“Revision of tariff in respect of new Solar Rooftop Photovoltaic Units of 1kW to 10kW capacity installed by domestic consumers”.

Suggestions and opinions on Revision of tariff in respect of new Solar Rooftop Photo-voltaic Units of 1kW to 10kW capacity installed by domestic consumers

  

Preamble :

The Karnataka Electricity Regulatory Commission (KERC), in exercise of the enabling powers conferred under the Electricity Act, 2003 and provisions of the National Electricity Policy, 2005 and Tariff Policy, 2016 has issued a discussion paper proposing revision of tariff in respect of new Solar Rooftop Photovoltaic Units of 1 kW to 10 kW capacity installed by domestic consumers.

The Commission has invited suggestions/comments/ views of the stakeholders and the general public on the following issues:

A.  The normative parameters that could be adopted for determination of tariff for smaller capacity SRTPV plants .

B. Any other modification/change in the operational procedures that could be adopted for encouraging SRTPV installations.

C. Any other issue considered relevant.

With regard to the above, I submit below my suggestions and opinions on betterment of processes and procedures .

Tariff or Feed in Tariff :

 Scenario :

Most of our customers argue that feed in tariff is too low. The argument definitely has water. The fact is “BESCOM is buying power from the ‘rooftop solar’ owner at a much lower rate than what they are selling to them or other conumers”. That is, the current feed in tariff is rupees 3.56 per unit while the average selling price of BESCOM is well above rupees 5 or 6 a unit (or even more) . Also, there is no escalation clause in the power purchase agreement (PPA).

This is  an unfair proposition. On the other hand BESCOM revises its selling rate almost every year at an average rate of about 7 to 8 Percent year on year. In the net metering scenario, The SRTPV (solar rooftop photo-voltaic) consumer buys at a rate higher than the rate he sells power to BESCOM.

Given that any excess feed in from a SRTPV consumer is consumed within the radius of the distribution transformer or in most cases by the immediate neighbor, it will be prudent to assume minimum or nil T and D losses from the power generated from a SRTPV unit. So, a SRTPV owner is giving clean power to BESCOM with almost Nil T & D losses with capex coming in from the SRTPV Owner.

Not only that the SRTPV consumer and the installer goes around pillar to post for all the approvals and commissioning.

SUGGESTION:

• The details of the cost incurred by BESCOM for purchasing power is given in their website (https://bescom.org/2018-7/)
• As per the details available in the website, average cost incurred by BESCOM for purchasing power in the year of 2018 is as follows

Sl No	Month	PP Cost (INR/KWh)
1	Jul-18	₹ 5.42
2	Jun-18	₹ 5.73
3	May-18	₹ 5.51
4	Apr-18	₹ 5.23
5	Mar-18	₹ 4.67
6	Feb-18	₹ 4.98
7	Jan-18	₹ 4.82
	Avg	₹ 5.19

• Average power purchase cost by BESCOM is rupees 5.19 rupees per unit.
• At an inflation of 3% year on year, the cost of power purchase by BESCOM for the next 20 year will be as follows

YEAR	PP Cost (INR/KWh)
1	₹ 5.19
2	₹ 5.35
3	₹ 5.51
4	₹ 5.68
5	₹ 5.85
6	₹ 6.02
7	₹ 6.20
8	₹ 6.39
9	₹ 6.58
10	₹ 6.78
11	₹ 6.98
12	₹ 7.19
13	₹ 7.41
14	₹ 7.63
15	₹ 7.86
16	₹ 8.09
17	₹ 8.34
18	₹ 8.59
19	₹ 8.84
20	₹ 9.11
AVG	₹ 6.98

• So in the most optimistic of scenario , the average power purchase cost by BESCOM over the next 20 years will be rupees 6.98 a unit.
• Any consumer who wishes to install SRTPV will be a middle class consumer falling in the second or third slab or BESCOM tariff .
• Currently Bescom tariff varies from 3.5 rupees to 7.65 Rupees a unit depending on the tariff slab.
• Given that Solar is still an expensive proposition, it will be safe to assume that any person who wishes to install solar will fall in the middle slab say who pays an average cost of rupees 5 per unit of electricity.
• So in a scenario where the consumer does not have SRTPV unit in his premises, BESCOM is charging him or her rupees 5 a unit (This is a very safe assumption since most domestic consumer who can afford SRTPV units fall in the higher slabs) .
• In other words, BESCOM charges at a rate of 5 rupees per unit for any domestic consumer.
• At an escalation of 4% every year, the unit rate of BESCOM power for the domestic consumer is as follows .

YEAR	Tariff (INR/Kwh)
1	₹ 5.00
2	₹ 5.20
3	₹ 5.41
4	₹ 5.62
5	₹ 5.85
6	₹ 6.08
7	₹ 6.33
8	₹ 6.58
9	₹ 6.84
10	₹ 7.12
11	₹ 7.40
12	₹ 7.70
13	₹ 8.01
14	₹ 8.33
15	₹ 8.66
16	₹ 9.00
17	₹ 9.36
18	₹ 9.74
19	₹ 10.13
20	₹ 10.53
AVG	₹ 7.44

• So in a 20 year time scale scenario, assuming ambitious very little inflation, BESCOM is buying power from KPTCL , NTPC and others at rupees 6.98 a unit and selling to the consumer at 7.44 rupees a unit.
• So ideally, BESCOM must pay any producer of electricity a minimum of rupees 6.98 a unit.
• However, BESCOM would say that the SRTPV consumer is using the BESCOM infrastructure free of cost. This is however not true. In a NET metering scenario, BESCOM recovers the infrastructure costs as demand charges. So, notwithstanding SRTPV, the consumer is paying for the infrastructure. For example, with or without SRTPV a consumer having sanctioned load of 5 KW pays (1x50) + (4x60) = 290 rupees a month. This is also subject to revision every year.
• BESCOM recovers its T and D losses in the profit earned. In a SRTPV scenario, the SRTPV owner is giving good clean power at nil T and D.
• BESCOM however loses a paying consumer, so to be fair to BESCOM and to account for cross subsidy, rupees 1.25 or 125 paise per unit of electricity can be pegged to account for losing a paying customer and for cross subsidy.
• So Rationally, any SRTPV consumer injecting excess energy into grid must be paid a rational price of (698-125) = 573 paise a unit or rupees 5.73 a unit.
• Competitive tariff for SRTPV owners will also encourage more installations and at the same time bring pressure on KPC and other companies to reduce rates and increase efficiency. 

Ease of application and Approvals:

Every installer and every SRTPV consumer is irritated by long and lengthy procedures and series of approvals required for SRTPV installations. There is an urgent need for rationalization of processes.

Plenty of precious time is wasted waiting at BESCOM offices for concerned officials.

Suggestions :

• Bescom website gives a timeline for various approvals. But it is nowhere mentioned what must be done or what is the next step if the time line is not adhered to.
• As per BESCOM website, it says all SRTPV applications must be done Online Only. In that case, why is format 1 Still there in the website? BESCOM officials are insisting on format 1 inspite of applying online. Format 1 must be abolished.
• Submission of completion report (Format 5) must be made online. Submission to commissioning timeline must be strictly adhered to.
• If BESCOM officials find any deviation or discrepancy in installation, the same must be put up online within a time frame.
• The delay in commissioning (If any) after submission of work completion report (Format 5) must be documented and monitored.
• Hybrid inverter empaneled by BESCOM by name Studer has a different grid interconnection Topology. Many BESCOM officials are not accepting this grid interconnection Topology though the inverter is empaneled. This is causing many delays and cost and time overrun.
• Best is to have a single point of contact for all SRTPV approvals. That is notwithstanding the sub-division, there must be a single point of contact in BESCOM office for all SRTPV approvals.

Billing issue:

Almost all SRTPV consumers are having tough time with billing. Following are few of the major issues regarding billing :

• Most consumers are not receiving the SRTPV bills on time.
• Some consumers are not receiving bills for months together.
• Payment is not happening on time.
• Meter readers are unable to take the EXPORT and IMPORT readings.
• In Spite of installing SRTPV system, consumer is receiving normal bills with arbitrary readings.
• Meter reader is sometime confused with the check meter (Abolishing check meter is a welcome move by BESCOM )

Suggestions :

• BESCOM must pay interest if there is delay in payment or even delay in meter reading.
• Meter reading along with meter serial number must be available online for customer to cross check.
• Call center (1912) must also handle SRTPV complaints.
• ALL SRTPV bills must be only online.

NOTE :

Consumers who are putting their hard-earned money for SRTPV are in a way doing a great service to nation and environment. If they cannot be incentivised, at least they must not be troubled or harassed or made to run from pillar to post for billing issue. Their due must be paid on time.

sanctioned load issue:

• If a rational feed in tariff is determined, then there must not be any capping on Capacity of SRTPV installation.
• Overloading of distribution transformer will be taken care at the technical feasibility stage.
• But at the application stage for installations less than 10 KW, the consumer must be allowed to install SRTPV system greater than the sanctioned load. (If the distribution transformer is not capable of taking load, then the application will be rejected at the technical feasibility stage).
• If tariff policy is rational, BESCOM will not make a loss.

Roads are fine , users need more skill.

This year, in Bengaluru ,we have had one of the heaviest rainfall in the recent past . Time and again roads were converted into rivers . Many residents have had pathetic time negotiating rainwater rushing into their homes.

Poor planning and corrupt administration has been completely exposed by the condition of the roads .  Yet no one seems to be be held accountable for the condition of the pathetic roads. Motorists and pedestrians are having a tough time commuting in bengaluru and yet no civic body has assured any help and no authority or no person is held responsible for the chaos on the city roads .

Over the years, i have made hundreds of representations to civic authorities (BBMP) and elected representatives (From corporators to MLA) . Have met commissioners , Mayors. MPs, MLA and even two chief ministers . One common thing among every person in authority is that they are all ever busy and no one is responsible (neither a solution) for the problem at hand.

No person in authority wants to talk about the problem at hand.  The political authority blames on bureaucratic authorities and vice versa.

Take the case of a pothole on the road. To start with, if the authorities had done their job properly and if they were competent enough, there should not have been any pothole in the first place . But as it stands today, Bengaluru roads has 30,000 potholes on record.  It is shameful on the authorities to have actually given out such a number. Looks like they are proud to publish their inefficiency and incompetency.  75 years of independence and we cannot lay a 1 km of pothole free road. Yet what is important today is beef and not roads.

Coming back to potholes on roads , On the bureaucratic side there are the following people responsible to either have laid a better road or at least fix the damage.  It starts from the ward engineer, You have a junior engineer, Then you have the Assistant engineer, You have the assistant executive engineer, Then comes executive engineer, Then is the superinedentent engineer, On top comes a chief engineer, On top of him is Engineer in chief. Parallel to these people there is Executive engineer (Road works), Executive engineer (Major roads). On top of all these people comes the steel frame of the administration It starts from the assistant commissioner , Then is the Deputy commissioner, on top of him is the additional commissioner, Then we have Joint commisioner, Then is the special commissioner and on top is the commissioner. Over all these commisoners sits the development commissoner , with him sits the joint secretary (Urban development), with him is the additional secretary (Urban development), Over them sits the Secretary (Urban development). On him sits the additional chief secretary and top of them all sits the Chief secretary.  Technically this line can be extended to secretaries in the union government as well all the way till cabinet secretary. All of them have the authority but none of them are accountable , answerable and not even accessible.

Coming to political side , the line of responsibility and accountability starts from the corporator or the councillor of the area, then comes the MLA, The mayor of the city , Then is the MP, Then is the urban development minister and on top of all sits the chief minister . Technically this can be extended all the way till PM. Again all of them have the authority but none of them are accountable , answerable and not even accessible.

Ask any of the above people on who is responsible for the pathetic condition of the Benagluru roads , the unanimous answer will be “NOT ME”. All the above authorities get the best cars, get drivers, fat pay , carry the best phone, Have personal secretaries and so on but no one is accountable nor answerable. According to the present system and the so called rank and file of our administrative set up no one in the above set of authorities is responsible for the pathetic roads in the city. If by your misfortune you end up hurting yourself or others while doing the misadventure of riding on the city roads, you are a negligent driver but the road is world class.

One set of political leadership is busy with pleasing their bosses in the center and the other class is busy worshipping their leader. Misplaced priorities has been the hallmark of the indian political system over the last two decades. Present leadership is more about PR and creating controversies than any real ground work. Unseen Ram (I am sure he does not need a temple), beef , celebrating birthdays of freedom fighters is more important than nutrition, roads and hygiene.

Go to the bureaucratic authorities. You must be lucky to find one in the first place . Everyone is very busy but no one is answerable . from top to bottom there is “Sahebru” attitude and status quo is the most favorite passion and perhaps duty of the almost all concerned.

Worst is even disheartening . Elected representatives and civic authorities have gone on rounds in the city and uploading pictures of their inspection of the damage. Some of the comments they have received on their pages are “We are proud of you”, “True leader”, “We need people like you”. Come on , are we any kind of elite democracy ? These are the exact people responsible for the mess and we are here glorifying them just because they had the courtesy of atleast seeing the damage.

The poor citizen is just caught up in this mess . The poor citizen has to just increase his prayers before stepping out of the house . May be the combined effort of our civic authorities and elite politicians has increased the citizen’s faith in God.  Perhaps the only other vent for the anguished motorist is his fellow motorist with whom he can pick up a fight and vent out his anger.

Culture or lack of it !

Last month , myself and couple of my friends were on a road trip across many places inIndia. We covered 5800 Kms in 9 days across 10 states and 2 union territories. We started from Bengaluru and drove up to chandigarh touching the western ghats, , the Vindhyas and the Aravallis. We covered lengths of Karnataka, Maharashtra, Gujarat, Rajasthan, Haryana and the union territory of Dadra and nagar haveli to reach Chandigarh. On the return journey , we touched Delhi, UP, MP, Maharashtra, Telangana, AP and reached back to Bengaluru.

It was a memorable trip. We saw some of the cleanest and filthiest parts of India. We Saw the best and worst roads of the country. We had a chance to taste plethora of delicacies from from chikkis of Lonavala to sweets of Gujrat, Amazing lassi of Rajasthan, parathas of chandigarh, chats of delhi to spicy food of Andhra.

This was my second road trip almost in the same route . One lifetime will be insufficient to understand the diversity of this country . Our country is amazing in more than one ways . One such thing is our culture . Though the country boasts of a very rich history and culture , people of my generation will not always find it to be always true.

One such trait in our culture is the culture of cleanliness. Again in this trip, we saw Chandigarh, arguably the cleanest part of India and also saw Ajmer and jabalpur, perhaps one of the filthiest parts of the country.

Swachh bharat is a much talked and much hyped national program by the current central government. Notwithstanding the initiatives of the government , it is the primary duty of every citizen in the country to keep the county clean. In our childhood, we were taught in school that “cleanliness is godliness”. In my opinion, keeping the country clean must be included as a “fundamental duty” in the constitution .

The least we can do to keep the country clean is at least keep our heritage sites, our monuments , our places of worship clean.

In this trip, we had been to India gate in New Delhi. This monument is a mark of respect to all our soldiers who have sacrificed their life in line of duty. India gate is in the heart of New delhi, about 1 KM away from the Indian parliament, the seat of power . It is from this parliament ;mission “Swacch Bharat” was launched. Our PM Narendra modi , one of his pet projects being Swachh Bharat sits in this very Parliament house.

It is painful to see the plight of India gate. It is used as a picnic spot. Numerous street vendors crowd the place. In-spite of dustbins provided , most people throw trash on the lawns, roads and the water bodies.  Paper cups, chips packets, Pani puri plates etc are to be seen everywhere around India gate.

The least we can do to our soldiers is to atleast keep an emblem built in their respect clean. It is an irony that our PM who launched this Swachh Bharat mission sits just one KM from this iconic structure.

Me and my friends started cleaning up the place. My friend avinash was in deep knee pain . Inspite of the pain, he started picking up paper cups and ice cream candies. We went around picking up bits and pieces. We were hopeful that some people may join us . To our surprise, not a single person joined us. We just went about our job. There were hundreds of people around,  not one joined us. Some were passing comments while few were supervising us.

Then came the most disgusting part. One gentleman walking with his wife and little daughter passed by us and threw his tea cup right in front of me. He had no sense of shame or guilt. Perhaps he did not notice that we were cleaning. When i picked up his cup, he did say sorry. But the point here is not about saying sorry. He just thought it is ok to throw the cup on the lawn.

Strange country , we are !! We are spending thousands of crores on clean India mission while many people just do not bother to put the trash in the dustbin just a few yards away.

It is just the sheer ignorance and disrespect to the country and fellow countrymen that drives some people not to care . Not sure what the solution for this is but i feel that this attitude is deeply ingrained in our culture.

Few days later, we move south and come to the district of Chandrapur in Central india located in one of the most backward regions of India, Vidarbha.

Vidarbha is in the news for all the wrong reasons and is one of the driest and poorest regions of the country .

We had a chance to interact with a few students of Sardar patel Mahavidyalaya in  chandrapur.  My friend Avinash was to deliver a talk there. Experience in this college was totally different.

We were greeted not by flowers or bouquets but by living flowering plants.  We were shown the campus and introduced to many activities taken up by the students of the college.

We drove past a beautiful lake called Ramala lake before reaching the college. We were wondering how the lake was so clean in a particularly dirty town. Just before arriving at chandrapur, we visited nagpur and the lake experience in Nagpur was not at all great. So we did not have high hopes on Chandrapur. But the Ramala lake was a totally different story.

The students of this college had made numerous petitions to the town administrations to desilt and clean the lake. When their petitions did not work, they took the task on themselves. Students made groups and started cleaning the lake and de-weeding the catchment . They formed groups and stood at the lakes during the immersion of Ganesha Idols and directed the devotees to the designated place for immersion . They have planted numerous trees around the lake.

Inspired and probably ashamed from the students, the town administration finally have started maintaining the lake.

Few students shared their experience in their efforts. Apparently locals did not help them but instead ridiculed them. Local residents did not come to their help. In Spite of this the students used to show up daily and clean the lake and the surroundings .

Every student in this college has a mandate to plant one tree and maintain it for three years. They have a green council among the students which looks into various green initiatives in the college campus.

India is a land of dichotomies and diversity.  Perhaps it is this dichotomy and diversity that makes this land so interesting.  However there are many practices and behaviour which are ingrained in the cultural fabric of this land that just refuses to change, cleanliness being one.

Swacch Bharat, Clean India ,all these are really good and must be appreciated, respected and followed. But these missions do not succeed very well if there is still a medieval mindset among the people of the country.

It is not the laws that govern the country. It is the people who govern the country.  Country cannot be governed by law “enforcement”, it can only be governed and cleaned when law is “respected”.

Winds of change are blowing swifty , let us hope it touches as many of us as possible.

Happy Independence Day !!

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