Smart Metering GettingItRight-PPP
Smart Metering GettingItRight-PPP
Smart Metering GettingItRight-PPP
India targets to install 25 Crore smart meters for consumers by 2022. Even with replacement of 19 Lakh
existing meters with smart meters, currently, there are very little accountability systems in place to check
the efficacy of such a large-scale program. Replacement of conventional meters with smart meters will
have implications beyond addressing metering and billing issues in the sector. They hold the promise
of performance improvement in the form of quicker detection of outages and losses in the system,
better service quality, and load management. To reap such benefits, it is important to closely monitor
the implementation of the program. Going forward, smart meters will be the main interface between
consumers and DISCOMs, and if the metering systems, and not just meters, do not function properly,
it will result in significant inconvenience to consumers. Large scale implementation can be achieved
through careful analysis and evaluation by regulators and by focusing on learnings from pilot projects.
Against this backdrop, and based on a review of implementation of smart metering programs in few
states, this article identifies key issues that need immediate attention, and provides some
recommendations to the actors involved.
1. Background
Electricity consumers in India are about to experience a change in how they receive and pay their bills, with
the introduction of an advanced smart metering technology. This was brought to the fore, when in the
union budget speech for 2020, the Finance Minister announced that all conventional consumer meters
would be replaced by smart meters by 2022. Subsequently, a scheme worth ₹ 3.05 lakh crore was
announced in the union budget for Financial Year 2021-22 (FY22), which focuses significantly on smart
metering. The idea has gathered steam, and primarily under the Smart Meter National Program (SMNP),
which is steered by the Government of India owned- Energy Efficiency Services Limited (EESL), 19 lakh smart
meters have already been installed in India (Figure 1). While the SMNP aims to replace 25 crore
conventional meters, electricity distribution companies (DISCOMs) are pushing for smart metering as well.
For example, Andhra Pradesh government is planning to install about 18 lakh smart meters on agricultural
connections.
1 Authors thank their colleagues Sreekumar N, Ann Josey, and Shantanu Dixit for valuable inputs on the drafts.
2 This article is part of an ongoing series called Power Perspectives which provides brief commentaries and analysis of
important developments in the Indian power sector, in various states and at the national level. The portal with all the
articles can be accessed on: https://prayaspune.org/peg/resources/power-perspective-portal.html. Comments and
suggestions on the series are welcome, and can be addressed to [email protected]
14,56,961
3,11,373
1,56,220
32,599 5,183
EESL Utility owned projects Smart grid pilot Integrated Power National Smart Grid
projects Development Scheme Mission
(IPDS)
These statistics and the policy push show that the large-scale implementation of smart meter installations
that has started in a few states, namely, Uttar Pradesh, Bihar, Haryana, Rajasthan and Delhi, will also take
place in other parts of the country over the next few years. Over and above this, there seems to be much
emphasis, of late, on operating smart meters only in prepaid mode. Prepaid meters will introduce unique
complexities with respect to temporary remote disconnections and barriers faced by consumers in
recharging on time. Given this development and significant financial investment thereof, effective checks
and balances are needed to ensure smooth implementation of these programmes.
Prima facie, large-scale replacement of conventional meters with smart meters might seem like an
advancement that smoothens out the creases in the metering and billing systems. However, the
implications of installation of smart meters are manifold. They go beyond the outcomes seen in the
previous transition from electro-mechanical to digital meters.
This transition not only calls for system-level changes at the DISCOM’s end, but also for adaptation to new
systems at the consumer’s end. Sufficient trials by DISCOMs are required to ensure technical upgradation
of the existing metering and billing system, whereby data, that is automatically received from smart meters,
can be integrated smoothly. This will ensure that meters installed at remotest places communicate without
difficulty. At the consumer’s end, migration to app-based systems and pre-paid billing may require
significant participation and the necessary know-how. Recent incidences of automatic disconnections, or
system faults that lead to outages, as in the case of Uttar Pradesh, are not helpful in building the necessary
confidence in the system. Similar cases of errors in logging into energy management applications and
issues with data privacy have been observed in other countries too.
Against this backdrop, and based on a review of implementation of smart metering programmes in five
states, namely, Uttar Pradesh, Bihar, Haryana, Rajasthan and Delhi, this article highlights a few key issues
that need immediate attention. Along with that, this article provides recommendations to the actors
involved.
While often being championed as the next big innovation to overcome the power sector’ woes, smart
meters are intended to benefit both DISCOMs and consumers. For DISCOMs, with full integration of smart
meters on the distribution system and at consumers’ end, tracking of Aggregate Technical and Commercial
(AT&C) losses is much easier. This will imply enhanced revenue collection and facilitate demand-side
management. Loss reduction, and thereby improvement in billing and collection efficiency are being
claimed as the benefits to justify the costs associated with this large-scale smart meter installation
programme. For consumers, installation of smart meters means more control over consumption through
records of their consumption history. Smart meters can also ensure better quality of electricity supply. This
is because smart meters facilitate quicker detection of outages and eliminate billing errors.
Performance parameters like loss reduction and increase in revenue seem to indicate substantial gains, but
the basis of such claims is not clear. This has been elaborated on in Section 4. Additionally, it is not clear
how often this dashboard is updated. This is because DISCOMs in Uttar Pradesh have stated in their
regulatory information that 24 lakh smart meters5 have been installed at the end of FY21, but the SMNP
dashboard shows a lower number. A different model of financing has also been taken up by DISCOMs,
3
https://cea.nic.in/wp-content/uploads/2020/04/Tech.-Specification-of-Smart-Meters-1-Ph-and-3-Ph-Feb-2020.pdf
4 EESL, promoted by the Ministry of Power, is a joint venture company of public sector undertakings such as NTPC
Limited, PFC Limited, REC Limited and Power Grid Corporation of India Limited.
5
https://www.prayaspune.org/peg/publications/item/500-comments-and-suggestions-on-uttar-pradesh-discoms-
tariff-process-for-fy22.html
Another national level institutional mechanism involves constitution of a National Smart Grid Mission6
(NSGM) by the Ministry of Power. As the name suggests, the programme’s focus extends beyond smart
metering of consumers to upgradation of the electricity grid, and equipping it with advanced
communicating technology. Established in 2015, the NSGM has the autonomy to monitor and plan for
implementation of smart grid programmes. To facilitate this, there are national and state level project
management units, consisting of stakeholders from DISCOMs, regulatory commissions, academia and civil
society. It is good that NSGM has governing bodies which meet regularly7 to track installation of smart grid
projects, and this could be further leveraged to track implementation of universal smart metering of
consumers. Under the NSGM, model standard bidding documents8 for appointment of AMISPs have also
been finalized after eliciting public comments, in July 2020.
Figure 2: Progress of consumer smart metering across India under the SMNP program of EESL
On the regulatory front, the CEA, which publishes regulations for installation and operation of meters9, has
been prescribing technical standards and specification10 for smart meters as well, from time to time. Recent
proposed amendments to CEA’s metering regulations mention that all new meters should be prepaid
meters. Other than this, the Forum of Regulators (FoR), came up with model Smart Grid Regulations in
2015, elaborating on guidelines for processes, project evaluation, and formulation of a smart grid cell
(responsible for formulation, design, implementation of smart grid plans). State Electricity Regulatory
Commissions (SERCs) in Assam, Haryana, Karnataka, Telangana, and Tripura have already issued smart grid
6 https://www.nsgm.gov.in/en/nsgm
7 https://www.nsgm.gov.in/en/exception_reports
8 https://www.nsgm.gov.in/en/amisp-sbd
9 https://cea.nic.in/old/meteringreg.html
10 https://cea.nic.in/wp-content/uploads/2020/04/Tech.-Specification-of-Smart-Meters-1-Ph-and-3-Ph-Feb-2020.pdf
Tracking benefits
The smart meter implementation programme measures benefits through loss reduction, billing efficiency,
and revenue increase. As shown in Figure 2, the SMNP dashboard claims an average increase in DISCOM
revenues by 21%, by collecting ₹301 more per meter every month. The methodology adopted to arrive at
these numbers, however, remain unclear. This also raises questions regarding treatment of arrears, subsidy
payments, tariff increases, and the time period considered for assessment, and how these factors were
used to arrive at “increased revenue” figures. DISCOMs in Uttar Pradesh, on the other hand, claim a net
benefit of ₹ 4,056 Crore14 in eight years through improvement in billing efficiency.
Hence, in order to track benefits effectively, SERCs should provide assessment frameworks in their tariff or
business plan regulations. The assessment frameworks could include parameters listed in Table 1. DISCOMs
should track and submit data for these parameters before and after installation of smart meters. While the
difference between billed energy and input energy in the system would help calculate distribution losses
and billing efficiency, the revenue parameters would shed light on collection efficiency at the Distribution
Transformer (DT) level. The revenue figures should not include recovery of past arrears and revenue subsidy
provision from the state government. Recovery of past arrears through smart meters should be reported
separately. These changes should be tracked and reported quarterly. Currently DISCOMs have different
11 https://terc.tripura.gov.in/sites/default/files/Draft_Regulation_mfor_Prepaid_Metering-converted_0.pdf
12 https://herc.gov.in/WriteReadData/Pdf/D20210503.pdf
13https://www.prayaspune.org/peg/resources/power-perspective-portal/194-regulatory-accountability-of-smart-
meter-rollout-plan-in-uttar-pradesh.html
14 Pg 12 of UPERC’s approval order for smart meter roll out plan: https://www.uperc.org/App_File/SmartMeters-
pdf1116201863224PM.pdf
Measuring costs
Modes of financing of costs have been discussed in Section 3. Now, irrespective of the financing model,
the question that arises next is how these costs are planned to be recovered by the DISCOMs. Different
approaches have been adopted in states for cost recovery from consumers. Uttar Pradesh DISCOMs,
during the roll out approval process in 2018, explicitly mentioned that costs are not going to be recovered
from consumers, given the claimed net-benefits. However, going back on their words, they have petitioned
to recover meter renting costs through annual tariff increase in the subsequent years. While petitioning19
for FY22 costs, DISCOMs have even mentioned that they are unsure of any net benefits.
Rajasthan DISCOMs have included smart metering costs in their Capital Investment Plan petitions for FY20-
FY24. Delhi SERC, through its business plan regulations of 2019 20, has mandated approval of smart
metering costs as part of capital expenses, giving DISCOM-wise trajectories for yearly capitalisation and
exact amounts to be invested by each DISCOM. Thus, smart meter costs, in these cases, would be passed
onto consumers through a tariff increase. Even with installation of more than a lakh smart meters in Bihar,
the matter of how to pass-through costs of installation of all prepaid meters in the state is still pending
before the SERC since last year21.
15 https://www.prayaspune.org/peg/publications/item/407.html
16 System losses (%) = (Total energy input in the system- Total energy finally consumed in system) x 100
Total energy input in the system
17 Billing Efficiency = Total Energy Billed to DISCOM Consumers x 100
Total Energy Sales to DISCOM consumers
18 Collection Efficiency (current year) = Revenue collected by DISCOM x 100
Revenue due to DISCOM (current year)
Where, revenue collected should not include receivables (pending subsidy payments from previous years recovered
in the current year as well as pending revenue payments from consumers from previous years recovered in the
current year).
19 https://www.dvvnl.org/UploadFiles/Dvvnl_Petition/DVVNL%20ARR%20PETITION%20FY%202021-22.pdf
20 http://www.derc.gov.in/sites/default/files/Business%20Plan%20Regulations%202019%20%281%29.pdf
21
https://berc.co.in/orders/tariff/distribution/sbpdcl/2330-tariff-order-of-strong-span-style-color-000000-discoms-
nbpdcl-sbpdcl-span-strong-for-fy-2021-22
4.2. What are the assessments that are needed to track performance of smart meters?
Pilot projects
Several operational challenges can emerge from on-field deployment of smart meters. This makes it crucial
to conduct pilot projects in different geographies before full-scale implementation. While a handful of
reports22 can be found about pilot projects for smart grids23, there is a dearth of documentation of lessons
from pilot projects focusing on consumer smart metering 24. Lessons from ground-level challenges from
already commenced roll outs in states like Uttar Pradesh, Bihar, and Delhi will certainly benefit the smart
meter rollout projects in other states.
Before implementation, smart meter rollouts should be brought under regulatory scrutiny and be subjected
to SERCs’ approval, since these projects involve significant investment and impacts on consumers. Among
the rollouts that have already taken place, as discussed earlier, only Uttar Pradesh SERC has conducted an
approval process. SERCs’ approval processes should involve scrutiny of the following:
Additionally, SERCs should direct DISCOMs to submit quarterly updates of the status of rollouts. This has
already been mandated by SERCs in Uttar Pradesh25 and Delhi26, however, these reports are not available
in the public domain. Information that should be reported to the SERC has been captured in the Annexure.
Independent third-party energy audits are important to gauge the efficacy of metering and the losses in
the system. To this end, recently, the Ministry of Power has proposed to make it mandatory for DISCOMs
Smart meters will be the main interface between consumers and DISCOMs. Thus, it is important to develop
consumer confidence in smart meters. As per media reports, more than six thousand electricity
consumers28 have opted for permanent disconnection in Uttar Pradesh, following their dissatisfaction and
distrust in smart meters. This is alarming, and with large-scale planned rollouts in remote parts of the
country, more disconnections are likely to take place, if installed meters do not function properly.
What might add to consumers’ anxieties is the lack of choice over modes of payment. Smart meters are
equipped to remotely disconnect consumers if bills are not paid on time, when one has a post-paid
connection. Similarly, upon exhaustion of recharge credit limit, consumers with prepaid connections will
face disconnection. The central government’s policy push seems to be in the direction of replacing all
meters with prepayment meters, to overcome the problem of consumer arrears. In fact, this can already
be observed in Bihar, where the replacement programme has solely focused on prepayment options29.
In the absence of proper alarms or notifications, consumers with prepaid connections will face difficulties.
This will further be exacerbated if accessibility to recharging options is not made easy. If one has to
recharge online, then cellular network connectivity issues might make recharging a hassle. Similarly, if
recharging involves buying coupon codes from physical shops (as was seen in initial years of using non-
smart prepaid meters, or for cell phone recharging), disconnection at odd hours, or in remote areas will
pose a problem. Much frustration of consumers can be found on Bihar’s “Bihar Bijli Smart Meter” app30,
where several complaints regarding meter/ billing or app malfunctioning can be found on Google Play’s
app review section.
Due to such challenges, mechanisms need to be in place to minimize hassles involved with remote
disconnection. South Bihar’s DISCOM, in a public notice31, mentions that disconnection on zero balance
will only take place during the day time, between 10 AM and 1 PM, on working days. Also, twenty-four
hours’ notice shall be given to consumers before temporary disconnection. Further, the DISCOMs have
submitted their disconnection criteria before the BERC during the annual tariff process32, and the
27 https://beeindia.gov.in/sites/default/files/2283_0.pdf
28https://www.hindustantimes.com/cities/lucknow-news/fed-up-with-smart-meters-over-6-000-power-consumers-
say-no-to-power-101617733640593-amp.html
29https://www.smart-energy.com/industry-sectors/smart-meters/2-34-million-smart-prepaid-electricity-meters-for-
indias-bihar-state/
30 https://play.google.com/store/apps/details?id=com.sew.scm.eesl&hl=en&gl=US
31 https://www.sbpdcl.co.in/(S(24k4zsykp04vliusl3opcqe5))/Images/SmartPrepaid.pdf
32https://berc.co.in/orders/tariff/distribution/sbpdcl/2330-tariff-order-of-strong-span-style-color-000000-discoms-
nbpdcl-sbpdcl-span-strong-for-fy-2021-22
Given the severity of the challenge that remote disconnections pose to prepaid consumers, even with
large-scale rollouts, there are barely any provisions to protect consumer interest in SERCs’ regulations. In
states like Uttar Pradesh and Bihar, where lakhs of meters have already been replaced, Standards of
Performance (SoP) or Supply Code regulations still do not contain performance standards or adequate
compensation clauses for smart meters.
SERCs of Rajasthan and Maharashtra have issued new Supply Code and SoP regulations in 2021. While
these regulations do not contain performance parameters for smart/prepaid meters in detail, they mention
disconnection criteria that can be applicable to such meters. Further, Maharashtra’s regulations mention
that any existing meter, if replaced, will be replaced with a smart meter and all new connections will only
be issued smart meters. It is quite clear that more needs to be covered in such regulations. As a starting
point, all SERCs should revise the following performance indicators and their compensation criteria, as has
been captured in Table 2.
Table 2: Some changes that are required in SERCs’ Supply Codes and SoP regulations
Parameter Description
Consumer Currently most SoP regulations33 mention that a fuse-off complaint has to be addressed within 4
fuse-off hours in urban areas and 12-24 hours in rural areas. With installation of smart meters, it will be
easier for DISCOMs to automatically detect fuse-off issues and thus response time, and
compensation thereof should be revised as smart metering systems are stabilized over time.
Meter related Since smart meters will play an important role in temporary disconnection, it is important that any
complaints meter related complaint be resolved at the earliest. Provisions should be there to ensure that
electricity supply is not interrupted due to faulty meters. Currently, most SoP regulations mention
a time standard of 7 days for replacement of meters. Stricter standards need to be in place,
especially for smart meters operating in prepaid mode.
Reporting of Smart meter data should be used to enhance accuracy of reliability indices and could be published
reliability based on information at the feeder, distribution transformer, division, as well as at the consumer
indices level. With smart meter data, it should be possible to have greater transparency in calculation of
reliability indices and hence methodology and underlying data should also be published by
DISCOMs.
Source: Analysis by Prayas (Energy Group)
Once smart meters have been installed at consumer premises, mechanisms need to be put in place to
ensure that consumers have the rights to access their own data, which is collected by these smart meters.
Further, it should be mandated that the DISCOMs present this information in a comprehensible manner
on their websites or mobile applications, which can be accessed by consumers upon logging-in with their
unique credentials.
33https://www.prayaspune.org/peg/publications/item/418-five-stitches-in-time-regulatory-and-policy-actions-to-
ensure-effective-electricity-service.html
Along with this, data privacy of consumers remains an unchartered territory, that needs to be addressed
urgently34. High-resolution smart meter data, through analysis and inference, has the potential to reveal
personal information of consumers, such as occupancy, appliance usage patterns, and even sensitive
information like entertainment preferences. DISCOMs need to be cognizant of the upcoming data
protection legislation in the country and build institutional capacity for following protocols in the future.
Smart meters can be programmed to record and communicate real-time data and thus, can be used to
record power interruptions. If these recorded interruptions are longer than what is allowed in regulations,
automatic compensation could be paid to consumers. Consumer smart meters can enable payment of
compensation to consumers, automatically, for not adhering to standards of performance stated by SERCs
in SoP regulations. In fact, the recently notified Electricity (Rights of Consumers) Rules, 202035, by the
Ministry of Power, states that automatic compensation can be paid to consumers in case of (i) no supply
to a consumer beyond a particular duration, (ii) number of interruptions in supply beyond the limits
specified by the SERC. Even the Maharashtra SERC’s Supply Code regulations of 2021 mention that
automatic compensation is payable for restoration of supply, wherever smart meters are installed. As
technology evolves, such payments will become even more viable, overcoming the present transaction
costs that a consumer has to bear to claim compensation.
5.2. Direct Benefit Transfer of subsides with the help of smart meters
Smart meters can be employed for better targeting of revenue subsidies that are provided by state
governments. Targeting of subsidy has been an issue because consumption by agricultural consumers is
mostly subsidised, and since many of them are not metered, subsidies are often disbursed on the basis of
estimated sales36. Smart meters will ensure timely measurement of consumption and subsequently timely
disbursal.
34https://www.prayaspune.org/peg/resources/power-perspective-portal/259-handling-smart-meter-data-privacy-
concerns-preparedness-and-safeguards.html
35 https://powermin.gov.in/sites/default/files/webform/notices/Consumers_Rules_2020.pdf
36https://www.prayaspune.org/peg/publications/item/419-elephant-in-the-room-implications-of-subsidy-practices-
on-discom-finances.html
While timely meter reading and money disbursal will heavily depend on stable cellular network coverage
in agricultural fields, meters installation may need special casing to protect against typical surges and
weather impacts. Burning of switchboards due to voltage fluctuation issues is common, and this will affect
meter functioning. In such a situation prompt response is required for meter repair or replacement. Such
concerns call for implementation only after comprehensive pilot projects are conducted. Soon after the
scheme was announced, a pilot project was commissioned in Srikakulam district. Lessons from the pilot
project cannot be found in the public domain. Full scale rollouts are expected to be done in FY22.
DISCOMs need to effectively utilise the data collected from smart meters for performance improvement.
Such data can facilitate quicker detection of outages in the system, and identify load theft. It will also aid
load research and help in more accurate demand estimation. Depending on such analysis, DISCOMs can
formulate their capital expenditure plans for distribution network augmentation. Intellismart38, an initiative
by EESL, is offering data analytics services for DISCOMs to understand smart meter information. Going
forward, such services will become even more necessary. Thus, to reap full benefits of smart metering,
DISCOMs also need to invest in capacity building, to effectively handle large volumes of information.
6. Getting it right
Smart metering of electricity consumers is being implemented with great speed, country-wide. However,
there has been inadequate monitoring of rollout programmes so far. Not only is there a dearth of lessons
from pilot projects in the public domain, not much consistent information can be found about the status
of implementation programmes either. Uncertainty remains surrounding costs of these programmes and
how they will be passed onto consumers.
Perhaps this new technology has potential for huge benefits. However, it will require careful
implementation, which would only be possible through careful analysis, evaluation and learnings from pilot
projects. This is where the SERCs can play an important role in holding DISCOMs accountable, and
formulating regulations to ensure consumer protection.
Given all this, getting it right is much “smart”-er than getting it done fast!
-x-
37 Through government order, GO no. MS-22, dated 01.09.2020, can be accessed on: https://goir.ap.gov.in/
38 https://intellismartinfra.in/