission details of consumers belonging to the above categories, to whom the 

MSEB can supply uninterrupted power based on the additional power available without in 

any way changing the load-shedding programme for other classes of consumers. The 

MSEB will impose an additional charge of 25 paise per kWh to these consumers and 

ensure that they get uninterrupted power supply. In any billing cycle, if there is any 

interruption in power supply from the MSEB system to these consumers, this Reliability 

Charge shall not be levied. 

51. The Commission is of the view that the use of energy efficient devices is absolutely 

essential. With this in view, the Commission intends to introduce, with effect from 1 st 

April 2002, a scheme for incentivising such measures in respect of agricultural pumps, 

PWW and street lighting by creating a separate fund, to be known as ‘Energy 

Conservation Fund’ within the MSEB itself to be financed from 2% of electricity charges, 

billed to these consumers. The scheme will be finalised in consultation with MEDA, 

Bureau of Energy Efficiency, New Delhi and selected Industrial Training Institutes in 

Maharashtra. 

52. In order to provide a forum for the consumers and to increase the awareness 

regarding the prevailing T & D losses in the division/circle/zone, the MSEB should 

display the monthly energy accounting data detailing the energy input, billed sales, 

and the T & D losses in the division/circle/zone, on the Notice Board of the office of 

the respective division/circle/zone as well as the collection centres in the area. The 

amount of revenue collected through T & D loss charges from the respective 

division/circle/zone and the name and contact details of the officer responsible for 

the division/circle/zone should also be displayed. The above details should also be 

published in the local newspaper, once every month. The MSEB should inform all 

the public representatives in the area regarding the above details. 

53. 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 Maharashtra Electricity Regulatory Commission, in exercise of the powers vested in it, 

under S.29 of the Electricity Regulatory Commissions Act, 1998 and all other powers 

enabling it in this behalf, determines the tariff for supply of electricity by the Maharashtra 

State Electricity Board for retail distribution as under; 

Table 1: Annual Revenue Requirement for FY 2001-02 in Rs. Crore 

Sl. Expense Head 

MSEB MERC Remarks 

Proposal Approval 

1 Generation 3792.0 3763.1 Reduction despite higher generation, 

due to reduction in heat rate and 

disallowance of transit loss 

2 Power Purchase 2818.0 2950.0 Higher due to higher power purchase 

to reduce load shedding 

3 Operation & Maintenance 672.1 670.2 

4 Employee Costs 1840.0 1703.8 Reduction due to disallowance of 

Rs.100 cr of wage arrears and higher 

capitalization rate 

5 Administration & General 

expenses 

277.6 119.6 Reduction due to disallowance of 

Rs.155 cr of interest on late payment 

of ED to GoM 

6 Depreciation 1544.0 1526.9 Reduction due to average depreciation 

rate being lower 

8 Provision for doubtful debts 200 169.7 Allowed at the rate of 1.5% of revenue 

from sale of electricity 

7 Interest cost 1308.4 1110.4 Reduction in working capital interest 

8 Lease Rental 85.0 85.0 

9 Other Expenses 250.7 254.7 

Total Expenses 12787.8 12353.2 

Add: Surplus 493.2 493.2 

Total Revenue Requirement 13281.0 12846.4 

Reduction in Revenue Requirement 

Excess T & D Loss 635.9 

Revenue earned through 

9.5 

FOCA for FY 2001-02 

Other Income 684.3 

Addition to Revenue Requirement 

FOCA (Jan 01 to March 01) 127.6 

Net Revenue Requirement to 

11644.4 

be recovered through tariffs 

Average Cost of Supply 

3.15 

(Rs./unit) 

Revenue from Existing tariff 11192.4 

Tariff Increase 452.0 



Table 2: Summary of LT Tariff (Effective from January 1 st 2002) 

Consumer Category 

Demand Charge 

(Rs/KVA/month) or 

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

connection per month) 

Energy 

Charge 

(p/u) 

T & D 

loss 

Charge 

(p/u) 

Domestic (LD 1) 

0-30 Units Rs. 20 per service connection 100 10 

31-100 Units Rs. 30 per service connection for 255 

101-300 Units single phase; 

295 

Rs. 75 per service connection for 

Above 300 units 

455 

three phase; 

(only balance 

Additional Fixed charge of Rs. 75 

Units) 

per 10 KW load or part thereof 

above 10 KW load shall be 

payable. 

Non Domestic (LD2) 



410 



500 

three phase; 

(only balance 

Additional Fixed Charge of Rs. 

Units) 

125 per 10 KW load or part thereof 


payable. 

Optional LTMD based Tariff will 

be available for all consumers. 

General Motive Power (LTP-G) – Base Tariff 

0-1000 Units Rs. 60 per HP (Rs. 80.50 per kW) 240 

1001-15000 Units per month for 50% of sanctioned 300 

load; 

15001- above Units 

340 

Optional MD based tariff will be 

(only balance 

available for all consumers, 

Units) 

irrespective of Contract demand, at 

Rs. 220 /KVA/ month 

Optional ToD Tariff $ 

2200 hrs – 0600 hrs 0 -50 

0600 hrs – 0900 hrs 0 

0900 hrs – 1200 hrs 30 

1200 hrs – 1800 hrs 0 

1800 hrs – 2200 hrs 

60 

Powerloom 

Rate* 

Flat 

Rs. 450 per loom per month 0 

20 

30 

25 



Public Water Supply 

Urban P. W. 

Rs. 60 per HP per month 225 0 

Schemes 

Rural P. W. 

Schemes 

Grampanchayat $ Rs. 20 per HP per month 75 

Metered Tariff 

(incl. ‘C’ Class 

Municipal 

Council) $ Rs. 30 per HP per month 140 

Agriculture 

Flat Rate Tariff Rs. 110 per HP per month 0 Rs. 10 per 

HP per 

month 

Metered Tariff Rs. 10 per HP per month 90 10 

(incl. Poultry 

Farms) 

Street Light Tariff 

Notes: 

Grampanchayat & 

Municipal Council 

Municipal 

Corporation 

Rs. 20 per kW per month 

0 

170 0 

* : Flat rate tariff (Rs. per loom per month) for power loom category will be applicable 

during the intervening period till the meters are installed (based on 8 hours working). 

250 

Thereafter, they will be billed at the rates applicable for LTP-G category. 

$ : Optional ToD tariff will be available for all LTP-G consumers, irrespective of 

whether they opt for LTMD based tariff, but provided they have installed ToD meters. 

• Flat rate tariff of Rs. 100 per HP per month will be applicable for Grampanchayats 

and ‘C’ Class Municipal Councils, in the interim period till meters are installed. 

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

monthly based on the FOCA Formula approved by the Commission. 



Summary of HT Tariff Effective from January 1 st 2002 


Demand Charge 

(Rs/KVA/month) 

Energy 

Charge 

(p/u) 

T & D loss 

Charge (p/u) 

HTP – I (Industrial - 

325 285 30 

BMR/PMR) Base Tariff 

HTP – II (Industrial – 

300 280 30 

Others) Base Tariff 

ToD Tariff (for HTP-I & HTP- 

II) 

2200 hrs – 0600 hrs 0 

-75 

0600 hrs – 0900 hrs 0 

0900 hrs – 1200 hrs 50 

1200 hrs – 1800 hrs 0 

1800 hrs – 2200 hrs 

Seasonal Category 350 $ 270 30 

HTP – III (PWW- 

300 265 0 

BMR/PMR) 

HTP – IV (PWW-Others) 250 255 0 

ToD Tariff (for HTP-III & 

HTP-IV) 

2200 hrs – 0600 hrs 0 

-50 

0600 hrs – 0900 hrs 0 

0900 hrs – 1200 hrs 30 

1200 hrs – 1800 hrs 0 

1800 hrs – 2200 hrs 

HTP - V (Railway Traction) 0 415 0 

HTP – VI 

Residential Complex 100 220 20 

Commercial Complex 

HTP VII (Agriculture) 

Flat Rate Tariff 

(Rs/HP/month)** 

90 

60 

350 30 

200 0 Rs. 10 per 

HP per 

month 

10 90 15 

Metered Tariff (incl. Poultry, 

agriculture High tech) 

Tata Power Company 600 $$ 290 0 

Mula Pravara Electric Co-op 

200 150 0 

Society 

Inter State Sale 0 260 



Notes: 

**: Flat rate tariff shall be applicable till the time meters are installed. 

$ : Demand Charges will be applicable as per normal billing demand formula only 

during declared season; for off-season, the clause of minimum 50% of contract 

demand will not be applicable 

$$ : Standby Demand Charges 

• HT Industrial consumers having captive generation facilities synchronised with the 

grid, will pay additional demand charges of Rs. 20 per kVA per month 



Table 3: Tariff Hike for FY 2001-02 

Description MSEB Proposal MERC Approval 

Tariff Increase in Rs. Crore * 1456 452 

Overall Tariff Increase in % * 11% 4% 

* - if revised tariffs were applicable for the entire year 

Incentives and Disincentives 

Incentives 

Power Factor Incentive for HT consumers 

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 T & D loss charge, 

FOCA charge, demand charge, electricity duty) 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. 

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 T & D loss charge, FOCA charge, demand charge, electricity 

duty) for every one million unit consumption above one million unit subject to a maximum of 

5%. For instance, a consumer having a monthly consumption of 2 million units will get a 

rebate of 2%. 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. 



Disincentives 

Power factor Penalty for HT Consumers 

Whenever the average power factor is less than 90%, penal charges shall be levied at the rate 


FOCA charge, demand charge, electricity duty) for each 1% (one percent) fall in the power 

factor below 90%. 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. 

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. 

Meter Rent 

The meter rent has been abolished by the Commission in the previous Tariff Order. The cost 

of the metering equipment shall be recovered from all the prospective consumers (except 

those agricultural consumers having land holding less than 1 hectare, in which case, only 

50% of the cost of meter shall be recovered). In case of existing consumers, the cost of 

metering equipment shall be recovered at the time when the existing meter is replaced, but 

only once in the lifetime of the consumer, except in the case of burnt meters. The recovery of 

cost of meters from existing consumers will be made in the next billing cycle after replacing 

the defective meters. The MSEB should file the rates of meter cost being recovered, for the 

information of the Commission. 

Security Deposit 

The Commission has reduced the amount of security deposit to be recovered by the MSEB to 

an equivalent of average of three months of billing or a billing cycle period, whichever is 

lesser, from the existing levels of billing cycle plus 1 month equivalent of security deposit. 

Thus, the security deposit for HT industrial consumers will be an equivalent of one month’s 

average billing, two months’ average billing for urban domestic consumers, three months’ 

average billing for LT agricultural category, and so on. 

Service Line Charges 

The MSEB should continue to charge Service Line Charges (SLC) as per the guidelines 

prevailing as on 5 th August 1999, i. e. the date the Commission came into existence, till such 

time as the SLC are modified by the Commission. 



Interest on Delayed Payment of Arrears 

The MSEB has repeatedly complained that the defaulting consumers have been using the due 

amount for their working capital purposes, due to the low rates of penal interest prescribed by 

the Commission. Normally, the MSEB is expected to disconnect the consumers for nonpayment 

within a certain period as per the provisions of the relevant Act. The interest on 

arrears is currently chargeable at the rate of 12% per annum. The Commission has, as shown 

in the Table below, revised the rate of interest chargeable on arrears to all consumers to 15%, 

if payment is delayed beyond 3 months from the due date, and to 18%, if payment is delayed 

beyond 6 months. The revised interest rates will be applicable from April 1, 2002. The 

revised interest rates will not be applicable in case of existing agreement or agreements 

entered into before March 31, 2002, for payment of arrears in instalments. The revised 

interest rates chargeable are: 

Sl Delay in Payment (span of months) Interest rate p.a. (%) 

1 Payment made after due date upto three months (0 – 3) 12% 

2 Payment made after three months and before six months 

15% 

(3 – 6) 

3 Payment made after six months (above 6) 18% 

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

COMMISSION 

Public Hearing Procedure 

Mr. R. B. Agarwal said during the public hearing in Amravati that there was no provision 

under the Conduct of Business Regulations (CBR) of the Commission, wherein the objector 

has to take oath to depose before the Commission. He, therefore, refused to take the oath. The 

Shiroli Manufacturers’ Association submitted that as per the CBR of the Commission, the 

MSEB is bound to reply to the objections within two weeks. Also, the petitioner should be 

allowed to cross-examine the MSEB. 

As regards the provision that the MSEB should submit its reply to the petitioner within two 

weeks, the Commission is of the view that the MSEB has earnestly attempted to comply with 

this regulation, and has met the requirements in most of the instances. Considering the short 

time-frame set by the Commission for the public hearings and the huge volume of objections 

received by the MSEB, there were bound to be instances wherein there was some delay in the 

receipt of the replies by the objector. The Commission is of the view that there is no malafide 

intent on the part of the MSEB in delaying the replies. 



Regulation 53 of the CBR of the Commission reads, “The Commission may determine the 

stages, manner, the place, the date and time of the hearing of the matter, as the Commission 

considers appropriate”. The Commission thus has the full authority to set its own procedure 

and has laid down that every person desirous of deposing before the Commission during the 

public hearing has to take an oath, unless he/she is an advocate by profession. Similarly, 

Regulation 54 of the CBR of the Commission gives the Commission the power to decide 

whether any evidence is to be led or not and, if it so directs that the evidence has to be led, 

then the objector could cross-examine the MSEB. 

The same procedure has been followed consistently by the Commission during all the public 

hearings conducted by the Commission since its inception. The Commission hence rejects 

these objections. 

Tariff Regulations and Process Timeframe 

Prayas, Pune, submitted that in order to ensure a smooth and fast decision on the Tariff 

Proposal without compromising transparency and public participation in the regulatory 

process, it is essential to set regulations/guidelines for (a) Data requirement and formats and 

(b) Tariff Revision process time-frame. Prayas added that such guidelines would reduce 

uncertainty in the tariff revision process and would help all stakeholders to effectively 

address various challenges before the sector. The utility would know what data it needs to 

provide and in what form, which would result in substantial reduction in the time required for 

preparation of the proposal and data gathering/synthesis. 

The Commission is of the view that there is merit in the suggestion, and the issuance of data 

requirement and formats as well as detailed guidelines on the tariff determination process and 

time frame, will reduce the uncertainty as well as increase the transparency of the process. 

The Commission intends to issue these guidelines and data formats for all the utilities in the 

State soon. 

Requirement of Audited Data 

Mr. S. R. Paranjape submitted that the MSEB had projected the expenses for FY 2001-02 on 

the basis of unaudited numbers for FY 2000-01, which was incorrect. He submitted that the 

Tariff Proposal for FY 2001-02 should not be processed unless the audited numbers were 

submitted for FY 2000-01. The Vidarbha Chamber of Commerce and Industry also submitted 

that the accounts and data are required to be audited by a competent authority before the 

MSEB approaches the Commission for tariff revision, in the absence of which the 



information submitted by the MSEB is invalid as they are projecting figures based on the 

previous financial year. 

The MSEB, being a public utility, has to follow a certain established procedure in getting its 

Annual Reports audited and approved by the State Legislature. The process takes time, and 

the audited annual reports are usually available only after the passage of one year’s time, after 

the completion of the financial year. Hence, it is not practical to insist that the MSEB should 

submit audited balance sheets for the previous year, along with the Tariff Proposal. The 

MSEB has projected the expenses and revenue based on the audited figures for FY 1999-00 

and the unaudited figures of FY 2000-01, and has submitted the Tariff Proposal on affidavit. 

As explained earlier, the Commission intends to publish guidelines and minimum 

requirements for the submission of a tariff proposal soon. 

Pending Cases in the High Court 

Mr. R. B. Agarwal submitted that the tariff revision of May 2000 as well as all tariff revisions 

implemented since 1992 are under appeal before the Honourable High Court and the 

competent civil court at Khamgaon, respectively, and, as such the matter is subjudice. He has 

added that unless the previous matters are heard and decided finally, revision of tariffs in the 

intermediary period is not justified and the proposal is liable to be rejected on this count also. 

The Commission is of the view that as there is no stay on the hearing by the Commission or 

the tariff revision, ordered by any court in the above proceedings, there is no bar on the 

continuation of the tariff determination process, and has hence rejected this objection. 

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 order of the Commission passed on 28 th 

December 2001. 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 sixteen 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 the year 2001-02. It briefly 

enumerates the tariff issues involved, examines the revenue projections of the MSEB, the 

various cost estimates for the year 2001-02 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 

A&G 

Administration & General 

ABT 

Availability Based Tariff 

AP 

Andhra Pradesh 

APERC Andhra Pradesh Electricity Regulatory Commission 

ARR 

Annual Revenue Requirement 

BEE 

Bureau of Energy Efficiency 

BMR 

Bombay Metropolitan Region 

BSES 

Bombay Suburban Electric Supply 

CAG 

Comptroller And Auditor General 

CAGR Compounded Annual Growth Rate 

CEA 

Central Electricity Authority 

CBR MERC (Conduct of Business) Regulations, 1999 

CERC 

Central Electricity Regulatory Commission 

CII 

Confederation Of Indian Industries 

CIL 

Coal India Limited 

CPP 

Captive Power Project 

DPC 

Dabhol Power Company 

EDP 

Electronic Data Processing 

EHV 

Extra High Voltage 

ERC 

Electricity Regulatory Commissions 

ERC Act Electricity Regulatory Commissions Act, 1998 

ESA Electricity (Supply) Act, 1948 

FC 

Fixed Cost 

FCA 

Fuel Cost Adjustment 

FOCA 

Fuel and Other Cost Adjustment 

GFA 

Gross Fixed Assets 

GoM 

Government of Maharashtra 

HP 

Horse Power 

HT 

High Tension (or High Voltage) 

HTP 

High Tension Power 



Hz 

IEGC 

IPP 

IREDA 

IT 

IWEA 

kcal 

kg 

kV 

kVA 

kW 

kwh 

LD1 

LD2 

LDC 

LIS 

LNG 

LS 

LT 

LTMD 

LTP-G 

MD 

MEDA 

MIDC 

MkCal 

MMP 

MOD 

MSEB 

MU 

Mula Pravara 

MVA 

MW 

NFA 

Hertz 

Indian Electricity Grid Code 

Independent Power Producer 

Indian Renewable Energy Development Agency 

Information Technology Section 

Indian Wind Energy Association 

Kilo Calories 

Kilograms 

Kilo Volt 

Kilo Volt Ampere 

Kilo Watt 

Kilo Watt Hour 

Residential or Domestic LT category 

Non-Domestic LT category 

Load Despatch Centre 

Lift Irrigation System 

Liquefied Natural Gas 

Load Shedding 

Low Tension (or Low Voltage) 

Low Tension Maximum Demand based Metered Tariff 

Low Tension Motive Power Group – General Motive Power 

Maximum Demand 

Maharashtra Energy Development Agency 

Maharashtra Industrial Development Corporation 

Million Kilo Calories 

Master Metering Plan 

Merit Order Dispatch 

Maharashtra State Electricity Board 

Million Units (million kWh) 

Mula Pravara Electricity Co-operative Society 

Mega Volt Ampere 

Mega Watts 

Net Fixed Assets 



NPC 

NTC 

NTPC 

O&M 

OLC 

PD 

PFC 

PLF 

PMR 

PPA 

PWW 

REC 

REDAM 

ROR 

RR 

SERC 

SLC 

SSI 

T&D 

TPC 

ToD 

TPS 

VC 

WTO 

Nuclear Power Corporation 

National Textile Corporation 

National Thermal Power Corporation 

Operation & Maintenance 

On Line Capacity 

Permanently Disconnected 

Power Finance Corporation 

Plant Load Factor 

Pune Metropolitan Region 

Power Purchase Agreement 

Public Water Works 

Rural Electrification Corporation, New Delhi 

Renewable Energy Developers Association of Maharashtra 

Rate of Return 

Revenue Requirement 

State Electricity Regulatory Commission 

Service Line Charges 

Small Scale Industry 

Transmission & Distribution 

Tata Power Company 

Time-Of-Day 

Thermal Power Station 

Variable Cost 

World Trade Organization 



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

COMMISSION’S RULING 

1 TARIFF DESIGN AND RATES....................................................................................31 

1.1 INDUSTRY TARIFF........................................................................................................31 

1.2 SEASONAL CONSUMPTION...........................................................................................33 

1.3 DIFFERENTIATION BASED ON LOCATION......................................................................35 

1.4 FUEL AND OTHER COSTS ADJUSTMENT (FOCA).........................................................36 

1.5 POWER LOOM TARIFF..................................................................................................37 

1.6 AGRICULTURE .............................................................................................................38 

1.7 RAILWAY TRACTION ...................................................................................................40 

1.8 DOMESTIC POWER SUPPLY TO RAILWAYS....................................................................41 

1.9 RESIDENTIAL COMPLEXES ATTACHED TO HT INDUSTRY .............................................42 

1.10 OTHER CATEGORIES.....................................................................................................42 

1.11 MULA PRAVARA ELECTRIC CO-OPERATIVE SOCIETY (MPECS) TARIFF .....................43 

2 TARIFF PHILOSOPHY ................................................................................................45 

2.1 GUIDELINES.................................................................................................................45 

2.2 COST OF SUPPLY/CROSS SUBSIDY................................................................................46 

2.3 SUBSIDY ......................................................................................................................48 

2.4 TIME OF DAY (TOD) TARIFFS.......................................................................................48 

2.5 OTHERS .......................................................................................................................49 

3 TARIFF SETTING PROCEDURE...............................................................................52 

4 TRANSMISSION & DISTRIBUTION LOSSES.........................................................53 

5 REVENUE/REVENUE ARREARS ..............................................................................58 

6 QUALITY OF SUPPLY/SERVICE ..............................................................................60 

7 POWER PURCHASE AND GENERATION...............................................................63 

8 EXPENDITURE..............................................................................................................65 

9 INFORMATION SYSTEMS/METERING ..................................................................69 

Index 28


10 REBATES/INCENTIVES...........................................................................................72 

11 SECURITY DEPOSIT (SD)........................................................................................73 

12 SERVICE LINE CHARGES (SLC)...........................................................................75 

13 CAPTIVE POWER POLICY.....................................................................................76 

14 POLICY FOR RENEWABLE ENERGY SOURCES..............................................77 

15 DEMAND SIDE MANAGEMENT (DSM) ...............................................................79 

16 DATA DISCREPANCY/INSUFFICIENCY .............................................................79 

17 NON-COMPLIANCE WITH COMMISSION DIRECTIVES ...............................81 

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

PROPOSAL 

18 APPLICABILITY OF TARIFF REVISION FOR REMAINING PART OF THE 

YEAR ......................................................................................................................................84 

19 REGULATORY ASSET .............................................................................................86 

20 AVERAGE COST OF SUPPLY.................................................................................87 

21 GOVERNMENT OF MAHARASHTRA SUBSIDY................................................87 

21.1 GOM ROLE IN TARIFF DETERMINATION PROCESS.......................................................90 

21.2 TARIFFS PROPOSED BY THE GOM................................................................................91 

21.3 OTHER ISSUES IN GOM SUBSIDY.................................................................................92 

22 CROSS-SUBSIDY REDUCTION ..............................................................................93 

23 RATIONALIZATION OF CATEGORIES ..............................................................94 

24 TIME OF THE DAY TARIFF ...................................................................................94 

25 METERING .................................................................................................................95 

Index 29


26 STATUS OF REFORMS ............................................................................................96 

26.1 NON-COMPLIANCE OF COMMISSION’S DIRECTIVES .....................................................96 

27 PROJECTED ENERGY INPUT REQUIREMENT ................................................98 

27.1 SALES PROJECTIONS ....................................................................................................99 

27.2 ENERGY AUDIT ANALYSIS AND TRANSMISSION & DISTRIBUTION LOSSES................106 

27.3 ENERGY INPUT REQUIREMENT ..................................................................................126 

28 EXPENDITURE PROJECTIONS...........................................................................126 

28.1 GENERATION AND POWER PURCHASE COSTS ............................................................127 

28.2 OTHER HEADS OF EXPENDITURE ...............................................................................145 

28.3 ANNUAL REVENUE REQUIREMENT ............................................................................153 

29 REDUCTION IN ANNUAL REVENUE REQUIREMENT .................................155 

29.1 EXCESS T & D LOSS..................................................................................................155 

29.2 REVENUE EARNED THROUGH FOCA.........................................................................164 

29.3 OTHER INCOME .........................................................................................................165 

29.4 ADDITION TO THE ANNUAL REVENUE REQUIREMENT ...............................................165 

30 TARIFF DESIGN PRINCIPLES .............................................................................166 

30.1 ENERGY CONSERVATION...........................................................................................171 

30.2 RELIABILITY CHARGE - CONCEPT ..................................................................174 

31 REVENUE PROJECTIONS.....................................................................................182 

32 TARIFF HIKE FOR FY 2001-02 .............................................................................182 

33 INCENTIVES AND DISINCENTIVES ..................................................................184 

33.1 INCENTIVES ...............................................................................................................184 

33.2 DISINCENTIVES..........................................................................................................184 

33.3 OTHER CHARGES.......................................................................................................184 

34 ANNEXURE I 

35 ANNEXURE II 

Index 30


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

COMMISSION RULING 

1 TARIFF DESIGN AND RATES 

1.1 Industry Tariff 

The industrial sector has represented against the tariff revision proposal of the MSEB citing 

the ongoing global recession. They have contended that the proposed tariff hike would cause 

undue hardship to the sector and would render their products non-competitive. The proposed 

increase in fixed charges would particularly be detrimental to the smaller industrial units. The 

steel industry, while opposing the increase of maximum demand charges proposed by the 

MSEB, has contended that it cannot survive without reasonable electricity rates in the State. 

They have further stated that the load factor of the steel industry being less than 50%, the 

average per unit cost is higher because of high maximum demand (MD) charges. This makes 

it impossible for them to avail of incentives for power factor and bulk consumption. They 

suggest a pragmatic approach in framing tariffs for HT bulk consumers consuming at extra 

high voltages (EHV). 

Indian Seamless Steel has argued that the EHT consumer invests a significant amount of 

capital in laying infrastructure to receive supply, and hence the maximum demand charges for 

a consumer should also be proportional to the assets created by MSEB for the consumer. 

Industry associations have contended that the demand charges should be based on the 

maximum demand recorded during the peak hours. Further, they have suggested that instead 

of using the MD recorded over the past 11 months as the basis for determining billing 

demand, actual monthly MD or 50% of contract demand should be considered. Another LT 

industrial objector has stated that since connected load does not lead to consumption of 

energy, the fixed charges should be based on Maximum Demand. He further stated that 

MSEB only loses revenue by imposing the sanctioned load criteria on the consumer and 

forcing him to physically disconnect any of his equipment. 

One small-scale industry has objected to being billed for July 2000 to May 2001 at a higher 

rate of 81 kVA due to a one-time additional consumption during the month of June 2000 on 

account of welding jobs undertaken by the civil contractor for building extension, despite the 

average load always being lower than 50kVA. The objector has requested the Commission to 

issue guidelines to the MSEB to the effect that before raising such additional demand 

charges, energy consumption pattern of the industrial unit be reviewed with a view to 

understanding genuine and occasional infrastructural requirements as well as unevenness, if 

Objections Received & 

Commission’s Ruling 

31


any, in the past records pertaining to routine manufacturing operations. The MIDC Industries 

Association have also raised a similar concern. 

Another objector has pointed out that, with the current tariff proposal, a HT industrial 

consumer at certain consumption levels would pay nearly 100% more than a similar 

consumer falling in LTPG category. While supporting the tariff level prevalent currently for 

LTPG, he has argued that this is not only against the stated philosophy of the MSEB to align 

the tariffs with costs, but would also lead to migration of HT consumers to LTPG category or 

would give rise to opportunities for collusion. 

Several objectors have objected to the MSEB’s proposal of rationalizing the HT categories, 

as a consequence of which the tariff differential between HTP-II and HTP-I consumers would 

be eliminated, and the reduction in HTP-II tariffs would be lower. They have requested the 

Commission to maintain the tariff differential between HTP-II and HTP-I, as the quality of 

supply was poorer and continuous supply is also not assured for HTP-II consumers. 

The MSEB has responded that the monthly bill for HTP-II category will also reduce 

substantially, as detailed in the comparison of the bills before and after tariff revision. The 

number of categories has been reduced with the view to rationalizing the tariff categories and 

in line with the movement towards the average Cost of Supply. 

The Commission has already commenced the process of reducing the cross-subsidy burden of 

HT industry in the previous Tariff Order of 5 th May 2000. The Commission is aware of the 

problems faced by the industrial consumers and has taken due care while framing the tariffs. 

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 cost of supply. 

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

recently commissioned a study to determine the voltage-wise cost of supply. The findings of 

the study will be publicized and the consumers’ opinions will be sought. After the finalization 

of the Discussion Paper, the Commission will determine the relationship of the tariffs in 

relation to the cost incurred at the respective supply voltages. 

The Commission would like to educate the consumers about the levy of fixed / demand 

charges. There seems to be a misconception in the consumers’ minds that the fixed/demand 

charges are levied to recover the capital expenditure incurred to supply electricity to the 

consumers. The consumers have to appreciate the fact that 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 



32


fixed in nature and the ratio of fixed to variable costs currently stands at 53:47. The consumer 

can access electricity at the flick of a switch any time he desires; however, the MSEB’s 

infrastructure (physical as well as employees, administration, etc.) have to be permanently 

available, and this thus comprises the fixed costs of the MSEB. 

The Commission has initiated the process of levying a part of the charges to the consumers as 

fixed charges to recover a part of these fixed costs in accordance with the cost structure and 

to safeguard the MSEB from steep fluctuations in revenue with varying consumption over 

time. However, the fixed charges levied were nominal and, through this tariff order, the 

Commission intends to further reduce this gap through incremental increase in fixed charges 

between the fixed costs and recovery. The Commission intends to continue this process till 

the problem of variability of revenues of MSEB is fully addressed. 

As regards the definition of Billing Demand, the Commission had ordered, in the previous 

Tariff Order, that the Maximum Demand (MD) recorded in the past 11 months would be one 

of the parameters. Subsequently, in the Review Order dated December 13, 2000, the 

Commission had decided that there should be no continuous penalty on the consumers who 

have exceeded the contract demand during the period of 11 months prior to May 1, 2000, 

from this provision. The Commission is of the view that the problems related to the 

continuous billing for 11 months on the higher billing demand has arisen because of lack of 

awareness among the consumers. Similar provisions exist for the Demand Charges levied by 

other utilities operating in Maharashtra, viz., BSES, BEST and the TPC. However, the 

Commission is of the view that the minimum billing demand of 50 kVA may not give the 

smaller industrial units any incentive to control their demand. Hence, the Commission has 

modified the existing formula for Billing Demand for HT industrial consumers, by removing 

the clause of ‘minimum 50 kVA’. 

As regards the merging of the categories proposed by the MSEB, the Commission is of the 

view that, though rationalization of tariff categories is required, such a drastic reduction in 

categories will be counter-productive. Hence, the Commission has reduced the number of 

categories and slabs to a lower extent than that proposed by the MSEB. The Commission has 

retained the HTP-I and HTP-II categories, with higher tariff for HTP-I category. 

1.2 Seasonal Consumption 

Cotton ginning and pressing industries have protested the merger of HT categories of I, II, III, 

IV and V on the ground that this would abolish the concept of seasonal consumer and will 

cause considerable hardship and deterioration in the financial situation of these consumers. 

They have also requested the Commission to consider both demand and energy charges to 



33


compute the minimum annual demand charges as practised by the MSEB before May 2000. 

Another objector has argued that the cotton and ginning factories do not work for more than 

100 days in a year, and the annual minimum demand charges should therefore be one-third of 

that fixed for the whole year or lower instead of half, as fixed by the Commission for 

seasonal consumers vide its order dated 13 th December 2000. 

It has also been represented that the annual demand charges should be computed only once 

annually rather than half-yearly, as is the prevailing practice. They have further contended 

that the demand charges are fixed on the assumption of uninterrupted power supply to the 

consumer at appropriate voltage and frequency; therefore, the low voltage and load shedding 

hours should be proportionately deducted from the monthly demand charges. They have 

added that the Time-of-Day (ToD) tariff pre-supposes uninterrupted supply of electricity and 

the MSEB should not resort to load shedding and, at the same time, charge a premium for 

peak hour consumption. Some objectors said that the payment of Maximum Demand charges 

during the period of maintenance and during the off-season period for seasonal consumers, 

should be waived. 

The representative of the Motilal Hirakhan Ginning & Pressing Industries said during the 

public hearing that the ginning and pressing industries have no control over the procurement 

of cotton, and the capacity utilization has reached very low levels. He requested the 

Commission to consider a reduction in the fixed demand charges for seasonal consumers and, 

if required, the variable energy charges could be increased. 

The MSEB has responded that no separate categorization for seasonal consumers has been 

envisaged in the Tariff Proposal. The number of categories has been reduced with the view to 

rationalizing the tariff categories and in line with the movement towards the average Cost of 

Supply. 

The Commission has dealt with the issue of seasonal consumption at length in the Review 

Order dated December 13, 2000. The Commission has retained the Seasonal Category of 

consumers while determining the tariff. However, keeping in mind the petitions received 

from the seasonal consumers, the Commission has decided to reduce the demand charges and 

increase the energy charges for this category. As regards the objection that the low voltage 

and load shedding hours should be deducted from the monthly demand charges, the 

Commission has already explained that the demand charges are levied to recover the fixed 

costs of the MSEB, and, therefore, there cannot be any reduction in relation to the load 

shedding and low voltage hours. 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 



34


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 commissioned a study to evaluate and determine performance 

benchmarks for various operational parameters for the utilities in the State. Based on the 

findings of the study, the Commission will set the performance benchmarks to be achieved by 

the utilities including the MSEB with related rewards/penalties for achieving the same. 

1.3 Differentiation based on Location 

The Vidarbha Chamber of Commerce and Industry has suggested that tariffs for HT and 

LTP-G consumers be divided into three categories in the order of their development as 

developed regions, moderately developed regions and backward regions, with lower tariffs 

for less developed regions to boost industrial activity in such areas. At the public hearing, the 

objector also complained about the acute discrimination in load shedding practised by the 

MSEB between Mumbai/Pune and other less-developed areas, despite the same tariffs being 

proposed for the two regions. 

The objector also stated during the hearing that it is not understood whether the fixed charges 

are for asset maintenance or for capital recovery. He requested for information regarding the 

rationale and basis for the levy of fixed charges. Vidarbha Industries Association has 

contended that the demand charges should be proportionately reduced based on the 

availability of supply to the consumer in a month considering frequent breakdowns, 

shutdowns and load shedding by MSEB. The All India Association of Industries has stated 

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 and must be provided relief to boost their commercial 

viability. One of the industrial objectors has contended that the MSEB is selling surplus 

power to other States at Rs. 2/kWh, thereby helping revival of industries in other States at the 

cost of industries in Maharashtra. 

MSEB Response 

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

tariff order that the consumers located near pit head sites should not be charged lower rates 

than those situated farther away. The MSEB has added that 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 on equality basis 



35


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. 

The ERC Act empowers the Commission to differentiate between consumers on the basis of 

their location. At the same time, industries that have been set up in backward regions have 

taken into account the sales tax and other incentives announced from time to time by the State 

Government. The Commission has decided not to introduce lower tariffs for selected regions, 

as this can give rise for similar demands from other regions as well. However, the 

Commission has decided to retain the HT-I and HT-II categories, with higher tariffs for HT-I 

category. 

1.4 Fuel and Other Costs Adjustment (FOCA) 

Mahalaxmi Ispat has demanded the rationale for levying FOCA charges, its calculation 

methodology and the authority of the MSEB to levy such charges for prior-period 

consumption. They have alleged that the MSEB is misusing its monopoly situation to charge 

abruptly. Another objector has suggested merging of prevailing FOCA with the energy 

charge in the new tariffs to enable separate FOCA determination for the subsequent periods, 

and the MSEB to be directed to take meter readings of every consumer a day prior to the 

enforcement of new tariffs. During the public hearing, one industrial consumer objected to 

the levy of FOCA for expenses incurred during May to December 2000, to his unit, though 

the unit got MSEB connection only in February 2001. The Tarapur Industries Association 

has contended that the imposition of FOCA, which is uncertain, makes the cost evaluation of 

the product difficult. 

The MSEB has said that the FOCA is being charged to the consumers as per the 

Commission’s Order dated July 31, 2001. 

The Commission had issued the FOCA Order on July 31, 2001 after a public hearing, 

wherein the MSEB was allowed to charge FOCA of 12 p/u for three months for the additional 

cost incurred during the period May to December 2000. The Commission had also issued a 

Formula by which the MSEB could recover the FOCA expenses incurred from January 2001 

onwards. The MSEB was directed to submit the calculations of FOCA charged to the 

consumers every month. As regards the levy of FOCA on account of expenses incurred 

before the consumer entered the system, the Commission had taken the decision on the basis 

of practicality, as it is almost impossible to charge the consumer on the basis of when he 



36


entered the system, in the absence of a centralized, comprehensive, electronic database of 

existing and new consumers in a particular year. As the Commission pointed out during the 

public hearing, by the same token, the units who are no longer the MSEB’s consumers would 

not be charged FOCA for the period when they were MSEB’s consumers. 

1.5 Power Loom Tariff 

The power-loom associations have strongly submitted that the situation in the textile industry 

is already bleak because of the recession and the proposal of levying Rs. 2/kWh from them 

would be unaffordable and requested the Commission to reduce their tariff to Re.1 per unit. 

They have added that the tariff hike proposed for the power-loom category exceeds 100% for 

both metered and un-metered categories, though the overall tariff hike appears lower at 19%. 

During the public hearing at Mumbai, the representative of the Vita Yantramagh Audhyogik 

Sangh said that the power loom tariff should be only Re. 1 per unit, in line with the tariff 

existing in Madhya Pradesh, to enable the power looms to compete on even terms. He also 

added that the demand charges of Rs. 60 per HP for metered consumers should either be 

scrapped or reduced to Rs. 30 per HP. Moreover, till 100% metering is achieved, the dual 

tariff should not be implemented, and only flat rate tariff of Rs. 250 per HP should be 

charged. 

While protesting the penal system sought to be introduced on un-metered power loom 

category through imposition of higher tariffs (as compared to metered category) as 

unconventional and illogical, they argue that the proposed tariff hike is contrary to the 

guidelines and orders issued by the Government of Maharashtra and also against the directive 

principles of State policy that provides for measures for encouraging and uplifting small scale 

industries. During the public hearings, Advocate Nyaz Ahmed Lodhi, representing power 

loom consumers, quoted S. 49 of the ESA, wherein it is stated that no ‘undue preference’ 

should be given to any person. He contended that the MSEB’s proposal to charge a higher 

tariff for un-metered category as compared to metered category amounted to showing ‘undue 

preference’ for the metered category, and was illegal. 

The objectors have said that the hike proposed for un-metered power loom category is nearly 

200% and is unjust, arbitrary and unfair. Further, they argue that metered tariff increases 

corruption and the consumers are constantly harassed by the Vigilance Department and the 

Flying Squad for supposedly indulging in mal-practices. 

The MSEB has submitted that it has faced enormous difficulty in converting unmetered 

power-loom consumers to metered consumers as the existing tariff structure for unmetered 



37


consumption is lower than that for metered consumption. The MSEB has further submitted 

that a penal flat tariff is essential to act as a disincentive. The MSEB has also denied the 

allegation that introduction of metering would increase corruption. 

The Commission is of the opinion that the MSEB’s strategy for converting flat rate 

consumers to metered consumers is sound, and is based on economic principles of 

incentives/disincentives. The Commission has incorporated the same methodology while 

determining the tariffs for un-metered categories. In the case of power loom category, the 

Commission had abolished the un-metered category in the previous Tariff Order itself, and 

the revenue was projected on the basis of metered tariffs. The flat rate tariffs were to be 

applicable only in the interim period, before the installation of meters. The Commission has 

applied the same methodology in this Tariff Order also. 

The argument of ‘undue preference’ for metered consumers, put forth by the power loom 

consumers is incorrect, as by this logic, for all these years, the un-metered consumers were 

the beneficiaries as the metered tariff has always been higher than that charged to flat rate 

consumers. As regards the allegedly huge increase in tariff, the Commission would like to 

inform the consumers that the hike depends on the overall revenue requirement approved by 

the Commission as well as the level of the base tariffs. 

The power loom consumers will appreciate that their tariffs are much lower than the cost 

incurred to serve them. The Commission is bound by the provisions of the ERC Act to ensure 

the interests of the consumers while maintaining the financial viability of the service 

provider. The Commission progressively intends to improve the efficiency parameters of the 

MSEB so as to enable it to provide its services at the lowest cost, while simultaneously 

moving the tariffs for various consumer categories towards their cost of supply. 

1.6 Agriculture 

The proposed tariff hike is exorbitantly high varying from 250% to 450% for all categories of 

agriculture consumers. For LT & HT Metered consumers, it amounts to 750% for demand 

charge & 750% for energy charge, whereas for LT & HT Unmetered consumers, it varies 

from 191% to 447%. 

Mr. Sambhajirao Kharade, Vice Chairman of Vasantdada Shetkari Sahakari Sakhar Karkhana 

Ltd., has argued that HP based tariff slabs and structure is not appropriate as capacity of the 

pump is dependent on distance between farm land & water source, required head to lift water, 

and higher capacity pump does not necessarily mean higher cultivation and consumption. He 



38


further argued that if the MSEB wishes to discontinue the Flat rate tariff system, they should 

have proposed outright termination of this Flat rate system, but proposing tariff structure that 

favors Metered Tariff against Flat rate tariff is a non-professional approach and appears to 

have ulterior motives. He has also claimed that it has caused grave injustice to farmers. 

Further, he suggested that tariff rates for metered category need to be determined only after 

consulting farmers’ representative body, co-operative societies processing farm produce and 

other social organizations and, once determined, should be valid for the next five years. 

An agriculturists’ association from Jalgaon has protested against the installation of meters for 

agricultural pump sets and the introduction of metered tariffs instead of HP based tariffs, and 

has pleaded to the Commission to stay the increase in tariffs at least for another year. They 

have stated that provision of electricity to farmers should be free as prevailing for the past 20- 

25 years. They have further objected to the heavy and intermittent load shedding undertaken 

by the MSEB that leads to significant increase in the repair and maintenance of the pumpsets. 

The MSEB has submitted that it has faced tremendous resistance in its meterisation 

programme, and has hence proposed to set the flat rate tariffs higher than the metered tariffs, 

so that the consumers have an economic incentive to shift to metered consumption. The 

MSEB has added that heavy subsidy distorts efficiency incentives, and despite the subsidies, 

the arrears from this category has increased steadily to over Rs. 1500 crore. The MSEB has 

further added that it is the State Government’s responsibility to provide the subsidy. The 

MSEB has also referred to the Chief Ministers’ Conference convened by the Prime Minister 

of India, which had agreed that the agricultural tariffs should be at least 50% of the cost of 

supply, and should reflect costs over time. The MSEB is of the view that the move towards 

the cost of supply has to be much faster than that proposed by the Commission and has 

proposed to set flat rate agricultural tariffs such that the average realization is approximately 

82% of the cost of supply. 

The objector’s argument that the pump capacity depends on the distance from the source of 

water and required head to lift the water, is correct, and the Commission has eliminated the 

slabs and the same flat rate tariff per HP will be applicable to all LT agricultural consumers, 

irrespective of the connected load rating of the pump. As regards the differential between flat 

rate tariff and metered tariff, the Commission has already given its ruling earlier. The 

Commission is of the view that all consumption should be metered and had directed the 

MSEB accordingly in its previous Tariff Order. 



39


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 

previous Tariff Order. The move towards the average cost of supply has been continued in 

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

The Commission would also like to inform the consumers that it has recently commissioned a 

study to determine the consumption of electricity by the agricultural sector and the cost of 

electricity in the overall agricultural cost of production as well as the economics of the 

agricultural sector. The findings of this study will be publicized and comments invited from 

consumers and consumer representatives. Based on the comments and discussions, the 

Discussion Paper will be finalized, and, thereafter, the Commission will incorporate the 

findings for determining the agricultural tariff in its future Tariff Orders. 

1.7 Railway Traction 

The Railways have argued that the unreasonably high traction tariff makes the operation of 

electric traction costlier than diesel, which is not in the national and environmental interest. 

They further argue that while the MSEB has proposed reduced tariffs for other HT 

consumers, no such reduction has been proposed for the Railways. They have stated that this 

treatment has been meted out despite a favorable observation of the Commission in its last 

order dated May 5, 2000 about the need for a drastic reduction in Railway tariffs. 

The Railways have quoted Article 287 of the Constitution stating that prices charged to the 

Railways should be less than that charged to other bulk consumers. They have also stated that 

the Public Accounts Committee of the 9 th Lok Sabha has underlined the importance of 

provision of electricity to the Railways at reasonable prices. The Railways have also brought 

to the attention of the Commission the UPERC order for FY 2002, wherein, the Commission 

has acted upon the appeals of the Railways and has reduced charges by 23 p/kWh. 

The MSEB has submitted that the tariff for the Railways cannot be compared with that of the 

other HT consumers, as for other HT consumers, it is a two-part tariff as against a single part 

tariff for the Railways. The MSEB has further stated that the demand from the Railways is 

not consistent and has huge fluctuations leading to poor quality of power and harmonic 

distortions in the power flow of the system. The MSEB has argued that the tariffs for the 

Railways have still been kept at the same level. It has further submitted that the Maharashtra 

State grid is being treated as a single unit and its resources from one part of the State is 

pooled and used in other parts of the State. The MSEB has stated that setting tariffs 

progressively reflecting cost of supply to different categories would only be achieved over 

time and, at present, a large number of consumers are not even paying the average cost of 



40


supply. In addition, allocating costs to consumers based on voltage levels would be a 

complex cost allocation exercise of academic interest only considering the implementation 

difficulty at existing tariff levels. 

On the incentive for prompt payment, the MSEB has replied that it has not considered any 

discount, as it would affect its revenues. It argued that the penalty for delayed payment is a 

deterrent, and, therefore, there is an in-built incentive for timely payment. Providing rebate 

would result in reversing the tariff structure with an assumed level of surcharge included in 

the tariff, with a rebate for prompt payment. 

The MSEB has also submitted that comparison of tariffs with other States in isolation would 

not be proper since determination of tariffs inter-alia depends upon many factors of the State 

like generation mix available, consumer mix, socio-economic conditions, geographical 

situation and others that are bound to vary across States. 

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

through its previous Tariff Order, and has continued the process in this Order also. The 

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

the average Cost of Supply. A prompt payment incentive also has been introduced at a rate of 

0.5% of the bill amount, and the Railways can avail of the incentive. A further 0.5% of bulk 

discount shall also be available to the Railways as per the conditions. The Commission has 

also commissioned a study to estimate the voltage-wise cost of supply in the State of 

Maharashtra as mentioned earlier. The findings of the study would be utilized for structuring 

the tariffs suitably for different consumer categories. 

1.8 Domestic power supply to Railways 

The Railways have stated that the Commission vide its Tariff Order dated May 5, 2000 had 

advised the MSEB to ensure electricity supply at domestic rates for the Railways’ residential 

quarters. However, despite repeated representations to the MSEB on the issue, no action has 

been initiated by the MSEB. They have further requested the Commission to allow domestic 

consumption of Railways to be billed as per consumption by each quarter per month at 

domestic rates instead of non-domestic rates as is being done presently. They have argued 

that the practice is discriminatory for the Railways’ domestic consumers and the Railways 

incur substantial costs in laying down the LT network, complaint handling, billing, etc. They 

have pled to the Commission to direct the MSEB to take over the function of meter sealing, 

reading and billing so as to extend the benefits of domestic category applicable to Railways 

domestic consumers as well. 



41


The MSEB has submitted that the necessary Circular has been issued to its offices to 

implement separate metering for the domestic load of the Railways. 

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

Commission’s Order, and would like the MSEB to note that mere issuance of a Circular is 

not enough. Non-implementation of the Commission’s directive shall be treated as noncompliance. 

The Commission hereby directs the MSEB to submit a compliance report 

regarding the progress of metering for separately capturing the consumption of railway 

domestic consumers and steps taken to enable separate billing of such consumers by 31 st 

March 2002. 

1.9 Residential complexes attached to HT industry 

The objectors have stated that the MSEB has proposed to increase MD as well as energy 

charges for HT complexes. They have requested that the MSEB should instead take over the 

infrastructure for supplying such domestic load and independently bill each consumer or else 

the MD charge should not be levied. 

The MSEB has submitted that the number of categories has been reduced with a view to 

rationalizing the tariff categories and in line with the movement towards the average Cost of 

Supply. As a consequence, the impact of the revised tariff is bound to vary from one 

consumer category to another. 

The Commission has kept this issue in mind while determining the tariff for residential 

complexes attached to HT industry. 

1.10 Other categories 

An industry association has questioned the rationale for providing special tariff for poultry 

farms, power looms, HT agricultural consumers, etc. The Pune Chapter of Cost Accountants 

has questioned the creation of a separate class for unmetered LT agricultural as 

discriminatory. Similarly, it has contended that the increase of fixed charges for LT-1 

consumers has been proposed without any justification for the method of apportionment of 

fixed expenses amongst consumer categories. The Akhil Bhartiya Grahak Panchayat has 

suggested that there should be at least 2 to 3 slabs for LD-1 and LD-2 with at least 100 units 

consumption for the lowest slab. It has also opposed the increase in fixed charges for the 



42


category. During the public hearings, several consumers objected to the increase in fixed 

charges for LTP-G category from Rs. 60 per HP/month to Rs. 75 per HP/month. 

The Dasha Srimali Arogya Bhavan Trust has requested the Commission to allow charitable 

trusts to receive power supply at LT, irrespective of connected load, upto 50 kVA. It has also 

requested the Commission to determine an appropriate tariff exclusively applicable to 

charitable trusts in line with the Commission’s intention to do so vide its Tariff Order dated 

May 5, 2000. 

Several objectors have protested against the tariff proposed for LTPG consumers, which 

favours only large consumers. It has been argued that such a proposal is not even in the 

interest of the MSEB in the face of decreasing industrial consumption. Others have opposed 

the increase in fixed charges for the category and have suggested 3 slabs for the category with 

400 units and 1000 units as the first two slabs. 

One objector has suggested that the first domestic slab should be raised to 200 units instead 

of 30 units as proposed. It has also been represented that the proposed MSEB tariffs are 

higher than that prevailing in other States and those charged by the Tata Power Company 

(TPC). 

1.11 Mula Pravara Electric Co-operative Society (MPECS) Tariff 

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

3.40/kWh proposed by the MSEB for the Society. The MPECS has submitted that 80% of its 

consumers are from the agricultural category, and, as the MSEB tariff is applicable to its 

consumers also, it is not in a position to pay the tariff proposed by the MSEB. It has 

requested the Commission to levy the rate as settled by Government of Maharashtra vide 

G.R. 21, May 99, wherein the ‘viable tariff’ mechanism has been implemented. On the other 

hand, other objectors have objected to the favorable treatment being given to Mula Pravara 

through tariffs even lower than the cost of generation of the MSEB. They have argued that 

this is particularly true when the Society is a defaulter in payment of its charges. They have, 

therefore, demanded the cancellation of its license. 

The MSEB has submitted that it has given instructions to its field offices to offer MD based 

tariffs to LTPG consumers in case such consumers wish to exercise the option. It has stated 

that the MSEB is allowing MD based tariffs even for connected load greater than 67HP and 

upto 100HP (such consumers are usually given HT tariffs) for consumers having high load 

diversity factor and demand not exceeding 50kVA. 



43


As regards the special tariff for categories like poultry, power looms and LT agricultural 

consumers, the MSEB has submitted that it has attempted to rationalize the number of 

categories and slabs in the current Tariff Proposal. The intention behind proposing higher flat 

rate tariffs is to incentivise metered consumption, to complement the move towards 100% 

metering. Once 100% metering is achieved, the flat rate tariffs will no longer be required. 

The fixed charges have been determined such that the fixed charges contribute to 35% of the 

revenue, as compared to the 55% of fixed costs incurred by the MSEB. 

As regards the tariff for the Mula Pravara Electric Co-operative Society (MPECS), the MSEB 

has submitted that the tariff has been determined based on the average cost of supply. The 

MPECS has huge arrears towards previous bills and the MSEB has represented to the State 

Government for settlement of these dues. 

The MSEB has submitted that its operations and hence tariffs cannot be compared to other 

licensees in the State as they differ from MSEB in the following aspects: 

‣ Subsidy and cross-subsidy existing in the system 

‣ Number and density of consumers served 

‣ Area served in square km 

‣ Profile of consumers 

The Commission has kept these objections in mind while determining the category-wise 

tariffs. The cardinal principle applied by the Commission is avoidance of tariff shock to 

hitherto subsidised consumers, though the tariff increase for such categories like agriculture 

and power loom is bound to be comparatively steeper. The Commission has retained certain 

selected slabs in domestic, commercial and LTP-G categories with a sliding scale such that 

all consumers within that category will benefit from the lower tariffs for the lower slabs. As 

regards a separate tariff for charitable trusts, the Commission has decided not to implement 

the same, as it goes against the basic philosophy of the Commission of aligning the tariffs to 

the cost of supply. 

The Mula Pravara Electric Co-operative Society (MPECS) is a distribution licensee receiving 

power from the MSEB at 11 kV and distributing power to its consumers at 11 kV and 440 

volts. As a distribution licensee, the MPECS is entitled to approach the Commission for 

revision in tariffs such that it earns the stipulated return. As regards the applicability of the 

G.R. 21 quoted by the MPECS fixing the ‘Viable Tariff’ to be charged to the MPECS, the 

Commission is of the view that, after its formation, the jurisdiction of determining the tariff 



44


for licensees within Maharashtra rests with the Commission, and the said G.R. is no longer 

valid. The Commission had started the process of aligning the tariff charged to MPECS with 

the average Cost of Supply in its Tariff Order last year, and has continued the process in this 

Order also. 

2 TARIFF PHILOSOPHY 

2.1 Guidelines 

In general, the tariff revision proposal has been alleged to be against the provisions of the 

Indian Electricity Act and the E (S) Act. Shri Ashok Jadhav of Ratnagiri Flour Mills 

Association has stated that the imposition of fixed and variable charges is tantamount to 

double charging, restrictive trade practice and against the provisions of the I E Act, public 

interest and natural justice. Mr.N.D.Patil, General Secretary of Bhartiya Shetkari Kamgar 

Paksha has argued that the Tariff Proposal has no scientific base and MSEB has grossly 

overlooked provisions of ERC Act 1998 & economic principles and that such Tariff proposal 

is against the interest of farmers & poor electricity consumers of the state. He has further 

suggested that prior to determining such drastic revision in the Tariff Structure for any Public 

Utility, it is quintessential to have detailed scientific & socio-economic basis for the same. 

Hence, he has requested the Commission to publish a “Tariff Policy Paper”, followed by 

detailed discussion on the same, prior to revision in any Tariff Structure. 

Mr. Pratap Hogade, during the public hearing, pointed out that the MSEB has violated the 

following provisions of ERC Act 1998 and the MERC Regulations as regards T&D losses 

and increased expenditure. 

1. Sec 22(1)(d) – Promoting competition, efficiency & economy 

2. Sec 22(2)(e) – Operating in an efficient, economic & equitable manner 

3. Sec 22(2)(g) – Set standards relating to quality, continuity & reliability of service 

4. Sec 22(2)(h) – Competitiveness & fair deal to consumers 

5. Sec 22(2)(m) – Safeguarding public interest 

6. Sec 29(2)(d) – efficiency, economic use of resources, good performance & optimum 

investment 

7. Reg 74 (a) – Productivity & efficiency improvement to protect consumer interest 

8. Reg 74 (d) – Continuous improvement in generation, transmission & distribution 

9. Reg 74 (h) – Healthy growth of industry 

The Railways have quoted section 29 of ERC Act, 1998 and section 74 of MERC CBR 1999 

which provide for tariffs being cost reflective and unbundled, which have been ignored by the 



45


MSEB in the current proposal. Industry associations have rejected the proposal as arbitrary, 

discriminatory, illegal and violating the spirit and objective of the legislation. It is stated that 

the proposal shows undue preference to a particular section of society at the cost of others 

and thus, runs contrary to E (S) Act provisions and the Rajdhyaksha Committee report. 

Further, the proposal goes against the economic principle of bulk purchases being cheaper 

and also doesn’t take into account affordability for the consumer. Similar sentiments have 

been echoed by Mr. Pratap Hogade, Vice-President, Janata Dal (Secular)-Maharashtra. He 

has requested that Tariff revision should be effected only once in 2 to 3 years.The objectors 

have requested the Commission to abolish the clause of early payment for availing bulk 

discount due to recessionary condition of industry. 

Some industry associations have argued that the objective of reform as stated by the MSEB in 

the filing is “to provide good quality of power to the consumer at competitive prices”. The 

associations have stated that this is a statutory obligation cast upon every SEB by the ESA, 

and is now being trumpeted as reforms after being overlooked for years. 

Others have questioned the ‘cost-plus’ basis of regulation, which is a hindrance to efficiency 

improvement and suggested alternative regulatory concepts. They have also objected to the 

proposed carry forward of Rs. 515 crore as regulatory asset as it is not based on sound 

commercial principles. 

One objector has contended that tariff making for public utilities should be designed to meet 

the community needs and a departure has to be made from the cost pricing and principles of 

affordability assumes prime importance. He has stated that public interest should be the 

guiding principle and cost price basis should be modified by income distribution principle so 

as to make electricity affordable to the low-income consumers. He, therefore, supported the 

tariff structure adopted till 1999. 

2.2 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 are 

being burdened much in excess of cost not just in tariffs but in recovery of capital as well. 

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. They have further 

argued that the costs are not being unbundled consumer category-wise rendering it difficult to 

design 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 E (S) Act and the ERC Act. Further, 



46


they have requested the Commission to direct the MSEB to project subsidies and crosssubsidies 

pertaining to all classes of consumers taking cost of supply at voltage levels (LT, 

HT and EHT) as the point of reference. 

Industrial associations have argued that cross-subsidy is being provided to agriculturists at the 

expense of industry and the MSEB has been ill advised by the State Government only to 

appease its vote bank. They have fervently 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 while attempting to reduce the 

burden of Government, contrary to the provisions of the ERC Act. The Railways have alleged 

that the MSEB is discriminating against the Railways by proposing to keep the tariffs of the 

Railways’ at the existing level, while proposing to reduce other HT tariffs. They submitted 

that they are being deprived of the benefits of tariff rationalization, which is the stated 

philosophy of the MSEB as enunciated in its proposal. 

The consumer representative, Prayas, has contended that it is easier to curb inefficiency in the 

MSEB than the social and economic impacts of radical increase in tariff for the poor, as 

suggested by the MSEB. In addition, tariff increases without commensurate increases in 

efficiency and service does not balance the interests of the consumers, as required by the 

ERC Act. They have suggested a detailed study on the impact of the proposed changes in 

tariff principles on different sections of the society. Akhil Bhartiya Janwadi Mahila 

Sangathan has exhorted the Commission to continue the existing system of cross-subsidies 

for the sake of the extremely poor and marginal farmers. They have argued that reducing the 

rates for the affluent while increasing it for the poor would ensure that the homes of the poor 

would be dark while the shop windows and neon signs would glitter, mocking their poverty. 

During the public hearings, several objectors said that the MSEB’s proposal to reduce crosssubsidy 

steeply would result in a higher Government subsidy, which would be tantamount to 

the MSEB getting the money through the back door. The Tata Power Company (TPC) said 

that the subsidy statement submitted by the MSEB showed that there was no cost of supply to 

the TPC, and the entire standby charges was thus on account of cross subsidy. The TPC 

submitted that the standby charges should also be reduced every year in line with the 

Commission’s stated philosophy of eliminating the cross-subsidy in five years’ time. 

Mr. Pradyumna Kaul said that the ERC Act empowers the Commission to set differential 

tariff based on the geographical location, nature of supply, and purpose for which electricity 

is consumed. He added that the Consumers Protection Act overrides the provisions of the 

ERC Act, and there was nothing wrong in protecting the weaker sections. Mr. Kaul also 



47


submitted that the average cost of supply should not be allowed to increase and the 

Commission should take proactive steps to reduce the average cost of supply as close to the 

international price as possible. 

2.3 Subsidy 

Several Industry Associations have argued that 80% of the farmers do not own pump-sets to 

avail the subsidy being extended by the Government. So, it is only the rich farmers who enjoy 

it. The scheme of subsidy is thus unscientific, and promotes disparity apart from distorting 

efficiency incentives. They have exhorted the MSEB to take up a sustained campaign to 

educate the masses of this peculiar anomaly. They further argue that the MSEB incurs huge 

cost difference while supplying energy to different categories as illustrated in its tariff 

revision proposal of March 2000. 

The subsidy statement thus worked out based on average cost of power in the current 

proposal is misleading and allows the MSEB to hide the actual subsidy being given/borne by 

different categories of consumers. They have quoted the MSEB’s statement in the proposal 

that 9 out of 10 consumers of the Board are being subsidized and this subsidy is largely being 

borne by the HT consumers, which are only 2% of total number of consumers. They have 

also stated that the lack of a system for speedy subsidy disbursal due from Government 

adversely affects cash flows impeding time bound cross-subsidy elimination plans and 

hampers investment in infrastructure improvement. 

The Mumbai Grahak Panchayat has requested the Commission to include schedule of subsidy 

payment from Government of Maharashtra in the tariff order itself. They have also suggested 

the provision of a 2% delayed payment interest to MSEB on delayed payments. The Akhil 

Bhartiya Grahak Panchayat has pointed out that no provision of subsidy has been made in the 

tariff proposal despite no explicit denial from the State Government. 

2.4 Time of day (ToD) tariffs 

The Railways have argued that they should be eligible for ToD tariff in line with that of HT 

consumers as their consumption improves the load factor during off-peak periods. The 

industry, on the other hand, has argued that the incentives proposed for industry for nighttime 

consumption are not commensurate with the fact that only energy charges need to be 

recovered by the Board for off-peak consumption. Other industries have stated that the 

benefits of ToD tariff are not being availed by the consumer in most cases owing to a lack of 

installation of the required meters by the MSEB. They have alleged that the MSEB has 



48


neither provided any justification for this enormous delay in meter installation nor any timebound 

plan of installation. One industrial objector has suggested differential night tariffs for 

HT and EHT consumption with EHT night tariff at Rs. 1.25/kWh. They have further 

suggested extension of duration of night tariff from 10 p.m. to 9 a.m. and for 24 hours during 

public holidays. 

The Indian Aluminium Company has contended that the proposed system of ToD tariffs is 

not fair to continuous process industries, as the increase in tariffs proposed for peak-time 

consumption is not offset by the decrease during off-peak hours. 

2.5 Others 

Universal Ferro Alloys has requested the Commission to clarify if the present MSEB 

proposal affects their eligibility to receive NTPC power through the MSEB. The Railways 

have put forth the argument that their tariffs should be benchmarked to the power purchase 

cost from Central Generating Stations of NTPC and NPC as they are a Central Government 

organisation. During the public hearings, the Ratnagiri Zilla Flour Mills said that flour mills 

should be charged at the agricultural rate and not at LT industrial rate, as they were 

processing the agricultural produce. 

On cross-subsidy, the MSEB has submitted that significant rationalization of the tariff 

structure has been proposed in an attempt to bring it closer to the intent of S. 29(3) of ERC 

Act, 1998. The MSEB has further submitted that in accordance with the intent to keep the 

cross-subsidy to a minimum, the slabs within various categories have been 

reduced/eliminated. The MSEB has stated that while the cross-subsidy to some categories 

appears to be inevitable and has been maintained, it has attempted to generate the crosssubsidy 

requirement from within the categories themselves to the extent possible, in line with 

the principle of charging the consumer closer to the average cost of supply. 

Similarly, the MSEB submitted that the rates within the LT category and within the HT 

category have been made uniform to a larger extent, which should also reduce the incentive 

for misclassification and collusion. On the specific issue of increase in cross-subsidy by the 

Railways with the proposed tariffs in comparison to last year, the MSEB has submitted that 

the average cost of supply as per the May 5, 2001 order of the Commission shows that the 

average realization/average cost of supply is 151% in the year FY 2000-01 while, as per the 

proposed tariffs for FY 2001-02, it stands at 125%. The MSEB also submitted that the 

average realization from the existing HTP I and HTP II consumers would reduce from 128% 



49


& 124% respectively to 121% as a percentage of the cost of supply of Rs. 3.37 per unit under 

the proposed tariffs. The MSEB has argued that this is in line with the principle of 

progressive movement towards the cost of supply, as enunciated in the tariff proposal. 

The MSEB has submitted that comparison of the cost of supply with other utilities/countries 

would not be proper since the cost of supply depends upon several factors like hydro-thermal 

mix of generation capacity, consumer mix, geographical situation, density of consumers, etc. 

All these factors differ from one State to another, and comparison is not appropriate. 

On subsidy, the MSEB has submitted that it has not envisaged any subsidy from the State 

Government for maintaining its Rate of Return requirement. The MSEB has stated that if the 

Commission or the State Government desire to subsidise any consumer category, the 

difference in the revenue from the proposed tariffs and the subsidised tariff should be 

provided to it either by a consequent increase in tariff of the other consumers or in the form 

of a transparent subsidy from the State Government. 

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. 

On ToD tariffs for the Railways, the MSEB submitted that the ToD tariffs are primarily 

introduced for Demand Side Management and to shift the maximum load from daytime to 

night time. It further stated that given the peculiar nature of operations, the Railways is not 

expected to shift its load and, for the same reason, no peak time tariffs are charged to it. As 

regards ToD tariffs for continuous process industries, the MSEB has replied that the ToD 

tariffs have been designed such that the three-shift industries are not adversely affected. 

The Commission has already detailed its tariff philosophy through its previous Tariff Order, 

wherein the Commission had expounded on the need for change in the tariff structure, twopart 

tariff, etc. The Commission has also discussed the rationale for levying fixed charges and 

variable charges in earlier sections. As regards the freezing of tariff for 2 to 3 years, the 

MSEB is entitled to approach the Commission for revision of tariff once in a year, as per the 

provisions of the ERC Act. 

The Commission believes that a regulatory oversight is essential during the transition period 

to facilitate speedy implementation of adequate metering and billing systems, loss 



50


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 long-term tariff implementation at an appropriate time. Therefore, the 

Commission believes that ‘Cost-Plus’ basis of regulation as envisaged in the ESA, with 

regulatory oversight to ensure prudency of expenditure is appropriate during the capitalintensive 

transition period. 

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

tariffs in relation to the average cost of supply, such that the average tariffs for subsidising 

categories is reduced and the average tariffs for subsidised categories is increased. 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 

Order, the reduction of cross-subsidy is a gradual process and cannot be achieved overnight. 

The Commission reiterates its view that the tariff determination exercise is being undertaken 

with regard to the efficiency of the MSEB and is not being done in isolation. 

Section 29 (5) of the ERC Act states, “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 this section, the State Government shall pay 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. The Commission had directed the GoM to submit its proposal 

for providing subsidy to any consumer category before the finalisation of the Tariff Order, to 

enable the Commission to account for it and issue the final tariffs to be charged by the 

MSEB. However, the Commission is of the view that the delay in providing the committed 

subsidy adversely affects the liquidity position of the MSEB. The Commission accordingly 

directs the GoM to provide the committed subsidy amount in cash every month on an equated 

monthly basis, without resorting to setting of the subsidy against the Electricity Duty at the 

end of the year. 

The Commission had introduced ‘Time of Day’ (ToD) tariffs for HT industrial consumers in 

its previous Tariff Order, with a view to achieving flattening of the demand curve. However, 

the MSEB has not installed ToD meters for all HT industrial consumers till date. This is a 

serious lapse on the part of the MSEB, and is being discussed separately in this Order. The 



51


Commission has introduced ToD tariffs for HTP-III and HTP-IV consumers also, as well as 

LTP-G category. The ToD data submitted by the MSEB indicates that the HT industrial 

consumption has shifted to some extent as a result of the ToD tariffs. To further encourage 

this trend, it is considered necessary to widen the differential between tariffs of off-peak and 

peak hours. 

The existing contractual arrangement for special tariffs in respect of the ferro-alloy industry 

will continue, and will not be affected by this Order. 

3 TARIFF SETTING PROCEDURE 

Several objectors have contended that the MSEB is not justified in submitting tariff revision 

proposal every year as it destabilizes the industry. They have proposed that the tariffs should 

be frozen for three to five years. They further suggest that the Commission should also fix the 

percentage of increment to be granted over review periods. On the other hand, Prayas has 

cited the present uncertainties about costs and performance improvements, etc., of the MSEB 

as reasons for infeasibility of implementation of long-term tariffs. 

A number of objectors, both in the written objections and during the public hearing process, 

have reacted vehemently to the acute lack of time provided by the Commission which, in 

some cases is as low as a week, for responding to the bulky tariff proposals. Another objector 

complained that the tariff proposals were not available till 24 th September 2001 in the 

regional offices of MSEB at many places, while the last date for submission of objections 

was 25 th September 2001. He has alleged it to be a deliberate attempt on the part of the 

MSEB to avoid a meaningful discussion on the proposal and to make a farce out of the public 

consultation process. He has further contended that the reason for the conduct of hearings in 

big cities that are expensive and prohibitive is again a deliberate attempt at keeping the 

objections to a minimum. The All India Association of Industries has argued that since FY 

2001-02 is largely over during the filing process itself, the tariff award of the Commission 

should also hold valid for FY 2002-03. 

Major Prakash Patil (Retd.) of the Jan Jagaran Andolan has brought to the attention of the 

Commission that no advertisements of the Commission were published in any of the 

Kolhapur edition newspapers like Sakal and Pudhari and, thus, people are unaware about the 

proceedings. He further requested for a time extension so as to get at least fifteen days for a 

study of the proposal and submission of the affidavit. 

Some other objectors have argued that since the MSEB has not complied with the Order of 

the Commission dated 14 th February 2001 regarding the submission of ‘Terms and 



52


Conditions of Supply’ to the Commission before the tariff proposal, the tariff proceedings 

should be stalled till the approval of the ‘Conditions of Supply’ by the Commission. The 

Pune Chapter of Cost Accountants has suggested that all the resolutions of the MSEB Board 

should be filed with the Commission and should also be open to the consumers and the press. 

The MSEB has said that S.59 of the Electricity (Supply) Act, 1948 states that the MSEB can 

adjust its tariffs every year, such that it earns the mandated surplus on the Net Fixed Assets. 

The MSEB has submitted that the ‘Conditions of Supply’ has been submitted to the 

Commission for its Approval. 

The Commission has already indicated its view on the fixation of multi-year tariffs. As 

regards the time given to the consumers to react to the MSEB’s Tariff Proposal, the 

Commission was of the view that any delay in the issue of the Order by the Commission 

would make the implementation of the Tariff Order difficult as only 4 months of the current 

year would be remaining. Moreover, in the interest of transparency and fairness, the 

Commission extended the time allowed to submit written objections up to October 16, 2001, 

which was the last day of the public hearing in Mumbai. Thus, the Commission was severely 

constrained to grant any more time in the interest of all concerned. 

In order to give more consumers a chance to participate in the public hearing process, the 

Commission conducted public hearings at 6 divisional headquarters, namely, Mumbai, Pune, 

Nagpur, Amravati, Aurangabad and Nasik, despite the extremely tight time schedule set by 

the Commission for issuing the Tariff Order. The Commission had ensured adequate 

publicity of the Tariff Proposal and the public hearing process, by publishing the schedule in 

the local and regional newspapers. 

The Commission had issued an Order in February 2001 directing the MSEB to approach the 

Commission for approval of the ‘Conditions of Supply’, before or with the Tariff proposal. 

However, the MSEB has approached the Mumbai High Court in this context, and the 

Honourable HC has ruled that the tariff process of FY 2001-02 can proceed till a decision is 

reached in this regard. The Hon. HC has also ruled that all modifications to the Conditions of 

Supply implemented after the formation of the Commission have to be approved by the 

Commission. As the matter is sub-judice, the Commission has not taken any decision in this 

regard and has decided to issue the Tariff Order for FY 2001-02. 

4 TRANSMISSION & DISTRIBUTION LOSSES 

The power loom associations have contended that the MSEB’s tariff proposal has not detailed 

any of the steps undertaken by the MSEB during the previous year to reduce T & D losses. 



53


Several industrial consumers have expressed their concern over the alarming increase in loss 

percentage in the current proposal over the last year. They have argued that the Commission 

estimated the MSEB’s losses at 31.87% last year as against 27.66% filed by the Board in the 

revised proposal. The MSEB had also prayed to the Commission last year to reduce the loss 

reduction target to 2% every year instead of 5%. However, the current proposal indicates a 

loss figure of 39% ignoring the Commission’s order and the MSEB’s own pleas. 

A mere 2% reduction of loss from the loss figure of 31.24% would have garnered additional 

revenues of Rs. 965 crore to the Board and a 5% reduction would have led to a revenue 

enhancement by Rs. 1587 crore, obviating the need for the tariff hike in the current proposal. 

They have stated that losses do not exceed 16% internationally and that the MSEB could 

easily reduce losses by 5% every year with minimum investments as it largely represents 

theft and unmetered consumption. During the public hearings, several objectors voiced their 

apprehension that the MSEB would report even higher T & D losses in the next year, at levels 

of over 50%. 

As regards determining the consumption norm for average Operating Hours/HP/Annum for 

the agriculture sector, Mr. Sambhajirao Kharade, Vice Chairman of Vasantdada Shetkari 

Sahakari Sakhar Karkhana Ltd., has argued that the MSEB has neither taken any efforts to 

gather information for over the past two decades nor involved any farmers in the same. He 

informed that, according to the produce, one can classify farmers into four broad categories 

(viz. sugarcane growers, farmers growing seasonal crops such as wheat, rice, soyabean, etc., 

farmers growing fruits & vegetable growers) for the purpose of agricultural consumption in 

the State. Each category depending on crop requirement & cultivation pattern would prefer 

either the Flat rate or the Metered Tariff system. 

He further indicated that his company has sponsored about 81 irrigation schemes covering 

installed pump capacity of 20919 HP. According to him, the average annual operating hours 

for sugarcane produce is 1120 Hrs, the same for Rabi crop is 1008 Hrs and that for individual 

pump owners in the area is 744 Hrs. 

Mr. Ganpati Lad of Sangli District Co-Op. Irrigation Federation indicated the norm of 

average annual operating hours as 374 for LT agricultural load and 561 hours for HT load. 

He has provided basis for his argument considering varied season conditions and crop 

patterns. Prayas has contended that energy audit data reveal substantial metering/inefficiency 

at the EHV and HV level and higher incidence of losses in urban areas. Their studies 

indicated 40% express feeders with consistently problematic readings and 15 divisions out of 

120 accounting for over 35% of losses with one division accounting for 3.7% of MSEB’s 



54


total losses. They suggest a sustained theft reduction drive in these high revenue realization 

areas to enhance revenue by Rs. 245 crore during the ensuing year. Prayas has submitted 

detailed workings to support their claims. 

The industries are also concerned with the low level of metering penetration amongst the 

consumers (45%) and the total apathy of the MSEB to remedy the situation. They have 

exhorted the MSEB to take up a time bound metering plan for all HT consumers and abolish 

unmetered/flat rate tariff in HT category. 

The Maharashtra Chamber of Commerce and Industry has suggested a circle-wise energy 

audit to identify circles with higher than average losses and measures to bring it down to 

average within twelve months. A system of cash and service penalties has also been 

suggested in other quarters for under-performing personnel. It is stated that these steps are 

essential in the light of the fact that the MSEB is a monopoly service provider and the 

consumers are deprived of a choice. Another objector has suggested that the MSEB and its 

employees should bear any loss over 10% rather than it being loaded to the consumers. The 

Pune Chapter of Cost Accountants has suggested a 10% cut on managerial remuneration in 

line with similar provision in the Companies Act 1956 for loss-making companies. 

The Akhil Bhartiya Grahak Panchayat has alleged that the MSEB is hiding its losses under 

unmetered consumption, which is a clear indication of an attempt to absolve itself from 

failure to adopt strict vigilance to arrest power thefts. The Thane Belapur Industries 

Association (TBIA) has requested the Commission to retain the earlier target of loss 

reduction mandated in the May 2000 order and the Government should make good the 

deficit. This, they have argued, would motivate the Government to move in the direction of 

reforms and desegregation of functions of the MSEB into manageable entities. They have 

suggested parallel implementation of the recommendations of the Godbole Committee while 

pursuing the other critical goals of 100% metering and energy audit. They also requested the 

Commission to urge the State Government to approve the Maharashtra State Electricity Theft 

& Malpractices Bill and amendments to Indian Electricity Act, 1910 forwarded to it. 

Prayas has contended that the Commission had directed MSEB in its last order to recover Rs. 

600 crore through reduction in thefts of power. However, the energy balances for FY 2000-01 

indicate increased losses even after assuming 1600 hours of agricultural consumption and 

reduced unmetered power-loom consumption. They have, therefore, requested the 

Commission to direct the MSEB to achieve a revenue target of Rs. 600 crore from theft 

reduction, set by the Commission for the last year at least for the ensuing year. 



55


Mr. Namdeo Patil, representing the Nagari Samasya Nivaran Samiti, Dhule, said that they 

have successfully managed to reduce the T & D losses in selected areas in Dhule, by using 

the ‘Sonagir Pattern’. Even the former MSEB Chairman had appreciated their efforts. 

However, the MSEB has not taken any steps to implement this scheme in other areas. 

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 certain targets 

for performance- increasing metered consumption from 44% to 47% as a percentage of net 

energy input, reduction in commercial losses by 2%, reduction in cross-subsidies, etc. 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 1:2.12 as against the maximum acceptable ratio of 1:1 

The MSEB has added that it is aware of the situation and is making efforts to reduce the T&D 

losses by adopting various measures, which have already been detailed in the tariff proposal 

submitted. On energy thefts, the MSEB has submitted that the number of disconnections has 

gone up significantly, aggregating to over 22 lakh till October 2001. The MSEB has stated 

that it has recovered Rs.18.5 crore by detection of thefts during the period April to March 01. 

The MSEB has further stated that it has suggested to the Government to enact the 

‘Maharashtra State Electricity Theft & Malpractices (Prohibition) Bill’ for constitution of 

Special Tribunals and Special Courts to try cases of criminal and civil mal-practices. It also 

submitted that it has initiated disciplinary action against employees in 646 cases and the 

benefits arising out of all these steps have been passed on in the proposed tariffs. 

The MSEB also submitted that it is taking a stern view on cases of corruption/malpractice 

involving its own employees and has taken the following measures during the last year: 

• 646 cases of disciplinary action were finalized with action taken against the various 

employees working in Head Office and Field offices, while cases against 950 employees 

has been initiated. Among the 646 employees, 134 are meter readers, billing staff and line 

staff. 



56


• 181 employees were suspended for offences that included ACB Trap cases (38), theft of 

energy cases (21) and other misappropriation/criminal cases (122). Of the 181 employees 

suspended, 10 belonged to Pay Group I, 36 belonged to Pay Group II and 135 belonged to 

Pay Group III & IV. 

• 5% of the oldest employees within a circle transferred out of the circle to avoid 

possibilities of collusion. 

The Commission is deeply concerned with the continuously 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 by 5% in FY 2000-01. At the same time, the 

Commission is of the opinion that the consumers are also equally responsible for the high 

level of T & D losses. This is on account of theft and pilferage through taking illegal 

connections, meter tampering, wrong billing in collusion with the MSEB staff and failure to 

report such occurrences to MSEB by people in the neighborhood. As it is not possible to 

identify and hold any particular category of consumer responsible for these losses, the 

Commission has decided that the MSEB and the consumers should bear the cost of the higher 

losses equally. 

The Commission also hereby directs the MSEB to devise and widely publicize schemes 

to incentivise reporting of such occurrences of theft by the public. A compliance report 

to the effect may be submitted to the Commission latest by 31 st January 2002. The 

Commission also reiterates its directive to the MSEB for the provision of name badges 

to all field staff at the earliest. The allowed level of T & D losses and the mechanism for 

recovery of excess losses has been explained in detail while discussing T & D losses in the 

section on Energy Input and Revenue Requirement. 

The Commission has analysed the energy audit data submitted by the MSEB to determine the 

consumption norm for un-metered agricultural consumers. The Commission has also 

analysed the energy audit data for HT and Express Feeders submitted by the MSEB. The 

analysis shows that the reported losses at HT levels are substantial, contrary to common 

perception that losses at the HT level are relatively lower. The Commission has taken a 

serious view of these findings and has issued certain directives to reduce the loss levels, as 

detailed in subsequent sections. 



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5 REVENUE/REVENUE ARREARS 

Several industrial consumers have expressed concern over the 4.8% reduction in off-take by 

HT industry leading to a loss of revenue of Rs. 185 crores. They have complained that the 

MSEB has not provided any reasons for this reduction. Others have interpreted it as a 

consequence of the prevailing high tariffs coupled with poor quality of supply that has forced 

these industries to switch to captive capacity and alternate fuels, leading to environmental 

pollution apart from revenue loss. 

A similar concern has been expressed at the substantial increase in receivables from Rs. 3700 

crore to Rs. 5000 crore. This has been interpreted as a lack of commitment to collect 

receivables, improper and inadequate billing and failure to curb thefts of electricity. The 

objectors have stated that this would lead to a strain on the finances of the MSEB and punish 

paying consumers. Further, a halt in the announcement of concessions and recovering arrears 

from public bodies could fill the projected revenue gap obviating the need for tariff revision. 

It has been represented that the MSEB has been giving waiver to habitual defaulters without 

any authority and the same should be recovered from the concerned consumers and the 

concerned authorities allowing such waiver, rather than from the paying consumers. Other 

objectors have stated that no legal action is taken for recovery of arrears and, in turn, new 

connections are given to the consumers in a new name further loading the consumers towards 

write-offs of PD cases. During the public hearings, several objectors complained against the 

practice of waiving 50% of the dues of non-paying consumers, which sends a wrong message 

to the consumers, as it rewards defaulters, while unfairly punishing the prompt payers. 

The Electricity Consumer Association has suggested a public disclosure of all debtors to the 

MSEB having an outstanding liability of more than Rs. 10 lakhs along with reasons for the 

accumulation and action taken by the MSEB authorities in this regard. Another objector has 

suggested auctioning bill collection to private parties in difficult areas to prevent energy 

thefts. 

The MSEB has submitted that it is taking all possible measures to improve its arrears position 

in exercise of the powers conferred to it under section 24 of the Indian Electricity Act, 1910. 

However, it has argued that disconnecting power supply of defaulting consumers is not 

always possible for various reasons like prohibitory orders from the Government, 

unemployment and labour unrest, the state of industry, sickness of the unit considering 

electricity provision as an essential service. The MSEB has contended that, in such cases, the 



58


MSEB allows defaulting consumers to pay the arrears in suitable instalments, depending on 

the merits of the case. 

The MSEB has admitted that resorting to legal recourse is often time consuming and does not 

bear material results, though cases for recovery have been filed against large defaulting 

consumers. Further, the MSEB has submitted that growth in arrears has been arrested in FY 

2000-01 while the arrears with respect to those consumer categories where it has a free hand 

in effecting disconnections (domestic, commercial and industrial), has actually fallen during 

FY 2000-01 due to disconnection drives conducted on these consumers. The MSEB has 

clarified that the arrears do not affect the calculation of the estimated revenue gap for FY 

2001-02 for which the revised tariffs are proposed. 

It has stated that bad debts assume greater importance in the business of electricity 

distribution as the product is sold on credit across a diverse section of consumers, with a 

payment period varying from one month to six months. The MSEB has stated that the bad 

debts are written off in the books of accounts with the approval of competent authorities 

prescribed under clause-10 of Administration of Funds and Properties Regulations, 1980. 

Further, the provision for doubtful dues from consumers is made as prescribed in Rule 4.2 of 

Annexure-V to the Electricity (Supply) Annual Accounts Rules, 1985. It has been submitted 

that the nature of debts is reviewed age-wise and the debts that are time-barred under the Law 

of Limitation or where civil remedy is not available or bills and delayed payment charges 

related to sick industrial BIFR units are chosen for write-off. 

The Commission is of the view that the reduction in industrial consumption over the past year 

is on account of the industrial recession as well as in part due to the high industrial tariffs 

prevailing in the State. The Commission has attempted to address this issue while 

determining the industrial tariffs while maintaining a balance between the interests of the 

MSEB and other consumers. 

The Commission has taken serious note of the increase in receivables for certain consumer 

categories, though the MSEB has managed to reduce the receivables from the residential, 

commercial and industrial categories. The MSEB has shown willingness to disconnect 

consumers, and has disconnected over 22 lakh consumers till date this year, which is 

commendable. As regards the GoM directives in regard to disconnection of certain consumer 

categories, the Commission directs the MSEB to undertake disconnection for all 

consumers who are having high receivables. At the same time, the Commission also 

appreciates that disconnection will be difficult in case of Mula Pravara and streetlighting and 



59


PWW consumers. The GoM should support the MSEB by directing these public utilities to 

pay their dues on time. 

The Commission is of the view that the MSEB’s request that the GoM should make good the 

dues of the public utilities such as Municipal Councils/Gram Panchayats for street lighting 

and water connections and Mula Pravara Society is justified. To this effect, the Commission 

recommends 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’. 

During the public hearing conducted with regard to the GoM subsidy, the GoM submitted 

that it would consider this request as well as direct the public utilities to pay their dues to the 

MSEB. The GoM added that the Mula Pravara Society has already been directed to clear their 

dues existing before May 2000 immediately, and for the dues after May 2000, the GoM was 

deliberating on the amount of subsidy support to be extended to the Mula Pravara Society. 

6 QUALITY OF SUPPLY/SERVICE 

Voltage fluctuations in supply have been universally condemned by all consumer categories. 

The power-loom associations have complained that voltage fluctuations cause erroneous 

meter readings further inflating the consumer bill and supply interruptions in turn hit their 

day-to-day business. Advocate Nyaz Ahmed Lodhi, representing power loom consumers, 

said during the public hearing at Nasik that due to the poor quality of supply and low voltage, 

the meter would record a higher consumption as compared to the actual usage. He hence 

submitted to the Commission that the flat rate system should be continued. Further, it also 

forces consumers to install motors of higher horsepower than required, thus leading to higher 

payment of fixed charges by the consumer. 

Small-scale consumers have expressed a similar concern of non-assurance of power supply 

despite paying as much as Rs. 16.36 per unit. Prakash Fabricators has objected to the 

discriminatory power supply guarantee allegedly being given to Ahmednagar by the MSEB. 

Others have objected to the imposition of fixed charges by the MSEB without provision of a 

reliable, stable supply. They have further argued for provision of specified free units to the 

consumer in lieu of fixed charges, as followed by the Telephone Department. 

Agricultural and rural consumers have argued that they never receive quality power and 

uninterrupted supply; hence, tariff for energy supply should be linked to the above factors. 

TELCO has prayed to the Commission to direct the MSEB to explore all avenues to have 

sufficient generation to maintain the level of frequency within the prescribed parameters of 

50 +/- 3%. TELCO has stated that maintenance of frequency within prescribed parameters is 



60


particularly relevant in the wake of new machines like CNC being used by industry, which 

are highly sensitive to frequency infringements. The Railways have asked for a mechanism to 

compensate them for the loss incurred due to supply interruptions and poor voltage. Mr. 

Pratap Hogade of the Janata Dal submitted during the public hearings that the compensation 

from the MSEB for the poor quality of supply should be placed in a separate fund for 

metering, etc. He added that the tariff should be commensurate with the quality of supply. 

The quality of supply to rural areas is very poor and continuous supply is also not assured. If 

the tariffs of both rural and urban regions are to be the same, then at least the unfair 

discrimination in quality of supply should not exist. 

Prayas has requested the Commission to make available to the public the circle-wise 

quarterly interruptions report, progress report and consultative council/public grievances 

report maintained by the MSEB as part of its internal performance management system. It 

has argued that routine disclosure of performance data would help in forcing MSEB staff to 

complete the tasks in a time-bound manner. 

The Vidarbha Industries Association has contended that load shedding imposed is unplanned 

and neither industrial consumers are taken into confidence nor suggestions are invited from 

consumers so as to minimize production loss of industries and agricultural sector. Indian 

Seamless has objected that the MSEB does not follow the guidelines given in the ‘Conditions 

of Supply’ for meter failure. Further, it has stated that power factor billing is not being done 

by the MSEB as per the guidelines using the kVARh reading, which penalizes the consumer 

unnecessarily. 

Load Shedding 

Mr. Pratap Hogade of Janata Dal (secular) has pointed out that as per MSEB’s own 

submission, its own generating capacity is 7212 MW to meet base load & 9132 MW to meet 

peak load. Further, as per the tariff proposal, peak load & base load demand curves indicate 

that there is no need for any load shedding. However, in reality, 800 to 1500 MW load 

shedding is already practised. He has requested the Commission to look into the matter and to 

issue appropriate orders to the MSEB. 

On frequency and voltage, the MSEB has submitted that, at present, 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 



61


continuously makes efforts to have proper co-ordination with the grid partners. Low voltage 

problems, the MSEB has submitted, arise in situations where power needs to be supplied in 

remote locations and there is overloading of distribution transformers. It has added that 

addressing these problems require significant capital expenditure. 

On reliability of supply, the MSEB has submitted that it makes 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. The MSEB has further 

submitted that new projects are being carried out for increasing capacity generation and T&D 

network augmentation. 

The MSEB has also denied the allegation of meters running faster. It has stated that the 

meters are designed for frequency and voltage fluctuations as per standard specifications. On 

load shedding scheduling in consultation with the consumers, the MSEB has submitted that 

though it agrees with the suggestion in principle, in practice, it is virtually impossible for the 

MSEB to incorporate all suggestions in chalking out a load shedding program. Therefore, the 

plan is formulated to cause least inconvenience to an average consumer. The MSEB has 

submitted that the power factor measurement would continue to be done in the method of 

kWh/kVAh, and in the absence/failure of suitable meters, Cosine [tan -1 (RkVAh/kWh)] 

method shall be followed. 

The Commission has taken a serious view of the complaints against the MSEB’s quality of 

supply. However, during the public hearings, a few objectors did admit to some improvement 

in the quality of supply, though they added that there is ample scope for further improvement. 

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 reworked the availability from TPC and central stations in the merit 

order dispatch schedule submitted by the MSEB, so as to minimize the number of hours of 

load shedding, compared to MSEB’s projections, in the months of January to March 2002. 

The TPC has represented that it has surplus power that can be sold to the MSEB, to the extent 

of about 150 MU in the period December to March 2002. As a result, the total load shedding 

envisaged in these months is of the order of around 400 MU as compared to the 1400 MU 

projected by the MSEB. 



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7 POWER PURCHASE AND GENERATION 

A number of objectors have objected to the low capacity utilisation of Uran generating plant, 

which is lower than 50% and has generated only 400MW for more than two years as against 

a rated capacity of 913 MW despite its being the lowest variable cost generator available with 

the MSEB. They have complained that no reasons whatsoever have been provided in the 

tariff proposal for such lower generation. This has arguably led to an additional unanticipated 

expenditure of Rs. 483 crores towards purchase power from NTPC and NPC. Others have 

expressed concern over 30% of revenue being utilised for power purchases and have 

demanded ascertaining of the optimum generating capacity of each of the MSEB plants to 

assess the prudence of this expenditure. 

Prayas has strongly objected to the inclusion of cost of approximately Rs. 100 cr. towards 

transit loss of coal in the current proposal, despite its disallowance by the Commission in its 

last tariff order. Further, they have sought to disallow all MSEB generation costs in excess of 

plant heat rate of 2740 kcal/kWh as prescribed by the Commission. They have contended that 

there has been a generation loss of 650 MW to MSEB due to poor quality of coal during the 

past year which could be rectified through measures such as coal import, coal washing and 

additional boilers. In addition, another 350 MW could be generated by using liquid fuels in 

the Uran generating plant. 

They have stated that the report of the Godbole (Energy Review) Committee has also 

corroborated these findings. They have, therefore, requested the Commission to direct the 

MSEB to submit a detailed report on the techno-commercial analysis and constraints of the 

options verified by independent consultants. Referring to capacity addition of 1000 MW in 

the Koyna power plant undertaken by the MSEB to boost peak generation, Prayas has argued 

that there has been no increase in generation during FY 2000-01 despite the capacity addition 

and requested the Commission to investigate the issue and order a capacity test of the Koyna 

station, if required. 

The Maharashtra Chamber of Commerce and Industry has estimated that the refurbishment of 

the Uran generating plant could add approximately 350 MW, while another 650 MW could 

be added through coal quality improvement. This, it is argued, would lead to reduced fund 

requirement for capacity addition and help tide over the load shedding and idle cost of labor 

and would lead to higher revenues. The Consumer Electricity Association has demanded a 

copy of the Power Purchase Agreement (PPA) between DPC and the MSEB be made 

available before the Commission for scrutiny and analysis. They have also argued that the 

losses sustained by the MSEB due to the PPA with the DPC should be provided by the State 

Government as a separate fund rather than being loaded onto the consumers. 



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The MSEB has submitted that it has achieved the highest ever generation in FY 2000-01 with 

the PLF improving from 71.7% in FY 1999-00 to 72.78% in FY 2000-01. It has further 

submitted that all its thermal power plants have qualified for cash awards from the 

Government of India for the year FY 2000-01 for reduced specific oil consumption. 

On reduced generation from Uran, the MSEB has submitted that the allocation of gas is 

decided by the Gas Linkage Committee constituted by the Union Government, over which it 

has no control. The availability of gas to the MSEB is dependent on the production of gas at 

Bombay High. Earlier, the MSEB was allocated 4.5mmcmd of gas at a production level of 

16.8mmcmd at Bombay High. However, this has reduced to 10mmcmd at present, resulting 

in an allocation of only 2mmcmd to MSEB. Therefore, the MSEB has submitted that it does 

not get enough gas to run its plants at Uran and, therefore, has to make good the shortfall of 

generation through additional power purchase. 

Further, four units of 120MW each in association with 240MW of Waste Heat Recovery have 

been commissioned in recent years with more than 90% availability. Thus, it submitted that 

the MSEB is capable of generating much higher than current levels with adequate supply of 

gas, which would also help in addressing the load shedding problem to some extent. 

However, Unit 1 would be refurbished only when all the remaining units get adequate supply 

of gas for generation. The MSEB has also submitted that generation from the Koyna plant has 

been lower due to the limitations in usage of quantity of water at Koyna Dam (67.5 TMC in 

one water year). 

On quality of coal, the MSEB stated that, by and large, Indian coal is inferior and the MSEB 

has no control over the coal linkage given by Standing Linkage Committee of Government of 

India. It submitted that the MSEB has been following up with Coal India Ltd. for getting 

linkage of good quality coal from WCL and other subsidiaries but cannot dispose off coal 

from SECL and MCL as alternative good quality coal source in India are tied up with other 

SEBs. In addition, the MSEB submitted the following measures taken by it for obtaining 

better quality coal from its plants: 

‣ Arrangement of one lakh ton per month of Korea-Reva coal, a good –quality coal, from 

SECL for its Nasik and Koradi plants. 

‣ Umrer coal, which is also a better quality coal, from WCL 

‣ Coal from Singareni Coal fields, particularly from Kalyan khani and Shanti khani is 

arranged for Parli stations through negotiations 



64


‣ Negotiations are on with SECL for washed coal from Deepika mine for washing upto six 

million metric tons per year. 

On the PPA with DPC, the MSEB has submitted that the DPC plant has been shut down from 

29 th May onwards, since the MSEB has given a notice to the DPC rescinding the PPA. 

Further, it has submitted that the power purchase costs from the DPC has not been factored in 

for the ensuing year as they have been contested for adjustment against the rebate claimed by 

the MSEB. Claims made by the MSEB towards the rebate have also not been considered, as 

the case is currently sub-judice. 

The Commission is of the opinion that the Uran gas plant should be utilized 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 

hereby directs 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 Commission has disallowed the cost incurred due to the transit loss in coal in line with 

the principles followed in the previous Tariff Order. The MSEB has approached the High 

Court for relief in this matter and the matter is sub-judice. The Commission has also reduced 

the allowed heat rate from 2740 kcal/kWh to 2704 kcal/kWh for coal thermal plants in line 

with the 1 % reduction in heat rate targeted by the Commission, for determining the fuel 

costs, though the MSEB has projected the fuel costs with a higher heat rate. The 

Commission also recommends to the MSEB to consider the feasibility of importing coal 

to overcome the problems in the coal quality and ash content, etc. 

8 EXPENDITURE 

Several objectors have objected to the additional expenditure of Rs. 538 crore over the last 

year proposed by the MSEB as it indicates laxity in curbing expenses. They have argued that 

the MSEB has always been harping about tariff increase without any mention regarding 

efforts to be undertaken to curb expenses. They have added that while consumers always pay 

for the lapses and failures of the MSEB, the MSEB’s officials never get penalized. They 

argued that the MSEB should validate the increase in expenses through concrete rationale 

rather than justifying them on the grounds of unforeseeable factors beyond control and 

systemic failures. 

Strong objections have been received regarding payment of penal interest of Rs. 155 crore to 

the State Government on account of the delay in paying duties and the Commission has been 



65


requested to disallow it. The Mumbai Grahak Panchayat submitted that the interest on late 

payment of Electricity Duty should not be allowed as the consumers have already paid the 

ED and it is the MSEB’s responsibility to forward the ED to the State Government. Similarly, 

interest on working capital is also sought to be disallowed as it indicates a lax approach by 

the MSEB in collecting its dues in time. Prayas has argued that the MSEB had been 

collecting security deposits from its consumers, which should be accounted for in 

computation of its working capital requirement. They have stated that this would bring down 

the interest cost on working capital by Rs. 159 crore. 

Pickomatic Industries has objected to a loan given by the MSEB to the MPDCL of Rs. 786.33 

crore @ 6% during FY 1999-00 as per the balance sheet while MSEB has taken loan @12 to 

18% this year from the market. He argued that this has caused additional burden of Rs. 48 

crore on the consumers. A large number of representations have also been received to 

disallow a return of 4.5% as proposed by the MSEB since it is not backed by any official 

gazette notification by the Government of Maharashtra and only 3% is mandatory as per 

section 59 of ESA. It is stated that this would lower the required return by Rs.164 crore. 

Objections have also been received regarding the provision of doubtful debts proposed by the 

MSEB to the tune of Rs. 200 crore. It has been argued that no basis has been provided for 

assuming only 90% collection of dues, which reflects the ineffectiveness of the MSEB in 

increasing revenue by reducing losses. Others have agreed to the provision for doubtful debts 

as a prudent accounting practice and in line with Electricity (Supply) Annual Account Rules 

1985 that provide for a fixed percentage of dues to meet bad debts. However, it is argued that 

the percentage should not exceed 3% of the dues as against 8% claimed by the MSEB. Prayas 

has objected to the inclusion of Rs. 5 cr. in the MSEB proposal towards bad debts written off 

despite the bad debt provision leading to double counting. 

TELCO has expressed its concern over a sudden increase in wages by Rs. 421 crore and has 

pled for its disallowance. The MCCI has alleged that the MSEB has not followed the 

Commission’s directive in the Tariff Order of May 5, 2000, of meeting employee cost 

increase through enhanced efficiency. The MCCI has further argued that the proposed 

increase in R&M expenditure should be reflected in performance improvement. It has prayed 

to the Commission to specify performance- norms for the MSEB. The objectors have also 

sought to disallow the income tax liability towards NTPC purchases as the Commission had 

disallowed the same in its previous order and have represented that it should rather be settled 

with the appropriate authorities. 



66


Prayas has sought to disallow Rs. 244 crores towards provision of arrears in employee cost as 

these are predictable expenses pertaining to previous years and should have been provided in 

the relevant year itself. The representative of the MSEB Graduate Engineers Association 

informed the Commission during the public hearing that there was no incentive scheme for 

the employees, and if incentives were provided, then the T & D losses could be reduced. He 

added that the bonus provision made by the MSEB should be paid only against specified 

incentive schemes applicable for all aspects of the MSEB operations. He also added that the 

wage revision agreement signed between the employees and the MSEB had specified that 

only 50% of the arrears would be paid upfront, and the balance would be paid out of the 

revenue collection in excess of Rs. 1000 crore in any month. Another objector has questioned 

the rationale of the existence of flying squads in the MSEB when no action is taken against 

irregularities reported by them every year to the tune of Rs. 100 crore. 

Pickomatic Industries have stated that sub-stations equipped with high cost instruments for 

unmanned operations have been needlessly provided with operators allegedly costing Rs. 38 

crores for the entire State. 

The MSEB has submitted that increase in tariffs is generally on account of increases in input 

costs and the existing tariffs are not sufficient to recover the costs. It has stated that the 

MSEB has estimated a gap of Rs. 1456 crore in the present proposal between the estimated 

revenues and estimated expenses, out of which only Rs. 130 crore is on account of increase in 

expenses over last year. It further submitted that the growth in administrative expenses has 

been partly arrested by not filling in 13000 posts and reduction in overtime payment. Other 

detailed measures have been spelled out by the MSEB in Section 5 of the proposal. 

On employee cost arrears, the MSEB has submitted that it is contractually required to 

negotiate a wage settlement with the employee unions every five years, and the wage 

settlement due since April 1998 could only be concluded in January 2001. It has further 

stated that the wage revision is effective from April 1998 and, accordingly, the accumulated 

arrears need to be paid to the employees leading to a major growth in employee expenses 

during the ensuing year. It contended that under section 59 of the Electricity Supply Act, 

1948, all its costs are to be recovered through tariffs. It stated that while the arrears of 

employee expenses pertain to the previous years, they have not been recovered during those 

years while determining tariffs. Accordingly, the MSEB submitted that it has provided for Rs. 

285.13 crore through tariffs for the ensuing year after accounting for the past provisions in 

this regard. 



67


On R&M expenses, the MSEB submitted that the R&M expenditure for the past year was 

lower than the earlier years on account of severe liquidity crunch faced by the utility, which 

has led to ill-maintenance of its assets affecting replacement of transformers, delay in new 

connections, replacement of faulty meters, overhauling of generating sets, voltage 

fluctuations in the grid and general system performance and affecting the quality of service to 

the consumers. The MSEB has, therefore, proposed to bring the R&M to the levels of earlier 

years and has pegged it at 3% of GFA. 

On payment of penal interest on late payment of ED, the MSEB has submitted that the 

subsidy is not paid in time by the State Government leading to a loss of liquidity to the 

MSEB. It has argued that payment of ED within due time would have forced the MSEB to 

borrow working capital from the market incurring additional interest cost. 

On working capital, the MSEB has submitted that it has assumed working capital requirement 

based on the norm of two months of sales and 15 days equivalent of fuel and oil expenses, 

with the revenue level projected at Rs. 12,000 crore and generation expenses at Rs. 3972 

crore. It has stated that application of these norms lead to a working capital requirement of 

Rs. 2171 crore and the interest cost at Rs. 279 crore. It further submitted that the working 

capital borrowing in the past has been much less as the Board had been resorting to deferral 

of payments, which is increasingly becoming difficult in the new commercial environment. 

On a rate of return of 4.5%, MSEB has stated that as per the financial covenants of the World 

Bank in respect of the Second Maharashtra Power Project Loan, it is required to earn an 

annual return of 4.5% from FY 1992-93 onwards. The MSEB has further submitted that it has 

been earning a return of at least 4.5% since FY 1992-93, which is being reflected in its 

Annual Accounts. Further, the State Government has been extending subsidies to the extent 

required to meet the covenant of 4.5% since FY 1995-96 implying that the State Government 

has recognised MSEB’s requirement to earn the prescribed return. Subsequently, the 

Government of Maharashtra (GoM) has notified the 4.5% RoR on the Net Fixed Assets in the 

State Government gazette. 

The MSEB has submitted that it has made substantial efforts to reduce the employee costs 

and administrative expenditure through measures such as: 

1. A ban on direct recruitment by keeping 10404 posts vacant in all categories and making 

2962 posts inoperative totaling 13366 posts, resulting in a saving of Rs. 166 crore. 

2. Drastic reduction of overtime payment by stopping overtime to administrative staff and 

reduction to operating staff to a bare minimum in all offices 



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3. Deployment of construction staff to urban areas, deployment of Drawing and Civil staff 

for Revenue/Generation/Stores work after appropriate training 

4. Imposition of travel discipline by restricting air travel facility only to the level of 

Superintending Engineer (SE) and above and tours undertaken only after permission from 

HoD. These measures have led to a saving of Rs. 3.65 crore 

5. Withdrawal of STD facility for officers below the rank of SE and a reduction in general 

expense towards telephones, meetings and office furniture by 20% 

6. Stoppage of cultural events saving Rs. 50 lakhs 

7. Curtailment of expenditure on training/seminars/workshops 

8. Transfer of 5% of total number of employees in public contact out of their spheres to 

minimize collusion and unscrupulous activities 

9. Ban on purchase of new vehicles, construction of new buildings and rest houses. 

On manning of unmanned substations, MSEB submitted that the installation expenditure for 

unmanned stations is no different from that of a manned station. Further, the decision to 

appoint operators was taken in the best interest of the consumers as there were problems in 

communication and the repairs could not be carried out in time. 

The Commission has analysed each head of expenditure in detail with the view to determine 

the prudency of the same. The Commission’s detailed analysis and allowed expenditure is 

discussed in a subsequent section. 

9 INFORMATION SYSTEMS/METERING 

It has been represented by a number of objectors that the MSEB has taken no steps to bridge 

the gaps in its Management Information Systems (MIS) despite the Commission’s directive 

to this effect in its last order. The MCCI has suggested that regional level segregation of 

T&D losses, metering and billing performance should be carried out and made available to 

consumers through internet with the establishment of a suitable MIS system. This, it is 

argued, is urgent in the wake of the fact that a mere 50% of the MSEB’s consumers are being 

billed on actual basis. It has been stated that delay in metering has caused the MSEB to lose 

revenue to the extent of Rs. 500 crore during FY 2000-01. Another objector has stated that a 

mere 3.3% commitment of metering improvement suggests lack of a determined attempt on 

the part of the Board to improve the status quo. 

Prayas has contended that MSEB has failed to meter power-looms and HT agriculture by 

December 2000 as proposed by it in its last tariff proposal and these categories have been 

assumed unmetered even in the current tariff proposal. This, they have argued, has caused a 



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revenue loss of Rs. 162 crore, which should not be loaded on to the paying consumers. In 

their written objection submitted to the Commission, the objector has suggested data formats 

for unit-wise energy flow accounting, metering & billing performance evaluation system, 

Material Purchase and Contract Evaluation, etc. 

The Pune Chapter of Cost Accountants has questioned the system of inventory valuation after 

a lapse of six months on the ground of lack of time. It has further requested the Commission 

to direct the MSEB to employ scientific Standard Costing method for its accounting 

purposes. Another objector has questioned the accounting of receipts on account of charges 

for replacement of meters, CTs, RTs, removal of overhead lines, etc. Advocate Nyaz Ahmed 

Lodhi, representing power loom consumers, said during the public hearing at Nasik that due 

to the poor quality of supply and low voltage, the meters would record a higher consumption 

as compared to the actual usage. He hence submitted to the Commission that the flat rate 

system should be continued. 

Mr. Sambhajirao Kharade has argued that there is no benefit that the MSEB can derive by 

metering as 

1. Based on past experience, the MSEB officials do not turn up for meter reading. 

2. The MSEB would be required to incur approx. Rs 200 Cr revenue expenditure p.a. on 

account of meter reading, meter repair & maintenance, depreciation & interest. Not 

spending this amount would be tantamount to saving capital outlay of Rs 496 Cr plus 

annual savings of Rs 200 Cr. 

Mr. Ganpati Lad has argued against metering as in almost 50% of the cases where meters are 

installed, the billing is based on average or minimum consumption. Hence, according to him, 

there is no merit in pushing for metering. Another objector has suggested that for agricultural 

pump-sets of 3 to 5 HP, it is not necessary to take up a program of installing meter at each 

user point and, instead, metering at the transformer level should suffice for energy accounting 

purposes. The Mumbai Grahak Panchayat has suggested introduction of Tatkal metering 

scheme in line with similar schemes provided by the Telephone department and the Railways. 

He suggested a premium of 10% of meter cost for the scheme with a provision for 2% penal 

interest in case of a delay in fitting the meters beyond seven days. They have further 

suggested introduction of competition among the circles by considering all the circles as cost 

and profit centres responsible for their input energy, billed energy as well as revenue 

generated. 



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One objector has pointed out that the connected load of un-metered consumers, as indicated 

in the filing, stands at 5825 MW, while the MSEB has proposed to convert only 48 MW for 

metering target for FY 2001-02. At this rate, the objector argued, the MSEB would take 120 

years for the entire un-metered load to be metered. Another objector has suggested suitable 

directives be issued by the Commission regarding the quality of the meters to be installed in 

the consumer premises, as most of the MD meters being installed by the MSEB are either 

defective or sub-standard causing disputes between the consumer and the MSEB officials. 

On metering, the MSEB has submitted that there has been a quantum jump in the amount to 

be spent on procurement of meters in view of the implications of the master metering plan. 

The MSEB has added that the expenditure per year on metering from 1996 to 1999 was about 

Rs. 25 crore which has gone up to Rs. 59 crore during FY 2000-01. It is further expected to 

go up to Rs. 345 crore on account of conversion of flat rate tariff consumers to metered 

category and additions of new consumers in the metered category. Accordingly, the number 

of meters to be purchased would also go up from 3 lakhs to 15 lakhs. 

Further, the MSEB has submitted that the success of the metering program would also require 

an environment favoring such conversion. The MSEB has contended that it has met with 

tremendous resistance from the consumers towards metering as the per unit rate for metered 

consumers is presently higher than the unmetered tariffs. This has led the MSEB to propose 

correction of tariffs for Agriculture, Power-loom, PWW and Street Light categories to 

incentivise such shift to metered tariffs from flat rate tariffs by keeping lower metered tariffs. 

It has stated that the MSEB has also initiated a number of activities for improving its 

performance, namely: 

‣ Effecting disconnections in certain consumer categories where it has a free hand to 

recover past dues of such consumer categories. 

‣ An MIS program is also being initiated for effective and efficient reporting and working. 

In addition, energy audit systems have been installed in 400kV to 66kV, express feeder 

level and MIDC areas. 

‣ Disciplinary action against erring employees has also been initiated. 

On the issue of delay in metering, the MSEB has stated that the existing tariffs are not 

sufficient to meet expenses while, at the same time, it had to face severe liquidity problems 

on account of late subsidy payment and delay in receipts from PFC and REC. This led to 

delays in procurement and installation of meters as per schedule. The MSEB has added that 

the monthly status of implementation of ToD meters has been submitted to the Commission. 



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The MSEB has initiated energy audits at various levels as directed by the Commission in the 

previous Tariff Order. However, there does not seem to be any effort on the part of the 

MSEB to analyse the results of the energy audits and no action seems to have been 

undertaken in the circles/zones and the MIDC areas showing higher losses. The Commission 

would like the MSEB to initiate efforts to hold the officers in charge of the circles/zones 

showing higher losses responsible and ensure accountability. The MSEB is hereby directed to 

submit energy audit results at all levels on a monthly basis to the Commission, with details on 

the action taken to reduce the losses at each level. 

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 the previous Tariff 

Order. However, the MSEB has not achieved any significant progress in this aspect, and the 

Commission has taken serious note of this non-compliance with the Commission’s directives. 

10 REBATES/INCENTIVES 

The Railways have argued that an incentive should exist for prompt payment of dues as a 

corollary to Delayed Payment Surcharge (DPS). They have further suggested that DPS 

should be applicable from the date of delivery of the bill to the consumer as against the 

billing date as significant time is lost in transit leaving little time for processing of the bill at 

the consumer end. The MCCI has also suggested a similar incentive for improving the cash 

flows of the Board. Some objectors have requested the Commission to delink the prompt 

payment clause from the payment of bulk discount. 

Representations have also been received from the industry to further incentivise power factor 

improvement beyond 95% to encourage consumers to adopt energy efficient practices and 

better load management. It is suggested that 1.5% discount in the energy bill should be 

provided beyond 95% for every 1% improvement. TELCO has suggested 2% discount for 

every 1% rise in PF beyond 97%. It has further stated that while the incremental discount 

only amounts to Rs. 53 crore to the Board, it will make available 215MW and Rs. 1000 crore 

additional revenue. 

Representations have also been received to bring down EHT rates in relation to HT rates at 

par with UPSEB and TPC. One of the objectors has suggested concessions to industries 

maintaining higher load factor on a graded scale and has detailed an incentive scheme in the 

objection. 



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Garware Polyester has suggested modification of the provision of discount for bulk 

consumption @1% flat for every 1 million units consumed to a graded one with 0.1% 

discount for every 0.1 million units. They have also suggested rounding off to the next 

million for granting bulk discount as is applicable for computation of power factor incentives. 

They have further submitted that the bulk discount scheme has been brought forth to 

discourage bulk consumers from going for captive generation. So consumption of different 

manufacturing facilities under the same owner should be consolidated for discount provision. 

The MSEB has responded that it has not envisaged any change in the incentive structure. The 

MSEB has added that any revision in the incentive structure will have an impact on the 

revenue of the MSEB, which will have to be compensated. 

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, and, hence, no additional incentive is required to be 

given for prompt payment. If the consumers do not pay their bills on time, then the delayed 

payment charges and interest on delayed payment charges will be applicable. 

As regards the grading of the bulk discount for every 0.1 million units or rounding off to the 

higher whole number, the Commission has decided to retain the existing practice of rounding 

off the incentive to the lower whole number as it is sufficient incentive. The Commission is 

of the view that the consumption of separate units cannot be clubbed for the purpose of 

availing the bulk discount, as for the purposes of billing, the 2 units are separate consumers. 

As regards the power factor incentive, the Commission has considered the requests 

favourably as a higher power factor is beneficial to the MSEB Grid. The incentive has been 

increased for PF of 0.99 and higher such that, if the PF is 0.99, then the reduction in the 

electricity bills will amount to 5%, and for unity PF, the reduction will be 7%. 

11 SECURITY DEPOSIT (SD) 

Industry Associations have complained that the MSEB has been modifying the conditions 

and charges time and again leading to confusion. It is suggested that the procedure for 

charging the Security Deposit (SD) should be simplified by basing it on the last one-year 

average bill and by also accepting Bank Guarantee or a revolving letter of credit in lieu of the 

same. 

Mr. Pratap Hogade has pointed out that the MSEB has increased Security deposit amount and 

commenced collection of the same selectively at one/two districts at a time. He has argued 



73


that the Commission has not issued any order in this respect its order dated 5 th May 2000 and 

such hike is unwarranted. He has further requested the Commission to issue appropriate 

orders in this respect as tariff and tariff related aspects come under purview of the 

Commission. 

Another objector has suggested the rationalisation of delayed payment surcharge by putting it 

at the same rate as the interest paid on the security deposit by MSEB. He argued that it is 

irrational for MSEB to be paying lower interest on security deposit while charging higher rate 

for its own delayed payments. 

The MSEB has submitted that the security deposit is taken from the consumers due to the 

significant time gap between the consumption of electricity and the actual payment of the 

bill. A defaulting consumer’s supply is disconnected only after he has consumed electricity 

for about one month over and above the consumption in the preceding billing period. 

Therefore, it has contended that it is essential for the MSEB to hold sufficient security in 

order to safeguard its interests. The MSEB has further submitted that the amount of security 

deposit is linked to the bill amount and thus linked to tariffs, necessitating its increase on 

revision of tariffs. 

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 and that it is not binding on the 

Board 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. 

The MSEB’s argument regarding collection of Security Deposit is justified and in line with 

the Supreme Court’s ruling in this regard. As regards the collection of higher SD from the 

consumers is concerned, the SD is to be collected as a proportion of the average billing for 

the specified period, and the MSEB has increased the SD payable in line with the higher 

average billing subsequent to the Commission’s Tariff Order. 

The Commission had reduced the rate of interest on delayed payment in the previous Tariff 

Order. 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. 



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Moreover, the Supreme Court has ruled that it is not mandatory for the utility to pay any 

interest on the security deposit. 

12 SERVICE LINE CHARGES (SLC) 

It has been represented by Indian Steel that the EHV consumers invest a significant amount 

of capital in establishing transformers at their premises and also absorb transformation losses 

on their account apart from paying high SLC. It has also been represented that the prevailing 

practice of SLC being based on the maximum of connected load or contract demand is 

inappropriate. He argued that the loading of the network is decided by the maximum demand 

recorded by the meter rather than the connected load, which could be three to four times 

higher than the maximum demand established by the consumer. 

Industry Associations have also represented that the MSEB should not charge SLC for 

restoration of CD, if it has already been collected once from the consumer and not refunded 

at the time of reduction of CD, which is the prevailing practice. 

Mr D.V.R. Rao from Pune has submitted that the Commission has directed the MSEB in May 

2000 not to collect Fixed Service Connection Charges, Service Line charges and Meter Rent. 

It is stated that the MSEB still continues to charge SLC and connection charges and has 

enhanced fixed charges in lieu of meter rent collection. He has further objected to the 

assessment of Connected Load methodology employed by the MSEB by counting bulb socket 

and plug points as arbitrary and defying engineering logic. He contends that no electrical 

utility would establish generating capacity on the basis of total possible maximum demand 

that can be used by consumers. He has also demanded for provision of market rate of interest 

on the deposit payable every six months. 

The Akhil Bhartiya Grahak Panchayat has contended that the MSEB has been evasive in 

providing details of receipts on account of SLC and fixed service connection charges 

recovered from consumers. They have requested the Commission to direct the MSEB to 

provide such details for the past five years and deductions made from the values of yearly 

assets on account of consumer's contributions while working out returns. 

The MIDC Industries Association have contended that the service connection charges for HT 

consumers should be based on the contract demand only and not on the connected load as the 

connected load could be 3 to 4 times the maximum demand established by the consumer. 

The Commission is of the opinion that the determination and payment of SLC is within the 

scope of the ‘Conditions of Supply’, and the Commission will take up the issue of the 



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‘Conditions of Supply’ after the issue of this Tariff Order, as per the Mumbai High Court’s 

directive in this regard. The Mumbai High Court has issued an interim ruling that all 

modifications to the ‘Conditions of Supply’ after formation of the Commission have to be 

approved by the Commission. As regards the larger issue of the Commission’s jurisdiction to 

decide and formulate the ‘Conditions of Supply’, the matter is sub-judice. 

13 CAPTIVE POWER POLICY 

It has been represented by the industry that non-allowance of captive installation by the 

MSEB is a misuse of its monopolistic position. It has been further suggested that: 

• NOC should be valid for five years 

• The MSEB should enter into a PPA with captive unit to buy excess generation with 25 

years validity 

• Energy banking should be allowed on a 24 hour basis 

• Unit should be freely allowed to reduce its contract demand 

It has been argued that integration of surplus power generated by Captive Power Plant (CPP) 

at Rs. 3 per unit would reduce peak hour shortage and avoid blocking additional funds for 

generation augmentation. TELCO has suggested that the MSEB should revise its captive 

policy to reduce demand-generation gap. The MSEB should ensure scrutiny of application 

within 15 days with another 22 days maximum to inspect/modify system. It has also 

requested for withdrawal of 10% additional demand charges currently prevailing. It has 

further sought waiver of electricity duty on captive generation. 

The Vidarbha Industries Association has requested to include co-generation based on 

industrial heat in Non-conventional Energy Sources. The Ispat Industries Ltd. has opposed 

the clause of the load centre and the CPP to be located at the same place, in the CPP policy of 

the MSEB. He has argued that the plant should be located at a location to enable generation at 

cheapest cost depending on the type of fuel used. 

The MIDC Industries Association has contended that the demand charges of CPP holder 

synchronized with the grid or otherwise should be same as applicable to other category of HT 

consumers and also the demand charges should be based on billing demand or contract 

demand only. 

The MSEB has submitted that it has enclosed its Captive Power Policy for the general 

information of the public and is separately under review by the Commission. It has stated 

that the CPPs are supposed to have their economy of operations on a stand alone basis and 

the MSEB should not be required to purchase any excess power from them. It has further 



76


stated that the purchase price decision is under the review of the MERC provided that the 

MSEB intends to buy power. The MSEB has also submitted that the sale to third party is not 

within its statutory authority, but provision of such a clause would lead to significant loss of 

revenue to the MSEB. 

The Commission is of the opinion that the ‘Captive Power Policy’ is a policy matter under 

the jurisdiction of the Government of Maharashtra, and the Commission has very recently 

been conferred with additional powers under S. 22(2) of the ERC Act, 1998, which includes 

the power to aid and advise the GoM in the formulation of the State Power Policy. The 

Commission would not like to comment on the captive power policy at this stage, but would 

like to state that the MSEB has appended the captive power policy along with the Tariff 

Proposal for the information of the consumers, and the Commission’s silence on this policy 

should not be taken as approval of the same. 

14 POLICY FOR RENEWABLE ENERGY SOURCES 

The Renewable Energy Developer’s Association of Maharashtra (REDAM), Indian Wind 

Energy Association, Tata Finance and other objectors have represented the case of the 

developers of the power projects based on renewable/ non-conventional energy sector of the 

State and have opposed the policy put forth by the MSEB in the current tariff proposal on the 

following grounds: 

• Only Government of Maharashtra policy dated 09-07-1999 should hold regarding 

generation based on wind and solar energy. It has been further submitted that all the 

projects which have received NOC from MEDA, should be excluded from any 

amendment in the policy framework, which may be approved by MERC, as the 

development process on these projects has already been initiated based on GoM’s policy 

dated March 12, 1998. 

• Concept of merchant generator as suggested by the MSEB should not be made applicable. 

• As the MSEB will be collecting demand charges from the consumer purchasing energy 

from the wind farm project, it should continue to support the wing farm projects by way 

of purchase/banking guarantee 

• A wind farm project should be permitted to opt for sale of energy to third party buyer or 

the MSEB. To address the concerns of the MSEB, the developer’s ability to exercise this 

option during the life of the project as well as the time period between two consecutive 

options could be regulated by a suitable policy directive from the Commission. 

• The increase proposed for Transmission losses and wheeling charges applicable to wind 

farm projects has been opposed. Further, the proposal to link the wheeling charges with 



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distance has also been opposed on the ground that energy is transported by the principle 

of displacement. It has also been argued that as wind farms are situated close to the load 

centers, increasing use of this energy would also bring down the losses of MSEB. 

• Delayed bill payment by MSEB should attract an interest rate penalty equivalent to the 

Prime Lending Rate of the State Bank of India rather than at savings bank rate as 

proposed by MSEB. They have argued that the cash shortfall arising out of payment 

delays would have to be met through working capital borrowings at commercial rates. 

• Proposal of MSEB not to allow reduction in Contract Demand for the consumer of Wind 

Energy has also been opposed. 

• MSEB should give credit for units generated, in the descending order of the energy 

consumed in different time slabs 

• MSEB purchase rate should not have a ceiling with respect to variable component, of the 

HT industrial tariff as proposed by MSEB. 

• MSEB compares power from wind projects vis-à-vis variable cost from thermal power 

plants. Considering the present load shedding, the wind projects being decentralized will 

provide relief to rural areas presently not electrified. Thus, cost of power from wind 

projects should be compared only to cost of ‘no-power’. 

Mr. Ganpati Lad has argued against MSEB’s banking and wheeling policy. According to 

him, energy generated by industries through wind power during lean period should be 

permitted to be drawn in lean period and peak period credit should be given if energy is 

generated during peak period. Further, the MSEB should account for appropriate T&D losses 

and not nominal 2% to 6% while giving credit to industry for wheeling of such energy. 

The MSEB has responded that it has no intention of getting the policy for renewable energy 

sources approved by the Commission through the tariff process, and the policy was annexed 

to the Tariff Proposal, for the information of the public. 

The Commission is of the opinion that the ‘Policy for Renewable Energy Sources’ is a policy 

matter under the jurisdiction of the Government of Maharashtra, and the Commission has 

very recently been conferred with additional powers under S. 22(2) of the ERC Act, 1998, 

which includes the power to aid and advise the GoM in the formulation of the State Power 

Policy. The Commission would not like to comment on the policy for renewable energy 

sources at this stage, but would like to state that the MSEB has appended the captive power 

policy, which includes the policy for renewable energy sources, along with the Tariff 

Proposal for the information of the consumers, and the Commission’s silence on this policy 

should not be taken as approval of the same. 



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15 DEMAND SIDE MANAGEMENT (DSM) 

Prayas has stated that DSM is one of the cheapest options to meet the growing demand for 

power. They have argued that studies carried out by the objector during 1992-94 clearly 

demonstrated that adopting an integrated least cost power plan (including DSM and 

decentralized generation) would substantially reduce dependence on centralized fossil fuel 

based plants and would reduce costs by more than 30%. They further requested the 

Commission to direct the MSEB to submit a pilot DSM project for its approval within six 

months, targeting peak demand reduction by measures other than ToD tariff and addressing 

issues such as implementation difficulties, program benefits, costs and lessons for large scale 

replication. During the public hearings, Mr.S. R. Paranjape said that the entire load shedding 

can be avoided if the agricultural load is shifted to night-time, and through proper DSM 

techniques. 

The Commission is in agreement with Prayas’ suggestion and is of the opinion that there is an 

urgent need for implementing Demand Side Management measures apart from the ToD tariff. 

The MSEB should commission pilot DSM studies in the State. The MSEB should 

encourage the use of energy efficient devices, and publicize the benefits to the consumer 

through appropriate publicity media. The Commission has attempted to provide an 

incentive to consumers who install energy efficient pumps and devices, through a scheme 

discussed in detail in a subsequent section. 

16 DATA DISCREPANCY/INSUFFICIENCY 

The power loom associations have expressed concern over the decrease in revenue for FY 

2001-02 in the proposed filing as compared to the revenue filed by MSEB in the revised tariff 

proposal last year of Rs. 12733 crore by Rs. 1330.65 crore, despite a tariff increase granted 

by MERC vide its last tariff order. They have also pointed out a significant reduction in the 

number of consumers in the category from the last year’s filing as probably a typographical 

mistake. They have further pointed out an alleged fallacy of assuming 4.07% growth rate for 

the last ten years for LTPG consumers for projection purposes in the wake of the fact that 

30% of the power-looms in Bhiwandi region itself have closed down during the past year. 

TELCO has pointed out data inadequacies in the current proposal for important parameters 

like metering status, T&D loss estimation, etc. Similarly, it has also observed data 

discrepancies within the filing regarding number of industrial consumers, ToD meters 

installed, sale to un-metered power loom category and energy input for FY 1999-2000. It has 

also suggested that consumer category-wise disconnection details and theft detection should 

also be submitted in the filing. 



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The Pune Chapter of Cost Accountants has sought details regarding the Industrial 

Engineering Study conducted by the MSEB and submitted to the MERC. It has been 

suggested that the MSEB should provide the report to the public along with the actions taken 

on it. They have also suggested a comparative ratio analysis statement of accounts with other 

SEBs on operational parameters to be enclosed in the filing to encourage competition. In 

addition, they have submitted to the Commission that no basis or methodology has been 

provided for making tariff revisions differently to different categories of consumers. They 

have argued that the MSEB is following an ad hoc and subjective approach due to a lack of 

laid down principles. They have pointed out to the Commission that the number of new 

meters expected to be purchased in the filing is increasing from 3 lakhs to 17 lakhs, while 

only 1.25 lakhs new metered connections are expected to be released for agricultural 

consumers during FY 2001-02. 

Further, they have alleged that no justification has been provided in the proposal behind the 

statement of cost of service for LT consumers being higher than HT consumers and have 

argued against it on the basis of cost being distributed much more evenly due to a larger base. 

They have objected to the practice followed by MSEB of counting their inventory during the 

months of September and October 2001 as not a prudent accounting practice and should be 

conducted closer to the balance sheet date. Lastly, they have suggested that there should be 

financial audit, cost audit and efficiency audit of the organization for betterment of services. 

The Akhil Bhartiya Grahak Panchayat has suggested that the information provided in the 

proposal is un-audited and should, therefore, be subjected to expert scrutiny. 

Mr. N.D.Patil has demanded that, as the present Tariff proposal of the MSEB is a revision of 

the Tariff Proposal dated 16 th Mar 2001after MSEB has terminated its PPA with DPC on 23 rd 

May 2001, the MSEB should also provide information about the exact quantum and nature of 

savings in the cost due to the above development. 

Electricity Consumers Association has demanded audited financial statements for FY 2000- 

01 and provisional statements till September 2001 for studying the proposal in depth. They 

have also questioned the absence of any provision for contingent liability in case of default to 

the DPC that may cost up to 5 billion USD. The Mumbai Grahak Panchayat has suggested 

obtaining an undertaking from the State Government to bear the liability arising out of the 

DPC issue from its general revenue expenditure. 

On the issue of revenue discrepancy raised by power loom associations compared to last 

year’s filing, the MSEB has submitted that the estimated revenue income for the year FY 



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2000-01 as indicated in its last tariff proposal was based on the tariff then proposed by the 

MSEB in its tariff proposal. However, the tariffs prevailing presently are in accordance with 

the tariff order issued by the Commission in May 2000 and the same has been used for 

revenue estimation in the current filing for FY 2001-02, and thus the difference. Similarly, 

the MSEB has pointed out that the figure given against the un-metered categories in the 

proposal for FY 2000-01 is the number of looms and not the number of consumers. Further, it 

has stated that the difference for the metered category is primarily because of a partial 

conversion of the un-metered consumers into metered category. In addition, the figures given 

in FY 2000-01 filing were the estimates, while the figures shown for the FY 2000-01 in the 

present proposal for FY 2001-02 are actuals. 

On other data discrepancies pointed out, the MSEB has denied the discrepancies and made 

the following clarifications: 

No. of Industrial HT consumers 8180 As per compliance report as on Jun’01 

8221 On pg 2-21 as on March ‘01 

ToD meters already installed 5743 No such figure given on pg 2-21 

5700 All HT ToD meters 

Sale of power loom un-metered 958 MU Reference on Pg 2-17 is for 2000-01 

838MU Reference on pg 6-22 is for 2001-02 

Energy Input for 1999-00 57378 Pg 1-8, Vol I is net of purchase from TPC 

The Commission has considered all these issues and the MSEB has submitted clarifications 

on the same to the Commission. 

17 NON-COMPLIANCE WITH COMMISSION DIRECTIVES 

Mr. Hogade, during the public hearing, pointed out that the MSEB has not adhered to 11 out 

of 27 orders issued by MERC in its earlier Tariff order dated 5 th May 2000 (Pg 6 to 9) as 

given in the following Table: 



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Directive No. 

4 There is no mention about “Single bulb consumers” in this proposal as 

demanded by the Commission 

8 The Commission had requested information about “public 

organizations” till 30 th Sept 2000. This does not find mention in the 

proposal. 

9 The Commission expected separate category for “Software Technology 

Park”. This has also not found any place in the proposal. 

10 The order was to complete metering within 3 years. In reality, at the 

end of 2 nd yr (i.e. Mar-2002) power loom metering is expected to be 

completed & only 1.25 lakhs out of 18.83 lakhs agricultural consumers 

are expected covered under metering plan. 

12 TOD meters were expected to be completed till Dec-2000. However 

the process is underway and it is not sure when the target would be 

achieved. 

19 Consumption Norms in case of un-metered category are not 

appropriately determined & in fact modified for convenience. 

20 T&D loss was expected to be reduced to 26.9%, but in fact has reached 

39.4% 

22 Employee’s expenses were asked to be reduced by Rs 100 Cr to Rs 

1418.85 Cr. But in fact employee expenses increased to Rs. 1474 Cr. 

23 There is no clarity whether return should be 3% or 4.5% 

26 There was order for employees to wear name badges, but that is also 

not implemented. 

27 New connection should be issued within fixed time frame, but the 

same is not yet implemented. 

Several other objectors have also objected to the MSEB’s non-compliance with the 

Commission’s directives. They have added that it amounts to ‘contempt of court’ and suitable 

action should be taken against the MSEB for this non-compliance. The objectors have 

submitted that if non-payment of dues by consumers’ results in disconnection, then by 

applying the same logic, the MSEB should also be subject to severe penalties. 

The MSEB has said that it has submitted a compliance report to the Commission and the 

same is also enclosed in the tariff proposal. It has submitted the details of the single bulb 

consumers, Public institutions and Software Technology Parks to the Commission. 

On the issue of name badges to its employees, the MSEB has submitted that necessary 

instructions have already been issued to its field offices. 



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The Commission has taken a very serious note of the MSEB’s non-compliance of the 

Commission’s directives issued in the Tariff Order dated May 5, 2000. The Commission has 

disallowed revenue to the MSEB for the above non-compliance at the rate of Rs. 1 crore for 

each act of non-compliance amounting to Rs. 7 crore. This amount should be deposited in a 

special account together with the Energy Conservation Fund, discussed subsequently in the 

section on Energy Conservation. This is subject to the MSEB implementing the directives by 

the end of March 2002. The Commission would also like to warn the MSEB that any further 

disregard of the Commission’s directives will be considered as a penal offence and the 

Commission will not hesitate from initiating stern action under the provisions of the ERC Act 

against the concerned MSEB officials. 



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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 submitted that the process of 

tariff determination for FY 2001-02 has been delayed on account of certain developments. 

The MSEB had first submitted its proposal on March 15 th 2001, on account of the time taken 

to prepare the proposal after incorporating the impact of the projected commissioning of 

DPC-II, and the detailed merit order schedule. 

The MSEB has added that the Commission reverted to the MSEB only three months later, on 

15 th June 2001, querying whether the MSEB desired to revise the proposal in the light of the 

PPA with the DPC being rescinded in the last week of May 2001. The updating of the data 

and the proposal took a further three months, and the MSEB was able to submit the revised 

Tariff Proposal only by 28 th August 2001. The MSEB has submitted that the revised tariffs 

would need to generate the revenue requirement for the entire year, to preserve the 

requirement of S.59 of the E (S) Act. In other words, the MSEB has stated that the entire 

additional revenue requirement would have to be recovered through the revised tariffs 

applicable for only 5 months from November to March 2002. 

The Commission is of the view that there was no delay on its part in the determination of the 

revised tariff. The submission of the original tariff proposal for FY 2001-02 by the MSEB 

itself was delayed, as the Commission would require at least 3 months’ time to analyse the 

tariff proposal thoroughly, undertake the public process and pronounce the tariff order. This 

would have effectively meant that the MSEB could have implemented the revised tariffs 

earliest by July 1 st 2001, i.e., 3 months of the year would have been lost. 

Further, the appointed consumer representative under S.26 of the ERC Act, Prayas, had filed 

a petition dated 7 th October 2000 seeking various documents related to Power Purchase 

Agreements (PPA) with Independent Power Producers (IPP) signed by the MSEB. The 

MERC issued its Order on 12 th January 2001 directing the MSEB to provide all documents 

available in its custody to Prayas. However, the MSEB did not comply with this Order, citing 

the ‘confidentiality clause’ between the MSEB and the DPC, and consequently, important 

documents related to the DPC PPA such as the related project contracts, LNG transportation 

agreement and financing agreements for Phase II, were not made available to Prayas. 

Commission’s Analysis & 

Decision on MSEB’s Proposal 

84


Prayas submitted that these documents were absolutely essential for undertaking a 

meaningful and thorough analysis of various aspects related to the power purchase 

expenditure, which has serious implications on (a) economy and efficiency, (b) consumer 

interest, (c) power tariff and (d) transparency of subsidy policies. As the MSEB did not 

comply with the Commission’s Order, Prayas filed a further petition on April 3, 2001 seeking 

certain documents, and specifically prayed, “not to consider MSEB’s application for revision 

of tariff before considering and deciding on this application”. The MSEB reply on 3 rd July 

2001 claimed confidentiality before the Commission regarding the documents to avoid the 

risk of being sued, stating that the DPC had objected to the disclosure of the documents. The 

MSEB’s reply also stated, “since, at present, no notice has been fixed by this Honourable 

Commission on the proposal submitted by the MSEB for approval of revision of the tariff, the 

demand of Prayas for the said documents is premature”. The Commission issued its final 

Order in this case on July 31, 2001, in which it directed the MSEB to supply all documents 

asked by Prayas upholding the basic principle of maintaining transparency. 

Moreover, when the MSEB had submitted the original tariff application, there was a lot of 

uncertainty regarding the power purchase from the DPC Phase II, when the generation from 

Phase I itself was not being entirely purchased by the MSEB. The MSEB’s original tariff 

application had included the impact of the DPC-II, which amounted to a monthly fixed 

charge of over Rs. 500 crore, as projected by the MSEB. As the entire fuel cost was 

considered under fixed costs, on account of the ‘take or pay’ contract entered into with the 

DPC, the MSEB was in the unenviable position of having to purchase the entire generation 

from DPC – I and II, as the variable charge was only 2 paise/unit, and the DPC generation 

was thus the cheapest after MSEB’s own hydel generation. Consequently, the average cost of 

supply and the tariffs proposed by the MSEB were very high. 

In this scenario, the Commission was of the opinion, that it would be wiser to wait till the 

issue of power purchase from DPC-II became clearer, and the impact could be estimated 

more accurately. Even if the Commission had initiated the tariff process immediately after 

submission of the original tariff proposal by the MSEB in March 2001, the process would 

have got derailed due to the rescinding of the PPA by the MSEB on 29 th May 2001, and the 

MSEB would have had to submit a revised tariff proposal after removing the power purchase 

component from the DPC. 

The Commission would also like to place on record that after submission of the revised tariff 

proposal, the Commission set a very tight time-frame for itself for issue of the tariff order. 

However, due to the delay in submission of the requisite data by the MSEB, the Commission 

was forced to increase the time period for issue of the tariff order from two to three months. 



85


Subsequently, the GoM submitted a petition on 5 th November 2001 that it desired to subsidise 

selected categories of consumers, and requested the Commission to give the GoM an 

opportunity to appear personally before the Commission. 

The Commission expressed its displeasure to the GoM for the delay in submitting its case as, 

though the GoM had been given sufficient time and opportunity to appear before the 

Commission during the public hearing to state its case, the GoM had not availed of the 

opportunity. However, considering the magnitude of the GoM subsidy and the impact on 

tariffs for several categories, the Commission asked the GoM to submit an additional 

affidavit and to represent its case before the public in a public hearing on 24 th December 

2001. All this has resulted in the tariff hearing process continuing for a period of 4 months 

through no fault of the Commission or the public. 

The Commission has also been consistently of the view that the tariffs should not be applied 

retrospectively. Acceptance of the MSEB’s proposal to apply the revised tariffs from 

November to March 2002, such that the entire year’s additional revenue requirement is 

recovered in 5 months, 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. 

The Commission thus rules that the revised tariffs would be applicable for 3 months of FY 

2001-02, i.e., from 1 st January 2002 to 31 st March 2002, and till such further time as the 

MSEB does not approach the Commission for tariff revision. In this context, the Commission 

expects that the MSEB will not approach the Commission for tariff revision for FY 2002-03. 

The Commission also directs that, henceforth, the MSEB will submit a Tariff Proposal 

for a year, by the end of December of the previous financial year. In other words, the 

Commission expects the MSEB to submit a tariff revision proposal for FY 2003-04 

before the end of December 2002. 

19 REGULATORY ASSET 

The MSEB has submitted that if the revised tariffs had become applicable from the beginning 

of the year, the average tariff increase required would have been about 12%. As the revised 

tariffs would be applicable from November 2001 at the earliest, the revised tariffs would be 

applicable for only five months and would need to generate the revenue requirement for the 

entire year. As this would entail an average tariff increase of about 29%, the MSEB has 

proposed to recover a part of the expenses as Regulatory Asset to be recovered through 



86


amortization and interest in the Annual Revenue Requirement for FY 2002-03. Further, the 

MSEB has added that the amount of cost increases/decreases for FY 2001-02 already 

recovered through FOCA may be set off against the Regulatory Asset being considered for 

FY 2002-03. 

The Commission is of the view that creation of ‘Regulatory Asset’ should only be considered 

in exceptional cases wherein the recovery of the entire revenue requirement during a single 

year might lead to tariff shock, and so a part of the required revenue is deferred for future 

recovery. A mere delay in tariff award due to late submission of the tariff revision proposal 

cannot be considered sufficient ground for creation of a Regulatory asset, as the MSEB could 

have approached the Commission for tariff revision much earlier. Accordingly, the 

Commission has disallowed the creation of a Regulatory Asset. 

20 AVERAGE COST OF SUPPLY 

The MSEB has submitted that the tariffs should reflect the cost of supply to the particular 

consumer category, i.e., the cost of supply at that voltage. Since the LT cost of supply is 

higher than that of HT supply, the LT tariffs should be higher than HT tariffs. The existing 

tariffs, however, are exactly in reverse, with the HT tariffs being much higher than LT tariffs. 

The MSEB has added that if the LT cost of supply is designed to reflect the LT cost of 

supply, then the tariff increase for LT consumers will be substantial. Hence, the MSEB has 

proposed that the tariffs should be linked to the average cost of supply. 

The Commission, in its previous Tariff Order dated May 5 th 2000, had stated that the tariffs 

would gradually approach the average cost of supply, and that the Commission would attempt 

to eliminate 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. The Commission has commissioned a study to determine the voltage-wise cost of 

supply for all power utilities in the State of Maharashtra. Based on the findings of the study, 

the Commission will determine the relationship between the category-wise tariffs and the 

voltage-wise cost of supply. 

21 GOVERNMENT OF MAHARASHTRA SUBSIDY 

The MSEB’s tariff proposal has not assumed any subsidy from the GoM. On the final day of 

the public hearings, the GoM representative requested the Commission to grant additional 

time for making its submission. On November 5, 2001, the GoM submitted an affidavit 

stating that the GoM had the power to issue policy directives to the Commission in the public 

interest, under S.39 of the ERC Act. The GoM submitted that the tariff for domestic, 

agriculture, power loom, street light, and public water works should be set within certain 



87


limits specified by the GoM, with the loss in revenue on this account to be made up partly by 

increasing the cross-subsidy and the balance of Rs. 550 crore would be paid by the GoM. The 

GoM specified the category-wise tariffs to be charged, and also requested the Commission 

for an opportunity to present its case in person. The Commission granted the GoM’s request 

for a hearing, and also invited the nominated consumer representatives for the meeting, which 

was held on 20 th November 2001. 

During this meeting, the GoM explained its stand, and the consumer representatives were 

also given an opportunity to voice their opinion. The Commission directed the GoM to file a 

fresh affidavit explaining its rationale for subsidising selected consumer categories and to 

expand on any other related issues, and also ruled that the GoM would have to explain its 

rationale in a public hearing, considering the importance of the issues involved. 

The Commission, after studying the relevant provisions and the judicial pronouncements of 

the apex court on this matter is of the firm view that though the GoM can issue policy 

directives to the Commission, the power to determine tariff rests solely with the Commission. 

The GoM has also taken the legal advice of the Advocate General of Maharashtra, Mr. 

Goolam Vahanvati, in the matter of issuing policy directives to the Commission. The 

Advocate General’s opinion in this regard is: 

♦ 

♦ 

♦ 

The Commission is set up as an independent Commission charged with discharging 

stautory functions. It is well settled that in the matter of adjudicatory functions, the 

authority concerned cannot be given directions to decide matters in a particular manner. 

The Supreme Court has held that no authority, however high, can control the decisions of 

a judicial or quasi-judicial authority. See Orient Paper Mills Ltd. v/s Union of India 

(1970), 3 SCC 76. 

All that Government can do is to lay down general directions in matters of policy 

involving public interest and the State Commission can be guided by such directions. 

However, the word “guided” does not mean that what is given by way of guidance has to 

be followed compulsorily. The word “guide” connotes laying down a ‘standard’ or norm. 

The Government can lay down general matters of policy for the guidance of the 

Commission. This would have to be taken into account by the Commission as one of the 

relevant factors, but they will not be binding on the Commission. 

Subsequent to the second affidavit filed by the GoM in this regard, several objectors have 

filed their objections. The MSEB has also filed its response on affidavit against the GoM’s 

stated intention to adjust the tariffs and to provide subsidy to selected consumers. 



88


The MSEB has requested that the Commission should: 

a) prescribe detailed procedures for announcement of any subsidy by the GoM under 

Sec. 29 (2) of the ERC Act and for advance compensation to the MSEB, and 

b) enable the MSEB to access GoM grants to municipal bodies to liquidate the arrears of 

PWW and Street Lighting consumers. 

The MSEB has submitted that the rates proposed by the GoM compromise several basic tariff 

principles applied by the MSEB, which have been summarized below: 

♦ 

♦ 

♦ 

♦ 

♦ 

♦ 

♦ 

The proposed rates defeat the intention of the MSEB to rationalize the existing tariff 

structure. 

The proposed rates would increase the incentive of misclassification and collusion and 

would further increase the MSEB’s dependence on its meter readers. Further, it is not 

desirable from an operational viewpoint to levy fixed charges in a given category, which 

can vary with the level of consumption. 

The proposed rates would not significantly reduce the subsidy requirement of the 

categories. 

The proposed rates for subsidising categories would actually increase the cross-subsidy 

and move the category away from the average cost of supply. Any further increase in this 

category would be counterproductive and would lead to increase in theft of energy and 

decrease in consumption (and, hence, the MSEB’s revenue) instead of improving the 

revenue from these categories. 

The proposed tariffs for flat rate category would still keep un-metered tariffs cheaper than 

the metered tariffs and would hamper the meterisation programme of the MSEB. 

The proposed agricultural tariffs almost bring the un-metered tariffs to above the metered 

tariff. However, the differential is so small that it would be more economical for the 

farmer to remain un-metered rather than converting to metered consumption and paying 

the same cost as earlier and also bearing the additional cost of the meter. This would 

seriously hamper the meterisation programme of the MSEB. 

The proposed rate for LT and HT agriculture metered category would not significantly 

increase the fixed revenues for the MSEB. 

The MSEB has further added that the delay of every month in the issue of the Tariff Order 

means that the MSEB will not be able to recover about Rs. 190 crore per month, based on the 

proposed tariffs. The MSEB requested that it should be compensated adequately in the case 

of any further delay. The MSEB hoped that the Commission will adopt the tariff principles as 

proposed by the MSEB while determining the tariffs applicable to each consumer category. If 

the Commission so desires, it could then further reduce the tariffs for the above categories to 



89


the extent of the subsidy amount as quoted in the GoM petition. The Commission should, 

however, ensure that these subsidy amounts are paid upfront to the MSEB in cash. The 

public hearing on the GoM petition was held on 24 th December 2001 in Mumbai. 

The objections filed by the consumers against the GoM petition and the points raised during 

the public hearing held on 24 December 2001, have been summarized below: 

21.1 GoM Role in Tariff Determination Process 

Several objectors representing the agricultural and power loom categories have opined that 

the GoM is fully empowered to issue policy directives, though the specific tariff 

determination is within the powers of the Commission. They added that the GoM has the 

right to guide the Commission in respect of policy matters relating to public interest as far as 

it related to identifying consumer categories needing subsidy protection. They agreed with 

the GoM’s perception that if the tariffs proposed by the MSEB were accepted, then there 

would be law and order problems. Mr. Hogade of the Janata Dal stated that even the domestic 

consumers, small-scale industry and the slum dwellers would be hard hit by the proposed 

tariffs and would protest the tariff hike. The objectors added that the affordability or ability to 

pay should be the guiding principle while determining the tariffs, as otherwise it would lead 

to law and order problems. 

Several objectors representing the industrial category as well as Prayas said that the GoM’s 

application should not be entertained as the public process was declared as complete on 16 th 

October 2001, and the GoM had not made any submission at that stage, apart from asking for 

additional time. The objectors added that the Advocate General’s clarification on the 

interpretation of S.39 of the ERC Act had made it amply clear that the GoM’s affidavit was to 

be merely considered as a guideline and was not binding on the Commission. Some objectors 

added that the GoM should compensate the MSEB for the delay in determination of the tariff 

on account of the delay caused by the GoM, and the MSEB or its consumers should not have 

to pay for the losses on account of the delay in GoM petition. 

One objector has stated that except for categories such as PWW and street lighting, all other 

electricity consumption activities pertained to personal gain and comfort and do not relate to 

the common public cause. Hence, consideration of these tariffs does not represent 

consideration of the public interest at large, but consideration of particular classes of society. 

Mr. S.R.Paranjape said that the GoM has not furnished any reasons for stating that the tariff 

hike proposed by the MSEB was unrealistic, and that, in fact, the GoM’s proposal was adhoc. 

The MIDC Industries Association said that the GoM plea that the law and order was under 



90


threat should not be accepted, as it would open the door for similar claims/threats from other 

consumer categories. 

21.2 Tariffs Proposed by the GoM 

All objectors representing the industrial category objected to the increase in cross-subsidy 

proposed by the GoM, and stated that the GoM’s proposed tariffs were against the principles 

of the ERC Act, as well as in contravention to the direction set by the Commission in this 

regard, in its earlier Tariff Order. Most of the objectors said that the GoM’s proposal had no 

logical rationale and should be rejected. They added that the GoM was showing undue 

preference to certain classes of consumers and if the GoM desired to protect these categories, 

the GoM should pay the difference in tariffs to the MSEB as open subsidy, and the crosssubsidy 

burden should not be increased further. The GoM’s proposal also lacked details on 

ToD tariffs and other incentives and penalties. 

The objectors opined that any further increase in industrial tariffs would lead to migration of 

the industry and closure of several industries, which would affect the GoM’s revenue. One 

objector has submitted that the GoM’s proposal for subsidised tariffs for rural PWW and 

street lighting should not be considered till all the arrears are recovered from these categories. 

Several objectors questioned the tariff calculations presented by the GoM and highlighted 

arithmetical inaccuracies in the revenue calculation. They also questioned the treatment 

proposed by the GoM for the deficit of Rs. 550 crore if the tariffs proposed by the GoM were 

to be accepted in toto. Mr. S. R.Paranjape stated that as the gap of Rs.550 crore was with 

respect to the revised tariffs being applicable for only 5 months, then the effective reduction 

in tariff proposed by the GoM over the entire year amounted to Rs. 1320 crore, which was 

almost equal to the Uncovered Gap projected by the GoM. 

The objectors representing the agricultural and power loom categories said that the tariffs 

proposed by the GoM for these categories were themselves very high, and the tariffs needed 

to be lowered. They requested the Commission to retain the flat rate tariff system, as it was 

beneficial to the MSEB. They added that the GoM’s intention that the tariff hike should be 

gradual and spread over a period of 4 to 5 years was justified and should be accepted by the 

Commission. One objector added that the GoM’s proposal had indicated a lower flat rate 

tariff for power loom but, at the same time, increased the tariff for the LTP-G category, in 

which the metered power loom category was classified. Some objectors said that the GoM 

petition was contradictory to the GoM’s own affidavit submitted earlier stating that the GoM 

subsidy would amount to Rs. 500 crore in FY 2001-02, and the power loom tariff would be 

Rs.250 per loom per month. 



91


Mr. Y. V. Tamhane, representing the Mill Owners’ Association, said that there should be no 

differentiation between the power looms and the composite mill industry, and the tariffs for 

both categories should be the same, and the level of subsidy, if any, should also be 

maintained at the same level for both categories. The Mula Pravara Electric Co-operative 

Society (MPECS) has stated that the difference between the ‘Viable Tariff’ as determined by 

the GoM formula and the revised tariff should be paid by the GoM as subsidy. 

21.3 Other Issues in GoM Proposal 

Some objectors stated that the penal interest on account of the late payment of Electricity 

Duty to the GoM should not be included in the Revenue Requirement, as the GoM had 

clarified that the delay in payment of subsidy was responsible for the delay in payment of 

Electricity Duty by the MSEB, and a proposal was being considered by the Finance 

Department for waiver of the same. 

Other categories such as Small Scale Industries (SSI) and flour mills said that they were also 

deserving of subsidy, as they were passing through very bad times, and they were in no 

position to pay the high electricity bills, especially the demand charges. They requested the 

Commission to create a separate category with reduced tariffs and either eliminate or reduce 

the demand charges for their category. One objector said that the demand charge for LTP-G 

category should be linked to the Maximum Demand and not to the Connected Load. 

Ms. Laxmi Gopalan, Joint Secretary, Ministry of Energy, GoM, represented the GoM during 

the public hearing. She reiterated that the GoM’s petition should be considered only as a 

guideline and was not mandatory on the Commission. The tariff hike should be gradual and 

spread over 4 to 5 years. She clarified that the delay in submitting the petition was due to the 

fact that several people had approached the Chief Minister’s office apprehending a law and 

order problem in the State, due to the high tariffs proposed by the MSEB. Subsequently, a 

Cabinet Sub-Committee was formed to decide on the GoM’s course of action and, hence, the 

delay. She requested the Commission to condone the delay, and stated that it was not the 

intention of the GoM to delay the tariff process. She added that the local bodies had been 

directed to pay their electricity bills on time, and the proposal to directly remit the amount to 

the MSEB was also under consideration. As regards the Mula Pravara Society, she clarified 

that all arrears prior to May 1 st 2000, based on the viable tariff calculations, would have to be 

collected from the Society. The GoM was considering a subsidy for the difference in tariffs 

between the Viable Tariff and the tariffs determined by the Commission after May 2000. 



92


The Commission is not satisfied with the GoM’s delay in submitting its petition, despite the 

Commission’s efforts to involve the GoM from the very first day of technical validation 

session. The Commission would like to inform the GoM that, henceforth, if the GoM 

delays its submission unconscionably, then it will not be considered. 

The Commission is in agreement with the Advocate General’s clarification that the GoM can 

only guide the Commission in matters of policy and the authority of tariff determination is 

vested with the Commission under S. 29 of the ERC Act read with Section 22 thereof. The 

Commission has hence ignored the category-wise tariffs proposed by the GoM and has only 

considered the policy that the GoM desires to subsidise the domestic, power loom, 

agricultural, LT PWW and street lighting categories. The GoM has been asked to submit a 

detailed petition under S.29 (5) of the ERC Act, stating the subsidy to be given to the 

subsidized categories, in relation to the tariffs determined by the Commission and the total 

amount of subsidy being paid by the GoM. Once the GoM submits the petition, the 

Commission will take a view on the tariffs to be charged to the subsidized categories after 

incorporation of the GoM subsidy. In the interim, the MSEB will charge all the consumers as 

per the revised tariffs determined by the Commission. The Commission would also like to 

reiterate that the GoM subsidy has to be paid in cash every month to the MSEB. 

22 CROSS-SUBSIDY REDUCTION 

The Commission had initiated the process of reduction of cross-subsidy in the previous Tariff 

Order, by reducing the tariffs of subsidizing categories (HT industrial, commercial, etc.) and 

increasing the tariffs of subsidized categories (agriculture, domestic, power loom, etc.). The 

Commission has continued the process in this Tariff Order also. The Commission has 

reduced the tariff for subsidizing categories, both in nominal terms as well as in real terms, in 

relation to the average cost of supply. However, as the tariffs for subsidized categories are 

still very low in comparison to the average cost of supply, the Commission is constrained and 

is unable to increase the tariff for subsidized categories substantially, as it would result in 

undesirable tariff shock. The Commission has also attempted to reduce the intra-category 

subsidy, by reducing the difference in tariffs between the different slabs. 

As discussed earlier, the Commission will determine the agricultural tariffs with a view to 

eliminating cross-subsidy over a period of time. The time frame and the method will be 

finalized based on the findings of the study already commissioned to determine the cost of 

electricity in agricultural production. The Commission reiterates its observation that it sees no 

reason to cross-subsidize a consumer category such as power loom, and has hence increased 

the tariffs over the existing metered tariffs, though the MSEB has not completed its meter 



93


installation programme. As regards the consumer categories such as street lighting and public 

water works, the consumers, in both cases, are the local municipal authorities, who are often 

cash strapped, and do not pay their dues in time. Moreover, the MSEB cannot disconnect 

these consumers due to probable law and order problems that may arise on account of the fact 

that these are services vital to the ordinary life of the community. 

23 RATIONALIZATION OF CATEGORIES 

The MSEB has proposed a very steep reduction in the number of categories and slabs from 

39 to 15. The MSEB’s proposal envisages reduction of HT categories to only three and 

elimination of all slabs except for the lowest slab within the domestic category. The MSEB 

has justified the drastic reduction in the number of categories and slabs by citing the move 

towards reduction in cross-subsidy, both between categories and within categories. 

The Commission is of the opinion that the rationalization of categories proposed by the 

MSEB is too drastic, though the broad approach is correct. The Commission would also like 

to reduce the number of categories and slabs to the maximum possible extent, in the longterm. 

The Commission has hence opted for a more moderate reduction in the number of 

categories and slabs, which is described in detail in the section on category-wise tariffs. 

24 TIME OF THE DAY TARIFF 

The Commission had introduced the ToD tariffs for HT industrial categories in the previous 

Tariff Order dated May 5, 2000. The MSEB has submitted the ToD consumption data for the 

year FY 2000-01 in the Tariff Proposal. The Commission, hence asked the MSEB to submit 

the ToD data for the original population of ToD meters, as in May 2000. The analysis of the 

ToD data for these consumers is presented in the following graph: 

The available data shows that the HT industrial consumption has shifted to some extent as a 

result of the ToD tariffs. Further analysis over a longer period reveals that there has been a 

significant shift in the demand from peak to off-peak hours. Moreover, the maximum demand 

recorded has reduced over the year. 



94


% Share 

45% 

40% 

35% 

30% 

25% 

20% 

15% 

10% 

5% 

0% 

ToD Consumption Trend 

Jun-00 Jul-00 Aug-00 Sep-00 Oct-00 Nov-00 Dec-00 Jan-01 Feb-01 Mar-01 

2200 - 0600 0600 - 0900 & 1200 -1800 0900 - 1200 1800 - 2200 

The Commission has hence decided to incentivise off-peak consumption further, while 

increasing the tariff for peak time consumption, in the hope that the HT industrial 

consumption pattern will undergo a shift from peak to off-peak hours, such that the system 

peak lowers and the incidence of load shedding is reduced. The Commission has also 

introduced ToD tariffs for HTP-III, HTP-IV and LTP-G category, in line with the 

Commission’s intention to extend the ToD tariffs to other categories, as detailed in the 

previous Tariff Order. The ToD tariff for LTP-G category will be applicable for only those 

consumers who opt for the LTMD based metering. 

25 METERING 

The MSEB’s progress of metering has left much to be desired. The MSEB had projected 

100% metering of power loom category, HT agricultural category and installation of ToD 

meters for HT industrial consumers, by the end of the calendar year 2000. The Commission 

had also directed the MSEB to install meters for LT agricultural consumers in such a manner 

that 100% metering was achieved in three years time, i. e., by May 2003. However, the 

MSEB has defaulted in all the areas, and has only installed about 1.25 lakh meters for LT 

agricultural consumers, including new connections. 

The Commission has taken a very serious view of this default on the part of the MSEB. The 

Commission’s ruling in this regard is detailed in the relevant section. 

The MSEB has submitted in the current Tariff Proposal that it will achieve 100% metering 

for power loom by March 2002 as well as for the LT agricultural category in three years from 

now. The Commission is not fully convinced about the MSEB’s seriousness in implementing 

these directives. The Commission hereby directs the MSEB to achieve all the metering 

targets projected by the MSEB as well as those directed by the Commission, as per 



95


schedule. In case there is slippage in the achievement of these targets, the Commission 

will be constrained to take serious action in the matter. 

26 STATUS OF REFORMS 

The Commission had issued certain directives to the MSEB in the previous Tariff Order 

dated May 5, 2000. The Commission had also initiated the process of tariff rationalization 

and improvement in the operational efficiency of the MSEB on selected parameters. The 

Commission has discussed the status of the various initiatives of the Commission as well as 

the directives of the Commission in this Tariff Order. 

26.1 Non-compliance of Commission’s Directives 

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 vide the Tariff Order dated May 5, 2000. 

However, the Commission has found that the MSEB has defaulted on the directives on seven 

counts, viz. 

♦ 

♦ 

♦ 

♦ 

♦ 

♦ 

Installation of ToD meters for all HT industrial consumers by September 2000 – the 

MSEB has not installed ToD meters for all HT industrial consumers till date 

Installation of meters for the flat rate categories, viz. LT and HT agriculture, Power loom 

and Municipal Councils – the MSEB has indicated installation of meters for only 1.25 

lakh agricultural consumers at the end of FY 2001-02, as against the total un-metered 

population of over 17.5 lakh consumers; no meters have been installed for power loom 

and municipal councils. It is all the more surprising that the MSEB has not metered even 

the HT LIS (only 1100 consumers) and ‘C’ class Municipal Councils (only 560 

connections). 

Provision for 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. 

Domestic Supply to Railways – In this case too, the MSEB has cited the issuance of a 

Circular to justify the compliance 

Disconnection of Supply to consumers for arrears over 75 days – the MSEB has 

submitted that it has not disconnected agricultural and power loom consumers in line with 

GoM directives in this regard. 

No commercial circulars to be issued by the MSEB without the prior approval of the 

Commission. 



96


♦ 

The MSEB was directed to submit data on public institutions to enable the Commission to 

charge average cost of supply tariffs to this category – the MSEB has not complied. 

The Commission has disallowed revenue to the MSEB for the above non-compliance at the 

rate of Rs. 1 crore for each act of non-compliance amounting to Rs. 7 crore. This amount 

should be deposited in a special account together with the Energy Conservation Fund, 

discussed subsequently in the section on Energy Conservation. 

The Commission would like to inform the MSEB that all the directives issued by the 

Commission in the previous Tariff Order of May 2000 are still applicable, and the 

MSEB is directed to comply with the same before 31 st March 2002. 

Apart from the above directives, which have not been complied with, there were other 

important directives and steps initiated by the Commission in the previous Tariff Order, 

which are discussed below: 

♦ 

♦ 

♦ 

The most important direction was the reduction of T & D losses. The performance of the 

MSEB in this regard and the Commission’s treatment of the same have been discussed in 

detail in earlier sections. 

The Commission had introduced the Bulk Discount and Prompt Payment incentive and 

modified the provision for PF incentives, with the intention of improving the cash flows 

of the MSEB and the efficiency of the system. Both these initiatives have shown the 

desired results, and the consumers have become more aware of the need for maintaining 

the PF above 0.95 and make prompt payment of the bills. The Commission has increased 

the PF incentive through this Order (detailed in subsequent sections), to further improve 

the efficiency of the grid. 

The Commission had initiated the process of tariff rationalization and had declared that 

the Commission intended to eliminate cross-subsidies over a period of 5 years, starting 

from May 2000. The Table in the Section on ‘Tariff Design Principles’ shows the 

movement of the average realization towards the average cost of supply for all categories. 

♦ The Commission had introduced ToD tariffs for HT industrial consumers in May 2000, 

and had declared that it intended to introduce ToD tariffs for other HT consumers 

(excluding Railways) as well as LT industrial consumers. The MSEB has delayed the 

installation of the ToD meters for HT industrial consumers, and was hopeful of 

completing the process just recently. The objective of the introduction of ToD tariffs was 

to enable the flattening of the load curve, which has been achieved to a certain extent. In 

this Order, the Commission has extended the ToD tariff for HT PWW and LTP-G 

category, in line with the philosophy adopted by the Commission. 



97


♦ 

♦ 

♦ 

♦ 

♦ 

♦ 

♦ 

The Commission had asked the MSEB to submit a Master Metering Plan (MMP) for 

achieving 100% metering. The MSEB submitted the MMP after a lot of delay, and has 

not met the targets set by its MMP. The Commission has considered this aspect under 

non-compliance earlier. 

The Commission had also directed the MSEB to release all new connections only on 

metered basis, and the MSEB has adhered to this directive. This has ensured that at least 

there is no increase in the number of un-metered connections. 

The Commission had initiated the process of planning generation and power purchase on 

the basis of merit order despatch in the previous Order, and has been regularly reviewing 

the performance of the MSEB in this regard. In the current Tariff Proposal, the MSEB has 

submitted its detailed generation and power purchase programme based on merit order 

principles, and the Commission has applied the same methodology with some 

modifications, discussed in the section on generation and power purchase expenses. 

There was a lot of confusion regarding the levy of FCA by the MSEB, and the 

Commission had directed the MSEB that FCA could be charged only after approval of the 

FCA Formula by the Commission. Subsequently, the Commission has approved a 

formula for levy of Fuel and Other Cost Adjustment (FOCA) charges, and the MSEB has 

been charging FOCA based on this formula. 

The Commission had ordered a freeze on recruitment by the MSEB, in an attempt to 

control the employee expenses, and the MSEB has adhered to this directive. 

The Commission had directed the MSEB to independent industrial engineers/agencies to 

conduct an independent technical audit of the O & M expenses incurred by the MSEB. 

The MSEB has appointed the National Productivity Council (NPC) for conducting the 

above audit. The Commission directs the MSEB to facilitate the speedy completion of 

the study and submit the report to the Commission before March 31, 2002. 

The Commission had directed the MSEB to conduct a detailed study of the coal 

procurement process, supply, use of coal and accounting methods, through independent 

consultants. The MSEB has commissioned a study by the Central Electricity Authority 

(CEA) to conduct the above study. This will enable the MSEB and the Commission to 

understand the system of coal procurement, the occurrence and the extent of transit 

losses. The MSEB is directed to submit this report before 31 st March 2001. 

27 PROJECTED ENERGY INPUT REQUIREMENT 

The summation of the category-wise sales and the T & D loss allowed by the Commission 

gives the energy input required. 



98


27.1 Sales Projections 

The category-wise sales projections are detailed in this section. The Commission has applied 

the same methodology used in the previous Tariff Order, 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 2000-01. The sales in FY 2000-01 have been adjusted for the loss in sales due to load 

shedding as submitted by the MSEB. 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 2001-02. The number of consumers in different categories has been 

projected based on the ten-year CAGR. 

The category-wise sales have been apportioned to different slabs on the same basis as the 

average monthly slab-wise sales in FY 1999-00 and FY 2000-01. The HT industrial sales 

have been apportioned to different ToD slots based on the actual average monthly ToD 

consumption pattern in FY 2000-01. The number of consumers in different slabs has also 

been projected in the same manner. The categories and the category-wise sales projections 

have been summarised below, and discussed in detail subsequently. 

27.1.1 LT Category 

Projected Sales to the LT Category (FY 2001-02) 

Category 

MSEB 

Projections 

– FY 2001- 

02* 

Actual Sales – 

FY 2000-01 $ 10 year 

CAGR 

(in MU) 

MERC 

Estimate – 

FY 2001-02 * 

Domestic 7741 6582 9.78% *** 7926 

Non-domestic 1524 1349 7.73% *** 1594 

LTP-G (incl Power 

loom) 

Public 

Works 

Water 

3392 3006 3318 

577 571 577 

Agriculture ** 7846 7542 $$ 7553 

Street Lighting 425 383 7.04% *** 450 

Total LT Category 21505 19710 21419 

Note: 

* - Without Load shedding 

$ - After accounting for loss in sales due to Load shedding 

$$ - Revised norm of 1250 hrs/HP/year 

** - including LT Poultry 

*** - including un-met sales as submitted by the MSEB on account of load shedding 



99


The total sales to the LT consumer category has been summarized in the above table. The 

sales projected by the Commission are lower than that projected by the MSEB due to the fact 

that the Commission has applied the revised norm of 1250 hours/HP/year for LT agricultural 

consumption. The Commission’s sales projections for other categories have been higher than 

that projected by the MSEB, in most cases. 

It should also be noted that the Commission has not considered any loss in sales on account 

of load shedding, because the MSEB is expected to shed agricultural load first and to shed 

commercial and domestic load only if absolutely essential. The very nature of agricultural 

load is such that load shedding will result in shifting the load and there will be no permanent 

loss in the load. Moreover, it is not possible to project the probable loss in sales on this 

account. The consumption of a category has been apportioned to different slabs on the basis 

of the proportion of consumption in that slab over the past two years. 

The category-wise sales projections, slab structure and slab-wise consumption have been 

discussed below: 

27.1.1.1 Domestic Category 

The Commission has retained the four slabs in this category. The estimated slab-wise 

consumption is given below: 

Domestic Category: Slab-wise consumption 

Monthly 

Consumption 

Average 

Consumption - 

FY 1999-00 and 

FY 2000-01 

Share of 

Consumption 

(in MU) 

MERC Estimate 

– FY 2001-02 

1 – 30 units 2524 39.76% 3170 

31 – 100 units 2229 35.13% 2774 

101- 300 units 915 14.43% 1110 

Above 300 units 681 10.68% 872 

Total 6349 100% 7926 

The Commission had indicated in the previous Tariff Order that it intended to create a 

separate slab for consumption below 15 units per month, called ‘Kutir Jyoti’, as well as 

separate categories for public institutions. However, the Commission has not implemented 

this, as the MSEB has not submitted the data in this regard to the Commission. Moreover, as 

the Commission intends that the number of categories and slabs should be reduced and all the 



100


tariffs should move towards the average/voltage wise cost of supply, there will be no benefit 

in creating additional categories. 

27.1.1.2 Non-domestic Category 

The Commission has retained the three slabs in this category, as shown below: 

Non-domestic Category: Slab-wise consumption 

Monthly 

Consumption 

Average 

Consumption - 

FY 1999-00 and 

FY 2000-01 

Share of 

Consumption 

(in MU) 

MERC Estimate 

– FY 2001-02 

1 – 100 units 588 44.59% 711 

101 – 200 units 171 12.99% 207 

Above 200 units 558 42.42% 676 

Total 1318 100% 1594 

27.1.1.3 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. At that 

time, most of the power loom consumers were un-metered, and the MSEB had committed to 

meter all power loom consumers within six months. The Commission had accordingly 

included this consumption under the smallest slab within the LT industrial category, in the 

previous order, and had estimated the sales revenue from the power loom category on 

metered basis only. 

The MSEB has, however, defaulted on the metering commitments, and has not installed 

meters in the power loom consumers’ premises. As the MSEB is to blame for this, the 

Commission has retained the practice of including the consumption under metered 

consumption, and tariffs have been designed accordingly. During the public hearing process 

in the case of the Review Petitions filed by the power loom associations against the previous 

Tariff Order, the power loom consumers had submitted that the consumption norm of 10 

hours per day was inaccurate, and the looms were operational for only 8 hours per day. This 

issue was reiterated during the public hearing process on the current Tariff Proposal also, and 

the MSEB has also submitted that the power looms are operational for only 8 hours per day. 

The Commission has accordingly assessed the un-metered consumption based on the 

consumption norm of 8 hours per loom per day (1 loom being equal to 1 HP of connected 

load), on a best effort basis, though there is no scientific evidence to support either 10 hours 



101


or 8 hours of daily operation. This is equivalent to a consumption of 182 units per loom per 

month. 

It should be noted that the MSEB has submitted that as per the latest computerized billing 

records, the number of looms and the connected load have reduced as compared to the 

submissions made in the previous Tariff Proposal. The Commission has accordingly assessed 

the un-metered sales based on the revised connected load numbers. 

The Commission has reduced the number of slabs within LTP-G category to three, by 

merging the 1-300 units slab with the 301 – 1000 units slab. The projected slab-wise 

consumption has been given in the following table: 

LTP-G Category: Slab-wise consumption 

Monthly 

Consumption 

LT Industrial * 

Share of 

Consumption 

(in MU) 

MERC Estimate 

– FY 2001-02 

1 – 1000 units 45.81% 1116 

1001- 15000 units 39.50% 992 

Above 15000 units 14.69% 372 

Power loom $ 838 

Total 3318 

Note: * - includes power loom metered consumption 

$ -Assessed power loom un-metered consumption, included in lowest slab for tariff purposes 

27.1.1.4 Public Water Works (PWW) Category 

This category has two sub-categories, viz., Urban PWW and Rural PWW. Each sub-category 

has further sub-classes, as detailed below: 

27.1.1.5 Urban PWW 

The Commission has continued the process of rationalization of slabs, which was started in 

the previous Tariff Order, and has removed all slabs within this sub-category. The entire 

consumption in this category is metered. 

27.1.1.6 Rural PWW 

The Commission has merged the sub-classes having metered tariff, viz., ‘C’ Class Municipal 

Councils and metered tariff category. In the case of ‘C’ class municipal councils, the 

Commission had directed the MSEB to install meters for this category, and in the interim 

period, the flat rate tariff would be applicable. However, the MSEB has not implemented this 

directive and has not metered this category till date, despite the presence of a very small 


102 

Decision on MSEB’s Proposal


number of such consumers (563 Municipal Councils). This is even more surprising 

considering that, in this case, there should be no resistance to metering, and there is no need 

to incentivise metered consumption in this case. 

The Commission has hence considered this category as metered, for the purposes of 

estimating the revenue. The consumption norm for assessing the un-metered consumption has 

been assumed to be the same as last year, i.e., 9.13 hours/HP/day and 11.32 hours/HP/day for 

Grampanchayats and ‘C’ Class Municipal Councils, respectively. 

The projected consumption of the different sub-categories is as follows: 

Public Water Works Category: sub-category-wise consumption 

Sub-Category 

Actual 

Consumption - 

FY 2000-01 

(in MU) 

MERC 

Estimate – FY 

2001-02 

Urban PWW 21 23.5 

Rural PWW 

Gram Panchayat 511 447 

Metered Tariff (incl ‘C’ 

Class MC) 

39 107 

Total 571 577 

27.1.1.7 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 1250 hours/HP/year to assess the consumption from the un-metered category. It 

should be noted that the MSEB has submitted that as per the latest computerized billing 

records, the number of agricultural consumers and the connected load have reduced as 

compared to the submissions made in the previous Tariff Proposal. The Commission has, 

accordingly, assessed the un-metered sales based on the revised connected load numbers. 

The metered consumption has been estimated based on the ten-year CAGR, and the shift 

from un-metered to metered basis have also been added, based on the MSEB projections. The 

Commission has merged the LT Poultry category with the agricultural category, as it is 

principally an agricultural activity, and separate categorization does not serve any purpose, as 

the sales to this category are quite low. 



103


The agricultural consumers have also represented that there is no rationale in having a 

differential tariff based on the connected load rating of the pump. The Commission has 

accepted this representation and has done away with the slabs in this category. Henceforth, all 

un-metered consumers within this category will pay the same flat rate tariff per HP, 

irrespective of the connected load of the pump. 

LT Agriculture Category: sub-category-wise consumption 

(in MU) 

Sub-Category Actual Consumption - MERC Estimate – 

FY 2000-01 

FY 2001-02 

Flat Rate Tariff 7281 7221 

Metered Tariff* 260 332 

Total 7542 7553 

Note: * - includes LT Poultry 

27.1.1.8 Street Lighting Category 

The consumption in this category is metered. The Commission has merged the 

Grampanchayats and the ‘A’, ‘B’ and ‘C’ class Municipal Councils into one category. The 

projected sales have been apportioned to the sub-categories based on the actual average 

consumption in FY 1999-00 and FY 2000-01, as follows: 

Street lighting Category: sub-category-wise consumption 

(in MU) 

Sub Category Average Consumption - FY Share of MERC Estimate 

1999-00 and FY 2000-01 Consumption – FY 2001-02 

Grampanchayats and 

248.5 61.95% 279 

Municipal Councils 

Municipal 

147.94 38.05% 171 

Corporation Areas 

Total 396.46 100% 450 



104


27.1.2 HT Category 

Projected Sales to the HT Category (FY 2001-02) 

Category 

MSEB 

Projections 

– FY 2001- 

02 

Actual Sales – 

FY 2000-01 $ 10 year 

CAGR 

(in MU) 

MERC 

Estimate – FY 

2001-02 

HTP-I 6425 6556 2% 6425 

HTP-II 5736 5652 5736 

HTP-III (PWW) 599 557 5.98% 599 

HTP-IV (PWW) 330 324 330 

HTP-V 

Traction) 

(Railway 

841 817 10.3% 817 

HTP-VI 261 253 261 

HTP-VII (Agri.) * 717 683 717 

Mula Pravara 697 623 6.5% 697 

Total HT Category 15606 15465 15586 

Note: * - assuming 3600 hours of operation per HP per year 

The total sales to the HT consumers have been summarized in the above table. The sales 

projected by the Commission is marginally lower than that projected by the MSEB on 

account of the lower sales projected for Railway Traction; the MSEB’s projection of sales to 

the other categories have been accepted. The sales to the Railways have been 

stagnant/marginally reducing over the years, and, hence, the Commission has projected sales 

at the same level as in FY 2000-01. 

For the other categories, the MSEB’s projections have been accepted as they are in line with 

the CAGR and the Commission’s projections. In the case of HT industry, the MSEB has 

submitted that the sales to this category have been reducing over the years, and it has hence 

projected a 2% reduction in sales to this category. The trend of sales to this category supports 

the MSEB argument, and the Commission has hence accepted these projections. The 

consumption of seasonal consumers has been estimated at the same level as in FY 2000-01. 

The MSEB had proposed a reduction in the number of HT categories, by retaining only four 

categories, viz. 

♦ 

♦ 

♦ 

♦ 

HT I – comprising earlier HT-I, HT-II, HT-III, HT-IV and HT-VI 

Railway Traction 

HT Agriculture – comprising earlier HT-VII, HT VIII and SP I & II 

Mula Pravara 



105


The Commission is of the opinion that the rationalisation in the number of categories 

proposed by the MSEB is too drastic and has retained the earlier categories, except for the 

clubbing of HT-VII, HT VIII and SP-I and SP-II into HT agriculture category, 

The Commission has already presented the ToD consumption pattern in earlier sections, 

while detailing the philosophy on ToD tariffs. The consumption of HTP- I and HTP- II 

category in the ToD slabs has been reproduced below: 

ToD Slab-wise Consumption of HTP-I and HTP-II Categories 

Time Slab Description % Share of Consumption 

Consumption 

(MU) 

2200 – 0600 hours Night off-peak 33% 3953 

0600 – 0900 hours Morning off-peak 19% 2315 

0900 – 1200 hours Morning peak 13% 1604 

1200 – 1800 hours Day off-peak 19% 2315 

1800 – 2200 hours Evening peak 16% 1930 

Total 12117 

27.1.3 Total Sales 

The Commission has thus projected the total sales in FY 2001-02 as 37000 MU. 

27.2 Energy Audit Analysis and Transmission & Distribution Losses 

The MSEB has submitted data corresponding to the Energy Audit Studies undertaken by it 

over a period, across a 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 that it serves: 

‣ LT – Agriculture feeders 

‣ Division level feeders 

‣ MIDC feeders 

‣ Express feeders 

‣ EHV level feeders 



106


27.2.1 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 the case of some of the feeders, very few data readings (say two, corresponding 

to two months) were available. The Commission is of the opinion that, to be able to judge 

consistency or to draw any inference regarding trend, at least 10 to 12 months’ data should be 

available, as the consumption pattern varies with 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. 

27.2.2 Output Parameters For Analysis 

For LT – Agriculture feeders 

The estimate of the Energy Audit – data analysis for the LT-Agriculture feeders was: - 

1. To evaluate norm for operating hours per HP per annum in case of LT agricultural 

connected load. 

2. To observe variation, if any, in the operating norm across zones, circles and divisions. 

For all other feeders (Division level, MIDC level, Express feeders, EHV level) 

The objective of the Energy Audit – data analysis for all other feeders was: - 

1. To assess T&D loss level on aggregate basis as well as on zone/circle basis. 

2. To monitor trend in T&D loss level. 

3. To highlight zones/circles that report higher level of T&D losses consistently. 

27.2.2.1 LT – Agriculture Feeders 

Sample characteristics (sample size, sample coverage, sample limitation) 

The MSEB has submitted Energy Audit data corresponding to 1701 feeders covering six (6) 

zones and twenty-five (25) circles. The zones covered are Amravati, Aurangabad, Beed, 

Kolhapur, Nasik and Nagpur. The information provided corresponding to particular feeder 

includes zone name, circle name, village name, number of pump sets connected, connected 

load, and the consumption recorded over a period. The time period covered by the readings 

vary from two months to more than twelve months. Based on the above information, average 

consumption per month and average consumption per HP per month for the particular feeder 

is reported. The MSEB has confirmed that the feeders covered under the study expressly 



107


cater only to LT-agricultural load. The consumption in terms of energy units is measured on 

the LT side of the distribution transformer. 

Filtering criteria 

For the purpose of our analysis, the Commission has considered only those feeders for which 

the readings are 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 we are determining annual operating 

norm per HP. Accordingly, as presented in the following Table, only 755 out of 1701 LT – 

agriculture feeders covered under Energy Audit reported data readings for more than 300 

days. 

Summary Data Table 

Operating Hrs 

No. of data 

/HP/Annum Ameravati Aurangabad Beed Kolhapur Nagpur Nasik readings 

< 300 31 4 6 23 1 13 78 

301 < hrs < 700 51 7 6 52 14 12 142 

701 < hrs < 1100 32 8 13 49 11 31 144 

1101 < hrs < 1500 22 10 5 36 11 14 98 

1501 < hrs < 1900 14 6 9 33 2 14 78 

1901 < hrs < 2300 11 9 3 21 5 9 58 

2301 < hrs < 2500 3 2 2 7 2 6 22 

2501 < hrs < 3000 5 3 3 13 4 16 44 

> 3000 4 6 6 28 2 45 91 

Total data readings 173 55 53 262 52 160 755 

Further, if we ignore terminal data readings from the Table that correspond to < 300 

operating hours (i.e. < 1 operating hour per day) and > 3000 operating hours (i.e. > 8 

operating hours per day), we will have 586 feeder readings for the purpose of analysis. 

Observations 

The data corresponding to above 586 feeder readings has been considered for determining the 

norm for LT- agricultural consumption in terms of operating hours per HP per annum. The 

summary of findings is reported under Table (circle-wise summary) and Table (zone-wise 

summary). As evident from the circle-wise summary, the average operating hours per HP per 

annum varies from 719 (for Osmanabad circle) to 1781 (for Bhandara circle). 



108


Connected 

Load 

(HP) 

Avg. Consum./ 

month/HP 

(units) 

Avg. 

Operating 

Hours / HP / 

Annum 

Zone Circle No. of pumps 

AMARAVATI AKOLA CIRCLE 532 2419 63.49 1021 

AMARAVATI CI 404 1952 67.43 1085 

BULDHANA CIR 362 1934 54.39 875 

YAVATMAL CIR 102 486 67.45 1085 

AURANGABAD AURANGABAD C 105 571 79.30 1276 

JALNA CIRCLE 100 482 52.63 847 

PARBHANI CIR 296 1493 90.50 1456 

BEED ZONE, BEED CIRCLE 21 120 46.42 747 

LATUR CIRCLE 168 765 82.32 1324 

NANDED CIRCL 192 1015 90.86 1462 

OSMANABAD CI 59 273 44.73 719 

KOLHAPUR KOLHAPUR CIR 674 3224 81.61 1313 

SANGLI CIRCL 762 3265 84.41 1358 

SATARA CIRCL 891 4609 73.05 1175 

SOLAPUR CIRC 482 2247 74.93 1205 

NAGPUR ZON BHANDARA CIR 142 658 110.71 1781 

CHANDRAPUR C 129 643 58.60 943 

GADCHIROLI C 39 189 92.22 1483 

NAGPUR (R) C 66 273 65.31 1051 

WARDHA CIRCL 160 765 51.52 829 

NASIK ZONE AHMEDNAGAR C 247 1173 102.64 1651 

DHULE CIRCLE 335 1527 88.94 1431 

JALGAON CIRC 455 1965 82.38 1325 

NASIK CIRCLE 217 1018 105.62 1699 

Table (Zonewise Summary) 

Zonewise 

Summary 

No. of 

pumps 

Connected 

Load (HP) 

Avg. 

consum./ 

month/HP 

(units) 

Avg. 

Operating 

Hours / HP / 

annum 

AMARAVATI 1400 6791 62.32 1002 

AURANGABAD 501 2546 80.82 1300 

BEED 440 2173 79.61 1281 

KOLHAPUR 2809 13345 78.21 1258 

NAGPUR 536 2528 73.26 1178 

NASIK 1254 5683 92.49 1488 

TOTAL 6940 33066 77.31 1244 



109


Inference 

1. Based on the analysis of the data furnished, it can be deduced that the average operating 

hours per HP per annum for LT- agricultural consumption on aggregate basis works out 

to 1244 hours per HP per annum. 

2. However, there are variations across zones and circles. The sample size available for 

analysis covers only 33066 HP of connected load which corresponds to only 0.4% of 

total connected load of 7808704 HP reported under LT- agriculture category for 2000-01. 

3. In this context, it is interesting to note the following observations made through the 

objections filed – 

o The MSEB has neither consulted nor involved farmers at any time. Before 

determining any such norm, the MSEB should discuss with farmers’ 

representative bodies. 

o Average operating hours is dependent on a 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. 

4. As per actual sales (2000-01) reported by the MSEB for LT-agriculture metered 

category, number of consumers (2.54 Lakh), connected load (933665 HP) and sales (230 

MU), the derived operating hours is 331 Hours per annum. This is logical, as only those 

consumers whose consumption is substantially lower would opt for metering under the 

Optional Regime. 

In the previous tariff process for FY 2000-01, the MSEB had submitted energy audit data of 

192 feeders, and the estimated consumption norm for LT agricultural category was 1600 

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 1701 feeders, which is a larger 

and more representative sample, and the Commission is of the opinion that the estimate based 

on the larger sample is more realistic. The MSEB has submitted that the consumption norm 

based on the 1701 feeders is 1530 hours per HP per year. The MSEB has deducted 

distribution loss of 15% from the norm to arrive at the estimated norm of 1300 hours per HP 

per annum. The earlier norm of 1600 hours was inclusive of the distribution losses. 

Moreover, there is no basis for the assumption of 15% distribution losses. The Commission 

has applied the filtering criteria and considered only the apparently more reliable data. Based 

on the above analysis, the Commission has applied the norm of 1250 hours per HP per 

annum, to estimate the consumption of un-metered LT agricultural consumers. 



110


Division Level Feeders 


The MSEB has submitted Energy Audit data corresponding to 120 divisions covering eleven 

(11) zones and thirty-three (33) circles. The zones covered are Nagpur, Kalyan, Nagpur- 

Urban, Aurangabad, Amravati, Kolhapur, Bhandup, Konkan, Beed, Pune-Urban and Nasik. 

The information provided corresponding to particular feeder includes zone name, circle 

name, division name, input energy, billed energy (HT and LT) and the un-metered or 

assessed energy (connected load, consumption norm) for each month. The readings have been 

typically provided for a period of eight months from November 2000 to June 2001. Based on 

the above information, T&D loss for the particular feeder for each month has been reported. 

The feeders covered under the study cater to LT as well as HT load. The energy units are 

measured on the LT side of the distribution transformer. 


For the purpose of analysis, only those feeders for which the readings are reported for a 

period of eight months were considered. The rationale for setting eight months data readings 

as filtering criteria was to cover as wide a period as available so as to monitor the trend in the 

percentage metering and T&D loss. Accordingly, as presented in the following Table, 105 

divisional feeders out of 120 divisional feeders covered under Energy Audit reported data 

readings for eight months. 

For the purpose of analysis and in order to gain some insight into percentage metering and 

T&D loss performance, the feeders under Rural and Urban zones were clubbed separately. 

The zones clubbed under each category are – 

Rural Zones 

- Nagpur, Aurangabad, Amravati, Kolhapur, Beed, and Nasik 

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. 

Accordingly, out of 105 divisions considered for analysis, 81 divisions fall under Rural zone 

whereas 24 divisions fall under Urban zone. 



111


Rural Zones 

List of Zones and Circles 

Urban Zones 

Zones Circle 

No of 

No of 

Zones Circle 

divisions 

division 

Wardha Circle 3 Pen Circle 2 

Nagpur 

Bhandara Circle 3 Kalyan Kalyan Circle 5 

Chandrapur Circle 3 Vasai Circle 2 

Gadchiroli Circle 3 Nagpur-Urban Nagpur-Urban 1 

Aurangabad 

Parbhani Circle 2 Vashi Circle 2 

Bhandup 

Aurangabad Circle 2 Bhiwandi Circle 2 

Jalna Circle 2 Ratnagiri Circle 2 

Konkan 

Aurangabad-U circle 1 Sindhudurg Circle 1 

Buldhana Circle 3 Pune-Urban Pune Urban Circle 7 

Amaravati 

Akola Circle 3 Urban Zones Summary 24 

Amravati Circle 4 

Yawatmal Circle 3 

Solapur Circle 4 

Kolhapur Circle 6 

Kolhapur Sangali Circle 4 

Pune Rural Circle 3 

Satara Circle 4 

Latur O&M Circle 3 

BEED 

Osmanabad Circle 2 

Nanded 3 

Beed Circle 2 

Ahmad Nagar Circle 3 

NASHIK 

Nasik Circle 5 

Dhule Circle 4 

Jalgoan Circle 6 

Rural Zones Summary 81 

Observations 

The summary of findings over the period of November 2000 to June 2001 is reported under 

Table (Rural zone summary) and Table (Urban zone summary). 

Table (Rural Zone Summary) 

Zones 

% 

M (c) 

% 

Losses 

% 

UM (c) 

Nagpur 71% 21% 8% 

Aurangabad 33% 40% 28% 

Amaravati 37% 39% 24% 

Kolhapur 36% 29% 35% 

Beed 16% 45% 39% 

Nashik 30% 28% 42% 

M(c) means Metered consumption and 

UM (c) means Um-metered consumption. 



112


% M(c) and % UM (c) are reported as percentage of Energy Input (EI) measured at the 

feeder. 

Table (Urban Zone Summary) 

Zones 

% 

M (c) 

% 

Losses 

% 

UM (c) 

Kalyan 73% 26% 1% 

Nagpur-U 66% 34% 0% 

Bhandup 54% 29% 17% 

Konkan 74% 23% 3% 

Pune-Urban 71% 29% 0% 

• Summary of all zones (Rural and Urban) indicates % Metered energy as 44%, % losses as 

31% and % Un-metered energy as 25% over the period November 2000 to June 2001. 

• 32 out of 105 divisions reported losses in excess of 39%, which is the loss level submitted 

by the MSEB. 

• There is a clear distinction in terms of % Metered energy between Urban (~ 70% range 

except Bhandup, as Bhandup zone includes Bhiwandi circle with substantial un-metered 

power loom consumption) and Rural (~ 35% range except Nagpur). 

• Further, as is evident from the Table, urban zones where Un-metered energy is negligible 

(0 – 3%), the reported losses are still as high as 23% - 34%. 

Rural Zones - % Metered Energy Trend 

Division Level :(% Metered Energy) 

90% 

80% 

70% 

60% 

50% 

40% 

30% 

20% 

Nagpur 

Aur'bad 

Am'vati 

Kolhapur 

Beed 

Nasik 

10% 

0% 

Nov-00 Dec-00 Jan-01 Feb-01 Mar-01 Apr-01 May-01 Jun-01 



113


• Nagpur reported the highest level of % Metered energy at 71% (avg), Beed reported 

lowest level of % Metered energy at 16% (avg). 

• However, trend line for Nagpur indicates that the % metered energy has declined over the 

period which is an area of concern. 

• If % Metered energy and % Un-metered energy are considered together and various zones 

are ranked in terms of assessed (billable) energy, the ranking is as follows. 

Table (Rural Zone) 

% Assessed (M + UM) Energy 

Rank Zones 

Assessed 

% (M+UM) 

1 Nagpur 79% 

2 Nashik 72% 

3 Kolhapur 72% 

4 Amaravati 61% 

5 Aurangabad 60% 

6 Beed 55% 

Division Level :(% Loss) 

60% 

50% 

40% 

30% 

20% 

10% 

Nagpur 

Aur'bad 

Am'vati 

Kolhapur 

Beed 

Nasik 

0% 


• There is a wide variation in the % losses reported across zones. While Nagpur reported 

lowest level of % losses at 21% (avg), Beed reported the highest level of % losses at 45% 

(avg). 

• Beed, Aurangabad and Amravati reported losses in the range of 40%, while Kolhapur, 

Nashik and Nagpur reported losses in the range of 21% - 28%. 



114


• The losses have declined over the period across zones. However, trend line for Nagpur 

indicates that the % losses have increased over the period, which is an area of concern. 

• If the various zones are ranked in terms of losses, the ranking is as follows 

Table (Rural Zone) 

(% Losses) 

Rank Zones % Loss 

1 Beed 45% 

2 Aurangabad 40% 

3 Amaravati 39% 

4 Kolhapur 29% 

5 NASHIK 28% 

6 Nagpur 21% 

Urban Zones - % Metered Energy Trend 

Division Level :(% Metered Energy) 

90% 

80% 

70% 

60% 

50% 

40% 

30% 

20% 

Kalyan 

Nagpur-U 

Bhandup 

Konkan 

Pune-U 

10% 

0% 


• There is no substantial variation in the % Metered energy reported for Urban zones except 

for Bhandup, which includes Bhiwandi circle comprising substantial un-metered power 

loom consumption. 

• Trend lines for various zones do not indicate any substantial improvement in the % 

metered energy over the period. 

• If % Metered energy and % Un-metered energy are considered together and various zones 

are ranked in terms of assessed (billable) energy, the ranking is as follows . 



115


Table (Urban Zone) 

% Assessed (M + UM) Energy 

Rank Zones 

Assessed 

% (M+UM) 

1 Konkan 77% 

2 Kalyan 74% 

3 Pune-Urban 71% 

4 Bhandup 70% 

5 Nagpur-U 66% 

Urban Zones - % Losses Trend 

Division Level :(% Loss) 

50% 

45% 

40% 

35% 

30% 

25% 

20% 

15% 

10% 

5% 

0% 


Kalyan 

Nagpur-U 

Bhandup 

Konkan 

Pune-U 

• As is evident from the trend lines, there is wide variation in the % losses reported over the 

period across the zones. 

• Overall, the losses indicate a declining trend. However, there is no corresponding increase 

in % metered energy. It is difficult to draw any inference from the data and the same 

needs to be further scrutinized. 

• Urban zones where Un-metered energy is negligible (0 – 3%), are reporting losses as high 

as 23% - 34%, which is a cause of extreme concern. 

• If we rank various zones in terms of losses, the ranking is reported in the following Table 



116


Table (Urban Zone) 

(% Losses) 

Rank Zones % Loss 

1 Konkan 23% 

2 Kalyan 26% 

3 Pune-Urban 29% 

4 Bhandup 29% 

5 Nagpur-U 34% 

27.2.2.2 Comparison of losses for rural zones – Derived v/s Reported 

Based on the findings of the Energy Audit for LT-agriculture, the norm for operating hours 

per HP per annum has already been derived to estimate consumption in terms of energy units 

for Un-metered energy consumption of LT-agriculture load. The same norm has been 

applied for each rural zone to derive the estimate of Un-metered energy consumption and 

comparison has been made against the reported Un-metered consumption. This exercise 

enables validation of the norm for operating hours as well as identifies zones that indicate 

substantial difference between reported losses and derived losses. 

Zones 

Avg. 

Connected 

load (HP) 

Norm for 

Op. Hrs/HP 

/annum 

Derived 

% Unmetered 

energy 

Avg. 

% unmetered 

Avg. 

% 

Metered 

Avg. 

% 

Losses 

Derived 

losses 

Nagpur 287783 1178 9% 8% 71% 21% 20% 

Aurangabad 1181770 1300 28% 28% 33% 40% 40% 

Amaravati 953928 1002 20% 24% 37% 39% 43% 

Kolhapur 2759788 1258 24% 35% 36% 29% 40% 

Beed 1229150 1281 25% 39% 16% 45% 59% 

Nashik 2405900 1488 24% 42% 30% 28% 46% 

All zones 1244 16% 25% 44% 31% 40% 

1. As is evident from the above Table, derived losses at 40% are higher than the reported 

losses at 31%. This indicates that either the losses have been reported low or the norm for 

operating hours should be higher. 

2. Kolhapur, Beed and Nashik zones contribute to this large difference between reported 

losses and derived losses. 



117


Inference 

1. Summary of all zones (Rural and Urban) indicates % Metered energy as 44%(avg), % 

losses as 31% (avg) and % Un-metered energy as 25%(avg) over the period November 

2000 to June 2001. 

2. There is a clear distinction in terms of % Metered energy between Urban (~ 70% range 

except Bhandup) and Rural (~ 35% range except Nagpur). 

3. Urban zones such as Pune-Urban, Kalyan, Nagpur-Urban where Un-metered energy is 

negligible (0 – 3%), are reporting losses as high as 23% - 34%. This disproves the 

MSEB’s theory that un-metered consumption is the cause of the high losses. 

4. Even under rural zones Beed, Aurangabd and Amravati reported losses in the range of 

40% whereas Kolhapur, Nashik and Nagpur reported losses in the range of 23%-29%. 

However, derived losses for Kolhapur and Nashik are also in excess of the range of 40%. 

27.2.2.3 MIDC LEVEL FEEDERS 


The MSEB has submitted Energy Audit data corresponding to 42 MIDC circles spread over 

eleven (11) zones covering eighty- seven (87) sub-stations. The zones covered are Amravati, 

Aurangabad, Beed, Bhandup, Kalyan, Kolhapur, Konkan, Nagpur, Nagpur-Urban, Nashik 

and Pune-Urban. The information provided corresponding to particular feeder substation 

includes zone name, circle name, MIDC area, energy sent out and billed energy (HT and LT) 

for each month. The readings have been typically provided for a period of six months from 

February 2001 to July 2001. Based on above information, the T&D loss for the particular 

feeder for each month have been reported. The feeders covered under the study cater to LT as 

well as HT industrial load. The energy units are measured on the LT side of the distribution 

transformer. 


Although most of the circles have reported data readings for six months, there are instances 

where no report has been submitted for one or two months. For the purpose of analysis, the 

Commission has considered only those feeders for which the readings are reported for at least 

four months. The rationale for setting four months’ data readings as filtering criteria was to 

cover as many MIDC circles as possible across all zones so as to monitor level of percentage 

metering and T&D loss within a notified area. Accordingly, as presented in the following 

Table, 39 MIDC circles out of 42 MIDC circles covered under Energy Audit reported data 

readings for at least four months. 



118


Table (List of Zones and MIDC Circles) 

Zone MIDC Circle Zone MIDC Circle 

Akola 

Kolhapur 

Amaravati 

Amaravati 

Pune 

Buldhana 

Kolhapur Sangli 

Yeotmal 

Satara 

A'bad-U1, MIDC-1 

Solapur 

A'bad-U2, MIDC-1 

Ratnagiri 

Konkan 

Aurangabad A'bad-Rural 

Sindhudurg 

Jalna 

Bhandara 

Parbhani 

Chandrapur 

Beed 

Nagpur Nagpur 

Beed 

Latur 

Wardha 

Nanded 

Gadchiroli 

Osmanabad 

Hingana-II 

Nagpur-Urban 

Bhandup-U 

Hingana-I 

Bhandup Vashi 

Dhule 

Bhiwandi 

Jalgoan 

Nashik 

Kalyan 

Ahmednagar 

Kalyan 

Vasai 

Nashik 

Pen-Mahad Pune- Urban Pune-Urban 

Pen-Khop/Roha 

Observations 

The summary of findings for the above indicated MIDC circles across zones over the period 

from February 2001 to July 2001 is reported under the following Table. 

Zone Feb-01 Mar-01 Apr-01 May-01 Jun-01 Jul-01 

Amaravati 4.0% 4.8% 2.6% 3.0% 3.9% 4.5% 

Aurangabad 1.9% 0.3% 1.5% 2.2% 1.3% 2.7% 

Beed 1.7% 7.1% 5.1% 7.4% 9.5% 12.7% 

Bhandup 4.1% 2.3% 3.4% 3.1% 3.9% 3.4% 

Kalyan 8.0% 3.6% 5.3% 1.5% 3.6% 2.9% 

Kolhapur 2.4% 6.1% 4.5% 3.2% 5.9% 4.1% 

Konkan -6.8% -0.7% -1.0% 1.8% 3.4% 4.4% 

Nagpur 28.9% -0.8% -1.3% -0.1% -0.3% -2.6% 

Nagpur-Urban 15.5% 9.4% 3.4% 0.2% 5.1% 7.1% 

Nashik 2.3% 1.6% 2.3% 3.5% 3.9% 3.7% 

Pune- Urban 7.7% 18.0% 18.0% 17.6% NA 0.8% 

All Zones 5.7% 5.3% 4.9% 4.5% 3.3% 3.2% 

• The level of losses reported in the MIDC circles on aggregate basis show a continuous 

declining trend from 5.7% to 3.2%. 



119


• However, the level of losses reported at a few zones such as Beed, Kalyan, Pune-Urban, 

Nagpur-Urban are substantially high. There is no reason for these losses to occur other 

than acceptable level of technical losses, as these areas are concentrated regions with 

primarily HT load with 100% metering. 

• Further, a lot of diversity is observed in the reported losses in the case of a few circles 

over the period. In some cases, such as Osmanabad (Beed zone) and Ratnagiri (Konkan 

zone), there is an increase in reported losses, while, in some case, such as Pune-Urban 

zone and Bhandara (Nagpur zone), there is a drastic reduction in losses reported, and even 

this reduction is not linear. 

• MIDC circles that report drastic variation in the losses have been plotted in the following 

Chart. 

MIDC - T&D loss 

20.0% 

15.0% 

% T&D loss 

10.0% 

5.0% 

Am'vati 

Parbhani 

Beed 

Latur 

Nanded 

Osmanabad 

Kalyan 

Bhandara 

Hingana-II 

Jalgoan 

Pune-U 

0.0% 

Feb-01 Mar-01 Apr-01 May-01 Jun-01 Jul-01 

-5.0% 

Inference 

1. Although the level of losses for all MIDC circles on aggregate basis show a declining 

trend, its is important to identify circles that report high level of losses consistently and 

also to identify MIDC circles that report drastic variations in the losses. 

2. For the purpose of analysis, it is important to monitor the performance over a longer 

tenure. Four months’ data is not adequate to provide any conclusive evidence. 

3. The amount of variation in the reported losses is quite substantial and the Commission 

has hence rejected this sample as inconclusive. 

The Commission directs the MSEB to conduct the energy audits for the MIDC zones and 

ensure that the data is consistent, as the data submitted by the MSEB indicates gross 



120


negligence in metering. If the MSEB is unable to accurately report the consumption of such a 

concentrated load center with 100% metering, then it indicates that the MSEB has to put its 

house in order immediately, to prevent loss of revenue due to inefficiency in metering and 

billing. The MSEB should analyze 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. 

27.2.2.4 Express Feeders 


The MSEB has submitted Energy Audit data corresponding to 187 to 237 express feeders 

(total of 1334 sample readings) spread over eleven (11) zones covering twenty nine (29) 

circles. The zones covered are Amravati, Aurangabad, Beed, Bhandup, Kalyan, Kolhapur, 

Konkan, Nagpur-Rural, Nagpur-Urban, Nashik and Pune-Urban. The information provided 

corresponding to particular feeder includes zone name, circle name, HT industrial consumer 

substation, energy sent out and billed energy (HT) for each month. The readings have been 

generally provided for a period of six months from February 2001 to July 2001. Only 187 

feeders were reported in February 2001, which increased to 237 in July 2001. Based on the 

above information, the T&D loss for the particular feeder for each month has been reported. 

The feeders covered under the study cater only to HT industrial load. 


The list of zones and circles covered for the purpose of Energy Audit of Express Feeders is 

presented under Table, below. The number of express feeders for which the MSEB has 

provided data is limited (approximately 230 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 considered 

a range of – 0.5% to + 2% as the acceptable range for the losses. Any data readings falling 

beyond this range have been rejected. 



121


Table (List of Zones and Circles) 

Zone Circle Zone Circle 

Ratnagiri 

Chandrapur 

Konkan 

Sindhudurg 

Wardha 

Nagpur-R 

Vashi 

Nagpur-R 

Bhandup 

Bhivandi 

Bhandara 

Kalyan 

Latur 

Beed 

Kalyan 

Pen 

Nanded 

Vasai Nagpur-U Nagpur-U 

Nashik 

Yawatmal 

Nashik 

Ahemadnagar 

Amaravati 

Amarawati 

Jalgoan 

Akola 

Dhule 

Buldhana 

Aurangabad Aurangabad Kolhapur 

Sangali 

Kolhapur Pune-R 

Solapur 

Satara 

Pune-U Pune-U 

The number of data readings falling within acceptable range is tabulated in Table below. 

-0.5% < 

loss 

< 2% 

% 

within 

range 

Zones 

loss 

< -0.5% 

loss > 

+2% 

Not 

Reported Sum 

Konkan 9 3 12 2 26 12% 

Bhandup 34 46 9 9 98 47% 

Kalyan 61 50 35 34 180 28% 

Nashik 35 131 62 36 264 50% 

Aurangabad 13 34 4 2 53 64% 

Nagpur-R 58 104 71 40 273 38% 

Beed 14 6 11 12 43 14% 

Nagpur-U 1 11 0 4 16 69% 

Amarawati 15 45 17 36 113 40% 

Kolhapur 24 60 28 29 141 43% 

Pune-U 64 37 14 12 127 29% 

All Zones 328 527 263 216 1334 40% 

25% 40% 20% 16% 100% 



122


Observations 

• As is evident from the above table, almost 60% of the data readings appear to be 

erroneous or outside acceptable range. 

• Considering approximately 230 express feeders (i.e. 460 readings each month) of which 

50% of the readings (units sent) are to be taken at MSEB’s end, the data within 

acceptable range is very low. 

• Further, express feeder readings for Kalyan, Pune- Urban, Beed and Konkan reported to 

be within acceptable range is very low. This requires further review and investigation. 

• The trend line of the readings within acceptable range have been plotted below: 

Express Feeder Data 

60% 

50% 

% readings 

40% 

30% 

20% 

loss < -0.5% 

-0.5% < loss < 2% 

losses > +2% 

Not reported 

10% 

0% 

Feb-01 Mar-01 Apr-01 May-01 Jun-01 Jul-01 

While the losses reported under the acceptable range are on the rise over the period February 

2001 to July 2001, the losses under “Not reported” category are also on the rise. 

Inference 

1. Although the MSEB has conducted Energy audit of express feeder data for over six 

months, the quality of data and findings leaves much to be desired. 

2. The MSEB must focus on these express feeders and identify reasons for such low 

reporting of readings falling within the acceptable range. 



123


27.2.2.5 EHV Level Feeders 


The MSEB has submitted Energy Audit data corresponding to EHV level feeders. The 

information provided includes energy import, energy export and T&D loss for each month 

from Jauary 2001 to June 2001. 

Observations 

Jan-01 Feb-01 Mar-01 Apr-01 May-01 Jun-01 

Energy Import, MU 5925 5512 5983 5876 5878 5089 

Energy Export, MU 5428 5053 5568 5557 5494 4846 

loss 8.40% 8.30% 6.90% 5.40% 6.50% 4.80% 

EHV level data analysis 

Energy MU 

7000 

6000 

5000 

4000 

3000 

2000 

1000 

9.00% 

8.00% 

7.00% 

6.00% 

5.00% 

4.00% 

3.00% 

2.00% 

1.00% 

% T&D loss 

Import 

Export 

% loss 

0 

Jan-01 Feb-01 Mar-01 Apr-01 May-01 Jun-01 

0.00% 

Inference 

1. The Energy Audit at EHV level feeders indicates a declining trend in reported losses from 

8.4% in January 2001 to 4.8% in June 2001. 

2. It is important to identify the reasons or specific efforts undertaken by MSEB in this 

regard to achieve the above reduction. 

27.2.3 Conclusion 

The above analysis of the Energy Audit data submitted by the MSEB shows that the MSEB 

has not made any effort to reduce the loss levels, apart from conducting energy audits at 

various voltage levels as directed by the Commission in the previous Tariff Order. The 

MSEB has repeatedly argued before the Commission during the tariff process that unless 



124


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 areas (Urban, MIDC, Express Feeders) range between 25 and 35 percent. The 

Commission takes serious note of the fact that the T & D losses in a city like Pune are thrice 

that of Mumbai. 

The MSEB also has not submitted any data to indicate that any concrete action has been 

initiated by the MSEB to address the high level of losses in these areas. The Commission 

would like the MSEB to realize that mere compilation of data is not sufficient, and the 

MSEB should take immediate steps to reduce the high level of losses in such areas. 

The loss levels indicated by the energy audits in urban zones and MIDC areas also cause a lot 

of concern, as does the inconsistency of data from these areas. The MSEB is hereby 

directed to conduct energy audits for all circles/zones (urban and rural) as well as all 

MIDC areas and to submit the energy audit reports to the Commission on a monthly 

basis along with the ‘Action Taken Report’ after fixing accountability. 

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. 

The MSEB has submitted that it intends to undertake energy audits for over 5500 LT 

agriculture feeders during the next year, as compared to the 1701 feeders covered this year. 

However, the data submitted by the MSEB for the 1701feeders indicates several lacunae with 

several feeders indicating ‘zero meter reading’ continuously as well as several meters not 

being read on a regular (monthly) basis. During the previous tariff exercise, the MSEB had 

submitted that the meters were not read regularly, as the billing was not being done on the 

basis of the metered consumption. However, despite the repeated urgings of the Commission 

and the consumers, the improvement shown by the MSEB in this regard is not sufficient. 

The Commission appreciates that the process of change takes time and the MSEB has had to 

cope with the changes brought about due to the regulatory process introduced only recently. 

However, it is now over two years under the Regulatory regime, and the MSEB has to 

improve its performance especially in the area of T & D loss as improvement in metering and 



125


billing and check on collusion will result in substantial improvement of revenues to the 

MSEB. 

27.3 Energy Input Requirement 

The MSEB has projected a system loss of 39.49% for FY 2001-02. 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 39.49%. 

With the sales during FY 2001-02 projected by the Commission at 37000 MU, the total 

energy requirement to be met through generation and power purchase is expected to be about 

61145 MU. 

The total energy input requirement as proposed by MSEB and as approved by the 

Commission for FY 2001-02 is as follows: 

Energy Input Requirement (MU) 

As projected by MSEB Commission’s Approval 

Sales 

Metered 26880 27894 

Unmetered 9104 $ 9106 $ 

Total Sales 35984 37000 

T&D Losses 23481 24144 

Energy Input Requirement 59465 61145 

T&D loss as a % of energy 39.49% 39.49% 

requirement 

Note: $ - After adjusting for revision in the LT agricultural consumption norm to 1250 hours/HP/year 

28 EXPENDITURE PROJECTIONS 

The major head of expenditure is generation and power purchase expenses, which account for 

over 50% of the total revenue requirement of the MSEB in FY 2001-02. 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. 



126


28.1 Generation and Power Purchase Costs 

The generation and power purchase cost comprises around 52% 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. 

28.1.1 Sources of Power 

The MSEB has three sources of firm power namely 

‣ MSEB’s own generating stations 

‣ Purchase from Central Generating Stations 

‣ Purchase from IPP, i.e., Dabhol Power Company (DPC) 

In addition to the above sources, the MSEB can buy some infirm power form Tata Electric 

Company (TEC) and other sources such as co-generation, wind power, etc. 

MSEB’s Own Generating Stations 

The total capacity of the MSEB’s own 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 2403 

Total MSEB 9711 

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: 



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MSEB’s Share of Central Generating Stations Capacity 

Station Total Capacity (MW) MSEB’s share (MW) 

NTPC 

Korba S.T.P.S 2100 682.62 

Vindhyachal S.T.P.S 2260 818.21 

Kawas S.T.P.S 656 235.15 

Gandhar S.T.P.S 657 214.35 

NPC 

Kakrapar A.P.S 440 160 

Tarapur A.P.S 320 246.35 

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 29 th May onwards, since the MSEB 

has rescinded the PPA with the DPC. The actual energy purchased by the MSEB from DPC 

till 29 th May 2001 is 303 MU. The MSEB has not included any cost for this purchase of 

power, as the matter is sub-judice. As the PPA has been rescinded by MSEB, the 

Commission has not projected any further purchase of power for FY 2001-02. 

Generation and Purchase of Power 

The MSEB has estimated the total generation and power purchase costs for FY 2001-02 

considering the actual generation and power purchase cost for the period of April 2001 to 

May 2001 and estimating the generation and power purchase cost from July 2001 to March 

2002 based on a simulation of merit order dispatch. 

The Commission has approved the total generation and power purchase costs for FY 2001-02 

considering actual generation and power purchase cost for the period of April to September 

2001 and estimating the generation and power purchase cost from October 2001 to March 

2002 based on a simulation of merit order dispatch and actual average generation and power 

purchase costs for the period of April to September 2001, subject to heat rate norms and 

removal of transit loss component. 

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 



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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. 

28.1.2 Actual Generation and Power Purchase from April 2001 – September 2001 

Quantum of Power from the MSEB’s owned plants 

MSEB has generated 23107 MU from its own plants during April 2001-September 2001. The 

table below summarises the generation from each thermal station and hydel source during the 

period, the PLF approved by Commission for FY 2000-01 and the actual PLF achieved in FY 

2000-01. 

PLF of Own Generating Stations 

Station 

Generation during 

2000-01 

April-Sept 2001 

Gross 

Generation (MU) 

PLF (%) Commission 

Approved PLF 

Actual 

PLF 

Khaparkheda 2600 70.7% 78.7% 78.3% 

Paras 191 75.2% 70.9% 75.4% 

Bhusawal 1658 79.2% 73.4% 70.0% 

Nasik 2903 72.8% 75.3% 73.3% 

Parli 1994 66.0% 73.8% 75.2% 

Koradi 2895 61.2% 67.5% 63.0% 

Chandrapur 7282 71.0% 76.3% 75.9% 

Total Thermal 19523 69.7% 74.2% 72.8% 

Gas Thermal 1841 46.1% 46.3% 43.5% 

Hydel Stations 1743 16.6% 19.6% 17.8% 

Total MSEB 23107 54.3% 57.3% 55.7% 

As observed from the above table, the actual generation for the period of April 2001 to 

September 2001 has reduced substantially (in terms of PLF) as compared to the generation 

levels approved by MERC for FY 2000-01 and the actual generation levels achieved during 

FY 2000-01. The Commission has analyzed this aspect in detail and it has been observed that 

the main reasons for reduction in generation during this period is planned outages and lower 

loads during the monsoon period. Typically thermal outages are planned during monsoon, as 

demand is low during this period due to less agricultural consumption. In FY 2000-01 also 

the PLF of thermal stations for the same period was 68.1% as against the annual average PLF 

of 72.8%. Further, the Commission has projected the availability of the thermal stations for 



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the remaining period of October 2001 to March 2002 considering the factor that the annual 

availability excluding planned outages for FY 2001-02 is similar to annual average 

availability for the last three years. 

Quantum of Power Purchase 

During the period of April-September 2001, MSEB has purchased power from the four 

NTPC stations, atomic power stations of Tarapur and Kakrapar, Tata Power Company, 

Dabhol Power Corporation and from other sources such as wind, co-generation, etc. The total 

quantum of power purchased during the period is 8076 MU and the power purchased from 

each source is summarised below: 

Actual Power Purchases 

Actual Net Drawal from April-Sept 

2001 (MU) 

NTPC 

Korba S.T.P.S. 2592 

Vindhyachal S.T.P.S 2303 

Gandhar G.P.S 503 

Kawas G.P.S. 586 

sub-total (NTPC) 5984 

NPC 

Tarapur A.P.S. 529 

Kakrapar A.P.S. 938 

Sub-total (NPC) 1467 

NR Import 106 

Tata Electric Co. 137 

Dabhol Power Co. 303 

Ad-hoc Purchase 79 

Total 8076 

28.1.3 Generation and Power Purchase Estimation from October 2001 to March 2002 

The generation and power purchase from October 2001 to March 2002 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: 



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i) Derivation of Month-wise hourly Load Curves by applying a growth rate of 3% over 

load curves during FY 2000-01 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 are 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 

allowed 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 growth in sales, energy input 

and considering actual power generated and purchased from April 2001 to September 

2001. 

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 are 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 



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hourly generation and power purchase schedule. However, the Commission has considered 

allowed T&D losses to determine the total energy input requirement and estimated load 

shedding based on hourly generation and power purchase schedule. 

28.1.4 Merit Order Dispatch Simulation 

The Commission has carried out the merit order dispatch simulation out 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 is as 

follows: 

28.1.4.1 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 3% over 

load curves during the previous year 2000-2001 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. 

28.1.4.2 Module 2: Availability Schedule 

In this module the maximum possible generation from each station during every month has 

been projected considering various factors. 

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. 



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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 planned outages and other factors have been considered based 

on the details provided by MSEB. 

The Stationwise ‘ability to generate’ factor as considered by MSEB and as approved by 

MERC is summarised in the following table: 

Ability to Generate of Own Generating Stations 

Ability to Generate Factor 

Station MSEB Projection Commission’s Approval 

Koradi 0.7482 0.7577 

Nasik 0.8157 0.8490 

Bhusawal 0.8435 0.8752 

Parli 0.8057 0.8712 

Chandrapur 0.8193 0.8686 

Paras 0.7982 0.7982 

Kaparkheda 0.8111 0.8500 

Uran 0.4819 0.4819 

MSEB’s Hydro Stations 

MSEB has assumed the hour-wise possible generation from all hydro stations similar to that 

in the corresponding month in 2000-01. With this assumption the total annual generation 

from hydro stations works out to 3371 MU. However, the MSEB in the proposal has 

mentioned that the total gross generation from hydro stations in year 2000-2001 was 3738 

MU. The MSEB further clarified that the actual total generation from all hydel stations in 

year 2001 was 3738 MU, however, the generation from some of the small hydel stations is 

not included in hour-wise generation recorded at the load despatch centre. The Commission 

has observed that the average generation from hydro stations during the last 5 years is in the 

range of 3740 MU. The Commission has approved the net generation target of 3720 MU 

from hydro stations for 2001-02. 

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 



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and NPC Stations to be the same as that considered by MSEB except for NTPC Kawas 

Station. The MSEB has considered 50% availability for NTPC Kawas, while the Commission 

has considered the availability of 80% for NTPC Kawas Station based on past trends. 

The Station-wise Availability for Central Generating Stations is summarized in the following 

table. 

Projected Availability of Central Generating Stations 

Station 

Availability 

NTPC Stations 

Vindhyachal 85% 

Korba 88% 

Kawas 80% 

Gandhar 50% 

NPC Stations 

Tarapur 90% 

Kakrapar 90% 

28.1.4.3 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. 

Variable cost of MSEB’s Stations 

The MSEB has projected the variable costs of its own stations based on the variable costs 

incurred in March 2001. These variable costs projected by MSEB are inclusive of transit loss 

component in cost of coal and based on the heat rate achieved during March 2001. The 

average heat rate of thermal stations as achieved by MSEB during March 2001 was 2784 

Kcal/kwh. 



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The Commission has projected the variable cost of MSEB stations based on the average of 

actual fuel costs from April-September 2001, as made available by the MSEB. The 

Commission has not approved the transit loss component in cost of coal in line with the 

Commission’s ruling in this regard in the previous Tariff Order. Moreover, the Commission 

also directs the MSEB to make efforts to improve the heat rate of its generating stations. 

Accordingly, the Commission has considered a reduction of about 1% in the stationwise heat 

rate from the heat rate figures approved by the Commission in its Tariff Order 

dated May 5, 2000. 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 gas 

based station, the Commission has considered the heat rate same as that approved in its Tariff 

Order dated May 5, 2000. The stationwise heat rate approved by the Commission for FY 

2000-01, actual heat rate achieved for FY 2000-01, actual heat rate achieved in March 2001, 

actual heat rate achieved during April-Sept 2001 and the heat rate approved by the 

Commission for FY 2001-02 is summarised in the following table: 

Heat Rate for MSEB Stations 

(Kcal/kwh) 

Station 

FY 2000-01 March Apr- Commission’s 

Approved Actual 01 

Actual 

Sept 01 

Actual 

Approval for FY 

2001-02 

K’kheda – I&II 2985 2845 2708 2839 2955 

K’kheda – 

2550 

III&IV 

Paras 3265 3249 3594 3454 3232 

Bhusawal 2791 2775 2729 2774 2763 

Nasik 2717 2674 2759 2712 2690 

Parli 2703 2711 2650 2681 2676 

Koradi 3057 3044 3069 3175 3026 

Chandrapur 2553 2626 2740 2824 2527 

Total Thermal 2740 2743 2785 2849 2704 

Gas Thermal 1966 2000 1914 2006 1966 

The table below summarizes the station-wise variable cost as projected by MSEB and as 

approved by the Commission. 



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Variable Cost per unit for MSEB’s Stations 

(Rs/kwh) 

Station 

MSEB’s Projections Commission’s Approval 

VC per unit VC per unit 

Koradi 1.0260 1.0284 

Nasik 1.2409 1.2849 

Chandrapur 0.7819 0.7078 

Paras 1.2346 1.2169 

Parli 1.2016 1.2241 

Bhusawal 1.0585 0.9294 

Khaperkheda 0.8645 0.9351 

GTPS Uran 0.6371 0.6553 

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 September 2001, considering stationwise approved heat rate and disallowing 

transit loss component. 

Variable cost of NTPC and NPC Stations 

The MSEB has projected the variable cost of NTPC and NPC stations based on the March 

2001 Variable Cost of these stations. The Commission has projected the variable cost of 

NTPC and NPC stations based on actual average variable costs of these stations from April- 

September 2001. 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 Commission’s Approval 

VC per unit VC per unit 

NTPC-Vindhyachal 0.7238 0.7701 

NTPC-Korba 0.4249 0.4506 

NTPC-Kawas 2.6219 2.9617 

NTPC-Gandhar 1.0737 1.1403 

NPC-Kakrapar 2.7402 2.8816 

NPC-Tarapur 0.8386 0.8386 

Note : VC indicates Variable Cost 



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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 September 2001. 

Based on the variable costs projected and considering transmission losses, the merit order 

stack-up as projected by MSEB for the period of October 2001-March 2002 is as follows: 

Merit Order Stack as proposed by MSEB for October 2001-March 2002 

Station Load Centre VC 

per unit 

VC per unit 

(paise/kwh) 

Transmission 

Losses 

(paise/kwh) 

Hydro 0.00 0.00 1.00% 

Korba 44.19 42.49 4.00% 

Uran 64.35 63.71 1.00% 

Vindhyachal 75.27 72.38 4.00% 

Chandrapur 81.32 78.19 4.00% 

Tarapur 84.70 83.86 1.00% 

Khaperkheda 89.91 86.45 4.00% 

Koradi 106.70 102.60 4.00% 

Bhusawal 107.96 105.85 2.00% 

Gandhar 111.66 107.37 4.00% 

Parli 122.57 120.16 2.00% 

Nasik 125.33 124.09 1.00% 

Paras 127.16 123.46 3.00% 

Kawas 272.68 262.19 4.00% 

Kakrapar 284.98 274.02 4.00% 

The MSEB has also included must-run stations in merit order stack-up. However, the 

Commission has not included must-run stations in merit order stack-up. Based on the variable 

costs projected and considering associated transmission losses, the merit order stack-up as 

projected by Commission for the period of October 2001-March 2002 is as follows: 



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Merit Order Stack as approved by Commission for October 2001-March 2002 

Station Load Centre VC per unit 

(paise/kwh) 

VC per unit 

(paise/kwh) 

Transmission 

Losses 

Korba 45.86 45.06 4.00% 

Chandrapur 73.61 70.78 4.00% 

Vindhyachal 80.09 77.01 4.00% 

Bhusawal 94.80 92.94 2.00% 

Khaperkheda 97.25 93.51 4.00% 

Koradi 106.95 102.84 4.00% 

Parli 124.85 122.41 2.00% 

Paras 125.34 121.69 3.00% 

Nasik 129.78 128.49 1.00% 

Kawas 296.17 284.78 4.00% 

28.1.4.4 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 & 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 as 

ii) 

considered by MSEB: 

- Hydro stations as their variable cost is zero 

- Nuclear Plants of NPC because of technical constraints 

- The Gas based plants (Uran of MSEB and Gandhar of NTPC) because of 

wastage of gas in these plants in case of non-utilisation of gas. 

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. 



138


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. In case the demand is not met even after 

the entire available capacity has been allocated to the hour, the demand supply gap exists 

during that hour and to the extent of demand supply gap in that hour, load shedding is 

required. The sample of merit order scheduling for the month of January 2002 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 and the quantum of load 

shedding required in MU. The monthwise generation from MSEB’s own stations and 

quantum of power purchase from NTPC and NPC stations is enclosed at Exhibit-2. 

28.1.5 Quantum of Generation from MSEB’s owned plants 

Considering the actual generation from April-September 2001 and the monthwise generation 

based on merit order scheduling, the total net generation approved by the Commission for 

2001-02 is 44708 MU. The table below summarises the net generation approved by the 

Commission and as projected by the MSEB for FY 02. 

Net Generation Estimates 

MSEB Net 

Generation 

Projections for 2001- 

02 (MU) 

PLF as per 

MSEB 

Proposal 

Commission’s 

Approval for 

2001-02 

(MU) 

PLF as 

Approved by 

MERC 

Khaparkheda 5187 77.0% 5201 77.2% 

Paras 314 68.5% 328 71.6% 

Bhusawal 2929 77.7% 2968 78.8% 

Nasik 4565 62.9% 4703 64.8% 

Parli 3887 71.2% 3944 72.3% 

Koradi 5376 63.0% 5365 62.9% 

Chandrapur 14861 78.5% 14932 78.8% 

Total Thermal 37119 72.5% 37440 73.2% 

Gas Thermal 3535 45.3% 3547 45.5% 

Hydel Stations 3371 16.1% 3720 17.8% 

Total MSEB 44025 56.0% 44708 56.9% 



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As observed from the above table, the net generation from MSEB’s own stations as approved 

by the Commission is 683 MU higher than that projected by MSEB. The Commission has 

increased the generation from Hydel Stations and some of the thermal stations based on 

ability to generate factor. 

28.1.6 Estimate of Power Purchase 

Considering the actual power purchase from April-September 2001 and the monthwise 

purchase based on merit order scheduling, the total power purchase approved by the 

Commission for 2001-02 is 16040 MU. The table below summarises the net power purchase 

approved by the Commission and as projected by the MSEB for year 2001-2002. 

Estimate of Power Purchases 

(MU) 

Actual Net 

Drawal in 2000-01 

Net Drawal estimated 

by MSEB in 2001- 

2002 


Approval for 

2001-2002 

NTPC 

Korba S.T.P.S. 4857 4776 4956 

Vindhyachal S.T.P.S 4134 5028 5074 

Gandhar G.P.S 760 836 922 

Kawas G.P.S. 1416 939 1011 

sub-total (NTPC) 11167 11579 11962 

NPC 

Tarapur A.P.S. 1097 1181 1128 

Kakrapar A.P.S. 1377 1802 1811 

Sub-total (NPC) 2474 2983 2939 

NR Import 119 

106 106 

Tata Power Company. 36 375 530 

Dabhol Power Co. 2453 303 303 

Ad-hoc Purchase 23 200 200 

Total 16273 15546 16040 

As observed from the above table, the net power purchase as approved by the Commission is 

494 MU higher than as projected by MSEB. The Commission has increased the quantum of 

power purchase mainly to reduce the load shedding. 



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28.1.7 Load Shedding 

The Commission has explored all the possibilities and considered all the sources of power 

available to reduce the load shedding to the minimum extent possible. The Commission has 

reworked the availability from TPC and central stations submitted by the MSEB, so as to 

minimize the number of hours of load shedding, compared to MSEB’s projections, in the 

months of January to March 2002. The TPC has represented that it has surplus power that can 

be sold to the MSEB, to the extent of about 155 MU in the period December to March 2002. 

The surplus energy available with Tata Power has been taken into account while projecting 

the energy availability and load shedding. 

The Commission is of the opinion that the Uran gas plant should be utilized 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 intermittently being in darkness. The 

Commission hereby directs 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 total load shedding for the period of October 2001 to March 2002 as approved by the 

Commission is 398 MU as against 1885 MU projected by the MSEB. The monthwise 

quantum of load shedding as projected by the MSEB and as estimated by the Commission for 

the period of October 2001 to March 2002 is summarized in the following table: 

Load Shedding 

(MU) 

Month As projected by MSEB Commission’s Approval 

October 2001 83 6 

November 2001 386 179 

December 2001 471 29 

January 2002 358 65 

February 2002 262 68 

March 2002 325 51 

Total (Oct 2001 

– March 2002) 

1885 398 



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The Commission directs the MSEB to take all necessary steps to further reduce the load 

shedding as compared to the load shedding as approved by the Commission. The MSEB 

should explore the possibility of additional power purchase from other sources to 

reduce the load shedding. 

The Commission has not reduced the category-wise sales based on the load shedding 

projected above, as the MSEB is expected to shed agricultural load, thus ensuring shift of 

demand, and no loss of load. Moreover, it is difficult to estimate the category-wise effective 

loss of load, unless detailed ‘Loss of Load Probability’ (LOLP) studies are conducted. 

28.1.8 Generation and Power Purchase Cost 

28.1.8.1 Generation Cost: 

The Commission has estimated the total generation costs in the following manner: 

‣ Actual Generation Costs for the period April 2001 – September 2001 subject to Heat Rate 

Norms and disallowing transit loss component in coal costs as described earlier. 

‣ Projected Generation for the period October 2001 – March 2002 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 

Variable cost of power 

from the MSEB 

stations for 2001-02 

(Rs. Crore) 


Approval for 2001-02 

Khaparkheda 449 449 

Paras 39 40 

Bhusawal 301 276 

Nasik 577 604 

Parli 468 483 

Koradi 559 552 

Chandrapur 1170 1127 

Total Thermal 3564 3531 

Gas Thermal 228 232 

Total 

Generation Cost 

3792 3763 



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28.1.8.2 Power Purchase Cost: 

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 2001 – September 2001 

‣ The variable charges based on the Projected Purchase for the period October 2001 – 

March 2002 multiplied by variable cost per unit as derived earlier in Section “Merit Order 

Stack-up” 

‣ Fixed Charges in line with the ABT Order and notified fixed charge for the post ABT 

period (October 2001-March 2002). 

‣ The Income Tax payable to NTPC &NPC has been considered as Rs 140 Crore & Rs 22 

Crore as projected by MSEB 

‣ The Foreign Exchange Rate Variation (FERV) and Income Tax payable to PGCIL has 

been considered as Rs 5 Crore as 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 per unit rate of 

March’2001 for the post ABT period (October 2001-March 2002). 

Power Purchase from DPC 

MSEB has purchased 303 MU from Dabhol Power Corporation till 29 th May 2001. The 

Power Purchase Agreement between MSEB and DPC was rescinded on 29 th May 2001. The 

MSEB has not considered power purchase expense for the power purchased from DPC till 

29 th May 2001. MSEB clarified that the power purchase costs from DPC has not been 

considered as they have been contested for adjustment against the rebate claimed by the 

MSEB. Accordingly, the Commission has not considered the power purchase cost for the 

power purchased during the period 1 st April 2001 to 29 th May 2001. Further, till the dispute 

between MSEB and DPC is resolved, MSEB will neither be purchasing any power from DPC 

and nor be paying any fixed charges to DPC. Accordingly, the Commission has also not 

considered any further purchase of power and payment of fixed charges to DPC. 

Power Purchase from TEC 

The MSEB has estimated the net purchase of 375 MU from TEC. In order to reduce the load 

shedding, the Commission has approved the net purchase of 530 MU from TEC. MSEB has 

estimated the total power purchase cost of Rs 105 Crores @ Rs 2.80/kwh. Further while 

submitting clarifications to Commission’s queries, MSEB indicated that as per the agreement 

with TEC, the power purchase rate is Rs 2.50/kwh upto 14 th Sept 2001 and Rs 2.65/kwh 

thereafter. Based on these rates indicated by MSEB, the Commission has approved the total 

power purchase cost of Rs 180 Crore. 



143


Power Purchase from other sources 

The Commission has proposed no change in the quantum and rate of power purchase from 

the figures indicated by MSEB. Accordingly, the Commission has approved the power 

purchase of 200 MU and the total power purchase expense of Rs 61 Crores. However, this is 

provisional, subject to the approval of the Power Purchase Agreement (PPA) between the 

MSEB and the Co-generation and other sources of energy, which are under consideration of 

the Commission. 

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 

for 2001-02 


Approval for 2001-02 

NTPC 

Korba S.T.P.S. 492 408 

Vindhyachal S.T.P.S 751 716 

Gandhar G.P.S 257 304 

Kawas G.P.S. 332 404 

Income Tax Payable 140 140 

Sub-Total (NTPC) 1972 1972 

NPC 

Tarapur A.P.S. 113 108 

Kakrapar A.P.S. 494 544 

Sub-total (NPC) 607 653 

NR Import 9 9 

Tata Electric Co. 105 180 

Ad-hoc Purchase 61 61 * 

Power Grid 73 76 

Total 2827 2950 

Note: * - Provisional approval based on assumed rate of Rs. 3.05 / unit, based on MNES Guidelines– 

actual cost will depend on rate approved by the Commission while ruling on the PPA’s with these IPPs. 

As observed from the above table, the total power purchase expenses approved by the 

Commission is higher as compared to the MSEB’s projections. The Commission has 

considered increased quantum of power purchase from Central Generating Stations and TPC 

in order to reduce the load shedding and projected the variable cost of power purchase for the 

period of October 2001-March 2002 based on the actual average variable cost for the period 

April-September 2001. 



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28.1.9 Total Generation and Power Purchase Expenses 

The total Generation & Power Purchase Cost as approved by Commission for 2000-2001, 

Actual Cost for 2000-2001, MSEB’s projected cost and the Commission approved cost for 

2001-2002 is summarised below: 

Total Generation and Power Purchase Cost 

(Rs. Crore) 

FY 2000-01 FY 2001-02 

Approved Actuals MSEB Commission’s 

Approval 

Total Generation Cost (Rs. Cr) 3387 3518 3792 3763 

Generation Cost per unit (Rs/kwh) 0.78 0.83 0.86 0.84 

Power Purchase : 

- Fixed Costs 1020 963 575 571 

- Variable Costs 2523 3063 2252 2379 

Total Power Purchase Cost (Rs. Cr) 3543 4026 2827 2950 

Total Generation and Power 6931 7545 6620 6714 

Purchase Cost (Rs. Cr) 

Generation and Power Purchase 

Cost per unit (Rs.) 

1.17 1.28 1.11 1.10 

28.2 Other Heads of Expenditure 

28.2.1 Employee Expenses 

The MSEB has projected employee expenses of Rs. 1840 crore, net of capitalization, 

including a provision of Rs. 244 crore on account of pay revision payment arrears. The 

MSEB has submitted that the wage agreement, which was due since April 1998, was signed 

only in January 2001. The accumulated arrears to be paid to the employees’ amounts to Rs. 

455 crore, of which Rs. 170 crore has already been provisioned for in FY99 and FY 1999-00, 

leaving a balance of Rs. 285 crore. 

The wage agreement provides for payment of 50% of the wage arrears only if the revenue 

collection in any month is over Rs. 1000 crore, and the arrears will be paid to the extent of 

50% of the surplus collection only in those months. The Commission commends the MSEB 

for incorporating this clause in the wage agreement, as it provides a tremendous incentive for 

the employees to improve the revenue collection, which will improve the cash flows of the 



145


MSEB. The MSEB has to however, provision for this payment in the current year, and hence 

the amount has been included in the revenue requirement for FY 2001-02. 

The MSEB has also submitted that 16% of the wage revision is included in the terminal 

benefits for FY 2001-02, which amounts to Rs. 41 crore. The net amount to be provided for 

through the tariffs is thus Rs. 244 crore. The MSEB has submitted that, in the revised pay 

scales, there has been an increase of 32% in the basic salary and 25% in the allowances 

payable. At the same time, part of the Dearness Allowance (DA) has been shifted to basic 

salary, and the net increase in basic and DA is an increase of 22.5%. 

The MSEB has also submitted that it has taken all possible steps to reduce the expenditure on 

employees by imposing a ban on direct recruitment, reduction in overtime payments, 

imposition of travel discipline, etc. The Commission is of the view that the wage revision 

agreement is a statutory agreement, and the MSEB is bound to honour the agreement. The 

Commission has also accepted the MSEB’s projections of staff welfare expenses 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 Commission has hence approved the expenses 

as submitted by the MSEB, with three differences, viz. 

• The Commission had reduced Rs. 100 crore from the employee expenses on account 

of wage revision, and had directed the MSEB to earn the additional amount through 

efficiency improvement. The Commission has hence disallowed the pay revision 

provision to the extent of Rs. 100 crore, in line with the previous Order. The MSEB is 

free to pay the arrears by earning additional revenue, through efficiency 

improvements. 

• All subsequent wage revision agreements should be linked to achievement of 

productivity norms. 

• The payment of bonus by the MSEB should be linked to incentive schemes 

designed to improve the operations of the MSEB. The incentive schemes should 

be implemented for all aspects of MSEB’s operation, viz. generation, 

transmission and distribution. 

• The MSEB has applied a capitalization rate of 10.8%, based on the rate applicable in 

the previous year. The Commission has applied the average capitalization rate 

observed over the past three years (12.8%) as a better indicator of the capitalization 

rate. 

The total employee expenses allowed by the Commission is Rs. 1703.84 crore, including the 

wage arrears provision of Rs. 144 crore. 



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28.2.2 Administration and General (A & G) Expenses 

The MSEB has projected A & G expenses of Rs. 123 crore in FY 2001-02, net of 

capitalisation. The expenses have been projected to increase marginally over the actual 

expenses incurred in the previous year, though the CAGR of A & G expenses is almost 10%. 

The Commission has hence accepted the A & G expenses projected by the MSEB. 

The MSEB has also requested the Commission to pass through the interest on late payment of 

Electricity Duty (ED) to the GoM through the tariffs, amounting to Rs. 155 crore. The MSEB 

has submitted that the subsidy payments are not received on time from the GoM, and in order 

to accommodate these delays, the MSEB is forced to delay payment of ED or increase 

borrowings for working capital. However, the GoM does not pay any interest on the delayed 

subsidy payments. 

The Commission is of the view that the MSEB’s consumers have already paid the ED and it 

is the responsibility of the MSEB to forward the same to the GoM. At the same time, there is 

no gainsaying the fact that the GoM has delayed payment of subsidy and this affects the 

liquidity of the MSEB. The Commission has hence requested the GoM to clarify its stand on 

the payment of interest on ED. The GoM has clarified that a proposal has been placed before 

the Finance Ministry that the interest on late payment of ED should not be charged, as the 

GoM normally adjusted the ED against payment of subsidy, and the late payment of subsidy 

was one of the causes of the late payment of ED by the MSEB. The Commission has hence 

not allowed this expenditure in the revenue requirement of the MSEB for FY 2001-02. 

Further analysis of the interest claimed by the GoM shows that the effective interest rate on 

the outstanding ED works out to about 22%, which is extremely high. In such a situation, it 

would be prudent on the part of the MSEB to pay the ED and take a working capital loan at 

lower rates of interest ranging around 12% to 13%. The Commission hence directs the 

MSEB to consider all possible sources of funds and opt for the lowest cost funds, while 

determining its financing plan. 

The capitalisation rate of 14.3% proposed by the MSEB is based on the previous year’s 

capitalisation rate. The Commission has applied a capitalisation rate of 16.4%, which is the 

average capitalisation over the past three years. The net Administration and General expenses 

approved by the Commission are Rs.119.55 crore. 



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28.2.3 Depreciation Expenses 

The MSEB has projected depreciation expenses of Rs. 1544 crore, based on the average 

depreciation rate of 6.81 % on the opening gross block of assets over the past three years. 

This is in line with the philosophy adopted by the Commission in the previous Tariff Order. 

The actual depreciation charged over the past three years as a percentage of the opening gross 

block of assets works out to 6.73% 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. 1526.94 crore. 

28.2.4 Operations and Maintenance (O & M) Expenses 

The MSEB has projected O & M expense to the extent of Rs. 672 crore, net of capitalization, 

which is about 3% of the Gross Fixed Assets (GFA) at the beginning of the year. The actual 

expenses as a percentage of GFA have been ranging around 3% to 4% with an average rate of 

3.55% over the past ten years. In FY 2000-01, due to paucity of funds, the MSEB has 

reduced its O & M expenses, to around 2.3% of the opening GFA. 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 capitalisation rate applied by the Commission is an average rate of the past three years 

(1.5%) as compared to the 1.2% assumed by the MSEB. The O & M expenditure allowed by 

the Commission is Rs. 670.22 crore. 

28.2.5 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 FY 2000-01, i. e., Rs. 85 crore. The 

MSEB is currently engaged in discussions with the GoM regarding the lease rentals to be 

charged for the newly commissioned hydel plants at Koyna. The Commission has accepted 

this expense of Rs. 85 crore, on account of lease rentals. 

28.2.6 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 2001-02, 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 

2001-02. The interest has been projected based on the average outstanding during the year. 



148


The MSEB has reduced the amount of interest due to loans taken to invest in Dabhol Power 

Company, in line with the Commission’s ruling in this regard in its previous Tariff Order, 

dated May 5, 2000. The Commission has accepted the projections of the interest on long-term 

loans as projected by the MSEB, as it has been found reasonable. The Commission has, 

however, applied a higher capitalization rate (15.7%) as compared to the MSEB (14.3%), 

based on the actual capitalization rate observed in FY 2000-01. The Commission also 

directs the MSEB to try and replace its high cost loans (loans taken by the MSEB from 

LIC, PFC and HDFC have an average interest rate of over 14%) with cheaper loans, to 

benefit from the prevailing low interest regime. 

28.2.6.1 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 used to defer 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 further classified the working capital loans into 2 parts, 

viz. from tied sources (Rural Electrification Corporation and MMRDA), and the balance from 

untied sources. 

The MSEB has submitted that part of the working capital loans are being reported under long 

term loans and hence the interest on stated working capital loans has been much lower in the 

past. The interest expenditure on working capital has been reported only around Rs. 50 lakh 

in the earlier years. The actual working capital interest incurred by the MSEB in the period 

April to September 2001 was Rs. 15 crore. 

The Commission agrees that the MSEB needs working capital to fund its regular 

requirements on account of the delay in payments by the consumers and to fund the payments 

for generation expenses. However, it is a fact that all businesses strive to match the inflows 

and outflows by delaying payments, if required. The MSEB should continue with the existing 

practice, wherever possible, and if there is negligible financial impact in terms of penalties. 

The Commission also directs the MSEB to consider innovative methods such as spot 

billing, opening of more collection centers, authorizing more agencies such as Lions 

Club, Rotary Club, etc. to collect payments to reduce the billing and collection cycle, 



149


thus improving the cash flows of the MSEB. These methods have been successfully 

implemented in other States such as Andhra Pradesh. The MSEB already has a system 

enabling consumers to pay their bills on-line, by directly debiting their bank accounts. The 

MSEB may also consider introduction of the ‘Voluntary Deposit Scheme’; akin to the 

scheme offered by the Mahanagar Telephone Nigam Ltd. (MTNL), wherein the consumers 

have the option to pay a specified amount in advance against their future bills as a deposit. 

The MSEB can deduct the bill amount from the deposit, while paying interest on the balance 

amount. Such steps will enable the MSEB to improve its cash flows and at the same time, 

make it more convenient for the consumers to pay their bills on time. 

The Commission has also made its views clear on this issue in the FOCA Order issued in July 

2001, wherein it had directed that the entire security deposits collected by the MSEB should 

be considered as a current liability, and the working capital requirement should be calculated 

on the basis of 0.75 x (CA – CL), where CA is current assets and CL is current liabilities. The 

projected security deposit at the end of FY 2001-02 is Rs. 1458 crore, and the average 

amount of security deposit in FY 2001-02 is Rs. 1370 crore. The average security deposit has 

been considered as current liability and the net working capital requirement has been 

estimated as Rs. 502 crore. Assuming an average interest rate of 12.5%, the working capital 

interest allowable has been projected as Rs. 63 crore. 

The total interest expense allowed by the Commission for FY 2001-02 is Rs. 1110 crore, net 

of capitalisation. 

28.2.7 Provision for Doubtful Debts 

The MSEB has not shown any improvement in the metering and billing efficiency, though 

there has been some improvement in the collection efficiency, as indicated by the reduction 

in arrears of the Residential, Commercial and LTP-G categories. However, the data on the 

average billing and faulty meter reading reveals that there has been no improvement and the 

reduction in basis other than metered is solely on account of the reduction due to the abolition 

of minimum meter billing by the Commission. The Kalyan, Beed and Pune zones have a 

higher than average level of billing on basis other than metered. The Commission directs 

the MSEB to improve the metering and billing efficiency to 75%, 80% and 90% from 

the existing levels of 69%, 71% and 80%, for the residential, commercial and LTP-G 

category, respectively, by the end of December 2002. 

The MSEB has achieved an overall collection efficiency of 92%, with higher collection from 

HT I to HT VI, and residential, commercial and LTP-G categories (95 ~ 100% range), and 

lower collection from HTP-VII, power loom, LT agriculture, LT PWW (rural) and street 

lighting categories (40 ~ 45% range). Though the overall collection efficiency is appreciable, 


150 

Decision on MSEB’s Proposal


the lower collection efficiency from categories that are already heavily subsidised is 

alarming. Moreover, the MSEB has projected an overall collection efficiency of only 90% in 

the cash flow statement submitted along with the Tariff Proposal. This is unacceptable, and 

the Commission directs the MSEB to improve the overall collection efficiency to 94% in 

FY 2001-02, with more emphasis on the categories having extremely low collection 

efficiency. 

The MSEB has submitted that delay / default by the local bodies in payment of electricity 

dues on account of PWW and Street lighting connections, severely affects the liquidity 

position of the MSEB and has requested the Commission to direct the GoM to remit the 

grants directly to the MSEB in lieu of the electricity dues. The Commission finds that there is 

merit in the MSEB’s suggestion, and requests the GoM to make a separate budgetary 

provision for payment of electricity bills while drawing up the budgets of the local bodies, as 

against the existing practice of clubbing electricity payments with other miscellaneous 

expenses. As regards the arrears of the Mula Pravara, the GoM has indicated that it has 

directed the Mula Pravara to pay its arrears before May 2000 to the MSEB, and was 

considering the payment of the difference in the ‘viable tariff’ determined as per the GoM 

formula and the tariff determined by the Commission. The GoM has to either ensure that the 

payments are made on time, or materially and morally support the MSEB in its disconnection 

drives against the local bodies and Mula Pravara. 

It is hoped that the GoM will co-operate in this regard, by setting aside an identified amount 

for payment of electricity bills in the budgets of the local bodies, as well as refraining from 

announcing amnesty schemes for waiver of dues, without adequately compensating the 

MSEB for the same. The Commission also directs the MSEB to disconnect all consumers 

whose names appear in the defaulters’ list for the second time, and submit the details of the 

same to the Commission along with the copy of the defaulters’ list. 

Several consumers have submitted that if all the arrears were collected, then there would be 

no need for tariff revision. However, it is ironical that the categories who complained the 

most about the high level of receivables, i. e. agriculture and power loom are one of the 

biggest defaulters of the MSEB, and due to GoM pressure, the MSEB is unable to disconnect 

these consumers. Moreover, the Commission would like to clarify that the billings have 

already been accrued as revenue in the same year, and collection of the arrears will not 

amount to ‘additional revenue’, and thus will not obviate the need for a tariff revision. At the 

same time, the reduction in the level of receivables will improve the liquidity position of the 

MSEB, and reduce the MSEB’s requirement for working capital finance. 



151


The total receivables of the MSEB amounted to Rs. 5200 crore as on March 31 st 2001, which 

is equivalent to almost 180 days of receivables, i.e. 6 months of sales revenue in FY 2000-01. 

This is extremely high and the Commission directs the MSEB to reduce the receivables in a 

time-bound manner. The Commission has set the MSEB a target of reducing the receivables 

to an equivalent of 5 months of the sales revenue in FY 2001-02, which would require the 

MSEB to reduce the receivables to a level of around Rs. 4600 crore in FY 2001-02. The 

MSEB should reduce the receivables every year in this fashion, and the permissible limit 

would be only 2 months of receivables. 

The MSEB has projected the provision for doubtful debts at Rs. 200 crore, which is 1.7% of 

the revenues projected by the MSEB for FY 2001-02. In FY 2000-01, the actual provision for 

bad debts was Rs. 172 crore, against the Rs. 200 crore allowed by the Commission. 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. 169.7 crore, considering the 

revenue from sale of electricity with existing tariffs being applicable for 9 months and revised 

tariffs being applicable for 3 months. 

28.2.8 Other Expenses 

The MSEB has projected other expenses of Rs. 251 crore, as compared to the previous year’s 

expense of Rs. 214 crore. The Commission has disallowed the penal interest on account of 

late payment of GoM guarantee fee, on the same rationale applied for disallowance of interest 

on late payment of Electricity Duty. The Commission has also disallowed the write off of bad 

debts claimed by the MSEB under ‘others’, as this has already been accounted for under 

‘provision for bad debts’. The security deposit projected by the Commission is higher than 

that projected by the MSEB and consequently, the interest on security deposit has been 

projected higher than that projected by the MSEB. The details of the ‘Other Expenses’ 

approved by the Commission are given below: 

Other Expenses 

(Rs. Crore) 

Sr Other Expenses 

MSEB MERC 

No. 


1 Interest on consumer’s security deposits 43.57 61.67 

2 Commitment charges 2.00 2.00 

3 Banks charges 54.52 54.52 

4 Guarantee Charges 93.68 93.68 

5 Loss on exchange rate variations 13.00 13.00 

6 Tax on sale of electricity 0 0 

7 Write off of deferred revenue expenditure 18.50 18.50 



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8 Recovery cost of agricultural consumers 0 0 

9 Others 16.30 11.30 

10 Penal Interest on late payment of GoM 

9.15 0 

guarantee fee 

Total 250.72 254.67 

28.2.9 Surplus 

The MSEB is entitled to earn the mandatory surplus on its Net Fixed Assets at the beginning 

of the year, as per S. 59 of the E (S) Act. The GoM has recently issued a gazette notification 

increasing the mandatory surplus to 4.5% of the Net Fixed Assets at the beginning of the 

year. The Commission has allowed the surplus at the rate of 4.5%, as Rs. 493.18 crore, which 

is the same as the MSEB’s projections. 

28.3 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 summarised below: 

Annual Revenue Requirement (Rs. Crore) 

Sr Expense Head 

MSEB MERC Remarks 

No 


1 Generation 3792.0 3763.1 Reduction despite higher 

generation, due to reduction in 

heat rate and disallowance of 

transit loss 

2 Power Purchase 2818.0 2950.0 Higher mainly due to higher 

power purchase to reduce load 

shedding 

3 Operation & Maintenance 672.1 670.2 

4 Employee Costs 1840.0 1703.8 Reduction due to disallowance of 

Rs.100 cr of wage arrears and 

higher capitalization rate 

5 Administration & General 

expenses 

277.6 119.6 Reduction due to disallowance of 

Rs.155 cr of interest on late 

payment of ED to GoM 

6 Depreciation 1544.0 1526.9 Reduction due to average 

depreciation rate being lower 

8 Provision for doubtful debts 200 169.7 Allowed at the rate of 1.5% of 

revenue from sale of electricity 

7 Interest cost 1308.4 1110.4 Reduction in working capital 

interest 

8 Lease Rental 85.0 85.0 

9 Other Expenses 250.7 254.7 

Total Expenses 12787.8 12353.3 

Add: Surplus 493.2 493.2 

Total Revenue Requirement 13281.0 12846.5 



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Thus, the total revenue requirement projected by the Commission is Rs. 12846.5 crore, for 

FY 2001-02. 

The Commission has analyzed the various heads of expenditure allowed by the Commission 

for FY 2001-02 vis-à-vis the actual expenditure in FY 2000-01, to help the consumers 

understand the reasons for the increase in overall expenditure, despite the reduction in power 

purchase cost, due to the non-inclusion of power purchase from the DPC. This has been a 

common refrain during the public hearings, and the Commission would like the consumers to 

understand the reasons behind the increase in expenditure. The MSEB has already submitted 

the comparison between the expenditure allowed by the Commission for FY 2000-01 and the 

actual expenditure incurred by the MSEB in FY 2000-01, on page 1-3 of the Tariff Proposal. 

The main heads of expenditure, where the actual expenditure has been higher than projected 

has been generation and power purchase, a substantial portion of which has been allowed 

subsequently through the FOCA formula. The comparison of the allowed expenses in FY 

2001-02 with the actual FY 2000-01 expenses is presented in the following table: 

Analysis of Expenditure 

Expenditure FY 2000- 

01 

(Actual) 

FY 2001-02 

Difference with FY 

2000-01 actual 

expenditure 

MSEB MERC 

(Rs. Crore) 

Remarks 

MSEB 

Proposal 

MERC 

Approval Proposal Approval 

Generation 3518 3792 3763 274 245 Increase lesser due to 

heat rate improvement 

and removal of transit 

loss 

Power Purchase 4026 2818 2950 -1208 -1076 Reduction lesser due to 

higher power purchase 

to reduce load shedding 

Operation & 453 672 670 219 217 Increase as actual 

Maintenance 

expenditure in FY 

2000-01 was much 

lower compared to 

allowed in FY 2000-01 

Employee Costs 1474 1840 1704 366 230 Increase due to revised 

Administration 

& General 

expenses 

wage agreement 

117 * 278 120 160 2 Increase negligible, due 

to disallowance of 

interest on late 

payment of ED 

Depreciation 1329 1544 1527 215 198 Increase due to asset 

addition in FY 2000-01 



154


Provision for 172 200 170 28 -2 

doubtful debts 

Interest cost 1043 $ 1308 1110 266 68 Reduction in allowed 

working capital interest 

Lease Rental 85 85 85 0 0 

Other Expenses 214 251 255 37 41 

Total Expenses 12431 12788 12353 357 -78 

Add: Surplus 304 $$ 493 493 189 189 GoM gazette 

notification for 4.5% 

surplus 

Total Revenue 12735 13281 12846 546 111 

Requirement 

Note: * - Excluding Rs. 155 crore interest on late payment of ED to GoM 

$ - Excluding Rs. 107 crore on account of interest on bonds raised for DPC stake 

$$ - Considering only 3% surplus, as gazette notification for 4.5% surplus issued subsequently 

The above comparison highlights the various reasons for the increase in Revenue 

Requirement as compared to the actual expenditure in FY 2000-01. 

29 REDUCTION IN ANNUAL REVENUE REQUIREMENT 

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: 

1. Excess T & D loss 

2. Revenue earned through FOCA for additional expenses in FY 2001-02 

3. Other Income 

29.1 Excess T & D loss 

The Commission has computed the cost of the excess T & D losses declared by the MSEB as 

compared to the targets set by the Commission. 

29.1.1 Excess losses as compared to Commission’s targets 

The MSEB has submitted that the estimated T & D losses are 39.4%. Based on the energyinput 

calculations discussed above and the T & D losses considered for the purpose of 

estimating the Energy Input requirement, the T & D losses works out to 39.6%. The target for 

T & D losses set by the Commission by the end of FY 2000-01, was 26.87%, the balance 

losses of 12.8% are thus excess losses vis-à-vis the targets. The losses are equivalent to 7772 

MU of energy input requirement. 

The MSEB has submitted that the T & D loss has not increased from 31.87% in FY 1999-00 

to 39.4% FY 2000-01, but the actual losses have been assessed better in the current exercise. 

The reasons put forth by the MSEB and the impact on the losses are: 



155


Sr. MSEB’s Justification Impact on T 

& D loss (%) 

1 Reduction in LT Agricultural consumption norm from 1600 to 1300 3.2% 

hrs/HP/year 

2 Reduction in LT Agricultural reported connected load from 83.5 lakh 0.8% 

HP to 78.1 lakh HP 

3 Reduction in Power loom consumption norm from 10 to 8 hours per 0.6% 

day per loom 

4 Reduction in Power loom reported connected load from 6.7 lakh HP 0.9% 

to 4.4 lakh HP 

5 Non-achievement of additional billing of 2200 MU 3.7% 

Overall Impact (with reasoning) 9.8% 

6 Reduction in HV/EHV sales 

7 Higher Energy Input in eastern part of the State and lower Energy 

Input in the Western part of the State 

Thus, the MSEB has attempted to justify about 10%of the excess T & D losses, as compared 

to the targeted level of 26.87 %. The remaining reasons cannot be quantified in terms of the 

impact on T & D loss, though they are logical reasons. The MSEB has added that T & D loss 

cannot be accurately estimated unless 100% metering is achieved, and the concept of T & D 

loss should be replaced by ‘metered consumption’ as a parameter. The MSEB has committed 

to a target of 2% improvement in the metered consumption, over FY 2000-01 levels. 

It is necessary to pause here for a moment to consider what exactly is the implication of T & 

D losses of the magnitude mentioned above for the total finances of the MSEB itself and for 

the electricity consumers of the State. The Central Electricity Authority of the Government of 

India is considered to be the apex expert body in the country in so far as estimating or laying 

down various standards and performance parameters in the electrical sector, especially for the 

guidance of SEBs and other electricity utilities, is concerned. The CEA has laid down that, 

for Indian conditions, the maximum permissible figure for T & D losses for any SEB in the 

country should be 16 per cent. In the developed countries, and even in some developing 

countries like Brazil, T & D losses do not exceed 8 or 9 per cent. In Maharashtra, in Mumbai 

City, Tata Power Company, B.E.S.T. and B.S.E.S. have been able to contain their T & D 

losses within around 11 per cent. 

The Commission has estimated that, for the year 2001-2002, 61145 million units would be 

available for the MSEB through generation and power purchase. Out of this, the sale of 

electricity to consumers is projected to be only 37000 million units. This is because the 

projected T & D losses are of the order of 39.49%. As against the projected loss of 39.49% in 

the present tariff proposal, if only it were possible to restrict the loss to the CEA norm of 

16%, the MSEB would be able to bill and collect revenue for an additional 14363 million 



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units. Since the average realization for the MSEB for 2001-2002 is estimated to be Rs. 3.15 

per unit, as discussed in section 29.4 on Annual Revenue Requirement, this means an 

additional revenue of about Rs. 4524 crore. This is much more than the annual budget of the 

Greater Mumbai Municipal Corporation (Annual budget of GBMC is Rs. 4391 crore in FY 

2001-02, for a population of about 1 crore and 9 lakh people) and probably higher than the 

annual budget of some of the States of the Indian Union. By tolerating T & D losses of 

39.49%, the MSEB is, in effect, foregoing an enormous revenue loss of Rs. 4524 crore. It 

may be mentioned, in this context, that the total revenue requirement of the MSEB for 2001- 

2002 is estimated to be Rs. 12846 crore as discussed in Section 28.3. 

During the year 2000, the MSEB filed a Review Application against the Commission’s Tariff 

Order dated 5 th May 2000. In its affidavit and in its oral submissions on oath before the 

Commission, the MSEB pleaded that, for a number of technical and financial reasons, the 

CEA norm for T & D losses of 16% was not achievable in Maharashtra. The MSEB argued 

that it would be more realistic to strive to attain a target of 21%. Even if we accept this more 

modest figure of 21%, and if the MSEB is able to reduce its T & D losses to this figure, it 

would mean an amount of about Rs. 3561 crore as additional revenue for the additional 

11306 million units billed and collected. 

The target fixed by the Commission to be achieved by the MSEB for 2001-2002 was even 

more modest, viz., 26.87% of T. & D losses. If this had been achieved, it would have been 

able to bill and collect revenue for an additional 7715 million units, which works out to Rs. 

2430 crore, and, as pointed out by a number of Objectors to the MSEB’s tariff proposal 

during the public hearings before the Commission, there would not have been any need at all 

for the MSEB to approach the Commission for a revision since the tariff increase asked for 

by it in the present application is for only Rs. 1456 crore. 

In the light of the foregoing, a quick calculation would show that if the T & D losses of the 

MSEB were brought down to the level that it has itself accepted in its Review Application in 

the year 2000, namely, 21%, it would be possible to bring down the average tariff, which has 

been worked out to be Rs. 3.15, to about Rs. 2.54per unit. Further, if the T & D losses were to 

be brought down to the CEA norm of 16%, the average tariff can be brought down by yet 

another 15 paise, namely, to Rs. 2.39 per unit. 

Therefore, by tackling the T & D losses problem effectively, it would be possible to benefit 

all categories of consumers through tariff rationalization. Further, as a result, a sea change for 

the better would be brought about in the financial position of the MSEB. Again, since it 

would be possible to bring down industrial and commercial tariffs even further than at 



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present, Maharashtra would be able to attract more industries and more industrial and 

commercial investment and, as a consequence, a virtuous circle of prosperity, increased 

employment, higher incomes, etc., would result. It is in this background that the question of 

tackling T & D losses has to be viewed. 

It is the view of the Commission that the MSEB does not seem to have made any substantial 

efforts to reduce T & D losses, especially commercial losses or losses due to theft of 

electricity by the not-so-honest elements amongst the consumers. It has to be recalled at this 

stage that, out of the total T & D losses, only a small portion is the irreducible minimum 

technical losses. The major portion consists of commercial losses, in fact, outright theft or 

pilferage of electricity in a variety of imaginative ways. Before the Commission was 

established in August 1999, it was being maintained by the MSEB for the last over 20 years 

before all instances like the State Legislature, Parliament, State Government, the Planning 

Commission, other public forums, the media, etc., that its T & D losses were only in the 

region of 17%. 

It was only during the course of the public hearings held in the year 2000 by the Commission 

in 6 different cities in Maharashtra that the MSEB was forced by irrefutable logic to admit on 

affidavit that its T & D losses were about 30%. In the present tariff proposal, not only has the 

MSEB sought to justify the lack of progress in reducing the loss from 31.87% to 26.87% 

during 2000-2001 mandated by the Commission in its last Tariff Order, but it has urged that, 

on account of improvement in estimation based on a larger sample size of 1701 feeders, the T 

& D loss level has, in fact, increased to 39.5%. It has even gone on further to state that, for 

the next year, energy audits of over 5500 feeders in the State were being undertaken and, as a 

result, it is likely that the T & D loss level may go up even further to 50-55 per cent! It 

pleaded before the Commission that the performance of the MSEB should not be judged by 

the progress achieved in reducing T & D losses, but it should be judged on the basis of the 

percentage of meterisation achieved in the State. 

The MSEB has detailed before the Commission the steps taken by it to reduce thefts of 

electricity during the previous year. It has drawn the attention of the Commission to the large 

number of disconnections that it has resorted to recently. It has referred to the increasing 

number of attacks on MSEB vigilance personnel, Flying Squad members and other staff by 

irate consumers when the former made efforts to detect thefts or to effect disconnections of 

wilful defaulters’ electrical equipment from the MSEB’s points of supply. In order that the 

MSEB’s staff may be more effective in this regard, it points out, it is necessary that more 

police personnel should be available to accompany them on their vigilance missions. 

However, due to a variety of familiar reasons, such as, general law and order situation, fairs 



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and festivals, VIP bandobast duties, etc., such police personnel in sufficient numbers are not 

always available. More often than not, they are just not available. In short, the MSEB claims 

that it has done all in its power to tackle the T & D loss problem, but with limited success. 

The Commission has carefully considered the available options in the matter of addressing 

this vexed problem of increasing T & D losses of the MSEB. In fact, this is a problem 

confronting all SEBs in the country. Increasing T & D losses, achieving 100% metering of 

electricity consumers and speedy recovery of mounting arrears on account of electricity bills 

are the three most difficult problems facing all the SEBs in the country, which are defying 

effective solutions. One solution could be to reject the proposal for tariff revision presented 

by the MSEB merely on the ground of excessive T & D losses which, admittedly, it has not 

been able to control. As pointed out above, if the MSEB had succeeded in carrying out the 

mandate expressed in this Commission’s last Tariff Order of 5 th May 2000 to bring down the 

losses to 26.87%, it would have earned additional revenue to the extent of about Rs. 2430 

crore. In the present proposal, the MSEB has asked for a tariff increase to the extent of only 

Rs. 1456 crore. Clearly, no tariff hike is, therefore, called for. In fact, in the recent public 

hearings held by the Commission to consider the MSEB’s tariff revision proposal, several 

objectors demanded that the proposal should be rejected out of hand for this very reason. 

However, it is the considered view of the Commission that if this option were to be accepted, 

it would have plunged the Board straightaway into a financial crisis as it is already facing a 

severe cash crunch. Even the State Government is not in a sufficiently strong position to bail 

the Board out owing to its own financial difficulties. A second option is to resort to the 

traditional method of suitably adjusting the demand charge and energy charge on different 

categories of consumers to the extent of the deficit in the usual cost-plus manner so as to 

meet with the requirements of Section 29 of the Electricity Regulatory Commissions Act, 

1998, read with Section 59 of the Electricity (Supply) Act, 1948. This would amount to 

acknowledging, without demur or scrutiny, the MSEB’s standpoint that we should just accept 

the fact of mounting T & D losses and proceed to hike the tariff. The question would also 

arise as to what should be done when the MSEB comes up after a year and reports that their T 

& D losses have indeed increased to, say, 55% based on a larger sample of feeders numbering 

5500 or 6000, and citing, more or less, the same reasons for not being able to put a stop to 

rampant power thefts. 

It is the view of the Commission that accepting either of these two options would tantamount 

to taking the line of least resistance by refusing to face up to the problem of T & D losses 

and, in fact, to brushing the problem under the carpet, as it were. The Commission has, 

therefore, considered a third option by taking a stringent view of the excessive commercial 



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losses. It has decided to partially reduce the allowed revenue requirement of the MSEB. It 

has, however, to be admitted that the MSEB is not entirely to blame for this phenomenon of 

T. D. losses. There is no denying the fact that a section of the MSEB’s consumers is also 

responsible for the high level of losses. The real difficulty lies in pinpointing this section of 

the consumers. 

The consumers who indulge in connivance/theft of energy are, of course, directly responsible. 

But, even honest, paying consumers who do not raise their voices to complain or are 

apathetic or look the other way when rampant thefts of electricity are taking place in their 

vicinity, can also be considered to be indirectly responsible for this distressing phenomenon. 

At the same time, it is evident that no single consumer category can be held to be solely 

responsible for the high and increasing level of T & D losses. Taking into consideration all of 

these factors and in the context of the socio-economic ethos in which the MSEB has to 

function, it appears to the Commission that the time has now come to confront this menace of 

increasing T & D losses in a more direct, determined and focused manner. 

The Commission is of the opinion that, by way of analogy, the procedure indicated in Section 

51 of the Bombay Police Act, 1951, which is provided for tackling disturbances where it is 

not possible to pinpoint responsibility on one or more persons for damage caused to property, 

etc., can be suitably adapted to tackle the present situation of excessive T & D losses in the 

MSEB serviced areas. 

Here, the Commission would like to refer to S.51 of the Bombay Police Act, 1951, which 

deals with compensation when any loss or damage is caused to any property during 

communal disturbances in which responsibility cannot be fixed on particular individual. The 

S. 51 of the Bombay Police Act has been reproduced below: 

1) When any loss or damage is caused to any property or when death results or grievous hurt 

is caused to any person or persons, by anything done in the prosecution of the common 

object of an unlawful assembly, the State Government may, by notification in the Official 

Gazette, specify - 

a) The area (hereinafter called “the disturbance area”), in which in its opinion such 

unlawful assembly was held; 

b) The date on which or the period during which such unlawful assembly was held. 

2) The decision of the State Government under clauses (a) and (b) of subsection (1) shall be 

final. 



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3) On the issue of a notification under sub-section (1), the Chief Presidency Magistrate in 

Greater Bombay, and the District Magistrate, in district, (with the previous sanction of the 

Revenue Commissioner), may, after such inquiry as he deems necessary, determine the 

amount of compensation which, in his opinion should be paid to person or persons in 

respect of the loss or damage or death or grievous hurt aforesaid. The amount of 

compensation shall be a tax imposed under this section and shall be recovered in the 

manner prescribed in the succeeding subsections. 

4) The Chief Presidency Magistrate or the District Magistrate, as the case may be, may 

require, - 

a) In any disturbance area which is within the limits of a Corporation, the Municipal 

Commissioner, the Collector or any other authority; 

b) In any disturbance which is within the limits of Municipality, the municipality, the 

Collector or any other authority; and 

c) In any disturbance which is outside the area specified in clauses (a) and (b) the 

Collector or any other authority, 

to recover the amount (hereinafter called “the compensation amount”) as determined 

under sub-section (3) either in whole or in part ad where the Municipal Commissioner or 

the Municipality is required to recover such amount, an additional sum not exceeding 

three percent of the compensation amount (hereinafter referred to as the “Municipal 

recovery costs”), generally from all persons who were inhabitants to the disturbance area 

or specifically from any particular section or sections, or class or classes of such persons 

in the said area, and in such proportion as the Chief Presidency Magistrate or the District 

Magistrate may direct. 

5) (i) The Chief Presidency Magistrate or the District Magistrate, as the case may be, may 

also require the Municipal Commissioner or the Municipality concerned to recover the 

compensation amount and the municipal recovery cost by an addition to the general or 

property tax which shall be imposed and levied in the disturbance area. Every addition to 

the general or property tax imposed under this sub-section shall be recovered by the 

Municipal Commissioner or the Municipality concerned from each person liable therefor 

in the same manner as the general or property tax due from him. The provisions of the 

relevant Municipal Act shall apply to any such addition as if it were part of the general or 

property tax under the relevant Municipal Act. Such additional shall be a charge along 

with the general or property tax on the properties in the area aforesaid. 

(ii) The Chief Presidency Magistrate or the District Magistrate, as the case may be, may 

also require the Municipal Commissioner or the Municipality concerned to recover the 

compensation amount and the municipal recovery cost from each person liable therefor 

under sub-section (4) in such manner as he may direct. 



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6) Where a Municipal Commissioner or a Municipality makes default in imposing and 

levying any such tax or in making any such recovery, the State Government may direct 

the Collector to impose and levy such tax or to make such recovery. 

7) Every amount recoverable by the Collector or other authority under this section shall be 

recoverable as if it were an arrear of land revenue due by the person liable therefor. 

8) Out of the total amount recovered by the Municipal Commissioner or by a Municipality 

under sub-section (5) or (7) whether before or after coming into operation of this Act, the 

proportionate amount of the municipal recovery cost shall be deducted therefrom and the 

amount not exceeding the compensation amount determined by the Chief presidency 

Magistrate, or the District Magistrate, as the case may be, under sub-section (3) shall be 

paid to him for the payment of compensation to the persons entitled thereto and the 

balance, if any, shall be credited to the municipal fund constituted under the relevant 

Municipal Act, such amount shall be paid to the Chief Presidency Magistrate or the 

District Magistrate, as the case maybe, every three months. 

9) It shall be lawful for the Chief Presidency Magistrate or the District Magistrate, as the 

case maybe, by order to exempt any persons from liability to any portion of the 

compensation amount. 

10) The State Government may, (a) on its own motion, or (b) on an application made by a 

person within a period of thirty days from date of the order of the Chief Presidency 

Magistrate or the District Magistrate, as the case maybe, granting or refusing to grant an 

exemption thereunder, set aside or modify such order. 

Explanation – in this section, the expression, “inhabitants” when used with reference to any 

disturbance area includes persons who themselves or by their agents or servants occupy or 

hold land or other immovable property within such area and landlords who themselves or by 

their agents or servants collect rent from holders or occupiers of land in such area, 

notwithstanding that they do not actually reside therein. 

The Commission is of the opinion that the procedure indicated in the above S.51 of the 

Bombay Police Act, 1951 can be adapted suitably to tackle the existing situation of T & D 

losses in the MSEB serviced areas, and all the consumers are to be held equally responsible. 

The Commission has decided to apportion the cost of this excess loss equally (50% each) to 

the MSEB and the consumers. The cost of the excess losses is the cost of additional power 

purchase required on account of the higher energy input requirement. 

The Commission has considered the average NTPC power purchase rate to determine the unit 

rate of the excess energy input requirement, which works out to Rs. 1.649 per unit, based on 

the Commission’s projections. The net cost of the excess energy input requirement is 



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Rs.1271.8 crore (7715 MU at an average rate of Rs. 1.649 per unit). Thus, the MSEB will 

have to bear 50% of this amount (Rs. 635.9 crore), by way of corresponding reduction in the 

revenue requirement, while the MSEB’s consumers will have to pay the remaining 50% 

through a special charge. 

The Commission has decided to recover this portion of the revenue requirement by showing a 

new charge called ‘T & D loss Charge’, which will be a variable charge and charged from all 

consumers of the MSEB, except for public utilities. This charge will be in addition to the 

Energy Charge and the Demand Charge determined by the Commission. The intention of the 

Commission is to stress upon the consumers that but for this loss, the effective tariffs would 

have been much lower. The Commission hopes that this will provoke the paying consumer to 

rise and act against the pilferage of energy by others. It is no secret that even earlier the 

consumers were paying for the higher losses, through the energy charge and demand charge, 

but if the charge is shown explicitly, it is expected to come more readily to notice and would 

bring about the necessary salutary effect of combating power thefts. It is the Commission’s 

view that there is an urgent need for civil society to bring its relentless social pressure to bear 

upon the power thieves and bring them to heel in the shortest possible time. 

The Commission has thus initiated the process of showing the ‘T & D loss Charge’ for all 

consumers, in proportion to the average realization from that category. It has also to be noted 

that, by its very nature, this is a temporary charge, temporary in the sense that the raison 

d’être of the charge will disappear as soon as the T & D losses of the MSEB reach the loss 

level mandated by the Commission. The Commission intends to create awareness among the 

consumers regarding the additional cost of the losses by showing this charge in an explicit 

manner. Hence, a more or less uniform T & D loss charge has been shown, to start with. 

However, in the next Tariff Order or even sooner, the Commission intends to differentiate 

between the various circles/zones, for charging T & D loss charge, based on the T & D losses 

recorded by the circle/zone in question. The Commission is fully aware that it is not fair that 

a consumer residing in a circle/zone, which has a considerably lower loss level, should pay 

the same T & D loss charge as a consumer residing in a high T & D loss circle/zone. 

The Commission directs the MSEB, under Section 22(2)(e) of the ERC Act, 1998, to 

submit zonal level energy audits for all circles/zones on a monthly basis to the 

Commission, along with the ‘Action Taken Report’ for each circle/zone. The 

Commission intends to charge ‘circle/zone-wise T & D loss Charge’ latest by the 1 st October 

2002 instead of the across-the board T & D loss Charge. The Commission has also not 

applied the T & D loss charge for public utilities like the Railways, Public Water Works, 



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Street Lighting and Mula Pravara Society, as, in the view of the Commission, these do not 

seem to have any incentive to pilfer energy. 

The Commission also directs that the MSEB should hold the concerned employees 

responsible for the excessive T & D losses in the respective zones, and the MSEB should 

consider recovering the T & D loss charge from these employees after following due 

disciplinary procedure. In order to provide a forum for the consumers and to increase 

the awareness regarding the prevailing T & D losses in the division/circle/zone, the 

MSEB should display the monthly energy accounting data detailing the energy input, 

billed sales, and the T & D losses in the division/circle/zone, on the Notice Board of the 

office of the respective division/circle/zone as well as the collection centres in the area. 

The amount of revenue collected through T & D loss charges from the respective 

division/circle/zone and the name and contact details of the officer responsible for the 

division/circle/zone should also be displayed. The above details should also be published 

in the local newspaper, once every month. The MSEB should inform all the public 

representatives in the area regarding the above details. 

29.1.2 Targeted Reduction in Losses in FY 2001-02 

The Commission has considered the MSEB’s viewpoint that the losses have not actually 

increased from 31.9% to 39.4%, but the losses have been better estimated based on improved 

level of energy audit. Though the Commission desired to set a target for further reduction in 

T & D losses by 4% to 5% in FY 2001-02, it has not done so as a special case for this year, 

considering the special circumstances prevailing and the estimation involved in the 

calculation of T & D losses, in the absence of 100% metering. However, the Commission will 

set targets for future years, with the intention of reaching the CEA norms for T & D loss 

levels of 15% to 16% in 2 to 3 year’s time. 

Thus, the total reduction in allowable revenue requirement due to the disallowance of excess 

losses is Rs. 635.9 crore. 

29.2 Revenue Earned through FOCA 

The MSEB has charged FOCA in September 2001 for increase in expenses incurred in July 

2001, based on the FOCA formula issued by the Commission, vide the FOCA Order issued in 

July 2001. The Commission has considered the actual generation and power purchase 

expenses for the period April to September 2001, while determining the revenue requirement 

of the MSEB for FY 2001-02. Hence, the Commission has deducted this amount recovered 

through FOCA for expenses incurred in FY 2001-02, from the revenue requirement of FY 

2001-02, amounting to Rs. 9.5 crore. Additional amount recovered by the MSEB through the 



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FOCA formula for increase in costs in FY 2001-02 after September 2002, if any, will be 

adjusted against the FOCA recoverable henceforth. 

29.3 Other Income 

The Commission has projected the ‘Other Income’ that the MSEB is likely to earn in FY 

2001-02 based on the past trend (CAGR) in these income streams. The projected Other 

Income has been detailed in the Table below: 

Other Income 

(Rs. Crore) 

Source of Other Income 

MSEB MERC 


Delayed Payment Charges 103.9 96.1 

Interest on Delayed Payment 366.7 380.2 

Income from Trading 14.3 14.8 

Income on Bank Deposits 12.2 12.2 

Miscellaneous Receipts 98.6 100.5 

Other Receipts 79.7 80.5 

TOTAL 675.4 684.3 

The ‘Other Receipts’ comprise primarily wheeling charges and other miscellaneous charges. 

The wheeling charges include the income earned from wheeling of NTPC power to ferro 

alloy units, discussed earlier. The total ‘Other Income’ projected by the Commission is Rs. 

684.3 crore. 

29.4 Addition to the Annual Revenue Requirement 

The Commission had issued an Order on December 5, 2001, permitting the MSEB to charge 

FOCA for the period of January to March 2001, amounting to Rs. 127.6 crore, over 3 months, 

starting from December 2001. However, the MSEB has been unable to charge the FOCA as 

the bills for December have already been issued. Hence, to avoid confusion, the Commission 

has included the FOCA amount of Rs. 127.6 crore in the Annual Revenue Requirement of FY 

2001-02, to be recovered through the revised tariffs. However, due to the applicability of the 

revised tariffs for only 3 months of FY 2001-02, the MSEB will be unable to recover the full 

FOCA amount, by this method. The Commission has hence allowed interest at the rate of 

12.5% on the balance amount, and added it to the net additional revenue to be recovered 

through revised tariffs. 



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Thus, the net revenue requirement allowed by the Commission for FY 2001-02 is Rs. 

11644.4 crore. The average cost of supply for FY 2001-02 works out to Rs. 3.15 per unit. The 

revenue from existing tariff works out to Rs. 11192.4 crore. Thus, there is an uncovered 

revenue gap is thus Rs. 452 crore, 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. 452 crore. However, the revised tariffs will be in force for only three months of 

FY 2001-02, as the Commission has always maintained that the tariffs cannot be revised 

retrospectively. Accordingly, the additional revenue recoverable in the remaining three 

months of FY 2001-02 with revised tariffs is thus Rs. 119 crore. 

30 TARIFF DESIGN PRINCIPLES 

The Commission has adopted certain principles, which are in continuation of the process of 

tariff rationalisation initiated in the previous Tariff Order. 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 merging of slabs and categories is bound to result in certain dissonance, with certain 

consumer categories facing a steeper hike, while other categories may have a reduction. For 

instance, the merging of the LT and HT poultry with the respective metered agricultural 

category has resulted in a reduction in the tariffs for the poultry and the High tech agriculture 

consumers, though their tariffs are already lower than the cost of supply. This is wholly 

unintentional, and the Commission has no intention of favoring any selected consumer 

category. 

The Commission had set metering targets for several categories, including power loom, ‘C’ 

Class municipalities, etc., which should have been completed within six months time, and the 

Commission had projected revenue for these categories based on metered tariff in the 

previous Tariff Order. The Commission has maintained the same practice on this occasion 

also, and ahs also set flat rate tariffs to be charged in the interim period. The flat rate tariffs 

have been set such that the consumers have an incentive to opt for metering. 

The Commission has initiated the process of showing the ‘T & D Loss Charge’ separately for 

all consumers, in proportion to the average realisation from that category. The Commission 

intends the consumers to get aware of the additional cost of the losses this charge in an 

explicit manner, and hence a more or less uniform T & D loss charge has been shown, to start 



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with. However, in the next Tariff Order, the Commission intends 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. The Commission is aware that it is unfair that a 

consumer residing in a circle/zone, which has a considerably lower loss level, should pay the 

same T & D loss charge as a consumer residing in a high T & D loss circle/zone. 

The Commission would like to clarify that the T & D loss charge is a part of the tariff, and 

has been considered for the estimation of the MSEB’s revenue. There will not be any 

additional revenue to the MSEB due to the levy of the T & D loss charge, over and above the 

tariff hike allowed by the Commission. 

The Commission intends to levy a ‘circle/zone-wise T & D loss Charge’ latest by 1 st October 

2002 instead of the across-the-board T & D loss charge. The Commission has also not 

applied the T & D loss charge for public utilities like railways, PWW, Street lighting and 

Mula Pravara Society, as they do not have nay incentive to pilfer energy. The MSEB should 

hold the concerned employees responsible for the T& D losses in the respective circles/zones, 

and the MSEB may consider recovering the T & D loss charge from these employees after 

following due disciplinary procedure. 

The Commission has attempted to increase the recovery from fixed charges, which ranged 

around 30% of the fixed costs in the existing tariffs, to around 35% in the revised tariffs. This 

has been achieved by gradually increasing the fixed charges for most consumer categories. 

The energy charges have been adjusted such that the average realization from each consumer 

category is approaching 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, power loom, 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: 



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Table: Movement of Average Realization towards Average Cost of Supply 

Category 

Average 

Cost of 

Supply 

(Rs./unit) 

Average 

Realization 

(Rs./unit) 

Existing 

Tariff 

Revised 

Tariff 

Ratio of Average 

Realization to 

Average Cost of 

Supply (%) 

Existing 

Tariff 

Revised 

Tariff 

Increase/ 

Decrease in 

Tariff with 

reference to the 


Supply 

LT Category 

Domestic (LD-1) 3.15 2.39 2.77 76% 88% 12% 

Non-domestic (LD-2) 3.15 4.64 4.60 147% 146% -1% 

General Motive Power 3.15 4.02 3.58 128% 114% -14% 

Public Water Works 

Urban PWW 3.15 2.45 2.83 78% 90% 12% 

Rural PWW 3.15 0.56 0.99 18% 32% 14% 

Agriculture 3.15 1.07 1.52 34% 48% 14% 

Street Lighting 3.15 2.29 2.97 73% 94% 22% 

Sub Total LT 3.15 2.24 2.52 71% 80% 9% 

HT Category 

HTP-I 3.15 4.33 4.20 138% 134% -4% 

HTP-II 3.15 3.98 3.92 126% 125% -2% 

HTP-III 3.15 4.03 3.18 128% 101% -27% 

HTP-IV 3.15 3.75 3.17 119% 101% -18% 

HTP-V (Railway 3.15 4.20 4.15 133% 132% -2% 

Traction) 

HTP-VI 3.15 2.66 2.82 84% 90% 5% 

HTP-VII (Agriculture) 3.15 0.64 0.96 20% 31% 10% 

Mula Pravara 3.15 1.20 2.02 38% 64% 26% 

Sub Total HT 3.15 4.11 4.03 131% 128% -2% 

The Commission has thus ensured that the tariffs for all subsidized categories (except Rural 

PWW and HT agriculture) are almost 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 Rural 

PWW would appear to be substantial, simply because the existing tariff levels are very low, 

and is in fact the lowest among all categories. Any tariff hike over a small base is bound to 

appear very high. 

The Commission has also attempted to ensure that the flat rate tariffs are higher than the 

metered tariffs, to act as an incentive for opting for metered tariff, even if it results in a 

reduction in the tariffs for metered category, which is already subsidized. The flat rate tariff 



168


for HTP-VII (agriculture) has been kept higher than the flat rate for LT agriculture, to 

account for the higher consumption of the HT agriculture category (3600 hours/HP/year 

against 1250 hours/HP/year for LT agriculture). The Railway Traction tariff has been 

adjusted such that the average realisation is lower than the average realisation for HTP-I 

category. The energy charge to be levied for net sale to the TPC has been reduced to match 

the highest cost of power purchase, i.e. 290 p/u. This has no revenue impact at this stage, as 

the MSEB has not projected any net sale to TPC. 

The Billing Demand definition in case of HT industrial consumers has been modified by 

removing the clause of ‘minimum 50 kVA’. For seasonal consumers, the minimum billing 

demand of 50 kVA will continue to apply, during the off-season. The tariffs for the seasonal 

category have been determined such that these consumers will pay a higher demand charge 

during the specified season, according to the normal billing demand definition, and during the 

off-season, the minimum billing equivalent to 50% of contract demand will not be applicable. 

The Commission has also specified the demand charges applicable for HT consumers having 

captive generation facilities synchronized with the grid. The demand charges have been fixed 

such that these consumers will pay an additional Rs. 20 per kVA of billing demand, in line 

with the existing practice. This is a provisional decision, and is subject to change after the 

Commission’s decision with regard to the ‘Captive Power Policy’ in the State, and the GoM’s 

approval for the same. 

The Commission had stated in the previous Tariff Order dated May 5, 2000, that it intended 

to create a separate category for single-bulb consumers and retain the tariffs for this category 

at a lower level. Due to the unavailability of reliable data on the number of such consumers, 

the Commission has retained the Fixed Charges for the lowest slab (1-30 units per month) in 

domestic category at the same level, while marginally increasing the energy charges, to 

protect this category of consumers. 

It is observed from the consumption pattern as well as the projected consumption, that as 

compared to the total industrial consumption (including LT and HT), the consumption of the 

non-domestic category is only around 10%, which most probably does not indicate the true 

picture. In the previous Tariff Order, the Commission had desired to consider favourably the 

plea of the software industry and such consumers. Keeping in mind the above, the 

Commission has offered optional LTMD based tariff with all its incentives and disincentives 

(ToD, PF incentive, PF penalty, etc.) to the non-domestic category. The Commission feels 

that it will not only improve the metering technology but also bring in buoyancy in the 

revenue collection from this category through improved metering and billing. This will also 



169


help the system by shift of load to the night time off-peak hours by those commercial 

consumers who are operating for 24 hours every day. In future, after considering the results 

of this step, intends to extend this LTMD based tariff to all LT consumers. 

As regards the PWW tariffs, the Commission sees no justification for their tariffs to be 

considerably higher than the average cost of supply, as these are public utilities, and in most 

cases, do not charge the residents commensurately with the costs incurred. The Commission 

has adjusted the HT PWW tariffs such that the average realisation from these categories is 

almost equal to the average cost of supply, which results in a steep reduction in tariffs for 

HT-III and HT-IV category. 

The Commission has also introduced the two-part tariff regime for hitherto single-part tariff 

categories such as Mula Pravara, Street Lighting and Grampanchayat (Rural PWW). The 

Demand Charges in the case of Mula Pravara will be levied on the cumulative Maximum 

Demand at all the 22 points of supply (current average maximum demand is around 144 

MVA). The average realization from Mula Pravara has been adjusted such that it reaches the 

average cost of supply in 5 years’ time. 

The Commission is of the view that the increase in HT VI consumers is beneficial to the 

MSEB as the residential/commercial complex maintains the entire distribution infrastructure 

as well as the billing and collection. The MSEB has to bill only a single consumer and invest 

in the distribution infrastructure only upto the point of main supply to the Complex. With this 

objective in mind, the Commission has designed the tariff for HT VI category such that the 

overall average realization from the category reaches the Cost of Supply, while at the same 

time ensuring that the residential consumers do not have a higher tariff than the domestic 

category. 

The Commission has increased the difference in the ToD rates for peak and off-peak times 

for the HTP-I and HTP-II categories. The Commission has also introduced ToD tariff for 

LTP-G and HTP-III and HTP-IV categories, in line with the direction set by the Commission 

in the previous Tariff Order of May 5, 2000. The ToD tariff for the LTP-G category is 

optional as most of the smaller units such as flour mills and fabrication shops may find it 

difficult to shift their consumption to off-peak time. The ToD tariff will be available for all 

LTP-G consumers irrespective of whether they opt for LTMD tariff or remain under the 

existing system, but subject to the installation of the ToD meter. The revenue impact due to 

introduction of the ToD tariff has not been estimated by the Commission due to the 

unavailability of ToD data for these categories. 



170


Several LTP-G consumers have submitted that several small units are either sick or on the 

verge of closure, due to the lack of market demand for their products and the competition 

from imports. They have added that the MSEB conducts raids on their premises and restates 

their connected load after adding up the rating of all the items like switches and batteries, 

which are stored in their inventory. The LTP-G category has submitted that in this scenario, 

they cannot afford the high demand charges being levied at present. The Commission has 

extended the optional LTMD tariff to all LTP-G consumers, irrespective of the connected 

load, as the levy of demand charges on billing demand is more scientific than the levy on the 

connected load, as all the equipment are unlikely to be used at the same time, which is 

reflected by the low load factor of the category. For consumers who do not opt for LTMD 

tariff, the demand charges will be applicable for 50% of the connected load. The billing 

demand for LTMD consumers has been defined as: 

Billing Demand in any month for LTMD category will be the higher of the following: 

• Actual Maximum Demand recorded in the month during 0600 hours to 2200 hours, 

over the past 11 months. 

• 50 % of the Contract Demand. 

30.1 Energy Conservation 

Recently, the Energy Conservation Bill, 2001 was placed in parliament. One of the objectives 

of the Bill is to enable the conservation of energy through use of more energy efficient 

devices, as energy conserved is equivalent to energy generated, which can be utilized for 

more productive purposes. In Maharashtra too, there is a need for encouraging the use of 

energy efficient devices, not only from the long-term point of view, but also in the short-term, 

considering the extent of load shedding being undertaken in the State. The load shedding 

occurs due to the higher energy requirement as well as the unevenness of the load curve, 

which has morning and evening peaks. 

The Commission has attempted to flatten the load curve, by introduction of the ToD tariffs, 

which has shown good results. At the same time, the Commission is also aware that efficient 

consumption is the need of the hour. Towards this objective, the Commission had preliminary 

discussions with the Energy Management Centre, New Delhi (renamed as Bureau of Energy 

Eficiency, under the Energy Conservation Bill), the Maharashtra Energy Development 

Agency (MEDA), and the Directorate of Technical Education in Maharashtra. 

Initially, the Commission wishes to concentrate on the energy consumption of mainly 

agricultural pumps, Municipal Street lighting systems and PWW systems, as these are the 

areas where there is substantial scope for conservation of energy. 



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30.1.1 Agricultural Pumps 

The Energy Management Centre (EMC) had conducted a study on the energy consumption 

by agricultural pumps through the Operations Research Group (ORG) in 1991, in four States, 

including Maharashtra. The findings of the study have been discussed below: 

♦ 

♦ 

♦ 

♦ 

♦ 

Energy consumption by agricultural pumps is affected by the hydrogeological features of 

the region, efficiency level of pumps, cropping pattern, etc. 

Efficiency of almost 95% of the pumps was below 40%, with 40% of the pumps 

operating at efficiency levels of below 20%. 

The energy consumption reduces substantially with increase in operational efficiency. 

Efficiency of the pump is affected by 

‣ Type of foot valve 

‣ Matching between various components of pumping system 

‣ Quality of the material and size of the components 

‣ Transfer of energy from prime mover to the pump, and 

‣ Leakage of water during suction and delivery, etc. 

Different types of rectification and the estimated reduction in energy consumption are: 

Rectification Description of Work Cost (Rs.) * Reduction potential 

Type 

in 

energy 

consumption over 

current consumption 

R1 Replacement of Foot Valve with 250 10% 

that of efficient design 

R2 R1 + Replacement of GI suction 750 25% 

pipe with RPVC pipe 

R3 R2 + Replacement of GI delivery 1000 30% 

pipe with RPVC pipe 

R4 R3 + Replacement of faulty 15000 50% 

motor and pumps with efficient 

monoblock 

Note: * - at 1991 prices 

The main recommendations of the study were: 

♦ 

♦ 

The scope of the pump rectification work needs to be enlarged to include awareness 

programmes, energy audits and post rectification monitoring. 

There is a need to have better interaction among different government agencies which are 

in contact with farmers, like the SEB, Agricultural Department, State Energy 

Development Agency, etc. 



172


♦ 

♦ 

♦ 

♦ 

The type of rectification measures (R1, R2, R3, etc.) should be decided based on current 

efficiency and energy consumption of the pumps. A combination of R1 and R2/R3 type 

of rectification would be most ideal to enhance the coverage of the programme. 

Since the energy saved through pump rectification benefits the SEB, and looking at the 

investments required for creation of energy generation potential, the SEB should also be 

involved in financing the pump rectification. 

Another possibility of transferring part of the rectification cost to the beneficiary farmers 

having electric pumps is through suitable modification of electricity tariff which is 

oriented towards energy conservation. 

In case of new pumps, there is a strong need for regulating the installation of pumps with 

appropriate quality and proper matching components. This can be controlled during the 

time of sanctioning of loan to the farmers for purchase of pumps. 

The Commission has also discussed the issue with other knowledgeable experts in this field. 

The suggestions for design of the rebate for use of energy efficient devices were: 

♦ 

♦ 

Rebate in energy charges for one year for installation of energy efficient pumps (higher 

efficiency and higher power factor, both) as specified by the Bureau of Energy Efficiency 

(BEE) or the MSEB and having ISI mark. 

Incentives should be offered only on submission of above certification by the Competent 

Authority, i.e. BEE, Chartered Engineer, Chief Electrical Engineer of MSEB, or Energy 

Auditor approved by the BEE/MEDA/IREDA. 

Similar incentives have been proposed by industry experts for municipal PWW and Street 

lighting connections. For street lighting, additional incentives have been suggested for 

installation of solar lamps or sodium vapour lamps or lamps having illumination 75 

lumen/watt and above, and for installation of electronic ballasts. 

The Commission has considered the issue of implementation of these rectification measures 

and the practical problems involved in doing so at the district/taluka level. Towards this, the 

Commission has considered utilization of the services of selected Industrial Training 

Institutes (ITI’s) located all over the State. There are about 500 ITI’s in Maharashtra, and 

their services can be effectively utilized to spread the message of energy conservation. 

The Commission has considered all these suggestions and has decided to introduce an 

incentive scheme for use of energy efficient devices as detailed below: 

The Commission intends to introduce, with effect from 1 st 

April 2002, a scheme for 

incentivising such measures in respect of agricultural pumps, Public Water Works and street 



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lighting by creating a separate fund to be called as ‘Energy Conservation Fund’, within the 

MSEB itself to be financed from 2% of electricity charges, billed to these consumers. The 

scheme will be finalized in consultation with the MEDA, Bureau of Energy Efficiency, New 

Delhi and selected Industrial Training Institutes in Maharashtra. 

30.2 RELIABILITY CHARGE - CONCEPT 

The consumers of any electric utility would always expect to receive uninterrupted, reliable 

and quality (in terms of steady voltage & without frequency fluctuations) power supply from 

the utility in the most efficient and economic manner. However, if the utility is unable to 

supply uniform power quality to all its consumers, or in other words, utility distinguishes, 

whether intentional or otherwise, in terms of “Power Supply Quality” to its 

consumers/category of consumers then, it would only be right for consumers to seek tariff 

linked to quality of power (reliable power) that they receive. The ERC Act 1998 provides for 

setting differential tariffs according to consumer’s load factor, power factor, total 

consumption of energy during specified period, time at which supply is required, 

geographical position of any area, the nature of supply and the purpose for which the supply 

is required. 

The reasons for distinction in the nature of power supply (uninterrupted / reliable) can be 

plenty, such as poor quality of infrastructure, economic considerations, supply/availability 

constraints, regional diversity of load factors, etc. One of the reasons for differentiation in the 

nature of power supply for consumers in Maharashtra is load shedding and its effect on 

system load factor. 

Presently, the urban areas experience load shedding for about 2 hours and rural areas upto 4 

hours. The Commission has explored all the possibilities and considered all the sources of 

power available to reduce the load shedding to the minimum extent possible. The 

Commission has reworked the availability from TPC and central stations submitted by the 

MSEB, so as to minimize the number of hours of load shedding, compared to MSEB’s 

projections, in the months of January to March 2002. The TPC has represented that it has 

surplus power that can be sold to the MSEB, to the extent of about 155 MU in the period 

December to March 2002. The surplus energy available with Tata Power has been taken into 

account while projecting the energy availability and load shedding. 

The Commission also wants MSEB to explore the option of converting Uran gas based power 

plant to multi-fuel generating facility in order to enhance online available generating capacity 

of the grid. The total load shedding for the period of October 2001 to March 2002 as 

estimated by the Commission is 398 MU as against 1885 MU projected by MSEB. The 



174


Commission also directs the MSEB to explore the possibility of additional power purchase 

from other sources to reduce the load shedding. While the Commission has directed MSEB to 

minimize the incidence and duration of load shedding, some amount of load shedding is 

inevitable under the present circumstances. 

The genesis of the problem lies at the concept level itself. The MSEB needs to carry out 

power balancing exercise on long term basis and accordingly plan and provide for the 

spinning reserve. The concept of loss of load probability (LOLP) for ensuring reliable power 

supply needs to be followed by the MSEB for devising its capacity procurement plan. In 

order to provide reliable (uninterrupted) power to all its consumers, MSEB would need to 

have additional online generating capacity on account of following: 

i) Load shedding quantum of around 600 MW. 

ii) Spinning Reserve of upto 10% of Peak Demand - Considering the peak load in the 

range of 9000 MW, the spinning reserve works out to 450 to 900 MW. 

iii) Apart from meeting the requirement of Maharashtra, the MSEB is also required to 

provide back up support in TPC licensee area to the extent of 550 MVA for ensuring 

uninterrupted power supply in the city of Mumbai. Whenever the MSEB is required to 

provide supply, it is done only at the cost of further load shedding in Maharashtra. In 

order to provide standby capacity of 550 MVA to TPC, the standby reserve works out 

to 495 MW (considering 0.9 as power factor). 

Thus, considering the reserve requirement (spinning and standby) of around 500 MW, the 

total additional peaking power requirement in order to provide reliable (uninterrupted) power 

to all consumers of the MSEB would range between 1100 to 1500 MW. This works out a 

standby capacity factor of about 15% of generation capacity. 

In some advanced countries, the power supply capacity is planned on the basis of LOLP of 1 

day in 10 years, that is 2.4 hours per year. The additional capacity that is required for 

uninterrupted power supply depends on the load profile and probability of demand variations 

coupled with forced outages of generating stations. Some of the textbooks have given a figure 

of twenty percent spinning reserve for ensuring the LOLP of 1 day in 10 years. It may be 

noted that in California, expected falling of spinning reserve to 7 percent triggers a public 

alert for voluntary conservation. Further, if the reserve forecast drop to below 5 percent, 

power is cut off to selected “interruptible” consumers. And finally, when the reserve drops 

below 1.5 percent, utilities begin rolling black outs. 



175


In this context, it is worthwhile to note the experience of other Indian States and the approach 

adopted by the Orissa Electricity Regulatory Commission (OERC). The OERC has 

formulated a document “Power Supply Planning and Security Standards” aimed at a least 

cost planning to serve the demand at a specified level of reliability. Under the same, the 

OERC has extensively dealt with planning criteria and modalities for power supply planning 

and security standards for power supply. The OERC has suggested the generation reserve to 

the extent of 5% of the system peak load. The salient features of the Power Supply Security 

Standards as adopted by OERC are as follows: 

POWER SUPPLY SECURITY STANDARDS 

To ensure that the generation reserve is sufficient so that the system can meet the load, even 

if one or more units are out of service for scheduled maintenance or in the event of nonavailability 

of adequate hydro-electric generation capacity during the dry period, adequate 

reserve capacity shall be built into the system both for capacity and energy. 

‣ Capacity Reserve 

Loss of Load Probability (LOLP) i.e. of 2% shall be used for planning models. This shall 

mean that for 2% of the year (i.e., upto 7.3 days/year) the power system may experience 

shortages of generating capacity. 

‣ A contingency reserve margin equal to 5% of the system peak load shall be planned to 

take care of fluctuations in the availability of Hydro Electric generation during the 

critical period of February to June of a dry- year, and to account for outages of units, 

power station equipment, non-availability of Central Sector share in order to maintain 

security and integrity of the system. 

‣ Energy Reserve 

“Energy Not Served’’ shall be limited to 0.15% of the average annual energy. 

While there is wide range of LOLP standards being followed by the industry, ranging from 1 

day in 10 years in the USA to 7.3 days in a year to as Orissa standard, there is a case for the 

MSEB consumers to enjoy at least the standards of rare interruptions set for consumers of the 

Mumbai region, which are served by the BSES, BEST and TPC. 

Thus, there is an urgent need to formulate standards for reliability of power supply and plan 

for generating capacity / reserve provisions to improve online generating capacity available at 

MSEB grid at any point of time; to enable it serve reliable and quality power to all its 

consumers. Here, improvement in generation capacity as well as the last mile connectivity is 

essential. However, the fact remains that until such condition is reached, the distinction can 

be made in the nature of supply to various consumers at least in terms of uninterrupted supply 

or otherwise. 



176


30.2.1 RELIABILITY CHARGE – APPLICATION 

In response to the oft-repeated demand for supply of reliable, uninterrupted power to MSEB 

consumers, similar to the situation prevailing in Greater Mumbai in the license areas of the 

TPC, BEST and the BSES, the Commission has initiated the process of levying a ‘Reliability 

Charge’, as a component of tariff, 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 intent of introduction of such charge as a component of tariff is to collect revenue from 

the consumers, who do receive uninterrupted (reliable) power supply. The collection of this 

charge would enable the MSEB to tie up with additional generation sources to enhance the 

online availability of generating capacity and consequently improve the quality of grid power 

supplied to all its consumers. Hence, it is expected that the MSEB would utilise the revenue 

proceeds towards improving quality and reliability of power supply to all its consumers and 

take up adequate measures required for the same; including tie up of additional generation 

sources. 

The cost of the standby capacity has been estimated based on the average cost of supply and 

the proportion of fixed costs to the total costs. This work out to an effective rate of around 25 

paise per unit. The scheme will be operational with effect from 1 st April 2002. The MSEB 

should submit to the Commission details of consumers belonging to the above categories, to 

whom the MSEB can supply uninterrupted power based on the additional power available 

without in any way changing the load-shedding programme for other classes of consumers. 

The MSEB will impose an additional charge of 25 paise per kWh, as a component of tariff to 

these consumers and ensure that they get uninterrupted power supply. In any billing cycle, if 

there is any interruption in power supply from the MSEB system to these consumers, this 

Reliability Charge shall not be levied. For the purpose of determination of uninterrupted 

power supply for the billing cycle, the planned interruptions (such as days covering staggered 

load programme of the MSEB for industrial consumers) shall be excluded. The revenue 

which would be realised from the levy of this Reliability Charge has not been included in the 

revenue projections, at the same time, the expenditure that the MSEB is likely to incur for the 

supply of reliable power has also not been included. 

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. 



177


The revised tariff applicable for all categories of consumers from January 1 st , 2001 has been 

shown below. The comparison of existing tariff, tariff proposed by the MSEB and the tariff 

issued by the Commission has been presented in the next table, followed by the revenue 

calculations. The comparison of the monthly bills with the existing tariff and revised tariff for 

sample consumption levels has been presented at the end. 



178


Summary of LT Tariff (Effective from January 1 st 2002) 


Domestic (LD 1) 

Demand Charge 

(Rs/KVA/month) or 

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

connection per month) 

Energy 

Charge 

(p/u) 

T & D loss 

Charge 

(p/u) 

0-30 Units Rs. 20 per service connection 100 10 



295 



455 

three phase; 

(only balance 

Additional Fixed charge of Rs. 75 

Units) 

per 10 KW load or part thereof 


payable. 

Non Domestic (LD2) 



410 



500 

three phase; 

(only balance 

Additional Fixed Charge of Rs. 

Units) 

125 per 10 KW load or part thereof 


payable. 

Optional LTMD based Tariff will 

be available for all consumers. 

General Motive Power (LTP-G) – Base Tariff 

0-1000 Units Rs. 60 per HP (Rs. 80.50 per kW) 240 

1001-15000 Units per month for 50% of sanctioned 300 

load; 

15001- above Units 

340 

Optional MD based tariff will be 

(only balance 

available for all consumers, 

Units) 

irrespective of Contract demand, at 

Rs. 220 /KVA/ month 

Optional ToD Tariff $ 

2200 hrs – 0600 hrs 0 -50 

0600 hrs – 0900 hrs 0 

0900 hrs – 1200 hrs 30 

1200 hrs – 1800 hrs 0 

1800 hrs – 2200 hrs 

60 

Powerloom 

Rate* 

Flat 

Rs. 450 per loom per month 0 

20 

30 

25 



179


Public Water Supply 

Urban P. W. Rs. 60 per HP per month 225 0 

Schemes 

Rural P. W. 

Schemes 

Grampanchayat $ Rs. 20 per HP per month 75 

Metered Tariff Rs. 30 per HP per month 140 

(incl. ‘C’ Class 

Municipal 

Council) $ 

Agriculture 

Flat Rate Tariff Rs. 110 per HP per month 0 Rs. 10 per 

HP per 

month 

Metered Tariff Rs. 10 per HP per month 90 10 

(incl. Poultry 

Farms) 

Street Light Tariff 

Grampanchayat & 

Municipal Council 

Municipal 

Corporation 

Rs. 20 per kW per month 

0 

170 0 

Notes: 

* : Flat rate tariff (Rs. per loom per month) for power loom category will be applicable 

during the intervening period till the meters are installed (based on 8 hours working). 

250 

Thereafter, they will be billed at the rates applicable for LTP-G category. 

$ : Optional ToD tariff will be available for all LTP-G consumers, irrespective of 

whether they opt for LTMD based tariff, but provided they have installed ToD meters. 

• Flat rate tariff of Rs. 100 per HP per month will be applicable for Grampanchayats 

and ‘C’ Class Municipal Councils, in the interim period till meters are installed. 





180


Summary of HT Tariff Effective from January 1 st 2002 


Demand Charge 

(Rs/KVA/month) 

Energy 

Charge 

(p/u) 

T & D loss 

Charge (p/u) 

HTP – I (Industrial - 

325 285 30 

BMR/PMR) Base Tariff 

HTP – II (Industrial – 

300 280 30 

Others) Base Tariff 

ToD Tariff (for HTP-I & HTP- 

II) 

2200 hrs – 0600 hrs 0 

-75 

0600 hrs – 0900 hrs 0 

0900 hrs – 1200 hrs 50 

1200 hrs – 1800 hrs 0 

1800 hrs – 2200 hrs 

Seasonal Category 350 $ 270 30 

HTP – III (PWW- 

300 265 0 

BMR/PMR) 

HTP – IV (PWW-Others) 250 255 0 

ToD Tariff (for HTP-III & 

HTP-IV) 

2200 hrs – 0600 hrs 0 

-50 

0600 hrs – 0900 hrs 0 

0900 hrs – 1200 hrs 30 

1200 hrs – 1800 hrs 0 

1800 hrs – 2200 hrs 

HTP - V (Railway Traction) 0 415 0 

HTP – VI 

Residential Complex 100 220 20 

Commercial Complex 

HTP VII (Agriculture) 

90 

60 

350 30 

Flat Rate Tariff 

200 0 Rs. 10 per 

(Rs/HP/month)** 

HP per 

month 

Metered Tariff (incl. Poultry, 

10 90 15 

agriculture High tech) 

Tata Power Company 600 $$ 290 0 

Mula Pravara Electric Co-op 

200 150 0 

Society 

Inter State Sale 0 260 



181


Notes: 

**: Flat rate tariff shall be applicable till the time meters are installed. 

$ : Demand Charges will be applicable as per normal billing demand formula only 

during declared season; for off-season, the clause of minimum 50% of contract 

demand will not be applicable 

$$ : Standby Demand Charges 

• HT Industrial consumers having captive generation facilities synchronized with the 

grid, will pay additional demand charges of Rs. 20 per kVA per month 



31 REVENUE PROJECTIONS 

The MSEB will earn revenue for 9 months with exiting tariff, while the revised tariffs will be 

applicable for 3 months. The total revenue from sale of electricity has been detailed below: 

Sr. Revenue from Sale of Electricity FY 2001-02 (Rs. 

Crore) 

1 Existing Tariffs for 9 months 8394 

2 Revised Tariffs for 3 months 2918 

Total 11312 

The detailed revenue calculations with the existing and revised tariff have been given below: 

32 TARIFF HIKE FOR FY 2001-02 

Description MSEB Proposal MERC Approval 

Tariff Increase in Rs. Crore * 1456 452 

Overall Tariff Increase in % * 11% 4% 

* - if revised tariffs were applicable for the entire year 

The overall tariff hike approved by the Commission amounts to 4%, over the revenue billed 

with the existing tariff. The consumers should appreciate that though the overall rate is 4%, 

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, power loom and LT PWW, the 

tariff hike will be higher than 4%. At the same time, there will be a reduction in effective 



182


tariff for subsidizing categories such as industrial (HT and LT), commercial, HT PWW and 

Railways. 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 categorywise 

average realization towards the average cost of supply has been shown in the table in 

Section 28. To enable the consumers to assess the impact of the revised tariffs on their 

monthly bills, the Commission has presented the table below, which shows the change in the 

monthly bills for sample levels of consumption for each category. 

Category 

Monthly 

Consumption 

(Units) 

Change in Monthly Bills 

Connected Load 

(HP) / Billing 

demand (kVA) 

Monthly Bill (Rs.) 

Existing Tariff Revised Tariff 

Domestic (single bulb) 15 31.3 36.5 

70 142.5 173 

200 517.5 570.5 

500 1737.5 1835.5 

Commercial 100 300 350 

250 1060 1055 

500 2560 2380 

LTP-G 1000 50 5590 4150 

5000 50 18390 17150 

20000 100 71390 69400 

Power loom (Flat Rate) 15 4500 6750 

Urban PWW 10000 50 22000 25500 

PWW – Gram 2000 10 880 1700 

Panchayat 

LT Agri. (Un-metered) 7.5 690 900 

LT Agri. (metered) 275 7.5 377.5 350 

Street Lighting (Gram 20000 50 32000 35000 

Panchayat) 

Street Lighting (B & C 20000 50 44000 35000 

Class MC) 

Street Lighting 20000 50 60000 51000 

(Municipal 

Corporation) 

HTP-I 125000 500 Rs. 5.65 lakh Rs. 5.52 lakh 

HTP-II 125000 500 Rs. 5.43 lakh Rs. 5.33 lakh 

HTP-III 125000 500 Rs. 5.88 lakh Rs. 4.81 lakh 

HTP-IV 75000 250 Rs. 2.95 lakh Rs. 2.54 lakh 

Railways 1000000 Rs. 42.00 lakh Rs. 41.51 

lakh 

HTP-VI (Residential) 50000 250 Rs. 1.45 lakh Rs. 1.45 lakh 

HT Agri. (Un-metered) 250 29250 52500 

HT Agri. (metered) 15000 150 21000 17250 

Mula Pravara 60000000 145 Rs. 7.20 crore Rs. 9.00 crore 



183


33 INCENTIVES AND DISINCENTIVES 

33.1 Incentives 

33.1.1 Power Factor Incentive for HT consumers 

Whenever the average power factor is more than 0.95, an incentive shall be given at the rate 


FOCA charge, demand charge, electricity duty) 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. 

33.1.2 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 T & D loss charge, FOCA charge, demand charge, electricity 

duty) for every one million unit consumption above one million unit subject to a maximum of 

5%. For instance, a consumer having a monthly consumption of 2 million units will get a 

rebate of 2%. 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. 

33.2 Disincentives 

33.2.1 Power factor Penalty for HT Consumers 

Whenever the average power factor is less than 90%, penal charges shall be levied at the rate 


FOCA charge, demand charge, electricity duty) for each 1% (one percent) fall in the power 

factor below 90%. 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. 

33.3 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. 



184


33.3.1 Meter Rent 

The meter rent has been abolished by the Commission in the previous Tariff Order. The cost 

of the metering equipment shall be recovered from all the prospective consumers (except 

those agricultural consumers having land holding less than 1 hectare, in which case, only 

50% of the cost of meter shall be recovered). In case of existing consumers, the cost of 

metering equipment shall be recovered at the time when the existing meter is replaced, but 

only once in the lifetime of the consumer, except in the case of burnt meters. The recovery of 

cost of meters from existing consumers will be made in the next billing cycle after replacing 

the defective meters. The MSEB should file the rates of meter cost being recovered, for the 

information of the Commission. 

33.3.2 Security Deposit 

The Commission has reduced the amount of security deposit to be recovered by the MSEB to 

an equivalent of average of three months of billing or a billing cycle period, whichever is 

lesser, from the existing levels of billing cycle plus 1 month equivalent of security deposit. 

Thus, the security deposit for HT industrial consumers will be an equivalent of one month’s 

average billing, two months’ average billing for urban domestic consumers, three months’ 

average billing for LT agricultural category, and so on. 

33.3.3 Service Line Charges 

The MSEB should continue to charge Service Line Charges (SLC) as per the guidelines 

prevailing as on 5 th August 1999, i. e. the date the Commission came into existence, till such 

time as the SLC are modified by the Commission. 

33.3.4 Interest on Delayed Payment of Arrears 

The MSEB has repeatedly complained that the defaulting consumers have been using the due 

amount for their working capital purposes, due to the low rates of penal interest prescribed by 

the Commission. Normally, the MSEB is expected to disconnect the consumers for nonpayment 

within a certain period as per the provisions of the relevant Act. The interest on 

arrears is currently chargeable at the rate of 12% per annum. The Commission has, as shown 

in the Table below, revised the rate of interest chargeable on arrears to all consumers to 15%, 

if payment is delayed beyond 3 months from the due date, and to 18%, if payment is delayed 

beyond 6 months. The revised interest rates will be applicable from April 1, 2002. The 

revised interest rates will not be applicable in case of existing agreement or agreements 

entered into before March 31, 2002, for payment of arrears in instalments. 



185


The revised interest rates chargeable are: 

Sl Delay in Payment (span of months) Interest rate p.a. (%) 

1 Payment made after due date upto three months (0 – 3) 12% 

2 Payment made after three months and before six months 

15% 

(3 – 6) 

3 Payment made after six months (above 6) 18% 



186

EXHIBIT 1: GENERATION AND POWER PURCHASE QUANTITY IN MU (APPROVED BY THE COMMISSION) 

Exhibit 1 

Plantwise Generation and Power Purchase in Mus (as approved by the Commission) 

Months Hydro Tarapur Kakrapar Uran Gandhar Korba ChandrapuVindhyachaBhusawal Kaparkhed Koradi Parli Paras Nasik Kawas 

April-Sept 01(Actuals) 1743 529 938 1841 503 2592 7282 2303 1658 2600 2895 1994 191 2903 586 

Oct-02 234 107 165 305 80 447 1512 517 311 513 502 392 29 360 34 

Nov-02 312 104 160 296 77 433 1463 501 132 514 526 433 33 409 92 

Dec-02 450 107 165 305 80 447 1512 517 293 531 426 433 33 413 84 

Jan-02 323 107 165 305 80 447 1512 517 311 515 482 415 32 409 81 

Feb-02 306 97 149 276 72 404 1366 467 281 480 508 385 29 323 83 

Mar-02 375 107 165 305 80 447 1512 517 311 531 609 316 17 352 104 

Total 3742 1158 1907 3635 971 5216 16160 5341 3298 5684 5948 4367 364 5168 1064 

Aux.Con (%) 0.58% 2.40% 7.60% 10.0% 8.50% 9.80% 9.70% 9.70% 9% 

Net MUs 3720 1158 1907 3547 971 5216 14932 5341 2968 5201 5365 3944 328 4703 1064 

Net MUs 2.65% 5% 5% 5% 5% 5% 

Net Mus Available 3720 1128 1811 3547 922 4956 14932 5074 2968 5201 5365 3944 328 4703 1011 

Page 187

Sample Sheet for Merit Order Despatch Simulation (For the month of January 2002) 

Representative Load Curve for Jan 

Must Run Stations 

EXHIBIT 2: SAMPLE MERIT ORDER DESPATCH SIMULATION (FOR THE MONTH OF JANUARY 2002) 

1 2 3 4 5 6 7 8 9 10 

MOD 

reqd 

Exhibit 2 

Jan-01 Jan-02 Hydro Tarapur Kakrapar Uran Gandhar KorbaChandrapurVindhyachal BhusawalKaparkheda Koradi Parli Paras Nasik Kawas 

Total 

HOURS RSD URSD No LS 

1 6522 6522 6522 6692 53 144 222 411 107 601 2033 695 418 657 483 421 32 416 0 2188 6692 0 

2 6438 6438 6438 6605 51 144 222 411 107 601 2033 695 418 571 483 421 32 416 0 2103 6605 0 

3 6387 6387 6387 6553 50 144 222 411 107 601 2033 695 418 521 483 421 32 416 0 2053 6553 0 

4 6458 6458 6458 6626 50 144 222 411 107 601 2033 695 418 593 483 421 32 416 0 2125 6626 0 

5 6559 6635 6614 6786 50 144 222 411 107 601 2033 695 418 714 522 421 32 416 0 2285 6786 0 

6 6959 7221 7148 7334 63 144 222 411 107 601 2033 695 418 714 690 601 46 589 0 2819 7334 0 

7 7588 7987 7875 8080 679 144 222 411 107 601 2033 695 418 714 690 601 46 594 125 2950 8080 0 

8 8069 8502 8380 8598 1000 144 222 411 107 601 2033 695 418 714 690 601 46 594 188 3147 8464 134 

9 8187 8678 8541 8763 1000 144 222 411 107 601 2033 695 418 714 690 601 46 594 188 3312 8464 299 

10 7933 8435 8294 8510 1000 144 222 411 107 601 2033 695 418 714 690 601 46 594 188 3059 8464 46 

11 7733 8121 8012 8220 820 144 222 411 107 601 2033 695 418 714 690 601 46 594 124 2949 8220 0 

12 7459 7805 7708 7908 506 144 222 411 107 601 2033 695 418 714 690 601 46 594 127 2952 7908 0 

13 7324 7641 7552 7749 345 144 222 411 107 601 2033 695 418 714 690 601 46 594 128 2953 7749 0 

14 7151 7459 7373 7565 159 144 222 411 107 601 2033 695 418 714 690 601 46 594 130 2955 7565 0 

15 7084 7398 7310 7500 95 144 222 411 107 601 2033 695 418 714 690 601 46 594 129 2954 7500 0 

16 7161 7487 7396 7588 183 144 222 411 107 601 2033 695 418 714 690 601 46 594 130 2955 7588 0 

17 7420 7792 7688 7888 485 144 222 411 107 601 2033 695 418 714 690 601 46 594 127 2952 7888 0 

18 7667 8171 8030 8238 839 144 222 411 107 601 2033 695 418 714 690 601 46 594 124 2949 8238 0 

19 8154 8837 8646 8871 1000 144 222 411 107 601 2033 695 418 714 690 601 46 594 188 3420 8464 406 

20 8360 9019 8834 9064 1000 144 222 411 107 601 2033 695 418 714 690 601 46 594 188 3613 8464 600 

21 8061 8613 8459 8678 596 144 222 411 107 601 2033 695 418 714 690 601 46 594 188 3631 8061 618 

22 7713 8169 8041 8250 233 144 222 411 107 601 2033 695 418 714 690 601 46 594 188 3567 7697 553 

23 7235 7392 7348 7539 97 144 222 411 107 601 2033 695 418 714 690 601 46 594 165 2991 7539 0 

24 6831 6831 6831 7009 60 144 222 411 107 601 2033 695 418 714 690 466 32 416 0 2497 7009 0 

176454 183999 186616 10413 3456 5321 9854 2572 14417 48780 16692 10040 16623 15561 13390 1028 13188 2625 69379 183960 2656 

MU 5703 82 

After Additional Power Purchase from TPC MU 5722 63 

max MW 1000 144 222 411 107 601 2033 695 418 714 690 601 46 594 188 

min MW 50 144 222 411 107 0 1423 0 293 500 483 421 32 416 0 

Balance 0 0 0 0 601 610 695 125 214 207 180 14 178 188 

LS 

reqd 

Page 188

EXHIBIT 3: COMPARISION OF TARIFFS (EXISTING, PROPOSED BY MSEB, AND REVISED) 

Sl 

Existing Consumer Categories 

Demand 

Charges 

(Rs/HP per 

month) 

Energy 

Charges 

(p/u) Sl MSEB Proposed Categories 

Demand 

Charges 

(Rs/HP/kVA 

per month) 

Energy 

Charges 

(p/u) Sl Commission's Approval 

Demand 

Charges 

(Rs/HP/kVA 

per month) 

Energy 

Charges 

(p/u) 

T & D loss 

charge (p/u) 

1 Domestic (LD 1) 1 Domestic (LD 1) 1 Domestic (LD 1) 

0-30 Units 20 75 0-30 units 75 75 0-30 units 20 100 10 

31-100 Units 20 250 Consumption above 30 units 75 300 31-100 units 30 255 20 

101-300 Units 20 300 101-300 units 30 295 20 

Consumption above 300 units 20 460 > 300 units 30 455 20 

2 Non Domestic (LD 2) 2 Non Domestic (LD 2) 100 300 2 Non Domestic (LD 2) 

0-100 Units 50 250 0-100 Units 70 250 30 

101-200 Units 50 460 101 to 200 Units 70 410 30 

201- above Units (only balance Units) 50 600 > 200 units 70 500 30 

3 General Motive Power (LTP-G) 3 General Motive Power (LTP-G) 75 200 3 General Motive Power (LTP-G) 

0-300 Units 60 210 (Rs.100/kW/mth) 0-1000 Units 60 240 25 

301-1000 Units 60 280 1001-15000 Units 60 300 25 

1001-15000 Units 60 320 >15000 Units 60 340 25 

15001- above Units (only balance Units 60 360 

(Power loom included in LTP - G) 

Optional ToD Tariff 

Power loom unmetered 393 Power loom Unmetered 634 2200 hrs - 0600 hrs -50 

(Rs.850/kW/mth) 0600 hrs - 0900 hrs 0 

0900 hrs - 1200 hrs 30 

1200 hrs - 1800 hrs 0 

1800 hrs - 2200 hrs 60 

(Power loom included in LTP - G) 

Power loom (Unmetered) 450 

4 Public Water Supply 4 Public Water Supply 4 Public Water Supply 

Urban P. W Schemes Urban P. W Schemes 75 200 Urban P. W Schemes 60 225 0 

For Connected Load 0 - 67 HP 40 200 (Rs.100/kW/mth) 

For Connected Load > 67 HP 40 300 

Rural P. W Schemes Rural P. W Schemes Rural P. W Schemes 

Flat Rate Tariff (Rs/HP/month) 


Grampanchayat 88 0 Grampanchayat 336 Grampanchayat 20 75 0 

'C' class Municipal Councils 20 100 'C' class Municipal Councils - metered 37.3 100 'C' class Municipal Councils & Metered 30 140 0 

Metered Tariff 20 100 (Rs. 50/kW/month) 

5 Agriculture 5 Agriculture 5 Agriculture (incl Poultry) 

Flat Rate Tariff (Rs/HP/month) Flat Rate Tariff (Rs/HP/month) 224 Flat Rate Tariff (Rs/HP/month) 

For Load upto 5 HP 75 0 (Rs. 300/kW/mth) For Load upto 5 HP 110 0 10 

For Load more than 5 HP upto 7.5 HP 92 0 For Load more than 5 HP upto 10 HP 110 0 10 

For Load more than 7.5 HP upto 10 HP 117 0 

Metered Tariff 10 110 Metered Tariff (incl Poultry) 56 135 Metered Tariff 10 90 10 

(Rs. 75/kW/mth)

6 Street Light 6 Street Light Tariff 0 350 6 Street Light Tariff 

Grampanchayat & C Class Municipal Co 0 160 Grampanchayat, A, B, C Class MC 20 170 0 

"A" & "B" Class Municipal Council 0 220 Municipal Corporation 20 250 0 

Municipal Corporation Areas 0 300 

7 Poultry Farms 40 160 

8 HTP - I 300 335 7 HT - I 325 300 7 HTP - I 325 285 30 

2200 hrs - 0600 hrs -50 2200 hrs - 0600 hrs -75 2200 hrs - 0600 hrs -75 

0600 hrs - 0900 hrs 0 0600 hrs - 0900 hrs 0 0600 hrs - 0900 hrs 0 




9 HTP - II 280 325 8 HTP - II 300 280 30 

Seasonal Consumers 

10 HTP - III 300 350 9 HTP - III 300 265 0 

11 HTP - IV 220 320 10 HTP - IV 250 255 0 

Optional ToD Tariff (HTP -III & IV) 

2200 hrs - 0600 hrs -50 

0600 hrs - 0900 hrs 0 

0900 hrs - 1200 hrs 30 

1200 hrs - 1800 hrs 0 

1800 hrs - 2200 hrs 60 

12 HTP - V (Railway Traction) 0 420 8 HT - II (Railway Traction) 0 420 11 HTP - V (Railway Traction) 0 415.137412 0 

13 HTP - VI 12 HTP - VI 

Residential Complex 180 200 Residential Complex 100 220 20 

Commercial Complex 180 300 Commercial Complex 100 350 30 

14 HTP VII (Agriculture) 9 HT - III (Agriculture & Related) 13 HTP VII (Agriculture & Related) 

Flat Rate Tariff (Rs/HP/month) 117 0 Flat Rate Tariff (Rs/HP/month) 522 Flat Rate Tariff (Rs/HP/month) 200 0 10 

Metered Tariff 20 120 Metered Tariff 75 135 Metered Tariff 10 90 15 

15 HTP VIII Poultry Layers & Broilers 180 120 

16 HTP IX (TEC) 600 330 14 HTP IX (TEC) 600 290 0 

17 SP-I & II Agri (HT/LT) HighTech 180 200 

18 Mula Pravara Electric Co-op Soc. 0 120 10 Mula Pravara Electric Co-op Soc. 0 340 15 Mula Pravara Electric Co-op Soc. 200 150 0 

19 Inter State Sale 0 260 11 Inter State Sale 12 Inter State Sale 0 260 0

EXHIBIT 4: REVENUE FROM EXISTING TARIFF - APRIL TO DECEMBER 2001 

Revenue from Tariff - April to December 2001 

9 months Existing Tariff 

Annual 

Number of Consumpti 

Consumers on MU 

Contract 

demand 

kW / 

kVA/HP 

Monthly 

Demand 

Charge 

(Rs/KW)/ 

(Rs/KVA) / 

(Rs / HP) 

Energy 

Charge 

Ps/U 

Revenue 

from Revenue 

demand from energy 

charge Rs charge Rs 

Cr Cr 

Total 

Revenue 

Rs Cr 

Average 

Realisatio 

n 

(Rs/unit) 

Average 

Cost of 

Supply 

(Rs/unit) 

Ratio of 

avg 

realisatio 

n to avg 

cost of 

supply 

(%) 

Consumer Category & Slab-wise 

Sl 

Consumption 

1 2 3 4 5 6 7 8 9 10 11 12 13 

LT Category 

1 Domestic (LD 1) 

0-30 Units 2682050 3152 0 20 75 48.3 177.3 225.6 

31-100 Units 5258436 2784 0 20 250 94.7 522.0 616.7 

101-300 Units 1294094 1144 0 20 300 23.3 257.3 280.6 

Consumption above 300 units 141128 847 0 20 460 2.5 292.1 294.7 

Addnl Fixed Charge for 3 phase consumers 

CL < 10 kW 81190 30 2.2 2.2 

CL > 10 kW 24269 790920 50 3.6 3.6 

Sub Total Domestic 9375708 7926 0 0 174.5 1248.8 1423.3 2.39 3.15 76.08% 

2 Non Domestic (LD 2) 

0-100 Units 614161 711 0 50 250 27.6 133.3 160.9 

101-200 units 158598 207 0 50 460 7.1 71.5 78.6 

Consumption above 200 units 104890 676 0 50 600 4.7 304.4 309.1 


CL < 10 kW 46598 50 2.1 2.1 

CL > 10 kW 14328 480625 100 4.3 4.3 

Sub Total Non-Domestic 877649 1594 0 0 0 45.9 509.1 555.0 4.64 3.15 147.49% 

3 General Motive Power (LTP-G) 

0-300 Units 152281 555 0 60 210 87.5 87.5 

301-1000 Units 74141 581 0 60 280 121.9 121.9 

1001-15000 Units 33051 980 0 60 320 235.1 235.1 

Above 15000 Units 4028 364 0 60 360 98.3 98.3 

Sub Total General Motive Power 263501 2480 3781635 60 204.2 542.8 747.0 4.02 3.15 127.63% 

4 Power Loom 

Flat Rate Tariff - considered as metered 27440 838 439920 60 210 23.8 132.0 155.7 2.48 3.15 78.74% 

393 

5 Public Water Supply 

(a) Urban P. W Schemes 

For Connected Load 0 - 67 HP 3180 22.01 17963 40 200 0.6 3.3 3.9 

For Connected Load > 67 HP 8 1.49 1071 40 300 0.0 0.3 0.4 

Sub total 3188 23.50 19035 0.7 3.6 4.3 2.45 3.15 77.91% 

(b) 

Rural P. W Schemes 


Grampanchayat 32380 447 179759 88 0 14.2 0.0 14.2 0.42 

'C' class Municipal Councils 563 13 4155 20 100 0.1 1.0 1.0 

Metered Tariff 10043 94 58311 20 100 1.0 7.1 8.1 

Sub Total 42986 554 242225 15.4 8.0 23.4 0.56 

Sub total PWW 46174 577 261260 16.0 11.7 27.7 0.64 3.15 20.33%

6 Agriculture 


For Connected Load upto 5 HP 1573062 6461 5751678 75 0 388.2 0.0 388.2 

For Load more than 5 HP upto 10 HP 160181 658 1350927 92 0 111.9 0.0 111.9 

For Connected Load > 10 HP 24877 102 641363 117 0 67.5 0.0 67.5 

Sub total unmetered 1758119 7221 7743968 567.6 0.0 567.6 1.05 

Metered Tariff 429838 300 1199464 10 110 10.8 24.8 35.6 1.58 

Sub Total Agriculture 2187957 7521 8943432 578.4 24.8 603.2 1.07 3.15 33.98% 

7 Street Light 

Grampanchayat & C Class Municipal Council 6448 161 0 0 160 0.0 19.3 19.3 

"A" & "B" Class Municipal Council 3435 117 0 0 220 0.0 19.4 19.4 

Municipal Corporation Areas 51184 171 0 0 300 0.0 38.5 38.5 

Sub Total Street Light 61067 450 452 0.0 77.2 77.2 2.29 3.15 72.74% 

8 Poultry Farms 6285 32 36863 40 160 1.3 3.8 5.2 2.15 3.15 68.41% 

Total Low Tension 12845781 21419 13463562 1044.2 2550.1 3594.3 2.24 3.15 71.10% 

HT Category 

1 HTP - I 3071 6425 2432719 300 335 497.2 1588.9 2086.1 4.33 3.15 137.56% 

2200 hrs - 0600 hrs 0 3968 0 0 -50 0.0 -148.8 -148.8 

0600 hrs - 0900 hrs 0 2323 0 0 0 0.0 0.0 0.0 

0900 hrs - 1200 hrs 0 1610 0 0 30 0.0 36.2 36.2 

1200 hrs - 1800 hrs 0 2323 0 0 0 0.0 0.0 0.0 

1800 hrs - 2200 hrs 0 1937 0 0 60 0.0 87.2 87.2 

2 HTP - II 4911 5736.00 2061079 280 325 396.3 1316.3 1712.6 4.01 3.15 127.47% 

Power Factor Incentive -66.9 

Power Factor Penalty 8.7 

Bulk Discount -14.4 

Seasonal category 239 44 37423 6.0 9.3 15.3 4.66 

2(a) Captive Consumers 229445 ditional 20 4.1 4.1 

3 HTP - III 115 599 100395 300 350 23.9 157.2 181.0 4.03 3.15 128.10% 

4 HTP - IV 417 330 94368 220 320 13.6 79.2 92.8 3.75 3.15 119.13% 

5 HTP - V (Railway Traction) 51 817 362 0 420 0.0 257.4 257.4 4.20 3.15 133.46% 

6 HTP - VI 

Residential Complex 245 243 62000 180 200 10.0 36.5 46.5 2.55 

Commercial Complex 39 18 9000 180 300 1.5 4.1 5.5 4.08 

Sub Total HTP VI 284 261 71000 11.5 40.5 52.0 2.66 3.15 84.41% 

7 HTP VII (Agriculture) 

Flat Rate Tariff (Rs/HP/month) 827 587 218633 117 0 23.0 0.0 23.0 0.52 

Metered Tariff 319 96 57909 20 120 1.0 8.6 9.7 1.34 

Sub Total HTP VII 1146 683 276542 24.1 8.6 32.7 0.64 3.15 20.28%

8 HTP VIII Poultry Layers & Broilers 39 11 4000 180 120 0.6 1.0 1.6 1.99 3.15 63.09% 

9 HTP IX (TEC) 1 0 550000 600 330 297.0 0.0 297.0 

11 SP-I Agri (HT/LT) HighTech 39 23 7734 180 200 1.2 3.5 4.6 2.67 3.15 84.74% 

13 Mula Pravara Electric Co-op Soc. 1 697 0 0 120 0.0 62.7 62.7 1.20 3.15 38.13% 

14 Inter State Sale 4 0 0 0 260 0.0 0.0 0.0 

Total High Tension 10079 15582 5598198 1265.3 3515.2 4800.0 4.11 3.15 130.51% 

Grand Total 12855860 37000 19061760 2309.5 6065.3 8394.3 3.02 3.15 96.12%

EXHIBIT 5: REVENUE FROM REVISED TARIFF - JANUARY TO MARCH 2002 

Annual 

Consumpti 

on MU 

Contract 

demand kW 

/ kVA/HP 

3 months Revised Tariff 

Monthly 

Demand 

Charge 

(Rs/KW)/ 

(Rs/KVA) 

/ (Rs / HP) 

Energy 

Charge 

Ps/U 

T & D 

loss 

Charge 

(p/u) or 

Rs/HP/mo 

nth 

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 


Realisatio Supply 

n (Rs/unit) (Rs/unit) 

Ratio of 

avg 

realisatio 

n to avg 

cost of 

supply 

(%) 

Sl 

Consumer Category & Slab-wise 

Consumption 

Number of 

Consumers 

1 2 3 4 5 6 7 8 9 10 11 12 13 

LT Category 

1 Domestic (LD 1) 

0-30 Units 2682050 3152 0 20 100 10 16.1 78.8 7.9 102.8 

31-100 Units 5258436 2784 0 30 255 20 47.3 177.5 13.9 238.7 

101-300 Units 1294094 1144 0 30 295 20 11.6 84.4 5.7 101.7 

Consumption above 300 units 141128 847 0 30 455 20 1.3 96.3 4.2 101.8 


CL < 10 kW 81190 45 1.1 1.1 

CL > 10 kW 24269 790920 75 1.8 1.8 

Sub Total Domestic 9375708 7926 79.2 437.0 31.8 547.9 2.77 3.15 87.86% 76.08% 

Ratio of 

avg 

realisatio 

n to avg 

cost of 

supply 

(%) with 

existing 

tariff 

2 Non Domestic (LD 2) 

0-100 Units 614161 711 0 70 250 30 12.9 44.4 5.3 62.7 

101-200 units 158598 207 0 70 410 30 3.3 21.2 1.6 26.1 

Consumption above 200 units 104890 676 0 70 500 30 2.2 84.5 5.1 91.8 


CL < 10 kW 46598 55 0.8 0.8 

CL > 10 kW 14328 480625 125 1.8 1.8 

Sub Total Non-Domestic 877649 1594 0 0 0 21.0 150.2 12.0 183.2 4.60 3.15 146.02% 147.49% 

3 General Motive Power (LTP-G) 

0-1000 Units 226422 1136 0 60 240 25 68.2 7.1 75.3 

1001-15000 Units 33051 980 0 60 300 25 73.5 6.1 79.6 

Above 15000 Units 4028 364 0 60 340 25 31.0 2.3 33.2 

Sub Total General Motive Power 263501 2480 3781635 60 34.0 172.6 15.5 222.1 3.58 3.15 113.85% 127.63% 

4 Power Loom 27440 838 439920 60 240 25 4.0 50.3 5.2 59.5 2.84 3.15 90.21% 78.74% 

5 Public Water Supply 

(a) Urban P. W Schemes 

For Connected Load 0 - 67 HP 3188 23.50 19035 60 225 0 0.3 1.3 0.0 1.7 

Sub total 3188 23.50 19035 0.3 1.3 0.0 1.7 2.83 3.15 90.03% 77.91% 

(b) 

Rural P. W Schemes 

Grampanchayat 32380 447 179759 20 75 0 1.1 8.4 0.0 9.5 

Metered Tariff (incl 'C' Class MC) 10606 107 62466 30 140 0 0.6 3.7 0.0 4.3 

Sub Total 42986 554 242225 100 1.6 12.1 0.0 13.8 0.99

Sub total PWW 46174 577 261260 2.0 13.4 0.0 15.4 1.07 3.15 33.96% 20.33% 

6 Agriculture 


Flat Rate Tariff (Rs/HP/month) 1758119 7221 7743968 110 0 10 255.6 0.0 19.2 274.7 1.52 

Metered Tariff (incl poultry) 436123 332 1236327 10 90 10 3.7 7.5 0.8 12.0 1.45 

Sub Total Agriculture 2194242 7553 8980295 259.3 7.5 20.0 286.7 1.52 3.15 48.25% 33.98% 

7 Street Light 

Grampanchayat & Municipal Council 9883 279 0 20 170 0 0.0 11.8 0.0 11.8 

Municipal Corporation Areas 51184 171 0 20 250 0 0.0 10.7 0.0 10.7 

Sub Total Street Light 61067 450 451774 20 10.8 22.5 0.0 33.4 2.97 3.15 94.34% 72.74% 

Total Low Tension 12845781 21419 13914884 410.3 853.5 84.4 1348.2 2.52 3.15 80.00% 71.10% 

HT Category 

1 HTP - I 3069 6425 2432445 325 285 30 179.5 447.1 48.2 674.8 4.20 3.15 133.50% 137.56% 

2200 hrs - 0600 hrs 0 3953 0 0 -75 0.0 -74.1 

0600 hrs - 0900 hrs 0 2315 0 0 0 0.0 0.0 

0900 hrs - 1200 hrs 0 1604 0 0 50 0.0 20.0 

1200 hrs - 1800 hrs 0 2315 0 0 0 0.0 0.0 

1800 hrs - 2200 hrs 0 1930 0 0 90 0.0 43.4 

2 HTP - II 4914 5692 2023930 300 280 30 141.1 374.3 42.7 558.1 3.92 3.15 124.60% 127.47% 

Power Factor Incentive -22.3 

Power Factor Penalty 2.9 

Bulk Discount -4.8 

2(a) Seasonal category 236 44 37423 350 270 30 3.9 2.9 0.3 7.2 6.60 

2(b) Captive Consumers 229445 ditional 20 1.4 1.4 

3 HTP - III 115 599 100395 300 265 0 8.0 39.7 0.0 47.6 3.18 3.15 101.09% 128.10% 

4 HTP - IV 417 330 94368 250 255 0 5.1 21.0 0.0 26.2 3.17 3.15 100.86% 119.13% 

5 HTP - V (Railway Traction) 51 817 362 0 415 0 0.0 84.8 0.0 84.8 4.15 3.15 131.91% 133.46% 

6 HTP - VI 

Residential Complex 245 243 62000 100 220 20 1.9 13.4 1.2 16.4 2.71 

Commercial Complex 39 18 9000 100 350 30 0.3 1.6 0.1 2.0 4.40 

Sub Total HTP VI 284 261 71000 2.1 14.9 1.4 18.4 2.82 3.15 89.70% 84.41% 

7 HTP VII (Agriculture)

Flat Rate Tariff (Rs/HP/month) 827 587 218633 200 0 10 13.1 0.0 0.7 13.8 0.94 

Metered Tariff 397 130 73638 10 90 15 0.2 2.9 0.5 3.6 1.12 

Sub Total HTP VII 1224 717 292271 13.3 2.9 1.1 17.4 0.97 3.15 30.85% 20.28% 

8 HTP IX (TEC) 1 0 550000 600 290 0 99.0 0.0 99.0 

9 Mula Pravara Electric Co-op Soc. 1 697 150000 200 150 0 9.0 26.1 0.0 35.1 2.02 3.15 64.07% 38.13% 

10 Inter State Sale 4 0 0 0 260 0.0 0.0 0.0 

Total High Tension 10316 15582 5752194 457.2 1010.9 93.4 1570.0 4.03 3.15 128.07% 130.51% 

Grand Total 12856097 37000 19667078 867.5 1864.3 177.8 2918.2 3.15 3.15 100% 96% 

Pages 194 to 196 

Note: 

1. ToD calculations not indicated for LTP-G and HTP-III and HTP-IV category, due to data unavailability 

2. ToD data shown for HTP-I include HTP-II category also 

3. Calculations of PF incentive and penalty, and bulk discount are for both HTP-I and HTP-II

(Rs. Crore) 

Category 

Revenue 

from 

Existing 

Tariff (April 

to December 

2001) 

Revenue from 

Revised Tariff 

(January to 

March 2002) 

Total 

Revenue FY 

2001-02 

LT Category 

Domestic (LD-1) 1423.3 547.9 1971.2 

Non-domestic (LD-2) 555.0 183.2 738.2 

General Motive Power 747.0 222.1 969.1 

Power Loom 155.7 59.5 215.2 

Public Water Works 27.7 15.4 43.1 

Agriculture 608.4 286.7 895.1 

Street Lighting 77.2 33.4 110.6 

Sub Total LT 3594.3 1348.2 4942.5 

HT Category 

HTP-I 2086.1 674.8 2760.9 

HTP-II 1732.0 566.6 2298.6 

HTP-III 181.0 47.6 228.7 

HTP-IV 92.8 26.2 119.0 

HTP-V (Railway Traction) 257.4 84.8 342.1 

HTP-VI 52.0 18.4 70.4 

HTP-VII (Agriculture) 38.9 17.4 56.3 

Tata Power Company 297.0 99.0 396.0 

Mula Pravara 62.7 35.1 97.9 

Sub Total HT 4800.0 1570.0 6370.0 

TOTAL 8394.3 2918.2 11312.5 

page 197


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 1 st January 2002. 

(VENKAT CHARY) (JAYANT DEO) (P. SUBRAHMANYAM) 

Member Member Chairman 

(SANJAY KUMAR) 

Secretary 

198


ANNEXURE – I 

LIST OF THE OBJECTORS TO THE MSEB-TARIFF PROPOSAL FOR THE YEAR 2001-02 

S.No. Name & Address of the Objector Remarks 

01 Shri Ramkrishna N. Wankhede- Laghuvetan Colony, Dist. Amravati On Affidavit 

02 Secretary, Nagarik Hakka Saurakshan Samiti, C/o. Ramson Printers, Club On Affidavit. 

Lay Out, Dist. Buldhana-443001, Amravati. 

03 Vidarbha Chamber of Commerce & Industry, Tilak Road, Akola-444 001, On Affidavit 

Amravati 

04 Shri R.B. Agrawal- Khamgaon, Tal. Khamgaon, Dist. Buldhana-444 303, On Affidavit 

05 Shri Rajesh Dattatray Mahajan & Shri Rajesh O Rajore, Tal. Khamgaon, On Affidavit 

Dist. Buldhana 444 303. 

06 Shri Shyamsunder S. Jaipuria- Ram Mandir Road, Yavatmal-45 001, On Affidavit 

07 Grahak Panchayat, Dhamangaon Railway- 444709, Dist. Amravati On Plain 

Paper 

08 Vidarbha Chamber of Small Scale Industry, Lohara Chowk, Yavatmal - On Affidavit 

445001, 

09 Vidarbha Iron & Steel Corporation Limited- MIDC Indl. Estate, Nagpur 

440 028 

On Letter 

head 

10 MSEB Workers Federation, Mohan Nagar, Nagpur 440 001 On Affidavit 

11 Vidarbha Industries Association, Civil Lines, Nagpur 440 001 On Affidavit 

12 Sunflag Iron & Steel Co. Ltd., 33 Mount Road, Sadar, Nagpur 440 001 On Affidavit 

13 Divisional Office, Traction Distribution, Central Railway, Nagpur 440 001 On Affidavit 

14 Shri Madhukar Kukde, M.P. Bose Nagar, Tumsar-441 912, Nagpur On Letterhead 

15 Bhandara Zilla Laghu Udyojak Sanstha, Station Road, Bhandara 441 904 On Letterhead 

16 Federation of Electrical Contractors Association of Maharashtra, Nagpur On Affidavit 

440 010 

17 Model Mills (NTC), Umrer Road, Nagpur. On Affidavit 

18 Shri Nathu Gangadhar Rambhad-8, Ambazari Layout, Nagpur 440 010 On Plain 

Paper 

19 The Wholesale Grain & Seeds Merchants Association, Nagpur 440 002. On letterhead 

20 Rice Millers Association- Gondia- 441 601 On Affidavit 

21 Nagpur Chamber of Commerce Ltd.-73-Central Avenue, Nagpur On Plain 

Paper 

22 Vidarbha Irrigation Dept. Gosikhurd Upsa Sinchan Mandal, Bhandara, 

Nagpur 

On Plain 

Paper 

23 Manikgarh Cement, Nagpur No Written 

Document 

24 Grahak Panchayat, Nagpur No Written 

Document 

25 Jalna Steel Manufacturers Association, Jalna 431 203, On Affidavit 

26 Shri Haribhau Madhav Javle, MLA, , Yaval, Dist. Jalgaon 425304 On Affidavit 

27 Shri Govind S Rao Kothari - Shri Vihar, Station Road, Aurangabad 

431005 

On Plain 

Paper 

28 Bajaj Auto Limited, Aurangabad No Written 

Document 

199


29 Shri Asaram Patil Pawar- Aurangabad No Written 

Document 

30 Shri Hemant Kapadia- Indulkar & Chaudhary, Aurangabad No Written 

Document 

31 Engineer Shri Atmaram G. Bhamre, Taharabad, Tal. Bagalan, Dist. On Affidavit. 

Nashik. 

32 Ab. Aziz Mohd. Husain, 1361, Islampura, Malegaon, Nashik 423203 On Affidavit. 

33 Ambad Indusries & Manufacturers’ Association MIDC, Ambad, Nashik On Affidavit 

422 010 

34 Nashik Industries & Mfrs. Association, MIDC, Satpur, Nashik 422 007 On letterhead 

35 Shri Purshottam Hanumandas Gindodia- Pushpanjali Market, Dhule 

424001 

On plain 

paper 

36 Sudal Industries Limited- Mumbai Nashik Highway, Nashik-422 010 On Affidavit 

37 National Congress Party, Sharanpur Road, Nashik - 422 002 On letter head 

38 Nashik District Builders Electrical Association, Nashik No Written 

Document 

Submitted 

39 Shri Vinayak Gokhale- Shyamla Electro Plater, Ambad, Nashik No Written 

Document 

40 Shri Balwant Haribhau Borse- Raver Yawal, Dist. Nashik No Written 

Document 

41 Shri Dagdu Kisan Mahajan- Raver Yawal, Dist. Nashik No Written 

Document 

42 Shri R.S. Kejriwal- Nashik No Written 

Document 

43 Indian Seamless Steels & Alloys Ltd., 174, Dhole Patil Road, Pune 411 On Affidavit 

001 

44 Mahratta Chamber of Commerce, Industries & Agriculture, Pune 411 On Affidavit 

002. 

45 Sind Co-op. Housing Society Ltd., Sadhu Vaswani Nagar, Aundh, Pune On Affidavit 

411 007 

46 Tata Engineering & Locomotive Company Ltd.- CPE Division, Pune 411 On Affidavit 

018 

47 Krishna Valley Chamber of Industries & Commerce, MIDC Kupwad 416 On Affidavit 

436, 

48 Kolhapur Zilla Powerloom Association, Tal. Hatkanangle, Kolhapur On Affidavit 

49 Solapur Zilla Powerloom Owners Sangh, Old Akkalkot Naka, Solapur On Affidavit 

413 006 

50 Prakash Fabricators, Rajaram Road, Post Box No.207, Kolhapur 416 008. On Affidavit 

51 Cinema Theatre Owners Association, Ichalkaranji 416115, Dist. Kolhapur On Affidavit 

52 Kolhapur Engineering Association, Shivaji Udyamnagar, Kolhapur 416 On Affidavit 

008 

53 National Society for Clean Cities, Pallod Farms, Baner Road, Pune- On Affidavit 

54 Pune Sahar Zilla Peeth Girni Malak Sangh, Mukund Nagar, Pune 411 On Affidavit 

067 

55 Shri Keshav Harihar Patwardhan, Killa Baug, Tal. Mangalvedha, Dist. On Affidavit. 

Solapur 

56 Jana Jagaran Andolan, Simla House, Jaysingpur 416 101, Dist. Kolhapur. On Affidavit. 

200


57 Shiroli Mfgrs. Association, MIDC Area, Shiroli, Kolhapur 416 122 On Affidavit 

58 Pune Chapter of Cost Accountants, Laxminagar, Parvati, Pune 411 098 On Affidavit 

59 Shri Karvir Nivasini Mahalaxmi Ispat Pvt. Ltd., Shirgaon, Kolhapur – 416 On Affidavit 

234 

60 The Kolhapur Steel Limited, Shiroli Tal. Hatkanangale, Dist. Kolhapur – 

416 122 

On Letter 

Head 

61 Emjay Alloys Pvt.Ltd.- 1536,Sadashiv Peth, Tilak Road, Pune – 411 030 On Affidavit 

62 Energy Forum, The Institute of Engineers, J.M.Road, Pune – 411 005 On Affidavit 

63 Pimpari Chinchwad Laghu Udhyog Sanghatana, Pimpari, Pune –411 019 On letter head 

64 Shri Mustafa Jamadar- Pune No Written 

Document 

65 Shri Gajanan Babar, MLA- Pune No Written 

Document 

66 Mula Pravara Electric Co-op. Society Limited - Shrirampur, Dist. On Affidavit 

Ahmednagar. 

67 Bharatiya Kisan Sangh-Maharashtra Pradesh, Tal.Rahata, Ahmednagar- On Affidavit 

423 107 

68 Bhaktashreshtha Kamalakarpant L.Walawalkar Hospital & Diagnostic On Affidavit 

Centre – 

Shreekshetra Dervan, Tal.Chiplun, Dist.Ratnagiri (M.S)-415 606 

69 Konkan Synthetic Fibres Processed Yarn Unit - MIDC, Mahad, Dist. On Affidavit 

Raigad 

70 Ratngiri Zilla Flour Mill Owners Assn. Tal. Sangameshwar,Dist. On Affidavit 

Ratnagiri 415804 

71 Jaisingpur Girni Va Kandap Mandal, Jaisingpur, Dist.Kolhapur,416 101 On Affidavit 

72 Kolhapur Zilla Dalap Kadap Girni Malak Sangh, Mangalwar Peth, On Affidavit 

Kolhapur 

73 Miss.Pournima S. Adelkar - Gavaldevwadi, Kudal, Sindhudurg – 416 520 On Affidavit 

74 Dr.Suvinay V.Damle- Ayurved Chikitsalaya, Kudal, Sindhudurg – 416 On Affidavit 

520 

75 Veej Darwadh Virodhi Sangharsh Samittee, Main Road, Ichhalkaranji, On Affidavit 

Kolhapur 

76 Sangli District Powerloom Owners Association Ltd., Main Road, Sangli On Affidavit 

416 406 

77 Vita Yantramarg Audhyogik Sahakari Sangh Ltd. Vita, Khanapur, Sangli- On Affidavit 

415 311 

78 R.S.R.Mohota Spinning & Weaving Mills Ltd. Hinganghat, Dist Wardha On Affidavit 

-442 301 

79 Shriniwas Laddha & Company, Laddha Gin Compound, College Road, On Affidavit 

Amaravati 

80 Gin Press Factory Owners Association-Tivsa ,College Road, Amravati- On Affidavit 

444 601 

81 Jain Medical, Dondaicha Road, Shahada, Dist.Nandurbar On Affidavit 

82 Krishna Tiles, Prakash Road, Shahada, Dist.Nandurbar- On Affidavit 

83 Espee Lights –Opp.Ambaji Mandir, Shahada, Dist. Nandurbar- On Affidavit 

84 Saurabh Electronics-Opp.Gandhiji’s Statue, Shahada, Dist.Nandurbar – On Affidavit 

85 Prerana Computer & Screen- Ambaji Mandir, Shahada, Dist.Nandurbar- 

425 409 

On Affidavit 

201


86 Prabhat Garage Opp.Gandhiji’s Statue, Shahada, Dist.Nandurbar – On Affidavit 

87 Shri Hiralal Onkar Patil- Gujar Galli, Shahada, Dist.Nandurbar – 425 409 On Affidavit 

88 Sharda Stores- Main Road, Shahada, Dist.Nandurbar On Affidavit 

89 Shri Rajendra M.Agarwal- Rishabha Offset, Shahada, Dist. Nandurbar – On Affidavit 

90 Shri Dhananjay D.Shimpi, Mohida Road, Shahada, Dist.Nandurbar On Affidavit 

91 Prof.Sanjay Shreepadrao Patil, Pusad, Yavatmal-444 204 On Affidavit 

92 Shri J.B.Deshmukh –Talao Lay Out, Pusad, Yavatmal-444 204 On Affidavit 

93 Shri Shirish Narayan Deodhar – 417-Shanivar Peth, Pune- On Affidavit 

94 Shri Kiran R.Kamble – Survay No.146/ 6,Garmal, Dhayari, Pune-411 041 On Affidavit 

95 Shri Vinayak S.Raikar- Raykar Nagar,Dhayari, Pune-41 On Affidavit 

96 Manjusha Madhukar Dheemate- D/12,Shivsagar,Wanwadi, Pune On Affidavit 

97 Shri Sunil Mahadevrao Pund - P.O.Mozar, Kheda, Murtijapur, Dist.Akola On Affidavit 

98 Nagrik & Grahak Hitvardini Mandal, Karnik Road, Kalyan-421 301, Dist. On Affidavit 

Thane 

99 Shri.Shreekant R.Paranjape, Lokgram, Kalyan (E)-421 306, Dist. Thane On Affidavit 

100 Shri Sushant G.Sathe – Mothi Umari, Akola, Dist. Akola On Affidavit 

101 Shri Umesh B.Gaiharwar- Mothi Umari, Akola, Dist. Akola On Affidavit 

102 Shri Shrikant R.Kabra- Toshniwal Lay-Out, Akola, Dist. Akola On Affidavit 

103 Shri Rupesh G.Kamle- Sindhi Camp, Akola, Dist. Akola On Affidavit 

104 Shri Mukund R.Giri- Fadke Nagar, Dabki Road, Akola, Dist. Akola On Affidavit 

105 -Patalganga & Rasayani Industries Association, Rasayani, Dist.Raigad- On Affidavit 

410 222 

106 Shri Shaikh Yusuf Mohmed- Near Urdu School, Gosaviwadi, Nashik-422 On Affidavit 

101 

107 Halari Powerloom Owners & Weavers Assn., Narpoli, Bhiwandi, Dist. On Affidavit 

Thane 

108 Bhiwandi Powerloom Owners & Weavers Welfare Trust, Bhiwandi, Dist. On Affidavit 

Thane 

109 Bhiwandi Padmanagar Powerloom Weavers Association, Bhiwandi, Dist. On Affidavit 

Thane 

110 Bhiwandi Powerloom Weavers Federation, Gokul Nagar, Bhiwandi, Dist. On Affidavit 

Thane. 

111 Shantinagar Powerloom Welfare Association, Bhiwandi, Dist. Thane. On Affidavit 

112 Maharashtra Yantramag Dharak Mahasangh, Narpoli, Bhiwandi, District On Affidavit 

Thane 

113 Bhiwandi Citizen Welfare Society, Patel Nagar, Bhiwandi, Dist. Thane On Affidavit 

421 302 

114 Nagri Samsya Nivaran Manch, Wadi Bhokar Road, Dhule, Tal./ Dist. On Affidavit 

Dhule 

115 Marathwada Industries Association, MIDC Area, Auranagabad-431 005 On Affidavit 

116 Mumbai Grahak Panchayat, Vile Parle (West) –Mumbai-400 056 On affidavit 

117 Thane Belapur Industries Association, Rabale Village, Navi Mumbai 400 On affidavit 

701 

118 Maharashtra Electrosmelt Limited, Mul Road, Chandrapur 442 401 On Affidavit 

119 Shri Deepak Pathak- E-43, MIDC, Latur –413 531 On Affidavit 

120 Vysan Mukt Yuvak Sangh, Koparde Haveli, Karad, Dist.Satara. On Affidavit 

121 Motilal Hirakhan Ginning & Pressing Factory, Gangapur, Aurangabad On Affidavit. 

202


423702 

122 Shri Dilip Anandrao Gulhane- 32-Gramin Grihnirrman Karmachari On Affidavit 

Society, Tal & Dist.Yavatmal – 445 001 

123 Akhil Bharatiya Grahak Panchayat 43/90, Navasahyadri, Pune 411 052 On Affidavit. 

124 Kolhapur Zilla Shivsena Sakha, Ichalkaranji, Dist. Kolhapur On Affidavit 

125 Vasantdada Shetkari Sahakari Sakhar Karkhana Ltd. Tasgaon, Sangli – On Affidavit 

416 416 

126 Hema Pankaj Shah , 19-Amar Society, 44/2 – Erandawane, Pune-411 004 On Affidavit 

127 Shri Suresh Namdeorao Pingle, Yashodham, 440-Shivaji Nagar, Pune-411 On Affidavit 

016 

128 Primlaks Waffles Pvt. Ltd. 862/208, Bhandarkar Institute Road, Pune 411 On Affidavit 

004 

129 Shri Sunil Kishor Kothari, E-25, Indraprastha, 589-Rata Peth, Pune-411 On Affidavit 

011 

130 Shri Madhukar P. Mane- Chaphekar Nagar, Ganeshkhind Road, Pune – On Affidavit 

411 016 

131 Shri Kamlakar Sopanrao Lomate- At Post Bhugaon, Dist.Mulshi-Pune On Affidavit 

132 Sudha G.Sharma, 635/313 Bibwewadi, Behind Mahesh Society, Pune – On Affidavit 

411 037 

133 Sadhana G.Lele, 528/6a,Durvakar Apmt; Dandekar Pool, Pune –411 030 On Affidavit 

134 Alkyl Amines Chemicals Ltd. 401/407 Sector - 17, Vashi, New Bombay- On Affidavit 

703 

135 Nagri Samsya Nivaran Samiti, At Post Vasai, Dist. Thane 401201 On Affidavit 

136 Universal Ferro & Allied Chemicals Ltd., Sir Vithaldas Thackersey Marg, On Affidavit. 

Mumbai 400 020 

137 Chief Engineer-Western Railway, Churchgate, Mumbai – 400 020 On Affidavit 

138 Dasha Srimali Arogya Bhavan Trust, 50, Shamsheth Street, Mumbai 400 On Affidavit 

002. 

139 Maharashtra State Co-op.Textile Federation Ltd. Ballard Estate, Mumbai On Affidavit 

400001 

140 Western Steels Drums Pvt.Ltd.- Yari Road, Versova, Mumbai – 400 061 On Affidavit 

141 Peasants & Workers Party Of India-Mahim (W)-Mumbai-40016 On Affidavit 

142 Jawahar Co.op.Industrial Estate Limited, Mumbai-Pune Road, Panvel-410 On Affidavit 

206 

143 Smt. Sujata Nagesh Soparkar, Road No.16/V, Wagle Indl. Estate, Thane- On Affidavit 

400 604 

144 Panvel Industrial Co.op.Estate Ltd. Mumbai Pune Road, Panvel-410 206 On Affidavit 

145 Janata Dal (Secular) M.S. Jeevan Beema Road, Churchgate, Mumbai- 400 On Affidavit 

020 

146 The Mill owners’ Association, 10-Veer Nariman Road, Mumbai –400 001 On Affidavit 

147 Bhashtachar Virodhi Jan-Andolan Samittee-.Tuljapur, Usmanabad, 413 On Letterhead 

602 

148 Electricity Consumers Association , Kanjurmarg (W), Mumbai –400 078 On Affidavit 

149 Navi Mumbai Action Committee, B/19, Sector 9-A, Vashi, Navi Mumbai On Affidavit 

400 

150 Maharashtra Chamber of Commerce & Industry, Fort, Mumbai 400001. On Affidavit 

151 Chief Electrical Distribution Engineer, Central Railway, Mumbai 400 On Affidavit. 

203


001. 

152 Vidarbha Pradesh Grahak Panchayat, Lendra Park,Ramdas Peth,Nagpur- On Affidavit. 

440 010 

153 Industrial Engg. Depart. of Vishwakarma Institute of Technology, Pune - On Affidavit 

411037 

154 Krishna Sahkari Sakhar Karkhana Ltd., Tal. Karad, Dist. Satara 415108. On Affidavit 

155 Shri Pankaj Sukhadeorao Shrikhande, Tal. Chandur Bazar, Dist. Amravati On Affidavit 

156 Sangli Zilla Sahakari Pani Purvatha Sangh, Tal. & Dist. Sangli, On Affidavit. 

157 Indian Aluminum Company Ltd., MIDC, Taloja A.V., Navi Mumbai 410 On Affidavit 

208 

158 United Consumers of India, , Maruti Complex, Ulhasnagar 421 003 On Affidavit 

159 Sarpanch, Grampanchayat, Nihe, At Post Nihe, Tal. Palghar, Dist. Thane On Affidavit 

160 Sarpanch, Group Gramphanchayat, Kakadpaeda, Nihe, Tal. Palghar, Dist. On Affidavit 

Thane 

161 Grampanchayat Gundle, Gundle, Mahagaon, Tal. Palghar, Dist. Thane. On Affidavit 

162 Akhil Bhartiya Janwadi Mahila Sanghatana, Maharashtra State 

On Affidavit 

Committee, Mahanagarpalika Marg, Mumbai 400 001. 

163 Shri Tushar Sharad Vaturkar, B-14/3, Bandhan Society, Pune 411 027 On Affidavit 

164 Dr Latika Argade, Reader, Gokhale Institute of Politics & Economics, On Affidavit. 

Pune. 

165 Mahad Manufacturers Association, , MIDC Office, Mahad 402 309 On Affidavit. 

166 Shri Nitin Ramesh Patil, New Puria Ward, Javal Bhusaval, Dist. Jalgaon. On Affidavit. 

167 Pani Sanghrsh Chalawal, Kisan Ahir Vidhyalaya, At Post-Walave, On Affidavit. 

Dist.Sangli 

168 Dhoot Compack Limited, , Pharola, Tal. Paithan Dist. Aurangabad 431 On Affidavit 

103 

169 Tarapur Industrial Mfgrs. Associatgion, MIDC, Dist. Thane 401 506 On Affidavit 

170 All India Induction Furnaces Assn.,Victoria Road, Mazgaon, Mumbai 400 On Affidavit. 

010 

171 Sanjay H. Pardeshi, 8, Yogeshwari, Erandwane, Pune 411 004. On Affidavit. 

172 Shri Baban Sonasa Khandare- Akhil Bhartiya Grahak Panchayat- On Affidavit. 

Dist.Amravati 

173 Shri Pravin G.Sirsat, Athwade Bazar, , Bhusawal, Dist.Jalgaon-425 201 On Affidavit 

174 Shri Bhaveshwar G Zadbuke, At Post Bhedshingi, Tal. Sangola, Dist. On Affidavit 

Solapur 

175 Shri Subhash G. Wasu, Parsapur, Tal. Achalpur, Dist. Amravati. On Affidavit 

176 Shri Rajkumar Vijaychand Bardia, Paratwada, Tal. Achalpur, Dist. On Affidavit 

Amravati. 

177 Shri Sanjay Motiram Boke, Paratwada, Tal. Achalpur, Dist. Amravati On Affidavit 

178 Azadi Bachao Andolan, Paratwada, Tal. Achalpur, Dist. Amravati. On Affidavit 

179 Shri Waman N Dhole, Pathrot Tal. Achalpur, Dist. Amravati On Affidavit 

180 Maharashtra Rajya Kisan Sabha, Janshakti, P.B. Marg, Worli, Mumbai On Affidavit 

400 013 

181 MIDC Industries Association, P-26, Indl. Area, Hingna Road, Nagpur 440 On Affidavit 

028 

182 Indian Wind Energy Assn., Maharashtra Chapter, Chira Bazar, Mumbai 

400 002 

On Affidavit 

204


183 Renewable Energy Developers Association of Maharashtra, Mumbai 400 On Affidavit 

01 

184 Shri Pradyumna Kaul, , Sitladevi Temple Road, Mahim, Mumbai 016 On Affidavit. 

185 Rice & Flour Mill Association Ratnagiri District, Tal. Dapoli, Ratnagiri On Affidavit. 

415 712 

186 Ispat Industries Limited, Nirmal, 7 th floor, Nariman Point, Mumbai 400 On Affidavit 

021 

187 Janta Dal (Secular), Tal. Vasai, Dist. Thane On Affidavit 

188 Nitin B Shelar, Nagar Sevak, Nallasopara Nagar Parishad, Tal. Vasai, On Affidavit 

401203 

189 Gram Panchayat Shelar, Tal. Bhiwandi, At Borpada, Dist. Thane On Affidavit 

190 Niskalp Inverstments & Trading Co. Ltd. Ballard Estate, Mumbai 400 On Affidavit 

001. 

191 Tata Finance Limited, Mahakali Caves Road, Andheri (East), Mumbai On Affidavit 

400 093. 

192 Deepak Fertlizers & Petro chemicals Ltd., Taloja, Raigad On Affidavit 

193 Rashtravadi Congress Party, Chembur Mumbai 400 071 On Affidavit 

194 Shri Vishnupant Shivramji Wadnekar, Tal. Chandur Bazar, Dist. On Affidavit 

Amravati 

195 Shri Vijay Pundlikrao Wadnerkar, Tal. Chandur Bazar, Dist. Amravati. On Affidavit 

196 Shri Dilip Rambhau Ghongade, Tal. Chandur Bazar, Dist. Amravati. On Affidavit 

197 Nag Vidarbha Chamber of Commerce, Temple Road, Civil Lines, Nagpur On Affidavit 

198 Rajarambapu Patil SSK Ltd., Rajaramnagar, Tal. Warna, Dist. Sangli On Affidavit 

415414 

199 Shri Tatyasaheb Kore Warana SSK Ltd. Tal. Panhala, Dist. Kolhapur. On Affidavit. 

200 Thane Small Scale Industries Association,.P-26, Wagle Estate, Thane-400 On Affidavit 

604 

201 Thane District Industries Power Forum- Pawar Nagar, Thane – 400 604 On Affidavit 

202 Shree Laxmi Narayan Oil Mills-Malegaon Road, Satana-423 301- 

Dist.Nashik 

On Plain 

Paper 

203 Promoters and Builders Association - Toral, Panchavati, Nashik –3 On Affidavit 

204 MSEB Workers Federation, C, 302/2, L.B.S.Marg, Kurla, Mumbai- On Affidavit 

400070 

205 Deputy Engineer- MIDC -Murbad, Kalyan On Affidavit 

206 Tata Power Co. Ltd. 22-A, Akash Ganga, 89 - B.D. Road, Mumbai - 400 On Affidavit 

026 

207 Nimba Murlidhar Kadam, Plot No.31, Dyane, Malegaon, Nashik-423203 On Affidavit 

208 Lanja Taluka Flour Mill Owners Association, Tal. Lanja, Dist. Ratnagiri On Affidavit 

209 Azadi Bachao Andolan, Charghar Colony, ,.Bhadravati, Dist. Chandrapur On Affidavit 

210 Shri. Dilip Baburao Mahajan, 60/3 Shivnagri, Chinchwad, Pune 411 033 On Affidavit 

211 Shri. Subhash K.Shukla, 5/21, Sector -8, C.B.D., Belapur, Navi Mumbai- On Affidavit 

614 

212 Maharashtra Vij Kamgar Mahasangh, 185, Shaniwar Peth, Pune On Affidavit 

213 Shri.Prashant K.Zaveri, 91/2, Banganga Road, Malbar Hill, Mumbai 400 On Affidavit 

006 

214 Transperent Energy System P.Ltd., Bibwewadi Corner, Pune – 411 037 On Affidavit 

215 Veej Grahak Sangha, 9996- V, Sadashiv Peth, Pune- 411 003 On Affidavit 

205


216 Pradip Sahahbrao Khajane, Karajgaon, Tal. Chandur, Dist: Amravati. On Affidavit 

217 Rajesh Punjabrao Hingane, Karajgaon, Tal: Chandur, Amravati On Affidavit 

218 Vikas Damodharrao Kuralkar, Karajgaon, Tal.Chandur, Amravati On Affidavit 

219 Sanjay Govindrao Wasankar, Karajgaon, Tal.Chandur, Amravati On Affidavit 

220 Deepak Devidasji Sonar Karajgaon, Tal.Chandur, Amravati On Affidavit 

221 Rupesh Pralhadrao Khajone, Karajgaon, Tal.Chandur, Amravati On Affidavit 

222 Jitendra Rajkumar Kuralkar- Karajgaon, Tal.Chandur, Amravati On Affidavit 

223 Rajabhau Wamanrao Tawalare Karajgaon, Tal.Chandur, Amravati On Affidavit 

224 , Raver Yawal Taluka, Agricultureal Pumps Owners Associaition, On Affidavit 

Chinawal 

225 Dr.Sulbha Brahme-Trustee, 129/B, Erandwane, Pune 411 004 On Affidavit 

226 Anil Manilal Shah, Akot, Tq. Akot, Dist Akola On Affidavit 

227 Jayantilal Shamji Haria, Murtijapur, Dist. Akola On Affidavit 

228 Chetan Kamlsingh Girase, Muktainagar, Jalgaon On Affidavit 

229 Prayas, Erandavane, Ganegote Path Pune 411 004 On Affidavit 

230 Madhukar Mahadev Gedam, Maywadi, Morshi, Amravati On Affidavit 

231 Vinod Amrutrao Gedam, Maywadi, Morshi, Amravati On Affidavit 

232 Ganesh Shankarrao Gedam, Maywadi, Morshi, Amravati On Affidavit 

233 Manohar Sadashivrao Gedam, Maywadi, Morshi, Amravati On Affidavit 

234 Sukhdev Govindrao Bhusari, Maywadi, Morshi, Amravati On Affidavit 

235 Ruprao Chandrabhan Gedam, Maywadi, Morshi, Amravati On Affidavit 

236 Bhagwat Shankarao Gedam, Maywadi, Morshi, Amravati On Affidavit 

237 Maniklal Ratanlalji Mantri, Maywadi, Morshi, Amravati On Affidavit 

238 Garware Polyester Limited, Shriniketan Colony, Jalna Road, Aurangabad On Affidavit 

239 Tabela Malak Sanghtana, Issa Mannu Dairy Farm, Taluka Vasai,Dist. On Affidavit 

Thane 

240 Shri Rohidas Kashinath Kadam, Chittagaon, Niphad, Nashik On Affidavit 

241 Shri Sudam T.Rayate- Chittagaon, Niphad, Nashik On Affidavit 

242 Jai Durga Jal Sanstha Sahakari Sanstha Maryadit, Chandori, Niphad, On Affidavit 

Nashik 

243 Mamleshwar Sahakari Upsa Jalsinchan Sanstha Maryadit, Niphad, Nashik On Affidavit 

244 Late Bhaskar Sakharam Patil Sahkari sanstha Maryadit, Kothure, Nashik On Affidavit 

245 Kothure Sah Upsa Jalsinchan Sanstha Maryadit, Koture, Nashik On Affidavit 

246 Shri Swamy Samarth Upsa Jalsinchan Sah Sanstha Maryadit, Niphad, On Affidavit 

Nashik 

247 Godavari Sahakari Upsa Jalsinchan Sanstha Maryadit - Niphad, Nashik On Affidavit 

248 Shriram Sahakari Upsa Jalsinchan Sanstha Maryadit- Niphad, Nashik On Affidavit 

249 Jalmalhar Sahakari Upsa Jalsinchin Sanstha Maryadit- Chapadgaon, On Affidavit 

Nashik 

250 Tatyasaheb Boraste Sahakari Upsa jasinchan Sanstha Maryadit, Niphad, On Affidavit 

Nashik 

251 Jay Malhar Prahlad Patil Karad Upsa Jalsinchan Sanstha Maryadit On Affidavit 

Niphad, Nashik 

252 Savarkar Saha.Upsa Jalsinchan Sahakari Sanstha Maryadit, Niphad, On Affidavit 

Nashik 

253 Sakradevi Sah.Upsa Jalsinchan Sanstha Maryadit-Mahalsakore, Niphad, 

Nashik 

On Affidavit 

206


254 Vagad Sah.Upsa Jalsinchan Sanstha, Umralhe, Dindori, Nashik On Affidavit 

255 Umrale Jalsinchan Sanstha Maryadit- Umrale, Dindori, Nashik On Affidavit 

256 Niphad Taluka Upsa Jalsinchan Sanstha Maryadit-Chandori, Niphad, On Affidavit 

Nashik- 

257 Late Tatya Saheb Borsate Sahakari Upsa Jal sinchan Sanstha Maryadit, On Affidavit 

Niphad, Nashik- 

258 Jai Kisan Upsa Jalsinchan Sanstha Maryadit- Chandori, Niphad, Nashik On Affidavit 

259 Sanjeevani Sah Upsa Jal Sinchan Sanstha Maryadit-Chandori, Niphad, On Affidavit 

Nashik 

260 Shri Bhimaji Dada Bodke, Shimpitakli, Niphad, Nashik On Affidavit 

261 Shri Sitaram Mahsu Gade, Chittagoan, Niphad, Nashik On Affidavit 

262 Shri Popat Damu Bhambare, Chittagoan, Niphad, Nashik On Affidavit 

263 Shri Baban Karbhari Lokhande, Shimpitakli, Niphad, Nashik On Affidavit 

264 Shri Devram Dagdu Bodke, Shimpitakli, Niphad, Nashik On Affidavit 

265 Shri Maruti Bhimaji Lokhande, Shimpitakli, Niphad, Nashik On Affidavit 

266 Shri Chindu Sukhdev Lokhande-Shimpitakli, Niphad, Nashik On Affidavit 

267 Shri Chindu Chimaji Lokhande, Shimpitakli, Niphad, Nashik On Affidavit 

268 Shri Rangnath Sukhdev Lokhade-Shimpitakli, Niphad, Nashik On Affidavit 

269 Shri Pandurang Karbhari Lokhande-Shimpitakli, Niphad, Nashik On Affidavit 

270 Shri Dhyaneshwar S.Lokhande- Shimpitakli, Niphad, Nashik On Affidavit 

271 Shimpitakle, Niphad, Nashik On Affidavit 

272 Shri Sanjay Popat Bodke, Shimpitakli, Niphad, Nashik On Affidavit 

273 Shri Baburao Trambak Nathe, Chandori, Niphad, Nashik On Affidavit 

274 Shri Pandit Devram Tarle, Chandori, Niphad, Nashik On Affidavit 

275 Shri Sukhdev Vithoba Tarle, Chandori, Niphad, Nashik On Affidavit 

276 Shri Eknath Sakharam Tarle, Chandori, Niphad, Nashik On Affidavit 

277 Shri Bajirao Dattu Tarle, Chandori, Niphad, Nashik On Affidavit 

278 Shri Vijay Kashinath Gadakh, Chandori, Niphad, Nashik On Affidavit 

279 Shri Pushkar Chandrashekhar Hingne, Chandori, Niphad, Nashik On Affidavit 

280 Shri Namdeo Govind Moghal, Shingave, Niphad, Nashik On Affidavit 

281 Shri Jaganath Mahadu Shinde, Shingave, Niphad, Nashik- On Affidavit 

282 Shri Rambhau Punja Tarle, Shingave, Niphad, Nashik- On Affidavit 

283 Shri Sitaram Shivram Hadpe, Mahalsakore, Niphad, Nashik- On Affidavit 

284 Shri Gulab Dadamiya Pathan, Mahalsakore, Niphad, Nashik- On Affidavit 

285 Shri Jaganath Ganagadhar Dhoble-Mahalsakore, Niphad, Nashik On Affidavit 

286 Shri Rangnath Yashwant Gunjale- Mahalsakore, Niphad, Nashik On Affidavit 

287 Shri Kisan Shankar Murkute, Mahalsakore, Niphad, Nashik On Affidavit 

288 Shri Baburao Genu Valke, Mahalsakore, Niphad, Nashik On Affidavit 

289 Shri Vamanrao Namdevrao Karad-Jalgaon, Niphad, Nashik On Affidavit 

290 Shri Udhav Vamanrao Karad, Jalgaon, Niphad, Nashik On Affidavit 

291 Shri Ratan Gomaji Wadgule, Jalgaon, Niphad, Nashik On Affidavit 

292 Shri Motiram Madhavrao Wadgule-Jalgaon, Niphad, Nashik On Affidavit 

293 Shri Laxman Pundlikrao Moghul-Kothure, Niphad, Nashik On Affidavit 

294 Shri Motiram Madhav Mogul, Kothure, Niphad, Nashik On Affidavit 

295 Shri Madhav Ramji Geethe, Kothure, Niphad, Nashik On Affidavit 

296 Shri Dinkar Jaganath Mogul, Kothure, Niphad, Nashik On Affidavit 

297 Shri Punja Namdeo Phad, Darna Sangvi, Niphad, Nashik On Affidavit 

207


298 Shri Daulat Pandharinath Khalkar- Bhendali, Niphad, Nashik On Affidavit 

299 Shri Govindrao Genuji Survade-Pimpals, Niphad, Nashik On Affidavit 

300 Shri Gorakh Parshuram Wakade-Kundewadi, Niphad, Nashik On Affidavit 

301 Shri Eknath Hari Tarle, Chandori, Niphad, Nashik On Affidavit 

302 Shri Haribhau Kacharu Padole, Mahalsakore, Niphad, Nashik On Affidavit 

303 Shri Nivurttti Karbhari Padole, Mahalsakore, Niphad, Nashik On Affidavit 

304 Shri Bansi Revji Tarle, Chandori, Niphad, Nashik On Affidavit 

305 Shri Somnath Sakharam Londhe & Shri Rambhau Sitaram Tarle - On Affidavit 

Chandori, Niphad, Nashik 

306 Shri Gopinath Shivram Rajole, Khadak Malegaon, Niphad, Nashik On Affidavit 

307 Shri Santu Ganpat Bodke, Darna Sangvi, Niphad, Nashik On Affidavit 

308 Shri Sharad Nivurttti Gohad, Darna Sangvi, Niphad, Nashik On Affidavit 

309 Shri Namdev Pandharinath Jadhav- Darna Sangvi, Niphad, Nashik On Affidavit 

310 Ramdas Parvat Adsare, Karanji Khurd, Niphad, Nashik On Affidavit 

311 Chitleshwar Sah. Upsa Jalsinchan Sanstha Ltd. Chitegaon, Dist.Niphad, On Affidavit 

Nashik 

312 Hanumant Rice Mill, Deori Road, Amgaon-441 902, Dist.Gondia (M.S.) On Affidavit 

313 Khandelwal Rice Mill, Lanji Road, Amgaon, Dist.Gondia On Affidavit 

314 Shri Ramesh Kumar A. Kavda, , At Post-Tahsil, Goregaon, Dist. Gondia On Affidavit 

315 Shri Dinesh Kumar B. Agarwal- Geeta Rice Mill, Manohar Chowk, Dist. On Affidavit 

Gondia 

316 Shri Gorakhnath R.Agrawal - Gurudeo Agro Industries, Gankhera, On Affidavit 

Gondia 

317 Gupta Rice Mills, Kamatha Road, Amgaon, Gondia On Affidavit 

318 Shri Vijaykumar B. Agrawal, C/o. Vijay Udyog, Amgaon, Gondia On Affidavit 

319 Shreenath Rice Industries, Durga Chowk, Tumkheda, Gondia On Affidavit 

320 Shreenath Parboiling, Tumkheda, Durga Chowk, Gondia On Affidavit 

321 Swastik Rice Mill, At Post - Sankhalia, Gondia On Affidavit 

322 Katakwar Rice & Oil Mill, Amgaon, Dist.Gondia On Affidavit 

323 Geetika Parbailing Nagara, C/o. Manohar Chowk, Gondia On Affidavit 

324 Rahul Rice Mills, Nagara, C/o. Manohar Chowk, Gondia On Affidavit 

325 BK Industries, Nagara, C/o. Manohar Chowk, Gondia On Affidavit 

326 Kailash Rice Mill, Near Rely Station, At Post -Tahsil, Goregaon, Gondia On Affidavit 

327 Kalpeshbhai Raojibhai Patel, Maruti Rice Mill, Mundipar, Gondia On Affidavit 

328 Ashti Rice Mill, Main Road, Amgaon, Gondia On Affidavit 

329 Ambika Rice Mill (Sakoritala), Main Road, Amgaon, Gondia On Affidavit 

330 Shri Mukeshbhai N. Patel , C/o. Patel Rice Industries, Mundipar, Gondia On Affidavit 

331 Subhalakshmi Rice Industries, F-42, M.I.D.C.Gondia On Affidavit 

332 Shri Kisanlal R. Khandelwal-Khandelwal Paddy Processors, Adasi, On Affidavit 

Gondia 

333 Rani Sati Rice Mill, Manohar Chowk, Gondia On Affidavit 

334 Shyambaba Parboiling Industries, Hidamalli, Goregoan Road, Gondia On Affidavit 

335 Maheshwari Industries, Amgaon, Gondia On Affidavit 

336 Bharat Rice Mill, MIDC, Gondia. On Affidavit 

337 Balaji Oil Industries, Amgaon, Gondia On Affidavit 

338 Maa Durga Rice Mill, At Post Mangali, Khapa, Tumsar, Gondia On Affidavit 

339 Shri Bhanabai Tannumal Karda- Karda Parboiling, Chhutiya Road, On Affidavit 

208


Gondia 

340 Sandeep Agro Industries, Laxmipur, Khamari, Gondia On Affidavit 

341 Ganesh Rice Mill, Amgaon, Gondia On Affidavit 

342 Karda Rice Mill, Pind Keeper, Chhutiya Road, Gondia On Affidavit 

343 Murlidhar Rice Mill, Lanji Road, Amgaon, Gondia On Affidavit 

344 Shri Dhanesh Bhomraj Agrawal Venketesh Rice Mill, F-39, MIDC, On Affidavit 

Mundipar, Gondia 

345 Shri Krishnakumar G. Gandhi-Gandhi Rice Mill, Marartoli, Gondia On Affidavit 

346 Shri Indrakumar B. Asati-Annapurna Rice Mill, Main Road, Amgaon, On Affidavit 

Gondia 

347 Shri Sureshkumar B. Agrawal-Narmada Rice Mill, Main Road, Gondia On Affidavit 

348 Sona Rice Mill, Amgaon, Gondia On Affidavit 

349 Shiv Shankar Modern Rice Mill, Mangali, Post Khapa, Tumsar, Gondia On Affidavit 

350 Shree Seeta Paddy Processors, Milltolly Village, Gankhera, Gondia On Affidavit 

351 Shri Vishnu Kumar B.Agrawal- Savita Industries, Laxmipur, Khamari, On Affidavit 

Gondia 

352 Balaji Rice Mill, Durga Chowk, Tumkheda, Gondia On Affidavit 

353 Shri Pralhad Sureshbabu Asati - Main Road, Amgaon 441902, Gondia. On Affidavit 

354 Jai Bamleshwari Rice Sortex, Manohar Chowk, Gondia On Affidavit 

355 Saibaba Rice Mill, At Khopa, Tumsar, Bhandara, Gondia On Affidavit 

356 Shri Asati Rice Mill, Amgaon 441902 On Affidavit 

357 R.M. Khandelwal Rice Dal, Flour & Oil Mills, Bajpai Ward, Gondia On Affidavit 

358 Vidarbha Rice Mill, Kidangipar, Amgaon On Affidavit 

359 Jai Bamleswari Rice Mill, Manohar Chowk, Gondia On Affidavit 

360 Shri Tirupati Rice Mill, Laxmipur, Khamari, Gondia On Affidavit 

361 Khendelwal Rice Mills, Bajpai Ward, Gondia On Affidavit 

362 Hanuman Rice Mills, Vijaya Nagar, Balaghat Rd., Gondia On Affidavit 

363 Shrinath Rice Mill, Kamatha Road, Amgaon, Gondia On Affidavit 

364 Bajrang Rice Mill, Lanji Road, Amgaon, Gondia On Affidavit 

365 Funde Rice Mill, Kamatha Road, Bangaon, Gondia. On Affidavit 

366 Shyam Shiv Rice Mill, Om Bhavan, Gondia On Affidavit 

367 Shri Balram Jiyalal Agrawal , C/o. Shri Ram Rice Mill, Amgaon On Affidavit 

368 Shri Sainath Rice Mill, Laxmipur, Kamari, Gondia On Affidavit 

369 Shyam Baba Rice Mill, Laxmipur, Khamari, Gondia On Affidavit 

370 Shyam Baba Rice Industries, Goregoan Road, Hirdamali, Gondia On Affidavit 

371 Bansal Rice Industries, Rajegaon, Gondia On Affidavit 

372 Shri Gopal S. Kothari - DK Sortex, Amgaon On Affidavit 

373 Keshav Rice Mill, At Mangli, Tumsar, Bhandara On Affidavit 

374 Gajanan Agro Industries, Vijay Nagar, Balaghat Road, Gondia On Affidavit 

375 Shree Sita Chawal Udyog, Nagpur Road, Gondia. On Affidavit 

376 Shri Chunilalbhau Thakur, M.P., Bhandara Lok Sabha, -Goregaon, Dist. 

Gondia. 

On 

Letterhead. 

377 Rice Millers Association, Rice Bhawan, Gondia-441 601 On Affidavit 

378 Santaram Rice Mills, Sharda Vachanalaya, Gondia On Affidavit 

379 Gupta Rice Indstries, Bapabodi Mills Compound, Gondia-441601 On Affidavit 

380 Shri Ramgopal Rice Mill- Lal Bahadur Shashtri Ward, Gondia On Affidavit 

381 Radhika Rice Industries, Sharda Vachanalya Complex, Gondia On affidaivt 

209


382 Shri Ganesh Industries, Sharda Vachanalya Complex, Gondia On affidaivt 

383 Prem Rice Mills- Plot NoC-1, MIDC, Mundipar, Gondia On affidaivt 

384 Hariom Rice Mills, Sharda Vachanalya Complex, Gondia On affidaivt 

385 Shree Saibaba Wires Industries, Mundipar, Gondia On affidaivt 

386 Bapabodi Rice Mills- Manohar Chowk, Gondia On affidaivt 

387 Shyam Rice Mill - F-43, MIDC, Mundipar, Gondia On affidaivt 

388 Gajanan Oil & Rice Mills-Amagon On affidaivt 

389 Shyam Rice Industries-Gankhera, Gondia On affidaivt 

390 Shree Ganesh Sortex, Sharda Vachanalya Complex, Gondia On affidaivt 

391 Kienzal Rice Industries, Manohar Chowk, Gondia On affidaivt 

392 Shri Saibaba Rice & Poha Mills-Sharda Vachanalya Complex, Gondia On affidaivt 

393 Shri Jugal Kishore Radheyshyam Khandelwal-Gondia On affidaivt 

394 Shri Lokesh K. Bansilal Agarwal-Shri Saibaba Rice Mill, Amagon On affidaivt 

395 Devi Rice Mill, At Palampur, Amgaon, Bhandara On affidaivt 

396 Agarwal Rice Mill, Amagaon On affidaivt 

397 Shree Industries, Sharda Vachanalya Complex, Gondia On affidaivt 

398 Shri Bhajandas Vaidhya (Guruji)-Tiroda, Gondia On letter head 

399 Gondia District Consumers Association, Govindpur, Civil lines, Gondia On letter head 

400 Shri Brij Mohan Agro Industries, Main Road, Gondia-441 601 On affidaivt 

401 Shri Tirupati Rice Mill, Amgaon, Gondia On Affidavit 

402 Saraswati Rice Mill, Amgaon, Gondia On Affidavit 

403 Guhagar Taluka Flour Mills Owner's Association, Tal-Guhagar, Dist On Affidavit 

Ratnagiri 

404 CITU - Maharashtra State Committee, Bhandup, Mumbai – 400 078 On Affidavit 

405 Dhanya & Kirana Retail Vyapari Association, Kulgaon, Dist. Thane-421 On Affidavit 

503 

406 Irrigation Colony, Near Date College, Tal. & Dist. Yavatmal On Affidavit 

407 Prof. Ashish C.Saoji, B.N.Engineering College, Pusad, Dist. Yavatmal – On Affidavit 

444 204 

408 Shri Anil H. Soni, Near Yashwant Stadium, Pusad, Dist.Yavatmal – 444 On Affidavit 

204 

409 Prof. K.M.Punwatkar , B.N.Engineering College,Pusad, Dist.Yavatmal- On Affidavit 

444 204 

410 Prof. R.J.Bhiwani, B.N.Engineering Colege, Pusad, Dist. Yavatmal-444 On Affidavit 

204 

411 Dr. Surendra Bilolikar , Saikrupa Hospital, Pusad, Dist. Yavatmal – 444 On Affidavit 

204 

412 Akhil Bhartiya Grahak Panchayat, Malgujariopura, Wardha – 442 001 On Affidavit 

413 All India Association of Industries, Nariman Point, Mumbai - 400 021 On Affidavit 

414 Indian Merchants' Chamber, IMC Marg, Churchgate, Mumbai – 400 020 On Letterhead 

415 Vidarbha Dal Millers Association, Bagdagani, Nagpur- 440 008 On Letterhead 

416 Mahindra & Mahindra Ltd. Akurli Road, Kandivali (E), Mumbai-400 101 On Letterhead 

417 Pushkaraj Plastics, Lote Parshuram Industrial Estate, Lote-415722 On Letterhead 

(Ratnagiri) 

418 Shri Tarun Kumar Ray, Chandansar, Virar (E)- Dist. Thane On Plain 

Paper 

419 Printers Guild, 973 G, Nandanvan Colony, Nagpur- 440009 On letter head 

210


420 Bajaj Electricals Ltd., 51-M.G.Road, Fort, Mumbai – 400 023 On letter head 

421 Vidarbha Mills, Berar, Achalpur-444 805 On Plain 

Paper 

422 Shri Uday V.Karandikar, P.O.Mirjole, Karandikarwadi, Dist.Ratnagiri- 

415 639 

On Plain 

Paper 

423 Adivasi Heet Savardhak Mandal, Meharshri, 8/4, Top Nagar, Amravati On Plain 

Paper 

424 Bombay Small Enterprenuers Assn., Mulund (W), Nahur, Mumbai – 400 On Letterhead 

080 

425 Shri Suresh Rajgure, Shivsena Shahar Pramukh, Khandeshwar, Amravati On Letterhead 

426 Nagrik Manch Maharashtra-Citizens Forum Maharashtra, Nagpur – On Letterhead 

440023 

427 Indian Medical Association, Branch Bhandara On Plain 

Paper 

428 Graduate Engineers Association- Nagpur On plain 

paper 

429 R.L.Birla-D-17/304, Yoginagar, Borivali, Mumbai On plain 

paper 

430 Advocate Shri Anand Vishal , 9-Shama Villa, Bhabha Nagar, Nashik - 

422 011 

On plain 

paper 

431 District Congress Committee (I)- Narayan Nagar, Amravati-444 601 On plain 

paper 

432 Miss. Kajal Anil Zope, Bhusaval, Dist. Jalgaon On plain 

paper 

433 Miss. Geetabali Patil, Bhusaval, Dist. Jalgaon On plain 

paper 

434 Miss. Sunita Vikram Patil, Bhusaval, Dist. Jalgaon On plain 

paper 

435 Miss. Jayashree Patil, Bhusaval, Dist. Jalgaon On plain 

paper 

436 Miss. Manish Ganesh Atarade, Bhusaval, Dist. Jalgaon On plain 

paper 

437 Miss. Manisha S.Gholane, Bhusaval, Dist. Jalgaon On plain 

paper 

438 Miss. Sarika M. Bhavsar-, husaval, Dist. Jalgaon On plain 

paper 

439 Miss. Snehalata P. Dhanokar, Bhusaval, Dist. Jalgaon On plain 

paper 

440 Miss.Yogita Gangadhar Chavan-Bhusaval, Dist. Jalgaon On plain 

paper 

441 Miss.Harsha Arun Dhonde-, husaval, Dist. Jalgaon On plain 

paper 

442 Miss. Meena Ashok Hire, Bhusaval, Dist. Jalgaon On plain 

paper 

443 Miss. Chandrakala V. Nemade, Bhusaval, Dist. Jalgaon On plain 

paper 

444 Miss. Bharati Tayade, Bhusaval, Dist. Jalgaon On plain 

paper 

211


445 Miss. Vaishali Sanjay Patil, Bhusaval, Dist. Jalgaon On plain 

paper 

446 Shri Harish Ramvilas Khandelwal-Pavan Nagar , Amravati-444 606 On plain 

paper 

447 Shri Atul Shivdas Deshmukh, New Akola, Dist. Amravati On plain 

paper 

448 Shri Raju Ghorphode, Amravati On plain 

paper 

449 Shri R.D.Patil, Amravati On plain 

paper 

450 Shri J.H.Dongo, Amravati On plain 

paper 

451 Shri A.S.Paithankar, Station Road, Khaparde Bagicha, Amravati On plain 

paper 

452 Shri R.V.Raut, Amravati On plain 

paper 

453 Shri Raj M. Patil, 37-I.I.T. Colony, Amravati On plain 

paper 

454 Shri Nilesh Subhashrao Bherde, Raja Peth, Amravati On plain 

paper 

455 Shri Sanjay A. Chitwale, Mahendra Colony, Amravati On plain 

paper 

456 Shri Jhan Ali, Taj Nagar, Amravati On plain 

paper 

457 Shri Rajersh N. Mungse, I.T.I. Colony, Amravati On plain 

paper 

458 Shri Vijay Nage, Vadali Camp, Amravati On plain 

paper 

459 Shri Nitin Umbarkar, I.T.I. Colony, Amravati On plain 

paper 

460 Shri Prem Ramchandraji Barde, Shanivar Peth, Amravati On plain 

paper 

461 Shri Bajrang Mahadev Lajurkar-Dist. Akola, Amravati On plain 

paper 

462 Shri V.G. Aerpande, I.T.I. Colony, Amravati On plain 

paper 

463 Shri D.G. Savarkar, Dist.Valgaon, Amravati On plain 

paper 

464 Smt. Sangeeta Dhore, 22, New I.T.I. Colony, Amravati On plain 

paper 

465 Shri Ashok Ramravji Deshmukh -Madhan, Chandurbazar, Amravati On plain 

paper 

466 Shri Dilip B. Pachpohar, Rahatgaon, Amravati On plain 

paper 

467 Shri Rupesh Salpekar, Sayed Pura Camp, Amravati On plain 

paper 

468 Shri R.D. Latake, Amravati On plain 

paper 

212


469 Shri Sudhir Khande, Amravati On plain 

paper 

470 Shri Raju Gopal Meghe, Amravati On plain 

paper 

471 Shri Ashok Jaganath Bhasavi, Amravati On plain 

paper 

472 Shri Vinod Uttamrao Tayade- Valgaon Road, Amravati On plain 

paper 

473 Shri Vilas Agarwal- Paratwada, Amravati On plain 

paper 

474 Shri Baba Khan- Nagpur Gate, Amravati On plain 

paper 

475 Shri Amit Ghuse- Amravati On plain 

paper 

476 Shri S.P. Wankhede- Rahul Nagar, Amravati On plain 

paper 

477 Shri Kuldeep Deshmukh- 9-Teacher Colony, Amravati On plain 

paper 

478 Shri Vijay Bijaware- I.T.I. Colony Camp, Amravati On plain 

paper 

479 Shri B.V.Vidhale-Murtijapur (Taroda), Livsa, Dist. Amravati On plain 

paper 

480 Shri Shrikant Dhotre- Achalpur, Amravati On plain 

paper 

481 Shri Atul Anandrao Kale- Dist. Valgaon, Amravati On plain 

paper 

482 Shri P.B. Patil- I.T.I. Colony, Amravati On plain 

paper 

483 Shri Rajesh Damodar Shinde- Amravati On plain 

paper 

484 Shri Iqbal Ahmed- Achalpur, Amravati On plain 

paper 

485 Shri Sanjay Dattuji Pawar- Amravati On plain 

paper 

486 Shri R.T.Deshmukh- Amravati On plain 

paper 

487 Shri Shakir Nayak- Amravati On plain 

paper 

488 Shri Pramod B.Raut – Amravati On plain 

paper 

489 Shri Mukund Shahane – Amravati On plain 

paper 

490 Shri Vijay K. Kanoji- Amravati On plain 

paper 

491 Shri Damodar Mahore- Vadgaon, Amravati On plain 

paper 

492 Smt. Mamtatai Netam- Amravati On plain 

paper 

213


493 Shri Madhukarrao Sachin- Amravati On plain 

paper 

494 Shri Nilesh Dhyaneshwar Savarkar- Amravati On plain 

paper 

495 Shri Manohar Thakur- Indira Chowk, Varad, Amravati On plain 

paper 

496 Shri P.D.Daryadi- Amravati On plain 

paper 

497 Bharat Krishak Samaj, Tope Nagar Camp, Amravati On plain 

paper 

498 Shri Rajesh Vithal Adgokar, Chandikapur, Daryapur, Dist. Amravati On plain 

paper 

499 Shri Sudarshan M. Wadnerkar- Valgaon, Amravati On plain 

paper 

500 Shri Narendra Vasanrrao Yawale- Valgaon, Amravati On plain 

paper 

501 Shri Kiran N. Sonar- Valgaon, Dist. Amravati On plain 

paper 

502 Shri Chandrashekhar D.Satange- Valgaon, Dist. Amravati On plain 

paper 

503 Shri Manoj Yawale- Valgaon, Dist. Amaravati On plain 

paper 

504 Shri Prashant D. Patil- Valgaon, Dist. Amravati On plain 

paper 

505 Shri Girish D. Thelkar- Valgaon, Dist. Amravati On plain 

paper 

506 Shri Amol Ingole- Matkuli, Dist. Amravati On plain 

paper 

507 Shri Devsing .P. Jadhav- Karanja, Dist. Vashim, Valgaon, Dist. Amravati On plain 

paper 

508 Dr. Chandrashekhar R. Kuralkar-Valgaon, Dist. Amravati On plain 

paper 

509 Shri Avinash Sawant- Amravati On plain 

paper 

510 Shri Harish Y. Yawale- Valgaon, Dist. Amravati On plain 

paper 

511 Shri Tukaram R. Sonone, Congress Nagar Road, Dist. Amravati On plain 

paper 

512 Shri Vinod Motiramji Deshmukh- New Akola, Dist. Amravati On plain 

paper 

513 Shri M.O.Mudnaik- Kanta Nagar, Dist. Amravati On plain 

paper 

514 Dr. R.G.Mahale- Ambapeth, Amravati On plain 

paper 

515 Shri Nasim Boli- Amravati On plain 

paper 

516 Shri Nilesh B. Bahe- Vrindavan Colony Camp, Dist. Amravati On plain 

paper 

214


517 Shri Ram P. Wangre- New Ganesh Peth, Amravati On plain 

paper 

518 Shri Himatrao Kale- Kanta Nagar, Dist. Amravati On plain 

paper 

519 Shri Ajak Patel- Pathan Chowk, Amravati On plain 

paper 

520 Shri Shailesh B. Dhunde- Dist. Amravati On plain 

paper 

521 Shri Kavita Pethare- Dist. Amravati On plain 

paper 

522 Shri Pramod M. Deshmukh- P.O.Brahmanwada, Chandur Bazar, Dist. 

Amravati 

On plain 

paper 

523 Shri Arun Ugale- Valgaon, Dist. Amravati On plain 

paper 

524 Shri Suresh Khandarkar- Valgaon, Dist. Amravati On plain 

paper 

525 Shri Manoh M. Mala- Valgaon, Dist. Amravati On plain 

paper 

526 Shri Kishore J. Vahekar- Valgaon, Dist. Amravati On plain 

paper 

527 Shri Vaman Khawal- Valgaon, Dist. Amravati On plain 

paper 

528 Shri Sudhir Bobade- Valgaon, Dist. Amravati On plain 

paper 

529 Shri Sandeep M. Khodaskar- Valgaon, Dist. Amravati On plain 

paper 

530 Shri Uttamrao G. Deshlattar- Valgaon, Dist. Amravati On plain 

paper 

531 Shri Praful O.Khodskar- Valgaon, Dist. Amravati On plain 

paper 

532 Shri Manoj Ambadkar- Valgaon, Dist. Amravati On plain 

paper 

533 Shri Ravi Sureshrao Savarkar- Valgaon, Dist. Amravati On plain 

paper 

X------------------X 

215


ANNEXURE - II 

Submission of Affidavits (Views & Comments) on the Government of Maharahstra 's 

Affidavit dtd. 5th November 2001 and 3rd December 2001 on Tariff Revision Proposal 

of the MSEB for 2001-2002 Public Hearing Scheduled on 24.12.2001 at 10.30 hrs. 

S.No. Name & Address of the Objector Remarks 

01 All India Induction Furnaces Assn. Western Region, Mazgaon, Mumbai On Affidavit 

400010 

02 Pimpri Chinchwad Small Industries Association- Pimpri, Pune-411 018 On Affidavit 

03 The Millowners' Association, 10-Veer Nariman Road, Mumbai - 400 001 On Affidavit 

04 CPED & Environment), TELCO Limited, Pimpri, Pune - 411 018 On Affidavit 

05 Shri Nimba Murlidhar Kadam, Dyane, Tal. Malegaon, District-Nashik On Affidavit 

06 Nagri Samsya Niwaran Manch, Vadibhokar Road, Devpur, Dhule- On Affidavit 

07 Shri Haibatrao N.Patil, Nagri Samsya Niwaran Manch, Devpur, Dhule- On Affidavit 

08 Garware Polyester Limited- Chikalthana Industrial Area, Aurangabad 431 On Affidavit 

210 

09 aisingpur Girni Va Kandap Udhyog Mandal- Jaisingpur Dist, Kolhapur- On Afffidavit 

416 101 

10 Kolhapur Zilla Powerloom Association, Ichalkaranji, Dist. Kolhapur On Affidavit 

11 Rice Millers Association, Gourakshan Market, Gondia - 441 601 On Affidavit 

12 Jan Jagaran Aandolan, Simla House, Jaisingpur, Dist. Kolhapur-416 101 On Affidavit 

13 Mahratta Chamber of Commerce, Industries and Agriculture- Pune - 411 On Affidavit 

022 

14 MIDC Industries Association, Industrial Area, Hingna Road, Nagpur-440 On Affidavit 

028 

15 Gondia Zilla Grahak Panchayat, Govindpur Road, Civil Lines, Gondia- On Affidavit 

16 Pune Chapter of Cost Accountants, Parvati, Shahu College Road, Pune- On Affidavit 

411 009 

17 Prakash Fabricators, 1034-E, Rajaram Road, P.B.No. 207, Kolhapur-416 On Affidavit 

008 

18 The Mula Pravara Electric Co.op.Society Ltd., Shrirampur, Dist. On Affidavit 

Ahmednagar- 

19 Vidarbha Chamber of Small Scale Industries, Lohara Chowk, Yavatmal- On Affidavit 

445 001 

20 Sudal Industries Limited, 227-Nariman Point, Mumbai - 400 021 On Affidavit 

21 Sangli Zilla Power loom Owners Association Ltd. Main Road, Sangli 416 On Affidavit 

406 

22 President, Janta Dal Secular), Yogkshem Marg, Churchgate, Mumbai- 400 On Affidavit 

020 

23 Ichalkaranji Powerloom Weavers Co.op.Association Ltd., Dist. Kolhapur On Affidavit 

24 Vita Yantramarg Authodyogik Sahakari Sangh Ltd. Vitha, Dist.Sangli, - On Affidavit 

415 311 

25 Vidarbha Industries Association-, Civil Lines, Nagpur 440 001 On Affidavit 

26 Vasantdada Shetkari Sahakari Sakhar Karkhana Ltd., Sangli-416 416 On Affidavit 

216


27 All India Association of Industries Nariman Point, Mumbai-400 021 On Affidavit 

28 Chief Electrical Distribution Engineer, Central Railway, CST, Mumbai- On Affidavit 

400 001 

29 Deepak Fertilizers & Petrochemicals Corporation ltd. Taloja, Dist. On Affidavit 

Raigad 

30 Maharashtra Chamber of Commerce & Industry-, Fort, Mumbai - 400 001 On Affidavit 

31 Nashik Industries & Manufacturers' Association, Satpur, Nashik - 422 007 On Affidavit 

32 Shri Deepak Pathak, E-43, MIDC, Latur. On Affidavit 

33 Krishna Valley Chamber of Industries & Commerce- Kupwad, Dist On Affidavit 

Kolhapur 

34 Pani Sangharsh Chalwal, Walve, Dist.Sangli. 415 301 On Affidavit 

35 Maharashtra State Co.op. Textile Federation Ltd. Bellard Estate, On Affidavit 

Mumbai400001 

36 Halari Powerloom Owners' Association, Narpoli, Bhiwandi, Dist. Thane On Affidavit 

37 Maharashtra Yantramarg Dharak Mahasangh, Narpoli, Bhiwandi, District On Affidavit 

Thane 

38 Maharashtra Elektrosmelt Limited, Nariman Point, Mumbai – 400 021 On Affidavit 

39 Electricity Consumers Association, Kanjurmarg (W), Mumbai - 400 078 On Affidavit 

40 Indian Aluminium Co Ltd- Taloja, MIDC, Navi Mumbai-410 208 On Affidavit 

41 Shri S.R. Paranjape-D2-203, Lok gram, Kalyan (E), 421 306 Dist Thane On Affidavit 

42 Ispat Industries Ltd. Nariman Point, Mumbai - 400 021 On Affidavit 

43 Shri Prashant K.Zaveri, 91/L, Banganga Road, Malbar Hill, Bombay - 400 On Affidavit 

006 

44 Thane Small Scale Industries Association, Wagle Estate, Thane - 400 604 On Affidavit 

45 Shri Kachru Fakira Khalkar & Shri Kashinath Kacharu Khalkar, 

On Affidavit 

Ramnagar (Berwadi), Saykheda, Niphad, Nashik 

46 Shri Chhabu Santu Borhade- Ramnagar, Saykheda, Niphad, Nashik On Affidavit 

47 Shri Karbhari Tukaram Khairnar, Ramnagar, Saykheda, Niphad, Nashik On Affidavit 

48 Shri Sonu Malhari Dalvi- Ramnagar, Saykheda, Niphad, Nashik On Affidavit 

49 Shri Shankar Ramji Pawar- Saykheda, Niphad, Nashik On Affidavit 

50 Shri Kishan Rambhau Khalkar- Ramnagar, Saykheda, Niphad, Nashik On Affidavit 

51 Shri Prabhakar Karbhari Pawar- Ramnagar, Saykheda, Niphad, Nashik On Affidavit 

52 Shri Shantaram Chandrabhan Pawar- Ramnagar, Saykheda, Niphad, On Affidavit 

Nashik 

53 Shri Narayan Trambak Kadbhane-Ram Nagar, Saykheda, Niphad, Nashik On Affidavit 

54 Shri Navnath Sitaram Khalkar- Ram Nagar, Saykheda, Niphad, Nashik On Affidavit 

55 Tatyasaheb Boraste Sah.Up-Jalsinchan Sanstha Limited- Niphad, Nashik On Affidavit 

56 Shri Murlidhar Namdev Jamkar- Ram Nagar, Saykheda, Niphad, Nashik On Affidavit 

57 Shri Arun Dattatraya Balak- Ram Nagar, Saykheda, Niphad, Nashik On Affidavit 

58 Shri Vithal Gangadhar Khairnar- Ram Nagar, Saykheda, Niphad, Nashik On Affidavit 

59 Shri Laxman Karbhari Jamkar & Shri Digambar Laxman Jamkar- Ram On Affidavit 

Nagar (Berwadi), Saykheda, Niphad, Nashik 

60 Shri Pundlik Punja Jamkar- Ram Nagar (Berwadi), Saykheda, Niphad, On Affidavit 

Nashik 

61 Shri Vishnu Rambhau Kadbhane- Ram Nagar, Saykheda, Niphad, Nashik On Affidavit 

62 Shri Bhanudas Murlidhar Khairnar-Ram Nagar, Saykheda, Niphad, 

Nashik 

On Affidavit 

217


63 Shri Ramnath Bhimaji Ukade- Ram Nagar (Berwadi), Saykheda, Niphad, On Affidavit 

Nashik 

64 Shri Kisan Somnath Nikam- Ram Nagar, Saykheda, Niphad, Nashik On Affidavit 

65 Shri Valiba Somnath Shinde- Ram Nagar, Saykheda, Niphad, Nashik On Affidavit 

66 Shri Radhakrishna Chhabu Ukade & Shri Eknath Pandu Ukade- Ram On Affidavit 

Nagar, Saykheda, Niphad, Nashik 

67 Shri Vasant Radhuji Kadbhane- Ram Nagar, Saykheda, Niphad, Nashik On Affidavit 

68 Shri Mahadu Dada Khalkar- Ram Nagar (Berwadi), Saykheda, Niphad, On Affidavit 

Nashik 

69 Shri B.R.Kadbhane- Ram Nagar (Berwadi), Saykheda, Niphad, Nashik On Affidavit 

70 Shri Rangnath Ramchandra Kadbhane- Ram Nagar, Saykheda, Niphad, On Affidavit 

Nashik 

71 Shri Laxman Chiman Borade- Ram Nagar, Saykheda, Niphad, Nashik On Affidavit 

72 Shri Dattatray Vishnu Ukade- Ram Nagar, Saykheda, Niphad, Nashik On Affidavit 

73 Shri Amruta Bhima Ukade- Ram Nagar, Saykheda, Niphad, Nashik On Affidavit 

74 Shri Baban Baburao Handge- Ram Nagar, Saykheda, Niphad, Nashik On Affidavit 

75 Shri Bhima Sawliram Pawar- Ram Nagar, Saykheda, Niphad, Nashik On Affidavit 

76 Shri Sanjay Bakerao Tarle- Ram Nagar, Saykheda, Niphad, Nashik On Affidavit 

77 Shri Nivrutti Pandit Borade- Ram Nagar, Saykheda, Niphad, Nashik On Affidavit 

78 Shri Namdev Rajaram Dalvi- Ram Nagar, Saykheda, Niphad, Nashik On Affidavit 

79 Shri Raoji Kisan Ukade- Ram Nagar (Berwadi), Saykheda, Niphad, On Affidavit 

Nashik 

80 Shri Namdev Jagannath Pawar- Ram Nagar, Saykheda, Niphad, Nashik On Affidavit 

81 Shri Shivaji Valu Nikam- Ram Nagar, Saykheda, Niphad, Nashik On Affidavit 

82 Shri Narayan Tatyoba Waychale- Ram Nagar, Saykheda, Niphad, Nashik On Affidavit 

83 Shri Nawasabai Karbhari Jamkar, Ram Nagar, Saykheda, Niphad, Nashik. On Affidavit 

84 Shri Janardan D. Ukade, Ram Nagar, Saykheda, Niphad, Nashik. On Affidavit 

85 Sou. Latabai Ramdas Shinde, Ram Nagar, Saykheda, Tal. Niphad, Dist. On Affidavit 

Nashik. 

86 Shri Ramchandra Baburao Nikam, Ram Nagar, Tal. Niphad, Dist. Nashik On Affidavit 

87 Shri Tukaram Baburao Shinde, Ram Nagar, Saykheda, Tal. Niphad, Dist. On Affidavit 

Nashik 

88 Shri Khandu Bhavraya Khalkar, Ram Nagar, Saykheda, Tal. Niphad, Dist. On Affidavit 

Nashik 

89 Shri Shivaji Namdeo Khalkar, Ram Nagar, Saykheda, Tal. Niphad, Dist. On Affidavit 

Nashik 

90 Shri Popat Fakira Ukade, Ramnagar, Saykheda, Tal. Niphad, Dist. Nashik On Affidavit 

91 Shri Bhagwan Khandu Balak, Ramnagar, Saykheda, Tal. Niphad, Dist. On Affidavit 

Nashik 

92 Shri Vishnu Ramji Pawar, Ramnagar, Saykheda, Tal. Niphad, Dist. On Affidavit 

Nashik 

93 Shri Babaji Radhu Pawar, Ramnagar, Saykheda, Tal. Niphad, Dist. On Affidavit 

Nashik 

94 Shri Shivaji Baburao Jadhav, Ramnagar, Saykheda, Tal. Niphad, Dist. On Affidavit 

Nashik 

95 Shri B. R. Kadbhane, Ramnagar, Saykheda, Tal. Niphad, Dist. Nashik On Affidavit 

96 Shri Ahilyaji Pandurang Shinde, Ramnagar, Saykheda, Tal. Niphad, Dist. On Affidavit 

218


Nashik 

97 Shri Popat Kacharu Shinde, Ramnagar, Saykheda, Tal. Niphad, Dist. On Affidavit 

Nashik 

98 Shri Babaji Bhima Chavan, Ramnagar, Saykheda, Tal. Niphad, Dist. On Affidavit 

Nashik 

99 Shri Ramgopal Kacharu Pawar, Ramnagar (Berwadi), Saykheda, Tal. On Affidavit 

Niphad, Dist. Nashik 

100 Shri Laxman Deoram Ukade, Ramnagar, Saykheda, Tal. Niphad, Dist. On Affidavit 

Nashik 

101 Shri Vikram Shankar Borade, Ramnagar, Saykheda, Tal. Niphad, Dist. On Affidavit 

Nashik 

102 Shri Balu Mahadu Jamkar, Ramnagar, Saykheda, Tal. Niphad, Dist. On Affidavit 

Nashik 

103 Shri Ashok Gajiram Dalvi, Ramnagar, Saykheda, Tal. Niphad, Dist. On Affidavit 

Nashik 

104 Shri Sunil Bhagwant Pawar, Ramnagar, Saykheda, Tal. Niphad, Dist. On Affidavit 

Nashik 

105 Shri Yadav Popat Borade, Ramnagar, Saykheda, Tal. Niphad, Dist. On Affidavit 

Nashik 

106 Shri Lankabai Vishnu Sable, Ramnagar (Berwadi), Tal. Niphad, Dist. On Affidavit 

Nashik 

107 Shri Ramkrishna Baburao Pawar, Ramnagar, Tal. Niphad, Dist. Nashik On Affidavit 

108 Shri Tanaji Laxman Dhomse, Ramnagar, Saykheda, Tal. Niphad, Dist. On Affidavit 

Nashik 

109 Shri Raghunath Sakharam Khalkar, Ramnagar, Tal. Niphad, Dist. Nashik On Affidavit 

110 Shri Vamanrao Namdeorao Karad, Jalgaon, Tal. Niphad, Dist. Nashik On Affidavit 

111 Shri Chindu Sukhdev Lokhande, Darnasangvi, Tal. Niphad, Dist. Nashik On Affidavit 

112 Shri Kashibai Kacharu Dalvi, Ramnagar (Berwadi), Tal. Niphad, Dist. On Affidavit 

Nashik 

113 Shri Bisavpuri Shankarpuri Gosavi, Ramnagar,, Tal. Niphad, Dist. Nashik On Affidavit 

114 Shri Rambhau Khandu Jamkar & Ors, Ramnagar, (, Tal. Niphad, Dist. On Affidavit 

Nashik 

115 Shri Sonu Kacharu Ukade, Ramnagar (Berwadi), Tal. Niphad, Dist. On Affidavit 

Nashik 

116 Shri Navnath Lahanu Pawar, Ramnagar, Saykheda, Tal. Niphad, Dist. On Affidavit 

Nashik 

117 Shri Parvat Deoram Khalkar & Shri Daulat Parvat Khalkar, Ramnagar On Affidavit 

Tal. Niphad, Dist. Nashik 

118 Shri Namdeo Tukaram Jamkar, Ramnagar, Saykheda, Tal. Niphad, Dist. On Affidavit 

Nashik 

119 Shri Bharat Malhari Sable & Shri Ramchandra Malhari Sable, Ramnagar On Affidavit 

(Berwadi), Saykheda, Tal. Niphad, Dist. Nashik 

120 Shri Yeshwant Namdeo Ukade, Ramnagar, Saykheda, Tal. Niphad, Dist. On Affidavit 

Nashik 

121 Shri Triambak Dada Khalkar & Puja Triambak Khalkar, Ramnagar On Affidavit 

(Berwadi), Tal. Niphad, Dist. Nashik 

122 Shri Shivaji Vithoba Pawar, Ramnagar, Saykheda, Tal. Niphad, Dist. 

Nashik 

On Affidavit 

219


123 Shri Kisan Nandaram Jamkar, Ramnagar (Berwadi), Tal. Niphad, Dist. On Affidavit 

Nashik 

124 Shri Maruti Mahadu Khalkar, Ramnagar (Berwadi), Tal. Niphad, Dist. On Affidavit 

Nashik 

125 Shri Ashok Damu Kholve, Ramnagar, Saykheda, Tal. Niphad, Dist. On Affidavit 

Nashik 

126 Shri Rajaram Laxman Chavan, Ramnagar, Saykheda, Tal. Niphad, Dist. On Affidavit 

Nashik 

127 Shri Kashinath Balwant Khalkar, Ramnagar, Tal. Niphad, Dist. Nashik On Affidavit 

128 Chabu Kacharu Ukade, Ramnagar, Saykheda, Tal. Niphad, Dist. Nashik On Affidavit 

129 Shri Bastiram Laxman Jamkar, Ramnagar, Saykheda, Tal. Niphad, Dist. On Affidavit 

Nashik 

130 Shri Prabhakar Gopalgir Gosavi, Ramnagar, Tal. Niphad, Dist. Nashik On Affidavit 

131 Shri Bhaskar Ramchandra Balak, Ramnagar, Tal. Niphad, Dist. Nashik On Affidavit 

132 Shri Bhaskar Buygir Gosavi, Ramnagar, Saykheda, Tal. Niphad, Dist. On Affidavit 

Nashik 

133 Shri Ramdas Murlidhar Borade, Ramnagar, Saykheda, Tal. Niphad, Dist. On Affidavit 

Nashik 

134 Shri Bhimaji Nana Dalvi, Ramnagar, Saykheda, Tal. Niphad, Dist. Nashik On Affidavit 

135 Shri Baban Tukaram Shirsat, Pimplas (Ramache), Tal. Niphad, Dist. On Affidavit 

Nashik 

136 Shri Sampat Savaleram Mali, Pimplas (Ramache), Tal. Niphad, Dist. On Affidavit 

Nashik 

137 Shri Nivruti Chiman Matsagar, Pimplas (Ramache), Tal. Niphad, Dist. On Affidavit 

Nashik 

138 Shri Chiman Punja Matsagar, Pimplas (Ramache), Tal. Niphad, Dist. On Affidavit 

Nashik 

139 Shri Dhondiram Yeshwant Matsagar, Pimplas Tal. Niphad, Dist. Nashik On Affidavit 

140 Shri Tukaram Dagu Surwade, Pimplas (Ramache), Tal. Niphad, Dist. On Affidavit 

Nashik 

141 Shri Balasaheb Vishwanath Matsagar, Pimplas Tal. Niphad, Dist. Nashik On Affidavit 

142 Shri Fakira Savaleram Tajane, Pimplas (Ramache), Tal. Niphad, Dist. On Affidavit 

Nashik 

143 Shri Nivruti Dada Matsagar, Pimplas (Ramache), Tal. Niphad, Dist. On Affidavit 

Nashik 

144 Shri Gangadhar Dagu Surwade, Pimplas (Ramache), Tal. Niphad, Dist. On Affidavit 

Nashik 

145 Shri Dhondiram Govinda Matsagar, Pimplas, Tal. Niphad, Dist. Nashik On Affidavit 

146 Shri Kacharu Damu Aher, Pimplas (Ramache), Tal. Niphad, Dist. Nashik On Affidavit 

147 Shri Yeshwant Trambak Shelke, Pimplas (Ramache), Tal. Niphad, Dist. On Affidavit 

Nashik 

148 Shri Vedu Dada Matsagar, Pimplas (Ramache), Tal. Niphad, Dist. Nashik On Affidavit 

149 Shri Walu Ganpat Tajane, Pimplas (Ramache), Tal. Niphad, Dist. Nashik On Affidavit 

150 Shri Govind Genuji Surwade, Pimplas (Ramache), Tal. Niphad, Dist. On Affidavit 

Nashik 

151 Shri Manohar Appaji Kulkarni, Pimplas (Ramache), Tal. Niphad, Dist. 

Nashik 

On Affidavit 

220


152 Shri Suresh Vithoba Matsagar, Pimplas (Ramache), Tal. Niphad, Dist. On Affidavit 

Nashik 

153 Shri Bajirao Popat Matsagar, Pimplas (Ramache), Tal. Niphad, Dist. On Affidavit 

Nashik 

154 Shri Sampat Narayan Surwade, Pimplas (Ramache), Tal. Niphad, Dist. On Affidavit 

Nashik 

155 Shri Rajaram Pundalik Aher, Pimplas (Ramache), Tal. Niphad, Dist. On Affidavit 

Nashik 

156 Shri Chabu Dhondiram Matsagar, Pimplas (Ramache), Tal. Niphad, Dist. On Affidavit 

Nashik 

157 Shri Ranganath Maruti Tajane, Pimplas (Ramache), Tal. Niphad, Dist. On Affidavit 

Nashik 

158 Shri Jagannath Kashinath Kharde Chandori, Tal. Niphad, Dist. Nashik On Affidavit 

159 Shri Tarle Ganpat Gopala At & Post Chandori Tal. Niphad, Dist. Nashik On Affidavit 

160 Shri Hingane Pushkar Chandrashekhar, At Chandori, Tal. Niphad, Dist. On Affidavit 

Nashik 

161 Shri Shivshankar Mhasuji Korade At & Post Chandori, Tal. Niphad, Dist. On Affidavit 

Nashik 

162 Shri Bansi Devji Tarle At & Post Chandori Tal. Niphad, Dist. Nashik On Affidavit 

163 Shri Sampath Vishwanath Gadakh, At Chandori, Tal. Niphad, Dist. On Affidavit 

Nashik 

164 Shri Nana Punja Korade At & Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 

165 Shri Shivaji Pandharinath Tarle At & Post Chandori, Tal. Niphad, Dist. On Affidavit 

Nashik 

166 Shri Devram Gabaji Nikam At & Post Chandori, Tal. Niphad, Dist. On Affidavit 

Nashik 

167 Shri Tarle Pandit Devram At & Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 

168 Shri Popat Santu Gadakh At & Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 

169 Mrs. Sharmila Jagannath Kharde At & Post Chandori, Tal. Niphad, Dist. On Affidavit 

Nashik 

170 Shri Dagu Bhimaji Tarle At & Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 

171 Shri Eknath Hari Tarle At & Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 

172 Shri Bhima Hari Tarle At & Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 

173 Shri Somnath Dattatraya Tarle At & Post Chandori,Tal. Niphad, Dist. On Affidavit 

Nashik 

174 Shri Vishnu Gopala Shinde At & Post Chandori, Tal. Niphad, Dist. On Affidavit 

Nashik 

175 Shri Dattu Gopala Shinde At & Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 

176 Shri Baburao Bhimaji Tarle At & Post Chandori,Tal. Niphad, Dist. On Affidavit 

Nashik 

177 Shri Baban Karbhari Lokhande Takli , Darpasangavi Tal. Niphad, Dist. On Affidavit 

Nashik 

178 Shri Subhash Baburao Korme At & Post Chandori, Tal. Niphad, Dist. On Affidavit 

Nashik 

179 Shri Sitaram Umaji Nikam At & Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 

180 Shri Dattatraya Shankar Tarle At & Post Chandori, Tal. Niphad, Dist. 

Nashik 

On Affidavit 

221


181 Shri Nandu Vasant Gadakh At & Post Chandori, Tal. Niphad, Dist. On Affidavit 

Nashik 

182 Shri Tukaram Vithoba Gadakh At & Post Chandori, Tal. Niphad, Dist. On Affidavit 

Nashik 

183 Shri Subhash Babu Handge At & Post Chandori, Tal. Niphad, Dist. On Affidavit 

Nashik 

184 Shri Genu Kisan Tarle At & Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 

185 Shri Baban Baburao Tarle At & Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 

186 Shri Balasaheb Daguji Tarle At & Post Chandori, Tal. Niphad, Dist. On Affidavit 

Nashik 

187 Shri Balu Murlidhar Sonavane At & Post Chandori, Tal. Niphad, Dist. On Affidavit 

Nashik 

188 Smt. Haushabai Daguji Tarle At & Post Chandori, Tal. Niphad, Dist. On Affidavit 

Nashik 

189 Shri Ragho Bhimaji Tarle At & Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 

190 Shri Vishnu Gopal Tarle At & Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 

191 Shri Bhimaji Popat Gadakh At & Post Chandori, Tal. Niphad, Dist. On Affidavit 

Nashik 

192 Shri Baburao Tryambak Nathe At & Post Chandori,Tal. Niphad, Dist. On Affidavit 

Nashik 

193 Shri Raghunath Rambhau Tarle At & Post Chandori, Tal. Niphad, Dist. On Affidavit 

Nashik 

194 Shri Sukhdev Punja Korade At & Post Chandori,Tal. Niphad, Dist. On Affidavit 

Nashik 

195 Shri Dattatraya Bhika Korade At & Post Chandori, Tal. Niphad, Dist. On Affidavit 

Nashik 

196 Shri Rohidas Kashinath Kadam At & Post Chitegaon, Tal. Niphad, Dist. On Affidavit 

Nashik 

197 Shri Jaganrao Mahadu Shinde At & Post Shingave, Tal. Niphad, Dist. On Affidavit 

Nashik 

198 Shri Nanasaheb Jayaram Gadakh, At & Post Chandori, Tal. Niphad, Dist. On Affidavit 

Nashik 

199 Shri Ganapat Malhari Bhoj At & Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 

200 Shri Namdevrao Gopala Patil At & Post Chandori,Tal. Niphad, Dist. On Affidavit 

Nashik 

201 Shri Tukaram Bhiika Korade At & Post Chandori, Tal. Niphad, Dist. On Affidavit 

Nashik 

202 Shri Balasaheb Ganapat Bhoj At & Post Chandori, Tal. Niphad, Dist. On Affidavit 

Nashik 

203 Shri Anna Bandu Repote At & Post Chandori, Tal. Niphad, Dist. Nashik On Affidavit 

204 Shri Pandurang Vithoba Bhoj At & Post Chandori, Tal. Niphad, Dist. On Affidavit 

Nashik 

205 Niphad Taluka Sahakari Upsa Jalsinchan Sah. Sanstha Sangh Ld., On Affidavit 

Chandori, Tal. Niphad, Dist. Nashik 

206 Jaykisan Upsa Jalsinchan Sanstha Ltd. Chandori, Tal. Niphad, Dist. On Affidavit 

Nashik 

207 Sanjivani Upsa Jalsinchan Sanstha Ltd. Chandori, Tal. Niphad, Dist. 

Nashik 

On Affidavit 

222


208 Mayleshwar Sah. Upsa Jalsinchan Sanstha Ltd., Tal. Niphad, Dist. Nashik On Affidavit 

209 Swami Samarth Upsa Jalsinchan Sah. Sanstha Ltd. Tal. Niphad, Dist. On Affidavit 

Nashik 

210 Usrale Sahari Upsa Jalsinchan Sanstha Ltd., Ubrale-B, Tal. Dindori, Dist. On Affidavit 

Nashik 

211 Vadyad Sah. Upsa Jalsinchan Sanstha Ltd. Ubrale B, Tal. Dindori, Dist. On Affidavit 

Nashik. 

212 Kothure Sah. Upsa Jalsinchan Sanstha Ltd. Kothure, Tal. Niphad, Dist. On Affidavit 

Nashik 

213 Bhaskar Sakharam Patil Sah. Upsa Jalsinchan Sanstha Ltd., Kothure, Tal. On Affidavit 

Niphbad, Dist. Nashik 

214 Godavari Sah. Upsa Jalsinchan Sanstha Ltd., Tal. Niphad, Dist. Nashik On Affidavit 

215 Chitleshwar Sah. Upsa Jalsinchan Sanstha Ltd. Tal. Niphad, Dist. On Affidavit 

Nashik. 

216 Late Tatyasaheb Borde Sah. Upsa Jalsinchan Sanstha Ltd. A/P Chandori, On Affidavit 

Tal. Niphad, Dist. Nashik 

217 Jai Malhar Sah. Upsa Jalsinchan Sanstha Ltd., At Chapadgaon, Post On Affidavit 

Karanjgaon, Tal. Niphad, Dist. Nashik 

218 Shri Sukhdev Khandu Khairnar, Ramnagar, Saykheda, Tal. Niphad, Dist. On Affidavit 

Nashik 

219 Shri Rajesh Onkarlal Rajore & Satishkumar O. Chaudhari, Khamgaon, On Affidavit 

A/P Jalamb, Tal. Shegaon, Dist. Buldhana 

220 Vidarbha Chamber of Commerce & Industry, Akola, Dist. Akola On Affidavit 

221 Shri Rajesh Dattatraya Mahajan, Khamgaon Road, Malkapur 444 300 On Affidavit 

222 Shri R.B. Agrawal, Opp. Sarafa Post Office, Khamgaon, Dist. Buldhana On Affidavit 

444 303 

223 Shaikh Yusuf Mohmed- Near Urdu School, Gosaviwadi, Nashik Road - On Affidavit 

422 101 

224 Maharashtra State Electricity Board Workers Federation- Nagpur-440 On Affidavit 

001 

225 Divisional Electrical Engineer (TRD), Divisional Office, Traction On Affidavit 

Distribution, Central Railway, Nagpur-440 001 

226 Kolhapur Zilla Dalap-Kandap Girni Malak Sangh, Mangalwar Peth, On Affidavit 

Kolhapur. 

227 Mumbai Grahak Panchayat, Vile Parle (W), Mumbai - 400 056 On Affidavit 

228 Shri Babanrao Radhuji Kadmane- Ramnagar (Berwadi), Dist. Niphad, On Affidavit 

Nashik 

229 Maharatta Chamber of Commerce, Industries & Agriculture, Pune - 411 On Affidavit 

002 

230 Shri Namdeo Totaram Patil- Narsi Natha Street, Masjid Bunder-400 009 On Plain 

Paper 

231 Energy Forum, The Instittute of Engineers, 1332, Shivaji Nagar, Pune-411 

005 

On Plain 

Paper 

232 Malegaon Powerloom Action Committee, Nav kiran Sizing Malegaon- 

423 203 

On Plain 

Paper 

233 Vidarbha Pradesh Grahak Panchayat, Lendra Park, Nagpur-440 010 On Plain 

Paper 

234 Shri R.L. Birla- D-17/304, Yogi Nagar, Borivali (W), Mumbai 400 091 On Plain 

223


Paper 

235 Shri Verzavand N.S.Postvala-, Sleater Road, Grant Road, Mumbai - 400 

007 

On Plain 

Paper 

236 Dr. Sulabha Brahme, Shankar Brahme Samajvigyan Granthalaya- 

Erandwane, Pune-411 004 

On Plain 

Paper 

237 Bhiwandi Padmanagar Power loom Weavers Association- Bhiwandi-421 

305 

On Plain 

Paper 

238 Shri Pravin G. Shirsat, Aathwade Bazar, Dist. Jalgaon, Bhusawal-425 201 On Plain 

Paper 

239 Shri Shri Nitin R. Patil- Aathwade Bazar, Dist. Jalgaon, Bhusawal-425 

201 

On Plain 

Paper 

240 Akhil Bhartiya Grahak Panchayat, Vani, Dist. Yavatmal (M.S.)-445 304 On Plain 

Paper 

241 Grahak Panchayat- Post-Anjangaon, Surji, Dist. Amravati On Affidavit 

242 Marathwada Industries Association, Station Road, Aurangabad 431 005 On Plain 

paper 

243 Shri Dhananjay D Shimpi, Mohida Road, Shahada, Dist. Nandurbar 425 

409 

On Plain 

paper 

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