CUTS International

COMMENTS AND SUGGESTIONS ON THE PROPOSED DRAFT Rajasthan Electricity Regulatory Commission (Distribution Licensees Standards of Performance) Regulations, 2012 1. In reference to Clause 2, Quality of Power Supply, of Schedule 1 under the Guaranteed Standards of Performance regulation, of the licensee, which are the guaranteed standards of service for its consumers : The clause can be modified to include consumer complaints in respect of Harmonics 1. Licensee shall monitor harmonics at regular interval at strategic points in aspects of high tension (HT) consumers, shall be measured by the licensee, which it considers prone to harmonic voltage generation and ask the user to comply with the specified standards. The harmonic currents drawn by various consumers should be measured and its records should be maintained. Licensee should also measure the level of harmonics generation of any customer on receipt of complaint from other affected consumer(s).

2. The notified Complaint Handling Mechanism regulation can be modified to read as Handling of Complaints. This is in accordance with the need for a clause, under this regulation, on obligating the licensee to hold regular (monthly) grievance redressal meetings with consumers. These meetings should be open to all consumers. The consumers can also register their complaints in these meetings. The chair, agenda, schedule and venue of the same should be clearly listed in the Standards of Performance Regulations. There is a need for a process chart that can list the time-frame for the resolving the complaint and the various stages thereof. The Manual for Handling Consumer Complaints, its contents and availability need to be publicized through suitable public platforms, in order for its intended benefits and welfare to reach the end-consumers. The publishing of the manual in the native language of the state, so as to benefit the semi-urban and rural population of the state, should also be considered.

3. The Clause 3.4 on distribution Reliability Indices, under the Overall Standards of Performance regulation should be modified to include the Customer Average Interruption Duration Index (CAIDI) formula. It is indicative of and stands for average interruption duration of sustained interruptions for those consumers who
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Harmonics are a distortion of the normal electrical current waveform, generally transmitted by nonlinear loads like variable speed motors and drives, photocopiers, personal computers, laser printers, fax machines, battery chargers and UPSs. The distortion travels back into the power source and can affect other equipment connected to the same source. Most power systems can accommodate a certain level of harmonic currents but will experience problems when harmonics become a significant component of the overall load.

experienced interruptions during the reporting period, determined by dividing the sum of all sustained consumer interruption durations, in minutes, by the total number of interrupted consumers for the reporting period. It can be calculated by using the following equation: CAIDI = SAIDI / SAIFI 4. Schedule -2 under the Payment of Compensation regulation lists various compensation amounts that o the individual/consumer is entitled to in case of violation of minimum Standards of Performance by the licensee. These amounts are levied on a weekly basis as per the draft regulations. Keeping in mind the importance and vitality of the subject here (Electricity), the compensation should be levied on a daily basis, or the compensation amount has to be substantial enough, in order for it to reflect the real and potential losses to the consumer and for it to act deterrent for delays in complaint redressal.

5. The Standards of Performance Regulations should introduce a regulation on Safety. This regulation should list clause(s) pertaining to construction, operation and maintenance of the distribution lines, to take all necessary actions to spread awareness among the consumers for safe usage of the electricity and to provide grounding for the equipment and lines and earthing grid for substations, in accordance with Code of Practice for Earthing. The Licensee shall take necessary steps to measure leakage current at various points in the system. It is also suggested that records of all the fatal electrocution accidents be maintained along with the investigation report with an electrical inspector.

6. The Standards of Performance regulations should also incorporate a regulation on Temporary Electricity Supply. It would facilitate consumers that may require temporary services for construction of residential houses, complexes, commercial complexes, industrial premises, etc.