Kindly refer to All India Power Engineers Federation (AIPEF) letter No. 26 - 2019 dt 11-09-2019 and letter No 28-2019 dt 23-09-2019 sent to you to kindly defer any proposal of unbundling of J&K Power Sector.
2. In continuation to above referred letters AIPEF further requests you to kindly shelve the proposal of unbundling of Power Development Department of J&K in view of following points in addition to points raised in previous letters sent to you --
a. Unbundling of Distribution , Transmission and Generation is not mandatory as per Electricity Act 2003. Kerala and Himachal Pradesh are states who continue as integrated utility in the name of KSEB Ltd and HPSEB Ltd respectively. Both the states have shown remarkable improvement under integrated system .
b. Mere Unbundling has not yielded any result to improve the system in any of the states. Improvement is possible by strengthening the system only which can be done better in integrated utility.
c. Every state has one SLDC where the entire state is considered as one control area. This gives SLDC a clear advantage to manage load dispatch over the state as one entity. For example if there is load crash in one portion of state (due to rain, storm etc.) SLDC can order additional supply or loading in other areas of state to offset load crash, so that overall drawl by State remains without deviation.
d. With one state Discom concept the state hydro generation can be optimally dispatched by SLDC in the most economic and optimum manner.
e. In regulatory matters of state level, and dealing with SERC, it is practically effective with one Discom and generation and transmission combined. Creation of multiple units only complicates SERC issues.
f. Similarly, in dealings with CERC and APTEL etc. it is practically possible and justified considering the state as one entity.
g. Manpower and HR functions are performed more efficiently and with uniformity with one organization as opposed to multiple companies.
h. Since electricity is a concurrent subject, it would be incorrect to carry out drastic changes in the Electricity Department of J&K when the State assembly has not been formed. It would be against the Constitution of India to ignore/ bye pass the State Government/ State Assembly on a concurrent subject where the State has an equal right as compared to the Central Government.
3. In a situation where the State is under President rule & where the elections to the State Assembly have not been held, it would be against the Constitution to ignore the public opinion and opinion of electricity consumers in the matter of unbundling / privatizing the State Power Department. It is against democracy and against the Constitution of India.
4. Therefore you are kindly requested to issue directions to Power Department authorities to restructure the power department so that all power utilities (Distribution,Transmission & Generation) remain integrated as one company like neighbouring hill state Himachal Pradesh in the larger interest of state for better coordination and better consumer service.
Thanking you. With Regards.
Yours faithfully
Shailendra Dubey
Chairman
CC.
1. Hon'ble Prime Minister, Govt Of India, New Delhi.
2. Hon'ble Power Minister, Govt Of India, New Delhi.
3. Chief Secretary, J&K Govt., Srinagar.