ISLAMABAD: The National Electric Power Regulatory Authority (NEPRA) has been urged to substantially revise its proposed amendments to the Consumer Service Manual (CSM) to prevent arbitrary grid-sharing charges, discriminatory treatment of consumers, expensive industrial grid connections and alleged misuse of detection-billing powers by distribution companies (DISCOs).
In detailed objections submitted to NEPRA, Muhammed Arif Bilvani has called for a comprehensive review of proposed changes to several provisions of the CSM, arguing that the amendments could impose additional financial burdens on consumers without establishing actual incremental infrastructure costs or adequate procedural safeguards.
The objections cover Clauses 2.6(3), 2.6(6), 2.6(7), 8.3, 8.3.4, 8.3.7, 9.2.1, 9.2.2 and 9.2.3, besides seeking clarification of Clause 2.22 governing the reduction of sanctioned load.
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A major concern relates to the proposed 500 kVA threshold for dedicated transformers under Clause 2.6(3). The objector maintained that imposing grid-sharing charges merely because a consumer requires a transformer exceeding 500 kVA would be arbitrary, particularly when the actual requirement for additional infrastructure and its cost had not been established.
He pointed out that a multi-storey commercial building requiring a dedicated transformer of 750 kVA or 1,000 kVA could face additional charges simply because its legitimate load requirement exceeded the proposed threshold.
According to the objections, the proposed arrangement could also encourage consumers to artificially divide their loads between two smaller transformers to remain below the 500 kVA limit. Such an approach would lead to additional equipment, space requirements, maintenance costs and potentially higher technical losses instead of promoting efficient electricity distribution.
The submission proposed allowing multi-storey, commercial, industrial-commercial and three-phase domestic consumers to install dedicated transformers of up to 1,000 kVA without automatically attracting grid-sharing charges solely because of transformer capacity.
Consumers requiring higher loads should also be allowed dedicated feeders where technically justified, subject to payment of the actual incremental infrastructure cost.
The objector further argued that DISCOs should not recover through grid-sharing charges the cost of infrastructure already incorporated into their regulated asset base and recovered through electricity tariffs.
“Where an existing grid station has sufficient spare capacity to accommodate additional demand without requiring new investment, no grid-sharing charge should be imposed,” he proposed.
He also questioned the proposed uniform grid-sharing rate of Rs8.948 million per MW, arguing that grid stations have different spare capacities, loading conditions and infrastructure requirements.
NEPRA has been asked to disclose the methodology, assumptions, infrastructure components and grid-station-wise cost calculations supporting the proposed rate before finalising the amendment.
The submission further called for revised charges to apply prospectively, protecting consumers who have already applied for new connections or load extensions, received demand notices, paid prescribed charges or commenced construction and procurement under the existing regulatory framework.
Another significant proposal concerns industrial connections and the voltage level required for establishing grid stations under Clause 2.6(6).
The objector has urged NEPRA to allow 33 kV grid stations for industrial demand below 25 MW and 66 kV grid stations for demand below 45 MW, while requiring 132 kV installations only where justified by actual demand, technical feasibility, network capacity and system stability.
He argued that compelling industrial consumers to establish 132 kV grid stations merely because their demand exceeds 15 MW, without examining the feasibility of lower-voltage alternatives, would unnecessarily increase capital expenditure.
Such investments involve additional costs relating to switchgear, protection systems, land, civil works and associated equipment, ultimately increasing production costs and affecting the competitiveness of Pakistani industry.
The submission proposed that DISCOs should provide technically supported reasons whenever they insist on a higher voltage level despite the availability of a feasible and economical lower-voltage alternative.
On temporary disconnections, the objector has sought an amendment to Clause 8.3 requiring DISCOs to serve consumers with at least 15 days’ prior notice before expiry of the approved temporary disconnection period.
The notice should inform consumers that the temporary disconnection period is approaching expiry and that an application for reconnection is required if they wish to continue the disconnected status within the prescribed framework.
According to the proposal, a connection should be deemed reconnected and applicable charges imposed after expiry of the temporary disconnection period only where the DISCO has properly served the required notice and the consumer has failed to apply for reconnection.
Where the DISCO fails to provide the mandatory notice, the connection should not automatically be deemed reconnected, nor should charges be imposed until proper notice has been served and the consumer has been given a reasonable opportunity to respond.
The objections also seek greater transparency in inspections and detection bills under Clause 9.2.2, particularly in cases involving alleged illegal abstraction of electricity by industrial and commercial establishments.
The objector proposed that a representative of the relevant trade body should be present during such inspections to provide an independent witness and reduce disputes concerning inspection proceedings and subsequent detection assessments.
The DISCO should provide reasonable notice to the consumer and relevant trade body, while recording the circumstances of the inspection and proof of service.
Another proposed safeguard requires DISCOs to provide complete, itemised calculations and documentary evidence with every detection bill, specifying the assessment period, estimated units, applicable tariff, adjustments and methodology used to calculate the amount.
The submission argued that detection bills should not be assessed mechanically on the basis of sanctioned load, as the sanctioned load represents the maximum authorised demand rather than proof that the consumer continuously utilised the entire capacity throughout the disputed period.
It proposed that assessments should take into account consumption history, meter data, inspection evidence, connected equipment, actual operating conditions and other relevant technical information.
The submission also called for special protection against disputed detection bills exceeding prescribed thresholds: Rs500,000 for industrial consumers, Rs250,000 for commercial consumers and Rs99,000 for domestic consumers.
Where such bills are formally challenged before the Electric Inspector/POI or NEPRA’s Consumer Affairs Department (CAD), recovery of the disputed amount should remain suspended until the competent forum decides the matter.
The complaint should be resolved through a summary procedure within 30 days, with a reasoned decision and disclosure of the material relied upon.
The DISCOs should not use disconnection or coercive recovery measures to compel payment of disputed amounts under formal adjudication, although consumers would remain liable to pay undisputed current bills.
The objector has also proposed introducing a new CSM provision requiring every non-normal bill, including Irregular Bills (IRB) and Assessed Bills (ASSD), as well as bills containing arrears, to be accompanied by an explanatory letter signed by the competent DISCO officer, such as the GM, DGM or XEN.
The letter should explain the reasons for issuing the bill, the relevant period, complete calculations, adjustments and the nature and reconciliation of arrears.
Where such an explanation is not provided, the due date for payment of the disputed exceptional amount or unexplained arrears should be extended until the required details are supplied and acknowledged. The existing statutory or regulatory time limit for raising bills, however, should remain unchanged.
The submission has additionally called for deletion of certain provisions under Clause 9.2.1 relating exclusively to obsolete metal-body electromechanical meters, to the extent that they have become irrelevant following the transition to electronic and smart meters.
In a further communication submitted in continuation of the October 14 objections, Bilvani has raised concerns about the procedure followed by DISCOs, particularly K-Electric, for reducing sanctioned load under Clause 2.22.
He maintained that the CSM already recognises a test report issued by the Electric Inspector or an authorised wiring contractor as the relevant technical basis for reducing sanctioned load to a lower limit.
However, DISCOs reportedly insist on conducting fresh load surveys, imposing additional requirements that are not expressly prescribed under the existing clause.
He has asked NEPRA to clarify that the prescribed test report should ordinarily be sufficient and that the highest Maximum Demand recorded during the preceding 12 months may be considered where a genuine technical dispute arises and reliable records are available.
The submission also opposes any automatic enhancement or fresh demand of security deposit merely because a consumer reduces sanctioned load, arguing that the consumer’s identity and location of supply remain unchanged.
The objector has urged NEPRA to incorporate these proposals before finalising the amendments, maintaining that the CSM should promote efficient utilisation of the existing electricity network, encourage legitimate consumption and industrial activity, and ensure that additional charges are based on actual incremental costs rather than arbitrary regulatory thresholds.
Copyright Business Recorder, 2026
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