Opposes proposed 20% ToD surcharge
Srinagar, Nov 28: The Kashmir Chamber of Commerce and Industry (KCCI) has formally submitted its objections before the Joint Electricity Regulatory Commission (JERC) in response to petition filed by Kashmir Power Development Corporation Limited KPDCL) seeking approval for the Proposal to impose a 20 percent Time of Day (ToD) surcharge during peak hours
KCCI in a statement said that the submission of written objections and feedback follows the open JSERC hearing on 20th November, 2025 in which Secretary General KCCI Faiz Bakshi had vehemently opposed the 20 percent surcharge
In its submission, the chamber has expressed deep concern over KPDCL’s proposal to impose a 20 percent Time of Day (ToD) surcharge during peak hours, describing it as an indirect tariff hike that would disproportionately burden domestic, commercial, and industrial consumers.
KCCI has said, “Although KPDCL claims to have proposed no tariff increase, the imposition of a steep surcharge during the busiest consumption hours effectively translates into a significant financial escalation for consumers already struggling under economic pressures.”
The chamber in the response had argued that the proposal is premature and technically infeasible, given that nearly half of Kashmir’s consumers are still not equipped with smart meters capable of recording time-based consumption.
“Without universal smart metering, there is no scientific or equitable mechanism to differentiate between peak and off-peak usage. Introducing such a surcharge, the Chamber noted, would lead to widespread billing inaccuracies, consumer disputes, and discriminatory treatment between metered and non-metered households,” it reads.
It also highlighted that KPDCL’s proposal lacks fairness, as it seeks to penalize consumers during peak hours without offering any corresponding rebate for off-peak usage, an essential feature of ToD tariff systems followed across the country. “A one-sided model focused solely on revenue enhancement, KCCI said, undermines the regulatory principles of balance, equity, and consumer protection.”
Expressing concern over KPDCL performance, KCCI noted that the utility continues to report extremely high Aggregate Technical & Commercial losses of around 47 percent, far above the national average.
“The Chamber stressed that honest, bill-paying consumers cannot be made to bear the financial burden of infrastructure leakages, and administrative inefficiencies. It reminded the Commission that established regulatory frameworks prohibit passing the cost of a utility’s shortcomings onto consumers,” reads the statement.
The chamber in a response filed before JERC said, “KCCI underscored the poor quality and reliability of power supply in the Valley. Citing data from the Central Electricity Authority (CEA), the Chamber pointed out that Kashmir’s interruption indices are among the worst in India, with prolonged and frequent outages severely affecting households, businesses, industries, healthcare facilities, and the education sector.”
“A utility struggling to ensure basic reliability, the Chamber submitted, cannot justify charging consumers a premium for peak-hour consumption,” it reads.
The statement further said that “Additionally, the Chamber called attention to the stagnation in local power generation capacity, noting that no new power projects have been commissioned since 2015. This shortfall forces the UT to depend heavily on costly power purchases, a consequence of planning gaps that, the Chamber insisted, should not be compensated through consumer surcharges.”
“KCCI also reminded the Commission of the provisions of the Electricity (Rights of Consumers) Rules, 2020, which mandate automatic compensation for outages and service deficiencies—rules that remain unimplemented. Instead of safeguarding consumer rights, the Chamber said, the present proposal seeks to increase costs without ensuring reliable service,” reads the statement.
The Chamber urged the Commission to ensure strict implementation of consumer compensation rules.
KCCI said that it reaffirms its commitment to protecting the rights and interests of the business community and the people of Kashmir, and expressed hope that the Hon’ble Commission would consider its submissions in the interest of justice, equity, and public welfare—(KNO)
