BEFORE MAHARASHTRA ELECTRICITY REGULATORY COMMISSION PETITION FOR FINAL TRUE UP FOR FY 2017-18 & FY 2018-19, PROVISIONAL TRUE UP FOR FY 2019-20 AND MULTI YEAR TARIFF FOR FY 2020-21 TO FY 2024-25 Maharashtra State Electricity Distribution Company Ltd. Regd. Off: Prakashgad, Anant Kanekar Marg, Bandra (E), Mumbai-400051 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Executive Summary EXECUTIVE SUMMARY A. Background The Hon’ble Commission has issued the MYT Regulations 2019 for the 4th Control Period from FY 2020-21 to FY 2024-25 on 01st August, 2019. As per the provisions of Regulation 5.1(a) of the said Regulations, Distribution Licensee has to file Multi Year Tariff Petition (MYT Petition) by 30th November 2019. Accordingly, MSEDCL has submitted the MYT Petition on 26th November 2019. The MYT Petition under section 62 of the Electricity Act, 2003 and MERC MYT Regulations, 2019 comprises of following: • • • • • Truing-up for FY 2017-18 based on Audited Annual Accounts under MERC (MYT) Regulations, 2015; Truing-up for FY 2018-19 based on Audited Annual Accounts under MERC (MYT) Regulations, 2015; Provisional Truing-up for FY 2019-20 based on provisional information available for FY 2019-20 under MERC (MYT) Regulations, 2015; Aggregate Revenue Requirement, expected revenue from existing Tariff and charges, expected revenue gap, and proposed category-wise Tariff for the period FY20 20-21 to FY 2024-25 under MYT Regulations, 2019; Revision in Schedule of Charges; B. Final True Up for FY 2017-18 Based on the Audited Annual Accounts of MSEDCL, the Aggregate Revenue Requirement (ARR) for FY 2017-18 is determined at Rs. 66,010.58 Cr. based on all the cost parameters as specified in the following table. The final True Up for FY 2017-18 comparing the actual audited data for FY 2017-18 with those approved by the Hon’ble Commission vide MTR Order dated 12th September 2018 in Case no. 195 of 2017 is summarized below. MSEDCL January 20 -1- Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Executive Summary Rs. Crs Particulars Power Purchase Expenses Operation & Maintenance Expenses Depreciation Expenses Interest on Loan Capital Interest on Normative Working Capital Interest on Consumers Security Deposit Other Finance Charges Provision for bad and doubtful debts Other Expenses Intra-State Transmission Charges MSLDC charge Incentives/Discounts DSM expenses Return on Equity Capital RLC refund ASC refund Effect of sharing of gains/losses Past Period Adjustment by Commission Impact of payment to MPECS in future years Aggregate Revenue Requirement Revenue from Sale of Power Non-Tariff Income Income from Open Access Charges Income from Trading of Surplus Power Income from Wheeling Charges Income from Additional Surcharge Total Revenue Revenue Gap/(Surplus) FY 2017-18 (Approved) 49,129.74 6,990.67 2,183.38 1,586.38 129.90 740.35 491.53 63.30 4,812.17 246.58 0.88 1,826.01 (1,116.00) 46.20 67,131.10 60,538.76 447.80 536.17 179.94 1.46 118.88 61,823.01 5,308.08 FY 2017-18 (Actual) 48,422.63 6,807.02 2,118.85 1,372.34 130.48 632.60 28.34 680.73 386.47 4,812.17 242.40 4.30 1,739.62 0.70 0.49 (299.01) (1,116.00) 46.46 66,010.58 61,146.03 380.33 546.56 186.27 1.46 118.88 62,379.54 3,631.04 Deviation (707.11) (183.64) (64.54) (214.05) 0.58 (107.75) 28.34 189.20 323.18 (4.19) 3.42 (86.39) 0.70 0.49 (299.01) 0.26 (1,120.52) 607.27 (67.46) 10.40 6.33 556.53 (1,677.05) MSEDCL submits that at the time of Provisional True up for FY 2017-18, MSEDCL had submitted provisional numbers. As the MSEDCL’s Accounts have been audited subsequently, MSEDCL is submitting the final true-up based on the audited accounts. C. Final True Up for FY 2018-19 Based on the Audited Annual Accounts of MSEDCL, the Aggregate Revenue Requirement (ARR) for FY 2018-19 is determined at Rs. 76,942.44 Cr. based on all the cost parameters as specified in the following table. The final True Up for FY 2018-19 comparing the actual audited data for FY 2018-19 with those approved by the Hon’ble Commission vide MTR Order dated 12th September 2018 in Case no. 195 of 2017 is summarized below. MSEDCL January 20 -2- Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Executive Summary Rs. Crs Particulars Power Purchase Expenses Operation & Maintenance Expenses Depreciation Expenses Interest on Loan Capital Interest on Normative Working Capital Interest on Consumers Security Deposit Other Finance Charges Provision for bad and doubtful debts Other Expenses Income Tax Intra-State Transmission Charges MSLDC charge Incentives/Discounts Contribution to Contingency Reserves Return on Equity Capital RLC refund Revenue Gap Allowed Effect of sharing of gains/losses Past Period Adjustment by Commission Impact of payment to MPECS in future years Aggregate Revenue Requirement Revenue from Sale of Power Non-Tariff Income Income from Open Access Charges Income from Trading of Surplus Power Income from Wheeling Charges Income from Additional Surcharge Total Revenue Revenue Gap/(Surplus) FY 2018-19 (Approved) 50,589.49 7,344.40 2,329.48 1,592.72 124.43 741.41 26.33 66.47 4,302.54 258.91 1,985.60 2,256.56 (1,031.50) 43.18 70,630.03 68,813.54 1,051.19 641.33 1.53 122.44 70,630.02 FY 2018-19 (Actual) 56,260.34 6,912.20 2,464.00 1,350.25 132.39 665.28 26.11 732.63 65.07 215.08 4,775.50 287.38 126.00 1,812.34 1.67 2,256.56 (152.29) (1,031.50) 43.43 76,942.44 72,591.72 609.35 387.11 408.82 1.79 108.44 74,107.23 2,835.21 Deviation 5,670.85 (432.20) 134.52 (242.47) 7.96 (76.13) 26.11 706.30 (1.40) 215.08 472.96 28.47 126.00 (173.26) 1.67 (152.29) 0.25 6,312.41 3,778.18 (441.84) (254.22) 408.82 0.26 (14.00) 3,477.21 2,835.20 Major reasons for deviation are higher power purchase cost due to increased sales and increase in power purchase cost , higher revenue from sale of power, change in actual consumer mix vis-à-vis that approved by Hon’ble Commission; revision in normative O&M Expenses approved by Hon’ble Commission as the applicable WPI & CPI indices being different than those considered by Hon’ble Commission. D. Provisional True-up for FY 2019-20 Aggregate Revenue Requirement of MSEDCL for FY 2019-20 is estimated considering the provisional data available for the first six months of the FY 201920 and projections for the remaining six months. Based on the provisional true-up, the Aggregate Revenue Requirement (ARR) for FY 2019-20 is Rs. 79,850.07 Cr. The provisional True Up for FY 2019-20, comparing the estimated data with that approved by the Hon’ble Commission vide MSEDCL January 20 -3- Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Executive Summary MTR Order dated 12th September 2018 in Case no. 195 of 2017 is summarized below. Rs. Crs Particulars Power Purchase Expenses Operation & Maintenance Expenses Depreciation Expenses Interest on Loan Capital Interest on Normative Working Capital Interest on Consumers Security Deposit Other Finance Charges Provision for bad and doubtful debts Other Expenses Intra-State Transmission Charges MSLDC charge Incentives/Discounts Contribution to Contingency Reserves Return on Equity Capital RLC refund Past Period Adjustment by Commission Revenue Gap Allowed Impact of payment to MPECS Aggregate Revenue Requirement Revenue from Sale of Power Non-Tariff Income Income from Open Access Charges Income from Trading of Surplus Power Income from Wheeling Charges Income from Additional Surcharge Total Revenue Revenue Gap/(Surplus) FY 2019-20 (Approved) 52,738.26 7,715.47 2,411.41 1,471.03 126.77 815.54 69.79 4,863.74 271.86 2,145.59 853.08 2,562.93 40.17 76,085.65 74,179.45 1,103.75 674.71 1.62 126.12 76,085.65 FY 2019-20 (Estimated) 56,305.45 7,107.96 2,594.37 1,349.54 127.89 796.03 31.10 845.43 50.08 4,867.55 307.03 142.85 1,866.79 1.84 853.08 2,562.93 40.17 79,850.07 76,371.19 361.66 211.92 298.18 1.79 317.14 77,561.88 2,288.19 Deviation 3,567.19 (607.51) 182.96 (121.49) 1.11 (19.52) 31.10 845.43 (19.71) 3.81 35.17 (278.80) 1.84 3,764.43 2,191.74 (742.09) (462.80) 298.18 0.17 191.03 1,476.24 2,288.19 Major reasons for deviation are increase in power purchase expenses, change in revenue from sale of power due to change in consumer mix; and change in capex related expenses. MSEDCL submits that these deviations are beyond the reasonable control of MSEDCL. E. Aggregate Revenue Requirement for FY 2020-21 to FY 2024-25 The aggregate revenue requirement for the period i.e. FY 2020-21 to FY 2024-25 has been determined based on the provisions of the MYT Regulations, 2019 and certain assumptions. 1. Sales Projection MSEDCL has used historical trend method and estimated energy consumption for various consumer categories mostly using 3 year CAGR. Wherever it is MSEDCL January 20 -4- Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Executive Summary observed that the trend is unreasonable/unsustainable, the growth factors have been corrected to arrive at more realistic projections. MSEDCL has projected the sales for the period FY 2020-21 to FY 2024-25 considering the historical sales. The projection of Sales for HT category is outlined in the following table: Category HT-I Industries HT-II Commercial HT III Railways HT IV-PWW HT V Agricultural HT VI Bulk Supply (Housing Complex) HT Temporary HT-IX Public services MSPGCL AUX SUPPLY HT Ag Others HT EV Charging Stations Total -HT Sales FY 20-21 FY 21-22 Projected Projected 33,586 34,929 1,850 1,887 80 82 1,745 1,832 1,486 1,685 239 242 5 5 1,044 1,065 184 184 299 332 0.31 0.31 40,519 42,243 FY 22-23 FY 23-24 Projected Projected 36,326 37,779 1,925 1,963 84 85 1,924 2,020 1,919 2,192 244 246 5 5 1,086 1,108 184 184 368 410 0.31 0.31 44,065 45,993 FY 24-25 Projected 39,290 2,003 87 2,121 2,512 249 5 1,130 184 456 0.31 48,037 The projection of Sales for LT category is outlined in the following table: Category LT Category LT I -BPL LT I Domestic LT II Non Domestic LT III PWW LT IV Agriculture LT V Powerloom LT V Industrial General LT VI Streetlight LT VII- Temporary Connection LT VIII Advertisement & Hoardings LT IX – Crematoriums & Burial Grounds LT X - Public services LT XI EV Charging Stations Total LT Sales Total Sales MSEDCL FY 20-21 FY 21-22 FY 22-23 FY 23-24 FY 24-25 Projected Projected Projected Projected Projected 140 21,583 6,360 886 31,374 2,132 5,265 2,383 24 5 2 154 22,120 6,900 932 32,185 2,217 5,475 2,610 24 5 2 169 22,674 7,491 981 33,028 2,306 5,694 2,863 24 5 2 186 23,242 8,141 1,033 33,904 2,398 5,922 3,145 24 6 2 205 23,827 8,854 1,088 34,816 2,494 6,159 3,458 24 6 2 569 0.23 70,722 1,11,241 609 0.23 73,233 1,15,476 652 0.23 75,889 1,19,954 698 0.23 78,701 1,24,694 748 0.23 81,682 1,29,719 January 20 -5- Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Executive Summary 2. Power Purchase Considering the sales projections, MSEDCL has projected the power purchase for the period FY 2020-21 to FY 2024-25 based on the availability, operational parameters; expected commissioning of upcoming projects, decommissioning of old generating units in the period FY 2020-21 to FY 2024-25 and projected the power purchase cost based on MYT Petition filed by MSPGCL and merit order principles (MoD) for optimum utilization. The source-wise power purchase projection for the period FY 2020-21 to FY 2024-25 is summarised below: Particulars MSPGCL NTPC NPCIL SSP Pench Dodson JSW CGPL (Mundra UMPP) Adani Power EMCO Power Rattan India Renewable PGCIL Charges Total Power Purchase Quantum MU 55,307.12 25,598.81 4,884.58 1,209.94 136.50 115.72 1,913.18 5,157.89 20,937.22 1,355.17 20,272.00 1,36,888.13 FY 2020-21 Cost Rs. Cr. 24,806.74 9,815.06 1,396.92 248.05 27.98 17.78 692.67 1,515.68 7,869.57 613.16 692.48 9,862.29 3,676.18 61,234.57 Rate Quantum Rs/Unit MU 4.49 55,262.53 3.83 26,667.17 2.86 4,884.58 2.05 1,209.94 2.05 136.50 1.54 115.72 3.62 1,913.18 2.94 5,157.89 3.76 20,784.14 4.52 1,355.17 4.86 24,164.00 4.47 1,41,650.83 FY 2021-22 Cost Rs. Cr. 25,654.11 10,389.47 1,430.57 248.06 27.98 17.92 731.78 1,568.26 7,962.99 650.26 692.48 10,660.92 3,859.99 63,894.79 Rate Quantum Rs/Unit MU 4.64 55,144.56 3.90 26,742.79 2.93 4,884.58 2.05 1,209.94 2.05 136.50 1.55 115.72 3.82 810.03 3.04 5,157.89 3.83 20,937.22 4.80 1,355.17 4.41 30,151.00 4.51 1,46,645.40 FY 2022-23 Cost Rs. Cr. 26,397.72 10,611.73 1,465.12 248.06 27.98 18.11 417.68 1,623.54 8,254.69 679.87 692.48 12,965.83 4,052.99 67,455.81 Rate Rs/Unit 4.79 3.97 3.00 2.05 2.05 1.57 5.16 3.15 3.94 5.02 4.30 4.60 EMCO Rate will reduce after shifting connectivity from CTU to STU. Particulars MSPGCL NTPC NPCIL SSP Pench Dodson JSW CGPL (Mundra UMPP) Adani Power EMCO Power Rattan India Renewable PGCIL Charges Total Power Purchase Quantum MU 55,908.76 27,610.48 4,897.96 1,213.26 136.87 116.04 736.28 5,172.02 20,917.77 1,358.88 33,882.00 1,51,950.32 FY 2023-24 Cost Rs. Cr. 27,636.92 11,094.73 1,504.72 248.75 28.06 27.68 410.60 1,684.98 8,265.39 712.34 692.48 14,355.53 4,255.64 70,917.81 Rate Rs/Unit 4.94 4.02 3.07 2.05 2.05 2.39 5.58 3.26 3.95 5.24 4.24 4.67 Quantum MU 57,779.78 28,847.51 4,884.58 1,209.94 136.50 115.72 413.29 5,157.89 20,937.22 1,355.17 142.19 36,593.00 1,57,572.78 FY 2024-25 Cost Rs. Cr. 28,717.14 11,759.78 1,537.05 248.07 27.98 32.93 334.63 1,742.82 8,050.30 744.72 748.55 15,405.57 4,468.42 73,817.97 Rate Rs/Unit 4.97 4.08 3.15 2.05 2.05 2.85 8.10 3.38 3.84 5.50 4.21 4.68 EMCO Rate will reduce after shifting connectivity from CTU to STU. MSEDCL January 20 -6- Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Executive Summary 3. Distribution Losses MSEDCL has achieved a significant reduction in distribution losses during recent years. Accordingly, MSEDCL has projected the Distribution Loss trajectory for the 4th Control Period considering year on year 0.25% reduction as given below: Particulars Distribution Losses (Excluding EHV) FY 2020-21 Projected FY 2021-22 Projected FY 2022-23 Projected FY 2023-24 Projected FY 2024-25 Projected 13.01% 12.76% 12.51% 12.26% 12.01% 4. Segregation of Wires and Supply Business The Regulation 71 of MERC (Multi Year Tariff) Regulations, 2019 mentions about apportioning of Aggregate Revenue Requirement between the Distribution Wires Business and Retail Supply Business. MSEDCL has segregated the expenses based on the allocation matrix as provided in the regulations. 5. Aggregate Revenue Requirement (ARR) for the period FY 2020-2021 to FY 2024-2025 Aggregate Revenue Requirement of MSEDCL for the period FY 2020-21 to FY 2024-25 is projected considering projections for various components of ARR and provisions of MERC MYT Regulations, 2019. Also, the Revenue has been considered based on the existing tariff and accordingly the year wise revenue gap has been calculated as summarised in following table. MSEDCL January 20 -7- Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Executive Summary Particulars Power Purchase Expenses Operation & Maintenance Expenses Depreciation Expenses Interest on Loan Capital Interest on Working Capital Interest on Consumers Security Deposit Provision for bad and doubtful debts Other Expenses Intra-State Transmission Charges MSLDC charge Incentives/Discounts Contribution to Contingency Reserves Opex Scheme Return on Equity Capital Add: Impact of payment to MPECS in future years Aggregate Revenue Requirement Revenue from Sale of Power Non-Tariff Income Income from Open Access Charges Income from Additional Surcharge Total Revenue Revenue Gap/(Surplus) FY 2020-21 Projected 61,234.57 6,978.91 2,756.88 1,407.20 130.10 540.58 891.59 52.58 10,293.78 322.38 159.27 117.21 1,735.95 37.16 86,658.16 76,997.55 379.75 388.89 108.44 77,874.63 8,783.54 FY 2021-22 Projected 63,894.79 7,246.35 2,966.30 1,463.59 139.50 567.61 941.10 55.21 6,352.56 338.50 176.64 117.40 1,806.60 34.15 86,100.30 79,927.39 398.73 388.89 108.44 80,823.46 5,276.84 FY 2022-23 Projected 67,455.81 7,524.04 3,155.21 1,357.48 145.20 595.99 994.24 57.97 6,715.36 355.43 189.60 117.62 1,867.86 31.14 90,562.95 83,017.87 418.67 388.89 108.44 83,933.87 6,629.08 FY 2023-24 Projected 70,917.81 7,812.38 3,221.66 1,112.36 145.16 625.79 1,051.34 60.87 7,344.34 373.20 199.32 117.88 1,916.55 28.13 94,926.77 86,309.90 439.60 388.89 108.44 87,246.84 7,679.93 Rs. Cr. FY 2024-25 Projected 73,817.97 8,111.76 3,280.93 856.88 144.64 657.08 1,112.72 63.91 7,999.76 391.86 208.02 118.17 1,962.93 21.14 98,747.77 89,801.46 461.59 388.89 108.44 90,760.38 7,987.39 F. Additional Claims Hon’ble Commission in Order dated 24th December 2018 in case no. 321 of 2018 on review petition of MSEDCL on the MTR Order dated 12th Sept 2018 has approved certain costs for capital expenditure for the past years and restated the GFA for the respective period. MSEDCL has now claimed the impact of reinstatement of GFA In addition to this, MSEDCL has also claimed the costs allowed by Hon’ble Commission due to certain error apparent in the said order as provided below: Particulars Impact of reinstatement of GFA Inpact of Review order Total Amount (Rs. Crs) 606.55 216.68 823.22 G. Impact of Change in Law Supreme Court in the Energy Watchdog matter in Civil Appeal No. 5399-5400 vide its Judgement dated 11.04.2017 ruled that NCDP 2013 is a ”Change in Law’ and further elaborated that the party affected due to the Change in law be restituted to its’ same economical position. In line with this Judgement, Hon’ble Commission has issued various Orders in respect of M/s. APML for approval of various claims MSEDCL January 20 -8- Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Executive Summary under change in Law. Hon’ble Commission in these orders has allowed NCDP policy, SHAKTI policy, Cancellation of Lohara Coal Block as a Change in Law and has allowed relief to M/s. APML for past period from year 2013. In line with the Hon'ble Supreme Court order for Rajasthan Discoms to make payment of 50% of claim and considering the already paid amount of Rs.2266 Crore, MSEDCL is liable to pay amount of Rs. 4192 Crore to avoid the carrying cost impact and contempt of Court Order. Accordingly, the said amount of Rs. 4192 Crore to be paid is added to the revenue gap for the Control Period. MSEDCL also submits that the Appeals against above Orders on different grounds are pending at Appellate Authority and whenever above Appeals get finality in the respective courts and the Court issues Orders in the above matter of change in law for NCDP policy, SHAKTI policy, Cancellation of Lohara Coal Block, etc., MSEDCL shall pass on or recover such impact through FAC mechanism from consumers. Similarly, CERC issued Order on 16.05.2019 and has allowed claims to GMR Warora in respect of NCDP Policy considering SHR as per CERC Regulations and GCV on as received basis and MSEDCL has made payment of Rs. 81.34 Crores (i.e. 50 % of claim) to GMR as per the APTEL Judgment. H. Liquidation of Regulatory Assets MSEDCL submits that the Hon’ble Commission in its MTR Order approved total revenue gap of Rs. 20,651 Crs. However, recovery of only Rs. 8,268 Crs was allowed over a period of two years. Hon’ble Commission created Regulatory Assets of Rs. 12,382 Crs. Accordingly, MSEDCL has considered the recovery of Regulatory Assets along with its Carrying Cost. I. Carrying Cost Hon’ble Commission has been allowing carrying cost/holding cost on the revenue gap/surplus respectively. Also Hon’ble Commission in the MTR order in Case no.195 of 2017 dated 12th September 2018 has created Regulatory assets and has allowed the recovery of the same with carrying costs. Accordingly MSEDCL has computed carrying cost on previous regulatory assets, unrecovered gaps, impact of the review order and impact of reinstatement of GFA. J. Net recovery required from tariff Considering the revenue gap for FY 2017-18 to FY 2019-20, impact of order on MSEDCL January 20 -9- Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Executive Summary Review Petition (Case No 321 of 2018), impact of revised GFA, Regulatory Asset, carrying cost, along with the revenue gap projected for the period FY 2020-21 to FY 2024-25, the net recovery required from tariff works out to be Rs. 60,313.11 Cr. as shown in the following table. Particulars Final True Up Requirement for FY17-18 Final True Up Requirement for FY 18-19 Provisional True Up Requirement for FY 19-20 Projected Revenue Gap for FY 20-21 Projected Revenue Gap for FY 21-22 Projected Revenue Gap for FY 22-23 Projected Revenue Gap for FY 23-24 Projected Revenue Gap for FY 24-25 Impact of Review Order on MTR Order Impact of Reinstatement of GFA of Rs. 927 Crs Carrying Cost for previous gaps/impact and unrecovered gaps during Control Period Total Revenue Gap for the MYT Period Impact of Change in Law Regulatory Assets Carrying Cost on Regulatory Assets upto Mar-20 Recovery for Regulatory Assets Total Recovery Incremental Revenue from Cross Subsidy Surcharge Incremental Revenue from Additional Surcharge Net recovery from Tariff Amount Rs. Cr (1,677.05) 2,835.21 2,288.19 8,783.54 5,276.84 6,629.08 7,679.93 7,987.39 216.68 606.55 5,850.30 46,476.66 4,192.00 1,176.33 12,382.45 64,227.44 (1,129.33) (2,785.00) 60,313.11 K. Tariff Design There is an urgent need for ensuring recovery of full cost of service from consumers to sustain the operations of the Company. Hon’ble Commission has been guided by the Electricity Act, 2003 and the National Tariff Policy while determining retail tariffs. Hon’ble Commission has always laid emphasis on parameters which encourages economy, efficiency, effective performance and improved supply conditions of supply for consumers. MSEDCL requests the Hon’ble Commission to apply similar principles considering the ground realities as well as to ensure the financial viability of the Company. MSEDCL January 20 - 10 - Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Executive Summary The tariff design proposed by MSEDCL is based on the following principles: Rationalisation of Fixed Charges to ensure appropriate recovery of fixed costs through fixed charges; Revision in Billing Demand definition for appropriate recovery of Contract Demand expenses; kVAh based billing for HT Category consumers; Revision in Load Factor Formula for more clarity; Rebate for Incremental Consumption for HT Industrial, Commercial, Public services & railways to incentivise the additional sales; Grid Support Charges for Rooftop Net Metering Systems; Additional Fixed/Demand Charges for Rooftop RE Systems not opting for Net Metering or Net Billing Arrangement; Revision in Standby Charges for CPP; Revision in ToD Charges in view of the solar capacity addition; Introduction of Harmonics Penalty for HT industrial & Commercial category for power quality improvement; Revision in Schedule of charges; Provision of mandatory standby arrangement for SEZ and railways; Recovery of Cross Subsidy Surcharge as per NTP formula without any ceiling from Open Access consumers; Applicability of Additional Surcharge extended to all OA consumers including those sourcing power from CPP; L. Rationale for Tariff revision MSEDCL has proposed a revision in fixed and energy charges for various categories in order to bridge revenue gap. The tariff revision is necessary for meeting additional costs due to increase in generation & transmission costs, regulatory assets and legitimate expenses of MSEDCL. The revenue gap has emerged due to additional costs, which are beyond the control of MSEDCL. M. Cross-Subsidy Surcharge (CSS) Section 2 (47) of the Electricity Act defines “Open Access’, while Section 42 of the said Act inter – alia mandates the Distribution Licensee to provide Open Access to eligible consumers, subject to payment of “Cross Subsidy Surcharge”, “Additional MSEDCL January 20 - 11 - Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Executive Summary Surcharge” & other applicable charges. As per the provisions of Section 42(2) of the Electricity Act 2003, the CSS needs to be based on the current levels of cross subsidy. Accordingly, the consumers who opted for Open Access need to be charged for the compensation of current level of Cross Subsidy, which prevailed during that period and in order to avoid the burden of the same being passed on other consumers who are with the Distribution Licensee. Accordingly, MSEDCL has determined the cross subsidy surcharge based on the Tariff Policy formula without putting any ceiling. A representative Cross Subsidy Surcharge for HT Industrial Category is tabulated below: Consumer Category HT I HT - Industry HT EHV FY 2020-21 Rs/kVAh FY 2021-22 Rs/kVAh 2.57 2.83 FY 2022-23 Rs/kVAh 3.09 3.35 3.19 3.45 FY 2023-24 Rs/kVAh FY 2024-25 Rs/kVAh 3.31 3.57 3.46 3.71 N. Wheeling Charges Considering the provisions of MYT Regulations 2019, MSEDCL has proposed the Wheeling charges for HT (excluding EHV) and LT voltage levels as per the table given below: Particulars Units HT (Excl EHV) Rs./kVAh LT Level Rs./kWh FY 20-21 FY 21-22 FY 22-23 FY 23-24 FY 24-25 0.77 0.78 0.78 0.77 0.75 1.15 1.17 1.17 1.14 1.11 For the purpose of commercial settlement, MSEDCL proposes to continue following Wheeling Losses which are already approved in previous Tariff Orders. Particulars 33 kV 22 kV 11 kV LT MSEDCL Wheeling Losses 6.00% 7.50% 9.00% 12.00% January 20 - 12 - Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Executive Summary O. Additional Surcharge Section 42(4) provides for the levy of Additional Surcharge to a consumer who receives supply of electricity from a person other than the distribution licensee of his area of supply. Regulation 14.8 of the MERC Distribution OA Regulations, 2016 outlines the principles for determination and levy of Additional Surcharge. MSEDCL has proposed Additional Surcharge for Open Access Consumers irrespective of Source i.e. Captive Power Plants, IPP, RE based power plants etc. in addition to the conventional open access consumers. CPPs existing prior to FY15-16, originally set up the plant for self-consumption and still continuing the same arrangement of captive use, shall be exempted from applicability of additional surcharge. Particulars FY 2020-21 Proposed Additional Surcharge (Rs/kVAh) FY 2021-22 1.33 FY 2022-23 FY 2023-24 FY 2024-25 1.37 1.40 1.43 1.42 P. Grid Support Charges for Net Metering Systems As per MERC Grid Interactive Rooftop Renewable Energy Generating Systems Regulations, 2019, MSEDCL has proposed the Grid support charges for Net Metering Systems for the Control Period. A representative Grid Support Charge for HT Industrial Category is tabulated below: Category HT I HT - Industry HT EHV FY 2020-21 Rs./kVAh 4.08 3.60 FY 2021-22 Rs./kVAh FY 2022-23 Rs./kVAh 4.07 3.59 4.05 3.57 FY 2023-24 Rs./kVAh 4.03 3.57 FY 2024-25 Rs./kVAh 3.96 3.52 The Grid Support Charges for Rooftop Net Metering Arrangements shall vary depending on approval of any cost component that affects MSEDCL’s tariff, prevailing REC Rates etc. The RPO benefits shall be adjusted at the year-end i.e. at the time of settlement of banked units and after assessment of REC requirement, as per the actual monthly REC Rates and consumption by consumer during the respective month. MSEDCL January 20 - 13 - Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Executive Summary Net Metering Regulations 2019 provides that the consumers having Sanctioned Load up to 10 kW shall be exempted from payment of Grid Support Charges for Net Metering systems. Such loss for exemption from paying the Grid Support Charges needs to be recovered from the consumers having Sanctioned Load above 10 kW so as to avoid the burden on consumers not opting for Net Metering. Q. Additional Fixed/Demand Charges for Rooftop Solar Systems not opting for Net Metering or Net Billing Arrangement As per MERC Grid Interactive Rooftop Renewable Energy Generating Systems Regulations, 2019, MSEDCL has proposed the Additional Fixed/Demand Charges for the Control Period. Particulars Actual FC Recovery Required (Rs/Unit) Monthly units generated by 1 kw rooftop SPV (CUF-19%) Fixed Charges to be recovered (Rs./kW/Month) FY 20-21 FY 21-22 FY 22-23 FY 23-24 FY 24-25 4.23 3.86 3.83 3.81 3.73 138.7 645 138.7 589 138.7 584 138.7 581 138.7 568 In addition to the above, the subsidising consumers shall pay Cross Subsidy Surcharge as proposed by MSEDCL for the respective year of the Control Period for compensating the common consumers of MSEDCL for the current level cross subsidy. R. Tariff Applicability Every consumer of electricity has a unique applicability of tariff, depending upon the nature of power supply, purpose of power usage etc. which determines the class of consumer or category of the consumer. The Hon’ble Commission has accordingly classified the consumers of electricity into various categories depending upon the nature of power supply i.e. (Low Tension or High Tension), purpose of power/type of usage i.e. (Domestic, Non-domestic, Industrial, Agricultural, etc.) MSEDCL has examined the tariff applicability and based on the feedback received during interactions with field officers, MSEDCL has proposed certain modifications in applicability of tariff. MSEDCL January 20 - 14 - Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Executive Summary S. Tariff Schedule In MYT Regulations, the Hon’ble Commission has merged various HT voltage levels (11kV, 22kV etc.) into one and has kept only two categories. (HT and EHV). Accordingly MSEDCL has proposed tariffs for HT and EHV category. Further, in order to rationalise tariff categories, MSEDCL has proposed the following changes: • • • • Merged sub slabs in 0-20 kVA slab for Commercial and Public Services; kVA based demand charges for loads less than 20kW; Merging of 500-1000 units & above 1000 units slab into a slab of 500 units and above for Residential category; Slab wise fixed charges for Residential category consumers. A comparison of detailed Category/Sub-category wise Existing and Proposed Energy Charges (excl. Wheeling Charges) is shown in tables below: MSEDCL January 20 - 15 - Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Executive Summary Comparison of Existing and Proposed Energy Charges (excl. Wheeling Charges) for HT Category (1/2) Particulars HT I HT - Industry HT EHV HT I (B): HT - Industry (Seasonal) HT EHV HT II: HT – Commercial HT EHV HT III : HT - Railways/Metro/Monorail Traction HT EHV HT IV: HT - Public Water Works HT EHV HT V(A): HT - Agriculture Pumpsets HT EHV HT V(B): HT - Agriculture - Others HT EHV HT VI: HT - Group Housing Societies (Residential) HT EHV HT VIII(A): HT - Temporary Supply Religious (TSR) HT EHV HT VIII(B): HT - Temporary Supply Others (TSO) HT EHV HT IX: HT - Public Services HT IX(A): HT - Public Services-Govt. HT EHV HT IX(B): HT - Public Services-Others HT EHV HT X: HT – Electric Vehicle Charging Station HT EHV MSEDCL FY 2020-21 Energy Charges (Rs/Unit) % Change over Existing Proposed FY 2019-20 Approved FY 2021-22 Energy Charges (Rs/Unit) % Change over Proposed FY 2020-21 Proposed 7.07 7.07 7.11 7.11 1% 1% 7.20 7.20 1% 1% 7.34 7.34 7.40 7.40 1% 1% 7.50 7.50 1% 1% 11.73 11.73 11.70 11.70 0% 0% 11.70 11.70 0% 0% 7.00 7.00 7.20 7.20 3% 3% 7.40 7.40 3% 3% 6.30 6.30 6.50 6.50 3% 3% 6.70 6.70 3% 3% 3.77 3.77 3.90 3.90 3% 3% 4.00 4.00 3% 3% 5.20 5.20 5.40 5.40 4% 4% 5.60 5.60 4% 4% 5.82 5.82 6.00 6.00 3% 3% 6.20 6.20 3% 3% 3.75 3.75 3.90 3.90 4% 4% 4.00 4.00 3% 3% 12.00 12.00 12.40 12.40 3% 3% 12.80 12.80 3% 3% 7.90 7.90 8.00 8.00 1% 1% 8.10 8.10 1% 1% 9.70 9.70 9.90 9.90 2% 2% 10.00 10.00 1% 1% 5.24 5.24 5.40 5.40 3% 3% 5.60 5.60 4% 4% January 20 - 16 - Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Executive Summary Comparison of Existing and Proposed Energy Charges (excl. Wheeling Charges) for HT Category (2/2) Particulars HT I HT - Industry HT EHV HT I (B): HT - Industry (Seasonal) HT EHV HT II: HT – Commercial HT EHV HT III : HT - Railways/Metro/Monorail Traction HT EHV HT IV: HT - Public Water Works HT EHV HT V(A): HT - Agriculture Pumpsets HT EHV HT V(B): HT - Agriculture - Others HT EHV HT VI: HT - Group Housing Societies (Residential) HT EHV HT VIII(A): HT - Temporary Supply Religious (TSR) HT EHV HT VIII(B): HT - Temporary Supply Others (TSO) HT EHV HT IX: HT - Public Services HT IX(A): HT - Public Services-Govt. HT EHV HT IX(B): HT - Public Services-Others HT EHV HT X: HT – Electric Vehicle Charging Station HT EHV MSEDCL FY 2022-23 Energy Charges (Rs/Unit) % Change over Proposed FY 2021-22 Proposed FY 2023-24 Energy Charges (Rs/Unit) % Change over Proposed FY 2022-23 Proposed FY 2024-25 Energy Charges (Rs/Unit) % Change over Proposed FY 2023-24 Proposed 7.30 7.30 1% 1% 7.40 7.40 1% 1% 7.47 7.47 1% 1% 7.60 7.60 1% 1% 7.70 7.70 1% 1% 7.80 7.80 1% 1% 11.70 11.70 0% 0% 11.70 11.70 0% 0% 11.70 11.70 0% 0% 7.60 7.60 3% 3% 7.80 7.80 3% 3% 8.00 8.00 3% 3% 6.90 6.90 3% 3% 7.10 7.10 3% 3% 7.30 7.30 3% 3% 4.10 4.10 2% 2% 4.20 4.20 2% 2% 4.30 4.30 2% 2% 5.80 5.80 4% 4% 6.00 6.00 3% 3% 6.20 6.20 3% 3% 6.40 6.40 3% 3% 6.60 6.60 3% 3% 6.80 6.80 3% 3% 4.10 4.10 2% 2% 4.20 4.20 2% 2% 4.30 4.30 2% 2% 13.20 13.20 3% 3% 13.60 13.60 3% 3% 14.00 14.00 3% 3% 8.20 8.20 1% 1% 8.30 8.30 1% 1% 8.40 8.40 1% 1% 10.10 10.10 1% 1% 10.20 10.20 1% 1% 10.30 10.30 1% 1% 5.80 5.80 4% 4% 6.00 6.00 3% 3% 6.20 6.20 3% 3% January 20 - 17 - Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Executive Summary Comparison of Existing and Proposed Energy Charges (excl. Wheeling Charges) for LT Category (1/4) Particulars LT Residential LT I(A): LT - Residential-BPL LT I(B): LT - Residential 1-100 units 101-300 units 301-500 units >500 units LT II: LT - Non-Residential (A1) (i): 0 – 20 kVA (Upto 200 units per month) (A1) (ii): 0 – 20 kVA (Above 200 units per month) (A1) (iii) 0-20 kVA (Single phase) (B): >20 kVA and ≤ 50 kVA (C): >50 KVA LT III: LT - Public Water Works (PWW) (A): 0-20 KVA (B): >20 kVA and ≤ 40 kVA (C): >40 KVA LT IV: LT - Agriculture LT IV(A): LT - AG Un-metered - Pumpsets Category 1 Zones (Above 1318 Hrs/HP/Annum) (a) 0-5 HP (b) Above 5 HP - 7.5 HP (c) Above 7.5 HP Category 2 Zones (Below 1318 Hrs/HP/Annum) (a) 0-5 HP (b) Above 5 HP - 7.5 HP (c) Above 7.5 HP LT IV(B): LT - Agriculture Metered Tariff - Pumpsets LT IV(C): LT - Agriculture Metered – Others MSEDCL FY 2020-21 Energy Charges (Rs/unit) % Change over Existing Proposed FY 2019-20 Approved 1.10 1.36 3.05 6.95 9.90 11.50 3.30 7.30 9.90 11.50 24% 8% 5% 0% 0% FY 2021-22 Energy Charges (Rs/unit) % Change over Proposed FY 2020-21 Proposed 1.40 3% 3.50 7.50 9.90 11.50 6% 3% 0% 0% 8.10 3% 6.10 9.25 6.10-9.25 9.30 11.60 7.90 9.50 11.60 2% 0% 8.10 9.80 11.80 3% 3% 2% 2.15 3.50 4.80 2.30 3.60 4.90 7% 3% 2% 2.40 3.70 5.00 4% 3% 2% 7.90 Rs./HP/Month Rs./HP/Month 374 403 452 400 430 480 7% 7% 6% 420 455 505 5% 6% 5% 288 316 366 2.09 3.51 310 335 390 2.20 3.70 8% 6% 7% 5% 5% 330 355 410 2.30 3.80 6% 6% 5% 5% 3% January 20 - 18 - Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Executive Summary Comparison of Existing and Proposed Energy Charges (excl. Wheeling Charges) for LT Category (2/4) FY 2022-23 Energy Charges (Rs/unit) % Change over Proposed FY 2021-22 Proposed Particulars LT Residential LT I(A): LT - Residential-BPL LT I(B): LT - Residential 1-100 units 101-300 units 301-500 units >500 units LT II: LT - Non-Residential (A1) (i): 0 – 20 kVA (Upto 200 units per month) (A1) (ii): 0 – 20 kVA (Above 200 units per month) (A1) (iii) 0-20 kVA (Single phase) (B): >20 kVA and ≤ 50 kVA (C): >50 KVA LT III: LT - Public Water Works (PWW) (A): 0-20 KVA (B): >20 kVA and ≤ 40 kVA (C): >40 KVA LT IV: LT - Agriculture LT IV(A): LT - AG Un-metered - Pumpsets Category 1 Zones (Above 1318 Hrs/HP/Annum) (a) 0-5 HP (b) Above 5 HP - 7.5 HP (c) Above 7.5 HP Category 2 Zones (Below 1318 Hrs/HP/Annum) (a) 0-5 HP (b) Above 5 HP - 7.5 HP (c) Above 7.5 HP LT IV(B): LT - Agriculture Metered Tariff - Pumpsets LT IV(C): LT - Agriculture Metered – Others MSEDCL FY 2023-24 Energy Charges (Rs/unit) % Change over Proposed FY 2022-23 Proposed FY 2024-25 Energy Charges (Rs/unit) % Change over Proposed FY 2023-24 Proposed 1.50 7% 1.60 7% 1.70 6% 3.70 7.70 9.90 11.50 6% 3% 0% 0% 3.90 7.90 9.90 11.60 5% 3% 0% 1% 4.10 8.10 9.90 11.70 5% 3% 0% 1% 8.30 2% 8.50 2% 8.70 2% 8.30 10.10 12.00 2% 3% 2% 8.50 10.40 12.10 2% 3% 1% 8.70 10.70 12.20 2% 3% 1% 2.50 3.80 5.20 4% 3% 4% 2.60 3.90 5.40 4% 3% 4% 2.70 4.00 5.60 4% 3% 4% Rs./HP/Month Rs./HP/Month Rs./HP/Month 445 480 535 6% 5% 6% 470 505 565 6% 5% 6% 495 535 595 5% 6% 5% 350 375 435 2.40 4.00 6% 6% 6% 4% 5% 370 395 460 2.50 4.20 6% 5% 6% 4% 5% 390 415 485 2.60 4.40 5% 5% 5% 4% 5% January 20 - 19 - Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Executive Summary Comparison of Existing and Proposed Energy Charges (excl. Wheeling Charges) for LT Category (3/4) Particulars LT V (A): LT - Industry - Powerlooms (i): 0-20 KVA (ii): Above 20 KVA (iii) 0-20 kVA (Single phase) LT V(B): LT - Industry - General (i): 0-20 KVA (ii): Above 20 KVA (iii) 0-20 kVA (Single phase) LT VI: LT - Street Light (A): Grampanchayat; A B & C Class Municipal Council (B): Municipal corporation Area LT VII: LT - Temporary Connection (A): LT - Temporary Supply Religious (TSR) (B): LT - Temporary Supply Others (TSO) LT VIII: LT - Advertisements and Hoardings LT IX: LT - Crematorium and Burial Grounds LT X (A) - Public Services – Govt. (i): ≤ 20 kVA Upto 200 units) (i): ≤ 20 kVA (Above 200 units) (ia) ≤ 20 kVA (Single phase) (ii): >20 - ≤ 50 kVA iii): >50 kVA LT X(B) - Public Services - Others (i): ≤ 20 kVA Upto 200 units) (i): ≤ 20 kVA (Above 200 units) (ia) ≤ 20 kVA (Single phase) (ii): >20 - ≤ 50 kVA (iii): >50 kVA LT XI – Electric Vehicle Charging Station MSEDCL FY 2020-21 Energy Charges (Rs/unit) % Change over Existing Proposed FY 2019-20 Approved FY 2021-22 Energy Charges (Rs/unit) % Change over Proposed FY 2020-21 Proposed 4.69 6.02 4.69 4.90 6.30 4.90 4% 5% 4% 5.10 6.40 5.10 4% 2% 4% 4.81 5.70 4.81 5.00 5.90 5.00 4% 4% 4% 5.30 6.20 5.30 6% 5% 6% 4.80 5.85 4.90 6.00 2% 3% 5.00 6.20 2% 3% 3.27 12.79 12.00 3.26 3.40 13.20 12.40 3.40 4% 3% 3% 4% 3.50 13.60 12.80 3.50 3% 3% 3% 3% 3.90 5% 3.90 4.70 6.00 5% 4% 5% 5.80 6.10 5% 5.80 7.10 7.60 5.00 6.10 7.50 8.00 5.30 5% 6% 5% 6% 3.00 4.20 3.00-4.20 4.30 5.40 4.25 6.90 4.25-6.90 6.80 7.20 4.72 January 20 3.70 3.70 4.50 5.70 5% 6% 4% 6% 6% - 20 - Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Executive Summary Comparison of Existing and Proposed Energy Charges (excl. Wheeling Charges) for LT Category (4/4) Particulars LT V (A): LT - Industry - Powerlooms (i): 0-20 KVA (ii): Above 20 KVA (iii) 0-20 kVA (Single phase) LT V(B): LT - Industry - General (i): 0-20 KVA (ii): Above 20 KVA (iii) 0-20 kVA (Single phase) LT VI: LT - Street Light (A): Grampanchayat; A B & C Class Municipal Council (B): Municipal corporation Area LT VII: LT - Temporary Connection (A): LT - Temporary Supply Religious (TSR) (B): LT - Temporary Supply Others (TSO) LT VIII: LT - Advertisements and Hoardings LT IX: LT - Crematorium and Burial Grounds LT X (A) - Public Services – Govt. (i): ≤ 20 kVA *Upto 200 units) (i): ≤ 20 kVA (Above 200 units) (ia) ≤ 20 kVA (Single phase) (ii): >20 - ≤ 50 kVA iii): >50 kVA LT X(B) - Public Services - Others (i): ≤ 20 kVA Upto 200 units) (i): ≤ 20 kVA (Above 200 units) (ia) ≤ 20 kVA (Single phase) (ii): >20 - ≤ 50 kVA (iii): >50 kVA LT XI – Electric Vehicle Charging Station MSEDCL FY 2022-23 Energy Charges (Rs/unit) % Change over Proposed FY 2021-22 Proposed FY 2023-24 Energy Charges (Rs/unit) % Change over Proposed FY 2022-23 Proposed FY 2024-25 Energy Charges (Rs/unit) % Change over Proposed FY 2023-24 Proposed 5.40 6.60 5.40 6% 3% 6% 5.70 6.80 5.70 6% 3% 6% 6.00 7.00 6.00 5% 3% 5% 5.60 6.50 5.60 6% 5% 6% 5.90 6.80 5.90 5% 5% 5% 6.20 7.10 6.20 5% 4% 5% 5.20 6.40 4% 3% 5.40 6.60 4% 3% 5.60 6.80 4% 3% 3.60 14.00 13.20 3.60 3% 3% 3% 3% 3.70 14.40 13.60 3.70 3% 3% 3% 3% 3.80 14.80 14.00 3.80 3% 3% 3% 3% 4.10 5% 4.30 5% 4.50 5% 4.10 4.90 6.30 5% 4% 5% 4.30 5.10 6.60 5% 4% 5% 4.50 5.40 6.90 5% 6% 5% 6.40 5% 6.70 5% 7.00 4% 6.40 7.90 8.40 5.60 5% 5% 5% 6% 6.70 8.30 8.80 5.90 5% 5% 5% 5% 7.00 8.70 9.20 6.20 4% 5% 5% 5% January 20 - 21 - Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Executive Summary Comparison of Existing and Proposed Fixed Charges for HT Category (1/2) Particulars HT I HT - Industry HT, EHV HT I (B): HT - Industry (Seasonal) HT, EHV HT II: HT – Commercial HT, EHV HT III : HT - Railways/Metro/Monorail Traction HT, EHV HT IV: HT - Public Water Works HT, EHV HT V(A): HT - Agriculture Pumpsets HT, EHV HT V(B): HT - Agriculture - Others HT, EHV HT VI: HT - Group Housing Societies (Residential) HT, EHV HT VIII(A): HT - Temporary Supply Religious (TSR) HT, EHV HT VIII(B): HT - Temporary Supply Others (TSO) HT, EHV HT IX: HT - Public Services HT IX(A): HT - Public Services-Govt. HT, EHV HT IX(B): HT - Public Services-Others HT, EHV HT X: HT – Electric Vehicle Charging Station HT, EHV MSEDCL FY 2020-21 Fixed Charges (Rs/kVA/mth) % Change over FY 2019-20 Proposed Existing Approved FY 2021-22 Fixed Charges (Rs/kVA/mth) % Change over FY 2020-21 Proposed Proposed 391 431 10% 475 10% 391 431 10% 464 8% 391 421 8% 453 8% 391 431 10% 464 8% 391 421 8% 453 8% 69 87 26% 94 8% 69 87 26% 94 8% 313 337 8% 363 8% 418 460 10% 495 8% 391 431 10% 464 8% 391 421 8% 453 8% 391 421 8% 453 8% 70 76 9% 82 8% January 20 - 22 - Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Executive Summary Comparison of Existing and Proposed Fixed Charges for HT Category (2/2) Particulars HT I HT - Industry HT, EHV HT I (B): HT - Industry (Seasonal) HT, EHV HT II: HT – Commercial HT, EHV HT III : HT - Railways/Metro/Monorail Traction HT, EHV HT IV: HT - Public Water Works HT, EHV HT V(A): HT - Agriculture Pumpsets HT, EHV HT V(B): HT - Agriculture - Others HT, EHV HT VI: HT - Group Housing Societies (Residential) HT, EHV HT VIII(A): HT - Temporary Supply Religious (TSR) HT, EHV HT VIII(B): HT - Temporary Supply Others (TSO) HT, EHV HT IX: HT - Public Services HT IX(A): HT - Public Services-Govt. HT, EHV HT IX(B): HT - Public Services-Others HT, EHV HT X: HT – Electric Vehicle Charging Station HT, EHV MSEDCL FY 2022-23 Fixed Charges (Rs/kVA/mth) % Change over Proposed FY 2021-22 Proposed FY 2023-24 Fixed Charges (Rs/kVA/mth) % Change over Proposed FY 2022-23 Proposed FY 2024-25 Fixed Charges (Rs/kVA/mth) % Change over Proposed FY 2023-24 Proposed 523 10% 576 10% 634 10% 499 8% 537 8% 578 8% 487 8% 524 8% 564 8% 499 8% 537 8% 578 8% 487 8% 524 8% 564 8% 102 9% 110 8% 119 8% 102 9% 110 8% 119 8% 391 8% 421 8% 453 8% 533 8% 573 8% 616 8% 499 8% 537 8% 578 8% 487 8% 524 8% 564 8% 487 8% 524 8% 564 8% 89 9% 96 8% 104 8% January 20 - 23 - Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Executive Summary Comparison of Existing and Proposed Fixed Charges for LT Category (1/4) Particulars Units (Existing) LT Residential LT I(A): LT - Residential-BPL LT I(B): LT - Residential 1-100 units 101-300 units 301-500 units >500 units Three Phase Charges LT II: LT - Non-Residential (A1) (i): 0 – 20 kVA (Upto 200 units per month) (A1) (ii): 0 – 20 kVA (Above 200 units per month) (A2) 0-20 kVA (Single phase) (B): >20 kVA and ≤ 50 kVA (C): >50 KVA LT III: LT - Public Water Works (PWW) (A): 0-20 kVA (B): >20 kVA and ≤ 50 kVA (C): >50 KVA LT IV: LT - Agriculture LT IV(B): LT - Agriculture Metered Tariff - Pumpsets LT IV(C): LT - Agriculture Metered – Others MSEDCL Units (Proposed) Existing FY 2020-21 Fixed Charges % Change over Proposed FY 2019-20 Approved FY 2021-22 Fixed Charges % Change over Proposed FY 2020-21 Proposed Rs/conn/mth Rs/conn/mth 25 25 Rs/conn/mth Rs/conn/mth Rs/conn/mth Rs/conn/mth Rs/conn/mth Rs/conn/mth Rs/conn/mth Rs/conn/mth Rs/conn/mth Rs/conn/mth 90 90 90 90 320 100 110 110 120 350 11% 22% 22% 33% 9% 105 116 116 132 382 5% 5% 5% 10% 9% Rs/Conn/mth Rs/Conn/mth Rs/Conn/mth Rs/kVA/mth Rs/kVA/mth Rs/kVA/mth Rs/kVA/mth Rs/Conn/mth Rs/kVA/mth Rs/kVA/mth 391 391 391 391 391 207 - 218 5% 411 411 411 5% 5% 5% 432 432 432 5% 5% 5% Rs/kVA/mth Rs/kVA/mth Rs/kVA/mth Rs/kVA/mth Rs/kVA/mth Rs/kVA/mth 97 117 146 102 123 154 5% 5% 5% 108 130 162 6% 6% 5% Rs/HP/mth Rs/kW/mth Rs/HP/mth Rs/kW/mth 40 108 42 114 5% 6% 45 120 7% 5% January 20 0% 25 0% - 24 - Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Executive Summary Comparison of Existing and Proposed Fixed Charges for LT Category (2/4) Particulars LT Residential LT I(A): LT - Residential-BPL LT I(B): LT - Residential 1-100 units 101-300 units 301-500 units >500 units Three Phase Charges LT II: LT - Non-Residential (A1) (i): 0 – 20 kVA (Upto 200 units per month) (A1) (ii): 0 – 20 kVA (Above 200 units per month) (A2) 0-20 kVA (Single phase) (B): >20 kVA and ≤ 50 kVA (C): >50 KVA LT III: LT - Public Water Works (PWW) (A): 0-20 kVA (B): >20 kVA and ≤ 50 kVA (C): >50 KVA LT IV: LT - Agriculture LT IV(B): LT - Agriculture Metered Tariff - Pumpsets LT IV(C): LT - Agriculture Metered – Others MSEDCL FY 2022-23 Fixed Charges % Change over Proposed FY 2021-22 Proposed FY 2023-24 Fixed Charges % Change over Proposed FY 2022-23 Proposed FY 2024-25 Fixed Charges % Change over Proposed FY 2023-24 Proposed Units (Existing) Units (Proposed) Rs/conn/mth Rs/conn/mth 25 Rs/conn/mth Rs/conn/mth Rs/conn/mth Rs/conn/mth Rs/conn/mth Rs/conn/mth Rs/conn/mth Rs/conn/mth Rs/conn/mth Rs/conn/mth 111 122 122 146 417 6% 5% 5% 11% 9% 117 129 129 161 455 5% 6% 6% 10% 9% 123 136 136 178 497 5% 5% 5% 11% 9% Rs/Conn/mth Rs/Conn/mth Rs/Conn/mth Rs/kVA/mth Rs/kVA/mth Rs/kVA/mth Rs/kVA/mth Rs/Conn/mth Rs/kVA/mth Rs/kVA/mth 229 5% 241 5% 254 5% 454 454 454 5% 5% 5% 477 477 477 5% 5% 5% 501 501 501 5% 5% 5% Rs/kVA/mth Rs/kVA/mth Rs/kVA/mth Rs/kVA/mth Rs/kVA/mth Rs/kVA/mth 114 137 171 6% 5% 6% 120 144 180 5% 5% 5% 126 152 189 5% 6% 5% Rs/HP/mth Rs/kW/mth Rs/HP/mth Rs/kW/mth 48 126 7% 5% 51 133 6% 6% 54 140 6% 5% January 20 0% 25 0% 25 0% - 25 - Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Executive Summary Comparison of Existing and Proposed Fixed Charges for LT Category (3/4) Particulars Units (Existing) LT V (A): LT - Industry - Powerlooms (i): 0-20 KVA (ii): Above 20 KVA (iii) 0-20 kVA (Single phase) LT V(B): LT - Industry - General (i): 0-20 KVA (ii): Above 20 KVA (iii) 0-20 kVA (Single phase) LT VI: LT - Street Light (A): Grampanchayat; A B & C Class Municipal Council (B): Municipal corporation Area LT VII: LT - Temporary Connection (A): LT - Temporary Supply Religious (TSR) (B): LT - Temporary Supply Others (TSO) LT VIII: LT - Advertisements and Hoardings LT IX: LT - Crematorium and Burial Grounds LT X (A) - Public Services – Govt. (i): ≤ 20 kVA (Upto 200 units) (i): ≤ 20 kVA (Above 200 units) (ia) 0-20 kVA (Single phase) (ii): >20 - ≤ 50 kVA iii): >50 kVA LT X(B) - Public Services - Others (i): ≤ 20 kVA (Upto 200 units) (i): ≤ 20 kVA (Above 200 units) (ia) 0-20 kVA (Single phase) (ii): >20 - ≤ 50 kVA iii): >50 kVA LT XI – Electric Vehicle Charging Station MSEDCL Units (Proposed) FY 2020-21 Fixed Charges Existing Proposed % Change over FY 2019-20 Approved FY 2021-22 Fixed Charges % Change over Proposed FY 2020-21 Proposed Rs/Conn/mth Rs/kVA/mth Rs/Conn/mth Rs/kVA/mth Rs/kVA/mth Rs/Conn/mth 441 294 441 158 309 463 5% 5% 166 325 486 5% 5% 5% Rs/Conn/mth Rs/kVA/mth Rs/Conn/mth Rs/kVA/mth Rs/kVA/mth Rs/Conn/mth 441 294 441 158 309 463 5% 5% 166 325 486 5% 5% 5% Rs/kW/mth Rs/kW/mth Rs/kW/mth Rs/kW/mth 108 108 114 114 6% 6% 120 120 5% 5% Rs/Conn/mth Rs/Conn/mth Rs/Conn/mth Rs/Conn/mth Rs/Conn/mth Rs/Conn/mth Rs/Conn/mth Rs/Conn/mth 443 449 833 438 466 472 875 460 5% 5% 5% 5% 490 496 919 483 5% 5% 5% 5% Rs/Conn/mth Rs/Conn/mth Rs/Conn/mth Rs/kVA/mth Rs/kVA/mth Rs/kVA/mth Rs/kVA/mth Rs/Conn/mth Rs/kVA/mth Rs/kVA/mth 323 323 323 323 323 161 - 170 6% 340 340 340 5% 5% 5% 357 357 357 5% 5% 5% Rs/Conn/mth Rs/Conn/mth Rs/Conn/mth Rs/kVA/mth Rs/kVA/mth Rs/kVA/mth Rs/kVA/mth Rs/kVA/mth Rs/Conn/mth Rs/kVA/mth Rs/kVA/mth Rs/kVA/mth 351 351 351 351 351 70 252 - 265 5% 369 369 369 74 5% 5% 5% 6% 388 388 388 78 5% 5% 5% 5% January 20 - 26 - Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Executive Summary Comparison of Existing and Proposed Fixed Charges for LT Category (4/4) Particulars LT V (A): LT - Industry - Powerlooms (i): 0-20 KVA (ii): Above 20 KVA (iii) 0-20 kVA (Single phase) LT V(B): LT - Industry - General (i): 0-20 KVA (ii): Above 20 KVA (iii) 0-20 kVA (Single phase) LT VI: LT - Street Light (A): Grampanchayat; A B & C Class Municipal Council (B): Municipal corporation Area LT VII: LT - Temporary Connection (A): LT - Temporary Supply Religious (TSR) (B): LT - Temporary Supply Others (TSO) LT VIII: LT - Advertisements and Hoardings LT IX: LT - Crematorium and Burial Grounds LT X (A) - Public Services – Govt. (i): ≤ 20 kVA (Upto 200 units) (i): ≤ 20 kVA (Above 200 units) (ia) 0-20 kVA (Single phase) (ii): >20 - ≤ 50 kVA iii): >50 kVA LT X(B) - Public Services - Others (i): ≤ 20 kVA (Upto 200 units) (i): ≤ 20 kVA (Above 200 units) (ia) 0-20 kVA (Single phase) (ii): >20 - ≤ 50 kVA iii): >50 kVA LT XI – Electric Vehicle Charging Station FY 2022-23 Fixed Charges % Change over Proposed FY 2021-22 Proposed FY 2023-24 Fixed Charges % Change over Proposed FY 2022-23 Proposed FY 2024-25 Fixed Charges % Change over Proposed FY 2023-24 Proposed Units (Existing) Units (Proposed) Rs/Conn/mth Rs/kVA/mth Rs/Conn/mth Rs/kVA/mth Rs/kVA/mth Rs/Conn/mth 175 342 510 5% 5% 5% 184 360 536 5% 5% 5% 194 378 563 5% 5% 5% Rs/Conn/mth Rs/kVA/mth Rs/Conn/mth Rs/kVA/mth Rs/kVA/mth Rs/Conn/mth 175 342 510 5% 5% 5% 184 360 536 5% 5% 5% 194 378 563 5% 5% 5% Rs/kW/mth Rs/kW/mth Rs/kW/mth Rs/kW/mth 126 126 5% 5% 133 133 6% 6% 140 140 5% 5% Rs/Conn/mth Rs/Conn/mth Rs/Conn/mth Rs/Conn/mth Rs/Conn/mth Rs/Conn/mth Rs/Conn/mth Rs/Conn/mth 515 521 965 508 5% 5% 5% 5% 541 548 1,014 534 5% 5% 5% 5% 569 576 1,065 561 5% 5% 5% 5% Rs/Conn/mth Rs/Conn/mth Rs/Conn/mth Rs/kVA/mth Rs/kVA/mth Rs/kVA/mth Rs/kVA/mth Rs/Conn/mth Rs/kVA/mth Rs/kVA/mth 179 5% 188 5% 198 5% 375 375 375 5% 5% 5% 394 394 394 5% 5% 5% 414 414 414 5% 5% 5% Rs/Conn/mth Rs/Conn/mth Rs/Conn/mth Rs/kVA/mth Rs/kVA/mth Rs/kVA/mth Rs/kVA/mth Rs/kVA/mth Rs/Conn/mth Rs/kVA/mth Rs/kVA/mth Rs/kVA/mth 279 5% 293 5% 308 5% 408 408 408 82 5% 5% 5% 5% 429 429 429 87 5% 5% 5% 6% 451 451 451 92 5% 5% 5% 6% MSEDCL requests Hon’ble Commission to approve the tariff considering the Tariff Design principles and Other Suggestions made by MSEDCL. MSEDCL January 20 - 27 - Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Executive Summary T. Average Tariff Hike Following table provides the average tariff hike for the Control Period. Financial Year Revenue at Existing Tariff (Rs. Crs) Revenue at Proposed Tariff (Rs. Crs) Revenue Recovery (Rs. Crs) Sales (MU) Average Cost of Supply (ACoS) (Rs/kWh) % Increase/Decrease Approved for FY 19-20 69,086 74,179 5,093 1,08,369 6.85 FY 20-21 FY 21-22 FY 22-23 FY 23-24 FY 24-25 76,998 82,925 79,927 88,887 83,018 95,051 86,310 1,01,390 89,801 1,08,160 5,928 8,960 12,033 15,080 18,358 1,14,510 1,18,884 1,23,506 1,28,397 1,33,580 7.24 7.48 7.70 7.90 8.10 5.80% 3.25% 2.93% 2.61% 2.54% U. Cross Subsidy Trajectory MSEDCL submits that for certain categories such as HT Industrial, HT Commercial, HT Public Services etc., there is a reducing trend in cross subsidy. Further, for LT Residential, LT Public Services etc. there is increasing trend in cross subsidy. However, considering the recovery of proposed revenue gap, changes in tariff design and philosophy, there is a need to revise the tariff for various categories. Accordingly, MSEDCL has proposed the tariffs to recover the proposed revenue gap. MSEDCL January 20 - 28 - Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Executive Summary FY 2020-21 FY 2021-22 FY 2022-23 FY 2023-24 FY 2024-25 Category HT I (A): HT - Industry HT II: HT - Commercial HT III: HT - Railways/Metro/Monorail Traction HT IV: HT - Public Water Works (PWW) HT V: HT - Agriculture Pumps HT VI: HT - Group Housing Societies HT VIII: HT - Temporary Supply HT IX : HT - Public Services Govt HT IX : HT - Public Services Others HT Total LT I: LT - Residential LT II: LT - Non-Residential LT III: LT - Public Water Works (PWW) LT IV: LT - Agriculture Metered LT V (A): LT - Industry - Power Looms LT V (B): LT - Industry – General LT VI: LT - Street Light LT VIII: LT - Advertisements and Hoardings LT IX: LT - Crematorium and Burial Grounds LT X- Public Services Govt. LT X- Public Services Others LT Total Projected Projected 125% 211% 146% 113% 62% 116% 233% 148% 175% 126% 100% 158% 58% 51% 101% 122% 90% 282% 71% 98% 130% 85% 124% 207% 147% 114% 61% 118% 238% 148% 174% 124% 100% 157% 58% 51% 101% 123% 88% 285% 71% 99% 131% 86% Projected 123% 203% 148% 114% 61% 120% 243% 148% 172% 123% 100% 155% 57% 51% 101% 125% 88% 289% 70% 99% 132% 86% Projected 122% 200% 150% 115% 60% 123% 250% 149% 171% 122% 101% 154% 57% 51% 102% 127% 88% 294% 69% 99% 134% 87% Projected 122% 197% 152% 115% 59% 125% 257% 150% 170% 121% 101% 152% 57% 51% 102% 128% 88% 299% 69% 100% 135% 87% V. Prayers MSEDCL most respectfully prays to the Hon’ble Commission: 1. To admit the MYT Petition as per the provisions of the MERC (MYT) Regulations 2019 and consider present Petition for further proceedings before Hon’ble Commission; 2. To approve the total recovery of Aggregate Revenue Requirement and revenue gap for FY 2017-18 to FY 2024-25 along with other claims including Regulatory Assets as proposed by MSEDCL; 3. To allow the carrying cost on the proposed recovery required during the control period; 4. To approve mechanism for recovery of computed revenue gap along with carrying cost and Tariff Schedule considering the Tariff Design principles and other suggestions proposed by MSEDCL; 5. To allow to charge 60% of approved fixed charges for single shift HT Industrial consumers as proposed by MSEDCL; 6. To allow the revision in definition of Billing Demand as proposed by MSEDCL; MSEDCL January 20 - 29 - Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Executive Summary 7. To allow kVAh based billing for HT category consumers; 8. To allow a rebate for incremental consumption to HT consumers of selected categories as proposed by MSEDCL; 9. To consider the incentives/rebates proposed as part of ARR; 10. To rationalize the incentives and penalties as proposed by MSEDCL; 11. To approve the revision in Load Factor Formula as proposed by MSEDCL; 12. To approve the revision in the Load Factor Incentive with a ceiling of 7.50%; 13. To approve the revision in ToD Charges as proposed by MSEDCL; 14. To approve the levy of Grid Support charges on generated energy for Net Metering systems as proposed by MSEDCL; 15. To approve the Additional Fixed/Demand Charges along with CSS for Grid Connected Renewable Energy Generating Systems connected behind the Consumer’s meter, and not opting for either Net Metering Arrangement or Net Billing Arrangement as proposed by MSEDCL; 16. To approve the kVA based Fixed Charges for 3 phase consumers having loads less than 20 kVA as proposed by MSEDCL; 17. To allow the levy of slab wise charges to LT three phase consumers based on the actual demand recorded; 18. To allow MSEDCL to retain the transmission charges collected from partial Open access consumers; 19. To approve levy of harmonics penalty through additional charge equivalent to 5% of Variable Charges (Wheeling Charges plus Energy Charges) for HT Industrial and HT Commercial consumers; 20. To approve Cross Subsidy Surcharge and all such other charges including wheeling charges and wheeling losses for Open Access consumers as proposed for the Control Period; 21. To approve the Additional Surcharge for Open Access Consumers irrespective of Source i.e. Captive Power Plants, IPP, RE based power plants etc. in addition to the conventional open access consumers but exempting CPPs existing prior to FY15-16, originally set up the plant for self-consumption and still continuing the same arrangement of captive use as proposed by MSEDCL 22. To allow revision in standby charges for consumers having CPP; 23. To make provision for mandatory standby arrangement by SEZ and other Deemed Licensees; 24. To allow the slab wise fixed charges for Residential category consumers as MSEDCL January 20 - 30 - Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Executive Summary proposed by MSEDCL; 25. To approve the suggested categorization for different type of activities as proposed by MSEDCL; 26. To approve the schedule of charges as proposed by MSEDCL; 27. To approve the CAPEX and Capitalisation as submitted by MSEDCL; 28. To approve the OPEX as proposed by MSEDCL; 29. To grant any other relief as the Hon'ble Commission may consider appropriate; 30. To pass any other order as the Hon’ble Commission may deem fit and appropriate under the circumstances of the case and in the interest of justice; 31. To condone any error/omission and to give opportunity to rectify the same; 32. To permit MSEDCL to make further submissions, addition and alteration to this Petition as may be necessary from time to time; (Satish Chavan) Director (Commercial) MSEDCL MSEDCL January 20 - 31 - Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition TABLE OF CONTENTS 1 2 3 4 BACKGROUND ................................................................................................................................... 1 1.1 Introduction ........................................................................................................................................ 1 1.2 Provisions of Law .............................................................................................................................. 1 1.3 MSEDCL Submission ....................................................................................................................... 3 1.4 Appeal No. 280 of 2019 before Hon’ble APTEL, New Delhi ...................................................... 3 REVISED O&M EXPENSES FOR FY 2015-16 ................................................................................. 5 2.1 Preamble ............................................................................................................................................ 5 2.2 Revised O&M Expenses for FY 2015-16 ...................................................................................... 6 IMPACT OF THE RECONCILIATION OF OPENING GFA .............................................................. 8 3.1 Preamble ............................................................................................................................................ 8 3.2 Gross Fixed Assets........................................................................................................................... 8 3.3 Depreciation ..................................................................................................................................... 10 3.4 Interest on Long Term Loans ........................................................................................................ 10 3.5 Return on Equity ............................................................................................................................. 11 3.6 Summary of impact of reinstatement of GFA.............................................................................. 13 FINAL TRUE UP FOR FY 2017-18 .................................................................................................. 14 4.1 Preamble .......................................................................................................................................... 14 4.2 Category Wise Sales for FY 2017-18 .......................................................................................... 14 4.3 Distribution Losses for FY 2017-18 .............................................................................................. 15 4.4 Energy Balance for FY 2017-18 ................................................................................................... 15 4.5 Power Purchase Expenses for FY 2017-18 ................................................................................ 20 4.6 Intra State Transmission Charges for FY 2017-18 .................................................................... 23 4.7 Fixed Costs for FY 2017-18 .......................................................................................................... 24 4.8 Actual Operation & Maintenance Expenses for FY 2017-18 .................................................... 24 4.9 Normative Operation & Maintenance Expenses for FY 2017-18 ............................................. 27 4.10 Capitalisation for FY 2017-18 ....................................................................................................... 28 4.11 Depreciation for FY 2017-18 ......................................................................................................... 29 4.12 Funding Arrangement for FY 2017-18 ......................................................................................... 30 4.13 Interest Expenses for FY 2017-18................................................................................................ 31 4.14 Interest on Working Capital for FY 2017-18 ............................................................................... 33 4.15 Other Finance Charges for FY 2017-18 ...................................................................................... 35 4.16 Provision for Bad Debts for FY 2017-18 ...................................................................................... 36 4.17 Other Expenses for FY 2017-18 ................................................................................................... 38 4.18 Contribution to Contingency Reserves for FY 2017-18 ............................................................ 38 4.19 Incentives and Discounts for FY 2017-18 ................................................................................... 39 MSEDCL January 20 i Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 5 4.20 RLC Refund for FY 2017-18.......................................................................................................... 39 4.21 ASC Refund for FY 2017-18 ......................................................................................................... 39 4.22 Return on Equity for FY 2017-18 .................................................................................................. 40 4.23 Sharing of Efficiency Gains & Losses for FY 2017-18 .............................................................. 41 4.24 Impact of payment to MPECS for FY 2017-18 ........................................................................... 44 4.25 Past Period Adjustment by Commission for FY 2017-18 .......................................................... 45 4.26 Aggregate Revenue Requirement for FY 2017-18 .................................................................... 45 4.27 Revenue from sale of electricity for FY 2017-18 ........................................................................ 46 4.28 Non-Tariff Income for FY 2017-18................................................................................................ 47 4.29 Income from Open Access Charges for FY 2017-18 ................................................................ 49 4.30 Income from Trading of Surplus Power for FY 2017-18 ........................................................... 49 4.31 Income from Wheeling Charges for FY 2017-18........................................................................ 50 4.32 Income from Additional Surcharge for FY 2017-18 ................................................................... 50 4.33 Revenue Gap/(Surplus) for FY 2017-18 ...................................................................................... 50 TRUE UP OF FY 2018-19 ................................................................................................................. 52 5.1 Preamble .......................................................................................................................................... 52 5.2 Category Wise Sales for FY 2018-19 .......................................................................................... 52 5.5 Distribution Losses for FY 2018-19 .............................................................................................. 55 5.6 Energy Balance for FY 2018-19 ................................................................................................... 55 5.7 Power Purchase Expenses for FY 2018-19 ................................................................................ 57 5.8 Transmission Charges for FY 18-19 ............................................................................................ 62 5.9 Fixed Costs for FY 2018-19 .......................................................................................................... 63 5.10 Actual Operation & Maintenance Expenses for FY 2018-19 .................................................... 63 5.11 Normative Operation & Maintenance Expenses for FY 2018-19 ............................................. 64 5.12 Capitalisation for FY 2018-19 ....................................................................................................... 65 5.13 Depreciation for FY 2018-19 ......................................................................................................... 67 5.14 Funding Pattern for FY 2018-19 ................................................................................................... 67 5.15 Interest Expenses for FY 2018-19................................................................................................ 68 5.16 Interest on Working capital for FY 2018-19 ................................................................................ 69 5.17 Other Finance Charges for FY 2018-19 ...................................................................................... 72 5.18 Provision for Bad Debts for FY 2018-19 ...................................................................................... 73 5.19 Other Expenses for FY 2018-19 ................................................................................................... 74 5.20 Contribution to Contingency Reserves for FY 2018-19 ............................................................ 75 5.21 Income Tax ...................................................................................................................................... 76 5.22 Incentives and Discounts for FY 2018-19 ................................................................................... 76 5.23 RLC Refund for FY 2018-19.......................................................................................................... 76 5.24 Return on Equity for FY 2018-19 .................................................................................................. 77 5.25 Sharing of Efficiency Gains & Losses for FY 2018-19 .............................................................. 78 5.26 Impact of payment to MPECS for FY 2018-19 ........................................................................... 81 MSEDCL January 20 ii Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 6 5.27 Past Period Adjustment by Commission for FY 2018-19 .......................................................... 81 5.28 Revenue Gap Recovery Allowed for FY 2018-19 ...................................................................... 82 5.29 Aggregate Revenue Requirement for FY 2018-19 .................................................................... 82 5.30 Revenue from sale of electricity for FY 2018-19 ........................................................................ 84 5.31 Non-Tariff Income for FY 2018-19................................................................................................ 84 5.32 Income from Open Access Charges for FY2018-19.................................................................. 85 5.33 Income from Trading of Surplus Power for FY 2018-19 ........................................................... 86 5.34 Income from Wheeling Charges for FY 2018-19........................................................................ 86 5.35 Income from Additional Surcharge for FY 2018-19 ................................................................... 86 5.36 Revenue Gap/(Surplus) for FY 2018-19 ...................................................................................... 87 PROVISIONAL TRUE UP OF FY 2019-20 ...................................................................................... 89 6.1 Preamble .......................................................................................................................................... 89 6.2 Principles of Truing-up for FY 2019-20 ........................................................................................ 89 6.3 Category Wise Sales for FY 2019-20 .......................................................................................... 89 6.4 Distribution Losses for FY 2019-20 .............................................................................................. 90 6.5 Energy Balance for FY 2019-20 ................................................................................................... 90 6.6 Power Purchase Expenses for FY 2019-20 ................................................................................ 92 6.7 Transmission Charges for FY 2019-20 ........................................................................................ 93 6.8 Fixed Costs for FY 2019-20 .......................................................................................................... 93 6.9 Normative Operation & Maintenance Expenses for FY 2019-20 ............................................. 94 6.10 Capitalisation for FY 2019-20 ....................................................................................................... 95 6.11 Depreciation for FY 2019-20 ......................................................................................................... 97 6.12 Funding Pattern for FY 2019-20 ................................................................................................... 97 6.13 Interest Expenses for FY 2019-20................................................................................................ 98 6.14 Interest on Working capital for FY 2019-20 ................................................................................ 99 6.15 Other Finance Charges ................................................................................................................ 101 6.16 Provision for Bad Debts for FY 2019-20 .................................................................................... 102 6.17 Other Expenses for FY 2019-20 ................................................................................................. 103 6.18 Provision for Contribution to Contingency Reserves for FY 2019-20 ................................... 103 6.19 Incentives and Discounts for FY 2019-20 ................................................................................. 104 6.20 RLC Refund for FY 2019-20........................................................................................................ 104 6.21 Return on Equity for FY 2019-20 ................................................................................................ 105 6.22 Impact of payment to MPECS for FY 2019-20 ......................................................................... 106 6.23 Past Period Adjustment by Commission for FY 2019-20 ........................................................ 106 6.24 Revenue Gap Recovery Allowed for FY 2019-20 .................................................................... 107 6.25 Aggregate Revenue Requirement for FY 2019-20 .................................................................. 107 6.26 Revenue for FY 2019-20 ............................................................................................................. 109 6.27 Non-Tariff Income for FY 2019-20.............................................................................................. 109 6.28 Income from Open Access Charges for FY 2019-20 .............................................................. 110 MSEDCL January 20 iii Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 7 6.29 Income from Trading of Surplus Power for FY 2019-20 ......................................................... 110 6.30 Income from Wheeling Charges for FY 2019-20...................................................................... 110 6.31 Income from Additional Surcharge for FY 2019-20 ................................................................. 111 6.32 Revenue Gap/(Surplus) for FY 2019-20 .................................................................................... 111 AGGREGATE REVENUE REQUIREMENT FOR FY 20-21 TO FY 24-25 .................................. 113 7.1 Preamble ........................................................................................................................................ 113 7.2 Approach for Sales Projection for Control Period .................................................................... 113 7.3 CAGR considered for Sales Projection for Control Period ..................................................... 115 7.4 Sales Projections for Control Period .......................................................................................... 118 7.5 Sales projections for Distribution Franchisees for Control Period ......................................... 119 7.6 Approach for No. of Consumers Projection for Control Period .............................................. 120 7.7 CAGR considered for Projection of Nos. Consumer for Control Period ............................... 121 7.8 Number of Consumer Projections for Control Period .............................................................. 124 7.9 Approach for Connected Load/ Contract Demand Projection for Control Period ................ 126 7.10 CAGR considered for Connected Load/Contract Demand Projection .................................. 127 7.11 Connected Load Projections for Control Period ....................................................................... 129 7.12 Segregation of Wires and Supply Business for Control Period ............................................. 131 7.13 Estimation of ARR for Control Period ........................................................................................ 133 7.14 Power Purchases Expenses for Control Period ....................................................................... 133 7.15 Assumptions for power purchase for Control Period ............................................................... 134 7.16 Assumptions for source wise Power Purchase Projection for Control Period ..................... 135 7.17 Intra State Transmission Charges .............................................................................................. 140 7.18 Distribution Loss for the Control Period ..................................................................................... 141 7.19 Energy Balance for Control Period ............................................................................................. 142 7.20 Operation & Maintenance Expenses for Control Period ......................................................... 144 7.21 Opex for the Control Period ......................................................................................................... 145 7.22 Capex and Capitalisation for Control Period ............................................................................. 146 7.23 Funding Pattern of the Capitalisation for Control Period......................................................... 147 7.24 Depreciation for Control Period .................................................................................................. 147 7.25 Interest on Long Term Loan for Control Period ........................................................................ 148 7.26 Interest on Working Capital for Control Period ......................................................................... 149 7.27 Other Finance Charges for Control Period ............................................................................... 152 7.28 Provision for Bad Debts for Control Period ............................................................................... 152 7.29 Other Expenses for Control Period ............................................................................................ 154 7.30 Contribution to Contingency Reserves for Control Period ...................................................... 155 7.31 Incentives and Discounts for Control Period ............................................................................. 156 7.32 Income Tax for Control Period .................................................................................................... 157 7.33 Return on Equity for Control Period ........................................................................................... 158 7.34 Impact of payment to MPECS in Control Period ...................................................................... 161 MSEDCL January 20 iv Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 8 9 7.35 Revenue from sale of electricity for Control Period ................................................................. 161 7.36 Non-Tariff Income for Control Period ......................................................................................... 162 7.37 Income from Open Access Charges for Control Period .......................................................... 163 7.38 Income from Additional Surcharge for Control Period ............................................................. 163 7.39 Aggregate Revenue Requirement for Control Period .............................................................. 163 ADDITIONAL CLAIMS AND NET RECOVERY FROM TARIFF ................................................. 166 8.1 Impact of Reinstatement of GFA of Rs. 927 Crs ...................................................................... 166 8.2 Impact of capitalisation of DPDC for FY 16-17 in MTR Order ............................................... 167 8.3 Impact of Review Order ............................................................................................................... 167 8.4 Impact of Change in Law in Power Purchase ........................................................................... 170 8.5 Carrying Cost on previous Gap and other Claims ................................................................... 174 8.6 Carrying Cost on unrecovered revenue gap during Control Period ...................................... 177 8.7 Incremental Revenue from CSS and Additional Surcharge ................................................... 177 8.8 Net Recovery from Tariff .............................................................................................................. 177 TARIFF DESIGN AND METHODOLOGY ...................................................................................... 179 9.1 Tariff Design Principles ................................................................................................................ 179 9.2 Full Cost Recovery ....................................................................................................................... 179 9.3 Rationalization of Fixed Cost ...................................................................................................... 180 9.4 Revision in Billing Demand .......................................................................................................... 184 9.5 Penalty for Contract Demand Violations ................................................................................... 188 9.6 kVAh Based Billing ....................................................................................................................... 190 9.7 Recording of Maximum Demand ................................................................................................ 200 9.8 Revision in Load Factor Formula................................................................................................ 202 9.9 Rebate for Incremental Consumption ........................................................................................ 205 9.10 9.11 Prepaid Meter Rebate .................................................................................................................. 207 kVA based Fixed Charges for Loads < 20 kW & consideration of Load in kVA instead of kW 208 9.12 Grid Support Charges for Rooftop Net Metering Arrangements ............................................ 211 9.13 Additional Demand/Fixed Charges for Rooftop Grid Connected RE Systems not opting for Net Metering or Net Billing Arrangement ................................................................................................. 218 9.14 InSTS Charges for Open Access Consumers .......................................................................... 220 9.15 Change in Slabs for Commercial and Public Services ............................................................ 223 9.16 Standby Charges for Captive Power Producers ...................................................................... 223 9.17 Standby Charges for SEZs and Deemed Licensees ............................................................... 226 9.18 Revision in ToD Rates ................................................................................................................. 229 9.19 Harmonics Penalty........................................................................................................................ 230 9.20 Petitions by MSEDCL in Past Regarding Harmonics .............................................................. 233 9.21 Compliance of Directives in Case No.34 of 2011 .................................................................... 233 MSEDCL January 20 v Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 9.22 Regulatory Provisions for Harmonics......................................................................................... 234 9.23 Proposal for Harmonics Penalty ................................................................................................. 237 9.24 Expenses for Go Green Initiative (E-Copy of the Bill) ............................................................. 238 9.25 Expenses for SMS Service .......................................................................................................... 241 9.26 Revision in Reconnection Charges for Restoration of Power Supply ................................... 243 9.27 Additional Suggestions for Tariff Applicability ........................................................................... 246 9.28 Modification in Tariff Applicability ............................................................................................... 248 9.29 Any Other submission .................................................................................................................. 250 10 SHARING OF CROSS SUBSIDY IMPACT DUE TO AG CONSUMERS IN MAHARASHTRA 251 11 WHEELING CHARGES ................................................................................................................... 255 11.1 12 13 14 15 16 Network Cost of MSEDCL ........................................................................................................... 255 TARIFF RECOVERY MECHANISM ............................................................................................... 259 12.1 Background .................................................................................................................................... 259 12.2 Rationale of Tariff Hike................................................................................................................. 260 12.3 Proposed Recovery from Tariff ................................................................................................... 274 12.4 ABR/ACoS Ratio ........................................................................................................................... 274 12.5 Cross Subsidy Trajectory............................................................................................................. 280 CROSS SUBSIDY SURCHARGE .................................................................................................. 282 13.1 Background .................................................................................................................................... 282 13.2 Lower CSS approved ................................................................................................................... 283 13.3 CSS as Compensatory Charge .................................................................................................. 285 13.4 Computation of Cross Subsidy Surcharge for the Control Period ......................................... 286 ADDITIONAL SURCHARGE .......................................................................................................... 296 14.1 Background .................................................................................................................................... 296 14.2 Backing down due to surplus power scenario .......................................................................... 297 14.3 Surcharge Computation ............................................................................................................... 300 PROPOSED TARIFF APPLICABILITY.......................................................................................... 304 15.1 Background .................................................................................................................................... 304 15.2 LT Category ................................................................................................................................... 305 15.3 HT Category .................................................................................................................................. 333 DETAILS OF CAPEX SCHEMES ................................................................................................... 352 16.1 INFRA-II Scheme .......................................................................................................................... 352 16.2 INFRA PART II Scheme in 7 Towns .......................................................................................... 352 16.3 Feeder Separation Scheme ........................................................................................................ 353 16.4 R-APDRP Scheme ....................................................................................................................... 355 MSEDCL January 20 vi Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 16.5 SCADA Part A ............................................................................................................................... 357 16.6 SCADA Part B ............................................................................................................................... 358 16.7 Integrated Power Development Scheme (IPDS-I) ................................................................... 359 16.8 Deen Dayal Upadhyay Gram Jyoti Yojana (DDUGJY) ........................................................... 361 16.9 SAP ERP Project .......................................................................................................................... 362 16.10 DC/DR IT Infra Up-Gradation – I ................................................................................................ 364 16.11 DPDC/Non-Tribal .......................................................................................................................... 366 16.12 DPDC/Special Component Plan ................................................................................................. 367 16.13 DPDC/TSP+OTSP (District Wise) .............................................................................................. 368 16.14 Backlog Removal Scheme .......................................................................................................... 370 16.15 AG Special Package for Vidarbha & Marathwada ................................................................... 370 16.16 Saubhagya Scheme ..................................................................................................................... 371 16.17 Providing and Fixing of Energy Metering Arrangement At 33kv & 22kv Incoming Feeders at 33/11kv Substations & 22kv Switching Stations. .................................................................................... 372 17 18 16.18 HVDS Scheme .............................................................................................................................. 373 16.19 High Loss Feeder (HLF) Scheme ............................................................................................... 374 16.20 System Strengthening in Metropolitan Region (SSMR Scheme) .......................................... 376 16.21 GIS Survey..................................................................................................................................... 377 16.22 Procurement of Modems For AMR ............................................................................................ 379 16.23 Network Bandwidth Service Providers for AMR & Other Projects (NBSP UMBRELLA) .... 380 16.24 Scheme for East Vidharbha (Shet-tale): .................................................................................... 381 16.25 Energy Command & Control Center .......................................................................................... 382 16.26 National Cyclone Risk Mitigation Project ................................................................................... 384 16.27 Mukhyamantri Sour Krishi Vahini Yojana (MSKVY) ................................................................ 385 16.28 Mukhyamantri Saur Krushi Pump Yojana (MSKPY) ................................................................ 388 DETAILS OF OPEX SCHEMES ..................................................................................................... 391 17.1 Customer Care Center ................................................................................................................. 391 17.2 Go Green Initiative ........................................................................................................................ 393 17.3 SMS Services ................................................................................................................................ 395 17.4 RF-DCU (Expression of Interest & Tender) .............................................................................. 397 17.5 Substation Monitoring System (SMS) ........................................................................................ 399 17.6 MSEDCL Cloud Project ............................................................................................................... 403 17.7 Annual Technical Support of SAP/HANA/Oracle Software Licences.................................... 405 17.8 Vehicle Tracking System ............................................................................................................. 407 CONSUMER SERVICE INITIATIVES ............................................................................................ 409 18.1 Mobile App for Consumers .......................................................................................................... 409 18.2 SMS Alerts & E-mail notifications to Consumers ..................................................................... 409 18.3 Online Cash Collection System (OCCS) ................................................................................... 411 MSEDCL January 20 vii Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 19 18.4 MahaPowerPay Wallet: ................................................................................................................ 411 18.5 Online Address Correction & Name change facility ................................................................. 412 18.6 Consumer outreach through Social Media such as Twitter, Facebook ................................ 412 18.7 Integration of MSEDCL IT system with Aaple Sarkar / Maitri / Garv / Urja portal ............... 412 18.8 Centralized Billing ......................................................................................................................... 413 18.9 RF Metering & AMR for HT Consumers, Feeders ................................................................... 414 18.10 HT Consumer Portal ..................................................................................................................... 415 18.11 Online Refund of Security Deposit / Electricity Duty................................................................ 415 18.12 Proposed Consumer Services .................................................................................................... 415 PROPOSAL FOR SCHEDULE OF CHARGES ............................................................................. 417 19.1 Background .................................................................................................................................... 417 19.2 Calculations for Service Connection Charges .......................................................................... 419 19.3 Cost of Meters and Hiring charges ............................................................................................. 424 19.4 Hiring Charges: ............................................................................................................................. 427 19.5 Miscellaneous and General charges .......................................................................................... 429 19.6 Installation Inspection & Testing Fees: ...................................................................................... 430 19.7 Reconnection Charges: ............................................................................................................... 431 19.8 Changing Location of the Meter within the same premises (shifting of service is not required) at consumer’s request: .............................................................................................................. 432 20 19.9 Shifting of services/Poles/Lines (Utility), if carried out only on consumer’s request: .......... 432 19.10 Testing of Meters/Equipment ...................................................................................................... 433 19.11 Administrative Charges for Cheque Bouncing: ........................................................................ 436 19.12 Schedule of Charges for Open Access & all Generators ........................................................ 436 19.13 MSEDCL’s reasoning for proposed Charges: .......................................................................... 436 19.14 Applicable Taxes:.......................................................................................................................... 437 COMPLIANCE TO THE DIRECTIVES IN CASE NO. 195 OF 2017 ............................................ 438 20.1 21 Background .................................................................................................................................... 438 PRAYERS TO THE HON’BLE COMMISSION .............................................................................. 440 MSEDCL January 20 viii Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition LIST OF TABLES Table 1: O&M Expenses for Distribution Wires Business for FY 2015-16 .................................................. 6 Table 2: O&M Expenses for Retail Supply Business for FY 2015-16 .......................................................... 6 Table 3: Sharing of gains on account of O&M Expenses FY 15-16 ............................................................. 7 Table 4: Reinstatement of GFA ......................................................................................................................... 8 Table 5: Comparison of the capitalization and funding of the capitalization for FY 07-08 ........................ 9 Table 6: Impact of Reinstatement of GFA on Depreciation ......................................................................... 10 Table 7: Revised Normative Loan Balance for FY 12-13 ............................................................................ 11 Table 8: Impact of Reinstatement of GFA on Interest on Loans................................................................. 11 Table 9: Impact of Reinstatement of GFA on Return on Equity .................................................................. 12 Table 10: Summary of Impact of Reinstatement of GFA ............................................................................. 13 Table 11: Category wise sales for FY 17-18 .................................................................................................. 14 Table 12: Distribution Losses for FY 17-18 .................................................................................................... 15 Table 13: Energy Available for Sales for FY 17-18 ....................................................................................... 16 Table 14: Energy Balance for FY 17-18 ......................................................................................................... 19 Table 15: Power Purchase Expenses for FY 17-18...................................................................................... 21 Table 16: Transmission Charges for FY 2017-18 ......................................................................................... 23 Table 17: Actual O&M Expenses for FY 2017-18 ......................................................................................... 24 Table 18: O&M Expenses for Wires and Supply Business for FY 17-18 .................................................. 28 Table 19: Capitalisation for FY 17-18 ............................................................................................................. 28 Table 20: Addition to GFA as per Annual Accounts for FY 17-18 .............................................................. 29 Table 21: Depreciation for FY 17-18 ............................................................................................................... 30 Table 22: Funding of Capitalisation for FY 2017-18 ..................................................................................... 31 Table 23: Computation of weighted avg. interest rate for FY 17-18........................................................... 32 Table 24: Interest Expenses for FY 17-18 ..................................................................................................... 32 Table 25: Working of weighted average Base Rate ..................................................................................... 33 Table 26: Interest on Working Capital for Wire business for FY 17-18 ..................................................... 34 Table 27: Working Capital for Retail Supply business for FY 17-18 .......................................................... 35 Table 28: Other Finance Charges for FY 17-18 ............................................................................................ 36 Table 29: Provision for bad and doubtful debts for FY 2017-18 ................................................................. 37 Table 30: Provision for Bad and Doubtful Debt (Wire and Supply) FY 2017-18 ...................................... 37 Table 31: Other Expenses for FY 2017-18 .................................................................................................... 38 Table 32: Incentives/discounts for FY 17-18 ................................................................................................. 39 Table 33: RLC Refund for FY 17-18 ............................................................................................................... 39 Table 34: ASC Refund for FY 17-18 ............................................................................................................... 39 Table 35: RoE for wires business for FY 17-18............................................................................................. 41 Table 36: RoE for Supply business for FY 17-18 .......................................................................................... 41 Table 37: Sharing of Efficiency Gains/(Losses) on O&M and IoWC Expenses for FY 2017-18 ............ 43 Table 38: Efficiency Gains/(Losses) due to lower Distribution Loss in FY 2017-18 ................................ 44 MSEDCL January 20 ix Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 39: Impact of sharing of gains and losses for FY 17-18 .................................................................... 44 Table 40: ARR for Wires Business for FY 17 -18 ......................................................................................... 45 Table 41: ARR for Supply Business for FY 17 -18 ....................................................................................... 46 Table 42: Revenue from Sale of power for FY 17-18 ................................................................................... 46 Table 43: Category wise Revenue for FY 2017-18 ....................................................................................... 47 Table 44: Non-Tariff Income for FY 17-18 ..................................................................................................... 48 Table 45: Income from Open Access Charges for FY 17-18 ...................................................................... 49 Table 46: Details of Income Open Access Charges for FY 17-18 .............................................................. 49 Table 47: Income from Trading of Surplus Power for FY 17-18 ................................................................. 50 Table 48: Income from Wheeling Charges for FY 2017-18 ......................................................................... 50 Table 49: Income from Additional Surcharge for FY 2017-18 ..................................................................... 50 Table 50: Revenue Gap/Surplus for FY 17-18 .............................................................................................. 51 Table 51: Category wise Sales for FY 2018-19............................................................................................. 52 Table 52: Increase in AG Sales FY 18-19 (Half Yearly) .............................................................................. 53 Table 53: Increase in AG Sales FY 18-19 (Yearly)....................................................................................... 53 Table 54: Distribution Losses FY 2018-19 ..................................................................................................... 55 Table 55: Energy Sales for MSEDCL for FY 2018-19 .................................................................................. 56 Table 56: Energy Requirement and Energy Balance FY 2018-19 ............................................................. 57 Table 57: Source wise Power Purchase for FY 18-19 ................................................................................. 58 Table 58: Transmission Charges paid to Transmission Licensee for FY 2018-19 .................................. 62 Table 59: Actual O&M Expenses for FY 2018-19 ......................................................................................... 63 Table 60: Escalation factor for FY 2018-19 ................................................................................................... 65 Table 61: O&M Expenses for FY 2018-19 ..................................................................................................... 65 Table 62: Capitalisation for FY 2018-19 ......................................................................................................... 66 Table 63: Capitalization as per Audited Accounts for FY 2018-19 ............................................................. 66 Table 64: Depreciation for FY 2018-19 .......................................................................................................... 67 Table 65: Funding Pattern of Capitalization for FY 2018-19 ....................................................................... 68 Table 66: Rate of Interest for FY 2018-19...................................................................................................... 68 Table 67: Interest Expenses for FY 2018-19 ................................................................................................. 69 Table 68: Calculation of Weighted Avg. Arte of MCLR ................................................................................ 70 Table 69: Interest on Working Capital for Wire business for FY 18-19 ..................................................... 71 Table 70: Interest on Working capital for Supply business for FY 18-19 .................................................. 72 Table 71: Other Finance Charges for FY 2018-19 ....................................................................................... 72 Table 72: Computation of provision for bad and doubtful debts for FY 2018-19 ...................................... 74 Table 73: Provision for Bad debts for FY 2018-19 ........................................................................................ 74 Table 74: Other Expenses FY 2018-19 .......................................................................................................... 75 Table 75: Contingency Reserve for FY 2018-19 ........................................................................................... 75 Table 76: Income Tax for FY 18-19 ................................................................................................................ 76 Table 77: Incentives/Discount for FY 18-19 ................................................................................................... 76 Table 78: RLC Refund for FY 18-19 ............................................................................................................... 77 MSEDCL January 20 x Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 79: RoE for Wires Business for FY 18-19 ........................................................................................... 78 Table 80: RoE for Retail Supply Business for FY 18-19 .............................................................................. 78 Table 81: O&M Expenses & Interest on Working Capital for FY 18-19 ..................................................... 80 Table 82: Sharing of Gains/Losses by MSEDCL & Consumers for FY 18-19 .......................................... 80 Table 83: Impact of Sharing of Gains/Losses for FY 18-19 ........................................................................ 81 Table 84: Revenue Recovery allowed in MTR for FY 2018-19................................................................... 82 Table 85: ARR for Distribution Wires for FY 18-19 ....................................................................................... 83 Table 86: ARR for Supply Business for FY 18-19......................................................................................... 83 Table 87: Revenue from Sale of Power for FY 18-19 .................................................................................. 84 Table 88: Non-Tariff Income for FY 18-19 ..................................................................................................... 84 Table 89: Income from Open Access Charges for FY 18-19 ...................................................................... 85 Table 90: Income from Trading of Surplus Power for FY 18-19 ................................................................. 86 Table 91: Income from Wheeling Charges for FY 18-19 ............................................................................. 86 Table 92: Income from Additional Surcharge for FY 18-19 ......................................................................... 87 Table 93: ARR for Wires & Supply Business for the FY 2018-19............................................................... 88 Table 94: Category wise Sales for FY 2019-20............................................................................................. 90 Table 95: Distribution Losses FY2019-20 ...................................................................................................... 90 Table 96: Energy Sales for FY 2019-20 ......................................................................................................... 91 Table 97: Energy Requirement and Energy Balance FY 2019-20 ............................................................. 92 Table 98: Source wise estimated Power Purchase for FY 2019-20 ........................................................... 93 Table 99: Transmission Charges paid to Transmission Licensee for FY 2019-20 .................................. 93 Table 100: O&M Expenses for FY 2019-20 ................................................................................................... 94 Table 101: Capitalisation for FY 2019-20 ....................................................................................................... 95 Table 102: Capitalisation for FY 2019-20 ....................................................................................................... 97 Table 103: Depreciation for FY 2019-20 ........................................................................................................ 97 Table 104: Funding Pattern of Capitalisation for FY 2019-20 ..................................................................... 98 Table 105: Interest Expenses for FY 2019-20 ............................................................................................... 99 Table 106: Interest on Working Capital for Wire business for FY 2019-20 ............................................. 100 Table 107: Interest on Working capital for Supply business for FY 2019-20 .......................................... 101 Table 108: Other Finance Charges ............................................................................................................... 101 Table 109: Computation of Provision for Bad Debt for FY 19-20 ............................................................. 102 Table 110: Provision for Bad debts for FY 2019-20.................................................................................... 103 Table 111: Other Expenses for FY 2019-20 ................................................................................................ 103 Table 112: Contingency Reserve for FY 2019-20....................................................................................... 104 Table 113: Incentives/Discount for FY 2019-20 .......................................................................................... 104 Table 114: Refund of RLC for FY 2019-20 .................................................................................................. 105 Table 115: RoE for wires business for FY 2019-20 .................................................................................... 105 Table 116: RoE for retail supply business for FY 2019-20 ........................................................................ 106 Table 117: Revenue Gap Recovery Allowed for FY 2019-20 ................................................................... 107 Table 118: ARR for Wires Business for the FY 2019-20 ........................................................................... 108 MSEDCL January 20 xi Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 119: ARR for Supply Business for the FY 2019-20 ......................................................................... 108 Table 120: Revenue for FY 2019-20 ............................................................................................................. 109 Table 121: Non-Tariff Income for FY 2019-20 ............................................................................................. 109 Table 122: Income from Open Access Charges FY 2019-20 ................................................................... 110 Table 123: Income from Power trading of surplus power for FY 2019-20 ............................................... 110 Table 124: Income from Wheeling Charges FY 2019-20 .......................................................................... 110 Table 125: Income from Additional Surcharge for FY 2019-20................................................................. 111 Table 126: Revenue Gap/ (Surplus) for FY 2019-20 .................................................................................. 112 Table 127: Historical Sales Growth and CAGR (HT Category) ................................................................ 114 Table 128: Historical Sales Growth and CAGR (LT Category) ................................................................. 115 Table 129: CAGR Considered for Sales Projections (HT Category)........................................................ 116 Table 130: CAGR Considered for Sales Projections (LT Category) ........................................................ 117 Table 131: Sales Projections (HT category) for the Control Period ......................................................... 118 Table 132: Sales Projections (LT Category) ................................................................................................ 119 Table 133: Input Sales for Bhiwandi DF for the Control Period ................................................................ 120 Table 134: Historical Growth and CAGR No. of Consumers (HT Category) .......................................... 121 Table 135: Historical Growth and CAGR No. of Consumers (LT Category) ........................................... 121 Table 136: CAGR Considered for No. of Consumers Projections (HT Category) ................................. 123 Table 137: CAGR Considered for No. of Consumers Projections (LT Category) .................................. 124 Table 138: No. of Consumers Projections (HT category) for the Control Period ................................... 125 Table 139: No. of Consumers Projections (LT category) for the Control Period .................................... 125 Table 140: Historical Growth and CAGR connected load/Contract Demand (HT Category) ............... 126 Table 141: Historical Growth and CAGR connected load/Contract Demand (LT Category) ................ 127 Table 142: CAGR Considered for Contract Demand Projections (HT Category) .................................. 128 Table 143: CAGR Considered for Connected Load/Contract Demand Projections (LT Category) ..... 129 Table 144: Connected load/contract demand Projections (HT category) for the Control Period ......... 130 Table 145: Connected load/contract demand Projections (LT category) for the Control Period ......... 131 Table 146: Segregation for Retail Supply and Wires Business Expenses .............................................. 132 Table 147: Source wise Power Purchase quantum and cost for FY 2020-21 to FY 2022-23 .............. 139 Table 148: Source wise Power Purchase quantum and cost for FY 2023-24 to FY 2024-25 .............. 139 Table 149: Intra State Transmission charges for Control Period .............................................................. 141 Table 150: Proposed Distribution Loss for the Control Period .................................................................. 142 Table 151: Total Energy Sales for MSEDCL for FY 2020-21 to FY 2024-25 ......................................... 142 Table 152: Energy Balance for FY 2020-21 to FY 2022-23 ...................................................................... 143 Table 153: Energy Balance for FY 2023-24 to FY 2024-25 ...................................................................... 144 Table 154: Normative O&M Expenses for the Control Period................................................................... 145 Table 155: Opex Schemes for the Control Period ...................................................................................... 146 Table 156: Capital expenditure and capitalisation for the Control Period ............................................... 146 Table 157: Funding Pattern of the Capitalisation for the Control Period ................................................. 147 Table 158: Depreciation for the Control Period ........................................................................................... 148 MSEDCL January 20 xii Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 159: Interest Expenses on Long Term Loan for the Control Period .............................................. 149 Table 160: Interest on Working Capital and SD for Wires Business for the Control Period ................. 150 Table 161: Interest on Working Capital and SD for Supply Business for the Control Period ............... 152 Table 162: Provision for Bad and Doubtful Debt for Wires Business for the Control Period ................ 154 Table 163: Provision for Bad and Doubtful Debt for Supply Business for the Control Period .............. 154 Table 164: Other Expenses for the Control Period ..................................................................................... 155 Table 165: Contribution to contingency reserve for the Control Period ................................................... 156 Table 166: Incentives/Discounts for the Control Period ............................................................................. 156 Table 167: ROE for wires business for the Control Period ........................................................................ 160 Table 168: ROE for Retail Supply business for the Control Period .......................................................... 160 Table 169: Impact of payment to MPECS in Control Period ..................................................................... 161 Table 170: Revenue from Sale of Power at Existing Tariff for the Control Period ................................. 161 Table 171: Non-Tariff Income for the Control Period.................................................................................. 162 Table 172: Income from Open Access Charges for the Control Period .................................................. 163 Table 173: Income from Additional Surcharge for the Control Period ..................................................... 163 Table 174: ARR for Wires Business for the Control Period ....................................................................... 164 Table 175: ARR for Supply Business for the Control Period ..................................................................... 164 Table 176: Combined ARR for Supply and Wires Business for the Control Period ............................... 165 Table 177: Net Impact of Reinstatement of GFA of Rs. 927 Crs .............................................................. 166 Table 178: Impact of DPDC Disallowance for FY 16-17 ............................................................................ 167 Table 179: Impact of Revised O&M Expenses for FY 15-16 and FY 16-17 ........................................... 168 Table 180: Impact of Correction in Distribution Loss for FY 2016-17 ...................................................... 169 Table 181: Total Impact of Review Order..................................................................................................... 170 Table 182: Calculation of carrying cost on previous claims ...................................................................... 176 Table 183: Carrying Cost on Unrecovered Revenue Gap during the Control Period ............................ 177 Table 184: Net Recovery from Tariff ............................................................................................................. 178 Table 185: Category-wise energy consumption details in kVAh and kWh .............................................. 197 Table 186: Proposed Grid Support Charges for Rooftop Net Metering Arrangements (FY 20-21) ..... 214 Table 187: Grid Support Charges for Rooftop Net Metering Arrangements (HT Category) ................. 215 Table 188: Grid Support Charges for Rooftop Net Metering Arrangements (LT Category) ................. 216 Table 189: Additional Fixed/Demand Charges for Grid Connected RE Generating Systems connected behind the Consumer’s meter .............................................................................................................. 220 Table 190: Network Cost of MSEDCL for FY 2020-21 to FY 2024-25 .................................................... 255 Table 191: Segregation of GFA for the Control Period .............................................................................. 256 Table 192: Network cost apportioned for the Control Period .................................................................... 256 Table 193: Voltage Wise Consumption for the Control Period ................................................................. 257 Table 194: Calculation of Wheeling Cost for FY 20-21 .............................................................................. 257 Table 195: Proposed Wheeling Charges for FY 2020-21 .......................................................................... 258 Table 196: Proposed Wheeling Charges for the Control Period............................................................... 258 Table 197: Proposed Wheeling Losses for the Control Period ................................................................. 258 MSEDCL January 20 xiii Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 198: Comparison of Existing and Proposed Energy Charges (excl. Wheeling Charges) for HT Category (1/2) ......................................................................................................................................... 262 Table 199: Comparison of Existing and Proposed Energy Charges (excl. Wheeling Charges) for HT Category (2/2) ......................................................................................................................................... 263 Table 200: Comparison of Existing and Proposed Energy Charges (excl. Wheeling Charges) for LT Category (1/4) ......................................................................................................................................... 264 Table 201: Comparison of Existing and Proposed Energy Charges (excl. Wheeling Charges) for LT Category (2/4) ......................................................................................................................................... 265 Table 202: Comparison of Existing and Proposed Energy Charges (excl. Wheeling Charges) for LT Category (3/4) ......................................................................................................................................... 266 Table 203: Comparison of Existing and Proposed Energy Charges (excl. Wheeling Charges) for LT Category (4/4) ......................................................................................................................................... 267 Table 204: Comparison of Existing and Proposed Fixed Charges for HT Category (1/2) .................... 268 Table 205: Comparison of Existing and Proposed Fixed Charges for HT Category (2/2) .................... 269 Table 206: Comparison of Existing and Proposed Fixed Charges for LT Category (1/4) ..................... 270 Table 207: Comparison of Existing and Proposed Fixed Charges for LT Category (2/4) ..................... 271 Table 208: Comparison of Existing and Proposed Fixed Charges for LT Category (3/4) ..................... 272 Table 209: Comparison of Existing and Proposed Fixed Charges for LT Category (4/4) ..................... 273 Table 210: ABR and Cross Subsidy trajectory for FY 2020-21................................................................. 275 Table 211: ABR and Cross Subsidy trajectory for FY 2021-22................................................................. 276 Table 212: ABR and Cross Subsidy trajectory for FY 2022-23................................................................. 277 Table 213: ABR and Cross Subsidy trajectory for FY 2023-24................................................................. 278 Table 214: ABR and Cross Subsidy trajectory for FY 2024-25................................................................. 279 Table 215: Cross Subsidy Trajectory for the Control Period ..................................................................... 281 Table 216: Computation of C for the Control Period .................................................................................. 286 Table 217: Computation of System Loss for the Control Period............................................................... 287 Table 218: Computation of Wheeling Charge D for the Control Period ................................................... 288 Table 219: Detailed computation of CSS for FY 2020-21 for HT Consumers ........................................ 289 Table 220: Detailed computation of CSS for FY 2020-21 for LT Consumers (1/2) ............................... 290 Table 221: Detailed computation of CSS for FY 2020-21 for LT Consumers (2/2) ............................... 291 Table 222: Summary of CSS for the Control Period for HT Consumers ................................................. 292 Table 223: Summary of CSS for the Control Period for LT Consumers (1/2)......................................... 293 Table 224: Summary of CSS for the Control Period for LT Consumers (2/2)......................................... 294 Table 225: Proposed Additional Surcharge for FY 2020-21 ...................................................................... 301 Table 226: Proposed Additional Surcharge for FY 2021-22 ...................................................................... 301 Table 227: Proposed Additional Surcharge for FY 2022-23 ...................................................................... 302 Table 228: Proposed Additional Surcharge for FY 2023-24 ...................................................................... 302 Table 229: Proposed Additional Surcharge for FY 2024-25 ...................................................................... 303 MSEDCL January 20 xiv Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition LIST OF ANNEXURES Annexure 1: Regulatory Formats (n Soft Only Excel Format) Annexure 2: Annual Accounts for FY 2017-18 Annexure 3: Annual Accounts for FY 2018-19 Annexure 4: Interest Rate for interest paid on SD for FY 2017-18 Annexure 5: Interest Rate for interest paid on SD for FY 2018-19 Annexure 6: FAQs regarding kVAh Billing Annexure 7: Power Point Presentation on kVAh Billing Annexure 8: Investment Proof for Contingency Reserves Annexure 9: Letter to MERC highlighting issues pertaining to SEZ Annexure 10: Detailed Cost Estimation Sheet for Schedule of Charges MSEDCL January 20 xv Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition LIST OF ABBREVIATIONS Abbreviation A&G ABR ABT ACoS AFC AG AMR APDRP APPC ARR AS ASC AT&C ATE/APTEL BPL CAG CAGR Capex CBA CEA CERC CGS CGPL CGRF CIL COD Commission/MERC COS CPI CPP CPPA CR CSD CSS CT CTU MSEDCL Expansion Administration and General Average Billing Rate Availability Based Tariff Average Cost of Supply Annual Fixed Cost Agriculture Automated Metering Reading Accelerated Power Development and Reforms Programme Average Power Purchase Cost Aggregate Revenue Requirement Accounting Standard Additional Supply Charge Aggregate Technical and Commercial Appellate Tribunal for Electricity Below Poverty Line Comptroller and Auditor General Compounded Annual Growth Rate Capital Expenditures Cost Benefit Analysis Central Electricity Authority Central Electricity Regulatory Commission Central Generating Stations Coastal Gujarat Power Limited Consumer Grievances Redressal Forum Coal India Ltd. Commercial Operation Date Maharashtra Electricity Regulatory Commission Cost of Supply Consumer Price Index Captive Power Plant Captive Power Producers Association Consumer Representative Consumer Security Deposit Cross-subsidy Surcharge Current Transformer Central Transmission Utility January 20 xvi Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition LIST OF ABBREVIATIONS Abbreviation CWIP CUF DA DCL DDUGJY DF DIC DPC DPR DSM DTC DTL EA 2003/Act ED EDP EHV ERP FAC FBSM FSA FY GC GEC GFA GFSS GOI GoM GSA HP HT HVDS IBSM IC IDC IIT InSTS MSEDCL Expansion Capital Work in Progress Capacity Utilisation Factor Dearness Allowance Distribution Commercial Loss Deen Dayal Upadhyay Gram Jyoti Yojana Distribution Franchisee Directorate of Industries and Commerce Delay Payment Charges Detailed Project Report Demand Side Management Distribution Transformer Centre Deferred Tax Liability Electricity Act, 2003 Electricity Duty Embedded Display Port Extra High Voltage Enterprise Resource Planning Fuel Adjustment Charge Final Balance Settlement Mechanism Fuel Supply Agreement Financial Year Generation Charge Gross Energy Consumption Gross Fixed Assets Gaothan Feeder Separation Scheme Government of India Government of Maharashtra Gas Supply Agreement Horse Power High Tension High Voltage Distribution System Interim Balancing Settlement Mechanism Interim Charge Interest During Construction Indian Institute of Technology Intra-State Transmission System January 20 xvii Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition LIST OF ABBREVIATIONS Abbreviation IoWC IPDS IPP ISTS IT/ITES kVA kW kWh LC LF LT LV MCLR MERC MIDC MIS MoD MOEF MOP MoU MPECS MSEB MSEBHCL MSEDCL MSETCL MSLDC MSPGCL MTR MU MW MYT NCDP NLDC NPCIL NTP MSEDCL Expansion Interest on Working Capital Integrated Power Development Scheme Independent Power Producer Inter State Transmission System Information Technology/ Information Technology Services Kilo-Volt Ampere Kilo Watt Kilo Watt Hour / Unit Letter of Credit Load Factor Low Tension Low Voltage Marginal Cost of fund based Lending Rate Maharashtra Electricity Regulatory Commission Maharashtra Industrial Development Corporation Management Information System Merit Order Desptach Ministry of Environment and Forest Ministry of Power Memorandum of Understanding Mula Pravara Electric Cooperative Society Limited Maharashtra State Electricity Board Maharashtra State Electricity Board Holding Co. Ltd. Maharashtra State Electricity Distribution Co. Ltd. Maharashtra State Electricity Transmission Co. Ltd. Maharashtra State Load Despatch Centre Maharashtra State Power Generation Co. Ltd. Mid Term Review Million Units Mega Watt Multi Year Tariff New Coal Distribution Policy National Load Despatch Centre Nuclear Power Corporation of India Limited National Tariff Policy January 20 Enabled xviii Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition LIST OF ABBREVIATIONS Abbreviation NTPC O&M OA Opex P&L PD PF PFC PGCIL PLF PoC PPA P:SI P:IE PWW PXIL R&M RBI RE REC RECL RGGVY RGPPL RLC RLDC RoE RPO RTC RSD Rs. SBAR SBI SBLC SCADA SD SERC MSEDCL Expansion National Thermal Power Corporation Limited Operation and Maintenance Open Access Operational Expenditure Profit and Loss Permanent Disconnected Power Factor Power Finance Corporation Power Grid Corporation of India Limited Plant Load Factor Point of Connection Power Purchase Agreement Project for System Improvement Project for Intensive Electrification Public Water Works Power Exchange India Limited Repair and Maintenance Reserve Bank of India Renewable Energy Renewable Energy Certificates Rural Electrification Corporation Ltd. Rajeev Gandhi Grameen Vidyutikaran Yojana Ratnagiri Gas and Power Pvt. Ltd. Regulatory Liability Charge Regional Load Desptach Centre Return on Equity Renewable Purchase Obligation Round The Clock Reserve Shutdown Indian Rupees State Bank Advance Rate State Bank of India Stand By Letter of Credit Supervisory Control and Data Acquisition Security Deposit State Electricity Regulatory Commission January 20 xix Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition LIST OF ABBREVIATIONS Abbreviation SEZ SLDC SMD SOP SSP STP STU T&D TC ToD TOSE TSO TSR TSU TTSC UI ULDC UMPP USO VRS V-CoS Wef WPI WRLDC WRPC y-o-y MSEDCL Expansion Special Economic Zone State Load Despatch Centre Simultaneous Maximum Demand Standards of Performance Sardar Sarovar Project Sewage Treatment Plant State Transmission Utility Transmission and Distribution Transmission Charge Time-of-Day Tax on Sale of Electricity Temporary Supply Others Temporary Supply Religious Transmission System User Total Transmission System Cost Unscheduled Interchange Unified Load Dispatch & Communication Ultra Mega Power Projects Universal Service Obligation Voluntary Retirement Scheme Voltage-wise Cost of Supply With effect from Wholesale Price Index Western Regional Load Despatch Centre Western Region Power Committee Year on Year January 20 xx Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 1 1.1 BACKGROUND Introduction 1.1.1 Maharashtra State Electricity Distribution Co. Ltd. (hereinafter referred to as “MSEDCL” or “The Company” or “The Petitioner”) has been incorporated under the Companies Act, 1956 pursuant to decision of Government of Maharashtra to reorganize erstwhile Maharashtra State Electricity Board (“MSEB”). The said reorganization of the MSEB has been done by Government of Maharashtra pursuant to “Part XIII – Reorganization of Board” read with section 131 of The Electricity Act 2003. MSEDCL has been incorporated on 31.5.2005 with the Registrar of Companies, and has obtained Certificate of Commencement of Business on 15.09.2005. MSEDCL is functioning in accordance with the provisions envisaged in the Electricity Act, 2003 (“the Act”) and is engaged, within the framework of Electricity Act, 2003, in the business of distribution of electricity to its consumers situated over the entire State of Maharashtra, except Mumbai City & its suburbs (excluding Mulund & Bhandup). 1.1.2 The Maharashtra Electricity Regulatory Commission (hereinafter referred to as “MERC” or “Hon’ble Commission”) is an independent statutory body constituted under the provisions of the Electricity Regulatory Commissions (ERC) Act, 1998, which was superseded by Electricity Act (EA), 2003. Hon’ble Commission is continued as provided under Section 82 of the EA, 2003. Hon’ble Commission is vested with the authority regulating the power sector in the State inter alia including setting of tariff for electricity consumers. 1.1.3 The Hon’ble Commission has issued MERC (Multi Year Tariff) Regulations 2019 (hereinafter to be referred to as MYT Regulations 2019) for the 4th Control Period (FY 2020-21 to FY 2024-25) on 1st August 2019. These Regulations have come into force from 1st August 2019. 1.2 Provisions of Law 1.2.1 The MERC (MYT) Regulations, 2019, issued by the Hon’ble Commission provide the framework under which the licensees have to operate along with determination of Aggregate Revenue Requirement, Tariff, etc. The MYT Regulations 2019 provide for the Petitions to be filed in the Control Period. MSEDCL January 20 1 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Regulation 5.1 (a) provides for Multi-Year Tariff Petition. The key provisions of the said Regulation are reproduced below for reference. 5.1 The Petitions to be filed in the Control Period under these Regulations are as under: Multi-Year Tariff Petition, which is complete in all aspects as per these Regulations, shall be filed by November 1, 2019 by Generating Companies and Transmission Licensees and SLDC, and by November 30, 2019, by Distribution Licensees, comprising: Truing-up for FY 2017-18 and FY 2018-19 to be carried out under the Maharashtra Electricity Regulatory Commission (Multi Year Tariff) Regulations, 2015: Provided that the Commission may, if it considers appropriate, carry out the Truing-up for years prior to FY 2017-18 under the Maharashtra Electricity Regulatory Commission (Multi Year Tariff) Regulations, 2015, along with the Truing-up for FY 2017-18, in case such Truing-up is yet to be completed; Provisional Truing-up for FY 2019-20 to be carried out under the Maharashtra Electricity Regulatory Commission (Multi Year Tariff) Regulations, 2015; Aggregate Revenue Requirement for each year of the Control Period under these Regulations; Revenue from the sale of power at existing Tariffs and charges and projected revenue gap for each year of the Control Period under these Regulations; Proposed category-wise Tariff or Fees & Charges for each year of the Control Period under these Regulations. 1.2.2 As per the provisions of Regulation 5.1(a) of the said Regulations, Distribution Licensee has to file Multi-Year Tariff Petition (MYT Petition) by 30 th November 2019. Accordingly, MSEDCL has submitted its Multi-Year Tariff Petition on 26th November 2019 as per provisions of MYT Regulations, 2019. MSEDCL January 20 2 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 1.3 MSEDCL Submission 1.3.1 Hon’ble Commission has issued Order dated 12th September 2018 in Case No. 195 of 2017 (herein after referred as “MTR Order”) for Truing-up of Aggregate Revenue Requirement (ARR) of FY 2015-16 and FY 2016-17, Provisional Truing-up of ARR of FY 2017-18 and Revised Projections of ARR for FY 201819 and FY 2019-20. 1.3.2 MSEDCL hereby submits the Petition under section 62 of the Electricity Act, 2003 and MERC (MYT) Regulations, 2019 for final True Up for FY 2017-18 & FY 2018-19, provisional True Up for FY 2019-20 based on latest available information for the year and Multi Year Tariff for the period FY 2020-21 to FY 2024-25 based on estimates/projections.. The Regulatory Formats are annexed as Annexure 1 in (soft copy only) to this Petition. MSEDCL is also submitting the Annual Accounts for the period 1st April 2017 to 31st March 2018 and 1st April 2018 to 31st March 2019 duly audited by the statutory auditors for the purpose of truing up of expenses and revenue for FY 2017-18 and FY 201819 annexed as Annexure 2 and Annexure 3 respectively to this Petition. 1.3.3 MSEDCL is also filing the provisional True Up for FY 2019-20 based on latest available information for FY 2019-20 and Multi Year Tariff for the period FY 2020-21 to FY 2024-25 based on the estimates/projections provided in this Petition. 1.4 Appeal No. 280 of 2019 before Hon’ble APTEL, New Delhi 1.4.1 MSEDCL submits that on 29th October 2018, it has filed Petition for review of certain aspects of the Mid Term Review (MTR) Order dated 12 September, 2018 in Case No.195 of 2017. Hon’ble Commission disposed of the said Petition vide its Order No. 321 of 2018 dated 24th December 2018 and partly allowed the certain contentions of MSEDCL. However, aggrieved by the rulings of Hon’ble Commission, MSEDCL preferred an appeal before Hon’ble APTEL, New Delhi (Appeal No. 280 of 2019) on following major grounds. Non-consideration of MSEDCL proposal for revision in definition of Billing Demand; MSEDCL January 20 3 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Capping Cross Subsidy Surcharge to 20% of Average Tariff Non-consideration of approved trajectory of distribution loss for computation of sharing of Gains & Losses for FY 2016-17; Non-consideration of MSEDCL submission for mandatory Standby Arrangement for SEZ and Deemed Licensees; Difference in opening normative equity for FY 2015-16 as submitted in MTR Petition and as approved in the MTR Order. 1.4.2 MSEDCL is submitting the current Petition without prejudice to any of its rights and contentions taken by MSEDCL in said Appeal and MSEDCL reserves its right to again approach the Hon’ble Commission depending upon the final decision of Hon’ble APTEL New Delhi in said Appeal. MSEDCL January 20 4 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 2 2.1 REVISED O&M EXPENSES FOR FY 2015-16 Preamble 2.1.1 MSEDCL submits that in MTR Petition, it had submitted the reconciliation of GFA and requested the Hon’ble Commission to approve an additional/ difference amount of Rs. 1135 Crore in the opening GFA of FY 2015-16. The Hon’ble Commission in the MTR Order dated 12th September 2018 has approved Rs. 927 Crore as against Rs. 1135 Crore. Accordingly, the normative opening GFA (excluding GFA of DFs) of FY 2015-16 got revised to Rs. 40568 Crore (39641 + 927) for the purpose of computation of O&M expenses. 2.1.2 However, for the computation of O&M Expenses for FY 2015-16, the Hon’ble Commission considered the same as Rs. 39641 Crore thereby missing out the inclusion of Rs. 927 Crore in the opening GFA for computation of O&M Expenses. 2.1.3 Aggrieved by this, MSEDCL had filed review of various aspects of Mid Term Review Order along with above issue before the Hon’ble Commission (Case No. 321 of 2018). 2.1.4 Hon’ble Commission vide its Order dated 24th December 2018 ruled that for the computation of normative O&M Expenses for FY 2015-16, normative opening GFA has been considered as Rs. 39641 Crore thereby excluded Rs. 927 Crore in the opening GFA. Hon’ble Commission has also accepted that was an error apparent from the face of record while considering the GFA for working out such normative expense. 2.1.5 Hon’ble Commission in the said Order also ruled that normative opening GFA to be considered for calculating normative O&M Expenses for FY 2015-16 is to be corrected as Rs. 40568 Crore (Rs 39,641 Crs + Rs 927 Crs), and the O&M expenses for FY 2015-16 has to be recalculated. Thus, the difference after recalculation of O&M Expense that is to be allowed is Rs. 34 Crore. Also, the consequent difference of Rs. 11 Crore in gains is to be passed on to the consumers. MSEDCL January 20 5 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 2.2 Revised O&M Expenses for FY 2015-16 2.2.1 Accordingly, MSEDCL has calculated the revised O&M Expenses for FY 201516 as shown in following tables. Table 1: O&M Expenses for Distribution Wires Business for FY 2015-16 FY 2015-16 S.No. Particulars Units A) Composite O&M Norms 1 O&M Expenses Norm specified in Regulations 1.1 1.2 1.3 2 2.1 2.2 2.3 B) For Wheeled Energy For No. of Consumers in Wires Business paise/kWh For R&M Expenses % of GFA Rs Lakh/ '000 Consumers MTR Order True-Up requirement 14.34 14.34 7.40 7.40 4.00% 4.00% 1,09,543.00 1,09,543.29 23,151.00 23,150.97 Difference Parameters for O&M Expenses Wheeled Energy No. of Consumers in Wires Business MU Opening GFA Total O&M Expenses Rs. Crore 35,677.00 36,511.30 Rs. Crore 4,711 4,744.47 '000 Consumers 33.37 Table 2: O&M Expenses for Retail Supply Business for FY 2015-16 FY 2015-16 S.No. Particulars Units A) Composite O&M Norms 1 O&M Expenses Norm specified in Regulations 1.1 1.2 1.3 2 For Sales in Supply Business For No. of Consumers in Supply Business paise/kWh For R&M Expenses % of GFA Rs Lakh/ '000 Consumers MTR Order True-Up requirement 9.94 9.94 5.13 5.13 0.50% 0.50% Parameters for O&M Expenses 2.1 Sales MU 87,903.00 87,902.89 2.2 No. of Consumers in Supply Business '000 Consumers 23,151.00 23,150.97 Rs. Crore 3,964.00 4,056.70 Rs. Crore 2,081.22 2,081.68 2.3 B) Difference Opening GFA Total O&M Expenses 0.46 2.2.2 As these parameters need to be treated as controllable under the MYT Regulations 2011, any variation in the actual expenses as against the MSEDCL January 20 6 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition permissible normative levels has been shared between MSEDCL and consumers. 2.2.3 Regulation 14 of the MYT Regulations 2011 provides for the mechanism of pass through of gains and losses on account of uncontrollable parameters, and the mechanism for sharing of gains and losses on account of controllable parameters. The actual O&M Expenses as per the Audited Accounts for FY 2015-16 are lower than that of allowed on normative basis. Hence, the sharing of gains on account of O&M Expenses are summarized below; Table 3: Sharing of gains on account of O&M Expenses FY 15-16 Rs. Crs Particulars O&M Expenses Now Revised for MTR 6,826.16 FY 2015-16 Actual Gains/ (Loss) 5,417.68 1,408.48 2/3 of Efficiency gains/Losses 938.99 1/3 of Efficiency Gains/Losses 469.49 Net Entitlement after sharing 6,356.66 2.2.4 MSEDCL submits that the above mentioned O&M Expense (net entitlement after sharing of gains) has been used as Base O&M Expenses for computing the normative O&M Expenses for the 3rd Control Period. 2.2.5 MSEDCL further submits that Hon’ble Commission in its Order dated 24th December 2018 in Case No. 321 of 2018 has also ruled as follows: 15. Further, the correction in GFA of FY 2015-16 and consequent change in O&M expense of base year, i.e., FY 2015-16, has an overall impact on computation of O&M Expenses for Ensuing Years i.e., FY 2016-17 to FY 201920. This also impacts the working of sharing of gains and loss during FY 201617. The impact of revision in O&M expense for FY 2016-17 to FY 2019-20 works out to Rs. 104 Crore and the impact of incremental gain to be passed on to the consumers as part of truing up of FY 2016-17 works out to Rs. 15 Crore. Accordingly the same needs to be allowed under this review Order. 2.2.6 Accordingly, MSEDCL has computed the impact of lower O&M expenses allowed for FY 2015-16 and its corresponding impact of on computation of O&M Expenses for the period of FY 2016-17 to FY 2019-20 along with the carrying cost separately in Chapter 8 and claimed separately under Additional Claims. MSEDCL January 20 7 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 3 3.1 IMPACT OF THE RECONCILIATION OF OPENING GFA Preamble 3.1.1 MSEDCL submits that in MTR Petition, it had submitted the reconciliation of GFA and requested the Hon’ble Commission to approve an additional/ difference amount of Rs. 1135 Crore in the opening GFA of FY 2015-16. The Hon’ble Commission in the MTR Order dated 12th September 2018 has approved Rs. 927 Crore against Rs. 1135 Crore claimed. 3.1.2 In the said Order, Hon’ble Commission had ruled that the capitalisation is allowable and has to be added in the GFA. Hon’ble Commission in the said Order also ruled that any consequent changes on account of the same in future years as mentioned in the Order cannot be allowed as no such computation or workings has been provided by MSEDCL. 3.1.3 Therefore, MSEDCL has computed the impact of reinstatement of GFA of Rs. 927 Crore and the computation/working is provided in the following paragraphs. 3.2 Gross Fixed Assets 3.2.1 Out of the approved Rs 927 Cr. the addition of Rs. 815 Crs is in FY 07-08 and Rs. 112 Crs is in FY 11-12. Accordingly, MSEDCL has revised the GFA as summarized in following table. Table 4: Reinstatement of GFA Opening Addition Financial Year GFA to GFA FY 2007-08 10,370.51 1,278.16 FY 2008-09 11,646.13 1,634.76 FY 2009-10 13,278.84 2,064.97 FY 2010-11 15,318.81 4,814.22 FY 2011-12 20,131.42 6,770.54 FY 2012-13 26,901.49 6,005.00 FY 2013-14 32,901.49 4,530.90 FY 2014-15 37,431.50 4,015.50 FY 2015-16 41,437.00 3,907.81 FY 2016-17 45,344.82 3,097.27 MSEDCL January 20 Retirement (2.54) (2.05) (25.00) (1.61) (0.47) (5.00) (0.89) (10.00) - Rs.Crs Closing GFA 11,646.13 13,278.84 15,318.81 20,131.42 26,901.49 32,901.49 37,431.50 41,437.00 45,344.82 48,442.09 8 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 3.2.2 MSEDCL submits that for FY 2007-08, MSEDCL has added Rs. 815 Crs to the approved capitalization. The amount of grant is considered same as that approved by Hon’ble Commission. However, the amount of consumer contribution is considered as per the Audited Accounts for FY 2007-08 as mentioned by the Hon’ble Commission in the Tariff Order in Case No. 116 of 2008 (Refer Page No.90 of 249 of the said Order) Further, the Debt: Equity ratio approved for FY 2007-08 has been considered for the computation of funding of capitalization. 3.2.3 Accordingly, a comparison of the capitalization and funding of the capitalization approved by Hon’ble Commission previously and now revised by MSEDCL in view of approval of Rs 815 Crs for FY 2007-08 is provided in following table. Table 5: Comparison of the capitalization and funding of the capitalization for FY 07-08 Rs. Crs MERC MSEDCL Case No. 116 of 2008 Now Revised TOTAL CAPITALISATION 463.16 1,278.16 Less : GRANT 59.03 59.03 Less : CONSUMER CONTRIBUTION 153.13 366.24 FUND REQUIREMENT 251.00 852.89 EQUITY % 9.84% 9.84% DEBT % 90.16% 90.16% EQUITY 24.70 83.92 DEBT 226.30 768.97 Particulars 3.2.4 This revised Debt and Equity has been added to the respective closing balance of normative loan and equity approved by Hon’ble Commission in its Order in Case No.116 of 2008. 3.2.5 MSEDCL further submits that the Hon’ble Commission has already approved the resultant impact due to above difference on Capex related expenses for FY 07-08 in Case No. 121 of 2014. So, MSEDCL has not claimed the same in this Petition being already approved. 3.2.6 MSEDCL most earnestly requests the Hon’ble Commission to approve the MSEDCL January 20 9 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition revision in GFA and normative loan & equity for MSEDCL as computed above. 3.3 Depreciation 3.3.1 MSEDCL submits that considering the revised opening GFA and approved Depreciation rates for the respective year, it has computed the revised deprecation. For FY 11-12 and FY 12-13, it has also considered the impact of Advance against Depreciation (AAD). Further, for FY 14-15, MSEDCL has computed the depreciation on pro-rata basis similar to the methodology adopted by Hon’ble Commission. Table 6: Impact of Reinstatement of GFA on Depreciation Rs. Crs Revised Approved Approved Approved Revised Impact to Opening Depreciation Opening GFA Depreciation Depreciation be Claimed GFA Rate (a) (b) (c ) (d ) (e)=(c)* ( d) ( f) =(e)-(b) FY 2008-09 10,831.13 430.00 11,646.13 3.97% 462.36 32.36 FY 2009-10 12,463.84 511.00 13,278.84 4.10% 544.41 33.41 FY 2010-11 14,503.81 616.83 15,318.81 4.25% 651.49 34.66 FY 2011-12^ 19,316.42 892.75 20,131.42 4.29% 892.75 FY 2012-13^ 25,974.49 1,235.00 26,901.49 4.08% 1,235.00 FY 2013-14 31,974.49 1,611.00 32,901.49 5.04% 1,657.71 46.71 FY 2014-15* 36,504.50 1,620.00 37,431.50 4.44% 1,638.39 18.39 FY 2015-16 41,437.00 1,856.00 41,437.00 4.48% 1,856.00 FY 2016-17 45,344.82 2,023.25 45,344.82 4.46% 2,023.29 0.04 Total 165.57 ^ Incl. impact of AAD * Prorata as per MERC Method Financial Year 3.3.2 MSEDCL most earnestly requests the Hon’ble Commission to approve the resultant impact of Rs. 165.57 Crs on depreciation as computed above. 3.4 Interest on Long Term Loans 3.4.1 MSEDCL submits that considering the revised normative opening balance of Loans, revised addition to the normative loans, revised repayment (equal to revised depreciation) and approved interest rates for the respective year, MSEDCL has computed the revised interest expenses. Additionally for FY 1314, MSEDCL has considered the impact of interest capitalized as approved by Hon’ble Commission. MSEDCL January 20 10 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 3.4.2 MSEDCL further submits that Hon’ble Commission in its Order in Case No. 38 of 2014 has erred in calculating the closing balance of normative loan for FY 12-13. MSEDCL has corrected the said error while computing the closing balance of normative loan for FY 12-13. Table 7: Revised Normative Loan Balance for FY 12-13 Particulars FY 2012-13 (Rs. Crs) (Table 88 Page No.114 of 148) Approved Corrected Opening balance of Normative Loan 9,518 9,518 Addition to Normative Loan 4,720 4,720 Repayment of Normative Loan (1,061) (1,061) Closing Balance of Normative Loan 13,117 13,177 3.4.3 The impact of reinstatement of GFA on interest on loans is summarized in following table. Table 8: Impact of Reinstatement of GFA on Interest on Loans Financial Year Approved Interest Expenses (a) FY 2008-09 274.00 FY 2009-10 318.00 FY 2010-11 480.67 FY 2011-12 836.16 FY 2012-13 1,304.00 FY 2013-14^ 1,469.00 FY 2014-15 1,677.00 FY 2015-16 1,701.00 FY 2016-17 1,588.03 Total ^ Incl. Interest capitalised Rs. Crs Revised Revised Opening Addition to Closing Approved Revised Impact to Balance of Normative Repayment Balance of Interest Interest be Normative Loan Normative Rate Expenses Claimed Loan Loan (b) (c ) (d) ( e) =(b) +(c )-(d) (f) (g)=Avg(a,b)*(f) (h)=(g)-(a) 3,026.71 619.16 -462.36 3,183.51 10.63% 329.94 55.94 3,183.51 1,248.00 -544.41 3,887.10 10.45% 369.60 51.60 3,887.10 2,981.07 -651.49 6,216.68 10.47% 528.77 48.10 6,216.68 4,550.71 -862.87 9,904.51 10.95% 882.67 46.51 9,904.51 4,720.00 -1,098.87 13,525.65 11.51% 1,348.71 44.71 13,525.65 2,424.00 -1,657.71 14,291.94 11.86% 1,510.06 41.06 14,291.94 2,105.94 -1,638.39 14,759.49 11.80% 1,714.00 37.00 14,759.49 1,800.00 -1,856.00 14,703.49 11.79% 1,736.88 35.88 14,703.49 1,239.24 -2,023.29 13,919.44 11.37% 1,627.21 39.18 399.99 3.4.4 MSEDCL most earnestly requests the Hon’ble Commission to approve the impact on interest on loans of Rs. 399.99 Crs as computed above. 3.5 Return on Equity 3.5.1 MSEDCL submits that due to the revision in opening balance of equity and MSEDCL January 20 11 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition revised addition to the equity, MSEDCL has computed the revised return on equity considering approved rate of return on equity. 3.5.2 It is pertinent to note that Hon’ble Commission has approved Rs. 8589 Crs as closing balance of normative equity for wire business for FY 14-15 in Case No. 48 of 2016 (Refer Page 134 of 617 of said Order). However, in Case No. 195 of 2017, Hon’ble Commission has considered Rs. 8713 Crs as opening balance of normative equity for wire business for FY 15-16 (Refer Page 183 of 638 of said Order). Similar is the case with supply business. MSEDCL submits that it has corrected the said errors and considered the opening balance of normative equity for FY 15-16 as closing balance of normative equity for FY 14-15 for wire and supply business. 3.5.3 The impact of reinstatement of GFA on return on equity is summarized in following table. Table 9: Impact of Reinstatement of GFA on Return on Equity Financial Year FY 2008-09 FY 2009-10 FY 2010-11 FY 2011-12 FY 2012-13 Wires Business FY 2013-14 FY 2014-15 FY 2015-16 FY 2016-17 Supply Business FY 2013-14 FY 2014-15 FY 2015-16 FY 2016-17 Total Approved Return on Equity (a) 518.58 550.64 663.63 914.21 1,139.78 1,133.44 1,269.06 1,396.86 1,480.79 142.28 159.08 175.18 185.68 Rs. Crs Revised Revised Opening Equity Addition to Closing Approved Impact to Balance portion of Revised Return Normative Balance of Rate of be of Retirement on Equity Equity Normative ROE Claimed Normative of Assets Equity Equity (b) (c ) (d) ( e) =(b) +(c )-(d) (f) (g)=(b)*(f)+(c)*(f)/2 (h)=(g)-(a) 3,167.85 265.00 3,432.85 16% 528.06 9.48 3,432.85 135.00 3,567.85 16% 560.06 9.42 3,567.85 1,277.60 4,845.45 16% 673.06 9.43 4,845.45 1,854.79 0.13 6,700.37 16% 923.65 9.43 6,700.11 966.00 0.80 7,666.91 16% 1,149.23 9.46 6,898.78 935.00 7,833.78 15.50% 1,141.77 8.34 7,833.78 812.29 3.04 8,649.11 15.50% 1,276.95 7.89 8,643.04 598.50 9,241.54 15.50% 1,386.05 -10.81 9,241.54 477.99 15.50% 1,469.48 -11.31 766.53 870.53 960.79 1,027.29 104.00 90.25 66.50 53.11 - 870.53 960.79 1,027.29 1,080.40 17.50% 17.50% 17.50% 17.50% 143.24 160.24 173.96 184.42 0.97 1.17 -1.22 -1.25 40.99 3.5.4 MSEDCL most earnestly requests the Hon’ble Commission to approve the impact on return on equity amounting to Rs. 40.99 Crs as computed above. MSEDCL January 20 12 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 3.6 Summary of impact of reinstatement of GFA 3.6.1 Considering the above, MSEDCL has summarized the total impact of reinstatement of GFA by Rs. 927 Crs in following table. Table 10: Summary of Impact of Reinstatement of GFA Financial Year Depreciation Interest on Loan FY 2008-09 32.36 55.94 FY 2009-10 33.41 51.60 FY 2010-11 34.66 48.10 FY 2011-12 46.51 FY 2012-13 44.71 FY 2013-14 46.71 41.06 FY 2014-15 18.39 37.00 FY 2015-16 35.88 FY 2016-17 0.04 39.18 Grand Total 165.57 399.99 Rs. Crs Return on Equity Total 9.48 97.78 9.42 94.44 9.43 92.19 9.43 55.95 9.46 54.17 9.30 97.07 9.06 64.45 (12.02) 23.86 (12.56) 26.65 40.99 606.55 3.6.2 MSEDCL requests the Hon’ble Commission to allow Rs. 606.55 Crs towards the impact on depreciation, interest on long term loans and return on equity due to reinstatement of GFA as submitted above. 3.6.3 MSEDCL further submits that the detailed computations of the impact on depreciation, Interest on loan and return on equity due to reinstatement of GFA of Rs. 927 Crs have also been provided in a separate form along with the Regulatory Formats. 3.6.4 MSEDCL submits that the impact of reinstatement of GFA of Rs. 927 Crore along with the carrying cost has been claimed separately at Chapter 8 under Additional Claims. MSEDCL January 20 13 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 4 4.1 FINAL TRUE UP FOR FY 2017-18 Preamble 4.1.1 This section outlines the actual performance of MSEDCL for the FY 2017-18. MSEDCL hereby submits final True Up for FY 2017-18 comparing the actual audited data for FY 2017-18 with those approved by the Hon’ble Commission vide MTR Order dated 12th September 2018 in Case no. 195 of 2017. 4.1.2 The Board of Directors of MSEDCL has approved the Audited Annual Accounts for the period April 2017 to March 2018 and Statutory Auditors M/s. SGCO & Co. LLP, M/s. Shah & Taparia, and M/s CNK & Associates LLP have audited the Accounts vide report dated 10/10/2018 attached as Annexure 2 to this Petition. MSEDCL hereby proposes to true up its expenses and revenues based on the said Audited Accounts. 4.1.3 Following sections outline the deviations in actual expenses/revenue for FY 2017-18 based on the Audited Accounts of MSEDCL in comparison with the expenses/revenue approved by the Hon’ble Commission vide MTR Order dated 12th September 2018. 4.2 Category Wise Sales for FY 2017-18 4.2.1 Category wise actual sales for FY 2017-18 for MSEDCL excluding all Distribution Franchisee have been summarized in the following table: Table 11: Category wise sales for FY 17-18 Category Residential Commercial HT-Industrial LT-Industrial PWW Street Light Agriculture Public Services Railways Others MSEDCL Excl. DF MSEDCL FY 2017-18 (Approved) 18,825.66 6,922.78 28,110.25 6,488.27 2,236.92 1,761.78 29,502.64 1,383.59 59.25 659.65 95,950.79 Sales (MUs) FY 2017-18 (Actual) 18,997.48 6,968.61 28,118.42 6,403.84 2,227.85 1,788.24 30,678.01 1,388.23 59.25 670.20 97,300.14 January 20 Deviation 171.82 45.83 8.17 (84.43) (9.07) 26.46 1,175.37 4.64 (0.00) 10.55 1,349.35 14 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 4.2.2 MSEDCL submits that during the MTR Process, it had submitted the provisional information available for FY 17-18 at the time of filing of the MTR Petition. Subsequently, the actual figures were available and Audited Accounts for FY 17-18 of MSEDCL were finalized. Accordingly, MSEDCL’s actual Sales for FY 2017-18 is 97,300.14 MUs (excluding the Franchisee Sales). 4.2.3 MSEDCL most earnestly requests the Hon’ble Commission to approve the Sales for FY 17-18 as submitted above. 4.3 Distribution Losses for FY 2017-18 4.3.1 In MYT Order dated 3rd November, 2016 in Case No. 48 of 2016, the Hon’ble Commission had approved distribution loss of 16.26% (excluding EHV Sales) for FY 17-18. The actual distribution loss (excluding EHV sales) achieved by MSEDCL for FY 2017-18 is 14.82% which is (1.44%) less than the Distribution Loss level approved by Hon’ble Commission. Table 12: Distribution Losses for FY 17-18 Particulars Distribution Loss FY 2017-18 (Approved) 16.26% FY 2017-18 (Actual) 14.82% Deviation (1.44%) 4.3.2 MSEDCL endeavours for taking Distribution Losses to the lowest possible level. MSEDCL has achieved a significant reduction in distribution losses during recent years. However, loss reduction is a slow process and becomes increasingly difficult as the loss levels come down. The change in sales mix also impacts the distribution losses. MSEDCL requests the Hon’ble Commission to approve the actual Distribution Loss as achieved by MSEDCL. 4.4 Energy Balance for FY 2017-18 4.4.1 The quantum of sales as shown in Table 11 is 97,300.14 MUs, representing the sales of MSEDCL excluding the sales in the areas served by Distribution Franchisees. As per the methodology adopted by Hon’ble Commission for calculating energy balance of MSEDCL as a whole, the sale to the consumers within the Distribution Franchisee area has also been considered. Therefore, MSEDCL January 20 15 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition energy available for sale for FY 2017-18 is computed as below: Table 13: Energy Available for Sales for FY 17-18 MUs FY 2017-18 (Approved) 95,950.79 4,436.88 Particulars Energy Sales by MSEDCL for FY 2017-18 Add: Category wise sales in DF area Add: Solar Offset Units Add: OA Sales (Conventional) Add: Renewable OA Total Energy Sales 4,330.00 679.00 1,05,396.67 FY 2017-18 (Actual) 97,300.14 4,372.89 18.17 4,303.33 676.51 1,06,671.04 Deviation 1,349.35 (63.99) 18.17 (26.67) (2.49) 1,274.37 4.4.2 MSEDCL submits that the total energy sales for FY 2017-18 is 1,06,671.04 MUs as compared to 1,05,396.67 MUs which was approved by the Hon’ble Commission in MTR Order dated 12th September 2018. The Hon’ble Commission is requested to allow the same. 4.4.3 MSEDCL further submits that it is procuring power from various Sources including MSPGCL, CGS including nuclear power plants, Traders, IPPs and Renewable Sources. It would be very difficult to differentiate which power is coming from which source at Transmission periphery. Hence an average interstate loss for the whole year is considered for power sourced from outside the State of Maharashtra. 4.4.4 MSEDCL also submits that data of metered energy is available at 3 points: at bus-bar of the generating station, at T <> D interface i.e. at Distribution Periphery and sales at consumer end. It is further to state that to calculate Distribution Loss, it considers metered energy. 4.4.5 MSEDCL submits that power purchased or scheduled from Inter State Transmission network is scheduled by Western Region Load Dispatch Center. The power purchase from inter State can be group under following categories. Type (Inter State Generating Station ) ISGS Long Term Access (LTA) i.e. IPP STOA MSEDCL Purchase Include power from NTPC, NPCIL, SSP, Pench, CGPL EMCO Short term bilateral power purchase, January 20 16 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Type Purchase Include power from Power purchase through Power Market like IEX, Banking Arrangement. 4.4.6 MSEDCL submits that based on the power scheduled at generator bus for Maharashtra is available as Full Schedule on WRLDC web based scheduling software. Similarly power schedule at Maharashtra state periphery are available as Net schedule on WRLDC web based scheduling software. 4.4.7 In case of Tarapur Atomic Power Station of NPCIL (TAPS 1&2) which is considered as ISGS station but connected to Maharashtra State STU network for power evacuation. Hence for scheduling of power to Maharashtra, no PoC / scheduling loss is considered. Similarly, EMCO Warora is located in Maharashtra but this generating station is connected to ISTS network. Hence power is scheduled by WRLDC. 4.4.8 For interstate loss computation, power scheduled from ISGS station, CGPL, EMCO, SSP, Pench & short term through Inter-state network i.e. whose scheduling done by RLDC is taken into consideration. 4.4.9 MSEDCL also purchase power from power market mainly Indian Energy Exchange as per requirement to meet demand or for cost optimization. The power purchase from Indian Energy Exchange is at Regional periphery and drawal losses are applicable for energy purchased from IEX to compute energy available at Maharashtra State periphery. 4.4.10 Further MSEDCL also had agreements for banking of power from States like Haryana, Himachal Pradesh, and UPPCL etc. In banking arrangement, Power transactions are settled at Regional Periphery and concern DISCOMs has to bear Drawal loss when receiving power from other DISCOM and has to bear injection loss when delivering power to other DISCOM. 4.4.11 MSEDCL submits that the surplus power traded at Exchange is billed at Regional Periphery and bilateral power traded is billed at STU periphery. The MSEDCL January 20 17 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition quantum of 985 MUs shown under ‘Surplus Energy Traded’ is the actual energy traded by MSEDCL at STU periphery during FY 17-18. 4.4.12 As per latest DSR available, UI for FY 17-18 is considered as (1,413.85) MUs. MSEDCL submits that the WRLDC provides web based scheduling reports on HTTP://SCHEDULING.WRLDC.IN/WBES/ACCOUNT/LOGIN. This site provides the details of full schedule and net schedule from each Inter State Generating Station (ISGS). The WRLDC uses this data for loss calculation. Further, WRPC prepares the REA from this data which forms the basis of billing for ISGS. MSEDCL prepared the cumulative information for FY 17-18 based on these reports. Considering the energy at ex bus bar and energy received at STU periphery from these reports, MSEDCL has considered the inter-state transmission losses as 3.54%. Source of Power (Station wise) NTPC NPCIL SSP Pench Mundra UMPP EMCO Power (Own Station) EMCO Power (Alternate source) Short Term Power Purchase Total Power Scheduled from Inter State Source At regional Periphery (MUs) 30116.16 2590.66 245.60 50.68 4990.04 1188.68 71.95 4432.99 43686.75 Energy Received at State Periphery (MUs) 28904.84 2537.05 237.99 48.59 4813.90 1138.83 71.95 4386.08 42139.23 Interstate Loss 4.0% 2.1% 3.1% 4.1% 3.5% 4.2% 0.0% 1.1% 3.54% 4.4.13 MSEDCL further submits that the MSLDC computes the Intra State Transmission System (InSTS) Grid Loss based on the Energy Input and Energy Output. This is grid loss for the Maharashtra Transmission System and not for MSEDCL. Hence, considering the fact that Grid Loss can’t be same for all Distribution Licensees, MSEDCL has computed Intra-State losses. Power purchase, sales and energy at Distribution Periphery being metered figures in this petition, Intra State losses is the number which is required to be computed. MSEDCL January 20 18 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 4.4.14 MSEDCL submits that the open access consumption takes place at different voltages viz. 11 kV, 22 kV, 33 kV and EHV level. Hon’ble Commission has been allowing the wheeling losses of 9%, 7.5%, 6% and 0% respectively for these voltage levels. Further, Intra State transmission loss for Maharashtra System is 3.30%. In view of these losses and consumption, MSEDCL has considered a normative loss of 6%. It is pertinent to note that Hon’ble Commission in the previous 3 to 4 Tariff Orders, has been computing the input for OA consumption by taking loss level of 6%. In line with the same, MSEDCL has considered the loss of 6% for computing the input for OA consumption. 4.4.15 Considering the energy available for sale for FY 2017-18 as shown in Table 13, the energy balance for MSEDCL is calculated. The following table shows the energy balance for FY 17-18. Table 14: Energy Balance for FY 17-18 Sr. No. 1 3 4 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Particulars LT Sales (Including D.F) HT Sales excluding EHV level sales (Including D.F) HT/LTIP Credit Sales and HT/LT Offset Export Solar units Total Sales including D.F (Excluding EHV Sales) OA Sales (Renewables) OA Sales (Conventional) Retail Energy Sale to Consumers (Excluding EHV Sales) Total Power Purchase Power Purchase Quantum from Intra-State sources Power Purchase Quantum from Inter-State sources Inter-State Losses Power Purchase Quantum from Inter-State sources at MS Periphery Add: FBSM Power Quantum handled at Maharashtra Periphery Infirm Non-PPA Wind Power Input for OA Consumption Total Power Purchase Quantum Handled Surplus Power Traded Energy Requirement at G<>T Periphery Intra-State Transmission Loss Intra-State Transmission Loss Net Energy requirement at T<>D Periphery EHV Sales Net Energy Available for Sale at 33kV Energy injected and drawn at 33kV Total Energy Available for Sale at 33kV (Metered Energy at EHV and 33 kV Input) Distribution Loss (Excl. EHV Sales) Distribution Loss (Excl. EHV Sales) Calculation UoM a b c d=a+b+c e f A=d+e+f B=g+h g h i j=h*(1-i) k l=g+j+k m n=f/(1-6%) o=l+m+n-w p q=o-p r s=q*r t=q-s u v=t-u w MU MU MU MU MU MU MU MU MU MU % MU C=v+w MU D=C-A E=D/C MU % MU MU MU MU MU MU % MU MU MU MU MU FY 2017-18 MTR Order Actual 66,874 65,600 27,075 27,082 18 92,683 93,967 677 679 4,303 4,330 97,692 98,947 1,25,422 1,27,311 83,616 82,115 43,696 43,307 3.54% 3.47% 42,149 41,806 (1,413.85) 1,23,921 1,24,351 720 4,578 4,606 1,29,159 1,28,039 985 580 1,28,174 1,27,459 3.72% 3.30% 4,772 4,206 1,23,402 1,23,253 7,724 7,705 1,15,678 1,15,548 490 488 1,16,036 18,344 15.81% 1,16,168 17,221 14.82% 4.4.16 MSEDCL further submits that the FBSM has not been finalized after February 2018. MSEDCL most earnestly submits that it has been more than 1.5 years since the FBSM was finalized. MSEDCL requests the Hon’ble Commission to MSEDCL January 20 19 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition direct SLDC to finalize the FBSM on regular basis so the exact impact of the quantum as well as cost can be considered in Tariff Petitions. 4.4.17 MSEDCL requests the Hon’ble Commission to approve the Energy Balance for FY 17-18 as submitted by MSEDCL in above table. 4.5 Power Purchase Expenses for FY 2017-18 4.5.1 MSEDCL has following sources of firm power viz. Maharashtra State Power Generation Company Limited (MSPGCL) Purchase from Central Generating Stations JSW (Ratnagiri) Mundra UMPP CGPL Adani Power Limited RattanIndia Limited Emco Power Limited etc. 4.5.2 MSEDCL also buys power from other sources such as Sardar Sarovar and Pench Hydro project, renewable sources including co-generation, Wind power and Solar. 4.5.3 In addition to the above sources, In case of any shortfall from approved sources, when demand exceeds availability or for cost optimization, MSEDCL sources power from exchange/Traders or other sources at the market price through competitive bidding in accordance with the Guidelines of MoP. 4.5.4 Following table summarizes the source wise power purchase done by MSEDCL during the FY 17-18. MSEDCL January 20 20 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 15: Power Purchase Expenses for FY 17-18 Source MSPGCL NTPC NPCIL SSP Pench Dodson JSW CGPL Adani Power EMCO Power Rattan India Renewable Traders RECs Short provision for PP Other Adjsutments PGCIL Charges FBSM Intra State Purchase Rebate Total Power Purchase PP Quantum (MUs) PP Cost (Rs. Cost) PP Cost (Rs. /Unit) Approved Approved in Approved in in MTR Actual Deviation Actual Deviation Actual Deviation MTR Order MTR Order Order 48,842.89 48,842.89 18,625.24 17,405.35 (1,219.88) 3.81 3.56 (0.25) 30,116.27 30,116.28 0.01 8,242.51 8,284.33 41.82 2.74 2.75 0.01 2,588.55 2,590.66 2.11 757.77 750.10 (7.67) 2.93 2.90 (0.03) 245.60 245.60 50.35 50.42 0.07 2.05 2.05 0.00 50.55 50.68 0.13 10.36 10.36 0.00 2.05 2.04 (0.01) 82.53 82.53 21.90 21.90 2.65 2.65 1,898.92 1,898.92 548.18 548.18 2.89 2.89 4,990.04 4,990.04 1,275.01 1,210.93 (64.08) 2.56 2.43 (0.13) 17,256.53 17,256.53 6,158.71 6,646.40 487.69 3.57 3.85 0.28 1,260.62 1,260.62 532.37 495.17 (37.20) 4.22 3.93 (0.30) 4,347.12 4,347.12 2,149.87 2,157.24 7.37 4.95 4.96 0.02 11,046.27 11,187.72 141.45 6,245.18 6,324.76 79.58 5.65 5.65 (0.00) 4,055.75 4,056.25 0.50 1,495.16 1,495.37 0.22 3.69 3.69 0.00 689.13 482.53 (206.60) 430.56 430.56 36.36 94.01 57.65 2,558.82 2,557.96 (0.86) (1,359.28) (1,413.85) (54.57) (267.17) (267.21) (0.05) 1.97 1.89 (0.08) 4.57 4.57 (280.31) (280.31) 1,25,422 1,25,512 90 49,130 48,423 (707) 3.92 3.86 (0.06) 4.5.5 In the following paragraphs, MSEDCL has given the detailed reasons for variation in the power purchase quantum and cost. a) MSPGCL: Hon’ble Commission in its MTR Order dated 12th September 2018 in Case No. 196 of 2017 for MSPGCL had approved the total revenue surplus of Rs. 1275.12 Crore including holding cost, after final true-up for FY 2015-16 and FY 2016-17 and provisional true-up for FY 2017-18. As per the IndAS 10, significant financial events that occur after reporting period, but prior to the issue of financial statements need to be considered in final Accounting Statements. Accordingly, MSEDCL has considered the surplus of Rs. 1275.12 Crore for MSPGCL. Further, MSEDCL had received supplementary bill of Rs. 55.11 Crs for April 17 to Mar 18 from MSPGCL. b) NTPC: MSEDCL has considered the NVVNL bundled power from NTPC. c) NPCIL: It is the amount received for Power Supply of Auxiliary Consumption from Apr16 to Sept 17. d) CGPL: An amount of Rs. 65 Crs was booked as a provision for FY 1617. However the provision so made for Mar-17 of Rs. 65 Crs was reversed after MTR petition was filed. e) Adani Power Maharashtra Limited: Hon’ble Commission has issued the Order on 19th April 2018 in Case No. 102 of 2016 and approved the MSEDCL January 20 21 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition f) g) h) i) j) k) l) compensation in Tariff on account of Change in Law in respect of 800 MW out of 1320 MW power contracted under PPA dated 08.09.2008. MSEDCL considered the same. EMCO Power: STOA/ MTOA credit passed on by GMR to MSEDCL along with interest amounting to Rs. 38 Crs. which was not available at time of MTR Petition. RattanIndia Power: An amount of Rs. 9.91 Crs was booked provisionally towards change in law of RIPL as per Order in Case No. 84 of 2016. Subsequently, the claim finalized at 17.28 Crs. Hence there is increase in cost of RIPL by Rs. 7.37 Crs. as compared to MTR approved cost. Renewable Energy: Wind Energy injected in FY 2014-15 & FY 2015-16 considered in FY 2017-18 due to execution of EPA in Mar & Aug 17. Rebate: As per the IndAS, the rebate received from power generators for prompt payments is shown in the power purchase only, instead of earlier practice of showing in Non-Tariff Income. RECs: MSEDCL has procured Solar and Non-Solar RECs for fulfilment of RPO. At the time of submission of provisional information for FY 2017-18, MSEDCL had submitted Rs. 689 Crs towards REC purchase for meeting shortfall in Non-Solar RPO Target. In FY 17-18, MSEDCL has withdrawn the provision amounting to Rs. 206 Crs made for RECs in FY 16-17. Short Provisions: The short provision of Rs. 521 Crs during FY 16-17 and Short provision of Rs. (90.53) Crs for FBSM for FY 16-17 included in short provisions while finalizing the Accounts for FY 17-18. Other Adjustments include Rs. 100 Crs of EMCO Power related to FY 15-16, FBSM of Rs. (43) Crs for FY 16-17 and Rs. 36 Crs paid to RGPPL. MSEDCL has paid Rs. 36 Crs towards adjustment of Electrical charges of Shirala Water Pump related to RGPPL. 4.5.6 Details of RE Purchase for FY 17-18 are tabulated below: Source Wind SHP MSEDCL FY 2017-18 Quantum (MU) Cost (in Rs. Crs.) 6331.68 3198.77 229.07 95.73 January 20 22 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Source Bagasse based Cogen. Biomass MSW Non-Solar RECs Total Non-Solar SPV Total Solar FY 2017-18 Quantum (MU) Cost (in Rs. Crs.) 3381.42 2104.96 428.74 284.63 0.18 0.09 2,872 482.53 10,371.09 6,166.71 816.63 640.57 816.63 640.57 4.5.7 During FY 2017-18, MSEDCL has fulfilled non-Solar RPO Target and with surplus of 55.151 MU and has the shortfall of 2147.016 MUs in fulfilling cumulative Solar RPO Target till FY 2017-18 including the standalone shortfall of 1476 MUs for FY 2017-18. 4.5.8 MSEDCL requests the Hon’ble Commission to approve the power purchase expenses as per Audited Accounts. 4.6 Intra State Transmission Charges for FY 2017-18 4.6.1 MSEDCL submits the actual transmission charges and SLDC charges paid to MSETCL and MSLDC as summarized in following table. Table 16: Transmission Charges for FY 2017-18 Rs. Crs Particulars Intra-State Transmission Charges MSLDC Charges Total FY 2017-18 (Approved) 4,796.64 15.53 4,812.17 FY 2017-18 (Actual) 4,796.64 15.53 4,812.17 Deviation - 4.6.2 MSEDCL submits that it pays the transmission charges to STU as per the InSTS Order issues by Hon’ble Commission from time to time. MSEDCL requests the Hon’ble Commission to approve the actual Transmission and MSLDC Charges as per the Audited Accounts. MSEDCL January 20 23 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 4.7 Fixed Costs for FY 2017-18 4.7.1 Based on the Capital Cost and the consequent Capitalized Expenditure, Equity Component and Normative Debt, the fixed cost of MSEDCL for FY 2017-18 (excluding fixed components of PP cost) has been determined in accordance with the provisions of MYT Regulations 2015 outlined thereof. As outlined under the regulations, the fixed cost for MSEDCL has been determined under the following major heads long with other items of expenditure: • Operation and Maintenance Expenses • Depreciation • Interest and Finance Charges • Interest on Working Capital • Income Tax • Return on Equity 4.7.2 Net Annual Revenue Requirement has been computed after netting off Expenses capitalized. 4.7.3 Head wise comparison has been made between the values approved by the Hon’ble Commission vide MTR Order dated 12th September 2018 in Case no. 195 of 2017 for FY 2017-18 and the values as per the audited accounts. 4.8 Actual Operation & Maintenance Expenses for FY 2017-18 4.8.1 Operations and Maintenance (O&M) Expenses of the company consists of the following elements viz. Employee Expenses, Administrative and General Expenses and Repairs and Maintenance Expenses. 4.8.2 The following table provides the actual O&M Expenses (net of Capitalization) for the FY 2017-18. Table 17: Actual O&M Expenses for FY 2017-18 Particulars Actual O&M Expenses MSEDCL January 20 Rs. Crs Actual 5,658.28 24 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 4.8.3 Head-wise details of employee expenses, A&G Expenses and R&M Expenses have been provided in Regulatory Formats. 4.8.4 The following paragraphs provide the detailed reasons for change in actual O&M expenses for FY 17-18 over FY 16-17. 4.8.5 Following table provides the comparison of actual O&M expenses for FY 17-18 and FY 16-17. Rs. Crs Sr. No. 1 2 3 Particulars Employee Exp. (Net) A & G Exp. (Net) R & M Exp. Total O & M Exp. 2016-17 4292.21 727.13 777.35 5796.69 2017-18 4157.45 684.76 816.07 5658.28 Diff. ( 134.76) ( 42.37) 38.72 ( 138.41) 4.8.6 There is a reduction of Rs. 138.41 Crs in O&M Expenses for FY 17-18 over FY 16-17. 4.8.7 Following Table summarises the reasons for change in major components of O&M Expenses for FY 17-18 over FY 16-17. Sr. No. Particulars 1. Employee Cost 1.1 Gratuity Payment 1.2 Earned Leave Encashment MSEDCL FY 16-17 FY 17-18 391.77 330.01 574.40 268.89 Difference Remark -61.76 The provision for gratuity & leave encashment as per actuarial valuation is less in FY 2017-18 as compared to FY 2016-17 due to :1. Average service has reduced by 10%. 2. Average leave balance has reduced by 6%. 3. Discount rate has increased from 7.25% to 7.70%. -305.51 Generally in the first year of leave encashment block, leave encashment is taken by most of the employees. The leave encashment January 20 25 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Sr. No. Particulars FY 16-17 FY 17-18 1.3 2. Exp. On 111.56 181.16 outsourced Employees Administration & General Expenses 2.1 2.2 3 Expenditure on Consumer billing Collection Charges 189.30 260.74 67.37 76.03 R & M Exp. 777.35 816.07 Difference Remark block was FY 2016-18. As such leave encashment in FY 2016-17 is more and less in FY 2017-18. 69.60 Expenditure on outsourced employees increased 71.44 Due in increase in no. of consumers, there has been increase in consumer billing expenses and collection charges. 8.66 38.72 It includes the amount of Rs. 108.02 Crs. paid to Datar Switchgear ltd in terms of Hon. Supreme Court’s order dated 18.01.2018 towards damages. 4.8.8 MSEDCL further submits that in the employee expenses, MSEDCL has added Rs. 50.20 Crs towards the regarding Re-measurement of defined benefits plans. In this regards, MSEDCL would like to submit that the Gratuity is recognized in the financial statements as per actuarial valuations by independent actuaries at the year-end by using projected unit credit method as on 31stMarch, 2018. It is unfunded defined benefit plan. 4.8.9 In accordance with the IND AS 19, all Actuarial Gain & Loss arising during the year has been recognised in the Other Comprehensive Income (OCI). For FY 2017-18 amount recognised in other comprehensive income (OCI) is as follows. Particulars Actuarial gain & Loss due to Financial assumptions changes in Defined benefit obligation (DBO) Actuarial gain & Loss due to Experience on DBO Total Actuarial (Gain)/ Loss included in OCI MSEDCL January 20 Amount (80.42) 130.62 50.20 26 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 4.8.10 MSEDCL requests the Hon’ble Commission to allow the same as a part of Employee Expenses. 4.9 Normative Operation & Maintenance Expenses for FY 2017-18 4.9.1 MSEDCL submits that Regulation 72 and Regulation 81 of the MERC (MYT) (1st Amendment) Regulations 2017provides for the O&M Expenses Norm for Distribution Wires Business and Retail Supply of electricity respectively. 4.9.2 Hon’ble Commission has issued an Amendment to the MERC (MYT) Regulations 2015. As per the said Amendment “”72.3….. Provided that, in the Truing-up of the Operation and Maintenance expenses for any particular year of the Control Period, an inflation factor with 30% weightage to the average yearly inflation derived based on the monthly Wholesale Price Index of the past five financial years (including the year of Truing-up) and 70% weightage to the average yearly inflation derived based on the monthly Consumer Price Index for Industrial Workers (all-India) of the past five financial years (including the year of Truing-up), as reduced by an efficiency factor of 1% or as may be stipulated by the Commission from time to time, shall be applied to arrive at the permissible Operation and Maintenance Expenses for that year.” 4.9.3 Following table provides the year-on-year variations in CPI and WPI for the last 5 years. Considering the average WPI and CPI and provisions of the Amendment to the MERC (MYT) Regulations 2015, MSEDCL has calculated the escalation factor as shown in the following table. Calculation of Escalation Factor Year WPI (2011-12) 106.90 112.50 113.88 109.72 111.62 114.88 FY 2012-13 FY 2013-14 FY 2014-15 FY 2015-16 FY 2016-17 FY 2017-18 5 Yrs Avg Weight 30% Rate with 1% reduction MSEDCL Annual Increase 5% 1% -4% 2% 3% 1.49% 0.45% 3.48% January 20 CPI Annual (2001) Increase 215.17 236.00 10% 250.83 6% 265.00 6% 275.92 4% 284.42 3% 70% 5.76% 4.03% 27 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 4.9.4 Considering the above escalation factor and O&M expenses for FY 15-16 after considering the impact of sharing of gains MSEDCL has calculated the O&M Expenses for Wires Business and Retail Supply of electricity for FY 17-18 (in the ratio of allocation matrix provided in the MYT Regulations 2015), as shown in following table. Table 18: O&M Expenses for Wires and Supply Business for FY 17-18 Particulars O&M Expenditure for Wires business O&M Expenditure for Retail Supply business Operation and Maintenance Expenses Rs. Crs FY 2017-18 FY 2017-18 Deviation (Approved) (Normative) 4,543.93 4,424.57 (119.37) 2,446.73 2,382.46 (64.27) 6,990.67 6,807.02 (183.64) 4.9.5 MSEDCL requests the Hon’ble Commission to allow the O&M Expenses as computed in above table. 4.10 Capitalisation for FY 2017-18 4.10.1 MSEDCL has achieved capitalization of Rs. 3,337.90 Cr. in FY 2017-18 as against Rs. 5,519.11 Cr. approved by Hon’ble Commission. Following table shows the capitalization in FY 2017-18. Table 19: Capitalisation for FY 17-18 Rs. Crs Particulars DPR Scheme Non DPR Scheme Total Capitalisation FY 2017-18 (Approved) 4,599.25 919.85 5,519.11 FY 2017-18 (Actual) 3,133.60 204.30 3,337.90 Deviation (1,465.65) (715.55) (2,181.21) 4.10.2 As per the Annual Accounts the addition to GFA is Rs. 3,379.29 Crs. whereas in Form 4.2 MSEDCL has shown Capitalization as Rs. 3,337.90 Crs. MSEDCL submits that in Form 4.2, only scheme wise details have been shown whereas in Annual Accounts the Addition to GFA is shown in totality including land and land rights, buildings etc. The detail of which is shown in the following table. MSEDCL January 20 28 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 20: Addition to GFA as per Annual Accounts for FY 17-18 Sr. No. 1 2 3 4 5 6 7 8 9 Particulars Capitalisation as per Note of the Accounts Capitalisation as per Form 4 Other Assets Land Buildings Vehicles Furniture & Fixtures General Assets Other Civil Works Total (2 to 8) Amount (Rs. Crs) 3,379.29 3,337.90 10.75 13.04 0.31 1.11 15.42 0.76 3,379.29 4.10.3 Further details of General Assets is summarised below: Particulars Hydraulics Works Communication Equipment IT Equipment Office Equipment Other Assets Total Amount (Rs. Crs) 0.47 1.07 4.97 1.14 7.78 15.42 4.10.4 Hon’ble Commission in its previous Orders has allowed the capitalization towards schemes not forming part of any specific scheme. MSEDCL further submits that Hon’ble Commission has accordingly revised the GFA to that extent as well. Therefore, MSEDCL requests the Hon’ble Commission to approve the capitalization as per the Audited Accounts and revise the GFA accordingly. 4.11 Depreciation for FY 2017-18 4.11.1 MSEDCL submits that in the MTR Petition, it has requested the Hon’ble Commission to reconcile the GFA and accordingly revise the opening GFA for FY 2015-16. In line with the approval of Rs. 927 Crs, MSEDCL has revised the GFA from FY 2007-08 onwards as detailed in Chapter 3. 4.11.2 The Opening GFA as per MSEDCL’s Audited Accounts is Rs. 49,151.79 Crs excluding the impact of Final Transfer Scheme/Restructuring Plan and MSEDCL January 20 29 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition subsequent revaluation. Accordingly, the depreciation has been reworked on a pro-rata basis on the revised Opening GFA for FY 2017-18 for the purpose of True-Up which is summarized below. Table 21: Depreciation for FY 17-18 Sr. No. 1 2 3 4 5 6 Particulars Opening GFA for FY 17-18 (Actual ) Revised Opening GFA* for FY 17-18 as per MERC Less: Consumer Contribution and Grants Net Opening GFA (Approved) Depreciation (Actual) Depreciation (Claimed in proportion to Actual) * Considering the impact of Rs. 927 Crs Amount (Rs. Crs) 49,151.79 48,442.09 760.55 47,681.54 2,184.18 2,118.85 4.11.3 MSEDCL requests the Hon’ble Commission to allow the Depreciation as computed in above table. 4.12 Funding Arrangement for FY 2017-18 4.12.1 As per the Regulation 26.1 of MERC (MYT), 2015, the debt-equity ratio as on the date of commercial operation shall be 70:30 of the amount of capital cost approved by the Commission. The said Regulation also provides that if the equity actually deployed is more than 30% of the capital cost, equity in excess of 30% shall be treated as normative loan for the Generating Company or Licensee or MSLDC for determination of Tariff. 4.12.2 MSEDCL submits that the Hon’ble Commission has designed the formats for submission of data in respect of Capex and Capitalization on yearly basis. MSEDCL further submits that the information required by Hon’ble Commission is on yearly basis whereas capital expenditure and capitalization of project is a process which continues for 3 to 5 years. With such different timelines, there will be spill-over of capex and capitalization and hence the capex and capitalization and its funding on yearly basis will never match. MSEDCL also submits that previously funding gap (if any) was shown as internal accrual and Hon’ble Commission has considered it as a part of normative equity or normative loan. It is pertinent to note that many times the Hon’ble Commission has restricted the equity to 30% if the equity portion of the funding is exceeded 30% and excess equity was treated as normative loan. Thus, Hon’ble MSEDCL January 20 30 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Commission has already given the necessary effect for additional equity. 4.12.3 MSEDCL submits that in FY 2017-18 the funds received in respect of Loan, Equity and Grant is more than the actual capital expenditure for the year. Therefore, MSEDCL has reduced the normative loan to that extent and actual equity infused during the year is considered. The grant and consumer contribution is considered in proportion to the funding pattern of capital expenditure. 4.12.4 The funding pattern for FY 2017-18 for the capitalization achieved by MSEDCL, in proportion to the funding pattern of capital Expenditure, is presented in the following table: Table 22: Funding of Capitalisation for FY 2017-18 Particular Total Capitalisation Less: Consumer Contribution Less: Grants Balance to be funded Equity Debt Amount (Rs. Crs) 3,337.90 268.40 1,031.67 2,037.82 560.80 1,477.02 Funding Mix (%) 27.52% 72.48% 4.12.5 MSEDCL requests the Hon’ble Commission to approve the funding as submitted in above table. 4.13 Interest Expenses for FY 2017-18 4.13.1 MSEDCL has computed the interest expenses on normative basis linked to the normative opening loan and normative loan addition during the year. In view of the approval of Rs. 927 Crs, MSEDCL has revised the normative opening loan from FY 2007-08 onwards in Chapter 3. 4.13.2 MSEDCL submits that the Regulation 29.5 of the MYT Regulations 2015 provides that at the time of Truing-up, the weighted average rate of interest computed on the basis of the actual loan portfolio during the concerned year shall be considered as the rate of interest. Accordingly, for arriving at the interest rate, MSEDCL has considered the weighted average interest rate of actual loan portfolio of FY 2017-18. The computation of weighted average MSEDCL January 20 31 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition interest rate of actual loan portfolio is shown in following table. Table 23: Computation of weighted avg. interest rate for FY 17-18 Particulars Actual (Rs. Crs) a 13,649.35 b 3,182.78 c 1,886.38 d=a+b-c 14,945.76 e=Avg(a,d) 14,297.55 f 1,442.88 g=f/e 10.09% Formula Outstanding Loan at the start of the year Loan drawal during the year Loan repayment during the year Balance outstanding at the end of the year Average Loan for the Year Interest Expense incurred during the year Weighted Average Interest rate 4.13.3 MSEDCL also submits that the opening balance of PFC/REC Loans as per Audited Accounts is inclusive of Medium Term Loan (MTL) whereas in above table, only long term capital loan amount is considered and MTL amount is not included. 4.13.4 Regulation 29.3 of the MERC (MYT) Regulations 2015 provides for repayment equal to depreciation. The relevant extract is reproduced below: 29.3 The repayment during each year of the Control Period from FY 2016-17 to FY 201920 shall be deemed to be equal to the depreciation allowed for that year. 4.13.5 Considering the normative opening loan, normative loan addition during the year and loan repayment equal to depreciation and the weighted average interest rate of actual loan portfolio, MSEDCL has computed the interest expenses on normative basis as summarized in table below: Table 24: Interest Expenses for FY 17-18 Rs. Crs Particulars Normative Outstanding Loan at beginning of the year Less: Reduction of Normative Loan due to retirement of assets Loan Drawal Loan Repayment Normative Balance Outstanding at the end of the year Average Balance of Net Normative Loan Interest Rate Interest Expenses MSEDCL January 20 FY 2017-18 FY 2017-18 (Approved) (Normative) 13,575.33 13,919.44 2,942.55 2,183.38 14,334.50 13,954.92 11.37% 1,586.38 1,477.02 2,118.85 13,277.61 13,598.53 10.09% 1,372.34 Deviation 344.10 (1,465.52) (64.54) (1,056.88) (356.39) (214.05) 32 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 4.13.6 MSEDCL submits that Hon’ble Commission had approved Funding of Capitalization based on the approved capitalization in the MTR Order dated 12th September 2018. However, actual capitalization is lower than the approved capitalization. The normative loan drawl is also lower than that approved in MTR Order. 4.13.7 MSEDCL requests the Hon’ble Commission to approve the normative interest expenses as submitted in the above table. 4.14 Interest on Working Capital for FY 2017-18 4.14.1 MSEDCL submits that the Regulations 31.3 of the MERC (MYT) Regulations 2015 provides for Interest on Working Capital for Wire business of electricity. Further, the MYT Regulations 2015 also provides that for the purpose of Truingup for any year, interest on working capital shall be allowed at a rate equal to the weighted average Base Rate prevailing during the concerned Year plus 150 basis points. However, Hon’ble Commission on 29th November 2017 issued the First Amendment to MYT Regulations 2015. In view of the MYT (First Amendment) Regulations, 2017, coming into force from 29th November, 2017, the rate of interest on working capital for FY 2017-18 is considered at a weighted average of SBI Base Rate plus 150 basis points for the first eight months and at one-year MCLR of SBI plus 150 basis points for the remaining four months. The detailed working of weighted average Base Rate is provided in following table. Table 25: Working of weighted average Base Rate From 01-04-2017 01-07-2017 01-10-2017 01-12-2017 01-01-2018 01-02-2018 01-03-2018 To 30-06-2017 30-09-2017 30-11-2017 31-12-2017 31-01-2018 28-02-2018 31-03-2018 Weighted Avg. Rate Plus 150 Basis Points Total Weighted Avg. Rate MSEDCL Days 91 92 61 31 31 28 31 Rate 9.10% 9.00% 8.95% 7.95% 7.95% 7.95% 8.15% Days X Rate 828% 828% 546% 246% 246% 223% 253% 365 8.69% 3170% 1.50% 10.19% January 20 33 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 4.14.2 MSEDCL has calculated the interest on working capital at 10.19% as computed in the following table. MSEDCL further submits that the amendment to the Regulation 29.11 of MYT Regulations 2015 provides for Interest on Security Deposit at MCLR plus 150 basis points. MSEDCL General Commercial Circular No. 258 for Rate of Interest on Consumer Security Deposit @ 9.50% per annum (MCLR plus 150 basis points) for FY 17-18 is attached as Annexure 4 to this Petition. Table 26: Interest on Working Capital for Wire business for FY 17-18 Rs. Crs Particulars Computation of Working Capital (Wire Business) O&M expenses for a month Maintenance Spares at 1% of Opening GFA 1.5 months of expected revenue from charges for use of Distribution wires Less: Amount held as SD from Distribution System Users Total Working Capital Requirement Rate of Interest (% p.a.) Interest on Working Capital Actual Working Capital Interest Interest on Security Deposit Rate of Interest (% p.a.) Interest on Security Deposit FY 2017-18 (Approved) FY 2017-18 (Normative) 379.00 431.00 368.71 435.98 1,162.00 1,174.95 12.95 (698.00) 1,274.00 10.20% 129.95 (698.60) 1,281.04 10.19% 130.48 89.38 (0.60) 7.04 10.60% 73.99 63.26 Deviation (10.29) 4.98 0.53 (10.73) 4.14.3 MSEDCL requests the Hon’ble Commission to allow the Interest on Working Capital along with the Interest on Security Deposit for wire business as shown in above table. MSEDCL January 20 34 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 27: Working Capital for Retail Supply business for FY 17-18 Rs. Crs Particulars Computation of Working Capital (Supply Business) O&M expenses for a month Maintenance Spares at 1% of Opening GFA 1.5 months equivalent of the expected revenue from sale of electricity at the prevailing Tariff and including revenue from CSS and Additional Surcharge Less: Amount held as security deposit Less: One month equivalent of cost of Power Purchase, Transmission Charges and MSLDC Charges Total Working Capital Requirement Rate of Interest (% p.a.) Interest on Working Capital Actual Working Capital Interest Interest on Security Deposit Rate of Interest (% p.a.) Interest on Security Deposit FY 2017-18 (Approved) FY 2017-18 (Normative) 204.00 48.00 198.54 48.44 7,582.00 7,797.44 (6,286.00) (6,287.40) (1.40) (4,495.00) (4,436.23) 58.77 (2,947.00) 10.20% - (2,679.21) 10.19% 804.43 267.79 10.60% 666.32 569.34 Deviation (5.46) 0.44 215.44 (96.98) 4.14.4 MSEDCL further submits that Regulation 31.4 of the MERC (MYT Regulations 2015) provides for Interest on Working Capital for Retail Supply business of electricity. MSEDCL has calculated the interest on working capital at 10.19% as computed above and interest on security deposit is paid at 9.50% i.e. MCLR plus 150 basis points and considered the actual paid amount as per audited accounts. 4.14.5 MSEDCL requests the Hon’ble Commission to allow the Security Deposit for supply business as shown in above table. 4.15 Other Finance Charges for FY 2017-18 4.15.1 MSEDCL submits that it has incurred Other Finance Charges amounting to Rs. 28.34 Crores during the FY 2017-18. These are the fund raising charges i.e. Guarantee Charges, Finance Charges, Stamp Duty and Service Fee. MSEDCL January 20 35 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 28: Other Finance Charges for FY 17-18 Particulars Guarantee Charges Finance Charges Stamp Duty Service Fee (Fund-raising charges) Total Rs. Cr. FY 2017-18 FY 2017-18 Deviation (Approved) (Actual) 0 1.20 1.20 0 24.17 24.17 0 0.61 0.61 0 2.36 2.36 28.34 28.34 4.15.2 MSEDCL submits that these charges depend on the no. of loans, LC required to be given to the Power Suppliers, documentation for availing long term and working capital loans. These charges are, thus, beyond reasonable control of MSEDCL and hence required to be allowed on actual basis. Therefore, MSEDCL humbly requests the Hon’ble Commission to allow the Other Finance Charges as per the Audited Accounts. 4.16 Provision for Bad Debts for FY 2017-18 4.16.1 MSEDCL submits that bad debts are inseparable incidents of the business of electricity distribution and retail supply. 4.16.2 Regulation 73 and 82 of the MYT Regulations, 2015 specifies that a provision of bad and doubtful debt may be allowed up to 1.5% of the amount shown as trade receivables or receivables in the Audited Accounts of the distribution licensee duly allocated for wires and supply business respectively. 4.16.3 MSEDCL submits that Provision of bad debt generally depends on the nature of the business and the risk involved in the business. A business typically estimates the amount of bad debt based on historical experience. 4.16.4 MSEDCL has written off Rs. 37.20 Crs against the bad debt during the FY 201718 details of which are summarised in following table. Sr. No. Category Amount (Rs. in Crs.) A PD LT consumers having arrears less than Rs. 1000 1 Residential MSEDCL 26.86 January 20 36 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Sr. No. 2 3 4 B C Category Amount (Rs. in Crs.) Commercial IP Other Total PD Amnesty Scheme Abhay Yojana Grand Total 3.53 0.49 0.50 31.39 5.72 0.09 37.20 4.16.5 MSEDCL has computed the provision for bad and doubtful debts for FY 201718 as per the provisions of the MYT Regulations 2015 considering the receivables as per Audited Accounts. Table 29: Provision for bad and doubtful debts for FY 2017-18 Rs. Crs FY 2017-18 (Approved) Particulars Opening Balance of Provision for bad and doubtful debts Receivables for the year Provision for bad & doubtful debts during the year Provision for bad & doubtful debts during the year Actual bad and doubtful debts written off Closing Balance of Provision for bad and doubtful debts Closing Balance as a % of receivables FY 2017-18 (Actual) 1,120.58 1,120.58 32,768.47 45,382.08 1.50% 491.53 1,612.10 4.92% Deviation 12,613.61 1.50% 680.73 189.20 37.20 37.20 1,764.11 152.00 3.89% 4.16.6 Considering the allocation matrix provided by Hon’ble Commission in the MYT Regulations 2015, MSEDCL has worked out the provision for Bad Debt for wire and retail supply businesses respectively as shown below. Table 30: Provision for Bad and Doubtful Debt (Wire and Supply) FY 2017-18 Particulars Bad Debt Provision for Wires business Bad Debt Provision for Retail Supply business Bad Debt Provision Rs. Crs FY 2017-18 FY 2017-18 Deviation (Approved) (Normative) 49.15 68.07 18.92 442.37 612.66 170.28 491.53 680.73 189.20 4.16.7 As per the above computation, MSEDCL humbly requests the Hon’ble MSEDCL January 20 37 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Commission to approve Rs. 680.73 Cr. towards the provision for Bad Debts for FY 17-18. 4.17 Other Expenses for FY 2017-18 4.17.1 The other expenses of MSEDCL comprise of the expenditure on account of Non-Moving items written off, interest to suppliers/contractors, Incentive to distribution franchisee and other expenses viz. compensation for injuries to staff and outsiders. MSEDCL accordingly submits the other expenses as shown in the table below. Table 31: Other Expenses for FY 2017-18 Rs. Crs Particulars Compensation for injuries,death to staff Compensation for injuries,death to others Loss on obsolescence of fixed Assets Sundry debit balances written off Non Moving Items Interest to Suppliers/Contractors Others Other Expenses (incl. payable to DSL towards damages in terms of Arbitral Award dt. 18.06.2004) Other Expenses for previous years Expected Credit loss on other receivables TOTAL FY 2017-18 (Approved) 1.23 14.81 3.45 2.39 FY 2017-18 (Actual) 1.28 16.05 22.53 1.55 1.67 280.71 - 41.41 63.30 41.81 11.89 8.99 386.47 Deviation 0.05 1.24 22.53 1.55 (1.79) 280.71 (2.39) 41.81 11.89 (32.42) 323.18 4.17.2 MSEDCL submits that the amount under the head “interest to suppliers/contractor” as per the Audited Accounts included Delayed Payment Charges / Surcharge payable to MSPGCL, MSETCL, IPPs & Wind Generators for FY 2017-18. MSEDCL has not claimed the same. 4.18 Contribution to Contingency Reserves for FY 2017-18 4.18.1 MSEDCL submits that considering the precarious financial condition and unavailability of sufficient funds to discharge its various liabilities, it was not feasible for MSEDCL to invest in contingency reserves. Therefore, MSEDCL has not invested any amount in contribution to contingency reserves. Accordingly, the same is not claimed in ARR of the FY 2017- 18. MSEDCL January 20 38 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 4.19 Incentives and Discounts for FY 2017-18 4.19.1 MSEDCL submits that during FY 2017-18, it has paid Rs. 242.40 Crs of incentives/discounts to the consumers for timely payment of bills as against Rs. 246.58 Crs approved by Hon’ble Commission in its MTR Order dated 12th September 2018. Table 32: Incentives/discounts for FY 17-18 Rs. Crs Particulars Incentives and Discount FY 2017-18 (Approved) 246.58 FY 2017-18 (Actual) 242.40 Deviation (4.19) 4.19.2 MSEDCL requests the Hon’ble Commission to allow the incentives/discounts as per the Audited Accounts for FY 2017-18. 4.20 RLC Refund for FY 2017-18 4.20.1 MSEDCL during FY 2017-18 has made a refund of Rs. 0.70 Crs of RLC. MSEDCL requests the Hon’ble Commission to allow the RLC Refund for FY 2017-18 as per Audited Accounts. MSEDCL also request the Hon’ble Commission to allow the RLC refund as and when it refunds the same to eligible consumers in future. Table 33: RLC Refund for FY 17-18 Rs. Crs FY 2017-18 (Approved) - Particulars RLC Refund FY 2017-18 (Actual) 0.70 Deviation 0.70 4.21 ASC Refund for FY 2017-18 4.21.1 MSEDCL during FY 2017-18 has made a refund of Rs. 0.49 Crs of ASC. MSEDCL requests the Hon’ble Commission to allow the ASC Refund for FY 2017-18 as per Audited Accounts. Table 34: ASC Refund for FY 17-18 Rs. Crs Particulars ASC Refund MSEDCL FY 2017-18 (Approved) FY 2017-18 (Actual) 0.49 January 20 Deviation 0.49 39 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 4.21.2 MSEDCL submits that the refund of ASC was made in the month of May-2017. Hon’ble Commission in the Order dated 7th July 2017 (Case No. 101 of 2016) has directed that “……..no further such refunds shall be made from the date of this Order irrespective of whether or not any applications are pending”. 4.21.3 As per said Order ASC refund stopped from the date of Order i.e. 7 July 2017. Being actual refund made to consumers before the Hon’ble Commission’s Order, MSEDCL submits that this ASC refund is in line with Hon’ble Commission’s earlier directives for ASC Refund. Hence, MSEDCL has claimed the ASC refund which is legitimate expense as per the Audited Account. 4.21.4 MSEDCL further submits that as per the Order of Hon’ble Commission dated 7th July 2017 in Case No. 101 of 2016, MSEDCL has stopped the refund of ASC. 4.22 Return on Equity for FY 2017-18 4.22.1 Regulation 28.2 of MERC (MYT) Regulations 2015 provides for Return on Equity (RoE) for Distribution Licensee for both Wire and Supply Business. In line with the approval of Rs. 927 Crs, MSEDCL has revised the normative opening equity from FY 2007-08 onwards in Chapter 3. Further, considering the funding pattern in Paragraph 4.12, MSEDCL has considered the equity addition during the year. 4.22.2 The return on equity capital is allocated in the ratio of Fixed Assets between the Wires and Retail Supply Business, i.e. 90% to Wires Business and 10% to Supply Business. Therefore, the capital expenditure, grants, equity and capitalisation is divided into wires and supply business in the ratio of 90:10. 4.22.3 MSEDCL further submits that it has not reduced the equity corresponding to the assets retired in FY 17-18 since retirement against only Land is seen and accordingly, claimed the ROE on entire equity. 4.22.4 Considering the provisions of the MYT Regulations 2015, MSEDCL has computed the return on equity as shown in following tables. MSEDCL January 20 40 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 35: RoE for wires business for FY 17-18 Rs. Crs FY 2017-18 (Approved) Particulars Return on Equity (Wires Business) Regulatory Equity at the beginning of the year Equity portion of Assets Capitalisation Equity portion of Assets Decapitalised Regulatory Equity at the end of the year Return on Computation Return on Regulatory Equity at the beginning of the year - 15.5%*(1) Return on Normative Equity portion of Asset Capitalization - 15.5%*(2)/2 Interest on Equity portion above 30% equity Total Return on Regulatory Equity FY 2017-18 (Normative) 9,796.00 1,270.00 11,066.00 9,719.53 504.72 10,224.25 1,518.38 1,506.53 98.43 39.12 6.00 1,622.81 1,545.64 Deviation (76.47) (765.28) (841.75) (11.85) (59.31) (71.16) Table 36: RoE for Supply business for FY 17-18 Rs. Crs Particulars FY 2017-18 (Approved) FY 2017-18 (Normative) 1,088 141 1,229 1,080 56 1,136 (7.60) (84.92) (92.52) 190.40 189.07 (1.33) 12.34 4.91 (7.43) 1 203.74 193.98 (8.76) Return on Equity (Supply Business) Regulatory Equity at the beginning of the year Equity portion of Assets Capitalisation Equity portion of Assets Decapitalised Regulatory Equity at the end of the year Return on Computation Return on Regulatory Equity at the beginning of the year - 17.5%*(1) Return on Normative Equity portion of Asset Capitalization - 17.5%*(2)/2 Interest on Equity portion above 30% @11.37%p.a. Total Return on Regulatory Equity Deviation 4.22.5 MSEDCL requests the Hon’ble Commission to allow the RoE as computed above. 4.23 Sharing of Efficiency Gains & Losses for FY 2017-18 4.23.1 Regulations 9, 10 and 11 of the MYT Regulations, 2015 specify the controllable and uncontrollable parameters, mechanism of pass-through of gains and losses on account of uncontrollable parameters, and the mechanism for their sharing on account of controllable parameters as follows: MSEDCL January 20 41 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition “11.1 The approved aggregate gain to the Generating Company or Licensee or MSLDC on account of controllable factors shall be dealt with in the following manner:— (a) Two-third of the amount of such gain shall be passed on as a rebate in Tariff over such period as may be stipulated in the Order of the Commission under Regulation 8.4; (b) The balance amount of such gain shall be retained by the Generating Company or Licensee or MSLDC. 11.2 The approved aggregate loss to the Generating Company or Licensee or MSLDC on account of controllable factors shall be dealt with in the following manner:— (a) One-third of the amount of such loss may be passed on as an additional charge in Tariff over such period as may be stipulated in the Order of the Commission under Regulation 8.4; (b) The balance amount of such loss shall be absorbed by the Generating Company or Licensee or MSLDC.” 4.23.2 Parameters such as O&M Expenses, Interest on Working Capital for which specific norms have been specified in the MYT Regulations, have been calculated on normative basis. 4.23.3 As these parameters need to be treated as controllable under the MYT Regulations 2015, any variation in the actual expenses as against the permissible normative levels has been shared between MSEDCL and consumers. 4.23.4 O&M Expenses: The actual O&M Expenses as per the Audited Accounts for FY 2017- 18 are lower than that on normative basis. 4.23.5 Interest on Working Capital: The actual IoWC expense as per the Audited Accounts for FY 2017-18 is higher than that on normative basis. 4.23.6 Distribution Loss: The actual distribution loss (excluding EHV Sales) for FY 2017-18 is lower than that approved in the MYT Order. MSEDCL January 20 42 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 4.23.7 The summary of sharing of efficiency gains/(loss) on account of O&M Expenses and IoWC is shown in the Table below: Table 37: Sharing of Efficiency Gains/(Losses) on O&M and IoWC Expenses for FY 2017-18 Particulars O&M Expenses Interest on Working Capital Normative 6,807.02 130.48 Actual 5,658.28 893.82 Rs. Crs 2/3 of Net Gains/ 1/3 of Efficiency Efficiency Entitlement (Loss) Gains/Losses gains/Losses after sharing 1,148.74 765.83 382.91 6,041.20 (763.34) (508.89) (254.45) 384.93 4.23.8 MSEDCL submits that it has computed the sharing of efficiency gain/ loss considering 16.26% as the approved distribution loss target (Excluding EHV Sales) against the actual distribution losses (Excluding EHV Sales) in accordance with the MERC (MYT) Regulations, 2015. MSEDCL further submits that the approved distribution loss of 13.50% for FY 2015-16 was inclusive of EHV sales. Hence, these two numbers cannot be compared for sharing purpose. It is pertinent to note that in MYT Order dated 3rd November 2016 the Hon’ble Commission itself has approved the distribution loss target as 16.26% (excluding EHV sales) for FY 2017-18. The normative loss of 13.50% was approved loss trajectory for FY 2015-16 on provisional basis and was inclusive of EHV Sales. 4.23.9 Since, Distribution Loss Trajectory excluding EHV sales was introduced by Hon’ble Commission for 3rd Control Period in MYT Order, the actual Distribution Loss excluding EHV sales needs to be compared with the approved Distribution Loss Trajectory excluding EHV sales. 4.23.10 The summary of sharing of efficiency gains/(loss) on account of Distribution Losses is shown in the Table below: MSEDCL January 20 43 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 38: Efficiency Gains/(Losses) due to lower Distribution Loss in FY 2017-18 Particulars Actual Distribution Loss MYT approved Loss Sales Excl. EHV sales in MUs EHV Sales in MUs Total Sales in MUs IntraSTS loss (Proposed) Power Requirement at Ex-Bus Periphery (Actual) in MUs Power Requirement at Ex-Bus Periphery (Normative) in MUs Additional/ (lower) Power purchase due to higher distribution loss in MUs Marginal Variable Cost of Power Purchase Rs./kWh Amount (Rs. Crs) 14.82% 16.26% 93,967 7,724 1,01,691 3.72% 1,22,602 1,24,566 (1,964.1) 3.24 Additional/(Lower) Power purchase Cost due to lower distribution loss 2/3 Efficiency gain/(loss) 1/3 Efficiency gain/(loss) to be borne by the consumers (637.10) 424.73 212.37 4.23.11 The total impact of sharing of efficiency gains and losses of various components have been summarized in the Table below: Table 39: Impact of sharing of gains and losses for FY 17-18 Particulars O&M Expenses IoWC Impact of Gain in Distribution Loss passed on Consumers Total Amount Rs. Crs (765.83) 254.45 212.37 (299.01) 4.23.12 MSEDCL requests the Hon’ble Commission to allow the sharing of gains and losses as submitted in above table. 4.24 Impact of payment to MPECS for FY 2017-18 4.24.1 Hon’ble Commission in the MYT Order dated 3rd November 2016 has approved following amounts towards payment to MPECS. Financial Year FY 17-18 FY 18-19 FY 19-20 MSEDCL Amount in Rs. Cr. 46.20 43.18 40.17 January 20 44 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 4.24.2 Hon’ble Commission in the MTR Order has approved the amount towards payment to MPECS as the same was allowed under the MYT Order. The Hon’ble Commission in the MTR Order also ruled that it shall consider the actual amount towards this head at the time of truing up of FY 2017-18. 4.24.3 MSEDCL has claimed Rs. 46.46 Crs towards the payments to MPECS for FY 2017-18 as per the Audited Accounts. 4.25 Past Period Adjustment by Commission for FY 2017-18 4.25.1 In the MTR Petition, MSEDCL had submitted that in the MYT Order dated 3rd November 2016, the Hon’ble Commission had considered the Net Impact of Past Period while approving the revenue for MSEDCL from revised tariffs for the third Control Period. MSEDCL had accordingly considered the impact of the same in the respective year during the MTR Process. 4.25.2 Hon’ble Commission had approved the past period adjustments of Rs. (1,116) Crs in MTR Order dated 12th September 2018 as approved in the MYT Order. MSEDCL has considered the same for FY 2017-18. 4.26 Aggregate Revenue Requirement for FY 2017-18 4.26.1 Considering the parameters discussed above, the Aggregate Revenue Requirement (ARR) of MSEDCL for Wires Business for the FY 2017 -18 is as follows: Table 40: ARR for Wires Business for FY 17 -18 Rs. Crs Particulars Operation & Maintenance Expenses Depreciation Interest on Loan Capital Interest on Normative Working Capital Interest on deposit from Consumers and Distribution System Users Other Finance Charges Provision for bad and doubtful debts Return on Equity Capital Aggregate Revenue Requirement MSEDCL FY 2017-18 (Approved) 4,543.93 1,965.04 1,427.74 129.90 FY 2017-18 (Actual) 4,424.57 1,906.96 1,235.10 130.48 74.04 63.26 (10.78) 49.15 1,643.41 9,833.22 25.50 68.07 1,545.64 9,399.59 25.50 18.92 (97.77) (433.63) January 20 Deviation (119.37) (58.08) (192.64) 0.58 45 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 4.26.2 MSEDCL submits that considering the parameters discussed above, the Aggregate Revenue Requirement (ARR) for Supply Business for the FY 2017 -18 is as follows: Table 41: ARR for Supply Business for FY 17 -18 Particulars Power Purchase Expenses Operation & Maintenance Expenses Depreciation Expenses Interest on Loan Capital Interest on Normative Working Capital Interest on Consumers Security Deposit Other Finance Charges Provision for bad and doubtful debts Other Expenses Intra-State Transmission Charges MSLDC charge Incentives/Discounts DSM expenses Return on Equity Capital RLC refund ASC refund Effect of sharing of gains/losses Past Period Adjustment by Commission Impact of payment to MPECS Aggregate Revenue Requirement for Supply Business Rs. Crs FY 2017-18 FY 2017-18 Deviation (Approved) (Actual) 49,129.74 48,422.63 (707.11) 2,446.73 2,382.46 (64.27) 218.34 211.88 (6.45) 158.64 137.23 (21.40) 666.32 569.34 (96.98) 2.83 2.83 442.37 612.66 170.28 63.30 386.47 323.18 4,812.17 4,812.17 246.58 242.40 (4.19) 0.88 4.30 3.42 182.60 193.98 11.38 0.70 0.70 0.49 0.49 (299.01) (299.01) (1,116.00) (1,116.00) 46.20 46.46 0.26 57,297.87 56,610.99 (686.88) 4.27 Revenue from sale of electricity for FY 2017-18 4.27.1 MSEDCL has considered the revenue for FY 2017-18 based on the Audited Accounts as shown in following table. Table 42: Revenue from Sale of power for FY 17-18 Rs. Crs Particulars Revenue from Sale of Power FY 2017-18 (Approved) 60,538.76 FY 2017-18 (Actual) 61,146.03 Deviation 607.27 4.27.2 The Annual Accounts of MSEDCL shows the revenue from various revenue operations including regulatory income. However, being not part of revenue from sale of power at retail tariff and as per practice in vogue, MSEDCL has MSEDCL January 20 46 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition shown certain items of revenue separately. 4.27.3 MSEDCL submits that the category wise details of actual revenue vis-à-vis approved revenue is summarized in following table. Table 43: Category wise Revenue for FY 2017-18 Category Residential Commercial HT-Industrial LT-Industrial PWW Street Light Agriculture Public Services Railways Other Categories Other (Subsidy/Recoveries from Theft etc) Sub Total Revenue from DF@input sales Standby Charges Total Revenue (Rs. Crs) Approved Actual Deviation 12,084.19 12,083.89 (0.30) 7,880.72 7,880.20 (0.52) 20,234.19 20,379.21 145.02 4,549.58 4,524.59 (24.98) 1,170.31 1,178.75 8.44 1,031.39 1,041.06 9.67 9,060.16 9,088.38 28.22 1,239.91 1,247.11 7.20 43.14 43.42 0.28 180.14 181.69 1.55 182.81 550.16 367.35 57,656.54 58,198.46 541.92 2,486.06 2,549.78 63.73 396.17 397.79 1.62 60,538.76 61,146.03 607.27 4.27.4 MSEDCL further submits that the detail of Others (Subsidy/ Recoveries from Theft of Power/Malpractice etc.) is provided in following table. Particulars Rs. Cr. FY 2017-18 (Actual) Recoveries from Theft of Power/Malpractice 88.41 Income from Wheeling Charges claimed Separately -1.46 Revenue from subsidy & grant 406.79 Miscellaneous charges from consumers Total 56.43 550.16 4.27.5 MSEDCL humbly requests to the Hon’ble Commission to consider the revenue from sale of power as shown in above table and true up the same. 4.28 Non-Tariff Income for FY 2017-18 4.28.1 MSEDCL has certain sources of non-tariff income viz. interest on arrears of MSEDCL January 20 47 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition consumers, delayed payment charges, interest on staff loans and advances, sale of scrap, interest on investment etc. 4.28.2 MSEDCL has claimed a Non-Tariff Income of Rs. 380.33 Crs as against Rs. 448.09 Crs as approved by the Hon’ble Commission. Table 44: Non-Tariff Income for FY 17-18 Rs. Crs Particulars Rents of land or buildings Sale of Scrap Income from investments Interest from Franchisee Income from sale of tender documents Prompt payment discount from REC/PFC Other/Miscellaneous receipts Non Tariff Income FY 2017-18 (Approved) 1.15 50.88 15.65 84.95 6.24 14.72 274.50 448.09 FY 2017-18 (Actual) 1.15 51.36 15.65 6.24 14.72 291.22 380.33 Deviation (0.00) 0.48 0.00 (84.95) 0.00 16.72 (67.76) 4.28.3 As provided in the Regulation 36.3 of the MYT Regulations 2015, delayed Payment Charge and Interest on Delayed Payment is not considered under Non-Tariff Income. 4.28.4 MSEDCL has not considered income from grants and contribution reported under non-tariff income amounting to Rs. 634 Crore, as the treatment to the same is already considered while computing the depreciation for the FY 201718. 4.28.5 As approved by Hon’ble Commission in MTR Order dated 12 th September 2018, MSEDCL has not considered the Grant of Rs.992 cr. received under UDAY Scheme. 4.28.6 MSEDCL further submits that the Other/Misc. receipts include Interest on loans & advances to supplier/contractors : Rs. 5.42 Crs Interest Income for prior period : Rs. 3.50 Crs Sundry Credit Balances written back : Rs. 38.86 Crs Miscellaneous Receipts : Rs. 146.61 Crs Penalty charges Recovered from Vendor : Rs. 78.87 Crs MSEDCL January 20 48 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Other income related to prior period : Rs. 23.42 Crs Other Adjustments: Rs.(5.46) Crs 4.29 Income from Open Access Charges for FY 2017-18 4.29.1 MSEDCL has an income from Open Access Charges of Rs. 546.56 Crs as against Rs. 536.17 Crs as approved by the Hon’ble Commission. Table 45: Income from Open Access Charges for FY 17-18 Rs. Crs FY 2017-18 (Approved) 536.17 Particulars Income from Open Access Charges FY 2017-18 (Actual) 546.56 Deviation 10.40 4.29.2 Details of income from Open Access charges are provided in the following Table. Table 46: Details of Income Open Access Charges for FY 17-18 Particulars Energy Charges Open Access F.C.A Charges Open Access Additional Charges Open Access Adjustment to past billing Open Access PF Penalty Open Access Cross Subsidy Surcharge Open Access Wheeling Charge Open Access Transmission Charge Open Access Operating Charges Open Access Additional Energy Charges Other Adjustments Total Income from Open Access Charges Amount (in Rs. Crs) 71.04 -1.56 0.05 -10.56 0.11 221.84 52.61 220.17 17.25 -1.08 -23 546.56 4.29.3 Hence, MSEDCL humbly requests to the Hon’ble Commission to approve the Income from Open Access Charges as per the Audited Accounts. 4.30 Income from Trading of Surplus Power for FY 2017-18 4.30.1 MSEDCL has an Income of Rs. 186.27 Crs. From trading of surplus power as MSEDCL January 20 49 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition provided in following table. Table 47: Income from Trading of Surplus Power for FY 17-18 Rs. Crs Particulars Income from Trading of Surplus Power FY 2017-18 (Approved) 179.94 FY 2017-18 (Actual) 186.27 Deviation 6.33 4.30.2 MSEDCL humbly requests to the Hon’ble Commission to approve the income from sale of surplus power as shown in above table. 4.31 Income from Wheeling Charges for FY 2017-18 4.31.1 MSEDCL has an income from Wheeling Charges of Rs. 1.46 Cr. in actual and as approved by the Hon’ble Commission. Table 48: Income from Wheeling Charges for FY 2017-18 Rs. Crs Particulars Income from Wheeling Charges FY 2017-18 (Approved) 1.46 FY 2017-18 (Actual) 1.46 Deviation - 4.31.2 Hence, MSEDCL humbly requests to the Hon’ble Commission to approve the Income from Wheeling Charges as per the Audited Accounts. 4.32 Income from Additional Surcharge for FY 2017-18 4.32.1 MSEDCL has an income from additional surcharge of Rs. 118.88 Cr during FY 2017-18. Table 49: Income from Additional Surcharge for FY 2017-18 Rs. Crs Particulars Income from Additional Surcharge FY 2017-18 (Approved) 118.88 FY 2017-18 (Actual) 118.88 Deviation - 4.32.2 MSEDCL humbly requests the Hon’ble Commission to approve the income from additional surcharge as per the Audited Accounts. 4.33 Revenue Gap/(Surplus) for FY 2017-18 4.33.1 Based on the above submissions, the summary of ARR (after sharing of MSEDCL January 20 50 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition efficiency gains &losses) for the Wires Business and Supply Business, as per Audited Account and as approved by the Hon’ble Commission, for FY 2017-18 is presented in the Table below. Table 50: Revenue Gap/Surplus for FY 17-18 Rs. Crs Particulars Power Purchase Expenses Operation & Maintenance Expenses Depreciation Expenses Interest on Loan Capital Interest on Normative Working Capital Interest on Consumers Security Deposit Other Finance Charges Provision for bad and doubtful debts Other Expenses Intra-State Transmission Charges MSLDC charge Incentives/Discounts DSM expenses Return on Equity Capital RLC refund ASC refund Effect of sharing of gains/losses Past Period Adjustment by Commission Impact of payment to MPECS in future years Aggregate Revenue Requirement Revenue from Sale of Power Non-Tariff Income Income from Open Access Charges Income from Trading of Surplus Power Income from Wheeling Charges Income from Additional Surcharge Total Revenue Revenue Gap/(Surplus) FY 2017-18 (Approved) 49,129.74 6,990.67 2,183.38 1,586.38 129.90 740.35 491.53 63.30 4,812.17 246.58 0.88 1,826.01 (1,116.00) 46.20 67,131.10 60,538.76 447.80 536.17 179.94 1.46 118.88 61,823.01 5,308.08 FY 2017-18 (Actual) 48,422.63 6,807.02 2,118.85 1,372.34 130.48 632.60 28.34 680.73 386.47 4,812.17 242.40 4.30 1,739.62 0.70 0.49 (299.01) (1,116.00) 46.46 66,010.58 61,146.03 380.33 546.56 186.27 1.46 118.88 62,379.54 3,631.04 Deviation (707.11) (183.64) (64.54) (214.05) 0.58 (107.75) 28.34 189.20 323.18 (4.19) 3.42 (86.39) 0.70 0.49 (299.01) 0.26 (1,120.52) 607.27 (67.46) 10.40 6.33 556.53 (1,677.05) 4.33.2 The Hon’ble Commission in its MTR Order dated 12th September 2018 has approved Aggregate Revenue Requirement of Rs. 67,131.10 Cr. for FY 201718. MSEDCL submits actual ARR of Rs. 66,010.58 Cr. with a deviation of Rs. (1,120.52) Crs. Considering the impact of revenue and other income, the truing up requirement works out to be Rs. (1,677.05) Cr. MSEDCL requests the Hon’ble Commission to allow MSEDCL the true up requirement as submitted above. MSEDCL January 20 51 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 5 5.1 TRUE UP OF FY 2018-19 Preamble 5.1.1 This section outlines the actual performance of MSEDCL for the FY 2018-19. MSEDCL hereby submits final True Up for FY 2018-19 comparing the actual audited data for FY 2018-19 with those approved by the Hon’ble Commission vide MTR Order dated 12th September 2018 in Case no. 195 of 2017. 5.1.2 The Board of Directors of MSEDCL has approved the Audited Annual Accounts for the period April 2018 to March 2019 and Statutory Auditors M/s. SGCO & Co. LLP, M/s. Shah & Taparia, and M/s CNK & Associates LLP have audited the Accounts vide report dated 25/10/2019 attached as Annexure 3 to this Petition. MSEDCL hereby proposes to true up its expenses and revenues based on the said Audited Accounts. 5.2 Category Wise Sales for FY 2018-19 5.2.1 Category wise actual sales for FY 2018-19 for MSEDCL excluding all Distribution Franchisee have been summarized in the following table: Table 51: Category wise Sales for FY 2018-19 Category Residential Commercial HT-Industrial LT-Industrial PWW Street Light Agriculture Public Services Railways Others MSEDCL Excl. DF FY 2018-19 (Approved) 19,564.23 7,418.70 28,647.64 6,849.84 2,330.36 1,883.04 30,137.30 1,445.99 59.25 702.42 99,038.77 Sales (MUs) FY 2018-19 (Actual) 19,718.85 7,276.70 31,025.59 6,763.16 2,329.59 1,958.44 33,853.32 1,456.10 67.08 686.98 1,05,135.81 Deviation 154.62 (142.00) 2,377.95 (86.68) (0.77) 75.40 3,716.02 10.11 7.83 (15.44) 6,097.04 5.2.2 MSEDCL submits that during the MTR Process, the Hon’ble Commission had approved the sales based on category-wise sales approved for FY 2017-18 as the base. The Hon’ble Commission had mostly applied 3-year CAGR for MSEDCL January 20 52 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition projecting the sales for FY 2018-19. Now, the actual figures of FY 2018-19 are available and the Audited Accounts for FY 18-19 of MSEDCL are also available. 5.3 Study of AG Dominated EHV Feeders: 5.3.1 The data of 734 EHV feeders feeding to MSEDCL AG dominated Substations were considered for study. These Selected EHV feeders feeding Distribution substations having AG feeder input more than 50% of total input. MSEDCL submits that the trend of the parameters under study have been analysed in the below tables. Table 52: Increase in AG Sales FY 18-19 (Half Yearly) All units are in MUs 734 EHV feeders MSEDCL H1 (Apr to Sep) H2 (Oct to Mar) EHV input AG Sale EHV input AG Sale 5,135 6,459 7,499 12,556 12,281 13,014 25.78 16.10 -2.19 5.97 FY 16-17 7,829 FY 17-18 9,954 FY 18-19 11,564 Year- on -Year trend (%) FY 17-18/16-17 27.14 FY 18-19/17-18 16.18 8,340 8,217 8,417 H1 (Apr to Sep) Total Total Ag I/p sales 55,291 10,720 60,927 12,813 65,804 15,316 H2 (Oct to Mar) Total Total Ag I/p sales 61,503 16,687 62,945 16,992 66,637 17,240 -1.48 2.44 10.19 8.01 2.35 5.86 19.52 19.53 1.83 1.46 Table 53: Increase in AG Sales FY 18-19 (Yearly) All units are in MUs 734 EHV feeders MSEDCL EHV input Total I/p 16-17 20,385 17-18 22,235 18-19 24,578 Year- on -Year trend (%) 13,475 14,675 15,916 1,16,794 1,23,872 1,32,441 Total Ag sales 27,407 29,805 32,556 AG Sale FY 17-18/16-17 9.07 8.91 6.06 8.75 FY 18-19/17-18 10.54 8.45 6.92 9.23 MSEDCL January 20 53 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 5.4 Observation for EHV Feeder Data 5.4.1 MSEDCL submits following observations for change in sale for FY 17-18 compared to FY 16-17 In H1 of FY 17-18, an increase of around 19.52% is observed in Actual AG sales. This aforementioned increase in MSEDCL AG Sales is substantiated with the input rise & AG Sales of EHV feeders feeding to MSEDCL Substations. The EHV feeder AG Sale rise of 25.78% is in line with Input rise of 27.14% of EHV feeders. In similar manner for H2 of FY 17-18, drop in EHV input (-2.19%) is reflected in drop in AG Sale (-1.48%). The above data for FY 2017-18 in comparison to FY 2016-17 shows rise of 8.91% in AG Sale of EHV feeder & rise of 8.75% in AG Sale of MSEDCL is in similar lines with the rise in EHV Input of 9.07%. 5.4.2 MSEDCL submits following observations for change in sale for FY 18-19 compared to FY 17-18 In H1 of FY 18-19, an increase of around 19.53% is observed in Actual AG sales. This aforementioned increase in MSEDCL AG Sales is substantiated with the input rise & AG Sales of EHV feeders feeding to MSEDCL Substations. The EHV feeder AG Sale rise of 16.10% is in line with Input rise of 16.18% of EHV feeders. In similar manner for H2 of FY 18-19, Rise in EHV input (5.97%) is reflected in rise in AG Sale (2.44%). The above data for FY 2018-19 in comparison to FY 2017-18 shows rise of 8.45% in AG Sale of EHV feeder & rise of 9.23% in AG Sale of MSEDCL is in similar lines with the rise in EHV Input of 10.54% The similar pattern displayed in the above figure strongly affirms the relationship between EHV Input and AG sales 5.4.3 MSEDCL hereby requests the Hon’ble Commission to approve the Sales for FY 2018-19 as submitted above. MSEDCL January 20 54 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 5.5 Distribution Losses for FY 2018-19 5.5.1 In MTR Order dated 12th September, 2018 in Case No. 195 of 2017, the Hon’ble Commission had approved distribution loss of 14.76% (excluding EHV Sales) for FY 2018-19. The actual distribution loss of MSEDCL for FY 2018-19 is 14.70% which is (0.06%) less than the Distribution Loss level approved by the Hon’ble Commission. Table 54: Distribution Losses FY 2018-19 Particulars Distribution Loss FY 2018-19 (Approved MYT Order) 14.76% FY 2018-19 (Actual) 14.70% Deviation (0.06%) 5.5.2 MSEDCL submits that it has been putting best endeavours for lowering the Distribution Losses to the lowest possible level. MSEDCL has achieved a significant reduction in distribution losses during recent years. However, loss reduction is a slow process and becomes increasingly difficult for the loss levels to come down. The change in sales mix also impact the distribution losses. 5.5.3 MSEDCL requests the Hon’ble Commission to approve the actual Distribution Loss as per the above table. 5.6 Energy Balance for FY 2018-19 5.6.1 The quantum of sales ( 1,05,135.81 MUs) shown in Table 51 represents the sales of MSEDCL excluding the sales in the area served by Distribution Franchisees. MSEDCL has further added 73.89 MUs against the solar offset units. As per the methodology adopted by Hon’ble Commission for calculating energy balance of MSEDCL as a whole, the sale to the consumers within the Distribution Franchisee area has also been considered. Therefore, energy available for sale for FY 2018-19 is computed as below: MSEDCL January 20 55 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 55: Energy Sales for MSEDCL for FY 2018-19 MUs FY 2018-19 (Approved) Particulars Energy Sales by MSEDCL for FY 2018-19 incl. Offset Solar Units Add: Category wise sales in DF area Add: OA Sales (Conventional) Add: Renewable OA Total Energy Sales 99,038.77 4,675.16 4,546.50 712.95 1,08,973.38 FY 2018-19 (Actual) 1,05,209.70 4,395.33 3,967.38 854.92 1,14,427.33 Deviation 6,170.93 (279.83) (579.12) 141.97 5,453.95 5.6.2 MSEDCL has traded surplus power of 1,413 MUs as and when available through energy exchanges and bilateral trading. 5.6.3 MSEDCL further submits that it is procuring power from various Sources including MSPGCL, CGS including nuclear power plants, Traders, IPPs and Renewable Sources. It would be very difficult to differentiate which power is coming from which source at Transmission periphery. Hence an average interstate loss for the whole year is considered for power sourced from outside the State of Maharashtra. 5.6.4 MSEDCL also submits that data of metered energy is available at 3 points: at bus-bar of the generating station, at T <> D interface i.e. at Distribution Periphery and sales at consumer end. It is further to state that to calculate Distribution Loss, it considers metered energy. 5.6.5 MSEDCL further submits that the TAPS (NPCIL) and EMCO Power Plants are connected to CTU and therefore considered as Inter-State sources. 5.6.6 As discussed in paragraph 4.4.12, MSEDCL has considered the inter-state transmission losses as based on the web based scheduling reports of WRLDC. 5.6.7 MSEDCL further submits that FBSM has been finalized by SLDC only till February 2018. FBSM is an Inter-Utility settlement and therefore, finalization of FBSM affects the Inter-Utility quantum resulting into modification of Transmission Loss of the Intra State Distribution Licensees. MSEDCL further submits that as discussed in Paragraph 4.4.13, it has computed Intra-State MSEDCL January 20 56 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition losses 5.6.8 Considering the energy available for sale for FY 2018-19 as shown in Table 55, the energy balance for MSEDCL is calculated. The following table shows the energy balance for FY 18-19. Table 56: Energy Requirement and Energy Balance FY 2018-19 Sr. No. 1 3 4 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Particulars LT Sales (Including D.F) HT Sales excluding EHV level sales (Including D.F) HT/LTIP Credit Sales and HT/LT Offset Export Solar units Total Sales including D.F (Excluding EHV Sales) OA Sales (Renewables) OA Sales (Conventional) Retail Energy Sale to Consumers (Excluding EHV Sales) Total Power Purchase Power Purchase Quantum from Intra-State sources Power Purchase Quantum from Inter-State sources Inter-State Losses Power Purchase Quantum from Inter-State sources at MS Periphery Add: FBSM Power Quantum handled at Maharashtra Periphery Infirm Non-PPA Wind Power Input for OA Consumption Total Power Purchase Quantum Handled Surplus Power Traded Energy Requirement at G<>T Periphery Intra-State Transmission Loss Intra-State Transmission Loss Net Energy requirement at T<>D Periphery EHV Sales Net Energy Available for Sale at 33kV Energy injected and drawn at 33kV Total Energy Available for Sale at 33kV (Metered Energy at EHV and 33 kV Input) Distribution Loss (Excl. EHV Sales) Distribution Loss (Excl. EHV Sales) Calculation UoM a b c d=a+b+c e f A=d+e+f B=g+h g h i j=h*(1-i) k l=g+j+k m n=f/(1-6%) o=l+m+n-w p q=o-p r s=q*r t=q-s u v=t-u w MU MU MU MU MU MU MU MU MU MU % MU FY 2018-19 MTR Order Actual MU MU MU MU MU MU % MU MU MU MU MU 68,236 27,363 95,598 713 4,547 1,00,858 1,27,199 87,596 39,604 3.30% 38,297 1,25,892 4,837 1,30,241 1,27,459 3.30% 4,298 1,25,943 8,116 1,17,827 488 71,527 28,391 73.89 99,991 855 3,967 1,04,813 1,36,435 89,916 46,519 3.07% 45,091 -1,286 1,33,721 909.48 4,221 1,38,278 1,413 1,36,866 3.62% 4,956 1,31,910 9,614 1,22,296 573 C=v+w MU 1,18,315 1,22,869 D=C-A E=D/C MU % 17,458 14.76% 18,062 14.70% 5.6.9 MSEDCL requests the Hon’ble Commission to approve the Energy Balance as shown in the table above. 5.7 Power Purchase Expenses for FY 2018-19 5.7.1 MSEDCL has following sources of firm power viz. Maharashtra State Power Generation Company Limited (MSPGCL) Purchase from Central Generating Stations JSW (Ratnagiri) MSEDCL January 20 57 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Mundra UMPP CGPL Adani Power Limited RattanIndia Limited Emco Power Limited etc. 5.7.2 MSEDCL also buys power from other sources such as Sardar Sarovar and Pench Hydro project, renewable sources including co-generation, wind power and solar generation. 5.7.3 In addition to the above sources, In case of any shortfall from approved sources, when demand exceeds availability or for cost optimization, MSEDCL sources power from exchange/Traders or other sources at the market price through competitive bidding in accordance with the Guidelines of MoP. 5.7.4 Following table summarizes the source wise power purchase done by MSEDCL during the FY 18-19. Table 57: Source wise Power Purchase for FY 18-19 Source MSPGCL NTPC NPCIL SSP Pench Dodson JSW CGPL Adani Power EMCO Power Rattan India Renewable Traders RECs Short provision for PP Other Adjsutments PGCIL Charges FBSM Intra State Purchase Rebate Total Power Purchase PP Quantum (MUs) PP Cost (Rs. Cost) PP Cost (Rs. /Unit) Approved Approved in Approved in in MTR Actual Deviation Actual Deviation Actual Deviation MTR Order MTR Order Order 47,691.69 49,423.42 1,731.73 18,715.20 19,648.52 933.32 3.92 3.98 0.05 25,936.59 29,665.17 3,728.58 8,197.40 9,562.31 1,364.91 3.16 3.22 0.06 5,470.24 4,475.32 (994.92) 1,400.42 1,263.15 (137.27) 2.56 2.82 0.26 1,209.94 153.63 (1,056.31) 248.04 31.49 (216.54) 2.05 2.05 (0.00) 136.50 43.71 (92.79) 27.98 8.96 (19.02) 2.05 2.05 (0.00) 115.72 78.01 (37.71) 21.31 24.58 3.27 1.84 3.15 1.31 2,055.10 1,998.60 (56.50) 658.89 686.59 27.71 3.21 3.44 0.23 5,480.26 4,854.00 (626.26) 1,373.08 1,456.84 83.76 2.51 3.00 0.50 20,207.15 21,140.45 933.30 6,898.58 9,126.87 2,228.29 3.41 4.32 0.90 1,370.06 1,313.25 (56.81) 496.05 593.76 97.72 3.62 4.52 0.90 3,717.12 3,717.12 982.87 1,970.07 987.20 5.30 5.30 17,526.06 13,558.44 (3,967.62) 8,881.68 7,745.56 (1,136.13) 5.07 5.71 0.65 6,022.64 6,022.64 2,870.47 2,870.47 4.77 4.77 154.56 154.56 (287.05) (287.05) (354.61) (354.61) 2,688.00 2,808.75 120.75 9.03 9.03 (1,006.07) (1,006.07) 6.26 6.26 (50.68) (50.68) 1,27,199 1,36,452.80 9,253 50,589 56,260 5,671 3.98 4.12 0.15 A) MSPGCL – The Hon'ble Commission in Order dated 12th September 2018 in Case No. 196 of 2017 did not approve quantum and cost of the following generation stations of MSPGCL: BHUSAWAL-3 MSEDCL January 20 58 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition NASHIK- 3,4 & 5 PARAS UNIT-3 & 4 PARLI UNIT-6&7 PARLI - 4&5 Parli Replacement U-8 However, due to coal shortages MSEDCL has purchased power from above mentioned units. Hence the actual quantum of power from MSPGCL generating units have increased as compare to that approved by the Hon’ble Commission. Further, the Hon'ble Commission did not consider Fixed and Variable cost for Parli Replacement Unit 8 but MSEDCL has purchased power worth Rs. 751 Cr. from this station. B) Central Generating Stations- The Hon'ble Commission did not consider the quantum of the Mauda and NTPC-Solapur generating stations. However, due to coal shortages MSEDCL has purchased power from the above mentioned units, hence the actual quantum and cost from central sector generating units is higher than that approved by the Hon’ble Commission. Further to this, CERC has approved new tariff for Gandhar in it’s Tariff Order dated 19.02.2019. Hence the cost has increased. C) JSW- The increase in cost is due to impact of Rs. 41 Cr. due to Change in Law. D) Adani – MSEDCL submits that it has paid an amount of Rs. 1786 Crs along with carrying cost to M/s. APML towards compensation in domestic coal shortfall. Such compensation is as per Order of Hon. Commission in case No. 189 of 2013 dtd. 07.03.2018 and case no 290 of 2018 dtd. 22.12.2018. M/s. APML submitted claim towards principal of Rs. 2821 Crs and carrying cost of Rs. 1316 Crs. However, MSEDCL has paid only 50% amount of claim along with carrying cost. E) CGPL: Actual MUs are less than approved by Hon'ble Commission. MSEDCL January 20 59 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition However, there is increase in cost is due to Change in Law of Rs. 108 Crs. F) CERC published new escalation indices in June’ 2018 & July’ 2018 and revised the escalation index applicable to Domestic coal and transportation from April’ 2013. This has resulted in increase in Energy Charges. Such revision in index has resulted in increased energy charges by Rs. 0.26 p.u. approximately in respect of APML 125 MW, 1200 MW & 440 MW PPAs (1320 MW PPA does not include escalable tariff component). Since, such indices were revised from April 2013; MSEDCL had to make payment of Rs. 102.22 Crs. pertaining to period April 2013 to May 2018 to M/s. APML during FY 2018-19. Further, the Capacity charges for APML 440 MW PPA are more than that of approved (Rs. 447 Crs against Rs. 77 approved in MTR order). G) RattanIndia: Hon’ble Commission had not approved any quantum from Rattan India, however, owing to coal shortage and demand increase, MSEDCL had to buy power from RattanIndia. Hon’ble Commission had approved only Capacity charges of Rs. 983 Crs. However, MSEDCL bought 3,717.12 MUs from RattanIndia. Due to this there is a deviation of Rs. 987.20 Crs in RattanIndia. H) EMCO- MSEDCL had projected variable cost of Rs. 1.83 p.u. for the FY 2018-19. However, due to change in CERC index towards fuel and transportation from FY 2013, there is increase in escalable energy charges by Rs. 0.21 p.u. (Impact is around Rs. 35 Crs.); Moreover, CERC has approved some change in law events in favor of M/s. EMCO Ltd, such as evacuation facility charges, Busy season and development surcharge etc. (Impact is around Rs.30 Crs.), Other charges are increased more than that projected. Such increase constitute around Rs. 20 Crs. MSEDCL has paid an amount of Rs. 11.5 Crs towards domestic coal shortfall i.e. (NCDP policy). I) Short Term PP- Due to increase in demand for the months of Sept 2018 and Oct 2018, MSEDCL has purchased short term power which increased in PP cost by Rs.1672.14 Cr. MSEDCL January 20 60 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition J) MSEDCL further submits that in the Audited Accounts of FY 18-19, it has made a provision of Rs.2,390 Crs towards the shortfall in achieving the renewable purchase obligation (RPO) for FY 18-19. However, since it is only provision, MSEDCL has not claimed the same in actual cost of power purchase for FY 18-19. MSEDCL reserves its right to claim the same on actual basis as and when such expense is incurred. 5.7.5 MSEDCL most respectfully submits that the above changes are beyond the reasonable control of MSEDCL but well within the regulatory provisions for consideration in true up. Hence, MSEDCL requests the Hon’ble Commission to approve the power purchase expenses as per Audited Accounts. 5.7.6 MSEDCL submits that details of RE Purchase for FY 18-19 are provided in following table. FY 2018-19 Quantum (MU) Cost (in Rs. Crs.) Wind 6619.70 3539.75 SHP 315.60 134.68 Bagasse based Cogen. 4173.81 2638.19 Biomass 488.89 282.00 MSW 0.97 0.47 Total Non-Solar 11,598.97 6,595.09 SPV 1957.64 1150.47 Solar REC upto 2015-16 1360 152.42 2016-17 19 2.13 Total Solar REC 1379 154.55 Total Solar 1957.64 1150.47 Source 5.7.7 MSEDCL would like to make following submission regarding RPO fulfilment for FY 18-19 MSEDCL January 20 61 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Solar Target: MSEDCL has procured 2279 MUs of Solar Power during FY 2018-19 and has the standalone shortfall of 1321 MUs for FY 2018-19. Non-Solar Target: MSEDCL has procured 12468 MUs of Non-Solar Power during FY 2018-19 and has the standalone shortfall of 1933 MUs for FY 2018-19. 5.8 Transmission Charges for FY 18-19 5.8.1 MSEDCL submits the actual transmission charges and SLDC charges paid to MSETCL and MSLDC as summarized in following table. Table 58: Transmission Charges paid to Transmission Licensee for FY 2018-19 Rs. Crs Particulars Intra-State Transmission Charges MSLDC Charges Total FY 2018-19 (Approved) 4,288.40 14.12 4,302.53 FY 2018-19 (Actual) 4,760.61 14.89 4,775.50 Deviation 472.21 0.77 472.98 5.8.2 MSEDCL submits that it pays the transmission charges to STU as per the InSTS Order issued by Hon’ble Commission from time to time. MSEDCL submits that the Hon’ble Commission in the MTR Order has approved the IntraState Transmission Charges based on Order for InSTS Charges in Case No. 265 of 2018. The said Order was applicable from September 2018. MSEDCL Made payment up Aug. 2018 as per MYT Order in case No. 48 of 2016. Thereafter, payment made as per MTR order in case No. 195 of 2017. The transmission Charges reduced from Rs. 450 Crs per month to Rs. 358 Crs. Per month Due to this, there a deviation in the Intra-State Transmission Charges. However, Hon’ble Commission approved the reduced Transmission Charges for entire year. 5.8.3 MSEDCL requests the Hon’ble Commission to approve the actual Transmission and MSLDC Charges as per the Audited Accounts as shown in the above table. MSEDCL January 20 62 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 5.9 Fixed Costs for FY 2018-19 5.9.1 Based on the Capital Cost and the consequent Capitalized Expenditure, Equity Component and Normative Debt, the fixed cost of MSEDCL for FY 2018-19 (excluding fixed component of PP cost) has been determined in accordance with the provisions of MYT Regulations 2015 outlined thereof. As outlined under the regulations, the fixed cost for MSEDCL has been determined under the following major heads long with other items of expenditure: Operation and Maintenance Expenses Depreciation Interest and Finance Charges Interest on Working Capital Return on Equity 5.9.2 Net Annual Revenue Requirement has been computed after netting off Expenses capitalized. 5.9.3 Head wise comparison has been made between the values approved by the Hon’ble Commission vide MTR Order dated 12th September 2018 in Case no. 195 of 2017 for FY 2018-19 and the values as per the audited accounts. 5.10 Actual Operation & Maintenance Expenses for FY 2018-19 5.10.1 Operations and Maintenance (O&M) Expenses of the company consists of Employee Expenses, Administrative and General Expenses and Repairs and Maintenance Expenses 5.10.2 MSEDCL submits that as per audited accounts it has incurred total O&M expenses of Rs. 6,401.01 Cr. for FY 2018-19. Table 59: Actual O&M Expenses for FY 2018-19 Particulars Actual O&M Expenses Rs. Crs Actual 6,401.01 5.10.3 Head-wise details of employee expenses, A&G Expenses and R&M Expenses MSEDCL January 20 63 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition have been provided in Regulatory Formats. 5.10.4 In the following sub-section, MSEDCL has given the detailed reasons for change in the O&M cost for FY 18-19. 5.11 Normative Operation & Maintenance Expenses for FY 2018-19 5.11.1 MSEDCL submits that Regulation 72 and Regulation 81 of the MERC (MYT) (1st Amendment) Regulations 2017provides for the O&M Expenses norms for Distribution Wires Business and Retail Supply of electricity respectively. 5.11.2 Hon’ble Commission has issued an Amendment to the MERC (MYT) Regulations 2015. As per the said Amendment relating to the Truing-up of O&M expenses: ”72.3….. Provided that, in the Truing-up of the Operation and Maintenance expenses for any particular year of the Control Period, an inflation factor with 30% weightage to the average yearly inflation derived based on the monthly Wholesale Price Index of the past five financial years (including the year of Truing-up) and 70% weightage to the average yearly inflation derived based on the monthly Consumer Price Index for Industrial Workers (all-India) of the past five financial years (including the year of Truing-up), as reduced by an efficiency factor of 1% or as may be stipulated by the Commission from time to time, shall be applied to arrive at the permissible Operation and Maintenance Expenses for that year.” 5.11.3 Following table provides the year-on-year variations in CPI and WPI for the last 5 years. Considering the average WPI and CPI and provisions of the Amendment to the MERC (MYT) Regulations 2015, MSEDCL has calculated the escalation factor as shown in the following table. MSEDCL January 20 64 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 60: Escalation factor for FY 2018-19 WPI (2011-12) Year FY 2013-14 112.50 FY 2014-15 113.88 FY 2015-16 109.72 FY 2016-17 111.62 FY 2017-18 114.88 FY 2018-19 119.80 5 Yrs Avg Weight 30% Rate with 1% reduction Annual Increase 1% -4% 2% 3% 4% 1.30% 0.39% 2.83% CPI (2001) 236.00 250.83 265.00 275.92 284.42 299.92 70% Annual Increase 6% 6% 4% 3% 5% 4.92% 3.44% 5.11.4 Considering the above escalation factor and O&M expenses for FY 15-16 after considering the impact of sharing of gains computed in Chapter 2, MSEDCL has calculated the O&M Expenses for Wires Business and Retail Supply of electricity for FY 18-19 (in the ratio of allocation matrix provided in the MYT Regulations 2015), as shown in following table. Table 61: O&M Expenses for FY 2018-19 Particulars O&M Expenditure for Wires business O&M Expenditure for Retail Supply business Operation and Maintenance Expenses Rs. Crs FY 2018-19 FY 2018-19 Deviation (Approved) (Normative) 4,773.68 4,492.93 (280.76) 2,570.44 2,419.27 (151.18) 7,344.13 6,912.20 (431.93) 5.11.5 MSEDCL requests the Hon’ble Commission to allow the O&M Expenses as computed in above table. 5.12 Capitalisation for FY 2018-19 5.12.1 MSEDCL has achieved capitalization of Rs. 5,240.66 Cr. in FY 2018-19 as against Rs. 4,565.00 Cr. approved by Hon’ble Commission. Following table shows the capitalization in FY 2018-19. MSEDCL January 20 65 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 62: Capitalisation for FY 2018-19 Rs. Crs Particulars Total Capitalisation FY 2018-19 (Approved) 4,565.00 FY 2018-19 (Actual) 5,240.66 Deviation 675.66 5.12.2 As per the Annual Accounts the addition to GFA is Rs. 5,334.45 Crs. whereas in Form 4.2 MSEDCL has shown Capitalization as Rs. 5,240.66 Cr. MSEDCL submits that in Form 4.2, only scheme wise details have been shown whereas in Annual Accounts the Addition to GFA is shown in totality including land and land rights, buildings etc. The detail of which is shown in the following table. Table 63: Capitalization as per Audited Accounts for FY 2018-19 Sr. No. 1 2 3 4 5 6 7 8 9 Particulars Capitalisation as per Note of the Accounts Capitalisation as per Form 4 Other Assets Land Buildings Vehicles Furniture & Fixtures General Assets Other Civil Works Total (2 to 8) Amount (Rs. Crs) 5,334.45 5,240.66 5.63 20.24 1.53 46.23 20.16 5,334.45 5.12.3 MSEDCL further submits that the additional details of general assets are provided in following table. Particulars Hydraulic works Communication Equipment IT Equipment Office Equipment Other Assets Total MSEDCL January 20 Amount Rs. Crs 1.42 0.41 1.96 29.92 12.52 46.23 66 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 5.12.4 Hon’ble Commission in its previous Orders has allowed the capitalization towards schemes not forming part of any specific scheme. MSEDCL further submits that Hon’ble Commission has accordingly revised the GFA to that extent as well. Therefore, MSEDCL requests the Hon’ble Commission to approve the capitalization as per the Audited Accounts and revise the GFA accordingly. 5.13 Depreciation for FY 2018-19 5.13.1 MSEDCL submits that in the MTR Petition, it has requested the Hon’ble Commission to reconcile the GFA and accordingly revise the opening GFA for FY 2015-16. In line with the approval of Rs. 927 Crs, MSEDCL has revised the GFA from FY 2007-08 onwards in Chapter 3. 5.13.2 The Opening GFA as per MSEDCL’s Audited Accounts is Rs. 49,760.55 Cr. (excluding the impact of Final Transfer Scheme/Restructuring Plan and subsequent revaluation). Accordingly, the depreciation has been reworked on a pro-rata basis on the revised Opening GFA for FY 2018-19 for the purpose of True-Up which is summarized below. Table 64: Depreciation for FY 2018-19 FY 18-19 (Approved) Particulars Opening GFA for FY 18-19 (Actual) Opening GFA for FY 18-19 (Regulatory*) Depreciation (Actual) Depreciation (Claimed in proportion to Actual) * Excluding consumer contribution and grants 2,329.48 FY 18-19 (Actual) 49,760.55 2,601.18 2,464.00 5.13.3 MSEDCL requests the Hon’ble Commission to allow the Depreciation as computed in above table. 5.14 Funding Pattern for FY 2018-19 5.14.1 The funding pattern for FY 2018-19 for the capitalization achieved by MSEDCL, in proportion to the funding pattern of capital Expenditure, is presented in the following table: MSEDCL January 20 67 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 65: Funding Pattern of Capitalization for FY 2018-19 Particular Total Capitalisation Less: Consumer Contribution Less: Grants Balance to be funded Equity Debt Amount (Rs. Crs) 5,240.66 626.45 2,057.93 2,556.28 365.54 2,190.74 Funding Mix (%) 14.30% 85.70% 5.14.2 MSEDCL requests the Hon’ble Commission to approve the funding mix as submitted in above table. 5.15 Interest Expenses for FY 2018-19 5.15.1 MSEDCL has computed the interest expenses on normative basis linked to the normative opening loan and normative loan addition during the year. In line with the approval of Rs. 927 Crs, MSEDCL has revised the normative opening loan from FY 2007-08 onwards as in Chapter 3. Further, for arriving at the interest rate, MSEDCL has considered the weighted average interest rate of actual loan portfolio of FY 2018-19. The computation of weighted average interest rate of actual loan portfolio is shown in following table. Table 66: Rate of Interest for FY 2018-19 Particulars Actual (Rs. Crs) a 14,945.76 b 1,592.27 c 2,355.38 d=a+b-c 14,182.66 e=Avg(a,d) 14,564.21 f 1,496.49 g=f/e 10.28% Formula Outstanding Loan at the start of the year Loan drawal during the year Loan repayment during the year Balance outstanding at the end of the year Average Loan for the Year Interest Expense incurred during the year Weighted Average Interest rate 5.15.2 Regulation 29.3 of the MERC (MYT) Regulations 2015 provides for loan repayment equal to depreciation. The relevant extract is reproduced below: “29.3 The repayment during each year of the Control Period from FY 2016-17 to FY 2019-20 shall be deemed to be equal to the depreciation allowed for that year.” MSEDCL January 20 68 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 5.15.3 MSEDCL further submits that for FY 18-19, the amount of Rs.15.76 Crs was inadvertently considered twice in addition to asset. The same was corrected; however, instead of reduction to addition in asset, it is erroneously shown as retirement of asset. Since there is no retirement of assets, MSEDCL has not reduced the loan to that extent. MSEDCL further submits that since there is only adjustment and not actual reduction, it has claimed the normative interest on balance loan. 5.15.4 Considering the normative opening loan, normative loan addition during the year and loan repayment equal to depreciation and the weighted average interest rate of actual loan portfolio, MSEDCL has computed the interest expenses on normative basis as summarized in table below: Table 67: Interest Expenses for FY 2018-19 Rs. Crs Particulars Normative Outstanding Loan at beginning of the year Less: Reduction of Normative Loan due to retirement of assets Loan Drawal Loan Repayment Normative Balance Outstanding at the end of the year Average Balance of Net Normative Loan Interest Rate Interest Expenses FY 2018-19 FY 2018-19 (Approved) (Normative) 14,334.50 13,277.61 1,680.60 2,190.74 2,329.35 2,464.00 13,685.75 13,004.36 14,010.12 13,140.99 11.37% 10.28% 1,592.66 1,350.25 Deviation (1,056.88) 510.14 134.65 (681.39) (869.14) (242.40) 5.15.5 MSEDCL submits that Hon’ble Commission had approved interest expenses of Rs. 1,592.66 Cr. while the normative Interest Expenses for MSEDCL works out to be Rs. 1,350.25 Cr. for FY 2018-19. 5.15.6 MSEDCL requests the Hon’ble Commission to approve the normative interest expenses as submitted in above table. 5.16 Interest on Working capital for FY 2018-19 5.16.1 MSEDCL submits that Regulations 31.3 of the MERC (MYT) Regulations 2015 provides for Interest on Working Capital for Wire business of electricity. Further, the MYT Regulations 2015 also provides that for the purpose of Truing-up for any year, interest on working capital shall be allowed at a rate equal to the MSEDCL January 20 69 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition weighted average Base Rate prevailing during the concerned Year plus 150 basis points. 5.16.2 MSEDCL has calculated the interest on working capital at 9.89% as computed in following table. Table 68: Calculation of Weighted Avg. Arte of MCLR To Days From 01-04-2018 30-04-2018 30.00 01-05-2018 31-05-2018 31.00 01-06-2018 30-06-2018 30.00 01-07-2018 31-07-2018 31.00 01-08-2018 30-08-2018 30.00 01-09-2018 30-09-2018 30.00 01-10-2018 31-10-2018 31.00 01-11-2018 09-12-2018 39.00 10-12-2018 09-01-2019 31.00 10-01-2019 09-02-2019 31.00 10-02-2019 09-03-2019 29.00 10-03-2019 31-03-2019 22.00 365.00 Weighted Avg. Rate Rate 8.15% 8.15% 8.25% 8.25% 8.25% 8.45% 8.50% 8.50% 8.55% 8.55% 8.55% 8.55% 8.39% Plus 150 Basis Points Total Weighted Avg. Rate Days X Rate 244.5% 252.7% 247.5% 255.8% 247.5% 253.5% 263.5% 331.5% 265.1% 265.1% 248.0% 188.1% 3062.55% 1.50% 9.89% 5.16.3 MSEDCL further submits that the amendment to the Regulation 29.11 of MYT Regulations 2015 provides for Interest on Security Deposit at MCLR plus 150 basis points. MSEDCL General Commercial Circular No. 271 for Rate of Interest on Consumer Security Deposit @ 9.65% per annum (MCLR plus 150 basis points) for FY 2018-19 is attached as Annexure 5 to this Petition. MSEDCL January 20 70 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 69: Interest on Working Capital for Wire business for FY 18-19 Rs. Crs Particulars Computation of Working Capital (Wire Business) O&M expenses for a month Maintenance Spares at 1% of Opening GFA 1.5 months of expected revenue from charges for use of Distribution wires Less: Amount held as SD from Distribution System Users Total Working Capital Requirement Rate of Interest (% p.a.) Interest on Working Capital Actual Working Capital Interest Interest on Security Deposit Rate of Interest (% p.a.) Interest on Security Deposit FY 2018-19 (Approved) FY 2018-19 (Normative) 397.81 481.07 374.41 466.39 1,206.11 1,252.12 46.02 (768.29) 1,316.70 9.45% 124.43 (754.35) 1,338.57 9.89% 132.39 66.22 13.94 21.88 9.65% 74.14 66.53 Deviation (23.40) (14.68) 7.96 (7.61) 5.16.4 MSEDCL requests the Hon’ble Commission to allow the Interest on Working capital along with the actual interest on security deposit for wire business as shown in above table. 5.16.5 MSEDCL further submits that Regulation 31.4 of the MERC (MYT Regulations 2015) provides for Interest on Working Capital for Retail Supply business of electricity. MSEDCL has calculated the interest on working capital at as 9.89% computed above and paid interest on security deposit at 9.65% i.e. MCLR plus 150 basis points. MSEDCL January 20 71 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 70: Interest on Working capital for Supply business for FY 18-19 Rs. Crs Particulars Computation of Working Capital (Supply Business) O&M expenses for a month Maintenance Spares at 1% of Opening GFA 1.5 months equivalent of the expected revenue from sale of electricity at the prevailing Tariff and including revenue from CSS and Additional Surcharge Less: Amount held as security deposit Less: One month equivalent of cost of Power Purchase, Transmission Charges and MSLDC Charges Total Working Capital Requirement Rate of Interest (% p.a.) Interest on Working Capital Actual Working Capital Interest Interest on Security Deposit Rate of Interest (% p.a.) Interest on Security Deposit FY 2018-19 (Approved) FY 2018-19 (Normative) 214.20 53.45 201.61 51.82 8,220.15 9,263.40 (6,914.61) (6,789.13) 125.48 (4,574.33) (5,086.32) (511.99) (3,001.14) 9.45% - (2,358.62) 9.89% 595.95 642.51 9.65% 667.26 598.75 Deviation (12.60) (1.63) 1,043.25 (68.51) 5.16.6 MSEDCL requests the Hon’ble Commission to allow the interest on working capital and actual security deposit for supply business as shown in above table. 5.17 Other Finance Charges for FY 2018-19 5.17.1 MSEDCL submits that it has incurred Other Finance Charges amounting to Rs. 26.11 Crores during the FY 2018-19. These are the fund raising charges i.e. Guarantee Charges, Finance Charges, Stamp Duty and Service Fee. Table 71: Other Finance Charges for FY 2018-19 Particulars Guarantee Charges Finance Charges Stamp Duty Service Fee (Fund-raising charges) Total Rs. Crs FY 2018-19 (Actual) 19.22 0.95 5.93 26.11 5.17.2 MSEDCL submits that these charges depend on the no. of loans, LC required to be given to the Power Suppliers, documentation for availing long term and working capital loans. These charges are, thus, beyond reasonable control of MSEDCL January 20 72 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition MSEDCL and hence required to be allowed on actual basis. Therefore, MSEDCL humbly requests the Hon’ble Commission to allow the Other Finance Charges as per the Audited Accounts. 5.18 Provision for Bad Debts for FY 2018-19 5.18.1 MSEDCL submits that bad debts are inseparable incidents of the business of electricity distribution and retail supply. 5.18.2 Regulation 73 and 82 of the MYT Regulations, 2015 specifies that a provision of bad and doubtful debt may be allowed up to 1.5% of the amount shown as trade receivables or receivables in the Audited Accounts of the distribution licensee duly allocated for wires and supply business respectively. 5.18.3 MSEDCL submits that Provision of bad debt generally depends on the nature of the business and the risk involved in the business. A business typically estimates the amount of bad debt based on historical experience. 5.18.4 MSEDCL has written off Rs. 4,019.34 Cr. towards Bad Debt in FY 2018-19. The regulatory opening balance provision for FY 2018-19 was Rs. 1,764.11 Cr. Thus after the write-off during FY 2018-19 the closing balance provision for Bad and Doubtful Debt becomes nil. 5.18.5 Category wise details of the actual bad debt written off is summarised below: Category LT AG LT PD consumers HT industrial HT PD consumers Consumers from Bhiwandi DF Area Total Total more than 15 years 0.00 489.44 0.01 0.00 169.20 658.65 Abhay Yojana Amnesty scheme 0.10 0.10 AG Interest prior to Mar 2013 3358.36 Total W/off (Rs. Crs) 0.46 0.01 1.77 3358.36 489.99 0.02 1.77 2.24 169.20 4019.34 3358.36 5.18.6 MSEDCL has computed the provision for bad and doubtful debts for FY 201819 as per the provisions of the MYT Regulations 2015 considering the MSEDCL January 20 73 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition receivables as per Audited Accounts as shown in following table: Table 72: Computation of provision for bad and doubtful debts for FY 2018-19 Rs. Crs FY 2018-19 (Approved) Particulars Opening Balance of Provision for bad and doubtful debts Receivables for the year Provision for bad & doubtful debts during the year Provision for bad & doubtful debts during the year Actual bad and doubtful debts written off Closing Balance of Provision for bad and doubtful debts Closing Balance as a % of receivables FY 2018-19 (Actual) Deviation 1,612.10 1,764.11 152.00 32,768.47 48,842.02 16,073.55 1.50% 1.50% 26.32 - 732.63 706.31 4,019.34 4,019.34 1,638.42 - 5.0% - (1,638.42) 5.18.7 Considering the allocation matrix provided by Hon’ble Commission in the MYT Regulations 2015, MSEDCL has worked out the provision for Bad Debt for wire and retail supply businesses respectively as shown above. Table 73: Provision for Bad debts for FY 2018-19 Rs. Crs Particulars Bad Debt Provision for Wires business Bad Debt Provision for Retail Supply business Bad Debt Provision FY 2018-19 (Approved) 2.63 23.69 26.32 FY 2018-19 (Actual) 73.26 659.37 732.63 Deviation 70.63 635.68 706.31 5.18.8 The total Bad Debt provision for FY 2018-19 works out to be Rs. 732.63 Cr. as against Rs. 26.32 Cr. MSEDCL humbly requests the Hon’ble Commission to approve the same. 5.19 Other Expenses for FY 2018-19 5.19.1 The other expenses of MSEDCL comprise of the expenditure on account of Non-Moving items written off, interest to suppliers/contractors, Incentive to distribution franchisee and other expenses viz. compensation for injuries to staff and outsiders. MSEDCL accordingly submits the other expenses as shown in the table below. MSEDCL January 20 74 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 74: Other Expenses FY 2018-19 Rs. Crs Particulars Compensation for injuries,death to staff Compensation for injuries,death to others Loss on obsolescence of fixed Assets Sundry debit balances written off Non Moving Items Interest to Suppliers/Contractors Others Other Expenses (incl. payable to DSL towards damages in terms of Arbitral Award dt. 18.06.2004) Sundry debit balances written off Other Expenses for previous years Expected Credit loss on other receivables TOTAL FY 2018-19 (Approved) 1.29 15.55 3.63 2.51 FY 2018-19 (Actual) 1.14 13.84 1.49 1.64 15.36 1.94 15.74 43.49 66.46 6.90 7.02 65.07 Deviation (0.15) (1.72) 1.49 1.64 11.73 1.94 13.23 6.90 7.02 (43.49) (1.39) 5.19.2 MSEDCL submits that the amount under the head “interest to suppliers/contractor” as per the Audited Accounts included Delayed Payment Charges / Surcharge payable to MSPGCL, MSETCL, IPPs & Wind Generators for FY 2018-19. MSEDCL has not claimed the same. 5.19.3 MSEDCL hereby requests the Hon’ble Commission to approve the Other Expenses as per actual expenses incurred by MSEDCL as given in the above table. 5.20 Contribution to Contingency Reserves for FY 2018-19 5.20.1 MSEDCL submits that it has invested Rs. 126.00 Cr. towards contribution to contingency reserves. Accordingly, the same is being claimed in the ARR of FY 2018- 19. Table 75: Contingency Reserve for FY 2018-19 Rs. Cr. Particulars Contribution to Contingency Reserves FY 2018-19 FY 2018-19 Deviation (Approved) (Actual) 126.00 126.00 5.20.2 MSEDCL further submits that the investment proof for the said amount is MSEDCL January 20 75 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition attached as Annexure 8 to this Petition. MSEDCL requests the Hon’ble Commission to allow the contribution to contingency reserves as submitted in above table. 5.21 Income Tax 5.21.1 During the FY 18-19, MSEDCL has paid Income Tax amounting to Rs. 215.08 Crs. MSEDCL has claimed the income tax as per the Audited Accounts. MSEDCL requests the Hon’ble Commission to allow the same. Table 76: Income Tax for FY 18-19 Particulars Income Tax Wire Business Income Tax Supply Business Total Income Tax Rs. Cr. FY 2018-19 FY 2018-19 Deviation (Approved) (Actual) 193.57 193.57 21.51 21.51 215.08 215.08 5.22 Incentives and Discounts for FY 2018-19 5.22.1 MSEDCL submits that during FY 2018-19, it has paid Rs. 287.38 Crs of incentives/discounts to the consumers for timely payment of bills as against Rs. 258.91 Crs approved by Hon’ble Commission in its MTR Order dated 12th September 2018. Table 77: Incentives/Discount for FY 18-19 Rs. Crs Particulars Incentives and Discount FY 2018-19 (Approved) 258.91 FY 2018-19 (Actual) 287.38 Deviation 28.47 5.22.2 MSEDCL requests the Hon’ble Commission to allow the incentives/discounts as per the Audited Accounts for FY 2018-19. 5.23 RLC Refund for FY 2018-19 5.23.1 MSEDCL during FY 2018-19 has made refund of Rs. 1.67 Crs of RLC. MSEDCL requests the Hon’ble Commission to allow the RLC Refund for FY 2018-19 as per Audited Accounts as shown below. MSEDCL also request the Hon’ble Commission to allow the RLC refund as and when it refunds the same MSEDCL January 20 76 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition to eligible consumers in future. Table 78: RLC Refund for FY 18-19 Rs. Crs Particulars RLC Refund FY 2018-19 (Approved) - FY 2018-19 Deviation (Actual) 1.67 1.67 5.24 Return on Equity for FY 2018-19 5.24.1 Regulation 28.2 of MERC (MYT) Regulations 2015, provides for Return on Equity (RoE) for Distribution Licensee for both Wire and Supply Business. In line with the approval of Rs. 927 Crs, MSEDCL has revised the normative opening equity from FY 2007-08 onwards in Chapter 3. Further, considering the funding pattern in Table 65, MSEDCL has considered the equity addition during the year. The return on equity capital is allocated in the ratio of Fixed Assets between the Wires and Retail Supply Business, i.e. 90% to Wires Business and 10% to Supply Business. Therefore, the capital expenditure, grants, equity and capitalisation is divided into wires and supply business in the ratio of 90:10. 5.24.2 MSEDCL submits that for FY 18-19, the amount of Rs.15.76 Crs was inadvertently considered in addition to asset twice. The same was corrected; however, instead of reduction to addition in asset, it is erroneously shown as retirement of asset. Since there is no retirement of assets, MSEDCL has not reduced the equity to that extent. 5.24.3 Considering the provisions of the MYT Regulations 2015, MSEDCL has computed the return on equity as shown in following tables. MSEDCL January 20 77 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 79: RoE for Wires Business for FY 18-19 Rs. Crs FY 2018-19 (Approved) Particulars Return on Equity (Wires Business) Regulatory Equity at the beginning of the year Equity portion of Assets Capitalisation Equity portion of Assets Decapitalised Regulatory Equity at the end of the year Return on Computation Return on Regulatory Equity at the beginning of the year - 15.5%*(1) Return on Normative Equity portion of Assett Capitalization - 15.5%*(2)/2 Interest on Equity portion above 30% equity Total Return on Regulatory Equity FY 2018-19 (Normative) 11,066.00 633.43 11,699.43 10,224.25 328.98 10,553.23 1,715.23 1,584.76 49.09 25.50 1,764.32 1,610.25 Deviation (841.75) (304.44) (1,146.20) (130.47) (23.59) (154.07) Table 80: RoE for Retail Supply Business for FY 18-19 Rs. Crs Particulars FY 2018-19 (Approved) FY 2018-19 (Normative) 1,229 70 1,299 1,136 37 1,173 (92.52) (33.83) (126.35) 215.08 198.88 (16.19) 6.16 3.20 (2.96) 221.23 202.08 (19.15) Return on Equity (Supply Business) Regulatory Equity at the beginning of the year Equity portion of Assets Capitalisation Equity portion of Assets Decapitalised Regulatory Equity at the end of the year Return on Computation Return on Regulatory Equity at the beginning of the year - 17.5%*(1) Return on Normative Equity portion of Assett Capitalization - 17.5%*(2)/2 Interest on Equity portion above 30% @11.37%p.a. Total Return on Regulatory Equity Deviation 5.24.4 MSEDCL requests the Hon’ble Commission to allow the RoE as computed above. 5.25 Sharing of Efficiency Gains & Losses for FY 2018-19 5.25.1 Regulations 9, 10 and 11 of the MYT Regulations, 2015 specify the controllable and uncontrollable parameters, mechanism of pass-through of gains and losses on account of uncontrollable parameters, and the mechanism for their MSEDCL January 20 78 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition sharing on account of controllable parameters as follows: “11.1 The approved aggregate gain to the Generating Company or Licensee or MSLDC on account of controllable factors shall be dealt with in the following manner:— (a) Two-third of the amount of such gain shall be passed on as a rebate in Tariff over such period as may be stipulated in the Order of the Commission under Regulation 8.4; (b) The balance amount of such gain shall be retained by the Generating Company or Licensee or MSLDC. 11.2 The approved aggregate loss to the Generating Company or Licensee or MSLDC on account of controllable factors shall be dealt with in the following manner:— (a) One-third of the amount of such loss may be passed on as an additional charge in Tariff over such period as may be stipulated in the Order of the Commission under Regulation 8.4; (b) The balance amount of such loss shall be absorbed by the Generating Company or Licensee or MSLDC.” 5.25.2 Parameters such as O&M Expenses, Interest on Working Capital for which specific norms have been specified in the MYT Regulations, have been calculated on normative basis. 5.25.3 As these parameters need to be treated as controllable under the MYT Regulations 2015, any variation in the actual expenses as against the permissible normative levels has been shared between MSEDCL and consumers. 5.25.4 O&M Expenses: The actual O&M Expenses as per the Audited Accounts for FY 2018- 19 are lower than that of allowed on normative basis. 5.25.5 Interest on Working Capital: The actual IoWC expense as per the Audited Accounts for FY 2018-19 is higher than that allowed on normative basis. 5.25.6 Distribution Loss: The actual distribution loss (excluding EHV Sales) for FY 2018-19 is lower than that approved in the MTR Order. MSEDCL January 20 79 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 5.25.7 The summary of sharing of efficiency gains/(loss) on account of O&M Expenses and IoWC is shown in the Table below: Table 81: O&M Expenses & Interest on Working Capital for FY 18-19 Particulars O&M Expenses Interest on Working Capital Normative 6,912.20 132.39 Rs. Crs 2/3 of Net 1/3 of Efficiency Efficiency Entitlement Gains/Losses gains/Losses after sharing 511.19 340.79 170.40 6,571.41 (529.78) (353.18) (176.59) 308.98 Gains/ (Loss) Actual 6,401.01 662.17 5.25.8 MSEDCL submits that it has computed the sharing of efficiency gain/ loss considering 14.76% as approved distribution loss target (Excluding EHV Sales) against the actual distribution losses (Excluding EHV Sales) 5.25.9 The summary of sharing of efficiency gains/(loss) on account of efficiency in Distribution Losses is shown in the Table below: Table 82: Sharing of Gains/Losses by MSEDCL & Consumers for FY 18-19 Particulars Actual Distribution Loss MYT approved Loss Sales Excl. EHV sales in MUs EHV Sales in MUs Total Sales in MUs IntraSTS loss (Proposed) Power Requirement at Ex-Bus Periphery (Actual) in MUs Power Requirement at Ex-Bus Periphery (Normative) in MUs Additional/ (lower) Power purchase due to higher distribution loss in MUs Marginal Variable Cost of Power Purchase Rs./kWh Additional/(Lower) Power purchase Cost due to lower distribution loss Efficiency gain/(loss) to be retained by MSEDCL Efficiency gain/(loss) to be borne by the consumers Amount (Rs. Crs) 14.70% 14.76% 99,991 9,614 1,09,605 3.62% 1,31,602 1,31,688 (85.6) 4.17 (35.74) 23.83 11.91 5.25.10 The total impact of sharing of gains and losses of various components have been summarized in the Table below: MSEDCL January 20 80 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 83: Impact of Sharing of Gains/Losses for FY 18-19 Particulars O&M Expenses IoWC Impact of Gain in Distribution Loss passed on Consumers Total Impact of Sharing of Gains/(Losses) Amount Rs. Crs (340.79) 176.59 11.91 (152.29) 5.25.11 MSEDCL requests the Hon’ble Commission to allow the sharing of gains and losses as submitted in above table. 5.26 Impact of payment to MPECS for FY 2018-19 5.26.1 Hon’ble Commission in the MYT Order dated 3rd November 2016 has approved following amounts towards payment to MPECS. Financial Year FY 17-18 FY 18-19 FY 19-20 Amount in Rs. Cr. 46.20 43.18 40.17 5.26.2 Hon’ble Commission in the MTR Order has approved the amount towards payment to MPECS as the same was allowed under the MYT Order. The Hon’ble Commission in the MTR Order also ruled that it shall consider the actual amount towards this head at the time of truing up of FY 2018-19. 5.26.3 Accordingly, MSEDCL has claimed Rs. 43.43 Cr. towards the actual payments to MPECS for FY 2018-19. 5.27 Past Period Adjustment by Commission for FY 2018-19 5.27.1 In the MTR Petition, MSEDCL had submitted that in the MYT Order dated 3rd November 2016, the Hon’ble Commission had considered the Net Impact of Past Period and MSPGCL MYT Order in Case No. 46 of 2016 while approving the revenue for MSEDCL from revised tariffs for the third Control Period. MSEDCL had accordingly considered the impact of the same in the respective year during the MTR Process. MSEDCL January 20 81 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 5.27.2 Hon’ble Commission had approved the past period adjustments of Rs. (1,031.50) Crs in MTR Order dated 12th September 2018 as approved in the MYT Order. MSEDCL has considered the same for FY 2018-19. 5.28 Revenue Gap Recovery Allowed for FY 2018-19 5.28.1 MSEDCL submits that in the MTR Order, Hon’ble Commission has allowed revenue recovery as shown in the following table. MSEDCL has considered the same. Table 84: Revenue Recovery allowed in MTR for FY 2018-19 Particulars ARR approved by the Hon'ble Commission Approved Revenue at existing tariff Approved Revenue Gap Formula A B C = A-B Rs. Crs FY 2018-19 66,556.98 65,638.75 918.23 Projected Revenue at appproved tariff Additional Recovery from approved tariff Previous Revenue Gap recovery allowed after adjustment of current year Revenue Gap D E = D-B 68,813.54 3,174.79 F = E-C 2,256.56 5.29 Aggregate Revenue Requirement for FY 2018-19 5.29.1 Considering the parameters discussed above, the Aggregate Revenue Requirement (ARR) of MSEDCL for Wires Business for the FY 2018 -19 is as follows: MSEDCL January 20 82 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 85: ARR for Distribution Wires for FY 18-19 Rs. Crs Particulars Operation & Maintenance Expenses Depreciation Interest on Loan Capital Interest on Normative Working Capital Interest on deposit from Consumers and Distribution System Users Other Finance Charges Provision for bad and doubtful debts Contribution to contingency reserves Income Tax Return on Equity Capital Aggregate Revenue Requirement FY 2018-19 (Approved) 4,773.70 2,096.54 1,433.44 124.43 FY 2018-19 (Actual) 4,492.93 2,217.60 1,215.23 132.39 74.14 66.53 (7.61) 2.63 1,787.00 10,291.88 2.61 73.26 12.60 193.57 1,610.25 10,016.97 2.61 70.63 12.60 193.57 (176.75) (274.91) Deviation (280.77) 121.06 (218.22) 7.96 5.29.2 Considering the parameters discussed above, the Aggregate Revenue Requirement (ARR) of MSEDCL for Supply Business for the FY 2018 -19 is as follows: Table 86: ARR for Supply Business for FY 18-19 Particulars Power Purchase Expenses Operation & Maintenance Expenses Depreciation Expenses Interest on Loan Capital Interest on Normative Working Capital Interest on Consumers Security Deposit Other Finance Charges Provision for bad and doubtful debts Other Expenses Income Tax Intra-State Transmission Charges MSLDC charge Incentives/Discounts Contribution to Contingency Reserves Return on Equity Capital RLC refund Effect of sharing of gains/losses Past Period Adjustment by Commission Revenue Gap Recovery Allowed Impact of payment to MPECS Aggregate Revenue Requirement for Supply Business MSEDCL January 20 Rs. Crs FY 2018-19 FY 2018-19 Deviation (Approved) (Actual) 50,589.49 56,260.34 5,670.85 2,570.70 2,419.27 (151.43) 232.94 246.40 13.46 159.28 135.03 (24.25) 667.27 598.75 (68.52) 23.49 23.49 23.70 659.37 635.67 66.47 65.07 (1.40) 21.51 21.51 4,302.54 4,775.50 472.96 258.91 287.38 28.47 113.40 113.40 198.60 202.08 3.48 1.67 1.67 (152.29) (152.29) (1,031.50) (1,031.50) 2,256.56 2,256.56 43.18 43.43 0.25 60,338.15 66,925.47 6,587.32 83 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 5.30 Revenue from sale of electricity for FY 2018-19 5.30.1 MSEDCL has considered the revenue for FY 2018-19 based on the Audited Accounts as shown in following table. Table 87: Revenue from Sale of Power for FY 18-19 Rs. Crs Particulars Revenue from Sale of Power FY 2018-19 (Approved) 68,813.54 FY 2018-19 (Actual) 72,591.72 Deviation 3,778.18 5.30.2 The Annual Accounts of MSEDCL shows the revenue from operations which includes various revenue items. However, being not part of revenue from sale of power at retail tariff and as per practice in vogue, MSEDCL has shown certain items of revenue separately. 5.30.3 MSEDCL humbly requests to the Hon’ble Commission to approve the categorywise revenue from sale of power as shown in above table. 5.31 Non-Tariff Income for FY 2018-19 5.31.1 MSEDCL has certain sources of non-tariff income viz. interest on arrears of consumers, delayed payment charges, interest on staff loans and advances, sale of scrap, interest on investment etc. Table 88: Non-Tariff Income for FY 18-19 Rs. Crs Particulars Rents of land or buildings Sale of Scrap Income from investments Income from sale of tender documents Prompt payment discount from REC/PFC Other/Miscellaneous receipts Revenue from subsidy & grant Non Tariff Income FY 2018-19 (Approved) 1.21 53.42 16.43 6.56 15.45 958.12 1,051.19 FY 2018-19 (Actual) 0.98 80.21 17.61 8.49 11.58 405.62 84.85 609.35 Deviation (0.23) 26.79 1.19 1.94 (3.88) (552.50) (441.84) 5.31.2 MSEDCL has a Non-Tariff Income of Rs. 609.35 Crs as against Rs. 1,051.19 Crs as approved by the Hon’ble Commission.. MSEDCL January 20 84 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 5.31.3 As provided in the Regulation 36.3 of the MYT Regulations 2015, delayed Payment Charge and Interest on Delayed Payment is not considered under Non-Tariff Income. 5.31.4 MSEDCL has not considered income from grants and contribution reported under non-tariff income, as the treatment (i.e. excluded while calculating depreciation) to the same is already considered while computing the depreciation for the FY 2018- 19. 5.32 Income from Open Access Charges for FY2018-19 5.32.1 MSEDCL has reported an income of Rs. 387.11 Cr. from Open Access Charges as against Rs. 641.33 Crs as approved by the Hon’ble Commission. Table 89: Income from Open Access Charges for FY 18-19 FY 2018-19 (Approved) 641.33 Particulars Income from Open Access Charges Rs. Crs FY 2018-19 Deviation (Actual) 387.11 (254.22) 5.32.2 Details of Income from Open Access Charges are summarised below: Particulars Energy Charges Open Access F.C.A Charges Open Access Penal Charges Open Access Additional Charges Open Access Adj to past billing Open Access PF Penalty Open Access Cross Subsidy Surcharge Open Access Wheeling Charge Open Access Transmission Charge Open Access Operating Charges Open Access Threshold penalty Open Access Total Income from Open Access Charges Amount Rs. Crs 25.25 -0.56 0.03 0.41 -39.18 0.00 166.25 37.47 182.33 14.90 0.19 387.11 5.32.3 Hence, MSEDCL humbly requests the Hon’ble Commission to true up the Income from Open Access Charges as per the Audited Accounts. MSEDCL January 20 85 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 5.33 Income from Trading of Surplus Power for FY 2018-19 5.33.1 MSEDCL has reported an Income from Trading of Surplus Power of Rs. 408.82 Crs. Details of surplus power traded is provided in following table. Table 90: Income from Trading of Surplus Power for FY 18-19 Rs. Crs Particulars Income from Trading of Surplus Power FY 2018-19 (Approved) - FY 2018-19 (Actual) 408.82 Deviation 408.82 5.33.2 MSEDCL humbly requests to the Hon’ble Commission to allow the income from sale of surplus power as shown in above table. 5.34 Income from Wheeling Charges for FY 2018-19 5.34.1 MSEDCL has reported an income from Wheeling Charges of Rs. 1.79 Crs as against Rs. 1.53 Crs as approved by the Hon’ble Commission for FY18-19. Table 91: Income from Wheeling Charges for FY 18-19 Rs. Crs Particulars Income from Wheeling Charges FY 2018-19 (Approved) 1.53 FY 2018-19 (Actual) 1.79 Deviation 0.26 5.34.2 Hence, MSEDCL humbly requests to the Hon’ble Commission to true up the Income from Wheeling Charges as per the Audited Accounts as shown in the above table. 5.35 Income from Additional Surcharge for FY 2018-19 5.35.1 MSEDCL has reported an income from Additional Surcharge of Rs. 108.44 Crs. The Hon’ble Commission in the last MTR Order dated 12th September 2018, had approved an income of Rs. 122.44 Cr. from additional surcharge for FY1819. MSEDCL January 20 86 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 92: Income from Additional Surcharge for FY 18-19 Rs. Crs Particulars Income from Additional Surcharge FY 2018-19 FY 2018-19 Deviation (Approved) (Actual) 122.44 108.44 (14.00) 5.35.2 MSEDCL humbly requests to the Hon’ble Commission to true up the Income from Additional Surcharge as per the Audited Accounts as shown in the above table. 5.36 Revenue Gap/(Surplus) for FY 2018-19 5.36.1 Based on the above analysis, the summary of ARR (after sharing of efficiency gains &losses) for the Wires Business and Supply Business, as per Audited Account and as approved by the Hon’ble Commission, for FY 2018-19 is presented in the Table below. MSEDCL January 20 87 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 93: ARR for Wires & Supply Business for the FY 2018-19 Rs. Crs Particulars Power Purchase Expenses Operation & Maintenance Expenses Depreciation Expenses Interest on Loan Capital Interest on Normative Working Capital Interest on Consumers Security Deposit Other Finance Charges Provision for bad and doubtful debts Other Expenses Income Tax Intra-State Transmission Charges MSLDC charge Incentives/Discounts Contribution to Contingency Reserves Return on Equity Capital RLC refund Revenue Gap Allowed Effect of sharing of gains/losses Past Period Adjustment by Commission Impact of payment to MPECS in future years Aggregate Revenue Requirement Revenue from Sale of Power Non-Tariff Income Income from Open Access Charges Income from Trading of Surplus Power Income from Wheeling Charges Income from Additional Surcharge Total Revenue Revenue Gap/(Surplus) FY 2018-19 (Approved) 50,589.49 7,344.40 2,329.48 1,592.72 124.43 741.41 26.33 66.47 4,302.54 258.91 1,985.60 2,256.56 (1,031.50) 43.18 70,630.03 68,813.54 1,051.19 641.33 1.53 122.44 70,630.02 FY 2018-19 (Actual) 56,260.34 6,912.20 2,464.00 1,350.25 132.39 665.28 26.11 732.63 65.07 215.08 4,775.50 287.38 126.00 1,812.34 1.67 2,256.56 (152.29) (1,031.50) 43.43 76,942.44 72,591.72 609.35 387.11 408.82 1.79 108.44 74,107.23 2,835.21 Deviation 5,670.85 (432.20) 134.52 (242.47) 7.96 (76.13) 26.11 706.30 (1.40) 215.08 472.96 28.47 126.00 (173.26) 1.67 (152.29) 0.25 6,312.41 3,778.18 (441.84) (254.22) 408.82 0.26 (14.00) 3,477.21 2,835.20 5.36.2 The Hon’ble Commission in its MTR Order dated 12th September 2018 had approved Aggregate Revenue Requirement of Rs. 70,630.03 Crs for FY 201819 against which MSEDCL has computed Rs. 76,942.44 Crs. MSEDCL, in this petition submits the actual revenue (incl. other components of revenue) of Rs. 74,107.23 Crs with a deviation of Rs. 3,477.21 Crs. Considering the impact of revenue and other income, the truing up requirement works out to be Rs. 2,835.20 Cr. The same has been summarised in above table. MSEDCL requests the Hon’ble Commission to allow the true up requirement as submitted. MSEDCL January 20 88 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 6 6.1 PROVISIONAL TRUE UP OF FY 2019-20 Preamble 6.1.1 This section outlines the performance of MSEDCL for FY 2019-20 in line with the provisions of the MYT Regulations 2015. MSEDCL hereby submits detailed Provisional Truing-up for FY 2019-20 comparing the estimated expenditures for FY 2019-20 based on the latest available information vis-à-vis the forecast approved by the Hon’ble Commission vide MTR Order dated 12th September 2018. 6.2 Principles of Truing-up for FY 2019-20 6.2.1 MSEDCL submits that the MERC (Multi Year Tariff) Regulations, 2019 specifies that Multi Year Tariff Petition shall comprise of Provisional Truing up for FY 2019-20 which has to be carried out based on the provisions of the MERC (Multi Year Tariff) Regulations, 2015. 6.2.2 In line with the provisions of MERC (Multi Year Tariff) Regulations, 2015, MSEDCL has computed this Provisional Truing- up for FY 2019-20. 6.2.3 Accordingly, based on the latest available information, the estimated Aggregate Revenue Requirement, revenue and gap for FY 2019-20 are discussed in detail in the following paragraphs. 6.3 Category Wise Sales for FY 2019-20 6.3.1 MSEDCL submits that it has considered the actual sales till September 2019 and estimated the sales for remaining six months of FY 2019-20 considering historical trend. Details of month wise sales are given in Form 1 of the Regulatory Formats. 6.3.2 MSEDCL submits the provisional sales for the FY 2019-20 excluding the sales in the areas of the Distribution Franchisee. MSEDCL January 20 89 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 94: Category wise Sales for FY 2019-20 Category Residential Commercial HT-Industrial LT-Industrial PWW Street Light Agriculture Public Services Railways Others MSEDCL Excl. DF FY 2019-20 (Approved) 20,336.63 7,963.08 29,207.84 7,232.08 2,427.77 2,013.76 31,943.14 1,515.68 59.25 740.91 1,03,440.14 Sales (MUs) FY 2019-20 (Estimatedl) 20,747.29 7,745.71 30,903.47 7,004.10 2,348.25 1,817.36 30,491.51 1,472.76 64.23 698.57 1,03,293.22 Deviation 410.66 (217.37) 1,695.63 (227.98) (79.52) (196.40) (1,451.63) (42.92) 4.98 (42.34) -146.92 6.3.3 MSEDCL submits that in this petition, LT Agriculture sales for FY 2019-20 have been estimated based on the half yearly sales plus the sales for remaining six months keeping in view the water availability for irrigation in the State. The actual sales to LT Agriculture consumers will depend upon Rabi crop cultivation and the same shall be updated to the Hon’ble Commission during the months of February/ March 2020. 6.4 Distribution Losses for FY 2019-20 6.4.1 In MYT Order dated November 2016, Hon’ble Commission had approved distribution loss of 13.26% (Excl. EHV). MSEDCL has considered the same targeted loss levels for estimation as shown in following table. Table 95: Distribution Losses FY2019-20 Particulars Distribution Loss FY 2019-20 FY 2019-20 (Approved) (Estimated) 13.26% 13.26% Deviation - 6.4.2 MSEDCL requests the Hon’ble Commission to approve the Distribution Losses for FY 19-20. 6.5 Energy Balance for FY 2019-20 6.5.1 The quantum of sales in MUs shown in the above para represents the sales of MSEDCL excluding the sales in the area served by Distribution Franchisees in MSEDCL January 20 90 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition the year FY 2019-20. Further, while calculating energy balance of MSEDCL as a whole, the sale to the consumers of the Distribution Franchisee area has also been considered. Since the Distribution Franchisee is an agent to MSEDCL as per the Franchisee Agreement, MSEDCL has to consider the loss within the Franchisee area for Energy balance. Therefore, estimated energy balance for FY 2019-20 is computed as below: Table 96: Energy Sales for FY 2019-20 MUs FY 2019-20 (Approved) Particulars Energy Sales by MSEDCL for FY 2019-20 incl. Offset Solar Units Add: Category wise sales in DF area Add: OA Sales (Conventional) Add: Renewable OA Total Energy Sales FY 2019-20 (Estimated) Deviation 1,03,440.14 1,03,367.11 (73.03) 4,929.10 4,773.83 748.60 1,13,891.66 4,709.97 3,983.40 859.40 1,12,919.88 (219.13) (790.43) 110.80 (971.78) 6.5.2 Considering the principles discussed in energy balance for FY 17-18 and FY 18-19, MSEDCL has computed the energy balance for FY 19-20 as summarised in following table. MSEDCL January 20 91 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 97: Energy Requirement and Energy Balance FY 2019-20 Sr. No. 1 3 4 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Particulars LT Sales (Including D.F) HT Sales excluding EHV level sales (Including D.F) HT/LTIP Credit Sales and HT/LT Offset Export Solar units Total Sales including D.F (Excluding EHV Sales) OA Sales (Renewables) OA Sales (Conventional) Retail Energy Sale to Consumers (Excluding EHV Sales) Total Power Purchase Power Purchase Quantum from Intra-State sources Power Purchase Quantum from Inter-State sources Inter-State Losses Power Purchase Quantum from Inter-State sources at MS Periphery Add: FBSM Power Quantum handled at Maharashtra Periphery Infirm Non-PPA Wind Power Input for OA Consumption Total Power Purchase Quantum Handled Surplus Power Traded Energy Requirement at G<>T Periphery Intra-State Transmission Loss Intra-State Transmission Loss Net Energy requirement at T<>D Periphery EHV Sales Net Energy Available for Sale at 33kV Energy injected and drawn at 33kV Total Energy Available for Sale at 33kV (Metered Energy at EHV and 33 kV Input) Distribution Loss (Excl. EHV Sales) Distribution Loss (Excl. EHV Sales) Calculation UoM a b c d=a+b+c e f A=d+e+f B=g+h g h i j=h*(1-i) k l=g+j+k m n=f/(1-6%) o=l+m+n-w p q=o-p r s=q*r t=q-s u v=t-u w MU MU MU MU MU MU MU MU MU MU % MU C=v+w D=C-A E=D/C FY 2019-20 MTR Order Estimated MU MU MU MU MU MU % MU MU MU MU MU 72,166 27,654 99,820 749 4,774 1,05,342 1,30,634 89,295 41,339 3.14% 40,041 1,29,336 5,079 1,33,926 1,33,926 3.30% 4,420 1,29,507 8,549 1,20,957 488 69,983 28,195 74 98,252 859 3,983 1,03,095 1,28,767 88,780 39,986 3.07% 38,759 1,27,539 914.25 4,238 1,32,118 767 1,31,351 2.47% 3,245 1,28,106 9,825 1,18,281 573 MU 1,21,445 1,18,854 MU % 16,103 13.26% 15,759 13.26% 6.5.3 MSEDCL requests the Hon’ble Commission to approve the Energy Balance as per the above table. 6.6 Power Purchase Expenses for FY 2019-20 6.6.1 MSEDCL submits that it has considered the power purchase till September 2019 (provisional) and projected power purchase for remaining 6 months of FY 2019-20 considering sales projection with estimated Distribution Losses. MSEDCL January 20 92 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 98: Source wise estimated Power Purchase for FY 2019-20 Source MSPGCL NTPC NPCIL SSP Pench Dodson JSW CGPL Adani Power EMCO Power Rattan India Renewable Traders Other Adjsutments PGCIL Charges Intra State Purchase Total Power Purchase PP Quantum (MUs) PP Cost (Rs. Cost) PP Cost (Rs. /Unit) Approved Approved in Approved in in MTR Estimated Deviation Estimated Deviation Estimated Deviation MTR Order MTR Order Order 47,826.72 47,840.33 13.61 18,769.37 20,238.13 1,468.77 3.92 4.23 0.31 27,634.48 26,638.65 (995.83) 9,182.60 10,452.18 1,269.57 3.32 3.92 0.60 5,485.23 5,612.76 127.54 1,474.47 1,615.18 140.71 2.69 2.88 0.19 1,213.26 1,043.46 (169.80) 248.72 213.91 (34.81) 2.05 2.05 (0.00) 136.87 91.58 (45.29) 28.06 18.77 (9.28) 2.05 2.05 (0.00) 116.04 34.68 (81.36) 16.33 14.67 (1.66) 1.41 4.23 2.82 2,060.73 2,120.32 59.59 660.58 725.07 64.50 3.21 3.42 0.21 5,495.27 4,696.92 (798.35) 1,375.53 1,350.07 (25.46) 2.50 2.87 0.37 19,655.43 19,710.82 55.38 6,783.31 7,496.65 713.33 3.45 3.80 0.35 1,373.82 1,331.67 (42.15) 494.19 569.08 74.89 3.60 4.27 0.68 3,356.11 3,356.11 982.87 2,122.00 1,139.13 6.32 6.32 19,635.91 15,718.00 (3,917.91) 9,794.24 7,761.79 (2,032.46) 4.99 4.94 (0.05) 571.42 571.42 224.84 224.84 3.93 3.93 0.01 0.01 2,928.00 3,501.12 573.12 1.98 1.98 1,30,634 1,28,766.72 (1,867) 52,738 56,305 3,567 4.04 4.37 0.34 6.6.2 MSEDCL requests the Hon’ble Commission to approve the power purchase as submitted in the above table. 6.7 Transmission Charges for FY 2019-20 6.7.1 The Intra State transmission charges are taken actual upto September 2019 and estimated for remaining 6 months of FY 2019-20 as per the InSTS Order dated 12th September 2018 in Case No. 265 of 2018. 6.7.2 Based on the above submission, the comparison of the approved and the estimated transmission charges for FY 2019-20 is as shown below: Table 99: Transmission Charges paid to Transmission Licensee for FY 2019-20 Rs. Crs Particulars Intra-State Transmission Charges FY 2019-20 (Approved) 4,863.74 FY 2019-20 (Estimated) 4,867.55 Deviation 3.81 6.7.3 MSEDCL requests the Hon’ble Commission to approve the intra state transmission charges as submitted in the above table. 6.8 Fixed Costs for FY 2019-20 6.8.1 Based on the Capital Cost and the consequent Capitalized Expenditure, Equity Component and Normative Debt, the fixed cost of MSEDCL for FY 2019-20 MSEDCL January 20 93 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition (excluding fixed components of PP cost) has been determined in accordance with the provisions of MYT Regulations 2015. As outlined under the regulations, the fixed cost for MSEDCL has been determined under the following major heads long with other items of expenditure: Operation and Maintenance Expenses Depreciation Interest and Finance Charges Interest on Working Capital Income Tax Return on Equity 6.8.2 Net Annual Revenue Requirement has been computed after netting off Expenses capitalized. 6.8.3 Head wise comparison has been made between the values approved by the Hon’ble Commission vide MTR Order dated 12th September 2018 in Case no. 195 of 2017 and the estimated for FY 2019-20. 6.9 Normative Operation & Maintenance Expenses for FY 2019-20 6.9.1 MSEDCL submits that Regulation 72 and Regulation 81 of the MERC (MYT) (1st Amendment) Regulations 2017 provides for the O&M Expenses Norm for Distribution Wires Business and Retail Supply of electricity respectively. 6.9.2 Considering the escalation factor same as that computed for FY 2018-19 at Table 60 and base year O&M Expenses for FY 2015-16 (net entitlement after sharing of gains/(losses), MSEDCL has computed the O&M Expenses for Wires Business and Retail Supply of electricity for FY 2019-20 as shown in following table. Table 100: O&M Expenses for FY 2019-20 Particulars O&M Expenditure for Wires business O&M Expenditure for Retail Supply business Operation and Maintenance Expenses MSEDCL Rs. Crs FY 2019-20 FY 2019-20 Deviation (Approved) (Normative) 5,015.05 4,620.17 (394.88) 2,700.41 2,487.79 (212.63) 7,715.46 7,107.96 (607.50) January 20 94 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 6.9.3 MSEDCL requests the Hon’ble Commission to allow the O&M Expenses as computed in above table. 6.10 Capitalisation for FY 2019-20 6.10.1 MSEDCL has estimated capitalization of Rs. 6,469.03 Cr. for FY 2019-20 based on the available information as on September 2019. Following table shows the estimated capitalization in FY 2019-20 is shown in the table below. Table 101: Capitalisation for FY 2019-20 Rs. Crs Particulars Total Capitalisation FY 2019-20 (Approved) 2,546.90 FY 2019-20 (Estimated) 6,469.03 Deviation 3,922.13 6.10.2 MSEDCL submits that the Hon’ble Commission had approved the capitalization based on the projections provided in the MTR Petition. Subsequently, various new schemes started, also additional information for few schemes is now available. 6.10.3 The major reasons for deviations are as follows: In case of DDUGJY, the projections in previous petition for FY 2017-18 & 2018-19 were Rs. 272.07 Cr & 761.60 Cr. But actual capitalization for these 2 yrs is total Rs. 450.44 Cr. The expenditure incurred in previous years is expected to be capitalized in FY 2019-20 and hence the projections for FY 2019-20 are revised to Rs. 824 Crore as compared to previous projection of Rs. 636.68 Cr. IPDS Scheme:- Here also the gap in projection and actual capitalization for FY 2017-18 and 2018-19 is Rs. 682.15 Cr. and hence, the projections are increased to Rs. 962 Crore. (Previous is Rs. 722.05 Cr.) Due to timely completion of projects in FY 2017-18 & 2018-19, DPDC funding and expenditure is expected to increase by another Rs. 200 Cr. Hence the projections are revised at Rs. 665.18 Cr (previous projection is Rs. 457.98 Cr.) Some new schemes were introduced during 2018-19 and some are introduced during 2019-20. The projections for these schemes were not MSEDCL January 20 95 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition considered in previous MTR petition. But the same is considered in current Petition based on actual progress and deadlines for work completion. New schemes introduced in FY 2017-18 & 2018-19 are i. Shet Tale ii. Saubhagya iii. HVDS iv. MSVVY New Schemes introduced in FY 2019-20 are i. High Loss Feeder ii. System Strengthening Work iii. NCRMP • • 6.10.4 The scheme wise difference is as follows: Previous Projections in MTR Current Projections in MYT Difference (Rs. Crs) DDUGJY 636.68 824.00 187.32 IPDS 722.05 962.00 239.95 DPDC 457.98 665.18 207.20 Shet Tale 0.00 156.06 156.06 Saubhagya 0.00 430.65 430.65 HVDS 0.00 1,159.78 1159.78 MSVVY 0.00 25.50 25.50 0.00 75.00 75.00 System strengthening 0.00 125.00 125.00 NCRMP 0.00 45.00 45.00 Name of Scheme High Feeder Loss Total Diff 2651.46 Based on the available information, the capitalisation for FY 2019-20 is. Rs.1,615 Crore. 6.10.5 Scheme wise details of the capitalization are provided in the Regulatory MSEDCL January 20 96 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Formats. However, for other assets such as land and land rights, buildings etc., MSEDCL has estimated capitalisation of Rs. 100.00 Crs. MSEDCL requests the Hon’ble Commission to approve the capitalisation as estimated above. Table 102: Capitalisation for FY 2019-20 Sr. No. 1 2 3 Amount (Rs. Crs) 6,469.03 100.00 6,569.03 Particulars Capitalisation as per Form 8/Form 4 Estimated Other Assets Total 6.10.6 Hon’ble Commission in its previous Orders has allowed the capitalization towards schemes not forming part of any specific scheme. MSEDCL further submits that Hon’ble Commission has accordingly revised the GFA to that extent as well. Therefore, MSEDCL requests the Hon’ble Commission to approve the capitalization as submitted above and compute the GFA accordingly. 6.11 Depreciation for FY 2019-20 6.11.1 Considering the Opening GFA for FY 2019-20 without grants and consumer contribution, MSEDCL has estimated the depreciation for FY 2019-20 at weighted average rate for FY 18-19 as summarised in following table. Table 103: Depreciation for FY 2019-20 Particulars Approved (Rs. Crs) Net Opening GFA (Regulatory*) Depreciation 2,411.41 * Excluding consumer contribution and grants Estimated (Rs. Crs) 52,393.41 2,594.37 6.11.2 MSEDCL requests the Hon’ble Commission to allow the Depreciation as computed in above table. 6.12 Funding Pattern for FY 2019-20 6.12.1 As per the Regulation 26.1 of MERC (MYT), 2015, the debt-equity ratio as on the date of commercial operation shall be 70:30 of the amount of capital cost approved by the Commission. The said Regulation also provides that if the equity actually deployed is more than 30% of the capital cost, equity in excess MSEDCL January 20 97 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition of 30% shall be treated as normative loan for the Generating Company or Licensee or MSLDC for determination of Tariff. 6.12.2 The funding pattern for FY 2019-20 for the capitalization estimated by MSEDCL, in proportion to the funding pattern of capital expenditure, is presented in the following table: Table 104: Funding Pattern of Capitalisation for FY 2019-20 Particular Total Capitalisation Less: Consumer Contribution Less: Grants Balance to be funded Equity Debt Amount Funding (Rs. Crs) Mix (%) 6,469.03 100.77 3,186.35 3,181.92 328.16 10.31% 2,853.76 89.69% 6.12.3 MSEDCL requests the Hon’ble Commission to allow the funding pattern as submitted above. 6.13 Interest Expenses for FY 2019-20 6.13.1 MSEDCL has computed the interest expenses on normative basis linked to the normative opening loan and normative loan addition during the year. Further, MSEDCL has considered the weighted average interest rate of actual loan portfolio of FY 2018-19 as shown in Table 66. 6.13.2 Regulation 29.3 of the MERC (MYT) Regulations 2015 provides for repayment equal to depreciation. The relevant extract is reproduced below: 29.3 The repayment during each year of the Control Period from FY 2016-17 to FY 2019-20 shall be deemed to be equal to the depreciation allowed for that year. 6.13.3 Considering the normative opening loan, normative loan addition during the year and loan repayment equal to depreciation and the weighted average interest rate of actual loan portfolio for FY 2018-19, MSEDCL has computed the interest expenses on normative basis as summarized in table below: MSEDCL January 20 98 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 105: Interest Expenses for FY 2019-20 Rs. Crs Particulars Normative Outstanding Loan at beginning of the year Less: Reduction of Normative Loan due to retirement of assets Loan Drawal Loan Repayment Normative Balance Outstanding at the end of the year Average Balance of Net Normative Loan Interest Rate Interest Expenses FY 2019-20 (Approved) 13,685.75 920.09 2,411.30 12,194.54 12,940.14 11.37% 1,471.02 FY 2019-20 (Estimated) 13,004.36 2,853.76 2,594.37 13,263.75 13,134.05 10.28% 1,349.54 Deviation (681.39) 1,933.66 183.06 1,069.21 193.91 (121.48) 6.13.4 MSEDCL requests the Hon’ble Commission to approve the interest expenses as submitted in above table. 6.14 Interest on Working capital for FY 2019-20 6.14.1 MSEDCL submits that the Regulations 31.3 of the MERC (MYT) Regulations 2015 provides for Interest on Working Capital for Wire business of electricity. Further the said Regulation also provides that the Normative Rate of interest on working capital shall be base rate as on date of filing of Petition plus 150 basis points. 6.14.2 Accordingly, MSEDCL has calculated Interest on Working Capital for FY 201920 @ 9.50% (8% + 1.50%) for wire business. 6.14.3 MSEDCL further submits that the amendment to the Regulation 29.11 of MYT Regulations 2015 provides for Interest on Security Deposit at MCLR as on 01st April 2019 plus 150 basis points. MSEDCL further submits that it has estimated the security deposit considering a nominal growth of 5% over previous year. Accordingly, MSEDCL has calculated Interest on consumer security deposit for FY 2019-20 @ 10.05% (8.55% + 1.5%) for wire business as shown in following Table. MSEDCL January 20 99 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 106: Interest on Working Capital for Wire business for FY 2019-20 Rs. Crs FY 2019-20 (Approved) Particulars Computation of Working Capital (Wire Business) O&M expenses for a month Maintenance Spares at 1% of Opening GFA 1.5 months of expected revenue from charges for use of Distribution wires Less: Amount held as SD from Distribution System Users Total Working Capital Requirement Rate of Interest (% p.a.) Interest on Working Capital Interest on Security Deposit Rate of Interest (% p.a.) Interest on Security Deposit FY 2019-20 (Estimated) Deviation 417.92 522.16 385.01 471.71 1,246.52 1,281.50 34.98 (845.12) 1,341.49 9.45% 126.77 (792.07) 1,346.16 9.50% 127.89 53.05 4.68 9.65% 81.55 10.05% 79.60 (32.91) (50.45) 1.11 (1.95) 6.14.4 MSEDCL requests the Hon’ble Commission to allow the interest on working capital and security deposit for wire business as shown in above table. 6.14.5 MSEDCL further submits that Regulation 31.4 of the MERC (MYT Regulations 2015) provides for Interest on Working Capital for Retail Supply business of electricity. Further the said Regulation also provides that the Normative Rate of interest on working capital shall be base rate as on date of filing of Petition plus 150 basis points. 6.14.6 Accordingly, MSEDCL has calculated Interest on Working Capital for FY 201920 @ 9.50% (8%+1.50%) for supply business. 6.14.7 MSEDCL further submits that the amendment to the Regulation 29.11 of MYT Regulations 2015 provides for Interest on Security Deposit at MCLR as on 01st April 2019 plus 150 basis points. MSEDCL further submits that it has estimated the security deposit considering a nominal growth of 5% over previous year. Accordingly, MSEDCL has calculated Interest on Consumer Security Deposit for FY 2019-20 @ 10.05% (8.55% + 1.5%) for supply business as shown in following table: MSEDCL January 20 100 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 107: Interest on Working capital for Supply business for FY 2019-20 Rs. Crs Particulars Computation of Working Capital (Supply Business) O&M expenses for a month Maintenance Spares at 1% of Opening GFA 1.5 months equivalent of the expected revenue from sale of electricity at the prevailing Tariff and including revenue from CSS and Additional Surcharge Less: Amount held as security deposit Less: One month equivalent of cost of Power Purchase, Transmission Charges and MSLDC Charges Total Working Capital Requirement Rate of Interest (% p.a.) Interest on Working Capital Estimated Working Capital Interest Interest on Security Deposit Rate of Interest (% p.a.) Interest on Security Deposit FY 2019-20 (Approved) FY 2019-20 (Estimated) 225.03 58.02 207.32 99.68 8,651.54 9,695.24 (7,606.07) (7,128.59) 477.48 (4,800.17) (5,097.75) (297.58) (3,471.65) 9.45% - (2,224.11) 9.50% - 9.65% 733.99 10.05% 716.42 Deviation (17.72) 41.66 1,043.70 1,247.54 (17.56) 6.14.8 MSEDCL requests the Hon’ble Commission to allow the interest on working capital and security deposit for supply business as shown in above table. 6.15 Other Finance Charges 6.15.1 MSEDCL submits that based on available information for FY 19-20, it has estimated the Other Finance Charges for the year as summarised below: Table 108: Other Finance Charges Particulars Guarantee Charges Finance Charges Stamp Duty Service Fee (Fund-raising charges) Total Rs. Crs FY 2019-20 (Estimated) 23.04 1.12 6.94 31.10 6.15.2 MSEDCL requests the Hon’ble Commission to allow the other finance charges as shown in above table. MSEDCL January 20 101 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 6.16 Provision for Bad Debts for FY 2019-20 6.16.1 MSEDCL submits that bad debts are inseparable incidents of the business of electricity distribution and retail supply. 6.16.2 Regulation 73 and 82 of the MYT Regulations, 2015 specifies that a provision of bad and doubtful debt may be allowed up to 1.5% of the amount shown as trade receivables or receivables in the Audited Accounts of the distribution licensee duly allocated for wires and supply business respectively. 6.16.3 MSEDCL has computed the provision for bad and doubtful debts for FY 201920 as per the provisions of the MYT Regulations 2015 considering the estimated receivables for FY 2019-20. The receivables are taken as per actuals till September 2019 and are further projected till March 2020 in order to arrive at the receivables for FY 2019-20. For the interest part a y-o-y rise of 2% and 10% is taken for Non-AG and AG respectively. For the principle part a y-o-y rise of 2% and 5% is taken for Non-AG and AG respectively. MSEDCL further submits that the provision estimated for FY 2019-20 shall be written off after the approval of Hon’ble Commission. The computation of provision for bad debt for FY 19-20 is shown in following table. Table 109: Computation of Provision for Bad Debt for FY 19-20 Rs. Crs FY 2019-20 (Approved) Particulars Opening Balance of Provision for bad and doubtful debts Receivables for the year Provision for bad & doubtful debts during the year Provision for bad & doubtful debts during the year Estimated bad and doubtful debts written off Closing Balance of Provision for bad and doubtful debts Closing Balance as a % of receivables 1,638.42 FY 2019-20 (Estimated) 56,362.04 Deviation -1,638.42 56,362.04 1.50% - 1,638.42 845.43 845.43 845.43 845.43 - -1,638.42 0.00% 6.16.4 Considering the allocation matrix provided by Hon’ble Commission in the MYT Regulations 2015, MSEDCL has worked out the provision for Bad Debt for wire MSEDCL January 20 102 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition and retail supply businesses respectively as shown below: Table 110: Provision for Bad debts for FY 2019-20 Rs. Crs Particulars Bad Debt Provision for Wires business Bad Debt Provision for Retail Supply business Bad Debt Provision FY 2019-20 (Approved) - FY 2019-20 (Estimated) 84.54 760.89 845.43 Deviation 84.54 760.89 845.43 6.16.5 MSEDCL requests the Hon’ble Commission to allow provision for Bad Debt as shown in above table. 6.17 Other Expenses for FY 2019-20 6.17.1 The other expenses of MSEDCL comprise of the expenditure on account of Non-Moving items written off, interest to suppliers/contractors, Incentive to distribution franchisee and other expenses viz. compensation for injuries to staff and outsiders. MSEDCL has estimated the other expenses for FY 2019-20 considering provisional figures for the first six months and projections for the remaining six months for FY 2019-20 as shown in the table below. Table 111: Other Expenses for FY 2019-20 Rs. Crs Particulars Compensation for injuries,death to staff Compensation for injuries,death to others Loss on obsolescence of fixed Assets Sundry debit balances written off Non Moving Items Others Other Expenses for previous years Expected Credit loss on other receivables TOTAL FY 2019-20 FY 2019-20 (Approved) (Estimated) 1.36 1.26 16.33 15.22 1.64 1.81 3.81 16.89 2.63 7.74 5.52 45.66 69.79 50.08 Deviation (0.10) (1.11) 1.64 1.81 13.08 5.11 5.52 (45.66) (19.71) 6.17.2 MSEDCL requests the Hon’ble Commission to allow the other expenses as shown in above table. 6.18 Provision for Contribution to Contingency Reserves for FY 2019-20 6.18.1 Regulation 34 of MYT Regulations 2015, provides for the Provision for MSEDCL January 20 103 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Contingency Reserves. Accordingly, MSEDCL has estimated the same @ 0.25% of the estimated Opening GFA (including grants and consumer contribution) for FY 2019-20 as shown in the following table: Table 112: Contingency Reserve for FY 2019-20 Rs. Cr. Particulars Contribution to Contingency Reserves FY 2019-20 (Approved) - FY 2019-20 (Estimated) 142.85 Deviation 142.85 6.18.2 MSEDCL submits that as per the Regulation 34 of the MYT Regulations 2015, MSEDCL has made the investment for FY 18-19. Considering this, MSEDCL has claimed the contribution to contingency reserve for FY 19-20. Once the approval is available, MSEDCL shall make the necessary investments as per the provisions of the MYT Regulations 2015. 6.18.3 MSEDCL requests the Hon’ble Commission to allow the contingency reserves as shown in above table. 6.19 Incentives and Discounts for FY 2019-20 6.19.1 MSEDCL has estimated the incentives and Discount for FY 2019-20 based on the information available for the first six months and for the remaining six months considered it to be equal to first six months. Table 113: Incentives/Discount for FY 2019-20 Rs. Crs Particulars Incentives and Discount FY 2019-20 (Approved) 271.86 FY 2019-20 (Estimated) 307.03 Deviation 35.17 6.19.2 MSEDCL requests the Hon’ble Commission to allow the incentives/discounts as shown in above table. 6.20 RLC Refund for FY 2019-20 6.20.1 MSEDCL has made RLC Refund of Rs. 1.84 Cr. in FY 2019-20 as per actual information available for first six months as shown in the below table. MSEDCL requests the Hon’ble Commission to approve the same. MSEDCL January 20 104 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 114: Refund of RLC for FY 2019-20 Rs. Crs Particulars RLC Refund FY 2019-20 (Approved) - FY 2019-20 (Estimated) 1.84 Deviation 1.84 6.21 Return on Equity for FY 2019-20 6.21.1 Regulation 28.2 of MERC (MYT) Regulations 2015, provides for Return on Equity (RoE) for Distribution Licensee for both Wire and Supply Business. 6.21.2 The return on equity capital is allocated in the ratio of Fixed Assets between the Wires and Retail Supply Business, i.e. 90% to Wires Business and 10% to Supply Business. Therefore, the capital expenditure, grants, equity and capitalisation are divided into wires and supply business in the ratio of 90:10. 6.21.3 Considering the provisions of the MYT Regulations 2015, MSEDCL has computed the return on equity as shown in following tables. Table 115: RoE for wires business for FY 2019-20 Rs. Crs FY 2019-20 (Approved) Particulars Return on Equity (Wires Business) Regulatory Equity at the beginning of the year Equity portion of Assets Capitalisation Equity portion of Assets Decapitalised Regulatory Equity at the end of the year Return on Computation Return on Regulatory Equity at the beginning of the year - 15.5%*(1) Return on Normative Equity portion of Assett Capitalization - 15.5%*(2)/2 Interest on Equity portion above 30% equity Total Return on Regulatory Equity MSEDCL January 20 FY 2019-20 (Estimated) 11,699.43 912.40 12,611.83 10,553.23 295.34 10,848.57 1,813.41 1,635.75 70.71 22.89 21.86 1,905.98 1,658.64 Deviation (1,146.20) (617.06) (1,763.25) (177.66) (47.82) (21.86) (247.34) 105 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 116: RoE for retail supply business for FY 2019-20 Rs. Crs Particulars Regulatory Equity at the beginning of the year Equity portion of Assets Capitalisation Equity portion of Assets Decapitalised Regulatory Equity at the end of the year Return on Computation Return on Regulatory Equity at the beginning of the year - 17.5%*(1) Return on Normative Equity portion of Assett Capitalization - 17.5%*(2)/2 Interest on Equity portion above 30% @11.37%p.a. Total Return on Regulatory Equity FY 2019-20 (Approved) 1,299 101 1,401 FY 2019-20 (Estimated) 1,173 33 1,206 227.39 205.28 (22.11) 8.87 2.87 (6.00) 3.33 239.60 208.15 (3.33) (31.44) Deviation (126.35) (68.56) (194.91) 6.21.4 MSEDCL requests the Hon’ble Commission to allow the RoE as computed above. 6.22 Impact of payment to MPECS for FY 2019-20 6.22.1 Hon’ble Commission in the MYT Order dated 3rd November 2016 has approved following amounts towards payment to MPECS. Financial Year FY 17-18 FY 18-19 FY 19-20 Amount in Rs. Cr. 46.20 43.18 40.17 6.22.2 Hon’ble Commission in the MTR Order has approved the amount towards payment to MPECS as the same was allowed under the MYT Order. 6.22.3 Accordingly, MSEDCL has claimed Rs. 40.17 Crs towards the payments to MPECS for FY 2019-20. MSEDCL requests the Hon’ble Commission to allow the same. 6.23 Past Period Adjustment by Commission for FY 2019-20 6.23.1 In the MTR Petition, MSEDCL had submitted that in the MYT Order dated 3rd MSEDCL January 20 106 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition November 2016, the Hon’ble Commission had considered the Net Impact of Past Period while approving the revenue for MSEDCL from revised tariffs for the third Control Period. 6.23.2 Hon’ble Commission had approved the past period adjustments of Rs. 853 Cr. in MTR Order dated 12th September 2018. MSEDCL has considered the same for FY 2019-20. 6.24 Revenue Gap Recovery Allowed for FY 2019-20 6.24.1 MSEDCL submits that in the MTR Order, Hon’ble Commission has allowed revenue recovery as shown in the following table. MSEDCL has considered the same. Table 117: Revenue Gap Recovery Allowed for FY 2019-20 Particulars ARR approved by the Hon'ble Commission Approved Revenue at existing tariff Approved Revenue Gap Formula A B C = A-B Rs. Crs FY 2019-20 71,616.52 69,086.17 2,530.35 Projected Revenue at appproved tariff Additional Recovery from approved tariff Previous Revenue Gap recovery allowed after adjustment of current year Revenue Gap D E = D-B 74,179.45 5,093.28 F = E-C 2,562.93 6.25 Aggregate Revenue Requirement for FY 2019-20 6.25.1 Considering the parameters discussed above, the Aggregate Revenue Requirement (ARR) of MSEDCL for Wires Business for the FY 2019 -20 is as follows: MSEDCL January 20 107 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 118: ARR for Wires Business for the FY 2019-20 Rs. Crs Particulars Operation & Maintenance Expenses Depreciation Interest on Loan Capital Interest on Normative Working Capital Interest on deposit from Consumers and Distribution System Users Other Finance Charges Provision for bad and doubtful debts Contribution to contingency reserves Return on Equity Capital Aggregate Revenue Requirement FY 2019-20 (Approved) 5,015.05 2,170.28 1,323.93 126.77 FY 2019-20 (Estimated) 4,620.17 2,334.93 1,214.59 127.89 81.55 79.60 (1.95) 1,931.03 10,648.62 3.11 84.54 128.56 1,658.64 10,252.04 3.11 84.54 128.56 (272.39) (396.58) Deviation (394.88) 164.65 (109.34) 1.11 6.25.2 Considering the parameters discussed above, the Aggregate Revenue Requirement (ARR) of MSEDCL for Supply Business for the FY 2019 -20 is as follows: Table 119: ARR for Supply Business for the FY 2019-20 Rs. Crs Particulars Power Purchase Expenses Operation & Maintenance Expenses Depreciation Expenses Interest on Loan Capital Interest on Normative Working Capital Interest on Consumers Security Deposit Other Finance Charges Provision for bad and doubtful debts Other Expenses Intra-State Transmission Charges MSLDC charge Incentives/Discounts Contribution to Contingency Reserves Return on Equity Capital RLC refund Past Period Adjustment by Commission Revenue Gap recovery allowed Impact of payment to MPECS in future years Aggregate Revenue Requirement for Supply Business MSEDCL FY 2019-20 (Approved) 52,738.26 2,700.42 241.13 147.10 733.99 69.79 4,863.74 271.86 214.56 853.08 2,562.93 40.17 FY 2019-20 (Estimated) 56,305.45 2,487.79 259.44 134.95 716.42 27.99 760.89 50.08 4,867.55 307.03 14.28 208.15 1.84 853.08 2,562.93 40.17 65,437.03 69,598.04 January 20 Deviation 3,567.19 (212.63) 18.31 (12.15) (17.57) 27.99 760.89 (19.71) 3.81 35.17 14.28 (6.41) 1.84 4,161.01 108 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 6.26 Revenue for FY 2019-20 6.26.1 MSEDCL has estimated the revenue for FY 2019-20 based on the available information up to Sept 2019 and projection for balance 6 months of the FY 2019-20 as shown in following table. Table 120: Revenue for FY 2019-20 Rs. Crs FY 2019-20 (Approved) 74,179.45 Particulars Revenue from Sale of Power FY 2019-20 (Estimated) 76,371.19 Deviation 2,191.74 6.26.2 MSEDCL humbly requests to the Hon’ble Commission to consider the revenue from sale of power as shown in above table 6.27 Non-Tariff Income for FY 2019-20 6.27.1 MSEDCL has certain sources of non-tariff income viz. interest on arrears of consumers, delayed payment charges, interest on staff loans and advances, sale of scrap, interest on investment etc. 6.27.2 Considering the available information for the first six months of FY 2019-20 and projections for the first six months, the Non-Tariff Income for FY 2019-20 has been estimated as given in the table below: Table 121: Non-Tariff Income for FY 2019-20 Rs. Crs Particulars Rents of land or buildings Sale of Scrap Income from investments Interest from Franchisee Income from sale of tender documents Prompt payment discount from REC/PFC Other/Miscellaneous receipts Non Tariff Income FY 2019-20 (Approved) 1.27 56.10 17.25 6.88 16.22 1,006.03 1,103.75 FY 2019-20 (Estimated) 1.03 52.05 18.50 8.92 12.16 269.00 361.66 Deviation (0.24) -4.05 1.25 2.04 -4.06 -737.03 -742.09 6.27.3 As provided in the Regulation 36.3 of the MYT Regulations 2015, delayed Payment Charge and Interest on Delayed Payment is not considered under Non-Tariff Income. MSEDCL January 20 109 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 6.27.4 MSEDCL has also not considered income from grants and contribution reported under non-tariff income, as the treatment to the same is already considered while computing the depreciation for the FY 2019- 20. 6.28 Income from Open Access Charges for FY 2019-20 6.28.1 Considering the available information for the first six months of FY 2019-20 and considering it to remain at same level of first six months for the remaining six months of FY 2019-20, MSEDCL has estimated the Income from Open Access for FY 2019-20. Table 122: Income from Open Access Charges FY 2019-20 Rs. Crs Particulars Income from Open Access Charges FY 2019-20 (Approved) 674.71 FY 2019-20 (Estimated) 211.92 Deviation -462.80 6.29 Income from Trading of Surplus Power for FY 2019-20 6.29.1 MSEDCL has estimated the Income from Trading of Surplus Power for FY 2019-20 as shown in the table below: Table 123: Income from Power trading of surplus power for FY 2019-20 Rs. Crs Particulars Income from Trading of Surplus Power FY 2019-20 (Approved) - FY 2019-20 (Estimated) 298.18 Deviation 298.18 6.29.2 MSEDCL humbly requests to the Hon’ble Commission to allow the income from sale of surplus power as shown in above table. 6.30 Income from Wheeling Charges for FY 2019-20 6.30.1 MSEDCL has estimated the Income from Wheeling Charges to be same as that of for FY 2018-19 as per audited accounts for FY 2019-20. Table 124: Income from Wheeling Charges FY 2019-20 Rs. Crs Particulars Income from Wheeling Charges MSEDCL FY 2019-20 (Approved) 1.61 January 20 FY 2019-20 (Estimated) 1.79 Deviation 0.17 110 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 6.30.2 MSEDCL humbly requests to the Hon’ble Commission to approve the Income from Wheeling Charges as shown in above table. 6.31 Income from Additional Surcharge for FY 2019-20 6.31.1 Considering the available information for first six months of FY 2019-20 and estimating it to remain at the same level for the remaining six months as that for the first six months, MSEDCL has estimated the Income from Additional Surcharge for FY 2019-20. Table 125: Income from Additional Surcharge for FY 2019-20 Rs. Crs Particulars Income from Additional Surcharge FY 2019-20 FY 2019-20 (Approved) (Estimated) 126.12 317.14 Deviation 191.03 6.31.2 MSEDCL humbly requests to the Hon’ble Commission to approve the Income from Additional Surcharge as shown in above table. 6.32 Revenue Gap/(Surplus) for FY 2019-20 6.32.1 Based on the above analysis, the summary of ARR for the Wires Business and Supply Business, estimated and as approved by the Hon’ble Commission, for FY 2019-20 is presented in the Table below. MSEDCL January 20 111 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 126: Revenue Gap/ (Surplus) for FY 2019-20 Rs. Crs Particulars Power Purchase Expenses Operation & Maintenance Expenses Depreciation Expenses Interest on Loan Capital Interest on Normative Working Capital Interest on Consumers Security Deposit Other Finance Charges Provision for bad and doubtful debts Other Expenses Intra-State Transmission Charges MSLDC charge Incentives/Discounts Contribution to Contingency Reserves Return on Equity Capital RLC refund Past Period Adjustment by Commission Revenue Gap Allowed Impact of payment to MPECS Aggregate Revenue Requirement Revenue from Sale of Power Non-Tariff Income Income from Open Access Charges Income from Trading of Surplus Power Income from Wheeling Charges Income from Additional Surcharge Total Revenue Revenue Gap/(Surplus) FY 2019-20 (Approved) 52,738.26 7,715.47 2,411.41 1,471.03 126.77 815.54 69.79 4,863.74 271.86 2,145.59 853.08 2,562.93 40.17 76,085.65 74,179.45 1,103.75 674.71 1.62 126.12 76,085.65 FY 2019-20 (Estimated) 56,305.45 7,107.96 2,594.37 1,349.54 127.89 796.03 31.10 845.43 50.08 4,867.55 307.03 142.85 1,866.79 1.84 853.08 2,562.93 40.17 79,850.07 76,371.19 361.66 211.92 298.18 1.79 317.14 77,561.88 2,288.19 Deviation 3,567.19 (607.51) 182.96 (121.49) 1.11 (19.52) 31.10 845.43 (19.71) 3.81 35.17 (278.80) 1.84 3,764.43 2,191.74 (742.09) (462.80) 298.18 0.17 191.03 1,476.24 2,288.19 6.32.2 The Hon’ble Commission in its MTR Order dated 12th September 2018 had approved Aggregate Revenue Requirement of Rs. 76,085.65 Cr. for FY 201920. MSEDCL submits the provisional ARR of Rs. 79,850.07 Cr. with a deviation of Rs. 3,764.43 Cr. Considering the impact of revenue and other income, the truing up requirement works out to be Rs. 2,288.19 Cr. MSEDCL requests the Hon’ble Commission to allow MSEDCL the provisional true up requirement as submitted above. MSEDCL January 20 112 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 7 7.1 AGGREGATE REVENUE REQUIREMENT FOR FY 20-21 TO FY 24-25 Preamble 7.1.1 Hon’ble Commission has notified the MERC (Multi Year Tariff) Regulations 2019 (hereinafter to be referred as MYT Regulations 2019) on 1st August 2019 which are applicable for the period FY 2020-21 to FY 2024-25 (the Control Period). This Chapter summarizes the Aggregate Revenue Requirement (ARR) for the Fourth Control Period from FY 2020-21 to FY 2024-25. The estimations/ projections for the period from FY 2020-21 to FY 2024-25 have been made considering the provisions of the MERC (MYT) Regulations, 2019. 7.2 Approach for Sales Projection for Control Period 7.2.1 MSEDCL submits that Regulation 82.1 of MERC (MYT) Regulations, 2019 provides that Distribution License is required to submit a month-wise forecast of the expected sales of electricity to each tariff category/ sub-category and to each Tariff slab within such Tariff category/sub-category. The relevant extracts of the regulation are reproduced below. “82 Sales Forecast 82.1 The Distribution Licensee shall submit a month-wise forecast of the expected sales of electricity to each Tariff category/sub-category and to each Tariff slab within such Tariff category/sub-category to the Commission for approval along with the Multi-Year Tariff Petition, as specified in these Regulations: Provided that the Distribution Licensee shall submit relevant details regarding category-wise sales separately for each Distribution Franchisee area within its Licence area, as well as the aggregated category-wise sales in its Licence area.” 7.2.2 It has been observed from the past experience that the historical trend method has proved to be a reasonably accurate and well accepted method for estimating the load, number of consumers and energy consumption. In light of the above, MSEDCL has estimated energy consumption for various customer categories primarily based on the CAGR trends during past years. Wherever it MSEDCL January 20 113 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition is observed that the trend is unreasonable/unsustainable or recent developments, the growth factors have been corrected to arrive at more realistic projections. 7.2.3 MSEDCL submits that the break-up of the past sales and the CAGR growth rates for different periods (5 years, 3 years and year on year) is provided in the following tables. It may be noted that the 5 year CAGR growth rate is for the period between FY 2013-14 & FY 2018-19 while the 3 year CAGR growth rate is for the period between FY 2015-16 & FY 2018-19 whereas year on year is for FY 2018-19 over FY 2017-18. 7.2.4 Historical trend in HT Category sales growth for MSEDCL (including sales in Franchisee Area) is given in following table: Table 127: Historical Sales Growth and CAGR (HT Category) Category HT-I Industries HT-II Commercial HT III Railways HT IV-PWW HT V Agricultural HT VI Bulk Supply (Housing Complex) HT Temporary HT-IX Public services MSPGCL AUX SUPPLY HT EV Charging Stations Total -HT Sales FY 13-14 FY 14-15 FY 15-16 FY 16-17 FY 17-18 MUs 5 Year 3 Year Y-oY FY 18-19 CAGR CAGR Growth 31,381 6% 10% 10% 1,805 0% -2% -6% 77 -45% -58% 17% 1,900 3% 4% -1% 1,413 11% 3% 45% 23,721 1,786 1,563 1,678 848 25,131 1,886 1,579 1,736 871 23,315 1,927 1,072 1,698 1,288 23,366 1,825 86 1,702 1,331 28,470 1,926 66 1,911 974 226 221 219 213 227 236 1% 2% 4% 3 801 14 30,640 6 860 61 32,352 5 907 83 30,514 4 922 179 29,628 5 1,003 218 34,799 5 1,004 184 0.31 38,004 12% 5% 68% 4% 3% 3% 30% 8% 9% 0% -16% 9% 7.2.5 Historical trend in LT Category sales growth (including sales in Franchisee Area) is given in following table. MSEDCL January 20 114 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 128: Historical Sales Growth and CAGR (LT Category) Category FY 13-14 FY 14-15 FY 15-16 FY 16-17 FY 17-18 FY 18-19 LT Category LT I -BPL 138 LT I Domestic 16,281 LT II Non Domestic 3,914 LT III PWW 593 LT IV Agriculture 20,915 LT V Powerloom 2,878 LT V Industrial General 4,599 LT VI Streetlight 1,328 LT VII- Temporary Connection 23 LT VIII Advertisement & Hoardings 3 LT IX – Crematoriums & Burial Grounds 2 LT X - Public services 87 LT Prepaid 12 P.D. Consumers -14 Total LT Sales 50,760 Total Sales 81,400 7.3 102 17,678 4,087 627 25,786 3,222 4,816 1,498 19 3 1 203 13 -10 58,045 90,397 5 Year CAGR 3 Year CAGR MUs Y-oY Growth 77 18,861 4,358 673 27,512 3,243 5,026 1,667 18 3 1 307 61 18,962 4,524 691 27,525 3,270 5,114 1,751 16 4 2 361 55 19,994 5,444 707 29,921 3,551 4,903 1,843 17 5 2 431 41 20,788 5,874 803 32,696 3,645 5,138 2,007 24 4 2 504 -22% 5% 8% 6% 9% 5% 2% 9% 1% 6% 4% 42% -19% 3% 10% 6% 6% 4% 1% 6% 9% 7% 11% 18% -26% 4% 8% 14% 9% 3% 5% 9% 43% -6% 5% 17% -11 61,736 92,250 -5 62,275 91,903 66,874 1,01,673 71,526 1,09,531 7% 6% 5% 6% 7% 8% CAGR considered for Sales Projection for Control Period 7.3.1 MSEDCL submits that it has witnessed a normal growth in Sales in the last few years. MSEDCL has been able to considerably increase the availability of power, because of which the sales of MSEDCL has grown. Additional availability of power to the consumers resulted in uninterrupted supply of power to all consumers (except AG with stipulated hours of supply) and hence resulted in increase in the consumption and in turn the Sales of MSEDCL. 7.3.2 Keeping the variations over a period in mind, MSEDCL has considered the 3 years/ 5 years CAGRs for projecting the sales. Wherever the trend was unreasonable /unsustainable, the growth factors have been corrected to arrive at more realistic projections. 7.3.3 The category wise CAGRs considered for the Control Period from FY 2020-21 to FY 2024-25 along with rationale for HT Category have been shown in the following table. MSEDCL January 20 115 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 129: CAGR Considered for Sales Projections (HT Category) Consumer Category HT-IND 11 KV CAGR Justification/Rationale Considered 4% 5 year CAGR considered. HT-IND 22 KV 4% 5 year & 3 year CAGR coming 5% & 8%, respectively. However, realistic growth rate of 4% considered HT-IND 33 KV 4% 5 year & 3 year CAGR coming 5% & 11%, respectively. However, realistic growth rate of 4% considered HT-IND EHV 4% HT-COMM 11 KV HT-COMM 22 KV HT-COMM 33 KV HT-COMM EHV HT RAILWAY/METRO/MONO 11 KV HT RAILWAY/METRO/MONO 22 KV HT RAILWAY/METRO/MONO 33 KV HT RAILWAY/METRO/MONO EHV HT-PWW 11 KV HT-PWW 22 KV HT-PWW 33 KV HT-PWW EHV 2% 2% 2% 2% 2% 2% 2% 2% 5% 5% 5% 5% HT-AGRICULTURE 11 KV 0% HT-AGRICULTURE 22 KV HT-AGRICULTURE 33 KV HT-AGRICULTURE EHV HT-AGRICULTURE OTHERS 11 KV HT-AGRICULTURE OTHERS 22 KV HT-AGRICULTURE OTHERS 33 KV HT-GROUP HOUSING 11 KV HT-GROUP HOUSING 22 KV HT-GROUP HOUSING 33 KV HT-PUBLIC SER.-GOVT 11 KV HT-PUBLIC SER.-GOVT 22 KV HT-PUBLIC SER.-GOVT 33 KV HT-PUBLIC SER.-OTHER 11 KV 20% 3% 17% 12% 7% 18% 1% 1% 0% 2% 2% 2% 2% HT-PUBLIC SER.-OTHER 22 KV 2% HT-PUBLIC SER.-OTHER 33 KV 2% HT-PUBLIC SER.-OTHER EHV 2% 5 year & 3 year CAGR coming quite high, i.e. 9% and 18%, hence realisting CAGR of 4% has been considered Unrealisting trends in CAGR observed due to change in category of sume consumers from Commercial to Public Services. Hence, realistic growth rate of 2% has been considered Negative trend in CAGR observed due to migration of Railway/ Metro/ Mono Rail consumers to Open Access. Thus, nominal growth rate of 2% has been observed considering upcoming metro rail in Nagour, Varying trends in CAGR observed in PWW category across all voltage levels. However, considering Government initiative of "Har Ghar Jal", a realistic growth rate of 5% has been considered across all 3 year CAGR -3%. Hence, 5 year CAGR has been considered 5 Yr CAGR considered 5 Yr CAGR considered 5 Year CAGR has been considered 5 Yr CAGR considered 5 Yr CAGR considered 5 Yr CAGR considered 5 Yr CAGR considered 5 Yr CAGR considered Negative CAGRs, hence 0% considered 3 Yr CAGR considered 3 Yr CAGR considered CAGR considered for 11/22 KV considered 2 Year CAGR considered Realistic growth rate of 2% considered inline with that considered for 11 kV sales Realistic growth rate of 2% considered inline with that considered for 11 kV sales Realistic growth rate of 2% considered inline with that considered for 11 kV sales 7.3.4 The category wise CAGRs considered for the Control Period from FY 2020-21 to FY 2024-25 along with rationale for LT Category have been shown in the following table. MSEDCL January 20 116 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 130: CAGR Considered for Sales Projections (LT Category) Consumer Category LT-I (A): LT- BPL CAGR Considered Justification/Rationale 5 & 3 year CAGR coming -22% & -19%, respectively. However, considering the GoI Schemes for Household Electrification, a realistic growth considered 10% LT-I (B) : LT-Residential( Other than BPL) 1-100 Units 3% 101-300 Units 2% 301-500 Units 1% 501-1000 Units -1% Above 1000 Units LT-II : LT- Non Residential 0-20 KW 0-200 Units -1% Above 200 units 12% >20-<=50 KW 7% >50 KW 10% LT-III : LT-Public Water Works 0% 0-20 KW 5% 20-<=40 KW 5% > 40 KW 10% *** LT-AG-Unmetered (Pumpsets) LT-AG Metered (Pumpsets) LT-AG Metered (Others) LT V(A) : LT Industry- Power Looms 0-20 KW (Upto & including 27 HP) Above 20 KW (above 27 HP) LT V(B) : LT Industry- General 0-20 KW (Upto & including 27 HP) Above 20 KW (above 27 HP) LT X - Public services - Govt 0-20 KW 0-200 Units >200 units >20-50 kW >50 kW LT X - Public services - Other 0-20 KW 0% 4% 0% 0% 4% 4% 0% 4% 4% 0% 0% 6% 6% 6% 6% 0% 0% 0-200 Units 6% >200 units >20-50 kW >50 kW LT VI – Street Light Gram panchayat A, B & C Class Municipal Council Municipal corporation Area LT VII – Temporary connection Temporary Connection (Religious) Temporary Connection (Other Purposes) LT VIII - Advertisements & Hoardings LT IX - Crematorium and Burial Grounds 6% 6% 6% MSEDCL Considering the CAGRs, realistic growth of 3% considered in view of the increased use of LEDs; Considering the CAGRs, realistic growth of 2% considered in view of the increased use of LEDs;; Considering the CAGRs, realistic growth of 1% considered; Considering the CAGRs and impact of Rooftop Solar, realistic growth of -1% considered; 4% Considering the CAGRs, realistic growth of 4% considered; Considering the varying CAGRs, realistic growth of 12% considered which in equivalent to 5 yr CAGR; Considering the varying CAGRs, realistic growth of 7% considered which in equivalent to 5 yr CAGR; Considering the varying CAGRs, realistic growth of 10% considered which in equivalent to 5 yr CAGR; Considering the varying CAGRs, realistic growth of 5% considered which in equivalent to 5 yr CAGR; Considering the varying CAGRs, realistic growth of 5% considered which in equivalent to 5 yr CAGR; 3 & 5 year CAGR coming quite high. realistic growth of 10% considering Govt initiative of "Har Ghar Jal" No new connections, hence 0% 3 year CAGR 10%. Realistic growth of 4% 3 Year CAGR coming quite high. Realistic rate of 0% considered 3 & 5 year CAGR coming quite low. Realistic growth of 4% 3 & 5 year CAGR coming quite high. Realistic growth of 4% 5 & 3 year CAGR coming negative. Realistic growth of 4% 5 & 3 year CAGR coming 6%. Realistic growth of 4% 3 & 5 year CAGR coming quite high. Realistic growth of 6% 3 & 5 year CAGR coming quite high. Realistic growth of 6% 3 & 5 year CAGR coming quite high. Realistic growth of 6% 3 & 5 year CAGR coming quite high. Realistic growth of 6% 5 year CAGR coming 29% & 3 year CAGR coming -2%, hence realistic growth of 6% 3 & 5 year CAGR coming quite high. Realistic growth of 6% 3 & 5 year CAGR coming quite high. Realistic growth of 6% 3 & 5 year CAGR coming quite high. Realistic growth of 6% 2% YoY Growth considered 4% YoY Growth considered 10% 10% 8% 0% CAGRs too high, realistic growth considered CAGRs too high, realistic growth considered 3 yr CAGR and YoY 8%, hence, YoY considered CAGRs are varying, realistic growth considered January 20 117 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 7.4 Sales Projections for Control Period 7.4.1 MSEDCL submits that it has considered FY 2018-19 as the base year for projection of sales for the fourth control period FY 2020-21 to FY 2024-25. Based on the sales for FY 2018-19 and the CAGR as shown in above tables, MSEDCL has projected the sales for various categories. The sales projections of HT Categories for the fourth control period are shown in the following table: Table 131: Sales Projections (HT category) for the Control Period Category HT-I Industries HT-II Commercial HT III Railways HT IV-PWW HT V Agricultural HT VI Bulk Supply (Housing Complex) HT Temporary HT-IX Public services MSPGCL AUX SUPPLY HT Ag Others HT EV Charging Stations Total -HT Sales FY 20-21 Projected 33,586 1,850 80 1,745 1,486 239 5 1,044 184 299 0.31 40,519 FY 21-22 Projected 34,929 1,887 82 1,832 1,685 242 5 1,065 184 332 0.31 42,243 FY 22-23 Projected 36,326 1,925 84 1,924 1,919 244 5 1,086 184 368 0.31 44,065 FY 23-24 Projected 37,779 1,963 85 2,020 2,192 246 5 1,108 184 410 0.31 45,993 MUs FY 24-25 Projected 39,290 2,003 87 2,121 2,512 249 5 1,130 184 456 0.31 48,037 7.4.2 Based on the above growth rate, it is estimated that HT category will witness a growth of ~5% on YoY basis. 7.4.3 For LT AG Category, MSEDCL has considered a growth rate of 4% considering the fact that MSEDCL is planning to provide future AG connections through OffGrid Solar Pumps. Details of the Scheme are provided in Details of Capex Chapter at Paragraph 16.28. MSEDCL has considered the average of consumption for FY 17-18, FY 18-19 and FY 19-20 as base for projections of AG sales for Control Period. 7.4.4 The sales projections of LT Categories for the fourth control period are shown in the following table: MSEDCL January 20 118 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 132: Sales Projections (LT Category) Category LT Category LT I -BPL LT I Domestic LT II Non Domestic LT III PWW LT IV Agriculture LT V Powerloom LT V Industrial General LT VI Streetlight LT VII- Temporary Connection LT VIII Advertisement & Hoardings LT IX – Crematoriums & Burial Grounds LT X - Public services LT XI EV Charging Stations Total LT Sales Total Sales MUs FY 20-21 FY 21-22 FY 22-23 FY 23-24 FY 24-25 Projected Projected Projected Projected Projected 140 21,583 6,360 886 31,374 2,132 5,265 2,383 24 5 2 154 22,120 6,900 932 32,185 2,217 5,475 2,610 24 5 2 169 22,674 7,491 981 33,028 2,306 5,694 2,863 24 5 2 186 23,242 8,141 1,033 33,904 2,398 5,922 3,145 24 6 2 205 23,827 8,854 1,088 34,816 2,494 6,159 3,458 24 6 2 569 0.23 70,722 1,11,241 609 0.23 73,233 1,15,476 652 0.23 75,889 1,19,954 698 0.23 78,701 1,24,694 748 0.23 81,682 1,29,719 7.4.5 Based on the above growth rate, it is estimated that LT category as well as overall sales will witness a growth of ~4% on YoY basis. 7.4.6 MSEDCL further submits that in the Petition it has proposed the introduction of kVAh based billing for HT consumers. In view of the same, for the purpose of determination of revenue from proposed kVAh based tariff, it has converted the kWh sales into kVAh sales considering category wise power factors as shown in Table 185. 7.5 Sales projections for Distribution Franchisees for Control Period 7.5.1 MSEDCL submits that due to financial condition, M/s SNDL, the Nagpur DF, in its Letter dated August 12, 2019 and September 6, 2019 showed its inability to maintain the electricity distribution system and requested MSEDCL to take over the Franchisee area. 7.5.2 Accordingly, the Distribution franchisee of Nagpur has been terminated as per MSEDCL January 20 119 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition the provisions of Distribution Franchisee Agreement (DFA) on September 9, 2019. The distribution operations of Nagpur DF area has been taken over by MSEDCL on September 9, 2019. 7.5.3 MSEDCL further submits that in Form “F1 MSEDCL Yearly Sales Forecast”, MSEDCL has shown category wise sales of MSEDCL including Distribution Franchisee. The category wise sales for Distribution Franchisee have been calculated in the respective form using the same methodology and CAGR for respective category used for MSEDCL. Since, MSEDCL has taken over the Nagpur DF, for the purpose of revenue estimation for the Control Period, MSEDCL has included the sales in Nagpur DF area in its own sale instead of input sale. 7.5.4 Considering the projected sales and estimated loss levels, MSEDCL has projected the input level sales of said DFs for the Control Period is shown in following table. Table 133: Input Sales for Bhiwandi DF for the Control Period Category Bhiwandi Category Wise Sales Distribution Loss Input Sales FY 20-21 Projected MU FY 21-22 FY 22-23 FY 23-24 FY 24-25 Projected Projected Projected Projected 3,269.49 3,407.40 3,551.80 3,703.03 3,861.50 13.01% 12.76% 12.51% 12.26% 12.01% 3,758.46 3,905.78 4,059.66 4,220.46 4,388.56 7.5.5 Considering the decision of Hon’ble Commission in its Order dated 18th June 2014 in Case No. 85 of 2010, MSEDCL has considered area of supply of MPECS as merged in the area of supply of MSEDCL for present projections. 7.6 Approach for No. of Consumers Projection for Control Period 7.6.1 MSEDCL submits that, similar to sales projections, MSEDCL has also adopted the historical trend method for projecting category wise no. of consumers of MSEDCL. The Break-up of category wise no. of consumers and the 5 year CAGR growth rate is for the period between FY 2013-14 & FY 2018-19 while the 3 year CAGR growth rate is for the period between FY 2015-16 & FY 2018- MSEDCL January 20 120 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 19 whereas year on year is for FY 2018-19 over FY 2017-18. Wherever it is observed that the trend is unreasonable or unsustainable, the growth factors have been corrected to arrive at more realistic projections. 7.6.2 Historical trend in No. of Consumers in HT Category for MSEDCL (Excluding Bhiwandi Franchisee) is given in following table. Table 134: Historical Growth and CAGR No. of Consumers (HT Category) Category FY 13-14 FY 14-15 FY 15-16 FY 16-17 FY 17-18 FY 18-19 HT-I Industries 12,730 HT-II Commercial 2,910 HT III Railways 44 HT IV-PWW 847 HT V Agricultural 1,292 HT VI Bulk Supply (Housing Complex) 227 HT Temporary 11 HT-IX Public services 1,077 MSPGCL AUX SUPPLY 14 HT EV Charging Stations Total -HT Consumers 19,152 12,932 3,053 44 941 1,338 234 10 1,147 23 19,722 13,257 3,072 10 963 1,380 242 7 1,205 24 20,160 13,560 3,098 24 995 1,430 248 10 1,261 28 20,654 13,998 3,137 79 967 1,435 242 11 1,313 28 21,210 14,353 3,165 82 983 1,446 266 11 1,357 27 2 21,692 5 Year CAGR 2% 2% 13% 3% 2% 3% 0% 5% 14% 3% 3 Year Y-oY CAGR Growth 3% 3% 1% 1% 102% 4% 1% 2% 2% 1% 3% 10% 16% 0% 4% 3% 4% -4% 2% 2% 7.6.3 Historical trend in No. of Consumers in LT Category for MSEDCL (Excluding Bhiwandi Franchisee) is given in following table. Table 135: Historical Growth and CAGR No. of Consumers (LT Category) Category LT Category LT I -BPL LT I Domestic LT II Non Domestic LT III PWW LT IV Agriculture LT V Powerloom LT V Industrial General LT VI Streetlight LT VII- Temporary Connection LT VIII Advertisement & Hoardings LT IX – Crematoriums & Burial Grounds LT X - Public services LT Prepaid Total LT Consumers Total Consumers 7.7 FY 13-14 FY 14-15 FY 15-16 4,46,132 1,58,00,457 15,61,091 46,949 36,66,591 80,903 3,02,400 81,819 3,43,979 1,66,03,380 16,16,503 48,337 38,31,998 82,088 3,10,683 85,615 2,65,105 1,73,74,057 16,83,093 50,118 39,87,916 82,377 3,19,330 88,561 2,922 2,471 2,639 2,640 2,015 2,027 2,203 2,527 104 41,230 14,482 2,20,47,095 2,20,66,247 126 73,782 14,937 2,30,15,926 2,30,35,648 152 78,942 14,090 2,39,48,583 2,39,68,743 FY 16-17 FY 17-18 2,09,731 1,76,998 1,80,24,487 1,86,32,604 17,56,626 18,37,478 51,833 51,671 41,03,781 41,79,004 81,682 73,178 3,16,776 3,07,183 91,293 93,798 FY 18-19 5 Year CAGR 3 Year Y-oY CAGR Growth 3,50,243 1,94,27,851 19,04,557 52,808 42,44,685 67,653 3,15,673 96,466 -5% 4% 4% 2% 3% -4% 1% 3% 10% 4% 4% 2% 2% -6% 0% 3% 98% 4% 4% 2% 2% -8% 3% 3% 3,673 6,028 16% 32% 64% 2,543 2,742 6% 8% 8% 180 244 83,487 92,691 13,071 12,097 2,47,38,114 2,54,63,162 2,47,58,768 2,54,84,372 229 1,04,129 10,809 2,65,83,873 2,66,05,565 17% 20% -6% 4% 4% 15% 10% -8% 4% 4% -6% 12% -11% 4% 4% CAGR considered for Projection of Nos. Consumer for Control Period 7.7.1 MSEDCL has considered CAGR methodology for projections. Wherever it is MSEDCL January 20 121 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition observed that the trend is unreasonable or unsustainable, the growth factors have been corrected to arrive at more realistic projections considering year on year growth rate. 7.7.2 Following tables provide the CAGRs considered for projecting the number of consumers for the third MYT control period. MSEDCL January 20 122 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 136: CAGR Considered for No. of Consumers Projections (HT Category) Category HT-IND 11 KV HT-IND 22 KV HT-IND 33 KV HT-IND EHV HT-COMM 11 KV HT-COMM 22 KV HT-COMM 33 KV CAGR Considered 2% 1% 3% 6% 2% 3% 2% HT-COMM EHV 0% HT RAILWAY/METRO/MONO 11 KV HT RAILWAY/METRO/MONO 22 KV HT RAILWAY/METRO/MONO 33 KV HT RAILWAY/METRO/MONO EHV HT-PWW 11 KV HT-PWW 22 KV HT-PWW 33 KV HT-PWW EHV HT-AGRICULTURE 11 KV HT-AGRICULTURE 22 KV HT-AGRICULTURE 33 KV HT-AGRICULTURE EHV HT-AGRICULTURE OTHERS 11 KV HT-AGRICULTURE OTHERS 22 KV HT-AGRICULTURE OTHERS 33 KV HT-POULTRY 11 AND 22 KV HT-POULTRY 33 KV HT-POULTRY EHV HT-AG HIGHTECH 11 AND 22 KV HT-AG HIGHTECH 33 KV HT-AG HIGHTECH EHV HT-AG (COLD STORAGE) 11 AND 22 KV HT-AG (COLD STORAGE) 33 KV HT-AG (COLD STORAGE) EHV HT-GROUP HOUSING 11 KV HT-GROUP HOUSING 22 KV 0% 0% 0% 0% 0% 0% 3% 0% 0% 0% 3% 9% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% HT-GROUP HOUSING 33 KV 0% HT-PUBLIC SER.-GOVT 11 KV HT-PUBLIC SER.-GOVT 22 KV HT-PUBLIC SER.-GOVT 33 KV HT-PUBLIC SER.-OTHER 11 KV HT-PUBLIC SER.-OTHER 22 KV HT-PUBLIC SER.-OTHER 33 KV HT-PUBLIC SER.-OTHER EHV HT-EV CHARGING STATIONS 11 KV HT-EV CHARGING STATIONS 22 KV MSEDCL 0% 0% 10% 0% 0% 10% 0% 0% 0% Justification/Rationale 5 & 3 year CAGR Negative. Realistic rate of 2% Realistic Rate of 1% considered YoY Growth rate of 3% considered 3 Year CAGR considered 3 & 5 Year CAGR Negative. Realistic growth of 2% Realistic growth of 3% considered 3 & 5 Year CAGR Negative. Realistic growth of 2% 3 & 5 Year CAGR Negative. Realistic growth of 0% considered as the no. of consumers are very less 3 & 5 year CAGR quite high. Realistic growth of 0% 3 & 5 year CAGR quite high. Realistic growth of 0% 3 & 5 year CAGR quite high. Realistic growth of 0% 3 & 5 year CAGR negative. Realistic growth of 0% 3 & 5 year CAGR negative. Realistic growth of 0% 3 & 5 year CAGR negative. Realistic growth of 0% 3 & 5 year CAGR quite high. Realistic growth of 3% 3 & 5 year CAGR quite high. Realistic growth of 0% 3 & 5 year CAGR negative. Realistic growth of 0% 3 & 5 year CAGR negative. Realistic growth of 0% 3 Year CAGR considered YoY Growth considered Inconsistent CAGR observed. Realistic growth of 0% Inconsistent CAGR observed. Realistic growth of 0% YoY Growth considered Realistic rate of 0% considered Realistic rate of 0% considered Realistic rate of 0% considered Realistic rate of 0% considered Realistic rate of 0% considered Realistic rate of 0% considered Realistic rate of 0% considered Realistic rate of 0% considered Realistic rate of 0% considered 3 & 5 year CAGR negative. Realistic growth of 0% Realistic growth of 0% considered Realistic growth of 0% in line with other voltage level consumers 3 Year CAGR considered Realistic rate of 0% considered 3 Year CAGR coming high. Realistic growth of 10% CAGR Negative. Realistic growth of 0% Realistic rate of 0% considered Considering YoY Growth too high, realistic growth considered 3 Year CAGR considered 0% growth considered 0% growth considered January 20 123 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 137: CAGR Considered for No. of Consumers Projections (LT Category) Consumer Category CAGR Justification/Rationale Considered LT Category LT-I (A): LT- BPL 10% LT-I (B) : LT-Residential( Other than BPL) LT-II : LT- Non Residential 0-20 KW >20-<=50 KW >50 KW LT-III : LT-Public Water Works 0-20 KW 20-<=40 KW > 40 KW LT-IV: LT-Agriculture *** LT-AG-Unmetered (Pumpsets) LT-AG Metered (Pumpsets) LT V(A) : LT Industry- Power Looms 4% Considering the GoI Schemes for Household Electrification, a realistic growth considered 3 year CAGR considered 4% 3% 10% 3 year CAGR considered 3 & 5 year CAGR coming high. YoY growth of 3% considered Year on Year growth considered 2% 9% 10% 5 Year CAGR considered 5 Year CAGR considered 3 & 5 year CAGR coming high. Realistic growth of 10% 0% 3% No new connections, hence 0% 3 & 5 year CAGR coming high. YoY growth of 3% considered 0-20 KW (Upto & including 27 HP) 0% Above 20 KW (above 27 HP) 0% LT V(B) : LT Industry- General 0-20 KW (Upto & including 27 HP) Above 20 KW (above 27 HP) LT X - Public services - Govt 0-20 KW >20-50 kW >50 kW LT X - Public services - Other 0-20 KW >20-50 kW >50 kW Street Light (LT-VI) Grampanchayat A, B & C Class Municipal Council Municipal corporation Area Temporary Connection (LT-VII) Temporary Connection (Religious) Temporary Connection (Other Purposes) LT-VIII : LT-Advertisements & Hordings LT-IX : LT-Crematorium and Burial Grounds CAGR including YoY growth coming negative. Hence, realistic growth of 0% CAGR including YoY growth coming negative. Hence, realistic growth of 0% 3% 3% CAGRs are varying. Considering the no. of consumers for Sept19 and increase in FY 18-19, YoY Growth of 3% considered. 10% 10% 10% 3 Year CAGR coming quite high. Realistic growth of 10% 3 Year CAGR coming quite high. Realistic growth of 10% 3 Year CAGR coming quite high. Realistic growth of 10% 5% 5% 5% 3 Yr CAGR coming 0%. Realistic growth of 5% 3 Yr CAGR coming quite high. Realistic growth of 5% 3 Yr CAGR coming quite high. Realistic growth of 5% 2% 4% Y-o-Y Considered Y-o-Y Considered 10% 10% 8% 0% Varying CAGR. Realistic growth of 10% Varying CAGR. Realistic growth of 10% 3 Yrs CAGR and Y-o-Y Growth 8%, hence 8% considered Y-o-Y Growth negative, hence, realistic growth 0% considered 7.7.3 MSEDCL submits that presently and for future period also, it has sufficient power availability. Considering this, MSEDCL has taken an optimistic view and considered positive or zero growth for most of the categories. 7.8 Number of Consumer Projections for Control Period 7.8.1 MSEDCL submits that it has considered FY 2018-19 (March 19 figures) as the base year for projection of number of consumers for the fourth control period FY 2020-21 to FY 2024-25. Details of no. of consumers, connected load, contract demand are provided in the Regulatory Formats. Based on the number MSEDCL January 20 124 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition of consumers for FY 2018-19 and the CAGR as shown in above tables, MSEDCL has projected the number of consumers (excluding Bhiwandi Franchisees) for various categories for the control period as shown in the following tables: Table 138: No. of Consumers Projections (HT category) for the Control Period FY 20-21 FY 21-22 FY 22-23 FY 23-24 FY 24-25 Projected Projected Projected Projected Projected HT-I Industries 14,435 14,686 14,944 15,207 15,476 HT-II Commercial 3,244 3,324 3,406 3,490 3,576 HT III Railways 85 85 85 85 85 HT IV-PWW 992 995 998 1,001 1,004 HT V Agricultural 1,465 1,475 1,485 1,496 1,507 HT VI Bulk Supply (Housing Complex) 384 384 384 384 384 HT Temporary 17 17 17 17 17 HT-IX Public services 1,385 1,389 1,394 1,399 1,405 MSPGCL AUX SUPPLY 27 27 27 27 27 HT EV Charging Stations 3 3 3 3 3 Total -HT Consumers 22,037 22,385 22,743 23,109 23,484 Category Table 139: No. of Consumers Projections (LT category) for the Control Period Category FY 20-21 Projected LT Category LT I -BPL 4,00,905 LT I Domestic 2,05,53,868 LT II Non Domestic 19,83,984 LT III PWW 55,230 LT IV Agriculture 43,46,007 LT V Powerloom 34,424 LT V Industrial General 3,19,725 LT VI Streetlight 99,945 LT VII- Temporary Connection 9,589 LT VIII Advertisement & Hoardings 3,175 LT IX – Crematoriums & Burial Grounds 228 LT X - Public services 1,16,717 LT Prepaid 10,334 Total LT Consumers 2,79,34,131 Total Consumers (Ex.Franchise) 2,79,56,168 MSEDCL FY 21-22 Projected FY 22-23 Projected FY 23-24 Projected FY 24-25 Projected 4,40,996 4,85,096 5,33,606 5,86,967 2,14,31,116 2,23,45,805 2,32,99,533 2,42,93,967 20,56,468 21,31,626 22,09,559 22,90,372 56,508 57,825 59,183 60,584 44,44,834 45,47,091 46,52,897 47,62,375 34,424 34,424 34,424 34,424 3,28,565 3,37,652 3,46,994 3,56,597 1,02,805 1,05,756 1,08,801 1,11,942 10,549 11,605 12,766 14,043 3,424 3,692 3,981 4,293 228 228 228 228 1,24,776 1,33,461 1,42,825 1,52,925 10,334 10,334 10,334 10,334 2,90,45,027 3,02,04,595 3,14,15,131 3,26,79,051 2,90,67,412 3,02,27,338 3,14,38,240 3,27,02,535 January 20 125 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 7.9 Approach for Connected Load/ Contract Demand Projection for Control Period 7.9.1 MSEDCL submits that, similar to sales and no. of consumers’ projections, MSEDCL has also adopted the historical trend method for projecting category wise no. of consumers of MSEDCL. The Break-up of category wise load and the 5 year & 3 year CAGR growth rates as well as Year on Year growth rates for the period FY 2018-19 over FY 2013-14 is provided in the below table. Wherever it is observed that the trend is unreasonable or unsustainable, the growth factors have been corrected to arrive at more realistic projections. 7.9.2 Historical trend in Billing Demand in HT Category for MSEDCL (Excluding Bhiwandi Franchisee) is given in following table. Table 140: Historical Growth and CAGR connected load/Contract Demand (HT Category) kVA 5 Year 3 Year Y-oY CAGR CAGR Growth 4% 5% 8% -2% -3% 1% -51% -20% -41% 6% 5% 2% 5% -1% 1% Category FY 13-14 FY 14-15 FY 15-16 FY 16-17 FY 17-18 FY 18-19 HT-I Industries HT-II Commercial HT III Railways HT IV-PWW HT V Agricultural HT VI Bulk Supply (Housing Complex) HT Temporary HT-IX Public services MSPGCL AUX SUPPLY HT EV Charging Stations 67,01,808 6,18,413 6,05,769 2,15,651 3,35,227 67,89,400 6,57,341 6,16,026 2,63,199 3,29,307 69,14,477 6,06,933 31,746 2,56,739 4,05,702 71,97,960 5,71,287 4,678 2,82,643 4,49,457 74,36,493 5,48,172 28,100 2,87,390 4,26,420 80,29,222 5,52,821 16,453 2,94,493 4,29,748 51,231 2,025 2,09,576 1,787 - 53,112 2,167 2,34,456 45,140 - 53,512 1,377 2,47,570 50,901 - 53,240 1,059 2,61,479 1,05,477 - 50,610 1,666 2,55,960 80,504 - 53,235 2,528 2,56,986 80,156 1,004 1% 0% 4% 0% 0% 0% 1% 0% 5% 52% 0% 0% Total -HT Consumers 87,41,487 89,90,148 85,68,957 89,27,280 91,15,315 97,16,646 2% 4% 7% 7.9.3 Historical trend in Load/Contract Demand in LT Category for MSEDCL (Excluding Bhiwandi Franchisee) is given in following table. MSEDCL January 20 126 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 141: Historical Growth and CAGR connected load/Contract Demand (LT Category) Unit LT-I (A): LT- BPL LT-I (B) : LT-Residential( Other than BPL) LT-II : LT- Non Residential 0-20 KW >20-<=50 KW >50 KW LT-III : LT-Public Water Works 0-20 KW 20-<=40 KW > 40 KW KW 46,757 35,281 26,872 21,246 18,548 40,894 KW 1,51,64,833 1,62,33,621 1,73,58,053 1,83,34,050 1,93,57,845 2,08,42,559 7% 6% 8% KW KVA KVA 25,28,071 2,43,831 1,29,753 26,72,479 2,50,900 1,33,018 28,23,343 2,83,429 1,52,961 30,78,782 2,95,751 1,67,158 33,97,369 2,86,895 1,68,933 36,27,431 3,33,682 2,05,625 7% 6% 10% 9% 6% 10% 7% 16% 22% KVA KVA KVA 79,871 15,332 11,518 80,662 15,577 12,363 88,211 18,733 12,681 89,632 1,13,720 14,521 94,161 20,053 14,179 95,257 24,025 29,855 4% 9% 21% 3% 9% 33% 1% 20% 111% 84,74,115 1,01,38,096 1,73,400 83,94,300 1,08,93,862 1,79,956 83,42,017 1,16,47,924 1,20,662 78,32,143 1,27,02,797 1,28,126 75,39,616 1,35,37,753 1,43,306 74,22,998 1,40,69,165 3,10,250 -3% 7% 0% -4% 6% 0% -2% 4% 0% *** LT-AG-Unmetered (Pumpsets) LT-AG Metered (Pumpsets) LT-AG Metered (Others) LT V(A) : LT Industry- Power Looms HP HP FY 13-14 FY 14-15 FY 15-16 FY 16-17 FY 17-18 FY 18-19 5 Year 3 Year Y-oY CAGR CAGR Growth -3% 15% 120% Category 0-20 KW (Upto & including 27 HP) Above 20 KW (above 27 HP) LT V(B) : LT Industry- General KW KVA 2,46,201 1,36,133 2,55,612 1,61,164 2,61,701 1,64,574 2,61,236 1,87,563 2,59,654 1,97,979 2,59,618 2,26,718 1% 11% 0% 11% 0% 15% 0-20 KW (Upto & including 27 HP) Above 20 KW (above 27 HP) Street Light (LT-VI) Grampanchayat A, B & C Class Municipal Council Municipal corporation Area Temporary Connection (LT-VII) Temporary Connection (Religious) Temporary Connection (Other Purposes) LT-VIII : LT-Advertisements & Hordings LT-IX : LT-Crematorium and Burial Grounds LT X - Public services - Govt 0-20 KW >20-50 kW >50 kW LT X - Public services - Other 0-20 KW >20-50 kW >50 kW KW KVA 19,38,252 13,39,134 20,13,535 13,63,675 20,58,722 14,01,915 20,40,403 14,33,786 19,56,730 13,58,172 20,14,870 16,55,184 1% 4% -1% 6% 3% 22% KW KW KW 2,19,008 1,38,014 2,30,403 1,42,547 1,92,475 1,85,695 2,04,649 1,82,535 1,96,357 1,94,167 1,96,980 2,02,475 -2% 8% 1% 3% 0% 4% KW 2,015 2,113 3,447 3,333 2,841 4,276 16% 7% 50% KW 13,889 12,374 11,701 12,477 15,589 26,168 14% 31% 68% KW 5,350 5,357 5,700 6,285 6,477 6,619 4% 5% 2% KW 786 841 1,225 1,446 1,609 1,748 17% 13% 9% KW KVA KVA 56,318 4,620 5,982 1,14,349 16,248 16,530 15,601 1,896 1,665 1,19,200 22,955 20,552 21,207 2,586 2,820 1,33,989 26,091 23,763 26,577 3,317 2,773 1,51,854 28,161 28,256 41,610 4,352 3,756 1,60,581 33,636 34,810 0% 0% 0% 0% 0% 0% 0% 39% 32% 31% 0% 10% 14% 19% 57% 31% 35% 0% 6% 19% 23% KW KVA KVA 7.10 CAGR considered for Connected Load/Contract Demand Projection 7.10.1 Similar to sales and no. of consumers, MSEDCL has used the CAGR methodology for projecting the connected load, billing demand/contract demand. Wherever it is observed that the trend is unreasonable or unsustainable, the growth factors have been corrected to arrive at more realistic projections. 7.10.2 Following tables shows the CAGR considered for projection of connected load, billing demand/contract demand. MSEDCL January 20 127 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 142: CAGR Considered for Contract Demand Projections (HT Category) Category HT-IND 11 KV HT-IND 22 KV HT-IND 33 KV HT-IND EHV HT-COMM 11 KV HT-COMM 22 KV HT-COMM 33 KV HT-COMM EHV HT-III RAILWAYS/Metro/Mono HT RAILWAY/METRO/MONO 11 KV HT RAILWAY/METRO/MONO 22 KV HT RAILWAY/METRO/MONO 33 KV HT RAILWAY/METRO/MONO EHV HT-PWW 11 KV HT-PWW 22 KV HT-PWW 33 KV HT-PWW EHV HT-AGRICULTURE 11 KV HT-AGRICULTURE 22 KV HT-AGRICULTURE 33 KV HT-AGRICULTURE EHV HT-GROUP HOUSING 11 KV HT-GROUP HOUSING 22 KV HT-GROUP HOUSING 33 KV HT-GROUP HOUSING EHV HT-PUBLIC SER.-GOVT 11 KV HT-PUBLIC SER.-GOVT 22 KV HT-PUBLIC SER.-GOVT 33 KV HT-PUBLIC SER.-GOVT EHV HT-PUBLIC SER.-OTHER 11 KV HT-PUBLIC SER.-OTHER 22 KV HT-PUBLIC SER.-OTHER 33 KV HT-PUBLIC SER.-OTHER EHV MSEDCL January 20 CAGR Considered 1% 1% 1% 1% 2% 2% 2% 2% 0% 2% 2% 5% 0% 3% 3% 2% 0% 0% 0% 5% 7% 1% 1% 1% 0% 5% 5% 5% 0% 0% 0% 2% 2% 128 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 143: CAGR Considered for Connected Load/Contract Demand Projections (LT Category) Category LT-I (A): LT- BPL LT-I (B) : LT-Residential( Other than BPL) LT-II : LT- Non Residential 0-20 KW 0-200 Units Above 200 units >20-<=50 KW >50 KW LT-III : LT-Public Water Works 0-20 KW 20-<=40 KW > 40 KW LT-AG Metered (Pumpsets) LT-AG Metered (Others) LT Poultry/Hightech LT V(A) : LT Industry- Power Looms 0-20 KW (Upto & including 27 HP) Above 20 KW (above 27 HP) LT V(B) : LT Industry- General 0-20 KW (Upto & including 27 HP) Above 20 KW (above 27 HP) LT X - Public services - Govt 0-20 KW >20-50 kW >50 kW LT X - Public services - Other 0-20 KW >20-50 kW >50 kW CAGR Considered 1% 5% 4% 0% 0% 4% 4% 3% 5% 5% 2% 0% 5% 1% 5% 1% 4% 3% 3% 3% 0% 3% 3% 3% 7.11 Connected Load Projections for Control Period 7.11.1 MSEDCL submits that based on the connected load/ contract demand or provisional billing demand for FY 2018-19 and the CAGRs as shown in above tables, MSEDCL has projected the connected load/contract demand for various categories (excluding Bhiwandi Franchisees) for the period as shown in the following table: MSEDCL January 20 129 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 144: Connected load/contract demand Projections (HT category) for the Control Period Category HT-I Industries HT-II Commercial HT III Railways HT IV-PWW HT V Agricultural HT VI Bulk Supply (Housing Complex) HT Temporary HT-IX Public services MSPGCL AUX SUPPLY HT EV Charging Stations Total -HT Consumers MSEDCL FY 20-21 Projected 81,89,374 5,75,160 17,160 3,10,195 4,60,978 FY 21-22 Projected 82,70,653 5,86,665 17,527 3,18,381 4,78,078 FY 22-23 Projected 83,52,745 5,98,400 17,904 3,26,800 4,96,253 FY 23-24 Projected 84,35,658 6,10,370 18,290 3,35,457 5,15,571 kVA FY 24-25 Projected 85,19,399 6,22,580 18,684 3,44,360 5,36,104 54,308 2,528 2,64,422 80,156 1,004 99,55,285 54,852 2,931 2,68,390 80,156 1,004 1,00,78,637 55,402 3,079 2,72,533 80,156 1,004 1,02,04,276 55,958 3,234 2,76,860 80,156 1,004 1,03,32,558 56,519 3,396 2,81,383 80,156 1,004 1,04,63,585 January 20 130 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 145: Connected load/contract demand Projections (LT category) for the Control Period KW KW FY 20-21 Projected 41,717 2,29,78,922 FY 21-22 Projected 42,135 2,41,27,869 FY 22-23 Projected 42,557 2,53,34,263 FY 23-24 Projected 42,983 2,66,00,977 FY 24-25 Projected 43,413 2,79,31,026 KVA KVA KVA 39,23,431 3,60,912 2,22,404 40,80,369 3,75,349 2,31,301 42,43,584 3,90,363 2,40,554 44,13,328 4,05,978 2,50,177 45,89,862 4,22,218 2,60,185 KVA KVA KVA 1,03,031 26,489 32,916 1,05,705 27,814 34,562 1,08,448 29,205 36,291 1,11,262 30,666 38,106 1,14,149 32,200 40,012 74,22,999 1,46,37,560 3,10,250 74,22,999 1,49,30,312 3,10,250 74,22,999 1,52,28,919 3,10,250 74,22,999 1,55,33,498 3,10,250 74,22,999 1,58,44,168 3,10,250 KVA KVA 2,65,188 2,49,957 2,68,018 2,62,455 2,70,878 2,75,578 2,73,769 2,89,357 2,76,690 3,03,825 KVA KVA 20,52,218 17,45,259 20,68,192 18,20,809 20,84,291 18,99,630 21,00,515 19,81,863 21,16,865 20,67,656 KW KW KW KW KW 2,00,623 2,10,624 32,308 6,838 1,855 2,02,176 2,16,787 33,924 6,989 1,948 2,03,742 2,23,130 35,621 7,144 2,046 2,05,320 2,29,659 37,403 7,302 2,149 2,06,910 2,36,379 39,274 7,464 2,257 KVA KVA KVA 43,316 4,531 3,910 44,616 4,667 4,028 45,955 4,808 4,149 47,334 4,953 4,274 48,755 5,102 4,403 KVA KVA KVA 1,67,164 35,015 36,237 1,72,179 36,066 37,325 1,77,345 37,148 38,445 1,82,666 38,263 39,599 1,88,146 39,411 40,787 Category Unit LT-I (A): LT- BPL LT-I (B) : LT-Residential( Other than BPL) LT-II : LT- Non Residential 0-20 KW >20-<=50 KW >50 KW LT-III : LT-Public Water Works 0-20 KW 20-<=40 KW > 40 KW LT-IV: LT-Agriculture *** LT-AG-Unmetered (Pumpsets) LT-AG Metered (Pumpsets) LT-AG Metered (Others) LT V(A) : LT Industry- Power Looms 0-20 KW (Upto & including 27 HP) Above 20 KW (above 27 HP) LT V(B) : LT Industry- General 0-20 KW (Upto & including 27 HP) Above 20 KW (above 27 HP) Street Light (LT-VI) Grampanchayat A, B & C Class Municipal Council Municipal corporation Area LT Temporary LT-VIII : LT-Advertisements & Hordings LT-IX : LT-Crematorium and Burial Grounds LT X - Public services - Govt 0-20 KW >20-50 kW >50 kW LT X - Public services - Other 0-20 KW >20-50 kW >50 kW HP HP HP 7.11.2 For the purpose of Revenue Estimation, MSEDCL has considered the average of no. of consumers, connected load, billing demand of the year end since the consumers get added throughout the year. 7.12 Segregation of Wires and Supply Business for Control Period 7.12.1 MSEDCL submits that Regulation 71 of the MYT Regulations 2019 provides that Aggregate Revenue Requirement of the Distribution Licensee shall be apportioned between the Distribution Wires Business and Retail Supply Business in accordance with the allocation matrix. MSEDCL January 20 131 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 7.12.2 The relevant extract of the regulation is reproduced below. 71 Separation of Accounts of Distribution Licensee Every Distribution Licensee shall maintain separate accounting records for the Distribution Wires Business and Retail Supply Business and shall prepare an Allocation Statement to enable the Commission to determine the Tariff separately for: (a) Distribution Wires Business; (b) Retail Supply of electricity: Provided that in case complete accounting segregation has not been done between the Distribution Wires Business and Retail Supply Business of the Distribution Licensee, the Aggregate Revenue Requirement of the Distribution Licensee shall be apportioned between the Distribution Wires Business and Retail Supply Business in accordance with the following Allocation Matrix: ……… ………. Provided further that the above Allocation Matrix shall be applied for all or any of the heads of expenditure and revenue, where actual accounting separation has not been done between the Distribution Wires Business and Retail Supply Business: Provided also that the Commission may require the Distribution Licensee to file separate Petitions for determination of Tariff for the Distribution Wires Business and Retail Supply Business. 7.12.3 MSEDCL has segregated the expenses based on the allocation matrix as provided in the MYT Regulations 2019 which is reproduced below for ready reference. Table 146: Segregation for Retail Supply and Wires Business Expenses Particulars Power Purchase Expenses Inter-State Transmission Charges MSEDCL Distribution Wires Business (%) 0% 0% January 20 Retail Supply Business (%) 100% 100% 132 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Particulars Intra-State Transmission Charges Operation & Maintenance Expenses Depreciation Interest on Long-term Loan Capital Interest on Working Capital Interest on Consumer Security Deposits Provision for Bad & Doubtful Debts Income Tax Contribution to Contingency Reserves Return on Equity Non-Tariff Income Distribution Wires Business (%) 0% 65% 90% 90% 10% 10% 10% 90% 90% 90% 10% Retail Supply Business (%) 100% 35% 10% 10% 90% 90% 90% 10% 10% 10% 90% 7.13 Estimation of ARR for Control Period 7.13.1 MSEDCL submits that the components for the calculation of total expenses for the Annual Revenue Requirement for the period FY 2020-21 to FY 2024-25 are as follow: Power Purchase Cost. Intra State Transmission Charges Operation & Maintenance Expenses. Interest on Loan and Financial Charges. Depreciation. Interest on Working Capital. Contribution to Contingency Reserves Provision for Bad Debts. Income Tax Return on Equity. 7.14 Power Purchases Expenses for Control Period 7.14.1 MSEDCL has following primary sources of firm power viz. Maharashtra State Power Generation Company Limited (MSPGCL) Purchase from Central Generating Stations MSEDCL January 20 133 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition JSW (RATNAGIRI) Mundra UMPP CGPL Adani Power Ltd. Rattan India (Previously India Bulls Ltd.) Emco Power Ltd. etc. 7.14.2 In addition to the above sources, MSEDCL buys power from Sardar Sarovar Project (SSP) and Pench Hydro project, renewable energy sources including co-generation, wind and solar. MSEDCL may also purchase the power from the Power trading Companies, Power exchanges in case of shortfall from regular sources or increase in demand depending on the availability. 7.15 Assumptions for power purchase for Control Period 7.15.1 MSEDCL submits that it procures power from different sources on Merit Order Despatch Principle for optimum utilization of the sources at least cost. For projection of availability, MSEDCL has considered the entire power available from all the tied-up sources during this period to meet the demand. Considering the capacity available and the demand projection, no power procurement from Traders or power exchange is projected for the period FY 2020-21 to FY 202425. 7.15.2 Further, a realistic approach has been adopted in projecting the power purchase availability based on the actual availability and considering upcoming projects in the period FY 2020-21 to FY 2024-25. 7.15.3 For estimating the power purchase cost, merit order despatch principles have been considered. As per the provisions of MYT Regulations 2019, MSEDCL has projected the monthly power requirement using the monthly sales projections and applying monthly MOD. While full fixed (capacity) charges have been considered for all the plants, the variable charges corresponding to the cheaper sources of power have been considered, whereas no variable charges have been considered in respect of energy not scheduled for power purchase (according to the merit order dispatch principles). 7.15.4 For power procurement from competitive bidding route, the tariff has been MSEDCL January 20 134 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition considered based on the rate quoted as per the terms of the PPA with the escalation based on the CERC rates, wherever applicable. 7.16 Assumptions for source wise Power Purchase Projection for Control Period A) IPPsMSEDCL submits that it procure power from 5 Independent Power Producers (IPPs) though 9 long term Power Purchase Agreements (PPAs) whose tariff is determined through competitive bidding process. For the projection of variable charges for the MYT Control Period, CAGR of last four financial years with that of FY 2018-19 as a base has been considered. For the computation of Capacity charges, MSEDCL has projected the escalable component of Capacity Charges considering CAGR of last four financial years with that of FY 2018-19 as a base. Non-escalable component of Capacity Charges has been considered as quoted in the PPA of respective IPPs. B) MSPGCL Variable Charges MSEDCL submits that it has considered the operational parameters as well as variable charges for MSPGCL Stations as per the MYT Petition filed by MSPGCL in Case No. 296 of 2019. MSPGCL in its Petition has made following submissions: Mine specific prices will be applied to mines falling in Ballarpur, Marri, Nagpur, Umrer and Warn regions (WCL notice dated Nov 1, 2019) Likely impact on such coal cost is expected to be -Rs 450/tonne. The overall impact is an increase of around 6-7 %in price of coal. Therefore, MSEDCL has considered the revised operational parameters as well as variable charges as per the revised Petition filed by MSPGCL on 10th December 2019. Capacity Charges MSEDCL submits that the projection of capacity charges for the Control MSEDCL January 20 135 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Period, MSEDCL has considered AFC as claimed by MSPGCL in their petition. However, following deductions have been considered in AFC: 1. AFC towards retiring units i.e. Bhusawal 03 & Nashik 03 have not been considered as the said units are set to retire in May 2022 and April 2020 respectively. Furthermore, no power purchase has been considered from the said units. 2. Impact of additional capitalization against FGD installation in the form of interest on Long Term Loan, Depreciation & RoE for Khaparkheda 01 to 04 and Koradi 06, 07 has not been considered. 3. Capacity charges for Parli 04 & 05 has not been considered as the same were under RSD and decommissioned by MSPGCL from 30/11/2019. C) NTPCMSEDCL submits that the variable charges for existing NTPC stations have been projected based on the CAGR of actual variable rate for last 4 financial years. For new NTPC stations like Lara, Gadarwara, Solapur Unit – II & Khargone, variable charges have been adopted as submitted by NTPC in its tariff petition with CERC and the same has been projected for FY 202021 to FY 2024-25 considering same CAGR of NTPC Solapur – I. Projection of Capacity Charges for MYT Petition for 4th Control period from FY 2020-21 to FY 2024-25 is worked out based on CAGR considering the capacity charges of last 4 Financial Years on Normative basis. D) Power Procurement from Renewable Energy Sources MSEDCL submits that it has projected the generation from solar and nonsolar energy sources based on estimated capacity addition and expected CUFs to meet the RPO Targets set by Hon’ble Commission. The following table provides the details of expected capacity addition during the Control Period. MSEDCL January 20 136 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition MW Particulars FY 19-20 FY 20-21 FY 21-22 FY 22-23 FY 23-24 FY 24-25 Capacity Addition 2527 974 3134 1684 1000 1400 Wind EPA expiring 562 282 214 137 137 569 1965 692 2920 1547 863 831 Net Capacity Addition MSEDCL submits that the Hon’ble Commission has notified MERC (Renewable Purchase Obligation, its Compliance and Implementation of Renewable Energy Certificate Framework) Regulations, 2019. As per the said Regulations, the RPO targets have been revised drastically as per the table given below: Year 2020-21 2021-22 2022-23 2023-24 2024-25 Quantum of Purchase (in %) from Renewable Energy Sources (in terms of energy equivalent in kWh) Solar Non-Solar Total 4.50% 11.50% 16.00% 6.00% 11.50% 17.50% 8.00% 11.50% 19.50% 10.50% 11.50% 22.00% 13.50% 11.50% 25.00% MSEDCL also submits that the Hon’ble Commission in the MERC RPO Regulations 2019 has stated that total consumption of electricity for specifying RPO percentage shall exclude the electricity procured from Hydro power. Clause 3.1 of the said regulations states that, “These Regulations shall apply in all cases where the State Commission is to promote Co-generation from renewable sources and generation of electricity from renewable sources and is to specify a minimum percentage for procurement of energy generated from such sources on the basis of total consumption of electricity within the area of a Distribution Licensee. Provided that total consumption of electricity shall exclude the consumption met from Hydro power.” MSEDCL January 20 137 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Considering the provisions of MERC RPO Regulations 2019, MSEDCL is expected to fulfil renewable purchase obligations (Both Solar as well as Non-Solar) considering the total consumption of electricity after excluding the consumption met from Hydro Power. Source wise power purchase from renewable energy sources/RECs are summarised in following table. MUs FY 2020-21 FY 2021-22 FY 2022-23 FY 2023-24 FY 2024-25 Source Projected Projected Projected Projected Projected Bagasse/Biomass 5,082 5,259 5,324 5,324 5,324 Wiind 8,202 9,050 10,128 10,128 10,128 Non Solar 13,284 14,309 15,452 15,452 15,451 Solar 6,988 9,855 14,699 18,430 21,051 Total 20,272 24,164 30,151 33,882 36,503 E) Inter State Transmission Charges The PGCIL charges have been increasing considerably in last 4-5 years after implementation of POC mechanism. MSEDCL has projected the PGCIL charges for FY 20-21 to FY 24-25 considering a growth of 5% per annum over the estimated charges for FY 19-20. F) Power Purchase from Short Term Markets MSEDCL submits that during the higher demand or shortage from regular sources due to various reasons including break downs, fuel shortage etc. , MSEDCL may require to purchase power from exchanges and through short term power purchase tenders throughout the year. Hence it is submitted that, considering the volatile nature of short term power market and uncertainty in supply of power from long term sources on account of various reasons, MSEDCL requests the Hon’ble Commission to accord in principle approval for procurement of power on DEEP e-bidding portal/ power exchange based on the projected average power purchase rate. MSEDCL also requests the Hon’ble Commission to revise the ceiling rate for procurement of power on DEEP e-bidding portal/ power exchange considering the projected power purchase rate during the Control Period. MSEDCL January 20 138 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 7.16.1 Following tables provide the summary of source wise power purchase quantum and cost for the Period FY 20-21 to FY 24-25. Table 147: Source wise Power Purchase quantum and cost for FY 2020-21 to FY 202223 Particulars MSPGCL NTPC NPCIL SSP Pench Dodson JSW CGPL (Mundra UMPP) Adani Power EMCO Power Rattan India Renewable PGCIL Charges Total Power Purchase Quantum MU 55,307.12 25,598.81 4,884.58 1,209.94 136.50 115.72 1,913.18 5,157.89 20,937.22 1,355.17 20,272.00 1,36,888.13 FY 2020-21 Cost Rs. Cr. 24,806.74 9,815.06 1,396.92 248.05 27.98 17.78 692.67 1,515.68 7,869.57 613.16 692.48 9,862.29 3,676.18 61,234.57 Rate Quantum Rs/Unit MU 4.49 55,262.53 3.83 26,667.17 2.86 4,884.58 2.05 1,209.94 2.05 136.50 1.54 115.72 3.62 1,913.18 2.94 5,157.89 3.76 20,784.14 4.52 1,355.17 4.86 24,164.00 4.47 1,41,650.83 FY 2021-22 Cost Rs. Cr. 25,654.11 10,389.47 1,430.57 248.06 27.98 17.92 731.78 1,568.26 7,962.99 650.26 692.48 10,660.92 3,859.99 63,894.79 Rate Quantum Rs/Unit MU 4.64 55,144.56 3.90 26,742.79 2.93 4,884.58 2.05 1,209.94 2.05 136.50 1.55 115.72 3.82 810.03 3.04 5,157.89 3.83 20,937.22 4.80 1,355.17 4.41 30,151.00 4.51 1,46,645.40 FY 2022-23 Cost Rs. Cr. 26,397.72 10,611.73 1,465.12 248.06 27.98 18.11 417.68 1,623.54 8,254.69 679.87 692.48 12,965.83 4,052.99 67,455.81 Rate Rs/Unit 4.79 3.97 3.00 2.05 2.05 1.57 5.16 3.15 3.94 5.02 4.30 4.60 EMCO rates will reduce after shifting connectivity from CTU to STU. Table 148: Source wise Power Purchase quantum and cost for FY 2023-24 to FY 202425 Particulars MSPGCL NTPC NPCIL SSP Pench Dodson JSW CGPL (Mundra UMPP) Adani Power EMCO Power Rattan India Renewable PGCIL Charges Total Power Purchase Quantum MU 55,908.76 27,610.48 4,897.96 1,213.26 136.87 116.04 736.28 5,172.02 20,917.77 1,358.88 33,882.00 1,51,950.32 FY 2023-24 Cost Rs. Cr. 27,636.92 11,094.73 1,504.72 248.75 28.06 27.68 410.60 1,684.98 8,265.39 712.34 692.48 14,355.53 4,255.64 70,917.81 Rate Rs/Unit 4.94 4.02 3.07 2.05 2.05 2.39 5.58 3.26 3.95 5.24 4.24 4.67 Quantum MU 57,779.78 28,847.51 4,884.58 1,209.94 136.50 115.72 413.29 5,157.89 20,937.22 1,355.17 142.19 36,593.00 1,57,572.78 FY 2024-25 Cost Rs. Cr. 28,717.14 11,759.78 1,537.05 248.07 27.98 32.93 334.63 1,742.82 8,050.30 744.72 748.55 15,405.57 4,468.42 73,817.97 Rate Rs/Unit 4.97 4.08 3.15 2.05 2.05 2.85 8.10 3.38 3.84 5.50 4.21 4.68 EMCO rates will reduce after shifting connectivity from CTU to STU. 7.16.2 MSEDCL requests the Hon’ble Commission to allow the power purchase as shown in the tables above. MSEDCL January 20 139 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 7.17 Intra State Transmission Charges 7.17.1 MSEDCL submits that Mumbai Utilities are already benefitted due to present transmission infrastructure. N-2 mechanism is basically to strengthen the network from reliability point of view. This will enhance the power supply & will only be benefitting to Mumbai Utilities. Therefore the transmission charges considered for strengthening of Infrastructure for Mumbai Utilities need to be recovered from Mumbai Consumers only and should not be burdened on MSEDCL. 7.17.2 MSEDCL also submits that the STU has filed the Petition for determination of Intra-State Transmission Tariff for the MYT Control Period from FY 2020-21 to FY 2024-25. As per the said Petition MSEDCL will have following share in the Total Transmission System Cost. Rs. Crs Particulars MSEDCL FY 20-21 10,293.78 FY 21-22 6,352.56 FY 22-23 6,715,36 FY 23-24 7,344.34 FY 24-25 7,999.76 7.17.3 In the said Petition, a steep rise in the transmission tariff from existing Rs. 0.30 per unit for FY 19-20 to Rs. 0.77 per unit in FY 20-21 is proposed. Further, the transmission charges for the remaining years of the Control Period are almost more than 50% higher than the existing transmission charges. 7.17.4 However, these charges seem to be unrealistic and on very higher side. MSEDCL while analysing the MSETCL Petition observed following: - Historically, Hon’ble Commission has been disallowing the income tax, MSETCL has claimed Income Tax of about Rs. 957.09 Crs - Contingency reserves shall be allowed only after investing the same in Securities as per provisions of MYT Regulations - Return on equity is calculated at 15.5% whereas in MTR it was allowed at 7.50% - The impact of disallowed capitalisation from FY 2010-11 to FY 2016-17 and the revenue gap till previous gap claimed by MSETCL is subject to prudence check of Hon’ble Commission; - Due to this, the corresponding carrying cost will also get reduced. MSEDCL January 20 140 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 7.17.5 MSEDCL further submits that there is a wide difference in the historical trend in Intra State Transmission Charges and Petition filed by the STU. The historical trend in the Intra State Transmission Charges for the last 4 years is shown in following table. Particulars FY 15-16 Intra State Transmission Charges (Rs. Crore) FY 17-18 Actual FY 18-19 Actual 3 Yr CAGR Actual FY 16-17 Actual 4,070 3,793 4,812.17 4,775.50 5.47% 7.17.6 However, as directed by Hon’ble Commission, MSEDCL has considered the MSEDCL share in the Total transmission System Cost (TTSC) as submitted by the State Transmission Utility as summarized in following table. Table 149: Intra State Transmission charges for Control Period Particulars Intra State Transmission Charges FY 2020-21 Projected 10,293.78 FY 2021-22 Projected 6,352.56 FY 2022-23 Projected 6,715.36 FY 2023-24 Projected 7,344.34 Rs. Cr. FY 2024-25 Projected 7,999.76 7.17.7 MSEDCL requests the Hon’ble Commission to allow the Intra State Transmission charges as may be approved in the InSTS Order after prudence check.. 7.18 Distribution Loss for the Control Period 7.18.1 MSEDCL submits that it has been achieving a significant reduction in distribution losses and these efforts shall be continued and will further be enhanced. However, the loss reduction is a slow process and as the loss levels come down further reduction in loss becomes difficult. MSEDCL has considered the distribution losses (excl. EHV) for the Control Period FY 2020-21 to FY 2024-25 considering an year on year reduction of 0.25% from the approved Distribution losses of FY 2019-20 i.e. 13.26%. MSEDCL January 20 141 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 150: Proposed Distribution Loss for the Control Period Particulars Distribution Losses (Excluding EHV) FY 2020-21 Projected FY 2021-22 Projected FY 2022-23 Projected FY 2023-24 Projected % FY 2024-25 Projected 13.01% 12.76% 12.51% 12.26% 12.01% 7.18.2 MSEDCL requests the Hon’ble Commission to approve the Distribution Loss (EHV Less) for the Control Period as shown in above table. 7.19 Energy Balance for Control Period 7.19.1 MSEDCL submits that the quantum of sales in MUs shown in Paragraph 7.4 represent the sales of MSEDCL excluding the sales in the area served by Distribution Franchisees. As per the methodology adopted by Hon’ble Commission for calculating energy balance of MSEDCL as a whole, the sale to the consumers in the Distribution Franchisee area has also been considered. Therefore, total energy sale for the Control Period is computed as below: Table 151: Total Energy Sales for MSEDCL for FY 2020-21 to FY 2024-25 Particulars Energy Sales by MSEDCL Add: Category wise sales in DF area (Bhiwandi) Add: OA Sales (Conventional) Add: OA Sales (Non-Conventional) Total Energy Sales FY 2020-21 Projected 1,11,240.53 FY 2021-22 Projected 1,15,476.39 FY 2022-23 Projected 1,19,954.32 FY 2023-24 Projected 1,24,694.41 MUs FY 2024-25 Projected 1,29,719.00 3,269.49 3,407.40 3,551.80 3,703.03 3,861.50 3,983.40 859.40 1,19,352.82 3,983.40 859.40 1,23,726.59 3,983.40 859.40 1,28,348.92 3,983.40 859.40 1,33,240.24 3,983.40 859.40 1,38,423.29 7.19.2 The Energy Balance for FY 2020-21 to FY 2022-23 is summarised in following table. MSEDCL January 20 142 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 152: Energy Balance for FY 2020-21 to FY 2022-23 Sr. No. Particulars FY 2020-21 FY 2021-22 FY 2022-23 Projected Projected Projected 73,257.14 75,873.96 78,640.63 30,637.19 31,832.18 33,078.18 1,03,894.33 1,07,706.14 1,11,718.81 859.40 859.40 859.40 3,983.40 3,983.40 3,983.40 Calculation UoM LT Sales (Including D.F) HT Sales excluding EHV level sales (Including D.F) HT/LTIP Credit Sales and HT/LT Offset Export Solar units Total Sales including D.F (Excluding EHV Sales) OA Sales (Renewables) OA Sales (Conventional) Retail Energy Sale to Consumers (Excluding EHV Sales) a b c d=a+b+c e f MU MU MU MU MU MU A=d+e+f MU 1,08,737.12 1,12,548.93 1,16,561.61 B=g+h g h i MU MU MU % 1,36,888.13 98,545.25 38,342.88 3.07% 1,41,650.83 1,02,239.58 39,411.25 3.07% 1,46,645.40 1,07,158.54 39,486.86 3.07% j=h*(1-i) MU 37,166.08 38,201.66 38,274.96 6 7.1 Total Power Purchase Power Purchase Quantum from Intra-State sources Power Purchase Quantum from Inter-State sources Inter-State Losses Power Purchase Quantum from Inter-State sources at MS Periphery Add: FBSM Power Quantum handled at Maharashtra Periphery k l=g+j+k MU MU 1,35,711.33 1,40,441.24 1,45,433.49 7.2 7.3 7 8 9 Infirm Non-PPA Wind Power Input for OA Consumption Total Power Purchase Quantum Handled Surplus Power Traded Energy Requirement at G<>T Periphery m n=f/(1-6%) o=l+m+n-w p q=o-p MU MU MU MU MU 914.25 4,237.66 1,40,289.97 1,40,289.97 914.25 4,237.66 1,45,019.88 1,45,019.88 914.25 4,237.66 1,50,012.13 1,50,012.13 8.1 8 9 10 11 13 Intra-State Transmission Loss Intra-State Transmission Loss Net Energy requirement at T<>D Periphery EHV Sales Net Energy Available for Sale at 33kV Energy injected and drawn at 33kV Total Energy Available for Sale at 33kV (Metered Energy at EHV and 33 kV Input) r s=q*r t=q-s u v=t-u w % MU MU MU MU MU 3.74% 5,248.75 1,35,041.22 10,615.69 1,24,425.53 573.27 3.73% 5,405.59 1,39,614.29 11,177.65 1,28,436.64 573.27 3.71% 5,570.41 1,44,441.72 11,787.31 1,32,654.41 573.27 C=v+w MU 1,24,998.80 1,29,009.91 1,33,227.68 D=C-A E=D/C MU % 16,261.68 13.01% 16,460.98 12.76% 16,666.07 12.51% 1.1 1.2 1.3 1 2.1 2.2 2 3 3.1 3.2 4 5 14 15.1 15 Distribution Loss (Excl. EHV Sales) Distribution Loss (Excl. EHV Sales) 7.19.3 The Energy Balance for FY 2023-24 to FY 2024-25 is summarised in following table. MSEDCL January 20 143 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 153: Energy Balance for FY 2023-24 to FY 2024-25 Sr. No. Particulars MU MU MU MU MU MU FY 2023-24 Projected 81,568.68 34,377.83 1,15,946.51 859.40 3,983.40 FY 2024-25 Projected 84,670.74 35,733.94 1,20,404.69 859.40 3,983.40 A=d+e+f MU 1,20,789.31 1,25,247.48 B=g+h g h i MU MU MU % 1,51,950.32 1,11,560.85 40,389.47 3.07% 1,57,572.78 1,15,981.20 41,591.58 3.07% j=h*(1-i) MU 39,149.86 40,315.08 k l=g+j+k MU MU 1,50,710.71 1,56,296.28 m n=f/(1-6%) o=l+m+n-w p q=o-p MU MU MU MU MU 914.25 4,237.66 1,55,289.35 1,55,289.35 914.25 4,237.66 1,60,874.91 1,60,874.91 r s=q*r t=q-s u v=t-u w % MU MU MU MU MU 3.70% 5,745.20 1,49,544.15 12,450.93 1,37,093.21 573.27 3.69% 5,930.38 1,54,944.54 13,175.81 1,41,768.73 573.27 C=v+w MU 1,37,666.49 1,42,342.00 D=C-A E=D/C MU % 16,877.18 12.26% 17,094.52 12.01% Calculation UoM LT Sales (Including D.F) HT Sales excluding EHV level sales (Including D.F) HT/LTIP Credit Sales and HT/LT Offset Export Solar units Total Sales including D.F (Excluding EHV Sales) OA Sales (Renewables) OA Sales (Conventional) Retail Energy Sale to Consumers (Excluding EHV Sales) a b c d=a+b+c e f 6 7.1 Total Power Purchase Power Purchase Quantum from Intra-State sources Power Purchase Quantum from Inter-State sources Inter-State Losses Power Purchase Quantum from Inter-State sources at MS Periphery Add: FBSM Power Quantum handled at Maharashtra Periphery 7.2 7.3 7 8 9 Infirm Non-PPA Wind Power Input for OA Consumption Total Power Purchase Quantum Handled Surplus Power Traded Energy Requirement at G<>T Periphery 8.1 8 9 10 11 13 Intra-State Transmission Loss Intra-State Transmission Loss Net Energy requirement at T<>D Periphery EHV Sales Net Energy Available for Sale at 33kV Energy injected and drawn at 33kV Total Energy Available for Sale at 33kV (Metered Energy at EHV and 33 kV Input) 1.1 1.2 1.3 1 2.1 2.2 2 3 3.1 3.2 4 5 14 15.1 15 Distribution Loss (Excl. EHV Sales) Distribution Loss (Excl. EHV Sales) 7.19.4 MSEDCL requests the Hon’ble Commission to approve the Energy Balance for the period FY 2020-21 to FY 2024-25 as submitted by MSEDCL in above tables. 7.20 Operation & Maintenance Expenses for Control Period 7.20.1 MSEDCL submits that Regulation 75 and 84 of the MERC (Multi Year Tariff) Regulations, 2019 provides for the procedure/ methodology to calculate O&M Expenses for Distribution Wires Business and Retail Supply of electricity respectively. MSEDCL January 20 144 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 7.20.2 MSEDCL further submits that MYT Regulations 2019 also provides that if the no. of consumers of Distribution Licensee are increased by more than 2% annually over the last 3 years, efficiency factor shall be considered as zero. Accordingly, considering the escalation factor without reducing efficiency factor, MSEDCL has computed the normative O&M Expenses for the Control Period. 7.20.3 The base year Normative O&M Expenses have been computed by escalating twice with an escalation rate. 7.20.4 The Normative O&M Expenses for the Control Period are summarized in following table. Table 154: Normative O&M Expenses for the Control Period Particulars O&M Expenditure (Wires Business) O&M Expenditure (Supply Business) Total O&M Expenditure Rs. Cr. FY 2020-21 FY 2021-22 FY 2022-23 FY 2023-24 FY 2024-25 Projected Projected Projected Projected Projected 4,536.29 4,710.13 4,890.63 5,078.04 5,272.64 2,442.62 2,536.22 2,633.42 2,734.33 2,839.12 6,978.91 7,246.35 7,524.04 7,812.38 8,111.76 7.20.5 MSEDCL requests the Hon’ble Commission to allow the O&M Expenses as shown in above table. 7.21 Opex for the Control Period 7.21.1 MSEDCL submits that the Regulation 75.7 and 84.7 of the MYT Regulations 2019 provide that the Licensee may undertake Opex schemes for wires and supply business respectively for system automation, new technology and IT implementation, etc. and such expenses may be allowed over and above normative O&M Expenses. 7.21.2 The said Regulations also provide that the Licensee shall submit the detailed justification, cost benefit analysis of such schemes as against capex schemes, and savings in O&M expenses, if any. MSEDCL submits that the details of Opex Schemes are provided in Chapter 17. 7.21.3 The revenue expenditure against the Opex Schemes is summarised in following table. MSEDCL January 20 145 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 155: Opex Schemes for the Control Period Particulars Opex Schemes (Wire Business) Substation Monitoring System (SMS) SMS Services MSEDCL Cloud Project Annual Technical Support of SAP/HANA/Oracle Software Licences Vehicle Tracking System Sub-Total Opex Schemes (Supply Business) Customer Care Center SMS Services RF-DCU (Expression of Interest & Tender) Go Green Initiative MSEDCL Cloud Project Annual Technical Support of SAP/HANA/Oracle Software Licences Vehicle Tracking System Sub-Total Total FY 2020-21 Projected FY 2021-22 Projected FY 2022-23 Projected FY 2023-24 Projected Rs. Cr. FY 2024-25 Projected 69.53 2.72 8.32 69.53 2.72 8.32 69.53 2.72 8.32 69.53 2.72 8.32 69.53 2.72 8.32 5.94 5.94 5.94 5.94 5.94 0.53 87.03 0.53 87.03 0.53 87.03 0.53 87.03 0.53 87.03 6.60 2.72 4.80 1.28 8.32 6.60 2.72 4.80 1.47 8.32 6.60 2.72 4.80 1.69 8.32 6.60 2.72 4.80 1.95 8.32 6.60 2.72 4.80 2.24 8.32 5.94 5.94 5.94 5.94 5.94 0.53 30.18 117.21 0.53 30.37 117.40 0.53 30.59 117.62 0.53 30.85 117.88 0.53 31.14 118.17 7.21.4 MSEDCL requests the Hon’ble Commission to allow the Opex as shown in above table. 7.22 Capex and Capitalisation for Control Period 7.22.1 MSEDCL submits that the projected capitalisation of MSEDCL from FY 202021 to FY 2024-25 is summarized below. The scheme wise details of capital expenditure and capitalisation for the Control Period is shown in a separate forms of the Regulatory Formats. Table 156: Capital expenditure and capitalisation for the Control Period Particulars Capital Expenditure Capitalisation Rs. Cr. FY 2020-21 FY 2021-22 FY 2022-23 FY 2023-24 FY 2024-25 Projected Projected Projected Projected Projected 6,687.24 2,511.67 1,762.74 1,807.60 1,886.44 6,840.31 5,068.20 2,038.96 1,808.60 1,877.44 7.22.2 MSEDCL requests the Hon’ble Commission to allow the capitalisation as shown in above table. MSEDCL January 20 146 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 7.23 Funding Pattern of the Capitalisation for Control Period 7.23.1 MSEDCL submits that it has been the practise of Hon’ble Commission to consider the consumer contribution, grants etc. in proportion the funding pattern of capital expenditure. In line with the same methodology, MSEDCL has considered the funding pattern for the capitalization projected, in proportion to the funding pattern of projected capital Expenditure. MSEDCL further submits that if the equity portion is more than 30% of the capitalisation to be funded, it has restricted the equity at 30% and balance amount is considered as normative loan as per the provisions of the Regulation 27 of the MYT Regulations 2019. The funding pattern of the proposed capitalisation is presented in the following table: Table 157: Funding Pattern of the Capitalisation for the Control Period S. No. 1 2 3 4 5 6 7 8 9 10 11 12 Particulars Funding pattern of capital expenditure Total Capital Expenditure Consumer Contribution Grants received during the year Equity Debt Funding pattern of capitalisation Total Capitalisation Consumer Contribution Grants received during the year Balance to be funded Equity amount Debt amount Equity (%) Debt (%) FY 2020-21 Projected FY 2021-22 Projected FY 2022-23 Projected FY 2023-24 Projected Rs. Cr. FY 2024-25 Projected 6,687.24 100.00 2,560.26 499.31 3,527.67 2,511.67 100.00 577.98 499.31 1,334.38 1,762.74 100.00 606.39 400.00 656.35 1,807.60 100.00 636.21 400.00 671.39 1,886.44 100.00 667.51 400.00 718.93 6,840.31 102.29 2,618.86 4,119.16 499.31 3,619.85 12% 88% 5,068.20 201.79 1,166.29 3,700.13 499.31 3,200.82 13% 87% 2,038.96 115.67 701.41 1,221.88 366.56 855.31 30% 70% 1,808.60 100.06 636.56 1,071.99 321.60 750.39 30% 70% 1,877.44 99.52 664.33 1,113.59 334.08 779.51 30% 70% 7.23.2 MSEDCL requests the Hon’ble Commission to approve the funding pattern as submitted in above table. 7.24 Depreciation for Control Period 7.24.1 MSEDCL submits that Regulation 28 of the MERC (MYT) Regulations, 2019 provides for recovery of Depreciation. As per Regulation 28.1(b) of MYT Regulation, the individual asset is to be depreciated to the extent of 70% on the straight line basis as per the rates specified in the Regulations and remaining depreciable value as on 31st March of the year closing shall be spread over the balance Useful Life of the asset. The relevant extract is reproduced below: MSEDCL January 20 147 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition (b) Depreciation shall be computed annually based on the straight line method at the rates specified in the Annexure I to these Regulations: Provided that the Generating Company or Licensee or MSLDC shall ensure that once the individual asset is depreciated to the extent of seventy percent, remaining depreciable value as on 31st March of the year closing shall be spread over the balance Useful Life of the asset including the Extended Life, as provided in this Regulation: 7.24.2 MSEDCL submits that depreciation has been calculated taking into consideration the opening balance of assets in the beginning of the year and the projected capitalization. Hon’ble Commission has been applying the weighted average rate of depreciation on opening GFA. Considering the actual weighted average rate of depreciation for FY 18-19, MSEDCL has computed the depreciation which is shown in the following table: Table 158: Depreciation for the Control Period Particulars Opening GFA Depreciation % Depreciation FY 2020-21 FY 2021-22 FY 2022-23 FY 2023-24 Projected Projected Projected Projected 55,675.32 59,904.48 63,719.61 65,061.48 2,756.88 2,966.30 3,155.21 3,221.66 4.95% 4.95% 4.95% 4.95% Rs. Cr. FY 2024-25 Projected 66,258.47 3,280.93 4.95% 7.24.3 MSEDCL requests the Hon’ble Commission to approve the depreciation as submitted in above table. 7.25 Interest on Long Term Loan for Control Period 7.25.1 MSEDCL submits that the interest expenditure on account of long-term loans depends on the outstanding loan, repayments, and prevailing interest rates on the outstanding loans. Further, the projected capital expenditure and the funding of the same also have a major bearing on the long-term interest expenditure. 7.25.2 Regulation 30.3 of the MYT Regulations 2019 states that MSEDCL January 20 148 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 30.3 The loan repayment during each year of the Control Period from FY 202021 to FY 2024-25 shall be deemed to be equal to the depreciation allowed for that year. 7.25.3 Considering the normative opening loan, normative loan addition during the year and loan repayment equal to depreciation and the weighted average interest rate of actual loan portfolio for FY 18-19 as shown in Table 66, MSEDCL has computed the interest expenses on normative basis for the Control Period as summarized in table below: Table 159: Interest Expenses on Long Term Loan for the Control Period Particulars Normative Outstanding Loan at beginning of the year Loan Drawal Loan Repayment Normative Outstanding Loan at the end of the year Interest Rate Gross Interest Expenses FY 2020-21 Projected FY 2021-22 Projected FY 2022-23 Projected FY 2023-24 Projected Rs. Cr. FY 2024-25 Projected 13,263.75 14,126.71 14,361.24 12,061.34 9,590.07 3,619.85 2,756.88 3,200.82 2,966.30 855.31 3,155.21 750.39 3,221.66 779.51 3,280.93 14,126.71 14,361.24 12,061.34 9,590.07 7,088.66 10.28% 1,407.20 10.28% 1,463.59 10.28% 1,357.48 10.28% 1,112.36 10.28% 856.88 7.25.4 MSEDCL requests the Hon’ble Commission to approve the interest expenses as submitted in above table. 7.26 Interest on Working Capital for Control Period 7.26.1 MSEDCL submits that Regulation 32 of the MYT Regulations 2019 provides for Interest on Working Capital. Regulation 32.3 (a) of the said Regulations provides for the norms of computation of Working Capital for Distribution Wires Business. 7.26.2 MSEDCL further submits that Regulation 32.3 (b) of the said Regulations provides that the normative rate of interest on working capital shall be equal to Base Rate as on the date on which the Petition for determination of Tariff is filed, plus 150 basis points. The relevant extract of the said Regulations is reproduced below: (b) Rate of interest on working capital shall be on normative basis and shall be MSEDCL January 20 149 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition equal to the Base Rate as on the date on which the Petition for determination of Tariff is filed, plus 150 basis points: 7.26.3 Accordingly, MSEDCL has calculated Interest on Working Capital for the control period @ 9.50% for Wires Business. 7.26.4 MSEDCL further submits that Regulation 30.11 of the MYT Regulations 2019 provides that the interest on security deposit shall be Bank Rate as on 1st April of the Year for which the interest is payable. The relevant extract of the said Regulations is reproduced below: 30.11 Interest shall be allowed only on the amount held in cash as security deposit from Transmission System Users, Distribution System Users and Retail consumers at the Bank Rate as on 1st April of the Year for which the interest is payable: 7.26.5 Accordingly, MSEDCL has calculated Interest on Security Deposit for the control period @ 6.50% for Wires Business. MSEDCL has projected the Security Deposit considering a growth of 5% per annum. 7.26.6 Detailed computation of Interest on Working Capital and Security Deposit for Wire Business is provided in the following table: Table 160: Interest on Working Capital and SD for Wires Business for the Control Period Particulars Computation of Working Capital Requirement O&M expenses for a month Maintenance Spares at 1% of Opening GFA One and half months equivalent of the expected revenue from charges for use of Distribution Wires Less: Amount held as Security Deposit from Distribution System Users Total Working Capital Requirement Computation of Working Capital Interest Interest Rate (%) - SBI Base Rate +150 basis points Interest on Working Capital Computation of Interest on Security Deposit Interest Rate (%) - Bank Rate Interest on Security Deposit MSEDCL Rs. Cr. FY 2024-25 Projected FY 2020-21 Projected FY 2021-22 Projected FY 2022-23 Projected FY 2023-24 Projected 378.02 530.83 392.51 593.38 407.55 640.03 423.17 659.46 439.39 676.86 1,292.24 1,355.82 1,397.71 1,408.14 1,417.19 (831.67) 1,369.42 (873.25) 1,468.46 (916.91) 1,528.38 (962.76) 1,528.01 (1,010.90) 1,522.55 9.50% 130.10 9.50% 139.50 9.50% 145.20 9.50% 145.16 9.50% 144.64 6.50% 54.06 6.50% 56.76 6.50% 59.60 6.50% 62.58 6.50% 65.71 January 20 150 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 7.26.7 MSEDCL requests the Hon’ble Commission to allow the Interest on Working capital along with the interest on security deposit for wires business as shown in above table. 7.26.8 MSEDCL submits that Regulation 32 of the MYT Regulations 2019 provides for Interest on Working Capital. Regulation 32.4 (a) of the said Regulations provides for the norms of computation of Working Capital for Retail Supply Business. 7.26.9 MSEDCL further submits that Regulation 32.3 (b) of the said Regulations provides that the normative rate of interest on working capital shall be equal to Base Rate as on the date on which the Petition for determination of Tariff is filed, plus 150 basis points. The relevant extract of the said Regulations is reproduced below: (b) Rate of interest on working capital shall be on normative basis and shall be equal to the Base Rate as on the date on which the Petition for determination of Tariff is filed, plus 150 basis points: 7.26.10 Accordingly, MSEDCL has calculated Interest on Working Capital for the control period @ 9.50% for Retail Supply Business. 7.26.11 MSEDCL further submits that Regulation 30.11 of the MYT Regulations 2019 provides that the interest on security deposit shall be Bank Rate as on 1st April of the Year for which the interest is payable. The relevant extract of the said Regulations is reproduced below: 30.11 Interest shall be allowed only on the amount held in cash as security deposit from Transmission System Users, Distribution System Users and Retail consumers at the Bank Rate as on 1st April of the Year for which the interest is payable: 7.26.12 Accordingly, MSEDCL has calculated Interest on Security Deposit for the control period @ 6.50% for Retail Supply Business. MSEDCL has projected the Security Deposit considering a growth of 5% per annum. 7.26.13 Detailed computation of Interest on Working Capital and Security MSEDCL January 20 151 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Deposit for Retail Supply Business is provided in the following table: Table 161: Interest on Working Capital and SD for Supply Business for the Control Period Particulars Computation of Working Capital Requirement O&M expenses for a month Maintenance Spares at 1% of Opening GFA One and half months equivalent of the expected revenue from sale of electricity including revenue from CSS and Additional Surcharge Less: Amount held as security deposit Less: One month equivalent of cost of power purchase, transmission charges and MSLDC Charges Total Working Capital Requirement Computation of Working Capital Interest Interest Rate (%) - SBI Base Rate +150 basis points Interest on Working Capital Interest on Security Deposit Interest Rate (%) - Bank Rate Interest on Security Deposit Rs. Cr. FY 2024-25 Projected FY 2020-21 Projected FY 2021-22 Projected FY 2022-23 Projected FY 2023-24 Projected 203.55 106.25 211.35 113.20 219.45 118.38 227.86 120.54 236.59 122.47 9,734.33 10,102.93 10,491.73 10,905.85 11,345.05 (7,485.02) (7,859.27) (8,252.23) (8,664.84) (9,098.09) (5,960.70) (5,853.95) (5,853.95) (6,521.85) (6,818.14) (3,401.59) (3,285.73) (3,276.61) (3,932.44) (4,212.12) 9.50% - 9.50% - 9.50% - 9.50% - 9.50% - 6.50% 486.53 6.50% 510.85 6.50% 536.40 6.50% 563.21 6.50% 591.38 7.26.14 MSEDCL requests the Hon’ble Commission to allow the Interest on Working capital along with the interest on security deposit for retail supply business as shown in above table. 7.27 Other Finance Charges for Control Period 7.27.1 MSEDCL submits that Regulation 30.8 of MYT Regulations, 2019 provides that the finance charges shall be allowed at the time of true-up. The relevant extract of the Regulations is reproduced below. “30.8 The finance charges incurred for obtaining loans from financial institutions for any Year shall be allowed by the Commission at the time of Truing-up, subject to prudence check.” 7.27.2 Therefore in line with the above regulations, MSEDCL is not projecting any finance charges for the control period and will claim the same during true-up of the respective years. 7.28 Provision for Bad Debts for Control Period 7.28.1 MSEDCL submits that Regulation 76 and 85 of the MYT Regulations, 2019 specifies that a provision for bad and doubtful debt may be allowed up to 1.5% MSEDCL January 20 152 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition of the amount shown as trade receivables or receivables from sale of electricity in the audited accounts of the distribution licensee duly allocated for wires and supply business. Further, the provision for bad and doubtful debts is allocated in ratio of 10% to Wires Business and 90% to Retail Supply Business. 7.28.2 .MSEDCL submits that for the projection of the receivables it has adopted the following approach: For interest part a y-o-y rise of 2% and 10% is taken for Non-AG and AG respectively, and for the principle part a y-o-y rise of 2% and 5% is taken for Non-AG and AG respectively. The projections for the control period is as shown below: Period upto 31.03.2021 ( Projected) upto 31.03.2022 ( Projected) upto 31.03.2023 ( Projected) upto 31.03.2024 ( Projected) upto 31.03.2025 ( Projected) MSEDCL Particulars Principle Interest Total (Rs. Crs) Non AG 12887.54 5681.51 18569.05 AG 23155.83 17714.30 40870.13 Total 36043.38 23395.81 59439.19 Non AG 13145.29 5795.14 18940.43 AG 24313.63 19485.73 43799.35 Total 37458.92 25280.87 62739.79 Non AG 13408.20 5911.05 19319.24 AG 25529.31 21434.30 46963.61 Total 38937.50 27345.35 66282.85 Non AG 13676.36 6029.27 19705.63 AG 26805.77 23577.73 50383.50 Total 40482.13 29607.00 70089.13 Non AG 13949.89 6149.85 20099.74 AG 28146.06 25935.50 54081.57 Total 42095.95 32085.36 74181.31 January 20 153 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 7.28.3 MSEDCL further submits that it will be writing off the provision of the bad debts approved for the year as per the provisions of the MYT Regulations. 7.28.4 MSEDCL has considered the provision for bad and doubtful debts as 1.5% of the projected receivables for the Control Period as given below: Table 162: Provision for Bad and Doubtful Debt for Wires Business for the Control Period Particulars Bad Debt Provision for Wire Business Receivables % of Receivables Rs. Cr. FY 2020-21 FY 2021-22 FY 2022-23 FY 2023-24 FY 2024-25 Projected Projected Projected Projected Projected 89.16 94.11 99.42 105.13 111.27 5,943.92 6,273.98 6,628.29 7,008.91 7,418.13 1.50% 1.50% 1.50% 1.50% 1.50% Table 163: Provision for Bad and Doubtful Debt for Supply Business for the Control Period Particulars Bad Debt Provision for Supply Business Receivables % of Receivables Rs. Cr. FY 2020-21 FY 2021-22 FY 2022-23 FY 2023-24 FY 2024-25 Projected Projected Projected Projected Projected 802.43 846.99 894.82 946.20 1,001.45 53,495.27 56,465.81 59,654.57 63,080.22 66,763.18 1.50% 1.50% 1.50% 1.50% 1.50% 7.28.5 MSEDCL requests the Hon’ble Commission to allow the provision for bad and doubtful debt as shown in above tables. 7.29 Other Expenses for Control Period 7.29.1 MSEDCL submits that the other expenses of MSEDCL comprise of the expenditure on account of interest to suppliers/contractors, rebate to consumers and other expenses viz. compensation for injuries to staff and outsiders. 7.29.2 Nature of Other expenses is summarised below Interest to Supplies / Contractors: This amount represents the interest expense on security deposits collected from collection agencies. Non-Moving items written off: These are items of stores which are lying as non-moving for 2 years the realizable value of which is nil. Incentive to distribution franchisee: This is the incentive given to the MSEDCL January 20 154 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition distribution franchisee for recovery of MSEDCL’s arrears from Live & PD Consumers. 7.29.3 The projections for the control period have been made on the basis of an annual 5% increase over the previous year. 7.29.4 Other Expenses projected for the Control Period is summarised in the following table. Table 164: Other Expenses for the Control Period Particulars Other Expenses FY 2020-21 Projected 52.58 FY 2021-22 Projected 55.21 FY 2022-23 Projected 57.97 FY 2023-24 Projected 60.87 Rs. Cr. FY 2024-25 Projected 63.91 7.29.5 The Detail break up of other expenses is given in the Form No. 6A of the Regulatory Formats. MSEDCL requests the Hon’ble Commission to allow the other expenses as submitted above. 7.30 Contribution to Contingency Reserves for Control Period 7.30.1 MSEDCL submits that Regulation 35.1 of MYT Regulations, 2019 provides for contribution to Contingency Reserve. The relevant extract of the Regulations is reproduced below: “35.1 Where the Licensee has made a contribution to the Contingency Reserve, a sum not less than 0.25 per cent and not more than 0.5 per cent of the original cost of fixed assets shall be allowed annually towards such contribution in the calculation of Aggregate Revenue Requirement: Provided that where the amount of such Contingency Reserves exceeds five (5) per cent of the original cost of fixed assets, no further contribution shall be allowed: Provided further that such contribution shall be invested in securities authorised under the Indian Trusts Act, 1882 within a period of six months of the close of the Year:……..” 7.30.2 Accordingly, MSEDCL has considered 0.25% of the Gross Fixed Assets (incl. MSEDCL January 20 155 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition consumer contribution and grants) and computed contribution to contingency reserve. 7.30.3 The expenses towards contribution to contingency reserve are allocated in ratio of fixed assets between wires and retail supply business. i. e. 90% to Wires Business and 10% to Supply Business. 7.30.4 The contribution to contingency reserve for the Control Period is summarised in following table. Table 165: Contribution to contingency reserve for the Control Period Particulars Contribution to Contingency Reserves (Wire Business) Contribution to Contingency Reserves (Supply Business) Total contribution to Contingency Reserves FY 2020-21 Projected 143.34 15.93 159.27 FY 2021-22 Projected 158.98 17.66 176.64 FY 2022-23 Projected 170.64 18.96 189.60 FY 2023-24 Projected 175.50 23.82 199.32 Rs. Cr. FY 2024-25 Projected 179.85 28.17 208.02 7.30.5 MSEDCL requests the Hon’ble Commission to allow the contribution to the contingency reserves as submitted above. 7.31 Incentives and Discounts for Control Period 7.31.1 MSEDCL submits that the Incentives and discounts are projected for the third control period considering a nominal rise of 5% over previous year. 7.31.2 The incentives and discounts for the Control Period is summarised in following table. Table 166: Incentives/Discounts for the Control Period Particulars Inentives/ Discounts FY 2020-21 Projected 322.38 FY 2021-22 Projected 338.50 FY 2022-23 Projected 355.43 FY 2023-24 Projected 373.20 Rs. Cr. FY 2024-25 Projected 391.86 7.31.3 MSEDCL requests the Hon’ble Commission to allow the incentives/discounts as submitted above. MSEDCL January 20 156 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 7.32 Income Tax for Control Period 7.32.1 MSEDCL submits that Regulation 34 of the MYT Regulations 2019 provides for the Income Tax. 34.1 The Income Tax for the Generating Company or Licensee or MSLDC for the regulated business shall be allowed on Return on Equity, including Additional Return on Equity through the Tariff charged to the Beneficiary/ies, subject to the conditions stipulated in Regulations 34.2 to 34.6:………….. 34.2 The rate of Return on Equity, including additional rate of Return on Equity as allowed by the Commission under Regulation 29 of these Regulations shall be grossed up with the effective tax rate of respective financial year. 34.3 The base rate of return on equity shall be rounded off to three decimal places and shall be computed as per the formula given below: Rate of pre-tax return on equity = Base rate of Return on Equity / (1-t), Where “t” is the effective tax rate 34.4 The effective tax rate shall be considered on the basis of actual tax paid in respect of financial year in line with the provisions of the relevant Finance Acts by the concerned Generating Company or Licensee or MSLDC, as the case may be: Provided that, in case of the Generating Company or Licensee or MSLDC has engaged in any other regulated or unregulated Business or Other Business, the actual tax paid on income from any other regulated or unregulated Business or Other Business shall be excluded for the calculation of effective tax rate: Provided further that effective tax rate shall be estimated for future year based on actual tax paid as per latest available Audited accounts, subject to prudence check. 34.5 In case of Generating Company or Licensee or MSLDC paying Minimum Alternate Tax (MAT), “t” shall be considered as MAT rate including surcharge and cess: MSEDCL January 20 157 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Illustration:(a) In case of a Generating Company or Licensee or MSLDC paying Minimum Alternate Tax (MAT) at rate of 21.55% including surcharge and cess: Base rate of return on equity = 15.50/(1-0.2155) = 19.758% (b) In case of Generating Company or Licensee or MSLDC paying normal corporate tax including surcharge and cess: (i) Estimated Gross Income of Company as a whole for FY 2020-21 is Rs. 1,000 crore; (ii) Income Tax for the year on above is Rs 240 crore; (iii) Effective Tax Rate for the year 2019-20 = Rs 240 Crore/Rs 1000 Crore = 24%; (iv)Base rate of return on equity = 15.50/ (1-0.24) = 20.395%. 34.6 Variation between the Income Tax estimated by the Commission for future year during MYT Order and Mid Term Review Order and the Income Tax approved by the Commission for the respective Year after truing up for respective year, shall be allowed for recovery as part of the Aggregate Revenue Requirement at the time of Mid-term Review or Truing-up, subject to prudence check:…………….” 7.32.2 MSEDCL submits that even though it has paid Income Tax in FY 18-19, it may not pay the Income Tax during the Control Period. Hence, it has not grossed up the return on equity by income tax. However, MSEDCL reserves its rights for claiming the Income Tax on actual basis during the Mid Term Review. 7.33 Return on Equity for Control Period 7.33.1 MSEDCL submits that Regulation 29.1 of MYT Regulations, 2019, provides for Return on Equity (RoE) for Distribution Licensee for both Wire and Supply Business which is reproduced as under: “29.1 Return on Equity for the Generating Company, Transmission Licensee, Distribution Wires Business and MSLDC shall be allowed on the equity capital determined in accordance with Regulation 27 for the assets put to use, at the rate of up to 15.5 per cent per annum in Indian Rupee terms, and for the Retail Supply Business, Return on Equity shall be allowed on the amount of equity MSEDCL January 20 158 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition capital determined in accordance with Regulation 27 at the rate of up to 17.5 per cent per annum in Indian Rupee terms: ……….” 7.33.2 The methodology to compute return on equity is provided in Regulation 29.3 and the same is reproduced below. “29.3 The Base Return on Equity shall be computed in the following manner: (a) Return at the allowable rate as per this Regulation, applied on the amount of equity capital at the commencement of the Year; plus (b) Return at the allowable rate as per this Regulation, applied on 50 per cent of the equity capital portion of the allowable capital cost, for the investments put to use in Generation Business or Transmission Business or Distribution Business or MSLDC, for such Year: ………….” 7.33.3 Considering the funding pattern at Table 157, MSEDCL has considered the equity addition during the year. 7.33.4 MSEDCL submits that the return on equity capital is allocated in the ratio of Fixed Assets between the Wires and Retail Supply Business, i.e. 90% to Wires Business and 10% to Supply Business. Therefore, the capital expenditure, grants, equity and capitalisation is divided into wires and supply business in the ratio of 90:10. 7.33.5 MSEDCL submits that in Form 4.4 of the Regulatory Formats, MSEDCL has shown the details of year wise funding for various schemes wherein the debt: equity portion is arranged. However, there can be few capital works which can be funded by consumers through consumer contribution which are reconciled at the time of finalization of accounts. MSEDCL submits that it will be difficult to project and allocate the consumer contribution to any particular scheme. Therefore, MSEDCL has not shown the consumer contribution in Form 4.4. However, for the purpose of computation of RoE, MSEDCL has projected the consumer contribution based on actual contribution, past experience and projected capital expenditure. 7.33.6 The return on equity has been computed as per the methodology specified in MSEDCL January 20 159 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition the MYT Regulations 2019. 7.33.7 Accordingly, the RoE for wires business for the Control Period is projected as under: Table 167: ROE for wires business for the Control Period Particulars Regulatory Equity at the beginning of the year Capitalisation during the year $ Equity portion of capitalisation during the year Reduction in Equity Capital on account of retirement / replacement of assets Regulatory Equity at the end of the year Return on Equity Computation Base Rate of Return on Equity Return on Regulatory Equity at the beginning of the year Return on Regulatory Equity addition during the year Interest on Equity portion above 30% Total Return on Equity FY 2020-21 Projected 10,848.57 3,707.24 449.38 FY 2021-22 Projected 11,297.95 3,330.12 449.38 - - FY 2022-23 Projected 11,747.33 1,099.69 329.91 - FY 2023-24 Projected 12,077.24 964.79 289.44 - Rs. Cr. FY 2024-25 Projected 12,366.67 1,002.23 300.67 - 11,297.95 11,747.33 12,077.24 12,366.67 12,667.34 14.00% 1,518.80 31.46 1,550.26 14.00% 1,581.71 31.46 1,613.17 14.00% 1,644.63 23.09 1,667.72 14.00% 1,690.81 20.26 1,711.07 14.00% 1,731.33 21.05 1,752.38 7.33.8 Further the RoE for retail supply business for the Control Period is projected as under: Table 168: ROE for Retail Supply business for the Control Period FY 2020-21 Projected 1,173.03 411.92 49.93 FY 2021-22 Projected 1,222.96 370.01 49.93 FY 2022-23 Projected 1,272.89 122.19 36.66 FY 2023-24 Projected 1,309.55 107.20 32.16 Rs. Cr. FY 2024-25 Projected 1,341.71 111.36 33.41 1,222.96 1,272.89 1,309.55 1,341.71 1,375.11 Return on Equity Computation Base Rate of Return on Equity 15.50% 15.50% 15.50% 15.50% 15.50% Pretax Return on Equity after considering effective Tax rate 15.50% 15.50% 15.50% 15.50% 15.50% Return on Regulatory Equity at the beginning of the year Return on Regulatory Equity addition during the year Interest on Equity portion above 30% Total Return on Equity 181.82 3.87 185.69 189.56 3.87 193.43 197.30 2.84 200.14 202.98 2.49 205.47 207.96 2.59 210.55 Particulars Regulatory Equity at the beginning of the year Capitalisation during the year $ Equity portion of capitalisation during the year Reduction in Equity Capital on account of retirement / replacement of assets Regulatory Equity at the end of the year 7.33.9 MSEDCL requests the Hon’ble Commission to approve the return on equity for wheeling and supply business as projected in above tables. MSEDCL January 20 160 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 7.34 Impact of payment to MPECS in Control Period 7.34.1 MSEDCL submits that in its Order dated 2nd May, 2016 in Case No. 24 of 2012 on the determination of charges payable to Mula Pravara Electric Co-operative Society (MPECS) by MSEDCL in pursuance of ATE‟s Judgment in Appeal No. 221 of 2014, Hon’ble Commission has directed MSEDCL to pay user charges to MPECS. MSEDCL submits that vide its Order dated 2nd May 2016, the Hon’ble Commission has determined the monthly user charges (Annexure B of the said Order) to be paid to MPECS. MSEDCL has considered the same. The following table summarises the payments to be paid to MPECS during the Control Period. Table 169: Impact of payment to MPECS in Control Period Particulars Impact of Payment to MPECS FY 2020-21 Projected 37.16 FY 2021-22 Projected 34.15 FY 2022-23 Projected 31.14 FY 2023-24 Projected 28.13 Rs. Cr. FY 2024-25 Projected 21.14 7.34.2 MSEDCL requests the Hon’ble Commission to allow the impact of payment to MPECS in Control Period as submitted above. 7.34.3 MSEDCL further submits that the MPECS has arrears of Rs.2397.13 Crs which are payable to MSEDCL. The litigations regarding Tariff, Recovery and Asset valuation related matters are pending before various judicial Authorities at this stage. 7.35 Revenue from sale of electricity for Control Period 7.35.1 MSEDCL has considered the projected sales, no. of consumers and connected load/contract/Billing demand for the Control Period and tariff prevailing as on date of submission of the Petition. 7.35.2 Year wise Revenue for the Control Period is summarised in the following table. Table 170: Revenue from Sale of Power at Existing Tariff for the Control Period Particulars Revenue from Sale of Power at Existing Tariff Rs. Cr. FY 2020-21 FY 2021-22 FY 2022-23 FY 2023-24 FY 2024-25 Projected Projected Projected Projected Projected 76,997.55 79,927.39 83,017.87 86,309.90 89,801.46 7.35.3 MSEDCL requests the Hon’ble Commission to allow the revenue from sale of MSEDCL January 20 161 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition power at existing tariff for the Control Period. 7.36 Non-Tariff Income for Control Period 7.36.1 MSEDCL has certain sources of non-tariff income viz. interest on arrears of consumers, interest on staff loans and advances, sale of scrap, interest on investment etc. Annual increase of 5% over previous year is considered for the heads covered under non-tariff income. 7.36.2 However, Regulation 36.3 of the MERC MYT Regulations, 2015 provides for non-inclusion of the Delayed Payment Charge and Interest on Delayed Payment in Non-Tariff Income. The relevant Regulation is reproduced below for reference: 36.3 Such Delayed Payment Charge and Interest on Delayed Payment earned by the Generating Company or the Licensee shall not be considered under its Non-Tariff Income. 7.36.3 Accordingly, MSEDCL has not projected any Delayed Payment Charge and Interest on Delayed Payment in Non-Tariff Income. MSEDCL further has not projected the deferred income since the consumer contribution and grants is being getting subtracted from opening GFA. 7.36.4 Following table shows the projected non-tariff income for the control period FY 2016-17 to 2019-20. Table 171: Non-Tariff Income for the Control Period Particulars Rents of land or buildings Sale of Scrap Income from investments Income from sale of tender documents Prompt payment discount from REC/PFC Other/Miscellaneous receipts Total FY 2020-21 Projected 1.09 54.65 19.43 9.37 12.77 282.45 379.75 FY 2021-22 Projected 1.14 57.39 20.40 9.83 13.41 296.57 398.73 FY 2022-23 Projected 1.20 60.25 21.42 10.33 14.08 311.40 418.67 FY 2023-24 Projected 1.26 63.27 22.49 10.84 14.78 326.97 439.60 Rs. Cr. FY 2024-25 Projected 1.32 66.43 23.61 11.38 15.52 343.32 461.59 7.36.5 MSEDCL requests the Hon’ble Commission to approve the Non-Tariff Income as per above projections. MSEDCL January 20 162 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 7.37 Income from Open Access Charges for Control Period 7.37.1 MSEDCL submits that the income from Open Access Charges (including CSS, Transmission Charges, Operating Charges etc.) which is inclusive of the income from Wheeling charges has been estimated at current level (audited for FY 18-19) without any escalation. The following table summarises the income from Open Access Charges for the Control Period. Table 172: Income from Open Access Charges for the Control Period Particulars Income from Open Access Charges FY 2020-21 Projected 388.89 FY 2021-22 Projected 388.89 FY 2022-23 Projected 388.89 FY 2023-24 Projected 388.89 Rs. Cr. FY 2024-25 Projected 388.89 7.37.2 MSEDCL requests the Hon’ble Commission to approve the income from open access charges as per above projections. 7.38 Income from Additional Surcharge for Control Period 7.38.1 The income from additional surcharge has been estimated at current level (audited for FY 181-9) without any escalation. The summary of projected income for the Control Period is summarised in following table: Table 173: Income from Additional Surcharge for the Control Period Particulars Income from Additional Surcharge Rs. Cr. FY 2020-21 FY 2021-22 FY 2022-23 FY 2023-24 FY 2024-25 Projected Projected Projected Projected Projected 108.44 108.44 108.44 108.44 108.44 7.38.2 MSEDCL requests the Hon’ble Commission to approve the income from Additional Surcharge as per above projections. 7.39 Aggregate Revenue Requirement for Control Period 7.39.1 Based on the parameters discussed above, the Aggregate Revenue Requirement for the Control Period for Wire Business is summarised in following Table: MSEDCL January 20 163 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 174: ARR for Wires Business for the Control Period Particulars Operation & Maintenance Expenses Depreciation Interest on Loan Capital Interest on Working Capital Interest on deposit from Consumers and Distribution System Users Provision for bad and doubtful debts Opex Schemes Contribution to contingency reserves Return on Equity Capital Aggregate Revenue Requirement FY 2023-24 Projected 5,078.04 2,899.49 1,001.12 145.16 Rs. Cr. FY 2024-25 Projected 5,272.64 2,952.83 771.19 144.64 FY 2020-21 Projected 4,536.29 2,481.19 1,266.48 130.10 FY 2021-22 Projected 4,710.13 2,669.67 1,317.23 139.50 FY 2022-23 Projected 4,890.63 2,839.69 1,221.73 145.20 54.06 56.76 59.60 62.58 65.71 89.16 87.03 143.34 1,550.26 10,337.91 94.11 87.03 158.98 1,613.17 10,846.58 99.42 87.03 170.64 1,667.72 11,181.66 105.13 87.03 175.50 1,711.07 11,265.13 111.27 87.03 179.85 1,752.38 11,337.55 7.39.2 The Aggregate Revenue Requirement for the Control Period for Supply Business is summarised in the following table: Table 175: ARR for Supply Business for the Control Period Particulars Power Purchase Expenses (including InterState Transmission Charges) Operation & Maintenance Expenses Depreciation Interest on Loan Capital Interest on Consumer Security Deposit Provision for bad and doubtful debts Other Expenses Intra-State Transmission Charges Incentives/Discounts Contribution to contingency reserves Return on Equity Capital Impact of payment to MPECS in future years Opex Scheme Total Revenue Expenditure FY 2020-21 Projected FY 2021-22 Projected FY 2022-23 Projected FY 2023-24 Projected Rs. Cr. FY 2024-25 Projected 61,234.57 63,894.79 67,455.81 70,917.81 73,817.97 2,442.62 275.69 140.72 486.53 802.43 52.58 10,293.78 322.38 15.93 185.69 37.16 30.18 76,320.25 2,536.22 296.63 146.36 510.85 846.99 55.21 6,352.56 338.50 17.66 193.43 34.15 30.37 75,253.72 2,633.42 315.52 135.75 536.40 894.82 57.97 6,715.36 355.43 18.96 200.14 31.14 30.59 79,381.29 2,734.33 322.17 111.24 563.21 946.20 60.87 7,344.34 373.20 23.82 205.47 28.13 30.85 83,661.63 2,839.12 328.09 85.69 591.38 1,001.45 63.91 7,999.76 391.86 28.17 210.55 21.14 31.14 87,410.22 7.39.3 Based on the Wire and Supply Business ARR discussed above, the stand alone Revenue gap (combined for wires and supply) for Control Period is summarised in following Table: MSEDCL January 20 164 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 176: Combined ARR for Supply and Wires Business for the Control Period Particulars Power Purchase Expenses Operation & Maintenance Expenses Depreciation Expenses Interest on Loan Capital Interest on Working Capital Interest on Consumers Security Deposit Provision for bad and doubtful debts Other Expenses Intra-State Transmission Charges MSLDC charge Incentives/Discounts Contribution to Contingency Reserves Opex Scheme Return on Equity Capital Add: Impact of payment to MPECS in future years Aggregate Revenue Requirement Revenue from Sale of Power Non-Tariff Income Income from Open Access Charges Income from Additional Surcharge Total Revenue Revenue Gap/(Surplus) FY 2020-21 Projected 61,234.57 6,978.91 2,756.88 1,407.20 130.10 540.58 891.59 52.58 10,293.78 322.38 159.27 117.21 1,735.95 37.16 86,658.16 76,997.55 379.75 388.89 108.44 77,874.63 8,783.54 FY 2021-22 Projected 63,894.79 7,246.35 2,966.30 1,463.59 139.50 567.61 941.10 55.21 6,352.56 338.50 176.64 117.40 1,806.60 34.15 86,100.30 79,927.39 398.73 388.89 108.44 80,823.46 5,276.84 FY 2022-23 Projected 67,455.81 7,524.04 3,155.21 1,357.48 145.20 595.99 994.24 57.97 6,715.36 355.43 189.60 117.62 1,867.86 31.14 90,562.95 83,017.87 418.67 388.89 108.44 83,933.87 6,629.08 FY 2023-24 Projected 70,917.81 7,812.38 3,221.66 1,112.36 145.16 625.79 1,051.34 60.87 7,344.34 373.20 199.32 117.88 1,916.55 28.13 94,926.77 86,309.90 439.60 388.89 108.44 87,246.84 7,679.93 Rs. Cr. FY 2024-25 Projected 73,817.97 8,111.76 3,280.93 856.88 144.64 657.08 1,112.72 63.91 7,999.76 391.86 208.02 118.17 1,962.93 21.14 98,747.77 89,801.46 461.59 388.89 108.44 90,760.38 7,987.39 7.39.4 MSEDCL requests the Hon’ble Commission to allow the expenditure and revenue gap as shown in the above table. MSEDCL January 20 165 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 8 8.1 ADDITIONAL CLAIMS AND NET RECOVERY FROM TARIFF Impact of Reinstatement of GFA of Rs. 927 Crs 8.1.1 MSEDCL submits that in MTR Petition, it had submitted the reconciliation of GFA and requested the Hon’ble Commission to approve an additional/ difference amount of Rs. 1135 Crore in the opening GFA of FY 2015-16. The Hon’ble Commission in the MTR Order dated 12th September 2018 has approved Rs. 927 Crore against Rs. 1135 Crore claimed. 8.1.2 In the said Order, Hon’ble Commission had ruled that the capitalisation is allowable and has to be added in the GFA. Hon’ble Commission in the said Order also ruled that any consequent changes on account of the same in future years as mentioned in the Order cannot still be allowed as no such computation or workings has been provided by MSEDCL. 8.1.3 Therefore, MSEDCL has computed the impact of reinstatement of GFA of Rs. 927 Crore in Chapter 3. The net impact of reinstatement of GFA is summarized in following table. Table 177: Net Impact of Reinstatement of GFA of Rs. 927 Crs Financial Year Depreciation Interest on Loan FY 2008-09 32.36 55.94 FY 2009-10 33.41 51.60 FY 2010-11 34.66 48.10 FY 2011-12 46.51 FY 2012-13 44.71 FY 2013-14 46.71 41.06 FY 2014-15 18.39 37.00 FY 2015-16 35.88 FY 2016-17 0.04 39.18 Grand Total 165.57 399.99 Rs. Crs Return on Equity Total 9.48 97.78 9.42 94.44 9.43 92.19 9.43 55.95 9.46 54.17 9.30 97.07 9.06 64.45 (12.02) 23.86 (12.56) 26.65 40.99 606.55 8.1.4 MSEDCL requests the Hon’ble Commission to allow the impact of reinstatement of GFA as computed above. MSEDCL January 20 166 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 8.2 Impact of capitalisation of DPDC for FY 16-17 in MTR Order 8.2.1 Considering the provision of Regulation 23.6 of MYT Regulation 2015, Hon’ble Commission allowed capitalisation towards non-DPR schemes only up to threshold level. 8.2.2 However, subsequently, MSEDCL submitted the DPR for DPDC for the approval of the Hon’ble Commission. Hon’ble Commission accorded its post facto approval vide Letter No. MERC/Capex/2019-20/1108 dated 28th Nov. 2019. Accordingly, MSEDCL requests the Hon’ble Commission to consider the DPDC in DPR Schemes FY 16-17 onwards and allow the impact of the same disallowed in FY 16-17 as shown in following table. Table 178: Impact of DPDC Disallowance for FY 16-17 Rs. Crs Particulars Approved Total DPR Allowed in MTR Add: Capitalisation for DPDC Schemes Revised Total DPR Allowed Total Excess Capitalisation in the year 2,110.39 300.69 2,110.39 423.22 2,533.61 300.69 50% of IDC of excess capitalisation Net DPR Allowed after adjusting IDC of Excess capitalisation 1.31 2,109.08 1.31 2,532.30 Allowable non-DPR capitalisation (considering 20% cap) Total Non-DPR Grant schemes 421.82 1,195.05 506.46 771.83 Net Non-DPR capitalisation approved Total (DPR+non-DPR Capitalisation) for loan & Equity 421.82 2,530.89 506.46 3,038.76 58.38 58.38 2,589.27 3,097.14 Capitalization-Other Assets Net Capitalisation allowed (for depreciation) Revised Impact to be claimed 507.86 8.2.3 Considering the above, MSEDCL has revised the Opening GFA of FY 17-18 to the extent of impact of capitalisation of DPDC as shown in the above table. 8.3 Impact of Review Order 8.3.1 MSEDCL submits that on 29th October 2019, it has filed Petition for review of certain aspects of the Mid Term Review (MTR) Order dated 12 September, MSEDCL January 20 167 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 2018 in Case No.195 of 2017. Hon’ble Commission disposed of the said Petition vide its Order dated 24th December 2018 and partly allowed certain contentions of MSEDCL. MSEDCL further submits that the impact of said Order is considered in the following paragraphs. 8.3.2 Calculation of normative O&M Expenses for FY 15-16: Hon’ble Commission in its Order dated 24th December 2018 ruled that for the computation of normative O&M Expenses for FY 2015-16, opening GFA had been considered as Rs. 39,641 Crore thereby not included Rs. 927 Crore in the opening GFA. This was an error apparent from the face of record while considering the GFA for working out such normative expense. MSEDCL in Paragraph 2.2 above has computed the revised O&M Expenses for FY 15-16. The impact of revised O&M Expenses for FY 15-16 and FY 16-17 is summarised in following table. Table 179: Impact of Revised O&M Expenses for FY 15-16 and FY 16-17 Rs. Crs Particulars O&M Expenses for FY 15-16 Approved in MTR Order Now Revised Impact passed on to ARR O&M Expenses for FY 16-17 Approved in MTR Order Now Revised Impact passed on to ARR 2/3 of 1/3 of Net Efficiency Efficiency Entitlement gains/Losses Gains/Losses after sharing Actual Gains/ (Loss) 6,792.34 6,826.16 5,417.68 5,417.68 1,374.66 1,408.48 916.44 938.99 458.22 469.49 6,334.12 6,356.66 22.54 6,654.74 6,678.07 5,796.69 5,796.69 858.05 881.38 572.04 587.59 286.02 293.79 6,082.71 6,090.48 7.78 Normative 8.3.3 Correction in Distribution Loss of FY 2016-17: Hon’ble Commission in its Order dated 24th December 2018 ruled that as the input at T< >D periphery was metered, it needed to be maintained as it was. Replacing such metered value by a derived number was not appropriate. Hence, it was an error apparent from the face of records. Hence, Hon’ble Commission revised the input at T< >D periphery for FY 2016-17 to 116300 MU based on metered energy. This lead to revision in Distribution Loss to 15.33% from 15.95% approved in impugned MTR Order. Accordingly, Hon’ble Commission ruled that impact of Rs. 178 crore on sharing of loss needs to be MSEDCL January 20 168 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition allowed to MSEDCL. MSEDCL has computed the impact of correction in Distribution Loss for FY 2016-17. Table 180: Impact of Correction in Distribution Loss for FY 2016-17 Units Particulars Impact to Now be passed Approved Revised on to ARR MTR Approved Distribution Loss Trajectory MYT approved Loss Trajectory Sales Excl. EHV sales EHV Sales Total Sales Intra STS loss (Approved) Power Requirement at Ex-Bus Periphery (Actual) % % MU MU MU % MU 15.33% 15.95% 13.50% 13.50% 86,252 86,252 5,480 5,480 91,732 91,732 3.63% 3.63% 1,12,171 1,11,392 Power Requirement at Ex-Bus Periphery (Normative) MU 1,09,155 1,09,155 MU 3,016 2,236 Rs/ kWh 3.43 3.43 Rs. Crore 1,035 767 Rs. Crore Rs. Crore 689.90 344.95 511.54 255.77 Additional/ (lower) Power purchase due to higher distribution loss Marginal Variable Cost of Power Purchase Additional Power purchase Cost due to higher distribution loss Efficiency Loss to be retained by MSEDCL Efficiency Loss to be borne by the consumers 178.36 8.3.4 Loss of obsolescence of fixed assets for FY 15-16: Hon’ble Commission in its Order dated 24th December 2018 ruled that for FY 15-16, it had not approved Rs. 8 Crore on account of “loss of obsolescence of fixed assets and on account of natural calamities.” However, In MYT Order dated 3 November, 2016, the Hon’ble Commission had allowed such expenses. Hence, Hon’ble Commission accepted that it was an error apparent from the face of records, and therefore, ruled that other expenses of Rs. 8 Crore needed to be allowed. 8.3.5 MSEDCL requests the Hon’ble Commission to allow the impact of Review Order as computed above. MSEDCL January 20 169 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 181: Total Impact of Review Order Particulars Impact of O&M Expenses for FY 15-16 and FY 16-17 Correction in Distribution Loss for FY 2016-17 Loss of obsolescence of fixed assets for FY 15-16 Total Impact of Review Order Amount in Rs. Crs 30.32 178.36 8.00 216.68 8.3.6 MSEDCL is submitting the above impact of Review Order without prejudice to any of its rights and contentions taken by MSEDCL in Appeal No. 280 of 2019 before the Hon’ble APTEL, New Delhi and MSEDCL reserves its right to again approach the Hon’ble Commission depending upon the final decision of Hon’ble APTEL, New Delhi in said Appeal. 8.4 Impact of Change in Law in Power Purchase 8.4.1 MSEDCL submits that the Supreme Court in the Energy Watchdog matter in Civil Appeal No. 5399-5400 vide its Judgement dated 11.04.2017 ruled that NCDP 2013 is a ”Change in Law’ and further elaborated that the party affected due to the Change in law be restituted to its’ same economical position. In line with this order, Hon’ble Commission has passed Orders in following matters in respect of M/s. APML for approval of various claims under change in Law. S.No. 1 Subject Matter SHAKTI i.e. 4 years policy Change In Law 3 Case No. Date of order NCDP policy as Change June 2013 to 31.03.2017 189 of 2013 and 07.03.2018 in law 2 The period of Impact 140 of 2014 as Since 01.04.2017 to Till 290 of 2018 07.02.2019 date i.e. 2.5 years Cancellation of Lohara From Date of 68 of 2012 06.09.2019 Coal Block as Change in commissioning till date 4 Law i.e. 5 years Carrying Cost June 2013 to 31.03.2017 295 of 2018 18.12.2018 i.e. 4 years MSEDCL January 20 170 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 8.4.2 Hon’ble commission in the above orders has allowed NCDP policy, SHAKTI policy, Cancellation of Lohara Coal Block as a Change in Law and has allowed relief to M/s. APML for past period from 2013. These Orders are passed over a period of last 1.5 years. Subsequent to the Orders of Hon’ble Commission, M/s. APML has raised claims in the respective matters. The details of claims are as follows: Change In Law Event Claim Type NCDP Policy Main Bill 3,094.00 Carrying Cost 1,442.88 Main Bill 2,451.05 SHAKTI Policy Carrying Cost Cancellation Lohara Coal Block Claims in Rs. Cr. 242.70 Main Bill 3,280.61 Carrying Cost 2,406.00 Total 12,917.24 8.4.3 MSEDCL has principally challenged MERC order dated 07.02.2019 in Case No. 290 of 2018 (SHAKTI) and MERC order dated 06.09.2019 in Case No. 68 of 2012 (Lohara Coal Block) before APTEL. APML has challenged MERC orders dated 07.03.2018 in Case No. 189 of 2013 and Case No. 140 of 2014, order dated 07.02.2019 in Case No. 290 of 2018 demanding consideration of operational parameters such as normative SHR and GCV on as received basis along with compensation for 100 % shortfall. APML has also challenged order dated 06.09.2019 in Case No. 68 of 2019 before APTEL. 8.4.4 Further, regarding Inter Plant Transfer (IPT) of coal, i.e. utilization of linkage coal of APL, Mundra to APML, Tiroda, Hon’ble CERC has also issued order dated 31.05.2018 in Petition No.97/MP/2017 and order dated 08.07.2019 in Petition no.269/MP/2018 and has ruled that supply of coal under the FSA shall remain unchanged for the commercial purpose and shall be on account of the original Power Plant. MSEDCL January 20 171 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 8.4.5 As the above mentioned matters are sub-judice, at this stage exact amount of payment to be made against the above claims is not finalised. Further, APTEL has not granted any stay on these orders. Hence, at present MSEDCL is liable for payment. 8.4.6 In similar developments, Rajasthan Electricity Regulatory Commission (RERC) vide order dated 17.05.2018 allowed NCDP 2013 as a change in Law to M/s. Adani Rajasthan. Rajasthan Discom had filed appeal before APTEL and APTEL by interim order in Appeal No. 202 of 2018 passed the directives to Rajasthan Discoms to make payment of 70% of the compensation claims to M/s. Adani Rajasthan. Rajasthan Discoms had filed a Civil appeal against APTEL Judgement before Hon’ble Supreme Court bearing no. 10188 / 2018. Hon'ble Supreme Court passed the order dated 29.10.2018 and directed Rajasthan Discoms to make payment of 50% of claim payments to M/s. APRL within two months from the date of order. Further, recently on 14.9.2019 APTEL has issued final Judgement in Appeal No. 202 of 2018 and allowed NCDP and Shakti Policy as Change in Law and also directed Rajasthan Discoms to pay the balance claims to M/s. APRL within 2 and 3 months respectively. 8.4.7 As per present regulations, MSEDCL recover claims of Change in Law and Carrying cost from consumers through FAC. In line with Hon'ble Supreme Court order in case no 10188 of 2018 dtd.29.10.2018, MSEDCL has made partial payment towards claims and carrying cost amounting to Rs. 2266 Crore in respect of claims raised by M/s APML by recovering the amount through FAC to avoid carrying cost burden and contempt of court order. 8.4.8 However in line with Hon'ble Supreme Court order for Rajasthan Discoms to make payment of 50% of claim and considering the paid amount of Rs.2266 Crore, MSEDCL is liable to pay amount of Rs. 4192 Crore to avoid the carrying cost impact and contempt of Court Order. 8.4.9 Similarly, M/s. GMR had filed the Petition No. 8/MP/2014 before CERC. CERC issued the Order on 01.02.2017 and disallowed compensation on certain change in law events claimed by the M/s. GMR. Aggrieved by the decision of MSEDCL January 20 172 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition the Commission, M/s. GMR filed appeal A. No. 111 of 2017 before APTEL. APTEL vide its order dated 14.8.2018, remanded back the matter to CERC to pass consequential orders regarding Busy Season Surcharge, Development Surcharge, MOEF Notification on coal quality, change in NCDP and Carrying Cost. 8.4.10 Meanwhile, GMR had also filed a fresh Petition No. 284/MP/2018 whereby GMR included all its previous disallowed Change in Law along with fresh claim regarding SHAKTI Policy with a prayer of declaration of the same as a change in law event. CERC issued Order on 16.05.2019 and has allowed all the claims considering SHR as per CERC regulation and GCV on as received basis. MSEDCL has filed appeal on 26.07.2019 (bearing DFR No. 2221 of 2019) against CERC Order dated 16.05.2019 before APTEL. However, there is no stay on the Order. 8.4.11 M/s GMR Warora Energy has raised change in law bills of Rs. 162.68 Crore and details of bills are given in following table. Description GMR Claim in Rs. Cr. Coal Shortfall May14 to Aug19 74.62 BSS & DS May14 to June18 35.37 Carrying cost 40.46 Late Payment Surcharge 12.23 Total 162.68 8.4.12 APTEL, during the hearing on 23.10.2019 directed to release 50% of payment of total claim by GMR after adjusting payments made within one week. Accordingly, MSEDCL has made payment of Rs. 81.34 Crores (i.e. 50 % of claim made by GMR). 8.4.13 Hence, it is submitted that balance amount of Rs. 4192 Crore to be paid is added to the revenue gap for the Control Period. MSEDCL also submits that the Appeals against above Orders on different grounds are pending at MSEDCL January 20 173 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Appellate Authority and whenever above Appeals get finality in the respective courts and the Court issues Orders in the above matter of change in law for NCDP policy, SHAKTI policy, Lohara Coal Block etc., MSEDCL shall pass on or recover such impact through FAC mechanism from consumers. 8.5 Carrying Cost on previous Gap and other Claims 8.5.1 Hon’ble Commission has been allowing carrying cost/holding cost on the revenue gap/surplus respectively. MSEDCL requests the Hon’ble Commission to allow the carrying cost on the previous gaps. 8.5.2 MSEDCL further submits that the APTEL, New Delhi in its Judgement dated 8th April, 2015 in the matter of Reliance Infrastructure Limited Vs MERC and others, the APTEL has ruled that the carrying cost should be calculated for the period from the middle of the financial year in which the revenue gap had occurred upto the middle of the financial year in which the recovery has been proposed. This is because the expenditure is incurred throughout the year and its recovery is also spread out throughout the year. 8.5.3 The revenue gap is determined at the end of the financial year in which the expenditure is incurred. However, the under or over recovery is the resultant of the cost and revenue spread out throughout the year. Similarly, the revenue gap of the past year is recovered throughout the year in which its recovery is allowed. Therefore, the carrying cost on revenue gap as a result of true up for a financial year should be calculated from the mid of that year till the middle of the year in which such revenue gap is allowed to be recovered. 8.5.4 MSEDCL requests the Hon’ble Commission to allow the carrying cost on same principle so as to avoid any legitimate revenue loss. 8.5.5 MSEDCL submits that the Hon’ble Commission in its MTR Order approved total revenue gap of Rs. 20,651 Crs. However, recovery of only Rs. 8,268 Crs was allowed over a period of two years. Hon’ble Commission created Regulatory Assets of Rs. 12,382 Crs. Hon’ble Commission directed MSEDCL, that at the time of next ARR/Tariff filling process for final true-up of ARR of 3rd Control Period , MSEDCL should submit its proposal for planned recovery of Regulatory MSEDCL January 20 174 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Asset along with carrying cost for the ensuing years in the next Control Period, so that recovery of such Regulatory Asset and adjustment of on account of final true up of Revenue Gap/(Surplus) (if any) shall not exceed for the period of two years beyond the current Control Period (i.e. 3rd Control Period). 8.5.6 MSEDCL submits that the details of carrying cost on the regulatory assets, revenue gap of FY 2016-17 to FY 2019-20 along with the additional claims is given in following table. The Interest Rate is taken as per the rate on Interest on Working Capital for the respective year. MSEDCL January 20 175 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 182: Calculation of carrying cost on previous claims Particulars Impact of Reinstatement of GFA Impact of Review Order Revenue Gap Regulatory Assets Total Interest Rate From To FY 08-09 97.78 FY 09-10 94.44 FY 10-11 92.19 FY 11-12 55.95 FY 12-13 54.17 FY 13-14 97.07 FY 14-15 64.45 FY 15-16 23.86 30.54 FY 16-17 26.65 186.14 FY 17-18 FY 18-19 -1,677 97.78 94.44 92.19 55.95 54.17 97.07 64.45 54.40 212.79 2,835 12,382.45 -1,677.05 15,217.66 Rs. Crs FY 19-20 2,288 2,288.19 12.25% 12.25% 11.75% 13% 14.75% 14.45% 14.75% 14.75% 10.20% 10.19% 9.89% 9.50% 9.50% 01-10-2008 01-10-2009 01-10-2010 01-10-2011 01-10-2012 01-10-2013 01-10-2014 01-10-2015 01-10-2016 01-10-2017 01-10-2018 01-10-2019 01-10-2020 30-03-2020 30-03-2020 30-03-2020 30-03-2020 30-03-2020 30-03-2020 30-03-2020 30-03-2020 30-03-2020 30-03-2020 30-03-2020 30-03-2020 30-03-2020 FY 08-09 FY 09-10 FY 10-11 FY 11-12 FY 12-13 FY 13-14 FY 14-15 FY 15-16 FY 16-17 FY 17-18 FY 18-19 FY 19-20 5.99 11.98 11.49 12.71 14.42 14.13 14.42 14.42 9.97 9.96 9.67 9.29 5.78 11.10 12.28 13.93 13.65 13.93 13.93 9.63 9.62 9.34 8.97 5.42 11.99 13.60 13.32 13.60 13.60 9.40 9.39 9.12 8.76 3.64 8.25 8.08 8.25 8.25 5.71 5.70 5.53 5.31 4.00 7.83 7.99 7.99 5.53 5.52 5.36 5.15 7.01 14.32 14.32 9.90 9.89 9.60 9.22 4.75 9.51 6.57 6.56 6.37 6.12 4.01 5.55 5.54 5.38 5.17 10.85 21.67 21.05 20.21 -85.41 -165.87 -159.32 752.56 1,176.33 108.69 Total 138.45 122.15 108.19 58.73 49.35 74.26 39.89 25.65 73.79 -410.60 1,928.89 108.69 MSEDCL Total January 20 176 2,317.44 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 8.6 Carrying Cost on unrecovered revenue gap during Control Period 8.6.1 MSEDCL submits that the full recovery of revenue gap in the first few years would amount to tariff shock to the consumers. In view of the above, MSEDCL has deferred revenue recovery. However, the deferred revenue recovery will require funding for the same. Hence, in view of the above, MSEDCL has computed the carrying cost on the unrecovered revenue gap and regulatory assets as shown in following table. Table 183: Carrying Cost on Unrecovered Revenue Gap during the Control Period Rs. Crs Revenue Recovery Formula FY 20-21 FY 21-22 FY 22-23 FY 23-24 FY 24-25 Total Revenue Gap for previous years Revenue Gap for current year Total Revenue Gap upto current year Recovery from Addl CSS Recovery from Addl AS Net Revenue Gap upto current year Less: Recovery from Tariff hike Revenue gap to be carried forward Interest Rate Carrying Cost on unrecovered Gap Carrying Cost on previous claims till FY 19-20 Total Carrying Cost a b c=a+b d e f=c+d+e g h=f-g i j=a*i k l=j+k 8.7 16,652 8,784 25,436 -175 -530 24,731 5,928 18,804 9.50% 791 2,317 3,108 18,804 5,277 24,080 -223 -545 23,312 8,960 14,353 9.50% 1,786 14,353 6,629 20,982 -232 -563 20,187 12,033 8,154 9.50% 1,364 1,786 1,364 8,154 7,680 15,834 -243 -576 15,014 15,080 -65 9.50% 775 775 -65 7,987 7,922 -257 -571 7,094 18,358 -11,264 9.50% -6 -6 Incremental Revenue from CSS and Additional Surcharge 8.7.1 MSEDCL has considered the impact of incremental revenue from CSS and Additional Surcharge as per the proposed CSS and proposed Additional Surcharge for the Control Period. 8.8 Net Recovery from Tariff 8.8.1 Considering the above, MSEDCL has computed the net recovery from tariff as shown in following table. MSEDCL January 20 177 Total 36,357 60,358 4,709 7,027 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 184: Net Recovery from Tariff Particulars Final True Up Requirement for FY17-18 Final True Up Requirement for FY 18-19 Provisional True Up Requirement for FY 19-20 Projected Revenue Gap for FY 20-21 Projected Revenue Gap for FY 21-22 Projected Revenue Gap for FY 22-23 Projected Revenue Gap for FY 23-24 Projected Revenue Gap for FY 24-25 Impact of Review Order on MTR Order Impact of Reinstatement of GFA of Rs. 927 Crs Carrying Cost for previous gaps/impact and unrecovered gaps during Control Period Total Revenue Gap for the MYT Period Impact of Change in Law Regulatory Assets Carrying Cost on Regulatory Assets upto Mar-20 Recovery for Regulatory Assets Total Recovery Incremental Revenue from Cross Subsidy Surcharge Incremental Revenue from Additional Surcharge Net recovery from Tariff Amount Rs. Cr (1,677.05) 2,835.21 2,288.19 8,783.54 5,276.84 6,629.08 7,679.93 7,987.39 216.68 606.55 5,850.30 46,476.66 4,192.00 1,176.33 12,382.45 64,227.44 (1,129.33) (2,785.00) 60,313.11 8.8.2 MSEDCL requests the Hon’ble Commission to approve the net recovery from tariff as computed above MSEDCL January 20 178 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 9 9.1 TARIFF DESIGN AND METHODOLOGY Tariff Design Principles 9.1.1 Hon’ble Commission has been guided by the Electricity Act, 2003 and the National Tariff Policy while determining retail tariffs across the State of Maharashtra. Hon’ble Commission has always laid emphasis on adoption of factors that encourages economy, efficiency, effective performance and improved conditions of supply for the consumers. On the similar guidelines Hon’ble Commission may apply similar principles considering the ground realities as well as to ensure the financial viability of the Licensee. 9.1.2 Tariffs linked to cost of supply and gradual reduction of cross-subsidies in a given time frame is an important feature of the Electricity Act, 2003 and the Tariff Policy. Also, in terms of the Section 61(g) of the Act, the Hon’ble Commission shall be guided by the objective that the tariff progressively reflects the efficient and prudent cost of supply of electricity. 9.1.3 MSEDCL hereby submits that there is an urgent need for ensuring recovery of cost of service from consumers to make the sectors viable. At the same time as mandated in the EA 2003, some minimum level of support by way of cross subsidy is required to make electricity affordable for very poor consumers as electricity has now become a necessity and an essential driver of growth in an agrarian economy of the State. 9.2 Full Cost Recovery 9.2.1 MSEDCL submits that the present Petition is based on full cost recovery of the total revenue gap computed for the previous years. Section 61 of the Act mandates that the Appropriate Commission, while determining tariff, shall not only ensure safeguarding of consumer’s interests but shall also ensure the recovery of the cost of electricity in a reasonable manner. 9.2.2 MSEDCL submits that the MYT period can be utilized to evolve a methodology to determine the commercial principles to sustain growth, ensure financial viability of the Licensee, avoid financial losses and at the same time protect the consumer interests. Also, paragraph 5.10 of the National Tariff Policy notified MSEDCL January 20 179 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition on 28th January 2016 states that “Consumer interest is best served in ensuring viability and sustainability of the entire value chain viz., generation, transmission and distribution of electricity, while at the same time facilitating power supply at reasonable rate to consumers. The financial turnaround/restructuring plans are approved by the Appropriate Government from time to time to achieve this objective. The Appropriate Government as well as the Appropriate Commission while implementing such plans shall ensure viability of the generation, transmission and distribution in terms of recovery of all prudent costs”. 9.2.3 MSEDCL thus proposes the following Tariff Philosophy which may be considered while deciding the retail tariffs as well as the terms and conditions of the tariff schedule: 9.3 Rationalization of Fixed Cost 9.3.1 It has been the Hon’ble Commission’s policy of recovering the Fixed Costs of MSEDCL through a Fixed Tariff applicable to the consumers (to the extent possible). Hon’ble Commission in its first tariff Order dated 5th May 2000 while determining the fixed charge component of the tariff ruled that the recovery of fixed costs should come from fixed charges and also observed that the fixed charge component of tariff needs to be gradually increased in due course to cover the actual fixed costs incurred. 9.3.2 The Hon’ble Commission has articulated its view point in its December 2003 Tariff Order as follows: “The Commission has already elaborated the rationale for levy of demand charges in its previous Tariff Orders. A major part of the costs of the MSEB, apart from the cost of fuel for own generation and variable cost of power purchase, is fixed in nature and the ratio of fixed to variable costs currently stands at 53:47. Though the consumer accesses electricity at any time he desires, the MSEB’s infrastructure (physical infrastructure as well as employees, administration, etc.) has to be permanently available, and related costs incurred irrespective of the level of consumption by individual consumers, and these expenses thus comprises the fixed costs of the MSEB. The Commission has continued the process of increasing the recovery of fixed costs MSEDCL January 20 180 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition by levy of fixed charges to consumers, to safeguard the MSEB from steep fluctuations in revenue with varying consumption over time. The revised fixed/demand charges have been designed to recover around 40% of MSEB’s fixed costs, as compared to the existing level of recovery of around 35% of fixed costs. The balance fixed costs are recovered through energy charges. Thus, for any disruption in supply, the MSEB is effectively losing out on the recovery of fixed costs to that extent. If MSEB is not allowed to recover fixed cost for the period of interruptions and low voltage period, it would further affect the financial viability of MSEB.” (“Emphasis added”) 9.3.3 In the APR Order for FY 2007-08 for MSEDCL, the Hon’ble Commission observed “..........As and when sufficient power is available and contracted by the licensees, the fixed charges can again be increased, and energy charges reduced correspondingly.” 9.3.4 Similarly, in the Tariff Order dated September 12, 2010, Hon’ble Commission has observed that “.... once sufficient power is available and contracted by the licensees, the fixed/demand charges can again be increased, and energy charges reduced correspondingly.” 9.3.5 It is humbly submitted that, at that point of time also, the power supplied to certain categories of consumers was maintained without any reduced supply. As such, MSEDCL feels that the said reduction was unwarranted. 9.3.6 It is further submitted that unavoidable circumstances in real time operations such as coal shortages, faults in generation units, transmission line tripping etc. have led to load shedding for short duration. The load shedding is resorted to safeguard the system from over drawls and/or grid collapse. It is not MSEDCL’s infrastructure which is incapable of supplying the power, rather there is sufficient supply to match the consumer demand. Thus, the fixed/demand charges should not be linked to the few instances of load shedding. 9.3.7 At present, due to sufficient availability of power, there is no Load Shedding in the State. MSEDCL therefore categorically submits that it has sufficient power and has contracted enough power to meet the present and ever-increasing MSEDCL January 20 181 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition future demand of the State. 9.3.8 MSEDCL submits that out of the total ARR, major expenses are fixed in nature and need to be incurred irrespective of any distribution / retail business undertaken by it. A similarity can be drawn in case of generator i.e. even if power plant is shut down, the generating companies need to incur expenses for employees, minor R&M to other assets, depreciation, obligation for loan repayment, interest on loan payments etc. MSEDCL also has similar type of fixed expenses which need to be incurred irrespective of any distribution / retail business undertaken by it. MSEDCL submits that ideally these fixed expenses should be recovered by a combination of Fixed & Demand Charges. MSEDCL has carried out the detailed exercise wherein the fixed cost obligations are mapped out and which it intends that Hon’ble Commission may align the fixed charges accordingly. 9.3.9 MSEDCL submits that all its expenditure excluding the variable cost (fuel related cost) of Power Purchase Expense is fixed in nature. Thus ideally these fixed cost expenses should be recovered through Fixed/Demand Charges. 9.3.10 The Hon’ble Commission in the last MTR Order dated 12th September 2018, had allowed recovery of only 18% through fixed charges as against 55% of recovery that should have been allowed then. This under-recovery has led to inadequacy of funds and unnecessary borrowings by MSEDCL. Further, the recovery from Fixed Charges is much lower which is against the basic principles of recovery of fixed costs through fixed charges as agreed by Hon’ble Commission in the previous Tariff Orders. Since the fixed charges are inadequate, MSEDCL need to borrow some amount to meet its working capital requirements for discharging its fixed liabilities. Also, not increasing the Fixed Charges will result in a corresponding impact on Energy Charges which may not be sufficient enough to meet the fixed charges obligation as the same depends on the consumption of the consumers which is fluctuating and seasonal in nature. 9.3.11 The following table compares Demand Charges for HT Industrial category consumers among some of the states. MSEDCL submits that the fixed charges MSEDCL January 20 182 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition in the neighbouring states are relatively higher than those approved for MSEDCL. Such charges eventually lead to appropriate fixed charge recovery for these States. Rs./kVA/Month FY 19-20 EHV- Industries MSEDCL 391 Madhya Pradesh 650 Andhra Pradesh 475 Gujarat* 475 Himachal Pradesh 425 Telangana 390 Chhattisgarh^ 500 *For > 1000 kVA; ^For Mines 9.3.12 As stated rightly by the Hon’ble Commission in the tariff order dated 26th June 2015 that “Levy of Fixed Charges and Demand Charges do not result in any windfall gain to MSEDCL, since it is recovering only a part of the Fixed Costs through such Charges”, the question is about the principle of applicability and recovery of fixed charges to meet fixed liabilities and not continue to dependent on the consumption. 9.3.13 In the last MTR order dated 12th September 2018, the Hon’ble Commission has accepted the prayer of MSEDCL for increase in the Fixed Charges to certain extent and this may be considered as a gradual approach so as to ensure proper recovery process for MSEDCL. This may not result into any undue tariff burden on the consumers because, to maintain the full cost recovery, the tariff will either have a corresponding change on fixed charges or energy charges. 9.3.14 Therefore, MSEDCL has proposed increasing the Fixed/Demand Charges for various categories for each category of consumers every year as a step towards gradual balancing the fixed charges recovery with fixed charges obligation. This is in line with the Hon’ble Commission’s observation that the recovery of fixed costs should come from fixed charges and the fixed charge MSEDCL January 20 183 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition component of tariff needs to be gradually increased in due course of time to cover the actual fixed costs incurred by the licensee. 9.3.15 Further, it is proposed that the HT-Industrial consumers, running single shift operation shall be levied 60% of applicable demand charges. Single shift operation means running of operations at a stretch for maximum 10 Hrs. For illustration, a consumer running 4hrs.in one stretch and 6hrs.in another stretch cannot be considered as running in a single shift. However, a maximum of three instances of running beyond 10hrs up to 12hrs is permitted in a billing cycle. Consumer has to declare in advance about one shift operation. In absence of such declaration, he shall be billed as per the applicable demand charges. Billing will be done based on MRI/AMR Data. MSEDCL humbly requests the Hon’ble Commission to charge 60% of approved fixed charges for single shift consumers as proposed by MSEDCL 9.3.16 MSEDCL submits that the increase in Fixed/Demand Charges has been proposed in line with the recommendations/discussions at various committees such as Committee on Simplification & Rationalization of Tariff formed on the advice of Ministry of Power (MoP), Government of India (GoI), to examine issues relating to amendments in the Electricity Rules, 2005 as well as in Consultation Paper on issues pertaining to Open Access by Ministry of Power (MoP) issued in August 2017. 9.4 Revision in Billing Demand 9.4.1 Hon’ble Commission in its Tariff Order dated May 5, 2000 revised the definition of billing demand to be the higher of the following for HT Consumers: a) Actual demand [During 0600 hrs. to 2200 hrs.] b) 75%of the highest billing demand during preceding 11 months c) 50% of the Contract Demand d) 50 kVA 9.4.2 Subsequently, in its Tariff Order dated January 10, 2002 for FY 2001-02, Hon’ble Commission observed that the minimum billing demand of 50 kVA may not give the smaller industrial units any incentive to control their demand. Hence, the Hon’ble Commission modified the formula for Billing Demand for HT MSEDCL January 20 184 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition industrial consumers, by removing the clause of ‘minimum 50 kVA’. 9.4.3 MSEDCL also submits that most of the Open Access consumers opt for partial open access and do not reduce the Contract Demand. The Licensee is not expected to purchase power for open access consumers. 9.4.4 Due to Universal Service Obligation, MSEDCL has to be ready with the requisite power including the Contract Demand of the Open Access consumers. Due to such obligation, power purchase planning becomes difficult and MSEDCL has been paying fixed charges for the contracted power capacity. Also the capacity blocking affects the overall tariff. 9.4.5 MSEDCL submits that the existing actual billing demand is much lower than the contract demand (around 50%) and due to lower utilization of contract demand, power planning becomes difficult and MSEDCL has to be ready with the additional power to the extent of contract demand. MSEDCL further submits that with higher contract demand and lower billing demand, the infrastructure is not utilized properly, many times it gets blocked for few consumers and optimum utilization of assets doesn’t take place. In some case even with lower billing demand, additional infrastructure is required due to contract demand. If the consumers keep billing demand as close as possible to the contract demand, proper utilization would occur and thereby reducing the overall tariff. 9.4.6 MSEDCL further submits that the recovery from fixed charges as approved by the Hon’ble Commission is also not happening due to restriction on billing demand. 9.4.7 Considering the above, MSEDCL suggests that the Billing Demand definition may be amended to as proposed. It is pertinent to note that MSEDCL’s billing demand is low as compared to most of the States. State wise billing demand definition is summarised in the following table. MSEDCL January 20 185 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition TN MP Gujarat AP Karnataka (BESCOM) Chhattisgarh Actual Demand recorded during 0600 hours to 2200 hours Actual Demand Actual Demand Actual Demand Actual Demand Actual Demand Actual Demand 75% of max billing demand during last 11 month 90% of Contract demand 90% of Contract Demand 85% CD 80% of Contract Demand 85% of Contract Demand 75% of CD MSEDCL HT Category Highest of 50% CD of 100 kVA of 60 kVA LT Category Highest of 65% of the Actual Maximum Demand recorded during 0600 hours to 2200 hours 40% CD of Contracted demand Actual Maximum Demand Actual Maximum Demand Actual Demand Maximum Demand recorded Actual Maximum Demand 90% CD 85% CD Contract demand Sanctioned load 75% of CD of of 6kW 9.4.8 MSEDCL had earlier approached the Hon’ble Commission to revise the definition of Billing Demand to Actual Maximum Demand recorded OR 85% of the Contract Demand whichever is higher. However, in the MTR Order 195 of MSEDCL January 20 186 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 2017, the Hon’ble Commission did not accept MSEDCL’s prayer citing that: “9.22.10. Accordingly, the Commission has revised the eligibility conditions for applicability LF incentive, which would hopefully address the concerns raised by MSEDCL. Hence, the Commission has not accepted MSEDCL’s proposal for revision in definition of Billing Demand but has put restriction on the eligibility of LF incentive; in case Billing Demand exceeds Contract Demand in any of the time block duration through the day.” 9.4.9 MSEDCL humbly submits that though the Hon’ble Commission’s directive of putting restriction on the eligibility of LF incentive has put a check on the misuse of load factor incentive, it will not ensure the recovery of approved revenue from fixed charges. It is noteworthy, that LF Incentive and Billing Demand are two different issues. Billing demand is for recovery of cost of licensee whereas LF Incentive is for effective utilisation of contracted demand. Only few consumers are availing LF incentive as it mostly depends on manufacturing process and to some extent operational strategy. In FY 2017-18, around 390 consumers have availed the load factor incentives of Rs. 350 Crs. Hence the concerns of MSEDCL still remain unaddressed. 9.4.10 MSEDCL therefore requests the Hon’ble Commission to consider the proposal of revision in definition of billing demand suitably as given below: LT 3 Phase HT Existing Proposed Maximum of Maximum of 65% of actual MD recorded during 06 to 22 Hrs OR 40% of the Contract Demand Actual MD recorded in a billing period OR 60% of the Contract Demand Actual MD recorded during 06 to 22 Hrs OR 75% of the highest Billing Demand OR 50% of the Contract Demand Actual period MD recorded in a billing OR 85% of the Contract Demand 9.4.11 The proposed changes in definition of Billing Demand shall also be applicable to 3 Phase consumers under 0-20 kVA category in addition to those belonging MSEDCL January 20 187 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition to >20 kVA category. 9.4.12 MSEDCL submits that in view of the submission provided hereinabove, MSEDCL has computed the revenue from proposed Fixed/Demand Charges for HT & LT category for FY 20-21 to FY 24-25 considering the proposed definition for billing demand. 9.4.13 MSEDCL requests the Hon’ble Commission to allow the revision in the definition of Billing Demand so as to ensure the appropriate recovery from fixed /demand charges. 9.4.14 MSEDCL also requests the Hon’ble Commission to approve the kVA based Fixed Charges for 3 phase consumers having loads less than 20 kVA as proposed by MSEDCL 9.5 Penalty for Contract Demand Violations 9.5.1 MSEDCL submits that in the last MTR Order dated 12th September 2018, the Commission had given directives for penalties for violations of maintaining contract demand and also stated that “Under these circumstances, the consumer shall not be liable for any other action under Section 126 of the EA, 2003, since the penal additional charge provides for the penalty that the consumer is liable to pay for exceeding his Contract Demand. In case a consumer exceeds his Contract Demand on more than three occasions in a calendar year, the action to be taken would be governed by the provisions of the Supply Code Regulations.” 9.5.2 MSEDCL submits that, further to the issuance of the MTR Order, the Hon’ble Commission also issued Order No. 60 of 2018 dated 1st January 2019 invoking the inherent power to remove difficulty under Supply Code Regulations 2005. The Commission in the said Order had noted the difficulty of MSEDCL to give effect to the specific provision of the MTR Order when read with Supply Code Regulations and therefore, could not take appropriate action against the consumers who regularly and intentionally breach their contract demand. In the said Order, the Commission ruled that “ Distribution Licensee can enhance the Contract Demand of the consumer when the consumers exceeds the contract MSEDCL January 20 188 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition demand on more than three occasions during a calendar year, irrespective whether the Consumer submits an application for the same or otherwise. However, before such revision of Contract Demand, Distribution Licensee must give 15 days’ notice to such consumer” 9.5.3 In line with the same, MSEDCL had issued Commercial Circular No. 312 for implementing the provisions of the said Order. MSEDCL further submits that the consumer should be charged with the tariff applicable to the slab to which he actually belongs. i.e. If a consumer utilises demand for say more than 20 kVA, then he should be charged with the tariff applicable to the sub-slab of >20 kVA only and so on. However, it is observed that some consumers opt for demand upto 20 kVA and actually utilises demand more 20 KVA. Therefore, he should be charged with tariffs for more than 20 kVA slab only. Therefore all such consumers should be charged with the tariffs applicable to the slabs in which its recorded demand falls. There is lack of clarity on this issue and due to which some of the LT consumers are raising disputes and approaching various Forums such as CGRF, Ombudsman etc. against charging such tariffs. In Order to bring explicit clarity, MSEDCL hereby submits that the said stipulation regarding penalty for exceeding contract demand may be revised as proposed below: In case a consumer exceeds his Contract Demand, he will be billed at the tariff applicable for the respective load slab approved by the Commission, in which recorded demand falls for that billing cycle only and also be charged an additional amount at the rate of 150% of the applicable charge for the Demand in excess of the Contract Demand. Further Distribution Licensee can enhance the Contract Demand of the consumer when the consumers exceeds the contract demand on more than three occasions during a calendar year, irrespective whether the Consumer submits an application for the same or otherwise. However, before such revision of Contract Demand, Distribution Licensee must give 15 days’ notice to such consumer. Also the Consumer is liable to pay the necessary charges as may be stipulated in the approved Schedule of Charges for the revised Contract Demand. MSEDCL January 20 189 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 9.6 kVAh Based Billing 9.6.1 There are two components of electric power, active and reactive. The active or real power is actually consumed and converted into useful work for creating heat, light and motion and is measured in kilo Watt (kW) and is totalized by the energy meter in kilo watt hour(kWh). The reactive power is measured by kilo Volt Ampere Reactive (kVAR) and is totalized by the energy meter in kiloVolt Ampere Reactive hour (kVARh). This power is used to provide the electromagnetic field in inductive and capacitive equipment. 9.6.2 The reactive power occupies the capacity of electricity network and reduces the useful capacity of system for generation and distribution. The source of most reactive currents is the poor power factor loads (equipment) connected at consumer premises. As these loads are not compensated by appropriate capacitor installations by consumers, utilities are burdened for installation of capacitors. 9.6.3 Reactive power is a local phenomenon and the extra reactive compensation by industrial consumers in MIDC/ Industrial area cannot be used / compensated against extra reactive energy drawl by agricultural section. As a result, in both situations, system stability of Distribution Company is hampered. It is thus imperative that every section of consumers has to shoulder their responsibility to maintain the system PF within permissible limits only. 9.6.4 The most effective remedy to remove such anomaly is to introduce kVAh billing. Introduction of kVAh metering and kVAh tariffs is therefore seen as a commercial inducement to consumers to ensure a smaller electricity bill by ensuring that they do not draw reactive power. It is considered that these consumers will in turn use efficient devices with power factor correctors or install capacitors at their premises. 9.6.5 The Forum of Regulators (FoR) in its report on “Metering Issues” August, 2009, has stated that kVAh billing is the new trend in electricity billing, which is adopted worldwide. In the report they have strongly advocated to adopt kVAh billing in India on account of following reasons. MSEDCL January 20 190 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition a) kVAh Metering is a check on power factor. b) It will encourage consumers to use reactive energy compensators to control the voltage at their intake point and maintain unity power factor. c) The accepted threshold limit of power factor is unity. There need not be any penalty exemption for power factor neither lagging nor leading. Thus kVAh billing merits consideration over power factor penalty. 9.6.6 The Hon’ble Commission in MYT Regulations, 2019 has provisioned for kVAh billing. Regulations 73.2 states that “Wheeling Charges of the Distribution Licensee shall be determined….. Provided that the Wheeling Charges may be denominated in terms of Rupees/kWh or Rupees/kVAh or Rupees/kW/month or Rupees/kVA/month, for the purpose of recovery from the Distribution System User,…” 9.6.7 It is pertinent to mention that kVAh billing has already been adopted in some of the state in India as per orders of respective SERCs details of which are as below: HP: HPERC Order dated 18.09.2001. Delhi: DERC in 2001. Jammu &Kashmir: Order dated 28.03.2007. AP: APERC Order dated 30-03-2011. Haryana: HERC Order dated 25.07.2012 UP: UPERC Tariff order dated 31.05.2013. Punjab: PERC order dated 22.08.2014. Chhattisgarh : Chhattisgarh ERC Tariff order dated 23.05.2015 Bihar: BERC order dated 21-03-2016. 9.6.8 Category wise status of applicability of kVAh billing for various states is tabulated as below. MSEDCL January 20 191 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Category AP CG Delhi Haryana J&K UP Bihar Industrial Commercial Railways Agriculture × × × PWW/LIS × Temporary × × Bulk Supply × Start up × × × × × × × × × × × × Non Domestic /Commercial * × * $ × × × PWW × * × × × Agriculture × × × × × × × # × * × × × × × × × × × HT LT Domestic Industrial Street Light $ >20 kW/20 kVA *>10 kW# > 15kW kVAh Tariff Applicable 9.6.9 The Prime Objective of the kVAh based billing is to encourage the consumers to maintain near unity Power factor to achieve loss reduction, improve system stability, power quality and improve voltage profile. At the national level, emphasis is being given to Energy conservation, energy efficiency and Demand Side Management (DSM) and green energy solutions to optimize the energy usage. By kVAh billing, the consumers will be encouraged to adopt energy efficiency programs and will be benefited by reduced electricity bills. 9.6.10 Moreover, due to improvement of Power Factor (nearer to unity), the consumer’s demand may get reduced and also the kVAh billing will be correspondingly reduced in turn improving system voltage. The improvement in Power Factor will reduce the licensee’s expenditure on Power Purchase and thereby the consumers will be benefited with lower tariff. If in case, the Power Factor is less than unity, the consumption recorded in respect of kVAh would MSEDCL January 20 192 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition be high compared to kWh consumption. Thus, the kVAh based billing will drive the consumers to reach unity power factor. Ultimately, kVAh billing will be providing inbuilt incentive, which will automatically take care of power factor incentive and disincentive. 9.6.11 Legal & Regulatory provisions: A) Relevant APTEL judgments in the subject matter: Hon’ble Appellate Tribunal for Electricity, New Delhi in the matter of Prime Ispat Ltd., Mahamaya Steel Industries Limited and Chhattisgarh State Electricity Regulatory Commission, in its judgment dated 10th April 2015 in Appeal No. 263/2014 had observed advantages of High Power Factor and kVAh billing. The relevant extracts of the same are reproduced below: “…… a) Higher the power factor, lower is the load current and thereby technical losses of the transmission lines i.e. I²R losses will be reduced considerably. b) Due to increase of Power Factor (nearer to one), the consumer’s demand charges will be reduced and also the kVAh billing will also be correspondingly reduced. c) The Higher Power Factor will reduce the demand on the system and improve the systems Voltage. d) Increases the available transmission and distribution system capacity. e) The improvement in Power Factor will reduce the licensee’s expenditure on Power Purchase and thereby the consumers will be benefited with lower tariff. f) In view of the above, most of the States are changing their billing system from kWh to kVAh billing system. The learned counsel of the Appellant has contended that due to kVAh billing, bill amount has been increased and thereby the Appellant burdened with higher power bill. We do not find any merit in the contention for the following reasons: Because Power Factor = kWh/ kVAh If Power Factor is unity, then kWh = kVAh In the instant case, the Power Factor is less than unity and hence the MSEDCL January 20 193 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition consumption recorded in respect of kVAh is high compared to kWh consumption. Further, the power factor surcharge/rebate will not be there in kVAh billing. Thus, the kVAh based billing will drive the consumers to reach unity power factor and thereby the system performance will be improved and also reactive power drawal from the system will be minimised and thereby better system voltages for the tail end consumers also.…” 9.6.12 The Hon’ble ATE, in appeal No. 130 of 2005 between South East Central Railways, Chhattisgarh Versus Chhattisgarh State Electricity Board has upheld the decision of the State Commission in introducing kVAh billing, relevant extract of the same is reiterated below: “kVAh billing which provides inbuilt incentive for the Appellant’s category, which will automatically take care of power factor incentive and disincentive for the high and low power factor respectively” 9.6.13 MSEDCL in its MTR Petition had requested the implementation of kVAh billing and Hon’ble Commission in the MTR Order in Case no.195 of 2017 dated 12th September, 2018 ruled as follows: “.. 9.23.11. The Commission has taken a note of Petitioner’s proposal for adoption of kVAh-based billing for HT consumer categories. The Commission is of the view that the kVAh billing may not be appropriate at this time of juncture as it has to be done in a gradual manner to avoid any tariff shock due to such change. MSEDCL may submit its proposal for kVAh billing in next control period. The Commission intends to implement kVAh billing to all HT consumer and LT consumers having load above 20 kW from 1 April, 2020. All Distribution Licensees in State are required to take necessary steps such as meter replacement, if required, preparedness of billing software etc. Also, wherever possible, Distribution Licensee shall start collecting category-wise energy consumption details in kVAh terms and submit it during the next Tariff determination process. Though the Commission agrees that the benefits and its technical superiority for measuring energy, it is felt that sufficient time needs to be given to MSEDCL and also the consumers to change over the billing kVAh MSEDCL January 20 194 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition method. The Commission directs MSEDCL to educate the consumers and take all necessary steps to ensure that all the consumers are billed by kVAh method from the next MYT i.e. from 1st April 2020.” 9.6.14 In line with the above directive of the Hon’ble Commission, MSEDCL has taken the following steps to ensure effective implementation of kVAh billing from 1st April 2020. 9.6.15 Consumer Awareness: MSEDCL has conducted awareness programs across the State and explained the concept of kVAh billing and its implications to various Industrial Category consumers. During these program, different aspects of the proposed kVAh billing were discussed and deliberated upon. During these Programs, a Power Point Presentation (PPT) was presented to the participants. Further queries of consumers regarding kVAh billing were addressed during these interactive sessions. The Power Point Presentation is attached as Annexure 7 to this Petition. In line with the above directive of the Hon’ble Commission, MSEDCL has proposed the kVAh Billing. MSEDCL conducted these program from sub division officer level to the Director level i.e. Management level. Around 100 such awareness camps were organised at various places across the State. FAQs on kVAh billing were uploaded on the MSEDCL website and on 2nd February 2019, MSEDCL emailed Letter informing proposed implementation of kVAh billing from 1st April 2020 to all HT consumers having email IDs registered with MSEDCL. 9.6.16 MSEDCL submits that for Implementation of kVAh billing program, MSEDCL has already initiated meter replacement drive. Replacement of meters for HT consumers will be completed by January 2020. Net meter and OA consumer meters programing will be done before March 2020. Subsequently, the LT consumer meters will also be replaced in a phased manner so as to enable kVAh billing for LT consumers during the Mid-Term Review process in accordance with the readiness of such implementation. Meters of all the LT consumers, will be changed or programmed for kVAh reading by March-2021. 9.6.17 The progress for kVAh billing meter replacement status of HT consumers as follows: MSEDCL January 20 195 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Meter Balance to be Replaced Replaced TARGET 19043 18690 353 MONTHLY PLAN Dec-19 Jan-20 100 253 24000 HT Meters are procured; programing of Open Access (ABT Meters) & Solar Consumers will be done before March 2020 to have kVAh reading with actual PF, TD Consumer Meters will be replaced while Reconnection; 359 Meters under Bhiwandi franchisee Area kVAh compatible. The progress for kVAh billing meter reprograming of LT (>20 kW) consumers as follows: LIVE CT ABOVE OPERATED EMBEDDED EMBEDDED Embedded 20 kW METER METERS in METERS TO Meter IN consumers billing BE REReplaced BILLING in billing system PROGRAMMED till Date SYSTEM system CATEGORY INDUSTRIAL COMMERCIAL OTHER TOTAL LT Meters 63072 29013 29936 25863 16393 24116 37209 12620 5820 18317 7093 5026 18892 5527 794 122021 66372 55649 30436 25213 The Reprograming target and plan is as below: REPROGRAMMING IND 18317 COMM OTHER 7093 TARGET REPROGRAMMED METER TO BE REPROGRAMMED 30436 5312 25124 5026 MONTHLY PLAN Dec-19 Jan-20 Feb-20 Mar-20 3000 7376 7374 7374 The Progress for kVAh billing meter replacement status of LT (>20 kW) MSEDCL January 20 196 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition consumers as follows: CATEGORY INDUSTRIAL TARGET (NONDeckVAh 19 METERS) 25863 2000 MONTHLY PLAN Jan20 Feb20 Mar20 7955 7955 7953 COMMERCIAL 16393 866 5176 5175 5176 OTHER 24116 0 0 0 0 TOTAL 66372 2866 13131 13130 13129 Apr20 May20 Jun20 Jul20 Aug20 Sep20 4020 4020 4020 4020 4020 4016 4020 4020 4020 4020 4020 4016 9.6.18 At present, MSEDCL has not done any change in the Billing software, however, same will be done as per Hon’ble Commission’s Order within one month. However metering specifications are changed to measure kVAh and kVA MD considering rkVAh (Lag & Lead). Software updation of OA consumer meters also will be done as per Hon’ble Commission’s Order within one month. 9.6.19 MSEDCL further submits that it shall strive to complete metering/programming all HT Consumers latest by March 2020. However, in case the replacement/programming is not done for any consumer, then the existing methodology to derive the kVAh shall be used for kVAh billing of those consumers. MSEDCL is committed to provide the kVAh Meters to all consumers for whom kVAh billing shall be applicable and it shall complete the activity of providing meters on priority. 9.6.20 Energy Consumption Details: As directed by the Hon’ble Commission, MSEDCL has collected category-wise energy consumption details in kVAh and kWh for HT category consumers. Details of the same are provided below. Table 185: Category-wise energy consumption details in kVAh and kWh Categories HT – Industry HT – Commercial HT - Railways/Metro/Monorail Traction MSEDCL Apr-19 to Oct-19 MkWh MkVAh Consumption Consumption 19,161 19,482 1,280 1,318 47 48 January 20 PF% 98% 97% 97% 197 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Categories HT - Public Water Works (PWW) HT – Agriculture HT - Group Housing Societies (Residential) HT - Public Services HT – Electric Vehicle Charging Station Apr-19 to Oct-19 MkWh MkVAh Consumption Consumption 1,110 1,152 733 801 124 128 643 658 3 3 PF% 96% 91% 97% 98% 99% 9.6.21 MSEDCL requests the Hon’ble Commission to allow gradual implementation of kVAh billing consisting of the first stage of rollout to HT consumers. Many States started billing in kVAh initially for HT category consumers only. In line with the same, MSEDCL proposes the kVAh based billing to HT category initially considering the higher awareness about the advantages of maintaining PF among HT consumer groups. The kVAh billing will be proposed for the LT consumers subsequently in the next Mid-Term Review Petition. 9.6.22 MSEDCL would also like to submit that implementation of kVAh billing is a move to encourage consumers to adopt energy efficient programs and for the overall benefit of the sector. The same has already been implemented in various states and the Hon’ble Commission may allow MSEDCL to be the initiator of the same and implement the same in MSEDCL area. MSEDCL feels that other Licensees in the State may take the decision depending upon their readiness, the implementation may not be linked to the readiness of all Licensees in the State. If any Licensee requests the Hon’ble Commission for implementation of kVAh billing, it should be considered irrespective of the stands taken by other Licensees. MSEDCL once again requests the Hon’ble Commission to allow the gradual implementation of kVAh billing for its consumers. 9.6.23 Regarding abolition of PF incentive, MSEDCL would like submit that Hon’ble APTEL has already ruled that “kVAh billing which provides inbuilt incentive for the Appellant’s category, which will automatically take care of power factor incentive and disincentive for the high and low power factor respectively”. MSEDCL further submits that the principle of revenue neutrality is being followed in implementing the kVAh tariff so that both the Licensee as well MSEDCL January 20 198 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition consumers are not burdened unnecessarily. kVAh billing system is a more accurate and cost effective system to extend uniform incentives/penalties on account of low or good power factor and is also prevalent in many States. Tariff determined in kVAh shall be less than kWh tariff by the average power factor. 9.6.24 MSEDCL further submits that some of the consumers who have already spent money to maintain power factor, will have an added advantage as they already have the resources to maintain higher power factor which will benefit them in terms of reduced consumption. 9.6.25 Regarding kWh as a unit for sale of electricity specified in the MYT Regulations, MSEDCL submits that even though the MYT Regulations specify unit of generation or sale as kWh, the same MYT Regulations provide for Rs./kVAh as one of the unit for Wheeling Charges. 9.6.26 MSEDCL would like to submit that even though power purchase is done in terms of kWh, as per the CERC Grid Code Regulations 2010 as amended from time to time, reactive charges (present rate 14.05 paise/kVArh) are payable depending on the system conditions. The relevant Regulation is reproduced below: 6.6 (2)The charge for VArh shall be at the rate of 10 paise/kVArh w.e.f. 1.4.2010, and this will be applicable between the Regional Entity, except Generating Stations, and the regional pool account for VAr interchanges. This rate shall be escalated at 0.5 paise/kVArh per year thereafter, unless otherwise revised by the Commission. 9.6.27 MSEDCL submits that for Open Access Consumers, Special Energy Meters (SEMs) are installed at all consumers sourcing power through Open Access. SEM records kVAh in 15 minutes time block. At unity power factor MW=MVA, thus the settlement of scheduled power in kVAh with consumer’s consumption in kVAh in the corresponding 15 min slot can be done. 9.6.28 In view of the submissions in the foregoing paras, the steps taken by MSEDCL and various advantages as listed below, MSEDCL is proposing to adopt kVAh billing presently for HT category consumers. Simultaneously the PF incentive MSEDCL January 20 199 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition for these categories shall be withdrawn from FY 2020-21 onwards. a) The kVAh based billing has an inbuilt incentive/penalty mechanism and therefore separate mechanism for the same is no more required. It will encourage the consumers to improve the power factor by way of reactive power compensation at the load point itself. b) With the better power factor, the line loading shall be lower for the same kW requirement leading to lower transmission as well as distribution losses. c) Benefit of kVAh billing is passed on to the consumers by way of reduction in energy charges or lower increase which would have been more in case of kWh billing. d) Power supply quality will be improved. e) It is win-win proposal for both - the consumers and MSEDCL. 9.6.29 In view of the above Hon’ble Commission is humbly requested to approve the kVAh based billing for the HT Consumers. 9.6.30 In view of the proposed kVAh billing, the power factor incentive and penalty shall not be applicable for HT Category consumers. However, the existing provisions for power factor incentive and penalty shall continue to be applicable for LT Category consumers as per the relevant Orders of Hon’ble Commission. 9.7 Recording of Maximum Demand 9.7.1 It has been observed that certain consumers are taking the benefit of lacunae in system of block window method of Maximum Demand recording and thereby getting the benefit of lower MD recording. 9.7.2 As per the Regulation 2.1 (p) of the MERC (Electricity Supply Code and Other Conditions of Supply) Regulations 2005, the maximum demand (MD) means twice the largest number of kWh or kVAh supplied and taken during any consecutive thirty minute blocks in that period. Same definition of ‘Maximum Demand’ is also provided by Hon’ble Commission in MTR order dated 12 th September 2018 (case No 195 of 2017). 9.7.3 MSEDCL submits that “IS 14697” is INDIAN STANDARD for AC static CT/PT operated Energy meters and specifies about the Demand integration period i.e. MSEDCL January 20 200 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 15 or 30 min. 9.7.4 MSEDCL submits that CBIP’s “guide on Static energy meters- Specification and testing” has mentioned two methods i.e. block & sliding window method for determination of the MD. In sliding window method determination of the MD is based on 30 min DIP (Demand Integration Period). Here the 30 min period is not fixed as in case of the block window. In block window method the MD is determined over a fixed time slot of 30 min i.e. from 10:00 to 10:30 hrs. 10:30 to 11:00 hrs.…..so on. The new Demand Integration Period (DIP) starts only after the end of previous DIP. 9.7.5 In block window method the MD is integrated over a fixed block of time as per meter clock, i.e. from 10.00 to 10.30 hrs or 10.30 to 11.00 hrs. In this method there is one disadvantage i.e. consumer with higher demand can split his load in two consecutive time slots such that the demand is split in two blocks and MD recorded is less than the actual load on the system. This splitted high load than sanctioned contract demand is harmful to the Grid and pose difficulties to Distribution Company for meeting Demand. Hence sliding window method is incorporated in new meters to determine demand more accurately, which is complying with the MERC regulations, Tariff Order, IS and CBIP standards. 9.7.6 In the revised methodology of determination of Maximum demand, the Demand Integration Period (DIP) of consecutive 30 min as specified in the MERC (Electricity Supply Code and other Conditions of Supply) Regulation 2005 is maintained and considered for measuring, recording & billing the Maximum Demand of consumer and is in line the IS and CBIP Guide. 9.7.7 Further, FAQs regarding kVA Maximum Demand Calculation are available on MSEDCL’s website. 9.7.8 MSEDCL has installed new technology meters with a sliding window for recording maximum demand in consecutive 30 minutes block. The 30 min demand integral period is sliding consecutively with 10 min sub-interval has been used. MSEDCL January 20 201 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 9.8 Revision in Load Factor Formula 9.8.1 The Hon’ble Commission in the last MTR Order dated 12 th September 2018, had acknowledged the issue of wilful violation of Contract Demand during 22:00 to 6:00 Hours to avail ToD benefits & Load Factor Incentive and observed that “In order to ensure secure operation of electricity grid, it is critical that every constituent of the system acts within its assigned boundaries. Intentional violation of Contract Demand limit by individual consumer for its own financial gain may lead to a system failure, which may affect other consumers.” Accordingly the Hon’ble Commission revised the provision and ruled that LF incentives shall not be available in case of exceeding Contract Demand during night also. 9.8.2 Further, as per the Order dated 24th December 2018 in Case No. 321 of 2018, Hon’ble Commission revised the LF incentive formula for PF and now the Unity Power Factor is considered instead of actual PF. 9.8.3 The concept of LFI was introduced by Hon’ble Commission in Case No. 2 of 2003 i.e. nearly 16 years ago. Since then till date, there have been numerous disputes with regards to the interpretation of the LF formula. Consumers are approaching MSEDCL with the demand of consideration of interruption/nonsupply hours and shut down more than 60 Hours because of unforeseen incidents like water logging in EHV Substation, Flood situation etc. However, as per Formula only planned outage (since 60 hours in a 30 day month is already in built in the Formula) is considered for reduction in hours for calculation of Load Factor. This ultimately results into disputes before CGRF or Hon’ble Commission. 9.8.4 MSEDCL submits that the change in LFI computation is sought with the intention of bringing clarity and simplification in the LFI formula. MSEDCL submits that any shutdown (planned outage), breakdown or any interruption of supply to the extent of 60 Hrs. in a month has to be considered while framing the calculation for Load Factor Incentive. This means, in the 60 Hrs, the effect of non-supply to the extent of 60 Hrs is built in and will not have additional effect while calculating LF whereas any non-supply beyond 60 Hrs will be considered. MSEDCL January 20 202 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 9.8.5 MSEDCL further submits that since the introduction of LF incentive, in the calculation of Load Factor as per the methodology adopted by Hon’ble Commission, 60 Hrs have been deducted towards interruption/non-supply in a 30 day month. As per formula of LF incentive, maximum incentive of 15% become available at 92.5%. It means non-supply including interruption up to 60 hours are inbuilt in the formula. 9.8.6 In view of the above submission, 60 Hrs of non-supply should include any type of break down, interruptions, maintenance, planned shut-down etc. 9.8.7 MSEDCL further submits that sometimes due to natural calamity such as floods or cyclones, there is non-supply for more than 60 hours or sometimes more than few days. However, lack of clarity on how to treat planned outages resulted into various disputes. There is a need to bring in more clarity in the Formula for treatment of shut downs/planned outages. Therefore, it is proposed not to deduct any non-supply upto 60 Hours including planned shut down for calculating the load factor, whereas, any non-supply more than 60 Hours will be deducted while calculating the load factor. Hence, MSEDCL proposes following formula: Consumption during the month in MU Load Factor = Maximum Consumption Possible during the month in MU Maximum consumption possible = Contract Demand (kVA) x Unity Power Factor x Total no. of hours during the month less non-supply hours beyond 60 hrs. (Irrespective of planned or un-planned load shedding) In case the consumer exceed its Contract Demand in any particular month, the Load Factor Incentive will not be payable to the consumer in that month 9.8.8 Alternatively, if Hon’ble Commission deems fit, the 60 Hours may be reduced to Zero Hours by reducing the incentive and actual non-supply hours shall be excluded from the computation of load factor. This will protect the consumer interest and he will not lose the incentive due to non-supply from MSEDCL/MSETCL. Load Factor incentive will be based on his own performance and this will help in reducing the litigations. MSEDCL January 20 203 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 9.8.9 It is pertinent to note that due to such revision, the Load Factor of the consumers will improve and many consumers presently not getting the load factor incentive may get the Incentives for Load Factor achievement. 9.8.10 Hence, in both the proposed cases as above, the maximum incentives shall be limited to 7.5% and the proposed applicability of Load factor Incentive is as follows: Load factor above 75% and upto 85% - incentive of 0.25% on the energy charge for every 1% rise in load factor from 75% to 85%. Consumers having load factor above 85% - incentive of 0.50% on the energy charge for every 1% rise in load factor from 85%. The total incentive will be subject to a ceiling of 7.5% of energy charges applicable to the consumer. 9.8.11 Load Factor Calculation with proposed changes Base data Assumed for case studies consumption during month Units CD kVA 500000 1000 MSEDCL PF 1 Existing Method Proposed Method Total interruptions during the Month in Hrs Hours consid ered for deducti on Load Fact or Hours consider ed for deductio n Loa d Fact or MSETCL Breakdo wn in Hrs Plann ed Outag e in Hrs Brea kdo wn in Hrs Plann ed Outa ge in Hrs 1 2 3 4 5=1+2+3+4 6 7 8 9 30 30 0 10 0 10 25 20 55 70 0 10 69% 70% 55 70 75% 77% Scenario CASE 1 CASE 2 Total number of hours during month 720 MSEDCL January 20 204 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition MSEDCL Scenario Breakdo wn in Hrs CASE 3 CASE 4 9.9 40 10 Existing Method Proposed Method Total interruptions during the Month in Hrs Hours consid ered for deducti on Load Fact or Hours consider ed for deductio n Loa d Fact or 110 100 50 90 75% 79% 110 100 82% 81% MSETCL Plann ed Outag e in Hrs 50 90 Brea kdo wn in Hrs 20 0 Plann ed Outa ge in Hrs 0 0 Rebate for Incremental Consumption 9.9.1 MSEDCL in its MTR Petition had proposed to provide incentive to the existing HT consumers for incremental consumption, with a rebate of Rs.1 /kVAh in energy charges for additional consumption over a threshold limit, provided the effective variable charge of such consumer should not be less than Rs.4 Per kVAh after considering all charges, rebates, incentives etc. 9.9.2 Hon’ble Commission its MTR Order dated 12th September 2018 has observed that encouraging incremental consumption by way of discount would be good idea, particularly, in surplus power scenario and contracted capacity is available in excess which otherwise would be subjected to backing down. However, Hon’ble Commission further opined that providing such rebate during mid-term review process would not be proper. Hence, Hon’ble Commission ruled that the same can be considered along with next filing for new Control Period with detailed scheme and cost/benefit analysis of such scheme. 9.9.3 Further, the Hon’ble Commission in Regulation 81.4 of MYT Regulations 2019 provides for such rebates. “The Distribution Licensee may propose other rebates for inter-alia, taking supply at higher voltages, bulk consumption, power factor, etc., as a part of their Petition, and the revenue impact of rebates shall be passed on through the Aggregate Revenue Requirement and tariffs, subject to the Commission’s approval.” However, this rebate should not be considered under Regulation 81.5 of the MYT Regulations 2019. MSEDCL requests the Hon’ble Commission to allow this rebate as a part of the ARR. The impact MSEDCL January 20 205 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition assessment of incremental consumption, estimate consumer/consumption base etc. have been illustrated below. of eligible Coswt Benefit Analysis Sales due to incremental consumption Average Billing Rate of HT Consumers Rebate Given for Incremental Consumption Net ABR for HT Consumers Total revenue from incremental sales UoM MU Rs/unit Rs/unit Rs/unit Rs Cr. FY 2020-21 2,424 9.12 1.00 8.12 1,969 FY 2021-22 1,318 9.31 1.00 8.31 1,094 FY 2022-23 1,392 9.49 1.00 8.49 1,181 FY 2023-24 1,472 9.66 1.00 8.66 1,275 FY 2024-25 1,561 9.81 1.00 8.81 1,376 Purchase quantum for incremental sales Marginal Variable Cost of Power Purchase Total Cost for incremental sales Total Benefit MU Rs/unit Rs Cr. Rs Cr. 2,621 3.00 786 1,183 1,425 3.00 427 667 1,505 3.00 451 730 1,592 3.00 478 798 1,687 3.00 506 869 9.9.4 Thus for incremental sales due to such subsidising consumers, MSEDCL would get additional revenue. 9.9.5 Accordingly, MSEDCL hereby proposes to provide incentive to HT consumers for incremental consumption, with a rebate of Re.1 /kVAh in energy charges for additional consumption over a threshold limit. The consumers have to pay the fixed and wheeling charges as may be applicable to that category. The criterion for allowing the rebate shall be as under: a) The rebate shall be applicable to HT Industries, HT Commercial, HT Public Services and HT Railways/Metro/Mono. b) The rebate shall be given only to those consumers who source their entire power from MSEDCL. c) The rebate shall be for a period of five years subject to reconsideration during the mid-term review. d) The rebate shall be allowed to consumers, who consume power above threshold limit. The total consumption in financial year FY 2018-19 by the consumer shall be considered as baseline consumption. e) In case, period is less than one year, baseline consumption shall be worked out on prorate basis; f) The billing at the reduced rates after allowing the rebate shall be done once the consumer crosses the baseline consumption. e.g. if a consumer’s total annual consumption in FY 2018-19 was 10,000 units, the consumer shall be entitled for a rebate of Rs. 1/kVAh for consumption exceeding consumption of previous year (not below the baseline consumption of 10,000 units) in FY 2020-21 onwards. g) The amount of rebate shall be adjusted in the Consumer’s bill after MSEDCL January 20 206 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition completion of the Financial Year. h) The rebate shall be over and above the existing rebates subject to the fact that the consumer’s total variable charges should not be less than Rs. 4 per kVAh after accounting all applicable rebates. i) This rebate would also be applicable to open access consumers who shifts their entire demand to MSEDCL 9.9.6 MSEDCL submits that such incentives on incremental consumption is prevalent for Industrial, Non-Industrial and Shopping Malls categories in Madhya Pradesh and the relevant clause (6.12 -xii of MPERC Tariff Order FY19-20) for the same is reproduced as “A rebate of Re. 1 per unit in energy charges is applicable for incremental monthly consumption w.r.t corresponding month of FY 2015-16.” 9.9.7 MSEDCL submits that in order to reduce the burden of fixed charges on common consumers of MSEDCL, there is a need to promote the consumption from MSEDCL. Apart from optimum utilisation of all sources of power, MSEDCL will also get additional revenue from the subsidising HT categories. MSEDCL further submits that, benefit of increased revenue as a result of increased consumption will get passed through in tariffs during future truing up. This will be a win-win situation for all stakeholders including consumers. Hence, MSEDCL requests the Hon’ble Commission to approve the above proposal and consider the said rebate as a part of ARR. 9.10 Prepaid Meter Rebate 9.10.1 It was difficult for MSEDCL to persuade the consumers to shift to pre-paid metering in the absence of any discount. Further to this, activities like meter reading, preparation and distribution of bills and payment collection takes considerable time and the costs associated with such processes is a significant amount that is being charged to the consumers. If prepaid meter is opted by the consumers, such costs will decrease and hence the consumers get benefited. In view of this, the Hon’ble Commission in its Tariff Order as dated 12th September 2010 (in Case No. 111 of 2009) has approved prepaid meter rebate of 5%. 9.10.2 MSEDCL submits that the consumers paying regular bills within the timelines MSEDCL January 20 207 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition stipulated get prompt payment discount of 1%. Further, for normative working capital, the Hon’ble Commission provides interest rate of about 8%-10% p.a. which is less than 1% per month. For Security Deposit the Hon’ble Commission provides interest at Bank Rate which is 6 to 6.50% p.a. Further, the interest rates provided for bank deposits are also in the range of 6%-8% per annum. In view of the same, MSEDCL submits that the existing discount of 5% is much high which comes to 60% per annum which was initially given as promotional activity and there is a need to correct the same. 9.10.3 The rebate appears to be quite high and considering saving in cost from implementation of prepaid meters, MSEDCL proposes to reduce the prepaid meter rebate to 2% of the consumer’s total monthly bill. MSEDCL also submits that even after reduction to 2%, it is still attractive and higher than prompt payment discount. 9.10.4 MSEDCL humbly requests the Hon’ble Commission to allow the Prepaid Meter Rebate as proposed above. 9.11 kVA based Fixed Charges for Loads < 20 kW & consideration of Load in kVA instead of kW 9.11.1 MSEDCL submits that presently tariff is categorised as per the Sanctioned Load in kW. For categories such as LT Commercial, LT Public Services and LT Industrial, the fixed charges for 0-20 kW are based on Rs./Connection/Month. The consumers above 20kW in these categories are billed on the contract demand basis (kVA) of the consumer i.e. Rs./kVA/Month. Hence it is necessary to divide categories as per contract demand of the consumer. Following cases highlights the necessity for contract demand as a basis for categorisation. Case 1:- If consumer having 20 kW sanctioned load uses the same load at 0.7 P.F. then demand of the consumer will be =20/0.7=28.57 kVA. Case 2 :- If consumer having 25 kW sanctioned load uses the same load at Unity P.F. then demand of the consumer will be =25/1=25 kVA. 9.11.2 In Case 1 consumer uses more contract demand than Case 2 but still gets billed MSEDCL January 20 208 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition at only fixed charge of Rs./Connection/Month because of sanctioned load is below 20 kW. Hence it is necessary to correlate slabs of tariff in kVA also. 9.11.3 In view of the above, MSEDCL suggests that the sub slabs in the 3 Phase LT Categories (wherever applicable) needs to be on the basis of kVA only. Based on the recorded demand, the consumer shall be billed on Rs./kVA/Month for that month and if the consumer crosses the 20kVA limit on three instances in a year, he shall be categorized in higher slab permanently. Before, such revision, MSEDCL shall give 15 days’ notice to such consumer. MSEDCL shall implement the higher slab tariffs in the next billing cycle. Hon’ble Commission has given similar ruling in the Order dated 1st January 2019 in Case No. 60 of 2018. However, if the consumer is willing to reduce its demand back to the previously allocated demand, then MSEDCL would monitor the load of the consumer for 3 consecutive months before switching it back to the previously allocated lower tariff category. Further, all consumers shall be charged for minimum demand of 1 kVA even if a consumer’s demand is below 1 kVA. 9.11.4 In a similar note, many utilities have been following Rs./kVA/Month billing for LT categories. Below tabular brief from respective tariff orders illustrates the applicability of kVA based billing among various LT categories. State West Bengal Category Having kVA Based Demand Charges LV-All Categories, MV-All Categories Delhi LT-Commercial, LT-Public Utilities, LT-Advertisements & Hoardings LT-Commercial >500Units consumption, LT-Medium Industrial, LT-Bulk Supply LT-EV Charging Stations Rajasthan Karnataka Madhya Pradesh Punjab LT-Commercial >10kW, LT-Agricultural (upto 150HP), LT-EV Charging Stations LT-Domestic >50 kW, LT-Commercial >20kW, LTPublic Lighting, LT-Bulk Supply, PwD Hospitals 9.11.5 Since kVA based tariff is proposed to be introduced for 0-20 kVA Industries, MSEDCL January 20 209 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Commercial, Public Services in 3 phase LT category, for the first time, in case, consumer exceeds his contract demand (in kVA) but remains within 20 kVA, then penalty for exceeding contract demand will be exempted for first three events in a calendar year only up to first April 2021. Thereafter, penalty will be levied as per the applicable rates. Further, if such consumer (0-20 kVA) exceeds 20 kVA demand, then he will be charged the applicable penalty. 9.11.6 MSEDCL submits that for consumers having single phase connections (upto 40 amperes /7.5 kW) in 0-20 kVA Industries, Commercial, Public Services in LT category, MSEDCL shall continue to levy fixed charges on Rs./Connection/Month as per the proposed tariff. 9.11.7 MSEDCL further submits that following additional considerations shall be applied to LT category 0-20 kVA consumers: Grace Period: These consumers will get 3 months of grace period for changing their sanctioned load and applicability of kVA based demand charges ; the impact of sales or revenue for such usage can always be taken care of in the true up mechanism. Billing Demand Determination: As per the provisions of “Miscellaneous and General Charges” of the applicable Tariff Order. Billing Demand of these consumers shall be determined as per the current practice used for consumers with load above 20 kVA i.e. Maximum of actual MD recorded OR 60% of the Contract Demand. Contract Demand: Unless specified by the consumer, Contract Demand shall be derived from sanctioned load in kW. Further, for conversion of kW into kVA, power factor of 90% shall be applied. In case consumer seeks to change/modify his sanctioned load, he can apply for the same as per the provisions of the prevailing Regulations. Contract Demand Violations: If the consumer crosses the 20kVA limit on three instances in a year, he shall be categorized in higher slab permanently. Before, such revision, MSEDCL shall give 15 days’ notice to such consumer. MSEDCL shall implement the higher slab tariffs in the next billing cycle. 9.11.8 In view of the above, MSEDCL humbly requests the Hon’ble Commission to MSEDCL January 20 210 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition allow the kVA based demand charges for LT category as proposed above. 9.12 Grid Support Charges for Rooftop Net Metering Arrangements 9.12.1 MSEDCL submits that it has always supported the renewable energy. The current RE Contracted capacity by MSEDCL is 10795 MW and Installed Capacity is 7654 MW which is one of the highest in the Country. 9.12.2 The net metering does help MSEDCL in meeting the RPO targets and cost for purchase of solar energy gets saved. However, the resultant impact of such net metering is much more on other consumers of MSEDCL due to under recovery of infrastructure costs, CSS from such Net metering systems etc. 9.12.3 MSEDCL encounters challenges due to continuous addition of rooftop renewable energy systems. Installation of such facility not only reduces the utilisation of MSEDCL’s distribution network but also disturbs the power planning and results into stranded tied-up capacity of generation. As such Net metering consumers end up paying much lower charges for keeping ready the network and generation capacity, which was earlier setup/tied-up for all consumers including these consumers. The burden of unrecovered expenses gets passed on to other consumers of MSEDCL. 9.12.4 As per the approved tariff, a part of the fixed cost is being recovered through wheeling charges on per unit basis. The solar energy is generated during daytime and after self-consumption by the consumer the balance energy is fed into the grid. Due to its combined impact, the utility has to back down thermal generation but is obligated to pay the same fixed cost to generators. When there is no Solar Generation (evening, seasonal change, technical problem in system etc.), the consumer draws full power as per requirement from the grid and utility has to keep network and generators on bar ready to feed this demand. The consumer is using the grid as a storage system for his solar rooftop arrangement under net metering and at the same time loading the balance costs on other consumers of the distribution utility such as generators fixed cost, infrastructure cost recovery, CSS etc. Thus, the burden of such unrecovered expenses from net metering systems is passed on to other consumers of MSEDCL. MSEDCL January 20 211 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 9.12.5 MSEDCL further submits that Net Metering facility is being utilized mostly by high end LT/ HT consumers which are subsidizing consumers and in the event of any decrease in consumption by these high end consumers from Distribution Licensee, it has a direct impact by way of increase in tariff of all consumers due to under recovery. With increased Net Metering system installations, more and more consumers are becoming subsidized consumers. The exponential rise in the use of Net Metering will greatly affect the delicate tariff structure designed in line with the Electricity Act and National Tariff Policy with the provision of Cross subsidy mechanism for giving supply to poor consumers and agricultural consumers at low tariff. Thus, the cross subsidy balance inbuilt in the tariff structure will get disturbed. 9.12.6 The Hon’ble Commission in the MERC Grid Interactive Rooftop Renewable Energy Generating Systems Regulations, 2019, has provided for levy of Grid Support Charges on the generated energy under Net Metering systems. The excerpts of the relevant clauses are given below: “11.5 The Commission may determine in the retail Tariff Order such Grid Support Charges to be levied on the generated energy under Net Metering systems which shall cover balancing, banking and wheeling cost after adjusting RPO benefits, avoided distribution losses and any other benefits accruing to the Distribution Licensee. These Grid Support Charges would be determined consumer tariff category wise, based on the proposal of the Distribution Licensee in its retail supply Tariff Petition, supported by adequate justification: Provided that the consumers of all Categories having Sanctioned Load up to 10 kW shall be exempted from payment of Grid Support Charges for Net Metering systems:..” 9.12.7 In accordance with the above provision of the MERC Net Metering 2019 Regulations, MSEDCL hereby proposes Grid Support Charges for Rooftop Net Metering systems as discussed in following paragraphs. 9.12.8 MSEDCL submits that as per the Net Metering Regulations 2019, the Grid Support Charges cover balancing, banking and wheeling cost after adjusting MSEDCL January 20 212 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition RPO benefits, avoided distribution losses and any other benefits accruing to the Distribution Licensee. 9.12.9 MSEDCL submits that the fixed cost component of its cost gets recovered partially through demand/fixed charges. However, the variable charges along with the fixed cost component built into it remains unrecovered. It is further submitted that due to consumer opting for Net Metering arrangement, MSEDCL shall save only variable component of power purchase cost and T&D losses thereon. Accordingly, considering the category wise variable charges, marginal variable cost of power purchase, applicable wheeling and intra state transmission losses, MSEDCL has proposed the Grid Support Charges for Rooftop Net Metering Arrangements. For representation purpose, MSEDCL has shown the computation for FY 20-21 in following table. MSEDCL January 20 213 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 186: Proposed Grid Support Charges for Rooftop Net Metering Arrangements (FY 20-21) Category Variable Charge Marginal Cost of Power Purchase Rs./kVAh Rs./kWh HT I HT - Industry HT 7.88 3.38 EHV 7.11 3.38 HT I (B): HT - Industry (Seasonal) HT 8.17 3.38 EHV 7.40 3.38 HT II: HT – Commercial HT 12.47 3.38 EHV 11.70 3.38 HT III : HT - Railways/Metro/Monorail Traction HT 7.97 3.38 EHV 7.20 3.38 HT IV: HT - Public Water Works HT 7.27 3.38 EHV 6.50 3.38 HT V(A): HT - Agriculture Pumpsets HT 4.67 3.38 EHV 3.90 3.38 HT V(B): HT - Agriculture - Others HT 6.17 3.38 EHV 5.40 3.38 HT VI: HT - Group Housing Societies (Residential) HT 6.77 3.38 EHV 6.00 3.38 HT VIII(A): HT - Temporary Supply Religious (TSR) HT 4.67 3.38 EHV 3.90 3.38 HT VIII(B): HT - Temporary Supply Others (TSO) HT 13.17 3.38 EHV 12.40 3.38 HT VIII(B): HT - Temporary Supply Others (TSO) Total 17.38 HT IX: HT - Public Services HT IX(A): HT - Public Services-Govt. Edu. Institutions and Hospitals HT 8.77 3.38 EHV 8.00 3.38 HT IX(B): HT - Public Services-Others HT 10.67 3.38 EHV 9.90 3.38 HT X: HT – Electric Vehicle Charging Station HT 6.17 3.38 EHV 6.17 3.38 Category Rs./kWh Rs./kWh LT Residential LT I(A): LT - Residential-BPL 1.36 3.38 LT I(B): LT - Residential 1-100 units 4.45 3.38 101-300 units 8.45 3.38 301-500 units 11.05 3.38 Above 500 units 12.65 3.38 LT II: LT - Non-Residential (A) (i): 0 – 20 kVA 9.05 3.38 (B): >20 kVA and ≤ 50 kVA 10.65 3.38 (C): >50 kVA 12.75 3.38 LT III: LT - Public Water Works (PWW) (A): 0-20 KVA 3.45 3.38 (B): >20 kVA and ≤ 50 kVA 4.75 3.38 (C): >50 kVA 6.05 3.38 LT IV(C): LT - Agriculture Metered – Others 4.85 3.38 LT V (A): LT - Industry - Powerlooms (i): 0-20 kVA 6.05 3.38 (ii): Above 20 KVA 7.45 3.38 LT V(B): LT - Industry - General (i): 0-20 kVA 6.15 3.38 (ii): Above 20 kVA 7.05 3.38 LT VI: LT - Street Light (A): Grampanchayat; A B & C Class Municipal Council 6.05 3.38 (B): Municipal corporation Area 7.15 3.38 LT VII: LT - Temporary Connection (A): LT - Temporary Supply Religious (TSR) 4.55 3.38 (B): LT - Temporary Supply Others (TSO) 14.35 3.38 LT VIII: LT - Advertisements and Hoardings 13.55 3.38 LT IX: LT - Crematorium and Burial Grounds 4.55 3.38 LT X (A) - Public Services – Govt. (i): ≤ 20 kVA 4.85 3.38 (ii): >20 - ≤ 50 kVA 5.65 3.38 iii): >50 kVA 6.85 3.38 LT X(B) - Public Services - Others (i): ≤ 20 kVA 6.95 3.38 (ii): >20 - ≤ 50 kVA 8.25 3.38 iii): >50 kVA 8.75 3.38 LT XI – Electric Vehicle Charging Station 6.15 3.38 MSEDCL January 20 Intra State Transmission Loss % Wheeling Loss Grid Support Charge % Rs./kVAh 3.74% 3.74% 7.50% 4.08 3.60 3.74% 3.74% 7.50% 4.37 3.89 3.74% 3.74% 7.50% 8.67 8.19 3.74% 3.74% 7.50% 4.17 3.69 3.74% 3.74% 7.50% 3.47 2.99 3.74% 3.74% 7.50% 0.87 0.39 3.74% 3.74% 7.50% 2.37 1.89 3.74% 3.74% 7.50% 2.97 2.49 3.74% 3.74% 7.50% 0.87 0.39 3.74% 7.50% 9.37 9.02 3.74% 3.74% 7.50% 4.97 4.49 3.74% 3.74% 7.50% 6.87 6.39 3.74% 3.74% 7.50% 2.37 2.65 Rs./kWh 3.74% 12.00% 3.74% 3.74% 3.74% 3.74% 12.00% 12.00% 12.00% 12.00% 0.46 4.46 7.06 8.66 3.74% 3.74% 3.74% 12.00% 12.00% 12.00% 5.06 6.66 8.76 3.74% 3.74% 3.74% 3.74% 12.00% 12.00% 12.00% 12.00% 0.76 2.06 0.86 3.74% 3.74% 12.00% 12.00% 2.06 3.46 3.74% 3.74% 12.00% 12.00% 2.16 3.06 3.74% 3.74% 12.00% 12.00% 2.06 3.16 3.74% 3.74% 3.74% 3.74% 12.00% 12.00% 12.00% 12.00% 0.56 10.36 9.56 0.56 3.74% 3.74% 3.74% 12.00% 12.00% 12.00% 0.86 1.66 2.86 3.74% 3.74% 3.74% 3.74% 12.00% 12.00% 12.00% 12.00% 2.96 4.26 4.76 2.16 3.74% % - 214 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 9.12.10 Following table provides the category wise and year wise proposed Grid Support Charges for Rooftop Net Metering Arrangements. Table 187: Grid Support Charges for Rooftop Net Metering Arrangements (HT Category) Category HT I HT - Industry HT EHV HT I (B): HT - Industry (Seasonal) HT EHV HT II: HT – Commercial HT EHV HT III : HT - Railways/Metro/Monorail Traction HT EHV HT IV: HT - Public Water Works HT EHV HT V(A): HT - Agriculture Pumpsets HT EHV HT V(B): HT - Agriculture - Others HT EHV HT VI: HT - Group Housing Societies (Residential) HT EHV HT VIII(A): HT - Temporary Supply Religious (TSR) HT EHV HT VIII(B): HT - Temporary Supply Others (TSO) HT EHV HT IX: HT - Public Services HT IX(A): HT - Public Services-Govt. Edu. Institutions and Hospitals HT EHV HT IX(B): HT - Public Services-Others HT EHV HT IX : HT - Public Services Total HT X: HT – Electric Vehicle Charging Station HT EHV MSEDCL FY 2020-21 Rs./kVAh FY 2021-22 Rs./kVAh FY 2022-23 Rs./kVAh FY 2023-24 Rs./kVAh FY 2024-25 Rs./kVAh 4.08 3.60 4.07 3.59 4.05 3.57 4.03 3.57 3.96 3.52 4.37 3.89 4.37 3.89 4.35 3.87 4.33 3.87 4.29 3.85 8.67 8.19 8.57 8.09 8.45 7.97 8.33 7.87 8.19 7.75 4.17 3.69 4.27 3.79 4.35 3.87 4.43 3.97 4.49 4.05 3.47 2.99 3.57 3.09 3.65 3.17 3.73 3.27 3.79 3.35 2.37 1.89 2.47 1.99 2.55 2.07 2.63 2.17 2.69 2.25 2.97 2.49 3.07 2.59 3.15 2.67 3.23 2.77 3.29 2.85 9.37 9.02 9.67 9.19 9.95 9.47 10.23 9.77 10.49 10.05 4.97 4.49 4.97 4.72 4.95 4.61 4.93 4.92 4.89 5.02 6.87 6.39 6.87 6.39 6.85 6.37 6.83 6.37 6.79 6.35 2.37 2.65 2.59 2.09 2.55 2.07 2.63 2.17 2.69 2.25 January 20 215 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 188: Grid Support Charges for Rooftop Net Metering Arrangements (LT Category) Category LT Residential LT I(B): LT - Residential 1-100 units 101-300 units 301-500 units Above 500 units LT II: LT - Non-Residential (A) (i): 0 – 20 kVA (B): >20 kVA and ≤ 50 kVA (C): >50 kVA LT III: LT - Public Water Works (PWW) (A): 0-20 KVA (B): >20 kVA and ≤ 50 kVA (C): >50 kVA LT IV(C): LT - Agriculture Metered – Others LT V (A): LT - Industry - Powerlooms (i): 0-20 kVA (ii): Above 20 KVA LT V(B): LT - Industry - General (i): 0-20 kVA (ii): Above 20 kVA LT VI: LT - Street Light (A): Grampanchayat; A B & C Class Municipal Council (B): Municipal corporation Area LT VII: LT - Temporary Connection (A): LT - Temporary Supply Religious (TSR) (B): LT - Temporary Supply Others (TSO) LT VIII: LT - Advertisements and Hoardings LT IX: LT - Crematorium and Burial Grounds LT X (A) - Public Services – Govt. (i): ≤ 20 kVA (ii): >20 - ≤ 50 kVA iii): >50 kVA LT X(B) - Public Services - Others (i): ≤ 20 kVA (ii): >20 - ≤ 50 kVA iii): >50 kVA LT XI – Electric Vehicle Charging Station FY 2020-21 Rs./kWh FY 2021-22 Rs./kWh FY 2022-23 Rs./kWh FY 2023-24 Rs./kWh FY 2024-25 Rs./kWh 4.46 7.06 8.66 4.56 6.96 8.56 4.63 6.83 8.43 4.69 6.69 8.39 4.73 6.53 8.33 5.06 6.66 8.76 5.16 6.86 8.86 5.23 7.03 8.93 5.29 7.19 8.89 5.33 7.33 8.83 2.06 2.06 2.13 2.19 2.23 2.06 3.46 2.16 3.46 2.33 3.53 2.49 3.59 2.63 3.63 2.16 3.06 2.36 3.26 2.53 3.43 2.69 3.59 2.83 3.73 2.06 3.16 2.06 3.26 2.13 3.33 2.19 3.39 2.23 3.43 10.36 9.56 10.66 9.86 10.93 10.13 11.19 10.39 11.43 10.63 1.66 2.86 1.76 3.06 1.83 3.23 1.89 3.39 2.03 3.53 2.96 4.26 4.76 2.16 3.16 4.56 5.06 2.36 3.33 4.83 5.33 2.53 3.49 5.09 5.59 2.69 3.63 5.33 5.83 2.83 9.12.11 MSEDCL requests the Hon’ble Commission to approve the levy of Grid Support charges on generated energy for Net Metering systems as proposed above by MSEDCL; 9.12.12 MSEDCL submits that the Grid Support Charges for Rooftop Net Metering Arrangements shall vary depending on Any cost approved by Hon’ble Commission for Genco/Transco in their respective tariff Orders or by way of a separate Order. Variation in any cost approved by Hon’ble Commission affecting MSEDCL tariff. MSEDCL’s REC requirement to fulfil the shortfall in meeting the RPO Targets The prevailing monthly market rate for RECs MSEDCL January 20 216 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 9.12.13 The RPO benefits, being a variable element, shall be adjusted at the year-end i.e. at the time of settlement of banked units and after assessment of REC requirement, as per the actual monthly REC Rates and consumption during the respective month and financial impact of net metering of below 10 kW consumers. 9.12.14 MSEDCL also submits that the benefit of RPO (REC rate) shall be as per the prevailing market rates. Additionally, in case, MSEDCL does not require the energy for RPO fulfilment, the benefit of RPO to Net metering consumers shall be treated as Zero. Benefit of RPO shall be adjusted only till the time MSEDCL has RPO shortfall. Further, if the consumer is obligated entity (above 1 MW), then also such benefit of RPO shall be treated as Zero for that consumer. 9.12.15 MSEDCL further submits that the Net Metering Regulations 2019 provides that the consumers having Sanctioned Load up to 10 kW shall be exempted from payment of Grid Support Charges for Net Metering systems. MSEDCL submits that such loss for exemption from paying the Grid Support Charges needs to be recovered from the consumers having Sanctioned Load above 10 kW so as to avoid the burden on consumers not opting for Net Metering. The impact of this shall be computed by considering the same category wise GSC as proposed above and shall be passed on to >10 kW Net Metering consumers during the year-end settlement as proposed in above para 9.12.13. 9.12.16 MSEDCL submits that as per the above table and assumptions, MSEDCL has computed the Grid Support Charges for all categories. However, for certain categories such as LT Residential 0-100 Units, LT PWW (>20 kVA upto 50 kVA), LT AG Metered Others, LT Temporary Supply Religious, LT Crematoriums and Burial Grounds, LT Public Services-Govt. (0-20 kVA) and HT AG Pump sets & HT Temporary Supply Religious, considering the adjustment of RPO benefit and floor price of Rs. 1.00 per unit of REC, such charges may be Nil for these categories. Hence, MSEDCL has not proposed the Grid Support charges for these categories in this Petition. However, the same shall be reviewed during Mid Term Review Process. MSEDCL January 20 217 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 9.12.17 MSEDCL further submits that the applicability of Grid Support Charges for Rooftop Net Metering Arrangements shall be as follows: RE generated Units All Generated Units Banked Units Applicable Charges Grid Support Charges Wheeling losses 9.12.18 MSEDCL submits that in case of HT Consumers having rooftop net metering arrangements, the kVAh consumption recorded in the net meter shall be used for commercial settlement for banked energy after considering wheeling losses. The generated units shall be converted to kVAh by considering the Unity Power Factor. The settlement shall be done on kVAh basis. 9.12.19 Further, for Net Billing arrangement, no grid support charges for rooftop RE systems shall be levied. 9.12.20 MSEDCL submits that the financial impact of the Grid Support Charges is not considered at present due to uncertainty of usage by consumers. The impact on revenue for such charges will be considered at the time of final true up. 9.13 Additional Demand/Fixed Charges for Rooftop Grid Connected RE Systems not opting for Net Metering or Net Billing Arrangement 9.13.1 MSEDCL submits that the Hon’ble Commission, in the MERC Grid Interactive Rooftop Renewable Energy Generating Systems Regulations, 2019, has provided for the additional Fixed Charges or Demand Charges and any other Charges for consumers of Rooftop Grid Connected RE Systems not opting for Net Metering or Net Billing Arrangement. The relevant extract of the Regulations are given below: “7.9 Grid Connected Renewable Energy Generating Systems connected behind the Consumer’s meter, and not opting for either Net Metering Arrangement or Net Billing Arrangement, shall be allowed only after prior MSEDCL January 20 218 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition intimation to the respective Distribution Licensee: …..Provided further that the Commission may determine additional Fixed Charges or Demand Charges and any other Charges for such Grid Connected systems excluding Non-fossil fuel based Co-generation plants, in the retail Tariff Order, if Distribution Licensee proposes such additional Fixed Charges or Demand Charges and any other Charges for such systems… Provided also that in case the Consumer installs Renewable Energy Generating Systems behind the Consumer’s meter without prior intimation to the respective Distribution Licensee, then the total additional liabilities in terms of additional Fixed Charges or Demand Charges and any other Charges for such systems, shall be levied at twice at the determined rate for such period of default.” 9.13.2 MSEDCL submits that it is observed that certain consumers connected at EHV/HT Level are installing rooftop RE Projects without informing Distribution Licensee. Such Rooftop RE systems, though connected behind the Consumer’s meter, take support of Grid and the network of the Distribution Licensee. Further, installation of such facility reduce the utilisation of Transmission/Distribution Network and thereby such consumer pay lower charges for such network setup earlier for it. Such unrecovered part of expenses is then loaded on other consumers of the Distribution Licensee. 9.13.3 In view of the above, MSEDCL hereby proposes Additional Fixed/Demand Charges for Grid Connected Renewable Energy Generating Systems connected behind the Consumer’s meter, and not opting for either Net Metering Arrangement or Net Billing Arrangement along with the procedure for intimating MSEDCL as stipulated below. Consumer willing to install such Rooftop RE Systems shall intimate MSEDCL with the type and capacity of such system. Additional Fixed/Demand Charges as given below shall be applicable on installed capacity per kWp per month over and above the applicable charges for the respective consumer category. 9.13.4 MSEDCL has considered the projected ARR for respective year of the Control MSEDCL January 20 219 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition period and bifurcated it into fixed and variable costs. The per unit fixed cost recovery required is computed using expected average monthly generation. The units generated by 1 kW rooftop solar plant are computed assuming annual CUF of 19%. Further, nominal 10% demand/fixed charges is added to the computed demand/fixed charges so as to encourage net Metering or Net Billing arrangement. The additional fixed/demand charges computed in Rs./kW/month basis are shown below: Table 189: Additional Fixed/Demand Charges for Grid Connected RE Generating Systems connected behind the Consumer’s meter Particulars Actual FC Recovery Required (Rs/Unit) Monthly units generated by 1 kw rooftop SPV (CUF-19%) Fixed Charges to be recovered (Rs./kW/Month) FY 20-21 FY 21-22 FY 22-23 FY 23-24 FY 24-25 4.23 3.86 3.83 3.81 3.73 138.7 645 138.7 589 138.7 584 138.7 581 138.7 568 9.13.5 In addition to the above, the subsidising consumers shall pay Cross Subsidy Surcharge as proposed by MSEDCL for the respective year of the Control Period for compensating the common consumers of MSEDCL for the current level cross subsidy. 9.13.6 MSEDCL request the Hon’ble Commission to approve the Additional Fixed/Demand Charges along with CSS for Grid Connected Renewable Energy Generating Systems connected behind the Consumer’s meter, and not opting for either Net Metering Arrangement or Net Billing Arrangement as proposed by MSEDCL. 9.13.7 MSEDCL submits that the financial impact of the Additional Fixed/Demand Charges is not considered at present due to uncertainty of usage by consumers. The impact on revenue for such charges will be considered at the time of final true up. 9.14 InSTS Charges for Open Access Consumers 9.14.1 Hon’ble Commission in its Order dated 14th June 2019 in Case No. 361 of 2018 directed MSEDCL to submit the details of revenue collected on account of transmission charges from partial OA Consumers for the period of FY 2016-17 MSEDCL January 20 220 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition to FY 2019-20 in its next tariff Petition. Accordingly, MSEDCL submits the details of transmission charges collected from partial OA Consumers in following table. Particulars Amount in Rs. Crs FY 2016-17 284.82 FY 2017-18 220.17 9.14.2 MSEDCL would like to submit that the Distribution Licensees may be allowed to retain the transmission charges collected from partial Open access consumers. It is pertinent to note that the demand of partial OA consumers is embedded within the demand of the Licensee. Hence, the Transmission Charges payable by the Distribution Licensee also includes the share of Transmission Charges attributable to Partial Open Access consumers. Therefore, Distribution Licensees must recover any such charges from partial open access consumers to avoid any burden on their regular consumers. 9.14.3 Alternatively, while calculating the Base TCR of Distribution Licensees for determination of InSTS charges, the CPD/NCPD of Distribution Licensees should be exclusive of the open access capacity of partial open access consumers. This will ensure correct Transmission Charge liability of the Distribution Licensees corresponding to their own consumers. By including the open access capacity of partial open access consumers, STU is getting paid doubly for the same demand. Following table provides details of partial open access consumers and its impact on MSEDCL. MSEDCL January 20 221 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Particulars Base TCR approved for MSEDCL MSEDCL share in TTSC Transmission charges Partial OA capacity Amount paid by MSEDCL to STU for OA Consumers Amount collected by MSEDCL from partial OA Consumers Loss to MSEDCL Unit FY 16-17 FY 17-18 FY 18-19 MW 15,657 16,663 17,891 Rs. Crs Rs. Crs/MW MW 3,837 0.25 1,838 4,797 0.29 1,274 4,288 0.24 1,224 Rs. Crs 450 367 293 Rs. Crs 285 220 182 Rs. Crs 166 147 111 9.14.4 MSEDCL submits that since the Base TCR approved for MSEDCL already includes the Partial OA capacity, the transmission charges being paid to STU are inclusive of the charges meant for the Partial Open Access consumers. If the amount collected from partial OA Consumers by MSEDCL is again paid to STU, it is getting paid twice for the demand corresponding to partial OA consumers which will unnecessarily add burden to common consumers of MSEDCL. 9.14.5 Therefore, MSEDCL submits that the transmission charges collected from partial Open access consumers may be allowed to retain by the Distribution Licensees. This will not only help to lessen the loss to MSEDCL but also help to avoid the unnecessary burden on the common consumers of MSEDCL. 9.14.6 Hence, MSEDCL humbly requests the Hon’ble Commission it may be allowed to retain the transmission charges collected from partial Open access consumers and further requests the Hon’ble Commission to devise a mechanism to recover the complete amount of Transmission Charges due to OA consumers. MSEDCL has raised this issues many times before the Hon’ble Commission through submissions in Petition and comments on Draft Open Access Regulations. MSEDCL January 20 222 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 9.15 Change in Slabs for Commercial and Public Services 9.15.1 MSEDCL submits that the Ministry of Power has constituted a Committee for simplification of tariff categories. One of the objectives of the said Committee was reduction in number of tariff categories. 9.15.2 Ministry of Power has appointed a Committee for Tariff Simplification and another for Tariff Rationalization to suggest measures for simplification of tariff structure & improve transparency so as to possibly enhance operational performance of the distribution utilities. The said Committee has strongly advocated for merging of categories and simplify the tariff structure. MSEDCL submits that simplification of tariff structure is one of the major reason for this proposal. Over the years, there have been additions in the slabs /sub-slabs in tariff categories of MSEDCL. There is a need to simplify and rationalize the tariff structure. 9.15.3 As a first step towards the reduction in number of tariff categories, MSEDCL proposes that the consumption based sub-slabs in 0-20 kVA for LT Commercial and LT Public Services may be done away with and just a single tariff category 0-20 kVA may be kept. Due to the fact that a large number of consumers are shifting to rooftop renewable energy, the high consumption consumers will automatically shift to lower tariff slab as a result of the merger of these tariff slabs. This will enable simplification of tariff structure. 9.15.4 Considering the proposed change in kVA based Fixed Charges for Loads less than 20 kW for 3 phase consumers, the energy charges for such consumers are proposed not to increase substantially and thus this will not have impact on the small consumer due to such change. 9.16 Standby Charges for Captive Power Producers 9.16.1 The origin of levy of additional standby demand charges is in the Commission’s Order dated 8th September, 2004 in Case Nos. 55 and 56 of 2003 (hereby referred as ‘the CPP Order’) wherein, it provided power purchase and other dispensation for fossil fuel based Captive Power Plants (CPPs). Further, the Commission has allowed recovery of additional demand charges from MSEDCL January 20 223 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition embedded Captive Power Plants (CPP) though it’s respective Tariff Orders. The additional standby demand charges of Rs. 20/- per kVA is being levied to embedded CPP holders which were introduced long back and not been revised till date. 9.16.2 MSEDCL submits that the CPP Order determining standby charges for CPP was issued more than thirteen years back, considering the then prevailing power supply situation wherein, the circumstances have emerged to be precisely different at present. These charges are still continued and are on much lower side in comparison to capacity charges payment made by MSEDCL for serving standby contracted capacity. MSEDCL submits that such charges should be revised to fit the present power scenario where MSEDCL gets affected by over drawl from these CPP holders in present DSM Regulations 2019. 9.16.3 CPP consumers having captive generation facilities who are synchronised with the grid, require standby facility throughout the year. The stand-by arrangement is for the benefit of the consumers so that they receive uninterrupted electricity supply and the stand-by charges are the premium (as fixed charges) on such guaranteed supply, which is irrespective of whether any supply is actually drawn under the stand-by arrangement or not. As per existing dispensation, MSEDCL can charge additional demand charges on embedded CPP consumers, only when it is being utilized and only up to the extent of use. 9.16.4 MSEDCL over the time observed that, a CPP Unit trips due to faults resulting in drawl of power from MSEDCL. This may result in over drawl of power from the Grid by MSEDCL, which also affects the State Grid as well as impacts MSEDCL financially in terms of deviation charges. Moreover, such over-drawl may lead to power deficit situation for the existing consumers of MSEDCL and may result in grid instability. Further, MSEDCL has to plan its power purchase to cater such additional demands. It is observed that if penal charges for exceeding the demand on account of unplanned shutdown of CPP are computed based on existing provisions, then it works out to be minuscule and does not provide adequate compensation. MSEDCL January 20 224 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 9.16.5 The Commission in the last MTR Order already observed that: “9.35.10..…..the Commission has already determined the Stand-by charges of Rs. 20/kVA for the embedded CPPs. The Commission notes that the same said charges, which has been worked in the past, might require some revision. The same shall be taken up during next MYT Order for the new Control Period.” 9.16.6 Thus, MSEDCL submits that the additional standby charges for CPPs may be revised in the following manner considering the present power scenario. Demand Charges on Standby Contracted Capacity By its very nature the standby demand has two scenarios as follows. o Scenario 1: Standby demand is not utilised. o Scenario 2: Standby demand is utilised in planned /unplanned shutdown. 9.16.7 Following dispensation is prayed before the Hon’ble Commission: Particular Energy Charges Penal Additional Demand Charges Demand Charges on standby contracted capacity When standby demand is not utilized Except planned shut down When standby demand is utilized Energy charge as Planned approved in Tariff shutdown Order for relevant category Applicable Energy charge for temporary Unplanned category; energy shutdown/break consumption due to down unplanned shut down will be calculated on MSEDCL 25% of applicable demand charges on standby contracted capacity As approved in tariff Order for relevant category on total contracted standby capacity (on monthly basis). 25% of applicable demand charges on standby contracted capacity January 20 2 times Demand Charges (on monthly basis) in force 225 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Particular Demand Charges on standby contracted capacity Energy Charges prorate basis demand utilized. Penal Additional Demand Charges of 9.16.8 The method stipulated above would reduce the risk borne by CPP consumers, protect MSEDCL consumers from load shedding, compensate the MSEDCL for standby services and is easy to implement and levy. 9.17 Standby Charges for SEZs and Deemed Licensees 9.17.1 It has been observed that many of the SEZ and deemed Licensees do not have standby arrangement. MSEDCL requests Hon’ble Commission to make it compulsory for making standby arrangement for supply of power in case of failure of the source generator. In order to ensure 24x7 reliable and uninterrupted power supplies to its consumers, there are possibilities that such licensees would draw power from grid. Therefore, in order to maintain the grid discipline and to avoid the financial impact of penalty of overdrawal on MSEDCL, MSEDCL requests Hon’ble Commission that SEZ/deemed licensees must have a standby arrangement. 9.17.2 Hon’ble commission, in its MTR order dated 12th September 2018, ruled that many of the deemed licensees have their own standby arrangements, where the demand is fulfilled by DG sets installed in different premises within their licensee area and Hon’ble Commission further stated that these deemed licenses have not shown their concerns or requirement for the standby arrangement. Hon’ble Commission also ruled that there is no legal mandate on SEZs for the Standby Arrangement. 9.17.3 In view of the above, MSEDCL would like to submit that, at present there is no mechanism to ensure whether such standby arrangement in the form of DG sets really exists within the SEZ/Deemed licensee area as ruled by the Hon’ble Commission in MTR Order and even if such arrangement exists whether it is being used at the time of failure of the source generator is not monitored or MSEDCL January 20 226 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition such data is not available. Further, it is to submit that any over drawal can be seen only at the time of FBSM. There is no real time monitoring system with SLDC to ensure that such standby arrangement is being put to use at the time of unavailability of source generator. 9.17.4 It is further to submit that MSEDCL, in its Review Petition on the MTR order, had already submitted the number of instances during which certain SEZs/Indian Railways resorted to over-drawal from the grid. 9.17.5 MSEDCL would further like to bring it to the notice of the Hon’ble Commission the exact details of the time blocks during which schedule of the source generator of M/S Gigaplex (SEZ) was Zero and still there was drawal from the grid. Generator Schedule and Drawal details of M/s Gigaplex is summarized in following table. Time Slot No. 10th Oct 2016 Slot 75 to 96 (18.30 to 24:00) 10th Oct 2016 Slot 1 to 28 (00:00) to (07:00) Generator Schedule Actual Drawal from Grid (kWh) Pool imbalance (kWh) 0 9,611 (9,611) 0 8,537 (8,537) 9.17.6 Similarly, Indian Railways has also resorted to over drawal from Grid when the schedule of the source generator of Indian Railways was curtailed as shown in the table below for FY17-18 (upto 25.03.2018): MSEDCL January 20 227 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Month August September October November December January February March Total Total No. of Time blocks for which Bills prepared (Time Block) Net OD Energy (MUs) 2976 2880 2976 2496 2688 2976 2688 2400 22080 8.1 6.1 10.5 12.9 8.3 13.8 8.0 6.4 74.1 No. of Instance having OD more than 12% Demand (No. of Time Blocks) % 1364 1263 2087 1664 1528 2069 1678 1511 13164 46% 44% 70% 67% 57% 70% 62% 63% 60% No. of Instance having OD more than 100% Demand (Time Block) 123 22 33 347 60 44 57 0 686 9.17.7 MSEDCL thereby submits that if M/s. Gigaplex and M/s. Indian Railways have their own standby arrangement, there was no necessity to draw power from the grid during the unavailability/ curtailed availability of source generator. Thus, it is seen that factual situation is contrary to the ruling of the Hon’ble Commission that the SEZs/ Deemed Licensees have their own standby arrangement. 9.17.8 MSEDCL reiterates that such instances are not only detrimental to the stability of the grid but the undue financial burden of such instances is also getting passed onto the consumers of MSEDCL for no fault on their part and therefore SEZs/ deemed license and Indian Railways must have standby arrangement. 9.17.9 MSEDCL further submits that it has submitted a Letter on 8th February 2019 highlighting the issues pertaining to SEZ. The said Letter is attached as Annexure 9 to this Petition. 9.17.10 MSEDCL thus requests the Hon’ble Commission to make standby arrangement compulsory. In the event, standby arrangement is opted from MSEDCL, allow recovery of standby charges from SEZs or Deemed Licensees at the rate of applicable demand charges for HT Industrial Category. MSEDCL January 20 228 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 9.18 Revision in ToD Rates 9.18.1 MSEDCL submits that Hon’ble Commission in the MTR Order dated 12th September 2018 has observed that revision in ToD slabs and rates thereof would depend on several factors such as change in the load curve, demand side measures, overall system demand management measures in vogue etc. Hon’ble Commission further ruled that as this issue has to be seen in totality across all Licensees, it would take a view on proposals to modify the ToD timeslots and/or ToD slot-wise tariffs in the next Control Period. 9.18.2 In existing TOD tariff concept, rebate or penalty is same in all month irrespective of load pattern, surplus & shortfall in availability. There is no consideration of impact of RE generation which will be one of important change in generation mix. Moreover due to various Govt. of India policies to promote RE generation and as per the RPO Targets set for Utilities by Hon’ble Commission, there is tremendous rise in RE generation is expected. The major rise is in solar generation which has typical shape of inverted hyperbola. There is no or very less generation during specific time period of a day; particularly during 06:00 to 09:00 and during 15:00 to 19:00 Hrs. Considering the demand pattern and expected Solar Generation, MSEDCL has proposed revision in ToD tariff /rates. 9.18.3 MSEDCL is hereby submitting that the existing ToD slabs and Tariffs may be followed with the revision in ToD tariffs as shown in the table below. However, with the increasing share of renewable generations over the last few years, it is necessary to revise ToD slabs so as to change the demand pattern of consumers to enable the utilities to meet their peak demand effectively. MSEDCL shall propose revision in ToD slabs and tariffs based on the existing and upcoming renewable capacity additions and the demand-supply scenario at the time of filing of the next Mid-term review petition. Consumption Slab (kWh) 2200 Hrs-0600 Hrs 0600 Hrs-0900 Hrs & 1200 Hrs-1800 Hrs 0900 Hrs-1200 Hrs 1800 Hrs-2200 Hrs MSEDCL Existing ToD Charge (Rs./kWh) -1.50 0.00 Proposed ToD Charge (Rs./kWh) -1.50 0.00 0.80 1.10 0.60 1.50 January 20 229 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 9.18.4 MSEDCL requests the Hon’ble Commission to approve the revision in ToD Charges as proposed in above table. 9.19 Harmonics Penalty 9.19.1 MSEDCL submits that Central Electricity Authority on 6th February 2019 has notified amendment to the CEA (Technical Standards for Connectivity to the Grid) Regulations, 2007. As per the said amendment, Distribution Licensee and Bulk consumers are required to provide adequate reactive compensation to compensate reactive power requirement in their system. Further, the said amendment also mandates for installation of power quality meter and sharing the recorded data thereof. The relevant extract of the Regulations are reproduced below: “(2) (i) The distribution licensee and bulk consumer shall provide adequate reactive compensation to compensate reactive power requirement in their system so that they do not depend upon the grid for reactive power support. (ii) The power factor for distribution system and bulk consumer shall be within ± 0.95; (3) Voltage and Current Harmonics. – (i) The limits of voltage harmonics by the distribution licensee in its electricity system, the limits of injection of current harmonics by bulk consumers, point of harmonic measurement, i.e., point of common coupling, method of harmonic measurement and other related matters, shall be in accordance with the IEEE 519-2014 standards, as amended from time to time; ….. ….. (iv) The bulk consumer shall install power quality meter and share the recorded data thereof with the distribution licensee with such periodicity as may be specified by the appropriate Electricity Regulatory Commission: 9.19.2 MSEDCL submits that the Regulation 2.1 (i) of the MERC (Electricity Supply code and other Conditions of Supply) Regulations, 2005 defines “Harmonics” as under: MSEDCL January 20 230 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition “Regulation 2.1 (l) “Harmonics” means a component of a periodic wave having frequency that is an integral multiple of the fundamental power line frequency of 50 Hz causing distortion to pure sinusoidal waveform of voltage or current, and as governed by IEEE STD 519-1992, namely “IEEE Recommended Practices and Requirements for Harmonic Control in Electrical Power Systems” and corresponding standard as may be specified in accordance with clause (c) of subsection (2) of section 185 of the Act.” 9.19.3 From the definition, it is understood that the presence of harmonics in electrical systems means that the current and/or voltage are distorted and deviated from the sinusoidal waveform. 9.19.4 MSEDCL further submits that the Regulation 12.1 of MERC Supply Code provides that the certain categories of HT Consumers and LT Consumers (Industrial and Commercial) are required to control the harmonics generated in their system on account of their load. The regulation is reproduced below for ready reference. “12.1 It shall be obligatory for the consumer ……………… Provided that it shall be obligatory for the HT consumer and the LT consumer (Industrial and Commercial only) to control harmonics of his load at levels prescribed by the IEEE STD 519-1992, and in accordance with the relevant Orders of the Commission.” 9.19.5 MSEDCL also submits that Regulation 12.2 MERC Supply Code Regulations 2005 provides for the minimum time period given to the consumer to make necessary changes in their system so as to control harmonics (or) improve the system’s power factor. Further, the said Regulations also set provisions for penalizing the neglecter for failing to do so. This may attract penalty for not controlling harmonics within the prescribed limit. The regulation is reproduced below for ready reference. “12.2 The Distribution Licensee may require the consumer, within a reasonable time period, which shall not be less than three months, to take such effective measures so as to raise the average power factor or control MSEDCL January 20 231 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition harmonics of his installation to a value not less than such norm, in accordance with Regulation 12.1 above Provided that the Distribution Licensee may charge penalty or provide incentives for low / high power factor and for harmonics, in accordance with relevant Orders of the Commission.”(Emphasis Added) 9.19.6 MSEDCL consumers use various non-linear loads in industries and commercial establishments which demand non-sinusoidal currents. Such nonlinear currents are rich in harmonics. Harmonics are currents of higher frequencies i.e. 150 Hz, 250 Hz etc. Such currents cause overheating of transformers, cables, switchgears, causing insulation deterioration and nuisance tripping in control circuits. Excessive current harmonics results into voltage harmonics and poor power quality. Hence, it is necessary to control the harmonics. 9.19.7 Considering the fact that industrial systems have been moving towards nonlinear load equipment, which further result in higher Harmonics in the system. It is pertinent to mention here that higher harmonics in the system lead to increased iron and copper losses in upstream electrical equipment in distribution systems, which do not get metered to the consumer. 9.19.8 MSEDCL is apprehensive of the fact that the increased THD levels (total Harmonic distortion), will have adverse effects on the equipment of the utility, which affects the operational efficiency of the utility and consumers also. 9.19.9 Disadvantages of Harmonics 9.19.10 Following are some of the effects of harmonics on various components: Generators & Transformers Increased heating on account of higher iron & copper losses, affects the machine efficiency and insulation life. Harmonics lead to asymmetrical unbalanced currents which in turn cause stress on insulation provided to neutral conductors in star connected systems and give rise to failure. Power Cables and Capacitor Voltage stress induces higher corona losses, resulting in dielectric failure. MSEDCL January 20 232 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Meters Non-linear voltages and current introduce errors into the measurement circuit results in false readings. Switch gear and Relay The out-of-balance current causes spurious/false operations, might operate false alarms and trips Conductors Increase in losses, heating leads to reducing life of conductors. 9.20 Petitions by MSEDCL in Past Regarding Harmonics 9.20.1 MSEDCL had filed a Petition before the Hon’ble Commission for amendment in SOP Regulations related to Harmonics limits and prayed for effective implementation of Regulation 12.2 of the Supply Code Regulations 2005 (Case No. 34 of 2011). 9.20.2 Hon’ble Commission vide its Order dated 24.12.2012 opined that introduction of penalty for injection of the Harmonics at this stage will be premature. Instead of introduction of penalty, MSEDCL needs to analyse existing level of Harmonics in the system, causes and remedial measures for limiting the same. Hon’ble Commission further observed that MSEDCL needs to arrange program for creating awareness amongst the consumers about effects of Harmonics on the power equipment. 9.20.3 MSEDCL subsequently filed a Petition for removal of difficulties and amendment of Standards of Performance Regulations, 2014 and prayed that the onus of control of Harmonics should be placed on the consumer, in addition to the Distribution Licensee. (Case No. 138 of 2014) 9.20.4 Hon’ble Commission vide its Order dated 17 August, 2015 rejected the claim of MSEDCL citing pendency of response to directives in Case No.34 of 2011. 9.21 Compliance of Directives in Case No.34 of 2011 9.21.1 As per the directives of this Hon’ble Commission, the harmonics measurement study has been carried out by the Petitioner. The study was carried out at MSEDCL January 20 233 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition substation end in Load ON and OFF condition. Additionally, the Petitioner has also carried out measurement of harmonics at various HT consumers. 9.21.2 The measurement of harmonics was carried out by MSEDCL field engineers using Electronic Reference Standard Meter (Make: Zera, Class: 0.2S) available with MSEDCL and the THD is measured at consumer premises as well as at substation end. 9.21.3 Out of the 21,810 HT consumers for whom harmonics were measured, 9,905 consumers has shown the abnormalities. This is about 45% which is very high. 9.21.4 In order, to further confirm the abnormalities, MSEDCL decided to appoint an expert third party agency to undertake measurement of harmonics and analyze the issues involved in respect of sample 100 HT consumers spread all over the state including 25 consumers from each region strictly as per the requirements of IEEE 519 : 1992. This exercise was carried out with the assistance of a third party expert agency in the field of harmonics measurement and analysis in order to cross verify and validate the observations made by MSEDCL field engineers. M/s. SAS Powertech P. Ltd., Pune was awarded the work of measurement of harmonics and analysis thereof. 9.21.5 M/s. SAS, Pune completed the work of measurement of harmonics at selected 100 HT consumer premises in May 2018 and submitted the report with detailed analysis in June 2018. These measurements and recording were carried for 24 hours at each consumer premises at HT PCC between MSEDCL and consumer electrical system. 9.21.6 It was observed that out of 100 HT consumers, 31 consumers were exceeding the permissible limits of TDD compliance, 10 consumers had their TDD at border level. Further, 4 consumers were found exceeding voltage harmonic compliance. 9.22 Regulatory Provisions for Harmonics 9.22.1 IEEE Standard namely “IEEE 519-1992 - IEEE Recommended Practices and Requirements for Harmonic Control in Electrical Power Systems” provides for MSEDCL January 20 234 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition the requirement of harmonics control. 9.22.2 Central Electricity Authority on 6th February 2019 has notified amendment to the CEA (Technical Standards for Connectivity to the Grid) Regulations, 2007. As per the said amendment, Distribution Licensee and Bulk consumers are required to provide adequate reactive compensation to compensate reactive power requirement in their system. Further, the said amendment also mandates for installation of power quality meter and sharing the recorded data thereof. 9.22.3 Further, Regulation 12.1 of MERC (Electricity supply code & other conditions of (supply) Regulation 2005 provides that it shall be obligatory for HT consumers to control harmonics of his loads at level prescribed by IEEE STANDARD 519-1992. 9.22.4 Current distortion limits as per IEEE 519-2014 for general distribution system (120V to 69000V) are as below:- Isc/IL < 20* 20 < 50 50 < 100 100 < 1000 > 1000 Maximum Harmonic Current Distortion in % of IL Individual Harmonic Order (Odd Harmonics) 3≤h< 11 11≤h<I7 17≤h<23 23≤h<35 35≤h≤50 4.0 2.0 1.5 0.6 0.3 7.0 3.5 2.5 1.0 0.5 10.0 4.5 4.0 1.5 0.7 12.0 5.5 5.0 2.0 1.0 15.0 7.0 6.0 2.5 1.4 TDD 5.0 8.0 12.0 15.0 20.0 9.22.5 Current distortion limits as per IEEE 519-2014 for general distribution system rated above 69 kV through 161 kV are as below:- MSEDCL January 20 235 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Isc/IL < 20* 20 < 50 50 < 100 100 < 1000 > 1000 Maximum Harmonic Current Distortion in % of IL Individual Harmonic Order (Odd Harmonics) 3≤h< 11 11≤h<I7 17≤h<23 23≤h<35 35≤h≤50 2.0 1.0 0.75 0.3 0.15 3.5 1.75 1.25 0.5 0.25 5.0 2.25 2.0 0.75 0.35 6.0 2.75 2.5 1.0 0.5 7.5 3.5 3.0 1.25 0.7 TDD 2.5 4.0 6.0 7.5 10.0 9.22.6 Current distortion limits as per IEEE 519-2014 for general distribution system rated > 161 kV are as below:- Isc/IL < 25 25 < 50 ≥50 Maximum Harmonic Current Distortion in % of IL Individual Harmonic Order (Odd Harmonics) 3≤h< 11 11≤h<I7 17≤h<23 23≤h<35 35≤h≤50 1.0 0.5 0.38 0.15 0.1 2.0 1.0 0.75 0.3 0.15 3.0 1.5 1.15 0.45 0.22 TDD 1.5 2.5 3.75 Even harmonics are limited to 25% of the odd harmonic limits. TDD refers to Total Demand Distortion and is based on the average maximum demand current at the fundamental frequency taken at the PCC * All power generation equipment is limited to these values of current distortion regardless of Isc/IL Isc = Maximum short circuit current at the PCC IL = Maximum demand load current (Fundamental) at the PCC h = Harmonic Number 9.22.7 Further, now IEEE 519-2014, has introduced statistical evaluation (Very short and Short time harmonic measurements), having same limits as mentioned in IEEE 519-1992. 9.22.8 MSEDCL further submits that Tamil Nadu Electricity Regulatory Commission MSEDCL January 20 236 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition (TNERC) through its order dated 30.03.12 has permitted the utility to levy harmonic compensation of 15% of respective tariff for High tension consumers for non-compliance of Harmonics limit. The relevant portion from the said Order are reproduced below for ready reference: “10.1.2 Harmonics: As specified in the Supply Code, when the consumer fails to provide adequate harmonic suppression equipment to avoid dumping of harmonics beyond the limits as specified by CEA regulations into Licensee’s distribution system, he is liable to pay compensation at 15% of the respective tariff. As and when the consumer brings down the harmonics within the limit, compensation charges shall be withdrawn. The measurement of harmonics shall be done by the Distribution Licensee using standard meters/equipment in the presence of consumers or their representatives. This compensation provision is applicable to HT-I & HT-III category of consumers. The TANGEDCO shall give three months clear notice to all consumers under these categories stating that they shall pay 15% compensation charges if the harmonics introduced by their load is not within the limits set by CEA. The TANGEDCO shall implement the compensation provision after the three months period if the measured harmonics is more than the limits. “ 9.23 Proposal for Harmonics Penalty 9.23.1 In view of the above, 1) MSEDCL proposes to introduce a harmonics penalty of 5% additional Energy Charges (Wheeling Charges plus Energy Charges) for HT Industrial and Commercial consumers who does not maintain the harmonics levels specified in IEEE STD 519-2014 2) MSEDCL normally carries out quarterly/yearly testing of HT Consumers. MSEDCL proposes to carry out harmonic survey along with quarterly/annual testing. If any consumer is found with harmonic levels beyond limits specified in IEEE 519 :2014, then MSEDCL will serve a Notice indicating test results and intimation to take corrective action for harmonic suppression within 3 months from the date of service of Notice. 3) Subsequent to above Notice, consumers are required to file report of compliance accompanied with test certificates of harmonic filters, invoices and commissioning report. For such consumers who provide compliance to MSEDCL January 20 237 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition the Notice, no penalty will be levied, but it is expected that they will maintain harmonic filters in working condition. 4) The consumers who do not adhere to Notice stipulations, will be charged additional energy charges for consumption beyond 6 months, till rectification of defect. 5) If it is observed that the consumer has not complied with stipulations provided in Notice or has not maintained harmonic filters in working conditions then MSEDCL will apply harmonics penalty for past consumption i.e. from date of serving of Notice and for future consumption till rectification of defect. 9.23.2 MSEDCL requests the Hon’ble Commission to approve levy of harmonics penalty through additional charge equivalent to 5% of Variable Charges (Wheeling Charges plus Energy Charges) for HT Industrial and Commercial consumers who does not maintain the harmonics levels specified in IEEE STD 519-2014. 9.23.3 Further, the HT Industrial and Commercial consumers shall install power quality meters within six months period and share the recorded data with MSEDCL quarterly. 9.24 Expenses for Go Green Initiative (E-Copy of the Bill) 9.24.1 Hon’ble Commission in its Order dated 19th March 2019 in Case No. 1 of 2019 opined that MSEDCL may decide and continue with SMS services and may increase rebate to Rs. 10/- per bill under Go-Green initiative which could be linked to a percentage of bill amount or Rs 10/- per bill whichever is higher. This expenditure pass through would either be treated as an expenditure under O&M and more specifically under A&G or would be considered as a pass through subject to submission of cost benefit analysis justifying the expense incurred, during its upcoming tariff Petition. 9.24.2 MSEDCL submits that Digital India Program (Digital Program) was launched by the Government of India (GoI) with an objective to ensure that the services of the Government are made available to citizens electronically by improved online infrastructure and by increasing Internet connectivity or by making the MSEDCL January 20 238 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition country digitally empowered in the field of technology. 9.24.3 In addition to the above flagship Program, GoI has also been encouraging Government departments / Ministries to shift to paperless functioning mode in a time bound manner. The ‘Paperless Office’ initiative is aimed at improving the ease of governance and expediting the administrative process. 9.24.4 The Government of Maharashtra (GoM) has been encouraging digitization of its services and implementation of ‘Paperless Office’ at State Level. MSEDCL is proactively moving towards paperless and digitally led systems & structures. 9.24.5 In view of the above and in order to encourage the consumers to participate in the Digital Program, MSEDCL has decided to offer a rebate of Rs. 10/- on every electricity bill to the consumers who opt for an electronic copy of the bill instead of the hard copy under its “Go Green” initiative. 9.24.6 Go-Green initiative is launched as a voluntary initiative (not a compulsion) wherein consumers are free to opt for an electronic copy of the bill instead of the hard copy as per their willingness. 9.24.7 MSEDCL was giving a discount of Rs. 3 per electricity bill since 2016, but in order to encourage more participation under the Go-Green initiative has decided to offer a discount of Rs. 10/- on every electricity bill to the consumers, opting for an electronic copy of the bill. This initiative is implemented w.e.f. 1 December, 2018 for LT consumers. MSEDCL January 20 239 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Bill month Apr-18 May-18 Jun-18 Jul-18 Aug-18 Sep-18 Oct-18 Nov-18 Dec-18 Jan-19 Feb-19 Mar-19 Registered Consumers 2,507 2,527 2,701 2,721 2,778 3,090 4,072 4,665 15,432 21,142 23,276 38,636 Total for FY 18-19 Go-Green Discount per month (In Rs.) 7,521 7,581 8,103 8,163 8,334 9,270 12,279 18,118 1,54,299 2,11,420 2,32,760 3,86,360 10,64,208 9.24.8 Currently, 59,040 consumers have opted for Go-Green initiative. Presently about 14 lakh consumers have registered email address with MSEDCL and more than 50 lakhs consumer are paying online. Therefore, MSEDCL expect more and more consumers will opt for electronic copy of the bill. 9.24.9 Benefits of the Go Green Initiative a) Paperless bills, will save cost of bill stationery including paper and ink b) Save time for Bill Distribution and Bill Printing. (Approximately 1 day required for Bill printing and 3-7 days for Bill Distribution depending on Urban and Rural area) c) Saves cost of Bill Printing and bill Distribution i.e approximately Rs 1.50/per bill. d) Reducing the number of complaints from the consumers regarding nonreceipt of the bill; e) E-bill is immediately sent to consumers and can be accessed by consumers from any location. f) Ensuring timely and early realization of payments from consumers thereby reducing the working capital requirement of MSEDCL; g) Bringing down the printing and distribution expenses in the long run, if considerable number of consumers opt for this initiative; MSEDCL January 20 240 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 9.24.10 MSEDCL submits that the Go Green Initiative (E-Copy of the Bill) has many tangible and intangible benefits. This will help MSEDCL as well assist in boosting the Digital India Program launched by Govt. of India. In view of the various benefits, MSEDCL most earnestly requests the Hon’ble Commission to allow the expenditure for Go Green Initiative as revenue expenditure over and above the normative O&M Expenses. 9.25 Expenses for SMS Service 9.25.1 The Hon’ble Commission in its MTR Order in Case No.195 of 2017 noted that serving of notices to the consumers through digital medium such as whatsapp message, email, SMS etc. will not only be environmental friendly and save administrative cost but also would free the human resources for other consumer service related works and hence the Hon’ble Commission allowed MSEDCL to issue notices under Section 56 of the Electricity Act, 2003 through digital mode such as whatsapp message, email, SMS etc. 9.25.2 Since 2016, MSEDCL, focused towards providing all services to its consumer’s online (digital platform). In this endeavor, MSEDCL introduced mobile app for consumers. Till date, more than 30 Lakh consumers have downloaded and using this app. Understanding that, not all consumers would require mobile app, MSEDCL, decided on passive communication via SMS, In order, to reach maximum consumers, all-out efforts taken to collect mobile no. of all consumers. As on today, registered mobile no. has reached up to 2.20+ crores. 9.25.3 Also, new SMS services are introduced for employees through Employee portal, vendors through vendor payment system and for Solar Ag Consumers. Various SMS campaigns are also executed for informing consumers about MSEDCL schemes and major breakdowns during emergencies and natural calamities etc. Recently added Meter Reading Intimation SMS makes consumer aware that meter reader is going to visit his/her premises for capturing reading Meter Reading in particular slots. 9.25.4 MSEDCL has already created a facility for consumers to get information by way of SMS generated by MSEDCL’s system delivered to the mobile number MSEDCL January 20 241 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition registered with MSEDCL. The scope of SMS services includes following: a) Intimation of billing information: Consumer can request for his bill details on his registered mobile number by sending SMS to the designated short code/long code (Push and Pull Services); b) Billing Alerts: For registered consumers the system will send alerts informing his total due amount, due date, when services will be disconnected if not paid, Notices for unpaid bills, payment acknowledgement etc.; c) Acknowledgement of consumer registrations/complaints; d) Intimation of consumer complaints to MSEDCL officers; e) OTP for VPN users; f) SMS to consumer for new connection system; g) Other SMS for systems like bill revision, ERP, feeder outages etc.; h) Any other useful and commercially viable services 9.25.5 Following table provides the cost of SMS service per month. Approx. No.of Cost of SMS SMS Service SMS Per Per month (Rs.) Month (In Lakh) Meter Reading Information 150 10,35,450 Bill Alert & Bill Reminder Before and 290 20,01,870 After Due Date Outage Notification 180 12,42,540 Payment Ack for all payments 90 6,21,270 Complaint Acknowledgement 5 34,515 Self-Reading Request 15 1,03,545 New Connection Approval 2.50 17,257 Employee Portal 0.53 3,683 OTP for Employees/ vendors etc. 10 69,030 Other ad-hoc SMS (incidental / 150 10,35,450 occasional) Advance Meter Reading Intimation 42.93 2,96,372 Total 945.96 64,60,982 9.25.6 SMS service has various benefits which are summarized below: a) Transparency in Service Delivery, MSEDCL January 20 242 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition b) Advance intimation of meter reading schedule improves normal billing percentage and in turn billing efficiency. c) Bill Alerts, Bill Reminder SMS helps to improve collection it turn timely realization of revenue. d) Improving the working capital requirement e) Outage intimation to consumers helps to reduce consumer grievances. f) SMS to employees helps to improve better productivity and efficiency. g) OTP ensures secured access to authorized employees / end users. 9.25.7 MSEDCL submits that the SMS service will help not only consumer but MSEDCL also in information disseminating in a matter of seconds to large section of consumers at one go. Delhi Electricity Regulatory Commission (DERC) in its Order in the matter of Petition for approval of Annual Revenue Requirement (ARR) of Tata Power Delhi Distribution Ltd. for the FY 2018-19, Revised ARR for FY 2017-18, True up for FY 2016-17 has approved expenses of SMS services separately in ARR under other expenses. By drawing same analogy and inn view of the various benefits, MSEDCL most earnestly requests the Hon’ble Commission to allow the expenditure for SMS Services as revenue expenditure over and above the normative O&M Expenses. 9.26 Revision in Reconnection Charges for Restoration of Power Supply 9.26.1 The percentage of consumers who pay within the due date is only 51% in case of LT consumers. LT category has a large base of consumers. The percentage of consumers paying late or not paying are about 40% of the overall LT category of consumers which is a very high proportion. Thus, a high proportion of consumers in LT category do not pay on time resulting in blocking of revenue. Further cost and expense have to be incurred to take necessary steps to realise the unpaid dues of the electricity bill from the defaulting consumers. Further, it reveals from the above mentioned table that at least ~10% of the consumers are such that they are paying electricity bill during notice period. Thus MSEDCL has to incur the administrative charges and expenses for serving notice on such consumers. 9.26.2 MSEDCL submits that due to lower collection efficiency, administrative costs, its financial position is getting worse day by day and interest on working capital MSEDCL January 20 243 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition is increasing. Therefore, recovery on arrears is a prime concern for MSEDCL and hence, higher disconnection/reconnection charges are required to ensure timely payments by the consumers. It is further submitted that higher reconnection charges may encourage the consumer to pay the electricity bills in time and discourage the consumer from becoming a defaulter. 9.26.3 The disconnection and reconnection is two stage process. Initially, the defaulting consumer’s supply is physically disconnected from consumers’ premises. After the consumer makes payment of electricity bills and reconnection charges, the reconnection process has to be completed at the consumer premises only, with all physical activities including transportation of equipment. When the consumer pays the bill MSEDCL has to reconnect the meter, metering equipment, service line etc. Unlike telephone or mobile where disconnection/reconnection is done remotely, physical disconnection/reconnection at consumer premises is essential in the disconnection of electricity. While for the physical disconnection/ reconnection of electric supply, the charges are comparatively very low in the range of Rs. 50-100 for LT category of consumers. 9.26.4 MSEDCL submits that the reconnection charges approved by Hon’ble Commission are meagre and does not cover the actual cost incurred by MSEDCL for reconnection. 9.26.5 MSEDCL submits that as provided in the Section 56 (2) of the Electricity Act 2003, when any person neglects to pay any charge for electricity or any sum other than a charge for electricity due from him in respect of supply of electricity to him, MSEDCL after giving fifteen days’ notice in writing can disconnect the electric supply. 9.26.6 Notice is to be served through lawyer, whose legal fee varies. MSEDCL has approved the legal charges of Rs. 200/- towards preparation of disconnection notice and Postage & Printing charges of Rs 35/- for serving a single notice. Apart from that MSEDCL billing staff has to spend its time. There are cases when the consumer makes the payment during the notice period after the notice has been issued to him. In such cases, also the cost of issuance of notice is MSEDCL January 20 244 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition incurred by MSEDCL. 9.26.7 MSEDCL submits that reconnection activity involves administrative cost including man-power, transportation and time. In case of HT category consumer, for disconnecting supply, it is required to take outage & disconnect the supply from sub-station. During this period of disconnection, there is revenue loss for MSEDCL. Further, two persons (line staff + Helper) are required to reconnect the electricity supply. 9.26.8 Considering the fact that the disconnections/reconnections are required to be done during operating hours only, MSEDCL has restrictions in terms of manpower utilisation for multiple tasks. Due to such restrictions, MSEDCL needs to deploy staffs for reconnections which add to the employee cost. Moreover it is pertinent to mention that the issuance of notice and carrying out disconnection/reconnection incurs cost under several heads. In usual practice, two DISCOM employees are required to carry out ‘disconnection/reconnection’ activity. It is submitted that MSEDCL incur cost for carrying out the reconnection activity. Thus charges incurred on account of logistics & overheads of those employees should be subsumed within the reconnection charges. Hence the ‘Notice’ as well as ‘disconnection/reconnection’ needs to be fully compensated by individual consumer who is in default. 9.26.9 It is submitted that in accordance with EA 2003, the Commission had notified MERC (Electricity Supply Code and Other Condition of Supply) Regulations, 2005. As per the provisions of the Supply Code Regulations, MSEDCL recovers various charges approved by the Hon’ble Commission vide its Order dated 12 September 2018 (Case No. 195 of 2017), for various services provided to consumers. 9.26.10 While deciding the schedule of charges in MTR Order dated 12th September 2018 (Case No. 195 of 2017), the Hon’ble Commission has considered the six year average of Consumer Price Index published by the Labour Bureau, Government of India to escalate previously approved charges in Order dated 16 August, 2012 on compounded basis. MSEDCL January 20 245 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 9.26.11 However, the Hon’ble Commission has ignored the revision rate of minimum wages. This has necessitated the need for revision of schedule of charges. MSEDCL has proposed increase in reconnection charges after considering the increase in labour cost and inflationary indices. This is for encouraging prompt payment and to discourage consumer from defaulting on the energy bills. 9.26.12 In order to encourage timely payments by defaulting consumers avoiding disconnection reconnection activities, it is necessary to have higher reconnections charges. Thus it is necessitated the need for revision of reconnection charges. 9.26.13 Hon’ble Commission in its Order dated 20th April 2015 has approved Visit Charges for subsequent visit for Inspection and test of Installation for Mumbai Licensees. MSEDCL submits that on similar lines, the staff of MSEDCL also requires to visit the consumer premises twice; first for disconnection and again for reconnection. Thus, considering the number of visits, manpower and time involved, transportation up to consumer premises the reconnection charges need to be increased to cover the costs incurred by MSEDCL. 9.26.14 The estimate of the cost incurred by MSEDCL towards disconnection/reconnection charges and for serving notice to the consumer along with proposed revision in reconnection charges is submitted in the Chapter on Schedule of Charges. 9.27 Additional Suggestions for Tariff Applicability 9.27.1 MSEDCL submits that Hon’ble Commission in its past tariff Orders has explicitly spelt tariff applicability to various usages. With growth in economy, new usages pattern have emerged, which require clarification and confirmation of Hon’ble Commission. Though the applicability specified by the Hon’ble Commission is representative, MSEDCL prays for confirmation on following usage categorisation. 9.27.2 Following new usages have been identified and added in tariff applicability proposal. MSEDCL January 20 246 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 9.27.3 Day Care Centre for senior Citizens in Residential category: In urban areas day care centre for the older generation are coming up, where elderly people are being looked after by a volunteer. MSEDCL is already charging residential rates to orphanages and homes for destitute. Similarly MSEDCL proposes to include Day Care Centres for senior citizens under Residential Category. 9.27.4 Water ATM (RO/UV/UF) Water Purifier Plants The novel concept of ‘water ATMs’, has been initiated in remote areas of vidharbha where there is severe water scarcity or flow of contaminated water. Majority of Water ATMs are being installed with the funds received from multination Companies and state run Mahagenco under corporate social responsibility fund. In some cases these machines are being handed over to Gram panchayat or directly to women’s self-help groups for operation. Considering this MSEDCL proposes to charge such units under Public services (Others) category, if Gram panchayat or local body operates the same. Otherwise Non-residential tariff may be made applicable. 9.27.5 Godowns and Warehouses in Non-Residential Colony: MSEDCL submits that warehousing means art of storage goods, making maximum use of available space for storage of goods (Raw and Finished). Godowns and warehouses are third party logistic providers and meant for temporary storage of goods. There exists the cluster of warehouses outside Bhiwandi and Pune in Maharashtra. The facilities of godowns and warehouses are leased by owner to any company, who intend to store the goods near to its demand centre. Presently Hon’ble Commission has not explicitly mentioned usages for Godowns and warehouses in any category. Hence, MSEDCL proposes to classify the Godowns and warehouses in Non-Residential category. 9.27.6 Common facility Centre (CFC) establish under cluster development program of Central/State Government Govt. of India has announced schemes for upgradation of potential industrial MSEDCL January 20 247 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition clusters. Govt. of India gives financial support by grant-in-aid to establish Common Facilities Centre (CFC) & infrastructure development to enhance the productivity and competitiveness of the clusters. CFC includes R & D facilities, Packaging Centre, Testing Centre, Training Centre, Common Processing Centre etc. The scheme is implemented by the Special Purpose Vehicle (SPV) under PPP mode. Government of Maharashtra in its Industrial Policy 2019 stipulated that Common Facility Centre (CFC) established under the cluster development programme of Central/ State Government will be treated as industrial activity. Considering promotional measures as stipulated in Industrial Policy 2019, MSEDCL intends to categorise the said usages under industrial category. 9.27.7 Packaged drinking water plants Packaged drinking water uses water from any source which has to be treated and disinfected, a process that mainly involve filtration, UV or ozone treatment or reverse osmosis (RO) before it is fit for human consumption. There are mainly 4 sections in a packaged drinking water plant: water treatment, bottling, quality control (lab) and overall utility. Considering nature of usage, MSEDCL proposes to charge Industrial Tariff to Packaged drinking water plants. 9.27.8 Lighting for religious exhibitions and gatherings Many times it is observed that religious functions involve multiple activities like satsang, spiritual book exhibition, talk sessions etc. At field level it is very difficult to differentiate the usages thus MSEDCL proposes to include lighting for religious exhibitions & gatherings like satsangs/spiritual gatherings etc. under Temporary Supply Religious (TSR) category. 9.28 Modification in Tariff Applicability 9.28.1 Explicit clarification regarding supply to large construction projects Hon’ble Commission’s earlier Tariff Orders stipulate 1 year for temporary supply. But MERC (Supply Code) Regulation, 2005 mentions limit of 2 years. MSEDCL proposes the limit of 2 years for Temporary supply. Further, it is worthwhile to mention that that large construction project take may take longer time than 2 years for completion. Hence it is proposed that for Construction, MSEDCL January 20 248 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition initially supply will be provided under Temporary Supply Others (TSO), after 2 years the supply will be regularized under Non- Residential category. 9.28.2 Sewage Treatment Plants and common effluent treatment plants Sewage Treatment Plants and effluent treatment plant require attention for curbing water pollution. In this Petition MSEDCL intends to categorise Sewage Treatment Plants and effluent treatment plant set up by Local Self-Government Bodies (Gram Panchayats, Panchayat Samitis, Zilla Parishads, Municipal Councils and Corporations, etc.), Maharashtra Industries Development Corporation (MIDC), Industries Association or consortium of industries., Housing societies/complexes under Public Water Works and Sewage Treatment Plants category. Only Sewage Treatment Plants and common effluent treatment plants of commercial establishments and of individual industry within its premises will be charged at respective tariff category. 9.28.3 Information Technology (IT) or IT-enabled Services (ITeS) Unit The Commission in its earlier Tariff Orders has given preferential treatment to IT & ITES units conceptualized under IT & ITES Policy of Government of Maharashtra. Government of Maharashtra in its IT & ITES Policy 2015 (Page No.12) stipulated following “ iii) Electricity Tariff: IT/ITES units registered with the Directorate of Industries will be supplied power at industrial rates applicable under Maharashtra Electricity Regulatory Commission's (MERC's) tariff orders.” In past, it has been observed that there has been issue with regards to permanent registration certificate. It is submitted that Directorate of Industries issues registration certificate with validity. Validity of units needs to be the basis of application of industrial tariff. MSEDCL has developed a portal for uploading registration certificates and IT & ITES Units are require to submit fresh certificates, before it gets expire. If any unit fails to resubmit the same then the unit is re-categorised under Non-Residential category. 9.28.4 Public Sanitary Conveniences/Toilets MSEDCL January 20 249 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition In earlier Tariff Order Public Sanitary Conveniences have been categorised under street light category. In present tariff filing MSEDCL proposes that the same usages may be considered under Public services (Other) category. 9.29 Any Other submission 9.29.1 Decisions of various Regulatory Forums The Aggregate Revenue Requirement has been arrived at on the basis of firmed up data from various Utilities like MSPGCL, MSETCL, NTPC etc. Also, this data in some cases is likely to be revised on account of various reasons including decisions by the appropriate regulatory forums and judicial authorities. This is likely to have an additional impact on revenue gap, which cannot be estimated at this stage. Hon’ble Commission is humbly requested that as and when such impact is arrived at, the same may please be considered by the Hon’ble Commission and may permit recovery of the same with appropriate mechanism with immediate effect. MSEDCL January 20 250 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 10 SHARING OF CROSS SUBSIDY IMPACT DUE TO AG CONSUMERS IN MAHARASHTRA 10.1.1 The state of Maharashtra is one of the agrarian State in Indian. Out of MSEDCL’s total consumer base of around 2.65 crore consumers, MSEDCL caters to more than 42 Lakhs agricultural category consumers. The share of the electricity consumption by the agricultural category consumers is ~30 % of the total electricity consumption of MSEDCL consumers. Historically, the electricity tariff of the agriculture category consumers is being determined to be much less than the Average Cost of Supply effectively increasing the tariff of other category consumers by way of cross subsidy. At the same time, revenue realised from the agriculture consumers is also less owing to various reasons such as poor capacity to pay, uncertain agricultural produce due to unpredictable rainfall etc. This Ag cross subsidy is getting passed on to other subsidizing consumers of MSEDCL and increasing their tariff further. 10.1.2 The higher tariffs of the cross subsidising consumers of MSEDCL (Industrial, Commercial, high end residential etc.) is impacting sales and revenue of MSEDCL thereby requiring tariff hike and thus entering into a vicious circle. Hence there is a necessity to maintain a balance in tariff of the subsidised AG consumers and the high end subsidising consumers of MSEDCL. 10.1.3 It is pertinent to note that the consumer base of Mumbai licensees (Tata, Adani, BEST) as well as other SEZs comprises mostly of high end consumers (Industrial, Commercial, high end Residential etc.). These consumers have higher capacity to pay in comparison to the Agricultural category consumers. For Mumbai Licensees and SEZs, as there are no AG consumers, there is no impact on the tariff of these consumers because of cross subsidy for agricultural consumers. Thus, the consumers of Mumbai Licensees and SEZs are protected from payment of the cross subsidy for AG consumers and since all AG consumers are in MSEDCL License Area has created imbalance in revenue recovery. 10.1.4 It is a fact that the benefits of the agricultural produce from the agricultural consumers of MSEDCL are being enjoyed by all the consumers of Maharashtra including Mumbai Licensees and SEZs, it is advisable that the impact of such MSEDCL January 20 251 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition cross subsidy should also be shared equally by all the consumers of the state of Maharashtra including those in the area of Mumbai Licensees and SEZs. This will also reduce differentiation among similar category consumers across the state. Hon’ble Commission is therefore requested to take the note of the same and address the issue in the larger benefit of the similarly placed electricity consumers in the State. 10.1.5 MSEDCL further submits that proposed amendment in the EA 2003 provides for separation of carriage and contents. As a result, multiple supply Licensees will be introduced in State and being incumbent Supply Licensee, the impact of cross subsidy of all AG consumers in MSEDCL area will be on MSEDCL. In view of this, the cross subsidy impact needs to be distributed amongst all the supply Licensee in Maharashtra which is in line with the proposed Amendment. 10.1.1 MSEDCL submits that the details of approved ACoS for FY 19-20 of Distribution Licensee in Maharashtra are summarized as below: Particulars Units ARR Rs. Crs Sales MUs ACOS Rs./Unit MSEDCL TPC-D AEML-D BEST 74,179 3,462 7,717 3,440 1,08,369 4,607 8,887 4,870 6.85 7.51 8.68 7.06 10.1.2 From the above table, it is evident that the ACOS of MSEDCL is lowest among all the Licensees in State. 10.1.3 MSEDCL submits that based on the approved sales and revenue for the Licensees for FY 19-20, MSEDCL has computed the impact which is summarized below: MSEDCL January 20 252 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Category ABR MUs Rs./Unit Rs./Unit Rs./Unit HT-V-Ag ACOS Cross Cross Subsidy Subsidy Sales Rs. Crs 804 4.27 6.85 2.58 207 LT IV(A): LT - AG Unmetered 9,899 3.86 6.85 2.99 2,960 LT IV(B): LT -AG Metered 21,091 3.74 6.85 3.11 6,559 MSEDCL AG Total 31,793 9,726 MSEDCL Sale (MUs) 1,08,369 TPC-D Sale (MUs) 4,607 AEML-D Sale (MUs) 8,887 BEST Sale (MUs) 4,870 Total Sale in MH (MUs) 1,26,733 Total Ag Sale in MH (MUs) 31,793 Total Subsidising Sale in MH (MUs) 69,299 Total Subsidising Sale in MSEDCL (MUs) 56,270 Ag Cross Subsidy (Rs. Cr.) 9,726 Per Unit Ag Cross Subsidy (Rs./Unit) Existing Avg. impact on Total Subsidising Sale in MSEDCL 1.73 If spread on Total Subsidising Sale in MH 1.40 Rs.0.33 p.u. Reduction in Cross Subsidy for MSEDCL Impact on Mumbai Licensee MSEDCL Rs. (1829) Crs Rs. 1829 Crs January 20 253 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 10.1.4 MSEDCL submits that the National Tariff Policy, the Electricity Act and other enabling provisions has emphasized on protecting the interests of all stakeholders of electricity sector in the State including consumers. The Hon’ble Commission has inherent powers to decide the matters in the interest of consumers as well as Utilities. The relevant extracts are reproduced below: MERC (MYT) Regulations 2019 106 Power to remove difficulties If any difficulty arises in giving effect to the provisions of these Regulations, the Commission may, by general or specific order, make such provisions not inconsistent with the provisions of the Act, as may appear to be necessary for removing the difficulty. National Tariff Policy 5.10 Consumer interest is best served in ensuring viability and sustainability of the entire value chain viz., generation, transmission and distribution of electricity, while at the same time facilitating power supply at reasonable rate to consumers. The Electricity Act 2003 Section 61. (Tariff regulations) (d) safeguarding of consumers' interest and at the same time, recovery of the cost of electricity in a reasonable manner; Section 86. (Functions of State Commission) (4) In discharge of its functions, the State Commission shall be guided by the National Electricity Policy, National Electricity Plan and tariff policy published under section 3 MSEDCL January 20 254 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 11 WHEELING CHARGES 11.1 Network Cost of MSEDCL 11.1.1 Hon’ble Commission in MYT Regulations 2019 has provided the ratio of network and supply cost segregation. MSEDCL has considered the same for segregation of aggregate revenue requirement for the Control Period and arrived at the Wires Business and Retail Supply Business Cost. Following table provides the summary of Network Cost of MSEDCL for the Control Period. Table 190: Network Cost of MSEDCL for FY 2020-21 to FY 2024-25 S. No. 1 2 3 4 5 6 7 8 9 10 11 12 Particulars Operation & Maintenance Expenses Depreciation Interest on Loan Capital Interest on Working Capital Interest on deposit from Consumers and Distribution System Users Other Finance Charges Provision for bad and doubtful debts Opex Schemes Contribution to contingency reserves Income Tax Return on Equity Capital Total Revenue Expenditure Rs. Crs FY 2020-21 FY 2021-22 FY 2022-23 FY 2023-24 FY 2024-25 4,536 4,710 4,891 5,078 5,273 2,481 2,670 2,840 2,899 2,953 1,266 1,317 1,222 1,001 771 130 140 145 145 145 54 57 60 63 66 89 87 143 1,550 10,338 94 87 159 1,613 10,847 99 87 171 1,668 11,182 105 87 175 1,711 11,265 111 87 180 1,752 11,338 11.1.2 MSEDCL submits that the Regulation 73.2 of MERC (Multi Year Tariff) Regulations 2019 provides for computation of wheeling charges separately for LT voltage, HT voltage and EHT voltage levels. The relevant extract of such regulations are given below: “73.2 The Wheeling Charges of the Distribution Licensee shall be determined by the Commission on the basis of a Petition for determination of Tariff filed by the Distribution Licensee in accordance with Part B of these Regulations: Provided that the Wheeling Charges may be denominated in terms of Rupees/kWh or Rupees/kVAh or Rupees/kW/month or Rupees/kVA/month, for the purpose of recovery from the Distribution System User, or any such denomination, as may be stipulated by the Commission: Provided further that the Wheeling Charges shall be determined separately for LT voltage, HT voltage, and EHT voltage, as applicable:” MSEDCL January 20 255 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 11.1.3 Accordingly, MSEDCL submits that for the Control Period from FY 2020-21 to FY 2024-25, it is proposed Wheeling Charges for three levels only, EHV (66 kV and above), HT (combined wheeling charges for 33, 22 & 11 kV) and LT Level. 11.1.4 MSEDCL further submits that it does not maintain audited accounts for voltage wise assets and thus it does not have segregation between GFA for HT and LT Levels. Hence, MSEDCL for the purpose of projection has considered GFA segregated into HT and LT as considered by the Hon’ble Commission in the Mid Term Review Order dated 12th September 2018. MSEDCL further submits that in order to arrive at the proportion of GFA for HT Level, it has added the GFA proportion for 33 kV, 22 kV and 11 kV voltage levels and the same is shown in the table below. Table 191: Segregation of GFA for the Control Period Particulars FY 2020-21 FY 2021-22 FY 2022-23 FY 2023-24 FY 2024-25 HT (Excl EHV) 70% 70% 70% 70% 70% LT Level 30% 30% 30% 30% 30% 11.1.5 MSEDCL has then applied ratio of Voltage-wise GFA shown in table above to arrive at GFA of HT (Excluding EHV Level) and LT levels asset which has been approved by the Hon’ble Commission in its order dated 12th September 2018. 11.1.6 The Network Cost is apportioned among voltage level in the ratio of GFA as computed above: Table 192: Network cost apportioned for the Control Period Particulars HT (Excl EHV) LT Level Rs. Crs FY 2020-21 FY 2021-22 FY 2022-23 FY 2023-24 FY 2024-25 7,237 7,593 7,827 7,886 7,936 3,101 3,254 3,354 3,380 3,401 11.1.7 MSEDCL has considered the voltage wise consumption (in kVAh also) as projected in Form 1.2 for the respective years of the control period for determining the wheeling charges. The projected consumption at different voltage levels is shown below: MSEDCL January 20 256 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 193: Voltage Wise Consumption for the Control Period Particulars HT (Excl EHV) LT Level MUs FY 2020-21 FY 2021-22 FY 2022-23 FY 2023-24 FY 2024-25 30,895 32,100 33,356 34,666 36,034 73,257 75,874 78,641 81,569 84,671 11.1.8 To arrive at the cost of wheeling at the various voltage levels, the total wire network cost (as computed above) has been apportioned to various voltage levels (i.e., HT (Excluding EHV) and LT) in the ratio of sales at respective voltage levels. The wire costs at higher voltage levels have been further apportioned to lower voltage levels, since the HT system is also being used for supply to the LT consumers. Table 194: Calculation of Wheeling Cost for FY 20-21 Network Cost (Rs. Crs) HT (Excl EHV) 7,237 LT Level 3,101 Total 10,338 Particulars Sales (MUs) 30,895 73,257 1,04,152 % of Wheeling Cost Sales (Rs. Crs) 30% 2,147 70% 8,191 100% 10,338 11.1.9 Using the same methodology as referred above, MSEDCL has computed the Wheeling Cost for the entire Control Period. 11.1.10 Subsequently, MSEDCL has calculated the share of each voltage category in the non-coincident peak demand using % sales for each category. The wheeling charge has then been derived by dividing the wheeling cost of each voltage category (as computed above) by the non-coincident peak demand for that category and dividing it by 12 months. 11.1.11 Finally, the wheeling charges for each category have been calculated by dividing the wheeling charge for each category by the load factor (assumed to be 66%) and 720 hrs (24x30). MSEDCL January 20 257 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 195: Proposed Wheeling Charges for FY 2020-21 Particulars HT (Excl EHV) LT Level Total Wheeling Cost (Rs. Crs) 2,147 8,191 10,338 Share in Non Wheeling Coincident Charge Demand (MW) (Rs./kW/Month) 4,913 364 12,540 544 17,453 494 Wheeling Charges 0.77 1.15 1.04 11.1.12 Using the same methodology, as referred above, MSEDCL has computed the Wheeling Cost for the entire Control Period. The proposed Wheeling Charges for the Control Period are given below: Table 196: Proposed Wheeling Charges for the Control Period Particulars Units HT (Excl EHV) Rs./kVAh LT Level Rs./kWh FY 20-21 0.77 1.15 Rs/Unit FY 21-22 FY 22-23 FY 23-24 FY 24-25 0.78 0.78 0.77 0.75 1.17 1.17 1.14 1.11 11.1.13 MSEDCL For the purpose of commercial settlement, MSEDCL proposes to continue following Wheeling Losses which are already approved in previous Tariff Orders. Table 197: Proposed Wheeling Losses for the Control Period Particulars 33 kV 22 kV 11 kV LT Wheeling Losses 6.00% 7.50% 9.00% 12.00% 11.1.14 MSEDCL requests the Hon’ble Commission to approve the wheeling charges as proposed above. MSEDCL January 20 258 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 12 TARIFF RECOVERY MECHANISM 12.1 Background 12.1.1 As discussed in previous Chapter, MSEDCL has considered the following while determining proposed tariff for the Control Period: Rationalisation of the fixed charge to ensure recovery of fixed cost from all consumers; Revision in definition of Billing Demand Introduction of kVAh based billing for all HT Consumers Rationalization of Incentives Revision in ToD charges etc. 12.1.2 National Tariff Policy envisages that the consumer tariff should progressively reflect the cost of supply of electricity. 12.1.3 MSEDCL submits that Regulation 6.5 of the MERC (MYT) Regulations 2019 provides for forecast of expected revenue from tariff and charges. The relevant provisions are reproduced below for reference: 6.5 The forecast of expected revenue from Tariff and charges shall be based on the following: (a)……… (b)…….. (c) In the case of a Distribution Licensee, estimates of quantum of electricity to be supplied to consumers and wheeled on behalf of Distribution System Users for each year of the Control Period: Provided that the Distribution Licensee shall submit relevant details of categorywise sales separately for each Distribution Franchisee area, including the Input Energy and the Input Rate; (d) Prevailing Tariff as on the date of filing of the Petition. 12.1.4 Accordingly, MSEDCL has projected the revenue at existing tariff considering the prevailing tariff as on the date of filing the MYT Petition which is based on the MTR Order dated 12th September 2018. MSEDCL January 20 259 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 12.1.5 Therefore, MSEDCL has shown the prevailing tariff (including wheeling charges) as on the date of filing the MYT Petition and compared the proposed tariff with the same. 12.2 Rationale of Tariff Hike 12.2.1 It is submitted that Hon’ble Commission in its MTR Order approved total revenue gap of Rs. 20,651 Crs. However, recovery of only Rs. 8,268 Crs was allowed over a period of two years. Hon’ble Commission created Regulatory Assets of Rs. 12,382 Crs. Hon’ble Commission directed MSEDCL, that at the time of next ARR/Tariff filling process for final true-up of ARR of 3rd Control Period , MSEDCL should submit its proposal for planned recovery of Regulatory Asset along with carrying cost for the ensuing years in the next Control Period, so that recovery of such Regulatory Asset and adjustment of on account of final true up of Revenue Gap/(Surplus) (if any) shall not exceed for the period of two years beyond the current Control Period (i.e. 3rd Control Period). This has major bearing on the recovery of revenue gap during the 4th Control Period. 12.2.2 Therefore, it is necessary for the licensee to seek an appropriate hike in the tariff, up to the level as proposed and detailed in this petition so as to meet the bare minimum requirement of the Utility to remain financially viable and to meet the financial obligation to discharge the liabilities. 12.2.3 Accordingly, MSEDCL in the said petition filed under Section 45, 46, 61, 62, 64 and 86 of the Electricity Act, 2003, for determination of Tariff for fourth control period i.e. FY 2020-21 to FY 2024-25 has proposed tariff considering the increase in various costs. 12.2.4 MSEDCL has proposed a revision in fixed and energy charges for various categories in order to bridge revenue gap. The tariff revision is necessary for meeting additional costs due to increase in generation & transmission costs, regulatory assets and legitimate expenses of MSEDCL. The revenue gap has emerged due to additional costs, which are beyond the control of MSEDCL. MSEDCL January 20 260 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 12.2.5 A comparison of detailed Category/ Sub-category wise Existing and Proposed Fixed/ Demand Charges and Energy Charges (Excluding Wheeling Charges) is shown in tables below: MSEDCL January 20 261 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 198: Comparison of Existing and Proposed Energy Charges (excl. Wheeling Charges) for HT Category (1/2) Particulars HT I HT - Industry HT EHV HT I (B): HT - Industry (Seasonal) HT EHV HT II: HT – Commercial HT EHV HT III : HT - Railways/Metro/Monorail Traction HT EHV HT IV: HT - Public Water Works HT EHV HT V(A): HT - Agriculture Pumpsets HT EHV HT V(B): HT - Agriculture - Others HT EHV HT VI: HT - Group Housing Societies (Residential) HT EHV HT VIII(A): HT - Temporary Supply Religious (TSR) HT EHV HT VIII(B): HT - Temporary Supply Others (TSO) HT EHV HT IX: HT - Public Services HT IX(A): HT - Public Services-Govt. HT EHV HT IX(B): HT - Public Services-Others HT EHV HT X: HT – Electric Vehicle Charging Station HT EHV MSEDCL FY 2020-21 Energy Charges (Rs/Unit) % Change over Existing Proposed FY 2019-20 Approved FY 2021-22 Energy Charges (Rs/Unit) % Change over Proposed FY 2020-21 Proposed 7.07 7.07 7.11 7.11 1% 1% 7.20 7.20 1% 1% 7.34 7.34 7.40 7.40 1% 1% 7.50 7.50 1% 1% 11.73 11.73 11.70 11.70 0% 0% 11.70 11.70 0% 0% 7.00 7.00 7.20 7.20 3% 3% 7.40 7.40 3% 3% 6.30 6.30 6.50 6.50 3% 3% 6.70 6.70 3% 3% 3.77 3.77 3.90 3.90 3% 3% 4.00 4.00 3% 3% 5.20 5.20 5.40 5.40 4% 4% 5.60 5.60 4% 4% 5.82 5.82 6.00 6.00 3% 3% 6.20 6.20 3% 3% 3.75 3.75 3.90 3.90 4% 4% 4.00 4.00 3% 3% 12.00 12.00 12.40 12.40 3% 3% 12.80 12.80 3% 3% 7.90 7.90 8.00 8.00 1% 1% 8.10 8.10 1% 1% 9.70 9.70 9.90 9.90 2% 2% 10.00 10.00 1% 1% 5.24 5.24 5.40 5.40 3% 3% 5.60 5.60 4% 4% January 20 262 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 199: Comparison of Existing and Proposed Energy Charges (excl. Wheeling Charges) for HT Category (2/2) Particulars HT I HT - Industry HT EHV HT I (B): HT - Industry (Seasonal) HT EHV HT II: HT – Commercial HT EHV HT III : HT - Railways/Metro/Monorail Traction HT EHV HT IV: HT - Public Water Works HT EHV HT V(A): HT - Agriculture Pumpsets HT EHV HT V(B): HT - Agriculture - Others HT EHV HT VI: HT - Group Housing Societies (Residential) HT EHV HT VIII(A): HT - Temporary Supply Religious (TSR) HT EHV HT VIII(B): HT - Temporary Supply Others (TSO) HT EHV HT IX: HT - Public Services HT IX(A): HT - Public Services-Govt. HT EHV HT IX(B): HT - Public Services-Others HT EHV HT X: HT – Electric Vehicle Charging Station HT EHV MSEDCL FY 2022-23 Energy Charges (Rs/Unit) % Change over Proposed FY 2021-22 Proposed FY 2023-24 Energy Charges (Rs/Unit) % Change over Proposed FY 2022-23 Proposed FY 2024-25 Energy Charges (Rs/Unit) % Change over Proposed FY 2023-24 Proposed 7.30 7.30 1% 1% 7.40 7.40 1% 1% 7.47 7.47 1% 1% 7.60 7.60 1% 1% 7.70 7.70 1% 1% 7.80 7.80 1% 1% 11.70 11.70 0% 0% 11.70 11.70 0% 0% 11.70 11.70 0% 0% 7.60 7.60 3% 3% 7.80 7.80 3% 3% 8.00 8.00 3% 3% 6.90 6.90 3% 3% 7.10 7.10 3% 3% 7.30 7.30 3% 3% 4.10 4.10 2% 2% 4.20 4.20 2% 2% 4.30 4.30 2% 2% 5.80 5.80 4% 4% 6.00 6.00 3% 3% 6.20 6.20 3% 3% 6.40 6.40 3% 3% 6.60 6.60 3% 3% 6.80 6.80 3% 3% 4.10 4.10 2% 2% 4.20 4.20 2% 2% 4.30 4.30 2% 2% 13.20 13.20 3% 3% 13.60 13.60 3% 3% 14.00 14.00 3% 3% 8.20 8.20 1% 1% 8.30 8.30 1% 1% 8.40 8.40 1% 1% 10.10 10.10 1% 1% 10.20 10.20 1% 1% 10.30 10.30 1% 1% 5.80 5.80 4% 4% 6.00 6.00 3% 3% 6.20 6.20 3% 3% January 20 263 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 200: Comparison of Existing and Proposed Energy Charges (excl. Wheeling Charges) for LT Category (1/4) Particulars LT Residential LT I(A): LT - Residential-BPL LT I(B): LT - Residential 1-100 units 101-300 units 301-500 units >500 units LT II: LT - Non-Residential (A1) (i): 0 – 20 kVA (Upto 200 units per month) (A1) (ii): 0 – 20 kVA (Above 200 units per month) (A1) (iii) 0-20 kVA (Single phase) (B): >20 kVA and ≤ 50 kVA (C): >50 KVA LT III: LT - Public Water Works (PWW) (A): 0-20 KVA (B): >20 kVA and ≤ 40 kVA (C): >40 KVA LT IV: LT - Agriculture LT IV(A): LT - AG Un-metered - Pumpsets Category 1 Zones (Above 1318 Hrs/HP/Annum) (a) 0-5 HP (b) Above 5 HP - 7.5 HP (c) Above 7.5 HP Category 2 Zones (Below 1318 Hrs/HP/Annum) (a) 0-5 HP (b) Above 5 HP - 7.5 HP (c) Above 7.5 HP LT IV(B): LT - Agriculture Metered Tariff - Pumpsets LT IV(C): LT - Agriculture Metered – Others MSEDCL FY 2020-21 Energy Charges (Rs/unit) % Change over Existing Proposed FY 2019-20 Approved 1.10 1.36 3.05 6.95 9.90 11.50 3.30 7.30 9.90 11.50 24% 8% 5% 0% 0% FY 2021-22 Energy Charges (Rs/unit) % Change over Proposed FY 2020-21 Proposed 1.40 3% 3.50 7.50 9.90 11.50 6% 3% 0% 0% 6.10 9.25 6.10-9.25 9.30 11.60 7.90 8.10 3% 7.90 9.50 11.60 2% 0% 8.10 9.80 11.80 3% 3% 2% 2.15 3.50 4.80 2.30 3.60 4.90 7% 3% 2% 2.40 3.70 5.00 4% 3% 2% Rs./HP/Month Rs./HP/Month 374 403 452 400 430 480 7% 7% 6% 420 455 505 5% 6% 5% 288 316 366 2.09 3.51 310 335 390 2.20 3.70 8% 6% 7% 5% 5% 330 355 410 2.30 3.80 6% 6% 5% 5% 3% January 20 264 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 201: Comparison of Existing and Proposed Energy Charges (excl. Wheeling Charges) for LT Category (2/4) FY 2022-23 Energy Charges (Rs/unit) % Change over Proposed FY 2021-22 Proposed Particulars LT Residential LT I(A): LT - Residential-BPL LT I(B): LT - Residential 1-100 units 101-300 units 301-500 units >500 units LT II: LT - Non-Residential (A1) (i): 0 – 20 kVA (Upto 200 units per month) (A1) (ii): 0 – 20 kVA (Above 200 units per month) (A1) (iii) 0-20 kVA (Single phase) (B): >20 kVA and ≤ 50 kVA (C): >50 KVA LT III: LT - Public Water Works (PWW) (A): 0-20 KVA (B): >20 kVA and ≤ 40 kVA (C): >40 KVA LT IV: LT - Agriculture LT IV(A): LT - AG Un-metered - Pumpsets Category 1 Zones (Above 1318 Hrs/HP/Annum) (a) 0-5 HP (b) Above 5 HP - 7.5 HP (c) Above 7.5 HP Category 2 Zones (Below 1318 Hrs/HP/Annum) (a) 0-5 HP (b) Above 5 HP - 7.5 HP (c) Above 7.5 HP LT IV(B): LT - Agriculture Metered Tariff - Pumpsets LT IV(C): LT - Agriculture Metered – Others MSEDCL FY 2023-24 Energy Charges (Rs/unit) % Change over Proposed FY 2022-23 Proposed FY 2024-25 Energy Charges (Rs/unit) % Change over Proposed FY 2023-24 Proposed 1.50 7% 1.60 7% 1.70 6% 3.70 7.70 9.90 11.50 6% 3% 0% 0% 3.90 7.90 9.90 11.60 5% 3% 0% 1% 4.10 8.10 9.90 11.70 5% 3% 0% 1% 8.30 2% 8.50 2% 8.70 2% 8.30 10.10 12.00 2% 3% 2% 8.50 10.40 12.10 2% 3% 1% 8.70 10.70 12.20 2% 3% 1% 2.50 3.80 5.20 4% 3% 4% 2.60 3.90 5.40 4% 3% 4% 2.70 4.00 5.60 4% 3% 4% Rs./HP/Month Rs./HP/Month Rs./HP/Month 445 480 535 6% 5% 6% 470 505 565 6% 5% 6% 495 535 595 5% 6% 5% 350 375 435 2.40 4.00 6% 6% 6% 4% 5% 370 395 460 2.50 4.20 6% 5% 6% 4% 5% 390 415 485 2.60 4.40 5% 5% 5% 4% 5% January 20 265 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 202: Comparison of Existing and Proposed Energy Charges (excl. Wheeling Charges) for LT Category (3/4) Particulars LT V (A): LT - Industry - Powerlooms (i): 0-20 KVA (ii): Above 20 KVA (iii) 0-20 kVA (Single phase) LT V(B): LT - Industry - General (i): 0-20 KVA (ii): Above 20 KVA (iii) 0-20 kVA (Single phase) LT VI: LT - Street Light (A): Grampanchayat; A B & C Class Municipal Council (B): Municipal corporation Area LT VII: LT - Temporary Connection (A): LT - Temporary Supply Religious (TSR) (B): LT - Temporary Supply Others (TSO) LT VIII: LT - Advertisements and Hoardings LT IX: LT - Crematorium and Burial Grounds LT X (A) - Public Services – Govt. (i): ≤ 20 kVA Upto 200 units) (i): ≤ 20 kVA (Above 200 units) (ia) ≤ 20 kVA (Single phase) (ii): >20 - ≤ 50 kVA iii): >50 kVA LT X(B) - Public Services - Others (i): ≤ 20 kVA Upto 200 units) (i): ≤ 20 kVA (Above 200 units) (ia) ≤ 20 kVA (Single phase) (ii): >20 - ≤ 50 kVA (iii): >50 kVA LT XI – Electric Vehicle Charging Station MSEDCL FY 2020-21 Energy Charges (Rs/unit) % Change over Existing Proposed FY 2019-20 Approved FY 2021-22 Energy Charges (Rs/unit) % Change over Proposed FY 2020-21 Proposed 4.69 6.02 4.69 4.90 6.30 4.90 4% 5% 4% 5.10 6.40 5.10 4% 2% 4% 4.81 5.70 4.81 5.00 5.90 5.00 4% 4% 4% 5.30 6.20 5.30 6% 5% 6% 4.80 5.85 4.90 6.00 2% 3% 5.00 6.20 2% 3% 3.27 12.79 12.00 3.26 3.40 13.20 12.40 3.40 4% 3% 3% 4% 3.50 13.60 12.80 3.50 3% 3% 3% 3% 3.70 3.90 5% 3.70 4.50 5.70 3.90 4.70 6.00 5% 4% 5% 6.10 5% 6.10 7.50 8.00 5.30 5% 6% 5% 6% 3.00 4.20 3.00-4.20 4.30 5.40 4.25 6.90 4.25-6.90 6.80 7.20 4.72 January 20 5% 6% 5.80 5.80 7.10 7.60 5.00 4% 6% 6% 266 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 203: Comparison of Existing and Proposed Energy Charges (excl. Wheeling Charges) for LT Category (4/4) FY 2022-23 Energy Charges (Rs/unit) % Change over Proposed FY 2021-22 Proposed Particulars LT V (A): LT - Industry - Powerlooms (i): 0-20 KVA (ii): Above 20 KVA (iii) 0-20 kVA (Single phase) LT V(B): LT - Industry - General (i): 0-20 KVA (ii): Above 20 KVA (iii) 0-20 kVA (Single phase) LT VI: LT - Street Light (A): Grampanchayat; A B & C Class Municipal Council (B): Municipal corporation Area LT VII: LT - Temporary Connection (A): LT - Temporary Supply Religious (TSR) (B): LT - Temporary Supply Others (TSO) LT VIII: LT - Advertisements and Hoardings LT IX: LT - Crematorium and Burial Grounds LT X (A) - Public Services – Govt. (i): ≤ 20 kVA *Upto 200 units) (i): ≤ 20 kVA (Above 200 units) (ia) ≤ 20 kVA (Single phase) (ii): >20 - ≤ 50 kVA iii): >50 kVA LT X(B) - Public Services - Others (i): ≤ 20 kVA Upto 200 units) (i): ≤ 20 kVA (Above 200 units) (ia) ≤ 20 kVA (Single phase) (ii): >20 - ≤ 50 kVA (iii): >50 kVA LT XI – Electric Vehicle Charging Station MSEDCL FY 2023-24 Energy Charges (Rs/unit) % Change over Proposed FY 2022-23 Proposed FY 2024-25 Energy Charges (Rs/unit) % Change over Proposed FY 2023-24 Proposed 5.40 6.60 5.40 6% 3% 6% 5.70 6.80 5.70 6% 3% 6% 6.00 7.00 6.00 5% 3% 5% 5.60 6.50 5.60 6% 5% 6% 5.90 6.80 5.90 5% 5% 5% 6.20 7.10 6.20 5% 4% 5% 5.20 6.40 4% 3% 5.40 6.60 4% 3% 5.60 6.80 4% 3% 3.60 14.00 13.20 3.60 3% 3% 3% 3% 3.70 14.40 13.60 3.70 3% 3% 3% 3% 3.80 14.80 14.00 3.80 3% 3% 3% 3% 4.10 5% 4.30 5% 4.50 5% 4.10 4.90 6.30 5% 4% 5% 4.30 5.10 6.60 5% 4% 5% 4.50 5.40 6.90 5% 6% 5% 6.40 5% 6.70 5% 7.00 4% 6.40 7.90 8.40 5.60 5% 5% 5% 6% 6.70 8.30 8.80 5.90 5% 5% 5% 5% 7.00 8.70 9.20 6.20 4% 5% 5% 5% January 20 267 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 204: Comparison of Existing and Proposed Fixed Charges for HT Category (1/2) Particulars HT I HT - Industry HT, EHV HT I (B): HT - Industry (Seasonal) HT, EHV HT II: HT – Commercial HT, EHV HT III : HT - Railways/Metro/Monorail Traction HT, EHV HT IV: HT - Public Water Works HT, EHV HT V(A): HT - Agriculture Pumpsets HT, EHV HT V(B): HT - Agriculture - Others HT, EHV HT VI: HT - Group Housing Societies (Residential) HT, EHV HT VIII(A): HT - Temporary Supply Religious (TSR) HT, EHV HT VIII(B): HT - Temporary Supply Others (TSO) HT, EHV HT IX: HT - Public Services HT IX(A): HT - Public Services-Govt. HT, EHV HT IX(B): HT - Public Services-Others HT, EHV HT X: HT – Electric Vehicle Charging Station HT, EHV MSEDCL FY 2020-21 Fixed Charges (Rs/kVA/mth) % Change over Existing Proposed FY 2019-20 Approved FY 2021-22 Fixed Charges (Rs/kVA/mth) % Change over Proposed FY 2020-21 Proposed 391 431 10% 475 10% 391 431 10% 464 8% 391 421 8% 453 8% 391 431 10% 464 8% 391 421 8% 453 8% 69 87 26% 94 8% 69 87 26% 94 8% 313 337 8% 363 8% 418 460 10% 495 8% 391 431 10% 464 8% 391 421 8% 453 8% 391 421 8% 453 8% 70 76 9% 82 8% January 20 268 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 205: Comparison of Existing and Proposed Fixed Charges for HT Category (2/2) Particulars HT I HT - Industry HT, EHV HT I (B): HT - Industry (Seasonal) HT, EHV HT II: HT – Commercial HT, EHV HT III : HT - Railways/Metro/Monorail Traction HT, EHV HT IV: HT - Public Water Works HT, EHV HT V(A): HT - Agriculture Pumpsets HT, EHV HT V(B): HT - Agriculture - Others HT, EHV HT VI: HT - Group Housing Societies (Residential) HT, EHV HT VIII(A): HT - Temporary Supply Religious (TSR) HT, EHV HT VIII(B): HT - Temporary Supply Others (TSO) HT, EHV HT IX: HT - Public Services HT IX(A): HT - Public Services-Govt. HT, EHV HT IX(B): HT - Public Services-Others HT, EHV HT X: HT – Electric Vehicle Charging Station HT, EHV MSEDCL FY 2022-23 Fixed Charges (Rs/kVA/mth) % Change over Proposed FY 2021-22 Proposed FY 2023-24 Fixed Charges (Rs/kVA/mth) % Change over Proposed FY 2022-23 Proposed FY 2024-25 Fixed Charges (Rs/kVA/mth) % Change over Proposed FY 2023-24 Proposed 523 10% 576 10% 634 10% 499 8% 537 8% 578 8% 487 8% 524 8% 564 8% 499 8% 537 8% 578 8% 487 8% 524 8% 564 8% 102 9% 110 8% 119 8% 102 9% 110 8% 119 8% 391 8% 421 8% 453 8% 533 8% 573 8% 616 8% 499 8% 537 8% 578 8% 487 8% 524 8% 564 8% 487 8% 524 8% 564 8% 89 9% 96 8% 104 8% January 20 269 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 206: Comparison of Existing and Proposed Fixed Charges for LT Category (1/4) Particulars LT Residential LT I(A): LT - Residential-BPL LT I(B): LT - Residential 1-100 units 101-300 units 301-500 units >500 units Three Phase Charges LT II: LT - Non-Residential (A1) (i): 0 – 20 kVA (Upto 200 units per month) (A1) (ii): 0 – 20 kVA (Above 200 units per month) (A2) 0-20 kVA (Single phase) (B): >20 kVA and ≤ 50 kVA (C): >50 KVA LT III: LT - Public Water Works (PWW) (A): 0-20 kVA (B): >20 kVA and ≤ 50 kVA (C): >50 KVA LT IV: LT - Agriculture LT IV(B): LT - Agriculture Metered Tariff - Pumpsets LT IV(C): LT - Agriculture Metered – Others MSEDCL Units (Existing) Units (Proposed) Existing FY 2020-21 Fixed Charges % Change over Proposed FY 2019-20 Approved FY 2021-22 Fixed Charges % Change over Proposed FY 2020-21 Proposed Rs/conn/mth Rs/conn/mth 25 25 Rs/conn/mth Rs/conn/mth Rs/conn/mth Rs/conn/mth Rs/conn/mth Rs/conn/mth Rs/conn/mth Rs/conn/mth Rs/conn/mth Rs/conn/mth 90 90 90 90 320 100 110 110 120 350 11% 22% 22% 33% 9% 105 116 116 132 382 5% 5% 5% 10% 9% Rs/Conn/mth Rs/Conn/mth Rs/Conn/mth Rs/kVA/mth Rs/kVA/mth Rs/kVA/mth Rs/kVA/mth Rs/Conn/mth Rs/kVA/mth Rs/kVA/mth 391 391 391 391 391 207 - 218 5% 411 411 411 5% 5% 5% 432 432 432 5% 5% 5% Rs/kVA/mth Rs/kVA/mth Rs/kVA/mth Rs/kVA/mth Rs/kVA/mth Rs/kVA/mth 97 117 146 102 123 154 5% 5% 5% 108 130 162 6% 6% 5% Rs/HP/mth Rs/kW/mth Rs/HP/mth Rs/kW/mth 40 108 42 114 5% 6% 45 120 7% 5% January 20 0% 25 0% 270 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 207: Comparison of Existing and Proposed Fixed Charges for LT Category (2/4) Particulars LT Residential LT I(A): LT - Residential-BPL LT I(B): LT - Residential 1-100 units 101-300 units 301-500 units >500 units Three Phase Charges LT II: LT - Non-Residential (A1) (i): 0 – 20 kVA (Upto 200 units per month) (A1) (ii): 0 – 20 kVA (Above 200 units per month) (A2) 0-20 kVA (Single phase) (B): >20 kVA and ≤ 50 kVA (C): >50 KVA LT III: LT - Public Water Works (PWW) (A): 0-20 kVA (B): >20 kVA and ≤ 50 kVA (C): >50 KVA LT IV: LT - Agriculture LT IV(B): LT - Agriculture Metered Tariff - Pumpsets LT IV(C): LT - Agriculture Metered – Others MSEDCL FY 2022-23 Fixed Charges % Change over Proposed FY 2021-22 Proposed FY 2023-24 Fixed Charges % Change over Proposed FY 2022-23 Proposed FY 2024-25 Fixed Charges % Change over Proposed FY 2023-24 Proposed Units (Existing) Units (Proposed) Rs/conn/mth Rs/conn/mth 25 Rs/conn/mth Rs/conn/mth Rs/conn/mth Rs/conn/mth Rs/conn/mth Rs/conn/mth Rs/conn/mth Rs/conn/mth Rs/conn/mth Rs/conn/mth 111 122 122 146 417 6% 5% 5% 11% 9% 117 129 129 161 455 5% 6% 6% 10% 9% 123 136 136 178 497 5% 5% 5% 11% 9% Rs/Conn/mth Rs/Conn/mth Rs/Conn/mth Rs/kVA/mth Rs/kVA/mth Rs/kVA/mth Rs/kVA/mth Rs/Conn/mth Rs/kVA/mth Rs/kVA/mth 229 5% 241 5% 254 5% 454 454 454 5% 5% 5% 477 477 477 5% 5% 5% 501 501 501 5% 5% 5% Rs/kVA/mth Rs/kVA/mth Rs/kVA/mth Rs/kVA/mth Rs/kVA/mth Rs/kVA/mth 114 137 171 6% 5% 6% 120 144 180 5% 5% 5% 126 152 189 5% 6% 5% Rs/HP/mth Rs/kW/mth Rs/HP/mth Rs/kW/mth 48 126 7% 5% 51 133 6% 6% 54 140 6% 5% January 20 0% 25 0% 25 0% 271 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 208: Comparison of Existing and Proposed Fixed Charges for LT Category (3/4) Particulars LT V (A): LT - Industry - Powerlooms (i): 0-20 KVA (ii): Above 20 KVA (iii) 0-20 kVA (Single phase) LT V(B): LT - Industry - General (i): 0-20 KVA (ii): Above 20 KVA (iii) 0-20 kVA (Single phase) LT VI: LT - Street Light (A): Grampanchayat; A B & C Class Municipal Council (B): Municipal corporation Area LT VII: LT - Temporary Connection (A): LT - Temporary Supply Religious (TSR) (B): LT - Temporary Supply Others (TSO) LT VIII: LT - Advertisements and Hoardings LT IX: LT - Crematorium and Burial Grounds LT X (A) - Public Services – Govt. (i): ≤ 20 kVA (Upto 200 units) (i): ≤ 20 kVA (Above 200 units) (ia) 0-20 kVA (Single phase) (ii): >20 - ≤ 50 kVA iii): >50 kVA LT X(B) - Public Services - Others (i): ≤ 20 kVA (Upto 200 units) (i): ≤ 20 kVA (Above 200 units) (ia) 0-20 kVA (Single phase) (ii): >20 - ≤ 50 kVA iii): >50 kVA LT XI – Electric Vehicle Charging Station MSEDCL Units (Existing) Units (Proposed) Existing FY 2020-21 Fixed Charges % Change over Proposed FY 2019-20 Approved FY 2021-22 Fixed Charges % Change over Proposed FY 2020-21 Proposed Rs/Conn/mth Rs/kVA/mth Rs/Conn/mth Rs/kVA/mth Rs/kVA/mth Rs/Conn/mth 441 294 441 158 309 463 5% 5% 166 325 486 5% 5% 5% Rs/Conn/mth Rs/kVA/mth Rs/Conn/mth Rs/kVA/mth Rs/kVA/mth Rs/Conn/mth 441 294 441 158 309 463 5% 5% 166 325 486 5% 5% 5% Rs/kW/mth Rs/kW/mth Rs/kW/mth Rs/kW/mth 108 108 114 114 6% 6% 120 120 5% 5% Rs/Conn/mth Rs/Conn/mth Rs/Conn/mth Rs/Conn/mth Rs/Conn/mth Rs/Conn/mth Rs/Conn/mth Rs/Conn/mth 443 449 833 438 466 472 875 460 5% 5% 5% 5% 490 496 919 483 5% 5% 5% 5% Rs/Conn/mth Rs/Conn/mth Rs/Conn/mth Rs/kVA/mth Rs/kVA/mth Rs/kVA/mth Rs/kVA/mth Rs/Conn/mth Rs/kVA/mth Rs/kVA/mth 323 323 323 323 323 161 - 170 6% 340 340 340 5% 5% 5% 357 357 357 5% 5% 5% Rs/Conn/mth Rs/Conn/mth Rs/Conn/mth Rs/kVA/mth Rs/kVA/mth Rs/kVA/mth Rs/kVA/mth Rs/kVA/mth Rs/Conn/mth Rs/kVA/mth Rs/kVA/mth Rs/kVA/mth 351 351 351 351 351 70 252 - 265 5% 369 369 369 74 5% 5% 5% 6% 388 388 388 78 5% 5% 5% 5% January 20 272 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 209: Comparison of Existing and Proposed Fixed Charges for LT Category (4/4) Particulars LT V (A): LT - Industry - Powerlooms (i): 0-20 KVA (ii): Above 20 KVA (iii) 0-20 kVA (Single phase) LT V(B): LT - Industry - General (i): 0-20 KVA (ii): Above 20 KVA (iii) 0-20 kVA (Single phase) LT VI: LT - Street Light (A): Grampanchayat; A B & C Class Municipal Council (B): Municipal corporation Area LT VII: LT - Temporary Connection (A): LT - Temporary Supply Religious (TSR) (B): LT - Temporary Supply Others (TSO) LT VIII: LT - Advertisements and Hoardings LT IX: LT - Crematorium and Burial Grounds LT X (A) - Public Services – Govt. (i): ≤ 20 kVA (Upto 200 units) (i): ≤ 20 kVA (Above 200 units) (ia) 0-20 kVA (Single phase) (ii): >20 - ≤ 50 kVA iii): >50 kVA LT X(B) - Public Services - Others (i): ≤ 20 kVA (Upto 200 units) (i): ≤ 20 kVA (Above 200 units) (ia) 0-20 kVA (Single phase) (ii): >20 - ≤ 50 kVA iii): >50 kVA LT XI – Electric Vehicle Charging Station MSEDCL FY 2022-23 Fixed Charges % Change over FY 2021-22 Proposed Proposed FY 2023-24 Fixed Charges % Change over FY 2022-23 Proposed Proposed FY 2024-25 Fixed Charges % Change over FY 2023-24 Proposed Proposed Units (Existing) Units (Proposed) Rs/Conn/mth Rs/kVA/mth Rs/Conn/mth Rs/kVA/mth Rs/kVA/mth Rs/Conn/mth 175 342 510 5% 5% 5% 184 360 536 5% 5% 5% 194 378 563 5% 5% 5% Rs/Conn/mth Rs/kVA/mth Rs/Conn/mth Rs/kVA/mth Rs/kVA/mth Rs/Conn/mth 175 342 510 5% 5% 5% 184 360 536 5% 5% 5% 194 378 563 5% 5% 5% Rs/kW/mth Rs/kW/mth Rs/kW/mth Rs/kW/mth 126 126 5% 5% 133 133 6% 6% 140 140 5% 5% Rs/Conn/mth Rs/Conn/mth Rs/Conn/mth Rs/Conn/mth Rs/Conn/mth Rs/Conn/mth Rs/Conn/mth Rs/Conn/mth 515 521 965 508 5% 5% 5% 5% 541 548 1,014 534 5% 5% 5% 5% 569 576 1,065 561 5% 5% 5% 5% Rs/Conn/mth Rs/Conn/mth Rs/Conn/mth Rs/kVA/mth Rs/kVA/mth Rs/kVA/mth Rs/kVA/mth Rs/Conn/mth Rs/kVA/mth Rs/kVA/mth 179 5% 188 5% 198 5% 375 375 375 5% 5% 5% 394 394 394 5% 5% 5% 414 414 414 5% 5% 5% Rs/Conn/mth Rs/Conn/mth Rs/Conn/mth Rs/kVA/mth Rs/kVA/mth Rs/kVA/mth Rs/kVA/mth Rs/kVA/mth Rs/Conn/mth Rs/kVA/mth Rs/kVA/mth Rs/kVA/mth 279 5% 293 5% 308 5% 408 408 408 82 5% 5% 5% 5% 429 429 429 87 5% 5% 5% 6% 451 451 451 92 5% 5% 5% 6% January 20 273 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 12.3 Proposed Recovery from Tariff 12.3.1 Following table summarised the year on year increase in ACoS along with the recovery from revised tariff. Financial Year Revenue at Existing Tariff (Rs. Crs) Revenue at Proposed Tariff (Rs. Crs) Revenue Recovery (Rs. Crs) Sales (MU) Average Cost of Supply (ACoS) (Rs/kWh) % Increase/Decrease Approved for FY 19-20 69,086 74,179 5,093 1,08,369 6.85 FY 20-21 FY 21-22 FY 22-23 FY 23-24 FY 24-25 76,998 82,925 79,927 88,887 83,018 95,051 86,310 1,01,390 89,801 1,08,160 5,928 8,960 12,033 15,080 18,358 1,14,510 1,18,884 1,23,506 1,28,397 1,33,580 7.24 7.48 7.70 7.90 8.10 5.80% 3.25% 2.93% 2.61% 2.54% 12.4 ABR/ACoS Ratio 12.4.1 Following Tables provides the ABR/ACOS ratio for the Control Period. MSEDCL January 20 274 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 210: ABR and Cross Subsidy trajectory for FY 2020-21 Category HT I (A): HT - Industry HT II: HT - Commercial HT III: HT - Railways/Metro/Monorail Traction HT IV: HT - Public Water Works (PWW) HT V: HT - Agriculture Pumps HT VI: HT - Group Housing Societies (Residential) HT VIII: HT - Temporary Supply HT IX : HT - Public Services Govt HT IX : HT - Public Services Others HT Total LT I: LT - Residential LT II: LT - Non-Residential LT III: LT - Public Water Works (PWW) LT IV: LT - Agriculture Metered LT V (A): LT - Industry - Power Looms LT V (B): LT - Industry – General LT VI: LT - Street Light LT VIII: LT - Advertisements and Hoardings LT IX: LT - Crematorium and Burial Grounds LT X- Public Services Govt. LT X- Public Services Others LT Total MSEDCL Ratio of Average Billing Rate Average Billing Rate Projected to Projected Average Cost of (Rs./kVAh) or (Rs/kWh) % increase Average Supply (%) / decrease % increase Cost of in Cross- in tariff (%) Existing Proposed Existing Tariff Proposed Supply subsidy Tariff for FY Tariff for for FY 2019- Tariff for FY (Rs/kWh) 2019-20 FY 2020-21 20 2020-21 7.24 8.42 14.16 8.89 7.49 4.27 7.76 13.29 9.63 11.65 8.59 7.22 11.79 4.17 3.74 7.12 8.61 6.58 18.05 5.04 8.71 8.85 6.12 9.04 15.27 10.57 8.21 4.50 8.40 16.85 10.73 12.71 9.12 7.21 11.46 4.18 3.71 7.33 8.82 6.50 20.39 5.15 7.10 9.43 6.15 January 20 114% 191% 120% 101% 58% 105% 180% 130% 157% 116% 98% 159% 56% 50% 96% 116% 89% 244% 68% 118% 120% 83% 125% 211% 146% 113% 62% 116% 233% 148% 175% 126% 100% 158% 58% 51% 101% 122% 90% 282% 71% 98% 130% 85% 11% 20% 26% 12% 4% 11% 53% 18% 18% 10% 2% -1% 2% 1% 5% 6% 1% 38% 3% -20% 10% 2% 7% 8% 19% 10% 5% 8% 27% 11% 9% 6% 0% -3% 0% -1% 3% 2% -1% 13% 2% -18% 7% 0% 275 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 211: ABR and Cross Subsidy trajectory for FY 2021-22 Category HT I (A): HT - Industry HT II: HT - Commercial HT III: HT - Railways/Metro/Monorail Traction HT IV: HT - Public Water Works (PWW) HT V: HT - Agriculture Pumps HT VI: HT - Group Housing Societies (Residential) HT VIII: HT - Temporary Supply HT IX : HT - Public Services Govt HT IX : HT - Public Services Others HT Total LT I: LT - Residential LT II: LT - Non-Residential LT III: LT - Public Water Works (PWW) LT IV: LT - Agriculture Metered LT V (A): LT - Industry - Power Looms LT V (B): LT - Industry – General LT VI: LT - Street Light LT VIII: LT - Advertisements and Hoardings LT IX: LT - Crematorium and Burial Grounds LT X- Public Services Govt. LT X- Public Services Others LT Total MSEDCL Ratio of Average Billing Rate Average Billing Rate Projected to Projected Average Cost of (Rs./kVAh) or (Rs/kWh) % increase Average Supply (%) / decrease % increase Cost of in Cross- in tariff (%) Proposed Proposed Proposed Supply Proposed Tariff subsidy (Rs/kWh) Tariff for FY Tariff for FY Tariff for for FY 2021-22 2020-21 2021-22 FY 2020-21 7.48 9.04 15.27 10.57 8.21 4.50 8.40 16.85 10.73 12.71 9.12 7.21 11.46 4.18 3.71 7.33 8.82 6.50 20.39 5.15 7.10 9.43 6.15 January 20 9.25 15.44 11.00 8.50 4.58 8.81 17.76 11.07 12.98 9.31 7.47 11.72 4.30 3.85 7.52 9.23 6.61 21.31 5.28 7.37 9.82 6.40 125% 211% 146% 113% 62% 116% 233% 148% 175% 126% 100% 158% 58% 51% 101% 122% 90% 282% 71% 98% 130% 85% 124% 207% 147% 114% 61% 118% 238% 148% 174% 124% 100% 157% 58% 51% 101% 123% 88% 285% 71% 99% 131% 86% -1% -4% 1% 0% -1% 2% 5% 0% -2% -2% 0% -2% 0% 0% -1% 2% -1% 3% -1% 1% 1% 1% 2% 1% 4% 4% 2% 5% 5% 3% 2% 2% 4% 2% 3% 4% 3% 5% 2% 5% 2% 4% 4% 4% 276 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 212: ABR and Cross Subsidy trajectory for FY 2022-23 Category HT I (A): HT - Industry HT II: HT - Commercial HT III: HT - Railways/Metro/Monorail Traction HT IV: HT - Public Water Works (PWW) HT V: HT - Agriculture Pumps HT VI: HT - Group Housing Societies (Residential) HT VIII: HT - Temporary Supply HT IX : HT - Public Services Govt HT IX : HT - Public Services Others HT Total LT I: LT - Residential LT II: LT - Non-Residential LT III: LT - Public Water Works (PWW) LT IV: LT - Agriculture Metered LT V (A): LT - Industry - Power Looms LT V (B): LT - Industry – General LT VI: LT - Street Light LT VIII: LT - Advertisements and Hoardings LT IX: LT - Crematorium and Burial Grounds LT X- Public Services Govt. LT X- Public Services Others LT Total MSEDCL Ratio of Average Billing Average Billing Rate Projected Rate to Projected Average (Rs./kVAh) or (Rs/kWh) % increase Average Cost of Supply (%) / decrease % increase Cost of in Cross- in tariff (%) Proposed Proposed Proposed Supply Proposed Tariff subsidy (Rs/kWh) Tariff for FY Tariff for FY Tariff for for FY 2022-23 2021-22 2022-23 FY 2021-22 7.70 9.25 15.44 11.00 8.50 4.58 8.81 17.76 11.07 12.98 9.31 7.47 11.72 4.30 3.85 7.52 9.23 6.61 21.31 5.28 7.37 9.82 6.40 January 20 9.46 15.60 11.42 8.78 4.66 9.24 18.72 11.41 13.25 9.49 7.73 11.94 4.41 3.96 7.78 9.63 6.79 22.24 5.39 7.62 10.20 6.64 124% 207% 147% 114% 61% 118% 238% 148% 174% 124% 100% 157% 58% 51% 101% 123% 88% 285% 71% 99% 131% 86% 123% 203% 148% 114% 61% 120% 243% 148% 172% 123% 100% 155% 57% 51% 101% 125% 88% 289% 70% 99% 132% 86% -1% -4% 1% 0% -1% 2% 6% 0% -1% -1% 0% -1% 0% 0% 1% 2% 0% 4% -1% 1% 1% 1% 2% 1% 4% 3% 2% 5% 5% 3% 2% 2% 3% 2% 3% 3% 4% 4% 3% 4% 2% 3% 4% 4% 277 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 213: ABR and Cross Subsidy trajectory for FY 2023-24 Category HT I (A): HT - Industry HT II: HT - Commercial HT III: HT - Railways/Metro/Monorail Traction HT IV: HT - Public Water Works (PWW) HT V: HT - Agriculture Pumps HT VI: HT - Group Housing Societies (Residential) HT VIII: HT - Temporary Supply HT IX : HT - Public Services Govt HT IX : HT - Public Services Others HT Total LT I: LT - Residential LT II: LT - Non-Residential LT III: LT - Public Water Works (PWW) LT IV: LT - Agriculture Metered LT V (A): LT - Industry - Power Looms LT V (B): LT - Industry – General LT VI: LT - Street Light LT VIII: LT - Advertisements and Hoardings LT IX: LT - Crematorium and Burial Grounds LT X- Public Services Govt. LT X- Public Services Others LT Total MSEDCL Ratio of Average Billing Average Billing Rate Projected Rate to Projected Average (Rs./kVAh) or (Rs/kWh) % increase Average Cost of Supply (%) / decrease % increase Cost of in Cross- in tariff (%) Proposed Proposed Proposed Supply Proposed Tariff subsidy Tariff for FY Tariff for FY Tariff for (Rs/kWh) for FY 2023-24 2022-23 2023-24 FY 2022-23 7.90 9.46 15.60 11.42 8.78 4.66 9.24 18.72 11.41 13.25 9.49 7.73 11.94 4.41 3.96 7.78 9.63 6.79 22.24 5.39 7.62 10.20 6.64 January 20 9.67 15.76 11.84 9.05 4.73 9.68 19.73 11.76 13.52 9.66 7.96 12.14 4.50 4.05 8.03 10.01 6.94 23.20 5.47 7.85 10.55 6.86 123% 203% 148% 114% 61% 120% 243% 148% 172% 123% 100% 155% 57% 51% 101% 125% 88% 289% 70% 99% 132% 86% 122% 200% 150% 115% 60% 123% 250% 149% 171% 122% 101% 154% 57% 51% 102% 127% 88% 294% 69% 99% 134% 87% -1% -3% 2% 0% -1% 2% 7% 1% -1% -1% 0% -2% 0% 0% 1% 2% 0% 5% -1% 0% 1% 1% 2% 1% 4% 3% 2% 5% 5% 3% 2% 2% 3% 2% 2% 2% 3% 4% 2% 4% 2% 3% 3% 3% 278 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 214: ABR and Cross Subsidy trajectory for FY 2024-25 Category HT I (A): HT - Industry HT II: HT - Commercial HT III: HT - Railways/Metro/Monorail Traction HT IV: HT - Public Water Works (PWW) HT V: HT - Agriculture Pumps HT VI: HT - Group Housing Societies (Residential) HT VIII: HT - Temporary Supply HT IX : HT - Public Services Govt HT IX : HT - Public Services Others HT Total LT I: LT - Residential LT II: LT - Non-Residential LT III: LT - Public Water Works (PWW) LT IV: LT - Agriculture Metered LT V (A): LT - Industry - Power Looms LT V (B): LT - Industry – General LT VI: LT - Street Light LT VIII: LT - Advertisements and Hoardings LT IX: LT - Crematorium and Burial Grounds LT X- Public Services Govt. LT X- Public Services Others LT Total MSEDCL Ratio of Average Billing Rate Average Billing Rate Projected to Projected Average Cost of (Rs./kVAh) or (Rs/kWh) % increase Average Supply (%) / decrease % increase Cost of in Cross- in tariff (%) Proposed Proposed Proposed Supply Proposed Tariff subsidy Tariff for FY Tariff for FY Tariff for (Rs/kWh) for FY 2024-25 2023-24 2024-25 FY 2023-24 8.10 9.67 15.76 11.84 9.05 4.73 9.68 19.73 11.76 13.52 9.66 7.96 12.14 4.50 4.05 8.03 10.01 6.94 23.20 5.47 7.85 10.55 6.86 January 20 9.85 15.92 12.29 9.32 4.81 10.14 20.83 12.14 13.80 9.81 8.20 12.33 4.59 4.14 8.27 10.39 7.10 24.18 5.55 8.10 10.90 7.08 122% 200% 150% 115% 60% 123% 250% 149% 171% 122% 101% 154% 57% 51% 102% 127% 88% 294% 69% 99% 134% 87% 122% 197% 152% 115% 59% 125% 257% 150% 170% 121% 101% 152% 57% 51% 102% 128% 88% 299% 69% 100% 135% 87% -1% -3% 2% 1% -1% 3% 7% 1% -1% -1% 0% -1% 0% 0% 0% 2% 0% 5% -1% 1% 1% 1% 2% 1% 4% 3% 2% 5% 6% 3% 2% 2% 3% 2% 2% 2% 3% 4% 2% 4% 1% 3% 3% 3% 279 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 12.5 Cross Subsidy Trajectory 12.5.1 MSEDCL submits that for certain categories such as HT Industrial, HT Commercial, HT Public Services etc., there is a reducing trend in cross subsidy. Further, for LT Residential, LT Public Services etc. there is increasing trend in cross subsidy. However, considering the recovery of proposed revenue gap, changes in tariff design and philosophy, there is a need to revise the tariff for various categories. Accordingly, MSEDCL has proposed the tariffs to recover the proposed revenue gap. MSEDCL January 20 280 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 215: Cross Subsidy Trajectory for the Control Period FY 2020-21 FY 2021-22 FY 2022-23 FY 2023-24 FY 2024-25 Category HT I (A): HT - Industry HT II: HT - Commercial HT III: HT - Railways/Metro/Monorail Traction HT IV: HT - Public Water Works (PWW) HT V: HT - Agriculture Pumps HT VI: HT - Group Housing Societies HT VIII: HT - Temporary Supply HT IX : HT - Public Services Govt HT IX : HT - Public Services Others HT Total LT I: LT - Residential LT II: LT - Non-Residential LT III: LT - Public Water Works (PWW) LT IV: LT - Agriculture Metered LT V (A): LT - Industry - Power Looms LT V (B): LT - Industry – General LT VI: LT - Street Light LT VIII: LT - Advertisements and Hoardings LT IX: LT - Crematorium and Burial Grounds LT X- Public Services Govt. LT X- Public Services Others LT Total MSEDCL Projected 125% 211% 146% 113% 62% 116% 233% 148% 175% 126% 100% 158% 58% 51% 101% 122% 90% 282% 71% 98% 130% 85% January 20 Projected 124% 207% 147% 114% 61% 118% 238% 148% 174% 124% 100% 157% 58% 51% 101% 123% 88% 285% 71% 99% 131% 86% Projected 123% 203% 148% 114% 61% 120% 243% 148% 172% 123% 100% 155% 57% 51% 101% 125% 88% 289% 70% 99% 132% 86% Projected 122% 200% 150% 115% 60% 123% 250% 149% 171% 122% 101% 154% 57% 51% 102% 127% 88% 294% 69% 99% 134% 87% Projected 122% 197% 152% 115% 59% 125% 257% 150% 170% 121% 101% 152% 57% 51% 102% 128% 88% 299% 69% 100% 135% 87% 281 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 13 CROSS SUBSIDY SURCHARGE 13.1 Background 13.1.1 Section 2 (47) of the said Electricity Act defines “Open Access’, while Section 42 of the said Act inter – alia mandates the Distribution Licensee to provide Open Access to eligible consumers, subject to payment of “Cross Subsidy Surcharge”, “Additional Surcharge” & other applicable charges. 13.1.2 MSEDCL further submits that Section 42(2) of the Act provides for the levy of Cross Subsidy Surcharge (CSS). The relevant provision of the Act is reproduced below:“……. In determining the charges for wheeling, it shall have due regard to all relevant factors including such cross-subsidies, and other operational constraints; Provided that such open access shall be allowed on payment of surcharge in addition to the charges for wheeling as may be determined by the state commission; Provided further that such surcharge shall be utilised to meet the requirements of the current level of cross-subsidy within the area of distribution licensee….(emphasis added)” 13.1.3 Section 86 (1) (a) of the said Act inter – alia mandates the Hon’ble Commission to determine “Cross Subsidy Surcharge”, “Additional Surcharge” & other applicable charges payable by the consumers opting for Open Access. 13.1.4 MSEDCL submits that the National Electricity Policy as stipulated by the Central Government provides that – “Under sub – section (2) of Section 42 of the Act, a surcharge is to be levied by the respective State Commissions on consumers switching to alternate supplies under Open Access. This is to compensate the host distribution licensee serving such consumers who are permitted Open Access under Section 42 (2), for loss of Cross Subsidy element built into the tariff of such consumers………” MSEDCL January 20 282 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 13.1.5 The Central Government notified the revised National Tariff Policy on 28th January, 2016 and has revised the “Surcharge Formula” as follows: S = T – [C/ (1 - L / 100) + D + R] Where S is the Surcharge T is the tariff payable by the relevant category of consumers, including reflecting the Renewable Purchase Obligation C is the per unit weighted average cost of power purchase by the Licensee, including meeting the Renewable Purchase Obligation D is the aggregate of transmission, distribution and wheeling charge applicable to the relevant voltage level L is the aggregate of transmission, distribution and commercial losses, expressed as a percentage applicable to the relevant voltage level R is the per unit cost of carrying regulatory assets. 13.1.6 MSEDCL submits that as per the provision of Section 42 (2) of the Electricity Act 2003, the cross-subsidy surcharge needs to be based on the current level of cross subsidy. Accordingly, the consumers who opted for Open Access need to be charged for the compensation of current level of cross subsidy which prevailed during that period and in order to avoid the burden of the same getting passed on other consumers who are with the Distribution Licensee. 13.2 Lower CSS approved 13.2.1 To examine the issues related to Open Access along with issues relating to amendments in provisions relating to captive Generating plants in the Electricity Rules, 2005, a committee was constituted by CEA on the advice of Ministry of Power. In the Consultation paper by MoP issued on 24th August 2017, which is based on the report of the said Committee, it has been proposed that the SERCs should determine the CSS based on real cross subsidy. The said Paper also advocated for implementation of Tariff Policy 2016 in true spirit. The relevant extract of the said Consultation Paper is reproduced below: The Tariff Policy 2016 mandates SERCs to determine roadmap for reduction of cross subsidy and bring tariff at +/- 20% Average Cost of Supply, however it MSEDCL January 20 283 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition restricts Cross Subsidy Surcharge at 20% of the consumer tariff. In case the consumer tariff is more than 120% of Average Cost of Supply, DISCOM will not be able to recover losses through cross subsidy surcharge in case consumer opts for open access. It is essential for SERCs to implement both Para 8.3 -2 and First proviso to para 8.5.1 of the Tariff Policy 2016 simultaneously. If one of the provision could not be implemented due to some reason, the second provision should also not be implanted to that extent. 13.2.2 While approving the CSS in Case No. 195 of 2017, Hon’ble Commission worked out the various components of CSS formulae based on the approved values for FY 18-19 and FY 19-20 and computed the consumer category-wise CSS in accordance with the Tariff Policy, 2016. The CSS computed in accordance with the NTP Formulae represents the current level of cross subsidy. However, Hon’ble Commission has approved the CSS equal to minimum of the two values: Computed CSS and 20% of tariff. This has resulted in lower CSS applicable than current level of cross subsidy leading to incomplete recovery of Cross Subsidy from Open Access consumers. 13.2.3 For example, the CSS calculated by Hon’ble Commission as per the NTP formula for HT Industry (General) at EHV level for FY 18-19 was Rs 3.21 per unit whereas the CSS approved for that category was Rs 1.58 per unit only. Considering the EHV Open Access Quantum for FY 18-19, MSEDCL lost about Rs. 670 Crs of legitimate revenue from HT Industrial category Open Access consumers due to the lower level of approved CSS. 13.2.4 Such revenue deficit due to lower CSS approved is being passed on to the consumers of the MSEDCL during true up exercise. This results in:a) Substantial delay in revenue realisation which comes only after true up exercise; and b) Further tariff increase of MSEDCL consumers at large, despite not being at any fault. 13.2.5 In the process, OA consumers unduly get benefited due to less cross subsidy surcharge. As Industrial consumers are subsidizing consumers, the more impact gets loaded onto the Industrial category, raising its tariff further. Such MSEDCL January 20 284 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition increased Industrial tariff will lead to more consumers opting for Open Access which will further add to revenue deficit, leading to requirement of further tariff hike, entering into vicious cycle. Therefore, as a principle, only those consumers who opt for Open Access during a particular period should pay the CSS for such period to maintain the prevailing level of cross subsidy and should not be loaded onto MSEDCL’s consumers at large. 13.2.6 One of the reasons for tariff hike for MSEDCL was incomplete recovery of CSS as discussed above. 13.3 CSS as Compensatory Charge 13.3.1 MSEDCL submits that there can be no ambiguity with the proposition that CSS is a compensatory charge to the Discom. This principle had been accepted even by the Appellate Tribunal, in several judgments earlier. MSEDCL would also like to add that, as has also been held by the Tribunal, CSS is not only to compensate the Discom for the loss of cross subsidy, it is also to compensate the remaining consumers of the Discom who have not taken open access. The same has been up held in the APTEL in its Judgment dated 2nd December 2013 in Appeal No. 178 of 2011 (supra) which is reproduced below:" . .II The contention of the State Commission that Tariff Policy provide that the CSS should not be so enormous to suffocate the Competition is misplaced. The Act mandated the State Commission to determine the CSS to meet the requirement of current level of cross subsidy. We have to keep in mind that the CSS is paid by the subsidizing consumers only. This Tribunal in catena of cases has held that CSS is compensatory in nature. It is meant for to compensate the loss suffered by the remaining subsidized low-end consumers. Thus, in the scenario of mass changeover of consumers, the CSS has also to be such that exodus of subsidizing consumers does not load the remaining low end consumers heavily. The State Commission has to balance the interest of all the consumers, the plea taken by the State Commission in Appeal No. 132/2011 and accepted by this Tribunal in its judgment. The above submission of the State Commission also suggests that it has attempted to suppress the CSS artificially ..."(“Emphasis Added”) MSEDCL January 20 285 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 13.3.2 MSEDCL has determined the cross subsidy surcharge based on the Tariff Policy formula without putting any ceiling. 13.3.3 In view of the submissions in foregoing paragraphs, MSEDCL requests Hon’ble Commission to determine the Cross Subsidy Surcharge considering the formula prescribed by the NTP 2016 without putting any ceiling. 13.4 Computation of Cross Subsidy Surcharge for the Control Period 13.4.1 Computation of ‘ C ‘ 13.4.1.1 Computation of ‘C’ is based on the projected power purchase quantum and price for the Control Period as submitted in the Form 2 of the Regulatory Formats for the respective year. The definition/ explanation for ‘C’ has been revised in the Tariff Policy dated 28th January, 2016 with inclusion of renewable power purchase in the computation of ‘C’. The comparison of old and new tariff policy is given below. Old Tariff Policy Weighted average cost of power purchase of top 5% at the margin excluding liquid fuel based generation and renewable power. Revised Tariff Policy Per unit weighted average cost of power purchase by the licensee, including meeting the renewable purchase obligation. 13.4.1.2 Therefore, computation of ‘C’ can be taken as the total power purchase cost based on MOD principle to the total power scheduled to be purchased as per MOD principle. Therefore, the ‘C’ computed for MSEDCL for Control Period are shown in the following table. Table 216: Computation of C for the Control Period Financial Details of Power Purchase Year MUs Rs. Crs* Rs./kWh 2020-21 1,36,888 57,558 4.20 2021-22 1,41,651 60,035 4.24 2022-23 1,46,645 63,403 4.32 2023-24 1,51,950 66,662 4.39 2024-25 1,57,573 69,350 4.40 * - Power Purchase Cost is excluding the PGCIL transmission Charges MSEDCL January 20 286 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 13.4.2 Computation of System loss ‘L’ 13.4.2.1 The projected wheeling losses at the respective voltage level and the transmission losses are used to arrive at the grossed up total system losses for MSEDCL which is shown in the following table. Table 217: Computation of System Loss for the Control Period Particulars Transmission Losses (%) Wheeling Losses (%) Total System Losses (%) EHV 3.30% 0.00% 3.30% HT LT Level 3.30% 3.30% 7.50% 12.00% 10.55% 14.90% 13.4.3 Computation of wheeling charge ‘D’ 13.4.3.1 The projected wheeling charges as shown in the Chapter 11 at the respective voltage levels for MSEDCL along with per unit transmission charges (including PGCIL Charges and Intra-State) are used for the parameter “D’ in the computation of cross subsidy surcharge for the Control Period. The same wheeling charges at respective voltage levels are shown in the following table along with system losses. MSEDCL January 20 287 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 218: Computation of Wheeling Charge D for the Control Period Wheeling Charges and Transmisison Charges Wheeling Charges (Rs./Unit*) Particulars EHV HT LT Level 2020-21 0.77 1.15 2021-22 0.78 1.17 2022-23 0.78 1.17 2023-24 0.77 1.14 2024-25 0.75 1.11 Transmission Charges (Rs./Unit*) Particulars EHV HT LT Level 2020-21 1.22 1.22 1.22 2021-22 0.86 0.86 0.86 2022-23 0.87 0.87 0.87 2023-24 0.90 0.90 0.90 2024-25 0.93 0.93 0.93 Wheeling and Transmission Charges (Rs./Unit*) Particulars EHV HT LT Level 2020-21 1.22 1.99 2.37 2021-22 0.86 1.64 2.03 2022-23 0.87 1.66 2.04 2023-24 0.90 1.67 2.04 2024-25 0.93 1.68 2.05 13.4.4 Computation of Average Billing Rate “T” 13.4.4.1 ABR of MSEDCL has been taken as the effective average billing rate as per the proposed tariff for the Control Period 13.4.5 Determination of Cross subsidy surcharge “S” 13.4.5.1 The category wise CSS applicable to open access consumers arrived on consideration of the components ABR, C, L & D from the above referred respective sections is provided in the tables below:- MSEDCL January 20 288 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 219: Detailed computation of CSS for FY 2020-21 for HT Consumers Consumer Category T C (ABR) Rs./Unit* HT I HT - Industry HT 9.25 EHV 8.40 HT I (B): HT - Industry (Seasonal) HT 12.18 EHV 13.93 HT II: HT – Commercial HT 15.26 EHV 16.47 HT III : HT - Railways/Metro/Monorail Traction HT 10.71 EHV 9.55 HT IV: HT - Public Water Works HT 8.29 EHV 6.95 HT V(B): HT - Agriculture - Others HT 6.57 EHV HT VI: HT - Group Housing Societies (Residential) HT 8.77 EHV 6.00 HT VIII(B): HT - Temporary Supply Others (TSO) HT 17.38 EHV HT IX: HT - Public Services HT IX(A): HT - Public Services-Govt. Edu. Institutions and Hospitals HT 10.73 EHV HT IX(B): HT - Public Services-Others HT 12.96 EHV 10.81 MSEDCL WL TL L % % % D = WL + CSS Tx Computed Rs./Unit* 4.20 4.20 7.50% 0.00% 3.30% 3.30% 10.55% 3.30% 1.99 1.22 2.57 2.83 4.20 4.20 7.50% 0.00% 3.30% 3.30% 10.55% 3.30% 1.99 1.22 5.49 8.36 4.20 4.20 7.50% 0.00% 3.30% 3.30% 10.55% 3.30% 1.99 1.22 8.57 10.90 4.20 4.20 7.50% 0.00% 3.30% 3.30% 10.55% 3.30% 1.99 1.22 4.03 3.98 4.20 4.20 7.50% 0.00% 3.30% 3.30% 10.55% 3.30% 1.99 1.22 1.61 1.38 4.20 4.20 7.50% 0.00% 3.30% 3.30% 10.55% 3.30% 1.99 1.22 4.20 4.20 7.50% 0.00% 3.30% 3.30% 10.55% 3.30% 1.99 1.22 2.09 0.43 4.20 4.20 7.50% 0.00% 3.30% 3.30% 10.55% 3.30% 1.99 1.22 10.69 - 4.20 4.20 7.50% 0.00% 3.30% 3.30% 10.55% 3.30% 1.99 1.22 4.04 - 4.20 4.20 7.50% 0.00% 3.30% 3.30% 10.55% 3.30% 1.99 1.22 6.27 5.24 January 20 - 289 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 220: Detailed computation of CSS for FY 2020-21 for LT Consumers (1/2) Consumer Category LT Residential LT I(A): LT - Residential-BPL LT I(B): LT - Residential 1-100 units 101-300 units 301-500 units Above 500 units LT II: LT - Non-Residential (A) 0 – 20 kVA (B): >20 kVA and ≤ 50 kVA (C): >50 kVA LT IV(C): LT - Agriculture M etered – Others MSEDCL T C (ABR) Rs./Unit* WL TL L % % % D = WL + CSS Tx Computed Rs./Unit* 2.18 4.20 12.00% 3.30% 14.90% 2.37 5.61 9.68 12.32 13.15 4.20 4.20 4.20 4.20 12.00% 12.00% 12.00% 12.00% 3.30% 3.30% 3.30% 3.30% 14.90% 14.90% 14.90% 14.90% 2.37 2.37 2.37 2.37 2.37 5.01 5.85 10.55 13.39 15.35 7.95 4.20 4.20 4.20 4.20 12.00% 12.00% 12.00% 12.00% 3.30% 3.30% 3.30% 3.30% 14.90% 14.90% 14.90% 14.90% 2.37 2.37 2.37 2.37 3.24 6.08 8.04 0.65 January 20 - 290 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 221: Detailed computation of CSS for FY 2020-21 for LT Consumers (2/2) Consumer Category LT V (A): LT - Industry - Powerlooms (i): 0-20 kVA (ii): Above 20 kVA LT V(B): LT - Industry - General (i): 0-20 kVA (ii): Above 20 kVA LT VI: LT - Street Light (B): Municipal corporation Area LT VII: LT - Temporary Connection (A): LT - Temporary Supply Religious (TSR) (B): LT - Temporary Supply Others (TSO) LT VIII: LT - Advertisements and Hoardings LT X (A) - Public Services – Govt. (i): ≤ 20 kVA (ii): >20 - ≤ 50 kVA (iii): >50 kVA LT X(B) - Public Services - Others (i): ≤ 20 kVA (ii): >20 - ≤ 50 kVA (iii): >50 kVA LT XI – Electric Vehicle Charging Station MSEDCL T C (ABR) Rs./Unit* WL TL L % % % D = WL + CSS Tx Computed Rs./Unit* 6.50 7.87 4.20 4.20 12.00% 12.00% 3.30% 3.30% 14.90% 14.90% 2.37 2.37 0.56 7.92 9.22 4.20 4.20 12.00% 12.00% 3.30% 3.30% 14.90% 14.90% 2.37 2.37 0.61 1.92 7.76 4.20 12.00% 3.30% 14.90% 2.37 0.45 8.06 16.32 20.39 4.20 4.20 4.20 12.00% 12.00% 12.00% 3.30% 3.30% 3.30% 14.90% 14.90% 14.90% 2.37 2.37 2.37 0.75 9.01 13.08 6.09 8.72 9.80 4.20 4.20 4.20 12.00% 12.00% 12.00% 3.30% 3.30% 3.30% 14.90% 14.90% 14.90% 2.37 2.37 2.37 1.41 2.50 8.33 10.65 10.85 6.35 4.20 4.20 4.20 4.20 12.00% 12.00% 12.00% 12.00% 3.30% 3.30% 3.30% 3.30% 14.90% 14.90% 14.90% 14.90% 2.37 2.37 2.37 2.37 1.02 3.34 3.54 - January 20 291 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 222: Summary of CSS for the Control Period for HT Consumers Consumer Category FY 2020-21 Rs/Unit FY 2021-22 Rs/Unit FY 2022-23 Rs/Unit FY 2023-24 Rs/Unit FY 2024-25 Rs/Unit 2.57 2.83 3.09 3.35 3.19 3.45 3.31 3.57 3.46 3.71 5.49 8.36 6.06 9.02 6.20 9.25 6.35 9.50 6.57 9.81 8.57 10.90 9.05 11.49 9.10 11.66 9.17 11.85 9.30 12.11 4.03 3.98 4.77 4.64 5.09 4.87 5.44 5.12 5.87 5.42 1.61 1.38 2.21 1.92 2.38 2.03 2.56 2.15 2.81 2.32 0.41 - 0.52 - 0.62 - 0.78 - 2.09 0.43 2.84 0.96 3.19 1.06 3.57 1.16 4.03 1.32 10.69 - 11.95 - 12.83 - 13.80 - 14.92 - 4.04 - 4.69 - 4.92 - 5.18 - 5.54 - 6.27 5.24 6.86 5.75 7.04 5.84 7.23 5.93 7.49 6.09 1.99 - 2.71 - 3.03 - 3.36 - 3.78 - HT I HT - Industry HT EHV HT I (B): HT - Industry (Seasonal) HT EHV HT II: HT – Commercial HT EHV HT III : HT - Railways/Metro/Monorail Traction HT EHV HT IV: HT - Public Water Works HT EHV HT V(B): HT - Agriculture - Others HT EHV HT VI: HT - Group Housing Societies (Residential) HT EHV HT VIII(B): HT - Temporary Supply Others (TSO) HT EHV HT IX: HT - Public Services HT IX(A): HT - Public Services-Govt. Edu. Institutions and Hospitals HT EHV HT IX(B): HT - Public Services-Others HT EHV HT X: HT – Electric Vehicle Charging Station HT EHV MSEDCL January 20 - 292 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 223: Summary of CSS for the Control Period for LT Consumers (1/2) Consumer Category LT Residential LT I(A): LT - Residential-BPL LT I(B): LT - Residential 1-100 units 101-300 units 301-500 units Above 500 units LT II: LT - Non-Residential (A) ≤ 20 kVA (B): >20 kVA and ≤ 50 kVA (C): >50 kVA LT III: LT - Public Water Works (PWW) (A): ≤ 20 kVA (B): > 20 kVA and ≤ 40 kVA (C): > 40 kVA LT IV(C): LT - Agriculture Metered – Others MSEDCL FY 2020-21 Rs/Unit - FY 2021-22 Rs/Unit - FY 2022-23 Rs/Unit - FY 2023-24 Rs/Unit - FY 2024-25 Rs/Unit - 2.37 5.01 5.85 2.99 5.45 6.25 3.18 5.45 6.23 3.39 5.49 6.33 3.66 5.58 6.51 3.24 6.08 8.04 3.78 6.76 8.54 3.88 7.00 8.61 3.98 7.24 8.58 4.14 7.55 8.61 0.65 1.23 1.48 1.77 0.14 2.11 January 20 293 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 224: Summary of CSS for the Control Period for LT Consumers (2/2) Consumer Category LT V (A): LT - Industry - Powerlooms (i): 0-20 kVA (ii): Above 20 kVA LT V(B): LT - Industry - General (i): 0-20 kVA (ii): Above 20 kVA LT VI: LT - Street Light (A): Grampanchayat; A B & C Class Municipal Council (B): Municipal corporation Area LT VII: LT - Temporary Connection (A): LT - Temporary Supply Religious (TSR) (B): LT - Temporary Supply Others (TSO) LT VIII: LT - Advertisements and Hoardings LT IX: LT - Crematorium and Burial Grounds LT X (A) - Public Services – Govt. (i): ≤ 20 kVA (ii): >20 - ≤ 50 kVA iii): >50 kVA LT X(B) - Public Services - Others (i): ≤ 20 kVA (ii): >20 - ≤ 50 kVA (iii): >50 kVA LT XI – Electric Vehicle Charging Station MSEDCL FY 2020-21 Rs/Unit FY 2021-22 Rs/Unit FY 2022-23 Rs/Unit FY 2023-24 Rs/Unit FY 2024-25 Rs/Unit 0.56 1.02 1.14 0.12 1.28 0.39 1.48 0.61 1.92 1.27 2.66 1.50 2.97 1.72 3.30 2.02 3.69 0.45 1.01 1.14 1.29 1.49 0.75 9.01 13.08 - 1.73 10.04 14.31 - 2.35 10.68 15.13 - 3.08 11.39 16.00 - 3.98 12.22 16.96 - 1.41 2.50 2.00 3.06 2.15 3.20 2.31 3.34 2.63 3.54 1.02 3.34 3.54 - 1.66 4.11 4.23 - 1.88 4.46 4.48 - 2.10 4.81 4.74 - 2.39 5.22 5.06 - January 20 294 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 13.4.6 As stipulated in the Open Access Regulations, the cross-subsidy surcharge shall be based on the current level of cross subsidy of the tariff category / tariff slab and/ or voltage level to which such consumer or person belong or are connected to. Accordingly, the consumers who opt for Open Access during the Control Period need to be charged to compensate the level of cross subsidy which will prevail during the control period and to avoid the burden of the same on other consumers. Therefore, MSEDCL requests the Hon’ble Commission to approve the CSS for the Control Period as computed above. MSEDCL January 20 295 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 14 ADDITIONAL SURCHARGE 14.1 Background 14.1.1 Section 42 (4) of the Electricity Act 2003, provides that Where the State Commission permits a consumer or class of consumers to receive supply of electricity from a person other than the distribution licensee of his area of supply, such consumer shall be liable to pay an additional surcharge on the charges of wheeling, as may be specified by the State Commission, to meet the fixed cost of such distribution licensee arising out of his obligation to supply 14.1.2 Regulation 14.8 of the Commission’s Distribution OA Regulations, 2016 outlines the principles for determination and levy of Additional Surcharge as below: “14.8 Additional Surcharge a) An Open Access consumer receiving supply of electricity from a person other than the distribution licensee of his area of supply shall pay to the Distribution Licensee an Additional Surcharge on the charges of wheeling and Cross Subsidy Surcharge to meet the fixed cost of such distribution licensee arising out of its obligation to supply, as provided in sub-section (4) of Section 42 of the Act. b) This additional surcharge shall become applicable only when due to the Open Access being granted or having been granted, the obligation of the Distribution Licensee in terms of power purchase commitments has been and continues to be stranded, or there is an unavoidable obligation and incidence to bear fixed costs consequent to such a commitment. c) The Distribution Licensee shall submit to the Commission with its petition under the Commission’s Regulations governing a Multi-year tariff, detailed computations of fixed cost which it is incurring towards his obligation to supply, and actual expenses incurred vis-à-vis those approved by the Commission. d) The Commission shall determine category wise additional surcharge to be recovered by Distribution Licensee from Open Access consumers, based on the following principles: i) The cost must have been incurred by or be expected, with reasonable certainty, to be incurred by Distribution Licensee on account of such consumer; and MSEDCL January 20 296 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition ii) The cost has not been or cannot be recovered from such consumer, or from other consumers who have been given supply from the same assets or facilities, through wheeling charges, standby charges or other charges approved by the Commission Provided that such additional surcharge shall be applicable to all the consumers who have availed Open Access to receive supply from a source other than the Distribution Licensee to which they are connected. e) ……………….. f) ………………..” 14.2 Backing down due to surplus power scenario 14.2.1 It is submitted that the Section 43 of the Electricity Act 2003 casts Universal Service Obligation (USO) on MSEDCL. Accordingly, in order to cater the consumer demand, MSEDCL purchases power on long term basis from Mahagenco, NTPC under MOU route and from IPPs through competitive bidding process. The tariff for generation as per PPA/MoU comprises of two parts viz. Fixed Charge which is dependent on declared availability of generator and variable charge which is dependent on actual energy supplied. 14.2.2 MSEDCL submits that capacity addition was done by signing the PPAs with generating companies after due approval of Hon’ble Commission and based on estimated demand as per the projections published in 16th Electric Power Survey (EPS) published by CEA. However, there is a variation in projected and actual demand due to various reasons such as increase in Open Access, RE capacity addition to fulfil RPO Target, RE capacity addition by CPP because of low tariff and Net Metering etc. This is resulting into surplus power availability. 14.2.3 Further, MSEDCL submits that to fulfill the RPO targets set by Hon’ble Commission, MSEDCL has to plan prospective power purchase from renewable energy sources. Also, as per the RPO Regulations 2019 notified on 27th December 2019, MSEDCL is required to procure at least 25% of power from Renewable Sources by FY 2024-25 which includes 13.5% of Solar and 11.5% of Non-Solar power. Keeping up pace with the RPO requirement, MSEDCL has tied up total 10,795 MW capacity of Renewable Energy as on MSEDCL January 20 297 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 31st October 2019 of which 7,654 MW capacity is commissioned. This includes Wind Generation of 3,999 MW, Solar of 4017 MW, Bagasse based cogeneration of 2,406 MW, Biomass capacity of 236 MW, Small Hydro of 121 MW & Municipal solid waste of 16 MW capacity. Further, by the end of FY 202425 to meet the RPO target, MSEDCL has planned to increase the solar capacity to 12,500 MW. Due to such addition of renewable power, the surplus power is expected to be continued further since the renewable energy is treated as “Must Run”. 14.2.4 MSEDCL also submits that due to the recent trends in the prices of solar energy and MERC Net Metering Regulations 2019, various consumers are now converting to captive power plants (CPP) by installing solar projects through Developers. Due to this, the surplus power is also likely to increase further. 14.2.5 To manage the surplus power, MSEDCL gives zero schedule/ backdown the high variable cost thermal generation as per Merit Order Despatch or sell in energy market depending upon market rates thereby reducing the burden of energy charges. However whenever such surplus capacity remains available, MSEDCL has to pay fixed/capacity charges irrespective of the scheduling or non-scheduling of power from the units which declares its availability. 14.2.6 Further, whenever there is unavailability of generation due to the forced outage/coal shortage, there is requirement of additional power during certain blocks of the day, sometimes the duration of shortfall during the day is so small that to cater the demand for such small period, it is unviable to take a generation unit on bar to cater the demand for small period. In such cases, MSEDCL forecast the demand, availability and shortfall on day-ahead basis and procures power from Short Tern Markets such as Energy Exchanges. 14.2.7 Furthermore considering the historical trend of demand, coal shortage scenario, trend of rates in Exchanges, etc. MSEDCL in advance plans and procures the power on short term through bilateral transactions on DEEP Portal. 14.2.8 In addition to this, MSEDCL also explores the option of optimization of power MSEDCL January 20 298 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition purchase cost by backing down of costly generation unit as per MoD and procuring the cheaper power available in Short Term Market/Exchange. 14.2.9 It is further submitted that MSEDCL has to pay Fixed Charges to the Generators as per the terms and conditions of the PPAs irrespective of utilization of generation capacity and thus the surplus capacity adds the fixed cost burden on MSEDCL. 14.2.10 The year wise details of net surplus capacity, back-down quantum, capacity under outages due to the coal shortage and power purchase through short term tender and IEX is given in following tables. Units under RSD,ESD & BD ( MUs) Capacity under coal shortage (MUs) Total Surplus (MUs) Total Short Term Purchase (MUs) A B C=A+B D Total MUs 18349 11443 29792 4029 Avg. MW on RTC basis 2095 1306 3401 460 FY 18-19 Units under RSD,ESD & BD ( MUs) Capacity under coal shortage (MUs) Total Surplus (MUs) Total Short Term Purchase (MUs) A B C=A+B D Total MUs 20883 15599 36482 5821 Avg. MW on RTC basis 2384 1781 4165 665 Units under RSD,ESD & BD ( MUs) Capacity under coal shortage (MUs) Total Surplus (MUs) Total Short Term Purchase (MUs) A B C=A+B D Total Mus 22796 932 23727 763 Avg. MW on RTC basis 3893 159 4052 130 FY 17-18 FY 19-20 (Nov-19) MSEDCL January 20 299 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 14.2.11 From above, it is clear that MSEDCL is in power surplus and will continue to be in surplus for Control Period. However, short term power is purchased for cost optimization or to meet demand during coal shortage scenario and hence, additional surcharge is justifiable & needs to be made applicable to all OA consumers. 14.3 Surcharge Computation 14.3.1 MSEDCL has implemented Intra State ABT in the state of Maharashtra since 1st August 2011 and SLDC / DISCOM are granting approvals / consent to open access consumers for purchase and sale of power through open access as per Open Access Regulations. Accordingly, open access consumers are now buying considerable quantum of power under open access and on the other hand MSEDCL has tied up sufficient quantum of power after approval of the Commission, so as to meet the expected demand by considering the overall growth in the State. 14.3.2 As a result, the generation capacity tied up by MSEDCL becomes excess. In this situation, MSEDCL needs to back down the generation and also has to pay Fixed Charges (or Capacity Charges) to the Generators as per the terms and conditions of the PPAs irrespective of utilization of generation capacity. The burden of fixed cost is affecting the viability and sustainability of operations of MSEDCL, which ultimately adversely affects the tariff of MSEDCL’s common consumers. Hence, to mitigate this, it was appropriate to determine the Additional Surcharge for OA consumers, as per Section 42 (4) of the EA, 2003. Hon’ble Commission in its Order dated 3rd November 2016 (Case No. 48/2016) had observed that there was a case for recovery of the part of fixed cost towards the stranded capacity arising from the power purchase obligation through levy of Additional Surcharge from OA consumers. Accordingly, Hon’ble Commission has determined the additional surcharge in the said MYT Order dated 3rd November 2016 and subsequently in MTR Order dated 12th September 2018. 14.3.3 In line with the methodology adopted by Hon’ble Commission in the MYT Order dated 3rd November 2016 and MTR Order dated 12th September 2018, MSEDCL computed the Additional Surcharge for the Control Period i.e. FY MSEDCL January 20 300 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 2020-21 to FY 2024-25 as per DOA Regulations, 2016 based on the data for the FY 2018-19 Table 225: Proposed Additional Surcharge for FY 2020-21 Particulars Reference Step-1: Establishing contribution of OA to backing-down/stranded capacity OA volume for FY 2019-20 (Upto Sept-19) (a) Backing Down quantum for FY 2019-20 (Upto Sept-19) (b) Ratio to OA to Backed down for FY 2019-20 (Upto Sept-19) (c )=(b)/(a) Unit Value MU MU % 2,178 14,704 15% Step-2: Ascertaining Cost of Stranded Capacity Fixed Cost of Thermal Generating Sources for FY 2020-21 Total Available MU from Thermal Generating Stations for FY 2020-21 Wt. Avg. Per Unit FC of Thermal Generating Stations for FY 2020-21 Total Projected Backdown/RSD Volume for FY 2020-21 Projected Open Access Volume for year for FY 2020-21 Fixed Cost pertaining to Backdown/RSD capacity for FY 2020-21 (d) (e ) (f)=(d)/(e ) x10 (g) (h) (i)=(f)*(h)/10 Rs. Crs MUs Rs/kWh MUs MUs Rs. Crs 19,207 1,43,926 1.33 32,653 4,843 646 Step-3: Determination of Additional Surcharge Per Unit Additional Surcharge (to be applicable on OA Consumers ) j=(i)/(h)*10 Rs/Unit 1.33 Table 226: Proposed Additional Surcharge for FY 2021-22 Particulars Reference Step-1: Establishing contribution of OA to backing-down/stranded capacity OA volume for FY 2019-20 (Upto Sept-19) (a) Backing Down quantum for FY 2019-20 (Upto Sept-19) (b) Ratio to OA to Backed down for FY 2019-20 (Upto Sept-19) (c )=(b)/(a) Unit Value MU MU % 2,178 14,704 15% Step-2: Ascertaining Cost of Stranded Capacity Fixed Cost of Thermal Generating Sources for FY 2021-22 Total Available MU from Thermal Generating Stations for FY 2021-22 Wt. Avg. Per Unit FC of Thermal Generating Stations for FY 2021-22 Total Projected Backdown/RSD Volume for FY 2021-22 Projected Open Access Volume for year for FY 2021-22 Fixed Cost pertaining to Backdown/RSD capacity for FY 2021-22 (d) (e ) (f)=(d)/(e ) x10 (g) (h) (i)=(f)*(h)/10 Rs. Crs MUs Rs/kWh MUs MUs Rs. Crs 19,698 1,44,100 1.37 31,957 4,843 662 Step-3: Determination of Additional Surcharge Per Unit Additional Surcharge (to be applicable on OA Consumers ) j=(i)/(h)*10 Rs/Unit 1.37 MSEDCL January 20 301 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 227: Proposed Additional Surcharge for FY 2022-23 Particulars Reference Step-1: Establishing contribution of OA to backing-down/stranded capacity OA volume for FY 2019-20 (Upto Sept-19) (a) Backing Down quantum for FY 2019-20 (Upto Sept-19) (b) Ratio to OA to Backed down for FY 2019-20 (Upto Sept-19) (c )=(b)/(a) Unit Value MU MU % 2,178 14,704 15% Step-2: Ascertaining Cost of Stranded Capacity Fixed Cost of Thermal Generating Sources for FY 2022-23 Total Available MU from Thermal Generating Stations for FY 2022-23 Wt. Avg. Per Unit FC of Thermal Generating Stations for FY 2022-23 Total Projected Backdown/RSD Volume for FY 2022-23 Projected Open Access Volume for year for FY 2022-23 Fixed Cost pertaining to Backdown/RSD capacity for FY 2022-23 (d) (e ) (f)=(d)/(e ) x10 (g) (h) (i)=(f)*(h)/10 Rs. Crs MUs Rs/kWh MUs MUs Rs. Crs 20,038 1,42,875 1.40 31,725 4,843 679 Step-3: Determination of Additional Surcharge Per Unit Additional Surcharge (to be applicable on OA Consumers ) j=(i)/(h)*10 Rs/Unit 1.40 Table 228: Proposed Additional Surcharge for FY 2023-24 Particulars Reference Step-1: Establishing contribution of OA to backing-down/stranded capacity OA volume for FY 2019-20 (Upto Sept-19) (a) Backing Down quantum for FY 2019-20 (Upto Sept-19) (b) Ratio to OA to Backed down for FY 2019-20 (Upto Sept-19) (c )=(b)/(a) Unit Value MU MU % 2,178 14,704 15% Step-2: Ascertaining Cost of Stranded Capacity Fixed Cost of Thermal Generating Sources for FY 2023-24 Total Available MU from Thermal Generating Stations for FY 2023-24 Wt. Avg. Per Unit FC of Thermal Generating Stations for FY 2023-24 Total Projected Backdown/RSD Volume for FY 2023-24 Projected Open Access Volume for year for FY 2023-24 Fixed Cost pertaining to Backdown/RSD capacity for FY 2023-24 (d) (e ) (f)=(d)/(e ) x10 (g) (h) (i)=(f)*(h)/10 Rs. Crs MUs Rs/kWh MUs MUs Rs. Crs 20,487 1,43,181 1.43 30,469 4,843 693 Step-3: Determination of Additional Surcharge Per Unit Additional Surcharge (to be applicable on OA Consumers ) j=(i)/(h)*10 Rs/Unit 1.43 MSEDCL January 20 302 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Table 229: Proposed Additional Surcharge for FY 2024-25 Particulars Reference Step-1: Establishing contribution of OA to backing-down/stranded capacity OA volume for FY 2019-20 (Upto Sept-19) (a) Backing Down quantum for FY 2019-20 (Upto Sept-19) (b) Ratio to OA to Backed down for FY 2019-20 (Upto Sept-19) (c )=(b)/(a) Unit Value MU MU % Step-2: Ascertaining Cost of Stranded Capacity Fixed Cost of Thermal Generating Sources for FY 2024-25 Total Available MU from Thermal Generating Stations for FY 2024-25 Wt. Avg. Per Unit FC of Thermal Generating Stations for FY 2024-25 Total Projected Backdown/RSD Volume for FY 2024-25 Projected Open Access Volume for year for FY 2024-25 Fixed Cost pertaining to Backdown/RSD capacity for FY 2024-25 (d) (e ) (f)=(d)/(e ) x10 (g) (h) (i)=(f)*(h)/10 Rs. Crs MUs Rs/kWh MUs MUs Rs. Crs Step-3: Determination of Additional Surcharge Per Unit Additional Surcharge (to be applicable on OA Consumers ) j=(i)/(h)*10 Rs/Unit 2,178 14,704 15% 20,276 1,42,854 1.42 27,218 4,843 687 1.42 Summary of the Additional Surcharge: Particulars Proposed Additional Surcharge (Rs/kVAh) FY 2020-21 1.33 FY 2021-22 1.37 FY 2022-23 FY 2023-24 FY 2024-25 1.40 1.43 1.42 14.3.4 In view of the submissions in the above paragraphs MSEDCL requests the Hon’ble Commission to approve the Additional Surcharge for Open Access Consumers irrespective of Source i.e. Captive Power Plants, IPP, RE based power plants etc. in addition to the conventional open access consumers as computed in the above tables. 14.3.5 MSEDCL further submits that CPPs existing prior to FY15-16, originally set up the plant for self-consumption and still continuing the same arrangement of captive use, shall be exempted from applicability of additional surcharge. This is due to the fact that these were set up during the power shortage situation and were captive in real sense as per the spirit of the Act. MSEDCL January 20 303 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 15 PROPOSED TARIFF APPLICABILITY 15.1 Background 15.1.1 Every consumer of electricity has a unique applicability of tariff, depending upon the nature of power supply, purpose of power supply etc. which determines the class of consumer or category of the consumer. 15.1.2 The Hon’ble Commission has accordingly classified the consumers of electricity into various categories depending upon the nature of power supply i.e. (Low Tension or High Tension), purpose of power supply i.e. (Domestic, Nondomestic, Industrial, Agricultural, etc.) 15.1.3 In the recent past, it is observed that classification of a consumer into a particular category has resulted in litigation since applicability of a particular category of tariff is not available in exhaustive nature. 15.1.4 A comparison of the existing applicability as per the MTR Order dated 12 th September 2018 and proposed applicability of tariff for different categories of consumer is given in the following table. 15.1.5 It is submitted that it is very difficult to cover all the existing activities. However, this exercise of MSEDCL has attempted to cover majority of activities. The applicability given in this Petition is indicative and may not cover some of the activities. Such cases will be dealt by the respective field officer/ concerned authority of MSEDCL for the purpose of categorization based on nature of usages. MSEDCL January 20 304 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 15.2 LT Category Sr. No. 1. Existing Applicability Proposed Applicability LT I A: LT – Residential (BPL) LT I A: LT – Residential (BPL) Applicability: This Below Poverty Line (BPL) tariff category is applicable to Residential consumers who have a Sanctioned Load upto 0.25 kW and who have consumed upto 360 units per annum in the previous financial year. The eligibility of such consumers will be reassessed at the end of each financial year. If more than 360 units have been consumed in the previous financial year, the LTI (B) - Residential tariff shall thereafter be applicable, and such consumer cannot revert thereafter to the BPL category irrespective of his future consumption level. Applicability: This Below Poverty Line (BPL) tariff category is applicable to Residential consumers who have a Sanctioned Load upto 0.25 kW and who have consumed upto 360 units per annum in the previous financial year. The eligibility of such consumers will be reassessed at the end of each financial year. If more than 360 units have been consumed in the previous financial year, the LTI (B) - Residential tariff shall thereafter be applicable, and such consumer cannot revert thereafter to the BPL category irrespective of his future consumption level. The categorization of BPL consumers will be reassessed at the end of the financial year on a pro rata basis if there has been consumption for only a part of the year The categorization of BPL consumers who have been added The categorization of BPL consumers will be reassessed at the end of the financial year on a pro rata basis if there has been consumption for only a part of the year The categorization of BPL consumers who have been added MSEDCL January 20 305 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Sr. No. Existing Applicability Proposed Applicability during the previous year would be assessed on a pro rata during the previous year would be assessed on a pro rata basis, i.e., 30 units per month. basis, i.e., 30 units per month. This BPL category will also be applicable to all new consumers subsequently added in any month with a Sanctioned Load of upto 0.25 kW and consumption between 1 to 30 units (on pro rata basis of 1 unit/day) in the first billing month. This BPL category will also be applicable to all new consumers subsequently added in any month with a Sanctioned Load of upto 0.25 kW and consumption between 1 to 30 units (on pro rata basis of 1 unit/day) in the first billing month. The BPL tariff is applicable only to individuals and not to The BPL tariff is applicable only to individuals and not to institutions. institutions. 2. LT I B: LT – Residential LT I B: LT – Residential Applicability: This tariff category is applicable for electricity used at Low/Medium Voltage for operating various appliances used for purposes such as lighting, heating, cooling, cooking, washing/cleaning, entertainment/leisure, water pumping in the following premises: a) Private residential premises, Government/semiGovernment residential quarters; Applicability: This tariff category is applicable for electricity used at Low/Medium Voltage for operating various appliances used for purposes such as lighting, heating, cooling, cooking, washing/cleaning, entertainment/leisure, water pumping in the following premises: a) Private residential premises, Government/semiGovernment residential quarters; MSEDCL January 20 306 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Sr. No. Existing Applicability b) c) d) e) f) Proposed Applicability Premises used exclusively for worship, such as temples, gurudwaras, churches, mosques, etc.; provided that halls, gardens or any other part of such premises that may be let out for a consideration or used for commercial activities would be charged at the applicable LT-II tariff; All Students Hostels affiliated to Educational Institutions; All other Students’ or Working Men/Women’s Hostels; Other types of Homes/Hostels, such as (i) Homes/Hostels for Destitutes, Disabled Persons (physically or mentally handicapped persons, etc.) and mentally ill persons (ii) Remand Homes (iii) Dharamshalas, (iv) Rescue Homes, (v) Orphanages subject to verification and confirmation by the Distribution Licensee; Government / Private / Co-operative Housing Colonies/complexes (where electricity is used exclusively for domestic purposes) only for common facilities such as Water Pumping / Street and other MSEDCL b) Premises used exclusively for worship, such as temples, gurudwaras, churches, mosques, etc.; provided that halls, gardens or any other part of such premises that may be let out for a consideration or used for commercial activities would be charged at the applicable LT-II tariff; c) All Students Hostels affiliated to Educational Institutions; d) All other Students’ or Working Men/Women’s Hostels; e) Other types of Homes/Hostels, such as (i) Homes/Hostels for Destitute, Disabled Persons (physically or mentally handicapped persons, etc.) and mentally ill persons (ii) Remand Homes (iii) Dharamshalas, (iv) Rescue Homes, (v) Orphanages, (vi) Day care Centre for senior citizen- subject to verification and confirmation by the Distribution Licensee; f) Government / Private / Co-operative Housing Colonies/complexes (where electricity is used exclusively for domestic purposes) only for common facilities such as Water Pumping / Street and other common area Lighting / Lifts /Parking Lots/ Fire-fighting Pumps and other equipment, etc.; January 20 307 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Sr. No. Existing Applicability g) h) i) j) k) Proposed Applicability common area Lighting / Lifts /Parking Lots/ Fire-fighting Pumps and other equipment, etc.; Sports Clubs or facilities / Health Clubs or facilities / Gymnasium / Swimming Pool / Community Hall of Government / Private / Co-operative Housing Colonies/complexes - provided that they are situated in the same premises, and are for the exclusive use of the members and employees of such Housing Colonies/complexes; Telephone booths owned/operated by Persons with Disabilities/Handicapped persons; Residential premises used by professionals like Lawyers, Doctors, Engineers, Chartered Accountants, etc., in furtherance of their professional activities, but not including Nursing Homes and Surgical Wards or Hospitals; Single-phase household Flour Mills (Ghar-ghanti) used only for captive purposes; A residential LT consumer with consumption upto 500 units per month (current month of supply) who undertakes construction or renovation activity in his MSEDCL g) Sports Clubs or facilities / Health Clubs or facilities / Gymnasium / Swimming Pool / Community Hall of Government / Private / Co-operative Housing Colonies/complexes - provided that they are situated in the same premises, and are for the exclusive use of the members and employees of such Housing Colonies/complexes; h) Telephone booths owned/operated by Persons with Disabilities/Handicapped persons; i) Residential premises used by professionals like Lawyers, Doctors, Engineers, Chartered Accountants, etc., in furtherance of their professional activities, but not including Nursing Homes and Surgical Wards or Hospitals; j) Single-phase household Flour Mills (Ghar-ghanti) used only for captive purposesself-use; k) A residential LT consumer with consumption upto 500 units per month (current month of supply) who undertakes construction or renovation activity in his existing premises: such consumer shall not require a January 20 308 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Sr. No. Existing Applicability l) Proposed Applicability existing premises: such consumer shall not require a separate temporary connection, and would be billed at separate temporary connection, and would be billed at this Residential tariff rate; this Residential tariff rate; Note: Note: This tariff category shall also be applicable to consumers This tariff category shall also be applicable to who are supplied power at High Voltage for any of the consumers who are supplied power at High Voltage for purposes (a) to (k) above. any of the purposes (a) to (k) above. l) Consumers undertaking business or commercial / industrial / non-residential activities from a part of their Consumers undertaking business or commercial / residence, whose monthly consumption is upto 300 units industrial / non-residential activities from a part of their a month and annual consumption in the previous residence, whose monthly consumption is upto 300 financial year was upto 3600 units. The applicability of units a month and annual consumption in the previous this tariff to such consumers will be assessed at the end financial year was upto 3600 units. The applicability of of each financial year. In case consumption has this tariff to such consumers will be assessed at the end exceeded 3600 units in the previous financial year, the of each financial year. In case consumption has consumer will thereafter not be eligible for the tariff under exceeded 3600 units in the previous financial year, the this category but be charged at the tariff otherwise consumer will thereafter not be eligible for the tariff applicable for such consumption, with prior intimation to under this category but be charged at the tariff him. otherwise applicable for such consumption, with prior m) Entities supplied electricity at a single point at intimation to him. Low/Medium Voltage for residential purposes, in MSEDCL January 20 309 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Sr. No. Existing Applicability Proposed Applicability m) Entities supplied electricity at a single point at accordance with the Electricity (Removal of Difficulties) Low/Medium Voltage for residential purposes, in Eighth Order, 2005, in the following cases: accordance with the Electricity (Removal of Difficulties) (i) a Co-operative Group Housing Society which owns Eighth Order, 2005, in the following cases: the premises, for making electricity available to the (i) a Co-operative Group Housing Society which owns members of such Society residing in the same the premises, for making electricity available to the premises for residential purposes; and members of such Society residing in the same premises for residential purposes; and (ii) a person, for making electricity available to its (ii) a person, for making electricity available to its employees residing in the same premises for employees residing in the same premises for residential purposes. residential purposes. Note: Note: a) For three phase supply, an additional fixed charge of a) For three phase supply, an additional fixed charge of Rs.185 per 10kW load or part thereof above 10 kW load Rs.185 per 10kW load or part thereof above 10 kW load shall also be payable. shall also be payable. b) Professionals like Lawyers, Doctors, Professional b) Professionals like Lawyers, Doctors, Professional Engineers, Chartered Accountants, etc., occupying Engineers, Chartered Accountants, etc., occupying residential premises exclusively for conducting their premises exclusively for conducting their profession, profession, shall not be eligible for this tariff, and will be MSEDCL January 20 310 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Sr. No. Existing Applicability Proposed Applicability shall not be eligible for this tariff, and will be charged at the tariff applicable to the respective categories. 3. charged at the tariff applicable to the respective categories. LT II: LT– Non-Residential LT II: LT– Non-Residential Applicability: (A) 0-20 kW This tariff category is applicable for electricity used at Low/Medium voltage in non-residential, non-industrial and/or commercial premises for commercial consumption meant for operating various appliances used for purposes such as lighting, heating, cooling, cooking, washing/cleaning, entertainment/ leisure and water pumping in, but not limited to, the following premises: a) Non-Residential, Commercial and Business premises, including Shopping Malls and Showrooms; b) Combined lighting and power supply for facilities relating to Entertainment, including film studios, cinemas and theatres (including multiplexes), Hospitality, Leisure, Meeting/Town Halls, and places of Recreation and Public Entertainment; Applicability: (A) 0-20 kVA This tariff category is applicable for electricity used at Low/Medium voltage in non-residential, non-industrial and/or commercial premises for commercial consumption meant for operating various appliances used for purposes such as lighting, heating, cooling, cooking, washing/cleaning, entertainment/ leisure and water pumping in, but not limited to, the following premises: a) Non-Residential, Commercial and Business premises, including Shopping Malls and Showrooms; b) Combined lighting and power supply for facilities relating to Entertainment, including film studios, cinemas and theatres (including multiplexes), Hospitality, Leisure, Meeting/Town Halls, and places of Recreation and Public Entertainment; MSEDCL January 20 311 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Sr. No. Existing Applicability Proposed Applicability c) Offices, including Commercial Establishments; d) Marriage Halls, Hotels / Restaurants, Ice-cream parlours, Coffee Shops, Guest Houses, Internet / Cyber Cafes, Telephone Booths not covered under the LT I category, and Fax / Photocopy shops; e) Automobile and all other types of repairs, servicing and maintenance centres (unless specifically covered under another tariff category); Retail Gas Filling Stations, Petrol Pumps and Service Stations, including Garages; f) Tailoring Shops, Computer Training Institutes, Typing Institutes, Photo Laboratories, Beauty Parlours and Saloons; g) Banks and ATM centres, Telephone Exchanges, TV Stations, Microwave Stations, Radio Stations, Telecommunications Towers; h) Common facilities, like Water Pumping / Lifts / FireFighting Pumps and other equipment / Street and other common area Lighting, etc., in Commercial Complexes; i) Sports Clubs/facilities, Health Clubs/facilities, Gymnasiums, Swimming Pools not covered under any other category; c) Offices, including Commercial Establishments; d) Marriage Halls, Resorts, Hotels / Restaurants, Ice-cream parlours, Commercial Water ATM (RO/UV/UF Water Purifier Plants), Coffee Shops, Guest Houses, Internet / Cyber Cafes, Telephone Booths not covered under the LT I category, and Fax / Photocopy shops; e) Automobile and all other types of repairs, servicing and maintenance centres (unless specifically covered under another tariff category); Retail Gas Filling Stations, Petrol Pumps and Service Stations, including Garages; f) Tailoring Shops, Computer Training Institutes, Typing Institutes, Photo Laboratories, Beauty Parlours and Saloons; g) Banks and ATM centres, Telephone Exchanges, TV Stations, Microwave Stations, Radio Stations, Telecommunications Towers; h) Common facilities, like Water Pumping / Lifts / FireFighting Pumps and other equipment / Street and other common area Lighting, etc., in Commercial Complexes; MSEDCL January 20 312 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Sr. No. Existing Applicability Proposed Applicability j) External illumination of monuments/ historical/ heritage buildings approved by Maharashtra Tourism Development Corporation (MTDC) or the concerned Local Authority; k) Construction of all types of structures/ infrastructure such as buildings, bridges, fly-overs, dams, Power Stations, roads, Aerodromes, tunnels for laying of pipelines for all purposes, and which is not covered under the Temporary tariff category; Note: Residential LT consumers with consumption above 500 units per month (current month of supply) and who undertake construction or renovation activity in their existing premises shall not require a separate Temporary category connection, and shall be billed at the LT-II Commercial Tariff rate; i) Sports Clubs/facilities, Health Clubs/facilities, Gymnasiums, Swimming Pools not covered under any other category; j) External illumination of monuments/ historical/ heritage buildingsapproved by Maharashtra Tourism Development Corporation (MTDC) or the concerned Local Authority; k) Godowns and warehouses; l) Construction of all types of structures/ infrastructure such as buildings, bridges, fly-overs, dams, Power Stations, roads, Aerodromes, tunnels for laying of pipelines for all purposes, and which is not covered under the Temporary tariff category; Note: l) Milk Collection Centres; m) Sewage Treatment Plants/ Common Effluent Treatment Plants for Commercial Complexes not covered under the LT – Public Water Works or LT – Industry categories; MSEDCL January 20 (i) Residential LT consumers with consumption above 500 units per month (current month of supply) and who undertake construction or renovation activity in their existing premises shall not require a separate Temporary category connection, and shall be billed at the LT-II Commercial Tariff rate; 313 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Sr. No. Existing Applicability Proposed Applicability n) Stand-alone Research and Development units not covered under any other category; (ii) For Construction, initially supply will be provided under LT VII (B) Temporary Supply Others (TSO), after 2 years the supply will be regularized under LT (B) > 20 kW and ≤ 50 kW and (C) > 50 kW II Non- Residential. m) Milk Collection Centres; Applicability: n) Sewage Treatment Plants/ Common Effluent Treatment As per the applicability described in LT II (A) and for the Plants for Commercial Complexes not covered under the Sanctioned Load in the range applicable in this subLT – Public Water Works or LT – Industry categories; category, i.e. LT II (B) and LT II (C). o) Stand-alone Research and Development units not covered under any other category; Note: The ToD tariff is applicable to the LT-II (B) and (C) categories, and optionally available to LT- II (A) category (B) > 20 kVA and ≤ 50 kVA and (C) > 50 kVA consumers having ToD meter installed. Applicability: As per the applicability described in LT II (A) and for the Sanctioned Load in the range applicable in this subcategory, i.e. LT II (B) and LT II (C). MSEDCL January 20 314 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Sr. No. Existing Applicability Proposed Applicability Note: The ToD tariff is applicable to the LT-II (B) and (C) categories, and optionally available to LT- II (A) category consumers having ToD meter installed. 4. LT III: LT - Public Water Works and Sewage Treatment LT III: LT - Public Water Works and Sewage Treatment Plants Plants Applicability: This tariff category is applicable for electricity / power supply at Low / Medium Voltage for pumping of water, purification of water and allied activities relating to Public Water Supply Schemes and Sewage Treatment Plants, provided they are owned or operated or managed by Local Self-Government Bodies (Gram Panchayats, Panchayat Samitis, Zilla Parishads, Municipal Councils and Corporations, etc.), or by Maharashtra Jeevan Pradhikaran (MJP), Maharashtra Industries Development Corporation (MIDC), Cantonment Boards and Housing Societies/complexes. MSEDCL Applicability: This tariff category is applicable for (i) Electricity / power supply at Low/Medium Voltage for pumping of water, purification of water and allied activities relating to Public Water Supply Schemes and Sewage Treatment Plants, provided they are owned or operated or managed by Local Self-Government Bodies (Gram Panchayats, Panchayat Samitis, Zilla Parishads, Municipal Councils and Corporations, etc.), or by Maharashtra Jeevan Pradhikaran (MJP), Maharashtra Industries Development Corporation (MIDC), Cantonment Boards. January 20 315 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Sr. No. 5. Existing Applicability Proposed Applicability All other Public Water Supply Schemes and Sewage Treatment Plants (including allied activities) shall be billed under the LT II or LT V category tariff, as the case may be. LT IV: LT – Agriculture LT IV (A): LT - Agriculture Un-metered –Pumpsets All other Public Water Supply Schemes and Sewage Treatment Plants (including allied activities) shall be billed under the LT II or LT V category tariff, as the case may be (ii) Electricity / power supply at Low/Medium Voltage for Sewage Treatment Plants and common effluent treatment plants, set up by Local Self-Government Bodies (Gram Panchayats, Panchayat Samitis, Zilla Parishads, Municipal Councils and Corporations, etc.), Maharashtra Industries Development Corporation (MIDC), Industries Association or consortium of industries., Housing societies/complexes. LT IV: LT - Agriculture LT IV (A): LT - Agriculture Un-metered –Pumpsets Applicability: Applicability: This tariff category is applicable for motive power supplied This tariff category is applicable for motive power supplied for Agriculture metered pumping loads, and for one lamp of for Agriculture metered pumping loads, and for one lamp of MSEDCL January 20 316 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Sr. No. Existing Applicability Proposed Applicability wattage up to 40 to be connected to the motive power circuit wattage up to 40 to be connected to the motive power circuit for use in pump-houses at Low/Medium Voltage. for use in pump-houses at Low/Medium Voltage. Note: Note: i. The Flat Rate Tariff as above will remain in force only till i. The Flat Rate Tariff as above will remain in force only meters are installed; once meter is installed, the till meters are installed; once meter is installed, the consumer will be billed as per the Tariff applicable to consumer will be billed as per the Tariff applicable to metered agricultural consumers. metered agricultural consumers. ii. The list of Category 1 Zones (with consumption norm ii. The list of Category 1 Zones (with consumption norm above 1318 hours/ HP/year) and Category 2 Zones (with above 1318 hours/ HP/year) and Category 2 Zones consumption norm below 1318 hours/HP/year) is given (with consumption norm below 1318 hours/HP/year) is as below: given as below: Category 1 Zones (with Category 2 Zones (with consumption norm above consumption norm below 1318 hours/HP/year) 1318 hours/HP/year) Bhandup (U), Pune, Nashik, Baramati, Jalgaon MSEDCL Amaravati, Aurangabad, Kalyan, Konkan, Kolhapur, Latur, Nagpur, Chandrapur, Gondia, Nanded, Akola Category 1 Zones (with consumption norm above 1318 hours/HP/year) Bhandup (U), Pune, Nashik, Baramati, Jalgaon January 20 Category 2 Zones (with consumption norm below 1318 hours/HP/year) Amaravati, Aurangabad, Kalyan, Konkan, Kolhapur, Latur, Nagpur, Chandrapur, Gondia, Nanded, Akola 317 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Sr. No. Existing Applicability Proposed Applicability iii. Supply under this Tariff will be given for a minimum load iii. of 2 HP. If any consumer requires any load less than 2 HP for agricultural purposes, he shall be required to pay the Fixed Charge/Energy Charge on this basis as if a load of 2 HP is connected. Supply under this Tariff will be given for a minimum load of 2 HP. If any consumer requires any load less than 2 HP for agricultural purposes, he shall be required to pay the Fixed Charge/Energy Charge on this basis as if a load of 2 HP is connected. LT IV (B): LT – Agriculture Metered – Pumpsets LT IV (B): LT – Agriculture Metered – Pumpsets Applicability: This tariff category is applicable for motive power supplied for Agriculture metered pumping loads, and for one lamp of wattage up to 40 to be connected to the motive power circuit for use in pump-houses at Low/Medium Voltage. It is also applicable for power supply for cane crushers and/or fodder cutters for self-use for agricultural processing operations, but not for operating a flour mill, oil mill or expeller in the same premises, either operated by a separate motor or a change of belt drive. Applicability: This tariff category is applicable for motive power supplied for Agriculture metered pumping loads, and for one lamp of wattage up to 40 to be connected to the motive power circuit for use in pump-houses at Low/Medium Voltage. It is also applicable for power supply for cane crushers and/or fodder cutters for self-use for agricultural processing operations, but not for operating a flour mill, oil mill or expeller in the same premises, either operated by a separate motor or a change of belt drive. LT IV (C): LT - Agriculture Metered – Others LT IV (C): LT - Agriculture Metered – Others MSEDCL January 20 318 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Sr. No. 6. Existing Applicability Proposed Applicability Applicability: Applicability: This category shall be applicable for use of electricity / This category shall be applicable for use of electricity / power supply at Low / Medium Voltage for: power supply at Low / Medium Voltage for: a. Pre-cooling plants and cold storage units for Agriculture a. Pre-cooling plants and cold storage units for Agriculture Products – processed or otherwise; Products – processed or otherwise; b. Poultries exclusively undertaking Layer & Broiler b. Poultries exclusively undertaking Layer & Broiler activities, including Hatcheries; activities, including Hatcheries; c. High-Tech Agriculture (i.e. Tissue Culture, Green c. High-Tech Agriculture (i.e. Tissue Culture, Green House, Mushroom activities), provided the power supply House, Mushroom activities), provided the power supply is exclusively utilized by such Hi-Tech Agriculture is exclusively utilized by such Hi-Tech Agriculture consumers for purposes directly concerned with the crop consumers for purposes directly concerned with the cultivation process, and that the power is not utilized for crop cultivation process, and that the power is not any engineering or industrial process; utilized for any engineering or industrial process; Floriculture, Horticulture, Nurseries, Plantations, stand- d. Floriculture, Horticulture, Nurseries, Plantations, standalone Aquaculture, Sericulture, Cattle Breeding Farms, alone Aquaculture, Sericulture, Cattle Breeding Farms, etc. etc.; LT V: LT- Industry LT V: LT- Industry LT-V (A): LT – Industry –Powerlooms Applicability: MSEDCL LT-V (A): LT – Industry –Powerlooms Applicability: January 20 319 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Sr. No. Existing Applicability Proposed Applicability This category shall be applicable for power supply to Powerlooms including other allied activities like, Warping, Doubling, Twisting, etc., connected at Low/Medium Tension only. Note: The ToD Tariff is compulsorily applicable for LT V (A) (ii) (i.e., above 20 kW), and optionally available to LT- V (A) (i) (i.e., up to 20 kW) having ToD meter installed. This category shall be applicable for power supply to Powerlooms including other allied activities like, Warping, Doubling, Twisting, etc., connected at Low/Medium Tension only. Note: The ToD Tariff is compulsorily applicable for LT V (A) (ii) (i.e., above 20 kVA), and optionally available to LT- V (A) (i) (i.e., up to 20 kVA) having ToD meter installed. LT-V (B): LT - Industry – General LT-V (B): LT - Industry – General Applicability: This tariff category is applicable for electricity for Industrial use, at Low/Medium Voltage, for purposes of manufacturing and processing, including electricity used within such premises for general lighting, heating/cooling, etc. It is also applicable for use of electricity / power supply for Administrative Offices / Canteens, Recreation Hall / Sports Club or facilities / Health Club or facilities/ Gymnasium / Swimming Pool exclusively meant for employees of the Applicability: This tariff category is applicable for electricity for Industrial use, at Low/Medium Voltage, for purposes of manufacturing and processing, including electricity used within such premises for general lighting, heating/cooling, etc. It is also applicable for use of electricity / power supply for Administrative Offices / Canteens, Recreation Hall / Sports Club or facilities / Health Club or facilities/ Gymnasium / Swimming Pool exclusively meant for employees of the MSEDCL January 20 320 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Sr. No. Existing Applicability Proposed Applicability industry; lifts, water pumps, fire-fighting pumps and industry; lifts, water pumps, fire-fighting pumps and equipment, street and common area lighting; Research and equipment, street and common area lighting; Research and Development units, Dhobi/Laundry etc. Development units, Dhobi/Laundry; Common facility Centre (CFC) establish under cluster development program of Provided that all such facilities are situated within the same Central/State Government etc. industrial premises and supplied power from the same point of supply; Provided that all such facilities are situated within the same This tariff category shall also be applicable for use of industrial premises and supplied power from the same point electricity / power supply by an Information Technology (IT) of supply; or IT-enabled Services (ITeS) Unit as defined in the This tariff category shall also be applicable for use of applicable IT/ITeS Policy of Government of Maharashtra. electricity / power supply by an Information Technology (IT) Where such Unit does not hold the relevant permanent or IT-enabled Services (ITeS) Unit as defined in the registration Certificate, the tariff shall be as per the LT II applicable IT/ITeS Policy of Government of Maharashtra. category, and the LT V(B) tariff shall apply to it after receipt Where such Unit does not hold the relevant valid permanent of such permanent registration Certificate and till it is valid. registration Certificate, the tariff shall be as per the LT II category, and the LT V(B) tariff shall apply to it after receipt It shall also be applicable for use of electricity / power supply of such permanent registration Certificate and till it is valid. for (but not limited to) the following purposes: It shall also be applicable for use of electricity / power supply a. Flour Mill, Dal Mill, Rice Mill, Poha Mill, Masala Mill, for (but not limited to) the following purposes: Saw Mill; MSEDCL January 20 321 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Sr. No. Existing Applicability Proposed Applicability b. Ice Factory, Ice-cream manufacturing units, Milk Processing / Chilling Plants (Dairy); c. Engineering Workshops, Engineering Goods Manufacturing units; Printing Presses; Transformer Repair Workshops; Tyre Remoulding/Retreading units; and Vulcanizing units; d. Mining, Quarrying and Stone Crushing units; e. Garment Manufacturing units; f. LPG/CNG bottling plants, etc.; g. Sewage Treatment Plant/ Common Effluent Treatment Plant for industries, and not covered under the LT – Public Water Works category h. Start-up power for Generating Plants, i.e. the power required for trial run of a Power Plant during commissioning of the Unit and its Auxiliaries, and for its start-up after planned or forced outage (but not for construction); i. Brick Kiln (Bhatti); j. Biotechnology Industries covered under the Biotechnology Policy of Government of Maharashtra; MSEDCL a. Flour Mill, Dal Mill, Rice Mill, Poha Mill, Masala Mill, Saw Mill; b. Ice Factory, Ice-cream manufacturing units, Milk Processing / Chilling Plants (Dairy), Packaged drinking water plants; c. Engineering Workshops, Engineering Goods Manufacturing units; Printing Presses; Transformer Repair Workshops; Tyre Remoulding/Retreading units; and Vulcanizing units; d. Mining, Quarrying and Stone Crushing units; e. Garment Manufacturing units; f. LPG/CNG bottling plants, etc.; g. Sewage Treatment Plant/ Common Effluent Treatment Plant for industries not covered under the LT – Public Water Works category; h. Start-up power for Generating Plants, i.e. the power required for trial run of a Power Plant during commissioning of the Unit and its Auxiliaries, and for its start-up after planned or forced outage (but not for construction); i. Brick Kiln (Bhatti); January 20 322 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Sr. No. 7. Existing Applicability Proposed Applicability k. Cold Storages not covered under LT IV (C) – j. Biotechnology Industries covered under the Agriculture (Others); Biotechnology Policy of Government of Maharashtra; l. Food (including seafood) Processing units; k. Cold Storages not covered under LT IV (C) – Agriculture m. Seed manufacturing; (Others); n. Dedicated water supply schemes to power plants; l. Food (including seafood) Processing units; o. Auxiliary Power supply to EHV/Distribution m.Seed manufacturing; Substations (but not for construction) n. Dedicated water supply schemes to power plants; Note: o. Auxiliary Power supply to EHV/Distribution Substations The ToD Tariff is applicable for LT-V (B) (ii) (i.e. above 20 (but not for construction); kW), and optionally available to LT-V (B) (i) (i.e. up to 20 p. Ordinance Factories of Defence Establishments kW) having ToD meter installed. Note: The ToD Tariff is applicable for LT-V (B) (ii) (i.e. above 20 kVA), and optionally available to LT-V (B) (i) (i.e. up to 20 kVA) having ToD meter installed. LT VI: LT – Street Light LT VI: LT – Street Light Applicability: This tariff category is applicable for the electricity used for lighting of public streets/ thoroughfares which are open for use by the general public, at Low / Medium Voltage, and also at High Voltage. MSEDCL Applicability: This tariff category is applicable for the electricity used for lighting of public streets/ thoroughfares which are open for use by the general public, at Low / Medium Voltage, and also at High Voltage. January 20 323 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Sr. No. Existing Applicability Proposed Applicability Street lights in residential complexes, commercial complexes, industrial premises, etc. will be billed at the tariff of the respective applicable categories. This category is also applicable for use of electricity / power supply at Low / Medium Voltage or at High Voltage for (but not limited to) the following purposes, irrespective of who owns, operates or maintains these facilities: a) Lighting in Public Gardens (i.e. which are open to the general public free of charge); Street lights in residential complexes, commercial complexes, industrial premises, etc. will be billed at the tariff of the respective applicable categories. This category is also applicable for use of electricity / power supply at Low / Medium Voltage or at High Voltage for (but not limited to) the following purposes, irrespective of who owns, operates or maintains these facilities: a) Lighting in Public Gardens (i.e. which are open to the general public free of charge); b) Traffic Signals and Traffic Islands; b) Traffic Signals and Traffic Islands; c) Public Sanitary Conveniences; c) Public Sanitary Conveniences; d) Public Water Fountains; and d) Public Water Fountains; and e) Such other public places open to the general public free of charge. e) Such other public places open to the general public free of charge. Note: Note: MSEDCL January 20 324 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Sr. No. Existing Applicability Proposed Applicability The above street and other lighting facilities having The above street and other lighting facilities having ‘Automatic Timers’ for switching On/Off would be levied ‘Automatic Timers’ for switching On/Off would be levied Demand Charges on the lower of the following– Demand Charges on the lower of the following– 8. i) 50 percent of ‘Contract Demand’ or ii) Actual ‘Recorded Demand’. LT VII: LT-Temporary Supply LT VII (A): LT – Temporary Supply Religious (TSR) i) 50 percent of ‘Contract Demand’ or ii) Actual ‘Recorded Demand’. LT VII: LT-Temporary Supply LT VII (A): LT – Temporary Supply Religious (TSR) Applicability: This tariff category is applicable for electricity supply at Low/Medium voltage for temporary purposes for public religious functions like Ganesh Utsav, Navaratri, Eid, Moharrum, Ram Lila, Diwali, Christmas, Guru Nanak Jayanti, etc., and for areas where community prayers are held; and for functions to commemorate anniversaries of personalities and National or State events for which Public Holidays have been declared, such as Gandhi Jayanti, Ambedkar Jayanti, Chhatrapati Shivaji Jayanti, Republic Day, Independence Day, etc. Applicability: This tariff category is applicable for electricity supply at Low/Medium voltage for temporary purposes for a period not exceeding two year for public religious functions, like Ganesh Utsav, Navaratri, Eid, Moharrum, Ram Lila, Diwali, Christmas, Guru Nanak Jayanti, etc., and for areas where community prayers are held; for functions to commemorate anniversaries of personalities and National or State events for which Public Holidays have been declared, such as Gandhi Jayanti, Ambedkar Jayanti, Chhatrapati Shivaji Jayanti, Republic Day, Independence Day, lighting for MSEDCL January 20 325 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Sr. No. Existing Applicability Proposed Applicability religious exhibitions & Gatherings (Satsang, Spiritual talks, Spiritual Book Exhibition) etc. LT VII (B): LT - Temporary Supply Others (TSO) LT VII (B): LT - Temporary Supply Others (TSO) Applicability: This tariff category is applicable for electricity used at Low/Medium voltage for Temporary use for a period not exceeding one year, other than for the religious or commemorative purposes covered under LT VII (A), for a) Construction of all types of structures/ infrastructure such as buildings, bridges, fly-overs, dams, Power Stations, roads, Aerodromes, tunnels for laying of pipelines; b) Any construction or renovation activity in existing premises; c) Decorative lighting for exhibitions, circuses, film shootings, marriages, etc., d) Any other activity not covered under LT VII (A). Applicability: This tariff category is applicable for electricity used at Low/Medium voltage for Temporary use for a period not exceeding onetwoyear, other than for the religious or commemorative purposes covered under LT VII (A), for a) Construction of all types of structures/ infrastructure such as buildings, bridges, fly-overs, dams, Power Stations, roads, Aerodromes, tunnels for laying of pipelines; b) Any construction or renovation activity in existing premises; c) Decorative Lighting for exhibitions other than religious exhibitions covered under LT VII (A), circuses, film shootings, marriages, etc., d) Any other activity not covered under LT VII (A). Note: MSEDCL January 20 326 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Sr. No. Existing Applicability Proposed Applicability i. Additional Fixed Charges of Rs. 185 per 10 kW load or Note: i. Additional Fixed Charges of Rs. 185 per 10 kW load or part thereof above 10 kW load shall be payable. part thereof above 10 kW load shall be payable. ii. Electricity used at Low / Medium Voltage for operating Fire-Fighting pumps and equipment in residential or ii. Electricity used at Low / Medium Voltage for operating Fire-Fighting pumps and equipment in residential or other premises shall be charged as per the tariff other premises shall be charged as per the tariff category applicable to such premises. category applicable to such premises. 9. LT VIII: LT - Advertisements and Hoardings LT VIII: LT - Advertisements and Hoardings Applicability: This tariff category is applicable for use of electricity at Low/ Medium Voltage for advertisements, hoardings (including hoardings fixed on lamp posts/installed along roadsides), and other commercial illumination such as external floodlights, displays, neon signs at departmental stores, malls, multiplexes, theatres, clubs, hotels and other such establishments; Note: Applicability: This tariff category is applicable for use of electricity at Low/ Medium Voltage for advertisements, hoardings (including hoardings fixed on lamp posts/installed along roadsides), and other commercial illumination such as external floodlights, displays, neon signs at departmental stores, malls, multiplexes, theatres, clubs, hotels and other such establishments; Note: MSEDCL January 20 327 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Sr. No. 10. Existing Applicability Proposed Applicability a) Consumers availing power supply at High Voltage for a) Consumers availing power supply at High Voltage for any of the above purposes shall be billed as per the tariff any of the above purposes shall be billed as per the tariff of this LT category. of this LT category. b) This category is not applicable to use of electricity b) This category is not applicable to use of electricity for the specifically covered under the LT-II category; or to external illumination of monuments and electricity used for the external illumination of historical/heritage buildings which is specifically covered monuments and historical/heritage buildings approved under the LT-II category; or to electricity used approved by MTDC or the concerned Local Authority, which shall by MTDC or the concerned Local Authority, which shall be covered under the LT-II category depending upon be covered under the LT-II category depending upon the the Sanctioned Load. Sanctioned Load. c) The electricity used for indicating/ displaying the name c) The electricity used for indicating/ displaying the name and other details of the premises shall be covered under and other details of the premises shall be covered under the category of such premises, and not under this tariff the category of such premises, and not under this tariff category. category. LT IX: LT- Crematorium and Burial Grounds LT IX: LT- Crematorium and Burial Grounds Applicability: MSEDCL Applicability: January 20 328 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Sr. No. Existing Applicability Proposed Applicability This tariff category is applicable for electricity used at This tariff category is applicable for electricity used at Low/Medium Voltage in Crematoriums and Burial Grounds Low/Medium Voltage in Crematoriums and Burial Grounds for all purposes, including lighting. for all purposes, including lighting. 11. However, it will be applicable only to the portion of the premises catering to such activities. In case a part of the area is being used for other purposes, a separate meter will have to be provided for such purposes and the consumption charged at the applicable tariff. LT X: LT - Public Services However, it will be applicable only to the portion of the premises catering to such activities. In case a part of the area is being used for other purposes, a separate meter will have to be provided for such purposes and the consumption charged at the applicable tariff. LT X: LT - Public Services LT X (A): LT - Public Services - Government Educational LT X (A): LT - Public Services - Government Educational Institutes and Hospitals Institutes and Hospitals Applicability: This tariff category is applicable for electricity supply at Low/Medium Voltage for Educational Institutions, such as Schools and Colleges; Health Care facilities, such as Hospitals, Dispensaries, Clinics, Primary Health Care Centres, Diagnostic Centres, Blood Banks and Pathology Laboratories; Libraries and public reading rooms - of the MSEDCL Applicability: This tariff category is applicable for electricity supply at Low/Medium Voltage for Educational Institutions, such as Schools and Colleges; Health Care facilities, such as Hospitals, Dispensaries, Clinics, Primary Health Care Centres, Diagnostic Centres, Blood Banks and Pathology Laboratories; Libraries and public reading rooms - of the January 20 329 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Sr. No. Existing Applicability Proposed Applicability State or Central Government or Local Self-Government bodies such as Municipalities, Zilla Parishads, Panchayat Samitis, Gram Panchayats, etc; It shall also be applicable for electricity used for Sports Clubs and facilities / Health Clubs and facilities / Gymnasium / Swimming Pools attached to such Educational Institutions / Hospitals, provided that they are situated in the same premises and are meant primarily for their students / faculty/ employees/ patients. Note: The ToD Tariff is applicable for LT-X (A) (ii) and LT-X (A) (iii) (i.e., above 20 kW)and optionally available to LT- X (A) (i) (i.e., up to 20 kW) having ToD meter installed. State or Central Government or Local Self-Government bodies such as Municipalities, Zilla Parishads, Panchayat Samitis, Gram Panchayats, etc; It shall also be applicable for electricity used for Sports Clubs,and facilities / Health Clubs, Hostels,and facilities /Gymnasium / Swimming Pools attached to such Educational Institutions / Hospitals, provided that they are situated in the same premises and are meant primarily for their students / faculty/ employees/ patients. Note: The ToD Tariff is applicable for LT-X (A) (ii) and LT-X (A) (iii) (i.e., above 20 kVA)and optionally available to LT- X (A) (i) (i.e., up to 20 kVA) having ToD meter installed. LT X (B): LT - Public Services – Others LT X (B): LT - Public Services – Others Applicability: This tariff category is applicable for electricity supply at Applicability: This tariff category is applicable for electricity supply at Low/Medium Voltage for Low/Medium Voltage for a) Educational Institutions, such as Schools and Colleges; Health Care facilities, such as Hospitals, Dispensaries, MSEDCL January 20 330 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Sr. No. Existing Applicability b) c) d) e) Proposed Applicability Clinics, Primary Health Care Centres, Diagnostic Centres, Blood banks and Pathology Laboratories; Libraries and public reading rooms - other than those of the State or Central Government or Local SelfGovernment bodies such as Municipalities, Zilla Parishads, Panchayat Samitis, Gram Panchayats, etc. Sports Clubs and facilities / Health Clubs and facilities / Gymnasium / Swimming Pools attached to such Educational Institutions /Health Care facilities, provided that they are situated in the same premises and are meant primarily for their students / faculty/ employees/ patients; all offices of Government and Municipal/ Local Authorities/ Local Self-Government bodies, such as Municipalities, ZillaParishads, PanchayatSamitis, Gram Panchayats; Police Stations and Police Chowkies; Post Offices; Armed Forces/Defence and Para-Military establishments; Service-oriented Spiritual Organisations; State or Municipal/Local Authority Transport establishments, including their Workshops; MSEDCL a) Educational Institutions, such as Schools and Colleges; Health Care facilities, such as Hospitals, Dispensaries, Clinics, Primary Health Care Centres, Diagnostic Centres, Blood banks and Pathology Laboratories; Libraries and public reading rooms - other than those of the State or Central Government or Local SelfGovernment bodies such as Municipalities, Zilla Parishads, Panchayat Samitis, Gram Panchayats, etc. b) Sports Clubs,andfacilities / Health Clubs, Hostels,and facilities /Gymnasium / Swimming Pools attached to such Educational Institutions /Health Care facilities, provided that they are situated in the same premises and are meant primarily for their students / faculty/ employees/ patients; c) all offices of Government and Municipal/ Local Authorities/ Local Self-Government bodies, such as Municipalities, Zilla Parishads, Panchayat Samitis, Gram Panchayats; Police Stations and Police Chowkies; Post Offices; Armed Forces/Defence and Para-Military establishments; Administrative offices of MSEDCL/MSETCL & MSPGCL. January 20 331 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Sr. No. Existing Applicability f) g) h) i) 12. Proposed Applicability Fire Service Stations; Jails, Prisons; Courts; Airports; Ports and Jetties; Railway/Metro/Monorail Stations, including Shops, Workshops, Yards, etc, if the supply is at Low/ Medium Voltage. d) Service-oriented Spiritual Organisations; e) State or Municipal/Local Authority Transport establishments, including their Workshops; f) Fire Service Stations; Jails, Prisons; Courts; g) Airports; h) Ports and Jetties; i) Public Sanitary Conveniences/Toilets; j) Water ATM (RO/UV/UF Water Purifier Plants) of Local bodies; k) Railway/Metro/Monorail Stations, including Shops, Workshops, Yards, etc., if the supply is at Low/ Medium Voltage. LT (XI) LT : Electrical Charging Stations/Centers for LT (XI) LT : Electrical Charging Stations/Centers for Vehicles Vehicles Applicability: Applicability: This Tariff category is applicable for Electric Vehicle This Tariff category is applicable for Electric Vehicle Charging Station Charging Station MSEDCL January 20 332 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Sr. No. Existing Applicability Proposed Applicability In case the consumer uses the electricity supply for In case the consumer uses the electricity supply for charging his own electric vehicle at his premises, the tariff charging his own electric vehicle at his premises, the tariff applicable shall be as per the category of such premises. applicable shall be as per the category of such premises. Electricity consumption for other facilities at Charging Station such as restaurant, rest rooms, convenience stores, etc., shall be charged at tariff applicable to Commercial Category. Electricity consumption for other facilities at Charging Station such as restaurant, rest rooms, convenience stores, etc., shall be charged at tariff applicable to Commercial Category. 15.3 HT Category Sr. No . 1. Existing Applicability Proposed Applicability HT I: HT- Industry HT I (A): Industry- General HT I: HT- Industry HT I (A): Industry- General Applicability: This tariff category is applicable for electricity for Industrial use at High Voltage for purposes of manufacturing and processing, including electricity used within such premises for general lighting, heating/cooling, etc. Applicability: This tariff category is applicable for electricity for Industrial use at High Voltage for purposes of manufacturing and processing, including electricity used within such premises for general lighting, heating/cooling, etc. MSEDCL January 20 333 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Sr. No . Existing Applicability Proposed Applicability It is also applicable for use of electricity / power supply for Administrative Offices / Canteen, Recreation Hall / Sports Club or facilities / Health Club or facilities/ Gymnasium / Swimming Pool exclusively meant for employees of the industry; lifts, water pumps, fire-fighting pumps and equipment, street and common area lighting; Research and Development units, etc. – It is also applicable for use of electricity / power supply in the same contiguous premises for Administrative Offices / Canteen, Recreation Hall / Sports Club or facilities / Health Club or facilities/ Gymnasium / Swimming Pool exclusively meant for employees of the industry; lifts, water pumps, firefighting pumps and equipment, street and common area lighting; Research and Development units, unit specific sewage treatment plants/effluent treatment plants etc. Provided that all such facilities are situated within the same industrial premises and supplied power from the same point of supply. This tariff category shall be applicable for use of electricity / power supply by an Information Technology (IT) or IT-enabled Services (ITeS) Unit as defined in the applicable IT/ITes Policy of Government of Maharashtra. Where such Unit does not hold the relevant permanent registration Certificate, the tariff shall be as per the HT II category, and the HT I tariff shall apply to it after receipt of such permanent registration Certificate and till it is valid. Provided that all such facilities are situated within the same industrial premises and supplied power from the same point of supply. This tariff category shall be applicable for use of electricity / power supply by an Information Technology (IT) or IT-enabled Services (ITeS) Unit as defined in the applicable IT/ITes Policy of Government of Maharashtra. Where such Unit does not hold the relevant valid permanent registration Certificate, the tariff shall be as per the HT II category, and the HT I tariff shall apply to it after receipt of such permanent registration Certificate and It shall also be applicable for use of electricity / power supply for (but till it is valid. not limited to) the following purposes: MSEDCL January 20 334 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Sr. No . Existing Applicability a) b) c) d) e) f) g) h) i) j) k) l) Proposed Applicability Flour Mills, Dal Mills, Rice Mills, Poha Mills, Masala Mills, Saw It shall also be applicable for use of electricity / power supply Mills; for (but not limited to) the following purposes: Ice Factories, Ice-cream manufacturing units, Milk Processing a) Flour Mills, Dal Mills, Rice Mills, Poha Mills, Masala Mills, / Chilling Plants (Dairy); Saw Mills; Engineering Workshops, Engineering Goods manufacturing b) Ice Factories, Ice-cream manufacturing units, Milk units; Printing Presses; Transformer Repair Workshops; Tyre Processing / Chilling Plants (Dairy); Remoulding/Retreading units, and Vulcanizing units; c) Engineering Workshops, Engineering Goods Mining, Quarrying and Stone Crushing units; manufacturing units; Printing Presses; Transformer Garment Manufacturing units Repair Workshops; Tyre Remoulding/Retreading units, LPG/CNG bottling plants, etc.; and Vulcanizing units; Sewage Treatment Plant/ Common Effluent Treatment Plant d) Mining, Quarrying and Stone Crushing units; for industries, and not covered under the HT – PWW category e) Garment Manufacturing units Start-up power for Generating Plants, i.e., the power required f) LPG/CNG bottling plants, etc.; for trial run of a Power Plant during commissioning of the Unit g) Sewage Treatment Plant/ Common Effluent Treatment and its Auxiliaries, and for its start-up after planned or forced Plant for industries not covered under the HT – PWW outage (but not for construction); category; Brick Kiln (Bhatti); h) Start-up power for Generating Plants, i.e., the power Biotechnology Industries covered under the Biotechnology required for trial run of a Power Plant during Policy of Government of Maharashtra; commissioning of the Unit and its Auxiliaries, and for its Cold Storages not covered under HT V (B)– Agriculture start-up after planned or forced outage (but not for (Others); construction); Food (including Seafood) Processing units. MSEDCL January 20 335 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Sr. No . Existing Applicability Proposed Applicability m) Seed manufacturing; n) Dedicated Water Supply Schemes to Power Plants; o) Auxiliary Power Supply to EHV/Distribution Substations (but not for construction) i) Brick Kiln (Bhatti); j) Biotechnology Industries covered under the Biotechnology Policy of Government of Maharashtra; k) Cold Storages not covered under HT V (B) – Agriculture (Others); l) Food (including Seafood) Processing units; m) Seed manufacturing; n) Dedicated Water Supply Schemes to Power Plants; o) Auxiliary Power Supply to EHV/Distribution Substations (but not for construction); p) Ordinance Factories of Defence Establishments. q) Common facility Centre (CFC) established under cluster development program of central/state Government etc. r) Packaged Drinking Water Plant; HT I (B): Industry – Seasonal HT I (B): Industry – Seasonal Applicability: Applicable to Seasonal consumers, who are defined as those who normally work during a part of the year up to a maximum of 9 months, such as Cotton Ginning Factories, Cotton Seed Oil Mills, Cotton Pressing Factories, Salt Manufacturers, Khandsari/Jaggery Applicability: Applicable to Seasonal consumers, who are defined as those who normally work during a part of the year up to a maximum of 9 months, such as Cotton Ginning Factories, Cotton Seed Oil Mills, Cotton Pressing Factories, Salt Manufacturers, MSEDCL January 20 336 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Sr. No . Existing Applicability Proposed Applicability Manufacturing Units excluding Sugar Factories, or such other Khandsari/Jaggery Manufacturing Units excluding Sugar consumers who opt for a seasonal pattern of consumption, such that Factories, or such other consumers who opt for a seasonal the electricity requirement is seasonal in nature. pattern of consumption, such that the electricity requirement is seasonal in nature. Provided that the period of operation of in a financial year should be limited upto 9 months, and the category should be opted for by the Provided that the period of operation of in a financial year consumer within first quarter of the financial year’. should be limited upto 9 months, and the category should be Note: opted for by the consumer within first quarter of the financial i. High Tension Industrial consumers having captive generation year’. facility synchronised with the grid will pay additional Demand Note: Charges of Rs. 20/kVA/Month only on the extent of Stand-by A) High Tension Industrial consumers having captive Contract Demand component and not on the entire Contract generation facility synchronised with the grid will pay Demand. additional Demand Charges in following manner: ii. Stand-by Charges will be levied on such consumers on the Standi. If standby demand is unutilized then 25% of applicable by component, only if the consumer‟s demand exceeds the demand charges on standby contracted capacity needs Contract Demand. to be levied. iii. This additional Demand Charge will not be applicable if there is ii. During planned/unplanned outage of CPP, embedded no Stand-by demand and the Captive Unit is synchronised with CPP consumer shall pay additional Demand Charges on the Grid only for the export of power. utilized standby capacity at the rate of 150%of applicable iv. Demand Charge shall be applicable at 25% of the above rates on demand charges (on monthly basis). the start-up demand contracted by the Power Plant (as referred to at (h) above) with the Distribution Licensee. MSEDCL January 20 337 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Sr. No . Existing Applicability Proposed Applicability v. Demand Charge shall be applicable at 75% of the above rates for Steel Plant operating with electric arc furnaces. iii. Demand exceeding the contracted demand plus stand by component shall be billed at a rate of 2 times the applicable demand charges on monthly basis. B) Demand Charge shall be applicable at 25% of the above rates on the start-up demand contracted by the Power Plant (as referred to at (h) above) with the Distribution Licensee. C) Demand Charge shall be applicable at 75% of the above rates for Steel Plant operating with electric arc furnaces. 2. HT II: HT- Commercial HT II: HT- Commercial Applicability: This tariff category is applicable for electricity used at High Voltage in non-residential, non-industrial and/or commercial premises for commercial consumption meant for operating various appliances used for purposes such as lighting, heating, cooling, cooking, washing/cleaning, entertainment/ leisure and water pumping in, but not limited to, the following premises: a) Non-Residential, Commercial and Business premises, including Shopping Malls and Showrooms; Applicability: This tariff category is applicable for electricity used at High Voltage in non-residential, non-industrial and/or commercial premises for commercial consumption meant for operating various appliances used for purposes such as lighting, heating, cooling, cooking, washing/cleaning, entertainment/ leisure and water pumping in, but not limited to, the following premises: a) Non-Residential, Commercial and Business premises, including Shopping Malls and Showrooms; MSEDCL January 20 338 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Sr. No . Existing Applicability Proposed Applicability b) Combined lighting and power services for facilities relating to Entertainment, including film studios, cinemas and theatres (including multiplexes), Hospitality, Leisure, Meeting/Town Halls, and places of Recreation and Public Entertainment; c) Offices, including Commercial Establishments; d) Marriage Halls, Hotels / Restaurants, Ice-cream parlours, Coffee Shops, Guest Houses, Internet / Cyber Cafes, Telephone Booths and Fax / Photocopy shops; e) Automobile and all other types of repairs, servicing and maintenance centres (unless specifically covered under another tariff category); Retail Gas Filling Stations, Petrol Pumps & Service Stations, including Garages; - b) Combined lighting and power services for facilities relating to Entertainment, including film studios, cinemas and theatres (including multiplexes), Hospitality, Leisure, Meeting/Town Halls, and places of Recreation and Public Entertainment; c) Offices, including Commercial Establishments; d) Marriage Halls, Resorts, Hotels / Restaurants, Ice-cream parlours, Commercial Water ATM (RO/UV/UF Water Purifier Plants), Coffee Shops, Guest Houses, Internet / Cyber Cafes, Telephone Booths and Fax / Photocopy shops; f) Tailoring Shops, Computer Training Institutes, Typing Institutes, Photo Laboratories, Beauty Parlours and Saloons; e) Automobile and all other types of repairs, servicing and maintenance centres (unless specifically covered under another tariff category); Retail Gas Filling Stations, Petrol Pumps & Service Stations, including Garages; - g) Banks and ATM centres, Telephone Exchanges, TV Stations, Micro Wave Stations, Radio Stations, Telecommunications Tower; f) Tailoring Shops, Computer Training Institutes, Typing Institutes, Photo Laboratories, Beauty Parlours and Saloons; MSEDCL January 20 339 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Sr. No . Existing Applicability Proposed Applicability h) Common facilities, like Water Pumping / Lifts / Fire-Fighting Pumps and other equipment / Street and other common area Lighting, etc., in Commercial Complexes; g) Banks and ATM centres, Telephone Exchanges, TV Stations, Micro Wave Stations, Radio Stations, Telecommunications Tower; i) Sports Clubs/facilities, Health Clubs/facilities, Gymnasiums, Swimming Pools not covered under any other category; h) Common facilities, like Water Pumping / Lifts / FireFighting Pumps and other equipment / Street and other common area Lighting, etc., in Commercial Complexes; j) External illumination of monuments/ historical/heritage buildings approved by Maharashtra Tourism Development Corporation (MTDC) or the concerned Local Authority; k) Construction of all types of structures/ infrastructure such as buildings, bridges, fly-overs, dams, Power Stations, roads, Aerodromes, tunnels for laying of pipelines for all purposes, and which is not covered under the HT - Temporary category; Note: Residential LT consumers with consumption above 500 units per month (current month of supply) and who undertake construction or renovation activity in their existing premises shall not require a separate Temporary category connection but be billed at the LTII Commercial tariff; MSEDCL January 20 i) Sports Clubs/facilities, Health Clubs/facilities, Gymnasiums, Swimming Pools not covered under any other category; j) External illumination of monuments/ historical/heritage buildings approved by Maharashtra Tourism Development Corporation (MTDC) or the concerned Local Authority; k) Godowns and warehouses; l) Construction of all types of structures/ infrastructure such as buildings, bridges, fly-overs, dams, Power Stations, roads, Aerodromes, tunnels for laying of pipelines for all 340 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Sr. No . Existing Applicability l) Proposed Applicability Milk Collection Centres; m) Sewage Treatment Plant/ Common Effluent Treatment Plant for Commercial Complexes , not covered under the HT- PWW category or HT I - Industry n) Stand-alone Research and Development units not covered under any other category; Note: A consumer in the HT II category requiring single-point supply for the purpose of downstream consumption by separately identifiable entities shall have to operate as a Franchisee authorised as such by the Distribution Licensee; or such downstream entities shall be required to take separate individual connections and be charged under the tariff category applicable to them. MSEDCL January 20 purposes, and which is not covered under the HT Temporary category; Note: For Construction, initially supply will be provided under LT VII (B) Temporary Supply Others (TSO), after 2 years the supply will be regularized under LT II Non- Residential. Residential LT consumers with consumption above 500 units per month (current month of supply) and who undertake construction or renovation activity in their existing premises shall not require a separate Temporary category connection but be billed at the LT-II Commercial tariff; m) Milk Collection Centres; n) Sewage Treatment Plant/ Common Effluent Treatment Plant for Commercial Complexes , not covered under the HT IV- PWW & Sewage Treatment Plants or HT I Industry 341 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Sr. No . Existing Applicability Proposed Applicability o) Stand-alone Research and Development units not covered under any other category; Note: 3. 4. HT III: HT – Railways/Metro/Monorail A consumer in the HT II category requiring single-point supply for the purpose of downstream consumption by separately identifiable entities shall have to operate as a Franchisee authorised as such by the Distribution Licensee; or such downstream entities shall be required to take separate individual connections and be charged under the tariff category applicable to them. HT III: HT – Railways/Metro/Monorail Applicability: This tariff is applicable to power supply at High Voltage for Railways, Metro and Monorail, including Stations and Shops, Workshops, Yards, etc. Applicability: This tariff is applicable to power supply at High Voltage for Railways, Metro and Monorail, including Stations and Shops, Workshops, Yards, etc. HT IV: HT - Public Water Works and Sewage Treatment Plants HT IV: HT - Public Water Works and Sewage Treatment Plants Applicability: MSEDCL January 20 342 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Sr. No . Existing Applicability Proposed Applicability This tariff category is applicable for electricity / power supply at High Applicability: Voltage for pumping of water, purification of water and allied activities This tariff category is applicable for relating to Public Water Supply Schemes and Sewage Treatment Plants, provided they are owned or operated or managed by Local 1. Electricity / power supply at High Voltage for pumping of water, purification of water and allied activities relating to Self-Government Bodies (Gram Panchayats, PanchayatSamitis, Public Water Supply Schemes and Sewage Treatment ZillaParishads, Municipal Councils and Corporations, etc.), or by Plants, provided they are owned or operated or managed Maharashtra Jeevan Pradhikaran (MJP), Maharashtra Industries Development Corporation (MIDC), Cantonment Boards and Housing by Local Self-Government Bodies (Gram Panchayats, Societies/complexes. Panchayat Samitis, Zilla Parishads, Municipal Councils and Corporations, etc.), or by Maharashtra Jeevan All other Public Water Supply Schemes and Sewage Treatment Pradhikaran (MJP), Maharashtra Industries Development Plants (including allied activities) shall not be eligible under this tariff Corporation (MIDC), Cantonment Boards. category, but be billed at the tariff applicable to the HT I or HT II All other Public Water Supply Schemes shall not be eligible categories, as the case may be. under this tariff category, but be billed at the tariff applicable to the HT I or HT II categories, as the case may be. 2. Electricity / power supply at High Voltage for Sewage Treatment Plants and common effluent treatment plants, set up by Local Self-Government Bodies (Gram Panchayats, PanchayatSamitis, ZillaParishads, Municipal Councils and Corporations, etc.), Maharashtra Industries MSEDCL January 20 343 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Sr. No . 5. Existing Applicability Proposed Applicability Development Corporation (MIDC), Industries Association or consortium of industries., Residential Housing societies/complexes. HT V: HT – Agricultural HTV (A) – Agriculture Pump sets HT V: HT – Agricultural HTV (A) – Agriculture Pump sets Applicability: This category shall be applicable for Electricity / Power Supply at High Tension for pumping of water exclusively for the purpose of Agriculture / cultivation of crops including HT Lift Irrigation Schemes (LIS) irrespective of ownership. It is also applicable for power supply for cane crushers and/or fodder cutters for self-use for agricultural processing operations, but not for operating a flour mill, oil mill or expeller in the same premises, either operated by a separate motor or a change of belt drive. HT V (B): HT – Agricultural Others Applicability: This category shall be applicable for Electricity / Power Supply at High Tension for pumping of water exclusively for the purpose of Agriculture / cultivation of crops including HT Lift Irrigation Schemes (LIS) irrespective of ownership. It is also applicable for power supply for cane crushers and/or fodder cutters for self-use for agricultural processing operations, but not for operating a flour mill, oil mill or expeller in the same premises, either operated by a separate motor or a change of belt drive. HT V (B): HT – Agricultural Others Applicability: This tariff category is applicable for use of electricity / power supply Applicability: at High Voltage for: This tariff category is applicable for use of electricity / power supply at High Voltage for: MSEDCL January 20 344 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Sr. No . Existing Applicability Proposed Applicability a) Pre-cooling plants and cold storage units for Agricultural Products – processed or otherwise; b) Poultries exclusively undertaking layer and broiler activities, including Hatcheries; c) High-Technology Agriculture (i.e. Tissue Culture, Green House, Mushroom cultivation activities), provided the power supply is exclusively utilized for purposes directly concerned with the crop cultivation process, and not for any engineering or industrial process; d) Floriculture, Horticulture, Nurseries, Plantations, Aquaculture, Sericulture, Cattle Breeding Farms, etc; 6. HT VI: HT - Bulk Supply (Residential) a. Pre-cooling plants and cold storage units for Agriculture Products – processed or otherwise; b. Poultries exclusively undertaking layer and broiler activities, including Hatcheries; c. High-Technology Agriculture (i.e. Tissue Culture, Green House, Mushroom cultivation activities), provided the power supply is exclusively utilized for purposes directly concerned with the crop cultivation process, and not for any engineering or industrial process; d. Floriculture, Horticulture, Nurseries, Plantations, Aquaculture, Sericulture, Cattle Breeding Farms, etc; HT VI: HT - Bulk Supply (Residential) Applicability: Entities supplied electricity at a single point at High Voltage for residential purposes in accordance with the Electricity (Removal of Difficulties) Eighth Order, 2005, in the following cases: a) Co-operative Group Housing Society which owns the premises, for making electricity available to the members of such Society residing in the same premises for residential purposes; and Applicability: Entities supplied electricity at a single point at High Voltage for residential purposes in accordance with the Electricity (Removal of Difficulties) Eighth Order, 2005, in the following cases: a) Co-operative Group Housing Society which owns the premises, for making electricity available to the members MSEDCL January 20 345 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Sr. No . Existing Applicability Proposed Applicability b) a person, for making electricity available to its employees residing in the same premises for residential purposes. 7. of such Society residing in the same premises for residential purposes; and b) a person, for making electricity available to its employees residing in the same premises for residential purposes. HT VIII: HT - Temporary Supply HT VIII (A): HT - Temporary Supply Religious (TSR) HT VIII: HT - Temporary Supply HT VIII (A): HT - Temporary Supply Religious (TSR) Applicability: Applicability: This tariff category is applicable for electricity supply at High Voltage, for temporary use for a period not exceeding one year, for public religious functions like Ganesh Utsav, Navaratri, Eid, Moharrum, Ram Lila, Diwali, Christmas, Guru Nanak Jayanti, etc. or for areas where community prayers are held; and for functions to commemorate anniversaries of personalities and National or State events for which Public Holidays have been declared, such as Gandhi Jayanti, AmbedkarJayanti, Chhatrapati Shivaji Jayanti, Republic Day, Independence Day, etc. This tariff category is applicable for electricity supply at High Voltage, for temporary use for a period not exceeding two year, for public religious functions, like Ganesh Utsav, Navaratri, Eid, Moharrum, Ram Lila, Diwali, Christmas, Guru Nanak Jayanti, etc. or for areas where community prayers are held; and for functions to commemorate anniversaries of personalities and National or State events for which Public Holidays have been declared, such as Gandhi Jayanti, AmbedkarJayanti, Chhatrapati Shivaji Jayanti, Republic Day, Independence Day, lighting for religious exhibitions & Gatherings Satsang, HT VIII (B) – Temporary Supply Others (TSO) Spiritual talks, Spiritual Book Exhibition) etc. MSEDCL January 20 346 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Sr. No . Existing Applicability Proposed Applicability HT VIII (B) – Temporary Supply Others (TSO) Applicability: This tariff category is also applicable for electricity supplied at High Voltage for Temporary use for a period not exceeding one year for a) Construction of all types of structures/ infrastructure such as buildings, bridges, fly-overs, dams, Power Stations, roads, Aerodromes, tunnels for laying of pipelines for all purposes; b) Any construction or renovation activity in existing premises; c) Decorative lighting for exhibitions, circuses, film shootings, marriages, etc. Note: Additional Fixed Charges of Rs.230 per 10 kW load or part thereof above 10 kW load shall be payable. 8. HT IX: HT Public Services MSEDCL Applicability: This tariff category is also applicable for electricity supplied at High Voltage for Temporary use for a period not exceeding onetwo year for a) Construction of all types of structures/ infrastructure such as buildings, bridges, fly-overs, dams, Power Stations, roads, Aerodromes, tunnels for laying of pipelines for all purposes; b) Any construction or renovation activity in existing premises; c) Decorative lighting for exhibitions other than religious exhibitions covered under HT VIII (A), circuses, film shootings, marriages, etc. Note: (i) Additional Fixed Charges of Rs.230 per 10 kW load or part thereof above 10 kW load shall be payable; HT IX: HT Public Services January 20 347 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Sr. No . Existing Applicability Proposed Applicability HT IX (A): HT - Public Services - Government Educational HT IX (A): HT - Public Services - Government Educational Institutes and Hospitals Institutes and Hospitals Applicability: This tariff category is applicable for electricity supply at High Voltage for Educational Institutions, such as Schools and Colleges; Health Care facilities, such as Hospitals, Dispensaries, Clinics, Primary Health Care Centres, Diagnostic Centres, Blood banks and Pathology Laboratories; Libraries and public reading rooms - of the State or Central Government, Local Self-Government bodies such as Municipalities, ZillaParishads, PanchayatSamitis, Gram Panchayats, etc; It shall also be applicable for electricity used for Sports Clubs and facilities / Health Clubs and facilities / Gymnasium / Swimming Pools attached to such Educational Institutions / Health Care facilities, provided that they are situated in the same premises and are meant primarily for the students / faculty/ employees/ patients of such Educational Institutions and Hospitals. HT IX (B): Public Services – Others Applicability: This tariff category is applicable for electricity supply at High Voltage for Educational Institutions, such as Schools and Colleges; Health Care facilities, such as Hospitals, Dispensaries, Clinics, Primary Health Care Centres, Diagnostic Centres, Blood banks and Pathology Laboratories; Libraries and public reading rooms - of the State or Central Government, Local Self-Government bodies such as Municipalities, ZillaParishads, PanchayatSamitis, Gram Panchayats, etc; It shall also be applicable for electricity used for Sports Clubs,and facilities / Health Clubs, Hostels and facilities / Gymnasium / Swimming Pools attached to such Educational Institutions / Health Care facilities, provided that they are situated in the same premises and are meant primarily for the students / faculty/ employees/ patients of such Educational Institutions and Hospitals. Applicability: MSEDCL January 20 348 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Sr. No . Existing Applicability Proposed Applicability This tariff category is applicable for electricity supply at High Voltage HT IX (B): Public Services – Others for Applicability: a) Educational Institutions, such as Schools and Colleges; Health This tariff category is applicable for electricity supply at High Care facilities, such as Hospitals, Dispensaries, Clinics, Voltage for Primary Health Care Centres, Diagnostic Centres, Blood banks and Pathology Laboratories; Libraries and public reading a) Educational Institutions, such as Schools and Colleges; rooms - other than those of the State or Central Government, Health Care facilities, such as Hospitals, Dispensaries, Local Self-Government bodies such as Municipalities, Clinics, Primary Health Care Centres, Diagnostic ZillaParishads, Panchayat Samities, Gram Panchayats, etc. Centres, Blood banks and Pathology Laboratories; b) Sports Clubs and facilities / Health Clubs and facilities / Libraries and public reading rooms - other than those Gymnasium / Swimming Pools attached to such Educational of the State or Central Government, Local SelfInstitutions / Health Care facilities, provided that they are Government bodies such as Municipalities, situated in the same premises and are meant primarily for their ZillaParishads, Panchayat Samities, Gram students / faculty/ employees/ patients; Panchayats, etc. c) all offices of Government and Municipal/ Local Authorities/ b) Sports Clubs, andfacilities/ Health Clubs, Hostels and Local Self-Government bodies, such as Municipalities, facilities / Gymnasium / Swimming Pools attached to ZillaParishads, PanchayatSamitis, Gram Panchayats; Police such Educational Institutions / Health Care facilities, Stations and Police Chowkies; Post Offices; Armed provided that they are situated in the same premises Forces/Defence and Para-Military establishments; and are meant primarily for their students / faculty/ d) Service-oriented Spiritual Organisations; employees/ patients; MSEDCL January 20 349 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Sr. No . Existing Applicability e) f) g) h) 9. Proposed Applicability State or Municipal/Local Authority Transport establishments, including their Workshops; Fire Service Stations; Jails, Prisons; Courts. Airports Ports and Jetties HT (X): Electrical Vehicle (EV) Charging Stations c) all offices of Government and Municipal/ Local Authorities/ Local Self-Government bodies, such as Municipalities, ZillaParishads, PanchayatSamitis, Gram Panchayats; Police Stations and Police Chowkies; Post Offices; Armed Forces/Defence and Para-Military establishments; Administrative offices of MSEDCL/MSETCL & MSPGCL; d) Service-oriented Spiritual Organisations; e) State or Municipal/Local Authority Transport establishments, including their Workshops; f) Water ATM (RO/UV/UF Water Purifier Plants) of Local bodies; g) Fire Service Stations; Jails, Prisons; Courts. h) Airports i) Ports and Jetties HT (X): Electrical Vehicle (EV) Charging Stations Applicability: Applicability: This Tariff category is applicable for Electric Vehicle Charging This Tariff category is applicable for Electric Vehicle Charging Station. Station. MSEDCL January 20 350 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Sr. No . Existing Applicability Proposed Applicability In case the consumer uses the electricity supply for charging his own In case the consumer uses the electricity supply for charging electric vehicle at his premises, the tariff applicable shall be as per his own electric vehicle at his premises, the tariff applicable the category of such premises. shall be as per the category of such premises. Electricity consumption for other facilities at Charging Station such as Electricity consumption for other facilities at Charging Station restaurant, rest rooms, convenience stores, etc., shall be charged at such as restaurant, rest rooms, convenience stores, etc., shall tariff applicable to Commercial Category. be charged at tariff applicable to Commercial Category. MSEDCL January 20 351 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 16 DETAILS OF CAPEX SCHEMES 16.1 INFRA-II Scheme 16.1.1 Infrastructure Plan Part II scheme is formulated for enhancing and upgrading the Infrastructure so as to enable MSEDCL to cater increasing demand for releasing New connections under Residential, Commercial, Industrial and Agriculture categories and Renovation/Modernization (R&M) works to be taken up during the period 2013-14 to FY 2015-16. While formulating the scheme, expected load Growth up to 2015-16 has been considered. 16.1.2 Infra Plan “Part II” Scheme is prepared keeping in view the following Objectives: Releasing New Connections - R, C, I as well as to clear all the Agriculture Paid Pending Connections and prospective demand. Up-gradation of existing system Meeting Load Growth Providing reliable & quality supply Reducing AT&C Loss Reduction in DTC Failure Rates. 16.2 INFRA PART II Scheme in 7 Towns 16.2.1 As the Distribution losses are below 15% in Pune, Kolhapur, Panvel & Navi Mumbai (16 divisions), Nashik, Sinnar and Ozar towns were excluded from the R-APDRP Part-B works. To cope with the growing demand and to release the new Residential, Commercial, Industrial and other connections upto 2015-16, it is necessary to implement INFRA Part- II Scheme in these towns for development of Infrastructure. 16.2.2 Scope and progress of works: The tenders for Infra II were awarded from September 2013 to October 2015 in phased manner. MSEDCL January 20 352 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Progress of Infra II & Infra Part II Scheme in 7 towns is as follows (as on 31.10.2019): Freezed Completed Sr. No. Particulars Unit WIP Scope works 1 New Sub Stations + Switching No. 512 512 0 Stations 2 Addl. Power Transformers No. 213 213 0 3 Augmentation of Power No. 327 327 0 Transformers 4 New Distribution No. 37040 37040 0 Transformers 5 Augmentation of Distribution No. 14825 14825 0 Transformers 6 HT Line (O/H + U/G ) Km. 24439 24439 0 7 LT Line (O/H + U/G ) Km. 20729 20729 0 16.2.3 Physical works completed in FY 18-19 but capitalization is delayed due financial closure of scheme. 16.3 Feeder Separation Scheme 16.3.1 For giving 24 x 7 power supply to villages (Gaothan) feeder segregation work has been taken in past under 'Gaothan Feeder Separation Scheme' (GFSS). Total 5398 No. of feeders have been separated under GFSS & Infra Plan Schemes. 16.3.2 Benefits of the feeder separation Scheme are as below: There will be control on Ag. Consumption. There will be reduction in distribution loss. Energy audit of Ag. consumers will be correct resulting in proper Ag. Index. The feeling of discrimination in non-Ag. consumers will cease. The system will be strengthened. The demand in peak hours will be regulated. Feeder segregation will help in achieving 24x7 power for all non-Ag. consumers covered by these feeders and all Ag. consumers will get better regulated reliable power supply. MSEDCL January 20 353 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 16.3.3 However, some of the feeders are yet not segregated and some of the villages & habitations are not yet covered by the segregated feeders. These nonsegregated feeders are of mix and single phasing type. Out of these feeders, segregation of 690 feeders is being carried out in 'Deendayal Upadhyay Gram Jyoti Yojana'. Segregation of remaining 4330 Mix / Single Phasing feeders is balance. 16.3.4 The proposal for estimated cost of Rs. 2665 Crores is prepared for segregation of remaining Mix / Single Phasing feeders. MSEDCL has requested the GoM for the grant of Rs. 2665 Crores for this project. Further, as per assurance of Hon. MoS MoP, GoI, MSEDCL has requested Hon. MoP, GoI to provide funds of atleast Rs. 1000 Crores for this Scheme. 16.3.5 In this connection, the GoI has instructed to review the progress of DDUGJY and Saubhagya regularly so as to achieve the milestones and to get benefit of additional grant as envisaged in the Schemes. 16.3.6 In the meantime, M/s. REC approached MSEDCL and showed readiness for preparation of 'Detailed Project Report' (DPR) for the said feeder separation work. Accordingly, MERC has appointed an Agency for survey and preparation of DPRs. 16.3.7 Total projected cost of feeder separation for 2647 no. of feeders is approx. Rs. 2730 Cr. DPRs for 19 circles are prepared for Rs. 1314 Cr. Also, DPRs for remaining 11 circles are under preparation with approx. cost of Rs. 1416 Cr. 16.3.8 The DPRs for 11 Circles as detailed below were submitted to MERC. The MERC has accorded In-Principle approval for DPR amount of Rs. 535.19 Cr. as detailed below: Sr. No. Name of District 1 Buldhana 27 18.81 2 Ahmednagar 84 68.60 3 Chandrapur 65 81.97 MSEDCL Proposed No. of feeders Amount for separation (Rs. Cr.) January 20 354 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Sr. No. Name of District 4 Nagpur 98 87.74 5 Jalgaon 101 69.34 6 Gondia 38 45.60 7 Bhandara 29 30.32 8 Baramati 139 103.47 9 Satara 22 22.01 10 Kolhapur 3 4.59 11 Sangli 3 2.74 609 535.19 Total Proposed No. of feeders Amount for separation (Rs. Cr.) 16.3.9 Also, M/s REC Ltd. has sanctioned loan amounting to the tune of 80% of the project cost for feeder separation work in 11 Circles as detailed above. The tenderization process for execution above works is in progress. Preparation and finalization of DPR’s are in progress for remaining District viz: Osmanabad, Hingoli, Dhule, Yavatmal, Washim, Aurangabad, Jalna, Amravati, Solapur, Parbhani, Beed, Latur, Wardha, Nashik (Nashik (U) + Malegaon circle), Akola, Pune. Considering the huge cost involved in the project, it would not be possible for MSEDCL to raise such a large amount through loan. In view of above, the request letter dtd. 08.08.2019 has been submitted to M/s REC Ltd. for considering the feeder separation work as an extension of DDUGJY and extend full grant of 60% as per DDUGJY Scheme guidelines. 16.4 R-APDRP Scheme 16.4.1 GOI has initiated a scheme named “R-APDRP” to focus on establishment of baseline data and fixation of accountability and reduction of AT & C losses through strengthening & upgradation of sub-transmission and distribution network and adoption of Information Technology during XI Plan. MSEDCL January 20 355 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 16.4.2 R-APDRP scheme includes following: Urban areas- Towns and cities with population of more than 30,000 are covered under the scheme. Project is taken up in Two parts Part 'A’ and Part 'B’, Part A includes the projects for establishment of Base Line Data and IT applications for energy Accounting /Auditing and IT Based Consumer Service centres. Part B includes regular distribution strengthening and augmentation projects to reduce AT&C Losses upto 15%. 16.4.3 Funding Mechanism: Initially GOI will provide 100% Loan for Part A and 25% loan for Part B projects on the terms decided by Ministry of Finance. The Loan of Part A is converted into grant once establishment of the required system is achieved; The balance funds (75 %) for Part B projects shall be raised from financial institutions. The entire loan from GoI is routed through financial institutions for the respective schemes funded by them. 16.4.4 Conversion of loan into Grant Part A: The loan shall be converted into grant once the establishment of the required system is achieved and verified by the independent agencies. The interest on the converted Loan shall be capitalized. No conversion to grant will be made in case Part A is not completed within 5 years from the date of sanctioning of the project/ till the period extended by PFC. PFC has extended the period of completion of R-APDRP Part A till March -2017 Part B: Up to 50% loan of Part-B projects shall be converted into grant in five equal tranches on achieving the 15% AT&C loss in the project area on a sustainable basis for a period of five years. If the utility fails to achieve or sustain the 15% AT&C loss target in a particular year, that year’s trench of conversion of loan to grant will be reduced in proportion to the shortfall in achieving 15% AT&C loss target from the starting AT&C loss figure. PFC has extended the RAPDRP Part B till March -18. MSEDCL January 20 356 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 16.4.5 Progress of works: A) Achievements of R-APDRP Part A: a) 128 Towns with population more than 30, 000 (Census 2001) selected for Implementation of R-APDRP Part A. b) Loan amounting to Rs 315 Crs for 128 towns is sanctioned by PFC on 19.03.2010. The sanctioned amount is revised to Rs 260.09 Crs on 30.01.2017. c) All 128 towns Declared as go-Live as on Oct’14. d) After declaration of Go live of towns the TPIA (M/s PWC Ltd) appointed by PFC has started their work in April -2015. The verification is completed. The reports submitted by TPIEA for successful completion of the scheme is accepted by PFC in the month of Oct – 16. e) The Expenditure of R-APDRP Part A is Rs 226 Crs. f) B) Achievements of R-APDRP Part B: a) The Expenditure of RAPDRP Part B is Rs 2234.97 Crs b) The achievements are as given below: Sr. No Activities Unit Scope Achievement 1 New Sub-stations Nos 135 135 2 Aug Of Power Transformers Nos 29 29 3 Add of Power Transformers Nos 35 35 4 New Distribution Transformers Nos 5823 5823 HVDS 5 Aug of Dist. Transformer Nos 3624 3624 C) All 120 Towns are declared as completed and financially closed. 16.5 SCADA Part A 16.5.1 SCADA is implemented in 8 towns of MSEDCL. The towns with population more than 4 lakhs and Annual Input energy more than 350 MU are selected for SCADA implementation amounting to Rs. 117 Crs. The eligible towns are Amravati, Malegaon, Sangli, Solapur and Greater Mumbai for SCADA and DMS, and Pune, Nashik and Kolhapur for Only substation SCADA. 16.5.2 The SCADA Part A Includes the following scope of work: MSEDCL January 20 357 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition a) b) c) d) Establishment of SCADA/DMS control centre in eight specified towns. Integration with IT system being implemented under R-APDRP Part-A Establishment of Data Recovery Center at Nagpur Supply, installation, integration and commissioning of RTUs at all 66/33/22/11kV S/S e) FRTUs at locations of RMUs on 11kV Distribution networks etc. f) SCADA/DMS system for control and supervision of 33/11kV S/S and 33KV & 11kV feeders 16.5.3 The Achievements of SCADA Part A are as below: Sr. No Activity Scope 1 SCADA Control center 8 2 RTU 268 3 FRTU 1653 Installed 8 268 1653 a) All 8 towns are completed as on March 2018 b) The third party verification by the Agency appointed by PFC is completed and the reports are accepted by PFC. c) The Expenditure of SCADA (Part A) as on 30.09.2019 is Rs. 72 Crs. 16.6 SCADA Part B 16.6.1 PFC has sanctioned 8 towns for SCADA enabling works amounting to Rs 189 crs. The Towns sanctioned by PFC are Greater Mumbai, Amravati, Solapur, Sangli, Malegaon, Pune, Nashik and Kolhapur. 16.6.2 The SCADA Part B Includes the following scope of work: Installation of equipment required for automation such as Ring Main Units, numerical Relays for the Protection of 11 KV feeders, Capacitors and incomers, Automatic Voltage regulators, winding Temperature Indicator and Oil Temperature Indicator for Power Transformers etc. 16.6.3 The Achievements of SCADA Part B are as below: MSEDCL January 20 358 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Sr No 1 2 3 Activity Scope 1370 3808 403 RMU Numerical Relay WTI/OTI Installed 1370 3310 403 16.6.4 The scheme is financially closed as on 31st March 2018 16.6.5 The Expenditure of SCADA (Part B) as on is Rs. 136 Crs 16.7 Integrated Power Development Scheme (IPDS-I) 16.7.1 Government of India has launched Integrated Power Development Scheme (IPDS) for urban area (Statutory Towns) only. The existing scheme of RAPDRP is subsumed in this new IPDS scheme. 16.7.2 Objectives of IPDS: 24x7 Hrs Power supply for consumers. Strengthening of electrical distribution network. Reduction of AT&C Losses. 16.7.3 Provision of funds: 60% Grant Central Government. 10% Utility/ State Government 30% Loan from FIs/ Banks Additional grant of 50% of loan component i.e. 15% will be released subject to achievement of milestones. 16.7.4 The DPRs have been prepared as per the guidelines of IPDS and in consultation with Local MP’s. Government of India has approved the Project cost of Rs 2300.43 Crs for IPDS under MSEDCL on 16.03.2016. The works under this scheme is being executed on Full Turnkey Contract basis. The tenders of the same have been floated at HO and Zonal level. 16.7.5 Current Status of the scheme is provided below: MSEDCL January 20 359 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Activity Total New Substation (Nos.) Power Transformer Augmentation (Nos.) Additional Transformer (Nos.) New DTC (Nos.) Augmentation of DTC (Nos.) HT + LT Line (KMs.) 122 Completed/ Commissioned 97 57 55 2 29 4871 3710 9885 26 3786 3381 5507 3 366 15 405 WIP 22 16.7.6 The works in 25 Circles have been completed 16.7.7 The R.I charges of Rs. 900 Crs have been considered for works of underground cabling. 16.7.8 MERC has accorded in principle approval for IPDS scheme in MSEDCL amounting to Rs 2300.43 Crs on dt 10/2/2016. New approved schemes by Ministry of Power, Government of India under IPDS 16.7.9 IT Phase – II under IPDS 124 towns with population more than 15000 selected for implementation of IT – Phase II. The works under the scheme include supply and installation of IT Infra material at Towns, DC (Data Centre) and DR (Data recovery centre) up gradation. 1) The sanctioned cost of the scheme is Rs 94.79 Crs against the DPR cost of Rs 134.56 Crs 2) The following works are included under the scheme IT infra material in all 124 towns GIS Mapping of HT lines and DTC Installation of Feeder Meters , Boundary Meters and Meters to HT consumers and modems at these locations Up gradation of DC ( Data Centre) and DR ( Data recovery centre) 3) Current status of the scheme MSEDCL January 20 360 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition LOA for all the activities awarded and Work is in progress IT Phase – II Scheme is targeted to be completed by January 2020 16.7.10 ERP (Enterprise Resource Planning) DPR 1) The sanctioned cost of the scheme is Rs 40.86 Crs 2) The works sanctioned are targeted to be completed by August 2020 16.7.11 Smart Meter DPR 1) 10 towns viz Kannad, Paithan, Sillod, Vaijapur, Anjangaon, Daryapur, Jalna, Dahanu, Nalasopara and Kamptee are selected for implementation of smart metering. 2) The scope includes installation of 4 Lakhs smart meters. 3) The sanctioned cost is Rs 80 Crs against the DPR cost of Rs 166.16 Crs 4) Tenderisation is in process 5) The works sanctioned under the scheme are targeted to be completed by 18.01.2021 16.8 Deen Dayal Upadhyay Gram Jyoti Yojana (DDUGJY) 16.8.1 Government of India (GoI) has launched an ambitious program of “Deen Dayal Upadhyay Gram Jyoti Yojana” (DDUGJY) in December 2014. The scheme is being implemented 33 Districts (37 Circles) of Maharashtra State. 16.8.2 Objectives of DDUGJY scheme: Giving regulated Power Supply to Ag. Consumers, Continuous Power Supply (24X 7) for non-agriculture consumers Strengthening and augmentation of Distribution networks. Metering at various level for proper Energy accounting. Reduction of AT & C Losses. Subsuming RGGVY in DDUGJY and carry forward the approved outlay for RGGVY to DDUGJY 16.8.3 The work completion period for the scheme is 1/ 1.5 years from the date of issue of LoAs. Due to poor response to the tenders for DDUGJY & higher rates quoted by the agencies, the process of awarding LoA was delayed. Hence there MSEDCL January 20 361 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition is deviation in projections which was already provided by this section. 16.8.4 Now LoAs for all the Districts/ Circle in Maharashtra State have been awarded & work proposed under the scheme is in progress. Progress of Deen Dayal Upadhyay Gram Jyoti Yojana is as follows (as on 31.10.2019): Completed/ Activity Total WIP Commissioned New Substation (Nos.) 213 175 33 Augmentation (Nos.) 55 55 0 Additional Transformer (Nos.) 45 45 0 New DTC (Nos.) 9207 6217 532 Augmentation of DTC (Nos.) 348 292 0 HT + LT Line (KMs.) 21223 14705 1453 16.9 SAP ERP Project 16.9.1 Introduction a) MSEDCL has implemented integrated SAP ERP (Enterprise Resource Planning) solution for its core functions for improvement in operation efficiencies with respect to the finance, project functions and integrating with existing systems viz. Billing, HRMS etc. b) The scope of work of this project primarily consists of: Providing and installing ERP package and related software licenses; Implementation of ERP, Project Management and control; Integration with ancillary modules, R-APDRP Applications, SCADA under development in R-APDRP Part-A & other systems; Revamping/Upgrading of existing Billing System to n-tier architecture and integrating with proposed ERP; Enhancement and maintenance of ancillary modules; Development of custom application and its maintenance. c) ERP project cost to provide ERP solution as above is Rs. 51.13 crores, which includes support for 3 years after completion of the project. d) The scope of LOA “Supply, Installation, Commissioning and Maintenance of MSEDCL January 20 362 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Hardware for ERP implementation solution in MSEDCL” primarily consist of: Procurement, Commissioning, Integration, Maintenance and Management of New Servers, Laptops and other hardware and software in DC and DR. Comprehensive Warranty of Hardware and software for 5 years from date of commissioning and Final acceptance. Implementation of DC-DR replication Two Factor Authentication for VPN users with Authentication manager at DC and DR Application Performance Monitoring tool Up-gradation of existing mail server application 16.9.2 Objectives: The existing Financial Accounting System was standalone system and needs to be re-engineered to a latest platform. It was also required to integrate the new system to all the existing system. Further, the existing billing system is distributed and client server architecture based. It was required to re-engineer this system to N tier architecture. Further for the management of different projects running at MSEDCL like Infra, RGGVY, GFSS, R-APDRP etc., an off the shelf project management tool was required. This tool helps in managing and monitoring the projects. There was need to keep track of all the materials in stock and accordingly manage the procurement activity. This implementation helps MSEDCL in achieving following objectives in mind: Enable MSEDCL to improve operational and financial efficiencies; Reduces the workload pressure and provides accurate, timely information for taking appropriate business decisions; Adopt best practices, standardization and automate many of the business activities. 16.9.3 Benefits: Provide real time, on-line information and MIS for fast, efficient decision making at the highest levels; Centralized Data storage and real-time availability of information; MSEDCL January 20 363 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition No duplication of data at enterprise level; Online workflows and approvals; Plant Maintenance operates the overall maintenance business processes and functions of MSEDCL. It helps to keep track of breakdown and preventative maintenance activity of equipment; FICO module enables to centrally track financial accounting data and crossfunctional integration with other SAP modules helps to generate financial statement and balance sheet at ease; IT solution for Project Execution and Management enables users and managers to execute and monitor the projects effectively; Material Management speeds up the procurement and material management activities making the business run smoother with complete time and cost efficiency; Revamp the existing 2 tier billing system to ‘n’ tier architecture, this help the billing system online and ensure faster access to MIS reporting. The billing solution would be centralized to ensure lowest total cost of ownership; 16.9.4 Scheme Approval MERC scheme code: MSEDCL/FY11/21 MERC In Principle Clearance Reference No. MERC/CAPEX/2010/2011/02588 dated 31.03.2011 In Principal Approved Cost Rs in Crs : Rs. 91.00 Crores. and Dt: 16.10 DC/DR IT Infra Up-Gradation – I 16.10.1 Scope: Upgradation of existing 3PAR SAN Storage space at both DC & DR and procurement of SAN switch at both DC & DR Upgradation of Processor & RAM of existing BL870 Servers at DC & DR Upgradation cum Procurement of High Performance Servers Supply & installation of Latest Oracle Ebiz Suite to Servers and Applications and data migration of existing HRMS, Payroll, etc modules to new environment (including migration of existing oracle database instances to latest enterprise edition release) along with successful DC-DR replication. MSEDCL January 20 364 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition The successful integration of migrated modules as per pre-migration scenario. Comprehensive Training of Oracle Ebiz Suite & migration activities to MSEDCL staff. 16.10.2 Supply and Installation of Window Servers. Up-gradation cum Procurement of SAP Hana Appliance & HANA Software Licenses by 256GB with one-year support Successful Integration of new & upgraded servers, storage and other hardware with existing infrastructure. Objective: MSEDCL’s Data Center at Prakashganga, BKC, Mumbai hosts various enterprise level applications like Website, Online Bill Payment, E-Tendering, HRMS, Payroll, Data Warehouse, Mobile Apps, ERP etc. Similar configuration exists at Disaster Recovery Center at Nagpur with continuous replication of data of Data Centre via point to point leased lines. Objective is to upgrade few of the IT Infrastructure components at Data Center & Disaster Recovery Center to meet the current requirements of MSEDCL. 16.10.3 Benefits There is no direct tangible cost benefit, the up- gradation of existing infrastructure is essential to run the existing critical applications smoothly. Also, the proposed new solution will give the following benefits: 16.10.4 Strengthen the availability and responsiveness of existing online applications by having appropriate hardware & software resources. Strengthen agility, scalability, multi-tenancy, governance of its IT infrastructure and maintain these for a foreseeable future. Utilization of the modem technologies evolved in Servers, Storage and software to improve the scalability, availability, maintainability & performance of IT based systems. Scheme Approval MERC In Principle Clearance Reference No. and Dt : MERC/CAPEX/201718/3971 dt. 21.07.2017, Approved Cost Rs in Cr: Rs. 17.59 Crores. MSEDCL January 20 365 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 16.11 DPDC/Non-Tribal 16.11.1 Release of residential, agriculture, street light, public water works connections & infrastructure (H.T. line, L.T. line, DTC etc.) development are the main works carried out under this plan. 16.11.2 As per Government Resolution No. Sankirna-2013/ Pra. Kra. 189/ Energy -5 Dt. 30.12.2013, funds under this plan are released as grant to MSEDCL from the year 2013-14. 16.11.3 The GoM has sanctioned Outlay of Rs. 187.26 Crs for year 2017-18 & Rs. 232.07 Crs for year 2018-19 under General Plan (Non-Tribal) For FY 2017-18 and FY 2018-19 works carried out till Sep 19 under this plan is as below: FY 2017-18 FY 2018-19 Particulars Target Achievement Target Achievement Residential Connection 14860 10783 9102 5075 Funds Sanctioned (Rs. Rs. 187.26 crs Rs. 232.07 in crs) Expenditure (Rs. in crs) Rs. 182.32 crs. Rs. 139.37 16.11.4 Projected Expenditure & physical target under General Plan for FY 1920 is as below: Particulars 2019-20 Fund (Rs. In crs) 261.55 Agriculture Pump Set Connection 230 Residential Connection 10900 Physical DTC 3100 Targets HT Line 1600 LT Line 4000 MSEDCL January 20 366 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 16.12 DPDC/Special Component Plan 16.12.1 Release of residential connections & Ag. connections to Scheduled Caste & Nav-Buddha beneficiaries & release of street light connections in dalit basti are the main works carried out under this plan. 16.12.2 As per Government Resolution No. Sankirna-2013/ Pra. Kra. 189/ Energy -5 Dt. 30.12.2013, funds under this plan are released as grant to MSEDCL from the year 2013-14. 16.12.3 The GoM has sanctioned Outlay of Rs. 117.10 Crs. for FY 2017-18 and Rs. 113.66 for FY 2018-19 under Special Component Plan and works carried out till Sep 19 under this plan is as below- Particulars Special Action Plan (FY 2017-18) Target Achievement Agriculture Pump 3900 2253 Set Connection Physical Residential 2941 2343 Targets Connection Street Light 3796 2921 electrification Funds Sanctioned (Rs. in Rs. 117.10 Cr. Crs) Expenditure (Rs. in Crs) Rs. 116.52 Cr. Special Action Plan (FY 2018-19) Target Achievement 2621 537 3809 1180 2401 1413 Rs. 113.66 Cr. Rs. 56.42 Cr. 16.12.4 Projected Expenditure & physical target under General Plan for FY 1920 is as below: Particulars Fund (Rs. In crs) Physical Agriculture Pump Set Connection MSEDCL January 20 2019-20 134.47 3100 367 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Targets Residential Connection Dalit Basti Street Light DTC HT Line LT Line 4500 2900 2800 1435 1300 16.13 DPDC/TSP+OTSP (District Wise) 16.13.1 This scheme is executed in area notified as Tribal Sub-Plan (TSP) area as well as other than Tribal Sub Plan (OTSP) area. In this scheme, out of total allocation, 85% allocation is utilized for Tribal beneficiary living in TSP area and balance for Tribal beneficiary living in OTSP area. 16.13.2 The fund is received from GOM under DPDC (TSP + OTSP) Scheme as a 100% grant. The fund sanctioned under this scheme should be obtained from concern District Collector. 16.13.3 The works included under this scheme is mainly to release Ag. connections, L&F Connection to tribal beneficiaries and to electrify unelectrified tribal Wadi / Pada. 16.13.4 The budget provision for FY 2017-18, for area under TSP is Rs. 91.85 Crs. & for OTSP is Rs. 11.95 Crs. The budget provision for FY 2018-19, for area under TSP is Rs. 93.28 Crs. & for OTSP is Rs. 11.05 Crs The works to be done under this scheme & progress of work upto Sep 2019 are as under: TSP FY 2017-18 Description Physical Target Ag. pump energisation L&F connection MSEDCL Target OTSP FY 2017-18 Achievement Target Achievement 2904 1046 324 199 3076 2906 1059 983 January 20 368 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Wadi/Pada Electrification 193 Sanctioned Outlay Expenditure 16 Rs. 91.85 Cr. Rs. 87.54 Cr. Target Ag. pump energisation L&F connection Wadi/Pada Electrification Sanctioned Outlay Expenditure 16 Rs. 11.95 Cr. Rs. 11.95 Cr. TSP FY 2018-19 Description Physical Target 160 OTSP FY 2018-19 Achievement Target Achievement 423 82 160 13 2153 256 760 247 103 63 - - Rs. 93.28 Cr. Rs. 35.55 Cr. Rs. 11.05 Cr. Rs. 4.08 Cr. 16.13.5 Projected Expenditure & physical target under TSP & OTSP for FY 1920 is as below: 2019-20 Particulars TSP OTSP Fund (Rs. In crs) Physical Targets MSEDCL 99.48 19.68 Agriculture pump energisation Residential Connection Wadi/Pada Electrification 500 190 2000 120 900 10 HT line 750 140 LT Line 1300 120 DTC 1100 250 January 20 369 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 16.14 Backlog Removal Scheme 16.14.1 The GOM is making provision of funds to the Mahavitaran Co. for the removal of District wise Backlog of Ag pumps energisation declared by The Backlog & Indicator Committee set up by Govt. of Maharashtra in March 1996 as per the Hon. Governor, Maharashtra State, directives issued since FY 200506 regarding removal of the Regional Imbalance of Agricultural Pump Sets. Presently, in the five districts namely Thane, Raigad, Ratnagiri, Chandrapur and Gadchiroli, the work of energisation of agricultural pumps is being carried out through the Backlog Scheme. 16.14.2 The Target of 2500 nos. of Ag pumps energisation under Backlog Scheme has been set for the year 2017-18 and for that the GoM has sanctioned Rs. 39.30 Crs. under Backlog Scheme. Similarly for FY 2018-19, target of 2500 nos. of Ag pumps energisation under Backlog Scheme has been set and for that the GoM has sanctioned Rs. 40 Crs. under Backlog Scheme. MSEDCL has carried out work of electrification of 1330 nos. of Ag. Pumps & Expenditure incurred is Rs. 65.07 Crs. up to Mar-2018 and work of electrification of 510 nos. of Ag. Pumps & Expenditure incurred is Rs. 13.80 Crs. up to Mar-2019. 16.15 AG Special Package for Vidarbha & Marathwada 16.15.1 AG Special Package I:- As compared to the Rest of Maharashtra, there was imbalance of Ag. Pump energisation in Vidarbha & Marathwada. To remove the imbalance of Ag. Pump energisation in Vidarbha & Marathwada the GoM made the provision of fund of Rs. 819 Cr. under Special Package for FY 2015-16 for energisation of 99054 nos. of Ag. paid pending as on March 2015 in Vidarbha & Marathwada. 95167 nos. of Ag. Pumps are energized during FY 2015-16 to FY 2018-19 under this scheme. 16.15.2 AG Special Package II:- For the FY 2016-17, the GoM made the provision of fund of Rs. 916.20 Cr. under Special Package for energisation of 94462 nos. of Ag pumps. 79889 nos. of Ag. pumps energized during FY 201617 to FY 2018-19 under this scheme. 16.15.3 During FY 2017-18, under special package scheme, 27099 nos. of Ag. MSEDCL January 20 370 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition pumps energized. During FY 2018-19, under special package scheme 27340 nos. of Ag. pumps energized. Particulars Financial Achievement (Rs. In Cr.) Physical Achievement (in Nos.) 2015-16 481.22 65900 2016-17 594.35 54717 2017-18 343.29 27099 2018-19 310.85 27340 16.16 Saubhagya Scheme 16.16.1 Govt. of India has launched ‘Pradhan Mantri Sahaj Bijli Har Ghar Yojana “Saubhagya”, on September 25, 2017. 16.16.2 Objectives of Saubhagya Scheme: Providing last mile connectivity and electricity connections to all unelectrified households in rural areas. Providing Solar Photo Voltaic (SPV) based standalone systems for unelectrified households located in remote and inaccessible villages/Habitations where Grid extension is not feasible or cost effective. Providing last mile connectivity and electricity connections to all remaining economically poor un-electrified households in urban areas. 16.16.3 Provision of Funds: 60% Grant Central Government. 10% Utility/ State Government 30% Loan from FIs/ Banks Additional grant (50% of loan component i.e. 5% for special category states and 15% for other states) under the scheme will be released subject to achievement of 100% household electrification of all willing households by 31st December, 2018. 16.16.4 Sanctioned & Utilized Funds Details: 16.16.5 Total amount of Rs. 774.8 Crs. (Rs. 405.88 Crs. + Rs. 368.92 Crs.) is sanctioned against the total DPR amount of Rs. 1945.212 Crs. under Saubhagya Scheme for Maharashtra State. Household Electrification as per Saubhagya Dashboard: MSEDCL January 20 371 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Maharashtra has completed the 100% electrification total 10,93,614 nos. of connections are released i.e. up to 27.12.2018, as per the Saubhagya Dashboard. Fortnightly progress report (till 31th December-2018) is submitted to REC/MoP. As on 31.03.2019 15,17,922 households are electrified after 10.10.2017 and achieved 100% electrification in Maharashtra State. 16.17 Providing and Fixing of Energy Metering Arrangement At 33kv & 22kv Incoming Feeders at 33/11kv Substations & 22kv Switching Stations. 16.17.1 In order to have proper energy accounting, energy metering is very essential. Since at present at many locations it is observed that there is no metering provided at incoming feeder to 33/11kV Substation and Switching Stations. 16.17.2 In order to provide the metering to incoming feeders, the administrative approval in the matter was granted as per Board Resolution no 1714 dt: 22.04.2019 for providing and fixing of Energy Metering arrangement to Incomer feeders having DPR cost of 30.10 Crs. 16.17.3 The details of scheme is as follows: Scope of Work: - Supply and fixing Metering arrangement at 897 nos of Incoming feeders. Approximate Cost: - Rs 30.10Crs. Funding Arrangement: REC have approved the 80% of Approximate cost i.e 24.08 Crs. vide ref no REC/MUM/MSEDCL/116-SI/322 dt:02.08.2019. However, as per site requirement and due to change cost data the number of metering locations have been modified to 765 nos from 897 nos as DPR for 30.10Crs was already approved by Board. Hon. MERC have granted in-principle approval, in which it is mention that MSEDCL shall carry out balance 132 nos of metering through internal funds and necessary ARR shall be conveyed in MTR petition. The proposal for carrying out these balance work by obtaining fund through loan from MSEDCL January 20 372 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition REC/internal fund. The approximate cost for the balance work will be about 810 Crs approx. Status of Scheme:- Tendering work is under progress. 16.18 HVDS Scheme 16.18.1 Approval of HVDS scheme: GoM and MSEDCL decided to release 224785 Ag paid pending connections as on date 31.03.2018. GoM of Maharashtra vide GR dt. 05.05.2018 has approved the scheme having a scheme cost of 5048.13 Crs. The regulatory authority viz. Maharashtra State Electricity Regulatory Commission (MERC) has in-principle approved the scheme. 16.18.2 Advantages of HVDS Reliable and uninterrupted Power Supply In the existing LVDS, due to lengthy LT lines and high current flowing through it, there is issue of low voltage at consumer end. The low voltage is causing frequent motor burnt out incidences. If HVDS system is implemented, the current flowing through the lines and associated equipment will be reduced by more than 25 times. This will result into improvement in the voltage resulting into reduction in failure of equipment like DTs, motors, breaking of conductors, etc. and hence substantial reduction in interruption of electric supply. Better voltage and less interruption will facilitate the reliability and quality of power supply to Ag. consumers. Further, there will be increase in the life of equipment, saving the maintenance cost of utility Reduction in electrical accidents: As the HT line is controlled by circuit breaker in the sub-station, the circuit breaker will trip whenever line conductor snaps on the ground, avoiding the electrical accidents due to live conductor. Reduction in distribution losses: As mentioned above, the current flowing through HT line in HVDS will reduce by more than 25 times in LVDS will result into reduction in the distribution losses. Further, in HVDS, theft of energy by hooking the lines, . MSEDCL January 20 373 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition as frequently observed in LVDS will be eliminated. This will result into further reduction in distribution losses. Reduction in DT fail: In HVDS, there will be only one or two Ag. consumers on one DT. Hence, the consumer will feel ownership of the DT, will take responsibility and will not allow any unauthorized connection on the DT. This will avoid overloading of DTs and hence, there will be substantial reduction in DT failure rate due to overloading of DTs, as observed in LVDS. Further, in the event of failure of DT, only one or two consumers will be affected as against 15-20 consumers in existing LVDS. Thus, it can be seen that by implementing HVDS, reliability and quality of power supply to Ag. Consumers in the state will be improved to great extent, thereby securing the stable energy supply and improving the efficiency of Ag. production as well as living standard of rural population in the state. 16.18.3 Tenderization Standard Bidding Documents (SBD) is prepared by HO for full turnkey and partial turnkey tenders. In case of full turnkey tenders circle wise tenders are floated by concerned chief engineers and in case of partial turnkey sub division wise and section wise tenders are floated by concerned circle office. E-Tendering process is adopted for all tenders. 16.18.4 Progress (As on 31 October,2019) No. of AG Paid Pending Connections 150399 DTC Commissioned Connections released 31243 31030 16.19 High Loss Feeder (HLF) Scheme 16.19.1 MSEDCL is implementing High Loss Feeder (HLF) scheme to bring down distribution losses in 259 high loss feeders (more than 50% losses). In MSEDCL January 20 374 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition the 1st Phase 185 feeders are chosen to be taken up in Financial Year 201819, 2019-20 with total capital cost of Rs 316.22 Crores to bring down distribution losses in 185 high loss feeders (more than 50% losses) under statutory towns. 16.19.2 The objectives of the scheme are: Introduce HVDS (High Voltage Distribution System) for reducing HT: LT ratio and providing AB (Aerial Bunched) cable to prevent theft and pilferage of electricity by hooking. To shift energy meters from consumers premises and providing multimeter boxes to outside to prevent tampering of energy meters. Replacement of faulty energy meters. To replace old, corroded and deteriorated LT conductor and providing AB switches and wedge connectors to reduce power supply interruptions and prevent accidents. 16.19.3 The funds for execution of the project are being arranged by availing loan from financial institutions. MERC has accorded in-principle approval to the scheme. 16.19.4 The following benefits are envisaged from the scheme: Increase in revenue and reduction in losses. Reduction of power supply interruptions and accidents. Improvement in reliability of power supply due to introduction of HVDS. Meeting Universal Supply Obligation. The turnkey tenders for execution of project are floated and work is in progress. Progress of High Loss Feeder Scheme Sr No. 1 2 3 4 Description Unit Scope Completed Installation /Replacement of Meters HVDS (New DTC) Conversion of LT Line to HT Line Provision of AB cable Nos. Nos. Kms. Kms. 208868 11234 296.15 3672.86 15991 77 0.24 90.4 MSEDCL January 20 375 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Shifting of meters from Inside to Outside consumers premises Installation of 1 Ph/ multi meter/ service box boxes 5 6 Nos. 276996 4549 Nos. 20630 6335 16.20 System Strengthening in Metropolitan Region (SSMR Scheme) 16.20.1 MSEDCL is implementing System Strengthening in Metropolitan Region (SSMR) -scheme in Financial Year 2018-19, 2019-20 & 2020-21 with total capital cost of Rs 438 Crores to strengthen existing distribution network and reduce power supply interruptions in high revenue pocket areas in Mumbai & Pune Metropolitan Region consisting of Bhandup, Kalyan & Pune Zones. 16.20.2 The objectives of the scheme are: Strengthening & Augmentation of existing distribution network. To reduce power supply interruptions in High Revenue pocket areas of Mumbai & Pune Metropolitan Regions. Replacement of existing feeder pillars with RMUs and providing RMUs at multiple locations for easier load diversion, fault isolation & minimizing interruption area. Laying of additional link lines for conversion of existing Radial network to Ring Mains. To replace old, corroded and deteriorated aging infrastructure like Electric Poles, Feeder Pillars, Conductors, etc to reduce frequent power supply interruptions. 16.20.3 The funds for execution of the project are being arranged by availing loan from financial institutions. MERC has accorded in-principle approval to the scheme vide letter No. MERC/CAPEX/2019-20/9170/, Date: 22-10-2019. 16.20.4 The following benefits are envisaged from the scheme: 24x7 reliable power supply to consumers in high revenue pocket areas. Reduction of power supply interruptions and breakdowns. Reducing overloading of existing network and meeting load of prospective consumers. MSEDCL January 20 376 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Meeting Universal Supply Obligation. 16.20.5 The full turnkey tenders for execution of project are floated and work is in progress. Sr No. Description Unit Scope Completed 1 Installation /Replacement of R.M.U Nos. 636 90 2 Augmentation/ conversion of Lines Kms. 733.43 4 3 New Lines Kms. 836.52 21.48 4 Replacement of Feeder Pillars Nos. 814 717 5 Replacement of Poles Nos. 3129 600 6 Replacement of DB Nos. 95 0 Provision/ Replacement of isolators/ 7 Nos. 361 25 AB switches/VCB 8 Replacement of Line accessories Lot 8605 1569 9 R&M of DTC Lot 793 53 Installation of multi meter/ service 10 Nos. 1847 0 box boxes 11 Others (R&M)- Guarding, etc Lot 8085.5 6 DTC New/ 12 Nos. 374 8 Augmentation/Conversion 13 Substation a Augmentation of Power Transformer Nos. 10 0 b Renovation of Existing Substation Lot 25 0 Establishment of New Substation / c Nos. 18 0 Switching station 16.21 GIS Survey 16.21.1 MSEDCL is an electricity distribution company having vast network of electrical assets spread over a large geographical area. A convenient and powerful way to collect, organizes, maintain and manage this physical asset data and display it on a geographic map (Geospatial Data) is through geographic information system (GIS). 16.21.2 MSEDCL has been requested by Ministry of Communications & IT (Govt. MSEDCL January 20 377 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition of India) to submit Geo-coordinate data (Latitude and Longitude) of existing poles in LT and HT network of entire distribution utility area; so that laying of Optic Fiber under National Optic Fiber Network (NOFN) project can be taken up. If enterprise-wide GIS data is available then such types of GIS information can be easily provided for large scale National/State wide initiatives. 16.21.3 Scope Under R-APDRP part ‘A’ Project, GIS Survey, Asset Mapping & Consumer Indexing of 128 R-APDRP towns was undertaken and a comprehensive GIS system has been established for R-APDRP areas. Total 755 nos. of Substations; 4143 nos. of Feeders; 65807 nos. of DTC; 9043846 LT Consumers and 8299 HT consumers are currently mapped in the GIS system. The GIS database is linked with other R-APDRP modules and is being used to fulfill various MSEDCL business requirements like New Connection, Technical feasibility, estimation, Customer Care, Energy Audit, etc. However, MSEDCL has not been able to utilize the full potential of the GIS system due to non-coverage of Non-APDRP Network in the GIS System. The location data of these non-covered network assets can be collected through manual survey by using newly developed MSEDCL Mobile App on GPS based Smartphone. In view of above, Competent Authority directed to get the Network Survey conducted using MSEDCL Mobile apps. 16.21.4 Vide Board Resolution no. 1027 dtd. 22-Sep-2017 Board approved GIS survey of entire MSEDCL HT Electric Network (approx. 3,22,788 Ckt Kms) and AG Consumers (approx. 40 lakh) with an estimate 17.51 Lakhs (excl. Taxes). 16.21.5 Total 6982.14 ckt kms of HT Lines (2.16 % of Total HT Lines) with total estimate of expenditure of Rs. 14.5 Lakh is considered under IPDS scheme where 60% grant will be applicable. 16.21.6 Benefits Following are the important usages of Enterprise wide GIS for Distribution Utility: a. Distribution Network Planning & augmentation MSEDCL January 20 378 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition b. c. d. e. f. g. h. i. VR Calculation/ Technical Feasibility Distribution Network Load flow Analysis Simulate Load Shifting Scenarios Base for implementing Outage Management System AT&C loss calculation for Consumers mapped in GIS DTC Load profile generation. Ready geo-coordinate data of Poles for Govt. NOFN(National Optic Fiber Network) Smart Grid & SCADA readiness. Projects like 16.21.7 Scheme Approval (a) MERC approved the total estimate of Rs. 31.48 Crs for Enterprise GIS survey of MSEDCL HT Electric Network and AG Consumers. (b) Vide Letter no. MERC/CAPEX/2018-19/045 dtd. 06-Feb-2019 MERC approved in principle clearance for DPR of MSEDCL for Survey and Asset mapping of 12 Zones of MSEDCL Electrical Network for Rs.14.43 Crs (c) Vide Letter no. MERC/CAPEX/2018-19/1112 dtd. 23-Jul-2018 MERC approved in principle clearance for DPR of MSEDCL for Survey and Asset mapping of 4 Zones of MSEDCL Electrical Network for Rs.16.08 Crs 16.22 Procurement of Modems For AMR 16.22.1 Scope: Supply, installation & Commissioning of modems: The agency has to supply, install & commission modems at various HT meters & feeder meters. Integration of modems with MSEDCL MDAS: Modems installed are configured in MSEDCL MDAS & meter data downloaded through modem is available in MSEDCL MDAS. Meter data such as billing parameters, event information and load survey data is downloaded through modem. 16.22.2 Objective: To achieve automatic meter reading (AMR) of all HT consumer meters & feeder meters avoiding any manual intervention. MSEDCL January 20 379 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 16.22.3 Benefits: 100% Accuracy of readings. No need to visit the consumer premise carrying Meter Reading Instrument (MRI) to take meter readings. Readings downloaded through modem can be seen online on MSEDCL MDAS. 16.22.4 Estimated Project cost: The total estimated cost for the project is Rs.8.34 Cr. 16.23 Network Bandwidth Service Providers for AMR & Other Projects (NBSP UMBRELLA) 16.23.1 Objectives & Scope: Previously, various each implementing agency implementing Automated Meter Reading (AMR) brought their own Network Bandwidth Service Providers (NBSP) with whom it has tripartite agreement with MSEDCL. One of the main reason behind modem reading failure (inactive cases) was low or no network connectivity of that specific NBSP. However, there is general observation that in areas where NBSP lacks presence of good cellular network for AMR purpose, other NBSP has strong presence in that area. In this scenario, MSEDCL introduced NBSP umbrella scheme where various Network Bandwidth Service Providers viz. M/s Vodafone Idea Ltd., M/s Bharti Airtel Ltd. & M/s BSNL are engaged for providing SIM based services as per agreed common rate and SIMs of different NBSP wise are requisitioned by field offices as per their requirements and network connectivity status which are dispatched centrally. Currently, MSEDCL is in process of awarding fresh LOAs to M/s Vodafone, M/s Airtel and M/s Reliance Jio for AMR & Other Projects (NBSP Umbrella) for a period of 3 years for all existing & new SIM cards along with backhaul leased lines, limited up to Rs.15.19 Crs for estimated SIM quantity of 1.85 MSEDCL January 20 380 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Lakhs. Expenditure towards SIM services should be considered as Capital Expenditure required for DSM implementation apart from other expenditure required for DSM & pass through in the ARR 16.24 Scheme for East Vidharbha (Shet-tale): 16.24.1 Objectives: 1) Providing electricity connections to paid pending Ag consumers and prospective Ag pumps on shet-tale constructed under 'Jalayukta Shiwar Scheme' of GoM so that farmers will be facilitate to use water in Shet tale during draught period. 2) Providing quality of power supply to Ag-consumers by strengthening of existing electrical networks & adding new infrastructure. 3) Enhancement in living standards of farmers by increasing Agriculture Production. 16.24.2 Funding: Estimated scheme cost works out to be Rs. 749.72 Crs. Out of which GoM has disbursed the grant of Rs. 350 Crs only. 16.25.3 Scope of Work (a) SI work such as Substation, HT line, LT line & DTC etc New Substation - 11 Nos Addl. Power Transformer - 07 Nos Aug. of Power Transformer - 14 Nos HT Line - 4320 Ckt-Km , LT Line - 1454 Ckt-Km., Addl. DTC - 1129 Nos (b) R&M work such as Replacement of Distribution Box, Cable, Breakers & Reearthing of DT etc. (c) Providing Ag connections to farmers in East Vidarbha Region, Ag Connection - 27000 Nos HT Line - 135 Ckt-Km , LT Line - 396.9 Ckt-Km. MSEDCL January 20 381 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition DTC - 270 Nos. 16.24.3 Approach (a) Remote and Naxlite prone five districts of east Vidarbh are identified by GoM. (b) Beneficiaries are identified according to no. of Ag paid pending as on March2016 and prospective Ag pumps on Shet-Tale. (c) Required infrastructure and funds for electrification of beneficiaries are estimated. (d) GoM .has sanctioned the funds for Strengthening, Renovation & Modernisation of existing electrical network and for electrification of beneficiaries. (e) Accordingly, tenders are floated at Circle level and work is carried out for the electrification of beneficiaries in the scheme. 16.25 Energy Command & Control Center 16.25.1 Overview Globally the power sector is witnessing key changes in terms of shift of focus towards green energy and sustainable growth and the smart grids evolving by integrating end-to-end, advanced communications infrastructure and information systems into the electric power system. The objective of the Smart Grid projects are to use advancements of information and communication technology to make the power grid more efficient, reliable, secure and resilient whilst avoiding costly investments in new centralized power generation capacity. One of the main features of the Intelligent Grid is an increased level of observation and control of a complex power system to facilitate distributed and renewable energy generation. This can only be achieved by an increased level of information sharing between the individual components and subsystems of the power system. Standardization plays a key role in providing the ability of information sharing which will be required to enable the development of new applications. An information & analytics driven grid can provide consumers near real-time information on their energy use, support pricing that reflects changes in supply and demand and enable the use of smart appliances and devices to help consumers exercise choices in terms of usage of energy. Utilities can better manage the grid in terms of increased visibility of the network, improved billing and realization efficiency, increased availability of grid and access of power to rural areas. MSEDCL January 20 382 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 16.25.2 Intent of the Project: Intent of the project is to select a Implementation Service Provider, ISP that can design the solution for the proposed Energy Command and Control Centre, implement the same along with its partners (if any) in a time bound manner and evaluate the outcome of the Project. The ISP will have sound knowledge of SCADA systems / IT applications / Communication Systems / Smart Meters and Power System. ISP will also provide the facility management for 5 years. 16.25.3 Benefits The proposed Energy Command and Control Centre (ECCC) will enable measurable improvements including: Power Portfolio Management Reliability and Performance Indices Network System behaviour and response to disturbances Energy Analytics – reduction in losses Optimization of asset utilization and operating efficiency of the electric power system Consumer satisfaction 16.25.4 Expected Functionalities a. The ECCC will aggregate various data feeds from systems & sensors and further process information out of these data feeds to provide interface /dashboards for generating alert and notifications in real time. b. The ECCC would also equip MSEDCL to respond quickly and effectively to emergency or disaster situation in distribution network through Standard Operating Procedures (SOPs) and step-by-step instructions. The ECCC shall support and strengthen coordination in response to incidents/emergencies/crisis situations. c. Single Dashboard for MSEDCL for AMI, SCADA, Substation Monitoring System, SLDC system, GIS etc visualized real time on geographical map of distribution network. This dashboard can be accessed via web application as well as mobile app. The various information that may be accessed from the system but not limited to are as below: i. Visual alerts generated by other sub-systems that is part of the MSEDCL January 20 383 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition overall distribution operations systems e.g. SCADA, AMI etc. ii. Information about AMI system performance iii. Access information from Substation Monitoring System iv. Integration with Load Dispatch Centres v. Demand (Load) forecasting vi. Power portfolio management d. Take action based on events generated by any Distribution operation systems. e. The system shall provide reporting & audit trail functionalities to track all the information and monitor operator interactions with the system and to impart necessary training to the users. 16.25.5 Project status: Tender with an approved estimate Rs. 20.55 Crs is floated on MSEDCL eTender Portal. 16.26 National Cyclone Risk Mitigation Project NCRMP is a Government of India Project funded by World Bank. Relief & Rehabilitation (R&R) Department, GOM is the State Project Implementing Unit (SPIU) for Maharashtra. NCRMP unit is set up under R&R Department World Bank is providing Rs. 200 Crores grant for implementation of this project. Government of Maharashtra is the State Project Implementing Agency (SPIU). This project will be implemented under MSEDCL supervision. 16.26.1 Objective: To reduce the vulnerability of coastal communities across India to cyclones and other hydro-meteorological hazards. NCRMP is to mitigate the effects of cyclone & other hazards in coastal areas. Conversion of Overhead network to Underground 16.26.2 Scope of work: MSEDCL January 20 384 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 22 kV GIS Switching substation at Alibag 33kV, 22kV, 11kV Network conversion of overhead line to underground. LT Network conversion to underground Installation of New/Augmentation of Distribution Transformer Details of Project and Cities where the project is being implemented. Description Alibag Ratnagiri Saatpati Tender Amount Rs. 80 Cr. Rs. 96 Cr. Rs. 16 Cr. Tender floating date 30.07.2018 30.01.2019 07.02.2019 Contractor Name M/s. Leena Powertech Engineers Pvt. Ltd. LoA Date Contract Value 13.06.2019 06.09.2019 06.09.2019 Rs. 89.53 Cr. Rs. 96.95 Cr. Rs. 17.28 Cr. 1.5 Year 1.5 Year 1 Year Duration of Contract Project Area Details Description Alibag Ratnagiri Saatpati Total area Coverage 7.9 sq km 50 sq km 2.86 sq km Total No. of consumer 15548 Nos 37336 Nos 6399 Nos Total 2011) 20743 Nos 76239 Nos 17032 Nos 22 kv HT Network U/G Cable 41.48 km --- --- 33 kv HT Network U/G Cable ---- 6.37 km --- 11 kv HT Network U/G Cable ---- 42.34 km 14.2 km 136.84 km 66.58 km 20.66 km 2.9 km --- ---- --- 233 Nos 34 Nos population (census LT Network U/G Cable AB cable Distribution Transformer 16.27 Mukhyamantri Sour Krishi Vahini Yojana (MSKVY) 16.27.1 MSEDCL is implementing Mukhyamantri Sour Krishi Vahini Yojana MSEDCL January 20 385 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition (MSKVY) announced by Govt. of Maharashtra vide G.R. 14.6.2017 by installing decentralized Grid connected solar power projects for giving day time power to farmers. 16.27.2 Vide GoM GR dated 17.03.2018 nominated MSEDCL as an implementing agency for the scheme. MSEDCL is implementing scheme by developing 0.3 to 10 MW solar projects in 5 KM area of AG dominated substations and directly connecting at 11 kV bus of AG dominated substation through private solar projects developers, EESL & MSPGCL. 16.27.3 The scheme has multiple benefits which are as under, Farmer will get good quality day time power supply. Reduced peak energy demand Increase in consumer satisfaction. Saving the transmission & distribution network losses due generation at distribution point. Environmentally benign. Reduce MSEDCL’s total power purchase cost. To fulfill the enormous RPO Targets. 16.27.4 Solar Projects Developed by EESL: i) The Scheme is being implemented in two phases viz. Phase-I of 200 MW and Phase-II of 300 MW through MoU route with Tariff of Rs. 3.00 per unit and projects are developed on spare substation or Govt. Land. The PPAs for these two projects are executed on 20.01.2018 & 30.10.2019 respectively. ii) Phase-I (200 MW) a) MSEDCL will make available spare substation land or Govt. Land for these decentralized solar projects. b) M/s EESL will execute these projects of 0.3 MW to 10 MW capacity on the land made available by MSEDCL. c) MERC has given in principal approval for this scheme vide Order dated 29.01.2019. MSEDCL January 20 386 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition d) The civil & evacuation work for these projects will be carried out by MSEDCL at its own cost and reimbursement will be given by Govt. of Maharashtra through Green cess fund. e) Phase-I of the project is under implementation and as on date total 64 nos of sites are commissioned having total capacity of 56.97 MW. f) These projects are to be executed within 13 months from handing over of sites by MSEDCL. g) All these projects are to be completed by March-2021. iii) Phase-II (300 MW) a) PPAs are signed and 0.3 to 10 MW projects are to be executed on Substation, Gram panchayat & Govt. lands. b) Site identification & survey is being carried out by M/s EESL. c) These projects are to be executed within 13 months from handing over of sites by MSEDCL. d) Target for completion of project is March 2021. 16.27.5 Solar Projects developed through Private Developers: a) MSEDCL has carried out competitive bidding for 2 to 10 MW solar projects in 5 KM area of AG dominated sub-stations connected at 11 kV Bus of the Sub Station for which land procurement, evacuation expenses etc. will be done by Project Developer. b) Total 235 MW projects capacity is contracted at tariff of Rs. 3.15 per unit. c) Target for completion of project is in FY 19-20. d) Further, Tendering is being done for developing such projects near AG dominated sub-stations. However, there is no response from developers. e) MERC has disallowed tariff of Rs. 3.29 per unit for 1180 MW solar projects. 16.27.6 Solar Projects Developed by M/s. MSPGCL: a) MSPGCL will execute PPA with the grid connected solar projects developer and PSA with MSEDCL. b) MSEDCL will purchase the power from MSPGCL at the tariff rate decided through competitive bidding and approved by MERC. c) Total 600 MW Solar projects under MSKVY are planned to be executed by MSPGCL. MSEDCL January 20 387 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 16.27.7 MSEDCL is further planning to create land bank on lease rent near AG dominated substation within 5 KM range and increase tariff for these decentralized project to add decentralized solar capacity aggressively. MSEDCL is targeting to develop around 3500 MW decentralized solar project in next 5 years. 16.28 Mukhyamantri Saur Krushi Pump Yojana (MSKPY) 16.28.1 Under ATAL AG Solar Scheme, MSEDCL has installed 5662 Nos. of AG Solar pumps. 16.28.2 In order to facilitate day time irrigation to the farmers & to promote use of renewable source of energy, the Govt. of Maharashtra vide G.R. No. Solar Project-2018/ C. No. 401/ energy-7 Dt. 15.11.2018 declared ‘Mukhyamantri Saur Krushi Pump Yojana’ (MSKPY) to install 1,00,000 Off-Grid 3 HP & 5 HP Solar Photovoltaic Water Pumping Systems in phase manner. After commencement of scheme, each phase should be completed in 18 month. Target for Phase-I is 25000 solar pumps. MSEDCL is implementing agency for this scheme. 16.28.3 Solar Agriculture pump will be installed in phase wise manner as under: Phase I (2018-19) – 25,000 Pumps Phase II (2019-20) – 50,000 Pumps Phase III (2020-21) – 25,000 Pumps 16.28.4 Benefits to Farmer – Day time Solar power to agriculture pump No Electrical network hence no interruption due to breakdown/ transformer failure etc. No electricity bills to farmers Will help to increase crop yield and farmers income 16.28.5 Benefits to MSEDCL – No maintenance cost MSEDCL January 20 388 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Environment friendly operation Minimize cross subsidy burden on Commercial & Industrial electricity consumers Helpful to meet out renewable power obligation (RPO) Benefits to Government – 16.28.6 Bringing more farm land under irrigation Decouple irrigation sector from power subsidy burden Category wise Beneficiary Share & Government Share – Category wise allocation of Pumps – 16.28.7 16.28.8 Govt. Share 3 HP Beneficiary Share 5 HP Beneficiary Share 10% 90% Rs. 16560/- Rs. 24710/- 5% 95% Rs. 8280/- Rs. 12355/- Beneficiary Share General S.C/ST Category As per G.R., Category wise & Capacity wise allotted quantity is as under: Phase Gen 3 HP SC ST Gen 5 HP SC ST Gen 7.5 HP SC ST Phase-I 17033 2364 1869 2678 589 467 - - - Phase-II & III 41396 6200 4904 11828 1772 1400 5914 886 700 Total 58429 8564 6773 14506 2361 1867 5914 886 700 16.28.9 Implementation of Phase-I – Letter of Empanelment (LoE) are issued to vendors on dtd. 07.03.2019 for installation of 25,000 Solar AG pump of 3 HP & 5 HP capacity. Revenue Division wise Capacity wise vendors are empanelled. 16.28.10 Implementation of Phase-II & III – The Govt. of Maharashtra vide G.R. No. Solar Project-2019/ C. No. 159/ energy-7 Dt. 11.09.2019 declared to implement Mukhyamantri Saur Krushi MSEDCL January 20 389 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Pump Yojana (MSKPY) Phase-II & III together to install 75,000 Off-Grid 3 HP, 5 HP & 7.5 HP Solar Photovoltaic Water Pumping Systems in the ratio 70:20:10. Letter of Empanelment (LoE) are issued to vendors on dtd. 18.09.2019 for installation of 67,500 Nos. of solar pumps of 3 HP & 5 HP capacity. Revenue Division wise vendors are empanelled. In addition to the approved MSKPY, MSEDCL is planning to install 67500 Solar Pumps per year from FY 2020-21. The proposal for the same will be submitted to the GoM. MSEDCL January 20 390 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 17 DETAILS OF OPEX SCHEMES 17.1 Customer Care Center 17.1.1 Objective: The purpose of setting up the CENTRALISED CUSTOMER CARE CENTER is to improve the supply /billing related complaint handling processes of MSEDCL and enhance the customer servicing capabilities of MSEDCL. Centralized Customer Care Centers (CCCC) with single window operation are equipped with latest technology & multi skilled customer service representatives. CCCC take the complaints and feedback through Telephone calls, e-mail, etc and each communication are answered and forwarded to concerned office. The one point contact service relieves the customer from the inconvenience of identifying the concerned offices, visiting or contacting offices to solve their grievances. CCCC are manned by trained and polite personnel, who are sensitive to customer needs. 17.1.2 Scope: To improve Customer Care Services, MSEDCL has outsourced the entire CCC Operations (incl. Manpower, Infra, Links, etc) on turnkey basis to a professional large scale BPO company. Their brief scope is as follows: Set-up an integrated contact center for MSEDCL with following functionalities: a. Inbound calls b. Social Media Management c. Email/SMS Handling d. Chat Support e. Outbound calls Two dedicated teams created for Technical Complaints (Power Failure, Emergency, etc.) & Commercial Complaints (Billing issues, New Connection request, etc.). Integrating CTI software with MSEDCL’s CRM software. A single screen to be provided to agents to access both CTI as well as MSEDCL CRM. MSEDCL January 20 391 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Coordination regarding installation, transfer, routing, mapping, and troubleshooting of the toll free number as well as PRI lines shall be handled by the bidder. Any document/ letter in this regard will be issued by MSEDCL. MSEDCL’s owned Toll Free numbers – 2 numbers (1800-2333-435 & 1800-200-3435 along with short Code 1912 & 19120 ) to be mapped & along with 8 PRI Lines (in the name of MSEDCL) MIS Reporting. a) Place: The Primary Call Center and the Disaster Recovery Center (Active) must be located in Maharashtra. Currently, primary center is located at Pune & secondary site is located at Thane location. b) Language: The call center would be required to provide inbound/outbound services in Marathi, Hindi and English. 17.1.3 Benefits: Better & professional Customer Care service to MSEDCL Consumers calling its Toll free numbers (1912, 19120, 1800-2333-435, 1800-2003435). Faster call handling and quicker resolution of Consumers’ Calls. Professional Social Media Management with integrated Social Media engagement Platform. High Availability of CCC operations. BPO companies maintain robust CCC Infrastructures, trained manpower backups & redundant telecom lines to avoid disruptions and SLA penalty. Outbound campaign like payment follow-ups can be easily arranged for better outcome. Changes in IVRS or Business Process can be easily & quickly carried out. Easy Capacity addition with similar Service Level during Monsoon & other critical times. System Generated Agent Utilization reports & live dashboard fully accessible to MSEDCL. 17.1.4 Project status: Letter of Award for ‘Providing Customer Care Services to MSEDCL for the period of Three Years’ is issued on dated 25.01.2018 for Rs. 19.94 crores. The MSEDCL January 20 392 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition service provider has been managing enterprise wide customer care of MSEDCL since 16th March 2018. 17.1.5 Revenue Expenditure: (Rs. Crs) FY20-21 (Projected) FY21-22 (Projected) FY22-23 (Projected) FY 23 -24 (Projected) FY 24 - 25 (Projected) 6.60 6.60 6.60 6.60 6.60 17.1.6 Cost Benefit: In addition to address the consumer complaints for which Customer Care Centre has been established, MSEDCL has utilized Centre for follow up of payments and achievements of Outbound Campaign for payment follow-ups are as under:-:For the period Apr-2018 to Mar-2019 total no. of calls made to defaulting consumers were 5, 67,046 nos. (Monthly avg. 47,253 nos.) and payment received was of Rs. 461.36 crore (monthly avg. Rs. 38.44 crore ). For the period Apr-2019 to Dec-2019 total no. of calls made to defaulting consumers were 1, 50,515 nos. (Monthly avg. 16,723 nos.) and payment received is of Rs. 89.02 Crore (monthly avg. Rs. 9.89 crore). Outbound Campaign for payment follow-ups with defaulting consumers, helped MSEDCL in realization of revenue. 17.2 Go Green Initiative 17.2.1 Objectives & Scope: In pursuance of Digital India Program (Digital Program) of Government of India (GoI) and digitization of its services and implementation of ‘Paperless Office’ at State Level by Government of Maharashtra (GoM), MSEDCL is proactively moving towards paperless and digitally led systems & structures. In view of the above and in order to encourage the consumers to participate in the Digital Program, MSEDCL has decided to offer a rebate of Rs. 10/on every electricity bill to the consumers who opt for an electronic copy of the bill instead of the hard copy under its “Go Green” initiative. The initiative MSEDCL January 20 393 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition is launched (after approval of MSEDCL Board) w.e.f. 1 December, 2018 for LT consumers. Go-Green initiative is launched as a voluntary initiative (not a compulsion) wherein consumers are free to opt for an electronic copy of the bill instead of the hard copy as per their willingness. MSEDCL has incurred expenditure in upgrading its digital infrastructure to deliver this service to the willing consumers. At present MSEDCL is serving around 2.5 crores consumers, out of which around 40 lakhs consumers are availing the online facilities for payment of bills and other activities. Thus there is a potential of tapping these consumers under the Go-green initiative by opting for the e-bill facilities. Presently around 93,000+ consumers have opted for e-bills under the GoGreen initiative. Go-Green initiative of MSEDCL has two objectives - delivering bills through the digital platform and reducing paper consumption. Additionally, it is expected that this initiative will help in: Significantly reducing the time spent in distributing the bills and therefore improving ease in accessing the electricity services; Reducing the number of complaints from the consumers regarding nonreceipt of the bill; Ensuring timely and early realization of payments from consumers thereby reducing the working capital requirement of the petitioner; Bringing down the printing and distribution expenses in the long run, if considerable number of consumers opt for this initiative; It is requested to allow the revenue expenditure of the said initiative as a part of Annual Revenue Requirement (ARR) for determination of Tariff for respective years and any cost saving achieved due to this initiative will also be reflected in ARR of respective years and will thereby benefit the consumers at large. MSEDCL January 20 394 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 17.2.2 Revenue Expenditure: (Rs.Crs) FY 20-21 (Projected) FY 21-22 FY 22-23 FY 23 -24 (Projected) (Projected) (Projected) FY 24 - 25 (Projected) 1.28 1.47 1.69 1.95 2.24 Note: Per year rise of 15% consumers opting for Go-Green initiative is considered. 17.2.3 Cost benefit: As on Dec-2019, total no. of consumers registered for Go-Green facility are 93,068 nos. For the period Apr-2018 to Mar-2019 no. of complaints for “Non receipt of Bills were 83829 nos. (Monthly avg. 6986 nos.). For the period Apr2019 to Dec-2019 no. of complaints for “Non receipt of Bills” are 36249 nos. (Monthly avg. 4027 nos.). It is observed that there is a reduction in no. of complaints of “Non receipt of Bills”. During the period Apr-2019 to Dec-2019 the no. of Go-Green registered consumers who have availed Prompt Payment Discount are 3, 38,355 nos. and bill amount paid is of Rs.49.69 Crore. This has helped MSEDCL in realization of Revenue. 17.3 SMS Services 17.3.1 Objectives & Scope MSEDCL has undertaken several initiatives & online services in which large numbers of SMS are sent to Consumers & Employees of MSEDCL Currently, approx. 2.21+ Crs out of 2.69 Crs consumers have registered their mobile numbers with MSEDCL. MSEDCL send SMS text messages to its consumers & for internal purpose (with Annual Avg.) for: Bill Alerts & Bill Reminders (27.5 Crs) Payment ack. for all Payments (10.93 Crs) Power Outage Notification (20.02 Crs) Ack. for Online New Connections (52.4 lakh) OTP messages (11.13 Crs) Verification of VPN Verification Employee Portal, MSEDCL Escalations to MSEDCL officials etc. Self-Reading intimation (2.17 Crs) Leave Notification Notifications for day to day works (paid pendency of new connections etc.) Salary Notifications (6.78 lakh) Disconnection Notices (62.71 lakh) Meter Reading Info (1.38 Crs) January 20 395 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Verification of Vendor Portal etc. Meter Reading adv. intimation (4.5 Crs) Complaint Ack. (56.18 Lakh) Confirmation through OTP for Mobile No. Registration Various MSEDCL Campaigns (2.74 Crs) Total SMS sent in FY 19-20 (Apr-19 to Sept-19) are 52.98 Crores. Average Monthly SMS sent are 8.83 Crores per month. MSEDCL is in process of issuing Letter of Award to the lowest cost (L1) bidder of the tender for ‘Providing SMS Services to MSEDCL’ for Rs. 30.20 Crores including GST @ 7.90 paise per SMS (excluding GST) for three years. 17.3.2 Revenue Expenditure: (Rs. Crs) FY 20-21 (Projected) 5.44 FY 21-22 (Projected) 5.44 FY 22-23 (Projected) 5.44 FY 23 -24 (Projected) 5.44 FY 24 - 25 (Projected) 5.44 17.3.3 Cost Benefit: Benefit of sending monthly Bill Alerts & Bill reminders to approx. 2.21 crore consumers is as under:MSEDCL has issued Letter of Award to the lowest cost (L1) bidder M/s Karix Mobile Pvt. Ltd of the tender for ‘Providing SMS Services to MSEDCL’ for Rs. 30.20 Crores including GST @ 7.90 paisa per SMS (excluding GST) for three years. MSEDCL is spending Rs. 0.84 crore per month on SMS services. For the period Apr-2018 to Mar-2019 total no. of consumers who availed Prompt Payment Discount was 5, 49, 17,438 nos. (Monthly approx. 45 lacs consumers) and amount paid was of Rs. 7948.17 crore (monthly avg. 662 crore). For the period Apr-2019 to Dec-2019 total no. of consumers who availed Prompt Payment Discount was 4, 34, 47,518 nos. (Monthly approx. 48 lacs consumers) and amount paid was of Rs. 7051.45 crore (monthly avg. Rs. 587 crore). This helped MSEDCL in realisation of revenue. MSEDCL January 20 396 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Delhi Electricity Regulatory Commission (DERC) in its Order in the matter of Petition for approval of Annual Revenue Requirement (ARR) of Tata Power Delhi Distribution Ltd. for the FY 2018-19, Revised ARR for FY 2017-18, True up for FY 2016-17 has approved expenses of SMS services separately in ARR under other expenses. By drawing same analogy, MSEDCL humbly requests Hon’ble Commission to consider expenses incurred for the above said SMS services as revenue expenditure over and above O&M expenses. 17.4 RF-DCU (Expression of Interest & Tender) 17.4.1 Scope: The vendor has to supply, install, commission and configure RF DCU in the pilot area having RF Meters installed. In case of multiple agencies are allotted the work, the quantum of RF meters in pilot area, allotted to each agency. The brief scope of work includes the following activities: Installation and Configuration of RF DCU in field where RF Meters are installed Commissioning of RF Meters for existing and newly installed RF Meters Download of RF Meter data (from all the RF Meter make) through RF DCU. a) Reading Data: As per Billing Cycle compulsory & also on demand, if required. b) Tamper Data: As and when detected in a meter c) Bill History & Load Survey: On demand Installation and configuration of data collection software at MSEDCL. Network debug, validation of data. Maintenance of RF Networks in the field. For first two months, RF DCU implementation will be done in parallel to existing RF reading through HHT and correctness of RF Meter readings received through RF DCU will be verified after comparing with RF reading received through HHT. In case of no reading received through DCU, all the remaining meters shall be downloaded using HHT and submitted in the format required for billing. MSEDCL January 20 397 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 17.4.2 Objective: To take readings of RF meters by installing DCUs so as to achieve automatic meter reading (AMR) for single phase & three phase consumers. 17.4.3 Benefits: No need to visit the consumer premise/carry Hand Held Terminals (HHT) to take meter readings. Readings downloaded by DCUs can be seen online through web based data collection software of agencies. Accuracy of reading is 100%. 17.4.4 Project status: LoA against EOI is awarded for 3 years for Rs 30.6 Lakh LoA against EOI is awarded for 5 years for Rs 24.18 Crs 17.4.5 Revenue Expenditure (RF-DCU meter readings) (Rs.Crs) FY 20-21 (Projected) 4.8 FY 21-22 (Projected) 4.8 FY 22-23 (Projected) 4.8 FY 23 -24 (Projected) 4.8 FY 24 - 25 (Projected) 4.8 17.4.6 Cost Benefit: RF-DCU project is implemented in towns with high losses like Jalgaon, Nanded and Latur on pilot basis. The detailed analysis has shown rise of 12% in sale after RF DCU based meter installation in above zones. As MSEDCL is planning to implement RF-DCU all across Maharashtra, it is expected to get 1741.49 MUs annually, which can yield additional revenue of Rs. 115.28 cr. approx. also additional saving of meter reading cost of Rs.21.68 cr. approx. MSEDCL January 20 398 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 17.5 Substation Monitoring System (SMS) 17.5.1 Objective: The growth of a Country depends upon various basic pillar of infrastructure and one of such basic infrastructure is availability of quality and reliable power. 16 years have been passed since the enactment of The Electricity Act 2003. Indian power distribution utilities have come a long way but still distribution is the weakest link in the entire value chain of the Electricity sector. Thus, there is a need of introduction of IT and automation in operation of distribution utilities. Distribution utilities generally operates three layers of network i.e. Subtransmission (33 kV), Primary Distribution (11 kV) and Secondary Distribution (0.415 kV). Any interruption at any level accounts for outage to hundreds/ thousands of customers. Thus it is necessary to monitor each and every network element in the system remotely. Substations are inevitable components in all power networks. It is the heart of distribution network. The entire downstream network is controlled and managed by sub-stations. Substation equipment health monitoring is very important for providing reliable and continuous power to the consumers. Substation equipment failure plays a major role in reliability of power delivery. Having an important role within the power system, substations are required to be equipped with great variety of monitoring and control devices. Therefore, it becomes of utmost importance to have real time data of substations. 17.5.2 Solution Proposed: Ever rising power demand and increase in CAPEX required for building new substations has motivated the utilities to utilize their existing power system capabilities more efficiently and smartly. But to achieve this objective, we need data of various equipment in the sub-station. For this we have implemented SCADA/AMR etc. but due to one or another reason these systems are not giving desired results. In order to avoid CAPEX and problems faced as above and to ensure data availability, we have implemented Substation Monitoring System pilot project for 44 nos. of 33 kV substations under Akola Circle. 17.5.3 Substation Monitoring System (SMS) Pilot Project Substation Monitoring System (SMS) Pilot project implemented at Akola Circle for 44 nos. of substations on OPEX basis. Payment to agency only on availability of data. MSEDCL January 20 399 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition SMS is a low cost indigenous technology for automation and business process improvement. SMS project is effective in monitoring of various substations equipment such as circuit breaker, transformer, feeder and DC battery system. The online substation monitoring devices are installed on all the incoming and outgoing feeders and on all the transformers. These devices captures the data like voltage, current, frequency, breaker status, relay tripping, OLTC position, Transformer OTI,WTI etc. after every 15 mins and send it to the central server. The specially developed webbased software shows different dashboards of all these monitored data. The system monitors all parameters (Voltage, Current, Power, Energy, Power factor, frequency etc.) on real-time basis at the substation level, and displays single line diagram of substation and provides the reports to all the stake holders. Akola Pilot Project - 3 LOAs issued o LOA given for Rs. 1.86 Crs o LOA given for Rs. 1.58 Crs o LOA given Rs. 1.78 Crs 17.5.4 Benefits of Substation Monitoring System: Benefit to MSEDCL: a) Improved monitoring substations and situational awareness of remote b) Monitoring of substation data in real time c) Reducing the work of operator like taking hourly data, recording the tripping etc. d) Substation equipment health monitoring e) Feeder Interruption analysis and computation of reliability indices such as SAIDI, SAIFI etc. f) Monitoring failures and breakdowns, Feeder load profiling, Load growth planning and management g) Feeder demand monitoring, Energy accounting MSEDCL January 20 400 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition h) Reporting of violations/exceptional values of different equipment in substations i) Analysis and diagnose the condition of the substation equipment j) Load balancing , Data for Load forecasting k) Data for Strategic, Managerial and Operational decisions Benefit to Customers: a) Quick actions from MSEDCL to reduce downtime and improve customer satisfaction. b) SMS alerts facility can be extended to consumers so that consumers will know that feeder is under breakdown. The Substation Monitoring System helps the Substation Operator/Shift Incharge to perform managerial duties primarily involving operation and maintenance of MSEDCL’s Sub-Station equipment effectively. Traditionally most utility performed regular maintenance in order to prevent equipment failure. On-line monitoring of power transformers and associated accessories is becoming an essential feature. The justification for on-line monitoring is driven by the need to increase the availability of power transformers, re-direction of time and/or operational-based maintenance to condition based maintenance, asset and life management and failure cause analysis. The planning for distribution system includes the analysis of existing system and planning of optimal future requirement of sub transmission and Distribution lines & Distribution Substations keeping in view the futuristic approach. This would also include the requirement of adequate Communication system and IT infrastructure etc. Through this approach, a distribution company should be able to analyze the distribution network for following: a) Optimization of loading of power transformers and Feeders. b) Ensuring an adequate network for existing as well future need with N-1 redundancy in the network. c) Reduce technical loss by optimizing the network configuration. d) Ensure voltage regulation in line with the Regulations. MSEDCL January 20 401 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition The data obtained from substation monitoring system project can be used for carrying out various analytics which will be helpful in taking decisions in respect of Operational, Strategic, Managerial and Planning of the system. The system helps in monitoring power supply, proper planning, decision support and taking corrective actions on the business activities in addition to transparently disseminating the power supply status. 17.5.5 Substation Monitoring System across Maharashtra Vide Board Resolution no. 1489 dtd 12-Oct-2018, MSEDCL Competent Authority has approved floating the Tender for Substation Monitoring System across Maharashtra with an estimate of Rs. 330.54 Crs. Tender with an estimate of Rs. 330.54 Crs (incl. Taxes) for 5 years is floated on OP-EX basis for Implementing Substation Monitoring System for 3289 nos. of 33/22/11 kV substations & switching stations across MSEDCL. Along with the monitoring of feeders, feeder control action also proposed under ADMS (Automatic Demand Management Scheme) for all feeders. 17.5.6 Revenue Expenditure: (Rs. Crs) FY 20-21 (Projected) 69.53 FY 21-22 (Projected) 69.53 FY 22-23 (Projected) 69.53 FY 23 -24 (Projected) 69.53 FY 24 - 25 (Projected) 69.53 17.5.7 Cost Benefit: Implementing Substation Monitoring System (SMS), will help MSEDCL in controlling outages by bringing effective OMS (Outage Management System) of Feeders, health monitoring of equipment’s and other benefits as mentioned above. Further, the revenue loss due to force outages will be reduced. At present the revenue loss due to force outages is approx. Rs. 339.77 crore/year, with the help of SMS, savings of nearly 20 % of revenue loss (i.e. Rs. 67.95 crore/year) is envisaged. Though the SMS is shown as OPEX, it is actually deferred CAPEX, as by making performance based payment over the 5 year period and this expenditure is not a part of regular O&M expenses. MSEDCL January 20 402 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 17.6 MSEDCL Cloud Project 17.6.1 Objectives & Scope: Under the Govt. of India funded (100% grant) RAPDRP Part ‘A’ Scheme, MSEDCL had established its own state of the art Tier-III Data Centre (DC) at Mumbai and Disaster Recovery (DR) Centre at Nagpur in the year 2011. Vide MERC’s in-principle approval MERC/CAPEX/2017-18/5053 dtd. 01/01/2018, Hon’ble Commission has given the approval for upgradation of IT Infrastructure at ON-PREMISE Data Center & Disaster Recovery site of MSEDCL (Cost Rs. 131.40 Crs.). However, vide Maharashtra Government Circular (मातंसं-060/3/2017 dtd. 29th Jan 2018) on Cloud Computing Policy, instructions were given to the Govt. Departments, Local Bodies & PSUs to migrate all their existing IT applications onto cloud platform. In pursuance to this, MSEDCL Competent Authority vide Board Resolution no. 1242 dtd. 07/04/2018, has accorded approval to migrate all MSEDCL IT applications onto Cloud Platform. Cloud computing is the on-demand delivery of IT resources (i.e. compute power, database storage, applications etc.) through a cloud services platform via the internet with pay-as-you-go facility. The building and maintaining data centers is replaced by consuming such IT resources from cloud services platform. Leading Cloud Services Providers in India are Amazon Web Services (AWS) and Microsoft Azure. MSEDCL has appointed a Managed Service Provider to migrate all its applications over to Amazon Cloud (selected Cloud Service Provider) and maintain them as per MSEDCL’s requirement in the cloud environment for the period of 5 years. The cost of Project is Rs. 88.77 Crs. 17.6.2 Benefits Less operational issues: The maintenance of On-Premises Infrastructure is becoming challenging day by day. The cloud runs on its own servers through a professional company whose only job is to make the cloud functional and bug-free, it’s usually a whole lot more reliable than on premise server. The cloud service provider company has to maintain the cloud uptime as per the Service level Agreement with the Customer which is normally 99.99%. Therefore cloud MSEDCL January 20 403 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition computing actually has fewer issues than On-Premises infrastructures. Security: Cloud is usually managed by large technologically advanced companies like Google, Microsoft, Amazon etc. backed by top class security professionals managing the security infrastructure of Cloud 24x7. The cloud service providers also perform more regular security audits. e.g. Following are Amazon Web Service Security Certifications/Compliances: CSA Cloud Security Alliance Controls, ISO 9001 Global Quality Standard, ISO 27001 Security Management Controls, ISO 27017 Cloud Specific Controls, ISO 27018 Personal Data Protection, PCI DSS Level 1 Payment Card Standards, SOC 1 Audit Controls Report, SOC 2 Security, Availability, & Confidentiality Report, SOC 3General Controls Report. Cloud providers even back up data to additional remote servers so data loss just won’t happen. Lower Total Cost of Ownership: MSEDCL’s On-premise IT-infrastructure estimated cost for 5 years (201819 to 2022-23) is approx. Rs. 205.79 Crores i.e. approx. Rs. 41.15 Crores per year. Whereas for cost of Cloud Computing (as per recent LOA awarded by MSEDCL) for availing same type of services is approx. Rs. 21.65 Crs per year (thus saving Rs. 19.50 Crs per year). No Capital Expenditure: The On-premise IT-infra procurement is usually done on the basis of sizing requirement of next five years with peak load. This often results in wastage of resources during initial years & off peak period. In case of Cloud Computing only operational cost needs to be paid which is billed on monthly basis. Client simply needs to pay for the amount of computing resources (servers & storage) utilized per month. You get purely what you need, when you need it. Faster Deployment: The IT infrastructure in Cloud Environment can be deployed within matter of minutes whereas for On-Premises IT Infrastructure; the procurement process of new IT equipment can take months. In case of Cloud Computing, resources can be purchased and consumed on a “pay-as-you-go” basis, and increased or decreased as needed for MSEDCL January 20 404 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition optimal utilization. Cloud computing is scalable on demand. Cloud service providers usually allow scaling up and down on demand seamlessly. The billing is done by cloud service providers on monthly basis. 17.6.3 Project status: The migration of applications from On-premise Data Center to Amazon Web Service (AWS) Cloud is going on and will be completed by Dec-19. 17.6.4 Revenue Expenditure (Rs. Crs) FY 20-21 (Projected) 16.64 FY 21-22 (Projected) 16.64 FY 22-23 (Projected) 16.64 FY 23 -24 (Projected) 16.64 FY 24 - 25 (Projected) 16.64 17.7 Annual Technical Support of SAP/HANA/Oracle Software Licences 17.7.1 Introduction: MSEDCL has implemented integrated SAP ERP (Enterprise Resource Planning) solution for its core functions for improvement in operation efficiencies with respect to the finance, project functions and integrating with existing systems viz. Billing, HRMS etc. MSEDCL has also implemented Integrated Enterprise wide SAP HRMSPayroll-ESS solution with allied module. MSEDCL has also invested in procurement of Oracle Databases Licences for its various IT systems. 17.7.2 Objectives: The OEM Annual Technical Support (ATS) which covers product updates, maintenance releases in the form of free fixes and patches and support related to the ERP products/ERP Database/Oracle Database is required for smooth functioning of SAP ERP, Oracle Database & Other IT Systems. 17.7.3 Scope: The Scope of ATS includes Telephonic, FAX, email & online Support service or by deputation of experts if necessary. MSEDCL January 20 405 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Product updates/ Maintenance releases in the form of free fixes and patches. All support related to ERP/Oracle Product and ERP/Oracle Databases. The Annual Technical Support is 24x7. 17.7.4 Scheme Approval: ERP Scheme: MERC scheme code: MSEDCL/FY11/21 MERC In Principle Clearance Reference No. and Dt : MERC/CAPEX/2010/2011/02588 dated 31.03.2011 In Principal Approved Cost Rs in Crs : Rs. 91.00 Crores. IPDS Scheme: a) MERC In Principle Clearance Reference No. and Dt : MERC/CAPEX/2017-18/5033 dt. 21.07.2017 b) In Principal Approved Cost Rs in Cr : Rs. 131.40 Crores. 17.7.5 LOA Project cost: LOA for “Annual Technical Support of SAP Software Users licences and HANA Licences” issued to M/s SAP India Pvt. Ltd. of amount Rs. 5.36 Crs (excl. GST) (Rs. 4.60 Crs [excl GST] for 1 year). LOA for “Supply of SAP-HRMS licenses” including AMC of Licences for 1 year is issued to M/s SAP India Pvt. Ltd. of amount Rs.11.96 Crs excluding GST. Per year cost of AMC Licences is Rs. 2.16 crs (excl. GST) LOA (CGM(IT)/1182) for renewal of ATS of Oracle Software for 1 year was given to M/s Oracle India Pvt. Ltd on 20-08-2019. 17.7.6 Revenue Expenditure: (Rs. Crs) FY 20-21 (Projected) 11.87 MSEDCL FY 21-22 (Projected) 11.87 FY 22-23 (Projected) 11.87 January 20 FY 23 -24 (Projected) 11.87 FY 24 - 25 (Projected) 11.87 406 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 17.8 Vehicle Tracking System 17.8.1 Scope of work : This is a OPEX project and hence all investment for supply, implementation, operation and maintenance of the entire infrastructure (hardware, software etc.) for the complete duration of 5 years contract period should be borne by the successful bidder only. Design, Development, Customization, Supply, Installation, configuration of the GPS based VTS tracking Solution on successful bidder’s own cloud. Application will be used by approx. 250 no. of MSEDCL users. Successful bidder will Provide maintenance support of the GPS based VTS tracking Solution for a period of 5 years (from the date of Go-live of the project) on OPEX basis. The fitment of GPS device for vehicles shall enable on-line, real-time monitoring of their movement and effective enforcement through a web based Vehicle Tracking Application Solution. The devices will have to be mapped on licensed map having commercial license with the geo-fencing of all vehicles as per the assigned route and working area. The cost of all types of licenses will have to be borne by the bidder. As part of the project, a web based application integrated with mobile app to be supplied to facilitate monitoring of vehicle movement. Generation of MIS reports along with dashboard for easy monitoring shall be provided. The selected bidder needs to provide handholding support along with integration of system with MSEDCL existing systems such as CRM, SAPERP for sharing the data of vehicles i.e. location, mileage data etc. The VTS devices are to be installed by the successful bidder on MSEDCL’s vehicles up to sub-division/Section office level. The information of these vehicles including contact details will be shared with successful bidder after award of contract. During the contract period, it will be the responsibility of the successful bidder to remove VTS devices from old vehicles and install VTS devices in new vehicles, whenever required (transfer / relocation). (Note: Renewal of vehicle hiring contracts is done by MSEDCL periodically. Also new departmental vehicles may be purchased and old vehicles scrapped). MSEDCL January 20 407 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 17.8.2 Objectives / Benefits The objective of this project is to establish robust and reliable mechanism of GPS Monitoring System on OPEX basis which shall a) Provide effective monitoring, better decision making, planning and management of MSEDCL vehicles. b) Track the vehicles on real-time basis, so that the current location of the vehicle can be identified for effective monitoring. c) Identify the vehicles doing violations based on the time of travel, distance travelled, destinations, etc. d) Generate analytical / graphical reports based on the various parameters, as desired by MSEDCL from time-to-time (development/customization to be done if required). 17.8.3 Revenue Expenditure: (Rs.Crs) FY 20-21 (Projected) FY 21-22 (Projected) FY 22-23 (Projected) 1.05 1.05 1.05 MSEDCL January 20 FY 23 -24 (Projected) 1.05 FY 24 - 25 (Projected) 1.05 408 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 18 CONSUMER SERVICE INITIATIVES 18.1 Mobile App for Consumers 18.1.1 ‘‘Mahavitaran’ a mobile app for consumers was launched in Jul-2016 and received unprecedented consumer response. Initially App was launched with basic services such as view and pay bill, view bill history, complaint registration, feedback about services, contact details update etc. App is available in English & Marathi on Android & iOS platform and till date, more than 40 Lakh consumers have downloaded this app. 18.1.2 Mobile app has enabled active two way interaction with the consumers. Constant interaction and listening to our consumers had helped in enhancing mobile app by adding following more services. Additional facilities made available in the app during year 2018-19 and 2019-20 are as follows: Apply for New Connection, Change of Name, Change of Load etc Locate nearest MSEDCL office and nearest collection center Estimate energy consumption and bill calculator Get Information about the Feeder from where power supply is provided to your connection Report any suspected electricity theft activity in your area Application for Solar Ag under MSKPY Register for Go-Green facility 18.2 SMS Alerts & E-mail notifications to Consumers 18.2.1 Understanding that not all consumers would require mobile app, MSEDCL, since year 2016-17, started providing all consumer related services through SMS on mobile and towards this, took massive efforts to collect mobile number of all consumers. Registered mobile numbers are used for passive communication with the consumers. Till date, total mobile numbers registered are more than 222 Lakh and total E-Mail IDs registered are more than 19+ Lakh. MSEDCL January 20 409 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition SMS alerts are issued to consumers for bill details, meter reading SMS, outage information etc. SMS services cover entire gamut of consumer connect with MSEDCL. MSEDCL Bill details (210+ Lakh SMS per month) Meter Reading SMS (210+ Lakh SMS per month ) Payment Acknowledgement (160+ Lakh SMS per month) New Connection status information (1+ Lakh SMS per month) Outage Information (150+ Lakh SMS per month ) Ack for Complaint Registration ( 1+ Lakh SMS per month) Bill reminder (before and after due date) (100+ Lakh per month) Other SMS (OTP/ Campaign SMS) ( 100+ Lakh SMS) E-Mails are sent for January 20 410 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Monthly Bill Firm Quotation for new connection ( 19+ Lakh E-mail per month ) (3000+ E-mail per month) 18.3 Online Cash Collection System (OCCS) 18.3.1 MSEDCL having consumer base of around 26 million consumers and turnover of more than Rs. 5000 Crores every month, has a very diversified ways of Bill Collection spread all over Maharashtra. Around 8000 cash collection centers are operative across the state which includes Departmental Collection Counters, Private Collection Agencies, Banks, District Co-operative Banks, Any-Time-Payment Machines and Post Offices, in addition to the Online Payment options like ECS, Bank Payment Gateways, Online Payment Agencies and through MSEDCL Web-site and Mobile app. Collection made by these offline collection centers took couple of days for reconciliation at MSEDCL offices. Remote Collection Centers located in villages far off, would even take more time for the data to be updated in billing system. Consolidation of data from various sources was one of the major challenges for the MSEDCL Staff. 18.3.2 At all physical collection Centers centralized Online Cash Collection System is implemented w.e.f. Jan-18 onwards. Consumer is allowed to pay MSEDCL’s Energy bill and New Connection other service charges anywhere in the state, simply by showing bill details SMS, no hard copy of bill is required. 18.3.3 With the implementation of OCCS, the bill paid by consumer gets reflected in his account on the same day. 18.4 MahaPowerPay Wallet: 18.4.1 For facilitating consumers especially in a rural area and slum area, MSEDCL has launched its own e-wallet ‘MahaPowerPay’. It is also a collection mechanism to engage small entrepreneurs in distant area in MSEDCL bill collection. It helps in enabling bill payment at retailers, at nearest location convenient to consumers. It is a pre-paid system having online registration process. It can be accessed through mobile for recharging of wallet as well as bill payments. There is no need of person to visit MSEDCL office. It can be owned by any individual / retailer like grocery shop owner, daily need shop MSEDCL January 20 411 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition owner, medical shop owner etc. In this retailer has to recharge the account with Rs. 5000/- initially, with subsequent recharges in multiples of Rs. 1000/-. He can recharge the wallet online through debit / credit card, netbanking etc. 18.5 Online Address Correction & Name change facility 18.5.1 There were several complaints received from consumers about long pending applications for name change and address correction. In order to facilitate speedy redressal of such complaints, address correction is enabled for consumers through SMS, wherein consumers are sent SMS with weblink for address correction. Approx. 80,000+ applications for address correction received through weblink after sending SMS request to consumers. Also consumers can submit the address correction application online through Web Self Service (WSS) portal. 18.5.2 Facility is made available to consumers to apply for name change through Mobile App, WSS Portal. Consumer can apply for name change, upload the documents online and need not visit the MSEDCL office. 18.6 Consumer outreach through Social Media such as Twitter, Facebook 18.6.1 MAHAVITARAN has active presence on Social Media such as Facebook, Twitter etc. to interact with consumers. From CMD, Directors to every filed officer of MAHAVITARAN are available actively on social media platforms to redress consumer grievances. 18.6.2 Approx. 800 twitter accounts used by field officers to respond to consumer queries, grievances. Complaints received through twitter and facebook are getting recorded in CRM and assigned to concerned field officer for redressal. 18.7 Integration of MSEDCL IT system with Aaple Sarkar / Maitri / Garv / Urja portal 18.7.1 Under the digital initiatives of Maharashtra Government, MSEDCL Services are integrated to ‘Aaple Sarkar’ portal of Govt. of Maharashtra & ‘MAITRI’ portal for Industries New Connection MSEDCL January 20 412 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Change of Name Faulty Meter Replacement Also, as per guidelines from ministry of power, Govt of India, MSEDCL has done Integration of Outage Information with Urja App of Ministry of Power Integration of performance parameters with National Power Portal New Connection system integrated with Garv portal for availability of Data of Rural Household Electrification at habitat. 18.8 Centralized Billing 18.8.1 Before implementation of centralized billing system, decentralized consumer database was being maintained at circle IT centers and for reporting purpose, billing data was uploaded to central server, which was post billing activity. Most of the billing activities such as submission of reading, receipts, meter replacement and validation thereof, was done offline and there was delay in bill generation due to manual activities which were under control of sub-division office. Unscheduled reading program, delay in reading program was resulting in delay in bill generation in turn resulting delay in revenue realization. 18.8.2 Centralized billing started for select circles in the year 2016-17 and till Mar-18, billing of all consumers in 8 circles was done successfully through centralized billing system. 100% billing of all consumers across all circles (44 no.) was started through centralized billing from Aug-2018 onwards. 18.8.3 The objectives of centralized billing are as follows: Regulate the cash flow through scheduled billing activity i.e. billing of each consumer on fix date – each meter to be read on fix date of every month Improved quality of billing – centralized validation and sanitization of data Reduction in billing complaints and reduction in losses 18.8.4 With the centralized billing system following achievement is observed: Consumer meter reading to bill generation, complete process is scheduled and automated, without any manual intervention from field or IT staff MSEDCL January 20 413 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Minimum delay in submitting the MIS information due to no/minimal network delay or manual activities. 18.9 RF Metering & AMR for HT Consumers, Feeders 18.9.1 RF Metering & RF DCU (Data Concentrator Unit) implementation: To reduce the manual intervention in meter reading process, MSEDCL has adopted policy to install new technology meters i.e. meters with communication capability.For Single Phase and Three Phase meters, Meters with RF port with 6LowPAN standard protocol for communication over 865-867 MHz de-licensed frequency band are being procured at MSEDCL. In the year 2017-18, more than 35 Lakh Single Phase RF Meters procured. These meters will be read through DCU for automatic meter reading. RF DCUs are having in-built RF module to capture meter data and in built GPRS modem for communication with AMR server. DCU has store and forward feature and can store meter data of approx. 2000 meters at a time. In 2017-18, a pilot project at Washi & Kalyan circle was done and two agencies appointed to implement DCU solution to read RF meters in this area for 3 years. Total RF meters covered in pilot activity was 40,000 RF Meters. RF DCU implementation is done for approx. 5 lakh RF meters in RF dominated area at Nashik, Pune, Kalyan and Bhandup zone. MSEDCL January 20 414 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Replacement of existing 8.5 lakh meters with RF meters is being done in towns at Latur zone, Nanded zone and Jalgaon zone, wherein a vendor will install RF meters by replacing all existing meters in the area and also implement RF DCU to read these meters for next 5 years. Till date, MSEDCL has installed more than 60 lakh RF meters for single phase consumers across Maharashtra and these RF meters will be read remotely through RF DCU in future. 18.10 HT Consumer Portal 18.10.1 A Portal is launched in Sept-19 for HT Consumers. For registered HT Consumer, following services are available through portal View Bill details Online payment of bills View Consumption History View Load Profile – Energy / Demand / Voltage / Current Graph Grievance Redressal System Profile Update Bill Simulation – helps to prepare the monthly budget for electricity usage Comparison with peers – compare the consumption pattern with peers in the same sector 18.11 Online Refund of Security Deposit / Electricity Duty 18.11.1 Consumer can apply online for refund of excess SD, refund of SD after disconnection. 18.12 Proposed Consumer Services 18.12.1 LT Consumer Portal: The portal for LT Consumers will be prepared in line with HT consumer portal after implementation of RF DCU and installation of modems to LT consumers above 20kW. Daily consumption pattern will be made available to all LT consumers. 18.12.2 Missed Call service for registration of no power complaints MSEDCL January 20 415 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition A dedicated number will be published so that consumers can register their no power complaints just by giving miss call to MSEDCL number. MSEDCL January 20 416 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 19 PROPOSAL FOR SCHEDULE OF CHARGES 19.1 Background 19.1.1 Presently, MSEDCL is recovering various charges from the consumers for various services provided as per the Schedule of charges approved by Hon. Commission vide its Order dated 12 September, 2018 (Case No. 195 of 2017). 19.1.2 Basically these charges are for recovery of cost incurred for availing supply of electricity and various other services provided to the consumers. In order to shield regular consumers from consumer service specific costs, provision for schedule of charges has been made. Income from these charges form a part of the non-tariff income of MSEDCL. 19.1.3 As per the provisions of Section 46 of the Act provides that the Commission may authorize a Distribution Licensee to charge a person requiring a supply of electricity any expenses reasonably incurred in providing any electric line or electrical plant used for the purpose of giving that supply. Otherwise these costs will get passed on to regular consumers of MSEDCL. 19.1.4 The Electricity Act 2003 (EA 2003) provides Distribution Licensees to recover charges incurred for supply of electricity from its consumers in accordance with tariff determined by the State Regulatory Commission. The charges to be recovered may include fixed charges in addition to charges for supply of electricity and rent or other charges for meter or other equipment provided by licensees. Section 45 of EA 2003 reads as follows – “ (3) The charges for electricity supplied by a distribution licensee may include – (a) a fixed charge in addition to the charge for the actual electricity supplied; (b) a rent or other charges in respect of any electric meter or electrical plant provided by the distribution licensee ” 19.1.5 In accordance with the provisions of EA 2003, Hon’ble Commission has notified MSEDCL January 20 417 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition MERC (Electricity Supply Code and Other Condition of Supply), Regulation 2005. MSEDCL submits that as per Regulation 18 of the MERC (Electricity Supply Code and Other Conditions of Supply) Regulations, 2005, Distribution Licensees are required to submit the proposal before Commission for approval of Schedule of Charges (SoC) for such matters required by the Distribution Licensee to fulfil its obligation to supply electricity to consumers under the Electricity Act, 2003 and other relevant Regulations. 19.1.6 MSEDCL submits that Schedule of Charges (SoC) represent the charges levied to consumers/applicants for new connection and on existing consumers for various activities carried out by the Licensee such as load enhancement, change of name, category, etc., meter testing and various other miscellaneous activities required to be performed as a Distribution Licensee. 19.1.7 As per provisions of Supply Code Regulations, various charges are permitted to be recovered from consumers subject to approval from the Commission. Various services for which charges can be recovered from the consumer as per provisions in regulations of MERC (Electricity Supply Code) Regulations, 2005 are given below: Sr. No. Broad Head Relevant Regulation 1. Service connection charges 2. Charges for temporary supply 3.3.6 3. Supervision charges 3.3.8 4. Processing of applications 5. Charges for increase/reduction Contract demand/sanctioned load 6. Change of Name 7. Processing fee for change of name 8. Security deposit 9. Cost of meter 10. Meter testing charges 11. Charges for restoration of supply MSEDCL 3.3.1 to 3.3.4 4.1 (ix) in 6.8 10.3 10.3 (iv) 11.3 14.1.3 & 14.2.2 14.4.2 January 20 16.2 418 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 19.1.8 Considering the above provisions, MSEDCL has proposed following revision in Schedule of Charges: 19.2 Calculations for Service Connection Charges 19.2.1 In this Section, MSEDCL has provided the necessary calculations to rationalise the proposed charges. a) The Commission in its Order in Case No.195 of 2017 dated 12 September, 2018 has estimated the service connection charges on the basis of 20 meters as the average length. MSEDCL in present proposal has followed the same estimation and worked out the service connection charges. b) As per revised Cost data of FY 2019-20 and centages, the estimates are prepared to derive the Service Connection charges. In this proposal the loading - unloading and handling charges for meter, Contingencies, Insurance of material & price variation/ escalation were taken in consideration. The centages in total over the total estimated cost of materials required is 25.50%. All other things are kept as it is such as supervision charges, variable charges etc. c) While estimating charges for new HT Overhead connection, MSEDCL has considered all the legitimate expenditure for works of Gantry, Earthing, protection and Metering etc. The same works has considered in case of HT underground new service connection. Accordingly, MSEDCL proposes the new service connection charges based on all legitimate costs. The detail cost estimations are enclosed as Annexure 10. The proposed normative service connection charges are as below: Sr. No. Particulars I) SERVICE CONNECTION CONNECTION 1 CHARGES Existing Charges (Rs.) FOR NEW Proposed Charges (Rs.) OVERHEAD Low Tension (LT) Supply. a. Single Phase MSEDCL January 20 419 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Sr. No. Particulars i. Existing Charges (Rs.) 1,000 Proposed Charges (Rs.) 1,530 3,100 3,630 7,150 8,030 For load up to 0.5kW For load above 0.5kW and up to ii. 1,500 2,230 7.5kW b. Three Phase Motive power up to 27 HP or other i. 3,500 8,130 loads up to 20 kW. Motive power above 27 HP but up to ii. 107 HP or other loads above 20 kW 8,500 14,920 but up to 80 kW. Motive power above 107 HP but up iii. to 201 HP or other loads above 80 13,000 23,840 kW but up to 150 kW. High Tension (HT) Supply& Extra High Voltage (EHV) Supply * i. 11kV Supply up to 1,000 kVA. 2,34,900 11kV Supply above 1,000 kVA up to ii. 21,500 + 2,75,900 5,000 kVA 30/-Per iv. 22kV Supply up to 1,000 kVA. 2,79,100 2 kVA for 22kV Supply above 1,000 kVA up to excess v. 3,40,000 10,000 kVA load above vi. 33kV Supply up to 20,000 kVA. 3,96,600 500 kVA. EHV Supply and beyond SOP At actual viii. Cases II) SERVICE CONNECTION CHARGES FOR NEW UNDERGROUND CONNECTION Low Tension (LT) Supply. a. Single Phase i. For load up to 0.5 kW 1 For loads above 0.5 kW & up to ii. 7.5kW b. Three Phase MSEDCL January 20 420 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Sr. No. Existing Charges (Rs.) 13,5 00 Particulars Motive power up to 27 HP or other loads up to 20 kW Motive power above 27 HP but up to ii. 67 HP or for other loads above 20 21,000 kW but up to 50 kW Motive power above 67HP but up to iii. 134 (201)HP or for other loads 43,000 above 50 kW but up to 100 kW(150) Motive power above 134HP but up iv. to 201 HP or for other loads above 66,500 100 kW but up to 150 kW High Tension (HT) & Extra High Voltage (EHV) Supply * i. 11kV Supply up to 1,000 kVA. 2,21,000 11kV Supply above 1,000 kVA up to ii. (up to 500 5,000 kVA kVA) iv.2 22kV Supply up to 1,000 kVA. 22kV Supply above 1,000 kVA up to 2,30,000 v. 10,000 kVA (above vi. 33kV Supply up to 20,000 kVA. 500 kVA) viii. EHV Supply & beyond SOP Cases i. Proposed Charges (Rs.) 15,0 80 26,040 50,800 75,660 2,69,800 2,81,900 3,06,600 3,46,000 4,06,900 At actual Notes: 1. In case MSEDCL permits an applicant to carry out the works through a Licensed Electrical Contractor (LEC), a rate of 1.30 % of the normative charges will be applicable towards supervision charges. 2. In case of extension of load, the normative charges will be applicable on the total load (existing as well as additional load demanded) as per the load slabs indicated above. 3. In case of extension of Load where augmentation of infrastructure is required, the expenses will be recovered for such augmentation as actual in accordance with clause 3.3.4 of MERC Regulation, 2005. 4. The GST will be levied extra as per applicable rates. MSEDCL January 20 421 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 5. The road opening charges vary from area to area hence will be levied on actual basis. d) Charges for Premium Service: A distribution Licensee has a Universal Supply Obligation (USO) under Section 43 of the Electricity Act, 2003 to supply electricity to any consumer within its area of supply who makes a demand. The Petitioner submits that the Regulatory mechanism permits capital investment after approval of the Hon’ble Commission and it is further subject to availability of funds for implementation of this work. MSEDCL being fully owned Government Company rely for funds on Government Grants and same is worked out and approved on year to year basis. The Petitioner submits that the other mode of CAPEX is funding through ARR. The funding through ARR requires loans to be approved and the same is required to be recovered in tariff. There is limitation for availing loans by MSEDCL as well as the capacity to repay loans in time. The connections are released after following seniority list. It is observed that many consumers are approaching field offices with requests to carry out work on priority and are ready to carry out works by paying cost of infrastructure and metering. MSEDCL submits that there is no explicit Regulatory provision to act on such request applications. Hence, MSEDCL proposes Premium Service (excluding DDF) charges based on actual cost estimate (all items including Civil works, road reinstatement and metering). Such premium service will be applicable to all categories and it will be on non-refundable basis. Further, MSEDCL will maintain the assets created and will be utilized for catering future load growth. The expenditure required is not uniform and vary case to case. However, the estimate required is prepared based on latest CPA data and Cost data (BOQ). Rates are derived through e-tendering, joint measurement after work completion and in consultation with contractors for market prices. MSEDCL submits that such premium charges will reduce the burden of infrastructure cost on common consumers. e) Scheme for optimum utilization of existing distribution assets: MSEDCL submits that Section 42 (1) of the Electricity Act, 2003 casts duty MSEDCL January 20 422 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition on MSEDCL to develop and maintain an efficient co-ordinated and economical distribution system. The Electricity Act 2003 mandates that a distribution licensee is under obligation to supply electricity to every consumer within its licensed area of supply. As per Section 43 of the Act if the owner or occupier of any premises situated in the license area of the distribution licensee demands supply then the licensee is statutorily compelled to give connection and release the supply to such an applicant within the stipulated time period. By virtue of provisions in MERC Supply Code Regulations, 2005 the consumers have option to opt for dedicated distribution facility. All the assets created under DDF schemes are maintained by MSEDCL. It is evident that in many cases consumer assets created under DDF are not being optimally utilized. Further, due to allocation of bays exclusively for DDF works, MSEDCL is not in position to release new connections due to Right of way issues and space constraints in sub-stations, network/capacity constraints. In such cases; only option available is mutually sharing of under-utilized capacity of infrastructure by existing consumer with prospective consumer. Voltage wise details of underutilized capacity (Feeders in Nos.) are depicted in table below: Voltage Level No. of feeders 11 kV 460 22 kV 213 33 kV 335 It is necessary to devise the scheme for optimum utilization of distribution assets. Accordingly, MSEDCL proposes following: Based on new service connection requests, MSEDCL at first stage will strive to release the connection through its own infrastructure. If there is space/capacity constraints in MSEDCL substation/lines and underutilized network created under DDF is readily available in the vicinity then MSEDCL will utilise underutilized DDF assets, if any available. In such cases in the interest of common consumers, MSEDCL will take over the assets created under DDF by granting depreciated cost of the MSEDCL January 20 423 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition sanctioned CAPEX to original developer. While implementing above proposal, MSEDCL will ensure technical feasibility by considering nature of load, process in consumer establishment and reliability of supply. Further, if any works related to augmentation, isolation of supply systems is required, then MSEDCL will carry out the works in accordance with Regulation 3.3.4 of MERC (Electricity Supply Code and Other Conditions of Supply) Regulations, 2005. f) In case MSEDCL permits an applicant to carry out the works through a Licensed Electrical Contractor, a rate of 1.30% of the cost estimate will be applicable towards supervision charges. 19.3 Cost of Meters and Hiring charges 19.3.1 Cost of Meter Section 45 (3) (b) of the Electricity Act, 2003 empowers Distribution Licensees to recover a rent or other charges in respect of any electric meter or electrical plant provided by it. Accordingly, MSEDCL is entitled to recover the following charges related to meters: a. Cost of the meter in case the meter is purchased from the Distribution Licensee b. Replacement in case of lost/burnt meter c. Hire charges for the meter As per Regulation 14.1.3 of MERC Supply Code Regulations 2005, a consumer of a distribution licensee can purchase a meter from distribution licensee or from any supplier of correct meter in accordance with specification laid down by CEA. In recent years metering technology has given new dimensions to billing practiced by Distribution Companies. Metering is no longer limited to the conventional application of billing alone. It also provides useful information for Analytics, Pricing mechanisms, revenue protection, Demand forecast, Energy management etc. Due to obsolescence in metering technology and for easy facilitation of billing data transfer MSEDCL has adopted new metering technologies. MSEDCL submits that it is aiming to adopt innovative metering technologies to improve billing efficiency and cut down costs & time lags. It is submitted that MSEDCL January 20 424 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition the new metering technologies are available with low cost in bulk procurement and due to competition in market. Major adopted innovations: (a) Radio Frequency Meters: MSEDCL has adopted RF technology based metering in order to avoid human error in meter reading, data punching, data validation and manipulation in reading by meter reader. The meter reading of large quantity of meters can be taken by reader from the distance. (b) Smart Meters: In order to improve billing efficiency and in compliance to National Tariff Policy, 2016 MSEDCL has adopted smart metering solutions. Smart meters provides for time of use feature, internal connect and disconnect switches with two way communication capacity and for remote diagnosis. Smart meter supports both pre-paid and postpaid mode. (c) CT Embedded Meters: MSEDCL has adopted CT embedded meters in place of traditional metering with external CTs. Installations with LT CT operated meters are prone to theft of energy through reverse connection of CTs and non-sealing of metering cabinets and terminal covers. CT embedded meters has advantage of compact size and easy installation and no scope for reversal of connection. Most benefits are articulated in terms of improvements or cost savings. Benefits can be quantifiable (tangible) and non-quantifiable (intangible). Major Benefits of new metering technologies are listed as below: Operational Benefits - Meter Reading Automation; - Operational Efficiencies in field and Meter services; - Reduction in unaccounted Energy; - Operational Efficiencies in Billing and Customers Management; - Improvements in capital spend efficiency. Quantified - Enhanced Customer Service; Customer/societal - Billing Accuracy Improvement; Benefits - Reduced Consumption on Inactive Meters; - Informed Decisions on Energy Usage; MSEDCL January 20 425 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Additional customer/societal benefits - Environmental Preservation through Reduced Peak-Time Usage Enhanced Customer Convenience; Increased Safety for Meter Readers and Field Services Personnel Accordingly, MSEDCL proposes following: Sr. No. 1 2 3 3 4 A B C Type Proposed Cost (Rs) Single Phase 5-30 A 6 LoWPAN RF Meter without enclosure 10-60A Smart Meter (including GPRS communication Module) as per IS:16444 Part-I Three Phase 10-40 A 6 LoWPAN RF Meters without enclosure 10-60 A Smart Meter (including GPRS communication Module) as per IS:16444 Part-I LT-CT Operated Three Phase Metering Unit 250/5 A Meter with CTs & MCCB 40-200 A CT embedded Meters LT-CT Operated Three Phase Smart Meter (including GPRS Communications Module) as per 15: 16444 Part-2 with Accuracy Class 0.5 S and current rating of -/5 A. Supporting CTs and MCCB for LT-CT Operated three phase Smart meters as above H.T. ToD Meter 5 A rating with 0.5 s accuracy class 1 A rating with 0.5 s accuracy class 1A & 5A rating with 0.2 s accuracy class H.T. Metering cubical including C.T & P.T 11 kV 22 kV 33 kV 820 2610 1520 3790 22500 13840 3570 18720 2420 2650 5930 85000 130000 190000 Notes: MSEDCL January 20 426 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 1. In case consumer opts to purchase the meter, metering Cabinet/ cubicle from MSEDCL, the security for the price of the meter, metering Cabinet/ cubicle in accordance with the provisions of clause 14.1.1 of MERC Regulation, 2005 will not be applicable. 2. In case of Lost & Burnt Meter & metering Cabinet/ cubicle, the ‘Installation Testing Fees’ will be recovered from the consumer as per approved SoC. 3. Meter box will be provided by MSEDCL at its own cost. 4. The GST will be levied extra as per applicable rates. 19.4 Hiring Charges: MSEDCL submits that stated that Regulation 14.1.2 of MERC (Electricity Supply Code and Other Conditions of Supply) Regulations, 2005 specifies as under: "14.1.2 The Charges for hiring of meters by a consumer shall be in accordance with the approved schedule of charges under Regulation 18." MSEDCL submits that in case the consumer opts for hiring the meter as per Section 45 of the EA 2003 and Regulation 14.1.2 of MERC (Electricity Supply Code and Other Conditions of Supply) Regulations, 2005 then such facility needs to be granted. MSEDCL has proposed the hire/rent charges for the meter based on the annual depreciation @20% per annum. Sr. No. 1. a. b. 2. a. Particulars LT Single Phase 5-30A 6LoWPAN RF Meter without enclosure 10-60A Smart Meter (including GPRS communication Module) as per IS:16444 Part-I LT Three Phase 10-40A 6LoWPAN RF Meters without enclosure MSEDCL Material Cost (Rs.) Annual Cost Considering Life of 5 Years (Depreciated @20%) Charges per month (Rs.) Proposed Rent (Rs/ Connection/ Month) 820 164 14 15 2610 522 44 45 1520 304 25 25 January 20 427 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Sr. No. b. 3. 4. 5. Particulars 10-60A Smart Meter (including GPRS communication Module) as per IS:16444 Part-I LT 40-200A CT embedded Meters LT 250/5A CT Operated Meter with CTs & MCCB LT-CT Operated Three Phase Smart Meter (including GPRS Communications a. Module) as per 15:16444 Part-2 with Accuracy Class 0.5S and current rating of /5 A. Supporting CTs and MCCB for LTCT Operated b. Three Phase Smart Meter as above 4. Material Cost (Rs.) Annual Cost Considering Life of 5 Years (Depreciated @20%) Charges per month (Rs.) Proposed Rent (Rs/ Connection/ Month) 3790 758 63 65 13840 2768 231 235 22500 4500 375 375 3,570 714 59.50 60 18,720 3,744 312 315 40 40 44 45 99 100 HT ToD Meter 5. 5A rating with 0.5 s 2420 484 accuracy class 1A rating with 0.5 s 2650 530 accuracy class 1A & 5A rating with 5930 1186 0.2s accuracy class HT Metering cubical including C.T & P.T a. For 11 kV Supply 85000 17000 1417 1420 b. For 22 kV Supply 130000 26000 2167 2170 c. For 33 kV Supply 190000 38000 3167 3170 a. b. c. MSEDCL January 20 428 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 19.5 Miscellaneous and General charges 19.5.1 MSEDCL submits revision in following miscellaneous and general charges along with rationale behind the proposal: 19.5.2 Application Registration and processing Charges: a) A consumer can submit application of provision of electric supply, sanction of additional load, shifting of service etc. As per Regulation 4.1 (ix) of the MERC Supply Code Regulations, a distribution licensee can recover fees for processing such applications. b) After receipt of application form, distribution licensee is primarily required to conduct following activities Verification and scrutiny of existing location of applicant; Scrutiny of past dues, if any; Existing facility / infrastructure at consumer premises (service line, meter board etc.); Provision of electrical network and equipment; Verification of compliances from consumer (payment of charges and appropriate wiring / distribution). c) MSEDCL incur the cost to conduct the above mentioned activities. Apart from release of new connection, MSEDCL is require to process applications related to change of name, reduction or enhancement of load, shifting of service/line, change of category, disconnection request and any certificates (such as certificate of no installation which required for NonAgricultural land, No dues certificates etc.). For carrying out these activities require man power and associated facilities. Further, it is necessary to create minimum barrier to discourage frivolous or non-serious consumers. d) It is pertaining to note that the schedule of charges determined in present proceedings will be applicable till FY 2024-25. Hence it is necessary to escalate the charges considering trend in inflation. For devising escalation factor, MSEDCL has considered the five year average WPI. MSEDCL January 20 429 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Year Annual Increase WPI 236.00 FY 2013-14 250.83 FY 2014-15 265.00 FY 2015-16 275.92 FY 2016-17 284.42 FY 2017-18 299.92 FY 2018-19 Average from FY 14-15 to FY 18-19 6% 6% 4% 3% 5% 4.80%~5% Following table shows the proposed application registration & processing charges to be recovered: Sr. No. 1 2 3 4 5 Category Single Phase Three Phase LT (Agriculture) HT Supply up to 33 kV EHV Supply Existing SoC approved by MERC in Case No.195 of 2017 Rs 100 150 150 2400 4800 Proposed charge Rs 110 160 160 2500 5100 19.6 Installation Inspection & Testing Fees: a) Regulation 9 of MERC (Electricity Supply Code and Other Conditions of Supply) Regulations, 2005 provides that the wiring of consumer’s premises shall conform to the standards specified in the Indian Electricity Rules, 1956. As per Rule 47, it is the duty of the supplier to inspect and test applicant’s installation before connecting the supply. As per Rule 53(1), the cost of first inspection and testing of a consumer’s installation carried out in pursuance of the provisions of Rule 47 shall be borne by the supplier and the cost of every subsequent inspection and test shall be borne by the consumer. b) The first testing of a consumer’s installation will be free of cost as done currently. For every subsequent inspection and test, following rates have MSEDCL January 20 430 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition been proposed after application of escalation factor devised above. Existing SoC approved by MERC Proposed Sr. in Case No.195 of charge Category No. 2017 Rs Rs LT Installations 1 Single Phase 100 110 2 Three Phase 200 220 HT Installations 3 Agricultural 550 600 4 All categories 750 except Agricultural 5 Renewable Energy Installations with Net Metering features Single Phase 500 Three Phase 1000 19.7 Reconnection Charges: 19.7.1 Considering the practice followed by MSEDCL in disconnection of supply pursuance to default of payment, it is proposed to reframe reconnection charges based on nature of disconnection. Following re-connection charges have been proposed: Sr. No. 1 Existing SoC approved by MERC in Case No.195 of 2017 Rs Category Low Tension Re-connection at Meter incoming main: Single Phase MSEDCL January 20 100 Proposed charge Rs 200 431 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Sr. No. 2 2 3 Category Three Phase At overhead distributing main: Single Phase Three Phase Re-connection in underground cable works Single Phase Three Phase Re-installation of Cut out, Meter & Service cable High Tension supply Existing SoC approved by MERC in Case No.195 of 2017 Rs 200 Proposed charge Rs 400 100 200 300 500 200 200 300 500 1000 800 3000 19.8 Changing Location of the Meter within the same premises (shifting of service is not required) at consumer’s request: 19.8.1 MSEDCL is hereby submitting different charges for shifting of meter in case of single phase supply and three phase supply. The said bifurcation is required as three phase meter shifting requires more labor and sundry items than single phase meter shifting. Sr. No. 1 2 Category Single Phase Three Phase Existing SoC approved by MERC in Case No. 195 of 2017 Rs 350 Proposed charge Rs 400 1000 19.9 Shifting of services/Poles/Lines (Utility), if carried out only on consumer’s request: 19.9.1 It is submitted that the consumer’s request may not be limited to shifting of a single meter within the same meter cabin or another meter box, but may also require shifting of the entire meter box along with its service cable or shifting of MSEDCL January 20 432 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition poles. This may involve partial or complete removal of the existing service cable. It may also involve relocation of the meter along with the service cable, fuse unit and other safety arrangements. In case of underground cable, if the cable is to be removed, it will require excavation which may be in private property or on public roads. Accordingly, reinstatement charges become applicable. Thus, additional manpower and resources are required which would vary from case to case considering consumer requirement and site conditions. 19.9.2 Further, due development work, many consumers approach the MSEDCL to shift the poles in his premises. In many cases consumers are approaching MSEDCL to shift Poles/Lines (Utility) to secure non-agricultural (NA) land status. Present schedule of charges do not address this scenario, hence following is proposed. It is submitted that for such cases charges will be recovered based on approved cost data of MSEDCL. Sr. No. Category 1 2 Single Phase Three Phase Proposed charge Rs Actuals Actuals 19.9.3 In case MSEDCL permits an applicant to carry out the works through a Licensed Electrical Contractor (LEC), a rate of 1.30 % of the sanctioned charges based estimate will be applicable towards supervision charges. 19.9.4 The Commission in its Order in Case No.83 of 2014 dated 25 July, 2014 in the matter of Petition filed by Tata Power Company for review of Order dated 28 December, 2012 in Case No. 47 of 2012 in the matter of its Schedule of Charges to the extent of charges for (a) Service Connection for ‘Switchover’ consumers (b) Service shifting and Meter shifting on the consumer’s request accorded its approval to recover actual expenditure incurred in shifting of services. 19.10 Testing of Meters/Equipment 19.10.1 MSEDCL submits that it has proposed charges for testing of meters MSEDCL January 20 433 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition considering the increase in labour cost, testing equipment cost, maintenance cost, duration of testing, etc. Further, MSEDCL states that testing charges proposed for single phase (1Ph.), three phase (3Ph), LTCT Operated (3ph), HT TOD & ABT/Apex meter having different applicable IS. The testing charges have been proposed based on type of meter, duration for testing, and its accuracy class. Hence, the rates for testing charges are varying accordingly. Also, considering the costly automatic equipment service maintenance, electricity cost and all other costs, the proposed rates revised. The consumers do have option to test meters at TQA labs other than MSEDCL. In order to keep rates competitive, MSEDCL has not proposed any revision in testing charges at TQA labs. 19.10.2 Further, MSEDCL carry out testing of Distribution Transformers of consumers. Hence, charges for testing of Distribution transformers are also proposed. Sr. No. 1. a. b. c. d. e. f. g. Existing Particulars Charges (Rs.) Testing of meters and metering equipment Single Phase 200 Poly-phase Meter/ RkVAh Meter 800 LT MD Meters (With/ Without CTs) 1,000 Tri-vector Meter 1,000 LT Metering Equipment like CT/PT 1,000 per Unit HT Metering equipments like CT/PT 3,000 per Unit (up to and including 33kV) HT & EHV Metering equipments like 5,000 CT/PT per Unit (above 33kV) Proposed Charges (Rs.) 250 1,000 1,200 1,200 1,000 3,000 5,000 Net Meter i. i. Single Phase - 500 ii. Three Phase LT CT operated - 2,200 MSEDCL January 20 434 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Sr. No. Particulars Existing Charges (Rs.) Proposed Charges (Rs.) Bidirectional Three Phase HT ToD 2,400 Bidirectional Testing of Meters at TQA Laboratories Single Phase 2,000 2,000 Three Phase 9,500 9,500 LT CT Operated Meters 10,000 10,000 HT ToD Meters 15,000 15,000 ABT/Apex Meters 20,000 20,000 Summator meter – module Two module + Summator 46,500 Three module + Summator 68,200 Four module + Summator 89,990 Calibration of Testing Equipments of Other Utilities’ request at TQA Laboratories Active/ Reactive Energy 400 per Load Point Active/ Reactive/ Apparent Power Voltage Current 500 per Load Point Power Factor Frequency Cable Testing and fault Detection 33/11KV cable fault location 12,000 33/11KV cable Hipot 4,500 33/11KV Cable Identification 4,500 33/11KV Cable fault Identification 4,500 LT U.G. Cable Fault location and 4,500 identification Distribution Transformer 3,000 iii. 2. a. b. c. d. e. 3. a. b. c. 4. a. b. c. d. e. f. 5. a. b. c. d. e. 6. MSEDCL January 20 435 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 19.11 Administrative Charges for Cheque Bouncing: 19.11.1 MSEDCL is not seeking any change in administrative charges for Cheque bouncing. 19.12 Schedule of Charges for Open Access & all Generators 19.12.1 MSEDCL has proposed following Schedule of Charges for “processing fees per application and operating charges per transaction/permissions” for non-consumers of MSEDCL as below: Load Requisitioned Processing Fees per Application (Rs.) Upto 1 MW 15,000 More than 1 MW & up to 5 MW 25,000 More than 5 MW & up to 20 MW 45,000 More than 20 MW & up to 50 MW 60,000 More than 50 MW 75,000 Operating Charges per transaction/Permissions(Rs) 20,000 40,000 19.13 MSEDCL’s reasoning for proposed Charges: a) Processing Fees: As per MERC Distribution Open Access Regulation 2016, an Open Access Consumer can avail open access from multiple generators and multiple sources. Thus no of applications are increased, MSEDCL has developed online system for submission of applications for availing open access. The no of consumers availing short term open access are more, the consumers apply every month for STOA and upload the required documents in the online system having 50 to 100 MB capacity. Thus MSEDCL have to purchase additional storage space to save all the documents every month in the online system. MSEDCL January 20 436 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition A separate IT System is developed for proper operation of the online system for submission and processing of open access applications. MSEDCL has developed online system for paying the processing fees with the applications. Thus MSEDCL has to pay service charges to service providers of online payment system. Issuance of periodical open access permissions: Maintaining OA Consumer Records and recording change of name/change of ownership, if any. b) Operating Charges: A multiple monthly joint meter reading is taken for consumers availing open access from multiple generator and multiple sources; Forwarding the metering data to the consumer end through electronic media; Separate IT system and IT staff for processing of open access bills; Providing vehicle for monthly joint meter reading. The rate of diesel is almost doubled; Deputation / deployment of Engineers and staff; Testing of generation meter; Development in open billing software as per changes in Regulations and MERC various Orders; Monitoring of daily schedule of open access consumers; Downloading and checking of schedules from WRLDC, MSLDC and Exchange website for billing; Compilation of consumer wise, date wise monthly schedule; Purchase of Meter Reading Instruments and Laptops for meter readings. 19.14 Applicable Taxes: 19.14.1 MSEDCL submits that Goods and Service Tax will be levied extra as per applicable rates on aforementioned charges. 19.14.2 Further, in case any taxes are made applicable or introduced by any Competent Authority in future, MSEDCL request to allow recovery of such charges from the respective consumers for services for which Schedule of Charges are approved. MSEDCL January 20 437 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 20 COMPLIANCE TO THE DIRECTIVES IN CASE NO. 195 OF 2017 20.1 Background 20.1.1 MSEDCL submits that the Hon’ble Commission in its Mid Term Review Order dated 12th September 2018 (Case No 195 of 2017) has given various directives to MSEDCL having different timelines for submission of their compliances. The same along with its compliances are reproduced as below: Order Ref. No. and Directives of MERC in Order 195 Compliance Status Topic of 2017 8.6.7: Feeder-based Out of 4901 Agricultural feeders with MSEDCL submits that as on 25th November 2019, out of the Metering with AMR AMR, only 1021 feeders are active total 5405 Ag feeders, 5228 nos. have been upgraded with facilities and the rest are having AMR facilities. MSEDCL is rigorously taking up the process to communication linkage problem. install AMR for the balance 177 nos. MSEDCL shall keep all the feeder MSEDCL also submits that the feeder input data for all the AMR active and start uploading data feeders (including Ag feeders) is made available at MSEDCL on its website. website on following path: Consumer Portal > Operational data > Feeder Input Data (HTTPS://CONSUMERINFO.MAHADISCOM.IN/FEEDERDATA/INDEX.PHP) 9.23.11 kVAh Metering MSEDCL to educate the consumers MSEDCL submits that it has taken up necessary steps to and take all necessary steps to ensure smooth rollout of kVAh billing. Consumer awareness ensure that all the consumers are programs were conducted. FAQs on kVAh billing were billed by kVAh method from the next uploaded on the website and many interactive sessions on the MSEDCL January 20 438 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition Order Ref. No. and Topic MSEDCL Directives of MERC in Order 195 of 2017 MYT i.e. from 1st April 2020. Compliance Status same were conducted. The consumer awareness programs received many interest from the consumers and were successfully coordinated. The next step towards kVAh metering was meter replacement. MSEDCL has already initiated meter replacement and the same for HT consumers is planned to be completed by January 2020. After completing HT meter replacement, MSEDCL will rigorously take up LT meter replacement too. The status of the same can be communicated to the Hon’ble Commission during the next MTR process. The FAQs have been annexed to this Petition as Annexure 6. January 20 439 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 21 PRAYERS TO THE HON’BLE COMMISSION 21.1.1 MSEDCL most respectfully prays to the Hon'ble Commission: 1. To admit the MYT Petition as per the provisions of the MERC (MYT) Regulations 2019 and consider present Petition for further proceedings before Hon’ble Commission; 2. To approve the total recovery of Aggregate Revenue Requirement and revenue gap for FY 2017-18 to FY 2024-25 along with other claims including Regulatory Assets as proposed by MSEDCL; 3. To allow the carrying cost on the proposed recovery required during the control period; 4. To approve mechanism for recovery of computed revenue gap along with carrying cost and Tariff Schedule considering the Tariff Design principles and other suggestions proposed by MSEDCL; 5. To allow to charge 60% of approved fixed charges for single shift HT Industrial consumers as proposed by MSEDCL; 6. To allow the revision in definition of Billing Demand as proposed by MSEDCL; 7. To allow kVAh based billing for HT category consumers; 8. To allow a rebate for incremental consumption to HT consumers of selected categories as proposed by MSEDCL; 9. To consider the incentives/rebates proposed as part of ARR; 10. To rationalize the incentives and penalties as proposed by MSEDCL; 11. To approve the revision in Load Factor Formula as proposed by MSEDCL; 12. To approve the revision in the Load Factor Incentive with a ceiling of 7.50%; 13. To approve the revision in ToD Charges as proposed by MSEDCL; 14. To approve the levy of Grid Support charges on generated energy for Net Metering systems as proposed by MSEDCL; 15. To approve the Additional Fixed/Demand Charges along with CSS for Grid Connected Renewable Energy Generating Systems connected behind the Consumer’s meter, and not opting for either Net Metering Arrangement or Net Billing Arrangement as proposed by MSEDCL; 16. To approve the kVA based Fixed Charges for 3 phase consumers having loads less than 20 kVA as proposed by MSEDCL; 17. To allow the levy of slab wise charges to LT three phase consumers based on the actual demand recorded; MSEDCL January 20 440 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Main Petition 18. To allow MSEDCL to retain the transmission charges collected from partial Open access consumers; 19. To approve levy of harmonics penalty through additional charge equivalent to 5% of Variable Charges (Wheeling Charges plus Energy Charges) for HT Industrial and HT Commercial consumers; 20. To approve Cross Subsidy Surcharge and all such other charges including wheeling charges and wheeling losses for Open Access consumers as proposed for the Control Period; 21. To approve the Additional Surcharge for Open Access Consumers irrespective of Source i.e. Captive Power Plants, IPP, RE based power plants etc. in addition to the conventional open access consumers but exempting CPPs existing prior to FY15-16, originally set up the plant for self-consumption and still continuing the same arrangement of captive use as proposed by MSEDCL 22. To allow revision in standby charges for consumers having CPP; 23. To make provision for mandatory standby arrangement by SEZ and other Deemed Licensees; 24. To allow the slab wise fixed charges for Residential category consumers as proposed by MSEDCL; 25. To approve the suggested categorization for different type of activities as proposed by MSEDCL; 26. To approve the schedule of charges as proposed by MSEDCL; 27. To approve the CAPEX and Capitalisation as submitted by MSEDCL; 28. To approve the OPEX as proposed by MSEDCL; 29. To grant any other relief as the Hon'ble Commission may consider appropriate; 30. To pass any other order as the Hon’ble Commission may deem fit and appropriate under the circumstances of the case and in the interest of justice; 31. To condone any error/omission and to give opportunity to rectify the same; 32. To permit MSEDCL to make further submissions, addition and alteration to this Petition as may be necessary from time to time; (Satish Chavan) Director (Commercial) MSEDCL MSEDCL January 20 441 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Annexures Annexure 1: Regulatory Formats (n Soft Only Excel Format) MSEDCL January 20 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Annexures Annexure 2: Annual Accounts for FY 2017-18 MSEDCL January 20 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Annexures Annexure 3: Annual Accounts for FY 2018-19 MSEDCL January 20 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Annexures Annexure 4: Interest Rate for interest paid on SD for FY 2017-18 MSEDCL January 20 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Annexures Annexure 5: Interest Rate for interest paid on SD for FY 2018-19 MSEDCL January 20 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Annexures Annexure 6: FAQs regarding kVAh Billing MSEDCL January 20 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Annexures Annexure 7: Power Point Presentation on kVAh Billing MSEDCL January 20 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Annexures Annexure 8: Investment Proof for Contingency Reserves MSEDCL January 20 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Annexures Annexure 9: Letter to MERC highlighting issues pertaining to SEZ MSEDCL January 20 Final True Up For FY 2017-18 & FY 2018-19, Provisional True Up For FY 2019-20 and Multi Year Tariff For FY 2020-21 to FY 2024-25 Annexures Annexure 10: Detailed Cost Estimation Sheet for Schedule of Charges MSEDCL January 20