Saakshya Law recently represented three Greenko group companies before the Karnataka Electricity Regulatory Commission (KERC) in a matter concerning refusal by KPTCL, BESCOM and MESCOM to issue ‘B Forms’ to these generating companies.

B forms are documents that record the total energy injected into the grid by a generating company in a month and as per the existing system of metering and billing, are necessary for raising invoices to ESCOMs for the energy sold to ESCOMS. 

ESCOMS also ask for B Forms while issuing Official Memorandum regarding wheeling of energy to consumers. 

On 29 March 2023, the KERC passed an Order holding that the system of issuing B Forms itself is not necessary as per the Wheeling and Banking Agreement between the generating companies, KPTCL and ESCOMS and the Power Purchase Agreement with BESCOM. It was also held that the C forms that are presently required to be submitted by generators for obtaining Official Memorandum is also not contemplated under the Wheeling and Banking Agreements. While so holding, the Commission issued industry wide guidelines for meter reading and billing (in paragraph 12(vi) of the Order) and directed all ESCOMs to follow these guidelines.

The Guidelines provide as follows:

a. With effect from 1 August 2023 all meter reading at the injection point and at the drawal point of consumers shall be through AMR and the data shall be transferred automatically to the billing software, for automatic generation of bills. The necessary web portal and system integration shall be put in place by KPTCL/ESCOMs. Without waiting for the above cut-off date, wherever AMR is installed and communication facility is in place, the billing shall be automated.

b. Till such time automatic reading and billing take place, the following shall be adopted:

i. Each month, at the injection point, the authorised representative of the ESCOM where the energy is injected and the authorised representative of the company shall read or download the meter data, on the metering date i.e., the midnight of the last day of the calendar month and sign a joint statement indicating the previous month reading and the current month reading of the various parameters and compute the energy and reactive power imported as recorded by the import meter and the energy and reactive power injected as recorded by the export meter, in addition to any parameter required for billing purpose. The joint statement shall not be signed by any other official other than the authorised representatives.

ii. Along with the joint statement the generator shall submit an allocation statement duly signed by the authorised representative of the company, allocating the entire energy injected during the month to its consumers (indicating the RR Number and the ESCOM) under WBA.

iii. The joint statement and the allocation statement shall be sent by email by second day of every calendar month to avoid delay in billing, to the nodal agency and the billing section of the ESCOMs where the open access consumers are situated, by the authorised representative of the injection ESCOM and the original copy of the joint statement and allocation statement could be sent later for record purpose.

iv. At the consumer end the jurisdictional engineer shall read or download the meter data, on the metering date i.e., the midnight of the last day of the calendar month and sign a statement indicating the previous month reading and the current month reading of the various parameters and compute the energy and reactive power consumed by the consumer, in addition to any parameter required for billing purpose and send it to the billing section by second day of the calendar month.

v. If the net energy injected by the Generator under WBA, is more than the total quantum of energy consumed by the Open Access consumer, the entire consumption of such Open Access consumer should be treated as “wheeled energy‟. The balance quantum of energy remaining, after wheeling, has to be treated as “banked energy”.

vi. If the net energy injected by the Generator under WBA, plus the banked energy, if any, is less than the total consumption of energy of the Open Access consumer, the excess energy consumed is to be billed as per the tariff applicable to the said “Non-Exclusive Consumer” or the “Exclusive Consumer”, as the case may be, and such excess energy consumed is deemed to be supplied by the “Consumption Point” ESCOM.

vii. The billing section shall prepare the bill after deducting the consumption by the consumer from various open access sources like IEX, Wheeling etc., and send it to the concerned consumers by the 5th day of the calendar month.