KESC/CPPA, Transparency In Electricity Affairs.

See my previous post on KESC petition for the thread.

1. 
   At this moment,we notice NEPRA activity wrt new projects and Discos petitions.In Discos petitions NEPRA is apparently occupied only with distribution margin and PPP increase.DM constituting less than 10% of the average sales rate , the major componenet PPP is taken without contest or review. At least it is not in public domain.
   


2. 
   There are several problems and issues with PPP/CPPA. The purpose of common pool of CPPA apparently was to build a uniform price.We are not in a regionally differentiated price regime. All primary energies and many commodities are subject to inland freight equalising margin regime.But CPPA bills different prices to different Discos.Most objectionable, apparently, is higher CPPA rates to the politically sensitive areas of PESCO and QUESCO, from where cheaper hydro electricity and gas is supplied.That it is finally mitigated with higher subsidies is a rather comic and strange excercise. Often uninformed public is misguided by higher CPPA prices by politicians having seperatist agenda.
   


3. 
   CPPA's workings are strangely enough , as it appears, not under NEPRA's review.If this is true , it is a compromise of NEPRA's role and responsibility. It would not be appropriate to assume that most or all of IPP's tarriff has been awarded before NEPRA's establishment.Annual payments to IPPs require a lot of adjudication. Usually there are many grey areas and variables ie.,availability, dispatch, fuel consumption, heat rates .these should be subject to NEPRA's oversight and review. If IPPs and Gencos are exempt then , Discos should also be exempt especially their monthly adjustment which requires a mechanical application of PPP increase and adjustment and no more. Of CPPA, nothing appears to be under public domain. If there is a beauracratic ruling on this ,there should be a judicial review of such restriction on regulatory oversight.Who will bell the cat?
   


4. 
   KESC has booked a lot of electricity purchases from PASMIC , KANUPP and IPPs . No proceedings have been noticed of NEPRA tarriff award for these organistaions.Is KESC bilaterally negotiating the price? It is an accepted regulatory practice that alll electricity purchases that go into regulated price , are also subject to regulatory review.In my earlier comments , I have proposed to route all third party purchases through CPPA with latters' uniform basket price.
   


5. 
   Finally your information/transparency policy is not implemented uniformly.Petitions are often placed on your website after the decision has been made.However, KESC petition has been placed before hearing/ decision.AES/ imported coal project petition was not put on your website , and a copy was not e mailed to me despite my several requests to your department.There is a requirement of payment of Rs. 5/ hard copy. This puts the non- Islamabad residents into a lot of inconvenience and disadvantage as expensive and inconvenient banking processes are involved.This condition is an invisible barrier to transparency.Please reconsider your policy and publish petitions before hearing on a uniform basis.