Al ANDHRA PRADESH SPINNING MILLS ASSOCIATION SMA (ead. No. 38201) 105, 1st Floor, Surya Towers, Sardar Patel Road, Secunderabad - 500 006. “Tel: 491-40-27890041, Fax : +91-40-27846837 E-mail: contact @apepia.com Mobile: 8649028556 (Liaison Ofticer) Date: 08-02-2013 ‘D.No, }-660, 4% & St Floors, oO Singizeni Bhavan, Red Hills, [es h89 HYDERABAD = 500 004 ( Regulatory Commission = sir, . X uy J sub; Our cbfectone/tuggcane wits ference w Arne Qacablat 5A proposals for retail supply business for the year 201B-1 Beguine by the DISCOMG to Honble APERC Our industry represents ~ 1) Over 135 Spinning Mills with over 35 lakh spindles, spinning substantially cotton yarn and some synthetic yarn. 2) Andhra Pradesh is a major cotton growing State 3) We employ over a lakh of people 4) We have a connected load of over 300 MW and consume 185 MU a year most of it at 33 KV 5} We, Spinning Mille aerate at an average of 80% and above load factory and at 0.95 and above power factor. ‘Textile industry is 2m! largest industry in India in providing more employment after Agriculture. Andhra ie the 3 largest State in production of Cotton with 55.00 Lakh bales and consuming only 34.00 lakh bales at present, As many as 21.00 Lakh spindles were added to the previous 19.90 Lalths in the period of 2005-10 aud based on the lower tariff and stable supply of power had attracted the investments. A.P. Government is anticipating much investment in the coming 2010-15 in textile sector in order to consume the entire cotton for making the textile products to end of value chain ie, upto the garment stage. Briefly. Spinning Mills are ~ = An efficient energy users as our load factor is above 75% and power factor is above 0.95 and mostly at 33 KV = Our load curve all the day and the year is uniform ~ i.e., we are a beneficial factor to the DISCOM GRID in load management.(Regd. No. 39201) 108, 1st Floor, Surya Towers, Sardar Patel Road, Secunderabad - 500 003. ‘Tol: +91-40-27890041, Fax : +91-40-27846897 E-mail: contact@apspin.com Mobile : 9849028556 (Liaison Officer) ANDHRA PRADESH SPINNING MILLS ASSOCIATION nbn Energy cost represents 33% on the cost of production at current tariff levels. Thus, the energy tariff proposals are a matter of significant concern to, we, spinning mills. The Spinning Mills are distributed across the State and we have raised our objections with reference to specific page numbers in the ARR proposals of APCPNCI., although the objections would be equally applicable to the proposals of all the Discos. — il — May it please the Honourable Commission ~ 1) We are an association of spinning mills in Andhra Pradesh and our members are consumer of one or mnore of the four DISCOMS. We are submitting hereunder, in the first instance, our objection to the ARR and proposed tariff for the retail supply business for Financial Year 2013-14 and reserve the right to make further objections and/or submit ours during the course of the proceedings upon further information as required hereunder being made available, or as may otherwise be considered necessary. 2) Its a fact that the customer mix of each DISCOM is different and yet the final tariff of each DISCOM is same. We believe that all the DISCOMS are acting in cartel, defeating the objective of the electricity act in the promotion of competition, efficiency and ‘consequent negative input in a competitive tariff to we, consumers. ‘Thanking you, Yours faithfully, For ANDHRA Rennes SPINNING MILLS ASSOCIATION * 7 RK. AGARWAL HON. CHAIRMAN, Copy To! A. Chief General Manger, (Comunl & RAC), Central Power Distribution Company Co, of AP Ud. 2 Foor, Mint Compound, Hyderabad - 50008, 2 Chief General Manger, (Comm & RAC), Souther Power Distribution Company Co, of AP La. 19-1345/A, Srinivasapuram, Truchanst Road, Tirupati 517513 3. Chie General Manger, (Comm! & RAC), Eastern Power Distribution Company Co, of AP Lid 2nd Foor, Near Gurudwar,PleT Colony, Seetammadhara,Vishakapatnam ~S30013 44 Cher Genera Mange, (° & KAC), Nortnemn Yower Distribution Company Co, of AP Lid. 1-503 508, Chatanyapusi, Opp. REC Petrol Bunk, Hanamnkonda Warangel - 506004atinn ANDHRA PRADESH SPINNING MILLS ASSOCIATION (Regd. No. 39201) 105, 151 Floor, Surya Towers, Sardar Patel Road, Secunderabad - 500 003, Tol: +91-40-27690041, Fax: +91-40-27846887 E-wal: contact@ apspin.com_MCbIe YB4B0ZBE5E (Liason Oficr) REFERENCES FERENCE TO APCI ‘TARIFF RETAIL SUPPLY BUSI 13-14 1 12 Page ii) - Distribution Losses: It is stated that “whereas, actual losses are different from the ‘approved losses. The additional power purchase to cover the difference in losses is not accounted for in this fling. Hence, the licensee humbly request the Hon'ble Commission (H C) to consider 1oF projection by Ue on actual logeee achieved in the last year or alternate mechanism to compensate the additional power purchase ‘cost due to difference in losses OUR PRAYER Once the loss trajectory has been approved by APERC, deviation should not be permitted by APERC. However, as we note il year after year the deviations between the approved APERC losses and actuals are at variance (as we see substantially) it is definitely time ‘that “HC” examine the very basis of their permitted sales and or ‘examine the methodology adopted by DISCOMS in arriving at their sales since this has got significant effect right from the estimates of ARR, the cost of servire and canseqniential tariff. Needless to say that ‘since the final tariff in any case is to be finalized by ensuring reduction in cross subsidy year after year as mandated by various Acts and NTP. We also note that T&D losses are lumped up without any separation of 3) technical losses and ii) commercial losses. We ‘submit that since both these losses have the single largest effect un tariff, the “HC” direct the DISCOMS that this be given by the DISCOMS in their ARR customer-wise, at various voltage levels during the last 3 years alongwith steps taken and steps to be taken to reach the targeted leveis mandated by “HC. We also note that APERC target T&D losses now being taken by DISCOMS are different from the earlier multi year tariff targets set by the “HC”