BEFORE THE KERALA STATE ELECTRICITY REGULATORY COMMISSION

Transcription

1 BEFORE THE KERALA STATE ELECTRICITY REGULATORY COMMISSION IN THE MATTER OF: Review of the KSERC Order dated on Rationalisation of ToD Tariff for HT-EHT consumers. And IN THE MATTER OF: Kerala State Electricity Board Vydyuthi Bhavanam, Pattom, Thiruvananthapuram The petitioner named above respectfully submits as under: 1. Hon ble Commission vide the order dated on ARR &ERC of KSEB for the year had directed KSEB to file a proposal on rationalization of ToD tariffs for the HT-EHT consumers within two months from the date of the order. Accordingly, KSEB vide its petition dated had proposed a simple procedure for ToD tariff as against the then prevailing ToD tariff structure. The summary of the proposal is detailed below. (a) Demand and Energy charges during peak time as 140% and 130% respectively of the normal time charges (b) Demand and Energy charges during off-peak time as 85% and 90% of the normal time charges (c) Excess demand charges for billing demand exceeding contract demand is proposed as 100% on the normal demand charges. While making the proposal, KSEB had made a study on the proposed ToD tariff with the actual zone wise consumption for the year and 1

2 made to ensure that, either KSEB or consumers would not earn any extra benefit through the change in the ToD revision proposal. The details of the study report was also furnished before the Hon ble Commission during the proceedings of the petition on rationalization of tariff. 2. Hon ble Commission vide the order dated 2 nd December-2009 on petition TP No. 66 of 2009 had revised the TOD tariff for HT-EHT consumers with certain modifications as detailed below. Particlars Table-1. Comparison of the ToD tariff proposed by KSEB and approved KSERC Rates proposed by KSEB Rates approved by KSERC (% of Ruling Charges) (% of Ruling Charges) Peak period Normal Off peak period Peak period (22:00 hrs (18:00 hrs to (6:00 hrs (18:00 hrs to to 6:00 22:00 hrs) to 18:00 22:00 Hrs) hrs) Normal period (6:00 hrs to 18:00 hrs) Off peak (22:00 hrs to 6:00 hrs) hrs) Demand Charges 100% 140% 85% 100% 140% 80% Energy Charges 100% 130% 90% 100% 130% 85% Hon ble Commission has allowed the reduced off-peak demand charges for the excess demand during off-peak period up to 130% of the Contract Demand (CD) as against 120% of the CD prevalent as per the pre-revised tariff. Further, the rate of penalty when the billing demand exceeds the Contract Demand (CD) is allowed at 50% of the normal demand charge as against 100% proposed by the Board in view of the provision in the Electricity Act-2003 for unauthorized use of Electricity. 3. As detailed above, Hon ble Commission had allowed a reduction of 5% on the demand and energy charge during off-peak hours from the rates proposed by KSEB. Hon ble Commission had also enhanced the limit of excess demand at incentivised tariff during off-peak hours from 120% of the CD to 130%. Further, the penalty for excess demand charges had 2

3 reduced to 50% of the normal demand charges against 100% as proposed by the Board based on the provisions in the Electricity Act As directed by the Hon ble Commission, KSEB had implemented the revised the ToD tariff from Jan-2010 onwards. On account of the revised ToD tariff as ordered by the Hon ble Commission, KSEB has a substantial revenue loss since the month of Jan The details are given below. Tariff Category Jan-2010 Table-2. Comparison on the shortfall in revenue due to the revised ToD tariff No of consumers Prerevised tariff Demand Charge As per KSERC order Revenue short fall Percentage of reduction Prerevised tariff As per KSERC order Energy Charge Revenue short fall Percentage of reduction Total reduction Total reduction (Rs.Cr) (Rs.Cr) (Rs.Cr) (%) (Rs.Cr) (Rs.Cr) (Rs.Cr) (%) (Rs.Cr) (%) EHT (I & II) EHT PI HT I HT II HT I PI HT IV Total Feb-2010 EHT (I & II) EHT PI HT I HT II HT I PI HT IV Total Mar-10 EHT (I & II) HT I HT II HT I PI HT IV Total Total for 3 months As detailed above, KSEB had a total reduction of about 4% on the revenue by implementing the tariff order dated 2 nd December-2009 of the Hon ble Commission. But, had the Hon ble Commission approved the 3

4 TOD tariff as proposed by the Board, the financial impact on KSEB would have been neutral. 6. Based on the KSERC order dated 2 nd December-2009, Hon ble Commission vide the letter No. KSERC/III/ T&C of supply/2010/ 138 dated had forwarded the approved Schedule of Tariff and Terms and Conditions for retail supply by KSEB w.e.f In the schedule of Tariff approved, Hon ble Commission had allowed an additional incentive in tariff during off-peak period through granting 80% of the normal demand charge for the entire off-peak demand disregarding the ceiling limit of 130% of the CD as per the order dated 2 nd December As per order dated , if the off-peak billing demand of a consumer exceeds 130% of the CD, the excess demand over 130% of the CD is allowed to charge at the normal demand charge plus of 50% of the normal charge as excess demand charge. But as per the schedule of tariff approved, even when the off-peak billing demand exceeds 130% of the CD, the entire billing demand is allowed to charge at the reduced tariff of 80% of the normal demand charge. KSEB vide its letter dated had brought this discrepancy before the Hon ble Commission for making suitable amendments. But, Hon ble Commission vide the letter No. KSERC/III/ T&C of Supply/2010/339 dated communicated that, appropriate modifications in the billing procedures can be made after assessing the revenue implications, impact of load shifting etc as per the study report of KSEB on the revised ToD tariff. 7. Further, Hon ble Commission had made certain changes in the billing procedures for excess demand charges proposed by KSEB. A comparison of the billing procedures for excess demand charges proposed by KSEB and the same approved by KSERC is given below. 4

5 Table-3. Comparison of the billing procedures proposed by KSEB and approved by Hon ble Commission for charging excess demand KSEB proposal KSERC approval Demand Charge in each time zones (a) in Time Zone (T1), Dc1 = BMD1 x D x (12/24) (b) in Time Zone (T2), Dc2 = BMD2 x D x 1.4 (4/24) (c) in Time Zone (T3), Dc3* = BMD3 x D x 0.80 x (8/24) (*Incentive is applicable for excess demand only upto 30% of the CD during time zone- T3) Excess Demand Charges in each time zone (a) in Time Zone (T1), Ed1 = (RMD1-CD) x 0.5x D (b) in Time Zone (T2), Ed2 = (RMD2-CD) x 0.5x D (c) in Time Zone (T3), Ed3 = (RMD x CD)x1.5x D (d) Total Excess Demand Charge (ED) = Ed1+Ed2+Ed3 Demand Charge in each time zones (a) in Time Zone (T1), Dc1 = BMD1 x D x (12/24) (b) in Time Zone (T2), Dc2 = BMD2 x D x 1.4 (4/24) (c) in Time Zone (T3), Dc3 = BMD3 x D x 0.80 x (8/24) Excess Demand for HT& EHT consumers in each time zone shall be (a) in Time Zone (T1), Ed1 = (RMD1-CD) (b) in Time Zone (T2), Ed2 = (RMD2-CD) (c) in Time Zone (T3), Ed3 = {RMD3-(1.30 x CD)} Total Excess Demand Charge (ED) = Excess demand Ed1, ED2 or ED3 whichever is higher x 0.5 x D Hon ble Commission may kindly note that, KSEB had proposed the revision in ToD tariff with the prime objective of reducing the peak demand by shifting the same to off-peak period. Accordingly, as per the the billing procedures proposed, KSEB had proposed to impose penalty for excess demand for the three time zones separately as follows. (a) Excess demand charges may be charged for normal time and peak time when the billing demand exceeds Contract Demand and (b) Excess demand charges during off-peak period may be charged when the billing demand exceeds 1.30 x CD. However, as per the billing procedures approved by the Hon ble Commission as detailed above, the excess demand charges can be claimed only for one of the three time zones- normal, peak or off-peak hours. As per the approved billing procedures, even though there is excess demand during peak hours/ normal time and if there is more increase in excess demand during off-peak hours, the consumers will not 5

6 be liable to pay any excess demand charges for the excess consumption during normal/ peak period. This will over shadow the basic purpose of ToD structure motivating the consumers to reduce the demand during peak and day time. This anomaly is also need to be corrected. Month Study on the load shifting due to the revised ToD tariff (a) Pattern of Energy consumption of HT&EHT consumers 8. KSEB had analyzed the time zone wise energy consumption of HT & EHT consumers for the months of December-2009 to March-2010 with the same during the previous year and A comparison of the zone wise consumption for EHT1, EHT2 and HT consumers for the months of Dec to March for the years , and are given as Annexure-1, Annexure-2 and Annexure-3. The time zone wise consumption of EHT1, EHT2 and HT categories of consumers as a percentage of total consumption for the months of December to March for the years to is given in the following table. Table-4. Comparison of time zone wise energy consumption of HT&EHT consumers Normal Time (% of EHT1 EHT2 HT category Off-peak Normal Peak Off-peak Normal Peak time Time Time time Time Time Peak Time (% of (% of (% of (% of (% of (% of (% of Off-peak time (% of Dec Dec Dec Jan Jan Jan Feb Feb Feb Mar Mar Mar Graphical representation of the time zone wise energy consumption of EHT1, EHT2 and HT categories are given in the following charts. 6

7 C hart - 1 EHT1- Category ( Zo ne wise energy co nsump t ion- as p ercent ag e of t ot al) Of f -peak time Peak Time Nor mal Time Dec-07 Dec-08 Dec-09 Jan-08 Jan-09 Jan-10 Feb-08 Feb-09 Feb-10 Mar -08 Mar -09 Mar -10 M ont h C hart - 2 EH T 2- C atego ry ( Zo ne wise Energy C o nsump t io n- as p ercent age o f t ot al) Off -peak Peak Time Nor mal Time Dec-07 Dec-08 Dec-09 Jan-08 Jan-09 Jan-10 Feb-08 Feb-09 Feb-10 Mar -08 Mar -09 Mar -10 M ont h 7

8 Chart-3 HT Category (Zone w ise energy consumption- as a percentage of Energy consumption (percentage of Off-peak Peak time Normal Time 0.00 Dec- 07 Dec- 08 Dec- 09 Jan- 08 Jan- 09 Jan- 10 Feb- 08 Feb- 09 Feb- 10 Mar- 08 Mar- 09 Mar- 10 Month 10. It can be observed from the above Table-4 and charts-1 to 3 that, during the period from December to March for the years to , the peak consumption of EHT1 categories varies between 14.60% to 15.88% of the total consumption, EHT2 category varies between 13.54% to 15.11% and that of HT categories varies between 11.34% to 13.58%. It is also observed that, even after the revised ToD tariff, there was no appreciable change or shift in the consumption pattern of the EHT and HT categories of consumers. Accordingly, KSEB did not have any benefit through reduction in peak consumption as the consumers did not shift the demand from peak to off-peak period. Changes in the daily load pattern of KSEB system 11. KSEB had studied the system load after the implementation of the revised ToD tariff. The variation of average daily load curve of the KSEB system for the months of Jan-10 to Mar-10 with that of the 8

9 corresponding months of the previous years and were studied in detail. The average daily load curve for the months of January, February and March for the years and and is given below. Chart-4 Daily Load Curve for the month of January Jan-08 Jan-09 Jan T ime ( Hour s) Chart-5 Daily Load Curve for the month of February Feb-08 Feb-09 Feb Time ( 1/ 2 hour ) 9

10 Chart-6 Daily Load Curve for the month of March Mar-08 Mar-09 Mar Ti me ( H r s) Chart-7 Daily Load Curve- Dec-09, Jan to Mar Jan-10 Feb-10 Mar-10 Dec Time ( hours) 10

11 12. Hon ble Commission may please note that, there was no appreciable shift of peak demand to the off-peak or variation in daily load curve after revising the TOD tariff w.e.f The month over month variation in load curve is only on account of the increase in energy demand. It may also be noted that, due to the power restrictions during the year , KSEB was able to contain the system demand during normal and off-peak time for the month of January and February 2009 as that of the previous year. 13. From the above studies, it is concluded that there was no appreciable change in the consumption pattern of the HT&EHT consumers after implementing the revised ToD tariff w.e.f January Further, KSEB has also not experienced any reduction in the peak demand by way of shifting a part of the peak demand to the off-peak demand, but the tariff modification initiated by the Hon ble Commissions has only resulted in passing on huge unnecessary benefit to HT&EHT consumers at the cost of KSEB. Hence, considering the huge revenue reduction of about 4% from pre-revised tariff, KSEB may request before the Hon ble Commission to suitably modify the present TOD tariff as proposed by KSEB through the earlier petition TP 66 of 2009 or retain the pre-revised ToD, simultaneously taking suitable measures to recoup the losses from the same set of consumers. 14. The impact of the revised ToD tariff on KSEB is summarized as: (i) KSEB had incurred a total revenue loss of Rs crore for three months from January-2010 to March-2010 on account of revised ToD tariff as per the KSERC order dated (ii) The monthly revenue short fall was about 4% on the total revenue at the pre-revised rates. 11

12 (iii) (iv) The HT&EHT consumers of the State has not made any change in the consumption pattern after implementing the revised ToD tariff w.e.f January KSEB has not been benefited with any appreciable reduction in peak demand by way of shifting a part of the peak demand to offpeak period. Prayer KSEB humbly prayed before the Hon ble Commission that: Considering the huge financial loss on account of the revised TOD tariff and also considering the fact that there was no appreciable system benefit on KSEB due to the revised ToD tariff, Hon ble Commission may either: (i) Restore the pre-revised ToD tariff which was continued till December-2009 OR (ii) Approved the ToD tariff structure as proposed by KSEB vide its Petition No. TP No. 66 of 2009 on rationalization of KSEB tariff. (iii) Issue appropriate orders by the Hon ble Commission to recoup the losses already incurred by KSEB, from the same set of consumers. Chief Engineer (Commercial & Tariff) 12

13 Annexure-3 Month wise energy consumption details of HT Category (units) December-07 December-08 December-09 January-08 January-09 HT I Zone-A Zone-B Zone-C Zone-A Zone-B Zone-C Zone-A Zone-B Zone-C Zone-A Zone-B Zone-C Zone-A Zone-B Zone-C 4/4129 A.C. POLYMER INDUSTRIES HT I /154 A.P. STEEL RE-ROLLING MILLS HT I /419 ACHOOR ESTATE HT I /4577 ACTIVE CHARS PVT LTD HT I /3314 AGROWOOD ANDAMAN TIMBER INDUSTRIES HT I /1331 AHAMMED ROLLER FLOUR MILLS (P)LTD HT I /3752 AISWARYA STEELS PVT. LTD. HT I /4279 AKAY FLAVOURS & AROMATICS PVT. LTD. HT I /2667 AKAY FLAVOURS AND AROMATICS LTD HT I /3999 AKG MEMORIAL PRINTING& PUBLG CO (P) LTD, HT I /4508 AL AMEEN CRUSHER HT I /712 ALAGAPPA TEXTILES LTD. (NTC) HT I /530 ALAMPALLY BROTHERS LTD HT I /4566 ALLEPPEY COMPANY LTD HT I /4526 ALLEPPEY LATEX (P) LTD. HT I /3561 ALLEPPY CO-OP SPINNING MILLS LTD HT I /1958 ALLIANCE GRAIN PRODUCTS (P) LTD HT I /3482 AL-MADEENA GRANITE METAL& CEMENT FACTORY HT I /3873 ALPHS VENEERS,TALAPADY HT I /4307 ALWAYE METALS & ALLOYS PVT LIMITED HT I /2114 ALWAYE RUBEX (P) LTD HT I /2034 ALWAYE TECHNO RUBBERS HT I /621 AMBANAD ESTATE HT I /3728 AMRUT DISTILLERIES LTD. HT I /2858 ANAND OIL & EXTRACTIONS LTD. HT I /1420 ANAND WATER METER MFG CO (27/14/1420) HT I /4557 ANNS IND FLAVOURS HT I /414 ARAPETTA ESTATE HT I /3941 ARCH PLY N BOARDS HT I /3391 ARIKKAT OIL INDUSTRIES HT I /4183 ARJUNA NATURAL EXTRACTS LTD. HT I /1551 ARKAY ARC INDUSTRIES HT I /1038 ARNAKAL ESTATE HT I /4313 ARYA VAIDYA PHARMACY(COIMBATORE) LTD HT I /4042 ASHIQUE CHEMICALS AND COSMETICS HT I /3277 ASHIQUE EXPORTS (P) LTD HT I /3117 ASPINWAL (TRAVANCORE) LTD HT I /1361 AVT NATURAL PRODUCTS LTD HT I /518 BALIAPATTAM TILE WORKS HT I /4645 BENZY FOODS AND BEVERAGES PVT LTD HT I /3419 BERTECH (P) LTD HT I /2625 BEST BRICKS & TILES HT I /4124 BEST GRANITES, KOTHACHIRA HT I /4604 BEST READY MIX HT I /3430 BETA GRANITE PVT LTD HT I /2946 BHARATHY RUBBER INDUSTRIES HT I /3533 BHAVANI TEA & PRODUCE CO. LTD. HT I /1512 BINANI INDUSTRIES(P)LTD HT I /3913 BODY GEAR INTERNATIONAL (PVT) LTD HT I /718 BOYCE ESTATE HT I Page1/6

14 Annexure-3 Month wise energy consumption details of HT Category (units) December-07 December-08 December-09 January-08 January-09 HT I Zone-A Zone-B Zone-C Zone-A Zone-B Zone-C Zone-A Zone-B Zone-C Zone-A Zone-B Zone-C Zone-A Zone-B Zone-C 26/2639 BPL INDIA LTD HT I /904 BPL LIMITTED HT I /2640 BPL SYSTEMS & PROJECTS LTD HT I /4480 BRAHMINS ENTERPRISES HT I /2815 BRISTOL BOATS HT I /1934 BROTHERS RUBBER MILLS HT I /1025 CALICUT TILE CO. HT I /450 CALIFER POLYMERS (P) LTD HT I /641 CANARA PAPER MILLS LTD. HT I /515 CANNANORE CO-OPERATIVE SPINNING MILLS HT I /3994 CHAKKIATH MOODA AGRO PRODUCTS HT I /3283 CHAKKIATH MOODA EXTRACTIONS HT I /523 CHANDANAPALLY ESTATE HT I /510 CHANDRAMALAI ESTATE HT I /3632 CHARANKATTU COIR MFG. CO. (P) LTD HT I /3382 CHEERAMALIL EXTRUSIONS (P) LTD HT I /422 CHEMBRA PEAK ESTATE HT I /1607 CHIDAMBARAM TEA ESTATE HT I /4055 CHINTHA PRINTING & PUBLISHING CO PVT LTD HT I /3524 CHIRACKAL AGRO MILLS HT I /3992 CHIRAYINKEEZHU-ANJENGO COIR MATS&MATTING HT I /4213 CHLOROPLAST HT I /420 CHULLIKA ESTATE HT I /415 CHUNDALE ESTATE HT I /2262 COCHIN CEMENTS LTD (31/22/2262) HT I /3306 COCHIN KAGAS LTD HT I /3948 COCHIN KAGAZ LTD. UNIT-II HT I /3272 COCHIN MALABAR ESTATES&INDUSTRIES(31/22) HT I /1856 COCHIN MINERALS & RUTILE LTD HT I /3610 COCHIN RECLAIMS & TREAD RUBBER PVT. LTD. HT I /2332 COMMON FACILITY SERVICE CENTRE HT I /1020 COMMONWEALTH TILES, FEROKE HT I /336 CO-OPERATIVE SPINNING MILLS,KOLLAM HT I /4191 CO-RUBBER CRUMB FACTORY HT I /4320 CRESCENT CEMENTS HT I /552 CRESCENT CRUMB (P) LTD HT I /535 CRUMB RUBBER FACTORY (KCRMF) HT I /4040 D.C MILLS PVT LTD, PATHIRAPPALLY HT I /3574 D.C. BOOKS HT I /3742 D.C.MILLS HT I /3278 DANSON MOULDS (P) LTD. HT I /3411 DC MILLS (P) LTD HT I /5178 DELTA GRANITES & SAND HT I /4157 DESHABHIMANI PRINTING&PUBLSHG. HOUSE LTD HT I /4574 DETILISH RUGS HT I /4598 DIMESCO FOOT CARE INDIA (P) LTD. HT I /4365 DIVINE GASES PVT.LTD HT I /2419 DUROFLEX COIR INDUSTRIES (P) LTD HT I /4605 DYNAMIC TECHNO MEDICALS PVT. LTD. HT I Page2/6

15 Annexure-3 Month wise energy consumption details of HT Category (units) HT I 4/4129 A.C. POLYMER INDUSTRIES HT I 1/154 A.P. STEEL RE-ROLLING MILLS HT I 4/419 ACHOOR ESTATE HT I 7/4577 ACTIVE CHARS PVT LTD HT I 31/3314 AGROWOOD ANDAMAN TIMBER INDUSTRIES HT I 13/1331 AHAMMED ROLLER FLOUR MILLS (P)LTD HT I 7/3752 AISWARYA STEELS PVT. LTD. HT I 19/4279 AKAY FLAVOURS & AROMATICS PVT. LTD. HT I 26/2667 AKAY FLAVOURS AND AROMATICS LTD HT I 10/3999 AKG MEMORIAL PRINTING& PUBLG CO (P) LTD, HT I 29/4508 AL AMEEN CRUSHER HT I 7/712 ALAGAPPA TEXTILES LTD. (NTC) HT I 5/530 ALAMPALLY BROTHERS LTD HT I 31/4566 ALLEPPEY COMPANY LTD HT I 25/4526 ALLEPPEY LATEX (P) LTD. HT I 2/3561 ALLEPPY CO-OP SPINNING MILLS LTD HT I 15/1958 ALLIANCE GRAIN PRODUCTS (P) LTD HT I 32/3482 AL-MADEENA GRANITE METAL& CEMENT FACTORY HT I 9/3873 ALPHS VENEERS,TALAPADY HT I 8/4307 ALWAYE METALS & ALLOYS PVT LIMITED HT I 21/2114 ALWAYE RUBEX (P) LTD HT I 20/2034 ALWAYE TECHNO RUBBERS HT I 6/621 AMBANAD ESTATE HT I 6/3728 AMRUT DISTILLERIES LTD. HT I 28/2858 ANAND OIL & EXTRACTIONS LTD. HT I 14/1420 ANAND WATER METER MFG CO (27/14/1420) HT I 18/4557 ANNS IND FLAVOURS HT I 4/414 ARAPETTA ESTATE HT I 17/3941 ARCH PLY N BOARDS HT I 27/3391 ARIKKAT OIL INDUSTRIES HT I 18/4183 ARJUNA NATURAL EXTRACTS LTD. HT I 17/1551 ARKAY ARC INDUSTRIES HT I 18/1038 ARNAKAL ESTATE HT I 25/4313 ARYA VAIDYA PHARMACY(COIMBATORE) LTD HT I 10/4042 ASHIQUE CHEMICALS AND COSMETICS HT I 13/3277 ASHIQUE EXPORTS (P) LTD HT I 30/3117 ASPINWAL (TRAVANCORE) LTD HT I 13/1361 AVT NATURAL PRODUCTS LTD HT I 5/518 BALIAPATTAM TILE WORKS HT I 15/4645 BENZY FOODS AND BEVERAGES PVT LTD HT I 31/3419 BERTECH (P) LTD HT I 26/2625 BEST BRICKS & TILES HT I 11/4124 BEST GRANITES, KOTHACHIRA HT I 4/4604 BEST READY MIX HT I 31/3430 BETA GRANITE PVT LTD HT I 29/2946 BHARATHY RUBBER INDUSTRIES HT I 32/3533 BHAVANI TEA & PRODUCE CO. LTD. HT I 15/1512 BINANI INDUSTRIES(P)LTD HT I 20/3913 BODY GEAR INTERNATIONAL (PVT) LTD HT I 8/718 BOYCE ESTATE HT I January-10 February-08 February-09 February-10 Mar-08 Zone-A Zone-B Zone-C Zone-A Zone-B Zone-C Zone-A Zone-B Zone-C Zone-A Zone-B Zone-C Zone-A Zone-B Zone-C Page3/6

16 Annexure-3 Month wise energy consumption details of HT Category (units) HT I 26/2639 BPL INDIA LTD HT I 10/904 BPL LIMITTED HT I 26/2640 BPL SYSTEMS & PROJECTS LTD HT I 27/4480 BRAHMINS ENTERPRISES HT I 28/2815 BRISTOL BOATS HT I 11/1934 BROTHERS RUBBER MILLS HT I 10/1025 CALICUT TILE CO. HT I 4/450 CALIFER POLYMERS (P) LTD HT I 7/641 CANARA PAPER MILLS LTD. HT I 5/515 CANNANORE CO-OPERATIVE SPINNING MILLS HT I 25/3994 CHAKKIATH MOODA AGRO PRODUCTS HT I 25/3283 CHAKKIATH MOODA EXTRACTIONS HT I 5/523 CHANDANAPALLY ESTATE HT I 5/510 CHANDRAMALAI ESTATE HT I 7/3632 CHARANKATTU COIR MFG. CO. (P) LTD HT I 21/3382 CHEERAMALIL EXTRUSIONS (P) LTD HT I 4/422 CHEMBRA PEAK ESTATE HT I 16/1607 CHIDAMBARAM TEA ESTATE HT I 10/4055 CHINTHA PRINTING & PUBLISHING CO PVT LTD HT I 32/3524 CHIRACKAL AGRO MILLS HT I 13/3992 CHIRAYINKEEZHU-ANJENGO COIR MATS&MATTING HT I 5/4213 CHLOROPLAST HT I 4/420 CHULLIKA ESTATE HT I 4/415 CHUNDALE ESTATE HT I 22/2262 COCHIN CEMENTS LTD (31/22/2262) HT I 31/3306 COCHIN KAGAS LTD HT I 7/3948 COCHIN KAGAZ LTD. UNIT-II HT I 22/3272 COCHIN MALABAR ESTATES&INDUSTRIES(31/22) HT I 18/1856 COCHIN MINERALS & RUTILE LTD HT I 19/3610 COCHIN RECLAIMS & TREAD RUBBER PVT. LTD. HT I 23/2332 COMMON FACILITY SERVICE CENTRE HT I 10/1020 COMMONWEALTH TILES, FEROKE HT I 18/336 CO-OPERATIVE SPINNING MILLS,KOLLAM HT I 11/4191 CO-RUBBER CRUMB FACTORY HT I 7/4320 CRESCENT CEMENTS HT I 5/552 CRESCENT CRUMB (P) LTD HT I 5/535 CRUMB RUBBER FACTORY (KCRMF) HT I 31/4040 D.C MILLS PVT LTD, PATHIRAPPALLY HT I 32/3574 D.C. BOOKS HT I 31/3742 D.C.MILLS HT I 13/3278 DANSON MOULDS (P) LTD. HT I 31/3411 DC MILLS (P) LTD HT I 17/5178 DELTA GRANITES & SAND HT I 9/4157 DESHABHIMANI PRINTING&PUBLSHG. HOUSE LTD HT I 4/4574 DETILISH RUGS HT I 30/4598 DIMESCO FOOT CARE INDIA (P) LTD. HT I 8/4365 DIVINE GASES PVT.LTD HT I 24/2419 DUROFLEX COIR INDUSTRIES (P) LTD HT I 5/4605 DYNAMIC TECHNO MEDICALS PVT. LTD. HT I January-10 February-08 February-09 February-10 Mar-08 Zone-A Zone-B Zone-C Zone-A Zone-B Zone-C Zone-A Zone-B Zone-C Zone-A Zone-B Zone-C Zone-A Zone-B Zone-C Page4/6

17 Annexure-3 Month wise energy consumption details of HT Category (units) HT I 4/4129 A.C. POLYMER INDUSTRIES HT I 1/154 A.P. STEEL RE-ROLLING MILLS HT I 4/419 ACHOOR ESTATE HT I 7/4577 ACTIVE CHARS PVT LTD HT I 31/3314 AGROWOOD ANDAMAN TIMBER INDUSTRIES HT I 13/1331 AHAMMED ROLLER FLOUR MILLS (P)LTD HT I 7/3752 AISWARYA STEELS PVT. LTD. HT I 19/4279 AKAY FLAVOURS & AROMATICS PVT. LTD. HT I 26/2667 AKAY FLAVOURS AND AROMATICS LTD HT I 10/3999 AKG MEMORIAL PRINTING& PUBLG CO (P) LTD, HT I 29/4508 AL AMEEN CRUSHER HT I 7/712 ALAGAPPA TEXTILES LTD. (NTC) HT I 5/530 ALAMPALLY BROTHERS LTD HT I 31/4566 ALLEPPEY COMPANY LTD HT I 25/4526 ALLEPPEY LATEX (P) LTD. HT I 2/3561 ALLEPPY CO-OP SPINNING MILLS LTD HT I 15/1958 ALLIANCE GRAIN PRODUCTS (P) LTD HT I 32/3482 AL-MADEENA GRANITE METAL& CEMENT FACTORY HT I 9/3873 ALPHS VENEERS,TALAPADY HT I 8/4307 ALWAYE METALS & ALLOYS PVT LIMITED HT I 21/2114 ALWAYE RUBEX (P) LTD HT I 20/2034 ALWAYE TECHNO RUBBERS HT I 6/621 AMBANAD ESTATE HT I 6/3728 AMRUT DISTILLERIES LTD. HT I 28/2858 ANAND OIL & EXTRACTIONS LTD. HT I 14/1420 ANAND WATER METER MFG CO (27/14/1420) HT I 18/4557 ANNS IND FLAVOURS HT I 4/414 ARAPETTA ESTATE HT I 17/3941 ARCH PLY N BOARDS HT I 27/3391 ARIKKAT OIL INDUSTRIES HT I 18/4183 ARJUNA NATURAL EXTRACTS LTD. HT I 17/1551 ARKAY ARC INDUSTRIES HT I 18/1038 ARNAKAL ESTATE HT I 25/4313 ARYA VAIDYA PHARMACY(COIMBATORE) LTD HT I 10/4042 ASHIQUE CHEMICALS AND COSMETICS HT I 13/3277 ASHIQUE EXPORTS (P) LTD HT I 30/3117 ASPINWAL (TRAVANCORE) LTD HT I 13/1361 AVT NATURAL PRODUCTS LTD HT I 5/518 BALIAPATTAM TILE WORKS HT I 15/4645 BENZY FOODS AND BEVERAGES PVT LTD HT I 31/3419 BERTECH (P) LTD HT I 26/2625 BEST BRICKS & TILES HT I 11/4124 BEST GRANITES, KOTHACHIRA HT I 4/4604 BEST READY MIX HT I 31/3430 BETA GRANITE PVT LTD HT I 29/2946 BHARATHY RUBBER INDUSTRIES HT I 32/3533 BHAVANI TEA & PRODUCE CO. LTD. HT I 15/1512 BINANI INDUSTRIES(P)LTD HT I 20/3913 BODY GEAR INTERNATIONAL (PVT) LTD HT I 8/718 BOYCE ESTATE HT I Mar-09 Mar-10 Zone-A Zone-B Zone-C Zone-A Zone-B Zone-C Page5/6

18 Annexure-3 Month wise energy consumption details of HT Category (units) HT I 26/2639 BPL INDIA LTD HT I 10/904 BPL LIMITTED HT I 26/2640 BPL SYSTEMS & PROJECTS LTD HT I 27/4480 BRAHMINS ENTERPRISES HT I 28/2815 BRISTOL BOATS HT I 11/1934 BROTHERS RUBBER MILLS HT I 10/1025 CALICUT TILE CO. HT I 4/450 CALIFER POLYMERS (P) LTD HT I 7/641 CANARA PAPER MILLS LTD. HT I 5/515 CANNANORE CO-OPERATIVE SPINNING MILLS HT I 25/3994 CHAKKIATH MOODA AGRO PRODUCTS HT I 25/3283 CHAKKIATH MOODA EXTRACTIONS HT I 5/523 CHANDANAPALLY ESTATE HT I 5/510 CHANDRAMALAI ESTATE HT I 7/3632 CHARANKATTU COIR MFG. CO. (P) LTD HT I 21/3382 CHEERAMALIL EXTRUSIONS (P) LTD HT I 4/422 CHEMBRA PEAK ESTATE HT I 16/1607 CHIDAMBARAM TEA ESTATE HT I 10/4055 CHINTHA PRINTING & PUBLISHING CO PVT LTD HT I 32/3524 CHIRACKAL AGRO MILLS HT I 13/3992 CHIRAYINKEEZHU-ANJENGO COIR MATS&MATTING HT I 5/4213 CHLOROPLAST HT I 4/420 CHULLIKA ESTATE HT I 4/415 CHUNDALE ESTATE HT I 22/2262 COCHIN CEMENTS LTD (31/22/2262) HT I 31/3306 COCHIN KAGAS LTD HT I 7/3948 COCHIN KAGAZ LTD. UNIT-II HT I 22/3272 COCHIN MALABAR ESTATES&INDUSTRIES(31/22) HT I 18/1856 COCHIN MINERALS & RUTILE LTD HT I 19/3610 COCHIN RECLAIMS & TREAD RUBBER PVT. LTD. HT I 23/2332 COMMON FACILITY SERVICE CENTRE HT I 10/1020 COMMONWEALTH TILES, FEROKE HT I 18/336 CO-OPERATIVE SPINNING MILLS,KOLLAM HT I 11/4191 CO-RUBBER CRUMB FACTORY HT I 7/4320 CRESCENT CEMENTS HT I 5/552 CRESCENT CRUMB (P) LTD HT I 5/535 CRUMB RUBBER FACTORY (KCRMF) HT I 31/4040 D.C MILLS PVT LTD, PATHIRAPPALLY HT I 32/3574 D.C. BOOKS HT I 31/3742 D.C.MILLS HT I 13/3278 DANSON MOULDS (P) LTD. HT I 31/3411 DC MILLS (P) LTD HT I 17/5178 DELTA GRANITES & SAND HT I 9/4157 DESHABHIMANI PRINTING&PUBLSHG. HOUSE LTD HT I 4/4574 DETILISH RUGS HT I 30/4598 DIMESCO FOOT CARE INDIA (P) LTD. HT I 8/4365 DIVINE GASES PVT.LTD HT I 24/2419 DUROFLEX COIR INDUSTRIES (P) LTD HT I 5/4605 DYNAMIC TECHNO MEDICALS PVT. LTD. HT I Mar-09 Mar-10 Zone-A Zone-B Zone-C Zone-A Zone-B Zone-C Page6/6