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    Comments byDistribution Committee

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    11/11/2014 2

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    11/11/2014CERC 3

    PETITIONER(generators,transmission

    licensee, Distributionlicensee etc)

    RESPONDENTS(distribution

    companies, consumergroups etc)

    ARGUMENTS

    ORDERSREVIEW

    PROCEEDINGS(before SERC)

    Appeal inAppellateTribunal

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    Section 61: Guiding principles for tariff determination.

    Section 181 : Empowers SERC to frame terms and

    conditions of tariff under section 61

    Section 182 : Requires SERC to lay regulations before theState Legislature

    Section 62: Tariff is determined by SERC under section 62

    Section 63: Tariff determined through competitive bidding,

    need to be adopted by SERC under section 63

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    Promote Multi-Year Tariff (MYT) framework.Tariff design : Linkage of tariffs to cost of service

    Encourage efficiency in operations by sharing of gains

    between licensees and consumers.To encourage better operating performance, norms should be efficient,

    relatable to past performance , capable of achievement and progressivelyreflecting increased efficiencies

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    The Appropriate Commission shall, subject to the provisions of this Act, specify the terms and conditions for the determination of tariff,and in doing so, shall be guided by the following, namely:- the principles and methodologies specified by the Central Commission

    for determination of the tariff applicable to generating companies andtransmission licensees;the generation, transmission, distribution and supply of electricity areconducted on commercial principles ;the factors which would encourage competition, efficiency, economicaluse of the resources , good performance and optimum investments;safeguarding of consumers' interest and at the same time, recovery ofthe cost of electricity in a reasonable manner;the principles rewarding efficiency in performance;

    multi-year tariff principles ;that the tariff progressively reflects the cost of supply of electricityand also reduces cross-subsidies in the manner specified by the

    Appropriate Commission;the promotion of co-generation and generation of electricity fromrenewable sources of energy;

    the National Electricity Policy and tariff policy 11/11/2014CERC 7

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    The Appropriate Commission shall determine thetariff in accordance with provisions of this Act for

    (a) supply of electricity by a generating company to adistribution licensee;

    (b) transmission of electricity;

    (c) wheeling of electricity &

    (d) retail sale of electricity.

    Retail Tariff for consumers is in the exclusive domain of the StateRegulators

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    Section 63: Notwithstanding anythingcontained in section 62, the Appropriate

    Commission shall adopt the tariff if such tariff

    has been determined through transparent

    process of bidding in accordance with the

    guidelines issued by the Central Government

    Purchase of Power through Power Exchange may be consideredunder this category .?!!

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    Function of Central Commission

    (1) The Central Commission shall discharged the following functions, namely:-(a) To regulate the tariff of generating companies would owned or

    controlled by the Central Government;(b) to regulate the tariff of generating companies other than those

    owned or controlled by the Central Government specified inclause (a); if such generating companies enter into or otherhave a composite scheme for generation and sale of electricityin more than one State;

    (c) to regulate the inter-State transmission of electricity;(d) to determine tariff for inter-State transmission of electricity;(e) To issue licences to persons to function as transmission

    licensee and electricity trader with respect to their inter-State operations;

    (f) to adjudicate upon disputes involving generating companies ortransmission licensee in regard to matters connected with

    clause (a) to (d) above and to refer any dispute for arbitration;11/11/2014CERC 10

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    Function of State Commission

    (1) The State Commission shall discharged the following functions, namely:-a) determine the tariff for generation, supply, transmission and

    wheeling of electricity, wholesale, bulk or retail, as the case maybe, within the State:Provided that where open access has been permitted to a categoryof consumers under section 42, the State Commission shalldetermine only the wheeling charges and surcharge thereon, if any,for the said category of consumers;

    b) regulate electricity purchase and procurement process ofdistribution licensees including the price at which electricity shallbe procured from the generating companies or licensees or from

    other sources through agreements for purchase of power fordistribution and supply within the State ;c) facilitate intra-State transmission and wheeling of electricity;d) issue licences to persons seeking to act as transmission licensees,

    distribution licensees and electricity traders with respect to theiroperations within the State;

    11/11/2014CERC 11

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    e) promote co-generation and generation of electricity from

    renewable sources of energy by providing suitable measuresfor connectivity with the grid and sale of electricity to anyperson, and also specify, for purchase of electricity from suchsources, a percentage of the total consumption of electricityin the area of a distribution license e;

    f) adjudicate upon the disputes between the licensees, and

    generating companies and to refer any dispute for arbitration;g) levy fee for the purposes of this Act;h) specify State Grid Code consistent with the Grid Code specified

    under clause (h) of sub-section (1) of section 79i) specify or enforce standards with respect to quality, continuity

    and reliability of service by licensees;j) fix the trading margin in the intra-State trading of electricity, ifconsidered, necessary; and

    k) discharge such other functions as may be assigned to it underthis Act.

    EA 2003: Section 86: Function of State Commission

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    (2) The State Commission shall advise the StateGovernment on all or any of the following matters,namely :-.

    (i) promotion of competition, efficiency and economy in

    activities of the electricity industry;(ii) promotion of investment in electricity industry;(iii) reorganization and restructuring of electricity

    industry in the State;

    (iv) matters concerning generation, transmission,distribution and trading of electricity or any othermatter referred to the State Commission by thatGovernment

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    (3) The State Commission shall ensure transparencywhile exercising its powers and discharging itsfunctions.

    (4) In discharge of its functions, the State Commission

    shall be guided by the National Electricity Policy,National Electricity Plan and tariff policy publishedunder section 3 .

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    According to Para 5.3.2 of National Electricity Policy 2005;The STU is responsible for planning and development of theintrastate transmission system. Network expansion shouldbe planned and implemented keeping in view of theanticipated transmission needs that would be incident onthe system in the open access regime. STU should

    undertake network expansion after identifying therequirements in consultation with stakeholders and takingup the execution after due regulatory approvalsAccording to Para 5.3.5 of National Electricity Policy 2005;The transmission capacity would be planned and built to

    cater to both the redundancy levels and margins keeping inview international standards and practices. A well plannedand strong transmission system will ensure not only optimalutilization of transmission capacities but also of generationfacilities and would facilitate achieving ultimate objectiveof cost effective delivery of power.

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    According to the National Electricity plan; We need

    heavy investment to upgrade our transmission system to thetune of N-1 & N-1-1 & N-2 requirement as envisaged inthe section of the Para 6 - Reliability criteria, in the CEATRANSMISSION PLANNING CRITERIA, 2013 to avoid localisedblackouts.

    Again we have a mandatory requirement for upgradingour transmission protection system, as envisaged in theCentral Electricity Authority (Grid Standards) Regulations2010 which is a basic requirement for reliability of supply inthe state.

    Grid visibility and protection coordination is anotherarea for urgent investment in communication through FibreOptic cable network and wireless network. Thecommunication system of the transmission licensee shallcomply with Central Electricity Authority (TechnicalStandards for Connectivity to the Grid) Regulations, 2007 and

    our Transmission system needs to be upgraded accordingly.

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    According to Para 2.2 of Tariff policy 2006; the CentralElectricity Regulatory Commission (CERC) and StateElectricity Regulatory Commissions (SERCs) shall be guidedby the tariff policy in discharging their functions includingframing the regulations under section 61 of the Act .According to Para 2.3 of Tariff policy 2006; RegulatoryCommissions shall be guided by the principles andmethodologies specified by the Central Commission fordetermination of tariff applicable to generating companiesand transmission licensees.According to Para 5.0 of Tariff policy 2006; the generalapproach to transmission tariff should be based on a)Return on Investment, b) Equity Norms, c) Depreciation, d)Cost of Debt, e) Cost of Management of Foreign ExchangeRisk, f) Operating Norms, g) Renovation and Modernization& (h) Multi Year Tariff

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    Balance needs to be maintained between the interests ofconsumers and the need for investments while laying down rateof return .The Central Commission would notify, from time to time, therate of return on equity for generation and transmission projectskeeping in view the assessment of overall risk and the prevalentcost of capital which shall be followed by the SERCs also. Therate of return notified by CERC for transmission may beadopted by the State Electricity Regulatory Commissions(SERCs) for distribution with appropriate modification takinginto view the higher risks involved .The State Commission may consider distribution margin asbasis for allowing returns in distribution business at anappropriate time. The considerations while preparing such anapproach would, inter-alia, include issues such as reduction inAggregate Technical and Commercial losses, improving thestandards of performance and reduction in cost of supply.

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    For financing of future capital cost of projects, a Debt

    : Equity ratio of 70:30 should be adoptedThe equity in excess of this norm should be treated asloans advanced at the weighted average rate ofinterest and for a weighted average tenor of the longterm debt component of the project after ascertainingthe reasonableness of the interest rates and takinginto account the effect of debt restructuring done, ifany.In case of equity below the normative level, the actualequity would be used for determination of Return onEquity in tariff computations.

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    The Central Commission may notify the rates of

    depreciation in respect of generation and transmissionassets. The depreciation rates so notified would alsobe applicable for distribution with appropriatemodification as may be evolved by the Forum of

    RegulatorsThe rates of depreciation so notified would beapplicable for the purpose of tariffs as well asaccounting.

    Benefit of reduced tariff after the assets have beenfully depreciated should remain available to theconsumers.

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    Except for the cases referred to in para 5.3 (h)(2), theoperating parameters in tariffs should be at normative levels only and not at lower of normative and actuals .The Central Commission would, in consultation with theCentral Electricity Authority, notify operating norms fromtime to time for generation and transmission. The SERCwould adopt these norms. In cases where operationshave been much below the norms for many previousyears, the SERCs may fix relaxed norms suitably anddraw a transition path over the time for achieving thenorms notified by the Central CommissionOperating norms for distribution networks would benotified by the concerned SERCs. For uniformity ofapproach in determining such norms for distribution, theForum of Regulators should evolve the approach includingthe guidelines for treatment of state specific distinctivefeatures

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    1) Section 61 of the Act states that the Appropriate Commission, for

    determining the terms and conditions for the determination of tariff,shall be guided inter-alia, by multi-year tariff principles. The MYTframework is to be adopted for any tariffs to be determined from April1, 2006. The framework should feature a five-year control period.The initial control period may however be of 3 year duration for

    transmission and distribution if deemed necessary by the RegulatoryCommission on account of data uncertainties and other practicalconsiderations.2) In cases where operations have been much below the norms formany previous years the initial starting point in determining the

    revenue requirement and the improvement trajectories should berecognized at relaxed levels and not the desired levels.Suitable benchmarking studies may be conducted to establish thedesired performance standards. Separate studies may be requiredfor each utility to assess the capital expenditure necessary to meetthe minimum service standards .

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    3) Once the revenue requirements are established atthe beginning of the control period, the RegulatoryCommission should focus on regulation of outputs andnot the input cost elements. At the end of the controlperiod, a comprehensive review of performance maybe undertaken.4) Uncontrollable costs should be recovered speedilyto ensure that future consumers are not burdened with

    past costs. Uncontrollable costs would include (but notlimited to) fuel costs, costs on account of inflation,taxes and cess, variations in power purchase unit costsincluding on account of hydro-thermal mix in case of

    adverse natural events

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    5) Clear guidelines and regulations on information disclosure may bedeveloped by the Regulatory Commissions. Section 62 (2) of the Actempowers the Appropriate Commission to require licensees to furnishseparate details, as may be specified in respect of generation,transmission and distribution for determination of tariff .

    (i) Benefits under CDM Tariff fixation for all electricity projects(generation, transmission and distribution) that result in lower GreenHouse Gas (GHG) emissions than the relevant base line should take intoaccount the benefits obtained from the Clean Development Mechanism(CDM) into consideration, in a manner so as to provide adequateincentive to the project developers.While it is recognized that the State Governments have the right toimpose duties, taxes, cess on sale or consumption of electricity, thesecould potentially distort competition and optimal use of resourcesespecially if such levies are used selectively and on a non- uniform basis.For realizing the goal of making available electricity to consumers atreasonable and competitive prices, it is necessary that such duties are

    kept at reasonable level.

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    According to Para 6.1 of Tariff policy 2006; powerprocurement for future requirements should be through atransparent competitive bidding mechanism using theguidelines issued by the Central Government vide gazettenotification dated 19th January, 2005. These guidelinesprovide for procurement of electricity separately for baseload requirements and for peak load requirements. This

    would facilitate setting up of generation capacitiesspecifically for meeting peak.According to Para 6.2.1 of Tariff policy 2006; A two-parttariff structure should be adopted for all long term contractsto facilitate Merit Order dispatch. According to NationalElectricity Policy, the Availability Based Tariff (ABT) is to beintroduced at State level by April 2006. This frameworkwould be extended to generating stations (including gridconnected captive plants of capacities as determined by theSERC). The Appropriate Commission may also introducedifferential rates of fixed charges for peak and off peakhours for better management of load.

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    According to Para 6.3 of Tariff policy 2006; captive

    plants could inject surplus power into the grid subjectto the same regulation as applicable to generatingcompanies. Firm supplies may be bought from captiveplants by distribution licensees using the guidelines

    issued by the Central Government under section 63 ofthe Act. The prices should be differentiated for peak and off-peak supply and the tariff should include variable cost

    of generation at actual levels and reasonablecompensation for capacity charges. Alternatively, a frequency based real time mechanismcan be used and the captive generators can be allowed

    to inject into the grid under the ABT mechanism

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    According to Para 6.4 of Tariff policy 2006; the appropriate Commissionshall fix a minimum percentage for purchase of energy from such sources

    taking into account availability of such resources in the region and itsimpact on retail tariffs. Such percentage for purchase of energy shouldbe made applicable for the tariffs to be determined by the SERCs latestby April 1, 2006. SERCs shall also reserve a minimum percentage for purchase of solarenergy from the date of notification in official gazette which will go upto 0.25% by the end of 2012-13 and further up to 3% by 2022 an appropriate mechanism such as Renewable Energy Certificate (REC)would need to evolved. Through such mechanism, the renewable energybased generation companies can sell the electricity to local distributionlicensee at the rates for conventional power and can recover thebalanced cost by selling certificate to other distribution companies andobligated entities enabling the latter to meet their renewable powerpurchase obligations. In view of the comparatively higher cost ofelectricity from solar energy currently, the REC mechanism should alsohave solar specific REC It will take some time before non-conventional technologies cancompete with conventional sources in terms of cost of electricity.Therefore, procurement by distribution companies shall be done at

    preferential tariffs determined by the Appropriate Commission

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    According to Para 7.1.4 of Tariff policy 2006; STU should undertake networkexpansion after identifying the requirements in consonance with the National

    Electricity Plan and in consultation with stakeholders, and taking up the executionafter due regulatory approvals.As per Para 7.1.7 of Tariff Policy; after coming into effect of the CERC regulationon framework for the inter-State transmission ,a similar approach should beimplemented by SERCs in next two years for the intra-State transmission, dulyconsidering factors like voltage, distance, direction and quantum of flow.As per Para 7.1.8 of Tariff Policy; Metering compatible with the requirements ofthe proposed transmission tariff framework should be established on prioritybasis. The metering should be compatible with ABT requirements, which wouldalso facilitate implementation of Time of Day (ToD) tariffs.According to Para 7.2.2 of Tariff policy 2006; The Appropriate Commission mayrequire necessary studies to be conducted to establish the allowable level ofsystem loss for the network configuration, and the capital expenditure requiredto augment the transmission system and reduce system losses. Since additionalflows above a level of line loading leads to significantly higher losses, STUshould ensure upgrading of transmission systems to avoid the situations ofoverloading. The Appropriate Commission should permit adequate capitalinvestments in new assets for upgrading the transmission system .

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    Supply of reliable and quality power of specified standards in anefficient manner and at reasonable rates is one of the main objectives of

    the National Electricity Policy. The State Commission should determineand notify the standards of performance of licensees with respect toquality, continuity and reliability of service for all consumers. It isdesirable that the Forum of Regulators determines the basic frameworkon service standards. A suitable transition framework could beprovided for the licensees to reach the desired levels of service asquickly as possible. Penalties may be imposed on licensees inaccordance with section 57 of the Act for failure to meet the standards.

    Making the distribution segment of the industry efficient and solvent isthe key to success of power sector reforms and provision of services ofspecified standards . Therefore, the Regulatory Commissions need tostrike the right balance between the requirements of the commercialviability of distribution licensees and consumer interests . Loss makingutilities need to be transformed into profitable ventures which can raisenecessary resources from the capital markets to provide services ofinternational standards to enable India to achieve its full growthpotential. Efficiency in operations should be encouraged. Gains ofefficient operations with reference to normative parameters should beappropriately shared between consumers and licensees

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    This would minimise risks for utilities and consumers, promoteefficiency and appropriate reduction of system losses and attractinvestments and would also bring greater predictability toconsumer tariffs on the whole by restricting tariff adjustments toknown indicators on power purchase prices and inflation indices.The framework should be applied for both public and privateutilities.

    The State Commissions should introduce mechanisms for sharingof excess profits and losses with the consumers as part of theoverall MYT framework . In the first control period the incentivesfor the utilities may be asymmetric with the percentage of theexcess profits being retained by the utility set at higher levels thanthe percentage of losses to be borne by the utilityAs indicated in para 5.3 (h), the MYT framework implemented inthe initial control period should have adequate flexibility toaccommodate changes in the baselines consequent to metering

    being completed .

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    At the beginning of the control period when the actual costsform the basis for future projections, there may be a largeuncovered gap between required tariffs and the tariffs that arepresently applicable. The gap should be fully met throughtariff charges and through alternative means that could inter-alia include financial restructuring and transition financing .Incumbent licensees should have the option of filing for separaterevenue requirements and tariffs for an area where the StateCommission has issued multiple distribution licenses, pursuant tothe provisions of Section 14 of the Act read with para 5.4.7 ofthe National Electricity PolicyAppropriate Commissions should initiate tariff determination andregulatory scrutiny on a suo moto basis in case the licensee doesnot initiate filings in time. It is desirable that requisite tariffchanges come into effect from the date of commencement ofeach financial year and any gap on account of delay in filingshould be on account of licensee .

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    All power purchase costs need to be considered legitimateunless it is established that the merit order principle hasbeen violated or power has been purchased atunreasonable rates. The reduction of Aggregate Technical& Commercial (ATC) losses needs to be brought about butnot by denying revenues required for power purchase for

    24 hours supply and necessary and reasonable O&M andinvestment for system up gradation. Consumers,particularly those who are ready to pay a tariff whichreflects efficient costs have the right to get uninterrupted24 hours supply of quality power. Actual level of retailsales should be grossed up by normative level of T&Dlosses as indicated in MYT trajectory for allowing powerpurchase cost subject to justifiable power purchase mixvariation (for example, more energy may be purchasedfrom thermal generation in the event of poor rainfall) andfuel surcharge adjustment as per regulations of the SERC.

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    ATC loss reduction should be incentivised by linking returns in a

    MYT framework to an achievable trajectory. Third partyverification of energy audit results for different areas/localitiescould be used to impose area/locality specific surcharge forgreater ATC loss levels and this in turn could generate localconsensus for effective action for better governance. The SERCsmay also encourage suitable local area based incentive and

    disincentive scheme for the staff of the utilities linked toreduction in losses The SERC shall undertake independent assessment of baselinedata for various parameters for every distribution circle of thelicensee and this exercise should be completed latest by March,2007.As the metering is completed upto appropriate level in thedistribution network, latest by March, 2007, it should bepossible to segregate technical losses. Accordingly technicalloss reduction under MYT framework should then be treated asdistinct from commercial loss reduction which require adifferent approach.

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    Section 65 of the Act provides that no direction of the StateGovernment regarding grant of subsidy to consumers in thetariff determined by the State Commission shall beoperative if the payment on account of subsidy as decidedby the State Commission is not made to the utilities and thetariff fixed by the State Commission shall be applicable fromthe date of issue of orders by the Commission in this regard.The State Commissions should ensure compliance of this

    provision of law to ensure financial viability of theutilities . To ensure implementation of the provision of the

    law, the State Commission should determine the tariffinitially, without considering the subsidy commitment by theState Government and subsidised tariff shall be arrived atthereafter considering the subsidy by the State Governmentfor the respective categories of consumers

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    4. Working capital should be allowed duly recognising thetransition issues faced by the utilities such as progressiveimprovement in recovery of bills. Bad debts should berecognised as per policies developed and subject to theapproval of the State Commission.5. Pass through of past losses or profits should be allowed to

    the extent caused by uncontrollable factors. During thetransition period controllable factors should be to theaccount of utilities and consumers in proportionsdetermined under the MYT framework6. The contingency reserves should be drawn upon with prior

    approval of the State Commission only in the event ofcontingency conditions specified through regulations by theState Commission. The existing practice of providing fordevelopment reserves and tariff and dividend controlreserves should be discontinued

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    Regulatory Asset: should be done only as exception, andsubject to the following guidelines

    The circumstances should be clearly defined through regulations,and should only include natural causes or force majeureconditions . Under business as usual conditions, the openingbalances of uncovered gap must be covered through transitionfinancing arrangement or capital restructuring Carrying cost of Regulatory Asset should be allowed to the utilities Recovery of Regulatory Asset should be time-bound and within aperiod not exceeding three years at the most and preferably withincontrol period

    The use of the facility of Regulatory Asset should not be repetitiveIn cases where regulatory asset is proposed to be adopted, itshould be ensured that the return on equity should not becomeunreasonably low in any year so that the capability of the licenseeto borrow is not adversely affected.

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    Tariff design & Cross subsidy : Subsidies should be targetedeffectively and in transparent manner. As a substitute ofcross-subsidies, the State Government has the option ofraising resources through mechanism of electricity duty andgiving direct subsidies to only needy consumers. This is abetter way of targeting subsidies effectively.

    In accordance with the National Electricity Policy, consumers belowpoverty line who consume below a specified level, say 30 units permonth, may receive a special support through cross subsidy. Tariffsfor such designated group of consumers will be at least 50% of theaverage cost of supply. This provision will be re-examined afterfive years.

    By the end of year 2010-2011 SERC should ensure that tariffsshould be within 20 % of the average cost of supply.subsidized rates of electricity should be permitted only up to apre-identified level of consumption beyond which tariffs reflectingefficient cost of service should be charged from consumers .

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    Two-part tariffs featuring separate fixed and variablecharges and Time differentiated tariff shall beintroduced on priority for large consumers (say,consumers with demand exceeding 1 MW) within oneyear. This would also help in flattening the peak andimplementing various energy conservation measures.

    The retail tariffs would reflect the relative efficiencyof distribution companies in procuring power atcompetitive costs, controlling theft and reducing otherdistribution losses

    The State Commission may provide incentives toencourage metering and billing based on meteredtariffs, particularly for consumer categories that arepresently unmetered to a large extent. The meteredtariffs and the incentives should be given wide publicity

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    A consumer who is permitted open access will have to make payment tothe generator, the transmission licensee whose transmission systems areused, distribution utility for the wheeling charges and, in addition, thecross subsidy surcharge. The computation of cross subsidy surcharge,needs to be done in a manner that it compensates the distributionlicensee on its obligation to supply in the area of his licence. when open access is allowed the surcharge for the purpose of sections38,39,40 and sub-section 2 of section 42 would be computed as thedifference between (i) the tariff applicable to the relevant category ofconsumers and (ii) the cost of the distribution licensee to supplyelectricity to the consumers of the applicable classWheeling charges should be determined on the basis of same principlesas laid down for intra-state transmission charges and in addition wouldinclude average loss compensation of the relevant voltage level.In case of outages of generator supplying to a consumer on open access,standby arrangements should be provided by the licensee on thepayment of tariff for temporary connection to that consumer category asspecified by the Appropriate Commission.

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    The Determination of tariffs should be based on costplus principle based on normative benchmarksThe landed cost at various voltage levels shall bearrived suitably by identifying the interfacing pointswith transmission.Capital investment for Time synchronized meteringsystem for accurate determination of losses at variousvoltage levels is a pre-requisite for evolution ofappropriate bench marks.Based on the accurate data on loss study, an investmentplan for loss reduction can be arrivedExisting asset has to be identified and segregated on thebasis of time of creation and source of creation for thedetermination of actual depreciation.Assets with expired useful life span need additional 40%or more R&M expenses, till the full replacement of thesame with appropriate capital investment plan .

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    Expenditure resulting in the extended life of theunit/station beyond useful life need to beconsidered accordingly.

    Expenditure necessary for sustaining the operationof the plant on account of obsolescence orchanged working conditions etc. Option for the Licensee for availing a special

    allowance 130% of the normative O&M expenseand Thereafter, escalated @ 10 % every year From the next financial year from the respective

    date of the completion of useful life

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    Hydro tariff shall be decided for individual projects withseasonal tariff. Only the cost of selling the power shall be reflected inthe O&M. This means expense for metering, billing,collection, restoration of supply during normalconditions including the employee cost only .All the capital works, shifting of lines by deposit works,DSM activities, consultancy services for Government &local bodies, other business activities, natural calamityworks shall not be included in the R&M expenses.

    For the demarcation and accounting of the above activitiesappropriately and accurately, we need to have an exclusiveorganizational set up for Capital works.

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    Energy conservation and energy efficiency

    campaign role of our organization may betransferred to agencies like EMC, since it is againstthe business philosophy of the organization.The responsibility for new sources of power

    generation including augmentation of generationcapacity may be exempted from the distributionbusiness/ licensee, since generation is a de-licensedactivity.

    In distribution wing, a power procurement groupmay be constituted .

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    Social obligation is the responsibility of the state

    government and the distribution business/ licenseeshall be allowed to function on commercialprinciples.According to para 8(3) of national tariff policy, the

    tariff of all categories of consumers shall be within 20% of cost of power supply. A road map forachieving the same may be included in theregulation.

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    Interest on Working Capital +

    O& M ChargesInterest On Loan

    Depreciation

    ROE

    Cost of Power Purchase

    Transmission Charges

    NLDC/RLDC/SLDC Charges

    Provision for Bad debts(Minus): Non Tariff Income

    Components of Tariff

    Cost Plus Multi Year Tariff ( 3 years) is adopted by SERC.

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    COMPONENTS OF TARIFF SUMMERY OF REMARKS

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    COMPONENTS OF TARIFF: SUMMERY OF REMARKSPARAMETER KSERC

    draft REMARK

    ROE 14%

    According to 24(2) of CERC T&C of Tariff regulation 2014: Return onequity shall be computed at the base rate of 15.50% for thermalgenerating stations, transmission system including communicationsystem and run of the river hydro generating station, and at the baserate of 16.50% for the storage type hydro generating stations including pumped storage hydro generating stations and run of rivergenerating station with pondage. Hence distribution deserve a

    minimum of 16.5% return

    INTERST ONLOAN

    D E P R E C I A T I O N

    Accordi

    ng toAnnex-I

    Useful life for IT Hardware (7 years) & software (4 years) and nosalvage value for these items need to be specified in tune with CERC

    regulations.Useful life of communication equipment (15 years) needs to bespecified.

    Useful life of electronic/static energy meters need to be specified as 7years.

    Useful life of distribution line shall not be equated with transmissionlines and may be specified as 25 years.

    COMPONENTS OF TARIFF SUMMERY OF REMARKS

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    COMPONENTS OF TARIFF: SUMMERY OF REMARKSPARAMETER KSERC draft REMARK

    O & M

    EXPENSE

    Not asset focused.The methodology for

    arriving the publishedrate is not specified.No consideration of

    aging of the asset

    R&M expense need to be asset focusedand there shall be appropriate level of

    increase after 1st

    10 years and there afterevery 5 years of lifeNormative AMC for 33kV, 11kV & LT

    lines need to be arrived based ongeographical basis (hilly, rural, semi-urbanand urban etc)

    Normative AMC need to be arrived forTr. Station, 11kV bay,33 kV bay etc.

    INTEREST ONWC

    SBBR rate is allowedfor normative WC

    NOMATIVEAVAILABILITY

    100% supplyavailability is targeted0.1% deduction in RoE

    for every 1% deductionin supply availability.

    With out a transmission system that do notsatisfy n-1 criterion, with obsolete assetswith extended life and without appropriateR&M the targeted normative availabilitynot realistic. Even for 400kV transmissionline, 98% of the availability is enough fornormative return .

    COMPONENTS OF TARIFF SUMMERY OF REMARKS

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    COMPONENTS OF TARIFF: SUMMERY OF REMARKS

    PARAMETER KSERC draft

    REMARK

    RENOVATION&MODERNISATION

    No specificdirectives

    Specific plan required for R&M of all assets with

    expired useful life.Additional allowances equivalent to 50%normative depreciation cost for the 1 st year ofextended life and additional 10% increase forevery successive years

    ADDITNL.CAPITALISATION

    Allowed accordingto the specificoriginal approval &conditions

    DEBT EQUITYRATIO

    70 : 30 The existing equity according to the transferscheme and future capital investment accordingly

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    COMPONENTS OF TARIFF: SUMMERY OF REMARKS

    PARAMETER KSERC draft REMARK

    RECOVERY OFFXD. CHARGE

    Need a two part tariff structure for all thecategories. Ensure recovery of investment cost &normative O&M through annual fixed chargecollected monthly.

    Power purchase cost, transmission &distribution loss and variations in O&M expensethrough variable charge.

    REBATE &SURCHARGE

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    Debt equity ratioFor New Projects: 70:30For Existing Projects: as admitted by the Commission in earlier tariffsettingAdditional capitalization & R&M- 70:30Actual debt : Equity ratio in case equity less than 30%

    Return in equity: 16.5% (Post-Tax) proposed in tune with CERC T&C of tariff 2014 Interest on Loan:

    Computed loan wise on normative loan

    After accounting for the cumulative repayments with Depreciationrecovered shall be deemed as repaymentRepayment to be considered from the date of COD

    epreci tion Depreciation rate: Link to useful life of assets in tune with CERC data Repayment linked to depreciation90% of asset value recoverable ( 10% salvage value ) for items excluding ITequipment & software

    100% depreciation for IT equipment & software no salvage valueAfter 12 years balance depreciable value to be spread over balanceuseful life

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    O&M Expenses Administrative ExpensesRepair & Maintenance: Need to be Asset Focused

    Normative AMC for 33 kV lines, 11kV lines, LT lines, Transformerstations, 11kV bay, LT Panel etc need to be arrived. Should be arrived according to geographical requirement ( Hilly,rural, semi urban, urban etc.)

    Appropriate increase after 1st

    10 years and there after every 5 years. Different approach for asset with extended life.Employee Salary & welfare measures

    Employee requirement may be standardized based on asset focus(Line length, Substations, geographical classification etc. A specific % of the total Salary may be accounted for welfare

    measuresCorporate ExpensesMiscellaneous Expenses Reasonable compensation for DA & pay hikes need to befactored into O&M Norms