True-up Petition for FY 2017-18
Submitted to
Assam Electricity Regulatory Commission
November 2018
ASSAM POWER DISTRIBUTION COMPANY LIMITED (APDCL)
BijuleeBhawan, Paltanbazar
Guwahati-781 001
ASSAM POWER DISTRIBUTION COMPANY LIMITED
BijuleeBhawan, Paltanbazar
Guwahati - 781 001
Ref: Dated:
To,
The Secretary,
Assam Electricity Regulatory Commission,
A.S.E.B. Campus, Dwarandhar,
G. S. Road, Sixth Mile,
Guwahati – 781 022
Dear Sir,
Sub: Submission of True-up Petition for FY 2017-18
In exercise of the powers conferred under Section 61 of the Electricity Act, 2003, the Hon’ble
Commission has issued the AERC (Terms and Conditions for determination of Multi Year Tariff)
Regulations, 2015for the MYT control period from FY 2016-17 to FY 2018-19.
In compliance to the aforesaid regulations, APDCL is herewith submitting the petition for
approval of true-up for FY 2017-18as per AERC (Terms and Conditions for determination of
Multi Year Tariff) Regulations, 2015for consideration and approval of the Hon’ble
Commission.The following documents are enclosed herewith for the kind perusal and approval
by the Hon’ble Commission:
1. Formal Petition, Formats and Affidavit verifying the petition along with authorization
2. Petition Fee of Rs. XX (Rupees XX only) in terms of Cheque no. …………..DatedXXdrawn on
………………………
We request the Hon’ble Commission to kindly admit the aforesaid petition and proceed further
in the matter at the earliest. We would also request the Hon’ble Commission to kindly provide
us an opportunity of personal hearing to further clarify/explain our submissions in the enclosed
petition.
Yours Faithfully,
For Assam Power Distribution Company Limited, Guwahati
(Authorized Signatory)
General Manager (Tariff Regulatory Cell)
Enclosed: As above
Table of Contents
BEFORE THE HON’BLE ASSAM ELECTRICITY REGULATORY COMMISSION, GUWAHATI ...................... 5
BEFORE THE HON’BLE ASSAM ELECTRICITY REGULATORY COMMISSION, GUWAHATI ...................... 6
NOTES AND ABBREVIATIONS ...................................................................................................................... 7
1: INTRODUCTION ................................................................................................................................... 9
ASSAM POWER DISTRIBUTION COMPANY LIMITED (APDCL) ............................................................................ 9 MULTI-YEAR TARIFF REGULATIONS, 2015 ................................................................................................... 10
2: REGULATORY REQUIREMENT OF FILING OF THE TRUE-UP PETITION ....................................... 11
REGULATIONS ............................................................................................................................................. 11 MYT TARIFF ORDER AND LAST TARIFF ORDER ............................................................................................. 12
3: METHODOLODY ADOPTED IN FILING OF THIS PETITION (INCLUDING CONSTRAINTS) ........... 13
METHODOLOGY ........................................................................................................................................... 13
4: TRUE-UP OF ARR FOR FY 2017-18 ................................................................................................... 14
CONTENTS OF THE PETITION ........................................................................................................................ 14 CATEGORY-WISE ENERGY SALES ................................................................................................................... 14 DISTRIBUTION LOSSES ................................................................................................................................. 16 ENERGY REQUIREMENT ................................................................................................................................ 19 POWER PURCHASE QUANTUM AND COST ....................................................................................................... 19 SHARING OF GAIN/(LOSS) ON ACCOUNT OF EXCESS POWER PURCHASE COST DUE TO HIGHER THAN APPROVED
DISTRIBUTION LOSSES ................................................................................................................................. 21 OPERATION & MAINTENANCE (O&M) EXPENSES ........................................................................................... 21 CAPITALISATION ......................................................................................................................................... 25 DEPRECIATION ............................................................................................................................................ 26 INTEREST & FINANCE CHARGES .................................................................................................................... 28 INTEREST ON WORKING CAPITAL .................................................................................................................. 31 INTEREST ON CONSUMER SECURITY DEPOSIT ................................................................................................. 32 OTHER DEBITS ............................................................................................................................................ 33 NET PRIOR PERIOD INCOME/EXPENSES......................................................................................................... 33 RETURN ON EQUITY ..................................................................................................................................... 34 OTHER INCOME ........................................................................................................................................... 35 NON-TARIFF INCOME ................................................................................................................................... 36 REVENUE GRANT/SUBSIDY .......................................................................................................................... 36 REVENUE FROM SALE OF POWER ................................................................................................................... 37 TRUE-UP OF ARR FOR FY 2017-18 ............................................................................................................. 37
5: PRAYER ............................................................................................................................................... 40
List of Tables
TABLE 1: ENERGY SALES FOR FY 2017-18 (MU) .............................................................................................. 15 TABLE 2: ENERGY BALANCE FOR FY 2017-18 .................................................................................................. 16 TABLE 3: TARGET VIS-À-VIS ACTUAL DISTRIBUTION LOSS OF APDCL.................................................................... 17 TABLE 4: LT: HT RATIO VIS-À-VIS ACTUAL DISTRIBUTION LOSS OF APDCL .......................................................... 18 TABLE 5: ENERGY REQUIREMENT FOR FY 2017-18 (MU) ................................................................................. 19 TABLE 6: POWER PURCHASE COST ACTUAL VIS-A-VIS APPROVED FOR FY 2017-18 .............................................. 20 TABLE 7: SHARING OF GAIN/(LOSS) ON ACCOUNT OF HIGHER DISTRIBUTION LOSSES FOR FY 2017-18 ................... 21 TABLE 8: NORMATIVE EMPLOYEE EXPENSES FOR FY 2017-18 (RS. CRORES) ....................................................... 22 TABLE 9: ROP ARREARS (RS. CRORES) ............................................................................................................. 23 TABLE 10: O&M EXPENSES FOR FY 2017-18 (RS CRORES) ............................................................................... 25 TABLE 11: CAPITAL EXPENDITURE AND CAPITALISATION FOR FY 2017-18 (RS CRORES) ...................................... 26 TABLE 12: DEPRECIATION CALCULATION FOR FY 2017-18 (RS CRORES) ............................................................ 27 TABLE 13: DEPRECIATION CLAIMED BY APDCL FOR FY 2017-18 (RS CRORES) .................................................. 27 TABLE 14: TREATMENT OF LOANS UNDER UDAY MOU CONSIDERED BY THE COMMISSION (RS CRORES) ................. 29 TABLE 15: INTEREST & FINANCE CHARGES FOR FY 2017-18 (RS CRORES) ......................................................... 29 TABLE 16: INTEREST ON GOA LOAN AND RAPDRP LOAN FOR FY 2017-18 (RS CRORES)..................................... 30 TABLE 17: REVISED CLAIM FOR INTEREST & FINANCE CHARGES FOR FY 2017-18 (RS CRORES) ............................ 31 TABLE 18: INTEREST ON WORKING CAPITAL FOR FY 2017-18 (RS CRORES)....................................................... 32 TABLE 19: ‘OTHER DEBITS’ FOR FY 2017-18 (RS CRORES) ............................................................................... 33 TABLE 20: NET PRIOR PERIOD INCOME/EXPENSE FOR FY 2017-18 (RS CRORES) ................................................. 34 TABLE 21: RETURN ON EQUITY FOR FY 2017-18 (RS CRORES) .......................................................................... 35 TABLE 22: OTHER INCOME FOR FY 2017-18 (RS CRORES) ................................................................................ 35 TABLE 23: NON-TARIFF INCOME FOR FY 2017-18 (RS CRORES) ........................................................................ 36 TABLE 24: TRUE-UP OF ARR FOR FY 2017-18 (RS CRORES) ............................................................................. 38 TABLE 25: REVENUE GAP ALONG WITH CARRYING COST FOR FY 2017-18 (RS. CRORES) ...................................... 39
True-up Petition for FY 2017-18
Assam Power Distribution Company Limited Page 5
BEFORE THE HON’BLE ASSAM ELECTRICITY REGULATORY
COMMISSION, GUWAHATI
Filing No_______________
Case No________________
IN THE MATTER OF: Filing of the Petition for approval of true-up of ARR for FY 2017-18
AND
IN THE MATTER OF: AERC MYT Regulations, 2015
AND
IN THE MATTER OF: Assam Power Distribution Company Limited (hereinafter referred to as ‘’APDCL’’ or ‘’ the Petitioner’’ or Applicant)
I, Sri Arup Kr Baruah, son of Late Jagot Baruah, aged about 59 years, General Manager (Tariff Regulatory Cell) of the Assam Power Distribution Company Ltd, having its office at 5th Floor, Bijuli Bhawan, Paltanbazar, Guwahati, Assam, PIN-781001do solemnly affirm and say as follows:
1. I am the General Manager (Tariff Regulatory Cell) of Assam Power Distribution Company Limited, the Petitioner in the above matter and am duly authorized by the said Petitioner to make this affidavit for and on behalf of Assam Power Distribution Company Limited.
2. The statements made in the petition are based on information received from official records and I believe them to reflect truly and no material has been concealed from the statements so made or documents or supporting data etc. attached.
3. Solemnly affirm at Guwahati on 15 day of December, 2018 that the contents of this affidavit are true to my knowledge, no part of it is false or no material has been concealed therefore and misleading material included therein.
Date: 15/12/2018 General Manager (Tariff Regulatory Cell) Deponent APDCL, Guwahati
True-up Petition for FY 2017-18
Assam Power Distribution Company Limited (APDCL) Page 6
BEFORE THE HON’BLE ASSAM ELECTRICITY REGULATORY
COMMISSION, GUWAHATI
Filing No_______________
Case No________________
IN THE MATTER OF: Filing of the Petition for approval of true-up of ARR for FY 2017-18
AND
IN THE MATTER OF: Assam Power Distribution Company Limited (hereinafter referred to as ‘’APDCL’’ or ‘’ the Petitioner’’ or Applicant)
The Applicant respectfully submits as under: -
1. The Petitioner is a deemed licensee under the provisions laid down in Section 14 Proviso 5, read with Section 131 (2) of the Electricity Act 2003
2. The Petitioner submits that the Hon’ble Commission has issued the following regulation namely, AERC (Terms and Conditions for determination of Multi Year Tariff) Regulations, 2015for the MYT control period from FY 2016-17 to FY 2018-19(hereinafter referred to as “MYT Regulations 2015”).
3. The said regulations are applicable to power generating stations, transmission system, SLDC and distribution system where tariff for generation, transmission, SLDC, retail or wheeling is not determined under section 63 of the Electricity Act 2003 through transparent process of competitive bidding in accordance with the guidelines issued by the Central Government.
4. The Petitioner is accordingly filing this petition for approval of true-up of ARR for FY 2017-18.
5. As per the MYT Regulations 2018, APDCL has filed the true-up of ARR for FY 2017-18on 30th
November 2018.
6. The Hon’ble commission during the TVS on 10th December’2018 identified defects in the petition and directs APDCL to submit the revised petition after rectifying the defects on or before 15th December’2018 vide order dated 10.12.2018.
7. Accordingly APDCL is submitting the revised petition as per direction.
Date: 15/12/2018 Petitioner
General Manager(Tariff Regulatory Cell)
APDCL, Guwahati
True-up Petition for FY 2017-18
Assam Power Distribution Company Limited (APDCL) Page 7
NOTE SAND ABBREVIATIONS
In this Petition:
Control Period is defined as Financial Year 2019-20, 2020-21 and 2021-22
hereinafter referred to as FY 20, FY 21 and FY 22
Ensuing Year is defined as Financial Year 2019-20 or FY 20
Current Year is defined as Financial Year 2018-19or FY 19
Previous Year is defined as Financial Year 2017-18 or FY 18
All currency figures used in this Petition, unless specifically stated otherwise, are
in Rs. Crores.
Abbreviation Full Description
AEGCL Assam Electricity Grid Corporation Limited
APDCL Assam Power Distribution Company Limited
APGCL Assam Power Generation Corporation Limited
AERC Assam Electricity Regulatory Commission
A&G Administrative & General
APR Annual Performance Review
ARR Aggregate Revenue Requirement
AT&C Aggregate Technical and Commercial
CAGR Compounded Annual Growth Rate
DDUGJY Deendayal Upadhyay Gram Jyoti Yojana
EA - 2003 The Electricity Act 2003
FY Financial Year
GFA Gross Fixed Assets
GoA Government of Assam
GoI Government of India
HT High Tension
HV High Voltage
HVDS High Voltage Distribution System
IPDS Integrated Power Development Scheme
LT Low Tension
MVA Mega Volt Ampere
MNRE Ministry of New & Renewable Energy
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Assam Power Distribution Company Limited (APDCL) Page 8
Abbreviation Full Description
MYT Multi Year Tariff
NPS National Pension Scheme
O&M Operation & Maintenance
PGCIL Power Grid Corporation of India Limited
RAPDRP Restructured Accelerated Power Development and Reforms Programme
RGGVY Rajiv Gandhi Grameen Vidyutikaran Yojana
ROP Revision of Pay
R&M Repair & Maintenance
UDAY Ujwal DISCOM Assurance Yojana
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Assam Power Distribution Company Limited (APDCL) Page 9
1: INTRODUCTION
Assam Power Distribution Company Limited (APDCL)
1.1 The Government of Assam, vide Memo No. PEL151/2003/Pt./165 dated
December 10, 2004, notified the restructuring of the erstwhile Assam State
Electricity Board (ASEB) into five entities, namely:
i. Assam Electricity Grid Corporation Limited (AEGCL) to carry out function
as State Transmission Utility (STU).
ii. Assam Power Generation Corporation Limited (APGCL) to carry out
function of generation of electricity in the State of Assam.
iii. Three Electricity Distribution Companies, namely Lower, Central and
Upper Assam Electricity Distribution Company Limited, to carry out
functions of distribution and retail sale of electricity in the districts
covered under each company area
1.2 All Companies are duly incorporated with the Registrar of Companies as per the
Companies Act, 1956. Further, in exercise of power under Section 172 of the
Electricity Act 2003, the Government of Assam authorized ASEB to continue its
trading functions by periodic notification till September 2009.
1.3 As per the Government of Assam Notification No. PEL.41/2006/199 dated May
13, 2009, in accordance with the Assam State Reform (Transfer and merger of
Distribution Functions and undertakings) scheme, 2009, CAEDCL and UAEDCL
Distribution Companies merged with the LAEDCL, thereby forming one
distribution company for the State. The name of the Company was changed from
LAEDCL to Assam Power Distribution Company Limited (APDCL) vide Certificate
of Incorporation dated October 23, 2009. The Government of Assam vide
Notification dated March 12, 2013 dissolved ASEB under Section 131 of the Act
with effect from March 31, 2013 and transferred ASEB’s current functions and
reassigned its personnel to its successor entities namely APDCL, AEGCL and
APGCL in accordance with the Scheme of Reorganization.
1.4 The Company is a Distribution Licensee within the meaning of Section 2 (17) of
Electricity Act 2003. Further, Section 42 and 43 of the Electricity Act 2003
prescribes the following major duties of the Distribution Licensee:
To develop and maintain an efficient, co-ordinate and economical
distribution system;
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Assam Power Distribution Company Limited (APDCL) Page 10
To supply electricity on an application of the consumer in accordance with
the provisions specified in the Electricity Act 2003;
To provide non-discriminatory open access to the consumers;
To establish a forum for redressal of grievances of the consumers;
Multi-Year Tariff Regulations, 2015
1.5 The Hon’ble Commission in exercise of the powers conferred under Section 61
read with Section 181(2) (zd) of the Act, has notified the Assam Electricity
Regulatory Commission (Terms and Conditions for determination of Multi Year
Tariff) Regulations, 2015 (hereinafter referred as “MYT Regulations 2015”) on
June 2’ 2015. These Regulations are applicable for determination of Tariff for
Generation, Transmission, SLDC, Wheeling and Retail Supply for the Control
Period of three financial years from April 1’ 2016to March 31’ 2019. These
regulations are applicable to all existing and future Generating Companies,
Transmission Licensees and Distribution Licensees within the State of Assam.
1.6 It is submitted that the true-up petition for FY 2017-18 is being filed in
accordance with the provisions of MYT Regulations 2015 and the provisional
accounts for FY 2017-18.
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Assam Power Distribution Company Limited (APDCL) Page 11
2: REGULATORY REQUIREMENT OF FILING OF THETRUE-UP
PETITION
Regulations
2.1 This petition is based on the following regulations notified by the Assam
Electricity Regulatory Commission (AERC):
Assam Electricity Regulatory Commission (Terms and Conditions for
determination of Multi Year Tariff) Regulations, 2015 - applicable for
determination of tariff in all cases covered under these Regulations from
1stApril, 2016 to 31st March 2019.
2.2 The MYT Regulations 2015 have been referred to for filing of the true-up petition
for FY 2017-18.
2.3 The Hon’ble Commission in its MYT Regulations, 2015 has directed the licensees
to file true-up of the previous year and corresponding adjustment of revenue
gap/surplus in the ensuing year. The relevant clauses of MYT Regulations 2015
are reproduced below;
‘’10.2 The Generating company, Transmission Licensee and the Distribution
Licensee shall file an application for annual performance review of current year,
true-up of previous year and tariff for the ensuing year not less than 120 days
before the close of each year of the control period..
Provided that the Generating Company or Transmission Licensee or Distribution
Licensee or SLDC, as the case may be, submit to the Commission information in
such form as may be stipulated by the Commission, together with the Accounting
Statements, extracts of books of account and such other details as the Commission
may require to assess the reasons for and extent of any variation in financial
performance from the approved forecast of Aggregate Revenue Requirement and
expected revenue from tariff and charges
Provided that the information sought by the Commission shall be submitted in the
formats as prescribed by the Commission.’’
2.4 Regulation 10 of the MYT Regulations, 2015, as amended in November
2017,specifies that the Commission shall undertake APR and True-up for the
respective years of the Control Period from FY 2016-17 to FY 2018-19, as
reproduced below:
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Assam Power Distribution Company Limited (APDCL) Page 12
“10.3 The scope of the annual review and True up shall be a comparison of the
actual performance of the Generating Company or Transmission Licensee or SLDC
or Distribution Licensee with the approved forecast of Aggregate Revenue
Requirement and expected revenue from tariff and charges and shall comprise the
following:
True Up: a comparison of the audited performance of the applicant for the previous
financial year with the approved forecast for the financial year and truing up of
expenses and revenue in line with Regulation 11including pass through of impact of
uncontrollable items;..’’
2.5 As per Regulation 19 of the MYT Regulations, 2015 the generating company and
the licensee shall submit the true-up of the previous year by 30th November of
each year of the control period. Accordingly, the said petition is being filed by the
licensee.
MYT Tariff Order and Last Tariff Order
2.6 The Commission had issued the Business Plan Order for the control period from
FY 2016-17 to FY 2018-19 on September 1’ 2016. The MYT order for the same
was issued on March 31’ 2017. In the MYT order, the Commission had approved
the ARR for FY 2017-18. Subsequently, in the latest tariff order dated March 19’
2018, the Commission had carried out the Annual Performance Review (APR) for
FY 2017-18.
2.7 The true-up of ARR for FY 2017-18 is being submitted by comparing the actual
performance for FY 2017-18 with the values as approved in the MYT order dated
March 31’ 2017.
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Assam Power Distribution Company Limited (APDCL) Page 13
3: METHODOLODYADOPTED IN FILING OF THIS PETITION
(INCLUDING CONSTRAINTS)
Methodology
3.1 APDCL is submitting the true-up of ARR for FY 2017-18 based on the available
provisional accounts. It consists of details of actual expenditures incurred and
details of revenue leading to actual revenue gap/surplus for the period from
April 2017 to March 2018. The Petitioner has proposed the true-up of ARR for FY
2017-18 as per the provisions of the MYT Regulations 2015. The present true-up
of ARR for FY 2017-18 is being filed based on the provisional accounts and the
data as available with APDCL. The same would be adjusted/revised based on the
audited accounts, if made available during the course of scrutiny of the petition
or as and when available.
3.2 The true-up of ARR for FY 2017-18 is being submitted by comparing actual
performance (based on accounts) with the values as approved in the MYT order
dated March 31’ 2017.
3.3 The Petitioner humbly requests the Hon’ble Commission to approve the true-up
of ARR for FY 2017-18 as submitted.
True-up Petition for FY 2017-18
Assam Power Distribution Company Limited (APDCL) Page 14
4: TRUE-UP OF ARR FOR FY 2017-18
Contents of the Petition
4.1 This petition has in detail, the true-up of ARR for FY 2017-18. The following
section explains in detail the key elements of determination of ARR and thereby
the revenue gap/(surplus) of the utility.
4.2 Determination of Aggregate Revenue Requirement by validating the actual
figures taken from the audited accounts of the following costs, other income &
returns:
i. Power Purchase Cost
ii. Operation& Maintenance Cost
iii. Depreciation
iv. Interest & Finance Charges
v. Interest on Working Capital
vi. Interest on Consumer Security Deposits
vii. Other Debits
viii. Net Prior Period Expenses/(Credit)
ix. Return on Equity
x. Other Income
xi. Non-Tariff Income
4.3 The revenue includes revenue from sale of power and revenue grant/subsidy
figures to arrive at the revenue gap/ (surplus) for the utility.
Category-wise Energy Sales
4.4 The Commission had approved energy sales of 7107 MU in the APR for FY 2017-
18 in the tariff order dated March 19’ 2018. Against approved energy sales of
7107 MU, actual sale is 6814MU. The actual category-wise energy sales vis-à-vis
earlier approved energy sales is as depicted in the table below.
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Assam Power Distribution Company Limited (APDCL) Page 15
Table 1: Energy Sales for FY 2017-18 (MU)
Particulars FY 2017-18
MYT Order
Submitted in APR
Approved in APR
True-up % inc
(+)/dec (-) JEEVAN DHARA 565 465 610 669 18.38% DOMESTIC A Total 3134 2893 2889 2727 -13.00% Domestic-B above 5 kw to 20kw 288 284 291 277 -3.92% Commercial Load above 0.5 to 20kw 693 684 690 627 -9.52% General Load upto 20 kw 136 120 121 99 -27.29% Public Lighting 23 16 17 13 -44.70% Agriculture upto 7.5 HP 17 22 18 20 16.06% Small Industries Rural upto 20kw 61 71 71 66 7.82% Small Industries Urban 32 32 35 30 -4.94% Temporary 6 6 8 7 22.00% LT TOTAL 4955 4592 4750 4534 -8.49% HT Domestic 20kw and above 46 32 36 31 -32.72% HT Commercial 20kw & above 395 398 426 352 -10.89% Public Water Works 71 83 95 71 -0.06% Bulk Supply Govt. Edu Inst 94 88 95 76 -19.35% Bulk Supply Others 414 439 410 383 -7.42% HT Small Industries upto 50 kw 23 29 27 23 1.48% HT Industries-I 50kw to 150 kw 88 90 82 67 -24.23% HT Industries-II above 150 kw 793 673 617 702 -11.51% Tea Coffee & Rubber 442 554 437 484 9.53% Oil & Coal 182 94 112 76 -58.37% HT Irrigation Load above 7.5 HP 22 25 21 15 -31.86% HT TOTAL 2570 2506 2358 2280 -11.30% TOTAL Energy Sales (excluding OA consumption)
7524 7098 7107 6814 -9.44%
4.5 The actual sale has shown a decline of ~9.44% vis-à-vis approved energy sales as
per the MYT order. It is to be noted that actual energy sales for FY 2017-18 are
more than the actual energy sales for FY 2016-17, both for the LT and HT
category. The Commission had approved actual energy sales of 6526 MU during
true-up of FY 2016-17. LT sales for FY 2017-18 has shown an increase of ~6.16%
over LT sales for FY 2016-17 and HT sales for FY 2017-18 has shown an increase
of ~1.09% over LT sales for FY 2016-17. Overall, sales of FY 2017-18 are more
than the actual energy sales for FY 2016-17 by ~4.41%.
4.6 It is to be noted that the sales to the Jeevan Dhara category have shown an
increase of 18.38% over the MYT approved energy sales, primarily due to the
implementation of the Saubhagya scheme. Further, the energy sales of the cross-
subsidising categories particularly HT-I, HT-II and Oil & Coal have shown a
decline over the approved MYT energy sales, thereby impacting the revenue
realisation of the utility.
4.7 It is observed that the LT sales have shown a higher increase compared to the
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Assam Power Distribution Company Limited (APDCL) Page 16
increase in the HT sales over FY 2016-17 sales. Primary reason for this is the
massive rural electrification being undertaken through various ongoing flagship
programs like RGGVY/DDUGJY and Saubhagya scheme of Govt. of India. Such
programs have led to manifold increase in domestic consumers in a small span of
time. Further, the supply hours to rural areas have also increased in the last few
years owing to greater availability of power and the vision of moving towards
24x7 power for all. This has resulted in increased sales for LT categories
especially for the Jeevan Dhara and small domestic consumers. Massive rural
electrification and availing of power through open access route by some HT
consumers in the recent years has resulted in inverse HT: LT ratio against the
commercial proposition of APDCL. This reversal of trend and corresponding
trend of distribution losses is discussed subsequently under the head of
‘Distribution Losses’.
4.8 The Petitioner requests the Hon’ble Commission to approve actual retail
energy sales of 6814 MU (excluding OA consumption) for true-up of ARR
for FY 2017-18 since it is uncontrollable.
Distribution Losses
4.9 The Commission in the business plan order dated September 1’ 2016 had
approved distribution loss of 17.35%, 17.10% and 16.85% for FY 2016-17, FY
2017-18 and FY 2018-19 respectively. The Commission during APR of FY 2017-
18 vide tariff order dated March 19’ 2018 had maintained the same approved
distribution loss target of 17.10%.
4.10 The Petitioner during FY 2017-18 has achieved actual distribution loss of
17.64% against the target of 17.10% even with various constraints i.e. adverse
HT: LT Ratio, incremental sale to LT consumers, old infrastructure etc.The actual
distribution loss for FY 2017-18 has been arrived at by considering the actual
quantum of power purchase, losses in inter-state and intra-state transmission
and actual sales to the consumers of the utility. The energy balance for FY 2017-
18 is as shown below.
Table 2: Energy Balance for FY 2017-18
S. No. Sources FY 2017-18
1 Input from Central Sector Generators (MU) 6138.12
2 Input from APGCL (MU) 1423.25
3 Input from DLF (IPP) (MU) 0.00
4 Input from MeECL (MU) 0.55
5 Input from NCE Sources (MU) 61.84
6 Input from IOCL(AOD) (MU) 0.00
7 Input from UI Pool (MU) 350.92
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Assam Power Distribution Company Limited (APDCL) Page 17
S. No. Sources FY 2017-18
8 Input from Trader + IEX (MU) 1389.85
9 Total Power Purchase (MU) 9364.54
10 PGCIL Loss (MU) 121.86
11 Loss in PGCIL% (11= 10/(1+8)) 1.62%
12 Energy Available for Sale (MU) 9242.68
13 Trading Sale/Export under PSA (MU) 670.58
14 Energy Available for Sale to discoms (MU) (14 = 12 -13) 8572.10
15 Tr Loss of AEGCL (%) 3.49%
16 Energy available to DISCOM (MU) 8272.93
17 Distribution Loss (MU) (17 = 16 – 19) 1459.13
18 Distribution Loss (%)(18 = 17/16) 17.64%
19 Energy Sold(MU) 6813.81
4.11 The past years actual distribution loss of APDCL against the target approved by
the Commission is shown in the following table:
Table 3: Target vis-à-vis actual distribution loss of APDCL
Year Approved Loss (%) Actual Loss Level (%)
2005-06 29.95 31.10
2006-07 30.71 29.43
2007-08 25.05 27.32
2008-09 24.24 24.32
2009-10 22.60 26.06
2010-11 21.60 25.44
2011-12 20.60 26.61
2012-13 19.60 25.85
2013-14 18.60 24.11
2014-15 18.60 21.14
2015-16 17.60 18.12
2016-17 17.35 17.89
2017-18 17.10 17.64
4.12 It is seen that over the years the utility has been able to bring down the losses
gradually. It is pertinent to mention that with specific programs like DSM
initiatives, creation of dedicated cells to monitor high value consumers etc.
APDCL has been able to bring down the loss level significantly even with
restricted resources. The Petitioner, humbly submits that despite the best efforts
of the utility to achieve the target distribution losses, it is getting much more
difficult to reduce the distribution losses now at the same rate as achieved in the
past years.The HT: LT ratio is getting adverse every year as LT sales are
increasing on account of extensive rural electrification and HT sales are not
increasing at the same rate as it is impacted due to other factors like lack of
industrial growth in the state, etc.
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Assam Power Distribution Company Limited (APDCL) Page 18
4.13 Year on year sales mix of APDCL and corresponding distribution losses of APDCL
are as depicted below:
Table 4: LT: HT ratio vis-à-vis actual distribution loss of APDCL
4.14 It is understood that HT: LT ratio has a key impact on overall distribution losses
of the state and with the present trend of inverse HT: LT ratio, there is a need to
revisit the distribution loss target. Losses increase with increase in LT
consumption at the same performance levels. APDCL requests the Hon’ble
Commission to review the T&D loss targets based on the actual achievements
and the above concerns, while executing the truing-up exercise.
4.15 The distribution loss scenario of APDCL is also to be seen from the aspect of
overall situation prevailing in some parts of the state. It may be seen that in
predominantly urban areas as well as areas without any social disturbances, the
utility was able to achieve distribution loss far below the approved loss levels.
However, in some areas where the situation is beyond reasonable control of the
licensee, the losses have crossed the approved limit. Further, consumer
behaviour ofcertain areas under APDCL is at variance from others. Frequent
bandh as well as perennial natural calamities in some part of the State affects the
performance in these areas resulting in higher losses.
4.16 Considering the past actually achieved distribution loss levels, increase in
consumption of LT sales and deferred implementation of various schemes
as per the approved capital investment plan, the Petitioner requests the
Hon’ble Commission to approve actual distribution loss of 17.64% for FY
2017-18.
4.17 Any deviation in the distribution losses vis-à-vis the approved losses directly
affects thepower purchase requirement of the licensee. If the losses are higher,
FY LT Sales (MU) (%)
HT Sales (MU) (%)
Distribution Loss (%)
2008-09 1489(49%) 1555(51%) 24.32
2009-10 1573(48%) 1674(52%) 26.06
2010-11 1769(50%) 1767(50%) 25.44
2011-12 2026(51%) 1944(49%) 26.61
2012-13 2176(52%) 2029(48%) 25.85
2013-14 2593(54%) 2170(46%) 24.11
2014-15 3228(59%) 2257(41%) 21.14
2015-16 3886(63%) 2313(37%) 18.12
2016-17 4270(65%) 2256(35%) 17.89
2017-18 4534 (67%) 2280 (33%) 17.64
True-up Petition for FY 2017-18
Assam Power Distribution Company Limited (APDCL) Page 19
the power purchase requirements would go up resulting in a loss to the licensee
or if the losses are lower, the power purchase requirements would go down
resulting in saving in the power purchase costs thus resulting in gain.
4.18 Further, considering the age of assets vis-à-vis restricted R&M allowance as
per the regulations, the Hon’ble Commission is requested to consider the
actual distribution loss of 17.64% in the true-up of ARR for FY 2017-18.
Energy Requirement
4.19 Based on actual sales, actual distribution losses and inter-state and intra-state
transmission losses, the actual energy requirement for the year is as below.
Table 5: Energy Requirement for FY 2017-18(MU)
Particulars FY 2017-18
MYT Order Submitted
in APR Approved
in APR True-up
Energy Sales (MU) 7524 7098 7107 6,814 Distribution Loss (%) 17.10% 17.10% 17.10% 17.64% Energy Requirement at Distribution Periphery T-D (MU)
9,076 8,562 8,574 8,273
Intra-State Transmission Loss (%) 3.49% 3.49% 3.49% 3.49% Energy input to Transmission System (MU)
9,404 8,871 8,884 8,572
Inter-State (PGCIL) Pooled Loss (MU) 139 114 114 122 Total Energy Requirement (MU) * 9,544 8,985 8,998 8,694
Note: * - Excluding trading sales quantum of 670.58 MU
Power Purchase Quantum and Cost
4.20 Power procurement of APDCL is largely dependent on the state generating
stations of APGCL and central generating stations to meet its base load. However,
in order to meet the peak demand of the state, APDCL ties up with the short-term
sources like traders and also sources power from Power Exchanges.
4.21 During FY 2017-18, APDCL incurred expenditure of Rs. 4506.31 Crores for
purchase of 9364.54 MU as against the approved cost of Rs. 4376.30 Crores for
9543.76 MU as approved in the MYT order for FY 2017-18.
4.22 This increase in power purchase cost can be mainly attributed to the following
factors:
Increase in the total quantum of power sourced from allocated sources
with compulsion as compared to the approved quantum at higher rate
True-up Petition for FY 2017-18
Assam Power Distribution Company Limited (APDCL) Page 20
Even with additional power from allocated sources, APDCL has to procure
power from additional sources i.e. through bilateral trading, energy
exchange etc. To mitigate gradually increasing demand particularly in peak
hours
4.23 The total power purchase cost for the company for FY2017-18 comprises of the
basic power purchase cost, transmission charges payable to AEGCL (inclusive of
PGCIL charge & special charge on BST). Based on the same, the comparison of the
power purchase is as shown in the table below.
Table 6: Power Purchase Cost actual vis-a-vis approved for FY 2017-18
Quantum
(MU)
Cost
(Rs Crore)
Average
rate
(Rs/kwh)
Quantum
(MU)
Cost
(Rs Crore)
Average
rate
(Rs/kwh)
Quantu
m (MU)
Cost
(Rs Crore)
Average
rate
(Rs/kwh)
APGCL 2209.03 582.63 2.64 1423.25 415.07 2.92 -785.78 -167.56 0.28
CSGS NER
Kopili HEP 350.0 39.55 1.13 550.89 57.71 1.05 200.89 18.16 -0.08
Kopili HEP - II 50.0 8.15 1.63 57.60 7.70 1.34 7.60 -0.45 -0.29
Khandong HEP 95.0 16.72 1.76 141.73 22.60 1.59 46.73 5.88 -0.17
RHEP 560.0 113.68 2.03 600.51 174.43 2.90 40.51 60.75 0.87
DHEP 70.0 30.59 4.37 113.64 54.72 4.82 43.64 24.13 0.45
AGBPP 930.0 325.50 3.50 824.96 280.64 3.40 -105.04 -44.86 -0.10
AGTPP+AGTPP2 345.0 106.73 3.09 267.53 98.62 3.69 -77.47 -8.11 0.59
NHPC 150.0 42.45 2.83 238.31 63.91 2.68 88.31 21.46 -0.15
OTPC 1100.0 314.60 2.86 1269.32 384.08 3.03 169.32 69.48 0.17
NTPC, BTPS* 1576.7 900.28 5.71 1007.75 645.45 6.40 -568.92 -254.83 0.69
CSGS NER GROSS 5284.67 1918.55 3.63 5072.23 1789.86 3.53 -212.44 -128.69 -0.10
CSGS ER
Farakka 250.00 83.25 3.33 222.62 79.26 3.56 -27.38 -3.99 0.23
Kahalgaon I 130.00 46.28 3.56 115.02 42.28 3.68 -14.98 -4.00 0.12
Kahalgaon II 540.00 211.14 3.91 550.90 194.92 3.54 10.90 -16.22 -0.37
Talcher 140.00 37.52 2.68 141.73 39.01 2.75 1.73 1.49 0.07
CSGS ER GROSS 1060.0 378.19 3.57 1030.3 355.48 3.45 -29.73 -22.71 -0.12
OTHERS
HHPCPL 9.80 4.03 4.11 8.55 3.51 4.11 -1.25 -0.52 0.00
IOCL(AOD) 27.20 10.53 3.87 -27.20 -10.53 -3.87
MeECL 28.60 17.13 5.99 0.55 0.40 7.30 -28.05 -16.73 1.31
SECI Solar 31.00 18.68 6.03 39.17 24.41 6.23 8.17 5.73 0.21
JNNSM Solar Bundled 9.60 11.12 11.58 7.97 9.83 12.33 -1.63 -1.29 0.75
Suryatap Solar* 0.56 0.54 9.64 6.15 5.45 8.86 5.59 4.91 -0.78
Pohmura SHEP* 0.47 0.14 2.98 #DIV/0! -0.47 -0.14
JNNSM Coal Bundled 35.00 10.96 3.13 35.62 11.48 3.22 0.62 0.52 0.09
TRADING PURCHASE 261.18 60.07 2.30 632.09 250.34 3.96 370.91 190.27 1.66
IEX IN 586.65 134.93 2.30 757.76 317.40 4.19 171.11 182.47 1.89
Additional Solar RPO (RECs) 20.71 #DIV/0! 3.88 #DIV/0! -16.83
Additional Non-solar RPO(RECs) 15.70 #DIV/0! 18.16 #DIV/0! 2.46
OTHERS GROSS 990.06 304.54 3.08 1487.86 644.88 4.33 497.80 340.34 1.26
Deviation Settlement Mechanism 350.92 93.93 2.68 350.92 93.93 2.68
TOTAL BUY 9543.8 3183.91 3.34 9364.5 3299.22 3.52 -179.22 115.31 0.19
Transmission Charges 1192.39 1.25 1207.09 1.29 14.70 0.04
Total Power Purchase Cost 9543.8 4376.30 4.59 9364.54 4506.31 4.81 -179.22 130.01 0.23
Approved (MYT) Actual Deviation
Agency/Source
4.24 The power purchase cost of the utility (on gross basis) for FY 2017-18 is Rs.
4506.31 Crores. The rebate on timely payment of power purchase of Rs. 10.07
True-up Petition for FY 2017-18
Assam Power Distribution Company Limited (APDCL) Page 21
Crores has been considered under the head of ‘Other Income’ and has been
adjusted there.
4.25 The Petitioner, humbly requests the Hon’ble Commission to approve the
actual power purchase cost of the utility during true-up of ARR for FY 2017-
18.
Sharing of gain/(loss)on account of excess power purchase cost due to higher
than approved Distribution Losses
4.26 As the actual distribution losses are higher than the approved distribution losses
for FY 2017-18, the efficiency loss on account of higher than approved
distribution losses, in terms of excess power purchase expenses, have been
shared between APDCL and the consumers, as shown in the table below.
Table 7: Sharing of gain/(loss) on account of higher distribution losses for FY 2017-18
Particulars Unit FY 2017-18
Total Power Purchase including trading sales MU 9365
Allowable Energy Purchase for sale within
State MU 9309
Excess Energy Purchase MU 56
Average power purchase rate Rs/kWh 3.52
Excess Power Purchase Cost Rs. Crores (19.68)
Share of gain/(loss) to be borne by APDCL Rs. Crores (13.12)
Share of gain/(loss) to be borne by consumers Rs. Crores (6.56)
4.27 Therefore, the loss of Rs. 13.12 Crores has been considered to be borne by the
Petitioner in accordance with the MYT Regulations 2015.
Operation & Maintenance (O&M) Expenses
4.28 The Operation and Maintenance (O&M) Expenses comprise of the following
elements:
Employee Expenses
Repair and Maintenance (R&M) Expenses
Administrative and General (A&G) Expenses
4.29 Each of the expense heads are discussed herein below.
True-up Petition for FY 2017-18
Assam Power Distribution Company Limited (APDCL) Page 22
Employee Cost
4.30 Employee expenses comprise of salaries, dearness allowance, bonus, terminal
benefits in the form of contribution for pension and gratuity funding, leave
encashment, and staff welfare expenses.
4.31 It is to be noted that the Commission had provisionally considered Rs. 28.88
Crores towards Revision of Pay (ROP) during APR of FY 2017-18. This was
considered over and above the normative employee expenses of Rs. 694.69
Crores for FY 2017-18. The Revision of Pay (ROP) 16 is applicable from January
2016; the implementation of ROP 16 in APDCL took place in December 2017,
consequently, the impact of ROP 16 was affected in the salaries for the period
January to March 2018. The remaining pending arrears due on account of ROP
16 will be paid along with the salaries for FY 2018-19.
4.32 In this regard, it is submitted that the amount shown under the head of
‘Employee Benefit Expenses’ in the books of accounts is Rs. 742.06 Crores
pertaining to the period FY 2017-18. The provision against ROP duesas
considered in the books of accounts is Rs. 122.67 Crores. The pending arrears on
account of ROP will be paid during FY 2018-19. The provision of Rs. 122.67
Crores has been made against ROP dues.
4.33 The normative calculation of employee expenses for FY 2017-18 is as below.
Table 8: Normative employee expenses for FY 2017-18 (Rs. Crores)
Particulars FY 2017-18
MYT Order
Submitted in APR
Approved in APR
True-up Deviation
Employee Expenses for Previous Year 640.20 640.20 Growth Factor 3% 3% CPI Inflation 5.35% 3.08% Employee Expenses 728.12 777.96 694.69 679.72 Add: Revision of Pay Impact (ROP 16) 28.88 122.67 Total Employee Expenses 728.12 777.96 723.57 802.39 74.27
4.34 The Petitioner requests the Hon’ble Commission to approve normative employee
expenses of Rs. 802.39 Crores for true-up of ARR for FY 2017-18, including the
impact of ROP of Rs. 122.67 Crores.
4.35 The detailed calculation of the ROP arrears of Rs. 122.67 Crores is as below.
True-up Petition for FY 2017-18
Assam Power Distribution Company Limited (APDCL) Page 23
Table 9: ROP arrears (Rs. Crores)
ParticularsPay
Liability
NPS
Employer
Contributi
on
Pension
Contributio
n Liability
Total ParticularsPay
Liability
NPS
Employer
Contributi
on
Pension
Contribut
ion
Liability
TotalGrand
Total
Already
releasedBalance
Apr-16 6.27 0.20 0.98 7.46 Apr-17 5.71 0.22 0.82 6.74
May-16 6.22 0.20 0.97 7.40 May-17 5.67 0.22 0.81 6.70
Jun-16 6.19 0.21 0.96 7.36 Jun-17 5.62 0.22 0.80 6.63
Jul-16 6.17 0.21 0.96 7.33 Jul-17 6.17 0.24 0.87 7.28
Aug-16 6.14 0.21 0.95 7.29 Aug-17 6.12 0.24 0.86 7.23
Sep-16 6.10 0.21 0.94 7.25 Sep-17 6.08 0.24 0.85 7.18
Oct-16 5.89 0.20 0.91 7.00 Oct-17 6.02 0.24 0.84 7.10
Nov-16 6.02 0.21 0.92 7.14 Nov-17 6.45 0.29 0.84 7.57
Dec-16 6.03 0.21 0.91 7.15 Dec-17 -
Jan-17 6.03 0.22 0.90 7.14 Jan-18 -
Feb-17 5.83 0.22 0.85 6.90 Feb-18 -
Mar-17 5.78 0.22 0.84 6.84 Mar-18 -
TOTAL 72.67 2.51 11.08 86.26 TOTAL 47.82 1.91 6.70 56.43
142.69 20.20 122.49
4.36 The Petitioner requests the Commission to consider the effect of ROP while
approving normative employee expenses for FY 2018-19 and for the control
periodfrom FY 2019-20 to FY 2021-22.
4.37 The Petitioner requests the Hon’ble Commission to allow normative employee
expenses of Rs. 802.39 Crores for FY 2017-18. The Petitioner requests the
Commission to allow normative employee expenses for FY 2017-18.
R&M Expenses
4.38 R&M Expenses are incurred for daily upkeep of the distribution network and
forms an integral part of the company's efforts towards reliable and quality
power supply.
4.39 R&M Expenses are dependent on various factors. It is to be submitted that most
of its assets are old and not adequately maintained from time to time primarily
due to restricted allowance in tariff for many previous years. Regular
maintenance of assets is prerequisite to ensure uninterrupted operations. APDCL
has been trying its best to ensure uninterrupted operations of the system and
accordingly has been undertaking necessary expenditure for R&M activities.
Considering this fact, the expenditure incurred on R&M activities are
uncontrollable in nature.
4.40 Against approved cost of Rs. 103.21 Crores on normative basis during the MYT
order, the actual expenditure incurred is Rs. 124.26 Crores.
4.41 Such deviation is mainly due to the following factors:
Restricted approval for R&M merely on the basis of regulation irrespective
of the age vis- à-vis health of infrastructure for many previous years
True-up Petition for FY 2017-18
Assam Power Distribution Company Limited (APDCL) Page 24
Outsourcing for operation & maintenance of many sub-stations due to
severe human resource constraints
4.42 The Petitioner requests the Commission to allow actual R&M expenses of Rs.
124.26 Crores for FY 2017-18 and not consider approval based on normative
approach linked to K factor and WPI index as it does not adequately cover the
actual expense incurred on R&M of assets, considering the age of assets. The
ageing infrastructure of the utility necessitates higher R&M expenditure for
maintaining system operations and thereby are uncontrollable in nature.
Considering the above, the actual R&M expenses should be allowed in entirety.
A&G Expenses
4.43 A&G Expenses mainly comprise of rents, taxes, various statutory charges,
telephone and other communication expenses, professional charges, legal
charges, conveyance & travelling allowance etc.
4.44 The Commission had approved A&G expenses of Rs. 38.82 Crores for FY 2017-18
on normative basis in the MYT order. Actual A&G expenses are Rs. 44.72 Crores,
as per statement of accounts for FY 2017-18.
4.45 It is to be noted that actual A&G expenses depend on the growth in the business
size requiring higher operational activity thereby resulting in higher expenses in
addition to the inflation factor. Further, the increase is also due to uncontrollable
reasons like increase in telephone charges, water charges and increase in other
statutory taxes etc. vis-à-vis the lump-sum amount approved as per the
regulations on normative basis.
4.46 Considering the above, the Petitioner requests the Commission to allow actual
A&G expenses of Rs. 44.72 Crores for FY 2017-18.
4.47 Further, the Petitioner requests the Commission to allow actual A&G expenses
for FY 2017-18 and not consider approval based on normative approach linked
to WPI index as it does not adequately cover the actual expenditure under the
head of A&G expenses.
Total O&M Expenses for FY 2017-18
4.48 The summary of the total O&M expenses being claimed as part of the true-up of
ARR for FY 2017-18 vis-à-vis approved earlier is as below.
True-up Petition for FY 2017-18
Assam Power Distribution Company Limited (APDCL) Page 25
Table 10: O&M Expenses for FY 2017-18(Rs Crores)
Particulars (in Rs. Crores) FY 2017-18
MYT Order
Submitted in APR
Approved in APR
True-up Deviation
Employee Expenses 728.12 777.96 723.57 802.39 74.27 R&M Expenses 103.21 109.35 109.41 124.26 21.05 A&G Expenses 38.82 59.96 35.19 44.72 5.90 Total O&M Expenses 870.15 947.27 868.17 971.37 101.22
4.49 It is submitted that the total O&M Expenses amounting to Rs. 971.37 Crores
be allowed by the Hon’ble Commission in the true-up of ARR for FY 2017-
18.
Capitalisation
4.50 The Petitioner submits that the actual capitalisation achieved during the year is
Rs. 211.46 Crores. The net addition to the GFA for the purpose of computing the
depreciation is Rs. 20.18 Crores, while Rs. 186.25 Crores is towards assets not
belonging to APDCL, and Rs. 5.03 Crores is funded by Consumer Contribution.
The Commission had approved capitalisation of Rs. 1041.35 Crores in the APR of
FY 2017-18. The reasons for low capitalisation achieved during FY 2017-18 are
as:
Delay in receipt of funds for various schemes
Deferred implementation of various schemes as per the last business plan
order
Delay in approval of schemes
Further, most of the schemes are being implemented in packages (e.g. RGGVY/12th Plan package A/B/C etc.).The capitalization is done only after completion of the entire package
4.51 The Petitioner requests the Hon’ble Commission to approve actual capitalisation
of Rs. 211.46 Crores during true-up of ARR for FY 2017-18.
4.52 The capital expenditure and CWIP summary for FY 2017-18 is as shown below.
True-up Petition for FY 2017-18
Assam Power Distribution Company Limited (APDCL) Page 26
Table 11: Capital expenditure and capitalisation for FY 2017-18 (Rs Crores)
Particulars FY 2017-18
MYT Order
Submitted in APR
Approved in APR
True-up
Opening CWIP 3812.96 2897.86 3,456.98 2,897.86 Capital Expenditure 1,000.00 1789.65 1,789.65 735.32 Capitalisation 650.00 2227.09 1,041.35 211.46 Closing CWIP 4162.96 2460.42 4,205.28 3,421.72
4.53 The Petitioner requests the Hon’ble Commission to approve the above said
capitalisation for FY 2017-18.
Depreciation
4.54 As per Regulation 33.2 of the MYT Regulations, 2015, the total depreciation
during the life of the asset shall not exceed 90% of the original cost of GFA.
Commission has computed the depreciation separately for assets added under
each asset head for the year. The Commission has disallowed the depreciation on
assets where depreciation is in excess of 90% of the original cost of asset under
different asset heads. The Commission did not consider depreciation on assets
funded through grants in accordance with Regulation 31 and 33 of MYT
Regulations, 2015. The Commission considered the conversion of loan to grant
under the UDAY Scheme during APR of FY 2017-18.
4.55 For computation of depreciation, the Commission considered the approved
closing GFA for FY 2016-17 as the opening GFA for FY 2017-18. The
capitalization approved for the year was considered as asset addition during the
year. The Commission considered the scheduled depreciation rates as specified
in MYT Regulations, 2015. Accordingly, the Commission approved Rs. 18.47
Crores on account of depreciation during APR for FY 2017-18.
4.56 Opening Gross Block of Fixed Assets for FY 2017-18 as per the statement of
accounts is Rs. 3612.16 Crores, out of which assets not belonging to the company
are Rs. 1424.35 Crores and assets created out of consumer contribution are Rs.
223.44 Crores. Depreciation has been calculated taking into consideration the
opening as well as addition of assets during FY 2017-18 as per statement of
accounts. While actual depreciation as per Companies Act is shown in the
statement of account, truing-up claim has been made after recalculating the same
as per AERC Regulations and is shown in the table below.
True-up Petition for FY 2017-18
Assam Power Distribution Company Limited (APDCL) Page 27
Table 12: Depreciation calculation for FY 2017-18(Rs Crores)
ParticularsAs on
01.04.17
Net
addition
during the
year
Rate of DepAccumulated as
on 01.04.17
Assets fully
depreciatedOn OB
On
AdditionTotal
Land & Rights
i) Land owned under full title 15.61 - - - - -
ii) Leasehold land 2.22 - 3.34% 0.07 0.07 - 0.07
Sub total: 17.83 - 0.07 - 0.07 - 0.07
Building 53.86 1.21 3.34% 22.28 - 1.80 0.02 1.82
Hydraulic - - -
Other Civil Works 54.39 0.25 3.34% 24.90 - 1.82 0.00 1.82
Plant & Machinery 589.64 7.41 5.28% 352.61 214.60 19.80 0.20 20.00
Lines & Cable Network 1,194.58 9.07 5.28% 610.38 388.81 42.54 0.24 42.78
Vehicles 11.94 - 5.28% 10.55 11.23 0.04 - 0.04
Furniture & Fixtures 15.83 0.78 6.33% 10.53 9.20 0.42 0.02 0.44
Office Equipment 26.30 1.46 6.33% 19.41 16.80 0.60 0.05 0.65
SUB TOTAL 1,964.36 20.18 3.44% 1,050.73 640.64 67.10 0.53 67.63 Ad d : Consumers contribution deducted from
service connection under O.H.lines & cable
network
223.44 5.03 5.28% 91.68 11.80 0.13 11.93
Ad d : Assets not belonging to the entity 1,424.35 186.25 - - -
3,612.16 211.46 1,142.41 640.64 78.89 0.66 79.56
(All amount in Rs. Crores) Depreciation
Table 13: Depreciation claimed by APDCL for FY 2017-18(Rs Crores)
Grant for assets
not belonging
to entity
(RGGVY, MNRE
etc.)
Co
nsu
me
r
Co
ntr
ibu
tio
nTotal
As on
01.04.2005
As on
01.04.2017Sub total
Grants Available - 1,911.09 1,911.09 3,211.21 223.44 5,345.73
GFA (excluding Consumer Contribution and assets
not belonging to company)1,095.63 868.73 1,964.36 1,424.35 223.44 3,612.16
CWIP - 2,897.86 2,897.86 106.21 3,004.07
Total 1,095.63 3,766.59 4,862.22 1,530.56 223.44 6,616.22
Cumulative grants apportioned in the ratio of GFA
and CWIP
GFA - 440.78 440.78 2,988.38 3,429.15
CWIP - 1,470.31 1,470.31 222.83 1,693.14
Total - 1,911.09 1,911.09 3,211.21 - 5,122.30
Depreciation calculated as per the Regulation on
the GFA 37.72 29.91 67.63 - 67.63
Weighted Average Rate of Depreciation (%) 3.44% 3.44% 3.44% -
Depreciation to be deducted on the assets built on
the grants component on 90% asset value - 15.17 15.17 - 15.17
Depreciation claimed 37.72 14.73 52.45 - - 52.45
State Govt. grant
As on 01.04.2017
Particulars
4.57 The depreciation amount claimed works out to Rs. 52.45 Crores as shown above.
It is to be noted that the conversion of loan to grant as per the UDAY scheme did
not materialise during FY 2017-18 and the effect of the same has not been
True-up Petition for FY 2017-18
Assam Power Distribution Company Limited (APDCL) Page 28
considered.
4.58 In regard to the above claim, the following points are detailed below:
Rates of depreciation as notified in addendum to MYT Regulations 2015
are considered
As depreciation on assets created out of consumer contribution was not
charged in Profit and Loss account, the same has also not been considered
for claim
No funding from grant for Fixed Assets vis-à-vis CWIP transferred to
APDCL consequent to unbundling of erstwhile ASEB as on 1st April, 2005.
As such, total depreciation on the opening balance of GFA as on transfer
scheme 1st April, 2005 amounting to Rs. 37.72 Crores calculated at the
weighted average rate of 3.44% is claimed in totality
Depreciation on subsequent assets is claimed after apportionment of
available grant. Total amount of depreciation claimed on this account is Rs.
14.73Crores after adjustment of funding from grant for Rs. 15.17 Crores.
4.59 As no depreciation has been charged on assets created out of RGGVY, MNRE as
well as consumer contribution, grant received against such schemes are shown
separately with no claim of depreciation.
4.60 Thus, depreciation of Rs. 52.45 Crores be considered by the Hon’ble Commission
in the true-up of ARR for FY 2017-18.
Interest & Finance Charges
4.61 The Commission has approved interest on loan capital for the year on normative
basis in its previous tariff orders. The normative closing loan of Rs. 432.80
Crores for FY 2016-17 as approved in the true-up of FY 2016-17 was considered
as the normative loan outstanding as on April 1, 2017 during APR of FY 2017-18.
4.62 The Commission considered the amount of loan converted under UDAY to grant
equivalent to the net normative loan outstanding as on April 1, 2016, i.e., Rs.
343.06 Crores, as the net normative loan outstanding was lower than the amount
of loan converted to Grant by the GoA. Further, as the entire net normative loan
outstanding had been converted to grants, the Commission did not consider any
conversion of loan to equity during APR of FY 2017-18.
4.63 The treatment of loans under the UDAY MoU as considered by the Commission is
True-up Petition for FY 2017-18
Assam Power Distribution Company Limited (APDCL) Page 29
reproduced below:
Table 14: Treatment of Loans under UDAY MoU considered by the Commission (Rs Crores)
4.64 Accordingly, the Commission had considered the net addition of loan during FY
2017-18 as the sum of loan of Rs. 79.12 Crores taken for funding the
capitalization during FY 2017-18 and the reduction of loan of Rs. 343.06 Crores
due to conversion to grant. Thus, the Commission had considered a net reduction
of loan of Rs. 263.95Crores in FY 2017-18. Further, the loan repayment was
considered equivalent to depreciation approved. The Commission had
considered the interest rate of 9.40% for the balance loan amount as proposed
by APDCL in accordance with the UDAY MoU. Accordingly, the Commission had
approved interest charges of Rs. 27.41 Crores and finance charges of Rs. 3.78
Crores, thereby allowing Rs. 31.19 Crores as interest & finance charges during
APR of FY 2017-18.
4.65 In this context, it is to be submitted that the UDAY MoU was executed on 4th
January, 2017 and conversion of govt. loan requires going through process up to
the level of Cabinet approval, the same didn’t materialize during FY 2017-18. As
such, the benefit of reduction in interest on Govt. Loan consequent to conversion
as envisaged couldn’t be availed during FY 2017-18 and actual debt structure has
prevailed till the end of FY 2017-18.
4.66 Actual interest and finance charges booked vis-à-vis approved during FY 2017-
18 is presented in the table below:
Table 15: Interest & Finance Charges for FY 2017-18 (Rs Crores)
Particulars Approved Actual Claim
Interest on GoA Loan 193.33 77.67 Interest on Bank Overdraft 7.30 7.30
Sl. Particulars Amount As per UDAY MoU
A GoA Loan for capital works & payment of liabilities (as on Sep
2015) 1510.04
B GoA Loan to be taken over (75% of A) 1132.53
C Grant (75% of B) 849.40
D Equity (25% of B) 283.13
E Total GoA Loan taken over under UDAY 1132.53
Impact of UDAY considered by the Commission
F Net normative loan at the beginning of FY 2016-17 343.06
G Loan converted to Grant in FY 2017-18 343.06 H Loan converted to Equity in FY 2017-18 0.00
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Assam Power Distribution Company Limited (APDCL) Page 30
Particulars Approved Actual Claim Bank Charges 4.26 4.26
Interest on GPF 28.03 28.03
Interest on New Pension Fund 4.93 4.93 Interest on R-APDRP Loan 60.00 60.00 Less: Interest Capitalized 78.03 42.40
Total 31.19 219.82 139.79
4.67 Amount of interest on Govt. Loan and RAPDRP loan allowable as per regulations
with the actual debt structure is depicted below:
Table 16: Interest on GoA loan and RAPDRP loan for FY 2017-18 (Rs Crores)
Particulars
Opening Balance
Addition during
the year
Repayment/ Adj during
the Year
Closing Balance
RoI
Interest
GoA Loan 750.34 105.10 52.45 802.99 10% 77.67
RAPDRP Loan 410.44 173.31 583.75 11.50% 60.00
4.68 The Commission has not allowed interest on RAPDRP Loan, interest on GPF,
interest on NPS etc. In this context, the following points are submitted:
At the time of unbundling, no funding was accommodated to APDCL
against the accumulated GPF balance along with interest. The same was
considered as a part of internal resources in the Asset Financing Structure
on formation of the company. Considering the perennial resource crunch
vis-à-vis pendency of approval from concerned authorities, no dedicated
GPF can be formed. As most of the employees covered under GPF will be
attaining superannuation within a very short span of time, formation of
trust at this juncture doesn’t seem operationally prudent. However, as per
the terms of transfer scheme on unbundling, APDCL is committed to
disburse the share of interest on GPF to every incumbent.
All contributions under NPS are being deposited regularly to NSDL as per
norms. However, APDCL is liable to pay interest for the period of delay in
uploading or generation of PRAN etc.
With bank accounts spread all across the state of Assam, APDCL is liable to
pay various charges levied by banks viz. cash handling charges, remittance
charges, and RTGS/NEFT charges wherever applicable.
4.69 With the facts stated above, APDCL claims the right to claim of Rs. 139.79Crores
True-up Petition for FY 2017-18
Assam Power Distribution Company Limited (APDCL) Page 31
on account of Interest and Finance charges in the true-up of ARR for FY 2017-18.
4.70 However, considering the observations made by the Hon’ble Commission in its
previous Tariff Orders, revised claim excluding interest liabilities on GPF as well
as NPS as depicted below is claimed in the instant petition to provide tariff relief
to that extent. Further, the interest on GoA loan amounting to Rs. 77.67 Crores is
kept in abeyance in order to provide tariff relief to that extent.
Table 17: Revised claim for Interest & Finance Charges for FY 2017-18 (Rs Crores)
Particulars Approved Actual Revised Claim
Interest on GoA Loan 193.33 - Bank Charges 4.26 4.26 Interest on GPF 28.03 -
Interest on New Pension Fund 4.93 - Interest on R-APDRP Loan 60.00 60.00 Less: Interest Capitalized 78.03 18.48
Total 31.19 212.52 45.78
Normative IWC claimed in the petition 5.58
Actual IWC (interest on bank overdraft) 7.30
Difference (1.72)
Net claim for interest & finance charges in this petition 47.50
4.71 The Petitioner requests the Hon’ble Commission to allow recovery of Rs.
47.50 Crores on account of interest & finance charges during true-up of
ARR for FY 2017-18, including actual payment of interest on bank
overdraft.
4.72 The Petitioner craves leave of the Hon’ble Commission to allow recovery of
actual cost incurred on interest on GPF as well as NPS at an opportune time
so as to safeguard the financial viability of the utility. Also, the Petitioner
requests to allow recovery of the interest on GoA loan at an opportune time
so as to safeguard the financial viability of the utility.
Interest on Working Capital
4.73 The interest on working capital has been calculated on normative basis in line
with the formula given by the Hon’ble Commission in MYT Regulations, 2015.
The same is depicted in the table below.
True-up Petition for FY 2017-18
Assam Power Distribution Company Limited (APDCL) Page 32
Table 18: Interest on Working Capital for FY 2017-18 (Rs Crores)
Particulars FY 2017-18
MYT Order
Submitted in APR
Approved in APR
True-up Deviation
O&M Expenses-One month 72.51 68.49 72.35 80.95 8.44 2-month Receivables 839.05 869.15 881.92 793.24 (45.81) Maintenance spares @ 15% of O&M Expenses
130.52 123.29 130.23 145.70 15.18
Less: One-month Power Purchase Cost 364.69 359.00 358.16 375.53 10.84 Less: Consumer Security Deposit 579.25 515.02 617.11 600.04 20.79 Total Working Capital 98.14 186.91 109.23 44.33 (53.81) Rate of Interest on WC 12.80% 12.80% 12.60% 12.60% Interest on WC 12.56 23.92 13.76 5.58 (6.98)
4.74 As against Rs. 12.56 Crores approved in the MYT tariff order dated March 31’
2017, Rs. 5.58 Crores has been worked out on normative basis of the interest on
working capital for FY 2017-18. The normative values of the components of
working capital requirement as per revised claims have been considered for the
calculation of the interest on working capital. The rate of interest has been
considered equal to State Bank of India base rate as on 1st April 2017 plus 350
basis points i.e. 12.60%. It is to be noted that the consumer security deposit of
Rs. 35.63 Crores of the permanently disconnected consumers has not been
considered here for calculation of the interest on working capital.
4.75 The interest on working capital amounting to Rs. 5.58 Crores as shown
above may be considered by the Hon’ble Commission in the true-up of ARR
for FY 2017-18.
Interest on Consumer Security Deposit
4.76 The Commission had approved Rs. 15.37 Crores as interest on consumer security
deposit for FY 2017-18 (as approved in tariff order dated March 19’ 2018).
However, actual interest liability on Consumer Security Deposits as per the
Statement of Accounts for FY 2017-18 on the basis of load security as on 1st
April of the year is Rs. 47.57 Crores.
4.77 It is to be noted that the amount of interest on consumer security deposits
amounting to Rs. 47.57 Crores will be liquidated subsequently with energy bills
for respective consumers and actual payment during the year is Rs. 14.43 Crores.
The Petitioner is claiming amount of Rs. 14.43 Crores actually liquidated
during the year to provide tariff relief to that extent. Considering the above,
APDCL prays before the Hon’ble Commission to allow recovery of amount
of Rs. 33.14 Crores (Rs. 47.57 Crores - Rs. 14.43 Crores) pending liquidation
during the year at the time of actual payment in subsequent periods.
True-up Petition for FY 2017-18
Assam Power Distribution Company Limited (APDCL) Page 33
Other Debits
4.78 The Hon’ble Commission had approved an amount of Rs. 14.42 Crores as
provision for bad & doubtful debts during APR for FY 2017-18 in the tariff order
dated March 19’ 2018. Actual amount booked under various heads of ‘Other
Debits’ for FY 2017-18 including bad &doubtful debt written-off is Rs. 23.43
Crores as per the accounts for FY 2017-18.However, it is to be noted that
expenditure head of Rs. 8.99 Crores on purchase of LED, tubelight, fan etc. is not
being claimed as the same is provided separately under the UJALA scheme.
4.79 Further, the Petitioner under the head of ‘Bad and doubtful debt written off’ has
netted-off the amount of Rs. 4.29 Crores shown under the head of ‘Other Income’
in the accounts for FY 2017-18 and accordingly considered the amount of Rs
(13.10 – 4.29) = 8.82 Crores under this head.
4.80 Element-wise break up of expenses booked under ‘Other Debits’ is detailed in the
table below for kind consideration of the Hon’ble Commission.
Table 19: ‘Other Debits’ for FY 2017-18 (Rs Crores)
Particulars FY 2017-18
MYT Order
Submitted in APR
Approved in APR
True-up Deviation
Compensation for injuries, deaths and damage of outsiders
1.34 1.34
Bad and doubtful Debt written off 8.82 8.82 Expenditure on purchase of LED, tube-light, fan etc.
0.00
Provision for Bad & Doubtful Debts 12.42 14.42 14.42 - (12.42 ) Total 12.42 14.42 14.42 10.15 (2.27 )
4.81 The Hon’ble Commission is requested to approve the amount of Rs. 10.15
Crores under the head of ‘Other Debits’ in true-up of ARR for FY 2017-18.
Net Prior Period Income/Expenses
4.82 The Hon’ble Commission has not allowed any amount on this head in its earlier
tariff orders. However, the actual component-wise breakup is detailed in the
table below.
True-up Petition for FY 2017-18
Assam Power Distribution Company Limited (APDCL) Page 34
Table 20: Net prior period income/expense for FY 2017-18 (Rs Crores)
Particulars FY 2017-18
Actual Remarks Prior Period Expenses
Operating Losses for Prior Period 17.26 Adjustment of targeted subsidy for FY 2016-17
Power Purchase for Prior Period 26.42 Adjustment of power purchase cost and wheeling charges of previous periods
Employee Cost related to Prior Period 0.00 Prior Period Depreciation Charges 0.02
Interest & finance relating to Prior Period 9.61 Refund of REC Ltd. against interest earned on fund rcvd. from REC
Administration expenses relating to prior period 0.01 Sub-Total 53.32 Prior Period Income
Interest Income for Prior Period 30.51 Related to auto renewal of STDR relating to previous years
Excess Provision in Prior Period 0.32
Other Income relating to Prior Period 27.34
Rs. 25.33 Crores related to reversal of power swapping arrangement, Rs. 2 Crores related to reversal of excess booking of NEEPCO’s fees and charges in FY 2016-17
Sub- Total 58.17 Net Prior Period Expenses/(Income) (4.85)
4.83 From the above, amounts charged to power purchase for prior period (Rs. 26.42
Crores) and operating losses(Rs. 17.26 Crores) is not claimed in the instant
petition considering observation by Hon’ble Commission in its previous orders.
Likewise, amount charged under the head of ‘Other Income’ relating to prior
period of Rs. 27.34 Crores is not claimed in the instant petition.
4.84 Considering the above, the Petitioner has claimed prior period expenses of
Rs. 9.64 Crores and prior period income of Rs. 30.84 Crores, amounting to
net prior period income of Rs. (30.84 – 9.64) = 21.20 Crores. The Hon’ble
Commission is requested to approve net prior period income of Rs. 21.20
Crores in the true-up of ARR for FY 2017-18.
Return on Equity
4.85 Hon’ble Commission had considered equity of Rs.162.77 Crores and allowed
return@16% on the equity base. The share application money pending allotment
amounting to Rs. 88.04 Crores transferred from erstwhile ASEB on transfer of
trading function to APDCL w.e.f. 01-04-2009 and Rs. 0.63 Crores transferred on
True-up Petition for FY 2017-18
Assam Power Distribution Company Limited (APDCL) Page 35
dissolution of ASEB on 31- 03-2013 was not considered by the Commission in its
tariff order dated March 19’ 2018.The Return on Equity claimed by the Petitioner
in the true-up of ARR for FY 2017-18 vis-à-vis approved earlier is presented in
the table below.
Table 21: Return on Equity for FY 2017-18 (Rs Crores)
Particulars FY 2017-18
MYT Order
Submitted in APR
Approved in APR
True-up Deviation
Opening Equity 162.77 251.45 162.77 162.77 - Net Addition during the Year - - - Closing Equity 162.77 251.45 162.77 162.77 - Average Equity 162.77 251.45 162.77 162.77 - Rate of Return on Equity 16.00% 16.00% 16.00% 16.00% - Return on Equity 26.04 40.23 26.04 26.04 -
4.86 Accordingly, Return on Equity amounting to Rs. 26.04 Crores may be
considered by the Hon’ble Commission.
4.87 It is to be noted that pending notification by Govt. on Share Application Money
Pending Allotment amounting to Rs. 88.04 Crores transferred from erstwhile
ASEB on transfer of trading function to APDCL w.e.f. 01-04-2009 and Rs. 0.63
Crores transferred on dissolution of ASEB on 31-03-2013 during FY 2017-18,
claim is made to the extent of approval by the Hon’ble Commission. The
Petitioner prays before the Hon’ble Commission to allow return on equity
on the above said share application money pending allotment once the
notification on the same is issued.
Other Income
4.88 Other income amount as approved vis-à-vis actual as per statement of accounts
for FY 2017-18 is depicted in the table below.
Table 22: Other Income for FY 2017-18 (Rs Crores)
Particulars FY 2017-18
MYT Order
Submitted in APR
Approved in APR
True-up Deviation
Interest from banks and investment 60.48 87.63 Receipt from sale of LED bulb, Tube light, Fan etc.
- -
Rent from residential buildings 0.03 0.05 Miscellaneous receipts 14.51 26.83 Bad and doubtful debts provided for - dues from consumers*
-
Receipt from Pension Trust 51.11 73.09 Income on seasonal export of surplus 31.47 144.20
True-up Petition for FY 2017-18
Assam Power Distribution Company Limited (APDCL) Page 36
Particulars FY 2017-18
MYT Order
Submitted in APR
Approved in APR
True-up Deviation
power/Revenue from Sale of Power - IEX Total 172.96 157.60 187.24 341.87 168.91
Note: * The same has been netted-off under ‘Bad and doubtful debt written-off’ in ‘Other Debits’ head.
4.89 It is to be noted that the receipt amount of Rs. 14.15 Crores is not being claimed
here as it is provided separately under the UJALA scheme.
4.90 An increase of Rs.168.91Crores is seen on this account over the approved
amount. Primary factor leading to the increase is export of seasonal power from
allocated sources due to significant gap in demand during peak and off-peak
hours. The Hon’ble Commission is requested to approve actual amount of
Rs. 341.87 Crores as ‘Other Income’ in the true-up of ARR for FY 2017-18.
Non-Tariff Income
4.91 Non-tariff income amount as approved vis-à-vis actual as per statement of
accounts for FY 2017-18 is depicted in the table below.
Table 23: Non-Tariff Income for FY 2017-18 (Rs Crores)
Particulars FY 2017-18
MYT Order
Submitted in APR
Approved in APR
True-up Deviation
Rentals from Meters, Service Lines, Capacitors, etc.
22.04 22.04 21.29
Income from recoveries on account of theft of energy/ Malpractices
0.29 0.29 0.74
Delayed Payment Charges from Consumers
147.81 147.81 160.71
Miscellaneous Recoveries 24.9 24.9 21.63 Cross Subsidy Surcharge on Open Access Consumer
9.96 9.96 24.91
Wheeling Charges collected 2.92 2.92 3.92 TOTAL 166.28 207.92 207.92 233.20 66.92
4.92 An increase of Rs.66.92 Crores is seen on this account over the figure as
approved in the MYT order. The Hon’ble Commission is requested to approve
actual amount of Rs. 233.20 Crores as Non-Tariff Income for FY 2017-18
during true-up of ARR for FY 2017-18.
Revenue Grant/Subsidy
4.93 The Commission has approved the tariff on gross basis without factoring the
True-up Petition for FY 2017-18
Assam Power Distribution Company Limited (APDCL) Page 37
targeted subsidy allowed to various category of consumers by Govt. of Assam.
Total amount of targeted subsidy booked during FY 2017-18 as per the
statement of accounts is Rs. 390.10 Crores.
4.94 In addition to the above, Govt. of Assam has also provided an amount of Rs.
560.58 Crores as Operation Fund Requirement as per the UDAY MoU during FY
2017-18. Out of this amount, Rs. 230.28 Crores pertains to FY 2016-17 and Rs.
330.30 Crores pertains to FY 2017-18. In this regard, the Hon’ble Commission in
the last tariff order dated March 19’ 2018 noted that the OFR amount provided
by GoA is for liquidation of outstanding power purchase liabilities and is not
intended to meet the revenue gap or targeted subsidy requirement. The
Commission noted that for various reasons, APDCL has been unable to meet its
obligations to pay the power purchase liabilities, and the GoA, as the owner of
APDCL, has provided OFR cash support under the terms of the UDAY MoU. Under
these circumstances, the amount of OFR support provided by GoA cannot be
considered as income for the purposes of APR.
4.95 In line with the treatment adopted by the Hon’ble Commission, the Petitioner has
not considered the OFR amount as income for arriving at the revenue
gap/(surplus) of the utility.
4.96 As such, subsidy amount of Rs. 390.10 Crores, be considered by the Hon’ble
Commission in the true-up of ARR for FY 2017-18.
Revenue from Sale of Power
4.97 Against the approved revenue of Rs. 5584.71Crores, the actual revenue collected
from sale of power within the state amounted to Rs. 4,369.35 Crores (excluding
targeted subsidy received of Rs. 390.10 Crores). The lesser recovery is primarily
attributed to the following factors:
Negatively skewed consumer mix
4.98 Considering the above, the actual revenue from sale of power within the
state as per the statement of accounts for FY 2017-18 amounting to Rs.
4369.35Crores (excluding govt. subsidy of Rs. 390.10 Crores) be
considered by the Hon’ble Commission in the true-up of ARR for FY 2017-
18.
True-up of ARR for FY 2017-18
4.99 Based on the submission in the above paragraphs, the Aggregate Revenue
Requirement (ARR) and revenue deficit/(surplus) of the utility for FY 2017-18
True-up Petition for FY 2017-18
Assam Power Distribution Company Limited (APDCL) Page 38
vis-à-vis earlier approved figures is as shown below:
Table 24: True-up of ARR for FY 2017-18 (Rs Crores)
Particulars FY 2017-18
MYT Order
Submitted in APR
Approved in APR
Actual True-up Deviation
Power Purchase Expenses 4376.29 4307.99 4297.87 4496.24 4506.31 130.02 O&M Expenses Employee Expenses 728.12 777.96 723.57 742.06 802.39 74.27 R&M Expenses 103.21 109.35 109.41 124.26 124.26 21.05 A&G Expenses 38.82 59.96 35.19 44.72 44.72 5.90 Depreciation 21.93 63.62 18.47 53.94 52.45 30.52 Interest and Finance Charges 14.14 73.86 31.19 219.82 47.50 33.36 Interest on Working Capital 12.56 23.92 13.76 5.58 (6.98) Interest on CSD 40.00 15.95 15.37 47.57 14.43 (25.57) Return on Equity 26.04 40.23 26.04 - 26.04 0.00 Prior Period Debits/(Income) (4.85) (21.20) (21.20) Other Debits, incl. Provisioning for Bad Debts
12.42 14.42 14.42 14.44 10.15 (2.27)
Sharing of gains/(losses) due to excess distribution losses
(13.12) (13.12)
Revenue Gap/(Surplus) of FY 14-15
657.96 657.96 657.96 657.96 657.96 0.00
Carrying Cost on Revenue Gap/(Surplus) of FY 14-15
179.29 179.29 179.29 179.29 179.29 0.00
Revenue Gap/(Surplus) of FY 15-16
354.52 354.52 354.52 354.52 354.52 0.00
Carrying Cost on Revenue Gap/(Surplus) of FY 15-16
45.38 45.38 45.38 45.38 45.38 0.00
Revenue Gap/(Surplus) of FY 16-17
(686.74) (242.25) (686.74) (686.74) (686.74) 0.00
TotalExpenditure 5923.95 6482.16 5835.71 6288.61 6149.93 225.98 Less: Non-Tariff Income 166.28 207.92 207.92 233.20 233.20 66.92 Less: Other Income 172.96 157.60 187.24 345.95 341.87 168.91 Aggregate Revenue Requirement
5584.71 6116.64 5440.55 5709.45 5574.86 (9.85)
Revenue at Approved Tariff (including FPPPA)
5584.71 4869.07 5291.50 4369.35 4369.35 (1215.36)
State Government Targeted Subsidy
- 345.81 - 390.10 390.10 390.10
State Government - OFR - 560.58 - - - - Total Revenue incl. subsidy 5584.71 5775.46 5291.50 4759.45 4759.45 (825.26) Revenue Gap/(Surplus) 0.00 341.18 149.04 950.00 815.40 815.40
Note: The figures mentioned in the ‘Actual’ column are as per the audited accounts
4.100 It can be observed that the Revenue Gap/ Deficit of Rs. 815.40 Crores has to be
recovered by revising the tariff in subsequent periods keeping some legitimate
claims in abeyance to provide tariff relief in the instant petition.
4.101 APDCL requests the Hon’ble Commission to approve total gap of Rs.
815.40Crores during true-up of ARR for FY 2017-18, along with the carrying cost
to be adjusted in the tariff for FY 2019-20.
True-up Petition for FY 2017-18
Assam Power Distribution Company Limited (APDCL) Page 39
4.102 It is to be noted that as per the Commission’s tariff order dated March 19’ 2018,
the Commission had considered revenue gap of Rs. 149.04 Crores in the APR for
FY 2017-18 vis-à-vis revenue gap of Rs. 815.40 Crores arrived during the true-up
exercise. The Commission had observed that the revenue gap arrived during APR
of FY 2017-18 has not been carried forward to the ARR of FY 2018-19 and would
be done during the true-up exercise. Accordingly, the Petitioner requests the
Commission to allow revenue gap of Rs. 815.40 Crores in tariff for FY 2019-20.
4.103 As per Regulation 10.6 of the MYT Regulations 2015, the carrying cost is to be
allowed for the trued-up amount (positive or negative) at the State Bank of India
base rate as on 1st April of the respective year plus 350 basis points. Carrying
cost on the trued-up revenue gap has been considered for FY 2017-18 (half
year), FY 2018-19 (full year) and FY 2019-20 (half year). The total revenue gap
along with the carrying cost is as shown below.
Table 25: Revenue Gap along with carrying cost for FY 2017-18 (Rs. Crores)
Particulars Rate of
Interest Amount (Rs. Crores)
Revenue Gap/(Surplus) for FY 2017-18 815.40
Carrying/(Holding) cost for FY 2017-18 (half Year) 12.60% 51.37
Carrying/(Holding) cost for FY 2018-19 (full Year) 12.20% 99.48
Carrying/(Holding) cost for FY 2019-20 (half Year) 12.45% 50.76
Total Carrying/(Holding) Cost 201.61 Total Revenue Gap for FY 2017-18 to be adjusted in FY 2019-20
1017.01
4.104 Accordingly, the Petitioner requests the Hon’ble Commission to allow total
revenue gap of Rs. 1017.01 Crores on account of true-up of ARR for FY 2017-18.
4.105 The Petitioner submits that the present true-up is being submitted based on the
provisional accounts. The final audited accounts along with report from
statutory auditor is yet to be received. The receipt is expected to be received in
December 2018. As the petition will go through the process of scrutiny,
validation till notification for public, Hon’ble Commission is requested to admit
the instant petition pending submission of statutory audit report. The CAG audit
will start after receiving the statutory audit report. However, it is to be submitted
that APDCL is committed to all endeavors to ensure submission of audit report as
early as possible.
True-up Petition for FY 2017-18
Assam Power Distribution Company Limited (APDCL) Page 40
5: PRAYER
APDCL requests the Hon’ble Commission to:
a. To admit the petition for true-up of ARR for FY 2017-18
b. To approve the amount of revenue gap for true-up of ARR for FY 2017-18 as
mentioned above
c. To condone any inadvertent omissions/ errors/ shortcomings and permit the
petitioner to add/ change/ modify/ alter this filing and make further
submissions as may be required at a future date
d. To allow further submissions, addition and alteration to this Petition as may
be necessitated from time to time
e. Treat the filing as complete in view of substantial compliance as also the
specific requests for waivers with justification placed on record
f. To grant any other relief as the Hon'ble Commission may consider
appropriate
g. And pass such other and further orders as are deemed fit and proper in the
facts and circumstances of the case in the interest of justice
BY THE APPLICANT THROUGH
General Manager (Tariff Regulatory Cell)
APDCL, Guwahati